Will They Kill Themselves?

January 5th, 2024 Epstein Files

  • 1327-1.pdf
    • The provided text is an excerpt from a rough, uncertified, and unedited transcript of the deposition of Tony Figueroa in the case of Virginia L. Giuffre v. Ghislaine Maxwell related to the Jeffrey Epstein investigation. Throughout different pages of the transcript, Figueroa, who has been questioned under oath, discusses his role in bringing young girls—whom he describes as appearing to be in their late teens—to Epstein's residence upon Epstein's request and sometimes under the direction of Maxwell. He mentions driving the girls, who were not professional masseuses, to Epstein's house with the understanding that they were being brought there for massages, and he recounts seeing Maxwell occasionally at Epstein's house in the kitchen during these visits. Figueroa also details conversations where Epstein would ask him to find more girls and payments he received for bringing them to Epstein's home.
    • Names mentioned:
  • 1327-2.pdf
    • The document is from Boies, Schiller & Flexner LLP addressed to Laura A. Menninger, Esq. regarding a court-ordered electronic data search and production in the case Guiffre v. Maxwell. Dated June 30, 2016, it instructs Menninger to use specific software to capture emails from various accounts associated with Ms. Maxwell and to retrieve data from her electronic devices and cloud storage. The correspondence specifies the use of wildcard and pattern searches, negotiation on search terms, and includes an extensive list of terms to be used in the discovery process, covering various names, entities, and potentially relevant words, ensuring metadata is included in the search. The document emphasizes the need for thoroughness in the electronic discovery process, reflecting the detailed legal procedures followed in intricate litigation.
  • 1327-3.pdf
    • The released confidential document, marked as Exhibit 2, appears to be an organized list of contacts and service providers, potentially used for managing the estate and personal affairs of Mr. Jeffrey Epstein and associated individuals, possibly including Ms. Ghislaine Maxwell. It details vehicles owned, their maintenance records, as well as various vendors for utility services, groceries, health products, travel arrangements, and maintenance services like plumbing, landscaping, and pest control. Contact information for bank accounts, accountants, assistants, residential and computer maintenance personnel, and transportation services are also included. The document emphasizes the importance of routine upkeep by noting specific schedules for tasks such as pool maintenance, car servicing, and tree trimming. Information appears compiled for convenient reference possibly by household staff or managing personnel, with additional references to procedures for airport car drop-off and financial account reconciliation. The document was under seal and associated with a court case, signifying its sensitivity.
    • Names mentioned:
      • Jeffrey Epstein
      • Ghislaine Maxwell
      • Jane Doe 2
      • Shawn Adison
      • Roger Dean
      • Nestor
      • Leslie Groff
      • Cecelia Helan
      • Kim
      • Keith Blumberg
      • Mark Lumberg
      • Larry Visoski
      • Dave Rodgers
      • Larry Morrison
      • Jojo
      • Lynn
      • Brent Tindall
      • Amy
      • Lenny
      • Sam
      • Ken
      • Alan Stopek
      • Jerome Pierre
      • Francis Peadon
      • Pastora Peadon
      • Chad Banta
      • Peter Kapopoulos
      • Frank Jeanes
      • Joe Di Giovanni
      • Carlos
      • Sam
      • Keith Kelly
      • Francis
      • Eric Gany
      • Bella Klein
      • Keith Kelly
      • George Dan Tischen
  • 1327-4.pdf
    • The document is an exhibit from a case in the United States District Court, Southern District of New York, titled Virginia L. Giuffre v. Ghislaine Maxwell, with the case number 1:15-cv-07433-RWS. It contains Ghislaine Maxwell's initial disclosures under Federal Rules of Civil Procedure 26(a)(1)(A), listing individuals who may have relevant information about disputed facts alleged in the pleadings. The mentioned individuals include Ghislaine Maxwell and Virginia Giuffre themselves, among others such as Jeffrey Epstein and Ross Gow. Additionally, the whereabouts or contact information of several individuals is unknown. The document, presumed to be publicly filed, implies that these individuals may have knowledge about statements made to the press, court pleadings, or events between 1999 and 2002 that are relevant to the case. The disclosures were submitted by Maxwell's attorney, Laura A. Menninger, on February 24, 2016, and the service of this document to the opposing counsel is certified at the end.
    • Names mentioned:
  • 1327-5.pdf
    • The document appears to be a motion filed by Virginia L. Giuffre's legal team to compel Ghislaine Maxwell to fully answer deposition questions in a defamation case related to Jeffrey Epstein. The motion states that despite a court order requiring Maxwell to answer questions about her involvement in Epstein's alleged sex trafficking scheme, she repeatedly refused to provide answers during her deposition. The document includes examples of Maxwell's refusals to answer questions regarding the recruitment and sexual abuse of underage girls for Epstein, as well as requests for compensation for legal fees due to Maxwell's non-compliance.
    • Names mentioned:
  • 1327-6.pdf
    • Meredith L. Schultz, an attorney with Boies, Schiller & Flexner LLP, submitted a declaration in support of a motion to compel Defendant Ghislaine Maxwell to respond to deposition questions as part of a legal case being heard in the Southern District of New York. The declaration is regarding the case Virginia L. Giuffre v. Ghislaine Maxwell (Case No. 15-cv-07433-RWS) and includes Schultz's statement that various sealed exhibits, namely excerpts from depositions and a court order, are true and correct. These exhibits are provided to support the plaintiff's motion, and Schultz attests to their authenticity under penalty of perjury. This document, including a certificate of service, was filed with the court on July 29, 2016, and served electronically to all parties on record.
    • Names mentioned:
  • 1327-7.pdf
    • The document is a deposition of Johanna Sjoberg relating to the case of Virginia L. Giuffre v. Ghislaine Maxwell, held under the confidentiality order in Fort Lauderdale, Florida. Sjoberg testifies about her observations and experiences while working for Jeffrey Epstein and Ghislaine Maxwell from 2001 to 2006, including Epstein receiving three massages a day, expectations around sexual acts, particularly with Epstein, and explicit discussions about sexual encounters. The text of the deposition includes objections from an attorney identified as Ms. Menninger and ends with an affidavit and a certification with placeholders for the deponent's name and notary public's details.
    • Names mentioned:
  • 1327-8.pdf
    • During a videotaped deposition on June 24, 2016, Tony Figueroa testified in the District Court for the Southern District of New York with respect to Virginia Giuffre's lawsuit against Ghislaine Maxwell. Figueroa recounted that Giuffre, along with Maxwell and Jeffrey Epstein, would pick up young-looking girls, mostly teenagers, from clubs and bring them back for Epstein. Figueroa also mentioned his own role in driving these girls to Epstein's residence, believing that the girls were sought after for their youth and appearance rather than professional massage skills. He recalled that after Giuffre left for Thailand, his involvement with Epstein diminished, stating that Epstein would occasionally request that he bring someone over but his involvement effectively ended when Giuffre did not return. Throughout Figueroa's involvement, he was paid $200 for each girl he brought to Epstein. The deposition was documented under a certificate of oath by a notary public, with the court proceedings filed on January 5, 2024.
    • Names mentioned:
  • 1327-9.pdf
    • The document is a court order from the Southern District of New York in the case of Virginia L. Giuffre v. Ghislaine Maxwell, outlining the rulings on several discovery motions, including granting in part and denying in part Plaintiff Giuffre's motion for forensic examination of Maxwell's electronic devices, denying Maxwell's motion to compel disclosure of ongoing criminal investigations, and granting Giuffre's motion to compel Maxwell to answer deposition questions about her knowledge of Jeffrey Epstein-related sexual activities. Other motions regarding the number of depositions, subpoenas, and privilege claims were also addressed, with some being granted and others denied, while the court emphasizes compliance with its procedural rules and filing protocols, with a reminder that frivolous motions could lead to sanctions.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • Sweet, D.J.
      • Nadia Marcinkova
      • Sarah Kellen
      • Jeffrey Epstein
      • Alessi
      • Rodgers
      • Rizzo
      • Gow
      • Recarey
      • Brunel
      • Alessi
      • Reiter
      • Clinton
      • Edwards
      • Cassell
      • Alan Dershowitz
      • Ross Gow
      • Bradley Edwards
      • Stan Pottinger
      • Book Dog Books, LLC
      • Freydl
      • Meringolo
      • Sanchez
      • Coates
      • Akerman
      • Senterfitt
      • Eidson
      • Chin
      • Rogoff
      • Jane Doe 2
  • 1327-10.pdf
    • This PDF document is a transcript of a sealed deposition taken on July 22, 2016, involving Ghislaine Maxwell in the Southern District of New York. The case number is 1:15-cv-07433-LAP and the document was filed on January 5, 2024. Throughout the deposition, Maxwell's attorney, Pagliuca, frequently objects to questions about sexual activities and contacts and instructs Maxwell not to answer certain inquiries, citing the judge's order. The questions primarily focus on her involvement and knowledge of Jeffrey Epstein's activities, including whether she participated in or was aware of sexual activities, the existence of lists of females providing massages, and references to individuals connected to the case. Maxwell denies involvement or knowledge in several instances and the deposition includes interactions over what testimony is permissible under the court's order.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Leslie Fagin
      • Pagliuca (Mr. Pagliuca, attorney for Ghislaine Maxwell)
      • Boies (Mr. Boies, attorney for Virginia Giuffre)
      • Jeffrey Epstein
      • Johanna
      • Maria Farmer
      • Les Wexner
      • Tony Figueroa
      • Carolyn Andriano
      • Nicole
      • Colleen
      • Crystal
      • Judge Sweet
  • 1327-11.pdf
    • The content provided appears to be a series of message logs from various documents related to a court case (Case 1:15-cv-07433-LAP). These messages include fragmented notes indicating communication attempts such as calls to be returned, meetings, and special attention requests, often accompanied by dates, times, and indications of urgent or important matters. The recurrence of the term "Jane Doe 2" suggests these documents pertain to or involve an unidentified individual referred to by this pseudonym within the context of the case. The texts include annotations and reference codes that might relate to the evidence or exhibits in legal proceedings.
    • Names mentioned:
      • Jane Doe 2
      • GIUFFRE
      • SV
      • Maxwell
  • 1327-12.pdf
    • In a submission to the United States District Court Southern District of New York, defendant Ghislaine Maxwell's legal team reports compliance with a court order concerning the forensic examination of her electronic devices. After running proposed search terms provided by plaintiff Virginia L. Giuffre’s counsel, no additional responsive or non-privileged documents were found. Maxwell’s counsel carried out extensive searches on various devices and accounts, both previously and in accordance with the court order, confirming the completeness of the initial February 2016 document search. They are requesting the striking of a motion for an adverse inference instruction against Maxwell, and for costs incurred during the forensic examination to be awarded to her.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Jeffrey Epstein
      • Prince Andrew
      • Ross Gow
      • Alan Dershowitz
      • Emmy Taylor
      • Sarah Kellen
      • Glenn Dubin
      • Eva Dubin
      • Jean-Luc Brunel
      • Nadia Marcinkova
      • Bill Clinton
      • Hillary Clinton
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • Philip Barden
      • Vicky Ward
      • Johana Sjoberg
      • Karen Kutikoff
      • Jarred Weisfeld
      • Lynn Miller
      • Joseph Recarey
      • Scott Rothstein
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Paul G. Cassell
      • Bradley J. Edwards
      • J. Stanley Pottinger
      • Nicole Simmons
  • 1327-13.pdf
    • The document is a letter dated June 30, 2016, from Meredith L. Schultz, Esq. of Boies Schiller & Flexner LLP addressed to Laura A. Menninger, Esq. regarding the case Guiffre v. Maxwell. Schultz instructs Menninger to use specific e-discovery software tools to capture and search through all sent and received emails and electronic documents from various email accounts and devices associated with Ms. Maxwell, including personal and work computers, tablets, phones, and cloud storage. The letter outlines detailed instructions on how to conduct the search using wildcard characters and specifies that metadata should be included in the search. A comprehensive list of search terms to be used in the search and production is provided, addressing the syntax for proximity searches, initials, and non-case sensitive terms, intended to find relevant information for the case.
