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.447706.1330.6
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.447706.69.2
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.447706.1320.4
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.447706.1137.18_2
15 pg
…The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recrniting and abuse, and those who
observed the recrniting or the abuse.
_6 _ _
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
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.447706.1137.1_1_1_1
10 pg
…state of mind when she attacked Ms.
Giuffre's assertions as ·'entirely untrue." Ms. Giuffre intends to prove at trial that Defendant
knew full well the sexual purpose for which she was recruiting females - including underage
females like Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
15. -
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.
16. Carolyn Casey
…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…state of mind when she attacked Ms.
Giuffre’s assertions as “entirely untrue.” Ms. Giuffre intends to prove at trial that Defendant
knew full well the sexual purpose for which she was recruiting females – including underage
females like Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.17
6 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.447706.1320.21
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…
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