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.447706.599.0
12 pg
…Evid. 403 ............................................................................................................................ 6
Rule 702, Federal Rules of Evidence.............................................................................................. 7
…
giuffre-maxwell
gov.uscourts.nysd.447706.303.0
13 pg
…simply not an answer to that interrogatory by that party. It must be
recalled that interrogatories serve not only as a discovery device but as a means of
producing admissible evidence; there is no better example of an admission of…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.29_1
16 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.447706.1198.25_1
13 pg
…simply not an answer to that interrogatory by that party. It must be
recalled that interrogatories serve not only as a discovery device but as a means of
producing admissible evidence; there is no better example of an admission of…
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.447706.1320.32
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.447706.1295.11
19 pg
…the underlying matter, but instead allegedly relevant to
another Federal Action styled
Ransome objects to this Request as overbroad, harassing, and not calculated
to lead to discoverable evidence relevant to the Defamation Action.
See Menninger Decl. Ex. E, Responses 9…
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.447706.422.0
8 pg
…his alleged sexual abuse
of her from 1998 to 2002. Plaintiff’s damages claims alleged:
Plaintiff has in the past suffered, and will in the future continue to suffer, physical
injury, pain and suffering, emotional distress, psychological and/or psychiatric
…
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
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.447706.1219.29
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.447706.1331.30
19 pg
…cv-00616-JGK
(S.D.N.Y.). Ransome objects to this Request as overbroad, harassing, and not calculated
to lead to discoverable evidence relevant to the Defamation Action.
See Menninger Decl. Ex. E, Responses 9-30.
This argument is perplexing…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…2. This Request calls for the production of all responsive Documents in Your
possession, custody or control without regard to the physical location of such documents.
3. If any Document requested was in any defendant’s possession or control, but…
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.447706.684.0
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 …
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