Epstein Docs

Case 18-2868, Document 271, 08/09/2019, 2628203, Page1 of 1
UNITED STATES COURT OF APPEALS

FOR THE
SECOND CIRCUIT
_____________________________________________
At a stated term of the United States Court of Appeals for the Second Circuit, held at the
Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the
9th day of August, two thousand nineteen.
________________________________________
Julie Brown, Miami Herald Media Company,
Intervenors - Appellants.
v. ORDER
Docket No: 18-2868
Ghislaine Maxwell,
Defendant - Appellee,
v.
Virginia L. Giuffre,
Plaintiff - Appellee.
_______________________________________
Appellee, Ghislaine Maxwell, filed a petition for panel rehearing, or, in the alternative, for
rehearing en banc. The panel that determined the appeal has considered the request for panel
rehearing, and the active members of the Court have considered the request for rehearing en banc.
IT IS HEREBY ORDERED that the petition is denied.
FOR THE COURT:

Catherine O'Hagan Wolfe, Clerk
Selected docket entries for case 18−2868
Generated: 08/09/2019 10:13:24
Filed Document Description Page Docket Text

08/09/2019 272 Order FILED 2 ORDER, dated 08/09/2019, directing the Clerk to issue the
mandate forthwith, by JAC, RSP, CFD, FILED.[2628208]
[18−2868]
08/09/2019 273 JUDGMENT MANDATE, ISSUED.[2628218] [18−2868]
273 Judgment Mandate ISSUED 4
273 Supporting Document 5
273 Supporting Document 30
08/09/2019 275 UNSEALED SUMMARY 31 UNSEALED SUMMARY JUDGMENT RECORD,
JUDGMENT RECORD, appendix 1 of 13 , pursuant to the Court's decision dated
DOCKETED July 3, 2019, DOCKETED. [2628223] [18−2868]

FOR THE
SECOND CIRCUIT
At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the
9th day of August, two thousand nineteen.
Before: José A. Cabranes,

Rosemary S. Pooler,
Christopher F. Droney,
Circuit Judges.
________________________________

ORDER
Intervenors - Appellants,
v. 18-2868
Ghislaine Maxwell,
v.
________________________________
Alan M. Dershowitz, Michael Cernovich,

DBA Cernovich Media, 16-3945(L)
17-1625(Con)
Intervenors - Appellants, 17-1722(Con)
v.
Plaintiff - Appellee,
v.
Ghislaine Maxwell,
Defendant-Appellee.
________________________________
IT IS HEREBY ORDERED that the Clerk is directed to issue the mandate forthwith.
For the Court:
Catherine O’Hagan Wolfe,

Clerk of Court
Case 18-2868, Document 273-1, 08/09/2019, 2628218, Page1 of 1

FOR THE
SECOND CIRCUIT
MANDATE At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the
3rd day of July, two thousand and nineteen.
Before: José A. Cabranes,

Rosemary S. Pooler,
Christopher F. Droney,
Circuit Judges.
________________________________

JUDGMENT
Intervenors - Appellants. Docket Nos. 18-2868
v.
Ghislaine Maxwell,
v.
________________________________
The appeal in the above captioned case from a judgment of the United States District
Court for the Southern District of New York was argued on the district court’s record and the
parties’ briefs. Upon consideration thereof,
IT IS HEREBY ORDERED, ADJUDGED and DECREED that the orders of the District
Court entered on November 2, 2016, May 3, 2017, and August 27, 2018 are VACATED. The
Court further ORDERS the unsealing of the summary judgment record as described in its
opinion. The case is REMANDED to the District Court for a particularized review of the
remaining materials.
For the Court:
Catherine O’Hagan Wolfe,

Clerk of Court
MANDATE ISSUED ON 08/09/2019

18‐2868; 16‐3945‐cv(L)
Brown v. Maxwell; Dershowitz v. Giuffre
In the
United States Court of Appeals
for the Second Circuit

AUGUST TERM 2018

No. 18‐2868‐cv

JULIE BROWN, MIAMI HERALD COMPANY,
Intervenors‐Appellants,

v.

GHISLAINE MAXWELL,
Defendant‐Appellee,

v.

VIRGINIA L. GIUFFRE,
Plaintiff‐Appellee.

No. 16‐3945‐cv(L)
No. 17‐1625 (CON)
No. 17‐1722(CON)

ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH
MEDIA,
Intervenors‐Appellants,

V.

Plaintiff‐Appellee,

v.

GHISLAINE MAXWELL,
Defendant‐Appellee.*

On Appeal from the United States District Court
for the Southern District of New York

ARGUED: MARCH 6, 2019
DECIDED: JULY 3, 2019

Before: CABRANES, POOLER, and DRONEY, Circuit Judges.

Intervenors‐Appellants Alan Dershowitz, Michael Cernovich,

and the Miami Herald Company (with reporter Julie Brown) appeal
from certain orders of the United States District Court for the Southern
District of New York (Robert W. Sweet, Judge) denying their respective
motions to unseal filings in a defamation suit. We conclude that the
The Clerk of Court is directed to amend the captions as set out above.
*
2
District Court failed to conduct the requisite particularized review

when ordering the sealing of the materials at issue. At the same time,
we recognize the potential damage to privacy and reputation that may
accompany public disclosure of hard‐fought, sensitive litigation. We
therefore clarify the legal tools that district courts should use in
safeguarding the integrity of their dockets. Accordingly, we VACATE
the District Court’s orders entered on November 2, 2016, May 3, 2017,
and August 27, 2018, ORDER the unsealing of the summary judgment
record as described further herein, and REMAND the cause to the
District Court for particularized review of the remaining sealed
materials.
Judge Pooler concurs in this opinion except insofar as it orders
the immediate unsealing of the summary judgment record without a
remand.

SANFORD L. BOHRER (Christine N. Walz,
Madelaine J. Harrington, New York, NY, on
the brief), Holland & Knight LLP, Miami, FL,
for Intervenors‐Appellants Julie Brown and
Miami Herald.
TY GEE (Adam Mueller, on the brief),
Haddon, Morgan and Foreman, P.C.,
Denver, CO, for Defendant‐Appellee Ghislaine
Maxwell.
3
PAUL G. CASSELL (Sigrid S. McCawley, Boies
Schiller Flexner LLP, Ft. Lauderdale, FL, on
the brief), S.J Quinney College of Law,
University of Utah, Salt Lake City, UT, for
Plaintiff‐Appellee Virginia L. Giuffre.
ANDREW G. CELLI JR. (David A. Lebowitz, on
the brief), Emery, Celli, Brinckerhoff &
Abady LLP, New York, NY, for Intervenor‐
Appellant Alan M. Dershowitz.
MARC RANDAZZA (Jay Marshall Wolman,
Las Vegas, NV, on the brief), Randazza Legal
Group, PLLC, Hartford, CT, for Intervenor‐
Appellant Michael Cernovich.

JOSÉ A. CABRANES, Circuit Judge:
Intervenors‐Appellants Alan M. Dershowitz (“Dershowitz”),

Michael Cernovich (“Cernovich”), and the Miami Herald Company
(with reporter Julie Brown, jointly the “Herald”) appeal from certain
orders of the United States District Court for the Southern District of
New York (Robert W. Sweet, Judge) denying their respective motions
to unseal filings in a defamation suit. We conclude that the District
Court failed to conduct the requisite particularized review when
ordering the sealing of the materials at issue. At the same time, we
4
recognize the potential damage to privacy and reputation that may
accompany public disclosure of hard‐fought, sensitive litigation. We
therefore clarify the legal tools that district courts should use in
safeguarding the integrity of their dockets. Accordingly, we VACATE
the District Court’s orders entered on November 2, 2016, May 3, 2017,
and August 27, 2018, ORDER the unsealing of the summary judgment
record as described further herein, and REMAND the cause to the
District Court for particularized review of the remaining sealed
materials.
I. BACKGROUND
A. Jeffrey Epstein’s Conviction and the CVRA Suit
The origins of this case lie in a decade‐old criminal proceeding
against financier Jeffrey Epstein (“Epstein”). On June 30, 2008, Epstein
pleaded guilty to Florida state charges of soliciting, and procuring a
person under the age of eighteen for, prostitution. The charges
stemmed from sexual activity with privately hired “masseuses,” some
of whom were under eighteen, Florida’s age of consent. Pursuant to
an agreement with state and federal prosecutors, Epstein pleaded to
the state charges. He received limited jail‐time, registered as a sex
offender, and agreed to pay compensation to his victims. In return,
prosecutors declined to bring federal charges.
Shortly after Epstein entered his plea, two of his victims,
proceeding as “Jane Doe 1” and “Jane Doe 2,” filed suit against the
Government in the Southern District of Florida under the Crime
Victims’ Rights Act (“CVRA”). The victims sought to nullify the plea
5
agreement, alleging that the Government failed to fulfill its legal
obligations to inform and consult with them in the process leading up
to Epstein’s plea deal.1
On December 30, 2014, two additional unnamed victims—one
of whom has now self‐identified as Plaintiff‐Appellee Virginia Giuffre
(“Giuffre”)—petitioned to join in the CVRA case. These petitioners
included in their filings not only descriptions of sexual abuse by
Epstein, but also new allegations of sexual abuse by several other
prominent individuals, “including numerous prominent American
politicians, powerful business executives, foreign presidents, a well‐
known Prime Minister, and other world leaders,” as well as
Dershowitz (a long‐time member of the Harvard Law School faculty
who had worked on Epstein’s legal defense) and Defendant‐Appellee
Ghislaine Maxwell (“Maxwell”).2
Dershowitz moved to intervene, seeking to “strike the

outrageous and impertinent allegations made against him and to
request a show cause order to the attorneys that have made them.”3
Exercising its authority to “strike from a pleading an insufficient
1 On February 21, 2019, the Florida District Court ruled that federal
prosecutors had violated the CVRA by failing to adequately notify the two victims‐
plaintiffs of the plea deal. The District Court has not yet determined the appropriate
remedy. See Doe 1 v. United States, 359 F. Supp. 3d 1201, 1204–17 (S.D. Fla. 2019).
2 Doe 1 v. United States, No. 08‐CV‐80736‐KAM, 2015 WL 11254692, at *2 (S.D.
Fla. Apr. 7, 2015) (internal quotation marks omitted).
3 Id. (internal quotation marks and brackets omitted).
6
defense or any redundant, immaterial, impertinent, or scandalous

matter . . . on its own,”4 the Florida District Court (Kenneth A. Marra,
Judge) sua sponte struck all allegations against additional parties from
the pleadings, including those against Dershowitz, and therefore
denied Dershowitz’s motion as moot.5
The stricken allegations, however, quickly found their way into
the press, and several media outlets published articles repeating
Giuffre’s accusations. In response to the allegations, on January 3,
2015, Maxwell’s publicist issued a press statement declaring that
Giuffre’s allegations “against Ghislaine Maxwell are untrue” and that
her “claims are obvious lies.”6
B. Giuffre Sues Maxwell
On September 21, 2015, Giuffre filed the underlying action

against Maxwell in the Southern District of New York. Giuffre alleged
that Maxwell had defamed her through this and other public
statements. Extensive and hard‐fought discovery followed. Due to the
volume of sealing requests filed during discovery, on August 9, 2016,
the District Court entered a Sealing Order that effectively ceded
control of the sealing process to the parties themselves. The Sealing
Order disposed of the requirement that the parties file individual letter
briefs to request sealing and prospectively granted all of the parties’
4 Fed. R. Civ. P. 12(f).
5 Doe 1, 2015 WL 11254692, at *2–3.
6 See Giuffre v. Maxwell, 325 F. Supp. 3d 428, 434 (S.D.N.Y. 2018).
7
future sealing requests. In total, 167 documents—nearly one‐fifth of

the docket—were filed under seal. These sealed documents include,
inter alia, motions to compel discovery, motions for sanctions and
adverse inferences, motions in limine, and similar material.
On January 6, 2017, Maxwell filed a motion for summary

judgment. The parties submitted their memoranda of law and
supporting exhibits contesting this motion under seal. On March 22,
2017, the District Court denied the motion in a heavily redacted 76‐
page opinion. Once again, the entire summary judgment record,
including the unredacted version of the District Court opinion
denying summary judgment, remained under seal. On May 24, 2017,
Maxwell and Giuffre executed a settlement agreement, and the case
was closed the next day.
C. Motions to Intervene and Unseal
Over the course of the litigation before Judge Sweet, three
outside parties attempted to unseal some or all of the sealed material.
On August 11, 2016, Dershowitz moved to intervene, seeking to unseal
three documents that, he argues, demonstrate that Giuffre invented
the accusations against him. On January 19, 2017, Cernovich, an
independent blogger and self‐described “popular political
journalist,”7 moved to intervene, seeking to unseal the summary
judgment record, and Dershowitz joined his motion. On April 6, 2018,
after the case had settled, the Herald moved to intervene and unseal
7 Br. Appellant (Cernovich) 4.
8
the entire docket. The District Court granted each of these motions to
intervene, but denied the related requests to unseal in orders entered
November 2, 2016, May 3, 2017, and August 27, 2018, respectively.
The Appellants timely appealed from each of the orders

denying their respective motions to unseal. Although each Appellant
seeks the release of a different set of documents, all argue that the
District Court failed to analyze the documents individually or
properly apply the presumption of public access to court documents.
We therefore ordered that the appeals be heard in tandem and held
argument on March 6, 2019.
On March 11, 2019, we issued an order to show cause why we
“should not unseal the summary judgment motion, including any
materials filed in connection with this motion, and the District Court’s
summary judgment decision.”8 The parties timely filed their
responses.
II. DISCUSSION
There are two categories of sealed material at issue in these
appeals: (1) the summary judgment record, which includes the parties’
summary judgment briefs, their statements of undisputed facts, and
incorporated exhibits; and (2) court filings made in the course of the
discovery process and with respect to motions in limine. In this
Opinion, we explain that our law requires the unsealing of the
8 Giuffre v. Maxwell, No. 18‐2868‐cv, Docket No. 138.
9
summary judgment materials and individualized review of the

remaining sealed materials.
While the law governing public access to these materials is
largely settled, we have not yet adequately addressed the potential
harms that often accompany such access. These harms are apparent.
Over forty years ago, the Supreme Court observed that, without
vigilance, courts’ files might “become a vehicle for improper
purposes.”9 Our legal process is already susceptible to abuse.
Unscrupulous litigants can weaponize the discovery process to
humiliate and embarrass their adversaries. Shielded by the “litigation
privilege,”10 bad actors can defame opponents in court pleadings or
depositions without fear of lawsuit and liability. Unfortunately, the
presumption of public access to court documents has the potential to
exacerbate these harms to privacy and reputation by ensuring that
damaging material irrevocably enters the public record.
We therefore take the opportunity to describe the tools available
to district courts in protecting the integrity of the judicial process, and
emphasize the courts’ responsibility to exercise these powerful tools.
We also caution the public to critically assess allegations contained in
judicial pleadings.
9 Nixon v. Warner Commcʹns, Inc., 435 U.S. 589, 598 (1978).
10 See notes 46–47 and accompanying text, post.
10
A. Standard of Review
When reviewing a district court’s decision to seal a filing or

maintain such a seal, “we examine the court’s factual findings for clear
error, its legal determinations de novo, and its ultimate decision to seal
or unseal for abuse of discretion.”11
B. The Summary Judgment Materials
With respect to the first category of materials, it is well‐settled
that “documents submitted to a court for its consideration in a
summary judgment motion are—as a matter of law—judicial
documents to which a strong presumption of access attaches, under
both the common law and the First Amendment.”12 In light of this
strong First Amendment presumption, “continued sealing of the
documents may be justified only with specific, on‐the‐record findings
that sealing is necessary to preserve higher values and only if the
sealing order is narrowly tailored to achieve that aim.”13
11 Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, 814 F.3d 132, 139
(2d Cir. 2016).
12 Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 121 (2d Cir. 2006). We
observe that our holding in Lugosch relies on the general principle that parties may
“be assumed to have supported their papers with admissible evidence and non‐
frivolous arguments.” Id. at 122. Insofar as a district court has, through striking a
filing, specifically found that assumption inapplicable, the categorical rule in
Lugosch may not apply. See notes 42–43 and accompanying text, post.
Id. at 124. Examples of such countervailing values may include,
13
depending on the circumstances, preserving “the right of an accused to
fundamental fairness in the jury selection process,” Press‐Enter. Co. v. Superior Court
11
In this case, the District Court erred in several respects.14 First, it
failed to give proper weight to the presumption of access that attaches
to documents filed in connection with summary judgment motions.
The District Court reasoned that the summary judgment materials
were “entitled to a lesser presumption of access” because “summary
judgment was denied by the Court.”15 In assigning a “lesser
presumption” to such materials, the District Court relied on a single
sentence of dicta from our decision in United States v. Amodeo.16 We
have since clarified, however, that this sentence was based on a
“quotation from a partial concurrence and partial dissent in the D.C.
Circuit . . . [and] is thus not the considered decision of either this court
or the D.C. Circuit.”17 In fact, we have expressly rejected the
proposition that “different types of documents might receive different
of California, Riverside Cty., 464 U.S. 501, 510 (1984); the protection of attorney‐client
privilege, Lugosch, 435 F.3d at 125; “the danger of impairing law enforcement or
judicial efficiency,” SEC. v. TheStreet.Com, 273 F.3d 222, 232 (2d Cir. 2001); and “the
privacy interest of those who resist disclosure,” id.
Our discussion here focuses specifically on the District Court’s denial of
14
the Herald’s motion to unseal the entire record. Because this decision grants relief
to all Appellants, we need not discuss any separate, additional error in the District
Court’s denial of the earlier motions to unseal.
15 Giuffre, 325 F. Supp. 3d at 444.
71 F.3d 1044, 1049 (2d Cir. 1995) (“Amodeo II”) (“One judge [in the District
16
of Columbia Circuit] has pointed out, for example, that where a district court
denied the summary judgment motion, essentially postponing a final determination
of substantive legal rights, the public interest in access is not as pressing.” (internal
quotation marks omitted; emphasis in original)).
17 Lugosch, 435 F.3d at 121.
12
weights of presumption based on the extent to which they were relied
upon in resolving [a] motion [for summary judgment].”18
Second, in contravention of our precedent, the District Court

failed to review the documents individually and produce “specific, on‐
the‐record findings that sealing is necessary to preserve higher
values.”19 Instead, the District Court made generalized statements
about the record as a whole.20 This too was legal error.
Finally, upon reviewing the summary judgment materials in

connection with this appeal, we find that there is no countervailing
privacy interest sufficient to justify their continued sealing. Remand
with respect to these documents is thus unnecessary. Accordingly, and
to avoid any further delay,21 we order that the summary judgment
documents (with minimal redactions) be unsealed upon issuance of
our mandate.22
18 Id. at 123.
19 Id. at 124.
See, e.g., Giuffre, 325 F. Supp. 3d at 445 (summarily concluding that all
20
“[t]he Summary Judgment Judicial Documents openly refer to and discuss these
allegations [of sexual assault and sexual trafficking] in comprehensive detail, and
that those allegations “establish[] a strong privacy interest here”).
Cf. Lugosch, 435 F.3d at 127 (ordering that “the mandate shall issue
21
forthwith” to expedite the unsealing process).
Upon issuance of our mandate, a minimally redacted version of the
22
summary judgment record will be made accessible on the Court of Appeals docket.
We have implemented minimal redactions to protect personally identifying
information such as personal phone numbers, contact lists, birth dates, and social
13
C. The Remaining Sealed Materials
The law governing disclosure of the remaining sealed material
in this case is only slightly more complex. The Supreme Court has
recognized a qualified right “to inspect and copy judicial records and
documents.”23 In defining “judicial records and documents,” we have
emphasized that “the mere filing of a paper or document with the
court is insufficient to render that paper a judicial document subject to
the right of public access.”24 Instead, “the item filed must be relevant
to the performance of the judicial function and useful in the judicial
process in order for it to be designated a judicial document.”25
As our precedent makes clear, a court “perform[s] the judicial
function” not only when it rules on motions currently before it, but
also when properly exercising its inherent “supervisory powers.”26 A
security numbers. We have also redacted the names of alleged minor victims of
sexual abuse from deposition testimony and police reports, as well as deposition
responses concerning intimate matters where the questions were likely only
permitted—and the responses only compelled—because of a strong expectation of
continued confidentiality. See Fed. R. Civ. P. 5.2. While we appreciate the views
expressed in Judge Pooler’s separate opinion, the panel majority believes that the
efforts invested by three former district judges in reviewing these materials
adequately address those concerns.
23 Nixon, 435 U.S. at 597–98.
24 United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) (“Amodeo I”).
25 Id.
Cf. United States v. HSBC Bank USA, N.A., 863 F.3d 125, 135 (2d Cir. 2017)
26
(explaining that, in considering whether the report of a monitor charged with
assessing compliance with a deferred prosecution agreement is a judicial
14
document is thus “relevant to the performance of the judicial function”
if it would reasonably have the tendency to influence a district court’s
ruling on a motion or in the exercise of its supervisory powers, without
regard to which way the court ultimately rules or whether the
document ultimately in fact influences the court’s decision.27
Accordingly, if in applying these standards, a court determines that
documents filed by a party are not relevant to the performance of a
judicial function, no presumption of public access attaches.28
Once an item is deemed relevant to the exercise of judicial
power, “the weight to be given the presumption of access must be
governed by the role of the material at issue in the exercise of Article
III judicial power and the resultant value of such information to those
document, “[i]f the district court’s conception of its supervisory power in this
context were correct, the Monitor’s Report would quite obviously be relevant to the
performance of the judicial function and useful in the judicial process” (internal
quotation marks omitted)). Whether a specific judicial decision constitutes a
“performance of the judicial function” is a question of law. Accordingly, we review
such determinations de novo. Id. at 134.
27 Amodeo I, 44 F.3d at 145–46 (concluding that documents were relevant to
the performance of a judicial function because they would have “informed” the
district court’s decision whether to discharge or retain a Receiver); see also FTC. v.
Standard Fin. Mgmt. Corp., 830 F.2d 404, 409 (1st Cir. 1987) (citing Federal Rule of
Evidence 401’s “having any tendency” definition of relevance in determining
whether documents were “judicial documents”).
28 As we explain below, there are several (often preferable) tools beyond
sealing that district courts can use to protect their dockets from becoming a vehicle
for irrelevant—and potentially defamatory—accusations. See Section D, post.
15
monitoring the federal courts.”29 Thus, while evidence introduced at
trial or in connection with summary judgment enjoys a strong
presumption of public access, documents that “play only a negligible
role in the performance of Article III duties” are accorded only a low
presumption that “amounts to little more than a prediction of public
access absent a countervailing reason.”30 Documents that are never
filed with the court, but simply “passed between the parties in
discovery, lie entirely beyond the presumption’s reach.”31
The remaining sealed materials at issue here include filings

related to, inter alia, motions to compel testimony, to quash trial
subpoenae, and to exclude certain deposition testimony. All such
motions, at least on their face, call upon the court to exercise its Article
III powers. Moreover, erroneous judicial decision‐making with respect
to such evidentiary and discovery matters can cause substantial harm.
Such materials are therefore of value “to those monitoring the federal
courts.”32 Thus, all documents submitted in connection with, and
relevant to, such judicial decision‐making are subject to at least some
presumption of public access.33
29 Amodeo II, 71 F.3d at 1049.
30 Id. at 1050.
31 Id.
32 Id. at 1049.
33 In previous decisions, we have identified an important exception to this
general rule: the presumption of public access does not apply to material that is
submitted to the court solely so that the court may decide whether that same
16
Although a court’s authority to oversee discovery and control
the evidence introduced at trial surely constitutes an exercise of
judicial power, we note that this authority is ancillary to the court’s
core role in adjudicating a case. Accordingly, the presumption of
public access in filings submitted in connection with discovery
disputes or motions in limine is generally somewhat lower than the
presumption applied to material introduced at trial, or in connection
with dispositive motions such as motions for dismissal or summary
judgment.34 Thus, while a court must still articulate specific and
substantial reasons for sealing such material, the reasons usually need
not be as compelling as those required to seal summary judgment
filings.
Here, the precise basis for the District Court’s decision to deny
the motion to unseal these remaining materials is unclear. In the three
paragraphs devoted to the issue, the District Court emphasized the
potential for embarrassment “given the highly sensitive nature of the
underlying allegations,” and concluded that “the documents sealed in
the course of discovery were neither relied upon by [the District] Court
in the rendering of an adjudication, nor necessary to or helpful in
resolving a motion.”35 It is therefore unclear whether the District Court
held that these materials were not judicial documents (and thus are
material must be disclosed in the discovery process or shielded by a Protective
Order. See TheStreet.Com, 273 F.3d at 233.
34 Amodeo II, 71 F.3d at 1049–50.
Giuffre, 325 F. Supp. 3d. at 442 (internal quotation marks and brackets
35
omitted).
17
not subject to a presumption of public access), or found that privacy
interests outweighed a limited right of public access.
On either interpretation, however, the District Court’s holding
was error. Insofar as the District Court held that these materials are not
judicial documents because it did not rely on them in adjudicating a
motion, this was legal error. As explained above, the proper inquiry is
whether the documents are relevant to the performance of the judicial
function, not whether they were relied upon.36 Indeed, decision‐
makers often find that a great deal of relevant material does not
ultimately sway their decision. And insofar as the District Court held
that privacy interests outweigh the presumption of public access in
each of the thousands of pages at issue, that decision—which appears
to have been made without particularized review—amounts to an
abuse of discretion.37
In light of the District Court’s failure to conduct an
individualized review of the sealed materials, it is necessary to do so
now. We believe the District Court is best situated to conduct this
review. The District Court can directly communicate with the parties,
and can therefore more swiftly and thoroughly consider particular
objections to unsealing specific materials. Relatedly, the District Court
can obtain the parties’ assistance in effecting any necessary redactions,
and in notifying any outside parties whose privacy interests might be
36 See text accompanying notes 12–18 and 26–28, ante.
37 See In re City of New York, 607 F.3d 923, 943 n.21 (2d Cir. 2010) (explaining
that “abuse of discretion” is a nonpejorative, legal “term of art”).
18
implicated by the unsealing. Accordingly, we remand the cause to the
District Court to conduct such a particularized review and unseal all
documents for which the presumption of public access outweighs any
countervailing privacy interests.
D. Protecting the Integrity of Judicial Proceedings
While we disagree with the District Court’s disposition of the
motions to unseal, we share its concern that court files might be used
to “promote scandal arising out of unproven potentially libelous
statements.”38 We therefore describe certain methods courts can
employ to protect the judicial process from being coopted for such
purposes.
The Supreme Court has explained that “[e]very court has

supervisory power over its own records and files” to ensure they “are
not used to gratify private spite or promote public scandal” or “serve
as reservoirs of libelous statements for press consumption.”39 This
supervisory function is not only within a district court’s power, but
also among its responsibilities.
In practice, district courts may employ several methods to fulfill
this function. They may, for instance, issue protective orders
forbidding dissemination of certain material “to protect a party or
person from annoyance, embarrassment, oppression, or undue
38 Giuffre, 325 F. Supp. 3d at 447.
Nixon, 435 U.S. at 598 (internal quotation marks).
39
19
burden” and require that filings containing such material be submitted
under seal.40 If parties then seek to file such materials, the court may
deny them leave to do so.41 District courts may also seek to counteract
the effect of defamatory statements by explaining on the record that
the statements appear to lack credibility. Moreover, under Federal
Rule of Civil Procedure 12(f), the district court may strike such
material from the filings on the grounds that it is “redundant,
immaterial, impertinent, or scandalous.”42 Because such rejected or
stricken material is not “relevant to the performance of the judicial
function” it would not be considered a “judicial document” and would
enjoy no presumption of public access.43 Finally, in appropriate
40 Fed. R. Civ. P. 26(c); see also TheStreet.Com, 273 F.3d at 229–30.
See, e.g., S.D.N.Y. Electronic Case Filing Rules & Instructions, February 1,
41
2019 Edition, Rule 6.1,

http://nysd.uscourts.gov/ecf/ECF%20Rules%20020119%20Final.pdf.
42 Fed. R. Civ. P. 12(f). Courts may strike material from the pleadings either
“on its own” or “on motion made by a party.” Id. Although motions to strike
material solely “on the ground that the matter is impertinent and immaterial” are
disfavored, when material is also “scandalous,” no such presumption applies. Cf.
Lipsky v. Commonwealth United Corp., 551 F.2d 887, 893 (2d Cir. 1976); see also Talbot
v. Robert Matthews Distrib. Co., 961 F.2d 654, 664 (7th Cir. 1992)
(“Allegations may be stricken as scandalous if the matter bears no possible relation
to the controversy or may cause the objecting party prejudice.”); Wine Markets Intʹl,
Inc. v. Bass, 177 F.R.D. 128, 133 (E.D.N.Y. 1998) (“Motions to strike are not generally
favored, except in relation to scandalous matters.”); Alvarado‐Morales v. Digital
Equip. Corp., 843 F.2d 613, 617–18 (1st Cir. 1988) (categorizing as scandalous “matter
which impugned the character of defendants”).
43 Amodeo I, 44 F.3d at 145.
20
circumstances, district courts may impose sanctions on attorneys and
parties under Federal Rule of Civil Procedure 11(c).44
E. A Cautionary Note
We conclude with a note of caution to the public regarding the
reliability of court filings such as those unsealed today.
Materials submitted by parties to a court should be understood
for what they are. They do not reflect the court’s own findings. Rather,
they are prepared by parties seeking to advance their own interests in
an adversarial process. Although affidavits and depositions are
offered “under penalty of perjury,” it is in fact exceedingly rare for
anyone to be prosecuted for perjury in a civil proceeding.45 Similarly,
44 In relevant part, Rule 11 provides:
By presenting to the court a pleading, written motion, or other paper . . . an
attorney or unrepresented party certifies that . . . it is not being presented
for any improper purpose, such as to harass, cause unnecessary delay, or
needlessly increase the cost of litigation . . . . [T]he court may impose an
appropriate sanction on any attorney, law firm, or party that violated the
rule or is responsible for the violation . . . . The sanction may include
nonmonetary directives; an order to pay a penalty into court; or, if imposed
on motion and warranted for effective deterrence, an order directing
payment to the movant of part or all of the reasonable attorney’s fees and
other expenses directly resulting from the violation.
Fed. R. Civ. P. 11. See also Amodeo II, 71 F.3d at 1049 (describing sanctions available
to the court).
45 Sonia Sotomayor & Nicole A. Gordon, Returning Majesty to the Law and
Politics: A Modern Approach, 30 Suffolk U. L. Rev. 35, 47 n.52 (1996) (ʺPerjury cases
are not often pursued . . . .”).
21
pleadings, complaints, and briefs—while supposedly based on

underlying evidentiary material—can be misleading. Such documents
sometimes draw dubious inferences from already questionable
material or present ambiguous material as definitive.
Moreover, court filings are, in some respects, particularly

susceptible to fraud. For while the threat of defamation actions may
deter malicious falsehoods in standard publications, this threat is non‐
existent with respect to certain court filings. This is so because, under
New York law (which governs the underlying defamation claim here),
“absolute immunity from liability for defamation exists for oral or
written statements made . . . in connection with a proceeding before a
court.”46 Thus, although the act of filing a document with a court might
be thought to lend that document additional credibility, in fact,
allegations appearing in such documents might be less credible than
those published elsewhere.47
Front, Inc. v. Khalil, 24 N.Y.3d 713, 718 (2015); see also Kelly v. Albarino, 485
46
F.3d 664, 666 (2d Cir. 2007) (adopting the reasoning of the District Court explaining
that this privilege is “the broadest of possible privileges”); Restatement (Second) of
Torts § 587 (1977) (“A party to a private litigation or a private prosecutor or
defendant in a criminal prosecution is absolutely privileged to publish defamatory
matter concerning another in communications preliminary to a proposed judicial
proceeding, or in the institution of or during the course and as a part of, a judicial
proceeding in which he participates, if the matter has some relation to the
proceeding.”). But see note 47, post.
While common law courts have generally interpreted the litigation privilege
47
broadly, they nevertheless maintain an important (if rarely implemented)

limitation on its scope: to qualify for the privilege, a statement must be “material
and pertinent to the questions involved.” Front, 24 N.Y.3d at 718 (quoting Youmans
22
We have long noted that the press plays a vital role in ensuring
the public right of access and in enhancing “the quality and safeguards
the integrity of the factfinding process.”48 When faithfully observing
its best traditions, the print and electronic media “contributes to public
understanding of the rule of law” and “validates [its] claim of
functioning as surrogates for the public.”49
At the same time, the media does the public a profound
disservice when it reports on parties’ allegations uncritically. We have
previously observed that courts cannot possibly “discredit every
statement or document turned up in the course of litigation,” and we
have criticized “the use by the media of the somewhat misleading term
‘court records’ in referring to such items.”50 Even ordinarily critical
v. Smith, 153 N.Y. 214, 219–20 (1897)). It follows, then, that immaterial and
impertinent statements are (at least nominally) actionable, particularly when they
are “so needlessly defamatory as to warrant the inference of express malice.” Id.
(same). It seems to us that when a district court strikes statements from the record
pursuant to Fed. R. Civ. P. 12(f) on the ground that the matter is “impertinent” and
“immaterial,” it makes the very same determination that permits a defamation
action under the common law. We think the judicial system would be well served
were our common law courts to revitalize this crucial qualification to the litigation
privilege.
48 Westmoreland v. Columbia Broad. Sys., Inc., 752 F.2d 16, 23 (2d Cir. 1984)
(quoting Globe Newspaper Co. v. Superior Court for Norfolk Cty., 457 U.S. 596, 606
(1982)).
Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 572–73 (1980) (plurality
49
opinion) (internal quotation marks omitted).
50 Amodeo II, 71 F.3d at 1049.
23
readers may take the reference to “court papers” as some sort of
marker of reliability. This would be a mistake.
We therefore urge the media to exercise restraint in covering
potentially defamatory allegations, and we caution the public to read
such accounts with discernment.
III. CONCLUSION
To summarize, we hold as follows:
(1) Materials submitted in connection with a motion for

summary judgment are subject to a strong presumption of
public access.
(2) The summary judgment record at issue will be unsealed
upon issuance of our mandate, subject to minimal
redactions.51
(3) Materials submitted in connection with, and relevant to,

discovery motions, motions in limine, and other non‐
dispositive motions are subject to a lesser—but still
substantial— presumption of public access.
(4) The District Court is directed to review the remaining sealed
materials individually and unseal those materials as
appropriate.
51 See note 22, ante.
24
(5) District courts should exercise the full range of their
substantial powers to ensure their files do not become
vehicles for defamation.
For the foregoing reasons, we VACATE the orders of the
District Court entered on November 2, 2016, May 3, 2017, and August
27, 2018, ORDER the unsealing of the summary judgment record as
described herein, and REMAND the cause to the District Court for
particularized review of the remaining materials.
In undertaking this task, the District Court may be well‐served
by ordering the parties to submit to the Court unredacted, electronic
copies of the remaining sealed materials, as well as specific, proposed
redactions. The District Court may also order the parties to identify
and notify additional parties whose privacy interests would likely be
implicated by disclosure of these materials.
In the interests of judicial economy, any future appeal in this
matter shall be referred to this panel.
25
POOLER, Circuit Judge, dissenting in part:
I join the Court’s opinion in every respect but one: the decision to unseal
the summary judgment record ourselves. I agree that all or most of the material
must be unsealed. Nevertheless, in my view, the district court is better suited to
the task. As the Court’s opinion recognizes in connection with the remaining
sealed materials, the district court is better positioned to communicate with the
parties and any nonparties whose privacy interests might be affected by
unsealing. On that score, it is worth clarifying here the breadth of the Court’s
unsealing order: it unseals nearly 2000 pages of material. The task of identifying
and making specific redactions in such a substantial volume is perilous; the
consequences of even a seemingly minor error may be grave and are irrevocable.
Moreover, although I share the majority’s concern about avoiding delay, I would
alleviate that concern through other means—perhaps with an order directing the
district court to act expeditiously and by making clear what types of limited
redactions are and are not appropriate. In sum, I would unseal the district court’s
summary judgment decision only and leave the remainder of the materials for
the district court to review, redact, and unseal on remand.
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
.............................................
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
DEFENDANT’S STATEMENT OF MATERIAL UNDISPUTED

FACTS PURSUANT TO LOCAL CIVIL RULE 56.1
Laura A. Menninger
Jeffrey S. Pagliuca
HADDON, MORGAN, AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
303.831.7364
Pursuant to Rule 56.1 of the Local Civil Rules of this Court, defendant Ghislaine
Maxwell submits this statement of the material facts as to which she contends there is no genuine
issues to be tried. Ms. Maxwell expressly preserves all of her objections to the admissibility of
the evidence cited herein and in the accompanying memoranda of law and does not waive any
objections by making this submission.
numbered.
1. Ms. Maxwell’s response to publications of plaintiff’s false allegations: the
March 2011 statement. In early 2011 plaintiff in two British tabloid interviews made numerous
false and defamatory allegations against Ms. Maxwell. In the articles, plaintiff made no direct
allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey Epstein, who
had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless, plaintiff suggested
that Ms. Maxwell worked with Epstein and may have known about the crime for which he was
convicted.
2. In the articles, plaintiff alleged she had sex with Prince Andrew, “a well-known
businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head
of state.”
3. In response to the allegations Ms. Maxwell’s British attorney, working with
Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations about
[Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely false.”
4. The statement read in full:
Statement on Behalf of Ghislaine Maxwell

By Devonshires Solicitors, PRNE
Wednesday, March 9, 2011
London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about
her that have appeared recently in the media. These allegations are all entirely
false.
1
It is unacceptable that letters sent by Ms Maxwell’s legal representatives to

certain newspapers pointing out the truth and asking for the allegations to be
withdrawn have simply been ignored.
In the circumstances, Ms Maxwell is now proceeding to take legal action against
those newspapers.
“I understand newspapers need stories to sell copies. It is well known that certain
newspapers live by the adage, “why let the truth get in the way of a good story.”
However, the allegations made against me are abhorrent and entirely untrue and
I ask that they stop,” said Ghislaine Maxwell.
“A number of newspapers have shown a complete lack of accuracy in their
reporting of this story and a failure to carry out the most elementary investigation
or any real due diligence. I am now taking action to clear my name,” she said.
Media contact:
Ross Gow
Acuity Reputation
Tel: +44-203-008-7790
Mob: +44-7778-755-251
Email: ross@acuityreputation.com
Media contact: Ross Gow, Acuity Reputation, Tel: +44-203-
008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com
5. Plaintiff’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two
alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against the
United States government purporting to challenge Epstein’s plea agreement. They alleged the
government violated their CVRA rights by entering into the agreement.
6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA
action, claiming she, too, had her CVRA rights violated by the government. On January 1, 2015,
Ms. Giuffre filed a “corrected” joinder motion.
7. The issue presented in her joinder motion was narrow: whether she should be
permitted to join the CVRA action as a party under Federal Rule of Civil Procedure 21,
specifically, whether she was a “known victim[] of Mr. Epstein and the Government owed them
CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual details that [plaintiff]
and [her co-movant] ‘would prove . . . if allowed to join.’” Ms. Giuffre gratuitously included
2
provocative and “lurid details” of her alleged sexual activities as an alleged victim of sexual
trafficking.
8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media
had been following the Epstein criminal case and the CVRA action. While they deliberately filed
the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy and secrecy,
they made no attempt to file the motion under seal. Quite the contrary, they filed the motion
publicly.
9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d]
several individuals, and she offers details about the type of sex acts performed and where they
took place.” The court ruled that “these lurid details are unnecessary”: “The factual details
regarding whom and where the Jane Does engaged in sexual activities are immaterial and
impertinent . . ., especially considering that these details involve non-parties who are not related
to the respondent Government.” Accordingly, “[t]hese unnecessary details shall be stricken.” Id.
The court then struck all Ms. Giuffre’s factual allegations relating to her alleged sexual activities
and her allegations of misconduct by non-parties. The court said the striking of the “lurid details”
was a sanction for Ms. Giuffre’s improper inclusion of them in the motion.
10. The district court found not only that the “lurid details” were unnecessary but also
that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew the
motion with all its “lurid details” was unnecessary because the motion itself recognized that she
would be able to participate as a fact witness to achieve the same result she sought as a party.
The court denied plaintiff’s joinder motion.
11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was
Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion,
3
Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by
Epstein:
 Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years
old” to recruit her into the scheme.
 Ms. Maxwell was “one of the main women” Epstein used to “procure under-
aged girls for sexual activities.”
 Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme.
 She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar

to the manner in which Epstein and his other co-conspirators coerced dozens of
other children.”
 At the mansion, when plaintiff began giving Epstein a massage, he and

Ms. Maxwell “turned it into a sexual encounter.”
 Epstein “with the assistance of” Ms. Maxwell “converted [plaintiff] into . . . a
‘sex slave.’” Id. Plaintiff was a “sex slave” from “about 1999 through 2002.”
 Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.”
 Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea
agreement, because the immunity protected her from prosecution “for the crimes
she committed in Florida.”
 Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.”
 Ms. Maxwell “took numerous sexually explicit pictures of underage girls

involved in sexual activities, including [plaintiff].” Id. She shared the photos
with Epstein.
 As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]”
Epstein with “powerful individuals” so that Epstein could traffick plaintiff to
these persons.
 Plaintiff was “forced to have sexual relations” with Prince Andrew in

“[Ms. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” plaintiff’s
sex with Prince Andrew “by acting as a ‘madame’ for Epstein.”
 Ms. Maxwell “assist[ed] in internationally trafficking” plaintiff and “numerous

other young girls for sexual purposes.”
 Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in
illegal sexual acts with dozens of underage girls.”
4
12. In the joinder motion, plaintiff also alleged she was “forced” to have sex with
Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many other
powerful men, including numerous prominent American politicians, powerful business
executives, foreign presidents, a well-known Prime Minister, and other world leaders.”
13. Plaintiff said after serving for four years as a “sex slave,” she “managed to escape to
a foreign country and hide out from Epstein and his co-conspirators for years.”
14. Plaintiff suggested the government was part of Epstein’s “conspiracy” when it
“secretly” negotiated a non-prosecution agreement with Eptstein precluding federal prosecution
of Epstein and his “co-conspirators.” The government’s secrecy, plaintiff alleged, was motivated
by its fear that plaintiff would raise “powerful objections” to the agreement that would have
“shed tremendous public light on Epstein and other powerful individuals.
15. Notably, the other “Jane Doe” who joined plaintiff’s motion who alleged she was
sexually abused “many occasions” by Epstein was unable to corroborate any of plaintiff’s
allegations.
16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher
three years earlier, plaintiff told Ms. Churcher of virtually none of the details she described in the
joinder motion.
17. Ms. Maxwell’s response to plaintiff’s “lurid” accusations: the January 2015
statement. As plaintiff and her lawyers expected, before District Judge Marra in the CVRA
action could strike the “lurid details” of plaintiff’s allegations in the joinder motion, members of
the media obtained copies of the motion.
18. At Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous
representatives of British media organizations an email containing “a quotable statement on
5
behalf of Ms Maxwell.” The email was sent to more than 6 and probably less than 30 media
representatives. It was not sent to non-media representatives.
19. Among the media representatives were Martin Robinson of the Daily Mail; P.
Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and
Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association. These
representatives were selected based on their request—after the joinder motion was filed—for a
response from Ms. Maxwell to plaintiff’s allegations in the motion.
20. The email to the media members read:
To Whom It May Concern,

Please find attached a quotable statement on behalf of Ms Maxwell.
No further communication will be provided by her on this matter.
Thanks for your understanding.
Best
Ross
Ross Gow
ACUITY Reputation
Jane Doe 3 is Virginia Roberts—so not a new individual. The allegations made by
Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations
are not new and have been fully responded to and shown to be untrue.
Each time the story is re told [sic] it changes with new salacious details about
public figures and world leaders and now it is alleged by Ms Roberts [sic] that
Alan Derschowitz [sic] is involved in having sexual relations with her, which he
denies.
Ms Roberts claims are obvious lies and should be treated as such and not
publicised as news, as they are defamatory.
Ghislaine Maxwell’s original response to the lies and defamatory claims remains
the same. Maxwell strongly denies allegations of an unsavoury nature, which
have appeared in the British press and elsewhere and reserves her right to seek
redress at the repetition of such old defamatory claims.
21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a
traditional press release solely to disseminate information to the media. So he intentionally did
not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation.
6
22. The January 2015 statement served two purposes. First, Mr. Barden intended that it
mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of plaintiff’s false
allegations. He believed these ends could be accomplished by suggesting to the media that,
among other things, they should subject plaintiff’s allegations to inquiry and scrutiny. For
example, he noted in the statement that plaintiff’s allegations changed dramatically over time,
suggesting that they are “obvious lies” and therefore should not be “publicised as news.”
23. Second, Mr. Barden intended the January 2015 statement to be “a shot across the
bow” of the media, which he believed had been unduly eager to publish plaintiff’s allegations
without conducting any inquiry of their own. Accordingly, in the statement he repeatedly noted
that plaintiff’s allegations were “defamatory.” In this sense, the statement was intended as a
cease and desist letter to the media-recipients, letting the media-recipients understand the
seriousness with which Ms. Maxwell considered the publication of plaintiff’s obviously false
allegations and the legal indefensibility of their own conduct.
24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with
the following language: “Please find attached a quotable statement on behalf of Ms Maxwell”
(emphasis supplied). The statement was intended to be a single, one-time-only, comprehensive
response—quoted in full—to plaintiff’s December 30, 2014, allegations that would give the
media Ms. Maxwell’s response. The purpose of the prefatory statement was to inform the media-
recipients of this intent.
25. Plaintiff’s activities to bring light to the rights of victims of sexual abuse.
Plaintiff has engaged in numerous activities to bring attention to herself, to the prosecution and
punishment of wealthy individuals such as Epstein, and to her claimed interest of bringing light
to the rights of victims of sexual abuse.
7
26. Plaintiff created an organization, Victims Refuse Silence, Inc., a Florida corporation,
directly related to her alleged experience as a victim of sexual abuse.
27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors
surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse.”
Toward this end, plaintiff has “dedicated her professional life to helping victims of sex
trafficking.”
28. Plaintiff repeatedly has sought out media organizations to discuss her alleged
experience as a victim of sexual abuse.
29. On December 30, 2014, plaintiff publicly filed an “entirely unnecessary” joinder
motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a “minor
victim[]” by wealthy and famous men and being “trafficked” all around the world as a “sex
slave.”
30. The plaintiff’s alleged purpose in filing the joinder motion was to “vindicate” her
rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution
agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful
individuals” that would undermine the agreement, and support the CVRA plaintiffs’ request for
documents that would show how Epstein “used his powerful political and social connections to
secure a favorable plea deal” and the government’s “motive” to aid Epstein and his “co-
conspirators.”
31. Plaintiff has written the manuscript of a book she has been trying to publish detailing
her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s alleged “sex
scheme.”
8
32. Republication alleged by plaintiff. Plaintiff was required by Interrogatory No. 6 to
identify any false statements attributed to Ms. Maxwell that were “‘published globally, including
within the Southern District of New York,’” as plaintiff alleged in Paragraph 9 of Count I of her
complaint. In response, plaintiff identified the January 2015 statement and nine instances in
which various news media published portions of the January 2015 statement in news articles or
broadcast stories.
33. In none of the nine instances was there any publication of the entire January 2015
statement.
34. Ms. Maxwell and her agents exercised no control or authority over any media
organization, including the media identified in plaintiff’s response to Interrogatory No. 6, in
connection with the media’s publication of portions of the January 2015 statement.
35. Plaintiff’s defamation action against Ms. Maxwell. Eight years after Epstein’s
guilty plea, plaintiff brought this action, repeating many of the allegations she made in her
CVRA joinder motion.
36. The complaint alleged that the January 2015 statement “contained the following
deliberate falsehoods”:
(a) That Giuffre’s sworn allegations “against Ghislaine Maxwell are untrue.”
(b) That the allegations have been “shown to be untrue.”
(c) That Giuffre’s “claims are obvious lies.”
37. Plaintiff lived independently from her parents with her fiancé long before
meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug rehabilitation
facility in 1999, plaintiff moved in with the family of a fellow patient. There she met, and
became engaged to, her friend’s brother, James Michael Austrich. She and Austrich thereafter
9
rented an apartment in the Ft. Lauderdale area with another friend and both worked at various
jobs in that area. Later, they stayed briefly with plaintiff’s parents in the Palm Beach/
Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak Drive
in Royal Palm Beach. Although plaintiff agreed to marry Austrich, she never had any intention
of doing so.
38. Plaintiff re-enrolled in high school from June 21, 2000 until March 7, 2002.
After finishing the 9th grade school year at Forest Hills High School on June 9, 1999, plaintiff re-
enrolled at Wellington Adult High School on June 21, 2000, again on August 16, 2000 and on
August 14, 2001. On September 20, 2001, Plaintiff then enrolled at Royal Palm Beach High
School. A few weeks later, on October 12, 2001, she matriculated at Survivors Charter School.
Id. Survivor’s Charter School was an alternative school designed to assist students who had been
unsuccessful at more traditional schools. Plaintiff remained enrolled at Survivor’s Charter School
until March 7, 2002. She was present 56 days and absent 13 days during her time there. Id.
Plaintiff never received her high school diploma or GED. Plaintiff and Figueroa went “back to
school” together at Survivor’s Charter School. The school day there lasted from morning until
early afternoon.
39. During the year 2000, plaintiff worked at numerous jobs. In 2000, while living
with her fiancé, plaintiff held five different jobs: at Aviculture Breeding and Research Center,
Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis Outsourcing, and
Neiman Marcus. Her taxable earnings that year totaled nearly $9,000. Plaintiff cannot now recall
either the Southeast Employee Management Company or the Oasis Outsourcing jobs.
40. Plaintiff’s employment at the Mar-a-Lago spa began in fall 2000. Plaintiff’s
father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in Palm
10
Beach, Florida, beginning on April 11, 2000. Mr. Roberts worked there year-round for
approximately 3 years. After working there for a period of time, Mr. Roberts became acquainted
with the head of the spa area and recommended plaintiff for a job there. Mar-a-Lago closes every
Mother’s Day and reopens on November 1. Most of employees Mar-a-Lago, including all
employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club
is open, i.e., between November 1 and Mother’s Day. Plaintiff was hired as a “seasonal” spa
attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17.
41. Plaintiff represented herself as a masseuse for Jeffrey Epstein. While working at
the Mar-a-Lago spa and reading a library book about massage, plaintiff met Ms. Maxwell.
Plaintiff thereafter told her father that she got a job working for Jeffrey Epstein as a masseuse.
Plaintiff’s father took her to Epstein’s house on one occasion around that time, and Epstein came
outside and introduced himself to Mr. Roberts. Plaintiff commenced employment as a traveling
masseuse for Mr. Epstein. Plaintiff was excited about her job as a masseuse, about traveling
with him and about meeting famous people. Plaintiff represented that she was employed as a
masseuse beginning in January 2001. Plaintiff never mentioned Ms. Maxwell to her then-fiancé,
Austrich. Plaintiff’s father never met Ms. Maxwell.
42. Plaintiff resumed her relationship with convicted felon Anthony Figueroa. In
spring 2001, while living with Austich, plaintiff lied to and cheated on him with her high school
boyfriend, Anthony Figueroa. Plaintiff and Austrich thereafter broke up, and Figueroa moved
into the Bent Oak apartment with plaintiff. When Austrich returned to the Bent Oak apartment to
check on his pets and retrieve his belongings, Figueroa in Plaintiff’s presence punched Austrich
in the face. Figueroa and plaintiff fled the scene before police arrived. Figueroa was then a
convicted felon and a drug abuser on probation for possession of a controlled substance.
11
43. Plaintiff freely and voluntarily contacted the police to come to her aid in 2001
and 2002 but never reported to them that she was Epstein’s “sex slave.” In August 2001 at
age 17, while living in the same apartment, plaintiff and Figueroa hosted a party with a number
of guests. During the party, according to plaintiff, someone entered plaintiff’s room and stole
$500 from her shirt pocket. Plaintiff contacted the police. She met and spoke with police officers
regarding the incident and filed a report. She did not disclose to the officer that she was a “sex
slave.” A second time, in June 2002, plaintiff contacted the police to report that her former
landlord had left her belongings by the roadside and had lit her mattress on fire. Again, plaintiff
met and spoke with the law enforcement officers but did not complain that she was the victim of
any sexual trafficking or abuse or that she was then being held as a “sex slave.”
44. From August 2001 until September 2002, Epstein and Maxwell were almost
entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs
maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips
away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August
2001 and September 2002. Rodgers maintained a log of all flights on which Epstein and
Maxwell traveled with him. Epstein additionally traveled with another pilot who did not keep
such logs and he also occasionally traveled via commercial flights. For substantially all of
thirteen months of the twenty-two months (from November 2000 until September 2002) that
Plaintiff lived in Palm Beach and knew Epstein, Epstein was traveling outside of Florida
unaccompanied by Plaintiff. During this same period of time, Plaintiff was employed at various
jobs, enrolled in school, and living with her boyfriend.
45. Plaintiff and Figueroa shared a vehicle during 2001 and 2002. Plaintiff and
Figueroa shared a ’93 white Pontiac in 2001 and 2002. Plaintiff freely traveled around the Palm
12
Beach area in that vehicle. In August 2002, Plaintiff acquired a Dodge Dakota pickup truck from
her father. Figueroa used that vehicle in a series of crimes before and after Plaintiff left for
Thailand.
46. Plaintiff held a number of jobs in 2001 and 2002. During 2001 and 2002, plaintiff
was gainfully employed at several jobs. She worked as a waitress at Mannino’s Restaurant, at
TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse Grill. She also was
employed at Courtyard Animal Hospital (aka Marc Pinkwasser DVM).
47. In September 2002, Plaintiff traveled to Thailand to receive massage training
and while there, met her future husband and eloped with him. Plaintiff traveled to Thailand
in September 2002 to receive formal training as a masseuse. Figueroa drove her to the airport.
While there, she initially contacted Figueroa frequently, incurring a phone bill of $4,000. She
met Robert Giuffre while in Thailand and decided to marry him. She thereafter ceased all contact
with Figueroa from October 2002 until two days before Mr. Figueroa’s deposition in this matter
in May 2016.
48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that
Ms. Maxwell was involved in sexual abuse of minors, sexual trafficking or production or
possession of child pornography. Joseph Recarey served as the lead detective from the Palm
Beach Police Department charged with investigating Jeffrey Epstein. That investigation
commenced in 2005. Recarey worked only on the Epstein case for an entire year. He reviewed
previous officers’ reports and interviews, conducted numerous interviews of witnesses and
alleged victims himself, reviewed surveillance footage of the Epstein home, participated in and
had knowledge of the search warrant executed on the Epstein home, and testified regarding the
case before the Florida state grand jury against Epstein. Detective Recarey’s investigation
13
revealed that not one of the alleged Epstein victims ever mentioned Ms. Maxwell’s name and she
was never considered a suspect by the government. None of Epstein’s alleged victims said they
had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,” nor paid
any money by her, nor told what to wear or how to act by her. Indeed, none of Epstein’s alleged
victims ever reported to the government they had met or spoken to Ms. Maxwell. Maxwell was
not seen coming or going from the house during the law enforcement surveillance of Epstein’s
home. The arrest warrant did not mention Ms. Maxwell and her name was never mentioned
before the grand jury. No property belonging to Maxwell, including “sex toys” or “child
pornography,” was seized from Epstein’s home during execution of the search warrant. Detective
Recarey, when asked to describe “everything that you believe you know about Ghislaine
Maxwell’s sexual trafficking conduct,” replied, “I don’t.” He confirmed he has no knowledge
about Ms. Maxwell sexually trafficking anybody. Detective Recarey also has no knowledge of
Plaintiff’s conduct that is subject of this lawsuit.
49. No nude photograph of Plaintiff was displayed in Epstein’s home. Epstein’s
housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr. Epstein’s
house.” Detective Recarey entered Epstein’s home in 2002 to install security cameras to catch a
thief and did not observe any “child pornography” within the home, including on Epstein’s desk
in his office.
50. Plaintiff intentionally destroyed her “journal” and “dream journal” regarding
her “memories” of this case in 2013 while represented by counsel. Plaintiff drafted a
“journal” describing individuals to whom she claims she was sexually trafficked as well as her
memories and thoughts about her experiences with Epstein. In 2013, she and her husband created
a bonfire in her backyard in Florida and burned the journal together with other documents in her
14
possession. Id. Plaintiff also kept a “dream journal” regarding her thoughts and memories that
she possessed in January 2016. To date, Plaintiff cannot locate the “dream journal.”
51. Plaintiff publicly peddled her story beginning in 2011. Plaintiff granted journalist
Sharon Churcher extensive interviews that resulted in seven (7) widely distributed articles from
March 2011 through January 2015. Churcher regularly communicated with plaintiff and her
“attorneys or other agents” from “early 2011” to “the present day.” Plaintiff received
approximately $160,000 for her stories and pictures that were published by many news
organizations.
52. Plaintiff drafted a 144-page purportedly autobiographical book manuscript in
2011 which she actively sought to publish. In 2011, contemporaneous with her Churcher
interviews, plaintiff drafted a book manuscript which purported to document plaintiff’s
experiences as a teenager in Florida, including her interactions with Epstein and Maxwell.
Plaintiff communicated with literary agents, ghost writers and potential independent publishers
in an effort to get her book published. She generated marketing materials and circulated those
along with book chapters to numerous individuals associated with publishing and the media.
53. Plaintiff’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and
generated highly publicized litigation between her lawyers and Alan Dershowitz. On
December 30, 2014, plaintiff, through counsel, publicly filed a joinder motion that contained her
“lurid allegations” about Ms. Maxwell and many others, including Alan Dershowitz, Prince
Andrew, Jean-Luc Brunel. The joinder motion was followed by a “corrected” motion and two
further declarations in January and February 2015, which repeated many of plaintiff’s claims.
These CVRA pleadings generated a media maelstrom and spawned highly publicized litigation
between plaintiff’s lawyers, Edwards and Cassell, and Alan Dershowitz. After plaintiff publicly
15
alleged Mr. Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in
the media. He called plaintiff a liar and accused her lawyers of unethical conduct. In response,
attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This litigation, in turn,
caused additional media attention by national and international media organizations.
54. Plaintiff formed non-profit Victims Refuse Silence to attract publicity and
speak out on a public controversy. In 2014, plaintiff, with the assistance of the same counsel,
formed a non-profit organization, Victims Refuse Silence. According to plaintiff, the purpose of
the organization is to promote plaintiff’s professed cause against sex slavery. The stated goal of
her organization is to help survivors surmount the shame, silence, and intimidation typically
experienced by victims of sexual abuse. Plaintiff attempts to promote Victims Refuse Silence at
every opportunity. For example, plaintiff participated in an interview in New York with ABC to
promote the charity and to get her mission out to the public.
Dated: January 6, 2017
Respectfully submitted,
/s/ Laura A. Menninger

Laura A. Menninger (LM-1374)
Jeffrey S. Pagliuca (pro hac vice)
HADDON, MORGAN AND FOREMAN, P.C.
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
lmenninger@hmflaw.com
Attorneys for Ghislaine Maxwell
16
CERTIFICATE OF SERVICE
I certify that on January 6, 2017, I electronically served this Defendant’s Statement of Material
Undisputed Facts Pursuant to Local Civil Rule 56.1 via ECF on the following:
Sigrid S. McCawley Paul G. Cassell

Meredith Schultz 383 S. University Street
BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112
401 East Las Olas Boulevard, Ste. 1200 cassellp@law.utah.edu
Ft. Lauderdale, FL 33301
smccawley@bsfllp.com
mschultz@bsfllp.com
J. Stanley Pottinger
Bradley J. Edwards 49 Twin Lakes Rd.
FARMER, JAFFE, WEISSING, EDWARDS, South Salem, NY 10590
FISTOS & LEHRMAN, P.L. StanPottinger@aol.com
425 North Andrews Ave., Ste. 2
brad@pathtojustice.com
/s/ Nicole Simmons
Nicole Simmons
17
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-------------------------------------------------X
...........................................
Plaintiff,
v. 15-cv-07433-RWS
.....
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration of Laura A. Menninger in Support of

Defendant’s Motion For Summary Judgment
I, Laura A. Menninger, declare as follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of
Ms. Maxwell’s Motion for Summary Judgment.1
2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher
entitled “Prince Andrew and the 17-year-old girl his sex offender flew to Britain to meet him,”
DAILY MAIL, dated March 2, 2011.
1
At trial, defendant intends to produce either the custodian of record relevant to any
disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902.
See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition
documents herein were either produced by plaintiff or obtained with releases signed by plaintiff.
3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher
entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill
Clinton,” DAILY MAIL, dated March 5, 2011.
4. Attached as Exhibit C is a true and correct copy of a statement on behalf of Ms.
Maxwell dated March 9, 2011.
5. Attached as Exhibit D (filed under seal) is a true and correct copy of the corrected
Motion for Joinder, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Jan. 2,
2015).
6. Attached as Exhibit E is a true and correct copy of an Order Denying Motion to Join
Under Rule 21, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016).
7. Attached as Exhibit F is a true and correct copy of a statement on behalf of Ms.
Maxwell dated January 2, 2015.
8. Attached as Exhibit G (filed under seal) are true and correct copies of excerpts from
the November 18, 2016 deposition of Ross Gow, designated Confidential under the Protective
Order.
9. Attached as Exhibit H (filed under seal) is a true and correct copy of Plaintiff’s
Response to Second Request for Production and to Interrogatories and Requests for Admissions,
dated July 1, 2016.
10. Attached as Exhibit I (filed under seal) is a true and correct copy of Plaintiff’s
Supplemental Responses to to Interrogatory Nos. 6, 12 and 13, dated August 17, 2016,
designated Confidential under the Protective Order.
2
11. Attached as Exhibit J (filed under seal) is a true and correct copy of the Declaration
of Ghislaine Maxwell, dated January 6, 2017.
12. Attached as Exhibit K (filed under seal) is a true and correct copy of the Declaration
of Philip Barden, dated January 6, 2017.
13. Attached as Exhibit L (filed under seal) are true and correct copies of excerpts from
the June 23, 2016 deposition of James Austrich, designated Confidential under the Protective
Order.
14. Attached as Exhibit M (filed under seal) is a true and correct copy of Plaintiff’s
passport application, dated January 12, 2001, designated Confidential under the Protective Order.
15. Attached as Exhibit N (filed under seal) are true and correct copies of excerpts from
the May 3, 2016 deposition of Virginia Giuffre, designated Confidential under the Protective
Order.
16. Attached as Exhibit O (filed under seal) are true and correct copies of Plaintiff’s
school records Bates stamped GM_00888 and GIUFFREE004981-88 and designated
Confidential under the Protective Order.
17. Attached as Exhibit P (filed under seal) are true and correct copies of excerpts from
the June 24, 2016 deposition of Tony Figueroa, designated Confidential under the Protective
Order.
18. Attached as Exhibit Q (filed under seal) are true and correct copies of excerpts from
the November 14, 2016 deposition of Virginia Giuffre, designated Confidential under the
Protective Order.
3
19. Attached as Exhibit R (filed under seal) is a true and correct copy of Plaintiff’s
Social Security records dated October 25, 2016, Bates stamped GIUFFRE009175, designated
Confidential under the Protective Order.
20. Attached as Exhibit S (filed under seal) is a true and correct copy of Mar-A-Lago
records, Bates stamped MAR-A-LAGO-0001 and MAR-A-LAGO-0161-0177.
21. Attached as Exhibit T (filed under seal) is a true and correct copies of excerpts from
the May 20, 2016 deposition of Sky Roberts, designated Confidential under the Protective Order.
22. Attached as Exhibit U (filed under seal) ) is a true and correct copy of the Mar-A-
Lago employee handbook, dated October 28, 1995, Bates stamped MAR-A-LAGO-0178-0243.
23. Attached as Exhibit V (filed under seal) is a true and correct copy of the Mar-A-Lago
advertisement, Bates stamped MAR-A-LAGO-0086.
24. Attached as Exhibit W (filed under seal) is a true and correct copy of Plaintiff’s
Courtyard Animal Hospital employment application, Bates stamped GIUFFRE009201-11,
designated Confidential under the Protective Order.
25. Attached as Exhibit X(filed under seal) is a true and correct copy of the Royal Palm
Beach Police Department Offense Report date, June 10, 2001, Bates stamped GM_00780-82.
26. Attached as Exhibit Y (filed under seal) is a true and correct copy of the Royal Palm
Beach Police Department Probable Cause Affidavit date, November 19, 1999, Bates stamped
GM_01223-28.
27. Attached as Exhibit Z (filed under seal) is a true and correct copy of the Royal Palm
Beach Police Department Offense Report date, August 3, 2001, Bates stamped GM_00777-79.
4
28. Attached as Exhibit AA (filed under seal) is a true and correct copy of the Palm
Beach County Sheriff’s Offense Report date, June 02, 2002, Bates stamped GM_00748-79.
29. Attached as Exhibit BB (filed under seal) are true and correct copies of David
Rodgers flight logs from November 1995 to May 2013, Bates stamped DR__0001-DR0107.
30. Attached as Exhibit CC (filed under seal) is a true and correct copy of excerpts from
the June 3, 2016 deposition of David Rodgers, designated Confidential under the Protective
Order.
31. Exhibit DD left intentionally blank.
32. Attached as Exhibit EE (filed under seal) is a true and correct copy of the Royal
Palm Beach Police Citation Tracking Report date, June 19, 2002, Bates stamped GM_00776.
33. Attached as Exhibit FF (filed under seal) is a true and correct copy of the Palm
Beach County Sheriff’s Offense Report, Bates stamped GM_01202-28.
34. Attached as Exhibit GG (filed under seal) is a true and correct copies of excerpts
from the June 21, 2016 deposition of Joseph Recarey, designated Confidential under the
Protective Order.
35. Attached as Exhibit HH (filed under seal) is a true and correct copy of the Affidavit
of Juan P. Alessi, dated January 13, 2016, Bates stamped GM_01197-1201.
36. Attached as Exhibit II (filed under seal) is a true and correct copy of excerpts from
the Deposition of Virginia Giuffre taken in Cassell v. Dershowitz, on January 16, 2016, and
designated as Confidential under the Protective Order.
5
37. Attached as Exhibit JJ (filed under seal) is a true and correct copy of Errata Sheet
from the January 16, 2016 deposition of Virginia Giuffre taken in Cassell v. Dershowitz, dated
February 11, 2016 and designated by Plaintiff as Confidential under the Protective Order.
38. Attached as Exhibit KK (filed under seal) is a true and correct copy of The
Billionaire Playboys Club book manuscript, designated by Plaintiff as Confidential under the
Protective Order.
39. Attached as Exhibit LL is a true and correct copy of the Victims Refuse Silence, Inc.
Articles of Incorporation dated December 23, 2014, GIUFFRE001064-65.
40. Attached as Exhibit MM (filed under seal) is a true and correct copy of excerpts from
the September 8, 2016 deposition of Brittany Henderson, designated Confidential under the
Protective Order.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on January 6, 2017.
s/ Laura A. Menninger
Laura A. Menninger
6
I certify that on January 6, 2017, I electronically served this Declaration of Laura A. Menninger
in Support of Defendant’s Motion for Summary Judgment via ECF on the following:

mschultz@bsfllp.com
/s/ Nicole Simmons
Nicole Simmons
7
EXHIBIT A
EXHIBIT B
EXHIBIT C
EXHIBIT D
EXHIBIT E
EXHIBIT F
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EXHIBIT H
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
United States District Court

Southern District of New York
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSES AND OBJECTIONS TO DEFENDANT’S SECOND

REQUEST FOR PRODUCTION AND DEFENDANT’S INTERROGATORIES,
PLAINTIFF’S ANSWERS TO DEFENDANT’S REQUESTS FOR ADMISSION
Pursuant to Federal Rules of Civil Procedure 26, 33, 34, Plaintiff hereby serves her
responses and objections to Defendant’s Second Set of Discovery Requests and serves her
Answers to Defendant’s Requests for Admission.
GENERAL OBJECTIONS
Defendant’s Discovery Requests violate Rule 33, Fed. R. Civ. P., which provides “a party
may serve on any other party no more than 25 interrogatories, including all discrete subparts” –
in that Defendant has served a total of 59 interrogatories in this case, including subparts, in
violation of Rule 33.
Ms. Giuffre objects to Defendant’s Second Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege, work product privilege, joint defense privilege, public interest privilege,
and any other applicable privilege.
1
on hundreds (if not thousands) of matters, and collectively have well over 100 years of combined
practice experience. Accordingly, a request that each of these attorneys list all communications
with the media is facially overbroad.
Additionally, Ms. Giuffre objects to this Interrogatory because a response would cause
Ms. Giuffre the incredible and undue burden of having to catalogue literally hundreds of
communications that she has already produced in this case.
Moreover, Ms. Giuffre objects because this interrogatory calls for the production of
documents that are irrelevant to this action and not reasonably calculated to lead to the discovery
of admissible evidence. Communications with the media regarding cases that bear no relation to
the subject matter of this case, from decades in the past, are facially invalid and not calculated to
lead to the discovery of admissible evidence.
Ms. Giuffre additionally objects to the extent that this interrogatory seeks the
communications of her attorneys, any author, reporter, correspondent, columnist, writer,
commentator, investigative journalist, photojournalist, newspaper person, freelance reporter,
stringer, or any other employee of any media organization or independent consultant as such
interrogatory is overly broad and unduly burdensome. Furthermore, Ms. Giuffre is not obligated
to produce anything currently in the possession of Defendant Maxwell or her attorneys.
Notwithstanding such objections, Ms. Giuffre has already produced her responsive
communications, which are found in documents Bates labelled GIUFFRE000001 to
GIUFFRE007566.
6. Identify any “false statements” attributed to Ghislaine Maxwell which were
“published globally, including within the Southern District of New York” as You contend in
paragraph 9 of Count I of Your Complaint, including:
5
a. the exact false statement;
b. the date of its publication;
c. the publishing entity and title of any publication containing the purportedly false
statement;
d. the URL or internet address for any internet version of such publication; and the
nature of the publication, whether in print, internet, broadcast or some other form of
media.
Response to Interrogatory No. 6:
Ms. Giuffre objects because the information interrogatory above is in the possession of
Defendant who has failed to comply with her production obligations in this matter, and has failed
to comply with her production obligations with this very subject matter. See Document Request
No. 17 from Ms. Giuffre’s Second Request for Production of Documents to Defendant Ghislaine
Maxwell.1 Maxwell has not produced all “URL or Internet addresses for any internet version of
such publication” that she directed her agent, Ross Gow, to send.
1
Request No. 17 stated: Produce all documents concerning any statement made by You or on
Your behalf to the press or any other group or individual, including draft statements, concerning
Ms. Giuffre, by You, Ross Gow, or any other individual, from 2005 to the present, including the
dates of any publications, and if published online, the Uniform Resource Identifier (URL)
address. In response, Defendant stated: “Ms. Maxwell objects to this Request on the grounds that
it is cumulative and duplicative. Ms. Maxwell also objects to this Request to the extent it calls
for information that exists within the public domain, the internet or in public court records and
which are equally available to both parties and can be obtained from some other source that is
more convenient, less burdensome, and less expensive. Ms. Maxwell further objects to this
Request to the extent it seeks documents or information protected by the attorney/client
privilege, the work-product doctrine, or any other applicable privilege. Ms. Maxwell is not
producing documents that are available in the public domain. Ms. Maxwell has been unable to
locate any additional documents responsive to this Request.”
6
Ms. Giuffre further objects because the information requested above is in the possession
of Defendant’s agent, who caused the false statements to be issued to various media outlets. Ms.
Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer
remains incomplete. Consequently, Ms. Giuffre reserves the right to modify and/or supplement
her responses, as information is largely in the possession of the Defendant and her agent.
Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its subparts, in
combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms.
Giuffre objects to this request because it is in the public domain. Ms. Giuffre also objects in that
it seeks information protected by the attorney-client/work product privilege, and any other
applicable privilege stated in the General Objections.
Notwithstanding such objections, Ms. Giuffre has already produced documents
responsive to this request; Bates labelled GIUFFRE000001 to GIUFFRE007566, and
supplements such responsive documents with the following list of publications. While the
identification of an exhaustive responsive list would be unduly burdensome, in an effort to make
a good faith effort towards compliance, Ms. Giuffre provides the following examples, which are
incomplete based on the aforementioned reasons:
Date Nature Publishi Statement/URL

ng
Entity
Januar Internet Ross Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by
Gow Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are
y 2, not new and have been fully responded to and shown to be untrue.
2015 Each time the story is re told it changes with new salacious details about public
figures and world leaders and now it is alleged by Ms. Roberts that Alan
Dershowitz is involved in having sexual relations with her, which he denies.
Ms. Roberts’s claims are obvious lies and should be treated as such and not
publicized as news, as they are defamatory.
Ghislaine Maxwell's original response to the lies and defamatory claims remains the
same. Maxwell strongly denies allegations of an unsavoury nature, which have
appeared in the British press and elsewhere and reserves her right to seek redress at
7
the repetition of such old defamatory claims.

