- 1424-1.pdf
- Defendant Ghislaine Maxwell's legal team responds to non-party Sharon Churcher's motion to quash a subpoena in the case of Virginia L. Giuffre v. Ghislaine Maxwell. Maxwell's team argues that Churcher, a journalist, is a material fact witness who was not acting in a journalistic capacity but as a friend and advisor to plaintiff Giuffre, helping her fabricate stories. They assert that Churcher's testimony and documents are critical to Maxwell's defense in the defamation case, as they will prove that the statements Giuffre made about public figures and world leaders, including allegations involving Prince Andrew and Alan Dershowitz, were lies. Maxwell's counsel contests Churcher's claim to journalistic privilege, stating that much of the information sought is not covered due to lack of confidentiality and contends that Churcher's evidence cannot be obtained from other sources, thus necessitating her compliance with the subpoena.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Sharon Churcher
- Laura A. Menninger
- Jeffrey S. Pagliuca
- Alan Dershowitz
- Prince Andrew
- Bradley J. Edwards
- Bill Clinton
- Claus von Bulow
- Sigrid S. McCawley
- Meredith L. Schultz
- Paul G. Cassell
- J. Stanley Pottinger
- Nicole Simmons
- 1424-2.pdf
- This series of emails between Virginia Giuffre and journalist Sharon Churcher reveals discussions about Giuffre's experience with Jeffrey Epstein and her plans to write a book detailing her story. Sharon Churcher provides advice on navigating potential publishing deals, working with ghostwriters, handling publicity, and communicating with literary agents. The correspondence shows Giuffre's progress from being under a contract that limited her disclosures to reaching the point where she can freely pursue publication and share her story with a wider audience.
- Names mentioned:
- Virginia L. Giuffre
- Sharon Churcher
- Jeffrey Epstein
- Jenna
- Ann Marie Villafaña
- Wende Bardfeld
- Emmy Taylor
- Sarah Kellen
- Jarred Weisfeld
- Irene Goodman
- Sandra White
- Bradley J. Edwards
- Jason
- Teala Davies
- Kathy
- Miles
- Johanna Sjoberg
- David Heymann
- Mel Berger
- Nick Pileggi
- Alfredo Rodriguez
- Prince Andrew
- Bill Clinton
- Kenneth Starr
- Alan Dershowitz
- Paulo Silva
- 1424-3.pdf
- Jane Doe #3 and Jane Doe #4 are seeking to join an existing legal action against the United States Government, alongside Jane Doe #1 and Jane Doe #2, under the claim that their rights under the Crime Victims' Rights Act (CVRA) were violated in connection with the sexual abuse they endured by Jeffrey Epstein. Their motion, supported by a detailed recount of the abuses and alleged government complicity, aims to address the lack of notification about a secret non-prosecution agreement (NPA) offered to Epstein that shielded him and his co-conspirators from federal charges. The document mentions multiple high-profile individuals, including politicians and royalty, whom Epstein allegedly coerced the victims into having sexual relations with, often for the purposes of blackmail. Attorneys argue that the addition of Jane Doe #3 and Jane Doe #4 would not prejudice the Government, as they are not intent on re-litigating resolved issues and share legal counsel with the original plaintiffs.
- 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
- Ann Marie Villafaña
- 1424-4.pdf
- Email correspondence primarily involving attorneys Sigrid McCawley, Laura Menninger, and Meredith Schultz. The emails, dated May 17, 2016, discuss the scheduling of depositions for the Virginia Giuffre v. Ghislaine Maxwell case. McCawley is preparing a deposition calendar but is facing delays due to awaiting confirmation from a witness's counsel and difficulties serving subpoenas to witnesses evading service. Menninger expresses frustration over not receiving a proposed schedule for depositions and warns about the possibility of seeking court intervention. Schultz attaches subpoena notices, and a proposed deposition schedule for May and June 2016 is included, listing several names and locations. The document emphasizes the difficulty in coordinating depositions, exceeding the deposition limit, and confirming attendance of witnesses at trial.
