here are a few things to look out for:
- Names of lawyers, associates to Epstein.
- Claims about Prince Andrews shady deals and friends.
- What the newspapers wrote at the time.
- How Giuffre got the job at Mar-a-Lago.
- Testimony from Fiancé at time, father and others Overall this dump is less salacious then the first, but I feel just as important, especially for trying to answer certain questions you guys were asking in the first post. Link to docs used – gofile.io/?c=lyoJKI Link to the first post – If you are new read this first – www.reddit.com/r/JoeRogan/comments/cq93tu/i_am_combing_through_all_of_the_epstein_files/?utm_source=share&utm_medium=web2x
Page 2 Exhibit A Daily mail article concerning Prince Andrew, Epstein and Virginia Roberts (Giuffre) – Andrew sold a property for 15 million to a Kazakh Businessman after it was left unsold at 12 million for 5 years. – Had criticized an official corruption investigation into the huge Al-Yamamah arms deal between Britain and Saudi Arabia,
- is close to Saif Al-Islam Ghaddafi,
- may have had role in early release of Lockerbie bomber Abdelbaset Al Megrahi
- Known Epstein since at least 2000
- First seen on holiday with Maxwell and Giuffre in Thailand. Then a Halloween party in Manhattan.
- Strolled with Epstein in Central park
- Spent four days in Epstein’s mansion, which included woody Allan at dinner.
- Was also guest at cocktail party years earlier, packed with young Russian models.
- Police claim Epstein’s donations, connections to politicians and dream team of lawyers got him off easy.
- Epstein has made 17 out of court settlements at the time of this article.
- Epstein guaranteed her a minimum of 200 each time they met for an erotic massage.
- She worked to stay in his favour and say his number one girl.
- Epstein bought her many gifts
- Went on 6-week trip, travelled the world.
- Ghislaine joked about having to trade her in soon because she was to old.
- Claims in this article that is was Ghislaine who put the puppet on her hand and fondled Giuffre while Andrew grabbed the other.
- She met prince Andrew three times.
- Was told that Jeffrey wanted her to have his child.
- Wanted her to sign contract giving up rights to child.
- This woke her up.
Exhibit B Page 11
- Daily mail article on Epstein and Giuffre.
- Flew Chris Tucker and Kevin Spacey to Africa to discuss aids.
- Epstein has donated over 75K to candidates in the democratic party.
- Flew Mr. Clinton to Russia, Oslo, Hong Kong, Shanghai and Beijing
- Giuffre says she was never lent out to Clinton.
- As far as she knows, Clinton did not take the bait when it came to the two brunettes.
- She met bill Clinton twice.
- Epstein told her they were good friend and that bill owed him some favours.
- Claims bill must have known about the girls.
- Desks were covered with Jeffrey sharking hand with famous people and of naked girls in three desks in the living room of the villa.
- Emmy Taylor – Ghislaine assistant – dined with them and Bill and the two brunettes
- After dinner she gave Epstein a erotic massage but doesn’t remember seeing Bill again.
- Arnold Prosperi, Clinton acquittance, visited Epstein in jail the first time.
- Mr. Clinton in the final hours of his presidency, commuted this man’s sentence for tax fraud to house arrest.
- She met the Gores and had no idea Al Gore was being accused of trying to force sex on a woman at a therapeutic massage he had booked.
- Jeffrey did not ask her to give him a massage.
- There might have been other girls on that trip, but she couldn’t imagine gore doing that.
- She planned to vote for gore when she was 18.
- Senator George Mitchell frequently visited.
- Was very close to Epstein, was Obamas middle east peace envoy.
- Met Ehud Barak, Israel defense secretary.
- He attended several functions with other leading businessmen, university presidents, Nobel prize laureates, and public figures.
- Epstein knew Matt Groening, Simpsons creator
- he drew pictures of Bart and Homer for her on a flight.
- She gave matt a foot massage.
- Met Naomi Campbell at birthday party of her on yacht in south of France
- Was real bitch but friend of Ghislaine.
- More then 20 of Epstein’s girls have sued for damages., at least 17 settled.
- Clinton, Gore and Mitchell were contacted for comment but declined.
Exhibit C PR HUB Article – Statement on behalf of Ghislaine Maxwell Page 16
- Maxwell denies allegations
- Jane Doe 3 and 4 wished to join the action involved in the CVRA.
- Jane doe 3 (appears to be Giuffre) was approach by Maxwell. The government knew Maxwell regularly participated in Epstein’s sexual exploitation of minors.
