EFTA00794269.pdf
GHISLAINE MAXWELL - DEPOSITION OUTLINE
Recruitment
1. In the late summer or early fall of 2006, did you tell to recruit a young
woman to perform sexual acts on Jeffrey Epstein's behalf?
2. In the summer or fall of 2006, did tell you that she had recruited a young
woman by the name of to perform sexual acts on Jeffrey Epstein's behalf?
3. Did you ever pay to recruit females for Jeffrey Epstein?
4. Did you ever see Jeffrey Epstein pay to recruit females for him?
5. Did you recruit young, including underage, females for Jeffrey Epstein?
6. Did Jeffrey Epstein tell you to recruit young, including underage, females for him?
7. Did you oversee and train other recruiters on how best to recruit females for sex for Jeffrey
Epstein?
8. Did you ever promise young women money, shelter, transportation, gifts, employment,
admission into educational institutions, education tuition, protection or other things in
exchange for sex or sexual activities?
9. Did you ever hear Jeffrey Epstein promise young women money, shelter, transportation,
gifts, employment, admission into educational institutions, education tuition, protection or
other things in exchange for sex or sexual activities?
10. Did you ever demand that recruit other females to participate in sexual acts
with Jeffrey Epstein?
II. Did you ever hear Jeffrey Epstein demand that recruit other females to
participate in sexual acts with him or others?
12. Did you recruit for the purpose of sex trafficking?
Threaten/Coerce/Fraudulently Promise
13. In February, March or April of 2007, did you threaten that she had to
perform sex acts at your direction?
14. To your knowledge, in Februa , March or April of 2007, did Jeffrey Epstein or anyone
acting on his behalf threaten that she had to perform sex acts at Jeffrey
Epstein's direction?
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15. In February, March or April of 2007, did you ever threaten with physical
force if she did not provide body massages to Jeffrey Epstein?
16. In February, March or April of 2007, did you ever threaten with physical
force if she did not have sex with Jeffrey Epstein?
17. Did you ever coerce, threaten or intimidate any young women to perform sex or sexual
activities for Jeffrey Epstein?
18. Did Jeffrey Epstein ever tell you to coerce, threaten or intimidate any young women to
perform sex or sexual activities for him or others?
19. Did you ever hear Jeffrey Epstein coerce, threaten or intimidate any young women to
perform sex or sexual activities for him or others?
20. Did you ever hear Jeffrey Epstein threaten with physical harm?
21. Did you ever physically restrain
22. Did you ever see Jeffrey Epstein restrain =I '?
23. Did you promise that in exchange for performing sexual acts for Jeffrey
Epstein or others that you would assist her in gaining admission to the Fashion Institute of
Technology?
24. Did you ever hear Jeffrey Epstein promise that in exchange for performing
sexual acts for him or others that he would assist her in gaining admission to the Fashion
Institute of Technology?
Weight
25. In February, March and April of 2007, did you tell that she had to lose
weight?
26. To our knowledge, in February, March and April of 2007, did Jeffrey Epstein tell
that she had to lose weight?
27. Did need to lose weight to pursue her modeling career?
Passport/Travel
28. At any time in 2006 or 2007, did you seize any passport belonging to
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29. To your knowled e, at an time in 2006 or 2007, did Jeffrey Epstein seize any passport
belonging to
30. To your knowledge, at any time in 2006 or 2007, did Jeffrey Epstein instruct anyone to
seize any passport belonging to
31. Did you take possession or control of passport to induce or coerce her
into performing sexual acts with Jeffrey Epstein and others?
32. Did you ever see Jeffrey Epstein take possession or control of passport to
induce or coerce her into performing sexual acts for him and others?
33. Did you ever stop from leaving New York when she wanted?
34. Did you ever stop from returning to New York when she wanted?
35. Was restricted from leaving New York at any time?
36. Did you ever inhibit from traveling within the USA or outside of it in any
way?
Phone Calls to South Africa
37. While • was in South Africa in February of 2007, did you ever call her
parents?
