giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…additional depositions. See Motion at 5-8 (listing 59 examples of memo1y
lapses dming Ms. Maxwell deposition, including inability to remember events recorded on
aircraft flight logs or a photograph). Defendant offers no explanation for her convenient
forgetfulness. Moreover, evidence…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…26
5. FBI 302 Statement, attached hereto as Exhibit 5.
6. Flight Logs, attached hereto as Composite Exhibit 6.
7. Message Pads from Law Enforcement from trash pull of Jeffrey Epstein's Palm
Beach home, attached hereto as Exhibit 7…
giuffre-maxwell
gov.uscourts.nysd.447706.1097.0_1
6 pg
…videos, or other media depicting, any of
Epstein’s properties or airplanes.
11. All flight logs from Epstein’s planes.
12. All police reports concerning Giuffre.
13. All emails exchanged between Sarah Ransome and any member of the media, including…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…additional depositions. See Motion at 5-8 (listing 59 examples of memory
lapses during Ms. Maxwell deposition, including inability to remember events recorded on
aircraft flight logs or a photograph). Defendant offers no explanation for her convenient
forgetfulness. Moreover, evidence…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…victim, alleged perpetrator, witness, someone named in flight logs, or an individual whose
association has been publicly reported, etc.); and (3) a brief description of the privacy interest
asserted.
6
Case 1:15-cv-07433-LAP Document 1354 Filed 01…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.9_7
56 pg
…17 A. You seemed very distracted in that
18 moment.
19 (Maxwell Exhibit 6, flight logs,
20 marked for identification.)
21 A. Do you mind if I take a break for
22 the bathroom.
23 Q. It's 11:08…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…young age of fifteen (15) to come “massage” Jeffrey Epstein at his Palm Beach mansion.
Publicly available flight logs from convicted pedophile1 Jeffrey Epstein’s private jets show the
Defendant flying close to 360 times and at least 20 of…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…4
Mr. Rodgers deposition, held last Friday and requiring a separate trip to Florida for Colorado counsel after the
scheduled court hearing on Thursday, served simply to authenticate flight logs. There are far more convenient, less
burdensome, and less expensive…
giuffre-maxwell
1320-8
12 pg
…Ms. Giuffre alleges that they were
heavily involved in the sex trafficking. Both Kellen and Marcinkova appear repeatedly on the
flight logs of Jeffrey Epstein’s aircraft. The U.S. Attorney’s Office for the Southern District of
Florida specifically…
giuffre-maxwell
1320-5
56 pg
…17 A. You seemed very distracted in that
18 moment.
19 (Maxwell Exhibit 6, flight logs,
20 marked for identification.)
21 A. Do you mind if I take a break for
22 the bathroom.
23 Q. It's 11:08…
giuffre-maxwell
1320-21
15 pg
…additional depositions. See Motion at 5-8 (listing 59 examples of memory
lapses during Ms. Maxwell deposition, including inability to remember events recorded on
aircraft flight logs or a photograph). Defendant offers no explanation for her convenient
forgetfulness. Moreover, evidence…
giuffre-maxwell
1320-20
11 pg
…4
Mr. Rodgers deposition, held last Friday and requiring a separate trip to Florida for Colorado counsel after the
scheduled court hearing on Thursday, served simply to authenticate flight logs. There are far more convenient, less
burdensome, and less expensive…
giuffre-maxwell
1320-27
15 pg
…additional depositions. See Motion at 5-8 (listing 59 examples of memory
lapses during Ms. Maxwell deposition, including inability to remember events recorded on
aircraft flight logs or a photograph). Defendant offers no explanation for her convenient
forgetfulness. Moreover, evidence…
giuffre-maxwell
1320-24
16 pg
…additional depositions. See Motion at 5-8 (listing 59 examples of memory
lapses during Ms. Maxwell deposition, including inability to remember events recorded on
aircraft flight logs or a photograph). Defendant offers no explanation for her convenient
forgetfulness. Moreover, evidence…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…Flight logs
for “the relevant years 2002-2005 showed Clinton traveling on Epstein’s plane on more than 10 occasions and his
assistant, Doug Band, traveled on many more occasions.” The logs also showed Clinton traveled with other
“employees and…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…4
Mr. Rodgers deposition, held last Friday and requiring a separate trip to Florida for Colorado counsel after the
scheduled court hearing on Thursday, served simply to authenticate flight logs. There are far more convenient, less
burdensome, and less expensive…
giuffre-maxwell
gov.uscourts.nysd.447706.233.0
9 pg
…crime – literally – for years while the two were
4
involved together in the sexual abuse of minors. Flight logs shows Epstein, Defendant and Ms.
Giuffre on numerous flights together. Epstein and Defendant also have extensive financial
dealing with each other…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…Ms. Giuffre alleges that they were
heavily involved in the sex trafficking. Both Kellen and Marcinkova appear repeatedly on the
flight logs of Jeffrey Epstein’s aircraft. The U.S. Attorney’s Office for the Southern District of
Florida specifically…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…by Mr. Epstein. General phone records, flight logs,
or other documents having nothing to do with Plaintiff, who was in Australia, are simply too
tangential and remote to be relevant even under the most broad definitions of relevance.
Accordingly, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.76.2
21 pg
…Exhibit 4.
5. FBI 302 Statement, attached hereto as Exhibit 5.
6. Flight Logs, attached hereto as Composite Exhibit 6.
7. Message Pads from Law Enforcement from trash pull of Jeffrey Epstein’s Palm
Beach home, attached hereto as Exhibit…
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