giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
1320-37
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.232.1
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…addressed the admissibility of evidence of physical flight from the jurisdiction as
proof of consciousness of guilt. 21 F.3d 1251, 1258 (2d Cir. 1994). Plaintiff failed to cite a
single civil litigation in which evidence of the sale of…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…custodian, location and
general description of relevant documents, including pertinent insurance agreements, and other
physical evidence, or information of a similar nature.” Defendant’s interrogatories do just that:
1 – addresses where Plaintiff lived, dates, names of witnesses who lived…
giuffre-maxwell
gov.uscourts.nysd.447706.70.0
15 pg
…location and general description of
relevant documents, including pertinent insurance agreements, and other physical
evidence, or information of a similar nature.
(b) During discovery, interrogatories other than those seeking information described in
paragraph (a) above may only be served (1…
giuffre-maxwell
gov.uscourts.nysd.447706.509.0
18 pg
…STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
..
.............................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…1\:'IL V• --- -
I V.
Plaintiff, -----
15-cv-07433-RWS
GHISLAINE MAXWELL,
I Defendant.
I --------------------------------------------------X
I
DEFENDANT'S MOTION FO…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…or necessary to this action and, thus, are not reasonably calculated to lead to
the discovery of admissible evidence. Ms. Giuffre further objects because Defendant’s Second
Set of Requests for Production seeks documents that are in no way limited…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…In short, the Opposition seems to suggest because she produced these pages, she should
not have to answer other of the subpoena requests nor answer deposition questions which are
designed to lead to admissible evidence and which, concededly, do not…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…In short, the Opposition seems to suggest because she produced these pages, she should
not have to answer other of the subpoena requests nor answer deposition questions which are
designed to lead to admissible evidence and which, concededly, do not…
giuffre-maxwell
gov.uscourts.nysd.447706.599.0
12 pg
…Evid. 403 ............................................................................................................................ 6
Rule 702, Federal Rules of Evidence.............................................................................................. 7
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…1
Ms. Giuffre intends to strongly disprove Defendant’s false assertions and to demonstrate that
Defendant recruited Ms. Giuffre to be involved in massages of a sexual nature with Epstein.
To develop evidence to support her position, Ms. Giuffre recently…
giuffre-maxwell
gov.uscourts.nysd.447706.303.0
13 pg
…simply not an answer to that interrogatory by that party. It must be
recalled that interrogatories serve not only as a discovery device but as a means of
producing admissible evidence; there is no better example of an admission of…
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