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pe of this case, which is a real 23 issue, obviously. So is it you are restricting your claim to 24 the truth and falsity of the statements about Maxwell? 25 MS. McCAWLEY: Yes, that is the case, your Honor. The SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794557 3 H3V0GIU1 1 stateme
If you notice the date of that 10 article, your Honor, it's March 5th, 2011. 11 The next document I provided is a press statement 12 issued by Ghislaine Maxwell on March 10th, 2011, so five days 13 later, in which she writes, care of her attorneys, "Ghislaine 14 Maxwell denies the various allegations abou
ided is a press statement 12 issued by Ghislaine Maxwell on March 10th, 2011, so five days 13 later, in which she writes, care of her attorneys, "Ghislaine 14 Maxwell denies the various allegations about her that have 15 appeared recently in the media. These allegations are all 16 entirely false."
re statement talks about 24 allegations against Ms. Maxwell have been proven 25 untrue. SOUTHERN DISTRICT
0 guess, unless you all think it's been covered, the Maxwell 11 motions. What do you think? 12 MR. PAGLIUC
s". 10 Your Honor will notice that this document is not 11 marked confidential, it was produced by Ms. Maxwell over a year 12 ago, it is marked Ghislaine Maxwell 0006, and it's a 13 communication between herself and Alan Dershowitz, someone with 14 whom she does not have a joint defense agreement, and that's 1
ut Bill 13 Clinton being on the island and says, "He was never there." 14 Right after that, she says, n discussed that Al Gore 15 and his wife Tipper were also guests on the island." And 16 Ms. Maxwell writes, "They have also never been on the island, 17 and I don't believe they even know Jeffr
ss Complaints". Your Honor will notice that this document is not marked confidential, it was produced by Ms. Maxwell over a year ago, it is marked Ghislaine Maxwell 0006, and it's a communication between herself and Alan Dershowitz, someone with whom she does not have a joint defense agreement, and that's why she pr
20 21 22 23 24 25 H3VOGIU1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15 Civ. 7433 (RWS) GHISLAINE MAXWELL, Defendant. Oral Argument x New York, N.Y. March 31, 2017 LO310 a.m, Before? HON. ROBERT W. SWEET, District Judge APPEARANCES BOIES, SCHILLER
the scope of this case, which is a real issue, obviously. So is it you are restricting your claim to the truth and falsity of the statements about Maxwell? MS. McCAWLEY: Yes, that is the case, your Honor. The SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011305 10 id. 12 13 14
edia coverage. If you notice the date of that article, your Honor, it's March 5th, 2011. The next document I provided is a press statement issued by Ghislaine Maxwell on March 10th, 2011, so five days later, in which she writes, care of her attorneys, "Ghislaine Maxwell denies the various allegations about her th
alks about Virginia Giuffre's allegations against Ms. Maxwell have been proven untrue. SOUTHERN DISTRICT REPO
I guess, unless you all think it's been covered, the Maxwell motions. What do you think? MR. PAGLIUCA: Your
ms about Bill Clinton being on the island and says, "He was never there." Right after that, she says, "Virginia discussed that Al Gore and his wife Tipper were also guests on the island." And Ms. Maxwell writes, "They have also never been on the island, and I don't believe they even know Jeffrey Epste
6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. GHISLAINE MAXWELL, Defendant. Before: x x 15 Civ. 7433 (RWS) Oral Argument New York, N.Y. March 31, 2017 10:10 a.m. HON. ROBERT W. SWEET, District J
the scope of this case, which is a real issue, obviously. So is it you are restricting your claim to the truth and falsity of the statements about Maxwell? MS. McCAWLEY: Yes, that is the case, your Honor. The SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00612251 1 2 3 4 5 6 7 9 10
If you notice the date of that 10 article, your Honor, it's March 5th, 2011. 11 The next document I provided is a press statement 12 issued by Ghislaine Maxwell on March 10th, 2011, so five days 13 later, in which she writes, care of her attorneys, "Ghislaine 14 Maxwell denies the various allegations abou
entire statement talks about allegations against Ms. Maxwell have been proven untrue. SOUTHERN DISTRICT REPO
I guess, unless you all think it's been covered, the Maxwell motions. What do you think? MR. PAGLIUCA: Your
