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.447706.1325.14
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.447706.1328.40
3 pg
…3
To: Marianne Strong[[email protected]]
From: Virginia Giuffre
Sent: Fri 2/21/2014 1:17:22 PM
Importance: Normal
Subject: Re: NYC Post Inquiry re : Jeffrey Epstein
Received: Fri 2/21/2014 1:17:22 PM
Dearest marianne,
…
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.447706.69.2
21 pg
… Alternatively, if Ms. Giuffre is assumed to work until a normal
retirement age of 65, or 33.6 years from her age at the beginning of
2015, and based on an annual growth rate of 2.0% and a discount…
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.447706.1295.10
14 pg
… I
20 mean, I know guys can normally cum
21 once or twice a day, but Jeffrey's not
22 a normal person.
23 So, I mean, our rotation
24 changed every day that specific trip
25 we had in…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…2016, deposition.
2
Defendant appears to have acquired these police reports outside of the normal discovery process,
as they unequivocally came from non-parties, yet Defendant never served a notice of subpoena on
Plaintiff indicating her efforts to acquire these…
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.447706.1078.5
161 pg
…and trying to blame
these girls for what happened is so contrary to the evidence, is so contrary to people’s
normal sense of morality,” Boies said. “I think that’s just going to enrage a jury if she goes…
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.447706.1332.15
11 pg
…2012). There can be no legitimate purpose for
the movants seeking pictures of Jane Doe 43 after her attempted suicide and these are documents
they can seek through the normal courses of discovery before Judge Koeltl. As with other non…
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.447706.1259.0
17 pg
…Access .............................................................................. 10
2.1.2 The First Amendment Compels Access ................................................................ 12
2.2 Standard for Sealing a Court Record ........................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…Id. at 29. She only witnessed
masseuses who were her age or older and they wore “normal” clothes. Id. at 31-32.
x She never was asked by Epstein or Maxwell to give sexual massages to any of their
friends…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…Computation Of Damages Complies With Rule 26............6
D. Ms. Giuffre Can Base Alleged Lost Income On “The Jobs of Others” – i.e.,
On Standard Economic Estimation Techniques. ...........................................................8
E. Plaintiff Has Not Refused To Provide Addresses And Te…
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…
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