- Names mentioned:
- Sigrid S. McCawley
- Laura A. Menninger
- Meredith L. Schultz
- Jeffrey S. Pagliuca
- Bradley J. Edwards
- Paul G. Cassell
- Mr. Rizzo
- Johanna Sjoberg
- Dr. Lynn Miller
- Steven Olson
- Juan Alessi
- Sky Roberts
- Detective Joe Recarey
- James Michael Austrich
- Jean-Luc Brunel
- JoJo Fontanella
- Jeffrey Epstein
- Jared Weisfeld
- Sharon Churcher
- Nadia Marcinkova
- Sarah Kellen
- David Rodgers
- Rinaldo Rizzo
- Emmy Taylor
- Ross Gow
- 1424-5.pdf
-
The provided excerpt from Document 1325-5 filed on January 4, 2024, in the case involving plaintiff Virginia L. Giuffre against defendant Ghislaine Maxwell (Case No. 15-cv-07433-RWS), includes Virginia Giuffre's third revised disclosure pursuant to Federal Rule of Civil Procedure 26. The document lists witnesses who may have information relevant to the case, details on the alleged sexual trafficking conduct of Maxwell and Jeffrey Epstein, including interactions with underage minors, as well as a detailed itemization of relevant documents and exhibits, such as police reports, press releases, and flight logs. Additionally, the document outlines a computation of damages, including psychological harm, lost income, and punitive damages, the latter based on the egregious nature of Maxwell's conduct and her wealth, totaling over $50 million. The filing was made by Giuffre's legal representation from Boies, Schiller & Flexner LLP and other associated counsel, and a certificate of service confirms delivery to opposing counsel.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Juan Alessi
- Maria Alessi
- Kathy Alexander
- Miles Alexander
- Doug Band
- Gwendolyn Beck
- Sophie Biddle
- Sarah Bjorlin
- Jean-Luc Brunel
- Ron Burkle
- Carolyn Casey
- Alyson Chambers
- Bill Clinton
- Maximilia Cordero
- Valdson Cotrin
- Chauntae Davies
- Teala Davies
- Anouska DeGeorgiou
- Alan Dershowitz
- Ryan Dionne
- Eva Anderson Dubin
- Glen Dubin
- Prince Andrew Albert Christian Edward, Duke of York
- Records Custodian for Travel for Prince Andrew Albert Christian Edward, Duke of York
- Jeffrey Epstein
- Tatiana Espinoza
- Annie Farmer
- Maria Farmer
- Vicky Ward
- Fredrick Fekkai
- Tony Figueroa
- Luciano ``Dojo" Fontanilla
- Lynn Fontanilla
- Michael Friedman
- Rosalie Friedman
- Ross Gow
- Tiffany Kathryn Grant
- Amanda Grant
- Lesley Groff
- Claire I. Hazell
- Shelley Harrison
- Gina Ignatieva
- Brett Jaffe
- Sarah Kensington Vickers (formerly Sarah Kellen)
- Tatiana Kovylina
- Adam Perry Lang
- Michael Liffman
- Peter Listerman
- Cindy Lopez
- Melinda Lutz
- Cheri Lynch
- Nadia Marcinko (formerly Nadia Marcinkova)
- Bob Meister
- Todd Meister
- Brahakmana Mellawa
- Jayarukshi Mellawa
- Andrea Mitrovich
- Bill Peadon
- Francis Peadon
- Dara Preece
- Louella Rabuyo
- Joseph Recarey
- Chief Michael Reiter
- Governor Bill Richardson
- Rinaldo Rizzo
- Haley Robson
- David Rodgers
- Adriana Ross (formerly Adriana Mucinska)
- Johanna Sjoberg
- Kelly Spamm
- Cecilia Stein
- Emmy Taylor
- Evelyn Valenzuela
- Larry Visosky
- Leslie Wexner
- Courtney Wild
- Igor Zinoview
- All females identified in the police reports or identified through the United States Attorney's office
- All other then-minor girls
- All pilots, chauffeurs, chefs, and other employees of either Defendant Maxwell or Jeffrey Epstein
- All staff and employees at the Mar-a-Lago Club
- All other witnesses learned through discovery process
- Sigrid S. McCawley, Esq.
