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Ghislaine Maxwell Case 1:15-cv-07433-LAP Document 1090-1

Pages 11-39 of 638

Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell: MOTION TO COMPEL ALL ATTORNEY-CLIENT COMMUNICATIONS AND ATTORNEY WORK PRODUCT PLACED AT ISSUE BY PLAINTIFF AND HER ATTORNEYS

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Document Highlights

Page 4 (8 of 29) Shows that Jane Doe 3 that joined the Jane Doe 1 & 2 is  Ms. Giuffre. It goes on to say Ms. Giuffre; then a minor, claims to have had sexual relations with Prince Andrew, Duke of York ("Prince Andrew"), Ms. Maxwell, Jean Luc Brunel ("Brunel") and Alan Dershowitz("Dershowitz").


Page 16 (20 of 29) "The assertions of sexual abuse are more than adequately corroborated by compelling circumstantial evidence which is detailed at length by Cassell in his deposition." (word product/investigations); "Edwards and Cassell clearly had a powerful basis for believing their client's allegation that she had been sexually abused by Dershowitz, particularly where she had made this allegation to them as far back as 2011" (attorney-client communications).


Page 20 (24 of 29) ... Plaintiff claims that she was defamed when Ms. Maxwell stated that the allegations Plaintiff made in the Joinder Motion, included allegations regarding Dershowitz, Ms. Maxwell and Prince Andrew, were false. In the Joinder Motion Edwards and Cassell boldly state "Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, Mew Mexico, and the U.S. Virgin Islands."

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