giuffre-maxwell
gov.uscourts.nysd.447706.908.0
4 pg
…with Plaintiff Virginia Giuffre
at the United States Consulate in Sydney, Australia. During that meeting, Plaintiff informed FBI
Special Agents of the existence of multiple original photographs. See Edwards Declaration, FBI
302 attached hereto as Exhibit A. On March 18…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…her and Ms. Maxwell and Jeffrey
15 were all intimate together on multiple occasions.
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…her and Ms. Maxwell and Jeffrey
15 were all intimate together on multiple occasions.
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…Document 1201-17 Filed 01/27/21 Page 2 of 12
hundreds of young girls who came and went from the home she shared with Epstein. Her
testimony is directly refuted by multiple witnesses.
Juan Alessi, Epstein’s house manager…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
…her and Ms. Maxwell and Jeffrey
15 were all intimate together on multiple occasions.
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…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…stay
discovery pending resolution of her Motion to Dismiss. First, the Motion to Dismiss presents
multiple, independent bases upon which this Court may dismiss the Complaint pursuant to Rule
12(b)(6). Each basis for dismissal is legally well-founded…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…Document 1328-7 Filed 01/05/24 Page 2 of 12
hundreds of young girls who came and went from the home she shared with Epstein. Her
testimony is directly refuted by multiple witnesses.
Tony Figueroa, Defendant’s own witness…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…abuse suffered by Ms. Giuffre and others at the hands of
Maxwell, and should not be withheld. Moreover, flight logs demonstrate that Sarah Kellen and
Maxwell flew together multiple times, including with Ms. Giuffre. See McCawley Decl. at
Exhibit 4…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…As a
result, Ms. Giuffre is now in a position where she has to call multiple witnesses to establish
fundamental facts in the case. For example, Defendant would not even admit that the initials
“GM” which are on the private…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…the high-security
Metropolitan Detention Center in Brooklyn
on £4 million bail, arguing that her life is in
danger from coronavirus and ‘multiple and
credible’ death threats.
Maxwell, who is a long-time friend of Prince Andrew and who saw…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…As a
result, Ms. Giuffre is now in a position where she has to call multiple witnesses to establish
fundamental facts in the case. For example, Defendant would not even admit that the initials
“GM” which are on the private…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…Dep. Tr. at 311-312 (Q. And when you say you were on
purpose of giving
rotation, you mean you were having sex with Jeffrey multiple times per
Epstein sexual
day? A. No. As in when I was finished, another…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…and defame Ms. Giuffre.
The Court is aware that a mountain of testimonial evidence, from multiple witnesses,
firmly establishes Defendant operated as convicted pedophile Jeffrey Epstein’s procurer of
underage girls. The Court is also aware that, as things stand…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…to that proceeding. Dershowitz has himself
answered that question in the affirmative on multiple occasions during his recent deposition:
Q: You were asked on the occasion of that same Don Lemon CNN interview
what possible motive the attorneys, Brad Edwards…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…As a
result, Ms. Giuffre is now in a position where she has to call multiple witnesses to establish
fundamental facts in the case. For example, Defendant would not even admit that the initials
“GM” which are on the private…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…As a
result, Ms. Giuffre is now in a position where she has to call multiple witnesses to establish
fundamental facts in the case. For example, Defendant would not even admit that the initials
“GM” which are on the private…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…here that even
Defendant has to ultimately concede that discovery about her financial information is relevant to
this case.
II. DISCUSSION
Because discovery regarding Defendant’s financial circumstances and recent transactions
is relevant to this case for multiple reasons, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…lawsuits against him, brought
by young women, out of court. As of 2015, Epstein had settled multiple such cases.
ogoinst him, brought
byyoung women, out Giuffre has sued Ghislaine Maxwell in Manhattan federal court, charging defamation
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…barring his prosecution for
federal crime for his sexual abuse of Ms. Giuffre and multiple other victims. Several of
Epstein's sexual abuse victims have filed a suit alleging that they were not properly notified of
3
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…connection with which the Document and the
information it contains was obtained and/or prepared.
20. Plaintiff does not seek and does not require the production of multiple copies of
identical Documents.
21. This Request is deemed to be continuing…
Comments