- Laura A. Menninger, Esq.
- Joe Titone, Esq.
- Marshall Dore Louis, Esq.
- Richard A. Simpson, Esq.
- Jack Goldberger, Esq.
- Robert Lewis, Esq.
- Bruce Reinhart, Esq.
-
- 1424-6.pdf
- This series of legal correspondence, dated between June 13 and June 16, 2016, involves attorneys Meredith L. Schultz and Laura Menninger addressing the service of subpoenas in the case of Giuffre v. Maxwell. Schultz expresses frustration at Menninger's non-compliance in providing proofs of service for subpoenas issued by Menninger's side, despite having made a reciprocal request to Schultz’s firm, which complied earlier. Schultz emphasizes the urgency to confirm witness attendance at upcoming depositions and notes the efforts made to serve particular witnesses, while refuting any obligation to provide certificates of service. She concludes by urging a response to set up a meet-and-confer regarding discovery issues. The document was filed under seal on January 4, 2024, as part of an ongoing court case.
- Names mentioned:
- Sandra Perkins
- Laura A. Menninger
- Meredith L. Schultz
- Sigrid S. McCawley
- Paul G. Cassell
- Bradley J. Edwards
- Rebecca Boylan
- Michael Austrich
- Tony Figueroa
- Deborah Knowlton
- Marcinkova (First name not provided)
- Kellen (First name not provided)
- 1424-7.pdf
- Plaintiff Virginia L. Giuffre, in her response in opposition to Defendant Ghislaine Maxwell's motion for Rule 37(b) & (c) sanctions, argues that she has complied with all discovery obligations concerning the production of medical provider information and records. Despite Maxwell's claims of Giuffre withholding information, Giuffre asserts that she provided names and records of medical providers to the extent possible, given the long time frame and multiple locations involved. She has signed all medical release forms requested by Maxwell, disclosed additional providers' information when recalled, and provided relevant medical records upon receipt from medical professionals. Her legal team contests any claims of deliberate withholding and suggests that the sanctions motion is an attempt to distract from the merit of Giuffre's claims that Maxwell facilitated the sexual abuse of young girls by Jeffrey Epstein. The response requests denial of the sanctions motion in its entirety.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Jeffrey Epstein
- Rinaldo Rizzo
- Johanna Sjoberg
- Joseph Recarey
- Tony Figueroa
- Judith Lightfoot
- Dr. Christopher Donahue
- Dr. Scott Robert Geiger
- Dr. Joseph Heaney
- Donna Oliver P.A.
- Dr. Michele Streeter
- Dr. Steven Olson
- Dr. Carol Hayek
- Dr. Karen Kutikoff
- Dr. John Harris
- Dr. Majaliyana
- Dr. Wah Wah
- Dr. Sellathuri
- Dr. Donahue
- Dr. Hayek
- Ms. Lightfoot
- Dr. Olson
- Dr. Kutikoff
- Wellington Imaging Associates
- Growing Together
- Bradley J. Edwards
- Paul G. Cassell
- Sigrid S. McCawley
- Meredith L. Schultz
- David Boies
- Laura A. Menninger
- Jeffrey S. Pagliuca
- 1424-8.pdf
- In this legal document from the United States District Court for the Southern District of New York, Sigrid S. McCawley, a Partner at Boies, Schiller & Flexner LLP, submits a declaration in response to a defendant's motion for sanctions under Rules 37(b) & (c) for failure to comply with a court order and with Rule 26(a). The document includes various sealed exhibits, such as deposition excerpts and email correspondences, related to the case of Virginia L. Giuffre versus Ghislaine Maxwell (Case No.: 15-cv-07433-RWS). The declaration is part of the electronic filings in the court case, and Sigrid McCawley personally certifies the electronic service of the document to the involved parties.
