giuffre-maxwell
gov.uscourts.nysd.447706.1198.17
3 pg
…providers or records because suing for $30 million of medical and Objections to First
“privileged” mental injury Discovery Requests
April 4 Plaintiff “has sent written Plaintiff had sent only one release to Plaintiff’s Response to
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…issues orally with Brad last week, I am including them in written form
so that there can be no dispute about our position.
I do object to the vast number of your 368 search terms. Most are not tied to…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.42
5 pg
…12 Q. What did you put in the bonfire?
13 A. Any kind of memories that I had written
14 down about all the stuff going on.
15 Q. Had you written anything about Professor
16 Dershowitz?
17 A. He…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
… If it helps, have your attorney write a suggested column-
oriented item re your case and if it's written in 'journalistic style,' Colin and I can pop it off to Emily, as a possible piece f,
her renowned Page…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…legal team. Since returning to full time law teaching in 2007, Professor Cassell has developed a
specialized expertise in crime victims’ rights, an area in which he has co-written a leading law
school casebook. See Beloof, Cassell & Twist, Victims…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…announcements, and sound recordings of any
nature. “Document” also means all copies which are not identical to the original document as
originally written, typed or otherwise prepared. The term “Document” shall also include all
documents of any nature that have…
giuffre-maxwell
gov.uscourts.nysd.447706.13.0
1 pg
…on any day thereafter.
5. Adjournments of the dates set forth above will not be granted except for good
cause and upon written application made as soon as the grounds for such application
are known.
6. Failure to comply with…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…independent
contractor or any other person acting, or purporting to act, at the discretion of or on behalf of
another.
2. “Correspondence” or “communication” shall mean all written or verbal
communications, by any and all methods, including without limitation, letters…
giuffre-maxwell
gov.uscourts.nysd.447706.958.3
4 pg
…thereto.
As to any individual to whom CONFIDENTIAL information was shared
pursuant to Paragraph 6 (and from whom there must be a written
acknowledgment of their willingness to abide by the Protective Order):
o The attorney who shared the…
giuffre-maxwell
gov.uscourts.nysd.447706.1182.0_1
3 pg
…judicial review or intervention. Specifically, Paragraph 11 of the Order permits “any party”
to file Confidential Information in the public record so long as that party “obtain[s] written
permission from the producing party to file such material.” Id. ¶ 11.…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…independent
contractor or any other person acting, or purporting to act, at the discretion of or on behalf of
another.
4. “Correspondence” or “communication” shall mean all written or verbal
communications, by any and all methods, including without limitation, letters…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…that the newest iteration of her story contained in the
I CVRA litigation differed materially from her rior "memories" which were written wli'en she
was riot planninglitigation and rlbt motivate
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…a 2003 Vanity Fair article, written before the Jeffrey Epstein scandal
broke, describes Maxwell as someone who “seems to organize much of [Epstein’s] life --
recently she was making telephone inquiries to find a California-based yoga instructor for
him…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…the particular dates
and times when you allege to have been present in your response to Request No. 5,
above.
7. All statements, written or recorded, which you have provided to anyone that reference by
name, Alan M. Dershowitz.
8…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…40
a. the date of any such Communication;
b. the form of any such Communication, whether oral or written and if
written, the format of any such Communication;
c. the identities of all persons involved in the Communication, including the…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…including “deponents, witnesses, or potential witnesses” or “by written
agreement of the parties.” Likewise, Paragraph 14 allows modification of the order by the Court
“at any time for good cause.” Finally, Paragraph 13 provides that the Protective Order “shall have…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
…taped statement, did he ever present
4 BY MR. CRITTON: 4 anything ror you, anything in writing that he had
5 Q. Is that correct? 5 written to say, Mr. Rodriguez, I would like you to
6 A. Yes, correct…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…communication made to such victim’s advocate by a victim
of domestic violence…or a victim of sexual assault, in person or through the media of written records or reports
without the consent of the victim.” C.R.S. …
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…quite the opposite. The express reason for the
communication was to obtain press coverage and to cause the publications of the series of
articles written and published by Churcher. Plaintiff was paid over $140,000 to go “on record.”
With…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…01/05/24 Page 5 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
b. the form of any such Communication, whether oral or written and if written, the
format of any such Communication;
c…
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