Januar Internet Telegrap http://www.telegraph.co.uk/news/uknews/theroyalfamily/11323872/Prince-
h Andrew-denies-having-relations-with-sex-slave-girl.html
y 3,
2015
Januar Internet Express http://www.express.co.uk/news/world/550085/Ghislaine-Maxwell-Jeffrey-Epstein-

not-madam-paedophile-Florida-court-case-Prince-Andrew
y 4,
2015
Januar Internet Daily http://www.dailymail.co.uk/news/article-2895366/Prince-Andrew-lobbied-

Mail government-easy-Jeffrey-Epstein-Palace-denies-claims-royal-tried-use-influence-
y 3, help-billionaire-paedophile-2008-police-probe html
2015
Januar Internet Huffingt http://www.huffingtonpost.co.uk/2015/01/03/duke-of-york-sex-abuse-

on Post claims_n_6409508 html
y 3,
2015
Januar Internet Jewish http://www.jewishnews.co.uk/dershowitz-nothing-prince-andrews-sex-scandal/

News
y 4, Online
2015
Januar Internet Bolton http://www.theboltonnews.co.uk/news/national/11700192.Palace_denies_Andrew_s

News ex_case_claim/
y 2,
2015
Januar Internet NY http://www.nydailynews.com/news/world/alleged-madame-accused-supplying-

Daily prince-andrew-article-1.2065505
y 5, / News
2015 Broadca
st
Januar Internet AOL UK http://www.aol.co.uk/video/ghislaine-maxwell-declines-to-comment-on-prince-

andrew-allegations-518587500/
y 5, /
2015 Broadca
st
8
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley

Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boies Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Telephone: (954) 356-0011
David Boies
333 Main Street
Armonk, NY 10504
Bradley J. Edwards (Pro Hac Vice)

FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Telephone: (954) 524-2820
Paul G. Cassell (Pro Hac Vice)

S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake City, UT 84112
Telephone: (801) 585-5202
I HEREBY CERTIFY that on July 1, 2016, I electronically sent the foregoing document
to the counsel below via e-mail.
Laura A. Menninger, Esq.

Jeffrey Pagliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: lmenninger@hmflaw.com
43
EXHIBIT I
EXHIBIT J
EXHIBIT K

--------------------------------------------------X
..........................................
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration of Philip Barden
I, Philip Barden, declare as follows:
1. I am a Solicitor of the Senior Courts of England & Wales based in London, England.
2. I am submitting this Declaration in support of Ghislaine Maxwell’s motion for
summary judgment in this action.
3. I am not authorised to and do not waive Ms. Maxwell’s attorney-client privilege.
4. I have represented Ms. Maxwell since 2011 regarding the allegations made by
Plaintiff Virginia Giuffre and as published in the United Kingdom. I continue to be retained in
this regard. I am familiar generally with the subject matter of this action.
5. I first represented Ms. Maxwell in this matter over the weekend of 5th and 6th March
2011, about the time when various UK national newspapers, in hard copy and on line, published
numerous and provocative allegations made by the Plaintiff Virginia Giuffre against
Ms. Maxwell. The articles by Sharon Churcher were among those published in this time frame.
6. I instructed British press agent Ross Gow to assist me in representing Ms. Maxwell.
1
7. I caused to be prepared a statement to respond to the articles that appeared in the
British Press over the weekend—March 5 and 6, 2011, and thereafter. I directed Mr. Gow to
distribute the statements to various media outlets that had published articles.
8. On December 30, 2014, Ms. Giuffre made numerous salacious and improper
allegations against Ms. Maxwell in a joinder motion publicly filed in a civil case involving
Jeffrey Epstein. Shortly afterward, the British media gained access to the motion and began
inquiring about Ms. Maxwell’s response.
9. I continued to represent Ms. Maxwell at that time and I coordinated the response to
the media. I again instructed Mr. Gow to assist me.
10. In liaison with Mr. Gow and my client, on January 2, 2015, I prepared a further
statement denying the allegations, and I instructed Mr. Gow to transmit it via email to members
of the British media who had made inquiry about plaintiff’s allegations about Ms. Maxwell.
Attached as Exhibit A1 is an email containing a true and correct copy of this statement. The
statement was issued on my authority. Although it is possible others suggested or contributed
content, I prepared the vast majority of the statement and ultimately approved and adopted all of
the statement as my work.
11. As is evident from the timing and the typographical errors in the statement,
I prepared the statement in haste. I was not in the office on 2nd January 2015 as it was the Friday
immediately after New Years day which is a public holiday. Most people took 2nd January off
and many business closed that day. I don’t now recall where I was that day but I was hard to
reach and that indicates I was out with my family. I therefore would have prepared the statement
in a hurry. I recall that I wanted to get a statement out as a matter of urgency.
12. I recall that immediately after Ms. Giuffre’s motion was filed, media representatives
began contacting Mr. Gow and requesting Ms. Maxwell’s response to Ms. Giuffre’s allegations
2
of criminal and other misconduct by Ms. Maxwell. I believed an immediate response was
imperative, even though this was happening in the midst of the holidays in the United Kingdom.
My communications with Mr. Gow and with Ms. Maxwell were sporadic, delayed and hurried
because of my and their own holiday schedules. I worked while on vacation and on Friday,
January 2, 2015, to ensure that the statement was issued as soon as possible after receiving the
media inquiries.
13. I did not ask Ms. Maxwell to respond point by point to Ms. Giuffre’s factual
allegations in the CVRA joinder motion. What we needed to do was issue an immediate denial
and that necessarily had to be short and to the point. It should have been obvious to the media
that Ms. Giuffre’s new and significantly more salacious allegations had no credibility because
they differed so substantially from her previous allegations, when she had the opportunity and
incentive to disclose all relevant facts about being a victim of alleged sexual abuse and sex
trafficking at the hands of the rich and powerful. I prepared the January 2015 statement based on
my knowledge of Ms. Giuffre’s past statements and her most recent statements in the joinder
motion, and made the point to the media-recipients that she and her new statements, which
differed so substantially from her former ones, were not credible—specifically, that the new
allegations were patently false—i.e., “obvious lies.”
14. By way of example I recall that prior to the December 2014 filing of the joinder
motion and the subsequent press reports that Ms. Guiffre clearly stated she had not had sex with
Prince Andrew. Yet in her joinder motion she claimed she did have sex with Prince Andrew and
that the sex occurred in what can only be described as a very small bathtub, too small for a man
of Prince Andrew’s size to enjoy a bath in let alone sex. So as of December 2014 it was clear
Ms. Guiffre had made polar opposite statements. She was either lying when she said they did not
have sex or when she said they did. I made the inescapable inference that she is a liar, as clearly
3
she is, since both statements cannot as a matter of fact be true. When someone says she did not
have sex and then says she did, in other words, there is an obvious lie.
15. I did not intend the January 2015 statement as a traditional press release solely to
disseminate information to the media. This is why I intentionally did not request that Mr. Gow or
any other public relations specialist prepare or participate in preparing the statement. Instead,
Mr. Gow served as my conduit to the media representatives who had requested a response to the
joinder motion allegations and who I believed might republish those allegations.
16. My purpose in preparing and causing the statement to be disseminated to those
media representatives was twofold. First, I wanted to mitigate the harm to Ms. Maxwell’s
reputation from the press’s republication of plaintiff’s false allegations. I believed these ends
could be accomplished by suggesting to the media that, among other things, they should subject
plaintiff’s allegations to inquiry and scrutiny. For example, I noted that plaintiff’s allegations
changed dramatically over time, suggesting that they are “obvious lies” and therefore should not
be “publicised as news.”
17. Second, I intended the January 2015 statement to be “a shot across the bow” of the
media, which I believed had been unduly eager to publish plaintiff’s allegations without
conducting any inquiry of their own. This was the purpose of repeatedly stating that plaintiff’s
allegations were “defamatory.” In this sense, the statement was very much intended as a cease
and desist letter to the media-recipients, letting the media-recipients understand the seriousness
with which Ms. Maxwell considered the publication of plaintiff’s obviously false allegations and
the legal indefensibility of their own conduct.
18. It is important to understand that any story involving a member of the Royal Family,
especially a senior member such as Prince Andrew, gains huge media attention in the UK and a
story alleging he had a sex with the Plaintiff caused a feeding frenzy for the press. I wanted the
4
press to stop and think before publishing, to cease and desist, and that if they continued then they
faced higher damages for ignoring my clear warning.
19. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with
the following language: “Please find attached a quotable statement on behalf of Ms Maxwell”
(italics supplied). The statement was intended to be a single, one-time-only, comprehensive
response—quoted in full, if it was to be used—to plaintiff’s December 30, 2014, allegations that
would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to
inform the media-recipients of this intent.
20. Selective and partial quotation and use of the statement would disserve my purposes.
It was intended to address Plaintiff’s behavior and allegations against Ms. Maxwell on a broad
scale, that is to say, Plaintiff’s history of making false allegations and innuendo to the media
against Ms. Maxwell. This is why the statement references Plaintiff’s “original allegations” and
points out that her story “changes”—i.e. is embellished—over time including the allegations
“now” that Professor Dershowitz allegedly had sexual relations with her. This is why I
distinguished in the statement between Plaintiff’s “original” allegations and her “new,” joinder-
motion allegations, which differed substantially from the original allegations. And this is why I
wrote, “Each time the story is re told [sic] it changes with new salacious details about public
figures and world leaders and now it is alleged by [Plaintiff] that Alan Derschowitz [sic] is
involved in having sexual relations with her, which he denies.” (Emphasis supplied.) Having
established the dramatic difference between Plaintiff’s two sets of allegations, which suggested
she was fabricating more and more-salacious allegations as she had more time to manufacture
them, I added the third paragraph: “[Ms. Giuffre’s] claims are obvious lies and should be treated
as such and not publicised as news, as they are defamatory.” (Emphasis supplied.) I believed
then, and believe now, that it was and remains a fair inference and conclusion that her claims
5
were and are “obvious lies.” As noted, her claims not to have slept with Prince Andrew and to
have slept with Prince Andrew are a classic example of an obvious lie. One or other account is
on the face of it a lie.
21. As an example of her lack of credibility, the Plaintiff made allegations against
Professor Dershowitz, which I understand she has now withdrawn. Professor Dershowitz has
credibility because his story, insofar as I am familiar with it, has been consistent; Ms. Giuffre has
no credibility because her story has shifted and changed.
22. Further the Plaintiff’s account has become more salacious, for example, regarding
Prince Andrew. The Plaintiff clearly has been seeking publicity for her story and it is clear to me
that she understands retelling the same story doesn’t feed the media and generate publicity and
so each time she appears to create new allegations to generate media interest.
23. I understand the Plaintiff alleged in her Complaint in this action that the following
statements are defamatory. She alleges it was defamatory in the first paragraph of the January
2015 statement to state that “the allegations made by [the Plaintiff] against [Ms.] Maxwell are
untrue.” For the reasons stated above, it was and is my considered and firm opinion that, in fact,
her allegations are untrue. She alleges it was defamatory to state in the same paragraph that the
“original allegations” have been “shown to be untrue.” For the reasons stated above, it was and is
my considered and firm opinion that, in fact, her allegations are untrue. Finally, she alleges that it
was defamatory in the third paragraph to state that her claims are “obvious lies.” For the reasons
stated above, it was and is my considered and firm opinion that, in fact, her claims are obvious
lies.
24. Both Mr. Gow and I understood that once the January 2015 statement was sent to the
media-representatives, we had no ability to control whether or how they would use the statement
and we made no effort to control whether or how they would use the statement.
6
25. It is my understanding that some of the media-recipients of the January 2015
statement did not publish any part of the statement. I am unaware of any media-recipient
publishing the statement in full.
26. The issuance of the statement fully complied with my ethical obligations as a lawyer.
Indeed it was duty in representing my client’s interests to ensure that a denial was immediately
issued. I would have been remiss if I had sat back and not issued a denial, and the press had
published that Ms. Maxwell had not responded to enquiries and had not denied the new
allegations; the public might have taken the silence as an admission there was some truth in the
allegations.
27. The content of the statement was entirely based on information I acquired in
connection with my role as counsel for Ms. Maxwell.
28. At the time I directed the issuance of the statement, I was contemplating litigation
against the press-recipients as an additional means to mitigate and prevent harm to Ms. Maxwell.
Whilst the limitation period for a pure defamation claim has now expired, claims are still being
considered for example for publishing a deliberate falsehood, conspiracy to inure and other
tortious acts.
29. In any such UK defamation, or other related, action Ms. Giuffre would be a
defendant or a witness.
30. I directed that the statement indicate Ms. Maxwell “strongly denie[d] the allegations
of an unsavoury nature,” declare the allegations to be false, give the press-recipients notice that
the publications of the allegations “are defamatory,” and inform them that Ms. Maxwell was
“reserv[ing] her right to seek redress.”
7
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Agren
Case 18-2868, Blando Court
Document Reporting2628230,
278, 08/09/2019, & Video, Inc.
Page127 of 648
IN THE UNITED STATES DISTRICT COURT
Civil Action No. 15-cv-07433-RWS

__________________________________________________
CONFIDENTIAL VIDEOTAPED DEPOSITION OF

VIRGINIA GIUFFRE May 3, 2016
__________________________________________________
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
__________________________________________________
APPEARANCES:
FAMER, JAFFE, WEISSING, EDWARDS, FISTOS &

LEHRMAN, P.L.
By Brad Edwards, Esq.
425 N. Andrews Avenue
Suite 2
Fort Lauderdale, FL 33301
Phone: 954.524.2820
Appearing on behalf of the
Plaintiff

By Sigrid S. McCawley, Esq. (For Portion)
401 East Las Olas Boulevard
Suite 1200
Fort Lauderdale, FL 33301-2211
Phone: 954.356.0011
Plaintiff
VIRGINIA GIUFFRE 5/3/2016 1

Agren
278, 08/09/2019, & Video, Inc.
Page128 of 648
1 APPEARANCES: (Continued)
2 HADDON, MORGAN AND FORMAN, P.C.
By Laura A. Menninger, Esq.
3 Jeffrey S. Pagliuca, Esq.
4 Denver, CO 80203
Phone: 303.831.7364
5 lmenninger@hmflaw.com
jpagliuca@hmflaw.com
6 Appearing on behalf of the
Defendant
7
Also Present:
8 Brenda Rodriguez, Paralegal
Nicholas F. Borgia, CLVS Videographer
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Agren
278, 08/09/2019, & Video, Inc.
Page129 of 648
1 Pursuant to Notice and the Federal Rules

2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF
3 VIRGINIA GIUFFRE, called by Defendant, was taken on
4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150
5 East 10th Avenue, Denver, Colorado, before Kelly A.
6 Mackereth, Certified Shorthand Reporter, Registered
7 Professional Reporter, Certified Realtime Reporter
8 and Notary Public within Colorado.
9
* * * * * * *
10 I N D E X
11
EXAMINATION PAGE
12
MS. MENNINGER 8
13
14 PRODUCTION REQUEST(S):
15 (None.)
16
17
18
19
20
21
22
23
24
25

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1 INDEX OF EXHIBITS
2
INITIAL
3 DESCRIPTION REFERENCE
4
Exhibit 1 Complaint and Demand for Jury 17
5 Trial re Jane Doe No. 102 v.
Jeffrey Epstein
6
Exhibit 2 Jane Doe #3 and Jane Doe #4's 21
7 Motion Pursuant to Rule 21 for
Joinder in Action
8
Exhibit 3 Declaration of Virginia L. 23
9 Giuffre re Jane Doe #1 and Jane
Doe #2 vs. United States of
10 America
11 Exhibit 4 Declaration of Jane Doe 3 re 31
Jane Doe #1 and Jane Doe #2 vs.
12 United States of America
13 Exhibit 5 Declaration of Virginia Giuffre 33
re Bradley J. Edwards and
14 Paul G. Cassell vs. Alan M.
Dershowitz
15
Exhibit 6 FBI documentation, date of entry 36
16 7/5/13
17 Exhibit 7 Document titled Telecon, 39
Participants Jack Scarola, Brad
18 Edwards, Virginia Roberts. Re
Edwards adv. Epstein, 4/7/11,
19 (23 pages of transcription)
20 Exhibit 8 The Billionaire's Playboy Club, 41
By Virginia Roberts
21
Exhibit 9 Plaintiff's Response and 44
22 Objections to Defendant's First
Set of Discovery Requests to
23 Plaintiff re Giuffre v. Maxwell
24
25

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1
INITIAL
3
Exhibit 10 Plaintiff's Supplemental 46
4 Response and Objections to
Defendant's First Set of
5 Discovery Requests to Plaintiff
6 Exhibit 11 Undated Declaration of Virginia 46
Giuffre re Plaintiff's
7 Supplemental Response and
Objections to Defendant's First
8 Set of Discovery Requests served
on March 22, 2016
9
Exhibit 12 Plaintiff's Second Amended 47
11 Set of Discovery Requests to
Plaintiff
12
Exhibit 13 Mrs. Virginia Giuffre resume 67
13
Exhibit 14 Compilation of e-mails re Open 68
14 Position - Virginia Giuffre
15 Exhibit 15 Virginia Lee Roberts passport 180
application
16
Exhibit 16 Composite of e-mail strings 251
17
Exhibit 17 Compilation of e-mails between 259
18 Giuffre and Silva and others
19 Exhibit 18 Compilation of e-mails between 265
Virginia Giuffre and Sandra
20 White
Marianne Strong and Virginia
22 Giuffre
Virginia Roberts and Jason
24 Richards
25

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1
INITIAL
3
4 Sharon Churcher and Virginia
Giuffre
5
Exhibit 22 Compilation of e-mails among 287
6 Sharon Churcher, Michael Thomas,
Virginia Giuffre and others
7
Exhibit 23 Compilation of May 2011 e-mails 288
8 among Sharon Churcher, Virginia
Giuffre, Paulo Silva and others
9
Exhibit 24 Compilation of June 2011 e-mails 289
10 between Virginia Giuffre and
Sharon Churcher
11
Exhibit 26 PR Hub Statement on Behalf of 300
12 Ghislaine Maxwell article
13 Exhibit 27 1/2/15 e-mail from Ross Gow to 309
To Whom It May Concern
14
15
16
17
18
19
20
21
22
23
24
25

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1 January 19th, 2015?

2 A At the very top of the page it says
3 January 21st, 2015.
4 Q The date it was filed. Is there a date
5 just above the signature block?
6 A Oh, yes, sorry. Yes, there is.
7 Q And what date -- what date was that?
8 A The 19th day of January, 2015.
9 Q Okay. And this document is something that
10 you believe contains the truth, correct?
11 A To the best of my knowledge at the time,
12 yes.
13 Q All right. Did something change between
14 the time then and today that makes you believe that
15 it's not all accurate?
16 A Well, as you can see, in line 4 on page 1,
17 I wasn't aware of my dates. I was just doing the
18 best to guesstimate when I actually met them.
19 Since then I've been able to find out that
20 through my Mar-a-Lago records that it was actually
21 the summer of 2000, not the summer of 1999.
22 Q Oh, I'm sorry. Are you back on page 1?
23 A On the first page.
24 Q Okay.
25 A Yes.

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1 Q And you're talking about line 4?

2 A Line 4.
3 Q Paragraph 4 or line 4?
4 A Oh, sorry. Number 4, the paragraph
5 number 4.
6 Q Okay. And what part of paragraph 4 do you
7 now believe to be untrue?
8 A In approximately --
9 MR. EDWARDS: Object to the form.
10 You can answer.
11 A In approximately 1999 when I was 15 years
12 old I met Ghislaine Maxwell.
13 Q (BY MS. MENNINGER) Okay.
14 A I now know that it was 2000, that I was 16
15 years old when I met Ghislaine Maxwell.
16 Q So when you signed this document under
17 penalty of perjury stating that it was true, you no
18 longer believe that to be true, correct?
19 A It was an honest mistake. We had no idea
20 how to pinpoint without any kind of records or dates
21 or anything like that. I was just going back
22 chronologically through time. And that's the best
23 time that I thought it was. And now I know the
24 facts, so it's good to know.
25 Q So you now believe that a document you

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1 filed under oath is no longer true, correct?

3 A I wouldn't say that it wasn't true. I was
4 just unaware of the times and the dates.
5 Q (BY MS. MENNINGER) Again, is there more
6 than one truth, Ms. Roberts?
7 A No, there's no more than one truth.
8 Q All right. So a document in which you
9 swore that you were 15 years old when you met
10 Ms. Ghislaine Maxwell is an untrue statement,
11 correct?
13 A It's not that it's an untrue statement.
14 It was a mistake. So it wasn't intentionally trying
15 to say something that wasn't true. It was to my best
16 knowledge that I thought it was 1999. And when I got
17 my records from Mar-a-Lago I was able to find out
18 that it was 2000. And this was entered before I
19 found out the actual dates that I did work at
20 Mar-a-Lago.
21 Q (BY MS. MENNINGER) Okay. So a document
22 that you filed under oath --
23 A Um-hum.
24 Q -- is now, you believe to be untrue,
25 correct?

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1 MR. EDWARDS: Objection. Asked and

2 answered.
3 Q (BY MS. MENNINGER) You may answer.
4 MR. EDWARDS: Answer again.
5 A Again, I wouldn't say it's untrue. Untrue
6 would mean that I would have lied. And I didn't lie.
7 This was my best knowledge at the time. And I did my
8 very best to try to pinpoint time periods going back
9 such a long time ago.
10 It wasn't until I found the facts that I
11 worked at Mar-a-Lago in 2000 that I was able to
12 figure that out.
13 Q (BY MS. MENNINGER) And approximately when
14 did you learn those facts about the dates you worked
15 at Mar-a-Lago?
16 A I would say it was mid-2015.
17 Q Mid-2015 is the first time you became
18 aware of the dates --
19 A I don't know the exact --
20 Q If you could just let me finish.
21 A I'm sorry.
22 Q That's all right. Approximately mid-2015
23 when you learned the true dates that you had worked
24 at Mar-a-Lago?
25 A That's correct. Sorry.

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1 a lot of the circumstances that I had been subjected

2 to, I decided I wanted to get my GED.
3 Q Okay. So you were going to an actual
4 school to get your GED, that's what you're saying?
5 A Yes.
6 Q And that school, whatever it was, where
7 you were getting your GED was not Palm Beach High
8 School, right?
9 A No.
10 Q And it -- whatever the school was where
11 you were getting your GED took a summer break?
12 A I believe so, yes.
13 Q And that was in 2000?
14 A Now that we know the right dates, yes.
15 Q And that's when your dad helped you get a
16 quote-unquote summer job?
17 A Yes.
18 Q All right. And that summer job was
19 Mar-a-Lago?
20 A Yes.
21 Q Okay. Now tell me how you sort of came
22 into Mar-a-Lago for the first time? He asked you to
23 come? They called you? What happened?
24 A My dad was very liked there. So I think
25 he talked to the people who were in HR. And then

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1 mic higher up on your jacket, please?

2 THE DEPONENT: Sure.
3 THE VIDEOGRAPHER: Thank you.
4 THE DEPONENT: Tell me if that's okay.
5 Better?
6 A Okay. Page 40?
7 Q (BY MS. MENNINGER) Right. Do you see the
8 first full paragraph on that page?
9 A I do.
10 Q The first line begins: I spent my sweet
11 16th birthday on his island in the Caribbean next to
12 Little (sic) St. James Isle. He liked to call it
13 Little St. Jeff's. His ego was enormous as his
14 appetite for fornicating.
15 Do you see that sentence?
16 A I do.
17 Q That is not true, correct? You were not
18 spending your sweet 16th birthday on Little St. James
19 Isle, correct?
20 A Based on my knowledge at the time that I
21 wrote this manuscript, I thought I did spend my 16th
22 birthday there. And so I put it down in there as
23 that. Now I know that it wasn't my 16th birthday.
24 Q Or your sweet 16th birthday?
25 A Well, we --

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2 Harassing.
3 Q (BY MS. MENNINGER) Was it your sweet 16th
4 birthday?
5 A Is it not custom to call your 16th
6 birthday sweet? Have you never heard that saying
7 before?
8 Q Was it your sweet 16th birthday,
9 Ms. Giuffre?
10 A As we --
11 MR. EDWARDS: She's answered the question.
12 It's been asked and answered.
13 MS. MENNINGER: She asked me a question,
14 actually. You're not testifying here.
15 Q (BY MS. MENNINGER) Was it your sweet 16th
16 birthday?
17 A As I thought, in the manuscript when I
18 wrote it, I thought it was my sweet 16th birthday.
19 Q Okay. Now that you know it wasn't, where
20 did you spend your sweet 16th birthday?
21 A Well, I don't know.
22 Q Well, just give us your best guess.
23 MR. EDWARDS: Objection. And she's not
24 going to guess today. She's going to tell you the
25 answers as she remembers them.

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1 A Again, I don't know.

2 Q Do you recall any present you actually got
3 on your sweet 16th birthday?
4 A No, I don't. I don't know where I spent
5 it, who I spent it with or what I got. I'm sorry.
6 Q How long did you work at Mar-a-Lago?
7 A Best of my recollection, it was a summer
8 job. I believe I started in June. And I think I
9 only worked there approximately two weeks, two, three
10 weeks.
11 Q How many hours a week did you work?
12 A I want to say it was a -- I want to say
13 it's a full-time job.
14 Q Do you recall it being a full-time job?
15 A It was a summer job, but just thinking
16 back, my dad used to bring me in and bring me home.
17 So he worked full time, all day. So -- and I didn't
18 lounge around Mar-a-Lago so, yes, I think it would
19 have been a full-time job.
20 Q And how much did you make per hour?
21 A Approximately, I think I remember making
22 $9 an hour.
23 Q The bracelet and earrings you got for your
24 birthday, some birthday, on Little -- or where was
25 that birthday party, at Little St. James?

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1 Q Which brother?
2 A Sky.
3 Q What about your other brother?
4 A I think he had moved out by then.
5 Q What forms of communication did you have?
6 Just a home phone number, or what?
7 A Yeah, there was a home phone.
8 Q When do you recall ever getting a cell
9 phone?
10 A The first cell phone I ever got was the
11 one that Ghislaine gave to me.
12 Q So you never had -- your parents, did they
13 have ones when you were working at Mar-a-Lago?
14 A No, my dad used to -- like, we had phones
15 in the spa and maintenance area and so on, so forth.
16 And you could, so to speak, page people from around
17 the courts.
18 Q Okay. So tell me what you recall of the
19 first conversation that you had with Ghislaine
20 Maxwell.
21 A I'm sitting there reading my book about
22 massage therapy, as I'm working in the spa. And I'm
23 getting my GE -- well, I was in the process of
24 getting my GED before I went to my summer job. I
25 decided that I would like to become a massage

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1 A Yes.
2 Q Who else was at home when you got home?
3 A My mom, my dad and my brother.
4 Q Which brother?
5 A Sky.
6 Q And anyone else who was there at the time?
7 A I believe Michael might have been living
8 with me at that time. So he might have been there.
9 Q Do you recall if he was there when you got
10 home?
11 A I don't really remember. I remember what
12 I did when I got home, that I basically made a
13 beeline for the bathroom.
14 Q Let me ask you a question. Michael was
15 living with you at that home, at your parents' home
16 at the time, is your best recollection today; is that
17 right?
18 A That's my best recollection, yes.
19 Q When you say living with you, were you
20 guys staying in the same room?
21 A Yes.
22 Q Were you engaged at that time to him?
23 A That was a really weird relationship. He
24 was a friend who looked after me, and he did propose
25 to me and I did say yes. But my heart was never in

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1 it.
2 He was somebody that helped me off the
3 streets so I felt compelled to say yes to him.
4 Q Okay. So when he proposed to you and you
5 said yes, did that take place before you started
6 working at Mar-a-Lago or after you started working at
7 Mar-a-Lago?
8 A Before.
9 Q And so if he were living with your parents
10 at that time, you were living in the same room; is
11 that correct?
12 A I believe so.
13 Q And your parents understood him to be your
14 fiance?
15 A I don't think they agreed with it, but I
16 think they understood it as that. I mean --
17 Q I mean, you communicated to them that he
18 had proposed and you had accepted?
19 A Yeah, in not such a pretty way. I mean,
20 they obviously weren't very happy about it. And it
21 wasn't my true intentions to ever marry him.
22 Q Okay.
23 A But I did it to make him feel okay. I
24 didn't want to be mean.
25 Q What did your mom say about your

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1 know where it was when she said to go do this.

2 Q (BY MS. MENNINGER) Okay. Where were you
3 sent to have sex with the owner of a large hotel
4 chain by Ghislaine Maxwell?
6 A I believe that was one time in France.
7 Q (BY MS. MENNINGER) Which time in France?
8 A I believe it was around the same time that
9 Naomi Campbell had a birthday party.
10 Q Where did you have sex with the owner of a
11 large hotel chain in France around the time of Naomi
12 Campbell's birthday party?
13 A In his own cabana townhouse thing. It was
14 part of a hotel, but I wouldn't call it a hotel.
15 Jeffrey was staying there. Ghislaine was
16 staying there. Emmy was staying there. I was
17 staying there. This other guy was staying there. I
18 don't know his name.
19 I was instructed by Ghislaine to go and
20 give him an erotic massage.
21 Q She used the words erotic massage?
22 A No, that's my word. The word massage is
23 what they would use. That's their code word.
24 Q Was she in the room when you gave this
25 erotic massage to the owner of a large hotel chain?

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1 A No, she was not in the room. She was in

2 another cabana.
3 Q And other than telling you to go give the
4 owner of this large hotel chain a massage, do you
5 remember any other words she used to you to direct
6 you in what you should do?
7 A Not at the time, no.
8 Q Where did -- where were you and where was
9 Ms. Maxwell when she directed you to go have sex with
10 Marvin Minsky?
12 A I don't know.
13 Q (BY MS. MENNINGER) Where did you go to
14 have sex with Marvin Minsky?
15 A I believe it was the U.S. Virgin Islands,
16 Jeff's -- sorry, Jeffrey Epstein's island in the U.S.
17 Virgin Islands.
18 Q And when was that?
19 A I don't know.
20 Q Do you have any time of year?
21 A No.
22 Q Do you know how old you were?
23 A No.
24 Q Other than Glenn Dubin, Stephen Kaufmann,
25 Prince Andrew, Jean Luc Brunel, Bill Richardson,

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1 another prince, the large hotel chain owner and

2 Marvin Minsky, is there anyone else that Ghislaine
3 Maxwell directed you to go have sex with?
4 A I am definitely sure there is. But can I
5 remember everybody's name? No.
6 Q Okay. Can you remember anything else
7 about them?
8 A Look, I've given you what I know right
9 now. I'm sorry. This is very hard for me and very
10 frustrating to have to go over this. I don't -- I
11 don't recall all of the people. There was a large
12 amount of people that I was sent to.
13 Q Do you have any notes of all these people
14 that you were sent to?
15 A No, I don't.
16 Q Where are your notes?
17 A I burned them.
18 Q When did you burn them?
19 A In a bonfire when I lived at Titusville
20 because I was sick of going through this shit.
21 Q Did you have lawyers who were representing
22 you at the time you built a bonfire and burned these
23 notes?
24 A I've been represented for a long time, but
25 it was not under the instruction of my lawyers to do

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1 this. My husband and I were pretty spiritual people

2 and we believed that these memories were worth
3 burning.
4 Q So you burned notes of the men with whom
5 you had sex while you were represented by counsel in
6 litigation, correct?
8 A This wasn't anything that was a public
9 document. This was my own private journal, and I
10 didn't want it anymore. So we burned it.
11 Q (BY MS. MENNINGER) When did you write
12 that journal?
13 A Just over time. I started writing it
14 probably in, I don't know, I can't speculate, 2012,
15 2011.
16 Q So you did not write this journal at the
17 time it happened?
18 A No.
19 Q You started writing this journal
20 approximately a decade after you claim you finished
21 being sexually trafficked, correct?
22 A Yes.
23 Q And you started writing a journal after
24 you had a lawyer, correct?
25 A Correct.

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1 Q Including Mr. Edwards, who is sitting

2 right here, correct?
3 A Correct.
4 Q What did that journal look like?
5 A It was green.
6 Q And what else?
7 A It was just a spiral notebook.
8 Q Okay. And what did you put into that
9 green spiral notebook?
10 A Bad memories. Things that I've gone
11 through, lots of things, you know. I can't tell you.
12 There was a lot of pages. It was over 300 pages in
13 that book.
14 Q Did you ever show that book to your
15 lawyers?
16 A No.
17 Q Did you show that book to anyone?
18 A My husband.
19 Q Did you show it to anyone else besides
20 your husband?
21 A No.
22 Q Did you tear out pages and give them to
23 Sharon Churcher?
24 A No, I wrote -- those pages that you're
25 talking about, I wrote for her specifically. She

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1 wanted to know about the Prince Andrew incident.

2 Q So that's a different piece of paper?
3 A Yeah, that's just random paper.
4 Q So you had a green spiral notebook that
5 you began sometime in 2011 or 2012 in which you wrote
6 down your recollections about what had happened to
7 you, and you burned that in a bonfire in 2013.
8 Did I get that right?
9 A You got that right.
10 Q And do you have no other names of people
11 to whom you claim Ghislaine Maxwell directed you to
12 have sex, correct?
13 A At this time, no.
14 Q Is there any document that would refresh
15 your recollection that you could look at?
16 A If you have a document you'd like to show
17 me, I would be glad to look at it and tell you the
18 names I recognize off of that.
19 Q I'm just asking you if there's a document
20 you know of that has this list of names in it?
21 A Not in front of me, no.
22 Q Where is the original of the photograph
23 that has been widely circulated in the press of you
24 with Prince Andrew?
25 A I probably still have it. It's not in my

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1 other terms of his probationary period?

2 A No. He went to everything that he was
3 supposed to go to.
4 Q Has he paid his fines?
5 A Yes, as far as I know.
6 Q Describe for me the contract that you had
7 with the Mail On Sunday?
8 A Could you be a little bit more specific?
9 Like --
10 Q Have you had more than one contract with
11 the Mail On Sunday?
12 A Well, there was one contract for the
13 picture. And that was to pay me 140,000 for the
14 picture. And then two stories were printed after
15 that for the amount of 10,000 each.
16 Q Is that the only money that you received
17 from the Mail On Sunday?
18 A Correct.
19 Q Did you receive any money for syndication
20 of the photograph?
21 A Isn't that what the 140 was for?
22 Q I'm asking you.
23 A Well, I don't really know what syndication
24 means.
25 Q Did you have a written contract with the

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1 Mail on Sunday?
2 A Yes.
3 Q Where is that contract right now?
4 A I don't know. I've moved that many times.
5 I -- I lose paperwork wherever I go.
6 Q Is it possible it's in the boxes in
7 Sydney?
8 A I don't think I kept it, to be honest.
9 Q Did you ever refer back to it after you
10 signed it?
11 A I know I kept it for a short while, but I
12 mean, like I said, I've moved countries twice in the
13 last two years and three different houses. So the
14 paper trail is lost. I don't know where it would be.
15 Q Did you receive it via e-mail?
16 A No. I received it -- Sharon Churcher
17 handed it to me by paper.
18 Q And you signed it?
19 A I signed it.
20 Q And then did you make a copy of it?
21 A No.
22 Q You never had a copy of it?
23 A Well, I had my own copy. I'm sure she has
24 hers.
25 Q Do you recall there being a period of

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1 STATE OF COLORADO)
2 ) ss. REPORTER'S CERTIFICATE
3 COUNTY OF DENVER )
4 I, Kelly A. Mackereth, do hereby certify
5 that I am a Registered Professional Reporter and
6 Notary Public within the State of Colorado; that
7 previous to the commencement of the examination, the
8 deponent was duly sworn to testify to the truth.
9 I further certify that this deposition was
10 taken in shorthand by me at the time and place herein
11 set forth, that it was thereafter reduced to
12 typewritten form, and that the foregoing constitutes
13 a true and correct transcript.
14 I further certify that I am not related to,
15 employed by, nor of counsel for any of the parties or
16 attorneys herein, nor otherwise interested in the
17 result of the within action.
18 In witness whereof, I have affixed my
19 signature this 11th day of May, 2016.
20 My commission expires April 21, 2019.
21
22 ____________________________
Kelly A. Mackereth, CRR, RPR, CSR
23 216 - 16th Street, Suite 600
24
25

EXHIBIT O
EXHIBIT P
Video Deposition of Tony Figueroa (Volume 1) 1
2 UNITED STATES DISTRICT COURT

3
CASE: 15-cv-07433-RWS
4
VIRGINIA GIUFFRE,
5
Plaintiff,
6
v.
7
GHISLAINE MAXWELL,
8
Defendant.
9 ____________________/
10
VIDEOTAPED DEPOSITION OF TONY FIGUEROA
11
Volume 1 of 2
12
Pages 1 - 157
13
14
15 Taken at the Instance of the Defendant

16
17
DATE: Friday, June 24, 2016
18
TIME: Commenced: 8:59 a.m.
19 Concluded: 1:22 p.m.
20 PLACE: Southern Reporting Company
B. Paul Katz Professional Center
21 (SunTrust Building)
One Florida Park Drive South
22 Suite 214
Palm Coast, Florida 32137
23
REPORTED BY: LEANNE W. FITZGERALD, FPR
24 Florida Professional Reporter
Court Reporter and Notary Public
25
Southern Reporting Company (386)257-3663

1 APPEARANCE OF COUNSEL
2
4 ON BEHALF OF THE PLAINTIFF:

5 BRADLEY J. EDWARDS, Esquire
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
6 425 North Andrews Avenue
Ft. Lauderdale, Florida 33301
7 954-524-2820
Brad@pathtojustice.com
8
10 ON BEHALF OF THE DEFENDANT:

11 LAURA A. MENNINGER, Esquire
Haddon, Morgan and Foreman, P.C.
12 150 East 10th Avenue
13 303-831-7364
Lmenninger@hmflaw.com; Nsimmons@hmflaw.com
14
15
16 Also appearing: Jenny Martin, Videographer from Abel

Virginia Giuffre, Plaintiff
17
18
19
20
21
22
23
24
25

1 INDEX
2
3 ----------------------------------------------------
4 VOLUME 1 (pages 1 - 157)
5 TONY FIGUEROA
Direct Examination by Ms. Menninger 5
6
OATH OF REPORTER 156
7
CERTIFICATE OF REPORTER 157
8
---------------------------------------------------
9
VOLUME 2 (Pages 158 - 258)
10
TONY FIGUEROA
11 Cross-Examination by Mr. Edwards 162
Redirect Examination by Ms. Menninger 218
12 Recross-Examination by Mr. Edwards 243
Further Direct Examination by 253
13 Ms. Menninger
14 OATH OF REPORTER 257
15 CERTIFICATE OF REPORTER 258
16 ---------------------------------------------------
17
- - -
18
19
20 STIPULATION
21 It is hereby stipulated and agreed by and
22 between counsel present at this deposition and by
23 the deponent that the witness review of this
24 deposition would be waived.
25

1 INDEX OF EXHIBITS
2
3
(MARKED BY THE DEFENDANT:)
4
Defendant's Exhibit 1 42
5 (Palm Beach County Sheriff's Reports -
Case Number 98041883)
6
7 (Greenacres Reports)
8 Defendant's Exhibit 3 77
(Two Pictures of Apartment Building)
9
10 (Palm Beach County Sheriff's Reports -
Case Number 02075321)
11
12 (Royal Palm Beach Police Reports)
(Robert's School Records)
14
15
16 - - -
17
18 (MARKED BY THE PLAINTIFF:)

19 Plaintiff's Exhibit 1 162
(Photos)
20
Plaintiff's Exhibit 2 163
21 (Passport)
22
23
- - -
24
25

1 BY MS. MENNINGER:
2 Q And where did you go after Royal Palm
3 Beach?
4 A I believe it was South Area. I'm pretty
5 sure it was South Area.
6 Q Did you go to another school after that?
7 A Yeah. I went to Gold Coast after that.
8 Q Is that also in Royal Palm Beach?
9 A No. That's -- South Area was in Lake
10 Worth. Gold Coast is in West Palm. They were both
11 alternative schools.
12 Q Did you ever go to a Survivors Charter
13 School?
14 A Yes. I went there, too.
15 Q When did you go there?
16 A I'm not exactly sure of the date. But it
17 was somewhere after either -- I'm pretty sure it
18 was -- maybe -- I can't remember if it was Gold
19 Coast first or Survivor. But one of the -- I'm
20 trying to remember. I honestly don't remember which
21 one came first.
22 Q That's all right.
23 Can you describe for me Survivors Charter
24 School? What is it like, or was it like?
25 A I mean, like I said, it was an alternative

1 school. It was just pretty much a bunch of bad

2 kids, you know, who have gotten kicked out. And it
3 was pretty much like a last chance kind of school,
4 you know what I mean?
5 Q Does it look like a school?
6 A Kind of. I mean, it had, like, a
7 cafeteria, and then it had a whole bunch of, like,
8 portables and stuff around there. And it was
9 under -- it was, like, right near the Lake Worth. I
10 remember there was, like, a bridge that went over
11 the interstate right by it. But, I mean, it was
12 just a little, you know, little crappy school.
13 Q Was it during the day or at night?
14 A It was during the day.
15 Q So regular school hours?
16 A Yeah. Well, it was actually a little bit
17 shorter hours. I can't remember exactly. But I
18 know it was not like the full days. Because, I
19 mean, at the alternative schools, it's obviously not
20 up to regular high school standards. I mean, they
21 just do pretty much stuff to get people to get out
22 of school, you know, so...
23 Q Get the credits that you need?
24 A Yeah. So that way they can finish high
25 school and not drop out and whatnot, so...

1 Q You actually go there in the morning,

2 though, and take classes?
3 A Yeah.
4 Q And get checked in at attendance?
5 A Yeah.
6 Q And then you may leave a little earlier
7 than a regular school day?
8 A Uh-huh (affirmative).
9 Q All right. It's not a online program?
10 A No, it was not online.
11 Q When you were at Survivors Charter School,
12 did you ever see Ms. Roberts there?
13 A Was it Survivors? I don't remember if it
14 was Survivors. Or was it -- because I'm pretty sure
15 we were both -- was it -- I know we both went to one
16 of the schools. I'm pretty sure it was Survivors,
17 maybe.
18 Q Did you see her there?
19 A Now, when we went to the school, like, we
20 were together afterwards. But I don't remember
21 exactly which one it was. I know it was one of
22 those alternative schools that we went to, though.
23 Q Okay. Did you -- was Wellington an
24 alternative school?
25 A No. Wellington is a -- is a real high

1 school, like a regular high school.

2 Q Do you know if Wellington has an adult
3 program?
4 A They might. I mean, I really don't know.
5 I'm not sure.
6 Q Did you ever take night classes there?
7 A No.
8 Q So you believe when you reunited with
9 Ms. Roberts in or around 2001, she had also gone to
10 one of those alternative schools?
11 A When I reunited with her, no. We ended
12 up, like, trying to go finish school.
13 Q Tell me about that.
14 A I mean, we just ended up going to one of
15 those alternative schools and didn't even finish
16 that.
17 Q So you two had both left school, but went
18 back together --
19 A Yeah.
20 Q -- to one of the alternative schools?
21 A Yeah.
22 Q And that may have been Survivors Charter
23 School?
24 A Yeah. I'm pretty sure it probably was.
25 I'm pretty sure.

1 Q You both wanted to get your GEDs?

2 A Yeah.
3 Q Get better jobs?
5 Q Things like -- that was the plan?
6 A Yeah.
7 Q But it did not work out?
8 A Yeah.
9 Q Do you know how long the two of you went
10 to Survivors Charter School?
11 A I honestly don't remember.
12 Q Okay. You do have a recollection of going
13 with her, though?
14 A Yeah.
15 Q Seeing her there?
17 Q I'm trying to get a little bit of a time
18 frame on the time that you reunited with
19 Ms. Roberts. I know you said you lived -- you
20 remember being in an apartment with her in September
21 of 2000 -- 9/11/2001; right?
22 A Yeah.
23 Q Do you think you had been together with
24 her for a while at that point?
25 A It was probably, I'd say, like a month or

1 so. Like, I'm pretty sure. Because it was not too

2 long after I had moved in, so...
3 Q And just to be clear, she already lived in
4 the apartment?
5 A Yeah. She lived in the apartment with her
6 ex-boyfriend Michael and JJ. And I think there was
7 somebody else. I don't remember who, though.
8 Q All right. That's where she was living
9 when you reunited with her?
10 A Yeah.
11 Q And then you moved in?
12 A Yeah.
13 Q Did the other people move out?
14 A Yeah. I kicked them out.
15 Q How long did you live there with
16 Ms. Roberts?
17 A I think it was just till, like, the end of
18 the lease, so it was probably maybe, like, five or
19 six months. I'm pretty sure. I don't know. I'm
20 not exactly [sic] on the whole time frame.
21 Q That's okay. I understand it was a while
22 ago.
23 A Yeah.
24 Q Where did you two move from there?
25 A I believe we either -- we went to her --

1 it was either her family's house or mine. It was

2 either one of the two. And then we ended up getting
3 another -- we were renting a house out in
4 Loxahatchee also, eventually. But we also stayed in
5 a little trailer behind her parents' house.
6 Q When did your relationship with
7 Ms. Roberts end the second time?
8 A When she went to Thailand and --
9 (Brief interruption.)
10 A -- never heard from her again.
11 THE COURT REPORTER: I'm sorry. Can you
12 re-answer?
13 A Yeah. When Jeffry sent her to Thailand.
14 And then I never heard from her again until
15 freaking, like, two days ago.
16 BY MS. MENNINGER:
17 Q You heard from her two days ago?
18 A Yeah. She had called me to apologize
19 about, obviously, everything about me getting
20 dragged into this mess. And we talked just pretty
21 much about, you know, the way shit ended, and pretty
22 much tried just -- her apologizing mainly about
23 dragging me all into this and having to make me
24 get -- you know, knowing how I have my family and
25 stuff now. And that was pretty much it, so...

1 Q Another instant connection.

3 Q From the time Ms. Roberts left to go to
4 Thailand until today, have you seen her?
5 A Nope.
6 And to be honest, it still does not even
7 feel real that she's sitting right there across from
8 me.
9 Q Well, you offered to get in touch with her
10 a couple of times?
11 A I know. But, like I said, it's just -- it
12 still does not seem like this is actually happening.
13 Like, she's -- I don't know. It's like talking to a
14 ghost or seeing one.
15 Q Does she look different now?
16 A Yeah.
17 Q How?
18 A Just more mature, more older.
19 Q When you were with Ms. Roberts the first
20 time in '98 --
22 Q -- you believe that relationship lasted
23 just a couple of weeks?
24 A Yeah. I'm not exactly sure, but it was
25 pretty brief.


2 Q What did she tell you about that?
3 A I -- I think that maybe he -- I mean, I
4 don't know exactly. I don't really remember. I
5 remember hearing about him, but I don't remember
6 what she said about him.
7 Q Did Ms. Roberts ever tell you that she had
8 met Al Gore?
9 A Not that I'm aware of.
10 Q Did Ms. Roberts ever tell you that she had
11 met a foreign president?
12 A I'm not sure; I'm not sure.
13 Q Did Ms. Roberts ever tell you she had met
14 a prime minister?
15 A I don't know.
16 Q Did Ms. Roberts ever tell she had met a
17 senator?
18 A Not that I'm aware of. I mean, she's told
19 me that she met a bunch of people before. And after
20 it started becoming, like, an almost everyday thing
21 about -- just hearing about famous people with
22 Jeffrey and stuff like that, it's, like, I kind of
23 didn't, like, tone it out, but I just -- it became
24 normal, so I just stopped, like, listening to all
25 the details, because I was not going to meet these

1 people, you know what I mean? It's just, like, all

2 right.
3 Q Was she excited that she was meeting
4 famous people?
5 A Yeah.
6 Q Was that a job perk?
7 A Obviously.
8 Q She talked about it a lot?
9 A Yeah.
10 Q To the point where you were drowning it
11 out?
12 A Well, that's what I'm saying. It was not
13 like I was drowning it out. It's just I knew that
14 she was with Jeffrey, and he was, obviously,
15 well-connected with everybody. So it was not like,
16 you know, a special occasion, per se. You know, it
17 was, but it's not like it was -- it was not very not
18 rare so...
19 Q Did she show you any photographs of
20 herself with famous people?
21 A No.
22 Q Did you see a photograph of her with
23 Prince Andrew --
24 A Yes.
25 Q -- in her possession?

1 BY MS. MENNINGER:
2 Q Mr. Figueroa, you mentioned that you and
3 Ms. Roberts attempted to go to back to school while
4 you were together --
5 A Yes.
6 Q -- to get your GED?
7 A Yeah. Yes.
8 Q And you believe that you went to the
9 Survivors Charter School?
10 A Yes.
11 MS. MENNINGER: Okay. I'm going to mark
12 Defendant's Exhibit 6.
13 (Defendant's Exhibit 6 was marked for
14 identification.)
16 Q This is a school record for Ms. Roberts
17 that lists the names of various schools. And --
18 A So it was Survivors, obviously. That's
19 the only one on that list that isn't -- or that's
20 there that's on mine, as well.
21 Q Okay.
22 A Other than the other ones, but...
23 Q All right. So you recognize Survivors
24 Charter School on Ms. Roberts' school records?
25 A Yeah. That's what I'm saying. Since that

1 is the one on here, that's -- that's completely

2 clear. I could not remember if it was that one or
3 Gold Coast.
4 Q Okay. There is an entry date for
5 Ms. Roberts at Survivors Charter School of
6 10/12/2001, and a withdrawal on 3/7 of '02. Do you
7 see that?
8 A I mean, it's this; right? I mean, that's
9 the top.
10 Q The entry date of 10/12/01, withdrawal
11 3/7/02 at Survivors?
12 A Okay. I did not know what those
13 numbers -- I did not realize that that was a date.
14 Q I understand. And I know you did not make
15 this record.
16 So I'm just wanting to know if that's
17 consistent with your recollection, that you guys
18 went to school in the fall of 2001 until the --
19 A Yeah, that sounds about right.
20 Q -- March of 2002. It sounds right?
21 A Yeah.
22 Q And you both went to school together?
24 Q In the mornings?
25 A Yeah.

1 Q And got out of school at some earlier time

2 than a regular school day?
3 A Yeah.
4 Q Do you recall Ms. Roberts going to Royal
5 Palm Beach High? Again, this is in the 2001 time
6 frame.
7 A I -- I don't recall. I really don't.
8 Q Do you recall her, during the time you
9 were with her, taking any night classes at
10 Wellington High School?
11 A I don't recall.
12 Q Is it possible?
13 A It's a possibility.
16 Q Do you know whether Wellington has a night
17 school program?
18 A Like I said before, I don't know. They
19 could.
20 Q You went there in ninth grade?
21 A Yeah. It was during the day, though. I
22 have no clue about night school.
23 Q Got it.
24 But you do have a memory about Survivors
25 Charter School?

1 CERTIFICATE OF REPORTER
2
STATE OF FLORIDA )
3 )
COUNTY OF VOLUSIA )
4
7 I, Leanne W. Fitzgerald, Court Reporter, do

hereby certify that I was authorized to and did
8 stenographically report the deposition of TONY
FIGUEROA; and that the foregoing transcript is a
9 true record of my stenographic notes.
10 I further certify that I am not a relative,
employee, attorney, or counsel of any of the
11 parties, nor am I a relative or employee of any of
the parties' attorneys or counsel connected with the
12 action, nor am I financially interested in the
action.
13
Dated this 5th day of July, 2016.
14
15
16
17
18
19
__________________________________
20 Leanne W. Fitzgerald, FPR
Florida Professional Reporter
21
Digital Certificate Authenticated
22 By Symantec
23
24
25

EXHIBIT Q
!"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67

__________________________________________________
CONFIDENTIAL VIDEO DEPOSITION OF

VIRGINIA GIUFFRE, VOLUME II
November 14, 2016
__________________________________________________
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
__________________________________________________
APPEARANCES:

By Sigrid S. McCawley, Esq.
Suite 1200
Phone: 954.356.0011
Appearing on behalf of the Plaintiff
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!"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67
By Laura Menninger, Esq.
4 Denver, CO 80203
Phone: 303.831.7364
Defendant
7
Also Present:
8 Ann Lundberg, Paralegal
Maryvonne Tompkins, Videographer
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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2 of Civil Procedure, the continued video
3 deposition of VIRGINIA GIUFFRE, called by Defendant,
4 was taken on Monday, November 14, 2016, commencing at
5 8:04 a.m., at 150 East 10th Avenue, Denver, Colorado,
6 before Pamela J. Hansen, Registered Professional
7 Reporter, Certified Realtime Reporter and Notary
8 Public within Colorado.
9
* * * * * * *
10 I N D E X
11 VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II
12 EXAMINATION PAGE
13 By Ms. Menninger 354
14
15
16
17
18
19
20
21
22
23
24
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1 INDEX OF EXHIBITS (continued)

2
INITIAL
4 Exhibit 1 Settlement Agreement and General 355
Release
5
Exhibit 2 List of names 370
6
Exhibit 3 Photocopy of photograph 408
7
Exhibit 4 Photocopy of photograph, with 411
8 attachments
9 Exhibit 5 Photocopy of photograph, with 417
attachments
10
11 attachments
12 Exhibit 7 Statements 437
13 Exhibit 8 History of education, with 462
attachment
14
Exhibit 9 Application for Employment, 474
15 with attachment
16 Exhibit 10 The Great Outdoors Community 481
Services Association, Inc.
17 Termination Form, with
attachments
18
Exhibit 11 7/6/2016 letter to Schultz 484
19 from Hayek, with attachments
20 Exhibit 12 Patient Registration 490
Information, with attachments
21
Exhibit 13 CVS Prescription Records 502
22 document, 7/29/2016, with
attachment
23
Exhibit 14 Affidavit of Custodian of 507
24 Records, Walgreen Company,
with attachments
25
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1 INITIAL
DESCRIPTION REFERENCE
2
Exhibit 15 Patient Health Summary, Clifton 512
3 Beach Medical & Surgical,
printed on 6/28/2016
4
Exhibit 16 Portions of deposition transcript 533
5 of Virginia Giuffre taken
May 3, 2016
6
Exhibit 17 Amendment/Errata Sheet signed 540
7 May 31, 2016 by Virginia Giuffre
8 Exhibit 18 Ad for Mar-a-Lago Club 548
9 Exhibit 19 The Mar-a-Lago Club, L.C. 549
Employment Policies, October 28,
10 1995
11 Exhibit 20 Page from the Mar-a-Lago Club 550
Employment Policies, Revised
12 10/2001
13
14
15
16
17
18
19
20
21
22
23
24
25
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1 A Yes.
2 Q And you believe the Neiman Marcus was
3 located in which city?
4 A Well, it's around Fort Lauderdale. I
5 can't tell you exactly. Fort Lauderdale is so big,
6 like Broward County? Is that the word for it?
7 Q And what did you do at Neiman Marcus?
8 A I worked in the changing rooms.
9 Q And what did you do in the changing room?
10 A I think I just like -- if I remember
11 right, I just put clothes away that people left in
12 there. Probably went out to get sizes, different
13 sizes for women who wanted different sizes of the
14 same product.
15 Q And where did you work after Neiman
16 Marcus?
17 A Taco Bell.
18 Q Did you work at Southeast Employee
19 Management Company?
20 A I don't recognize that. I don't know if
21 that's a payroll company or what it is. I don't know
22 what Southeast -- what is it called?
23 Q Southeast Employee Management Company.
24 A No, I don't remember that.
25 Q Did you ever work as a temp?
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1 A Not that I remember.

2 Q Going to different offices and filling in?
3 A No.
4 Q Did you work for Oasis Outsourcing?
5 A I don't -- I don't know if that's a
6 payroll company or if that's an actual place, but
7 that doesn't ring a bell.
8 Q Did you -- do you know how much you got
9 paid when you were working at places like Oasis
10 Outsourcing?
11 A Well, considering I don't know if I worked
12 at Oasis Outsourcing, I wouldn't even know how much I
13 got paid.
14 Q Did you review your Social Security
15 records?
16 A Yes.
17 Q You saw Oasis Outsourcing listed there?
18 A Right, but like I said, it doesn't even
19 ding a bell at all.
20 Q Do you know how much money they said you
21 made from them?
22 MS. MCCAWLEY: Objection. If you want to
23 show her the documents, she can see what amount is
24 listed and answer your questions, but if you're not
25 going to show her the document, that's the best she
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!"#$%&'()%*+&,+-#.&/$0+#.1%"&2&31*$+4&5%67
1 don't know where I was living.

2 Q Okay. Did you indicate whether you had
3 gone to school?
4 A Yes, I did.
5 Q What did you indicate?
6 A I indicated that I attended Survivors
7 Charter School for four years and had a high school
8 diploma.
9 Q And you graduated?
10 A Well, I didn't. I just wanted to get a
11 job, and I wanted it to look good, so I fluffed it
12 up.
13 Q So you wrote that down in your handwriting
14 on this application, correct?
15 A I did.
16 Q And it was not true, correct?
17 A Again, I'm not proud of it. I just didn't
18 have any other way of getting a job and I just
19 thought if I put that down there, I might be
20 considered.
21 Q You indicated when you were younger you
22 volunteered for six years at a riding clinic. What's
23 the name of the riding clinic?
24 A Vince Ramos. And I'm not too sure if it
25 was six years, but I started off there quite young,
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1 a former employer is the Indigo Bar and Grill,

2 correct?
3 A Yes.
4 Q Is that true?
5 A No, it was not.
6 Q On the page before that, it indicates you
7 went to Royal Palm Beach High School. Is that in
8 your handwriting?
9 A Yes, it is.
10 Q And it says you went for four years and
11 you graduated?
12 A Yes.
13 Q In your handwriting?
14 A Yes.
15 Q Is that true?
16 A No.
17 Q This was an application you filled out in
18 January of 2014, correct?
19 A Correct.
20 Q The page before that is your -- portion of
21 your resume I think we have previously discussed, but
22 just confirming, you did send that resume to this job
23 application, correct?
24 A I did.
25 Q And you indicated you had worked at
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4 I, Pamela J. Hansen, do hereby certify that
5 I am a Registered Professional Reporter and Notary
6 Public within the State of Colorado; that previous to
7 the commencement of the examination, the deponent was
8 duly sworn to testify to the truth.
19 signature this 23rd day of November, 2016.
20 My commission expires September 3, 2018.
21
22 _______________________________
Pamela J. Hansen, CRR, RPR, RMR
24
25
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EXHIBIT R
EXHIBIT S
MAR-A-LAGO-0001
TERMINATIONS
LAST NAME FIRST NAME

Abbott Philip Box #1
Acevedo Michael Box #4
Adams Zane Box #3
Adams Cynthia Box #1
Adams Patrick Box #1
Addison Andrea Box #4
Adelfio Peter Box #4
Adler Jessica Box #1
Aldahondo Francisco Box #6
Alexis Genicia Box #3
Allen Suzanne Box #1
Almeida Tiberio Box #4
Almgren Shane Box #3
Alves Victor Box #4
Anaya Orlando Box #4
Anderson Sandra Box #6
Andres-Felix Francisco Box #4
Annunziata Susan Box #3
Anton Frank Box #1
Aquino Jorge Box #4
Argueta Irma Box #3
Armstrong April Box #4
Ash Carol Box #6
Ashenbrenner William Box #3
Auguste Firenze Box #6
Bacon John Box #4
Bader Susan Box #1
Bader Erwin Box #1
Baghouli Adel Box #6
Bahena Lucio Box #6
Baker Teresa Box #3
Balkunas Vicki Box #6
Banks Michael Box #4
Baranek Katherine Box #3
Baron Todd Box #6
Barr James Box #4
Barr Gail Box #1
Barrett Loraine Box #3
Barrill London Box #3
Beam Stephen Box #6
Beaudoin Louis Box #1
Beckett Sam Box #3
Benarroch Alice Box #1
Bend John Box #1
Benitez Sixta Box #3
Bennett Thomas Box #3
Benney Tabitha Box #3
Benoit Mark Box #1
Bernal Ana Box #6
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Bernhardt Gretchen Box #1
Berube Michael Box #4
Beswick Allan Box #6
Beverly Tim Box #4
Bezwiechin Cham Box #3
Blake Howard Box #3
Bloch Michael Box #3
Blyth Alison Box #6
Bobrowski Michele Box #3
Bocksch Kristy Box #4
Boehm Erica Box #3
Boettcher Joe Box #6
Bogert Debra Box #3
Boisvert Cory Box #1
Bonilla Jose Box #4
Bork Allen Box #4
Borrego Sandra Box #4
Borrell Salvator Box #1
Borrelli Lisa Box #6
Boudreau Matthew Box #4
Boukhalfa Said Box #6
Bouschet Courtney Box #4
Brass Baysson Box #1
Brassler Chris Box #1
Brendel Kendra Box #6
Brennan Mary Box #1
Briante Gerard Box #1
Bridger Jody Box #3
Briggs Jacqueline Box #1
Brown Eleanor Box #6
Brown William Box #6
Brummel Denis Box #3
Bryan Amy Box #1
Bryant William Box #4
Buckingham Annette Box #1
Buckley Cynthia Box #4
Budziak Diane Box #1
Burdett Jill Box #6
Burgess Lawrence Box #3
Burgon Helya Box #6
Burke Maureen Box #4
Burke Christopher Box #4
Burlew Gary Box #1
Burton Myles Box #3
Butler Michael Box #4
Calder Malgorzata Box #3
Caldwell Karen Box #1
Camacho Darren Box #4
Camilleri Mark Box #4
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MAR-A-LAGO 0162
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Campbell Benjamin Box #3
Candella Charles Box #4
Cantrell Dantelle Box #4
Capozzi Christina Box #4
Carlisle Kevin Box #1
Carr Janet Box #3
Carroll VALerie Box #4
Carvalho Deo Box #3
Casher Jeremy Box #1
Castano Ku Box #4
Castillo Sandra Box #6
Castro Juan Box #4
Catranbone Angela Box #1
Cavinee Krystal Box #4
Celestin Jean Box #3
Chambers Craig Box #1
Chapuis Rene Box #1
Charles Fresnel Box #6
Charles Sylfida Box #6
Chillingsworth Vanette Box #6
Chioffe James Box #1
Christie Michael Box #4
Ciaffone Cora Box #6
Ciccia John Box #3
Clark Kimberly Box #1
Cleveland Trisha Box #6
Cloninger Tana Box #3
Coffman Connie Box #4
Cohen Julius Box #6
Cole Joanne Box #1
Collins Yvette Box #1
Collins Barbara Box #1
Conroy James Box #4
Cordero Vera Box #1
Cordero Vero Box #1
Cortes Roberto Box #3
Corti Debra Box #3
Coutts Rachael Box #1
Cox Emory Box #1
Cronin Sonia Box #6
Cross Deborah Box #6
Crostic Barbara Box #4
Crowley Tricia Box #6
Cruz Lonjino Box #6
Cruz Israel Box #6
Crystle Joshua Box #4
Cuervo Anamaria Box #4
Cummings Meghan Box #6
Curran Maureen Box #1
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Czerniak Anthony Box #4
Daley Chad Box #6
Damiano Anthony Box #4
Davis Jeremy Box #4
Davis Eric Box #1
Deak Stephen Box #6
Dean Laurie Box #6
Deleon Elais Box #4
Delia Frank Box #4
Dellay Scott Box #1
DeLorenzo Mark Box #6
DeNarvaez Claudia Box #3
DePaula Danielle Box #4
DeRiso Gina Box #1
DeSernia Sulamita Box #3
Devine Keith Box #1
DeVito Dawn Box #1
DiBenedetto Melissa Box #3
Dickens George Box #6
Dieu Donne Jean Charles Box #4
Dimitrova Violeta Box #3
Dodge Virginia Box #1
Dombayci Yimaz Box #6
Domnick Mark Box #1
Donnelly Jennie Box #3
Dorsa Antonio Box #1
Drake Charlie Box #6
Drogowski David Box #6
Dubois Lydia Box #4
Dubois Crystal Box #6
Dumstra Adam Box #6
Eaton Adam Box #4
Edge Jerod Box #4
Edwards Don Box #4
Egger Paul Box #6
Elkhoury Toni Box #6
Ellingworth David Box #6
Ellis Christine Box #1
Elwell Douglas Box #1
Enger Mark Box #3
English Mistie Box #3
Espinoza Francisca Box #4
Espinoza Henner Box #3
Espinoza Carlos Box #6
Estime Karl Box #1
Ettehad Shahla Box #4
Faaland Roy Box #1
Faba Juan Box #1
Fagen Lanell Box #1
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Faraci Franklin Box #1
Fasel Jeremy Box #4
Faulk Joel Box #1
Feal Jose Box #4
Feick Gretchen Box #4
Fein Lawrence Box #1
Fernandez Jose Box #6
Ferree Tonya Box #3
Fesser Michael Box #1
Fidanovic Novak Box #6
Figueroa Irina Box #3
Filippone Vittorio Box #4
Finch Michael Box #1
Finckenor George Box #4
Fink Roger Box #4
Fiorentino Maria Box #4
Firat Turabi Box #1
Fischbach Nora Box #3
Fischer Rosemary Box #4
Fiumara Michele Box #3
Flores Pedro Box #3
Folmer Ronald Box #1
Foss John Box #1
Fox Lisa Box #6
Francoeur Mary Lou Box #6
Fratus Donna Box #3
Frelich Jason Box #6
Frey Kenneth Box #4
Friday Jennifer Box #6
Frith Cynthia Box #1
Fritz John Box #1
Frost Mark Box #1
Gacon Allan Box #1
Galla Galla Box #1
Galloway Kurt Box #6
Galloza Sergio Box #3
Garcia Souad Box #6
Garcia-Douglas Marcia Box #6
Garrido Dante Box #4
Gedeum Rosalie Box #3
Gell William Box #3
Gervais Marie Box #6
Getgood Russell Box #1
Gibeault Larry Box #1
Gillie Barbara Box #1
Gividen Nathan Box #1
Glass Kevin Box #1
Goicochea Darcy Box #6
Goldrich Amanda Box #3
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Golemis Sam Box #3
Gomaa Ashraff Box #6
Gonzales Augustine Box #4
Gonzales Dora Box #4
Gonzalez Raul Box #3
Gonzalez David Box #1
Gonzalez Elsa Box #1
Gonzalez Alex Box #6
Goodman William Box #4
Goupy Bernad Box #6
Gowdy Charles Box #1
Granjales Myriam Box #6
Grant Everton Box #4
Grasso William Box #3
Graves Erika Box #4
Green Michelle Box #1
Greene James Box #1
Greenwood Elizabeth Box #1
Gregson Scott Box #3
Grieve Daniel Box #3
Griffin Mark Box #1
Griffin Michael Box #1
Griffiths Sandra Box #1
Griggs Dora Box #3
Grosso Peter Box #1
Guerin Jean Box #1
Gutierez Mauricio Box #1
Gutierez Porfidio Box #1
Gutierrez Antonio Box #3
Guyierrez Warren Box #6
Hader Karen Box #3
Hagen Kyla Box #1
Haggar Karen Box #3
Hamby Michael Box #1
Harris Dan Box #6
Hartsough Cheryl Box #1
Hatch Wendy Box #1
Hatfield Michael Box #1
Havican Robert Box #6
Heanssler Pete Box #3
Hefel Eric Box #6
Hemings Romy Box #6
Hennessee Jason Box #3
Hernandez Gladys Box #3
Hernandez Alexander Box #3
Hernandez Luis Box #3
Herrara Julio Box #4
Herth Francesca Box #3
Higgins Jennifer Box #4
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Higgs Kathleen Box #1
Hill Donna Box #4
Hill Samuel Box #1
Hinkin Cynthia Box #3
Ho Stella Box #1
Hochong Anthony Box #6
Hodes Robin Box #4
Holcomb Mary Box #3
Holryid Mary Box #1
Homenuik Wilfred Box #6
Hong David Box #6
Hopkins Victoria Box #6
Horsky George Box #3
Hossain Mohammed Box #1
Hoyle Patricia Box #4
Huber Frank Box #4
Huguet Roberto Box #3
Hulsey Thomas Box #4
Hutchins Marguerite Box #4
Hyde Rose Box #6
Hylton Longsworth Box #6
Ibrahim Ashraf Box #4
Infante Carlos Box #4
Insani Mark Box #3
Ioli Gina Box #4
Irvine Marche Box #3
Jacob Maureen Box #1
Jacobs Rick Box #1
Jacques Dudley Box #1
Jacques Nixon Box #6
Jaferali Errol Box #4
James Buddy Box #6
Jankowski Keith Box #1
Jaramillo Olmes Box #1
Jean Jacques Box #6
Jenkins Todd Box #4
Jesperson Henrik Box #3
Johnansen Elise Box #6
Johnson Eric Box #4
Johnson Josh Box #4
Johnson Chad Box #1
Johnson Debbie Box #1
Johnson Laura Box #1
Johnson Jade Box #1
Johnson Walter Box #1
Johnson Cathiejo Box #6
Jones Steve Box #4
Jones Regina Box #3
Joseph Elisca Box #6
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Juan Miguel Tomas Box #4
Juan Angelina Box #6
Kaiser Stephen Box #4
Kalson Vince Box #1
Kapreilian Peter Box #4
Karius Michael Box #4
Kaufman Robert Box #1
Keady Mike Box #1
Keiser Lisa Box #4
Keller Mikchael Box #4
Kelley Nancy Box #1
Kelly Lois Box #4
Kelly John Box #1
Kennedy Sean Box #3
Kenney Marlou Box #3
Kenny Brian Box #4
Kent Scott Box #4
Kincl Joseph Box #4
King Helen Box #4
King Jeffrey Box #3
King Michael Box #6
Kirby Brian Box #1
Kleinfeld Robert Box #1
Kline Eileen Box #6
Kole Karen Box #4
Kowalski Susan Box #1
Kresic Blago Box #1
Krogman Terry Box #1
Krpina-Zito Marija Box #4
Kruppenbacher Michael Box #6
Kuiper Gary Box #3
Kuntz Carlson Box #4
LaCerte Troy Box #1
Laidlaw Kenneth Box #3
Laine Brent Box #6
Laing Melissa Box #6
Lang Eric Box #4
Langford Chad Box #6
Langweiler Albert Box #1
Lanunziata Stacia Box #6
Laskaris Alexandra Box #1
Laufenberg Lynette Box #1
Lawlor Thomas Box #3
Lefrancois Aaron Box #3
Leite Paulo Box #1
Leitzell jTara Box #4
Leone Nick Box #1
Leonova Victoria Box #6
LeRoux Marthinus Box #6
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Lester Carolina Box #6
Lewis Corey Box #1
Leyden Gene Box #6
Liberte Monney Box #3
Lightbourne Andrianne Box #1
Lisec Lisa Box #1
Locke Michelle Box #3
Logalbo Franklin Box #6
Lopez Claudio Box #4
Lopez Julian Box #3
Lopez Marvin Box #3
Lopez Mario Box #6
Lopez Roger Box #6
Love Rena Box #3
Lowe Karl Box #3
Lugo Christianne Box #3
Lusse Robert Box #1
Luxton Stephanie Box #4
Lyle Mary Jane Box #6
Lynam Robert Box #6
Lynch Cheri Box #3
MacDonnell Thomas Box #7
Machado Carlos Box #4
Magerus Georges Box #4
Malay Maya Box #3
Maldonado Juvencio Box #1
Maldonaldo James Box #7
Mann Andrew Box #3
Mannion Deidre Box #4
Marcenaro Eduardo Box #1
Marchman Henry Box #4
Marino Mindy Box #1
Marrone Kimberly Box #3
Marshall John Box #7
Martinez Steve Box #1
Martinez Zach Box #7
Martinez Hector Box #7
Massias Caroline Box #4
Mateo Alfredo Lucas Box #1
Maurice Marie Box #3
Max Susan Box #1
Maxwell Terence Box #7
McAlees Brook Box #4
McBrayer Cassandra Box #1
McCabe Kevin Box #3
McCambridge Angela Box #1
McCann Kevin Box #3
McCarthy Shannon Box #3
McConnell James Box #4
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McCormick Jennifer Box #7
McDaniel Elizabeth Box #4
McDonald Amanda Box #3
McDonald Deborah Box #1
McFarland Robert Box #4
McGreevy Barbara Box #1
McKee Wende Box #4
McKeen Nohora Box #3
McKim Mark Box #1
McLean Stephen Box #4
McMahon Leo Box #7
McMiled Patricia Box #3
McNaughton Sean Box #7
McNicholas Marie Box #3
Mead Paul Box #7
Meade Raymond Box #1
Mena Arturo Box #1
Merchant Kenneth Box #4
Merriman Rita Box #7
Mesa Uenoi Box #3
Messemer Brian Box #4
Metayer Edenes Box #4
Metayer Marie Box #1
Michaels Jesse Box #7
Michel Bernadette Box #7
Miller Eric Box #3
Miller Lisa Box #3
Miller Ronald Box #7
Milosevic Sas Box #1
Miranda Cari Box #7
Mitchell Edward Box #4
Mohamed Waleid Box #4
Monaco Lettia Box #1
Monia Gregory Box #1
Monson Jill Box #7
Montano Helmuth Box #4
Montano Henry Box #4
Montecinos James Box #4
Moore Joel Box #2
Moran Tom Box #7
Moree Darlene Box #4
Moreno Aura Box #3
Morgan Todd Box #2
Morgan Jennifer Box #7
Morris Katherine Box #3
Morris Rebecca Box #7
Mosher Neil Box #2
Moss William Coury Box #4
Mullen Sony Box #7
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Mullen Cheryl Box #7
Munford Cheryl Box #7
Munoz Mariadelrocio Box #4
Musallet Hassan Box #2
Musso Diane Box #7
Myers Louisa Box #3
Myers Linda Box #7
Nagy Matthew Box #4
Nagy Viktoria Box #7
Nakoneczny Dawn Box #4
Narleski Linda Box #2
Nasie Waleed Box #7
Natal Luis Box #3
Neira Fernando Box #3
Nelsen Holly Box #2
Nelson Lisa Box #3
Nemets Tammie Box #3
Nieporte Joseph Box #4
Noe Thomas Box #7
Noel Marie Box #7
Nolan Susan Box #2
Northern Brad Box #7
Noufal Michel Box #2
O'Boyle Thomas Box #7
Oconnor Kevin Box #2
Oesterling Emily Box #7
Oldfield Janice Box #2
Oliver Meike Box #4
O'Neill Kathryn Box #2
O'Neill William Box #2
O'Neill Joseph Box #7
Orozco Clemente Box #3
Pagen Mitchel Box #2
Pagliaro Peter Box #4
Palomba Amanda Box #2
Parker Sandra Box #3
Parker Everett Box #2
Parkinson Nicole Box #4
Pavelka Nathan Box #2
Pavonni Michelle Box #2
Pedro David Box #4
Peison Brenda Box #7
Pelaez Juan Box #2
Penate Alexander Box #4
Perez Marlow Box #4
Perkins Tian Box #4
Perrey Arielle Box #2
Pesasico Crispin Box #4
Petery Pamela Box #7
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Petrillo Camille Box #3
Pharr Stephanie Box #4
Philips Ralph Box #3
Pickens Robert Box #2
Pientka John Box #2
Pierre-Noel Yvonne Box #4
Pinder Patricia Box #7
Pine Jon Box #3
Pino Alex Box #7
Pinto Julie Box #2
Piques Christian Box #7
Pisani Craig Box #2
Pisani Nicholas Box #2
Pitot Patrick Box #3
Pittinger Mark Box #4
Pitts Jeremiah Box #2
Plaine Victoria Box #3
Ponder Janet Box #3
Poston Roberta Box #4
Powell Nicole Box #3
Powell Kelley Box #7
Presto Nicholas Box #4
Price Robin Box #2
Prouty Joy Box #2
Prucien Mona Box #3
Quigley Christy Box #7
Quirao Maria Box #4
Rafrano Dawn Box #2
Ragland Leslie Box #2
Ramirez Roxana Box #2
Ramos Milka Box #3
Raphael-Dallas Jamie Box #3
Reardon Lisa Box #2
Reasinger Amy Box #2
Redmond Suzanne Box #2
Reed Diana Box #4
Reich Gwendalyn Box #2
Reil Richard Box #2
Reis Brian Box #7
Reis Charles Box #7
Reiser Scott Box #7
Rene Josette Box #4
Rene Jean Box #7
Rene Lamercie Box #7
Rennie Kerry Box #2
Reyes Randolfo Box #4
Reynolds Janice Box #7
Ribeiro Gregg Box #3
Richardson Brian Box #7
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Rinker Ross Box #7
Rivera Pablo Box #3
Rivera Eduardo Box #2
Rivero Alicia Box #7
Robbins Jody Box #4
Roberts Virginia Box #4
Roberts Walter Box #4
Roberts Diane Box #3
Robsham Lydie Box #7
Rodriguez Francisco Box #4
Rodriguez Abel Box #3
Rodriguez Kenia Box #3
Rodriguez Aristalia Box #2
Rogers Howard Box #2
Romeus Melege Box #2
Rony Jean Box #2
Roqueta Maria Box #2
Rose Cheryl Box #2
Rosenberg Bradley Box #2
Rosier Sandra Box #2
Rotchford Bernadette Box #4
Rubio Pascual Box #2
Rueda Maria Box #4
Ruiz Juan Box #2
Russeau Heidi Box #4
Russell Kathryn Box #4
Russotto Vincent Box #7
Ryan Megan Box #2
Ryan Michael Box #7
Saint Gerard Manes Box #7
Saint Surin Jacquest Box #2
Salloum Adib Box #2
Salman David Box #2
Salvador Marian Box #2
Sanford Kevin Box #5
Santos Elimos Box #2
Sasaki Shoko Box #7
Saunders Sarah Box #2
Savage Angelia Box #5
Savoie Terry Box #2
Scanlan Peter Box #5
Schlechter Melissa Box #5
Schmantowsky Craig Box #2
Schoonover Richard Box #2
Schroeder Glenn Box #5
Schumacher Patricia Box #2
Schwab Emily Box #2
Scotland Jaycen Box #7
Scott Cecelia Box #2
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Seebauer Gina Box #7
Seesholtz Joseph Box #2
Sellas William Box #2
Serpico Joseph Box #2
Sevilla Carlos Box #5
Shaw Tammy Box #7
Shelhamer Sage Box #7
Shepherd Michael Box #7
Shields Catherine Box #2
Shumate Regis Box #5
Shumpis David Box #7
Similien Raymond Box #2
Simms Amanda Box #7
Simpson Robert Box #7
Sineni Sandra Box #2
Singerline Thomas Box #2
Skinner Troy Box #2
Sluzenski Jonathan Box #7
Smith Jeremiah Box #5
Smith Ivan Box #5
Smith Meadow Box #2
Smith Debbie Box #2
Smith Elizabeth Box #2
Smith Fred Box #2
Snyder Lisa Box #7
Soler Luis Box #2
Soliman Alex Box #2
Sosa Anian Box #7
Southall Ginger Box #2
Souza Robert Box #2
Spencer Sxott Box #2
Sprague Steven Box #2
Springer Timothy Box #2
Stanfield Todd Box #5
Staniszewski Casey Box #7
Stankunas Jolanta Box #7
Stanley Lisa Box #2
Sta-Rosa Jaime Lindo Box #2
Steinberg Kathleen Box #2
Steinhaus Cynthia Box #2
Steliga Stephanie Box #5
Stenger Stuart Box #2
Stephans Dorian Box #2
Stewart Selvin Box #2
Strohminger Matthew Box #2
Stuart Susan Box #2
Stuhr Kenneth Box #2
Sturtevant Charles Box #5
Sucur Nicholas Box #7
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Sullivan Judith Box #2
Sumpter Drew Box #2
Swan Pyson Box #5
Sweeney Bridget Box #5
Swiderski Richard Box #2
Swiderski Mark Box #2
Sylne Romel Box #2
Tan Priscilia Box #2
Tarantino Vincenzo Box #2
Tatum Christopher Box #7
Taylor Kevin Box #5
Tempfli Glenn Box #2
Thelemaque {ierre Box #5
Thibeault William Box #7
Thiel Kurt Box #2
Thiel Ryan Box #2
Thomas Edward Box #2
Thompson Derek Box #2
Thompson Christine Box #2
Tomer Mary Box #2
Tonge Al Box #5
Torres Frank Box #5
Torres Iris Box #7
Toussant Elby Box #7
Trevino Danielle Box #2
Tsitsirides Alex Box #5
Tucker Marie Box #7
Uljic Gjon Box #2
Umpierre Frances Box #7
Valdez Bridges Box #2
Valdez Julie Box #2
Valenti Paul Box #2
Vandersloot Mildred Box #5
VanVliet Jane Box #2
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Vasquez Sosmar Box #5
Vasquez Christian Box #2
Vaughn Matthew Box #2
Velasquez Rodollfo Box #2
Vidalis Chantal Box #2
Voluck Justin Box #2
Vyskrebentsev Aleksey Box #5
Wahl Steven Box #5
Walker Sylvia Box #7
Walkowiak Toni Box #7
Wallace Philip Box #2
Ward Terry Box #5
Webb Jacob Box #7
Weber Ronald Box #2
Weidner James Box #7
Weisman Brian Box #2
Wentworth Gayle Box #2
Weslowski Elaine Box #2
White Scott Box #5
Whitley Deborah Box #7
Whitney Moriah Box #7
Whittle Tamara Box #2
Wilburn Jennifer Box #2
Williams Arhon Box #2
Williams Gretchen Box #2
Williams Jacqueline Box #2
Williams Ellen Box #7
Williams Kristin Box #7
Willoughby William Box #2
Willson Howard Box #5
Willson Joseph Box #2
Woolf Elena Box #2
Wynn Beverly Box #2
Yancey Kathryn Box #2
Yancey Scott Box #7
Yeskey Dean Martin Box #5
Young Todd Box #2
Zervoulis Matthew Box #2
Zivkovic Milo Box #2
Zorn Christopher Box #7
Zwick Danielle Box #2
Box #1 1998 terms

