giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
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.447706.1328.7
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.447706.1256.16
30 pg
…other physicians,” and then states that other records revealed “three additional health care
5
Defendant’s argument that Ms. Giuffre was trying to “hide” these providers is illogical and
wholly contradicted by the fact that Ms. Giuffre disclosed these providers…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…other physicians,” and then states that other records revealed “three additional health care
5
Defendant’s argument that Ms. Giuffre was trying to “hide” these providers is illogical and
wholly contradicted by the fact that Ms. Giuffre disclosed these providers…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…se and does not require proof of special damages.”)
(Emphasis original, quotations and citations omitted).
Defendant’s argument that her statement is not defamatory because it is a “mere denial”
is also flatly contradicted by the prevailing case law. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…other physicians,” and then states that other records revealed “three additional health care
5
Defendant’s argument that Ms. Giuffre was trying to “hide” these providers is illogical and
wholly contradicted by the fact that Ms. Giuffre disclosed these providers…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…other physicians,” and then states that other records revealed “three additional health care
6
Defendant’s argument that Ms. Giuffre was trying to “hide” these providers is illogical and
wholly contradicted by the fact that Ms. Giuffre disclosed these providers…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
…other physicians,” and then states that other records revealed “three additional health care
6
Defendant’s argument that Ms. Giuffre was trying to “hide” these providers is illogical and
wholly contradicted by the fact that Ms. Giuffre disclosed these providers…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…4
C. Plaintiff failed to address issue of her employment records ............................................ 5
D. Newly obtained education records and other witness testimony contradict Plaintiff’s
deposition ...........................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…4
C. Plaintiff failed to address issue of her employment records ............................................ 5
D. Newly obtained education records and other witness testimony contradict Plaintiff’s
deposition ...........................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…who recalled him
saying, “We have her dead to rights.”5 Id. All of this contradicts The government’s
representations to , who specifically
Reassured by the government that modified
the Protective Order so that could comply with the subpoena. Ex…
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.447706.1307.4
28 pg
…and, in fact,
participated in sex acts with minors. She was also on numerous flights with Defendant (in
contradiction to Defendant’s testimony), and she can provide valuable testimony about
Maxwell's role in the recruitment of females.
16. Sarah…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…and, in fact,
participated in sex acts with minors. She was also on numerous flights with Defendant (in
■
contradiction to Defendant’s testimony), and she can provide valuable testimony about
Maxwell's role in the recruitment of females.
16…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…and, in fact,
participated in sex acts with minors. She was also on numerous flights with Defendant (in
■
contradiction to Defendant’s testimony), and she can provide valuable testimony about
Maxwell's role in the recruitment of females.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…and, in fact,
participated in sex acts with minors. She was also on numerous flights with Defendant (in
contradiction to Defendant’s testimony), and she can provide valuable testimony about
Maxwell's role in the recruitment of females.
16. Sarah…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…true purpose behind the instant motion, and wholly contradict the flimflam
he has presented to this Court: “My goal is to bring charges against the client and require her to
speak in court.”37
Indeed, in over 50 statements to…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…Ms.
Giuffre provided documents responsive to this request, which included her personal bank
-
records. Defendant takes the contradictory and self-serving position that discovery concerning
the personal finances of Ms. Giuffre is appropriate, yet discovery concerning her own finances is…
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, ¶…