giuffre-maxwell
gov.uscourts.nysd.447706.1256.7
14 pg
…11 We further agree not to share, give, copy,
scan, fax or in any way distribute this
12 realtime rough draft in any form (written or
computerized) to any party. However, your
13 own experts, cocounsel and staff may have
…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 66 Filed 03/23/16 Page 3 of 35 3
G3hdgium
1 written and we know that both sides know what it is, and that…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…object to the confidentiality
designations: “A party may object to the designation of particular
CONFIDENTIAL INFORMATION by giving written notice to the party
designating the disputed information… it shall be the obligation of the party
designating the information as…
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.447706.1218.39
36 pg
…DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 1218-39 Filed 07/15/21 Page 4 of 36
3
G3hdgium
1 written and we know that both sides know what it is, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.17
6 pg
…Miami Beach, FL 33141
Case 1:15-cv-07433-LAP Document 1328-17 Filed 01/05/24 Page 3 of 6
Page 166 Page 168
1 written down anywhere? 1 for now we'll call it a massage -- as…
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.447706.40.0
8 pg
…and (j) any other person by written
agreement of the parties or by Order of a Court of competent jurisdiction.” Ms.
Giuffre made the proposed addition above because she contends it will alleviate
debate over a document that has been…
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.447706.1331.32
4 pg
…the same freely and vo/untarif;· for the uses and purposes
therein mentioned.
[SEAL]
offtera/ seal the d.iy and year 1asl above written.
Hsiao-Chi…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…at ¶ 8. The Order continues:
A party may object to the designation of particular CONFIDENTIAL INFORMATION by
giving written notice to the party designating the disputed information. The written notice
shall identify the information to which the objection is made…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…The FBI have
reopened the Epstein case due to Virginia’s revelations. I also am
attaching a link to a NY Magazine profile of Epstein.....written
before his world combusted. The FBI believe he was essentially
running a private — and…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…asking these questions before I -
MR. BOIES: I’m asking these questions because these are people who not only have
been publicly written about in terms of the sexual activity that they were put into in
connection with Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…161
Along with Farmer’s remarks, Assistant U.S. Attorney Alison Moe read from a letter
written by another of Maxwell’s alleged victims, who asked to be identified only as Jane
Doe. It’s possible that the woman may…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…Roberts at Mar-a-Lago? 12 Q. Is it possible she was 13 years old
13 A. Again, this was written in, when 13 when you first met her?
14 were you saying? 14 MR. PAGLIUCA: Object to the form…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…the jury in the video . . . has
been made public and has been written about in the local press, to all appearances
largely satisfying the legitimate public interest in the trial.
Id. at 65–66 (emphasis added); see also United States…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…Ms. Maxwell responds as follows:
Ms. Maxwell already produced any written communications with Mr. Epstein that were
responsive to the Interrogatory for the same, as limited by the Court to (a) all communications
from January 2015 and (b) all documents…
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