giuffre-maxwell
gov.uscourts.nysd.447706.1084.0
1 pg
…this point without the unredacted copy. I
note that we had attempted to avoid burdening the court by requesting from Ms. Maxwell’s counsel
their proposed redactions so we could do a comparison, however, they never provided a copy of…
giuffre-maxwell
gov.uscourts.nysd.447706.526.0
5 pg
…Handwriting Analysis Lacks Peer Review and Lacks Acceptance by Neutral, Financially
Disinterested Community .................................................................................................. 11
E. One-on-One Handwriting Comparisons Are Unduly Suggestive ...................................... 12
CONCLUSIO…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…to the protective order later became public doesn't mean that
20 the protective order was improvidently granted at the outset.
21 So I don't think that's a fair comparison.
22 While we're talking about improvidently granted…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…of the discovery from Maxwell,”” he has not
beyond conclusory assertions demonstrated a congruence between the
Maxwell action and his own that would warrant such an
indiscriminate approach.
A brief comparison of the Maxwell and Dershowitz actions makes
this clear…
giuffre-maxwell
gov.uscourts.nysd.447706.56.0
14 pg
…2003, 265 F.
Supp. 2d 321, 330 (S.D.N.Y. 2003), but that the facts are so different between that case and the instant case
that the comparison is inapt. Instead, for this case, Egiazaryan v. Zalmayev, 290 F…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…s decision in Spinelli is inapposite. Pl’s Opp’n. at 17. In a
sense, she is correct: the potential discovery in Spinelli pales in comparison to the anticipated
discovery here. Spinelli v. Nat’l Football League, No. 13 CIV…
giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…first issue.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
H39YGIUC
Case 1:15-cv-07433-LAP Document 755 Filed 03/20/17 Page 18 of 75 18
1 There is an interesting comparison, I think,
2 your Honor…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
…media, need to be responsible, you need to be questioning, and
•9 you need to make comparisons between her earlier statements and
--
10
11
her new statements, and you figure it out, because if you
figure it out wrong, you…
giuffre-maxwell
gov.uscourts.nysd.447706.702.0
63 pg
…media, need to be responsible, you need to be questioning, and
9 you need to make comparisons between her earlier statements and
10 her new statements, and you figure it out, because if you
11 figure it out wrong, you…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…Dershowitz is entitled to discover evidence and
present it to the jury that the so-called acts comprising “trafficking” which Giuffre alleges put him
on notice that she did not consent in fact never happened.
Dershowitz can only do this…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…the purpose of limitation.
8. The words “relate,” “relating,” “relates,” or any other derivative thereof, as used
herein includes concerning, referring to, responding to, relating to, pertaining to, connected with,
comprising, memorializing, evidencing, commenting on, regarding, discussing, showing,
describing, reflecting…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…limitation.
8. The words "relate." "relating," ' 1relates," or any other derivative thereof, as used
herein includes concerning, relerring to, responding to, relating to, penaining to, connected
with, comprising, mcrnoriali2ing, evidencing, commenting on, regarding, discussing, showing,
describing, reflecting, analyzi…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…Jean Luc Brunel. Epstein sexually trafficked Jane Doe #3 to Jean Luc
Brunel many times. Brunel was another of Epstein’s closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. Brunel has…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…11 MS. MENNINGER: Objection, foundation.
12 THE WITNESS: Well, beyond companionship,
13 her job, as it related to me, was to find other
14 girls that would perform massages for him and
15 herself.
16 BY MS. McCAWLEY:
17 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
…11 MS. MENNINGER: Objection, foundation.
12 THE WITNESS: Well, beyond companionship,
13 her job, as it related to me, was to find other
14 girls that would perform massages for him and
15 herself.
16 BY MS. McCAWLEY:
17 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…the purpose of limitation.
8. The words "relate," "relating," "relates," or any other derivative thereof, as used
herein includes concerning, referring to, responding to, relating to, pertaining to, connected with,
comprising, memorializing, evidencing, commenting on, regarding, discussing, showing,
describing, reflecting…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…for the purpose of limitation.
8. The \vords "relate," "relating," "relates," or any other derivative thereot~ as used
herein includes concerning, referring to, responding to, relating to, pertaining to, connected with,
comprising, memorializing, evidencing, commenting on, regarding, discussing, showing,
describing…
giuffre-maxwell
gov.uscourts.nysd.447706.55.21
69 pg
…5 before you? 5 Q. Who is she?
6 A. I understand there were several in one 6 A. She was her companion.
7 year. There was Mike Friedman, there is Joe 7 Q. Whose companion?
8 Alessi. There was…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…almost
no investigative effort) is . Epstein sexually trafficked Jane Doe #3 to
many times. was another of Epstein’s closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. has been a
model…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.17
6 pg
…13 but you're revealing some certain information that 13 Q. You referred to her at one point in time
14 Mr. Epstein would not like? 14 as Jeffrey Epstein's companion. But then later on
15 MR. CRITTON: Form. …
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