giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…father, sister
and cousin, and walked nearly a mile to Larry Wilkins' home in remote western
Kentucky to get help. There are new developments in the sex scandal involving
Prince Andrew and famed attorney Alan Dershowitz, including the fact that…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…taken (not a
paper copy) not produced in response to Request No. 2, above, of Alan M. Dershowitz at
(i) Jeffrey Epstein’s Manhattan home in New York City, New York; (ii) Mr. Epstein’s
home in Palm Beach, Florida…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…law
enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous
home life, bearing no relationship to any press statements or alleged defamation and providing
alternative causation to any of Plaintiff’s now-claimed emotional distress. It makes…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
… Ms. Maxwell’s Privilege Log Is Sufficient ............................................................... 15
CONCLUSION ............................................................................................................................. 17
ii
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.14
7 pg
… Okay. So, is it your understanding that
19 the only connection then through Citrix with these
20 computers, these various computers that were in
21 Mr. Epstein's home, was for e-mail purposes?
22 A. …
giuffre-maxwell
gov.uscourts.nysd.447706.1187.0
3 pg
…i) private
financial information, such as tax records and bank
account numbers; (ii) personally identifiable
information, such as a social security numbers,
home addresses, personal email addresses or
personal telephone numbers; (iii) protected health
information, inclusive of physical and mental
…
giuffre-maxwell
gov.uscourts.nysd.447706.56.0
14 pg
…Inc. v Bombardier Capital, Inc.,
354 F. App'x 448 (2d Cir. 2009)..................................................................................................2
Pem-Am., Inc. v. Sunham Home Fashions, LLC,
No. 03 CIV. 1377JFKRLE, 2007 WL 3226156 (S.D.N.Y. Oct. 31, 2007).................................7
Rutgerswerke AG & Frendo…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.34
7 pg
… Okay. So, is it your understanding that
19 the only connection then through Citrix with these
20 computers, these various computers that were in
21 Mr. Epstein's home, was for e-mail purposes?
22 A. …
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…law
enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous
home life, bearing no relationship to any press statements or alleged defamation and providing
alternative causation to any of Plaintiff’s now-claimed emotional distress. It makes…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.22_1
10 pg
…have never concluded
that Plaintiff was a “child victim of sexual abuse.” Rather their reports reflect Plaintiff’s false
allegations of being a “child victim of sexual abuse” in situations such as getting in trouble for
running away from home…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.11
18 pg
…15-cv-07433-LAP Document 1325-11 Filed 01/04/24 Page 3 of 18
Page 29
1 JOSEPH RECAREY - CONFIDENTIAL
2 Ghislane Maxwell?
3 A. I wanted to speak with everyone related to
4 this home, including Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…Avenue, Valley Stream, NY 11580-4016
917-975-4500
Jeffrey Epstein's staff member in his various homes and may have knowledge of
Defendant and Jeffrey Epstein’s inappropriate conduct with underage girls.
29. Lynn Fontanilla
18 Teneyck Avenue, Valley…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…documents responsive to this request that she should produce.
7. All photographs and video of You in any of Jeffrey Epstein’s properties,
including, but not limited to: his home in Palm Beach, Florida; his home in New York
City…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…attempts at great cost and inconvenience, and
who then (because of Plaintiff’s last minute unavailability) had to be re-served by a process server who swam
through a swamp to get to his home, at additional cost and inconvenience…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…relevant to Dershowitz’s defense of the sexual assault claims which Giuffre has
brought against him on the theory that he was “on notice” that she was being sexually trafficked
by Epstein merely by observing her in Epstein’s home…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…v. Swilley,
462 So.2d 1188 (Fla. 1st DCA 1985)......................................................................................................30
Rhone-Poulenc Rorer, Inc. v. Home Indem. Co.,
32 F.3d 851 (3d Cir.1994)..........................................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
…that you talked to 25 Q. I'm just confused as to why you told us
Page 336 Page 338
( 1 in the last year? 1 before that …
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
….
Virginia says: ‘Ghislaine said I was to start immediately and that someone would
drive me home.
My father left and I was told to go upstairs.’ She was led by another woman
through Epstein’s bedroom into a massage room…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…where Virginia
was during the period of 2000 – 2002, public records directly contradict this statement and show that he actually had
an apartment in New York not far from Epstein’s home for a year from 2000 – 2001. McCawley Dec…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.11
8 pg
…ever at El Brillo Way?
8 Q. And you didn't think that the massage 8 A. I never saw what was going on inside the
9 table at a home was unusual? 9 house, Ma'am.
10 A. No…