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.447706.1229.0
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.447706.1331.35
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.447706.1296.11
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
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
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…known by You to be affiliated
with Jeffrey Epstein.
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.
17…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
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.447706.1219.8
29 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.
(Emphasis supplied.) A request more sweeping than this one would be hard to imagine.
In this…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…There, the Supreme Court held
that a decision by a state’s highest court “not only direct[ing] a transfer of
property, but also order[ing] an accounting of profits from such property”
was “final,” notwithstanding that the order clearly…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…41
Produce all records pertaining to the acquisition, transfer and sale of all securities by You
or on Your behalf from January 2015 to the present, such records to include any and all
information relative to gains or losses realized…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…There, the Supreme Court held
that a decision by a state’s highest court “not only direct[ing] a transfer of
property, but also order[ing] an accounting of profits from such property”
was “final,” notwithstanding that the order clearly…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…known by You to be affiliated
with Jeffrey Epstein.
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.
17…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…of January 1, 2015 through the present, Ms. Maxwell has had no payments made or things
of value transferred to her, including loans, by Jeffrey Epstein or any entity or person affiliated
with or controlled by him.” Simply put, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…January 1, 2015.
5. Identify all payments made or things of value transferred to you by Jeffrey Epstein,
directly or indirectly or through any entity or person affiliated with or controlled by
Epstein, from 1992 through the present, and if…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…crime victim’s right case in the past (let alone
one that involved wholly different parties and wholly different causes of action) somehow
transfers to a New York state law defamation claim involving a different party that arose years
later…
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