giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…are
among the best records of Plaintiff’s lies. They are public documents and there is no good faith
basis for Plaintiff’s attempt to render them hidden from public view, in her public lawsuit
designed to promote her well…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…Dustin Hoffman, Michael Bloomberg and Richard Branson.
Bill Clinton in 1994.
AP
ln a 2006 court filing, Palm Beach police noted that a search of Epstein's home uncovered two hidden
cameras. The Mirror reported that in 2015, a 6…
giuffre-maxwell
gov.uscourts.nysd.447706.885.0
7 pg
…Accordingly, not only did Defendant improperly withhold these documents, she also
improperly failed to disclose them on her privilege log. They were simply hidden.
3
The Requests to which these documents are responsive include, but are not limited to, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…are
among the best records of Plaintiff’s lies. They are public documents and there is no good faith
basis for Plaintiff’s attempt to render them hidden from public view, in her public lawsuit
designed to promote her well…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…1053 at 1. Neither Doe 1 nor
Doe 2 requested excerpts of the sealed materials that mention their names, and Maxwell has not
identified any compelling reason to continue to keep their identities hidden. In fact, Doe 1 and
Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…all emails—whether saved or deleted –
and irrespective of which account they came from; not a single responsive email was located
from any Mindspring account and no emails were located from Earthlink or any other secret,
hidden, “undisclosed” email account…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…Rankings ABOVE THE LAW LAWYER MARKETING LAWYER MARKETING
ABOVE THE LAW
Case 1:15-cv-07433-LAP Document 363-11 Filed 08/11/16 Page 8 of 40
6 comments
(hidden for your protection)
comments sponsored by
SHOW…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…all emails—whether saved or deleted –
and irrespective of which account they came from; not a single responsive email was located
-
from any Mindspring account and no emails were located from Earthlink or any other secret,
hidden, “undisclosed” email account…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…materials.” Brown, supra at 45. Although TGP is appreciative of the Court’s efforts to
unseal since that decision, the most crucial information that the public is demanding to know
remains hidden. Though it may be possible that, somehow, no…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…of 35
Page 106
1 sitting, and I believe Jeffrey took the photo. I
2 was just sitting on a couch upstairs in the
3 bathroom.
4 Q. It wasn't taken by a hidden camera?
5 A. No. No…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…discoverable, and was purposefully hidden by Plaintiff.
Any action short of precluding claims for physical, psychological and emotional distress
damages will fall short of serving Rule 37’s purpose to “ensure that a party will not benefit from
its own…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…they would take a screenshot
14 of a part of an e-mail. Another one would be hidden in the
15 screenshot and another one would be disclosed. So there are
16 obviously e-mails that are responsive to our…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…example, if Defendant were to testify at trial she had a
net worth of only ten million dollars – and not provide information about where she had hidden
the fifteen million dollars associated with the sale of her apartment – then Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…Dr. Donahue.
Additionally, Defendant acts in bad faith when she claims that medical records from Dr.
Donahue were “purposefully hidden by Plaintiff” (Mtn. at 11) when Defendant knows that Ms.
Giuffre executed and sent a medical release for Dr. Donahue…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…2016, Subpoenas to Churcher and Weissfeld.
Yet, Defendant cited a number of cases wherein discovery was buried amid voluminous
productions so as to be hidden or to cause delayed or cumbersome discovery of them. They are
inapposite. Defendant didn’t…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
… disclosed June 1
Shopper’s Paradise – subpoena notice April 26; never disclosed
How many other witnesses are there with relevant information that Plaintiff has hidden?
5
No ruling had been made on this Motion.
12
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…example, if Defendant were to testify at trial she had a
net worth of only ten million dollars – and not provide information about where she had hidden
the fifteen million dollars associated with the sale of her apartment – then Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…to relevant discovery.
7
Case 1:15-cv-07433-LAP Document 230 Filed 06/20/16 Page 11 of 19
It is completely unknown what other relevant and probative information will be
uncovered in Plaintiff’s previously hidden accounts…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…result
in an unmanageable number of documents. Instead, Defendant is picking and choosing which
documents she will produce, and which documents she will keep hidden. She’s not making this
determination based on responsiveness, or based on undue burden, but…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…Dr. Donahue.
Additionally, Defendant acts in bad faith when she claims that medical records from Dr.
Donahue were “purposefully hidden by Plaintiff” (Mtn. at 11) when Defendant knows that Ms.
Giuffre executed and sent a medical release for Dr. Donahue…
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