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
gov.uscourts.nysd.447706.1256.11
15 pg
…Jeffrey Epstein. The people she now seeks to
depose are all witnesses who can testify to Defendant working essentially as a madam for Jeffrey
Epstein, recruiting young females for Epstein, or corroborate other important aspects of her
statements. The fact…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…Epstein’s victims.
The book, from which we are summarising stories in The Mail on Sunday, details
Maxwell’s alleged role in recruiting and grooming underage girls for Epstein. According to
some accounts, she was even involved in some of…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
… and
(5) knowingly, in and affecting interstate and foreign commerce. recruiting.
enticing. and obtaining by any means a person, knowing that tho person had
not attained lhc age of 18 years and would be caused to cngaee in a
commercial…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…therapist and they would send to the house. So it was
referrals.”
In response to Ms. Giuffre’s assertions about Defendant recruiting of females for sexual
purposes, Defendant has made the sweeping claim that Ms. Giuffre’s assertions are “entirely
…
giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…Case 1:15-cv-07433-RWS Document 315 Filed 07/29/16 Page 3 of 17
In response to Ms. Giuffre’s assertions about Defendant recruiting of females for sexual
purposes, Defendant has made the sweeping claim that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…therapist and they would send to the house. So it was
referrals.”
In response to Ms. Giuffre’s assertions about Defendant recruiting of females for sexual
purposes, Defendant has made the sweeping claim that Ms. Giuffre’s assertions are “entirely
…
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
…Case 1:15-cv-07433-LAP Document 315 Filed 07/29/16 Page 3 of 17
In response to Ms. Giuffre’s assertions about Defendant recruiting of females for sexual
purposes, Defendant has made the sweeping claim that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…groomed her to perform sexual acts for Jeffrey
Epstein. She also performed other services for Jeffrey Epstein, including recruiting and
scheduling girls to perform “massages” for Epstein. The household staff testified that they took
instructions from Maxwell. See McCawley Decl…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…Jeffrey Epstein’s sexual trafficking
conduct.
12. Dana Burns
Address unknown at this time.
Telephone number unknown at this time
Worked for Ghislaine Maxwell and has information about Ghislaine Maxwell’s
recruiting of girls for Jeffrey Epstein.
13. Alyson Chambers
…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.2
56 pg
…
25 A. Probably in the early '90s.
Case 1:15-cv-07433-LAP Document 1307-2 Filed 08/25/23 Page 45 of 56
Questions About Recruiting Girls, an Underage Girl in London,
and Foreign Girls
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…in a defamation case against British socialite Ghislaine
Maxwell for saying that Roberts made “obvious lies” when accusing Maxwell of recruiting Roberts to
become a victim of sex trafficking between 1999 to 2002.
“Alan Dershowitz is not a party to…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.4
17 pg
…6 A. You just heard my counsel.
7 Q. Have you ever said to anybody that
8 recruiting other girls to perform sexual
9 massages for Jeffrey Epstein takes the
10 pressure off you?
11 MR . PAGLIUCA: Object to the…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…therapist and they would send to the house. So it was
referrals.”
In response to Ms. Giuffre’s assertions about Defendant recruiting of females for sexual
purposes, Defendant has made the sweeping claim that Ms. Giuffre’s assertions are “entirely
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…who else could we ask
20 better themselves when they're in a group 20 these questions?
21 than going by themselves, but I don't know 21 A. Sarah.
22 somebody recruiting. 22 Q. Sarah Kellen?
23 BY MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.1
26 pg
…your going over to Jeffrey Epstein
21 house primary it was just you and Virginia?
22 A Yeah,.
23 Q At someintp point in time Virginia starts
24 recruiting other girls to go to the house; is that
25 right…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who
observed the recruiting or the abuse. For example…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who
observed the recruiting or the abuse. For example…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.5
56 pg
…
25 A. Probably in the early '90s.
MAGNA& LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 45 of 56
Questions About Recruiting Girls, an Underage Girl in London,
and Foreign Girls…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.
9. Employment records obtained from ET Employment Training and Recruiting
Australia.
10. Education records obtained from Royal Palm Beach Community High School
and Forest Hills High School.
11. Documents received…
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