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From: Sigrid McCawley <

From: Sigrid McCawley < Subject: RE: Depo Date: 20 November 2018 at 08:46:13 GMT To: Cc: Stan Pottin "Brittany Henderson > , Meredith Schultz , "Paul Cassell Hell that the issues with and make tasks requiring concentration, like a deposition, very difficult and they should be avoided until you have been which will likely be in mid January Thank you. Sent by Boxer On November 19, 2018 at 4:57:11 PM EST, Sigrid McCawley < wrote: Thanks for the update and I am so sorry to hear about In addition to the travel could you see if the that the and you will not be in a position to do anything that involves work, including sitting through a deposition? (Or maybe someone else on the team has better language to propose). It is fine if it is in — we can Thank you,Sigrid Sigrid McCawleyPartner BOIES SCHILLER FLEXNER L LP Fort Lauderdale, FL. 33301 www.bsfllp.com EFTA00143682 From: [mailto November 19, 2018 4:46 PMTo: Sigrid McCawleyCc: Stan Pottinger; Paul Cas

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Virginia Giuffre Deposition May 2016

Case Document 1090-32 Filed 07/30/20 Page 1 of 89 EXHIBIT Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 2 of 89 GIUFFRE VS. MAXWELL Deposition VIRGINIA GIUFFRE 05/03/2016 _______________________________________________________________________ Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017 Agren Blando Court Reporting & Video, Inc. Page 3 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 1 IN THE UNI

COHEN & GRESSER LLP

GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com October 13, 2020 BY EMAIL. , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 000 Thud Avenue New Yoek. NY 10022 +1 212 957 7600 phone owswoohensresser corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of

Ghislaine Maxwell Deposition Transcript

EXHIBIT 6 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendants. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above