giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…delay,
Ms. Giuffre stated that she would be willing to “agree to a reasonable Protective Order being in
place in this case” and attached a redlined version of Defendant’s proposed Protective Order.
1
See McCawley Decl. at Exhibit 4…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…I certainly do feel that down the long, winding road, your case has merit! God willing that it puts that piece of human scurr
back behind bars! Should you win the day, yes, T do believe that you can create…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…Civ. P. 1). “If protective orders were easily modified . . . parties would be less
forthcoming in giving testimony and less willing to settle their disputes.” S.E.C. v.
TheStreet.Com, 273 F.3d 222, 230 (2d Cir. 2001). In particular…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…'”
Case 1:15-cv-07433-LAP
Dershowitz responded Document
by saying that if Boies 363-11
is willing to haveFiled
Freeh08/11/16 Page
…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…when it gets produced in this case. I
22 am not willing to accept plaintiff's representations on this as
23 to what it is or isn't. I've never had the opportunity to
24 question or cross-examine…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…CONTACT WITH JOSHUA BUNNER AND THIS
TIME I WAS SUCCESSFUL. I ASKED JOSH IF HE "WO)JLD BE WILLING TO SPEAK WITH
ME IN REGARDS TO AN ONGOING SHERIFF'S OFFft:~~f?J:NVESTIGATION AND HE AGREED TO
DO THIS…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…no purchase price for the ticket, because the people who
want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono
basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…no purchase price for the ticket, because the people who
want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono
basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…the possibility that soin'e"""a'rhis
friends might have abused his girlfriend and he wanted me to know
that he was willing to cooperate in anyway that he c o u ~ t to
the bottom of this incident…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…maybe what about
7 you?
8 And I was at a point in life, I was super
9 spontaneous and willing to skip school.
10 So she said, Come to my house, come in my
11 car and check it…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…No other girl would be there
8
Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 13 of 29
Key Testimony Transcript Citation
willingly just to have sex with Jeffrey.)
Victoria Secret
Ransome Dep…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…defend himself against charges of gross
wrongdoing, Dershowitz followed his own prescription and took his defense to the court of
public opinion where he had an audience willing to ignore both law and facts. The lawyer
victims of Dershowitz's…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…in Rhinebeck, New York, confirming
the suspicion that she was indeed still in the country and willing to say anything to avoid her
deposition.
Similarly, the Court is familiar with the long (and still on-going) effort of Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…wrote in her responses and objections, that she is willing to produce the Settlement Agreement and
all documents concerning the Settlement Agreement if Defendant gets a waiver of liability from
Jeffrey Epstein for its disclosure. Defendant has a joint defense…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…requesting an opportunity to take his deposition:
Dear Mr. Dershowitz:
Statements attributed to you in the public media express a willingness,
indeed a strong desire, to submit to questioning under oath regarding your alleged
knowledge of Jeffrey Epstein's extensive…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…girl would be there
8
Case 1:15-cv-07433-LAP Document 1334-1
1332-7 Filed 01/08/24 Page 13 of 29
Key Testimony Transcript Citation
willingly just to have sex with Jeffrey.)
Victoria Secret
…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…at a high-profile wedding in
Rhinebeck, New York, confirming the suspicion that she was indeed still in the country and
willing to say virtually anything in order to avoid her deposition. See Decl. of Sigrid McCawley
at Composite Exhibit…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…etc.
B. Plaintiff Refuses To Provide Her Residence, Domicile And Address
Where She Lived During Alleged “Defamation.”
Plaintiff claims she was willing to, and has already, responded to Interrogatory 1 and
complied with the requirement of Local Rule 26.1…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…Moreover, Ms. Giuffre’s willingness to sit for press interviews
undermines any suggestion she might make that she has an ongoing interest in keeping her
allegations of sexual abuse private.
This Case, My Involvement as a Witness, and My Discovery…
giuffre-maxwell
gov.uscourts.nysd.447706.898.0
4 pg
…fact that “the names of the minor victims were already in the public
record, and the record indicates that the victims may have been willing to testify despite the
presence of the press,” would presumably have weighed against closure. Id…
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