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
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giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
… Dr. Donahue ............................................................................................................ 9
B. Dr. Hayek ................................................................................................................ 9
C. Dr. Kutikoff, Wellington Imaging Associates (“Wel…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
… Dr. Donahue ............................................................................................................ 9
B. Dr. Hayek ................................................................................................................ 9
C. Dr. Kutikoff, Wellington Imaging Associates (“Wel…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…Edwards”) and PAUL G. CASSELL (“Cassell”) (together,
“Plaintiffs”) in opposition to Dershowitz’s Motion to Compel Production of Documents and
Complete Responses to Interrogatories (the “Motion to Compel”).1
INTRODUCTION
At the outset of their Response, Pla…
giuffre-maxwell
gov.uscourts.nysd.447706.1298.0
1 pg
…2022 (Dkt. 1297) asking the parties
to jointly prepare and file a chart concerning the remaining non-objecting Does.
The parties have been working together to prepare the chart for filing. The number of non-
objecting Does and pleadings at…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…the objections
of Does 55, 56, 93, and 151 together. This would be efficient because the names of Does 55, 56,
and 93 only appear in motions that Doe 151’s name also appears in, so the parties and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…Working off the Non-Party’s list, I have been looking at the list that has the Doe I, Doe
II identifiers down the right-hand side, and our proposal is that we begin with Doe I and II
together . . . .”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1258.0
3 pg
…heard, together with such other and further relief as this Court deems just and proper.
1
Case 1:15-cv-07433-LAP Document 1258 Filed 07/28/22 Page 2 of 3
PLEASE TAKE NOTICE that opposition papers, if…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…at the house maybe a handful of days, again.
7 Q. I would like to direct you to, you
8 have it pulled together now, it's page 39,
9 Bates stamped Giuffre 00040?
10 A. Can you repeat that…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
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giuffre-maxwell
gov.uscourts.nysd.447706.1218.26
4 pg
…He
can’t vote. He can’t hunt. He can’t carry a badge.
``He has spent years making amends and piecing his life back together. If we can’t allow people to change, then we give
people no incentive…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.22_1
12 pg
…else you remember about her when she
4 walks into the kitchen.
5 A. Very attractive, beautiful young
6 girl. Makeup, very put together, casual
7 dress. But she seemed to be upset, maybe
8 distraught, and she was shaking…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…having said all of that, this really is the first
5 time that we've had an opportunity, I think, to get together on
6 this case. And let me just say, I think -- I mean, I'm not
7…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.17
5 pg
…time, had met with
19 and went shopping with her at the Palm Beach
20 Mall, where they purchased items from
21 Victoria's Secrets.
22 After spending the day together, they went
23 over to the Palm Beach house…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.22
5 pg
…During that time,
- had met with
and went shopping with her at the Palm Beach
Mall, where they purchased items from
-
21 Victoria's Secrets.
22 After spending the day together,…
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.447706.1200.16_1
9 pg
…else you remember about her when she
4 walks into the kitchen.
5 A. Very attractive, beautiful young
6 girl. Makeup, very put together, casual
7 dress. But she seemed to be upset, maybe
8 distraught, and she was shaking…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
…needed to relay a message to 9 A. Because there were pictures with him
10 Epstein he would have to notify Epstein's 10 together.
11 secretary Lesley in New York who would then notify 11 Q. In the house…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…today.” (Id. at 2.) On top of this--and despite the
Court’s instruction that the parties work together to ensure that
the materials were properly redacted by the appointed time--Ms.
Maxwell apparently has not provided to Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…But having said all of that, this really is the first
5 time that we've had an opportunity, I think, to get together on
6 this case. And let me just say, I think -- I mean, I'm not
…
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