Will They Kill Themselves?

January 3rd, 2024 Epstein Files

The first of the Epstein Client List documents have been unsealed.

  1. 1320-1.pdf
    • Email from Ghislaine Maxwell to Philip Barden and Ross Gow
    • The sender expresses concern about potential legal risks, including defamation, and the desire to avoid lawsuits. They mention being inexperienced with legal matters, particularly in the U.S., and the complexities of the U.S. legal system. The email refers to ongoing civil suits and discovery motions related to Jeffrey Epstein, and the sender's need to consult U.S. lawyers before making any statements to minimize legal exposure. The email also mentions the need for a crafted statement to address potential defamation risks and the sender's relationship with notable figures like Clinton and Andrew. The sender is overwhelmed ("too may cooks in the kitchen") and requests assistance in understanding and managing these risks. The email concludes with a mention of the sender's recent personal loss and a need for a break, with plans to resume discussions on Monday. The document also references The TerraMar Project and social media accounts.
    • Names mentioned:
  2. 1320-2.pdf
    • PLAINTIFF'S MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL
    • This document is a legal motion filed by Virginia Giuffre's legal counsel in a case against Ghislaine Maxwell in the United States District Court for the Southern District of New York. It seeks to compel Maxwell to answer deposition questions she previously refused to respond to, concerning allegations of sexual activity and trafficking linked to Jeffrey Epstein. The motion argues that these questions are crucial to the defamation case, as they pertain to Giuffre's claims of being recruited by Maxwell for sexual abuse by Epstein. The document details Maxwell's repeated refusals to answer questions about her and Epstein's sexual activities, including those with alleged "adults," and the impact of this refusal on the case. The plaintiff's counsel asserts that these answers are necessary to establish the truth of Giuffre's allegations and Maxwell's knowledge of the sexual nature of massages and other interactions at Epstein's properties.
    • Names mentioned:
  3. 1320-3.pdf
    • Videotaped deposition of GHISLAINE MAXWELL (Transcript)
    • Jeffrey S. Pagliuca
    • Names mentioned:
  4. 1320-4.pdf
    • Videotaped deposition of GHISLAINE MAXWELL (Transcript)

    • This document is a transcript of Ghislaine Maxwell's deposition for the case of Virginia L. Giuffre vs. Ghislaine Maxwell, held on April 22, 2016. It details the examination of Maxwell regarding her knowledge of, and involvement in, sexual acts and recruitment of masseuses for Jeffrey Epstein. Maxwell repeatedly denies witnessing any inappropriate or underage activities with Epstein and objects to many questions on the grounds of consensual adult sex. Her lawyer frequently interjects to object to the form and foundation of questions, and instructs Maxwell not to answer certain inquiries related to her personal sexual activities. The transcript also mentions interactions with prominent figures, including Bill Clinton, and discusses Maxwell's relationship with various individuals associated with Epstein.

    • Names mentioned:
  5. 1320-5.pdf
    • Videotaped deposition of GHISLAINE MAXWELL (Transcript)
    • Questions About People Under the Age of 18 at Epstein’s Home
    • The document is a detailed transcript of a legal deposition involving Ghislaine Maxwell, taken in April 2016 at the law offices of Boies Schiller & Flexner in New York. It's part of a case filed in the Southern District of New York. The deposition covers various topics, including Maxwell's employment practices at Jeffrey Epstein's properties, her interactions with Virginia Roberts Giuffre and other individuals, her visits to Mar-a-Lago, and her role in hiring staff, including massage therapists. Throughout the deposition, Maxwell denies involvement in or knowledge of any illegal activities, particularly those involving minors. The transcript also includes objections and instructions from lawyers, reflecting the contentious and complex nature of the legal proceedings.
    • Names mentioned
  6. 1320-6.pdf
    • PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS

    • Plaintiff Virginia Giuffre is filing a reply in support of her motion to compel defendant Ghislaine Maxwell to answer deposition questions related to her involvement in or knowledge of sexual activities connected to Jeffrey Epstein's abuse of females. This evidence is crucial to corroborating Giuffre's testimony and impeaching Maxwell's credibility. Testimonies from household staff members confirm the presence of young girls engaged in sexual activities at Epstein's home, Maxwell's involvement in recruiting them for massages, and her possession of explicit images. Giuffre's questions are narrow in focus and will be kept confidential. The relevance of the questions and the burden of demonstrating irrelevance lies with Maxwell. The conclusion requests that Maxwell be ordered to answer the specific questions about sexual activity.

