giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…internal quotations omitted).
B. “Ancillary” court submissions. A court’s authority to oversee discovery and control
the evidence introduced at trial is ancillary to the court’s core role in adjudicating a case.
Brown, 929 F.3d at 50. Accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…It accepts
no liability for viruses introduced by this e-mail or attachments.
News Corp UK & Ireland Limited and its titles are committed to abiding by
IPSO's regulations and the Editors' Code of Practice that IPSO enforces.
Ross Gow…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…No. . . : 1-05- 000368 (Continued)
introduced himself as Jeff. l■■•advised she recalled she and
removed their clothing down to their panties, Epstein lay on his
stomach area and they provided a massage on his legs and feet area. I…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…No. . . : 1-05- 000368 (Continued)
introduced himself as Jeff. l■■•advised she recalled she and
removed their clothing down to their panties, Epstein lay on his
stomach area and they provided a massage on his legs and feet area. I…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…which I have managed to save. They include the
following:
I moved from Edinburgh to
New York in September 2006, where shortly after I was introduced to Jeffery Epstein by Natalie.
. A couple months later, after he constantly stalked me…
giuffre-maxwell
1320-13
45 pg
…No. . . : 1-05- 000368 (Continued)
introduced himself as Jeff. l■■•advised she recalled she and
removed their clothing down to their panties, Epstein lay on his
stomach area and they provided a massage on his legs and feet area. I…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…there's
12 a good-faith basis.
13 Q. Did you approach Alan
14 Dershowitz for the purpose of seeking
15 legal advice?
16 A. I was introduced to Alan.
17 Q. By whom?
18 A. Jeffrey Epstein.
19 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
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.447706.1325.2
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.447706.441.0
18 pg
… INTRODUCTION
O n M ay 3,2016,M s.Giu ffre satthrou ghafu lld ay of d eposition.
.A s the C ou rtknows,M s.Giu ffre
also agreed to sitforasecond d eposition,bu trequ ested certain limitations from…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…MORGAN, AND FOREMAN, P.C.
East 10th Avenue
Denver, CO 80203
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Court Order regarding
Forensic Examination of Devices, as follows:
INTRODUCTION
Defense counsel has already run the amended list of search terms proposed by Plaintiff
on each applicable device and as to each email account to which Ms. Maxwell has access…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…the Court should allow Ms. Giuffre to question Defendant in a deposition about these
late produced communications.
I. INTRODUCTION
As the Court is well aware, Ms. Giuffre has alleged that Defendant defamed her when she
called her a liar after…
giuffre-maxwell
gov.uscourts.nysd.447706.110.0
7 pg
…Avenue
Denver, CO 80203
303.831.7364
Case 1:15-cv-07433-LAP Document 110 Filed 04/21/16 Page 2 of 7
INTRODU…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Gee
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
…
giuffre-maxwell
gov.uscourts.nysd.447706.64.0
14 pg
…AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
303.831.7364
…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…MORGAN, AND FOREMAN, P.C.
East 10th Avenue
Denver, CO 80203
303.831.73…
giuffre-maxwell
gov.uscourts.nysd.447706.841.0
6 pg
…hereby files her Reply in
Support of the Objection to the Production of Documents1 Submitted in camera and states as
follows:
INTRODUCTION
1
Case 1:15-cv-07433-LAP Document 841 Filed 04/11/17 Page 3 of 6
2…
giuffre-maxwell
gov.uscourts.nysd.447706.806.0
6 pg
…and
further states as follows:
INTRODUCTION
ARGUMENT
1
Case 1:15-cv-07433-LAP Document 806 Filed 03/28/17 Page 3 of 6
2
Case 1:15-cv-07433-LAP Document 806 Filed 03/28/17 Page 4 of…
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