giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…in which she works – the U.S.
Attorney’s Office for the Southern District of Florida – has been recused by the Justice
Department “from prospective responsibility for any criminal investigation or potential
prosecution relating to Jeffrey Epstein’s alleged sexual…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…in this case, (b) the fact the information can be obtained from other sources,
1
Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to
her, as the actual transcript amply demonstrates. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…late production of important emails. These two issues developed as follows.
Defendant’s Failure to Answer Certain Questions
During her first deposition, Defendant improperly refused to answer certain questions.
Accordingly, the Court ordered a second deposition, directing the Defendant to…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…that substantial portions of her story are untrue; she has so far
refused to say under oath what other lies printed by the press about her story are untrue, but has
admitted that journalist Sharon Churcher “got it wrong.” For…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…accepts the interview request by January 19.
The attorney for her legal team confirmed to CNN that Buckingham Palace had refused to accept the letter to Prince
Andrew and that it was returned to them.
Buckingham Palace didn't respond…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…her to Epstein’s mansions to be sexually abused. At several points during her recent
deposition, Ms. Maxwell refused to answer Ms. Giuffre’s questions about Epstein, but instead
told her she should go ask Epstein about the subject. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…that substantial portions of her story are untrue; she has so far
refused to say under oath what other lies printed by the press about her story are untrue, but has
admitted that journalist Sharon Churcher “got it wrong.” For…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…...........................................................8
E. Plaintiff Has Not Refused To Provide Addresses And Telephone Numbers ..............10
F. Defendant Is Not Prejudiced And She Has Not Made A Showing of Prejudice.........11
CONCLUSION ..............................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…ARE HIGHLY RELEVANT TO MS. RANSOME’S TESTIMONY
IN THIS ACTION ................................................................................................................... 5
III. MS. RANSOME UNJUSTIFIABLY REFUSED TO ANSWER RELEVANT DEPOSTION
QUESTIONS, AND SHE MUST BE COMPELLED TO RE-APPEAR AND RESPOND . 10
IV. MS. RA…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…directed Maxwell to sit for her deposition on April 22, 2016. During her deposition
Defendant refused to answer the majority of the questions asked or stated that she had no
memory of any of the events. As a result, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…in this case, (b) the fact the information can be obtained from other sources,
1
Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to
her, as the actual transcript amply demonstrates. Ms…
giuffre-maxwell
1320-8
12 pg
…her to Epstein’s mansions to be sexually abused. At several points during her recent
deposition, Ms. Maxwell refused to answer Ms. Giuffre’s questions about Epstein, but instead
told her she should go ask Epstein about the subject. See…
giuffre-maxwell
1320-20
11 pg
…in this case, (b) the fact the information can be obtained from other sources,
1
Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to
her, as the actual transcript amply demonstrates. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…2
B. 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.447706.189.0
11 pg
…in this case, (b) the fact the information can be obtained from other sources,
1
Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to
her, as the actual transcript amply demonstrates. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…unavailing.
First, Ms. Giuffre is entitled to question the Defendant on
Defendant’s press agent who she refused to produce
for a deposition, despite him being her agent and despite their sharing the same attorney, forcing Ms.
Giuffre to litigate…
giuffre-maxwell
gov.uscourts.nysd.447706.199.0
8 pg
…Than Personal Service, and [DE 161] Declaration of Sigrid McCawley in Support of Plaintiff’s
Motion for Leave to Serve Three Deposition Subpoenas By Means Other Than Personal
Service.) Mr. Epstein refused to accept service, thereby forcing Ms. Giuffre to…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…ARE HIGHLY RELEVANT TO MS. RANSOME’S TESTIMONY
IN THIS ACTION ................................................................................................................... 5
III. MS. RANSOME UNJUSTIFIABLY REFUSED TO ANSWER RELEVANT DEPOSTION
QUESTIONS, AND SHE MUST BE COMPELLED TO RE-APPEAR AND RESPOND . 10
IV. MS. RA…