giuffre-maxwell
gov.uscourts.nysd.447706.91.0
3 pg
…Motion to Compel are at once novel (Plaintiff asserts, for
example, a “public interest privilege” which is unavailable to individual, non-governmental
litigants) and mundane (Plaintiff completely refused to answer interrogatories, even though they
comply with the Federal and Local…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…Moreover, the USVI also may be hindered absent intervention because this action
involves testimony by and/or about Epstein, whereas his direct testimony is unavailable in the
CICO action due to his death while in federal custody. Furthermore, the allegations…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…. . is”3 Ms. Maxwell sent the earlier email to
Mr. Barden originally and because he was unavailable, she forwarded it to Mr. Gow.
Plaintiff’s reliance on this testimony is misplaced. Even if Mr. Gow’s speculation about
how he…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…of her long-time boyfriend and joint defense partner, Jeffrey Epstein.
A blanket statement of “unavailability” is incredible – particularly without any description of the
steps she has taken to make the emails available. Without taking any efforts to recover her
…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…Martindell involved a criminal investigation, which
meant that the Government could take a number of significant steps
that are unavailable in the USVI’s civil action here. 594 F.2d at
296 (noting that the Government “may institute or continue…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…318 (1976)).
Since Maxwell and Doe agree (as they must) that Epstein is unavailable to testify in the
USVI’s CICO action and since his allegedly repeated invocations of the Fifth Amendment
privilege in his deposition in this action would…
giuffre-maxwell
gov.uscourts.nysd.447706.49.0
12 pg
…Rule 26.4. Not
surprisingly, Counsel for Ms. Maxwell was unavailable on the dates unilaterally selected by
Plaintiff.
Counsel for Ms. Maxwell attempted to have a professional conversation about an orderly
discovery plan and, contemporaneously with that request, on February…
giuffre-maxwell
gov.uscourts.nysd.447706.872.0
76 pg
…Barden was not necessarily accessible at
some point in time, so this had been sent to him
orig inall y by Ms . Maxwell, and because he was
unavailable , she forwarded it to me for immediate
action. I therefore respond, "Okay…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…These files demonstrate the magnitude of Epstein's criminal
conduct and the unlikelihood that Dershowitz was ignorant of his confidant and close friend's
criminal behavior.
Dershowitz complains that some of the documents are sealed or otherwise unavailable to
him…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.19
12 pg
…Mr. Barden was
not necessarily accessible at some point in time, so this had been sent to him
originally by Ms. Maxwell, and because he was unavailable, she forwarded it to
me for immediate action. I therefore respond, “Okay, Ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…684 N.Y.S.2d 443, 444 (1st Dep’t 1996)
(“Notwithstanding [subpoenaing party’s] excuses offered to the contrary, no clear and specific
showing has been made that the relevant material was unavailable elsewhere.”); Flynn, 235
15
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Menninger Declaration, Ex. A (Rizzo deposition transcript excerpts). Of course, Plaintiff’s counsel has
engaged in their own last-minute “unavailability” for a deposition scheduled by Ms. Maxwell, as to Plaintiff’s
former fiancé, a witness who is hostile, required…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…Menninger Declaration, Ex. A (Rizzo deposition transcript excerpts). Of course, Plaintiff’s counsel has
engaged in their own last-minute “unavailability” for a deposition scheduled by Ms. Maxwell, as to Plaintiff’s
former fiancé, a witness who is hostile, required…
giuffre-maxwell
1320-28
32 pg
…Menninger Declaration, Ex. A (Rizzo deposition transcript excerpts). Of course, Plaintiff’s counsel has
engaged in their own last-minute “unavailability” for a deposition scheduled by Ms. Maxwell, as to Plaintiff’s
former fiancé, a witness who is hostile, required…
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