giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…lawsuit presents one relatively simple question: is Plaintiff’s claim that she was
sexually abused, sexually trafficked and held as a “sex slave” by Jeffrey Epstein between 1999
and 2002 “with the assistance and participation of” Ms. Maxwell substantially true…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…lawsuit presents one relatively simple question: is Plaintiff’s claim that she was
sexually abused, sexually trafficked and held as a “sex slave” by Jeffrey Epstein between 1999
and 2002 “with the assistance and participation of” Ms. Maxwell substantially true…
giuffre-maxwell
gov.uscourts.nysd.447706.697.0
21 pg
…1986) ............................................................................................... 11
Granite Partners, L.P. v. Bear Stearns & Co. Inc.,
184 F.R.D. 49 (S.D.N.Y.1999) ................................................................................................. 11
Guiffre v. Maxwell,
2016 WL 1756918 (S.D.N.Y…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.4
4 pg
…Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre
c/o Sigrid S. Mccawley…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…and/or Jeffrey Epstein.
15. All documents relating to any telephone, including any cellular telephone, used by you
between January 1, 1999 and December 31, 2002.
16. Any diary, journal or calendar concerning your activities between January 1, 1999 and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…to, or with whom You
engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999,
including the names of the individuals involved, the dates of any such illegal or inappropriate
sexual contact, conduct or assault…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…Exhibit A.
Response to Interrogatory No. 12
Pursuant to this Court’s Order, Ms. Giuffre will provide information for health care
providers from 1999 through the present. Ms. Giuffre continues to search for medical providers
that appear in documents.
! Dr…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…Exhibit A.
Response to Interrogatory No. 12
Pursuant to this Court’s Order, Ms. Giuffre will provide information for health care
providers from 1999 through the present. Ms. Giuffre continues to search for medical providers
that appear in documents.
! Dr…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…Ms. Giuffre recalls
one facility named “Growing Together” that was located in or around
Palm Beach, but she does not recall the dates when she resided at the
facility.
From 1999-2002, Ms. Giuffre lived and travelled with Jeffrey…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…in violation of her rights under the CVRA. If allowed to join this action, 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…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…Ms. Giuffre recalls
one facility named “Growing Together” that was located in or around
Palm Beach, but she does not recall the dates when she resided at the
facility.
From 1999-2002, Ms. Giuffre lived and travelled with Jeffrey…
giuffre-maxwell
1320-37
48 pg
…Exhibit A.
Response to Interrogatory No. 12
Pursuant to this Court’s Order, Ms. Giuffre will provide information for health care
providers from 1999 through the present. Ms. Giuffre continues to search for medical providers
that appear in documents.
! Dr…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…to, or with whom You
engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999,
including the names of the individuals involved, the dates of any such illegal or inappropriate
sexual contact, conduct or assault…
giuffre-maxwell
gov.uscourts.nysd.447706.55.12
21 pg
…appearances for the record. 17 Q. Okay.
18 MR. WILLITS: Richard Willits, representing 18 A. '99.
19 Carolyn Andriano. 19 Q. 1999?
20 MR. BERGER: William J. Berger, representing …
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…Exhibit A.
Response to Interrogatory No. 12
Pursuant to this Court’s Order, Ms. Giuffre will provide information for health care
providers from 1999 through the present. Ms. Giuffre continues to search for medical providers
that appear in documents.
! Dr…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…Epstein, most notably by submitting an untruthful
declaration in the Edwards defamation lawsuit. On November 20, 2015 Ms. Giuffre executed
an affidavit in which she alleged that: “In approximately 1999, when I was 15 years old, I met
Ghislaine Maxwell . …
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