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.447706.648.0
4 pg
…23/17 Page 2 of 4
The Parties, through their respective counsel, propose the following case management
deadlines and request that the Court enter an order modifying its Order of October 3, 2016, ECF
#455 for the following reasons:
Subsequent…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
… AND UNSEAL
ALAN M. DERSHOWITZ declares under penalty of perjury that the following
is true and correct:
1. I am personally familiar with the facts set forth in this Reply Declaration,
which I submit in further support of my pending…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
… AND UNSEAL
ALAN M. DERSHOWITZ declares under penalty of perjury that the following
is true and correct:
1. I am personally familiar with the facts set forth in this Reply Declaration,
which I submit in further support of my pending…
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.447706.1320.16
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.447706.223.2
7 pg
…April 07, 2016 12:01 PM
To: Martin Weinberg
Subject: RE: Giuffre v. Maxwell
No -I can wait until tomorrow. Thank you for following up.
Sigrid
Sigrid S. McCawley·
Partner
BOIES, SCHILLER & FLEXNER LLP
401 East Las Olas Blvd., Suite…
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.447706.1327.16
6 pg
…Meredith:
I write to confirm our oral conferral. Please let me know if you disagree with the following or if there is some other
agreement you think we reached:
1. I will endeavor to have my client gain access to…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.4
4 pg
…DISCLOSURES
Pursuant to F.R.C.P. 26(a)(l)(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
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.447706.773.4
5 pg
…is on a list of witnesses for trial in a Palm Beach
lawsuit that pits billionaire pedophile Jeffrey Epstein against a Fort
Lauderdale attorney who represents Epstein’s victims.
The case appears bound for trial this summer following a Feb…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.565.0
4 pg
…Defendant.
____________________________/
PLAINTIFF’S OBJECTIONS TO DEFENDANT’S DEPOSITION DESIGNATIONS
AND PLAINTIFF’S CROSS DESIGNATIONS
Plaintiff Virginia Giuffre, hereby submits the following objections to Defendant’s
Deposition Designations and submits the following cross designati…
giuffre-maxwell
gov.uscourts.nysd.447706.455.0
4 pg
…451 Filed 09/30/16 Page 2 of 4
The Parties, through their respective counsel, propose the following discovery and case
management deadlines and request that the Court enter an order modifying its Order filed
October 30, 2015 , ECF #13 …