  • 1327-14.pdf
    • Laura Menninger, an attorney for Ghislaine Maxwell, outlines her objections to the overbreadth and non-specificity of the 368 proposed search terms for the review of Maxwell’s electronic devices in a legal conferral. Menninger disputes the inclusion of irrelevant and non-responsive items such as broad and common words, names of unrelated individuals, and terms that could infringe on attorney-client privilege. She stipulates her willingness to negotiate relevant terms for the search and expresses readiness to finalize these terms to meet deadlines for an upcoming deposition, while intentionally not addressing other unrelated demands from a prior correspondence.
  • 1327-15.pdf
    • Laura Menninger, an attorney from Haddon, Morgan and Foreman, P.C., has communicated with Meredith Schultz in a series of emails, objecting to the scope of search terms proposed for the electronic discovery process in a legal case against their client. Referring to the Court's Order, Menninger disputes claims of her team choosing "secret search terms" and clarifies that they have only excluded certain terms from Schultz's proposed list that were not tied to any discovery request or were overly broad, potentially yielding irrelevant or non-responsive documents. She has extended an offer to discuss the excluded terms via a telephone conference and requested that any issues with their approach to the search terms should be communicated before a specified deadline, in anticipation of their client's upcoming deposition.
  • 1327-16.pdf
    • This document contains a series of email communications from Laura Menninger, an attorney at Haddon, Morgan and Foreman, P.C., to Meredith Schultz concerning the negotiation of search terms related to electronic discovery in a legal case. Menninger details objections to the proposed search terms for being overbroad or not related to any specific Request for Production (RFP), discussing terms such as witness names, common words, and other words which potentially yield a high volume of non-responsive documents. She emphasizes a need to refine the search to match terms more closely to the case, arguing against terms that could pull up privileged communications or irrelevant documents. Menninger requests a conferral with Schultz to agree on the search terms to expedite the e-discovery process and warns of potential overbreadth issues if too many search terms are used. The emails also include confidentiality notices warning against unauthorized use or distribution of the information contained within.
  • 1327-17.pdf
    • This document contains a series of email communications from Laura Menninger, an attorney at Haddon, Morgan and Foreman, P.C., to Meredith Schultz concerning the negotiation of search terms related to electronic discovery in a legal case. Menninger details objections to the proposed search terms for being overbroad or not related to any specific Request for Production (RFP), discussing terms such as witness names, common words, and other words which potentially yield a high volume of non-responsive documents. She emphasizes a need to refine the search to match terms more closely to the case, arguing against terms that could pull up privileged communications or irrelevant documents. Menninger requests a conferral with Schultz to agree on the search terms to expedite the e-discovery process and warns of potential overbreadth issues if too many search terms are used. The emails also include confidentiality notices warning against unauthorized use or distribution of the information contained within.
  • 1327-18.pdf
    • This document, identified as EXHIBIT F in Case 1:15-cv-07433-LAP, lists the search terms that the defendant has already searched from the plaintiff's proposed lists dated June 30th and July 20th. The search terms mainly include various names (both complete and partial), keywords related to potential criminal activities and investigations (such as "assault," "federal w/3 bur," "prosecut*"), and terms that could be associated with sex crimes or related evidence (like "massage*," "sex w/3 toy*"). Notably, references to "Jane Doe 2" suggest that these searches are part of an ongoing, possibly complex, legal matter involving multiple parties or complainants.
  • 1327-19.pdf
    • In this document, Virginia L. Giuffre's legal team is supplementing her motion for an adverse inference instruction against Ghislaine Maxwell, based on Maxwell's alleged failure to comply with her discovery obligations in the ongoing case. Giuffre's counsel argues that Maxwell has failed to produce a single document out of over 10,000 claimed to have been reviewed, despite the court's order to run specific search terms and produce relevant documents. The plaintiff asserts that this non-compliance not only violates the court's direct orders but also poses significant prejudice to Giuffre's case. They request that the court grant an adverse inference jury instruction, allow for a forensic review of Maxwell's computer, and direct Maxwell to recover any remaining data from her unsearched email accounts.
    • Names mentioned:
  • 1327-20.pdf
    • In the United States District Court Southern District of New York, Sigrid S. McCawley, a partner at Boies Schiller & Flexner LLP, provided a declaration in support of a supplemental motion regarding the case Virginia L. Giuffre v. Ghislaine Maxwell, Case No.: 15-cv-07433-RWS. Dated August 8, 2016, the declaration states that attachments include a range of sealed exhibits featuring deposition excerpts from Ghislaine Maxwell, Rinaldo Rizzo, Detective Joseph Recarey, Johanna Sjoberg, Juan Alessi, and the sworn testimony of Janusz Banasiak, as well as a Rule 45 Subpoena to Microsoft. McCawley's declaration affirms that all provided documents are true and correct, thus contributing evidence to the motion for an adverse inference instruction based on new information, and the documents were filed and served to all relevant parties electronically.
    • Names mentioned:
  • 1327-21.pdf
    • This document is a partial transcript from a sworn deposition of Ghislaine Maxwell taken on April 22, 2016, as part of the case Virginia L. Giuffre vs. Ghislaine Maxwell (Case No. 15-cv-07433-RWS). In the deposition, Maxwell answers questions regarding her relationship with individuals such as Sarah Kellen and Glenn Dubin, her not-for-profit ocean foundation, and her interactions with Jeffrey Epstein and an unnamed employee. There are also discussions about Maxwell's authorized statements to the media through her lawyers and Ross Gow in response to allegations made by Virginia Giuffre, as well as references to criminal allegations possibly being leaked to the press. The document is concluded with a certification by Leslie Fagin, the Court Reporter and Notary Public who recorded the testimony.
    • Names mentioned:
  • 1327-22.pdf
    • In a confidential deposition taken by Plaintiff on June 21, 2016, Joseph Recarey discussed his interaction with individuals linked to Jeffrey Epstein. Recarey recounted how one of Epstein's alleged dates had purchased clothing from Victoria's Secret with Epstein's money and was subsequently asked by Epstein to try on and show the items, which made her uncomfortable. There's also a mention of an instance where Epstein disrupted a massage session, making inappropriate requests and performing an unwelcome chiropractic move. The deposition includes an objection from Mr. Pagliuca related to questioning about Alan Dershowitz, and it concludes with a statement that Recarey was duly sworn in before Notary Public Kelli Ann Willis in Miami-Dade County, Florida. The document is part of the court case Virginia L. Giuffre v. Ghislaine Maxwell, case number 1:15-cv-07433-LAP, filed under seal on January 5, 2024.
    • Names mentioned:
  • 1327-23.pdf
    • Confidential deposition document filed under seal from case number 15-CV-07433-RWS in the United States District Court for the Southern District of New York. Dated May 18, 2016, the deposition is that of Johanna Sjoberg, who participated in a legal proceeding related to the case of Virginia L. Giuffre vs. Ghislaine Maxwell. In the snippet shown, Sjoberg gives testimony about her observations of a person she met, commenting on the individual's transformation and confidence over time, mentioning grooming aspects such as obtaining braces and improving posture through massages. There is also a reference to activities in the US Virgin Islands. The document ends with an official certificate of oath signed by Kelli Ann Willis, a notary public in the State of Florida.
    • Names mentioned:
  • 1327-24.pdf
    • During a confidential deposition on June 1, 2016, John Alessi provided testimony regarding his experiences working for Jeffrey Epstein. He described the use of a messaging system called MindSpring, which relayed messages from Epstein's office to the staff at the house. Alessi recounted how the system became a routine part of communication, to the extent that even simple requests like ordering a cup of coffee from Epstein would be sent through MindSpring by the office, and he would receive and act on such messages. The deposition took place in Fort Lauderdale, Florida, before Kelli Ann Willis, a professional reporter and notary public, and the document is part of a case filed in the United States District Court for the Southern District of New York.
    • Names mentioned:
  • 1327-25.pdf
    • A deposition of Janusz Banasiak took place on February 16, 2010, concerning the removal of computers from Jeffrey Epstein's property before a search warrant was executed. Banasiak, who lived full-time at Epstein's residence, testified that he was informed by Adriana—an associate of Epstein—about the arrival of an unknown man who assisted her in removing three computers from the house, about which Banasiak had no prior knowledge or reason given for their removal. Banasiak also discussed the use of Citrix within Epstein's organization for email communication but professed ignorance about the computers sharing other types of files. Additionally, various individuals were named as part of Epstein's organization, including Bella Klen, Richard Kahn, Leslie Groff, Ghislaine Maxwell, Nadia Marcinkova, Sarah Kellen, and Adriana Ross, some of whom were mentioned in connection with Epstein's legal issues.
    • Names mentioned:
  • 1327-26.pdf
    • A legal filing from Ghislaine Maxwell's defense counsel, addressed to the United States District Court Southern District of New York, arguing against the plaintiff Virginia L. Giuffre's motion to enforce a court order and to compel Maxwell to answer additional deposition questions. The defense asserts that Maxwell has already answered all pertinent questions during her deposition, which covered various topics including her relationship with Jeffrey Epstein, her knowledge of sexual trafficking, and other matters related to the defamation claim brought against her. The defense argues that any further questioning would be redundant, fall outside of the court's order, or would pertain to topics already addressed satisfactorily in previous depositions, amounting to an unnecessary "witch-hunt" into Maxwell's personal life. They request that the court deny Giuffre's motion and consider imposing fees and costs on the plaintiff for the unfounded motion.
    • Names mentioned:
  • 1327-27.pdf
    • This appears to be a transcript of a legal deposition involving a witness named Virginia Giuffre. Throughout the document, there are interactions between an attorney noted by the abbreviation "Q" for questions and a witness marked as "A" for answer. The dialogue includes discussions about the accuracy of certain statements related to dates and events, with the witness admitting to mistakes in previous statements due to lack of records and later obtained documentation which clarified the dates. There is also mention of Ghislaine Maxwell in the context of the case. The witness is instructed by their lawyer not to answer specific questions without the presence or review of certain documents, invoking objections to form. The deposition content indicates a complex case involving details that the witness has written about in the past, including their interactions with notable individuals and the media coverage surrounding their allegations.
    • Names mentioned:
  • 1327-28.pdf
    • Ghislaine Maxwell was deposed under subpoena regarding her involvement with Jeffrey Epstein and allegations brought forth by Virginia Giuffre. During the deposition, Maxwell denied participating in or being aware of any sexual activities involving minors or massages at Epstein's residences. She contested many of the claims made by Giuffre, calling them lies and expressing uncertainty or lack of recollection on various points, such as the presence of sex toys, the purpose of certain phone calls, and interactions with Prince Andrew. Her attorney frequently interjected with objections and instructions not to answer certain questions, citing privilege and relevance. Maxwell also discussed her role in hiring staff for Epstein's homes and the presence of a document alleged to be stolen from Epstein's residence.
