Search results for 01/05/24
1,750 results for "01/05/24"
Page 50 of 70
Giuffre_Maxwell_Batch4_p00159.png
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 30 of 32
promotes efficiency in complex civil discovery, it strongly weakens the parties’ claim to a
reasonable expectation that every document marked confidential will remain subject to a Rule
26(c) order indefinitely. See EPDM...
Giuffre_Maxwell_Batch4_p00315.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 12 of 50
Defendant in her Requests Nos. 17 and 18, in which she requested documents “concerning any
statement made by You or on Your behalf to the press or any other group or individual, including...
Giuffre_Maxwell_Batch4_p00533.png
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 8 of 13
it. Defendant has produced no documents at all related to this statement made by her
representative.
This is a statement made to a major publication on behalf of Defendant. “Reasonable
inquiry,” as required...
Giuffre_Maxwell_Batch5_p00111.png
Legal
...States Code, Sections 2422(b) and 2;
(4) traveling in interstate commerce for the purpose of engaging in illicit sexual
conduct, as defined in 18 U.S.C. § 2423(f), with minor females; in violation
Page 1 of 7
Filed 01/05/24 Page 2 of 10
GIUFFRE007597
CONFIDENTIAL
a
Giuffre_Maxwell_Batch5_p00235.png
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 5 of 17
IL. MS. MAXWELL HAS DISCLOSED AND SEARCHED ALL EMAIL ACCOUNTS
a. All Devices Have Been Forensically Searched for Responsive Emails
As requested by Plaintiff and Ordered by the Court, Ms. Maxwell’s computer...
Giuffre_Maxwell_Batch5_p00249.png
Deposition
Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 2 of 12
Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Response to Plaintiff's Motion
to Reopen Defendant’s Deposition, and states as follows:
INTRODUCTION
Plaintiff comes to this Court — for the third time — seeking to...
Giuffre_Maxwell_Batch5_p00251.png
Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 4 of 12
The Motion is untimely and no special circumstance exists, nor have any been claimed, requiring
denial of the motion.
B. November 2015 Communication from Mr. Gow Concerning a Press Inquiry
is Cumulative and...
Giuffre_Maxwell_Batch6_p00342.png
Legal
Case 1:15-cv-07433-LAP Document 1331-31 Filed 01/05/24 Page 26 of 27
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
the...
EFTA02542529.pdf
...Sat, 6 Aug 2011 01:05:24 +0200
To:
Subject:
when ca= you cme to paris?
T=e information contained in this communication is confidential, may be a=torney-client privileged, may constitute
inside information, and is intended only for the use of the a=dressee. It is the property...
Giuffre_Maxwell_Batch5_p00018.png
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 4 of 40
Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege, work...
Giuffre_Maxwell_Batch5_p00139.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-8 Filed 01/05/24 Page 2 of 10
Motion for Protective Order trying to avoid her deposition. After a hearing on the issue, the
Court directed Maxwell to sit for her deposition on April 22, 2016. During her deposition
Defendant refused...
Giuffre_Maxwell_Batch5_p00217.png
Legal
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 30 of 43
23.
24,
25.
26.
oe
28.
30.
31.
32.
34.
She
36.
37.
Q. Alan Dershowitz has sent drafts of books he was writing for you to review,
right? (/d. at 200.)
Q...
Giuffre_Maxwell_Batch3_p00321.png
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 15 of 27
Il. COUNSEL INSTRUCTED MAXWELL NOT TO ANSWER TO ENFORCE
THE COURT’S ORDER AND TO PREVENT HARASSMENT BY
PLAINTIFF’S COUNSEL
The only questions to which counsel for Ms. Maxwell instructed her not...
Giuffre_Maxwell_Batch4_p00329.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 26 of 50
Defendant says that Ms. Giuffre’s claim of medical damages somehow necessitates
Defendant having access to Ms. Giuffre’s childhood medical records. This argument is without
merit. As Defendant knows, as was explained...
Giuffre_Maxwell_Batch4_p00377.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-21 Filed 01/05/24 Page 6 of 19
Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page: 4
Time: 8:52:07 Offense Report Program: CMS301L
1-97-002687 (Continued)
Category . . . : PROP/EVIDENCE--NO VALUE
UCR Prop Type : CLOTHING AND...
Giuffre_Maxwell_Batch5_p00113.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-6 Filed 01/05/24 Page 4 of 10
Terns of the Agreement:
1. Epstein shall plead guilty (not nolo contendere) to the Indictment as
currently pending against him in the 15th Judicial Circuit in and for
Palm Beach County (Case No...
Giuffre_Maxwell_Batch6_p00240.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-19 Filed 01/05/24 Page 8 of 12
Inc., 783 F. Supp. 2d 373, 380 (E.D.N.Y. 2011) (waiver where party filed attorney-client
communications on “publically-accessible electronic docket” and voluntarily sent copy to
opposing counsel); accord First...
Giuffre_Maxwell_Batch6_p00307.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 10 of 19
The remaining document requests are specifically targeted to obtain impeachment
evidence concerning Ms. Ransome’s story, as told in the Jane Doe 43 Complaint and her
affidavit submitted in support of Plaintiffs Letter...
Giuffre_Maxwell_Batch6_p00311.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 14 of 19
Category 4 — Ms. Ransome’s current medical provider
Ms. Maxwell will withdraw this question.
The Witness’s Abandoned Objections
Notably absent from the Motion for Protective Order are several other questions posed to...
Giuffre_Maxwell_Batch6_p00339.png
Legal
Case 1:15-cv-07433-LAP Document 1331-31 Filed 01/05/24 Page 23 of 27
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
the...
Giuffre_Maxwell_Batch4_p00123.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 39 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
With regard to communications by Ms. Giuffre's attorneys, this request seeks clearly
privileged materials (or materials covered by the work...
Giuffre_Maxwell_Batch4_p00143.png
Legal
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 14 of 32
could appeal to the Oprah/female set as well as the Wall Streeters
who follow Epstein — a hedge fund king.
Here are a few of our stories about Virginia, plus some examples
of...
Giuffre_Maxwell_Batch4_p00430.png
Legal
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 18 of 22
forgetful about how many assets she has available to satisfy a judgment in this case —
forgetfulness that can be easily concealed with an unelaborated net worth statement.
In addition, a net worth statement...
Giuffre_Maxwell_Batch6_p00331.png
Legal
Case 1:15-cv-07433-LAP Document 1331-31 Filed 01/05/24 Page 15 of 27
15. All Documents reflecting any money, payment, valuable consideration or other remuneration
received by You from Jeffrey Epstein or any person known by You to be affiliated with Jeffrey
Epstein.
RESPONSE:
In addition...
Giuffre_Maxwell_Batch6_p00334.png
Legal
Case 1:15-cv-07433-LAP Document 1331-31 Filed 01/05/24 Page 18 of 27
(S.D.N.Y.). Ransome objects to this Request as overbroad, harassing, and not calculated to lead
to discoverable evidence relevant to the Defamation Action. Ransome objects to this Request in
that it...
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