giuffre-maxwell
gov.uscourts.nysd.447706.1325.13
2 pg
…are not the intended recipient, do not read, use, disseminate, distribute or copy this message or
attachments. If you have received this message in error, please notify the sender immediately and delete this message
together with any attachments.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…All the best
David Brown
Reporter
The Times
"Please consider the environment before printing this e-mail"
Newsworks - bringing advertisers and newsbrands together
www.newsworks.org.uk
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…included the name “max*” well aware that our client’s surname, and that of all of her paternal family members,
will begin with those three letters together. Your search terms thus are likely to yield every single email sent or…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Maxwell is submitting her
Response to the Motion for Protective Order together with her Motion to Compel.
2
In their letter motion to the Court of January 19 as well as during the hearing of February 2 on this topic…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…13 MR. GUIRGUIS: No, you do
14 need to answer this.
15 A. Okay. We've been together
16 almost a year.
17 Q. And what is your current
18 occupation?
19 A. I'm a writer.
20 Q. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…fully below, the Requested Documents, separately and
together, demonstrate that the allegations of sexual misconduct lodged and repeated by Ms.
Giuffre are nothing more than a recent fabrication— a made up story designed to increase
commercial interest in Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…Maxwell is submitting her
Response to the Motion for Protective Order together with her Motion to Compel.
2
In their letter motion to the Court of January 19 as well as during the hearing of February 2 on this topic…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…1998, Ms. Giuffre was 14 years old. Ms. Giuffre recalls
one facility named “Growing Together” that was located in or around
Palm Beach, but she does not recall the dates when she resided at the
facility.
! From 2000-2002, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…13 MR. GUIRGUIS: No, you do
14 need to answer this.
15 A. Okay. We've been together
16 almost a year.
17 Q. And what is your current
18 occupation?
19 A. I'm a writer.
20 Q. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…with and
went shopping with her at the Palm Beach Mall, where they purchased items from
Victoria's Secrets. After spending the day together, they went over to the Palm Beach
house, where Epstein requested to see what was purchased…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…13 MR. GUIRGUIS: No, you do
14 need to answer this.
15 A. Okay. We've been together
16 almost a year.
17 Q. And what is your current
18 occupation?
19 A. I'm a writer.
20 Q. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…This Firm does not accept service by electronic mail or facsimile.
A list of partners, together with further legal statements, is available upon request or at
www.devonshires.co .uk/terms-and-conditions/legal-notices.html
giuffre-maxwell
gov.uscourts.nysd.447706.1327.15
5 pg
…included the name “max*” well aware that our client’s surname, and that of all of her paternal family members,
will begin with those three letters together. Your search terms thus are likely to yield every single email sent or…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…with and
went shopping with her at the Palm Beach Mall, where they purchased items from
Victoria's Secrets. After spending the day together, they went over to the Palm Beach
house, where Epstein requested to see what was purchased…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…1998, Ms. Giuffre was 14 years old. Ms. Giuffre recalls
one facility named “Growing Together” that was located in or around
Palm Beach, but she does not recall the dates when she resided at the
facility.
! From 2000-2002, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…Ms. Giuffre was 14 years old. Ms. Giuffre recalls
one facility named “Growing Together” that was located in or around
Palm Beach, but she does not recall the dates when she resided at the
facility.
From 1999-2002, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…And
went shopping with her at the Palm Beach Mall, where they purchased items from
and
Victoria's Secrets. After spending the day together, they went over to the Palm Beach
house, where Epstein requested…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…Donald Trump liked flicking and sucking her nipples
until they were raw. One evening when we were showering together she showed me her
nipples. They looked incredibly painful as they were red and swollen and I remember
wincing when I…
giuffre-maxwell
gov.uscourts.nysd.447706.64.0
14 pg
…deposition notices on witnesses and their counsel. Additionally,
defense counsel highlighted Plaintiff’s failure to provide a computation of damages
together with “documents or other evidentiary material…on which each computation is
based, including materials bearing on the nature…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…iii) date of the documents; and (iv) author(s), addressee(s) and
recipient(s). In the alternative, the responding party may produce the documents, together with
identifying information sufficient to satisfy Fed. R. Civ. P. 33(d).
10. In producing…
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