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.447706.130.0
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.447706.443.0
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.447706.34.2
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.447706.1198.13_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.447706.1227.0
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.447706.1295.11
19 pg
…Plaintiff, also counsel for non-party witness Sarah Ransome, in mid-January
belatedly disclosed a “new witness” counsel apparently had known about for months.2 Plaintiff
then asked this Court to re-open discovery for the deposition of Ms. Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.269.0
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.447706.751.9
3 pg
…deal that allowed Epstein to avoid much more serious federal charges and potentially longer prison time.
Epstein served 13 months of an 18-month sentence after pleading guilty to a single charge of soliciting prostitution
before being released in 2009…
giuffre-maxwell
gov.uscourts.nysd.447706.1228.0
4 pg
…Similarly, the replies of the non-parties would have been
submitted at least six months ago and thus the issues would have been at least fully briefed. But,
because of the modification requested by the original parties after the Protocol…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…Plaintiff, also counsel for non-party witness Sarah Ransome, in mid-January
belatedly disclosed a “new witness” counsel apparently had known about for months.2 Plaintiff
then asked this Court to re-open discovery for the deposition of Ms. Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.441.0
18 pg
…ex ecu ted a release and requ est for
record s from over fou r months ago,on M ay 9,20 16.O n M ay 25,20 16,M s.Giu ffre
prod u ced the requ estto …
giuffre-maxwell
gov.uscourts.nysd.447706.1008.0
5 pg
…Act of 1990 requires the Administrative Office of the United States Courts to prepare a semiannual
report summarizing judicial inaction, including motions pending more than six months and civil
cases pending more than three years. See 28 U.S.C…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…so I
8 can't remember that number offhand.
9 Q. How long did you have that
10 cell phone?
11 A. About eight months.
12 Q. What happened to it?
13 A. I got rid of it.
14 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…among others, that: (1) the government did not move to seal the state-court
records until they had already been publicly available on the federal docket for eight months; (2) the government
made a conclusory claim that mere redactions were…
giuffre-maxwell
gov.uscourts.nysd.447706.587.0_2
10 pg
…a motion for sanctions.
14 We have a separate trial in this case in March and they waited
15 until nine months after they first raised the issue to bring it
16 to the Court's attention with this motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1042.0
2 pg
…response time for any Non-party objections, as well as for responses to
objections and replies. This will prolong the process into a months-long endeavor. The Second
Circuit’s ruling in this matter was issued on July 2, 2019…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…Churcher has continued to cover this story as
9 a reporter, has published stories, including just I think two
10 months ago, often using "Virginia" or her so-called agents as
11 sources, of course most prominently in early 2015…
giuffre-maxwell
gov.uscourts.nysd.447706.121.0
10 pg
…expended considerable sums of
money and considerable time to ensure Ms. Giuffre’s compliance with her discovery obligations.
(DE 96 at 7.) Fact discovery closes in less than two months, and Defendant has yet to disclose
information about what was…
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