giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…For example, Defendant swore under oath that she hardly was around Jeffrey Epstein for more
than “maybe an hour or two” in the years after 2003 until she claimed she ultimately left his
employment in 2008 or 2009. See Pottinger…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.11
5 pg
…9:08-cv-80736 (S.D. Fla. July 7,
2008.
Case 1:15-cv-07433-LAP Document 1090-11 Filed 07/30/20 Page 2 of 5
4. Attached hereto as Exhibit 2, is a true and correct copy…
giuffre-maxwell
gov.uscourts.nysd.447706.185.0
5 pg
…08-cv-80736 (S.D. Fla. July 7,
2008.
Case 1:15-cv-07433-LAP Document 185 Filed 06/01/16 Page 2 of 5
4.
5.
6. Attached hereto as Exhibit 4, Order denying Jane Doe 3’s…
giuffre-maxwell
gov.uscourts.nysd.447706.64.0
14 pg
…R.D. 685 (D. Kan. 1996) ............................................. 7
Fausto v. Credigy Svcs. Corp., 251 F.R.D. 427 (N.D.Ca. 2008) ........................................ 7
Hartman v. Am. Red Cross, No. 09–1302, 2010 WL 1882002 (C.D.Ill. May 11, 2010) .... 7…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…2 (E.D.N.Y. Sept. 21, 2011)
..................................................................................................................................................... 1
Harris v. Bornhorst, 513 F.3d 503, 525-26 (6th Cir. 2008) ......................................................... 10
Hlinko v. Virgin Alt. Airways, No…
giuffre-maxwell
gov.uscourts.nysd.447706.36.0
4 pg
… Attached hereto as Composite Exhibit 7, is a true and correct copy of the
September 9, 2008 Victim Notification Letter.
10. Attached hereto as Composite Exhibit 8, is a true and correct copy of the Notice
of Deposition of Ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.885.0
7 pg
…F.R.D. 160, 164 (S.D.N.Y. 2008) (“Work product may be shown to others when there is some
good reason to show it; however, once a party voluntarily discloses work product to an
adversary, the need for…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…of those dates. At this location, Ms. Giuffre lived with Robert
Giuffre.
! Blue Bay, NSW from approximately 2005 - 2008 but is not certain of
those dates. At this location, Ms. Giuffre lived with Robert Giuffre.
! 3 Elk St., NSW from…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…hotel moms/suites, automobiles, or aircraft.
11. All documents rdaling to your travel from the period of 1996 - 2008, when that
travel ,:vas either with Ghislaine Maxwell or Jeffrey Epstein, or to mee1 Ghislaine Maxwell or
Jeffrey Epstein, including but…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…of those dates. At this location, Ms. Giuffre lived with Robert
Giuffre.
! Blue Bay, NSW from approximately 2005 - 2008 but is not certain of
those dates. At this location, Ms. Giuffre lived with Robert Giuffre.
! 3 Elk St., NSW from…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…those dates. At this location, Ms. Giuffre lived with Robert
Giuffre.
Blue Bay, NSW from approximately 2005 - 2008 but is not certain of
those dates. At this location, Ms. Giuffre lived with Robert Giuffre.
3 Elk St., NSW…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…C.f. U.S. S.E.C.
v. Shehyn, 2008 WL 6150322, at *4 (S.D.N.Y. 2008) (“Whatever delay there may have been in
applying to the Spanish Central Authority was caused, in large part, by defendant Donald…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…their locations are, just in case
anything happens to me before the footage is released.
When my friend eventually had the courage to speak out and went to the police in 2008 to report
what had happened, nothing was done…
giuffre-maxwell
gov.uscourts.nysd.447706.205.0
7 pg
…Supp. 2d 606, 611 (E.D. Va. 2008)
(“Applying the clear and unambiguous language of § 2702 to this case, AOL, a corporation that
provides electronic communication services to the public, may not divulge the contents of the
Rigsbys’ electronic communications…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…those dates. At this location, Ms. Giuffre lived with Robert
Giuffre.
Blue Bay, NSW from approximately 2005 - 2008 but is not certain of
those dates. At this location, Ms. Giuffre lived with Robert Giuffre.
3 Elk St., NSW…
giuffre-maxwell
1320-37
48 pg
…of those dates. At this location, Ms. Giuffre lived with Robert
Giuffre.
! Blue Bay, NSW from approximately 2005 - 2008 but is not certain of
those dates. At this location, Ms. Giuffre lived with Robert Giuffre.
! 3 Elk St., NSW from…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…of those dates. At this location, Ms. Giuffre lived with Robert
Giuffre.
! Blue Bay, NSW from approximately 2005 - 2008 but is not certain of
those dates. At this location, Ms. Giuffre lived with Robert Giuffre.
! 3 Elk St., NSW from…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…of a team of lawyers that included Roy Black, Gerald Lefcourt, Kenneth Starr,
Martin Weinberg, and several others. In 2008, Mr. Epstein pleaded guilty to certain offenses
involving sex with minors.
8. Virginia Roberts Giuffre, the plaintiff in this action…
giuffre-maxwell
gov.uscourts.nysd.447706.207.0
7 pg
…550 F. Supp. 2d 606, 611 (E.D. Va.
2008) (“Applying the clear and unambiguous language of § 2702 to this case, AOL, a
corporation that provides electronic communication services to the public, may not divulge the
contents of the Rigsbys…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.25
4 pg
…Maxwell; is that correct? 09:20:05
10· · · · A.· ·It does appear to be so. 09:20:07
11· · · · Q.· ·Did you send the top email of the chain that 09:20:08
12· ·says "Okay, G, going with this"…
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