giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…March call to identify what date is
reflected on those reports, but Defendant is resisting production of those documents. Upon receipt of
the newly produced police reports, counsel for Ms. Giuffre immediately informed counsel for
Defendant that she would like…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…with that Order. The parties are further directed to jointly file a proposed redacted version
of this Opinion or Notify the Court that none are necessary within two weeks of the date of receipt of this Opinion.”
June 20, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…are.
a. There is no evidence that Doe 1 received or read the Notice from the Court,
nor even that Doe 1 is still living. The return receipt was signed for by someone other than
Doe 1. Ex. A.
b…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…person . . . .” The purpose of “requiring delivery to a
named person is to ‘ensure receipt, so that notice will be provided to the recipient, and
enforcement of the subpoena will be consistent with the requirements of due process.’”
Aristocrat Leisure Ltd…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…Court’s Order, Non-Parties Cannot Challenge
Confidentiality Designations and Dershowitz has Already Agreed to
be Bound by the Parties’ Confidentiality Designations in Exchange for
Receipt of Documents
The Protective Order (DE 62) does not allow …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…ONLY
!£ s:::::::::
RECEIPT II AMOUNT !FP JUDGE MAG JUDGE
Case 1:15-cv-07433-LAP …
giuffre-maxwell
1320-8
12 pg
…person . . . .” The purpose of “requiring delivery to a
named person is to ‘ensure receipt, so that notice will be provided to the recipient, and
enforcement of the subpoena will be consistent with the requirements of due process.’”
Aristocrat Leisure Ltd…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…with that Order. The parties are further directed to jointly file a proposed redacted version
of this Opinion or Notify the Court that none are necessary within two weeks of the date of receipt of this Opinion.”
June 20, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…copy of Your passport that was valid for any
part of that time period, any visa issued to You for travel, any visa application that
You prepared or which was prepared on Your behalf, and travel itinerary, receipt, log,
or
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…person . . . .” The purpose of “requiring delivery to a
named person is to ‘ensure receipt, so that notice will be provided to the recipient, and
enforcement of the subpoena will be consistent with the requirements of due process.’”
Aristocrat Leisure Ltd…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…in any sequence, and (B) discove1y by one paiiy does not
require any other party to delay its discove1y."). Likewise, receipt of Ms. Maxwell's Rule 26
disclosures in Febmaiy also had nothing to do with these witnesses. Id. Notably…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…to attempt to support what
otherwise was an inadequate investigation and shotgun filing, without Dershowitz being able to
test the timing of Plaintiffs’ receipt and review of that evidence. Plaintiffs cannot be allowed to
use the attorney-client privilege or…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…allegations.
Furthermore, for the period after Epstein was indicted for sex crimes against children,
documents showing Defendant’s continued communications with Epstein and his associates,
documents showing receipt of payments from Epstein, and documents showing her attempts to
cover up…
giuffre-maxwell
gov.uscourts.nysd.447706.75.0
31 pg
…work product, and joint/common defense privilege cannot be tested. Ms.
Maxwell anticipates that upon receipt of this requested information, counsel will be able to
identify significant numbers of documents on Plaintiff’s privilege log unjustifiably withheld.
B. Plaintiff cannot…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…records indicating passengers traveling with
you, hotel records, and credit card receipts.
a. Maxwell’s Response:
Maxwell objects to this Request on the grounds that it is overly broad, unduly
burdensome and/or propounded for the improper purpose of annoying…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…any documents responsive to Request 26. As to the
remaining requests:
Request 12 – Ms. Ransome testified that she does not have any credit card receipts,
cancelled checks, or documents reflecting travel from 2006-2007, other than what she has…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…any documents responsive to Request 26. As to the
remaining requests:
Request 12 – Ms. Ransome testified that she does not have any credit card receipts,
cancelled checks, or documents reflecting travel from 2006-2007, other than what she has…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…whether published or not), notes (handwritten or not),
memoranda, mobile phone agreements, wire transfer receipts, or any other document that
concerns Plaintiff in any way, whether or not they reference her by name.
RESPONSE: Ms. Maxwell objects to this Request…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…to be sent to the
lab for testing. See property receipts.
This investigator then conducted an interview with Fire/Rescue
Officer Ellen F. Delai who was in the rescue wagon with tbe victim
while she was being transported to the…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…to Request 26. As to the
remaining requests:
! Request 12 – Ms. Ransome testified that she does not have any credit card receipts,
cancelled checks, or documents reflecting travel from 2006-2007, other than what she has
already produced. See Pottinger…
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