giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…pictured below, is the executive producer of a film starring2 none
other than Alan Dershowitz3:
Online film promotions claim the following:
Indeed, a clip of Dershowitz’s starring role in the film is featured by its promotional website:4
2…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…150 East 10th Avenue
Denver, CO 80203
Tel: 303.831.7364
Dated: November 30, 2015
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…including subparts, in
violation of Rule 33.
Ms. Giuffre objects to Defendant’s Second 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, work…
giuffre-maxwell
gov.uscourts.nysd.447706.75.0
31 pg
…to disclose her address under Local Rule 26.1 ...................... 8
VI. PLAINTIFF’S SUBSTANTIVE OBJECTIONS ARE UNRECOGNIZED AND
MERITLESS ................................................................................................................. 9
A. Plaintiff’s privilege claims are not cognizable. ...............…
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.447706.1328.4
40 pg
…other interrogatories, exceed the allowable
twenty-five interrogatories. Ms. Giuffre objects in that it seeks information
protected by the attorney-client privilege, work product protections, and any other
applicable privilege or protection as stated in the General Objections.
Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…1 at 5), while simultaneously
submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed
that these pages were “privileged” for various reasons, attaching an abbreviated privilege log.
Jane Doe No. 1 and Jane No…
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.447706.1256.10
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.447706.1200.16_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.447706.1256.7
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…according to court papers.
iJane Doe No. 3" also alleged that she had been forced to have sex with "numerous prominent
American politicians, powerful business executives, a well-known prime minister, and other world
leaders."
"We uncovered a lot of…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…Paris, the south of France, and California.
Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men,
including numerous prominent American politicians, powerful business executives, foreign
presidents, a well-known Prime Minister, and other world leaders…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…Ghislaine Maxwell.3 Here, the plaintiff sued Maxwell over her denial
of “allegations of sexual abuse by several other prominent individuals, ‘including numerous
prominent American politicians, powerful business executives, foreign presidents, a well-known
Prime Minister, and other world leaders…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…and as young as twelve, in a
trafficking ring that involved some of the most powerful people in America and around the world, including • numerous
prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other
…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…Paris, the south of France, and California.
Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men,
including numerous prominent American politicians, powerful business executives, foreign
presidents, a well-known Prime Minister, and other world leaders…
giuffre-maxwell
1320-9
10 pg
…Paris, the south of France, and California.
Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men,
including numerous prominent American politicians, powerful business executives, foreign
presidents, a well-known Prime Minister, and other world leaders…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…Mr. Epstein, and how Mr. Epstein
sexually trafficked her to several high-profile non -parry individuals, " including numerous
prominent American politicians, powerful business executives, foreign presidents, a well- known
Prime Minister, and other world leaders." ( Id. at 3- 6). She…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.5
12 pg
…book manuscript differs in dramatic respects from her CVRA joinder motion.
In the Joinder Motion, Plaintiff alleged she was trafficked “to many other powerful men,
including numerous prominent American politicians, powerful business executives, foreign
presidents, a well-known Prime Minister…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…Paris, the south of France, and California.
Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men,
including numerous prominent American politicians, powerful business executives, foreign
presidents, a well-known Prime Minister, and other world leaders…
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