giuffre-maxwell
gov.uscourts.nysd.447706.356.0
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.447706.1137.1_1_1_1
10 pg
…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, (DE 1). at~ 27…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…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, (DE 1), at …
giuffre-maxwell
1320-2
10 pg
…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, (DE 1). at 127…
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
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.447706.1320.2
10 pg
…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, (DE 1). at 127…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…other
witnesses’ accounts of what Defendant’s job was for Epstein.8
That other young females were similarly recruited by the Defendant is evidence that Ms.
Giuffre is telling the truth about her experiences – and thus direct evidence that Defendant
…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…Document 1256-11 Filed 05/03/22 Page 9 of 15
Case 1:15-cv-07433-LAP Document 1256-11 Filed 05/03/22 Page 10 of 15
recruited her and other young females for sex with Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
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.447706.1201.1_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.447706.1327.5
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.447706.562.1
13 pg
…state of Colorado.
FACTUAL ALLEGATIONS
8. Virginia Giuffre became a victim of sex trafficking and repeated sexual abuse
after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Giuffre was under the age
of eighteen.
9. Between 1999 and 2002…
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.447706.1.0
12 pg
…state of Colorado.
FACTUAL ALLEGATIONS
8. Virginia Giuffre became a victim of sex trafficking and repeated sexual abuse
after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Giuffre was under the age
of eighteen.
9. Between 1999 and 2002…
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…
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