giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF VIRGINIA GIUFFRE’S MOTION FOR FINDING
OF CIVIL CONTEMPT AGAINST SARAH KELLEN
FOR IGNORING SUBPOENA AND FOR
giuffre-maxwell
gov.uscourts.nysd.447706.311.0
3 pg
…Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF VIRGINIA
GIUFFRE’S MOTION FOR FINDING OF CIVIL CONTEMPT AGAINST NADIA
MARCINKOVA FOR IGNORING SUBPOENA AND FOR ASSOCIATED SANCTIONS…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…other accounts at
mindspring.com); (3) any of Ms. Maxwell's email account associated with The Terramar Project
(including any account ending [email protected]); and (4) any other email accounts
either used in the past, or currently in use.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
…It says, during the sworn taped statement 4 Clinton. Why would you pick those names, were
5 Mr. Rodriguez stated he was employed by Jeffrey 5 they associated with Mr. Epstein?
6 Epstein for approximately six months. 6 A. Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.6
4 pg
…401 E. Las Olas at Gray Robinson's office - suite
1000.
Michael Austrich -Thursday June 23 rd 9:00 a.m. - Ocala Florida - Owens & Associates - 108 N. Magnolia Ave
Tony Figueroa - Friday June 24 t h - 9:00 a.m. …
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…delete it from your system. Please
be advised that the views and opinions expressed in this e-mail may not
reflect the views and opinions of Associated Newspapers Limited or any of
its subsidiary companies . We make every effort to…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.13
13 pg
…not limited to the following: (1) (and any
and any other accounts at
(3) any of Ms. Maxwell's email account associated with The Terramar Project
(including any accoun …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…of all persons involved in the Communication, including the
identity of the law enforcement agency with whom the agent is or was
affiliated;
d. the case number associated with any such Communication;
e. the subject matter of any such Communication;
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…civil complaint against Mr. Epstein on Ms. Giuffre’s behalf which accused “academicians”
3
Case 1:15-cv-07433-LAP Document 1218-49 Filed 07/15/21 Page 4 of 27
associated with Mr. Epstein of abusing her; (iv…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…to an inference in her favor when a witness takes the
Fifth Amendment rather than answer a relevant question where that witness is associated with the other side of the
case or otherwise in an adverse position to the victims…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…of all persons involved in the Communication, including the
identity of the law enforcement agency with whom the agent is or was
affiliated;
d. the case number associated with any such Communication;
e. the subject matter of any such Communication;
…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…not already
responded to either at her first deposition or during this deposition, Ms. Maxwell requests that
the fees and costs associated with defending this Motion be imposed on Plaintiff, her counsel or
both.
Respectfully submitted,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…17. Recarey went on to describe the importance of the information:
Q. Did you find names of other witnesses and people that you knew to have been
associated with the house in those message pads?
THE WITNESS: Yes.
Q. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.27
8 pg
… I wanted to speak
24 with everyone in the home and everyone
25 associated with Jeffrey Epstein.
Case 1:15-cv-07433-LAP Document 1201-27 Filed 01/27/21 Page 8 of 8
Page 363
2 AFFIDAVIT
3 STATE…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…
10 scandal, was it that they are associated or 10 MR. CRITTON: Form .
11 friends with Jeffrey Epstein or is it that you 11 THE WITNESS: She knew what was going on.
12 have information and you have this confidentiality…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…17. Recarey went on to describe the importance of the information:
Q. Did you find names of other witnesses and people that you knew to have been
associated with the house in those message pads?
THE WITNESS: Yes.
Q. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…of all persons involved in the Communication, including the
identity of the law enforcement agency with whom the agent is or was
affiliated;
d. the case number associated with any such Communication;
e. the subject matter of any such Communication;
…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…representation of her as a
witness in this matter. She has not produced, nor indicated any basis for withholding, her fee
agreement associated with her civil complaint in Jane Doe 43 v. Epstein et al., including any for
Mr. Cassell…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…and his
word for sex.
friends and his girls, you’re out, because otherwise there’s no reason for
you to be associated with Jeffrey, because you’re just there to have sex
with him, so...)
The girls were on
…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…is or was
affiliated;
9
Case 1:15-cv-07433-RWS Document 71-2 Filed 03/23/16 Page 11 of 45
d. the case number associated with any such Communication;
e. the subject matter of any such Communication…