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.447706.356.0
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
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.447706.1201.27
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.447706.1327.5
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.447706.562.1
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
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.447706.1137.5_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.447706.1320.21
15 pg
…testified that, when she was a twenty-
one-year-old college student, Defendant (not Jeffrey Epstein) recruited and hired her under the
pretext of being a personal assistant to provide sexual massages. As one example of this
testimony, Sjoberg testified…
giuffre-maxwell
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
1320-21
15 pg
…testified that, when she was a twenty-
one-year-old college student, Defendant (not Jeffrey Epstein) recruited and hired her under the
pretext of being a personal assistant to provide sexual massages. As one example of this
testimony, Sjoberg testified…
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