giuffre-maxwell
gov.uscourts.nysd.447706.79.5
2 pg
…Flexner, LLP, counsel for Virginia Giuffre
Stephen Zach, Esq. - Boies Schiller & Flexner, LLP, for Virginia Giuffre
Erika Perez - Boies Schiller & Flexner, LLP, legal assistant
Megan Hirsh - Boies Schiller & Flexner, LLP, legal intern
Brad Edwards, Esq. - Farmer, Jaffe, Weissing, Edwards, Fistos…
giuffre-maxwell
gov.uscourts.nysd.447706.156.6
3 pg
…Edwards, AC Privilege and
McCawley and legal assistant re seeking Work Product/joint
5/4/2015 information to assist in providing legal advice, with defense…
giuffre-maxwell
gov.uscourts.nysd.447706.363.14
2 pg
…the judges signature, along
with sufficient copies, self addressed, self stamped envelopes for all parties.
These orders cannot be submitted through the order portal.
Respectfully,
Susan Moss
Judicial Assistant to Judge Thomas M. Lynch, IV
201 S.E. 6th Street…
giuffre-maxwell
gov.uscourts.nysd.447706.103.2
3 pg
…telephone conversation to have any broader
or different meaning, I apologize for the misunderstanding.
Sincerely yours,
Wifredo A. Ferrer
United States Attorney
…
giuffre-maxwell
gov.uscourts.nysd.447706.156.3
9 pg
…Work Product/joint
4/10/2015 tice.com,eperez@BSFL Edwards, Pottinger and legal assistant re legal defense/common
58 17:31 Sigrid McCawley [email protected] LP.com documents, with attachments interest Withheld …
giuffre-maxwell
gov.uscourts.nysd.447706.93.0
2 pg
…First Set of Discovery Requests to Plaintiff.
2. On April 5, 2016, I spoke by telephone with Assistant United States Attorney
Marie Villafana, counsel of record in Jane Doe #1 and Jane Doe #2 v. United States, #08-
80736-CIV…
giuffre-maxwell
gov.uscourts.nysd.447706.94.0
2 pg
…First Set of Discovery Requests to Plaintiff.
2. On April 5, 2016, I spoke by telephone with Assistant United States Attorney
Marie Villafana, counsel of record in Jane Doe #1 and Jane Doe #2 v. United States, #08-
80736-CIV…
giuffre-maxwell
gov.uscourts.nysd.447706.156.7
6 pg
…Ellen Brockman, Scarola, Stan Pottinger, related to the CVRA case, communications sending docs
other Legal Assistants, Ellen Brockman, Legal or attaching attorney work product related to the over…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…to testify, by contrast to every other
witness ever identified, that 1) Ms. Maxwell was actively involved as an assistant to Mr. Epstein
in late 2006 to early 2007, and 2) that she was “lent out” to other people, including…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…14
case 1:1!:l-CV-Uf4;J;J-RWS Document 161-1 Filed 05/25116 Page 14 of 40
Jeffrey Epstein
including but not limited to, work as an assistant, a massage therapist, sex worker, or companion.
20. AI1…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…2011, Ms. Giuffre was interviewed by FBI
Special Agents—along with a telephonically present Assistant United States Attorney—at the
United States Consulate in Sydney, Australia, as part of an ongoing investigation into Jeffrey
Epstein sexual abuse and sex trafficking…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…to testify, by contrast to every other
witness ever identified, that 1) Ms. Maxwell was actively involved as an assistant to Mr. Epstein
in late 2006 to early 2007, and 2) that she was “lent out” to other people, including…
giuffre-maxwell
gov.uscourts.nysd.447706.542.8
4 pg
…Revenue Code, or the corresponding section of any future federal tax
code. The corporation is organized to provide assistance to victims of sexual abuse as well as victims of human trafficking.
Upon the dissolution of Victims Refuse Silence, Inc., assets…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…are false. Giuffre’s fantastical claims,
contained in news stories and press-releases masquerading as legal pleadings over the last five
years have been well-crafted with the assistance of high-priced attorneys to facilitate Giuffre’s
media exposure, to…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
….................................................. 58
3. The January 2015 statement accurately denied that “with [Ms. Maxwell’s]
assistance, [Epstein] converted [Plaintiff] into what is commonly referred
to as a ‘sex slave.’” ................…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.28
4 pg
…3241)
. Both of
those pharmacies likewise have release forms for their records.
. If you need assistance
locating those release forms, please let me know.
Also please consider this…
giuffre-maxwell
gov.uscourts.nysd.447706.1231.0
3 pg
…August 27, 2020:
The Court’s staff will receive Non-Party submissions, make appropriate redactions,
e.g., the Non-Party’s identifying information (with the assistance of the Original
Parties, as appropriate), substitute Non-Party pseudonymous identifiers as
appropriate, redact…
giuffre-maxwell
gov.uscourts.nysd.447706.538.0
10 pg
….................................................. 58
3. The January 2015 statement accurately denied that “with [Ms. Maxwell’s]
assistance, [Epstein] converted [Plaintiff] into what is commonly referred
to as a ‘sex slave.’” ................…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…Court’s staff will receive Non-Party submissions, make appropriate
redactions, e.g., the Non-Party’s identifying information (with the assistance of the
Original Parties, as appropriate), substitute Non-Party pseudonymous identifiers as
appropriate, redact the submission as appropriate…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…please use a reasonable, good-faith syntax to capture communications with
those individuals -- Sometimes that takes some trial-and-error – I’m happy to
be of any assistance with regard to that process. Please let me know what your syntax…
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