giuffre-maxwell
gov.uscourts.nysd.447706.1328.11
11 pg
…I was authorized to and did
8 stenographically report the deposition of TONY
FIGUEROA; and that the foregoing transcript is a
9 true record of my stenographic notes.
10 I further certify that I am not a relative,
employee, attorney…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.18
8 pg
…a
review of the transcript was not requested; and
18 that the transcript is a true record of my
stenographic notes.
19 I FURTHER CERTIFY that I am not a
relative, employee, attorney, or counsel of any
20 of the…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…publications, including The Mail on Sunday, the National Enquirer, and Radar Online,
and were written by Ms. Churcher either as an employee of the publication or as freelance
reporter. See Declaration of Sharon Churcher (“Churcher Decl.”) ¶¶ 4-7 and Exs…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…course, whether the information sought to be kept confidential is already public.”); Lytle, 810 F.
Supp. 2d at 626 (“While the conduct at issue may be potentially embarrassing to these employees
. . . their names are already in the public record, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…big difference between having a
private email account (gmail, aol, yahoo, etc.) and communicating through a private messaging
system on an employer’s sever, as described by Mr. Alessi (“It was a server. I think it was --the
office would…
giuffre-maxwell
gov.uscourts.nysd.447706.1029.0
2 pg
…unnecessary delay and expense, and those employees’ affiliations with Epstein are already public.
The real motivation behind Defendant’s over broad nonparty list is best demonstrated by
her efforts to include her press agent on the list. Ross Gow is…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.24
4 pg
…was thereafter reduced to
12 typewritten form, and that the foregoing constitutes
13 a true and correct transcript.
14 I further certify that I am not related to,
15 employed by, nor of counsel for any of the parties or…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue of her employment records ............................................ 5
D. Newly obtained education records and other witness testimony contradict Plaintiff’s
…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…order .................................................................... 3
B. Plaintiff failed to produce emails form her iCloud and hotmail accounts ....................... 6
C. Plaintiff has failed to produce her employment records .................................................. 8
D. Plaintiff h…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue of her employment records ............................................ 5
D. Newly obtained education records and other witness testimony contradict Plaintiff’s
…
giuffre-maxwell
gov.uscourts.nysd.447706.443.0
4 pg
…Gow through The Hague Convention, causing
United Kingdom government agency to serve the subpoena at Mr. Gow’s place of employment.
Additionally, Ms. Giuffre hired process servers in the United Kingdom who made
multiple attempts to effect personal service upon…
giuffre-maxwell
gov.uscourts.nysd.447706.542.3
2 pg
…Method Launch FromFrom Ztieblina
Accelerator to Drive Innovation and Support
UK Economic Growth _.. _... _. Sir Paul McCartney
Supports BUAV
North East Lincolnshire Council Campaign to end Cruel
Emplovees& apos; Ideas Win Votes
…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
......
.........................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL, …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…on
multiple and critical issues including unproduced medical records, and undisclosed treatment
providers, undisclosed educational history, undisclosed employment, undisclosed intervening
causes of her alleged emotional distress, her material contradictory changes to testimony, and
any statements published and attributed to her…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…attempts to distinguish her two emails with key players in this case from the documents
that Ms. Giuffre produced after her deposition, namely, medical and employment records. There is a
distinction, but not what Defendant suggests. Not only are Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.12
15 pg
…thereafter reduced to
12 typewritten form, and that the foregoing constitutes
13 a true and correct transcript.
14 I further certify that I am not related to,
15 employed by, nor of counsel for any of the parties or
16…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…Control & Prevention, National Center for Health Statistics.
2) “Calculation of Work life Expectancy Using the Life, Participation,
Employment Method,” Vocational Econometrics, Inc.
3) Consumer Price Index for Urban Wage Earners and Clerical Workers,
Unite…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…. . The Plaintiff may be questioned about any documents
produced subsequent to the May 3 deposition relating to employment and education.” See Sealed
August 30, 2016 Order. As the Court has already ruled that reopening a deposition is appropriate
3
…
giuffre-maxwell
gov.uscourts.nysd.447706.440.1
21 pg
…New York since 1983. Churcher ~ 1.
Deel. 1
Churcher Decl. 1. She is
currently employed by American
American Media
Media,, Inc.,
Inc ., which
…