giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…enterprise operated in a
hierarchal strucfire with Defendants Jeffrey Epstein and Ghislaine Ma>rwell at the
top and rurderlings below. Underlings included the other named Defendants as
well as unnarned co-conspirators such as various housekeepers and butlen; an
airplane pilot…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…the global stage at that point [when she held the
bonfire]. She is a child victim of sex abuse at the hands of the defendant [and] co-
conspirators, and she decided to burn certain memories as a step toward the
…
giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…Epstein.
9 As you know, Ms. Giuffre has made allegations that she
10 was sexually trafficked by Epstein's conspiracy in which
11 Ms. Giuffre was the madam or key lieutenant. So he's the first
12 most important witness…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…1). at~ 27 (Giuffre "described
Maxwell's role as one of the main women who Epstein used to procure under-aged girls for
sexual activities and a primary co-conspirator and participant in his sexual abuse and sex
trafficking scheme'')…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…to procure under-aged girls for sexual activities
1
Defendant has labelled her entire deposition transcript as Confidential at this time.
1
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…to procure under-aged girls for sexual activities
1
Defendant has labelled her entire deposition transcript as Confidential at this time.
1
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…at this time.
1
Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 2 of 17
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…at ¶ 27 (Giuffre “described
Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for
sexual activities and a primary co-conspirator and participant in his sexual abuse and sex
trafficking scheme”). In…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…Florida, and in this District. Between 2001 and 2007, with the assistance of numerous
co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by
state and federal law enforcement.
10. As part of their sex…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…at this time.
1
Case 1:15-cv-07433-LAP Document 1218-1 Filed 07/15/21 Page 2 of 17
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
1320-2
10 pg
…1). at 127 (Giuffre '·described
Maxwell's role as one of the main women who Epstein used to procure under-aged girls for
sexual activities and a primary co-conspirator and participant in his sexual abuse and sex
trafficking scheme'')…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…Florida, and in this District. Between 2001 and 2007, with the assistance of numerous
co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by
state and federal law enforcement.
10. As part of their sex…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…Florida, and in this District. Between 2001 and 2007, with the assistance of numerous
co-conspirators, Epstein abused more than thirty (30) minor underage girls, a fact confirmed by
state and federal law enforcement.
10. As part of their sex…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.2
10 pg
…1). at 127 (Giuffre '·described
Maxwell's role as one of the main women who Epstein used to procure under-aged girls for
sexual activities and a primary co-conspirator and participant in his sexual abuse and sex
trafficking scheme'')…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…Defendant’s Resp. at 3. Tellingly, Defendant’s response brief
cites no authority to refute that proposition that adverse inference can be drawn against co-
conspirators. Presumably this is because, as recounted in Ms. Giuffre’s opening brief (at pp…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…Defendant’s Resp. at 3. Tellingly, Defendant’s response brief
cites no authority to refute that proposition that adverse inference can be drawn against co-
conspirators. Presumably this is because, as recounted in Ms. Giuffre’s opening brief (at pp…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Marcinkova was specifically identified by the U.S. Attorney’s
Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non-
prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his sexual abuse and sex trafficking scheme. In fact…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…Marcinkova was specifically identified by the U.S. Attorney’s
Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non-
prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
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