giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…Defendant’s job was for Epstein.8
That other young females were similarly recruited by the Defendant is evidence that Ms.
Giuffre is telling the truth about her experiences – and thus direct evidence that Defendant
defamed her when calling her…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…This fundamental guarantee is part of a criminal defendant’s basic right
to a fair trial, which requires that a defendant must be judged by a jury of her peers based on
evidence presented at trial, not in the media…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…NAME KNOWN? ...
CAN VICTIM I.D. SUSPECT? Y SUSPECT LOCATION KNOWN N
WILL VICTIM PROSECUTE ? . . Y STOLEN PROPERTY TRACEABLE?
IS M.O. SIGNIFICANT? EVIDENCE LEFT AT SCENE? ...
LATENTS LIFTED? ... SUSPECT'S VEHICLE KNOWN? .. N
TAG NUMBER KNOWN ? .. …
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s Interrogatories
are based on information currently known to her and are given without waiving Ms. Maxwell’s
right to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…ARRESTED ON PRIMARY OFFENSE
Arrest Case No.: 1-97-006345 People Arrested: 1
*********P ROPERTY INFORMA TION # 1 ************** *******
Category. . . PROP/EVIDENCE--NO VALUE
UCR Prop Type CONSUMABLE GOODS Quantity. 1
Description . : SEAGRAMS VO LIQUOR Value : 1.00
R…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…and pantry located off the kitchen were searched and
yielded negative results .
Th~ kitchen was searched and taken into evidence was a phone message
book: that was located near a house phone.
North of the kitchen was an office room…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…and pantry located off the kitchen were searched and
yielded negative results .
Th~ kitchen was searched and taken into evidence was a phone message
book: that was located near a house phone.
North of the kitchen was an office room…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…of 15
fact of this dispute confinns, this case is going to be hotly contested and the weight of the
evidence on each side is going to be vitally impo1iant. The Comi is well aware of many other
civil cases…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…1
Ms. Giuffre intends to strongly disprove Defendant’s false assertions and to demonstrate that
Defendant recruited Ms. Giuffre to be involved in massages of a sexual nature with Epstein.
To develop evidence to support her position, Ms. Giuffre recently…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…10
Ms. Giuffre intends to strongly disprove Defendant’s false assertions and to demonstrate that
Defendant recruited Ms. Giuffre to be involved in massages of a sexual nature with Epstein.
To develop evidence to support her position, Ms. Giuffre recently…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…ofPage
01/21/2015 41 2 of 40
sworn affidavit (attached as Exhibit 1) that all her allegations are true – an affidavit consistent
with compelling corroborating evidence.
BACKGROUND AND COURSE OF PROCEEDINGS
Because this case …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…to benefit from her obvious failure to properly disclose Ms.
Ransome.
Ms. Ransome's Testimonv is ot Cumulative And Has Highly Relevant Evidence
Defendant also advances the remarkable argument that it is "unlikely" that Ms. Ransome
will have relevant information…
giuffre-maxwell
1320-6
10 pg
…10
Ms. Giuffre intends to strongly disprove Defendant’s false assertions and to demonstrate that
Defendant recruited Ms. Giuffre to be involved in massages of a sexual nature with Epstein.
To develop evidence to support her position, Ms. Giuffre recently…
giuffre-maxwell
1320-13
45 pg
…and pantry located off the kitchen were searched and
yielded negative results .
Th~ kitchen was searched and taken into evidence was a phone message
book: that was located near a house phone.
North of the kitchen was an office room…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…victims, employing “a pyramid abuse scheme in which he paid
underage victims $200-$300 cash for each other underage victim that she brought to him.”
“There is no evidence the President was involved in Epstein’s schemes,” Scarola said.
Still…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Privileges Were Not Waived
a. Attorney-Client Privilege
The attorney-client privilege is codified under Florida's Title VII Evidence. The
statute provides that neither an attorney nor a client may be compelled to divulge confidential
communications between a lawyer…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…Pending
or Reasonably Foreseeable Litigation to Which Ms. Giuffre Was a Party..............6
C. There Was No Willful Destruction of Evidence......................................................8
D. Defendant Cannot Show That The Journal Was Favorable to Her.........................…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…internal
inquiry report, which was contemporary, contained statements
n by witnesses on the spot and would almost certainly be the
best evidence as to the cause of the accident, should be dis
closed; that for that important public interest to…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…1 four individuals had sexually abused her prior to ever meeting
2 Mr. Epstein.
3 If she has evidence that she already was suffering
4 from depression or some type of mental health disorder before
5 meeting our client, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…3, 2019). There, the proposed intervenors sought “materials (1) offered into evidence but
excluded by the Court at trial, (2) used to refresh a witness’s recollection, or (3) discussed on the
record but never moved into evidence.” Id. at…
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