- Jane doe 3 was 15 at the time and persuaded to come to Epstein’s mansion.
- Epstein and Maxwell turned a massage into a sexual encounter.
- Converted her into a sex slave after and she was sexually trafficked
- Claims forced to have sex with Alan Dershowitz in numerous occasions including Florida and an airplane, New York, New Mexico, US Virgin Islands.
- Eyewitness to other girls being abused.
- Government is aware of some underaged illegal child porn pictures and has them in their possession.
- Prince Andrew again.
- Jean Luc Brunel would bring young girls as young as 12 to the US for sexual purposes and farm them out to friends.
- Brunel would off the girls modeling jobs.
- Epstein forced her to have sex with Brunel numerous times, in Virgin Islands, New York, New Mexico, Paris, south of France, and California.
- Epstein required her to sleep with powerful men in order to black mail them.
- The government hid the deal for non-prosecution with Epstein from Giuffre violating her rights under the CVRA
- The offences Epstein committed had no statue of limitations
- There was a request made for documents pertaining to Epstein’s lobbying efforts to persuade the government to give him a more favourable deal.
Order denying petitioners motion to join under rule 21 and motion to amend under rule 15
- Jane Doe 3 and 4 can’t join under rule 21, rule 15 is the proper procedure.
- Failed to join under rule 15 because undue delay joining, undue prejudice that amendment will cause.
- Issue with rule 21 is they were not omitted due to inadvertence or mistake and are instead trying to join under rule 20
- Rule 15 covers these types of situations so rule 21 is denied.
- Portions of 21 motion stricken from record along with related findings.
- Alan Dershowitz intervened “for the limited purposes of moving to strike the outrageous and impertinent allegations made against him and requesting a show cause order to the attorney that have made them”. Court strike’s anyways so motion to intervene will be denied as moot.
- This also moots Alan Dershowitz motion for leave to file supplemental reply in support of motion for limited intervention.
Rule 15 motion
- It is unnecessary for jane doe 3 and 4 to be parties rather then act witnesses (seems to be telling them to file their own lawsuits)
- Lawyers for 4 Jane does claim don’t want duplicate proceedings at same time and instead coordinate efforts.
- Motion doesn’t show why addition of “other similarly-situated victims” is now necessary to “vindicate their rights as well”.
- Can participate but that participation is not limited to listing them as parties rather then witnesses.
- Jane does 3 and 4 can participate and may offer relevant evidence but listed as parties is not necessary.
- Rule 21 motion denied
- Rule 15 motion denied
- Alan Dershowitz motion for intervention and motion for leave to file supplemental reply in support of motion for limited intervention are denied as moot.
- Motion to seal is denied as moot.
- Certain materials stricken from record.
- Ross Gow letter on behalf of Maxwell
- Repeating claim that she claims Virginia Roberts (Giuffre) is lying
Virginia Giuffre V Ghislaine Maxwell
- Meredith Schultz appearing for plaintiff Giuffre with David Turner – from Boies, Schiller and Flexner LLP.
- Laura Menninger Appearing on behalf of Ghislaine Maxwell From Haddon, Morgan and Foreman (Missing pages)
- Talking to Mr. Ross Gow
- Discussing who knew what related to the statements given in the public or to journalist.
- James Ball at the guardian reached out to Ross Gow in relation to the fresh allegation levied against Maxwell, since he had represented her before.
- Ross asked Maxwell how she would like to handle it
PLAINTIFF’S RESPONSES AND OBJECTIONS TO DEFENDANT’S SECOND REQUEST FOR PRODUCTION AND DEFENDANT’S INTERROGATORIES, PLAINTIFF’S ANSWERS TO DEFENDANT’S REQUESTS FOR ADMISSION
- Defendant’s Discovery Requests violate Rule 33, Fed. R. Civ. P., which provides “a party may serve on any other party no more than 25 interrogatories, including all discrete subparts” – in that Defendant has served a total of 59 interrogatories in this case, including subparts, in violation of Rule 33
- Ms. Giuffre objects to Defendant’s Second Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege
- A request that each of these attorneys list all communications with the media is facially overbroad
- Ms. Giuffre objects to this Interrogatory because a response would cause Ms. Giuffre the incredible and undue burden of having to catalogue literally hundreds of communications that she has already produced in this case.
- Giuffre objects because this interrogatory calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence
- Giuffre objects to the extent that this interrogatory seeks the communications of her attorneys, any author, reporter, correspondent, columnist, writer, commentator, investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any media organization or independent consultant
- Ms. Giuffre is not obligated to produce anything currently in the possession of Defendant Maxwell or her attorneys.
