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Case 18-2868, Document 283, 08/09/2019, 2628241, Page221 of 883
ray
JOSEPH RECAREY - CONFIDENTIAL
THE WITNESS: Correct.
BY MR. EDWARDS:
Q. And let me go back to the beginning six
pages of that exhib
Case 18-2868, Document 283, 08/09/2019, 2628241, Page192 of 883
Confidential
Page 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
—- = = = = = = = ee we ewe et ew ew ete et et ee hl hx
Case 18-2868, Document 283, 08/09/2019, 2628241, Page162 of 883
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
VIRGINIA L. GIUFFRE,
Plaintiff,
Case No.:
-against- 15-cv-07433-RWS
GHISL
Case 18-2868, Document 283, 08/09/2019, 2628241, Page152 of 883
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
Civil Action No. 15-cv-07433-RWS
VIDEOTAPE DEPOSITION OF: P
Case 18-2868, Document 281, 08/09/2019, 2628234, Page58 of 66
the house had already been sanitized, revealed photographs of nudity displayed, including a
photograph of Maxwell herself in the nude. Se
Case 18-2868, Document 281, 08/09/2019, 2628234, Page54 of 66
to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove
her to the airport. While there, she initially con
Case 18-2868, Document 281, 08/09/2019, 2628234, Page55 of 66
seen coming or going from the house during the law enforcement surveillance of
Epstein’s home. The arrest warrant did not mention Ms. Max
Case 18-2868, Document 281, 08/09/2019, 2628234, Page57 of 66
trafficking scheme from a high level, and insulated herself from most of the underage girls who
were being paid for sex.
Tony Figueroa,
Case 18-2868, Document 281, 08/09/2019, 2628234, Page56 of 66
19, 21, Banasiak Dep. Tr. at 8:21-9:16; 14:20-15:6; Alessi Dep. Tr. at 23:11-23:20; Rodriguez
Dep. Tr. at 169:1-169:4.
Rodriguez, the ho
Case 18-2868, Document 281, 08/09/2019, 2628234, Page37 of 66
eventually put her on their payroll, but paid her very little. Giuffre Dep. Tr. at p. 52; Aviculture
Breeding and Research Center taxable
Case 18-2868, Document 281, 08/09/2019, 2628234, Page24 of 66
DEFENDANT’S PURPORTED FACTS
28. Ms. Giuffre repeatedly has sought out media organizations to discuss her alleged
experience as a victim
Case 18-2868, Document 281, 08/09/2019, 2628234, Page4 of 66
Giuffre gratuitously included provocative and “lurid details” of her alleged sexual
activities as an alleged victim of sexual trafficking.
Case 18-2868, Document 281, 08/09/2019, 2628234, Page3 of 66
Media contact:
Ross Gow
Acuity Reputation
Tel: +44-203-008-7790
Mob: +44-7778-755-251
Email: [email protected]
Media contact
Case 18-2868, Document 280, 08/09/2019, 2628232, Page30 of 74
massages as reflected in the Palm Beach Police Report. Giuffre 001427 (pictured
above) — 1/2/03 — JE from “Wants to know if she should br
Case 18-2868, Document 280, 08/09/2019, 2628232, Page25 of 74
... [Ms. Giuffre] was approached by Ghislaine Maxwell who said she could help
her get a job as a massage therapist . . . seemed respectab
Case 18-2868, Document 278, 08/09/2019, 2628230, Page644 of 648
EDWARDS: Objection --
THE WITNESS: During this telephone
conversation --
BY MR. PAGLIUCA:
Yes.
-- or in general?
During this teleph
Case 18-2868, Document 278, 08/09/2019, 2628230, Page560 of 648
Confidential/Sealed Transcript Pursuant to Court Order
Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016)
Job No. J02
Case 18-2868, Document 278, 08/09/2019, 2628230, Page562 of 648
Confidential/Sealed Transcript Pursuant to Court Order
Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016)
Job No. J02
Case 18-2868, Document 278, 08/09/2019, 2628230, Page504 of 648
Page 211
JOSEPH RECAREY - CONFIDENTIAL
A. Correct.
Q. And then Mr. Epstein is arrested and ends
up pleading guilty and all of that, ri
Case 18-2868, Document 278, 08/09/2019, 2628230, Page505 of 648
Page 212
H RECAREY - CONFIDENTIAL
THI ESS: No. Based on the questions
that the state was asking, no.
BY MR. PAGLIUCA:
Q. Were you
Case 18-2868, Document 278, 08/09/2019, 2628230, Page485 of 648
IN DI
Examination by Mr. Edwards
Examination by Ms. Schultz
Examination by Mr. Pagliuca
Further Examination by Ms. Schultz
Further Ex
Case 18-2868, Document 278, 08/09/2019, 2628230, Page448 of 648
Confidential
Page 12
DAVID RODGERS
years. The period of time -- or that is evidenced
by this logbook is '95 through 2013.
