giuffre-maxwell
gov.uscourts.nysd.447706.1256.7
14 pg
…However, your
13 own experts, cocounsel and staff may have
limited internal use of same with the
14 understanding that we agree to destroy your
realtime rough draft and/or any computerized
15 form, if any, and replace it with…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.13
9 pg
…It's also very easy to say uh-huh or huh-uh, 3 main house and then there's also a staff house on the
4 but it kind of looks the same on paper, so you can't do …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
…him to England to
20 Q. Rodriguez stated Epstein did not want to 20 introduce him to the royalty.
21 see or hear the staff when he was in the 21 Q. Is it's your understanding that Ghislaine
22 …
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…some as young as 12. A “statement of undisputed facts” filed by Scarola says
Epstein used his staff and his victims to recruit more victims, employing “a pyramid abuse scheme in which he paid
underage victims $200-$300 cash for…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.2
56 pg
…me that any
13 activities took place, that people were in
14 distress, either reported to me by the staff
15 or anyone else. I base my answer based on
16 that.
17 Q. Are you familiar with a person…
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…A. First, I was consulting and what I
22 did was I helped with decorating houses and
23 in hiring staff to help run those houses.
24 Q. Did your duties change over the
25 course of 1992 to 2009…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.11_3
23 pg
…A. First, I was consulting and what I
22 did was I helped with decorating houses and
23 in hiring staff to help run those houses.
24 Q. Did your duties change over the
25 course of 1992 to 2009…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.5
56 pg
…me that any
13 activities took place, that people were in
14 distress, either reported to me by the staff
15 or anyone else. I base my answer based on
16 that.
17 Q. Are you familiar with a person…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…in Florida. She was, with her husband, household staff for Epstein in the Palm Beach
home he shared with Defendant, and, it is anticipated, will corroborate many of the observations
of her husband about minor girls and massages inside of…
giuffre-maxwell
gov.uscourts.nysd.447706.55.21
69 pg
…of the maintenance 5 A. On and off, yes, in Fisher Island,
6 of the estate, payroll of the gardeners, 6 Florida.
7 scheduling staff and security, food, coordinating 7 Q. Fisher Island?
8 activities with the chef, and pilots…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…case. Other witnesses
have testified regarding Defendant’s involvement in recruiting females for sex under the cover of
a “massage.” During the investigation of Jeffrey Epstein, certain household staff was deposed.
Alfredo Rodriguez, who was Jeffrey Epstein’s household manager…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…certain household staff was deposed.
5
Case 1:15-cv-07433-LAP Document 1137-10 Filed 10/22/20 Page 6 of 10
-
6
Case 1:15-cv-07433-LAP Document 1137-10 Filed 10/22/20 Page…
giuffre-maxwell
1320-6
10 pg
…case. Other witnesses
have testified regarding Defendant’s involvement in recruiting females for sex under the cover of
a “massage.” During the investigation of Jeffrey Epstein, certain household staff was deposed.
Alfredo Rodriguez, who was Jeffrey Epstein’s household manager…
giuffre-maxwell
1320-5
56 pg
…me that any
13 activities took place, that people were in
14 distress, either reported to me by the staff
15 or anyone else. I base my answer based on
16 that.
17 Q. Are you familiar with a person…
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