giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
1320-9
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…result of joint input into the final document, the judge at
the hearing on liability referred to below found that copyright in that final version vested
jointly in Scottish Power and USP.
2. In 2000 the claimants and LGH were…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…judicial documents “may mean.” Doc.993 at 6. That is just willful
ignorance. Plaintiff’s counsel was present at the September 4 hearing when the Court three times
referred to “negligibly judicial” documents. See 9/4/19 Tr. at 10…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…the non-parties to be addressed in the second round of objection briefing. DE 1243.
Although Plaintiff referred to this Doe as “Doe 169,” they are Doe 171. Plaintiff’s counsel sent
Doe 171’s counsel an email to inform…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…what Ms. Giuffre’s own counsel have referred to as
the “strong current media interest in the case”—which Ms. Giuffre has worked to sustain,
including by selling her story—bolsters the public’s right to access the Requested Documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…questioned the veracity of the Palm Beach Police report containing the accounts of the
numerous minor children who were also sexually abused by Jeffrey Epstein. Defendant referred
to at least one of those children as a prostitute, which is false…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…THIS CASE, I WAS REFERRED TO A SUBJECT B't
THE NAME OF NICHOLAS SILVAGE AS THE PERSON WHO MIGHT KNOW THE LAST NAME
OF A SUBJECT IDENTIFIED ONLY.,~ /,JOSH IN THE REPORT.
ON 7-29- 98, I RESPONDElYTO…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…endeavored to do the same type of review
6 that Ms. McCawley just referred to and I think we would be in a
7 position to confer with Ms. McCawley and reach agreement on the
8 documents that we both…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.37
11 pg
…1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 5 of 11
Page 49
1 (The referred-to document was marked by
2 the court reporter for Identification as
3 Sjoberg Exhibit 4.)
4 BY MS…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…And you've talked about, at least 24 Q. She would know this?
25 referred to yourself I believe to the police and 25 A. Yes.
Page 167 Page 169
1 as well today as a human ATM machine. Right? …
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…in January of 2015.
ANSWER:
Ms. Maxwell objects to this Interrogatory as vague and ambiguous, specifically by not defining
what types or topics of “statements” are referred to. As drafted, this Interrogatory calls for
information clearly outside the relevancy of…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…questioned the veracity of the Palm Beach Police report containing the accounts of the
numerous minor children who were also sexually abused by Jeffrey Epstein. Defendant referred
to at least one of those children as a prostitute, which is false…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…315, 320, & 335.
ECF No. 1149 (referred to as “Maxwell Br.”). Attached as Exhibit A hereto is a summary chart
of her position as to each document for ease of reference.
PRELIMINARY STATEMENT
On October 19, 2020, the Second Circuit…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…remember off the top of my head,
6 I'm sorry.
7 Q. You also referred to prominent American
8 politicians. What prominent American politicians other
9 than the ones we've already named were you sexually
10 trafficked to…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.12
15 pg
…A Um-hum.
5 Q Do you know how many times that you saw
6 Virginia Giuffre?
7 A Once.
8 Q Do you know whether she was referred to
9 you by another doctor?
10 A No.
11 Q …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
…matter.
9 And I'm going to ask the court reporter if I can
10 mark those.
11 (The referred-to document was marked by
12 the court reporter for Identification as
13 Sjoberg Exhibits 1 and 2.)
14 BY…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…questioned the veracity of the Palm Beach Police report containing the accounts of the
numerous minor children who were also sexually abused by Jeffrey Epstein. Defendant referred
to at least one of those children as a prostitute, which is false…