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.447706.1328.10
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.447706.1325.11
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.447706.1330.23
9 pg
…and one of the late
1
Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 2 of 9
produced documents at issue in this pending motion is an email chain showing Epstein’s involvement…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…www.forbes.com/profile/leslie-wexner/) Leslie “Les” Wexner, CEO and founder of the women’s clothing chain Limited
Brands Inc., played a pivotal role.
Epstein bragged about having several unnamed billionaire clients at the height of his success, however…
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.447706.1320.39
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.447706.1320.19
22 pg
…to answer the impossible.
19 Q (BY MS. MENNINGER) All right. When did
20 Ghislaine Maxwell send you to have sex with the owner
21 of a large hotel chain?
22 MR. EDWARDS: Object to the form.
23 Mischaracterization.
24 …
giuffre-maxwell
1320-19
22 pg
…to answer the impossible.
19 Q (BY MS. MENNINGER) All right. When did
20 Ghislaine Maxwell send you to have sex with the owner
21 of a large hotel chain?
22 MR. EDWARDS: Object to the form.
23 Mischaracterization.
24 …
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.447706.1090.13_1
23 pg
…to answer the impossible.
19 Q (BY MS. MENNINGER) All right. When did
20 Ghislaine Maxwell send you to have sex with the owner
21 of a large hotel chain?
22 MR. EDWARDS: Object to the form.
23 Mischaracterization.
24 …
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…Virginia Roberts
Sent from my iPhone
GIUFFRE005613
CONFIDENTIAL
Log …
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…Dershowitz.
“Initially, they lied about the reason. They said that one of their partners was the chair of Columbia
University and they didn’t want to get involved in cases involving academics. That was a blatant lie. So
while they…