giuffre-maxwell
gov.uscourts.nysd.447706.1218.28
3 pg
…younger the better. [The girl] once
stated she once tried to bring a 23-year-
old female and Epstein stated that the
female was too old ." According to the
women who claimed to have visited his
home, they were paid…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…1
A. Plaintiff’s Response is Misleading, At Best .............................................................. 1
B. Plaintiff’s Responses and Log Fail to Reveal Whether Privilege Claimed as to Any
Category of Documents .............................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…privilege – Cross-examination – When court
could go behind affidavit of documents – Third party sought specific disclosure
of documents – Litigation privilege claimed – Material sought gathered in course C
of investigations into incident – Dominant purpose of investigations so that
solicitors could provide…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…The two lawyers alleged that Dershowitz defamed them when he claimed
that they knowingly filed a lawsuit containing falsehoods about him or at least failed to
properly investigate their client’s allegations that Dershowitz had sexual relations with her
when…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…kitten'
who enjoyed her lavish lifestyle, former friends have claimed.
Virginia Roberts is currently in the midst of a lawsuit claiming she was recruited to join Epstein's harem of underage
women in 1999, naming Prince Andrew and attorney Alan…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…disgraced tycoon Robert Maxwell;
Epstein ‘wasn’t beyond killing someone’ to keep his sex addiction alive, the witness
claimed.
Annie Farmer, now 40, helped keep Epstein behind bars last July after giving evidence
about her ordeal as a teenager during…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…friends, including Prince Andrew. It's claimed she had sex with him three
times when she was 17 at Jeffrey Epstein's luxury Caribbean Island home and in New
York and London, all denied by Prince Andrew.
VICTORIA MURPHY, UK…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…Is it the three
23 sentence fragments contained in paragraph 30 against Ghislaine
24 Maxwell are untrue, shown to be untrue, claimed or obvious
25 lies, or does it include some additional or extra false
SOUTHERN DISTRICT REPORTERS, P.C.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…Defendant has
claimed in her deposition that she did not procure girls for sex with Epstein nor notice the
1
Case 1:15-cv-07433-LAP Document 1201-17 Filed 01/27/21 Page 2 of 12
hundreds of…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…And Go
Beyond The Requirements Of Rule 26(a). ....................................................................3
B. The Claimed $102,000 For Future Medical Expenses Is Supported By Proper
Calculations And Supporting Documents. ...............................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…issue . Is it the three
23 sentence fragments contained in paragraph 30 against Ghislaine
24 Maxwell are untrue, shown to be untrue, claimed or obvious
25 lies, or does it include some additional or extra false
SOUTHERN DISTRICT REPORTERS, P …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…p. 89-90; 83-84. While Defendant was working with Epstein during
the time period when these underage girls were visiting Jeffrey’s home, Defendant claimed to be
at the house maybe once in 2005. Id. at p. 84. Yet…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…p. 89-90; 83-84. While Defendant was working with Epstein during
the time period when these underage girls were visiting Jeffrey’s home, Defendant claimed to be
at the house maybe once in 2005. Id. at p. 84. Yet…
giuffre-maxwell
1320-6
10 pg
…p. 89-90; 83-84. While Defendant was working with Epstein during
the time period when these underage girls were visiting Jeffrey’s home, Defendant claimed to be
at the house maybe once in 2005. Id. at p. 84. Yet…
giuffre-maxwell
gov.uscourts.nysd.447706.590.1
4 pg
…friends, including Prince Andrew. It's claimed she had sex with him three
times when she was 17 at Jeffrey Epstein's luxury Caribbean Island home and in New
York and London, all denied by Prince Andrew.
VICTORIA MURPHY, UK…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…Miami
Herald claims to practice. Indeed none of the descriptions of alleged sexual activities or
unsupported claims of sex with nonparties would be relevant to the Herald’s claimed
investigation of a “cross-border sex-trafficking ring,” Mot. to Unseal…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…Defendant has
claimed in her deposition that she did not procure girls for sex with Epstein nor notice the
1
Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 2 of 12
hundreds of…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…or their group, did enter into a scheme with Apollo, and it is not alleged
that the final scheme involved the use of any documents over which copyright or
confidentiality is claimed. However, it is said that at some stage…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…defamation, period.
12 MS. MENNINGER: Your Honor, she has claimed emotional
13 distress from the defamation, yes. We are requesting evidence
14 that would show that she has preexisting emotional conditions.
15 THE COURT: Not from the defamation.
16 MS…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…jury subpoena enforced through an ex parte
proceeding before
. Although the government claimed not to know what was in
file and that had no role in instigating the investigation of
Maxwell, both of these representations to were false.
In turn…