giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…news/ghislaine-maxwell-denied-inappropriate-action-by-jeffrey-epstein-in-newly-released-2016-deposition/
232 https://www.washingtonexaminer.com/policy/courts/ghislaine-maxwell-repeatedly-pushed-back-on-epstein-sexual-misconduct-allegations-unsealed-deposition-revea
233 https://www.mynspr.org/post…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…an (2)(h)(1) Identity of victim of sexual battery, lewd and
inventory of law enforcement resources, policies or ascivious offense upon a person less than 16 years old, child abuse,
to mobilization, deployment or tactical operati se…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…an (2)(h)(1) Identity of victim of sexual battery, lewd and
inventory of law enforcement resources, policies or ascivious offense upon a person less than 16 years old, child abuse,
to mobilization, deployment or tactical operati s s…
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
gov.uscourts.nysd.447706.1328.31
13 pg
…This Court should Order Production of Documents Responsive to Requests
Nos. 1-3
Defendant characterizes the police reports (and information therein) concerning Ms.
Giuffre as a minor as both “highly relevant” (Br. at 4) and “irrelevant” to this action (Br…
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.447706.1219.11
13 pg
…This Court should Order Production of Documents Responsive to Requests
Nos. 1-3
Defendant characterizes the police reports (and information therein) concerning Ms.
Giuffre as a minor as both “highly relevant” (Br. at 4) and “irrelevant” to this action (Br…
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.447706.1328.2
26 pg
…category, victim
4 information, and then we have listed, I believe, a
5 total of 17 individuals that the Palm Beach Police
6 Department incident report lists as alleged victims
7 in this case, correct?
8 A. Correct.
9 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.7
18 pg
…category, victim
4 information, and then we have listed, I believe, a
5 total of 17 individuals that the Palm Beach Police
6 Department incident report lists as alleged victims
7 in this case, correct?
8 A. Correct.
9 Q…
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.447706.1202.0_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.447706.320.0
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.447706.1331.15
27 pg
…show him.
3 assume because some lawyers ask you a leading 3 Thank you, (athy.
4 question or suggested in a report or like the 4 BY MR. CRITTON:
5 police report like Mr. Mermelstein and Mr. Edwards 5 Q…
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.447706.1330.16
17 pg
…defined terms. It resulted in nothing.
1
Plaintiff conveniently omits the fact that the EarthLink and MindSpring accounts were in an address book
purportedly recovered from Mr. Epstein’s home by the Palm Beach Police in 2005. Thus, there is…
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.447706.1327.12
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)…