giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…LAP Document 1078-5 Filed 07/29/20 Page 6 of 161
Socialite Ghislaine Maxwell 'groped a 16-year-old girl
during a naked massage,' victims' lawyer says
dailymail.co.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-groped-16-year…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…and other physical evidence, or information of a similar
nature.
(b) During discovery, interrogatories other than those seeking information described
in paragraph (a) above may only be served (1) if they are a more practical method
of obtaining the information…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
…Nadia Macinkova, and various
other girls and guests he brought to the island.
3. During one ofmy visits to the island I met Ghislaine Maxwell. Watching her
interact with the other girls on the island, it became clear to me…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.9
10 pg
…Did you ever see the photo after it was
8 taken?
9 A. I did not.
10 Q. And Ms. Maxwell was present during the --
11 was Ms. Maxwell present during that?
12 A. Yes.
13 Q. What happened next…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…and other physical evidence, or information of a similar
nature.
(b) During discovery, interrogatories other than those seeking information described
in paragraph (a) above may only be served (1) if they are a more practical method
of obtaining the information…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.27
8 pg
…and everybody had an attorney, and I was
10 not going to be able to speak with them.
11 Q. Okay. During your investigation, what did
12 you learn in terms of Ghislane Maxwell's
13 involvement, if any?
14 …
giuffre-maxwell
gov.uscourts.nysd.447706.1200.17
5 pg
…form and
14 foundation.
15 THE WITNESS: was allegedly
16 dating Jeffrey Epstein at the time. And
17 and were roommates.
18 During that time, had met with
19 and went shopping with her at the Palm Beach
20 Mall…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.26
10 pg
…Did you ever see the photo after it was
8 taken?
9 A. I did not.
10 Q. And Ms. Maxwell was present during the --
11 was Ms. Maxwell present during that?
12 A. Yes.
13 Q. What happened next…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.22
5 pg
…form and
14 foundation.
15 THE WITNESS: was allegedly
16
17
dating Jeffrey Epstein at the time.
and
- were roommates.
And
-
18
19
20
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…and other physical evidence, or information of a similar
nature.
(b) During discovery, interrogatories other than those seeking information described
in paragraph (a) above may only be served (1) if they are a more practical method
of obtaining the information…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…and other physical evidence, or information of a similar
nature.
(b) During discovery, interrogatories other than those seeking information described
in paragraph (a) above may only be served (1) if they are a more practical method
of obtaining the information…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
… 3 Google, I guess you Googled Prince Andrew and Bill
4 Q. It says, during the sworn taped statement 4 Clinton. Why would you pick those names, were
5 Mr. Rodriguez stated he was employed by Jeffrey 5 they associated…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…recall.” For example, when
faced with the police report which contains statements from approximately thirty (30) different
victims during a time frame which the Defendant acknowledges she was actively working for
Epstein at his various homes, Defendant challenged the veracity…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.23
10 pg
…Did you ever see the photo after it was
8 taken?
9 A. I did not.
10 Q. And Ms. Maxwell was present during the --
11 was Ms. Maxwell present during that?
12 A. Yes.
13 Q. What happened next…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…recall.” For example, when
faced with the police report which contains statements from approximately thirty (30) different
victims during a time frame which the Defendant acknowledges she was actively working for
Epstein at his various homes, Defendant challenged the veracity…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…and other physical evidence, or information of a similar
nature.
(b) During discovery, interrogatories other than those seeking information described
in paragraph (a) above may only be served (1) if they are a more practical method
of obtaining the information…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.4
4 pg
…at this time
Mr. Figueroa may have knowledge concerning matters at issue, including
Plaintiff's activities during 1996- 2002.
9. Louis Freeh
Address unknown at this time
Jane Doe 2
Mr. Freeh may have knowledge concerning travel of Bill Clinton.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.16
8 pg
…fo1111.
12 Q And E.W. is somebody you observed nt 12 A Fifth.
13 Jeffrey Epstein's house on more than 100 13 Q During your lnternction with nndernge
14 occasions between 2002 and 2005, n time period 14…
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