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.447706.71.2
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
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.447706.232.1
…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.447706.1187.0
3 pg
…such as a social security numbers,
home addresses, personal email addresses or
personal telephone numbers; (iii) protected health
information, inclusive of physical and mental
health records; and (iv) identifying information of
sexual abuse victims, such as names, emails,
telephone numbers…
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.447706.1005.0
6 pg
…when
is a mere document transformed into a judicial one? The Third Circuit’s focus was “‘on the
technical question of whether a document is physically on file with the court.’” Amodeo I, 44
F.3d at 145 (quoting Pansy…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…2010 Deposition Transcript of Nadia Marcinkova, attached hereto as
Exhibit 28.
C. Computation of damages:
1. Physical, psychological and psychiatric injuries and resulting medical expenses – in
an amount of approximately $ 102,200 present value.
a. Computation Analysis:
…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…prostitute,” a “liar,” or a “bad mother” or any other similar
derogatory and harassing language.
c. Physical Location Limitations
Non-party Jane Doe No. 3 has a valid and real basis to fear being in physical proximity of
the Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…revised to reflect that she is not seeking a specific
monetary damage in the form of a specific lost wage claim.
13. Identify any Health Care Provider from whom You received any treatment for any
physical, mental or emotional condition…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…any other person.
Indeed, though the Manuscript describes sexual encounters Ms. Giuffre allegedly had with a
different member of the Harvard faculty—whom she identifies by name and physical
characteristics—it levels no such accusation against Professor Dershowitz. Dershowitz
Decl. …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…Document.
3. This Request calls for the production of all responsive Documents in your
possession, custody or control without regard to the physical location of such documents.
4. If any Document requested was in your possession or control, but is…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…Document.
3. This Request calls for the production of' all responsive Documents in your
possession, custody or control without regard lo the physical location of such documents.
4. lf any Document requested was in your possession or control. but is…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…for
the subpoenaing party.
2. This Request calls for the production of all responsive Documents in your possession,
custody or control without regard to the physical location of such documents.
3. If any Document was in your possession or control…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…not a plaintiff. She is
11 not going to be revealing any names today of an
12 individual who is going to harm her physically,
13 period. If we have to go to Judge Lynch on that
14 we will…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…bias)
4. Whether Alan Dershowitz contacted anyone on her behalf (communications with others
by counsel not privileged)
5. Her stepmother’s phone number and email address and physical address (she claims that
they spoke with Ms. Maxwell and Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…bias)
4. Whether Alan Dershowitz contacted anyone on her behalf (communications with others
by counsel not privileged)
5. Her stepmother’s phone number and email address and physical address (she claims that
they spoke with Ms. Maxwell and Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…Document.
3. This Request calls for the production of all responsive Documents in your
possession, custody or control without regard to the physical location of such documents.
4. If any Document requested was in your possession or control, but is…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…Document.
3. This Requcst calls for the production of alll'esponsive Documents in Your
possession. custody or control without regard to the physical location of such Documents.
4. Ir any Document requested was in Your possession or control, but is…
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