giuffre-maxwell
gov.uscourts.nysd.447706.311.0
3 pg
…Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF VIRGINIA
GIUFFRE’S MOTION FOR FINDING OF CIVIL CONTEMPT AGAINST NADIA
MARCINKOVA FOR IGNORING SUBPOENA AND FOR ASSOCIATED SANCTIONS…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…11 together. Like I said, that they would all go out
12 to clubs to pick up girls and try and find them to
13 bring back for Jeffrey. And then she told me about
14 how, like I said…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…11 together. Like I said, that they would all go out
12 to clubs to pick up girls and try and find them to
13 bring back for Jeffrey. And then she told me about
14 how, like I said…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…happened when she approached you?
12 A. She asked me if I could tell her how to
13 find someone that would come and work at her house.
14 She wanted to know if there was, like, a bulletin
15 …
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
…11 together. Like I said, that they would all go out
12 to clubs to pick up girls and try and find them to
13 bring back for Jeffrey. And then she told me about
14 how, like I said…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.24
6 pg
… And on occasion, after -- in cleaning up
17 after a massage of Jeffrey Epstein or Ghislaine
18 Maxwell, did you have occasion to find vibrators or
19 sex toys that would be left out?
20 MR. PAGLIUSCA: Object to form…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.25
10 pg
…happened when she approached you?
12 A. She asked me if I could tell her how to
13 find someone that would come and work at her house.
14 She wanted to know if there was, like, a bulletin
15 …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
… 8 had some information, and then I look with
9 Q. Sorry? 9 my daughter and we couldn't find anything,
10 A. The staff house, the guest house. 10 …
giuffre-maxwell
gov.uscourts.nysd.447706.1307.2
56 pg
…14 hired pilots, I hired all sorts of people.
15 In the course and a very small part
16 of my job was from from time to time to find
17 adult professional massage therapists for
18 Jeffrey.
19 Q. …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.11
8 pg
…ma'am. 13 A. Yes, sir.
14 Q. And you did along with Louella find and 14 Q. Okay. How much did you pay her?
15 -- and you did also find sex toys and rnas…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…our representations during the March 21, 2016 meet and
confer phone call, we are working diligently to find information to supplement the below
information with regard to address and dates, and once that information is obtained, Plaintiff will
serve supplemental…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.29
5 pg
…Uh-huh. 20 A. Yeah, uh-huh.
21 Q. -- how often did be come? 21 Q. Did yon ever find any vibrators in that area?
22 A. He came pretty -- pretty often. l would says, 22 A. Yes. I told…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…ACTIVITY.
[ '.i.["7,~:::1 WENT ON TO TELL ME THAT SHE WAS HAVING HER PERIOD DURING THE ASSAULT
AND SHE REMEMBERS WAKING UP AND FINDING HER PANTS AROUND HER ANKLES AND
SHE HAD A FEMININE PAD INSIDE OF HER…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…I think this is squarely in the court's order, but if you instruct her not to
answer, you instruct her not to answer.
MR. PAGLIUCA: We'll find out.
Id. at pg. 184:14-185:6.
Q. “In 2005…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…SCHULTZ:
15 Q. Did the course of your investigation --
16 through the course of your investigation, did you
17 find that all 30 or 33 of the girls knew one
18 another?
19 MR. PAGLIUCA: Object to form and
20…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…15 In the course and a very small part 15 as a masseuse?
16 of my job was from from time to time to find 16 MR. PAGLIUCA: Object to the form
17 adult professional massage therapists for 17 and…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.15
6 pg
…going to
24 privilege. 24 invoke her Fifth Amendment privilege. The
25 MR. KUVIN: I'm just trying to find out. 25 question is compound and therefore ambiguous.
Page 98 Pag…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.27
8 pg
…16 When you went into the bedroom of Jeffrey
17 Epstein, everything was removed from the -- the
18 shelves, from the armoire.
19 Q. Did you find nude photographs of girls?
20 A. Yes.
21 Q. All right.
22 And…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…him?
21 employing you 7 21 A. No.
22 A. No, they said they' re going to find out 22 Q. It was through somebody else?
23 and obviously the first thing they did was talk to 23 A. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…14 hired pilots, I hired all sorts of people.
15 In the course and a very small part
16 of my job was from from time to time to find
17 adult professional massage therapists for
18 Jeffrey.
19 Q. …
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