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.447706.99.0
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.447706.751.9
3 pg
…York.
The second denial comes after two Sunday papers in Britain published interviews with the woman in which she
claimed that she was forced by American financier Jeffrey Epstein to have sex with Prince Andrew at least three
times between…
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.447706.363.11
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.447706.408.0
13 pg
…5), while simultaneously submitting 14,825 pages of relevant materials under seal to the
Court. The Government claimed that these pages were “privileged” for various reasons,
attaching an abbreviated privilege log.
8. While these discovery issues were pending, in the…
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…
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