giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida
33301, within thirty (30) days of service hereof.
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
1. “Agent” shall mean any agent, employee, officer, director…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…14 Q. Yes, that's okay.
15 A. A few days later, I remember asking her
16 questions to try to figure out her role, why she was
17 there, and she gave me vague answers and was never
18…
giuffre-maxwell
gov.uscourts.nysd.447706.59.0
5 pg
…on Ms. Giuffre to collect, evaluate, and log such communications within thirty days of service
of the Requests.
Local Civil Rule 26.2(b) requires, inter alia, that when documents sought are withheld on the
grounds of privilege, a privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…See
McCawley Decl. at Exhibit 6, SAO 2830. Maxwell was also organizing “massages” for Epstein
in 2004 with underage girls and indicating which girls she had lined-up on given days. See
McCawley Decl. at Exhibit 6, SAO 02841.
Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…Epstein with an
underage girl.
9
Case 1:15-cv-07433-LAP Document 1218-49 Filed 07/15/21 Page 10 of 27
. I would be spending
two days with him showing him around the island, dining with
him…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…and Defendant requested that Ms. Giuffre reschedule that
deposition just days before the scheduled date.
12
Case 1:15-cv-07433-LAP Document 1307-4 Filed 08/25/23 Page 17 of 28
7. Jean Luc Brunel (3 ½…
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…14 form and foundation. You can answer if
15 you have knowledge.
16 A. I already testified I was limited
17 in the house, a couple of days, there is no
18 way I knew. I have read these reports. …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…and Defendant requested that Ms. Giuffre reschedule that
deposition just days before the scheduled date.
12
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 17 of 28
7. Jean Luc Brunel (3 ½…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.17
11 pg
…A Yeah. Well, it was actually a little bit
17 shorter hours. I can't remember exactly. But I
18 know it was not like the full days. Because, I
19 mean, at the alternative schools, it's obviously not…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…visited
Epstein's Palm Beach mansion four or five times a year, staying two or three days
when he went there — and Alessi was able to identify a photograph of Ms. Giuffre
as someone who was at the mansion as…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
…14 Q. Yes, that's okay.
15 A. A few days later, I remember asking her
16 questions to try to figure out her role, why she was
17 there, and she gave me vague answers and was never
18…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.11_3
23 pg
…14 form and foundation. You can answer if
15 you have knowledge.
16 A. I already testified I was limited
17 in the house, a couple of days, there is no
18 way I knew. I have read these reports. …
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…and Defendant requested that Ms. Giuffre reschedule that
deposition just days before the scheduled date.
12
Case 1:15-cv-07433-LAP Document 1137-12 Filed 10/22/20 Page 17 of 28
7. Jean Luc Brunel (3 ½…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…it is relevant. It was just submitted just
21 recently, parenthetically, two days ago, that is why I raised
22 it before. It has been submitted.
23 I'm sure that the plaintiff believes that it's
24 relevant, obviously…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…and Defendant requested that Ms. Giuffre reschedule that
deposition just days before the scheduled date.
12
Case 1:15-cv-07433-LAP Document 1256-3 Filed 05/03/22 Page 17 of 28
7. Jean Luc Brunel (3 ½…
giuffre-maxwell
gov.uscourts.nysd.447706.55.21
69 pg
…had completed going through what you would do
13 Q. And how long did this training last? 13 in a day.
14 A. Two or three days. 14 A. Until noon we have all the -- we knew
15 Q. Okay…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…is enough to point out that
Defendant’s motion was filed on August 12, 2016 – and then, just four days later, on August 16,
2016 – defense counsel disclosed to Ms. Giuffre’s counsel an email revealing quite clearly that
GIUFFRE001465…
giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
…first met her, or the
15 like. All we know is that in the last 30 days, they've had
16 enough time to go to Europe to meet with her, to draft a
17 separate complaint which they filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…Write a Brief Statement of Cause (Do ,wt citejuriwlictional statutes u11less diversity):
VII. CAUSE OF ACTION Miscellaneous Action to Enforce Rule 45 Subpoena
LENGTH OF TR IAL via days estimated (for both sides to try entire case)
VIII. REQUESTED IN …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.28
38 pg
…Yes. 24 visit?
25 Q. Were there days when he received 25 MR. PAGLIUCA: Objection to the
Page 79 Page 81
1 G Maxwell - Confidential 1 G Maxwell - Confidential…
Comments