giuffre-maxwell
gov.uscourts.nysd.447706.931.0
15 pg
… One set of
10 them are a bunch of photographs. I have looked at them,
11 nothing prurient about them, they all predate the statute of
12 limitations time period and were used during the deposition.
13 THE COURT: Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…to establish
that Jane Doe 43’s claims should be barred because they are outside the ten (10) year statute of
limitation period and also that they somehow establish that Epstein is not within the New York
Court’s jurisdiction.
…
giuffre-maxwell
gov.uscourts.nysd.447706.55.10
10 pg
…4 A. She is being sued by Virginia Roberts for
5 defamation, not for the underlying offenses, which
6 are beyond the statute of limitations, as I
7 understand it, correct.
8 Q. And have you spoken with Ghislaine Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…in order for
of allegedly defamatory statement gave rise to defamation claim to survive motion to dismiss,
new defamation claim against purported allegedly defamatory statement must contain at
defamer, and thus statute of limitations did not least one false factual…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…DEFENSES
23. The Complaint fails to state a claim upon which relief could be granted.
24. Plaintiff’s claims may be barred by the statute of limitations.
25. Plaintiff’s claims are barred by the “single publication” rule.
26. Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…him again.”
Instead, Boies said that Dershowitz has reverted to a “very sad” PR campaign against the lawyers
representing Roberts.
Dershowitz disputed Boies’s comments that he declined to waive the statute of limitations, saying that he
filed an affidavit…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…of
the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution ofthe
United States to a speedy trial or to bar the prosecution by reason of the running of the statute
of limitations for a period of…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…charges against me. I waive any statute of limitations,
any immunity, because if she files a false rape charge against me, she goes to jail.
The end result of this case should be she should go to jail, the lawyers…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…were part of
the sexual trafficking ring that Defendant was a party to and she has known about them and
interacted with them for years. Ms. Ransome's claim had to be filed swiftly because her statute
of limitations was…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…22 question, we can use the invocation that we 22 taken on the absence of the meaningful
23 just did in response to your second 23 Statute of Limitations, in terms of our
24 question, or we simply can say…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…precepts of fairness.
More practically, nothing precludes participants in this matter from publicly disclosing
their own allegations with more particularity. This is true in two key respects. First, New
York’s recent legislation extending and revising the statute of limitations…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…22 question, we can use the invocation that we 22 taken on the absence of the meaningful
23 just did in response to your second 23 Statute of Limitations, in terms of our
24 question, or we simply can say…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…state.
7. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
8. The words “relate,” “relating,” “relates,” or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…state.
7. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
8. The words "relate," "relating," "relates," or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…7. Unless instructed otherwise, each Request shall be construed independently and not
by reference to any other Request for the purpose of limitation.
8. The \vords "relate," "relating," "relates," or any other derivative thereot~ as used
herein includes concerning, referring…
giuffre-maxwell
1320-32
27 pg
…state.
7. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
8. The words "relate," "relating," "relates," or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…non-identical copy is a separate document within the meaning
of this term.
5. “Employee” includes a past or present officer, director, agent or servant, including
any attorney (associate or partner) or paralegal.
6. “Including” means including without limitations.
7…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…stale.
7. Unless instrncted otherwise, each Request shall be constrned indepcnde11tly and
not by reference to any other Request for the purpose of limitation.
8. The words "relate." "relating," ' 1relates," or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…state.
6. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
7. The words “relate,” “relating,” “relates,” or any other derivative thereof, as used
herein includes concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…interests. Finally, like Mr.
Dershowitz’s original Motion, the Government here seeks all deposition material and exhibits,
sealed or unsealed, without any limitations on the scope of the needs of their case against Mr.
Epstein’s estate. (Doc. # 1113, p…
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