giuffre-maxwell
gov.uscourts.nysd.447706.648.0
4 pg
…modifying its Order of October 3, 2016, ECF
#455 for the following reasons:
Subsequent to the hearing on February 16, 2017 the parties have conferred extensively
about the viability of the existing case management deadlines. The parties agree that the…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…to
Reopen Defendant’s Deposition Based on Defendant’s Production of New, Key Documents because
Defendant produced documents subsequent to her deposition about which she should answer
questions. The Court has already ruled that reopening a party deposition is appropriate…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…that time, they say. The lawyers also
want to discuss subsequent interactions with their client in New York City later that year, the letter says.
"The interview could be conducted at a time and place of your choosing, and with…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.27
8 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.447706.1059.0
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.447706.1090.7
11 pg
…the motion
12 to strike the testimony that you allowed over the
13 ruling.
14 SPECIAL MASTER: And there's a series of
15 those things that might need to be cleaned up in a
16 subsequent sitting.
17 MR…
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.447706.1106.0_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.447706.40.0
8 pg
…to challenge the propriety of any designation of
discovery material under this Order at the time the designation is made, and a
failure to do so shall not preclude a subsequent challenge thereto. Moreover,
failure to challenge the designation of …
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.447706.1198.13_1
19 pg
…of court discovery order and where false testimony, material misrepresentations by
counsel and foot-dragging were used in an effort to prevent defendant from getting at the
relevant records, despite subsequent production of the records); Radetsky v. Binney & Smith,
Inc…
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.447706.1335.3
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.447706.503.0
21 pg
…for the Articles that were, in fact, subsequently published
under Churcher's byline over the next several years.
In von Bulow , the court held that the reporter's
privilege did not apply to notes that a woman, Andrea Reynolds,
took…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
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.447706.41.5
18 pg
…No bullets or numbering, Tab stops: 1",
Formatted: Font: 12 pt
failure to do so shall not preclude a subsequent challenge thereto. Moreover,
…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…with and among Ms.
Maxwell and her attorney, Mr. Philip Barden on dates subsequent to the press release at issue
here. His provision of information was a necessary part of Mr. Barden’s ability to give cogent
legal advice to…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…or emotional condition, including addiction to alcohol, prescription or illegal
drugs, that You suffered from subsequent to the Alleged Defamation by Ghislaine Maxwell”
(Interrogatory No. 12) and “prior to the Alleged Defamation.” Interrogatory No. 13 (emphasis
added). As to both…
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