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.447706.1058.1
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.447706.1201.10_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.447706.996.0
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.447706.1247.0
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.447706.1090.18
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.447706.1325.1
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…
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.447706.1328.5
45 pg
…they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a minor victim of sexual trafficking.
Ms. Giuffre objects to the requests to the extent they are overly broad and unduly
burdensome…
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.447706.1320.8
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.447706.1074.0
18 pg
…that she could prove
the circumstances under which a non-party introduced her to Mr. Epstein, and how Mr. Epstein
sexually trafficked her to several high-profile non-party individuals, “including numerous
prominent American politicians, powerful business executives, foreign presidents…
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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