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.447706.1320.32
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.447706.1335.6
134 pg
…13 A. True. 13 believe that the question that I just asked is
14 Q. Is there anything, including any physical 14 vague?
15 conditions or ailments, that would prevent you from 15 MR. PAGLIUCA: It is vague. I don…
giuffre-maxwell
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.447706.1338.1
134 pg
…13 A. True. 13 believe that the question that I just asked is
14 Q. Is there anything, including any physical 14 vague?
15 conditions or ailments, that would prevent you from 15 MR. PAGLIUCA: It is vague. I don…
giuffre-maxwell
gov.uscourts.nysd.447706.683.0
18 pg
…York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S MOTION IN LIMINE TO ADMIT
THE “BLACK BOOK” AS EVIDENCE AT TRIAL
…
giuffre-maxwell
gov.uscourts.nysd.447706.666.0
4 pg
…OF NEW YORK
--------------------------------------------------X
..
.............................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
…
giuffre-maxwell
gov.uscourts.nysd.447706.693.0
5 pg
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
..
.............................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
…
giuffre-maxwell
gov.uscourts.nysd.447706.686.0
17 pg
…Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF MS. GIUFFRE’S MEMORANDUM OF LAW IN
SUPPORT OF HER MOTION IN LIMINE TO PRESENT
ALL EVIDENCE OF DEFENDANT’S INVOLVEMENT IN
EPSTEIN SEXUAL ABUSE AND SEX TRAFFICKING
…
giuffre-maxwell
gov.uscourts.nysd.447706.679.0
4 pg
…MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
303.…
giuffre-maxwell
gov.uscourts.nysd.447706.895.0
3 pg
…GIUFFRE,
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration Of Laura A. Menninger In Support Of Defendant’s
Response in…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.1
2 pg
…ARGUMENT REQUESTED
:
:
------------------------------------------------------- x
DEFENDANT GHISLAINE MAXWELL’S NOTICE OF MOTION UNDER THE DUE
PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE
GOVERNMENT’S SUBP…
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.447706.513.0
21 pg
…Untimely and Defendant
is Merely Trying to Deflect from Her Own Discovery Misconduct........................5
C. There Was No Willful Destruction of Evidence......................................................8
E. No Alleged Spoliation in the Context of an Unrelated Claim Att…
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.447706.516.0
3 pg
…GIUFFRE,
Plaintiff,
v. 15-cv-07433-RWS
.....
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration of Laura A. Menninger in Sup…
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.447706.524.0
5 pg
…establishing an
appropriate evidentiary basis for each and every opinion it intends to offer. The opinions violate
numerous rules of evidence and fundamental rights.
Ms. Maxwell requests a pre-trial hearing on this issue and that the Court issues a…
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