    • Names mentioned:
  • 1327-29.pdf
    • During a confidential deposition taken on May 18, 2016, Johanna Sjoberg provided testimony about her experiences and observations while interacting with Jeffrey Epstein, Ghislaine Maxwell, and others associated within their circle. Sjoberg described engaging in massages with Epstein, sometimes involving Maxwell and others; the massages occasionally included sexual acts. She recounted instances where Epstein shared details of sexual encounters with other women and remembered being asked by Maxwell to recruit another girl for Epstein's services. Sjoberg also discussed her impressions of Maxwell and detailed her interactions with Virginia Giuffre, who was described as appearing orphan-like and revealed she was 17 during conversations. The deposition included Sjoberg's recollections of the environment in Epstein's properties, such as the presence of photographs of topless women but no child pornography, and the absence of observing any explicit sexual activities among guests or signs of trafficking. Sjoberg's testimony was part of a court case brought by Giuffre against Maxwell in the Southern District of New York.
    • Names mentioned:
      • Johanna Sjoberg
      • Jeffrey Epstein
      • Ghislaine Maxwell
      • Virginia L. Giuffre (also referred to as Virginia Roberts)
      • Kelli Ann Willis
      • Laura A. Menninger
      • Sigrid S. McCawley
      • AP
      • PK
      • Sarah Kellen
      • Marvin Minsky
      • George Lucas
      • Donald Trump
      • Alan Dershowitz
      • Glenn
      • Al Gore
      • Tipper Gore
      • Michael Jackson
      • Prince Andrew
      • Jane Doe 2
  • 1327.pdf
    • On January 5, 2024, Sigrid S. McCawley, representing the plaintiff in Giuffre v. Maxwell (Case No. 15-cv-7433-LAP), submitted a letter to District Court Judge Loretta A. Preska to confirm compliance with the court's December 18, 2023, unsealing order. In the communication, sent via the Electronic Court Filing (ECF) system and addressed to the United States District Court for the Southern District of New York, McCawley stated that document unsealing would be done progressively and noted the exclusion of documents related to Does 105, 107, and 110, pending the court's ongoing review. The letter also includes a record of communication with chambers and informs the counsel of record through the ECF.
  • 1328-1.pdf
    • Jeffrey S. Pagliuca, an attorney for Ghislaine Maxwell, submitted a declaration in support of Maxwell's opposition to Virginia L. Giuffre's motion to compel answers to deposition questions. The document, filed with the U.S. District Court for the Southern District of New York, includes several exhibits filed under seal, containing excerpts from depositions of Virginia Giuffre, Ghislaine Maxwell, and others, all designated as confidential under a protective order. The filing, dated August 8, 2016, also includes a certificate of service indicating electronic service of the declaration to the attorneys representing Giuffre.
    • Names mentioned:
  • 1328-2.pdf
    • Detective Joseph Recarey provided a deposition in the case of Virginia L. Giuffre vs. Ghislaine Maxwell, confirming that none of the 17 individuals listed as alleged victims in the Palm Beach Police Department incident report, related to the Jeffrey Epstein investigation, had claimed Ghislaine Maxwell was present, paid them, gave instructions on attire or behavior, or even interacted with them at Epstein's house. Recarey discussed the surveillance and evidence gathering methods used during the investigation, stating that no child pornography was observed in seized materials nor evidence implicating Maxwell directly in victim witness statements or video surveillance. The document reveals the thoroughness of questioning despite Maxwell not being a target in the grand jury investigation at the time.
    • Names mentioned:
      • Joseph Recarey
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Kelli Ann Willis
      • Jeffrey S. Pagliuca
      • Meredith L. Schultz
      • Detective Pagan
      • VI 17 Juno (possibly a code or reference, not a name)
      • AH
      • Jane Doe (used multiple times as placeholder for unnamed individuals)
      • FP
      • Johanna Sjoberg
      • Christina Venero
      • Jeffrey Epstein
      • Janush (possibly a typo or shorthand for an individual's name)
      • Ms. O'Connor
  • 1328-3.pdf
    • The provided text is a transcription of a video deposition of Tony Figueroa related to the lawsuit Virginia Giuffre vs. Ghislaine Maxwell. Figueroa recounts his experiences and observations regarding Giuffre, including details about her vehicles, his involvement in recruiting girls for Jeffrey Epstein by bringing them to his home under the guise of work, which Epstein would pay him for, his and Giuffre's drug use, and the lifestyle they led, which often included partying and using substances such as weed and Xanax. He also discusses a time when he got into legal trouble using Giuffre's truck after she left for Thailand, resulting in his arrest for grand theft.
    • Names mentioned:
  • 1328-4.pdf
    • This document is a motion filed by Defendant Ghislaine Maxwell's legal team in the United States District Court Southern District of New York compelling Plaintiff Virginia L. Giuffre to provide complete and responsive answers to Maxwell's second set of discovery requests, and to admit or deny certain requests for admissions in a defamation case. Maxwell argues that Giuffre's responses have been deficient, evasive, or protected by improper objections, and requests the court to overrule Giuffre's objections, for Giuffre to provide all requested information, and for the court to award attorney's fees and costs to Maxwell for having to bring the motion. The motion also notes that Giuffre has failed to sign her interrogatory responses, which is against the rules of civil procedure.
    • 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
      • J. Stanley Pottinger
      • Alan Dershowitz
      • Jeffrey Epstein
      • Bill Clinton
      • Al Gore
      • Nicole Simmons
  • 1328-5.pdf
    • Virginia L. Giuffre, the plaintiff, provided her responses and objections to the second set of discovery requests and interrogatories from defendant Ghislaine Maxwell in a case before the United States District Court Southern District of New York. Giuffre objected to the defendant's discovery requests on several grounds, including that they exceeded the limit of 25 interrogatories set by Rule 33, sought privileged information, were duplicative, overbroad, unduly burdensome, and not proportional to the needs of the case. Despite the objections, Giuffre provided answers and produced documents within the limits she deemed appropriate under the Federal Rules of Civil Procedure and the court's protective order, while reserving the right to modify or supplement her responses as needed.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Bill Clinton
      • Alan Dershowitz
      • Prince Andrew
      • Johanna Sjoberg
      • Marshall Dore Louis
      • Allyson Chambers
      • Ross Gow
      • Bradley Edwards
      • Paul G. Cassell
      • Jeffrey Epstein
      • Jane Doe #1
      • Jane Doe #2
      • Jane Doe #3
      • Jane Doe #4
      • Jane Doe No. 102
      • Dr. Olsen
      • Carol Hayek
      • Chris Donahue
      • John Harris
      • Majliyana
      • Wah Wah
      • Sellathuri
      • Judith Lightfoot
      • Mona Devanesan
      • Scott Robert Geiger
      • Joseph Heaney
      • Donna Oliver
      • Michele Streeter
      • Karen Kutikoff
      • Al Gore
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • David Boies
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
  • 1328-6.pdf
    • Alan M. Dershowitz, a prominent lawyer and Harvard Law professor, seeks to intervene in a defamation case between Virginia Giuffre and Ghislaine Maxwell to unseal certain judicial documents. He argues that these documents, which include emails and a manuscript, demonstrate his innocence in allegations of sexual misconduct made against him by Giuffre. Dershowitz claims that Giuffre concocted the allegations to help sell her book, and contends that her continued public accusation against him affects his reputation. He requests from the court either the unsealing of the documents based on First Amendment and common law rights or a modification of the protective order that currently restricts their disclosure.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Alan M. Dershowitz
      • Jeffrey Epstein
      • Laura A. Menninger
      • Louis Freeh
      • Bradley Edwards
      • Paul G. Cassell
      • Claus von Bulow
      • David Boies
      • Sharon Churcher
      • Kenneth Starr
      • Jarred Weisfeld
      • Sandra
      • Louis J. Freeh
      • Jarred Weisfeld
  • 1328-7.pdf
    • Virginia L. Giuffre's legal counsel filed a reply in support of her motion to enforce a court order compelling Ghislaine Maxwell to answer deposition questions related to her involvement with Jeffrey Epstein and knowledge of his sexual activities. Despite the court's clear order, Maxwell refused to respond to several questions during her first deposition regarding her recruitment and participation in Epstein's sexual activities, as well as her knowledge of other individuals involved, including underage girls. Giuffre's lawyers argue that Maxwell’s obstructionist tactics, feigned ignorance, and refusal to answer pertinent questions not only wasted time but also revealed her inability to provide exculpatory information, urging the court to direct Maxwell to comply with the order and answer all relevant questions.
    • Names mentioned:
  • 1328-8.pdf
    • Sigrid S. McCawley, an attorney with Boies, Schiller & Flexner LLP, submitted a declaration in support of Plaintiff Virginia L. Giuffre's motion to enforce a court order and compel Defendant Ghislaine Maxwell to answer deposition questions. McCawley, admitted pro hac vice to practice in this case, attached various sealed exhibits, including deposition excerpts and flight logs, to her filing. She certified the truth and accuracy of these documents under penalty of perjury and recorded the service of the documents on defense counsel on August 12, 2016. The motion was part of the ongoing case in the United States District Court for the Southern District of New York.
    • Names mentioned:
  • 1328-9.pdf
    • In this excerpt from a legal document in the case of Virginia L. Giuffre against Ghislaine Maxwell (Case 1:15-cv-07433-LAP), the United States District Court Southern District of New York addresses eight discovery motions presented before it. The court grants in part and denies in part the plaintiff's motion for forensic examination of electronically stored information (ESI), denies the defendant's motions to compel the plaintiff to disclose ongoing criminal investigations and to compel non-privileged documents, and grants the plaintiff's motion to compel the defendant to answer deposition questions. Additionally, it allows the plaintiff to serve deposition subpoenas by alternative means in part, denies the defendant's motion to compel attorney-client communications and work product, and grants the plaintiff's motions to exceed the presumptive ten deposition limit and to file an opposition brief in excess of the court's 25-page limit. The court orders parties to manage future filings in accordance with its Individual Rules of Practice and provides directions for submitting redacted versions of the court's opinion.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • Sweet, D.J. (Judge)
      • Jeffrey Epstein
      • Nadia Marcinkova
      • Sarah Kellen
      • Ross Gow
      • Bradley Edwards
      • Stan Pottinger
      • Mr. Alessi
      • Mr. Rodgers
      • Mr. Rizzo
      • Mr. Recarey
      • Mr. Brunel
      • Mrs. Alessi
      • Mr. Reiter
      • Former President Clinton (Bill Clinton)
      • Jane Doe 2
      • Edwards
      • Cassell
      • Alan Dershowitz
  • 1328-10.pdf
    • This document is a transcript from a deposition of Ghislaine Maxwell, taken on July 22, 2016, at the law offices of Boies, Schiller & Flexner, LLP, in New York City. It's part of a case filed in the United States District Court Southern District of New York by plaintiff Virginia L. Giuffre against defendant Ghislaine Maxwell (Case No. 15-cv-07433-RWS). The content includes exchanges about Maxwell's knowledge of sexual activities and massage practices at properties owned by Jeffrey Epstein and interactions with individuals whose names were listed and whether Maxwell recognized them. The deposition handles confidential topics, with the witness often instructed by attorney Mr. Pagliuca not to answer questions based on objections regarding relevance to the court's order or testimonies given at previous depositions.
    • Names mentioned:
  • 1328-11.pdf
    • The web page displays portions of a legal document related specifically to a deposition from the case of Virginia Giuffre versus Ghislaine Maxwell. The document includes the deposition of Tony Figueroa, which occurred on June 24, 2016, at the Southern Reporting Company facility in Palm Coast, Florida. Figueroa provides testimonies about Ghislaine Maxwell and Jeffrey Epstein's sexual activities, including their efforts to recruit other girls for Epstein. He details being asked by Maxwell to find girls, describes conversations with Giuffre about sexual encounters involving Maxwell, Epstein, and the use of sex toys, and mentions payments offered for bringing girls to Epstein. The document concludes with the court reporter's certification of deposition's accuracy.
