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A federal court in New York ordered lawyers for Ghislaine Maxwell to search her emails for dozens of lewd terms and high-profile names in the lawsuit brought by Jeffrey Epstein accuser Virginia Giuffre, court records show.

Amid some back-and-forth between lawyers for both sides, Giuffre’s team zeroed in on key names in Maxwell’s orbit, including the British Prince Andrew, and terms including “nipple,” “schoolgirl,” “servitude” and sexual terms.

“Massage,” another sought-after term, was Epstein’s code word for sex with the young women and girls he employed as massage therapists, one of Epstein’s accusers claimed in other files released in the case.

But Maxwell’s lawyers disputed more than a hundred requested names, including a list of first names that belonged to Epstein accusers, associates and others but which also would have resulted in the flagging of many unrelated emails because they are “incredibly common names.” They also challenged searches for “common words,” lawyer names and other keywords.


The name “Bill,” Maxwell’s lawyers added, is not only a common name but would also return receipts for “every bill that our client has ever received, sent or discussed.”

Frank Thornton, an expert in digital forensics, said the back-and-forth about what terms should be searched is “very typical” in a lawsuit.


Ghislaine Maxwell in 2005

“You derive things like these lists from talking to these witnesses who say, ‘Well, I have an email and used this term, this name was used,’” he told Fox News Digital. “The judge may have decided that, after reviewing it, a lot of it really doesn’t pertain to the case at all, no basis to turn it over to the other party.”

Some of the phrases may look bizarre to the average viewer, he added, but provide a glimpse at how legal software can scan huge amounts of documents quickly for subjects that fall outside specific keywords.


“No. 104 jumps out at me: ‘joint* w/3 defend*,’” he said. “They’d be looking for something that begins with ‘joint’ and within 3 words of something that begins with ‘defen.'” 

READ: Maxwell and Giuffre attorneys discuss search items

That could turn up emails, for example, discussing a “joint defense privilege” between Maxwell and Epstein.

Other sought-after terms including the “w/3” qualifier included “high* w/3 school*,” “school* w/3 girl*” and “sex w/3 toy*.” Giuffre’s lawyers also sought references to law enforcement, including the FBI, as well as state and federal prosecutors.

The documents include redaction and sealed files that remained secret years after the end of a 2015 lawsuit between Giuffre and Maxwell. U.S. District Judge Loretta Preska ordered the documents’ unsealing in December but gave each of the John and Jane Does two weeks to appeal. Lawyers for Giuffre posted the first 191 unsealed files last week out of an estimated 240, later reduced to 215.

Prince Andrew Virginia Giuffre and Ghislaine Maxwell in 2001 photo

Epstein had many high-profile connections. Some of the names were previously known through other means despite having been withheld from the public’s eye in the lawsuit. Many of the names belong to people who have not been accused of wrongdoing.

READ the list of requested search terms

Throughout the civil case, Giuffre’s lawyers accused Maxwell and Epstein, who was still alive at the time, of stalling by refusing to cooperate during depositions and improperly withholding documents during discovery. Maxwell and Giuffre settled a lawsuit in 2017. Epstein died in jail in 2019 awaiting trial on federal sex trafficking charges.

Ghislaine Maxwell and Jeffrey Epstein smile in this undated photograph

Even after Epstein’s lenient plea deal in a prior case in 2008, Maxwell continued to rub elbows with rich and influential people. Photographs show her at VIP conferences, galas and other high-profile events alongside celebrities and other prominent public figures before her arrest in early 2020.

In her criminal case, Maxwell was sentenced to 20 years behind bars for grooming and sex trafficking Epstein’s victims.

She is appealing that conviction and has declined to comment on the document dump.


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