giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…2015 WL 4610422 (S.D.N.Y. July 23, 2015) (granting in part
motion to compel production).
In the Second Circuit, courts have dismissed actions where a party has demonstrated
willful disregard for its discovery obligations. Edwards v. Am. Airlines…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…24, 2015 3:36 AM
To: G Max; Ph ilip Ba rden
Subject: VR cried rape - prior case dismissed as pmsecutors found her 'not credible'
Ghislaine
Some helpful leakage ...
Defendant has been liberal with her own confidentiality designations. In fact…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…was on hold for two years pending last month’s Florida Supreme
Court ruling, which reversed a lower court decision that dismissed the accusation on technical grounds.
Edwards won’t discuss either case. But in a little-noticed 2010 affidavit…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…order by truthfully answering a question put to me by the opposing lawyer and
offering to seal my answer. The BSF motion for sanctions was subsequently dismissed for lack of jurisdiction and
standing, and is now being appealed by Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…RWS Document 22 Filed 12/15/15 Page 2 of 14
Table of Contents
ARGUMENT....................................................................................................................... 2
I. The Motion to Dismiss is Dispositive and Well Founded In Law ....................…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…on
his improper invocation of the Fifth Amendment in refusing to comply with the subpoena.
Epstein's invocation of the Fifth Amendment was invalid for several reasons, as discussed in
detail in the Motion to Compel. One of those reasons…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…observations.
Defendant Violated Rule 26 By Failing To Disclose This Critical Witness
Defendant argues that Ms. Giuffre is somehow to blame for the fact that Sarah Ransome
is only now being discussed as a witness in this case. But Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
… 2005.
18 Q. Why?
19 A. My wife and I had discussed these
20 incidents, and this last one was just, we
21 couldn't deal with it.
22 Q. When you left your employment with
23 the Dubin family…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
… 2005.
18 Q. Why?
19 A. My wife and I had discussed these
20 incidents, and this last one was just, we
21 couldn't deal with it.
22 Q. When you left your employment with
23 the Dubin family…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Giuffre, under
the age of 18 on any of Epstein’s properties. Id. at 384.
Whether Defendant had discussed with any of the details of Ms. Giuffre’s
allegations against him.
Because Defendant refused to answer those questions, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…the age of 18 on any of Epstein’s properties. Id. at 384.
! Whether Defendant had discussed with Prince Andrew any of the details of Ms. Giuffre’s
allegations against him. Id. at 400.
Because Defendant refused to answer those…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…PRIVILEGE.
As the Court is aware, Edwards and Cassell have pending a motion to dismiss both
counts of the First Amended Counterclaim on the basis of litigation privilege and other
arguments. In this motion for summary,Edwards and Cassell specifically…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…Ms. Giuffre, under
the age of 18 on any of Epstein's prope1ties. Id. at 384.
• Whether Defendant had discussed with any of the details of Ms. Giuffre's
allegations against him. -
Because Defendant refused to answer those questions, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…I'll be oblique in my references to it now -- to whom
6 she discussed the subject matter of her testimony in this case,
7 but only produced selected e-mails with that individual because
8 they have been marked…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
… 2005.
18 Q. Why?
19 A. My wife and I had discussed these
20 incidents, and this last one was just, we
21 couldn't deal with it.
22 Q. When you left your employment with
23 the Dubin family…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…be presented to the jury). Instead, it appears that her
only argument concerns the timing of the disclosure of such information, an issue discussed
below. For purposes of setting out the salient facts, then, it is enough to note here…
giuffre-maxwell
1320-10
28 pg
…the age of 18 on any of Epstein’s properties. Id. at 384.
! Whether Defendant had discussed with Prince Andrew any of the details of Ms. Giuffre’s
allegations against him. Id. at 400.
Because Defendant refused to answer those…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…claims to
have been abused and one month prior to the purported defamation. Plaintiff has offered no
plausible explanation for her expansive time frame as discussed below.
The gist of Plaintiff’s temporal relevance argument is that, according to Plaintiff…
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