giuffre-maxwell
gov.uscourts.nysd.447706.1295.2
12 pg
…cv-07433-LAP Document 1295-2 Filed 12/12/22 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.
Chillingly, Rinaldo Rizzo…
giuffre-maxwell
gov.uscourts.nysd.447706.443.0
4 pg
…agent, Ross Gow, who is a key witness in this case because he issued, on Defendant’s behalf, one
of the defamatory statements at issue to multiple media outlets.
Defendant’s counsel, Philip Barden, is also counsel for Mr. Gow…
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.447706.1124.0_3
2 pg
…to documents that may be released, they should not receive a second
opportunity to object thereafter.
Allowing Non-Parties multiple opportunities to object to unsealing would set a precedent
that would exponentially delay this process. The same is true of…
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.447706.1102.0_1
2 pg
…1100), in which she seeks a
stay of the sealing process based on “critical new information.”
Ms. Maxwell has made multiple efforts to stall this litigation and prevent the disclosure
of documents to the public. Her August 10, 2020 letter…
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.447706.1295.16
22 pg
…York.
EXH!BIT
ztllt 17
Case 1:17-cv-00616 Document 1- Frled OLl26lt7 Page 2 of 2l
4. At all times material to this cause of action Defendant Jeftey Epstein
had multiple…
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.447706.1307.2
56 pg
…And for
8 the record, she is an absolute total liar and
9 you all know she lied on multiple things and
10 that is just one other disgusting thing she
11 added.
12 Q. Did you help her obtain…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…I said three with three
18 fingers. That is a single
19 request on her part and a single
20 answer, not multiple.
21 MS. MENNINGER: No. She has
22 looked to her lawyers for
23 previous answers.
24 We…
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.447706.1328.13
9 pg
…girls
14 BY MR. EDWARDS: 14 were making this up?
15 Q Are you aware of the allegations by multiple 15 A No, sir.
16 female girls that allege that these are the crimes that 16 MR. CRITTON: Form.
17…
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.447706.1320.5
56 pg
…And for
8 the record, she is an absolute total liar and
9 you all know she lied on multiple things and
10 that is just one other disgusting thing she
11 added.
12 Q. Did you help her obtain…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…for Jeffrey. And then she told me about how, like I said, her and Ms. Maxwell and Jeffrey
were all intimate together on multiple occasions.”
x See Schultz Decl. at Composite Exhibit 3, Excerpts of June 21, 2016, Deposition of…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…at p. 10-11, 410. As the Court knows, the
Palm Beach Police Report demonstrates multiple incidents of “massages” being given by
untrained minor children that involved sexual acts. See McCawley Decl. at Exhibit 3, Palm
Beach Police Report. Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…at p. 10-11, 410. As the Court knows, the
Palm Beach Police Report demonstrates multiple incidents of “massages” being given by
untrained minor children that involved sexual acts. See McCawley Decl. at Exhibit 3, Palm
Beach Police Report. Defendant…
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
…
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