giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…For example, Defendant swore under oath that she hardly was around Jeffrey Epstein for more
than “maybe an hour or two” in the years after 2003 until she claimed she ultimately left his
employment in 2008 or 2009. See Pottinger…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.3
7 pg
…A No, there's no more than one truth.
8 Q All right. So a document in which you
9 swore that you were 15 years old when you met
10 Ms. Ghislaine Maxwell is an untrue statement,
11 correct?…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…Gustini, in The Wire (June 21, 2011).
7
While Dershowitz swore under oath that he never saw any naked photos at Epstein’s Palm Beach mansion, the
recently released video taken by the Palm Beach Police department during its investigation…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…OF JOINTS. THIS
CONCLUDED THE INTERVIEW AND I SWORE IN AGAIN AFTER THE INTERVIEW TO
CONFIRM THAT ALL THE INFORMATION SHE HAD GIVEN WAS THE TRUTH AND SHE SWORE
THAT IT WAS.
ON 4-1-98 AT 1515HRS, I SPOKE…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Ms. Ransome also produced numerous photographs of her travels to
Epstein’s Little Saint James Island, which unequivocally establish Defendant’s presence during the
years that she swore under oath that she was hardly around. Ms. Ransome’s testimony proves…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…Ms. Ransome also produced numerous photographs of her travels to
Epstein’s Little Saint James Island, which unequivocally establish Defendant’s presence during the
years that she swore under oath that she was hardly around. Ms. Ransome’s testimony proves…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…Ms. Ransome also produced numerous photographs of her travels to
Epstein’s Little Saint James Island, which unequivocally establish Defendant’s presence during the
years that she swore under oath that she was hardly around. Ms. Ransome’s testimony proves…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…Ms. Ransome also produced numerous photographs of her travels to
Epstein's Little Saint James Island, which unequivocally establish Defendant's presence dming the
years that she swore under oath that she was hardly around. Ms. Ransome's testimony proves…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…Gustini, in The Wire (June 21, 2011).
7
While Dershowitz swore under oath that he never saw any naked photos at Epstein’s Palm Beach mansion, the
recently released video taken by the Palm Beach Police department during its investigation…
giuffre-maxwell
gov.uscourts.nysd.447706.977.2
1 pg
…is better positioned to communicate with the
parties and any nonparties whose privacy interests might be affected by
unsealing. On that score, it is worth clarifying here the breadth of the Court’s
unsealing order: it unseals nearly 2000 pages…
giuffre-maxwell
gov.uscourts.nysd.447706.968.1
1 pg
…positioned to communicate with the
parties and any nonparties whose privacy interests might be affected by
unsealing. On that score, it is worth clarifying here the breadth of the Court’s
unsealing order: it unseals nearly 2000 pages of material…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…. .”). Using the February 4 Non-Party List as a scorecard, following this approach
would knock out a significant number of docket entries in dispute for Does 1 and 2, as highlighted
below.
Case 1:15-cv-07433-LAP Document…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…privately-owned islands in the Virgin Islands were
essential to the sex-trafficking enterprise. Little St. James is a secluded, private island, nearly
two miles off-shore from St. Thomas with no other residents while Epstein resided there. Id., ¶
66…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…A Mr Chan and a Mr Cooper, solicitors on the Isle of Man,
devised a scheme involving moneys being held off-shore and in trust. In the course of
devising the scheme a document known in these proceedings as a…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…1999)....................................................................................................................18
iii
Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 5 of 40
Falco v. N. Shore Labs. Corp.,
866 So.2d 125…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…¶¶ 4, 5(a).)
Cooper & Kirk is sunk on either score. As a practical matter,
the Court would be surprised--shocked, even--if Cooper & Kirk was
not in some sense “using” the Maxwell discovery in its
representation of Ms. Giuffre in…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…misconduct” or the “sexual abuse of young girls at
the hands of the wealthy and powerful,” as the Miami Herald speculates. While the Court’s
review of the Sealed Materials will speak for itself on this score, to be specific…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…2.
Prosecutor Audrey Strauss condemned her as ‘playing a critical role in finding and
grooming victims’, while scores of Epstein’s victims claim that she acted as his ‘madam’,
often driving from his £20 million mansion in Palm Beach, Florida…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…Cir. 1999).................................................................................................................... 18
iii
Case 1:15-cv-07433-LAP Document 1137-14 Filed 10/22/20 Page 5 of 40
Falco v. N. Shore Labs. Corp.,
866 So.2d 12…
giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
…their testimony. So
6 that discovery has been ongoing for those bits and pieces that
7 we needed to shore up.
8 While I appreciate the concern over the fact that the
9 Rule 26 disclosures has her name, it…
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