giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…abuse suffered by Ms. Giuffre and others at the hands of
Maxwell, and should not be withheld. Moreover, flight logs demonstrate that Sarah Kellen and
Maxwell flew together multiple times, including with Ms. Giuffre. See McCawley Decl. at
Exhibit 4…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…24 Page 9 of 31
abused numerous underage girls in his Florida mansion, his New York mansion, and several
other places that Dershowitz apparently admits he visited on multiple occasions.
In 2009, one of Epstein’s household employees, Juan Alessi…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…it was with Ms. Maxwell, it was in his bedroom.
21 "Q. Ms. Maxwell, what -- you're naming the locations where the
22 book was kept; correct?
23 "A. Yes, at Ms. Maxwell's desk."
24 And that's in…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…the high-security
Metropolitan Detention Center in Brooklyn
on £4 million bail, arguing that her life is in
danger from coronavirus and ‘multiple and
credible’ death threats.
Maxwell, who is a long-time friend of Prince Andrew and who saw…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…witness should be entitled to rely upon the enforceability of a protective order
against any third parties.’” In this case, the parties and multiple other deponents
have relied on this Court’s Protective Order in giving testimony and producing
documents . …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…notice anything to my
20 law office for Virginia. She's had some safety
21 issues with respect to her location so we're not
22 going to be putting that on the record.
23 MS. BORJA: That's fine…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…negations:
MS. MCCAWLEY: Your Honor, if the intent here is to continue to spew the
confidential settlement negotiations and have Dershowitz go to New York or other
locations to say these things again, I would object to that. I think…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…the reason was that “[m]ultiple individuals have placed you in the presence of
Jeffrey Epstein on multiple occasions and in various locations when Jeffrey Epstein was in the
13
Case 1:15-cv-07433-LAP
Case 9:08…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…notice anything to my
20 law office for Virginia. She's had some safety
21 issues with respect to her location so we're not
22 going to be putting that on the record.
23 MS. BORJA: That's fine…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…s terms.
D. Plaintiff Must Produce Medical Records and Releases
Defendant has requested, multiple times and in multiple ways, information concerning
any medical and mental health treatment that Plaintiff has received for the period prior to, during
and subsequent to…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…21 Page 9 of 31
abused numerous underage girls in his Florida mansion, his New York mansion, and several
other places that Dershowitz apparently admits he visited on multiple occasions.
In 2009, one of Epstein’s household employees, Juan Alessi…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…including Mr Malcolm Jones, Mr Poynter, and others
from locations in the UK, France and Belgium. It states inter alia that the Buncefield
D
explosion had many similarities to an explosion which occurred at Saint Herblain
near Nantes …
giuffre-maxwell
gov.uscourts.nysd.447706.957.0
13 pg
…motion. Doc.892. Among
other things, the Court found that “the parties and multiple deponents have reasonably relied on
the Protective Order in giving testimony and producing documents including evidence of assault,
medical records, and emails.” Id. at 6. Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…Document 185-8 Filed 06/01/16 Page 7 of 24
certain specific locations, among other allegations of criminal conduct by Dershowitz.6 Giuffre
subsequently submitted multiple sworn affidavits repeating the allegations against Dershowitz,
which likewise have been stricken from…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…COMMANDED lo permit entry on to the designated premises, land, or
other property possessed or contro l led by you at the l ime, date, and location set forth below. so Lhal lhc ,·cquesling party
rnay inspect, measure, survey, photograph…
giuffre-maxwell
gov.uscourts.nysd.447706.193.0
14 pg
…Edwards and Cassell Waived Any Work Product Protection .......................................... 9
V. Edwards and Cassell are Conflicted Because of Their Multiple Roles – Plaintiff’s Choice
to Present Their Testimony at Trial not Relevant to the Waiver Issue.............................. 10
CERTIFICATE OF SERVICE…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…with Prince Andrew. Plaintiff was well paid for this picture,
and continued to get royalties on the reprints. Despite multiple requests, Plaintiff has not been
able to produce or provide the actual native version of the picture, or identify the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…specifically identify persons or documents, to provide information concerning who prepared
documents, the location of any copies of such documents, the identities and contact information
for persons who have custody or control of such documents, the reasons for inability to…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…for
the subpoenaing party.
2. This Request calls for the production of all responsive Documents in your possession,
custody or control without regard to the physical location of such documents.
3. If any Document was in your possession or control…
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