giuffre-maxwell
gov.uscourts.nysd.447706.136.0_2
29 pg
… Absolutely not, your Honor. They are
23 not entitled to a full-scale production of everything that's
24 happened in this young lady's life. She was abused by these
25 individuals. She shouldn't be reabused by having…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…related:
" On one occasion, she adds, Epstein did invite two young brnnettes to dinner
which he gave on his Caribbean island for Mr. Clinton sho1t ly after he left office.
But as far as she knows, the ex-President did…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…As the Court is also aware, evidence relating to the sexual
abuse and trafficking of minors and other young women is contained in many of the documents
in this case. This Court’s Protective Order (DE 62) protects both the…
giuffre-maxwell
gov.uscourts.nysd.447706.702.0
63 pg
…There can hardly be a more compelling reason to seal documents
23 than those that depict the sexual abuse and sexual trafficking
24 of plaintiff, other minors and other young women.
25 Here, there is no showing why some unspecified
…
giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
…other witness,
Accordingly, in this manner, Ms. Giuffre needs to depose other witnesses to show the veracity of
her claim that Defendant recruited young females, unexperienced in massage, for sex with
Jeffrey Epstein, proving that Defendant was lying when she…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…namely Mr. Epstein’s private bedroom.
10. Ms. Giuffre and her counsel have alleged that she was not the only “young
girl” that I had sexual contact with – i.e., that there were others. Of course, no such persons have…
giuffre-maxwell
gov.uscourts.nysd.447706.1158.0
17 pg
…19 Q. Okay. So do you remember back in 2009
20 testifying:
21 "QUESTION: Did you ever observe her doing
22 a photo shoot of any of the young women whose names
23 you mentioned?
24 "ANSWER: Young women?
25…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.19
4 pg
…mother of her three children going around selling her
false stories of prostitution."
Dershowitz is an admitted long-time friend of Epstein's who frequented his homes at the time Roberts and
other young girls were in Epstein's employ…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.13
22 pg
…under that rule.
Defendant also makes reference to the Palm Beach police repo1i, which details Epstein' s
sexual abuse of many young girls. With respect to claims that aspects o f - testimony
imply read into evidence passages from the police…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…victims. The Miami Herald’s coverage of Mr. Epstein’s and his associates’ alleged crimes has
nothing to do with consensual sexual preferences and everything to do with the abuse of young
girls, whether that crime was justly prosecuted or…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.6
32 pg
…and
more these days. Alan’s taste for the young and beautiful was a
bias for a blooming business relationship between him and Jeffrey.
After an explicit session of Jeffrey’s vulgar pilgrimage into my
body, we were interrupted by…
giuffre-maxwell
gov.uscourts.nysd.447706.436.0
15 pg
…and smeared Professor Dershowitz through surrogates
even after her lawyers had admitted it was a mistake to accuse him of raping young girls.
4
Case 1:15-cv-07433-RWS Document 436 Filed 09/15/16 Page 9 of…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
…21
iii
Case 1:15-cv-07433-LAP Document 1325-14 Filed 01/04/24 Page 5 of 30
INTRODUCTION
As more and more witnesses come forward testifying about Defendant’s involvement in
the sexual abuse of young girls…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…Hr’g Tr.
4:10-16 (“In the context of this case, especially its allegations of sex trafficking of young girls, the
Court finds that any minor embarrassment or annoyance resulting from disclosure of Ms.
Maxwell’s mostly nontestimony about…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…Y. 2012) (internal citations
and quota t ions omitted) (denying motion to lift confidentiality
of report of polic in g failures surrounding the murder of a young
mother) . "It is presumptively unfair for courts to modify
protecti v e orders…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…clear contrast, the
Florida state action did not involve “the same subject matter” – i.e., it did not involve the
Defendant’s participation in procuring girls and young women as part of Epstein’s sex
trafficking enterprise. Indeed, the Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…DocumentDocument 1325-3
279 Entered Filed Docket
on FLSD 01/04/24 Page 5 of Page
12/30/2014 10 4 of 13
(along with other young girls) to such powerful people were to ingratiate …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…of Defendant’s counsel’s campaign to
blame the victim and make Ms. Giuffre (who was 15 years old or younger at the time of the
requested documents). Maxwell’s counsel has used offensive language in this proceeding at
every…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…the 21 job I was dealing with.
22 work lessened, when did you complete working 22 Q. How old was the youngest female you
23 for Mr. Epstein; when was the last time you 23 ever hired to work for…
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…run a very substantial
20 building project. That's the nature of the
21 job I was dealing with.
22 Q. How old was the youngest female you
23 ever hired to work for Jeffrey?
24 MR. PAGLIUCA: Object to…