    • Names mentioned:

      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Jeffrey Epstein
      • Sigrid S. McCawley
      • Prince Andrew
      • Alfredo Rodriguez
      • Juan Alessi
      • David Boies
      • Bradley J. Edwards
      • Paul G. Cassell
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
  7. 1320-7.pdf
    • Depositions Jane Doe 2, 3, 4, 5, 6, 7, II, 101, 102, Alfredo Rodriguez
    • Names mentioned:
      • C.W.
      • Jane Doe No. 2
      • Jeffrey Epstein
      • Jane Doe No. 3
      • Jane Doe No. 4
      • Jane Doe No. 5
      • Jane Doe No. 6
      • Alfredo Rodriguez
      • Jane Doe No. 7
      • Stuart Mermelstein
      • C.M.A.
      • Brad J. Edwards
      • Cara Holmes
      • Emma Rosen
      • Jane Doe
      • Podhurst Orseck
      • Katherine W. Ezell
      • Jane Doe No. 11
      • Leopold-Kuvjn
      • Adam J. Langino
      • Jane Doe No. 101
      • Richard Willits, Esq.
      • Jane Doe No. 102
      • Robert Critton
      • Joe Langsam
      • Maria
      • Eva
      • Ghislaine Maxwell
      • Jean-Luc Brunel
      • Michelle Payne
      • Sarah Kellen
  8. 1320-8.pdf
    • PLAINTIFF’S NON-REDACTED MOTION FOR LEAVE TO SERVE THREE DEPOSITION SUBPOENAS BY MEANS OTHER THAN PERSONAL SERVICE
    • Difficulty serving deposition subpoenas to key individuals involved in a sexual abuse and trafficking case. Seeking permission for alternative service methods due to evaded personal service attempts. Crucial to gather testimony and evidence for the case and ensure justice is served.
    • Names mentioned:
  9. 1320-9.pdf
    • JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION
    • Jane Doe #3 and Jane Doe #4 seek to join the action against the United States for violations of their rights under the CVRA. The Court has previously ruled that the CVRA rights apply to Jane Doe #1 and Jane Doe #2, despite no federal charges against Epstein. Jane Doe #3 was sexually abused by Epstein and coerced into becoming a "sex slave." She was also forced to have relations with Alan Dershowitz and Prince Andrew, facilitated by Ghislaine Maxwell. Epstein trafficked Jane Doe #3 to powerful men for potential blackmail. Jean Luc Brunel was involved in sexual trafficking as well.
    • Names mentioned:
      • Jane Doe #1
      • Jane Doe #2
      • Jane Doe #3
      • Jane Doe #4
      • Jeffrey Epstein
      • Ghislaine Maxwell
      • Alan Dershowitz
      • Prince Andrew
      • Jean-Luc Brunel
      • Bradley J. Edwards
      • Paul G. Cassell
      • Dexter Lee
      • A. Marie Villafaña
  10. 1320-10.pdf
    • PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
    • Plaintiff Virginia Giuffre seeks permission to exceed the ten deposition limit in her case against Defendant Ghislaine Maxwell. The depositions are necessary due to Maxwell's challenge to Giuffre's claims and refusal to provide direct answers. Various witnesses are needed to establish key facts in the case, such as flight identities and the recruitment of underage females for sex. The requests for additional depositions fall within the allowed hours and the Defendant has obstructed the process by refusing to attend scheduled depositions. Giuffre's counsel has engaged in discussions with Defendant's counsel but no agreement has been reached. The Defendant's obstruction may require more time for discovery.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • David Boies
      • Bradley J. Edwards
      • Paul G. Cassell
      • Johanna Sjoberg
      • Juan Alessi
      • Maria Alessi
      • David Rodgers
      • Rinaldo Rizzo
      • Jean-Luc Brunel
      • Ross Gow
      • Dana Burns
      • Jo Jo Fontanella
      • Joseph Recarey
      • Michael Reiter
      • Emmy Taylor
      • Alexandra Hall
      • Nadia Marcinkova
      • Sarah Kellen
      • Jeffrey Epstein
      • Prince Andrew
      • Alfredo Rodriguez
      • Governor Bill Richardson
      • Fredrick Fekkai
      • David Copperfield
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
  11. 1320-11.pdf
    • NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN FEDERAL RULE OF CIVIL PROCEDURE 30(A)(2)(a)(ii), FILED UNDER SEAL
    • Sigrid S. McCawley has submitted a declaration in support of Virginia Giuffre's motion to exceed the presumptive ten deposition limit in the case against Ghislaine Maxwell. The motion seeks permission to take additional depositions beyond the set limit, citing the Defendant's challenge to the Plaintiff's claims and a need to establish key facts in the case. The declaration includes attached exhibits, such as email correspondence, deposition transcripts, and other documents related to the case. The Defendant's obstruction and refusal to attend scheduled depositions are mentioned as contributing factors. Granting approval to exceed the deposition limit is crucial in ensuring a fair and thorough legal process for Virginia Giuffre's case.
