EFTA00025469.pdf

Type: pdf
Source set: data-set-8

Extracted text

United States District Court
Southern District of New York
Plaintiff,
Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
PLAINTIFF'S REQUEST FOR ADMISSIONS
TO DEFENDANT GHISLAINE MAXWELL
Plaintiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Set
of Interrogatories to Defendant Ghislaine Maxwell, pursuant to Rules 26 and 36 of the Federal
Rules of Civil Procedure and Local Rule
. The responses are due at the offices of Boies,
Schiller & Flexner LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida
33301, within thirty (30) days of service hereof.
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
1.
"Agent" shall mean any agent, employee, officer, director, attorney, independent
contractor or any other person acting, or purporting to act, at the discretion of or on behalf of
another.
2.
"Correspondence" or "communication" shall mean all written or verbal
communications, by any and all methods, including without limitation, letters, memoranda,
and/or electronic mail, by which information, in whatever form, is stored, transmitted or
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EFTA00025469

received; and, includes every manner or means of disclosure, transfer or exchange, and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
3.
"Defendant" shall mean the defendant Ghislaine Maxwell and her employees,
representatives or agents.
4.
"Document" shall mean all written and graphic matter, however produced or
reproduced, and each and every thing from which information can be processed, transcribed,
transmitted, restored, recorded, or memorialized in any way, by any means, regardless of
technology or form. It includes, without limitation, correspondence, memoranda, notes,
notations, diari…

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