giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…Maxwell’s rights to a fair trial by poisoning any venire and influencing witness testimony. For
reasons discussed below, the Court should decline to unseal the identified Sealed Items.
I. Ms. Maxwell’s July 22, 2016 deposition must remain sealed.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…jury, unsealing the deposition material also risks compromising the integrity of witness
testimony because it provides an opportunity for a witness to change his or her story to conform
to the allegations made in the unsealed (and publicized) material.” Id…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…Court, it didn't have everything.
23 So after the summary judgment, your Honor will
24 remember there was other witness testimony that was presented
25 and put in the court record. There were designations for trial
SOUTHERN DISTRICT REPORTERS…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…Deposition Designations and Counter-Designations
Ms. Maxwell contends that trial deposition designations and counter-designations are not
judicial documents: In fact, pre-trial disclosures like this contain the direct witness testimony that
the parties were designating as public trial testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…had to review the proposed trial testimony designations for each witness
to determine how he would rule on objections to the testimony that would be presented to the jury.
As noted above, the trial deposition designations and counter-designations were…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…Inadmissible in the Criminal
Action Risks Tainting and Prejudicing the Jury Pool
The deposition testimony and witness names and information that may be revealed in this
unsealing may or may not be presented (or even admissible) in the Criminal Action…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
… potential witness in criminal Note: The deponent is not on the
CI-6
trial and deposition testimony Non-Party notification list
CI-7
…
giuffre-maxwell
gov.uscourts.nysd.447706.1209.1
24 pg
… from this
398-5 8.24.16
Rule 23.1; potential witness in criminal trial CI-5; CI-6; Doe to
and deposition testimony potential CI-7 remain
evidence. …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…not do so, and still has not provided this information to date. It is only
through deposition testimony that Ms. Maxwell became aware of at least five – if not more –
treating health care providers who were never previously identified. Yet…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…not do so, and still has not provided this information to date. It is only
through deposition testimony that Ms. Maxwell became aware of at least five – if not more –
treating health care providers who were never previously identified. Yet…
giuffre-maxwell
1320-33
24 pg
…not do so, and still has not provided this information to date. It is only
through deposition testimony that Ms. Maxwell became aware of at least five – if not more –
treating health care providers who were never previously identified. Yet…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…not do so, and still has not provided this information to date. It is only
through deposition testimony that Ms. Maxwell became aware of at least five – if not more –
treating health care providers who were never previously identified. Yet…
DataSet-9
EFTA00066510
21 pg
…order, and thus that the Government's use of her
deposition testimony against her would violate her right against compelled self-incrimination.
She contends that she had a reasonable expectation of privacy in the documents covered by the
protective order…
DataSet-9
EFTA00087251
21 pg
…order, and thus that the Government's use of her
deposition testimony against her would violate her right against compelled self-incrimination.
She contends that she had a reasonable expectation of privacy in the documents covered by the
protective order…
DataSet-9
EFTA00106039
21 pg
…order, and thus that the Government's use of her
deposition testimony against her would violate her right against compelled self-incrimination.
She contends that she had a reasonable expectation of privacy in the documents covered by the
protective order…
DataSet-9
EFTA00040664
21 pg
…order, and thus that the Government's use of her
deposition testimony against her would violate her right against compelled self-incrimination.
She contends that she had a reasonable expectation of privacy in the documents covered by the
protective order…
DataSet-9
EFTA00087230
21 pg
…order, and thus that the Government's use of her
deposition testimony against her would violate her right against compelled self-incrimination.
She contends that she had a reasonable expectation of privacy in the documents covered by the
protective order…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…Martindell.
Additionally, it is worth noting Ms. Guiffre has already considered – and advanced to her
advantage – the purpose of a witness’s reliance on confidentiality. Mr. Epstein’s deposition
testimony itself, including its videotaping, was compelled by this Court over…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…the identity and identifying
information as pertains to Plaintiff.
These same reports document that Plaintiff was a resident at a drug rehabilitation
facility from at least February 1999 until December 1999, whereas she has sworn
in deposition testimony, in affidavits…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…problematic, the release of deposition testimony from, or
evidentiary and advocate references to, individual Does (which includes many likely testifying
witnesses in the criminal trial), in the very weeks leading up to jury selection and testimony risks
prejudicing Ms. Maxwell…