giuffre-maxwell
gov.uscourts.nysd.447706.1320.14
3 pg
…are false the strongest is the clinton dinner, and the new version in the virgin isalnds that stven
hawking partica-ted in an underage orgy
please note
The information contained in this communication is
confidential, may be attorney-client privileged…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.2
3 pg
…are false the strongest is the clinton dinner, and the new version in the virgin isalnds that stven
hawking partica-ted in an underage orgy
please note
The information contained in this communication is
confidential, may be attorney-client privileged…
giuffre-maxwell
1320-14
3 pg
…are false the strongest is the clinton dinner, and the new version in the virgin isalnds that stven
hawking partica-ted in an underage orgy
please note
The information contained in this communication is
confidential, may be attorney-client privileged…
giuffre-maxwell
gov.uscourts.nysd.447706.165.0
4 pg
…v. 15-cv-07433-RWS
......
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration Of Laura A. Menninger In Support Of
…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.5
4 pg
…v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration Of Laura A. Menninger In Support Of
Motion To Compel All Attorney-Client Communication
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…included within your Rule 26 disclosures. However, you never submitted a RFP seeking all
-
communications between our client and your witnesses. There are some RFPs which identify individual witnesses whose
communications with…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…include all
documents of any nature that have been archived or placed in permanent or temporary storage
including electronic storage.
5. “Communication” means any transmission or exchange of information between
two or more persons, orally or in writing or otherwise…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…matter was
deemed fully c submitted. ·.
II. The J?riv;i.l.ege Claim$ at l$l?rie
:
Defendant has withheld 99 pages of emails with
communications involving various combinations of Brett Jaffe,
Esq. ("Jaffe"), Mark Cohen, Esq. …
giuffre-maxwell
gov.uscourts.nysd.447706.56.0
14 pg
…English “Legal Advice” Privilege Does Not Apply...................................4
a. Confidentiality Under English Law..........................................................5
b. Communication Via An Agent Under English Law.................................6
…
giuffre-maxwell
gov.uscourts.nysd.447706.239.1
11 pg
…Washington, D.C. 20005
Telephone: (202) 583-2500
Fax: (202) 583-0565
Mobile: (202) 595-4466
Web Site: www.gpoelaw.com
This communication is intended solely for the use of the addressee. It may contain
information that is privileged, confidential…
giuffre-maxwell
gov.uscourts.nysd.447706.440.1
21 pg
…Churcher to
Subpoena also commands to bring with her to the
documents:
deposition several broad categories of documents:
1.
1. Documents containing communications with
All Documents
Roberts.
Virginia …
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…on information currently known to her and are given without waiving Ms. Maxwell’s right
to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms. Maxwell reserves the right to supplement this Response in accordance
with…
giuffre-maxwell
gov.uscourts.nysd.447706.196.0
2 pg
…Declaration in
support of Defendant's Reply In Support of Motion to Compel All Attorney-Client
Communications and Attorney Work Product Placed At Issue by Plaintiff and Her
Attorneys under seal pursuant to this Court' s Protective Order (Doc.# 62).
…
giuffre-maxwell
gov.uscourts.nysd.447706.140.2
3 pg
…463 N.Y.S.2d 977 (4th Dep’t 1983) (privilege attaches only to certain confidential communications
between public officers in performance of their duties).
The public interest privilege extends to confidential communications made to public officers in the performance…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…the requests as
3
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 5 of 40
overly burdensome to the extent that they would require logging voluminous and ever-increasing
privileged communications between Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…P. Specifically, Ms. Giuffre objects to the requests as
overly burdensome to the extent that they would require logging voluminous and ever-increasing
privileged communications between Ms. Giuffre and her counsel after the date litigation
commenced on September 21, 2015…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…are
hereby notified that any dissemination, distribution or copying of the information contained herein is strictly
unauthorize d and prohibited. If you have received this communication in error, please notify the sender
immediately and delete this messa ge. Thank you.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…P. Specifically, Ms. Giuffre objects to the requests as
overly burdensome to the extent that they would require logging voluminous and ever-increasing
privileged communications between Ms. Giuffre and her counsel after the date litigation
commenced on September 21, 2015…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…> the rights to the child in the event that she and Epstein
> had a falling out. She says she refused this
> request.·
--
please note
The information contained in this communication is
confidential, may be attorney-client privileged…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…the requests as
overly burdensome to the extent that they would require logging voluminous and ever-increasing
3
Case 1:15-cv-07433-RWS Document 71-2 Filed 03/23/16 Page 5 of 45
privileged communications between Ms…