giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…Jan 23, 2015 at 6:03 PM, G Maxwell wrote:
gawker have printed the entire address book, albeit redacted x
Sent from my iPad
please note
The information contained in this communication is
confidential, may be attorney…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…NO. 24
All documents relating to contact lists, phone lists or address books for you or Jeffrey Epstein
from 1999 – present.
DOCUMENT REQUEST NO. 25
All documents relating to any hospital records for Virginia Roberts Guiffre.
DOCUMENT REQUEST NO. 26…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…family, in the presence
of young girls.11 It also appears that Rodriguez would later circle Dershowitz’s name in Epstein’s
address book as among the people with important information for the FBI to collect regarding
sex trafficking. In…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…its annual Renaissance Award to
Wexner for giving “critical support and counsel to Hillel.”
Though Wexner has reportedly replaced (http://www.palmbeachdailynews.com/news/news/jeffrey-epstein-address-book-
holy-grail-of-famous-/nMCxm/) Epstein with a new money manager…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…Exhibit E
Case 1:15-cv-07433-LAP Document 363-5 Filed 08/11/16 Page 2 of 6
District Court Fremont County, Colorado
Court Address:
136 Justice Center Rd
Canon City, CO 81212
Plaintiff(s)/Petitioner(s): Edwards…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…BRINCKERHOFF 600 FIFTH AVENUE AT ROCKEFELLER CENTER FACSIMILE
JONATHAN S. ABADY 10TH FLOOR (212) 763-5001
EARL S. WARD NEW YORK, NEW YORK 10020 …
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…2
I. CHURCHER IS A MATERIAL FACT WITNESS AND WAS NOT ACTING AS A
JOURNALIST ..................................................................................................................... 2
A. Churcher was acting as a friend and advisor to help Plaintiff publish her book, not as
journalist…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…Epstein’s sexual trafficking
conduct and interaction with underage minors.
11. Ron Burkle
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein’s sexual trafficking
conduct.
12. Dana Burns
Address…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…7 There's two points on that, and he can address them as
8 well.
9 The protective order itself that we entered in the
10 case does have a paragraph in it that addresses the trial. It
11 provides…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…possession, custody or control, or of which You have knowledge, including but not limited to, e-
mails, text messages, instant messages, videotapes, photographs, notes, letters, memoranda,
forms, books, magazines, resumes, notebooks, ledgers, journals, diaries, calendars, appointment
books, papers, agreements, contracts…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…minors.
5. Kathy Alexander
Address unknown at this time.
Telephone number unknown at this time.
Believed to be in South Africa.
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors.
6. …
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…babe!!! The book next...
See you tomorrow.
Hugs ,
s
XOxO
This e-mail and any attached files are intended for the named addressee
only. It contains information, which may be confidential and legally
privileged and also protected by copyright. Unless…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…b) Also Allows Interrogatories as a “More Practical” Means of
Obtaining Discovery ....................................................................................................... 14
B. Plaintiff Refuses To Provide Her Residence, Domicile And Address Where She
Lived During Alleged “Defamation.” ....…
giuffre-maxwell
gov.uscourts.nysd.447706.76.2
21 pg
…Epstein’s sexual trafficking
conduct and interaction with underage minors.
11. Ron Burkle
Address unknown at this time
Telephone number unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein’s sexual trafficking
conduct.
12. Dana Burns
Address…
giuffre-maxwell
gov.uscourts.nysd.447706.75.0
31 pg
…6
B. Plaintiff has failed to execute the Discovery Reponses. ................................................... 8
C. Plaintiff improperly refuses to disclose her address under Local Rule 26.1 ...................... 8
VI. PLAINTIFF’S SUBSTANTIVE OBJECTIONS ARE UNRECOGNIZED AND
MERITLESS .............................…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date: 06/15/2016
CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is not intended
to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…to
respond to this subpoena and the potential consequences of not doing so.
Date: 05/13/20111
CLERK OF COURT
OR
Signature of Clel'k or Dep/ity CIeri…
giuffre-maxwell
1320-32
27 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is not intended
to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…includes, without limitation, correspondence, memoranda, notes,
notations, diaries, papers, books, accounts, newspaper and magazine articles, advertisements,
1
Case 1:15-cv-07433-LAP Document 1219-29 Filed 07/15/21 Page 6 of 24
photographs, videos, notebooks, ledgers, letters…
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