giuffre-maxwell
gov.uscourts.nysd.447706.1332.12
7 pg
…and states as follows:
STATEMENT OF CONFERRAL
The undersigned has conferred with counsel for Plaintiff, who stated that they do not
agree to the appointment of a special master to oversee Ms. Maxwell’s third deposition.
INTRODUCTION
Plaintiff has deposed…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.12
15 pg
…
3 A No. I -- she would have filled out a new
4 patient packet and showed up for a new patient
5 appointment for a particular reason. I reviewed it.
6
7
Jane Doe 2
8 Q Do you know…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…notes, letters, memoranda,
forms, books, magazines, resumes, notebooks, ledgers, journals, diaries, calendars, appointment
books, papers, agreements, contracts, invoices, analyses, transcripts, plaques, correspondence,
telegrams, drafts, data processing or computer diskettes and CD disks, tapes of any nature and
computer interpretations thereof…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.10
14 pg
…you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.25_1
4 pg
…
11 A. I don't ever recall paying her.
12 Q. Do you know what happened during
13 the massage appointments with Jeffrey Epstein
14 and Virginia Roberts?
15 MR. PAGLIUCA: Objection to the
16 form and foundation.
17 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.23
10 pg
…evidence whatsoever that Ms.
Giuffre was the child victim of any sexual abuse. As she testified at her deposition:
2
Q. Do you know what happened during the massage appointments with Jeffrey
Epstein and Virginia Roberts?
A. No.
Q…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…to two hours.” Sealed
Transcript, Nov. 10, 2016, at 34.
DISCUSSION
Defendant now moves for appointment of a special master, offering two arguments.
First, Defendant claims that she is concerned about “repetitive duplicative questioning” of
certain subjects. Mot. at 2…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…photographs, notes,
letters, memoranda, forms, books, magazines, resumes, notebooks, ledgers, journals,
diaries, calendars, appointment books, papers, agreements, contracts, invoices, analyses,
transcripts, plaques, correspondence, telegrams, drafts, data processing or computer
diskettes and CD disks, t…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…I recommended we meet at the
Palm Beach Gardens Mall in the food court area. She agreed and an
appointment was made for November 15 , 2005 at 5:00 pm at the food
court.
Investigations Continue.
~*************************NARRATIVE # 20 **************************
Reported…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…I recommended we meet at the
Palm Beach Gardens Mall in the food court area. She agreed and an
appointment was made for November 15 , 2005 at 5:00 pm at the food
court.
Investigations Continue.
~*************************NARRATIVE # 20 **************************
Reported…
giuffre-maxwell
1320-13
45 pg
…I recommended we meet at the
Palm Beach Gardens Mall in the food court area. She agreed and an
appointment was made for November 15 , 2005 at 5:00 pm at the food
court.
Investigations Continue.
~*************************NARRATIVE # 20 **************************
Reported…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.22_1
12 pg
…you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.10
15 pg
…1 - CONFIDENTIAL
2 know the ex t ent of their relat ions hip . But she
3 would schedule his appointments and handle clerical
4 th ings for him as far as I can see.
5 Q. All right .
6 And…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…drafted, this Interrogatory calls for
information clearly outside the relevancy of this lawsuit because it implicates her assistant
making work calls for her, scheduling appointments for her and her representatives making
“statements” in all manner of business capacities. Further, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.16_1
9 pg
…you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
…you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.17
12 pg
…you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job…
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 …
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