giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…with
the aid of British counsel and without having seen Defendant's
British law argument, s6bmits an interpretation of British law
directly contradicting Defendant's. 4
• • .~ ·f
This precarious support provides an insu…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…primary or substantial purpose, and the judgment
of Buckley L.J., even taken on its own, does not go to the extent of
contradicting that of Hamilton L.J.: see at p. 856: " I t is not I think
necessary . . ."…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…people, more lurid accounts of tawdry sexual encounters, and more exploitive
circumstances. Giuffre’s stories have proven wildly contradictory and, even by her own words,
have been definitively proven untrue.
4. Giuffre published her false allegations and accusations about Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…To date, those (and many other) records have not been produced.
Moreover, Plaintiff made substantive and completely contradictory changes to her
deposition testimony in errata sheets after the conclusion of her deposition. As well, she was
instructed by counsel not…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…Ms.
Giuffre provided documents responsive to this request, which included her personal bank
records. Defendant takes the contradictory and self-serving position that discovery concerning
the personal finances of Ms. Giuffre is appropriate, yet discovery concerning her own finances is…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…records in footnote 4 of her
brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr.
Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records.
See chart above, Giuffre005431-005438…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…Ms.
Giuffre provided documents responsive to this request, which included her personal bank
-
records. Defendant takes the contradictory and self-serving position that discovery concerning
the personal finances of Ms. Giuffre is appropriate, yet discovery concerning her own finances is…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…records in footnote 4 of her
brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr.
Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records.
See chart above, Giuffre005431-005438…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…records in footnote 4 of her
brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr.
Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records.
See chart above, Giuffre005431-005438…
giuffre-maxwell
gov.uscourts.nysd.447706.193.0
14 pg
…in the upcoming weeks. It is currently, however, limited to rebutting the
claims of “relevance” made by Plaintiff relating to the at issue waiver.
11
Plaintiff’s argument on this issue is actually internally contradictory. By alleging Fed. R. Evid…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…contradictory evidence – that she and her 15
attorneys’ have spent the last 5 years of unsuccessful litigation and media-spin to concoct.
1
Case 1:15-cv-07433-LAP Document 99 Filed 04/15/16 Page 5 of 22…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…records in footnote 4 of her
brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr.
Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records.
See chart above, Giuffre005431-005438…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…records in footnote 4 of her
brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr.
Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records.
See chart above, Giuffre005431-005438…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…with no evidence other
than her self-serving and contradictory statements states: “ Communications with convicted sex
offender Jeffrey Epstein for whom Defendant Maxwell is alleged to have assisted with his sexual
trafficking activities are of the highest relevance in this…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
…records in footnote 4 of her
brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr.
Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records.
See chart above, Giuffre005431-005438…