giuffre-maxwell
gov.uscourts.nysd.447706.443.0
4 pg
…of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NOTICE OF RELATED ACTION IN THE UNITED KINGDOM TO
OBTAIN THE DEPOSITION OF DEFENDANT’S PRESS AGENT, ROSS GOW
Plaintiff, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…that substantial portions of her story are untrue; she has so far
refused to say under oath what other lies printed by the press about her story are untrue, but has
admitted that journalist Sharon Churcher “got it wrong.” For…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…that substantial portions of her story are untrue; she has so far
refused to say under oath what other lies printed by the press about her story are untrue, but has
admitted that journalist Sharon Churcher “got it wrong.” For…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…Flight logs show that from 2001 to
2003, Bill Clinton flew on Epstein's private plane, dubbed "The Lolita Express" by the press, 26 times. After Epstein's arrest in July 2006,
federal tax records show Epstein donated $25,000…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.4
4 pg
…Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre
c/o Sigrid S. Mccawley…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…his colleague Mr. Edwards and Ms. Giuffre’s current
lawyers at Boies Schiller & Flexner, LLP—have a valid factual basis for continuing to press Ms.
Giuffre’s false allegations. Mr. Cassell’s effort is an unmitigated failure, as this declaration…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.2
56 pg
…of 56
Page 31
1 G Maxwell - Confidential
2 -- just another one of Virginia's many
3 fictitious lies and stories to make this a
4 salacious event to get interest and press.
5 It's absolute rubbish.
6 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…will further help prove that Defendant’s statements to the press that
Virginia’s allegations were “obvious lies” was itself an obvious lie.
13
The questions Defendant refused to answer fall squarely within this Court’s earlier order.
Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…That was on my partner's
25 cell phone.
Highly Confidential
Page 42
1 HIGHLY CONFIDENTIAL AEO
2 Q. And what had you read in the
3 press that caused you to get in touch
4 with Ms. Callahan…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…Her actress mother pulled her out of it in 2018 after fighting relentlessly in the
press to expose Raniere and his practices.
1/12
Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 16…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…3 fictitious lies and stories to make this a 3 A. First of all, Virginia Roberts who
4 salacious event to get interest and press. 4 you are referring to was a masseuse aged 17,
5 It's absolute rubbish. …
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…of 465
Page 31
1 G Maxwell - Confidential
2 -- just another one of Virginia's many
3 fictitious lies and stories to make this a
4 salacious event to get interest and press.
5 It's absolute rubbish.
6 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…of 465
Page 31
1 G Maxwell - Confidential
2 -- just another one of Virginia's many
3 fictitious lies and stories to make this a
4 salacious event to get interest and press.
5 It's absolute rubbish.
6 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
…of 465
Page 31
1 G Maxwell - Confidential
2 -- just another one of Virginia's many
3 fictitious lies and stories to make this a
4 salacious event to get interest and press.
5 It's absolute rubbish.
6 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…his colleague Mr. Edwards and Ms. Giuffre’s current
lawyers at Boies Schiller & Flexner, LLP—have a valid factual basis for continuing to press Ms.
Giuffre’s false allegations. Mr. Cassell’s effort is an unmitigated failure, as this declaration…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…16 10 times. Was there anything unusual about those
17 massages?
18 A. No.
19 Q. You've been quoted in the press perhaps as
20 saying that she wasn't very picky?
21 A. About massage?
22 Q. About…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.5
56 pg
…of 56
Page 31
1 G Maxwell - Confidential
2 -- just another one of Virginia's many
3 fictitious lies and stories to make this a
4 salacious event to get interest and press.
5 It's absolute rubbish.
6 Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…will further help prove that Defendant’s statements to the press that
Virginia’s allegations were “obvious lies” was itself an obvious lie.
13
Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 14…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.19
106 pg
…3 fictitious lies and stories to make this a 3 A. First of all, Virginia Roberts who
4 salacious event to get interest and press. 4 you are referring to was a masseuse aged 17,
5 It's absolute rubbish. …
giuffre-maxwell
gov.uscourts.nysd.447706.1137.9_7
56 pg
…of 56
Page 31
1 G Maxwell - Confidential
2 -- just another one of Virginia's many
3 fictitious lies and stories to make this a
4 salacious event to get interest and press.
5 It's absolute rubbish.
6 Q…
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