giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…no purchase price for the ticket, because the people who
want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono
basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…for the second time, Mr. Dershowitz has demonstrated that he is willing to reveal -
and misrepresent - confidential information in his effort to win his battle in the court of public
opinion. This time, he did so in deliberate and brazen…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…the possibility that soin'e"""a'rhis
friends might have abused his girlfriend and he wanted me to know
that he was willing to cooperate in anyway that he c o u ~ t to
the bottom of this incident…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…maybe what about
7 you?
8 And I was at a point in life, I was super
9 spontaneous and willing to skip school.
10 So she said, Come to my house, come in my
11 car and check it…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…2005, I was contacted by Atty . Gus Fronstin , who
advised he was willing to assist with the investigation. Atty.
Fronstin advised he would try to have his client , Jeffrey Epstein
available to be interviewed. I explained I would be interested…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…No other girl would be there
8
Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 13 of 29
Key Testimony Transcript Citation
willingly just to have sex with Jeffrey.)
Victoria Secret
Ransome Dep…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…defend himself against charges of gross
wrongdoing, Dershowitz followed his own prescription and took his defense to the court of
public opinion where he had an audience willing to ignore both law and facts. The lawyer
victims of Dershowitz's…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…2005, I was contacted by Atty . Gus Fronstin , who
advised he was willing to assist with the investigation. Atty.
Fronstin advised he would try to have his client , Jeffrey Epstein
available to be interviewed. I explained I would be interested…
giuffre-maxwell
gov.uscourts.nysd.447706.110.0
7 pg
…As indicated in her March 14 correspondence, Ms. Maxwell’s counsel is willing to discuss
her ESI discovery protocols, but only if such discussion begins at a rational starting point for a
single-plaintiff, single-defendant case such as this…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…because the people who want the testimony are willing to front the
cost of the litigation either on a contingency or pro-bono basis.
“Evidence tending to show a witness's bias or motive to fabricate testimony or evidence
presented…
giuffre-maxwell
gov.uscourts.nysd.447706.121.0
10 pg
…flat refusal to discuss her ESI protocols (“ [w]e do not believe
we have an obligation to describe for your [sic] our document search methods”), Defendant now
acknowledges in her Response brief some willingness to do so.3 Yet, still…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…Richard Branson having
sexual intercourse with my friend. I will be more then willing to swear under oath and testify in court
over these sex tapes. It will break your heart into a million tiny pieces Maureen when you watch…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…to be opened up. Yes, there might be redactions, and my
5 client is willing to cooperate in all regards to that. We do
6 this all the time. I do other public records and judicial
7 records access. But…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…in Rhinebeck, New York, confirming
the suspicion that she was indeed still in the country and willing to say anything to avoid her
deposition.
Similarly, the Court is familiar with the long (and still on-going) effort of Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…wrote in her responses and objections, that she is willing to produce the Settlement Agreement and
all documents concerning the Settlement Agreement if Defendant gets a waiver of liability from
Jeffrey Epstein for its disclosure. Defendant has a joint defense…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…requesting an opportunity to take his deposition:
Dear Mr. Dershowitz:
Statements attributed to you in the public media express a willingness,
indeed a strong desire, to submit to questioning under oath regarding your alleged
knowledge of Jeffrey Epstein's extensive…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…girl would be there
8
Case 1:15-cv-07433-LAP Document 1334-1
1332-7 Filed 01/08/24 Page 13 of 29
Key Testimony Transcript Citation
willingly just to have sex with Jeffrey.)
Victoria Secret
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…2017, to
fu lly evaluate her credibility. Upon evaluating the witness and upon the witness confirming that
she was willing to sign an affidavit under oath regarding her testimony, Ms. Giuffre ananged to
have a sworn affidavit executed at the…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…at a high-profile wedding in
Rhinebeck, New York, confirming the suspicion that she was indeed still in the country and
willing to say virtually anything in order to avoid her deposition. See Decl. of Sigrid McCawley
at Composite Exhibit…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…etc.
B. Plaintiff Refuses To Provide Her Residence, Domicile And Address
Where She Lived During Alleged “Defamation.”
Plaintiff claims she was willing to, and has already, responded to Interrogatory 1 and
complied with the requirement of Local Rule 26.1…