giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Deposition excerpts indicating Dershowitz received "a massage" at Epstein's home; (6) Portions
of an address book containing Dershowitz's name and contact information which an Epstein
associate characterized as "the Holy Grail;" and (7) Numerous demonstrably incomplete flight
manifests…
giuffre-maxwell
gov.uscourts.nysd.447706.235.2
4 pg
…employment, the address and telephone number for the employers, job titles
and income from such employer. Interrog. 9.
Plaintiff’s health care providers from 1999 – present, including their name,
address, telephone number, and dates of any treatment. Interrog. 12…
giuffre-maxwell
gov.uscourts.nysd.447706.232.1
…mental or emotional condition, that You suffered from subsequent to any
Alleged Defamation by Ghislaine Maxwell, including:
a. the Health Care Provider’s name, address, and telephone number;
14
Case 1:15-cv-07433-LAP Document 232-1 Filed…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…invocations provide any
basis for staying this case. Defendant suffers no prejudice going into her deposition not knowing
the name of the law enforcement entity because truthful testimony should not change.
Accordingly, the Court should deny Defendant’s motion in…
giuffre-maxwell
gov.uscourts.nysd.447706.719.0
1 pg
…201 7, the Court
addressed and resolved the ore tenus motion requesting the redaction of the non-party's witness
name, that did not address the substance of the Non-Party's Motion for Protective Order which
seeks relief from…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.25
10 pg
…01/05/24 Page 3 of 10
Page 8
1 Q. Okay. Great.
2 All right. Do you know a female by the
3 name of Ghislaine Maxwell?
4 A. Yes.
5 Q. And when did you first meet Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…not going to work because not all
21 of this stuff at issue is going be to confidential. No, no
22 way. What is your name? Ok. We will deal with tomorrow's
23 problem tomorrow.
24 MR. PAGLIUCA: Ok…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…CIV-MARRA/JOHNSON. Request no. 1, for example, demands: “All documents that
reference by name, Alan M. Dershowitz, which support and/or confirm the allegations set forth in
Paragraphs 24-31 of your Declaration dated January 19, 2015 and/or…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
… Identify any email address, email account, cellphone number and cellphone
provider, social media account and login or screen name, text or instant messaging account name
and number, that You have used, applied for or been supplied between 1998 and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Gow actually issued the statement pertinent to this
defamation suit. Plaintiff has known about Ross Gow and his role in this lawsuit since the
outset: She referenced him repeatedly by name in the Complaint filed on September 21, 2015.
See…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…(Jane Doe 3,
Virginia Giuffre, subsequently decided to reveal her name). The joinder motion argued that Jane
Does 3 and 4 should be allowed to join the two existing plaintiffs in the action because they had
suffered the same violations…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…Virgin Islands. See 3 V.I.C. § 114(3) (USVI
Attorney General has power and duty to “prosecute in the name of the People of the Virgin
Islands, offenses against the laws of the Virgin Islands”); 14 V.I.C. …
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…be cooperating with people who are much
less culpable than her. Will she name names to try to shave years off of what
would be a lengthy prison sentence maybe, I think you should probably expect
that if she’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
…more than one occasion? 2 take from frequent people -- I mean, people who
3 A. I heard her name several times from 3 used to frequent the house and -- I'm sorry, it's
4 Sarah, sir, but beyond that…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…(June 1, 2016) (McCawley Decl. at Sealed Exhibit 1).
Accordingly, mindspring was a domain name set up for Jeffrey Epstein and his household to
communicate with one another, and was, in fact, used in this manner.
The sworn testimony of…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…01/05/24 Page 8 of 40
Page 8
1 Q. Okay. Great.
2 All right. Do you know a female by the
3 name of Ghislaine Maxwell?
4 A. Yes.
5 Q. And when did you first meet Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.14_1
11 pg
…s entirely
20 possible that in the course of conversations
21 since 2002, 2003 that a conversation in which
22 name would have come up is entirely
23 possible.
24 Q. I provided you with and I'm sorry,
25 …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…witness who has emails and
photographs that corroborate her testimony. There is no need whatsoever for the Defendant to
know the name of the non-party’s current treating physician or other intrusive, threatening,
personal information irrelevant to this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…this Doe at her deposition,
23 plaintiff Giuffre testified that she believed Doe 17 also went
24 by another specified name "if it's the same woman I'm thinking
25 of." Doe 17 never went by the specified name…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…A, p. 59. Churcher also had extensive discussion with Plaintiff on the best strategies for
getting interest in her book, including determining when to “name names” Menninger Decl. Ex.
A, p. 63. She strategized with Plaintiff and Plaintiff’s counsel…