    • Names mentioned:
  12. 1320-12.pdf
    • Deposition of JOHANNA SJOBERG
    • The deposition is part of the Virginia L. Giuffre vs Ghislaine Maxwell case. Johanna Sjoberg testifies about her initial meeting with Maxwell and her employment offer. She visited Maxwell's residence in Palm Beach and met Jeffrey there.
    • Names mentioned:
  13. 1320-13.pdf
    •  PALM BEACH POLICE DEPARTMENT Incident Report
    • The page contains narrative reports from the Palm Beach Police Department about the investigation of Jeffrey Epstein. The reports detail the execution of a search warrant at Epstein's residence, the seizure of items such as massage tables and explicit photographs, and interviews with individuals involved. The reports include allegations of inappropriate behavior by Epstein during massages. The investigation was ongoing at the time of the reports.
    • Names mentioned:
      • Janusz Banasiak
      • Daniel Estes
      • Mark Zeff
      • Jeffrey Epstein
      • Sgt. Frick
      • Gus Fronstin
      • Joseph Recarey
      • Nickie A. Altomaro
      • Haley Robson
      • Sarah Kellen
      • Adrianna Mucinska
      • Nadia Marcinkova
      • Alfredo Rodriguez
      • Juan Alessi
      • Maria Alessi
      • Ghislaine Maxwell
      • Donald Morrell
      • Gus Fronstin
      • Alan Dershowitz
      • Roy Black
      • Paul A Lavery
      • Johanna Sjoberg
      • Joanna Harrison
      • Victoria Bean
      • Lana Belohlavek
      • Jack Goldberger
  14. 1320-14.pdf
    • Email from Jeffrey Epstein to Ghislaine Maxwell
    • Email from Ross Gow to Ghislaine Maxwell and Philip Barden
    • Email exchanges discussing allegations against an individual named Virginia relating to a Clinton dinner and an underage orgy in the Virgin Islands. The emails suggest offering a reward to disprove Virginia's allegations, mention leaked information about Prince Andrew's sex slave accusations, and refer to a confidential report by the Palm Beach County Sheriff's Office concerning drug abuse, witchcraft, and animal sacrifice involving children in Royal Palm Beach. The emails also include contact information for Ross Gow, the managing partner of Acuity Reputation.
    • Names mentioned:
  15. 1320-15.pdf
    • Email Spreadsheet/Log
    • This document is a privilege log from a legal case, specifically detailing email communications related to the legal representation of Virginia Giuffre. Spanning from early 2015 to 2024, it lists various types of privileged communications between Giuffre and her legal team, including attorneys like Sigrid McCawley, Brad Edwards, Paul Cassell, and others. The communications cover a range of subjects such as legal advice, case strategy, media communications, and draft legal documents. Most of these communications are withheld under attorney-client privilege and work product doctrine, indicating they are confidential and not disclosed in the court proceedings. The log reflects the extensive and detailed legal work undertaken in the case, encompassing over 1,000 documents and involving multiple legal professionals and staff.
    • Names mentioned:
      • Virginia L. Giuffre
      • Sigrid S. McCawley
      • Stan Pottinger
      • Bradley J. Edwards
      • Paul G. Cassell
      • Brittany Henderson
      • Meredith L. Schultz
      • David Boies
      • Jack Scarola
      • Ellen Brockman
      • Andres Ortiz
      • Stephen Zach
      • Katherine W. Ezell
      • Amy Ederi
      • Bob Josefsberg
      • Rebecca Boylan
      • Alan Dershowitz
  16. 1320-16.pdf
    • Ghislaine Maxwell’s Privilege Log Amended as of May 16, 2016
    • The page is a privilege log from the case Giuffre v. Maxwell, listing emails between Ghislaine Maxwell and her attorneys. Privileges such as attorney-client privilege and common interest privilege are asserted under British law, Colorado law, and NY law. The log includes dates, recipients, and attachments related to legal advice and common interests.
