giuffre-maxwell
gov.uscourts.nysd.447706.1202.9
5 pg
…e*
101) assault*
102) juvenile*
103) seal*
104) joint* w/3 defen*
105) jda
106) roadhouse*
108) illegal*
109) immune*
110) prosecut*
111) law* w/3 enforc*
112) jane* w/3 *doe*
117) model*
118) actress*
123) vanity* w/ 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…allegedly sexually assaulted 16-year-old Annie
Farmer
It reportedly happened at paedophile Epstein's 7,500-acre New Mexico
ranch
A lawyer for more than 20 of Epstein's victims has made the allegation
By Mark Hookham For The…
giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…Doc.892, at 4-10. It found that “the
parties and multiple deponents have reasonably relied on the Protective Order in giving
testimony and producing documents including evidence of assault, medical records, and
emails,” and “[t]hird-party witnesses have…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…in filing a legal document on
their client's behalf which contained those allegations. As a result, the undisputed record
evidence establishes that Dershowitz waged a baseless international media assault on the
honesty, integrity, and professionalism of Edwards and Cassell…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Joshua Bunner
Address unknown at this time
Joshua Bunner has knowledge concerning Plaintiff’s credibility, including false
claims of sexual assault.
13. Carolyn Casey
Address unknown at this time
Telephone number unknown at this time
3
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…i
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 3 of 50
4. Sexual Assault Records are a Medical Event and Are Barred by This
Court’s Order ............................................................................................23
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…RFP No. 1 seeks documents Mr. Pagliuca allegedly ‘reviewed and/or relied upon’ in
allegedly making statements stating that Plaintiff previously made false accusations of sexual
assault.” (Br. at 5). (Emphasis original).
How Defendant purports to distinguish between the actual…
giuffre-maxwell
1320-40
19 pg
…Joshua Bunner
Address unknown at this time
Joshua Bunner has knowledge concerning Plaintiff’s credibility, including false
claims of sexual assault.
13. Carolyn Casey
Address unknown at this time
Telephone number unknown at this time
3
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…RFP No. 1 seeks documents Mr. Pagliuca allegedly ‘reviewed and/or relied upon’ in
allegedly making statements stating that Plaintiff previously made false accusations of sexual
assault.” (Br. at 5). (Emphasis original).
How Defendant purports to distinguish between the actual…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…to, or with whom You
engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999,
including the names of the individuals involved, the dates of any such illegal or inappropriate
sexual contact, conduct or assault…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…the discovery sought from the Maxwell case is believed
to be particularly relevant to Dershowitz’s defense of the sexual assault claims which Giuffre has
brought against him on the theory that he was “on notice” that she was being…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Exhibit. 5, Complaint in Edwards and Cassell
v. Dershowitz. The complaint alleged that Dershowitz had engaged in a “massive public media
assault on the reputation and character” of Cassell and Edwards. Id. at 4. Ms. Giuffre was not a
party…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Rather, on the way to the detox unit at the hospital, Plaintiff
claimed she had been forcibly sexually assaulted by her friends. Plaintiff’s claim
of forced sexual assault was expressly refuted by the witnesses, who also verified
Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…to, or with whom You
engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999,
including the names of the individuals involved, the dates of any such illegal or inappropriate
sexual contact, conduct or assault…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…the plaintiff in this lawsuit, and
republished all over the world. Professor Dershowitz has done everything in his power to
combat this assault on his reputation, from proclaiming his innocence in public, to marshalling
every bit of information within his…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…motion. Doc.892. Among
other things, the Court found that “the parties and multiple deponents have reasonably relied on
the Protective Order in giving testimony and producing documents including evidence of assault,
medical records, and emails.” Id. at 6. Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…the March 21,
2016, meet and confer discussion when Mr. Pagliuca stated that (1) Plaintiff made false
allegations concerning her sexual assault; (2) she made them in roughly the same time frame that
Plaintiff was abused by Jeffrey Epstein; (3)…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…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 the reputation and
character of Bradley J. Edwards and Paul G…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…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 the reputation and
character of Bradley J. Edwards and Paul G…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…public interest privilege, and any other applicable privilege. Ms. Giuffre objects to the extent
this seeks information regarding sexual assaults that occurred prior to her involvement with the
Defendant and Jeffrey Epstein. Ms. Giuffre responds as follows: Ms. Giuffre met…
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