giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…sealed.
19 Doe 73. This Doe worked for Epstein in a financial
20 capacity and there is no allegation that he was involved in any
21 of the conduct underlying this action. Given the sensitive and
22 potentially salacious issues…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…only testify to the fact that I
11 read a police report that stated that.
12 Q. Were you working for Jeffrey -- you
13 said you worked for him off an on until 2009,
14 is that correct?
15 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…any fact material to this case. He flatly testifies that
he had never heard or, met or seen the Plaintiff. He worked for Mr. Epstein over 2 years after
Plaintiff left the country. Nothing Mr. Rodriguez could have possibly testified…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.35
5 pg
…you know who set up the mind spring
14 system?
15 A. It was a computer guy. It was a computer
16 guy who worked only for Jeffrey.
17 .
18 Q. Was he local to Palm Beach?
19 A. No…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.24
6 pg
…you know who set up the mind spring
14 system?
15 A. It was a computer guy. It was a computer
16 guy who worked only for Jeffrey. Mark. Mark
17 Lumber.
18 Q. Was he local to Palm Beach…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.13
5 pg
…you know who set up the mind spring
14 system?
15 A. It was a computer guy. It was a computer
16 guy who worked only for Jeffrey. Mark. Mark
17 Lumber.
18 Q. Was he local to Palm Beach…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.18
6 pg
…you know who set up the mind spring
14 system?
15 A. It was a computer guy. It was a computer
16 guy who worked only for Jeffrey.
17 .
18 Q. Was he local to Palm Beach?
19 A. No…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.26_1
4 pg
…15 A. Right, but she was --
16 MS. SCHULTZ: Object to form and
17 foundation.
18 THE WITNESS: She was -- she had worked
19 there for quite some time, so you would have to
20 back up, I think, a…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…e., plaintiff and defendant, worked off J. Doe’s proposed
protocol, Doc.1019. The original parties ultimately made substantial changes to the
protocol. The changes were made for various reasons, most of which will be apparent,
e.g., the protocol…
giuffre-maxwell
gov.uscourts.nysd.447706.881.0
8 pg
…you ever worked in the legal field.
AGREE TO BE HONEST AND FORTHRIGHT
Does everyone agree that they will tell us if they have feelings that may impact their ability
to be impartial in this trial for any reason…
giuffre-maxwell
gov.uscourts.nysd.447706.363.8
3 pg
…act as the mediator
and assist the parties and their counsel toward this agreed resolution. I want to extend my
appreciation for the professionalism exhibited by the parties and their counsel with whom
I worked directly: Jack Scarola, Rick Simpson…
giuffre-maxwell
gov.uscourts.nysd.447706.441.0
18 pg
…Universityof Tex as,who
has stu d ied and worked on electronic healthrecord s systems,and u sed them as aphysician.
”).
A ccord ingly,“certainty”thatevery med icalrecord ever created forM s.Giu ffre,across nearlytwo
d ecad es and…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…American Correspondent of The Mail on Sunday, a
publication owned by Associated Newspapers of London, England.
During the interim she worked as a freelance reporter for
publications including The Mail on Sunday, the U.S. operation of
its digital arm…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR
DEFENDANT’S RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH
COURT ORDER AND FAILURE TO COMPLY WITH RULE 26(a)
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S CORRECTED1 RESPONSE IN OPPOSITION TO DEFENDANT’S
MOTION FOR DEFENDANT’S RULE 37(b) &(c) SANCTIONS FOR FAILURE TO
COMPLY WITH COURT ORDER AND FAILURE TO COMPLY WITH RULE 26(a)
1
Due to inadvertence…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…foreign presidents, a well‐
known Prime Minister, and other world leaders,” as well as
Dershowitz (a long‐time member of the Harvard Law School faculty
who had worked on Epstein’s legal defense) and Defendant‐Appellee
Ghislaine Maxwell (“Maxwell”).2…
giuffre-maxwell
gov.uscourts.nysd.447706.1143.0_1
2 pg
…Dkt. 1099.
The parties have sent the Non-Party Notice to the remaining Non-Parties, have worked
diligently to respond to requests for Excerpts, and are on track to complete serving Excerpts by
the end of the month. As of…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…foreign presidents, a well‐
known Prime Minister, and other world leaders,” as well as
Dershowitz (a long‐time member of the Harvard Law School faculty
who had worked on Epstein’s legal defense) and Defendant‐Appellee
Ghislaine Maxwell (“Maxwell”).2…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…stating:
Maxwell admits that she has worked with Mr. Gow on occasion for several years
and that she has corresponded with Mr. Gow regarding communications to
members of the British press to reserve her right to seek redress for their
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…worthy.
bu
There is also another major paper that has followed the story for a while and has worked with me before, they're asking me again for the exclus…
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