    • Names mentioned:
  • 1328-12.pdf
    • In a deposition taken in the Southern District of New York as part of the case between Virginia L. Giuffre and Ghislaine Maxwell, witness Johanna Sjoberg recounted her experiences beginning in 2001, which included being approached by Maxwell at Palm Beach Atlantic College for employment with unusual requirements, leading to a series of events where she initially performed menial tasks and subsequently gave massages that escalated into sexual encounters involving Jeffrey Epstein and others, including an incident with a puppet of Prince Andrew. Sjoberg described the expectations set by Maxwell and Epstein, including the provision of sexualized massages and interactions with various young women, which occurred regularly and involved figures known to Maxwell and Epstein. Additionally, Sjoberg detailed conversations indicating Epstein and Maxwell's relationship dynamics, their manipulation strategies, and the psychological impact these events had on her life.
    • Names mentioned:
  • 1328-13.pdf
    • Louella Rabuyo, who was hired as a housekeeper for Jeffrey Epstein in November 2004, provided a deposition in a civil case against Epstein, detailing her employment conditions, her interactions with Ghislaine Maxwell and Epstein, as well as her awareness of the visitors to Epstein's residence. She recounted the process through which she was hired by Maxwell, her duties, salary, and the scheduling that varied depending on Epstein's presence at the house. Rabuyo also described the atmosphere and activities at Epstein’s house, referencing the unusual number of young female visitors, and her observations of Epstein and Maxwell's interactions over the years. Although she did not witness any illegal activities firsthand, she was aware of the police seizure of photos from Epstein's property and the allegations against him from news reports.
    • Names mentioned:
      • Louella Rabuyo
      • Jeffrey Epstein
      • Ghislaine Maxwell
      • Teresa Whalen
      • Sarah Kellen
      • Janusz
      • Douglas Schoettle
      • Mr. Critton
      • Bradley J. Edwards
      • Mr. Reinhart
  • 1328-14.pdf
    • The document is a confidential deposition transcript from a court case (Case No. 1:15-cv-07433-LAP), where plaintiff Virginia L. Giuffre is vs. defendant Ghislaine Maxwell. The testimony of David Rodgers, a pilot, taken at the offices of Boies Schiller & Flexner in Florida, is documented by court reporter Kelli Ann Willis. Rodgers discusses flight procedures and identification of passengers, including Ghislaine Maxwell, often referred to by her initials "GM," on flights spanning from 1995 through the early 2000s. Other topics include the possible lack of a standard code for Epstein's private landing strip and the planes used to land there, notably excluding the Gulfstream and Boeing but including a Cessna 421. The deposition also references court exhibits, questions about a specific plane, and pictures of the plane's interior.
    • Names mentioned:
  • 1328-15.pdf
    • The provided text is a partial transcript of a videotaped deposition involving Sarah Kellen, who repeatedly invokes her Fifth Amendment right when questioned about her association with Jeffrey Epstein, her knowledge of his properties and planes, her involvement in the modeling industry, and her interactions with underage girls. Despite various inquiries made by the questioning attorneys, Kellen does not provide substantial answers to the questions posed, consistently following her lawyer’s instruction to invoke the Fifth Amendment to avoid self-incrimination. The deposition is in relation to multiple cases against Epstein and includes references to figures such as Ghislaine Maxwell and Jean-Luc Brunel.
    • Names mentioned:
  • 1328-16.pdf
    • A transcript of a court deposition related to a case against Jeffrey Epstein and various associates, including Nadia Marcinkova. Throughout the deposition, Marcinkova frequently invokes the Fifth Amendment, declining to answer questions pertaining to accusations of Epstein's sexual abuse of underage girls, the involvement of accomplices like Ghislaine Maxwell, and the operation of trafficking schemes involving a modeling agency. The content includes objections to question form by attorneys and insinuations that Marcinkova had engaged in illegal activities. The deposition also touches on Epstein's interactions with notable figures, potential intimidation of witnesses, and Marcinkova's refusal to answer questions to avoid self-incrimination.
    • Names mentioned:
      • JANE DOE
      • Jeffrey Epstein
      • Nadia Marcinkova
      • MR. VAREMA
      • Sarah Kellen
      • Ghislaine Maxwell
      • Jean-Luc Brunel
      • Les Wexner
      • Alan Dershowitz
      • ADRIANA
      • MR. VISOSKI
      • Bradley J. Edwards
      • MS. EZELL
      • MR. GOLDBERGER
      • MR. HOROWITZ
      • MR. GOLDBERGER
      • THE COURT REPORTER
      • TERRI BECKER
      • JANE DOE 2
      • JANE DOE-102
      • A.O. (initials only, not a full name)
  • 1328-17.pdf
    • The provided text appears to be a transcribed excerpt from a legal deposition involving multiple plaintiffs represented by various attorneys against defendant Jeffrey Epstein. The witness, Alfredo Rodriguez, Epstein's former employee, discusses his knowledge of young girls being brought to Epstein's residence, the payments made to them, his interactions with Ghislaine Maxwell, and expresses his fear and concern for his safety due to the powerful status of those involved. The deposition concludes with discussions on logistics for resuming testimony at a later date and the official certification of the transcript by the court reporter.
    • Names mentioned:
      • JANE DOE NO. 6
      • JANE DOE NO. 7
      • Jeffrey Epstein
      • Alfredo Rodriguez
      • Stuart Mermelstein
      • Brad J. Edwards
      • Cara Holmes
      • Katherine W. Ezell
      • Adam J. Langino
      • RICHARD WILLITS
      • Robert Critton
      • Joe Langsam
      • JEAN-LUC
      • EVA
      • Sarah Kellen
      • C.M.A.
      • LESLEY
      • Michelle Payne
  • 1328-18.pdf
    • Virginia L. Giuffre's legal counsel submitted an opposition to Ghislaine Maxwell's request for the court to compel Giuffre to provide additional information and documents, as well as a motion for sanctions against Giuffre. They argue that Maxwell's motion should be denied due to lack of legal basis, noncompliance with Local Rule 37.1 for adequately specifying each discovery dispute, and overreach in the requested materials, some of which are already provided or are irrelevant to the case. The response details reasons for the opposition, including privilege concerns, potential for harassment, and undue burden. Additionally, Giuffre's attorneys argue against Maxwell's sanctions request, labeling it frivolous and without foundational support.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Bradley J. Edwards
      • Paul G. Cassell
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • Dr. Steven Olson
      • Dr. Chris Donohue
      • Dr. Peter Del Mar
      • St. Thomas More Hospital
      • Ms. Judith Lightfoot
      • Dr. Rauf Yousaf
      • CVS Pharmacy
      • Walgreens Pharmacy
      • Dr. John Harris
      • Dr. Darshanee Majaliyana
      • Dr. K. L. Lee
      • Dr. M. Sellathurai
      • Dr. Carol Hayek
      • Dr. Ahmed El Moghazi
      • Dr. Stephen Edmond
      • Campbelltown Hospital
      • Westmead Hospital
      • Royal Oaks Medical Center
      • Dr. Mona Devanesan
      • Dr. Karen Kutikoff
      • Wellington Imaging Associates
      • Dr. Ranjit Thind
      • Medicare Australia
      • Dr. Wah Wah San
      • Dr. Timothy D. Hartwig, D.O.
      • Dr. James T. Nichols, M.D.
      • Dr. Rodolfo Torres Jr., M.D.
      • Prince Andrew
      • Jeffrey Epstein
      • Alan Dershowitz
      • Bill Clinton
      • Sharon Churcher
      • Jarred Weissfeld
      • Ross Gow
      • David Boies
  • 1328-19.pdf
    • Attorney Alan Dershowitz vehemently denied allegations that he engaged in sex with an underage girl who was coerced into a sex ring by convicted sex offender Jeffrey Epstein. In a 14-page affidavit, Virginia Roberts claimed she was forced to have sex with Dershowitz and others while working as a "sex slave" for Epstein. Dershowitz refuted the claims by calling Roberts a "serial liar" and "prostitute," suggesting she was making false allegations for financial gain. Despite his long-standing friendship with Epstein, Dershowitz asserted he never witnessed any underage girls at Epstein's properties and stated he would willingly participate in a deposition only after Roberts and her attorneys—who have sued him for defamation—are deposed first.
    • Names mentioned:
      • Alan Dershowitz
      • Bob Norman
      • Virginia Roberts
      • Jeffrey Epstein
      • Prince Andrew
      • Ghislaine Maxwell
      • Robert Maxwell
      • Alfredo Rodriguez
  • 1328-20.pdf
    • This document is a legal response by Ghislaine Maxwell's defense team opposing Virginia L. Giuffre's motion for a protective order to keep police reports confidential and requesting the court to direct Maxwell to disclose all individuals she shared confidential information with. The defense argues that the police reports in question are not confidential as they are public records accessible by anyone and that Giuffre has waived any argument to confidentiality by not moving the court in time. They provide detailed accounts of past interactions Giuffre has had with law enforcement, highlighting inconsistencies in her current claims, and allege that her motives to hide this information are to protect a public image created by her accusations against Maxwell. The response concludes by requesting the court to deny Giuffre's motion, enforce the protective order, and award Maxwell attorneys' fees and costs associated with the response.
    • Names mentioned:
      • Ghislaine Maxwell
      • Virginia L. Giuffre
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • Meredith L. Schultz
      • Sigrid S. McCawley
      • Paul G. Cassell
      • Bradley J. Edwards
      • J. Stanley Pottinger
      • Nicole Simmons
      • Michael Austrich
      • Ron Eppinger
      • Jeffrey Epstein
      • Oren Yaniv
  • 1328-21.pdf
    • A police report from the Royal Palm Beach Police Department documents the response to a scene where a juvenile female was allegedly intoxicated and positioned beneath a male in what appeared to be a simulated sexual act. The situation was reported by Officer Mancino after observing the juveniles in a backyard; a group of other juveniles was present, and liquor was involved. Subsequent to the initial response, interviews were conducted with both the male and the female involved, as well as with witnesses. The male admitted to a consensual sexual relationship with the female prior to the incident. Due to the lack of conclusive evidence from the lab tests and the decision by the State Attorney's Office not to prosecute, the case was closed, and the associated property was eventually destroyed as the statute of limitations had expired.
    • Names mentioned:
      • Royal Palm Beach Police Department
      • Officer Mancino
      • Adella Oneal
      • Dominic Mancino, Jr.
      • Thomas Hughes
      • Robert Robkin
      • David Pervenecki
      • John Wikse
      • Jerry Robeson
      • Ellen F. Delai
      • Patricia Badu-Tweneboah
      • Ian Varvaro
      • Adam Nissensohn
      • Janice Magrane
      • Christopher S. Farron
      • Glenn A. Gerould
      • Erin M. Giannotti (Davis)
  • 1328-22.pdf
    • This document exhibits a case file from the Palm Beach County Sheriff’s Office detailing an investigation into a sexual battery case that occurred on February 28, 1998. The victim, a juvenile, identified one of the offenders as Joshua Bunner through a photo lineup, while another suspect, Kevin Thompson, was later interviewed and admitted to consensual sexual relations with the victim. Bunner was arrested, and while the case was initially cleared by an arrest, it was subsequently not filed due to the victim's credibility issues and a lack of likelihood of success at trial, as informed by a letter from Assistant State Attorney Teresa Bowman.
