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 Terramar – You have withdrawn…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.447706.239.1
11 pg
…nor June 28 is an available date.
Regards,
Greg Poe
Please note: As of June 1,2016, my email address has changed to
[email protected]. Please update your address book accordingly.
Gregory L. Poe
LAW OFFICES OF GREGORY L…
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.447706.1330.22
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.447706.1332.1
42 pg
…of
the account for her own 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…of
the account for her own 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…
giuffre-maxwell
gov.uscourts.nysd.447706.684.0
3 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF
PLAINTIFF’S MOTION IN LIMINE TO ADMIT THE “BLACK BOOK” AS
EVIDENCE AT …
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.447706.716.0
8 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S
MOTION TO EXCLUDE THE “BLACK BOOK”
…
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.447706.71.6
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.447706.1325.2
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.447706.1219.29
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…Emma Ashley Ransome.
10 Q. And what is your birth date?
11 A.
12 Q. And what is your current
13 address?
14 MR. GUIRGUIS: I'm going to
15 object to current address.
16 Q. You can answer.
17…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…is your birth date?
11 A. 13th of the 8th, 1984.
12 Q. And what is your current
13 address?
14 MR. GUIRGUIS: I'm going to
15 object to current address.
16 Q. You can answer.
17 MR. GUIRGUIS: …
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…on her deposition testimony, sometime in October of 2016, Ms. Ransome read an article in
the New York Post written by Maureen Callahan regarding a recently published book by James
Patterson concerning Jeffrey Epstein. See Menninger Decl. Ex. A (Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…on her deposition testimony, sometime in October of 2016, Ms. Ransome read an article in
the New York Post written by Maureen Callahan regarding a recently published book by James
Patterson concerning Jeffrey Epstein. See Menninger Decl. Ex. A (Ransome…
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