giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…well-crafted with the assistance of high-priced attorneys to facilitate Giuffre’s
media exposure, to enhance her marketability, to extract financial gain for herself and her family,
and to promote her sham non-profit, Victims Refuse Silence, Inc.
2…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…producing no more money,
Ms. Giuffre wants to use its information to profit from generating new lawsuits—and media
coverage—through her well-worn strategy: Accuse a prominent person of participating in
Epstein’s misconduct; if they deny the allegations…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.14_1
11 pg
…him a
Page 270
1 G Maxwell - Confidential
2 A. She helps with my not-for-profit
3 ocean foundation and any other related
4 activities that I may have.
5 Q. Is she paid for by Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.21
11 pg
…4 of 11
Page 270
1 G Maxwell - Confidential
2 A. She helps with my not-for-profit
3 ocean foundation and any other related
4 activities that I may have.
5 Q. Is she paid for by Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…citation omitted). “In assessing the amount of damages to award for
defamation, a jury is not limited to compensating the plaintiff for ‘economic’ losses, such as
demonstrable lost profits. Rather, a plaintiff may suffer ‘non-economic’ injuries as well. Among
…
giuffre-maxwell
gov.uscourts.nysd.447706.599.0
12 pg
…injuries. In contrast, Taylor does not offer opinions that fall within the competence of an
accountant, such as financial reports and loss/profit ledgers. Instead, he ventures far afield
.
Such is the stuff of an attorney’s closing argument, not…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…Giuffre publicly and falsely accused
Professor Dershowitz of sex crimes, then spent years attempting to profit from those allegations
and disseminate them as widely as possible. She now seeks to hijack this Court’s Article III
powers to hamstring Professor…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…been produced. Plaintiff also produced an email to but not any
response to that email.
The iCloud account also discloses a previously undisclosed potential witness,
, a person working at a not-for-profit relating to sexual trafficking victims. Apparently, in…
giuffre-maxwell
gov.uscourts.nysd.447706.509.0
18 pg
…at 86, since it is difficult to prove what is contained in
documents that have been destroyed. To require a detailed showing in such circumstances poses
the danger that “the spoliator [may] profit from its” own misconduct. Id. (quoting Orbit…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…The deposition was
cancelled. Yet a short time later, Maxwell was photographed at a high-profile wedding in
Rhinebeck, New York, confirming the suspicion that she was indeed still in the country and
willing to say virtually anything in order…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.5
12 pg
…evidentiary, as to the facts alleged in the
pleading.”
2
In actuality, it appears that the very purpose of Plaintiff’s inclusion in the CVRA action of explicitly
detailed allegations of sexual interaction with high profile individuals including Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…at 86, since it is difficult to prove what is contained in
I documents that have been destroyed . To require a detailed showing in such circumstances poses
the danger that "the spoliator [may] profit from its" own misconduct. Id. (quoting…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…and consequential damages.” Compl. Count 1 ¶ 19. Further, Plaintiff
claims she “incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for-
profit corporation” on December 23, 2014, approximately 10 days before the January 3
Statement. Compl. ¶¶ 24-25…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…held
that a decision by a state’s highest court “not only direct[ing] a transfer of
property, but also order[ing] an accounting of profits from such property”
was “final,” notwithstanding that the order clearly contemplated ongoing
proceedings. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…held
that a decision by a state’s highest court “not only direct[ing] a transfer of
property, but also order[ing] an accounting of profits from such property”
was “final,” notwithstanding that the order clearly contemplated ongoing
proceedings. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…15, 2021) (rejecting
concerns about media attention as basis to testify under pseudonym because “these generalized
concerns are present in every high-profile criminal case”).
Accordingly, the Court should overrule the objections of Doe 133 and unseal the judicial
documents…
giuffre-maxwell
gov.uscourts.nysd.447706.515.0
12 pg
…evidentiary, as to the facts alleged in the
pleading.”
2
In actuality, it appears that the very purpose of Plaintiff’s inclusion in the CVRA action of explicitly
detailed allegations of sexual interaction with high profile individuals including Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…As a Retained Expert, Phillip Esplin Cannot Be Deemed Unavailable ............................... 3
II. TESTIMONY IN WHICH WITNESS REFUSED TO RESPOND TO QUESTIONS
POSED IS IRRELEVANT, MORE PREJUDICIAL THAN PROBITIVE, AND MUST BE
EXCLUDED FROM TRIAL ..............................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…N.Y. Dec. 15, 2021) (rejecting concerns about media attention as basis to testify under
pseudonym because “these generalized concerns are present in every high-profile criminal case”).
Accordingly, the Court should overrule the objections of Does 12, 28, 97…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…Ms. Maxwell rightfully remains skeptical of
Plaintiff’s ability to abide by the terms of this Court’s Protective Order when it comes to
confidential financial information.
In other cases involving higher profile individuals and matters, the courts have been…
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