giuffre-maxwell
gov.uscourts.nysd.447706.1198.17
3 pg
…Information
Date Plaintiff’s Statement Truth Sources
March 16 Refusal to identify any health Privilege waived by Plaintiff when Plaintiff’s Responses &
care providers or records because suing for $30 million of medical a…
giuffre-maxwell
gov.uscourts.nysd.447706.1302.0
3 pg
…Rule of Appellate
Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a document
filed with this Court, a party must cite either the Federal Appendix or an electronic database
(with…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
… 1n the summer of 2006, when I was twenty-two years old and living in New York,
I was introduced to Jeffrey Epstein by a girl I had met named Natalya.
Malyshov. Shortly after meeting Jeffrey he invited me to…
giuffre-maxwell
gov.uscourts.nysd.447706.1305.0
4 pg
…Rule of Appellate
Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a
document filed with this Court, a party must cite either the Federal Appendix or an
electronic database (with…
giuffre-maxwell
gov.uscourts.nysd.447706.1126.0
3 pg
…Rule of Appellate
Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a
document filed with this Court, a party must cite either the Federal Appendix or an
electronic database (with…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…first paragraph of this brief, as well as the
second-to-last paragraph of Section I of this brief out of a concern Defendant raised with the use of the term “set”
when referring to depositions. In an abundance of…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.35
7 pg
…when and where the following proceedings were
reported by:
Michele Cameron
Magna Legal Services
866-624-6221
Case 1:15-cv-07433-LAP Document 1218-35 Filed 07/15/21 Page 3 of 7
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.7
9 pg
…of Florida.
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 3 of 9
Page 30
1 Q. Did you observe her to be young when you
2 met her?
3 MS …
giuffre-maxwell
gov.uscourts.nysd.447706.1296.4
4 pg
…a Registered
Professional Reporter, Certified Realtime
Reporter and Notary Public within and
for the State of Florida.
Page 45
1 Q. And what -- do you recall any observations
2 about when you met her?
3 A. To speak with…
giuffre-maxwell
gov.uscourts.nysd.447706.1304.0
3 pg
…Rule of Appellate
Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a
document filed with this Court, a party must cite either the Federal Appendix or an
electronic database (with…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.18
6 pg
…3 them?
4 A. No, sir.
5 Q. So when there would be a message from one
6 of them while they were out of town, they would call
7 you, call you on the telephone?
8 A. I haven…
giuffre-maxwell
gov.uscourts.nysd.447706.87.0
4 pg
…C., hereby respectfully
moves for a brief adjournment of the April 13 hearing until April 21, 2016, when Ms.
Maxwell’s Motion to Compel will be heard by this Court. As grounds she asserts as
follows:
1. On April 5…
giuffre-maxwell
gov.uscourts.nysd.447706.515.0
12 pg
… PLAINTIFF’S DUTY TO PRESERVE ATTACHED IN 2011
WHEN SHE FORMED AN INTENT TO JOIN THE CVRA LITIGATION
Plaintiff concedes she willfully and deliberately destroyed while she
prepared to join the CVRA litigation and while she was represented by current…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…ii
I. PRELIMINARY STATEMENT ............................................................................................1
II. ARGUMENT .........................................................................................................................2
1. Conference Is Futile When A Party Is Stonewalling Dis…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.19
22 pg
…RXUW5HSRUWLQJ
Case 1:15-cv-07433-LAP 9LGHR,QF
Document 1320-19 Filed 01/03/24 Page 2 of 22
1 A I believe this is when I was hoping to
2 join the CVRA case.
3 Q All right…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.23
4 pg
…SERVICES
Case 1:15-cv-07433-LAP Document 1327-23 Filed 01/05/24 Page 3 of 4
Page 45
1 Q. And what -- do you recall any observations
2 about Jane Doe 2 when you met her?
3 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.3
7 pg
…A No, there's no more than one truth.
8 Q All right. So a document in which you
9 swore that you were 15 years old when you met
10 Ms. Ghislaine Maxwell is an untrue statement,
11 correct?…
giuffre-maxwell
1320-19
22 pg
…RXUW5HSRUWLQJ
Case 1:15-cv-07433-LAP 9LGHR,QF
Document 1320-19 Filed 01/03/24 Page 2 of 22
1 A I believe this is when I was hoping to
2 join the CVRA case.
3 Q All right…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
… B
Judgment delivered 22 July 2008.
Specific disclosure – Litigation privilege – Cross-examination – When court
could go behind affidavit of documents – Third party sought specific disclosure
of documents – Litigation privilege claimed – Ma…
giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…aware, Ms. Giuffre has alleged that Defendant defamed her when she
called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of
Defendant and Defendant’s long-time boyfriend, convicted…
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