1320-27.pdf

"Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS"

"Sjoberg testified that, when she was a twenty-one-year-old college student, Defendant (not Jeffrey Epstein) recruited and hired her under the pretext "

"Ms. Sjoberg’s testimony also shows that Defendant was a predator of young women and girls, and that her business was to provide girls for Jeffrey Epst"

"Sigrid McCawley BOIES, SCHILLER & FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301"

"This brief contained excerpt from Rinaldo Rizzo’s “rough” deposition transcript, as the final transcript had not yet been completed by the stenographe"

"Case 1:15-cv-07433-LAP... Ms. Giuffre is still working diligently with opposing counsel"

"Defendant Maxwell has produced several emails between Epstein and herself ... In this defamation case"

"Sigrid McCawley (Pro Hac Vice) Boies Schiller & Flexner LLP"

"foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. "

"foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. "

"Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C."

"Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C."

"HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203"

"I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system."

"Defendant Maxwell hired to recruit girls for Jeffrey Epstein... Defendant working essentially as a madam for Jeffrey Epstein"

"Q. So is it fair to say that Maxwell expected you to perform sexual acts when you were massaging Jeffrey? A. I can answer? Yes, I took that conversati"

"Defendant had threatened a terrified 15 year old girl and confiscated her passport to try to make her have sex with Epstein on his private island"

"have sex with Epstein on his private island"

"Mr. Rizzo’s testimony was harmful to Defendant’s case"

"Ms. Sjoberg, Mr. Alessi, and Mr. Rizzo’s testimony was harmful to Defendant’s case"

"Epstein sexually abused the underage girls that were brought to him. ... testimony would fully confirm Ms. Giuffre’s account of her sexual abuse."

"Apparently privy to her former boyfriend Epstein’s anticipated plans in this regard"

"Defendant cannot refute the documentary evidence that she was on Epstein private jet with Ms. Giuffre over 20 times while Ms. Giuffre was a minor"

"Defendant cannot refute the documentary evidence that she was on Epstein private jet with Ms. Giuffre over 20 times"

"Defendant Maxwell has produced several emails between Epstein and herself discussing Ms. Giuffre."

"Defendant fails to recognize that in calling Ms. Giuffre a liar, she was attacking all aspects of Ms. Giuffre’s account ... Thus, in this defamation c"

"that deposition did not take place until June 10, 2016. Additionally, three other important witnesses evaded Ms. Giuffre’s repeated efforts to serve t"

"Ms. Giuffre mentioned former President Bill Clinton’s close personal relationship with Defendant and Jeffrey Epstein."

"Ms. Giuffre mentioned former President Bill Clinton’s close personal relationship with Defendant and Jeffrey Epstein."

"former President Clinton is a key person who can provide information about his close relationship with Defendant and Mr. Epstein"

"former President Clinton is a key person who can provide information about his close relationship with Defendant and Mr. Epstein"

"Defendant’s recruitment and management of the girls for Jeffrey Epstein was a major aspect of Defendant’s job"

"Defendant served generally as a recruiter of girls for Epstein and that Epstein sexually abused the underage girls that were brought to him."

"Sarah took her passport and phone and gave it to Ghislaine Maxwell"

"Ms. Sjoberg’s testimony also corroborates Ms. Giuffre’s accounts concerning her being trafficked to Prince Andrew."

"Defendant’s response brief cites no authority to refute that proposition that adverse inference can be drawn against co-conspirators."