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.447706.235.3
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.447706.441.0
18 pg
…efamation physicians
she has everseen and alld etails relatingthereto -this wou ld also inclu d e allped iatric record s from
birth:
“Id entify any H ealthC are P rovid erfrom who Y ou received any treatmentforany physical,
2
…
giuffre-maxwell
gov.uscourts.nysd.447706.1313.0
1 pg
…is based on circumstances
specific to Doe 107 and 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 the redactions
to…
giuffre-maxwell
gov.uscourts.nysd.447706.1116.0
3 pg
…105
6. On September 11, I sent Non-Party Notices via e-mail to the following Non-Parties
for whom only an email address was available despite best efforts to locate a physical address:
• J. Doe 10
• J. Doe 77…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Tr. at 199.
Her stepmother’s phone, e-mail address and physical address – despite the fact that
non-party Ms. Ransome already gave testimony at her lengthy deposition that she
does not have her stepmother’s contact information. See…
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.447706.1296.9
29 pg
…Tr. at 199.
Her stepmother’s phone, e-mail address and physical address – despite the fact that
non-party Ms. Ransome already gave testimony at her lengthy deposition that she
does not have her stepmother’s contact information. See…
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.447706.1295.11
19 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.447706.71.6
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.447706.64.0
14 pg
…other evidentiary materials.” Id. In her November 2015
disclosures, Plaintiff first stated that she suffered: (1) Physical, psychological and
psychiatric injures and resulting medical expenses—precise amount yet to be computed,
but not less than $100,000.00; (2) Past…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…responsive Documents in your
possession, custody or control without regard to the physical location of such documents.
3
Case 1:15-cv-07433-RWS Document 17-1 Filed 12/01/15 Page 4 of 13
3. If any Document…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…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 requested was in any defendant’s possession or control, but…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…Giuffre allegedly had
with other people, including a professor of psychology at Harvard who she identified by name
and physical characteristics.
38. The May 10-11 and June 8 Emails were filed under seal in connection with the
motion to…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
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…