giuffre-maxwell
gov.uscourts.nysd.447706.751.9
3 pg
…in London after visiting his
father Prince Philip. (AP)
Buckingham Palace officials have again denied claims made by a woman who alleged that she was forced to have
sex while underage with Prince Andrew, Duke of York.
The second denial…
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.447706.1218.42
9 pg
…is demanding his name be
removed from her lawsuit and is asking for damages. Roberts says that a wealthy
investor forced her into sex slavery when she was a teenager to please his powerful
friends, including Dershowitz and Prince Andrew…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.16
8 pg
…Did Jeffrey Epstein tell you, thnt when
21 of Jeffrey Epstein sexunlly molesting her, 21 E.W. wns 1111 underage minor female, he forced her
22 correct? 22 to give him oral sex?
23 MR. VAREMA : Object to the form. …
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.447706.1295.5
12 pg
…denial of which by Ms. Maxwell gave rise to this litigation. As soon as Plaintiff
formed her intent to join or participate as a witness in the CVRA action, her duty to preserve this
evidence attached. She then either lost…
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.447706.1320.18
40 pg
…For example, Jane Doe 3 alleged that she had been forced by Epstein to have sexual
relations with various persons, including Alan Dershowitz – who had been one of Epstein’s
defense attorneys negotiating the non-prosecution deal and arranging to…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Plaintiff
claimed she had been forcibly sexually assaulted by her friends. Plaintiff’s claim
of forced sexual assault was expressly refuted by the witnesses, who also verified
Plaintiff’s attempt to get out of trouble by offering to have sex…
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.447706.1320.9
10 pg
…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 of Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…Epstein asserted his Fifth Amendment privilege. No
different result would obtain were Mr. Epstein forced to take the stand and assert his Fifth
Amendment privilege in front of the jury. Plaintiff seeks to call Mr. Epstein as a witness in…
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.447706.1328.21
19 pg
…Palm's West
Hospital in reference to a suspicious incident. The juvenile victim,
~ was transported to the hospital-Royal Palm Beach
~ There were allegations made by that she
may have been forced to have sex. (See original report.
…
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.447706.562.2
29 pg
…2015). And yet a flight log shows Dershowitz on a flight with a young woman
named "Tatianna." Dershowitz also was forced to admit in his deposition that whenever he met
with Epstein, part ofthe Epstein "entourage were woman whom he…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…point. But now that those accusations have been made—in
public and in court papers, again and again—Professor Dershowitz cannot be forced to respond
with one rhetorical hand tied behind his back. The motion should be granted.
ARGUMENT
I…