giuffre-maxwell
gov.uscourts.nysd.447706.55.10
10 pg
…4 A. She is being sued by Virginia Roberts for
5 defamation, not for the underlying offenses, which
6 are beyond the statute of limitations, as I
7 understand it, correct.
8 Q. And have you spoken with Ghislaine Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…him again.”
Instead, Boies said that Dershowitz has reverted to a “very sad” PR campaign against the lawyers
representing Roberts.
Dershowitz disputed Boies’s comments that he declined to waive the statute of limitations, saying that he
filed an affidavit…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…of
the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution ofthe
United States to a speedy trial or to bar the prosecution by reason of the running of the statute
of limitations for a period of…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…charges against me. I waive any statute of limitations,
any immunity, because if she files a false rape charge against me, she goes to jail.
The end result of this case should be she should go to jail, the lawyers…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…state.
7. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
8. The words “relate,” “relating,” “relates,” or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…state.
7. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
8. The words "relate," "relating," "relates," or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…7. Unless instructed otherwise, each Request shall be construed independently and not
by reference to any other Request for the purpose of limitation.
8. The \vords "relate," "relating," "relates," or any other derivative thereot~ as used
herein includes concerning, referring…
giuffre-maxwell
1320-32
27 pg
…state.
7. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
8. The words "relate," "relating," "relates," or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…stale.
7. Unless instrncted otherwise, each Request shall be constrned indepcnde11tly and
not by reference to any other Request for the purpose of limitation.
8. The words "relate." "relating," ' 1relates," or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…state.
6. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
7. The words “relate,” “relating,” “relates,” or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…interests. Finally, like Mr.
Dershowitz’s original Motion, the Government here seeks all deposition material and exhibits,
sealed or unsealed, without any limitations on the scope of the needs of their case against Mr.
Epstein’s estate. (Doc. # 1113, p…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…state.
7. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
8. The words “relate,” “relating,” “relates,” or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…or
alluded to in Your Complaint, or any that could be included in any amended complaint in this
action.
7. “Employment” includes without limitation, the provision of work and/or services,
whether paid or unpaid, whether as an employee, intern…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…standards in
Federal Rule of Evidence 502. In 2008, Congress enacted Federal Rule of Evidence 502, which
is entitled “Attorney-Client Privilege and Work Product; Limitations on Waiver.” New rule 502
places a number of protections in place to reduce…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…dissemination of confidential information or
information which will properly annoy, embarrass, or oppress any
party, witness, or person providing discovery in this case." ECF
Dkt. 62. The Protective Order applied broadly "to all documents,
materials, and information, including without limitation…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…standards in
Federal Rule of Evidence 502. In 2008, Congress enacted Federal Rule of Evidence 502, which
is entitled “Attorney-Client Privilege and Work Product; Limitations on Waiver.” New rule 502
places a number of protections in place to reduce…
giuffre-maxwell
1320-18
40 pg
…standards in
Federal Rule of Evidence 502. In 2008, Congress enacted Federal Rule of Evidence 502, which
is entitled “Attorney-Client Privilege and Work Product; Limitations on Waiver.” New rule 502
places a number of protections in place to reduce…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…7
Statutes
Fed. R. Civ. P. 26 ......................................................................................................................3, 22
Fed. R. Civ. P. 37 ........................................................................................................................4, 8
Fed. R. Evid. 501 ...............…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…1328-18 Filed 01/05/24 Page 3 of 50
4. Sexual Assault Records are a Medical Event and Are Barred by This
Court’s Order ............................................................................................23
5. Information About Ms. Giuff…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…investigation of the same, which have been previously
produced, are available in the public domain, or referenced in court papers. Defendant also
refers Plaintiff to documents within the possession, custody and control of Plaintiff and her
counsel, including without limitation…
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