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.447706.356.0
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.447706.1137.1_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
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.447706.160.0
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.447706.1.0
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.447706.712.0
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.447706.315.0
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.447706.69.2
21 pg
…Fairway Lakes Drive, Boynton Beach, FL 33472
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein’s sexual
trafficking conduct and interaction with underage minors.
4. Maria Alessi
6791 Fairway Lakes Drive, Boynton Beach…
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.447706.1332.17
13 pg
…of Confidential Materials. This
Court should issue an Order to Show Cause.
FACTUAL BACKGROUND
Ms. Giuffre sought to convert her defamation action into a lawsuit for child “sexual
abuse” and “sexual trafficking” of children. Toward that end, she made numerous…
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.447706.1134.0_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…
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.447706.149.0
9 pg
…i.e., did Ms. Maxwell assist Mr. Epstein in the sexual trafficking of the
Plaintiff from 1999 to 2002. The
ARGUMENT
Federal Rule of Civil Procedure 26(b)(1) provides, in relevant part, that "[p]arties may
obtain discovery regarding…