giuffre-maxwell
gov.uscourts.nysd.447706.1256.29
6 pg
…asseur,
” “ therapy” etc.asyou requested,
butyou w ould stilllikem etosearchasubsetof124-341 surnam esnam esforallcom m unicationsw ithcertain
w itnessesthatyou believerelateto“ m assages.” IsaidIw ould lookatyourlist,w henyou send it,and evalu…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.7
6 pg
…asseur,
” “ therapy” etc.asyou requested,
butyou w ould stilllikem etosearchasubsetof124-341 surnam esnam esforallcom m unicationsw ithcertain
w itnessesthatyou believerelateto“ m assages.” IsaidIw ould lookatyourlist,w henyou send it,and evalu…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…relate to your RFP number 5 (“All documents relating to massages…”). I
represented to you that I have searched for the terms “massage,” “masseur,” “therapy” etc. as you requested,
1
Case 1:15-cv-07433-LAP Document 1327…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.8
6 pg
…believethatsearchterm s124-341,w hicharew itnessnam esbrokenupintofirstand last
nam esfrom yourR ule26 list,relatetoyourR FP num ber5 (“ Alldocum entsrelatingtom assages… ” ).I
represented toyou thatIhavesearchedfortheterm s“ m assage, ” “ m asseur,
” “…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…relate to your RFP number 5 (“All documents relating to massages…”). I
represented to you that I have searched for the terms “massage,” “masseur,” “therapy” etc. as you requested,
but you would still like me to search a subset…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.30
6 pg
…believethatsearchterm s124-341,w hicharew itnessnam esbrokenupintofirstand last
nam esfrom yourR ule26 list,relatetoyourR FP num ber5 (“ Alldocum entsrelatingtom assages… ” ).I
represented toyou thatIhavesearchedfortheterm s“ m assage, ” “ m asseur,
” “…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…During the deposition, the Non-Party testified that they had undergone extensive
therapy to overcome the trauma and did not want to be involved in the proceedings at all. Doe
#84’s name was mentioned in some of the sealed…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.29
5 pg
…I pick her
7 MR. BERGER: I would ask that U1e court 7 up from high school sometimes. But she was not a
8 reporter initial tJiat. 8 massage therapist. She will go for dinner. And
9 MS. EZELL: Sure…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.10
15 pg
…nde r stand what
20 you and your lawyer have said here t oday , yo u have
21 been i nvolved in some n umber of years of therapy , i n
22 which the purpose -- part o f t he…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Maxwell already had
run the Plaintiff’s proposed terms related to massages, including “massage,” “masseuse,”
“masseur,” and “therapy.” In effect, Plaintiff proposed search terms sought to expand her
discovery requests from communications with a discrete set of individuals to all…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.42
5 pg
…I pick her
7 MR. BERGER: I would ask that the court 7 up from high school sometimes. But she was not a
8 repo1ter initial that. 8 massage therapist. She will go for dinner. And
9 MS. EZELL: Sure…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…emotional
problems, psychological or psychiatric disorders, sexually transmitted diseases, and
therapy records, and any prescriptions for any of the above categories.
25. Any Documents containing any Communications You have had with any law
enforcement agency.
26. Any Documents that reflect…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…psychological
or psychiatric disorders, sexually transmitted diseases, and therapy records, and any prescriptions
for any of the above categories.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a non…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…of confidentiality under the Protective Order. During the deposition,
this Doe testified that she had undergone extensive therapy to overcome the trauma and did not
want to be involved in the proceedings at all. The Second Circuit sua sponte redacted…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…psychological
or psychiatric disorders, sexually transmitted diseases, and therapy records, and any prescriptions
for any of the above categories.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a non…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…emergency care or other
treatment for any eating disorder, malnourishment, kidney malfunction, emotional problems,
psychological or psychiatric disorders, sexually transmitted diseases, and therapy records, and
any prescriptions for any of the above categories. (Complaint ¶ 52, 64; motivation to fabricate)
25…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…doctor, nurse,
psychiatrist, psychologist, counselor, therapist, social worker, or other medical or mental health
care practitioner, and includes any Person or entity referred to as a “Health Care Professional” or
“Health Care Institution” in Colorado Revised Statute § 13-64-202…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…Court is aware, this defamation case involves Ms. Giuffre's assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being "massage therapists." See Complaint, (DE 1). at~ 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.10
13 pg
…do not know.
13 MR. PAGLIUCA: Object to form.
14 BY MR. EDWARDS:
15 Q. Were you going out to look for a massage
16 therapist, a professional massage therapist to bring
17 to him?
18 A. No.
19 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being “massage therapists.” See Complaint, (DE 1), at …
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