- Ms. Giuffre has already produced her responsive communications, which are found in documents Bates labelled GIUFFRE000001 to GIUFFRE007566
- Ms. Giuffre objects because the information interrogatory above is in the possession of Defendant who has failed to comply with her production obligations in this matter.
- Ms. Giuffre further objects because the information requested above is in the possession of Defendant’s agent, who caused the false statements to be issued to various media outlets
- Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow.
PLAINTIFF’S SUPPLEMENTAL RESPONSES TO DEFENDANT’S INTERROGATORIES 6, 12 AND 13
- Violate rule 33
- Some information protected by applicable privilege
- Certain request invades Giuffre’s privacy
- Overly broad and unduly burdensome
- No. 12 – Related to healthcare provider information at that time
- Declaration of Ghislaine Maxwell
- “I have no control over any media organization, including those media organizations that published any part of a January 2015 statement on my behalf at the direction of my attorney, Philip Barden”
- “Neither I, nor any agent acting on my behalf approved or participated in any activity of any media organization in its decision to publish or not to publish any part of the January 2015 statement”
- Declaration of Philip Barden
- Solicitor of the Senior Courts of England & Wales based in London, England.
- Represented Ms. Maxwell since 2011 regarding the allegations made by Plaintiff Virginia Giuffre
- Hired during Sharon Churcher Articles
- December 30, 2014, Ms. Giuffre made numerous salacious and improper allegations against Ms. Maxwell
- Continued to represent Ms. Maxwell at that time and I coordinated the response to the media
- Cannot remember where he was when he prepared statement but did it January 2, 2015,
- Needed to do was issue an immediate denial and that necessarily had to be short and to the point
- Claimed they were “obvious lies”
- Barden goes after Giuffre credibility for not stating certain claims sooner or claiming that they have changed
- For example – “Yet in her joinder motion she claimed she did have sex with Prince Andrew and that the sex occurred in what can only be described as a very small bathtub, too small for a man of Prince Andrew’s size to enjoy a bath in let alone sex”
- Barden did not intend the January 2015 statement as a traditional press release solely to disseminate information to the media
- purpose in preparing and causing the statement to be disseminated to those media representatives was twofold.
- First, wanted to mitigate the harm to Ms. Maxwell’s reputation
- Second, intended statement to be “a shot across the bow” of the media, which I believed had been unduly eager to publish plaintiff’s allegations without conducting any inquiry of their own
- intended as a cease and desist letter to the media-recipients Page 90
- Continues to try to attack Giuffre’s credibility
- Brings up Alan Dershowitz
- Barden claims it was his opinion Giuffre was lying
Video Deposition of James Michael Austrich
- Knows Virginia Roberts (Giuffre) last seen around 16 years ago
- Friend of his stepsister (name blacked out)
- Sister met her in rehab
- He met her in 1999
- Lived together in an apartment in Oakland park, both worked at taco bell
- Giuffre was not in school when he met her
- She stayed with him at dad’s house
- Stepfamily lived there too.
- Giuffre was not there long, only weeks
- He met Giuffre’s parents but doesn’t remember much from it
- Became couple soon after
- After moving out of his Dad’s place, they move to Oakland park apartment together
- He was about 18 she was about 16
- Lived there together less then a year
- Another roommate named Mario
- Both men were manager’s at Taco Bell, she was employee
- Giuffre and James moved out, Mario kept apartment, James cannot remember why
- Moved into trailer Giuffre family had on property
- They were engaged when living in Oakland park
- Later moved into an apartment in Royal Palm Beach
- Knew Jeff, referred to him as that
- Knows she went to work for him
- Knew they went to an island and travelled
- He was told it was for massages in the beginning
- Was making a lot more money
- A fight involving a guy named Tony eventually brought out some of the truth of what Giuffre was doing
- Doesn’t really remember what she said, he admits to probably being on drugs at the time
- Q) Regardless, you would not have been comfortable believing your fiancé was having sex with other people?
- A) No.
- Q) Did she, Ms. Roberts ever tell you that she was posing naked for photographs?
- A) No.
- Q) Would you have been okay with her posing naked for photographs? A No.
- Q) Did Ms. Roberts ever mention Ghislaine Maxwell, my client?
- A) If she did, I don’t remember the name. Like I said, I only remember Jeff. That name is all I really remember.
