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.447706.986.0
60 pg
…Court
500 Pearl Street
New York, NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-07433-LAP
Dear Judge Preska:
Plaintiff submits the following categories of documents pursuant to the Court’s Order of
September 5, 2019. Dkt. 982…
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.447706.1327.12
11 pg
…07433-LAP Document 1327-12 Filed 01/05/24 Page 2 of 11
Defendant Ghislaine Maxwell (“Ms. Maxwell”) respectfully files the following
Submission Concerning Search Terms and Notice of Compliance with Court Order regarding
Forensic Examination of Devices, as follows:
…
giuffre-maxwell
gov.uscourts.nysd.447706.130.0
5 pg
…Plaintiff, forthwith, to deliver any “materials” to
the Defendant for the following reasons:
For months Ms. Maxwell has been requesting documents from the Plaintiff relating to her
claim that there is an ongoing and active criminal investigation in which Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…date. Defendant represents to the Court that there is no
undisclosed email address, yet in the following sentence, she begins a three-page description of her
undisclosed email account on Epstein’s server that she says she cannot access. Accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…AKT)
TYPE OF CONFERENCE: DISCOVERY STATUS CONFERENCE
APPEARANCES: Plaintiff Paul C. Whalen
Defendant Eamon P. Joyce
FTR: 3:31-4:44
THE FOLLOWING RULINGS WERE MADE:
1. As a preliminary matter, the Court addressed Defendant’s motion for an inspection…
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.447706.363.9
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.447706.320.0
11 pg
…cv-07433-LAP Document 320 Filed 08/01/16 Page 2 of 11
Defendant Ghislaine Maxwell (“Ms. Maxwell”) respectfully files the following
Submission Concerning Search Terms and Notice of Compliance with Court Order regarding
Forensic Examination of Devices, as follows:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…07/15/21 Page 5 of 24
To: Ellmax, LLC
EXHIBIT A
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
1. “Plaintiff” in the above captioned action shall…
giuffre-maxwell
gov.uscourts.nysd.447706.124.0
3 pg
…for Forensic Examination (Doc. #96),
scheduled for April 28, 2016, for the following reasons:
Plaintiff filed her Motion for Clarification of Court’s Order and for Forensic
Examination on April 13, 2016.
On April 15, 2016, the Court scheduled a…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
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.447706.1100.1
13 pg
…be disclosed or distributed in any
form by the Defendant or her counsel except as set forth in
paragraph 1(d) below;
d) May be disclosed only by Defense Counsel and
only to the following persons (“Designated Persons”):
i. investigative…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…and on
July 8, 2016, counsel for Ms. Giuffre sent letters to Defendant following up on this Order and
proposing search terms (attached as exhibits to DE 279). Defendant did not respond. The July 11,
2016, deadline passed without any…
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.447706.1318.0
3 pg
…1313. On October 27, 2023, the Court entered the following
endorsement:
Doe 107 shall, by November 22, 2023, submit to the Court for in
camera review an affidavit supporting her assertion that she
faces a risk of physical harm in…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…subpoena demonstrates
that Defendant is not even seeking documents relevant to the matter before this Court, and is
instead attempting to obtain backdoor discovery for other actions.
Ms. Ransome’s responses are subject to the following qualifications, explanations, and
objections…