giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…the following words and phrases have the following
meanings:
1. “Plaintiff” in the above captioned action shall mean the plaintiff Virginia Giuffre
formerly known as Virginia Roberts.
2. “Defendant” in the above captioned action shall mean the defendant Ghislaine
Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…xMitrovich
J
- I
xMullen
xPagano
xPaluga
xPeadon
xPritzker
xPreece
xRabuyo
xRizzo
xRobson
xRoss (surname of Adriana)
xMucinska (former surname of Adriana)
xSjoberg
xSpamm
-
xStein (surname of Cecilia)
xValdes (surname of Cresenda)
xVazquez
xValenzuela
xVisosky
xWexner
xWild (surname…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…and I traveled to 6791 Fairway Lakes
Drive in Boynton Beach, Florida in hopes to interview Juan Alessi, the
former houseman of Epstein's home. As no one was home, a business
card was left for him to return my…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…and I traveled to 6791 Fairway Lakes
Drive in Boynton Beach, Florida in hopes to interview Juan Alessi, the
former houseman of Epstein's home. As no one was home, a business
card was left for him to return my…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…television or movie deals
concerning Your allegations about being a sex slave, including but not limited to a potential book
by former New York Police Department detective John Connolly and writer James Patterson.
32. All manuscripts and/or other writings…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…her coming
forward. She has 3 young children and a husband and has concerns about
whether she is compromising their well-being .
I am a former investigative reporter for New York Magazine where my
colleagues included Nick Pileggi . I understand…
giuffre-maxwell
1320-13
45 pg
…and I traveled to 6791 Fairway Lakes
Drive in Boynton Beach, Florida in hopes to interview Juan Alessi, the
former houseman of Epstein's home. As no one was home, a business
card was left for him to return my…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…25. Also in April 2016, I released the results of a thorough investigation led by former
FBI Director and federal judge Louis Freeh, which found that “the totality of the evidence”
“refutes the allegations made against” me by Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.689.0
42 pg
…of
privilege were admissible evidence in that case. The Second Circuit adopted the rational that the
ex-employees’ refusal to testify could be appropriately conceptualized “as vicarious admissions
of their former employer.” LiButti, 107 F.3d at 121 (citing Robert…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…City, UT 84112
401 East Las Olas Boulevard, Ste. 1200 [email protected]
Ft Lauderdale, FL 33301
[email protected]
[email protected]
Bradley J. Edwards
FARMER, JAFFE, WEISSING, EDWARDS,
FISTOS & LEHRMAN, P.L.
42S North Andrews Ave., Ste…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.9
4 pg
…Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies Schiller & Flexner LLP
333 …
giuffre-maxwell
gov.uscourts.nysd.447706.1094.3_2
14 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S
MOTION IN LIMINE TO EXCLUDE FBI 302 STATEMENT OF PLAINTIFF
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.17_1
4 pg
…Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies Schiller & Flexner LLP
333 …
giuffre-maxwell
gov.uscourts.nysd.447706.1090.24
4 pg
…Blvd., Suite 1200
Ft. Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies Schiller & Flexner LLP
333 …
giuffre-maxwell
gov.uscourts.nysd.447706.881.0
8 pg
…States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF MS. GIUFFRE’S PROPOSED JURY QUESTIONS
…
giuffre-maxwell
gov.uscourts.nysd.447706.919.0
2 pg
…P. 4l(a)(l)(A)(ii), this action shall be
DISMISSED WITH PREJUDICE, with each party to bear its own attorneys' fees and costs.
Dated: May 24, 2016 Respectfully Submitted,
FARMER, JAFFE, WEIS SING
…
giuffre-maxwell
gov.uscourts.nysd.447706.1094.2_2
15 pg
…L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S
MOTION IN LIMINE TO EXCLUDE REFERENCES TO
“CRIME VICTIMS’ RIGHTS ACT” LITIGATI…
giuffre-maxwell
gov.uscourts.nysd.447706.86.0
3 pg
…of Florida and there are no pending
disciplinary proceedings against me in any state or federal court.
Dated: April 7, 2016 Respectfully Submitted,
/s/ Bradley J. Edwards
Bradley J. Edwards (Seeking Pro Hac Vice)
…
giuffre-maxwell
gov.uscourts.nysd.447706.731.0
3 pg
…TO
EXCLUDE FBI 302 STATEMENT OF PLAINTIFF
I, Bradley Edwards, declare that the below is true and correct to the best of my
knowledge as follows:
1. I am a Partner with the law firm of Farmer, Jaffe, Weissing, Edwards…
giuffre-maxwell
gov.uscourts.nysd.447706.916.0
2 pg
…P. 41(a)(1)(A)(ii), this action shall be
DISMISSED WITH PREJUDICE, with each party to bear its own attorneys' fees and costs.
Dated: May 24, 2016 Respectfully Submitted,
FARMER, JAFFE, WEISSING
EDWARDS, F…
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