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.447706.1219.43
12 pg
…files this Reply in
Support of her Motion to Compel Data from Defendant’s Undisclosed Email Account and for
Adverse Inference Instruction.
This Court Ordered Defendant to search for and produce documents from all her email
accounts from 1999-present…
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.447706.751.9
3 pg
…denial comes after two Sunday papers in Britain published interviews with the woman in which she
claimed that she was forced by American financier Jeffrey Epstein to have sex with Prince Andrew at least three
times between 1999 and 2002…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…produce
clear and convincing evidence of its falsity. ........................................................... 56
1. The January 2015 statement accurately denied that Ms. Maxwell met
Plaintiff when Plaintiff was 15 years old in 1999. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.441.0
18 pg
…C ou rt’s A pril21,2016,ru lingM s.Giu ffre has mad e significantefforts to try to
trackd own and collectany med icalrecord she can find from 1999 to the present,inclu d ingpayingall
fees associated withthatcollection process…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…01/08/24 Page 3 of 42
Importantly, Defendant has never denied using an email account for communication from
1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant
did not use an email account…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…07/15/21 Page 2 of 12
Importantly, Defendant has never denied using an email account for communication from
1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant
did not use an email account…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…nor produce documents from it.
Importantly, Defendant has never denied using an email account for communication from
1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant
did not use an email account to…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…1986) ............................................................................................... 11
Granite Partners, L.P. v. Bear Stearns & Co. Inc.,
184 F.R.D. 49 (S.D.N.Y.1999) ................................................................................................. 11
Guiffre v. Maxwell,
2016 WL 1756918 (S.D.N.Y…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.29
4 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.447706.343.0
8 pg
…routinely grant extensions of time of deadlines when awaiting Hague Convention
service, and the facts and circumstances in this case call for the same. Daly v. Llanes, 1999 WL
259507, (S.D.N.Y. April 30, 1999), is perfectly illustrative:
…
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.447706.1320.33
24 pg
…2016 hearing on Ms. Maxwell’s Motion to Compel, the Court clearly
Ordered Plaintiff to disclose all of her treating health care providers since 1999 and produce their
records. Plaintiff did not do so, and still has not provided this…
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.447706.149.0
9 pg
…wit, that Ms. Maxwell “assisted” and participated in
sexual abuse of the Plaintiff between 1999 and 2002.
Plaintiff does not claim that any sexual abuse occurred after 2002 or that she had any
contact with Ms. Maxwell after 2002. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…2016 hearing on Ms. Maxwell’s Motion to Compel, the Court clearly
Ordered Plaintiff to disclose all of her treating health care providers since 1999 and produce their
records. Plaintiff did not do so, and still has not provided this…
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.447706.230.0
19 pg
…2016) ............................ 1,2,3
Quantachrome Corp. v. Micromeritics Instrument Corp., 189 F.R.D. 697, 701 (S.D. Fla. 1999)10
Redwood v. Dobson, 476 F.3d 462, 467-68 (7th Cir. 2007) ........................................................... 9
Vincent v. Mortman, No. 04 Civ…
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