    • Names mentioned:
      • Joshua Bunner
      • Kevin P. Thompson
      • Teresa Bowman
      • Ric L. Bradshaw
      • David Bures
      • D. Bures
      • Arnold
      • Nicholas Silvage
      • Nicholas Bunner
      • Ramirez
      • Tony Figueroa
      • Rick Sacks
      • Michael Salnick
  • 1328-23.pdf
    • Virginia Giuffre is opposing Ghislaine Maxwell's motion for a protective order to withhold financial information in a defamation case in the Southern District of New York, arguing that the information is highly relevant for assessing punitive damages and demonstrating Maxwell's consciousness of guilt. Giuffre's legal team asserts that Maxwell's recent asset transfers suggest an attempt to evade jurisdiction and point towards guilt, while detailing the necessity of pre-trial financial discovery for punitive damages and emphasizing the defendant's potential bias and financial connections, such as those with the Clinton Foundation. They further argue against Maxwell's eventual summary judgment motion, noting the overwhelming evidence of her involvement in sex trafficking, and request broader financial discovery than a mere net worth statement due to Maxwell's complex financial dealings and suspected asset concealment.
    • Names mentioned:
  • 1328-24.pdf
    • A legal declaration by Sigrid McCawley, an attorney with Boies, Schiller & Flexner LLP, in support of the plaintiff's position against the defendant's motion for a protective order to keep financial information confidential, in the case of Virginia L. Giuffre v. Ghislaine Maxwell (Case No. 15-cv-07433-RWS) before the United States District Court Southern District of New York. Dated August 22, 2016, the declaration includes nine sealed exhibits consisting of deposition excerpts and correspondence material relevant to the case, and it concludes with a certificate of service documenting the electronic filing and service of the document to parties involved in the litigation.
    • Names mentioned:
      • Sigrid S. McCawley
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Johanna Sjoberg
      • Rinaldo Rizzo
      • Juan Alessi
      • Tony Figueroa
      • Joseph Recarey
      • David Rodgers
      • Ross Gow
      • Meredith L. Schultz
      • David Boies
      • Bradley J. Edwards
      • Paul G. Cassell
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
  • 1328-25.pdf
    • The document is a portion of a sealed deposition transcript from a court case where Johanna Sjoberg provided testimony about her interactions with Ghislaine Maxwell and Jeffrey Epstein. Sjoberg describes meeting Maxwell on her college campus, being hired initially for basic household tasks, and then being enticed to perform massages that escalated to sexual activities. She details how Maxwell and Epstein manipulated her with promises of money and gifts, such as a camera, contingent on her performing sexual acts. Maxwell is described as someone who participated in and facilitated Epstein's sexual encounters, looking for "model types" and trying to please Epstein by bringing in other girls. Sjoberg also recounts conversations with Epstein about sexual activities and the expectations that were put upon her. The document shows examples of leading questions and objections by counsel during the deposition.
    • Names mentioned:
  • 1328-26.pdf
    • This excerpt of the videotaped deposition of Tony Figueroa, taken on June 24, 2016, which is part of a legal case (15-cv-07433-RWS) between Virginia Giuffre as the plaintiff and Ghislaine Maxwell as the defendant, contains Figueroa's testimony regarding what he had learned about the relationship between Giuffre, Maxwell, and Jeffrey Epstein. He discusses the intimate activities Giuffre said she was involved in with Maxwell and Epstein and also describes how he and Giuffre were asked to help find other girls for Epstein. Objections during the deposition by Ms. Menninger suggest that there were concerns about the form and foundation of the questions being asked.
    • Names mentioned:
      • Tony Figueroa
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Jeffrey Epstein
      • Ms. Menninger (likely the attorney Laurie Menninger based on the context)
      • Mr. Edwards (likely the attorney Brad Edwards based on the context)
      • Leanne W. Fitzgerald
      • Prince (not a full name provided, but contextually possibly referring to Prince Andrew)
  • 1328-27.pdf
    • The document is a confidential email correspondence dated November 10, 2015, from Ross Gow to Ghislaine Maxwell and Philip Barden, forwarding an inquiry from New York Times reporter Barry Meier regarding Ghislaine Maxwell's response to a lawsuit filed by Virginia Roberts Giuffre related to the Jeffrey Epstein case. The message includes instructions for handling the confidential nature of the email, and legal disclaimers from the sender's firm, ACUITY Reputation Limited, and Devonshires Solicitors LLP, advising that the information is privileged and not to be disseminated or used by unintended recipients.
    • Names mentioned:
      • Ross Gow
      • Gmax
      • Philip Barden
      • Meier, Barry
      • Virginia Roberts Giuffre
      • Jeffrey Epstein
      • Jane Doe 2
  • 1328-28.pdf
    • This web page contains Exhibit 9, corresponding to a sealed court document in which Virginia L. Giuffre, the plaintiff, has filed a subpoena against Ghislaine Maxwell, the defendant, in the case number 15-cv-07433-LAP. The subpoena, issued by the United States District Court for the Southern District of New York, commands production of a wide range of documents, communications, and electronically stored information related to Jeffrey Epstein, Virginia Giuffre, and other specified terms, from entities associated with Maxwell, such as Ellmax, LLC and TerraMar Project, Inc. The subpoena asks for information dating from 1996 to the present and includes instructions and definitions to standardize the request across recipients.
    • Names mentioned:
  • 1328-29.pdf
    • This document is a declaration by Sigrid McCawley, a partner at Boies, Schiller & Flexner LLP, supporting the plaintiff Virginia L. Giuffre’s motion for a protective order and for the defendant, Ghislaine Maxwell, to disclose the individuals to whom she has disseminated confidential information in the case numbered 15-cv-07433-RWS. McCawley, licensed to practice in Florida and before the Southern District of New York court, attaches sealed exhibits, including deposition excerpts and flight logs, to her signed declaration. The document was submitted to the United States District Court for the Southern District of New York and electronically filed with a certificate of service on August 23, 2016, ensuring that it was served to all parties of record through the court’s electronic filing system.
    • Names mentioned:
      • Sigrid S. McCawley
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Tony Figueroa
      • Johanna Sjoberg
      • Rinaldo Rizzo
      • John Alessi
      • Lynn Miller
      • Joseph Recarey
      • David Rodgers
      • Meredith L. Schultz
      • David Boies
      • Bradley J. Edwards
      • Paul G. Cassell
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
  • 1328-30.pdf
    • The provided text appears to be various excerpts from court documents related to the case of Virginia L. Giuffre vs. Ghislaine Maxwell, with testimonies from several depositions describing interactions with Jeffrey Epstein, Ghislaine Maxwell, and minor girls. The documents contain accounts of alleged sexual misconduct, recruitment of young women for massages that allegedly turned sexual, and descriptions of employee duties and interactions within Epstein's properties. Specific individuals discuss their experiences and roles, while the questioning revolves around the nature of interactions with, and between, Epstein, Maxwell, and the young women involved.
    • Names mentioned:
  • 1328-31.pdf
    • Virginia L. Giuffre's legal team submits a reply in support of her motion to compel, providing arguments to counter previous claims by Ghislaine Maxwell's defense. The reply argues for the court-ordered production of documents Maxwell deemed both relevant and irrelevant, addresses the issue of privileged communication, discusses joint defense agreements and communications, insists on obtaining documents concerning Giuffre, highlights newly discovered defamatory statements, and supports the need for a forensic review of Maxwell's electronic communications. Giuffre's counsel contends that Maxwell's non-compliance and selective production of evidence warrant the court's intervention to ensure full disclosure of all relevant and non-privileged materials linked to the defamation claim.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • BOIES
      • SCHILLER & FLEXNER LLP
      • Jeffrey S. Pagliuca
      • Jeffrey Epstein
      • Alan Dershowitz
      • Ross Gow
      • Mary E. Borja
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • David Boies
      • Bradley J. Edwards
      • Paul G. Cassell
      • S.J. Quinney
      • Jane Doe 2
  • 1328-32.pdf
    • Sigrid McCawley, a partner at Boies, Schiller & Flexner LLP, filed a declaration in support of the plaintiff Virginia Giuffre's motion to compel in the case against Ghislaine Maxwell before the U.S. District Court, Southern District of New York. The document, identified as Case No.: 15-cv-07433-RWS, dated August 24, 2016, includes McCawley's declaration that the attached sealed exhibits are true and correct copies of various correspondences and depositions related to the case. McCawley confirms the accuracy of these documents under penalty of perjury and provides proof of electronic service to all parties on record. The certification of service includes the contact details of the law firm Haddon, Morgan & Foreman, P.C. and confirms the document was filed electronically using the CM/ECF system.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Sigrid S. McCawley
      • Ross Gow
      • Laura A. Menninger
      • John Alessi
      • Janusz Banasiak
      • Meredith L. Schultz
      • David Boies
      • Bradley J. Edwards
      • Paul G. Cassell
      • Jeffrey S. Pagliuca
  • 1328-33.pdf
    • The document is a confidential email exchange, with the key email dated November 10, 2015, from Ross Gow to Ghislaine Maxwell and Philip Barden, referencing an inquiry from Barry Meier, a reporter at The New York Times. Meier is seeking a response from Maxwell on an article he is working on regarding her involvement in the legal issues arising from the Jeffrey Epstein case, specifically mentioning a lawsuit filed against Maxwell by Virginia Roberts Giuffre. Confidentiality disclaimers from ACUITY Reputation and Devonshires Solicitors follow the correspondence, reiterating the sensitive nature of the information and outlining the privacy and legal protocols.
    • Names mentioned:
  • 1328-34.pdf
    • This excerpt from a legal document details a deposition of Janusz Banasiak regarding a case involving Jeffrey Epstein and Sarah Kellen, where Banasiak discusses the computer network and Citrix program used for exchanging emails within Epstein's organization. Banasiak confirms that, to his knowledge, the computers were not linked for sharing other files beyond email. He identifies various individuals as part of Epstein's organization, including accountants and employees such as Ghislaine Maxwell, Leslie Groff, and others, but he does not have information on their involvement in the crimes for which Epstein was investigated. The document also touches on the removal of computers from Epstein’s house before a search warrant could be executed, with Banasiak denying knowledge of who assisted in this action.
    • Names mentioned:
  • 1328-35.pdf
    • The document is a motion filed by Ghislaine Maxwell's legal team in the United States District Court Southern District of New York, requesting the court's permission to submit a Sur-Reply or, alternatively, to strike certain alleged misrepresentations of fact made by plaintiff Virginia L. Giuffre in her reply supporting a motion for protective order in case 15-cv-07433-RWS. Maxwell's attorneys argue that Giuffre's reply includes false statements about Maxwell's role in Jeffrey Epstein's activities and attempts to mislead the court about the nature of Maxwell's association with other individuals. The motion systematically refutes various claims made by Giuffre regarding Maxwell's conduct, emphasizing that many statements about Maxwell's involvement with Epstein and others are either misrepresented or outright false. The motion seeks redress for these inaccuracies with the intent to clarify the record.
    • Names mentioned:
      • Ghislaine Maxwell
      • Virginia L. Giuffre
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • Joseph Recarey
      • Jeffrey Epstein
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Paul G. Cassell
      • Bradley J. Edwards
      • J. Stanley Pottinger
      • Nicole Simmons
      • Ms. Sjoberg
      • Mr. Rizzo
      • Mr. Alessi
      • Mr. Figueroa
      • Ross Gow
      • Bradley J. Edwards
      • Christina Venero
  • 1328-36.pdf
    • This document is a declaration by attorney Laura A. Menninger from the law firm Haddon, Morgan & Foreman, P.C., in support of a motion filed on behalf of Ghislaine Maxwell, the defendant in a case presided by the United States District Court for the Southern District of New York. The declaration, dated August 25, 2016, is related to case number 15-cv-07433-RWS, where Virginia L. Giuffre is the plaintiff. Menninger's filing includes the defendant's request for the court to allow a Sur-Reply to counter alleged misrepresentations by the plaintiff or, alternatively, a motion to strike those alleged misrepresentations from the record. The declaration references several exhibits under seal, which are purported to be true and correct copies of deposition excerpts from various individuals associated with the case, all designated as confidential under a Protective Order. The document concludes with a certificate of service, indicating that Menninger's declaration and the associated motion have been electronically served to the counsel representing both parties.
