giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…07433-LAP Document 1286
1285 Filed 12/05/22 Page 1 of 6
December 5, 2022 Counsel for Plaintiff, Defendant, and the
Herald shall submit letter responses, if
VIA CM/ECF any, by December 7, 2022.
The Honorable Loretta A…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…NY 10007
[email protected]
Re: Giuffre v. Maxwell,
Case No.: 15-cv-07433-RWS
Dear Judge Sweet,
This is a reply letter in support of Ms. Giuffre's letter motion to allow for the newly-
discovered wi lness…
giuffre-maxwell
gov.uscourts.nysd.447706.1323.0
2 pg
…Loretta A. Preska
District Court Judge
United States District Court
Southern District of New York
500 Pearl Street
New York, New York 10007
Re: INTERVENOR ALAN DERSHOWITZ’S LETTER MOTION
TO UNSEAL DOCKET ENTRY 1026-3
Giuffre v. Maxwell, Case…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…7 the status of the case with respect to these issues?
8 THE COURT: Certainly. If you feel you want to. I
9 have your letters.
10 MS. McCAWLEY: Okay.
11 THE COURT: But, whatever you want to do. Sure.
…
giuffre-maxwell
gov.uscourts.nysd.447706.235.2
4 pg
… All fee agreements, retainer agreements, and letters of engagement for any
attorney listed on Plaintiff’s privilege log and “Identification Information from
Privilege Log for Plaintiff’s First Production.” See Resp. to RFP 4.
Ms. Giuffre’s deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…97 is mentioned in nine documents.5 They are either excerpts of deposition transcripts,
Rule 26 disclosures, or letters regarding search terms and productions. Doe 97’s objection is that
(1) they have never met anyone referenced in the excerpts…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…than by motion.” Dkt. 1034 at 3. Plaintiff agreed
with that approach, Dkt. 1038 at 1, and Maxwell did not address that request in her separate letter,
Dkt. 1037. At the March 31, 2020, hearing, the Court indicated that it…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…me. When he first
made these claims with, for example my firm, we wrote him a letter that said, ‘Put up or shut up, bring these
claims to court or move on.’ ”
Dershowitz issued a statement following Boies’s comments…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…See
McCawley Decl. at Exhibit 4, May 26, 2016 Letter from Sigrid McCawley.
2
Case 1:15-cv-07433-LAP Document 1307-4 Filed 08/25/23 Page 7 of 28
Ghislaine Maxwell. Therefore, Ms. Giuffre is now required…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.29
5 pg
…Beautiful girl. Very talented.
12 MR. BERGER: Did she put her initials or did 12 That's the only girl that I know that it
13 she just put a number or a letter? 13 was -- T would says, underage…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…Q. Under that it says, Thank you. I 15 Mar-a-Lago?
16 have it now and I'm working on a letter, a 16 A. It does not.
17 little, I will send the final version 17 Q. So…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
… Under that it says, Thank you. I
16 have it now and I'm working on a letter, a
17 little, I will send the final version
18 tomorrow and what ever it is will be
19 factually accurate.
20…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…See
McCawley Decl. at Exhibit 4, May 26, 2016 Letter from Sigrid McCawley.
2
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 7 of 28
Ghislaine Maxwell. Therefore, Ms. Giuffre is now required…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
… Under that it says, Thank you. I
16 have it now and I'm working on a letter, a
17 little, I will send the final version
18 tomorrow and what ever it is will be
19 factually accurate.
20…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.42
5 pg
…Beautiful girl . Very talented.
12 MR. BERGER: Did she put her initials or did 12 That's the only girl that I know that it
13 she just put a number or a letter? 13 was -- I would says, underage.…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…is Exhibit 1 to our brief
11 on this matter.
12 We wrote a letter to opposing counsel citing some
13 governing provisions of Microsoft's email policy that indicates
14 that due to inactivity they delete accounts after a…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
… Under that it says, Thank you. I
16 have it now and I'm working on a letter, a
17 little, I will send the final version
18 tomorrow and what ever it is will be
19 factually accurate.
20…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…BE LIABLE TO SATISFY A PART
OR ALL OF A JUDGMENT
Ms. Maxwell’s AIG Homeowners and Excess Liability insurance policies.
Coverage has been denied by AIG, as their letter of April 18, 2016 to Ms.
Maxwell, copied to Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…See
McCawley Decl. at Exhibit 4, May 26, 2016 Letter from Sigrid McCawley.
2
Case 1:15-cv-07433-LAP Document 1137-12 Filed 10/22/20 Page 7 of 28
Ghislaine Maxwell. Therefore, Ms. Giuffre is now required…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…your
8 Honor. That is just black-letter law on privilege. There was
9 no basis for asserting that privilege during the deposition,
10 and we would ask her to be deposed and answer the questions
11 related to that…
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