- Names mentioned:
- Sigrid S. McCawley
- Virginia L. Giuffre
- Ghislaine Maxwell
- Rinaldo Rizzo
- Johanna Sjoberg
- Joseph Recarey
- Laura A. Menninger
- Judith Lightfoot
- Tony Figueroa
- Dr. Steven Olson
- Meredith L. Schultz
- David Boies
- Paul G. Cassell
- Ronald N. Boyce
- Bradley J. Edwards
- Jeffrey S. Pagliuca
- 1424-9.pdf
- This document is a transcript of a confidential deposition taken on May 18, 2016, as part of the United States District Court case between Virginia L. Giuffre, the plaintiff, and Ghislaine Maxwell, the defendant (Case No. 15-CV-07433-RWS). The deposition by Johanna Sjoberg discusses events at Jeffrey Epstein's home, including the presence of Prince Andrew and Virginia Giuffre. Sjoberg describes a scenario involving a puppet caricature of Prince Andrew, the taking of a questionable photograph, and her uncomfortable interactions with Maxwell and Epstein. She also mentions being asked by Maxwell to bring other girls for Epstein and recounts a conversation where Maxwell implied that having additional girls relieved her of certain responsibilities. The witness also details an episode involving a fitness trainer and reveals that she was encouraged to take explicit pictures for Epstein, which she did not end up doing.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Johanna Sjoberg
- Jeffrey Epstein
- Prince Andrew
- Kelli Ann Willis
- Laura A. Menninger
- Sigrid S. McCawley
- Emmy
- Nadia
- Jane Doe 2
- 1424-10.pdf
- The document is a sealed court transcript from a deposition taken during the Virginia L. Giuffre v. Ghislaine Maxwell case, under case number 15-CV-07433-RWS. The deposition involves "Jane Doe 2" recounting her experiences related to Jeffrey Epstein. She describes being brought to Epstein's house without any massage training and being involved in encounters that turned sexual without her consent, starting from when she was a minor. Jane Doe 2 recalls being asked by Epstein to bring other young girls to him, which she did, although she did not know what transpired between them and Epstein after she left them in his company. The testimonies deal with the nature of the gatherings, interactions with Epstein's assistants, and the context leading to sexual abuse, emphasizing the coercion and manipulation of young girls.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Kelli Ann Willis
- Jane Doe 2
- Bradley J. Edwards
- Jeffrey S. Pagliuca
- Hayley Robson
- Tony Figueroa
- Ashley Davis
- Felicia Esposito
- 1424-11.pdf
- The provided excerpt is from a legal deposition of Joseph Recarey, taken as part of the case "Virginia L. Giuffre v. Ghislaine Maxwell" before the United States District Court Southern District of New York. Recarey, during the deposition, details his investigation into allegations against Ghislaine Maxwell and Jeffrey Epstein which involved the recruitment of young girls, primarily under the age of 18, for the purpose of giving massages at Epstein's home that often resulted in sexual acts. He describes a system in which some victims were encouraged to bring friends to Epstein's house, who would then be paid both for massages and for bringing additional girls. Recarey's investigation finds that few of these girls had any legitimate massage experience and that the massages were understood to be a pretext for sexual exploitation. The document also references the eventual public awareness of Epstein's actions through media reports and the investigation's methodology consisting of interviewing victims to uncover a larger network of abused girls.
