giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…facilitated, and
contributed to Jeffrey Epstein's abuse of minor girls by, among
other things, helping Epstein to recruit, groom, and ultimately
abuse victims known to MAXWELL and Epstein to be under the age
of 18. The victims were as…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…former friends claim
Virginia Roberts claims she was recruited to Epstein's harem in 1999
Named Prince Andrew and Alan Dershowitz as men she had to 'service'
Her friends say there was no indication she was being held captive
Asked…
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.447706.1137.1_1_1_1
10 pg
…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, (DE 1). at~ 27…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…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, (DE 1), at …
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…princes and an American president, a power broker with
the darkest of secrets: He was also a pedophile, accused of recruiting dozens of underage girls into a sex-slave network, buying their
silence and moving along, although he has been…
giuffre-maxwell
1320-2
10 pg
…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, (DE 1). at 127…
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.447706.1320.2
10 pg
…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, (DE 1). at 127…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…other
witnesses’ accounts of what Defendant’s job was for Epstein.8
That other young females were similarly recruited by the Defendant is evidence that Ms.
Giuffre is telling the truth about her experiences – and thus direct evidence that Defendant
…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…Document 1256-11 Filed 05/03/22 Page 9 of 15
Case 1:15-cv-07433-LAP Document 1256-11 Filed 05/03/22 Page 10 of 15
recruited her and other young females for sex with Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
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.447706.1343.1
23 pg
…5 clarify the question. I don't understand
6 what you mean by female, I don't understand
7 what you mean by recruit. Please be more
8 clear and specific about what you are
9 suggesting.
10 Q. Are…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.27
8 pg
… And, as well, certain people that were
8 friends or girlfriends or assistants of Jeffrey
9 Epstein would recruit girls under the pretense of
10 giving a massage?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
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.447706.1320.8
12 pg
…is the most important person for
Ms. Giuffre to depose. It was Epstein who gave the directions to Maxwell to recruit Ms. Giuffre
and bring her to Epstein’s mansions to be sexually abused. At several points during her recent
…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.11_3
23 pg
…5 clarify the question. I don't understand
6 what you mean by female, I don't understand
7 what you mean by recruit. Please be more
8 clear and specific about what you are
9 suggesting.
10 Q. Are…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
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.447706.1320.6
10 pg
…anyone.” At trial,
1
Ms. Giuffre intends to strongly disprove Defendant’s false assertions and to demonstrate that
Defendant recruited Ms. Giuffre to be involved in massages of a sexual nature with Epstein.
To develop evidence to support her position…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…state of Colorado.
FACTUAL ALLEGATIONS
8. Virginia Giuffre became a victim of sex trafficking and repeated sexual abuse
after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Giuffre was under the age
of eighteen.
9. Between 1999 and 2002…
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