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Case 18-2868, Document 281, 08/09/2019, 2628234, Page36 of 66
Ms. Giuffre disputes this statement. During 2000, Ms. Giuffre shared an apartment with
her then boyfriend, James Michael Austrich and his
Case 18-2868, Document 281, 08/09/2019, 2628234, Page38 of 66
Job postings and job descriptions produced by Mar-a-Lago from 2002 and later are
irrelevant to Ms. Giuffre’s employment because they are
Case 18-2868, Document 281, 08/09/2019, 2628234, Page40 of 66
massage. Jd. He furthered testified that he witnessed Ms. Giuffre at Epstein’s house on the very
same day that he witnessed Defendant rec
Case 18-2868, Document 281, 08/09/2019, 2628234, Page47 of 66
A few glaring examples of how Ms. Giuffre’s travel records are incomplete is that Ms.
Giuffre traveled from ADS (Addison, Texas) on May 3
Case 18-2868, Document 281, 08/09/2019, 2628234, Page33 of 66
While “Grade 30” indicates adult education, Ms. Giuffre’s attendance records indicate that she
was not present in school between 6/21/00
Case 18-2868, Document 281, 08/09/2019, 2628234, Page46 of 66
See also photo of Ms. Giuffre, Maxwell and Prince Andrew in London.
GIUFFRE007167; see also Figueroa Dep. Tr. at 251.
Ms. Giuffre, Epst
Case 18-2868, Document 281, 08/09/2019, 2628234, Page32 of 66
DEFENDANT’S PURPORTED FACTS
38. Ms. Giuffre re-enrolled in high school from June 21, 2000 until March 7, 2002. After
finishing the 9th g
Case 18-2868, Document 281, 08/09/2019, 2628234, Page31 of 66
MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS
Agreed. However, in discovery, Defendant was finally forced to produce the compl
Case 18-2868, Document 281, 08/09/2019, 2628234, Page28 of 66
DEFENDANT’S PURPORTED FACTS
33. In none of the nine instances was there any publication of the entire January 2015
statement.
MS. GIUFF
Case 18-2868, Document 281, 08/09/2019, 2628234, Page25 of 66
DEFENDANT’S PURPORTED FACTS
31, Ms. Giuffre has written the manuscript of a book she has been trying to publish detailing
her alleged ex
Case 18-2868, Document 281, 08/09/2019, 2628234, Page30 of 66
A. That is true, yeah.
RK
Q. Is it correct that you advertise your “excellent relationships with the media"
because your services often
Case 18-2868, Document 281, 08/09/2019, 2628234, Page23 of 66
See McCawley Dec. at Exhibit 6 Gow Dep. Tr. at 12:19-21; 13:9-16. The record evidence shows
that Defendant’s intent was for the press to
Case 18-2868, Document 281, 08/09/2019, 2628234, Page17 of 66
22. The January 2015 statement served two purposes. First, Mr. Barden intended that it
mitigate the harm to Ms. Maxwell’s reputation from
Case 18-2868, Document 281, 08/09/2019, 2628234, Page16 of 66
21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional
press release solely to disseminate informati
Case 18-2868, Document 281, 08/09/2019, 2628234, Page20 of 66
Second, Ms. Giuffre disputes that her allegations have changed over time, “dramatically”
or otherwise. Third, Ms. Giuffre disputes that t
Case 18-2868, Document 281, 08/09/2019, 2628234, Page10 of 66
and it is Ms. Giuffre's belief that the Government did fail to so inform the victims, and
intentionally did not inform the victims becaus
Case 18-2868, Document 281, 08/09/2019, 2628234, Page14 of 66
Q. To the extent you can recall or could estimate, how many other emails do you believe
you sent bearing that statement that's in Exhibit
Case 18-2868, Document 281, 08/09/2019, 2628234, Page18 of 66
Exhibit 2 Excerpted Rodgers Dep. Ex. | at flight #s 1433-1434, 1444-1446, 1464-1470,
1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 an
Case 18-2868, Document 281, 08/09/2019, 2628234, Page8 of 66
See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36
Exhibit 2 Excerpted Rodgers Dep. Ex. | at flight #s 143
Case 18-2868, Document 281, 08/09/2019, 2628234, Page7 of 66
= She “persuaded” Ms. Giuffre to go to Epstein’s mansion “in a fashion very similar to
the manner in which Epstein and his other co-conspi
Case 18-2868, Document 281, 08/09/2019, 2628234, Page5d of 66
6. To prove the applicability of the “crime/fraud/misconduct” exception to
the attorney-client privilege that was being raised by the Gov
Case 18-2868, Document 281, 08/09/2019, 2628234, Page1 of 66
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwel
Case 18-2868, Document 280, 08/09/2019, 2628232, Page73 of 74
massage, and converted her into a traveling sex slave, consistent with Defendant and Epstein’s
pattern and practice.
As the Court astutel
Case 18-2868, Document 280, 08/09/2019, 2628232, Page69 of 74
Defendant, in addition to the continued — and fraudulent — promise of a better future, as those
things that kept her retained in a situat
Case 18-2868, Document 280, 08/09/2019, 2628232, Page66 of 74
sixteen years old before August 9, 2000, and turned seventeen on that date. It is unclear from the
limited records available whether Defe
Case 18-2868, Document 280, 08/09/2019, 2628232, Page62 of 74
this term . . . Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation.
