giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…Radar"), where she has worked since November 2014. Id. ' 4 .
From 1992 through October 2013, she was employed as the New
York-based Chief American Correspondent of The Mail on Sunday, a
publication owned by Associated Newspapers of London, England…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…will continue to ask my questions and
you can continue to make your objection~.
Q. Did you ever participate from the time period of 1992 to 2009, did
you ever participate in a massage with Jeffrey Epstein and another female…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…will continue to ask my questions and
you can continue to make your objections.
Q. Did you ever participate from the time period of 1992 to 2009, did
you ever participate in a massage with Jeffrey Epstein and another female…
giuffre-maxwell
1320-2
10 pg
…will continue to ask my questions and
you can continue to make your objections.
Q. Did you ever participate from the time period of 1992 to 2009, did
you ever participate in a massage with Jeffrey Epstein and another female…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.2
10 pg
…will continue to ask my questions and
you can continue to make your objections.
Q. Did you ever participate from the time period of 1992 to 2009, did
you ever participate in a massage with Jeffrey Epstein and another female…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…4th Cir.1966). .............................. 39
Goldstein v. Cogswell, No. 85 CIV. 9256 (KMW), 1992 WL 131723, at *27 n.32
(S.D.N.Y. June 1, 1992) ................................................................................................ 33
Gross v. New York Times, 623 N.E.2d 1163, 1169 (N.Y…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…unfavorable to the party; or (C) dismiss
the action or enter a default judgment.”). Failure to disclose the email account Defendant actually
used from 1992-2002 warrants an adverse inference instruction.
III. CONCLUSION
For the reasons set forth above, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…States v. Sanusi, 813 F.Supp. 149, 160 (U.S.Dist.Ct.E.D.1992)).
Starting with Ms. Maxwell, Churcher’s articles directly conflict with the allegations in
the Joinder Motion and Plaintiff’s testimony in this case. First, Churcher…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…My job entailed running the homes
5 the age probably of about 40 or 50 was in 5 that he had but much more importantly, most
6 sometime in 1992. 6 of the houses had construction and so whilst
7…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…3 female?
4 A. As best as I can recollect, a woman
5 the age probably of about 40 or 50 was in
6 sometime in 1992.
7 Q. How long did you work for Mr.
8 Epstein?
9 A. …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…3 female?
4 A. As best as I can recollect, a woman
5 the age probably of about 40 or 50 was in
6 sometime in 1992.
7 Q. How long did you work for Mr.
8 Epstein?
9 A. …
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
…3 female?
4 A. As best as I can recollect, a woman
5 the age probably of about 40 or 50 was in
6 sometime in 1992.
7 Q. How long did you work for Mr.
8 Epstein?
9 A. …
giuffre-maxwell
gov.uscourts.nysd.447706.1201.19
106 pg
…My job entailed running the homes
5 the age probably of about 40 or 50 was in 5 that he had but much more importantly, most
6 sometime in 1992. 6 of the houses had construction and so whilst
7…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…LoGrande, 983 F.2d 1047 (2d Cir. 1992).
6
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 10 of 40
Plaintiff’s deficient answer. “Notwithstanding” her objections, Plaintiff “answered” by
referring the defense…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…BSJ), 2003 WL 21146657 (S.D.N.Y. May 19, 2003) ...................................8
Moran v. Flaherty,
No. 92 Civ. 3200, 1992 WL 276913 (S.D.N.Y. Sept. 25, 1992).................................................6
Morien v. Munich Reins. Am., Inc.,
270 F.R.D…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…2008) .......................................................................................15
Lawson v. Stow,
2014 COA 26, 327 P.3d 340 .....................................................................................................21
Liberman v. Gelstein,
80 N.Y.2d 429, 605 N.E.2d 344 (1992) .............................…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…185
A.D.2d 268, 269 (N.Y.A.D.,1992) (Inspector General's investigative files regarding incident in
correctional facility not discoverable by inmate).
5
In her first Motion to Compel (DE 75), Defendant wholly fails to make any…
giuffre-maxwell
gov.uscourts.nysd.447706.42.0
7 pg
…412 (M.D.N.C. 1992) (“[b]road and undirected requests for all
documents which relate in any way to the complaint are regularly stricken as too
ambiguous”).
And, Plaintiff has expanded the dictionary definition of “relate” in her definition…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.8_3
9 pg
…questions at issue were not limited to the time frame in which
the Plaintiff claims she was sexually trafficked and was expanded to the time frame of 1992 to
2009--- seven years before the Plaintiff claims to have met Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.29.1
18 pg
…or
injure the person in her business or profession. Livingston v. Murray, 612 A.2d 443, 447 (Pa.
Super. 1992), alloc. den., 617 A.2d 1275 (Pa. 1992). Defamatory communications tend to lower
a person in the estimation of the…