giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…object to the confidentiality
designations: “A party may object to the designation of particular
CONFIDENTIAL INFORMATION by giving written notice to the party
designating the disputed information… it shall be the obligation of the party
designating the information as…
giuffre-maxwell
gov.uscourts.nysd.447706.587.0_2
10 pg
…defamation case and words are important in
22 this case.
23 THE COURT: That's true.
24 MR. PAGLIUCA: Those words written down by a plaintiff
25 prior to filing the litigation, some 300 pages of words,
SOUTHERN DISTRICT REPORTERS…
giuffre-maxwell
gov.uscourts.nysd.447706.39.1
7 pg
…1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 4 of 7
h. other persons by written agreement of the parties.
6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person
listed above (other than counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.335.0
13 pg
…at ¶ 8. The Order continues:
A party may object to the designation of particular CONFIDENTIAL INFORMATION by
giving written notice to the party designating the disputed information. The written notice
shall identify the information to which the objection is made…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…that the newest iteration of her story contained in the
I CVRA litigation differed materially from her rior "memories" which were written wli'en she
was riot planninglitigation and rlbt motivate
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…and (j) any other person by written
agreement of the parties or by Order of a Court of competent jurisdiction.” Ms.
Giuffre made the proposed addition above because she contends it will alleviate
debate over a document that has been…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…including “deponents, witnesses, or potential witnesses” or “by written
agreement of the parties.” Likewise, Paragraph 14 allows modification of the order by the Court
“at any time for good cause.” Finally, Paragraph 13 provides that the Protective Order “shall have…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…communication made to such victim’s advocate by a victim
of domestic violence…or a victim of sexual assault, in person or through the media of written records or reports
without the consent of the victim.” C.R.S. …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…information previously produced, covering topics on which
Ms. Maxwell already has been deposed at length, relating to lines of inquiry covered in other
written discovery that have been fully responded to, making reopening the deposition cumulative
and duplicative. Moreover, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…The FBI have
reopened the Epstein case due to Virginia’s revelations. I also am
attaching a link to a NY Magazine profile of Epstein.....written
before his world combusted. The FBI believe he was essentially
running a private — and…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…a bonfire.
Q. What did you put in the bonfire?
A. Any kind of memories that I had written down about all the stuff going on.
Q. Had you written anything about Professor Dershowitz?
A. He could have been there…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…asking these questions before I -
MR. BOIES: I’m asking these questions because these are people who not only have
been publicly written about in terms of the sexual activity that they were put into in
connection with Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.10
23 pg
…MR. BOIES: I ' m asking these
21 questions because these are people who
22 not only have been publicly written
23 about in terms of the sexual activity
24 that they were put into in connection
25 with Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…Document 1284 Filed 12/02/22 Page 4 of 17 4
1 objecting Does have been afforded the opportunity to respond to
2 the written positions of the parties and the herald and some,
3 but not all of them…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…Document 1283 Filed 12/02/22 Page 4 of 17 4
1 objecting Does have been afforded the opportunity to respond to
2 the written positions of the parties and the herald and some,
3 but not all of them…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…onler discovery from such sources if the
things or to pennit inspection may serve on the party or attorney designated requesting party shows good c&IISe, considering the limitations of Rule
in the subpo~• a written objection to inspecting, copying…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…cross-examine attorney).
To be sure, parts of Barden’s Declaration appear to have been cleverly written in an
attempt obscure the fact that he is revealing attorney-client communications. But just as using the
words “plan” and “intent” as…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
! Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 9…
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