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.447706.71.2
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.447706.76.1
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
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.447706.232.1
…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.447706.99.0
22 pg
…custodian, location and
general description of relevant documents, including pertinent insurance agreements, and other
physical evidence, or information of a similar nature.” Defendant’s interrogatories do just that:
1 – addresses where Plaintiff lived, dates, names of witnesses who lived…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…1\:'IL V• --- -
I V.
Plaintiff, -----
15-cv-07433-RWS
GHISLAINE MAXWELL,
I Defendant.
I --------------------------------------------------X
I
DEFENDANT'S MOTION FO…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…or necessary to this action and, thus, are not reasonably calculated to lead to
the discovery of admissible evidence. Ms. Giuffre further objects because Defendant’s Second
Set of Requests for Production seeks documents that are in no way limited…
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.447706.1332.9
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.447706.69.2
21 pg
…2010 Deposition Transcript of Nadia Marcinkova, attached hereto as
Exhibit 28.
C. Computation of damages:
1. Physical, psychological and psychiatric injuries and resulting medical expenses – in
an amount of approximately $ 102,200 present value.
a. Computation Analysis:
…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…See, e.g., Peisach v. Antuna, 539 So. 2d 544 (Fla. 3d DCA 1989) (holding that
the trial judge erred in allowing the deposition of certain non-parties where evidence sought was
irrelevant); see also Citimortgage, Inc. v. Davis, No…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…with a
different member of the Harvard faculty—whom she identifies by name and physical
characteristics—it levels no such accusation against Professor Dershowitz. Dershowitz
Decl. ¶ 37.
The Requested Documents, taken together with other evidence currently in the public
record…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…matter of every
kind and description, graphic and oral records and representations of any kind, and electronic
“writings” and “recordings” as set forth in the Federal Rules of Evidence, including but not
limited to, originals or copies where originals are…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…worksheets, printed matter of every kind and description, graphic and oral records and
representations of any kind, and electronic "writings'' and ·'recordings" as set fo11h in the Federal
Rules of Evidence, including but not limited to, originals or copic;s…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…suggest that a prime minister
20 is threatening the physical safety of this
21 witness. There's no foundation for that. The
22 suggestion that a foreign minister is going to
23 physically harm has no evidence in this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…matter of every
kind and description, graphic and oral records and representations of any kind, and electronic
"writings" and "recordings" as set forth in the Federal Rules of Evidence, including but not
limited to, originals or copies where originals are…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…of every
kind and dcsniption, graphic and oral records and representations of any kind, and electronic
"writings" and "recordings" as set (()fth in the Federal Rules of Evidence, including but not
limited to, originals or copies where originals are not…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…Ms. Maxwell -- I am not understanding
11 precisely the court's question, but I think if the court is
12 talking about it being introduced into evidence in the trial or
13 for some other purpose?
14 THE COURT: Well…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…Maxwell's press release appears
5. All evidence obtained by the Federal Bureau of Investigations which relate in any way
to Jeffrey Epstein or Ghislaine Maxwell.
6. All 302 statements that relate in any way to Jeffrey Epstein or Ghislaine…
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