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.447706.78.0
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.447706.1078.5
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.447706.156.1
26 pg
…joint
[email protected],robiej defense/commo
2 2/16/2015 1:05 [email protected] [email protected] Discussion of evidence among clien…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.3
27 pg
…joint
[email protected],robie defense/commo
2 2/16/2015 1:05 [email protected] jJane Doe 2 Discussion of evidence among client an…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.15
27 pg
…joint
[email protected],robie defense/commo
2 2/16/2015 1:05 [email protected] [email protected] Discussion of evidence among client and …
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…whom she allegedly had
complained about Jeffrey Epstein, but only produced selected emails within the same email
chain.
Because a thorough search of email communications was not performed within the
Yahoo account or any other account used by Ms. Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
United States District Court
Southern District Of New York
--------------------------------------------------X
......
.........................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GH…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…category of withheld documents are email communications
between Ms. Ransome and her acquaintances while associated with Mr. Epstein (including the
12
people she has sued). Counsel for Ms. Ransome only produced selective portions of email
chains. By way of example…
giuffre-maxwell
1320-15
27 pg
…joint
[email protected],robie defense/commo
2 2/16/2015 1:05 [email protected] [email protected] Discussion of evidence among client and …
giuffre-maxwell
gov.uscourts.nysd.447706.156.3
9 pg
…joint
[email protected],ro Email chain with Giuffre, Edwards, Pottinger and defense/common
9/7/2015 [email protected],stan McCawley re collection of information to assist in interest/work
109 18:58 Sig…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…whom she allegedly had
complained about Jeffrey Epstein, but only produced selected emails within the same email
chain.
Because a thorough search of email communications was not performed within the
Yahoo account or any other account used by Ms. Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.4
35 pg
…joint
Jane Doe 2
[email protected], defense/commo
2 2/16/2015 1:05 [email protected] …
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…Document 179 Filed 05/31/16 Page 6 of 22
descriptions (which merely said, in every entry, “Communication re: legal advice”), Ms.
Giuffre’s entries describe the subject matter of the communication and disclose all individuals on
the email chain…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.39
35 pg
…joint
[email protected],robie defense/commo
2 2/16/2015 1:05 [email protected] [email protected] Discussion of evidence among clien…
giuffre-maxwell
1320-39
35 pg
…joint
[email protected],robie defense/commo
2 2/16/2015 1:05 [email protected] [email protected] Discussion of evidence among clien…
giuffre-maxwell
gov.uscourts.nysd.447706.165.1
6 pg
…the in the rendition of legal attorney work product related to the Epstein case, and defense/commo with other
128 from 2009 - Present rendition of legal advice advice communications r…
giuffre-maxwell
gov.uscourts.nysd.447706.155.0
15 pg
…log are 29 entries including Stan Pottinger as a person within
the distribution chain. See Menninger Decl., Ex. D. Pottinger is an attorney. According to
public records, he is licensed to practice in the States of New York and California…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…shows an email chain containing six
communications she had with Natalia Malyshev, an alleged co-conspirator, yet only two of those
emails were produced. The emails produced are in “screenshot” format rather than providing a
complete production of the emails…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…Virginia Roberts
Sent from my iPhone
GIUFFRE005613
CONFIDENTIAL
Log …