EFTA00022960.pdf

"VIRGINIA L. GIUFFRE, Plaintiff v. GHISLAINE MAXWELL, Defendant."

"GHISLAINE MAXWELL, Defendant. 15-cv-07433-LAP"

"Laura A. Menninger (LM-1374) ... Attorneysfor Chislaine Maxwell"

"Jeffrey S. Pagliuca (pro hac vice) ... Attorneysfor Chislaine Maxwell"

"Ty Gee (pro hac vice) ... Attorneysfor Chislaine Maxwell"

"Haddon, Morgan and Foreman, P.C. ... Attorneysfor Chislaine Maxwell"

"15-cv-07433-LAP"

"Sigrid S. McCawley ... BOLES, SCHILLER & FLEXNER, LLP"

"Bradley J. Edwards ... EDWARDS POTTINGER LLC"

"Defendant Ghislaine Maxwell, through her counsel ... objects to the unsealing of the Sealed Items"

"Ms. Maxwell was the Defendant in this defamation action."

"Ms. Maxwell was deposed under a court-ordered guarantee that her testimony would remain confidential."

"Exhibit 2 contains a Flight Log Summary Chart prepared by Plaintiff's counsel"

"the Second Circuit itself redacted sensitive personal references in Ms. Maxwell's deposition testimony excerpts."

"DE 172-1, exhibit 6 is the entire, 418-page, deposition of Ms. Maxwell taken under the guarantee of the Protective Order"

"Exhibit 3 to DE 204-1 is deposition testimony taken of J. Doe I pursuant to the Protective Order. Although J. Doe 1 has not responded to the notice, J"

"Jeffrey S. Pagliuca (pro hac vice) ... Attorneysfor Ghislaine Maxwell"

"Laura A. Menninger (LM-1374) ... Attorneysfor Ghislaine Maxwell"

"Ty Gee (pro hac vice) ... Attorneysfor Ghislaine Maxwell"

"Jeffrey S. Pagliuca (pro hac vice) Haddon, Morgan and Foreman, P.C."

"Sigrid S. McCawley BOLES, SCHILLER & FLEXN ER, LLP"

"I certify that on June 10, 2020, I electronically served this Ms. Maxwell's Memorandum Brief In Support of Her Objections to Unsealing Sealed Material"

"Exhibits 5 and 6 concern J. Doe I... referencing numerous Non-Parties."

"During the course of this litigation Plaintiff offered... compilations of the Palm Beach Police Reports in which no one identified Ms. Maxwell as a su"

"Ms. Maxwell's Memorandum Brief In Support of Her Objections to Unsealing Sealed Materials"

"The Pleadings related to DE 230 concern the reopening of Plaintiff's deposition."

"Palm Beach Police Reports in which no one identified Ms. Maxwell as a suspect, a perpetrator, or participant"

"DE 172 contains multiple references to Ms. Maxwell's deposition testimony"

"The attachment of alleged summaries of flight logs, alleged flight logs, and police reports was simply a mechanism to attempt to bias the Court"

"DE 189 is Defendant's response to the motion... DE 190 and 190-1 relate to deposition testimony by Plaintiff."

"The declarant... had been involved in attempting to obtain money from one of Plaintiff's lawyers in exchange for alleged evidence"

"Ms. Maxwell is aware... that investigations surrounding the alleged conduct of Mr. Epstein survive his death."

"Does 1 and 2 ... should be provided Notice and an opportunity to object pursuant to the Protocol"

"Exhibits 5 and 6 concern J. Doe I. Both exhibits are hearsay statements made by J. Doe 1 in proceedings that did not involve Ms. Maxwell."

"J. Doe 1 was not examined by Ms. Maxwell's counsel in that proceeding"