giuffre-maxwell
gov.uscourts.nysd.447706.1117.0
1 pg
…documents. ECF No. 1112. Plaintiff does not oppose the USVI’s motion and supports its effort
to conduct a full investigation into the Estate of Jeffrey E. Epstein and Epstein-controlled entities.
Sincerely,
/s/ Sigrid S. McCawley
…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…thereto.
INTRODUCTION
The USVI seeks confidential access to these materials because they are very likely both
relevant and necessary to its pending Virgin Islands Criminally Influenced and Corrupt
Organizations Act (“CICO”) civil enforcement action against the Estate of Jeffrey E…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…hearing. The financier was found dead in his
cell the following month. Ms Farmer is now suing Epstein’s estate and Maxwell in the New
York district court for damages.
According to Ms Farmer’s testimony, detailed in the book…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…No. 1:11-cv-48, 2013 WL 1312563, at *7 (E.D. Tex. Mar. 1, 2013) 8
Moss v. Ole South Real Estate, Inc., 933 F.2d 1300, 1305 (5th Cir. 1991) .................................... 8
Parsons v. Honeywell, Inc., 929 F.2d…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…and Defendant Ms. Maxwell. The
Government contends that intervention will assist in its action to enforce the Virgin Islands
Criminally Influenced and Corrupt Organizations Act (“CICO”) against the Estate of Jeffrey E.
Epstein. The Estate of Jeffrey E. Epstein is…
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…19.”
As for Clinton, Roberts claims she met him at a U.S. Virgin Islands estate owned by Epstein, who allegedly hired her as his
top sex slave when she was just 15. Although she did not have sex with…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…from
Jeffrey Epstein or any related entity to you from 1999 – present, including payments for work
performed, gifts, real estate purchases, living expenses, and payments to your charitable
endeavors including the TerraMar project.
b. Maxwell’s Response to Request No…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…is seeking to drain funds from the very estate that should be paying the
Epstein victims’ claims...We view her actions as unconscionable but this is an individual who lost
sight of right from wrong a very long time ago…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…address, telephone number and
any other identifying information possessed by You.
8. "Person" means any natural person, individual, firm, partnership, association,joint
venture, estate, trust, receiver, syndicate, enterprise or combination, corporation or other
legal, business or government entity.
9. …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…did. ~ l s osays that at this time he was
also approached by his neighbor, who is a real estate agent
and is selling his p a r ~ . said that he needed to take
pictures of the bouse …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…meet ?
2 A. , at the islands.
3 Q. And when you say the islands, do you mean
4 Jeffrey Epstein's estate?
5 A. Yes.
6 Q. And where did you meet Marvin Minsky?
7 A. Marvin Minsky was at…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…hotel records, and credit card receipts.
21. All Documents relating to payments You made, whether as cash, stock, real
estate, or in-kind, to Ghislaine Max\vell, or any related cntity to Ghislainc Maxwell, including
the TerraMar Project.
22. All…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…any other financial consideration, or provision of
any other thing of value.
11. “Person” means any natural person, individual, firm, partnership, association,
joint venture, estate, trust, receiver, syndicate, enterprise or combination, corporation or other
legal, business or government entity.
12. …
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…see infra at 7, because of their potential
relevance to its pending Virgin Islands Criminally Influenced and
Corrupt Organizations Act (“CICO”) enforcement action against the
Estate of Jeffrey E. Epstein and several Epstein-controlled
entities before the Superior Court of…
giuffre-maxwell
gov.uscourts.nysd.447706.55.21
69 pg
…that period?
5 A. Oversees all aspects of the maintenance 5 A. On and off, yes, in Fisher Island,
6 of the estate, payroll of the gardeners, 6 Florida.
7 scheduling staff and security, food, coordinating 7 Q. Fisher Island…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…public’s desire for transparency, the House
Oversight Committee released tens of thousands of Epstein-related records from the U.S.
Department of Justice (“DOJ”) and the Epstein Estate in September and November of 2025.2 On
November 19, 2025…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…any related entity to you from
1999 – present, including payments for work performed, gifts, real estate purchases, living
expenses, and payments to your charitable endeavors including the TerraMar project.
DOCUMENT REQUEST NO. 11
All documents relating to or describing any…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…Where did you meet ?
2 A. , at the islands.
3 Q. And when you say the islands, do you mean
4 Jeffrey Epstein's estate?
5 A. Yes.
6 Q. And where did you meet ?
7 A. …
giuffre-maxwell
gov.uscourts.nysd.447706.55.12
21 pg
…12
1 Then my job changed little by little to house 1 Q. And when Ms. Maxwell started assuming
2 man, estate manager, and then to a majordomo. 2 responsibility for the house, did your duties change at
3 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…citizens in the discussion of these problems. Cernovich Media cannot conduct
its Forth Estate function if this Court allows the Parties to conduct their dispute outside of the
normal sunlight of transparency and accessibility. The public has a right to…
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