giuffre-maxwell
gov.uscourts.nysd.447706.233.0
9 pg
…FACTUAL BACKGROUND
The Court is already familiar with the factual circumstances surrounding Epstein’s efforts
to avoid answering questions related to this case. Indeed, after having spent thousands of dollars
unsuccessfully trying to serve Epstein personally, on May 25, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…about her
alleged sexual encounters with ever more prominent men. Whenever anyone denies her
allegations, she and her coterie of lawyers threaten to sue or sue for tens of millions of dollars for
“defamation.” Mr. Dershowitz find himself, as Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…account should have been searched and was not. To the contrary, Ms.
Maxwell has spent thousands of dollars to forensically image all of her devices, searching every
account to which she has access, conducting extremely broad and over-reaching searches…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.25
10 pg
…no, but later in the day,
7 yes.
8 Q. And what did she say?
9 A. Twenty dollars an hour.
10 Q. Was there anybody else with Ms. Maxwell
11 when you met her?
12 A. There was another…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…she has, she has
21 admitted that she has been paid hundreds of thousands of
22 dollars for giving these stories to the media.
23 But to the extent that she is now bringing this
24 defamation claim, if she…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…account should have been searched and was not. To the contrary, Ms.
Maxwell has spent thousands of dollars to forensically image all of her devices, searching every
account to which she has access, conducting extremely broad and over-reaching searches…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…She
then made up similar claims for the purpose of getting paid hundreds of thousands of dollars by the media for
publicizing her allegations and identifying well know public figures whose names she has seen documents that she
reviewed or…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…Ms. Maxwell
should have to provide the same information. Of course, Plaintiff seeks over $80 Million dollars in compensatory
damages based on her alleged loss of reputation and emotional distress, putting her personal financial information
directly at issue. Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.37
11 pg
…11
Page 101
1 Q. How much?
2 A. One hundred dollars extra.
3 Can I clarify?
4 Q. Absolutely.
5 A. He didn't ever say he would pay me more,
6 but when the massage was more than…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.1
26 pg
…Q And how much would he pay you foreach girl
15 that you brought to him?
16 A Object form founds.
17 A Two hundred dollars apiece.
18 Q Where would this transaction tace place?
19 A Object to the…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…CMS301L
1-97-002687 (Continued)
police station in reference to property. I released two lighters,
paper, seven dollars and sixteen cents, and a key on a weave. The
property wasn•t listed on the property sheet due to the property…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
…no, but later in the day,
7 yes.
8 Q. And what did she say?
9 A. Twenty dollars an hour.
10 Q. Was there anybody else with Ms. Maxwell
11 when you met her?
12 A. There was another…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…criminal organization, involving a kingpin with vast
wealth (Jeffrey Epstein, a reported billionaire), and multi-million dollar transactions to others in
the organization such as Defendant (e.g., the apparent concealed transfer, through an attorney
associated with Epstein, of an…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…has forced Ms. Giuffre to
spend thousands of dollars to track down a person who is in Defendant’s employ.
5
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 7 of 13
D. …
giuffre-maxwell
gov.uscourts.nysd.447706.64.0
14 pg
…The fact discovery in this case is currently scheduled to close on July 1, 2016.
Although claiming tens of millions of dollars in damages Plaintiff has not identified one
doctor, medical record or other relevant information to support her claims…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…behind her. Her lawyers have been working together to coordinate
her media strategy, to make book deals, to give on-air interviews about Plaintiff’s allegations,
securing hundreds of thousands of dollars in media-money. Ms. Maxwell has not. She…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…of resources, but as this Court is
aware, Defendant is a wealthy socialite (wbo recently sold her New York Townhome for $15
million dollars) who has heavily litigated this case in ways that were completely unnecessary. 2
Moreover, deposition discovery…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.40
30 pg
…she has, she has
21 admitted that she has been paid hundreds of thousands of
22 dollars for giving these stories to the media.
23 But to the extent that she is now bringing this
24 defamation claim, if she…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…of
Plaintiff’s allegations published in Britain “and elsewhere” to which Maxwell responded and
which forms the basis of this action. In exchange for hundreds of thousands of dollars, Plaintiff
told The Mail on Sunday in 2011:
“Born in Sacramento…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…She
then made up similar claims for the purpose of getting paid hundreds of thousands of dollars by the media for
publicizing her allegations and identifying well know public figures whose names she has seen documents that she
reviewed or…
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