Search results for 01/05/24
1,750 results for "01/05/24"
Page 47 of 70
Giuffre_Maxwell_Batch5_p00199.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 12 of 43
incrimination, He should be ordered to answer these specific questions, which are enumerated in
Section II, below.
Third, Epstein also took the Fifth when asked questions about Ghislaine Maxwell’s
interactions with females...
Giuffre_Maxwell_Batch5_p00281.png
Email
Case 1:15-cv-07433-LAP Document 1330-20 Filed 01/05/24 Page 4 of 10
From:
Sent: Friday, January 02, 2015 10:07 AM
To: G Max
Subject: Fw: The Times - David Brown
Hi Ghislaine
The Times and the BBC having rung suggesting there are 'fresh' allegations by...
Giuffre_Maxwell_Batch6_p00335.png
Legal
Case 1:15-cv-07433-LAP Document 1331-31 Filed 01/05/24 Page 19 of 27
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a non-party and this requests seeks information that is clearly not relevant to...
Giuffre_Maxwell_Batch3_p00259.png
Legal
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 16 of 21
See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16-
268, Disc 7 at p. 2305 (GIUFFRE007843)
Because of Defendant’s refusal to search this important email...
Giuffre_Maxwell_Batch4_p00532.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 7 of 13
D. This Court Should Order Production of Documents Responsive to Requests
No 17 and 18.
Requests Nos. 17 and 18 seek documents “concerning any statement made by You or on
Your behalf to...
Giuffre_Maxwell_Batch5_p00240.png
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 10 of 17
2016, the Court entered an Order adopting Plaintiff's expanded request and methodology. All
accessible email accounts and devices, including deleted files and emails, were searched — again
— at significant expense. Again, no additional...
Giuffre_Maxwell_Batch3_p00323.png
Court Filing
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 17 of 27
Cc. “Objected” to Question Number 4.
“Do you know if Maria Farmer was ever at Mr. Wexner’s property in Ohio?”
This question is completely outside the Court’s June 20, 2016 Order...
Giuffre_Maxwell_Batch4_p00096.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 12 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
individuals would be irrelevant and unduly burdensome. Moreover, as specifically provided in
Rule 33.3(b), “[dJuring discovery, interrogatories other than...
Giuffre_Maxwell_Batch4_p00125.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 41 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
Marra for in camera review). It is not clear whether the request is designed to request all of these
communications as...
Giuffre_Maxwell_Batch5_p00166.png
Case 1:15-cv-07433-LAP Document 1330-11 Filed 01/05/24 Page 7 of 12
conspirators Sarah Kellen, Nadia Marcinkova, and Epstein. However, it is Defendant’s
representation that this account does not presently have responsive documents and was merely
used for “spam.”
Cc. Defendant’s Non-Disclosed...
Giuffre_Maxwell_Batch5_p00193.png
Legal
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 6 of 43
Federal Rule of Civil Procedure 26 authorizes a court, for good cause, to enter a
protective order to seal or to limit disclosure. Indeed, courts have the discretion to place entire
cases under...
Giuffre_Maxwell_Batch5_p00211.png
Legal
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 24 of 43
illustrations will demonstrate that Epstein’s claim that he need not produce even a single
document is vastly overbroad.
a. Records Reflecting Communications with Maxwell
One simple example is the request for records...
Giuffre_Maxwell_Batch5_p00327.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 7 of 9
standards to the parties’ privilege logs, explaining “what’s good for the goose is good for the
gander.”).
Well-reasoned precedent, as well as the facts in this case, requires the re-opening...
Giuffre_Maxwell_Batch6_p00164.png
Legal
Case 1:15-cv-07433-LAP Document 1331-13 Filed 01/05/24 Page 6 of 22
ARGUMENT
I. EPSTEIN AND, POTENTIALLY, ESPLIN ARE UNAVAILABLE WITNESSES.
A. Jeffrey Epstein is a Witness who is more than 100 miles from the place of
hearing, or at a Minimum a Witness Who...
Giuffre_Maxwell_Batch3_p00318.png
Deposition
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 12 of 27
(S.D.N.Y. Sept. 9, 1994) (permitting reopening of deposition only if party could specifically
identify areas of inquiry previously foreclosed). To the extent Plaintiff has not identified specific
questions that Ms...
Giuffre_Maxwell_Batch4_p00110.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 26 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
Mar-a-Lago by Ghislaine Maxwell. She later obtained some records from Mar-a-Lago which
indicated that she was employed...
Giuffre_Maxwell_Batch4_p00319.png
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 16 of 50
internet for any instances of Dershowitz defaming her. He is not a party to this action. And, Ms.
Giuffre’s single count of defamation does not allege in facts in relation to Dershowitz...
Giuffre_Maxwell_Batch5_p00019.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 5 of 40
overly burdensome to the extent that they would require logging voluminous and ever-increasing
privileged communications between Ms. Giuffre and her counsel after the date litigation
commenced on September 21, 2015. Ms. Giuffre...
Giuffre_Maxwell_Batch5_p00098.png
Deposition
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 18 of 27
any sex toys in any room I ever stayed in, nor were there any visible pictures of naked young
women. My children and grandchildren stayed in the rooms in question at Mr. Epstein...
Giuffre_Maxwell_Batch6_p00255.png
15-cv-07433-LAP Document 1331-21 Filed 01/05/24 Page 7 of 8
Case 1
WILNAGISANOO
uopieg
dyptyg Jo wonsanp
oy} 1B [JoMxXeyL
uoreorunututo0d oute[sTyD
quar]g-Aoulony Aq posedoid
‘onporg y10\\ Aousony quowmns0q qual[g/Aoulony 90° 10°S 107 “ST
qusMIeaIS Vy quouryporne
ASOIIALIg ISOIOJUT...
Giuffre_Maxwell_Batch4_p00082.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 38 of 40
Under Rule 37(a)(5), if a party is required to file a motion to compel discovery responses
and the motion is granted or disclosure or discovery is provided after filing, “the court...
Giuffre_Maxwell_Batch4_p00345.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 42 of 50
are unduly burdensome. As described in full above, Ms. Giuffre has produced what documents
she has in response to these requests. This Court should deny Defendant’s motion to compel the
documents related...
Giuffre_Maxwell_Batch6_p00312.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 15 of 19
people she has sued). Counsel for Ms. Ransome only produced selective portions of email
chains. By way of example, Menninger Decl. Exhibit G shows an email chain containing six
communications she had with...
EFTA01775197.pdf
Email
...Sat, 6 Aug 2011 01:05:24 +0200
To:
Subject:
when can you cme to paris?
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
Jeffrey Epstein...
Giuffre_Maxwell_Batch3_p00248.png
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 5 of 21
defamatory statements made about Ms. Giuffre. Obviously, Ms. Giuffre has a compelling need
to obtain Defendant’s documents about her, and she has accordingly requested Defendant’s
communications concerning her. Defendant’s documents...
Search Tips
- Use quotes for exact phrases:
"flight manifest" - Use OR for alternatives:
bank OR financial - Use wildcard for partial matches:
invest* - Exclude words:
document -redacted - Search names:
John Smith