giuffre-maxwell
gov.uscourts.nysd.447706.1035.0
2 pg
…Both Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell have asked for this
Court’s permission to file a List of Decided Motions under seal because the list contains
information that is currently subject to the Sealing Order in this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1036.0
2 pg
…Both Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell have asked for this
Court’s permission to file a List of Decided Motions under seal because the list contains
information that is currently subject to the Sealing Order in this case…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…Maxwell’s Personal and Financial Information ARE Irrelevant to This Action .......... 3
II. Personal (and business) Financial Information Not Subject to Pre-Trial Discovery where it
Relates Solely to Claim for Punitive Damages .................................................................... 5
A. Discovery…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…Maxwell’s Personal and Financial Information ARE Irrelevant to This Action .......... 3
II. Personal (and business) Financial Information Not Subject to Pre-Trial Discovery where it
Relates Solely to Claim for Punitive Damages .................................................................... 5
A. Discovery…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…sexually abused. At several points during her recent
deposition, Ms. Maxwell refused to answer Ms. Giuffre’s questions about Epstein, but instead
told her she should go ask Epstein about the subject. See, e.g., Tr. of Depo. of Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…5. Ms. Maxwell objects to the Requests to the extent they seek information which is
not relevant to the subject matter of the litigation and/or is not reasonably calculated to lead to
the discovery of admissible evidence.
6. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…subpoena demonstrates
that Defendant is not even seeking documents relevant to the matter before this Court, and is
instead attempting to obtain backdoor discovery for other actions.
Ms. Ransome’s responses are subject to the following qualifications, explanations, and
objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…subpoena demonstrates
that Defendant is not even seeking documents relevant to the matter before this Court, and is
instead attempting to obtain backdoor discovery for other actions.
Ms. Ransome’s responses are subject to the following qualifications, explanations, and
objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…non-
parties is no longer appropriate. Plaintiff respectfully requests that the Parties be permitted to
review and publish the sealed materials subject to redactions to protect the names and personally
identifiable information of victims only, which would greatly expedite the…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…subpoena demonstrates
that Defendant is not even seeking documents relevant to the matter before this Court, and is
instead attempting to obtain backdoor discovery for other actions.
Ms. Ransome’s responses are subject to the following qualifications, explanations, and
objections…
giuffre-maxwell
1320-8
12 pg
…sexually abused. At several points during her recent
deposition, Ms. Maxwell refused to answer Ms. Giuffre’s questions about Epstein, but instead
told her she should go ask Epstein about the subject. See, e.g., Tr. of Depo. of Defendant…
giuffre-maxwell
1320-17
25 pg
…5. Ms. Maxwell objects to the Requests to the extent they seek information which is
not relevant to the subject matter of the litigation and/or is not reasonably calculated to lead to
the discovery of admissible evidence.
6. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…5. Ms. Maxwell objects to the Requests to the extent they seek information which is
not relevant to the subject matter of the litigation and/or is not reasonably calculated to lead to
the discovery of admissible evidence.
6. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…the Miami Herald respectfully requests that the
Court enter an order identifying each of these documents as judicial documents subject to both the
First Amendment right of access and the common law right of access.2
Given the presumption of…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…Therefore, when referring to
documents “to identify” means to give, to the extent known, the (i) type of documents, (ii)
general subject matter; (iii) date of the documents; and (iv) author(s), addressee(s) and
recipient(s). In the alternative…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…Defendant)
PTF DEF PTF DEF PTF DEF
CITIZEN OF THIS STATE [ )1 [)(]I 1 CITIZEN OR SUBJECT OF A f ]3I ]3 INCORPORATED and PRINCIPAL PLACE [ )5 I J 5,…
Comments