38. Did you speak to her parents?
39. Did you promise her parents that if she came back to the United States that you would get
her modeling contracts?
40. Did you promise her parents that if she came back to the United States that you would get
her into the Fashion Institute of Technology?
Sex Trafficking/Commercial Sex Acts
41. Did perform sexual acts at your direction or on your behalf?
42. Did perform sexual acts at Jeffrey Epstein's direction or on his behalf?
43. In 2006 and 2007, did you provide with money or other things of value in
exchange for performing sexual acts?
44. To your knowledge, in 2006 and 2007, did Jeffrey Epstein provide with
money or other things of value in exchange for performing sexual acts?
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45. Did you, in February, March and April of 2007, provide with money and
other things of value in exchange for performing sexual acts?
46. To our knowledge, did Jeffrey Epstein, in February, March and April of 2007, provide
with money or other things of value in exchange for performing sexual
acts?
47. In February, March and April of 2007, did you instruct to perform sex acts
with persons other than yourself?
48. To our knowledge, in February, March and April of 2007, did Jeffrey Epstein instruct
to perform sex act with persons other than himself?
49. In February, March and April of 2007, did you have sex with
50. To your knowled e, in February, March and April of 2007, did Jeffrey Epstein have sex
with
51. In February, March and April of 2007, were there other young women, other than
who you were paying or providing things of value in exchange for the
performance of sex acts?
52. To your knowled e, in February, March and April of 2007, were there other young women,
other than who Jeffrey Epstein was paying or providing things of value in
exchange for the performance of sex acts?
53. In February, March and April of 2007, did you employ young women, other than
to perform sex acts?
54. To your knowledge, in Febru , March and April of 2007, did Jeffrey Epstein employ
young women, other than to perform sex acts?
55. To your knowledge, in February, March and April of 2007, were there females under the
age of 18 who performed sex acts at Jeffrey Epstein's residence in Florida?
56. To your knowledge, in February, March and April of 2007, were there females under the
age of 18 who performed sex acts at Jeffrey Epstein's residence in New York City for
people other than Jeffrey Epstein?
57. To your knowledge, in February, March and April of 2007, were there females under the
age of 18 who performed sex acts at Jeffrey Epstein's residence in Florida for people other
than Jeffrey Epstein?
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58. To your knowledge, in February, March and April of 2007, were there females under the
age of 18 who Jeffrey Epstein directed to perform sex acts at his residence in New York
City for people other than himself?
59. In February, March and April of 2007, were there females under the age of 18 who you
directed to perform sex acts at Jeffrey Epstein's residence in Florida for people other than
Jeffrey Epstein?
60. To your knowledge, in February, March and April of 2007, were there females under the
age of 18 who Jeffrey Epstein directed to perform sex acts at his residence in Florida for
people other than himself?
61. To your knowledge, did Jeffrey Epstein participate in a sex trafficking enterprise?
62. To your knowledge, does Jeffrey Epstein provide females under the age of 18 to his friends
for sexual purposes in order to secure social, business and other contacts as well as other
things of value?
63. Has Jeffrey Epstein ever asked you to provide a female under the age of 18 to his friends for
sexual purposes in order to secure social, business and other contacts as well as other things
of value?
64. To your knowledge, does Jeffrey Epstein provide females over the age of 18 to his friends
for sexual purposes in order to secure social, business and other contacts as well as other
things of value?
65. Has Jeffrey Epstein ever asked you to provide a female over the age of 18 to his friends for
sexual purposes in order to secure social, business and other contacts as well as other things
of value?
66. Did you ever conspire with the other named Defendants to force to have
sex with Jeffrey Epstein?
67. Did you ever conspire with the other named Defendants to coerce to have
sex with Jeffrey Epstein?
68. Did you ever conspire with the other named Defendants to fraudulently promise
either an education or a modeling contract, so she would have sex with Jeffrey
Epstein?
69. Did you ever sex traffic ==.?
70. Were you ever involved in a scheme to make engage in commercial sex
acts?
