1320-17.pdf

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

"VIRGINIA L. GIUFFRE, Plaintiff"

"GHISLAINE MAXWELL, Defendant"

"Produce all documents concerning Virginia Giuffre... or any other document that concerns Plaintiff in any way"

"paying Ross Gow, or any entities associated with Ross Gow, for any work he performed on Your behalf."

"Case 1:15-cv-07433-LAP Document 1320-17 Filed 01/03/24... Ms. Maxwell objects to this Request"

"Ms. Maxwell has made available documents related to some of Ms. Giuffre’s contacts with law enforcement in her Second Supplemental Fed. R. Civ. P. 26("

"nor will Defendant move for a Protective Order with regard to this Request, without further conferral"

"Ms. Maxwell objects to this Request on the grounds that it is overly broad and unduly burdensome"

"Defendant move for a Protective Order with regard to this Request"

"counsel for Plaintiff has agreed to hold this Request in abeyance pending either a finding of liability or resolution of dispositive motions. Plaintif"

"produce all documents concerning any source of funding for the TarraMar Project or any other not-for-profit entities with which You are associated"

"Ms. Maxwell objects to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are ir"

"Laura A. Menninger (LM-1374) ... Attorneys for Ghislaine Maxwell"

"Jeffrey S. Pagliuca (pro hac vice) ... Attorneys for Ghislaine Maxwell"

"DEFENDANT GHISLAINE MAXWELL’S RESPONSES AND OBJECTIONS TO PLAINTIFF’S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS"

"Laura A. Menninger (LM-1374) ... HADDON, MORGAN AND FOREMAN, P.C."

"Sigrid S. McCawley ... BOIES, SCHILLER & FLEXNER, LLP"

"Bradley J. Edwards ... FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L."

"I certify that on May 16, 2016, I served the attached document ... via email to the following counsel of record: Sigrid S. McCawley"

"Case 1:15-cv-07433-LAP ... Ms. Maxwell also objects to this Request"

"Mr. Pagliuca stated that... Ms. Maxwell's counsel during the March 16, 2016 meet and confer."

"Mr. Pagliuca stated that... in the March 21, 2016, meet and confer discussion"

"Joint Defense Agreement entered into between You and Jeffrey Epstein from 1999 to the present"

"Produce any Joint Defense Agreement entered into between You and Jeffrey Epstein from 1999 to the present."

"Case 1:15-cv-07433-LAP Document 1320-17 Filed 01/03/24 Page 15 of 25"

"counsel for Plaintiff has agreed to hold this Request in abeyance pending either a finding of liability or resolution of dispositive motions"

"DEFENDANT GHISLAINE MAXWELL’S RESPONSES AND OBJECTIONS TO PLAINTIFF’S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS"

"Plaintiff was abused by Jeffrey Epstein"

"Defendant is withholding communications between Mr. Dershowitz’s counsel and Defendant’s counsel which contain work product and concern joint defense "

"Produce all documents concerning which individuals or entities You or Your agents distributed or sent any statements... You, Ross Gow, or any other in"

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

"Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this Request in abeyance"

"counsel for Plaintiff has agreed to hold this Request in abeyance pending either a finding of liability"

"Based on the May 16, 2016 conferral, counsel for Plaintiff has agreed to hold this Request in abeyance"

"counsel for Plaintiff has agreed to hold this Request in abeyance pending either a finding of liability"

"relating to the recruitment of any female under the age of 18 for any purpose... socializing or performing any type of work or services."

"bank accounts owned by You solely, or jointly as co-owner, partner, or joint venture, in any business enterprise"

"allegations concerning her sexual assault... were found to be unfounded by local police."

"Produce all contracts, including but not limited to indemnification agreements and employment agreements, between You and Jeffrey Epstein"

"evidences of ownership possessed by You or held for Your beneficial interest with respect to... Aircraft of any type"

"activity of defendant with respect to the practice which has been alleged... defined as sexual abuse or trafficking"

"produce all documents concerning any source of funding for the TarraMar Project... including but not limited to, funding received from... the Clinton "

"produce all documents concerning any source of funding for the TarraMar Project... including but not limited to, funding received from the Clinton Glo"