giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…The Government of the United States Virgin Islands (the “USVI”) moves to intervene in
this action for the limited purpose of obtaining confidential access to both: (a) all sealed
documents related to the parties’ motions for summary judgment [ECF No…
giuffre-maxwell
gov.uscourts.nysd.447706.981.0
2 pg
…Mr. Cernovich was the only party
to obtain the exact relief he sought, namely the unsealing of the summary judgment
records. The Miami Herald subsequently sought the full case record to be unsealed,
which Mr. Cernovich believed to be far…
giuffre-maxwell
gov.uscourts.nysd.447706.712.0
11 pg
…e.g., Plaintiff’s Statement of Undisputed Facts in Response to Defendant’s Motion for
Summary Judgment at 4-27 (recounting details of Epstein’s and Defendant’s sex trafficking and sex
abuse conspiracy); see also Plaintiff Giuffre’s Reply…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…After Entry of a Verdict on Issues of
Liability and Punitive Damages, or, at a Minimum, After Determination of Summary
Judgment Motion ................................................................................................................. 7
B. Scope of Financial Discovery Must Be Limited to…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…and personal vendettas. Plaintiff’s arguments are
unsupported by law or fact.
One week after Cernovich sought to intervene and unseal the summary judgment
pleadings, counsel for Plaintiff filed yet another action in this District against Defendant
Ghislaine Maxwell (“Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…19, 2019) (listing
in a cursory fashion several reasons that the summary judgment materials should remain under in
response to the Second Circuit’s order to show cause). Her consistent failure to adhere to the
3
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…discovery. Additionally, Ms. Giuffre will continue to
suffer prejudice because she will not be able to use this discovery in summary judgment
proceedings, nor present this evidence to the jury at trial.
The Second Circuit has stated, “[w]here documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…Prime Minister, and other world leaders,’ as well as Dershowitz (a long-time member of the
1
Curiously, he died the very day after this Court’s summary judgment record was unsealed by the
Second Circuit.
2
Reinstein, Julia, 23…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
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.447706.1328.23
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.447706.561.0
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.447706.1200.11_1
21 pg
…Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
willful non-compliance, as well as a supplement to her motion for an adverse inference
instruction based on new information…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
willful non-compliance, as well as a supplement to her motion for an adverse inference
instruction based on new information…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
willful non-compliance, as well as a supplement to her motion for an adverse inference
instruction based on new information…