giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
1320-37
48 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…Id.
Two other victims, who are in many respects similarly situated to the current victims,
now wish to join this action. The new victims joining at this stage will not cause any delay and
their joinder in this case is…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
…BY MS. EZELL: 13 Q. And did Ms. Maxwell have a list of the
14 Q. Were they similar to the pictures that 14 girls who came to give massages?
15 Ms. Kellen had on her computer? 15 MR. CRITTON…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
… Let me correct myself. I
21 believe only one had.
22 Q. And was that -- was that one of similar
23 age to the other girls?
24 MR. PAGLIUCA: Object to form and
25 foundation.
MAGNA9 LEGAL SERVICES
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.11
8 pg
…4'11
l Q. And you said that that was -- the massage 1 MR. EDWARDS: I don't have anything else.
2 table was similar in kind to that used by Mr. 2 MS. EZELL: I have a few.
3 …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
…Taylor? 15 MR. YA RE MA: Object to the form.
16 A Fifth . 16 A Fi fih.
17 Q Similar to you being Jeffrey Epstein's 17 Q To your knowledge, has .lcfTrcy Epstein
18 sex slave, is Emmy Tnylor…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
… Let me correct myself. I
21 believe only one had.
22 Q. And was that -- was that one of similar
23 age to the other girls?
24 MR. PAGLIUCA: Object to form and
25 foundation.
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…20 foundation.
21 THE WITNESS: Some did, some did not.
22 BY MS. SCHULTZ:
23 Q. Okay. Among the girls who did not know
24 one another, were their accounts of what happened at
25 Jeffrey Epstein's house similar?
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…The witness has expressed to
21 me fears of harassment and the
22 belief that she's being followed,
23 and my understanding is that
24 there are other witnesses that
25 have had similar fears and
Highly Confidential
…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…v. Silver, 2016 WL 1572993, at *9 (S.D.N.Y. Apr.
14, 2016) (emphasis added). Other Courts in this Circuit structure their unsealing
orders in a similar fashion. See, e.g., United States v. Caicedo Velandia, 2019 WL
6913524…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.13
9 pg
…in the late 2004, when you were hired, through 2005?
19 and their stories are so strikingly similar as to what's 19 A Three limes.
20 taking place in Mr. Epstein's bedroom? 20 Q Three times a week?
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
! Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 9…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
…of the words. So I'll try to do my
21 best to go slower and make sure I'm not talking over
22 you.
23 And, similarly, if you've got an answer to
24 a question, make sure…
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