giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…whether Income was received by You or anyone else
concerning such event, whether a police report was ever filed concerning such event and the
outcome of any such case, as well as the address and location of any such event…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…8~ . 3,7.3, ,..448 ' ~ ~: E ;2 dJ 1_2:1 ., i. ·
(1983). The policy purposes 6f privilege in both jurisdictions
also mi..r ~fn
giuffre-maxwell
gov.uscourts.nysd.447706.56.0
14 pg
…the law of the country that has the ‘predominant’ or ‘the most
direct and compelling interest’ in whether those communications should remain confidential,
unless that foreign law is contrary to the public policy of this forum.” 208 F.R.D…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…of 5
Page 84
1 G Maxwell - Confidential
2 30 girls --
3 A. I did not count the number of girls
4 and I did read the police report. I can only
5 testify to what I read.
6 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.55.0
5 pg
…45].
3. Attached hereto as Exhibit 1, is a true and correct copy of the Palm Beach Police
Department’s Report.
4. Attached hereto as Exhibit 2, is a true and correct copy of the Flight Logs from
Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.144.0
4 pg
…4
5. Attached hereto as Exhibit 3, is a true and correct copy of the Palm Beach police
report.
6. Attached hereto as Exhibit 4, are true and correct copies of pages 60-62 of
Defendant Maxwell’s April 22…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…whether Income was received by You or anyone else
concerning such event, whether a police report was ever filed concerning such event and the
outcome of any such case, as well as the address and location of any such event.…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…the type of testimony the presumptive limit is intended to prevent.
Similarly, the expected deposition testimony of former Palm Beach Detective Joe
Recarey and former Palm Beach Police Chief Michael Reiter are duplicative of each other.
4
Mr. Rodgers deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…whether Income was received by You or anyone else
concerning such event, whether a police report was ever filed concerning such event and the
outcome of any such case, as well as the address and location of any such event.…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…whether Income was received by You or anyone else
concerning such event, whether a police report was ever filed concerning such event and the
outcome of any such case, as well as the address and location of any such event.…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…whether Income was received by You or anyone else
concerning such event, whether a police report was ever filed concerning such event and the
outcome of any such case, as well as the address and location of any such event.…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…whether Income was received by You or anyone else
concerning such event, whether a police report was ever filed concerning such event and the
outcome of any such case, as well as the address and location of any such event.…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…within the
enterprise were the subjects of a Palm Beach, Florida Police Department criminal
investigation which revealed that Defendant Epstein had engaged in sexual
activities with dozens of young teenage children. Each child was lured into
Defendant Epstein's Palm…
giuffre-maxwell
1320-37
48 pg
…whether Income was received by You or anyone else
concerning such event, whether a police report was ever filed concerning such event and the
outcome of any such case, as well as the address and location of any such event.…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…the type of testimony the presumptive limit is intended to prevent.
Similarly, the expected deposition testimony of former Palm Beach Detective Joe
Recarey and former Palm Beach Police Chief Michael Reiter are duplicative of each other.
4
Mr. Rodgers deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…whether Income was received by You or anyone else
concerning such event, whether a police report was ever filed concerning such event and the
outcome of any such case, as well as the address and location of any such event.…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…whether Income was received by You or anyone else
concerning such event, whether a police report was ever filed concerning such event and the
outcome of any such case, as well as the address and location of any such event.…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…without further conferral.
DOCUMENT REQUEST NO. 42
Produce all policies of insurance having any cash value that exist or existed from January
2015 to the present, which policies You or any entity controlled by You is the owner or
beneficiary…
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…Attorney in one district is not able to bind U.S. Attorneys in other districts.”
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