giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
…burden (“Privacy Interests”).
CI-4 - Preserving the fundamental rights of suspects or others under criminal investigation –
including due process right to a fair trial and impartial jury unimpaired by excessive publicity,
release of potentially inadmissible evidence for the Criminal Action…
giuffre-maxwell
gov.uscourts.nysd.447706.1209.1
24 pg
…422, 468 640
DATE
DOC. # DEFENDANT’S POSITION C/I[1] Status
FILED
Court
Keep sealed – Non-Party reliance on ordered ot…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.1_2
28 pg
…burden (“Privacy Interests”).
CI-4 - Preserving the fundamental rights of suspects or others under criminal investigation –
including due process right to a fair trial and impartial jury unimpaired by excessive publicity,
release of potentially inadmissible evidence for the Criminal Action…
DataSet-10
EFTA01372153
1 pg
…witness
to draw legal conclusions. That determination is reserved to the trial court."). Opinion
testimony of experts amounting to conclusions of law are inadmissible because the
determination of such questions is exclusively within the court's province. Thundereal
Corp. v…
DataSet-9
EFTA00221929
24 pg
…v. Baker, 432 F.3d 1189, 1211-12 (11th Cir. 2005) (holding that newspapers articles
were inadmissible double hearsay when offered to prove the truth of their contents - the
identity of the gunman); Dollar v. State, 685 So. 2d 901…
DataSet-9
EFTA01081110
18 pg
…styled v.
Jeffrey Epstein then pending in this Court, but the copy of the transcript is not signed and certified by the court
reporter or otherwise authenticated and is therefore inadmissible. Attachment "2" consists of an excerpt of 9-pages…
DataSet-9
EFTA01105263
60 pg
…3. The Specific Extrinsic Evidence FTC Anticipates that Fund Will Cite Is
Legally Irrelevant and Inadmissible.
There are additional reasons why the specific types of extrinsic evidence that the Fund
will likely submit here are irrelevant and should be excluded…
DataSet-10
EFTA01371379
1 pg
…witness
to draw legal conclusions. That determination is reserved to the trial court."). Opinion
testimony of experts amounting to conclusions of law are inadmissible because the
determination of such questions is exclusively within the court's province. Thundereal
Corp. v…
DataSet-9
EFTA01103302
19 pg
…v.
Jeffrey Epstein then pending in this Court, but the copy of the transcript is not signed and certified by the court
reporter or otherwise authenticated and is therefore inadmissible. Attachment "2" consists of an excerpt of 9-pages of…
DataSet-9
EFTA01104798
60 pg
…3. The Specific Extrinsic Evidence FTC Anticipates that Fund Will Cite Is
Legally Irrelevant and Inadmissible.
There are additional reasons why the specific types of extrinsic evidence that the Fund
will likely submit here are irrelevant and should be excluded…
DataSet-9
EFTA00074964
40 pg
…pleadings to remain sealed. DE 143 contains material
7
EFTA00074970
CaatatIg-retiR-4743N.OWneDbeurfiefIVIMOTaieb3OMIIKVaRt6W8461 22
misrepresentations of fact, and the attached porti…
DataSet-9
EFTA00600054
15 pg
…Crim. P. 11(0 provides, "The admissibility or inadmissibility of a plea, a plea
discussion, and any related statement is governed by Federal. Rule of Evidence 410."
'Federal Rule of Evidence 410 (a) provides in pertinent part:
(a) Prohibited Uses…
DataSet-9
EFTA00794214
13 pg
…allegations.
5. We object to the disclosure of any materials that were inadmissible
under the rules of evidence and were the subject of multiple pending and later-filed
motions to exclude their use. Virtually all of the exhibits attached to…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
… Case 1:15-cv-07433-LAP Document 1073 Filed 07/01/20 Page 8 of 22
misrepresentations of fact, and the attached portions of deposition testimony demonstrate that
Plaintiff’s questions themselves were packed with inadmissible, false representations.
1…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…153-1, Exhibits 4, 5, 6 and 7
Ms. Maxwell claims that the third-party depositions are unreliable and inadmissible. Again,
this is not the correct standard for sealing. See Section II.F.
C. Dkt. 172 and Related Submissions
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.0
56 pg
…burden (“Privacy Interests”).
CI-4 - Preserving the fundamental rights of suspects or others under criminal investigation –
including due process right to a fair trial and impartial jury unimpaired by excessive publicity,
release of potentially inadmissible evidence for the Criminal Action…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.0
31 pg
…burden (“Privacy Interests”).
CI-4 - Preserving the fundamental rights of suspects or others under criminal investigation –
including due process right to a fair trial and impartial jury unimpaired by excessive publicity,
release of potentially inadmissible evidence for the Criminal Action…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.0
9 pg
…F.3d 806, 813 (10th Cir. 1997) (upholding district
court’s sealing of discovery materials deemed inadmissible at trial, holding that “disclosure of
such [materials] would play a negative role in the functioning of the criminal process, by
exposing the…
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…argument is meritless.
First, Maxwell argues that much of the evidence is inadmissible because Giuffre planned
to introduce documents and testimony concerning Jeffrey Epstein’s sex trafficking scheme which,
according to her, “allegedly occur[ed] between approximately 2000-2008.” Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…withheld
4
See supra, fn. 2.
3
Case 1:15-cv-07433-LAP Document 185-8 Filed 06/01/16 Page 5 of 24
what they contend is irrelevant, inadmissible, and/or privileged discovery. Again, Plaintiffs are
in error…
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