giuffre-maxwell
gov.uscourts.nysd.447706.1328.14
7 pg
…Page 34
1 DAVID RODGERS
2 Q. -- is that right?
3 And is that -- is Ghislaine Maxwell
4 somebody that through the years 1995 through 2013
5 was somebody who flew very frequently?
6 A. What were the years again…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…wants to
publicize police reports concerning Ms. Giuffre - most of them from when she was a child, some
of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s
confidentiality designation is without merit…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…mile awayfrom me in Palm Beach," authorJames Patterson tells The Post. ln the 11 years since Epstein was
investigated and charged by the Palm Beach police department, ultimately copping a plea and serving 13 months on one charge of soliciting…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…Plaintiff clearly seeks to litigate her false and
malicious accusations of sexual abuse against Ms. Maxwell. For years, Ms. Maxwell has
suffered Plaintiff’s unabated and unfiltered character attacks in both the media and in thinly-
veiled press releases masquerading…
giuffre-maxwell
gov.uscourts.nysd.447706.59.0
5 pg
…privilege.
However, Ms. Giuffre is continuing to search for additional responsive documents.
Defendant propounded 57 requests for production (including subparts), with the date range spanning
18 years or longer. Accordingly, as this search goes on, the undersigned is aware that…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…24, 32, 33, 34, and 37.
Indeed, it is undisputed that Maxwell spent many years traveling with Ms. Giuffre. And, for
years thereafter, Maxwell continued her association with convicted sex offender Jeffrey Epstein.
Ms. Giuffre is entitled to those documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…establish, I was never in Mr. Epstein’s Palm Beach home, private
island, ranch or airplane during the two years that she was associated with Mr. Epstein. The
Palm Beach Police Department Report neither corroborates Ms. Giuffre’s false accusation…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
…as she
visits London
conference to make a
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…6 Q. How old was this girl?
7 A. 15 years old.
8 Q. What happens next when Ghislaine
9 Maxwell and Jeffrey Epstein and a 15-year-old
10 girl walk into Eva Anderson's home?
11 MR. PAGLIUCA…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…6 Q. How old was this girl?
7 A. 15 years old.
8 Q. What happens next when Ghislaine
9 Maxwell and Jeffrey Epstein and a 15-year-old
10 girl walk into Eva Anderson's home?
11 MR. PAGLIUCA…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…1307-4 Filed 08/25/23 Page 8 of 28
at the time she made the defamatory statement that it was untrue.
Additionally, to prove Ms. Giuffre’s allegations, that span multiple years, on multiple
continents, and multiple locations, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 6 of 161
Socialite Ghislaine Maxwell 'groped a 16-year-old girl
during a naked massage,' victims' lawyer says
dailymail.co.uk/news/article-8163681/Socialite-Ghislaine-Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…
17 A. Again, I don't understand what
18 female -- I am a 54 year old women.
19 Q. I'm not making it age, any age of a
20 female that you recruited to work for Mr.
21 Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.15
6 pg
…I don't remember. I don't remember the dates. 15 lawyer, I must invoke my Fifth Amendment
16 It was at least maybe ten years ago. 16 privilege.
17 Q. And you're how old now? 17 BY MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…Johanna Sjoberg, on May 18, 2016. Ms. Sjoberg testified that, while a twenty-
year-old college student with no massage training, Ms. Maxwell, a stranger to her, approached
her on her college campus, and told her she would hire Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…more significant evidence, including
photographic evidence and electronic communications, than Defendant has produced in the two years
she has been litigating this matter. Defendant has not produced a single document prior to 2009 and
not a single photograph, despite testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…distorted the legal system. . . . Why would he charge a person with a
sterling reputation for 50 years on the basis ofthe word alone of a woman who is
serial liar. . . If they just checked the records, they could have known…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…for sexual abuse, of
, respectively. Notably, was only 16 years old at the time: a familiar
yet still disturbing theme running through Defendant and Epstein’s lifestyle. Therefore, questions
relating to Defendant’s involvement with, knowledge of, and observations of…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.29
35 pg
…21 Q. Sure. When you're performing the
22 massages, can you tell me -- you said on occasion.
23 Over the five years that you worked for him, how
24 often did you perform massages naked?
25 A. Somewhere between…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.12
179 pg
…Ghislaine?
17 MS. MENNINGER: Objection, leading and
18 foundation.
19 THE WITNESS: I believe it was five years,
20 2001 to 2006.
21 BY MS. McCAWLEY:
22 Q. And how many massages did Epstein receive
23 per day on average…
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