Search results for 01/05/24
1,750 results for "01/05/24"
Page 60 of 70
Giuffre_Maxwell_Batch3_p00330.png
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 24 of 27
The majority of masseuses that came to the house were over the age of 20. Pagliuca
Decl., Ex. G at 200.
Mr. Epstein and Ms. Maxwell found the massage therapists from the high...
Giuffre_Maxwell_Batch4_p00139.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 10 of 32
FACTUAL AND PROCEDURAL BACKGROUND
I. MS. GIUFFRE’S ALLEGED RELATIONSHIP WITH JEFFREY EPSTEIN AND
BELATED ACCUSATIONS AGAINST PROFESSOR DERSHOWITZ
In 2006, Professor Dershowitz was retained by financier Jeffrey Epstein to join a team...
Giuffre_Maxwell_Batch6_p00376.png
Case 1:15-cv-07433-LAP Document 1331-36 Filed 01/05/24 Page 5 of 10
determining whether to draw any adverse inferences it is permitted to consider by seeing Mr. Epstein
assert the privilege in live testimony in front of it, rather than by seeing him do the...
Giuffre_Maxwell_Batch5_p00322.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 2 of 9
produced documents at issue in this pending motion is an email chain showing Epstein’s involvement
in crafting yet another draft statement. The other late produced document is a communication between
Defendant and...
Giuffre_Maxwell_Batch3_p00317.png
Court Filing
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 11 of 27
time of 11 hours and 52 minutes. A total of 787 questions were posed to Ms. Maxwell in the
second deposition. Ms. Maxwell answered every question posed to her that fell within the...
Giuffre_Maxwell_Batch4_p00330.png
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 27 of 50
This request is particularly improper as it cannot conceivably lead to admissible
evidence. While Federal Rule of Civil Procedure 26 controls the limits of discovery, FRE 412
informs discovery over the boundaries of...
Giuffre_Maxwell_Batch4_p00376.png
Case 1:15-cv-07433-LAP Document 1328-21 Filed 01/05/24 Page 5 of 19
ROYAL PALM BEACH POLICE DEPARTMENT
Offense Report
Date: 4/25/16
Time: 8:52:07
Category...
UCR Prop Type
Name. ....
Value ...
Recovered Date
Recovery value
RKREKKKKE DPROPERTY
Category...
UCR Prop Type
Name .....
Value...
Giuffre_Maxwell_Batch4_p00531.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 6 of 13
Defendant, and containing explicit references to Ms. Giuffre, are irrelevant and not subject to
discovery.
What should be reviewed and produced are the documents in Defendant’s possession
concerning Ms. Giuffre that are...
Giuffre_Maxwell_Batch5_p00209.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 22 of 43
of incrimination from the mere production of documents to Ms, Giuffre’s counsel. See generally
Mare Youngelson, The Use of 26(c) Protective Orders: “Pleading the Fifth” Without Suffering
“Adverse” Consequences, 1994 Ann...
Giuffre_Maxwell_Batch4_p00092.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 8 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
Ms. Giuffre further objects because the information requested above is in the possession
of Defendant’s agent, who caused the false...
Giuffre_Maxwell_Batch6_p00011.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 3 of 48
Local Civil Rule 33.3(b), (c). The interrogatories you served violate Local Rule 33.3 and we ask
that you immediately withdraw those interrogatories. See Rule 33.3, Local Rules for the...
Giuffre_Maxwell_Batch4_p00105.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 21 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
informs discovery over the boundaries of the proper inquiry into an alleged sexual assault
victim's sexual conduct and history. Silva...
Giuffre_Maxwell_Batch4_p00338.png
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 35 of 50
fictitious scenario and asks Ms. Giuffre to admit or deny it. This fictitious scenario is not
something that Ms. Giuffre has ever alleged. As stated in the objection, Defendant has interposed
and comingled...
Giuffre_Maxwell_Batch6_p00064.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 8 of 21
Il. LEGAL ARGUMENT
A. Defendant’s Motion Should Be Denied Because it is Untimely and Defendant
is Merely Trying to Deflect from Her Own Discovery Misconduct
The first reason the Court should deny...
Giuffre_Maxwell_Batch6_p00260.png
Case 1:15-cv-07433-LAP Document 1331-22 Filed 01/05/24 Page 4 of 9
of criminal and other misconduct by Ms. Maxwell. I believed an immediate response was
imperative, even though this was happening in the midst of the holidays in the United Kingdom.
My communications with...
Giuffre_Maxwell_Batch6_p00306.png
Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 9 of 19
Plaintiff's counsel, seeks, among other things, civil forfeiture of two private jets, a mansion in
New York, and a private island in the U.S. Virgin Islands. One can hardly imagine a...
Giuffre_Maxwell_Batch6_p00288.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-27 Filed 01/05/24 Page 8 of 11
Rule 37(a)(3) requires that a motion to compel the production of a document be grounded
on the existence of an unsatisfied request for production. So too does Local Civil Rule 37...
Giuffre_Maxwell_Batch4_p00060.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 16 of 40
previously produced documents or identified witness lists.”), appeal dismissed (Mar. 30, 2016);
Smith v. Trawler Capt. Alfred, Inc., No. 2:12-CV-2866-DCN, 2014 WL 1912067, at *3 (D.S.C.
May...
Giuffre_Maxwell_Batch4_p00271.png
Case 1:15-cv-07433-LAP Document 1328-13 Filed 01/05/24 Page 4 of 9
Louella Rabuyo - Volume I
A No.
Q_ Where had you worked prior to working for
Mr. Epstein?
A_ | work as a certified nursing assistant.
Q_ Where?
A Atthat time | was doing private duty...
Giuffre_Maxwell_Batch4_p00557.png
Deposition
Case 1:15-cv-07433-LAP Document 1328-35 Filed 01/05/24 Page 5 of 10
Q. So out of your entire report, the only two people who ever said anything about
Ms. Maxwell were Ms. Sjoberg, who I believe was 23 when you interviewed her?
A. Right, but...
Giuffre_Maxwell_Batch4_p00601.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 9 of 31
abused numerous underage girls in his Florida mansion, his New York mansion, and several
other places that Dershowitz apparently admits he visited on multiple occasions.
In 2009, one of Epstein’s household employees...
Giuffre_Maxwell_Batch5_p00017.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 3 of 40
that you immediately withdraw those interrogatories. See Rule 33.3, Local Rules for the
Southern District of New York; see also Shannon v. New York City Transit Auth., No. 00 CIV.
5079 (Sweet...
Giuffre_Maxwell_Batch6_p00252.png
15-cv-07433-LAP Document 1331-21 Filed 01/05/24 Page 4 of 8
Case 1
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Giuffre_Maxwell_Batch3_p00067.png
Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 7 of 17
be safe under Epstein’s roof, not least because he phoned her to reassure her, and she
also knew he had Ghislaine Maxwell with him at all times. When the girls’ mother
learned...
Giuffre_Maxwell_Batch4_p00397.png
Court Filing
OQS - Vi&ASE Gabo AAA ARS3D0cument 1328-22 Filed 01/05/24 Page 7 Of Pe 5 of 20
PALM BEACH COUNTY SHERIFF'S OFFICE PAGE 1
CASE NO. 98041883 SUPPLEMENT 2 OFFENSE REPORT CASE NO. 98041883
DISPOSITION: OPEN
DIVISION: DETECTIVE
911: N CONFIDENTIAL
SEXUAL BATTERY * * *
SIGNAL CODE: CRIME CODE...
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