giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…relate to your RFP number 5 (“All documents relating to massages…”). I
represented to you that I have searched for the terms “massage,” “masseur,” “therapy” etc. as you requested,
but you would still like me to search a subset…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…During the deposition, the Non-Party testified that they had undergone extensive
therapy to overcome the trauma and did not want to be involved in the proceedings at all. Doe
#84’s name was mentioned in some of the sealed…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.29
5 pg
…I pick her
7 MR. BERGER: I would ask that U1e court 7 up from high school sometimes. But she was not a
8 reporter initial tJiat. 8 massage therapist. She will go for dinner. And
9 MS. EZELL: Sure…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.10
15 pg
…nde r stand what
20 you and your lawyer have said here t oday , yo u have
21 been i nvolved in some n umber of years of therapy , i n
22 which the purpose -- part o f t he…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Maxwell already had
run the Plaintiff’s proposed terms related to massages, including “massage,” “masseuse,”
“masseur,” and “therapy.” In effect, Plaintiff proposed search terms sought to expand her
discovery requests from communications with a discrete set of individuals to all…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.42
5 pg
…I pick her
7 MR. BERGER: I would ask that the court 7 up from high school sometimes. But she was not a
8 repo1ter initial that. 8 massage therapist. She will go for dinner. And
9 MS. EZELL: Sure…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…of confidentiality under the Protective Order. During the deposition,
this Doe testified that she had undergone extensive therapy to overcome the trauma and did not
want to be involved in the proceedings at all. The Second Circuit sua sponte redacted…
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.447706.1325.10
13 pg
…do not know.
13 MR. PAGLIUCA: Object to form.
14 BY MR. EDWARDS:
15 Q. Were you going out to look for a massage
16 therapist, a professional massage therapist to bring
17 to him?
18 A. No.
19 Q…
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.447706.1331.7
21 pg
…has little or no memory
of most or all of the events surrounding the time she knew Mr. Epstein, and specifically testified
that she is in therapy for the purpose of repressing any memories concerning Mr. Epstein. See
Menninger Decl…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…asseur,
” “ therapy” etc.asyou requested,
butyou w ould stilllikem etosearchasubsetof124-341 surnam esnam esforallcom m unicationsw ithcertain
w itnessesthatyou believerelateto“ m assages.” IsaidIw ould lookatyourlist,w henyou send it,and evalu…
giuffre-maxwell
gov.uscourts.nysd.447706.55.12
21 pg
…C., J.
24 A. Yes. 24 There were also massage therapists from
25 Q. How -- and why did you become aware of that? 25 Europe. They sometimes travel with him in the plane.
…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…Maxwell already had
run the Plaintiff’s proposed terms related to massages, including “massage,” “masseuse,”
“masseur,” and “therapy.” In effect, Plaintiff proposed search terms sought to expand her
discovery requests from communications with a discrete set of individuals to all…
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.447706.1325.11
18 pg
…whether there was actually
17 intercourse, all of that was documented and was
18 asked whether they brought anyone to the home,
19 whether they had any formal training in massage
20 therapy, and once -- once additional victims
21 were…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…*
9) virginia*
10) jenna*
11) jena*
12) genna*
13) andrew*
14) prince*
15) royal*
22) massage*
23) masseur*
24) therapist*
26) mindspring*
28) emmy*
29) taylor*
30) sara*
31) kellen*
32) kensington *
33) vikers*
34) dubin*
35) eva*
36) glen…
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.447706.1219.24
6 pg
…of Florida.
Case 1:15-cv-07433-LAP Document 1219-24 Filed 07/15/21 Page 3 of 6
Page 28
1 JOHN ALESSI
2 Q. And where did the massage therapists --
3 where did they come from?
4 A…
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