giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…Order.
28. Any civil complaint or civil demand filed by You or on Your behalf by which You have ever
sought damages or compensation of any form or nature.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…Order.
28. Any civil complaint or civil demand filed by You or on Your behalf by which You have ever
sought damages or compensation of any form or nature.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…He received limited jail‐time, registered as a sex
offender, and agreed to pay compensation to his victims. In return,
prosecutors declined to bring federal charges.
Shortly after Epstein entered his plea, two of his victims,
proceeding as “Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…letter, witness statement, and summary.
28. Any civil complaint or civil demand filed by You or on Your behalf by which You have
ever sought damages or compensation of any form or nature.
30. A copy of your Facebook, Instagram…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…16 Page 7 of 19
10. “Income” includes, without limitation, any revenue, payments, compensation,
remuneration, financial benefit or support or any other financial consideration, or provision of
any other thing of value.
11. “Person” means any natural person, individual, firm…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…164.
• Whether Defendant was aware of any interstate or international transportation of
women, aged 18 to 28, for purposes of having sex with Epstein where they would
receive compensation. Id. at 278-79.
• Whether Defendant could recall interacting with anyone…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…Order.
28. Any civil complaint or civil demand filed by You or on Your behalf by which You have ever
sought damages or compensation of any form or nature.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome…
giuffre-maxwell
gov.uscourts.nysd.447706.881.0
8 pg
… What was the result?
Has anyone been falsely accused of something?
PERSONAL INJURY SUITS
Who has negative feelings about lawsuits seeking compensation for damages or injury?
Who believes there are too many lawsuits?
Who is naturally…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…Russell
Poynter, Head of Legal at Total UK Limited (“Total”), that the size and scale
of the incident was such that civil claims for compensation were inevitable and
E that, given our clients’ connection with the terminal amongst others, it…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…He received limited jail‐time, registered as a sex
offender, and agreed to pay compensation to his victims. In return,
prosecutors declined to bring federal charges.
Shortly after Epstein entered his plea, two of his victims,
proceeding as “Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…He received limited jail‐time, registered as a sex
offender, and agreed to pay compensation to his victims. In return,
prosecutors declined to bring federal charges.
Shortly after Epstein entered his plea, two of his victims,
proceeding as “Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…He received limited jail‐time, registered as a sex
offender, and agreed to pay compensation to his victims. In return,
prosecutors declined to bring federal charges.
Shortly after Epstein entered his plea, two of his victims,
proceeding as “Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…letter, witness statement, and summary.
28. Any civil complaint or civil demand filed by You or on Your behalf by which You have
ever sought damages or compensation of any form or nature.
30. A copy of your Facebook, Instagram…
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