Box #2 1998 & 1999 terms
Box #3 1999 terms
Box #4 2000 terms
Box #5 2000 terms
Box #6 2001 terms
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Box #7 2001 terms
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EXHIBIT T
Case 18-2868, Document 278, 08/09/2019, 2628230, Page221 of 648 1
1 UNITED STATES DISTRICT COURT

for the
2 Southern District of New York
3
4
VIRGINIA GIUFFRE,
5
Plaintiff,
6
vs.
7
GHISLAINE MAXWELL,
8
Defendant.
9 -----------------------------------------------------
10 VIDEO-DEPOSITION Sky Roberts

OF:
11
TAKEN BY: Defendant
12
REPORTED BY: Karla Layfield, RMR
13 Stenographic Court Reporter
Notary Public
14 State of Florida at Large
15 DATE AND TIME: May 20, 2016; 8:33 a.m.
16 PLACE: Millhorn Law Firm

11294 North US Highway 301
17 Oxford, Florida
18 APPEARANCES: Laura A. Menninger, Esquire

HADDON, MORGAN & FOREMAN, PC
20 Attorney for Defendant
21 Brad Edwards, Esquire

Farmer, Jaffe, Weissing, Edwards,
22 FISTOS & LEHRMAN, PL
425 Andrews Avenue, Suite 2
23 Fort Lauderdale, Florida 33301
Attorney for Plaintiff
24
25 ALSO PRESENT: Kenneth Sarcony, Videographer

Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * owenassocs@aol.com
1 I N D E X
2 PAGE
WITNESS:
3
Sky Roberts
4
Direct Examination by Ms. Menninger 4
5 Cross-Examination by Mr. Edwards 133
Redirect Examination by Ms. Menninger 135
6 Recross-Examination by Mr. Edwards 141
7
Reporter's Certificate 143
8 Certificate of Oath 144
10 - - -
11
12
E X H I B I T S
13
18
19 (Exhibits attached.)
20
21
22
23
24
25
1 Q Do you remember there being a job posting that
2 you felt like was appropriate for Virginia or did you just
3 go out and talk to the woman who ran the spa area on your
4 own?
5 A I just talked to Angela.
6 Q Okay. Do you recall whether this was intended
7 to be a full-time job?
8 A I don't remember if it was full time or just
9 summer jobs or, you know, during season. It was probably
10 for a season because Mar-a-Lago is seasonal.
11 I mean, I was there year round but a lot of
12 people are seasonal, you know, because it's like
13 snowbirds, you know, summertime comes and nobody wants to
14 be down in south Florida.
15 Q What would you call the season, the seasonal
16 aspect of Mar-a-Lago? What's the season?
17 A Probably from September or October to, you know,
18 maybe May, I guess.
19 Q Is that the coolest time?
20 A Times of the year, yes.
21 Q And it's more guests that come during that
22 period of time?
23 A Yes.
24 Q And is there more staff brought on during that
25 period of time?
1 A Yes.
2 Q You saw that happen every year that you were
3 there?
4 A Every year.
5 Q And in the summer, it's relatively dead because
6 it's so hot?
7 A Basically, it closed during the summer. That's
8 when we would kind of work on everything and then make
9 sure everything is up to snuff for the next year, you
10 know.
11 Q Do you remember what capacity Virginia was hired
12 to work in, what her job title was, for example?
13 A I don't know. I would have lunch with Virginia.
14 That's about as much as I know about what she did. I was
15 busy all the time.
16 Q I understand.
17 A I didn't have time to go see what she was doing.
18 I didn't really talk to Angela about what she had to do.
19 I think that was her name, Angela. But it's kind of the
20 name that sticks out.
21 Q We'll just use Angela.
22 A We'll use that as the name.
23 Q But we know it may not be Angela.
24 A It may not be.
25 Q Just because we have to call her something,

1 A Where did I learn that?
2 Q Uh-huh.
3 A I think Virginia had told me that there was a
4 lady in the spa area named Ms. Maxwell. I don't know her.
5 I couldn't tell you what she looked like.
6 But just she said Ms. Maxwell said she can get
7 me a job with Jeffrey Epstein who is a friend of Donald
8 Trump, so I figured, well, he was a good guy or whatever,
9 you know, and that she was going to learn massage therapy.
10 Q When did Virginia tell you this?
11 A Oh, I can't tell you what date and time but I
12 don't remember.
13 Q I understand.
14 Did she tell you this while she was working at
15 Mar-a-Lago?
16 A Yes. I mean, after she had been there for a
17 little bit, you know, and then she told me, yes, that she
18 could possibly get this other job.
19 Q Okay.
20 A You know.
21 Q So she worked at Mar-a-Lago for a few months?
22 MR. EDWARDS: Form.
23 THE WITNESS: I have no idea. I don't know
24 how long she worked there. I don't remember.
1 A Uh-huh. Yes. It's not to me. It's up to her.
2 I think that's the way I told her, you know.
3 Q Did you ever meet Jeffrey Epstein?
4 A Once.
5 Q When was that?
6 A I dropped Virginia off at the house once and he
7 came out and I met him and seemed just fine to me. I
8 mean, you can't tell people by looking at them.
9 I mean, I know now from, you know, what I've
10 read that he's not a good guy. But you can't tell. You
11 know, you don't even know your neighbors sometimes, you
12 know.
13 Q Do you remember about when you dropped Virginia
14 off at his house that you met him?
15 A What do you mean?
16 Q Was it about the same time Virginia started
17 working with him?
18 A Yeah.
19 Q Was it later?
20 A I think it was about the time she started.
21 Because I wanted to see where she was at, you know. And
22 it was just a mansion down the street from, you know,
23 Mar-a-Lago. So I didn't think twice about it. I didn't
24 think nothing of it. He came out. He was very cordial,
25 very nice.
1 Q Do you remember any part of your conversation
2 with him?
3 A No. It was just that, you know how a parent has
4 to meet -- you know, if my daughter is going to work
5 somewhere, I just want to meet the guy and see what was
6 going on, you know. But I don't remember any
7 conversation, you know.
8 I just remember meeting him and that was it and
9 she walked into the house and --
10 Q All right. So you recall Mr. Epstein coming
11 outside of his home and greeting you?
12 A Yes.
13 Q Were you invited into his home?
14 A No.
15 Q Did you ever go inside of his home?
16 A No.
17 Q Other than that one time you dropped her off
18 there, do you ever remember going to that home?
19 A No. I couldn't tell you where it was at.
20 Q Okay. Did you meet anyone else while you were
21 there at the home?
22 A No.
23 Q Did you have a conversation with anyone else?
24 A No.
25 Q Did you every call Virginia at that home?

1 massage therapy.
2 Q All right. When she came home at night from
3 working with Mr. Epstein, did she look distressed to you
4 in any way?
5 A Not that I remember.
6 Q Okay. Did she report any complaints about her
7 job with Mr. Epstein?
8 A Not to me.
9 Q Okay. Did she report them to anyone else who
10 then reported them to you?
11 A No.
12 Q Your wife, for example?
13 A I have no idea. Like I said, if she did tell my
14 wife, I never heard about it.
15 Q Okay. Have you ever met Ms. Maxwell?
16 A Not that I remember ever meeting her.
17 Q Do you know what she looks like?
18 A No.
19 Q Did you ever meet anyone else who worked with
20 Mr. Epstein?
21 A No.
22 Q Do you remember anyone else who worked for
23 Mr. Epstein bringing your daughter home, for example?
24 A No.
25 Q Did your daughter ever move into the home where

1 C E R T I F I C A T E
2 STATE OF FLORIDA
3 COUNTY OF MARION
4 I, Karla Layfield, RMR, Stenographic Court
5 Reporter, do hereby certify that I was authorized to and
6 did stenographically report the foregoing deposition of
7 Sky Roberts; that said witness was duly sworn to testify
8 truthfully; and that the foregoing pages, numbered 1
9 through 142, inclusive, constitute a true and correct
10 record of the testimony given by said witness to the best
11 of my ability.
12 I FURTHER CERTIFY that I am not a relative or
13 employee or attorney or counsel of any of the parties
14 hereto, nor a relative or employee of such attorney or
15 counsel, nor am I financially interested in the action.
16 WITNESS MY HAND this day of May, 2016, at
17 Ocala, Marion County, Florida.
18
19
Karla Layfield, RMR
20 Stenographic Court Reporter
21
22
23
24
25
1 CERTIFICATE OF OATH
2 STATE OF FLORIDA
3 COUNTY OF MARION
4 I, the undersigned authority, certify that Sky
5 Roberts personally appeared before me and was duly sworn
6 on the 20th day of May 2016.
7 WITNESS MY HAND AND OFFICIAL SEAL this day
8 of May 2016.
10
11 Karla Layfield, RMR

Notary Public
12 State of Florida at Large
My Commission No. FF942806
13 My Commission Expires 12/10/2019
14
15 Personally Known
Professionally Known
16 Produced Identification of FDL
17
18
19
20
21
22
23
24
25
EXHIBIT U
EXHIBIT V
EXHIBIT W
EXHIBIT X
EXHIBIT Y
EXHIBIT Z
EXHIBIT AA
EXHIBIT BB
EXHIBIT CC
Confidential
Page 1

CASE NO. 15-CV-07433-RWS
------------------------------------------x
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
June 3, 2016
9:07 a.m.
C O N F I D E N T I A L
Deposition of DAVID RODGERS, pursuant

to notice, taken by Plaintiff, at the
offices of Boies Schiller & Flexner, 401
Las Olas Boulevard, Fort Lauderdale, Florida,
before Kelli Ann Willis, a Registered
Professional Reporter, Certified Realtime
Reporter and Notary Public within and
for the State of Florida.
Confidential
Page 2
2
3 A P P E A R A N C E S:
4 BOIES SCHILLER & FLEXNER, LLP
Attorneys for Plaintiff
5 401 East Las Olas Boulevard
6 BY: BRADLEY EDWARDS, ESQ.
7
8 HADDON MORGAN & FOREMAN, P.C.
Attorneys for Defendant
10 BY: JEFFREY PAGLIUCA, ESQ.
11
12
13 ALSO PRESENT: Sandy Perkins, Paralegal
Boies Schiller & Flexner
14
Ryan Kick, Videographer
15
16
17
18
19
20
21
22
23
24
25
Confidential
Page 3
2
3 I N D E X
4 Examination by Mr. Edwards .................... 5

Examination by Mr. Pagliuca .................... 209
5 Further Examination by Mr. Edwards ............. 217
8 E X H I B I T S
9 Deposition Exhibit 1 ........................... 6

Flight logs
10
Deposition Exhibit 2 ........................... 77
11 Photo

Photo
13
14 Photo

Photo
16
17 Photo

Photo
19
20 Confidential list

Equus Global Aviation offering
22
23
24
25
Confidential
Page 6
1 DAVID RODGERS
2 A. Yes.
3 Q. Can you -- can you tell me -- I have been
4 provided by your attorney a -- what has been
5 represented to be a copy, a direct copy of that
6 logbook. And I'm going to mark this as
7 Plaintiff's 1. I just want you to confirm that this
8 is an accurate copy of the original logbook that you
9 brought to your deposition today.
10 A. Yes.
11 MR. REINHART: Let him show it to you.
12 BY MR. EDWARDS:
13 Q. There you go.
14 (The referred-to document was marked by
15 the court reporter for Identification as
16 Deposition Exhibit 1.)
17 MR. REINHART: It is not a copy of the
18 entire book. It is the time period that was
19 covered by the subpoena. I just want to make
20 clear the book covers the time period outside
21 the subpoena.
22 MR. EDWARDS: Okay. I will let him
23 clarify that, of course, too.
24 THE WITNESS: Yes. It is logbook. It is
25 not 40 years, but it is my logbook.

Confidential
Page 7
1 DAVID RODGERS
2 BY MR. EDWARDS:
3 Q. Okay. You can keep this -- that down
4 there --
5 A. Okay.
6 Q. -- so we can keep track of the exhibits.
7 A. Okay.
8 Q. So does the copy that you just went
9 through, is that an exact copy of the original
10 logbook from the November 1995 date through, it
11 looks like, September 2013? That period of time?
12 A. Yes.
13 Q. Okay. And what is this book? What do you
14 call the book?
15 A. It is called the standard pilot master
16 log.
17 Q. All right. And who made the various
18 entries in the book?
19 A. I did.
20 Q. When did you make --
21 MR. PAGLIUCA: Brad, can you hang on for
22 one second.
23 MR. EDWARDS: Sure.
24 MR. PAGLIUCA: You said September 2013, I
25 thought.
Confidential
Page 8
1 DAVID RODGERS
2 MR. EDWARDS: That is what I have on the
3 last page.
4 MR. PAGLIUCA: My last page is 2008 on
5 this copy, 093 Bates label.
6 MR. REINHART: There's 108 pages to the
7 exhibit.
8 MR. PAGLIUCA: I'm missing the last 8
9 pages. That is why.
10 MS. PERKINS: Do you want the last copy?
11 What is your last page?
12 MR. PAGLIUCA: Ninety-three is my last
13 page.
14 That is why I only go through '08.
15 MS. PERKINS: So I will give you my '94 to
16 the end. That should give you a complete. Oh,
17 you're looking -- which one are you looking at,
18 the new one or the old one?
19 MR. EDWARDS: The one through '08.
20 MR. PAGLIUCA: Okay.
21 MR. EDWARDS: Okay. Are you ready, Jeff?
22 MR. PAGLIUCA: Yes.
23 BY MR. EDWARDS:
24 Q. When did you make each individual entry?
25 A. It could have been on that date that it

Confidential
Page 9
1 DAVID RODGERS
2 says. It could have been possibly a later date.
3 Most likely, fairly close to that date.
4 Q. Okay. How did you make sure that the log
5 entries that you were creating were accurate?
6 A. Well, people get on the airplane and I see
7 who the people are, and I put them down there.
8 Q. Okay. So you are making the notation at
9 or around the time that you are making this
10 observation -- the observations?
11 A. Correct.
12 Q. And you are recording the data accurately
13 in your logbook?
14 A. As accurately as I can.
15 Q. Okay.
16 A. Yes.
17 Q. Can we just look at the first page of the
18 exhibit?
19 A. Uh-huh.
20 Q. And if you could walk me through, let's
21 just take the first line.
22 A. Uh-huh.
23 Q. In the top left corner, there is a date.
24 A. Correct.
25 Q. And it says, "NOV '95." Is that you

Confidential
Page 10
1 DAVID RODGERS
2 indicating that this is November 1995?
3 A. Yes.
4 Q. Okay. And the first line under that in
5 the date column says 17. Is that November 17th,
6 1995?
7 A. Yes.
8 Q. Is that a notation that you would have
9 made on November 17th, 1995?
10 A. Yes.
11 Q. And the next column over under "aircraft
12 make and model," there is a number there. What is
13 that number?
14 A. That's the model of aircraft we're flying.
15 It's a G-1159B. It is Gulfstream, II-B aircraft.
16 Q. Okay. And then the next column over,
17 aircraft identification mark?
18 A. It is the registration number of the
19 aircraft.
20 Q. And what is the registration number? What
21 does that mean?
22 A. The number that is on the side of every
23 aircraft to identify what country it is from and
24 what particular airplane it is in that country. The
25 N means United States.

Confidential
Page 11
1 DAVID RODGERS
2 Q. And is that number unique to the aircraft?
3 A. Yes.
4 Q. So there is no other aircraft at the same
5 time bearing the identification number in N908JE?
6 A. That's correct.
7 Q. Who picks the identification number? I
8 understand N means United States.
9 A. Right.
10 Q. Who picks the 908JE?
11 A. It depends -- some aircraft, I mean, when
12 you get them, they already have the number on there,
13 and so that would be one way. Sometimes the
14 manufacturer puts them on there.
15 You can also request a certain number, if
16 you so chose to do so.
17 Q. Okay. The particular air -- these
18 particular logs were produced in a -- as a
19 consequence of a subpoena issued in the case of
20 Virginia Roberts Giuffre versus Ghislaine Maxwell.
21 A. Uh-huh.
22 Q. Is that your understanding?
23 A. Yes.
24 Q. And the period of time that we were
25 produced -- I understand you have flown for 40

Confidential
Page 12
1 DAVID RODGERS
2 years. The period of time -- or that is evidenced
3 by this logbook is '95 through 2013.
4 Why was it that period of time that was
5 chosen?
6 A. Because that is what the subpoena
7 requested.
8 Q. Okay. Is that when you started flying for
9 Jeffrey Epstein?
10 A. No.
11 Q. When did you start flying for Jeffrey
12 Epstein?
13 A. July of 1991.
14 Q. Okay. Do you have available today the
15 entries going back as far as July 1991?
16 A. I don't know. I have to look and see.
17 Q. Okay.
18 A. No. Because this is from 7/28 of '94.
19 Q. Okay. So that particular logbook begins
20 July 28th, 1994?
21 A. Yes.
22 Q. And were you privately flying for Jeffrey
23 Epstein on November 17th, 1995?
24 A. Yes.
25 Q. And is that Gulfstream that you described

Confidential
Page 13
1 DAVID RODGERS
2 a Jeffrey Epstein owned or controlled airplane?
3 A. It was -- let me think.
4 This was 908 Juliet, Echo -- I believe it
5 was owned by Hyperion Air, Inc., I believe.
6 Q. And is Hyperion Air, to your
7 understanding, a company associated with Jeffrey
8 Epstein?
9 A. As far as I know. I mean, I would assume
10 so, but --
11 Q. Was Jeffrey Epstein your primary
12 passenger --
13 A. Yes.
14 Q. -- on that airplane?
15 A. Yes.
16 Q. And who was the individual that gave you
17 direction as to what passengers to let on and off
18 the airplane and where to fly, et cetera?
19 A. Well, Jeffrey was usually -- I mean,
20 almost always on the airplane, unless we were going
21 to maintenance. And so when he got there, he would
22 have the people with him.
23 Q. Okay. So going back to the aircraft
24 identification mark, 908JE, does the JE signify the
25 initials of Jeffrey Epstein?

Confidential
Page 14
1 DAVID RODGERS
2 A. I would assume so.
3 Q. Okay.
4 A. But technically they are actually the
5 phonetic letters that we use. But technically it is
6 Juliet echo; it is not Jeffrey Epstein. As far as
7 radio phraseology, we don't answer Jeffrey Epstein;
8 we answer Juliet.
9 Q. Okay. But the JE doesn't signify some
10 jurisdictional code?
11 A. No.
12 Q. It is -- it is chosen by the owner of the
13 aircraft?
14 A. Right. Right.
15 Q. So as his pilot and as Jeffrey Epstein
16 being the main passenger, you have presumed that JE
17 signifies his initials?
18 A. I would assume so.
19 Q. In fact, we will get to it later down the
20 road, but the -- the other plane also bears the
21 ending initials JE; is that right?
22 A. Yes.
23 And this N number that's on this airplane
24 was eventually switched to another airplane.
25 Q. To the Boeing?
Confidential
Page 15
1 DAVID RODGERS
2 A. To the Boeing, correct.
3 Q. Okay.
4 So if we go back to this first entry, the
5 next column says, "From CMH."
6 A. Yes.
7 Q. And what is that?
8 A. Columbus, Ohio.
9 Q. That is an airport code?
10 A. Airport identifier.
11 Q. And, again, that airport code is unique to
12 a particular airport?
13 A. Correct.
14 Q. The next is "To PBI"?
15 A. Yes.
16 Q. Where is that?
17 A. West Palm Beach.
18 Q. And flight number? The next column says
19 "Miles Flown."
20 A. Right.
21 Q. That is not something that you log.
22 A. I don't.
23 Q. You kept pretty meticulous logs.
24 So the next column is flight log -- or
25 flight number?
Confidential
Page 99
1 DAVID RODGERS
2 Q. Okay.
3 A. But I'm not even sure we still had it at
4 this point in time.
5 Q. Yeah. It shows up on the next page. We
6 will get there.
7 A. Does it? Okay.
8 So then, yes, the answer is, yeah, we
9 still had the airplane. But we wouldn't have used
10 that.
11 Q. So is there any way of telling how Jeffrey
12 Epstein, Ghislaine Maxwell, Adam Perry Lang, and
13 Virginia were in the Virgin Islands on that, from
14 December 14th, 2000 --
15 MR. PAGLIUCA: Object to foundation.
16 BY MR. EDWARDS:
17 Q. -- based on your knowledge or your logs or
18 anything else?
19 A. No, I wouldn't have any way of knowing.
20 Q. Okay.
21 A. Because the next flight that they are on
22 was like this Palm Beach one, January 16th. So I
23 wouldn't have any idea.
24 Q. Okay. To your knowledge, did Jeffrey
25 Epstein ever fly commercially?

Confidential
Page 100
1 DAVID RODGERS
2 A. He probably has. Back then at this time,
3 I'm going to say probably not. But I know that he
4 has flown commercially. But usually that would be
5 like going to Europe, maybe.
6 Q. Okay. January 16th through the 25th,
7 those flights, do you see that block that I'm
8 talking about?
9 A. Yes.
10 Q. Jeffrey Epstein, Ghislaine Maxwell, Emmy
11 Tayler, and then at times Shelly Lewis, do you see
12 that?
13 A. Yes, right.
14 Q. The 25th it lands in Teterboro. And the
15 next day, on the 26th, leaves out of Teterboro with
16 Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, and
17 Virginia Roberts. This time you wrote the whole
18 name.
19 A. Right. Right.
20 Q. So when you write the full name, does that
21 signify -- that's when you may have learned her last
22 name?
23 A. Correct.
24 Q. And do you know how she -- how she got up
25 to New Jersey or New York?

Confidential
Page 103
1 DAVID RODGERS
2 Boeing?
3 A. Yes.
4 Q. The Boeing, was that previously owned by
5 The Limited or Les Wexner?
6 A. I'm not sure of the company name,
7 officially. But probably, yes.
8 Q. Some association with him?
9 A. Some association, yes.
10 Q. Do you know who flew the Gulfstream while
11 you were doing the simulator?
12 A. Well, it would have been Larry Visoski,
13 I'm not sure who the first officer was.
14 Q. Do you know if any logs were kept of the
15 passengers' names?
16 A. While I was at school?
17 Q. Right, while you were at school.
18 A. There probably were logs, but I don't know
19 where they are.
20 Q. Have you ever spoken with Larry about
21 whether he kept names of passengers?
22 A. I don't think he does.
23 Q. Do you know where Larry Visoski flew the
24 Gulfstream for the month that you were --
25 A. No.
Confidential
Page 107
1 DAVID RODGERS
2 different, because one day is the 5th; one day is
3 the 6th. But we landed there like at 11:50 at
4 night. And then when we took off, it was, you know,
5 the next day.
6 Q. Okay. Got it.
7 And then where do you go the next day?
8 A. We went from Stephenville to
9 Paris-Le Bourget.
10 Q. And who were the passengers going to
11 Paris?
12 A. Jeffrey Epstein, Ghislaine Maxwell, Emmy
13 Tayler, and Virginia Roberts.
14 Q. And then what's the next flight?
15 A. On the 8th, from Paris to -- I believe
16 that is in Spain.
17 Q. Granada, Spain?
18 A. Granada, Spain. Correct.
19 Q. Okay. And who are the passengers on that
20 trip?
22 Tayler, Virginia Roberts, Alberto and Linda Pinto,
23 one female, and Ricardo, it looks like Orieta.
25 A. From there to Tangiers. From Granada to

Confidential
Page 219
1 DAVID RODGERS
3 STATE OF FLORIDA )
4 COUNTY OF MIAMI-DADE )
5
I, the undersigned authority, certify
6 that DAVID RODGERS personally appeared before
me and was duly sworn.
7 WITNESS my hand and official seal
this 8th day of June, 2016.
8
9
Kelli Ann Willis, RPR, CRR
10 Notary Public, State of Florida
Commission FF928291, Expires 2-16-20
11 + + + + + + + + + + + + + + + + + +
12 CERTIFICATE
15 I, Kelli Ann Willis, Registered

Professional Reporter and Certified Realtime
16 Reporter do hereby certify that I was
authorized to and did stenographically report the
17 foregoing deposition of DAVID RODGERS; that a
review of the transcript was not requested; and
18 that the transcript is a true record of my
stenographic notes.
19 I FURTHER CERTIFY that I am not a
relative, employee, attorney, or counsel of any
20 of the parties, nor am I a relative or employee of
any of the parties' attorney or counsel connected
21 with the action, nor am I financially interested
in the action.
22 Dated this 8th day of June, 2016.
23
24 KELLI ANN WILLIS, RPR, CRR
25
EXHIBIT DD
INTENTIONALLY
LEFT BLANK
EXHIBIT EE
EXHIBIT FF
GM_01206
GM_01207
GM_01213
GM_01214
GM_01215
GM_01216
GM_01222
EXHIBIT GG
Page 1

------------------------------------------x
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
June 21, 2016

9:17 a.m.
Deposition of JOSEPH RECAREY, pursuant
Page 2
2 A P P E A R A N C E S:
3
4 BOIES SCHILLER & FLEXNER, LLP
5 Attorneys for Plaintiff
BY: BRADLEY EDWARDS, ESQ.
7
8 HADDON MORGAN & FOREMAN, P.C.
Attorneys for Defendant
10 BY: JEFFREY PAGLIUCA, ESQ.
11
12 JONES FOSTER JOHNSTON & STUBBS, P.A.
Attorneys for Deponent
13 505 South Flagler Drive
Suite 1100
14 West Palm Beach, Florida 33401
BY: JOANNE O'CONNOR, ESQ.
15
16 ALSO PRESENT: Sandy Perkins, Paralegal
Boies Schiller & Flexner
17
18
19
20
21
22
23
24
25
Page 3
2
3 I N D E X
4 Examination by Mr. Edwards .................... 9
Examination by Ms. Schultz ..................... 123
5 Examination by Mr. Pagliuca .................... 165
Further Examination by Ms. Schultz ............. 329
6 Further Examination by Mr. Pagliuca ............ 355
7
8 E X H I B I T S
Palm Beach Police Department
10 Incident Report
AH statement
12
13 CD with video (retained by Boies)
Search warrant return
15
16 Property receipts
Additional search warrant returns
18
19 Probably cause affidavit
Trash pull return
21
22 Folder with evidence
23
24
25
Page 4
2 Deposition Exhibit 10 .......................... 119
Investigative report
3
Deposition Exhibit 11 .......................... 165
4 CD with audio recording (retained by Boies)
Supplement to incident report
6
7 Rule 26 disclosure
Vol. 2 of prior Recarey transcript
9
10 Vol. 1 of prior Recarey transcript
11
12
13 *** Exhibit 11 was used on two different exhibits.
14
15
16
17
18
19
20
21
22
23
24
25
Page 10
1 JOSEPH RECAREY - CONFIDENTIAL
2 Q. Most of the events that we are going to
3 discuss today occurred, at least the investigation
4 that we're going to discuss today, occurred in 2005
5 and 2006.
6 So can you just tell us what your position
7 was with the Palm Beach Police Department at that
8 time?
9 A. I was a police detective.
10 Q. And did you investigate a person by the
11 name of Jeffrey Epstein?
12 A. I did.
13 Q. All right.
14 What was your role in the investigation of
15 Jeffrey Epstein?
16 A. I was the lead detective once the case was
17 turned over to me by Michelle Pagan.
18 Q. Okay. And as the lead detective, did you
19 review all of the history of the investigation up to
20 the point it was turned over to you?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Correct.
24 BY MR. EDWARDS:
25 Q. And was that one of your jobs as the lead
Page 11
2 investigator over a case, is to acclimate yourself
3 to the history of the case?
5 foundation.
6 THE WITNESS: Yes.
7 BY MR. EDWARDS:
8 Q. Just so that the record is clear, will you
9 just give a brief pause in case Mr. Pagliuca has an
10 objection?
11 A. All right.
12 Q. So they can also capture your answer.
13 A. Okay.
14 Q. In reviewing the history of the case, did
15 you review prior police reports, police reports
16 prior to you becoming involved personally?
17 A. I did.
18 Q. Okay. And I've handed you what is marked
19 as Plaintiff's Exhibit 1.
23 BY MR. EDWARDS:
24 Q. Do you recognize that?
25 A. Yes.
Page 177
2 Police Department incident report as suspects?
3 MS. SCHULTZ: Object to form and
4 foundation.
5 BY MR. PAGLIUCA:
6 Q. These people, right?
7 A. At that time, yes.
8 Q. Well, and then are you aware -- were there
9 any suspects added in any subsequent reports, to
10 your knowledge?
11 A. Not that I'm aware of.
12 Q. In fact, you did not seek a probable cause
13 warrant for any other suspects in this case,
14 correct?
16 foundation.
17 THE WITNESS: That's correct.
18 BY MR. PAGLIUCA:
19 Q. And Ms. Ghislaine Maxwell is not listed in
20 any of your Palm Beach Police Department incident
21 reports as a suspect in this case, correct?
23 foundation.
24 THE WITNESS: Not -- no, not as a suspect
25 in this case, no.
Page 180
2 Exhibit 1. Are you with me?
3 A. Uh-huh.
4 Q. Okay. Again, this was information that
5 was obtained by Detective Pagan, correct?
6 A. Correct.
7 Q. And it's true, is it not, that this
8 alleged victim never claimed to have been recruited
9 by Ghislaine Maxwell; true?
11 foundation.
13 BY MR. PAGLIUCA:
14 Q. And this individual, alleged victim No. 1,
15 never identified Ghislaine Maxwell as being at
16 Mr. Epstein's house when she was there, correct?
18 foundation.
19 THE WITNESS: I don't believe so.
20 BY MR. PAGLIUCA:
21 Q. You don't believe so --
22 A. I don't believe so.
23 Q. That she ever identified Ghislaine Maxwell
24 as being in the house?
25 A. Right.
Page 181
2 Q. Okay. She never -- this individual,
3 victim No. 1, never claimed that Ghislaine Maxwell
4 paid her any money, correct?
5 A. Correct.
6 Q. And this individual No. 1 never claimed
7 that Ms. Maxwell instructed her what to wear,
8 correct?
9 A. Right.
10 Q. This individual never claimed that
11 Ghislaine Maxwell told her how to act, correct?
12 A. Correct.
13 Q. This individual never claimed to have met
14 Ghislaine Maxwell ever, correct?
15 A. I don't believe so, no.
16 Q. This individual never claimed to even have
17 spoken to Ghislaine Maxwell ever, correct?
18 A. I don't believe so, no.
19 Q. And when you say "I don't believe so, no,"
20 that means my statement to you is correct; is that
21 right?
22 MS. SCHULTZ: Object to form, foundation.
23 THE WITNESS: Well, you're saying "ever."
24 I don't know if she's ever, ever spoken to --
25
Page 182
2 BY MR. PAGLIUCA:
3 Q. To Detective Pagan.
4 A. Right. To my knowledge, I don't know,
5 because Detective Pagan is the one who actually
6 interviewed her. So I don't know to the answer of
7 "ever." So not to my knowledge.
8 Q. Certainly, nothing in Exhibit 1, Narrative
9 1 reflects that this individual ever met or talked
10 to or spoke to Ghislaine Maxwell, right?
11 A. Right. Not to my knowledge.
12 Q. And, indeed, you would agree with me that
13 if this individual claimed that Ms. Maxwell had
14 something to do with the events listed in Narrative
15 1, you would have folded up on it, as the
16 investigating detective, right?
17 MS. SCHULTZ: Object to the form.
18 THE WITNESS: Either myself or Detective
19 Pagan would have.
20 BY MR. PAGLIUCA:
21 Q. Sure. And when you got the case six
22 months later, if there hadn't been follow-up, you
23 would have followed up on it, right?
24 MS. SCHULTZ: Object to form.
Page 187
2 Q. Okay. The person alleged to have brought
3 the alleged victim No. 1 to Mr. Epstein's house is
4 this Hayley Robson individual, correct?
5 A. Yes.
6 Q. Okay. Then with regard to alleged victim
7 No. 2, then this individual did not claim to have
8 been recruited by Ms. Maxwell, correct?
9 MS. SCHULTZ: Object.
10 THE WITNESS: Who would be victim No. 2?
11 BY MR. PAGLIUCA:
12 Q. Well, you can either go to the second page
13 of Exhibit 1 and we can just follow down the victim
14 information, or you can go to the body of the
15 report, whichever is easier for you.
16 MS. SCHULTZ: Can you use the initials?
17 MR. PAGLIUCA: Sure. I can call them 1 or
18 AH or whatever you want to call them. That's
19 fine with me.
20 BY MR. PAGLIUCA:
21 Q. So I'll just say alleged victim AH never
22 claimed to have been recruited by Ms. Maxwell,
23 correct?
24 A. Correct.
25 Q. And alleged victim AH did not claim to
Page 188
2 have spoken to Ms. Maxwell ever, correct?
4 THE WITNESS: It's been a while since I
5 read this report.
6 BY MR. PAGLIUCA:
7 Q. Sure. Is it fair to say, Detective, that
8 this investigation occurred some 12 years ago,
9 right?
10 A. Yeah. Well, yeah.
11 Q. And is it fair to say that you've
12 conducted quite a few investigations over your
13 career?
14 A. Yes.
15 Q. All right.
16 And it's fair to say that it would be
17 impossible for you to remember all the details of
18 this investigation as you sit here today, correct?
19 A. Correct.
20 Q. And you've been referring to Exhibit 1
21 frequently throughout this deposition, correct?
22 A. Yes.
23 Q. And that's because you don't have any
24 present memory of these details, correct?
Page 189
2 THE WITNESS: I have some recollection,
3 but I'm not going to have exact dates and times
4 off the top of my head.
5 BY MR. PAGLIUCA:
6 Q. Sure.
7 A. You know, I spoke to over 33 girls
8 regarding this case. So when you say an initial, it
9 takes me a little while to go through the entire
10 list. But to have specifics, I'm not going to be
11 able to remember the exact specifics of -- of the
12 report.
13 Q. I appreciate that.
14 So we can take our time, but do you
15 recall, did AH ever identify Ms. Maxwell has someone
16 she spoke to?
17 A. I don't recall.
18 Q. You don't recall at all?
19 A. I don't recall that she had mentioned
20 Ms. Maxwell.
21 Q. And if she had, you would have put that in
22 your report, correct?
23 A. I believe so, yes, I would have.
24 Q. All right.
25 And so the absence of alleged victim AH
Page 190
2 referring to Ms. Maxwell means that she didn't,
3 right?
5 THE WITNESS: Say the question one more
6 time.
7 BY MR. PAGLIUCA:
8 Q. When we go through this report, and I've
9 gone through it, if any of the alleged victims had
10 identified Ms. Maxwell as someone that they spoke to
11 at Mr. Epstein's house, you would have listed that
12 in your report, right?
14 THE WITNESS: I believe I would have, yes.
15 BY MR. PAGLIUCA:
16 Q. Yeah.
17 You tried to be thorough and accurate when
18 you were writing your reports, right?
19 A. Yes.
20 Q. And, certainly, you've indicated on direct
21 examination that the identity of people who were at
22 the house was something that was important to your
23 investigation, correct?
24 A. Yes.
25 Q. And that's why you did trash pulls, right?
Page 191
2 A. Yes.
3 Q. And then you asked various individuals who
4 was there when you went to Mr. Epstein's house,
5 right?
6 A. Correct.
7 Q. And you then, to the best of your ability,
8 recorded those answers, I take it, as to who was
9 there, right?
10 A. Yes.
11 Q. And with regard to AH, she never said
12 anything about Ghislaine Maxwell being at
13 Mr. Epstein's house, did she?
15 foundation.
16 BY MR. PAGLIUCA:
17 Q. To you?
18 A. I don't believe she did.
19 Q. Okay. And if she did, it's likely that
20 you would have recorded it, correct?
21 A. Correct, and it would be on the -- it
22 would be on the tape.
23 Q. Right.
24 She never claimed, AH, that Ms. Maxwell
25 paid her, right?
Page 192
3 foundation.
5 BY MR. PAGLIUCA:
6 Q. She never claimed that -- AH never claimed
7 that Ms. Maxwell instructed her about what to wear,
8 correct?
11 BY MR. PAGLIUCA:
12 Q. AH never claimed that Ms. Maxwell told her
13 how to act at Mr. Epstein's house, correct?
16 BY MR. PAGLIUCA:
17 Q. AH never claimed to have met Ghislaine
18 Maxwell anywhere, correct?
20 THE WITNESS: I don't believe so, no.
21 BY MR. PAGLIUCA:
22 Q. Okay. If we go on to individual alleged
23 victim No. 3, AY, the same question: AY never
24 identified Ms. Maxwell as someone she knew or
25 interacted with in any fashion, correct?
Page 193
3 THE WITNESS: No.
4 BY MR. PAGLIUCA:
5 Q. No, she did not?
6 A. No, she did not.
7 Q. Okay. The same with individual No. 4,
8 alleged victim FP: Again, FP never claimed to have
9 met with Ms. Maxwell, correct?
11 foundation.
13 BY MR. PAGLIUCA:
14 Q. Okay. And FP never identified Ms. Maxwell
15 as someone being at Mr. Epstein's house, correct?
17 foundation.
18 BY MR. PAGLIUCA:
19 Q. And if you need to look at your report --
20 A. No, I don't -- I don't believe so. The
21 only people that recalled Ghislaine at the house
22 was --
23 Q. Sjoberg?
24 A. Johanna Sjoberg.
25 Q. Who was over the age of 18, correct?
Page 194
3 foundation.
4 THE WITNESS: And Venero, Christina
5 Venero.
6 BY MR. PAGLIUCA:
7 Q. Who is an adult as well?
8 MS. O'CONNOR: Object to form.
9 THE WITNESS: Yes.
10 BY MR. PAGLIUCA:
11 Q. So out of your entire report, the only two
12 people who ever said anything about Ms. Maxwell were
13 Ms. Sjoberg, who I believe was 23 when you
14 interviewed her?
15 A. Right, but she was --
17 foundation.
18 THE WITNESS: She was -- she had worked
19 there for quite some time, so you would have to
20 back up, I think, a year or two.
21 BY MR. PAGLIUCA:
22 Q. She was an adult when she worked there?
23 A. Right. She was over the age of 18, right,
24 let's put it that way.
25 Q. And she was not listed by you as a victim
Page 195
2 as part of this case, right?
3 A. Correct, because it was between two
4 consenting adults.
5 Q. Exactly.
6 And so that's Ms. Sjoberg, and then the
7 other individual, I think you said Bolero; is that
8 right?
9 A. Venero, Christina Venero. She's a --
10 Q. Adult masseuse, correct?
11 A. Yes. I remember she had lots of tattoos.
12 Q. Tatts, right.
13 But the 17 individuals that you listed in
14 Exhibit 1, none of those individuals ever said the
15 word -- the words "Ghislaine Maxwell" during the
16 course of this investigation to you, correct?
18 foundation.
19 THE WITNESS: I don't believe so. It
20 would be on the tapes if they did.
21 BY MR. PAGLIUCA:
22 Q. Well, or it would be in your report,
23 right?
25 foundation.
Page 196
2 THE WITNESS: Either in the report or on
3 the tapes.
4 BY MR. PAGLIUCA:
5 Q. That's an interesting point, so let's talk
6 about that for a moment.
7 This report, this Palm Beach Police
8 Department incident report, Exhibit 1, is a summary
9 of your investigation, correct?
10 A. Correct.
11 Q. And these recitations of your interviews
12 are abbreviated summaries, correct?
13 A. Correct.
14 Q. And so you're typing into this report
15 parts of it but not every word verbatim into the
16 report, correct?
17 A. Right.
18 Q. And, again, the originals of these tapes
19 are somewhere with the FBI at this point, correct?
21 foundation.
22 THE WITNESS: Correct. Or at the State
23 Attorney's Office.
24 BY MR. PAGLIUCA:
25 Q. Are you aware of any of these originals
Page 203
2 That would be one. Probably victim JB would be
3 another. I believe there was a victim ML, as well.
4 Q. Let me ask this question: As you sit here
5 today, do you know who the subjects of the four
6 counts that are referenced on the first page of
7 Exhibit 7 are?
8 A. If I went through the entire PC affidavit,
9 I could -- I could tell you who. But I just named
10 three.
11 Q. Okay.
12 A. So, like I said, I can go through it and
13 tell you who exactly those four counts were for.
14 Q. Okay. We are limited to four, though,
15 right?
16 A. Four instances.
18 BY MR. PAGLIUCA:
19 Q. Right.
20 And then throughout this entire 22-page,
21 Palm Beach Police Department affidavit,
22 Ms. Maxwell's name does not appear in here once,
23 does it?
Page 211
2 A. Correct.
3 Q. And then Mr. Epstein is arrested and ends
4 up pleading guilty and all of that, right?
6 THE WITNESS: I think there was a
7 non-prosecution agreement prepared between the
8 Feds and some kind of agreement was made. But,
9 yes, he did end up pleading guilty.
10 BY MR. PAGLIUCA:
11 Q. All right.
12 Now, based on the questions that were
13 asked of you in the grand jury, it's fair to say
14 that Ms. Maxwell was not a target of the grand
15 jury's investigation, correct?
17 foundation.
18 THE WITNESS: Not based on the questions
19 that the state was asking me, no, the state
20 wasn't...
21 BY MR. PAGLIUCA:
22 Q. In fact, it's fair to say that you never
23 said Ms. Maxwell's name in the grand jury, right?
25 foundation.
Page 212
2 THE WITNESS: No. Based on the questions
3 that the state was asking, no.
4 BY MR. PAGLIUCA:
5 Q. Were you aware of who was being issued
6 subpoenas by the grand jury?
7 A. No. But it wasn't the actual subpoena
8 from the grand jury; it came from the State
9 Attorney's Office.
10 Q. At the direction of the grand jury,
11 though, right?
13 foundation.
14 THE WITNESS: I don't know. Again, I
15 don't know.
16 BY MR. PAGLIUCA:
17 Q. I would like to talk a little bit about
18 the surveillance that you initiated at Mr. Epstein's
19 house, okay?
20 Can you tell me when the surveillance
21 began?
22 A. It would have started under Detective
23 Pagan and gone through --
24 Q. The entire investigation?
25 A. Pretty much trash pulls. We stopped the
Page 213
2 actual physical surveillance sometime during the
3 investigation. But it would have started under
4 Pagan.
5 Q. Okay. Do you recall in what -- well, how
6 was surveillance conducted, if you recall?
7 A. I didn't conduct it personally, no. That
8 would have been under plainclothes unit team. They
9 would have sent out a vehicle and recorded vehicles
10 coming and going and actual physical surveillance.
11 Q. So physical surveillance means eyes on the
12 property, correct?
13 A. Right.
14 Q. And eyes on the property by a police
15 officer, correct?
16 A. Correct.
17 Q. And that police officer would be charged
18 with the obligation of recording the incomings and
19 outgoings of people to the property, correct?
20 A. Correct.
21 Q. Is there a log that's maintained during
22 surveillance?
23 A. I'm not sure who -- if there was a log or
24 not. I know that they set up a vehicle with cameras
25 facing -- facing Epstein's residence.
Page 214
2 Q. And so these were video cameras?
3 A. Correct.
4 Q. And so whoever was coming and going,
5 whenever -- an officer saw somebody coming or going,
6 they would videotape that person; is that correct?
7 A. Or they would just leave the video
8 rolling, time lapse.
9 Q. And did you have the opportunity to
10 observe any of that video?
11 A. I did observe a couple, but the person who
12 actually set it up would review it and then submit a
13 supplement to the report.
14 Q. Okay. It's true that none of the video of
15 the surveillance led to the identification of
16 Ghislaine Maxwell as coming or leaving the house
17 during the time of surveillance, correct?
19 foundation.
20 THE WITNESS: I don't know. I didn't see
21 all of the video, so I can't -- I can't attest
22 to that.
23 BY MR. PAGLIUCA:
24 Q. Okay. Did anybody report to you that
25 Ms. Maxwell was seen coming or going?
Page 215
3 THE WITNESS: I don't recall.
4 BY MR. PAGLIUCA:
5 Q. If someone had reported to you that
6 Ms. Maxwell was seen coming or going, you would have
7 recorded it in your Palm Beach Police Department
8 incident report, Exhibit No. 1, correct?
10 foundation.
11 THE WITNESS: I would have told the
12 officer who was conducting the surveillance or
13 reviewing the video to document it in the
14 supplements.
15 BY MR. PAGLIUCA:
16 Q. And there is no documentation in the
17 supplement of Ms. Maxwell either coming or going
18 from Mr. Epstein's house during this time frame,
19 correct?
21 THE WITNESS: I don't believe so. I
22 don't -- I don't -- I don't believe so.
23 BY MR. PAGLIUCA:
24 Q. And, again, so we're on the same page,
25 when you say "I don't believe so," I interpret that
Page 241
3 BY MR. PAGLIUCA:
4 Q. And none of these individuals was employed
5 as a massage therapist at the time of their alleged
6 involvement with Mr. Epstein, correct?
7 A. Correct.
8 Q. Each of these individuals, as I recall,
9 claimed to have been paid directly by Mr. Epstein or
10 Ms. Kellen, correct?
12 foundation.
14 BY MR. PAGLIUCA:
15 Q. Most often, these individuals, these 17
16 individuals, were paid directly by Mr. Epstein,
17 correct?
19 foundation.
20 THE WITNESS: Mr. Epstein or Sarah Kellen.
21 BY MR. PAGLIUCA:
22 Q. Okay. None of these individuals identify
23 Ms. Maxwell as someone who was paying them money,
24 correct?
Page 242
2 foundation.
4 BY MR. PAGLIUCA:
5 Q. And each of these individuals identified
6 receiving cash, correct?
9 BY MR. PAGLIUCA:
10 Q. Each of these individuals claimed varying
11 amounts, generally between $200 and up to $1,000,
12 correct?
15 BY MR. PAGLIUCA:
16 Q. According to each of these individuals,
17 Mr. Epstein, when the massage was over, would either
18 hand them the money -- that happened according to
19 these individuals, right?
21 THE WITNESS: At times, yes.
22 BY MR. PAGLIUCA:
23 Q. Or Mr. Epstein had laid out the money
24 somewhere and directed them to where to go get it,
25 correct?
Page 257
2 A. I don't believe clothing was seized.
3 Q. To your knowledge, did you seize any
4 property belonging to Ghislaine Maxwell from the
5 home?
7 foundation.
8 THE WITNESS: I'm not sure. Not to my
9 knowledge.
10 BY MS. SCHULTZ:
11 Q. Okay. No one ever came to you and said,
12 Could you please return these items to Ms. Maxwell,
13 correct?
15 THE WITNESS: No.
16 BY MS. SCHULTZ:
17 Q. All right.
18 You did that with Janush?
19 A. Yes, he had photos and --
20 Q. But nothing like that ever happened with
21 Ms. Maxwell, correct?
23 THE WITNESS: No.
24 BY MS. SCHULTZ:
25 Q. Ms. Maxwell was not present when you
Page 259
2 Q. Any way that you get contacted by a police
3 officer, if they put it into your database, it will
4 come up when you do the CAD search, correct?
5 A. Right.
6 Q. And that's all that came up with regard to
7 Ms. Maxwell, was her name was somewhere in the
8 system. Do you know or not know?
10 foundation.
11 THE WITNESS: I don't know.
12 MR. PAGLIUCA: Okay.
16 BY MR. PAGLIUCA:
17 Q. I have handed you what has been marked as
18 Deposition Exhibit 12, which I will represent to you
19 are the Plaintiff in this case, Ms. Giuffre's Rule
20 26 disclosure.
21 I want to just go through very quickly and
22 ask you if you know any of these individuals.
23 So, let's start with No. 1, Virginia
24 Giuffre. Have you ever met Virginia Giuffre?
25 A. No.
Page 260
2 Q. Have you ever talked to her?
4 Q. Do you know what information that she may
5 have that's referenced below? Conducted is the
6 subject of this action. Do you have any knowledge
7 of that?
8 MS. O'CONNOR: Object to form.
9 THE WITNESS: No.
10 BY MR. PAGLIUCA:
11 Q. Number 2, Ghislaine Maxwell, I'm going to
12 come back to her.
13 Number 3, Juan Alessi, you did interview
14 Mr. Alessi, correct?
15 A. Yes.
16 Q. I have seen a transcript of that
17 interview, and I have seen Exhibit 2, which is a
18 transcript of the interview with Ms. . I want
19 to ask you a couple of questions about the
20 transcription process.
21 As I understand your testimony previously,
22 the electronic recordings are sent somewhere, you
23 don't know where, for transcription; is that right?
25 THE WITNESS: I didn't request a
Page 274
2 different investigators Mr. Black uses in a
3 particular calendar year, do you?
5 THE WITNESS: No.
6 BY MR. PAGLIUCA:
7 Q. And so you don't know whether Mr. Black's
8 association with this law firm was in connection
9 with Mr. Epstein's case or some other case, do you?
11 THE WITNESS: I worked this case,
12 nothing -- nothing but this case for an entire
13 year. This was my only case for a year.
14 BY MR. PAGLIUCA:
15 Q. Okay. That's it?
16 A. If it walks like a duck.
17 MS. SCHULTZ: Objection.
18 BY MR. PAGLIUCA:
19 Q. Okay. So we're finished with Dershowitz.
20 Keep on going.
21 A. Number 28, obviously, .
22 Q. Okay. And you've talked about her?
23 A. Right.
24 Q. And, again, she never discussed Ghislaine
25 Maxwell with you, correct?
Page 278
2 Q. Right. So you're 75. So I want you -- I
3 want to take a moment and read what's under 75:
4 "Detective Recarey was the chief investigator of the
5 crimes committed at Jeffrey Epstein's Palm Beach
6 mansion." Is that true?
8 THE WITNESS: Yes.
9 BY MR. PAGLIUCA:
10 Q. "And has information about Ghislaine
11 Maxwell and Jeffrey Epstein's sexual trafficking
12 conduct and interaction with underaged minors."
13 Tell me everything that you believe you
14 know about Ghislaine Maxwell's sexual trafficking
15 conduct.
17 THE WITNESS: I don't.
18 BY MR. PAGLIUCA:
19 Q. So that's inaccurate, then? I mean, you
20 have no knowledge about Ghislaine Maxwell sexually
21 trafficking anybody, do you?
23 THE WITNESS: Not with -- not with the
24 girls that I spoke with, no.
25
Page 279
2 BY MR. PAGLIUCA:
3 Q. But that's your investigation, right?
4 A. Right.
5 Q. Okay.
6 A. Right.
7 Let's see. Seventy-six.
8 Q. Okay. And you've talked about her.
9 Whatever happened to her, do you know?
11 BY MR. PAGLIUCA:
12 Q. Haley Robson?
13 A. No.
14 Q. She was never charged, as I understand it,
15 correct?
16 A. Correct.
17 Q. And after you spoke to her in connection
18 with your investigation, did you ever speak to her
19 again?
20 A. No.
21 Q. Okay.
22 A. David Rogers, 77.
23 Q. And you know him because he was identified
24 as one of the pilots for Mr. Epstein, right?
25 A. Right.
Page 289
2 in your mind, right? Correct?
4 THE WITNESS: Yes.
5 BY MR. PAGLIUCA:
6 Q. And you're a peace officer, obligated to
7 arrest when a felony is committed in your presence,
8 correct?
9 A. Correct.
10 Q. And the possession of child pornography is
11 a felony, correct?
12 A. Correct.
13 Q. And had you seen any child pornography in
14 Mr. Epstein's house when you were there installing
15 these cameras, you would have done something about
16 it, correct?
17 MS. SCHULTZ: Object for form.
18 THE WITNESS: Right.
19 BY MR. PAGLIUCA:
20 Q. You wouldn't have just walked out and
21 said, Nice pics, have a nice day, correct?
22 A. Correct.
23 Q. So is it fair to say the entire time you
24 were in Epstein's house, whether it's 2002, 2003,
25 you did not observe any child pornography, right?
Page 290
3 THE WITNESS: Not in the areas I was in.
4 BY MR. PAGLIUCA:
5 Q. You don't recall seeing any pictures of
6 naked women, do you?
8 THE WITNESS: Again, I was only confined
9 to where that desk was. That's where I set up
10 the camera, and then after it was set up, I
11 left.
12 BY MR. PAGLIUCA:
13 Q. Okay. But, again, all I'm asking you is
14 wherever you were, you didn't see any pictures of
15 naked women?
16 A. Right. No, I didn't see any.
17 Q. And at the time you recall that he had
18 these surveillance cameras already installed; is
19 that true? Other cameras, the clock cameras?
21 THE WITNESS: I'm not sure if he had the
22 cameras installed or not. I can't recall.
23 BY MR. PAGLIUCA:
24 Q. Why would he need your cameras if he
25 already had cameras?
Page 300
2 None of these alleged victims claimed to
3 have ever traveled with Mr. Epstein, correct?
5 THE WITNESS: No.
6 BY MR. PAGLIUCA:
7 Q. No, they did not? They did not travel
8 with Mr. Epstein, right?
11 BY MR. PAGLIUCA:
12 Q. None of them reported that to you?
13 A. Not reported, correct.
14 Q. None of them reported to you that they
15 ever spent the night with Mr. Epstein, did they?
18 BY MR. PAGLIUCA:
19 Q. None of them ever reported being
20 trafficked by Mr. Epstein to other men, correct?
23 BY MR. PAGLIUCA:
24 Q. The only other men that any of these
25 alleged victims -- the only man that any of these
Page 301
2 alleged victims ever claimed to have any contact
3 with that was sexual in nature was Mr. Epstein,
4 correct?
6 foundation.
7 THE WITNESS: Yes.
8 BY MR. PAGLIUCA:
9 Q. Okay. None of these alleged victims ever
10 claimed to have been sent to another location to
11 have sex with another man, correct?
13 foundation.
15 BY MR. PAGLIUCA:
16 Q. Meaning my statement is correct; is that
17 right?
19 BY MR. PAGLIUCA:
20 Q. I'm just trying to --
21 A. Meaning I don't believe they've ever said
22 that. I don't recall any of them ever saying...
23 Q. Had they claimed that they were sent
24 somewhere else to have sex with another man, you
25 would have followed up on that, correct?
Page 302
4 BY MR. PAGLIUCA:
5 Q. And none of them ever claimed to have been
6 sent to another location to give another man a
7 massage, correct?
9 THE WITNESS: No, not the victims.
10 BY MR. PAGLIUCA:
11 Q. Right. That's who I'm talking about.
12 A. I believe did.
13 Q. Who is an adult, right?
15 THE WITNESS: Right.
16 BY MR. PAGLIUCA:
17 Q. We covered this, I believe: None of them
18 ever was on Mr. Epstein's airplane, correct?
20 THE WITNESS: I believe one of the victims
21 were, but not to a private island. I think
22 they went -- they didn't go to a private
23 island; they went to some other trip.
24 BY MR. PAGLIUCA:
25 Q. I think maybe you're referring to AH, who
Page 303
2 went to New York but on a commercial flight. Does
3 that jog your memory?
5 THE WITNESS: No.
6 BY MR. PAGLIUCA:
7 Q. Okay. Do you recall who it is?
8 A. It would have been FP.
9 Q. Okay. Was on Mr. Epstein's airplane?
11 THE WITNESS: I believe so.
12 BY MR. PAGLIUCA:
13 Q. Would that be reflected in Exhibit 1?
15 THE WITNESS: But she flew alone. It
16 wasn't like Epstein was there. She went
17 someplace else, not to his private island,
18 nothing to do with Epstein. It was something
19 she wanted to do. And I think she flew on his
20 plane, but it was, like, her by herself.
21 BY MR. PAGLIUCA:
22 Q. Alone.
23 A. Right.
24 Q. With a pilot?
25 A. Right.
Page 304
3 BY MR. PAGLIUCA:
4 Q. None of the alleged victims in your
5 investigation claimed to have gone to the Caribbean
6 island of Little St. James, correct?
8 THE WITNESS: No.
9 BY MR. PAGLIUCA:
10 Q. "No" meaning they never went there,
11 correct?
13 THE WITNESS: Not that I'm aware of.
14 BY MR. PAGLIUCA:
15 Q. None of the alleged victims ever went to
16 Mr. Epstein's New York residence, to your knowledge,
17 correct?
20 BY MR. PAGLIUCA:
21 Q. None of them ever reported that to you?
23 THE WITNESS: No.
24 BY MR. PAGLIUCA:
25 Q. Okay. And none of them ever claimed to
Page 305
2 have been outside of the country with Mr. Epstein,
3 ever, correct?
6 MR. PAGLIUCA: Can we go off for a second?
7 Time check.
8 THE VIDEOGRAPHER: Off the record at 4:13.
9 (Thereupon, a recess was taken, after
10 which the following proceedings were held:)
11 THE VIDEOGRAPHER: On the record at 4:14.
12 BY MR. PAGLIUCA:
13 Q. Can you take a look at Exhibit 4, please?
14 A. Which one is 4?
15 Q. Four is the True Copy. That's what it
16 says at the top. Exhibit 4. Six pages.
17 A. Yes.
18 Q. Do you have that?
19 A. Yes, sir.
20 Q. There's yellow highlighting on the exhibit
21 that's in front of you.
22 Do you know how that got there?
23 A. No.
24 Q. And there's a -- there are numbers, item
25 numbers. Do you see that in the left column?
Page 365
2
6
7 I, the undersigned authority, certify
8 that JOSEPH RECAREY personally appeared before me
9 and was duly sworn.
10 WITNESS my hand and official seal this
11 24th day of June, 2016.
12
13
KELLI ANN WILLIS, RPR, CRR
My Commission No. EE911443
15 Expires: 2/16/16
16 + + + + + + + + + + + + + + + + + +
17
18
19
20
21
22
23
24
25
Page 366
2
: ss
6 I, KELLI ANN WILLIS, a Registered
7 Professional, Certified Realtime Reporter and
8 Notary Public within and for The State of
9 Florida, do hereby certify:
10 That JOSEPH RECAREY, the witness whose
11 deposition is hereinbefore set forth was duly
12 sworn by me and that such Deposition is a true
13 record of the testimony given by the witness.
14 I further certify that I am not related
15 to any of the parties to this action by blood
16 or marriage, and that I am in no way interested
17 in the outcome of this matter.
18 IN WITNESS WHEREOF, I have hereunto set
19 my hand this 24th day of June, 2016.
20
21 __________________________
22
23
24
25
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CONFIDENTIAL
EXHIBIT KK
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EXHIBIT LL
EXHIBIT MM

CASE NO: 15-cv-07433-RWS
Plaintiff.
-vs-
GHISLAINE MAXWELL,
Defendant.
______________________________________/

Thursday, September 8, 2016
8:53 a.m. - 10:30 a.m.
VIDEOTAPED DEPOSITION OF BRITTANY HENDERSON
Taken before Rinat Katz, Reporter, a Notary

Public for the State of Florida at Large, pursuant
to Notice of Taking Deposition filed in the above-
styled cause.
1 APPEARANCES:
2 On Behalf of the Plaintiff:
3 BOEIS, SCHILLER & FLEXNER, P.A.
401 East Las Olas Boulevard, Suite 1200
Smccawley@bsfllp.com
5 BY: SIGRID MCCAWLEY, ESQUIRE
6 On Behalf of the Plaintiff and Victims Refuse
Silence, Inc.:
7
FARMER JAFFE WEISSING EDWARDS FISTO LEHRMAN
8 425 North Andrews Avenue, Suite 2
9 (954) 524-2820
Brad@pathtojustice.com
10 BY: BRADLEY J. EDWARDS, ESQUIRE
11 On Behalf of the Defendant:
12 HADDON, MORGAN & FOREMAN
13 Denver, Colorado 80203
(303) 831-7364
14 Jpagliuca@hmflaw.com
BY: JEFFREY PAGLIUCA, ESQUIRE
15
Also Present:
16
17
18
19
20
21
22
23
24
25
Page 3
1 INDEX OF PROCEEDINGS
2 VIDEO DEPOSITION OF BRITTANY HENDERSON PAGE
3 Direct Examination by Mr. Pagliuca 4
4 Certificate of Oath 73
Certificate of Reporter 74
5 Witness Letter 75
Errata Sheet 76
6
7 DEFENDANT'S EXHIBITS
8 NUMBER DESCRIPTION PAGE
9 Exhibit 1 Amended NOD 14
10 Exhibit 2 Motion to Quash Composite 20
11 Exhibit 3 Bates Stamped 01 - 064 31
12 Exhibit 4 Bates Stamped 064 - 091 32
13 Exhibit 5 Articles of Incorporation 36
14 Exhibit 6 Bank Statements 41
15 Exhibit 7 2015 Annual Report 62
16 Exhibit 8 2016 Annual Report 62
17
18 (Exhibits Retained by the Court Reporter)
19
20
21
22
23
24
25
Page 17
1 she has continued to try and promote Victims Refuse
2 Silence at every possible chance she gets with -- the
3 story she told me was that someone had come to her
4 door, knocked on the door, selling something or talking
5 about something totally different, and she explained
6 what our mission was and tried to get them to, then, go
7 and spread the word for victims of human trafficking,
8 as well.
9 Q And this would be in Australia this
10 conversation occurred?
11 A Correct.
12 Q Okay. To your knowledge, is VRS incorporated
13 in any fashion in the country of Australia?
14 A It is not.
15 Q To your knowledge, does VRS have any website
16 presence in Australia?
17 A I believe that the internet works everywhere,
18 so I would say yes, because, if you Google Victims
19 Refuse Silence, we do have a website. So I would
20 imagine that that's something that would come up in
21 Australia.
22 Q Okay. Other than the somebody knocking at
23 her door, that conversation, did she report to you
24 anything else that she has done on behalf of Victims
25 Refuse Silence in the last year, let's say?
Page 18
1 MR. EDWARDS: Objection --
2 THE WITNESS: During this telephone
3 conversation --
4 BY MR. PAGLIUCA:
5 Q Yes.
6 A -- or in general?
7 Q During this telephone conversation?
8 A She did explain that, when she goes to her
9 kids' schools and when she is out, she tries to promote
10 the organization, as well, and just talk to people, and
11 general awareness and understanding to raise -- for
12 issues of human trafficking, yes.
13 Q And did she report anything else to you
14 during this phone conversation?
15 A During this particular conversation?
16 Q Yes.
17 A No.
18 Q Okay. Then, you indicated that you reviewed
19 your file for all the paperwork, and we'll talk about
20 the documents produced in this case in a moment.
21 Can you tell me, other than what has been
22 produced as part of the response to subpoena issued to
23 VRS, what other documents are in the file that you
24 reviewed?
25 A I have saved every piece of mail that has
Page 27
1 "publication," would be the Facebook page; correct?
2 A In addition to the website, yes.
3 Q Okay. Number 11, documents relating to all
4 appearances. As I understand it, there are no
5 documents that exist that comply with this request;
6 correct?
7 A Correct; to my knowledge.
8 Q Do you know, has anybody on behalf of VRS
9 made a public appearance on behalf of VRS?
10 A I believe that there was a scheduled
11 appearance, yes, one.
12 Q And when was that?
13 A I honestly don't know when that took place.
14 I would imagine in the beginning of 2015.
15 Q And do you know who was scheduled to appear
16 in the beginning of 2015?
17 A Ms. Giuffre.
18 Q And do you know where she was scheduled to
19 appear?
20 A I believe in New York with ABC.
21 Q And that would have also been with Mr.
22 Edwards and Ms. McCawley; is that correct?
24 Q And in fact, she did go to ABC and give a
25 taped interview, correct?
Page 28
1 MS. MCCAWLEY: Objection.
2 THE WITNESS: It's my understanding, yes.
3 BY MR. PAGLIUCA:
4 Q Okay. Is it your understanding that that was
5 on behalf of VRS?
6 A I do not believe her appearance there was
7 made on behalf of VRS, but I do believe that -- I know
8 that she wanted to promote the charity, so that we
9 could start helping people and that she could start
10 getting her mission out to the public.
11 Q Okay. Number 12, all contacts received by
12 VRS through its website, or otherwise, to schedule -- I
13 think it should say "an event," and "and event."
14 There are none of those, as I understand it?
15 A No, that is not correct. We produced a --
16 yes, we did produce something to you. I'm not sure
17 what the Bates Stamp number is, but it was a contact
18 received by another victim of sexual assault who had
19 reached out to the organization.
20 Q An email, I think it's in December of 2015,
21 maybe; is that what you're referring to?
22 A I believe -- I'm not sure of the date. I
23 guess.
24 Q We'll look at it. And that would be the only
25 contact received by VRS; is that correct?
Page 72
1 C E R T I F I C A T E OF OATH
2
3 STATE OF FLORIDA
4 COUNTY OF BROWARD
5
6
7 I, Rinat Katz, Reporter, Notary Public, State
8 of Florida, certify that BRITTANY HENDERSON
9 personally appeared before me on the 8th day of
10 September, 2016, and was duly sworn.
11
12 Signed this 22nd day of September, 2016.
13
14
15 _________________________________
Rinat Katz, Reporter
Commission No.: FF4576
17 Commission Expires: 04-03-2017
18
19
20
21
22
23
24
25
Page 73
2
3 STATE OF FLORIDA
4 COUNTY OF BROWARD
5
6 I, Rinat Katz, Reporter, certify that I was
7 authorized to and did report the deposition of
8 BRITTANY HENDERSON, that a review of the
9 transcript was requested; and that the transcript
10 is a true and correct record of my stenographic
11 notes.
13 employee, attorney, or counsel of any of the
15 the parties' attorneys or counsel connected with
16 the action, nor am I financially interested in the
17 action.
18 Dated this 22nd day of September, 2016.
19
20
21 ____________________________________
Rinat Katz, Reporter
22
23
24
25
Generated: 08/09/2019 10:17:16


--------------------------------------------------X
.............................................
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Reply Brief in Support of Defendant’s

Motion for Summary Judgment
Laura A. Menninger
Jeffrey S. Pagliuca
Ty Gee
Denver, CO 80203
303.831.7364
TABLE OF CONTENTS
PRELIMINARY STATEMENT ......................................................................................... 1
ARGUMENT....................................................................................................................... 2
I. Ms. Maxwell is not liable for republications of the January 2015 statement. .............. 2
A. Plaintiff’s argument against summary judgment is substantially groundless. 2
B. New York state and federal courts have rejected liability for republication
based on “foreseeability.” ................................................................................ 5
C. Plaintiff’s purported application of the Geraci rule is misleading and wrong.