- Names mentioned:
- Joseph Recarey
- Virginia L. Giuffre
- Ghislaine Maxwell
- Jeffrey Epstein
- Kelli Ann Willis
- Gus Fronstin
- Jeffrey S. Pagliuca
- Bradley J. Edwards
- Sarah Kellen
- Haley Robson
- Molly
- Tony
- 1424-12.pdf
- The provided text appears to be a redacted version of a legal deposition transcript from a court case, Giuffre v. Maxwell, in which Dr. Steven W. Olson was deposed on May 26, 2016. Dr. Olson discusses his one-time medical consultation with Virginia L. Giuffre, noting he does not recall much about her aside from a single meeting a year prior to the deposition, where there was mention of Giuffre being involved in a sexual abuse case. The deposition includes details of Olson's inability to remember Giuffre's appearance or details apart from her case, and also covers the administrative aspects of the deposition, including document exhibits related to Olson's medical practice and Giuffre's medical records. The transcript indicates the deposition was conducted before a Notary Public and court reporter Kelly A. Mackereth in Denver, Colorado, and filed with the court under seal.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Steven W. Olson
- Paul G. Cassell
- Laura A. Menninger
- Kelly A. Mackereth
- Lynn Miller
- 1424-13.pdf
- The document is an email from Bernadette Martin of MBE Accounting to Meredith Schultz, dated June 27, 2016. It contains a message forwarded from Judith A Lightfoot, Consulting Psychologist, indicating that all records of a psychological nature related to Virginia Giuffre have been presented. The email underscores the confidentiality of the contents, provides contact details for Bernadette, and alerts the receiver that the information is privileged and intended only for the specified recipient, warning against unauthorized use or dissemination. The excerpt references a legal filing in case number 1:15-cv-07433-LAP, with the document number 1325-13, filed on January 4, 2024.
- Names mentioned:
- Bernadette Martin
- Meredith L. Schultz
- Virginia L. Giuffre
- Judith A Lightfoot
- 1424-14.pdf
- In this United States District Court document for the Southern District of New York, Plaintiff Virginia L. Giuffre opposes the Defendant Ghislaine Maxwell's motion for sanctions against her. The opposition argues that Giuffre has not willfully withheld information from the Defendant, stating that any omissions in her listing of medical care providers since 1999 were due to difficulty in recollection, given that she lived in multiple countries and states during this period. Her legal team has diligently attempted to provide a full listing and retrieved records whenever possible, providing newly recalled information promptly upon discovery. Additionally, it is highlighted that the Defendant's motion for sanctions attempts to distract from the main issue of the case, which is Maxwell's alleged involvement in the sexual abuse of young girls. The document includes an extensive factual background, legal arguments, and a rebuttal of the claimed discovery violations, ultimately requesting the motion for sanctions be denied in full.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Dr. Mona Devanesan
- Rinaldo Rizzo
- Johanna Sjoberg
- Tony Figueroa
- Joseph Recarey
- Dr. Donahue
- Dr. Hayek
- Dr. Kutikoff
- Wellington Imaging Associates
- Growing Together
- Ms. Lightfoot
- Dr. Olson
- Jeffrey Epstein
- Meredith L. Schultz
- Laura A. Menninger
- Jeffrey S. Pagliuca
- Sigrid S. McCawley
- David Boies
- Bradley J. Edwards
- Paul G. Cassell
- 1424-15.pdf
- This document is a legal reply by Ghislaine Maxwell's attorneys in support of their motion to reopen Virginia L. Giuffre's deposition for further examination, based on the late production of various documents by the plaintiff after her initial deposition. Maxwell's team argues that Giuffre's production of new documents—pertaining to her health care providers, emails, employment records, education records, and newly identified witnesses—necessitates additional questioning. They also contest the limitations to conduct a two-hour deposition via videoconference and request to have it done in person for a longer duration, indicating the complexity and volume of the documents involved. Maxwell’s legal team also rebuts Giuffre's counsel's instructions which prevented her from answering specific questions during the first deposition and seeks to address material edits made to her testimony through an errata sheet. They request the inclusion of these topics in the reopened deposition and ask the court to grant costs incurred for the motion due to the plaintiff's counsel's improper instructions not to answer relevant and non-privileged questions.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Laura A. Menninger
- Jeffrey S. Pagliuca
- Sharon Churcher
- Tony Figueroa
- Judith Lightfoot
- Sigrid S. McCawley
- Meredith L. Schultz
- Paul G. Cassell
- Bradley J. Edwards
- J. Stanley Pottinger
- Nicole Simmons
- 1424-16.pdf
- Laura A. Menninger, a licensed attorney and member of Haddon, Morgan & Foreman, P.C., submitted a declaration in support of a reply to Virginia L. Giuffre's opposition to reopening Giuffre's deposition in the case against Ghislaine Maxwell. In this declaration, filed with the United States District Court for the Southern District of New York, Menninger includes confidential medical records and deposition excerpts under seal as exhibits. The certificate of service indicates the electronic delivery of the declaration to various attorneys involved in the case, with the document's filing dated January 4, 2024, and the service certified as of July 8, 2016.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Laura A. Menninger
- Sigrid S. McCawley
- Meredith L. Schultz
- Paul G. Cassell
- Bradley J. Edwards
- J. Stanley Pottinger
- Nicole Simmons
- Anthony Figuera
- 1424-17.pdf
- In a video deposition, Tony Figueroa testifies about his educational background and his relationship with Virginia Giuffre. They both attended an alternative school, Survivors Charter School, to try and complete their high school education after having been out of school. Despite their efforts to get their GEDs and better jobs, they did not finish school. Figueroa confirms that they were at the alternative school together in the mornings with shorter hours than a regular school day, which is consistent with the school records of Ms. Giuffre, showing attendance from October 2001 until March 2002. He also recalls living with Ms. Giuffre around the time of the 9/11 attacks in 2001.
