giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…production on February 8, 2016. All documents identified as responsive were reviewed by
counsel and either produced or placed on a privilege log. The First Responses were the subject
of litigation in March and April 2016. This Court limited the…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Ms. Maxwell has access. Based
on those searches, not one single additional responsive and non-privileged document has been
identified. Ms. Maxwell’s original search for responsive documents was complete at the time it
was conducted in February 2016. The…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…Upon securing the
residence we met with the gentleman who identified himself to
Detective Recarey as the lawyer for the defendant and he was informed
that the residence was secured and that copies of the inventory return
had been left…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…Upon securing the
residence we met with the gentleman who identified himself to
Detective Recarey as the lawyer for the defendant and he was informed
that the residence was secured and that copies of the inventory return
had been left…
giuffre-maxwell
gov.uscourts.nysd.447706.303.0
13 pg
…33. She strenuously argues that she has
“disclosed” various treatment providers because their names are buried in records that she has
belatedly produced and which she obtained only after defense counsel had identified their
existence and absence through independent investigation…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.25_1
13 pg
…33. She strenuously argues that she has
“disclosed” various treatment providers because their names are buried in records that she has
belatedly produced and which she obtained only after defense counsel had identified their
existence and absence through independent investigation…
giuffre-maxwell
1320-13
45 pg
…Upon securing the
residence we met with the gentleman who identified himself to
Detective Recarey as the lawyer for the defendant and he was informed
that the residence was secured and that copies of the inventory return
had been left…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…Ms. Maxwell has access. Based
on those searches, not one single additional responsive and non-privileged document has been
identified. Ms. Maxwell’s original search for responsive documents was complete at the time it
was conducted in February 2016. The…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Court of the 15th Cir. for Palm Beach County) ("Epstein v. Edwards"). The
Supplemental responses also identified the pleadings, discovery responses and depositions in
twenty-four civil proceedings in which Dersbowitz's client, Jeffrey Epstein, is named as a party…
giuffre-maxwell
gov.uscourts.nysd.447706.1290.0
3 pg
…cv-7433-LAP
Dear Judge Preska:
Intervenors Julie Brown and Miami Herald Media Co. respectfully submit this letter to
oppose Doe 171’s – whom this Court has identified as Emmy Tayler – letter motion to reconsider
regarding unsealing, dated December 5…
giuffre-maxwell
gov.uscourts.nysd.447706.27.1
3 pg
…General Purpose Computing Device
Case 1:15-cv-07433-LAP Document 27-1 Filed 01/11/16 Page 3 of 3
The attorney(s) identified in this Order must present a copy of this Order when entering
the Courthouse…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…therein.
I. BACKGROUND
In a March 21, 2016, meet-and-confer call, Defendant’s counsel specifically referenced
certain police reports wherein Ms. Giuffre was identified as a victim. On April 14, 2016, Ms. Giuffre
issued requests for production, seeking the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.25
4 pg
…UT 84112
(801) 585-52022
2
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…sexual contact ever took place
between the pair as "false and hurtful to me."
Interview request
The woman, identified by Buckingham Palace as Virginia Roberts, first named the prince in a civil motion filed
December 30 in the U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s Interrogatories
are based on information currently known to her and are given without waiving Ms. Maxwell’s
right to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…relief as to Doe 28).
Based on the information available to us, Doe 171’s requested relief pertains to at
most 13 of the of the 29 documents that this Court unsealed, identified as the
“Confidential Records”—namely, Doc. Nos…
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…motion also does not directly address the Court’s sound and obvious reason for unsealing,
which is that numerous public sources, including a federal complaint she herself voluntarily filed,
have already identified her, and described her relationship with Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1042.0
2 pg
…And, Ms. Maxwell’s proposed language
stating that Non-Parties “will not be identified in any court filing” is misleading. After the
objections are considered, it is likely that Non-Parties will be identified because the public interest
in disclosure…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…and other witness testimony contradict Plaintiff’s
deposition ......................................................................................................................... 5
E. Plaintiff identified new witnesses in her Rule 26 disclosures after her deposition .......... 6
II. PLAINTIFF’S COUNSEL IN…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.22
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
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