    • Names mentioned:
      • Ghislaine Maxwell
      • Brett Jaffe, Esq.
      • Ross Gow
      • Brian Basham
      • Jeffrey Epstein
      • Alan Dershowitz
      • Philip Barden
      • Mark Cohen
      • Martin Weinberg, Esq.
      • Laura A. Menninger
      • Mary Borja
      • Darren Indyke
  17. 1320-17.pdf
    • DEFENDANT GHISLAINE MAXWELL’S RESPONSES AND OBJECTIONS TO PLAINTIFF’S SECOND REQUEST FOR PRODUCTION OF DOCUMENTS
    • The document from the United States District Court Southern District of New York is part of the legal proceedings in the defamation case between Virginia L. Giuffre and Ghislaine Maxwell. It consists of Ghislaine Maxwell's formal responses and objections to the plaintiff's second request for the production of documents. In the responses, Maxwell's representatives outline numerous objections to the requested document categories, frequently invoking privileges such as attorney-client and work-product doctrines. Maxwell also denotes what she perceives to be the overbroad and unduly burdensome nature of the requests, the irrelevance to the subject matter, as well as privacy concerns. Her team contests certain characterizations and assumptions intrinsic to the requests and seeks protective orders for her financial information, selectively responding to certain requests while deferring or outright refusing others. The document ends with a certification of the service of these responses to opposing counsel.
    • Names mentioned:
      • Ghislaine Maxwell
      • Virginia L. Giuffre
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Paul G. Cassell
      • Bradley J. Edwards
      • Alan Dershowitz
      • Ross Gow
      • Bill Clinton
      • Hilary Clinton
      • Chelsea Clinton
  18. 1320-18.pdf
    • RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS AND ATTORNEY WORK PRODUCT MATERIALS
    • In this document, the legal team of Virginia L. Giuffre, led by Boies, Schiller & Flexner LLP, responds to a motion seeking to compel the disclosure of attorney-client communications and work product materials in the case against Ghislaine Maxwell. They argue that Virginia Giuffre has not waived her attorney-client privilege or work-product protections, citing the controlling authority of Federal Rule of Evidence 502 which protects against such waivers. They note that the Florida court previously ruled that no waiver occurred in a related defamation action brought by her attorneys against Alan Dershowitz, argue that Giuffre's communications were never “at issue,” and affirm that Giuffre's legal team does not plan to use any confidential attorney-client communications in the current case against Maxwell. The document concludes by urging the court to deny the motion to compel.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • David Boies
      • Alan Dershowitz
      • Bradley J. Edwards
      • Jeffrey Epstein
      • Hala Gorani
      • Jack Scarola
      • Juan Alessi
      • Alfredo Rodriquez
      • Sarah Kellen
      • Nadia Marcinkova
      • Adrianna Mucinska
      • Paul G. Cassell
      • Judge Marra
      • Judge Lynch
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
  19. 1320-19.pdf
    • Deposition of Virginia Giuffre
    • To provide you with a one-paragraph summary, I would need more context or a topic to summarize. A summary is a condensed version of a larger text or discourse, capturing the main points and essential information. Without knowing the specific content or subject that requires summarizing, I cannot craft an appropriate summary. If you can provide a passage, document, set of events, or a topic, I can then generate a concise summary for you. Please provide the information to summarize, and I'll be glad to help.
    • Names mentioned:
  20. 1320-20.pdf
    • DEFENDANT’S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT
    • In the district court case of Virginia L. Giuffre v. Ghislaine Maxwell, Maxwell's legal team responded in opposition to Giuffre’s motion to take more than the standard ten depositions, arguing that the request is premature and that nearly double the limit is unnecessary. They assert that the additional depositions Giuffre proposed won't yield new information but will instead provide cumulative or duplicative testimony irrelevant to the key issues of the defamation case. Maxwell’s attorneys highlight that Giuffre has not substantiated the relevance, nor demonstrated the necessity of the testimony from the extra deponents to the defamation claim, and they question Giuffre's interpretation of the Federal Rules regarding deposition limits. They add that Giuffre's purported strategy seems less about obtaining evidence and more about seeking corroboration for her allegations. Furthermore, they state that Maxwell answered all questions during her own deposition and stress that testimonies from individuals who may invoke the Fifth Amendment should not warrant an adverse inference against Maxwell. Maxwell's team concludes by requesting that the motion for additional depositions be denied or, if granted, that Giuffre should bear any extra costs involved.
