giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…*
9) virginia*
10) jenna*
11) jena*
12) genna*
13) andrew*
14) prince*
15) royal*
22) massage*
23) masseur*
24) therapist*
26) mindspring*
28) emmy*
29) taylor*
30) sara*
31) kellen*
32) kensington *
33) vikers*
34) dubin*
35) eva*
36) glen…
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.447706.1332.14
9 pg
…involving
Plaintiff, (c) with or involving underage females known to Epstein or who
Defendant believed or intended might become known to Epstein, or (d) involving
or including massage with individuals Defendant knew to be, or believed might
become, known to…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…the kitchen were searched and
yielded negative results .
Th~ kitchen was searched and taken into evidence was a phone message
book: that was located near a house phone.
North of the kitchen was an office room which contained a computer…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…the kitchen were searched and
yielded negative results .
Th~ kitchen was searched and taken into evidence was a phone message
book: that was located near a house phone.
North of the kitchen was an office room which contained a computer…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.8
6 pg
…allT erram arem ailsforotherw iseresponsivedocum entsasw ell .
3.W itnessnam es– You believethatsearchterm s124-341,w hicharew itnessnam esbrokenupintofirstand last
nam esfrom yourR ule26 list,relatetoyourR FP num ber5 (“ Alldocum entsrelatingtom assages… ” ).I
represented toyou thatIhavesearchedfortheterm s“ m assage…
giuffre-maxwell
1320-13
45 pg
…the kitchen were searched and
yielded negative results .
Th~ kitchen was searched and taken into evidence was a phone message
book: that was located near a house phone.
North of the kitchen was an office room which contained a computer…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…to her (RFP 27), her employment
(RFP 28), and any person to whom she gave a massage (RFP 29).
Ms. Maxwell conducted a thorough search of her email systems and her devices prior to
her production on February 8, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.30
6 pg
…allT erram arem ailsforotherw iseresponsivedocum entsasw ellas .
3.W itnessnam es– You believethatsearchterm s124-341,w hicharew itnessnam esbrokenupintofirstand last
nam esfrom yourR ule26 list,relatetoyourR FP num ber5 (“ Alldocum entsrelatingtom assages… ” ).I
represented toyou thatIhavesearchedfortheterm s“ m assage…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Deposition excerpts placing
Dershowitz in Epstein's home on numerous occasions and when girls were present; (5)
Deposition excerpts indicating Dershowitz received "a massage" at Epstein's home; (6) Portions
of an address book containing Dershowitz's name and contact…
giuffre-maxwell
gov.uscourts.nysd.447706.435.1
8 pg
…when, for example, household staff
19 were saying that Mr. Dershowitz was receiving massages.
20 And so, yes, I have 24 names in mind as
21 possible sexual abuse victims that Dershowitz may or may
22 not have abused. And…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…And he and Jeffrey and Ghislaine told
blokey jokes and the brunettes listened politely and giggled. After dinner I gave
Jeffrey an erotic massage. I don’t remember seeing Bill again on the trip but I
assume Ghislaine flew him…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
…Maxwell kept the
20 MR. CRITTON: Form to the last question, 20 names and telephone numbers of the girls who came
21 move to strike the answer as nonresponsive. 21 to do massages?
22 BY MS. EZELL: 22 A. Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…As a part of those
communications, on May 10, 2011, Plaintiff writes Churcher:
“Hello gorgeous, I hope this message comes to you on a bright, sunny day!!! I took your
advice about what to offer Sandra [a ghostwriter] and she…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…one of Epstein’s household employees, Juan Alessi, testified about the parade of
young “massage therapists” entering Epstein’s Palm Beach mansion, and that Ms. Giuffre was
one of the girls who came to Epstein’s mansion.8 Alessi also…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…with him; and
(4) she never gave anyone, including Accuser-23, a massage.
3
The indictment refers to the accusers as Minor Victim-1, Minor Victim-2, and Minor Victim-3.
We will refer to them as Accuser-1, Accuser…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
… And he identified the
11 document, identified names of individuals in the document,
12 young girls who came over to provide these massages. There's a
13 section in the directory that's called "Florida Massages" that
14 has numbers…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.29
5 pg
…I pick her
7 MR. BERGER: I would ask that U1e court 7 up from high school sometimes. But she was not a
8 reporter initial tJiat. 8 massage therapist. She will go for dinner. And
9 MS. EZELL: Sure…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…14) prince*
15) royal*
16) PA
17) JE
18) GM
19)
20)
21)
22)
23)
-AD
Jane Doe 2
GX
massage*
masseur*
24) therapist*
25) ellmax*
26) mindspring*
27) gmax*
28) emmy*
29) taylor*
30) sara*
31) kellen*
32) kensington…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…telephone, telecopies, e-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
3. "Defendant" shall mean the ddendant Ghislaine Maxwell and her employees,
representatives or agenls.
4. "Document" shall mean all v.:rit:ten and graphic matter…