giuffre-maxwell
gov.uscourts.nysd.447706.223.6
4 pg
…proceed with a VI deposition and to accept service
for that deposition. I understand the issue expressed below and will prgmptly communicate
with Ms Maxwell's counsel in order to determine her position.
Thanks, Marty
From: Sigrid McCawley
Sent: Thursday…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…at Exhibit 10, “All aboard the ‘Lolita Express’: Flight logs reveal the
many trips and Alan Dershowitz took on pedophile Jeffrey Epstein’s private jet with
anonymous women” at The Daily Mail, http://www.dailymail.co.uk/news/article-
2922773…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…Flight logs show that from 2001 to
2003, Bill Clinton flew on Epstein's private plane, dubbed "The Lolita Express" by the press, 26 times. After Epstein's arrest in July 2006,
federal tax records show Epstein donated $25,000…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.22_1
12 pg
…down and sat in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.16_1
9 pg
…in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was very nervous.
14 …
giuffre-maxwell
gov.uscourts.nysd.447706.1257.17
12 pg
…down and sat in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…delete it from your system. Please
be advised that the views and opinions expressed in this e-mail may not
reflect the views and opinions of Associated Newspapers Limited or any of
its subsidiary companies . We make every effort to…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…s 'lieutenant', 'flew on the lolita express
almost as many times as the disgraced couple'
Reports suggest that Ms Maxwell moved 36 times before her arrest last
week
By Ryan Fahey For Mailonline
Published: 20:46 EDT, 11 July 2020…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.24
4 pg
…have sued Dershowitz for defamation after he alleged they should be
disbarred for initially putting Roberts' allegations in court papers.
"I am happy today to express my willingness to be deposed after the three of them are deposed," he said…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.30
4 pg
…have sued Dershowitz for defamation after he alleged they should be
disbarred for initially putting Roberts' allegations in court papers.
"I am happy today to express my willingness to be deposed after the three of them are deposed," he said…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.41
4 pg
…have sued Dershowitz for defamation after he alleged they should be
disbarred for initially putting Roberts' allegations in court papers.
"I am happy today to express my willingness to be deposed after the three of them are deposed," he said…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.19
4 pg
…have sued Dershowitz for defamation after he alleged they should be
disbarred for initially putting Roberts' allegations in court papers.
"I am happy today to express my willingness to be deposed after the three of them are deposed," he said…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…12
proceedings (apparently, also forgetting the 23 flights she shared with Ms. Giuffre on Epstein’s
private jet,6 known colloquially as the “Lolita Express”7).
Police Detective Joseph Recarey, who led the investigation of Epstein, testified that
Defendant procured…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…and sat in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was very…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…and sat in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was very…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…her family's location,
19 things of that nature.
20 The witness has expressed to
21 me fears of harassment and the
22 belief that she's being followed,
23 and my understanding is that
24 there are other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.27
8 pg
…person described in and who executed the
foregoing instrument and acknowledged to and
17 before me that he executed the said instrument
in the capacity and for the purpose therein
18 expressed.
19
20 Witness my hand and official seal…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…a privilege log identifying any such privileged documents. Rule
45(e)(2)(A) requires as to any withheld document “subject to protection as trial-preparation
material,” a non-party witness must “(i) expressly make the claim; and (ii) describe the…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…Ms. Maxwell knew or believed might be known to Epstein.
5
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 8 of 27
The continued deposition was expressly limited to the above eight categories…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…a privilege log identifying any such privileged documents. Rule
45(e)(2)(A) requires as to any withheld document “subject to protection as trial-preparation
material,” a non-party witness must “(i) expressly make the claim; and (ii) describe the…
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