1320-31.pdf

"Virginia L. Giuffre, Plaintiff: Case No.: 15-cv-07433-RWS V. Ghislaine Maxwell, Defendant"

"Sigrid Mccawley (Admitted Pro Hae Vice) Boies Schiller & Flexner LLP"

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

"I HEREBY CERTIFY that on February 16, 2016, l served the foregoing document on the individuals identified below via email. Laura A. Menninger, Esq."

"Virginia L. Giuffre, Plaintiff: Case No.: 15-cv-07433-RWS"

"Ghislaine Maxwell, Dc1endanL. Case No.: 15-cv-07433-RWS"

"Document 1320-31 Filed 01/03/24"

"Defendant shall mean the ddendant Ghislaine Maxwell and her employees, representatives or agenls."

"offict:.s of Boies Schiller & Flexner, LLP, 575 Lexington Avenue, New York, :-Jew York."

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

"All documents relating to payments made from Jeffrey Epstein, Ghislaine Maxwell, or any related entity to you from 1996 -present."

"All documents relating to or describing any work you performed with Jeffrey Epstein, Ghislaine Maxwell, or any affiliated entity from 1996 -2008."

"All documents rdaling to your travel from the period of 1996 - 2008, when that travel ,:vas either with Ghislaine Maxwell or Jeffrey Epstein, or to me"

"BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley... Meredith Schultz... David Boies"

"PLAINTIFF’S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF JEAN LUC BRUNEL"

"Virginia L. Giuffre, Plaintiff"

"Ghislaine Maxwell, Defendant"

"The name, address, e-mail address, and telephone number of the attorney representing (name ofparty) Virgina Giuffre Sigrid S. Mccawley"

"Laura A. Menninger, Esq. ... following counsel of record"

"Sigrid S. Mccawley, BSF, LLP"

"United States District Court Southern District of New York ... Case No.: 15-cv-07433-RWS"

"Case 1:15-cv-07433-LAP Document 1320-31 Filed 01/03/24 Page 23 of 24"

"From: Brad Edwards To: Laura Menninger; Jeff Pagliuca Subject: Depositions next week Date: Thursday, June 02, 2016"

"From: Brad Edwards To: Laura Menninger; Jeff Pagliuca Subject: Depositions next week"

"[email protected]"

"[email protected]"

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

"We got an email yesterday from Mr. Brunel's attorney saying he needs to reschedule."

"Laura, can you talk later this afternoon to see what we can do about a deposition schedule that makes sense for everyone going forward?"

"I HEREBY CERTIFY that on February 16, 2016, l served the foregoing document on the individuals identified below via email. Laura A. Menninger, Esq."

"Case 1:15-cv-07433-LAP Document 1320-31 Filed 01/03/24 Page 7 of 24 TO: JEA.~ LUC BRUNEL EXIHBIT A DEFINITIONS"

"All documents relating to models or females thar you employed who also worked for or interacted with Jeffrey Epstein or Ghislaine :\1axwe11."

"We got a similar email from Mr. Fontanella's lawyer yesterday saying that he is also not available next week."

"As of right now, the only confirmed depo for next week is that of Mr. Rizzo."

"I have not heard from anyone representing Jane Doe 2 yet. I was hoping you could tell me whether she is represented and whether next week works for he"

"Jeffrey Epstein includes Jeffrey Epstein... Ghislaine Maxwell includes Ghislaine Maxwell and any entities owned or controlled by Ghislaine Maxwell"

"All video 1apes, audio tapes... that relate to: (1) Alan Dershowitz; (2) Virginia Roberts; (3) Alan Dershowitz in the presence of Virginia Roberts"

"Alan Dershowitz in the presence of Jeffrey Epstein am.I and/or any female agent or employee of Jeffrey Epstei n."

"[email protected]"

"AO 88A (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action (Page 3) Federal Rule of Civil Procedure 45 (c), (d), (e), and (g)"

"f the United States, or one of its officers or agents, I have also tendered to the witness the fees for one day's attendance"