giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
….............. 60
5. The January 2015 statement accurately denied that Ms. Maxwell created
and distributed child pornography and that the Government knows of and
possesses such child pornography. .................................…
giuffre-maxwell
gov.uscourts.nysd.447706.751.9
3 pg
…royal stepped down from his role as a U.K. trade ambassador after he was photographed with Epstein in New York.
Prince Andrew is the second son and third child of Queen Elizabeth II and Prince Philip, Duke of Edinburgh…
giuffre-maxwell
gov.uscourts.nysd.447706.749.0
9 pg
…10) ................................................. 19
11. Plaintiff put her full childhood history and character at issue (Motion in Limine 11) .. 20
12. Victims Refuse Silence is a sham not-for-profit established to create a claim for
defamation per se (Motion in Limine…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
… Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that
Defendant is not prejudiced by the failure to provide information about Ms.
Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
… Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that
Defendant is not prejudiced by the failure to provide information about Ms.
5…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
… Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that
Defendant is not prejudiced by the failure to provide information about Ms.
5…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…reply to one further allegation in this bullshit
She says Epstein and Maxwell asked her
> to have a child for them and to sign a document signing away
> the rights to the child in the event that she…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
… Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that
Defendant is not prejudiced by the failure to provide information about Ms.
Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…was then fifteen years old) to come to Epstein’s
mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators
coerced dozens of other children (including Jane Doe #1 and Jane Doe #2)…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
… Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that
Defendant is not prejudiced by the failure to provide information about Ms.
Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…within the
enterprise were the subjects of a Palm Beach, Florida Police Department criminal
investigation which revealed that Defendant Epstein had engaged in sexual
activities with dozens of young teenage children. Each child was lured into
Defendant Epstein's Palm…
giuffre-maxwell
1320-37
48 pg
… Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that
Defendant is not prejudiced by the failure to provide information about Ms.
5…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
… Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that
Defendant is not prejudiced by the failure to provide information about Ms.
Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
… Due to safety concerns with respect to Ms. Giuffre and her minor children,
she is not at liberty to reveal her present residential location. To ensure that
Defendant is not prejudiced by the failure to provide information about Ms.
5…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…girls. A copy of the Nancy Drew series would be responsive to this request. Photographs of
Ms. Maxwell as a child would be included. Any CD referencing a “girl” might be responsive.
The list goes on and on. And, because…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
…Did you know that Jeffrey Epstein received 13 MR. RHEINHART: That question was asked
14 sexual gratification from directing other…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.3_1
7 pg
…females
20 under the age of 18 in the presence of
21 Jeffrey Epstein at his home?
22 MR. PAGLIUCA: Object to the form
23 and foundation.
24 A. Again, I have friends that have
25 children
MAGNA9 LEGAL SERVICES
giuffre-maxwell
gov.uscourts.nysd.447706.70.0
15 pg
…s discovery in this case in the
following ways:
2
Defendant’s Position: Defendant says Plaintiff lodged baseless objections and is
withholding documents.
Reality: Plaintiff produced non-privileged documents without withholding anything,
except pictures of her minor c…