giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…and later worked
with the FBI to provide information, she is likely the person who has the photo, or knows the
chain of custody of the picture. Either way, information including the date and location where
the picture was taken…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…22 MS. McCAWLEY: Sure. Right.
23 We're not talking about cocaine being transported
24 where you would have a concern over the chain of custody and it
25 being what it is. It's the telephone directory. There's…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…and has produced medical
provider records that were in the custody of third-parties. Ms. Giuffre has maintained an ongoing
search and effort to find any responsive document that may exist, in satisfaction of her discovery
obligations.
Despite all this…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…
4) Produce all documents requested in RFP’s 1-37 that are within her possession, custody or
control, or that of her attorneys, after a reasonable and diligent inquiry and search.
Defendant further requests the Court to 1) enter an…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…decision that Maxwell finally broke down.
She began moving uneasily in her chair as the judge said the evidence against her was
‘strong’.
When Judge Nathan said a ‘combination of factors’ showed she had the ‘motive and
opportunity’ to flee…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…use the
privileged information in order to establish its claim or
defense ." ) with Chin v. Rogoff & Co. , P.C ., No. 05 CIV.
15
Case 1:15-cv-07433-LAP Document 1201-20 Filed 01/27/21 Page 17 of 21
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.9
21 pg
…information in order to establish its claim or
defense.") with Chin v. Rogoff & Co., P.C., No. 05 CIV.
15
----------~-------
Case 1:15-cv-07433-LAP Document 1327-9 Filed 01/05/24 Page 17 of 21
•
'
IX…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.9
21 pg
…privileged information in order to establish its claim or
defense.") with Chin v. Rogoff & Co., P.C., No. 05 CIV.
15
Case 1:15-cv-07433-LAP Document 1328-9 Filed 01/05/24 Page 17 of 21
IX …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.10
23 pg
…happy to give you a break at a fixed
20 time. What I ' m not happy to do is
21 interrupt a chain of examination .
22 So if you want a break now , we will
23 take a break now…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…is something I must do to break a large chain of se rial sex abuse happening for too long now.
anc
We have spoken in great deal about what kind of piece yon would like to present to the NYC…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.10
23 pg
…to give you a break at a fixed
20 time. What I 1 m not happy to do is
21 interrupt a chain of examination .
22 So if you want a break now , we will
23 take a break now…
giuffre-maxwell
gov.uscourts.nysd.447706.903.0
46 pg
…of 46 22
H45AGIU1ps
1 young girls then brought Alex Hall to the house. So there is a
2 chain of events directly linked to the defendant in this case.
3 Her testimony, they're trying to get rid of…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…the premise that Ms.
Giuffre violated a duty to preserve evidence that arose in a different case. The attenuated chain
of reasoning is that Ms. Giuffre’s duty to preserve this journal with respect to this case arose in
2013…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…consider this chain of causation – that is
a matter for the inquiry.
5. However, the claimants also now rely on earlier matters. The claimants seek to establish
an earlier breach. I have already referred to a reduction of price at…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.11
18 pg
…EDWARDS:
19 Q. Did you ever trace all the way up to the
20 highest level to determine who was it that started
21 this particular chain of Palm Beach girls coming
22 over to Jeffrey Epstein's home?
23 …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.25
4 pg
…10
13· · · · A.· ·I did. 09:20:13
14· · · · Q.· ·And did you receive from Ms. Maxwell, the 09:20:14
15· ·bottom email of that chain? 09:20:16
16· · · · A.· ·I believe so.· Well, I believe -- yes, yeah…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…from, if you look at the chain at the top, you will see it's from
you to Jeffrey on January 27 and the email at the bottom of the chain is from
Jeffrey to you on January 27. He…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.19
15 pg
…if you look
15 at the chain at the top, you will see it's
16 from you to Jeffrey on January 27 and the
17 email at the bottom of the chain is from
18 Jeffrey to you on…
giuffre-maxwell
gov.uscourts.nysd.447706.156.6
3 pg
…156-6 Filed 05/20/16 Page 2 of 3
Pre‐Existing Factual Documents
Log Email Sent Privilege Page Doc
ID Date Email…
giuffre-maxwell
gov.uscourts.nysd.447706.156.1
26 pg
…joint
[email protected],robiej defense/commo
2 2/16/2015 1:05 [email protected] [email protected] Discussion of evidence among clien…