PublicIntel_Batch7.pdf

"the email account she used while abusing Ms. Giuffre from 2000-2002 in violation of this Court’s Order"

"Jeffrey Epstein’s house manager, Juan Alessi testified"

"It was a computer guy who worked only for Jeffrey. Mark. Mark Lumber."

"Defendant lived in Palm Beach and Manhattan"

"Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant."

"Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant."

"The Honorable Loretta A. Preska District Court Judge"

"Plaintiff, Virginia Giuffre, by and through her undersigned counsel... Respectfully, /s/ Sigrid S. McCawley"

"Ms. Giuffre issued requests to Defendant on October 27, 2015."

"L.M. v. Jeffery Epstein and Sarah Kellen,2 gives a fuller representation"

"VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant."

"VIRGINIA L. GIUFFRE, Plaintiff"

"GHISLAINE MAXWELL, Defendant."

"Laura A. Menninger... HADDON, MORGAN, AND FOREMAN, P.C.... attorneys for Defendant Ghislaine Maxwell"

"Jeffrey S. Pagliuca... HADDON, MORGAN, AND FOREMAN, P.C.... attorneys for Defendant Ghislaine Maxwell"

"Sigrid McCawley (Pro Hac Vice) Boies Schiller & Flexner LLP"

"Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP"

"Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C."

"Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C."

"Case 1:15-cv-07433-LAP Document 1332-1 ... Ms. Maxwell requests that the Motion be denied"

"address book purportedly recovered from Mr. Epstein’s home by the Palm Beach Police in 2005"

"Plaintiff’s counsel, Meredith Shultz, wrote on May 17, 2016"

"Case 1:15-cv-07433-LAP"

"Ms. Maxwell has not been employed by Mr. Epstein for over 10 years"

"Defendant is ordered to collect all ESI by imaging her computers"

"Plaintiff fails to carry her burden of proving those factors are present in this case. Defendant does not contest that she is obligated to comply with"

"things that I had written to get my story out of my head and into pages"

"Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant."

"Attorneys for Ghislaine Maxwell Laura A. Menninger"

"Attorneys for Ghislaine Maxwell Jeffrey S. Pagliuca"

"her long-time boyfriend and joint defense partner, Jeffrey Epstein."

"Defendant and Epstein are currently both parties to a joint defense agreement"

"Plaintiff, Virginia Giuffre, by and through her undersigned counsel, hereby files this Reply"

"undisclosed email account on Epstein’s server that she says she cannot access."

"Laura A. Menninger... HADDON, MORGAN AND FOREMAN, P.C."

"Ms. Giuffre had to litigate for Defendant to commence discovery (DE 28)."

"You may consider that this evidence would have been unfavorable to Defendant on the issue of her defense that her alleged defamatory statements were t"

"The following examples are some conferral letters sent by Ms. Schultz, counsel for Ms. Giuffre, that Defendant’s counsel have chosen to ignore"

"Defendant’s Resp. Br. at 2 (emphasis added). Defendant has it exactly backwards. It is Defendant’s responsibility to be “bothered” to answer"

"Laura A. Menninger, Esq. ... HADDON, MORGAN & FOREMAN, P.C. ... Counsel for Defendant"

"Jeffrey Pagliuca, Esq. ... HADDON, MORGAN & FOREMAN, P.C."

"Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP"

"Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant."

"Sigrid McCawley BOIES, SCHILLER & FLEXNER LLP ... Attorneys for Virginia Giuffre"

"Sigrid McCawley BOIES, SCHILLER & FLEXNER LLP"

"Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS"

"Virginia L. Giuffre, Plaintiff"

"United States District Court Southern District of New York ... Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant."

"Plaintiff, Virginia Giuffre, hereby files this Reply in Support of her Motion to Compel Work Product and Attorney Client Communications with Philip Ba"

"By January 2015 Ms. Maxwell had retained British Solicitor Philip Barden to represent and advise her in connection with plaintiff’s publication in the"