giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…INTRODUCTION ................................................................................................................. 1
FACTUAL BACKGROUND ................................................................................................. 2
I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED
UNANSWERE…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…INTRODUCTION ................................................................................................................. 1
FACTUAL BACKGROUND ................................................................................................. 2
I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED
UNANSWERE…
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.447706.64.0
14 pg
…LAP Document 64 Filed 03/22/16 Page 2 of 14
Table of Contents
Introduction ......................................................................................................................... 1
Certificate of Conferral ..................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…For example, Defendant swore under oath that she hardly was around Jeffrey Epstein for more
than “maybe an hour or two” in the years after 2003 until she claimed she ultimately left his
employment in 2008 or 2009. See Pottinger…
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.447706.1201.17
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.447706.1295.11
19 pg
…Order together with her Motion to Compel.
2
In their letter motion to the Court of January 19 as well as during the hearing of February 2 on this topic,
Plaintiff claimed she had “recently” learned of this “new” witness…
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
gov.uscourts.nysd.447706.303.0
13 pg
…Thus, her
claimed failure to remember all of her doctor’s names does not square with the information
readily available to herself and her attorneys.
A. Plaintiff Has Failed to Comply with Her Obligations to Respond to
Interrogatory Requests as…
giuffre-maxwell
gov.uscourts.nysd.447706.659.0
7 pg
…her various email accounts,
After issuing that Order, Defendant implausibly claimed that
However,
Accounts Defendant used during the relevant period
were excluded from this “search.” Moreover, Defendant has inappropriately refused to disclose
what email accounts she has used during the…
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.447706.216.8
4 pg
…and $400 for a subsequent alleged sex session at Epstein’s NYC
mansion. A third encounter, she claimed, happened on Epstein’s tropical orgy island, where the two had sex with
“approximately eight other girls,” according to the af뒫…
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.447706.1331.30
19 pg
…Order together with her Motion to Compel.
2
In their letter motion to the Court of January 19 as well as during the hearing of February 2 on this topic,
Plaintiff claimed she had “recently” learned of this “new” witness…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…EarthLink account) and it contains relevant information. Yet Plaintiff claims she
4
Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 20 of 42
Because Plaintiff claimed she cannot access her Microsoft account, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…documents.
25. Ms. Giuffre has also claimed to have had sex with such prominent
individuals as former
,
11
Case 1:15-cv-07433-LAP Document 1218-49 Filed 07…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…Epstein’s. It was not until the Joinder Motion
in December 2014 that she claimed she engaged in sexual relations with Mr. Dershowitz,
something he adamantly and publicly denied.
At the heart of this case is the question of whether…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.2
56 pg
…again, read that
14 claimed that she met or that she said she met
15 I don't know if I was the one
16 who made the introduction or not.
17 Q. Do you know a female by the…