giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…Edwards”) and PAUL G. CASSELL (“Cassell”) (together,
“Plaintiffs”) in opposition to Dershowitz’s Motion to Compel Production of Documents and
Complete Responses to Interrogatories (the “Motion to Compel”).1
INTRODUCTION
At the outset of their Response, Pla…
giuffre-maxwell
gov.uscourts.nysd.447706.1298.0
1 pg
…2022 (Dkt. 1297) asking the parties
to jointly prepare and file a chart concerning the remaining non-objecting Does.
The parties have been working together to prepare the chart for filing. The number of non-
objecting Does and pleadings at…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…to accomplish is not a reason to unseal. Rather, the
hundreds of interested Non-Parties together with Ms. Maxwell have every right and reason to
expect that the promises of confidentiality afforded by a Protective Order, to which Plaintiff and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.26
4 pg
…He
can’t vote. He can’t hunt. He can’t carry a badge.
``He has spent years making amends and piecing his life back together. If we can’t allow people to change, then we give
people no incentive…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…included the name “max*” well aware that our client’s surname, and that of all of her paternal family members,
will begin with those three letters together. Your search terms thus are likely to yield every single email sent or…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
…needed to relay a message to 9 A. Because there were pictures with him
10 Epstein he would have to notify Epstein's 10 together.
11 secretary Lesley in New York who would then notify 11 Q. In the house…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…to the supplemental reports of Jansen and Kliman;
21 the 302 motion; and there are three that seem to me to go
22 together -- the references to the Florida action, the CVRA
23 action; the Epstein plea agreement and nonprosecution…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…to the supplemental reports of Jansen and Kliman;
21 the 302 motion; and there are three that seem to me to go
22 together -- the references to the Florida action, the CVRA
23 action; the Epstein plea agreement and nonprosecution…
giuffre-maxwell
gov.uscourts.nysd.447706.362.0
2 pg
…documents previously filed with the Court,
or in the alternative for an Order modifying the Protective Order previously entered by the Court,
together with such other and further relief as this Court deems just and proper.
PLEASE TAKE NOTICE that…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…13 MR. GUIRGUIS: No, you do
14 need to answer this.
15 A. Okay. We've been together
16 almost a year.
17 Q. And what is your current
18 occupation?
19 A. I'm a writer.
20 Q. And…
giuffre-maxwell
gov.uscourts.nysd.447706.288.2
3 pg
…i.e.,divorced from the
accom panyingsurnam esorfirstnam es. You haveincluded thenam e“ m ax*” w ellaw arethatour
client’ssurnam e,and thatofallofherpaternalfam ily m em bers,w illbeginw iththosethreeletters
together. Yoursearchterm sthusarelikely toyield every singleem ailsentorreceived by ourclient,or…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.37
9 pg
…party Virginia Roberts, Defendant Alan Dershowitz, and
David Stone, an attorney representing the interests of Dershowitz, met together to discuss the
claims concerning litigation involving Dershowitz, Brad Edwards, Paul Cassell and Virginia
Roberts. In partaking in these meetings, it was…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…fully below, the Requested Documents, separately and
together, demonstrate that the allegations of sexual misconduct lodged and repeated by Ms.
Giuffre are nothing more than a recent fabrication— a made up story designed to increase
commercial interest in Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…abuse suffered by Ms. Giuffre and others at the hands of
Maxwell, and should not be withheld. Moreover, flight logs demonstrate that Sarah Kellen and
Maxwell flew together multiple times, including with Ms. Giuffre. See McCawley Decl. at
Exhibit 4…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…Ms. Giuffre was 14 years old. Ms. Giuffre recalls
one facility named “Growing Together” that was located in or around
Palm Beach, but she does not recall the dates when she resided at the
facility.
! Ms. Giuffre lived and travelled…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…him and I remember him talking about what a good job she did. I
only met Bill twice but Jeffrey told me they were good friends.’
‘We all dined together that night. Jeffrey was at the head of the table…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…5, 2015. https://www.youtube.com/watch?v=KXzcxsiQv7Q.
And yet (among other occasions), a flight log shows Epstein and Dershowitz traveling together—alone.
5
The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005).
6
Vanity Fair Reminds…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…one, your Honor, is with regards, since we
14 are all together, to the issue of the third round of unsealing.
15 Because we already provided notice to Does 1 and 2, we are not
16 providing notice to them…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…
12 All right. We seem to be together on this.
13 As we know, we are here on Professor Dershowitz's
14 motion to have the protective order in the Maxwell case
15 modified to permit the production of all…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.11
8 pg
…CRITTON: Me. 18 MR. EDWARDS: Form .
19 RECROSS EXAMINATION 19 MR. WILLITS: Form.
20 BY MR. CRITTON: …
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