giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a. A a multi-story private residence on the
Upper East Side of…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…with
1
Case 1:15-cv-07433-LAP Document 1256-16 Filed 05/03/22 Page 6 of 30
Case 1:15-cv-07433-LAP Document 1256-16 Filed 05/03/22 Page 7 of 30
in multiple locations…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…of 30
Case 1:15-cv-07433-LAP Document 1198-5 Filed 01/27/21 Page 6 of 30
Case 1:15-cv-07433-LAP Document 1198-5 Filed 01/27/21 Page 7 of 30
in multiple locations…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…old girl to his employer’s home who, in utmost distress,
told him that Defendant stole the young girl’s passport and tried to make her have sex with
1
in multiple locations. So she and her legal counsel have…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…of 30
Case 1:15-cv-07433-LAP Document 1198-12 Filed 01/27/21 Page 6 of 30
Case 1:15-cv-07433-LAP Document 1198-12 Filed 01/27/21 Page 7 of 30
in multiple locations…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…the Court’s order, Ms. Giuffre effected alternative
service of a subpoena to testify at a deposition on Ms. Kellen in multiple ways, all calculated to
give her actual notice of the subpoena. See Schultz Decl. at Composite Exhibit 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
giuffre-maxwell
1320-33
24 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
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.447706.1332.17
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.447706.1320.8
12 pg
…Here, Ms.
Giuffre has diligently attempted to make personal service on each of the three individuals,
having made multiple attempts to personal service them, including going to different locations at
different times on different days, and attempting to reach them…
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.447706.1327.5
17 pg
…for Jeffrey. And then she told me about how, like I said, her and Ms. Maxwell and Jeffrey
were all intimate together on multiple occasions.”
x See Schultz Decl. at Composite Exhibit 3, Excerpts of June 21, 2016, Deposition of…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…on French
servers and not housed in such places G-mail or Skype which have co-locations for information
which may be found outside of European servers.
Defendant’s counsel maintains that his client has assured him that all remaining…
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.447706.1218.12
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
1320-8
12 pg
…Here, Ms.
Giuffre has diligently attempted to make personal service on each of the three individuals,
having made multiple attempts to personal service them, including going to different locations at
different times on different days, and attempting to reach them…
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