giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…therapist and they would send to the house. So it was
referrals.”
In response to Ms. Giuffre’s assertions about Defendant recruiting of females for sexual
purposes, Defendant has made the sweeping claim that Ms. Giuffre’s assertions are “entirely
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…therapist and they would send to the house. So it was
referrals.”
In response to Ms. Giuffre’s assertions about Defendant recruiting of females for sexual
purposes, Defendant has made the sweeping claim that Ms. Giuffre’s assertions are “entirely
…
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.447706.1320.24
16 pg
…for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who
observed the recruiting or the abuse. For example…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who
observed the recruiting or the abuse. For example…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.
9. Employment records obtained from ET Employment Training and Recruiting
Australia.
10. Education records obtained from Royal Palm Beach Community High School
and Forest Hills High School.
11. Documents received…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recrniting and abuse, and those who
observed the recrniting or the abuse.
_6 _ _
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who
observed the recruiting or the abuse. For example…
giuffre-maxwell
gov.uscourts.nysd.447706.903.0
46 pg
…nude photographs on her computer, things of that nature.
13 He testified that he was directed to go to a high
14 school to drop off flowers to a high school student as part of
15 this massage recruiting scheme. …
giuffre-maxwell
1320-21
15 pg
…for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who
observed the recruiting or the abuse. For example…
giuffre-maxwell
1320-40
19 pg
…Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.
9. Employment records obtained from ET Employment Training and Recruiting
Australia.
10. Education records obtained from Royal Palm Beach Community High School
and Forest Hills High School.
11. Documents received…
giuffre-maxwell
1320-27
15 pg
…for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who
observed the recruiting or the abuse. For example…
giuffre-maxwell
1320-24
16 pg
…for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who
observed the recruiting or the abuse. For example…
giuffre-maxwell
gov.uscourts.nysd.447706.76.2
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.447706.1150.3_2
12 pg
…trafficking-operation-she-allegedly-ran-with-late-jeffrey-epstein.html
192 https://www.pbs.org/newshour/politics/ghislaine-maxwell-denied-recruiting-girls-for-sex-with-powerful-men-in-2016-deposition
193 https://nationalpost.com/news/world/in-revealed-2016-deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…Maxwell
in a lawsuit she instituted against Jeffrey Epstein but denies the allegations contained in
Paragraph 18, including that allegation that she engaged in any sex trafficking or any recruiting
of any minor for purposes of sexual crimes.
19. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.53.0
15 pg
…at Exhibit 3, Message Pads from Law Enforcement trash pulls of Jeffrey Epstein’s Palm
Beach home.
3
Documents showing Defendant recruiting underage girls from that time period are
relevant because they help establish Ms. Giuffre’s contention that…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recrniting and abuse, and those who
observed the recrniting or the abuse.
- 4
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recmiting and abuse, and those who
observed the recmiting or the abuse.
4
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…response and opposition to Defendant’s Motion to Appoint a Special Master to Preside Over the
Third Deposition of Defendant.
BACKGROUND
Defendant’s recounting of the certain background facts obscures the fact that the Court
has entered two separate orders…
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