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Recruitment
1. In the late summer or early fall of 2006, did you tell to recruit a young
woman to perform sexual acts on Jeffrey Epstein's behalf?
2. In the summer or fall of 2006, did tell you that she had recruited a young
woman by the name of to perform sexual acts on Jeffrey Epstein's behalf?
3. Did you ever pay to recruit females for Jeffrey Epstein?
4. Did you ever see Jeffrey Epstein pay to recruit females for him?
5. Did you recruit young, including underage, females for Jeffrey Epstein?
6. Did Jeffrey Epstein tell you to recruit young, including underage, females for him?
7. Did you oversee and train other recruiters on how best to recruit females for sex for Jeffrey
Epstein?
8. Did you ever promise young women money, shelter, transportation, gifts, employment,
admission into educational institutions, education tuition, protection or other things in
exchange for sex or sexual activities?
9. Did you ever hear Jeffrey Epstein promise young women money, shelter, transportation,
gifts, employment, admission into educational institutions, education tuition, protection or
other things in exchange for sex or sexual activities?
10. Did you ever demand that recruit other females to participate in sexual acts
with Jeffrey Epstein?
II. Did you ever hear Jeffrey Epstein demand that recruit other females to
participate in sexual acts with him or others?
12. Did you recruit for the purpose of sex trafficking?
Threaten/Coerce/Fraudulently Promise
13. In February, March or April of 2007, did you threaten that she had to
perform sex acts at your direction?
14. To your knowledge, in Februa , March or April of 2007, did Jeffrey Epstein or anyone
acting on his behalf threaten that she had to perform sex acts at Jeffrey
Epstein's direction?
EFTA00794269
15. In February, March or April of 2007, did you ever threaten with physical
force if she did not provide body massages to Jeffrey Epstein?
16. In February, March or April of 2007, did you ever threaten with physical
force if she did not have sex with Jeffrey Epstein?
17. Did you ever coerce, threaten or intimidate any young women to perform sex or sexual
activities for Jeffrey Epstein?
18. Did Jeffrey Epstein ever tell you to coerce, threaten or intimidate any young women to
perform sex or sexual activities for him or others?
19. Did you ever hear Jeffrey Epstein coerce, threaten or intimidate any young women to
perform sex or sexual activities for him or others?
20. Did you ever hear Jeffrey Epstein threaten with physical harm?
21. Did you ever physically restrain
22. Did you ever see Jeffrey Epstein restrain =I '?
23. Did you promise that in exchange for performing sexual acts for Jeffrey
Epstein or others that you would assist her in gaining admission to the Fashion Institute of
Technology?
24. Did you ever hear Jeffrey Epstein promise that in exchange for performing
sexual acts for him or others that he would assist her in gaining admission to the Fashion
Institute of Technology?
Weight
25. In February, March and April of 2007, did you tell that she had to lose
weight?
26. To our knowledge, in February, March and April of 2007, did Jeffrey Epstein tell
that she had to lose weight?
27. Did need to lose weight to pursue her modeling career?
Passport/Travel
28. At any time in 2006 or 2007, did you seize any passport belonging to
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29. To your knowled e, at an time in 2006 or 2007, did Jeffrey Epstein seize any passport
belonging to
30. To your knowledge, at any time in 2006 or 2007, did Jeffrey Epstein instruct anyone to
seize any passport belonging to
31. Did you take possession or control of passport to induce or coerce her
into performing sexual acts with Jeffrey Epstein and others?
32. Did you ever see Jeffrey Epstein take possession or control of passport to
induce or coerce her into performing sexual acts for him and others?
33. Did you ever stop from leaving New York when she wanted?
34. Did you ever stop from returning to New York when she wanted?
35. Was restricted from leaving New York at any time?
36. Did you ever inhibit from traveling within the USA or outside of it in any
way?
Phone Calls to South Africa
37. While • was in South Africa in February of 2007, did you ever call her
parents?
