giuffre-maxwell
gov.uscourts.nysd.447706.542.3
2 pg
…com
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giuffre-maxwell
gov.uscourts.nysd.447706.24.2
2 pg
…7454
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giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…Preska
November 16, 2019
Page 3
numbers,” and “the names of alleged minor victims of sexual abuse from deposition
testimony and police reports, as well as deposition responses concerning intimate
matters where the questions were likely only permitted—and the…
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.447706.218.0
25 pg
…Apr. 22, 2014). Although the “the federal and state policies” on the reporter’s
privilege are “congruent,” id. *4, as discussed further herein, the standards for overcoming the privilege are higher
when the state Shield Law applies.
2
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…1 Filed 05/27/16
173-8 Filed 01/04/24 Page
Page 22 of
of 45
45
----- --------- --- …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…cv-07433-RWS Document
Document1320-13 Filed05/27/16
173-8 Filed 01/03/24 Page
Page22ofof45
45
----- --------- --- ------…
giuffre-maxwell
1320-13
45 pg
…cv-07433-RWS Document
Document1320-13 Filed05/27/16
173-8 Filed 01/03/24 Page
Page22ofof45
45
----- --------- --- ------…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…Second set of Requests for Production on April 14. Those Requests
primarily concerned police reports about Plaintiff’s various contacts with law enforcement and
how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19)…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…e-
mail address for Defendant that Ms. Giuffre discovered when reviewing a FOIA production from
the Palm Beach County State Attorney’s Office relating to the police investigation of Jeffrey
Epstein. The undisclosed e-mail address for the Defendant was…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…that this is fishing with a drift net. We decline your
request to engage in this exercise.
Regarding redacted police reports that plaintiff designated “confidential”: We
objected to plaintiff’s confidentiality designation, and plaintiff failed to file a
motion in…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…Second set of Requests for Production on April 14. Those Requests
primarily concerned police reports about Plaintiff’s various contacts with law enforcement and
how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19)…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.11
4 pg
…2016 Deposition Transcript of Ghislaine Maxwell.
9. Attached hereto as Exhibit 7, is a true and correct copy of the Palm Beach Police
Report.
10. Attached hereto as Exhibit 8, is a true and correct copy of the November 21…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…fairly obvious that this is fishing with a drift net. We decline your
request to engage in this exercise.
Regarding redacted police reports that plaintiff designated “confidential”: We
objected to plaintiff’s confidentiality designation, and plaintiff failed to file a
…
giuffre-maxwell
1320-11
4 pg
…2016 Deposition Transcript of Ghislaine Maxwell.
9. Attached hereto as Exhibit 7, is a true and correct copy of the Palm Beach Police
Report.
10. Attached hereto as Exhibit 8, is a true and correct copy of the November 21…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…Second set of Requests for Production on April 14. Those Requests
primarily concerned police reports about Plaintiff’s various contacts with law enforcement and
how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19)…
giuffre-maxwell
gov.uscourts.nysd.447706.173.0
4 pg
…26, 2016
Correspondence from Sigrid McCawley.
9. Attached hereto as Exhibit 7, is a true and correct copy of the Palm Beach Police
Report.
10. Attached hereto as Exhibit 8, is a true and correct copy of the November 21…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…Second set of Requests for Production on April 14. Those Requests
primarily concerned police reports about Plaintiff’s various contacts with law enforcement and
how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19)…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…Account
Ms. Giuffre has knowledge of the account because it was listed as
part of Defendant’s contact information (including phone number) on documents gathered by the
police from Epstein’s home, and turned over to the Palm Beach County…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…437, 440
(Sup. Ct. 1995) (source “had no understanding or expectation of confidentiality with either Mr.
Hurley or the police detectives regarding the viewing of the interrogation. Consequently, there is
no absolute privilege which protects the movant's materials, see…
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