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.447706.269.0
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.447706.996.0
14 pg
…about her
alleged sexual encounters with ever more prominent men. Whenever anyone denies her
allegations, she and her coterie of lawyers threaten to sue or sue for tens of millions of dollars for
“defamation.” Mr. Dershowitz find himself, as Ms…
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.447706.1219.30
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.447706.64.0
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.447706.1354.0
7 pg
…Earlier today, the DOJ released an additional
three million pages of Epstein-related records.
4
Maxwell’s counsel asserts that many John Does “relied” on the Protective Order (Dkt. 62) in this case and therefore
require an opportunity to object…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…of resources, but as this Court is
aware, Defendant is a wealthy socialite (wbo recently sold her New York Townhome for $15
million dollars) who has heavily litigated this case in ways that were completely unnecessary. 2
Moreover, deposition discovery…
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.447706.235.1
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…
giuffre-maxwell
gov.uscourts.nysd.447706.136.0_2
29 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.447706.1218.49
27 pg
…This allegation, and
the string of inferences necessary to make it “work,” is patently absurd. Millions of people were
present in the New York City area when Ms. Giuffre travelled there; it is simply not reasonable
to infer from my…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…burden must take into account the scope of the underlying case. Ms. Giuffre
is seeking both compensatory and punitive damages that would total millions of dollars. Against
that backdrop, a handful of additional depositions cannot be seen as unduly burdensome…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.26
4 pg
…has another book to flog.
TIDBITS
It’s official. Daytime talker Rosie O’Donnell will be a celeb contestant on ABC’s Who Wants to Be a Millionaire.
O’Donnell, who was a ``phone-a-friend’’ on an earlier show…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…of evidence: depositions are needed.
Third, the burden and expense of this proposed discovery is limited to three additional
depositions. Defendant in this case is a multi-millionaire with able counsel. Three depositions
will not cause her undue burden, expense…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…evidence: depositions ar e needed.
Third, the bmden and expense of this proposed discovery is limited to three additional
depositions. Defendant in this case is a multi-millionaire with able counsel. Three depositions
will not cause her undue bmden, expense…
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