Search results for 01/05/24
1,750 results for "01/05/24"
Page 54 of 70
Giuffre_Maxwell_Batch4_p00137.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 8 of 32
submitted as part of that same motion (“Emails”), as well as a draft of Ms. Giuffre’s memoir
(“Manuscript”) that was filed in connection with a motion to extend the parties’ deadline for...
Giuffre_Maxwell_Batch4_p00337.png
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 34 of 50
back with Defendant and Epstein, and went on five more flights on Epstein’s plane before finally
escaping abroad.
Accordingly, the records and testimony in this case establish that Ms. Giuffre had no...
Giuffre_Maxwell_Batch3_p00250.png
Deposition
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 7 of 21
documents containing the search terms and remarkably states that none — not a single one of the
documents are responsive or relevant to the issues in this matter. Defendant’s representation is
simply implausible...
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Case 1:15-cv-07433-LAP Document 1328-20 Filed 01/05/24 Page 10 of 14
Colorado Statutes
Plaintiff also cites Colorado statutes which, she claims, support the proposition that her
identity as the victim of domestic violence is protected by Colorado law. It is not. Section 13-
90...
Giuffre_Maxwell_Batch4_p00426.png
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 14 of 22
clear-cut as to deprive Ms. Giuffre of her right to jury trial borders on frivolous. Ms. Giuffre is a
courageous young woman who has come forward to reveal the broad dimensions of...
Giuffre_Maxwell_Batch4_p00616.png
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 24 of 31
Dershowitz’s motion fails both parts of the test. “Protective orders prohibiting dissemination of
materials discovered before trial are not the kind of classic prior restraint that require[ ] exacting
First Amendment scrutiny.” In...
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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 2 of 27
had a valid basis for disseminating her false, grotesque and impertinent allegations against me in
a public filing. And it is that “fight,” essentially, that Mr. Cassell reignites in his declaration in
this...
Giuffre_Maxwell_Batch6_p00173.png
Case 1:15-cv-07433-LAP Document 1331-13 Filed 01/05/24 Page 15 of 22
opportunity to cross-examine Mr. Rodriguez earlier. Second, even if for some technical reason
Mr. Rodriguez’s deposition does not meet the requirements of Rule 804(b)(1), his testimony is
clearly trustworthy...
Giuffre_Maxwell_Batch3_p00234.png
Email
Case 1:15-cv-07433-LAP Document 1327-17 Filed 01/05/24 Page 2 of 6
From: Meredith Schultz
Sent: Wednesday, July 20, 2016 11:24 AM
To: Laura Menninger
Ce: Sigrid McCawley; Jeff Pagliuca; Brad Edwards; Paul Cassell ([email protected])
Subject: RE: Conferral...
Giuffre_Maxwell_Batch3_p00320.png
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 14 of 27
additional 4.5 hours permitted in the second deposition and the fact that she answered in the
second deposition the only pertinent questions permitted by the Court Order. See Fed. R. Civ. P...
Giuffre_Maxwell_Batch4_p00073.png
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 29 of 40
wildly overly broad and unduly burdensome, and calls for the production of
documents that are irrelevant to this action and not reasonably calculated to lead
to the discovery of admissible evidence, as described...
Giuffre_Maxwell_Batch4_p00332.png
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 29 of 50
outside the scope of discovery permitted by Fed. R. Civ. P. 26. Specifically, Ms. Giuffre’s sexual
abuse as minor child neither proves nor disproves Defendant and Epstein’s sexual abuse;
therefore, it...
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Court Filing
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 10 of 48
Facebook account for a short time but it is no longer active. Per our representations during the
March 21, 2015 meet and confer phone call, we are working diligently to find information to...
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Legal
Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 5 of 21
Epstein will invoke the Fifth Amendment, if permitted by this Court, does not constitute
exceptional circumstances that would permit use of his deposition at trial. /d.
Likewise, Mr. Rizzo, who lives in North...
Giuffre_Maxwell_Batch4_p00155.png
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 26 of 32
Nothing could be less private. Indeed, both Ms. Giuffre’s relationship with Ms. Churcher and
the nature of her allegations against Professor Dershowitz have been the subject of publicly
available court filings in...
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Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 19 of 32
a number of discovery disputes and other applications have been submitted to the Court in just
the last few weeks, this modest request is unlikely to appreciably affect the schedule of the
litigation...
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Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 17 of 32
IV. THE REVELATION OF THE EXCULPATORY DOCUMENTS TO PROFESSOR
DERSHOWITZ
In or about May 2016, Professor Dershowitz was named as a witness in this case by both
plaintiff and defendant. /d. § 29. Thereafter...
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Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 31 of 32
In contrast, there is no basis for a finding of good cause to protect the content of the
Requested Documents, all of which concern Ms. Giuffre’s own allegations. She cannot credibly
claim...
Giuffre_Maxwell_Batch4_p00334.png
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 31 of 50
assault is within the right to privacy.” Defendant cites no case law or statutes to back this up. Of
course, the opposite is true, as evidenced by the statutes and case law cited...
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Legal
Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 6 of 21
The Second Circuit first addressed this issue in Carter-Wallace, Inc. v. Otte, 474 F.2d
529, 536 (2d Cir. 1972). In that case, Judge Friendly observed that “there is something unusual
about...
Giuffre_Maxwell_Batch4_p00091.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 7 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
a. the exact false statement;
b. the date of its publication;
c. the publishing entity and title of any publication containing...
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Court Filing
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 7 of 50
Plaintiff Virginia Giuffre (“Ms. Giuffre”), by and through her undersigned counsel,
hereby files this Response in Opposition to Defendant’s Motion to Compel and her baseless
Motion for Sanctions (DE 354).
L INTRODUCTION...
Giuffre_Maxwell_Batch4_p00314.png
Legal
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 11 of 50
(including the identity of the organization with which they are affiliated), particularly as the
communicators each received one of Defendant’s subpoenas.
At the end of the day, the only thing Ms. Giuffre...
Giuffre_Maxwell_Batch4_p00331.png
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 28 of 50
Interrogatory No. 14 seeks information concerning Ms. Giuffre being sexually abused as
achild. It is worth recalling that this request is being propounded by Defendant, who sexually
abused Ms. Giuffre as a child...
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Legal
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 11 of 13
about privacy. (This Court quashed those subpoenas, see June 23, 2016, Minute Entry).
Defendant cannot argue to the Court in June that it is appropriate for her to receive unfettered
access to every...
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