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.447706.1199.22_1
10 pg
…21 Page 3 of 10
Case 1:15-cv-07433-LAP Document 1199-22 Filed 01/27/21 Page 4 of 10
Q. Do you know what happened during the massage appointments with Jeffrey
Epstein and Virginia Roberts?
A…
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.447706.1219.29
24 pg
…affidavits, statements,
summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income
statements, statistical records, desk calendars, appointment books, lists, tabulations, sound
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries,
computer printouts,…
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.447706.1325.10
13 pg
…1 Jane Doe 2
2 know the extent of their relationship. But she
3 would schedule his appointments and handle clerical
4 things for him as far as I can see.
5 Q. All right.
6 And when you first…
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.447706.1328.28
24 pg
…affidavits, statements,
summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income
statements, statistical records, desk calendars, appointment books, lists, tabulations, sound
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries,
computer printouts,…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…Excerpts from July 22, 2016, Deposition of Ghislaine
Maxwell at 174:2-4.
an 11:00 appointment. There were other individuals that had called during that
day.
Q. And when you would -- when you would see females…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…affidavits, statements,
summaries, opinions, tests, experiments, analysis. evaluations, journals, balance sheets, income
statements, statistical records, desk calendars, appointment books, l ists, tabulations, sound.
recordings, data prot:essing input or output, microfilms, film negatives, film slides, memory
sticks, checks, stat…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…Excerpts from July 22, 2016, Deposition of Ghislaine
Maxwell at 174:2-4.
an 11:00 appointment. There were other individuals that had called during that
day.
Q. And when you would -- when you would see females…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…affidavits, statements,
summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income
statements, statistical records, desk calendars, appointment books, lists, tabulations, sound
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries,
computer printouts,…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…affidavits, statements,
sllmmaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income
statements, statistical records, desk calendars, appointment books, lists, tabulations, sound
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries,
computer print…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…with
women other than what you have testified to already? Id. at 89:24-90:3.
an 11:00 appointment. There were other individuals that had called during that
day.
Q. And when you would -- when you would see females…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…Excerpts from July 22, 2016, Deposition of Ghislaine
Maxwell at 174:2-4.
an 11:00 appointment. There were other individuals that had called during that
day.
Q. And when you would -- when you would see females…
giuffre-maxwell
1320-32
27 pg
…affidavits, statements,
summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income
statements, statistical records, desk calendars, appointment books, lists, tabulations, sound
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries,
computer printouts,…
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…
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