giuffre-maxwell
gov.uscourts.nysd.447706.986.0
60 pg
…982. The parties met and conferred several times over the past two weeks,
and were able to reach agreement with the exceptions of Categories 4 and 10 below. Plaintiff
believes that all documents concerning trial deposition designations (including objections and…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…the March 31, 2020 telephone
conference, to identify the first five motions for the unsealing process. The Original Parties have
met and conferred multiple times to propose five motions pertaining to J. Doe 1 and J. Doe 2, as
identified…
giuffre-maxwell
gov.uscourts.nysd.447706.1006.0
1 pg
…2019 Order (DE 998), the parties have
met and conferred. The parties are in agreement as to all of the decided motions with the exception
of two motions.
The first motion in dispute is ECF 567 Defendant’s Motion in…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…ECF No. 1108. The Parties met and conferred on July 26, and discussed
ways in which the sealing process can proceed more efficiently. The Parties therefore present the
following options to the Court.
Plaintiff’s Proposal
At the July 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…Upon securing the
residence we met with the gentleman who identified himself to
Detective Recarey as the lawyer for the defendant and he was informed
that the residence was secured and that copies of the inventory return
had been left…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.1_1
7 pg
…2628241,
283, 08/09/2019, Filed 08/24/20
Page92Page
of 8832 of 7
Agren Blando Court Reporting & Video, Inc.
l think I met Prince Andrew in 2001. A…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…Upon securing the
residence we met with the gentleman who identified himself to
Detective Recarey as the lawyer for the defendant and he was informed
that the residence was secured and that copies of the inventory return
had been left…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.7
9 pg
…of Florida.
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 3 of 9
Page 30
1 Q. Did you observe her to be young when you
2 met her?
3 MS …
giuffre-maxwell
gov.uscourts.nysd.447706.1296.4
4 pg
…a Registered
Professional Reporter, Certified Realtime
Reporter and Notary Public within and
for the State of Florida.
Page 45
1 Q. And what -- do you recall any observations
2 about when you met her?
3 A. To speak with…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…ii
I. BACKGROUND .................................................................................................................1
II. ARGUMENT ......................................................................................................................6
A. Defendant Has Not Met Her Burden T…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.23
4 pg
…SERVICES
Case 1:15-cv-07433-LAP Document 1327-23 Filed 01/05/24 Page 3 of 4
Page 45
1 Q. And what -- do you recall any observations
2 about Jane Doe 2 when you met her?
3 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.3
7 pg
…A No, there's no more than one truth.
8 Q All right. So a document in which you
9 swore that you were 15 years old when you met
10 Ms. Ghislaine Maxwell is an untrue statement,
11 correct?…
giuffre-maxwell
1320-13
45 pg
…Upon securing the
residence we met with the gentleman who identified himself to
Detective Recarey as the lawyer for the defendant and he was informed
that the residence was secured and that copies of the inventory return
had been left…
giuffre-maxwell
gov.uscourts.nysd.447706.908.0
4 pg
…Defendant.
________________________________/
MOTION FOR ORDER DIRECTING THE FBI IN MIAMI, FLORIDA
TO PRODUCE PHOTOGRAPHS TO THE COURT
In 2011, the Federal Bureau of Investigation (“FBI”) met with Plaintiff Virginia Giuffre
at the United States Consulate in Sydney, Australia. During that meeting…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…for information related to your recovery as a victim of . The
process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
Best wishes,
Jason
-----Original Message---…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…produce
clear and convincing evidence of its falsity. ........................................................... 56
1. The January 2015 statement accurately denied that Ms. Maxwell met
Plaintiff when Plaintiff was 15 years old in 1999. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…they should not be served because they are not “a more practical
method of obtaining the information sought than a request for production or a deposition,” and
because they were served in advance of the period “30 days prior to…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Ms. Giuffre’s Confidential Communications With Her Attorneys Were Never “At
Issue” in the Florida Dershowitz Litigation....................................................................19
D. Defendant Has Not Met the Other Requirements for Showing Waiver of Attorney-
Cli…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…any kind, and, to my knowledge, I never
even met her until her deposition in 2016. By swearing to this, I am deliberately exposing
myself to a perjury prosecution and disbarment if I am not telling the truth. If Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1080.0
2 pg
…in her opinion, they were under-inclusive. The parties met
and conferred on July 29, and disagreed as to what constitutes “nonparties’ specific conduct”
requiring redaction. Plaintiff’s understanding of the Court’s order is that the documents are to…
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