giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
… Dr. Donahue............................................................................................................ 9
B.
C.
-Dr. Hayek................................................................................................................ 9
Dr. Kutikoff, Wellington…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…Edwards”) and PAUL G. CASSELL (“Cassell”) (together,
“Plaintiffs”) in opposition to Dershowitz’s Motion to Compel Production of Documents and
Complete Responses to Interrogatories (the “Motion to Compel”).1
INTRODUCTION
At the outset of their Response, Pla…
giuffre-maxwell
gov.uscourts.nysd.447706.1258.0
3 pg
…heard, together with such other and further relief as this Court deems just and proper.
1
Case 1:15-cv-07433-LAP Document 1258 Filed 07/28/22 Page 2 of 3
PLEASE TAKE NOTICE that opposition papers, if…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…at the house maybe a handful of days, again.
7 Q. I would like to direct you to, you
8 have it pulled together now, it's page 39,
9 Bates stamped Giuffre 00040?
10 A. Can you repeat that…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…to accomplish is not a reason to unseal. Rather, the
hundreds of interested Non-Parties together with Ms. Maxwell have every right and reason to
expect that the promises of confidentiality afforded by a Protective Order, to which Plaintiff and
…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…having said all of that, this really is the first
5 time that we've had an opportunity, I think, to get together on
6 this case. And let me just say, I think -- I mean, I'm not
7…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.16_1
9 pg
…else you remember about her when she
4 walks into the kitchen.
5 A. Very attractive, beautiful young
6 girl. Makeup, very put together, casual
7 dress. But she seemed to be upset, maybe
8 distraught, and she was shaking…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…But having said all of that, this really is the first
5 time that we've had an opportunity, I think, to get together on
6 this case. And let me just say, I think -- I mean, I'm not
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.26
6 pg
…9 A That her and Ms. Maxwell and Jeffrey would
10 obviously be doing stuff, all three of them
11 together. Like I said, that they would all go out
12 to clubs to pick up girls and try and…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.10
13 pg
…of mine. Barely an acquaintance. We maybe
10 spoke three times in our entire going to school
11 together and everything.
12 Q. Did you ever learn what her incentive was
13 to bring you to Jeffrey Epstein's house?…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.11
11 pg
…9 A That her and Ms. Maxwell and Jeffrey would
10 obviously be doing stuff, all three of them
11 together. Like I said, that they would all go out
12 to clubs to pick up girls and try and…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.8
8 pg
…9 A That her and Ms. Maxwell and Jeffrey would
10 obviously be doing stuff, all three of them
11 together. Like I said, that they would all go out
12 to clubs to pick up girls and try and…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…fully below, the Requested Documents, separately and
together, demonstrate that the allegations of sexual misconduct lodged and repeated by Ms.
Giuffre are nothing more than a recent fabrication— a made up story designed to increase
commercial interest in Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…MAXWELL and
Epstein were photographed together on multiple occasions,
including in the below image:
2
Case 1:15-cv-07433-LAP
Case 1:20-cr-00330-AJNDocument
Document1078-3 Filed
17 Filed 07/29/20Page
…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
… Dr. Donahue ............................................................................................................ 9
B.
C.
-
Dr. Hayek ................................................................................................................ 9
…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…abuse suffered by Ms. Giuffre and others at the hands of
Maxwell, and should not be withheld. Moreover, flight logs demonstrate that Sarah Kellen and
Maxwell flew together multiple times, including with Ms. Giuffre. See McCawley Decl. at
Exhibit 4…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…Ms. Giuffre was 14 years old. Ms. Giuffre recalls
one facility named “Growing Together” that was located in or around
Palm Beach, but she does not recall the dates when she resided at the
facility.
! Ms. Giuffre lived and travelled…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…the
airplane, Mr. Cassell also states that the flight logs show me and “an apparently young woman
named who did not appear to serve any business purpose for Epstein” flying together
on Mr. Epstein’s plane with Mr. Epstein and…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…Harry at
charity soccer match...
while her older brothers
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…5, 2015. https://www.youtube.com/watch?v=KXzcxsiQv7Q.
And yet (among other occasions), a flight log shows Epstein and Dershowitz traveling together—alone.
5
The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005).
6
Vanity Fair Reminds…
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