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.447706.1325.7
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
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.447706.172.0
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.447706.1328.7
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.447706.1328.41
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.447706.824.0_2
47 pg
…it was with Ms. Maxwell, it was in his bedroom.
21 "Q. Ms. Maxwell, what -- you're naming the locations where the
22 book was kept; correct?
23 "A. Yes, at Ms. Maxwell's desk."
24 And that's in…
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.447706.1332.17
13 pg
…witness should be entitled to rely upon the enforceability of a protective order
against any third parties.’” In this case, the parties and multiple other deponents
have relied on this Court’s Protective Order in giving testimony and producing
documents . …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…Here, Ms.
Giuffre has diligently attempted to make personal service on each of the three individuals,
having made multiple attempts to personal service them, including going to different locations at
different times on different days, and attempting to reach them…
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.447706.406.0
31 pg
…negations:
MS. MCCAWLEY: Your Honor, if the intent here is to continue to spew the
confidential settlement negotiations and have Dershowitz go to New York or other
locations to say these things again, I would object to that. I think…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…the reason was that “[m]ultiple individuals have placed you in the presence of
Jeffrey Epstein on multiple occasions and in various locations when Jeffrey Epstein was in the
13
Case 1:15-cv-07433-LAP
Case 9:08…
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…
Comments