giuffre-maxwell
gov.uscourts.nysd.447706.1327.25
12 pg
…RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1317
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
Electronically signed by cynthia hopkins (601-051-976-2934)
Electroni…
giuffre-maxwell
gov.uscourts.nysd.447706.5.0
2 pg
…York 10065
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency…
giuffre-maxwell
gov.uscourts.nysd.447706.3.0
2 pg
…York 10065
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…publicly disclosed volumes of information related to her
allegations, to claim that letters or emails from her lawyers or other documents sent to any law
enforcement agency are protected by any privilege. Plaintiff lacks standing to raise the issue and
…
giuffre-maxwell
gov.uscourts.nysd.447706.8.0
2 pg
…York 10065
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
are the United States or a United States agency…
giuffre-maxwell
gov.uscourts.nysd.447706.235.2
4 pg
…May 3rd,
please provide the following documents on or before April 27th, 2016.
All documents withheld on the basis of the “public interest privilege,” other
than Plaintiff’s actual statements to any law enforcement agency, which are to
be…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Background ........................................................................................................................ 2
I. THE DOCUMENTS AT ISSUE ARE NOT CONFIDENTIAL............................................. 4
A. Plaintiff’s Police Records Are Publicly Available from Law Enforcement Agencies in
…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…21
3. All Documents containing communications with
Jason Richards.
4. All Docume nts containing communications with
law enforcement agency concerning Virginia
Roberts.
5. All Documents reflecting any payment of any
…
giuffre-maxwell
gov.uscourts.nysd.447706.440.1
21 pg
…containing communications with
All Documents
Richards.
Jason Richards.
4.
4. All Documents
Documents containing communications with
law enforcement agency concerning Virginia
Roberts.
…
giuffre-maxwell
gov.uscourts.nysd.447706.140.2
3 pg
…whether there’s a privilege in the first place. 12
Once the public interest privilege has been determined to be applicable to protect information in the possession of a
governmental agency, private litigant may obtain such information only if the…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…your Honor. She shouldn't need
18 to know what agency is investigating her in order to decide
19 whether or not she is going to be asserting her Fifth Amendment
20 privilege.
21 We do have with us, your…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege, work product privilege, joint defense/common interest privilege, agency
privilege, investigative privilege, spousal privilege, doctor/patient privilege, accountant/client
privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
…22 23 Notary Public, SlUl\l ofFlurida
23 Pr,ise Court Reporting Ser;,ices
2
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…including the transmission of any Document, that
You or Your Attorneys have had with any local, state or federal law enforcement agent or
agency, whether in the United States or any other country, whether in Your capacity as a
purported…
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…planes
19 but I can't testify to anything past 2002,
20 2003, what happened to his planes after that.
21 Q. Do you know what travel agency, if
22 any, Jeffrey would use when he would send
23 someone…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…attorney-client privilege, the attorney work product
18 privilege, the joint defense, interest privilege, the agency
19 privilege, the investigative privilege, the spousal privilege,
20 the accountant/client privilege, and any other applicable
21 privilege."
22 THE COURT: Hot dog. …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…disorders, sexually transmitted diseases, and
therapy records, and any prescriptions for any of the above categories.
25. Any Documents containing any Communications You have had with any law
enforcement agency.
26. Any Documents that reflect any criminal charges, tickets, summonses…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.13
9 pg
…for Mr. Epstein? 21 there were other interviewees,_you received a call and
22 A The agency called me that there is an 22 u were as
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…undue
harassment serving no admissible purpose.
25. Any Documents containing any Communications You have had with any law enforcement
agency.
RESPONSE:
21
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…including the transmission of any Document, that
You or Your Attorneys have had with any local, state or federal law enforcement agent or
agency, whether in the United States or any other country, whether in Your capacity as a
purported…
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