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.447706.1106.0_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.447706.1259.0
17 pg
…R. Civ. P. 24............................................................................................................................. 7
5
Case 1:15-cv-07433-LAP Document 1259 Filed 07/28/22 Page 6 of 17
MEMORANDUM OF LAW
…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…Jane Doe 2 v. United States of
America, 08-cv-80736-KAM, as the “high-profile non-party individuals” to whom Mr. Jeffrey
Epstein sexually trafficked You, “including numerous prominent American politicians, powerful
business executives, foreign presidents, a well-known…
giuffre-maxwell
gov.uscourts.nysd.447706.1097.0_1
6 pg
…or
Maria Farmer.
7. All documents produced, or deposition or written testimony given, by any of the
following individuals whom Giuffre has testified she was sexually trafficked to by
Epstein:
a. Prince Andrew
b. Jean-Luc Brunel
c. Glenn Dubin
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…alleges that defendant Ms. Ghislaine Maxwell
defamed her by calling her a "liar" for filing documents alleging that Maxwell and her boyfriend,
Jeffrey Epstein, had sexually abused her and trafficked her for sexual purposes. See Mccawley
Deel., Exhibit 1 (complaint…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.3
7 pg
…2011.
16 Q So you did not write this journal at the
17 time it happened?
18 A No.
19 Q You started writing this journal
20 approximately a decade after you claim you finished
21 being sexually trafficked, correct…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…motion in limine seeking to exclude from evidence Ms. Giuffre’s
statement to the FBI in 2011 about Jeffrey Epstein’s and Defendant’s sex trafficking crimes,
raising a hearsay objection. In Defendant’s Motion in Limine to Exclude FBI…
giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…time.
1
Case 1:15-cv-07433-RWS Document 315 Filed 07/29/16 Page 2 of 17
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
2
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.385.0
2 pg
…representing
. Although Ms. Giuffre is not a
, central to that action are her allegations that she was the
victim of “sexual trafficking.”
4. Based on my knowledge of the …
giuffre-maxwell
gov.uscourts.nysd.447706.542.8
4 pg
…Revenue Code, or the corresponding section of any future federal tax
code. The corporation is organized to provide assistance to victims of sexual abuse as well as victims of human trafficking.
Upon the dissolution of Victims Refuse Silence, Inc., assets…
giuffre-maxwell
gov.uscourts.nysd.447706.712.0
11 pg
…e.g., Plaintiff’s Statement of Undisputed Facts in Response to Defendant’s Motion for
Summary Judgment at 4-27 (recounting details of Epstein’s and Defendant’s sex trafficking and sex
abuse conspiracy); see also Plaintiff Giuffre’s Reply…
giuffre-maxwell
gov.uscourts.nysd.447706.686.0
17 pg
…Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF MS. GIUFFRE’S MEMORANDUM OF LAW IN
SUPPORT OF HER MOTION IN LIMINE TO PRESENT
ALL EVIDENCE OF DEFENDANT’S INVOLVEMENT IN
EPSTEIN SEXUAL ABUSE AND SEX TRAFFICKING
…
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
…time.
1
Case 1:15-cv-07433-LAP Document 315 Filed 07/29/16 Page 2 of 17
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
2
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…Introduction
1. Ghislaine Maxwell did not participate in, facilitate, manage or otherwise conspire
to commit sex trafficking as alleged by Plaintiff Virginia Roberts Giuffre (“Giuffre”). Giuffre’s
unsubstantiated allegations concerning Ms. Maxwell are false. Giuffre’s fantastical claims,
contained in…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.3_1
7 pg
…is, which would be, as
6 you've termed it, sexual trafficking of
7 Ms. Roberts .
8 To the extent you are asking for
9 information relating to any consensual
10 adult interaction between my client and
11 Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.2_2
4 pg
…business
19 and I will instruct the wi tness not to
20 answer.
21 MS . McCAWLEY: This case involves
22 sexual trafficking , sexual abuse,
23 questions about her having interactions
24 with other females is relevant to this
25 case…
giuffre-maxwell
gov.uscourts.nysd.447706.1134.0_5
2 pg
…Id. at 1. But it should not
come as a surprise that those “non-parties,” including those implicated as potential abusers within
Jeffrey Epstein’s sex-trafficking conspiracy, would seek to obscure as much information
concerning their conduct as possible…
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