giuffre-maxwell
gov.uscourts.nysd.447706.908.0
4 pg
…Defendant.
________________________________/
MOTION FOR ORDER DIRECTING THE FBI IN MIAMI, FLORIDA
TO PRODUCE PHOTOGRAPHS TO THE COURT
In 2011, the Federal Bureau of Investigation (“FBI”) met with Plaintiff Virginia Giuffre
at the United States Consulate in Sydney, Australia. During that meeting…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…any kind, and, to my knowledge, I never
even met her until her deposition in 2016. By swearing to this, I am deliberately exposing
myself to a perjury prosecution and disbarment if I am not telling the truth. If Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…16 Q When did she tell you this?
17 A I'm not exactly sure on the dates.
18 Q Was it while you were still together?
19 A Yes.
20 Q Did you -- had you met Ms. Maxwell?
21 …
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…16 Q When did she tell you this?
17 A I'm not exactly sure on the dates.
18 Q Was it while you were still together?
19 A Yes.
20 Q Did you -- had you met Ms. Maxwell?
21 …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.15
6 pg
…5 BY MR. KUVIN:
6 Q. Who introduced you to Jeffrey Epstein the 6 Q. Would you agree with me that
7 first time that you met him? 7 Jeffrey Epstein owns numerous planes, private
8 MR. RHEINHART: Same instruction…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…She was unable to crawl . .
.Based on [REDACTED] intoxicated condition, a [sic] ambulance was called to transport
her to [REDACTED] to check on her condition. I then met with [REDACTED] and his
mother. I advised [REDACTED] of his Miranda rights . . …
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
…16 Q When did she tell you this?
17 A I'm not exactly sure on the dates.
18 Q Was it while you were still together?
19 A Yes.
20 Q Did you -- had you met Ms. Maxwell?
21 …
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…2010) .....................................2
Graham v. Ortiz,
No. 07-CV-1690 (JG)(LB), 2009 WL 4016055 (E.D.N.Y. Nov. 18, 2009) ...............................5
Metrokane, Inc. v. Built NY, Inc.,
No. 06-CIV-14447 (LAK-MHD), 2008 WL 4185865 (S.D.N…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…any kind, and, to my knowledge, I never
even met her until her deposition in 2016. By swearing to this, I am deliberately exposing
myself to a perjury prosecution and disbarment if I am not telling the truth. If Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…acting, or purporting to act, at the discretion of or on behalf of
another.
2. “Correspondence” or “communication” shall mean all written or verbal
communications, by any and all methods, including without limitation, letters, memoranda,
and/or electronic mail, by…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…sex with Roberts on a private plane - is false and
that flight manifests will prove he was never aboard the plane with her.
Nobody's looking at
'I've ever seen her and I've never met her,' he insisted…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.6_3
17 pg
…20 characterization of introduc tion .
21 came to answer telephones.
22 Q. When did you - - were you the person
23 who brought or introduced or met or
24 purposes of bringing her to Jeffrey Epstein ' s
25 home?
MAGNA9 L…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.4
17 pg
…of introduction. Johanna
21 came to answer telephones.
22 Q. When did you -- were you the person
23 who brought or introduced or met Johanna for
24 purposes of bringing her to Jeffrey Epstein ' s
25 home?
MAGNA9 LEGAL SERVICES
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…articulated below.2
2
Ms. Giuffre’s counsel met and conferred with Defendant’s counsel both in person and by phone in an
effort to obtain agreement to proceed with these depositions but was unable to obtain an agreement. See
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…individual never claimed that
11 Ghislaine Maxwell told her how to act, correct?
12 A. Correct.
13 Q. This individual never claimed to have met
14 Ghislaine Maxwell ever, correct?
15 A. I don't believe so, no.
16 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…who introduced billionaire Epstein to Prince Andrew;
Fears dying of Covid-19 while in prison;
Insists she and Epstein had not met in person for 15 years;
Weeps over friends who have lost jobs because of their association with her;
…
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…17 years ago, so I cannot
Case 1:15-cv-07433-LAP Document 1343-1 Filed 01/26/24 Page 13 of 23
Page 108
1 G Maxwell - Confidential
2 that he may have met socially through me.
3 Q. …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…articulated below.2
2
Ms. Giuffre’s counsel met and conferred with Defendant’s counsel both in person and by phone in an
effort to obtain agreement to proceed with these depositions but was unable to obtain an agreement. See
…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…2015). And yet a flight log shows Dershowitz on a flight with a young woman
named "Tatianna." Dershowitz also was forced to admit in his deposition that whenever he met
with Epstein, part ofthe Epstein "entourage were woman whom he…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…
19 A. No.
20 Q. Do you remember an individual by the name
21
22
23
of
-
Epstein?
A.
that you met during your time with Jeffrey
In Palm Beach?
24 Q. Yes.
25 A. Yes.
MAGNA& LEGAL SERVICES
Case…