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counsel has withdrawn the Joinder Motion in which Plaintiff made that allegation.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.447706.164.0
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.447706.492.0
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.447706.1256.8
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.447706.1256.11
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.447706.1090.18
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.447706.1296.2
17 pg
…message pads collected
from Jeffrey Epstein's home in the search warrant?
THE WITNESS: It was very important to corroborate what the victims had
already told me as to calling in and for work.
Id. at 78:25 -79:15.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…all,
Q. Okay. My understanding, and tell me if was this a telephone call?
this is wrong or you can corroborate this, is that A. Yes, she was in New York.
Mr. Epstein would pay the girl that was actually…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…message pads collected
from Jeffrey Epstein's home in the search warrant?
THE WITNESS: It was very important to corroborate what the victims had
already told me as to calling in and for work.
Id. at 78:25 -79:15.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 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.2 But…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
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.447706.1320.27
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.3 But…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
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…
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