giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…a disk you produced last week, 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.
-
2. Terramar – You have withdrawn…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.11
4 pg
…Report.
10. Attached hereto as Exhibit 8, is a true and correct copy of the November 21, 2005
Sworn Statement of Juan Alessi.
11. Attached hereto as Exhibit 9, is a true and correct copy of the May 4, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.8
6 pg
…1.Iw illendeavortohavem y clientgainaccesstoanearthlinkaccountthatyou believeishers.Yourbasisforthat
beliefisadiskyou produced lastw eek,obtained pursuanttoaFO IA request,thatcontained atP age2035 an
addressbookfrom approxim ately 2005 w hichhasthatearthlinkaccountnam enexttoM s.M axw ell’snam e.
P leaseadviseofthepr…
giuffre-maxwell
1320-11
4 pg
…Report.
10. Attached hereto as Exhibit 8, is a true and correct copy of the November 21, 2005
Sworn Statement of Juan Alessi.
11. Attached hereto as Exhibit 9, is a true and correct copy of the May 4, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.173.0
4 pg
…Report.
10. Attached hereto as Exhibit 8, is a true and correct copy of the November 21, 2005
Sworn Statement of Juan Alessi.
11. Attached hereto as Exhibit 9, is a true and correct copy of the May 4, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.30
6 pg
…1.Iw illendeavortohavem y clientgainaccesstoanearthlinkaccountthatyou believeishers.Yourbasisforthat
beliefisadiskyou produced lastw eek,obtained pursuanttoaFO IA request,thatcontained atP age2035 an
addressbookfrom approxim ately 2005 w hichhasthatearthlinkaccountnam enexttoM s.M axw ell’snam e.
P leaseadviseofthepr…
giuffre-maxwell
gov.uscourts.nysd.447706.279.0
8 pg
…LP v. Petroleos de
Venezuela, S.A., 2005 WL 1026461, at *1 (S.D.N.Y. May 2, 2005) (denying application to set
aside Magistrate Judge Peck’s order entering an adverse inference instruction against defendant
for failure to produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…LP v. Petroleos de Venezuela, S.A., 2005 WL 1026461, at *1 (S.D.N.Y. May 2, 2005)
(denying application to set aside Magistrate Judge Peck’s order entering an adverse inference
instruction against defendant for failure to produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…LP v. Petroleos de Venezuela, S.A., 2005 WL 1026461, at *1 (S.D.N.Y. May 2, 2005)
(denying application to set aside Magistrate Judge Peck’s order entering an adverse inference
instruction against defendant for failure to produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…LP v. Petroleos de
Venezuela, S.A., 2005 WL 1026461, at *1 (S.D.N.Y. May 2, 2005) (denying application to set
aside Magistrate Judge Peck’s order entering an adverse inference instruction against defendant
for failure to produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…of that date. At this location, Ms. Giuffre lived with Robert
Giuffre.
! N. Paramentata, NSW from approximately 2003 - 2005, but she is not
certain of those dates. At this location, Ms. Giuffre lived with Robert
Giuffre.
! Blue Bay, NSW from…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…defined terms. It resulted in nothing.
1
Plaintiff conveniently omits the fact that the EarthLink and MindSpring accounts were in an address book
purportedly recovered from Mr. Epstein’s home by the Palm Beach Police in 2005. Thus, there is…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…her permissions to live, work or study in a
foreign country for the years 2005 – present.” What is responsive and relevant to this case - the
passport she held during the years 2006 and 2007 - has been produced. The reminder is…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…LP v. Petroleos de Venezuela, S.A., 2005
WL 1026461, at *1 (S.D.N.Y. May 2, 2005) (denying application to set aside Magistrate Judge
Peck’s order entering an adverse inference instruction against defendant for failure to produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…Okay. Do you recall on any occasion who
2 Q. The next page is a message in the upper 2 would travel with him to the Virgin Islands?
3 lelt dated January 13, 2005, from C.W. Correct? 3 MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…LP v. Petroleos de Venezuela, S.A., 2005 WL 1026461, at *1 (S.D.N.Y. May 2, 2005)
(denying application to set aside Magistrate Judge Peck’s order entering an adverse inference
instruction against defendant for failure to produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…her permissions to live, work or study in a
foreign country for the years 2005 – present.” What is responsive and relevant to this case - the
passport she held during the years 2006 and 2007 - has been produced. The reminder is…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…9. All of Your passports, travel visas, or pennissions to live, work or study in a foreign
country, related to the years 2005-present.
10. All Communications regarding any of Your passports, visas, visa applications, or other
permission to live…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…LP v. Petroleos de Venezuela, S.A., 2005
WL 1026461, at *1 (S.D.N.Y. May 2, 2005) (denying application to set aside Magistrate Judge
Peck’s order entering an adverse inference instruction against defendant for failure to produce…
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