giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
1320-37
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…2023
Page-2-
does not extend to other purported victims living in countries
without the same risks of physical harm.
The Parties therefore respectfully request the Court’s permission
to maintain th…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.19
22 pg
…Yes, I do.
9,5*,1,$*,8))5(
$JUHQ%ODQGR&RXUW5HSRUWLQJ
Case 1:15-cv-07433-LAP 9LGHR,QF
Document 1320-19 Filed 01/03/24 Page 4 of 22
1 physical features of Ghislaine Maxwell…
giuffre-maxwell
1320-19
22 pg
…Yes, I do.
9,5*,1,$*,8))5(
$JUHQ%ODQGR&RXUW5HSRUWLQJ
Case 1:15-cv-07433-LAP 9LGHR,QF
Document 1320-19 Filed 01/03/24 Page 4 of 22
1 physical features of Ghislaine Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1317.0
3 pg
…2023
Page-2-
does not extend to other purported victims living in countries
without the same risks of physical harm.
The Parties therefore respectfully request the Court’s permission
to maintain th…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.13_1
23 pg
…
25 A Yes, I do.
9,5*,1,$ *,8))5(
$JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF
1 physical features of Ghislaine Maxwell?
2 A I can tell you that she had very large
3 natural breasts…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…Epstein to
physically appear to assert his Fifth Amendment privilege in front of the jury.
While it may be true that there is no blanket prohibition in all civil cases against calling a
witness who will assert his Fifth Amendment…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…earnings – precise amounts yet to be computed, but not
less than $5,000,000.”
12. Identify any Health Care Provider from whom You received any treatment for any
physical, mental or emotional condition, that You suffered from subsequent to any…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…the instnrctions given her by Defendan* Epstein and Maxwell.
ll
Case 1:17-cv-00616 Document 1 Flled OU26|L7 page L2 ot 2L
39. Plaintiff reasonably believed that her compliance with Defendants'
demands was crucial to her physical, psychological…
giuffre-maxwell
gov.uscourts.nysd.447706.70.0
15 pg
…location and general description of
relevant documents, including pertinent insurance agreements, and other physical
evidence, or information of a similar nature.
(b) During discovery, interrogatories other than those seeking information described in
paragraph (a) above may only be served (1…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
…that if he doesn't
15 A Fift h. 15 physically force the underage minor female iuto
16 Q Mas ,l effrcy Epstein instruclccl you to 16 any act, then he is entitled lo engage in sex
17 lie to…
giuffre-maxwell
gov.uscourts.nysd.447706.239.1
11 pg
…deposition service issue as to Mr. Epstein has been
resolved. I will forward any proposals on dates to the
attorney or attorneys who will physically be present at the
deposition so that they, Laura, and you can work agree on…