giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…that it seeks information protected by the attorney client and work product
privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the
subject nature of this litigation.
8. Identify the individuals referenced…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…that it seeks information protected by the attorney client and work product
privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the
subject nature of this litigation.
8. Identify the individuals referenced…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…serving party tangible things in a manner that, without revealing information itself
may move the court for the district where compliance is required for an privileged or protected, will enable the parties to assess the claim.
order compelling production or…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…due to holding both
French and British passports, she has the ability to 'live beyond the reach of extradition
indefinitely'.
Prosecutor Moe argued: 'She is good at living under an assumed identity. There really
can be no question that she…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…that it seeks information protected by the attorney client and work product
privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the
subject nature of this litigation.
8. Identify the individuals referenced…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…protected by the attorney-client privilege, the attorney work
product privilege, joint defense/common interest privilege, the public interest privilege, and any
other applicable privilege. Ms. Giuffre objects in that this request is overly broad and unduly
burdensome.
6. Identify…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…protected by the attorney-client privilege, the attorney work
product privilege, joint defense/common interest privilege, the public interest privilege, and any
other applicable privilege. Ms. Giuffre objects in that this request is overly broad and unduly
burdensome.
6. Identify…
giuffre-maxwell
1320-37
48 pg
…that it seeks information protected by the attorney client and work product
privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the
subject nature of this litigation.
8. Identify the individuals referenced…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…that it seeks information protected by the attorney client and work product
privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the
subject nature of this litigation.
8. Identify the individuals referenced…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…that it seeks information protected by the attorney client and work product
privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the
subject nature of this litigation.
8. Identify the individuals referenced…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…APPEAR AND RESPOND . 10
IV. MS. RANSOME MUST BE REQUIRED TO PRODUCE REPONSIVE DOCUMENTS
THAT HAVE BEEN WITHELD WITHOUT BASIS, AND IDENTIFY ANY OTHER
DOCUMENTS WITHELD ................................................................................................... 12
CONCLUSION .............................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…10
IV. MS. RANSOME MUST BE REQUIRED TO PRODUCE REPONSIVE DOCUMENTS
THAT HAVE BEEN WITHELD WITHOUT BASIS, AND IDENTIFY ANY OTHER
DOCUMENTS WITHELD ................................................................................................... 12
CONCLUSION ..................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…Such documents do not even require extensive review as they are protected by privilege,
and can be categorically logged pursuant to the Local Rules and governing case law.3 Therefore,
there is no merit to Defendant’s burden claim.
Moreover…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…r entification Information (Fingerprints, palm
Information
1'19.071 (2)(e) Confession
3€>!5.171 (15) Identity of 911 reports are confidential for period of 60 days after
seHvice
1 'I …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…1331.
2. Plaintiff files this Complaint under a pseudonym in order to protect
her identity because this Complaint makes allegations of a sensitive sexual nature
and disclosure of Plaintiffs name publicly will cause firther harm to her.
3. At all…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…10th Avenue
Denver, Colorado 80203
Tel: (303) 831-7364
Email: [email protected]
Defendant in this action.
CONFIDENTIAL as to victims' identity
…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…Parties will be reluctant to participate in
this process if their objection will itself become publicized and also believes that despite best
redaction efforts and pseudonym efforts, any objections may reveal the identity of its author.
For those reasons, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave
Rodgers to authenticate his pilot logs and the identity of the individuals on various flights.
In addition, as the Court knows, this case involves allegations that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…another purpose, such as proving motive, opportunity, intent, preparation, plan,
knowledge, identity, absence of mistake, or lack of accident.”). Indeed, even more specifically
than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
… . : 1-05-000368 (Continued)
the previous houseman left . Rodriguez stated that it was his
responsibility to keep the identity of the masseuses private. Mr.
Epstein had a massage in the morning and one in the afternoon. Mr.
Rodriguez stated he…