giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…underage girls.” Id. ¶ 21(p). Mr. Cassell describes this as “a
pattern of deception” that was “consistent with a pattern of other persons involved in Epstein’s
international sex trafficking organization.” Id. ¶ 21(p)-(q). Again, these assertions are false…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…to any Documents withheld on the basis of a privilege, provide a log
consistent with Local Rule 26.2 of the Federal Rules of Civil Procedure for the Southern
District of New York.
INSTRUCTIONS
I. Production of documents and items…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.17
11 pg
…14 Q I understand. And I know you did not make
15 this record.
16 So I'm just wanting to know if that's
17 consistent with your recollection, that you guys
18 went to school in the fall…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…delay the
investigation;
• Dershowitz's pattern of avoiding depositions (and helping Epstein avoid
questioning) was consistent with a pattern of other persons who were involved in
Epstein's international sex trafficking organization evading efforts to obtain
information from them;
• Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…underage girls.” Id. ¶ 21(p). Mr. Cassell describes this as “a
pattern of deception” that was “consistent with a pattern of other persons involved in Epstein’s
international sex trafficking organization.” Id. ¶ 21(p)-(q). Again, these assertions are false…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…should
be construed pursuant to British law. Mr. Gow is a British press relations specialist, hired as an
agent consistent with British law, to render assistance to Ms. Maxwell’s counsel in England, for
purposes of potential litigation in England…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
… With respect to any Documents withheld on the basis of a privilege, provide a log
consistent with Local Rule 26.2.
17. Nothing in these interrogatories or requests for production should be construed as
an admission by Ghislaine Maxwell.
INTERROGATORIES…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…investigation;
q. Dershowitz’s pattern of avoiding depositions (and helping Epstein avoid
questioning) was consistent with a pattern of other persons who were involved
in Epstein’s international sex trafficking organization evading efforts to obtain
information fr…
giuffre-maxwell
gov.uscourts.nysd.447706.33.0
19 pg
…disclosure of relevant evidence and thus impedes the quest for truth, ... it must ‘be strictly
confined within the narrowest possible limits consistent with the logic of its principle.” ’ See In
re Shargel, 742 F.2d at 62 . (quoting 8 J…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…investigation;
q. Dershowitz’s pattern of avoiding depositions (and helping Epstein avoid
questioning) was consistent with a pattern of other persons who were involved
in Epstein’s international sex trafficking organization evading efforts to obtain
information fr…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…Lago where she had a summer job as a changing room assistant—indeed
it is one of the few aspects of her story that has remained consistent from the outset.10 Ms.
Giuffre turned seventeen in the summer of 2000…
giuffre-maxwell
gov.uscourts.nysd.447706.155.0
15 pg
…disclosure of relevant evidence and thus impedes the quest for truth, ... it
must ‘be strictly confined within the narrowest possible limits consistent with the
logic of its principle.” ’ See In re Shargel, 742 F.2d at 62 . (quoting 8 J.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…including one named “Virginia.” Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…including one named “Virginia.” Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…including one named "Virginia." Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant's coW1sel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…as the Defendant’s persistence
in avoiding discovery rendered futile any attempt to engage in a meet and confer process.
From the outset of this litigation, the Defendant has consistently sought to avoid any
participation in the discovery process. Indeed…
giuffre-maxwell
1320-10
28 pg
…including one named “Virginia.” Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…¶ 4). Ms. Maxwell consistently has denied
Plaintiff’s allegations, both publicly and privately. Plaintiff cannot therefore complain of “fading
memories” and “stale evidence” during a months’ long stay when she waited years to bring a
claim against Ms. Maxwell regarding…