giuffre-maxwell
gov.uscourts.nysd.447706.1320.14
3 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.447706.1326.2
3 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
1320-14
3 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.447706.1090.28_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.447706.1328.28
24 pg
…Fort Lauderdale, FL 33301 (954) 356-0011
0 Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…450 COMMERCE
I J 150 RE COVERY OF [ J 330 FEDERAL INJURY PRODUCT I ] 460 DEPORTATION
OVERPAYM ENT & EMPLOYERS' LIABILITY PROPERTY RIGHTS …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…conferral.
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.
RESPONSE: Ms. Maxwell objects to…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…as RANSOME_000001-000016, which should be treated as
Confidential pursuant to the parties’ Protective Order.
4. All Communications You have had in whatever form with any other female who you ever
witnessed at or in a property, home, business…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…INTERVENE AND UNSEAL
1
Case 1:15-cv-07433-LAP Document 1259 Filed 07/28/22 Page 2 of 17
TABLE OF CONTENTS
MEMORANDUM OF LAW ..................................................................................................…
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.447706.1332.8
27 pg
…as RANSOME_000001-000016, which should be treated as
Confidential pursuant to the parties’ Protective Order.
4. All Communications You have had in whatever form with any other female who you ever
witnessed at or in a property, home, business…
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.447706.1330.15
43 pg
…58 □ 375 False Claims Act
D 120 Maiine D 310 Airplane 0 365 Personal htju,y • of Property 21 USC 88 I 0 423 Withdrawal □ 376 Qui Tam (31 USC
D 130 Miller Act 0 315 Airplane Product …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…as RANSOME_000001-000016, which should be treated as
Confidential pursuant to the parties’ Protective Order.
4. All Communications You have had in whatever form with any other female who you ever
witnessed at or in a property, home, business…
giuffre-maxwell
gov.uscourts.nysd.447706.513.0
21 pg
…motion,
in part, as untimely).
“Spoliation is the destruction or
significant alteration of evidence, or the failure to preserve property for another's use as evidence
in pending or reasonably foreseeable litigation.” Kraus v. General Motors Corp., 2007 WL
3146911…
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
1320-17
25 pg
…conferral.
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.
RESPONSE: Ms. Maxwell objects to…
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