giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…wherein he used his vast wealth and property holdings and a deliberately opaque web of
corporations and companies to transport young women and girls to his privately-owned islands
where they were held captive and subject to severe and extensive…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…16 Page 3 of 15
TABLE OF AUTHORITIES
Page
Cases
Byrnie v. Town of Cromwell, Bd. Of Educ,,
243 F.3d 93 (2d Cir. 2001) ..................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…1:15-cv-07433-LAP Document 604 Filed 02/09/17 Page 2 of 11
underage girl into his elaborate sex trafficking enterprise under the guise of using his wealth and
connections to get her into a prestige NYC college”…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…272, 368 N.Y.S.2d 904, 912 (4th
Dep't 1975) (“defendant's wealth should not be a weapon to be used by plaintiff to enable him to
2
By contrast, during the pendency of this lawsuit, Plaintiff assisted…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…“wherein
he used his vast wealth and property holdings and a deliberately
opaque web of corporations and companies to transport young women
and girls to his privately-owned islands where they were held
captive and subject to severe and extensive…
giuffre-maxwell
gov.uscourts.nysd.447706.121.0
10 pg
…for Defendant.
Defendant’s refusal to disclose her ESI preservation and collection methods, coupled
with an insufficient production as described in the moving brief,2 constitutes good cause for a
forensic examination. See Genworth Fin. Wealth Mgmt., Inc. v. McMullan…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…punitive damages claim. Of course, it is well-settled law that “evidence of a tortfeasor’s wealth
is traditionally admissible as a measure of the amount of punitive damages that should be
awarded.” City of Newport v. Fact Concerts, Inc.…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…whether victims were treated properly, and whether Epstein was given favorable
treatment because of his wealth and status. The Miami Herald seeks to paint a full and fair picture
1
Case 1:15-cv-07433-LAP Document 946 Filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…trafficking enterprise in the Virgin Islands, wherein he used his vast wealth and property
holdings and a deliberately opaque web of corporations and companies to transport young
women and girls to his private islands, where they were held captive and…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…property holdings, trusts, and every other conceivable
document regarding Ms. Maxwell’s wealth. Under the Federal Rules, this information is not
discoverable because it is not relevant to the claim or defense of any party in this action. Further,
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…of by the criminal justice system, whether victims were treated properly,
whether Epstein's victims were unfairly kept in the dark, whether Epstein was given favorable
treatment because of his wealth and status, in short, whether the public interest was…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…property holdings, trusts, and every other conceivable
document regarding Ms. Maxwell’s wealth. Under the Federal Rules, this information is not
discoverable because it is not relevant to the claim or defense of any party in this action. Further,
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…Ms. Giuffre alleges that Professor
14 Dershowitz has defamed her by calling her a serial liar who's
15 committed perjury as part of an extortion scheme against
16 multiple wealthy third parties and individuals. She uses those
17 words…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…living arrangements. She is not citing this countervailing interest
because she believes there is any evidence of “misconduct” or the “sexual abuse of young girls at
the hands of the wealthy and powerful,” as the Miami Herald speculates. While the…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…to meet the good cause standard of Rule 26, especially when the allegations at issue in the litigation
concern the sexual abuse of young girls at the hands of the wealthy and powerful. Framing
allegations of sexual abuse as “private…