giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…OVERVIEW
1. The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendant, in the sexual exploitation
and abuse of multiple minor girls by Jeffrey Epstein. In
particular, from at least in or about 1994, up to…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…1999. .................................... 56
2. The January 2015 statement accurately denied that Ms. Maxwell
“regularly participate[d] in Epstein’s sexual exploitation of minors” and
that “the Government knows” such fact. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.538.0
10 pg
…1999. .................................... 56
2. The January 2015 statement accurately denied that Ms. Maxwell
“regularly participate[d] in Epstein’s sexual exploitation of minors” and
that “the Government knows” such fact. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…conspirator
in his sexual abuse and sex trafficking scheme. In fact, it became known to the government that
Maxwell herself regularly participated in Epstein’s sexual exploitation of minors, including Jane
Doe #3. Maxwell persuaded Jane Doe #3 (who was…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…as a
government actor, does not have a compelling need for the materials
because “the Government as investigator has awesome powers” which
“render unnecessary its exploitation of the fruits of private
litigation.” See Martindell, 594 F.2d at 296 (citations…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…conspirator
in his sexual abuse and sex trafficking scheme. In fact, it became known to the government that
Maxwell herself regularly participated in Epstein’s sexual exploitation of minors, including Jane
Doe #3. Maxwell persuaded Jane Doe #3 (who was…
giuffre-maxwell
1320-9
10 pg
…conspirator
in his sexual abuse and sex trafficking scheme. In fact, it became known to the government that
Maxwell herself regularly participated in Epstein’s sexual exploitation of minors, including Jane
Doe #3. Maxwell persuaded Jane Doe #3 (who was…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…Doug Band, traveled on many more occasions.” The logs also showed Clinton traveled with other
“employees and/or co-conspirators of Epstein’s that were closely connected to Epstein’s child exploitation and
sexual abuse.”
· “Jane Doe No. 102 stated…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…the Joinder Motion), Giuffre gave an interview to the Daily Mail, a British tabloid
publication, in which she described in detail how she was purportedly recruited by
Epstein for sexual exploitation. See Daily Mail Article dated March 5, 2011, attached
…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…was the
federal government, which has at its disposal special investigatory powers not available to
private litigants.
[T]he Government as investigator has awesome powers which render unnecessary its
exploitation of the fruits of private litigation. Normally the Government may…
giuffre-maxwell
gov.uscourts.nysd.447706.1204.0
3 pg
…as the Miami Herald implies there is, about
Ms. Maxwell challenging the government’s exploitation of its awesome investigatory powers.
To be sure, neither plaintiff nor the Herald challenges Ms. Maxwell’s argument that
her due process rights will be…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…conspirator
in his sexual abuse and sex trafficking scheme. In fact, it became known to the government that
Maxwell herself regularly participated in Epstein’s sexual exploitation of minors, including Jane
Doe #3. Maxwell persuaded Jane Doe #3 (who was…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…B, [GM_01036-
01044]. Any questioning concerning Ms. Maxwell’s involvement or input into the content of the
single statement was available for exploration. Yet, Plaintiff either neglected to or decided not to
question Ms. Maxwell about the majority of…
giuffre-maxwell
gov.uscourts.nysd.447706.233.0
9 pg
…that issue will ultimately play out in the course of these
proceedings – clearly his assertion of the privilege advances not only his interests but also
Defendant’s by preventing exploration of the sexual abuse scheme they worked on together.
Nonetheless…
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