giuffre-maxwell
gov.uscourts.nysd.447706.363.9
5 pg
…in Judge Freeh’s professional opinion, “The
totality of the evidence found during the investigation refutes the allegations made against
Professor Dershowitz.”
STATEMENT OF LOUIS J. FREEH
Over the past several months, an independent investigation was conducted, under my
supervision…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…Order.
INTRODUCTION
The Protective Order requires the destruction or return of all “Confidential”-designated
materials. This action was terminated more than eighteen months ago when the parties reached a
settlement and stipulated to dismissal, and the Court dismissed the case…
giuffre-maxwell
gov.uscourts.nysd.447706.34.2
3 pg
…opportunities.
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giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…client’s allegations that Dershowitz had sexual relations with her
when she was a minor. Settlement talks in the defamation case have been going on for months,
and the two sides just reached agreement.
Shortly before 5 p.m. today…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…before returning with cash.
He did say that she tried to get out of the sex business, but was dragged back in.
Last month it was revealed Roberts accused two male acquaintances she was raped, bringing her credibility into
1…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 8 of 161
It raises serious questions as to why Maxwell, whose whereabouts have been a mystery for
months, has never been charged with any wrongdoing…
giuffre-maxwell
gov.uscourts.nysd.447706.1227.0
2 pg
…1226 at 2, 3. As Plaintiff clearly laid out in a letter
submitted to the Court nine months ago, because the Court is currently proceeding through the
unsealing process on a Doe-by-Doe basis, the Original Parties’ understanding is…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…In fact, for the most part, her failures to actively
pursue depositions with these witnesses qualifies as in-excusable neglect: She frittered away
seven of the eight months of the discovery period and now has placed Ms. Maxwell, this Court…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…admission pro hac vice appear to be inaccurate, this consolidated reply is
being filed to clarify a few points of law and fact.
II. ARGUMENT
For many months now, Professor Cassell and Mr. Edwards have actively worked to help
represent…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
…pick those names, were
5 Mr. Rodriguez stated he was employed by Jeffrey 5 they associated with Mr. Epstein?
6 Epstein for approximately six months. 6 A. Yes.
7 I think we already talked about that. 7 Q. And what…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…id. ¶¶ 5(a)-(h)).
The protective order has been a primary theater of battle in
this litigation over the past several months.1 Most notably, it
has been the subject of two separate requests seeking modification
brought by Alan Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…agreement
among them, but she refuses to disclose the joint defense agreement, and this Court, months ago, has
already ordered Defendant to turn over her communications with Epstein and Dershowitz that she
purported were privileged. (See April 15, 2016 Order…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…2014, despite having had four months to provide a
position, the Government responded by email to counsel that it was seeking more time,
indicating that the Government understood that victims’ counsel might need to file a motion with
the court…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…ARGUMENT
I. PLAINTIFF’S VIOLATION OF THIS COURT’S ORDER TO PRODUCE
DOCUMENTS IS NOT AN OPPORTUNITY FOR HER TO RE-LITIGATE
THE ISSUE.
Plaintiff has been attempting to dodge the production of these documents for months.
First, Plaintiff claimed…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…agreement
among them, but she refuses to disclose the joint defense agreement, and this Court, months ago, has
already ordered Defendant to turn over her communications with Epstein and Dershowitz that she
purported were privileged. (See April 15, 2016 Order…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…projected trial date in the fall, while Defendant has repeatedly
attempted to stall progress1.
Defendant’s deposition is currently set to be taken on Friday, April 22 – many months
after Ms. Giuffre filed her complaint. Defendant’s deposition has not…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.11
9 pg
…it failed to list verbatim any such
allegedly unanswered discovery request, as required by local rule. Additionally, discovery closed
nearly eight months ago, and trial is 60 days away.
Substantively, the Motion to Compel is facially frivolous. It argues Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…production of documents on defendant on October 27,
2015. Now, almost four (4) months later, and even after this Court denied defendant’s attempts
to stay discovery and directed a response, defendant is still refusing to produce highly relevant
documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…In fact, for the most part, her failures to actively
pursue depositions with these witnesses qualifies as in-excusable neglect: She frittered away
seven of the eight months of the discovery period and now has placed Ms. Maxwell, this Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…about whether Dershowitz had been involved
with massages by young girls;
x refusals by Jeffrey Epstein to discuss Dershowitz’s involvement but instead to
invoke his Fifth Amendment right.
-
Id. at 26-38.
Several months later, on April 7, 2015…
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