giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…and in the face of Plaintiff’s sworn denial that
she has had any contact with law enforcement officials from 1996 to the present apart from
supposed “active investigations involving Ghislaine Maxwell,” counsel for Defendant
unearthed numerous records of such…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.3_1
4 pg
… Attached hereto as Exhibit 5, is a true and correct copy of Excerpts from Juan
Alessi’s November 21, 2005 Sworn Statement.
8. Attached hereto as Exhibit 6, is a true and correct copy of Excerpts from the
September 8…
giuffre-maxwell
gov.uscourts.nysd.447706.153.0
4 pg
… Attached hereto as Exhibit 5, is a true and correct copy of Excerpts from Juan
Alessi’s November 21, 2005 Sworn Statement.
8. Attached hereto as Exhibit 6, is a true and correct copy of Excerpts from the
September 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
… 3 Google, I guess you Googled Prince Andrew and Bill
4 Q. It says, during the sworn taped statement 4 Clinton. Why would you pick those names, were
5 Mr. Rodriguez stated he was employed by Jeffrey 5 they associated…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…NY 10022
(212) 446-2300
Mr. Boies has knowledge concerning matters at issue in the Complaint and in
Plaintiff’s pleadings and sworn statements in other litigations, including in
particular her publicly filed allegations concerning Defendant and Alan
Dershowitz.
9…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…the witness whose
11 deposition is hereinbefore set forth was duly
12 sworn by me and that such Deposition is a true
13 record of the testimony given by the witness.
14 I further certify that I am not related…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.4
4 pg
…MIAMI-DADE )
4
5 I, the undersigned authority, certify
6 that personally appeared before me
7 and was duly sworn.
8 WITNESS my hand and official seal this
9 18th day of May, 2016.
10
11
KELLI ANN WILLIS, RPR…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…ofPage
01/21/2015 41 2 of 40
sworn affidavit (attached as Exhibit 1) that all her allegations are true – an affidavit consistent
with compelling corroborating evidence.
BACKGROUND AND COURSE OF PROCEEDINGS
Because this case …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.23
4 pg
…4
5 I, the undersigned authority, certify
6 that JOHANNA SJOBERG personally appeared before me
7 and was duly sworn.
8 WITNESS my hand and official seal this
9 18th day of May, 2016.
10
11
KELLI ANN WILLIS, RPR…
giuffre-maxwell
1320-40
19 pg
…NY 10022
(212) 446-2300
Mr. Boies has knowledge concerning matters at issue in the Complaint and in
Plaintiff’s pleadings and sworn statements in other litigations, including in
particular her publicly filed allegations concerning Defendant and Alan
Dershowitz.
9…
giuffre-maxwell
gov.uscourts.nysd.447706.173.0
4 pg
…Report.
10. Attached hereto as Exhibit 8, is a true and correct copy of the November 21, 2005
Sworn Statement of Juan Alessi.
11. Attached hereto as Exhibit 9, is a true and correct copy of the May 4, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…The
response also explained some of the evidence supporting the allegations against Dershowitz,
-
including:
x sworn testimony from one of Epstein’s household employees (Juan Alessi) that
Dershowitz came “pretty often” to Epstein’s Florida mansion and got massages
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…innocence.” DE
-
364 at 1. The documents do not directly bear on Ms. Giuffre’s sworn and detailed statements
about how Dershowitz sexually abused her, statements that are corroborated by a mountain of
supporting evidence.2 Instead, according to Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
… But shouldn't, in the
24 normal course, a litigant be able to get an adversary's prior
25 sworn testimony on the same subject matter? So that's really
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.11
8 pg
…witness?
Suite 400 11 Thereupon,
10 West Palm Beach, Florida 33401 12 ALFREDO RODRIGUEZ,
Attorney for Jeffrey Epstein.
11 …
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…for stealing, and then trying to sell, documents related to Jeffrey Epstein. See
DE 679,
It also
quotes from Doe 1’s prior sworn statements and testimony, which he explained earlier, e.g.,
Given Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…before a jury to answer the very same questions as to which he has
already asserted his Fifth Amendment privilege during sworn video-recorded testimony will add
nothing to the ultimate issue of whether any adverse inference should be permitted…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…Defendant
has provided no evidence other than the fact of his
representation of Plaintiff ' s non - profit to doubt that the
communications logged are privi l eged.
Having provided no grounds to doubt the sworn
representations of Plaintiff ' s counsel …
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…disclosure of related materials they know are
unfavorable, would destroy Plaintiff’s claim that she has been truthful, and reveal her attorneys’
knowledge of Plaintiff’s false statements in multiple sworn filings and her concerted media
campaign. The law, however…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
… The court reporter is Deborah
18 Harris, both from Esquire Deposition Solutions.
19 Would counsel please introduce yourselves and your
20 affiliation and the witness will be sworn in.
21 MS. MCCAWLEY: My name is Sigrid McCawley.
22 I'm…
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