    • Names mentioned:
  • 1328-37.pdf
    • Johanna Sjoberg provided a deposition in a case involving Virginia L. Giuffre and Ghislaine Maxwell, discussing how she first met Maxwell while attending Palm Beach Atlantic College in 2001. Sjoberg was approached by Maxwell about employment, which led to her working at Jeffrey Epstein's house initially answering phones and later being asked to massage Epstein for $100 an hour. Over time, her interactions with Epstein became more sexual, and she received additional payment for these encounters. Sjoberg continued this work until the police investigation into Epstein became public. She pointed out inaccuracies in a police report and clarified that her interactions with Epstein occurred when she was a consenting adult, though she had no direct knowledge of Epstein's actions with other individuals behind closed doors.
    • Names mentioned:
      • Johanna Sjoberg
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Kelli Ann Willis
      • Emmy Taylor
      • Jeffrey (presumably Jeffrey Epstein, though the last name is not explicitly stated in the provided text)
      • Recarey, Joseph
      • Sigrid S. McCawley
      • Laura (with the assumption that it’s Laura Menninger since she was referred to as MS. MENNINGER)
      • Jane Doe 2
      • The Lane Spa
  • 1328-38.pdf
    • The document is a transcript from the confidential deposition of John Alessi, taken on June 1, 2016, in the Southern District of New York, related to the case of Virginia L. Giuffre versus Ghislaine Maxwell (Case No. 15-CV-07433-RWS). Alessi testified about the massage therapists at 358 El Brillo Way, stating that they were paid $100 per hour, and to his knowledge, excepting one individual known as Jane Doe 2, all were adults over the age of 18. He also mentioned that many of the massage therapists had day jobs at local spas and clubs, like the Breakers or Mar-a-Lago, and were summoned from there for appointments at Mr. Epstein's property, which included private amenities like a pool and exercise equipment.
    • Names mentioned:
  • 1328-39.pdf
    • The PDF document appears to be a portion of the deposition transcript of Tony Figueroa related to the case Virginia Giuffre v. Ghislaine Maxwell (Case 1:15-cv-07433-RWS), filed with the U.S. District Court for the Southern District of New York. In this deposition taken on June 24, 2016, Figueroa discusses his knowledge and involvement in recruiting young women for Jeffrey Epstein and states that while he brought girls to Jeffrey, he did not witness any sexual activities, and he did not receive payment from Ghislaine Maxwell for these actions. He also mentions that Virginia Giuffre had substantial amounts of money at times and confirms that he did not observe any sexual acts between Giuffre and Maxwell or the recruited girls and Epstein.
    • Names mentioned:
  • 1328-40.pdf
    • This document appears to be an email correspondence between Virginia Giuffre (referred to as "Jenna" in the emails) and Marianne Strong related to a potential expose for the NYC Post about Jeffrey Epstein, whom Giuffre identifies as an "ill-esteemed billionaire and registered sex offender" and alleges she was sexually abused by as his personal and underage sex slave. Giuffre is cautious and strategic in her approach, eager for the truth to be told but also aware of the need for legal protection and potential profitability from the story. Strong, head of a literary agency, discusses the possibility of providing a journalistic piece to her contact Emily Smith for the renowned Page Six column as a favor, while highlighting the importance of gravitas and factual accuracy, and also noting the potential for a story if Giuffre wins her case. The emails outline the dynamics between journalistic practice, public relations, and the legal implications of sharing Giuffre's experiences with Epstein.
    • Names mentioned:
      • Virginia L. Giuffre
      • Marianne Strong
      • Emily Smith
      • Lord Colin Campbell
      • Duke of Argyll
      • Jeffrey Epstein
  • 1328-41.pdf
    • The document is a legal response opposing a motion to intervene by Alan Dershowitz, a non-party in the case of Virginia L. Giuffre v. Ghislaine Maxwell. The response argues that Dershowitz's request to modify a protective order and publicly release certain emails and a manuscript lacks legal merit. It states that the documents in question are not judicial documents, the presumption of access is weak, there is no First Amendment right of access in this context, and modifying the protective order would be unfair to the parties who relied on it. Additionally, it suggests Dershowitz seeks the information for an illegitimate purpose, namely to engage in a smear campaign against Giuffre, rather than to inform the public about the court's exercise of its powers.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Alan Dershowitz
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Jeffrey Epstein
      • Jack Scarola
      • Sarah Kellen
      • Nadia Marcinkova
      • Adrianna Mucinska
      • Juan Alessi
      • Alfredo Rodriguez
      • Professor Cassell
      • Ms. Edwards
      • Judge Lynch
      • Jeff Sloman
      • Ms. Churcher
      • Vicky Ward
      • Ray Gustini
      • Vivia Chen
      • Rania Khalek
      • Louis Freeh
      • Cassell
      • Prince Andrew
      • Duke of York
      • Recarey
  • 1328-42.pdf
    • The provided text appears to be a transcript of a videotaped deposition from a United States District Court case, specifically highlighting excerpts where a witness, identified as Juan Alessi, discusses his time working for Jeffrey Epstein. The witness describes interactions with Epstein's associates and guests, including celebrities and political figures, and details tasks he performed, such as setting up massage tables and cleaning up afterward, including dealing with sex toys. Notable figures mentioned include Prince Andrew, Sarah Ferguson, Alan Dershowitz, and Bill Clinton, illustrating the high-profile nature of Epstein's social circle. The witness also mentions Ghislaine Maxwell in the context of massages and describes finding sex toys in her closet.
    • Names mentioned:
      • Juan Alessi
      • Jeffrey Epstein
      • Robert J. Critton
      • Jane Doe No. 2
      • Sandra W. Townsend
      • Richard Willits
      • Stuart Mermelstein
      • William J. Berger
      • Katherine W. Ezell
      • Adam J. Langino
      • Lesley
      • Prince Andrew
      • Sarah Ferguson
      • Alan Dershowitz
      • Bill Clinton
      • Kevin Spacey
      • Diana (possibly referring to the secretary of Princess Diana)
      • Mr. Trump (Donald Trump)
      • Robert Kennedy Junior
      • Frederick Fekkai
      • V.R.
      • A. Rod (likely Alex Rodriguez reference as "Mr. Rodriguez")
      • Ms. Maxwell (likely Ghislaine Maxwell)
      • N. (Name abbreviated and undisclosed)
      • Princess Diana (indirectly referenced as "Diane's secretary")
      • David Copperfield
  • 1328-43.pdf
    • This court document excerpt, titled "COMPOSITE EXHIBIT 8" from case 1:15-cv-07433-LAP and filed on January 5, 2024, details the testimony of witnesses such as Alfredo Rodriguez in relation to multiple civil lawsuits against Jeffrey Epstein in the Southern District of Florida. The witnesses discuss the protocol for communication within Epstein’s staff, witness accounts of Epstein's behavior and visitors including notable figures like Prince Andrew and Alan Dershowitz, as well as descriptions of the interior of Epstein's residence and procedures like handling phone calls and e-mails within Epstein's organization.
    • Names mentioned:
      • Alfredo Rodriguez
      • Jeffrey Epstein
      • Lesley
      • Sarah
      • Mr. Critton
      • Bradley J. Edwards
      • C.
      • T.
      • Alan
      • Prince Andrew
      • Bill Clinton
      • Ghislaine Maxwell
      • David Copperfield
      • Ms. Ezell
      • Mr. Willits
      • Joe Langsam
      • Michelle Payne
      • Sarah Kellen
      • Nadia Marcenacova
      • Jane Doe No. 2
      • Jane Doe No. 3
      • Jane Doe No. 4
      • Jane Doe No. 5
      • Richard Willits, Esq.
      • Robert Critton, Esq.
  • 1328-44.pdf
    • The provided documents are excerpts from various deposition transcripts where witnesses, including Nadia Marcinkova and Sarah Kellen, are questioned about their knowledge and involvement with Jeffrey Epstein and his associates. The witnesses are asked about their interactions with notable individuals like Bill Clinton, Alan Dershowitz, Prince Andrew, and others in relation to Epstein's activities, but they frequently invoke their Fifth Amendment rights, refusing to answer many questions that pertain to Epstein's alleged sex trafficking and sexual abuse of minors. The documents also hint at Epstein's international connections and travels that are potentially linked to criminal activities involving underage girls.
    • Names mentioned:
      • Nadia Marcinkova
      • Sarah Kellen
      • Bill Clinton
      • Alan Dershowitz
      • Prince Andrew
      • Jeffrey Epstein
      • Dong Band
      • Jean-Luc Brunel
      • Glenn Dubin
      • Aline Weber
      • Jane Doe 102
      • Ghislaine Maxwell
      • El Zorro Ranch Corporation
      • New York Strategy Group
      • Financial Strategy Group
      • Emmy Taylor
      • Ivan Robles
      • Sandy Berger
      • Adam Perreylang
      • Claire Hazlett
      • JoJo and Lynn Fontanella
      • Zolia Braunek
      • Igor Zinoviev
      • Andrea Mitrovich
      • SH
  • 1328.pdf
    • On January 5, 2024, Sigrid S. McCawley, the attorney for the plaintiff in the case of Giuffre v. Maxwell, sent a notification to Judge Loretta A. Preska of the Southern District of New York, advising that in compliance with the court's December 18, 2023, order, documents related to the case are being unsealed and submitted to the court on a rolling basis. However, the filing excludes certain documents related to Does 105, 107, and 110, pending ongoing review by the court. This filing process and exclusions are communicated to the court and copies are sent to counsel of record via the Electronic Court Filing (ECF) system.
  • 1330-1.pdf
    • This document is a declaration by Paul G. Cassell, a licensed attorney and law professor, filed in opposition to a motion by Alan M. Dershowitz seeking permissive intervention and unsealing of judicial documents in a Florida Crime Victims’ Rights Act case. Cassell details his and co-counsel Bradley J. Edwards’ involvement in representing two underage victims who were sexually abused by Jeffrey Epstein, a case which involves Dershowitz due to allegations made by the plaintiff, Virginia Giuffre. The declaration includes background information on the case, the relevance of Dershowitz’s interactions and history with Epstein to the litigation, and Cassell’s accounts of the extensive efforts made to investigate and corroborate Giuffre’s allegations against Dershowitz, which ultimately led to a settled defamation case against Dershowitz without Cassell and Edwards concluding that Giuffre’s claims were mistaken.
    • Names mentioned:
      • Paul G. Cassell
      • Alan M. Dershowitz
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Bradley J. Edwards
      • Jeffrey Epstein
      • Nathanael J. Mitchell
      • Jack Scarola
      • Sarah Kellen
      • Adrianna Mucinska
      • Nadia Marcinkova
      • Juan Alessi
      • Alfredo Rodriguez
      • Bob Josefsberg
      • Ms. Ezell
      • Tatiana
      • Prince Andrew
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
  • 1330-2.pdf
    • This document is a legal filing by Virginia L. Giuffre, plaintiff, objecting to the first set of discovery requests made by Ghislaine Maxwell, defendant, in a defamation lawsuit before the United States District Court Southern District of New York. Giuffre argues that Maxwell's requests violate local and federal procedural rules, specifically citing overstepping interrogatory limits, seeking information not relevant to the case, requesting information in possession of the defendant, and attempting to obtain information protected by various privileges. The document details Giuffre's responses to individual interrogatories and requests for production, highlighting her objections based on relevancy, burden, and privilege, while noting her willingness to produce certain non-privileged documents.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Jeffrey Epstein
      • Shannon
      • Gary Friedrich
      • Marvel Enterprises, Inc.
