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.447706.1327.1
26 pg
…05/24 Page 2 of 26
**ROUGH***Deposition of Tony Figueroa*** ROUGH*** 1
1 UNCERTIFIED TRANSCRIPT DISCLAIMER IN THE MATTER OF
2 Virginia L. Giuffre
v.
3 Ghislaine Maxwell
4 The following transcr…
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.447706.17.1
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.447706.773.4
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.447706.435.0
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.447706.235.2
4 pg
…cv-07433-RWS
Sigrid,
Based on the Court’s rulings on April 21st, and your client’s deposition on May 3rd,
please provide the following documents on or before April 27th, 2016.
All documents withheld on the basis of…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…and allegedly took many of the pictures
displayed on the walls of Epstein’s mansions.
According to one witness, she felt ‘indebted’ to Epstein for helping her following the
mysterious death in 1991 of her father, disgraced tycoon Robert Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…received emails from Ms. Maxwell's various
email accounts, including but not limited to the following: (1) GMaxl @ellmax.com (and any
other accounts at ellmax.com); (2) gmax I (@mindspring.com (and any other accounts at
mindspring.com); (3…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…h;s subpoena is directed}
,6
Production: YOt; ARE CO.M MANDED to produce at t he time, date, a11d place set forth below the following
doc11mcnls, elec tTOnil.:ally stored informatfon, or objects. and to permit i nspection, copying…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…SERVICE
I certify that on February 6, 2017, I electronically served this NOTICE OF SERVICE OF
RULE 45 SUBPOENA AND NOTICE OF DEPOSITION OF SA.RAH RANSOME via Email on
the folJowing:
Sigrid S. McCawley Paul G. Cassell
Meridith Schultz …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.13
13 pg
…emails from Ms. Maxwell's various
email accounts, including but not limited to the following: (1) (and any
and any other accounts at
(3) any of Ms. Maxwell's email account associated with The Terramar Proj…
giuffre-maxwell
gov.uscourts.nysd.447706.156.0
3 pg
…OF SERVICE
I certify that on May 20, 2016, I electronically served this Declaration Of Laura A.
Menninger In Support Of Motion To Compel Non-Privileged Documents via ECF on the
following:
Sigrid S. McCawley Paul G. Cassell
Meridith Schultz …
giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…in sex acts ~ith Jeffrey Epstein, through a variety of
means and methods, including but not limited to the following:
a. MAXWELL first attempted to befriend some of
Epstein's minor victims prior to their abuse, including by
asking the…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…him with other females or discussing
other individuals who may have been involved with this activity.
3. Request No. 6: All documents relating to communications with any of the
following individuals from 1999 – present: Emmy Taylor, Sarah Kellen, Eva Dubin…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…01/04/24 Page 13 of 21
capacity. Ms. Maxwell proffers the following clear and specific showing establishing each of
these elements, requiring production of the information sought and deposition of Churcher.
A. The Information Sought from Churcher is Highly…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…her deposition, Defendant indicated that she lacked
recollection of or was otherwise unable to specifically answer the following questions:
Whether Defendant observed a female under the age of 18 at Jeffrey Epstein’s home in
Palm Beach. See McCawley…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Ransome to sit for additional questions. The following are
18
the categories of deposition testimony that Defendant seeks for which non-party Ms. Ransome
contends are sought only for the purpose of harassment and intimidation:
Current paycheck records and…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.34
10 pg
…Ransome
Sent
H~llo Sarah! lhe following is from Jeffrey
Archive
I'm surprised I haven't heard from you.
Spam (123)
Trash
v Smart views
Important
Unread Lesley Groff
Executive Assistant to Jeffrey E…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…example, at her deposition, Defendant indicated that she lacked
recollection of or was otherwise unable to specifically answer the following questions:
! Whether Defendant observed a female under the age of 18 at Jeffrey Epstein’s home in
Palm Beach. See…