giuffre-maxwell
gov.uscourts.nysd.447706.686.0
17 pg
…Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF MS. GIUFFRE’S MEMORANDUM OF LAW IN
SUPPORT OF HER MOTION IN LIMINE TO PRESENT
ALL EVIDENCE OF DEFENDANT’S INVOLVEMENT IN
EPSTEIN SEXUAL ABUSE AND SEX TRAFFICKING
…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.1
2 pg
…THE DUE
PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE
GOVERNMENT’S SUBPOENA TO AND TO DISMISS COUNTS
FIVE AND SIX
(Pretrial Motion # 3)
PLEASE TAKE NOTICE that, upon the accompanying memorandum of law and
exhibits, Defendant Ghislaine Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.3
7 pg
… My husband and I were pretty spiritual people
2 and we believed that these memories were worth
3 burning.
4 Q So you burned notes of the men with whom
5 you had sex while you were represented by counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.749.0
9 pg
…7).................................................................................................................................... 14
8. Plaintiff’s drug use is relevant to her memory and lack of damages (Motion in Limine
8)........................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…behalf of
another.
4. “Correspondence” or “communication” shall mean all written or verbal
communications, by any and all methods, including without limitation, letters, memoranda,
and/or electronic mail, by which information, in whatever form, is stored, transmitted or
received; and…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…another.
2. "Con-espondence" or "communication'' shall mean all ·written or verbal
communicalions, by any and all methods_, including without limitation, letters, memoranda,
and/or electronic mail, by which information, in whatever form, is stored, transmitted or
received: and, includes…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…behalf of
another.
2. "Correspondence" or "communication" shall mean all written or verbal
communications, by any and all methods, including without limitation, letters, memoranda,
and/or electronic mail, by which information, in whatever form, is stored, transmitted or
received; and…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…behalf of
another.
2. "Correspondence" 01' "communlcation" shall mean all written or verbal
communications, by any and all methods, including without limitation, letters, memoranda,
and/or electronic mail, by which information, in whatever form, is ston;:d, transmitted or
received…
giuffre-maxwell
1320-30
27 pg
…Q What is the date the photograph was
11 printed?
12 A I believe it's in March 2001.
13 Q Okay.
14 A But that's just off of my photographic
15 memory. I don't -- it could be…
giuffre-maxwell
1320-32
27 pg
…behalf of
another.
2. "Correspondence" or "communication" shall mean all written or verbal
communications, by any and all methods, including without limitation, letters, memoranda,
and/or electronic mail, by which information, in whatever form, is stored, transmitted or
received; and…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.30
27 pg
…Q What is the date the photograph was
11 printed?
12 A I believe it's in March 2001.
13 Q Okay.
14 A But that's just off of my photographic
15 memory. I don't -- it could be…
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