giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…Evidence ........................................................................................................... 2
C. Ms. Maxwell Already Has Fully Responded to All Discovery Requests Relating to
Payments Made to Her By Epstein ...................................................................................... 5
…
giuffre-maxwell
gov.uscourts.nysd.447706.70.0
15 pg
…Ferrante,
No. 13 CIV 4468 VEC, 2014 WL 1327968 (S.D.N.Y. Apr. 3, 2014) .........................................9
In re Payment Card Interchange Fee & Merch. Dis.,
No. MD-05-1720 (JG)(JO), 2007 WL 121426 (E.D.N.Y. Jan. 12…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…cross examination, not one. Any standard of
truth and were used for those who claimed they were victims to receive financial
payment to be shared between them and their lawyers. One firm created and sold
fake cases against Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…15. All Documents reflecting any money, payment, valuable consideration or other remuneration
received by You from Jeffrey Epstein or any person known by You to be affiliated with Jeffrey
Epstein.
RESPONSE:
In addition to the Preliminary Statement and General Objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…15. All Documents reflecting any money, payment, valuable consideration or other remuneration
received by You from Jeffrey Epstein or any person known by You to be affiliated with Jeffrey
Epstein.
RESPONSE:
In addition to the Preliminary Statement and General Objections…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…court; or, if imposed
on motion and warranted for effective deterrence, an order directing
payment to the movant of part or all of the reasonable attorney’s fees and
other expenses directly resulting from the violation.
Fed. R. Civ. P…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…15. All Documents reflecting any money, payment, valuable consideration or other remuneration
received by You from Jeffrey Epstein or any person known by You to be affiliated with Jeffrey
Epstein.
RESPONSE:
In addition to the Preliminary Statement and General Objections…
giuffre-maxwell
1320-28
32 pg
…cross examination, not one. Any standard of
truth and were used for those who claimed they were victims to receive financial
payment to be shared between them and their lawyers. One firm created and sold
fake cases against Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…court; or, if imposed
on motion and warranted for effective deterrence, an order directing
payment to the movant of part or all of the reasonable attorney’s fees and
other expenses directly resulting from the violation.
Fed. R. Civ. P…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…court; or, if imposed
on motion and warranted for effective deterrence, an order directing
payment to the movant of part or all of the reasonable attorney’s fees and
other expenses directly resulting from the violation.
Fed. R. Civ. P…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…all documents concerning any apartment or other dwelling occupied by Plaintiff
from 1999 to the present, including but not limited to, all documents concerning the acquisition
of, and payment for, such dwellings. This Request includes, but is not limited to…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…court; or, if imposed
on motion and warranted for effective deterrence, an order directing
payment to the movant of part or all of the reasonable attorney’s fees and
other expenses directly resulting from the violation.
Fed. R. Civ. P…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…at best, tangentially related to the dispute in this case. And there are ample alternative sources
for the information. (As a starting point, in order to obtain information about payments to, or
contracts or communications with, Ms. Roberts, the obvious…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…January 1, 2015.
5. Identify all payments made or things of value transferred to you by Jeffrey Epstein,
directly or indirectly or through any entity or person affiliated with or controlled by
Epstein, from 1992 through the present, and if…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…specifically discuss sexual trafficking.4 Defendant’s view would exclude from production
documents such as flight manifests listing the girls Defendant flew over to Jeffrey Epstein’s
island, and payments made from Epstein to Defendant for her services. Under Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
… Ultimately, Dershowitz settled the defamation case. That settlement included
both a public statement and confidential monetary payments. As part of the settlement, Edwards
and I withdrew our allegations against Dershowitz in the defamation case contained in the then-
pending summary…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…your or Jeffrey Epstein or any associated
entity from 1999 – present. (No. 9)
All documents relating to payments made from Jeffrey Epstein or any related
entity to you from 1999-present, including payments for work performed, gifts,
3
Interestingly…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…Maxwell already has disclosed that there are no insurance
policies that would be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse
for payments made to satisfy the judgment.
2
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…Maxwell already has disclosed that there are no insurance
policies that would be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse
for payments made to satisfy the judgment.
2
…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…won't be able to see until then if she's paid
15 taxes on all the money and gifts and in-kind payments from
16 Epstein that she's received or has kept that away from the
17 government…
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