giuffre-maxwell
gov.uscourts.nysd.447706.34.2
3 pg
…who are
sharing connections, ideas, and opportunities.
• See who you know in common
• Get introduced
• Contact Ross directly
Experience
Owner, Managing Partner
ACUITY Reputation
January 2010 – Present (6 years 2 months)
ACUITY advises Governments, Corporates and UHNWIs on reputational issues…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
…him to England to
20 Q. Rodriguez stated Epstein did not want to 20 introduce him to the royalty.
21 see or hear the staff when he was in the 21 Q. Is it's your understanding that Ghislaine
22 …
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…1:15-cv-07433-LAP Document 1073 Filed 07/01/20 Page 2 of 22
Introduction
This Court asked the parties to brief three issues: “(a) the weight of presumption of
public access that should be afforded to an item…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…relate solely to five-year-old discovery disputes and therefore, at most,
begin with a presumption of public access “somewhat lower than the presumption applied to
material introduced at trial, or in connection with dispositive motions such as motions for…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…Jeffrey Epstein, a financier who was accused of soliciting sex workers and having
inappropriate sexual conduct with underage girls, was a client of mine. I first was introduced to
Mr. Epstein by a friend, Lynn Forester de Rothschild, in 1997…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…I Defendant Ghislaine Maxwell ("Ms. Maxwell") hereby submits this Motion for Sanctions
I Based on Plaintiffs Intentional Destruction of Evidence and further states as follows:
I INTRODUCTION
In 2013 , after Plaintiff was in the process of attempting to join the…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Epstein, who was not a defendant. She tried to do so by seeking to introduce
evidence wholly irrelevant to her defamation claim. See Doc.991 at 6-7. Plaintiff claims not to
5
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…AND FOREMAN, P.C.
East 10th Avenue
Denver, CO 80203
303.831.7364
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…NY 10504
Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 2 of 40
TABLE OF CONTENTS
TABLE OF CONTENTS.....................…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…also has not explained to this
Court any legally relevant or admissible evidence that either possess, nor how she intends to
introduce that evidence in a trial of this defamation claim between Plaintiff and Ms. Maxwell.
Apart from these witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
… The court reporter is Deborah
18 Harris, both from Esquire Deposition Solutions.
19 Would counsel please introduce yourselves and your
20 affiliation and the witness will be sworn in.
21 MS. MCCAWLEY: My name is Sigrid McCawley.
22 I'm…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…315, 320, & 335, and states as
follows:
Introduction
Ms. Maxwell submits this Memorandum of Law in support of her objection to the
unsealing of her July 22, 2016 deposition testimony, any excerpts of that testimony and any
pleadings that quote…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…Skype, if possible. We feel that a video-conference would
up a Skype account with user name Wende [email protected].
be a better way for us to introduce ourselves to you. Wende has set
…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…Armonk, NY 10504
Case 1:15-cv-07433-LAP Document 1137-14 Filed 10/22/20 Page 2 of 40
TABLE OF CONTENTS
TABLE OF CONTENTS............................................................................................................................... i
TABLE OF AUTHORITIES ...........…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
… The court reporter is Deborah
18 Harris, both from Esquire Deposition Solutions.
19 Would counsel please introduce yourselves and your
20 affiliation and the witness will be sworn in.
21 MS. MCCAWLEY: My name is Sigrid McCawley.
22 I'm…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…a Southern District of New York case, similarly holds
19 FBI records like the one that we are seeking to introduce are
20 entered into evidence under this public records exception.
21 So let's take a look at it. …
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…a Southern District of New York case, similarly holds
19 FBI records like the one that we are seeking to introduce are
20 entered into evidence under this public records exception.
21 So let's take a look at it. …
giuffre-maxwell
1320-28
32 pg
…AND FOREMAN, P.C.
East 10th Avenue
Denver, CO 80203
303.831.7364
…
giuffre-maxwell
1320-18
40 pg
…NY 10504
Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 2 of 40
TABLE OF CONTENTS
TABLE OF CONTENTS.....................…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
…
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