giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…that’s something the judge can decide, but a question as to how much this young girl was
being paid for a “massage,” I think goes directly to the issue of sexual activity.
See Schultz Decl. at Composite Exhibit 7…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…sex-trafficking and serial molestation.
Epstein procured and molested no fewer than forty underage girls, some from other continents and as young as twelve, in a
trafficking ring that involved some of the most powerful people in America and around…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…wherein
he used his vast wealth and property holdings and a deliberately
opaque web of corporations and companies to transport young women
and girls to his privately-owned islands where they were held
captive and subject to severe and extensive…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…the age of 18 after being recruited by Ghislaine
Maxwell and Jeffrey Epstein. Ms. Giuffre has alleged that Defendant recruited her and other
young females, unexperienced in massage, for sex with Jeffrey Epstein by lying to them and
telling them…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…an interview with journalist
Sharon Churcher ("Churcher") which was published in two British
tabloids, described Maxwell's alleged role as someone who
recruited or facilitated the recruitment of young females for
sexual activity with Jeffrey Epstein ("Epstein"), that she,
Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…the age of 18 after being recruited by Ghislaine
Maxwell and Jeffrey Epstein. Ms. Giuffre has alleged that Defendant recruited her and other
young females, unexperienced in massage, for sex with Jeffrey Epstein by lying to them and
telling them…
giuffre-maxwell
gov.uscourts.nysd.447706.55.21
69 pg
…5 wasn't there. Correct? 5 A. And then we have a young lady who used to
6 A. Yes. 6 take care of the pool but I don't recall her name
7 Q. Let's take a day…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…claims. Ms. Giuffre stated that Defendant
recrnited her and other young females for sex with Jeffrey Epstein. The people she now seeks to
depose are all witnesses who can testify to Defendant working essentially as a madam for Jeffrey
Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…deposed.
Alfredo Rodriguez, who was Jeffrey Epstein’s household manager, testified that the Defendant
frequently stayed in Jeffrey Epstein’s home and assisted with bringing in young girls to act as
“masseuses” for Jeffrey Epstein.
Q. “Okay. Going back to…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…Giuffre of her right to jury trial borders on frivolous. Ms. Giuffre is a
courageous young woman who has come forward to reveal the broad dimensions of a sex
trafficking ring – a criminal conspiracy that involved Defendant. That fact, alone…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
…1 R. Rizzo - Confidential
2 Q. Did you learn whether your
3 perception was correct?
4 MR. PAGLIUCA: Same objection.
5 A. It was younger. Yes, I did.
6 Q. How old was this girl?
7 A. 15 years old…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…21
iii
Case 1:15-cv-07433-LAP Document 1256-16 Filed 05/03/22 Page 5 of 30
INTRODUCTION
As more and more witnesses come forward testifying about Defendant’s involvement in
the sexual abuse of young girls…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.10
13 pg
…17 to him?
18 A. No.
19 Q. What he wanted at his house was young high
20 school girls under the pretense of some massage?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 BY MR. EDWARDS
24…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…told about the
NPA.
16. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey
Epstein’s victims (other than Giuffre), filed a petition to enforce her rights under the Crime
Victims’ Rights Act…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…DocumentDocument 1090-6
279 Entered Filed Docket
on FLSD 07/30/20 Page 5 of Page
12/30/2014 10 4 of 13
(along with other young girls) to such powerful people were to ingratiate …
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…Roberts lodged in
Florida last week, The Mail on Sunday can publish the most complete story yet of how this young woman was
exploited by Epstein’s shuttered world of seedy sex and influence. … While fragments of her testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…D. at 64 (E.D.N.Y. 2012) (internal citations and quotations omitted) (denying motion to lift
21
confidentiality of report of policing failures surrounding the murder of a young mother).
“Consequently, in a major decision in this field, Martindell…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…her coming
forward. She has 3 young children and a husband and has concerns about
whether she is compromising their well-being .
I am a former investigative reporter for New York Magazine where my
colleagues included Nick Pileggi . I understand…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.25
12 pg
…to be?
21 A. Secretary I would say.
22 Q. Did she also schedule appointments for
23 these young females to come to Jeffrey Epstein's
24 house?
25 …
giuffre-maxwell
gov.uscourts.nysd.447706.1218.30
4 pg
…mother of her three children going around selling her
false stories of prostitution."
Dershowitz is an admitted long-time friend of Epstein's who frequented his homes at the time Roberts and
other young girls were in Epstein's employ…