38. Did you speak to her parents?
39. Did you promise her parents that if she came back to the United States that you would get
her modeling contracts?
40. Did you promise her parents that if she came back to the United States that you would get
her into the Fashion Institute of Technology?
Sex Trafficking/Commercial Sex Acts
41. Did perform sexual acts at your direction or on your behalf?
42. Did perform sexual acts at Jeffrey Epstein's direction or on his behalf?
43. In 2006 and 2007, did you provide with money or other things of value in
exchange for performing sexual acts?
44. To your knowledge, in 2006 and 2007, did Jeffrey Epstein provide with
money or other things of value in exchange for performing sexual acts?
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45. Did you, in February, March and April of 2007, provide with money and
other things of value in exchange for performing sexual acts?
46. To our knowledge, did Jeffrey Epstein, in February, March and April of 2007, provide
with money or other things of value in exchange for performing sexual
acts?
47. In February, March and April of 2007, did you instruct to perform sex acts
with persons other than yourself?
48. To our knowledge, in February, March and April of 2007, did Jeffrey Epstein instruct
to perform sex act with persons other than himself?
49. In February, March and April of 2007, did you have sex with
50. To your knowled e, in February, March and April of 2007, did Jeffrey Epstein have sex
with
51. In February, March and April of 2007, were there other young women, other than
who you were paying or providing things of value in exchange for the
performance of sex acts?
52. To your knowled e, in February, March and April of 2007, were there other young women,
other than who Jeffrey Epstein was paying or providing things of value in
exchange for the performance of sex acts?
53. In February, March and April of 2007, did you employ young women, other than
to perform sex acts?
54. To your knowledge, in Febru , March and April of 2007, did Jeffrey Epstein employ
young women, other than to perform sex acts?
55. To your knowledge, in February, March and April of 2007, were there females under the
age of 18 who performed sex acts at Jeffrey Epstein's residence in Florida?
56. To your knowledge, in February, March and April of 2007, were there females under the
age of 18 who performed sex acts at Jeffrey Epstein's residence in New York City for
people other than Jeffrey Epstein?
57. To your knowledge, in February, March and April of 2007, were there females under the
age of 18 who performed sex acts at Jeffrey Epstein's residence in Florida for people other
than Jeffrey Epstein?
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58. To your knowledge, in February, March and April of 2007, were there females under the
age of 18 who Jeffrey Epstein directed to perform sex acts at his residence in New York
City for people other than himself?
59. In February, March and April of 2007, were there females under the age of 18 who you
directed to perform sex acts at Jeffrey Epstein's residence in Florida for people other than
Jeffrey Epstein?
60. To your knowledge, in February, March and April of 2007, were there females under the
age of 18 who Jeffrey Epstein directed to perform sex acts at his residence in Florida for
people other than himself?
61. To your knowledge, did Jeffrey Epstein participate in a sex trafficking enterprise?
62. To your knowledge, does Jeffrey Epstein provide females under the age of 18 to his friends
for sexual purposes in order to secure social, business and other contacts as well as other
things of value?
63. Has Jeffrey Epstein ever asked you to provide a female under the age of 18 to his friends for
sexual purposes in order to secure social, business and other contacts as well as other things
of value?
64. To your knowledge, does Jeffrey Epstein provide females over the age of 18 to his friends
for sexual purposes in order to secure social, business and other contacts as well as other
things of value?
65. Has Jeffrey Epstein ever asked you to provide a female over the age of 18 to his friends for
sexual purposes in order to secure social, business and other contacts as well as other things
of value?
66. Did you ever conspire with the other named Defendants to force to have
sex with Jeffrey Epstein?
67. Did you ever conspire with the other named Defendants to coerce to have
sex with Jeffrey Epstein?
68. Did you ever conspire with the other named Defendants to fraudulently promise
either an education or a modeling contract, so she would have sex with Jeffrey
Epstein?
69. Did you ever sex traffic ==.?
70. Were you ever involved in a scheme to make engage in commercial sex
acts?
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