giuffre-maxwell
gov.uscourts.nysd.447706.75.0
31 pg
…s lost wage claims puts her employment history, educational history and
earning capacity at issue. ...................................................................................................... 19
3. Plaintiff’s compensation for selling information ........................................................... 20
…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…Rodriguez at 24-25. Therefore,
her work for Epstein and related entities is relevant. Discovery concerning Maxwell’s
compensation, formal or informal, for the work she performed for convicted sex offender Jeffrey
Epstein is highly relevant for the entire Relevant…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…000.
a. Computation Analysis
i. Ms. Giuffre’s estimated compensation capacity is $180,000 annually.
Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the
beginning of 2015 when the alleged injury occurred. Her expected…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…massage.
Whether Defendant could recall seeing and Epstein together.
Whether Defendant was aware of any interstate or international transportation of women,
aged 18 to 28, for purposes of having sex with Epstein where they would receive
compensation. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…seeing and Epstein together. .
! Whether Defendant was aware of any interstate or international transportation of women,
aged 18 to 28, for purposes of having sex with Epstein where they would receive
compensation. Id. at 278-79.
! Whether Defendant could recall…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…nominal damages,’” and confirming an award of punitive
damages) (internal citation omitted). “In assessing the amount of damages to award for
defamation, a jury is not limited to compensating the plaintiff for ‘economic’ losses, such as
demonstrable lost profits. Rather…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…Defendant could recall se e i n g - and Epstein together.
• Whether Defendant was aware of any interstate or international transpo1tation of women,
aged 18 to 28, for purposes of having sex with Epstein where they would receive
compensation. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…164.
• Whether Defendant was aware of any interstate or international transportation of
women, aged 18 to 28, for purposes of having sex with Epstein where they would
receive compensation. Id. at 278-79.
• Whether Defendant could recall interacting with anyone…
giuffre-maxwell
gov.uscourts.nysd.447706.881.0
8 pg
… What was the result?
Has anyone been falsely accused of something?
PERSONAL INJURY SUITS
Who has negative feelings about lawsuits seeking compensation for damages or injury?
Who believes there are too many lawsuits?
Who is naturally…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…each child
was made to engage in a sex act in order to recsive the promised compensation.
Case 1:17-cv-00616 Document 1 Filed O1l26lt7 Page 8 of 21
Several were also made to engage in sex with…
giuffre-maxwell
1320-10
28 pg
…seeing and Epstein together. .
! Whether Defendant was aware of any interstate or international transportation of women,
aged 18 to 28, for purposes of having sex with Epstein where they would receive
compensation. Id. at 278-79.
! Whether Defendant could recall…
giuffre-maxwell
gov.uscourts.nysd.447706.76.2
21 pg
…000.
a. Computation Analysis
i. Ms. Giuffre’s estimated compensation capacity is $180,000 annually.
Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the
beginning of 2015 when the alleged injury occurred. Her expected…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…transcripts-release-1c7caf33ced3db9ea7f4a81e5e114fb8
130 https://www.dailymail.co.uk/news/article-8911449/Two-Jeffrey-Epstein-accusers-drop-cases-suggesting-paid-compensation-fund.html
131 https://www.thedailybeast.com/ghislaine-maxwell-deposition-discussing-her-sex-life-and-jeffrey-epstein-ordered-released…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…filed her
lawsuit against Defendant here in the Southern District of New York. (DE 1.) Ms. Giuffre is
seeking at least $50 million in compensatory and punitive damages from Ms. Maxwell. Just a
few months after the suit was filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…filed her
lawsuit against Defendant here in the Southern District of New York. (DE 1.) Ms. Giuffre is
seeking at least $50 million in compensatory and punitive damages from Ms. Maxwell. Just a
few months after the suit was filed…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…with an express finding that the [defamation] was intended to injure plaintiff and did in fact
cause injury, authorizes the jury to consider and assess punitive damages without any finding of
a specific amount of compensatory damages." Lawnwood Med. Ctr.…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…case to deter Maxwell and
others from wantonly and maliciously using a campaign of lies to discredit Giuffre and other
victims of sex trafficking.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Giuffre respectfully requests judgment against Defendant
Maxwell, awarding compensatory, consequential, exemplary…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…No. 3.
been caused by the statement. In deciding the amount of compensatory damages, you will take into consideration the
evidence offered by both sides regarding plaintiff's reputation at the time defendant's statement was published.”).
21
Menninger Decl…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…case to deter Maxwell and
others from wantonly and maliciously using a campaign of lies to discredit Giuffre and other
victims of sex trafficking.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Giuffre respectfully requests judgment against Defendant
Maxwell, awarding compensatory, consequential, exemplary…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…case to deter Maxwell and
others from wantonly and maliciously using a campaign of lies to discredit Giuffre and other
victims of sex trafficking.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Giuffre respectfully requests judgment against Defendant
Maxwell, awarding compensatory, consequential, exemplary…
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