giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…Buckingham Palace issued a statement which said, "It is emphatically denied that the Duke of
York [Andrew] had any form of sexual contact or relationship" with the woman. "Any claim to the contrary is false and
without foundation."
Andrew is…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.21
8 pg
…the following privileges are asserted pursuant to British law, Colorado law and NY law.
DATE DOC. FROM TO CC RELATIONSHIP SUBJECT MATTER PRIVILEGE
TYPE OF PART…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…AUTHORITIES ...................................................................................................... iii-v
PRELIMINARY STATEMENT .....................................................................................................1
FACTUAL AND PROCEDURAL BACKGROUND...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.10
13 pg
…within and
for the State of Florida.
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 3 of 13
Page 16
1 Jane Doe 2
2 know the extent of their relationship…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…TO SHOW THAT CHURCHER WAS NOT
ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3
A. The “Primary Relationship” Between Churcher and Plaintiff Was
Reporter and Source ...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.263.0
14 pg
…TO SHOW THAT CHURCHER WAS NOT
ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3
A. The “Primary Relationship” Between Churcher and Plaintiff Was
Reporter and Source ...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.55.15
2 pg
…38pm
Ghislaine Maxwell is quietly selling her New York townhouse on East 65th Street amid
renewed gossip about her relationship with disgraced mogul Jeffrey Epstein.
M…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.6
8 pg
…the following privileges are asserted pursuant to British law, Colorado law and NY law.
DATE DOC. FROM TO CC RELATIONSHIP SUBJECT MATTER PRIVILEGE
TYPE OF PART…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.14_1
11 pg
…12 Q. Do you know
13 A. I do.
14 Q. What is your relationship with
15
16 MR. PAGLIUCA: Object to the form.
17 A. What do you mean what is my
18 relationship.
19 Q. Are you friendly…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.1
2 pg
…and painful loss over the last few days that I can't even see what life
after press he'll even looks like - statements that don't address all just lead to more questions ..what is my
relationship to clinton …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
…EMA: Object to th e form.
17 A Fifth. 17 A Fi fth.
18 Q How ma ny times have you l"idden on the 18 Q Whnt is Jeffrey E pstein's rclalionship
19 nirplane with Jean Luc Brunel'! …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…I can't even see what life
after press he'll even looks like - statements that don't address all just lead to more questions .. what is my
relationship to clinton ? Andrew on and on.
Let's rest till monday…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.26
4 pg
…given his
relationship with Ross and Diane Sawyer.
It was during a Sawyer interview on ABC’s PrimeTime Live that the ex-cop said he was sorry for remarks he made that may
have influenced the jury to acquit Simpson…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.19
15 pg
… I don't recollect, and I don't
8
9
10
to what
Jeffrey.
-
recollect how I met
-
and I can't testify
relationship is or is not with
11 Q. Have you ever talked to Jeffrey
12
13
14…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…satisfied .................................................. 18
III. There is No Privilege as to Communications with Scarola ............................................ 22
a. There is no Attorney-Client Relationship .......................................................................... 22
b. Work Product Privilege has…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…received or sent or discussed. Your search terms include Philip
Barden who the court has already ruled maintains an attorney-client relationship with our client (and to the extent
others are copied on his emails, those would be captured by…
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…sound and obvious reason for unsealing,
which is that numerous public sources, including a federal complaint she herself voluntarily filed,
have already identified her, and described her relationship with Jeffrey Epstein. On these bases
alone, Doe 171’s motion fails…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…Id.
(suggesting limitations on searches of names to “make some effort to match them to actual
people who have some relationship to this case (like first name /3 last name or some parts
thereof)”).
After explaining the appropriate and well…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…satisfied .................................................. 18
III. There is No Privilege as to Communications with Scarola ............................................ 22
a. There is no Attorney-Client Relationship .......................................................................... 22
b. Work Product Privilege has…
giuffre-maxwell
gov.uscourts.nysd.447706.34.1
6 pg
… Case 1:15-cv-07433-RWS Document 34-1 Filed 02/26/16 Page 3 of 6
TAB DATE DOC. FROM TO CC RELATIONSHI SUBJECT PRIVILEGE
TYPE P MATTER
15. …
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