giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…CONTINUING
INSISTENCE ON, AND REPETITION OF, ACCUSATIONS
AGAINST PROFESSOR DERSHOWITZ..............................................................5
III. THE EXCULPATORY EMAILS, REPLY BRIEF,
AND MANUSCRIPT ..................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.35
5 pg
…for the State of Florida.
Case 1:15-cv-07433-LAP Document 1219-35 Filed 07/15/21 Page 3 of 5
Page 223
1 JOHN ALESSI
2 Q. You never received emails from either of
3 them?
4 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.46
2 pg
…Subject: Giuffre v. Maxwell
Attachments: 2016-09-23 Letter to L.Menninger re Emails.pdf
Dear Ms. Menninger,
Attached please find correspondence from Meredith Schultz in regards to the above-referenced matter.
Please do not hesitate to contact our office…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…providers and produce their records prior to
her deposition, despite this Court’s order ........................................................................ 2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue o…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.24
6 pg
…of Florida.
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1327-24 Filed 01/05/24 Page 3 of 6
Page 223
1 JOHN ALESSI
2 Q. You never received emails from either of
3 them?
4 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.13
5 pg
…of Florida.
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1330-13 Filed 01/05/24 Page 3 of 5
Page 223
1 JOHN ALESSI
2 Q. You never received emails from either of
3 them?
4 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.18
6 pg
…Ann Willis, a Registered
Professional Reporter, Certified Realtime
Reporter and Notary Public within and
for the State of Florida.
Page 223
1 JOHN ALESSI
2 Q. You never received emails from either of
3 them?
4 A. No, sir…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…care providers and produce their records prior to
her deposition, despite this Court’s order .................................................................... 3
B. Plaintiff failed to produce emails form her iCloud and hotmail accounts ....................... 6
C. Plaintiff has failed to produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…providers and produce their records prior to
her deposition, despite this Court’s order ........................................................................ 2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue o…
giuffre-maxwell
gov.uscourts.nysd.447706.205.0
7 pg
…THE
SUBPOENA TO APPLE, INC. SEEKING PRODUCTION
OF ALL OF MS. GIUFFRE’S SENT AND RECEIVED EMAILS AND RELATED DATA
Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this
motion for a protective order, barring enforcement of…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…2. Terramar – You have withdrawn that as a standalone search term. I have represented to you that we have
searched all Terramar emails for otherwise responsive documents as well as
3. Witness names – You believe that search terms 124-341…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…publicly disclosed volumes of information related to her
allegations, to claim that letters or emails from her lawyers or other documents sent to any law
enforcement agency are protected by any privilege. Plaintiff lacks standing to raise the issue and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.18
2 pg
…past and
ongoing legal matters both before and after April 2015. I regularly communicated with Mr.
Epstein regarding my legal representation of him via email with the intention that such email
communications remain confidential and privileged. As counsel for Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.386.0
2 pg
…to as to specific past and
ongoing legal matters both before and after April 2015. I regularly communicated with
regarding my legal representation of via email with the intention that such email
communications rema…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.6
32 pg
…AND REPETITION OF, ACCUSATIONS
AGAINST PROFESSOR DERSHOWITZ..............................................................5
III. THE EXCULPATORY EMAILS, REPLY BRIEF,
AND MANUSCRIPT ..............................................................................................6…
giuffre-maxwell
gov.uscourts.nysd.447706.207.0
7 pg
…Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S MOTION FOR A PROTECTIVE ORDER REGARDING THE
SUBPOENA TO MICROSOFT CORPORATION SEEKING PRODUCTION
OF ALL OF MS. GIUFFRE’S SENT AND RECEIVED EMAILS AND RELATED DATA
Plaintiff Virginia Giuffre, by and through her undersigned counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.208.0
3 pg
…Defendant.
________________________________/
DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF MS. GIUFFRE’S
MOTION FOR A PROTECTIVE ORDER REGARDING THE SUBPOENA TO
MICROSOFT CORPORATION SEEKING PRODUCTION OF ALL OF MS.
GIUFFRE’S SENT AND RECEIVED EMAILS AND RELATED DATA
I, Meredith L…
giuffre-maxwell
gov.uscourts.nysd.447706.206.0
3 pg
…IN SUPPORT OF MS. GIUFFRE’S
MOTION FOR A PROTECTIVE ORDER REGARDING THE SUBPOENA TO APPLE,
INC. SEEKING PRODUCTION OF ALL OF MS. GIUFFRE’S SENT AND RECEIVED
EMAILS AND RELATED DATA
I, Meredith L. Schultz, declare that the below…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…During
that time, Plaintiff has had a full and fair opportunity to depose Ms. Maxwell on the subject
matters she claims are raised by these two emails, and Plaintiff did in fact question Ms. Maxwell
on the subjects covered by…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…deposition will not exceed a total of four hours. The
two separate issues relate to (1) Defendant’s failure to answer certain questions at her deposition
and (2) her late production of important emails. These two issues developed as follows.
…
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