giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…. . prior rulings in subsequent stages of
the same case absent cogent and compelling reasons such as an intervening change of
controlling law, the availability of new evidence, or the need to correct a clear error or prevent
manifest injustice.” United…
giuffre-maxwell
gov.uscourts.nysd.447706.107.0
4 pg
…Obection to this motion was lodged by Ms. Maxwell on April 8, 2016, Doc. # 88.
Subsequent to the filing of the Objections, Ms. Maxwell obtained a statement issued by
Mr. Cassell and Mr. Edwards related to Edwards and Cassell v…
giuffre-maxwell
gov.uscourts.nysd.447706.232.1
…12. Identify any Health Care Provider from whom You received any treatment for any
physical, mental or emotional condition, that You suffered from subsequent to any
Alleged Defamation by Ghislaine Maxwell, including:
a. the Health Care Provider’s name, address…
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…the af뒫davit, she was paid
$15,000 for their 뒫rst alleged encounter, in the U.K., and $400 for a subsequent alleged sex session at Epstein’s NYC
mansion. A third encounter, she claimed, happened…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.11
18 pg
…at the time, who
6 initially had told me that he would make everyone
7 available for an interview. And subsequent
8 conversations later, no one was available for
9 interview and everybody had an attorney, and I was
10…
giuffre-maxwell
gov.uscourts.nysd.447706.104.0
4 pg
…Obection to this motion was lodged by Ms. Maxwell on April 8, 2016, Doc. # 88.
Subsequent to the filing of the Objections, Ms. Maxwell obtained a statement issued by
Mr. Cassell and Mr. Edwards related to Edwards and Cassell v…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…has
reviewed confidential and sealed materials from Maxwell, the Court subsequently directed the
parties in Dershowitz to confer regarding “reasonable accommodation concerning Mr.
Dershowitz’s requests for various filings and discovery materials from Giuffre v. Maxwell” so as
to be …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s requests are
based on information currently known to her and are given without waiving Ms. Maxwell’s right
to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
1320-17
25 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s requests are
based on information currently known to her and are given without waiving Ms. Maxwell’s right
to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1187.0
3 pg
…the parties unrestricted authority to disclose
publicly the confidential materials from Maxwell--not least of
all because the parties only may agree to downgrade
confidentiality designations for materials that the “designating
party has subsequently produced in this action,” i.e.…
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.447706.1330.2
40 pg
…12. Identify any Health Care Provider from whom You received any treatment for any
physical, mental or emotional condition, that You suffered from subsequent to any
Alleged Defamation by Ghislaine Maxwell, including:
a. the Health Care Provider’s name, address…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…place where they are located.” (cleaned up)).
C. The government’s subpoena to was an unconstitutional
Fourth Amendment seizure.
Although Fourth Amendment challenges typically involve “the subsequent search of the
container rather than to its initial seizure by the authorities, …
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…an opportunity to dispute them. Id. Although Ms. Giuffre
elaborated these false allegations in subsequent filings, eventually, the presiding judge in the
CRVA Action struck them as a sanction against the lawyers who had filed them. But the damage
to…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…Mar. 25, 2021).
3
There is no basis to believe that the protective order or subsequent sealing of documents were
imposed solely for Maxwell’s benefit; Judge McMahon discussed “Maxwell[’s] … degree of pro-
tection” because she “assume[d]…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…improper basis. The LiButti court and subsequent decisions have been
8
Case 1:15-cv-07433-LAP Document 1331-36 Filed 01/05/24 Page 9 of 10
quite clear that the types of questions posed to Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…Jean Luc Brunel ("Brunel") and Alan Dershowitz (“Dershowitz”). Id.
at 3-6.1
1
The judge in the CVRA case subsequently struck these allegations, stating “[a]t this juncture in the proceedings,
these lurid details are unnecessary to the determination…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…Mr. Dershowitz by requiring him to pay Ms. Giuffre's attorneys' fees relating to sealing
Mr. Dershowitz's affidavit and the subsequent work and motion practice related to his continuing
violations of thi s Court's Order. See, e.g.…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…23 SPECIAL MASTER: So that will have to be
24 dealt with in front of Judge Lynch for a
25 subsequent time because I do think that it's
CONFIDENTIAL
Case 1:15-cv-07433-LAP Document 1335-3…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…Opp’n at 1-4 (Doc. 700). Any such implication would be
false. As Ms. Ransome testified and as subsequent investigation has revealed, the photographs
of Ms. Maxwell were actually taken by , placed on a disk, and given to Ms.
…
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