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Case 1:15-cv-07433-LAP Document 1320-11 Filed 01/03/24 Page 1 of 4
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
Vv.
Ghislaine
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 13 of 28
2. Johanna Sjorberg (3 % hours). Ms. Sjorberg’s deposition was taken on May 18,
2016, in Fort Lauderdale. She testified as follows
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 18 of 28
including during the time that Ms. Giuffre was staying the night at the mansion when she was a
minor child. Virginia interacted wi
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 15 of 28
that I was not one of those girls. He was always trying to recruit me almost in a way that
I could be one of them and travel with
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 9 of 28
During her deposition, however, Defendant did not take the Fifth. Instead, she testified
that she suffered from a series of memory
Case 9:08@AS60735-RV NT 4Beduifrenb2azumeEntdeeoog Aritad BbOa242/Bame dat hAge 4 of 13
(along with other young girls) to such powerful people were to ingratiate himself with them for
business, perso
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 1 of 28
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine M
Case 9:08@AS60735-RV MT 4Beduifrenb2acumeEntdaz0og Aritad BOa242/Bame 240f HAge 1 of 13
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Johnson
JANE DOE #1 and
Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 6 of 12
Q Are you aware of Jeffrey Epstein and Ghislaine Maxwell’s sexual interaction
with Jane Doe-102 when she was a minor?
Q This is one
Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 5 of 12
Investigator Alpha Group. In addition, counsel for Ms. Giuffre reached out to Ms. Marcinkova’s
former counsel but he indicated that
Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 2 of 9
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Page 1
Case No: 08-CV-80119
Case NO: 08-CV-80232
Case No: 08-CV-80380
Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 6 of 10
roughly the same age group as C. and T. (minor children) and to have a good time as
you put it?
A. Yes.
Q. And what was her involv
Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 1 of 10
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine
Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 2 of 10
Yet during her deposition, Defendant refused to answer any questions that she construed
as having something to do with “consensual a
Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 6 of 10
to turn massages into sex (that was his modus operandi and plan all along); and that Maxwell
recruited other females for an ostensib
Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 1 of 10
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine
Case 18-2868, Document 287, 08/09/2019, 2628251, Page74 of 76
that the Press Release was anything near an attorney’s
statement; Barden was not even copied on the email.
The pre-litigation privilege
Case 18-2868, Document 287, 08/09/2019, 2628251, Page69 of 76
Maxwell acknowledges that the Court properly applied
Davis at the motion to dismiss stage, but argues that the third
factor, especially,
Case 18-2868, Document 287, 08/09/2019, 2628251, Page68 of 76
In deciding its motion to dismiss opinion, the Court
relied on Davis v. Boeheim, 22 N.E.3d 999 (2014), and held that
the three allegedly
Case 1:15-cv-07433-LAP Document 1320 Filed 01/03/24 Page 1of1
BOIES
SCHILLER
—_ FLEXNER
January 3, 2024
VIA ECF
The Honorable Loretta A. Preska
District Court Judge
United States District Court
S
Case 18-2868, Document 287, 08/09/2019, 2628251, Page76 of 76
VII. Conclusion
For the reasons set forth above, the motion for
summary judgment is denied.
The parties are directed to jointly file a
Case 18-2868, Document 287, 08/09/2019, 2628251, Page67 of 76
audience for a press release is the public. The motion to
dismiss opinion clearly addressed this issue:
Sexual assault of a minor is a c
Case 18-2868, Document 287, 08/09/2019, 2628251, Page53 of 76
Id. The relevant inquiry on application for summary judgment is
“whether the evidence presents a sufficient disagreement to
require submi
Case 18-2868, Document 287, 08/09/2019, 2628251, Page61 of 76
does not distort or misrepresent the message Maxwell intended to
convey to the public with the Press Release.
Because the purpose of th
Case 18-2868, Document 287, 08/09/2019, 2628251, Page60 of 76
specialist. The Press Release was sent by Maxwell’s express
request. Gow’s testimony about the process leading up to the
dissemination of
Case 18-2868, Document 287, 08/09/2019, 2628251, Page54 of 76
to a lack of evidence . . . on an essential element of the non-
movant’s claim... . [T]he nonmoving party must [then] come
forward with a
Case 18-2868, Document 287, 08/09/2019, 2628251, Page65 of 76
are not substantially true.” Boehner v. Heise, 734 F.
Supp. 2d 389, 399 (S.D.N.Y. 2010).
The motion for summary judgment to dismiss the
Case 18-2868, Document 287, 08/09/2019, 2628251, Page28 of 76
Giuffre has denied the statement and noted that she
was approached by numerous media outlets and refused to speak to
most of them, that m
Case 18-2868, Document 287, 08/09/2019, 2628251, Page3 of 76
Ir. The Facts
The facts have been set forth in Maxwell’s Memorandum
of Law in Support of Maxwell’s Motion for Summary Judgment,
Southern
Case 18-2868, Document 287, 08/09/2019, 2628251, Page2 of 76
Sweet, D.J.
