giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…CONTINUING
INSISTENCE ON, AND REPETITION OF, ACCUSATIONS
AGAINST PROFESSOR DERSHOWITZ..............................................................5
III. THE EXCULPATORY EMAILS, REPLY BRIEF,
AND MANUSCRIPT ..................................................…
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.447706.1325.15
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.447706.1328.6
32 pg
…AND REPETITION OF, ACCUSATIONS
AGAINST PROFESSOR DERSHOWITZ..............................................................5
III. THE EXCULPATORY EMAILS, REPLY BRIEF,
AND MANUSCRIPT ..............................................................................................6…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…A. Menninger
HADDON
MORGAN
150 East 10th Avenue
FOREMAN
Denver, Colorado 80203
PH 303.831.7364 FX 303.832.2628
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…the Ransome deposition—an action
that would require modification of the Protective Order in this case —it also simultaneously
remove the confidentiality designation from several related emails and attachments that the
parties previously designated confidential (RANSOME_000273-557) (“the Emails”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…in determining whether nonparty
witness’ invocation of privilege against self-incrimination in course of civil litigation and
9
In discovery, Defendant Maxwell has produced several emails between Epstein and herself
discussing Ms. Giuffre.
8
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…than
her attorneys. See In re Grand Jury Subpoena, JK-15-029, 828 F.3d at 1090 (“DAS’s current
possession of [Kitzhaber’s] emails does not vitiate that claim. The Fourth Amendment protects
people, not places. Kitzhaber’s interests…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…at pp. 20-
8
In discovery, Defendant Maxwell has produced several emails between Epstein and herself
discussing Ms. Giuffre.
7
Case 1:15-cv-07433-LAP Document 1256-11 Filed 05/03/22 Page 12 of 15
22), the…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…112; 233; 250-251.
1
Jane Doe 43 inadvertently failed to include Document 000425-426 and hereby incorporates that email, which is
from 2007, into the documents she has agreed to release.
4
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…on June 2, Plaintiff’s counsel sent an email that
they had received “an email yesterday from Mr. Brunel's attorney saying he needs to reschedule.
I believe he is trying to get us new dates today or tomorrow.” Id…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…without
24 marking it as confidential. So I sent them an email just
25 asking them to hold that as confidential until the Court has an
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…2015, I prepared a further
statement denying the allegations, and I instructed Mr. Gow to transmit it via email to members
of the British media who had made inquiry about plaintiff’s allegations about Ms. Maxwell.
Schultz Decl., Exh. 2…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…in determining whether nonparty
witness’ invocation of privilege against self-incrimination in course of civil litigation and
9
In discovery, Defendant Maxwell has produced several emails between Epstein and herself
discussing Ms. Giuffre.
8
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…in determining whether nonparty
witness’ invocation of privilege against self-incrimination in course of civil litigation and
9
In discovery, Defendant Maxwell has produced several emails between Epstein and herself
discussing Ms. Giuffre.
8
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…at pp. 20-
8
In discovery, Defendant Maxwell has produced several emails between Epstein and herself
discussing Ms. Giuffre.
7
Case 1:15-cv-07433-LAP Document 1320-27 Filed 01/03/24 Page 12 of 15
22), the…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…a contingency or pro-bono
basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication” is directly refuted by
the multiple pictures and e-mails non-party Ms. Ransome produced – documentary evidence that
Defendant fails to discuss in her…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…camera review, Defendant and Mr. Gow
previously exchanged emails about how to leak information to the press to discredit Ms. Giuffre
by saying that she “cried rape” when she was 14 (GM_00577):
From: Ross Gow
Sent: Tuesday, February 24…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…at pp. 20-
8
In discovery, Defendant Maxwell has produced several emails between Epstein and herself
discussing Ms. Giuffre.
7
Case 1:15-cv-07433-LAP Document 1137-18 Filed 10/22/20 Page 12 of 15
22), the…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…in determining whether nonparty
witness’ invocation of privilege against self-incrimination in course of civil litigation and
8
In discovery, Defendant Maxwell has produced several emails between Epstein and herself
discussing Ms. Giuffre.
8
Case 1:15-cv-07433…