giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…1). at~ 27 (Giuffre "described
Maxwell's role as one of the main women who Epstein used to procure under-aged girls for
sexual activities and a primary co-conspirator and participant in his sexual abuse and sex
trafficking scheme'')…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…to procure under-aged girls for sexual activities
1
Defendant has labelled her entire deposition transcript as Confidential at this time.
1
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…to procure under-aged girls for sexual activities
1
Defendant has labelled her entire deposition transcript as Confidential at this time.
1
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…at this time.
1
Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 2 of 17
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…at ¶ 27 (Giuffre “described
Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for
sexual activities and a primary co-conspirator and participant in his sexual abuse and sex
trafficking scheme”). In…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…relevant to at least three
issues in this case. First, Defendant’s recent efforts to conceal assets from the reach of this Court
proves consciousness of her guilt of sex trafficking. Second, Defendant’s financial affairs will
show dependence on…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…at this time.
1
Case 1:15-cv-07433-LAP Document 1218-1 Filed 07/15/21 Page 2 of 17
and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”).
Numerous other witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…to be called as a witness at trial because she can testify
about Defendant's involvement in Epstein's sex tratficking ring based on first-hand experiences
and first-hand observations.
Defendant Violated Rule 26 By Failing To Disclose This…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.28
38 pg
…I just explained. 6 you've termed it, sexual trafficking of
7 A. I spent the entire time talking to 7 Ms. Roberts.
8 Virginia's mother outside the house so the 8 To the extent you are asking for…
giuffre-maxwell
1320-2
10 pg
…1). at 127 (Giuffre '·described
Maxwell's role as one of the main women who Epstein used to procure under-aged girls for
sexual activities and a primary co-conspirator and participant in his sexual abuse and sex
trafficking scheme'')…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.2
10 pg
…1). at 127 (Giuffre '·described
Maxwell's role as one of the main women who Epstein used to procure under-aged girls for
sexual activities and a primary co-conspirator and participant in his sexual abuse and sex
trafficking scheme'')…
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.447706.1078.1
8 pg
…befriend, and groom
minor victims for abuse’ … ‘In some cases Maxwell participated in the abuse
itself.’2
1
https://www.law.com/newyorklawjournal/2020/07/02/ghislaine-maxwell-arrested-in-
connection-with-jeffrey-epstein-sex-trafficking-ring/?slreturn=20200614124921
2…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…against British socialite Ghislaine
Maxwell for saying that Roberts made “obvious lies” when accusing Maxwell of recruiting Roberts to
become a victim of sex trafficking between 1999 to 2002.
“Alan Dershowitz is not a party to that litigation,” said Boies…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…I just explained. 6 you've termed it, sexual trafficking of
7 A. I spent the entire time talking to 7 Ms. Roberts.
8 Virginia's mother outside the house so the 8 To the extent you are asking for…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
… I
14 would think you would give me this much material. You know,
15 this document implicates this person's privacy interests
16 because she is said to be a victim of sex trafficking. That's
17 all you need…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his sexual abuse and sex trafficking scheme. In fact…
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