giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…documents do not directly bear on Ms. Giuffre’s sworn and detailed statements
about how Dershowitz sexually abused her, statements that are corroborated by a mountain of
supporting evidence.2 Instead, according to Dershowitz, these materials create some sort of…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…these claims.” (emphasis supplied) (attorney-client communications);
“The assertions of sexual abuse are more than adequately corroborated by compelling
circumstantial evidence which is detailed at length by Cassell in his deposition.” (work
product/investigations);
“Regardless of whether Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…of Virginia Giuffre (Exhibit #2), at II 24-31,¶ 71.
The assertions of sexual abuse are more than adequately corroborated by compelling
circumstantial evidence which is detailed at length by Cassell in his deposition. However, the
Court (like the jury…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…these claims.” (emphasis supplied) (attorney-client communications);
“The assertions of sexual abuse are more than adequately corroborated by compelling
circumstantial evidence which is detailed at length by Cassell in his deposition.” (work
product/investigations);
“Regardless of whether Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…documents do not directly bear on Ms. Giuffre’s sworn and detailed statements
about how Dershowitz sexually abused her, statements that are corroborated by a mountain of
supporting evidence.2 Instead, according to Dershowitz, these materials create some sort of…
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…I hope my attorneys can interview Prince Andrew under oath about the contacts and that he
will tell the truth.”
“Her allegations against Prince Andrew are strongly corroborated,” her attorneys claimed in newly 뒫led court documents.
“For example…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…and
e. any Documents You have to support or corroborate Your claim of such
sexual trafficking.
12
Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 14 of 40
Response to Interrogatory No. 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…by anything that Ms. Kellen or Ms. Marcincova may have done with
anyone else. Their testimony cannot corroborate Plaintiff’s account, nor can it shed light on
whether Ms. Maxwell’s denial of that account is accurate, because Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…working for Epstein. Plaintiff
goes so far as to state that Maria Alessi’s deposition is expected to “corroborate” the
observations of her husband’s.
Plaintiff admits that the purpose in seeking the additional depositions is “obtaining
witnesses, like Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…Ex. 2, p, 6/34. Shortly thereafter, on March 20, 2011,
Churcher emailed Plaintiff explaining to her how she can corroborate a story to tell the FBI –
that she was “given to” Prince Andrew. Menninger Decl., Ex. A, p. 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…which
Ms. Maxwell personally directed him to distribute the January 2015 statement. Mot. 4.
The “smoking gun” is a dud. It too is consistent with—corroborates—Mr. Barden’s
testimony. The earlier email is from Ms. Maxwell to Mr. Gow…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…Income You received in exchange for such sexual trafficking; and
e. any Documents You have to support or corroborate Your claim of such sexual
trafficking.
Response to Interrogatory No. 8:
Ms. Giuffre objects to this interrogatory in that it violates…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…EXCULPATORY EMAILS, REPLY BRIEF, AND MANUSCRIPT
Each of the Requested Documents corroborates Professor Dershowitz’s claims of
innocence and undermines both Ms. Giuffre’s credibility generally and the veracity of her
accusations against Professor Dershowitz specifically.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…Filed 07/29/20 Page 91 of 161
'The recollections of the victims bear striking resemblances that corroborate each other
and provide compelling proof of the defendant's active participation in a disturbing
scheme to groom and sexually abuse minor…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…by anything that Ms. Kellen or Ms. Marcincova may have done with
anyone else. Their testimony cannot corroborate Plaintiff’s account, nor can it shed light on
whether Ms. Maxwell’s denial of that account is accurate, because Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…Income You received in exchange for such sexual trafficking; and
e. any Documents You have to support or corroborate Your claim of such
sexual trafficking.
Response to Interrogatory No. 8
Ms. Giuffre objects to this interrogatory in that it violates…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…Income You received in exchange for such sexual trafficking; and
e. any Documents You have to support or corroborate Your claim of such sexual
trafficking.
9. Identify any Employment You have had from 1996 until the present, including
without limitation…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…the document they confiscated from a houseman called
Alfredo Rodriguez. Maybe Jason means that he wants to know how they
corroborate the flight to London when you were 'given' to Andrew . Here's
how: you had photos from that trip…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…and
e. any Documents You have to support or corroborate Your claim of such
sexual trafficking.
Response:
11
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 15 of 40
Ms. Giuffre objects to…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…involved in the abuse of Ms. Giuffre is false. Overwhelming evidence – including
documents, witness testimony, and even photographs of Defendant - not only clearly corroborate
Ms. Giuffre’s report of the sex abuse, but also, importantly, show Defendant’s deep and…
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