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.447706.1111.1
55 pg
…STATES
VIRGIN ISLANDS, Case No.:
PLAINTIFF,
ACTION FOR DAMAGES
V.
DARREN K. INDYKE, in his capacity as the JURY TRIAL DEMANDED
EXECUTOR FOR THE ESTATE
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.447706.1150.3_2
12 pg
…v=ZFefTM1VAow
14 https://nypost.com/tag/ghislaine-maxwell/
15 https://nypost.com/2020/11/03/two-epstein-victims-drop-cases-against-estate-ghislaine-maxwell/
16 https://apnews.com/article/new-york-jeffrey-epstein-ghislaine-maxwell-manhattan-ec7b6b0a07aa51bb7c0147d473535bcb
17 https://www…
giuffre-maxwell
gov.uscourts.nysd.447706.205.0
7 pg
…file a motion to quash a subpoena served on a third party when the party has a
personal right or privilege regarding the subject matter of the subpoena. See, e.g., Estate of
Ungar v. Palestinian Authority, 332 Fed. Appx…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…Id.at RFP 25, 27, 28, 29, 30, and 31.
real estate or personal property in which she holds an interest; Id. at RFP 20, 26, and 36.
loans or statements of indebtedness to or from Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…Id.at RFP 25, 27, 28, 29, 30, and 31.
real estate or personal property in which she holds an interest; Id. at RFP 20, 26, and 36.
loans or statements of indebtedness to or from Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.207.0
7 pg
…file a motion to quash a subpoena served on a third party when the party
has a personal right or privilege regarding the subject matter of the subpoena. See, e.g., Estate of
Ungar v. Palestinian Authority, 332 Fed. Appx…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…d] that
plaintiff’s current requests for financial discovery are overbroad.” Id. at 4. There the Plaintiff
sought “three years of tax returns; information regarding real estate holdings, motor vehicles,
investments, and bank and brokerage accounts; documents regarding personal loans…
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.447706.1320.24
16 pg
…Rinaldo Rizzo, an estate manager for a friend
of Defendant and Epstein’s, testified about an episode where Defendant had threatened a terrified
15 year old girl and confiscated her passport to try to make her have sex with Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…Rinaldo Rizzo, an estate manager for a friend
of Defendant and Epstein’s, testified about an episode where Defendant had threatened a terrified
15 year old girl and confiscated her passport to try to make her have sex with Epstein…
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.447706.1320.21
15 pg
…Rinaldo Rizzo, an estate manager for a friend
of Defendant and Epstein’s, testified about an episode where Defendant had threatened a terrified
15 year old girl and confiscated her passport to try to make her have sex with Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.509.0
18 pg
…documents. That obligation arises even pre-suit, if “the party ‘should have known that
the evidence may be relevant to future litigation.’” MASTR Adjustable Rate Mortgages Trust
2006–0A2 v. UBS Real Estate Secs., Inc., 295 F.R.D. 77…
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
1320-21
15 pg
…Rinaldo Rizzo, an estate manager for a friend
of Defendant and Epstein’s, testified about an episode where Defendant had threatened a terrified
15 year old girl and confiscated her passport to try to make her have sex with Epstein…
giuffre-maxwell
1320-27
15 pg
…Rinaldo Rizzo, an estate manager for a friend
of Defendant and Epstein’s, testified about an episode where Defendant had threatened a terrified
15 year old girl and confiscated her passport to try to make her have sex with Epstein…
giuffre-maxwell
1320-24
16 pg
…Rinaldo Rizzo, an estate manager for a friend
of Defendant and Epstein’s, testified about an episode where Defendant had threatened a terrified
15 year old girl and confiscated her passport to try to make her have sex with Epstein…
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