giuffre-maxwell
gov.uscourts.nysd.447706.684.0
3 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF
PLAINTIFF’S MOTION IN LIMINE TO ADMIT THE “BLACK BOOK” AS
…
giuffre-maxwell
gov.uscourts.nysd.447706.716.0
8 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S
MOTION TO EXCLUDE THE “BLACK BOOK”
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…!! (I have lived all over the world some I have quite
a big little black book of my own!
I have also emailed Wiki Leaks and Anonymous, because my voice will be heard if it's the last
thing I…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
… Brad Edwards; Paul Cassell ([email protected])
Subject: RE: Conferral regarding forensic search
Follow Up Flag: Follow Up
Flag Status: Flagged
Laura,
Please see my additions in-line, in black, below to your email sent yesterday. My in-line…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…quarters. We started in the
garage . All areas of the garage were searched to include four
vehicles . These vehicles were three black Mercedes Benz cars
registered to Jeffrey Epstein. The fourth vehicle was a Harley
Davidson motorcycle, green in color…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…quarters. We started in the
garage . All areas of the garage were searched to include four
vehicles . These vehicles were three black Mercedes Benz cars
registered to Jeffrey Epstein. The fourth vehicle was a Harley
Davidson motorcycle, green in color…
giuffre-maxwell
1320-13
45 pg
…quarters. We started in the
garage . All areas of the garage were searched to include four
vehicles . These vehicles were three black Mercedes Benz cars
registered to Jeffrey Epstein. The fourth vehicle was a Harley
Davidson motorcycle, green in color…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…for Sunday MaiL She
mentioned to me that you roduce miniseries back in N,Y and thought it would be a great idea to contact you to talk: abou
"Tlie Billionaires Playboy Club" a book tliat I am currently writing…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…misconduct lodged and repeated by Ms.
Giuffre are nothing more than a recent fabrication— a made up story designed to increase
commercial interest in Ms. Giuffre’s book manuscript, and promote its sale to a publisher and
eventually to readers…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…2
I. CHURCHER IS A MATERIAL FACT WITNESS AND WAS NOT ACTING AS A
JOURNALIST ..................................................................................................................... 2
A. Churcher was acting as a friend and advisor to help Plaintiff publish her book, not as
journalist…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.34
10 pg
…start to worry. Also I really do need a flight booked back to New
York preferably the 27th as it is high season here and there might not be any avalable flights at
the end or the month. can you…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…Barden
Date: Sat, 10 Jan 2015 18:27:12 +0000
To: G Maxwell
Cc: Ross Go
Subject: Re:
All
I am back on line now.
I see the statement didn't go. Monday…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…I certainly do feel that down the long, winding road, your case has merit! God willing that it puts that piece of human scurr
back behind bars! Should you win the day, yes, T do believe that you can create…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…appointment books, lists, tabulations, sound
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries,
computer printouts, computer programs, text messages, e-mails, information kept in computer
hard drives, other computer drives of any kind, computer tape back-up…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…appointment books, lists, tabulations, sound
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries,
computer printouts, computer programs, text messages, e-mails, information kept in computer
hard drives, other computer drives of any kind, computer tape back-up…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
… No. No.
25 Q. All right. So have you had
Highly Confidential
Page 36
1 HIGHLY CONFIDENTIAL AEO
2 any agreements regarding writing a
3 book --
4 A. No.
5 Q. -- about your experience?
6 …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…you had
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 37 of 469
Highly Confidential
Page 36
1 HIGHLY CONFIDENTIAL AEO
2 any agreements regarding writing a
3 b…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…on her deposition testimony, sometime in October of 2016, Ms. Ransome read an article in
the New York Post written by Maureen Callahan regarding a recently published book by James
Patterson concerning Jeffrey Epstein. See Menninger Decl. Ex. A (Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.79.1
12 pg
… We agreed to that as
15 the date so let me back up.
16 I think everyone recognized that we would not be able
17 to be there today given the airport situation here and the
18 backlog of flights…
giuffre-maxwell
gov.uscourts.nysd.447706.82.0_2
11 pg
… We agreed to that as
15 the date so let me back up.
16 I think everyone recognized that we would not be able
17 to be there today given the airport situation here and the
18 backlog of flights…
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