giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…sex offender Jeffrey Epstein and Defendant were engaging in sexual trafficking conduct;
the later part of that period includes the investigations by law enforcement and the co-
conspirator’s efforts to coordinate and cover up the abuse that occurred. Therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…receipt of payments from Epstein, and documents showing her attempts to
cover up her wrongful sexual abuse of minors are relevant.
There are already materials implicating Defendant’s post-2008 involvement with Epstein
and the related cover-up. For example…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…15 Here's my concern, your Honor, I guess: If there's a
16 witness that shows up in court, I think it's prejudicial to the
17 defendant if we're using initials or things like that, because
18 …
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…Dkt. 991, and states as follows.
INTRODUCTION
Of the nine categories of documents that the parties agreed upon for purposes of the Court’s
unsealing analysis, Maxwell concedes that eight consist of “judicial documents,” 1 Dkt. 991 at 2,
which…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…fact, seeking
only to response Plaintiff on one subject: “Defendant should be ordered to sit for a follow-up
deposition and directed to answer questions regarding her knowledge of alleged “adult” sexual
activity.” Plaintiff’s Motion to Compel Deposition Questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…Q. Did you ever bring someone who was
11 areas. I will leave it up to you, but 11 under -- invite someone under the age of 18
12 if this is general background it will 12 to Jeffrey's home…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…fine.
9 I assumed by your first question
10 you were going into more sensitive
11 areas. I will leave it up to you, but
12 if this is general background it will
13 not be designated as confidential.
14 …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…fine.
9 I assumed by your first question
10 you were going into more sensitive
11 areas. I will leave it up to you, but
12 if this is general background it will
13 not be designated as confidential.
14 …
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…the scope of the litigation or to negotiate
19 a resolution in advance of litigation. That prelitigation
20 privilege does not cover public statements by Ms. Maxwell's
21 hired press agent that are given to the national and
22…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…fact, seeking
only to response Plaintiff on one subject: “Defendant should be ordered to sit for a follow-up
deposition and directed to answer questions regarding her knowledge of alleged “adult” sexual
activity.” Plaintiff’s Motion to Compel Deposition Questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…to
confer with Defendant to secure her agreement to be deposed on this new information, Defendant
refused to sit for a follow up deposition (despite the fact that Ms. Giuffre agreed to sit for her
deposition under these same circumstance)…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
…fine.
9 I assumed by your first question
10 you were going into more sensitive
11 areas. I will leave it up to you, but
12 if this is general background it will
13 not be designated as confidential.
14 …
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…the scope of the litigation or to negotiate
19 a resolution in advance of litigation. That prelitigation
20 privilege does not cover public statements by Ms. Maxwell's
21 hired press agent that are given to the national and
22…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.19
106 pg
…Q. Did you ever bring someone who was
11 areas. I will leave it up to you, but 11 under -- invite someone under the age of 18
12 if this is general background it will 12 to Jeffrey's home…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…Defendant’s sexual relationship with Epstein from 1992 to 2009 – the time period in which she
worked for Jeffrey Epstein and which Epstein (with the assistance of Defendant) was engaging in
sexual acts with females under the cover of “massage”…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…statement from
house employee Juan Alessi in which he revealed that girls would come over to give “massages”
and he observed Ms. Maxwell going upstairs in the direction of the bedroom quarters. See Decl.
of Sigrid McCawley at Exhibit 7…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…to bully
the victim back into silence. But this story will not end here. Defamation law protects victims
when they are courageous enough to stand up against their abuser’s false character assaults. Based
on her well-pled Complaint, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…motives, and character into question by virtue of her claims in this lawsuit,
Plaintiff must be prepared to cough up any evidence – or more likely, contradictory evidence – that she and her 15
attorneys’ have spent the last 5 years of…
giuffre-maxwell
1320-6
10 pg
…Defendant’s sexual relationship with Epstein from 1992 to 2009 – the time period in which she
worked for Jeffrey Epstein and which Epstein (with the assistance of Defendant) was engaging in
sexual acts with females under the cover of “massage”…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…explanation for her expansive time frame as discussed below.
The gist of Plaintiff’s temporal relevance argument is that, according to Plaintiff, Ms.
Maxwell communicated or associated with Mr. Epstein after 2002 up to 2015. And, according to
Plaintiff, Mr…
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