Search results for 01/05/24
1,750 results for "01/05/24"
Page 48 of 70
Giuffre_Maxwell_Batch4_p00121.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 37 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
between the four Jane Does, via Ms. Giuffre's attorneys, would be plainly be subject to attorney
client protection, not to...
Giuffre_Maxwell_Batch4_p00122.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 38 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
The request is also vague because it is not clear precisely what "witnesses" Defendant
Maxwell is concerned about. There have, for...
Giuffre_Maxwell_Batch5_p00161.png
Case 1:15-cv-07433-LAP Document 1330-11 Filed 01/05/24 Page 2 of 12
Importantly, Defendant has never denied using an email account for communication from
1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant
did not use an email account...
Giuffre_Maxwell_Batch5_p00289.png
Email
Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 2 of 11
From: [email protected]
Sent: Saturday, January 10, 2015 9:00 AM
To: Philip Barden; Ross Gow
!am out of my depth to understanding defamation and other legal hazards and don't want...
Giuffre_Maxwell_Batch4_p00311.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 8 of 50
involving discovery or disclosure requests or responses under Fed. R. Civ. P. 37, the moving
party shall specify and quote or set forth verbatim in the motion papers each discovery request
and response...
Giuffre_Maxwell_Batch4_p00464.png
Case 1:15-cv-07433-LAP Document 1328-28 Filed 01/05/24 Page 7 of 24
INSTRUCTIONS
1. Production of documents and items requested herein shall be made at the offices
of Boies Schiller & Flexner, LLP, 401 E. Las Olas Boulevard, Suite 1200, Fort Lauderdale,
Florida 33301, no later...
Giuffre_Maxwell_Batch4_p00555.png
Case 1:15-cv-07433-LAP Document 1328-35 Filed 01/05/24 Page 3 of 10
(Tr. at 57:5-13).
Q. The women with whom you engaged in sexual activities with Mr. Epstein and
yourself and the other women, were they older or younger than you?
A. Same...
Giuffre_Maxwell_Batch5_p00086.png
Flight Log
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 6 of 27
13. As the record demonstrates, I could not have abused Virginia Roberts
Giuffre because, as the records establish, I was never in Mr. Epstein’s Palm Beach home, private
island, ranch or airplane...
Giuffre_Maxwell_Batch5_p00284.png
Email
Case 1:15-cv-07433-LAP Document 1330-20 Filed 01/05/24 Page 7 of 10
Hi Ghislaine
The Times and the BBC having rung suggesting there are ‘fresh’ allegations by another woman, not Victoria.
Do you still wish to stand by original statement, including including the part about...
Giuffre_Maxwell_Batch4_p00048.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 4 of 40
Defendant Ghislaine Maxwell moves under Federal Rule of Civil Procedure 37(a)(3)(B)
to compel Plaintiff Virginia Giuffre to provide responsive answers to Ms. Maxwell’s Second Set
of Discovery Requests, attached...
Giuffre_Maxwell_Batch4_p00344.png
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 41 of 50
Regarding documents related to Interrogatory No. 11, which concerns facts about Ms.
Giuffre’s lost wages, Ms. Giuffre has withdrawn her lost wage claim, and therefore, this
interrogatory is no longer relevant.
Regarding...
Giuffre_Maxwell_Batch4_p00477.png
Case 1:15-cv-07433-LAP Document 1328-28 Filed 01/05/24 Page 20 of 24
TerraMar Project, Inc.
Schedule A
INSTRUCTIONS
is Production of documents and items requested herein shall be made at the offices
of Boies Schiller & Flexner, LLP, 5301 Wisconsin Avenue NW Washington, DC 20015, no...
Giuffre_Maxwell_Batch6_p00327.png
Legal
Case 1:15-cv-07433-LAP Document 1331-31 Filed 01/05/24 Page 11 of 27
Without waiving such objections, a copy of non-party Sarah Ransome’s current passport
is attached hereto as RANSOME 000157-000168, which should be treated as Confidential
pursuant to the parties’ Protective Order...
Giuffre_Maxwell_Batch6_p00329.png
Legal
Case 1:15-cv-07433-LAP Document 1331-31 Filed 01/05/24 Page 13 of 27
Maxwell, Sarah Kellen, Lesley Groff, and Natalya Malyshev Case Number 1:17-cv-00616-JGK
(S.D.N.Y.). Ransome further objects to this Request as overbroad, harassing, and not calculated
to lead...
Giuffre_Maxwell_Batch3_p00072.png
Legal
Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 12 of 17
Finally, Defendant also refused to answer foundational questions that are necessary to
precede questions authorized by this Court, such as:
“In terms of preparing for this deposition, what documents did you review?” See...
Giuffre_Maxwell_Batch3_p00322.png
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 16 of 27
Court’s Order counsel for Ms. Maxwell sought guidance form the Court, which was not
available.
Notwithstanding that the examination was repetitive, Ms. Maxwell responded to
questions, without instruction not to answer, that...
Giuffre_Maxwell_Batch4_p00527.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 2 of 13
Plaintiff Virginia Giuffre (“Ms. Giuffre”), by and through her undersigned counsel,
hereby files this Reply in Support of her Motion to Compel (DE 345).
L ARGUMENT
A. This Court should Order Production of...
Giuffre_Maxwell_Batch5_p00096.png
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 16 of 27
there. It was not, as Mr. Cassell misleadingly suggests, an affirmation that Ms. Giuffre and I
were present at Mr. Epstein’s house at the same time.
37. In fact, Mr. Alessi has...
Giuffre_Maxwell_Batch5_p00310.png
Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 12 of 22
Thanks and all best
Jon
Visit thequardian.com. On your mobile and tablet, download the Guardian iPhone and Android apps
thegquardian.com/gquardianapp and our tablet editions thequardian.com/editions. Save up to...
Giuffre_Maxwell_Batch6_p00092.png
Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 3 of 21
Defendant Ghislaine Maxwell (““Ms. Maxwell”) hereby moves to in /imine to exclude in
toto certain depositions designated by Plaintiff for use at trial, specifically those of Alfredo
Rodriguez, Jeffrey Epstein, MM and Dr...
Giuffre_Maxwell_Batch4_p00107.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 23 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
REQUESTS FOR ADMISSION
1. Admit that you were not 15 years old when you first met Ghislaine Maxwell.
Response to Request...
Giuffre_Maxwell_Batch4_p00141.png
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 12 of 32
results of Judge Freeh’s investigation, Ms. Giuffre and her counsel have republished Ms.
Giuffre’s allegations against Professor Dershowitz. Id. | 26. For example, on April 8, 2016, just
after the settlement of...
Giuffre_Maxwell_Batch4_p00169.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 8 of 12
See McCawley Decl. at Exhibit 2, June 20, 2016 Sealed Order at p. 10 (Emphasis added).
As articulated in the moving brief, Defendant refused to answer four categories of
questions that were directly...
Giuffre_Maxwell_Batch4_p00171.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 10 of 12
to answer any more questions with respect to whether she knows certain girls who came over to
Epstein’s home to massage him, “Q. Have you ever heard the name Carolyn Andriamo, A...
Giuffre_Maxwell_Batch4_p00313.png
Legal
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 10 of 50
Weissfeld. The overwhelming majority of them were produced in her second rolling production
and continued on a rolling basis through the fifth production (all of which were small
productions). Specifically, there are approximately...
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