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.447706.1206.2
23 pg
…The government knew
what was in the had provided that information well before the
investigation began. The government did indeed have previous contact with . And
was instrumental in fomenting the Maxwell prosecution.
The record is surpassingly clear: But for…
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.447706.1327.12
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.447706.46.0
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.447706.1328.18
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.447706.363.0
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.447706.363.9
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.447706.363.8
3 pg
…cv-07433-LAP Document 363-8 Filed 08/11/16 Page 1 of 3
Exhibit H
Case 1:15-cv-07433-LAP Document 363-8 Filed 08/11/16 Page 2 of 3
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.447706.1219.46
2 pg
…Dear Ms. Menninger,
Attached please find correspondence from Meredith Schultz in regards to the above-referenced matter.
Please do not hesitate to contact our office should you have any questions regarding this matter.
Thank You,
Aneisha K.Christie
BOIES, SCHILLER…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.33
3 pg
…good time in UK .. .Wanted to
Shopping contact u for a while but didn't have Uf email
Travel I am good Pretty busy but productive
Write back let me know what ur up to ... When r u gonna b…
giuffre-maxwell
gov.uscourts.nysd.447706.34.2
3 pg
…who are
sharing connections, ideas, and opportunities.
• See who you know in common
• Get introduced
• Contact Ross directly
Experience
Owner, Managing Partner
ACUITY Reputation
January 2010 – Present (6 years 2 months)
ACUITY advises Governments, Corporates and UHNWIs on reputational issues…
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.447706.988.1
5 pg
…I believe you should now have everything you need. Please do not hesitate to contact me should you need anything
further.
Sandra
From: [email protected] [mailto:[email protected]]
Sent: Thursday, April 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…Doe #1, Doe #2, and Doe #3.
• Provide the address or contact information for each Non-Party or his or her legal
counsel, which the Original Parties identified to the best of their ability.
2. Judicial Adjudication: Because of the…
giuffre-maxwell
gov.uscourts.nysd.447706.988.0_2
6 pg
…I believe you should now have everything you need. Please do not hesitate to contact me should you need anything
further.
Sandra
From: [email protected] [mailto:[email protected]]
Sent: Thursday, April 27…
Comments