giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…154 F.R.D. at 92–93. Despite this prohibition, counsel for the
defendant approached the Manhattan District Attorney’s Office and suggested that it had
evidence of criminal violations relating to the case. Id. at 93. A grand jury…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…2d 325, 326 (N.Y.A.D.,1994) (affirming the denial of a
request for records held by the New York County District Attorney’s office).2
1
Portions of this brief are redacted because they quote from, or describe…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…custody of the New York City District Attorney. The District Attorney, a
non-party to the action, objected to the production of the statement which was made during the
course of the district attorney’s investigation that a minor child…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…namely, whether the
United States District Attorney for the Southern District of Florida failed to discharge its
statutorily-mandated duty to Epstein’s victims upon entering into a plea agreement with Epstein.
Ms. Giuffre’s supposed 2013 contemplation of the…
giuffre-maxwell
gov.uscourts.nysd.447706.140.3
4 pg
…jury favored disclosure of banking
records of alleged perpetrators of a Ponzi scheme, which were in possession of county district attorney in connection with a
pending grand jury investigation, in action brought against perpetrators by alleged victim of the scheme…
giuffre-maxwell
gov.uscourts.nysd.447706.103.2
3 pg
…Page 1 of 3
EXHIBIT 2
Case 1:15-cv-07433-LAP Document 103-2 Filed 04/19/16 Page 2 of 3
U.S. Department of Justice
United States Attorney
Southern Dis…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…types of comments, which serve no
compelling law enforcement or investigatory purpose, are prohibited by the local rules of this
District.
New York attorney David Boies and his partner Sigrid McCawley, who represent several
witnesses in this matter, have also…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…Id.
Amara’s counsel then sought attorneys’ fees based on the total benefits
recovered. See id. at 245–46. “In April 2019—almost six months after the
district court awarded attorney’s fees and over a year after the last…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…Id.
Amara’s counsel then sought attorneys’ fees based on the total benefits
recovered. See id. at 245–46. “In April 2019—almost six months after the
district court awarded attorney’s fees and over a year after the last…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…80656-CIV-Marra/Johnson (Southern District of Florida) (“Epstein case”)
(i) The date range of the documents is 2009 – Present
(ii) Persons identified as involved in the communications are: Giuffre, Bob
Josefsberg, Katherine W. Ezell, Amy Ederi, other Podhurst attorneys…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
......
.........................................
VIRGINIA L. GIUFFRE,
Plaintiff,
…
giuffre-maxwell
gov.uscourts.nysd.447706.685.0
6 pg
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S MOTION IN LIMINE TO PRECLUDE DEFENDANT FROM CALLIN…
giuffre-maxwell
gov.uscourts.nysd.447706.423.0
3 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.12
4 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.14
3 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…their attorneys should be denied as well.
V. Ms. Maxwell’s Privilege Log Is Sufficient
Finally, Plaintiff complains that Ms. Maxwell’s privilege log insufficiently describes the
“subject matter” of the communications. Plaintiff cites three cases from the Southern District…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.31
2 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
...............................................
VIRGINIA L. GIUFFRE,
PLAINTIFF,
V. …
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
DECLARATION OF PAUL G. CASSELL IN SUPPORT OF PLAINTIF…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…Cassell as her attorneys.
16. In December 2014, Ms. Giuffre, represented by Messrs. Edwards and Cassell,
filed a motion to join an action that had been initially filed in the United States District Court for
the Southern District of Florida…
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