giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.5
2 pg
…constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…001048
GM_01062
CONFIDENTIAL
Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 5 of 11
legally privileged and are the property of News…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…York, NY 10022
□ Inspection of Premises: YOU ARE COMMANDED lo permit entry on to the designated premises, land, or
other property possessed or contro l led by you at the l ime, date, and location set forth below. so…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…were taken from the room. See the
completed property receipt for a detailed list.
A green bathroom located on the first floor was searched and nothing
was taken.
A closet located just west of the green bathroom was searched. Two
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…were taken from the room. See the
completed property receipt for a detailed list.
A green bathroom located on the first floor was searched and nothing
was taken.
A closet located just west of the green bathroom was searched. Two
…
giuffre-maxwell
1320-13
45 pg
…were taken from the room. See the
completed property receipt for a detailed list.
A green bathroom located on the first floor was searched and nothing
was taken.
A closet located just west of the green bathroom was searched. Two
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…her money.
19 Q. Had you seen this girl before at the El 19 Q. Is it fair to say that the girls who came
20 Brillo Way property? 20 to the Palm Beach residence, these are not the
21 …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…Natalya
Malyshov, Sarah Kellen, and Nadia Marcincova.
4. All Communications You have had in whatever form with any other female who you ever
witnessed at or in a property, home, business, plane or automobile other vehicle owned or
controlled by…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…Philip Barden, “to waive service of process.”
Indeed, “[o]nce documents have been properly transmitted to a Hague Convention Central
Authority, the period for completion of service of process may be extended, as ‘the timing of service
is out of…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…But, if Plaintiff insists that Ms. Ransome should testify at trial,
she must comply with properly served and propounded subpoena for testimony and records.
1
To avoid excessive and duplicative briefing on overlapping issues, Ms. Maxwell is submitting her
Response…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…01/15 Page 11 of 13
DOCUMENT REQUEST NO. 34
All documents reflecting your ownership or control of property in London between the years
1999 and 2002.
DOCUMENT REQUEST NO. 35
All documents reflecting your or Jeffrey Epstein’s membership…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…the present.
DOCUMENT REQUEST NO. 26
Produce all deeds and titles to all real property owned by You or held on Your behalf
either directly or indirectly at any time from January 2015 to the present.
DOCUMENT REQUEST NO. 27
…
giuffre-maxwell
1320-7
9 pg
…her money.
19 Q. Had you seen this girl before at the El 19 Q. Is it fair to say that the girls who came
20 Brillo Way property? 20 to the Palm Beach residence, these are not the
21 …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…But, if Plaintiff insists that Ms. Ransome should testify at trial,
she must comply with properly served and propounded subpoena for testimony and records.
1
To avoid excessive and duplicative briefing on overlapping issues, Ms. Maxwell is submitting her
Response…
giuffre-maxwell
gov.uscourts.nysd.447706.970.0
2 pg
…resisted the appellants’ and plaintiff Virginia Giuffre’s efforts
to unseal and release to the public materials and information we believe
properly were sealed.
Since the mandate has not issued and jurisdiction has not been returned to the
district court…
giuffre-maxwell
gov.uscourts.nysd.447706.1123.0
2 pg
…concerns may be help explain
the Doe 1 email. These two Does cannot properly formulate their objections or non-
objections until they have had a chance to review the excerpts mentioning them. For example,
they don’t really know how…
giuffre-maxwell
gov.uscourts.nysd.447706.223.7
3 pg
…Civ. P. 26(b)(1) or information (if any) that otherwise may properly be obtained
or used under the rules and in the action.
2. Mr. Epstein objects to the Subpoena to the extent that it seeks or purports to…
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