giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
16
Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 18 of 48
Response to Interrogatory No. 10
Ms. Giuffre objects…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
16
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 18 of 48
Response to Interrogatory No. 10
Ms. Giuffre objects…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…the nature of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
Response to Interrogatory No. 10
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms.
Giuffre objects…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…whether a loan, investment proceeds, legal settlement, asset sale, gift, or
other source.
11. Identify any facts upon which You base Your contention that You have suffered
as a result of the Alleged Defamation by Ghislaine Maxwell “past and future…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…the nature of the Income, whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
Response to Interrogatory No. 10
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms.
Giuffre objects…
giuffre-maxwell
1320-37
48 pg
…whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
16
Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 18 of 48
Response to Interrogatory No. 10
Ms. Giuffre objects…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…whether a loan, investment proceeds, legal settlement, asset sale,
gift, or other source.
16
Case 1:15-cv-07433-LAP Document 235-3 Filed 06/21/16 Page 18 of 48
Response to Interrogatory No. 10
Ms. Giuffre objects…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…in this action. First and most
fundamentally, the Jane Doe 43 action seeks millions if not hundreds of millions worth of assets
as “civil forfeiture.” It appears (although Ms. Ransome refused to answer) that she is
unemployed, with no source…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…in this action. First and most
fundamentally, the Jane Doe 43 action seeks millions if not hundreds of millions worth of assets
as “civil forfeiture.” It appears (although Ms. Ransome refused to answer) that she is
unemployed, with no source…
giuffre-maxwell
gov.uscourts.nysd.447706.1003.0
1 pg
…in Giuffre v. Dershowitz,
19 Civ. 3377. As set forth in her earlier filings, Giuffre supports the unsealing of this case’s docket.
See Dkt. 995 at 7 (“[A]ll of the documents in question are judicial documents, and accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…friend and advisor to help Plaintiff publish her
book, not as journalist
As set out in Churcher’s Declaration, she first met with Plaintiff in early 2011 and
conducted a weeks-long series of extensive interviews in person with Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…worksheets, printed matter of every kind and description, graphic and oral records and
representations of any kind, and electronic "writings'' and ·'recordings" as set fo11h in the Federal
Rules of Evidence, including but not limited to, originals or copic;s…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…matter of every
kind and description, graphic and oral records and representations of any kind, and electronic
“writings” and “recordings” as set forth in the Federal Rules of Evidence, including but not
limited to, originals or copies where originals are…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…personal delivery or otherwise.
3. “Defendant” shall mean the defendant Ghislaine Maxwell and her employees,
representatives or agents.
4. “Document” incorporates the definition as set forth in Rule 26.3(c)(2), Southern
District of New York Local Rules, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…living with her
boyfriend. Nevertheless, Defendant insists on moving to compel highly personal financial
17
information from this non-party as set forth in Request 29: “A copy of your most recent
paycheck, paycheck stub, earnings statement and any bank…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…living with her
boyfriend. Nevertheless, Defendant insists on moving to compel highly personal financial
17
information from this non-party as set forth in Request 29: “A copy of your most recent
paycheck, paycheck stub, earnings statement and any bank…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…graphic and oral records and representations of any kind, and electronic
“writings” and “recordings” as set forth in the Federal Rules of Evidence, including but not
2
Case 1:15-cv-07433-RWS Document 17-1 Filed 12/01…
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