giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…party in any criminal action pertaining to JE
Every story in the press innuendo and comment has been taken from civ
depositions against JE, which were settled many years ago. None of the
depositions were ever subject to cross examination…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.1
2 pg
…my self to being
part of discovery apparently. I am trying to stay out of litigation and not have to employ lawyers for years as I
get lost in US legal nightmare. I stand no legal risk currently on these…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…my self to being
part of discovery apparently. I am trying to stay out of litigation and not have to employ lawyers for years as I
get lost in US legal nightmare. I stand no legal risk currently on these…
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
gov.uscourts.nysd.447706.34.2
3 pg
…opportunities.
• See who you know in common
• Get introduced
• Contact Ross directly
Experience
Owner, Managing Partner
ACUITY Reputation
January 2010 – Present (6 years 2 months)
ACUITY advises Governments, Corporates and UHNWIs on reputational issues
Skills
Public Relations Marketing …
giuffre-maxwell
gov.uscourts.nysd.447706.552.0
2 pg
…declare:
1. I am over the age of 18 years and am fully competent to make this Declaration.
The facts set forth herein are within my personal knowledge and are true and correct.
2. I respectfully submit this Declaration in…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…are false. Giuffre’s fantastical claims,
contained in news stories and press-releases masquerading as legal pleadings over the last five
years have been well-crafted with the assistance of high-priced attorneys to facilitate Giuffre’s
media exposure, to…
giuffre-maxwell
gov.uscourts.nysd.447706.605.0
2 pg
…declare:
1. I am over the age of 18 years and am fully competent to make this Declaration.
The facts set forth herein are within my personal knowledge and are true and correct.
2. I am an attorney duly licensed…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…produce
clear and convincing evidence of its falsity. ........................................................... 56
1. The January 2015 statement accurately denied that Ms. Maxwell met
Plaintiff when Plaintiff was 15 years old in 1999. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…email account for communication from
1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant
did not use an email account to communicate those years.1
For example, according to United States Department of Commerce…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…these underage girls
18 were visiting Jeffrey's home?
19 MR. PAGLIUCA: Objection to the
20 form and foundation.
21 A. I was not -- what year, I need
22 years.
23 Q. How about let's say 2005?
24 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1264.0
1 pg
…1157, 1230. That protocol, which was first put in place more than two years ago, balances
the presumption of public access to judicial documents against the privacy, reputational, and
other countervailing interests that support the continued sealing of certain of…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.3_1
2 pg
…likely because there is none. GM 748-840 are various
police reports that have been publicly available for years. GM 841-849 are
public comments about your client's story which are available to the world by
a simple Google…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.5_1
4 pg
…forasearchofthefollow ingterm s:
50 – S outhernDistrict(w hichw illpullupevery attorney-clientcom m unicationthatreferstoourcaseand includesany
pleading)
51 – P alm Beach(aplaceourclientlived form any years)
64 – N ew M exico
66-72 – U S VIby variousnam es
113 – hospital
114 – 116 – hotel…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.35
5 pg
…call you on the telephone?
8 A. I haven't spoken to Ghislaine in 12 years.
9 Q. Sorry. I'm talking about when you worked
10 there and you would receive a message that they were
11 coming into…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.16
2 pg
…Intervenor Dershowitz
supports the pending application. As this Court knows, Intervenor Dershowitz has been
litigating to unseal materials from this case for nearly two years. Indeed, at this very moment,
Intervenor’s appeal of this Court’s order denying his…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.17
3 pg
…were “in the past. We are talking disclosed: Del Mar, Lightfoot, at 22-23
Case 1:15-cv-07433-LAP Document 1198-17 Filed 01/27/21 Page 2 of 3
about years and years
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…on his emails, those would be captured by searches for the other people’s names). You included my
client’s boyfriend of many years, though he is not on any witness list or in any RFP.
In sum, I will…
giuffre-maxwell
gov.uscourts.nysd.447706.587.0_2
10 pg
…than the second group of documents. Give me a break. Leave
8 that aside. I haven't remembered any one of my dreams now for
9 a couple of years but okay. Yes, I hear you.
10 MR. PAGLIUCA: Your…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…yes, T do believe that you can create a mighty manifesto on prostitution as it
exists in the U.S.A. in the years leading up to 2014- one that has real literary possibilities. If you win the case, contact…
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