giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…ARGUMENT ................................................................................................................................ 12
I. Ms. Maxwell is not liable for republications of her January 2015 statement that she did not
authorize or request and by entities she did not control. ................................…
giuffre-maxwell
gov.uscourts.nysd.447706.56.0
14 pg
…Lauderdale, FL 33301
(954) 356-0011
Ellen Brockman
Boies, Schiller & Flexner LLP
575 Lexington Ave
New York, New York 10022
…
giuffre-maxwell
gov.uscourts.nysd.447706.70.0
15 pg
…Lauderdale, FL 33301
(954) 356-0011
Ellen Brockman
Boies, Schiller & Flexner LLP
575 Lexington Ave
New York, New York 10022
…
giuffre-maxwell
gov.uscourts.nysd.447706.1024.0
7 pg
…MAKES CLEAR THAT UNDECIDED MOTIONS ARE
JUDICIAL RECORDS. ..........................................................................................................1
CONCLUSION ................................................................................................................................4
…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.1
55 pg
…Government of the Virgin Islands, pursuant
to 3 V.I.C. § 114 and her statutory authorityto enforce the laws ofthe Virgin Islands, and advocate
for the public interest, safety, healthand well-being of persons in the Virgin Islands.
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.33
3 pg
…Wales with company number OC397401 at the address below. This Firm
is authorised and regulated by the Solicitors Regulation Authority under the name of Devonshires Solicitors LLP and registration number 619881. This Firm does not accept
service by electronic mail…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.27
3 pg
…Wales with company number OC397401 at the address below. This Firm
is authorised and regulated by the Solicitors Regulation Authority under the name of Devonshires Solicitors LLP and registration number 619881. This Firm does not accept
service by electronic mail…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…Wales with company number OC397401 at the address below. This Firm
is authorised and regulated by the Solicitors Regulation Authority under the name of Devonshires Solicitors LLP and registration number 619881. This Firm does not accept
service by electronic mail…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…I. PRELIMINARY STATEMENT
It is undisputed that Mr. Gow is a key witness in this case, given that he was authorized by
the Defendant to release the defamatory statements, that are central to this case to the media.
Defendant, however…
giuffre-maxwell
gov.uscourts.nysd.447706.223.6
4 pg
…McCawley; Martin Weinberg
Subject: SERVICE - Epstein Deposition
Sigrid, I am authorized to accept service conditioned on the deposition being
located near Mr. Epstein's Virgin Island residence which you indicated in
your email of May 25 was acceptable to you…
giuffre-maxwell
gov.uscourts.nysd.447706.121.0
10 pg
…26, and in addition to case
law from the this Court and others courts within the Southern District of New York, various
other instructive authorities emphasize the need for disclosure and agreement concerning ESI
preservation, collection, and production protocols among…
giuffre-maxwell
gov.uscourts.nysd.447706.229.6
24 pg
…NY 10022
The videotaped deposition will be taken upon oral examination before Magna Legal
Services, or any other notary public authorized by law to take depositions. The oral examination
will continue from day to day until completed.
The video operator…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.19
22 pg
…composite Exhibit 2 has both a
19 motion and a corrected motion.
20 Do you see that?
21 A Yes.
22 Q And were both of those pleadings
23 authorized by you to be filed?
24 A Yes.
25 Q …
giuffre-maxwell
1320-19
22 pg
…composite Exhibit 2 has both a
19 motion and a corrected motion.
20 Do you see that?
21 A Yes.
22 Q And were both of those pleadings
23 authorized by you to be filed?
24 A Yes.
25 Q …
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…MS. MAXWELL’S OBJECTIONS IS APPROPRIATE ..................................... 6
IV. PLAINTIFF’S FAILURE TO CONFER WITH MS. MAXWELL PRIOR TO FILING
HER MOTIONS TO COMPEL IS DISPOSITIVE ............................................................. 13
ii
…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.13_1
23 pg
…Exhibit 2 has both a
19 motion and a corrected motion.
20 Do you see that?
21 A Yes.
22 Q And were both of those pleadings
23 authorized by you to be filed?
24 A Yes.
25 Q In…
giuffre-maxwell
gov.uscourts.nysd.447706.751.9
3 pg
…and want authorities to reconsider a
plea deal that allowed Epstein to avoid much more serious federal charges and potentially longer prison time.
Epstein served 13 months of an 18-month sentence after pleading guilty to a single charge of…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…has been produced. As to other investigations by law
enforcement, Ms. Giuffre objects as this seeks information covered by the investigative
privilege.
5. Identify each Communication that You or Your Attorneys have had with any
author, reporter, correspondent, columnist, writer…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…17, 2011. Ms.
Giuffre also corresponded with Maria Villafano from the U.S. Attorney’s office and that
correspondence has been produced.
5. Identify each Communication that You or Your Attorneys have had with any
author, reporter, correspondent, columnist, writer…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…in any way. Statements or opinions in
this e-mail or any attachment are those of the author and are not
necessarily agreed or authorised by News Corp UK & Ireland Limited
or any member of its group. News Corp UK…