    • Names mentioned:
  21. 1320-21.pdf
    • PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT
    • This page is a legal document that serves as a reply in support of a motion to exceed the presumptive ten deposition limit in a case involving Ghislaine Maxwell. The plaintiff argues that the proposed depositions are important to the fundamental claims and defenses of the case, and none of them are duplicative. They also claim that the request is timely and necessary for the proper development of the case. The plaintiff seeks to take three additional depositions, including one from former President Bill Clinton, to gather relevant information and disprove the defendant's claims.
    • Names mentioned:
  22. 1320-22.pdf
    • DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S REPLY TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT
    • This is a declaration by Sigrid S. McCawley, a partner at the law firm Boies, Schiller & Flexner LLP, in support of Plaintiff's Reply to a Motion to Exceed Presumptive Ten Deposition Limit in a case between Virginia L. Giuffre and Ghislaine Maxwell. The declaration includes attached exhibits of deposition transcripts and states that the information provided is true and correct to the best of McCawley's knowledge. The document also includes a certificate of service, indicating that the document was filed electronically and served to relevant individuals.
    • Names mentioned:
  23. 1320-23.pdf
    • Deposition of JOHANNA SJOBERG
    • This page contains a confidential deposition of Johanna Sjoberg in the Virginia L. Giuffre vs. Ghislaine Maxwell case, where Sjoberg describes an incident involving a puppet of Prince Andrew, a photo with sexual undertones, and Maxwell's involvement in procuring girls for Jeffrey Epstein.
    • Names mentioned:
  24. 1320-24.pdf
    • PLAINTIFF’S CORRECTED REPLY IN SUPPORT OF MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT
    • In this page, Ms. Giuffre files a request for additional depositions in her case against Defendant, arguing that they are important and not duplicative. She cites examples of Defendant's mischaracterizations and lack of memory during previous depositions and argues that the additional depositions are necessary to prove her claims and refute Defendant's statements. She also mentions the need for former President Bill Clinton's deposition to provide information about his relationship with Defendant and Jeffrey Epstein. Ms. Giuffre asserts that the evidence from these depositions is crucial in proving her defamation claim.
    • Names mentioned:
  25. 1320-25.pdf
    • CORRECTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S REPLY TO MOTION TO EXCEED  PRESUMPTIVE TEN DEPOSITION LIMIT
    • This page contains a corrected declaration by Sigrid S. McCawley in support of the plaintiff's reply to a motion to exceed the presumptive ten deposition limit in the case of Virginia L. Giuffre v. Ghislaine Maxwell. The declaration includes exhibits of deposition transcript excerpts from Johanna Sjoberg, Rinaldo Rizzo, and Juan Alessi.
    • Names mentioned:
  26. 1320-26.pdf
    • Deposition of JOHANNA SJOBERG
    • In this content, a deposition of Johanna Sjoberg is described. Sjoberg mentions attending a gathering at Jeffrey Epstein's home where she met Prince Andrew, Ghislaine Maxwell, and Virginia Giuffre. Sjoberg recalls a puppet of Prince Andrew being brought out and a photo being taken with the puppet's hand placed on Virginia's breast and Andrew's hand on her own breast. Sjoberg also mentions being asked to bring other girls to Epstein and performing sexual acts during massages. Maxwell is implied to have suggested having other girls around to please Epstein.
    • Names mentioned:
  27. 1320-27.pdf
    • PLAINTIFF’S AMENDED CORRECTED REPLY IN SUPPORT OF MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT
    • This page contains a plaintiff's amended reply in support of a motion to exceed the presumptive ten deposition limit in the Ghislaine Maxwell case. The plaintiff argues that the proposed depositions are important to the fundamental claims and defenses in the case and are not duplicative. The plaintiff also argues that the request for additional depositions is timely. The web page includes a table of contents, table of authorities, and the plaintiff's arguments and justifications for the motion.
