giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…particularly in light of
Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may
be selling her assets in New York and transferring the money outside the jurisdiction.
Accordingly, Defendant’s motion for a…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…particularly in light of
Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may
be selling her assets in New York and transferring the money outside the jurisdiction.
Accordingly, Defendant’s motion for a…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…memoranda, mobile phone agreements, wire
transfer receipts, or any other document that concerns Plaintiff in any way,
whether or not they reference her by name.” Plaintiff is asking defendant to
Meredith Schultz
Paul Cassell
July 29, 2016
Page 2
produce…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…mobile phone agreements, wire
transfer receipts, or any other document that concerns Plaintiff in any way,
whether or not they reference her by name.” Plaintiff is asking defendant to
Case 1:15-cv-07433-LAP Document 1199-5 Filed 01…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…Filed 12/01/15 Page 2 of 13
received; and, includes every manner or means of disclosure, transfer or exchange, and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…Filed 08/12/16 Page 3 of 13
received; and, includes every manner or means of disclosure, transfer or exchange, and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…whatever form, is stored, transmitted or
received; and, includes every manner or means of disclosure, transfer or exchange, and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…However, you do need to check this e-mail and any attachments
to it for viruses as we can take no responsibility for any computer virus
which may be transferred by way of this e-mail. Use of this or…
giuffre-maxwell
gov.uscourts.nysd.447706.1229.0
3 pg
…Mar. 30, 2018) (holding the parties’ “self-
designation” of materials as “Confidential” “is not binding on the Court”); In re Citibank Aug.
11, 2020 Wire Transfers, No. 20-CV-6539 (JMF), 2020 WL 6782213, at *1 (S.D.N.Y…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…Copyright in that document vested in the
second claimant; in due course it was transferred to the first claimant. I shall not
distinguish between those two companies for the purposes of this judgment (because it is
not necessary to do…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…and
Treasurer—knowingly participated in the Epstein Enterprise and facilitated the trafficking and
sexual servitude of underage girls and young women by providing the secluded properties at,
from, or to which Epstein and his associates could transport, transfer, maintain, isolate…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…required-and also, after a
subpoena, the court for the district where compliance is required may, on motion is transferred, the issuing court-may hold in contempt a person
motion, quash or modify the subpoena ifit requires: who, having been…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.29
5 pg
…Who else? I don't think I can remember
8 all of the business, except for the office, transfer of 8 anymore.
9 commu11ications or faxes. But I have no idea of the 9 Q. ?
10 relationship wi th other…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…in whatever form, is stored, transmitted or
received: and, includes every manner or means of disclosuTe, transfer or exchange, and every
disclosure, transfer or exchange of i11formation whether ornlly or by document or otherwise,
face-to-face, by telephone, telecopies…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…whether published or not), notes (handwritten or not),
memoranda, mobile phone agreements, wire transfer receipts, or any other document that
concerns Plaintiff in any way, whether or not they reference her by name.
RESPONSE: Ms. Maxwell objects to this Request…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.42
5 pg
…hairstylist. Who else? I don't think I can remember
8 all of the business, except for the office, transfer of 8 anymore.
9 communications or faxes. But I have no idea of the 9 Q. David Copperfield, the magician…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…and also, aller a
subpoena, the court tor the district where compliance is required may, on motion is transferred, die issuing cour1-may hold in contempt a person
motion, quash or modify the subpoena if it requires: who, having been…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…501,
510 (1984)). Plaintiff ignores this expressly-condoned countervailing factor and instead relies on
cases generally concerning pretrial publicity and motions to transfer venue.4
Plaintiff shrugs off concerns about the fairness of Ms. Maxwell’s criminal trial as
“vague…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…Div.
2016).
16. All bank statements, credit card statements, money transfer records, or other statements from
any financial institution in Your name, in whole or in part, for the years 2006-2007.
14
RESPONSE:
In addition to the Preliminary Statement…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…or not), memoranda, mobile phone agreements, wire transfer receipts, or
any other document that concerns Plaintiff in any way, whether or not they reference her by
name.
Defendant is clearly withholding Barden documents that are responsive to Ms. Giuffre’s…
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