      • Maria Villafano
      • Bradley Edwards
      • Paul G. Cassell
      • David Boies
      • Sigrid S. McCawley
      • Bob Josefsberg
      • Stan Pottinger
      • James Michael Austrich
      • Tony Figueroa
      • Robert Giuffre
      • Tony Figueroa
      • James Michael Austrich
      • Spencer Kuvin
      • Jack Scarola
      • Carol Roberts Kess
      • Philip Guderyon
      • Anthony Valladares
      • Anthony Figueroa
      • Ron Eppinger
      • Alan Dershowitz
      • Sky Roberts
      • Lynn Roberts
      • Kimberley Roberts
      • Spencer Kuvin
      • Jack Scarola
      • Andrew Albert Christian Edward (Prince Andrew)
      • Bill Clinton
      • Stephen Hawking
      • Al Gore
      • John Connolly
      • James Patterson
      • Laura A. Menninger
  • 1330-3.pdf
    • In a civil lawsuit filed in the Southern District of New York (Case No. 1:15-cv-07433), Virginia L. Giuffre, represented by Boies Schiller Flexner LLP, is suing Ghislaine Maxwell for damages related to Maxwell's alleged involvement in Jeffrey Epstein's sexual trafficking and abuse of minors. The document filed by Giuffre's legal team provides a Fourth Revised Disclosure pursuant to Federal Rule of Civil Procedure 26, detailing an extensive list of witnesses and relevant documents to support the case. This includes evidence of interactions with minors and transport records, as well as a computation of damages seeking compensation for medical expenses, pain and suffering, and punitive damages, citing Maxwell's defamatory statements and arguing for amounts that consider Maxwell's purported wealth. The document also lists measures to preserve victim confidentiality throughout the legal process.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Juan Alessi
      • Maria Alessi
      • Kathy Alexander
      • Miles Alexander
      • Doug Band
      • Gwendolyn Beck
      • Sophie Biddle
      • Fary Bjorlin
      • Kelly Bovino
      • 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
      • Jeffrey Epstein
      • Tatiana Espinoza
      • Annie Farmer
      • Marie Farmer
      • Vicky Ward
      • Fredrick Fekkai
      • Tony Figueroa
      • Luciano "Jojo" Fontanilla
      • Lynn Fontanilla
      • Michael Friedman
      • Rosalie Friedman
      • Ross Gow
      • Tiffany Kathryn Gramza
      • Amanda Grant
      • Lesley Groff
      • Claire Hazel
      • Shelly 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
      • Tom Pritzker
      • Dara Preece
      • Louella Rabuyo
      • Joseph Recarey
      • Chief Michael Reiter
      • Governor Bill Richardson
      • Rinaldo Rizzo
      • Haley Robson
      • Sky Roberts
      • David Rodgers
      • Adriana Ross (formerly Adriana Mucinska)
      • Johanna Sjoberg
      • Kelly Spamm
      • Cecilia Stein
      • Emmy Taylor
      • Evelyn Valenzuela
      • Larry Visosky
      • Leslie Wexner
      • Courtney Wild
      • Doug Wilson
      • Igor Zinoview
      • Sigrid S. McCawley
      • Laura A. Menninger
      • Joe Titone
      • Marshall Dore Louis
      • Richard A. Simpson
      • Jack Goldberger
      • Bradley J. Edwards
      • Bruce E. Reinhart
      • Bruce Reinhart
      • David Boies
      • Meredith L. Schultz
      • Paul G. Cassell
  • 1330-4.pdf
    • Alan M. Dershowitz submitted a declaration to the New York Southern District Court arguing for permission to intervene and unseal documents that he believes will exonerate him from allegations of sexual misconduct brought against him by Virginia Roberts Giuffre's legal team. Dershowitz contends that Giuffre’s accusations are false fabrications and that her attorneys, particularly Paul Cassell, have misrepresented evidence and failed to perform due diligence in verifying her claims. He asserts under oath that he never met Giuffre until 2016 and refutes Cassell's claim that evidence such as flight logs, police reports, and witness testimonies implicate him in any misconduct. Dershowitz requests the court to allow him to use specific documents to demonstrate that the allegations against him were recently constructed and to preserve his reputation against what he views as an ongoing legal assault.
    • Names mentioned:
      • Alan M. Dershowitz
      • Virginia Roberts Giuffre
      • Ghislaine Maxwell
      • Paul G. Cassell
      • Jeffrey Epstein
      • Bradley Edwards
      • Sharon Churcher
      • Tatiana Kovylina
      • Bob Josefsberg
      • David Gergen
      • Marvin Minsky
      • Larry Summers
      • Stephen Kosslyn
      • Henry Rosovsky
      • Howard Gardner
      • Stephen Jay Gould
      • Juan Alessi
      • Alfredo Rodriguez
      • Sarah Kellen
      • Adriana Mucinska
      • Nadia Marcinkova
      • Bill Clinton
      • Flavio Briatore
      • Courtney Love
      • Elie Wiesel
      • Donald Trump
      • Emmy Tayler
      • Al Gore
      • Tipper Gore
      • Louis Freeh
      • Tom Pritzker
      • Ehud Barak
      • Prince Andrew
      • Jack Scarola
      • Boies Schiller & Flexner LLP
  • 1330-5.pdf
    • The document from the web page is marked as Exhibit C, part of a legal case with the docket number 1:15-cv-07433-LAP, and contains an email chain labeled confidential, potentially involving attorney-client privileged information. Dated January 25, 2015, the email from Jeffrey E. to G Maxwell encourages Maxwell to maintain a confident public presence and mentions a conversation with Lisa Svenson, the Swedish ocean ambassador, who has dismissed the severity of certain allegations and suggested Maxwell would be welcome at ocean-related conferences. In a preceding email, G Maxwell expresses a desire for someone to publicly acknowledge their past romantic relationship. The document includes a disclaimer about the confidential nature of the communication and the legal consequences of unauthorized disclosure. It is associated with The Terramar Project, as evidenced by the references to social media accounts and initiatives related to the project.
    • Names mentioned:
      • Jeffrey E.
      • G Maxwell
      • Lisa Svenson
  • 1330-6.pdf
    • The extracted text is a Non-Prosecution Agreement between Jeffrey Epstein and the United States Attorney's Office, in which federal prosecution is deferred in favor of state prosecution for Epstein's alleged criminal activities involving solicitation of prostitution and engaging in sexual acts with minors. The agreement details conditions including Epstein's guilty plea to state charges, his registration as a sex offender, possible compensation to identified victims, and recognition that any violation of the agreement terms could lead to federal charges within specified deadlines. The agreement also stipulates that co-conspirators of Epstein will not be charged and that the grand jury investigation will be suspended upon the agreement's execution, with Epstein waiving his rights to a speedy trial and to be indicted by a grand jury.
    • Names mentioned:
      • Jeffrey Epstein
      • R. Alexander Acosta
      • A. Marie Villafana
      • Gerald Lefcourt
      • Lily Ann Sanchez
      • Sarah Kellen
      • Adriana Ross
      • Lesley Groff
      • Nadia Marcinkova
  • 1330-7.pdf
    • The provided web page text contains a portion of the deposition of Joseph Recarey, a witness in the Virginia L. Giuffre v. Ghislaine Maxwell case, Case No. 15-cv-07433-LAP, taken on June 21, 2016. In the deposition, Recarey, who was interviewed by Mr. Pagliuca and Ms. Schultz, discusses details from his investigation related to Jeffrey Epstein's conduct. Specifically, the questions focus on whether any of the alleged victims mentioned Ghislaine Maxwell's involvement or presence at Epstein's house, whether Maxwell was seen during surveillance, and if any of her property was seized. Recarey confirms that most victims did not mention Maxwell, and there is no documented evidence of Maxwell coming to or leaving Epstein's house during surveillance, nor was any property belonging to Maxwell seized.
    • Names mentioned:
  • 1330-8.pdf
    • Virginia L. Giuffre requests the reopening of Ghislaine Maxwell's deposition following the late production of key documents by Maxwell, which could impact the case. Giuffre's motion, filed with the United States District Court for the Southern District of New York, underscores the necessity to question Maxwell about new email communications with her press agent, Ross Gow, and her former boyfriend, convicted pedophile Jeffrey Epstein, disclosed after Maxwell's earlier depositions. Giuffre's counsel argues that this late disclosure of significant documents merits further deposition to ensure Maxwell answers previously evaded questions and to probe the newly revealed documents for a complete and just examination of the facts.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Ross Gow
      • Jeffrey Epstein
      • Laura A. Menninger
      • Philip Barden
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • David Boies
      • Bradley J. Edwards
      • Paul G. Cassell
      • Jeffrey S. Pagliuca
  • 1330-9.pdf
    • The web page contains a legal document from a case (Giuffre v. Maxwell, Case No. 15-cv-07433-LAP) and includes a letter from lawyer Laura A. Menninger acknowledging the delayed production of subpoenaed documents from Mar-a-Lago Club, Inc., as well as emails. These pertain to communications regarding media inquiries into Ghislaine Maxwell's role in the Jeffrey Epstein case. The emails involve discussions about responding to a New York Times inquiry about Virginia Roberts Guiffre's lawsuit against Maxwell and include a mention of a bizarre and disturbing request allegedly made by Epstein and Maxwell for Guiffre to bear a child for them. The content of these emails seems to be part of ongoing litigation and is marked as confidential.
    • Names mentioned:
      • Laura A. Menninger
      • Sigrid S. McCawley
      • Ghislaine Maxwell
      • Virginia Roberts Guiffee
      • Ross Gow
      • Philip Barden
      • Barry Meier
      • Jeffrey E.
  • 1330-10.pdf
    • The provided text appears to be a transcript from a confidential videotaped deposition of Ghislaine Maxwell taken on April 22, 2016, for the case Virginia L. Giuffre v. Ghislaine Maxwell (Case No. 15-cv-07433-RWS). Throughout the deposition, Maxwell is questioned regarding statements made about Virginia Roberts' (Virginia L. Giuffre's) accusations against Jeffrey Epstein. Maxwell evades directly answering whether she believes Giuffre's claims of sexual contact with Epstein while underage are lies, despite repeated questioning. Her responses indicate that her press agent, Ross Gow, issued a statement on her behalf, claiming Giuffre's accusations were "obvious lies", but she refers to legal advice received and deflects by emphasizing the lies told about herself rather than addressing the specific claims about Epstein. Her lawyer, identified as Mr. Pagliuca, frequently objects to the questions on the basis of "form and foundation."
    • Names mentioned:
  • 1330-11.pdf
    • Virginia L. Giuffre filed a motion in the United States District Court Southern District of New York to compel Ghislaine Maxwell to produce data from an undisclosed email account that Maxwell used from 2000 to 2002, which Giuffre asserts Maxwell utilized for communication related to the abuse of Giuffre. Additionally, Giuffre seeks an adverse inference jury instruction due to Maxwell's willful violation of the Court's orders to disclose and produce documents from the said email account. Despite evidence suggesting the inevitability of Maxwell’s email usage during the time of Giuffre's abuse, Maxwell has not responded to inquiries about the account and has only provided documents dating from July 2009, thus disobeying the Court's directive for full disclosure and production of relevant communication from all her email accounts dating back to 1999.
