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MS. 
So with respect to these requests, I 
2 
just want to -- you know, because the Court has mentioned this 
3 
and it is worthy of referencing, that if you look at the 
4 
defendants' request to us, they actually request a longer time 
5 
period; they request from 1996 to the present. So while they 
6 
don't want us to -- they don't want to produce to us except for 
7 
that short window, they are requesting the entire period. In 
8 
some cases they request 
and I did a chart. Your Honor, 
9 
would you mind if I just pass this up to you for reference? 
10 
THE COURT: OK. 
11 
MS. 
I did a chart, I believe it is on page 
12 
10, and it has for you the various requests and what the time 
13 
periods are, and for many of the requests there is no time 
14 
period at all. 
15 
MR. PAGLIUCA: I have it. I don't need it. 
16 
MS. 
Oh, you have that? 
17 
MR. PAGLIUCA: I do not need it. 
18 
MS. 
OK. I'm sorry. 
19 
So that time period shows that many of those requests 
20 
don't have a time period at all; so it is even broader, from 
21 
infancy to present. So, in fairness, our requests are 1999 to 
22 
the present, which we believe is the critical time period. 
23 
Now, what happens in 2002? So my client does flee to 
24 
Australia away from these individuals, but the conduct 
25 
continues. So we have, for example, the law enforcement trash 
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pulls that show the message pads of the back and forth of 
2 
arranging these underaged minors to come for massages, things 
3 
of that nature. We have the flight logs that show Ms. Maxwell 
4 
flying 360 times with Jeffrey Epstein, 20 of which were with my 
5 
client when she was underage. We have the Palm Beach police 
6 
report, which shows over 30 minors who reported during that 
7 
time period, to up until now 2006, being abused in that 
8 
circumstance in Palm Beach. Then we have the arrest that 
9 
happens of Jeffrey Epstein in 2006. 
10 
Thereafter, my client in 2008 is -- I'm sorry, she 
11 
receives from the U.S. government a victim notification letter. 
12 
At that point, in 2009, Ms. Maxwell's deposition is sought in 
13 
underlying civil cases. She flees from that deposition, says 
14 
her mother is ill in England, she has to leave the country, 
15 
cannot be deposed. She then shows up three weeks later at 
16 
Chelsea Clinton's wedding. So clearly she was around, she was 
17 
able to do something, but she avoided that deposition. Her 
18 
testimony was never taken in that case. 
19 
So that's in 2009. Then we have in 2011 my client is 
20 
interviewed by the FBI about the issues that have happened. 
21 
Then we have in 2011 Ms. Maxwell starts issuing different 
22 
statements to the press. She continues that, issues a 
23 
statement in 2015, which is the statement that we are here 
24 
about in this case. 
25 
So I contend, your Honor, that all of those years have 
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relevant information in them with respect to my client. 
2 
THE COURT: OK. I understand. 
3 
Let's hear from the defendant. 
4 
MR. PAGLIUCA: So, your Honor, I have tried to refrain 
5 
from responding in kind, but the problem here is all of this --
6 
the agenda behind all of this is not really the issue in this 
7 
case but it is to make inflammatory statements like counsel 
8 
just made as fact when they are speculation, at best, your 
9 
Honor, and to pack into the record things that are demonstrably 
10 
not true but counsel says them like they are true and then 
11 
refers to her own declaration to support the fact of what she 
12 
is saying may or may not be true. So let's get to the issue 
13 
here in terms of the relevant timeframe. 
14 
has no contact with 
17 
Ms. Maxwell or Mr. Epstein. So everything that happens from 
18 
2002 forward has absolutely nothing to do with the plaintiff in 
19 
this case, and she has absolutely no personal knowledge about 
20 
what did or didn't happen in Florida or elsewhere from that 
21 
timeframe forward. 
22 
You know, I carefully, your Honor, read your ruling on 
23 
the motion to dismiss, and I believe that you characterized the 
24 
issue in this case very narrowly, and that is is what the 
25 
plaintiff said about Ms. Maxwell, and from 1999 to 2002, true 
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or not. Those two individuals have the facts that relate to 
2 
that, and anything outside of that, quite frankly, is opinion 
3 
and not a subject matter of this litigation. 
