giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…1999. .................................... 56
2. The January 2015 statement accurately denied that Ms. Maxwell
“regularly participate[d] in Epstein’s sexual exploitation of minors” and
that “the Government knows” such fact. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…deposition-virginia-roberts-giuffre-epstein-prince-andrew-clinton-b1235076.html
46 https://www.washingtonpost.com/politics/ghislaine-maxwell-jeffrey-epstein-minors-unsealed-testimony/2020/10/22/8681039c-1475-11eb-ba42-ec6a580836ed_story
47 https://www.eonline.com/news/1201123/ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.538.0
10 pg
…1999. .................................... 56
2. The January 2015 statement accurately denied that Ms. Maxwell
“regularly participate[d] in Epstein’s sexual exploitation of minors” and
that “the Government knows” such fact. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…more specifically
than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to
the fact that those involved in sexual abuse of minors have a strong propensity for repeating
those crimes. See Fed. R…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…Moreover, Defendant cannot refute the documentary evidence that she was on Epstein
private jet with Ms. Giuffre over 20 times while Ms. Giuffre was a minor – flights that
Defendant is, quite conveniently, now unable to recall. Motion at 5-8…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…respect to the practice, which we
would say would be sexual abuse or trafficking of minors.
THE COURT: OK.
4
Case 1:15-cv-07433-LAP Document 96 Filed 04/13/16 Page 8 of 15
MS. McCAWLEY: And…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…more specifically
than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to
the fact that those involved in sexual abuse of minors have a strong propensity for repeating
those crimes. See Fed. R…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…interrogatory P is over-broad because it is not
limited to speech defendant has already determined to be ‘harmful to minors’ under COPA but
appears to command defendant to search for all speech over the entire internet and determine
whether…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…saw Ms. Giuffre give a massage to Ms. Maxwell is immaterial. Ms.
Sjoberg was with Defendant and Epstein when Ms. Giuffre was a minor child, and corroborates
Ms. Giuffre’s accounts concerning her being trafficked to Prince Andrew. Id. at…
giuffre-maxwell
1320-21
15 pg
…saw Ms. Giuffre give a massage to Ms. Maxwell is immaterial. Ms.
Sjoberg was with Defendant and Epstein when Ms. Giuffre was a minor child, and corroborates
Ms. Giuffre’s accounts concerning her being trafficked to Prince Andrew. Id. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…This Court should Order Production of Documents Responsive to Requests
Nos. 1-3
Defendant characterizes the police reports (and information therein) concerning Ms.
Giuffre as a minor as both “highly relevant” (Br. at 4) and “irrelevant” to this action (Br…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…This Court should Order Production of Documents Responsive to Requests
Nos. 1-3
Defendant characterizes the police reports (and information therein) concerning Ms.
Giuffre as a minor as both “highly relevant” (Br. at 4) and “irrelevant” to this action (Br…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…a
subject she would know as Jeffrey Epstein . Prior to speaking with
her, I explained that because of the fact that she is a minor, I
needed to speak with her parents prior to speaking with her. She
telephoned her…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…a
subject she would know as Jeffrey Epstein . Prior to speaking with
her, I explained that because of the fact that she is a minor, I
needed to speak with her parents prior to speaking with her. She
telephoned her…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.29_1
16 pg
…they seek to invade her privacy for the sole purpose
of harassing and intimidating Ms. Giuffre who was a minor victim of sexual trafficking.
Ms. Giuffre objects to the requests to the extent they are overly broad and unduly
burdensome…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…defamation.
Indeed, Defendant is the one who brought her to that hospital, while she was a minor.
Therefore, Defendant’s statement in her brief that “Plaintiff failed therein to identify any
treatment providers prior to the alleged defamation, despite the…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…One of the crimes to which you pled guilty
24 that, to your knowledge, Ms. Maxwell had access to in 24 in open court was soliciting a minor for
25 2000 and 2001. 25 prostitution, true?
8 (Pages 26 to…
giuffre-maxwell
1320-13
45 pg
…a
subject she would know as Jeffrey Epstein . Prior to speaking with
her, I explained that because of the fact that she is a minor, I
needed to speak with her parents prior to speaking with her. She
telephoned her…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…One of the crimes to which you pled guilty
24 that, to your knowledge, Ms. Maxwell had access to in 24 in open court was soliciting a minor for
25 2000 and 2001. 25 prostitution, true?
8 (Pages 26 to…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…defamation.
Indeed, Defendant is the one who brought her to that hospital, while she was a minor.
Therefore, Defendant’s statement in her brief that “Plaintiff failed therein to identify any
treatment providers prior to the alleged defamation, despite the…