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How To Remove Redactions In Suit Against Ghislane Maxwell

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Here are the court documents, lets use item 143 as an example

Some document are downloadable directly, but some are shown as “purchase from PACER”.  
PACER is a system of court records, like where those 120,000 sealed indictments are.   I signed up for an account years ago.    Curious, just as all this stuff is released…..their PACER system is down for maintenance…..hmm…..I wonder what might “get lost” in that maintenance.

This is an amazing find.    The “electronic redactions” in some of the court documents against Ghislane Maxwell, can be fairly easily removed.

Download the PDF

Open the containing folder
Right Click on the file and go to “Open With”

This is the only tricky part, Word will not likely be on that picklist, so you have to show it where the Winword.exe file is.    Do a search, it is buried in pretty deep under Program Files.

Here is help with that search

Open it with Word, Word can open PDF’s.   

Now “Select All”

CTRL-C for copy, then drop that into Notepad.    All the redactions will be removed.

Here is Document 143

I skimmed it.  It was quite odd.    Virginia Robert’s lawyer had a series of objections related to anything of a sexual nature, when indeed the whole matter related to sexual activity.   Was her lawyer paid off to prevent a sucessful prosecution?    It is sure odd.

     Here again, this information is critical to the case.  Among other things, these questions
are designed to show a modus operani (“M.O”) for Epstein and Maxwell – specifically, how they recruited for a non-sexual massage than converted the massage into sexual activities.  

     One last illustration comes from Defendant’s refusal to answer about her knowledge of
Epstein’s sexual interests during massages:

     Q.   Does Jeffrey like to have his nipples pinched during sexual

     MR. PAGLIUCA:  Objection to form and foundation.

     A.   I’m not referring to any advice on my counsel.  I’m not talking about
any adult sexual things when I was with him.
     Q.   When Jeffrey would have a massage, would he request that the
masseuse pinch his nipples while he was having a massage?
     A.   I’m not talking about anything with consensual adult situation.

See McCawley Decl. at Exhibit 5, Tr. of Maxwell Depo. (Apr. 22, 2016) at 82.  
     While Epstein himself might also provide answers to these questions, it appears likely
that he will assert his Fifth Amendment privilege regarding his sexual activities.  Accordingly, Ms. Giuffre must pursue questioning of Maxwell to obtain information on this subject.  Here again, information about Epstein’s sexual idiosyncrasies will provide important corroboration to

Ms. Giuffre’s testimony that she had sexual interactions of an identical nature with Epstein.  
     These refusals are not an isolated instance.  Instead, similar refusals to answer questions
occurred repeatedly throughout the deposition.  See, e.g., McCawley Decl. at Composite Exhibit
6. 52-55; 64-65; 82; 92-93; 137-38; 307-09.  

     The Court should compel Defendant to answer all these questions.  In addition to the
specific points made above, the “big picture” here reveals how vital such discovery is.          At the
core of Ms. Giuffre’s allegations is the allegation that Defendant lured her into a sexual situation with the offer of a job making money as a massage therapist; that Epstein always habitually tried to turn massages into sex (that was his modus operandi and plan all along); and that Maxwell recruited other females for an ostensibly proper position, such as therapeutic masseuse, with knowledge that the intent was for that person would be pressured to provide sexual gratification to Epstein.  As a result, Epstein’s use of massages for sexual purposes is a central part of this case.  
And Defendant’s role in those massages – and knowledge of the purposes of those massages – is a critical piece of evidence showing her state of mind when she attacked Ms.
Giuffre’s assertions as “entirely untrue.”  Ms. Giuffre intends to prove at trial that Defendant knew full well the sexual purpose for which she was recruiting females – including underage females like Ms. Giuffre.  Ms. Giuffre is entitled to explore Defendant’s knowledge of the sexual activities that took place under the guise of “massages.”  Otherwise Defendant will be able to portray to the jury an inaccurate picture of that what was happening at Epstein’s house what nothing more than run-of-the-mill massage therapy.  See, e.g., McCawley Decl. at Exhibit 7, Tr. of Maxwell Depo. (Apr. 22, 2016) at 51 (“Q: Did [the pay for massage therapists] vary on what sexual acts they performed? . . . A: No, it varied depending on how much time, some massage therapists charge more and some charge less.”).  
     Defendant’s refusal to answer questions about alleged “adult” consensual sex also blocks Ms. Giuffre from seeking legitimate discovery in this case.  By refusing to answer questions about her and Epstein’s sexual activities with alleged “adults,” Defendant is essentially given the ability to refuse to answer any sexual question she does not wish to answer.  Defendant simply has to deem the question as involving “consensual adult sex” and no need be given.  The result is to leave Ms. Giuffre with no way of exploring the identity of these alleged adults, the ages of these alleged adults, and indeed whether they were adults at all.  This allows Defendant to claim that she is unaware of any sexual activity involving underage females, because (she claims) the only sexual activity she was aware involved adults.    
     The Court should compel Ms. Maxwell to answer all questions about her knowledge
relating to sexual activities with Epstein and other females while at Epstein’s various homes.          See

