giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…production on February 8, 2016. All documents identified as responsive were reviewed by
counsel and either produced or placed on a privilege log. The First Responses were the subject
of litigation in March and April 2016. This Court limited the…
giuffre-maxwell
gov.uscourts.nysd.447706.1097.0_1
6 pg
…DERSHOWITZ,
Defendant.
VIRGINIA L. GIUFFRE,
Plaintiff,
No. 15 Civ. 7433 (LAP)
-against-
ORDER
GHISLAINE MAXWELL,
Defendant.
LORETTA A. PRESKA, Senior United States District Judge:
The Co…
giuffre-maxwell
gov.uscourts.nysd.447706.205.0
7 pg
…Apple,
Inc. for all of the records associated with her “iCloud” email account. Counsel for Ms. Giuffre
has already reviewed Ms. Giuffre’s account for responsive records. Defendant is not entitled to
all emails that Ms. Giuffre may have ever…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…The objections and responses to the RFPs are proper. ................................................ 1
A. RFP No. 1: Documents defense counsel “reviewed and/or relied upon” in a phone
call with Plaintiff’s counsel. ...................................................................................... 1
B. RFP N…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
… Thank you, lawyers.
19 In talking about the phases through which the review
20 will proceed, first, the parties' briefed and the Court
21 reviewed the documents associated with the 16 nonparty
22 objectors; and, second, the parties briefed and…
giuffre-maxwell
gov.uscourts.nysd.447706.1134.0_5
2 pg
…Whereas Plaintiff’s proposed redactions adhered to
each of the Court’s prior orders (and were reviewed and approved by the Court previously),
Maxwell repeated her assertion that large portions of these materials (including sections of
Maxwell’s deposition transcript…
giuffre-maxwell
gov.uscourts.nysd.447706.1135.0_6
1 pg
…for Ms. Maxwell received Plaintiff’s proposed
redactions. Counsel reviewed the proposed redactions to Ms. Maxwell’s 465-page deposition
transcript and conferred with Plaintiff’s counsel regarding her proposed redactions during a
telephone conference at 1 p.m. today…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…production on February 8, 2016. All documents identified as responsive were reviewed by
counsel and either produced or placed on a privilege log. The First Responses were the subject
of litigation in March and April 2016. This Court limited the…
giuffre-maxwell
gov.uscourts.nysd.447706.39.1
7 pg
…be placed near the Bates number.
8. Designation of a document as CONFIDENTIAL INFORMATION shall
constitute a representation that such document has been reviewed by an
attorney for the designating party, that there is a valid and good faith basis…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…the United States District Court for the Southern District of New
York (Preska, J.) individually reviewed and unsealed voluminous
Case:
Case:24-182,
24-182,01/08/2026,
07/23/2025,DktEntry:
DktEntry:102.1,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.18
8 pg
…when you
7 met Jeffrey Epstein?
8 A. Sixteen or 17.
9 Q. Okay. And have you reviewed --
10 A. I may have been 15. I don't recall. I
11 apologize.
12 Q. If you told the police officer…
giuffre-maxwell
gov.uscourts.nysd.447706.753.1
7 pg
…2 MS. MENNINGER: Your Honor, I actually believe that
3 these emails were some that your Honor had reviewed because we
4 had asserted a joint defense agreement privilege, and your
5 Honor reviewed these emails, and they were produced…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…2d
Cir. 2019), the United States District Court for the Southern District of New
York (Preska, J.) individually reviewed and unsealed voluminous
CERTIFIED COPY ISSUED ON 07/23/2025
Case: 24-182, 07/23/2025, DktEntry: 95.1, Page…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…I've tried
14 to do that in our papers. But listening to opposing counsel
15 I'm concerned maybe she hasn't reviewed the documents we have
16 produced. We have clearly produced all of the media
17 communications…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…Ms. Giuffre is withholding documents based on her objections.
2. All Documents reviewed or relied upon in answering Interrogatory Nos.
1-14 above.
Response to Request No. 2
Ms. Giuffre objects to this request in that defendant’s interrogatories violate…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…regarding sex abuse, sexual trafficking and acting as his
“madam” to the stars. As proof, one need look no further than emails already reviewed
by this Court. In an email sent by Epstein to Ms. Maxwell on January 25, 2015…
giuffre-maxwell
gov.uscourts.nysd.447706.1058.1
3 pg
…the same discovery materials will likely have to be reviewed and re-produced,
needlessly causing duplication of effort and extra expense.”).
The following is a list of objections or responses based upon the Protective Order in
Maxwell which Professor Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…before it was filed in September of 2015, as
evidenced by the email communications between Dershowtiz and Defendant the Court reviewed in its in camera
review before ordering Defendant to produce them. Yet Dershowitz waited until after discovery closed and…
giuffre-maxwell
gov.uscourts.nysd.447706.1126.0
3 pg
…order articulated and applied the correct legal
framework in its individualized review of the materials to be unsealed.
CONCLUSION
We have reviewed all of the arguments raised by Defendant-Appellant Maxwell on appeal
and find them to be without merit…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…underaged individuals in that directory
16 with their phone numbers. So we reviewed that with him.
17 He has testimony about the fact that the black book
18 was something that was kept in the course of their work. It…