giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…During the deposition, the Non-Party testified that they had undergone extensive
therapy to overcome the trauma and did not want to be involved in the proceedings at all. Doe
#84’s name was mentioned in some of the sealed…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.10
15 pg
…nde r stand what
20 you and your lawyer have said here t oday , yo u have
21 been i nvolved in some n umber of years of therapy , i n
22 which the purpose -- part o f t he…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…emotional
problems, psychological or psychiatric disorders, sexually transmitted diseases, and
therapy records, and any prescriptions for any of the above categories.
25. Any Documents containing any Communications You have had with any law
enforcement agency.
26. Any Documents that reflect…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…of confidentiality under the Protective Order. During the deposition,
this Doe testified that she had undergone extensive therapy to overcome the trauma and did not
want to be involved in the proceedings at all. The Second Circuit sua sponte redacted…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…emergency care or other
treatment for any eating disorder, malnourishment, kidney malfunction, emotional problems,
psychological or psychiatric disorders, sexually transmitted diseases, and therapy records, and
any prescriptions for any of the above categories. (Complaint ¶ 52, 64; motivation to fabricate)
25…
giuffre-maxwell
gov.uscourts.nysd.447706.903.0
46 pg
…m paraphrasing -- said, I've spent
8 years forgetting all of this, I've spent lots of time in
9 therapy forgetting all of this, I'm not going to remember any
10 of this, and basically refused to answer…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…has little or no memory
of most or all of the events surrounding the time she knew Mr. Epstein, and specifically testified
that she is in therapy for the purpose of repressing any memories concerning Mr. Epstein. See
Menninger Decl…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…emergency care or other
treatment for any eating disorder, malnourishment, kidney malfunction, emotional problems,
psychological or psychiatric disorders, sexually transmitted diseases, and therapy records, and
any prescriptions for any of the above categories. (Complaint ¶ 52, 64; motivation to fabricate)
25…
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.447706.1218.1
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.447706.1330.17
12 pg
…educational records, all
of which were requested prior to her deposition. She even omitted records from her current
-
therapist and from the doctor who was (and is, apparently) prescribing substantial quantities of
drugs at the time of her depo…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…one of Epstein’s household employees, Juan Alessi, testified about the parade of
young “massage therapists” entering Epstein’s Palm Beach mansion, and that Ms. Giuffre was
one of the girls who came to Epstein’s mansion.8 Alessi also…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…Pagliuca
Decl., Ex. G at 200.
Mr. Epstein and Ms. Maxwell found the massage therapists from the high-end spas
nearby, including the Breakers, Boca Raton and Mar-a-Lago, as Mr. Alessi confirmed
when he called them at…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…underage females like herself, under the guise of working in a legitimate position - such as an
assistant or as a massage therapist - only to almost immediately be coerced or enticed into
engaging in sex for money. Defendant has challenged the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…underage females like herself, under the guise of working in a legitimate position - such as an
assistant or as a massage therapist - only to almost immediately be coerced or enticed into
engaging in sex for money. Defendant has challenged the…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
… id. Ex. 3 at 2 ("a law enforcement source "); id. Ex. 4
at 3 ("[massage] therapist, who does not wish to be named"); id.
Ex. 8 at 2 ("a le gal expert"; "a source familiar with the
case"). Churcher has…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…4). In truth, Mr. Alessi testified that the massage therapists for Mr. Epstein were over
the age of 18 and that he only assisted Ms. Maxwell in hiring adult massage therapists from high
end spas such as Breakers Hotel, Mar…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…underage females like herself, under the guise of working in a legitimate position - such as an
assistant or as a massage therapist - only to almost immediately be coerced or enticed into
engaging in sex for money. Defendant has challenged the…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…underage females like herself, under the guise of working in a legitimate position - such as an
assistant or as a massage therapist - only to almost immediately be coerced or enticed into
engaging in sex for money. Defendant has challenged the…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.23
10 pg
…4). In truth, Mr. Alessi testified that the massage therapists for Mr. Epstein were over
the age of 18 and that he only assisted Ms. Maxwell in hiring adult massage therapists from high
end spas such as Breakers Hotel, Mar…
Comments