giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…TABLE OF CONTENTS
INTRODUCTION .......................................................................................................................... 1
ARGUMENT .................................................................................................................................. 2
I. CHURCHER IS A MATERIAL FACT WITNESS …
giuffre-maxwell
gov.uscourts.nysd.447706.24.2
2 pg
…release
Become a client Search Regulatory News Search
For journalists Products & Ser…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…Specifically, I seek to
unseal portions of a brief (the “Reply Brief”) and certain emails (the “Emails”) that were
submitted in connection with a motion to quash a testimonial subpoena directed to British tabloid
journalist Sharon Churcher, and a draft…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
… If it helps, have your attorney write a suggested column-
oriented item re your case and if it's written in 'journalistic style,' Colin and I can pop it off to Emily, as a possible piece f,
her renowned Page…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…Ms. Maxwell does not believe that searching these terms is appropriate, because, for example,
the names include a journalist (Vicky Ward), Mr. Epstein’s elderly secretary, and various
business people that form part of Plaintiff’s false narrative regarding her…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…correspondent, columnist, writer, commentator, investigative journalist,
11
Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 13 of 48
photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any
media organization or…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Ms. Maxwell does not believe that searching these terms is appropriate, because, for example,
the names include a journalist (Vicky Ward), Mr. Epstein’s elderly secretary, and various
business people that form part of Plaintiff’s false narrative regarding her…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…correspondent, columnist, writer, commentator, investigative journalist,
11
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 13 of 48
photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any
media organization or…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…Ms. Maxwell does not believe that searching these terms is appropriate, because, for example,
the names include a journalist (Vicky Ward), Mr. Epstein’s elderly secretary, and various
business people that form part of Plaintiff’s false narrative regarding her…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…Attorneys have had with any
author, reporter, correspondent, columnist, writer, commentator, investigative journalist,
photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any
media organization or independent consultant to the same, including:
a. the date of any such…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…e-
mails, text messages, instant messages, videotapes, photographs, notes, letters, memoranda,
forms, books, magazines, resumes, notebooks, ledgers, journals, diaries, calendars, appointment
books, papers, agreements, contracts, invoices, analyses, transcripts, plaques, correspondence,
telegrams, drafts, data processing or computer di…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…not as a journalist.
Page 3 of 69 GIUT-T RE003700
CONFIDENTIAL
Case 1:15-cv-07433-LAP Document 1325-2 Filed 01/04/24 Page 5 of 70
I am sure you understand that it has been a…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…Attorneys have had with any
author, reporter, correspondent, columnist, writer, commentator, investigative journalist,
photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any
media organization or independent consultant to the same, including:
a. the date of any such…
giuffre-maxwell
1320-37
48 pg
…correspondent, columnist, writer, commentator, investigative journalist,
11
Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 13 of 48
photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any
media organization or…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…Ms. Maxwell does not believe that searching these terms is appropriate, because, for example,
the names include a journalist (Vicky Ward), Mr. Epstein’s elderly secretary, and various
business people that form part of Plaintiff’s false narrative regarding her…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…correspondent, columnist, writer, commentator, investigative journalist,
11
Case 1:15-cv-07433-LAP Document 235-3 Filed 06/21/16 Page 13 of 48
photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any
media organization or…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…to
testify at a deposition in a civil action and produce documents (the “Subpoena”) in this case.
PRELIMINARY STATEMENT
Sharon Churcher’s involvement in this defamation case stems entirely from the fact that,
in her capacity as a professional journalist…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…ready to pounce with voice recorders and cameras in hand. In recent months,
journalists have searched high and low for Maxwell, who had already been
maintaining a low profile even before the Epstein scandal came roaring back to life
this…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…Virginia Roberts), whether or
not they reference her by name. This request includes, but is not limited to, all
communications, diaries, journals, calendars, blog posts (whether published or
not), notes (handwritten or not), memoranda, mobile phone agreements, wire
transfer receipts…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…k/a Virginia Roberts), whether or
not they reference her by name. This request includes, but is not limited to, all
communications, diaries, journals, calendars, blog posts (whether published or
not), notes (handwritten or not), memoranda, mobile phone agreements, wire
…