giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…Hi Jenna,
My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information
you are looking for because I am not able to release information (should there be any) from FBI
records…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.9
5 pg
EXHIBIT F
Search Terms Defendant Has Already Searched
From Plaintiff’s June 30th proposed list:
(note: Plaintiff’s numbers have been used)
1) jef*
2) geof*
3) epst! !n*
4) jeevacation*
5) j* w/2 *jep*
6) j* w…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…cv-07433-LAP Document 1327-18 Filed 01/05/24 Page 2 of 5
Search Terms Defendant Has Already Searched
From Plaintiff’s June 30th proposed list:
(note: Plaintiff’s numbers have been used)
1) jef*
2) geof*
3) epst…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.2
12 pg
…12/12/22 Page 1 of 12
Case 1:15-cv-07433-LAP Document 1295-2 Filed 12/12/22 Page 2 of 12
hundreds of young girls who came and went from the home she shared with Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…LAP Document 1327-17 Filed 01/05/24 Page 1 of 6
EXHIBIT E
Case 1:15-cv-07433-LAP Document 1327-17 Filed 01/05/24 Page 2 of 6
From: Meredith Schultz
Sent: Wednesday…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
… Case 1:15-cv-07433-LAP Document 1328-40 Filed 01/05/24 Page 2 of 3
To: Marianne Strong[[email protected]]
From: Virginia Giuffre
Sent: Fri 2/21/2014 1:17:22 PM
Importance: Normal
Subject: Re…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…filed her Reply in Support of her Motion to Exceed the Presumptive Ten Deposition
Limit (DE 203). This brief contained excerpt from Rinaldo Rizzo’s “rough” deposition transcript, as the final
transcript had not yet been completed by the stenographer…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…behalf of our client, Ghislaine Maxwell, we write to request that the Court enter an
order prohibiting the Government, its agents and counsel for witnesses from making extrajudicial
statements concerning this case. Although Ms. Maxwell is presumed innocent, the Government,…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…In addition, Defendant set her deposition for Friday,
February 17, 2017 giving this witness less than two (2) weeks notice to make travel
arrangements from Europe. Despite these obstacles, non-party Ransome complied by producing
over 235 pages of highly…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…v. :
:
GHISLAINE MAXWELL,
:
:
Defendant.
:
…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 824 Filed 04/03/17 Page 2 of 47 2
H3GVGIUC
1 THE COURT: First order of business from me, have you
2…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…she was being held captive
Asked other women if they knew anyone 'slutty' to bring to Epstein
Would allegedly use cash she gained from sex to live a luxury lifestyle
By Wills Robinson For Dailymail.com
Published: 12:49 EDT…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…HARASSING THIS NON-PARTY
WITNESS REQUEST 10 (CURRENT PASSPORT/CURRENT VISAS):......................17
III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL
DEPOSITION QUESTIONS THAT ARE SOLELY MEANT TO EMBARRASS,
INTIMIDATE AND HARASS THIS NON-PARTY...............................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…Laura,
I write pursuant to this Court' s June 20, 2016, Order regarding search and production
from Defendant's electronic media. Accordingly, please use IMAP Capable software (or a
functional equivalent) to capture all of the sent/received emails from…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…and Motion for the Court to Direct
Defendant to Disclose All Individuals to whom Defendant has Disseminated Confidential
Information (DE 335).
I. INTRODUCTION
“The nature of this case concerns highly personal and sensitive information from both
parties. In this action…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…HARASSING THIS NON-PARTY
WITNESS REQUEST 10 (CURRENT PASSPORT/CURRENT VISAS):......................17
III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL
DEPOSITION QUESTIONS THAT ARE SOLELY MEANT TO EMBARRASS,
INTIMIDATE AND HARASS THIS NON-PARTY...............................................…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 31 Filed 01/28/16 Page 2 of 22 2
G1ETGIUA
1 (In open court)
2 THE COURT: I will hear from the movant.
3 MS…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…filed her Reply in Support of her Motion to Exceed the Presumptive Ten Deposition
Limit (DE 203). This brief contained excerpt from Rinaldo Rizzo’s “rough” deposition transcript, as the final
transcript had not yet been completed by the stenographer…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…Ms. Giuffre filed her Reply in Support of her Motion to Exceed the Presumptive Ten Deposition
Limit (DE 203). This brief contained excerpt from• · • • • "rough" deposition transcript, as the final
transcript had not yet been completed by the stenographer. On…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…Paul
Callan, Chris Cuomo, Ana Cabrera
GUESTS: Wendy Murphy
HIGHLIGHT:
Friday night, seven-year-old Sailor Gutzler freed herself from the upside down
wreckage of her family's plane, moving past the bodies of her mother, father, sister
and cousin…
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