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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
nts #1067-1073 and #1074-79 Are Privileged Documents 41067-1073 and #1074-79 are mostly duplicative. In the N1074-79 series, communications between Harden, Defendant 34 EFTA_R1_00012010 EFTA01734220 Case 1:15-cv-07433-RWS Document 135 Filed 05/02/16 Page 35 of 37 . .1 and Cohen and between Barden
n ($49 billion) from 4.98 trillion yen a year earlier, according to the manufacturer, based in 'Thy- eta dly in central Ian. Toyota will overtake GM ac the world's No. I automaker in a few years if the current pace continues. In July. Toyota for the first time beat Ford Motor Co. in U.S. veh
he navigated New York high society. When he first attracted notice in the early 1990s. it was on account of the woman he was dating. Gh istaine Maxwell. daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Max- wells Secret Love," the
largest edam residence in Manhattan, It is repotted to have closed-circuit televisJon and a heated sidewalk to melt fallen snow. Women in his life Ghislaine Maxwell, a future at elite parties and the intensely private daughter of a media tycoon, dated Epstein in the 199Os. 'I'm like 'd• Reiss; told polic
In a lengthy article, headlined "The Mystery of Ghislaine Max- wells Secret Love," the British Mail an Sun
w what's going on ... how I can help. I feel I have a very good rela- tionship with staff. I've really grown close to them over the years" 'Though Harden, who oversees city staff, nonnally would speak to the employees about customer ser- vice and morale, Perlman said he thought it was his responsibi
C Protests in a Defense of Warrantless Spying • Bob Menendez's Bribery Case Reminds Us Why Proving Corruption Is So Hard CRIMINAL INVESTIGATIONS • Ghislaine Maxwell's Lawyer Tell Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Republicans Subpoenaed 15 Years of Hunter Biden Phone Records, De
argument was repeatedly challenged by one judge on the 2nd U.S. Circuit Court of Appeals before the three-judge panel reserved decision. Lawyers for Maxwell are challenging her December 2021 conviction on multiple grounds, but the only topic at oral arguments was whether the deal Epstein struck in Flori
Corruption Is So Hard CRIMINAL INVESTIGATIONS • Ghislaine Maxwell's Lawyer Tell Appeals Judges That Jeffrey
, according to the letter. In States With Laws Targeting LGBTQ Issues, School Hate Crimes Quadrupled The Washington Post (03/12, Meckler, Natanson, Harden) reported that school hate crimes targeting LGBTQ+ people have sharply risen in recent years, climbing fastest in states that have passed laws restr
C Protests in a Defense of Warrantless Spying • Bob Menendez's Bribery Case Reminds Us Why Proving Corruption Is So Hard CRIMINAL INVESTIGATIONS • Ghislaine Maxwell's Lawyer Tells Appeals Judges That Jeffrey Epstein's Florida Plea Deal Protects Her • Republicans Subpoenaed 15 Years of Hunter Biden Phone Records, D
argument was repeatedly challenged by one judge on the 2nd U.S. Circuit Court of Appeals before the three-judge panel reserved decision. Lawyers for Maxwell are challenging her December 2021 conviction on multiple grounds, but the only topic at oral arguments was whether the deal Epstein struck in Flori
Corruption Is So Hard CRIMINAL INVESTIGATIONS • Ghislaine Maxwell's Lawyer Tells Appeals Judges That Jeffre
, according to the letter. In States With Laws Targeting LGBTQ Issues, School Hate Crimes Quadrupled The Washington Post (03/12, Meckler, Natanson, Harden) reported that school hate crimes targeting LGBTQ+ people have sharply risen in recent years, climbing fastest in states that have passed laws restr
6 Pieces 1 WOIghl 0 Delivered Liar 14. 20010926 JOHN ALESSI JEFFREY E EPSTEIN 457 MADISCN AVE NEW YORK NY 100224939 US Tramp:40w Charge 0 MAXWELL J EPSTEIN 6 CO 457 MADISON AVE 4TH NEW YORK NY 10022 US t6.50 SONO? Courier Pickup Charge 0.00 Area Code Al Nei Stitch/Me 095 Signed by
Ce Basso Pricing. Region 5 FedEx has audited tog arbll Ice correct pieces. weigh. and service. Arr/ changes made are rellee.ed in the invoice anew* Harden° ID 907139521863 Service Type FedEx MOM Overnight Package Type FedEx Pak Sender Re0Pent JERRY PERKINS STRUCTALUNG LARRY VlSOSKI 1131 PINE PO
Entities connected to both Ghislaine Maxwell and Harden

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
FedEx
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSONDoug Band
PERSONFBI
ORGANIZATION