giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…cv-07433-LAP Document 1327-18 Filed 01/05/24 Page 2 of 5
Search Terms Defendant Has Already Searched
From Plaintiff’s June 30th proposed list:
(note: Plaintiff’s numbers have been used)
1) jef*
2) geof*
3) epst…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…were taken from the room. See the
completed property receipt for a detailed list.
A green bathroom located on the first floor was searched and nothing
was taken.
A closet located just west of the green bathroom was searched. Two
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…were taken from the room. See the
completed property receipt for a detailed list.
A green bathroom located on the first floor was searched and nothing
was taken.
A closet located just west of the green bathroom was searched. Two
…
giuffre-maxwell
1320-13
45 pg
…were taken from the room. See the
completed property receipt for a detailed list.
A green bathroom located on the first floor was searched and nothing
was taken.
A closet located just west of the green bathroom was searched. Two
…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…2003, New York magazine reported that Trump also attended a dinner party at
Epstein's honoring Bill Clinton.
Last year, The Guardian reported that Epstein's "little black book" contained contact numbers for A-
list…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…Apr.
21, 2016 at 24). Moreover, Plaintiff ignores the fact that she has listed communications from
some agency to her lawyers on her deficient privilege log. These communications are not
statements by Plaintiff or statements by her lawyers. Nevertheless, Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…documents relating to your travel to or from locations for those occasions when you
allege you were present with Alan M. Dershowitz.
13. To the extent not produced in response to the above list of requested documents, all
notes, writings…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…and produce relevant documents until completion.
Ms. Giuffre incorporates her above-listed general objections in the responses herein.
4
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 6 of 40
INTERROGATORIES
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
…MS. EZELL:
13 BY MS. EZELL: 13 Q. And did Ms. Maxwell have a list of the
14 Q. Were they similar to the pictures that 14 girls who came to give massages?
15 Ms. Kellen had on her computer…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…copies of the police reports and disclosed
them to Plaintiff. Indeed, the Sheriff’s Office completed and provided a form with a list of state
requirements regarding redaction and, consistent with their practice, checked the box indicating
1
Plaintiff also…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…produce relevant documents until completion.
4
Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 6 of 48
Ms. Giuffre incorporates her above-listed general objections in the responses herein.
INTERROGATORIES
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…produce relevant documents until completion.
4
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 6 of 48
Ms. Giuffre incorporates her above-listed general objections in the responses herein.
INTERROGATORIES
…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…and produce relevant documents until completion.
Ms. Giuffre incorporates her above-listed general objections in the responses herein.
4
Case 1:15-cv-07433-RWS Document 71-2 Filed 03/23/16 Page 6 of 45
INTERROGATORIES
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…issue, including
Plaintiff’s whereabouts during 1998-2002 and Plaintiff’s damages.
44. Peter Listerman
Address unknown at this time
Telephone number unknown at this time
Mr. Listerman may have knowledge concerning Plaintiff’s false claims against
Defendant.
45. Tony…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…from the organization, and any Documents
reflecting Your role within the organization or any acts taken on behalf of the Organization.
34. To the extent not produced in response to the above list of requested Documents,
all notes, writings, photographs…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…in Martindell, the Government could easily
leverage its investigatory powers in part because it had already
been provided with a list of witnesses who had testified in the
relevant civil action. See 594 F.2d at 293 (“At Judge Conner…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…on the merits of any particular unsealing request,
the parties and the Court need clarity on the universe of “undecided motions.” The parties should
first be tasked with compiling and submitting a list of those undecided motions to this Court…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…and produce relevant documents until completion.
Ms. Giuffre incorporates her above-listed general objections in the responses herein.
4
Case 1:15-cv-07433-LAP Document 76-1 Filed 03/31/16 Page 6 of 45
INTERROGATORIES
…
giuffre-maxwell
1320-37
48 pg
…produce relevant documents until completion.
4
Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 6 of 48
Ms. Giuffre incorporates her above-listed general objections in the responses herein.
INTERROGATORIES
…
giuffre-maxwell
1320-40
19 pg
…issue, including
Plaintiff’s whereabouts during 1998-2002 and Plaintiff’s damages.
44. Peter Listerman
Address unknown at this time
Telephone number unknown at this time
Mr. Listerman may have knowledge concerning Plaintiff’s false claims against
Defendant.
45. Tony…
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