giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…Epstein’s sexual trafficking
conduct and interaction with underage minors.
11. Ron Burkle
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein’s sexual trafficking
conduct.
12. Dana Burns
Address…
giuffre-maxwell
gov.uscourts.nysd.447706.648.0
4 pg
…designations.
May 4, 2107, Pre-trial Conference to address any outstanding issues including
confidentiality.
WHEREFORE, the parties request that the Court adopt the proposed schedule and
modify the Court' s Order of October 3, 2016 to reflect the above deadlines…
giuffre-maxwell
gov.uscourts.nysd.447706.813.0
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is not intended
to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.733.0
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.739.0
3 pg
…[email protected]
/s/ Meredith Schultz
Meredith Schultz, Esq.
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endor…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…So they present more or less similar arguments. We request leave to address their three
separate briefs in a single reply brief. We submit this will be more succinct and efficient and less
repetitious for the Court.
As the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.933.0
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is not intended
to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…Doe #1, Doe #2, and Doe #3.
• Provide the address or contact information for each Non-Party or his or her legal
counsel, which the Original Parties identified to the best of their ability.
2. Judicial Adjudication: Because of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…be
considered, but reached an impasse as to the remaining four motions.
Plaintiff’s position is that the Court should address the motions in an order that prioritizes
those containing the most docket entries that involve the non-parties. To…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…produced in this litigation is from July 18, 2009.
(GM_00069). Ms. Giuffre is aware of two email addresses that appear to be the email addresses
Defendant used while Ms. Giuffre was with Defendant and Epstein, namely, from 2000 - 2002.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.29
4 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.9
4 pg
…UT 84112
(801) 585-52022
2
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…project. Before reaching the merits of
sealing/redaction of the Sealed Materials we think it appropriate and necessary to
address the complexity and difficulty of the project as well as its difficult-to-overstate
importance to the lives of Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…And, once again, the Court ordered
Defendant to answer questions about the subjects she had refused to address, enumerating four
specific topics:
The Plaintiff has moved to compel answers to questions which were the subject of
the June 20, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.6_3
17 pg
…see - - can you read back the question?
11 (Record read.)
12 A. I ' m not addressing any questions
13 about consensual adult sex. If you want to
14 talk about what the subject matter, which is
15 defamation and lying…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.3_1
4 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.1
2 pg
…and painful loss over the last few days that I can't even see what life
after press he'll even looks like - statements that don't address all just lead to more questions ..what is my
relationship to clinton …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…produced in this litigation is from July 18, 2009.
(GM_00069). Ms. Giuffre is aware of two email addresses that appear to be the email addresses
Defendant used while Ms. Giuffre was with Defendant and Epstein, namely, from 2000 - 2002.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…Giuffre’s counsel sent a
follow up letter on July 8, 2016 requesting that Defendant also search a previously undisclosed e-
mail address for Defendant that Ms. Giuffre discovered when reviewing a FOIA production from
the Palm Beach County State…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…obtained pursuant to a FOIA request, that contained at Page 2035 an
address book from approximately 2005 which has that earthlink account name next to Ms. Maxwell’s name.
Please advise of the processes you are undertaking to access the…