giuffre-maxwell
gov.uscourts.nysd.447706.684.0
3 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF
PLAINTIFF’S MOTION IN LIMINE TO ADMIT THE “BLACK BOOK” AS
EVIDENCE AT …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.601.0
5 pg
…Defendant has indicated, through counsel, that she intends to raise every possible objection to
Ms. Giuffre’s evidence in this case. Some of evidence Ms. Giuffre intends to offer may be regarded
as hearsay evidence and Ms. Giuffre is fully…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
1320-37
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…Cassell has crossed the line from being a legitimate advocate for a client, to being a
lawyer who is seeking to justify his own conduct in the face of compelling evidence that his
client is a thoroughgoing liar. That was…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…NAME KNOWN? ...
CAN VICTIM I.D. SUSPECT? Y SUSPECT LOCATION KNOWN N
WILL VICTIM PROSECUTE ? . . Y STOLEN PROPERTY TRACEABLE?
IS M.O. SIGNIFICANT? EVIDENCE LEFT AT SCENE? ...
LATENTS LIFTED? ... SUSPECT'S VEHICLE KNOWN? .. N
TAG NUMBER KNOWN ? .. …
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…claimed.
Annie Farmer, now 40, helped keep Epstein behind bars last July after giving evidence
about her ordeal as a teenager during a bail hearing. The financier was found dead in his
cell the following month. Ms Farmer is now…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…and pantry located off the kitchen were searched and
yielded negative results .
Th~ kitchen was searched and taken into evidence was a phone message
book: that was located near a house phone.
North of the kitchen was an office room…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…In short, the Opposition seems to suggest because she produced these pages, she should
not have to answer other of the subpoena requests nor answer deposition questions which are
designed to lead to admissible evidence and which, concededly, do not…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…Cassell has crossed the line from being a legitimate advocate for a client, to being a
lawyer who is seeking to justify his own conduct in the face of compelling evidence that his
client is a thoroughgoing liar. That was…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…and pantry located off the kitchen were searched and
yielded negative results .
Th~ kitchen was searched and taken into evidence was a phone message
book: that was located near a house phone.
North of the kitchen was an office room…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…In short, the Opposition seems to suggest because she produced these pages, she should
not have to answer other of the subpoena requests nor answer deposition questions which are
designed to lead to admissible evidence and which, concededly, do not…
giuffre-maxwell
gov.uscourts.nysd.447706.928.0
11 pg
…S.D.N.Y. 2009) (Sweet, J.) (Court not considering evidence
outside of complaint in deciding motion to dismiss, denying motion) (“‘[T]he evidence advanced
by Defendants is not within the four corners of the Complaint, and cannot be considered…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…1
Ms. Giuffre intends to strongly disprove Defendant’s false assertions and to demonstrate that
Defendant recruited Ms. Giuffre to be involved in massages of a sexual nature with Epstein.
To develop evidence to support her position, Ms. Giuffre recently…
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