giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…former friends claim
Virginia Roberts claims she was recruited to Epstein's harem in 1999
Named Prince Andrew and Alan Dershowitz as men she had to 'service'
Her friends say there was no indication she was being held captive
Asked…
giuffre-maxwell
gov.uscourts.nysd.447706.35.1
4 pg
… Verbatim Statement of Request No. 1:
All documents relating to communications with Jeffery Epstein from 1999 – Present
ii. Maxwell’s Response:
Maxwell objects to this Request on the grounds that it is overly broad and unduly
burdensome and calls for…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre
c/o Sigrid S. McCawley…
giuffre-maxwell
1320-40
19 pg
…Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre
c/o Sigrid S. McCawley…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…r. 32.7 – Control of Major Hazard Regulations
1999.
This was an application by the third party (TAV) for specific disclosure of
documents over which the defendants had asserted litigation privilege. E
The proceedings arose out of the explosion and…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…her agent, associate, employee or assignee.
3. “Your Attorneys” includes any attorney who You have engaged to represent You,
whether for remuneration or pro bono, from 1999 until today, including without limitation,
David Boies, Paul Cassells, Bradley Edwards, Spencer Kuvin…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
… Ms. Giuffre Has Answered This Interrogatory Completely .....................10
2. This Court Has Already Ruled Against Defendant on Pre-1999
Medical Records, so Defendant is Estopped From Bringing This
Argument .........................…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…R.D. 190 (W.D.N.Y. 2005) ............................... 10
Kolenc v. Bellizzi, No. 95 CIV. 4494 (LMM KNF), 1999 WL 92604 (S.D.N.Y. Feb. 22, 1999) .. 8
Lyman v. Felter, No. 1:12-CV-530 MAD/RFT, 2015…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…Yetev Lev D'Satmar, Inc.,
265 A.D. 2d 360, 696 N.Y.S. 2d 496 (2d Dep't. 1999) .............................................................12
Brooks v. Macy's, Inc.,
No. 10 CIV 5304 (BSJ/HBP), 2010 WL 5297756 (S.D.N.Y. Dec…
giuffre-maxwell
gov.uscourts.nysd.447706.637.0
12 pg
…Co. Inc., 184 F.R.D. 49, 54 (S.D.N.Y.1999) (Sweet, D.J.); see also Coleco Indus., Inc.
5
Case 1:15-cv-07433-RWS Document 637 Filed 02/22/17 Page 6 of 12
v…
giuffre-maxwell
gov.uscourts.nysd.447706.56.0
14 pg
…Co. v. Certain Underwriters at Lloyd's
263 A.D. 2d 367, 692 N.Y.S. 2d 384 (1999)...............................................................................2
Anwar v. Fairfield Greenwich Ltd,,
982 F. Supp. 2d 260 (S.D.N.Y. 2013) .........................................................................................1
Astra A…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…Notably, the police report documents that neither the residences she was moving
from or to involved the apartment Plaintiff claims was rented for her by Jeffrey
Epstein and where she testified she lived exclusively from June 1999 until
September 2002…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…attempts to limit discovery to the month of December 30, 2014 – January 31, 2015
when her defamatory statement was issued and 1999 – 20024. Maxwell’s time period limitation
clearly violates both the letter and spirit of Rule 26. For example…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…Maxwell or
Jeffrey Epstein with knowledge of Defendant and Jeffrey Epstein’s inappropriate
conduct with underage girls.
72. All staff and employees at the Mar-a-Lago Club during 1999-2002.
73. All other witnesses learned through discovery process.
B…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…and/or Jeffrey Epstein.
15. All documents relating to any telephone, including any cellular telephone, used by you
between January 1, 1999 and December 31, 2002.
16. Any diary, journal or calendar concerning your activities between January 1, 1999 and
…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…15
15. Defendant also demands items like personal financial documents from this non-party
including payments she received from convicted sex offender Jeffrey Epstein and the men he
“lent” this minor child out to from 1999 – 2002. See Exhibit 6…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…to, or with whom You
engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999,
including the names of the individuals involved, the dates of any such illegal or inappropriate
sexual contact, conduct or assault…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Ms. Maxwell only received her pilot’s license in mid-1999 casting
insurmountable doubt that a recently retired president and his staff would be permitted to fly
with her at the helm.
With the record thus, Plaintiff’s claims about…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…CSX Transp., Inc. v. Carpenter,
725 So.2d 434 (Fla. 2d DCA 1999)........................................................................................................30
Delap v. State,
440 So.2d 1242 (Fla. 1983)...................................................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Florida law, the records were redacted for the identity and identifying
information as pertains to Plaintiff.
These same reports document that Plaintiff was a resident at a drug rehabilitation
facility from at least February 1999 until December 1999, whereas she…
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