......................................................................................................................... 6
D. Subjecting Ms. Maxwell to liability for the media’s republication of excerpts

they unilaterally selected is particularly unfair. .............................................. 9
E. Mr. Barden’s declaration is perfectly proper. ................................................ 11
F. Plaintiff effectively has confessed Arguments I.B. and I.C. of the

Memorandum................................................................................................. 12
II. The January 2015 statement is constitutionally protected opinion. ............................ 12
III. The pre-litigation privilege bars this action. ............................................................... 20
A. The privilege applies to the January 2015 statement. ................................... 20
B. Malice is irrelevant to the pre-litigation privilege. ........................................ 21
IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. .................................... 25
V. Summary judgment is warranted because plaintiff cannot establish falsity or actual

malice by clear and convincing evidence. .................................................................. 25
CONCLUSION ................................................................................................................. 30
CERTIFICATE OF SERVICE .......................................................................................... 32
i
TABLE OF AUTHORITIES
Cases
Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). .............................................. 9
Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) ...................... 25
Cerasani v. Sony Corp., 991 F. Supp. 343, 351 (S.D.N.Y. 1998)................................... 3, 4
Chambers v. Wells Fargo Bank, N.A., No. CV 15-6976 (JBS/JS), 2016 WL 3533998, at
*8 (D.N.J. June 28, 2016) .......................................................................................... 2, 20
China Med. Techs., Inc., 539 B.R. 643, 658 (S.D.N.Y. 2015) .......................................... 12
Cowan v. City of Mount Vernon, 95 F. Supp. 3d 624, 645-46 (S.D.N.Y. 2015) ......... 13,25
Croy v. A.O. Fox Mem’l Hosp., 68 F. Supp. 2d 136, 144 (N.D.N.Y. 1999) ....................... 3
Dalbec v. Gentleman’s Companion, Inc., 828 F.2d 921, 927 (2d Cir. 1987) ................... 25
Davis v. Boeheim, 22 N.E.3d 999 (N.Y. 2014) ............................................................ 14,18
Davis v. Costa-Gavras (“Davis I”), 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984) ....... 2,3,4,6
Davis v. Costa-Gavras (“Davis II”), 595 F. Supp. 982, 988 (S.D.N.Y. 1984) ................... 3
Dibella v. Hopkins, No. 01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct.
30, 2002) ........................................................................................................................ 20
DiBella v. Hopkins, 403 F.3d 102, 111 (2d Cir.2005) ...................................................... 25
Egiazaryan v. Zalmayev (“Egiazaryan I”), No. 11 CIV. 2670 PKC, 2011 WL 6097136, at
*5 (S.D.N.Y. Dec. 7, 2011) ............................................................................................. 3
Egiazaryan v. Zalmayev (“Egiazaryan II”), 880 F. Supp. 2d 494, 501 (S.D.N.Y. 2012)
................................................................................................................................... 3,4,5
Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906) ............................................................ 2,4
Front, Inc. v. Khalil, 28 N.E.3d 15, 16 (N.Y. 2015) ................................. 2, 20,21,22,24,25
Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010) ..................................... 2,3,5,6,8,10,13
ii
Green v. Cosby, 138 F. Supp. 3d 114 (D. Mass. 2015) ..................................................... 14
Hawkins v. Harris, 661 A.2d 284, 289-91 (N.J. 1995) ................................................. 2, 20
Hickman v. Taylor, 329 U.S. 495, 510-11 (1947) ............................................................. 12
Hoffman v. Landers, 537 N.Y.S.2d 228, 231 (2d Dep’t 1989) ........................................... 5
Immuno AG v. Moor-Jankowski, 567 N.E.2d 1270, 1274 (N.Y. 1991) ............................ 13
Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (N.Y. 1980) ....................................... 3
Karedes v. Ackerley Grp., Inc., 423 F.3d 107, 114 (2d Cir. 2005) ................................... 26
Law Firm of Daniel P. Foster, P.C. v. Turner Broad. Sys., 844 F.2d 955, 959 (2d Cir.
1988). ................................................................................................................. 15, 28, 29
Levy v. Smith, 18 N.Y.S.3d 438, 439 (2d Dep’t 2015) ........................................................ 5
Liberman v. Gelstein, 605 N.E.2d 344, 349 (N.Y. 1992) .................................................. 22
National Puerto Rican Day Parade, Inc. v. Casa Pubs. (“NPR”), 914 N.Y.S.2d 120, 122-
23 (1st Dep’t 2010) ........................................................................................................... 5
Ollman v. Evans, 750 F.2d 970 (D.C. Cir. 1984) .............................................................. 13
Phila. Newspapers v. Hepps, 475 U.S. 767, 773 (1986). .................................................. 26
Porky Prods. v. Nippon Exp. U.S.A., 1 F.Supp.2d 227, 234 (S.D.N.Y. 1997) .................... 2
Rand v. New York Times Co., 430 N.Y.S.2d 271, 275 (1st Dep’t 1980) ....................... 9, 10
Rinaldi v. Viking Penguin, Inc., 420 N.E.2d 377, 382 (N.Y. 1981) .............................. 2,3,7
Rinaldi v. Viking Penguin, Inc., 425 N.Y.S.2d 101, 104 (1st Dep’t 1980) .......................... 3
Rizzuto v. Nexxus Prod. Co., 641 F. Supp. 473, 481 (S.D.N.Y. 1986), aff’d, 810 F.2d
1161 (2d Cir. 1986) ....................................................................................................... 16
Schoepflin v. Coffey, 56 N.E. 502 (N.Y. 1900) ................................................................ 3,5
Steinhilber v. Alphonse, 501 N.E.2d 550 (N.Y. 1986) ............................................ 11,13,16
iii
Sweeney v. Prisoners’ Legal Servs. of N.Y., 538 N.Y.S.2d 370, 371-72 (3d Dep’t 1989).
....................................................................................................................................... 19
Telephone Sys. Int’l v. Cecil, No. 02 CV 9315(GBD), 2003 WL 22232908, at *2

(S.D.N.Y. Sept. 29, 2003)........................................................................................ 16, 30
Travelers Indem. Co. v. Northrop Grumman Corp., No. 12 CIV. 3040 KBF, 2013 WL
3055437, at *3 (S.D.N.Y. Apr. 22, 2013) ..................................................................... 12
United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). ..................................... 25
Rules
Federal Rule of Civil Procedure 12(b)(6) ............................................................................ 5
Treatises
Sack on Defamation § 2.7.2, at 2-113 to -114 (4th ed. 2016) .............................................. 4
iv
PRELIMINARY STATEMENT
Before the Court reaches the question whether plaintiff can prove falsity and actual
malice, it should decide three questions of law, one that narrows considerably the legal issues
and two that dispose of the case entirely.
1. It is undisputed Ms. Maxwell, through her agents, sent to various media-
representatives—and to no one else—the January 2015 statement. It is undisputed she had no
control over any of the media that decided to republish excerpts from the statement. On these
facts, under black letter New York law, she is not responsible for these republications. Plaintiff’s
contrary argument relies on a “foreseeability” doctrine the New York Court of Appeals has
specifically rejected. Summary judgment should enter in favor of Ms. Maxwell as to any
republication.
2. Under the New York Constitution, whether a statement is constitutionally
nonactionable opinion depends upon, among other things, an examination of the full context of
the communication and consideration of the setting surrounding it. The January 2015 statement,
making no reference to specific allegations, explains why the author believes plaintiff’s
allegations are “obvious lies”: “Each time the story is re told [sic] it changes with new salacious
details . . . .” It is an expression of a venerable opinion: when a person falsely cries wolf
previously, others are free to opine she is telling falsehoods now. This is nonactionable opinion.
3. Under New York law, a statement made pertinent to good faith anticipated litigation is
nonactionable. The statement was sent exclusively to the media representatives, and contained a
clear message: the media should not republish plaintiff’s “obvious lies,” else Ms. Maxwell would
sue them. Such a statement is nonactionable.
If the Court reaches the question of falsity and actual malice, the Rule 56 record
establishes plaintiff cannot prove falsity and actual malice by clear and convincing evidence.
1
ARGUMENT
I. Ms. Maxwell is not liable for republications of the January 2015 statement.
Under black letter New York law, liability for republication of an allegedly defamatory
statement “must be based on real authority to influence the final product.” Davis v. Costa-
Gavras, 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984). “[W]here a defendant ‘had no actual part in
composing or publishing,’ he cannot be held liable.” Id. (citing Folwell v. Miller, 145 F. 495, 497
(2d Cir. 1906)); accord Geraci v. Probst, 938 N.E.2d 917, 921 (N.Y. 2010). “[C]onclusive
evidence of lack of actual authority [is] sufficiently dispositive that the [trial court] ‘ha[s] no
option but to dismiss the case . . . .’” Id. (emphasis supplied; quoting Rinaldi v. Viking Penguin,
Inc., 420 N.E.2d 377, 382 (N.Y. 1981)).
It is undisputed Ms. Maxwell and her agents had no ability to control and did not control
whether or how the media-recipients would use the statement. DOC. 542-7, Ex.J ¶¶ 2-3; id., Ex.K
¶ 24. Unsurprisingly, plaintiff has offered no evidence of such control. A fortiori this Court
“ha[s] no option but to dismiss the case,” id. (internal quotations omitted), to the extent it is
founded upon the media’s republication of the statement.
A. Plaintiff’s argument against summary judgment is substantially groundless.
A legal argument is frivolous if it is presented contrary to a “long line of authorities” and
the “fundamental principles”1 of the underlying substantive law. Plaintiff Giuffre’s argument
opposing summary judgment as to republication is frivolous.
The New York Court of Appeals in Geraci followed a long line of New York cases
holding that a defamation defendant is not liable for republication of his allegedly defamatory
statement unless he had “actual authority” to control the decision to republish: “Our
1
Porky Prods. v. Nippon Exp. U.S.A., 1 F.Supp.2d 227, 234 (S.D.N.Y. 1997), aff’d, 152
F.3d 920 (2d Cir. 1998).
2
republication liability standard has been consistent for more than one hundred years.” See
Geraci, 938 N.E.2d at 921 (footnote omitted). Indeed, the Geraci court observed, the New York
Court of Appeals in Schoepflin v. Coffey,2 a case decided in 1900, held:
“It is too well settled to be now questioned that one who . . . prints and publishes a
libel[] is not responsible for its voluntary and unjustifiable repetition, without his
authority or request, by others over whom he has no control and who thereby
make themselves liable to the person injured, and that such repetition cannot be
considered in law a necessary, natural and probable consequence of the original
slander or libel.”
938 N.E.2d at 921 (emphasis supplied; quoting Schoepflin, 56 N.E. at 504).
The cases in which this Court and its sister courts in this Circuit assiduously have
followed this line of New York cases are legion.3 The Second Circuit was in the vanguard.4
2
56 N.E. 502 (N.Y. 1900).
3
See Egiazaryan v. Zalmayev, 880 F. Supp. 2d 494, 501 (S.D.N.Y. 2012) (“[t]he original
publisher is not liable for republication where he had ‘nothing to do with the decision to
[republish] and [he] had no control over it.’”) (quoting Rinaldi v. Viking Penguin, Inc., 425
N.Y.S.2d 101, 104 (1st Dep’t 1980), aff’d, 420 N.E.2d 377 (N.Y. 1981)); Egiazaryan v.
Zalmayev, No. 11 CIV. 2670 PKC, 2011 WL 6097136, at *5 (S.D.N.Y. Dec. 7, 2011) (same);
Davis v. Costa-Gavras, 595 F. Supp. 982, 988 (S.D.N.Y. 1984) (“Under New York law, liability
for a subsequent republication must be based on real authority to influence the final product, not
upon evidence of acquiescence or peripheral involvement in the republication process.”); Davis,
580 F. Supp. at 1094 (original publisher not liable for injuries caused by the republication
“‘absent a showing that they approved or participated in some other manner in the activities of
the third party republisher’”) (quoting Karaduman v. Newsday, Inc., 416 N.E.2d 557, 560 (N.Y.
1980)); Croy v. A.O. Fox Mem’l Hosp., 68 F. Supp. 2d 136, 144 (N.D.N.Y. 1999) (“The original
author of a document may not be held personally liable for injuries arising from its subsequent
republication absent a showing that the original author approved or participated in some other
manner in the activities of the third-party republisher.”) (citations omitted); Cerasani v. Sony
Corp., 991 F. Supp. 343, 351 (S.D.N.Y. 1998) (“a libel plaintiff must allege that the party had
authority or control over, or somehow ratified or approved, the republication”).
4
See Folwell v. Miller, 145 F. 495, 497 (2d Cir. 1906) (affirming directed verdict in favor
of managing editor: “when it appears affirmatively that he was not on duty [upon receipt of
libelous matter and its republication], and could not have had any actual part in composing or
publishing, we think he cannot be held liable without disregarding the settled rule of law by
which no man is bound for the tortious act of another over whom he has not a master’s power of
control”) (emphasis supplied), quoted with approval in Davis I, 580 F. Supp. at 1096; Cerasani,
991 F. Supp. at 351.
3
In the face of this uninterrupted line of New York state (and federal) cases dating back to
the nineteenth century powerfully establishing a bright line rule regarding republication liability,
plaintiff Giuffre manages what amounts to a—frivolous—murmur of opposition. She claims
there are “[t]wo standards” in New York law: one “older,” and one “more modern.” Resp. 28.
The “older” standard, plaintiff says, is represented by the legion of cases we have cited. The
“more modern formulation”—where can it be found? Why, in one place: a treatise on
defamation. Id. (citing Sack on Defamation § 2.7.2, at 2-113 to -114 (4th ed. 2016)). It surely is
frivolous to argue that a treatise creates a republication-liability standard that is separate from,
“more modern” than, and supersedes the New York Court of Appeals’ 2010 decision in Geraci
and this Court’s 2012 decision in Egiazaryan.
Trying to build on this start, plaintiff argues, “New York appellate courts have repeatedly
held than an individual is liable for the media publishing that individual’s defamatory press
release.” Resp. 28 (emphasis supplied). Even if we accept plaintiff’s mischaracterization of the
January 2015 statement as a “press release,”5 her argument still would be meritless. To begin
with, when plaintiff says the New York appellate courts have “repeatedly” supported her claimed
rule of law, she means . . . twice. And an examination of those two cases reveals she is quite
wrong and, worse, has advanced a seriously misleading argument. Neither case involved, as here,
a motion for summary judgment. In both cases, the New York appellate division affirmed the
denial of a motion to dismiss under the state’s equivalent of Federal Rule of Civil Procedure
12(b)(6). See Levy v. Smith, 18 N.Y.S.3d 438, 439 (2d Dep’t 2015); National Puerto Rican Day
Parade, Inc. v. Casa Pubs. (“NPR”), 914 N.Y.S.2d 120, 122-23 (1st Dep’t 2010).
5
As discussed in This Reply, at 16-19, the January 2015 statement would be a strange
“press release,” as it threatened to sue the very press to which it was “releasing” information.
4
This argument, too, is frivolous. Despite plaintiff’s baseless claim there is an “old”
formulation and a “more modern” formulation of republication-liability law in New York, both
cases she cites applied the same “old” standard used by the New York Court of Appeals in
Geraci, by this Court in the two Egiazaryan cases, and by us in our Memorandum of Law in
support of Ms. Maxwell’s motion for summary judgment. See Levy, 18 N.Y.S.3d at 439 (citing
Geraci and Schoepflin); NPR, 914 N.Y.S.2d at 594-95 (citing Hoffman v. Landers, 537 N.Y.S.2d
228, 231 (2d Dep’t 1989) (citing Schoepflin)).
Both the courts in Levy and NPR applied the Geraci standard and the 12(b)(6) standards,
e.g., assuming the pleaded facts were true. They concluded it was possible to infer from the
complaints’ allegations that the defendant caused the republications. Accordingly, they denied
the motions to dismiss. See Levy, 18 N.Y.S.2d at 439; NPR, 914 N.Y.S.2d at 123. It was
improper for plaintiff to cite these cases without disclosing they are 12(b)(6) cases in which the
courts applied the Geraci republication rule and inferred facts from the pleaded allegations.
B. New York state and federal courts have rejected liability for republication
based on “foreseeability.”
Plaintiff cites section 576 of the Restatement (Second) of Torts for the proposition that if
republication was foreseeable, then the defendant is the cause of any special damages from the
republication. This argument is frivolous. As an initial matter, plaintiff has pleaded no special
damages. See Doc.1; Doc.23 at 23; Doc.37 at 17.
Regardless, the New York Court of Appeals in Geraci rejected the Restatement’s
foreseeability doctrine. See 938 N.E.2d at 921-22 (noting that section 576’s foreseeability
standard “is not nearly as broad as plaintiff . . . suggest[s]” and “[t]hat we did not endorse such a
broad [Restatement] standard of foreseeability in Karaduman is evident from our decision the
following year in Rinaldi”) (emphasis supplied).
5
While trying to distinguish this Court’s decision in Davis, plaintiff fails to disclose that
Davis itself—decided 26 years before Geraci—also rejected plaintiff’s foreseeability argument.
The Davis plaintiffs, like plaintiff Giuffre here, also asserted republication liability, despite
defendant’s lack of participation, on the ground “he could reasonably have foreseen that
republication would occur.” 580 F.Supp. at 1096. This Court, relying on Karaduman, was
unpersuaded: The New York Court of Appeals “has not applied the foreseeability standard
suggested by plaintiffs in prior libel cases in which such a standard would have been relevant, if
not controlling.” Id. This Court noted: The jurisdictions that have adopted a foreseeability
standard “have refused to hold responsible a defendant with no control or influence over the
entity that actually republished the statement.” Id. Plaintiff’s failure to disclose this Court’s
holdings in Davis is a notable lapse in candor.
C. Plaintiff’s purported application of the Geraci rule is misleading and wrong.
Plaintiff eventually purports to apply the “old” standard, that is to say, the controlling law
in the state of New York. She argues Ms. Maxwell “authorized” the January 2015 statement,
“paid money to her publicist to convince media outlets to publish it,” “request[ed]” its
publication, “made a deliberate decision to publish her press release,” “actively participated” in
“the decision to publish her press release,” was “active” in “influencing the media to publish” the
statement, and “approved of” and “pushed for” the publication of the statement. Resp. 30-31.
These argument-manufactured facts have no record support.
In applying the controlling law, plaintiff wittingly makes a mess of it. She disingenuously
suggests any help Ms. Maxwell gave to help her lawyer prepare the January 2015 statement and
her signing-off on it are the equivalent of requesting, authorizing and controlling its
republication. That isn’t the law. The “authority” required for republication liability is the
“actual authority . . . to decide upon or implement” the republication. 580 F.Supp. at 1095
6
(emphasis supplied; citing Rinaldi, 420 N.E.2d at 382). Judge Sofaer studied Rinaldi’s holding,
and noted republication liability must be based on a “decision” by the defendant to republish and
must focus on “real authority to influence the final product, not upon evidence of acquiescence
or peripheral involvement in the republication process.” Id. at 1096 (emphasis supplied).
Accordingly, Judge Sofaer held, when there is “conclusive evidence of lack of actual authority”
this is “dispositive” of republication liability and the trial court “‘ha[s] no option but to dismiss
the case against the [defendant].” Id. (emphasis supplied; quoting Rinaldi, 420 N.E.2d at 382).
There is no evidence Ms. Maxwell “paid money to her publicist to convince” the media
to publish her statement; this is why plaintiff cites no evidence to support that assertion. See
Resp. 30. Mr. Gow’s email containing the statement says nothing to “convince” the media to
publish the statement. See Doc.542-6, Ex.F. There is no evidence Ms. Maxwell was “active” in
“influencing the media to publish” it; nor is there any evidence she “pushed for” or “requested”
its publication; this is why plaintiff cites no evidence to support these assertions. See id. 31.
Indeed, plaintiff has zero evidence Ms. Maxwell or her agents ever did anything to urge
or request any media to publish the statement. Mr. Gow presented the January 2015 statement
via email to six to thirty media representatives; it was not sent to anyone else; in the email he
told the journalists he was presenting a “quotable statement” “on behalf of” Ms. Maxwell and
“[n]o further communication will be provided.” Doc.542-6, Ex.F. It is undisputed Ms. Maxwell
and her agents had no control over the media that republished portions of the statement.
Doc.542-7, 542-7, Ex.J ¶¶ 2-3; id., Ex.K ¶ 24.
Plaintiff argues “a jury” should decide whether Ms. Maxwell “authorized or intended”
the statement to be republished, or “approved of, and even participated, in” its republication.
Resp. 30-31. All plaintiffs want to get to “a jury.” The summary-judgment question is whether
they deserve to. Plaintiff has offered no evidence to put before a jury on the dispositive Geraci
7
question: whether Ms. Maxwell affirmatively authorized or requested a person or entity “over
whom [s]he has . . . control,” 938 N.E.2d at 921. The only new argument plaintiff makes in her
entreaty to see “a jury” is that she should be permitted to prove Ms. Maxwell’s “complicity.” As
with her other factually bereft arguments, the complicity argument awaits plaintiff’s introduction
of facts to support it. Having failed to do so, plaintiff cannot avoid summary judgment.
Plaintiff labors in vain to turn the Barden Declaration into “disputed issues of fact.” For
there to be a disputed factual issue, plaintiff would need to introduce evidence disputing his
sworn statements. She has not done so. In any event, the Barden Declaration is all but irrelevant
to the central, dispositive republication question: whether Ms. Maxwell is liable for the media’s
republication of her statement, where they did so without her authority or request and where she
and her agents had “no control”6 over the media. On this question we cited to the Barden
Declaration for one evidentiary fact: Messrs. Barden and Gow had no control over the media.7
See Doc.542-7, Ex.K ¶ 24, cited in Memo. of Law 14.8 Plaintiff has offered no admissible
evidence disputing this fact.
“[T]here is no issue for trial unless there is sufficient evidence favoring the nonmoving
party for a jury to return a verdict for that party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242,
249 (1986). It is one thing to argue in conclusory fashion, as plaintiff does, that “a jury” should
decide a factual question. It is quite another to identify evidence in the Rule 56 record that raises
a genuine question of material fact, which plaintiff does not do. Summary judgment is warranted.
6
Geraci, 938 N.E.2d at 921.
7
As discussed in Argument I.D., below, we cited more plenarily to the Barden
Declaration in connection with a different point—the particular unfairness of subjecting
Ms. Maxwell to liability when the media selectively quoted portions of the January 15 statement.
8
In the Memorandum, we erroneously cited to ¶ 24 of Exhibit J; we intended to cite to
¶ 24 of Exhibit K (Doc.542-1, Ex.K), which is Mr. Barden’s declaration.
8
D. Subjecting Ms. Maxwell to liability for the media’s republication of excerpts

they unilaterally selected is particularly unfair.
It is undisputed that no one ever republished in toto the January 2015 statement and that
various media unilaterally selected portions of the statement to republish. We said on page 14 of
our Memorandum that the media’s “selective, partial republication of the statement is more
problematic yet” (emphasis altered). That is to say, as improper as it is to hold a publisher of a
statement liable for republications over which she had no control, worse is it to make her liable
for selective, partial republications of her statement. We relied on the holding in Rand v. New
York Times Co., 430 N.Y.S.2d 271, 275 (1st Dep’t 1980), that a publisher cannot be charged with
a republisher’s “editing and excerpting of her statement.” Memo. of Law 14.
Plaintiff argues that our position is “absurd on its face” because “[i]t would mean . . . a
defamer could send to the media a long attack on a victim with one irrelevant sentence and, when
the media quite predictably cut that sentence, escape liability.” Resp. 32. This argument has two
erroneous assumptions. One is that the “defamer” can “escape liability.” Not true. An original
publisher remains liable for her defamation. We are concerned here with republication. The
second wrong assumption is that the original publisher must always remain liable for any
republication. Geraci rejects that view: Under New York law “each person who repeats the
defamatory statement is responsible for the resulting damages.” 938 N.E.2d at 921.
The effort by plaintiff to distinguish Rand is meritless. She argues the media’s
republication of the January 2015 statement actually was not a republication at all, just an
original publication. Resp. 32. That argument is “absurd on its face,” id., since there is no dispute
Ms. Maxwell did not control the media’s decision to republish (excerpts from) the statement.
Plaintiff next argues the media did not “edit[]” or “tak[e] . . . quote[s] out of context.” Id.
Plaintiff could not be more wrong. As she concedes, all republications of the statement by the
9
media were selective, partial republications of the statement. Any such selective, partial
republication by definition took those excerpts “out of context.” This is so because Mr. Gow
informed the media in his email that he was providing “a quotable statement,” Doc.542-6, Ex.F,
not a statement “from which you, the media, are free to excerpt as you please.”
More importantly, as Mr. Barden explained, selectively excerpting the statement
substantially altered his message. See id., Ex.K ¶ 20. For example, when he said in the third
paragraph that plaintiff’s claims are “obvious lies,” it followed two paragraphs in which he
explained why it was obvious the new claims are lies. See id., Ex.K ¶¶ 19-22. Excerpting and
republishing only the “obvious lies” phrase—as plaintiff did in her complaint—certainly gives
the reader a different understanding than if the media had republished the entire statement. As
Rand held: A defendant cannot be liable for the republication of derogatory but constitutionally
protected opinion “when the foundation upon which that opinion is based is omitted. The
defamatory remark should be read against the background of its issuance.” 430 N.Y.S.2d at 275
(internal quotations omitted).
Plaintiff argues: “A jury could reasonably conclude that [Ms. Maxwell’s] statement that
Ms. Giuffre’s claims of child sexual abuse are ‘obvious lies’ is not a rhetorical device, nor
hyperbole, but a literal and particular affirmation that [plaintiff] lied.” Resp. 33 (emphasis
supplied). We italicize plaintiff’s rhetorical sleight of hand. As plaintiff knows, nowhere did the
January 2015 statement specify which of plaintiff’s countless allegations are “obvious lies.”
Indeed, this is the problem with plaintiff’s case: since the statement specified no particular
allegations as obvious lies, plaintiff believes she is entitled to “prove” the truth of every
allegation she ever has made about her alleged experience as a “sex slave.” What Mr. Barden’s
declaration makes clear is he deliberately made no reference to any specific allegation by
plaintiff. He had a bigger target: plaintiff’s credibility. He used the statement to show plaintiff’s
10
behavior is that of a liar, i.e., one who increasingly embellishes her story, and her allegations
become more and more outlandish, so that by January 2015 she was claiming to have had sex
with a well respected Harvard law professor, Alan Dershowitz. See Doc.542-7, Ex.K ¶¶ 19-22.
Contrary to plaintiff’s argument, “even apparent statements of fact may assume the
character of statements of opinion, and thus be privileged, when made in public debate . . . or
other circumstances in which an audience may anticipate the use of epithets, fiery rhetoric or
hyperbole.” Steinhilber v. Alphonse, 501 N.E.2d 550, 556 (N.Y. 1986) (internal quotations and
brackets omitted). That was the case here. Plaintiff falsely—and, as Judge Marra held,
“unnecessar[ily]”9—alleged in lurid detail that Ms. Maxwell had sexually abused her. The six to
thirty journalists would have anticipated a “fiery” denial of the allegations. Regardless, the
statement overall was constitutionally protected opinion grounded on facts disclosed to the
journalists: plaintiff’s increasingly outlandish and inconsistent stories, her newly embellished
allegations, and her increasingly lurid and salacious enhancements of her earlier allegations.
E. Mr. Barden’s declaration is perfectly proper.
Plaintiff makes a plethora of complaints about Mr. Barden’s declarations. None has any
merit. She objects to Mr. Barden’s declaration of his intent and purposes for preparing the
January 2015 statement because, she says, this implicates the attorney-client privilege. That is
untrue. His intent and purposes are by definition not attorney-client communications and do not
implicate such communications; they are attorney work product,10 which he is free to disclose.11
9
Doc.542-5, Ex.E, at 5.
10
Travelers Indem. Co. v. Northrop Grumman Corp., No. 12 CIV. 3040 KBF, 2013 WL
3055437, at *3 (S.D.N.Y. Apr. 22, 2013) (identifying work product as including defense
counsel’s “mental impressions, thought processes and strategies connected with [the] defense”) .
11
See In re China Med. Techs., Inc., 539 B.R. 643, 658 (S.D.N.Y. 2015)
11
She objects he is “non-deposed.” But Mr. Barden was the third-listed potential witness in
our Rule 26(a)(1)(A) disclosure, served on plaintiff a year ago; the disclosure said he “has
knowledge concerning press statements by . . . Defendant in 2011-2015 at issue in this matter.”12
Plaintiff was free to depose him; that she chose not to was her own tactical decision. Finally,
plaintiff argues “there are factual disputes” regarding the declaration. But plaintiff identified no
such factual disputes relating to the declaration. A party opposing summary judgment cannot
create a dispute by arguing, which is all plaintiff does. See Resp. 35-38.
F. Plaintiff effectively has confessed Arguments I.B. and I.C. of the Memorandum.
Argument I.B. of the Memorandum contends the First Amendment bars liability for
republication by media organizations of the January 2015 statement. See Memo. of Law 16-17.
Argument I.C. contends that under Geraci plaintiff is barred from introducing into evidence any
of the media organizations’ republication of the January 2015 statement. See id. at 17-18.
Plaintiff offers no resistance to these arguments. We respectfully request that the Court consider
these arguments confessed. See, e.g., Cowan v. City of Mount Vernon, 95 F. Supp. 3d 624, 645-
46 (S.D.N.Y. 2015) (citing cases).
II. The January 2015 statement is constitutionally protected opinion.
In deciding whether a statement is opinion the New York Constitution requires
application of “the widely used four-part Ollman[13] formula,” Immuno AG v. Moor-Jankowski,
567 N.E.2d 1270, 1274 (N.Y. 1991). See id. at 1274, 1277-78, 1280-82 (noting Steinhilber’s
adoption of formula). We addressed each of the four Ollman factors. The plaintiff avoids this
analysis, choosing merely to block-quote large portions of this Court’s Rule 12(b)(6) order. That
12
Menninger Decl. EXHIBIT NN, at 2.
13
Ollman v. Evans, 750 F.2d 970 (D.C. Cir. 1984).
12
is a mistake. Immuno AG is the seminal case prescribing the analysis to be used in a summary-
judgment proceeding for assessing whether under the New York Constitution a statement is
absolutely protected as opinion.
Instead of addressing the four factors, plaintiff simply relies on this Court’s 12(b)(6)
order. The Court’s order does not control. In deciding the Rule 12(b)(6) motion, the Court
assumed the complaint’s allegations were true and drew all reasonable inferences in plaintiff’s
favor. In this proceeding, plaintiff is not entitled either to the assumption or the inferences. The
opinion-versus-fact question will be controlled by the Rule 56 record.
Relying on the Court’s order, plaintiff argues that the question whether the three
allegedly defamatory sentences are opinion or fact is controlled by Davis v. Boeheim, 22 N.E.3d
999 (N.Y. 2014), and Green v. Cosby, 138 F. Supp. 3d 114 (D. Mass. 2015). See Resp. 38. Davis
was an appeal from a 12(b)(6) dismissal. This procedural posture was critical to its decision:
[D]efendants argue that because a reader could interpret the statement as pure
opinion, the statement is as a consequence, nonactionable and was properly
dismissed [pursuant to a pre-answer motion]. However, on a motion to dismiss we
consider whether any reading of the complaint supports the defamation claim.
Thus, although it may well be that the challenged statements are subject to
defendants’ interpretation, the motion to dismiss must be denied if the
communication at issue, taking the words in their ordinary meaning and in
context, is also susceptible to a defamatory connotation. We find this complaint to
meet this minimum pleading requirement.
Davis, 22 N.E.3d at 1006-07 (internal quotations, brackets, ellipsis and citations omitted).
Green was a decision on the defendant’s motion to dismiss. The case was decided under
California and Florida defamation law. See 138 F. Supp. 3d at 124, 130, 136-37. The court made
it clear the 12(b)(6) procedural posture was critical to its decision: “At this stage of the litigation,
the court’s concern is whether any fact contained in or implied by an allegedly defamatory
statement is susceptible to being proved true or false; if so capable, Defendant cannot avoid
application of defamation law by claiming the statement expresses only opinion.” Id. at 130.
13
In the case at bar, application of the four Steinhilber factors on the Rule 56 record
compels a different conclusion. The complaint alleges three sentences in the January 2015
statement are defamatory: in the first paragraph of the statement, plaintiff Giuffre’s allegations
are “untrue”; in the same paragraph, the “original allegations” have been “shown to be untrue”;
and in the third paragraph, plaintiff’s “claims are obvious lies.”14 Doc.1 ¶ 30.
Factor 1: Indefiniteness and ambiguity. On the face of the complaint in a 12(b)(6)
proceeding, the words “untrue” and “obvious lies” might be susceptible of “a specific and readily
understood factual meaning,” Doc.37 at 9. This is especially true if it is taken out of context, e.g.,
extracted from the statement. But this approach is forbidden. See, e.g., Law Firm of Daniel P.
Foster, P.C. v. Turner Broad. Sys., 844 F.2d 955, 959 (2d Cir. 1988).
The first sentence—“[t]he allegations made by [plaintiff] against [Ms. Maxwell] are
untrue”—is indefinite and ambiguous because it is wholly unclear which “allegations” are being
referenced. The second sentence—“[t]he original allegations . . . have been fully responded to
and shown to be untrue”—also is indefinite and ambiguous for the same reason. Additionally, it
is unclear what are the “original” allegations. It is unclear what is meant by “shown to be
untrue.” What one person may believe is a fact shown to be untrue, another person may believe
is a fact not (sufficiently) shown to be untrue. The existence of God, climate change and
existence of widespread voter fraud in the election are examples of this. The third sentence—
14
Ms. Maxwell testified in her deposition that she “know[s]” plaintiff is a “liar.” This
testimony, plaintiff argues, “contradict[s]” our contention that the three allegedly defamatory
sentences in the July 2015 statement are opinion. Resp. 39-40. Plaintiff’s argument is a non-
sequitur. Ms. Maxwell’s 2016 deposition testimony in which she disclosed all the reasons she
believes plaintiff has uttered a plethora of false allegations is irrelevant to whether the three
sentences in the July 2015 statement, prepared by Mr. Barden to respond to the joint-motion
allegations, are opinions.
14
“[plaintiff’s] claims are obvious lies”—also is indefinite and ambiguous. An “obvious lie” to one
person is not an “obvious lie” to another.
Factor 2: Capable of being characterized as true or false. On the 12(b)(6) record, the
Court held the three statements “are capable of being proven true or false.” Doc.37 at 9. As a
general question of law, one person’s statement that another person’s allegations are “untrue” or
are “obvious lies” is not necessarily capable of being proved true or false—regardless of the
subject matter of the opined “untruths” or “lies.” See Rizzuto v. Nexxus Prod. Co., 641 F. Supp.
473, 481 (S.D.N.Y. 1986), aff’d, 810 F.2d 1161 (2d Cir. 1986); Telephone Sys. Int’l v. Cecil, No.
02 CV 9315(GBD), 2003 WL 22232908, at *2 (S.D.N.Y. Sept. 29, 2003); Memo. of Law 35
(citing cases). As Steinhilber observed, “even apparent statements of fact may assume the
character of statements of opinion, and thus be privileged.” 501 N.E.2d at 556.
At least two of plaintiff’s CVRA allegations cannot be proven true or false (only two
such allegations are needed in order to render the January 15 statement an opinion). We have
identified two such allegations in the joinder motion: that Ms. Maxwell “appreciated the
immunity granted” to Epstein, and that she “act[ed] as a ‘madame’ for Epstein.” Memo. of Law
22. Plaintiff does not dispute this. The result is that the January 15 statement’s assertion that
plaintiff’s “allegations” and “claims” in the joint motion are “untrue” or “obvious lies” is by
definition an opinion. It cannot be proven true or false whether Ms. Maxwell “appreciated”
Epstein’s immunity or whether she “acted as a madame.” Indeed, it seems quite obvious that the
joinder-motion allegations about “appreciation” and “madame” are themselves opinion.
In the statement, Mr. Barden on behalf of Ms. Maxwell also says plaintiff’s “original
allegations . . . have been fully responded to and shown to be untrue.” Doc.542-6, Ex.F. This
cannot be proven true or false. The “full response” to the original allegations is a reference to the
“Statement on Behalf of Ghislaine Maxwell” issued March 9, 2011, in response to plaintiff’s

15
allegations contained in media stories, including the Churcher articles. See Doc.542-3, Ex.C.
Whether the 2011 statement “fully” responded to the original allegations and whether it
“showed” the original allegations to be untrue are pure (argumentative) opinion. “[O]bvious lies”
on its face is an opinion. The “obviousness” of a lie simply cannot be proven true or false.
Factor 3: The full context of the statement. Three contextual facts are revealed by the
Rule 56 record. One, the email transmitting the statement to the media-representatives—along
with the third-person references to Ms. Maxwell—told them Ms. Maxwell did not prepare the
statement: “Please find attached a quotable statement on behalf of Ms. Maxwell.” Doc.542-6,
Ex.F (emphasis supplied). It is undisputed that in fact Mr. Barden prepared the bulk of it and
ultimately approved and adopted as his work all of it. Doc.542-7, Ex.K ¶ 10.
Two, Mr. Barden’s statement issued on behalf of his client would not be a traditional
press release solely to disseminate information to the media; this is why he did not request
Mr. Gow or any other public relations specialist to prepare or participate in preparing the
statement. Id., Ex.K ¶ 15. The statement was a broad-brush communique to the media about
plaintiff and her new allegations; it was not to be a “point by point” rebuttal of each new
allegation. Id., Ex.K ¶ 13. The logic and approach to preparing the statement were simple:
compare plaintiff’s prior allegations and conduct in telling her story with her current allegations
and conduct. See generally id., Ex.K ¶ 13. When he wrote the statement, he knew of plaintiff’s
2011 allegation that she had not had sex with Prince Andrew and he knew of her CVRA
allegation that she did have sex with him. Id., Ex.K ¶ 14. Also within his knowledge was the
story she had told Churcher before March 2011—a story that was far less provocative and
salacious than the one she included in the joinder motion. See id., Ex.K ¶ 5; compare Docs.542-1
& 542-2, Exs.A & B (Churcher articles published March 2011) with Doc.542-4, Ex.D (plaintiff’s
joinder motion containing dramatically different and more lurid and salacious allegations).
16
Mr. Barden’s approach provides critical context to explaining how the statement builds a
logical argument that the new allegations are false. It first notes plaintiff’s “original allegations”;
then it points out how the story changed and was embellished over time, “now” with allegations
that plaintiff had sex with a prominent and highly respected Harvard law professor (“Each time
the story is re told [sic] it changes with new salacious details about public figures and world
leaders . . . .”). The argument builds up to the opinion in the third paragraph: “[Plaintiff’s] claims
are obvious lies and should be treated as such . . . .” Doc.542-6, Ex.F. See generally id., Ex.K
¶¶ 13-22. This third paragraph—and the threat in the fourth paragraph to sue the media for
republication of plaintiff’s falsehoods—confirms what is plain from the statement itself: it was
not a traditional press release.
Three, the statement was intended to respond (via denial) to the media-recipients’
requests for a reply to the new CVRA joinder-motion allegations. Id. ¶¶ 8, 10, 16. But more than
that, it was intended to be “a shot across the bow” of the media. Id. ¶ 17. The logical argument
was created to (a) persuade the media-recipients that they needed to “subject plaintiff’s
allegations to inquiry and scrutiny”; (b) explain to the media-recipients how it was “obvious”
that plaintiff “had no credibility” because of her shifting story and increasingly lurid and
salacious allegations as time went on, many of which (e.g., the allegations of sex with Prince
Andrew and Professor Dershowitz) on their face appear far-fetched,15 and (c) warn the media-
15
Since the CVRA joinder motion, there has emerged a substantial amount of evidence—
some from plaintiff’s own pen—that plaintiff’s allegations about having been “forced” to have
sex with prominent individuals are falsehoods. A telling example is a series of emails between
plaintiff and reporter Churcher when plaintiff was working on negotiating a book deal about her
alleged experiences and Churcher was trying to help her. On May 10, 2011, plaintiff tells
Churcher she cannot remember whom she had told Churcher she had had sex with. Churcher
responds responds, “Don’t forget Alan Dershowitz,” which Churcher says is a “good name for
[plaintiff’s] pitch” to her literary agent. It is clear neither Churcher nor plaintiff believed plaintiff
(footnote cont’d on next page)
17
recipients that they republished plaintiff’s obvious falsehoods against Ms. Maxwell at their legal
peril. See id. ¶¶ 13, 16, 17, 20.
As the New York Court of Appeals observed, the context of a statement often is the “key
consideration” in fact vs. opinion cases. Davis, 22 N.E.3d at 1006. So it is here. As Davis
suggested, the three challenged statements are “subject to [Ms. Maxwell’s] interpretation,” id. at
1007; accord Sweeney v. Prisoners’ Legal Servs. of N.Y., 538 N.Y.S.2d 370, 371-72 (3d Dep’t
1989). The context of the January 2015 statement makes clear that the characterization of
plaintiff’s allegations and claims as “untrue” or “obvious lies” are ultimate opinions—
conclusions—drawn from disclosed facts.
Factor 4: The broader setting surrounding the statement, including conventions that
might signal to readers that the statement likely is opinion and not fact. It is undisputed that
the January 2015 statement was sent exclusively to more than six and fewer than thirty media
representatives, each of whom expressly had requested from Mr. Gow that he provide them with
Ms. Maxwell’s reply to the new joint-motion allegations. Doc.542-7, Ex.K ¶¶ 8, 10. As was
obvious from the statement, it was not a traditional press release, as such a release does not
explain—lawyer-like—why new allegations when measured against previous allegations lack
credibility. Nor does a traditional release threaten to sue the media to whom the release is sent.
The media representatives upon receiving the January 2015 statement would have understood it
was presenting an (opinionated) argument that plaintiff was not credible because of her
had had sex with Professor Dershowitz, since (a) Churcher suggests that he would be a “good
name” to “pitch” because of his prominence (“he [represented] Claus von Bulow and a movie
was made about that case…title was Reversal of Fortune”), and (b) Churcher states, “We all
suspect [Professor Dershowitz] is a pedo[phile] and tho no proof of that, you probably met him
when he was hanging put w [Epstein].” Menninger Decl., EXHIBIT.OO, at Giuffre004096-97
(emphasis supplied).
18
inconsistent and shifting sex abuse story and her increasingly lurid allegations against more and
more prominent individuals. And they would have understood that these characteristics of a
storyteller undermine her credibility and ergo the credibility of her new allegations.
In its 12(b)(6) order the Court said the three sentences have the effect of denying
plaintiff’s story but “they also clearly constitute fact to the reader.” The ruling is affected in two
ways by the Rule 56 record. Based on the foregoing discussion of the evidence, the three
sentences clearly constitute (argumentative) opinions of Mr. Barden on behalf of Ms. Maxwell.
Though the Court did not discuss who is “the reader,” this is important in Steinhilber
Factor 4.” Under settled defamation-opinion law, an allegedly defamatory statement is to be
viewed “from the perspective of the audience to whom it is addressed.” Dibella v. Hopkins, No.
01 CIV. 11779 (DC), 2002 WL 31427362, at *2 (S.D.N.Y. Oct. 30, 2002). Here, “the reader” is
six to thirty journalists. They could not have read the July 2015 statement—or the three allegedly
defamatory sentences—the same way it was read by these journalists’ audience, i.e., the general
public. This is because, as plaintiff implicitly concedes, these journalists only republished
excerpts—and not the entirety of the statement, which would have given context to the three
sentences. It is axiomatic that an out-of-context republication of the three sentences—without the
rest of the statement—would deprive the reader of the logic and reasoning behind the
opinionated conclusion that plaintiff was making “untrue” allegations and telling “obvious lies.”
19
III. The pre-litigation privilege bars this action.
A. The privilege applies to the January 2015 statement.
Statements pertinent to a good faith anticipated litigation made by attorneys (or their
agents under their direction16) before the commencement of litigation are privileged and “no
cause of action for defamation can be based on those statements,” Front, Inc. v. Khalil, 28
N.E.3d 15, 16 (N.Y. 2015). The facts that must be established, therefore, are (a) a statement,
(b) that is pertinent to a good faith anticipated litigation, and (c) by attorneys or their agents
under their direction. We did this. See Memo. of Law 6-8, 33-38; Doc.542-7, Ex.K ¶¶ 8-30. For
example, Mr. Barden (a) drafted the vast majority of the January 2015 statement and approved
and adopted all of it, (b) directed Mr. Gow to send it to the media representatives who had
requested Ms. Maxwell’s reply to plaintiff’s joint-motion allegations, (c) in the statement
threatened legal action again these media representatives, and (d) at the time of the statement
“was contemplating litigation against the press-recipients.” Id., Ex.K ¶¶ 10, 16-17, 28, 30.
Plaintiff argues without citation to authority: Ms. Maxwell herself did not testify she
intended to sue; she hasn’t offered any witnesses to testify she intended to bring a lawsuit; she
didn’t in fact sue; and—this one is a non-sequitur—the statement was an “attempt[] to continue
to conceal her criminal acts.” Resp. 41-42. These arguments fail. The privilege exists without
regard to whether Ms. Maxwell testifies she “intended” to sue, whether she has “witnesses” to
say she intended to sue, or whether she “in fact” sued. It refers to “anticipated” litigation, not
“guaranteed” litigation. Indeed, the point of the pre-litigation privilege is to promote
communications that avoid litigation. See Khalil, 28 N.E.3d at 19 (“When litigation is
16
See Chambers v. Wells Fargo Bank, N.A., No. CV 15-6976 (JBS/JS), 2016 WL
3533998, at *8 (D.N.J. June 28, 2016); see generally Hawkins v. Harris, 661 A.2d 284, 289-91
(N.J. 1995).
20
anticipated, attorneys and parties should be free to communicate in order to reduce or avoid the
need to actually commence litigation.”). It applies when there is a good faith basis to anticipate
litigation. Mr. Barden, Ms. Maxwell’s lawyer who drafted and caused the statement to be sent
out, actually was anticipating litigation. Doc.542-7, Ex.K ¶ 28. The argument that the statement
was an attempt to “conceal” Ms. Maxwell’s “criminal acts” is fatuous. It would be hard to post
facto “conceal” alleged criminal acts that plaintiff luridly and salaciously described in an earlier
public filing, i.e., in the CVRA case, in which the United States government was the defendant.
Citing no record evidence, plaintiff argues, “The record evidence shows [Mr. Barden] did
not make the [January 2015] statement.” Resp. 42. That argument is easily disposed of by
Mr. Barden’s uncontested testimony. See Doc.542-7, Ex.K ¶¶ 10-13, 15-17, 20, 26-28, 30.
B. Malice is irrelevant to the pre-litigation privilege.
Citing the New York Court of Appeals’ decision in Khalil, we pointed out that malice is
not relevant to the pre-litigation privilege. Memo. of Law 34-35. To prevail on the pre-litigation
privilege the defendant need only establish one element: the allegedly defamatory statement at
issue was “‘pertinent to a good faith anticipated litigation.’” Id. (quoting Khalil, 28 N.E.3d at
16). Plaintiff disputes this and, without discussing Khalil or citing authorities, simply argues the
pre-litigation privilege is “foreclosed . . . because [Ms. Maxwell] acted with malice.” Resp. 43.
As suggested by her inability to find any law to support her, plaintiff is wrong.
Under general New York defamation law, “[t]he shield provided by a qualified privilege
may be dissolved” if plaintiff in rebuttal can show that the defendant “spoke with ‘malice.’”
Liberman v. Gelstein, 605 N.E.2d 344, 349 (N.Y. 1992); accord Khalil, 28 N.E.3d at 19.
“Malice” means two things: spite or ill will, and knowledge of falsity or reckless disregard of
falsity. Liberman, 605 N.E.2d at 349. Plaintiff relies on this general qualified-privilege law.
21
The problem for plaintiff is that in Khalil the New York Court of Appeals held this
general rule does not apply to the pre-litigation privilege. Khalil worked for a company named
Front. After eight years, he resigned and began working for “EOC,” one of Front’s competitors.
Front’s lawyer Kimmel sent a demand letter to Khalil alleging he had committed criminal,
tortious and ethical misconduct. Kimmel sent another demand letter to EOC and others stating
Khalil had conspired with EOC to breach his fiduciary duty to Front. Six months later, Front
sued Khalil. Khalil brought a third-party claim against Kimmel for libel per se. The trial court
dismissed the lawsuit, ruling that the letters were “absolutely privileged” under the litigation
privilege “and that it therefore did not need to reach the question of malice.” 28 N.E.3d at 17
(internal quotations omitted). The Appellate Division affirmed, holding that the litigation
privilege absolutely protected the letter “because they were issued in the context of prospective
litigation.” Id. at 18 (internal quotations omitted).
The Court of Appeals affirmed, but altered the law on the litigation privilege. It observed,
“Although it is well-settled that statements made in the course of litigation are entitled to
absolute privilege, this Court has not directly addressed whether statements made by an attorney
on behalf of his or her client in connection with prospective litigation are privileged.” Id.
(emphasis supplied). Some Appellate Division departments had held the absolute privilege
applies to statements made in connection with prospective litigation, but other departments had
held such statements were entitled only to a qualified privilege. Id.
The answer to whether pre-litigation statements should be absolute or qualified, the Court
of Appeals held, is driven by the rationale for protecting pre-litigation statements:
When litigation is anticipated, attorneys and parties should be free to

communicate in order to reduce or avoid the need to actually commence
litigation. Attorneys often send cease and desist letters to avoid litigation. . . .
Communication during this pre-litigation phase should be encouraged and not
chilled by the possibility of being the basis for a defamation suit.
22
Id. at 19. However, the court recognized that “extending privileged status to communication
made prior to anticipated litigation has the potential to be abused”; extending an absolute
privilege to this context, the court said, “would be problematic and unnecessary.” Id.
The court held it would recognize only a qualified privilege for pre-litigation
communications. Id. Crucially to the case at bar, the court held that the traditional privilege-
rebuttal malice was inapplicable to the pre-litigation privilege:
Rather than applying the general malice standard to this pre-litigation stage, the
privilege should only be applied to statements pertinent to a good faith anticipated
litigation. This requirement ensures that privilege does not protect attorneys who
are seeking to bully, harass, or intimidate their client’s adversaries by threatening
baseless litigation or by asserting wholly unmeritorious claims, unsupported in
law and fact, in violation of counsel’s ethical obligations. Therefore, we hold that
statements made prior to the commencement of an anticipated litigation are
privileged, and that the privilege is lost where a defendant proves that the
statements were not pertinent to a good faith anticipated litigation.
Id. (emphasis supplied).
Accordingly, the only question is whether the January 2015 statement Mr. Barden caused
to be issued to the six to thirty journalists was “pertinent to a good faith anticipated litigation.”
The undisputed evidence establishes that the answer is yes. Mr. Barden anticipated litigation.17
He “fully complied with [his] ethical obligation as a lawyer.”18 He was hardly “bully[ing],
harass[ing], or intimidat[ing]” the six to thirty journalists, since he caused a press agent, Mr.
17
See Doc.542-7, Ex.K ¶ 28 (“At the time I directed the issuance of the statement, I was
contemplating litigation against the press-recipients . . . .”); id. ¶ 17 (statement was intended as
“‘a shot across the bow’”; “the statement was very much intended as a cease and desist letter to
the media-recipients, letting [them] understand the seriousness with which Ms. Maxwell
considered the publication of plaintiff’s obviously false allegations and the legal indefensibility
of their own conduct”); Doc.542-6, Ex.F (“Maxwell . . . reserves her right to seek redress”).
18
Doc.542-7, Ex.K ¶ 26.
23
Gow, to issue the statement,19 and he believed he had an affirmative duty in representing
Ms. Maxwell to prepare the statement and cause it to be delivered to the journalists.20
Plaintiff argues that when Mr. Barden issued the January 2015 statement on
Ms. Maxwell’s behalf, he had only “‘wholly unmeritorious claims, unsupported in law and fact,
in violation of counsel’s ethical obligations’” and did not have “‘good faith anticipated
litigation.’” Resp. 46 (quoting Khalil, 28 N.E.3d at 19; italics omitted). Plaintiff’s rationale?
Because she was telling the truth and so the media would only be reporting the truth. Id. That is a
nonsensical, frivolous argument.
Whether Mr. Barden, who represents Ms. Maxwell, had a meritorious or good faith basis
for anticipating defamation litigation has nothing to do with whether the media believed plaintiff
was telling the truth, and surely not whether the plaintiff believed or said she was telling the
truth. Based on his knowledge of plaintiff’s history, Mr. Barden in good faith believed that
plaintiff had been making false allegations for years and that the falsity of the allegations “should
have been obvious to the media.” Doc.542-7, Ex.K ¶ 13; see id. ¶¶ 14, 16-17, 20-23, 26-28, 30.
Accordingly, at the time he caused the statement to issue, Mr. Barden had a good-faith basis to
anticipate litigation against any of the media that republished plaintiff’s false allegations.
It hardly matters for purposes of the pre-litigation privilege whether the media
republished or did not republish plaintiff’s allegations or whether Mr. Barden ultimately did or
did not sue any of the media for any republication. As the Khalil court recognized, “[a]ttorneys
often send cease and desist letters to avoid litigation,” 28 N.E.3d at 19, and such letters have a
19
The Khalil court admonished attorneys to “exercise caution when corresponding with
unrepresented potential parties who may be particularly susceptible to harassment and
unequipped to respond properly even to appropriate communications from an attorney.” Khalil,
28 N.E.3d at 19 n.2.
20
See Doc.542-7, Ex.K ¶ 26.
24
valid purpose protected by the pre-litigation privilege. Mr. Barden testified that the January 2015
statement in fact served as a cease and desist letter. See Doc.542-7, Ex.K ¶ 17.
IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable.
Plaintiff did not respond to our argument that Ms. Maxwell’s January 4, 2015, statement
to a reporter is nonactionable. See Memo. of Law 38-39. We respectfully submit plaintiff has
confessed this point. See Cowan, 95 F. Supp. 3d at 645-46.
V. Summary judgment is warranted because plaintiff cannot establish falsity or actual

malice by clear and convincing evidence.
Plaintiff is a public figure. See Memo. of Law 16-17, 49-54. Therefore, she must prove
falsity and actual malice. Under New York law, a public-figure defamation plaintiff must go
beyond the federal constitutional minimum and prove falsity by clear and convincing evidence.
Blair v. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) (citing DiBella v.
Hopkins, 403 F.3d 102, 111 (2d Cir.2005)). She must also prove actual malice by clear and
convincing evidence. Karedes v. Ackerley Grp., Inc., 423 F.3d 107, 114 (2d Cir. 2005) (quoting
Phila. Newspapers v. Hepps, 475 U.S. 767, 773 (1986)).
Clear and convincing evidence is evidence that “produces in the mind of the trier of fact a
firm belief or conviction as to the truth of the allegations sought to be established, evidence so
clear, direct and weighty and convincing as to enable the factfinder to come to a clear conviction,
without hesitancy, of the truth of the precise facts in issue.” Blair, 7 F. Supp. 3d. at 358 (internal
quotations and brackets omitted).
Plaintiff must prove by clear and convincing evidence (a) the material falsity of three
sentences in the context of the January 2015 statement, and (b) Ms. Maxwell’s actual malice, i.e.,
knowledge of the falsity of the three sentences or reckless disregard of whether they were false.
The three sentences are: in the first paragraph of the statement, plaintiff’s allegations are
25
“untrue”; in the same paragraph, the “original allegations” have been “shown to be untrue”; and
in the third paragraph, plaintiff’s “claims are obvious lies.”21 Doc.1 ¶ 30.
Plaintiff cannot prove the falsity of the three sentences, let alone actual malice. If the
Rule 56 record establishes that two of plaintiff’s CVRA joinder-motion allegations are false and
two of her “original” allegations are false, this defamation action collapses on itself. This is
because the statement does not specify how many of plaintiff’s allegations are false; it certainly
does not say “all” plaintiff’s allegations are false. It uses the plural of “allegation.” The plural of
allegation literally means “more than one.” See Memo. of Law 21.
Sentence No. 1. Since the sentence does not specify any particular allegation and since
plaintiff made a plethora of allegations against Ms. Maxwell, plaintiff would be required to prove
the truth of every one of the plethora of allegations and that Ms. Maxwell knew each one of the
allegations was true. Conversely, if there are at least two allegations that plaintiff cannot prove to
be true or if there was good reason for Ms. Maxwell to believe at least two of the allegations to
be false, then summary judgment should enter against plaintiff.
There are at least two allegations by plaintiff against Ms. Maxwell that are untrue. In the
CVRA joinder motion, plaintiff alleged that in plaintiff’s first encounter with Mr. Epstein,
Ms. Maxwell took her to Mr. Epstein’s bedroom for a massage that Mr. Epstein and
Ms. Maxwell “turned . . . into a sexual encounter,” Doc.542-4, Ex.D, at 3. This allegation
contradicted her allegation in the Sharon Churcher article that a woman other than Ms. Maxwell
21
Ms. Maxwell said in her deposition she “know[s]” plaintiff is a “liar.” This testimony,
plaintiff argues, “contradict[s]” our contention that the three sentences in the January 2015
statement are opinion. Resp. 39-40. Plaintiff’s argument is a non-sequitur. Ms. Maxwell’s 2016
deposition testimony in which she disclosed all the reasons she believes plaintiff has uttered a
plethora of false allegations is wholly irrelevant to whether the three sentences in the January
2015 statement, prepared by Mr. Barden to respond to the joint-motion allegations, are opinions.
26
took her to Mr. Epstein’s bedroom; during the massage that woman gave instructions to plaintiff,
and the massage “quickly developed into a sexual encounter.” Doc.542-1, Ex.A, at 4.
A second allegation pertaining to plaintiff’s entire story about Ms. Maxwell’s
introduction of plaintiff to Prince Andrew is untrue. In the joinder motion, plaintiff alleged
Ms. Maxwell served an “important . . . role” in “Epstein’s sexual abuse ring,” namely,
connecting Mr. Epstein to “powerful individuals” who would sexually abuse plaintiff. Id., Ex.D,
at 5. Plaintiff alleged that in this role Ms. Maxwell introduced plaintiff to Prince Andrew, and
she was “forced to have sexual relations with this Prince in three separate geographical
locations,” including Ms. Maxwell’s London apartment. Id., Ex.D, at 5. These allegations
directly contradicted her earlier allegations in the 2011 Churcher article that (a) there never was
“any sexual contact between [plaintiff] and [Prince] Andrew,” and (b) Prince Andrew did not
know “Epstein paid her to have sex with [Epstein’s] friends.” Id., Ex.A, at 6.
Mr. Barden on behalf of Ms. Maxwell said in the first sentence that plaintiff’s
“allegations”—plural—against Ms. Maxwell are “untrue.” We have just established through
plaintiff’s own contradictory words that it would be fair to characterize at least two of her
allegations to be untrue. Having spent significant time with Ms. Churcher in 2011 and having
substantial incentive to disclose all important details of her “sex abuse” story, see Menninger
Decl. EXHIBIT OO, plaintiff in 2011 presented a story that exculpated Ms. Maxwell and Prince
Andrew of the very misconduct that in 2015—after securing a lawyer and seeing her story as a
profit vehicle—she inculpated them for. In the face of her contradictory allegations, plaintiff
cannot possibly prove by clear and convincing evidence that all her joinder-motion allegations
are true, or that when Ms. Maxwell said they were untrue, she knew each one of the allegations
was true or that she recklessly disregarded whether each one was true.
27
Under New York law, a defendant’s allegedly defamatory statement is held “to a standard
of substantial, not literal, accuracy.” Law Firm of Daniel P. Foster, 844 F.2d at 959. Here,
Ms. Maxwell’s first sentence literally is true: more than one of plaintiff’s allegations are
“untrue.” Accordingly, there is no defamation.
Sentence No. 2. The second sentence at issue in this action states, “The original
allegations are not new and have been fully responded to and shown to be untrue.” Plaintiff
alleges the sentence is defamatory to the extent it asserts the original allegations were “shown to
be untrue.” Doc.1 ¶ 30. Plaintiff cannot prove this statement’s falsity.
It is a matter of pure opinion whether any given allegation was “shown” to be untrue.
Some people require more proof than others to conclude that a fact has been “shown to be
untrue.” We discussed above various examples of this, e.g., climate change. Here, Ms. Maxwell
via Mr. Barden in March 2011 issued a statement denying plaintiff’s Churcher-story allegations
as “all entirely false.” Doc.542-3, Ex.C. Plaintiff did not respond to this statement, let alone
claim it was defamatory. Her non-response reasonably could be seen as a concession that
Ms. Maxwell’s denial was righteous. See Doc.542-7, Ex.K (Mr. Barden: “I would have been
remiss if I had sat back and not issued a denial, and the press had published that Ms. Maxwell
had not responded to enquiries and had not denied the new allegations; the public might have
taken the silence as an admission there was some truth in the in allegations.”).
Regardless, we easily can show two of plaintiff’s original allegations are untrue. Many of
plaintiff’s original allegations are contained in the two Churcher articles, Docs.542-1 & 542-2,
Exs.A & B. The articles contained numerous allegations by plaintiff relating to her alleged
sexual abuse. In her deposition, plaintiff was shown Deposition Exhibit 7, a collection of some of
her allegations in the articles. Plaintiff placed checkmarks by those allegations she admitted—
over the course of 20 pages of testimony—were not true. See Menninger Decl. EXHIBIT PP, at
28
435:7-455:6 & Depo. Ex.7. These include her claims that: (1) she was 17 when she flew to the
Caribbean with Mr. Epstein and Ms. Maxwell “went to pick up Bill in a huge black helicopter,”
referring to former President Bill Clinton; (2) her conversation with Mr. Clinton about
Ms. Maxwell’s pilot skills; and (3) Donald Trump was a “good friend” of Mr. Epstein’s and
“flirted with me”.
Plaintiff’s admissions on the falsity of her original allegations are fatal to her defamation
claim as to the second sentence. The eleven admittedly false “original allegations” axiomatically
would warrant the second sentence. Plaintiff has no possible way to prove the second sentence is
false. Indeed, like Ms. Maxwell’s first sentence, the second sentence literally is true: more than
one of plaintiff’s original allegations are untrue. A statement that literally is true cannot be
defamatory as a matter of law. See Law Firm of Daniel P. Foster, 844 F.2d at 959.
Sentence No. 3. Defamation as to the third sentence is foreclosed. To begin with, as
discussed above, whether plaintiff has uttered “obvious lies” is a matter of opinion: in the face of
plaintiff’s gratuitous and lurid allegations of Ms. Maxwell’s years-long participation at the center
of a child sex-trafficking ring, for the journalists-recipients of the July 2015 statement the phrase
was an anticipated “epithet[], fiery rhetoric or hyperbole,” Steinhilber, 501 N.E.2d at 556
(internal quotations omitted); see Tel. Sys. Int’l, 2003 WL 22232908, at *2 (observing Court’s
previous holding in Rizzuto that defendants’ use of phrases “conned,” “rip off” and “lying” in
advertisements were not actionable as libel and were “rhetorical hyperbole, a vigorous epithet
used by those who considered themselves unfairly treated and sought to bring what they alleged
were the true facts to the readers”) (internal quotations omitted).
Even if arguendo the third sentence—plaintiff’s “claims are obvious lies”—cannot be
considered opinion, the Rule 56 record forecloses a defamation claim. The sentence does not
specify which of plaintiff’s “claims,” i.e., allegations, are obvious lies. It could refer to the
29
“original” claims; the “new,” CVRA claims; the claims against Ms. Maxwell; the claims against
anyone, including Professor Dershowitz, who was mentioned in the preceding sentence; or any
two or more of all the claims plaintiff ever had made about her alleged experiences as the alleged
victim of a child sex-trafficking ring.
Regardless of what is being referred to, there is no defamation. As demonstrated in the
discussion above of the first and second sentences, the Rule 56 record establishes that at least
two of plaintiff’s “original” allegations are untrue, at least two of her CVRA allegations are
untrue, at least two of her allegations against Ms. Maxwell are untrue, at least two of her
allegations against anyone (e.g., Ms. Maxwell, Prince Andrew or Professor Dershowitz) are
untrue, and at least two of her allegations about her alleged sex-trafficking experiences are
untrue. Moreover, the untruthfulness—the falsity—of the allegations certainly is “obvious.”
After all, plaintiff herself admitted under oath that a multitude of her original allegations are
untrue, and she implicitly admitted some of her CVRA allegations are untrue because they were
contradicted by her original allegations.
CONCLUSION
The Court should grant summary judgment in favor of Ms. Maxwell.
February 10, 2017.
30
Ty Gee (pro hac vice pending)
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
Attorneys for Defendant Ghislaine Maxwell
31
I certify that on February 10, 2017, I electronically served this Reply Brief in Support of
Defendant’s Motion for Summary Judgment via ECF on the following:

mschultz@bsfllp.com
Farmer, Jaffe, Weissing, Edwards, Fistos & South Salem, NY 10590
Lehrman, P.L. StanPottinger@aol.com
s/ Nicole Simmons
Nicole Simmons
32

v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFFS’ RESPONSE TO DEFENDANT’S

MOTION FOR SUMMARY JUDGMENT
Sigrid McCawley
(954) 356-0011
TABLE OF CONTENTS
Page
I. PRELIMINARY STATEMENT .........................................................................................1
II. UNDISPUTED FACTS.......................................................................................................4
A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have

Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s
Procurer of Underage Girls......................................................................................4
1. It is an undisputed fact that Joanna Sjoberg testified Defendant lured

her from her school to have sex with Epstein under the guise of hiring
her for a job answering phones....................................................................4
2. It is an undisputed fact that Tony Figueroa testified that Defendant

would call him to bring over underage girls and that Defendant and
Epstein would have threesomes with Ms. Giuffre.......................................6
3. It is an undisputed fact that Rinaldo Rizzo testified that Defendant

took the passport of a 15-year-old Swedish girl and threatened her
when she refused to have sex with Epstein. ................................................8
4. It is an undisputed fact that Lyn Miller testified that she believed

Defendant became Ms. Giuffre’s “new mama”...........................................9
5. It is an undisputed Fact that Detective Joseph Recarey testified that he

sought to investigate Defendant in relation to his investigation of
Jeffrey Epstein. ............................................................................................9
6. It is an undisputed fact that Pilot David Rodgers testified that he flew

Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the
“Lolita Express” and that “GM” on the flight logs Stands for Ghislaine
Maxwell. ....................................................................................................10
7. It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and

Jeffrey Epstein invoked the fifth amendment when asked about
Defendant trafficking girls for Jeffery Epstein..........................................10
8. It is an undisputed fact that Juan Alessi testified that Defendant was

one of the people who procured some of the over 100 girls he
witnessed visit Epstein, and that he had to clean Defendant’s sex toys. ...11
9. It is an undisputed fact that Defendant is unable to garner a single

witness throughout discovery who can testify that she did not act as the
procurer of underage girls and young women for Jeffrey Epstein. ...........12
i
B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre and
Procured her for Sex with Convicted Pedophile Jeffrey Epstein while She Was
Underage................................................................................................................12
1. The Flight Logs .........................................................................................12
2. The Photographs ........................................................................................13
3. The Victim Identification Letter................................................................15
4. New York Presbyterian Hospital Records.................................................15
5. Judith Lightfoot Psychological Records....................................................16
6. Message Pads.............................................................................................17
7. The Black Book .........................................................................................22
8. Sex Slave Amazon.com Book Receipt ......................................................23
9. Thailand Folder with Defendant’s Phone Number....................................24
10. It is undisputed fact that the FBI report and the Churcher emails
reference Ms. Giuffre’s accounts of sexual activity with Prince
Andrew that she made in 2011, contrary to Defendant’s argument that
Ms. Giuffre never made such claims until 2014........................................25
C. Defendant Has Produced No Documents Whatsoever That Tend to Show That

She Did Not Procure Underage Girls For Jeffrey Epstein.....................................26
III. LEGAL STANDARD .......................................................................................................27
IV. LEGAL ARGUMENT ......................................................................................................27
A. Defendant is Liable for the Publication of the Defamatory Statement and