Fed. R. Crim. P. 37(a)(3)(B)(i); see, e.g., Kelly v. A1 Tech., No. 09 CIV. 962 LAK MHD, 2010
WL 1541585, at *20 (S.D.N.Y. Apr. 12, 2010) (“Under the Federal Rules, when a party refuses to answer a question during a deposition, the questioning party may subsequently move to compel disclosure of the testimony that it sought.  The court must determine the propriety of the deponent’s objection to answering the questions, and can order the deponent to provide improperly withheld answers during a continued deposition” (internal citations omitted)).  Of course, the party objecting to discovery must carry the burden of proving the validity of its objections, particularly in light of “the broad and liberal construction afforded the federal discovery rules . . . .”  John Wiley & Sons, Inc. v. Book Dog Books, LLC, 298 F.R.D. 184, 186 (S.D.N.Y. 2014).  For purposes of a deposition, the information sought “need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence.”  Chen-Oster v. Goldman, Sachs & Co., 293 F.R.D. 557, 561 (S.D.N.Y. 2013) (citing
Fed.R.Civ.P. 26(b)(1)).   
     Defendant cannot carry her burden of showing that the questions asked are not
reasonably calculated to lead to the discovery of admissible evidence.          This is a case in which
sexual activities lie at the heart of the issues in dispute.  As a result, it is hardly surprising to find that discovery pertains to alleged “adult” sexual activities – and questions about such subjects are
entirely proper.      See, e.g.,

     Condit v. Dunne, 225 F.R.D. 100, 113 (S.D.N.Y. 2004) (in defamation
case, “Plaintiff is hereby ordered to answer questions regarding his sexual relationships in so far as they are relevant to a defense of substantial truth, mitigation of damages, or impeachment of plaintiff.”); Weber v. Multimedia Entm’t, Inc., No. 97 CIV. 0682 PKL THK, 1997 WL 729039, at

*3 (S.D.N.Y. Nov. 24, 1997) (“While discovery is not unlimited and may not unnecessarily intrude into private matters, in the instant case inquiry into private matters is clearly relevant to the subject matter of the suit. Accordingly, plaintiff Misty Weber shall respond to defendants’ interrogatories concerning her sexual partners . . . .”).
     Generally speaking, instructions from attorneys to their clients not to answer questions at a deposition should be “limited to [issues regarding] privilege.”  Morales v. Zondo, Inc., 204
F.R.D. 50, 54 (S.D.N.Y. 2001).

     In this case, defense counsel ranged far beyond the normal
parameters of objections and sought to decide for himself what issues were relevant.  That was improper and the Court should order a resumption of the Defendant’s deposition so that she can answer questions about her knowledge of sexual activity relating to Jeffrey Epstein. 
     Defendant should be ordered to sit for a follow-up deposition and directed to answer
questions regarding
her knowledge of alleged “adult” sexual activity.
Dated: May 5, 2016.
Respectfully Submitted,
                              BOIES, SCHILLER & FLEXNER LLP

     By:  /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boies Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011

David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
Bradley J. Edwards (Pro Hac Vice)
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
 (954) 524-2820

Paul G. Cassell (Pro Hac Vice)
S.J. Quinney College of Law University of Utah 383 University St.
Salt Lake City, UT 84112
(801) 585-5202


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