giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…used his vast wealth and property holdings and a deliberately opaque web of
corporations and companies to transport young women and girls to his privately-owned islands
where they were held captive and subject to severe and extensive sexual abuse…
giuffre-maxwell
gov.uscourts.nysd.447706.1302.0
3 pg
…of “any and all documents” filed in Giuffre v. Maxwell that “identify the men who abused
the girls trafficked by Jeffrey Epstein and Defendant Maxwell.” Appellant’s App’x at 260. The
District Court denied TGP’s motion to intervene…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…financier Jeffrey
Epstein. (Accused of having sexual relations with multiple underage girls, Epstein ultimately
pleaded guilty to just a single state charge of soliciting prostitution.)
Case 1:15-cv-07433-LAP Document 363-11 Filed 08/11/16 Page…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…co-counsel Bradley J. Edwards, I have been pursuing a federal case pro bono on behalf of two
young women who were sexually abused as underage girls by Dershowitz’s close personal friend
– Jeffrey Epstein.
6. During the litigation, Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…s role in negotiating the Non-Prosecution Agreement
("the NPA") between Epstein and the United States; (4) Facts inferring that Dershowitz was
aware of Epstein's illegal sexual activities with underage girls; and (5) Dershowitz's
participation in those activities…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…massage. I don’t remember seeing Bill again on the trip but I
assume Ghislaine flew him back.”
See Sharon Churcher, “Teenage girl recruited by peadophile Jeffrey Epstein reveals how she
twice met Bill Clinton,” DAILY MAIL (Mar. 5…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…of 13
alleged that Ms. Maxwell was a ringleader in Jeffrey Epstein’s
sex-trafficking scheme, a trusted lieutenant of Epstein’s who
facilitated his purported trafficking of underage girls to
prominent individuals. Ms. Giuffre’s defamation action against
Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…living arrangements. She is not citing this countervailing interest
because she believes there is any evidence of “misconduct” or the “sexual abuse of young girls at
the hands of the wealthy and powerful,” as the Miami Herald speculates. While the…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…the public
interest in disclosure, which will shed light on the abuse of young girls and women—and the
system that allowed the abuse to continue.
Claims of Inaccuracies Do Not Warrant Sealing
Likewise, concerns about the accuracy or veracity…
giuffre-maxwell
gov.uscourts.nysd.447706.1237.0
20 pg
…Hr’g Tr. 4:10-16
(“In the context of this case, especially its allegations of sex trafficking of young girls, the Court
finds that any minor embarrassment or annoyance resulting from disclosure of Ms. Maxwell’s
mostly nontestimony about…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…16 What's relevant to that is the sexual trafficking
17 ring. If after my client left they are also trafficking other
18 underaged girls repetitively, that is relevant to prove the
19 truth of my client's allegations as…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…Epstein and a person under the age of 18.
25. Identify all girls under the age of 18 with whom you have interacted at one of
Epstein’s properties, including his Palm Beach mansion or his New York City mansion…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…Jane Doe 43
Dep. Tr. 216; 250-251; Jane Doe 43000002-15.
x She testified that she and the other girls were frightened of Epstein and Ghislaine
Maxwell. Jane Doe 43 Dep. Tr. 44; 283.
x She testified that she…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…addresses (only of their counsel) as to just two, Jeffrey Epstein and Alan
Dershowitz. Plaintiff then also listed categories of witnesses such as “all other then-minor girls,
whose identities Plaintiff will attempt to determine” and “all pilots, chauffeurs, chefs…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…shadows outside of the normal sunlight of transparency and accessibility. The public
has a right to know who trafficked these girls.
The former judge assigned to this case committed a transgression, shielding from scrutiny
that which rightfully should be exposed…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…16 What's relevant to that is the sexual trafficking
17 ring. If after my client left they are also trafficking other
18 underaged girls repetitively, that is relevant to prove the
19 truth of my client's allegations as…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…documents and
communications with, Sarah Kellen and Nadia Marcinkova, when they were asked in
their depositions about Ms. Maxwell sexually trafficking underage girls, both of those
individuals took the Fifth. If there are documents between Ms. Maxwell and Sarah
Kellen…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…used his vast wealth and property holdings and a deliberately
opaque web of corporations and companies to transport young women
and girls to his privately-owned islands where they were held
captive and subject to severe and extensive sexual abuse.” …
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…when the Palm Beach
Police Department was first investigating Epstein’s sexual abuse, the Department accumulated
overwhelming evidence placing underage girls at Epstein’s residence who gave statements that
they were being sexually abused, the accounts bearing chillingly similar details…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…Ms. Giuffre sought to
join a long-running Crime Victims’ Rights Act (“CVRA”) lawsuit, which was brought by other
young girls who were also abused, and sought to challenge Jeffrey Epstein’s non-prosecution
agreement which also pardoned co-conspirators…
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