DataSet-9
EFTA00159199
7 pg
July 30, 2021 David Rodgers prep VTC
Attorney Quigley
Prepared for trial testimony.
• Currently retired, formerly worked as a pilot.
• Employer from 1991 through 2019 was Jeffrey Epstein, though was paid by NES corp
o First 13 years, was chief…
DataSet-9
EFTA00159208
1 pg
Au st 18, 2021 David Rodgers Prep
Attorney Quigley
Prepared for trial testimony. DR's previously undisclosed, clarifying, or different recollections
below:
• JE. had six helicopters during the time DR worked for him.
3523-0…
DataSet-9
EFTA00157613
13 pg
June 8, 2021 Juan Alessi prep
AUSA
SA
Det
Attorney Reynolds
•
• JA provided a copy of his separation agreement with JE
• Prior testimony
o
o Testified three times regarding Epstein
• Approximately 2004 or 2005, provided sworn statement to Detective from…
DataSet-9
EFTA01015079
4 pg
…Subject: Fwd: ABC News: Michael Cohen expected to plead guilty to lying to Congress in collusion probe;
gave 70 hours of testimony to special counsel: Sources
Date: Thu, 29 Nov 2018 14:42:07 +0000
Begin forwarded message:
From: Jason…
giuffre-maxwell
gov.uscourts.nysd.447706.651.0
3 pg
…Plaintiff,
Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S REPLY IN
SUPPORT OF MOTION TO PRESENT TESTIMONY FROM JEFFREY EPSTEIN FOR
PURPOSE OF OBTAINING AN ADVERSE INFERNCE IN…
DataSet-9
EFTA00160986
10 pg
…Hamburger, 14.2M) reports Democrats on the House Judiciary Committee have been "negotiating for Jeff Sessions's
testimony in their impeachment investigation of President Trump, an appearance they hope could bolster their inquiry given the
former attorney general's rocky…
DataSet-9
EFTA00076065
2 pg
…contact, and interview all these Domestic Staff Housekeepers, Chefs, Drivers, Personal Assistants, Couples,
Butlers, etc and ask for their testimony, then the case opens wide, as the Domestics see, and hear
everything.
Everything They know who comes, and goes, when…
DataSet-11
EFTA02464998
1 pg
…Press, lmdb=. 5. olivier fabrice christoph, others recently fired, 6 . rockefeller. - jaco=, parsons . 7 benjamin,
chairman role. testimony spending etc. 8 f=mily liquidity, - Johnny, 9 family estate plan. henri = philip. . 10 non
financial - hotel wine . four seasons. . 11. IT=C2…
DataSet-9
EFTA00096268
2 pg
…publicized, so they
couldn't possibly make up their testimony.
All I can really think of that we could add—if they just want more information in the indictment—would be:
• A paragraph about the volume of victims (i.e.…
DataSet-9
EFTA00136372
54 pg
…Arrest Two
Activists.
• Jayapal Says Barr Perjured Himself During Testimony On Protests.
• Arkansas Governor Confident In Investigation Into Morris Death.
• Nevada Legislature Votes To Ban Police From Using Chokeholds.
Counter-Terrorism
• UK Goes To Supreme Court To Fight Return Of…
DataSet-9
EFTA01245481
1 pg
…Subject: tic re:
From: (USANYS) >
To: (USANYS)
arial cSSAN
W
tic wittr@
8/3/20
I calling because received grand jur…
DataSet-9
EFTA00608292
4 pg
…for her Reply brief
due to the complexity of the issues raised in Ms. Motion to Compel the Production of
Documents and Testimony from Jeffrey Epstein, and because the Reply brief must set forth
certain questions posed to Jeffrey Epstein…
DataSet-9
EFTA00608288
4 pg
…submits
this Sealed Motion to Exceed Page Limit pursuant to Local Rule 7.1(cX2) for her Reply brief
due to the complexity of the issues raised in Motion to Compel the Production of
Documents and Testimony from Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
…DATE
DOC. # DEFENDANT’S POSITION C/I1 PLAINTIFF’S POSITION
FILED
Unseal and redact only (1) medical
Redact all quotes from Ms.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.12
7 pg
…not
agree to the appointment of a special master to oversee Ms. Maxwell’s third deposition.
INTRODUCTION
Plaintiff has deposed Defendant for more than thirteen hours of testimony on the record.
During the previous depositions, a variety of issues arose…
giuffre-maxwell
gov.uscourts.nysd.447706.573.0
4 pg
…Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION IN LIMINE
TO EXCLUDE EXPERT TESTIMONY AND OPINION OF PROFESSOR TERRY
…
giuffre-maxwell
gov.uscourts.nysd.447706.991.1
48 pg
…in Limine re. Admissibility of Evidence and Related Orders (“Motion in Limine re.
Admissibility of Evidence”)
3. Motions in Limine re. Expert Testimony and Related Orders (“Motion in Limine re. Expert”)
4. Deposition Designations and Counter-Designations
5. Objections to…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.1_2
28 pg
…315, 320, & 335
DOCKET DATE COUNTERVAILING
# FILED DEFENDANT’S POSITION
INTERESTS1
Redact all quotes from Ms.
Maxwell and Non-Party deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.600.0
3 pg
…Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF
PLAINTIFF’S REPLY IN SUPPORT OF PLAINTIFF’S MOTION IN LIMINE TO
EXCLUDE TESTIMONY OF GREGORY B TAYLOR and KYLE JACOBSON
I…
giuffre-maxwell
gov.uscourts.nysd.447706.575.0
3 pg
…L. Giuffre,
Plaintiff,
Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S
RESPONSE IN OPPOSITION TO MOTION IN LIMINE TO EXCLUDE EXPERT
TESTIMONY AND OPINIONS OF REBUTTA…
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