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.447706.1229.0
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.447706.1328.28
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.447706.1320.17
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.447706.1296.11
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.447706.1320.32
27 pg
…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 if it requires: who, having been…
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.447706.223.1
14 pg
…and also, after 11
subpoena. the court tor the district where compliance is re4uircu lIlay, on Illotion is transferred, the issuing court-may hold in contempt u persoll
l1lotion, quash or mOdify Ihe subpoena ifit r,~qllir¢s: who, having been…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…Appeal IU □ Remnnded ti-om
Proceeding
2 Removed
from State (See VI or
5
…
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
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
1320-32
27 pg
…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 if it requires: who, having been…
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…
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