Search results for 01/05/24
1,750 results for "01/05/24"
Page 51 of 70
Giuffre_Maxwell_Batch4_p00109.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 25 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
Ghislaine Maxwell approached and recruited her for illegal purposes, and she remembers
celebrating a birthday with Ghislaine Maxwell.
5. Admit that...
Giuffre_Maxwell_Batch4_p00150.png
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 21 of 32
1. The Common Law Test
In determining the applicability of the common-law right of access to a given document,
courts are charged with determining the weight of the presumption of access under...
Giuffre_Maxwell_Batch4_p00312.png
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 9 of 50
her counsel ever had with any media without any time or subject matter limitation. The search
for, and production of, all communications involving her counsel and the media is unduly
burdensome and wholly...
Giuffre_Maxwell_Batch4_p00479.png
Case 1:15-cv-07433-LAP Document 1328-28 Filed 01/05/24 Page 22 of 24
TerraMar Project, Inc.
Schedule A
12. Any copy of a Document that is not identical shall be considered a separate
document.
13% If any requested Document cannot be produced in full, produce the...
Giuffre_Maxwell_Batch4_p00528.png
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 3 of 13
made by law enforcement or any state attorney.”” (Br. at 9). Ms. Giuffre understands this winding
sentence to mean that documents responsive to Requests Nos. 2-3 constitute communications
between Defendant and Jeffrey...
Giuffre_Maxwell_Batch5_p00003.png
Legal
Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 2 of 13
THE FLORIDA CRIME VICTIMS RIGHTS ACT CASE
4. Since July 2008, I have been involved in important and precedent-setting crime
victims’ rights litigation in the Southern District of Florida trying to protect...
Giuffre_Maxwell_Batch5_p00099.png
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 19 of 27
A: I don’t know sir.”
Ex. U at 426-27.
43. Mr. Rodriguez’s testimony contained nothing inculpatory of me and,
inasmuch as it concerned the period 2005 and later, it has...
Giuffre_Maxwell_Batch5_p00215.png
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 28 of 43
Epstein also took the Fifth with regard to many questions for which there was no realistic
risk of self-incrimination. As the Eleventh Circuit has explained, “[t]he central standard for the
. application...
Giuffre_Maxwell_Batch6_p00218.png
Case 1:15-cv-07433-LAP Document 1331-16 Filed 01/05/24 Page 7 of 10
Likewise, under Rule 32(a)(8), the subject matters of those litigations were completely different.
The cases were personal claims against Mr. Epstein by various individuals. There could be no
identity of issues...
Giuffre_Maxwell_Batch6_p00285.png
Case 1:15-cv-07433-LAP Document 1331-27 Filed 01/05/24 Page 5 of 11
judgment. On her third try, plaintiff makes no further headway. We address here each piece of
“documentary and testimonial evidence” plaintiff alleges supports her argument.
a. As plaintiff acknowledges, Ms. Maxwell’s testimony...
Giuffre_Maxwell_Batch4_p00053.png
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 9 of 40
Objection 4.
The requested information is relevant. Piggybacking on Objection 2, Plaintiff objected
that “Communications with the media regarding cases that bear no relation to the subject matter
of this case, from decades...
Giuffre_Maxwell_Batch4_p00075.png
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 31 of 40
this case. Plaintiff argued that the request encompasses “over 100” witnesses; notably, however,
Plaintiff did not claim she and her attorneys have communicated with even 20, let alone 100,
witnesses, nor has she...
Giuffre_Maxwell_Batch4_p00126.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 42 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
Ms. Giuffre objects to this request on the grounds that it is overly broad and unduly
burdensome, particularly as it calls...
Giuffre_Maxwell_Batch4_p00431.png
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 19 of 22
(DE 62). As this Court has previously explained, in allowing discovery of financial information
for punitive damage purposes, “any privacy interests defendants may have in confidential
financial information produced to plaintiffs can be...
Giuffre_Maxwell_Batch4_p00612.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 20 of 31
There simply is no legal basis for this Court to find that the documents Dershowitz seeks
qualify as “judicial documents.” First, it is not clear that this Court has even reviewed or
considered...
Giuffre_Maxwell_Batch5_p00208.png
Legal
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 21 of 43
In light of these controlling authorities, Epstein cannot rely on a Fifth Amendment self-
incrimination argument to withhold the documents.
G Epstein Cannot Assert an Act of Production Privilege to Refuse to Produce...
Giuffre_Maxwell_Batch5_p00213.png
Legal
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 26 of 43
becomes relevant. Epstein does not appear to have even bothered to first collect responsive
documents before asserting a Fifth Amendment claim. For example, during his deposition,
Epstein took the Fifth rather than answer...
Giuffre_Maxwell_Batch6_p00149.png
Flight Log
Case 1:15-cv-07433-LAP Document 1331-12 Filed 01/05/24 Page 1 of 10
B. ©: | E.'S, SCHALLER & Fob Ee xX NIE R Eg) Dy
40/ EAST LAS OLAS BOULEVARD® SUITE [200* FORT LAUDERDALE, FL 3330). 22) * PH G54 54,356 DUe2
Sigrid McCawley, Esq.
smecawlev@bstllp...
Giuffre_Maxwell_Batch4_p00051.png
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 7 of 40
independent consultant as such interrogatory is overly broad and unduly
burdensome. Furthermore, Ms. Giuffre is not obligated to produce anything
currently in the possession of Defendant Maxwell or her attorneys.
Notwithstanding such objections...
Giuffre_Maxwell_Batch4_p00429.png
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 17 of 22
Il. DISCOVERY OF DEFENDANT’S FINANCIAL INFORMATION SHOULD NOT
BE CONFINDED TO A NET WORTH STATEMENT.
Perhaps recognizing that it is inevitable that her financial information will be relevant in
this case, Defendant...
Giuffre_Maxwell_Batch4_p00610.png
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 18 of 31
164 (3d Cir. 1993) (“holding that discovery motions and supporting materials are subject to a
presumptive right of access would make raw discovery, ordinarily inaccessible to the public,
accessible merely because it had...
Giuffre_Maxwell_Batch5_p00212.png
Legal
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 25 of 43
making any testimonial aspect [of the production] a ‘foregone conclusion.*” Sallah v.
Worldwide Clearing LLC, 855 F. Supp. 2d 1364, 1372 (S.D. Fla. 2012) (quoting In re Grand
Jury Subpoena Duces Tecum...
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Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 7 of 12
Finally, Mr. Gow himself is scheduled to sit for a deposition himself during November on
topics to include his correspondence with Ms. Maxwell and with the press concerning Ms.
Maxwell, presumably to include...
Giuffre_Maxwell_Batch6_p00309.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 12 of 19
26. Any Documents that reflect any criminal charges, tickets, summonses, arrests,
investigations concerning You or witnessed by You.
27. Any Documents containing any statement regarding Your experience or contact with
Virginia Roberts, Ghislaine...
Giuffre_Maxwell_Batch4_p00136.png
Legal
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 7 of 32
PRELIMINARY STATEMENT
At nearly 78 years of age, Alan M. Dershowitz, the highly regarded Harvard Law
professor, criminal defense lawyer, and author, is entitled to enjoy the reputation for strict
personal rectitude that...
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