giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…particularly in light of
Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may
be selling her assets in New York and transferring the money outside the jurisdiction.
Accordingly, Defendant’s motion for a…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…memoranda, mobile phone agreements, wire
transfer receipts, or any other document that concerns Plaintiff in any way,
whether or not they reference her by name.” Plaintiff is asking defendant to
Meredith Schultz
Paul Cassell
July 29, 2016
Page 2
produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…mobile phone agreements, wire
transfer receipts, or any other document that concerns Plaintiff in any way,
whether or not they reference her by name.” Plaintiff is asking defendant to
Case 1:15-cv-07433-LAP Document 1199-5 Filed 01…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…whatever form, is stored, transmitted or
received; and, includes every manner or means of disclosure, transfer or exchange, and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e…
giuffre-maxwell
gov.uscourts.nysd.447706.1229.0
3 pg
…Mar. 30, 2018) (holding the parties’ “self-
designation” of materials as “Confidential” “is not binding on the Court”); In re Citibank Aug.
11, 2020 Wire Transfers, No. 20-CV-6539 (JMF), 2020 WL 6782213, at *1 (S.D.N.Y…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…Copyright in that document vested in the
second claimant; in due course it was transferred to the first claimant. I shall not
distinguish between those two companies for the purposes of this judgment (because it is
not necessary to do…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…required-and also, after a
subpoena, the court for the district where compliance is required may, on motion is transferred, the issuing court-may hold in contempt a person
motion, quash or modify the subpoena ifit requires: who, having been…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.29
5 pg
…Who else? I don't think I can remember
8 all of the business, except for the office, transfer of 8 anymore.
9 commu11ications or faxes. But I have no idea of the 9 Q. ?
10 relationship wi th other…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…in whatever form, is stored, transmitted or
received: and, includes every manner or means of disclosuTe, transfer or exchange, and every
disclosure, transfer or exchange of i11formation whether ornlly or by document or otherwise,
face-to-face, by telephone, telecopies…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.42
5 pg
…hairstylist. Who else? I don't think I can remember
8 all of the business, except for the office, transfer of 8 anymore.
9 communications or faxes. But I have no idea of the 9 Q. David Copperfield, the magician…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…501,
510 (1984)). Plaintiff ignores this expressly-condoned countervailing factor and instead relies on
cases generally concerning pretrial publicity and motions to transfer venue.4
Plaintiff shrugs off concerns about the fairness of Ms. Maxwell’s criminal trial as
“vague…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…and also, after a
subpoena, the court for the district where compliance is required may, on motion is transferred, the issuing court-may hold in contempt a person
motion, quash or modify the subpoena if it requires: who, having been…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…and also, after 11
subpoena. the court tor the district where compliance is re4uircu lIlay, on Illotion is transferred, the issuing court-may hold in contempt u persoll
l1lotion, quash or mOdify Ihe subpoena ifit r,~qllir¢s: who, having been…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…Appeal IU □ Remnnded ti-om
Proceeding
2 Removed
from State (See VI or
5
…
giuffre-maxwell
1320-32
27 pg
…and also, after a
subpoena, the court for the district where compliance is required may, on motion is transferred, the issuing court-may hold in contempt a person
motion, quash or modify the subpoena if it requires: who, having been…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…mobile phone agreements, wire
transfer receipts, or any other document that concerns Plaintiff in any way,
whether or not they reference her by name.
(Emphasis supplied.) A request more sweeping than this one would be hard to imagine.
In this…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…There, the Supreme Court held
that a decision by a state’s highest court “not only direct[ing] a transfer of
property, but also order[ing] an accounting of profits from such property”
was “final,” notwithstanding that the order clearly…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…There, the Supreme Court held
that a decision by a state’s highest court “not only direct[ing] a transfer of
property, but also order[ing] an accounting of profits from such property”
was “final,” notwithstanding that the order clearly…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…of January 1, 2015 through the present, Ms. Maxwell has had no payments made or things
of value transferred to her, including loans, by Jeffrey Epstein or any entity or person affiliated
with or controlled by him.” Simply put, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…crime victim’s right case in the past (let alone
one that involved wholly different parties and wholly different causes of action) somehow
transfers to a New York state law defamation claim involving a different party that arose years
later…
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