giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…Response at
14) cannot establish that Maxwell’s defense “virtually rises or falls” with the information sought,
particularly when the degree to which Plaintiff’s story did or did not “change” over time is
evident already from the public record…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Mr. Dershowitz is the defendant in a lawsuit identical to this one. Since at least 2011
plaintiff has been selling her story to the media, telling ever more salacious stories about her
alleged sexual encounters with ever more prominent men…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…Ms. Churcher’s documents and testimony are critical to
establishing the fact that each time Plaintiff has told her story it changes and new salacious
details are added.
Likewise, Churcher admits that her testimony is relevant to Plaintiff’s credibility…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…22 the file. But I think the circumstances have changed now and
23 the situation has changed now such that the Court should be in
24 a position where it should look favorably on our motion.
25 First, your Honor…
giuffre-maxwell
gov.uscourts.nysd.447706.49.0
12 pg
…3
A. The Proposed Opening Paragraph and the Purposes and Limitations
Paragraph are Based on False Premises ................................................................ 3
B. The Proposed Changes to Paragraph 3 are Unnecessary ........................................ 4
C. …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…point in 1992 and the nature of my work 10 of hiring architects, I was also in charge of
11 relationship with him changed over time so 11 all the filings or overseeing that, like a
12 from around 2002…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…living off trust funds that
I have never ever had, party to stories that have changed materially both in
time place and event depending on what paper you read, and the list goes
on.
I have never been a party…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 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.447706.1335.1
465 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.447706.1137.13_5
465 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.447706.1320.12
179 pg
…3 shopping to Worth Avenue, but it was a Sunday and
4 Nieman Marcus was closed, so we went back to, like,
5 a little book store. And I remember she bought, I
6 think, five pairs of reading glasses…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.19
106 pg
…point in 1992 and the nature of my work 10 of hiring architects, I was also in charge of
11 relationship with him changed over time so 11 all the filings or overseeing that, like a
12 from around 2002…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…are 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
…
giuffre-maxwell
1320-12
179 pg
…3 shopping to Worth Avenue, but it was a Sunday and
4 Nieman Marcus was closed, so we went back to, like,
5 a little book store. And I remember she bought, I
6 think, five pairs of reading glasses…
giuffre-maxwell
gov.uscourts.nysd.447706.1308.1
465 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.447706.515.0
12 pg
…Plaintiff’s intentional destruction of evidence cannot be undone. This highly probative
evidence is and can never be recovered to show Plaintiff’s contradictions and
the constant changes to her story, which is the very subject of this defamation action…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.5
12 pg
…intentional destruction of evidence cannot be undone. This highly probative
evidence is “up in the clouds,” and can never be recovered to show Plaintiff’s contradictions and
the constant changes to her story, which is the very subject of this…
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.447706.587.0_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…
Comments