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Case 1:15-cv-07433-RWS Document 422 Filed 09/06/16 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RENEWED MOTION TO COMPEL SETTLEMENT AGREEMENT Laura A.
Case 1:15-cv-07433-RWS Document 422 Filed 09/06/16 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RENEWED MOTION TO COMPEL SETTLEMENT AGREEMENT Laura A. Menninger
attorneys for You and/or Mr. Epstein." Menninger Decl. Ex. A. • On March 16, 2016 Defendants responded to the Request for production stating "Ms. Giuffre is in possession of a document that contains a confidentiality provision. If Defendant obtains, and produces to Ms. Giuffre, a written waiver from .
DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant.
ts designated their indemnification agreement as confidential does not shield it from discovery"); Tribune Co. v. Purciglioni, 1996 WL 337277 at •3; Weissman v. Fruchtman, 1986 WL 15669,'19 (S.D.N.Y.1986) ("parties' intention that agreement remain confidential is not controlling."). In sum, a third-party
GORDON,SCOTT LEVINSON,BARBARA BURKE,VIRGINIA GALLEY,RICHARD J DE TOMASO,ISABELLE
IBIS ISLE CEN COND HAGGIN,JOHN B WEISSMAN,MORRIS SOCIETY OF THE FOUR ARTS HAR
re were huge paintings. "I didn't grow up poor, but I realised there was more money there than I could ever have imagined. "We had a picture taken. Virginia, another girl there, sat on a chair and had the puppet on her lap. Andrew sat on another chair, I sat on his lap — and he put his hand on my breast.
leen Wailes, Michael (Gun Club) Weaver, Regina (DOVE) Weeks, David (CC L) Weems, Kathy (INTAKE) Welcher; Todd (CC C) Weiss, Daliah (CC E) Weissman. Marvin (Hem) Wenzel, Barbara (Fel X) Whittaker, Judith (Juv It) Whittaker, Sharon (Exec) Williams, Craig (COMBAT) Williams, Karl (Belle Gl
Entities connected to both Virginia Giuffre and Weissman

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSON
New York
LOCATION
Joe Biden
PERSON
Prince Charles
PERSON
Stephen Hawking
PERSONMaria Farmer
PERSON
Barack Obama
PERSON
Michael Jackson
PERSON
Eric Trump
PERSON
George Mitchell
PERSONEmmy Taylor
PERSON
Alfredo Rodriguez
PERSON