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.447706.233.0
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.447706.363.11
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.447706.1199.16_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.447706.1218.43
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
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.447706.1218.24
4 pg
…She also added
details about her allegations that Epstein -- who served 13 months in jail after being convicted of soliciting a
minor for sex in 2008 -- ordered her to have sex on three occasions with Prince Andrew in London at…
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.447706.1328.26
6 pg
…01/05/24 Page 4 of 6
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.447706.1161.0_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.447706.1219.22
22 pg
…(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, on April 28, 2016, the New York Post reported that
2
As recently…
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.447706.1218.30
4 pg
…She also added
details about her allegations that Epstein -- who served 13 months in jail after being convicted of soliciting a
minor for sex in 2008 -- ordered her to have sex on three occasions with Prince Andrew in London at…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…(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, on April 28, 2016, the New York Post reported that
2
As recently…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…since Epstein was
investigated and charged by the Palm Beach police department, ultimately copping a plea and serving 13 months on one charge of soliciting
prostitution from a 14-year-old girl, Patterson has remained obsessed with the case.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.11
11 pg
…01/05/24 Page 5 of 11
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.447706.590.1
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…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…pleaded guilty June 30, 2008 in Palm
Beach Circuit Court to two felonies: procuring a person under 18 for prostitution and offering to commit prostitution.
He served 13 months of an 18-month sentence. The Palm Beach Daily News has…
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