- Picture of the application for a passport
CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE
- Q) And what part of paragraph 4 do you 7 now believe to be untrue?
- A) In approximately 1999 when I was 15 years old I met Ghislaine Maxwell.
- Q (BY MS. MENNINGER) Okay.
- A) I now know that it was 2000, that I was 16 years old when I met Ghislaine Maxwell.
- A) It wasn’t until I found the facts that I worked at Mar-a-Lago in 2000 that I was able to figure that out.
- Q) (BY MS. MENNINGER) And approximately when did you learn those facts about the dates you worked at Mar-a-Lago?
- A) I would say it was mid-2015.
- Q) Okay. Now tell me how you sort of came into Mar-a-Lago for the first time? He asked you to come? They called you? What happened?
- A) My dad was very liked there. So I think he talked to the people who were in HR. And then… (document cuts off)
- Q) How long did you work at Mar-a-Lago?
- A ) Best of my recollection, it was a summer job. I believe I started in June. And I think I only worked there approximately two weeks, two, three weeks.
- Q) How many hours a week did you work?
- A) I want to say it was a — I want to say it’s a full-time job.
- Q) Do you recall it being a full-time job?
- A) It was a summer job, but just thinking back, my dad used to bring me in and bring me home. So he worked full time, all day. So — and I didn’t lounge around Mar-a-Lago so, yes, I think it would have been a full-time job.
- Q) And how much did you make per hour?
- A) Approximately, I think I remember making $9 an hour.
- Q) The bracelet and earrings you got for your birthday, some birthday, on Little — or where was that birthday party, at Little St. James?
- Q) When do you recall ever getting a cell phone?
- A) The first cell phone I ever got was the one that Ghislaine gave to me.
- Q) Okay. So tell me what you recall of the first conversation that you had with Ghislaine Maxwell.
- A) I’m sitting there reading my book about massage therapy, as I’m working in the spa. And I’m getting my GE — well, I was in the process of getting my GED before I went to my summer job. I decided that I would like to become a massage
- Q) When you say living with you, were you guys staying in the same room?
- A) Yes.
- Q) Were you engaged at that time to him?
- A) That was a really weird relationship. He was a friend who looked after me, and he did propose to me and I did say yes.
- Q_ Okay. Where were you sent to have sex with the owner of a large hotel chain by Ghislaine Maxwell? MR. EDWARDS: Object to the form. A) I believe that was one time in France.
- Q) (BY MS. MENNINGER) Which time in France? A) I believe it was around the same time that Naomi Campbell had a birthday party.
- Q) Where did you have sex with the owner of a large hotel chain in France around the time of Naomi Campbell’s birthday party?
- A) In his own cabana townhouse thing. It was part of a hotel, but I wouldn’t call it a hotel. Jeffrey was staying there. Ghislaine was staying there. Emmy was staying there. I was staying there. This other guy was staying there. I don’t know his name. I was instructed by Ghislaine to go and give him an erotic massage
- Q) She used the words erotic massage?
- A) No, that’s my word. The word massage is what they would use. That’s their code word. Page 145
- Q) Where did you go to have sex with Marvin Minsky? A) I believe it was the U.S. Virgin Islands, Jeff’s — sorry, Jeffrey Epstein’s island in the U.S. Virgin Islands.
- Q) Other than Glenn Dubin, Stephen Kaufmann, Prince Andrew, Jean Luc Brunel, Bill Richardson, another prince, the large hotel chain owner and Marvin Minsky, is there anyone else that Ghislaine Maxwell directed you to go have sex with? A) I am definitely sure there is. But can I remember everybody’s name? No.
- Photo of documents involving school documents
VIDEOTAPED DEPOSITION OF TONY FIGUEROA
- Q) And just to be clear, she already lived in the apartment? A) Yeah. She lived in the apartment with her ex-boyfriend Michael and JJ. And I think there was somebody else. I don’t remember who, though.
- Q) When did your relationship with Ms. Roberts end the second time?
- A) When she went to Thailand and never heard from her again.
- THE COURT REPORTER: I’m sorry. Can you re-answer?
- A) Yeah. When Jeffry sent her to Thailand. And then I never heard from her again until freaking, like, two days ago.
- Q) Did Ms. Roberts ever tell she had met a senator?
- A) Not that I’m aware of. I mean, she’s told me that she met a bunch of people before. And after it started becoming, like, an almost everyday thing about — just hearing about famous people with Jeffrey and stuff like that, it’s, like, I kind of didn’t, like, tone it out, but I just — it became normal, so I just stopped, like, listening to all the details, because I was not going to meet these people, you know what I mean? It’s just, like, all right.
