giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
… “Objected” to Question Number 5
Without any record support Plaintiff claims that “Defendant’s counsel also stopped a line
of questioning in which defendant was asked if she recalled several girls brought
over to give a ‘massage’ to Epstein.” Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…Indeed, a contemporaneous document, the manuscript,
stated the same thing:
Nobody ever stopped to ask if I was comfortable or if I wanted to stop, no,
instead, Ghislane [sic] only directed me to conclude the massage session by
climbing up…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…public, to marshalling
every bit of information within his control to demonstrate that the allegations cannot be true, to
submitting to a full investigation of the charges by former federal judge and FBI Director Louis
Freeh, who exonerated him. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.6
32 pg
…public, to marshalling
every bit of information within his control to demonstrate that the allegations cannot be true, to
submitting to a full investigation of the charges by former federal judge and FBI Director Louis
Freeh, who exonerated him. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…information and belief. Ms. Maxwell, through her attorneys of record, have not completed the
investigation of the facts relating to this case, have not completed discovery in this action, and
have not completed preparation for trial. Ms. Maxwell’s responses…
giuffre-maxwell
1320-17
25 pg
…information and belief. Ms. Maxwell, through her attorneys of record, have not completed the
investigation of the facts relating to this case, have not completed discovery in this action, and
have not completed preparation for trial. Ms. Maxwell’s responses…
giuffre-maxwell
gov.uscourts.nysd.447706.79.2
18 pg
…well’s presentknowled ge,
information and belief.M s.M ax well,throu ghherattorneys of record ,have notcompleted the
investigation of the facts relatingto this case,have notcompleted d iscovery in this action,and
have notcompleted preparation fortrial.M s…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…DOC 291 thoroughly outlines: (1) The relationship
between Dershowitz and Epstein; (2) Dershowitz's role representing Epstein during the criminal
investigation of Epstein; (3) Dershowitz's role in negotiating the Non-Prosecution Agreement
("the NPA") between Epstein and the United…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…Ms. Giuffre were
to submit an affidavit repeating her false allegations against me, I would welcome and cooperate
with a criminal investigation by any prosecutorial office as to whether it is Ms. Giuffre or I who
is committing perjury. It…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…on him.
Either Virginia Roberts is lying or not. If we let her lie without challenge then the lies become the reality and
that may lead to you facing investigation. These are serious allegations and In the UK prosecuting people…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…information and belief. Ms. Maxwell, through her attorneys of record, have not completed the
investigation of the facts relating to this case, have not completed discovery in this action, and
have not completed preparation for trial. Ms. Maxwell’s responses…
giuffre-maxwell
gov.uscourts.nysd.447706.103.2
3 pg
…the Southern District of Florida (the “Office”), the Office was recused by the Department of
Justice from prospective responsibility for any criminal investigation or potential prosecution
relating to Jeffrey Epstein’s alleged sexual activities with minor females. As a result…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…Ms. Giuffre were
to submit an affidavit repeating her false allegations against me, I would welcome and cooperate
with a criminal investigation by any prosecutorial office as to whether it is Ms. Giuffre or I who
is committing perjury. It…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…LAP Document 1218-31 Filed 07/15/21 Page 4 of 10
Page 110
1 JOSEPH RECAREY - CONFIDENTIAL
2 Basically trying to dirty the victim as much as
3 possible.
4 He accused me of lying in my
5 investigation…
giuffre-maxwell
gov.uscourts.nysd.447706.382.0
2 pg
…to solicitation of prostitution and to procuring a person
under the age of 18 for prostitution.
3. In paragraph 11 of my previous declaration, I stated: “During the criminal
investigation of Mr. Epstein, which spanned the years 2006 through 2008…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…Ms. Giuffre were
to submit an affidavit repeating her false allegations against me, I would welcome and cooperate
with a criminal investigation by any prosecutorial office as to whether it is Ms. Giuffre or I who
is committing perjury. It…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.22_1
10 pg
…Reply at 3, n.4). In fact, Detective Recarey testified that none of the underage girls
interviewed in connection with his investigation into Epstein claimed to have been hired by
Maxwell; in fact, none of them mentioned Ms. Maxwell at…
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…that they don’t have to follow the same rules as everyone else. That is
wrong.”
READ The Bombshell Court Documents
Roberts declared, “I will cooperate fully in the investigation and prosecution of Epstein, [Ghislaine] Maxwell, or any of their
…
giuffre-maxwell
gov.uscourts.nysd.447706.956.0
3 pg
…Mr. Dershowitz joined a defense team assembled by
Jeffrey Epstein, a financier who was then under investigation for having sex with underage girls.
In 2008, Mr. Epstein pleaded guilty to state charges of solicitation of prostitution and solicitation
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.75.0
31 pg
…Defamatory” actions by others is relevant.................................................................... 20
D. Plaintiff’s incomplete and evasive answers are improper. ............................................. 21
1. Interrogatory responses limited to memory without any investigation are improper. ... 21
2. …