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Flight Logs (11,800 documents)
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 267 of 465
Page 266
G Maxwell - Confidential
can see the dates.
MR. PAGLIUCA: Can you identify a
Bates number, please.
Q. WM) which was a
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 148 of 465
Page 147
G Maxwell - Confidential
her but you would have to ask Jeffrey what he
brought her on the trip for.
Q. But she would tr
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 145 of 465
Page 144
G Maxwell - Confidential
building that you would have seen when you
were on the trip in Europe?
MR. PAGLIUCA: Objection
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 142 of 465
Page 141
G Maxwell - Confidential
flight?
A. I don't recollect any massages on
the flight.
Q. Do you know who yy is?
A. It do
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 128 of 465
Page 127
G Maxwell - Confidential
A. I cannot testify to that flight.
Q. Let's look at the next flight which
is on the JM from
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 129 of 465
Page 128
G Maxwell - Confidential
your recollection.
MR. PAGLIUCA: You are talking
about 9
MS. McCAWLEY: She can pick any
coupl
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 125 of 465
Page 124
G Maxwell - Confidential
Q. So as you sit here today, you don't
believe you flew on that plane?
A. I'm not saying tha
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 123 of 465
Page 122
G Maxwell - Confidential
Epstein's planes with individuals who were
under the age of 18?
A. I regularly flew on Jeffrey
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 119 of 465
Page 118
G Maxwell - Confidential
We are off the record.
(Recess.)
THE VIDEOGRAPHER: It's now 11:26,
we are back on the record
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 118 of 465
Page 117
G Maxwell - Confidential
asked Virginia Roberts or whatever she is
called now to have sex with anybody.
Q. Did you ever
Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 14 of 29
her story. From this dubious premise, Defendant then argues that Ms. Ransome should therefore be
punished by having to make burdens
Case 1:15-cv-07433-LAP Document 1331-32 Filed 01/05/24 Page 2 of 4
CONFIDENTIAL
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
Case 1:15-cv-07433-LAP Document 1331-12 Filed 01/05/24 Page 2 of 10
BOIES, SCHILLER & FLEXNER LLP
Honorable Judge Robert Sweet
United States District Court
Page -2- Confidential Sealed Filing
As re
Case 1:15-cv-07433-LAP Document 1331-12 Filed 01/05/24 Page 8 of 10
case —<—$—$— CONFIDENTIAL
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 1
Case 1:15-cv-07433-LAP Document 1331-12 Filed 01/05/24 Page 1 of 10
B. ©: | E.'S, SCHALLER & Fob Ee xX NIE R Eg) Dy
40/ EAST LAS OLAS BOULEVARD® SUITE [200* FORT LAUDERDALE, FL 3330). 22) * PH G54 5
Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 17 of 21
because it had not been previously notified of any injury that might reasonably lead to litigation
and no litigation had been threa
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 13 of 43
. Whether Defendant had meet Ms. Giuffre and introduced her to Epstein. Jd. at
33;
. Whether massage therapists at Epstein’s mans
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 7 of 27
16. Desperate to draw some connection between me and young girls on the
airplane, Mr. Cassell also states that the flight logs show
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 6 of 27
13. As the record demonstrates, I could not have abused Virginia Roberts
Giuffre because, as the records establish, I was never in M
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 21 of 26
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
FBI 302 Statement, attached hereto as Exhibit 5.
Flight Logs, attached hereto
Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 3 of 27
colleague, Bradley Edwards, brought against me (Edwards v. Dershowitz, Case No. CACE
15-000072 (Cir. Ct., Broward Cnty., Fla.)). Mor
Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 8 of 13
d. Epstein’s flight logs appeared to be disguising the identity of all of the
passengers on Epstein’s plane by using such notations
Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 7 of 13
19. Rather than try these questions in the media, Mr. Edwards and I filed a
defamation action in Florida against Dershowitz. We were
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 8 of 31
Il. FACTUAL AND PROCEDURAL BACKGROUND
A. Abundant Evidence Supports Ms. Giuffre’s Sworn Testimony That Alan
Dershowitz Sexually Ab
Case 1:15-cv-07433-LAP Document 1328-29 Filed 01/05/24 Page 1 of 4
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
Vv.
Ghislaine
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 13 of 22
of answering phones cannot be given to the media.° Similarly, Defendant fails to explain why a
jury shouldn’t be allowed to consid
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 15 of 22
Further proof of malice comes from Defendant’s extraordinary lack of memory about her
involvement in the abuse.'! For instance, De
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 33 of 50
Giuffre attended fifth grade in Florida, at the Loxahatchee Elementary School.'* However, for
the 1994-1995 and the 1995-1996 scho
WDAKHUSPWNHE
Case 1:15-cv-07433-LAP Document 1328-15 Filed 01/05/24 Page 4 of 6
Page 37
THE VIDEOGRAPHER: We're now on video
record at 11:01 a.m.
