giuffre-maxwell
gov.uscourts.nysd.447706.1258.0
3 pg
…and requests that the Court unseal and make
public and unredacted any and all documents that identify the men who abused the girls trafficked
by Jeffrey Epstein and Defendant Maxwell (“the Epstein Client List”).
Sealing those documents violates the rights…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…Americas
New York, New York 10026
MAGNA& LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1331-26 Filed 01/05/24 Page 3 of 5
Page 84
1 G Maxwell - Confidential
2 30 girls --
3 A. I did not…
giuffre-maxwell
gov.uscourts.nysd.447706.1264.0
1 pg
…the purpose of moving to unseal and
make public a hypothetical set of documents that TGP speculates identify a group of non-parties
in this action who allegedly “abused girls trafficked by Jeffrey Epstein and Defendant Maxwell.”
See DE 1258…
giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
… 27 (Giuffre “described Maxwell’s
role as one of the main women who Epstein used to procure under-aged girls for sexual activities
1
Defendant has labelled her entire deposition transcript as Confidential at this time.
1
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.28
3 pg
…ft By Radar Staff
~ Posted on Jul 7, 2016 @ 6:44AM
I rt J JO
This disturbing picture of a very young girl
hinted at Epstein's pedophile proclivities.
One source told the cops, according to
Radar's report…
giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…Sun, Jan 4, 2015
Ghislaine Maxwell: ‘I was not a madam
for paedophile’
SOCIALITE Ghislaine Maxwell dismissed claims yesterday that she
acted as a “madam” to supply underage girls to US businessman
Jeffrey Epstein.
PUBLISHED: 00:10, Sun, Jan 4…
giuffre-maxwell
gov.uscourts.nysd.447706.55.15
2 pg
…amid
renewed gossip about her relationship with disgraced mogul Jeffrey Epstein.
Maxwell’s been accused of acting as a “madam” and “procuring girls” for wealthy sex
offen…
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
… 27 (Giuffre “described Maxwell’s
role as one of the main women who Epstein used to procure under-aged girls for sexual activities
1
Defendant has labelled her entire deposition transcript as Confidential at this time.
1
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.27_1
5 pg
…
3 A. Yes.
4 Q. Now, when counsel for the Plaintiff was
5 asking you questions, he kept referring to females
6 as girls, okay?
7 A. Yes.
8 Q. So is it fair to say that other than
9…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.5_2
4 pg
…cv-07433-LAP Document 1137-5 Filed 10/22/20 Page 4 of 4
Page 82
1 G Maxwell - Confidential
2 Q. Did you train Virginia on how to
3 recruit other girls to perform sexual
4 massages?
5 MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…District of New York
(the ··New York case''). The case concerns a defamation action brought by a rhiJd victim of
convicted pedophile Jeffrey Epstein .against his live-in girlfriend who assisted him in prncuring
undcrag1: girls, including the plaintirt: Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.38
5 pg
…3 A. Yes.
4 Q. Now, when counsel for the Plaintiff was
5 asking you questions, he kept referring to females
6 as girls, okay?
7 A. Yes.
8
9
10 -
Q.
Jane Doe 2 , you understood at the time…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.2
4 pg
…What did you hear?
6 A. I heard him call someone, and say, Fekkai
7 is in Hawaii. Can we find some girls for him?
8 Q. And what was your reaction to that?
9 A. Well, I was massaging…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.22_1
10 pg
…mis-impression with the public that Ms.
Maxwell has in some way conceded that to be true. She has not.
3. “Detective Joseph Recarey … testified that Defendant procured underage girls
for Epstein” (Reply at 3, n.4). In fact…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.7_2
4 pg
… What are you asking me?
19 Q. I' m asking if the massage
20 therapists --
21 A. Are you asking me about underage
22 girls?
23 Q. I ' m asking in general, did any of
24 the massage therapists in…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.22
17 pg
… 27 (Giuffre “described Maxwell’s
role as one of the main women who Epstein used to procure under-aged girls for sexual activities
1
Defendant has labelled her entire deposition transcript as Confidential at this time.
1
The questions…
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.447706.1335.7
469 pg
…her in your phone call?
4 A. I told her what Jeffrey
5 Epstein and Ghislaine Maxwell did to
6 me and the other girls.
7 Q. Did she give you any money
8 in exchange for that interview?
9…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…once
of
vulnernble girls that looked like the "sweet girl nex t door" but now that they have been taken advantage ofby thi s "disgusting wall street tyrant" m…
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…
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