giuffre-maxwell
gov.uscourts.nysd.447706.712.0
11 pg
…e.g., Plaintiff’s Statement of Undisputed Facts in Response to Defendant’s Motion for
Summary Judgment at 4-27 (recounting details of Epstein’s and Defendant’s sex trafficking and sex
abuse conspiracy); see also Plaintiff Giuffre’s Reply…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…- Sl 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
Defendant.
X
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1134.0_5
2 pg
…Id. at 1. But it should not
come as a surprise that those “non-parties,” including those implicated as potential abusers within
Jeffrey Epstein’s sex-trafficking conspiracy, would seek to obscure as much information
concerning their conduct as possible…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…overcome the common law
presumption of openness in judicial proceedings. Giuffre, instead of making a convincing
argument about the law or the facts, has unfortunately chosen to concoct a wild tale of
conspiracy theories, ulterior motives, and personal vendettas. Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…to documents 뒫led by her attorneys, he had a “conspiracy with Epstein to engage in and conceal sex
traf뒫cking,” a claim Dershowitz hotly denies.
PHOTOS: Pervy Politicos? 30 Elected Of뒫cials Who Got…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…sexual-abuse conduct. See id., ¶¶ 171-258 (Counts IX-XIX). The Government also
alleges that Defendants engaged in a civil conspiracy to conceal the unlawful sexual abuse
alleged. See id., ¶¶ 281-287 (Count XXII).
In the present motion, the USVI…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…Id. at
293. The government claimed that the deposition transcripts were relevant to its investigation of
perjury, subordination of perjury, and conspiracy related to the 1970 presidential election in
Chile. Id. The government, “moreover, feared that unless it could obtain…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…21 I'm correct, and I'm happy to argue it to you paragraphs
22 cited -- that there is substantial overlap between the cases,
23 and Ms. Giuffre has put at issue a conspiracy here between,
24 allegedly, Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…tellingly, Plaintiff in her current Response hurls
unsupported and spurious claims about Ms. Maxwell’s supposed “hiding of assets” her vast
wealth, her tremendous “conspiracy,” and uses as support, media speculation. It would appear
that Plaintiff intends to generate, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…the truth.
10
These documents do not lie, and moreover make it abundantly clear that Defendant was far
from truthful during her deposition when she denied being a part of Epstein’s sexual abuse
conspiracy. Rather than engage Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…the truth.
10
These documents do not lie, and moreover make it abundantly clear that Defendant was far
from truthful during her deposition when she denied being a part of Epstein’s sexual abuse
conspiracy. Rather than engage Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…during her July 2016 deposition about
Second, all other witnesses
who testified in this action may be witnesses in the criminal trial under either Rule 404(b) or
background to the conspiracy; both cases allege an ongoing conspiracy between Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…her
deposition testimony. Maxwell Br. at 8-10. The public is entitled to review information
concerning Jeffrey Epstein’s sex-trafficking conspiracy that, until recently and until this unsealing
process began, remained largely unpunished and undisclosed. Because Maxwell’s deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…R. Civ. P. 24............................................................................................................................. 7
5
Case 1:15-cv-07433-LAP Document 1259 Filed 07/28/22 Page 6 of 17
MEMORANDUM OF LAW
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…29
Moreover, Ms. Ransome sat for ten hours of deposition and gave critical testimony showing
Defendant’s direct involvement in Epstein’s sex abuse and sex trafficking conspiracy:
Key Testimony Transcript Citation
Maxwell provided Ransome Dep. Tr. at 331 (Q…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…fact
from which an obvious adverse inference could be drawn that Dershowitz was,
indeed, involved in Epstein's crimes;
• In moving down from the top of Epstein's criminal conspiracy to the next
echelon, three women — Sarah Kellen, Adrianna Mucinska…
giuffre-maxwell
gov.uscourts.nysd.447706.995.0
11 pg
…here. Simply put, allowing
individuals such as John Doe (who could be one of the individuals implicated in the Epstein
conspiracy) to proceed anonymously in these unsealing proceedings is not one of the permissible
“tools” the Second Circuit identified. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…them.
Dershowitz played a key role in negotiating a secret provision in Epstein's plea
Alan Oershowitz and Israeli ambassador
deal that immunized • any potential co-conspirators" from federal prosecution.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…her eternal silence. If she breaks this
agreement, she is dead.
She told me how it was a complete conspiracy as Alan Dershowitz, whom was one of the lawyers
that represented Jeffery when he went to trail, made huge endorsements…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…Giuffre of her right to jury trial borders on frivolous. Ms. Giuffre is a
courageous young woman who has come forward to reveal the broad dimensions of a sex
trafficking ring – a criminal conspiracy that involved Defendant. That fact, alone…
Comments