giuffre-maxwell
gov.uscourts.nysd.447706.749.0
9 pg
…EVID. 405(B) REQUIRES ADMISSION OF ALL SPECIFIC INCIDENTS OF
PLAINTIFF LYING OR ENGAGING IN DECEITFUL OR FRAUDULENT CONDUCT 1
A. All allegations or comments made by Plaintiff are “connected to” the alleged defamatory
statement.........................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1058.1
3 pg
…made relevant here all of the discovery from Maxwell. Without limitation, and by
example only, Plaintiff has alleged, falsely, that circumstances surrounding Jeffrey Epstein made
it obvious to Dershowitz that she was being “trafficked” to him. As we understand it…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…permissible to the limited issue of punitive damages, Plaintiff changes tactics claiming the
discovery also relates to 1) Ms. Maxwell’s alleged potential sale of assets in this country and 2)
Ms. Maxwell’s alleged financial dependence on Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…category, victim
4 information, and then we have listed, I believe, a
5 total of 17 individuals that the Palm Beach Police
6 Department incident report lists as alleged victims
7 in this case, correct?
8 A. Correct.
9 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…production
confidential, I have several.
First, Florida statutes protect "[a]ny information in a videotaped statement of a minor
who is alleged to be or who is a victim of sexual battery ... which reveals that minor' s identity."
Fla. Stat…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.7
18 pg
…category, victim
4 information, and then we have listed, I believe, a
5 total of 17 individuals that the Palm Beach Police
6 Department incident report lists as alleged victims
7 in this case, correct?
8 A. Correct.
9 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…As the
Court will recall, in court pleadings filed December 30, 2014, Ms. Giuffre initially publicly
alleged Defendant had sexually abused her. On September 21, 2015, Ms. Giuffre filed her
lawsuit against Defendant here in the Southern District of New…
giuffre-maxwell
gov.uscourts.nysd.447706.1083.0
3 pg
…produced or answered discovery based on the understanding that
such discovery would be subject to the Protective Order, (b) persons who are identified as
allegedly having engaged in sex acts with Plaintiff or other alleged victims, or facilitated such
acts…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…As the
Court will recall, in court pleadings filed December 30, 2014, Ms. Giuffre initially publicly
alleged Defendant had sexually abused her. On September 21, 2015, Ms. Giuffre filed her
lawsuit against Defendant here in the Southern District of New…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…Sarah Kellen,
Lesley Groff, and Natalya Malyshw, alleges upon personal knowledge with
respect to her own acts and status and upon information and belief as to all other
matters, as follows:
1. This cause of action arises under federal statutes…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…of sexual acts involving Plaintiff and non-parties to this litigation, some famous,
some not; the identities of non-parties who either allegedly engaged in sexual acts with Plaintiff
or who allegedly facilitated such acts.” Giuffre v. Maxwell, 325 F…
giuffre-maxwell
gov.uscourts.nysd.447706.140.3
4 pg
…arising out of the World Trade Center (WTC) bombing, in which the plaintiffs alleged injuries resulting from the
negligent failure of the defendant Port Authority of New York and New Jersey to implement security measures, the defendant
was not required…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…on attorney-client privilege, either state law
where the disclosure was made or federal law. The alleged disclosures in this case were made in
Florida, and under Florida law did not constitute any waiver of attorney-client privilege. Indeed,
Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…WL 12925759, at *1 (E.D. Ky. Sept. 24,
2012) (“[D]efendant cites no authority—nor has the Court independently located any—which
supports the sealing of documents based upon alleged evidentiary problems.”); Krause v. Rhodes,
535 F. Supp. 338…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…and social security
numbers”; (2) “the names of alleged minor victims of sexual abuse”; and (3) “deposition responses
concerning intimate matters where the questions were likely only permitted—and the responses
only compelled—because of a strong expectation of continued…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…their client’s claims – were false. The Complaint by Edwards and Cassell alleged that
“[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well-
founded pleading, Dershowitz initiated a massive public media assault on…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…again, willfully disclosed confidential, alleged settlement negotiations
in a brazen and self-serving attempt to discredit one of his accusers during the continuation of his
deposition in this case:
Q. And the lawyers generically, he's talking about the lawyers…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…Epstein” and others).
She also possesses emails with witness , to whom she allegedly had
complained about Jeffrey Epstein, but only produced selected emails within the same email
chain.
Because a thorough search of email communications was not performed within the
…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…their client’s claims – were false. The Complaint by Edwards and Cassell alleged that
“[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well-
founded pleading, Dershowitz initiated a massive public media assault on…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…Jeffrey Epstein” and others).
She also possesses emails with witness Pumla Grizell, to whom she allegedly had
complained about Jeffrey Epstein, but only produced selected emails within the same email
chain.
Because a thorough search of email communications was not…
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