giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…particular materials under
the protective order are not mooted by the settlement of the underlying action. See Gambale v. Deutsche Bank AG,
377 F.3d 133, 140-41 (2d Cir. 2004).
Case 1:15-cv-07433-LAP Document 1332…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…2016, the New York Post reported that
2
As recently as 2005, Defendant was on Epstein’s Palm Beach House bank account for Palm
Beach. Bates Number SAO FOIA disc 7 (bates Giuffre 007590) at p. 93-95.
2
…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…ONE BOX ONLY> NATURE OF SUIT
TORTS ACTIONS UN DER ST ATU TES
CONTRACT PER SONALINJU RV PERSONALINJURY FORF£1TVRE/ PENALTY
giuffre-maxwell
gov.uscourts.nysd.447706.1327.3
16 pg
…Filed 01/05/24 Page 7 of 16
MAIL & DELIVERY SERVICES
FedEx 1-800-463-3339 Account No: -
Drop-off box is next to Palm Beach National
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
… 24 A Firth .
25 A Fifth. 25 Q Do you haven bank account at Chase Bnnk
16 ( Pa ge s 58 t o 61)
U.S. Legal Suppor…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…financial information contained in the other 21 discovery requests seeking,
for example, all of tax returns, bank statements, and every other conceivable piece of financial
information, none of which has any relevance to the claims or defenses in this matter…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…communications with her, or any other documents
withheld as privileged.
The cases cited by Plaintiff do not support her position. For example, Wells Fargo Bank,
N.A. has nothing to do with privilege logs and, in fact, holds to the…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…2000 WL 310345 (S.D.N.Y. Mar. 27, 2000) ............................................................................ 22
Upjohn Co. v. United States,
449 U.S. 383 (1981).................................................................................................................. 22
Wells Fargo Bank, N.A. v. Konover,
2009 WL 58…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…communications with her, or any other documents
withheld as privileged.
The cases cited by Plaintiff do not support her position. For example, Wells Fargo Bank,
N.A. has nothing to do with privilege logs and, in fact, holds to the…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…recent paycheck, paycheck stub, earnings statement and any bank
statement, credit card statement and any Document reflecting any money owed by You to
anyone.
7
The remaining document requests are specifically targeted to obtain impeachment
evidence concerning Ms. Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…'face an "X" in One Hox Only)
CONTRACT TORl S FORFEI fURE/PE'.N -1.LT\' BANKR\IPTC\' OTHER STATUTES
D 110 Insurance PERSONAL INJURY PERSONAL INJURY D 625 Drug Rel…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…25
Produce all bank statements or other financial statements which were prepared by You,
on Your behalf or by or on behalf of any entity in which You held an ownership interest of 10%
or more at any time from…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…2000 WL 310345 (S.D.N.Y. Mar. 27, 2000) ............................................................................ 22
Upjohn Co. v. United States,
449 U.S. 383 (1981).................................................................................................................. 22
Wells Fargo Bank, N.A. v. Konover,
2009 WL 58…
giuffre-maxwell
gov.uscourts.nysd.447706.903.0
46 pg
…high school student as part of
15 this massage recruiting scheme. He testified that Maxwell was
16 on a bank account for the Palm Beach house at the time he was,
17 they were jointly able to write checks, etc.…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…paycheck stub, earnings statement and any bank
statement, credit card statement and any Document reflecting any money owed by You to
anyone.
7
Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 10 of…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…A & M
Florida Properties II, LLC, No. 09-15173 (AJG), 2010 WL 1418861, at *6 (Bankr. S.D.N.Y. Apr. 7, 2010)
(declining to impose adverse inference instruction where documents were belatedly produced, but there was no bad
faith…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…on squad! Single mother-
of-two Halle Berry, 49,
the banker's private Caribbean island during her years of work. goes makeup-free and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…family that I send
drafts to is Jeffrey.”5 Dershowitz has also been quoted as saying that, even if Epstein went
bankrupt, “I would be as interested in him as a friend if we had hamburgers on the boardwalk in…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…family that I send
drafts to is Jeffrey.”5 Dershowitz has also been quoted as saying that, even if Epstein went
bankrupt, “I would be as interested in him as a friend if we had hamburgers on the boardwalk in…