giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…2 of 25
TABLE OF CONTENTS
PRELIMINARY STATEMENT .................................................................................................1
ARGUMENT ..............................................................................................................................2
…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.9
5 pg
… *
83) sex*
84) abuse*
85) toy*
86) dildo*
87) strap* w/3 on*
88) vibr*
89) sm* w/3 101 *
90) slave*
91) erotic*
92) servitude*
95) high* w/3 school*
96) secondary* w/3 school*
97) campus*
100) licen…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…lewd and
inventory of law enforcement resources, policies or ascivious offense upon a person less than 16 years old, child abuse,
to mobilization, deployment or tactical operati sexual offense
1'I !rn71 (2)(1) Assets of crime victim …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…policies or ascivious offense upon a person less than 16 years old, child abuse,
to mobilization, deployment or tactical operati s sexual offense
C 119.071 (2)(1) Assets of crime victim C 985.04(1) Juvenile offender records
…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…Court is aware, this defamation case involves Ms. Giuffre's assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being "massage therapists." See Complaint, (DE 1). at~ 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…particular, Ms. Giuffre seeks to ask the Defendant questions
regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s
sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this
case, particularly…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…particular, Ms. Giuffre seeks to ask the Defendant questions
regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s
sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this
case, particularly…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being “massage therapists.” See Complaint, (DE 1), at …
giuffre-maxwell
1320-6
10 pg
…particular, Ms. Giuffre seeks to ask the Defendant questions
regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s
sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this
case, particularly…
giuffre-maxwell
1320-2
10 pg
…Court is aware, this defamation case involves Ms. Giuffre's assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being "massage therapists." See Complaint, (DE 1). at 127…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.2
10 pg
…Court is aware, this defamation case involves Ms. Giuffre's assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being "massage therapists." See Complaint, (DE 1). at 127…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…cv-07433-LAP Document 1256-8 Filed 05/03/22 Page 11 of 16
Giuffre’s account of her sexual abuse and Defendant’s involvement accords perfectly with other
witnesses’ accounts of what Defendant’s job was for Epstein.8
…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…Secret
freebies? Kendall
Jenner goes braless in a
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
… *
83) sex*
84) abuse*
85) toy*
86) dildo*
87) strap* w/3 on*
88) vibr*
89) sm* w/3 101 *
90) slave*
91) erotic*
92) servitude*
95) high* w/3 school*
96) secondary* w/3 school*
97) campus*
98) duke…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…751-12 Filed 03/17/17 Page 3 of 3
question.
Roberts' lawyers says the latest allegations do not contend the fact she was used for underage sex.
Attorney Sigrid McCawleysaid : 'To say that our client acquiesced in this abuse…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…As the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being “massage therapists.” See Complaint, DE1, at …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…3771.
DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…As the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being “massage therapists.” See Complaint, DE1, at …
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