giuffre-maxwell
gov.uscourts.nysd.447706.1198.17
3 pg
…Statement Truth Sources
March 16 Refusal to identify any health Privilege waived by Plaintiff when Plaintiff’s Responses &
care providers or records because suing for $30 million of medical and Objections to First
“pr…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.13_1
19 pg
…with Court Order and Failure to Comply with Rule 26(a) (“Response”), as follows:
INTRODUCTION
Plaintiff filed this Complaint in September 2015 seeking $30 million of non-economic
damages related to her psychological damage from a defamation which, she claims…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…filed her
lawsuit against Defendant here in the Southern District of New York. (DE 1.) Ms. Giuffre is
seeking at least $50 million in compensatory and punitive damages from Ms. Maxwell. Just a
few months after the suit was filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…filed her
lawsuit against Defendant here in the Southern District of New York. (DE 1.) Ms. Giuffre is
seeking at least $50 million in compensatory and punitive damages from Ms. Maxwell. Just a
few months after the suit was filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…that Ms. Maxwell had subjected plaintiff to “sex trafficking” while Plaintiff was 15 years old.
Plaintiff alleged in her Rule 26(a)(1)(A)(iii) disclosures that she has suffered noneconomic injury
of “not less than” $30 million, medical expenses…
giuffre-maxwell
gov.uscourts.nysd.447706.269.0
19 pg
…with Court Order and Failure to Comply with Rule 26(a) (“Response”), as follows:
INTRODUCTION
Plaintiff filed this Complaint in September 2015 seeking $30 million of non-economic
damages related to her psychological damage from a defamation which, she claims…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…that Ms. Maxwell had subjected plaintiff to “sex trafficking” while Plaintiff was 15 years old.
Plaintiff alleged in her Rule 26(a)(1)(A)(iii) disclosures that she has suffered noneconomic injury
of “not less than” $30 million, medical expenses…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…2001 she was sharing a Palm Beach apartment with Anthony Valladares. He told the Daily News that she
bragged about going to the 'millionaire's house' for a day or two, before returning with cash.
He did say that she…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…13 time that she knew Mr. Epstein, and it certainly relates to all
14 of her requests for, I believe she has requested $30 million in
15 damages, your Honor, not just from the defamation, but also
16 harkening back…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…show Bill Clinton aboard the plane with Kevin Spacey and Charles Tucker is not great': Charlie
Sheen 'to sell 2 of his 3
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…Ms. Maxwell
should have to provide the same information. Of course, Plaintiff seeks over $80 Million dollars in compensatory
damages based on her alleged loss of reputation and emotional distress, putting her personal financial information
directly at issue. Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…be more then willing to swear under oath and testify in court
over these sex tapes. It will break your heart into a million tiny pieces Maureen when you watch this
footage, and I know that what I watched yesterday…
giuffre-maxwell
gov.uscourts.nysd.447706.64.0
14 pg
…as Ex. B. to the
Menninger Decl. Each of those figures and particularly the fantastical $5 million, $30
million and $50 million “estimates” are completely unsupported.
Four months later, Plaintiff’s supplemented disclosures state that she suffered: (A)
“Physical, psychological…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…her prior wages (if any), her bases for
claiming $30 million in non-economic damages. Plaintiff has admitted that some of the treating
professionals she will be relying on live in Australia but said she couldn’t understand why we…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…in his review. The alleged unique users,
6 which is his phrase for somebody who went on a website
7 somewhere, is more than 10 million more, and the other number,
8 which is the number of publications, has also…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.40
30 pg
…13 time that she knew Mr. Epstein, and it certainly relates to all
14 of her requests for, I believe she has requested $30 million in
15 damages, your Honor, not just from the defamation, but also
16 harkening back…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…in his review. The alleged unique users,
6 which is his phrase for somebody who went on a website
7 somewhere, is more than 10 million more, and the other number,
8 which is the number of publications, has also…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…D
terminal’s site and caused injuries to individuals and very significant damage to
properties in the area. Several hundred million pounds are claimed. There is to be
a trial of preliminary issues before David Steel J in October 2008…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…the Mike Cernovich Podcast.
See Declaration of Michael Cernovich (“Declaration”) at ¶ 3. His broadcasts on Periscope have
over 63,000 subscribers and 13 million “likes”, and are watched by tens-of-thousands of people
per episode.1 See id. at …
giuffre-maxwell
gov.uscourts.nysd.447706.235.1
31 pg
…13 time that she knew Mr. Epstein, and it certainly relates to all
14 of her requests for, I believe she has requested $30 million in
15 damages, your Honor, not just from the defamation, but also
16 harkening back…
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