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SDNY COURTHOUSE, Sept 30 – After the death of Jeffrey Epstein in the MCC prison, Virginia Giuffre, Annie Farmer and others are pursuing civil litigation for sex trafficking against his "madame" Ghislaine Maxwell and his estate.

   On July 23 SDNY Judge Loretta Preska read out ruling unsealing many documents, while Maxwell's lawyer asked for a stay to appeal, citing Maxwell's imprisonment and July 2021 trial. Inner City Press live tweeted it, below.

 Now on September 30, this: " I write on behalf of Plaintiff Virginia Giuffre in response to Defendant Alan Dershowitz’s letter of the same date requesting a pre-motion conference at which Mr. Dershowitz will seek leave to move to disqualify my firm as counsel for Ms. Giuffre, Doc. 176 (“Letter”). Plaintiff submits that Mr. Dershowitz’s proposed motion is without merit, and motion practice would accordingly be a waste of judicial and party resources. This is not the first time Mr. Dershowitz has sought leave to move to disqualify Cooper & Kirk PLLC (“Cooper & Kirk”) on the ground that Cooper & Kirk possesses information designated “confidential” under the protective order entered in Giuffre v. Maxwell, dated March 18, 2016 (Doc. 62 in No. 15 civ. 7433) (“Protective Order”). As we previously explained to the Court, we believed in good faith that we were entitled to possess the confidential information under the terms of the Protective Order, see Docs. 148 & 149, a fact that Mr. Dershowitz does not dispute, see Doc. 150. Although the Court initially held that Cooper & Kirk was not entitled to possess that information and ordered us to destroy it, Doc. 144, after receiving Mr. Dershowitz’s objection and our explanation, the Court ordered us to produce to Mr. Dershowitz material from Giuffre v. Maxwell that mentions him, Doc. 174—an order we are in the process of carrying out. Nothing else has changed since Mr. Dershowitz’s last request."

  On September 9 Judge Presksa granted in part and denied in part Dershowitz' requests: "Mr. Dershowitz has had several bites at this particular apple. Most recently, Mr. Dershowitz sought modification of the Maxwell protective order (dkt. no. 62 in 15 Civ. 7433) to permit him blanket access to all sealed materials and discovery at issue in the Maxwell litigation, a request that the Court denied. (See dkt. no. 144.) Core to the Court’s conclusion were several issues. First, Mr. Dershowitz’s request was staggeringly overbroad given the relatively constrained facts at issue in the Dershowitz litigation. (Id. at 8.) Second, the proposed modification of the protective order would threaten to undercut the carefully planned unsealing process in Maxwell. (Id. at 9.) Third, the Court found that parties providing documents and testimony in Maxwell reasonably relied on the Maxwell protective order, whose promises of confidentiality “functioned as a powerful mechanism for inducing parties to provide discovery in a contentious litigation.” (Id. at 11-12.) Shortly after the Court’s denial of Mr. Dershowitz’s request, the Court, in an effort to hasten the resolution of this case, ordered Mr. Dershowitz and Ms. Giuffre to confer “with an eye toward reaching a reasonable accommodation concerning Mr. Dershowitz’s requests for various filings and discovery materials from Giuffre v. Maxwell.” ... while Mr. Dershowitz has winnowed his request for documents somewhat since his earlier request for modification, he still seeks quite a broad universe of sealed materials related to the Maxwell litigation. As discussed above, Mr. Dershowitz seeks documents that fall into 13 separate categories, some of which are extremely broad. For example, Mr. Dershowitz seeks all documents “concerning Alan Dershowitz” and all documents produced and testimony given by dozens of witnesses. (See dkt. no. 153, Ex. A.) Mr. Dershowitz claims to have a “compelling need” for these materials because he wants to prove that all of the various instances of trafficking--by Mr. Dershowitz and numerous others-- alleged by Ms. Giuffre are false and therefore he never could have been on notice that Ms. Giuffre was a victim of sex trafficking. (See dkt. no. 171 at 5.) The Court again reminds Mr. Dershowitz that the central factual issue in this case is narrow, (see dkt. no. 152 at 1-2), and that discovery should therefore be proportionally narrow. While Mr. Dershowitz will not be forced to “litigate this action with one arm tied behind his back,” (dkt. no. 144 at 6 n.4), that does not require that the Court allow Mr. Dershowitz to use this defamation action as a vehicle for reconstructing everything that Ms. Giuffre has ever said about Jeffrey Epstein’s alleged sex trafficking operation.  ... Mr. Dershowitz’s request to modify the Maxwell protective order (dkt. no. 153) is granted in part and denied in part. Ms. Giuffre shall produce to Mr. Dershowitz all sealed materials and discovery that mentions Mr. Dershowitz, excluding material produced by or material (or portions of material) discussing a specific nonparty Doe whose privacy interests are the subject of a separate sealed order to be provided to Ms. Giuffre."