- Q) Was she excited that she was meeting famous people?
- A) Yeah.
CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE
- Related to employment at other places
- Social security evidence between 1998–2002 and 2013-2015
- Record do not show the exact date of employment (month and day) because SS do not need this information to figure Social Security benefits. Employers do not give that information.
Page 197 – 200
Exhibit S – Documents for Mar-a-Lago
- Letter (of recommendation after leaving job to relocate to Colorado) dated January 30, 2003 from Mar-a-Lago.
- Signed by Donald Trump
- Shows termination of Virginia Roberts Box #4
- Box #4 indicates 2000 terms
VIDEO-DEPOSITION Sky Roberts
- Q) Do you remember there being a job posting that you felt like was appropriate for Virginia or did you just go out and talk to the woman who ran the spa area on your own?
- A) I just talked to Angela.
- Q) Okay. Do you recall whether this was intended to be a full-time job?
- A) I don’t remember if it was full time or just summer jobs or, you know, during season. It was probably for a season because Mar-a-Lago is seasonal. I mean, I was there year round but a lot of people are seasonal, you know, because it’s like snowbirds, you know, summertime comes and nobody wants to be down in south Florida.
- Q) What would you call the season, the seasonal aspect of Mar-a-Lago? What’s the season?
- A) Probably from September or October to, you know, maybe May, I guess.
- Q) Is that the coolest time?
- A) Times of the year, yes.
- Q) And it’s more guests that come during that period of time?
- A) Yes.
- Q) And is there more staff brought on during that period of time?
- A) Yes.
- Q) You saw that happen every year that you were there?
- A) Every year.
- Q) And in the summer, it’s relatively dead because it’s so hot?
- A) Basically, it closed during the summer. That’s when we would kind of work on everything and then make sure everything is up to snuff for the next year, you know.
- Q) Do you remember what capacity Virginia was hired to work in, what her job title was, for example?
- A) I don’t know. I would have lunch with Virginia. That’s about as much as I know about what she did. I was busy all the time.
- Q) I understand.
- A) I didn’t have time to go see what she was doing. I didn’t really talk to Angela about what she had to do. I think that was her name, Angela. But it’s kind of the name that sticks out.
- A Where did I learn that?
- Q) Uh-huh.
- A) I think Virginia had told me that there was a lady in the spa area named Ms. Maxwell. I don’t know her. I couldn’t tell you what she looked like. But just she said Ms. Maxwell said she can get me a job with Jeffrey Epstein who is a friend of Donald Trump, so I figured, well, he was a good guy or whatever, you know, and that she was going to learn massage therapy.
- Q) When did Virginia tell you this?
- A) Oh, I can’t tell you what date and time but I don’t remember.
- Q I understand. Did she tell you this while she was working at Mar-a-Lago?
- A) Yes. I mean, after she had been there for a little bit, you know, and then she told me, yes, that she could possibly get this other job
- Q) Did you ever meet Jeffrey Epstein?
- A) Once.
- Q) When was that?
- A) I dropped Virginia off at the house once and he came out and I met him and seemed just fine to me. I mean, you can’t tell people by looking at them. I mean, I know now from, you know, what I’ve read that he’s not a good guy. But you can’t tell. You know, you don’t even know your neighbors sometimes, you know.
- Q) Was it about the same time Virginia started working with him?
- A) Yeah.
- Q) Was it later?
- A) I think it was about the time she started. Because I wanted to see where she was at, you know. And it was just a mansion down the street from, you know, Mar-a-Lago. So I didn’t think twice about it. I didn’t think nothing of it. He came out. He was very cordial, very nice.
- Q) Okay. Have you ever met Ms. Maxwell?
- A) Not that I remember ever meeting her.
- The Mar-a-Lago Club, L.C. Employment policies – October 28, 1995
- No Solicitation/No Distribution rules at Mar-a-Lago
- Persons who are not employees are prohibited from soliciting employees.
- Notice from Vicki Yawnick looking for help asked to run Saturday October 14th and Sunday October 15th
- Spa Attendants on list – Says “College students encourage to apply”
Page 300 to 311
- Application of employment and records
Page 313 to 315
- Police records for a Burglary – Non-Vehicle
Page 317 – 322
- Records pertaining to Anthony Figueroa arrest for marijuana
Page 324 – 326
- Police records for a Theft/Larceny
That is it for this post.
If you have made it this far, THANK YOU!!!