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.447706.1256.16
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
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.447706.1325.14
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.447706.231.0
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…24 Page 9 of 31
abused numerous underage girls in his Florida mansion, his New York mansion, and several
other places that Dershowitz apparently admits he visited on multiple occasions.
In 2009, one of Epstein’s household employees, Juan Alessi…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…on French
servers and not housed in such places G-mail or Skype which have co-locations for information
which may be found outside of European servers.
Defendant’s counsel maintains that his client has assured him that all remaining…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…s terms.
D. Plaintiff Must Produce Medical Records and Releases
Defendant has requested, multiple times and in multiple ways, information concerning
any medical and mental health treatment that Plaintiff has received for the period prior to, during
and subsequent to…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…21 Page 9 of 31
abused numerous underage girls in his Florida mansion, his New York mansion, and several
other places that Dershowitz apparently admits he visited on multiple occasions.
In 2009, one of Epstein’s household employees, Juan Alessi…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…including Mr Malcolm Jones, Mr Poynter, and others
from locations in the UK, France and Belgium. It states inter alia that the Buncefield
D
explosion had many similarities to an explosion which occurred at Saint Herblain
near Nantes …
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…and repeated sexual abuse after being recruited by Ghislaine
Maxwell and Jeffrey Epstein when Giuffre was under the age of eighteen. Between 1999 and
2002, with the assistance and participation of Maxwell, Epstein sexually abused Giuffre at
numerous locations . . . .” Dkt…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…Document 185-8 Filed 06/01/16 Page 7 of 24
certain specific locations, among other allegations of criminal conduct by Dershowitz.6 Giuffre
subsequently submitted multiple sworn affidavits repeating the allegations against Dershowitz,
which likewise have been stricken from…
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