giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…to answer questions on this subject. And, once
again, Ms. Giuffre was forced to move to compel answers. And, once again, the Court ordered
Defendant to answer questions about the subjects she had refused to address, enumerating four
specific topics…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…she had no
memory of any of the events. As a result, Ms. Giuffre was forced to file a Motion to Compel
Defendant to Answer Deposition Questions Filed under Seal (DE 143). On June 20, 2016, this
Court granted Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.444.0
2 pg
…the exhibits to Professor Dershowitz’s Reply Declaration are
confidential—and the declaration makes only a few brief references to materials that may be
deemed confidential—Professor Dershowitz was nonetheless forced to redact large swaths of the
publicly filed version…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…disregard of the Court’s compelling reasons for
permitting the parties to seal materials. This case involved plaintiff’s claim she had been
“forced” to be a “child” “sex slave” for a long list of prominent men. She accused Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…Allowing the
Defendant in this case to force this non-party to provide discovery on this highly sensitive topic
would be both oppressive and unreasonable and serves no purpose other than to foster Defendant’s
publicly admitted and utterly baseless…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Maxwell “in her deposition [on April 25] raised Ms.
Giuffre’s comments about President Clinton as one of the ‘obvious lies’ to which she was
referring in her public statement that formed the basis of this suit.” Reply at 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…Paragraph 13 provides that the Protective Order “shall have
no force and effect on the use of any [confidential information] at trial[.]” The parties thus clearly
contemplated that the Protective Order may be modified in the future and would not…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…Ms. Maxwell’s denial of those statements substantially true.7 Plaintiff has been forced to admit
that her repeated claims and sworn statements that she became a “sex slave” in 1999 when she
was 15 years old are untrue. She…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…called them “sleazy, unprofessional and
unethical.”
The controversy started in December 2014, when Roberts claimed that convicted sex offender Jeffrey
Epstein forced her to have sex with Dershowitz, the U.K’.s Prince Andrew and other men, at Epstein’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…Dershowitz’s
request to modify the Maxwell Protective Order, it will not in the
same breath force him to litigate this action with one arm tied
behind his back.
5 At a hearing before the Court on December 2, 2019…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…this assertion, implying knowledge of the contents of the Sealed Materials,
that alone is a violation of the Protection Order.
As Plaintiff well knows, Ms. Maxwell was forced to answer substantial, numerous, ill-
founded questions regarding her private life, her…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…find her. Jane Doe 43 Dep.
Tr. 177; 257.
x She was forced by Epstein to have sex with other girls and with a colleague of Epstein’s
in his New York mansion. Jane Doe 43 Dep. Tr. 187-192…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…argue that they should be fellow
travelers in this pursuit, lest they “be forced to file a separate suit raising their claims” resulting
in “duplicative litigation” (DE 280 at 11). The Court finds that justice does not require adding
new…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
… Ms. Maxwell was forced
to show the Court all the questions she had answered beyond those authorized by the Court’s
order and the number of repetitive and harassing questions. This submission of the July 2016
transcript to the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…Ms. Maxwell played some
role in Mr. Epstein’s counsel’s refusal to accept service. See Mot. at 2 (“forced to personally
serve the Defendant’s former boyfriend, employer, and co-conspirator”). As the timeline and
documents now reveal, however…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…52-60 (Defendant’s friend’s house manager, through tears, described how Defendant
tried to force a 15 year old Swedish girl to have sex with Epstein through threats and stealing her
passport); Juan Alessi’s June 1, 2016 Dep…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…43 Filed 07/15/21 Page 6 of 12
hasn’t been completed correctly.”)
Ms. Giuffre had to then litigate, extensively, to force Defendant to perform a proper
collection and search, and, correctly, in response to the Motion to Compel…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…argue that they should be fellow
travelers in this pursuit, lest they “be forced to file a separate suit raising their claims” resulting
in “duplicative litigation” (DE 280 at 11). The Court finds that justice does not require adding
new…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…Subpoena (pending). Similarly, the Court will recall that
Ms. Giuffre was recently forced to resort to the Hague Convention in an effort to depose
Maxwell’s spokesman, Ross Gow, about statements he made on Defendant’s behalf. See DE
306…
giuffre-maxwell
gov.uscourts.nysd.447706.563.0
10 pg
…10
Accordingly, the Court will be forced to sort through such issues if it allows
these deposition excerpts to be used at trial. It is far simpler for everyone if the Court simply
requires Defendant to ask questions of Ms…