giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…including one claiming privilege, by ordering cross-examination.
C Held, ruling accordingly:
1. Where a report was prepared pursuant to a statutory obligation the purposes
of the instigator of the report were irrelevant. There should be no difference in
principle…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…a named person, "Witness, interacted
2 and chat daily with underaged girls."
3 So this document is prepared by Mr. Rodriguez in an
4 effort to make money in connection with these Jane Doe cases.
5 Now, here's what…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…22
Produce all Financial Statements prepared for or submitted to any Lender or Investor for
the past three years by You personally or on Your behalf or on behalf of any entity in which You
hold or held a controlling…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…a portion of Ms.
Maxwell’s deposition. Exhibit 2 contains a “Flight Log Summary Chart” prepared by Plaintiff’s
counsel and flight logs that contain the names of numerous Non-Party Does. Exhibit 3 purports to
be 88 pages of…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…After extensive discussion
and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality
agreement prepared by Maxwell’s attorney, at the eleventh hour Maxwell’s attorney informed
the undersigned that Maxwell’s mother was very…
giuffre-maxwell
1320-17
25 pg
…22
Produce all Financial Statements prepared for or submitted to any Lender or Investor for
the past three years by You personally or on Your behalf or on behalf of any entity in which You
hold or held a controlling…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…Brief submitted by Churcher
in support of her motion to quash the subpoena served on her;
(2) emails between Churcher and Giuffre submitted in connection
with the same motion; and (3) a draft of a manuscript prepared
by Giuffre submitted…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…7. It is not. The document was prepared by Ms. Giuffre in
an attempt to seek legal advice at the request of her attorneys and to convey information to them
to assist in forming legal opinions and rendering legal advice…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.10
4 pg
…
prepared by Attorney-Client
Ghislaine …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.6
4 pg
…
prepared by Attorney-Client
Ghislaine …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.21
8 pg
…Document Attorney Work Product;
prepared by Attorney-Client
…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…today.
Materials submitted by parties to a court should be understood
for what they are. They do not reflect the court’s own findings. Rather,
they are prepared by parties seeking to advance their own interests in
an adversarial process…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…against Jeffrey Epstein.
After extensive discussion and coordinating a convenient time and place, as well as ultimately
agreeing to a confidentiality agreement prepared by Defendant’s then attorney, at the eleventh
hour Maxwell’s attorney informed the victims’ attorney that…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…Because the document was
prepared by a highly-credible public agency—the Federal Bureau of Investigation on a federally-
approved form—it is a report of a public office and qualifies for exemption from the hearsay
5
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…today.
Materials submitted by parties to a court should be understood
for what they are. They do not reflect the court’s own findings. Rather,
they are prepared by parties seeking to advance their own interests in
an adversarial process…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…today.
Materials submitted by parties to a court should be understood
for what they are. They do not reflect the court’s own findings. Rather,
they are prepared by parties seeking to advance their own interests in
an adversarial process…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.6
8 pg
…Document Attorney Work Product;
prepared by Attorney-Client
…
giuffre-maxwell
gov.uscourts.nysd.447706.155.0
15 pg
…639 (2d Cir. 1962) (“Insofar as the
papers include pre-existing documents and financial records not prepared by [the party] for the
purpose of communicating with their lawyers in confidence, their contents have acquired no
special protection from the simple…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…today.
Materials submitted by parties to a court should be understood
for what they are. They do not reflect the court’s own findings. Rather,
they are prepared by parties seeking to advance their own interests in
an adversarial process…
giuffre-maxwell
gov.uscourts.nysd.447706.1058.1
3 pg
…to raise similar objections. Professor Dershowitz
has explained that he is prepared to abide by any applicable court order subject only to reserving
the right to seek relief from the Court as to particular items if appropriate, a right which…
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