s Complaints". Your Honor will notice that this document is not marked confidential, it was produced by Ms. Maxwell over a year ago, it is marked Ghislaine Maxwell 0006, and it's a communication between herself and Alan Dershowitz, someone with whom she does not have a joint defense agreement, and that's why she p
e claims about Bill Clinton being on the island and says, "He was never there." Right after that, she says, " discussed that Al Gore and his wife Tipper were also guests on the island." And Ms. Maxwell writes, "They have also never been on the island, and I don't believe they even know Jeffrey Epste
e an imaginative fantasy about her fictional meeting with former President Clinton. She "describes" how Mr. Clinton's Secret Service detail allowed Ghislaine Maxwell, then a novice helicopter pilot, to fly the former President to Epstein's private island on a large black helicopter—an obvious lie. She then purpor
it constantly surprised me that people with as much to lose as Bill and [Prince] Andrew weren't more careful. She said that when dining that night, Maxwell sat at President Clinton's left, while they were joined by two 'olive- skinned brunettes' who had been flown in from New York... I'd never met them
I'd never met them before. I'd say they were no older than 17, very innocent-looking. They weren't there for me. They weren't there for Jeffrey or Ghislaine because I was there to have sex with Jeffrey on the trip. Maybe Jeffrey thought they would entertain Bill, but I saw no evidence that he was inter
est details designed to enhance the value of her fictional account: "[Jane Doe #3) disclosed that Mr Clinton's vice-president Al Gore and his wife, Tipper, were also guests of Epstein on his island...'I had no clue that anything was up,' [Jane Doe #3] says. 'The Gores seemed like a beautiful couple wh
other meeting with a powerful political figure for the British tabloid, this time claiming to have met former Vice President Gore and his then wife, Tipper, on the same Island, again providing no specific dates or times, but only personal interest details designed to enhance the value of her fictional
Microsoft Word - 1A6C.27.02
ctional meeting with former President Clinton, providing an elaborate description about how Mr. Clinton and his secret service detail somehow allowed Ghislaine Maxwell, then a novice helicopter pilot, to fly all of them to Jeffrey’s Epstein’s private island on Epstein’s black helicopter, as well as details a
Page: HOUSE_OVERSIGHT_010744 →eting with former President Clinton, providing an elaborate description about how Mr. Clinton and his secret service detail somehow allowed Ghislaine Maxwell, then a novice helicopter pilot, to fly all of them to Jeffrey’s Epstein’s private island on Epstein’s black helicopter, as well as details about the
Page: HOUSE_OVERSIGHT_010744 →ws, the ex-President did not take the bait. “‘I’d have been about 17 at the time,’ [Jane Doe #3] says. ‘I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill [Clinton] in a huge black helicopter that Jeffrey had bought her. She’d always wanted to fly and Jeffrey paid for her to take le
Page: HOUSE_OVERSIGHT_010744 →is British newspaper an account of yet another fictional meeting on the same island, but this time with former vice president Gore and his then wife, Tipper, providing specific details purportedly to enhance the value of her fictional story: “The Gores seemed like a beautiful couple when I met them... Jef
Page: HOUSE_OVERSIGHT_010744 →full of fictional minutae. about her dinner meeting with former President Clinton. She "describes" how Mr. Clinton's Secret Service detail allowed Ghislaine Maxwell, ( then a novice helicopter pilot,) to fly the former President to Epstein's private island on a large black helicopter —an obvious and ludicrous
urprised me that people with as much to lose as Bill and [Prince] Andrew weren't more careful. She said that when dining that EFTA00864872 night, Maxwell sat at President Clinton's left, while they were joined by two 'olive-skinned brunettes' who had been flown in from New York... I'd never met them
I'd never met them before. I'd say they were no older than 17, very innocent-looking. They weren't there for me. They weren't there for Jeffrey or Ghislaine because I was there to have sex with Jeffrey on the trip. Maybe Jeffrey thought they would entertain Bill, but I saw no evidence that he was inter
ther meeting with a powerful political figure for the British tabloid, this time claiming to have met former Vice President Gore and his then wife, Tipper, on the same Island, again providing no specific dates or times, but only personal interest details designed to enhance the value of her fictional a
