giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…to any party’s claim or defense; and documents that are not proportional to the
needs of the case. Such requests would create a heavy burden on Ms. Giuffre that outweighs any
benefit. Such discovery is prohibited by the Federal…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…award
Ms. Maxwell reasonable attorney fees and costs incurred in bringing this Motion.
I. Plaintiff’s interrogatory responses are deficient.
Interrogatory No. 5. Identify each Communication that You or Your Attorneys
have had with any author, reporter, correspondent, columnist, writer…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…made calls and interviewed
particular sources, techniques for the reporters’ investigation, and the backgrounds of the co-
authors and editorial staff).
3
See generally Beth Winegarner, 5 tips for journalists who want to do a better job of cultivating sources…
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…made calls and interviewed
particular sources, techniques for the reporters’ investigation, and the backgrounds of the co-
authors and editorial staff).
3
See generally Beth Winegarner, 5 tips for journalists who want to do a better job of cultivating sources…
giuffre-maxwell
gov.uscourts.nysd.447706.263.0
14 pg
…made calls and interviewed
particular sources, techniques for the reporters’ investigation, and the backgrounds of the co-
authors and editorial staff).
3
See generally Beth Winegarner, 5 tips for journalists who want to do a better job of cultivating sources…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…Irene
Goodman. She has had several successes with new authors. Maybe talk to both
of them as well as Sandra's agency.
Jane Doe 2
confidential and
This e-mail and any attached files are inte…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.40
30 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.235.1
31 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.136.0_2
29 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…history on a number of
occasions, including during her interviews with ABC, with other media outlets, with book
authors and journalists, but chose not to tell her true story, instead telling falsehoods and
fabricated and mistaken events, dates and participants.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.24
4 pg
…prostitute Filed
| News 07/15/21 Page 2 of 4Page 1 of 3
- Home
Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute
Famed attorney slams woman who claims he had underaged sex with her
A…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.30
4 pg
…prostitute Filed
| News 07/15/21 Page 2 of 4Page 1 of 3
- Home
Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute
Famed attorney slams woman who claims he had underaged sex with her
A…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.41
4 pg
…prostitute Filed
| News 07/15/21 Page 2 of 4Page 1 of 3
- Home
Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute
Famed attorney slams woman who claims he had underaged sex with her
A…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.19
4 pg
…Filed
| News 01/05/24 Page 2 of 4Page 1 of 3
- Home
.com
Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute
Famed attorney slams woman who claims he had underage…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.11
8 pg
…5, 7, and 8 were reta ined by Ms. 21 Q. And are you famillar with the fact that
Ezell .) 22 he's a famous author and famous lawyer?
22 23 A.…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…Alan M. Dershowitz, the highly regarded Harvard Law
professor, criminal defense lawyer, and author, is entitled to enjoy the reputation for strict
personal rectitude that he has earned. Unfortunately, however, over the course of the last year
and a half…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…Alan M. Dershowitz, the highly regarded Harvard Law
professor, criminal defense lawyer, and author, is entitled to enjoy the reputation for strict
personal rectitude that he has earned. Unfortunately, however, over the course of the last year
and a half…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…epstein-sex-scandal-book-clears-bill-
clinton/ (discussing a book about “the Jeffrey Epstein sex slavery scandal [that] will be published
with the help of best-selling author James Patterson” and referring to “allegations that
Dershowitz had sex with” Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.6
32 pg
…Alan M. Dershowitz, the highly regarded Harvard Law
professor, criminal defense lawyer, and author, is entitled to enjoy the reputation for strict
personal rectitude that he has earned. Unfortunately, however, over the course of the last year
and a half…