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.447706.1218.9
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.447706.53.0
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.447706.1218.49
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.447706.1320.10
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.447706.1327.26
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.447706.1335.2
73 pg
…I 9 Q. Have you ever seen anyone give
10 don't have any knowledge of any other person 10 Mr. Epstein a massage in New Mexico?
11 on this list. I don't believe I've ever even 11…
giuffre-maxwell
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.447706.1328.6
32 pg
…Document 1328-6 Filed 01/05/24 Page 11 of 32
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…4 A. Roughly when I was 17.
5 Q. Where were you?
6 A. New Mexico and New York.
7 Q. Are there witnesses to this?
8 A. Not to the actual event itself.
9 Q. What other powerful business…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…The
second time that I had sex with Dershowitz was at Epstein's house in Palm Beach.
I also had sex with Dershowitz at Epstein's Zorro Ranch in New Mexico
in the massage room off ofthe indoor pool area…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…4 A. Roughly when I was 17.
5 Q. Where were you?
6 A. New Mexico and New York.
7 Q. Are there witnesses to this?
8 A. Not to the actual event itself.
9 Q. What other powerful business…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.1_1
7 pg
…sorry, between Glenn and
16 Stephen. The first time I was with Alan Dershowitz
17 was in New York, so I wasn't actually sent to him.
18 It actually happened at one of Jeffrey's residences.
19 (Ms. McCawley…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
..
.............................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
…
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF VIRGINIA GIUFFRE’S RESPONSE TO DEFENDANT’S
…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.12
4 pg
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
...........................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v. …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
MOTION FOR PROTECTIVE ORDER FOR NON-PARTY WITNESS
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
.............................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
…
Comments