giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…2016, Deposition of
Detective Recarey at pg. 29:11-20. “Q. “Okay. During your investigation, what did you
learn in terms of Ghislaine Maxwell's involvement, if any? THE WITNESS: Ms.
Maxwell, during her research, was found to be Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…2016, Deposition of
Detective Recarey at pg. 29:11-20. “Q. “Okay. During your investigation, what did you
learn in terms of Ghislaine Maxwell's involvement, if any? THE WITNESS: Ms.
Maxwell, during her research, was found to be Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…2016, Deposition of
Detective Recarey at pg. 29:11-20. “Q. “Okay. During your investigation, what did you
learn in terms of Ghislaine Maxwell's involvement, if any? THE WITNESS: Ms.
Maxwell, during her research, was found to be Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…13 A. We flew to Sweden, we stopped at an
14 airport that we didn't usually stop at and
15 she got off the plane.
16 Q. Just so that I make sure I
17 understand, who it was…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…13 A. We flew to Sweden, we stopped at an
14 airport that we didn't usually stop at and
15 she got off the plane.
16 Q. Just so that I make sure I
17 understand, who it was…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…at . . .
. . . . . . . . . . _ Ofc. Wensyel and I w ~ Wildcat Way
at Willows Park when we noticed . . . . . . . . . crossing the road.
Ofc. Wensyel stopped and spoke w ~ a g r e e d to come in
voluntarily. we then .w;oceeded to - - . . . . . . . . . …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…2016, Deposition of
Detective Recarey at pg. 29:11-20. “Q. “Okay. During your investigation, what did you
learn in terms of Ghislaine Maxwell's involvement, if any? THE WITNESS: Ms.
Maxwell, during her research, was found to be Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
…13 A. We flew to Sweden, we stopped at an
14 airport that we didn't usually stop at and
15 she got off the plane.
16 Q. Just so that I make sure I
17 understand, who it was…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…within the
enterprise were the subjects of a Palm Beach, Florida Police Department criminal
investigation which revealed that Defendant Epstein had engaged in sexual
activities with dozens of young teenage children. Each child was lured into
Defendant Epstein's Palm…
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.447706.185.7
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.447706.1295.2
12 pg
…a
police report?
A. I am aware there is a police report.
Q. You are aware there was a criminal investigation of Jeffrey Epstein?
A. I am aware that there was that.
Q. Now that you are aware of those…
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.447706.1201.17
12 pg
…54.
2
Case 1:15-cv-07433-LAP Document 1201-17 Filed 01/27/21 Page 3 of 12
Police Detective Joseph Recarey, who led the investigation of Epstein, testified that
Defendant procured underage girls for Epstein.8 Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
… Annoyance, embarrassment, oppression, undue burden (“Privacy Interests”) (“CI-
3”).
4. Preserving the fundamental rights of suspects or others under criminal
investigation (“CI-4”).
5. Improper submission of documents thereby weaponizing judicial documents (“CI-
…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…documents – Third party sought specific disclosure
of documents – Litigation privilege claimed – Material sought gathered in course C
of investigations into incident – Dominant purpose of investigations so that
solicitors could provide legal advice in connection with expected proceedings
– Implied statutory duty…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…plaintiff’s alleged sex activities involving dozens of
nonparties. While there was no trial and therefore no factual findings, the defense believed its
investigation and the discovery significantly undermined, if not disproved, a large number of
plaintiff’s sex allegations…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.11
18 pg
…and everybody had an attorney, and I was
10 not going to be able to speak with them.
11 Q. Okay. During your investigation, what did
12 you learn in terms of Ghislane Maxwell's
13 involvement, if any?
14 …