- Names mentioned:
- Tony Figueroa
- Virginia L. Giuffre
- Ghislaine Maxwell
- Bradley J. Edwards
- Laura A. Menninger
- Jenny Martin
- Leanne W. Fitzgerald
- Bradley J. Edwards
- 1424-18.pdf
- In a defamation lawsuit, Virginia L. Giuffre has accused Ghislaine Maxwell of publicly calling her a liar regarding Giuffre's allegations of sexual abuse. Maxwell's attorney argues for dismissal based on the complaint's insufficiency and the application of general denial and prelitigation privileges, while Giuffre's attorney contends the statements about Giuffre's dishonesty are actionable defamation, particularly harmful due to her work with sexual trafficking victims, and that the case should proceed to allow Giuffre an opportunity to prove her allegations in court. The court has reserved decision on the motion to dismiss.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Hon. Robert W. Sweet
- Sigrid S. McCawley
- Laura A. Menninger
- Jeffrey Epstein
- Prince Andrew
- Bill Clinton
- Judge Marra
- Alan Dershowitz
- Jane Doe 3
- Ms. Roberts (Virginia L. Giuffre)
- 1424-19.pdf
- Ghislaine Maxwell, through her attorneys, has submitted responses to plaintiff Virginia L. Giuffre's first set of interrogatories in a defamation case filed in the Southern District of New York. Maxwell's responses include numerous objections based on relevancy, attorney-client privilege, and other legal grounds, with Maxwell repeatedly stating that certain information requested is either irrelevant to the case, or she does not recall the information. In cases where Maxwell provides a direct answer, she often denies knowledge or recollection, such as not recalling authorized statements made on her behalf or any non-professional massages facilitated for Jeffrey Epstein. The document concludes with acknowledgments of electronic service to the involved parties' attorneys.
- Names mentioned:
- Virginia L. Giuffre
- Ghislaine Maxwell
- Laura A. Menninger
- Jeffrey S. Pagliuca
- Ross Gow
- Jeffrey Epstein
- Johanna Sjoberg
- Prince Andrew
- Bradley J. Edwards
- Jack Scarola
- Sharon Churcher
- Sigrid S. McCawley
- Meredith L. Schultz
- Paul G. Cassell
- J. Stanley Pottinger
- Nicole Simmons
- 1424.pdf
- On January 4, 2024, Sigrid S. McCawley, on behalf of the plaintiff in the case of Giuffre v. Maxwell, notified the Honorable Loretta A. Preska of the Southern District of New York that pursuant to the court's December 18, 2023 unsealing order, they are submitting a set of documents to be unsealed and filed on a rolling basis. The correspondence pointed out that certain documents related to unidentified individuals referenced as Does 105, 107, and 110 were excluded from the current filing due to ongoing court review, as noted in previous court communications and electronic case filings (ECF). The document was filed with the court and a copy was sent to the counsel of record through the court's electronic filing system (ECF).