Why was it
Case 18-2868, Document 278, 08/09/2019, 2628230, Page447 of 648
Confidential
Page 11
DAVID RODGERS
Q. And is that number unique to the aircraft?
A. Yes.
Q. So there is no other aircraft at the s
Case 18-2868, Document 278, 08/09/2019, 2628230, Page442 of 648
Confidential
DAVID RODGERS
A. Yes.
Q. Can you -- can you tell me -- I have been
provided by your attorney a -- what has been
represe
8.22868 30, Page318 of 648
ZN, 4. Request for Capias 1
Agency ORI Number Agency Name Agency Report Number
ROYAL PALM BEACH POLICE DEPARTMENT | 8,6 |-!9, 9 |-13,0,4,6
— |_}2. Traffic Felony [] 4. Tra
Case 9:08-c¥-28746-RANS, Desumverit 32a. OBereAlsh FOSS BhcRage4O7IZIES Page 9 of 10
id. at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4’s “participation in this
case” can only be a
Case 9:08-cV-287 36-RAN, Document 32a, OB/eAlch EOS BacRaveAMTIAIL Page 7 of 10
issue, the Court finds that its action of striking the lurid details from Petitioners’ submissions is
sanction enough.
Case 18-2868, Document 278, 08/09/2019, 2628230, Page27 of 648
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 10 of 14
Jane Doe #3’s and Jane Doe #4’s participation is al
Case 18-2868, Document 278, 08/09/2019, 2628230, Page23 of 648
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 6 of 14
young as twelve) to the United States for sexual pur
Case 18-2868, Document 278, 08/09/2019, 2628230, Page26 of 648
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 9 of 14
The new victims will establish at trial that the Gov
Case 18-2868, Document 278, 08/09/2019, 2628230, Page25 of 648
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 8 of 14
The acts Epstein committed against Jane Doe #4, cons
Case 18-2868, Document 278, 08/09/2019, 2628230, Page19 of 648
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 2 of 14
As the Court is aware, more than six years ago, Jane
Case 9:08-c¥-28746-RANS, Desumrerit 32a. OB/18reAlsh FOSS BhcRAVeAMIIAIGS Page 1 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:08-CV-80736-KAM
JANE DOE 1 and JANE DOE 2,
P
Case 18-2868, Document 278, 08/09/2019, 2628230, Page4 of 648
6/14/2016
Manhattan.
The photograph that appeared last weekend shows the prince strolling through Central Park with
58-year-old Epstein.
Case 18-2868, Document 278, 08/09/2019, 2628230, Page14 of 648
6/15/2016
Epstein’s many Hollywood pals include Matt Groening, creator of The Simpsons.
‘Jeffrey once had me give Matt a foot massage wh
Case 18-2868, Document 276, 08/09/2019, 2628224, Page70 of 77
seized from Epstein’s home during the execution of the search warrant, which would include any
“child pornography” reportedly created by
Case 18-2868, Document 276, 08/09/2019, 2628224, Page64 of 77
Maxwell until she worked at the Mar-A-Lago as a spa attendant, and she confirms that she
obtained that job with the assistance of her fat
Case 18-2868, Document 276, 08/09/2019, 2628224, Page52 of 77
home, participated in and had knowledge of the search warrant executed on the Epstein home,
and testified regarding the case before the F
Case 18-2868, Document 276, 08/09/2019, 2628224, Page29 of 77
identify two instances in which plaintiff's allegations or claims'* are incapable of being proved
true or false. Such examples abound. It
Case 18-2868, Document 276, 08/09/2019, 2628224, Page17 of 77
within the Southern District of New York,”” as plaintiff alleged in Paragraph 9 of Count I of her
complaint. In response, plaintiff ident
Case 18-2868, Document 276, 08/09/2019, 2628224, Page12 of 77
e =Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea
agreement, because the immunity protected her from prosecutio
Case 18-2868, Document 276, 08/09/2019, 2628224, Page9 of 77
Statement on Behalf of Ghislaine Maxwell
By Devonshires Solicitors, PRNE
Wednesday, March 9, 2011
London, March 10, 2011 - Ghislaine Max
Case 18-2868, Document 276, 08/09/2019, 2628224, Page16 of 77
28. Plaintiff repeatedly has sought out media organizations to discuss her alleged
experience as a victim of sexual abuse. See This Motio
Case 18-2868, Document 275, 08/09/2019, 2628223, Page15 of 18
revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she
was never considered a suspect by the gove
Case 18-2868, Document 275, 08/09/2019, 2628223, Page14 of 18
Beach area in that vehicle. In August 2002, Plaintiff acquired a Dodge Dakota pickup truck from
her father. Figueroa used that vehicle in
Case 18-2868, Document 275, 08/09/2019, 2628223, Page10 of 18
32. Republication alleged by plaintiff. Plaintiff was required by Interrogatory No. 6 to
identify any false statements attributed to Ms.
Case 18-2868, Document 275, 08/09/2019, 2628223, Page3 of 18
It is unacceptable that letters sent by Ms Maxwell’s legal representatives to
certain newspapers pointing out the truth and asking for the
Case 18-2868, Document 275, 08/09/2019, 2628223, Page6é of 18
12. In the joinder motion, plaintiff also alleged she was “forced” to have sex with
Harvard law professor Alan Dershowitz, “model scout”
Case 18-2868, Document 275, 08/09/2019, 2628223, Page9 of 18
26. Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation,
directly related to her alleged experience as
Case 18-2868, Document 273-2, 08/09/2019, 2628218, Page16 of 25
monitoring the federal courts.””° Thus, while evidence introduced at
trial or in connection with summary judgment enjoys a strong
presu