giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…AND HARASS THIS NON-PARTY........................................................18
IV. NON-PARTY MS. RANSOME SHOULD NOT BE FORCED TO INCUR THE
BURDEN AND EXPENSE OF PRODUCING A PRIVILEGE LOG..............................20
V. NON-PARTY MS. RANSOME HAS PRODUCED DOCUMENTS RELEVANT TO
JANE DOE 43…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…Andrew has stepped
forward.
He's accused of having sex with an underage girl in sensational details aired in an
American court case.
The young woman says she was forced to entertain the Duke at the behest of his
friend…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…AND HARASS THIS NON-PARTY........................................................18
IV. NON-PARTY MS. RANSOME SHOULD NOT BE FORCED TO INCUR THE
BURDEN AND EXPENSE OF PRODUCING A PRIVILEGE LOG..............................20
V. NON-PARTY MS. RANSOME HAS PRODUCED DOCUMENTS RELEVANT TO
JANE DOE 43…
giuffre-maxwell
gov.uscourts.nysd.447706.590.1
4 pg
…Andrew has stepped
forward.
He's accused of having sex with an underage girl in sensational details aired in an
American court case.
The young woman says she was forced to entertain the Duke at the behest of his
friend…
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.447706.1201.26
28 pg
…says she was recruited as a slave when 1:39
she was 15, and that she was forced to have sex with both Prince Andrew
and Harvard law profession Alan Dershowitz A lot more Star…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…electronic communications non-party Ransome produced corroborates her testimony
that she was being trafficked by Defendant and Jeffrey Epstein, including being forced to lose
additional weight during the time she was being trafficked in order to meet their demands. For
…
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.447706.751.10
4 pg
…named the prince in a civil motion filed
December 30 in the U.S. District Court in southern Florida in which she claims she was forced to have sex with
several men. She is referred to as Jane Doe No…
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.447706.1325.4
6 pg
…If you do not intend to abide by the representations you made in our conferral, then please advise and we will once again be
forced to seek intervention of the Court. See Local Rule 26.4.
-Laura
From: Meredith Schultz…
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.447706.492.0
9 pg
…the Court will recall, a Defendant’s initial deposition,
. As a result, Ms. Giuffre was forced to file a Motion to Compel Defendant to
Answer Deposition Questions (DE 143). On June 20, 2016, this Court granted Ms. Giuffre’s Motion…
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.447706.1320.18
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.447706.1200.1
8 pg
…10. This deposition is currently scheduled for July 22, 2016. Ms. Giuffre is forced to take this
deposition without the discovery this Court ordered, and therefore, will not be able to depose
Defendant on the wrongfully withheld discovery. Additionally, Ms…
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.447706.1199.1_1
13 pg
…stating “When she awoke, she was lying on the front seat of Kevin's car
with her pants around her ankles and suspect number 2 (the unidentified suspect) on top of her
engaging in forced vaginal intercourse. Said that Kevin…
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