giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…plaintiff's credibility is central to the Shield Law.
9 They also focus heavily on the idea that the story
10 changed over time from what was published in 2011 and what was
11 published in 2015 and after and…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.24
2 pg
…not new and have been fully responded to and shown to
be untrue
Each time the story Is re told it changes with new salacious details about public
figures and world leaders and now it is alleged by Ms Robert…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…brought to light., it is in no favour or intention for me to put myself and story out there for nothing.
might
contact Orad Edwards lo see ifhe would still like to do a piece with E…
giuffre-maxwell
gov.uscourts.nysd.447706.587.0_2
10 pg
…case where my client
2 is alleged to have made a defamatory remark that is prefaced by
3 the words "Every time this story is told, it changes." So that
4 is why this becomes important in the context of…
giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…fresh denial yesterday, saying: “The allegations made… against Ghislaine Maxwell are
untrue.
"The original allegations are not new and have been fully responded to and shown to be untrue.
“Each time the story is retold it changes, with new…
giuffre-maxwell
gov.uscourts.nysd.447706.748.5
2 pg
…not new and have
been fully responded to and shown to be untrue.
Each time the story is re told it changes with new salacious details about public figures and
world leaders and now it is alleged by Ms Roberts…
giuffre-maxwell
gov.uscourts.nysd.447706.751.1
2 pg
…not new and have
been fully responded to and shown to be untrue.
Each time the story is re told it changes with new salacious details about public figures and
world leaders and now it is alleged by Ms Roberts…
giuffre-maxwell
gov.uscourts.nysd.447706.542.6
2 pg
…not new and have
been fully responded to and shown to be untrue.
Each time the story is re told it changes with new salacious details about public figures and
world leaders and now it is alleged by Ms Roberts…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…the claimants prepared, or caused to be prepared,
documentation for a warranty scheme which they sought to sell to retailers to replace
insurance based schemes which had been rendered commercially unattractive by a
change in the tax regime. A Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…to the
press, as if it was a diary, when it was just a story that she is writing of fiction,
fictional story for money.
Q. How did you arrive at the words that were put in that statement?
MR…
giuffre-maxwell
gov.uscourts.nysd.447706.25.0
13 pg
…the Statement referencing “obvious lies” immediately follows the
sentence: “Each time the story is retold it changes, with new salacious details about public
figures.” Even Judge Marra noted in his April 7 Order that Plaintiff’s latest story involves
3
…
giuffre-maxwell
gov.uscourts.nysd.447706.239.1
11 pg
…Epstein in Does.
Neither June 17 nor June 28 is an available date.
Regards,
Greg Poe
Please note: As of June 1,2016, my email address has changed to
[email protected]. Please update your address book accordingly.
Gregory L…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…interests.
I. Mr. Dershowitz’s Proposed Disclosure of Confidential Maxwell Materials
Nothing material has changed since Mr. Dershowitz’s last application to receive materials
protected by the Protective Order or otherwise filed under seal in the instant matter. The Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1038.0
2 pg
…Court’s proposal to review documents by Non-Party in
the order that the Non-Parties are listed on the Non-Party list. Defendant has proposed a number
of changes to the Court’s proposed revisions to the Protocol, however…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.36
4 pg
…Mr.
8 Epstein?
9 A. I started working for him at some
10 point in 1992 and the nature of my work
11 relationship with him changed over time so
12 from around 2002, 2003, the work lessened
13 considerably…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…mental impressions, and work product the keystone
5
Case 1:15-cv-07433-LAP Document 1332-3 Filed 01/08/24 Page 10 of 21
of her argument, things changed. Ms. Giuffre is entitled to present those changed circumstances…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…credentials, and
qualifications of the Special Agent, and the contents of his report are not changed in any way as
a result of redactions designed to protect confidentiality. Instead, the official Federal Bureau of
Investigation seal and corresponding attestation that…
giuffre-maxwell
gov.uscourts.nysd.447706.1040.0
1 pg
…DE 1039, at 1; those submissions regarded
additional changes to the protocol for notification of non-parties of the potential unsealing of
certain filed documents. Non-party John Doe concurs with the modifications proposed by the
defendant, for the reasons…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…2020 (Doc. 1034) at 3, attached please
find Ms. Maxwell’s proposed changes to the Court’s proposed revisions to the Protocol,
Notice to Non-Parties, the Non-Party Request for Excerpts, and the Non-Party Form
Objection. Counsel conferred…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.4
6 pg
…Attached is the proposed calendar with the caveat that dates
may shift if witnesses make change requests but we are doing our best to group locations together where possible.
Again - this is not final as I noted I believe you…
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