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.447706.515.0
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.447706.1295.5
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.447706.1328.20
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.447706.1201.10_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.447706.1327.26
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.447706.1137.12_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.447706.230.0
19 pg
…her own testimony. For these reasons,
Plaintiff’s depositions must be reopened to examine her on newly discovered evidence and her
contradictory statements.
ARGUMENT
“A person who has previously been deposed in a matter may be deposed again, but only…
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
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.447706.1332.10
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.447706.702.0
63 pg
…Barton drafted the bulk
17 of the statement. That's not true at all. If the Court looks
18 at the papers cited by the response, there is no contradiction
19 of Mr. Barton's testimony. Mr. Barton said that…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…Id.
B. Plaintiff’s Counsel Has Repeatedly and Publicly Filed In This Case
Numerous Publicly Available Police Reports With Redacted Juvenile
Information
In complete contradiction to her legal position in this Motion, Plaintiff and her counsel
have repeatedly filed in…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…of injuring the plaintiff. One who makes a
public attack upon another subjects his own motives to discussion.
It is a contradiction in terms to say that the one attacked is
privileged only to speak the truth, and not to…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…Even more significantly, there is no record evidence contradicting the
Plaintiffs' assertions that they did not fabricate Ms. Giuffre's sworn account of her interactions
with the defendant Dershowitz.
The good faith basis for Edwards and Cassell's reliance on…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…directly contradicting Plaintiff’s deposition testimony that she was a “sex
slave” for 4 years from 1998-2002 and that she was with Epstein constantly during that four year
-
period.
Based on the newly discovered education records and other witness…
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, ¶…
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