giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…just reached agreement.
Shortly before 5 p.m. today, Edwards and Cassell moved to withdraw their motion for partial
summary judgment. Their moving papers acknowledge a confidential settlement and mutual
release between themselves and Dershowitz, then go on to state:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…this action, the trial will be bifurcated. . . . Therefore, defendant's motions for
partial summary judgment and to stay discovery as to his financial status are
denied.
Tillery v. Lynn, 607 F. Supp. 399, 402-03 (S.D.N.Y. 1985…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…Unable to obtain stipulations by the Government, in 2011 the
victims filed a summary judgment motion alleging 53 proposed undisputed facts (DE 48), along
with a motion to have the Court accept those facts because of the Government’s failure…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…2d 69 (2d Cir.1991), the comt
denied the n10tion to reopen discovery and granted summary judgment because the plaintiff
fai led to seek any discovery during the six-month discovery period set forth by the court. In
stark contrast…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…be done without the victims “raising any objection.”
In February 2016, Edwards and co-counsel Paul Cassell filed a still-pending
motion for summary judgment that says Acosta’s successor, Wifredo Ferrer,
“has continued to fight” victims’ efforts “to have…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…is the case with former Massachusetts Institute of Technology professor Marvin Minsky, who
was recently implicated in the Epstein matter when the summary judgment materials were
publicly released. More than 350 different news reports repeating these allegations of sexual
misconduct…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…things of
23 that nature. But as we know, because your Honor reviewed the
24 case law with respect to the summary judgment, each individual
25 is responsible for their own defamation, so it doesn't come
SOUTHERN DISTRICT REPORTERS…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…attorneys, had
adequately investigated her allegations before filing them. As Edwards and Cassell explained
in their motion for summary judgment:
The central issue upon which Edwards and Cassell’s complaint rest is not whether
Ms. Giuffre’s claims were true…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…the prelitigation privilege,
12 and you found that it would be premature, even at the summary
13 judgment stage, to be analyzing whether or not that was
14 applicable.
15 So what we have here is qualified privileges being
16…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…the prelitigation privilege,
12 and you found that it would be premature, even at the summary
13 judgment stage, to be analyzing whether or not that was
14 applicable .
15 So what we have here is qualified privileges being
16…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…turns, to begin with, on
the form of words used in the affidavit (Eveleigh L.J. in the present case D
said that the judgment of Buckley L.J. there could be read in that way).
It was not, therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…1:15-cv-07433-LAP Document 1285 Filed 12/05/22 Page 2 of 6
information necessary to evaluate her privacy interests at stake.) See also Appendix
(Summary Chart).1
While Doe 171 strenuously maintains her right to remain anonymous…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…15-cv-07433-LAP Document 1286
1285 Filed 12/05/22 Page 2 of 6
information necessary to evaluate her privacy interests at stake.) See also Appendix
(Summary Chart).1
While Doe 171 strenuously maintains her right to remain anonymous…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…400, 402-03 (N.D. Iowa 2014).
As the Court can readily determine from the summary of anticipated testimony above,
none of the anticipated testimony is unreasonably cumulative or duplicative. Rather, all of the
anticipated testimony goes to central and…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…400, 402-03 (N.D. Iowa 2014).
As the Court can readily determine from the summary of anticipated testimony above,
none of the anticipated testimony is unreasonably cumulative or duplicative. Rather, all of the
anticipated testimony goes to central and…
giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
…400, 402-03 (N.D. Iowa 2014).
As the Court can readily determine from the summary of anticipated testimony above,
none of the anticipated testimony is unreasonably cumulative or duplicative. Rather, all of the
anticipated testimony goes to central and…
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