giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…being a
lawyer who is seeking to justify his own conduct in the face of compelling evidence that his
client is a thoroughgoing liar. That was, after all, the gravamen of Mr. Cassell’s defamation case
against me: the assertion…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
… She had told me about that, I
9 believe, after I had max- -- after I had already met
10 her.
11 Q Okay. And tell me everything that you
12 remember about what Ms. Roberts said about being
13 intimate…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
… She had told me about that, I
9 believe, after I had max- -- after I had already met
10 her.
11 Q Okay. And tell me everything that you
12 remember about what Ms. Roberts said about being
13 intimate…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…7 in this case, correct?
8 A. Correct.
9 Q. And are you aware as to whether or not
10 that list was supplemented after July 25th, 2006, in
11 the investigative incident report?
12 A. I'm not sure…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…at the wedding of former US President Bill
Clinton’s daughter Chelsea in July 2010, a year after Epstein was released from jail as
a convicted sex offender;
She loved to take nude photographs of girls and allegedly took many…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.17
11 pg
…Filed 01/04/24 Page 4 of 11
Video Deposition of Tony Figueroa (Volume 1) 23
1 BY MS. MENNINGER:
2 Q And where did you go after Royal Palm
3 Beach?
4 A I believe it was South Area…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…Ghislaine Maxwell, March 2, 20161
Less than six months after representing to this Court that this case involves “highly
personal and sensitive information” warranting a broad protective order, Defendant now wants to
publicize police reports concerning Ms. Giuffre - most of…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…called Epstein’s
, and told her not to come over to their house that day until the
afternoon.9
And though Defendant refused to admit that she flew with Ms. Giuffre,10 Epstein’s
.11
6
See Maxwell’s April…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…
15 A. I do not.
16 Q. Where did you go next, after the New York
17 visit?
18 A. I went to the Virgin Islands.
19 Q. And who told you that you would be going
20 to the…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
… She had told me about that, I
9 believe, after I had max- -- after I had already met
10 her.
11 Q Okay. And tell me everything that you
12 remember about what Ms. Roberts said about being
13 intimate…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
… Discovery of Financial Information is Relevant to Show Defendant’s
Transfer of Assets Out of the Jurisdiction after the Commencement of
Litigation and thus Her Consciousness of Guilt.
The requested financial information is relevant to issues relating to Defendant’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…26 times. After Epstein's arrest in July 2006,
federal tax records show Epstein donated $25,000 to the Clinton Foundation that year.
Epstein was also a regular visitor to Donald Trump's Mar-a-Lago, and the two were…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…being a
lawyer who is seeking to justify his own conduct in the face of compelling evidence that his
client is a thoroughgoing liar. That was, after all, the gravamen of Mr. Cassell’s defamation case
against me: the assertion…
giuffre-maxwell
gov.uscourts.nysd.447706.21.0
4 pg
…and January
13, 2015 Daily Mail, “Bill Clinton pictured with Jeffrey Epstein’s social fixer at Chelsea’s
wedding AFTER severing links with disgraced pedophile.”
11. Attached hereto as Exhibit 9, is a true and correct copy of Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…For the reasons set forth below, this Court should grant Ms.
Giuffre’s Motion to Compel in its entirety.
I. PRELIMINARY STATEMENT1
After sitting on Ms. Giuffre’s First Request for Production for four months, Defendant
only produced two documents…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…Now, almost four (4) months later, and even after this Court denied defendant’s attempts
to stay discovery and directed a response, defendant is still refusing to produce highly relevant
documents. Defendant is attempting to grant herself a de facto…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…show Bill Clinton aboard the plane with Kevin Spacey and Charles Tucker is not great': Charlie
Sheen 'to sell 2 of his 3
…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Court will recall, Ms. Giuffre made efforts to set Defendant’s deposition starting in
February 2016, yet Defendant did not sit for her deposition until after being ordered by the Court on April
22, 2016. During that deposition, Defendant refused…
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…most
6 of the houses had construction and so whilst
7 in 1992 there was no construction project,
8 there was construction projects that began
9 after that time and I was in charge not only
10 of hiring architects…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…Court will recall, Ms. Giuffre made efforts to set Defendant’s deposition starting in
February 2016, yet Defendant did not sit for her deposition until after being ordered by the Court on April
22, 2016. During that deposition, Defendant refused…
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