giuffre-maxwell
gov.uscourts.nysd.447706.239.1
11 pg
…address has changed to
[email protected]. Please update your address book accordingly.
Gregory L. Poe
LAW OFFICES OF GREGORY L. POE PLLC
The Executive Building
1030 15th Street, N.W.
Suite 580 West
Washington, D.C. 20005
Telephone: (202)…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…the 25 interrogatory limit set by Rule 33.
Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…the 25 interrogatory limit set by Rule 33.
Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege…
giuffre-maxwell
1320-37
48 pg
…the 25 interrogatory limit set by Rule 33.
Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…the 25 interrogatory limit set by Rule 33.
Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…and Law Enforcement are not news-
gathering activities ........................................................................................................... 7
II. THE ABSOLUTE PRIVILEGE OF THE SHIELD LAW IS NOT APPLICABLE
BECAUSE THERE WAS NO EXPECTATION OF CONFIDENTIALITY ..................... 9
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…Filed 01/05/24 Page 4 of 40
Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…Filed 03/23/16 Page 4 of 45
Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…Filed 03/31/16 Page 4 of 45
Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…Filed 03/23/16 Page 4 of 40
Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.34
10 pg
…Groff RANSOME_000006
Executive Assistant to Jeffrey Epstein
Case 1:15-cv-07433-LAP Document 1331-34 Filed 01/05/24 Page 3 of 10
6 Home Mail News Sport flnance …
giuffre-maxwell
gov.uscourts.nysd.447706.1256.10
14 pg
…Case 1:15-cv-07433-LAP Document 1256-10 Filed 05/03/22 Page 11 of 14
Page 55
1 R. Rizzo - Confidential
2 And I blurted out: You're his
3 executive personal assistant? What do you
4 do…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…and she
22 said yes. So I said, what do you do? And
23 she says I'm Jeffrey's executive assistant,
24 personal assistant. Which, from looking at
25 her, just didn't seem to suit.
MAGNA9 LEGAL SERVICES…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…and she
22 said yes. So I said, what do you do? And
23 she says I'm Jeffrey's executive assistant,
24 personal assistant. Which, from looking at
25 her, just didn't seem to suit.
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.22_1
12 pg
…and she
22 said yes. So I said, what do you do? And
23 she says I'm Jeffrey's executive assistant,
24 personal assistant. Which, from looking at
25 her, just didn't seem to suit.
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.16_1
9 pg
…and she
22 said yes. So I said, what do you do? And
23 she says I'm Jeffrey's executive assistant,
24 personal assistant. Which, from looking at
25 her, just didn't seem to suit.
Page 55…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…has failed to appear for her
deposition. This failure is sufficient for a finding of contempt. See, e.g., Securities Investor
Protection Corp. v. Executive Secs. Corp., 433 F. Supp. 470, 474 (S.D.N.Y. 1977) (“The failure
of…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
…and she
22 said yes. So I said, what do you do? And
23 she says I'm Jeffrey's executive assistant,
24 personal assistant. Which, from looking at
25 her, just didn't seem to suit.
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.17
12 pg
…and she
22 said yes. So I said, what do you do? And
23 she says I'm Jeffrey's executive assistant,
24 personal assistant. Which, from looking at
25 her, just didn't seem to suit.
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.7
14 pg
…and she
22 said yes. So I said, what do you do? And
23 she says I'm Jeffrey's executive assistant,
24 personal assistant. Which, from looking at
25 her, just didn't seem to suit.
٧
56
1…