giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…Florida alone, most of which were recruited after Ms. Giuffre escaped.10 Such documents would
show a pattern and practice of Defendant’s behavior and also show Defendant’s role within
Jeffrey Epstein’s criminal enterprise. That Ms. Giuffre was…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…joint
venture, estate, trust, receiver, syndicate, enterprise or combination, corporation or other
legal, business or government entity.
9. Regardless of the tense employed, all verbs should be read as applying to the past,
present and future, as is necessary to…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…person, individual, firm, partnership, association,
joint venture, estate, trust, receiver, syndicate, enterprise or combination, corporation or other
legal, business or government entity.
12. “Relate,” “relating,” “relates” means concerning, referring to, responding to,
relating to, pertaining to, connected with, eviden…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…with underage minors.
93. All females identified in the police reports or identified through the United State's
Attorney's office during or through the criminal investigation of Jeffrey Epstein
and his co-conspirators.
94. All other then-minor girls…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…Ms. Giuffre were
to submit an affidavit repeating her false allegations against me, I would welcome and cooperate
with a criminal investigation by any prosecutorial office as to whether it is Ms. Giuffre or I who
is committing perjury. It…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…In particular, Dershowitz went
so far as to repeatedly accuse Edwards and Cassell of criminal misconduct in actively suborning
perjury and fabricating the allegations of misconduct against him — acts that would warrant their
disbarment from the legal profession. The undisputed…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…Ms. Giuffre were
to submit an affidavit repeating her false allegations against me, I would welcome and cooperate
with a criminal investigation by any prosecutorial office as to whether it is Ms. Giuffre or I who
is committing perjury. It…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…Scarola said.
Still, the spectacle of a U.S. president being drawn into sordid litigation involving a notorious politically connected
sexual criminal who got an apparent sweetheart deal from then-Miami U.S. Attorney Alex Acosta, now Trump’s
nominee…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…or in the
Alternative Modification of the Protective Order.
3. I am the Ronald N. Boyce Presidential Professor of Criminal Law and University
Distinguished Professor of Law at the S.J. Quinney College of Law, where I teach criminal
procedure…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…or in the
Alternative Modification of the Protective Order.
3. I am the Ronald N. Boyce Presidential Professor of Criminal Law and University
Distinguished Professor of Law at the S.J. Quinney College of Law, where I teach criminal
procedure…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…Ms. Giuffre were
to submit an affidavit repeating her false allegations against me, I would welcome and cooperate
with a criminal investigation by any prosecutorial office as to whether it is Ms. Giuffre or I who
is committing perjury. It…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…of a person in either a
naked or semi-naked state. Id. at 193.
Whether Defendant could recall what Epstein told her about the criminal investigation of
him. Id. at 194-95.
Whether Epstein told Defendant that he…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…credible
evidence of the defendant's criminal conduct' - with more women coming forward in the
past week.
The victims have made clear they want Maxwell remanded in custody and say they were
'directly abused as a result of Ghislaine Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…person in either a
naked or semi-naked state. Id. at 193.
! Whether Defendant could recall what Epstein told her about the criminal investigation of
him. Id. at 194-95.
! Whether Epstein told Defendant that he never had sex with…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…him to defame Ms. Giuffre.
Defendant has also chosen to designate as confidential the fact that she has a DUI conviction,14
so that her own criminal activity for which she has been convicted is not in the media.
II. …
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…a
police report?
A. I am aware there is a police report.
Q. You are aware there was a criminal investigation of Jeffrey Epstein?
A. I am aware that there was that.
Q. Now that you are aware of those…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…agents, investigators, from the period 1999-present.
2. All fee agreements for Your engagements with any attorneys for the purpose of pursuing
any civil or criminal claims regarding Jeffrey Epstein, Ghislaine Maxwell,
29. A copy of Your most recent paycheck…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…prope11ies of a person in either a
naked or semi-naked state. Id. at 193.
• Whether Defendant could recall what Epstein told her about the criminal investigation of
him. Id. at 194-95.
• Whether Epstein told Defendant that he never…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…With respect to request 18, her driver's license, your
22 Honor, that provides some background information that can be
23 useful in investigation of an individual's criminal history and
24 the like. We, again, are happy to have…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…the
communication of privilege. “If a person hires a lawyer for advice, there is a rebuttable
presumption that the lawyer is hired ‘as such’ to give ‘legal advice,’ whether the subject of the
advice is criminal or civil, business, tort…