giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…Epstein Estate.
BACKGOUND
Under Virgin Islands law, the CICO authorizes the USVI through its Attorney General to
prosecute a civil action against any persons engaged in a pattern of criminal activity through
association with any enterprise. 14 V.I.C…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…C) Payment of Expenses. Instead of or in addition to the orders above, the
court must order the disobedient party, the attorney advising that party, or both to
pay the reasonable expenses, including attorney's fees, caused by the failure…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…C) Payment of Expenses. Instead of or in addition to the orders above, the
court must order the disobedient party, the attorney advising that party, or both to
pay the reasonable expenses, including attorney's fees, caused by the failure…
giuffre-maxwell
1320-33
24 pg
…C) Payment of Expenses. Instead of or in addition to the orders above, the
court must order the disobedient party, the attorney advising that party, or both to
pay the reasonable expenses, including attorney's fees, caused by the failure…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…C) Payment of Expenses. Instead of or in addition to the orders above, the
court must order the disobedient party, the attorney advising that party, or both to
pay the reasonable expenses, including attorney's fees, caused by the failure…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…After extensive discussion and
coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality
agreement prepared by Maxwell’s attorney, at the eleventh hour Maxwell’s attorney informed
plaintiff’s counsel that Maxwell’s mother was…
giuffre-maxwell
gov.uscourts.nysd.447706.895.0
3 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.34
4 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
1320-34
4 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…Kellen be directed to appear for her deposition; (2) that Ms.
Kellen pay Ms. Giuffre’s costs and reasonable attorney’s fees associated with bringing this
motion; (3) that Ms. Kellen be ordered to pay a civil penalty of $2500…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…Mr. Gee’s letter said that such a search
term was inappropriate because it was “guaranteed” to generate “thousands of hits”:
3
Having represented that running Ms. Giuffre’s that name was an “extraordinary and
unreasonable” task “guaranteed to…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…by the
police from Epstein’s home, and turned over to the Palm Beach County State Attorney as part of
-
the investigation and prosecution of Epstein.
M Ghislaine Maxwell
See (DE 280-2), Palm Beach County State Attorney’s Office…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…Mr. Gee’s letter said that such a search
term was inappropriate because it was “guaranteed” to generate “thousands of hits”:
3
Having represented that running Ms. Giuffre’s that name was an “extraordinary and
unreasonable” task “guaranteed to…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…Gee’s letter said that such a search
term was inappropriate because it was “guaranteed” to generate “thousands of hits”:
3
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 4 of 21
In…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…whether
Ms. Giuffre was telling the truth about Ms. Maxwell’s involvement in sex trafficking, but
whether attorneys representing her in a separate case had filed allegation on her behalf
concerning Alan Dershowitz with due diligence. Under Fed. R. Civ…
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