giuffre-maxwell
gov.uscourts.nysd.447706.768.0
23 pg
…Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF MS. GIUFFRE’S RESPONSE TO
DEFENDANT’S MOTION TO PROHIBIT QUESTIONING
REGARDING DEFENDANTS’ ADULT CONSENSUAL ACTIVITIES
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.28
38 pg
…7 Ms. Roberts.
8 Virginia's mother outside the house so the 8 To the extent you are asking for
9 answer to the question is no. 9 information relating to any consensual
10 Q. No, did you not walk…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.2
56 pg
…see -- can you read back the question?
11 (Record read.)
12 A. I'm not addressing any questions
13 about consensual adult sex. If you want to
14 talk about what the subject matter, which is
15 defamation and lying…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…privilege against self-
incrimination and was questioned extensively about, among other things: her relationship with
Jeffrey Epstein, her knowledge of “sexual trafficking,” sex with minors, non-consensual sex, sex
involving the Plaintiff and others, sex involving Plaintiff and Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…BUNNER AND THOMPSON AND THAT THIS .
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…7 Ms. Roberts.
8 Virginia's mother outside the house so the 8 To the extent you are asking for
9 answer to the question is no. 9 information relating to any consensual
10 Q. No, did you not walk…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…6 you've termed it, sexual trafficking of
7 Ms. Roberts.
8 To the extent you are asking for
9 information relating to any consensual
10 adult interaction between my client and
11 Mr. Epstein, I'm going to instruct…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…6 you've termed it, sexual trafficking of
7 Ms. Roberts.
8 To the extent you are asking for
9 information relating to any consensual
10 adult interaction between my client and
11 Mr. Epstein, I'm going to instruct…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…privilege against self-
incrimination and was questioned extensively about, among other things: her relationship with
Jeffrey Epstein, her knowledge of “sexual trafficking,” sex with minors, non-consensual sex, sex
involving the Plaintiff and others, sex involving Plaintiff and Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
…6 you've termed it, sexual trafficking of
7 Ms. Roberts.
8 To the extent you are asking for
9 information relating to any consensual
10 adult interaction between my client and
11 Mr. Epstein, I'm going to instruct…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.5
56 pg
…see -- can you read back the question?
11 (Record read.)
12 A. I'm not addressing any questions
13 about consensual adult sex. If you want to
14 talk about what the subject matter, which is
15 defamation and lying…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.19
106 pg
…7 Ms. Roberts.
8 Virginia's mother outside the house so the 8 To the extent you are asking for
9 answer to the question is no. 9 information relating to any consensual
10 Q. No, did you not walk…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…s theory of discovery, Ms. Giuffre would be precluded
from deposing her on that topic because the actions would culminate in “consensual adult sex.”
Yet, that scenario would fully validate the pattern of events that occurred with Ms. Giuffre when
…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…s theory of discovery, Ms. Giuffre would be precluded
from deposing her on that topic because the actions would culminate in “consensual adult sex.”
Yet, that scenario would fully validate the pattern of events that occurred with Ms. Giuffre when
…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.9_7
56 pg
…see -- can you read back the question?
11 (Record read.)
12 A. I'm not addressing any questions
13 about consensual adult sex. If you want to
14 talk about what the subject matter, which is
15 defamation and lying…
giuffre-maxwell
1320-6
10 pg
…s theory of discovery, Ms. Giuffre would be precluded
from deposing her on that topic because the actions would culminate in “consensual adult sex.”
Yet, that scenario would fully validate the pattern of events that occurred with Ms. Giuffre when
…
giuffre-maxwell
1320-5
56 pg
…see -- can you read back the question?
11 (Record read.)
12 A. I'm not addressing any questions
13 about consensual adult sex. If you want to
14 talk about what the subject matter, which is
15 defamation and lying…
giuffre-maxwell
gov.uscourts.nysd.447706.1308.1
465 pg
…6 you've termed it, sexual trafficking of
7 Ms. Roberts.
8 To the extent you are asking for
9 information relating to any consensual
10 adult interaction between my client and
11 Mr. Epstein, I'm going to instruct…
Comments