giuffre-maxwell
gov.uscourts.nysd.447706.1198.13_1
19 pg
…produce medical records (indeed none of the witnesses discussed know a single thing about Plaintiff’s medical
conditions), and Plaintiff’s Introduction and Conclusions should be stricken as impertinent and scandalous.
Similarly, Plaintiff devotes pages to inaccurate accounts of Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.44
4 pg
…parties who are not related to the respondent Government. These unnecessary details shall be
stricken."
The two "non-parties" have been Prince Andrew and Alan Dershowitz.
http://jewishbusinessnews.com/2015/04/08/after-vindication-afan-dershowitz-vows-to-sue-s.. …
giuffre-maxwell
gov.uscourts.nysd.447706.269.0
19 pg
…produce medical records (indeed none of the witnesses discussed know a single thing about Plaintiff’s medical
conditions), and Plaintiff’s Introduction and Conclusions should be stricken as impertinent and scandalous.
Similarly, Plaintiff devotes pages to inaccurate accounts of Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.88.0
7 pg
…of
Florida. In pleadings filed in that action, Mr. Edwards made representations on behalf of the
Plaintiff here that were stricken by the Court as “immaterial and impertinent.” These statements
were publicized and subsequently denied by Ms. Maxwell. Thereafter, Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…the NPA (pg. 3) and “The Government was well aware of Jane
Doe No. 3 when it was negotiating the NPA” (pg. 6) were stricken by Judge
Marra.]
13. January 21, 2015 Declaration of Jane Doe No. 3 filed in…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…The entire argument and reference to the transcript must be ignored and stricken
based on Plaintiff’s failure to produce in discovery the transcript she relies on.
6
Case 1:15-cv-07433-LAP Document 1332-1 Filed 01…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…The entire argument and reference to the transcript must be ignored and stricken
based on Plaintiff’s failure to produce in discovery the transcript she relies on.
6
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…pleadings. However, the Court should be aware that DEs 165-3, 185-2 and 185-15 are
pleadings that were stricken pursuant to Rule 12(f) by U.S. District Court Judge Marra and thus
are not, as Plaintiff claims…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…to Rule 37(b), (e) and (f), Fed. R. Civ. P., be stricken;
ii. Ms. Maxwell be awarded the costs of engaging the forensic examiner.
Dated: August 1, 2016.
Respectfully submitted,
/s/ Laura A. Menninger
…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…Epstein and the Government owed them CVRA duties), especially
considering that these details involve non-parties who are not related to the respondent Government. These
unnecessary details shall be stricken.” See Menninger Decl., Ex. D.
5
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…Epstein and the Government owed them CVRA duties), especially
considering that these details involve non-parties who are not related to the respondent Government. These
unnecessary details shall be stricken.” See Menninger Decl., Ex. D.
5
“State verbatim or…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…future pain and
suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims
for these categories of damages must be stricken or evidence as to these damages precluded from
trial under Fed. R. Civ. P. 37(b)(2…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…as discussed
below), the Rule 21 Motion will be denied.
The Court also concludes that portions of the Rule 21 Motion—and related
filings—should be stricken from the record. Pending for this Court’s consideration is a Motion
for…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…future pain and
suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims
for these categories of damages must be stricken or evidence as to these damages precluded from
trial under Fed. R. Civ. P. 37(b)(2…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…new documents she has identified, despite repeated requests for these documents. Id. at 16.
These late disclosures are clearly improper and should be stricken under Rule 37(c), a
matter for a different motion. Nevertheless, these material changes include witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…omitted). “Striking
allegations from a pleading ‘is a drastic remedy to be resorted to only when required for the
purposes of justice,’ and only when the allegations to be stricken have ‘no possible relation to the
controversy.’” Larise Atlantis, Inc…
giuffre-maxwell
1320-33
24 pg
…future pain and
suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims
for these categories of damages must be stricken or evidence as to these damages precluded from
trial under Fed. R. Civ. P. 37(b)(2…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…Amodeo
(“Amodeo I”), 44 F.3d 141, 145 (2d Cir. 1995); accord Maxwell I, 929 F.3d at 51–
52 (observing that material rejected or stricken by court as “redundant,
immaterial, impertinent, or scandalous . . . would not be considered a
judicial…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…allegations were false.
12. On January 5, 2015, Dershowitz filed a motion to intervene to argue to have the
allegations stricken. DE 282. Dershowitz also argued that Ms. Giuffre had not provided a sworn
affidavit attesting to the truth of…
giuffre-maxwell
gov.uscourts.nysd.447706.222.0
10 pg
…Plaintiff’s
Joinder Motion, ordered the portions of the Joinder Motion pertaining to non-parties such as Ms.
Maxwell stricken as ‘immaterial and impertinent,’ and restricted the documents mentioning those
‘lurid details’ from public access.” Id. at 4-5 (citations…