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.447706.1320.17
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.447706.1067.0
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.447706.1219.22
22 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
plaintiff’s counsel that Maxwell’s mother was…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 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
plaintiff’s counsel that Maxwell’s mother was…
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
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.447706.1327.26
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.447706.730.0
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.447706.751.10
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.447706.1295.5
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.447706.363.11
40 pg
…we've included additional statements by Alan
Dershowitz about the circumstances under which he's prepared to waive confidential
information.
It's not over.
If you thought the settlement that Alan Dershowitz reached on Friday with the lawyers
representing Virginia…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…SCHULTZ: Object to form.
6 THE WITNESS: I think there was a
7 non-prosecution agreement prepared between the
8 Feds and some kind of agreement was made. But,
9 yes, he did end up pleading guilty.
10 BY MR…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…Cassell, Esq., by and through their
undersigned counsel and pursuant to Rule 1.510, Florida Rules of Civil Procedure, hereby move
for (1) partial summary judgment on the issue of the false and defamatory nature of the
statements at issue…
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