The defendant Ghislaine Maxwell (“Maxwell” or the
“Maxwell”) has moved pursuant to Rule 56, Fed. R. Civ. P., for
summary judg
<r
Case 18-2868, Document 287, 08/09/2019, 2628251, Page1 of 76
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
poo eee eee ++ xX
VIRGINIA GIUFFRE,
Giuffre,
-against-
GHISLAINE MAXWELL,
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25
Case 184gren Rlande Coust Reporting & Video, TAGe.49 of 55
DESCRIPTION
INDEX OF EXHIBITS
INITIAL
REFERENCE
Complaint and Demand for Jury 17
Trial re Jane Doe No. 102 v.
Jeff
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24
25
Case 1949Ken Rlande Coust Repgoting & Video, ING=15 of 55
DESCRIPTION
Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Exhibit 5
Exhibit 6
Exhibit 7
Exhibit 8
Exhibit 9
Exhibit 10
Exhi
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25
Case 1949Ken Blande Coust Repgoting & Video, ENG=19 of 55
(e) (BY MS. MENNINGER) Yes.
A Yes.
Q And during any of those communications, do
you know whether she printed things
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25
Case 1949Ken Blande oust Repgoting & Video, ING=16 of 55
INITIAL
DESCRIPTION
Exhibit 15
Exhibit 16
Exhibit 17
Exhibit 18
Exhibit 19
Exhibit 20
R
Patient Health Summar
Case 18-2868, Document 286, 08/09/2019, 2628248, Page3 of 55
Miami, Florida 33301
(954) 356-0011
smccawley @bsfllp.com
Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue
Case 18-2868, Document 286, 08/09/2019, 2628248, Page2 of 55
United States District Court
Southern District Of New York
Virginia L. Giuffre,
Plaintiff,
v. 15-cv-07433-RWS
Ghislaine Maxwell,
Defend
Case 18-2868, Document 285, 08/09/2019, 2628246, Page4 of 4
CERTIFICATE OF SERVICE
I certify that on February 10, 2017, I electronically served this Declaration of Laura A.
Menninger in Support of D
Case 18-2868, Document 284, 08/09/2019, 2628244, Page33 of 38
A This is my writing.
Q Okay. To the best of your recollection as you sit here right now, is there anything
in that manuscript about Ghi
Case 18-2868, Document 285, 08/09/2019, 2628246, Page1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
wenn eee eee een ene eee xX
VIRGINIA L. GIUFFRE,
Plaintiff, :
v. : 15-cv-07433-
Case 18-2868, Document 284, 08/09/2019, 2628244, Page31 of 38
Roberts in Mr. Epstein’s house.” Ex.HH at { 17. Detective Recarey entered Epstein’s home in
2002 to install security cameras to catch a t
Case 18-2868, Document 284, 08/09/2019, 2628244, Page36 of 38
Fact 40 includes the statement, “Ms. Giuffre was hired as a ‘seasonal’ spa attendant to work at
the Mar-a-Lago Club in the fall of 2000 a
Case 18-2868, Document 284, 08/09/2019, 2628244, Page17 of 38
victims of sexual abuse.” Toward this end, plaintiff has “dedicated her professional life to
helping victims of sex trafficking.” Id.
a.
Case 18-2868, Document 284, 08/09/2019, 2628244, Page24 of 38
of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff
for a job there. Jd. at 72. Mar-a-Lago clo
Case 18-2868, Document 284, 08/09/2019, 2628244, Page19 of 38
a. Reply: Plaintiff directs the Court to her response to paragraph 52 and suggests
the factual statement is misleading. She, however, off
Case 18-2868, Document 284, 08/09/2019, 2628244, Page16 of 38
time-only, comprehensive response—quoted in full—to plaintiff's December 30, 2014,
allegations that would give the media Ms. Maxwell’s re
Case 18-2868, Document 284, 08/09/2019, 2628244, Page14 of 38
a. Reply: Plaintiff makes two responses. As to the first sentence, she asserts
without evidentiary support that “the Court should not con
Case 18-2868, Document 284, 08/09/2019, 2628244, Page11 of 38
motion, members of the media obtained copies of the motion. Ex.G at 31:2-36:4 & Depo. Exs.
3-4.
a. Reply: Plaintiff cites no contrary ev
Case 18-2868, Document 284, 08/09/2019, 2628244, Page1 of 38
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defenda
Case 18-2868, Document 283, 08/09/2019, 2628241, Page878 of 883
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 11 of 14
new victims will simply join in a single summary j