giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…stock, bonds, in-kind
income, earnings, salary, pay, remuneration, wages, stipends, revenue, profits, gains, proceeds,
turnover, yield, or dividends.
8. “Jeffrey Epstein” includes Jeffrey Epstein and any entities owned or controlled by
Jeffrey Epstein, any employee, agent, attorney, consultant, or…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Plaintiff’s proposal included astoundingly broad terms, to wit:
x “Terramar” -- both the name of Ms. Maxwell’s non-profit and
x
x
x “max*” – part of Ms. Maxwell’s last name, as well as all of her paternal relatives…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…been produced. Plaintiff also produced an email to but not any
response to that email.
The iCloud account also discloses a previously undisclosed potential witness,
, a person working at a not-for-profit relating to sexual trafficking victims. Apparently, in…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…wit:
Plaintiff’s originally proposed search terms would literally hit on every single email from either
Ms. Maxwell’s personal or her business email addresses, as well as every document related to
the non-profit, The Terramar Project, that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.2_1
10 pg
…The time to negotiate search terms has long passed; this Court
should not countenance Defendant profiting from her refusal to comply with her discovery
obligations and from her refusal to obey this Court’s Order.
Dated: August 1, 2016
Respectfully…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…The time to negotiate search terms has long passed; this Court
should not countenance Defendant profiting from her refusal to comply with her discovery
obligations and from her refusal to obey this Court’s Order.
Dated: August 1, 2016
Respectfully…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…Maxwell, who had already been
maintaining a low profile even before the Epstein scandal came roaring back to life
this past summer.”2
1
https://www.vanityfair.com/news/2019/11/hunt-for-jeffrey-epstein-alleged-enabler-
ghislaine-maxwell?utm…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…Florida, Jane Doe 1 and Jane Doe 2 v. United States of
America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey
Epstein sexually trafficked You, “including numerous prominent American politicians, powerful
business executives…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…Florida, Jane Doe 1 and Jane Doe 2 v. United States of
America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey
Epstein sexually trafficked You, “including numerous prominent American politicians, powerful
business executives…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…of the interview which I have reviewed I would like to add one further point to
underscore the lack of probity in Ms Roberts claims
At no point in Ms Maxwell’s life has she ever contemplated thought or wanted…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…Florida, Jane Doe 1 and Jane Doe 2 v. United States of
America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey
Epstein sexually trafficked You, “including numerous prominent American politicians, powerful
business executives…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…Florida, Jane Doe 1 and Jane Doe 2 v. United States of
America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey
Epstein sexually trafficked You, “including numerous prominent American politicians, powerful
business executives…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…Florida, Jane Doe 1 and Jane Doe 2 v. United States of
America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey
Epstein sexually trafficked You, “including numerous prominent American politicians, powerful
business executives…
giuffre-maxwell
1320-37
48 pg
…Florida, Jane Doe 1 and Jane Doe 2 v. United States of
America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey
Epstein sexually trafficked You, “including numerous prominent American politicians, powerful
business executives…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…Florida, Jane Doe 1 and Jane Doe 2 v. United States of
America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey
Epstein sexually trafficked You, “including numerous prominent American politicians, powerful
business executives…
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