giuffre-maxwell
gov.uscourts.nysd.447706.753.1
7 pg
…2 MS. MENNINGER: Your Honor, I actually believe that
3 these emails were some that your Honor had reviewed because we
4 had asserted a joint defense agreement privilege, and your
5 Honor reviewed these emails, and they were produced…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…18th
of posting the subpoenas to the addresses associated with each of the witnesses and mailing the
subpoenas to those addresses with the witness fee check and providing copies of the subpoenas
via e-mail to the witnesses known counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…experience or contact with Virginia
Roberts, Ghislaine Maxwell, Jeffrey Epstein,
including without limitation any Communication with anyone, any diary, journal,
email, letter, witness statement, and summary.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…Sarah Kellen, and Nadia
Marcincova, including without limitation any Communication with anyone, any diary, journal,
email, letter, witness statement, and summary.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…that the Court should make a record on the public docket each time a submission is
received. The Herald does not object to having objecting Does email their submissions directly to
the Court if they do not have counsel. However…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…Ghislaine Maxwell, Jeffrey Epstein,
, including without limitation any Communication with anyone, any diary, journal,
email, letter, witness statement, and summary.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…of disclosure, transfer or exchange, and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
3. …
giuffre-maxwell
1320-8
12 pg
…18th
of posting the subpoenas to the addresses associated with each of the witnesses and mailing the
subpoenas to those addresses with the witness fee check and providing copies of the subpoenas
via e-mail to the witnesses known counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…18th
of posting the subpoenas to the addresses associated with each of the witnesses and mailing the
subpoenas to those addresses with the witness fee check and providing copies of the subpoenas
via e-mail to the witnesses known counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…documents, particularly electronic
documents, dating back over 16 years. However, Ms. Maxwell, prior to this litigation has long
had a practice of deleting emails after they have been read.
17. Ms. Maxwell objects to Instruction Nos. 5, 8, 9, 12…
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