giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…L!n! will return "long," "link,"
"lane," "lone," etc.
(b) Multiple character wildcard example: a search for chil* will return "children,"
"chill," "chilling," etc.
(c) Mixed use ofwildcards: a search for L!n* will return "lines," "lining," "linty," etc.
Accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.13
13 pg
…n! will return "long," "link,"
"lane," "lone," etc.
(b) Multiple character wildcard example: a search for chil* will return "children,"
"chill," "chilling," etc.
(c) Mixed use of wildcards: a search for L!n* will return "lines," "lining," "linty," etc.
Accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…documents responsive to this Request, including things like mainstream newspapers,
magazines, videos, DVDs or other media or family photographs which contain depictions of
female children, including Maxwell herself as a child.
b. Maxwell’s Objections Fail, as the Request Seeks…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…any room I ever stayed in, nor were there any visible pictures of naked young
women. My children and grandchildren stayed in the rooms in question at Mr. Epstein’s home
during Christmas of 2005. I would never have allowed…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…the
Afflecks! Jennifer
Garner 'will join ex Ben
…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Joe Recarey (3 ½ hours). During Defendant’s deposition,
Defendant questioned the veracity of the Palm Beach Police report containing the accounts of the
numerous minor children who were also sexually abused by Jeffrey Epstein. Defendant referred
to at least…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…19 of an open area, correct?
20 A. Correct.
21 Q. You didn't observe any pictures of
22 neighborhood children when you were walking through
23 that area, did you?
24 A. I don't recall.
25 Q. That…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…phone numbers, dates of birth, children’s names, financial account
numbers, and social security numbers).
Request 22 (All Modeling Contracts Signed or Entered into By You):
Non-party Ransome provided testimony that she did very little modeling while in New…
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…17 Q. So your testimony is that during
18 the time you were working there, you did not
19 know that these minor children were being
20 abused in the home while you were there?
21 A. What I have…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…p. 35)
9
Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 14 of 28
! Maxwell called Johanna and the other girls her “children” when they were on a trip to the
USVI. (p…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…phone numbers, dates of birth, children’s names, financial account
numbers, and social security numbers).
Request 22 (All Modeling Contracts Signed or Entered into By You):
Non-party Ransome provided testimony that she did very little modeling while in New…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…including home addresses, email addresses, phone numbers, dates of
birth, children’s names, financial account numbers, and social security numbers).
Despite Ms. Ransome’s robust production, Defendant comes before this Court to seek
additional information solely for the purpose of…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…as a 14 year old, yet announce to the world that she “cried rape,”13 and to
humiliate her family (including three minor children) by publicizing she was the victim of
domestic abuse in 2015. As the Court saw during…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…any room I ever stayed in, nor were there any visible pictures of naked young
women. My children and grandchildren stayed in the rooms in question at Mr. Epstein’s home
during Christmas of 2005. I would never have allowed…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…. . . do you believe that Jeffrey Epstein abused any minor children?
A. Can you repeat the question please and break it down so it's more understandable.
Q. Now that you have the police report that I showed you this morning…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…second time?
8 A. Yes. That's when she called -- went to
9 bed and kissed us all on the head and called us her
10 children.
11 Q. Who were the other participants in that
12 session?
13 A. …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
…the girls in a
18 particular way?
19 A. At one point when we were in the islands,
20 we were all watching a movie and she called us her
21 children.
22 Q. Did anybody respond to that?
23 …
giuffre-maxwell
gov.uscourts.nysd.447706.1137.11_3
23 pg
…17 Q. So your testimony is that during
18 the time you were working there, you did not
19 know that these minor children were being
20 abused in the home while you were there?
21 A. What I have…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…Joe Recarey (3 ½ hours). During Defendant’s deposition,
Defendant questioned the veracity of the Palm Beach Police report containing the accounts of the
numerous minor children who were also sexually abused by Jeffrey Epstein. Defendant referred
to at least…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…Honor.
22 THE COURT: Oh, I'm sure.
23 MR. PAGLIUCA: I have two children that live here. It
24 is not a bad gig for me to come back.
25 THE COURT: Understood. I'll take them on submission.
…