giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…As the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being “massage therapists.” See Complaint, DE1, at …
giuffre-maxwell
gov.uscourts.nysd.447706.1218.24
4 pg
…one of as many as 40 women who allege that Epstein recruited them while
they were minors into a sex ring based at Epstein's Palm Beach mansion.
Roberts alleges in a 14-page affidavit -- which included newly-released photos…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.30
4 pg
…one of as many as 40 women who allege that Epstein recruited them while
they were minors into a sex ring based at Epstein's Palm Beach mansion.
Roberts alleges in a 14-page affidavit -- which included newly-released photos…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…As the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being “massage therapists.” See Complaint, DE1, at …
giuffre-maxwell
gov.uscourts.nysd.447706.542.0
7 pg
…2 of 7
3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher
entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill
Clinton,” DAILY MAIL, dated March 5…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…testified that, when she was a twenty-
one-year-old college student, Defendant (not Jeffrey Epstein) recruited and hired her under the
pretext of being a personal assistant to provide sexual massages. As one example of this
testimony, Sjoberg testified…
giuffre-maxwell
1320-21
15 pg
…testified that, when she was a twenty-
one-year-old college student, Defendant (not Jeffrey Epstein) recruited and hired her under the
pretext of being a personal assistant to provide sexual massages. As one example of this
testimony, Sjoberg testified…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.8_3
9 pg
…Ms.
Maxwell and Mr. Epstein. She was asked questions about whether she recruited girls for Mr.
Epstein to have sex with and her knowledge of Mr. Epstein’s sex with a number of people. She
was asked questions about “sex…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.41
4 pg
…one of as many as 40 women who allege that Epstein recruited them while
they were minors into a sex ring based at Epstein's Palm Beach mansion.
Roberts alleges in a 14-page affidavit -- which included newly-released photos…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.19
4 pg
…one of as many as 40 women who allege that Epstein recruited them while
they were minors into a sex ring based at Epstein's Palm Beach mansion.
Roberts alleges in a 14-page affidavit -- which included newly-released photos…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…Jeffrey Epstein’s sexual trafficking
conduct.
12. Dana Burns
Address unknown at this time.
Telephone number unknown at this time
Worked for Ghislaine Maxwell and has information about Ghislaine Maxwell’s
recruiting of girls for Jeffrey Epstein.
13. Alyson Chambers
…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…burden.
Further, the central allegations underlying this case—that Maxwell recruited Plaintiff into
a sex-trafficking network and participated in the recruitment and abuse of many others—are no
secret and have been available to the public for years. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…massage. I don’t remember seeing Bill again on the trip but I
assume Ghislaine flew him back.”
See Sharon Churcher, “Teenage girl recruited by peadophile Jeffrey Epstein reveals how she
twice met Bill Clinton,” DAILY MAIL (Mar. 5…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…sex involving the Plaintiff, Ms. Maxwell and Mr. Epstein. She was
asked questions about whether she recruited girls for Ms. Epstein to have sex with, her
knowledge of Ms. Epstein’s sex with a number of people. She was asked…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…of hours allowed for depositions, she seeks leave from this Court to
confirm that she may proceed with the additional depositions for the reasons stated below.
Ms. Giuffre has alleged that Defendant recruited females for Mr. Epstein, including
underage females…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
… Correct.
7 Q. And it's true, is it not, that this
8 alleged victim never claimed to have been recruited
9 by Ghislaine Maxwell; true?
10 MS. SCHULTZ: Object to form and
11 foundation.
12 THE WITNESS: Correct.
13…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…of hours allowed for depositions, she seeks leave from this Court to
confirm that she may proceed with the additional depositions for the reasons stated below.
Ms. Giuffre has alleged that Defendant recruited females for Mr. Epstein, including
underage females…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.7
18 pg
… Correct.
7 Q. And it's true, is it not, that this
8 alleged victim never claimed to have been recruited
9 by Ghislaine Maxwell; true?
10 MS. SCHULTZ: Object to form and
11 foundation.
12 THE WITNESS: Correct.
13…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…testified that, when she was a twenty-
one-year-old college student, Defendant (not Jeffrey Epstein) recruited and hired her under the
pretext of being a personal assistant to provide sexual massages. As one example of this
testimony, Sjoberg testified…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…is - -
. His deposition is necessaiy for the following reason:
depositions like this - verifying Ms. Giuffre's account of being recrnited by Defendant for sex
with Epstein - that Defendant is hying avoid. However, multiple other witnesses have testimony
that suppo1ts Ms…
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