4 
Now, you have to focus not only on this expansive 
5 
timeframe in which the plaintiff is not even in this 
6 
hemisphere, which is combined with the overbroad requests that 
7 
don't ask for things that might be arguably relevant under a 
8 
404(b) analysis -- you know, for example, did this happen with 
9 
Ms. Maxwell and someone else in 2005, let's say -- those aren't 
10 
what the requests are. The requests are for all communications 
11 
for 17 years with plug in the individual, all documents 
12 
relating to whatever you want to plug in there for 17 years. 
13 
And so those two things combined create a grossly overbroad and 
14 
unmanageable document request. Hence, the objections. 
15 
Now, had we had the ability to confer about this, we 
16 
may have been able to get down to, here, these are really the 
17 
relevant timeframes, or you need to modify your requests for 
18 
production to say things like any communication with Jeffrey 
19 
Epstein related to the plaintiff, any communication with this 
20 
person related to the plaintiff. But that's not what the 
21 
requests are. And so what you are left with is an unmanageable 
22 
pile of requests for production of documents. 
23 
I will note, your Honor, so the Court has this in 
24 
context, there are 39 requests that have been proposed to 
25 
Ms. Maxwell. She has no responsive documents, and I've so 
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indicated to 17 of those requests. So we then winnow this down 
2 
to the ones that we are objecting to for very good reason. The 
3 
timeframe we have proposed is the appropriate timeframe. If 
4 
there are narrowly tailored requests for production for 
5 
something that may be relevant outside that timeframe, then 
6 
they should propose that and not what they are proposing 
7 
currently, which makes the entire process unwieldy and 
8 
unreliable. 
9 
MS. 
Your Honor, the underlying issue in 
10 
this case is whether or not Ms. Maxwell lied when she said my 
11 
client was not subject to the abuse that she said she was 
12 
subject to. So in order to prove that, for defamation with 
13 
malice, we have to prove that my client was abused by these 
14 
individuals, that these individuals did take advantage of her 
15 
in the way that she expressed. 
16 
What's relevant to that is the sexual trafficking 
17 
ring. If after my client left they are also trafficking other 
18 
underaged girls repetitively, that is relevant to prove the 
19 
truth of my client's allegations as well. We are entitled to 
20 
that in discovery, your Honor. One of the requests is the 
21 
documents relating to communications of Jeffrey Epstein. If 
22 
she is e-mailing Jeffrey Epstein about the girls she's going to 
23 
send over to him in 2004, before he is arrested, that's 
24 
relevant to my client's claim, your Honor. So we shouldn't be 
25 
told that we're not entitled to these documents or that we're 
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only entitled to two emails out of all of our requests. 
2 
In addition, he says that there are 17 requests that 
3 
they have no documents for, your Honor, but, again, they have 
4 
restricted the time period to this very short window and then 
5 
they answered in their responses. OK. So --
6 
MR. PAGLIUCA: That is not true. If you read --
7 
actually read the response, there is no restriction because we 
8 
have looked and there are no documents. We're actually trying 
9 
to move this ball forward, your Honor, and what's happening 
10 
here is we keep getting sucked back into this morass of maybe 
11 
something happened. If you listen to the words that counsel is 
12 
saying, your Honor, it is very illustrative of the fishing 
13 
expedition. If there is this, then it is relevant. But that 
14 
is not what they are asking for. And you have to go back to 
15 
the request. "All documents" -- Request No. 1: "All documents 
16 
relating to communications with Jeffrey Epstein from 1990 to 
17 
present." Well, that's not all documents concerning 
18 
trafficking or underaged girls, that's all documents relating 
19 
to, which could be anything in the universe. 
20 
Those are the reasons why I objected. 
21 
Request No. 3: "All documents relating to 
22 
communications with Andrew Albert Christian Edward, Duke of 
23 
York, from 1990 to present." You know, what the heck does a 
24 
communication with the Duke in 2013, any old communication, 
25 
have to do with anything in this case? Nothing. If you 
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said -- if you give me a request for production of documents 
2 
that said give me any documents that talk about your press 
3 
release with the Duke, well, that might be relevant and 
4 
discoverable, but these are grossly overbroad. 
5 
If they had conferred with us, we would have been able 
6 
to narrow this down, but they haven't because there is an 
7 
agenda here that, quite frankly, I don't understand, your 
8 
Honor. But what I think it is is to simply pack the record, 
9 
the written record and the oral record, with these very 
10 
specious, quite frankly, disgusting allegations about my 
11 
client, and that's not what we're here for. If they want 
12 
something, they should ask for it specifically. If they just 
13 
want to, you know, kind of throw things around -- if this, then 
14 
that -- then that's what we're about here. 
