giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…which includes only some of the documents created during discovery,
totals in the “thousands of pages”).
Giuffre sought and obtained a wide variety of private and confidential information about
Maxwell and others, including information about financial and sexual matters. Brown…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
… 21 right.
22 BY MR. KlNlN: i 22 BY l'vffi. HOROWITZ:
23 Q. Have you ever heard of the Financial l
!
23 Q. Did you use the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…10
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms.
Giuffre objects to this request in that it is overly broad and seeks confidential financial
information. Ms. Giuffre objects to this interrogatory in that…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.1
10 pg
…full.
370: Defendant's Motion for Unseal and redact only names and identifying information of Non-
Protective Order regarding Parties who have objected to unsealing or whose time to object to
Financial Information unsealing has not yet expired.
371 Unseal…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…Rule
37 “rejects cases such as Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99
8
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 11 of 17
(2d Cir. 2002)5…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…living with her
boyfriend. Nevertheless, Defendant insists on moving to compel highly personal financial
17
information from this non-party as set forth in Request 29: “A copy of your most recent
paycheck, paycheck stub, earnings statement and any bank…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…19 object on behalf of the
20 plaintiff, Virginia Giuffre, to
21 the extent that you're requesting
22 from a nonparty financial
23 information, which is not allowed
24 under New York law.
25 MS. MENNINGER: I have asked…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…into a bun
Judge Alison Nathan ruled Maxwell was a significant flight risk, citing her
'substantial international' ties and 'extraordinary financial resources'
Maxwell appeared via video, accused of grooming girls as young as 14 for Jeffrey
Epstein to…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)).
Furthermore…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…19 object on behalf of the
20 plaintiff, Virginia Giuffre, to
21 the extent that you're requesting
22 from a nonparty financial
23 information, which is not allowed
24 under New York law.
25 MS. MENNINGER: I have asked…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.15
6 pg
…me that there is a
19 not to answer the question. Nice try. 19 financial arrangement between Jean-Luc Brunel and
20 Instruct you not to answer based on 20 Jeffrey Epstein, do you not?
21 your Fifth Amendment privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…the weight to be accorded an assertion of a right of
privacy, courts should first consider the degree to which the subject
matter is traditionally considered private rather than
public. Financial records of a wholly owned business, family
affairs, illnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…personal, political, and financial gain, as well as to obtain potential blackmail
information.
One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual
relations with was former Harvard Law Professor Alan Dershowitz, a close friend…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…05/24 Page 9 of 22
standard of truth and were used for those who claimed they were victims
to receive financial payment to be shared between them and their lawyers.
One firm created and sold fake cases against Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…Ms. Maxwell’s personal financial information is not at issue in this
matter and information relating thereto is irrelevant. This Interrogatory also violates Local Rule
33.3(a) – (c) in that it does not seek the name of witnesses or…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)).
Furthermore…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…living with her
boyfriend. Nevertheless, Defendant insists on moving to compel highly personal financial
17
information from this non-party as set forth in Request 29: “A copy of your most recent
paycheck, paycheck stub, earnings statement and any bank…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…DOCUMENT REQUEST NO. 21
Produce all copies of the complaints in any lawsuits that You have filed in any court in
which You seek damages or any other financial recovery from 2014 to the present.
RESPONSE: Ms. Maxwell objects to…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…20 of 29
Plaintiff to fabricate facts or portions of her stories; and 5) they were not motivated in taking
their actions by potential financial gain . Edwards and Cassell point to both communications
with Plaintiff and their own work product…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…at length calling the plaintiff in that case,
5 Mr. McNamee, a liar, calling him a liar 25 ways to Sunday,
6 talking about his financial motives, his potential financial
7 gain, et cetera.
8 Likewise, in the Davis v…