Damages for Its Publication ..................................................................................27
1. Under New York Law, Defendant is liable for the media’s publication
of her press release. ...................................................................................28
2. Defendant is liable for the media’s publication of the defamatory

statement....................................................................................................32
B. Material Issues of Fact Preclude Summary Judgment...........................................34
1. The Barden Declaration presents disputed issues of fact. .........................34
ii
a. The Barden Declaration is a deceptive back-door attempt to

inject Barden’s advice without providing discovery of all
attorney communications...............................................................34
b. Defendant’s summary judgment argument requires factual

findings regarding Barden’s intent, thereby precluding
summary judgment. .......................................................................35
c. There are factual disputes regarding Barden’s Declaration...........36
C. Defendant’s Defamatory Statement Was Not Opinion as a Matter of Law. .........38
D. The Pre-Litigation Privilege Does Not Apply to Defendant’s Press Release .......40
1. Defendant fails to make a showing that the pre-litigation privilege

applies........................................................................................................40
2. Defendant is foreclosed from using the pre-litigation privilege because

she acted with malice.................................................................................43
3. Defendant cannot invoke the pre-litigation privilege because she has

no “meritorious claim” for “good faith” litigation. ...................................46
V. DEFENDANT HAS NOT - AND CANNOT - SHOW THAT HER DEFAMATORY

STATEMENT IS SUBSTANTIALLY TRUE..................................................................47
VI. PLAINTIFF DOES NOT NEED TO ESTABLISH MALICE FOR HER

DEFAMATION CLAIM, BUT IN THE EVENT THE COURT RULES
OTHERWISE, THERE IS MORE THAN SUFFICIENT RECORD EVIDENCE FOR
A REASONABLE JURY TO DETERMINE DEFENDANT ACTED WITH
ACTUAL MALICE...........................................................................................................49
VII. THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER
MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE........................................51
VIII. THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,”

AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE
OF ITS FALSITY..............................................................................................................55
A. When Ms. Giuffre Initially Described Her Encounters With Defendant and
Epstein, She Mistakenly Believed the First Encounter Occurred During the
Year 1999. .............................................................................................................57
B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious

Lie” the Allegation That She Regularly Participated in Epstein’s Sexual
Exploitation of Minors and That the Government Knows Such Fact is Not
Substantially True But Instead Completely False. ................................................58
iii
C. Defendant’s January 2015 Statement Claiming as “Untrue” or an “Obvious

Lie” That Maxwell and Epstein Converted Ms. Giuffre Into a Sexual Slave is
Not Substantially True...........................................................................................60
D. Any Statement of Misdirection Regarding Professor Alan Dershowitz is

Nothing More Than an Irrelevant Distraction to The Facts of This Case and
Matters Not on the Defense of Whether Defendant’s Statement Was
Substantially True..................................................................................................61
E. Contrary to Defendant’s Position, There is a Genuine Issue of Material Fact as

to Whether She Created or Distributed Child Pornography, or Whether the
Government Was Aware of Same. ........................................................................62
F. Defendant Did Act as a “Madame” For Epstein to Traffic Ms. Giuffre to The
Rich and Famous. ..................................................................................................63
IX. CONCLUSION .................................................................................................................65
iv
TABLE OF AUTHORITIES
Page
Cases
Baiul v. Disson,
607 F. App'x 18 (2d Cir. 2015)..................................................................................................50
Black v. Green Harbour Homeowners’ Ass’n, Inc.,

19 A.D.3d 962, 798 N.Y.S.2d 753 (2005).................................................................................43
Block v. First Blood Associates,

691 F. Supp. 685 (Sweet, J.) (S.D.N.Y. 1988) ..............................................................41, 42, 43
Brady v. Town of Colchester,

863 F.2d 205 (2d Cir. 1988) ......................................................................................................27
Chambers v. TRM Copy Ctrs. Corp.,

43 F.3d 29 (2d Cir. 1994) ..........................................................................................................50
Contemporary Mission, Inc. v. N.Y. Times Co.,

842 F.2d 612 (2d Cir. 1988) ......................................................................................................51
Da Silva v. Time Inc.,

908 F. Supp. 184 (S.D.N.Y. 1995) ............................................................................................47
Davis v. Costa-Gavras,
580 F. Supp. 1082 (S.D.N.Y. 1984) ..........................................................................................31
De Sole v. Knoedler Gallery, LLC,

139 F. Supp. 3d 618 (S.D.N.Y. 2015) .......................................................................................50
Eliah v. Ucatan Corp.,

433 F. Supp. 309 (W.D.N.Y. 1977)...........................................................................................29
Flomenhaft v. Finkelstein,
127 A.D.3d 634, 8 N.Y.S.3d 161 (N.Y. App. Div. 2015) .........................................................42
Frechtman v. Gutterman,
115 A.D.3d 102, 979 N.Y.S.2d 58 (2014).................................................................................42
Friedman v. Meyers,
482 F.2d 435 (2d Cir. 1973) ......................................................................................................36
Front v. Khalil,
24 N.Y.3d 713 (2015).........................................................................................................passim
v
Gerts v. Robert Welch, Inc.,

418 U.S. 323 (1974) ............................................................................................................49, 54
Giuffre v. Maxwell,
165 F. Supp. 3d 147 (S.D.N.Y. 2016) ................................................................................passim
Greenberg v. CBS Inc.,

69 A.D.2d 693, 419 N.Y.S.2d 988 (1979).................................................................................54
Harte-Hanks Commc'ns, Inc. v. Connaughton,

491 U.S. 657, 109 S. Ct. 2678, 105 L. Ed. 2d 562 (1989) ........................................................49
HB v. Monroe Woodbury Cent. School Dist.,

2012 WL 4477552 (S.D.N.Y. Sept. 27, 2012) ..........................................................................34
Herbert v. Lando,
596 F. Supp. 1178 (S.D.N.Y. 1984) ..........................................................................................51
Hutchinson v. Proxmire,
443 U.S. 111, 99 S. Ct. 2675, 61 L.Ed.2d 411 (1979) ..............................................................53
In re “Agent Orange” Prod. Liab. Litig.,

517 F.3d 76 (2d Cir. 2008) ........................................................................................................27
Karaduman v. Newsday, Inc.,

416 N.E.2d 557 (1980) ..............................................................................................................31
Kirk v. Heppt,
532 F. Supp. 2d 586 (S.D.N.Y. 2008) .......................................................................................42
Lerman v. Flynt Distrib. Co.,

745 F.2d 123 (2d Cir. 1984) ................................................................................................51, 52
Levy v. Smith,
18 N.Y.S 3d 438 (N.Y.A.D. 2 Dept. 2015) ...............................................................................28
Lopez v. Univision Communications, Inc.,

45 F. Supp.2d 348 (S.D.N.Y. 1999) ..........................................................................................48
Mitre Sports Int’l Ltd. v. Home Box Office, Inc.,

22 F. Supp. 3d 240 (S.D.N.Y. 2014) ...............................................................................3, 47, 53
National Puerto Rican Day Parade, Inc. v. Casa Publications, Inc.,

914 N.Y.S.2d 120, 79 A.D.3d 592 (N.Y.A.D. 1 Dept. 2010) ...................................................29
Nehls v. Hillsdale Coll.,

178 F. Supp. 2d 771 (E.D. Mich. 2001) ....................................................................................51
vi
Net Jets Aviation, Inc. v. LHC Commc’ns, LLC,

537 F.3d 168 (2d Cir. 2008) ......................................................................................................27
New York Times Co. v. Sullivan,

376 U.S. 254, 84 S. Ct. 710, 11 L.Ed.2d 686 (1964) ................................................................50
Pacenza v. IBM Corp.,

363 F. App'x 128 (2d Cir. 2010)................................................................................................34
Patrick v. Le Fevre,
745 F.2d 153 (2d Cir. 1984) ......................................................................................................36
Petrus v Smith,
91 A.D.2d 1190 (N.Y.A.D.,1983) .............................................................................................42
Philadelphia Newspapers, Inc. v. Hepps,

475 U.S. 767 (1986) ..................................................................................................................49
Rand v. New York Times Co.,

430 N.Y.S.2d 271, 75 A.D.2d 417 (N.Y.A.D. 1980) ................................................................32
Rubens v. Mason,
387 F.3d 183 (2d Cir. 2004) ......................................................................................................35
Sexter & Warmflash, P.C. v. Margrabe,

38 A.D.3d 163 (N.Y.A.D. 1 Dept. 2007) ..................................................................................42
Stern v. Cosby,
645 F. Supp. 2d 258 (S.D.N.Y. 2009) .................................................................................27, 47
Swan Brewery Co. Ltd. v. U.S. Trust Co. of New York,

832 F. Supp. 714 (S.D.N.Y. 1993) ............................................................................................27
Rules
Fed. R. Civ. P. 56 ..........................................................................................................................27
Other Authorities
Merriam-Webster (11th ed. 2006) ............................................................................................60, 64

RESTATEMENT (SECOND) OF TORTS § 576 (1977) .........................................................................29
SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016) ..................................................28
vii
I. PRELIMINARY STATEMENT
There can be no question that disputed issues of material facts preclude granting
summary judgment when, in a one-count defamation case, Defendant presents the Court with a
68-page memorandum of law, a 16-page statement of purported facts, and approximately 700
pages of exhibits. The sheer scope of Defendant’s response, if anything, conclusively
demonstrates that volumes of disputed facts surround the core question of whether Defendant
abused Ms. Giuffre. Indeed, Defendant acknowledges a dispute between the parties as to whether
she abused Ms. Giuffre. See, e.g., Motion for Summary Judgment at 1; Motion to Dismiss at 1.
This Court already said that this disputed factual question is central to this case:
Either Plaintiff is telling the truth about her story and Defendant’s involvement, or
defendant is telling the truth and she was not involved in the trafficking and
ultimate abuse of Plaintiff. The answer depends on facts. Defendant’s statements
are therefore actionable as defamation. Whether they ultimately prove to meet the
standards of defamation (including but not limited to falsity) is a matter for the
fact-finder.
Order Denying Defendant’s Motion to Dismiss at 10. While this fact remains in dispute,
summary judgment is foreclosed.
But even turning to Defendant’s claims, the avalanche of aspersions she casts upon Ms.
Giuffre and her counsel should not distract the Court from the fact that the instant motion cannot
come within sight of meeting the standard for an award of summary judgment. The most glaring
and emblematic example of the Defendant’s far-fetched claims appears in her attempt to move
away from her defamatory statement by arguing that it was her attorney and not her, who issued
the defamatory statement for the press to publish, though she is forced to admit the statement
was made on her behalf. This is an untenable position to take at trial, and an impossible
argument to advance at the summary judgment stage, as both the testamentary and documentary
evidence positively refute that argument. Defendant incorrectly asks this Court to make a factual
1
finding that her defamatory press release was actually a legal opinion, issued not by her, but by
her lawyer, to the media, despite documentary evidence showing otherwise.
Defendant also argues that she has proven the truth of her statement calling Ms. Giuffre a
liar with respect to the statements Ms. Giuffre made about Defendant. To the contrary,
voluminous evidence, both documentary and testimonial from numerous witnesses, corroborate
Ms. Giuffre’s account of Defendant’s involvement in the sexual abuse and trafficking of Ms.
Giuffre. Just to briefly highlight a few, Johanna Sjoberg, testified that Defendant recruited her
under the guise of a legitimate assistant position, but asked her to perform sexual massages for
Epstein, and punished her when she didn’t cause Epstein to orgasm.1 Tony Figueroa testified that
Defendant contacted him to recruit high school-aged girls for Epstein, and also testified that
Maxwell and Epstein participated in multiple threesomes with Virginia Giuffre. Even more
shockingly, the butler for Defendant’s close friend witnessed, first-hand, a fifteen-year-old
Swedish girl crying and shaking because Defendant was attempting to force her to have sex with
Epstein and she refused. This is a fraction of the testimony that will be elicited at trial about
Defendant’s involvement in the sexual abuse and trafficking of Ms. Giuffre.
Defendant’s primary argument in support of her contention that she did not abuse and
traffic Ms. Giuffre as a minor child is that employment records show that Ms. Giuffre was either
sixteen or seventeen when Defendant recruited her from her job at Mar-a-Lago for sex with
Epstein, not fifteen-years-old as Plaintiff originally thought. Call this the “yes-I’m-a-sex-
trafficker-but-only-of-sixteen-year-old-girls” defense. Defendant does not explain why sexual
abuse of a fifteen year old differs in any material way from sexual abuse of a sixteen or
seventeen year old. All instances involve a minor child, who cannot consent, and who is
1
See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8:5-10; 13:1-3; 12:17-14:3; 15:1-5; 32:9-16; 34:5-35:1;
36:2-1.
2
protected by federal and state laws. The fact remains that Defendant recruited Ms. Giuffre while
she was a minor child for sexual purposes and then proceeded to take her all over the world on
convicted pedophile Jeffrey Epstein’s private jet, the “Lolita Express,”2 as well as to his various
residences, and even to her own London house. Flight logs even reveal twenty-three flights that
Defendant shared with Ms. Giuffre – although Defendant claims she is unable to remember even
a single one of those flights. Inconsequential details that Ms. Giuffre may have originally
remembered incorrectly do not render her substantive claims of abuse by Defendant false, much
less deliberate “lies.” At most, these minor inaccuracies, in the context of a child suffering from
a troubled childhood and sexual abuse, create nothing more than a fact question on whether
Defendant’s statement that Ms. Giuffre lied when she accused Defendant of abuse is
“substantially true,” thereby precluding summary judgment. See Mitre Sports Int’l Ltd. v. Home
Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y. 2014) (“Because determining whether COI
is substantially true would require this court to decide disputed facts ... summary judgment is not
appropriate”).
Defendant has tried to spin these inconsequential mistakes of memory into talismanic
significance and evidence of some form of bad-faith litigation, but this claim fails under the
weight of the evidence. As the Court knows, the clear weight of the evidence establishes
Defendant’s heavy and extensive involvement in both Jeffrey Epstein’s sex trafficking ring and
in recruiting Ms. Giuffre, living with her and Jeffrey Epstein in the same homes while Ms.
Giuffre was a minor, and traveling with Ms. Giuffre and Jeffrey Epstein – including 23
documented flights. Even the house staff testified that Defendant and Ms. Giuffre were regularly
2
See, e.g.: “All aboard the ‘Lolita Express’: Flight logs reveal the many trips Bill Clinton and Alan Dershowitz took
on pedophile Jeffrey Epstein’s private jet with anonymous women” at The Daily Mail,
http://www.dailymail.co.uk/news/article-2922773/Newly-released-flight-logs-reveal-time-trips-Bill-Clinton-
Harvard-law-professor-Alan-Dershowitz-took-pedophile-Jeffrey-Epstein-s-Lolita-Express-private-jet-anonymous-
women.html.
3
together. See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 103:4-9 (“Q. After that day, do you
recall that she started coming to the house more frequently. A. Yes, she did. Q. In fact, did she
start coming to the house approximately three times a week? A. Yes, probably.”). It is also
undisputed that witnesses deposed in this case have testified about Defendant’s role as a procurer
of underage girls and young women for Jeffrey Epstein. At the very least, a trier of fact should
determine whether the evidence establishes whether or not Ms. Giuffre’s claims of Defendant
being involved in her trafficking and abuse are true. Defendant’s summary judgment motion
should be denied in its entirety.
II. UNDISPUTED FACTS
The record evidence in this case shows that Defendant shared a household with convicted
pedophile Jeffrey Epstein for many years. While there, she actively took part in recruiting
underage girls and young women for sex with Epstein, as well as scheduling the girls to come
over, and maintaining a list of the girls and their phone numbers. Ms. Giuffre was indisputably a
minor when Defendant recruited her to have sex with convicted pedophile Jeffrey Epstein.
Thereafter, Ms. Giuffre flew on Epstein’s private jets – the – Lolita Express” – with Defendant at
least 23 times.
A. It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have

Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s
Procurer of Underage Girls.
1. It is an undisputed fact that Joanna Sjoberg testified Defendant lured

her from her school to have sex with Epstein under the guise of hiring
her for a job answering phones.
Ms. Sjoberg’s account of her experiences with Defendant are chillingly similar. As with
Ms. Giuffre, Defendant, a perfect stranger, approached Ms. Sjoberg while trolling Ms. Sjoberg’s
school grounds. She lured Ms. Sjoberg into her and Epstein’s home under the guise of a
legitimate job of answering phones, a pretext that lasted only a day. A young college student,
4
nearly 2,000 miles from home, Defendant soon instructed Ms. Sjoberg to massage Epstein, and
made it clear that Sjoberg’s purpose was to bring Epstein to orgasm during these massages so
that Defendant did not have to do it.
Q. And when did you first meet Ms. Maxwell?

A. 2001. March probably. End of February/beginning of March.
Q. And how did you meet her?
A. She approached me while I was on campus at Palm Beach Atlantic College.
***
Q. And how long did you work in that position answering phones and doing --
A. Just that one day.
***
Q. And what happened that second time you came to the house?
A. At that point, I met Emmy Taylor, and she took me up to Jeffrey’s bathroom and he was
present. And her and I both massaged Jeffrey. She was showing me how to massage. And
then she -- he took -- he got off the table, she got on the table. She took off her clothes, got
on the table, and then he was showing me moves that he liked. And then I took my clothes
off. They asked me to get on the table so I could feel it. Then they both massaged me.
***
Q. Who did Emmy work for?
2 A. Ghislaine.
3 Q. Did Maxwell ever refer to Emmy by any particular term?
5 A. She called her her slave.
***
Q. Did Jeffrey ever tell you why he received so many massages from so many different girls?
A. He explained to me that, in his opinion, he needed to have three orgasms a day. It was
biological, like eating.
***
Q. Was there anything you were supposed to do in order to get the camera?
THE WITNESS: I did not know that there were expectations of me to get the camera until
after. She [Defendant] had purchased the camera for me, and I was over there giving Jeffrey
a massage. I did not know that she was in possession of the camera until later. She told me --
called me after I had left and said, I have the camera for you, but you cannot receive it yet
because you came here and didn’t finish your job and I had to finish it for you.
Q. And did you -- what did you understand her to mean?
A. She was implying that I did not get Jeffrey off, and so she had to do it.
Q. And when you say “get Jeffrey off,” do you mean bring him to orgasm?
A. Yes.
***
Q. Based on what you knew, did Maxwell know that the type of massages Jeffrey was getting
typically involved sexual acts?
THE WITNESS: Yes.
Q. What was Maxwell’s main job with respect to Jeffrey?
5
THE WITNESS: Well, beyond companionship, her job, as it related to me, was to find
other girls that would perform massages for him and herself.3
Ms. Sjoberg also testified about sexual acts that occurred with her, Prince Andrew, and
Ms. Giuffre, when she and Defendant were staying at Epstein’s Manhattan mansion:
Q. Tell me how it came to be that there was a picture taken.

THE WITNESS: I just remember someone suggesting a photo, and they told us to go get on
the couch. And so Andrew and Virginia sat on the couch, and they put the puppet, the puppet
on her lap. And so then I sat on Andrew’s lap, and I believe on my own volition, and they
took the puppet’s hands and put it on Virginia’s breast, and so Andrew put his on mine.4
Ms. Sjoberg’s testimony corroborates Ms. Giuffre’s account of how Defendant recruited
her (and others) under a ruse of a legitimate job in order to bring them into the household to have
sex with Epstein. Ms. Sjoberg’s testimony also corroborates Ms. Giuffre’s account of being lent
out to Prince Andrew by Defendant, as even the interaction Ms. Sjoberg witnessed included a
sexual act: Prince Andrew using a puppet to touch Ms. Giuffre’s breast while using a hand to
touch Ms. Sjoberg’s breast.
2. It is an undisputed fact that Tony Figueroa testified that Defendant

would call him to bring over underage girls and that Defendant and
Epstein would have threesomes with Ms. Giuffre.5
Tony Figueroa testified that Plaintiff told him about threesomes Ms. Giuffre had with
Defendant and Epstein which included the use of strap-ons:
Q. Okay. And tell me everything that you remember about what Ms. Roberts said about
being intimate with Ms. Maxwell and Mr. Epstein at the same time.
A. I remember her talking about, like, strap-ons and stuff like that. But, I mean, like I said,
all the details are not really that clear. But I remember her talking about, like, how they
would always be using and stuff like that.
Q. She and Ms. Maxwell and Mr. Epstein would use strap-ons?
A. Uh-huh (affirmative).
***
3
See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 8:5-10; 13:1-3; 12:17-14:3; 15:1-5; 32:9-16; 34:5-35:1;
36:2-15.
4
See McCawley Dec. at Exhibit 16, Sjoberg Dep. Tr. at 82:23-83:9.
5
Defendant attempts to discredit Figueroa’s damaging testimony by repeatedly mentioning that he has been
convicted for a drug-related offense. Unsurprisingly, in this attack, Defendant does not mention that she has a DUI
conviction. See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 390:13-15. (April 22, 2016).
6
Q. Other than sex with the Prince, is there anyone else that Jeffrey wanted Ms. Roberts to
have sex with that she relayed to you?
A. Mainly, like I said, just Ms. Maxwell and all the other girls.
Q. Ms. Maxwell wanted -- Jeffrey wanted Virginia to have sex with Ms. Maxwell?
A. And him, yeah.
Q. And did she tell you whether she had ever done that?
A. Yeah. She said that she did.
***
Q. And what did she describe having happened?
A. I believe I already told you that. With the strap-ons and dildos and everything.6
.7
Figueroa also testified that Defendant called him to ask if he had found any other girls for
Epstein, thereby acting as procurer of girls for Epstein:
Q. [W]hen Ghislaine Maxwell would call you during the time that you were living with
Virginia, she would ask you what, specifically?
A. Just if I had found any other girls just to bring to Jeffrey.
Q. Okay.
A. Pretty much every time there was a conversation with any of them, it was either asking
Virginia where she was at, or asking her to get girls, or asking me to get girls.
***
Q. Okay. Well, tell me. When did Ms. Maxwell ask you to bring a girl?
A. Never in person. It was, like, literally, like, on the phone maybe, like, once or twice.
Q All right. Did Ms. Maxwell call you frequently?
A. No.
Q. All right. How many times do you think Ms. Maxwell called you, at all?
A. I’d just say that probably a just a few, a couple of times. Maybe once or twice.
Q. One or two --
A. The majority of the time it was pretty much his assistant.
Q. How do you know Ms. Maxwell’s voice?
A. Because she sounds British.
Q. So someone with a British accent called you once or twice and asked for --
A. Well, she told me who she was.
Q. Okay. And what did she say when she called you and asked you to bring girls?
A. She just said, “Hi. This is Ghislaine. Jeffrey was wondering if you had anybody that could
come over.”8
6
See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103.
7
See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 55:19-58:23 (July 22, 2016).
8
See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 200:6-18; 228:23-229:21.
7
3. It is an undisputed fact that Rinaldo Rizzo testified that Defendant

took the passport of a 15-year-old Swedish girl and threatened her
when she refused to have sex with Epstein.
Rinaldo Rizzo was the house manager for one of Defendant’s close friends, Eva Dubin.
Mr. Rizzo testified - through tears – how, while working at Dubin’s house, he observed
Defendant bring a 15 year old Swedish girl to Dubin’s house. In distress, the 15 year old girl
tearfully explained to him that Defendant tried to force her to have sex with Epstein through
threats and stealing her passport:
Q. How old was this girl?

A. 15 years old.
***
Q. Describe for me what the girl looked like, including her demeanor and anything else you
remember about her when she walks into the kitchen.
A. Very attractive, beautiful young girl. Makeup, very put together, casual dress. But she
seemed to be upset, maybe distraught, and she was shaking, and as she sat down, she sat
down and sat in the stool exactly the way the girls that I mentioned to you sat at Jeffrey’s
house, with no expression and with their head down. But we could tell that she was very
nervous.
Q. What do you mean by distraught and shaking, what do you mean by that?
A. Shaking, I mean literally quivering.
***
Q. What did she say?
A. She proceeds to tell my wife and I that, and this is not -- this is blurting out, not a
conversation like I’m having a casual conversation. That quickly, I was on an island, I was
on the island and there was Ghislaine, there was Sarah, she said they asked me for sex, I said
no. And she is just rambling, and I’m like what, and she said -- I asked her, I said what? And
she says yes, I was on the island, I don’t know how I got from the island to here. Last
afternoon or in the afternoon I was on the island and now I’m here. And I said do you have a
-- this is not making any sense to me, and I said this is nuts, do you have a passport, do you
have a phone? And she says no, and she says Ghislaine took my passport. And I said what,
and she says Sarah took her passport and her phone and gave it to Ghislaine Maxwell, and at
that point she said that she was threatened. And I said threatened, she says yes, I was
threatened by Ghislaine not to discuss this. And I’m just shocked. So the conversation, and
she is just rambling on and on, again, like I said, how she got here, she doesn’t know how she
got here. Again, I asked her, did you contact your parents and she says no. At that point, she
says I’m not supposed to talk about this. I said, but I said: How did you get here. I don’t
understand. We were totally lost for words. And she said that before she got there, she was
threatened again by Jeffrey and Ghislaine not to talk about what I had mentioned earlier,
about -- again, the word she used was sex.
Q. And during this time that you’re saying she is rambling, is her demeanor continues to be
what you described it?
8
A. Yes.
Q. Was she in fear?
A. Yes.
Q. You could tell?
A. Yes.
A. She was shaking uncontrollably.9
4. It is an undisputed fact that Lyn Miller testified that she believed

Defendant became Ms. Giuffre’s “new mama”.
Lyn Miller is Ms. Giuffre’s mother. She testified that when Ms. Giuffre started living
with Defendant, Defendant became Ms. Giuffre’s “new momma.”10 Incredulously, Defendant
testified that she barely remembered Ms. Giuffre.11
5. It is an undisputed Fact that Detective Joseph Recarey testified that

he sought to investigate Defendant in relation to his investigation of
Jeffrey Epstein.
Detective Recarey led the Palm Beach Police’s investigation of Epstein. He testified that
Defendant procured girls for Epstein, and that he sought to question her in relation to his
investigation, but could not contact her due to the interference of Epstein’s lawyer:
Q. A cross-reference of Jeffrey Epstein’s residence revealed which affiliated names?

A. It revealed Nadia Marcinkova, Ghislane Maxwell, Mark Epstein. Also, the cross-
reference, any previous reports from the residence as well.
Q. During your investigation, did you learn of any involvement that Nadia Marcinkova had
with any of the activities you were investigating?
***
Q. The other name that is on here as a cross-reference is Ghislane Maxwell. Did you speak
with Ghislane Maxwell?
A. I did not.
Q. Did you ever attempt to speak with Ghislane Maxwell?
A. I wanted to speak with everyone related to this home, including Ms. Maxwell. My contact
was through Gus, Attorney Gus Fronstin, at the time, who initially had told me that he would
make everyone available for an interview. And subsequent conversations later, no one was
available for interview and everybody had an attorney, and I was not going to be able to
speak with them.
Q. Okay. During your investigation, what did you learn in terms of Ghislane Maxwell’s
involvement, if any?
9
See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52:6-7; 52:25-53:17; 55:23-58:5
10
See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115.
11
See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 77:25-78:15 (April 22, 2016).
9
THE WITNESS: Ms. Maxwell, during her research, was found to be Epstein’s long-time
friend. During the interviews, Ms. Maxwell was involved in seeking girls to perform
massages and work at Epstein’s home.12
6. It is an undisputed fact that Pilot David Rodgers testified that he flew

Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the
“Lolita Express” and that “GM” on the flight logs Stands for
Ghislaine Maxwell.
Notably, at Defendant’s deposition, Defendant refused to admit that she flew with Ms.
Giuffre, and denied that she appeared on Epstein’s pilot’s flight logs.13 However, David Rodgers,
Epstein pilot, testified that the passenger listed on his flight logs bearing the initials – GM – was,
in fact, Ghislaine Maxwell, and that he was the pilot on at least 23 flights in which Defendant
flew with Plaintiff.14 The dates of those flights show that Ms. Giuffre was an underage child on
many of them when she flew with Defendant.15
7. It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and

Jeffrey Epstein invoked the Fifth Amendment when asked about
Defendant trafficking girls for Jeffery Epstein.
Both Sarah Kellen and Nadia Marcinkova lived with Jeffrey Epstein for many years.
They both invoked the Fifth Amendment when asked about Defendant’s participation in
recruiting underage girls for sex with Epstein. Marcinkova testified as follows:
Q. Did Ghislaine Maxwell work as a recruiter of young girls for Jeffrey Epstein when
you met her?
A. Same answer. [Invocation of Fifth Amendment]
***
Q. Have you observed Ghislaine Maxwell and Jeffrey Epstein convert what started as
a massage with these young girls into something sexual?
A. Same answer.16
12
See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 27:10-17; 28:21-29:20.
13
See McCawley Dec. at Exhibit 11, Maxwell’s April 22, 2016 Dep. Tr. at 78-79, 144.
14
See McCawley Decl. at Exhibit 41, Rodgers Dep. Ex. 1, GIUFFRE 007055-007161 (flight records evidencing
Defendant (GM) flying with Ms. Giuffre).
15
See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36; see also Exhibit 41,
Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464-1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528,
1570 and 1589.
16
See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15.
10
Kellen testified as follows:
Q. Did Ghislaine Maxwell work as a recruiter for young girls for Jeffrey Epstein when you
met her?
A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege . . .
***
Q. Isn’t it true that Ghislaine Maxwell would recruit underage girls for sex and sex acts with
Jeffrey Epstein?
A. On advice of my counsel I must invoke my Fifth and Sixth Amendment privilege . . .17
Similarly, Jeffrey Epstein invoked the Fifth Amendment when asked about Defendant’s
involvement in procuring underage girls for sex with him.
Q. Maxwell was one of the main women whom you used to procure underage girls for sexual
activities, true?
THE WITNESS: Fifth.
***
Q. Maxwell was a primary co-conspirator in your sexual abuse scheme, true?
THE WITNESS: Fifth.
Q. Maxwell was a primary co-conspirator in your sex trafficking scheme, true?
THE WITNESS: Fifth.
Q. Maxwell herself regularly participated in your sexual exploitation of minors, true?
THE WITNESS: Fifth.18
8. It is an undisputed fact that Juan Alessi testified that Defendant was

one of the people who procured some of the over 100 girls he
witnessed visit Epstein, and that he had to clean Defendant’s sex toys.
Juan Alessi was Epstein’s house manager. He testified as follows:
Q. And over the course of that 10-year period of time while Ms. Maxwell was at the house,
do you have an approximation as to the number of different females – females that you were
told were massage therapists that came to house?
A. I cannot give you a number, but I would say probably over 100 in my stay there.
***
Q. I don’t think I asked the right – the question that I was looking to ask, so let me go back.
Did you go out looking for the girls –
A. No.
Q. – to bring –
A. Never
Q. – as the massage therapists?
A. Never.
Q. Who did?
17
See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16.
18
See McCawley Dec. at Exhibit 3, Epstein Dep. Tr. at 116:10-15; 117:18-118:10.
11
A. Ms. Maxwell, Mr. Epstein and their friends, because their friend relay to other friends
they knew a massage therapist and they would send to the house. So it was referrals.
***
Q. Did you have occasion to clean up after the massages?
A. Yes.
Q. Okay. And that is after both a massage for Jeffrey Epstein, as well as clean up after a
massage that Ghislaine Maxwell may have received?
A. Yes.
Q. And on occasion, after -- in cleaning up after a massage of Jeffrey Epstein or Ghislaine
Maxwell, did you have occasion to find vibrators or sex toys that would be left out?
A. yes, I did.19
9. It is an undisputed fact that Defendant was unable to garner a single

witness throughout discovery who can testify that she did not act as
the procurer of underage girls and young women for Jeffrey Epstein.
Defendant has not been able to procure a single witness - not one – to testify that
Defendant did not procure girls for sex with Epstein or participate in the sex. Even one of her
own witnesses, Tony Figueroa, testified that she both procured girls and participated in the sex.
Another one of Defendant’s witnesses, Ms. Giuffre’s mother, named Defendant as Ms. Giuffre’s
“new mamma.” Indeed, those who knew her well, who spent considerable time with her in
Epstein’s shared household, like Juan Alessi, Alfredo Rodriguez and Joanna Sjoberg, have
testified that she was Epstein’s procuress. Others who lived with her – Jeffrey Epstein, Nadia
Marcinkova, and Sarah Kellen – invoked the Fifth Amendment so as not to answer questions on
the same. No one has testified to the contrary.
B. Documentary Evidence also Shows that Defendant Trafficked Ms. Giuffre

and Procured her for Sex with Convicted Pedophile Jeffrey Epstein while
She Was Underage.
1. The Flight Logs
Defendant has never offered a legal explanation for what she was doing with, and why
she was traveling with, a minor child on 21 flights while she was a child, including 6
international flights, aboard a convicted pedophile’s private jet all over the world. Her motion for
19
See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28:6-15; 30:51-25; 52:9-22.
12
summary judgment – as well as all previous briefing papers – are absolutely silent on those
damning documents.
2. The Photographs
Throughout a mountain of briefing and, and even in her own deposition testimony,
Defendant never offered an explanation regarding Ms. Giuffre’s photographs of her, Defendant,
and Epstein. She never offered a legal explanation for why Prince Andrew was photographed
with his hand around Ms. Giuffre’s bare waist while she was a minor child, while posing with
Defendant, inside Defendant’s house in London. This particular photograph corroborates Ms.
Giuffre’s claims, and there is no other reasonable explanation why an American child should be
in the company of adults not her kin, in the London house owned by the girlfriend of a now-
convicted sex offender.20
Ms. Giuffre also produced pictures of herself taken when she was in New York with
Defendant and Epstein, and from a trip to Europe with Defendant and Epstein:21
20
See McCawley Dec at Exhibit 42, GIUFFRE007167, Prince Andrew and Defendant Photo.
21
See McCawley Dec at Exhibit 42, GIUFFRE007182 - 007166.
13
And, Ms. Giuffre has produced a number of pictures of herself taken at the Zorro Ranch,
Epstein’s New Mexico Ranch, two of which are below. 22
Finally, among other nude photos, which included full nudes of Defendant, Ms. Giuffre
produced images of females that the Palm Beach Police confiscated during the execution of the
22
See McCawley Dec at Exhibit 42, GIUFFRE007175; 007173.
14
warrant, including one photograph revealing the bare bottom of a girl who appears to be pre-
pubescent (Ms. Giuffre will only submit its redacted form): 23
3. The Victim Identification Letter
In 2008, the United States Attorney’s office for the Southern District of Florida identified
Ms. Giuffre as a protected “victim” of Jeffrey Epstein’s sex abuse. The U.S. Attorney mailed Ms.
Giuffre a notice of her rights as a crime victim under the CVRA.24
4. New York Presbyterian Hospital Records
Ms. Giuffre has provided extensive medical records in this case, including medical
records from the time when Defendant was sexually abusing and trafficking her. Ms. Giuffre
produced records supporting her claim of being sexually abused in New York resulting in both
23
See McCawley Dec at Exhibit 44, GIUFFRE007584.
24
See McCawley Dec. at Exhibit 30, GIUFFRE 002216-002218, Victim Notification Letter.
15
Defendant and Epstein taking Plaintiff to New York Presbyterian Hospital in New York while
she was a minor.25 The dates on the hospital records show she was seventeen years old.
5. Judith Lightfoot Psychological Records
As the Court is aware, Defendant propounded wildly overbroad requests for production
concerning the past eighteen years of Ms. Giuffre’s medical history. Defendant repeatedly and
vehemently argued to the Court that it was essential to procure every page of these records in a
fanfare of unnecessary motion practice. See, e.g., Defendant’s Motion to Compel (DE 75);
Defendant’s Motion for Sanctions at 10 (“Ms. Maxwell has been severely prejudiced by
Plaintiff’s failure to provide the required identifying information and documents from her health
care providers.”). Ms. Giuffre and her counsel took on the considerable burden and significant
expense of retrieving and producing over 250 pages of medical records from over 20 providers,
spanning two continents and nearly two decades.
Now that those records have been collected, Defendant’s 68 page motion makes no
reference to a single medical record produced by Ms. Giuffre, nor a single provider, nor a single
treatment, nor or a single medication prescribed. After Defendant’s repeated motion practice
stressing the essentiality of these records, this may surprise the Court. But not Ms. Giuffre.
Defendant’s requests unearthed documents that are highly unfavorable to Defendant that
corroborate Ms. Giuffre’s claims against her.
Years before this cause of action arose, Ms. Giuffre sought counseling from a
psychologist for the trauma she continued to experience after being abused by Defendant and
Epstein. A 2011 psychological treatment record, written by her treating psychologist,
unambiguously describes Defendant as Ms. Giuffre’s abuser:
25
See McCawley Dec at Exhibit 33, GIUFFRE003259-003290.
16
. . . [Ms. Giuffre] was approached by Ghislaine Maxwell who said she could help
her get a job as a massage therapist . . . seemed respectable . . . was shown how to
massage, etc., Geoff [sic] Epstein. Told to undress and perform sexual acts on
person. Miss Maxwell promised her $200 a job.26
Therefore, years before Defendant defamed her, Ms. Giuffre confided in her treating
psychologist that Maxwell recruited her for sex with Epstein.
6. Message Pads
Detective Recarey, the lead investigator of the criminal investigation into Epstein and his
associates’ sex crimes, recovered carbon copies of hand-written messages taken by various staff,
including Defendant, at Epstein’s Palm Beach residence.27 These were collected both from trash
pulls from the residence and during the execution of the search warrant where the pads were
found laying out in the open in the residence.28 The search warrant was executed in 2005 and the
message pads collected include messages recorded in 2004 and 2005. Numerous witnesses have
described that these copies of collected messages accurately reflect those taken by various staff
at the Palm Beach Epstein mansion between 2004 and 2005.29
The messages raise a question of fact as to Maxwell’s involvement in the sexual abuse of
minors and are relevant to refute Maxwell’s denial of any involvement with Epstein during
relevant time periods, and, accordingly her denial of knowledge of certain events.
While there were hundreds of these messages recovered during the investigation, this
small sample demonstrates the undeniable reality that there exists a genuine issue of material fact
with respect to Defendant’s involvement in and knowledge of the activities described by Giuffre
which Maxwell has said we “untrue” and “obvious lies.”
26
See McCawley Dec. at Exhibit 38, Lightfoot Records, GIUFFRE005437.
27
See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 45:13-25; 97:9-98:8.
28
See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 25:12-21; 40:5-15; 41:16-23; 42:14-43:10; 45:13-25; see
also search warrant video showing the pads openly displayed on the desk.
29
See McCawley Dec. at Exhibit 21, 1, 16, 11, Rodriguez Dep. Tr. at 73:19-74:12; Alessi Dep. Tr. at 141:18-21;
Sjoberg Dep. Tr. at 64:1-6; Maxwell Dep. Tr. at 147:23-148:3; 148:19-149:14.
17
This sampling reveals that Maxwell, “GM,” took messages at the residence, including
from underage girls who were calling to schedule a time to come over to see Epstein. This
demonstrates that Maxwell was at Epstein’s Palm Beach mansion in 2004 and 2005, incidentally
a time period she has denied being around the house in her deposition. See supra
GIUFFRE001412; 001435; 001449. The messages also reveal that multiple “girls” were leaving
messages that were being taken and memorialized and left out in the open for anyone to see.
Certain messages also make clear that a number of these “girls” were in school. In addition to
taking messages herself (and the staff working under her direction taking these relevant
messages), staff employees were taking and leaving messages for Defendant. This is evidence
that Maxwell was in the house at relevant times, including times that she has now testified under
oath that she was not there. Other messages demonstrate Epstein and Maxwell’s friends,
including Jean Luc Brunel, leaving messages relating to underage females. The following is a
small sampling of such messages:
18
19
The following are descriptions of a sampling of messages pads30 that create a genuine dispute
of material fact:
 One message pad reflects , who is identified in the Palm Beach Police
Report as a minor, contacting Jeffrey Epstein for “work” explaining that she does not
have any money. The term “work” was often used by members of Jeffrey Epstein’s
sexual trafficking ring to refer to sexual massages. (See GIUFFRE05660 (“She stated she
was called by Sara for her to return to work for Epstein. stated ‘work’ is the term
used by Sarah to provide the massage in underwear.”). Giuffre 001462: July 5th no year
to JE from ”I need work. I mean I don’t have money. Do you have some
work for me?”
 Other message pads reflect who was a minor, calling and leaving a message at
the Palm Beach mansion that she has recruited another girl for Jeffrey Epstein. The
second message demonstrates that Jeffrey Epstein required different girls to be scheduled
every day of the week. The third shows an offer to have two minor girls come to the
home at the same time to provide sexual massages. These type of messages indicate the
lack of secrecy of the fact that multiple young females were visiting every day and at
least raises a question of fact whether Maxwell was knowledgeable and involved as
Giuffre has said, or whether Giuffre was lying and Maxwell was not at all involved or
aware of this activity, as Defendant would attempt to have the world believe.
Giuffre 001428 – undated Jeffrey From – “Has girl for tonight” ;Giuffre
001432 (pictured above)– 7/9/04 – Mr. Epstein From –“ is available
on Tuesday no one for tomorrow”; GIUFFRE 001433 /1/17/04 – Mr. Epstein from
– “Me and _____ can come tomorrow any time or alone” ; Giuffre –
001452 – undated Jeffrey from “Has girl for tonight.”
 Other message pads demonstrate that there was a pattern and practice of using young
females to recruit additional young females to provide sexual massages on a daily basis.
Giuffre 001413 (pictured above)– JE from “N” – “ hasn’t confirmed
for 11:00 yet, so she is keeping on hold in case doesn’t call back;
Giuffre 001448 -8/20/05 JE from - confirmed ___ at 4 pm. Who is
scheduled for morning? I believe wants to work.”
This message pad reflects that a friend of Jeffrey Epstein is sending him a sixteen year
old Russian girl for purposes of sex. Giuffre 001563 (pictured above)- 6/1/05 For
Jeffrey From Jean Luc “He has a teacher for you to teach you how to speak
Russian. She is 2X8 years old not blonde. Lessons are free and you can have your
1st today if you call.”
 This message pad directly refutes Maxwell’s sworn testimony that she was not present
during the year 2005 at Jeffrey Epstein’s Palm Beach mansion because this shows
leaving a message for Jeffrey at the Palm Beach home that she was going to work out
30
See McCawley Dec. at Exhibit 28.
20
with the Defendant on September 10, 2005. The police were only able to retrieve a
fraction of these message pads during their trash pull but even in the few they recovered,
it shows Maxwell was regularly at the Palm Beach home during the time period she
claimed she was not. To the contrary, she was both sending and receiving messages and
messages, like this one, reflect her presence at the mansion. Giuffre 001412 – 9/10/05
(during the year Maxwell says she was never around) JE from – “I went to
Sarah and made her water bottle and I went to work out with GM.”
 These message pads further corroborate that Defendant lied in her testimony and she was
in fact in regular contact with Jeffrey Epstein during the years 2004 and 2005. For
example, the message from “Larry” demonstrates that Defendant is at the Palm Beach
mansion so frequently that people, including Epstein’s main pilot Larry Visoski, are
leaving messages for Maxwell at the Palm Beach house. Giuffre 001435 7/25/04 – Mr.
Epstein from Ms. Maxwell – “tell him to call me”; Giuffre – 001449 – 8/22/05 – JE
from GM; Giuffre – 001453 – 4/25/04 for Ms. Maxwell From Larry “returning your
call”;
 This message pad shows that Defendant was clearly actively involved in Jeffrey Epstein’s
life and the activities at his Palm Beach mansion. Giuffre – 001454 – undated Jeffrey
From Ghislaine – “Would be helpful to have ___________ come to Palm Beach
today to stay here and help train new staff with Ghislaine.”
 This message pad clearly reflects an underage female (noted by the police redaction of
the name) leaving a message asking if she can come to the house at a later time because
she needs to “stay in school.” Giuffre 001417 (pictured above)– Jeffrey 2/28/05
Redacted name “She is wondering if 2:30 is o.k. She needs to stay in school.”
 This message pad reflects a message from who was under the age of eighteen at
the time she was going over to Jeffrey Epstein’s home to provide sexual massages
according to the Palm Beach Investigative Report. Giuffre 001421 3/4/05 to Jeffrey
from “It is o.k. for to stop by and drop something?”
 These message pads reflect the pattern of underage girls (noted by the police redaction of
the name on the message pad) calling the Palm Beach mansion to leave a message about
sending a “female” over to provide a sexual massage. Giuffre 001423 11/08/04 To Mr.
JE – redacted from – “I have a female for him” Giuffre 001426 (pictured above) –
1/09/05 JE To JE from Redacted – “I have a female for him.”
 This message pad reflects the pattern and practice of having young girls bring other
young girls to the house to perform sexual massages. Indeed the “ ” reflected in this
message pad corresponds in name to the ” that Tony Figueroa testified he initially
brought to Jeffrey Epstein during the time period that the Defendant was requesting that
Tony find some young females to bring to Jeffrey Epstein’s home. See Figueroa at 184-
185. The Palm Beach Police Report reflects that “ ” and “ ” also brought
seventeen year old to the home to perform sexual massages. See GIUFFRE
05641. thereafter recruited a number of other young girls to perform sexual
21
massages as reflected in the Palm Beach Police Report. Giuffre 001427 (pictured
above) – 1/2/03 – JE from “Wants to know if she should bring her friend
with tonight.”
 This message pad reflects multiple sexual massages being scheduled for the same day
which corroborates Virginia GIUFFRE, and Johanna Sjorberg’s
testimony that Jeffrey Epstein required that he have multiple orgasms in a day which
occurred during these sexual massages. Giuffre 001449 (pictured above) – 9/03/05 JE
from – “I left message for to confirm for 11:00 a.m. and for
4:30 p.m.”
 This message pad shows a friend of Jeffrey Epstein’s discussing with him how he had sex
with an 18 year old who had also been with Jeffrey Epstein. Giuffre – 001456 (pictured
above)– undated JE from Jean Luc – “He just did a good one – 18 years – she spoke
to me and said “I love Jeffrey.”
Law enforcement was able to confirm identities of underage victims through the use of
the names and telephone numbers in these message pads:
Q. The next line down is what I wanted to focus on, April 5th, 2005. This trash pull, what
evidence is yielded from this particular trash pull?
THE WITNESS: The trash pull indicated that there were several messages with written items
on it. There was a message from HR indicating that there would be an 11:00 appointment.
There were other individuals that had called during that day.
Q. And when you would -- when you would see females’ names and telephone numbers,
would you take those telephone numbers and match it to -- to a person?
THE WITNESS: We would do our best to identify who that person was.
Q. And is that one way in which you discovered the identities of some of the other what soon
came to be known as victims?
THE WITNESS: Correct.
***
Q. Did you find names of other witnesses and people that you knew to have been associated
with the house in those message pads?
THE WITNESS: Yes.
Q. And so what was the evidentiary value to you of the message pads collected from Jeffrey
Epstein’s home in the search warrant?
THE WITNESS: It was very important to corroborate what the victims had already told me
as to calling in and for work.31
7. The Black Book
Palm Beach Police confiscated an extensive lists of contacts with their phone numbers
form Defendant and Epstein’s residence.32 Ghislaine Maxwell maintained a contact list in an
31
See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 42:14-43:17; 78:25:-79:15.
22
approximately 100-page-long hard copy, which was openly available to other house employees.
It consisted primarily of telephone numbers, addresses, or email addresses for various personal
friends, associates, employees, or personal or business connections of Epstein or Defendant.
Prior to being terminated by Defendant, the Palm Beach house butler Alfredo Rodriguez printed
a copy of this document and ultimately provided it to the FBI. This document reflects the
numerous phone numbers of Defendant, Epstein as well as staff phone numbers. Additionally,
and importantly, there are several sections entitled “Massage” alongside a geographical
designation with names of females and corresponding telephone numbers. These numbers
included those of underage females (with no training in massage therapy ) – including
– identified during the criminal investigation of
Epstein. This document is an authentic reflection of the people who were associated with
Epstein, Defendant, and the management of their properties, and the knowledge each had of the
contents of the document.
8. Sex Slave Amazon.com Book Receipt
Detective Recarey authenticated an Amazon.com receipt that the Palm Beach Police
collected from Jeffrey Epstein’s trash. The books he ordered are titled:
(1) SM 101: A Realistic Introduction, Wiseman, Jay;
(2) SlaveCraft: Roadmaps for Erotic Servitude – Principles, Skills and Tools by Guy
Baldwin; and
(3) Training with Miss Abernathy: A Workbook for Erotic Slaves and Their Owners, by
Christina Abernathy, as shown below:
32
See McCawley Dec. at Exhibit 45, Phone List, Public Records Request No.: 16-268 at 2282 – 2288.
23
This disturbing 2005 purchase corroborate Ms. Giuffre’s account of being sexually
exploited by Defendant and Epstein – not to mention the dozens of underage girls in the Palm
Beach Police Report. Additionally, Defendant testified that she was not with Jeffrey Epstein in
2005 and 2006 when he was ordering books on how to use sex slaves; however, record evidence
contradicts that testimony.
9. Thailand Folder with Defendant’s Phone Number
Defendant also was integral in arranging to have Virginia go to Thailand. While Epstein
had paid for a massage therapy session in Thailand, there was a catch. Defendant told Virginia
she had to meet young girls in Thailand and bring her back to the U.S. for Epstein and
Defendant. Indeed, on the travel records and tickets Defendant gave to Virginia, Defendant wrote
on the back the name of the girl Virginia was supposed to meet, and she was also instructed to
check in frequently with Defendant as it was further signified by the words “Call Ms. Maxwell
(917) !” on Virginia’s travel documents. In this case, Virginia also produced the hard
copy records from her hotel stay in Thailand paid for by Epstein. See McCawley Dec. at Exhibit
32, 43, GIUFFRE 003191-003192; GIUFFRE 007411-007432.
24
10. It is undisputed fact that the FBI report and the Churcher emails
reference Ms. Giuffre’s accounts of sexual activity with Prince
Andrew that she made in 2011, contrary to Defendant’s argument
that Ms. Giuffre never made such claims until 2014.
Based on the FBI’s Interview of Ms. Giuffre in 2011, they wrote a report reflecting Ms.
Giuffre’s claims concerning her sexual encounters with Prince Andrew: 33
33
See McCawley Dec. at Exhibit 31, GIUFFRE001235-1246, FBI Redacted 302.
25
Additionally, 2011 correspondence with Sharon Churcher shows that Ms. Giuffre
disclosed her sexual encounters with Prince Andrew, but Churcher had to check with the
publisher’s lawyers “on how much can be published,”
See McCawley Dec. at Exhibit 34, GIUFFRE003678. Accordingly, there is documentary
evidence that refutes Defendant’s meritless argument that Ms. Giuffre did not allege she had sex
with Prince Andrew until 2014. To the contrary, two sources, including the FBI, show Ms.
Giuffre made these claims in 2011.
C. Defendant Has Produced No Documents Whatsoever That Tend to Show

That She Did Not Procure Underage Girls For Jeffrey Epstein.
Defendant has produced no documents that even tend to show that she did not procure
underage girls for sex with Epstein, and no documents that tend to show that she did not
participate in the abuse. Indeed, Defendant refused to produce any documents dated prior to
2009, which includes the 2000-2002 period during which she abused Ms. Giuffre.
Against this backdrop of an avalanche of evidence showing the Defendant sexually
trafficked Ms. Giuffre, summary judgment on any of the issues advanced by Defen dant is
inappropriate. While we discuss the particulars of the individual claims below, the larger picture
is important too. Ms. Giuffre will prove at trial that Epstein and Defendant sexually trafficked
her. And yet, when Ms. Giuffre had the courage to come forward and expose what Defendant
had done to world – in a Court pleading trying to hold Epstein accountable – Defendant
26
responded by calling her a liar in a press release intended for worldwide publication. Such
heinous conduct is not a mere “opinion,” but rather is defamation executed deliberately and with
actual malice. The jury should hear all of the evidence and then render its verdict on Ms.
Giuffre’s complaint.
III. LEGAL STANDARD
Rule 56 of the Federal Rules of Civil Procedure provides that a motion for summary
judgment may be granted only when “there is no genuine issue as to any material fact and that
the moving party is entitled to a judgment as a matter of law.” The Second Circuit has repeatedly
held that “all ambiguities and inferences to be drawn from the underlying facts should be
resolved in favor of the party opposing the motion, and all doubts as to the existence of a genuine
issue for trial should be resolved against the moving party.” Swan Brewery Co. Ltd. v. U.S. Trust
Co. of New York, 832 F. Supp. 714, 717 (S.D.N.Y. 1993) (Sweet, J.), citing Brady v. Town of
Colchester, 863 F.2d 205, 210 (2d Cir. 1988) (internal quotations omitted). In other words, in
deciding a motion for summary judgment, the court must construe the evidence in the light most
favorable to the non-moving party and draw all reasonable inferences in the non-moving party’s
favor. In re “Agent Orange” Prod. Liab. Litig., 517 F.3d 76, 87 (2d Cir. 2008). Stern v. Cosby,
645 F. Supp. 2d 258, 269 (S.D.N.Y.2009). Summary judgment should be denied “if the evidence
is such that a reasonable jury could return a verdict” in favor of the non-moving party. See Net
Jets Aviation, Inc. v. LHC Commc’ns, LLC, 537 F.3d 168, 178–79 (2d Cir. 2008).
IV. LEGAL ARGUMENT
A. Defendant is Liable for the Publication of the Defamatory Statement and

Damages for Its Publication
Defendant’s lead argument is that, when she issued a press release attacking Ms. Giuffre
to members of the media, she somehow is not responsible when the media quickly published her
27
attacks. If accepted, this remarkable claim would eviscerate defamation law, as it would permit a
defamer to send defamatory statements to the media and then stand back and watch – immune
from liability – when (as in this case) the defamatory statements are published around the world.
This absurd position is not the law, particularly given that the Defendant released a statement to
media asking them to “[p]lease find attached a quotable statement on behalf of Ms. Maxwell.”
To make her claim seem plausible, Defendant cites older cases, some dating back as far
as 1906. This presents a distorted picture of the case law on these issues. As a leading authority
on defamation explains with regard to liability for republication by another of statement by a
defendant: “Two standards have evolved. The older one is that the person making the defamatory
statement is liable for republication only if it occurs with his or her express or implied
authorization of consent. The more modern formulation adds responsibility for all republication
that can reasonably be anticipated or that is the ‘natural and probable consequence’ of the
publication.” SACK ON DEFAMATION § 2.7.2 at 2-113 to 2-114 (4th ed. 2016). In this case,
however, the nuances of the applicable legal standards make little difference because Defendant
so clearly authorized – indeed, desired and did everything possible to obtain – publication of her
defamatory statements attacking Ms. Giuffre.
1. Under New York Law, Defendant is liable for the media’s publication
of her press release.
Given the obvious purposes of defamation law, New York law unsurprisingly assigns
liability to individuals for the media’s publication of press releases. Indeed, New York appellate
courts have repeatedly held that an individual is liable for the media publishing that individual’s
defamatory press release. See Levy v. Smith, 18 N.Y.S.3d 438, 439, 132 A.D.3sd 961, 962–63
(N.Y.A.D. 2 Dept. 2015) (“Generally, [o]ne who makes a defamatory statement is not
responsible for its recommunication without his authority or request by another over whom he
28
has no control . . . Here, however . . . the appellant intended and authorized the republication of
the allegedly defamatory content of the press releases in the news articles”); National Puerto
Rican Day Parade, Inc. v. Casa Publications, Inc., 914 N.Y.S.2d 120, 123, 79 A.D.3d 592, 595
(N.Y.A.D. 1 Dept. 2010) (affirming the refusal to dismiss defamation counts against a defendant
who “submitted an open letter that was published in [a] newspaper, and that [the defendant] paid
to have the open letter published,” and finding that the defendant “authorized [the newspaper] to
recommunicate his statements.”) See also RESTATEMENT (SECOND) OF TORTS § 576 (1977) (“The
publication of a libel or slander is a legal cause of any special harm resulting from its repetition
by a third person if . . . the repetition was authorized or intended by the original defamer, or . . .
the repetition was reasonably to be expected.”)34
Defendant deliberately sent her defamatory statement to major news media publishers for
worldwide circulation because Defendant wanted the public at large to believe that Ms. Giuffre
was lying about her abuse. Defendant even hired a public relations media specialist to ensure the
media would publish her statement. Her efforts succeeded: her public relations agent instructed
dozens of media outlets to publish her “quotable” defamatory statement and they did.
Despite this deliberate campaign to widely publicize her defamatory statement,
Defendant now disclaims any responsibility for the media publishing her press release. If we
understand Defendant’s position correctly, because she somehow lacked “control” over what
major newspapers and other media finally put in their stories, she escapes liability for
defamation. This nonsensical position would let a defamer send a false and defamatory letter to
major media, and then, when they published the accusation, escape any liability. Such an
34
Cf., Eliah v. Ucatan Corp., 433 F. Supp. 309, 312–13 (W.D.N.Y. 1977) (“The alleged multistate publication of
plaintiff’s photograph without her consent thus gives rise to a single cause of action. … However, evidence of the
multistate publication of the magazine and the number of copies sold would be competent and pertinent to a
showing of damages, if any, suffered by plaintiff.”)
29
argument is not only an affront to logic, but it is contrary to prevailing New York case law, cited
above. Perhaps even more important, in the context of the pending summary judgment motion, it
would require Defendant to convince the jury that she did not “authorize or intend” for the major
media to publish her press release. Obviously the disputed facts on this point are legion, and
summary judgment is accordingly inappropriate.
Even the cases Defendant cites contradict her argument. She first cites Geraci v. Probst,
in which a defendant sent a letter to the Board of Fire Commissioners, and, years later, a
newspaper published the letter. The court held that the defendant was not liable for that belated
publication, “made years later without his knowledge or participation.” Id., at 340. By contrast,
Defendant not only authorized the defamatory statement, but paid money to her publicist to
convince media outlets to publish it promptly – actions taken with both her knowledge and
consent. Defendant’s statement was thus not published “without [her] authority or request,” as in
Geraci, but by her express authority and by her express request. Defendant’s publicist’s
testimony and the documents produced by Defendant’s publicist unambiguously establish that
the media published her press release with Defendant’s authority and by her request:
Q. When you sent that email were you acting pursuant to Ms. Maxwell’s retention of your
services?
A. Yes, I was
***
Q. The subject line does have “FW” which to me indicates it’s a forward. Do you know
where the rest of this email chain is?
A. My understanding of this is: It was a holiday in the UK, but Mr. Barden was not
necessarily accessible at some point in time, so this had been sent to him originally by Ms.
Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I
therefore respond, “Okay, Ghislaine, I’ll go with this.”
It is my understanding that this is the agreed statement because the subject of the second
one is “Urgent, this is the statement” so I take that as an instruction to send it out, as a
positive command: “This is the statement.”35
35
See McCawley Dec. at Exhibit 6, Ross Gow Dep. Tr. at 14:15-17; 44:6-45:13 (emphasis added).
30
Similarly, another case cited by Defendant, Davis v. Costa-Gavras, involved a libel claim
against a book author who wrote an account of the 1972 military coup in Chile. Years later, the
plaintiff attempted to ascribe defamation liability to a third-party publishing house’s decision to
republish the book in paperback form and a third-party filmmaker who released a movie based
on the book. The Court held that a “party who is ‘innocent of all complicity’ in the publication of
a libel cannot be held accountable . . . [but that] a deliberate decision to republish or active
participation in implementing the republication resurrects the liability.” 580 F. Supp. 1082, 1094
(S.D.N.Y. 1984). Here, Defendant made a deliberate decision to publish her press release, and
actively participated in that process. At the very least, the jury must make a determination of
whether Defendant was “innocent of all complicity” for a libelous statement contained in her
press release.
Finally, Defendant cites Karaduman v. Newsday, Inc., 416 N.E.2d 557 (1980), which
held that reporters of a series of articles on narcotics trade “cannot be held personally liable for
injuries arising from its subsequent republication in book form absent a showing that they
approved or participated in some other manner in the activities of the third-party republisher.”
Id., 416 N.E.2d at 559-560. Again, the jury could reasonably find that Defendant both approved
of, and even participated in, the media’s publication of her press release. Indeed, it is hard to
understand how any jury could find anything else. Defendant was obviously “active” in
influencing the media to publish her defamatory press release, she both “approved” of and
pushed for the publication of the press release. Accordingly, she is liable for its publication.36
36
On page 14 of her motion, Defendant makes wholly contradictory statements. In back-to-back sentences, she tells
the Court that (1) she has no control over whether the media published the statement she sent to the media (with
instructions to publish it by an influential publicist); (2) her public relations representative gave instructions to the
media on how to publish it (in full); and (3) her public relations representative “made no effort to control” how the
media would publish it. Indeed, the best evidence of Defendant’s control over the press is the fact dozens of media
outlets obeyed her directive to publish her defamatory statement.
31
Therefore, disclaiming responsibility for the media’s publication of a statement (for which she
hired a publicist for the purpose of influencing the media to publish that statement) is contrary to
both prevailing case law, and the cases cited by Defendant.
2. Defendant is liable for the media’s publication of the defamatory

statement.
After arguing, contrary to New York law, that she is not liable for the media’s publication
of her own press release, Defendant next argues that she is not liable for the media’s publications
of the defamatory statement contained within her press release if the media chose to make even
the tiniest of editorial changes. If we understand Defendant’s argument correctly, any omission
of any language from a press release is somehow a “selective, partial” publication for which she
escapes liability. Mot. at 14. Once again, this claim is absurd on its face. It would mean that a
defamer could send to the media a long attack on a victim with one irrelevant sentence and, when
the media quite predictably cut that sentence, escape liability for the attack. Moreover, even on
its face, the claim presents a jury question of what changes would be, in context, viewed as
“selective” or “partial” publications – something that only a jury could determine after hearing
all of the evidence.
In support of this meritless argument, Defendant cites Rand v. New York Times Co., for
the proposition that a defendant cannot be liable for a publisher’s “editing and excerpting of her
statement.” 430 N.Y.S.2d 271, 274, 75 A.D.2d 417, 422 (N.Y.A.D. 1980). This argument fails
for several reasons. First, there is no “republication” by the media as a matter of law. Defendant
issued a defamatory statement to the press, and its publication (as Defendant intended) is not a
“republication” under the law, as discussed above. Second, there was no “editing” or
paraphrasing or taking the quote out of context of the core defamatory statement in the press
release: that Ms. Giuffre is a liar. The “obvious lies” passage is the heart of the message
32
Defendant sent to the press: that Ms. Giuffre was lying about her past sexual abuse. Even in
isolation, Defendant’s quote stating that Ms. Giuffre’s claims are “obvious lies” does not distort
or misrepresent the message Defendant intended to convey to the public that Ms. Giuffre was
lying about her claims. As this Court explained in denying Defendant’s Motion to Dismiss, this
case “involves statements that explicitly claim the sexual assault allegations are false.” Giuffre v.
Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016).
Furthermore, the facts at issue here make the Rand holding inapposite. In Rand, a
newspaper paraphrased and “sanitized” defendant’s words. No such changing, sanitizing, or
paraphrasing occurred in the instant case: the media quoted Defendant’s statement accurately.
Further, the phrase at issue in Rand was that certain people “screwed” another person. The
speaker/newspaper used the term “screwed” in reference to a record label’s dealings with a
performing artist, and not did not mean “screwed” in the literal sense, but as “rhetorical
hyperbole, and as such, is not to be taken literally.” Id. By contrast, there is no hyperbole in
Defendant’s defamatory statement, and it was never distorted or paraphrased by any publication
known to Ms. Giuffre. A jury could reasonable conclude that Defendant’s statement that Ms.
Giuffre’s claims of child sexual abuse are “obvious lies” is not a rhetorical device, nor
hyperbole, but a literal and particular affirmation that Ms. Giuffre lied.
Accordingly, there is no support in the factual record that the media reporting that
Defendant stated that Ms. Giuffre’s claims of childhood sexual abuse are “obvious lies” is a
distortion of Defendant’s message or hyperbole. Even a cursory review of the press release
would lead to that conclusion. Moreover, to the extent that there is any dispute that Defendant’s
statement had a different meaning outside of the context of the remainder of the press release,
33
such a determination of meaning and interpretation is a question of fact for the jury to decide,
and is inappropriate for a determination upon summary judgment.
B. Material Issues of Fact Preclude Summary Judgment.
1. The Barden Declaration presents disputed issues of fact.
The primary basis of Defendant’s motion for summary judgment is her attorney’s self-
serving, post hoc affidavit wherein he sets forth his alleged “intent” with regard Defendant’s
defamatory statement.37 Ms. Giuffre disputes Defendant’s attorney’s alleged and unproven
“intent” (not to mention Defendant’s “intent”), not only because Defendant refuses to turn over
her attorney’s communications, but also because questions of intent are questions of fact to be
determined by a trier of fact. Furthermore, ample record evidence contradicts the claimed
“intent.”
a. The Barden Declaration is a deceptive back-door attempt to inject

Barden’s advice without providing discovery of all attorney
communications.
In her brief, Defendant discloses her attorney’s alleged legal strategy and alleged legal
advice; however, she deliberately states that her attorney “intended,” instead of her attorney
“advised,” when discussing her attorney’s legal strategy and advice, using that phrase at least 37
times,38 and using phrases such as Barden’s “beliefs,”39 “purposes,”40 “goals,”41 and
37
The Barden declaration is problematic for other reasons as well. In addition to Defendant’s over-length, 68-page
motion and among Defendant’s 654 pages of exhibits lies an eight-page attorney affidavit that proffers legal
conclusions and arguments. This exhibit is yet another improper attempt to circumvent this Court’s rules on page
limits. See Pacenza v. IBM Corp., 363 F. App'x 128, 130 (2d Cir. 2010) (affirming lower court decision to strike
“documents submitted . . . in support of his summary judgment motion [that] included legal conclusions and
arguments” because those “extraneous arguments constituted an attempt . . . to circumvent page-limit requirements
submitted to the court.”); cf. HB v. Monroe Woodbury Cent. School Dist., 2012 WL 4477552, at *6 (S.D.N.Y. Sept.
27, 2012) (“The device of incorporating an affirmation into a brief by reference, as Plaintiffs have done here, in
order to evade the twenty-five page limit, rather obviously defeats the purpose of the rule”). The court should
disregard the Barden Declaration for that reason alone
38
MSJ at 7 (three times), 8 (three), 15 (four), 16, 25 (five), 26, 33, 35 (two), 36 (three); Statement of Facts at 6
(two), 7 (five); Decl. of Philip Barden at 4 (four), 5 (three).
39
MSJ at 25, 35; Statement of Facts at 7 (two); Decl. of Philip Barden at 3, 4 (three), 5 (two).
40
MSJ at 8, 25, 35; Statement of Facts at 7 (three); Decl. of Philip Barden at 4 (two), 5 (three).
34
“contemplations” 25 other times. All the while Defendant has claimed a privilege as to her
communications with Barden. Defendant attempts to convince the Court that she only granted
Gow permission to publish the defamatory statement as part of “Mr. Barden’s deliberated and
carefully crafted” (MSJ at 16) legal strategy and advice. Yet, she still refused to turn over her
communications with Barden under the auspices of attorney-client privilege.42 Such
gamesmanship should not be permitted.
If the Court were to consider the Barden Declaration (which it shouldn’t), it would be
ruling on a less than complete record because, based on this Declaration, it is necessary that
Defendant disclose all communications with him and possibly others. Ms. Giuffre doesn’t have
those communications, the court doesn’t have those communications; therefore, Defendant is
asking for summary judgment on an incomplete record.
The Court should also not consider the Barden Declaration because it will be
inadmissible as unduly prejudicial. It is a self-serving declaration by a non-deposed witness
made without turning over the documents that are relevant to the declaration. See, e.g., Rubens v.
Mason, 387 F.3d 183, 185 (2d Cir. 2004) (“We find that the District Court predicated its grant of
summary judgment as to liability on an affidavit from the arbitrator who presided over the
underlying arbitration, the probative value of which was substantially outweighed by the danger
of unfair prejudice. The affidavit, therefore should not have been admitted. We therefore vacate
the grant of summary judgment to the defendants on liability and remand to the District Court.”).
b. Defendant’s summary judgment argument requires factual findings

regarding Barden’s intent, thereby precluding summary judgment.
Even were the Court to consider this Declaration and representations therein – which it
should not – the declaration itself demonstrates that the Court would have to make factual
41
MSJ at 27.
42
See McCawley Dec. at Exhibit 22, Defendant’s Privilege Log.
35
finding as to what Mr. Barden’s intent really was. Finding about intent are inappropriate at the
summary judgment stage, as this Court and the Second Circuit have recognized. This Court has
explained, “if it is necessary to resolve inferences regarding intent, summary judgment is not
appropriate.” Id. (Sweet, J.) (emphasis added), citing Patrick v. Le Fevre, 745 F.2d 153, 159 (2d
Cir. 1984); Friedman v. Meyers, 482 F.2d 435, 439 (2d Cir. 1973) (other citations omitted).
c. There are factual disputes regarding Barden’s Declaration.
Finally, there are material disputes over the statements in the Barden Declaration because
they are directly refuted by record evidence. For example, the instant motion and the Barden
Declaration describe the press release merely as a document expressing “his [Mr. Bardent’s]
opinion – in the form of a legal argument –as a lawyer would be,” as opposed to a press release
for dissemination by the media to the public. Record evidence refutes this claim, as (1) the press
release was sent to journalists, not media publishers or in-house counsel; (2) the press release
instructed the journalists to publish the defamatory statement (“Please find attached a quotable
statement on behalf of Ms. Maxwell”); (3) it was issued by a publicist on Defendant’s behalf and
not by an attorney, without any reference to attorneys or laws – indeed, Gow testified that
Barden was unavailable to approve the statement; and (4) Gow testified that he issued the
statement only after he understood Defendant to have “signed off” it, an understanding he
formed based on Defendant’s “positive command” to him: “This is the agreed statement.”
Q. When you sent that email were you acting pursuant to Ms. Maxwell’s retention of your
services?
A. Yes, I was.
***
Q. When you say “agreed statement” can you tell me more about what you mean? Who
agreed to the statement?
A. I need to give you some context, if I may, about that statement. So, this is on New Year’s
Day. I was in France so the email time here of 21:46, in French time was 22:46, and I was
getting up early the next morning to drive my family back from the south of France to
England, which is a 14-hour journey, door to door. So on the morning of the 2nd of January,
36
bearing in mind that Ms. Maxwell, I think was in New York then, she was five hours behind,
so there was quite a lot of, sort of time difference between the various countries here, I sent
her an email, I believe, saying - parsing this-- forwarding this email to her saying “How do
you wish to proceed?” And then I was on the telephone-- I had two telephones in the car, I
received in excess of 30 phone calls from various media outlets on the 2nd of January, all
asking for information about how Ms. Maxwell was looking to respond to the latest court
filings, which were filed on the 30th of December as I understand.
And by close-- towards close of play on the 2nd, I received an email forwarded by
Ms. Maxwell, containing a draft statement which my understanding was the majority of
which had been drafted by Mr. Barden with a header along the lines of “This is the agreed
statement.”· At close of play on the 2nd. So–I was–I had gone under the Channel Tunnel and
I was sitting on the other side and that email, which my understanding was that it had been
signed off by the client, effectively, was then sent out to a number of media, including Mr.
Ball and various other UK newspapers.
Q. Mr. Gow, when you say “end of play” and “close of play,” are you referring to sending
the email that is Exhibit 2?
A. Yes, I am
***
necessarily accessible at some point in time, so this had been sent to him originally by Ms.
Maxwell, and because he was unavailable, she forwarded it to me for immediate action.
I therefore respond, “Okay, Ghislaine, I’ll go with this.”
It is my understanding that this is the agreed statement because the subject of the
second one is “Urgent, this is the statement” so I take that as an instruction to send it
out, as a positive command: “This is the statement.”43
Accordingly, record evidence shows that the press release was intended as press release,
and not as a “legal argument.” Record evidence also establishes that Defendant circulated the
press release to Barden and Gow, and then gave a “positive command” to Gow to publish it.
Additionally, there is no indicia that the press release is a legal opinion. To the contrary, it was
issued by, and specifically attributed to, a woman who has personal knowledge of whether Ms.
Giuffre’s claims of sexual abuse are true, and she states that Ms. Giuffre is a liar.44 At the very
least, all of these factual issues must be considered by a jury.
43
See McCawley Dec. at Exhibit 6, Ross Gow Dep. Tr. at 14:15-17; 31:19-33:7; 44:6-45:13 (emphasis added).
44
Unsurprisingly, Defendant cites no case law to support her argument that her attorney’s alleged influence in
preparing the statement Defendant issued to the media somehow shields her from liability.
37
Another example is that Defendant states that “Gow served only as Mr. Barden’s conduit
to the media” (MTD at 25), and “Mr. Barden was directing the January 2-15 statement to a
discrete number of media representatives.” Barden wasn’t directing anything – he wasn’t even in
the loop when Defendant decided to publish the statement - and the documents prove it. Indeed,
the press release itself states that it is “on behalf of Ms. Maxwell,” not Barden, and it was
Defendant who gave the “positive command” to Gow to publish it. These are just a couple of
examples, among many, of the purported facts asserted in Defendant’s motion and Barden’s
Declaration that are directly refuted by facts in the record.
Finally, neither the media nor the general public could have known that the statement
should be attributed to Barden. His name was nowhere in it, nor is there any reference to counsel.
Defendant’s argument that the “context” is the media knowing Barden’s intent or involvement is
unsupported by the record. The significant factual disputes about Barden, alone, prevent
summary judgment.
C. Defendant’s Defamatory Statement Was Not Opinion as a Matter of Law.
As this Court previously held, correctly, Defendant stating that Ms. Giuffre’s claims of
sexual assault are lies is not an expression of opinion:
“First, statements that Giuffre’s claims ‘against [Defendant] are untrue,’ have
been ‘shown to be untrue,’ and are ‘obvious lies’ have a specific and readily
understood factual meaning: that Giuffre is not telling the truth about her history
of sexual abuse and Defendant’s role, and that some verifiable investigation has
occurred and come to a definitive conclusion proving that fact. Second, these
statements (as they themselves allege), are capable of being proven true or false,
and therefore constitute actionable fact and not opinion. Third, in their full
context, while Defendant’s statements have the effect of generally denying
Plaintiff’s story, they also clearly constitute fact to the reader.”
Giuffre v. Maxwell, 165 F. Supp. 3d 147, 152 (S.D.N.Y. 2016). This Court further explained:
“Plaintiff cannot be making claims shown to be untrue that are obvious lies
without being a liar. Furthermore, to suggest an individual is not telling the truth
38
about her history of having been sexually assaulted as a minor constitutes more
than a general denial, it alleges something deeply disturbing about the character of
an individual willing to be publicly dishonest about such a reprehensible crime.
Defendant’s statements clearly imply that the denials are based on facts separate
and contradictory to those that Plaintiff has alleged.” Id.
Defendant argues that somehow the “context” of the entire statement “tested against the
understanding of the average reader” should be the press release as a whole being read only by
journalists. This is an unreasonable construct because the ultimate audience for a press release is
the public. Indeed, the purpose of a press release is to reach readers. Unsurprisingly, Defendant
cites no case that holds that journalists might somehow believe statements of fact are opinion
while others do not.
This Court has previously covered this ground when it clearly stated:
Sexual assault of a minor is a clear-cut issue; either transgression occurred or it

did not. Either Maxwell was involved or she was not. The issue is not a matter of
opinion, and there cannot be differing understandings of the same facts that justify
diametrically opposed opinion as to whether Defendant was involved in Plaintiff’s
abuse as Plaintiff has claimed. Either Plaintiff is telling the truth about her story
and Defendant’s involvement, or Defendant is telling the truth and she was not
involved in the trafficking and ultimate abuse of Plaintiff.
Giuffre v. Maxwell, 165 F. Supp.at 152 (S.D.N.Y. 2016). The same conclusion applies now. At
the motion to dismiss stage, Defendant had not yet produced the statement she issued to the
press. That statement is now in evidence, so there is no ambiguity as to what defendant released
to the press.
The absurdity of Defendant characterizing his statements calling Ms. Giuffre a liar as
mere “opinion” is revealed by the fact that Defendant was the one who was sexually trafficking
and otherwise abusing Ms. Giuffre. No reasonable person in any context would construe that as
Defendant’s mere “opinion” on the subject, since Defendant knew she was abusing Ms. Giuffre.
Indeed, this argument is contradicted by Defendant’s own deposition testimony:
39
Q. Do you believe Jeffrey Epstein sexually abused minors?
A. I can only testify to what I know. I know that Virginia is a liar and I know what
she testified is a lie. So I can only testify to what I know to be a falsehood and half
those falsehoods are enormous and so I can only categorically deny everything she
has said and that is the only thing I can talk about because I have no knowledge of
anything else.
See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. (April 17, 2016) at 174:6-19.
Defendant slyly contends in her motion that “Mr. Barden’s “arguments” in the press release
constitute ‘pure opinion,’” attempting to disclaim any involvement in making the defamatory
statement. However, it is not Mr. Barden’s statement, nor his opinion, that it at issue here. At
issue here is Defendant’s statement – a statement attributable to her, that she approved, whose
publication she “command[ed],” and for which she hired a public relations representative to
disseminate to at least 30 journalists for publication. While Mr. Barden could possibly have had
his own opinion as to whether or not his client abused Ms. Giuffre, Defendant cannot express an
opinion on a binary, yes/no subject where she knows the truth. As this Court previously
articulated, “statements that Giuffre’s claims ‘against [defendant] are untrue,’ have been ‘shown
to be untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning.”
Giuffre v. Maxwell, 165 F. Supp. 3d at 152. Again, at the very least, the jury must pass on such
issues.
D. The Pre-Litigation Privilege Does Not Apply to Defendant’s Press Release
1. Defendant fails to make a showing that the pre-litigation privilege

applies.
Defendant’s next argument seeks refuge in the pre-litigation privilege. If we understand the
argument correctly, Defendant seems to be saying that because she was contemplating an
(unspecified and never-filed) lawsuit involving the British Press, she somehow had a “green
light” to make whatever defamatory statements she wanted about Ms. Giuffre. To prove such a
40
remarkably claim, Defendant relies on caselaw involving such mundane topics as “cease and
desist” letters sent to opposing parties and the like. Obviously such arguments have no
application to the press release that Defendant sent out, worldwide, attacking Ms. Giuffre’s
veracity.
The problems with the Defendant’s argument are legion. For starters, there is no record
evidence – not even Defendant’s own testimony – suggesting that she was contemplating
litigation against Ms. Giuffre, or that her press release was related to contemplated litigation
against Ms. Giuffre. Tellingly, the only “evidence” Defendant cites of any alleged contemplated
litigation is the self-serving, post hoc, partial waiver of attorney-client privilege found in the
Barden Declaration. As discussed above, that Declaration fails to establish that there was good
faith anticipated litigation between her and Ms. Giuffre, particularly when evidence in the record
contradicts such assertions. At the very least, it is a matter of fact for the jury to decide.
In another case in which a defendant attempted to claim pre-litigation privilege applied to
statements made to the press, this Court denied summary judgment, and held, “[t]o prevail on a
qualified privilege defense [defendant] must show that his claim of privilege does not raise
triable issues of fact that would defeat it.” Block v. First Blood Associates, 691 F. Supp. 685,
699-700 (Sweet, J.) (S.D.N.Y. 1988) (denying summary judgment on the pre-litigation qualified
privilege affirmative defense because there was “a genuine issue as to malice and appropriate
purpose”). Defendant’s claim here likewise fails.
First, Defendant’s testimony makes no mention of any contemplated lawsuit – much less,
any contemplated lawsuit against Ms. Giuffre. Second, Defendant has offered no witnesses who
will testify that she intended to bring any law suit. Third, she did not, in fact, bring any such
lawsuit. The only “evidence” is a post hoc Declaration written by her attorney. Finally, it must be
41
remembered, as explained at length above, the Defendant had sexually trafficking Defendant and
was attempting to continue to conceal her criminal acts. Whether her statements had an
“appropriate purpose,” Block 691 F. Supp. at 699-700 (Sweet, J.) – or were, rather, efforts by a
criminal organization to silence its victims – is obviously contested. Accordingly, obvious issues
of fact exist as to whether or not Defendant contemplated litigation.
Distorting reality, Defendant further argues: “Statements pertinent to a good faith
anticipated litigation made by attorneys (or their agents under their direction) before the
commencement of litigation are privileged.” (MSJ at 33). The record evidence shows that
Defendant’s attorney did not make the defamatory statement. Further, Defendant’s attorney’s
agents did not make the defamatory statement. Defendant did. And, there was no statement made
by anyone “before the commencement of litigation” because litigation never commenced.
Accordingly, the cases Defendant cites where attorneys are making statements (or where clients
are making statements to their attorneys regarding judicial proceedings including malpractice)
are wholly inapposite as detailed below.45
45
 Front v. Khalil, 24 N.Y.3d 713, 720 (2015) - statement made by attorney.

