giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…Second set of Requests for Production on April 14. Those Requests
primarily concerned police reports about Plaintiff’s various contacts with law enforcement and
how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19)…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…Second set of Requests for Production on April 14. Those Requests
primarily concerned police reports about Plaintiff’s various contacts with law enforcement and
how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19)…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…again, swearing under oath that I did not sexually abuse
Virginia Roberts Giuffre, and that any allegation or suggestion to the contrary is categorically
false. I never had sexual contact with Ms. Giuffre of any kind, and, to my knowledge…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…home in Palm Beach is where this document was taken from. It
20 was for purposes of the house staff being able to use to
21 contact people or when people called in, so it was a reference,
22 a…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…Brunel was another of Epstein’s closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. Brunel has been a
model scout for various modeling agencies for many years and apparently was able…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 10 of 20
As she testified at her deposition, Ms. Maxwell has contacted a number of professional
masseuses from spas in various locations, including New York, Palm Beach…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…information concerning who prepared
documents, the location of any copies of such documents, the identities and contact information
for persons who have custody or control of such documents, the reasons for inability to produce
portions of documents, and the “natural…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…taken
out ofthe legal profession. They can't be allowed to have a bar card to victimize
more innocent people."
Hala Gorani — CNN Live (Jan. 5,2015)
"There was no contact, no contact whatsoever. And I will prove it conclusively…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…again, swearing under oath that I did not sexually abuse
Virginia Roberts Giuffre, and that any allegation or suggestion to the contrary is categorically
false. I never had sexual contact with Ms. Giuffre of any kind, and, to my knowledge…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…Privilege1. For the reasons outlined below,
the Court should deny Plaintiff’s Motion to Compel Production of Documents Subject to
Improper Privileges.
INTRODUCTION
Without a single conferral (despite multiple email and telephonic contacts between
counsel in the interim weeks), Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
… was another of Epstein’s closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. has been a
model scout for various modeling agencies for many years and apparently was able to get…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…Jane Doe No. 1 and Jane Doe No. 2
contacted Government counsel to request their agreement to add an additional victim to this case:
a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014,…
giuffre-maxwell
1320-17
25 pg
…information concerning who prepared
documents, the location of any copies of such documents, the identities and contact information
for persons who have custody or control of such documents, the reasons for inability to produce
portions of documents, and the “natural…
giuffre-maxwell
1320-9
10 pg
…Brunel was another of Epstein’s closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. Brunel has been a
model scout for various modeling agencies for many years and apparently was able…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…my travel, work, and cell
phone records, together with other documentary evidence, prove that I could not have been in
locations in which she claims to have had sexual contact with me, including Little St. James,
New Mexico, Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…my travel, work, and cell
phone records, together with other documentary evidence, prove that I could not have been in
locations in which she claims to have had sexual contact with me, including Little St. James,
New Mexico, Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…I was never massaged by her. There was no contact,” Dershowitz insisted,
calling her a “serial liar, serial prostitute.” But her lawyers insisted in the new court documents that “Dershowitz’s name
http://radaronline.com/exclusives/2015/01/bill-clinton…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…Brunel was another of Epstein’s closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. Brunel has been a
model scout for various modeling agencies for many years and apparently was able…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…Buckingham Palace issued a statement which said, "It is emphatically denied that the Duke of
York [Andrew] had any form of sexual contact or relationship" with the woman. "Any claim to the contrary is false and
without foundation."
Andrew is…
giuffre-maxwell
gov.uscourts.nysd.447706.409.2
1 pg
…Hac Vice in the
above captioned action is granted.
Applicant has declared that he is a member in good standing of the bar of the State
of Florida; and that his contact information is as follows:
Jack A. Goldberger
Atterbury…