giuffre-maxwell
gov.uscourts.nysd.447706.1218.28
3 pg
…s pedophile proclivities.
One source told the cops, according to
Radar's report, that Epstein had promised,
"I'll pay you if you bring some girls. He told
her the younger the better. [The girl] once
stated she once tried…
giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…He’d gotten to them because of
his money. He promised the older sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Court to re-open discovery for the deposition of Ms. Ransome, promised to make
her available “immediately” for deposition and agreed to accept a subpoena for her to produce
documents, in an attempt to “cure” her own late disclosure. Now…
giuffre-maxwell
gov.uscourts.nysd.447706.422.0
8 pg
…for Mr. Epstein. These efforts were
apparently useless because, although counsel for the Plaintiff promised the Court that she would
“gladly” produce the documents with a “waiver from Mr. Epstein,” she has reneged on that
promise, forcing Ms. Maxwell to…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…to pending issues in this case; and fourth and finally, Jane Doe No. 3 attests in a
1
As promised in their motion to join (DE 280), Jane Doe No. 3 and Jane Doe No. 4 do not seek to…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.4
6 pg
…Cassell ([email protected])
Subject: Re: Notice of Subpoena
Sigrid and Brad -
We had a conferral last week in which you promised to provide for conferral purposes a proposed schedule for depositions we
both had requested in various locations…
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
…He’d gotten to them because of
his money. He promised the older sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…Court to re-open discovery for the deposition of Ms. Ransome, promised to make
her available “immediately” for deposition and agreed to accept a subpoena for her to produce
documents, in an attempt to “cure” her own late disclosure. Now…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…waiver. In any event, whether served or not, Mr.
Brunel apparently promised to provide new dates before his deposition date came and went, did
not do so, has left the country and not indicated a present intention to return. Given…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…at
230; see Brown, 929 F.3d at 48 n.22 (redacting confidential or sensitive information
because of the witnesses’ “strong expectation of continued confidentiality” that had been
promised under protective order).
L. Improper submission of documents. Documents that a…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…to
9 continue to redact them until we take up those particular Does
10 in the future and your Honor has an opportunity to do the
11 particularized review that the protocol promised would happen
12 with respect to nonparties…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…He’d gotten to them because of
his money. He promised the older sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…1 HIGHLY CONFIDENTIAL AEO
2 do that?
3 A. Yes.
4 Q. Were you promised anything
5 in exchange for your testimony in the
6 Giuffre versus Maxwell case?
7 A. No.
8 Q. Were you provided legal
9 counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…1 HIGHLY CONFIDENTIAL AEO
2 do that?
3 A. Yes.
4 Q. Were you promised anything
5 in exchange for your testimony in the
6 Giuffre versus Maxwell case?
7 A. No.
8 Q. Were you provided legal
9 counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.15
6 pg
…KUVIN: Sure. 9 BY MR. KUVIN:
10 MR. RHEIN HART: You can answer the 10 Q. Were you ever promised anything regarding
11 question. 11 your modeling career by Jeffrey Epstein?
12 THE WITNESS: Yes. …
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…He’d gotten to them because of
his money. He promised the older sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…LAP
DocumentDocument
324 Entered
1074-5
on FLSD
Filed Docket
07/01/20
…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…2016 deposition transcript at issue here, the first set of
deposition materials was not based on a specific promise by the Court and plaintiff’s counsel that
all of the answers would be kept confidential under the Protective Order. Rather…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…waiver. In any event, whether served or not, Mr.
Brunel apparently promised to provide new dates before his deposition date came and went, did
not do so, has left the country and not indicated a present intention to return. Given…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…format, or permit inspection of the same.
D. Request 9-12: Passports, Visas and Other Travel Documents
In Response 9, Ms. Ransome promised that her “current passport is attached.” Pottinger
Decl. Ex. 1 at 10. It was not. Ms. Ransome…
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