giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…Any Documents containing any Communications You have had with any law enforcement
agency.
RESPONSE:
21
Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 23 of 27
In addition to the Preliminary Statement and…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…including the transmission of any Document, that
You or Your Attorneys have had with any local, state or federal law enforcement agent or
agency, whether in the United States or any other country, whether in Your capacity as a
purported…
giuffre-maxwell
gov.uscourts.nysd.447706.35.1
4 pg
…Request No. 38
i. Verbatim Statement of Request No. 38
All documents reflecting contact with you by any law enforcement or police agency,
including any contact by the FBI, Palm Beach Police Department, or West Palm Beach Police
Department.
ii. …
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…She also testified that during the operative time frame she was making
money working for an agency in New York who arranged to have her paid $1,500 to “entertain”
or “spend time” with “gentlemen” with whom she sometimes engaged…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…1996). “As a general rule, a communication by a client
to his attorney by any form of agency employed or set in motion by the client is within the
privilege.” Mileski v. Locker, 178 N.Y.S.2d 911 (Sup…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.11_3
23 pg
…planes
19 but I can't testify to anything past 2002,
20 2003, what happened to his planes after that.
21 Q. Do you know what travel agency, if
22 any, Jeffrey would use when he would send
23 someone…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…the subject of “strong current media interest.” Nor
does the fact that Professor Dershowitz is not himself a news agency negate his access rights:
“The First Amendment generally grants the press no right to information about a trial superior to…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…attorney-client privilege, the attorney work product
18 privilege, the joint defense, interest privilege, the agency
19 privilege, the investigative privilege, the spousal privilege,
20 the accountant/client privilege, and any other applicable
21 privilege."
22 THE COURT: Hot dog. …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…(Complaint ¶ 52, 64; motivation to fabricate)
25. Any Documents containing any Communications You have had with any law
enforcement agency.
9
26. Any Documents that reflect any criminal charges, tickets, summonses, arrests,
investigations concerning You or witnessed by You.
27…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…including the transmission of any Document, that
You or Your Attorneys have had with any local, state or federal law enforcement agent or
agency, whether in the United States or any other country, whether in Your capacity as a
purported…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…Tel. & Tel. Corp. applies where, as here, “a government
agency seeks modification of a protective order governing
discovery in a civil action.” Daniels, 200 F.R.D. at 207 (citing
Martindell, 594 F.2d at 296). Under the Martindell standard…
giuffre-maxwell
gov.uscourts.nysd.447706.55.21
69 pg
…this 13 MR. WILLITS: I'm sorry.
14 position as household manager? 14 THE VIDEOGRAPHER: Do you want to go off
15 A. Through an employment agency. 15 the record?
16 Q. Do you know which employment agency it 16…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…in a case would only
matter if the material was sought to allow the public to monitor the Court’s actions (which is
why the courts in this district often recognize a news agency’s standing to challenge protective
orders32)…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…co.uk]
From: Jenna
·sent: Tue 3/15/201110:55:12 PM
Importance: Normal _ __
Subject: RE : Here is contact info for NY literary agency u might like
Received: Tue 3/15/2011 10:55:12 PM
Thanks so much shazza…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…records.
Plaintiff added equally non-applicable privileges to other of her responses. For example,
she claimed an “agency privilege,” “investigative privilege” and “accountant client privilege”
with respect to Request No. 13 – “All Documents concerning any allegations of theft by You…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…faces of her minor children.” Id. at 19.
“Ms. Giuffre is withholding documents that concern or relate to any currently
ongoing investigation by any law enforcement agency under the public interest
privilege and other applicable privileges”. Id. at 20.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…26
0 230 Rent Lease & Ejectment D 442 Employment use 7609 Act/Review or Appeal of
0 240 Torts to Land D i~~~~,~s~d~{ions Other: …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…undue
harassment serving no admissible purpose.
25. Any Documents containing any Communications You have had with any law enforcement
agency.
RESPONSE:
21
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…any employee, agent, attorney, consultant, or representative of Jeffrey Epstein.
8. “Person(s)” includes natural persons, proprietorships, governmental agencies,
corporations, partnerships, trusts, joint ventures, groups, associations, organizations or any other
legal or business entity.
9. “You” or “Your” …
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…including the transmission of any Document, that
You or Your Attorneys have had with any local, state or federal law enforcement agent or
agency, whether in the United States or any other country, whether in Your capacity as a
purported…