giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Ms. Maxwell was the employee of Mr. Epstein --in the 1990s -- not the other way
around. Mr. Epstein has never worked for or been in control of Ms. Maxwell.
x Ms. Maxwell and Mr. Epstein have had no financial, professional…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…Ms. Maxwell was the employee of Mr. Epstein --in the 1990s -- not the other way
around. Mr. Epstein has never worked for or been in control of Ms. Maxwell.
Ms. Maxwell and Mr. Epstein have had no financial, professional…
giuffre-maxwell
1320-28
32 pg
…Ms. Maxwell was the employee of Mr. Epstein --in the 1990s -- not the other way
around. Mr. Epstein has never worked for or been in control of Ms. Maxwell.
x Ms. Maxwell and Mr. Epstein have had no financial, professional…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…that Does 73 and 93 were not “involved in any of the conduct underlying this action” or
“accused of any wrongdoing” because they worked for Epstein in a “financial capacity” or because
Plaintiff could not remember their names at deposition.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…e., plaintiff and defendant, worked off J. Doe’s proposed
protocol, Doc.1019. The original parties ultimately made substantial changes to the
protocol. The changes were made for various reasons, most of which will be apparent,
e.g., the protocol…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…Giuffre as her attorney for years on issues related to her sexual abuse by Jeffrey
Epstein and his co-conspirators -- including active work in legal research and other aspects of
this case. Mr. Edwards has worked as lead trial counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…foreign presidents, a well‐
known Prime Minister, and other world leaders,” as well as
Dershowitz (a long‐time member of the Harvard Law School faculty
who had worked on Epstein’s legal defense) and Defendant‐Appellee
Ghislaine Maxwell (“Maxwell”).2…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…foreign presidents, a well‐
known Prime Minister, and other world leaders,” as well as
Dershowitz (a long‐time member of the Harvard Law School faculty
who had worked on Epstein’s legal defense) and Defendant‐Appellee
Ghislaine Maxwell (“Maxwell”).2…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Menninger
Jeffrey S. Pagliuca
Ty Gee
HADDON, MORGAN AND FOREMAN, P.C.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…SUBPOENA TO AND
TO DISMISS COUNTS FIVE AND SIX
Jeffrey S. Pagliuca
Laura A. Menninger
HADDON, MORGAN & FOREMAN P.C.
…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…attorney's office
12 somehow worked with the state authorities in crafting, and
13 those two other women, not plaintiff, litigated for I think
14 seven years now whether or not they should have been informed
15 earlier about whatever…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…Access .............................................................................. 10
2.1.2 The First Amendment Compels Access ................................................................ 12
2.2 Standard for Sealing a Court Record ........................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…foreign presidents, a well‐
known Prime Minister, and other world leaders,” as well as
Dershowitz (a long‐time member of the Harvard Law School faculty
who had worked on Epstein’s legal defense) and Defendant‐Appellee
Ghislaine Maxwell (“Maxwell”).2…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…foreign presidents, a well‐
known Prime Minister, and other world leaders,” as well as
Dershowitz (a long‐time member of the Harvard Law School faculty
who had worked on Epstein’s legal defense) and Defendant‐Appellee
Ghislaine Maxwell (“Maxwell”).2…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…The Mail on Sunday, a
publication owned by Associated Newspapers of London, England. During the interim she
worked as a freelance reporter for publications including The Mail on Sunday, the U.S. operation
of its digital arm, the Mail Online…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.1_1
7 pg
…20
Change to: “No. My lawyers worked with me to collect documents and my understanding
is that we turned those documents over to Dershowitz’s counsel prior to the deposition.”
Reason for change: Clarification of answer
Page No. 9 Line…
giuffre-maxwell
gov.uscourts.nysd.447706.1029.0
2 pg
…in
an effort to move this process forward she agreed to include a majority of the nonparties that
Defendant contends are entitled to notice. Accordingly, Plaintiff worked from Defendant’s larger
nonparty list and struck only those members of Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…for several reasons, as
detailed below, but primarily because the pre-litigation privilege is meant to protect parties to a
justiciable controversy in their attempts to narrow or resolve their claims to avoid litigation.
Defendant relies upon a vaguely-worded…
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