giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…her brief with snippets of her self-serving testimony. As the Court is aware,
all of this testimony is directly contradicted by the myriad of other witnesses in this case who
have testified at deposition, including Defendant’s own witness…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…is contradicted by Churcher's
statements to the contrary and by the fact that individuals in
those categories are quoted in the articles themselves (both by
16
Case 1:15-cv-07433-RWS Document 503 Filed 11/21/16…
giuffre-maxwell
gov.uscourts.nysd.447706.42.0
7 pg
…certification. More importantly, Plaintiff, in direct contradiction to both the
letter and spirit of Rule 37, did not make any effort to confer with Ms. Maxwell’s counsel
regarding any of the issues presented in her Motions to Compel. This…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…defense case-in-chief. In light of the well settled rules
that a rebuttal expert is “intended solely to contradict or rebut evidence on the same subject
matter identified” in the expert report of another party, there would be no…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…Mr. Cassell in
no way substantiates Ms. Giuffre’s claims. To the contrary, much of the evidence contradicts
Ms. Giuffre’s version of events. In addition, I offer a few final points about matters that
demonstrate clearly that Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…where Virginia
was during the period of 2000 – 2002, public records directly contradict this statement and show that he actually had
an apartment in New York not far from Epstein’s home for a year from 2000 – 2001. McCawley Dec…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…To the contrary, she states that there was
‘no proof’ that he was a ‘pedo’—which directly contradicts such a
suggestion in itself—but only that [Ms. Giuffre] ‘probably met him
when he was hanging out with [Jeffrey Epstein]’.
Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…their
entirety, those witnesses neither support Plaintiff’s single claim for defamation nor her claim for
19
relief in this Motion. In direct contradiction to Plaintiff’s fabricated story, the witnesses actually
testified as follows:
…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…Jane Doe #3), attached and
incorporated herein as Exhibit #2, unequivocally contradicts Alan Dershowitz's protestations of
innocence and his malicious statements made against Edwards and Cassell. However,
Dershowitz has denied the accuracy of Ms. Giuffre's charges against him…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 22 of 27
relief in this Motion. In direct contradiction to Plaintiff’s fabricated story, the witnesses actually
testified as follows:
Johanna Sjoberg worked as a masseuse…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…Mr. Cassell in
no way substantiates Ms. Giuffre’s claims. To the contrary, much of the evidence contradicts
Ms. Giuffre’s version of events. In addition, I offer a few final points about matters that
demonstrate clearly that Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…million in
noneconomic damages from “defamation.” Some of the most relevant and material evidence
concerns pre-1999 medical records and information, which contradict some of Plaintiff’s sworn
testimony about the alleged “sex trafficking.” For example, Plaintiff has testified Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…motion, the Government stood silent about the accuracy
of Reinhart’s affidavit. Much later, after the Court had denied the motion, the Government admitted that
it possessed information contradicting Reinhart’s sworn affidavit. See DE 225-1 at 9-10, ¶…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…with
the aid of British counsel and without having seen Defendant's
British law argument, s6bmits an interpretation of British law
directly contradicting Defendant's. 4
• • .~ ·f
This precarious support provides an insu…
giuffre-maxwell
gov.uscourts.nysd.447706.193.0
14 pg
…in the upcoming weeks. It is currently, however, limited to rebutting the
claims of “relevance” made by Plaintiff relating to the at issue waiver.
11
Plaintiff’s argument on this issue is actually internally contradictory. By alleging Fed. R. Evid…
giuffre-maxwell
gov.uscourts.nysd.447706.903.0
46 pg
…that's
13 not fair, that Alvarez gets to say whatever he wants to say and
14 there's directly contradictory testimony against Alvarez in
15 this Coast Guard hearing, so we're going to say for a variety
16…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…contrary, she states that there was “no proof” that he was a “pedo”—which
directly contradicts such a suggestion in itself—but only that Plaintiff “probably met him when
he was hanging [o]ut with JE [Jeffrey Epstein].” Menninger Decl.…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…contradictory evidence – that she and her 15
attorneys’ have spent the last 5 years of unsuccessful litigation and media-spin to concoct.
1
Case 1:15-cv-07433-LAP Document 99 Filed 04/15/16 Page 5 of 22…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
…Mr. Barton drafted the bulk
of the statement. That's not true at all. If the Court looks
18
19
-- at the papers cited by the response, there is no contradiction
of Mr. Barton's testimony. Mr. Barton said that…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…with no evidence other
than her self-serving and contradictory statements states: “ Communications with convicted sex
offender Jeffrey Epstein for whom Defendant Maxwell is alleged to have assisted with his sexual
trafficking activities are of the highest relevance in this…