giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…489
U.S. 749, 763 (1989) (holding that an individual's interest in
nondisclosure of an FBI rap sheet was the sort of personal
privacy interest that Congress intended FOIA law enforcement
exemption to protect); see Menand, supra at 6…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…2006) (professional journalist waived the exemption
of the Shield Law if they voluntarily disclose or consent to disclosure of otherwise covered
information to third parties).
None of the documents or information described above is covered by the New York
Shield…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…hers. Your basis for that
belief is a disk you produced last week, obtained pursuant to a FOIA request, that contained at Page 2035 an
address book from approximately 2005 which has that earthlink account name next to Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…hers. Your basis for that
belief is a disk you produced last week, obtained pursuant to a FOIA request, that contained at Page 2035 an
address book from approximately 2005 which has that earthlink account name next to Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…a subpoena that (iii) requires
disclosure of privileged or other protected matter, if no
exception or waiver applies; or (iv) subjects a person to undue
burden." "The party issuing the subpoena must demonstrate that
the information sought is relevant and…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…documents.
8 Again, it has the seal and everything that is required. Your
9 Honor, it did come to us as a result of a FOIA request that we
10 sent. It is, your Honor, produced in accordance with how…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…a libel case, where
truth or falsity of the underlying statements is at issue. Yet Maxwell cannot point to any
authority for a wholesale “libel exception”—let alone a “plaintiff’s credibility exception” to the
Shield Law. Cf. In re…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…documents.
8 Again, it has the seal and everything that is required. Your
9 Honor, it did come to us as a result of a FOIA request that we
10 sent. It is, your Honor, produced in accordance with how…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…32 AM
Hi Jenna,
My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information
you are looking for because I am not able to release information (should there be any) from…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…e-
mail address for Defendant that Ms. Giuffre discovered when reviewing a FOIA production from
the Palm Beach County State Attorney’s Office relating to the police investigation of Jeffrey
Epstein. The undisclosed e-mail address for the Defendant was…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.4
35 pg
…32 AM
Hi Jenna,
My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information
you are looking for because I am not able to release information (should there be any) from…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…Defendant was on Epstein’s Palm Beach House bank account for Palm
Beach. Bates Number SAO FOIA disc 7 (bates Giuffre 007590) at p. 93-95.
2
Case 1:15-cv-07433-LAP Document 1219-22 Filed 07/15…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…Defendant was on Epstein’s Palm Beach House bank account for Palm
Beach. Bates Number SAO FOIA disc 7 (bates Giuffre 007590) at p. 93-95.
2
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.39
35 pg
…32 AM
Hi Jenna,
My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information
you are looking for because I am not able to release information (should there be any) from…
giuffre-maxwell
gov.uscourts.nysd.447706.363.9
5 pg
…02138
Hon. Louis J. Freeh
Mobile: 202.215.8321
[email protected]
January 22, 2016
RE: FOIA Reques…
giuffre-maxwell
1320-39
35 pg
…32 AM
Hi Jenna,
My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information
you are looking for because I am not able to release information (should there be any) from…
giuffre-maxwell
gov.uscourts.nysd.447706.749.0
9 pg
…Clinton at Jeffrey Epstein’s private island twice (Motion in Limine 2) ..... 8
3. FOIA responses and related materials are admissible (Motion in Limine 3)................... 8
4. Louis Freeh’s testimony and report are admissible evidence (Motion in Limine 4) ..…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…54. Ms. Giuffre’ entire account is fabricated out of whole cloth: President
Clinton was never on the island during the relevant period. A FOIA request submitted by
former FBI Director Louis Freeh for “all shift logs, travel records, itineraries, reports…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…said Dershowitz. “She
said she had dinner with Bill Clinton on the island twice, and we did a FOIA request and found that Bill
Clinton was never on the island. She said she met Al Gore on the island, and…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…54. Ms. Giuffre’ entire account is fabricated out of whole cloth: President
Clinton was never on the island during the relevant period. A FOIA request submitted by
former FBI Director Louis Freeh for “all shift logs, travel records, itineraries, reports…
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