giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…facsimiles,
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions, tests, experiments…
giuffre-maxwell
gov.uscourts.nysd.447706.223.7
3 pg
…to the Subpoena
and all compliance efforts that may be sought or required under the Subpoena.
3. Mr. Epstein objects to videography as a form of recording of any deposition that
may occur.
4. Mr. Epstein objects to the Definitions…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…facsimiles,
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions, tests, experiments…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…of any nature and
computer interpretations thereof, instructions, announcements, and sound recordings of any
nature. “Document” also means all copies which are not identical to the original document as
originally written, typed or otherwise prepared. The term “Document” shall also…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…facsimiles,
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions, tests, experiments…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…minutes, rep011.s nnd
recordings of telephone or other conversations or communications, or of interview-s
Case 1:15-cv-07433-LAP Document 1320-31 Filed 01/03/24 Page 8 of 24
TO: .JEAN LUC BRU~EL
EXHIBIT A…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
1
Case 1:15-cv-07433-LAP Document 1320-32 Filed 01/03/24 Page 9 of 27
or conferences, or of…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…Epstein
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings ofteJcphone or other conversations or communic.ations, or of interviews
or conferences, 01' of other meetings, occurrences or transactions, affidavits, statements,
sllmmaries, opinions, tests, experiments…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…plaintiff’s motion to compel a response to Interrogatory no.
13 should be granted.
8
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 12 of 40
National Acad. of Recording Arts & Scis., Inc…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…on the final page, was the
4 interviewee. They make hay about the dates when the interview
5 was versus the date of recording. That's not unusual either,
6 your Honor. In the course of their work they will…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…on the final page, was the
4 interviewee. They make hay about the dates when the interview
5 was versus the date of recording. That's not unusual either,
6 your Honor. In the course of their work they will…
giuffre-maxwell
1320-32
27 pg
…work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
1
Case 1:15-cv-07433-LAP Document 1320-32 Filed 01/03/24 Page 9 of 27
or conferences, or of…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…they were cooperating fully. The proposed deliverables include ‘make
recommendations for measures to be put in place to prevent a recurrence’, ‘reappraise
existing risk assessments’ and ‘satisfy legal reporting and recording duties’. It is also
stated that, ‘due to the…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…Numerous courts, including this one, have admitted FBI 302s under this
authority. The statement is also trustworthy because it is simply the FBI’s recording of Ms.
Giuffre’s own statement and, of course, Ms. Giuffre is fully available to…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…Thus, plaintiff’s motion to compel a response to Interrogatory no.
13 should be granted.
8
Case 1:15-cv-07433-LAP Document 354 Filed 08/10/16 Page 12 of 40
National Acad. of Recording Arts & Scis., Inc…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…writings, photographs, and/or audio or video recordings made or recorded by or
of you on the dates on which you allege you were present with Alan M. Dershowitz,
including but not limited to your calendar, diary or journal entries…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…C. Obviously, Churcher’s notes, interviews and recordings are directly
relevant to Plaintiff’s original story about Ms. Maxwell, and how it has changed and morphed
over time, as well as the motivation for those changes.
The next allegation that…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…computer interpretations thereof,
instructions, announcements, and sound recordings of any nature. "Docwnent" also
means all copies which are not identical to the original document as originally written,
typed or otherwise prepared. The term "Document" shaU also include alJ documents of
…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.4
35 pg
…thrown out and speaking w Judge
Paul Cassal he suggested trying to get ahold of any photos and/or video recordings released by the FBI
to assist our case further in proving how much pedophilia occurred by Jeffrey and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…thrown out and speaking w Judge
Paul Cassal he suggested trying to get ahold of any photos and/or video recordings released by the FBI
to assist our case further in proving how much pedophilia occurred by Jeffrey and the…
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