giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…Civ. P. 26 through 37
inclusive, or making or opposing any other motion or application, shall
quote or attach only those portions of the depositions, interrogatories,
requests for documents, requests for admissions, or other discovery or
disclosure materials, together with…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…Civ. P. 26 through 37
inclusive, or making or opposing any other motion or application, shall
quote or attach only those portions of the depositions, interrogatories,
requests for documents, requests for admissions, or other discovery or
disclosure materials, together with…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…Sent: Monday, 7 March 2011 8:46 PM
To : Virginia Giuffre
Subject: Re:
All understood. A lot of people are rooting for you .
You must do what is best for you and your family.
Where shall we meet? (Glorious weather ... …
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…Respondent(s) in this action.
At that time and place, you also shall produce the following items now in your custody or control:
See attached Schedule A ______
Names, addresses and telephone numbers of all counsel of record in this action…
giuffre-maxwell
gov.uscourts.nysd.447706.919.0
2 pg
…and Fed. R. Civ. P. 4l(a)(l)(A)(ii), this action shall be
DISMISSED WITH PREJUDICE, with each party to bear its own attorneys' fees and costs.
Dated: May 24, 2016 Respectfully Submitted,
FARMER, JAFFE, WEIS SING
…
giuffre-maxwell
gov.uscourts.nysd.447706.542.8
4 pg
…INCORPORATION
In compliance with Chapter 617, F. S., ( Not for Profit)
ARTICIS I NAME
The name of the cQrporation shall be:
Victims Refuse Silence, Inc.
I
ARTICLE H PRINCIPAL OFFICE
Principal…
giuffre-maxwell
gov.uscourts.nysd.447706.916.0
2 pg
…parties and Fed. R. Civ. P. 41(a)(1)(A)(ii), this action shall be
DISMISSED WITH PREJUDICE, with each party to bear its own attorneys' fees and costs.
Dated: May 24, 2016 Respectfully Submitted,
FARMER, JAFFE, WEISSING
…
giuffre-maxwell
gov.uscourts.nysd.447706.55.15
2 pg
…Ghislaine is putting the word out to her wealthy friends
that she is ready to sell,” and wants more than $20 million.
Ghislaine Maxwell on the Upper East Side Perhaps she hopes to put some distance between herself and Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…question, shall be reserved to the time of the
9 trial.
10 IT IS FURTHER STIPULATED AND AGREED
11 that the within deposition may be sworn to and
12 signed before any officer authorized to
13 administer an oath, with…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.10
15 pg
…she ' ll say i t ' s the
25 truth but I don't remembe r that.
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1331-10 Filed 01/05/24 Page 11 of 15
Page 20
1 - CONFIDENTIAL…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.19
22 pg
…that's fine. She'll
5 read.
6 THE VIDEOGRAPHER: That concludes today's
7 proceedings. We're off the record at 5:28.
8 (Proceedings concluded at 5:28 p.m.)
9
10 * * * * * * *
11
12
13
14
15
16…
giuffre-maxwell
1320-19
22 pg
…that's fine. She'll
5 read.
6 THE VIDEOGRAPHER: That concludes today's
7 proceedings. We're off the record at 5:28.
8 (Proceedings concluded at 5:28 p.m.)
9
10 * * * * * * *
11
12
13
14
15
16…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.13_1
23 pg
…that's fine. She'll
5 read.
6 THE VIDEOGRAPHER: That concludes today's
7 proceedings. We're off the record at 5:28.
8 (Proceedings concluded at 5:28 p.m.)
9
10 * * * * * * *
11
12
13
14
15
16…
giuffre-maxwell
gov.uscourts.nysd.447706.622.0
17 pg
…Such a statement shall include citations to all
statutes relied on and relevant facts as to citizenship and jurisdictional
amount.
3
Case 1:15-cv-07433-LAP Document 622 Filed 02/10/17 Page 4 of 17
4
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.2
56 pg
… First of all, I didn't know she had
19 an apartment in Palm Beach. I only learned
20 that from the many times you guys have gone
21 to the press to sell stories, so no.
22 Q. Did…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…unlimited and may not unnecessarily
intrude into private matters, in the instant case inquiry into private matters is clearly relevant to
the subject matter of the suit. Accordingly, plaintiff Misty Weber shall respond to defendants'
interrogatories concerning her sexual partners . . . .”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…3288389, at *5 (E.D.N.Y. July 22, 2019) (“[T]he docketing and unsealing of these
two items shall be STAYED for 30 days, and, if the United States files a notice of
appeal within that time period, thereafter…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…For example, she testified that she wrote to the NY Post reporter, Maureen
Callahan, in an attempt to sell her story to the media, in or about October 2016. Pottinger Ex. 1
at 38 (“I emailed her after I read…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…37, the moving
party shall specify and quote or set forth verbatim in the motion papers each discovery request
and response to which the motion or application is addressed.” For all of the discovery items
upon which Defendant moves, Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…For example, she testified that she wrote to the NY Post reporter, Maureen
Callahan, in an attempt to sell her story to the media, in or about October 2016. Pottinger Ex. 1
at 38 (“I emailed her after I read…
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