In the court document filed on January 8, 2024, plaintiff Virginia L. Giuffre moves to compel defendant Ghislaine Maxwell to produce data from an undisclosed email account that Maxwell allegedly used from 2000-2002 and for an adverse inference instruction. The plaintiff asserts that the defendant has violated previous court orders by not disclosing the account nor producing requested documents from it, and despite substantial internet usage statistics from that era and the implication that Maxwell, who had extensive resources and a shared household with Jeffrey Epstein (who had a private email server), likely used email then. The plaintiff requests the court to compel Maxwell to disclose this account and sanction her for noncompliance, while Maxwell insists she has complied with all court orders and that no undisclosed account exists. The court is asked to provide an adverse inference jury instruction due to Maxwell's failure to disclose the email account and defiance of court orders.
During a court hearing in the case of Virginia L. Giuffre v. Ghislaine Maxwell, several motions were addressed, including the consideration of the release of a redacted opinion, the request to compel testimony from Jeffrey Epstein, the reopening of Ghislaine Maxwell's deposition to question her about newly produced emails, and a motion to compel additional electronic data. The court ruled that Maxwell would be deposed again regarding the emails but denied the motion for additional data, instructing the parties to meet and confer. Epstein's attorney, Martin Weinberg, was granted permission to submit further information on the issue of the Fifth Amendment waiver, and Paul Cassell, attorney for Giuffre, was granted permission to respond.
In this legal document, Plaintiff Virginia Giuffre, represented by the law firm Boies, Schiller & Flexner LLP, submits a reply in support of a motion to compel production of all work product and attorney-client communications between Defendant Ghislaine Maxwell and her attorney Philip Barden. The Plaintiff asserts that the Defendant has failed to produce the requested discovery materials, claiming they are protected by attorney-client privilege, which has been waived. The waiver occurred when the Defendant used Barden's statements about communications with her and his legal strategies as a defense in her summary judgment motion, thus placing this information at issue in the case. Consequently, the Plaintiff requests the court to compel the Defendant to produce these communications and to permit a deposition of Philip Barden regarding these matters.
Meredith Schultz, a licensed attorney with the law firm Boies Schiller & Flexner LLP, has submitted a sworn declaration in support of the plaintiff Virginia L. Giuffre's reply motion to compel the defendant Ghislaine Maxwell to disclose all work product and attorney-client communications with Philip Barden. In this declaration, Schultz affirms the truth of the attached exhibits, including Barden's declaration and Maxwell's privilege logs. Additionally, Schultz provides proof of service, confirming the electronic filing of this document with the court and its distribution to the parties of record using the court's electronic filing system. The declaration is dated March 7, 2017, and is part of the court documents for case number 15-cv-07433-RWS filed in the Southern District of New York.
The provided text is a declaration by Philip Barden in support of Ghislaine Maxwell's motion for summary judgment in a legal case involving allegations made by Virginia Giuffre. Barden, a Solicitor of the Senior Courts of England and Wales, represents Maxwell and outlines their legal response to various public allegations attributed to Giuffre—including claims involving Prince Andrew and Professor Dershowitz—that were published in the British press. The declaration discusses the strategic dissemination of a press statement, the intent to mitigate damage to Maxwell's reputation by contesting the credibility of Giuffre's changing claims, and Barden's ethical obligations as a lawyer while issuing the statement. The document reveals that although litigation against the press for defamation was considered, it notes that the statute of limitations for defamation had expired, leaving open the possibility of other tortious claims. The declaration emphasizes that Maxwell vehemently denies Giuffre's allegations and seeks legal redress, questioning Giuffre's truthfulness and motives.
The document is a privilege log from the United States District Court For The Southern District of New York, pertaining to the case of Giuffre v. Maxwell (Case 1:15-cv-07433-RWS). Filed on January 8, 2024, the log lists communications, primarily emails dated from 2011 to 2015, involving Ghislaine Maxwell and various parties including her legal counsel, Brett Jaffe, Esq., Ross Gow, Jeffrey Epstein, and Alan Dershowitz, Esq. The communications are asserted as privileged under British law, Colorado law, and New York law, with categories of privilege including Attorney-Client, Common Interest, Attorney Work Product, and others, indicating a protection against disclosure of sensitive legal discussions and strategy. This log was amended up to August 1, 2016, and contains detailed specifications of the types of privilege claimed for each document or email exchange.
