giuffre-maxwell
gov.uscourts.nysd.447706.27.0
3 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S MOTION FOR LEAVE TO BRING PERSONAL ELECTRONIC
DEVICES AND GENERAL PURPOSE COMPUTING DEVICES INTO THE
COURTHOUSE FOR THE JANUA…
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…and victims’ rights expert Bradley Edwards — to bring the men
to justice.
“I have directed my attorneys … to pursue all reasonable and legitimate means to have criminal charges brought against
http://radaronline.com/exclusives/2015/01/bill-clinton-sex…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.1
55 pg
…in support thereof,
would show unto the Court as follows:
JURISDICTION AND PARTIES
1. The Attorney General of the United States Virgin Islands (herein after "Virgin
Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands…
giuffre-maxwell
gov.uscourts.nysd.447706.140.2
3 pg
…a court to consider in determining whether
the public interest privilege may be invoked in a particular situation,6 although it has also been stated that the privilege may
not be invoked when the government itself brings suit.7 However…
giuffre-maxwell
gov.uscourts.nysd.447706.24.0
4 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices of
Electronic Filing generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.5
4 pg
…1 G. Maxwell - Confidential
2 and foundation.
3 A. Can you repeat the question,
4 please?
5 Q. Sure.
6 You remember from time to time
7 being at the Dubin residence, correct?
8 A. I do.
9 Q. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.27
5 pg
…to the
18 form and foundation.
19 A. I don't recollect her being in New
20 York and I have no idea where she slept.
21 Q. You don't ever remember seeing
22 Virginia Roberts in New York…
giuffre-maxwell
gov.uscourts.nysd.447706.34.0
3 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.69.0
4 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…including the named
Defendants, to conspire and assist in committing those crimes and additional torts
as well as to protect and conceal his crimes and torts from being discovered.
13. Defendant Epstein displays his enormous wealth,Inwer and influence
to…
giuffre-maxwell
gov.uscourts.nysd.447706.57.0
4 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.44.0
4 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.30.0
3 pg
…Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is
being served this day on the individuals identified below via transmission of Notices of Electronic
Filing generated by CM/ECF.
Laura A. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…discussing sexual topics, undressing in
front of the victim, being present when a minor victim was
undressed, and/or being present for sex acts involving the minor
victim and Epstein.
c. MAXWELL'S presence during minor victims'
interactions with Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.605.0
2 pg
…Clerk of the Court using CM/ECF. I also certify that a true and
correct copy of the foregoing document is being served via transmission of Notices of Electronic
Filing generated by CM/ECF.
Respectfully submitted,
/s/ Jay M. Wolman
…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
… All documents concerning any actual or potential book, television or movie deals
concerning your allegations about being a sex slave.
18. All documents concerning any monetary payments or other consideration received by
you from any media outlet in exchange for…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
…subscribed to,
and who executed the annexed instrument, and being infOrmed by me of the contents of said instrument she
duly acknowledged to me Iha/ she executed the same freely and vo/untarif;· for the uses and purposes
therein mentioned…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…Spencer Kuvin and Jack Scarola.
Ms. Giuffre’s responses to Defendant’s First Set of Discovery Requests are being made
after reasonable inquiry into the relevant facts, and are based only upon the information and
documentation that is presently known…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…As Doe 107 has
previously stated, she lives outside the United States in a culturally
conservative country and lives in fear of her name being released. I therefore
respectfully ask the Court to clarify whether its omission of Doe 107…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…Spencer Kuvin and Jack Scarola.
Ms. Giuffre’s responses to Defendant’s First Set of Discovery Requests are being made
after reasonable inquiry into the relevant facts, and are based only upon the information and
documentation that is presently known…
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