giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…of . The
process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
Best wishes,
Jason
-----Original Message-----
From:
Sent: Wednesday, August 27, 2014 9:49 AM…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.33
3 pg
…ny
., Smart vlOriginal Message------
Unread To: Sara new num
Sent: Feb 2, 2007 6:58 PM
Starred
Subject: Natalie from ny
People
Hey Sarra
Social
…
giuffre-maxwell
gov.uscourts.nysd.447706.908.0
4 pg
…with Plaintiff Virginia Giuffre
at the United States Consulate in Sydney, Australia. During that meeting, Plaintiff informed FBI
Special Agents of the existence of multiple original photographs. See Edwards Declaration, FBI
302 attached hereto as Exhibit A. On March 18…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…as
news, as they are defamatory.”
Churcher is the sole source of information regarding the original story told by Plaintiff,
and was the author of the first articles publishing Plaintiff’s claims. She was actively and
personally involved in changing…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…announcements, and sound recordings of any
nature. “Document” also means all copies which are not identical to the original document as
originally written, typed or otherwise prepared. The term “Document” shall also include all
documents of any nature that have…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.4
35 pg
…The
process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
Best wishes,
Jason
-----Original Message-----
From: Robert Giuffre Jane Doe 2
Sent: Wednesday, August 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.39
35 pg
…process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
Best wishes,
Jason
-----Original Message-----
From: Robert Giuffre [mailto:[email protected]]
Sent: Wednesday, August 27…
giuffre-maxwell
1320-39
35 pg
…process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
Best wishes,
Jason
-----Original Message-----
From: Robert Giuffre [mailto:[email protected]]
Sent: Wednesday, August 27…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…Giuffre’s references herein to production for the “Relevant Time
Period” refer to the Relevant Time Period of 1999 to the present as defined in her original requests for
production.
4
available documents demonstrate that the whole period is highly…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.34
10 pg
…for you and will pass them by Jef1rey...l will also let
Finance him know abcut the modeling potentials!
Pumla Griszell
> Folders
> Recent
Lesley Groff
Executive Assistant to Jeffrey Epstein
---…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…any kind, and electronic "writings'' and ·'recordings" as set fo11h in the Federal
Rules of Evidence, including but not limited to, originals or copic;s where originals are not
available. i\ny document -with any marks such as initials, comments…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…and sound recordings of any nature. "Docwnent" also
means all copies which are not identical to the original document as originally written,
typed or otherwise prepared. The term "Document" shaU also include alJ documents of
any nature that have been…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…the Court’s prior order and
obtain copies of unquestionably privileged material.
For example, unlike Defendant’s original privilege log that this Court found inadequate, Ms.
Giuffre is not trying to claim attorney-client privilege with communications to non-attorneys
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…a court would go about
determining that someone's reputation had already been ‘irreparably’ damaged—i.e., that no new
reader could be reached by the freshest libel” (Scalia, J.) (emphasis in original)), vacated on
other grounds, 477 U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…ORIGIN (Plm:e an "X" in One Box On lJ )
l'.J 1 Original D D 3 Re-filed D 4 Reinstated □ Trnnsferred from D 6 Multidistrict 0 7 Appeal IU □ Remnnded ti-om
Proceeding
2 Removed
…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…including but not
2
Case 1:15-cv-07433-RWS Document 17-1 Filed 12/01/15 Page 3 of 13
limited to, originals or copies where originals are not available. Any document with any marks
such as initials…
giuffre-maxwell
1320-30
27 pg
…it?
21 A Not in front of me, no.
22 Q Where is the original of the photograph
23 that has been widely circulated in the press of you
24 with Prince Andrew?
25 A I probably still have it…
giuffre-maxwell
gov.uscourts.nysd.447706.56.0
14 pg
…Rivers. By the same token, if a client summarizes or extracts advice in a
letter to a third party, that written communication is capable of retaining or attracting the privilege which
attached to the original advice, subject to waiver. It…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…5
Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 6 of 13
that the details involve non-parties who are not related to the respondent Government.” DE 324
at 5 (emphasis in original)…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…5
Case 1:15-cv-07433-LAP Document 1218-45 Filed 07/15/21 Page 6 of 13
that the details involve non-parties who are not related to the respondent Government.” DE 324
at 5 (emphasis in original)…