giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…entities with (apparently) audited financial statements, the discovery here
should be much broader – and should include all of the significant requests made by Ms. Giuffre.
For example, Defendant should also be required to identify all financial transactions involving
(directly or…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Court, and/or that
plaintiff submitted to the Court for no valid purpose. The Sealing Opponents’ reputational
(Dershowitz) and financial (the other Opponents) interests are diametrically opposed to
Ms. Maxwell’s and the non-parties’.
Because of their respective motivations…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…destroyed
Hollywood Prince
Charlie Sheen
…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…which includes only some of the documents created during discovery,
totals in the “thousands of pages”).
Giuffre sought and obtained a wide variety of private and confidential information about
Maxwell and others, including information about financial and sexual matters. Brown…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…into a bun
Judge Alison Nathan ruled Maxwell was a significant flight risk, citing her
'substantial international' ties and 'extraordinary financial resources'
Maxwell appeared via video, accused of grooming girls as young as 14 for Jeffrey
Epstein to…
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.447706.1325.19
20 pg
…Ms. Maxwell’s personal financial information is not at issue in this
matter and information relating thereto is irrelevant. This Interrogatory also violates Local Rule
33.3(a) – (c) in that it does not seek the name of witnesses or…
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.447706.1256.12
32 pg
…worked for or been in control of Ms. Maxwell.
Ms. Maxwell and Mr. Epstein have had no financial, professional or employment
relationship in more than a decade, many years before 2015 when the purportedly
defamatory statement was published. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…time. I watched them
both ejaculate with each other. They were having quite a good time
together.)
Ransome Dep. Tr. at 234-235 (Q. Did you apply for any financial aid for
FIT? A. No. Jeffrey was covering FIT. Q…
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.447706.831.0_2
59 pg
…number. She was directed by her counsel not to
14 answer the 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…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…The information at issue . . . does
not involve the type of medical, health-related, family, or personal financial matter to which
courts grant the greatest protection.” United States v. Martoma, No. S1 12 Cr. 973, 2014 WL
164181, at *6 (S…
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
gov.uscourts.nysd.447706.78.0
30 pg
…Additionally, Ms. Giuffre is not withholding any documents based on any “privacy” objection.10
Indeed, she has produced her financial information (including tax returns), employment
information (including drafts of resumes), and medical information (including extensive medical
provider files).
Again, the…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…The defense
intends to show that Plaintiff for financial and other improper reasons manufactured her
allegations of “sex trafficking” and created from whole cloth her alleged $30 million in
noneconomic damages from “defamation.” Some of the most relevant and material…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…time. I watched them
both ejaculate with each other. They were having quite a good time
together.)
Ransome Dep. Tr. at 234-235 (Q. Did you apply for any financial aid for
FIT? A. No. Jeffrey was covering FIT. Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…that he was a philanthropist who would help female victims advance
their careers and lives; and that the recruits needed only to provide Epstein with
body massages in order to avail themselves of his financial assistance and
influence. In fact…
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…