giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…1027.
D
Highgrade Traders Ltd, Re [1984] BCLC 151.
House of Spring Gardens Ltd v Waite [1985] FSR 173.
Jones v Monte Video Gas Co (1880) 5 QBD 556.
L (A Minor) (Police Investigation: Privilege), Re [1997] AC 16.
Lask…
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.447706.1202.0_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.447706.1332.1
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.447706.1200.11_1
21 pg
…her account. Both email accounts are listed as part of Defendant’s
contact information gathered by the police from Epstein’s home, and turned over to the Palm
Beach County State Attorney as part of the investigation and prosecution of…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 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.447706.1257.2
21 pg
…her account. Both email accounts are listed as part of Defendant’s
contact information gathered by the police from Epstein’s home, and turned over to the Palm
Beach County State Attorney as part of the investigation and prosecution of…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…media moguls, and high
profile business-people. Police departments regularly post mugshots and names of working-class
prostitution clients who get ensnared in street-level prostitution stings. That is considered to be a
matter of public concern. It is virtually…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…For
another example, Defendant represented to the Court that Ms. Giuffre’s rape (where the presence
of blood and semen was noted by the police report) was a “simulated sex act” (DE 335). For
another example, Defendant put forth to…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…her account. Both email accounts are listed as part of Defendant’s
contact information gathered by the police from Epstein’s home, and turned over to the Palm
Beach County State Attorney as part of the investigation and prosecution of…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…as a practical matter, there is no time to conduct
discovery—including depositions of the individual police officers—between the
liability verdict and the charge to the jury on punitive damages. Plaintiffs' counsel
represented at oral argument that if Defendants…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…but, to date, have not received any response. Again, Ms.
Giuffre has no input on Dr. Hayek’s document retention policies, and therefore, the lack of
production of records from Dr. Hayek cannot be attributed to Ms. Giuffre.
C. Dr…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…as a practical matter, there is no time to conduct
discovery—including depositions of the individual police officers—between the
liability verdict and the charge to the jury on punitive damages. Plaintiffs' counsel
represented at oral argument that if Defendants…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…but, to date, have not received any response. Again, Ms.
Giuffre has no input on Dr. Hayek’s document retention policies, and therefore, the lack of
production of records from Dr. Hayek cannot be attributed to Ms. Giuffre.
C. Dr…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…but, to date, have not received any response. Again, Ms.
Giuffre has no input on Dr. Hayek’s document retention policies, and therefore, the lack of
production of records from Dr. Hayek cannot be attributed to Ms. Giuffre.
C. Dr…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…but, to date, have not received any response. Again, Ms.
Giuffre has no input on Dr. Hayek’s document retention policies, and therefore, the lack of
production of records from Dr. Hayek cannot be attributed to Ms. Giuffre.
C. Dr…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…prove
4
See Declaration of Sigrid McCawley (“McCawley Decl.”) at Exhibit 1, Palm Beach Police Report.
5
Defendant disregarded Ms. Giuffre’s requested date range of 1999 to the present and unilaterally limited her
production to the years 1999 – 2002…