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.447706.79.1
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.447706.30.0
3 pg
…because they did not “lead to an inference that Plaintiff
is a ‘liar and an extortionist.’” In vivid contrast, Maxwell called Ms. Giuffre’s assertions of
sexual abuse “obvious lies.” It is axiomatic that a person telling “obvious lies” is…
giuffre-maxwell
gov.uscourts.nysd.447706.689.0
42 pg
…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 Can Be Called as Witnesse…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…Jeffrey
multiple times per day?
A. No. As when I was finished another girl was called by Ghislaine (Defendant). And
when they had finished another girl was called.
Q. How do you know that another girl was called by Ghislaine?
…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…In that correspondence, Defendant’s counsel gave specific
reasons for the objection to a number of the terms that were problematic in that they called for
the search of common words, names or phrases that would likely result pulling documents…
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.447706.1330.22
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.447706.1219.35
5 pg
…and also, there was a system at
13 the house, that it was MindSpring, MindSpring I
14 think it's called, that it was like a message system
15 that would come from the office.
16 Q. What is MindSpring?…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.16
2 pg
…designated as
“confidential” under the Protective Order in this case. Accordingly, in the June 2017 Letter,
Intervenor called upon the Court, in the event of an unsealing order, to permit the release of
certain emails to avoid a situation where…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…as a possible piece f,
her renowned Page Six column. It's called 'pure favor time' to Emily from the owner of the item, plus the press person wh
may or may not elect to pop it into print.
I…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.24
6 pg
…and also, there was a system at
13 the house, that it was MindSpring, MindSpring I
14 think it's called, that it was like a message system
15 that would come from the office.
16 Q. What is MindSpring?…
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.447706.1202.1_1
11 pg
…In that correspondence, Defendant’s counsel gave specific
reasons for the objection to a number of the terms that were problematic in that they called for
the search of common words, names or phrases that would likely result pulling documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
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.447706.1320.13
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.447706.1330.13
5 pg
…and also, there was a system at
13 the house, that it was MindSpring, MindSpring I
14 think it's called, that it was like a message system
15 that would come from the office.
16 Q. What is MindSpring?…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.18
6 pg
…and also, there was a system at
13 the house, that it was MindSpring, MindSpring I
14 think it's called, that it was like a message system
15 that would come from the office.
16 Q. What is MindSpring?…
giuffre-maxwell
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…
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