giuffre-maxwell
gov.uscourts.nysd.447706.345.0
18 pg
…L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS
SUBJECT TO IMPROPER OBJECTION AND IMPROPER CLAIM OF PRIVILEGE
Plaintiff Virginia Giu…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…70
day.co.uk]
To: Sharon [email protected][Sharon.Churcher@mailonsun
From: Jenna
·sent: Mon 3/7/2011 10:55:59 AM
Importance: Normal
Subject: RE: Re:
Received: Mon 3/7/2011 10:55:59 AM
Hi again ,
…
giuffre-maxwell
gov.uscourts.nysd.447706.223.3
2 pg
…April 11, 2016 8:45 AM
To: Sigrid McCawley
Cc: Martin Weinberg
Subject: Giuffre v maxwell
Sigrid, if you will agree to schedule tbe depo near his Virgin Island residence for a
mutually agreeable date in June I can accept…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.223.6
4 pg
…[email protected] ;
cassello©law.ytah.edu ; Meredith Schultz ; [email protected]
Subject: Re: SERVICE - Epstein Deposition
Hi Sigrid. Mr. Epstein is in agreement to proceed with a VI deposition and to accept service
for that deposition. I understand the issue…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.6
4 pg
…Cc: Sigrid Mccawley; Paul Cassell ([email protected]); '[email protected]'
([email protected])
Subject: Proof of Service - Second Email
Attachments: Proof of Services
Laura,
I am writing to follow up on m…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
1320-37
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…33.3. Defendant
has served interrogatories that are in direct violation of that Rule because the interrogatories are
not “restricted to those seeking names of witnesses with knowledge of information relevant to
the subject matter of the action, the computation…
giuffre-maxwell
gov.uscourts.nysd.447706.223.5
3 pg
…From: Meredith Schultz
Sent: Thursday, May 26, 20164:25 PM
To: Martin G. Weinberg; Sigrid McCawley
Subject: RE: SERVICE· Epstein Deposition
OK, thanks.
Meredith L. Schultz
BOIES. SCHILLER & FLEXNER LLP
40 I East Las OIas Blvd., Suite 1200
Fort Lauderdale…
giuffre-maxwell
gov.uscourts.nysd.447706.239.1
11 pg
…Cc: Sigrid McCawley; Martin G. Weinberg; Jeff Pagliuca;
[email protected]; Meredith Schultz
Subject: RE: SERVICE - Epstein Deposition
Mr. Edwards and Ms. McCawley -
As I informed Ms. McCawley in my June 9, 2016 letter, I represent Jeffrey Epstein with…
giuffre-maxwell
gov.uscourts.nysd.447706.223.4
2 pg
…G. Weinberg
Sent: Wednesday, May 25, 2016 2:58 PM
To: [email protected] ; [email protected]
Subject: Fw: Giuffre v maxwell
Hi Sigrid. I found the April 11 pre-court morning email, see below. As I
emailed earlier, I…
giuffre-maxwell
gov.uscourts.nysd.447706.1124.0_3
2 pg
…enough. Although Plaintiff is sensitive to the fact that Doe 1 and Doe 2 are proceeding
pro se, their communication indicates that they know the subject-matter of the documents that
mention them, for example testimony in this case, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…were retained
to represent her in this matter. The privacy interests at stake in this litigation are the
subject of considerable complexity that Doe 171’s undersigned counsel are still
attempting to digest. Although Doe 171’s undersigned counsel still…
giuffre-maxwell
gov.uscourts.nysd.447706.409.2
1 pg
…District Court for the Southern District of New
York. All attorneys appearing before this Court are subject to the Local Rules of this Court,
including the Rules governing discipline of attorneys.
DONE AND ORDERED on this day of August, 2016.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…To develop evidence to support her position, Ms. Giuffre recently deposed Defendant
about the central subjects in her case. Defendant flatly refused to answer a number of questions,
and for the majority of the others, gave varying versions of “I…
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