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

1:16 -cv-3989 (S.D.N.Y.) Doe v. Trump et al, No. 1:16-cv-4642 (S.D.N.Y.) Doe v. Trump et al, No. 1 :16-cv-7673 (S.D.N.Y.) Page 12 EFTA00091027 Giuffre v. Maxwell, No. 16-cv-3945 (2d Cir.) Doe (MM) v. Epstein et al, No. 1:17-cv-616 (S.D.N. K) Brown v. Maxwell, Nos. 18-2868-cv, 16-3945-cv (L), 17-1625 (CON), 1

v. Epstein et al, No. 1:17-cv-616 (S.D.N. K) Brown v. Maxwell, Nos. 18-2868-cv, 16-3945-cv (L), 17-1625 (CON), 17-1722(CON) (2d Cir. July 3, 2019) Giuffre v. Maxwell, No. 17-cv-16 25 (2d Cir.) Giuffre v. Maxwell, No. 17-cv-1722 (2d Cir.) Giuffre v. Maxwell, No. 18-cv-2868 (2d Cir.) Gerber et al v. The Financial

stency, fairness, and efficiency to all parties to this Motion and the underlying litigation. Therefore, this Court ORDERS the Motion TRANSFERRED to Giuffre v. Maxwell, No. 1:15-cv- 07433-RWS (S.D.N.Y. filed Sept. 21, 2015). Virginia L. Giuffre filed the underlying case in September 2015. The parties have heavily

Benson Magistrate Judge Evelyn J. Furse Paul G. Cassell moves this Court to quash a subpoena issued to him by the defendant, Ghislaine Maxwell in Giuffre v. Maxwell, No. 1:15-cv-07433-RWS (S.D.N.Y. filed Sept. 21, 2015). (ECF No. 2.) Ms. Maxwell opposes the Motion to Quash. (ECF No. 8.) Mr. Cassell replied. (EC

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 EFTA00077689 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M

as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 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

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).)

as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 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 EFTA00039504 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M

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).)

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

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).)

to use materials in addition to her deposition and the documents marked at the deposition (collectively, the "Transcript") in the matter captioned Giuffre v. Maxwell, Case No. 15-cv-07433(RWS) ("Giuffre Action"). We agreed to Plaintiff's request, and in return we proposed that should Plaintiff decide to use mater

e. She's made up the whole story. There is no truth to it." (t) August 12, 2019, in a press statement issued after the Second Circuit's ruling in Giuffre v. Maxwell: "She invented the false accusation against me only in 2014, when her lawyers `pressured' her to do so for financial reasons."2° (u) August 30, 201

ircuit.rI91 On March 11, 2019, in the appeal of the district judge's refusal to unseal the documents relating to • the 2017 defamation settlement of Giuffre v. Maxwell, the Second Circuit Court gave parties one week to provide good cause as to why they should remain under seal, without which they would be unsealed

nd Circuit.M On March 11, 2019, in the appeal of the district judge's refusal to unseal the documents relating to the 2017 defamation settlement of Giuffre v. Maxwell, the Second Circuit Court gave parties one week to provide good cause as to why they should remain under seal, without which they would be unsealed

ircuit.1i531 On March it, 2019, in the appeal of the district judge's refusal to unseal the documents relating to the 2017 defamation settlement of Giuffre v. Maxwell, the Second Circuit Court gave parties one week to provide good cause as to why they should remain under seal, without which they would be unsealed

. Koelti July 17, 2017 Page 2 With regard to Epstein's request that he be given leave to move for modification of the protective order entered in Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS), any issues related to the protective order are properly addressed to Judge Sweet. See, e.g., Daniels v. City of N. Y., 200

way of additional background information, shortly after Plaintiff initiated the Action, she was deposed in another matter pending in this District, Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (the "Giuffre action"). During that deposition, Plaintiff gave sworn testimony which relates in large measure to the claims

mechanism. See Giuffre v. Maxwell, 325 F. Supp. 3d 428, 444 (S.D.N.Y. 2019), rev'd on other grounds, Brown v. Maxwell, 929 F.3d 41 (2d Cir. 2019); Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (S.D.N.Y. Nov. 2, 2016), ECF No. 496 (Opinion Granting Dershowitz Motion to Intervene); Giuffre v. Maxwell, No. 15 Civ. 743

laid in the Southern District of New York. Finally, Plaintiff's deposition testimony, and the documents that she produced, in the action captioned Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (the "Giuffre action") further demonstrate that the FAC should be dismissed for the reasons set forth above and in the Defi