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Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 12 of 17
Psihoyos v. John Wiley & Sons, Inc., No. 11CV01416, 2012 WL 3601087 (S.D.N.Y. June 22,
2012) (refusing to grant adverse inference
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 4 of 17
searched all accounts that she can access. Had Plaintiff bothered to follow up on this alleged
communication, Ms. Maxwell would hav
Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 4 of 6
Case 1;15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 5 of 7
Whenever a deposition involves the disclosure of CONFIDENTIAL
INFORMATION
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 3 of 17
Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Response to Plaintiff's Motion
To Compel Data From Defendant’s (Non-Existent
Case 1:15-cv-07433-RWS Document 62 Filed 03/18/16 Page 1 of 6
Case 1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 2 of 7
United States District Court
Southern District Of New York. -
4
sain ac
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 1 of 17
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ween eee xX
VIRGINIA L. GIUFFRE,
Plaintiff,
Vv.
15-cv-07433-RWS
GHIS
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 22 of 43
of incrimination from the mere production of documents to Ms, Giuffre’s counsel. See generally
Mare Youngelson, The Use of 26(c) P
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 12 of 43
incrimination, He should be ordered to answer these specific questions, which are enumerated in
Section II, below.
Third, Epstein
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 10 of 43
Case 9:16-mc-81608-DMM *SEALED* pata 1 Entered on FLSD Docket 09/20/2016 Page 1
of 26
United States District Court
Southern Distr
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 11 of 43
FILED BY
SEP 20 206
STEVEN fk CAAIMORE
OT oy
United States District Court
Southern District of Florida
CLEP LE THOT
SD.OFRA er
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 5 of 43
improper Fifth Amendment objections because there is no risk of incrimination because these
proceedings will be under seal.
Moreov
Case 1:15-cv-07433-LAP Document 1330-11 Filed 01/05/24 Page 9 of 12
“An adverse inference serves the remedial purpose of restoring the prejudiced party to the
same position he would have been in abse
Case 1:15-cv-07433-LAP Document 1330-11 Filed 01/05/24 Page 1 of 12
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine M
Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 7 of 10
Defendant did not produce her response to Gow’s email. Additionally, since the communication
appears to directly contradict her depo
Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 8 of 10
opening Defendant’s deposition to ask questions about these newly-produced documents,
particularly given the case law that also requ
Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 6 of 10
See McCawley Decl. at Sealed Composite Exhibit 2, Maxwell Depo. Tr. at 202:24-204:6. Ms.
Giuffre should not be prejudiced or penaliz
Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 2 of 10
Motion for Protective Order trying to avoid her deposition. After a hearing on the issue, the
Court directed Maxwell to sit for her
Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 1 of 10
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Ma
Case 1:15-cv-07433-LAP Document 1330-7 Filed 01/05/24 Page 16 of 18
JOSEP
MS. SCHU
THE WITN
BY MR. PAGLIUCA:
LTZ:
ESS:
Page 215
H RECAREY - CONFIDENTIAL
Object to form, foundation.
I don't re
Case 1:15-cv-07433-LAP Document 1330-7 Filed 01/05/24 Page 5 of 18
Page 180
JOSEPH RECAREY - CONFIDENTIAL
Exhibit 1. Are you with me?
A. Uh-huh.
Q. Okay. Again, this was information that
was obtai
Case 1:15-cv-07433-LAP Document 1330-7 Filed 01/05/24 Page 4 of 18
Page 179
JOSEPH RECAREY - CONFIDENTIAL
(The referred-to document was marked by
the court reporter for Identification as
Deposition
Case 1:15-cv-07433-LAP Document 1330-7 Filed 01/05/24 Page 12 of 18
Page 195
JOSEPH RECAREY - CONFIDENTIAL
as part of this case, right?
A. Correct,
consenting adults.
Q. Exactly.
because it was
Case 1:15-cv-07433-LAP Document 1330-6 Filed 01/05/24 Page 4 of 10
Terns of the Agreement:
1. Epstein shall plead guilty (not nolo contendere) to the Indictment as
currently pending against him in t
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 26 of 27
fabrication. This is part of an overarching plan by Ms. Giuffre’s lawyers to cherry-pick the
evidence they want to publically revea
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 12 of 27
Barak, Prince Andrew of England, another unnamed prince, and several unnamed “foreign
presidents,” among others. See, e.g., Dershow
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 5 of 27
his airplane—during the time Ms. Giuffre was associated with him. Dershowitz Decl.,! 4 9.
Nothing about Ms. Giuffre’s relationship w
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 22 of 26
21. Victims Refuse Silence 2016 Annual Report, attached hereto as Exhibit 21.
22. January 3, 2015 Daily Mail article: “Harvard Law
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 1 of 27
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
VIRGINIA GIUFFRE,
Index No. 15 Civ. 7433 (RWS)
Plaintiff,
-against- REPL
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 2 of 26
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 5 of 40
overly burdensome to the extent that they would require logging voluminous and ever-increasing
privileged communications between Ms.
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 17 of 40
f. whether health insurance or some other person or organization or entity
has paid for the medical expenses; and
g. For each such
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 16 of 40
b. _ the type of consultation, examination, or treatment provided;
c. the dates You received consultation, examination, or treatme
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 12 of 40
6. Identify any “false statements” attributed to Ghislaine Maxwell which were
“published globally, including within the Southern D
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 13 of 40
c. the publishing entity and title of any publication containing the
purportedly false statement;
d. the URL or internet address fo
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 3 of 40
that you immediately withdraw those interrogatories. See Rule 33.3, Local Rules for the
Southern District of New York; see also Shan
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 2 of 40
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Ma
Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 11 of 13
Sealed Exhibit 3 is a true and correct copy of the court’s protective order, which Dershowitz
used to keep documents under seal.
2
Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 10 of 13
p. Dershowitz had told the Palm Beach Police Department that he was going to
make Epstein available to answer questions about sex a
Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 6 of 13
that the details involve non-parties who are not related to the respondent Government.” DE 324
at 5 (emphasis in original). While Ju
Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 1 of 13
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine
Case 1:15-cv-07433-LAP Document 1330 Filed 01/05/24 Page 1of1
BOIES
SCHILLER
—_ FLEXNER
January 5, 2024
VIA ECF
The Honorable Loretta A. Preska
District Court Judge
United States District Court
S
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 28 of 31
presumption against modification because there is no public right of access to discovery
materials.” Dorsett, 289 F.R.D. at 65 (I
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 27 of 31
confidentiality of report of policing failures surrounding the murder of a young mother).
“Consequently, in a major decision in th
Case 1:15-cv-07433-LAP Document 1328-43 Filed 01/05/24 Page 4 of 8
Page 270
a3 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
2
3 JANE DOE NO. 2, CASE NO: 08-CV-80119
4 Plaintiff,
5S Vs.
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 25 of 31
the CVRA case Dershowitz references, and the Court will note that the CVRA court denied as
moot Dershowitz’s intervention attempt
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 22 of 31
IAU Report did satisfy the judicial document inquiry, since the Report was passed between the
parties in discovery, it lies entire
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 26 of 31
Despite Dershowitz’s argument, the Protective Order, entered “[u]pon a showing of good
cause,” was not improvidently granted. (DE
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 19 of 31
filing of a piece of discovery material as part of a non-dispositive discovery motion does not
convert the material into a judicia
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,
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 10 of 31
implicated Dershowitz by invoking their Fifth Amendment right against self-incrimination’*
when asked questions about Dershowitz’s