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.447706.1201.10_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.447706.996.0
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.447706.1247.0
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.447706.1206.2
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…Inc., 800 F.2d 298 (2d
Cir. 1986).
10
witnesses have corroborated Plaintiff’s claim that she was “sexually trafficked.” Plaintiff’s
counsel has withdrawn the Joinder Motion in which Plaintiff made that allegation. These, along
with the numerous other…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…Id. ¶ 8. Ms. Giuffre
claims that she was held as a “sex slave” and trafficked by Epstein, who she alleges facilitated
sexual encounters with a number of men. Id.
In the period from 2006 through 2014, Ms. Giuffre submitted to…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…docs.html (Plaintiff’s counsel statements to the
press that the “document dump” would include evidence that would “expose that sex trafficking
scheme,” implying it contains evidence that young females “as young as 11” were abused,
despite absolute lack of…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…did they?
16 MS. SCHULTZ: Object to form.
17 THE WITNESS: I don't believe so.
18 BY MR. PAGLIUCA:
19 Q. None of them ever reported being
20 trafficked by Mr. Epstein to other men, correct?
21 MS. SCHULTZ…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Ms. Ransome’s fulsome production included items such as multiple e-mails with
. These e-mails are direct
evidence of the trafficking of females for the purpose of sex, and the use of fraud and manipulation to
accomplish that purpose…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…U.S.C. § 1595 for engaging in commercial sex trafficking. Despite the fact that it is well settled
that a Court should not consider documents beyond the four corners of the complaint in
evaluating a Motion to Dismiss, the Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…Ms. Ransome’s fulsome production included items such as multiple e-mails with
. These e-mails are direct
evidence of the trafficking of females for the purpose of sex, and the use of fraud and manipulation to
accomplish that purpose…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…Service.
The three persons to be subpoenaed – Jeffrey Epstein, Sarah Kellen and Nadia Marcinkova –
were each involved in the sexual abuse and sexual trafficking at issue in this case. It appears that
all three of them have evaded attempts to…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…the Plaintiff in this case. The allegations include that
“Epstein also sexually trafficked the then-minor Jane Doe [#3], making her available for sex to
politically-connected and financially-powerful people." The "politically-connected and
financially powerful people" identified by…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…yes.
14 Q. And you're aware, are you not, that there
15 are allegations that you were sexually trafficked being
16 made in that action, correct?
17 A. I'm aware that there are allegations that I
18 was…
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