 Flomenhaft v. Finkelstein, 127 A.D.3d 634, 637 n.2, 8 N.Y.S.3d 161 (N.Y. App. Div. 2015) - did not even
address pre-litigation privilege, and said that Front, Inc. was not relevant to the case.
 Kirk v. Heppt, 532 F. Supp. 2d 586, 593 (S.D.N.Y. 2008) - the communication at issue was made by an
attorney’s client to the attorney’s malpractice carrier concerning the client’s justiciable controversy against the
attorney over which the clients actually sued.
 Petrus v Smith, 91 A.D.2d 1190 (N.Y.A.D.,1983) - the court held: “[r]emarks of attorney to Surrogate are
cloaked with absolute immunity as statements made in course of judicial proceedings – Attorney’s gratuitous
opinion outside courthouse calling plaintiff liar . . . is not similarly immune.” (This case undermines the false
argument Defendant tries to make).
 Klien - contrary to dicta quoted by Defendant from the Klein case, there were no communications made
“between litigating parties or their attorneys,” just a press release Defendant instructed her press agent to
disseminate to the media.
 Frechtman v. Gutterman, 115 A.D.3d 102, 103, 979 N.Y.S.2d 58, 61 (2014) - the communication at issue was a
letter sent by a client to his attorney terminating the representation for malpractice.
 Sexter & Warmflash, P.C. v. Margrabe, 38 A.D.3d 163 (N.Y.A.D. 1 Dept. 2007) - privilege applied to letter
client sent discharging law firm as the client’s attorneys as statements relating to a judicial proceeding and law
firm sued for defamation.
42
Similarly, in Black v. Green Harbour Homeowners’ Ass’n, Inc., 19 A.D.3d 962, 963, 798
N.Y.S.2d 753, 754 (2005), cited by Defendant, the Court held a privilege applied to a letter sent
by a home owner’s association board of directors to the association’s members informing them
of the status of litigation to which the association was a party, and to the association’s letter to
the state attorney general sent to discharge it’s duties to the association. In this case, litigation
was actually pending, the communication was sent by a party to that litigation as part of its
duties, and the communication itself concerned the litigation. Defendant’s press release fits none
of those descriptions.
Unsurprisingly, Defendant cites to no case in which a Court has held that this or any
qualified privilege extends to internationally disseminated press releases defaming a non-party to
the purported “anticipated” litigation. Regardless of whether or not Barden had a hand in drafting
the statement (another disputed issue of fact for the jury), Defendant issued the statement,
instructed that it be published, and the statement she issued was attributed to her, and not to her
attorney (or his agents). Accordingly, all the case law Defendant cites about an attorney making
a statement (or a client making a statement to their attorney or malpractice carrier) is inapposite.
2. Defendant is foreclosed from using the pre-litigation privilege because

she acted with malice.
In any event, because Defendant acted with malice, she cannot avail herself of the pre-
litigation privilege. As this Court has explained denying Defendant’s motion to dismiss, “‘There
is no qualified privilege under New York law when such statements are spoken with malice,
knowledge of their falsity, or reckless disregard for their truth.’” Giuffre v. Maxwell, 165 F.
Supp. 3d at 155 (citing Block, 691 F. Supp. at 699 (Sweet, J.) (S.D.N.Y. 1988). There is ample
record evidence that Defendant acted with malice in issuing the press release, thereby making the
litigation privilege inapplicable. See Block, 691 F. Supp. at 700 (Sweet, J.) (“Here, sufficient
43
evidence has been adduced to support the inference that [defendant] acted with malice, and may
not, therefore, claim a qualified privilege under New York law . . . a genuine issue as to malice
and appropriate purpose has properly been raised and is sufficient to preclude summary
judgment.”). For example, Ms. Sjoberg testified that Defendant recruited her for sex with
Epstein, thus corroborating Ms. Giuffre’s own account of Defendant’s involvement in abusing
her with Epstein. For another example, Jeffrey Epstein’s pilot testified that Defendant flew with
Ms. Giuffre on at least 23 flights, thus corroborating Ms. Giuffre’s claims against Defendant. See
McCawley Dec. at Exhibit 15, Rodgers Dep. Tr., at 34:3-10. For another example, Tony
Figueroa testified that Defendant asked him for assistance in recruiting girls for Epstein – more
testimony that corroborates Ms. Giuffre’s claims against Defendant.
Defendant’s statements that Ms. Giuffre was lying and her claims of sexual abuse were
“obvious lies” were not pertinent to a good faith anticipated litigation but, instead, they were
made for an inappropriate purpose – i.e., to bully, harass, intimidate, and ultimately silence Ms.
Giuffre. As the record evidence shows, Defendant knew the statements were false because
Defendant engaged in and facilitated the sexual abuse of this minor child, therefore, they were
made for the inappropriate purpose of “bullying,” “harassment,” and “intimidation.” See Front v.
Khalil, 24 N.Y.3d 713, 720 (2015). Simply put, Defendant sexually trafficked Ms. Giuffre – and
then tried to silence Ms. Giuffre to keep her crimes secret – circumstances that prevent her from
using privileges designed to shield legitimate legal disputes from court interference.
New York case law fully confirms that pre-litigation qualified privilege does not apply to
this case. Historically, statements made in the course of litigation were entitled to privilege from
defamations claims “so that those discharging a public function may speak freely to zealously
represent their clients without fear of reprisal or financial hazard.” Id. at 718. A 2015 New York
44
Court of Appeals case somewhat extended this privilege by holding that statements made by
attorneys prior to the commencement of the litigation are protected by a qualified privilege if
those statements are pertinent to a good faith anticipated litigation. Id. at 718. (“Although it is
well settled that statements made in the course of litigation are entitled to absolute privilege, the
Court has not directly addressed whether statements made by an attorney on behalf of his or her
client in connection with prospective litigation are privileged” . . . “to advance the goals of
encouraging communication prior to the commencement of litigation” . . . “we hold that
statements made prior to the commencement of an anticipated litigation are privileged, and that
the privilege is lost where a defendant proves that the statements were not pertinent to a good
faith anticipated litigation.”).
The Court of Appeals’ reason for allowing this qualified privilege could not be more
clear: “When litigation is anticipated, attorneys and parties should be free to communicate in
order to reduce or avoid the need to actually commence litigation. Attorneys often send cease
and desist letters to avoid litigation. Applying privilege to such preliminary communication
encourages potential defendants to negotiate with potential plaintiffs in order to prevent costly
and time consuming judicial intervention.” Id. at 719-20. Under this rationale, the Khalil court
found that an attorney’s letters to the potential defendant were privileged because they were sent
“in an attempt to avoid litigation by requesting, among other things, that Khalil return the alleged
stolen proprietary information and cease and desist his use of that information.” Id. at 720.
Here, quite unlike Khalil, the Defendant’s statements were (1) made by a non-attorney
(Defendant through Gow); (2) concerning a non-party to any alleged anticipated litigation; (3)
knowingly false statements; and (4) contained in a press release directed at, and disseminated to,
45
the public at large. Defendant’s statements cannot be considered “pertinent to a good faith
anticipated litigation,” such that the qualified privilege should apply.
Finally, though it strains credulity to even entertain the prospect, if Defendant could
make even colorable showings on these basic issues, it would remain an issue of fact for the jury
to determine whether or not Defendant’s press release, calling Ms. Giuffre’s sex abuse claims
“obvious lies,” was any type of “cease-and-desist” statement or a statement that acted to “reduce
or avoid” or resolve any “anticipated” litigation. Summary judgment is obviously inappropriate
here as well.
3. Defendant cannot invoke the pre-litigation privilege because she has

no “meritorious claim” for “good faith” litigation.
Finally, Defendant cannot prevail in asserting this qualified privilege because, in order to
invoke this privilege, she must have “meritorious claims” for “good faith anticipated litigation.”
Khalil specifically states that for the qualified privilege to apply, the statements must be made
“pertinent to a good faith anticipated litigation,” and it does not protect attorneys . . . asserting
wholly unmeritorious claims, unsupported in law and fact, in violation of counsel’s ethical
obligations.” Khalil, 24 N.Y.3d at 718, 720 (emphasis added). Defendant has neither
“meritorious claims” nor “good faith anticipated litigation.” Defendant cannot have a
“meritorious claim” for “good faith anticipated litigation” against the press (or Ms. Giuffre)
because Ms. Giuffre’s reports of her sexual abuse are true, Defendant knows that they are true,
and Defendant made a knowingly false statement when she called Ms. Giuffre a liar. Under these
circumstances, Defendant has no “meritorious” claim to make in “good faith” relating to either
Ms. Giuffre’s statements or their coverage in the press, thereby making her defamatory
statements wholly outside the protection of this qualified privilege. At the very least, the issue of
46
whether Defendant has meritorious claims against the press on the grounds that she did not abuse
Ms. Giuffre is a question of fact for the jury to decide.
V. DEFENDANT HAS NOT - AND CANNOT - SHOW THAT HER DEFAMATORY

STATEMENT IS SUBSTANTIALLY TRUE
Defendant next claims that her press release calling Ms. Giuffre a liar about her past sex
abuse was somehow “substantially true.” Here again, this is a highly disputed claim. On its face,
to determine what is “substantially” true or not requires extensive fact finding, such as whether
Defendant recruited Ms. Giuffre as a minor child for sex with Defendant’s live-in boyfriend and
convicted pedophile, Jeffrey Epstein. Accordingly, summary judgment is not appropriate. See
Mitre Sports Intern. Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 255 (S.D.N.Y.2014)
(denying summary judgment because it would require the Court to decide disputed facts to
determine whether the statement at issue was substantially true); Da Silva v. Time Inc., 908 F.
Supp. 184, 187 (S.D.N.Y. 1995) (denying motion for summary judgment because there was a
genuine issue of material act as to whether defamatory photo and caption were not true, stating
“[i]n the instant case Da Silva’s contention that she was a reformed prostitute at the time of
photography and publication provides a rational basis upon which a fact-finder could conclude
that the photograph was not substantially true”).
Additionally, Defendant has remarkably not submitted any evidence that she did not
recruit Ms. Giuffre for sex with Epstein. Nor has Defendant offered any evidence that her role in
Epstein’s household was not to recruit girls and young women for Jeffrey Epstein. Accordingly,
summary judgment is inappropriate. See Stern v. Cosby, 645 F. Supp. 2d 258, 277 (S.D.N.Y.
2009) (because defendant had “not submitted any evidence to show that Statement 11 is
substantially true, her motion for summary judgment as to Statement 11 is denied”).
47
Further, much of the purported evidence upon which Defendant relies to allege the truth
of her defamatory statement is merely hearsay, including inadmissible hearsay statements made
by Alan Dershowitz, who Defendant did not depose in this case (and whom Ms. Giuffre has not
had an opportunity to cross examine). Hearsay cannot establish the truth of a defamatory
statement as a matter of law at summary judgment. Lopez v. Univision Communications, Inc., 45
F. Supp.2d 348, 359 (S.D.N.Y.1999) (denying summary judgment and holding “defendants’
evidence as to what they were told by representatives of NYU and Kean College, to the extent
offered for the truth of the matters asserted, is inadmissible hearsay and an insufficient basis
upon which to grant summary judgment of dismissal on the ground that the statements were
substantially true.”).
Finally, many of the facts upon which Defendant bases her argument that her defamatory
statement was true are wholly tangential to the claims against her by Ms. Giuffre and the
defamatory statement. For example, Defendant supports her contention that she did not recruit
Ms. Giuffre for sex with Epstein based on the fact that Ms. Giuffre lived independently of her
parents before meeting Epstein and Ms. Maxwell. (Of course, a child outside the supervision of
her parents makes it much more likely she would be recruited by Defendant into sex trafficking,
but that is for the jury to decide.) That fact does not go to whether or not Defendant’s statement
calling Ms. Giuffre a liar is true, because Ms. Giuffre never made any claims relating to where
she lived prior to meeting Defendant. Moreover, it is immaterial with whom she was living: the
fundamental and overarching fact remains that Defendant recruited Ms. Giuffre for sex with
Epstein when she was a minor child.
Defendant next proffers Ms. Giuffre’s limited high school enrollment and short-term jobs
that she held as evidence that she and Epstein did not abuse her. The logic of this position is
48
unclear. The fact that Ms. Giuffre worked at Taco Bell for a few days hardly establishes she was
not abused by Defendant and Epstein. Indeed, if anything its shows the vulnerability of Ms.
Giuffre to enticements that a billionaire and his wealthy and powerful girlfriend could offer. In
any event, what to make of such fact is something for the jury to consider. They are irrelevant for
the same reason as above: Ms. Giuffre never made any claims about her studies or her prior
employment. Indeed, neither Ms. Giuffre’s statement about being recruited by Defendant as a
child, nor Defendant’s refutation even mentions Ms. Giuffre’s lack of schooling or lack of a
stable home as a child. Purported facts that have nothing to do with Ms. Giuffre’s claims of
sexual abuse against Defendant, and nothing to do with Defendant calling Ms. Giuffre a liar for
such claims, do not establish the “substantial truth” of Defendant’s statement. Tellingly,
Defendant cites to no analogous case in any jurisdiction that even suggests otherwise.
VI. PLAINTIFF DOES NOT NEED TO ESTABLISH MALICE FOR HER

DEFAMATION CLAIM, BUT IN THE EVENT THE COURT RULES
OTHERWISE, THERE IS MORE THAN SUFFICIENT RECORD EVIDENCE
FOR A REASONABLE JURY TO DETERMINE DEFENDANT ACTED WITH
ACTUAL MALICE
Defendant’s next (and, again, quite remarkable) argument is that Ms. Giuffre somehow
will be unable to establish actual malice in this case. One would think that a sex trafficker calling
one of her victims a liar would be a quintessential example of actual malice. Defendant’s
spurious case citations and misplaced argument do not detract from this core fact.
Though Defendant does not mention the legal standard for actual malice until she is 48
pages into her 68-page brief,46 the legal definition of actual malice, as defined by the United
46
Though perhaps a scrivener’s error, Defendant errantly cites to two Supreme Court cases – Gerts v. Robert Welch,
Inc., 418 U.S. 323 (1974) and Philadelphia Newspapers, Inc. v. Hepps, 475 U.S. 767 (1986) – that arose out of the
laws of Illinois and Pennsylvania, respectively, to support a proposition concerning New York law. Defendant also
cites to Harte-Hanks Commc'ns, Inc. v. Connaughton, 491 U.S. 657, 109 S. Ct. 2678, 105 L. Ed. 2d 562 (1989),
wherein the ruling was not at summary judgment, and the plaintiff in the defamation case was a judicial candidate in
a public election.
49
States Supreme Court, and reiterated by the Second Circuit, should be the light by which all of
Defendant’s purported “facts” and argument should be viewed. “Actual malice” means that the
statement was published with “knowledge that the statement was ‘false or with reckless
disregard of whether it was false or not.’” Baiul v. Disson, 607 F. App'x 18, 20 (2d Cir. 2015),
quoting New York Times Co. v. Sullivan, 376 U.S. 254, 280, 84 S. Ct. 710, 11 L.Ed.2d 686
(1964).
Defendant argues that Ms. Giuffre is a limited purpose public figure. While Ms. Giuffre
disputes that claim, the issue is entirely irrelevant here because Ms. Giuffre will prove at trial,
with overwhelming evidence, that Defendant made her statement calling Ms. Giuffre a liar with
malice, fully knowing – as a sex trafficker – that it was false. Put another way, Defendant knew
that Ms. Giuffre was telling the truth when she described how Defendant recruited her for sex as
an underage girl and then sexually trafficked her with her boyfriend Jeffrey Epstein.
The Second Circuit instructs that, “[o]n a motion for summary judgment, a court cannot
try issues of fact; it can only determine whether there are issues to be tried. If, as to the issue on
which summary judgment is sought, there is any evidence in the record from any source from
which a reasonable inference could be drawn in favor of the nonmoving party, summary
judgment is improper.” Chambers v. TRM Copy Ctrs. Corp., 43 F.3d 29, 37 (2d Cir. 1994)
(internal citations and quotations omitted). “As the moving party, Defendants have the burden of
demonstrating an absence of clear and convincing evidence substantiating Plaintiffs’ claims.” De
Sole v. Knoedler Gallery, LLC, 139 F. Supp. 3d 618, 640 (S.D.N.Y. 2015) (citing Chambers).
Defendant fails to meet her burden of demonstrating an absence of clear and convincing
evidence substantiating Ms. Giuffre’s claims that Defendant acted with actual malice. Ms.
Giuffre will easily be able to meet any trial burden of clear and convincing evidence of actual
50
malice. Tellingly, Defendant does not even attempt to address the documentary evidence, nor the
testimonial evidence showing she was a recruiter of girls for Epstein.
As shown above, far beyond showing that a reasonable inference could be drawn in her
favor, which is all that is required at this point to defeat Defendant’s motion, Ms. Giuffre will
easily be able to meet her trial burden of clear and convincing evidence of actual malice.
Of course, a plaintiff need only show “actual malice” on the part of a defendant if that
plaintiff is a public figure or a limited public figure, which Ms. Giuffre is not, as explained infra.
VII. THE COURT NEED NOT REACH THE ISSUE, AT THIS TIME, OF WHETHER
MS. GIUFFRE IS A LIMITED PURPOSE PUBLIC FIGURE
For the reasons just explained, Ms. Giuffre will easily be able to prove actual malice at
the trial in this case. Defendant argues that Ms. Giuffre “is a public figure who must prove actual
malice.” MSJ at 49. Given the overwhelming proof of the second part of that statement, the
Court need not spend its time considering the first.
If the Court wishes to nonetheless consider the issue at this time, it is not appropriate for
disposition at the summary judgment stage of this case. The defendant bears the burden of
demonstrating that the plaintiff is a limited purpose public figure. See Lerman v. Flynt Distrib.
Co., 745 F.2d 123, 136–37 (2d Cir. 1984). Defendant correctly articulates the legal test for a
finding that a plaintiff is a limited purpose public figure, but glosses over the fact that all prongs
of the test must be met in order for a court to make that finding. See, e.g., Contemporary
Mission, Inc. v. N.Y. Times Co., 842 F.2d 612, 617 (2d Cir. 1988) (“[T]his court set forth a four
part test for determining whether someone is a limited purpose public figure” (emphasis added));
Herbert v. Lando, 596 F. Supp. 1178, 1186 (S.D.N.Y. 1984) (“The Second Circuit recently
summarized the criteria” (emphasis added)), aff’d in part, rev’d in part, 781 F.2d 298 (2d Cir.
1986); cf. Nehls v. Hillsdale Coll., 178 F. Supp. 2d 771, 778 (E.D. Mich. 2001) (finding plaintiff
51
was not a limited public figure for failing one element of the Lerman test and thus denying
defendant’s motion for summary judgment) (“The defendant has proven all of the elements but
the third …”), aff’d, 65 F. App’x 984 (6th Cir. 2003). Of course, proof that Ms. Giuffre (or
anyone else) is a limited purpose public figure requires proof of a set of facts from which Ms.
Giuffre believes Defendant has not shown in satisfaction of the four-part test.
Significantly –this Court should pause here to note that the details of Jane Doe 3’s sexual
exploitation and abuse, as anonymously set forth in her CVRA joinder motion, caused the
Defendant to identify, with certainty, Jane Doe 3 as Ms. Giuffre. Yet, at her deposition,
Defendant claimed to “barely remember her at all.”47 Defendant’s ability to immediately and
positively identify the anonymous individual making claims of sexual abuse, if anything, shows
that Defendant was intimately aware of Ms. Giuffre’s sexual exploitation.
And, to be sure, Ms. Giuffre never asked to be sexually abused or trafficked by
Defendant or convicted pedophile Jeffrey Epstein when she was a child – legally, she did not
even have the capacity to consent. Defendant cannot recruit a minor child for sexual exploitation
and then, afterwards, argue that her victim injected herself into the public controversy when
coming forward about the abuse she suffered.
Moreover, Defendant has not made a sufficient showing that Ms. Giuffre has “regular”
and “continuing” access to the news media. The policy rationale behind this prong is that public
figures generally enjoy significant access to the media. One reporter wrote some articles on Ms.
Giuffre in 2011. Thereafter, it was not until 2015, that Ms. Giuffre spoke to someone in the news
media about these issues, and that interview was granted after Defendant’s defamatory remarks.
Such limited contacts precludes a finding that Ms. Giuffre is a limited public figure. See
47
See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 44:23-45:4 (July 22, 2016) (“Q. You do remember
Virginia, about that time back in the 2000s, giving Mr. Epstein massages? A. I barely remember her at all.”).
52
Hutchinson v. Proxmire, 443 U.S. 111, 99 S. Ct. 2675, 61 L.Ed.2d 411 (1979) (finding plaintiff
maintained no regular and continuing access to the media and thus was not a public figure).
It is also unclear how Defendant plans to show that Ms. Giuffre “successfully invited
public attention to her views.” To be sure, Ms. Giuffre decided to start “Victims Refuse Silence,”
a not-for-profit organization whose mission is “to change the landscape of the war on sexual
abuse and human trafficking. Our goal is to undertake an instrumental role in helping survivors
break the silence associated with sexual abuse. To fulfill this mission, we aim to enhance the
lives of women who have been victimized.”48 The website lists the National Trafficking Hotline,
and provides a state-by-state resources for local organizations where victims can seek help.
Unsurprisingly, Defendant cites no cases that hold that maintaining a website makes one a public
figure. See Mitre Sports Int’l Ltd. v. Home Box Office, Inc., 22 F. Supp. 3d 240, 252 (S.D.N.Y.
2014) (finding plaintiff was not a limited public figure and denying defendant’s motion for
summary judgment) (“corporate policy denouncing child labor on its website … do[es] not show
that Mitre … aimed to influence the public’s views on the controversy”). More important,
Defendant does not explain how Ms. Giuffre was using the website to influence public views on
whether she had been abused by Defendant – the subject at issue in this lawsuit.
Interestingly, Defendant has spent $ 17,87549 on an expert witness to tell the Court and
the jury that hardly anyone searches on the internet using search terms such as “victims refuse
silence sex slave.” One of Defendant’s six briefs raising Daubert issues specifically argues that
Dr. Anderson’s estimates on the cost of remediating Ms. Giuffre’s online reputation are improper
because Dr. Anderson included nearly unused search phrases when evaluating internet content.
Kent’s rebuttal report states: “. . . there seems no reason to believe that such a person would use
48
http://www.victimsrefusesilence.org/our-mission.
49
See McCawley Dec. at Exhibit 9, Kent Dep. Tr. at 25:16-26:6.
53
this term . . . Indeed, these are terms unlikely to be used by anyone unfamiliar with this litigation.
. . . Why, for instance, would it be necessary to push down offending Web pages in the results
that the search engines provide for the term victim’s refuse silence sex slave, when this term is
likely never used . . .” See McCawley Dec. at Exhibit 25, Kent Report at 10, 33.
Defendant cannot argue to the Court that Ms. Giuffre has “successfully” invited public
attention to her views through her VRS website while simultaneously filing a Daubert motion
that argues that search terms such as “victims refuse silence sex slave” are “likely never used,”
thus making the website unsuccessful in inviting public attention. In any event, Defendant has
failed to set forth with precision the allegedly undisputed fact – and supporting evidence – she
uses to support her argument.
Moreover, “[i]t is preferable to reduce the public figure question to a more meaningful
context by looking to the nature and extent of an individual’s participation in the particular
controversy giving rise to the defamation.” Greenberg v. CBS Inc., 69 A.D.2d 693, 704, 419
N.Y.S.2d 988, 995 (1979) (emphasis added), citing Gertz v. Robert Welch, Inc., 418 U.S. 323,
345, 352, 94 S. Ct. 2997, 41 L.Ed.2d 789. The context here is highly significant. Ms. Giuffre
never chose to participate in Defendant and Epstein’s underage sex ring, a “controversy” that
gave rise to Defendant’s defamation. In arguing that Ms. Giuffre thrust herself into the public
spotlight, Defendant conveniently leaves out the fact that it is by her doing that Ms. Giuffre is in
this controversy in the first place. No minor child willingly becomes a participant in sexual
abuse, and it is perverse for the abuser to argue that her victim deliberately became a subject of
public attention when speaking out about that abuse for the purpose of advancing justice and
helping other victims.
54
For all these reasons, the Court should simply decline to decide the public figure issue at
this juncture. But if it chooses to reach the issue, it should reject Defendant’s unsupported
argument.
VIII. THE JANUARY 2015 STATEMENT WAS NOT “SUBSTANTIALLY TRUE,”

AND MS. GIUFFRE HAS PRODUCED CLEAR AND CONVINCING EVIDENCE
OF ITS FALSITY
As a final argument, Defendant argues that her January 2015 statement was “substantially
true.” Given that the statement argues that Ms. Giuffre lied when she said she was sexually
trafficked by Defendant, the reader of Defendant’s motion might reasonably expect to see some
evidence presented showing that Defendant was not a sex trafficker. Instead, the reader is treated
to technical quibbles. For example, the lead argument to show the “substantial” truth of
Defendant’s statement is the argument that Ms. Giuffre was not fifteen years old, but all of
sixteen or seventeen years old when she was trafficked. As the Court knows (and can take
judicial notice of), Florida law makes age eighteen the age of consent. Accordingly, it is no
moment that Ms. Giuffre may have been mistaken about the exact year the sex trafficking
started. Call this the “yes-I’m-a-sex-trafficker-but-only-of-sixteen-year-old-girls” defense. To
even describe the defense is to show how meritless it is.
More broadly, at issue are the statements Ms. Giuffre made regarding Defendant’s
involvement in, and knowledge of, the sexual abuse and sex trafficking of Ms. Giuffre (and other
minor girls) through a recruitment scheme executed by Defendant and Jeffrey Epstein. In
response to those various statements, Defendant publicly claimed that, “the allegations made by
(Ms. Giuffre) against Ghislaine Maxwell are untrue.” Defendant continued that Ms. Giuffre’s
“claims are obvious lies and should be treated as such....” Defendant, through her statement
55
intended to convey that Ms. Giuffre was lying about everything she had said against Defendant –
“the allegations.”
In sum and essence, those statements made by Ms. Giuffre about which Defendant
released a public statement to exclaim were “untrue” and “obvious lies” were:
(1) That Defendant approached Ms. Giuffre while Ms. Giuffre was an underage
minor working at the Mar-a-Lago Country Club, and recruited the then-minor
Ms. Giuffre to go to the house of Jeffrey Epstein under the pretense of providing
a massage to Jeffrey Epstein for money;
(2) That Ms. Giuffre followed Defendant’s instructions, and was driven to Jeffrey
Epstein’s house, where she was greeted by Defendant and later introduced to
Jeffrey Epstein;
(3) That Ms. Giuffre was lead upstairs to be introduced to Jeffrey Epstein in his
bedroom, and that while there Defendant demonstrated how Ms. Giuffre should
provide a massage to Jeffrey Epstein;
(4) That Defendant and Epstein converted the massage into a sexual experience,
requesting that Ms. Giuffre remove her clothing, after which time a sexual
encounter was had;
(5) That Defendant and Epstein expressed approval for Ms. Giuffre, and offered her
money in exchange for this erotic massage turned full sexual encounter;
(6) That Defendant and Epstein offered Ms. Giuffre the promise of money and a
better life in exchange for Ms. Giuffre acting sexually compliant and
subservient to their demands;
(7) That Ms. Giuffre, after that first encounter, was repeatedly requested to service
Epstein and/or Defendant sexually and/or others;
(8) That Ms. Giuffre was taken on Epstein’s private planes on numerous occasions
and trafficked nationally and internationally for the purpose of servicing Epstein
and others, including Defendant, sexually;
(9) That Defendant was Epstein’s primary manager of the recruitment and training
of females who Epstein paid for sexual purposes;
(10) That Defendant participated in sexual encounters with females, including Ms.
Giuffre; and
(11) That Ms. Giuffre and other recruited females were encouraged by Defendant
and Epstein to bring other young females to Epstein for the purpose of servicing
him sexually.
56
Defendant, by way of her January 2015 statement, declared that Ms. Giuffre lied about
each and every one of these allegations regarding Defendant. In fact, Defendant clarified further
this position in her deposition when she said repeatedly that everything Ms. Giuffre said about
Defendant was totally false.50 The clarification in her deposition is identical in intention to the
reasonable interpretation of her statement that Defendant made publicly, which has formed the
basis of this defamation action—that Ms. Giuffre was lying about everything she said about
Defendant, and that Defendant was not at all involved in the activity she was accused of
engaging in.
While her public statement could not have been more clear, as her deposition testimony
further underscored, Defendant intended the world to believe that nothing Ms. Giuffre said about
Defendant was true, and that Defendant was not at all involved with any of the things she was
accused of, Defendant has decided in this motion to minutely dissect the nuance of Ms. Giuffre’s
various statements to cause the Court to reach a far-fetched conclusion that Defendant’s
insidiously false statement was somehow “substantially true.” Ironically, this
repositioning amounts to nothing more than an admission by Defendant of the defamatory nature
of her statement.
A. When Ms. Giuffre Initially Described Her Encounters With Defendant and
Epstein, She Mistakenly Believed the First Encounter Occurred During the
Year 1999.
Discovery has resulted in the production of records, including Ms. Giuffre’s employment
records from Mar-a-Lago, which she did not possess at the time she was recounting her
interactions with Defendant. Those records establish that the initial encounter wherein Defendant
recruited Ms. Giuffre occurred during the year 2000 and not during 1999. Ms. Giuffre was
50
See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 135:3-4; 178:15-178:24; 179:20-180:7; 228:7-
229:10.
57
sixteen years old before August 9, 2000, and turned seventeen on that date. It is unclear from the
limited records available whether Defendant approached and recruited Ms. Giuffre before or just
after Ms. Giuffre’s 17th birthday. However, what has now been established through numerous
witnesses is that Defendant approached and recruited a minor child for the purposes of enticing
that minor over to the house of Jeffrey Epstein, a currently-registered sex offender.51 The exact
lure of Ms. Giuffre by Defendant - enticement of being paid money to give a billionaire a
massage at his mansion - was used by Epstein and his many associates and employees to recruit
dozens and dozens of other underage girls. There is no doubt that the crux of Ms. Giuffre’s
statement on this point is that Defendant recruited her when she was only a minor child unable to
consent to sex, not precisely how far under the age of consent she was. Defendant’s public claim
that Ms. Giuffre’s account of this approach, and recruiting element, was “untrue” and “obvious
lies” is not “substantially true,” but is itself an obvious lie – as Ms. Giuffre will prove to the jury
at trial.
B. Defendant’s January 2015 Statement Claiming as “Untrue” and an “Obvious

Lie” the Allegation That She Regularly Participated in Epstein’s Sexual
Exploitation of Minors and That the Government Knows Such Fact is Not
Substantially True But Instead Completely False.
Defendant next argues that she “accurately denied that [she] ‘regularly participate[d] in
Epstein’s sexual exploitation on minors’ and that ‘the Government knows such fact.’” MSJ at 58.
It is not clear whether Defendant is nitpicking this statement by contesting whether she
“regularly” participated in Epstein’s sexual exploitation or whether she did participate, but the
Government was unaware of the extent of her involvement. Call this the “yes-I’m-a-sex-
trafficker-but-only-on-Tuesdays-and-Thursdays” defense – here again, to simply recount the
claim is to see its absurdity.
51
See McCawley Dec. at Exhibit 1, 5, Alessi Dep. Tr. at 94:24-95:2; Giuffre Dep. Tr. at 111:12-111:21; 116:19-
117:12.
58
Contrary to Defendant’s misleading, cherry-picked fragments of information she has
chosen to use to support her point, there is an abundance of evidence clearly linking Defendant
to Epstein’s sexual exploitation of minors. As the Court is aware, numerous message pads were
recovered from Epstein’s home indicating Defendant’s involvement in and knowledge of
Epstein’s illegal exploitation. 52 Additionally, numerous employees and others have testified
about Defendant’s high-ranking position in the hierarchal structure of the sexual exploitation
scheme. 53 In fact, multiple individuals, in addition to the Ms. Giuffre, have testified about
Maxwell’s involvement in the exploitation of minors, including Ms. Giuffre.54
Defendant also argues that one government investigator, Palm Beach, Florida, Detective
Recarey, may not have been aware of her involvement in the sex trafficking. Defendant fails to
cite another passage in Detective Recarey’s deposition, where he noted that he was aware of
Defendant’s involvement with Epstein and the sexual exploitation of children.55 But even
assuming Recarey was unaware (which Ms. Giuffre strongly disputes), Defendant would have, at
most, a “yes-I’m-a-sex-trafficker-but-I-successfully-hid-it-from-one-of-the-cops” defense –
again, not a likely claim.
More broadly, Ms. Giuffre’s statement about what the “Government” knew about sex
trafficking was made in pleadings filed in a federal Court case attacking the decision of the U.S.
Attorney’s Office for the Southern District of Florida to offer Jeffrey Epstein immunity from
prosecution for federal sex trafficking crimes. Accordingly, to present an even arguable claim for
summary judgment, Defendant would have to show that the U.S. Attorney’s Office (and its
52
See, e.g., McCawley Dec at Exhibit 28 (message pad excerpts), GIUFFRE 001412, 001418, 001435, 001446,
001449, 001453, 001454.
53
See McCawley Dec. at Exhibit 21, 1, Rodriguez Dep. Tr. at 169:1-169:4; Alessi Dep. Tr. at 23:11-23:20; 34:19-
35:3; 98:5-98:12; 104:15-104:23.
54
See McCawley Dec. at Exhibit 16, 4, Sjoberg Dep. Tr. at 13; Figueroa Dep. Tr. at 96-97; 103; 200:6-18; 228:23-
229:21.
55
See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 29:16-29:20; 45:13-25; 83:3-83:15.
59
investigators from the FBI) did not know about Defendant’s sex trafficking. This proof would
need to include, for example, evidence that the FBI did not learn about Defendant’s sex
trafficking when (among other things) Ms. Giuffre told FBI agents about it when she met with
them in Australia in 2011. Here again, Defendant has no evidence to even begin making such a
showing.
C. Defendant’s January 2015 Statement Claiming as “Untrue” or an “Obvious

Lie” That Maxwell and Epstein Converted Ms. Giuffre Into a Sexual Slave is
Not Substantially True.
Defendant next argues that she accurately disputed Ms. Giuffre’s statement that
Defendant held her as a “sex slave.” Relying on dictionary definitions of “slave” that define the
term to refer to a “confined” person who is the “legal property” of another (MSJ at 59, citing
Merriam-Webster, etc.), Defendant claims Ms. Giuffre was not confined or the property of
Defendant. Call this the “yes-I’m-a-sex-trafficker-but-I-didn’t-use-chains” defense. And, once
again, to even describe the defense is to refute it.
Defendant does not explain why the jury would be required to use the held-in-chains
definition of “slave” in evaluating her statement. Merriam-Webster (11th ed. 2006) also defines
“slave” as “one that is completely subservient to a dominating influence” – a definition that fits
Ms. Giuffre’s circumstances to a tee. As Ms. Giuffre has explained in detail, she was recruited as
a minor child by Defendant, who then dominated her and used for sexual purposes. That
testimony alone creates a genuine issue of fact on this point.
From the context of all of Ms. Giuffre’s statements about Defendant, Ms. Giuffre has
never said or implied that she was physically placed in a cage. Instead, she has described the vast
disparity of power and the influence of Defendant and Epstein, the fear of disobedience, the
typical locations of the abuse being in a private plane, in huge mansion manned with Epstein
employed servants, a private island, or some inescapable place abroad in the presence of
60
Defendant, in addition to the continued – and fraudulent – promise of a better future, as those
things that kept her retained in a situation of sexual servitude. While not physical chained, Ms.
Giuffre was groomed as minor and trained, and these factors became her invisible chains.
Indeed, as Ms. Giuffre’s expert on sex trafficking, Professor Coonan, has explained:
Popular understandings of the term “sex slave” might still connote images of
violent pimps, white slavery, or of victims chained to a bed in a brothel in the
minds of some people. To call Ms. Giuffre a victim of sex trafficking would
however very accurately convey the reality that she along with a great many other
victims of contemporary forms of slavery are often exploited by the “invisible
chains” of fraud and psychological coercion.
See McCawley Dec. at Exhibit 23, Coonan Expert Report at 20.
If the Court takes as true, which it must for the purpose of this motion, that Ms. Giuffre
was trafficked and used exclusively for sexual purposes by Defendant and Epstein, then the
Court must also reach the conclusion at this stage that Maxwell’s assertion – that Ms. Giuffre’s
description of being a sex slave is “untrue” or “obvious lies” – is not substantially true. There
undoubtedly remains a genuine issue of material fact on this point, and in fact, Defendant’s
position taken in this motion is tantamount to an admission of the truth of Plaintiff’s statement
about Defendant on this point.
D. Any Statement of Misdirection Regarding Professor Alan Dershowitz is

Nothing More Than an Irrelevant Distraction to The Facts of This Case and
Matters Not on the Defense of Whether Defendant’s Statement Was
Substantially True.
Defendant next contends that she accurately recounted that Alan Dershowitz had denied
having sex with Ms. Giuffre. MSJ at 60. Call this the “yes-I’m-a-sex-trafficker-but-she-was-not-
trafficked-to-the-professor” defense. While it is accurate that Ms. Giuffre made allegations
against Professor Dershowitz, those allegations are not at issue in this case. Defendant, in her
defamatory statement, claimed that “the allegations made by [Ms. Giuffre] against Ghislaine
Maxwell are untrue.” See McCawley Dec. at Exhibit 26, GM_00068. In her deposition,
61
Defendant maintained the position that she “cannot speculate on what anybody else did or didn’t
do.” See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 180:3-180:4. In fact,
regarding Ms. Giuffre’s claims about others, Defendant unequivocally stated, “I can only testify
to what she said about me, which was 1000 percent false.” See McCawley Dec. at Exhibit 11,
Maxwell 4-22-2016 Dep. Tr. at 228:10-228:12.
Defendant Maxwell makes additional misstatements about Dershowitz’s production in a
defamation action filed against him in her desperate attempt to have Dershowitz to jump aboard
and help bail out her sinking canoe. While Ms. Giuffre can – and, if necessary, will – refute
Dershowitz’s claim he was not a beneficiary of Epstein and Defendant’s sex trafficking, that is
not relevant at this stage. Whatever may or may not have happened with Dershowitz (and Ms.
Giuffre’s sworn statements that he sexually abused her is alone enough to create disputed facts
on the issue of whether Defendant’s statements about him were “substantially true”) has no
bearing whatsoever on the truth or falsity of the statements Ms. Giuffre made about Defendant.
This case is not about whether Ms. Giuffre has ever made untruthful allegations against
anyone, which she contends she has not, but about whether her allegations about Defendant
were true, or whether those specific allegations were “untrue,” “obvious lies” as Defendant
publicly proclaimed. These issues are disputed and must go to the jury.
E. Contrary to Defendant’s Position, There is a Genuine Issue of Material Fact

as to Whether She Created or Distributed Child Pornography, or Whether
the Government Was Aware of Same.
Defendant next argues that she did not create child pornography and that the Government
knew this. Call this the “until-you-find-the-photos-I’m-innocent” defense. Of course, as noted
earlier, Defendant’s claim requires that she show that “the Government” – in context, the FBI
and the U.S. Attorney’s Office for the Southern District of Florida – “knew” that she had no
62
child pornography. Yet Defendant has offered no such evidence – much less evidence so
powerful as to warrant summary judgment on this point.
This point is disputed from the simple fact that Ms. Giuffre herself testified that
Defendant took many photograph of her naked. See McCawley Dec. at Exhibit 5, Giuffre Dep.
Tr. at 232:3-9; 233:7-9. This is consistent with the Palm Beach butler’s, Alfredo Rodriguez’s,
testimony that he personally saw photos of naked children on Defendant’s computer. See
McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 150:10-17; 306:1-306:24. Another
housekeeper, Juan Alessi also saw photos of young nude females on Defendant’s computer,
although he wasn’t sure whether to consider it pornography. See McCawley Dec. at Exhibit 1,
Alessi Dep. Tr. at 175:5-175:24. Finally, Detective Recarey found a collage of nude photos of
young females in Epstein’s closet, and turned the photos over to the FBI and U.S. Attorney’s
office.56 While the U.S. Attorney’s office will not share the photos obtained from Recarey’s
investigation, it is thus undisputed that the government possesses photos of nude, young females
confiscated from Epstein’s Palm Beach mansion. Indeed, the police video disclosed through a
FOIA request shows naked images of women throughout the house, including a full nude of the
Defendant.57 At a minimum, there is a clear genuine issue of material fact in this regard.
F. Defendant Did Act as a “Madame” For Epstein to Traffic Ms. Giuffre to The
Rich and Famous.
Defendant next argues that she did not act as a “Madame” for Epstein. MSJ at 63. The
gist of the argument seems to be that Defendant believes trafficking one girl to Epstein does not
a Madame make. Call this the “yes-I-was-Virginia’s-Madame-but-no-one-else’s” defense. This
argument fails linguistically on the very dictionary definitions that Defendant cites elsewhere –
56
See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 73:19-73:24; 74:2-74:7.
57
See McCawley Dec. at Exhibit 44, FOIA CD GIUFFRE 007584.
63
but not here. See Merriam-Webster (11th ed. 2006) (defining “madam” as “the female head of a
house of prostitution”).
Once again, Defendant conceals the relevant facts on this issue. First, multiple witnesses
have testified to Defendant’s recruiting, maintaining, harboring, and trafficking girls for
Epstein.58 In fact, Defendant herself was unable to deny procuring Ms. Giuffre for Epstein.59
While Defendant has attempted to fumble her way through explaining some plausible reason for
bringing a sixteen or seventeen year old to Epstein, her explanations are, to put it blandly,
unpersuasive. As with other issues, the jury will have to decide who to believe.
One of the individuals Ms. Giuffre was trafficked to was Prince Andrew – trafficking that
took place in Defendant’s own townhouse in London. There exist flight logs evidencing Ms.
Giuffre flying to London alongside Defendant and Epstein on Epstein’s private plane, and a
photo of Ms. Giuffre, Defendant, and the Prince, without Defendant ever offering a legal
reasonable explanation for that photo being taken, or for traveling with a year old girl overseas.
Defendant begins to meander somewhat aimlessly on this point, shifting Plaintiff’s
burden to substantiate Plaintiff’s claim that Defendant was Epstein’s Madame, which is a point
at issue, into whether or not Plaintiff has conclusively proven the identities and accurate job titles
of the other men to whom Plaintiff was lent for sex by Epstein. No matter how hard Defendant
tries to reframe this case, drag other people in, or split hairs, she is unable to contest the facts –
facts showing she was more than a Madame but a full-fledged sex trafficker. Ms. Giuffre told the
truth when she said that Defendant recruited her as a minor, under the pretense of giving a
58
See McCawley Dec. at Exhibit 16, 1, 18, 2, Sjoberg Dep. Tr. at 13; Alessi Dep. Tr. at 34; GIUFFRE000105 at 57-
58; GIUFFRE000241-242 at p. 212-213; Austrich Dep. Tr. at 34-35, 100-101, 127-128; Alessi Dep. Tr. at 34:19-
35:3; 98:5-98:12; 104:15-104:23.
59
See McCawley Dec. at Exhibit 11, Maxwell Dep. Tr. at 214:14-215:3.
64
massage, and converted her into a traveling sex slave, consistent with Defendant and Epstein’s
pattern and practice.
As the Court astutely acknowledged early on, “at the center of this case is the veracity of
a contextual world of facts more broad than the allegedly defamatory statements . . . either
transgression occurred or it did not. Either Maxwell was involved or she was not.” If Defendant
was involved, then her January 2015 statement was defamatory. Ms. Giuffre will prove to the
jury, through overwhelming evidence, her prior allegations about Defendant’s involvement. The
Court should give Ms. Giuffre that opportunity, and deny Defendant’s motion for summary
judgment.
IX. CONCLUSION
For the foregoing reasons, this Court should deny Defendant’s motion for summary
judgment in all respects.
Dated: January 31, 2017

(954) 356-0011
David Boies
333 Main Street
Armonk, NY 10504
65

(954) 524-2820

University of Utah
383 University St.
(801) 585-520260
I HEREBY CERTIFY that on January 31, 2017, I electronically filed the foregoing
document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.

Tel: (303) 831-7364
Fax: (303) 832-2628
/s/ Sigrid S. McCawley

Sigrid S. McCawley
60
This daytime business address is provided for identification and correspondence purposes only and is not intended
to imply institutional endorsement by the University of Utah for this private representation.
66

v.
Ghislaine Maxwell,
Defendant.
________________________________/
SOUTHERN DISTRICT OF NEW YORK LOCAL RULE 56.1 PLAINTIFF’S

STATEMENT OF CONTESTED FACTS AND PLAINTIFF’S UNDISPUTED FACTS
DEFENDANT’S PURPORTED FACTS
1. Ms. Maxwell’s response to publications of Ms. Giuffre’s false allegations: the March
2011 statement. In early 2011 Ms. Giuffre in two British tabloid interviews made
numerous false and defamatory allegations against Ms. Maxwell. In the articles, Ms.
Giuffre made no direct allegations that Ms. Maxwell was involved in any improper
conduct with Jeffrey Epstein, who had pleaded guilty in 2007 to procuring a minor for
prostitution. Nonetheless, Ms. Giuffre suggested that Ms. Maxwell worked with Epstein
and may have known about the crime for which he was convicted.
MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT’S FACTS
Ms. Giuffre denies that the allegations she made against Ms. Maxwell are false.
Furthermore, Ms. Giuffre did give an interview to journalist, Sharon Churcher, in which Ms.
Giuffre accurately and truthfully described Defendant Maxwell's role as someone who recruited
or facilitated the recruitment of young females for Jeffrey Epstein. See McCawley Dec. at
Exhibit 34, GIUFFRE003678. Ms. Giuffre was also interviewed by the FBI in 2011 and she
discussed Defendant’s involvement in the sexual abuse. See McCawley Dec. at Exhibit 31, FBI
Redacted 302, FIUFFRE001235-1246. Those statements were not "false and defamatory," but
instead truthful and accurate.
1
2. In the articles, Ms. Giuffre alleged she had sex with Prince Andrew, “a well-known
businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a
“foreign head of state.”
Ms. Giuffre does not contest this fact, but believes that it is irrelevant.
3. In response to the allegations Ms. Maxwell’s British attorney, working with Mr. Gow,
issued a statement on March 9, 2011, denying “the various allegations about [Ms.
Maxwell] that have appeared recently in the media. These allegations are all entirely
false.”
Ms. Giuffre denies that Mr. Barden, “issued a statement.” Instead it appears to have the
contact as Ross Gow and a reference to Devonshire Solicitors.
4. The statement read in full:

By Devonshires Solicitors, PRNE Wednesday, March 9, 2011
London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about her
that have appeared recently in the media. These allegations are all entirely false.
It is unacceptable that letters sent by Ms. Maxwell’s legal representatives to certain
newspapers pointing out the truth and asking for the allegations to be withdrawn have
simply been ignored.
In the circumstances, Ms. Maxwell is now proceeding to take legal action against those
newspapers.
However, the allegations made against me are abhorrent and entirely untrue and I ask
that they stop,” said Ghislaine Maxwell.
“A number of newspapers have shown a complete lack of accuracy in their reporting of
this story and a failure to carry out the most elementary investigation or any real due
diligence. I am now taking action to clear my name,” she said.
2
Media contact:
Ross Gow
Acuity Reputation
Tel: +44-203-008-7790
Mob: +44-7778-755-251
Media contact: Ross Gow, Acuity Reputation, Tel: +44-203-008-7790,
Mob: +44-7778-755-251, Email: ross at acuityreputation.com
The document speaks for itself although it is unclear if the original included the italics
that are inserted by the Defendant above.
5. Ms. Giuffre’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two
alleged victims of Epstein brought an action under the Crime Victims’ Rights Act against
the United States government purporting to challenge Epstein’s plea agreement. They
alleged the government violated their CVRA rights by entering into the agreement.
While we would stipulate to the statement in this paragraph starting with the words “In
2008” , we do not stipulate to the opening sentence fragment Maxwell places in bold.
6. Seven years later, on December 30, 2014, Ms. Giuffre moved to join the CVRA action,
claiming she, too, had her CVRA rights violated by the government. On January 1, 2015,
Ms. Giuffre filed a “corrected” joinder motion.
Agreed.
7. The issue presented in her joinder motion was narrow: whether she should be permitted
to join the CVRA action as a party under Federal Rule of Civil Procedure 21,
specifically, whether she was a “known victim[] of Mr. Epstein and the Government
owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious factual
details that [Ms. Giuffre] and [her co-movant] ‘would prove . . . if allowed to join.’” Ms.
3
Giuffre gratuitously included provocative and “lurid details” of her alleged sexual
activities as an alleged victim of sexual trafficking.
Ms. Giuffre denies that the issues presented in here joinder motion were narrow. The
issues presented by the joinder motion and related pleadings were multiple and complex,
requiring numerous details about Ms. Giuffre’s sexual abuse and the perpetrators of her abuse.
In a pleading explaining why the motion was filed, Ms. Giuffre’s lawyers sp ecifically listed nine
separate reasons why Jane Doe 3’s allegations that Dershowitz had sexually abused her were
relevant to the case and appropriately included in the relevant filings:
1. To establish that Jane Doe 3 had been sexually abused by Jeffrey Epstein
and his co-conspirators (including co-conspirator Alan Dershowitz), which would make
her a “victim” of a broad sex trafficking conspiracy covered by the federal Crime
Victims’ Rights Act, 18 U.S.C. § 3771, and therefore entitled to participate in the case;
2. To support then-pending discovery requests that asked specifically for

information related to contacts by Dershowitz with the Government on behalf of
Jeffrey Epstein;
3. To support the victims’ allegation that the Government had a motive for
failing to afford victims with their rights in the criminal process – specifically,
pressure from Dershowitz and other members of Epstein’s legal defense team to
keep the parameters of the non-prosecution agreement (NPA) secret to prevent
Jane Doe 3 and other victims from objecting to and blocking judicial approval of
the agreement;
4. To establish the breadth of the NPA’s provision extending immunity to

“any potential co-conspirators of Epstein” and the scope of the remedy that the
victims (including not only Jane Doe 3 but also other similarly-situated minor
victims who had been sexually abused by Dershowitz) might be able to obtain for
violations of their rights;
5. To provide part of the factual context for the scope of the “interface”
between the victims, the Government, and Epstein’s defense team – an interface
that was relevant under Judge Marra’s previous ruling that the Government was
entitled to raise “a fact-sensitive equitable defense which must be considered in
the factual context of the entire interface between Epstein, the relevant
prosecutorial authorities and the federal offense victims . . .”;
4
6. To prove the applicability of the “crime/fraud/misconduct” exception to

the attorney-client privilege that was being raised by the Government in
opposition to the victims’ motion for production of numerous documents;
7. To bolster the victims’ argument that their right “to be treated with
fairness,” 18 U.S.C. § 3771(a)(8), had been violated through the Government’s
secret negotiations with one of their abusers;
8. To provide notice and lay out the parameters of potential witness

testimony for any subsequent proceedings or trial – i.e., the scope of the testimony
that Jane Doe 3 was expected to provide in support of Jane Doe 1 and Jane Doe 2,
the already-recognized Ms. Giuffre in the action; and
9. To support Jane Doe 3’s argument for equitable estoppel to toll the six-
year statute of limitations being raised by the Government in opposition to her
motion to join – i.e., that the statute was tolled while she was in hiding in
Australia due to the danger posed by Epstein and his powerful friends, including
prominent lawyer Alan Dershowitz.
Jane Does #1 and #2 v. United States, No. 9:08-cv-80736, DE 291 at 18-26 & n.17 (S.D. Fla.
2015). Ms. Giuffre’s lawyers had attempted to obtain a stipulation from the Government on
point #1 above (“victim” status), but the Government had declined. Judge Marra’s ruling
concluded that certain allegations were not necessary “at this juncture in the proceedings.” DE
324 at 5. Judge Marra specifically added, however, that “Jane Doe 3 is free to reassert these
factual details through proper evidentiary proof, should Petitioners demonstrate a good faith
basis for believing that such details are pertinent to a matter presented for the Court’s
consideration.” DE 324 at 6. The CVRA litigation continues and no trial has been held as of the
filing of this brief. As such, the extent to which these factual details will be used at trial has not
yet been determined. See Docket Sheet, Jane Does #1 and #2 v. U.S., No. 9:08-cv-80736.
8. At the time they filed the motion, Ms. Giuffre and her lawyers knew that the media had
been following the Epstein criminal case and the CVRA action. While they deliberately
filed the motion without disclosing Ms. Giuffre’s name, claiming the need for privacy
and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they
filed the motion publicly.
5
See Ms. Giuffre’s Response to Point #7, above.

9. As the district court noted in ruling on the joinder motion, Ms. Giuffre “name[d] several
individuals, and she offers details about the type of sex acts performed and where they
took place.” The court ruled that “these lurid details are unnecessary”: “The factual
details regarding whom and where the Jane Does engaged in sexual activities are
immaterial and impertinent . . ., especially considering that these details involve non-
parties who are not related to the respondent Government.” Accordingly, “[t]hese
unnecessary details shall be stricken.” Id. The court then struck all Ms. Giuffre’s factual
allegations relating to her alleged sexual activities and her allegations of misconduct by
non-parties. The court said the striking of the “lurid details” was a sanction for Ms.
Giuffre’s improper inclusion of them in the motion.
10. The district court found not only that the “lurid details” were unnecessary but also that
the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and her lawyers knew
the motion with all its “lurid details” was unnecessary because the motion itself
recognized that she would be able to participate as a fact witness to achieve the same
result she sought as a party. The court denied Ms. Giuffre’s joinder motion.
11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms.
Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, Ms.
Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created
by Epstein:
 Ms. Maxwell “approached” Ms. Giuffre in 1999 when Ms. Giuffre was “fifteen
years old” to recruit her into the scheme.
 Ms. Maxwell was “one of the main women” Epstein used to “procure under-aged
girls for sexual activities.”
 Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme.
6
 She “persuaded” Ms. Giuffre to go to Epstein’s mansion “in a fashion very similar to
the manner in which Epstein and his other co-conspirators coerced dozens of other
children.”
 At the mansion, when Ms. Giuffre began giving Epstein a massage, he and Ms.
Maxwell “turned it into a sexual encounter.”
 Epstein “with the assistance of” Ms. Maxwell “converted [Ms. Giuffre] into . . . a
‘sex slave.’” Id. Ms. Giuffre was a “sex slave” from “about 1999 through 2002.”
 Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.”
 Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea
agreement, because the immunity protected her from prosecution “for the crimes she
committed in Florida.”
 Ms. Maxwell “participat[ed] in the sexual abuse of [Ms. Giuffre] and others.”
 Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in
sexual activities, including [Ms. Giuffre].” Id. She shared the photos with Epstein.
 As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]”
Epstein with “powerful individuals” so that Epstein could traffic Ms. Giuffre to these
persons.
 Ms. Giuffre was “forced to have sexual relations” with Prince Andrew in
 “[Ms. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” Ms. Giuffre’s
 sex with Prince Andrew “by acting as a ‘madame’ for Epstein.”
 Ms. Maxwell “assist[ed] in internationally trafficking” Ms. Giuffre and “numerous
 Ms. Giuffre was “forced” to watch Epstein, Ms. Maxwell and others “engage in
See Ms. Giuffre’s Response to Point #7, above. Ms. Giuffre contests the reference to
“lurid details”. Moreover, the testimony from numerous witnesses corroborates the statements
Ms. Giuffre made in her joinder motion. See below.
 See McCawley Dec. at Exhibit 16, Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35,
142-143
 See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and
103
 See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60
 See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115
 See McCawley Dec. at Exhibit 13, Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30
7
 See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36
 Exhibit 2 Excerpted Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464-1470,
1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589
 See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15; etc.
 See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16; etc. Epstein
Dep. Tr. at 116:10-15; 117:18-118:10; etc.
 See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28, 52-54
 See McCawley Dec. at Exhibit 30, U.S. Attorney Victim Notification Letter
GIUFFRE002216-002218
 See McCawley Dec. at Exhibit 33, July 2001 New York Presbyterian Hospital Records
GIUFFRE003258-003290
 J See McCawley Dec. at Exhibit 38, Judith Lightfoot psychological records
GIUFFRE005431-005438
 See McCawley Dec. at Exhibit 28, Message Pad evidencing Defendant arranging to have
underage girls and young women come to Epstein’s home GIUFFRE001386-001571
 See McCawley Dec. at Exhibit 29, Black Book in which Defendant and other household
staff maintained a roster of underage girls including
, who were minors at the time the Palm Beach Police’s Investigation of
Jeffrey Epstein GIUFFRE001573-00669
 See McCawley Dec. at Exhibit 40, Sex Slave books Epstein ordered from Amazon.com at
GIUFFRE006581
 See McCawley Dec. at Exhibit 32, the folder Defendant sent to Thailand with Ms.
Giuffre bearing Defendant’s phone number GIUFFRE003191-003192
8
 See McCawley Dec. at Exhibit 39, the Palm Beach Police Report showing that Epstein
used women and girls to collect underage girls for his abuse GIUFFRE005614-005700
 See McCawley Dec. at Exhibit 41, Epstein’s Flight Logs showing that Defendant flew
with Ms. Giuffre 23 times GIUFFRE007055-007161
12. In the joinder motion, Ms. Giuffre also alleged she was “forced” to have sex with
Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and “many
other powerful men, including numerous prominent American politicians, powerful
business executives, foreign presidents, a well-known Prime Minister, and other world
leaders.”
See Response to Point #7 and 11, above.
13. Ms. Giuffre said after serving for four years as a “sex slave,” she “managed to escape to a
foreign country and hide out from Epstein and his co-conspirators for years.”
Agreed that Ms. Giuffre made this statement and has since discovered evidence that
indicates she was mistaken on the exact timeframe of her abuse and was with Defendant and
Jeffrey Epstein from the years 2000 – 2002.
14. Ms. Giuffre suggested the government was part of Epstein’s “conspiracy” when it
“secretly” negotiated a non-prosecution agreement with Epstein precluding federal
prosecution of Epstein and his “co-conspirators.” The government’s secrecy, Ms. Giuffre
alleged, was motivated by its fear that Ms. Giuffre would raise “powerful objections” to
the agreement that would have “shed tremendous public light on Epstein and other
powerful individuals.
Ms. Giuffre did not suggest that the Government was part of Epstein's conspiracy to
commit sex offenses. The CVRA case deals with whether the Government failed in their
responsibilities to the victims to inform the victims that the Government was working out a NPA,
9
and it is Ms. Giuffre's belief that the Government did fail to so inform the victims, and
intentionally did not inform the victims because the expected serious objection from many of the
victims might prevent the Government from finalizing a NPA with Epstein. See McCawley Dec.
at Exhibit 50, Joinder Motion (GIUFFRE00319-00333).
15. Notably, the other “Jane Doe” who joined Ms. Giuffre’s motion who alleged she was
sexually abused “many occasions” by Epstein was unable to corroborate any of Ms.
Giuffre’s allegations.
This is untrue. The other Jane Doe could corroborate many of Ms. Giuffre's allegations
based on a similar pattern of abuse that she suffered by Epstein. She did not know Ms. Giuffre
though. , who was deposed in this case, and who was a minor, corroborates the
same pattern of abuse. See McCawley Dec. at Exhibit 7, Dep. Tr. at 54:25-57:5.
16. Also notably, in her multiple and lengthy consensual interviews with Ms. Churcher three
years earlier, Ms. Giuffre told Ms. Churcher of virtually none of the details she described
in the joinder motion.
This is untrue. Furthermore, Defendant does not offer any citation or evidence on this
point. Defendant's statement here is knowingly false. Having read the articles and taken Ms.
Giuffre's deposition, Defendant knows that Ms. Giuffre did reveal details in 2011 consistent with
those in the joinder motion. See McCawley Dec. at Exhibit 31, GIUFFRE003678, FBI Redacted
302, GIUFFRE001235-1246.
17. Ms. Maxwell’s response to Ms. Giuffre’s “lurid” accusations: the January 2015
statement. As Ms. Giuffre and her lawyers expected, before District Judge Marra in the
10
CVRA action could strike the “lurid details” of Ms. Giuffre’s allegations in the joinder
motion, members of the media obtained copies of the motion.
18. At Mr. Barden’s direction, on January 3, 2015, Mr. Gow sent to numerous representatives
of British media organizations an email containing “a quotable statement on behalf of
Ms. Maxwell.” The email was sent to more than 6 and probably less than 30 media
representatives. It was not sent to non-media representatives.
Defendant falsely claims that “[a]t Mr. Barden’s direction, on January 3, 2015, Mr. Gow
sent to numerous representatives of British media organizations an email containing ‘a quotable
statement on behalf of Ms. Maxwell.’” This is a blatant falsehood about the document that is at
the heart of this litigation. Record evidence shows that Gow sent that email at Defendant’s
direction, not at Mr. Barden’s direction. Indeed, on the evening before his deposition, Mr. Gow
produced an email exchange he had with Defendant in which Defendant directs Mr. Gow to send
the press statement. It is as follows:
11
Chronologically, this email comes at the end of various other email exchanges between
Defendant and Gow that discuss issuing a press release. The subject line of this email that
Defendant wrote to Gow states “URGENT – this is the statement,” thereby instructing Gow to
release this statement to the press. Shortly after Defendant sent this email to Gow directing him
to release the statement, Gow distributed the statement to multiple media outlets. Neither
Defendant nor Gow have produced any email in which Barden directed Gow to issue this press
release (nor can they).
Despite sending it herself, and despite it being responsive to six court-ordered search
terms, Defendant failed to produce this email. Her press agent, Gow, produced this the evening
before his deposition on November 17, 2016. At the deposition, Mr. Gow authenticated this
email and confirmed that Defendant authorized the statement:
Q. When you sent that email were you acting pursuant to Ms. Maxwell's retention of your
services?
A. Yes, I was.
***
(Exhibit 9 was marked for identification.)
Q. This also appears to be an email chain with you and Ms. Maxwell; is that correct?
A. It does appear to be so.
Q. Did you send the top email of the chain that says "Okay, G, going with this"?
A. I did.
Q. And did you receive from Ms. Maxwell, the bottom email of that chain?
A. I believe so. Well, I believe -- yes, yeah, it was forwarded from Ms. Maxwell, yes.
MR. DYER: Sorry, I don't quite understand that answer.
THE WITNESS: I misspoke that. I did receive it from Ms. Maxwell.
MR. DYER: Okay.
necessarily accessible at some point in time, so this had been sent to him originally by
Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate
action. I therefore respond, “Okay, Ghislaine, I’ll go with this.”
It is my understanding that this is the agreed statement because the subject of the
second one is “Urgent, this is the statement” so I take that as an instruction to send it out,
as a positive command: “This is the statement.”
12
See McCawley Decl. at Exhibit 6, November 18, 2016, Ross Gow Dep. Tr. at 14:15-17; 44:6-
45:13.
Together, the email and Gow’s testimony unequivocally establish that Defendant – not
Barden – directed and “command[ed]” Gow to publish the defamatory statement. Accordingly,
the first sentence of Defendant’s Paragraph 18 is false.
The second sentence – “This email was sent to more than 6 and probably less than 30
media representatives” – omits the fact that not only did Gow admit to emailing the statement to
the press, but he also read it to over 30 media representatives over the phone:
Q. Do you recall ever reading the statement to the press or the media over the phone?
A. It's very possible that I would have done so, yes.
See McCawley Decl. at Exhibit 6, Gow Dep. Tr. at 66:2-25.
Q. Do you -- do you remember discussing that with The Guardian?

