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.447706.1328.20
14 pg
…Sheriff’s Office for the identities and other identifying information
of all juveniles as well as Plaintiff’s parents.
x January 1998 – In contradiction to Plaintiff’s sworn testimony that she ran away
from home at the age of 13…
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.447706.1256.16
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.447706.230.0
19 pg
…NON-PRIVILEGED QUESTIONS IN HER FIRST DEPOSITION ......... 10
III. PLAINTIFF MADE MATERIAL CHANGES TO HER DEPOSITION THAT
COMPLETELY CONTRADICT HER SWORN TESTIMONY ...................................... 13
CERTIFICATE OF SERVICE ........................................................................................…
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.447706.1198.12_3
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.447706.1199.6_1
14 pg
…a statement.”). Unfortunately, counsel’s characterization of the police reports is directly
contradicted by the police reports themselves, which found that Plaintiff “lacked credibility” and
there was a “no reasonable probability of success at trial.” Compare id. and Menninger Decl.…
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.447706.994.0
14 pg
…and J. Doe’s repeated assertion that these documents are entitled to only a
“slight presumption of access” is directly contradicted by the Second Circuit’s conclusion that “the
presumption of access to “materials submitted in connection with, and relevant…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…Despite these obstacles, non-party Ransome complied by producing
over 235 pages of highly relevant documents which include photographic evidence and e-mail
communications during the mid-2000s that directly contradict Defendant’s deposition testimony.
For example, Defendant swore under…
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.447706.1154.0_5
3 pg
…in balancing privacy and other interests.” To find now that the
failure to seek excerpts or object by a Non-Party forfeited their ability to have the Court
perform its review function would contradict the plain terms of the Protocol…
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.447706.1331.16
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.447706.515.0
12 pg
…the CVRA litigation, i.e.,
The journal thus
was relevant to the CVRA litigation as a purported memorialization of, or contradiction to, the
factional assertions contained in .1 (Of
1
…
giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
… She directly contradicts a number of the
17 defendant's statements under oath that relate to what we
18 contend was the sexual trafficking organization and also one of
19 the witnesses that they intend to propose at trial.
20…
Comments