giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…Preska
November 16, 2019
Page 3
numbers,” and “the names of alleged minor victims of sexual abuse from deposition
testimony and police reports, as well as deposition responses concerning intimate
matters where the questions were likely only permitted—and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
… . : 1-05- 000368 (Continued)
introduced himself as Jeff. l■■•advised she recalled she and
removed their clothing down to their panties, Epstein lay on his
stomach area and they provided a massage on his legs and feet area. I
asked…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
… . : 1-05- 000368 (Continued)
introduced himself as Jeff. l■■•advised she recalled she and
removed their clothing down to their panties, Epstein lay on his
stomach area and they provided a massage on his legs and feet area. I
asked…
giuffre-maxwell
1320-13
45 pg
… . : 1-05- 000368 (Continued)
introduced himself as Jeff. l■■•advised she recalled she and
removed their clothing down to their panties, Epstein lay on his
stomach area and they provided a massage on his legs and feet area. I
asked…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Now, after having created a last-
minute scramble to conduct discovery on facts far removed in time and circumstance from
Plaintiff’s defamation claim, Plaintiff now complains that too much is being asked of her
“witness.” Plaintiff protests that the…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…if the Court allows Plaintiff Virginia
Giuffre to remove the confidentiality designation concerning the Ransome deposition—an action
that would require modification of the Protective Order in this case —it also simultaneously
remove the confidentiality designation from several related emails…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…Now, after having created a last-
minute scramble to conduct discovery on facts far removed in time and circumstance from
Plaintiff’s defamation claim, Plaintiff now complains that too much is being asked of her
“witness.” Plaintiff protests that the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…of the details that you know about that happened
15 the Epstein case for me resulted in two 15 in this case to remove yourself from the
16 years I have -- I won't bring the names but 16 spotlight…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.17
6 pg
…of the details that you know about that happened
15 the Epstein case for me resulted in two 15 in this case to remove yourself from the
16 years I have -- I won't bring the names but 16 spotlight…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…Plaintiff was asked to identify “email address, email account, cellphone
number and cellphone provider, social media account and login or screen name, text or instant
messaging account name and number, that You have used, applied for or been supplied between
…
giuffre-maxwell
1320-7
9 pg
…of the details that you know about that happened
15 the Epstein case for me resulted in two 15 in this case to remove yourself from the
16 years I have -- I won't bring the names but 16 spotlight…
giuffre-maxwell
gov.uscourts.nysd.447706.1125.0_2
5 pg
…stating that Doe 1 and Doe 2 did
not generally object to unsealing documents, (2) objecting to the
unsealing of their names out of respect for their privacy, and (3)
requesting excerpts of sealed materials that mention them for their…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…a disk you produced last week, obtained pursuant to a FOIA request, that contained at Page 2035 an
address book from approximately 2005 which has that earthlink account name next to Ms. Maxwell’s name.
-
2. Terramar – You have withdrawn…
giuffre-maxwell
1320-37
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.859.0
19 pg
…Case No.: 15-cv-07433-RWS.
ii. The Names and Addresses and Telephone and Fax Numbers of Trial Counsel:
Plaintiff’s Trial Counsel:
David Boies: Boies Schiller & Flexner
333 Main Street
Armonk, NY 10504
Tel: 914-749-8200
Fax: 914…
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