giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…agent who she refused to produce
for a deposition, despite him being her agent and despite their sharing the same attorney, forcing Ms.
Giuffre to litigate the issue in the London courts, against Defendant’s counsel, and at significant
expense…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…is photographic evidence of Prince
Andrew with his arm around Virginia’s waist, standing next to Maxwell, in Maxwell’s London
residence, when Virginia was a minor child. In the one email defendant did produce in Response
to the Requests…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…Prince Andrew Albert Christian Edward, Duke of York
Buckingham Palace Rd, London SW1A 1AA
Tel: 020 7766 7300
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein’s sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
24. Jeffrey…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…Defendant has documents responsive to this request that she should produce.
8. All photographs or video of You in any of Ms. Maxwell’s properties,
including her home in London, England and her home in New York City, New York…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…and for that she has attracted
more media attention. London’s tabloid the Sun placed a “£10,000 bounty on
Maxwell’s head, dangling its checkbook to encourage anyone with information on her
whereabouts to come forward.”1 Vanity Fair…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…whose systems they were generated. News Corp UK
& Ireland Limited is the holding company for the News UK group,
is registered in England & Wales under number 81701, has its
registered office at 1 London Bridge Street, London, SEl 9GF and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…London EC2M 7DT tel +44 (0)20 7628 7576 fax +44 (0)20 7256
7318
3
PRIVILEGED GM_001057
GM_01071
…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…in the book, and she states that "from 1997 to 2001, she
12 was employed in London and then New York as an assistant to
13 Ghislaine Maxwell." Numerous other public sources, including
14 unsealed portions of Ms. Maxwell's…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…in the book, and she states that "from 1997 to 2001, she
12 was employed in London and then New York as an assistant to
13 Ghislaine Maxwell." Numerous other public sources, including
14 unsealed portions of Ms. Maxwell's…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…copy).
8. All photographs or video of You in any of Ms. Maxwell’s properties, including
her home in London, England and her home in New York City, New York. To the extent You
have such photographs or video in…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…as a review of Defendant’s interactions with several of the important players
in this case makes clear.
i. Ross Gow
The Court will recall that Ross Gow is Defendant’s London-based press agent, who
shares Defendant’s attorney…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…Mail.com (Jan. 13, 2015),
http://www.dailymail.co.uk/news/article-2908852/Teen-diary-belonging-woman-claims-
underage-sex-Prince-Andrew-reveals-explicit-details-night-London.html (last accessed March
20, 2016).
11
persisting in any particular privilege, (c)…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…Defendant has documents responsive to this request that she should produce.
8. All photographs or video of You in any of Ms. Maxwell’s properties,
including her home in London, England and her home in New York City, New York…
giuffre-maxwell
gov.uscourts.nysd.447706.76.2
21 pg
…Prince Andrew Albert Christian Edward, Duke of York
Buckingham Palace Rd, London SW1A 1AA
Tel: 020 7766 7300
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein’s sexual trafficking
conduct and interaction with underage minors, including Virginia Giuffre.
24. Jeffrey…
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