Epstein Secrets

1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GUIFFRE, Plaintiff, 15 Civ. 7433 (RWS) - against - OPINION GHISLAINE MAXWELL, Defendant. X APpEARANCE S: Counsel for Plaintiffs BOEIS, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderd

07433-RWS Document 135 Filed 05/02/16 Page 2 of 37 Sweet, D.J. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved to compel Defendant Ghislaine Maxwell ("Maxwell" or "Defendant") to produce documents withheld on the grounds of privilege.- !lased on the conclusions set forth below, the motion is gr

35 Filed 05/02/16 Page 2 of 37 Sweet, D.J. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved to compel Defendant Ghislaine Maxwell ("Maxwell" or "Defendant") to produce documents withheld on the grounds of privilege.- !lased on the conclusions set forth below, the motion is granted in p

d NY law." Privilege Log at 1. Defendant argues "Ms. Maxwell's communications with Mr. Barden should be const

,..an exclusive agency agreement between the Defendant company and third party was provided to the court and upon which the,court relied. Stroh v. General Motors Corp. involved a tragic underlying car accident wherein the 76-year old Plaintiff had lost control of her vehicle driven into a park. Stroh v. Gen. Motor

bmitted an affidavit (substantially similar to the affidavits submitted in support of the instant motion) in which he attested that he was hired by GM with the understanding that communications would be protected by the attorney-client privilege, that he was retained to perform work in anticipation

ts or representatives of a party's attorney. 12. The attorney-client privilege also extends to subordinates of a party's attorney. See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court noted that to invoke the attorney client privilege: (1) the asserted holder of the privilege

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ere 34 percent lower than a year ago. "Stimulating sales is the only way to get the auto industry back on its led," said Rep. Donald Manzullo, General Motors Corp. and Chrysler LLC have received billions of dol- lars in government aid and the entire auto indus- try has watched car sales plummet during the pa