full of fictional minutae. about her dinner meeting with former President Clinton. She "describes" how Mr. Clinton's Secret Service detail allowed Ghislaine Maxwell, ( then a novice helicopter pilot,) to fly the former President to Epstein's private island on a large black helicopter—an obvious and ludicrous li
it constantly surprised me that people with as much to lose as Bill and [Prince] Andrew weren't more careful. She said that when dining that night, Maxwell sat at President Clinton's left, while they were joined by two 'olive-skinned brunettes' who had been flown in from New York... I'd never met them
I'd never met them before. I'd say they were no older than 17, very innocent-looking. They weren't there for me. They weren't there for Jeffrey or Ghislaine because I was there to have sex with Jeffrey on the trip. Maybe Jeffrey thought they would entertain Bill, but I saw no evidence that he was inter
ther meeting with a powerful political figure for the British tabloid, this time claiming to have met former Vice President Gore and his then wife, Tipper, on the same Island, again providing no specific dates or times, but only personal interest details designed to enhance the value of her fictional a
e an imaginative fantasy about her fictional meeting with former President Clinton. She "describes" how Mr. Clinton's Secret Service detail allowed Ghislaine Maxwell, then a novice helicopter pilot, to fly the former President to Epstein's private island on a large black helicopter —an obvious lie. She then purp
it constantly surprised me that people with as much to lose as Bill and [Prince] Andrew weren't more careful. She said that when dining that night, Maxwell sat at President Clinton's left, while they were joined by two 'olive-skinned brunettes' who had been flown in from New York." Jane Doe #3 also co
that anything was up,' says. 'The Gores seemed like a beautiful couple when I met them. All I knew was that Mr Gore was a friend of Jeffrey's and Ghislaine's. Jeffrey didn't ask me to give him a massage...There might have been a couple of other girls there on that trip but I could never have imagined t
th a powerful political figure for the British tabloid, this time claiming to have met former Vice President Gore and his then EFTA00582897 wife, Tipper, on the same Island, again providing no specific dates or times, but only personal interest details designed to enhance the value of her fictional a
ons with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared
Page: HOUSE_OVERSIGHT_014803 →lying in a hammock.‘We all dined together that night. Jeffrey was at the head of the table. Bill was at his left. | sat across from him. Emmy Tayler, Ghislaine’s blonde British assistant, sat at my right. ‘Ghislaine was at Bill’s left and at the left of Ghislaine there were two olive-skinned brunettes who'd
Page: HOUSE_OVERSIGHT_014807 →did Bill commute Prosperi’s sentence as some kind of favour for Epstein?’ Virginia disclosed that Mr Clinton’s vice- president Al Gore and his wife, Tipper, were also guests of Epstein on his island. © AFP/Getty Images Guests: Virginia says she also met former Vice President Al Gore, pictured right wit
Page: HOUSE_OVERSIGHT_014808 →n, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.’ 2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher entitled “Prince Andrew and the
Page: HOUSE_OVERSIGHT_014652 →espectfully submit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.’ 2. Attached as E
Page: HOUSE_OVERSIGHT_014652 →ives most concern. mon ey. | was a He was first seen with the pair on holiday in “Tt Thailand, and was pictured cavorting with paed Oop hile's dream Ghislaine at a Halloween fetishthemed party in hitp:/Avww.dailymail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him
Page: HOUSE_OVERSIGHT_014661 →did Bill commute Prosperi’s sentence as some kind of favour for Epstein?’ Virginia disclosed that Mr Clinton’s vice-president Al Gore and his wife, Tipper, were also guests of Epstein on his island. Case 1:15! GrO Tash VES 0 Dercerrne rit 2 Hb Bicokz pings SEMI] OMe Grind 5 Cambridge can't contain her
Page: HOUSE_OVERSIGHT_014670 →Entities connected to both Ghislaine Maxwell and Tipper

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Marc Rich
PERSON
Donald Trump
PERSONJeffrey Pagliuca
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONLaura Menninger
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONJane Doe
PERSONEmmy Taylor
PERSON
David Boies
PERSON
Sarah Kellen
PERSON