…Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS Plaintiff Virginia Giuffre, by …
…Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS Plaintiff Virginia Giuffre, by …
…Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS Plaintiff Virginia Giuffre, by …
…and requests that the Court unseal and make public and unredacted any and all documents that identify the men who abused the girls trafficked by Jeffrey Epstein and Defendant Maxwell (“the Epstein Client List”). Sealing those documents violates the rights…
…about Plaintiff’s claim of victimhood. Furthermore, Plaintiff left unredacted her assertion that it is “undisputed” that Ms. Roberts was the child victim of sexual abuse, leaving the mis-impression with the public that Ms. Maxwell has in some way…
…about Plaintiff’s claim of victimhood. Furthermore, Plaintiff left unredacted her assertion that it is “undisputed” that Ms. Roberts was the child victim of sexual abuse, leaving the mis-impression with the public that Ms. Maxwell has in some way…
…answers to “personal” or “embarrassing” questions. Pages 2 through 8 of Docket Entry 172 should therefore be unredacted. If the Court declines to unseal pages 2 through 8 in full, the following items in Docket Entry 172 summarize portions of…
…s claim of - victimhood. Furthermore, Plaintiff left unredacted her assertion that it is “undisputed” that Ms. Roberts was the child victim of sexual abuse, leaving the mis-impression with the public that Ms. Maxwell has in some way conceded that…
…Mr. Cernovich’s motion addresses the Order of June 24, 2016 (Docket No. 250) setting forth how the parties are to file unredacted documents under seal, and the Standing Order of August 9, 2016 (Docket No. 348). These orders abrogated…
…Plaintiff cannot establish). Plaintiff’s RFP and motion presuppose that the only way Mr. Pagliuca could have known Plaintiff’s previous false accusations of sexual assault is by reviewing unredacted 2 copies of the police reports, hence, the RFP’s…
…day just before the depositions of - and Recai·ey, Plaintiff disclosed 623 new documents, including for the first time the "unredacted" police repo11s from Palm Beach, that Plaintiff cleai·ly has had in her possession, or her counsel 's possession…
…For the Court’s ease of reference, the Reply Brief is attached hereto in unredacted form as Exhibit M (under seal). 40. Neither the Emails nor the Manuscript were disclosed to me or my lawyers in the lawsuit between me…
…ghislaine-maxwell-deposition-gives-insight-into-epstein-relationship-94465093962 27 https://pagesix.com/2020/10/26/alan-dershowitz-seeks-to-unredact-name-in-ghislaine-maxwell-deposition/ 28 https://www.reuters.com/article/people-ghislaine-maxwell/ghislaine-maxwell-repeatedly-denies-witnessing…
…that _______ demonstrated massage techniques.” Mot. at 4. But, of course, there are other un-redacted statements that are highly significant in corroborating Ms. Giuffre’s testimony. For example, the FBI 302 notes that, while working at the Mar-A-Lago…
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO EXCLUDE DEFENDANT’S DESIGNATION OF DEPOSITION EXCERPTS OF ALAN DERSHOWITZ IN AN UNRELATED CASE …
…and supporting affidavits.1 (Of 1 Plaintiff now takes the stance that “journal could only have related to issues about Ms. Giuffre’s victimization, and thus even in the unrelated CVRA case, which Ms. Giuffre was not allowed to join…
…categories: (1) documents that contain highly personal and sensitive information sought only to harass, embarrass and intimidate the non- party; (2) documents unrelated to this action and, instead, intended to gain discovery relating to Defendant’s admitted “goal” of putting…
…if she’s going to share information that’s going to actually help her, it’s probably gonna be about unrelated crimes that she may be aware about because with respect to this particular operation, in terms of living people…
…173 1 HIGHLY CONFIDENTIAL AEO 2 matter? 3 MR. GUIRGUIS: Objection. 4 I'm going to direct you not to 5 answer if it's unrelated to this 6 case. 7 Q. Was there an attorney 8 present? 9 A…
…N.Y. App. Div. 1988) (holding that the scope of a waiver of the physician-patient privilege in personal injury cases is “limited and does not permit discovery of information involving unrelated illnesses and treatment”); Sgambellone v. Wheatley, 165 Misc…
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