giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…Non-party Sarah Ransome, by and through her undersigned counsel, hereby submits this
Motion for a Protective Order based on harassing and highly personal discovery sought by
subpoena and during her deposition.
BACKGROUND
On February 6, 2017, Defendant served non…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…LAP Document 1078-5 Filed 07/29/20 Page 6 of 161
Socialite Ghislaine Maxwell 'groped a 16-year-old girl
during a naked massage,' victims' lawyer says
dailymail.co.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-groped-16-year…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly ·'adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly relevant to this case…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly “adult” sexual activity related
to Jeffrey Epstein. Because this activity is highly relevant to this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
1320-2
10 pg
…and through her undersigned counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly .. adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…DOC 291 thoroughly outlines: (1) The relationship
between Dershowitz and Epstein; (2) Dershowitz's role representing Epstein during the criminal
investigation of Epstein; (3) Dershowitz's role in negotiating the Non-Prosecution Agreement
("the NPA") between Epstein and the United…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.2
10 pg
…and through her undersigned counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly .. adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.22_1
10 pg
…21 Page 3 of 10
Case 1:15-cv-07433-LAP Document 1199-22 Filed 01/27/21 Page 4 of 10
Q. Do you know what happened during the massage appointments with Jeffrey
Epstein and Virginia Roberts?
A…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.22
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…and other physical evidence, or information of a similar
nature.
(b) During discovery, interrogatories other than those seeking information described
in paragraph (a) above may only be served (1) if they are a more practical method
of obtaining the information…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
…Nadia Macinkova, and various
other girls and guests he brought to the island.
3. During one ofmy visits to the island I met Ghislaine Maxwell. Watching her
interact with the other girls on the island, it became clear to me…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.9
10 pg
…Did you ever see the photo after it was
8 taken?
9 A. I did not.
10 Q. And Ms. Maxwell was present during the --
11 was Ms. Maxwell present during that?
12 A. Yes.
13 Q. What happened next…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.10
14 pg
…and I'm
22 not going to allow --
23 MS. MENNINGER: Do you
24 believe that relevance is a
25 proper objection during a
Highly Confidential
Page 28
1 HIGHLY CONFIDENTIAL AEO
2 with Ms. McCawley over the phone…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…
15 A. I helped out from time to time.
16 Q. So you were working with him during
17 the time period when these underage girls
18 were visiting Jeffrey's home?
19 MR. PAGLIUCA: Objection to the
20 form…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…she was recruited to join
Epstein's harem in 1999 by his friend, the socialite Ghislaine Maxwell.
She says during the three years she worked for Epstein, she was made to entertain his friends and named Prince
Andrew and Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…as a minor, even though
the video had been played publicly for the jury in the underlying trial, and even though a
transcript of his statements during that deposition remained publicly available during and after
the trial. Id. at 55…
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