A. No, I don't. I'm not saying I didn't but I can't recall. You have to bear in mind, if you'd
be so kind, that I've been speaking to over 30 journalists and media outlets about this,
and I can't recall every single -- the detail of every single conversation.
See McCawley Decl. at Exhibit 6, Gow Dep. Tr. at 64:8-14 (emphasis added). Thus, the second
sentence of Defendant’s Paragraph 18 is also false.
19. Among the media representatives were Martin Robinson of the Daily Mail; P. Peachey of
The Independent; Nick Sommerlad of The Mirror; David Brown of The Times; and Nick
Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press Association.
These representatives were selected based on their request—after the joinder motion was
filed—for a response from Ms. Maxwell to Ms. Giuffre’s allegations in the motion.
Ms. Giuffre agrees to the first sentence. The second sentence is a false. Accordingly,
there is no record evidence that Gow (or anyone else) “selected” journalists “for a response,” or
that there was any selection process whatsoever. To the contrary, Gow testified that anyone who
inquired received a reference to the January 2015 defamatory response:
13
Q. To the extent you can recall or could estimate, how many other emails do you believe
you sent bearing that statement that's in Exhibit 2?
A. I really can't remember but certainly more than six and probably less than 30,
somewhere in between. Any time there was an incoming query it was either dealt with on
the telephone by referring them back to the two statements of March 2011 and January
2015 or someone would email them the statement. So no one was left unanswered,
broadly, is the -- is where we were. But I can't remember every single person we reached
out to.
See McCawley Dec at Exhibit 6 Gow Dep. Tr. at 67:15-68:1 (emphasis added).
20. The email to the media members read:

Please find attached a quotable statement on behalf of Ms. Maxwell.
Best Ross
Ross Gow
ACUITY Reputation
Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations are not
new and have been fully responded to and shown to be untrue.
Each time the story is re told [sic] it changes with new salacious details about public
figures and world leaders and now it is alleged by Ms. Roberts [sic] that Alan
Derschowitz [sic] is involved in having sexual relations with her, which he denies.
Ms. Roberts claims are obvious lies and should be treated as such and not publicized as
news, as they are defamatory.
Ghislaine Maxwell’s original response to the lies and defamatory claims remains the
same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared
in the British press and elsewhere and reserves her right to seek redress at the repetition
of such old defamatory claims.
14
While Defendant cropped the body text of the email that was sent to news media
representatives, she completely omitted the headings and metadata. Ms. Giuffre has put an image
of the email below in Ms. Giuffre’s Paragraph. See GM_00068.
15
21. Mr. Barden, who prepared the January 2015 statement, did not intend it as a traditional
press release solely to disseminate information to the media. So he intentionally did not
pass it through a public relations firm, such as Mr. Gow’s firm, Acuity Reputation.
Defendant states: “Mr. Barden, who prepared the statement, did not intend it as a
traditional press release solely to dissemination information to the media.” Ms. Giuffre contests
this statement, and all statements regarding Mr. Barden’s beliefs and purposes, and the like.
Further, as stated in detail in Ms. Giuffre’s Opposition Defendant’s Motion for Summary
Judgment, this Court should not even consider the Barden Declaration. Additionally, there is
absolutely no record evidence of Barden’s intent and the Court should not consider it.
The next sentence states, “So he intentionally did not pass it [the press release] through a
public relations firm, such as Mr. Gow’s firm, Acuity Reputation.” Again, there is zero record
evidence to support any assertion of Barden’s intent. To the extent that this sentence claims that
Barden did not give the statement to Gow, Ms. Giuffre does not dispute it; as described above,
Defendant gave the statement to Gow with instructions to publish it. See McCawley Dec. at
Exhibit 48, RG(UK)_000009, imaged in full at paragraph 81, supra. To the extent that this
sentence claims that the statement did not pass “through a public relations firm, such as Mr.
Gow’s firm, Acuity Reputation,” Ms. Giuffre disputes that statement. Record documentary
evidence and testimony establish that this statement was disseminated through a public relations
firm, namely, Ross Gow’s firm, Acuity Reputation. See McCawley Dec. at Exhibit 6, Gow Dep.
Tr. at 109:4-6 (“Q. Approximately how long have you been providing such services? A. Acuity
was set up in 2010.”).
16
22. The January 2015 statement served two purposes. First, Mr. Barden intended that it
mitigate the harm to Ms. Maxwell’s reputation from the press’s republication of Ms.
Giuffre’s false allegations. He believed these ends could be accomplished by suggesting
to the media that, among other things, they should subject Ms. Giuffre’s allegations to
inquiry and scrutiny. For example, he noted in the statement that Ms. Giuffre’s
allegations changed dramatically over time, suggesting that they are “obvious lies” and
therefore should not be “publicized as news.”
Ms. Giuffre objects to this paragraph in its entirety. She disputes that the January 2015
statement “served two purposes,” as this statement is wholly unsupported by the record, which
Defendant again neglects to cite. Ms. Giuffre also contests the second sentence in which
Defendant claims that “Mr. Barden intended that it mitigate the harm to Ms. Maxwell’s
reputation from the press’s republication of Ms. Giuffre’s false allegations.” First, Ms. Giuffre
disputes any statement of Barden’s intent as explained above. Second, Ms. Giuffre disputes that
there was any “republication” by the press as a matter of law, as explained in her memorandum
of law opposing summary judgment, as the press did not “republish” the press statement under
New York law. Third, Ms. Giuffre disputes that her allegations are “false,” and cites to the
following non-exhaustive sampling of evidence to corroborate her allegations against Defendant:
 See McCawley Dec. at Exhibit 16, Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35,
142-143
 See McCawley Dec. at Exhibit 4, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and
103
 See McCawley Dec. at Exhibit 14, Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60
 See McCawley Dec. at Exhibit 12, Lynn Miller’s May 24, 2016 Dep. Tr. at 115
 See McCawley Dec. at Exhibit 13, Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30
 See McCawley Dec. at Exhibit 15, David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34-36
17
 Exhibit 2 Excerpted Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464-1470,
1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589
 See McCawley Dec. at Exhibit 10, Marcinkova Dep. Tr. at 10:18-21; 12:11-15; etc.
 See McCawley Dec. at Exhibit 8, Kellen Dep. Tr. at 15:13-18; 20:12-16; etc. Epstein
Dep. Tr. at 116:10-15; 117:18-118:10; etc.
 See McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 28, 52-54
 See McCawley Dec. at Exhibit 42, Photographs including GIUFFRE007162-007182.
 See McCawley Dec. at Exhibit 30, U.S. Attorney Victim Notification Letter
GIUFFRE002216-002218
 See McCawley Dec. at Exhibit 33, July 2001 New York Presbyterian Hospital Records
GIUFFRE003258-003290
 See McCawley Dec. at Exhibit 38, Judith Lightfoot psychological records
GIUFFRE005431-005438
 See McCawley Dec. at Exhibit 28, Message Pad evidencing Defendant arranging to have
underage girls and young women come to Epstein’s home GIUFFRE001386-001571
 See McCawley Dec. at Exhibit 29, Black Book in which Defendant and other household
staff maintained a roster of underage girls including
, who were minors at the time the Palm Beach Police’s Investigation of
Jeffrey Epstein GIUFFRE001573-00669
 See McCawley Dec. at Exhibit 40, Sex Slave books Epstein ordered from Amazon.com at
GIUFFRE006581
 See McCawley Dec. at Exhibit 32, the folder Defendant sent to Thailand with Ms.
Giuffre bearing Defendant’s phone number GIUFFRE003191-003192
18
 See McCawley Dec. at Exhibit 39, the Palm Beach Police Report showing that Epstein
used women and girls to collect underage girls for his abuse GIUFFRE005614-005700
 See McCawley Dec. at Exhibit 41, Epstein’s Flight Logs showing that Defendant flew
with Ms. Giuffre 23 times GIUFFRE007055-007161
Next, Defendant states, “He [Barden] believed these ends could be accomplished by
suggesting to the media that, among other things, they should subject Ms. Giuffre’s allegations to
inquiry and scrutiny.” Ms. Giuffre disputes any statement as to Barden’s “belief” (supra). Ms.
Giuffre disputes that the harm to Defendant’s reputation could be mitigated by the media’s
inquiry into and scrutiny of Ms. Giuffre’s allegations, because a deeper inquiry would only
reveal additional evidence corroborating Ms. Giuffre’s allegations, such as the evidence put forth
in Ms. Giuffre’s opposition memorandum of law and detailed in the bulleted citations, supra.
Defendant then states, “For example, he [Barden] noted in the statement that Ms.
Giuffre’s allegations changed dramatically over time, suggesting that they are ‘obvious lies’ and
therefore should not be ‘publicized as news.’” First, Ms. Giuffre disputes that Barden noted
anything in the statement, as that is unsubstantiated by the record evidence. Not to do
Defendant’s work for her, but the closest evidence Defendant has for such a statement is
testimony from the Gow deposition wherein Gow speculates that Barden “had a hand in”
drafting the press statement, an opinion which may or may not be based on first-hand
knowledge. See McCawley Dec. at Exhibit 6, Gow Dep. Tr. at 45:14-17 (Q. Okay. A. And I say,
“Thanks, Philip” because I’m aware of the fact that he had a hand, a considerable hand in the
drafting.”) This is wholly insufficient to show who drafted the passages quoted by Defendant
above. Regardless of those passages’ original author, it is ultimately Defendant who “noted”
anything because it is her statement and she directed that it be sent to the media and public.
19
Second, Ms. Giuffre disputes that her allegations have changed over time, “dramatically”
or otherwise. Third, Ms. Giuffre disputes that the press release “suggest[ed]” that her allegations
are “obvious lies,” because Defendant’s press release affirmatively, unambiguously stated that
her allegations are “obvious lies” – there is no subtlety, suggestion, or statement of opinion here.
See Giuffre v. Maxwell, 165 F. Supp.3d 147, 152 (S.D.N.Y. 2016) (“. . . these statements (as they
themselves allege), are capable of being proven true or false, and therefore constitute actionable
fact and not opinion.”
23. Second, Mr. Barden intended the January 2015 statement to be “a shot across the bow” of
the media, which he believed had been unduly eager to publish Ms. Giuffre’s allegations
without conducting any inquiry of their own. Accordingly, in the statement he repeatedly
noted that Ms. Giuffre’s allegations were “defamatory.” In this sense, the statement was
intended as a cease and desist letter to the media-recipients, letting the media-recipients
understand the seriousness with which Ms. Maxwell considered the publication of Ms.
Giuffre’s obviously false allegations and the legal indefensibility of their own conduct.
This paragraph is another purported statement of Defendant’s counsel’s “intent.”
Defendant states: “Second, Mr. Barden intended the January 2015 statement to be a ‘shot across
the bow’ of the media, which he believed had been unduly eager to publish Ms. Giuffre’s’
allegations without conducting any inquiry of their own.” Not only does Defendant once again
refer to Mr. Barden’s intent, but she also mischaracterizes the statement as a “shot across the
bow” of the media. The press release did not threaten or give warning to the media in any way
whatsoever. See McCawley Dec. at Exhibit 26, GM_00068, full image copied in Ms. Giuffre’s
Paragraph 18, supra.
Next, Ms. Giuffre disputes the sentence, “Accordingly, in the statement he repeatedly
noted that Ms. Giuffre’s allegations were ‘defamatory.’” Barden did not “note” anything in the
statement, nor does Defendant cite to any record evidence that he does. Furthermore, Ms. Giuffre
20
denies that any of her allegations are defamatory in the slightest, as they are all true and
substantiated by record evidence (supra).
Ms. Giuffre also disputes the sentence, “In this sense, the statement was intended as a
cease and desist letter to the media-recipients, letting the media-recipients understand the
seriousness with which Ms. Maxwell considered the publication of Ms. Giuffre’s obviously false
allegations and the legal indefensibility of their own conduct.” First, Ms. Giuffre objects to any
statement of Barden’s intent, as articulated above. Second, Defendant’s conventional press
release was in no way any type of “cease and desist letter.” There is no record evidence in
support of this claim, and Defendant unsurprisingly cites to none. Third, Ms. Giuffre disputes
that any media-recipients would be given to understand “the seriousness with which Ms.
Maxwell considered the publication of Ms. Giuffre’s obviously false allegations and the legal
indefensibility of their own conduct” by Defendant’s self-serving press release, as that is
unsupported by the record. Finally, Ms. Giuffre rejects that her allegations are "obviously false,”
a claim which is completely unsupported by record evidence.
24. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with the
following language: “Please find attached a quotable statement on behalf of Ms.
Maxwell” (emphasis supplied). The statement was intended to be a single, one-time-
only, comprehensive response—quoted in full—to Ms. Giuffre’s December 30, 2014,
allegations that would give the media Ms. Maxwell’s response. The purpose of the
prefatory statement was to inform the media-recipients of this intent.
21
Ms. Giuffre disputes that any part of Defendant’s press release is “consistent with those
two [of Barden’s] purposes.” Indeed, Ms. Giuffre disputes this and any statement relating to
Barden’s “purposes,” as explained above.
Next, Ms. Giuffre disputes that, “The statement was intended to be a single, one-time-
only, comprehensive response – quoted in full – to Ms. Giuffre’s December 30, 2014, allegations
that would give the media Ms. Maxwell’s response.” First, Ms. Giuffre disputes this and any
statement relating to Barden’s “intent” as explained above. Second, Ms. Giuffre disputes that
anyone intended the press release to be a one-time-only, comprehensive response. The record
evidence says otherwise: Gow repeatedly issued this statement via email and over the phone for
months on end.
Next, Defendant states, “The purpose of the prefatory statement was to inform the media-
recipients of this intent.” First, Ms. Giuffre disputes this and any statement relating to Barden’s
purpose as explained above. Second, Ms. Giuffre disputes that the press release was to inform
the media of anything. Defendant issued a press release, instructed them to publish it (by telling
them it was “quotable”), see McCawley Dec. at Exhibit 48, RG(UK)_000009 (supra), and hired
a press agent to feed it to the press:
Q. Did Ms. Maxwell retain the services of you or your firm?

A. Yes, she did.
***
Q. Is it your belief that that agreement was in effect on January 2nd, 2015?
A. Yes.
Q. Do you recall the terms of that agreement?
A. Well, it was a re-establishment of an existing agreement so if we go back to the
original agreement, it was to provide public relations services to Ms. Maxwell in the
matter of Giuffre and her activities.
22
See McCawley Dec. at Exhibit 6 Gow Dep. Tr. at 12:19-21; 13:9-16. The record evidence shows
that Defendant’s intent was for the press to publish her press release: any other interpretation is
not only contrary to logic, but unsupported by the record.
25. Ms. Giuffre’s activities to bring light to the rights of victims of sexual abuse. Ms.
Giuffre has engaged in numerous activities to bring attention to herself, to the prosecution
and punishment of wealthy individuals such as Epstein, and to her claimed interest of
bringing light to the rights of victims of sexual abuse.
Agreed to the portion of Defendant’s assertion in bold font. Ms. Giuffre has not engaged
in activities to bring attention to herself, rather she has taken action to aid in the prosecution of
her abusers, and she seeks to bring light to the rights of victims of sexual abuse.
26. Ms. Giuffre created an organization, Victims Refuse Silence, Inc., a Florida corporation,
directly related to her alleged experience as a victim of sexual abuse.
Ms. Giuffre created Victims Refuse Silence, Inc., in order to help other sexually
trafficked victims find the resources they need to recover and heal. See
www.victimsrefusesilence.org.
27. The “goal” of Victims Refuse Silence “was, and continues to be, to help survivors
surmount the shame, silence, and intimidation typically experienced by victims of sexual
abuse.” Toward this end, Ms. Giuffre has “dedicated her professional life to helping
victims of sex trafficking.”
Agreed.
23
28. Ms. Giuffre repeatedly has sought out media organizations to discuss her alleged
experience as a victim of sexual abuse.
Denied. Ms. Giuffre was approached by numerous media outlets and refused to speak to
most of them. Media organizations sought her out; she did not seek them out. See McCawley
Dec. at Exhibit 35, GIUFFRE003690, email from Sharon Churcher seeking to interview Ms.
Giuffre.
29. On December 30, 2014, Ms. Giuffre publicly filed an “entirely unnecessary” joinder
motion laden with “unnecessary,” “lurid details” about being “sexually abused” as a
“minor victim[]” by wealthy and famous men and being “trafficked” all around the world
as a “sex slave.”
See Ms. Giuffre’s Paragraph 7, supra, listing multiple reasons why details were, in fact,
necessary.
30. The Ms. Giuffre’s alleged purpose in filing the joinder motion was to “vindicate” her
rights under the CVRA, expose the government’s “secretly negotiated” “non-prosecution
agreement” with Epstein, “shed tremendous public light” on Epstein and “other powerful
individuals” that would undermine the agreement, and support the CVRA Ms. Giuffre’s’
request for documents that would show how Epstein “used his powerful political and
social connections to secure a favorable plea deal” and the government’s “motive” to aid
Epstein and his “co-conspirators.”
See Ms. Giuffre’s Paragraph 7, supra, listing multiple purposes of Ms. Giuffre’s lawyers’
filing of the motion.
24
31. Ms. Giuffre has written the manuscript of a book she has been trying to publish detailing
her alleged experience as a victim of sexual abuse and of sex trafficking in Epstein’s
alleged “sex scheme.”
See Ms. Giuffre’s Paragraph 52, infra, explaining that the context of this statement is
misleading.
32. Republication alleged by Ms. Giuffre. Ms. Giuffre was required by Interrogatory No. 6
to identify any false statements attributed to Ms. Maxwell that were “‘published globally,
including within the Southern District of New York,’” as Ms. Giuffre alleged in
Paragraph 9 of Count I of her complaint. In response, Ms. Giuffre identified the January
2015 statement and nine instances in which various news media published portions of the
January 2015 statement in news articles or broadcast stories.
Ms. Giuffre objects to this paragraph in its entirety, starting with the bolded heading
(“Republication alleged by Ms. Giuffre”). There is no “republication” as a matter of law in this
case, as explained in Ms. Giuffre’s memorandum of law. Accordingly, Ms. Giuffre is not and has
not alleged republication. As noted in her objection that, it is Defendant who possesses the
knowledge as to where the defamatory statements were published; unsurprisingly, Defendant
failed to comply with Ms. Giuffre’s discovery requests on the same.
As Defendant already knows, Ms. Giuffre provided a sampling of Defendant’s
defamatory statements published by the news media, as “identification of an exhaustive
responsive list would be unduly burdensome.” This, of course, is because Defendant caused her
statement to be published in an enormous number of media outlets. Ms. Giuffre’s full response to
Interrogatory No. 6 is below. As the Court can see, these nine instances were a good-faith effort
to provide some samples (as it would be virtually impossible to provide all of them), below. Ms.
25
Giuffre has also put forth an exhaustive expert report and expert testimony from Jim Jansen
regarding the dissemination of Defendant’s defamatory press release.
Ms. Giuffre objects because the information interrogatory above is in the

possession of Defendant who has failed to comply with her production obligations
in this matter, and has failed to comply with her production obligations with this
very subject matter. See Document Request No. 17 from Ms. Giuffre’s Second
Request for Production of Documents to Defendant Ghislaine Maxwell. Maxwell
has not produced all “URL or Internet addresses for any internet version of such
publication” that she directed her agent, Ross Gow, to send.
Ms. Giuffre further objects because the information requested above is in

the possession of Defendant’s agent, who caused the false statements to be issued
to various media outlets. Ms. Giuffre has not had the opportunity to depose
Maxwell’s agent Ross Gow; therefore, this answer remains incomplete.
Consequently, Ms. Giuffre reserves the right to modify and/or supplement

her responses, as information is largely in the possession of the Defendant and her
agent. Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its
subparts, in combination with the other interrogatories, exceed the allowable
twenty-five interrogatories. Ms. Giuffre objects to this request because it is in the
public domain. Ms. Giuffre also objects in that it seeks information protected by
the attorney-client/work product privilege, and any other applicable privilege
stated in the General Objections.
Notwithstanding such objections, Ms. Giuffre has already produced

documents supplements such responsive documents with the following list of
publications. While the identification of an exhaustive responsive list would be
unduly burdensome, in an effort to make a good faith effort towards compliance,
Ms. Giuffre provides the following examples, which are incomplete based on the
aforementioned reasons:
26
27

33. In none of the nine instances was there any publication of the entire January 2015
statement.
While there may be certain publications who did not print every word of Defendant’s
lengthy press release, most publications quoted the most salient, to-the-point parts of
Defendant’s statement that call Ms. Giuffre a liar. In each of the nine articles listed above, the
defamatory statement, as articulated by the Complaint and as identified by the Court as
actionable, is published. See Giuffre v. Maxwell, 165 F. Supp.3d 147, 152 (S.D.N.Y. 2016)
(“statements that Giuffre’s claims ‘against [Defendant] are untrue,’ have been ‘shown to be
untrue,’ and are ‘obvious lies’ have a specific and readily understood factual meaning: that
Giuffre is not telling the truth about her history of sexual abuse and Defendant’s role, and that
some verifiable investigation has occurred and come to a definitive conclusion proving that fact.
Second, these statements (as they themselves allege), are capable of being proven true or false,
and therefore constitute actionable fact and not opinion”). Ms. Giuffre also put forth extensive
evidence of the mass distribution of Defendant’s defamatory statement to over 66 million
viewers through her expert witness Jim Jansen. See McCawley Dec. at Exhibit 24, Expert Report
of Jim Jansen.
34. Ms. Maxwell and her agents exercised no control or authority over any media
organization, including the media identified in Ms. Giuffre’s response to Interrogatory
No. 6, in connection with the media’s publication of portions of the January 2015
statement.
Ms. Giuffre disputes this statement in its entirety, as it is completely devoid of record
evidence. In fact, the record establishes the contrary. First, Defendant hired Gow because his
28
position allowed him to influence the press to publish her defamatory statement. A sampling of
Gow’s testimony establishes just that:
Q. Did Ms. Maxwell retain the services of you or your firm?

A. Yes, she did.
***
Q. Is it your belief that that agreement was in effect on January 2nd, 2015?
A. Yes.
Q. Do you recall the terms of that agreement?
A. Well, it was a re-establishment of an existing agreement so if we go back to the
original agreement, it was to provide public relations services to Ms. Maxwell in
the matter of Giuffre and her activities.
***
Q. You can answer -- to the extent that anything you testify to is not protected by a
privilege.
A. Ms. Roberts first came to my attention on or around March 2011 when I was
called into a meeting with Philip Barden and Ms. Maxwell at Devonshires law office,
that she had made -- Ms. Giuffre had made extremely unpleasant allegations about
Ms. Maxwell's private life. We were -- Acuity Reputation, my firm was called in to
protect Ms. Maxwell's reputation, and to set the record straight. That was -- and
that work commenced on or around March of 2011.
***
Q. Does this document fairly depict pages from your -- from Acuity Reputation's
website?
A. It does.
Q. Do you see where it says "We manage reputation and forge opinion through
public relations, strategic communications and high level networking"?
A. I do.
Q. Is that a true statement?
A. Say it again. Sorry.
Q. Is that a true statement?
A. It is, yes. I wrote that statement.
***
Q. · · Okay.· Do you see where your website claims that your company has "excellent
relationships with the media"?
A.· · I do.
Q.· · Is that a true statement?
29
A.· · That is true, yeah.

***
Q.· · Is it correct that you advertise your “excellent relationships with the media"
because your services often include giving communications to the media on
behalf of your clients?
A.· · Yes.
See McCawley Dec. at Exhibit 6 Gow Dep. Tr. at 13:9-16; 15:18-16:3; 109:12-22; 110:16-21;
111:3-7. In addition to testimonial evidence, the proof is also in the result. By using Gow to issue
her press release, Defendant caused her statement to be published by numerous major news
organizations with wide readership all over the globe. Accordingly, the record evidence shows
that Ms. Maxwell, through her agent, had immense control and authority over the media,
convincing major news outlets to publish her words based on nothing more than a single email
from Gow.
35. Ms. Giuffre’s defamation action against Ms. Maxwell. Eight years after Epstein’s guilty
plea, Ms. Giuffre brought this action, repeating many of the allegations she made in her
CVRA joinder motion.
Agreed, but noting that the defamation cause of action against Defendant did not accrue
until Defendant defamed her in January of 2015, the same year Ms. Giuffre filed suit against
Defendant for defamation.
36. The complaint alleged that the January 2015 statement “contained the following
deliberate falsehoods”:
30
Agreed. However, in discovery, Defendant was finally forced to produce the complete
press release she issued. See McCawley Dec. at Exhibit 26, GIUFFRE00068.
37. Ms. Giuffre lived independently from her parents with her fiancé long before meeting Epstein
or Ms. Maxwell. After leaving the Growing Together drug rehabilitation facility in 1999,
Ms. Giuffre moved in with the family of a fellow patient. There she met, and became
engaged to, her friend’s brother, James Michael Austrich. She and Austrich thereafter rented
an apartment in the Ft. Lauderdale area with another friend and both worked at various jobs
in that area. Later, they stayed briefly with Ms. Giuffre’s parents in the Palm Beach/
Loxahatchee, Florida area before Austrich rented an apartment for the couple on Bent Oak
Drive in Royal Palm Beach. Although Ms. Giuffre agreed to marry Austrich, she never had
any intention of doing so.
Ms. Giuffre did not voluntarily live independently from her parents with her fiancé, rather
Ms. Giuffre was a troubled minor child who was not truly engaged prior to meeting Defendant and
Epstein. Where Ms. Giuffre lived, and who she lived with, are not relevant to the issues being
decided in this action. Again, this is merely a transparent distraction from the case that is
actually at issue, and is being used for the sole purpose of inserting conjecture in an effort to
distract the Court and ultimately the jury.
Although Austrich testified that he proposed to Ms. Giuffre on Valentine’s Day, see
Austrich at p. 19, Ms. Giuffre was a troubled teen who could not realistically be considered a
fiancé in the true sense of the word, nor was she of legal age to marry. In fact, as accurately
described by Defendant, Ms. Giuffre never had any intention of marrying Austrich. Giuffre Dep. Tr.
at 127:22-128:21. Given that Ms. Giuffre was a child with limited legal capacity at this point, and
that she did not have any intention of marrying Austrich, a reasonable person could not assert that
Ms. Giuffre was engaged.
31
38. Ms. Giuffre re-enrolled in high school from June 21, 2000 until March 7, 2002. After
finishing the 9th grade school year at Forest Hills High School on June 9, 1999, Ms.
Giuffre re-enrolled at Wellington Adult High School on June 21, 2000, again on August
16, 2000 and on August 14, 2001. On September 20, 2001, Ms. Giuffre then enrolled at
Royal Palm Beach High School. A few weeks later, on October 12, 2001, she
matriculated at Survivors Charter School. Id. Survivor’s Charter School was an
alternative school designed to assist students who had been unsuccessful at more
traditional schools. Ms. Giuffre remained enrolled at Survivor’s Charter School until
March 7, 2002. She was present 56 days and absent 13 days during her time there. Id.
Ms. Giuffre never received her high school diploma or GED. Ms. Giuffre and Figueroa
went “back to school” together at Survivor’s Charter School. The school day there lasted
from morning until early afternoon.
Ms. Giuffre denies this statement. Either Defendant is blatantly misleading this Court or
Defendant simply does not understand how to interpret Ms. Giuffre’s school records. The record
produced by Defendant (GM0888) is specifically titled “A07. Assignment History,” which
reflects semester start and end dates per each 180 day school year, not dates that Ms. Giuffre
physically enrolled or withdrew from school. See McCawley Dec. at Exhibit 27, GM0888.
32
While “Grade 30” indicates adult education, Ms. Giuffre’s attendance records indicate that she
was not present in school between 6/21/00-09/20/01 (see withdrawal codes W32 and W47).
More importantly, Ms. Giuffre’s school transcripts clearly indicate “NO COURSES
TAKEN” for the 1999-2000 and 2000-2001 school years. (See McCawley Dec. at Exhibit 27,
GM_00893.) Ms. Giuffre’s attempt to work and resume school at Survivor’s Charter School as a
10th grader in the 2001-2002 school year was limited to a portion of the school year (10/20/01-
03/07/02), and further substantiates Ms. Giuffre’s testimony that she attempted to get away from
Epstein’s abuse, along with the following testimony by Figueroa:
Q: Was there a period of time between 2001 and when she left in 2002 here she was
not working for Jeffrey?
A: Yes.
Q: What period of time was that?
A: It was pretty much, like, when she was actually working as a server. Like,
basically because we were trying to not have her go back there. Like, she did not
want to go back there. And we were trying to just work without needing his
money, you know.”
See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 92-93
Q: So the thing that Virginia was tired of …What was it that Virginia was trying to
get away from and stop with respect to working at Jeffrey Epstein's house?
A: To stop being used and abused.
See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 248
33
Even still, if the records are correct, which Ms. Giuffre does not concede, the records
indicate that Ms. Giuffre’s attendance was poor, with 69 days present and 32 days absent out of a
required 180 day school year and that she was not enrolled at the end of the school year
(emphasis added).
34
See McCawley Dec. at Exhibit 27, GM_00893.

Ms. Giuffre’s obvious gap in her school attendance, her presence verified by Epstein’s
pilot on flight logs, and an abundence of witness testimony all corroborate her story that she was
that Ms. Giuffre was flying domestic and internationally with Epstein at least 32 times between
12/11/00-07/28/01 and 06/21/02-08/21/02 (Defendant traveling with Ms. Giuffre on 23 of the
flights). See McCawley Dec. at Exhibits 15 and 41, Pilot, David Rodgers’ Dep. Tr. 96:12-166;
Rodger’s Dep. Ex. 1 (Ms. Giuffre flight dates: 12/11/00; 12/14/00 (GIUFFRE007095); 01/26/01;
01/27/01; 01/30/01 (GIUFFRE007096); 03/05/01: 03/06/01; 03/08/01 x’s 2; 03/09/01; 03/11/01
x’s 2 (GIUFFRE007097); 03/27/01; 03/29/01; 03/31/01 (GIUFFRE007098); 04/09/01 x’s 2;
04/11/01; 04/16/01; 05/03/01; 05/05/01 (GIUFFRE007099); 05/14/01(GIUFFRE007100);
06/03/01 06/05/01; 07/04/01; 07/08/01; 07/11/01 (GIUFFRE007101); 07/16/01; 07/28/01;
(GIUFFRE007102); 06/21/02 (GIUFFRE007111); 08/18/02; 08/21/02 (GIUFFRE007112); See
McCawley Dec. at Exhibit 1, Alessi Dep. Tr. at 104: 9-14 (Q: Do you know how long Virginia
had been coming over to the house before she started traveling on an airplane with Ghislaine and
Jeffrey? THE WITNESS: Not too long. I don't think it was too long after that); See McCawley
Dec. at Exhibit 37, GIUFFRE004721 (passport application).
39. During the year 2000, Ms. Giuffre worked at numerous jobs. In 2000, while living with
her fiancé, Ms. Giuffre held five different jobs: at Aviculture Breeding and Research
Center, Southeast Employee Management Company, The Club at Mar-a-Lago, Oasis
Outsourcing, and Neiman Marcus. Her taxable earnings that year totaled nearly $9,000.
Ms. Giuffre cannot now recall either the Southeast Employee Management Company or
the Oasis Outsourcing jobs.
35
Ms. Giuffre disputes this statement. During 2000, Ms. Giuffre shared an apartment with
her then boyfriend, James Michael Austrich and his friend, Mario. See McCawley Dec. at
Exhibit 2, Austrich Dep. Tr. at p. 92. Although Austrich testified that he proposed to Ms. Giuffre
on Valentine’s Day, see Austrich at p. 19, Ms. Giuffre was a troubled teen who could not
realistically be considered a fiancé in the true sense of the word nor was she of legal age to
marry. While Ms. Giuffre held various jobs in 2000, “[SSA] records do not show the exact date
of employment (month and day) because [they] do not need this information to figure Social
Security benefits.” See McCawley Dec. at Exhibit 46, GIUFFRE009176).
The reason that Ms. Giuffre cannot recall two companies listed on her SSA records
(Southeast Employee Management Company or Oasis Outsourcing) is simply because they were
not her employers. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 470-472. Had Defendant
bothered to run a simple google search, she could have ruled them out as being payroll and
benefit administration companies. See http://www.oasisadvantage.com/west-palm-beach-peo;
http://www.progressiveemployer.com/;
http://www.businesswire.com/news/home/20060501006151/en/Progressive-Employer-Services-
Purchases-Southeast-Employee-Management.
Ms. Giuffre has testified that she believes she worked at Taco Bell, at an aviary, then
Mar-a-Lago (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at p. 53, 470). Austrich also
testified that Ms. Giuffre worked with him at Taco Bell, as well as a pet store for “over a month”
before working at Mar-a-Lago (See McCawley Dec. at Exhibit 5, Austrich Dep. Tr. at p. 16, 30,
98). Neither Taco Bell nor the pet store are listed on Ms. Giuffre’s SSA records because they
were most likely paid through payroll companies. See McCawley Dec. at Exhibit 46,
GIUFFRE009178. Ms. Giuffre also testified that she volunteered at an aviary where they
36
eventually put her on their payroll, but paid her very little. Giuffre Dep. Tr. at p. 52; Aviculture
Breeding and Research Center taxable earnings for 2000 is $99.48, See McCawley Dec. at
Exhibit 46, GIUFFRE009178.
40. Ms. Giuffre’s employment at the Mar-a-Lago spa began in fall 2000. Ms. Giuffre’s
father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-Lago Club in
Palm Beach, Florida, beginning on April 11, 2000. Mr. Roberts worked there year-round
for approximately 3 years. After working there for a period of time, Mr. Roberts became
acquainted with the head of the spa area and recommended Ms. Giuffre for a job there.
Mar-a-Lago closes every Mother’s Day and reopens on November 1. Most of employees
Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are
“seasonal” and work only when the club is open, i.e., between November 1 and Mother’s
Day. Ms. Giuffre was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club
in the fall of 2000 after she had turned 17.
Ms. Giuffre disputes this statement. Defendant cannot simply infer Ms. Giuffre’s
employment history and claim it to be undisputed. The Mar-a-Lago Club produced 177 pages of
records in response to Defendant’s subpoena. However, not one page indicated Ms. Giuffre’s
actual dates of employment, nor whether she was a full-time or seasonal employee. In fact, the
only significant record produced was a single, vague chart entry indicating that Ms. Giuffre was
terminated in 2000. MAR-A-LAGO 0173, 0176.
37
Job postings and job descriptions produced by Mar-a-Lago from 2002 and later are
irrelevant to Ms. Giuffre’s employment because they are from after she worked there. Ms.
Giuffre testified that Mar-a-Lago was a summer job. See McCawley Dec. at Exhibit 5, Giuffre
Dep. Tr. 56, 550. In fact, her father, Sky Roberts, testified that he referred his daughter for
employment, and she did not get the job through a posting (See McCawley Dec. at Exhibit 17,
Sky Roberts Dep. Tr. at 72); he drove his daughter to and from work consistent with his full time
schedule (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 74); he believes the spa –
like the kitchen/dining room - was open to local guests in the summer (See McCawley Dec. at
Exhibit 17, Sky Roberts Dep. Tr. 138-139); and that his daughter was not attending school when
she worked at Mar-a-Lago (See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. 134). In
addition, Juan Alessi testified that it was “Summer” when Defendant approached Ms. Giuffre at
Mar-a-Lago because he specifically remembered “that day I was sweating like hell in the -- in
the car, waiting for Ms. Maxwell to come out of the massage.” See McCawley Dec. at Exhibit 1,
Alessi Dep. Tr. at 94:24-95:2.
41. Ms. Giuffre represented herself as a masseuse for Jeffrey Epstein. While working at
the Mar-a-Lago spa and reading a library book about massage, Ms. Giuffre met Ms.
Maxwell. Ms. Giuffre thereafter told her father that she got a job working for Jeffrey
Epstein as a masseuse. Ms. Giuffre’s father took her to Epstein’s house on one occasion
around that time, and Epstein came outside and introduced himself to Mr. Roberts. Ms.
Giuffre commenced employment as a traveling masseuse for Mr. Epstein. Ms. Giuffre
was excited about her job as a masseuse, about traveling with him and about meeting
famous people. Ms. Giuffre represented that she was employed as a masseuse beginning
in January 2001. Ms. Giuffre never mentioned Ms. Maxwell to her then-fiancé, Austrich.
Ms. Giuffre’s father never met Ms. Maxwell.
Ms. Giuffre denies Defendant’s false and factually unsupported narrative. In Florida, a
person cannot work as a masseuse unless she is “at least 18 years of age or has received a high
38
school diploma or high school equivalency diploma.” Fla. Stat. § 480.041. Ms. Giuffre was a
minor child, under the age of 18, when she was working at Mar-a-Lago as a spa
attendant. Giuffre Dep. Tr. at 61:9-61:24. She was approached by Defendant, who told her she
could make money as a masseuse, a profession in which Ms. Giuffre had no experience. See
McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12. (Sky Roberts,
Ms. Giuffre father, verified Ms. Giuffre’s account that Defendant recruited his daughter to “learn
massage therapy.” See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 80:7-19; 84:18 -
85:1).
Ms. Giuffre’s father drove her to Jeffrey Epstein’s house, the address of which was given
to her by Defendant. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 117:20-118:1. Ms.
Giuffre was lead into the house, and was instructed by Defendant on how to give a massage,
during which Epstein and Defendant turned the massage into a sexual encounter, and offered Ms.
Giuffre money and a better life to be compliant in the sexual demands of Defendant and
Epstein. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18.
The minor Ms. Giuffre then began travelling with Defendant and Epstein on private planes and
servicing people sexually for money—working not as a legitimate masseuse, but in a position of
sexual servitude. See McCawley Dec. at Exhibits 5, 1, Giuffre Dep. Tr. at 193:22-194:16;
201:24; 204:24:205:5; Alessi Dep. Tr. at 104:9-104:14.
Epstein’s house manager, Juan Alessi, described Defendant’s methodical routine of how
she prepared a list of places ahead of time, then drove to each place for the purpose of recruiting
girls to massage Epstein. See McCawley Dec. at Exhibit 18, Alessi Dep. Tr. at 34;
GIUFFRE000105 at 57-58; GIUFFRE000241-242 at p. 212-213. Alessi also stated that on
multiple occasions he drove Defendant to pre-planned places while she recruited girls for
39
massage. Id. He furthered testified that he witnessed Ms. Giuffre at Epstein’s house on the very
same day that he witnessed Defendant recruit Ms. Giuffre from Mar-a-Lago. See McCawley
Dec. at Exhibit 18, Alessi Dep. Tr. at 96-98; GIUFFRE000102-103 at p. 48-49.
Johanna Sjoberg, through her sworn testimony, demonstrated that Defendant recruited
her in a similar fashion by driving to the college campus where she attended school and
approached her to work at Epstein’s home answering phones. See McCawley Dec. at Exhibit 16,
Sjoberg Dep. Tr. at 8-9. Sjoberg testified that she answered phones for one day before
Defendant propositioned her to rub feet for $100.00 an hour. See McCawley Dec. at Exhibit 16,
Sjoberg Dep. Tr. at 13. The following day, Sjoberg was paired with Defendant’s assistant,
Emmy Taylor, who provided her with massage training on Epstein. Sjoberg at 13-15. Ms.
Giuffre’s then-boyfriend, Austrich, testified that he could not recall the name of the person who
recruited Ms. Giuffre. However, he did say that she was recruited by someone to work for
Epstein as a massage therapist, but that Ms. Giuffre did not have any experience. See McCawley
Dec. at Exhibit 2, Austrich Dep. Tr. at 34-35, 100-101, 127-128. Neither Ms. Giuffre nor Sjoberg
were licensed or trained in massage, but were invited soon after being recruited to travel with
Epstein on his private plane to massage him. See McCawley Dec. at Exhibit 16, Giuffre Dep. Tr.
at 16-17; Sjoberg Dep. Tr. at 13-15; Austrich Dep. Tr. at 109-110; Alessi Dep. Tr. at 104.
42. Ms. Giuffre resumed her relationship with convicted felon Anthony Figueroa. In
spring 2001, while living with Austrich, Ms. Giuffre lied to and cheated on him with her
high school boyfriend, Anthony Figueroa. Ms. Giuffre and Austrich thereafter broke up,
and Figueroa moved into the Bent Oak apartment with Ms. Giuffre. When Austrich
returned to the Bent Oak apartment to check on his pets and retrieve his belongings,
Figueroa in Ms. Giuffre’s presence punched Austrich in the face. Figueroa and Ms.
Giuffre fled the scene before police arrived. Figueroa was then a convicted felon and a
drug abuser on probation for possession of a controlled substance.
40
This entire statement is wholly irrelevant to the case being tried, and is improperly being
inserted to tarnish the record. Ms. Giuffre’s dating history as a young teen bears no relation to
the allegations made within Ms. Giuffre’s complaint against Defendant. As previously stated,
Defendant is attempting to muddy the record with nonsensical teen drama in an effort to detract
from her salacious sexual abuse of a minor child. Such statements bear no relation to the issues
presented through her motion for summary judgment, and should be given weight reflecting the
same. As specifically set forth in Ms. Giuffre’s objections to designated testimony, the alleged
information would be excluded by multiple rules of evidence, and contested by Ms. Giuffre. See
McCawley Dec. at Exhibit 5, Virginia Dep. Tr., passim. Moreover, it was the Defendant who
solicited Anthony Figueroa to recruit high school aged girls for Epstein. See McCawley Dec. at
Exhibit 4 Figueroa Tr. at 200 and 228-229.
43. Ms. Giuffre freely and voluntarily contacted the police to come to her aid in 2001
and 2002 but never reported to them that she was Epstein’s “sex slave.” In August
2001 at age 17, while living in the same apartment, Ms. Giuffre and Figueroa hosted a
party with a number of guests. During the party, according to Ms. Giuffre, someone
entered Ms. Giuffre’s room and stole $500 from her shirt pocket. Ms. Giuffre contacted
the police. She met and spoke with police officers regarding the incident and filed a
report. She did not disclose to the officer that she was a “sex slave.” A second time, in
June 2002, Ms. Giuffre contacted the police to report that her former landlord had left her
belongings by the roadside and had lit her mattress on fire. Again, Ms. Giuffre met and
spoke with the law enforcement officers but did not complain that she was the victim of
any sexual trafficking or abuse or that she was then being held as a “sex slave.”
This statement is misleading in several respects and irrelevant. The fact that Ms. Giuffre
did contact police on two occasions for two specific purposes and did not take that opportunity to
also inform the police of everything else that was going on in her life at the time is immaterial.
Defendant implies that anytime someone calls the police for one thing they should tell the police
41
about every other crime regardless of the relevance to the crime to which the police responded
and regardless to the threat to herself should she report on these powerful people. Moreover, as
Professor Coonan explained:
Popular understandings of the term “sex slave” might still connote images of violent
pimps, white slavery, or of victims chained to a bed in a brothel in the minds of some
people. To call Ms. Giuffre a victim of sex trafficking would however very accurately
convey the reality that she along with a great many other victims of contemporary forms
of slavery are often exploited by the “invisible chains” of fraud and psychological
coercion.
See McCawley Dec. at Exhibit 23, Coonan Expert Report at 20. Ms. Giuffre specifically testified
that she was fearful of Defendant and Epstein, and, accordingly, she would not have reporter her
abusers. She also knew that Epstein had control over the Palm Beach Police. See McCawley Dec.
at Exhibit 5, Giuffre Dep. Tr. at 240:3-241:2.
44. From August 2001 until September 2002, Epstein and Maxwell were almost entirely
absent from Florida on documented travel unaccompanied by Ms. Giuffre. Flight
logs maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number
of trips away from Florida that Epstein and Maxwell took, unaccompanied by Ms.
Giuffre, between August 2001 and September 2002. Rodgers maintained a log of all
flights on which Epstein and Maxwell traveled with him. Epstein additionally traveled
with another pilot who did not keep such logs and he also occasionally traveled via
commercial flights. For substantially all of thirteen months of the twenty-two months
(from November 2000 until September 2002) that Ms. Giuffre lived in Palm Beach and
knew Epstein, Epstein was traveling outside of Florida unaccompanied by Ms. Giuffre.
During this same period of time, Ms. Giuffre was employed at various jobs, enrolled in
school, and living with her boyfriend.
The flight logs produced in this matter provide substantive evidence of Ms. Giuffre’s
travel while in the control of Defendant and Epstein, but are clearly incomplete. Moreover, Ms.
Giuffre also was flown by Defendant on commercial flights. See McCawley Dec. at Exhibit 5,
Giuffre Dep. Tr. at 155:5-11. Ms. Giuffre disputes Defendant’s statement to the contrary, as
reliance upon incomplete records to prove that Ms. Giuffre was not in fact in the presence of
42
Defendant and Epstein is insufficient. Ms. Giuffre incorporates additional details contained in
Response #38 and #46 herein.
Ms. Giuffre’s obvious gap in her school records, her presence verified by Epstein’s pilot
on flight logs, and witness testimony, corroborate her story that she was traveling with Defendant
and Epstein. In fact, flight logs and pilot testimony clearly prove that Ms. Giuffre was flying
domestic and internationally with Epstein at least 32 times between 12/11/00-07/28/01 and
06/21/02-08/21/02 (Defendant traveling with Ms. Giuffre on 23 of the flights).
As Defendant acknowledges in her own statement #44, flight records are incomplete.
There were several pilots and co-pilots that flew Epstein and Maxwell (Lawrence “Larry”
Visoski, David (Dave) Rodgers, Bill Hammond, Pete Rathgeb, Gary Roxburgh, and Bill
Murphy) in multiple aircrafts (JEGE, Inc. Aircraft # N908JE – Type B-727-31, and Hyperion
Air, Inc. Aircraft # N909JE – Type G-1159B). Yet, only one pilot, David Rodger’s produced
flight records. See McCawley Dec. at Exhibit 41, David Rodger’s Flight Log,
GIUFFRE007055- GIUFFRE007161. In addition, many of the girls recruited by Defendant
routinely traveled on commercial flights for the purposes of providing massages to Epstein or
guests at Epstein’s New York, New Mexico, or U.S. Virgin Island homes. See McCawley Dec.
at Exhibit 16, Sjoberg Dep. Tr. at 27.
As thoroughly depicted below, Ms. Giuffre’s passport application, travel records and
witness testimony clearly demonstrate flight logs are incomplete because only one pilot kept a
log, and Ms. Giuffre also flew commercially while she worked for Defendant and Epstein. For
example, on December 11, 2000, while underage, Ms. Giuffre appears on Rodger’s flight log
(flight #1433) traveling with Epstein, Maxwell and Emmy Taylor from PBI (Palm Beach, FL) to
TEB (Teterboro, NJ) then on December 14, 2001 (#1434) continues traveling with Epstein and
43
Maxwell to TIST (U.S. Virgin Islands); however, there is no flight records of Ms. Giuffre’s
return to Palm Beach. See McCawley Dec. at Exhibit 15, see McCawley Dec. at Exhibit 41,
Rodger’s Dep. Ex. 1 at GIUFFRE007095; see also Rodger’s Dep. Tr. 96-98 (“Q: And do you
know how Jeffrey Epstein, Ghislaine Maxwell, Adam Perry Lang, and Virginia get off of St.
Thomas or leave the island? A: No. I do not. Probably a charter, I'm guessing.”).
On January 12, 2001, at Defendant’s directive, Ms. Giuffre applied for a Passport to
travel with them internationally. See McCawley Dec. at Exhibit 37, GIUFFRE004721, passport
application listing travel plans to London; flight logs subsequently lists Ms. Giuffre traveling to
London with Defendant, Epstein and others).
On January 26, 2001, while underage, Ms. Giuffre appears on Rodger’s flight log (flight
#1444) traveling with Epstein, Maxwell and Emmy Taylor from TEB (Teterboro, NJ) to PBI
(Palm Beach, FL); however, there is no flight record indicating how Ms. Giuffre got to New
York. On January 27, 2001 (#1445) continues traveling with Epstein, Maxwell and Emmy
Taylor from PBI (Palm Beach) to TIST (U.S. Virgin Islands) returning from TIST (U.S. Virgin
44
Islands) four days later on January 30, 2001. See McCawley Dec. at Exhibit 15, Rodger’s Dep.
Ex. 1 at GIUFFRE007096; Rodger’s Dep. Tr. at 100-102.
On March 5, 2001 Ms. Giuffre, Maxwell, Epstein, Emmy Taylor traveled together
internationally (flight #1464) leaving PBI (West Palm Beach) to CYJT (Stephenville, Canada);
then on March 6, 2001 (#1465) they continued on to LFPB (Paris, France) with a layover for
three days. On March 8, 2001, other passengers, including one unidentified female, joined them
on flights # 1466-1467 (from LFPB (Paris, France) - LGGR (Granada, Spain) eventually landing
in EGGW (London, England) on March 11, 2001, where she was then introduced to and lent out
to Prince Andrew. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007097;
Rodger’s Dep. Tr. at 104-114.
45
See also photo of Ms. Giuffre, Maxwell and Prince Andrew in London.
GIUFFRE007167; see also Figueroa Dep. Tr. at 251.
Ms. Giuffre, Epstein, Maxwell, and Taylor remained in London for three days until
departing on March 11, 2001 (#1469), stopping in BGR (Bangor, Maine) before departing
(#1470) back to TEB (Teterboro, NJ); however, there is no flight record of Ms. Giuffre’s return
to Palm Beach. See Rodger’s Dep. Ex. 1 at GIUFFRE007097; Rodger’s Dep. Tr. at 104-114.
On March 27, 2001, while underage, Ms. Giuffre, Maxwell, Epstein, Emmy Taylor, two
unidentified females and others traveled together (#1478) from PBI (Palm Beach) to TEB
(Teterboro, NJ); then three days later, on March 29, 2001, continued on (#1479) to SAF (Santa
Fe, NM), returning to PBI (Palm Beach, FL) with Nadia Bjorlin (#1480) on March 31, 2001. See
McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007098; Rodger’s Dep. Tr. at
119-125.
46
A few glaring examples of how Ms. Giuffre’s travel records are incomplete is that Ms.
Giuffre traveled from ADS (Addison, Texas) on May 3, 2001 (#1501) to SAT (San Antonio,
Texas); then departs SAT (San Antonio, Texas) on May 5, 2001 (#1502) to PBF (Pine Bluff,
AR) but there is no record produced that explains how Ms. Giuffre arrived in Addison, Texas or
how she returned to Palm Beach from Pine Bluff, AR. Although Epstein’s plane appears to have
to originated from Palm Beach on April 23, 2001, Ms. Giuffre’s name doesn’t not appear on the
log. See Rodger’s Dep. Ex. 1 at GIUFFRE007099; Rodger’s Dep. Tr. at 130-132 (“Q: Do you
know how Virginia Roberts got to Addison, Texas? A: No. … Q: Went to Addison and picked
up Virginia Roberts? A: It looks like it.”).
Another prime example of how incomplete Ms. Giuffre’s travel records are is on on May
14, 2001. While Ms. Giuffre appears on flight #1506 with Epstein, Maxwell, Emmy Taylor and
others (including one unidentified female) from TIST (U.S. Virgin Islands) to TEB (Teterboro,
NJ), there is no record produced explaining how Ms. Giuffre arrived to the U.S. Virgin Islands or
where she stayed when she landed in New York. See McCawley Dec. at Exhibit 15, Rodger’s
Dep. Ex. 1 at GIUFFRE007100; Rodger’s Dep. Tr. at 132-133 (“Q: What were the other possible
avenues back in those days for Jeffrey Epstein, Ghislaine Maxwell to travel to the Virgin
Islands? A: They could have done a charter, possibly.”) (Id. at 134-135 “Q: All right. So at some
point in time, between May 7th and May 14th – A: Uh-huh. Q: -- somebody flies the Gulfstream
to the Virgin Islands. A: Correct. Q: And who would that be? A: Larry Visoski and I don't know
who the other person would have been.”); Id. at 136 (“Q. Do you know where Virginia Roberts
went during that time after she landed in Teterboro on the 14th? A. I do not.”)
47
On June 3, 2001, Ms. Giuffre travels from PBI (Palm Beach) to TIST (U.S. Virgin
Islands) on flight #1510 for three days; then, on June 5, 2001, continues on flight #1511 to TEB
(Teterboro, NJ); however, there is no record of Ms. Giuffre returning to Palm Beach. See
Rodger’s Dep. Ex. 1 at GIUFFRE007101; Rodger’s Dep. Tr. at 136-137.
Then, on July 4, 2001, Ms. Giuffre reappears on flight #1524 with Epstein and an
unidentified female leaving TIST (U.S. Virgin Islands) to return to PBI (Palm Beach); however,
there is no flight record that reflects how Ms. Giuffre got to the U.S. Virgin Islands. See
McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007101; Rodger’s Dep. Tr. at
138-139 (“Q. And do you know how Virginia Roberts got to the Virgin Islands? A: No. Q. Is
there any -- is it possible that the Cessna took her or the Boeing took her? Or any other aircraft
that is owned by Jeffrey? A: No, I would -- if I had to guess, I would guess the airlines.”)
Again, on July 8, 2001, Ms. Giuffre appears on flight #1525 with Epstein, Maxwell,
Emmy Taylor and others including an unidentified female departing PBI (Palm Beach) to TEB
48
(Teteboro, NJ). Four days later, on July 11, 2001, Ms. Giuffre, Epstein and Maxwell continue on
(#1526) to CPS (Cahokia-St. Louis, Illinois) which was a stop due to a mechanical delay on the
way to Sante Fe, NM; however, there is no flight record that reflects how Ms. Giuffre returned
home to Palm Beach. See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at
GIUFFRE007101; Rodger’s Dep. Tr. 139-141 (“Q: And then three days later, you leave out of
Teterboro to CPS? A: Yes. Q: Where is that? A: That is St. Louis, actually it is Cahokia, Illinois,
across the river from St. Louis. Q. Who are your passengers? A. Jeffrey Epstein, Ghislaine
Maxwell, Emmy Tayler, Virginia Roberts. We were actually en route to Santa Fe. We had a
mechanical problem. We had to go into there for maintenance.”)
On July 16, 2001, Ms. Giuffre appears on flight #1528 with Epstein, Maxwell and Emmy
Taylor from SAF (Santa Fe, NM) to TEB (Teteboro, NJ); however, Ms. Giuffre’s flight to Santa
Fe, NM is missing from the records. In addition, on July 28, 2001, Ms. Giuffre reappears on the
flight log (#1531) returning with Epstein from TIST (U.S. Virgin Islands) to PBI (Palm Beach);
however, there is no record of Ms. Giuffre’s flight to the U.S. Virgin Islands. See McCawley
Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007102; Rodger’s Dep. Tr.142.
On June 21, 2002, Ms. Giuffre appears on flight #1570 with Epstein, Maxwell, Sarah
Kellen, Cindy Lopez and Jean Luc Brunel from PBI (Palm Beach, FL) to MYEF (George Town,
Bahamas); however, there is no record of Ms. Giuffre returning to Palm Beach. See McCawley
Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007111; Rodger’s Dep. Tr. 161-162 (“Q:
49
Virginia Roberts was taken to the Bahamas. Do you know where she went from there? A. I do
not.”)
On August 17, 2002, Ms. Giuffre appears on flight #1589 with Epstein, Maxwell, Sarah
Kellen, Cindy Lopez and others from SAF (Santa Fe, NM) to TEB (Teterboro, NJ); Ms. Giuffre
returns to PBI (Palm Beach, FL) on August 18, 2002 with Epstein and one unidentified female
(#1590). See McCawley Dec. at Exhibit 15, Rodger’s Dep. Ex. 1 at GIUFFRE007112; Rodger’s
Dep. Tr. 165 (“Q: Do you know how Virginia Roberts got to Santa Fe? A: No.”)
50
From September 29, 2002 through October 19, 2002, Defendant and Epstein sent Ms.
Giuffre on a commercial flight to Thailand for massage training and provided her with all
accommodations. See McCawley Dec. at Exhibit 43, Giuffre007411-Giuffre007432.
45. Ms. Giuffre and Figueroa shared a vehicle during 2001 and 2002. Ms. Giuffre and
Figueroa shared a ’93 white Pontiac in 2001 and 2002. Ms. Giuffre freely traveled around
the Palm Beach area in that vehicle. In August 2002, Ms. Giuffre acquired a Dodge
Dakota pickup truck from her father. Figueroa used that vehicle in a series of crimes
before and after Ms. Giuffre left for Thailand.
Ms. Giuffre and Tony Figueroa did not share a vehicle during 2001 and 2002. Instead,
Figueroa borrowed Ms. Giuffre’s car while she was traveling with Defendant and Epstein.
Figueroa testified that he “got to take the car, because she was going somewhere else in the
world and did not need it, so…” Figueroa Dep. Tr. At 89-90.
In fact, Ms. Giuffre was frequently traveling with Defendant and Epstein. See McCawley
Dec. at Exhibit 1, Alessi Dep. Tr. at 9-14 (stating that Virginia started traveling on an airplane
with Ghislaine and Jeffrey “not too long” after she started going over to the house). Figueroa
further testified that Virginia “would normally go about two weeks out of every month” with
Epstein. Figueroa Dep. Tr. at 90. He further stated, “Pretty much every time I took her there, it
was always to his mansion. I picked her up one time -- maybe it was a couple of times --from
the jet stream place. But pretty much every single time it was at the hou- -- at the mansion.” Id.
Moreover, Ms. Giuffre testified she purchased a car from the $10,000 payment she received from
Epstein after she was forced to have sex with Prince Andres in London at Defendant’s home
when Ms. Giuffre was a minor. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 120:1-20.
51
46. Ms. Giuffre held a number of jobs in 2001 and 2002. During 2001 and 2002, Ms.
Giuffre was gainfully employed at several jobs. She worked as a waitress at Mannino’s
Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at Roadhouse
Grill. She also was employed at Courtyard Animal Hospital (aka Marc Pinkwasser
DVM).
This statement is laughable. Ms. Giuffre was hardly gainfully employed during a time
period in which she was trying to escape from the grip Epstein and Maxwell had on Ms. Giuffre.
While Social Security provides that she earned nominal amounts of earning statements for 2001
and 2002, the records do not indicate the month or quarter of the year’s work. See McCawley
Dec. at Exhibit 46, GIUFFRE009176. For a brief period, Ms. Giuffre attempted to go back to
school to earn her GED, and tried unsuccessfully to hold down waitressing jobs. See McCawley
Dec. at Exhibit 27, GIUFFRE009179.
For example, in 2001, Ms. Giuffre earned $212.00 as a waitress working “briefly” at
Mannino’s Restaurant. (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 472). In 2002, Ms.
Giuffre earned $403.64 at CCI of Royal Palm Beach working there (TGI Fridays) for a “short
time period.” (See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 473). Then, Ms. Giuffre
worked at Roadhouse grill until about March 2002 earning $1,247.90 (See McCawley Dec. at
Exhibit 5, Giuffre Dep. Tr. at 474).
52
According to Dr. Pinkwasser’s records, Ms. Giuffre’s also received payroll checks for
weeks ending 04/22/02-06/04/02 earning a total of $1,561.75. (See McCawley Dec. at Exhibit
47, GIUFFRE009203).
Not long after Ms. Giuffre losing her job at Courtyard Animal Hospital,
GIUFFRE00009211, flight records show that Ms. Giuffre was soon back under Epstein’s control
traveling with Maxwell to the Bahamas, Santa Fe, New Mexico then New York, see McCawley
Dec. at Exhibit 47, GIUFFRE007111-GIUFFRE007112.
47. In September 2002, Ms. Giuffre traveled to Thailand to receive massage training
and while there, met her future husband and eloped with him. Ms. Giuffre traveled
53
to Thailand in September 2002 to receive formal training as a masseuse. Figueroa drove

her to the airport. While there, she initially contacted Figueroa frequently, incurring a
phone bill of $4,000. She met Robert Giuffre while in Thailand and decided to marry
him. She thereafter ceased all contact with Figueroa from October 2002 until two days
before Mr. Figueroa’s deposition in this matter in May 2016.
Ms. Giuffre did travel to Thailand to receive massage training in September 2002.
However, Defendant has inaccurately told only part of the story. Defendant has conveniently left
out certain key facts, which includes the fact that Ms. Giuffre was given an assignment from
Defendant and Epstein that she had to recruit another underage girl from Thailand, and bring that
young girl back to Epstein. See McCawley Dec. at Exhibit 43, GIUFFRE 003191. The
document Ms. Giuffre was give directs her to “call Ms. Maxwell.” See McCawley Dec. at
Exhibit 32, GIUFFRE003191. It is not disputed by Defendant or Epstein, that Ms. Giuffre was
expected to return to Epstein and Maxwell upon completion of her massage training and
assignment. It is undisputed by Ms. Giuffre that she did not return to Defendant and Epstein, but
instead escaped clear across the world to Australia where she remained in hiding from Defendant
and Epstein for several years.
48. Detective Recarey’s investigation of Epstein failed to uncover any evidence that Ms.
Maxwell was involved in sexual abuse of minors, sexual trafficking or production or
possession of child pornography. Joseph Recarey served as the lead detective from the
Palm Beach Police Department charged with investigating Jeffrey Epstein. That
investigation commenced in 2005. Recarey worked only on the Epstein case for an entire
year. He reviewed previous officers’ reports and interviews, conducted numerous
interviews of witnesses and alleged victims himself, reviewed surveillance footage of the
Epstein home, participated in and had knowledge of the search warrant executed on the
Epstein home, and testified regarding the case before the Florida state grand jury against
Epstein. Detective Recarey’s investigation revealed that not one of the alleged Epstein
victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by
the government. None of Epstein’s alleged victims said they had seen Ms. Maxwell at
Epstein’s house, nor said they had been “recruited by her,” nor paid any money by her,
nor told what to wear or how to act by her. Indeed, none of Epstein’s alleged victims ever
reported to the government they had met or spoken to Ms. Maxwell. Maxwell was not
54
seen coming or going from the house during the law enforcement surveillance of
Epstein’s home. The arrest warrant did not mention Ms. Maxwell and her name was
never mentioned before the grand jury. No property belonging to Maxwell, including
“sex toys” or “child pornography,” was seized from Epstein’s home during execution of
the search warrant. Detective Recarey, when asked to describe “everything that you
believe you know about Ghislaine Maxwell’s sexual trafficking conduct,” replied, “I
don’t.” He confirmed he has no knowledge about Ms. Maxwell sexually trafficking
anybody. Detective Recarey also has no knowledge of Ms. Giuffre’s conduct that is
subject of this lawsuit.
This statement is false. Detective Recarey knew that Maxwell was involved in the illegal
sexual activities at Epstein's house. He wanted to speak to her, but Maxwell did not return his
calls. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 28:23-29:10. Detective Recarey
concluded that Defendant’s role was to procure girls for Epstein. See McCawley Dec. at Exhibit
13, Recarey Dep. Tr. at 29:16-29:20. In the execution of the search warrant, stationary was
found in the home bearing Maxwell's name, and notes were written by house staff to Maxwell.
See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 45:13-25; Id. at 83:3-83:15; see also
Message Pads, GIUFFRE 001412, 001418, 001435, 001446, 001449, 001453, 001454. A key
piece of evidence in the investigation were message pads uncovered in trash pulls, and from
inside the residence during the search warrant. Those message pads revealed numerous calls left
at the house for Maxwell, indicating she was staying in the house during the days when Epstein
was engaging in illegal sex acts with minors.
Additionally, a walk through video taken during the execution of the search warrant
revealed photos of topless females at the home, and there was even a photograph of Maxwell
naked hanging in the home. The house staff who were deposed in the civil cases each testified to
Maxwell being the boss in charge of everyone in the house. See McCawley Dec. at Exhibits 1,
55
19, 21, Banasiak Dep. Tr. at 8:21-9:16; 14:20-15:6; Alessi Dep. Tr. at 23:11-23:20; Rodriguez
Dep. Tr. at 169:1-169:4.
Rodriguez, the house butler from 2004 through 2005, a time period that revealed daily
sexual abuse of underage females, testified that Maxwell kept a list of the local girls who were
giving massages at her desk, and that Maxwell kept nude photos of girls on her computer. See
McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 238:4-238:22; 302:19-303:10; 306:1-
306:24. Recarey testified that when the search warrant was executed, the house had been
sanitized and the computers removed from the home. See McCawley Dec. at Exhibit 13,
Recarey Dep. Tr. at 72:25-73:15. Banaziak testified that the computers were removed by
Adriana Ross, another employee who answered to Maxwell. See McCawley Dec. at Exhibit 19,
Banaziak Dep. Tr. at 54:7-22.
The record is replete with testimony demonstrating that Maxwell recruited Virginia, and
recruited other females, who in turn recruited other females, all who were sexually abuse by
Epstein; meaning, it is undisputed that Maxwell started the top of the pyramid of local Palm
Beach girls who were all eventually identified as victims. See, e.g., McCawley Dec. at Exhibit 1,
Alessi Dep. Tr. at 34:19-35:3; 98:5-98:12; 104:15-104:23. The co-conspirator who maintained
direct contact with the many underage victims was Sarah Kellen, whose sole responsibility was
to schedule underage girls to visit Epstein for sex. Sarah reported directly to Maxwell. See
McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 26:10-26:20. On the day when the search
warrant was executed, the house maid, Ruboyo was scheduled to report to the house that day at 8
am; however, she received a call from Maxwell telling her not to go. See McCawley Dec. at
Exhibit 20, Rabuyo Dep. Tr. at 81:20-82:25. Maxwell orchestrated and ran the entire sex
56
trafficking scheme from a high level, and insulated herself from most of the underage girls who
were being paid for sex.
Tony Figueroa, Ms. Giuffre's ex-boyfriend, did testify that Maxwell personally requested
that he find and bring girls to Epstein for sex once Ms. Giuffre had escaped, and that when he
brought the girls Maxwell interacted with them. See McCawley Dec. at Exhibit 4, Figueroa Dep.
Tr. at 200:6-18; 228:23-229:21. Rodriguez testified unequivocally that Maxwell was "the boss"
and that she knew everything that was going on. See McCawley Dec. at Exhibit 21, Rodriguez
Dep. Tr. 169:1-169:4.
49. No nude photograph of Ms. Giuffre was displayed in Epstein’s home. Epstein’s
housekeeper, Juan Alessi, “never saw any photographs of Virginia Roberts in Mr.
Epstein’s house.” Detective Recarey entered Epstein’s home in 2002 to install security
cameras to catch a thief and did not observe any “child pornography” within the home,
including on Epstein’s desk in his office.
This is false. Nude photographs were displayed throughout Epstein’s home.
Furthermore, Alfredo Rodriguez testified to Maxwell having pornography on her computer .
Rodriguez Dep. Tr. 150:10-17; 306:1-306:24. He also testified to there being a collage of nude
photos in Epstein's closet. Id. 253:14-254:18. That collage was eventually taken into evidence
by Detective Recarey, who testified to that fact in his deposition. See McCawley Dec. at Exhibit
13, Recarey Dep. Tr. at 73:19-73:24. And those photos are still in the possession of the FBI or
US Attorney's Office. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 74:2-74:7.
Numerous other people have testified about nude photographs being on display in the
home including Ronaldo Rizzo, who visited the home on numerous occasions and who was
reprimanded by Maxwell herself for looking at the nude photos. See McCawley Dec. at Exhibit
14, Rizzo Dep. Tr. at 25:19-26:20. Additionally, the search warrant video, taken at a time when
57
the house had already been sanitized, revealed photographs of nudity displayed, including a
photograph of Maxwell herself in the nude. See McCawley Dec. at Exhibit 44, Search Warrant
Video attached to the Deposition of Recarey.
Johanna Sjorberg testified that the Defendant bought her a camera for the specific
purpose of her taking nude photos of herself. See McCawley Dec. at Exhibit 16 Sjoberg Tr. at
150. Finally, Virginia Giuffre testified that there was a nude photograph of her at the house. See
McCawley Dec. at Exhibit 5 Virginia Giuffre Tr. at 232 and 333.
50. Ms. Giuffre intentionally destroyed her “journal” and “dream journal” regarding
her “memories” of this case in 2013 while represented by counsel. Ms. Giuffre
drafted a “journal” describing individuals to whom she claims she was sexually trafficked
as well as her memories and thoughts about her experiences with Epstein. In 2013, she
and her husband created a bonfire in her backyard in Florida and burned the journal
together with other documents in her possession. Id. Ms. Giuffre also kept a “dream
journal” regarding her thoughts and memories that she possessed in January 2016. To
date, Ms. Giuffre cannot locate the “dream journal.”
The dream journal contained memories of Ms. Giuffre’s dreams. While Ms. Giuffre has
looked for this journal, which is wholly irrelevant to this case, she has been unable to locate it.
Ms. Giuffre also wrote in a personal journal some of her experiences with Maxwell and Epstein,
which were harmful and painful. In an effort to relieve herself of those past painful experiences,
Ms. Giuffre followed the advice of a therapist, and burned the journal as a form of cathartic
release at a time when she was under no obligation to maintain the personal memorialization of
personal and painful experiences. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 205:13-
206:10.
58
51. Ms. Giuffre publicly peddled her story beginning in 2011. Ms. Giuffre granted
journalist Sharon Churcher extensive interviews that resulted in seven (7) widely
distributed articles from March 2011 through January 2015. Churcher regularly
communicated with Ms. Giuffre and her “attorneys or other agents” from “early 2011” to
“the present day.” Ms. Giuffre received approximately $160,000 for her stories and
pictures that were published by many news organizations.
Defendant's statement misrepresents history. In 2011, Ms. Giuffre was still in hiding
from Epstein and Maxwell in Australia. Ms. Giuffre was not looking to sell anything or even
speak with anyone about what had happened to her in her previous life from which she
dramatically escaped. Journalist, Sharon Churcher, located Ms. Giuffre and impressed the
importance of Ms. Giuffre standing up to those who had harmed her and speak with Federal
authorities, which Ms. Giuffre did in 2011. See McCawley Dec. at Exhibit 31, Redacted 302
GIUFFRE001235-01246.
In addition, Churcher impressed the importance of bringing the abuse of Defendant and
Epstein to public light to prevent their continued abuse of others. See McCawley Dec. at Exhibit
35, Giuffre003690. After much deliberation, Ms. Giuffre agreed to be interviewed by Churcher,
and was compensated for sharing her story, which came at a heavy price of being publicly
scrutinized.
52. Ms. Giuffre drafted a 144-page purportedly autobiographical book manuscript in

2011 which she actively sought to publish. In 2011, contemporaneous with her
Churcher interviews, Ms. Giuffre drafted a book manuscript which purported to
document Ms. Giuffre’s experiences as a teenager in Florida, including her interactions
with Epstein and Maxwell. Ms. Giuffre communicated with literary agents, ghost writers
and potential independent publishers in an effort to get her book published. She
generated marketing materials and circulated those along with book chapters to numerous
individuals associated with publishing and the media.
59
Defendant’s characterization of these activities are out of context and thus misleading. In
2008, Ms. Giuffre received a Victim Notification Letter from the United States Attorney’s office
for the Southern District of Florida, see McCawley Dec. at Exhibit 30, GIUFFRE0010202,
regarding her sexual victimization by Epstein. Thereafter, in 2011, she sought psychological
counseling from a psychologist for the trauma she endured. Also that year, journalist Sharon
Churcher sought her out, and traveled half way around the globe to interview her on painful
subjects. Ms. Giuffre was interviewed by the FBI in 2011. See McCawley Dec. at Exhibit 31,
FBI Redacted 302 GIUFFRE01235-1246. She was also getting psychological help. See
McCawley Dec. at Exhibit 38, Lightfoot Records, GIUFFRE005431-005438. In that situation,
Ms. Giuffre began to draft a fictionalized account of what happened to her. It was against this
backdrop of her trauma being unearthed, her steps to seek psychological counseling for it, that
she drafted this manuscript. Doing so was an act of empowerment and a way of reframing and
taking control over the narrative of her past abuse that haunts her.
“Writing ‘I’ has been an emancipatory project for women.” Perreault, Jeanne,
“AUTOGRAPHY/ TRANSFORMATION/ ASYMMETRY,” Women, Autobiography, Theory A Reader
edited by Sidonie Smith & Julia Watson. Indeed, scholars have written that the act of engaging in
autobiography or even accounts loosely based on autobiography, is a process of taking control of
one’s own narrative and one’s own self: “Thus a specific recitation of identity involves the
inclusion of certain identity contents and the exclusion of others; the incorporation of certain
narrative itineraries and internationalities, the silencing of others; the adoption of certain
autobiographical voices, the muting of others.” Smith, Sidonie, PERFORMATIVITY,
60
AUTOBIOGRAPHICAL PRACTICE, RESISTANCE, Women, Autobiography, Theory A Reader edited by
Sidonie Smith & Julia Watson.
Indeed, even a cursory look at the manuscript penned by Ms. Giuffre informs the reader
that she is trying to put forth a more palatable and more empowering narrative to over-write that
powerlessness she felt when being abused by Defendant and Epstein. While Ms. Giuffre
explored trying to publish her story to empower other individuals who were subject to abuse, she
ultimately decided not to publish it. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. 249:16-
18; 250:19-251:3.
53. Ms. Giuffre’s publicly filed “lurid” CVRA pleadings initiated a media frenzy and
generated highly publicized litigation between her lawyers and Alan Dershowitz. On
December 30, 2014, Ms. Giuffre, through counsel, publicly filed a joinder motion that
contained her “lurid allegations” about Ms. Maxwell and many others, including Alan
Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a
“corrected” motion and two further declarations in January and February 2015, which
repeated many of Ms. Giuffre’s claims. These CVRA pleadings generated a media
maelstrom and spawned highly publicized litigation between Ms. Giuffre’s lawyers,
Edwards and Cassell, and Alan Dershowitz. After Ms. Giuffre publicly alleged Mr.
Dershowitz of sexual misconduct, Mr. Dershowitz vigorously defended himself in the
media. He called Ms. Giuffre a liar and accused her lawyers of unethical conduct. In
response, attorneys Edwards and Cassell sued Dershowitz who counterclaimed. This
litigation, in turn, caused additional media attention by national and international media
organizations.
See Ms. Giuffre’s Paragraph 7, supra, explaining why the allegations were necessary and
appropriate for multiple reasons. Ms. Giuffre disputes Defendant’s false characterization of these
events, and, indeed, the media attention was caused by Defendant’s is suing her defamatory press
release.
61
54. Ms. Giuffre formed non-profit Victims Refuse Silence to attract publicity and speak
out on a public controversy. In 2014, Ms. Giuffre, with the assistance of the same
counsel, formed a non-profit organization, Victims Refuse Silence. According to Ms.
Giuffre, the purpose of the organization is to promote Ms. Giuffre’s professed cause
against sex slavery. The stated goal of her organization is to help survivors surmount the
shame, silence, and intimidation typically experienced by victims of sexual abuse. Ms.
Giuffre attempts to promote Victims Refuse Silence at every opportunity. For example,
Ms. Giuffre participated in an interview in New York with ABC to promote the charity
and to get her mission out to the public.
Ms. Giuffre did not form the non-profit Victims Refuse Silence to "speak out on a public
controversy," but instead to simply help survivors of sexual abuse and sexual trafficking. In
order to provide assistance to victims, Ms. Giuffre attempted to talk about the non-profit’s
mission when she had the opportunity to do so. See www.victimsrefusesilece.org.
MS. GIUFFRE’S STATEMENT OF UNDISPUTED FACTS
55. Virginia Roberts was born August 9, 1983. See McCawley Dec. at Exhibit 51,
Driver’s License GIUFFRE009209.
56. Virginia Roberts turned 18 on August 9, 2001.
57. In 2000, Virginia's father Sky Roberts worked at the Mar-a-Lago. See McCawley
Dec. at Exhibit 17, Sky Roberts Dep. Tr. at 72, 74.
58. Sky Roberts got Virginia a job at Mar-a-Lago in 2000, either months before or
just after Virginia's 17th birthday. See McCawley Dec. at Exhibit 17, Sky Roberts Dep. Tr. at
72, 74; Giuffre Dep. Tr. at 25:19-25:21; 28:10-28:12.
59. The only year in which Virginia was employed at Mar-a-Lago was 2000. See
McCawley Dec. at Exhibit 49, MAR-A-LAGO 0173, 0176.
62
60. Virginia worked at Mar-a-Lago as a spa bathroom attendant. See McCawley Dec.
at Exhibit 5, Giuffre Dep. Tr. at 61:9-61:24; Austrich Dep. Tr. at 100:3-12.
61. Virginia was not a masseuse at Mar-a-Lago as she had no massage experience.
See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21; 116:19-117:12; Austrich
Dep. Tr. at 34-35, 100-101, 127-128; Figueroa Dep. Tr. at 82:10-15; 168:24-169:1; Sky Roberts
Dep. Tr. at 80:7-19; 84:18 -85:1.
62. Maxwell approached Virginia at Mar-a-Lago, and recruited her to come to Jeffrey
Epstein's house. See McCawley Dec. at Exhibits 1, 5, and 17, Giuffre Dep. Tr. at 111:12-111:21;
116:19-117:12; Alessi Dep. Tr. at 94:24-95:2; Sky Roberts Dep. Tr. at 80:7-19; 84:18 -85:1.
63. At the time Maxwell recruited Virginia to Jeffrey Epstein's house, Virginia was
either 16 or 17 years old, depending on whether this occurred just before or just after Virginia's
birthday. See McCawley Dec. at Exhibit 49, MAR-A-LAGO 0173, 0176.
64. Virginia followed Maxwell's instructions and reported to Jeffrey Epstein's house
on the night of the day when Maxwell approached Virginia at Mar-a-Lago. See McCawley Dec.
at Exhibits 5 and 18, Giuffre Dep. Tr. at 117:20-118:1; Alessi Dep. Tr. at 96-98;
GIUFFRE000102-103 at p. 48-49.
65. Maxwell told Virginia at Mar-a-Lago that Virginia could get paid for giving a
massage to Jeffrey Epstein. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 111:12-111:21;
116:19-117:12.
66. When Virginia arrived at Epstein's house, she was taken upstairs to Epstein's
bedroom, and instructed by Maxwell and Epstein how to give Epstein a massage. See McCawley
Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18; Epstein Dep. Tr. at 74:3-14.
63
67. Epstein and Maxwell turned the massage into a sexual encounter. See McCawley
Dec. at Exhibit 5, Giuffre Dep. Tr. at 198:20-199:3; 199:15-199:18.
68. Virginia was not a professional masseuse, and was not old enough to be a
masseuse in Florida even though Maxwell testified she only hired professional masseuses. See
McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at 61:9-61:24, 111:12-111:21, 116:19-117:12; Fla.
Stat. § 480.041; Maxwell Dep. Tr. at 23:21-24:9; 31:6-18; 41:7-13; 220:13-221:2; 225:23-
226:20; 248:5-16; 310:6-17; 383:2-18.
69. Maxwell and Epstein promised Virginia money and a better life in exchange for
complying with their sexual demands. See McCawley Dec. at Exhibit 5, Giuffre Dep. Tr. at
198:20-199:3; 199:15-199:18.
70. Maxwell had sex with Virginia and other females. See McCawley Dec. at Exhibit
5, Giuffre Dep. Tr. at 138:17-139:16; Maxwell 07-22-2016 Dep. Tr. at 86:25-87:9; 91:15-91:21.
71. Virginia was trafficked nationally and internationally for sexual purposes. See
McCawley Dec. at Exhibits 5, 1, 41? GIUFFRE007055-007161 (Flight Logs); Giuffre Dep. Tr.
at 193:22-194:16; 201:24; 204:24:205:5; Alessi Dep. Tr. at 104:9-104:14; Andrew Photo
GIUFFRE007167; Spain Photo GIUFFRE007166.
72. Maxwell recruited other non-professionals under the guise of being a masseuse,
but in reality only recruited girls for sexual purposes. See McCawley Dec. at Exhibits 5, 16, 4, 1,
18 Giuffre Dep. Tr. at 198:20-199:3; Sjoberg Dep. Tr. at 13-15; Figueroa Dep. Tr. at 88:12-22;
Alessi Dep. Tr. at 34; GIUFFRE000105 at 57-58; GIUFFRE000241-242 at p. 212-213.
73. Maxwell was the boss of others whose job it was to recruit minor females for
Epstein for sex, such as Sarah Kellen. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at
26:10-26:20.
64
74. Maxwell was a recruiter of underage girls and other young females for Epstein for
sex, and was the boss in charge of those females. See McCawley Dec. at Exhibits 16, 4, 21, and
1, Sjoberg Dep. Tr. 8-9, 13-15, 27; Figueroa Dep. Figueroa Dep. Tr. at 200:6-18; 228:23-229:21;
Rodriguez Dep. Tr. 169:1-169:4; Alessi Dep. Tr. at 23:11-23:20; 34:19-35:3; 98:5-98:12;
104:15-104:23.
Dated: January 31, 2017 Respectfully Submitted,

(954) 356-0011
David Boies
333 Main Street
Armonk, NY 10504
(954) 524-2820
University of Utah
383 University St.
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
65
I HEREBY CERTIFY that on January 31, 2017, I electronically filed the foregoing
document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices
of Electronic Filing generated by CM/ECF.

