giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 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.447706.1219.10
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.447706.1332.6
8 pg
…Document Attorney Work Product;
prepared by Attorney-Client
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.34
10 pg
…news is that I got your email. I am not sure what happened the first time but I think I
must have deleted it by mistake as it went to bulk t0< some reason. I am however having a little…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…15 Civ. 7433 (LAP)
Dear Judge Preska:
Paragraph 1 of the Court’s October 28 Order (Doc.998) required the parties to identify
motions decided by the Court and related papers that were sealed or redacted (“Sealed
Materials”). Paragraphs 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…order as they are kept or maintained
by you in the ordinary course of business.
16. You are requesle
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…by counsel for Ms. Maxwell for responsiveness to Plaintiff’s
discovery request, pursuant to this Court’s Order. Of those documents, the only responsive
documents were either communications between Ms. Maxwell and current counsel or were
communications with, or prepared…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…10022, before a certified court
reporter or other officer duly authorized to administer oaths. The deposition will be recorded by
stenographic means.
Pursuant to Rule 45, Defendant Ghislaine Maxwell also hereby provides Notice of
Service of Subpoena upon Sarah Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…She agreed and was taken to the house by
had introduced her to Sarah and Epstein and brought her upstairs to a
master bedroom and Master bathroom where a massage table was prepared
and the proper oils were taken out…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…She agreed and was taken to the house by
had introduced her to Sarah and Epstein and brought her upstairs to a
master bedroom and Master bathroom where a massage table was prepared
and the proper oils were taken out…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…You prepared or which was
prepared on Your behalf, and travel itinerary, receipt, log, or Document (including any
photograph) substantiating Your travel during that time period.
18. All Documents showing any payments or remuneration of any kind made by
Jeffrey…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…same order as they are kept or maintained
by you in the ordinary course of business.
15. You are requested to produce all drafts and notes, whether typed, handwritten or
otherwise, made or prepared in connection with the requested Documents…
giuffre-maxwell
1320-13
45 pg
…She agreed and was taken to the house by
had introduced her to Sarah and Epstein and brought her upstairs to a
master bedroom and Master bathroom where a massage table was prepared
and the proper oils were taken out…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…by counsel for Ms. Maxwell for responsiveness to Plaintiff’s
discovery request, pursuant to this Court’s Order. Of those documents, the only responsive
documents were either communications between Ms. Maxwell and current counsel or were
communications with, or prepared…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…same order as they are kept or maintained
by you in the ordinary course of business.
16. You are requested to produce all drafts and notes, whether typed, handwritten or
otherwise, made or prepared in connection with the requested Documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.10
14 pg
…NEW YORK
Friday, February 17, 2017
Reported by:
JEREMY RICHMAN
JOB NO: 300491
MAGNA LEGAL SERVICES
320 West 37th Street, 12th Floor
New York, New York 10018
(866) 624-6221
Highly Confidential
Page 10
…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…NEW YORK
Friday, February 17, 2017
Reported by:
JEREMY RICHMAN
JOB NO: 300491
MAGNA LEGAL SERVICES
320 West 37th Street, 12th Floor
New York, New York 10018
(866) 624-6221
Highly Confidential
Page 2
1 …
giuffre-maxwell
gov.uscourts.nysd.447706.1008.0
5 pg
…435 F.3d 110, 123 (2d Cir. 2006) (holding that documents
submitted with a motion are “unquestionably judicial documents” “by virtue of having been
submitted to the court”). For the following reasons, the Court should hold that materials submitted
in…
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