giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
1320-37
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…custodian, location and general description of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.19
22 pg
…Yes, I do.
9,5*,1,$*,8))5(
$JUHQ%ODQGR&RXUW5HSRUWLQJ
Case 1:15-cv-07433-LAP 9LGHR,QF
Document 1320-19 Filed 01/03/24 Page 4 of 22
1 physical features of Ghislaine Maxwell…
giuffre-maxwell
1320-19
22 pg
…Yes, I do.
9,5*,1,$*,8))5(
$JUHQ%ODQGR&RXUW5HSRUWLQJ
Case 1:15-cv-07433-LAP 9LGHR,QF
Document 1320-19 Filed 01/03/24 Page 4 of 22
1 physical features of Ghislaine Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.13_1
23 pg
…
25 A Yes, I do.
9,5*,1,$ *,8))5(
$JUHQ %ODQGR &RXUW 5HSRUWLQJ 9LGHR ,QF
1 physical features of Ghislaine Maxwell?
2 A I can tell you that she had very large
3 natural breasts…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.9
10 pg
…money to bring her over;
14 however, they never called her to come.
15 Q. And then I believe you mentioned that one
16 of your physical fitness instructors, you brought a
17 physical fitness instructor; was that correct?
18 …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…18 instructor. She was a physical trainer.
19 And so I brought her over to the house,
20 and he told my friend Rachel that -- he said,
21 You see that girl over there laying by the
22 pool? She…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…18 instructor. She was a physical trainer.
19 And so I brought her over to the house,
20 and he told my friend Rachel that -- he said,
21 You see that girl over there laying by the
22 pool? She…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…of people to work for Mr. Epstein and
24 house so while while I still receive mail 24 hiring is one of my functions.
25 there, it's not my actual physical address. 25 Q. And when is the first…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…there, it's not my actual physical address.
Case 1:15-cv-07433-LAP Document 1307-5 Filed 08/25/23 Page 9 of 465
Page 8
1 G Maxwell - Confidential
2 It's in the process of being sold…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.26
10 pg
…money to bring her over;
14 however, they never called her to come.
15 Q. And then I believe you mentioned that one
16 of your physical fitness instructors, you brought a
17 physical fitness instructor; was that correct?
18 …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…there, it's not my actual physical address.
Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 9 of 465
Page 8
1 G Maxwell - Confidential
2 It's in the process of being sold…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.13
9 pg
…does not involve actual 3 many young females come over to his house every day?
4 physical or sexual contact with the victim in the 4 A No, sir.
5 presence of a victim who is less than sixteen years …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…owned that home?
19 A. As far as I knew, Epstein.
20 Q. Can you describe for me physically what --
21 A. Palatial. When you walk up, it looks like
22 a normal door to a townhouse, and when you…
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