gov.uscourts.nysd.447706.515.0.pdf PDF
…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 …
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gov.uscourts.nysd.447706.1295.5.pdf PDF
…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…
gov.uscourts.nysd.447706.1201.10_1.pdf PDF
…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: …
gov.uscourts.nysd.447706.1327.26.pdf PDF
…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…
gov.uscourts.nysd.447706.230.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1332.10.pdf PDF
…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…
gov.uscourts.nysd.447706.702.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1325.15.pdf PDF
…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…
gov.uscourts.nysd.447706.135.0.pdf PDF
…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…
gov.uscourts.nysd.447706.57.1.pdf PDF
…primary or substantial purpose, and the judgment of Buckley L.J., even taken on its own, does not go to the extent of contradicting that of Hamilton L.J.: see at p. 856: " I t is not I think necessary . . ."…
gov.uscourts.nysd.447706.1330.17.pdf PDF
…To date, those (and many other) records have not been produced. Moreover, Plaintiff made substantive and completely contradictory changes to her deposition testimony in errata sheets after the conclusion of her deposition. As well, she was instructed by counsel not…
gov.uscourts.nysd.447706.1219.22.pdf PDF
…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…
gov.uscourts.nysd.447706.1256.16.pdf PDF
…records in footnote 4 of her brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr. Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records. See chart above, Giuffre005431-005438…
gov.uscourts.nysd.447706.1198.5_2.pdf PDF
…records in footnote 4 of her brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr. Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records. See chart above, Giuffre005431-005438…
gov.uscourts.nysd.447706.193.0.pdf PDF
…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…
gov.uscourts.nysd.447706.99.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1256.19.pdf PDF
…records in footnote 4 of her brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr. Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records. See chart above, Giuffre005431-005438…
gov.uscourts.nysd.447706.1198.12_3.pdf PDF
…records in footnote 4 of her brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr. Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records. See chart above, Giuffre005431-005438…
gov.uscourts.nysd.447706.45.0.pdf PDF
…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…
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