MR. KUVIN: Just for the video record and
for the w
OWMWADANTSFWNHEH
Case 1:15-cv-07433-LAP Document 1328-15 Filed 01/05/24 Page 3 of 6
Page 21
answer the question based on her Fifth
Amendment privilege.
THE WITNESS: On the instruction of my
lawye
Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 28 of 35
Page 133
Flight logs.
Any other documents?
No.
Q. What did Ms. McCawley or Mr. Edwards or
any of the other lawyers say to you ab
Case 1:15-cv-07433-LAP Document 1328-8 Filed 01/05/24 Page 2 of 4
June 24, 2016 Deposition of Tony Figueroa.
7. Attac
hed hereto as Sealed Exhibit 5 is a true and correct copy of Excerpts from
May
Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 3 of 12
proceedings (apparently, also forgetting the 23 flights she shared with Ms. Giuffre on Epstein’s
private jet,° known colloquially as
Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 17 of 38
DIDO BWNFPWOOANDOAWNE
Page 146
G Maxwell - Confidential
one of his planes?
A. There was a bed on one of his
planes that folded
Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 26 of 38
DMIDMNAHBWNHRFPOWOCDIDA UYU AWNHE
Page 266
G Maxwell - Confidential
can see the dates.
MR. PAGLIUCA: Can you identify a
Bates nu
Case 1:15-cv-07433-LAP Document 1327-28 Filed 01/05/24 Page 16 of 38
DIDO BWNFPWOOANDOAWNE
Page 114
G Maxwell - Confidential
your London town home?
A. Ihave no idea what this picture
was taken. I
Case 1:15-cv-07433-LAP Document 1325-14 Filed 01/04/24 Page 27 of 30
escort young girls he brought over to Epstein’s home to Epstein for sex acts, and testified that
Defendant called him on the phone
Case 1:15-cv-07433-LAP Document 1325-7 Filed 01/04/24 Page 27 of 30
escort young girls he brought over to Epstein’s home to Epstein for sex acts, and testified that
Defendant called him on the phone,
C.
Case 1:15-cv-07433-LAP Document 1325-5 Filed 01/04/24 Page 18 of 24
Exhibits:
1,
13.
14.
13:
16.
Palm Beach Police Department report and documents contained within Jeffrey
Epstein's crimina
Case 1:15-cv-07433-LAP Document 1325-2 Filed 01/04/24 Page 9 of 70
To: [email protected][[email protected]]
From: Jenna
* Sent: Sat 3/19/2011 11:45:51 PM
Importance:
Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 15 of 21
records from the Mar-A-Lago, they have no records of Plaintiff's dates of employment to
establish the timeframe. Churcher is a witn
Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 7 of 35
From: Robert Giuffre
To: [email protected]
Subject: Virginia Roberts re: Jeffrey Epstein Case
Date: Wednesday, April 16,
Case 1:15-cv-Agted? Bian dm GonettReQorsin g Se Wineop/EAc.Page 41 of 89
Page 153 Page 155
1 Q_ Can you describe them physically? 1 Q_ More than 20?
2 A Beautiful, tall, some were blonde, some 2 A
Case 1:15-cv-07433-LAP Document 1320-27 Filed 01/03/24 Page 8 of 15
caused the need for additional depositions. See Motion at 5-8 (listing 59 examples of memory
lapses during Ms. Maxwell deposition,
Case 1:15-cv-07433-LAP Document 1320-24 Filed 01/03/24 Page 8 of 16
Second, if Ms. Giuffre is denied these depositions, she will not have had the opportunity
to obtain the information by other discov
Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 7 of 15
Second, if Ms. Giuffre is denied these depositions, she will not have had the opportunity
to obtain the information by other discov
Case 1:15-cv-07433-LAP Document 1320-20 Filed 01/03/24 Page 6 of 11
Weighing these factors, there is no basis for permitting more than the presumptive ten
deposition limit. First, as highlighted by t
Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 35 of 40
voluntary disclosure of confidential information effectively waives the privilege as to all
conversations, or the whole breadth of
Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 30 of 40
support his extreme assertion that Ms. Giuffre waived her privilege simply by allowing an
affidavit to be filed in a court proceed
Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 26 of 40
course, that motion was filed on their behalf — not Ms. Giuffre’s. To be sure, that motion
contained (among other supporting infor