giuffre-maxwell
gov.uscourts.nysd.447706.1256.7
14 pg
…11 We further agree not to share, give, copy,
scan, fax or in any way distribute this
12 realtime rough draft in any form (written or
computerized) to any party. However, your
13 own experts, cocounsel and staff may have
…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…the particular dates
and times when you allege to have been present in your response to Request No. 5,
above.
7. All statements, written or recorded, which you have provided to anyone that reference by
name, Alan M. Dershowitz.
8…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…40
a. the date of any such Communication;
b. the form of any such Communication, whether oral or written and if
written, the format of any such Communication;
c. the identities of all persons involved in the Communication, including the…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
…taped statement, did he ever present
4 BY MR. CRITTON: 4 anything ror you, anything in writing that he had
5 Q. Is that correct? 5 written to say, Mr. Rodriguez, I would like you to
6 A. Yes, correct…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
…the same freely and vo/untarif;· for the uses and purposes
therein mentioned.
[SEAL]
offtera/ seal the d.iy and year 1asl above written.
Hsiao-Chi…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…10
Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 12 of 48
b. the form of any such Communication, whether oral or written and if
written, the format of any such Communication;
c…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…asking these questions before I -
MR. BOIES: I’m asking these questions because these are people who not only have
been publicly written about in terms of the sexual activity that they were put into in
connection with Mr. Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…
15 A. I emailed after I read an
16 article that she had written about
17 Jeffrey Epstein, and the last sentence
18 was -- it was on the 16th of October,
19 and one of the last sentences I
20…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…161
Along with Farmer’s remarks, Assistant U.S. Attorney Alison Moe read from a letter
written by another of Maxwell’s alleged victims, who asked to be identified only as Jane
Doe. It’s possible that the woman may…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…Roberts at Mar-a-Lago? 12 Q. Is it possible she was 13 years old
13 A. Again, this was written in, when 13 when you first met her?
14 were you saying? 14 MR. PAGLIUCA: Object to the form…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.15
6 pg
…KUVIN: Just for the video record and 3 It's also compound.
4 for the written record Katherine Ezell and Amy 4 THE WlTNESS: On the instruction ofmy
5 Ederi have now appeared and are present in 5 lawyer l…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…Miami Beach, FL 33141
NON PARTY (VR) 000272
GIUFFRE00096 l
Case 1:15-cv-07433-LAP Docum…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…11 Q. So does that correct your testimony
12 that you did meet Ms. Roberts at Mar-a-Lago?
13 A. Again, this was written in, when
14 were you saying?
15 Q. 2011.
16 A. So by 2011, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…11 Q. So does that correct your testimony
12 that you did meet Ms. Roberts at Mar-a-Lago?
13 A. Again, this was written in, when
14 were you saying?
15 Q. 2011.
16 A. So by 2011, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.13
9 pg
… 20 Q Have you ever seen the names of these females
21 MR. CRITTON: Form. 21 that are alleged to have been masseuses written on
22 E WITNESS: She told me he was his boyfriend 22 anything?
23 (sic), …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…10
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 12 of 48
b. the form of any such Communication, whether oral or written and if
written, the format of any such Communication;
c…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…sell her story to the media, in or about October 2016. Pottinger Ex. 1
at 38 (“I emailed her after I read an article that she had written about Jeffrey Epstein.”); id. at 50
3
(“There were, I think…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
! Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at 9…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…limitation:
a. the date of any such Communication;
b. the form of any such Communication, whether oral or written and if
written, the format of any such Communication;
c. the identities of all persons involved in the Communication, including the…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
…11 Q. So does that correct your testimony
12 that you did meet Ms. Roberts at Mar-a-Lago?
13 A. Again, this was written in, when
14 were you saying?
15 Q. 2011.
16 A. So by 2011, Ms…
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