giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…BACKGROUND .............................................................................................. 1
III. DISCUSSION ...................................................................................................................... 2
A. Ms. Giuffre’s FBI 302 is Offered to Prove That She Reported Her Alleg…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Additionally, Plaintiffs' counsel have identified
approximately four boxes of documents that they have offered to make available to Dershowitz's
counsel for inspection. vAs of today's date Plaintiffs have produced all documents which are
properly subject to discovery in…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…2) holding that the transcript of Giuffre’s
deposition in a separate action, offered by a third-party in support of a
motion to intervene in this case, was entitled to no more than a “barely
cognizable” presumption of public…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Counsel
for (4) Jeffrey Epstein, offered to accept service on or about April 11 but Plaintiff ignored that
offer for more than six weeks. Plaintiff only began on June 12 any attempt to schedule that
deposition in the Virgin Islands…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…at the hearing, commented on the content of the hearing. As reported by Bloomberg,
Mr. Boies offered his gratuitous critique of defense counsel, commented on the credibility of Ms.
Maxwell and his client, and commented on what Mr. Boies considers…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
…sir.
9 BY MR. CRITTON: 9 Q. If he had offered to do that would you
10 Q. And when we were here, I think it was 10 have read what he wrote down to determine whether
11 last week…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…offered to have sex with
him in exchange for not telling her parents she had failed to go to school that day.
Both Plaintiff and her 17-year old boyfriend verified they had had sexual
intercourse in the days before…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…could not do so
without notice and an opportunity to be heard—only to find out that the testimony she offered
with the district court’s blessing was the primary evidence against her in a criminal case and the
basis…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…reasonable reliance
13 might apply. First, Professor Dershowitz has offered
14 unequivocally -- and subject only to rights he would enjoy
15 anyway, to get the Court to issue a further order changing the
16 status quo, but -- to join the…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…the
20 fact that there was information in this book that Maxwell was
21 knowledgeable of at the time she made her defamatory statement.
22 So not offered for the truth of the fact that the number was
23 one…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…which is next Friday.
3 We also offered to hold that deposition transcript confidential
4 until such time as the protective order could be issued so that
5 there is no barrier to us being able to take this deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…e.g., id. (“[C]ounsel for the [offending party]
offered no explanation or excuse for their failure to comply with the rule's
strictures. They did not attempt to defend the timeliness of their notice. The
[offending party's] admitted…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…and
fondled her breast with his hands as she provided the massage.
stated on one occasion, he offered extra monies to have vaginal
intercourse. She stated this all occurred on the massage table.
• stated Epstein penetrated her vagina with his…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…and
fondled her breast with his hands as she provided the massage.
stated on one occasion, he offered extra monies to have vaginal
intercourse. She stated this all occurred on the massage table.
• stated Epstein penetrated her vagina with his…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…in
an adversarial process. Although affidavits and depositions are
offered “under penalty of perjury,” it is in fact exceedingly rare for
anyone to be prosecuted for perjury in a civil proceeding.45 Similarly,
44 In relevant part, Rule 11 provides…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…which is next Friday.
3 We also offered to hold that deposition transcript confidential
4 until such time as the protective order could be issued so that
5 there is no barrier to us being able to take this deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…photographed, harassed, threatened and offered money in exchange for their refusal to cooperate with the
police investigation.
Former Palm Beach police chief Michael Reiter, who grew increasingly frustrated with the escalating campaign of intimidation
by Epstein’s lawyers, went on…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…
I feel so strongly about taking down these evil cunts, that even if you offered me enough
money to buy the biggest Super Yacht in the world, which would give me the ability to hire
and then fire all the…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
… id. at 17:5 (“I
produced 3,000 pages”). She also offered to produce any documents that she intended to “use”
at the March 25 deposition.
Counsel engaged in a conferral on March 21, 2016, regarding the deficiencies in
Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…273 F.3d at 233. The references to the various
attached exhibits were gratuitous and served no legitimate purpose related to the discovery
dispute. During the course of this litigation Plaintiff offered, on more than one occasion, various
iterations and…