giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…All bank statements, credit card statements, money transfer records, or other statements
from any financial institution in Your name, in whole or in part, for the years 2006-2007.
17. Any Docwnents concerning Your residency during the years 2006-2007…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…worked for or been in control of Ms. Maxwell.
Ms. Maxwell and Mr. Epstein have had no financial, professional or employment
relationship in more than a decade, many years before 2015 when the purportedly
defamatory statement was published. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)).
Furthermore…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.0
18 pg
…Maxwell argues that Docket Entry 388—Plaintiff’s Response In Opposition to
Defendant’s Motion for Protective Order Regarding Financial Information—should remain
redacted because the only current redactions are of the names of Non-Parties and other personally
identifying…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…10
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms.
Giuffre objects to this request in that it is overly broad and seeks confidential financial
information. Ms. Giuffre objects to this interrogatory in that…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…time. I watched them
both ejaculate with each other. They were having quite a good time
together.)
Ransome Dep. Tr. at 234-235 (Q. Did you apply for any financial aid for
FIT? A. No. Jeffrey was covering FIT. Q…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…Epstein, correct?
A. There were multiple motives. One of the motives was crassly financial.
They were trying to line their pockets with money. But as I also said, and
I said this over and over again, they profiled me. They…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…encourage
15
Plaintiff to fabricate facts or portions of her stories; and 5) they were not motivated in taking
their actions by potential financial gain . Edwards and Cassell point to both communications
with Plaintiff and their own work product in…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…10
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms.
Giuffre objects to this request in that it is overly broad and seeks confidential financial
information. Ms. Giuffre objects to this interrogatory in that…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…assertions about me, other examples of her lack of credibility are relevant.
53. In the first place, Ms. Giuffre has been demonstrated to have made up
wildly implausible tales for financial gain. In 2011, for example, Ms. Giuffre was interviewed…
giuffre-maxwell
gov.uscourts.nysd.447706.599.0
12 pg
…injuries. In contrast, Taylor does not offer opinions that fall within the competence of an
accountant, such as financial reports and loss/profit ledgers. Instead, he ventures far afield
.
Such is the stuff of an attorney’s closing argument, not…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…at length calling the plaintiff in that case,
5 Mr. McNamee, a liar , calling him a liar 25 ways to Sunday,
6 talking about his financial motives, his potential financial
7 gain, et cetera .
8 Likewise, in the Davis v …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…at 52 (noting that under
the common law, a showing of bias by extrinsic evidence was always permitted).
The discovery sought concerning Ms. Ransome’s financial information, employment, the
nature of her engagement with counsel (including the financial structure of…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…19
10. “Income” includes, without limitation, any revenue, payments, compensation,
remuneration, financial benefit or support or any other financial consideration, or provision of
any other thing of value.
11. “Person” means any natural person, individual, firm, partnership, association,
joint venture…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…In the end, Dershowitz leveraged Epstein’s
financial influence to mete out revenge on Trivers.
https://electronicintifada.net/blogs/rania-khalek/how-alan-dershowitz-bullied-rape-victims-... 8/29/2016
How Alan Dershowitz bullied rape victims to protect a serial…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)).
Furthermore…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…number. She was directed by her counsel not to
14 answer the phone number. There was no privilege asserted.
15 We asked for her financial information in our opening
16 papers. We explained the relevance of that financial
17 information…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…The information at issue . . . does
not involve the type of medical, health-related, family, or personal financial matter to which
courts grant the greatest protection.” United States v. Martoma, No. S1 12 Cr. 973, 2014 WL
164181, at *6 (S…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…for
business, personal, political, and financial gain, as well as to obtain potential blackmail
information.
One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual
relations with was , a close friend of Epstein’s
…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…Additionally, Ms. Giuffre is not withholding any documents based on any “privacy” objection.10
Indeed, she has produced her financial information (including tax returns), employment
information (including drafts of resumes), and medical information (including extensive medical
provider files).
Again, the…