giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…from the deposition
testimony of a deceased individual, who Ms. Maxwell never had the opportunity to cross-
examine, and who (contemporaneous with his deposition) was convicted of a felony and
sent to prison for stealing, and then trying to sell…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…described herself as a journalist.'
Last summer, DailyMail.com previously tracked down Maxwell in Manchester-by-the-Sea,
living at a home owned by her tech CEO lover Scott Borgerson. It is unclear if the man
who toured the New…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…1987) (where attorney took stand, privilege
waived for information necessary to cross-examine attorney).
To be sure, parts of Barden’s Declaration appear to have been cleverly written in an
attempt obscure the fact that he is revealing attorney-client…
giuffre-maxwell
gov.uscourts.nysd.447706.565.0
4 pg
…Giuffre,
Plaintiff, Case No: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
PLAINTIFF’S OBJECTIONS TO DEFENDANT’S DEPOSITION DESIGNATIONS
AND PLAINTIFF’S CROSS DESIGNATIONS
Plaintiff Virginia Giuffre, hereby subm…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…Dershowitz
Brittany N. Henderson, Esq.
6 Meridith Schultz, Esquire
7
- - -
8
I N D E X
9
10 WITNESS DIRECT CROSS REDIRECT RECROSS
11 Virginia Roberts Giuffre
By Ms. Borja …
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…Dershowitz
Brittany N. Henderson, Esq.
6 Meridith Schultz, Esquire
7
- - -
8
I N D E X
9
10 WITNESS DIRECT CROSS REDIRECT RECROSS
11 Virginia Roberts Giuffre
By Ms. Borja 5
12 …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…383 South University Street BY MR. CASSELL:
Salt Lake City, Utah 84112 5
5 Phone: 801.585.5202 CROSS-EXAMINATION 275
6 BY MR. PAGLIUCA:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…383 South University Street BY MR. CASSELL:
Salt Lake City, Utah 84112 5
5 Phone: 801.585.5202 CROSS-EXAMINATION 275
E-mail: [email protected] 6 BY MR. PAGLIUCA:
…
giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…is relevant to Ms. Giuffre’s claims for multiple reasons, not
least of which is
Ms. Giuffre should be able to cross her with and ask related
questions. Therefore, both of these documents are highly relevant. Whatever Defendant argues about…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…innuendo and comment has been taken from civil
depositions against JE, which were settled many years ago. None of the
depositions were ever subject to cross examination, not one. Any standard of
truth and were used for those who claimed…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…that’s just
going to enrage a jury if she goes to trial -- which I would not do if I were
representing her.’
Boies said he was confident Farmer would stand up to cross-examination if
there’s a trial…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…He makes me realize
things about myself':
Adele says motherhood
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
…microphone?
3 Corporation? 3 MR. HOROWITZ: l do,
MR, RHB!Nlil\RT: lnstruot the witness not 4 CROSS (SARAH KELLEN}
5 to answer based on her Fifth Amendment 5 BY MR. HOROWITZ:
6 priv:ilege. …
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…s representations on this as
23 to what it is or isn't. I've never had the opportunity to
24 question or cross-examine anybody about this document; it just
25 shows up in the course of this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…have had
limited contact since
Every story in the press innuendo and comment has been taken from civil
depositions against JE, which were settled many years ago. None of the
depositions were ever subject to cross examination, not one. any
…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…Dershowitz is now involved in
11 ongoing battles with plaintiff's lawyers down in Florida. They
12 cross claimed one another for defamation. And she's been
13 participating in that litigation as a non-party as well,
14 although…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…16 A. Yes.
17 MS. MENNINGER: Objection, outside the
18 scope of cross.
19 BY MS. McCAWLEY:
20 Q. You mentioned that there was a time when
21 you noticed that Maxwell was around a little bit
22 less?
23…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…she was when she met
21 Ghislaine Maxwell?
22 MS. McCAWLEY: Objection. Exceeds the
23 scope of cross.
24 THE WITNESS: I don't have any idea what
25 she told them in terms of her age.
MAGNA9 LEGAL SERVICES
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
…s
Page 276 Page 278
1 CONTINUED INDEX OF EXAMINATION 1 completely irrelevant and immaterial and has
2
WITNESS DIRECT CROSS REDIRECT RECROSS
…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…Dershowitz is now involved in
11 ongoing battles with plaintiff's lawyers down in Florida . They
12 cross claimed one another for defamat i on . And she ' s been
13 participating in that litigation as a non-party as well…