giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…Giuffre of her right to jury trial borders on frivolous. Ms. Giuffre is a
courageous young woman who has come forward to reveal the broad dimensions of a sex
trafficking ring – a criminal conspiracy that involved Defendant. That fact, alone…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…29
Moreover, Ms. Ransome sat for ten hours of deposition and gave critical testimony showing
Defendant's direct involvement in Epstein's sex abuse and sex trafficking conspiracy:
Key Testimony Transcript Citation
Maxwell provided Ransome Dep. Tr. at 331 (Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.0
9 pg
…subornation of perjury, obstruction of justice and conspiracy. The government:
speculated that the pretrial deposition testimony might be relevant to its
investigation into matters similar to those that had been the subject of the
Martindell action and might be useful…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…enterprise operated in a
hierarchal strucfire with Defendants Jeffrey Epstein and Ghislaine Ma>rwell at the
top and rurderlings below. Underlings included the other named Defendants as
well as unnarned co-conspirators such as various housekeepers and butlen; an
airplane pilot…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…any issue, I'm going to ask you, was one of
3 basis and this was a conspiracy between 3 the victims in that case a girl who was 14 years old
4 Mr. Epstein and the U.S. Attorney…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…present Assistant United States Attorney—at the
United States Consulate in Sydney, Australia, as part of an ongoing investigation into Jeffrey
Epstein sexual abuse and sex trafficking conspiracy. In due course, a Special Agent prepared a
standard summary of Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…any issue, I'm going to ask you, was one of
3 basis and this was a conspiracy between 3 the victims in that case a girl who was 14 years old
4 Mr. Epstein and the U.S. Attorney…
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…But as the
Court is aware, each of the actions involving Dershowitz arise out of the same subject matter as
this one: Epstein’s sex-trafficking conspiracy. The documents were relevant to the Court’s
14
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…an
obvious adverse inference could be drawn that Dershowitz was, indeed,
involved in Epstein’s crimes;
i. In moving down from the top of Epstein’s criminal conspiracy to the next
echelon, three women – Sarah Kellen, Adrianna Mucinska, and Nadia
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…
i. In moving down from the top of Epstein’s criminal conspiracy to the next
echelon, three women –
– all took the Fifth when asked about Dershowitz’s awareness of
Epstein’s sexual abuse of underage girls or whether Dershowitz was…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…fought-hide
236 https://www.bloomberg.com/news/storythreads/2020-10-22/ghislaine-maxwell-s-jeffrey-epstein-days-and-the-conspiracy-case-against-her
237 https://www.13newsnow.com/article/news/nation-world/ghislaine-maxwell-transcripts-reelased/507-5adb87e0-aea3…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…the global stage at that point [when she held the
bonfire]. She is a child victim of sex abuse at the hands of the defendant [and] co-
conspirators, and she decided to burn certain memories as a step toward the
…
giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…Epstein.
9 As you know, Ms. Giuffre has made allegations that she
10 was sexually trafficked by Epstein's conspiracy in which
11 Ms. Giuffre was the madam or key lieutenant. So he's the first
12 most important witness…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…Ms. Giuffre at this time.
1
Ms. Giuffre escaped.4 Therefore, discovery requests concerning Defendant’s continued
trafficking of minors, and continued contact with her co-conspirators (including payments from
Epstein), are relevant and discoverable.
II. ARGUMENT
…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…relating to sex offenses) and § 371
(conspiracy).
4
Case 1:15-cv-07433-LAP Document 102 Filed 04/19/16 Page 5 of 9
No good reason would be served by forcing Ms. Giuffre to disclose the name of…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…of any
publication. Plaintiff’s argument for relevance is nonsense. She claims the JDA might show “the
nature of the ongoing relationship between Ms. Maxwell and her “co-conspirator” and between
Ms. Maxwell and Mr. Dershowitz. Not only would a…
giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…time.
1
Case 1:15-cv-07433-RWS Document 315 Filed 07/29/16 Page 2 of 17
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
2
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
… CLARIFICATION OF THIS COURT’S MARCH 17, 2016 RULING.................................3
A. Documents Evidencing Communications and Interactions With
Co-Conspirators.............................................................................................................3
B. Documents Concer…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…1). at~ 27 (Giuffre "described
Maxwell's role as one of the main women who Epstein used to procure under-aged girls for
sexual activities and a primary co-conspirator and participant in his sexual abuse and sex
trafficking scheme'')…
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
…time.
1
Case 1:15-cv-07433-LAP Document 315 Filed 07/29/16 Page 2 of 17
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
2
Case 1:15-cv…
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