giuffre-maxwell
gov.uscourts.nysd.447706.1258.0
3 pg
…and requests that the Court unseal and make
public and unredacted any and all documents that identify the men who abused the girls trafficked
by Jeffrey Epstein and Defendant Maxwell (“the Epstein Client List”).
Sealing those documents violates the rights…
giuffre-maxwell
gov.uscourts.nysd.447706.1264.0
1 pg
…the purpose of moving to unseal and
make public a hypothetical set of documents that TGP speculates identify a group of non-parties
in this action who allegedly “abused girls trafficked by Jeffrey Epstein and Defendant Maxwell.”
See DE 1258…
giuffre-maxwell
gov.uscourts.nysd.447706.1058.1
3 pg
…Plaintiff has alleged, falsely, that circumstances surrounding Jeffrey Epstein made
it obvious to Dershowitz that she was being “trafficked” to him. As we understand it, virtually
every witness in Maxwell was asked about their percipient knowledge of Epstein’s alleged…
giuffre-maxwell
gov.uscourts.nysd.447706.1302.0
3 pg
…of “any and all documents” filed in Giuffre v. Maxwell that “identify the men who abused
the girls trafficked by Jeffrey Epstein and Defendant Maxwell.” Appellant’s App’x at 260. The
District Court denied TGP’s motion to intervene…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…Tr. at p 311:13-312:10.
The electronic communications non-party Ransome produced corroborates her testimony
that she was being trafficked by Defendant and Jeffrey Epstein, including being forced to lose
additional weight during the time she was being…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…fact that this is why we have laws in the United States to protect minor children
who are groomed and sexually trafficked by adults.'
Epstein served 13 months in a Florida prison after pleading guilty in 2008 to soliciting a…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…lawsuit presents one relatively simple question: is Plaintiff’s claim that she was
sexually abused, sexually trafficked and held as a “sex slave” by Jeffrey Epstein between 1999
and 2002 “with the assistance and participation of” Ms. Maxwell substantially true…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…lawsuit presents one relatively simple question: is Plaintiff’s claim that she was
sexually abused, sexually trafficked and held as a “sex slave” by Jeffrey Epstein between 1999
and 2002 “with the assistance and participation of” Ms. Maxwell substantially true…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.27
6 pg
…Q. Who?
8 A. and
9 , I'm not too sure.
10 Q. How often were you sexual trafficked in
11 Jeffrey Epstein's private bedroom?
12 MS. MCCAWLEY: Objection. Which bedroom
13 are you talking about?
14 BY MS…
giuffre-maxwell
gov.uscourts.nysd.447706.956.0
3 pg
…Roberts, who asserts that she was a victim of Epstein, alleged, among other things, that
Epstein had “trafficked” her to Mr. Dershowitz for sex. The allegation is utterly false and
defamatory: Mr. Dershowitz has never even met Ms. Roberts – and…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…was telling the truth. To
prove the truth of her sexual abuse, Ms. Giuffre seeks discovery of documents evidencing her
sexual abuse and sexual trafficking by Maxwell and her associates, including convicted sex
offender Jeffrey Epstein. Therefore, documents evidencing Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Motions in limine re admissibility of evidence and related orders.
We said papers in this category were negligibly judicial documents because of plaintiff’s
improper attempt to transform her defamation lawsuit into a de facto sex trafficking lawsuit
against Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
… rather, he is trying to find a way to send this victim of sexual trafficking to
“jail.” “She was hiding in Colorado…but we found her and she will have to be deposed. The end
1
For the limited…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking. Ms.
Giuffre objects to the requests to the extent they are overly broad and unduly…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…at
4:10-16 (“In the context of this case, especially its allegations of sex trafficking of young girls, the
Court finds that any minor embarrassment or annoyance resulting from disclosure of Ms.
Maxwell’s mostly nontestimony about behavior that…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…relevant to Dershowitz’s defense of the sexual assault claims which Giuffre has
brought against him on the theory that he was “on notice” that she was being sexually trafficked
by Epstein merely by observing her in Epstein’s home…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…accordance with the character.”
Furthermore, no other witness has claimed as Plaintiff does that Ghislaine Maxwell sexually abused them, sexually
trafficked them, or that she partook in daily sex with any underage girls. Plaintiff’s claim stands in isolation because…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
… Nor was it reasonable to accuse me of pedophila based on the fact that Ms.
Giuffre alleged in the Josefsberg-drafted civil complaint that she had been trafficked by Jeffrey
8
Case 1:15-cv-07433-LAP Document 1218…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…counsel, Brad Edwards, on how to use a
potential Vanity Fair article as book publicity by dropping names of famous politicians, claiming
she was sex trafficked, but refusing to provide additional information because she was writing a
book. Menninger Decl…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…over the span
of four years, that Maxwell had participated in a scheme to cause Giuffre to be “sexually abused
and trafficked” by Jeffrey Epstein.
1
See Norman Mailer, “An Appeal to Lillian Hellman and Mary McCarthy,” 5/11/80…
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