giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…inducing and enticing, and aiding and abetting the
inducement and enticement of, multiple minor victims. Victims
were groomed and/or abused at multiple locations, including the
following:
a. A a multi-story private residence on the
Upper East Side of…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…was untrue.
Additionally, to prove Ms. Giuffre’s allegations, that span multiple years, on multiple
continents, and multiple locations, Ms. Giuffre has arranged a series of depositions of persons
with direct knowledge of the relevant issues. To prove her case…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…this case.
Additionally, to prove Ms. Giuffre’s allegations, that span multiple years, on multiple
continents, and multiple locations, Ms. Giuffre has arranged a series of depositions of persons
with direct knowledge of the relevant issues. To prove her case…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…was untrue.
Additionally, to prove Ms. Giuffre’s allegations, that span multiple years, on multiple
continents, and multiple locations, Ms. Giuffre has arranged a series of depositions of persons
with direct knowledge of the relevant issues. To prove her case…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…was untrue.
Additionally, to prove Ms. Giuffre’s allegations, that span multiple years, on multiple
continents, and multiple locations, Ms. Giuffre has arranged a series of depositions of persons
with direct knowledge of the relevant issues. To prove her case…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…with
1
Case 1:15-cv-07433-LAP Document 1256-16 Filed 05/03/22 Page 6 of 30
Case 1:15-cv-07433-LAP Document 1256-16 Filed 05/03/22 Page 7 of 30
in multiple locations…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…of
and Excerpts from the June 21, 2016 Deposition of Joseph Recarey.
2
Case 1:15-cv-07433-LAP Document 1325-7 Filed 01/04/24 Page 7 of 30
in multiple locations. So she and her legal counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…of 30
Case 1:15-cv-07433-LAP Document 1198-5 Filed 01/27/21 Page 6 of 30
Case 1:15-cv-07433-LAP Document 1198-5 Filed 01/27/21 Page 7 of 30
in multiple locations…
giuffre-maxwell
1320-10
28 pg
…this case.
Additionally, to prove Ms. Giuffre’s allegations, that span multiple years, on multiple
continents, and multiple locations, Ms. Giuffre has arranged a series of depositions of persons
with direct knowledge of the relevant issues. To prove her case…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…old girl to his employer’s home who, in utmost distress,
told him that Defendant stole the young girl’s passport and tried to make her have sex with
1
in multiple locations. So she and her legal counsel have…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…of 30
Case 1:15-cv-07433-LAP Document 1198-12 Filed 01/27/21 Page 6 of 30
Case 1:15-cv-07433-LAP Document 1198-12 Filed 01/27/21 Page 7 of 30
in multiple locations…
giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
…was untrue.
Additionally, to prove Ms. Giuffre’s allegations, that span multiple years, on multiple
continents, and multiple locations, Ms. Giuffre has arranged a series of depositions of persons
with direct knowledge of the relevant issues. To prove her case…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
…of
and Excerpts from the June 21, 2016 Deposition of Joseph Recarey.
2
Case 1:15-cv-07433-LAP Document 1325-14 Filed 01/04/24 Page 7 of 30
in multiple locations. So she and her legal counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…the Court’s order, Ms. Giuffre effected alternative
service of a subpoena to testify at a deposition on Ms. Kellen in multiple ways, all calculated to
give her actual notice of the subpoena. See Schultz Decl. at Composite Exhibit 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
giuffre-maxwell
1320-33
24 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
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.447706.231.0
23 pg
…Comply with Rule 26(a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April…
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…
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