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.447706.1328.6
32 pg
…AND REPETITION OF, ACCUSATIONS
AGAINST PROFESSOR DERSHOWITZ..............................................................5
III. THE EXCULPATORY EMAILS, REPLY BRIEF,
AND MANUSCRIPT ..............................................................................................6…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…Up
Flag Status: Flagged
Laura,
Please see my additions in-line, in black, below to your email sent yesterday. My in-line communication should
also be responsive to the email that you just sent. If I have left anything out…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…production
from Defendant's electronic media. Accordingly, please use IMAP Capable software (or a
functional equivalent) to capture all of the sent/received emails from Ms. Maxwell's various
email accounts, including but not limited to the following: (1) GMaxl…
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.447706.1330.23
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.447706.385.0
2 pg
…representation , I have on various
occasions exchanged information via email with Ms. Maxwell’s counsel Laura Menninger.
These emails are attorney work product because the information we exchanged implicates my or
Case 1:15-cv-07433-LAP Document 385…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.13
13 pg
…and production
from Defendant's electronic media. Accordingly, please use IMAP Capable software (or a
functional equivalent) to capture all of the sent/received emails from Ms. Maxwell's various
email accounts, including but not limited to the following: (1) …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…any person, group or entity. ...... 15
II. Ms. Maxwell properly has asserted privileges. ......................................................... 17
A. Email from Mr. Epstein to Ms. Maxwell. ................................................................ 17
B. Emails exchanged between Mr. Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…Specifically, I seek to
unseal portions of a brief (the “Reply Brief”) and certain emails (the “Emails”) that were
submitted in connection with a motion to quash a testimonial subpoena directed to British tabloid
journalist Sharon Churcher, and a draft…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.17
2 pg
…During the course of my representation of Professor Dershowitz, I have on various
occasions exchanged information via email with Ms. Maxwell’s counsel Laura Menninger.
These emails are attorney work product because the information we exchanged implicates my or
…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…obligations1. Indeed, in response to thirty-eight (38) requests for
production, the defendant has chosen to produce two emails.2 This represents a willful disregard
of her discovery obligations, something this Court should not condone.
“Although not unlimited, relevance, for…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…173-4, 173-10, which Maxwell argues are
not judicial documents because they contain “various back and forth emails between counsel.”
Maxwell Mem. at 11-12. These docket entries are already available to the public in full on the
docket…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
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.447706.1256.8
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.447706.1218.49
27 pg
…¶ 37. This
entirely fabricated story was obviously inserted as the result of the email exchange between Ms.
Giuffre and Sharon Churcher in which Ms. Churcher urges Ms. Giuffre to include my name in
her manuscript in order to make it…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…of Danbury, 298 F.R.D. 37 (D. Conn. 2014)
(protective order granted with respect to personal information of nonparties, including home
addresses, email addresses, phone numbers, dates of birth, children’s names, financial account
numbers, and social security numbers);…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…before it a request from a non-party (Alan Dershowitz) to intervene in this
case for the purpose of extracting and publicizing several emails and a draft manuscript from the
Protective Order that has long been entered in this case…
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.447706.1295.10
14 pg
…the
7 record, I will say that my
8 understanding is that those
9 documents were all produced to
10 you, including all the emails
11 that you asked her about, and
12 where are the missing emails, and
13 …