giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL
DEFENDANT TO ANSWER DEPOSITION QUESTIONS
Plaintiff Virginia Giuffre, by …
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL
DEFENDANT TO ANSWER DEPOSITION QUESTIONS
Plaintiff Virginia Giuffre, by …
giuffre-maxwell
1320-6
10 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL
DEFENDANT TO ANSWER DEPOSITION QUESTIONS
Plaintiff Virginia Giuffre, by …
DataSet-9
EFTA00207967
9 pg
…DOE #1 AND JANE DOE #2'S REPLY TO GOVERNMENT'S RESPONSE TO
THEIR MOTION TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE
CRIME VICTIMS' RIGHTS ACT AND TO HAVE THEIR UNREDACTED
PLEADINGS UNSEALED
COME NOW Jane Doe #1 and…
DataSet-9
EFTA00103798
3 pg
…indicated to us that it will comply with our request to partially redact its report before
providing it to Epstein's next of kin.
> • We separately wanted to flag for you that in an unredacted portion of the report…
DataSet-9
EFTA00098153
2 pg
…indicated to us that it will comply with our request to partially redact its report before
providing it to Epstein's next of kin.
> • We separately wanted to flag for you that in an unredacted portion of the report…
DataSet-9
EFTA00793834
47 pg
…same vein Epstein's
DATE TAKEN: Thursday, March 8th, 2018 14 Notice of Service of Unredacted Appendix in
TIME: 1:30 p.m. - 4:50 p.m.
IS Support -- or Response in Opposition to Edwards'
PLACE 205 N. Dixie Highway…
DataSet-9
EFTA00103738
2 pg
…has indicated to us that it will comply with our request to partially redact its report before
providing it to Epstein's next of kin.
• We separately wanted to flag for you that in an unredacted portion of the report…
DataSet-9
EFTA00103794
2 pg
…has indicated to us that it will comply with our request to partially redact its report before
providing it to Epstein's next of kin.
• We separately wanted to flag for you that in an unredacted portion of the report…
DataSet-9
EFTA00103792
2 pg
…indicated to us that it will comply with our request to partially redact its report before
providing it to Epstein's next of kin.
> • We separately wanted to flag for you that in an unredacted portion of the report…
DataSet-9
EFTA00103796
2 pg
…indicated to us that it will comply with our request to partially redact its report before
providing it to Epstein's next of kin.
> • We separately wanted to flag for you that in an unredacted portion of the report…
DataSet-10
EFTA01728468
10 pg
…we ma ke refe rence throughout the letter, is
A copy of the unredacted Police we do not have an
redacted Police Report because provided to you
pag es 81 - 87 are tak en fro m …
DataSet-9
EFTA00793787
47 pg
…same vein Epstein's
DATE TAKEN: Thursday, March 8th, 2018 )4 Notice of Service of Unredacted Appendix in
TIME: 1:30 p.m. - 4:50 p.m.
IS Support -- or Response in Opposition to Edwards'
PLACE 205 N.…
DataSet-9
EFTA00793693
24 pg
…Edwards'
Motion to Strike and for Related Relief (D.E. 1233), and an Unopposed Emergency
Motion to Temporarily Seal Epstein's Notice of Unredacted Materials (D.E. 1232). As
the non-parties have intervened below on a limited and unrelated…
DataSet-9
EFTA00077052
1 pg
…has indicated to us that it will comply with our request to partially redact its report before
providing it to Epstein's next of kin.
• We separately wanted to flag for you that in an unredacted portion of the report…
DataSet-9
EFTA00795963
9 pg
…that sane vein roster'.
DATE TAKEN: Thursday, march 8th, 2018 10 Notice of Service of Unredacted Appendix in
TIME: 1:30 p.m. - 4:50 p.m.
15 Surport -- or Response in Opposition to Edwards'
PLACE 205 N. Dixie Highway…
DataSet-9
EFTA00798522
39 pg
…Epstein's home, Recarey had identified
21 possible victims, according to a copy of the unredacted police report obtained
by the Herald. By the time police felt they had enough evidence to arrest Epstein
on sex charges, they had identified…
DataSet-9
EFTA00805367
22 pg
…Accordingly, after the homeowner's association requested an unredacted copy
5
EFTA00805371
of the e-mail, the plaintiff could not rely on work-product privilege: "[B]ecause Tumelaire's…
DataSet-9
EFTA00801838
30 pg
…we
18 served the counsel and hand delivered to the
19 Court -- did not put it in the public file -- the
20 unredacted documents so we would all know what was
21 in there.
22 THE COURT: By the court…
DataSet-9
EFTA00102335
9 pg
…by November 10 a joint
13 proposal for any logistical issues related to this for voir
14 dire.
15 That leaves the issue of sealing unredacted exhibits
16 and the limited redacting of exhibits containing specific
17 personal identifying information…
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