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Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 13 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
b. the type of consultation, examination, or treatment pr
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 6 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
on hundreds (if not thousands) of matters, and collectivel
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 4 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
Case no. 08-80736 CIV-Marra, pending in the Southern Distr
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 2 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
United States District Court
Southern District of New York
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 33 of 40
The request is also vague because it is not clear precisely what “witnesses”
Defendant Maxwell is concerned about. There have, for
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 36 of 40
Giuffre objects in that it seeks information protected by the attorney-client/work
product privilege, and any other applicable priv
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 32 of 40
RFP No. 9. All Documents concerning any Communications between You or
Your attorneys and any witness in the case captioned Jane Doe
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 40 of 40
CERTIFICATE OF SERVICE
I certify that on August 10, 2016, I electronically served this Defendant’s Motion to
Compel Responses to D
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
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 19 of 40
Corp., 2014 WL 6885905, at **2-3 (W.D.N.Y. Dec. 8, 2014) (plaintiffs preexisting mental and
physical conditions relevant to plainti
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.
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 11 of 40
in this matter, and has failed to comply with her production obligations with this
very subject matter. See Document Request No. 17
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 14 of 40
defamed by Alan Dershowitz, but she failed to provide any information about the allegedly
defamatory statements made by Mr. Dershow
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 10 of 40
Plaintiffs deficient answer. “Notwithstanding” her objections, Plaintiff “answered” by
referring the defense to 7,566 pages of docu
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
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 5 of 40
that Ms. Maxwell has published “numerous” false statements, yet Plaintiff stubbornly refuses to
identify each of these allegedly fal
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 1 of 40
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ween eee xX
VIRGINIA L. GIUFFRE,
Plaintiff,
Vv.
15-cv-07433-RWS
GHISL
Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 16 of 26
JOSEP
MS. SCHU
THE WITN
BY MR. PAGLIUCA:
LTZ:
ESS:
Page 215
H RECAREY - CONFIDENTIAL
Object to form, foundation.
I don't re
Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 25 of 26
Page 303
JOSEPH RECAREY - CONFIDENTIAL
went to New York but on a commercial flight. Does
that jog your memory?
MS. SCHULTZ: Objec
Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 12 of 26
Page 195
JOSEPH RECAREY - CONFIDENTIAL
as part of this case, right?
A. Correct,
consenting adults.
Q. Exactly.
because it was
Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 5 of 26
Page 180
JOSEPH RECAREY - CONFIDENTIAL
Exhibit 1. Are you with me?
A. Uh-huh.
Q. Okay. Again, this was information that
was obtai
Case 1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 4 of 26
Page 179
JOSEPH RECAREY - CONFIDENTIAL
(The referred-to document was marked by
the court reporter for Identification as
Deposition
Case 1:15-cv-07433-LAP Document 1328 Filed 01/05/24 Page 1of1
BOIES
SCHILLER
—_ FLEXNER
January 5, 2024
VIA ECF
The Honorable Loretta A. Preska
District Court Judge
United States District Court
S
Case 1:15-cv-07433-LAP Document 1328-1 Filed 01/05/24 Page 3 of 3
CERTIFICATE OF SERVICE
I certify that on August 8, 2016, I electronically served this Declaration Of Jeffrey S.
Pagliuca In Support
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 27 of 27
CERTIFICATE OF SERVICE
I certify that on August 8, 2016, I electronically served Response in Opposition to Plaintiff's
Motion to
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 26 of 27
Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions
Filed Under Seal. Further, because Plainti
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 c
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 18 of 27
second deposition, the same Exhibit 13 was introduced and Ms. Maxwell was asked, without
objection, questions relating to specific
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
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 7 of 27
Epstein’s assistants would arrange times for underage girls to perform sexual massages.
Pagliuca Decl., Ex. C at 253-55. She was ex
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 3 of 27
Defendant Ghislaine Maxwell, by and through her counsel, hereby submits the following
Response in Opposition (“Response”) to Plaint
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 10 of 27
Duplicative Topic of Questioning (Exhibit) ition (Exhibit Dp osition
47:15-49:18;
Her knowledge of Sara Kellen, when she last 56:2
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 9 of 27
be required to answer questions about adult consensual sexual activity — the only questions on
which instructions were given in th
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 1 of 27
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ween eee xX
VIRGINIA L. GIUFFRE,
Plaintiff,
Vv.
15-cv-07433-RWS
GHIS
Case 1:15-cv-07433-LAP Document 1327-21 Filed 01/05/24 Page 8 of 11
Page 361
G Maxwell - Confidential
(Maxwell Exhibit 17, email, marked
for identification.)
Q. This is an email from you on
Janua
Case 1:15-cv-07433-LAP Document 1327-21 Filed 01/05/24 Page 9 of 11
Page 405
G Maxwell - Confidential
with Virginia Roberts.
Q. I'm marking this as Maxwell 25.
(Maxwell Exhibit 25, email, marked
fo
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 18 of 21
show (1) that the party having control over the evidence had an obligation to timely produce it;
(2) that the party that failed to
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 19 of 21
the party; (b) instruct the jury that it may or must presume the information was unfavorable to
the party; or (C) dismiss the acti
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 15 of 21
A. Yes.
56:13-17; 5:2-14; 58:1-7; 60:21-61:7 (February 16, 2010) (Emphasis added) (McCawley Decl. at
Exhibit 8).
Defendant (i em
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 11 of 21
A. Because you know, I know Jeffrey.
Maxwell Dep. Tr. at 271:18-22 (April 22, 2016) (McCawley Decl. at Exhibit 2).
Yet, Maxwell no
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 9 of 21
52:8-57:23 (June 10, 2016) (McCawley Decl. at Exhibit 4). Ms. Giuffre has also implicated Eva
Dubin’s husband, Glen Dubin, as someo
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 10 of 21
massage, which Epstein walked in on while she was getting a massage. He asked her
to turn over, expose her breasts to him. I think
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 4 of 21
In your June 8 letter, apparently acknowledging the overbreadth of the RFP,
you suggest the defendant could respond by conducting a
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 2 of 21
e Plaintiff's Response in Opposition to Defendant’s Motion to Stay Discovery (DE 20)
- Defendant’s Motion to Stay - Denied (DE 28).
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 3 of 21
IL. DISCUSSION
At a minimum, the Court should direct Defendant to run the search terms in the list
originally submitted by Ms. Giu
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 1 of 21
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine
Case 1:15-cv-07433-LAP Document 1327-16 Filed 01/05/24 Page 3 of 6
initials. With regards tof, you told me that is ‘J and there is no standalone request for
communications with her.
-Laura
Laura A.
Case 1:15-cv-07433-LAP Document 1327-15 Filed 01/05/24 Page 2 of 5
From: Laura Menninger
Sent: Monday, July 18, 2016 2:27 PM
To: ‘Meredith Schultz’
Ce: Jeff Pagliuca; ‘Sigrid S. McCawley - Boies,
Case 1:15-cv-07433-LAP Document 1327-12 Filed 01/05/24 Page 5 of 11
searched yet there is no RFP related to those names, nor the vast majority of the other listed first
and surnames.'
By corresponde
Case 1:15-cv-07433-LAP Document 1327-12 Filed 01/05/24 Page 6 of 11
tremendous stretch, I can agree to them in the interest of getting the search done on a timely
basis.”).? Having heard nothing from