giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…Plaintiff identifies Nadia
Marcinkova, Sarah Kellen (a/k/a Sarah Kensignton or Sarah Vickers), and Jeffrey Epstein as
alleged “co-conspirators” with each other. She requests the depositions of each. Plaintiff
anticipates each will invoke the Fifth Amendment –in other…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…p. 12. Churcher
is not a journalist; she is a co-conspirator in Plaintiff’s publication of false statements regarding
numerous people including Prince Andrew, Alan Dershowitz and Ms. Maxwell. It is the denial
of the defamatory claims Churcher helped…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…1332-14 Filed 01/08/24 Page 4 of 9
including Defendant’s coordination of the press attack on Ms. Giuffre and Defendant’s
coordination of the attack with her co-conspirator, Epstein.
The Court heard oral argument on Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 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.447706.1328.5
45 pg
…of Ms. Giuffre. A victim of sexual abuse should not be
re-abused by having to disclose events that occurred prior to the time that she was sexually
abused by Maxwell and her co-conspirators.
Furthermore, discovery concerning Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…Epstein.
Ms. Giuffre is in possession of a responsive document that contains a confidentiality
provision. If Defendant obtains, and produces to Ms. Giuffre, a written waiver from her co-
conspirator, Mr. Epstein, of the confidentiality provision, freeing Ms. Giuffre from…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Marcinkova 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.447706.1078.5
161 pg
…LAP Document 1078-5 Filed 07/29/20 Page 58 of 161
Sarah Kellen worked as an assistant for Jefferey Epstein and was named in his 2008 plea
agreement as 'potential co-conspirators'
Nada Marcinkova who now goes by Nadia…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…was part of Epstein’s
account through which he communicated with his employees and other members of his
household, including his co-conspirators , and the Defendant.
This email account likely has (or had) myriad of communications between and among Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his sexual abuse and sex trafficking scheme. In fact…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…Marcinkova 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.447706.1330.6
10 pg
…the United States also agrees that it will not institut
. inclucting but not limited to Sarah Kellen.
against any potential co-conspirators of Epstein
Adriana Ross, Lesley Oro~ or Nadia MarcinkoviL Further,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…07/15/21 Page 4 of 4
PHILIP WILLIAMS: Under the plea bargain struck with prosecutors by Jeffrey Epstein,
it appears that other potential allegations may not end up tested in court and that
could apply to possible co-conspirators…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…Office for the Southern District of
Florida specifically identified both Kellen and Marcinkova as among four named “potential co-
conspirators of Epstein” in the non-prosecution agreement it executed with Epstein as part of his
guilty plea to Florida state…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…his
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 31 Filed 01/28/16 Page 9 of 22 9
G1ETGIUA
1 co-conspirators were also part of that plea agreement, that
2…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
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.447706.1257.2
21 pg
…was part of Epstein’s
account through which he communicated with his employees and other members of his
household, including his co-conspirators , and the Defendant.
This email account likely has (or had) myriad of communications between and among Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
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.447706.1331.3
48 pg
…Epstein.
Ms. Giuffre is in possession of a responsive document that contains a confidentiality
provision. If Defendant obtains, and produces to Ms. Giuffre, a written waiver from her co-
conspirator, Mr. Epstein, of the confidentiality provision, freeing Ms. Giuffre from…
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