giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…waiver. In any event, whether served or not, Mr.
Brunel apparently promised to provide new dates before his deposition date came and went, did
not do so, has left the country and not indicated a present intention to return. Given…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…waiver. In any event, whether served or not, Mr.
Brunel apparently promised to provide new dates before his deposition date came and went, did
not do so, has left the country and not indicated a present intention to return. Given…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…and many requests have no date restrictions whatsoever. See, e.g., Request No.
26, “All Documents concerning any prescription drugs taken by You, including the prescribing doctor, the
dates of said prescription, and the dates of any fulfillment of any…
giuffre-maxwell
1320-28
32 pg
…waiver. In any event, whether served or not, Mr.
Brunel apparently promised to provide new dates before his deposition date came and went, did
not do so, has left the country and not indicated a present intention to return. Given…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…waiver. In any event, whether served or not, Mr.
Brunel apparently promised to provide new dates before his deposition date came and went, did
not do so, has left the country and not indicated a present intention to return. Given…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…custody and control that would demonstrate Maxwell traveling with underage
females but to date she has refused to produce this information and indeed is limiting her responses to a
very narrow window of time.
5
with various sexual abuse allegations…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…with that Order. The parties are further directed to jointly file a proposed redacted version
of this Opinion or Notify the Court that none are necessary within two weeks of the date of receipt of this Opinion.”
June 20, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…with that Order. The parties are further directed to jointly file a proposed redacted version
of this Opinion or Notify the Court that none are necessary within two weeks of the date of receipt of this Opinion.”
June 20, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1109.0_1
3 pg
…disclosure.
The Court will rule on (1) the appropriateness of the proposed
disclosure to Mr. Dershowitz and (2) the scope of any disclosure
to Mr. Dershowitz at a later date.
SO ORDERED.
Dated: New York, New York
August 31, 2020
…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.17
3 pg
Case 1:15-cv-07433-LAP Document 1198-17 Filed 01/27/21 Page 1 of 3
EXHIBIT R
Summary of Plaintiff’s Statements Concerning Disclosure of HealthCare Information
Date Plaintiff’s Statement Truth Sources
March 16 Refusal to…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…attorneys n interest Withheld 2 msg
Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
Log …
giuffre-maxwell
gov.uscourts.nysd.447706.165.1
6 pg
…cases
Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016
Case 1:15-cv-07433-LAP Document 165-1 Filed 05/26/16 Page 3 of 6
Log …
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…motion was
taken on submission on that date. Defendant filed a reply on
June 6, 2016 .
Plaintiff filed her letter motion for l eave to serve three
depositions subpoenas by means other than personal service. By
Order dated May 27 …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…Action No. 15-cv-07433-RWS
PROOF OF SERVICE
(This section should not be filed with the court unless re
I;:2e_:_e•V~-~ --~
_ 1J;_poena for (name ofindividual and title, ifany)
…
giuffre-maxwell
1320-32
27 pg
…Action No. 15-cv-07433-RWS
PROOF OF SERVICE
(This section should not be filed with the court unless re
I;:2e_:_e•V~-~ --~
_ 1J;_poena for (name ofindividual and title, ifany)
…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…Maxwell, Case No. 15-cv-7433-LAP
Dear Judge Preska,
Pursuant to the Court’s orders dated January 19 and January 26, 2021 (ECF No. 1193),
Plaintiff files the documents ordered unsealed listed in Exhibit F to Defendant’s Reply…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…Dershowitz on that same
date and time.
5. Any documents and information that support and/or confirm your presence at the various
locations named in Paragraphs 24-31 of your Declaration on the particular dates and
times when Alan M…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…this Response in Opposition to
Plaintiff’s Motion to Exceed Presumptive Ten Deposition Limit, and states as follows:
INTRODUCTION
Despite having taken only three depositions to date, Plaintiff prematurely requests
permission to exceed the presumptive ten deposition limit imposed by…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…to the 31-year-old say she relished her role as his 'travelling masseuse' and never
acted like she was being held captive.
Philip Guderyon, who used to date Roberts and would drive her to Epstein's Pal Beach, Florida…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…Ransome. A copy of the Subpoena is attached to this Notice.
EXHIBIT
(] J L }
)_ / l7 l /7
JEREMY RICHMAN
Case 1:15-cv-07433-LA…
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