giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…public access.
First, three of the documents only mention Doe 17’s name in the context of discovery
search terms or a Federal Rule of Civil Procedure Rule 26 disclosure. The list of search terms that
include Doe 17’s…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…with respect to these requests, I
2 just want to -- you know, because the Court has mentioned this
3 and it is worthy of referencing, that if you look at the
4 defendants' request to us, they actually request a…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…10 MR. CRITTON: Form . 10 A. No, sir.
11 THE WITNESS: I think she was an 11 Q. And you mentioned this was a girl you had
12 acquaintance, friend. 12 seen before?
13 BY MR. MERMELSTEIN: …
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.447706.1320.26
10 pg
…money to bring her over;
14 however, they never called her to come.
15 Q. And then I believe you mentioned that one
16 of your physical fitness instructors, you brought a
17 physical fitness instructor; was that correct?
18 …
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…at one point that it was published and
16 disseminated around the world, not a single publication is
17 mentioned or attached to the complaint.
18 And furthermore, the complaint fails to state where in
19 fact the statements were…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.42
5 pg
…saw except the two girls
24 MR. CRITTON: Let me just note my objection, 24 that I mentioned that I think it was underage was
25 as I did in A. Rod's deposition or Mr. Rodriguez's 25 N…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.6
9 pg
…few guests, did she talk to you about that at all? 19 Q All right. And I guess by the way that you're
20 A She mentioned that if there are guests, we 20 explaining it, if Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…parties. Jane Doe 3 is free to reassert these factual details through proper evidentiary proof,
should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a
matter presented for the Court’s consideration.
As mentioned…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…unsealing
as a courtesy that is not provided in the vast majority of cases. In the normal course, nonparties
whose names are mentioned in depositions, briefs, or other documents are not notified before such
documents are publicly filed on a…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…15-cv-07433-LAP Document 1256-12 Filed 05/03/22 Page 18 of 32
Plaintiff did not include either woman in her Sharon Churcher-paid interviews, nor were they
mentioned in Plaintiff’s Joinder Motion of December 30, 2014…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.13
9 pg
…to you about that at all? 19 Q Alt right. And l guess by the way that you're
20 A Sne mentioned that If there are guest~ we 20 explaining it, If Mr. Epstein was in town for a…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…18 MS. MCCAWLEY: I'm going to object to that.
19 That's inappropriate. She gave you everyone she
20 could remember at the time when you mentioned a
21 name.
22 SPECIAL MASTER: Okay. Okay. Please move
23 on…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…family, and they took her under their
4 wing.
5 Q. Now, you mentioned remembering going to
6 Atlantic City.
7 Did you go -- where did you go after
8 Atlantic City?
9 A. Once we landed in New York…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.10
14 pg
…12 understand. We were totally lost for words.
13 And she said that before she got
14 there, she was threatened again by Jeffrey
15 and Ghislaine not to talk about what I had
16 mentioned earlier, about -- again, the…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.0
18 pg
…Second, for the reasons set out below, the Court
should consider the interests of the Non-Parties mentioned in Docket Entry 388 whose time to
object has expired now for efficiency. See infra Part III.
Fourth, Maxwell contends that Docket…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…01/03/24 Page 7 of 16
x In a 2011 interview, Ms. Giuffre mentioned former President Bill Clinton’s close
personal relationship with Defendant and Jeffrey Epstein. While Ms. Giuffre made no
allegations of illegal actions by Bill Clinton…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…Clinton, Attorney General Eric Holder are expected to pay their respects. You
know, Chris mentioned to us, our NEW DAY family, that his father's life has served as
a lesson for him since he was a very little boy…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…deposition is necessary for the following reason:
x In a 2011 interview, Ms. Giuffre mentioned former President Bill Clinton’s close
personal relationship with Defendant and Jeffrey Epstein. While Ms. Giuffre made no
allegations of illegal actions by Bill Clinton…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.17
11 pg
…1 BY MS. MENNINGER:
2 Q Mr. Figueroa, you mentioned that you and
3 Ms. Roberts attempted to go to back to school while
4 you were together --
5 A Yes.
6 Q -- to get your GED?
7 A Yeah. …