In a U.S. District Court case between Virginia L. Giuffre and Ghislaine Maxwell, non-party Sarah Ransome filed a Reply in Support of her Motion for a Protective Order to prevent further invasive discovery requested by Maxwell's team and contested the Defendant's Motion to Compel her to produce additional documents and deposition testimony. Ransome, previously a victim of sex trafficking, argues that Maxwell's demands are undue, intended for harassment, and irrelevant to the 2015 case. Ransome asserts she has already provided substantial evidence, including witness testimony and photographic evidence of Maxwell's involvement in Jeffrey Epstein's alleged sex trafficking activities, challenging Maxwell's limited disclosures. The document submitted by Ransome's counsel on January 8, 2024, urges the court to protect her from Maxwell's continued invasive discovery efforts.
This document, titled "Nonparty Sarah Ransome’s Responses and Objections to Defendant’s Subpoena Requests," pertains to the case Virginia L. Giuffre v. Ghislaine Maxwell. Sarah Ransome, who is not a party in the case, has received a subpoena from the defendant, Maxwell, seeking various personal documents. Ransome's response includes numerous objections to the requests within the subpoena, arguing that they are irrelevant to the case, violate attorney-client privilege and privacy, and amount to harassment. The 27 items listed in the subpoena cover a wide range of requests, including inquiries into Ransome's communications, financial information, education, mental health records, and details about travel and residency, spanning various years. Each request is met with specific objections by Ransome, and in certain instances, she states either that responsive documents will be provided under a protective order or that no such documents exist or are in her possession. The document ends with a certificate of service indicating that Ransome’s objections were electronically served to the relevant parties on February 13, 2017.
This document is a legal filing from Ghislaine Maxwell's defense attorneys, titled "Defendant’s Reply in Support of Motion to Compel Non-Party Witness to Produce Documents and Respond to Deposition Questions," directed to the Southern District of New York. The filing contends that the non-party witness, Virginia L. Giuffre, has failed to produce necessary documents and answer deposition questions relevant to the case, Maxwell vs. Giuffre. The defense argues that Giuffre's evasion in providing a complete privilege log, her refusal to produce comprehensive responses to requests for various categories of documents (including photographs, financial records, passports, and communications), and her improper non-responses to deposition questions are unjustifiable. The defense requests that the court order Giuffre to comply by providing the requested information and reappearing for deposition to answer all relevant inquiries.
During a court hearing related to the defamation lawsuit between Virginia L. Giuffre (plaintiff) and Ghislaine Maxwell (defendant), the parties presented arguments on a motion for summary judgment. The defense argued that the plaintiff cannot establish defamation as they cannot prove the specific allegations referred to in Maxwell's statement were false or made with actual malice. Additionally, the defense claimed the issues of republication and pre-litigation privilege protect Maxwell from libel claims. The plaintiff contested these defenses, emphasizing evidence of sexual abuse and trafficking by Maxwell, challenging the characterization of the statement as a press release, and asserting it's defamatory to call Giuffre a liar about abuse claims. The judge reserved the decision and planned to consider other motions post summary judgment resolution.
This document reflects a legal submission made by Ghislaine Maxwell's attorneys in response to Virginia L. Giuffre's motion to compel the disclosure of work product and attorney-client communications with Philip Barden. Maxwell's lawyers argue that Giuffre's motion should be denied due to procedural deficiencies, such as failure to confer prior to filing the motion and insufficient identification of specific discovery requests. Additionally, they contend that the plaintiff's motions do not establish a waiver of attorney-client privilege and are, therefore, frivolous and sanctionable. The submission requests that the court deny Giuffre's motion and award sanctions to Maxwell for the improper motion to compel.
In this document, Ghislaine Maxwell's legal team has filed a motion in the Southern District of New York to appoint a special master to preside over her third deposition. The defense argues that the appointment is necessary due to previous issues during depositions, including repetitive questioning beyond the court's orders, and to provide immediate rulings on any further objections. They cite instances of what they consider improper conduct by the plaintiff's counsel, such as refusing Maxwell breaks and limiting communication with her counsel. The document outlines the limited scope of the deposition as previously ordered by the court and emphasizes the need for efficiency, given the trial's commencement date. Maxwell's attorneys propose that the costs for the special master be shared equally between the parties and offer to submit a list of potential candidates for the court's consideration.
