giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…communications with counsel) and her Motion to
Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the
routine step of looking at Defendant’s email and other electronic documents to find responsive
documents, but produced, instead…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…communications with counsel) and her Motion to
Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the
routine step of looking at Defendant’s email and other electronic documents to find responsive
documents, but produced, instead…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…communications with counsel) and her Motion to
Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the
routine step of looking at Defendant’s email and other electronic documents to find responsive
documents, but produced, instead…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
…communications with counsel) and her Motion to
Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the
routine step of looking at Defendant’s email and other electronic documents to find responsive
documents, but produced, instead…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…70
day.co.uk]
To: Sharon [email protected][Sharon.Churcher@mailonsun
From: Jenna
·sent: Mon 3/7/2011 10:55:59 AM
Importance: Normal
Subject: RE: Re:
Received: Mon 3/7/2011 10:55:59 AM
Hi again ,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.7
9 pg
…did -- do you recall what when
21 you observed the other females giving massages, do
22 you recall what they would dress like? Did they
23 wear scrubs or did they typically wear normal
24 clothes?
25 A. Normal clothes .
…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…unwarranted and prejudicial
pretrial publicity by the Government, its agents, and lawyers for alleged witnesses.
Legal Standard
More than fifty years ago, warning of the danger of pretrial publicity to fair trials, the
Supreme Court directed trial judges to take…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
… SHE AND THE TWO
SUSPECTS ARRIVED AT A WOODED AREA IN CALLED "WOODSIES". I ASKED
FOR A DESCRIPTION OF KEVIN'S CAR AID THE CAR HAD "NORMAL
"LIKE VELVET, WHICH INDICATES THEY PROBAB …
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…defense counsel once again ranged far beyond the normal parameters of objections and
gave instructions directly in contravention of this Court’s Order directing Defendant to answer
exactly the type of questions posed to her.
In light of Defendant’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…more ii
_'
5 threatened? 5 digging, all I want is this to be to get on
6 A. Yes . 6 with my normal…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…the
witnesses to appear via a trial subpoena. Accordingly, Ms. Giuffre seeks leave to take more than
the standard ten depositions in this case. At this time, she seeks leave to take seven additional
depositions, as articulated below.2
2…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…defense counsel once again ranged far beyond the normal parameters of objections and
gave instructions directly in contravention of this Court’s Order directing Defendant to answer
exactly the type of questions posed to her.
In light of Defendant’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
… Medium Facial Hair . : Mustache Only
Teeth . . . . Normal Build MEDIUM
Speech . . . . Normal Status .. Arrested
Arrest Case No.: 1-97-006345 Shirt BLK …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…21 A. Palatial. When you walk up, it looks like
22 a normal door to a townhouse, and when you walk
23 in -- I thought there were four floors. I heard
24 there were seven floors. I didn't see…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…done
25 some culinary training.
MAGNA& LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 18 of 35
Page 98
1 Q. And you guys had a normal type
2 conversation?
3 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
…21 A. Palatial. When you walk up, it looks like
22 a normal door to a townhouse, and when you walk
23 in -- I thought there were four floors. I heard
24 there were seven floors. I didn't see…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…defense counsel once again ranged far beyond the normal parameters of objections and
gave instructions directly in contravention of this Court’s Order directing Defendant to answer
exactly the type of questions posed to her.
In light of Defendant’s…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…around Spain by some unknown people. She
19 saw them a few times. She would go out on her normal route,
20 and she saw the same people. She thought they were following
21 her, so she got rid of…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…In this case, defense counsel ranged far beyond the normal
parameters of objections and sought to decide for himself what issues were relevant. That was
improper and the Court should order a resumption of the Defendant's deposition so that…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…such inquiries are crucial to impeaching the Defendant at trial. During her
deposition, Defendant attempted to characterize her work for Epstein as nothing more than a
normal job handling hiring for the various mansions. See McCawley Decl. at Exhibit 1…
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