    • Names mentioned:
      • Ms. Giuffre
      • Rinaldo Rizzo
      • Bill Clinton
      • Prince Andrew
      • Jeffrey Epstein
      • Ghislaine Maxwell
  28. 1320-28.pdf
    • DEFENDANT’S COMBINED MEMORANDUM OF LAW IN OPPOSITION TO EXTENDING DEADLINE TO COMPLETE  DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45
    • The web page content is a legal document in the form of a response to a motion to extend the deadline to complete depositions and motion for sanctions for violations of Rule 45. The document argues that the plaintiff has shown a lack of diligence in securing the remaining depositions and outlines various instances of alleged failure on the plaintiff's part. The document also argues against granting additional time for depositions, stating that it would unduly prejudice the defendant.
    • Names mentioned:
      • Ghislaine Maxwell
      • Bill Clinton
      • Louis Freeh
      • Ross Gow
      • Jeffrey Epstein
      • Sharon Churcher (witness)
  29. 1320-29.pdf
    • Videotaped deposition of RINALDO RIZZO
    • Rinaldo Rizzo, in his videotaped deposition, testified in the case of Virginia Giuffre versus Ghislaine Maxwell about his past employment with Glenn Dubin and Eva Anderson Dubin, issues arising during that period, and subsequent legal actions. He revealed his educational background, marital status, and his professional history in private domestic service. The deposition also discusses his lawsuit against the Dubins, any discussions he had regarding Jeffrey Epstein, his disability, and his interactions with Virginia Giuffre's attorney, Brad Edwards. Rizzo confirmed he had not worked after the lawsuit against the Dubins, is currently on disability, and opted not to retain Edwards as legal counsel.
    • Names mentioned:
      • Rinaldo Rizzo
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Leslie Fagin
      • Bradley J. Edwards
      • Jeffrey S. Pagliuca
      • Robert Lewis
      • Rodolfo Duran
      • Debra Rizzo
      • Glenn Dubin
      • Eva Anderson Dubin
      • Jeffrey Epstein
  30. 1320-30.pdf
    • Deposition of Virginia Giuffre
    • This page contains a deposition taken in a legal case between Virginia Giuffre and Ghislaine Maxwell. The deposition includes discussions about a photograph of Giuffre with Prince Andrew and the whereabouts of that photograph.
    • Names mentioned:
  31. 1320-31.pdf
    • NOTICE OF SERVICE OF RULE 45 SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT INSPECTION OF PREMISES UPON JEAN LUC BRUNEL
    • The provided document is a Notice of Service of Subpoena to Produce Documents in the case of Virginia Giuffre v. Ghislaine Maxwell. The subpoena is directed towards Jean Luc Brunel and requests the production of various documents and media related to Ghislaine Maxwell, Jeffrey Epstein, and their associates. The document also includes definitions and instructions regarding the production of documents. Additionally, an email exchange between attorneys discusses the rescheduling of depositions.
    • Names mentioned:
  32. 1320-32.pdf
    • NOTICE OF SERVICE OF RULE 45 SUBPOENA DUCES TECUM UPON <REDACTED>
    • The web page is a document related to a civil action, specifically a subpoena for testimony at a deposition. The document outlines the rules and requirements for compliance with the subpoena, including the place of compliance, protecting the person subject to the subpoena, and potential sanctions for noncompliance. The document also includes definitions of certain terms and instructions for producing documents.
    • Names mentioned:
  33. 1320-33.pdf
    • DEFENDANT’S MOTION FOR RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH COURT ORDER AND FAILURE TO COMPLY WITH RULE 26(a)
    • Defendant Ghislaine Maxwell has filed a motion for sanctions against the plaintiff for failure to comply with court orders and failure to disclose certain information. The motion alleges that the plaintiff has not provided complete responses to interrogatories and has not disclosed all relevant documents and witnesses. The defendant argues that the plaintiff's non-compliance should result in Rule 37 sanctions.
    • Names mentioned:
      • Ghislaine Maxwell
      • Dr. Steven Olson
      • Dr. Scott Robert Geiger
      • Dr. Joseph Heaney
      • Donna Oliver P.A.
      • Dr. Michele Streeter
      • Wellington Imaging Assocs.