On August 17 Judge Preska held a conference, largely about protective order and also possible deposition of Les Wexner. Inner City Press live tweeted it:

Judge Preska: I am well familiar with the Maxwell case. Isn't the issue you raise solved by seeking leave in advance? Given the problems we've had in Maxwell, let's avoid extraneous documents attached to motions.

Judge Preska: Is there any reason what is produced in this action should have to be produced in the state action?

Christian Kiely for Dershowitz: We had agreed to only take one deposition, not two, for each. But they made up file a motion to compel. So, no.

 Imran Ansari (also for Dershowitz) - we have a New York State proceeding tomorrow... We oppose a carte blanche approach that is unfair to Professor Dershowitz.

Judge Preska: What if I consult with the NYS Justice? Any objection?

No. No.  Judge Preska: Do you have his number?

Ansari: I'll email it to your chambers. Judge Preska: On Mr. Wexner, I propose that we wait.

A: There is close to zero % change Mr. Wexner is going to voluntarily agree to be deposed.

 A: Professor Dershowitz is entitled to depose Wexner to memorialize the denial that has been put in in a letter an hour ago. [Inner City Press tweeted a photographfrom that letter, here.]

Judge Preska: I must get to the issue. What else do you want to talk about, Counsel?

Nothing from the defendant.

Judge Preska: I will look for a protective order tomorrow. Get on it. Thanks for being on.

From July: "Deposition of Virginia Giuffre taken in the [STILL REDACTED] matter on January 16, 2016, and designated by Plaintiff as Confidential under the Protective Order... correspondence with Churcher re: Edwards Privilege communication." ..."Epstein required Jane Doe #3 to have sexual relations with [STILL REDACTED] on numerous occasions while she was a minor... [STILL REDACTED] would later play a significant role in negotiating the NPA on Epstein's behalf." [NPA = Non-Prosecution Agreement]  With Sharon Churcher of Mail on Sunday: "Take the o out of favour! Gives me away!!" And, "Whoever published that article took the phrase about Andrew straight out of my captions. Not cool!!"

"Maxwell had direct connections to other powerful individuals with whom she could connect Epstein... Prince Andrew. Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor"
Ghislaine Maxwell told you to go give a massage to [STILL REDACTED], correct?" A: Correct. 

"I was working at Donald Trump's spa in Mar-a-Lago and I was prompted by Ghislaine to come to Jeffrey's mansion in Palm Beach that afternoon after work to make some extra money and to learn about massage"

"filed under seal are Notices of Deposition and Subpoena for [STILL REDACTED], Joe Recarey and Michael Reiter... certificate of service for [STILL REDACTED]"

"The Billionaire's Playboy Club," by Virginia Roberts... 'His modeling agency was only posing for an undercover trade. His business was really an illegal immigrant trafficking ring of underage girls that he was using as escorts to make him uber rich."

"you flew on a helicopter with [STILL REDACTED] and Ghislaine Maxwell as the pilot? A: Ghislaine told me that she flew Bill Clinton in."

From: jeffrey E <jeevaction [at] http://gmail.com> To: Gmax ... holidays with people I have never met, living off trust funds that I have never ever had"

Q: Do you know the age of any girl that you saw have sexual contact with Ghislaine Maxwell? A: Well, for instance, I mean, [STILL REDACTED] was, I think, a year older than me. [STILL REDACTED] again, a few years older than me."

"Alexandra Cousteau may have knowledge concerning Plaintiff's false claim against Defendant and others" - Alexandra Cousteau "has been honored as an 'Earth trustee' by the United Nations 

Maria Alessi... May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct... [STILL REDACTED] may have information about Ghislaine Maxwell's sexual trafficking" - as do UN's Amir Dossal &  UNSC Antonio Guterres 

  Watch this site.

Before, Maxwell tried a request for reconsideration. Judge Preska denied it, but gave two business days to for Maxwell to appeal. Then a notice of appeal to the Second Circuit. Photos here.

From July 23:

Judge Preska: "Ms Maxwell refused to testify as to any consensual adult activity." Ms Maxwell as relied on little but ipse dixit [it is said] - there is a presumption of public access to these motions. Those papers shall be unsealed

 Judge Preska: Personal identifying information, and names of non-parties other than Doe 1 and Doe 2, will be redacted... Docket 142-2, unseal. Same thing for 144-5, 144-6 and 144-7.

