giuffre-maxwell
gov.uscourts.nysd.447706.1219.28
3 pg
…November 12, 2015.
And call me if you have any questions.
Regards,
Barry Meier
--
The New York Times
620 Eighth Avenue
New York, NY 10018
212-556-1917
1
CONFIDENTIAL GM_01141
Case 1:15-cv-07433-LAP Document 1219…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.33
3 pg
…November 12, 2015.
And call me if you have any questions.
Regards,
Barry Meier
--
The New York Times
620 Eighth Avenue
New York, NY 10018
Jane Doe 2
1
CONFIDENTIAL GM_01141
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.27
3 pg
…November 12, 2015.
And call me if you have any questions.
Regards,
Barry Meier
--
The New York Times
620 Eighth Avenue
New York, NY 10018
212-556-1917
Jane Doe 2
1
CONFIDENTIAL GM_01141
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.13
3 pg
…November 12, 2015.
And call me if you have any questions.
Regards,
Barry Meier
--
The New York Times
620 Eighth Avenue
New York, NY 10018
212-556-1917
1
CONFIDENTIAL GM_01141
Case 1:15-cv-07433-LAP Document 1219…
giuffre-maxwell
gov.uscourts.nysd.447706.1061.0
2 pg
…in for that conference is (888) 363-4734, access
code: 4645450. The parties are directed to call in promptly at
2:00 p.m.
SO ORDERED.
Dated: New York, New York
June 19, 2020
1 With respect to Giuffre v…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…The objections and responses to the RFPs are proper. ................................................ 1
A. RFP No. 1: Documents defense counsel “reviewed and/or relied upon” in a phone
call with Plaintiff’s counsel. ...................................................................................... 1
B. RFP N…
giuffre-maxwell
gov.uscourts.nysd.447706.587.0_2
10 pg
…15-cv-07433-LAP Document 587 Filed 02/02/17 Page 2 of 10 2
H1j6giua
1 (In open court; case called)
2 THE COURT: Please be seated.
3 I will hear from the movant.
4 MR. PAGLIUCA: Good afternoon…
giuffre-maxwell
gov.uscourts.nysd.447706.103.2
3 pg
…Ghislaine Maxwell
Dear Ms. Menninger:
I am in receipt of your letter of April 6, 2016, where you have attempted to memorialize a
telephone conversation in which you called me concerning Giuffre v. Maxwell, Case No. 15-cv-
07433-RWS…
giuffre-maxwell
gov.uscourts.nysd.447706.35.1
4 pg
…Response:
Maxwell objects to this Request on the grounds that it is overly broad and unduly
burdensome and calls for the production of documents that are irrelevant to this action and not
reasonably calculated to lead to the discovery of…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…“But it’s unlikely that he would ever be called” to appear at trial,
especially now that he’s assumed the presidency.
President Trump and Jeffrey Epstein
Scarola said Trump is one of a number of high-profile individuals whose…
giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…aware, Ms. Giuffre has alleged that Defendant defamed her when she
called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of
Defendant and Defendant’s long-time boyfriend, convicted…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 132-1 Filed 05/01/16 Page 3 of 31
2
G4LMGIUC
1 (Case called)
2 THE COURT: Welcome …
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…first
and surnames.1
By correspondence of July 14, Ms. Maxwell’s counsel specifically identified the
problematic terms, agreed to a limited list, and requested a substantive conferral call on this
issue. See Menninger Decl., Ex. B. In that correspondence…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…Protective Order (DE 62)
Ms. Giuffre objects to the requests to the extent Defendant’s Second Set of Discovery
Requests call for the production of documents or information that is already in the possession,
custody, or control of the Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
… Regardless, Philip plse call
jeffrey lawyer and see what you can under.stand from him and pehaps craft something in conjunction with
him? Either way I think you need to speak to him to understand my risk so you can…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…5 has to be a significant meeting; it can't be just one
6 ten-minute telephone call.
7 So that's how I feel about the meet and confer.
8 Now, I'm not going to get into whether…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…He has rightly called YR bluff and shouted his innocence.
You have to stand up and deny the allegations or be branded guilty by association and that may lead to other
investigations and worse.
I feel I am going around…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.15
5 pg
…Specifically, I stated “I am available by telephone today and tomorrow to discuss
the issues raised herein.” Despite this clear request for a call if there were issues you wished to discuss, or if you had
specific RFP’s to…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 276 Filed 07/13/16 Page 2 of 35 2
G6ndgium
1 (Case called)
2 THE COURT: Extending discovery.
3 MS. McCAWLEY: Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.1_1
7 pg
…people
11 constantly, told to -- my whole life revolved around
12 just pleasing these men and keeping Ghislaine and
13 Jeffrey happy. Their whole entire lives revolved
14 around sex.
15 They call massages sex. They call
16 modeling sex. …