giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…and in the face of Plaintiff’s sworn denial that
she has had any contact with law enforcement officials from 1996 to the present apart from
supposed “active investigations involving Ghislaine Maxwell,” counsel for Defendant
unearthed numerous records of such…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…again, swearing under oath that I did not sexually abuse
Virginia Roberts Giuffre, and that any allegation or suggestion to the contrary is categorically
false. I never had sexual contact with Ms. Giuffre of any kind, and, to my knowledge…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…The government knew
what was in the had provided that information well before the
investigation began. The government did indeed have previous contact with . And
was instrumental in fomenting the Maxwell prosecution.
The record is surpassingly clear: But for…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…home in Palm Beach is where this document was taken from. It
20 was for purposes of the house staff being able to use to
21 contact people or when people called in, so it was a reference,
22 a…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…having sex with Epstein where they would receive
compensation. Id. at 278-79.
Whether Defendant could remember entering any telephone numbers into a contact book
maintained by Epstein. Id. at 320-22.
Whether a document with Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…sitting on Prince Andrew’s lap with the puppet or caricature. Id. at 289-93.
! Whether Defendant could remember entering any telephone numbers into a contact book
maintained by Epstein. Id. at 320-22.
! Whether a document with Epstein’s…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…taken
out ofthe legal profession. They can't be allowed to have a bar card to victimize
more innocent people."
Hala Gorani — CNN Live (Jan. 5,2015)
"There was no contact, no contact whatsoever. And I will prove it conclusively…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…again, swearing under oath that I did not sexually abuse
Virginia Roberts Giuffre, and that any allegation or suggestion to the contrary is categorically
false. I never had sexual contact with Ms. Giuffre of any kind, and, to my knowledge…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…Privilege1. For the reasons outlined below,
the Court should deny Plaintiff’s Motion to Compel Production of Documents Subject to
Improper Privileges.
INTRODUCTION
Without a single conferral (despite multiple email and telephonic contacts between
counsel in the interim weeks), Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…763-8333
Mr. Pottinger may have knowledge concerning matters at issue, including
Plaintiff’s attempts to sell her story to the media and her contacts with the media.
55. Joseph Recarey
2753 Misty Oaks Circle
Royal Palm Beach, FL 33441
…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…him by various women. See Menninger Decl., Ex. B.
After reading the article, Ms. Ransome contacted Ms. Callahan via email resulting in several
communications with Ms. Callahan, none of which have been produced. See Menninger Decl.
Ex. A at 36…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…purposes of having sex with Epstein where they would receive
compensation. Id. at 278-79.
• Whether Defendant could remember entering any telephone numbers into a contact book
maintained by Epstein. Id. at 320-22.
• Whether a document with Epstein's…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…Jane Doe No. 1 and Jane Doe No. 2
contacted Government counsel to request their agreement to add an additional victim to this case:
a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014,…
giuffre-maxwell
1320-10
28 pg
…sitting on Prince Andrew’s lap with the puppet or caricature. Id. at 289-93.
! Whether Defendant could remember entering any telephone numbers into a contact book
maintained by Epstein. Id. at 320-22.
! Whether a document with Epstein’s…
giuffre-maxwell
1320-40
19 pg
…763-8333
Mr. Pottinger may have knowledge concerning matters at issue, including
Plaintiff’s attempts to sell her story to the media and her contacts with the media.
55. Joseph Recarey
2753 Misty Oaks Circle
Royal Palm Beach, FL 33441
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…my travel, work, and cell
phone records, together with other documentary evidence, prove that I could not have been in
locations in which she claims to have had sexual contact with me, including Little St. James,
New Mexico, Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…I was never massaged by her. There was no contact,” Dershowitz insisted,
calling her a “serial liar, serial prostitute.” But her lawyers insisted in the new court documents that “Dershowitz’s name
http://radaronline.com/exclusives/2015/01/bill-clinton…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…him by various women. See Menninger Decl., Ex. B.
After reading the article, Ms. Ransome contacted Ms. Callahan via email resulting in several
communications with Ms. Callahan, none of which have been produced. See Menninger Decl.
Ex. A at 36…
giuffre-maxwell
gov.uscourts.nysd.447706.363.8
3 pg
…cv-07433-LAP Document 363-8 Filed 08/11/16 Page 1 of 3
Exhibit H
Case 1:15-cv-07433-LAP Document 363-8 Filed 08/11/16 Page 2 of 3
FOR IMMEDIATE RELEASE Contact: Richard A…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…Buckingham Palace issued a statement which said, "It is emphatically denied that the Duke of
York [Andrew] had any form of sexual contact or relationship" with the woman. "Any claim to the contrary is false and
without foundation."
Andrew is…
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