 Judge Preska: Unseal docket 150 [Declaration of Jeffrey S. Pagliuca - this was filed, under seal, on May 10, 2016.  [Inner City Press note: UN official Amir Dossal, SG  @AntonioGuterres ' head of "Partnerships," was with Maxwell's Terrarmar up to 2018 filings...

Judge Preska: 185-11, excerpts of Giuffre declaration... 185-13, Giuffre affidavit, unseal in full... Billionaire's Club draft - unseal... Some others: withholding pending notice to that Doe

 Judge Preska: 260-1... Will, if this only the authorization? "Will" - that first two pages. Judge Preska: Medical records to remain sealed...  I will ask you to confer and prepare the documents, posting them within a week. Maxwell lawyer: We want a stay to appeal

 Maxwell lawyer: We want a two week stay. Giuffre's lawyer: We want it released right away. Maxwell lawyer: There's been a chance - Ms. Maxwell as been indicted and awaits trial in another courtroom in the SDNY in July 2021. We are concerned about a fair trial

Judge Preska: I'll give you a week to prepare the motion. I'll still ask you to prepare to make the documents public. If the 2d Circuit does not take up or grant your motion in a week, let me know. But prepare to unseal. 

   On July 2 Acting US Attorney Audrey Strauss has announced and unsealed in indictment of Maxwell on charges including sex trafficking and perjury. (As in the Schulte CIA leaks case, it is not yet clear where the grand jury sat, White Plains or Manhattan with virtual jurors). Many hope that the sex trafficking prosecutions will move on to the UN, where Maxwell held a ghoulish press conference, and where Antonio Guterres is now covering up both UN sexual exploitation by peacekeepers the UN moves in and out of countries with impunity, scoop video here, and sexual abuse right inside UN headquarters, exclusive audio here. Watch this site.

  On June 10, Maxwell filed that "Defendant Ghislaine Maxwell, through her counsel and pursuant to this Court’s Order and Protocol for Unsealing Decided Motions, DE 1044, as clarified by DE 1053, objects to the unsealing of the Sealed Items contained in: • DE 143 (and related DEs 142, 144, 144-1, 149, 150, 150-1, 151, 152, 153, and 153- 1); • DE 172 (and related DEs 171, 173, 173-1, 189, 190, 190-1, 202, 203, 204-1, 211, 212, 212-1, and 224) and; • DE 199 (and related DEs 200, 200-1, 228,2 29, 229-1, 284, 249, and 249-1)." Photo here.

  It is reminiscent of UN Sec-Gen Antonio Guterres covering up UN child rapes - except the UN's rapes are in DR Congo, CAR and Haiti. And now, this in Tel Aviv, another Inner City Press scoop on which Guterres refuses to answer.

And on July 1, this order: "MEMORANDUM & ORDER re: (133 in 1:19-cv-03377-LAP) FIRST LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Howard M. Cooper, Esq. dated June 12, 2020, filed by Alan Dershowitz. For the reasons discussed above: (1) Cooper & Kirk shall destroy (a) all materials from Giuffre v. Maxwell, No. 15 Civ. 7433, currently in its possession, save for the transcript of Ms. Giuffre's deposition in that case and (b) all work product derived from the Maxwell materials. Cooper & Kirk shall submit to the Court an affidavit detailing the steps that it took to destroy the materials. In addition, to the extent it is doing so, Cooper & Kirk shall cease all use of the Maxwell materials--outside of Ms. Giuffre's deposition transcript--in its work on Ms. Giuffre's action against Mr. Dershowitz. (2) Mr. Dershowitz's request to modify the Maxwell Protective Order [dkt. no. 133 in 19 Civ. 3377] is denied. SO ORDERED. (Signed by Judge Loretta A. Preska on 7/1/2020)."

   Judge Schofield said she does not see lumping in the complaint, and that does not think that the motion or motions Ghislaine Maxwell was suggesting she would make would be worth the time.    

Maxwell's lawyer Laura Menninger of Denver's Haddon, Morgan and Foreman, P.C. was urged to submitted a letter or answer in a week's time.   Menninger pushed forward, saying that given the case's link to New Mexico and that Farmer is not a resident of New York, the shorter of the statute of limitation might apply. 

 Judge Schofield repeated that the defendants, also for executors of Epstein's estate Darren K. Indyke and Richard D. Khan, should file in a week's time. Inner City Press will continue to follow and report on this case. It is Farmer v. Indyke, et al, 19-cv-10475 (Schofield). 

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