giuffre-maxwell
gov.uscourts.nysd.447706.685.0
6 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S MOTION IN LIMINE TO PRECLUDE DEFENDANT FROM CALLING
PLAINTIFF’S ATTORNEYS AS WITNESSES AT TRIAL
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…BYLINE: Alisyn Camerota, Martin Savidge, John Berman, Michaela Pereira, Paul
Callan, Chris Cuomo, Ana Cabrera
GUESTS: Wendy Murphy
HIGHLIGHT:
Friday night, seven-year-old Sailor Gutzler freed herself from the upside down
wreckage of her family's plane, moving past…
giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
…20
21
22
23
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 634 Filed 02/17/17 Page 2 of 15 2
H221giua
1 (Case called)
2 MS. McCAWLEY: Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.689.0
42 pg
…6
A. Controlling Second Circuit Case Law from LiButti v. United States Permits
Calling a Witness for Purposes of Obtaining Adverse Inferences.......................... 7
B. Federal Law Rather than New York Law Controls the Evidentiary Issue of
Whether …
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.447706.35.1
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.447706.79.1
12 pg
…SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 79-1 Filed 04/04/16 Page 3 of 12
2
G3o5giuA phone conference
1 (Case called)
2 THE DEPU…
giuffre-maxwell
gov.uscourts.nysd.447706.82.0_2
11 pg
…SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 82 Filed 04/07/16 Page 2 of 11 2
G3o5giuA phone conference
1 (Case called)
2 THE DEPUTY CLERK: Counsel, can you please…
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.447706.1296.10
469 pg
…Maxwell, who is
20 appearing by telephone.
21 SARAH RANSOME, having been
22 called as a witness, having first
23 been duly sworn by a Notary
24 Public (Jeremy Richman) of the
25 State of New York, was examined
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.35
5 pg
… No, sir.
5 Q. So when there would be a message from one
6 of them while they were out of town, they would call
7 you, call you on the telephone?
8 A. I haven't spoken to Ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…it is Mr. Epstein’s intention, if
he is called as a witness at the trial of this case, to once again assert his Fifth Amendment privilege
1
Mr. Epstein agreed to have his attorney accept service of the subpoena…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…that has yielded not so much as a single
goose feather. It is time to call off the hunt.
Submission Concerning Search Terms
The Requests for Production
Ms. Maxwell served Responses and Objections to Plaintiff’s First Discovery Requests on…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.11
51 pg
…2 Jane Doe 2
PHONE-,AA=EA,.,..COO!:i=
EXTENSION
TELEPHONED …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.24
6 pg
… No, sir.
5 Q. So when there would be a message from one
6 of them while they were out of town, they would call
7 you, call you on the telephone?
8 A. I haven't spoken to Ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…East side of the house. In the
Northeast bedroom closet I found adult sex toys called Twin Torpedoes.
Soap made in the shape of a penis and vagina were also found in these
upstair bedrooms . See the property receipt for…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…should
not have to answer other of the subpoena requests nor answer deposition questions which are
designed to lead to admissible evidence and which, concededly, do not call for privileged
answers. The Opposition, long on screenshots of photos and documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
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.447706.1320.13
45 pg
…East side of the house. In the
Northeast bedroom closet I found adult sex toys called Twin Torpedoes.
Soap made in the shape of a penis and vagina were also found in these
upstair bedrooms . See the property receipt for…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…should
not have to answer other of the subpoena requests nor answer deposition questions which are
designed to lead to admissible evidence and which, concededly, do not call for privileged
answers. The Opposition, long on screenshots of photos and documents…