giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…providers and produce their records prior to
her deposition, despite this Court’s order ........................................................................ 2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue o…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…care providers and produce their records prior to
her deposition, despite this Court’s order .................................................................... 3
B. Plaintiff failed to produce emails form her iCloud and hotmail accounts ....................... 6
C. Plaintiff has failed to produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…providers and produce their records prior to
her deposition, despite this Court’s order ........................................................................ 2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue o…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…During
that time, Plaintiff has had a full and fair opportunity to depose Ms. Maxwell on the subject
matters she claims are raised by these two emails, and Plaintiff did in fact question Ms. Maxwell
on the subjects covered by…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
… Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 2 of 9
produced documents at issue in this pending motion is an email chain showing Epstein’s involvement
in crafting yet another draft statement…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…VIRGINIA L. GIUFFRE,
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
DEFENDANT’S RESPONSE TO PLAINTIFF’S MOTION TO COMPEL
DATA FROM DEFENDANT’…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…by News Corp UK & Ireland Limited
or any member of its group. News Corp UK & Ireland Limited may
monitor outgoing or incoming emails as permitted by law. It accepts
no liability for viruses introduced by this e-mail or attachments…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.5
12 pg
…name, but makes
no claim that they were involved in any sexual abuse.
Plaintiff admittedly wrote that book manuscript in the hopes of selling her story on a
mass-market basis. In hundreds of emails throughout 2011, 2012 and 2013…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…concerns
.3 Although Ms. Giuffre dismisses the Requested Documents as irrelevant, they
indisputably
3
The fact that the Emails involve communications with a reporter neither implicates any privilege nor justifies
confidentiality protections. The Emails are in Ms. Giuffre’s possession…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…these documents to any particular time period or topic,
instead requiring Churcher to sift through a decade’s worth of communications, from multiple
email accounts with multiple employers.
The Subpoena must be quashed for two separate and independent reasons. First…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…2015), letters and emails which detailed likely litigation and an intent to sue were
extended the same pre-litigation privilege although sent to two non-parties who were only
potentially affected by the litigation or witnesses to it. See also…
giuffre-maxwell
gov.uscourts.nysd.447706.279.0
8 pg
…Plaintiff’s motion is granted in part.
Defendant is ordered to collect all ESI by imaging her computers and collecting all email and
text messages on any devices in Defendant’s possession or to which she has access that
Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.542.3
2 pg
EXHIBIT C
Share this
page
Ub …
giuffre-maxwell
gov.uscourts.nysd.447706.1029.0
2 pg
Case 1:15-cv-07433-LAP Document 1029 Filed 02/05/20 Page 1 of 2
Telephone: (954) 356-0011
Email: [email protected]
February 5, 2020
VIA ECF
The …
giuffre-maxwell
gov.uscourts.nysd.447706.156.2
4 pg
…05/20/16 Page 1 of 4
EXHIBIT B
Case 1:15-cv-07433-LAP Document 156-2 Filed 05/20/16 Page 2 of 4
Media Advice Communications
Log Email Sent …
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…then,
11 sometimes with information from the Original parties, will
12 prepare a redacted copy of those filings so that those can be
13 docketed.
14 With respect to filing objections by email, we're
15 going to include that…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…former boyfriend, convicted pedophile Jeffrey Epstein. See
McCawley Decl. at Sealed Composite Exhibit 1, August 16, 2016, email from Laura Menninger;
November 10, 2015, Email from Ross Gow to Defendant, GM_01141-01142; Email between
Defendant and Epstein, GM_01143…
giuffre-maxwell
gov.uscourts.nysd.447706.550.0
3 pg
…Pearl Street, 14th Floor
Hartford, CT 06103
Tele: 702-420-2001
Fax: 305-437-7662
Email: [email protected]
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.25
4 pg
…Yes. 09:19:56
·6· · · · · · (Exhibit 9 was marked for identification.) 09:19:56
·7· · · · BY MS. SCHULTZ: 09:20:01
·8· · · · Q.· ·This also appears to be an email chain with you 09:20:0…
giuffre-maxwell
gov.uscourts.nysd.447706.920.0
2 pg
…CT 06103
Tele: 702-420-2001
Fax: 305-437-7662
Email: [email protected]
Attorneys for Int…