giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 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.447706.1202.1_1
11 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.447706.1295.8
9 pg
…was there, and I saw it and heard it with all my senses. I saw Ghislaine call
another girl and she called me herself to go give Jeffrey Epstein a sexual massage.
Q. What do you mean by call? I…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…which are witness names broken up into first and last
names from your Rule 26 list, relate to your RFP number 5 (“All documents relating to massages…”). I
represented to you that I have searched for the terms “massage,”…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…2, 3, 4, 6, 17, 32 and 37)
x documents relating to various topics include massages (RFP 5 and 29), travel
records (RFPs 8, 9, 14 and 39), a civil deposition in 2010 (RFP 19), and Ms.
Maxwell’s professional…
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
gov.uscourts.nysd.447706.1328.17
6 pg
…Case 1:15-cv-07433-LAP Document 1328-17 Filed 01/05/24 Page 3 of 6
Page 166 Page 168
1 written down anywhere? 1 for now we'll call it a massage -- as well as
2 A. No…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…which are witness names broken up into first and last
names from your Rule 26 list, relate to your RFP number 5 (“All documents relating to massages…”). I
represented to you that I have searched for the terms “massage,”…
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.447706.1325.1
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.447706.1295.10
14 pg
… I saw Ghislaine call another
25 girl, and she called me herself, to go
Highly Confidential
Page 312
1 HIGHLY CONFIDENTIAL AEO
2 give Jeffrey Epstein a sexual massage.
3 Q. What do you mean by call? I
4…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…time, where she
was going to meet with and Epstein. They went for a bike ride, but had a
9
massage, which Epstein walked in on while she was getting a massage. He asked her
to turn over, expose…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…at 17:45 PM
To: Phi li p Barden, gmax
Subject: Fwd: Guardian
So this isn't getting better ... latest from our chums at The Guardian.
---------- Forwarded message----------
From: Jon Swaine
Date: Wednesday, January 21, 2015
Subject: Guardian
To:
Ross…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…sir. 1 Q. Okay. Do you recall on any occasion who
2 Q. The next page is a message in the upper 2 would travel with him to the Virgin Islands?
3 lelt dated January 13, 2005, from C.W…
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