giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…and in the face of Plaintiff’s sworn denial that
she has had any contact with law enforcement officials from 1996 to the present apart from
supposed “active investigations involving Ghislaine Maxwell,” counsel for Defendant
unearthed numerous records of such…
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.447706.1202.0_2
65 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.447706.320.0
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.447706.1325.19
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.447706.1327.12
11 pg
…20,
23, 24, 30);
x documents relating to any contact between Ms. Maxwell and law enforcement
(RFP 13 and 38);
x photos of females under the age of 18 (RFP 7), of any time inside a home or
aircraft of…
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.447706.1295.11
19 pg
…him by various women. See Menninger Decl., Ex. B.
After reading the article, Ms. Ransome contacted Ms. Callahan via email resulting in several
communications with Ms. Callahan, none of which have been produced. See Menninger Decl.
Ex. A at 36…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…Moreover, these documents are featured in Defendant’s briefs,
Defendant issued subpoenas to both Sharon Churcher and Jarred Weissfeld months ago, and
Defendant has deposed Ms. Giuffre about her media contacts. See McCawley Decl. at Composite
Exhibit 1, Defendant’s…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 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.447706.1331.30
19 pg
…him by various women. See Menninger Decl., Ex. B.
After reading the article, Ms. Ransome contacted Ms. Callahan via email resulting in several
communications with Ms. Callahan, none of which have been produced. See Menninger Decl.
Ex. A at 36…
giuffre-maxwell
gov.uscourts.nysd.447706.363.9
5 pg
…cv-07433-LAP Document 363-9 Filed 08/11/16 Page 1 of 5
Exhibit I
Case 1:15-cv-07433-LAP Document 363-9 Filed 08/11/16 Page 2 of 5
FOR IMMEDIATE RELEASE Contact: Richard A…
giuffre-maxwell
gov.uscourts.nysd.447706.9.0
3 pg
…declared that he/she is a member in good standing of the bar(s) of the state(s) of
Florida _ ; and that his/her contact information is as follows
(please print):
Applicant's Name: Sigrid S. Mccawley
Finn Name: Boies…
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.447706.623.0
2 pg
…practice pro hac vice in this action is
GRANTED.
Applicant has declared that he is a member in good standing of the bar of the state of
Colorado; and that his contact information is as follows:
Ty Gee, Colorado Atty…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…Account
Ms. Giuffre has knowledge of the account because it was listed as
part of Defendant’s contact information (including phone number) on documents gathered by the
police from Epstein’s home, and turned over to the Palm Beach County…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…release an even
stronger denial, categorically denying any sexual contact whatsoever.
PHILIP WILLIAMS: What isn't in dispute is that Prince Andrew and Jeffrey Epstein
were good friends over a number of years.
In 2008, Mr Epstein was sentenced to…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…Palm Beach, Florida, 33480.
Upon the announcement of the search warrant , immediate contact was
made with three white males who came out of the house or surrounding
structures. Those males were identified as Janusz Banasiak, Daniel
Estes, and Mark Zeff…