Laura A. Menninger, a licensed attorney admitted to practice in the United States District Court for the Southern District of New York and member of Haddon, Morgan & Foreman, P.C., has submitted a declaration in support of appointing a Special Master to oversee a third deposition of defendant Ghislaine Maxwell in the case of Virginia L. Giuffre vs. Ghislaine Maxwell (case number 15-cv-07433-RWS). The declaration includes portions of Maxwell's previous deposition designated as confidential and confirms that a copy of the declaration was electronically served to the involved parties' attorneys. The declaration and certificate of service were executed and filed with the court on April 11, 2017.
Virginia Giuffre's lawyers submitted a memorandum opposing Ghislaine Maxwell's motion to appoint a special master for her third deposition, arguing it's unnecessary and costly. They clarify the court orders for Maxwell's depositions regarding failing to answer questions related to sexual activities and late production of emails. Giuffre's legal team contends a special master would be ill-equipped to rule on the complexity of the case and burden Giuffre with undue expenses, given Maxwell's previous improper deposition conduct and document withholding. They request the court to deny the motion and confirm that Maxwell's deposition on two different topics will not exceed a total of four hours.
In this United States District Court Southern District of New York document, plaintiff Virginia L. Giuffre and Non-Party Jane Doe 43 oppose a motion filed by nonparties Jeffrey Epstein and Leslie Groff ("Epstein Defendants") seeking leave to intervene and to modify a protective order which was established to maintain the confidentiality of certain documents in a case involving commercial sex trafficking claims against Epstein, et al. The court has previously determined that non-parties do not have the right to challenge the protective order. Despite an agreement by Jane Doe 43 and Virginia Giuffre to release specific documents, the Epstein Defendants pursued additional documents. The response argues that the documents in question do not pertain to Epstein Defendants' statute of limitations and jurisdiction claims in their motion to dismiss. The response asserts the proposed intervenors are aiming to publicly embarrass Jane Doe 43 and misuse the documents unrelated to their motion to dismiss, maintaining that the motion to intervene and modify the protective order should be denied.
The document is a legal letter from Emery Celli Brinckerhoff & Abady LLP to Honorable Robert W. Sweet of the U.S. District Court regarding the case Giuffre v. Maxwell. It outlines a request by Intervenor Professor Alan M. Dershowitz to declassify certain emails (designated as RANSOME_000273-557) alongside the deposition of Sarah Ransome, which Virginia Giuffre may seek to declassify. The firm argues that the emails are crucial for context and contesting Ransome's credibility, who has made serious accusations against Dershowitz, claiming false and defamatory allegations, including salacious claims involving Donald Trump, Bill Clinton, and other public figures. The firm stresses the importance of releasing these emails concurrently with the deposition to prevent a one-sided narrative and potential damage to Dershowitz's reputation.
Ghislaine Maxwell, through her attorneys, has filed a motion for an Order to Show Cause with the Southern District of New York, requesting the court to compel plaintiff Virginia Giuffre and her legal team to explain why they shouldn't be sanctioned for not adhering to the court's Protective Order. The order required all confidential materials to be returned or destroyed at the end of the case, which concluded in 2017, yet Giuffre's lawyers have retained the materials and allegedly wish to use them in a separate case. Maxwell's lawyers argue that this retention violates the court's directive and the terms of the Protective Order, and they are seeking court enforcement of the Order's requirements.
On January 8, 2024, an attorney named Sigrid S. McCawley submitted a letter to Judge Loretta A. Preska at the U.S. District Court for the Southern District of New York regarding the case Giuffre v. Maxwell, case number 15-cv-7433-LAP. In compliance with a court order dated December 18, 2023, the letter informed the court that the plaintiff is filing documents set to be unsealed. This filing process is scheduled to be done on a rolling basis and excludes certain documents associated with Does 105, 107, and 110, which are still under the court's review. The communication was made via the court's electronic filing system (ECF) and included a notice to other counsels of record.
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Representing any side.
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Judges, clerks, court reporters, videographers, etc - basically any 3rd party not associated with either side.
