giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…OF AUTHORITIES ...................................................................................................... iii-v
PRELIMINARY STATEMENT .....................................................................................................1
FACTUAL AND PROCEDURAL BACKGROUND.................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…Buckingham Palace issued a statement which said, "It is emphatically denied that the Duke of
York [Andrew] had any form of sexual contact or relationship" with the woman. "Any claim to the contrary is false and
without foundation."
Andrew is…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…TO SHOW THAT CHURCHER WAS NOT
ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3
A. The “Primary Relationship” Between Churcher and Plaintiff Was
Reporter and Source ...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.263.0
14 pg
…TO SHOW THAT CHURCHER WAS NOT
ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3
A. The “Primary Relationship” Between Churcher and Plaintiff Was
Reporter and Source ...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.6
32 pg
…AUTHORITIES ...................................................................................................... iii-v
PRELIMINARY STATEMENT .....................................................................................................1
FACTUAL AND PROCEDURAL BACKGROUND...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…the police reports demonstrate Plaintiff’s tumultuous
home life, bearing no relationship to any press statements or alleged defamation and providing
alternative causation to any of Plaintiff’s now-claimed emotional distress. It makes perfect sense
that Plaintiff would want…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.14_1
11 pg
…12 Q. Do you know
13 A. I do.
14 Q. What is your relationship with
15
16 MR. PAGLIUCA: Object to the form.
17 A. What do you mean what is my
18 relationship.
19 Q. Are you friendly…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.26
4 pg
…given his
relationship with Ross and Diane Sawyer.
It was during a Sawyer interview on ABC’s PrimeTime Live that the ex-cop said he was sorry for remarks he made that may
have influenced the jury to acquit Simpson…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.19
15 pg
… I don't recollect, and I don't
8
9
10
to what
Jeffrey.
-
recollect how I met
-
and I can't testify
relationship is or is not with
11 Q. Have you ever talked to Jeffrey
12
13
14…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…satisfied .................................................. 18
III. There is No Privilege as to Communications with Scarola ............................................ 22
a. There is no Attorney-Client Relationship .......................................................................... 22
b. Work Product Privilege has…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…satisfied .................................................. 18
III. There is No Privilege as to Communications with Scarola ............................................ 22
a. There is no Attorney-Client Relationship .......................................................................... 22
b. Work Product Privilege has…
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…TO SHOW THAT CHURCHER WAS NOT
ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3
A. The “Primary Relationship” Between Churcher and Plaintiff Was
Reporter and Source ...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.21
11 pg
…Q. Do you know Glenn Dubin?
13 A. I do.
14 Q. What is your relationship with
15 Glenn Dubin?
16 MR. PAGLIUCA: Object to the form.
17 A. What do you mean what is my
18 relationship.
19 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.8_3
9 pg
…full seven hours. Ms. Maxwell did not assert any
privilege against self -incrimination and was questioned extensively about, among other things:
her relationship with Jeffrey Epstein, her knowledge of “sexual trafficking”, sex with minors,
non-consensual sex, sex involving the…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…a-predator-as-jeffrey-epstein-author/ar-BB1aNWEb
26 https://www.today.com/video/ghislaine-maxwell-deposition-gives-insight-into-epstein-relationship-94465093962
27 https://pagesix.com/2020/10/26/alan-dershowitz-seeks-to-unredact-name-in-ghislaine-maxwell-deposition/
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…the police reports demonstrate Plaintiff’s tumultuous
home life, bearing no relationship to any press statements or alleged defamation and providing
alternative causation to any of Plaintiff’s now-claimed emotional distress. It makes perfect sense
that Plaintiff would want…
giuffre-maxwell
gov.uscourts.nysd.447706.751.9
3 pg
…owned by Epstein.
A Palace spokesman has said that the allegations are "false and without any foundation."
"It is emphatically denied that the Duke of York had any form of sexual contact or relationship with (the woman)," the
statement continued…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…documents. Defendant acknowledges that she has other responsive
documents, but she is withholding them from production.2
Flight logs demonstrate the incredibly close relationship between Defendant and
convicted pedophile Jeffrey Epstein during the time they were abusing Ms. Giuffre and…
giuffre-maxwell
gov.uscourts.nysd.447706.211.0
16 pg
…LAP Document 211 Filed 06/14/16 Page 13 of 16
drawing of adverse inferences is admissible, court may consider the following nonexclusive
factors:
(1) nature of witness’ relationship with and loyalty to party;
(2) degree of control which party…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…the district court did not
rely on it in granting the motion; (3) finding that as to parts of defendant
Ghislaine Maxwell’s deposition concerning her sexual relationships with
consenting adults, her privacy interests outweighed any presumption of
public access…
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