      • Dr. Donahue
      • Dr. Lightfoot
  34. 1320-34.pdf
    • Declaration Of Laura A. Menninger In Support Of Defendant’s Motion For Rule 37(B) &(C) Sanctions For Failure To Comply With Court Order And Failure To Comply With Rule 26(A)
    • This document is a declaration by Laura A. Menninger, an attorney representing Ghislaine Maxwell, in support of a motion requesting sanctions against the plaintiff, Virginia L. Giuffre, for not complying with a court order and discovery rules in a case before the United States District Court Southern District of New York. Menninger argues that Giuffre failed to adhere to Rule 37(b) & (c) as well as Rule 26(a), and she provides multiple exhibits as evidence, some of which are under seal. This document also includes a certificate of service indicating the parties to whom the declaration and motion were served electronically on June 20, 2016.
    • Names mentioned:
  35. 1320-35.pdf
    • Deposition of Virginia Giuffre
    • Interesting to note that the OCR on this page is completely failed. Full text search is not possible with the document as provided.
    • Virginia Giuffre, in her deposition on May 3, 2016, discusses her past involvement with Jeffrey Epstein and Ghislaine Maxwell, the psychological trauma she continues to experience as a result of being trafficked and the denials of her allegations made by Maxwell and others. She describes the distress these denials have caused her, leading to severe anxiety and panic attacks, and how she has sought help from various professionals, including psychiatrist Dr. Judith Lightfoot. Giuffre details the burning of her personal journal, memories being recounted in therapy, and her efforts to overcome her past by starting a charity, Victims Refuse Silence. Giuffre also discusses her attempts to retrieve evidence and documentation shipped to Australia and the logistics around a photograph involving Prince Andrew.
    • Names mentioned:
      • Virginia L. Giuffre
      • Jeffrey Epstein
      • Ghislaine Maxwell
      • Dr. Judith Lightfoot
      • Prince Andrew
      • Marvin Minsky
      • Bradley J. Edwards
      • Sharon Churcher
      • Jason Richards
      • Judge Paul Cassell
      • Dr. Olsen
      • Alan Dershowitz
      • Bill Clinton
      • Dr. Donahue
  36. 1320-36.pdf
    • Declaration Of Laura A. Menninger In Support Of Defendant's Motion to Reopen Deposition of Plaintiff Virginia Giuffre
    • This document is a declaration by Laura A. Menninger, an attorney representing Ghislaine Maxwell, in support of a motion to reopen the deposition of plaintiff Virginia Giuffre in the Southern District of New York. Menninger outlines her credentials, lists several exhibits attached to the declaration—including transcripts from hearings, letters regarding discovery, medical records, depositions, and an errata sheet, some of which are filed under seal and marked confidential—and certifies that she has served the declaration electronically to counsel for Virginia Giuffre and others on June 20, 2016. The document ends with a certificate of service detailing the names and contact information of the attorneys served.
    • Names mentioned:
  37. 1320-37.pdf
    • PLAINTIFF’S SECOND AMENDED SUPPLEMENTAL RESPONSE AND OBJECTIONS TO DEFENDANT’S FIRST SET OF DISCOVERY REQUESTS TO PLAINTIFF
    • In this page, is a legal document related to a case filed by Virginia L. Giuffre against Ghislaine Maxwell. It includes Plaintiff's second amended supplemental response and objections to Defendant's first set of discovery requests. The document discusses various requests for information and documents related to Giuffre's residences, employment history, communications, healthcare providers, and photographs/video evidence. It also mentions that some documents are being withheld due to joint defense privilege and that both parties have their own responsive documents. The document ends with a certificate of service stating that the responses were served electronically on the specified date.
    • Names mentioned:
  38. 1320-38.pdf
    • Deposition of Virginia Giuffre
    • Virginia Giuffre was deposed regarding her interactions with Ghislaine Maxwell and Jeffrey Epstein, as well as her discussions with the press. Giuffre appears to describe being sexually trafficked by Maxwell and Epstein, and discusses the emotional distress this has caused her. The deposition also covers topics like Giuffre's conversations with doctors about the trauma she endured.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Jeffrey Epstein
      • Juan Alessi
      • Sharon Churcher
      • Michael Thomas
      • Paul Silva
      • Jarred Weisfeld
      • Marianne Strong
      • Judith Lightfoot
      • Dr. Olsen
      • Dr. Donahue
  39. 1320-39.pdf
    • The document is an extensive legal privilege log from the case "Giuffre v. Maxwell," detailing a range of confidential communications, primarily emails, involving Virginia Giuffre and her legal team. These emails, spanning several years, relate to various legal matters, including discussions about potential litigation, legal advice, and communications with law enforcement entities. The document reflects the complex nature of the legal proceedings, highlighting the breadth of communication and coordination among Giuffre's legal representatives as they navigated multiple legal challenges and investigations. The privilege log asserts attorney-client and work product privileges, indicating these documents are confidential and were not disclosed in the litigation process.
