giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1124.0_3
2 pg
…7433-LAP
Dear Judge Preska,
Plaintiff writes in response to Defendant’s letter dated September 30, 2020, seeking
clarification from the Court regarding Doe 1 and Doe 2’s communication to the Court. ECF No.
1123. As a preliminary matter…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…particular, Ms. Giuffre seeks to ask the Defendant questions
regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s
sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this
case, particularly…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…particular, Ms. Giuffre seeks to ask the Defendant questions
regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s
sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this
case, particularly…
giuffre-maxwell
gov.uscourts.nysd.447706.768.0
23 pg
…Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF MS. GIUFFRE’S RESPONSE TO
DEFENDANT’S MOTION TO PROHIBIT QUESTIONING
REGARDING DEFENDANTS’ ADULT CONSENSUAL ACTIVITIES
…
giuffre-maxwell
gov.uscourts.nysd.447706.1292.0
2 pg
…v. Maxwell, Case No. 1:15-cv-07433-LAP
Dear Judge Preska:
Doe 171 writes to respectfully request a status conference in front of Your
Honor regarding her December 5, 2022 Letter Motion (Doc. 1285) and the
December 7, 2022…
giuffre-maxwell
1320-6
10 pg
…particular, Ms. Giuffre seeks to ask the Defendant questions
regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s
sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this
case, particularly…
giuffre-maxwell
gov.uscourts.nysd.447706.854.0
3 pg
…and Steven A. Williams in support of Plaintiff’s Briefing on an Adverse
Inference Instruction Regarding Defendant’s Failure to Comply with This Court’s Orders to
Produce Her Electronic Documents and Communications (DE 838) filed on April 7, 2017.…
giuffre-maxwell
gov.uscourts.nysd.447706.223.6
4 pg
… [email protected] ;
mailto:[email protected] ; Meredith Schultz
Subject: RE: SERVICE - Epstein Deposition
Hello Marty,
Thank you for your response regarding our subpoena to Jeffrey Epstein. You have
represented that Mr. Epstein will agree to accept service of…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.6
4 pg
…Denver, CO 80203
Re: Giuffre v. Maxwell
Case no. 15-cv-07433-R\VS - Regarding Certificates of Service
Dear Laura,
I have lawfully served the witnesses in this case, and have undertaken great effort to
serve Ms. Marcinkova and Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…3771.
DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the…
giuffre-maxwell
gov.uscourts.nysd.447706.5.0
2 pg
…travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.7
14 pg
…18 REPORTER'S NOTE:
Since this deposition has been realtimed and
19 is in rough draft form, please be aware that
there may be a discrepancy regarding page and
20 line number when comparing the realtime
screen, the rough draft…
giuffre-maxwell
gov.uscourts.nysd.447706.3.0
2 pg
…travel and $ for services, for a total of $ 0.00 .
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
…
giuffre-maxwell
gov.uscourts.nysd.447706.602.0
11 pg
…of Dr. Phillip W. Esplin (hereinafter
“Esplin”).
PRELIMINARY STATEMENT
Ms. Giuffre has moved to exclude three opinions offered by Defendant’s expert Esplin,
specifically any opinions regarding
See McCawley Dec. at Exhibit 1, Defendant has already
c…
giuffre-maxwell
gov.uscourts.nysd.447706.239.1
11 pg
…I am now repeating to you what I said then
regarding our availability to participate in person as counsel for Ms.
Maxwell.
-Laura
2
Case 1:15-cv-07433-LAP Document 239-1 Filed 06/21/16 Page 4 of…
giuffre-maxwell
gov.uscourts.nysd.447706.8.0
2 pg
…0.00
I declare under penalty of perjury that this information is true.
Date: q z? lf {
s.t
lQ,r, til
…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…about being a sex slave.
18. All documents concerning any monetary payments or other consideration received by
you from any media outlet in exchange for your statements (whether “on the record” or
“off the record”) regarding Jeffrey Epstein, Alan M…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre
objects to this interrogatory in that it seeks protected information regarding confidential
investigations. Ms. Giuffre objects in that it seeks information protected by the attorney-client…
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