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.447706.1201.17
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.447706.1325.7
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.447706.1199.6_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.447706.1295.8
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.447706.1295.5
12 pg
…The journal thus
was relevant to the CVRA litigation as a purported memorialization of, or contradiction to, the
factional assertions contained in the CVRA Joinder Motion and supporting affidavits.1 (Of
1
Plaintiff now takes the stance that “journal could…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…people, more lurid accounts of tawdry sexual encounters, and more exploitive
circumstances. Giuffre’s stories have proven wildly contradictory and, even by her own words,
have been definitively proven untrue.
4. Giuffre published her false allegations and accusations about Ms…
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.447706.1206.2
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.447706.1201.10_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.447706.1307.4
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.447706.562.2
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…
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