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.447706.1219.30
16 pg
…Inc., 800 F.2d 298 (2d
Cir. 1986).
10
witnesses have corroborated Plaintiff’s claim that she was “sexually trafficked.” Plaintiff’s
counsel has withdrawn the Joinder Motion in which Plaintiff made that allegation. These, along
with the numerous other…
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.447706.1330.23
9 pg
…Giuffre to bear a child for them. Ms. Giuffre’s statement is directly
corroborated by another young woman Defendant’ recruited to provide sexual massages to
Epstein. Indeed, Johanna Sjorberg testified that Epstein asked her to bear a child for him…
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.447706.492.0
9 pg
…Giuffre to bear a child for them. Ms. Giuffre’s statement is directly
corroborated by
See Schultz Dec. at Exhibit 1, There is no
“fabrication” here.
3
5
Case 1:15-cv-07433-LAP Document 492 Filed 10/28…
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.447706.1256.8
16 pg
…Giuffre can establish that Defendant’s
modus operandi was to recruit young females for Epstein, that helps corroborate Ms. Giuffre’s
own testimony that Defendant recruited her for the same purposes and in the same manner.
Although the Court need…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…Tr. at p 311:13-312:10.
The electronic communications non-party Ransome produced corroborates her testimony
that she was being trafficked by Defendant and Jeffrey Epstein, including being forced to lose
additional weight during the time she was being…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…are all witnesses who can testify to Defendant working essentially as a madam for Jeffrey
Epstein, recruiting young females for Epstein, or corroborate other important aspects of her
statements. The fact that Defendant recruited girls, some of which were underage…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…gives her own narrow view of what existing witnesses have said.
For example, Defendant argues that Ms. Sjoberg “did not corroborate that [Ms. Giuffre] is telling
the truth.” Defendant’s Response at 5. Defendant’s characterization is untrue.1 But…
giuffre-maxwell
1320-21
15 pg
…gives her own narrow view of what existing witnesses have said.
For example, Defendant argues that Ms. Sjoberg “did not corroborate that [Ms. Giuffre] is telling
the truth.” Defendant’s Response at 5. Defendant’s characterization is untrue.1 But…
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.447706.1218.49
27 pg
…young
girl” that I had sexual contact with – i.e., that there were others. Of course, no such persons have
ever presented themselves to corroborate this accusation. Nonetheless, Mr. Cassell latched on to
this allegation as a “basis” for his…
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…
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