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.447706.1201.10_1
27 pg
…Decl., Ex. C at 312-
334 and Ex. D at 179- 89.
Exhibit 13 was a document prepared by someone other than Ms. Maxwell, was not
maintained by Ms. Maxwell and over which Ms. Maxwell had no control. Given the…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…apparently an
23 affidavit prepared by the FBI that's been provided to
24 Ms. Churcher by someone; I don't know whom, your Honor, but I'm
25 going to presume it was provided to Ms. Churcher by the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…discovery motions, motions in limine,
1
Counsel for Intervenors has not seen these documents and submits this response based on the list
of Decided Motions prepared by counsel for the Parties and Ms. Maxwell’s Objections.
Case 1:15…
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
gov.uscourts.nysd.447706.903.0
46 pg
…I
19 don't know what this is, it wasn't prepared by my department,
20 I've never looked at it.
21 And so whatever this document is has not been
22 authenticated by anyone. That's the first…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…Ms. Giuffre is entitled to have the Court compel production of
communications and documents related to these disclosures. Some of those documents are
specifically identified in the privilege logs prepared by Defendant, while Defendant has withheld
other documents and communications…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…Decl., Ex. C at 312-
334 and Ex. D at 179- 89.
Exhibit 13 was a document prepared by someone other than Ms. Maxwell, was not
maintained by Ms. Maxwell and over which Ms. Maxwell had no control. Given the…
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.447706.1328.10
23 pg
… One , I believe .
22 Q. One document . Was that a document
23 that had been prepared by your attorney , or
24 was it a document from the past?
25 MR. PAGLIUCA: I will tell you not
MAGNA9 LEGAL SERVICE$
Case…
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.447706.1327.10
23 pg
… One , I believe .
22 Q. One document . Was that a document
23 that had been prepared by your attorney , or
24 was it a document from the past?
25 MR. PAGLIUCA: I will tell you not
MAGNA9 LEGAL SERVICES
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…anticipation of legal proceedings—Whether latter
purpose to be dominant for claim to privilege to succeed—
Whether form of wording of report conclusive as to purpose
for which prepared
The plaintiff's husband was employed by the defendant
railways board…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…3 and the prince are being prepared, the letter
adds, but their filing will be delayed if Andrew accepts the interview request by January 19.
The attorney for her legal team confirmed to CNN that Buckingham Palace had refused to…
giuffre-maxwell
gov.uscourts.nysd.447706.515.0
12 pg
…ATTACHED IN 2011
WHEN SHE FORMED AN INTENT TO JOIN THE CVRA LITIGATION
Plaintiff concedes she willfully and deliberately destroyed while she
prepared to join the CVRA litigation and while she was represented by current counsel for that
express purpose…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…is filed
5 by her lawyers, and that's what they are saying on her behalf.
6 That's what I can say about that, your Honor.
7 THE COURT: I do understand how these documents are
8 prepared.
9 …
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…is filed
5 by her lawyers, and that's what they are saying on her behalf.
6 That's what I can say about that, your Honor.
7 THE COURT: I do understand how these documents are
8 prepared.
9 …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.5
12 pg
…SHE FORMED AN INTENT TO JOIN THE CVRA LITIGATION
Plaintiff concedes she willfully and deliberately destroyed her journal in 2013 while she
prepared to join the CVRA litigation and while she was represented by current counsel for that
express purpose…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…In 1998 the claimants prepared, or caused to be prepared,
documentation for a warranty scheme which they sought to sell to retailers to replace
insurance based schemes which had been rendered commercially unattractive by a
change in the tax regime…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…asked for, but
11 been denied by plaintiff, her own deposition testimony in the
12 Florida action. In that case the Court entered a confidential
13 order --
14 THE COURT: I'm prepared to deal with it.
15 MS. MENNINGER…
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