giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…the
interest of justice and to avoid any undue prejudice during the liability phase of
this action, the trial will be bifurcated. . . . Therefore, defendant's motions for
partial summary judgment and to stay discovery as to his financial status are…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…as she
poses to promote body
positivity
…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…information
protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal
Rules of Evidence, any common interest privilege, joint defense agreement or any other
applicable privilege.
4. Ms. Maxwell objects to the Interrogatories to the…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
… I don't have the
3 date in front of me. I'm sorry.
4 THE COURT: That solves that problem. I have the
5 joint interest agreement. It's been submitted. It occurs to
6 me that it is…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…the public in
order to advance and carry out his crimes and torts. At all relevant times,
Defendant Epstein owned and continues to own, directly or through nominee
individuals used to conceal his interests, a fleet of airplanes, motor vehicles…
giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…been married.
4 They have no financial relationship. They have no financial
5 ties. So the disparity between the LiButti relationship and
6 the relationship of Ms. Maxwell is significant.
7 The common interest agreement which the plaintiff
8 makes…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…The financial and other terms associated
with the settlement are confidential.
ARGUMENT
The Court should not permit the Defendant to use at trial in this case excerpts from
Dershowitz’s deposition in the Florida state defamation case involving Edwards and…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.15
6 pg
…me that there is a
19 not to answer the question. Nice try. 19 financial arrangement between Jean-Luc Brunel and
20 Instruct you not to answer based on 20 Jeffrey Epstein, do you not?
21 your Fifth Amendment privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…personal, political, and financial gain, as well as to obtain potential blackmail
information.
One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual
relations with was former Harvard Law Professor Alan Dershowitz, a close friend…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…at length calling the plaintiff in that case,
5 Mr. McNamee, a liar, calling him a liar 25 ways to Sunday,
6 talking about his financial motives, his potential financial
7 gain, et cetera.
8 Likewise, in the Davis v…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…at length calling the plaintiff in that case,
5 Mr. McNamee, a liar , calling him a liar 25 ways to Sunday,
6 talking about his financial motives, his potential financial
7 gain, et cetera .
8 Likewise, in the Davis v …
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…for
business, personal, political, and financial gain, as well as to obtain potential blackmail
information.
One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual
relations with was , a close friend of Epstein’s
…
giuffre-maxwell
1320-9
10 pg
…personal, political, and financial gain, as well as to obtain potential blackmail
information.
One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual
relations with was former Harvard Law Professor Alan Dershowitz, a close friend…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Such
documents are plainly protected by attorney-client privilege. The privileged character of these
communications is not negated by Dershowitz's claimed need to probe her and her lawyers'
financial motivations. The Florida District Court of appeal has plainly held…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…personal, political, and financial gain, as well as to obtain potential blackmail
information.
One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual
relations with was former Harvard Law Professor Alan Dershowitz, a close friend…
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