giuffre-maxwell
gov.uscourts.nysd.447706.223.2
7 pg
…Martin G. Weinberg, Esq.
20 Park Plaza
Suite 1000
Boston, MA 02116
(617) 227-3700 - Office
(617) 901-3472 - Cell
==================================This Electronic
Message contains information from the Law Office of Martin G.
Weinberg, P.C., and may be privileged. The…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…01/27/21 Page 3 of 30
TABLE OF AUTHORITIES
Page
Cases
Candelaria v. Erickson,
2006 WL 1636817 (S.D.N.Y. 2006) ..........................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…01/27/21 Page 3 of 30
TABLE OF AUTHORITIES
Page
Cases
Candelaria v. Erickson,
2006 WL 1636817 (S.D.N.Y. 2006) ..........................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…15 November?
16 MR. GUIRGUIS: Objection.
17 A. I can't remember.
18 Q. Was she speaking to you on
19 your cell phone or a landline?
20 A. Cell phone.
21 Q. A mobile number or a
22 landline?…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…or any related entity from 1996 - present.
15 . Al I telephone records associated with you, including cell phone records, from 1996
- present, that show any communications with either Jeffrey Epstein or Ghislaine Maxwell.
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…15 November?
16 MR. GUIRGUIS: Objection.
17 A. I can't remember.
18 Q. Was she speaking to you on
19 your cell phone or a landline?
20 A. Cell phone.
21 Q. A mobile number or a
22 landline?…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…telephone
number with Sarah, his assistant for future contact. •••provided
her cellular telephone number for future contact . was asked
if she was recently contacted about this investigation by anyone from
the Epstein organization . She replied she was called but it…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…attorney instructed her not to give her
“current address,” whether she “has any source of income,” “her family’s location, things of that
nature,” and her partner’s “cellphone number.” None of these questions call for privileged
information. Pottinger Dec…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…telephone
number with Sarah, his assistant for future contact. •••provided
her cellular telephone number for future contact . was asked
if she was recently contacted about this investigation by anyone from
the Epstein organization . She replied she was called but it…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…attorney instructed her not to give her
“current address,” whether she “has any source of income,” “her family’s location, things of that
nature,” and her partner’s “cellphone number.” None of these questions call for privileged
information. Pottinger Dec…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…we want more documents, we want things like
2 paycheck records. She testified she doesn't have them.
3 We want her boyfriend's cell phone number. Why do
4 they want her boyfriend's cell phone number? She is…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…any
related entity from 1999 – present.
DOCUMENT REQUEST NO. 21
All telephone records associated with you, including cell phone records from 1999 – present.
DOCUMENT REQUEST NO. 22
All documents relating to calendars, schedules or appointments for you from 1999 – present.
…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
…for all computers in operation
between 1999 – 2002,” (No. 16);
All telephone records associated with you, including cell phone records from
1999 – present.” (No. 21);
All documents relating to calendars, schedules or appointments for you from 1999
– present,” …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…Fifth.
8 THE WITNESS: Fifth. 8 Q. Did you tell the court that you accepted
9 BY MR. CASSELL: 9 responsibility for those crimes?
10 Q. What is your cell phone number, sir? 10 A. Fifth.
11 A. Fifth. …
giuffre-maxwell
1320-13
45 pg
…telephone
number with Sarah, his assistant for future contact. •••provided
her cellular telephone number for future contact . was asked
if she was recently contacted about this investigation by anyone from
the Epstein organization . She replied she was called but it…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…Fifth.
8 THE WITNESS: Fifth. 8 Q. Did you tell the court that you accepted
9 BY MR. CASSELL: 9 responsibility for those crimes?
10 Q. What is your cell phone number, sir? 10 A. Fifth.
11 A. Fifth. …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…15 November?
16 MR. GUIRGUIS: Objection.
17 A. I can't remember.
18 Q. Was she speaking to you on
19 your cell phone or a landline?
20 A. Cell phone.
21 Q. A mobile number or a
22 landline?…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…crime/maxwell-net-worth/
93 https://www.dailymail.co.uk/news/article-8884319/Ghislaine-Maxwell-two-cameras-trained-times-inside-cell-ensure-safety.html
94 https://www.kpcw.org/post/jeffrey-epstein-update-read-deposition-ghislaine-maxwell-fought-hide
95…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…Y. 2013)..................................... 49
Black v. Green Harbour Homeowners’ Ass’n, 798 N.Y.S.2d 753 (App. Div. 2005), ...... 34
Celle v. Filipino Reporter Enters. Inc., 209 F.3d 163, 176-77 (2d Cir. 2000) .................. 51
Celotex Corp. v. Catrett…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…of declarations or affidavits by you that relate in any way to Alan M.
Dershowitz and/or Jeffrey Epstein.
15. All documents relating to any telephone, including any cellular telephone, used by you
between January 1, 1999 and December 31…