giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…that the Defendant may
be selling her assets in New York and transferring the money outside the jurisdiction.
Accordingly, Defendant’s motion for a protective order should be denied.1
I. PRELIMINARY STATEMENT
As recounted by Defendant (DE 370 at…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…she says, molested her mid-flight on the private jet TURN BASED
• Both the Duke of York and Dershowitz have fiercely denied their
involvement in the ring
…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…to Ms. Giuffre’s
confidentiality designation is without merit, and it is for improper purposes. Therefore, it should
-
be denied.
Ms. Giuffre moved to maintain her confidentiality of highly sensitive documents. They
are police reports involving Ms. Giuffre, including two…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…Epstein
October 9, 2016 | 7:O8am
V
,J
cl
Jeffrey,Epst…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…Now, almost four (4) months later, and even after this Court denied defendant’s attempts
to stay discovery and directed a response, defendant is still refusing to produce highly relevant
documents. Defendant is attempting to grant herself a de facto…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…Ex. B at GIUFFRE004192-93.
In her deposition in the Edwards defamation lawsuit, she later denied having sex with
:
“Q: Have you ever met a ?
A: Possibly.
Q: Do you know one way or the other?
A: Do I know…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…LAP Document 1078-5 Filed 07/29/20 Page 67 of 161
Ghislaine Maxwell breaks down in
tears as she is DENIED bail and must
stay locked up until her July 2021 trial
as judge rules Epstein's 'madam' has
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…Page 15 of 29
These documents do not lie, and moreover make it abundantly clear that Defendant was far
from truthful during her deposition when she denied being a part of Epstein’s sexual abuse
conspiracy. Rather than engage Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…and
incorporated herein as Exhibit #2, unequivocally contradicts Alan Dershowitz's protestations of
innocence and his malicious statements made against Edwards and Cassell. However,
Dershowitz has denied the accuracy of Ms. Giuffre's charges against him. While at trial,
Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…Page 15 of 29
These documents do not lie, and moreover make it abundantly clear that Defendant was far
from truthful during her deposition when she denied being a part of Epstein’s sexual abuse
conspiracy. Rather than engage Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…2d 69 (2d Cir.1991), the comt
denied the n10tion to reopen discovery and granted summary judgment because the plaintiff
fai led to seek any discovery during the six-month discovery period set forth by the court. In
stark contrast…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…This conduct began with a motion to stay all discovery in the
case, which this Court denied. Defendant also missed the deadline for filing her Rule 26
disclosures and then waited an additional three months before filing the Rule 26…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…¶ 4). Ms. Maxwell consistently has denied
Plaintiff’s allegations, both publicly and privately. Plaintiff cannot therefore complain of “fading
memories” and “stale evidence” during a months’ long stay when she waited years to bring a
claim against Ms. Maxwell regarding…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…Okla. May 29, 2008) (finding that “many of the
parties’ requests for production of documents are overbroad, as they request ‘all documents'
relating to or concerning a subject”), reconsideration denied in part, 2008 WL 3892067 (N.D.
Okla. Aug. 14…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…2015, Judge Marra denied Ms. Giuffre’s motion to join the case.
Judge Marra concluded that “at this juncture in the proceedings” details about the sexual abuse
she had suffered was unnecessary to making a determination “of whether Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…2015, Judge Marra denied Ms. Giuffre’s motion to join the case.
Judge Marra concluded that “at this juncture in the proceedings” details about the sexual abuse
she had suffered was unnecessary to making a determination “of whether Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…Obviously, I
have never refused to answer questions about Ms. Giuffre’s absurd and false allegations against
me—I have repeatedly denied them outright, under oath—and I exercise no control over any of
Mr. Epstein’s associates who invoked…
giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…testimony, and
9 you, your Honor, denied that motion to compel and found that
10 Mr. Epstein had a Fifth Amendment privilege.
11 The control issue I think is also significant here,
12 your Honor, because not only does Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…our opinion, having a conversation with a
5 lawyer -- by the way, that lawyer denies he is her lawyer -- in
6 any event, she said she had a conversation with him in the
7 presence of a third party, and…
giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
…Maxwell, your Honor, absolutely denies these new
8 allegations relating to events that purportedly occurred more
9 than a decade ago and, moreover, do not bear directly on the
10 defamation claim at issue in this case.
11 I'd…
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