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.447706.1327.18
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.447706.1202.1_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.447706.356.0
17 pg
…As the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being “massage therapists.” See Complaint, DE1, at …
giuffre-maxwell
gov.uscourts.nysd.447706.1218.28
3 pg
…old ." According to the
women who claimed to have visited his
home, they were paid to give him erotic
massages despite their lack of
professional massage training.
I • -;
http://radaronline.com/photos/bill-clinton-jeffrey-epstein-teen-sex-claims-search…
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
…As the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being “massage therapists.” See Complaint, DE1, at …
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.447706.1327.17
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.447706.1137.3_1
7 pg
…with her
7 mother the entire time.
8 Q. So did you have - - did you give a
9 massage with Virginia Roberts and Mr. Epstein
10 during the first time Virginia Roberts was at
11 the West Palm Beach house…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.27_1
5 pg
…fair to say that other than
9 , you understood at the time that any of the
10 massage therapists that were being -- giving
11 massages at 358 El Brillo Way were over the age of
12 18; is that correct…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.2_2
4 pg
…continue to make your objections .
6 Q. Did you ever participate from the
7 time period of 1992 to 2 009, did you ever
8 participate in a massage with Jeffrey Epstein
9 and another female?
10 MR. PAGLIUCA: Objection…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.17
5 pg
…with
8 and Epstein. They went for a bike ride, but
9 had a massage, which Epstein walked in on
10 while she was getting a massage.
11 He asked her to turn over, expose her
12 breasts to him…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.22
5 pg
…meet with
and Epstein. They went for a bike ride, but -
9
10
11
- had a massage, which Epstein walked in on
while she was getting a massage.
He asked her to turn over, expose her
12 breasts to him…
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.447706.1199.25_1
4 pg
…
11 A. I don't ever recall paying her.
12 Q. Do you know what happened during
13 the massage appointments with Jeffrey Epstein
14 and Virginia Roberts?
15 MR. PAGLIUCA: Objection to the
16 form and foundation.
17 A…
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.447706.1137.5_2
4 pg
…cv-07433-LAP Document 1137-5 Filed 10/22/20 Page 4 of 4
Page 82
1 G Maxwell - Confidential
2 Q. Did you train Virginia on how to
3 recruit other girls to perform sexual
4 massages?
5 MR…
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
1320-3
6 pg
…I believe that I have read that ,
9 but I don 1 t have any memory of it.
10 Q. Did you ever tell Johanna that she
11 would get extra money if she provided Jeffrey
12 massages?
13 A…
Comments