giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…Miami
Herald claims to practice. Indeed none of the descriptions of alleged sexual activities or
unsupported claims of sex with nonparties would be relevant to the Herald’s claimed
investigation of a “cross-border sex-trafficking ring,” Mot. to Unseal…
giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
…In order to investigate, as we would be obligated to do and
3 entitled to do, your Honor, we would be forced to engage in
4 cross-border discovery. A simple Rule 45 subpoena would not
5 suffice, your Honor. …
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…21
and to witnesses who may be able to provide evidence of a wider, cross-border sex-trafficking
ring.
In connection with its ongoing investigation, the Miami Herald has sought to access public
court filings that will shed light on…
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.447706.1335.3
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.447706.1330.23
9 pg
…the commencement of this litigation (as shown by the document at issue) is
-
evidence to the contrary. Ms. Giuffre should be able to cross her with that email and ask related
questions. Therefore, both of these documents are highly relevant…
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.447706.492.0
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.447706.561.0
22 pg
…Parties.........................................6
II. THE COURT SHOULD USE ITS DISCRETION TO PRECLUDE INTRODUCTION
OF TESTIMONY FROM A WITNESS MS. GIUFFRE HAS NOT HAD THE
OPPORTUNITY TO CROSS EXAMINE. ............................................................................8
A. Allowing…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…motion papers. And Maxwell cites no
precedent for the proposition that Doe 1’s memory is a countervailing interest sufficient to justify
continued sealing—Doe 1’s medical condition may have been the proper subject of
cross-examination, but it…
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.447706.1331.11
8 pg
…s
Page 276 Page 278
l CONTINUED INDEX OF EXAMINATION 1 completely irrelevant and immaterial and has
2
WITNESS DIRECf CROSS RED…
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.447706.1296.2
17 pg
…Perhaps it will surprise you, I think it should not, that I do not believe in my
deposition I need to simply accept her characterization without cross-examination. Now
that’s something the judge can decide, but a question as…
giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…testimony as unreliable in this forum does not make it so. By their own admission,
neither the Does nor any representative of them attended the deposition to cross the deponent, and
their understanding of the deposition appears to stem from…
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
…