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
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.447706.1328.7
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.447706.1078.5
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.447706.562.2
29 pg
…of Giuffre's allegations:
• The Palm Beach Police Department put together an 87-page report based on
witness interviews and other evidence documenting sexual abuse of dozens of
minor girls occurring in Epstein's Florida mansion — a location where Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…N U.S. PLAIN1JFFCASES) (IN U. •. PLAJN7lFF § 4 f. 'W.£l:tARIMORE
NOTE: IN LAND CONDEM NA -,i.@, .ASh'8 l~]E_lJljE LOCATION , F
…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…responsive Documents in your
possession, custody or control without regard to the physical location of such documents.
3
Case 1:15-cv-07433-RWS Document 17-1 Filed 12/01/15 Page 4 of 13
3. If any Document…
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.447706.1332.7
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.447706.1328.23
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…
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