giuffre-maxwell
gov.uscourts.nysd.447706.1219.10
4 pg
…RWS
Ghislaine Maxwell’s Privilege Log Amended as of August 1, 2016
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
Log ID DATE DOC. BATES FROM …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.6
4 pg
…RWS
Ghislaine Maxwell’s Privilege Log Amended as of August 1, 2016
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
Log ID DATE DOC. BATES FROM …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.21
8 pg
…The Southern District of New York
Giuffre v. Maxwell
15-cv-07433-RWS
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
DATE D…
giuffre-maxwell
gov.uscourts.nysd.447706.27.1
3 pg
…Motion for Leave to Bring
Personal Electronic Devices and General Purpose Computing Devices into the Courthouse on
January 14, 2016. The following Order is subject to the definitions, obligations and restrictions
imposed pursuant to Standing Order M10-468, as Revised…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…Respondent(s) in this action.
At that time and place, you also shall produce the following items now in your custody or control:
See attached Schedule A ______
Names, addresses and telephone numbers of all counsel of record in this action…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…more efficiently without becoming unduly burdensome. The Original Parties therefore
present the following options to the Court.
Plaintiff’s Proposal
Plaintiff proposes beginning to address Non-Party objections in the next round of
unsealing, rather than first finishing the remaining…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…Plantation, Florida 33324-4413
(Name ofperson to whom this subpoena is directed)
~ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and to permit inspection…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.29
4 pg
…DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
…
giuffre-maxwell
gov.uscourts.nysd.447706.34.1
6 pg
…The Southern District of New York
Giuffre v. Maxwell 15-
cv-07433-RWS
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
TAB …
giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…including Prince Andrew, after moving to New York in 1991 following the death of her father on his
yacht.
According to the documents, a woman identified as Jane Doe 3 says Ms Maxwell asked her to visit Epstein’s
Florida…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.16
3 pg
…RWS
Ghislaine Maxwell’s Privilege Log Amended as of May 16, 2016
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
Log ID DATE DOC. BATES FROM …
giuffre-maxwell
gov.uscourts.nysd.447706.55.11
3 pg
…The Southern District of New York
Giuffre v. Maxwell
15-cv-07433-RWS
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
DATE D…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida
33301, within thirty (30) days of service hereof.
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
1. “Agent” shall mean any agent, employee, officer, director…
giuffre-maxwell
gov.uscourts.nysd.447706.363.9
5 pg
…MADE AGAINST PROFESSOR DERSHOWITZ
Professor Alan M. Dershowitz today issued the following statement regarding the results of the
independent investigation conducted by former FBI Director Louis Freeh of sexual misconduct
allegations made against Prof. Dershowitz.
STATEMENT OF PROFESSOR ALAN M…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…Giuffre, by and through her undersigned counsel, respectfully submits
the following authority for the application of the privilege claimed regarding her in camera
submission, pursuant to the Court’s Order [DE 134] dated May 2, 2016.1
ARGUMENT
Statements made…
giuffre-maxwell
1320-16
3 pg
…RWS
Ghislaine Maxwell’s Privilege Log Amended as of May 16, 2016
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
Log ID DATE DOC. BATES FROM …
giuffre-maxwell
1320-40
19 pg
…DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…3 and Jane Doe 4 as Petitioners (" Rule 15 Motion") ( DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…Civ. 7433 (RWS)
Plaintiff,
-against-
DECLARATION OF
GHISLAINE MAXWELL, ALAN M. DERSHOWITZ
Defendant.
ALAN M. DERSHOWITZ declares under penalty of perju…