giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…agreement (NPA) at issue in this case, which bars his prosecution
in the Southern District of Florida as a “potential co-conspirator of Epstein.” DE 280 at 4
(quoting NPA at 5). The Court has previously allowed Epstein to prospectively…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…10 , if it's the same woman that I'm thinking of
11 and she was one of Jeffrey's, I would like to say,
12 co-conspirators. She had sex with underaged girls and
13 myself.
14 . He was…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…sex offender Jeffrey Epstein and Defendant were engaging in sexual trafficking conduct;
the later part of that period includes the investigations by law enforcement and the co-
conspirator’s efforts to coordinate and cover up the abuse that occurred. Therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…prosecution agreement with the federal authorities obligating him to pay restitution for his crimes
against Ms. Giuffre. That agreement also protected any “co-conspirators” from prosecution.
The remaining question, then, is whether the Defendant was involved in this sexual
abuse…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…45
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.447706.23.0
32 pg
…to
join a long-running Crime Victims’ Rights Act (“CVRA”) lawsuit, which was brought by other
young girls who were also abused, and sought to challenge Jeffrey Epstein’s non-prosecution
agreement which also pardoned co-conspirators. Through lawyers1, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…Maxwell cannot defeat the strict protections of the Shield Law based on
groundless speculation, and the accusation that Churcher is “not a journalist,” but rather “a co-
conspirator in plaintiff’s publication of false statements” is unfounded, and frankly offensive.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.28
38 pg
…A. I have. 8 Q. Are you aware that Sarah Kellen was
9 Q. Have you flown with Nadia 9 a co-conspirator, named as a co-conspirator
10 Marcinkova? 10 in the case involving Jeffrey Epstein?
11 A. What…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
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
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
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
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
1320-21
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
1320-20
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
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
1320-27
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
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
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
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.447706.590.1
4 pg
…02/02/17 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…