giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…Giuffre was with Defendant and Epstein, namely, from 2000 - 2002.
Defendant has denied that she used those accounts to communicate, but she has not disclosed the
account she did use to communicate during that time, nor produce documents from it…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…is alleged by Ms. Roberts that Alan
Dershowitz is involved in having sexual relations with her, which he denies.
Ms. Roberts claims are obvious lies and should be treated as such and not publicized as
news, as they are defamatory…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…Giuffre was with Defendant and Epstein, namely, from 2000 - 2002.
Defendant has denied that she used those accounts to communicate, but she has not disclosed the
account she did use to communicate during that time, nor produce documents from it…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…this Court on June 20, 2016, granted in
part and denied in part Plaintiff’s Motion. Specifically, this Court held:
Federal Rule of Civil Procedure 26(f)(3)(C) requires the parties to state their views and
proposals as to…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…excessive and redundant briefing on these issues, resulting in no additional
production. Plaintiff’s Motion must be denied because no “undisclosed” email account exists
and Ms. Maxwell has fully complied with this Court’s Orders.
ARGUMENT
I. PLAINTIFF HAS FAILED…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…Ms. Giuffre
sought relief from the Court numerous times:
1
Plaintiff’s Response in Opposition to Defendant’s Motion to Stay Discovery (DE 20)
- Defendant’s Motion to Stay - Denied (DE 28).
Plaintiff’s February 26, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…Giuffre was with Defendant and Epstein, namely, from 2000 - 2002.
Defendant has denied that she used those accounts to communicate, but she has not disclosed the
account she did use to communicate during that time, nor produce documents from it…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…Ms. Giuffre
sought relief from the Court numerous times:
1
Plaintiff’s Response in Opposition to Defendant’s Motion to Stay Discovery (DE 20)
- Defendant’s Motion to Stay - Denied (DE 28).
Plaintiff’s February 26, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…LAP Document 1327-19 Filed 01/05/24 Page 2 of 21
x Plaintiff’s Response in Opposition to Defendant’s Motion to Stay Discovery (DE 20)
- Defendant’s Motion to Stay - Denied (DE 28).
x Plaintiff’s February 26…
giuffre-maxwell
gov.uscourts.nysd.447706.468.0
12 pg
…Giuffre was with Defendant and Epstein, namely, from 2000 - 2002.
Defendant has denied that she used those accounts to communicate, but she has not disclosed the
account she did use to communicate during that time, nor produce documents from it…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…that are still being repeated by Ms. Giuffre and her
2
lawyers today, as well as a sanctions motion against me that, while denied by the trial judge, is
currently being appealed by Ms. Giuffre’s lawyers.
5. I have…
giuffre-maxwell
gov.uscourts.nysd.447706.279.0
8 pg
…this Court on June 20, 2016, granted in
part and denied in part Plaintiff’s Motion. Specifically, this Court held:
Federal Rule of Civil Procedure 26(f)(3)(C) requires the parties to state their views and
proposals as to…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…Road, Dulwich Hill, NSW 2203. Records have been
requested, but thus far have been denied. Another medical release was sent and is
pending.
! New York Presbyterian Hospital treated Ms. Giuffre as described in the medical
records produced at Giuffre003258-3298.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…the truth.
10
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.447706.1296.9
29 pg
…the truth.
10
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.447706.1331.3
48 pg
…Road, Dulwich Hill, NSW 2203. Records have been
requested, but thus far have been denied. Another medical release was sent and is
pending.
! New York Presbyterian Hospital treated Ms. Giuffre as described in the medical
records produced at Giuffre003258-3298.
…
giuffre-maxwell
1320-37
48 pg
…Road, Dulwich Hill, NSW 2203. Records have been
requested, but thus far have been denied. Another medical release was sent and is
pending.
! New York Presbyterian Hospital treated Ms. Giuffre as described in the medical
records produced at Giuffre003258-3298.
…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…Road, Dulwich Hill, NSW 2203. Records have been
requested, but thus far have been denied. Another medical release was sent and is
pending.
! New York Presbyterian Hospital treated Ms. Giuffre as described in the medical
records produced at Giuffre003258-3298.
…
giuffre-maxwell
gov.uscourts.nysd.447706.542.3
2 pg
…March 10, 2011 - Ghislaine Maxwell denies the
various allegations about her
that have appeared recently in the media. These allegations
are all entirely
false.
It is unacceptable that letters sent by Ms Maxwell's legal
representatives to certain newspapers pointing…
giuffre-maxwell
gov.uscourts.nysd.447706.24.2
2 pg
…in Publishing & Information Services | Legal Issues
Statement on Behalf of Ghislaine Maxwell
Share
LONDON, March 10, 2011 /PRNewswire/ -- Ghislaine Maxwell denies the various allegations about her that have appeared
recently in the media. These allegations are all entirely false. …
Comments