giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…t discuss either case. But in a little-noticed 2010 affidavit, given a year after the case was filed,
Edwards explained why he thought Trump and other notables involved with Epstein, including former President Bill
Clinton, might have relevant information…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.28
38 pg
…You can answer. 5 of this lawsuit is, which would be, as
6 A. I just explained. 6 you've termed it, sexual trafficking of
7 A. I spent the entire time talking to 7 Ms. Roberts.
8 Virginia's…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…not the
case. Guests having massages did not have massages in Mr.
Epstein’s private bedroom suite. This area was private and off-
limits to guests, which I explained to the lawyers during my
deposition.
Id. at ¶¶ 9-10.
40…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
… She explained that she lived in Palm Beach
25 and didn't want butlers because they're too stuffy.
MAGNA& LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1328-30 Filed 01/05/24 Page 9 of 40
Page…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
… She explained that she lived in Palm Beach
25 and didn't want butlers because they're too stuffy.
Case 1:15-cv-07433-LAP Document 1257-22 Filed 05/03/22 Page 9 of 40
Page 9
1 And…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…including one named “Virginia.” Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…including one named “Virginia.” Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…s needs for
discovery, the Court should enter a protective order against further discovery (DE 640) and deny
Defendant’s Combined Motion to Compel1 (DE 655).
As explained in Non-Party Ransome’s Motion for Protective Order, Defendant should not
…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…or Independent of the Protective Order
Ms. Giuffre explained in detail why her application to the Court is timely filed under the
Protective Order [DE 62], and will not burden the Court with a recitation of such details and
arguments…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…person's reputation. As the Fourth DCA has explained in
upholding a punitive damages award in a defamation case:
Florida's unusually high protection of personal reputation derives from the
common consent of humankind and has ancient roots. It is…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
… She explained that she lived in Palm Beach
25 and didn't want butlers because they're too stuffy.
MAGNA& LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 10 of 179
Page…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…including one named "Virginia." Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant's coW1sel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…phone number. There was no privilege asserted.
15 We asked for her financial information in our opening
16 papers. We explained the relevance of that financial
17 information. There was no response to that relevance argument,
18 your Honor, so…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
… She explained that she lived in Palm Beach
25 and didn't want butlers because they're too stuffy.
Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 9 of 40
Page 9
1 And…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…247, 270 (1981). As explained by
the Reporters of the American Law Institute’s Restatement of Torts, when considering the size of
punitive damages “[t]he wealth of the defendant is also relevant, since the purposes of exemplary
damages are…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…s needs for
discovery, the Court should enter a protective order against further discovery (DE 640) and deny
Defendant’s Combined Motion to Compel1 (DE 655).
As explained in Non-Party Ransome’s Motion for Protective Order, Defendant should not
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…And, as this Court has already explained, taking the deposition
or a newly-discovered witness cures any prejudice: " [t]his and other courts have adopted the
taking of depositions as an appropriate mechanism to address late-disclosed witnesses." NJBJA
Ins…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…Giuffre and others; and Defendant
continued to communicate with convicted sex offender Jeffrey Epstein until at least 2015. As
explained in Ms. Giuffre’s Motion to Compel, the abuse underlying this case started in or around
6
Defendant contends she…
giuffre-maxwell
1320-10
28 pg
…including one named “Virginia.” Id. at 21. It is
anticipated that he will testify consistently with that previous testimony.
3
As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set
for Tuesday…
giuffre-maxwell
1320-12
179 pg
… She explained that she lived in Palm Beach
25 and didn't want butlers because they're too stuffy.
MAGNA& LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 10 of 179
Page…
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