giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…Eleven
months into this case, and after the close of fact discovery, Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
willful non-compliance, as well as a supplement…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…Eleven
months into this case, and after the close of fact discovery, Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
willful non-compliance, as well as a supplement…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…Eleven
months into this case, and after the close of fact discovery, Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
willful non-compliance, as well as a supplement…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…to “identify[] the most current address available for
[a non-party] in a public records database or other readily
available source.” This will ensure that the notice to non-
parties is “the best practicable under the circumstances.”
Guevoura Fund Ltd…
giuffre-maxwell
gov.uscourts.nysd.447706.724.0
7 pg
…many if not all of the Complaints against Epstein pursuant to his plea agreement
to fund such lawsuits against him were styled as “Jane Doe” to protect the privacy of his
underage victims.
1
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…Case 1:15-cv-07433-LAP Document 1320-24 Filed 01/03/24 Page 3 of 16
TABLE OF CONTENTS
Page
I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL
CLAIMS AND DEFEN…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…Case 1:15-cv-07433-LAP Document 1320-27 Filed 01/03/24 Page 3 of 15
TABLE OF CONTENTS
Page
I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL
CLAIMS AND DEFEN…
giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
1320-27
15 pg
…Case 1:15-cv-07433-LAP Document 1320-27 Filed 01/03/24 Page 3 of 15
TABLE OF CONTENTS
Page
I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL
CLAIMS AND DEFEN…
giuffre-maxwell
1320-24
16 pg
…Case 1:15-cv-07433-LAP Document 1320-24 Filed 01/03/24 Page 3 of 16
TABLE OF CONTENTS
Page
I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL
CLAIMS AND DEFEN…
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…took aim at Annie Farmer, one of Maxwell’s accusers. He said she has sued
Maxwell and is seeking a payout from a fund set up for Epstein’s victims, Cohen said.
Established in May, Epstein’s victims can be…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…Jeffery when he went to trail, made huge endorsements to the Clinton Foundation
to help fund her 2008 presidential campaign.
I personally met Alan numerous times as Jeffery had sent him to my legal aid, to deal with a case…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…right? .. .
THE WITNESS: Fifth.
BY MR. CASSELL:
Q. And you have plenty of money to fund any of the searches that would be
required to produce these documents, right? .. .
3 Defense counsel for Ms. Maxwell raised various "form and foundation…
giuffre-maxwell
gov.uscourts.nysd.447706.378.0
50 pg
…Spin Master Ltd. v. Bureau Veritas Consumer Products Service, Inc.,
2016 WL 690819 (W.D.N.Y., 2016) ....................................................................................... 30
T. Rowe Price Small-Cap Fund, Inc. v. Oppenheimer & Co., Inc.,
174 F.R.D. 38 (S.D.N.Y. 1997)…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…mind’; and
(3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…academicians.” Id. As Mr. Cassell is well aware, Jeffrey Epstein was heavily
involved in funding academic research at Harvard and kept an office there,3 and he was
consequently friendly with many academics, including David Gergen, Marvin Minsky, Larry
Summers…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…York law, it is well-settled that truth is an absolute, unqualified defense to a civil defamation
action. It is an equally fundamental concept that substantial truth suffices to defeat a charge of
libel.” Jewell v. NYP Holdings, Inc., 23…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…mind’; and
(3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…mind’; and
(3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. citing Residential Funding
Corp. v. DeGeorge…