giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…Id.
(suggesting limitations on searches of names to “make some effort to match them to actual
people who have some relationship to this case (like first name /3 last name or some parts
thereof)”).
After explaining the appropriate and well…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…Id.
(suggesting limitations on searches of names to “make some effort to match them to actual
people who have some relationship to this case (like first name /3 last name or some parts
thereof)”).
After explaining the appropriate and well…
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.447706.1331.36
10 pg
…draw adverse inferences against a party based on a witness’
invocation of his Fifth Amendment privilege:
1. The Nature of the Relevant Relationships: While no particular relationship governs, the
nature of the relationship will invariably be the most significant circumstance…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Id.
(suggesting limitations on searches of names to “make some effort to match them to actual
people who have some relationship to this case (like first name /3 last name or some parts
thereof)”).
After explaining the appropriate and well…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…the basis of this suit. Apait from the
Defendant and Mr. Epstein, is a key person who can provide
infonnation about his close relationship with Defendant and Mr. Epstein and disapprove
Ms. Maxwell's claims.
Ms. Giuffre is still working…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…Document 1137-18 Filed 10/22/20 Page 7 of 15
Defendant and Mr. Epstein, fo1mer is a key person who can provide
info1mation about his close relationship with Defendant and Mr. Epstein and disapprove
Ms. Maxwell's claims.
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…to ask whether or not they really had a
3 conversation with my client or not?
4 She testified at first that she doesn't have a
5 relationship with those parents anymore. She doesn't speak to
6 them…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…16 Filed 10/22/20 Page 12 of 15
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 has vested…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…damage Ms. Giuffre’s reputation. They also reveal that Defendant’s
defamatory statements are not “substantially true.” The joint defense agreement(s) show
Defendant’s ongoing and continued relationship with Dershowitz and Epstein, which is relevant
to her defenses. Both…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…Fontanella, and Michael Reiter.
2
x In a 2011 interview, Ms. Giuffre mentioned former President Bill Clinton’s close
personal relationship with Defendant and Jeffrey Epstein. While Ms. Giuffre made no
allegations of illegal actions by Bill Clinton, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.515.0
12 pg
…“While Ms. Roberts said there was never any sexual relationship between the
Prince and herself, she claims that as a 17-year-old she met the Prince on three occasions - at one of which she was
told to sit on…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.19
22 pg
…22
1 a 3. I think it's
I . I really can't make out
3 the telephone number.
4 Q Okay. Do you see Relationship? Can you
5 read that?
6 A Friend.
7 Q Okay. Do you see…
giuffre-maxwell
1320-19
22 pg
…22
1 a 3. I think it's
I . I really can't make out
3 the telephone number.
4 Q Okay. Do you see Relationship? Can you
5 read that?
6 A Friend.
7 Q Okay. Do you see…
giuffre-maxwell
1320-21
15 pg
…01/03/24 Page 6 of 15
x In a 2011 interview, Ms. Giuffre mentioned former President Bill Clinton’s close
personal relationship with Defendant and Jeffrey Epstein. While Ms. Giuffre made no
allegations of illegal actions by Bill Clinton…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…PAGLIUCA: I'm not going to debate 3 BY MR. CASSELL:
4 what you have a good faith for believing or 4 Q. How long did your long-term relationship
5 not. My -- my objection stands. 5 with Maxwell continue…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…Id.
(suggesting limitations on searches of names to “make some effort to match them to actual
people who have some relationship to this case (like first name /3 last name or some parts
thereof)”).
After explaining the appropriate and well…
giuffre-maxwell
gov.uscourts.nysd.447706.222.0
10 pg
…at 123. The Court held that “a number of non-
6
exclusive factors” should “guide the trial court in making these determinations” including (1) the
nature of the relevant relationships; (2) the degree of control of the party over the…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…PAGLIUCA: I'm not going to debate 3 BY MR. CASSELL:
4 what you have a good faith for believing or 4 Q. How long did your long-term relationship
5 not. My -- my objection stands. 5 with Maxwell continue…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…Id.
(suggesting limitations on searches of names to “make some effort to match them to actual
people who have some relationship to this case (like first name /3 last name or some parts
thereof)”).
After explaining the appropriate and well…