giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…clearly asked solely for the purpose of
embarrassing, intimidating and harassing a non-party already fearful for her safety and life based
upon the abuse she suffered at the hands of Defendant and Epstein, abuse as to which she
testified…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…re
11 seeking information to be able
12 to -- the witness has already
13 expressed fear about her --
14 people currently going after her.
15 So we would object to that
16 intimidation of a nonparty
17 witness.
18 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…re
11 seeking information to be able
12 to -- the witness has already
13 expressed fear about her --
14 people currently going after her.
15 So we would object to that
16 intimidation of a nonparty
17 witness.
18 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…asserts, without factual or legal support, that her financial
information is being sought “for the purpose of harassment and intimidation.” Because Ms.
Ransome failed to address the relevance argument asserted by the Motion, this issue should be
deemed admitted. Compare…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…...........................................15
II. DEFENDANT’S SUBPOENA SEEKS DOCUMENTS SOLELY FOR THE
PURPOSE OF INTIMIDATING AND HARASSING THIS NON-PARTY
WITNESS REQUEST 10 (CURRENT PASSPORT/CURRENT VISAS):......................17
III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL
DEPO…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…asserts, without factual or legal support, that her financial
information is being sought “for the purpose of harassment and intimidation.” Because Ms.
Ransome failed to address the relevance argument asserted by the Motion, this issue should be
deemed admitted. Compare…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…...........................................15
II. DEFENDANT’S SUBPOENA SEEKS DOCUMENTS SOLELY FOR THE
PURPOSE OF INTIMIDATING AND HARASSING THIS NON-PARTY
WITNESS REQUEST 10 (CURRENT PASSPORT/CURRENT VISAS):......................17
III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL
DEPO…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…re
11 seeking information to be able
12 to -- the witness has already
13 expressed fear about her --
14 people currently going after her.
15 So we would object to that
16 intimidation of a nonparty
17 witness.
18 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…documents
pursuant to Local Civil Rule 26.2(c).
Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…documents
pursuant to Local Civil Rule 26.2(c).
Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…documents
pursuant to Local Civil Rule 26.2(c).
Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…documents
pursuant to Local Civil Rule 26.2(c).
Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…substantial payout, directly from the Clinton Foundation to keep her quiet.
She is 1000% certain that the FBI did a cover up and she has the individual names of Hilary’s
Special Agent Officers involved in intimidating her. She was…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…documents
pursuant to Local Civil Rule 26.2(c).
Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
giuffre-maxwell
1320-37
48 pg
…documents
pursuant to Local Civil Rule 26.2(c).
Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…documents
pursuant to Local Civil Rule 26.2(c).
Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…documents
pursuant to Local Civil Rule 26.2(c).
Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…