giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…September
2001. Additionally, the Pew Research Center published findings that certain demographics have
higher internet usage, including many demographics to which Defendant belongs. For example,
higher rates of internet usage are found among younger adults (Defendant was 38 in 1999…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…academicians.” Id. As Mr. Cassell is well aware, Jeffrey Epstein was heavily
involved in funding academic research at Harvard and kept an office there,3 and he was
consequently friendly with many academics, including David Gergen, Marvin Minsky, Larry
Summers…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…September
2001. Additionally, the Pew Research Center published findings that certain demographics have
higher internet usage, including many demographics to which Defendant belongs. For example,
higher rates of internet usage are found among younger adults (Defendant was 38 in 1999…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…Palm Beach County State Attorney’s Office, Public Records Request
No.: 16-268, Disc 7 (GIUFFRE007590) at Page 2305. Upon finding this undisclosed email
accounts, the undersigned sent a follow-up letter to Ms. Menninger, stating: “please include a
search…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…mind’; and
(3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…September
2001. Additionally, the Pew Research Center published findings that certain demographics have
higher internet usage, including many demographics to which Defendant belongs. For example,
higher rates of internet usage are found among younger adults (Defendant was 38 in 1999…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…mind’; and
(3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…academicians.” Id. As Mr. Cassell is well aware, Jeffrey Epstein was heavily
involved in funding academic research at Harvard and kept an office there,3 and he was
consequently friendly with many academics, including David Gergen, Marvin Minsky, Larry
Summers…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…mind’; and
(3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…REQUEST NO. 37
From January 2012 to the present, produce all documents concerning any source of
funding for the TarraMar Project or any other not-for-profit entities with which You are
associated, including but not limited to, funding received…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…based on
8
As Mr. Cassell is well aware, Jeffrey Epstein was heavily
involved in funding academic research at Harvard and kept an office there,3 and he was
consequently friendly with many academics, including David Gergen,…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF VIRGINIA GIUFFRE’S MOTION FOR FINDING
OF CIVIL CONTEMPT AGAINST SARAH KELLEN
FOR IGNORING SUBPOEN…
giuffre-maxwell
gov.uscourts.nysd.447706.311.0
3 pg
…Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF VIRGINIA
GIUFFRE’S MOTION FOR FINDING OF CIVIL CONTEMPT AGAINST NADIA
MARCINKOVA FOR IGNORING SUBPOENA AND FOR ASSOCIATED SANCTIONS…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…and between (c) defense counsel with joint defense or common interest
privileges concerning obtaining or receiving 'local police[] findings or opinions’ and ‘statements
1
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 3…