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ng of Maxwell's Depositions Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 2016 deposition transcript. (See 15 Civ. 7433 (LAP), Dkt.
met that standard." (Id. at 7) (emphasis in original). 8. Unsealing of Maxwell's Depositions Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
stayed at this point. . . In particular, this matter appears to be the only remaining active civil case in this District in which 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover
by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless con
8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00077706 2016 deposition transcript. (See 15 Civ
on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m
on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)
8. Unsealing of Maxwell's Depositions Three months after Chief Judge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April
ge McMahon issued her Order, Giuffre v. Maxwell was reassigned to the Honorable Loretta A. Preska on July 9, 2019. On or about July 23, 2020, Judge Preska ordered unsealed certain litigation materials, including, and related to, Maxwell's April 74 EFTA00039521 2016 deposition transcript. (See 15 Civ
on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m
on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)
ability analysis in this case," however, "is predicated on an assessment of the actions that might have been taken by third parties," such as Judge Preska and the Miami Herald, who are "not acting at the behest of the police." Id. "Such an analysis is inherently speculative." Id. In fact, unlike every
A: Motion to Compel Plaintiff to Disclose Alleged "On-going Criminal Investigations by Law Enforcement" or, In the Alternative, to Stay Proceedings. Giuffre v. Maxwell, No. 15-cv- 07433-RWS, Apr. 18, 2016 EXHIBIT B: Giuffre v. Maxwell, No. 15-cv-07433-RWS, Transcript, Apr. 21, 2016 EFTA00100291 Ghislaine Maxwell
n District of New York against Maxwell or Epstein's estate, the government deliberately chose not to intervene in the on-going unsealing process in Giuffre v. Maxwell. In the only other active SDNY case against Epstein, Doe v. Indyke, No. 20-cv-484-JLIC, the government intervened and moved to stay discovery, sayi
materials. Giuf•e v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition materials are judicial documents to which the presumption of public access attaches, and did not abuse its discr
ess attaches, and did not abuse its discretion in rejecting Maxwell's meritless arguments that her interests superseded the presumption of access." Giuffre v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 3).43 On October 22, 2020, the defendant's April 2016 deposition was publicly filed. (See 15 Civ. 7433 (L
Count Six, stating that the "testimony is .. . far afield from the sex trafficking and sexual abuse allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)
Entities connected to both Loretta A. Preska and Giuffre v. Maxwell

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Julie K. Brown
PERSON
David Boies
PERSON
Virginia Giuffre
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONthe Southern District
LOCATIONSweet
PERSONJane Doe
PERSONSecond Circuit
ORGANIZATION
Alan Dershowitz
PERSON
United States
LOCATION
Colorado
LOCATION
Stephen Hawking
PERSONMartindell
PERSON
Schiller
PERSONColleen McMahon
PERSON
George W. Bush
PERSONJeffrey Pagliuca
PERSON