giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…and produced many
relevant documents. Indeed, witness Ms. Ransome has provided more significant evidence, including
photographic evidence and electronic communications, than Defendant has produced in the two years
she has been litigating this matter. Defendant has not produced a single…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…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
2
Case 1:15-cv-07433-RWS Document 17-1 Filed 12/01…
giuffre-maxwell
gov.uscourts.nysd.447706.156.1
26 pg
…and
Work
[email protected],bra …
giuffre-maxwell
gov.uscourts.nysd.447706.1326.3
27 pg
…and
Work
[email protected],br …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.15
27 pg
…and
Work
[email protected],br …
giuffre-maxwell
1320-15
27 pg
…and
Work
[email protected],br …
giuffre-maxwell
gov.uscourts.nysd.447706.908.0
4 pg
…FBI
302 attached hereto as Exhibit A. On March 18, 2011, Special Agents “traveled to Giuffre’s
residence where she provided 20 photographs,” which were taken into evidence. Id. at 12. One
of those 20 photographs was the photo of…
giuffre-maxwell
gov.uscourts.nysd.447706.165.1
6 pg
…overly
broad and unduly burdensome, as individually logging all
privileged responsive documents would be over…
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.447706.1078.5
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.447706.562.2
29 pg
…against
them. They have provided ample evidence that they had a powerful basis for believing their
client's sexual abuse allegations — and were accordingly justified in filing a legal document on
their client's behalf which contained those allegations. As…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…to benefit from her obvious failure to properly disclose Ms.
Ransome.
Ms. Ransome's Testimonv is ot Cumulative And Has Highly Relevant Evidence
Defendant also advances the remarkable argument that it is "unlikely" that Ms. Ransome
will have relevant information…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…victims, employing “a pyramid abuse scheme in which he paid
underage victims $200-$300 cash for each other underage victim that she brought to him.”
“There is no evidence the President was involved in Epstein’s schemes,” Scarola said.
Still…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…as even a cursory review can attest. The Opposition alone references dozens of
potential witnesses, many of whom reside abroad, and purported “mountain[s] of evidence”
spanning over sixteen years. Third, the length of the stay sought is negligible. Fourth…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
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.447706.435.1
8 pg
…happy to elaborate on that, but that is the
19 first piece of evidence that I would begin referring to.
20 If you want a more -- if you want -- just so
21 the record is clear, if you want to…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…2
2. Ms. Giuffre’s Post-2002 Discovery Requests Are Narrowly Tailored To
Seek Specific, Relevant Evidence Of Defendant’s Continued Involvement In
Jeffrey Epstein’s Underage Sex Trafficking .......................................................3
B. Defenda…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…non-privileged matter that is
relevant to any party’s claim or defense. Information within this scope of discovery need not be
admissible in evidence to be discoverable. Relevance is still to be “construed broadly to
encompass any matter that…
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