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.447706.1320.9
10 pg
…Brunel was another of Epstein’s closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. Brunel has been a
model scout for various modeling agencies for many years and apparently was able…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 10 of 20
As she testified at her deposition, Ms. Maxwell has contacted a number of professional
masseuses from spas in various locations, including New York, Palm Beach…
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.447706.1320.17
25 pg
…information concerning who prepared
documents, the location of any copies of such documents, the identities and contact information
for persons who have custody or control of such documents, the reasons for inability to produce
portions of documents, and the “natural…
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.447706.1320.40
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.447706.1137.12_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.447706.1328.18
50 pg
…Moreover, these documents are featured in Defendant’s briefs,
Defendant issued subpoenas to both Sharon Churcher and Jarred Weissfeld months ago, and
Defendant has deposed Ms. Giuffre about her media contacts. See McCawley Decl. at Composite
Exhibit 1, Defendant’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
… was another of Epstein’s closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. has been a
model scout for various modeling agencies for many years and apparently was able to get…
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
1320-17
25 pg
…information concerning who prepared
documents, the location of any copies of such documents, the identities and contact information
for persons who have custody or control of such documents, the reasons for inability to produce
portions of documents, and the “natural…
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
1320-9
10 pg
…Brunel was another of Epstein’s closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. Brunel has been a
model scout for various modeling agencies for many years and apparently was able…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
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…
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