giuffre-maxwell
gov.uscourts.nysd.447706.509.0
18 pg
…Brad Edwards. Edwards was then (and now) actively litigating his own personal civil case
against Mr. Epstein as well as pursuing the CVRA action in an attempt to void the non-
prosecution agreement between Mr. Epstein and the Government. According…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…in an attempt to void the non-
prosecution agreement between Mr. Epstein and the Government. According to Plaintiffs
I discovery responses:
I Bra~ Edward~, . (alon~ wi!h. ot~~Faqper, Jaffe ~ttomeys) represents !v.1t~· Giuffr~
as a non-party' i1i the…
giuffre-maxwell
gov.uscourts.nysd.447706.222.0
10 pg
…the Crime Victims Rights Act, 18 U.S.C. § 3771 (“CVRA”),
2
a non-prosecution agreement between Mr. Epstein and the U.S. Attorney’s Office for the Southern
District of Florida that is almost nine years old. Through counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…right?
5 MS. SCHULTZ: Object to form.
6 THE WITNESS: I think there was a
7 non-prosecution agreement prepared between the
8 Feds and some kind of agreement was made. But,
9 yes, he did end up pleading guilty…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.7
18 pg
…right?
5 MS. SCHULTZ: Object to form.
6 THE WITNESS: I think there was a
7 non-prosecution agreement prepared between the
8 Feds and some kind of agreement was made. But,
9 yes, he did end up pleading guilty…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…your 19 his potential criminal liability and your
20 questions, we can use the full invocation 20 intention to seek to rescind his
21 that we did in response to your first 21 non-prosecution agreement, the admissions
22 question…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…your 19 his potential criminal liability and your
20 questions, we can use the full invocation 20 intention to seek to rescind his
21 that we did in response to your first 21 non-prosecution agreement, the admissions
22 question…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
willful non-compliance, as well as a supplement to her motion for an adverse inference
instruction based on new information…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…practice concerning these issues, and
throughout all of the meet and confers, Defendant’s counsel has never presented a case
supporting the far-fetched position that non-privileged documents in the possession of the
2
Furthermore, Ms. Giuffre’s correspondence…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…Alexander Acosta, who, when he was United
States Attorney for the Southern District of Florida, approved Mr. Epstein’s nonprosecution
agreement. See, e.g., New York Daily News, “Labor Secretary nominee Alexander Acosta gave
‘sweetheart deal’ to sex offender Jeffrey…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…VIRGINIA L. GIUFFRE,
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
DEFENDANT’S RESPONSE TO PLAINTIFF’S MOTION TO COMPEL
DATA FROM DEFENDANT’…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…YORK
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
NON-PARTY SARAH RANSOME’s RESPONSES AND OBJECTIONS
TO DEFENDANT’S SUBPOENA REQUESTS
Sarah Ransome, a non…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…YORK
--------------------------------------------------X
.............................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…YORK
--------------------------------------------------X
.............................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…YORK
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
NON-PARTY SARAH RANSOME’s RESPONSES AND OBJECTIONS
TO DEFENDANT’S SUBPOENA REQUESTS
Sarah Ransome, a non…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
…Notre Dame, Miami Beach, FL 33141
NON PARTY (VR)0003 15
OIUFFREOO I004
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 3 of…
giuffre-maxwell
gov.uscourts.nysd.447706.1211.0_1
5 pg
…page 112, line 17 through and including page
113, line 12.1 Ms. Giuffre and non-parties Julie Brown and Miami
Herald Media Co oppose the motion.2
For the reasons described below, Ms. Maxwell’s motion is
denied.
I. …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Ms. Maxwell has access. Based
on those searches, not one single additional responsive and non-privileged document has been
identified. Ms. Maxwell’s original search for responsive documents was complete at the time it
was conducted in February 2016. The…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…YORK
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
NON-PARTY SARAH RANSOME’s RESPONSES AND OBJECTIONS
TO DEFENDANT’S SUBPOENA REQUESTS
Sarah Ransome, a non…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…Ms. Maxwell has access. Based
on those searches, not one single additional responsive and non-privileged document has been
identified. Ms. Maxwell’s original search for responsive documents was complete at the time it
was conducted in February 2016. The…