giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
… AND UNSEAL
ALAN M. DERSHOWITZ declares under penalty of perjury that the following
is true and correct:
1. I am personally familiar with the facts set forth in this Reply Declaration,
which I submit in further support of my pending…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.1
26 pg
…05/24 Page 2 of 26
**ROUGH***Deposition of Tony Figueroa*** ROUGH*** 1
1 UNCERTIFIED TRANSCRIPT DISCLAIMER IN THE MATTER OF
2 Virginia L. Giuffre
v.
3 Ghislaine Maxwell
4 The following transcr…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
… AND UNSEAL
ALAN M. DERSHOWITZ declares under penalty of perjury that the following
is true and correct:
1. I am personally familiar with the facts set forth in this Reply Declaration,
which I submit in further support of my pending…
giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…including Prince Andrew, after moving to New York in 1991 following the death of her father on his
yacht.
According to the documents, a woman identified as Jane Doe 3 says Ms Maxwell asked her to visit Epstein’s
Florida…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
1320-40
19 pg
…DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…3 and Jane Doe 4 as Petitioners (" Rule 15 Motion") ( DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…is on a list of witnesses for trial in a Palm Beach
lawsuit that pits billionaire pedophile Jeffrey Epstein against a Fort
Lauderdale attorney who represents Epstein’s victims.
The case appears bound for trial this summer following a Feb…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…Civ. 7433 (RWS)
Plaintiff,
-against-
DECLARATION OF
GHISLAINE MAXWELL, ALAN M. DERSHOWITZ
Defendant.
ALAN M. DERSHOWITZ declares under penalty of perju…
giuffre-maxwell
gov.uscourts.nysd.447706.382.0
2 pg
…DERSHOWITZ
Defendant.
ALAN M. DERSHOWITZ declares under penalty of perjury that the following
is true and correct:
1. I am personally familiar with the facts set forth in this supplemental declaration,
which I am submitting to clarify certain averments made…
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…Civ. 7433 (RWS)
Plaintiff,
-against-
DECLARATION OF
GHISLAINE MAXWELL, ALAN M. DERSHOWITZ
Defendant.
ALAN M. DERSHOWITZ declares under penalty of perjury that …
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
… AND UNSEAL
ALAN M. DERSHOWITZ declares under penalty of perjury that the following
is true and correct:
1. I am personally familiar with the facts set forth in this Reply Declaration,
which I submit in further support of my pending…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…is attached in both a redlined version and a clean version (See McCawley Decl. at Exhibit 5),
addresses the following important issues:
Opening Paragraph: Given the fact that this case involves sexual abuse
allegations of a minor child, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…on “rotation” for sex with Jeffrey Epstein
during the trips to Epstein’s island. For example, non-party Ransome witnessed the following:
Q. And when you say you were on rotation, you mean you were having sex with Jeffrey
multiple…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…Meredith:
I write to confirm our oral conferral. Please let me know if you disagree with the following or if there is some
other agreement you think we reached:
1. I will endeavor to have my client gain access to…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…by and through her counsel, hereby submits the following
Response in Opposition (“Response”) to Plaintiff’s Motion to Enforce the Court’s Order and
Direct Defendant to Answer Deposition Questions Filed Under Seal (“Motion”), as follows:
INTRODUCTION
This lawsuit presents…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…and allegedly took many of the pictures
displayed on the walls of Epstein’s mansions.
According to one witness, she felt ‘indebted’ to Epstein for helping her following the
mysterious death in 1991 of her father, disgraced tycoon Robert Maxwell…