    • Names mentioned:
  • 1330-12.pdf
    • In a legal document filed with the Southern District of New York, Sigrid McCawley, a partner at Boies, Schiller & Flexner LLP, provides a declaration in support of the plaintiff, Virginia Giuffre's motion to compel data from defendant Ghislaine Maxwell’s undisclosed email account and requests an adverse inference instruction. McCawley, who is representing Giuffre and is licensed to practice in Florida and pro hac vice before this court, attaches sealed exhibits with excerpts from various depositions and certifies under penalty of perjury that her statement is true and correct. The document was filed on January 5, 2024, and indicates that it was electronically served to all parties involved on October 14, 2016, through the court's electronic filing system.
    • Names mentioned:
      • Sigrid S. McCawley
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Juan Alessi
      • Janusz Banasiak
      • Meredith L. Schultz
      • David Boies
      • Bradley J. Edwards
      • Paul G. Cassell
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
  • 1330-13.pdf
    • The document is a confidential deposition transcript related to the case of Virginia L. Giuffre vs. Ghislaine Maxwell from the United States District Court for the Southern District of New York. John Alessi, the deponent, describes a communication system used by Jeffrey Epstein's household and office called MindSpring, through which messages like requests for coffee or juice would be conveyed electronically, sent from the office and delivered to Alessi via printed fax. The system was set up towards the end of Alessi’s employment, and he found it an overcomplicated method for communication, contributing to his decision to leave that employment. A computer specialist named Mark Lumber from New York was mentioned as the individual who set up the system in Epstein's Palm Beach house.
    • Names mentioned:
  • 1330-14.pdf
    • The provided text appears to be a snippet from a legal deposition involving a case against Jeffrey Epstein and Sarah Kellen, held in Palm Beach County, Florida. The witness, presumably Janusz Banasiak, discusses the lack of connectivity between computers at Epstein's property and the usage of the Citrix system for email communication within Epstein's organization. Names mentioned include Bella Klein (accountant), Leslie Groff, and others. The document also touches on conversations around co-conspirators named in negotiations between Epstein and the U.S. Attorney's Office, with further mention of individuals considered part of Epstein's organization.
    • Names mentioned:
  • 1330-15.pdf
    • Virginia L. Giuffre filed a sealed agreement motion to compel Jeffrey Epstein to produce documents and testimony as part of a defamation action against Ghislaine Maxwell, who is alleged to have assisted Epstein in abusing Giuffre when she was a minor. This motion in the Southern District of Florida is related to another case filed in the Southern District of New York, where Giuffre accused Maxwell of defaming her by calling her a liar for asserting Maxwell's involvement with Epstein's criminal activities. The motion seeks to unseal the entire docket and requires Epstein to provide documents and testamentary evidence that he refused to produce by invoking the Fifth Amendment, which Giuffre argues is not a valid invocation in this context.
    • Names mentioned:
      • Virginia L. Giuffre
      • Jeffrey Epstein
      • Ghislaine Maxwell
      • Bradley J. Edwards
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • David Boies
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • Jack Alan Goldberger
      • Steven M. Larimore
      • Judge Kenneth A. Marra
      • Judge Robert W. Sweet
      • Alan Dershowitz
      • Bill Clinton
      • Ms. Maxwell
      • Rodriguez
      • Menchel
      • Lurie (possibly referring to AUSA Lurie)
      • RWS (initials likely referring to Judge Robert W. Sweet)
  • 1330-16.pdf
    • This document is the Defendant Ghislaine Maxwell's response to Plaintiff Virginia L. Giuffre's motion to compel the production of information from a supposed undisclosed email account of Maxwell's and for an adverse inference instruction to be given to the court. Maxwell's legal team, led by Laura A. Menninger, argues that Maxwell has complied fully with all court orders by forensically imaging and thoroughly searching all her electronic devices and email accounts, with no additional relevant documents found. They contest Giuffre's claims as speculative, baseless, and procedurally flawed due to her failure to meet and confer before filing the motion. Maxwell's counsel concludes by requesting denial of Giuffre's motion and the awarding of attorneys' fees and costs for responding to the motion.
    • 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
      • J. Stanley Pottinger
      • Nicole Simmons
  • 1330-17.pdf
    • Ghislaine Maxwell's legal team responds to a motion by plaintiff Virginia L. Giuffre to reopen Maxwell's deposition, arguing that the motion is both untimely and unnecessary. They maintain that the two documents Giuffre bases her request on are innocuous, have been discussed extensively in two prior depositions totaling 13 hours, and that Maxwell has already provided written responses on similar previous documents. Maxwell's lawyers assert that the plaintiff has had ample opportunity to explore these issues and that further deposition is both cumulative and duplicative. They also offer to have Maxwell respond in writing to specific questions about the new documents as a less burdensome alternative.
    • Names mentioned:
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Laura A. Menninger
      • Jeffrey S. Pagliuca
      • Ross Gow
      • Philip Barden
      • Jeffrey Epstein
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Paul G. Cassell
      • Bradley J. Edwards
      • J. Stanley Pottinger
      • Nicole Simmons
  • 1330-18.pdf
    • In this legal document from the United States District Court for the Southern District of New York, Laura A. Menninger, an attorney for Ghislaine Maxwell, submits a declaration opposing the plaintiff Virginia L. Giuffre's motion to reopen Maxwell's deposition. Menninger presents several exhibits, filed under seal, which include excerpts from Maxwell's previous deposition, communications between Maxwell and others, and medical releases from the plaintiff requesting healthcare information. The declaration, executed under penalty of perjury, also includes a certificate of service indicating that the document was electronically served to the involved parties on October 24, 2016.
    • Names mentioned:
      • Laura A. Menninger
      • Virginia L. Giuffre
      • Ghislaine Maxwell
      • Ross Gow
      • Jeffrey Epstein
      • Mr. Barden
      • Sigrid S. McCawley
      • Meredith L. Schultz
      • Paul G. Cassell
      • Bradley J. Edwards
      • J. Stanley Pottinger
      • Nicole Simmons
  • 1330-19.pdf
    • Ghislaine Maxwell was deposed as part of a civil case where Virginia L. Giuffre is the plaintiff. During the deposition, questions were raised about Maxwell's communications with Jeffrey Epstein regarding their interactions with other individuals and her potential dissemination of statements to the press. Maxwell frequently responded with uncertainty or denied recollection of specifics. She also stated that any statements issued to the press were done so based on legal advice and that she had minimal contact with Epstein during the relevant period. Objections to the questions were frequently raised by her attorney, Mr. Pagliuca, citing form, foundation, and attorney-client privilege. The deposition addressed various topics, including Maxwell's financial arrangements with Epstein and inquiries into whether they sought individuals to carry Epstein's child, all of which Maxwell denied or claimed to have no knowledge of.
    • Names mentioned:
  • 1330-20.pdf
    • A series of confidential emails, part of legal document 1330-20 from case 1:15-cv-07433-LAP, reveals communications primarily between Ross Gow and Ghislaine Maxwell, dated early January 2015, discussing media inquiries regarding new allegations against Maxwell by someone referred to as Jane Doe #3. Contained within these exchanges are discussions about media statements, dealing with fresh allegations by another woman (not Victoria), and consideration of litigation against papers that reported on the subject. The emails also mention contacts from various news organizations, including The Times, the BBC, and The Guardian, seeking comments on the fresh allegations detailed in a document dated December 30, 2104. Maxwell's correspondence includes a mention of reworking a letter and informing the media that the person in question is Virginia Roberts, not a new individual. The email chain also refers to The Terramar Project and contains standard confidentiality notices and a reminder to consider the environmental impact before printing emails.
    • Names mentioned:
      • Ross Gow
      • G Max (Ghislaine Maxwell)
      • David Brown
      • Jane Doe #3
      • Victoria (implied reference, full name not provided)
      • Philip (full name not provided)
      • Devonshires (referenced entity, not a person's name)
      • G Maxwell (Ghislaine Maxwell, different email handle)
      • Daneil Bates (possibly a typo for Daniel Bates)
      • Martin Robinson
      • Brian Basham
      • James Ball
      • James (referring to James Ball)
  • 1330-21.pdf
    • The released content from Exhibit C of a legal document filed on January 5, 2024, reveals email correspondence involving discussions on how to handle public statements and press narratives in the face of legal action and potential defamation related to Ghislaine Maxwell. The emails, dating back to January 2015, involve Maxwell and her associates expressing concerns about legal risks, strategizing on crafting statements to mitigate those risks, and reacting to media inquiries and actions by Virginia Roberts who filed a defamation suit against Maxwell, claiming Maxwell publicly called her a liar. Mentioned parties are apprehensive about participating in discovery processes and are attentive to maintaining a favorable public image while managing the closeness of their relationships with influential figures such as Prince Andrew and Professor Dershowitz.
    • Names mentioned:
      • Ghislaine Maxwell
      • Virginia Roberts
      • Philip Barden
      • Ross Gow
      • Professor Dershowitz (Professor Alan Dershowitz)
      • Prince Andrew
      • Jeffrey (potentially referring to Jeffrey Epstein)
      • David Brown
      • Stephen Brown
  • 1330-22.pdf
    • The web page content is a legal document, "EXHIBIT D," from a case identified as "1:15-cv-07433-LAP" containing email communications primarily between G Maxwell and others including someone named Jeffrey E., dated from January 11 to January 27, 2015. The emails discuss the handling of allegations against a person identified as JE (Jeffrey Epstein, implied by context) and G Maxwell's (presumably Ghislaine Maxwell) response to those accusations, including discussion of a plea deal, interactions with the media, and potential legal strategies. The discussions reflect concerns about reputational damage, legal risks, and the importance of public statements in response to the allegations. There's also an email suggesting G Maxwell should be more public and act without shame. The document is marked as confidential and notes that it contains privileged information.
    • Names mentioned:
      • G Maxwell
      • Jeffrey E.
      • Philip Barden
      • Ross Gow
      • Jon Swaine
      • Jeffrey Epstein
      • Virginia Roberts
      • Alan Dershowitz
      • Virginia
      • Geordie
      • Jeffrey Epstein
      • Rothstein
      • Haley Robson
      • Iisa Svenson
      • Edwards
  • 1330-23.pdf
    • In this legal document, Virginia L. Giuffre, the plaintiff, requests the court to reopen the deposition of the defendant, Ghislaine Maxwell, to question her about new key documents that were produced late. These documents include communications between Maxwell and her press agent, Ross Gow, as well as with her long-time boyfriend, Jeffrey Epstein, concerning potential media statements about Giuffre. Maxwell had previously provided evasive responses or refused to answer questions in her earlier depositions. Giuffre argues that the late production of these documents, which are highly relevant to her defamation claims, justifies the need for an additional deposition opportunity. The court had previously compelled Maxwell to provide clearer answers, and Giuffre's legal team is highlighting the critical nature of questioning Maxwell regarding these recently produced emails. They emphasize that these communications with key individuals are central evidence in the case and the motion is filed on time despite Maxwell's team suggesting otherwise.
    • Names mentioned:
  • 1330.pdf
    • On January 5, 2024, Sigrid S. McCawley, in compliance with a court order dated December 18, 2023, submitted a set of documents to be unsealed to Judge Loretta A. Preska of the Southern District of New York regarding the Giuffre v. Maxwell case (No. 15-cv-7433-LAP). The documents were to be filed on a rolling basis and the current submission excluded information pertaining to Does 105, 107, and 110, which were still under the court's review. This information was detailed in a letter addressed to Judge Preska with copies sent to the counsel of record via ECF (Electronic Case Filing).

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