    • Names mentioned:
      • Sigrid S. McCawley
      • Laura A. Menninger
      • Virginia L. Giuffre
      • Jason R. Richards
      • Robert Giuffre
      • Christina Pyror
      • Sharon Rikard
      • Bradley J. Edwards
      • Paul G. Cassell
      • Brittany Henderson
      • David Boies
      • Jack Scarola
      • Stan Pottinger
      • Ellen Brockman
      • Meredith L. Schultz
      • Stephen Zach
      • Bob Josefsberg
      • Katherine W. Ezell
      • Amy Ederi
      • Andres Ortiz
      • Rebecca Boylan
  40. 1320-40.pdf
    • DEFENDANT GHISLAINE MAXWELL’S THIRD SUPPLEMENTAL F.R.C.P. 26(A)(1)(A) DISCLOSURES
    • The document is a legal filing from Ghislaine Maxwell in the case of Virginia L. Giuffre v. Ghislaine Maxwell, filed in the United States District Court for the Southern District of New York. It contains Ghislaine Maxwell's third supplemental disclosures under Federal Rule of Civil Procedure 26(a)(1)(A). These disclosures list individuals who may have discoverable information relevant to the facts disputed in the pleadings, including Maxwell herself, Virginia Giuffre (the plaintiff), and numerous other individuals whose addresses and contact details are either provided or noted as unknown. The document also details various documents, data, and tangible things in Maxwell's possession that may be used in her defense or to support her claims, and mentions her AIG Homeowners and Excess Liability insurance policies, which have been denied coverage in relation to this case. The document ends with a certificate of service, indicating its electronic distribution to various parties involved in the case.
    • Names mentioned:
      • Ghislaine Maxwell
      • Virginia L. Giuffre
      • Kathy Alexander
      • Miles Alexander
      • James Michael Austrich
      • Philip Barden
      • Jane Doe 2
      • David Boies
      • Laura Boothe
      • Evelyn Boulet
      • Rebecca Boylan
      • Joshua Bunner
      • Carolyn Casey
      • Paul G. Cassell
      • Sharon Churcher
      • Alexandra Cousteau
      • Alan Dershowitz
      • Dr. Mona Devanesan
      • Bradley J. Edwards
      • Amanda Ellison
      • Cimberly Espinosa
      • Jeffrey Epstein
      • Annie Farmer
      • Marie Farmer
      • Alexandra Fekkai
      • Crystal Figueroa
      • Anthony Figueroa
      • Louis Freeh
      • Eric Gany
      • Meg Garvin
      • Sheridan Gibson-Butte
      • Robert Giuffre
      • Ross Gow
      • Fred Graff
      • Philip Guderyon
      • Shannon Harrison
      • Victoria Hazel
      • Brittany Henderson
      • Brett Jaffe
      • Carol Roberts Kess
      • Dr. Karen Kutikoff
      • Peter Listerman
      • Tony Lyons
      • Bob Meister
      • Jamie A. Melanson
      • Lynn Miller
      • Marvin Minsky
      • David Mullen
      • Joe Pagano
      • Mary Paluga
      • J. Stanley Pottinger
      • Joseph Recarey
      • Michael Reiter
      • Jason Richards
      • Governor Bill Richardson
      • Sky Roberts
      • Scott Rothstein
      • Forest Sawyer
      • Doug Schoetlle
      • Cecilia Stein
      • Mark Tafoya
      • Brent Tindall
      • Kevin Thompson
      • Ed Tuttle
      • Emma Vaghan
      • Kimberly Vaughan-Edwards
      • Cresenda Valdes
      • Anthony Valladares
      • Maritza Vazquez
      • Vicky Ward
      • Jarred Weisfeld
      • Courtney Wild
      • Daniel Wilson
      • Prince Andrew
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
  41. 1320.pdf
    • Sigrid S. McCawley, regarding unsealing records.

Legend

  • Attorney
    • Representing any side.
  • Legal Professional
    • Judges, clerks, court reporters, videographers, etc - basically any 3rd party not associated with either side.
  • Associate
    • Participating in sex-trafficking activities.
  • Client
    • Took advantage of sex-trafficking victims.
  • Victim
  • Unknown