giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…Maxwell April 22, 2016,
The above photos were taken in 2006 on Jeffrey Epstein’s island and depict Defendant
Maxwell as an active participant in photos at the Island home. The photos also depict a number
of the girls…
giuffre-maxwell
gov.uscourts.nysd.447706.1008.0
5 pg
…435 F.3d 110, 123 (2d Cir. 2006) (holding that documents
submitted with a motion are “unquestionably judicial documents” “by virtue of having been
submitted to the court”). For the following reasons, the Court should hold that materials submitted
in…
giuffre-maxwell
gov.uscourts.nysd.447706.64.0
14 pg
…4849718 (N.D.W.Va. Oct. 11, 2012) .............................................................. 7
Design Strategy, Inc. v. Davis, 469 F.3d 284 (2d Cir. 2006) .............................................. 2
Dixon v. Certainteed Corp., 164 F.R.D. 685 (D. Kan. 1996) ............................................. 7
Fausto v. Credigy Svcs. Corp.…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…Inc., No. 05 CIV. 4837(HB), 2006 WL 1409413, at *7 (S.D.N.Y. May 23, 2006)
(holding that a sanction as severe as an adverse inference was not warranted where defendants came forward with
the evidence, even though…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…2006) (professional journalist waived the exemption
of the Shield Law if they voluntarily disclose or consent to disclosure of otherwise covered
information to third parties).
None of the documents or information described above is covered by the New York
Shield…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…Palm Beach, FL 33411 and a
telephone number of 561-651-0400.
! Ms. Giuffre worked at Employment Training and Recruitment Australia from
approximately 2005 through January of 2006, but Ms. Giuffre is unsure of the exact
dates of employment. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…Inc., No. 05 CIV. 4837(HB), 2006 WL 1409413, at *7 (S.D.N.Y. May 23, 2006)
(holding that a sanction as severe as an adverse inference was not warranted where defendants came forward with
the evidence, even though…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…R. Civ. P. 37.......................................................................................................................... 12
iii
Ransome_000218
Non-Party Sarah Ransome in 2006 on Little St. James Island
…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…R. Civ. P. 37.......................................................................................................................... 12
iii
Ransome_000218
Non-Party Sarah Ransome in 2006 on Little St. James Island
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…the years 2005-present.
11. All Documents referencing any commercial plane tickets, boarding passes, or any other
mode of travel during the time period 2006-2007.
12. Any credit card receipt, canceled check, or any other Document reflecting travel by…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…Palm Beach, FL 33411 and a
telephone number of 561-651-0400.
! Ms. Giuffre worked at Employment Training and Recruitment Australia from
approximately 2005 through January of 2006, but Ms. Giuffre is unsure of the exact
dates of employment. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…as a waiver of any applicable privilege,”
OneBeacon Ins. Co. v. Forman Int'l Ltd., 04 CIV. 2271(RWS), 2006 WL 3771010, at *7–8
(S.D.N.Y. Dec. 15, 2006). As this Court noted in OneBeacon Ins. Co.…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…start forwarding you, all the emails which I have managed to save. They include the
following:
I moved from Edinburgh to
New York in September 2006, where shortly after I was introduced to Jeffery Epstein by Natalie.
. A couple months…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…2007) ........................................................... 9
Vincent v. Mortman, No. 04 Civ. 491, 2006 WL 726680, at *1–2 (D. Conn. Mar. 17, 2006) ....... 1
ii
Case 1:15-cv-07433-LAP Document 230 Filed 06/20/16 Page 4 of 19
Pursuant…
giuffre-maxwell
1320-37
48 pg
…Palm Beach, FL 33411 and a
telephone number of 561-651-0400.
! Ms. Giuffre worked at Employment Training and Recruitment Australia from
approximately 2005 through January of 2006, but Ms. Giuffre is unsure of the exact
dates of employment. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…Palm Beach, FL 33411 and a
telephone number of 561-651-0400.
! Ms. Giuffre worked at Employment Training and Recruitment Australia from
approximately 2005 through January of 2006, but Ms. Giuffre is unsure of the exact
dates of employment. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…prior to being retained as one of his lawyers.
7. Mr. Epstein retained me as a criminal defense lawyer towards the end of 2006. I
was hired as part of a team of lawyers that included Roy Black, Gerald Lefcourt…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…630 F.2d 139 (3d Cir. 1980).....................................................................................................10
Velez v. Hunts Point Multi-Serv. Ctr., Inc.,
29 A.D.3d 104, 811 N.Y.S.2d 5 (1st Dep’t 2006) ...................................................................12
Constitutional Provisions
N.Y. Const.…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…as a waiver of any applicable privilege,”
OneBeacon Ins. Co. v. Forman Int'l Ltd., 04 CIV. 2271(RWS), 2006 WL 3771010, at *7–8
(S.D.N.Y. Dec. 15, 2006). As this Court noted in OneBeacon Ins. Co.…
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