giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…commenced” . . . and the moving party “ha[d] not listed
with specificity those individuals it wishes to depose.” Of course, neither of these points applies
in this case at hand: the parties are approaching the close of fact discovery, and Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…commenced” . . . and the moving party “ha[d] not listed
with specificity those individuals it wishes to depose.” Of course, neither of these points applies
in this case at hand: the parties are approaching the close of fact discovery, and Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…beggars belief.
No document has ever been contemplated, created nor lawyer nor other approached to write such a
document at anytime
THE TERRAMAR PROJECT
FACEBOOK
TWITTER
G+
PINTEREST
INSTAGRAM
PLEDGE
THE DAILY CATCHthe
From: J Jep
Date: Wednesday, April 22…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
…8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.11_3
23 pg
…Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 20 of 23
Page 207
1 G Maxwell - Confidential
2 obvious lie that you approached Virginia
3 while she was under age at Mar-a-Lago…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…commenced" ... and the moving paiiy "ha[ d] not listed
with specificity those individuals it wishes to depose." Of course, neither of these points applies
in this case at hand: the pa1iies are approaching the close of fact discovery, and Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…239.
7
Case 1:15-cv-07433-LAP Document 1137-12 Filed 10/22/20 Page 12 of 28
• Whether it was a lie for Ms. Giuffre to say that Defendant approached females to bring
them to Epstein. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…obtain depositions because certain witnesses are avoiding service and others were
difficult to locate, and the time period for the close of discovery is swiftly approaching. The
Court will recall that the Defendant managed to delay her deposition until April…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…commenced” . . . and the moving party “ha[d] not listed
with specificity those individuals it wishes to depose.” Of course, neither of these points applies
in this case at hand: the parties are approaching the close of fact discovery, and Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…I have
film footage all over Europe itching to be released.” Ex. 1 (RANSOME_000521);
x Her friend was “approached, by Special Agents Forces Men sent directly by Hilary [sic]
Clinton herself, in order to protect her presidential campaign.” Ex…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…Jane Doe #3
would prove the following:
In 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…commenced” . . . and the moving party “ha[d] not listed
with specificity those individuals it wishes to depose.” Of course, neither of these points applies
in this case at hand: the parties are approaching the close of fact discovery, and Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…as Plaintiff now concedes. It read: “In 1999, Jane Doe #3 was
approached by Ghislaine Maxwell,” and continuing that “Maxwell persuaded Jane Doe # 3 (who was only fifteen
years old) to come to Epstein's mansion . . .” Plaintiff now concedes that…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…Epstein.
34. Defendant Malyshev was working as one of the enterprise's recruiters
of young females when she approached and recruited Plaintiff.
l0
Case 1:17-cv-00616 Document 1 Frled Oil26lt7 page 11 of 21
35. Defendant Malyshev…
giuffre-maxwell
1320-10
28 pg
…Ms. Maxwell, a stranger to her, approached
her on her college campus, and told her she would hire Ms. Sjoberg as her personal assistant.
After Ms. Sjoberg began to work for Defendant inside the home she shared with Epstein,
Defendant…
giuffre-maxwell
1320-21
15 pg
…commenced” . . . and the moving party “ha[d] not listed
with specificity those individuals it wishes to depose.” Of course, neither of these points applies
in this case at hand: the parties are approaching the close of fact discovery, and Ms…
giuffre-maxwell
1320-20
11 pg
…as Plaintiff now concedes. It read: “In 1999, Jane Doe #3 was
approached by Ghislaine Maxwell,” and continuing that “Maxwell persuaded Jane Doe # 3 (who was only fifteen
years old) to come to Epstein's mansion . . .” Plaintiff now concedes that…
giuffre-maxwell
1320-9
10 pg
…Jane Doe #3
would prove the following:
In 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…
giuffre-maxwell
1320-27
15 pg
…commenced” . . . and the moving party “ha[d] not listed
with specificity those individuals it wishes to depose.” Of course, neither of these points applies
in this case at hand: the parties are approaching the close of fact discovery, and Ms…
giuffre-maxwell
1320-24
16 pg
…commenced” . . . and the moving party “ha[d] not listed
with specificity those individuals it wishes to depose.” Of course, neither of these points applies
in this case at hand: the parties are approaching the close of fact discovery, and Ms…