... Why, for instance, would it be
Case 18-2868, Document 280, 08/09/2019, 2628232, Page67 of 74
Contrary to Defendant’s misleading, cherry-picked fragments of information she has
chosen to use to support her point, there is an abunda
Case 18-2868, Document 280, 08/09/2019, 2628232, Page60 of 74
was not a limited public figure for failing one element of the Lerman test and thus denying
defendant’s motion for summary judgment) (“Th
Case 18-2868, Document 280, 08/09/2019, 2628232, Page71 of 74
child pornography. Yet Defendant has offered no such evidence — much less evidence so
powerful as to warrant summary judgment on this poi
Case 18-2868, Document 280, 08/09/2019, 2628232, Page61 of 74
Hutchinson v. Proxmire, 443 U.S. 111, 99 S. Ct. 2675, 61 L.Ed.2d 411 (1979) (finding plaintiff
maintained no regular and continuing acces
Case 18-2868, Document 280, 08/09/2019, 2628232, Page58 of 74
States Supreme Court, and reiterated by the Second Circuit, should be the light by which all of
Defendant’s purported “facts” and argumen
Case 18-2868, Document 280, 08/09/2019, 2628232, Page70 of 74
Defendant maintained the position that she “cannot speculate on what anybody else did or didn’t
do.” See McCawley Dec. at Exhibit 11, Ma
Case 18-2868, Document 280, 08/09/2019, 2628232, Page65 of 74
Defendant, by way of her January 2015 statement, declared that Ms. Giuffre lied about
each and every one of these allegations regarding D
Case 18-2868, Document 280, 08/09/2019, 2628232, Page55 of 74
whether Defendant has meritorious claims against the press on the grounds that she did not abuse
Ms. Giuffre is a question of fact for th
Case 18-2868, Document 280, 08/09/2019, 2628232, Page51 of 74
Similarly, in Black v. Green Harbour Homeowners’ Ass’n, Inc., 19 A.D.3d 962, 963, 798
N.Y.S.2d 753, 754 (2005), cited by Defendant, the C
Case 18-2868, Document 280, 08/09/2019, 2628232, Page52 of 74
evidence has been adduced to support the inference that [defendant] acted with malice, and may
not, therefore, claim a qualified privileg
Case 18-2868, Document 280, 08/09/2019, 2628232, Page47 of 74
about her history of having been sexually assaulted as a minor constitutes more
than a general denial, it alleges something deeply distu
Case 18-2868, Document 280, 08/09/2019, 2628232, Page48 of 74
Q. Do you believe Jeffrey Epstein sexually abused minors?
A. I can only testify to what I know. I know that Virginia is a liar and I know
Case 18-2868, Document 280, 08/09/2019, 2628232, Page42 of 74
such a determination of meaning and interpretation is a question of fact for the jury to decide,
and is inappropriate for a determination
Case 18-2868, Document 280, 08/09/2019, 2628232, Page37 of 74
has no control... Here, however . . . the appellant intended and authorized the republication of
the allegedly defamatory content of the
Case 18-2868, Document 280, 08/09/2019, 2628232, Page41 of 74
Defendant sent to the press: that Ms. Giuffre was lying about her past sexual abuse. Even in
isolation, Defendant’s quote stating that Ms
Case 18-2868, Document 280, 08/09/2019, 2628232, Page34 of 74
Additionally, 2011 correspondence with Sharon Churcher shows that Ms. Giuffre
disclosed her sexual encounters with Prince Andrew, but Chu
Case 18-2868, Document 280, 08/09/2019, 2628232, Page35 of 74
responded by calling her a liar in a press release intended for worldwide publication. Such
heinous conduct is not a mere “opinion,” but
Case 18-2868, Document 280, 08/09/2019, 2628232, Page43 of 74
“contemplations” 25 other times. All the while Defendant has claimed a privilege as to her
communications with Barden. Defendant attempts
Case 18-2868, Document 280, 08/09/2019, 2628232, Page32 of 74
This disturbing 2005 purchase corroborate Ms. Giuffre’s account of being sexually
exploited by Defendant and Epstein — not to mention the
Case 18-2868, Document 280, 08/09/2019, 2628232, Page33 of 74
10. It is undisputed fact that the FBI report and the Churcher emails
reference Ms. Giuffre’s accounts of sexual activity with Prince
And
Case 18-2868, Document 280, 08/09/2019, 2628232, Page28 of 74
The following are descriptions of a sampling of messages pads” that create a genuine dispute
of material fact:
One message pad reflects
Case 18-2868, Document 280, 08/09/2019, 2628232, Page31 of 74
approximately 100-page-long hard copy, which was openly available to other house employees.
It consisted primarily of telephone numbers,
Case 18-2868, Document 280, 08/09/2019, 2628232, Page24 of 74
Defendant and Epstein taking Plaintiff to New York Presbyterian Hospital in New York while
she was a minor.”° The dates on the hospital
Case 18-2868, Document 280, 08/09/2019, 2628232, Page23 of 74
warrant, including one photograph revealing the bare bottom of a girl who appears to be pre-
pubescent (Ms. Giuffre will only submit its