15 
MS. 
Your Honor --
16 
THE COURT: All right. I think I understand this 
17 
issue. 
18 
What else do we have? We have the timeframe and the 
19 
specificity. 
20 
MS. 
Right. So, your Honor, there is the 
21 
timeframe for the request, and then, right, I assume that they 
22 
are alleging that these are overbroad in some way as 
23 
THE COURT: I would rather think I just heard that. 
24 
MS. 
Right. Exactly. So, your Honor, just 
25 
to touch on that very quickly. Not only -- and you will see it 
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in our papers, but we also give specific examples of why these 
2 
are relevant, for example, and not overbroad. For example, two 
3 
of the people we asked for documents and communications with, 
4 
and 
when they were asked in 
5 
their depositions about Ms. Maxwell sexually trafficking 
6 
underaged girls, both of those individuals took the Fifth. If 
7 
there are documents between Ms. Maxwell and 
8 
discussing those issues at any time from 1990 to present, we 
9 
want those documents, your Honor. And while they say that 
10 
day-to-day communications with Jeffrey Epstein wouldn't be 
11 
relevant, they would. If they're communicating on a daily 
12 
basis, that's relevant. 
13 
THE COURT: I understand that point. 
14 
MS. 
So, your Honor, those are the two key 
15 
issues as I understand it, the time period and then the 
16 
overbreadth of the request, that they have been objecting to. 
17 
And, your Honor, we just obviously want discovery in 
18 
this case to move it forward. 
19 
THE COURT: All right. So we've got that. I 
20 
understand that. Is there any other broad category? 
21 
MS. 
No. Those are the two issues, as I 
22 
understand it, the date range which they've limited --
23 
THE COURT: If we resolve those two, have we resolved 
24 
the objections to the document demand? 
25 
MS. 
That's my understanding, that they 
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should be producing at that point. 
2 
THE COURT: All right. 
3 
MR. PAGLIUCA: Well, there are privilege issues that 
4 
remain unresolved. 
5 
THE COURT: No. We're going to deal with the 
6 
privilege issues. 
7 
MR. PAGLIUCA: I just didn't want you to think 
8 
THE COURT: No. I would be pleased to hear anybody if 
9 
they want to be heard on my proposal on the privilege --
10 
MR. PAGLIUCA: No. I think that is fine, your Honor. 
11 
I just didn't want to let that be unsaid. 
12 
The other thing I need to add in this discussion, 
13 
though, your Honor, is this. You know, the plaintiff 
14 
repeatedly now tries to distance herself from her own requests 
15 
for production by comparing, for example, the timeframe at 
16 
issue to the timeframe that Ms. Maxwell believes the plaintiff 
17 
should be responding to. 
18 
THE COURT: OK. All right. We'll take a short 
19 
recess. 
20 
(Recess) 
21 
THE COURT: Please be seated. Thank you very much. 
22 
The motion is granted and denied. Does that help? 
23 
MR. PAGLIUCA: Perfect, your Honor. 
24 
THE COURT: Let's do this. This is an effort to keep 
25 
this going forward. 
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I think a blanket coverage of all documents is too 
2 
broad. I think the period is relevant 
I mean, it could be 
3 
relevant. I don't say it is but it could be relevant. So the 
4 
period is all right, that is, the 2000 and later. I think any 
5 
documents with named individuals, that's fine. 
6 
As to "too broad categories," here's my problem and 
7 
maybe you can help me. Any documents which relate to any 
8 
activity of the defendant with respect to the practice which 
9 
has been alleged. Now, I don't want to try to define what that 
10 
is, and I hope you all today will define that. And then I 
11 
would say any documents that relate to the duties to be 
12 
performed by Maxwell. And it may be that there are other 
13 
definitional categories that would be appropriate but they 
14 
don't occur to me at the moment. 
15 
Now, let me ask the plaintiff, how do you want to 
16 
define the activities? 
17 
MS. 
I'm comfortable defining "activities," 
18 
your Honor. I think you said any documents which relate to the 
19 
activities of defendant with respect to the practice, which we 
20 
would say would be sexual abuse or trafficking of minors. 
21 
THE COURT: OK. 
22 
MS. 
And I think that everybody has an 
23 
understanding of what that is. So if there is emails about 
24 
girls getting massages for those sorts of --
25 
THE COURT: All right. So what do you all think about 
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