giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…to procure under-aged girls for sexual activities
1
Defendant has labelled her entire deposition transcript as Confidential at this time.
1
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…face allegations of sex abuse is now common place and a lot of resources are focused on this.
We can't sit back and let you be a conspirator by silence.
Your are not guilty and must follow Dershowtiz line…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…to procure under-aged girls for sexual activities
1
Defendant has labelled her entire deposition transcript as Confidential at this time.
1
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…Kellen was specifically identified by the U.S. Attorney’s Office for the Southern
District of Florida as a “potential co-conspirator of Epstein” in the non-prosecution agreement it
executed with Mr. Epstein as part of his guilty plea…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…at this time.
1
Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 2 of 17
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…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”). In…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…Florida, and in this District. Between 2001 and 2007, with the assistance of numerous
co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by
state and federal law enforcement.
10. As part of their sex…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…at this time.
1
Case 1:15-cv-07433-LAP Document 1218-1 Filed 07/15/21 Page 2 of 17
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
1320-2
10 pg
…1). at 127 (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.447706.1.0
12 pg
…Florida, and in this District. Between 2001 and 2007, with the assistance of numerous
co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by
state and federal law enforcement.
10. As part of their sex…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…Florida, and in this District. Between 2001 and 2007, with the assistance of numerous
co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by
state and federal law enforcement.
10. As part of their sex…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.2
10 pg
…1). at 127 (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.447706.199.0
8 pg
…Giuffre’s efforts to obtain depositions have been hampered by a number of factors.
An example of the conduct that has hampered Ms. Giuffre’s efforts to timely obtain
depositions is stall tactics of Defendant’s co-conspirator, Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…Epstein. Therefore, documents evidencing Ms. Giuffre’s encounters with
Maxwell, and documents evidencing Maxwell’s communications with her co-conspirators, are
plainly relevant and discoverable. For example, Request 6 seeks documents relating to
Maxwell’s communications with Sarah Kellen. At…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 7 of 21
Has knowledge of Defendant’s conduct that is the subject of this action and
knowledge of his sexual trafficking operation and other co-conspirators.
25…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…refusal to accept service. See Mot. at 2 (“forced to personally
serve the Defendant’s former boyfriend, employer, and co-conspirator”). As the timeline and
documents now reveal, however, Plaintiff failed to provide notice to Ms. Maxwell that she was…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…Defendant’s Resp. at 3. Tellingly, Defendant’s response brief
cites no authority to refute that proposition that adverse inference can be drawn against co-
conspirators. Presumably this is because, as recounted in Ms. Giuffre’s opening brief (at pp…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…Giuffre
and never had sex with her, but he is entitled to prove that the allegation fails for other reasons as
well). Giuffre has further alleged that Dershowitz was a “co-conspirator” of Jeffrey Epstein and
Ghislaine Maxwell, id. at …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…without his
family, in the presence of young girls;
x invocations of Fifth Amendment rights to remain silent by three of Epstein’s
identified co-conspirators (Sarah Kellen, Nadia Marcinkova, and Adrianna
Mucinska) when as…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…There are a few groups of people, his office in New
York and I guess --
***
Q. Okay. The other people mentioned as co-conspirators are Sarah Kellen, Adriana Ross, and
Nadia Marcinkova. So we'll get to them in a…
Comments