giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…Fort Lauderdale, Florida
33301, within thirty (30) days of service hereof.
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
1. “Agent” shall mean any agent, employee, officer, director, attorney, independent
contra…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…Fort Lauderdale, Florida
33301, within thirty (30) days of service hereof.
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
1. “Agent” shall mean any agent, employee, officer, director, attorney, independent
contra…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…meanings:
1. “Plaintiff” in the above captioned action shall mean the plaintiff Virginia Giuffre
formerly known as Virginia Roberts.
2. “Defendant” in the above captioned action shall mean the defendant Ghislaine
Maxwell and her employees, representatives or agents.
3. “Agent…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…her boyfriend, Jeffrey Epstein, with whom she shared a household from
1999-2002 (and other years), implemented an entire, private email system to communicate with
his household and employees, including Defendant. Accordingly, given Defendant’s
extraordinary economic resources, her high…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…12
Buck v. Indian Mountain Sch.,
2017 WL 421648 (D. Conn. Jan. 31, 2017).............................................................................. 22
City of Pontiac Gen. Employee’s Ret. Sys. v. Lockheed Martin Corp.,
2012 WL 4202657 (S.D.N.Y. Sept. 18, 2012)...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.29_2
2 pg
…or exempt from
disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible
to deliver it to the named recipient, you are hereby notified that any dissemination, distribution…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…her boyfriend, Jeffrey Epstein, with whom she shared a household from
1999-2002 (and other years), implemented an entire, private email system to communicate with
his household and employees, including Defendant. Accordingly, given Defendant’s
extraordinary economic resources, her high…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…12
Buck v. Indian Mountain Sch.,
2017 WL 421648 (D. Conn. Jan. 31, 2017).............................................................................. 22
City of Pontiac Gen. Employee’s Ret. Sys. v. Lockheed Martin Corp.,
2012 WL 4202657 (S.D.N.Y. Sept. 18, 2012)...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.24
6 pg
…it was -- the
18 office would have, like, a message system between
19 him, the houses, the employees, his friends. They
20 would write a message on the computer. There was no
21 email at that time.
22 Q. Okay…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…and anyone acting on her behalf, as her agent, associate, employee or assignee.
3. “Your Attorneys” includes any attorney who You have engaged to represent You,
whether for remuneration or pro bono, from 1999 until today, including without limitation,
David…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.18
6 pg
…it was -- the
18 office would have, like, a message system between
19 him, the houses, the employees, his friends. They
20 would write a message on the computer. There was no
21 email at that time.
22 Q. Okay…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.8
6 pg
…exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent respons ble to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution…
giuffre-maxwell
gov.uscourts.nysd.447706.81.0
1 pg
…error, counsel for Ms. Giuffre spoke with an employee with the
ECF help desk who instructed us to inform the Court via letter that he placed a temporary seal on
Exhibit 4 to Docket Entry 79, Declaration of Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.30
6 pg
…exempt from disclosure under applicable law. If the reader of this
electronic message is not the named recipient, or the employee or agent respons ble to deliver it to the named recipient, you are hereby notified that any
dissemination, distribution…
giuffre-maxwell
gov.uscourts.nysd.447706.223.5
3 pg
…or exempt from disclosure undGr applicable law, If the reader of this electronic message is not the named
reCipient, or the employee or agent responSible to deliver it to the named recipient, you are hereby notified that Bny
dissemination, distribution…
giuffre-maxwell
gov.uscourts.nysd.447706.239.1
11 pg
…copying of this
1
Case 1:15-cv-07433-LAP Document 239-1 Filed 06/21/16 Page 3 of 11
communication is prohibited except by the addressee and employees or agents
responsible for delivering it to the addressee…
giuffre-maxwell
gov.uscourts.nysd.447706.223.7
3 pg
…the definitions of “Agent,” “Correspondence,”
“communication,” “Defendant,” “Document,” “Employee,” “Jeffrey Epstein,” “Ghislaine
Maxwell,” “Person(s),” “You,” and “Your,” the definitions of “Relevant Period” and “relevant
time frame,” the phrases “relating to” and “associated with,” the seeking of documents and
information…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…her boyfriend, Jeffrey Epstein, with whom she shared a household from
1999-2002 (and other years), implemented an entire, private email system to communicate with
his household and employees, including Defendant. Accordingly, given Defendant’s
extraordinary economic resources, her high…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.35
5 pg
…it was -- the
18 office would have, like, a message system between
19 him, the houses, the employees, his friends. They
20 would write a message on the computer. There was no
21 email at that time.
22 Q. Okay…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.13
5 pg
…it was -- the
18 office would have, like, a message system between
19 him, the houses, the employees, his friends. They
20 would write a message on the computer. There was no
21 email at that time.
22 Q. Okay…
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