giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…Counsel or Defense Staff are prohibited from further disclosing
or disseminating such identifying information. This Order does
not prohibit Defense Counsel from publicly referencing
individuals who have spoken by name on the public record in this
case.
6. The Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…call you, call you on the telephone?
A. I haven't spoken to Ghislaine in 12 years.
Q. Sorry. I'm talking about when you worked there and you would receive a message that
they were coming into town, would…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.37
11 pg
… Well, after I had spoken with the police
23 report -- the police and there was a police report,
24 I did not realize that was public knowledge,
25 journalists would get a hold of. So at one point
MAGNA& LEGAL…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.27
8 pg
…or
15 girlfriend at the time.
16 BY MR. EDWARDS:
17 Q. And the underaged girls that you had
18 spoken with during your investigation, had they
19 described seeing photographs of naked girls in the
20 house?
21 MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…you, call you on the telephone?
A. I haven't spoken to Ghislaine in 12 years.
3
Q. Sorry. I'm talking about when you worked there and you would receive a message that
they were coming into town, would…
giuffre-maxwell
gov.uscourts.nysd.447706.587.0_2
10 pg
…DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 587 Filed 02/02/17 Page 5 of 10 5
H1j6giua
1 that the defamatory words were not spoken until January 2nd of
2 2015. …
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…before 2015 when the purportedly
defamatory statement was published. Ms. Maxwell testified that she has not spoken to
Mr. Epstein in 2 years.
Maxwell has not vested any control in Mr. Epstein “in regard to key facts and subject
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…now.
anc
We have spoken in great deal about what kind of piece yon would like to present to the NYC Post but we haven't spoken about any contract of any sort
I do need to know as much…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…call you, call you on the telephone?
A. I haven't spoken to Ghislaine in 12 years.
Q. Sorry. I'm talking about when you worked there and you would receive a message that
they were coming into town, would…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…call you, call you on the telephone?
A. I haven't spoken to Ghislaine in 12 years.
Q. Sorry. I'm talking about when you worked there and you would receive a message that
they were coming into town, would…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.13
6 pg
…loop on this
8 to me there is a waiver here. 8 and then we are done.
9 MR. LEWIS: You are presuming what 9 Have you spoken to anyone who is
10 he said to Mr. Edwards. And secondly…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…maintains that his client has assured him that all remaining materials are
in European servers. Counsel has spoken with the French IT professionals of his client who
have disclosed where their servers are based for e-mail, for Cloud materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…evil of this practice hardly merits discussion. The evil is no less when
an attorney can read the statement in the presence of the jury and thereby substitute his spoken
word for the written document.”) (italics in original). Gaines v…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…Subpoena (pending). Similarly, the Court will recall that
Ms. Giuffre was recently forced to resort to the Hague Convention in an effort to depose
Maxwell’s spokesman, Ross Gow, about statements he made on Defendant’s behalf. See DE
306…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…2015, The Sun (online) article: “Prince
Andrew’s pal Ghislaine ‘groped teen girls,’” (Miss Maxwell’s spokesman branded the
accusations against her a “web of lies and deceit” — adding: “None of these allegations are on
oath. “These girls are saying…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…who sounds nice and she's only a phone call away if I need some
Also I don't need Sandra to come this a.m, I've spoken to Jason
support . I'll call her a little later anyways…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…Subpoena (pending). Similarly, the Court will recall that
Ms. Giuffre was recently forced to resort to the Hague Convention in an effort to depose
Maxwell’s spokesman, Ross Gow, about statements he made on Defendant’s behalf. See DE
306…
giuffre-maxwell
gov.uscourts.nysd.447706.229.6
24 pg
…available the week of the 27th. I told him I would call him to coordinate a new date once I had
spoken with you.
I have not heard from anyone representing Dana Burns yet. I was hoping you could tell…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.0
16 pg
…Counsel or Defense Staff are prohibited from further disclosing
or disseminating such identifying information. This Order does
not prohibit Defense Counsel from publicly referencing
individuals who have spoken by name on the public record in this
case.
6. The Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…interest. There
5
Case 1:15-cv-07433-RWS Document 23 Filed 12/17/15 Page 11 of 32
is no qualified privilege under New York law when such statements are spoken with malice,
knowledge of their falsity, or…