giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…states as follows:
INTRODUCTION
Plaintiff comes to this Court – for the third time – seeking to reopen the deposition of Ms.
Maxwell based on the production of two innocuous documents which she received more than
two months ago on August 16…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…by and through her undersigned counsel, hereby files this
Supplement to her Motion for Adverse Inference Instruction Based on New Information. Eleven
months into this case, and after the close of fact discovery, Defendant continues to refuse to
abide by…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…by and through her undersigned counsel, hereby files this
Supplement to her Motion for Adverse Inference Instruction Based on New Information. Eleven
months into this case, and after the close of fact discovery, Defendant continues to refuse to
abide by…
giuffre-maxwell
gov.uscourts.nysd.447706.130.0
5 pg
…Plaintiff, forthwith, to deliver any “materials” to
the Defendant for the following reasons:
For months Ms. Maxwell has been requesting documents from the Plaintiff relating to her
claim that there is an ongoing and active criminal investigation in which Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…by and through her undersigned counsel, hereby files this
Supplement to her Motion for Adverse Inference Instruction Based on New Information. Eleven
months into this case, and after the close of fact discovery, Defendant continues to refuse to
abide by…
giuffre-maxwell
gov.uscourts.nysd.447706.443.0
4 pg
…Plaintiff, Ms. Giuffre, by and through her undersigned counsel hereby gives this Court
notice of a related action, and states as follows.
For many months, Ms. Giuffre has attempted to serve process on Defendant’s press
agent, Ross Gow, who…
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.
• See who you know in common
• Get introduced
• Contact Ross directly
Experience
Owner, Managing Partner
ACUITY Reputation
January 2010 – Present (6 years 2 months)
ACUITY advises Governments, Corporates and UHNWIs on reputational issues
Skills
Public Relations Marketing …
giuffre-maxwell
gov.uscourts.nysd.447706.233.0
9 pg
…files this
response to Jeffrey Epstein’s motion to quash a subpoena calling for his testimony. Having
spent months attempting to avoid service of a subpoena, Epstein claims that it will now be an
“undue burden” to answer questions at…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
… They
22 have been working with her. They had been working on this
23 matter for many months now. We need them as counsel of record
24 in the case now because we are going to have depositions
25 throughout…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…01/05/24 Page 4 of 40
97
1 Q Was it earlier in the time you were with
2 her, or...
3 A It was about -- I'd say about six months
4 or so. I don't know…
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.447706.1257.22
40 pg
…05/03/22 Page 4 of 40
97
1 Q Was it earlier in the time you were with
2 her, or...
3 A It was about -- I'd say about six months
4 or so. I don't know…
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.447706.1198.13_1
19 pg
…this claim. As she now admits, Plaintiff only began to request her
own medical records on April 5, 2016 – 15 months after the supposed defamation, 8 months after
filing suit, 8 weeks after the defense requested the records, 2 weeks…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…Ghislaine Maxwell, March 2, 20161
Less than six months after representing to this Court that this case involves “highly
personal and sensitive information” warranting a broad protective order, Defendant now wants to
publicize police reports concerning Ms. Giuffre - most of…
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.447706.1218.43
4 pg
…isn't in dispute is that Prince Andrew and Jeffrey Epstein
were good friends over a number of years.
In 2008, Mr Epstein was sentenced to 18 months' jail for soliciting an underage girl
for the purposes of prostitution. That…
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