giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…have been trafficked for sex. Finally, Maxwell’s travel to Epstein’s residences
in Florida, New York, New Mexico, and USVI will support the allegations that Maxwell assisted
Jeffrey Epstein with his sexual trafficking operation. Accordingly, this is an improper…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…him. Dershowitz Decl. ¶ 6.
4
Mr. Epstein’s private planes, in the British Virgin Islands, in New Mexico, and in New York.
Dershowitz Decl. ¶ 17. Unlike much of the record in the CVRA Action, these allegations were
not sealed; instead…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…him. Dershowitz Decl. ¶ 6.
4
Mr. Epstein’s private planes, in the British Virgin Islands, in New Mexico, and in New York.
Dershowitz Decl. ¶ 17. Unlike much of the record in the CVRA Action, these allegations were
not sealed; instead…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…together with other documentary evidence, prove that I could not have been in
locations in which she claims to have had sexual contact with me, including Little St. James,
New Mexico, Mr. Epstein’s home in Palm Beach, and Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…together with other documentary evidence, prove that I could not have been in
locations in which she claims to have had sexual contact with me, including Little St. James,
New Mexico, Mr. Epstein’s home in Palm Beach, and Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.435.0
27 pg
…2015).
9.
First, I was
not present in that home—or on Mr. Epstein’s private island, or at his New Mexico ranch, or on
4
his airplane—during the time Ms. Giuffre was associat…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…Reflecting Your Presence In: (A) Palm Beach Florida Or Immediately
Surrounding Areas; (B) 9 E. 71st Street, New York , NY 10021; (C) New
Mexico; (D) U.S. Virgin Islands; (E) Any Jet Or Aircraft Owned Or
Controlled By Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…Request No. 33: All travel records between 1999 and the present reflecting your
presence in: (a) Palm Beach Florida or immediately surrounding areas; (b) 9 E.
71st Street, New York , NY 10021; (c) New Mexico; (d) U.S. Virgin islands;…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…there are no high school students, all these claims are fraudulent and she’s in this
isolated place in New Mexico.”
Remote Hearing
Because of the pandemic, Maxwell’s hearing was held remotely with press and the public
permitted to…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…resided at the
facility.
! Ms. Giuffre lived and travelled with Jeffrey Epstein and stayed at his
various mansions in New York, Palm Beach, New Mexico (Zorro
Ranch), and U.S.V.I.
! Jeffrey Epstein also rented a residence for Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.14
7 pg
…
21 A. No. It's -- airlines go in there.
22 Q. Did Jeffrey Epstein also have a landing
23 strip at his property in New Mexico?
24 A. He did at one time.
25 Q. What would that -- do you…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…on Mr. Epstein’s private island, or at his New Mexico ranch, or on
4
Case 1:15-cv-07433-LAP Document 1218-49 Filed 07/15/21 Page 5 of 27
his airplane—during the time Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…of additional victims in the case and their contact
11 information. Rodriguez explained that the information
12 contained hundreds of additional victims and their phone
13 numbers from diverse geographical locations, including New
14 York, New Mexico, and Paris, France…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…and stayed at his various mansions in New York (9 E.
71st Street, New York, NY 10021-4102), Palm Beach (358 El
Brillo Way, Palm Beach, Florida 33480, New Mexico (Zorro
Ranch, 49 Zorro Ranch Rd., Stanley, New Mexico 87056),
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…what was
required of her.” (p. 123-124)
! She said she recalls that Defendant went to dinner with Governor Bill Richardson one
time when Johanna was visiting the ranch in New Mexico (p. 110).
B. Future Depositions Sought by Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…and stayed at his various mansions in New York (9 E.
71st Street, New York, NY 10021-4102), Palm Beach (358 El
Brillo Way, Palm Beach, Florida 33480, New Mexico (Zorro
Ranch, 49 Zorro Ranch Rd., Stanley, New Mexico 87056),
…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…properties,
including, but not limited to: his home in Palm Beach, Florida; his home in New York
City, New York; his ranch in Santa Fe, New Mexico; and Little Saint James Island in the
U.S. Virgin Islands. To the…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…in fact, answer the question about
oral sex with individuals other than Mr. Epstein when the locations were specified, i.e, planes;
New York; Palm Beach; New Mexico; Paris; and the Virgin Islands. See Pagliuca Decl., Ex. D,
Excerpts from…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…on Mr. Epstein’s private island, or at his New Mexico ranch, or on
4
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 5 of 27
his airplane—during the time Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
… Sarah Kellen was there. Ghislaine was
2 there. That's all I recall.
3 Q. Do you recall why you went on the trip to
4 New Mexico?
5 A. To work.
6 Q. Did you perform massages on that…
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