giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…Preska:
We write on behalf of an anonymous third party, John Doe, in advance of the conference
scheduled for tomorrow in the above-referenced matter. As this Court well knows, the July 3,
2019 Opinion of the United States Court…
giuffre-maxwell
gov.uscourts.nysd.447706.27.0
3 pg
…by and through undersigned counsel, hereby moves this Court for an Order
granting Plaintiff’s counsel leave to bring Personal Electronic Devices and General Purpose
Computing Device into the Courthouse for the hearing currently scheduled for January 14, 2016,
in…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…with the plaintiff and not with
10 me.
11 The problem I see, your Honor, is that now we are
12 scheduled to have expert disclosures due in July, dispositive
13 motions in August, and a trial date in October…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.10
13 pg
…1 Jane Doe 2
2 know the extent of their relationship. But she
3 would schedule his appointments and handle clerical
4 things for him as far as I can see.
5 Q. All right.
6 And when you first…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…Thursday, both Ms. Menninger and I have other matters that are
24 previously scheduled and it would be impossible for us to take
25 care of those matters and be here at the same time. I'm
SOUTHERN DISTRICT REPORTERS…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…Filed 03/18/22 Page 5 of 25
Pursuant to the Court’s November 15, 2021, Amended Order concerning the briefing
schedule for the Non-Party Objectors, Plaintiff Virginia Giuffre files this Brief in Response to
Non-Parties 12, 28…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…a 30-day extension of the deadline). In order to give the Court the opportunity to rule as far in
advance as possible – thereby permitting counsel for both side to schedule the remaining
depositions – Ms. Giuffre brings the motion now…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.6_3
17 pg
… In your responsibilities in working
3 for Jeffrey, would you book massages for him
4 on any given day so that he would have a
5 massage scheduled? Would you take a call for
6 example and book a massage…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…a 30-day extension of the deadline). In order to give the Court the opportunity to rule as far in
advance as possible – thereby permitting counsel for both side to schedule the remaining
depositions – Ms. Giuffre brings the motion now…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.4
17 pg
… In your responsibilities in working
3 for Jeffrey, would you book massages for him
4 on any given day so that he would have a
5 massage scheduled? Would you take a call for
6 example and book a massage…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…2016 Email Correspondence from Sigrid McCawley. Ms. Maxwell waited until one day before
the first deposition scheduled to take place on May 31, 2016 to inform Ms. Giuffre’s counsel that she
refuses to attend the deposition of this subpoenaed…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.29
5 pg
…the area --
20 MR. LANGlNO: It is noon, so I don't know wha 20 A. No.
21 everybody else's schedule is. I don't know how 21 Q. -- sometimes? You mentioned she kept them in
22 you're…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.22_1
12 pg
…you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…a massage on Palm Beach. An acquaintance of Jane Doe
#4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4
to go to Epstein’s house to give him a massage. During that call…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…16 of 20
20. Identify all reasons why you failed to appear for a deposition scheduled in about
2009 to 2010 in a sexual assault civil suit filed against Jeffrey Epstein.
ANSWER:
Ms. Maxwell objects to this Interrogatory on the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…2016 Email Correspondence from Sigrid McCawley. Ms. Maxwell waited until one day before
the first deposition scheduled to take place on May 31, 2016 to inform Ms. Giuffre’s counsel that she
refuses to attend the deposition of this subpoenaed…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…in this matter; (c) establish a prompt schedule for any additional briefing or
hearing (ex parte or otherwise) that this Court deems necessary for the parties to
address any of these urgent and delicate matters in more comprehensive detail;
and…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.42
5 pg
…the area --
20 MR. LANGINO: It is noon, so I don't know wha 2O A. No.
21 everybody else's schedule is. I don't know how 21 Q. -- sometimes? You mentioned she kept them in
22 you're…
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