giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…attaches to all judicial documents.
Maxwell’s repeated assertion that these documents are entitled to “a minimal presumption of
access” is directly contradicted by the Second Circuit’s conclusion that “the presumption of access
to “materials submitted in connection with…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…his guilty plea and associated non-prosecution agreement. Dershowitz
uniquely would have been aware of the compelling evidence against Epstein — and no doubt
would have taken a keen interest in the evidence that would have connected him with Epstein's…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…Specifically, each
notification should identify (1) the Doe identifier number; (2) how the Doe is connected to the case
(e.g. victim, alleged perpetrator, witness, someone named in flight logs, or an individual whose
association has been publicly reported, etc.)…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…Enters, Inc., 209 F.3d 163 (2d Cir. 2000) .............................. 17
Club Valencia Homeowners Ass’n, Inc. v. Valencia Associates, 712 P.2d 1024 (Colo.
App. 1985) ..................................................................................................................... 13
Cohen v. Stevanovich, 772 F.Supp.2d 416,…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…Giuffre charged defendant
Ghislaine Maxwell, an Epstein associate, with defaming her by publicly
calling her statements implicating Maxwell in Epstein’s trafficking “obvious
6
Case:
Case:24-182,
24-182,01/08/2026,
07/2…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…a victim of
sexual trafficking by financier Jeffrey Epstein. Giuffre charged defendant
Ghislaine Maxwell, an Epstein associate, with defaming her by publicly
calling her statements implicating Maxwell in Epstein’s trafficking “obvious
6
Case: 24-182, 07/23/2025…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…clear, the only massage I recall receiving at the Epstein home was
conducted by a professional masseuse—a woman in her in her 30s or 40s. This occurred well
outside the timeframe when Ms. Giuffre was associated with Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…proof” that Professor
Dershowitz had ever done anything wrong; and that Ms. Giuffre concocted her malicious
allegations against Professor Dershowitz, and used his name in her statements and book
proposal, not because he abused her—he didn’t—but because…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…people that you knew to have been
associated with the house in those message pads?
THE WITNESS: Yes.
Q. And so what was the evidentiary value to you of the message pads collected
from Jeffrey Epstein's home in the…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…clear, the only massage I recall receiving at the Epstein home was
conducted by a professional masseuse—a woman in her in her 30s or 40s. This occurred well
outside the timeframe when Ms. Giuffre was associated with Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…Defendant’s London-based press agent, who
shares Defendant’s attorney, Philip Barden, and who was connected with Defendant’s statements
about Ms. Giuffre in both 2011 and 2015. Defendant admitted that she used Mr. Gow in 2011 in
relation…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…2015, Maxwell again issued a statement,
responding to the allegations made in connection with Giuffre's
Joinder Motion. Maxwell stated that Giuffre's allegations
"against Ghislaine Maxwell are untrue" and that Giuffre's
"claims are obvious lies" (the "January 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…people that you knew to have been
associated with the house in those message pads?
THE WITNESS: Yes.
Q. And so what was the evidentiary value to you of the message pads collected
from Jeffrey Epstein's home in the…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…like to start with
19 Kliman, if I could.
20 Dr. Kliman is a summary witness who has no firsthand
21 knowledge about the facts associated with this case. He's been
22 proffered as an expert in psychiatry. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…Central Park Five” case in
connection with the civil lawsuit by the individuals who were wrongfully convicted in that case.
The City argued that the privilege did not apply because the filmmakers first conducted
interviews with one of the plaintiffs…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…like to start with
19 Kliman, if I could.
20 Dr. Kliman is a summary witness who has no firsthand
21 knowledge about the facts associated with this case. He's been
22 proffered as an expert in psychiatry. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.6
32 pg
…proof” that Professor
Dershowitz had ever done anything wrong; and that Ms. Giuffre concocted her malicious
allegations against Professor Dershowitz, and used his name in her statements and book
proposal, not because he abused her—he didn’t—but because…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…2015.
2
or disprove the claim in this case.6 Defendant cannot hold the position that documents relevant
to the claim in this case arise solely from a self-serving fraction of the requested date range if
collected from her…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…this litigation or that her dream journal had anything related to this
litigation within it.
Ms. Giuffre performed a diligent search for all documents even potentially connected to
-
this case. She produced a 141 page manuscript from her electronic files…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…Defendant. Accordingly, given Defendant’s
extraordinary economic resources, her high-level social connections, and her elaborate
residential email/internet configuration she had during that time, it is extraordinarily unlikely that
she would not employ an almost ubiquitous communication tool, nor…
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