giuffre-maxwell
gov.uscourts.nysd.447706.733.0
3 pg
…Virginia L. Giuffre,
Plaintiff,
Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S
RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION IN LIMINE TO EXCLUDE
VICTIM NOTIFICATI…
giuffre-maxwell
gov.uscourts.nysd.447706.1124.0_3
2 pg
…v. Maxwell, Case No. 15-cv-7433-LAP
Dear Judge Preska,
Plaintiff writes in response to Defendant’s letter dated September 30, 2020, seeking
clarification from the Court regarding Doe 1 and Doe 2’s communication to the Court. ECF…
giuffre-maxwell
gov.uscourts.nysd.447706.1098.0
2 pg
…The Honorable Loretta A. Preska
District Court Judge
United States District Court for the
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: INTERVENORS’ LETTER IN RESPONSE TO COURT’S AUGUST 4, 2020
ORDER (DKT. 1097)
…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…Maxwell, Case No. 1:15-cv-07433-LAP
Dear Judge Preska:
On behalf of non-party Doe 171, we file this letter motion for extension of the
stay pending appeal that Your Honor ordered on November 19, 2022, (Dkt.
No…
giuffre-maxwell
gov.uscourts.nysd.447706.1102.0_1
2 pg
…The Honorable Loretta A. Preska
District Court Judge
United States District Court for the
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: INTERVENORS’ LETTER IN RESPONSE TO MAXWELL’S LETTER
(DKT. 1100)
Giuffre v. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.6
4 pg
…of Services
Laura,
I am writing to follow up on my June 13, 2016, letter and my June 14, 2016 email (attached), where I requested that you
provide me with your proofs of service for the subpoenas you issued in…
giuffre-maxwell
gov.uscourts.nysd.447706.1292.0
2 pg
…Case No. 1:15-cv-07433-LAP
Dear Judge Preska:
Doe 171 writes to respectfully request a status conference in front of Your
Honor regarding her December 5, 2022 Letter Motion (Doc. 1285) and the
December 7, 2022 Responses by…
giuffre-maxwell
gov.uscourts.nysd.447706.239.1
11 pg
…Edwards and Ms. McCawley -
As I informed Ms. McCawley in my June 9, 2016 letter, I represent Jeffrey Epstein with
respect to the Rule 45 subpoena. Marty Weinberg represents Mr. Epstein in Does.
Neither June 17 nor June 28 is…
giuffre-maxwell
gov.uscourts.nysd.447706.443.0
4 pg
…4
address.
On August 3, 2016, Ms. Giuffre applied to this Court for a Letter Rogatory in order to
initiate a separate action in the United Kingdom to compel Mr. Gow to comply with the
subpoena. On August 11, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.828.0
3 pg
…a true and correct copy of Paul G. Cassel,
Esq.’s Curriculum Viate.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of the July 20, 2010
Victim Notification Letter addressed to Farmer, Jaffe, Weissing, Edwards…
giuffre-maxwell
gov.uscourts.nysd.447706.311.0
3 pg
…07433-LAP Document 311 Filed 07/25/16 Page 2 of 3
2016 email to Nadia Marcinkova and July 11, 2016 letters to Nadia Marcinkova.
7. Attached hereto as Exhibit 5 is a true and correct copy of July 8…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…island in the U.S. Virgin Islands.
25. All documents concerning your retention of the law firm Boies, Schiller & Flexner LLP,
including but not limited to: signed letter of retainer, retention agreement, explanation of
fees, and/or any documents describing…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…production. Ms. Giuffre is withholding documents based on her objections.
4. All Documents reflecting any letter of engagement, any fee agreement, or
any other type of writing reflecting an engagement of any attorney identified in
response to Interrogatory No. 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…is retired. We produced the letter we sent her as well as a
document indicating the practice was closed at GIUFFRE005335-
GIUFFRE0005338.
18
Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 20 of 48
!…
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.447706.1078.5
161 pg
…161
Along with Farmer’s remarks, Assistant U.S. Attorney Alison Moe read from a letter
written by another of Maxwell’s alleged victims, who asked to be identified only as Jane
Doe. It’s possible that the woman may…
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.447706.1335.1
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.…
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