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.447706.1078.0
9 pg
…subornation of perjury, obstruction of justice and conspiracy. The government:
speculated that the pretrial deposition testimony might be relevant to its
investigation into matters similar to those that had been the subject of the
Martindell action and might be useful…
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…But as the
Court is aware, each of the actions involving Dershowitz arise out of the same subject matter as
this one: Epstein’s sex-trafficking conspiracy. The documents were relevant to the Court’s
14
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…fought-hide
236 https://www.bloomberg.com/news/storythreads/2020-10-22/ghislaine-maxwell-s-jeffrey-epstein-days-and-the-conspiracy-case-against-her
237 https://www.13newsnow.com/article/news/nation-world/ghislaine-maxwell-transcripts-reelased/507-5adb87e0-aea3…
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.447706.1219.8
29 pg
…of any
publication. Plaintiff’s argument for relevance is nonsense. She claims the JDA might show “the
nature of the ongoing relationship between Ms. Maxwell and her “co-conspirator” and between
Ms. Maxwell and Mr. Dershowitz. Not only would a…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…face allegations of sex abuse is now common place and a lot of resources are focused on this.
We can't sit back and let you be a conspirator by silence.
Your are not guilty and must follow Dershowtiz line…
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.447706.1218.1
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
gov.uscourts.nysd.447706.35.0
31 pg
…Epstein. Therefore, documents evidencing Ms. Giuffre’s encounters with
Maxwell, and documents evidencing Maxwell’s communications with her co-conspirators, are
plainly relevant and discoverable. For example, Request 6 seeks documents relating to
Maxwell’s communications with Sarah Kellen. At…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 7 of 21
Has knowledge of Defendant’s conduct that is the subject of this action and
knowledge of his sexual trafficking operation and other co-conspirators.
25…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…Giuffre
and never had sex with her, but he is entitled to prove that the allegation fails for other reasons as
well). Giuffre has further alleged that Dershowitz was a “co-conspirator” of Jeffrey Epstein and
Ghislaine Maxwell, id. at …
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…There are a few groups of people, his office in New
York and I guess --
***
Q. Okay. The other people mentioned as co-conspirators are Sarah Kellen, Adriana Ross, and
Nadia Marcinkova. So we'll get to them in a…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…1332-14 Filed 01/08/24 Page 4 of 9
including Defendant’s coordination of the press attack on Ms. Giuffre and Defendant’s
coordination of the attack with her co-conspirator, Epstein.
The Court heard oral argument on Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…was part of Epstein’s
account through which he communicated with his employees and other members of his
household, including his co-conspirators , and the Defendant.
This email account likely has (or had) myriad of communications between and among Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…There are a few groups of people, his office in New
York and I guess --
***
Q. Okay. The other people mentioned as co-conspirators are Sarah Kellen, Adriana Ross, and
Nadia Marcinkova. So we'll get to them in a…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…was part of Epstein’s
account through which he communicated with his employees and other members of his
household, including his co-conspirators , and the Defendant.
This email account likely has (or had) myriad of communications between and among Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Menninger Decl. Exhibit G shows an email chain containing six
communications she had with , an alleged co-conspirator, yet only two of those
emails were produced. The emails produced are in “screenshot” format rather than providing a
complete production of…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…There are a few groups of people, his office in New
York and I guess --
***
Q. Okay. The other people mentioned as co-conspirators are Sarah Kellen, Adriana Ross, and
Nadia Marcinkova. So we'll get to them in a…
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