Tel: (303) 831-7364
Fax: (303) 832-2628
/s/ Sigrid S. McCawley

Sigrid S. McCawley
66

v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF

PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT AND UNDISPUTED FACTS
I, Sigrid McCawley, declare that the below is true and correct to the best of my
knowledge as follows:
1. I am a Partner with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my
Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in Support of Plaintiff’s Response to
Defendant’s Motion for Summary Judgment and Undisputed Facts.
3. Attached hereto as Sealed Exhibit 1 are true and correct copies of Excerpts from
June 1, 2016 Depositions of Juan Alessi.
4. Attached here to as Sealed Exhibit 2 is a true and correct copy of Excerpts from
June 23, 2016, Deposition of James Austrich.
5. Attached hereto as Sealed Exhibit 3 is a true and correct copy of Excerpts from
September 9, 2016, Deposition of Jeffrey Epstein.
June 24, 2016, Deposition of Tony Figueroa (Volumes I and II).

7. Attached hereto as Sealed Composite Exhibit 5 are true and correct copies of
Excerpts from May 3, 2016 and November 14, 2016, Deposition of Virginia Giuffre.
November 18, 2016, Deposition of Ross Gow.
June 20, 2016, Deposition of .
January 25, 2017, Deposition of Sarah Kellen.
November 29, 2016, Deposition of Peter Kent.
January 17, 2017, Deposition of Nadia Marcinko.
Excerpts from April 22, 2016 and July 22, 2016, Depositions of Ghislaine Maxwell.
May 24, 2016, Deposition of Lynne Trudy Miller
June 21, 2016, Deposition Joseph Recarey.
June 10, 2016, Deposition of Rinaldo Rizzo.
June 3, 2016, Deposition of David Rodgers.
May 18, 2016, Deposition of Johanna Sjoberg.
2
May 20, 2016, Deposition of Sky Roberts.
Excerpts from September 8, 2009, Depositions of Juan Alessi (GIUFFRE000102-000103;
GIUFFRE000105; GIUFFRE000241-000242).
February 16, 2010, Deposition of Janusz Banasiak (GIUFFRE004431-004432;
GIUFFRE004437-004438; GIUFFRE004477).
October 20, 2009, Deposition of Louella Rabuyo (GIUFFRE004386).
23. Attached hereto as Sealed Composite Exhibit 21 is a true and correct copy of
Excerpts from July 29, 2009 and August 7, 2009, Deposition of Alfredo Rodriguez
(GIUFFRE000936-000937; GIUFFRE000942; GIUFFRE000953-000954; GIUFFRE000974;
GIUFFRE000978; GIUFFRE000996; GIUFFRE000999-001000; GIUFFRE001003).
24. Attached hereto as Sealed Exhibit 22 is a true and correct copy of August 1,
2016, Defendant’s Privilege Log.
25. Attached hereto as Sealed Exhibit 23 is a true and correct copy of September 15,
2016, Expert Report of Professor Terry Coonan.
2016, Expert Report of Doctor Bernard Jansen.
27. Attached hereto as Sealed Exhibit 25 is a true and correct copy of November 28,
2016, Expert Report of Peter Kent
28. Attached hereto as Sealed Exhibit 26 is a true and correct copy of January 2,
2015, Email Correspondence (GM_00068).
3
29. Attached hereto as Sealed Exhibit 27 is a true and correct copy of Excerpts of
Palm Beach School County Records (GM_00888-00898).
30. Attached hereto as Sealed Exhibit 28 is a true and correct copy of Excerpts of
Message Pads (GIUFFRE001388; GIUFFRE001409; GIUFFRE001412-4213;
GIUFFRE001417-18, GIUFFRE001421; GIUFFRE001423; GIUFFRE001426-1428;
GIUFFRE001432-1433; GIUFFRE001435; GIUFFRE001446; GIUFFRE001448-1449;
GIUFFRE001452-1454; GIUFFRE001456; GIUFFRE001462; GIUFFRE001474;
GIUFFRE001563).
31. Attached here to as Sealed Exhibit 29 is a true and correct copy of Epstein’s
Black Book (GIUFFRE001573-GIUFFRE001669).
2008, U.S. Attorney Victim Notification Letter (GIUFFRE002216-002218).
33. Attached hereto as Sealed Exhibit 31 is a true and correct copy of July 5, 2013,
Federal Bureau of Investigation Interview (GIUFFRE001235-001246).
34. Attached hereto as Sealed Exhibit 32 is a true and correct copy of Handwritten
Note from Defendant. (GIUFFRE003191-003192).
35. Attached hereto as Sealed Exhibit 33 is a true and correct copy of July 2001 New
York Presbyterian Hospital Records (GIUFFRE003258-003290).
36. Attached hereto as Sealed Exhibit 34 is a true and correct copy of a February 17,
2011, Email Correspondence to Sharon Churcher (GIUFFRE003678).
37. Attached hereto as Sealed Exhibit 35 is a true and correct copy of February 13,
2011, Email Correspondence to Sharon Churcher (GIUFFRE003690).
38. Attached hereto as Sealed Exhibit 36 is a true and correct copy of February 25,
2011, Email Correspondence to Sharon Churcher (GIUFFRE003731).)
39. Attached hereto as Exhibit 37 is a true and correct copy of a Passport Application
4
(GIUFFRE004721).
40. Attached hereto as Sealed Exhibit 38 is a true and correct copy of Judith
Lightfoot Psychological Records (GIUFFRE005431-005438).
41. Attached hereto as Sealed Exhibit 39 is a true and correct copy of July 25, 2006,
Palm Beach Police Department Incident Report (GIUFFRE005614-005700).
42. Attached hereto as Sealed Exhibit 40 is a true and correct copy of an Amazon
Receipt (GIUFFRE006581).
43. Attached hereto as Sealed Exhibit 41 is a true and correct copy of David
Rodger’s June 3, 2016, Deposition Exhibit 1, Flight Log, (GIUFFRE007055-007161).
44. Attached hereto as Sealed Exhibit 42 are true and correct copies of Photographs
(GIUFFRE007162-7182).
45. Attached hereto as Sealed Exhibit 43 is a true and correct copy of Travel
Documents to Thailand (GIUFFRE007411-GIUFFRE007432).
46. Attached hereto as Sealed Exhibit 44 is a true and correct copy of Walkthrough
Video CD (GIUFFRE007584).
47. Attached hereto as Sealed Exhibit 45 is a true and correct copy of West Palm
Beach Contact List (GIUFFRE007834-GIUFFRE007847).
48. Attached hereto as Sealed Exhibit 46 is a true and correct copy of October 23,
2016, Social Security Administration records (GIUFFRE009176-GIUFFRE009179).
49. Attached hereto as Sealed Exhibit 47 is a true and correct copy of November 7,
2016, Employment Records from Courtyard Animal Hospital (GIUFFRE009203).
2015, Email Correspondence (RG (UK) _000009).
51. Attached hereto as Sealed Exhibit 49 are true and correct copies of Termination
5
Documents (MAR-A-LAGO 0173 & MAR-A-LAGO 0176).
2015, Joinder Motion (GIUFFRE000319-000333).
53. Attached hereto as Sealed Exhibit 51 is a true and correect copy of Virginia
Roberts Driver License (GIUFFRE009209).
/s/ Sigrid McCawley______________

Sigrid McCawley, Esq.
6
Dated: January 31, 2017.

(954) 356-0011
David Boies
333 Main Street
Armonk, NY 10504

(954) 524-2820

University of Utah
383 University St.
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
7
I HEREBY CERTIFY that on the 31st day of January, 2017, I electronically filed the
foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the
foregoing document is being served to all parties of record via transmission of the Electronic
Court Filing System generated by CM/ECF.

Tel: (303) 831-7364
Fax: (303) 832-2628
/s/ Sigrid McCawley

Sigrid McCawley
8
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&%-:%''3
EXHIBIT 1
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)%-:%''3
Page 1

------------------------------------------x
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
June 1, 2016
9:12 a.m.
Deposition of JOHN ALESSI, pursuant
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3%-:%''3
Page 9
1 JOHN ALESSI
2 Q. You're ready to start, correct?
3 A. Yes.
4 Q. Can you tell us your current address?
5 A. Boynton Beach,
6 Florida 33472.
7 Q. And your date of birth?
8 A. .
9 Q. And was there a time when you worked for a
10 man named Jeffrey Epstein?
11 A. Yes.
12 Q. And can you tell us when you began working
13 for Mr. Epstein?
14 A. I began working for Mr. Epstein part-time.
15 I cannot exactly tell you the date, but it was
16 1990/'91, probably. I worked a total of 13 years
17 for him.
18 Q. Okay. So you began in 1990 part-time,
19 correct?
20 A. Right.
21 Q. And you stopped working for him when?
22 A. I stopped working for him on
23 December 31st, 2001. I was out -- yes, 2001.
24 Q. Okay.
25 A. The end of 2001. I left the last day of
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7%-:%''3
Page 10
1 JOHN ALESSI
2 the year.
3 Q. Okay. I know that it's been a long time.
4 A. It's been a long time.
5 Q. I know. So I'm going to ask that you
6 refer to the statement that you provided to the
7 police November 21st, 2005, and please go to page 5.
8 I just want you to start reading at line 2 and 3,
9 and tell me if that refreshes your recollection as
10 to your time or duration of employment.
11 A. You're right. It was 2002, then. 2002.
12 Q. So sometime in 1990, you were a part-time
13 employee?
14 A. Uh-huh.
15 Q. And you worked until December 31st, 2002;
16 is that right?
17 A. Yes.
18 Q. Okay. And is it also correct that you
19 began full-time employment with Mr. Epstein on
20 January 1st, 1991, as stated in that report?
21 A. Yes.
22 Q. Prior to 1990, who did you work for?
23 A. Prior to 1990, I had a company, a
24 maintenance company, myself, my own company, Alessi
25 Maintenance. And before that, I worked for another
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;%-:%''3
Page 11
1 JOHN ALESSI
2 family, the Radi family in Palm Beach.
3 Q. Did you ever work for a man named Les
4 Wexner?
5 A. I did some work for him in his mother's
6 house.
7 Q. Where was that?
8 A. Palm Beach. What year? Before -- before
9 I came to work for Jeffrey.
10 Q. Is that who recommended that you work for
11 Jeffrey Epstein?
12 A. I guess so.
13 Q. Okay. When you started with Jeffrey
14 Epstein, what were your job duties?
15 A. I was doing maintenance. I was doing
16 building and rebuilding and maintenance work
17 basically. Because he just bought the house at that
18 time. And because of Mr. Wechsler knowing me, they
19 recommend me to go to the house and take a look at
20 the house. And we start tearing the house down,
21 basically, at the beginning of my job.
22 Q. Did you assist in the teardown?
23 A. Yes.
24 Q. Okay. So your job duties then was that of
25 a maintenance?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*%-:%''3
Page 12
1 JOHN ALESSI
2 A. Maintenance, building.
3 Q. Got it.
4 And did you meet Mr. Epstein when you
5 were -- in 1990?
6 A. Yes, I met him.
7 Q. Okay. And in 1991, who made the decision
8 for you to become a full-time employee?
9 A. Jeffrey.
10 Q. And as a full-time employee initially,
11 what was your job?
12 A. I was basically maintenance, the same
13 thing as I was doing with -- I was exclusively
14 working for him. I was full-time working for him as
15 maintenance, because the house was still on
16 renovation, and he wanted me there.
17 Q. Okay. And how was your relationship with
18 Mr. Epstein back then, 1991?
19 A. Great. No problem.
20 Q. It was good?
21 A. It was good.
22 Q. Did he have a girlfriend back then, in
23 1991?
24 MR. PAGLIUSCA: Object to the form and
25 foundation.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$<%-:%''3
Page 13
1 JOHN ALESSI
2 You can answer the question.
3 Occasionally, I'll need to object for the
4 record in case we need to have a discussion
5 about this with the judge. And so that's just
6 me preserving those objections.
7 THE WITNESS: Yes, he had a girlfriend.
8 Her name was Dr. Andersson, Eva Andersson. And
9 she was there just for a few months after I
10 came to the house.
11 BY MR. EDWARDS:
12 Q. And how was your relationship with
13 Dr. Andersson?
14 A. Fine.
15 Q. Okay. And at the time when Mr. Epstein
16 was -- at the time when Dr. Andersson was Jeffrey
17 Epstein's girlfriend, did you see any other female
18 companions around the house?
19 A. Eventually -- they have a lot of guests,
20 too. They did have guests coming in. But I can't
21 remember exactly who. It's a socialite. So they
22 have friends.
23 Q. At the time when Dr. Andersson was
24 Mr. Epstein's girlfriend, was Mr. Epstein getting
25 massages?
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Page 14
1 JOHN ALESSI
3 foundation.
4 THE WITNESS: I think so. I was not
5 involved in the house, inside of the house that
6 much. But they always got massages. Always.
7 BY MR. EDWARDS:
8 Q. Okay. I'm talking about the time period
9 when Dr. Andersson was there.
10 A. Yes, they got massages.
11 Q. Okay. So do you remember other female
12 visitors when Dr. Andersson was Mr. Epstein's
13 girlfriend?
14 A. I don't remember. I remember people being
15 there, visitors, but I cannot remember that far.
16 Q. Okay. After -- did there come a point in
17 time when Dr. Andersson was no longer Mr. Epstein's
18 girlfriend?
19 A. Right.
20 Q. Yes?
21 A. Yes.
22 Q. And did he -- did he have a new
23 girlfriend?
24 MR. PAGLIUSCA: Object to form and
25 foundation.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$6%-:%''3
Page 23
1 JOHN ALESSI
2 Q. All right.
3 Who was in charge of the Palm Beach house?
4 A. I was.
5 Q. All right.
6 Who was your direct supervisor?
7 A. Mr. Epstein. He would deal with me
8 directly, or if he was not available, Ms. Maxwell.
9 Q. Okay. I want you to go to Exhibit 3 and
10 page -- page 179, line 8.
11 A. Line 8, "QUESTION: And then Maxwell came
12 and she took over you as your immediate supervisor?
13 Yes. That's correct. Yes. She became
14 the supervisor not only for this house, but for all
15 the homes.
16 Q. Okay. So your immediate supervisor was
17 Ms. Maxwell?
18 A. Ms. Maxwell. But if Mr. Epstein was at
19 the house, I would never go to Ms. Maxwell; I would
20 go to him directly, or he would come to me.
21 Q. Okay. At some point in time towards the
22 end of your tenure, did you come to resent
23 Ms. Maxwell?
25 foundation.
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Page 28
1 JOHN ALESSI
2 Q. And where did the massage therapists --
3 where did they come from?
4 A. Most, they came from Palm Beach. Palm
5 Beach County.
6 Q. And over the course of that 10-year period
7 of time while Ms. Maxwell was at the house, do you
8 have an approximation as to the number of different
9 females -- females that you were told were massage
10 therapists that came to the house?
12 foundation.
13 THE WITNESS: I cannot give you a number,
14 but I would say probably over 100 in my stay
15 there.
16 BY MR. EDWARDS:
17 Q. And many of the times would the females
18 come only one time and not return?
20 foundation.
21 BY MR. EDWARDS:
22 Q. Let me ask that a different way.
23 Were there times when some of these
24 females that would come to the house, and you were
25 told that they were massage therapists, would come
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1 JOHN ALESSI
2 BY MR. EDWARDS:
3 Q. Okay. And who would find the massage
4 therapist to bring to the house?
5 A. They would call me in my office, and they
6 would say, Get me a massage at 10:00 with this
7 person.
8 I have a list of the massage therapists, a
9 Rolodex, or a card, and I would call them for the
10 specific time they want a massage. And I would do
11 that.
12 Q. I don't think I asked the right -- the
13 question that I was looking to ask, so let me go
14 back.
15 Did you go out looking for the girls --
16 A. No.
17 Q. -- to bring --
18 A. Never.
19 Q. -- as the massage therapists?
20 A. Never.
21 Q. Who did?
22 A. Ms. Maxwell, Mr. Epstein and their
23 friends, because their friends relayed to other
24 friends they knew a massage therapist and they would
25 send to the house. So it was referrals.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&)%-:%''3
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1 JOHN ALESSI
2 foundation. Hold on. That misstates what is
3 happening in this deposition, because the word
4 "recruit" was introduced by the lawyers in this
5 deposition. So I object to your
6 characterization of the testimony.
7 BY MR. EDWARDS:
8 Q. I'll read for you the question and the
9 answer.
10 The question was: "QUESTION: When did
11 that role get transferred from you to Ms. Maxwell,
12 the role of looking after girls or calling the
13 girls?
14 "ANSWER: I didn't look after -- out for
15 girls. Ms. Maxwell was the one that recruit. I
16 remember one occasion or two occasions she would say
17 to me, John, give me a list of all the spas in Palm
18 Beach County, and I will drive her from one to the
19 other to PGA in Boca; and she would go in and drop
20 credit cards -- not credit cards but business cards,
21 and she would come out. And then we'd go to -- she
22 will recruit the girls. Was never, never done by me
23 or Mr. Epstein or anyone else that I know of."
24 Is that truthful testimony?
25 A. It is truthful; however, I think
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Page 35
1 JOHN ALESSI
2 "recruiting," for myself, for my point of view, is
3 hiring immediately and recruit the person.
4 I think she was looking for massage
5 therapists. She was looking for the best kind. She
6 went -- and you're right, I went one time with her,
7 or twice maybe, to different spas and different
8 clubs, great clubs, I mean, in Boca, in Fort
9 Lauderdale, in -- in Palm Beach. She was looking
10 for the best massage therapists available.
11 How she find these girls, I don't know. I
12 just drove there. I just was the driver. I never
13 was involved with any of the offerings or
14 negotiations or meeting these girls. Never.
15 Q. Okay. Ms. Maxwell was the one that would
16 meet the girls?
17 A. Yeah.
18 Q. Okay. Did you ever check any of the IDs
19 for any of these girls?
20 A. I was not -- that was not in my everyday
21 things to do. It was not.
22 Q. That was just not part of your job?
23 A. That was not my job.
24 Q. Did Ms. Maxwell take photographs while she
25 was at the Palm Beach house?
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Page 52
1 JOHN ALESSI
3 foundation.
4 THE WITNESS: Himself. Himself.
5 BY MR. EDWARDS:
6 Q. And you do not know the ages of the
7 various massagists, right?
8 A. No.
9 Q. Did you have occasion to clean up after
10 the massages?
11 A. Yes.
12 Q. Okay. And that is after both a massage
13 for Jeffrey Epstein, as well as clean up after a
14 massage that Ghislaine Maxwell may have received?
15 A. Yes.
16 Q. And on occasion, after -- in cleaning up
17 after a massage of Jeffrey Epstein or Ghislaine
18 Maxwell, did you have occasion to find vibrators or
19 sex toys that would be left out?
21 foundation.
22 THE WITNESS: Yes, I did.
23 BY MR. EDWARDS:
24 Q. Can you describe the types of vibrators or
25 sex toys that you found left out after a massage
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;%-:%''3
Page 53
1 JOHN ALESSI
2 that Jeffrey Epstein had just received or Ghislaine
3 Maxwell had just received?
5 foundation.
6 THE WITNESS: It was probably two to three
7 times, I would say. It was not all the time.
8 I would find things like a dildo, it's called a
9 double. I hate to say it because these ladies.
10 But I find these things, put my gloves on, took
11 it out and rinse it, and put it in
12 Ms. Maxwell's closet.
13 BY MR. EDWARDS:
14 Q. Why would you put the dildo or sex toy in
15 Ms. Maxwell's closet?
16 A. Because I knew that's where they were
17 kept.
18 Q. How did you know that the sex toys were
19 kept in Ms. Maxwell's closet?
20 A. Because I know where everything was in
21 that house. Every single room, every single thing,
22 it was a place, it was placed by me, by the cleaning
23 lady or my wife. Every -- everything that happened
24 in that house, I knew it.
25 Q. Who showed you where the dildo or sex toys
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&*%-:%''3
Page 54
1 JOHN ALESSI
2 were kept in the house the first time?
4 foundation.
5 THE WITNESS: Nobody. Nobody show me.
6 BY MR. EDWARDS:
7 Q. You just saw it?
8 A. I saw it.
9 Q. So you knew where to put it back?
10 A. Yeah. We had to open the closet, clean
11 the closet, put the clothes in place, put the shoes
12 in place, put everything in place. So it was a
13 matter of tidying things up.
14 Q. Did you ever find any costumes?
15 A. I saw one shiny black costume, but I
16 didn't even know --
17 Q. Where did you see it?
18 A. The same place.
19 Q. In Ms. Maxwell's closet?
20 A. Yes.
21 Q. And where was Ms. Maxwell's closet in the
22 house?
23 A. In the house? It was in the opposite side
24 of his bathroom. It was her bathroom in the master
25 bedroom. It was in the middle. So it was on the
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Page 94
1 JOHN ALESSI
2 BY MR. EDWARDS:
3 Q. That demonstrates that she was, I believe,
4 terminated from her employment in 2000.
5 My question to you is: Do you remember
6 what time of year or what month it would have been,
7 whether spring, summer, fall, winter; January,
8 February, December?
9 A. Of what year?
10 Q. Of 2000, that you would have gone to the
11 Mar-a-Lago?
12 A. It wasn't 2000.
14 foundation.
15 BY MR. EDWARDS:
16 Q. Okay. Do you think it was a different
17 year that you went to Mar-a-Lago?
18 A. Yes.
19 Q. Okay. What year do you believe that you
20 went to the Mar-a-Lago to pick Virginia up?
21 A. I think it was 2000 and -- I think it was
22 the summer of 2002.
23 Q. Okay.
24 A. Summer, because I remember that day that I
25 was sweating like hell in the -- in the car, waiting
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Page 95
1 JOHN ALESSI
2 for Ms. Maxwell to come out of the massage.
3 Q. Okay. So what month of the summer do you
4 remember it being?
5 A. I think in June, July, maybe, 2001.
6 Q. 2000 and what?
7 A. 2001.
8 Q. June, July, 2001, that's when you believe
9 that it was?
10 A. Yes.
11 Q. Okay. And do you remember the month --
12 A. No, sorry. Sorry. Not 2001. We left in
13 December 31st. It was 2000 -- the last year that I
14 was working for Jeffrey, when I met Virginia.
15 Q. Your recollection, as you sit here
16 today --
17 A. It was 2002.
18 Q. -- is that it was June or July of 2002 --
19 A. 2002.
20 Q. -- when you met Virginia Roberts at the
21 Mar-a-Lago?
22 A. My recollection.
23 Q. Okay. And other than the fact that you
24 were sweating, what else tells you what month that
25 it was that you remember meeting her at the
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Page 96
1 JOHN ALESSI
2 Mar-a-Lago?
3 A. It was -- I know it was summer of 2002,
4 and she spoke to -- far away. I wasn't -- I was in
5 the driveway, and she was far away talking to
6 Virginia. She spoke to her maybe five minutes.
7 Q. Okay.
8 A. And she came to the car, and we went home.
9 In the afternoon, about 4:00 or 5:00 in the
10 afternoon, the same day, Virginia came to the house.
11 Q. Who brought her to the house?
12 A. I don't know. She came to the back door,
13 I remember. And she was dressed differently. She
14 came to the house.
15 Q. When you first arrived to the Mar-a-Lago
16 with -- are you driving the car and Ms. Maxwell is
17 in the passenger seat?
18 A. Yes.
19 Q. And could you see Virginia Roberts from
20 the car?
21 A. Yes.
22 Q. Where was she sitting or standing? How
23 far away from the car?
24 A. She was standing right in front of the
25 driveway. This is the Mar-a-Lago, the house, and
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)4%-:%''3
Page 97
1 JOHN ALESSI
2 here is the spa, and the driveway that's here. I
3 was parked this way, and I would see her with
4 Ms. Maxwell, talking.
5 Q. Did you --
6 A. I could not hear what they were saying,
7 but I did see it.
8 Q. Did you park the car or did you stop right
9 there and --
10 A. I parked the car because we are not
11 allowed to go into Mar-a-Lago.
12 Q. Okay. Let me finish my question.
13 Did you park the car in a parking space in
14 the parking lot or did you just stop on the side of
15 the road and Ms. Maxwell got out?
16 A. Mar-a-Lago has a -- has a long wide
17 driveway, and on the right of the driveway is -- is
18 the parking spots like this or something. And I
19 parked in one of those spaces. And waiting for her,
20 I think it was over an hour that I wait for her.
21 Q. Okay. So did you watch her first talk
22 to --
23 A. No. At the end. Right at the end,
24 before -- when she was leaving.
25 Q. So Ms. Maxwell gets out of the car. And
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Page 98
1 JOHN ALESSI
2 when you're pulling up to the Mar-a-Lago, could you
3 see Virginia Roberts then?
4 A. No. No.
5 Q. So after you wait an hour, Ms. Maxwell is
6 coming out?
7 A. And then she saw Virginia and she
8 stopped -- she went to her, she talked to her, she
9 came back to the car.
10 Q. And prior to that day, you had never seen
11 Virginia at the house?
12 A. Never. Never.
13 Q. Okay. Did Ms. Maxwell tell you that
14 Virginia's father worked at the Mar-a-Lago?
15 A. I don't think so. I think it was -- I
16 think we find out later, after the -- she says, My
17 father works -- I think it was from Virginia, that
18 she says her father works at Mar-a-Lago.
19 It is information from her. I don't think
20 it was Ms. Maxwell that told me anything. She don't
21 have to -- she don't have to talk to me. I mean,
22 Ms. Maxwell will not go and talk to me about this --
23 these people's family. I don't know. She never
24 did.
25 Q. Okay. I only have to go by what I have.
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Page 103
1 JOHN ALESSI
2 I don't remember that day, how she got
3 home. I don't know. I can't remember.
4 Q. After that day, do you recall that she
5 started coming to the house more frequently?
6 A. Yes, she did.
7 Q. In fact, did she start coming to the house
8 approximately three times a week?
9 A. Yes, probably.
10 Q. And at times, would you go pick her up?
11 A. Yes. This happened maybe twice, three
12 times.
13 Q. And at times, would you take her home?
14 A. Yes.
15 Q. And did there come a point in time where
16 Virginia starting bringing other girls with her?
18 foundation.
19 THE WITNESS: That was maybe two weeks
20 before we left. I saw her bringing some
21 friends with her to the house. And I cannot
22 remember how many times, but I was at the end
23 of our stay.
24 BY MR. EDWARDS:
25 Q. At the end of her [sic] stay, you saw when
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)3%-:%''3
Page 104
1 JOHN ALESSI
2 she would come over to the house, she would bring
3 certain friends who were girls --
5 foundation.
6 BY MR. EDWARDS:
7 Q. -- to the house, right?
8 A. Yes, females, yes.
9 Q. Do you know how long Virginia had been
10 coming over to the house before she started
11 traveling on an airplane with Ghislaine and Jeffrey?
12 MR. PAGLIUSCA: Object to foundation.
13 THE WITNESS: Not too long. I don't think
14 it was too long after that.
15 BY MR. EDWARDS:
16 Q. Would you drive her to the airport with
17 them?
18 A. Occasionally, I think so, yes. I would
19 drive everybody to the airport. My wife would drive
20 the chefs, the service people, the luggage to Jet
21 Aviation.
22 Q. Is that where Mr. Epstein kept his plane,
23 Jet Aviation?
24 A. Yes.
25 Q. At some point did Ghislaine Maxwell become
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Page 141
1 JOHN ALESSI
2 MR. PAGLIUSCA: Seven.
3 MR. EDWARDS: Seven?
7 MR. EDWARDS: I apologize, Jeff. I just
8 can't find a copy right now.
9 MR. PAGLIUSCA: I have it.
10 MR. EDWARDS: Okay.
11 BY MR. EDWARDS:
12 Q. So this is a composite exhibit. It is
13 four pages. The first one that you're looking at
14 should be -- do you have SAO 01456?
15 MR. PAGLIUSCA: Yes.
17 BY MR. EDWARDS:
18 Q. Does the format of this look familiar to
19 you?
20 A. Yes. It looks like the books that we used
21 to have that has -- the message books.
22 Q. How would that work? How would that
23 process work?
24 A. Somebody called, you write it down, and
25 you take the -- you leave the copy in the -- in the
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$);%-:%''3
Page 175
1 JOHN ALESSI
2 many things?
3 A. Yes, she did.
4 Q. Interesting buildings?
5 A. No. She -- she liked -- she had a dog,
6 and she took a lot of photographs of her dog. And
7 us. And she took photographs of the cars and the
8 house. Everything inside. She had an album full of
9 photographs of people, young girls, girls. And I
10 remember that she had. Like a hobby.
11 Q. Right.
12 You never saw any pictures that were very
13 upsetting to you, though, correct?
14 A. No. No.
15 Q. Okay. And the pictures that you saw were
16 sort of -- would you describe them as being artistic
17 kind of pictures?
18 MR. EDWARDS: Objection, counsel
19 testifying.
20 THE WITNESS: I think so. I don't think
21 they were pornographic. I don't think it was
22 any vaginal or things, you know, female parts
23 showing. It was some girls were topless,
24 taking the sun. It was a beautiful house, it
25 was a beautiful setting, so she took a lot of
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Page 236
1 JOHN ALESSI
5
6 that JOHN ALESSI personally appeared before me
and was duly sworn.
this 1st day of June, 2016.
8
9
11 + + + + + + + + + + + + + + + + + +
12 CERTIFICATE
17 foregoing deposition of JOHN ALESSI; that a review
of the transcript was not requested; and that the
18 transcript is a true record of my stenographic
notes.
in the action.
22 Dated this 1st day of June, 2016.
23
25
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)<%-:%''3
EXHIBIT 2
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)6%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$34%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$33%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$37%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$36%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$74%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$73%-:%''3
EXHIBIT 3
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$77%-:%''3
Page 1
FOR THE SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
-against-
GHISLAINE MAXWELL,
Defendant.
___________________________/
250 N. Australian Avenue,

Suite 1400
West Palm Beach, Florida 33401
Friday, September 9, 2016
8:35 a.m. - 2:08 p.m.
VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN
Taken before Darline M. West,

Registered Professional Reporter, Notary Public
in and for the State of Florida At Large,
pursuant to Notice of Taking Deposition filed
by the Plaintiff in the above cause.
MAGNA LEGAL SERVICES

1200 Avenue of the Americas
New York, New York 10026
(866) 624-6221
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7;%-:%''3
Page 74
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Isn't it true that Maxwell led Virginia up
4 to your Palm Beach mansion massage room the first
5 time you met her?
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. You saw Maxwell bringing Virginia up to
11 your room, true, sir?
13 foundation.
15 BY MR. CASSELL:
16 Q. Isn't it true that it was standard
17 operating procedure for Maxwell to bring underage
18 girls up to your room?
20 foundation.
22 BY MR. CASSELL:
23 Q. Isn't it true that it was standard
24 operating procedure for Maxwell to bring underage
25 girls up to your room for you to sexually abuse?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7*%-:%''3
Page 116
3 BY MR. CASSELL:
4 Q. In 2000, Virginia was approached by
5 Maxwell, true?
7 foundation.
9 BY MR. CASSELL:
10 Q. Maxwell was one of the main women whom you
11 used to procure underage girls for sexual activities,
12 true?
14 foundation.
16 BY MR. CASSELL:
17 Q. It was your understanding that Maxwell met
18 Virginia at the Mar-a-Lago Club in Palm Beach in
19 2000, true?
21 foundation.
23 BY MR. CASSELL:
24 Q. In 2000, you were a member of the
25 Mar-a-Lago Club, true?
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Page 117
2 MR. PAGLIUCA: Object to form.
4 BY MR. CASSELL:
5 Q. In 2000, Ms. Maxwell had access to the
6 Mar-a-Lago Club, true?
8 foundation.
10 BY MR. CASSELL:
11 Q. The reason Maxwell had access to the
12 Mar-a-Lago Club in 2000 was because of your
13 connections to the club, true?
15 foundation.
17 BY MR. CASSELL:
18 Q. Maxwell was a primary co-conspirator in
19 your sexual abuse scheme, true?
21 foundation.
23 BY MR. CASSELL:
24 Q. Maxwell was a primary co-conspirator in
25 your sex trafficking scheme, true?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7'%-:%''3
Page 118
3 foundation.
5 BY MR. CASSELL:
6 Q. Maxwell herself regularly participated in
7 your sexual exploitation of minors, true?
9 found.
11 BY MR. CASSELL:
12 Q. In 2000, Maxwell herself regularly
13 participated in your sexual exploitation of minors,
14 true?
16 foundation.
18 BY MR. CASSELL:
19 Q. Maxwell herself regularly participated in
20 your sexual exploitation of Virginia, true?
22 foundation.
24 BY MR. CASSELL:
25 Q. Did Maxwell participate in your sexual
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$76%-:%''3
Page 376
1 REPORTER'S CERTIFICATE
2
STATE OF FLORIDA
3 COUNTY OF PALM BEACH
4
5 I, DARLINE MARIE WEST, RPR, certify that I was
6 authorized to and did stenographically report the
7 foregoing deposition; and that the transcript is a
8 true record thereof.
9
11 employee, attorney, or counsel of any of the parties,
12 nor am I a relative or employee of any of the
13 parties' attorney or counsel connected with the
15 action.
16
17 Dated this 13th day of September 2016.
18
19
20
21 ________________________
22 DARLINE MARIE WEST, RPR
23
24
25
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;4%-:%''3
EXHIBIT 4
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;&%-:%''3

VIRGINIA GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
____________________/
Volume 1 of 2
Pages 1 - 157
Taken at the Instance of the Defendant

Concluded: 1:22 p.m.
PLACE: Southern Reporting Company
(SunTrust Building)
Suite 214

Southern Reporting Company

www.Southernreporting.com - (386)257-3663
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;)%-:%''3
82
1 Q Right?
2 A Yeah.
3 Q And she travelled the world?

4 A Uh-huh (affirmative). Yes.
5 Q Did JJ say there was anything weird about

6 her job?
7 A No.
9 BY MS. MENNINGER:
10 Q Did you know whether she had any massage

11 training?
12 A I did not. Like I said, the past three --

13 three or four years before then, I had no contact
14 with her whatsoever. So I had no clue what she was

15 certified in or had done with her life.
16 Q Okay. I would like to take about a five-

17 or ten-minute break, if that's okay with you.
18 A That's fine.
19 THE VIDEOGRAPHER: The time is 10:13. We
20 are off the record.
21 The time is 10:27. We are back on the

22 record.
23 MS. MENNINGER: All right. I would like

24 to mark as an exhibit now Defendant's
25 Exhibit 4.

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;3%-:%''3
88
1 certain times and stuff. And it would just -- you
2 know, it just did not make sense to me that it it
3 was just a masseuse, you know. Like I said, he's a

4 billionaire. You can afford another masseuse. Why
5 do you need her, you know.

6 Q Do you know whether he --
8 A Let me turn this down.
9 Q Sorry.
10 A I'm sorry.
11 (Briefly off the record.)
12 Q Do you know whether he had other masseuses

13 at the time?
14 A I -- I really don't know. All I know is

15 he would have Virginia, obviously, go out and look
16 for other girls, also, to bring back, as well.

17 Q And how do you know that?
18 A Because she had explained to me that

19 sometimes when she would go out on trips that her
20 and Ms. Maxwell and stuff would go out to, like,
21 clubs and stuff and just try and pick up girls to

22 bring back, so...
23 Q That's what Virginia told you?

24 A Yes.
25 Q All right. Did any of your information --

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;7%-:%''3
89
2 A I thought I muted it.
3 Q Did any of your information come from
4 anywhere other than Virginia?
5 A No.
7 A Like I said, I did not talk -- I did not
8 really speak to any of them other than, you know,
9 hi, how's it going and stuff like that, until I had
10 actually met Jeffrey. And then he was the only one
11 I ever really spoke with. I had met Ms. Maxwell a
12 couple of times, but it was never, like, you know,
13 actual conversations, so...
15 Q All right. Well, let me -- when did you
16 meet Jeffrey?
17 A I'd probably say -- probably a few months
18 after I had moved in with her.
19 Q Okay. And how did you come to meet
20 Jeffrey?
21 A Dropping her off over at his mansion.
22 Q And did you drop her off using her car?
23 A Yes.
24 Q And so she just asked you: Can you take
25 me over there?

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;%-:%''3
90
1 A Yeah.
2 Q And did she tell you where to go?
3 A Yeah. She told where he lived and

4 everything. And then obviously I got to take the
5 car, because she was going somewhere else in the

6 world and did not need it, so...
7 Q You were dropping her off for a multi-day

8 trip?
9 A Yeah. She would normally go about two
10 weeks out of every month, so...

11 Q Two weeks straight?
12 A Yeah. It was two weeks home and two weeks

13 gone, basically.
14 Q Did you always take her to his house,

15 or...
16 A Yeah. Pretty much every time I took her

17 there, it was always to his mansion. I picked her
18 up one time -- maybe it was a couple of times --

19 from the jet stream place. But pretty much every
20 single time it was at the hou- -- at the mansion.
22 Q Okay. So you're -- is that your phone?
23 I'm --
24 A No, it is. I thought I muted it.
25 Q That's okay.

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;*%-:%''3
92
1 talking like that, so...
2 Q Okay. Where did your first conversation
3 with Jeffrey take place?

4 A I'm pretty sure it was in the kitchen or
5 the living room.

6 Q Inside the house?
7 A Yeah, it was inside the house. I've never

8 seen him anywhere else other than in the mansion or
9 getting off the jet.
10 Q So you were allowed to go inside the

11 house --
12 A Yeah.
13 Q -- with Ms. Roberts?
14 A Yeah. But I never went upstairs. I've

15 only been in the kitchen, the living room, and by
16 the pool.
17 Q How many times would you estimate that you
18 had been over to the house?

19 A I mean, at least once every two weeks to
20 drop her off, you know.
21 Q Was there a period of time between 2001

22 and when she left in 2002 where she was not working
23 for Jeffrey?
24 A Yes.
25 Q What period of time was that?

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<%-:%''3
93
1 A It was pretty much, like, when she was
2 actually working as a server. Like, basically
3 because we were trying to not have her go back

4 there. Like, she did not want to go back there.
5 And we were trying to just work without needing his

6 money, you know.
7 Q All right. And if I can re-call up that

8 Exhibit 2, can you see from here when about she was
9 working as a server?
10 A March 4th, '02.

11 Q Do you know about how long she worked
12 there?
13 A I do not. I'm not sure.
14 Q Days? Weeks? Months? Anything?

15 A I really have no clue.
16 Q Okay. How old was Ms. Roberts in 2002, if

17 you know?
18 A I'd probably say, like, 18 or so, maybe.

19 Q If her birthday is in '83 --
20 A Oh, if it's in '83, then I'd say --
21 because I was born in '82, so a year younger than me

22 would be...
23 Q 18, 19?
24 A Yeah, somewhere around there.

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;'%-:%''3
96
1 Q I guess my question is: Did she ever tell
2 you that she had started as a regular masseuse for
3 him and then transitioned to something other than a

4 masseuse?
5 A No. She never said that it transitioned.

6 But she ended up explaining to me what had happened
7 before, so...
8 Q What has -- what is that?
9 A That her and Ms. Maxwell and Jeffrey would
10 obviously be doing stuff, all three of them

11 together. Like I said, that they would all go out
12 to clubs to pick up girls and try and find them to

13 bring back for Jeffrey. And then she told me about
14 how, like I said, her and Ms. Maxwell and Jeffrey

15 were all intimate together on multiple occasions.
16 Q When did she tell you this?

17 A I'm not exactly sure on the dates.
18 Q Was it while you were still together?

19 A Yes.
20 Q Did you -- had you met Ms. Maxwell?
21 A Yeah, I had met her a couple of times.

22 Q When did you meet Ms. Maxwell?
23 A Dates, I'm unsure of. But it was pretty

24 much, like I said, at Jeffrey's house in the
25 kitchen.

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;6%-:%''3
97
1 Q Was it earlier in the time you were with
2 her, or...
3 A It was about -- I'd say about six months

4 or so. I don't know. I'm not exactly positive.
5 Q All right. So at the time you met

6 Ms. Maxwell, had Ms. Roberts already told you that
7 she had been intimate?

8 A No. She had told me about that, I
9 believe, after I had max- -- after I had already met
10 her.
11 Q Okay. And tell me everything that you
12 remember about what Ms. Roberts said about being

13 intimate with Ms. Maxwell and Mr. Epstein at the
14 same time.
15 A I remember her talking about, like,
16 strap-ons and stuff like that. But, I mean, like I

17 said, all the details are not really that clear.
18 But I remember her talking about, like, how they

19 would always be using and stuff like that.
20 Q She and Ms. Maxwell and Mr Epstein would
21 used strap-ons?
23 Q How did you feel about that?

24 A I just -- obviously not happy about it.
25 Q What did you say?

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*4%-:%''3
103
1 A I did not.
2 Q When the FBI interviewed you, did you
3 mention this to them?

4 A I mentioned -- anything they asked me, I
5 did not hold anything back.

6 Q Okay. Do you recall specifically talking
7 about sex with the Prince?

8 A I -- I don't recall talking to them about
9 that, but, I mean, it's -- it could be possible.
10 Q Other than sex with the Prince, is there

11 anyone else that Jeffrey wanted Ms. Roberts to have
12 sex with that she relayed to you?

13 A Mainly, like I said, just Ms. Maxwell and
14 all the other girls.

15 Q Ms. Maxwell wanted -- Jeffrey wanted
16 Virginia to have sex with Ms. Maxwell?

17 A And him, yeah.
18 Q And did she tell you whether she had ever

19 done that?
20 A Yeah. She said that she did.
21 Q And when did she tell you that?

22 A I'm not sure on the date.
23 Q And what did she describe having happened?

24 A I believe I already told you that. With
25 the strap-ons and dildos and everything.

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*&%-:%''3
157
2
STATE OF FLORIDA )
3 )
COUNTY OF VOLUSIA )
4
5
6
action.
13
14
15
16
17
18
19
__________________________________
21
22 By Symantec
23
24
25

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*)%-:%''3
158

VIRGINIA GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
____________________/
Volume 2 of 2
Pages 158 - 258
Taken at the Instance of the Defendant

Concluded: 1:22 p.m.
PLACE: Southern Reporting Company
(SunTrust Building)
Suite 214


!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*3%-:%''3
168
1 A Yes.
2 Q All right. And that belief was based on
3 Virginia telling you that?

4 A And JJ and Michael.
5 Q Okay. So you had heard from some other

6 people, and then later --
7 A Yeah. Before she had come back to the

8 apartment, they said that she was a masseuse for
9 this guy. And then when she came back, she told me.
10 Q All right. Once you started dating her

11 again -- I'm sorry.
12 Prior to dating her. Go back to the first

13 time you were dating her. Did she have money?
14 A No.
15 Q All right. Was she able to afford her own
16 place?
17 A No.
18 Q Was she doing massages, at all?

19 A No.
20 Q All right. Fast forward to the second
21 time when you get back together with her sometime in

22 2001.
24 Q Did she appear to you to have any massage
25 training?

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*7%-:%''3
169
1 A No.
2 Q As a seventeen-year-old at that time, was
3 she able to afford things?

4 MS. MENNINGER: Objection. Form.
5 Foundation.
6 BY MR. EDWARDS:
7 Q Did she have money --

8 A She had money.
9 Q -- while working with Jeff?
10 And was the money in the form of cash?

11 A Yes.
12 Q And did she always have cash?

13 A Yes.
14 Q And how was the apartment paid for?

16 Foundation.
17 A Cash.
18 BY MR. EDWARDS:
19 Q And did you see how she was paying for the
20 apartment?
21 A I did not watch her pay the bill, but...

22 Q Okay. When you would go to dinner, who
23 would pay?
24 A Just whoever.

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*;%-:%''3
200
2 Foundation.
3 A For Jeffrey.
4 BY MR. EDWARDS:
5 Q All right. Let me fix this. Ghislaine --

6 when Ghislaine Maxwell would call you during the
7 time that you were living with Virginia, she would

8 ask you what, specifically?
10 Foundation.
11 A Just if I had found any other girls just
12 to bring to Jeffrey.
13 BY MR. EDWARDS:
14 Q Okay.
15 A Pretty much every time there was a
16 conversation with any of them, it was either asking

17 Virginia where she was at, or asking her to get
18 girls, or asking me to get girls.

19 Q All right. Let's go to that second
20 category you just identified, which is asking
21 Virginia to get girls. How many times were you in a

22 room where specifically Ghislaine Maxwell would ask
23 Virginia to bring girls?

24 A None that I can recall.
25 Q Okay. How many times -- when you say they

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$**%-:%''3
228
1 went with Virginia, and you dropped her off; and
2 some occasions you went inside?
3 A Yeah.
4 Q And some of the occasions you went inside,
5 you hung out by the pool?

6 A Yes.
7 Q Or in the kitchen with the chef?

8 A Yeah.
9 Q All right. And in the total of all the
10 times that you went inside the house, you saw

11 Ms. Maxwell -- I think you got up to six times?
12 A Yeah, about five or six times.

13 Q All right. Total?
14 A Total.
15 Q That's not five or six times where --
16 A That was period, all together.

17 Q -- you brought girls?
18 A No. All together, period.

19 Q All right. I thought you said when I was
20 asking you questions that Ms. Maxwell never asked
21 you to bring girls.

22 A I don't remember saying that.
23 Q Okay. Well, tell me. When did

24 Ms. Maxwell ask you to bring a girl?
25 A Never in person. It was, like, literally,

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*<%-:%''3
229
1 like, on the phone maybe, like, once or twice.
2 Q All right. Did Ms. Maxwell call you
3 frequently?
4 A No.
5 Q All right. How many times do you think

6 Ms. Maxwell called you, at all?
7 A I'd just say that probably a just a few, a

8 couple of times. Maybe once or twice.
9 Q One or two --
10 A The majority of the time it was pretty

11 much his assistant.
12 Q How do you know Ms. Maxwell's voice?

13 A Because she sounds British.
14 Q So someone with a British accent called

15 you once or twice and asked for --
16 A Well, she told me who she was.

17 Q Okay. And what did she say when she
18 called you and asked you to bring girls?

19 A She just said, "Hi. This is Ghislaine.
20 Jeffrey was wondering if you had anybody that could
21 come over."
22 Q Okay. When did that happen?
23 A I'm not exactly sure on the time frame.

24 Q Was it after the Roadhouse Grill or
25 before?

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*'%-:%''3
248
1 Q So the thing that Virginia was tired of --
2 just so that the record is clear -- well, I'll let
3 you answer in your words. Just be clear.

4 What was it that Virginia was trying to
5 get away from and stop with respect to working at

6 Jeffrey Epstein's house?
7 MS. MENNINGER: Objection. Form,

8 foundation -- as to Virginia's thought
9 processes.
10 A To stop being used and abused.

12 Q How do you know that?

14 Foundation.
15 A Due to all the things that I have come
16 to -- that have been brought to light, and in the

17 experiences that I've had, and the conversations
18 that I have had with her. Like, it just all adds up

19 to that, so...
21 Q When Virginia was wanting to get out, did

22 she ever express that it was the times of work that
23 she was trying to get away from?

24 A No.
25 Q Okay. What was she specifically

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*6%-:%''3
251
1 Q Was she getting paid as much as she was
2 getting paid to work for Jeff Epstein?
3 A Definitely not.
4 Q She no longer had cash all around?
5 A Nope.
6 Q You mentioned that there was -- you had
7 several conversations with Virginia when she was

8 discussing them wanting -- or I think the word you
9 used was force, but later we tried to clarify that,
10 but them forcing her to have sex with Prince Andrew.

11 Do you remember that?
12 A Yeah.
13 Q And that you expressed that you were
14 worried for her safety if she were to decline that?

15 A Yes.
16 Q What about your conversation with Virginia

17 on that particular occasion made you worried for
18 Virginia's safety?
19 A Just the way she was talking to me. Like,
20 she just sounded scared.
21 Q And what -- what -- try to dig back and

22 remember what exactly she was saying and how she was
23 saying it, if you could just describe that for us.

24 A She said that she went to go in -- I
25 remember at one time she was talking to me about how

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$<4%-:%''3
258
2
STATE OF FLORIDA )
3 )
COUNTY OF VOLUSIA )
4
5
6
action.
13
14
15
16
17
18
19
__________________________________
21
22 By Symantec
23
24
25

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$<&%-:%''3
EXHIBIT 5
(Filed Under Seal)
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!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&36%-:%''3
EXHIBIT 7
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&74%-:%''3
Page 1

------------------------------------------x
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
June 20, 2016

9:12 a.m.
Deposition of pursuant
offices of Podhurst Orseck, 25 West
Flagler Street, Suite 800, Miami, Florida,
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&7&%-:%''3
Page 54
1 - CONFIDENTIAL
2 BY MR. EDWARDS:
3 Q. When you got to his house, you were
4 requested to give a massage?
5 MR. PAGLIUCA: Object to foundation and
6 form.
7 THE WITNESS: I don't exactly remember. I
8 don't remember if I was asked in the kitchen.
9 I don't remember if -- I don't remember.
10 BY MR. EDWARDS:
11 Q. Massage was part of the game, though?
13 foundation.
14 THE WITNESS: I don't remember. I'm
15 sorry.
16 BY MR. EDWARDS:
17 Q. But even during this deposition today, we
18 have described at times you giving him a massage?
19 A. Yes. You're asking about my first
20 encounter, though.
21 Q. Sorry, I'm just trying to sum up the whole
22 thing.
23 A. Okay.
24 Q. Was massage part of the lure to get you
25 specifically to his house?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&7)%-:%''3
Page 55
1 - CONFIDENTIAL
2 A. Yes.
4 foundation.
5 BY MR. EDWARDS:
6 Q. And at the time, you are 15, 16 or 17
7 years old?
9 foundation.
10 THE WITNESS: Yes.
11 BY MR. EDWARDS:
12 Q. No massage experience?
13 A. No.
14 Q. You were told to bring other girls to his
15 house?
17 foundation.
18 THE WITNESS: After a while, yes.
19 BY MR. EDWARDS:
20 Q. These massages were turned sexual by
21 Jeffrey, as opposed to by anyone else?
22 A. Jeffrey took my clothes off without my
23 consent the first time I met him.
24 Q. The massages were scheduled by people
25 working for Jeffrey?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&73%-:%''3
Page 56
1 - CONFIDENTIAL
4 foundation.
5 BY MR. EDWARDS:
6 Q. Jeffrey Epstein, during these massages,
7 would use sex toys or have sex toys used?
9 foundation.
10 THE WITNESS: Well, at that point, it's no
11 longer a massage. Something else is going on.
12 But, yes, he would take out adult toys and
13 different things.
14 BY MR. EDWARDS:
15 Q. While you were a teenager, Jeffrey Epstein
16 asked you to live with him?
17 A. Yes. He wanted me to be emancipated.
18 Q. Jeffrey Epstein encouraged girl-on-girl
19 sex?
21 foundation.
23 BY MR. EDWARDS:
24 Q. And after you cooperated with the police,
25 you were intimidated by people working for Jeffrey
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&77%-:%''3
Page 57
1 - CONFIDENTIAL
2 Epstein?
4 foundation.
5 THE WITNESS: Yes.
6 MR. EDWARDS: All right. I don't have
7 anything further for you. I apologize that we
8 even had to go through this, all right?
9 THE WITNESS: Okay.
10 E X A M I N A T I O N
11 BY MR. PAGLIUCA:
12 Q. Ms. , by name is Jeff Pagluica. I
13 live in Denver, Colorado. And, like you, I don't
14 want to be here today either, okay? I would rather
15 be in Denver.
16 I just want to -- as I understand it, and
17 I'm not trying to get into any of your treatment
18 over the last, let's say, 10 years, because I don't
19 know how long it's been, but as I understand what
20 you and your lawyer have said here today, you have
21 been involved in some number of years of therapy, in
22 which the purpose -- part of the purpose of the
23 therapy has been to forget all of these events that
24 Mr. Edwards was asking you questions about; is that
25 correct?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&7;%-:%''3
Page 71
1 - CONFIDENTIAL
5
I, the undersigned authority, certify that
6 personally appeared before me and
was duly sworn.
7 WITNESS my hand and official seal this
23rd day of June, 2016.
8
9
11 + + + + + + + + + + + + + + + + + +
12 CERTIFICATE
17 foregoing deposition of that a
stenographic notes.
in the action.
22 Dated this 23rd day of June, 2016.
23
25
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&7*%-:%''3
EXHIBIT 8
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&7<%-:%''3
Page 1
Plaintiff,
v. CASE NO.:15-CV-07433-RWS
GHISLAINE MAXWELL,
Defendants.
_______________________________
January 25, 2017

9:05 a.m. - 12:44 p.m.
401 E. Las Olas Boulevard
Fort Lauderdale, Florida
**** C O N F I D E N T I A L ****
VIDEOTAPE DEPOSITION OF SARAH KELLEN
Taken on behalf of the before

Michael J. D'Amato, RMR, Notary Public in and for the
State of Florida at Large, pursuant to Notice of Taking
Deposition in the above cause.
Job # 293966
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&7'%-:%''3
Page 15
1 decline to answer.
2 Q. Who introduced you to Ghislaine Maxwell?
3 A. On advice of my counsel I must invoke my Fifth
4 and Sixth Amendment privilege which I understand
5 protect the innocent and therefore I must unfortunately
7 Q. When you met Ghislaine Maxwell was she working
8 for Jeffrey Epstein?
13 Q. Did Ghislaine Maxwell work as a recruiter for
14 young girls for Jeffrey Epstein when you met her?
19 Q. I'm defining young girls to mean females the
20 ages 12 to 23. Do you understand that?
25 Q. Didn't Ghislaine Maxwell approach you to
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&76%-:%''3
Page 20
1 girls for sex with Jeffrey Epstein?
6 Q. Did you assist Ghislaine Maxwell in procuring
7 underage girls for sex with Jeffrey Epstein?
12 Q. Isn't it true that Ghislaine Maxwell would
13 recruit underage girls for sex and sex acts with
14 Jeffrey Epstein?
19 Q. Did Ghislaine Maxwell give you information on
20 what underage girls she had contact information for?
25 Q. Did Ghislaine Maxwell teach you to offer these
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;4%-:%''3
Page 199
1 CERTIFICATE OF COURT REPORTER
2 I, MICHAEL J. D'AMATO, a Registered Merit Reporter
3 and Notary Public in and for the State of Florida at
4 Large, do HEREBY CERTIFY that I was authorized to and
5 did stenographically report the deposition of SARAH
6 KELLEN; that a review of the transcript was requested;
7 and that the foregoing transcript, pages from 1 to 197,
8 is a true and accurate record of my stenographic notes.
9 I FURTHER CERTIFY that I am not a relative,
10 employee, attorney, or counsel of any of the parties, nor
11 am I a relative or employee of any of the parties'
12 attorney or counsel connected with the action, nor am I
13 financially interested in the action.
14 Dated this 27th day of January 2017.
15 _______________________
16 MICHAEL J. D'AMATO,
17 Registered Merit Reporter
18
19
20
21
22
23
24
25
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;&%-:%''3
EXHIBIT 9
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;)%-:%''3
Page 1
FOR THE SOUTHERN DISTRICT OF NEW YORK
______________________________________________________
VIDEOTAPE DEPOSITION OF: PETER KENT

November 29, 2016
______________________________________________________
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
______________________________________________________
PURSUANT TO SUBPOENA AND NOTICE, the
videotape deposition of PETER KENT was taken on behalf
of the Plaintiff at 150 East 10th Avenue, Denver,
Colorado 80230, on November 29, 2016, at 9:00 a.m.,
before Sandra L. Bray, Registered Diplomate Reporter,
Certified Realtime Reporter, and Notary Public within
Colorado.

(866) 624-6221
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;3%-:%''3
Page 25
1 MS. McCAWLEY: I'm just asking about his
2 retention, which I believe is discoverable under
3 Rule 26.
4 Q. (BY MS. McCAWLEY) Do you recall whether
5 you were retained to perform work for one expert or
6 two experts?
7 THE DEPONENT: Am I allowed to answer
8 this?
9 MR. PAGLIUCA: Yes.
10 A. I actually don't recall.
11 Q. (BY MS. McCAWLEY) Do you know whether
12 you were provided with one report or two reports when
13 you initially were retained?
14 A. I believe I was provided with both the
15 reports at the same time.
16 Q. Let me turn to about halfway back. So
17 it's going to be -- there's markings on the bottom.
18 It says PK-005.
19 A. Yes.
20 Q. And it indicates an amount there, an
21 invoice. Is this one of your invoices?
22 A. Yes.
23 Q. It indicates an amount of $17,875?
24 A. Yes.
25 Q. Is that the total amount you've been
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;7%-:%''3
Page 26
1 paid, with the exception of what we paid you for your
2 testimony here today, in this matter?
3 A. I think so. What date was this?
4 Q. It looks like it's dated October 29th,
5 2016.
6 A. Oh, yes. In that case, yes.
7 Q. Have you performed any work after that
8 date that you've been paid for?
9 A. Only in preparation for this deposition.
10 Q. Have you been paid for that work?
11 A. No.
12 Q. No. Have you invoiced that work yet?
13 A. No.
14 Q. All right. And then I'm going to turn
15 you to the next page -- please don't put it away
16 yet -- which appear to be invoices.
17 A. Time sheets.
18 Q. Time sheets? You tell me.
19 A. It's a time sheet.
20 Q. Is this typically how you record your
21 time when you're doing expert work?
22 A. Yes.
23 Q. And this indicates -- the first entry is
24 on 9/28/2016. Is that when you commenced work on this
25 matter?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;;%-:%''3
Page 162
REPORTER'S CERTIFICATE
STATE OF COLORADO )
) ss.
CITY AND COUNTY OF DENVER )
I, SANDRA L. BRAY, Registered Diplomate

Reporter, Certified Realtime Reporter, and Notary
Public ID 20084001729, State of Colorado, do hereby
certify that previous to the commencement of the
examination, the said PETER KENT was duly sworn by me
to testify to the truth in relations to the matters in
controversy between the parties hereto; that the said
deposition was taken in machine shorthand by me at the
time and place aforesaid and was thereafter reduced to
typewritten form; that the foregoing is a true
transcript of the questions asked, testimony given,
and proceedings had.
I further certify that I am not employed by,

related to, nor of counsel for any of the parties
herein nor otherwise interested in the outcome of this
litigation.
IN WITNESS WHEREOF, I have affixed my
signature this 8th of December, 2016.
My commission expires January 16, 2020.
__X__ Reading and Signing was requested.
_____ Reading and Signing was waived.
_____ Reading and Signing is not required.

!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;*%-:%''3
EXHIBIT 10
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;<%-:%''3
Page 1

- - - - - - - - - - - - - - - - - - - - x
Plaintiff,
Case No.: 15-cv-07433-RWS
-against-
GHISLAINE MAXWELL,
Defendant.
- - - - - - - - - - - - - - - - - - - - x
Videotaped oral deposition of NADIA

MARCINKO, taken pursuant to notice, was
held at the law offices of BOIES
SCHILLER & FLEXNER, LLP, 575 Lexington
Avenue, New York, New York commencing
January 17, 2017, 1:04 p.m., before
Leslie Fagin, a Court Reporter and
Notary Public in the State of New York.
- - -

(866) 624-6221
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;'%-:%''3
Page 10
1 N. Marcinko - Confidential
2 reside, a dwelling that is paid for by either
3 Jeffrey Epstein or Ghislaine Maxwell?
4 A. Same answer.
5 Q. Do you know Jeffrey Epstein?
6 A. Same answer.
7 Q. Do you know Ghislaine Maxwell?
8 A. Same answer.
9 Q. How old were you when you met
10 either Jeffrey Epstein or Ghislaine Maxwell?
11 A. Same answer.
12 Q. Who introduced to you Ghislaine
13 Maxwell?
14 A. Same answer.
15 Q. When you met Ghislaine Maxwell, was
16 she working for Jeffrey Epstein?
17 A. Same answer.
18 Q. Did Ghislaine Maxwell work as a
19 recruiter of young girls for Jeffrey Epstein
20 when you met her?
21 A. Same answer.
22 Q. Did Ghislaine Maxwell instruct you
23 to recruit young girls for Jeffrey Epstein?
24 A. Same answer.
25 Q. Did Ghislaine Maxwell encourage
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&;6%-:%''3
Page 12
1 N. Marcinko - Confidential
2 Ghislaine Maxwell?
3 A. Same answer.
4 Q. Have you observed Ghislaine Maxwell
5 and Jeffrey Epstein offering these young
6 girls money, education or other things of
7 value during the massage to get that young
8 girl to return to Jeffrey Epstein for sexual
9 purposes?
10 A. Same answer.
11 Q. Have you observed Ghislaine Maxwell
12 and Jeffrey Epstein convert what started as a
13 massage with these young girls into something
14 sexual?
15 A. Same answer.
16 Q. Have you understood when I talk
17 about young girls, I'm talking about girls
18 between the age range of 13 and 23 years old?
19 A. Same answer.
20 Q. Have you observed that when
21 Ghislaine Maxwell and Jeffrey Epstein used
22 the term, massage, it always includes sex?
23 A. Same answer.
24 Q. Was massage a word used by
25 Ghislaine Maxwell to lure girls into sex with
Page 96
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&*&%-:%''3
EXHIBIT 11
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&*)%-:%''3
Page 1

- - - - - - - - - - - - - - - - - - - - x
Plaintiff,
Case No.:
-against- 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendants.
- - - - - - - - - - - - - - - - - - - - x
**CONFIDENTIAL**
Videotaped deposition of GHISLAINE

MAXWELL, taken pursuant to subpoena, was
held at the law offices of BOIES
SCHILLER & FLEXNER, 575 Lexington
Avenue, New York, New York, commencing
April 22, 2016, 9:04 a.m., on the above
date, before Leslie Fagin, a Court
Reporter and Notary Public in the State
of New York.
- - -
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Page 23
1 G Maxwell - Confidential
2 Q. I'm not talking about friends. I'm
3 talking about individuals --
4 MR. PAGLIUCA: I'm going to object
5 to you interrupting the witness who was
6 answering your question. The question
7 was, have you ever seen anyone, female
8 under the age of 18 at the house and
9 that's the question she was answering.
10 If you want to strike that question and
11 ask another question, feel free, but let
12 the witness respond, please.
13 MS. McCAWLEY: I will do that.
14 Q. Have you ever observed a female
15 under the age of 18 at Jeffrey Epstein's home
16 that was not a friend, a child -- one of your
17 friend's children?
18 A. Again, I can't testify to that
19 because I have no idea what you are talking
20 about.
21 Q. You have no idea what I'm talking
22 about in the sense you never observed a
23 female under the age of 18 at Jeffrey
24 Epstein's home that was not one of your
25 friend's children, is that correct?
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2 MR. PAGLIUCA: Object to the form
3 and foundation.
4 A. How would I possibly know how
5 someone is when they are at his house. You
6 are asking me to do that. I cannot possibly
7 testify to that. As far as I'm concerned,
8 everyone who came to his house was an adult
9 professional person.
10 Q. Are you familiar with the police
11 report that was issued in respect to the
12 investigation in this matter?
14 and foundation.
15 Q. Are you familiar with the police
16 report that was used in this matter, the
17 investigation of Jeffrey Epstein, has been
18 produced as a document in this matter?
19 A. I have seen a police report.
20 (Maxwell Exhibit 1, police report,
21 marked for identification.)
22 Q. The police report that you have in
23 front of you, can you turn to page 28 of that
24 report, the numbers are on the top right-hand
25 corner.
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2 -- just another one of Virginia's many
3 fictitious lies and stories to make this a
4 salacious event to get interest and press.
5 It's absolute rubbish.
6 Q. Were you in charge of hiring
7 individuals to provide massages for Jeffrey
8 Epstein?
9 A. My job included hiring many people.
10 There were six homes. As I sit here, I hired
11 assistants, I hired architects, I hired
12 decorators, I hired cooks, I hired cleaners,
13 I hired gardeners, I hired pool people, I
14 hired pilots, I hired all sorts of people.
15 In the course and a very small part
16 of my job was from from time to time to find
17 adult professional massage therapists for
18 Jeffrey.
19 Q. When you say adult professional
20 massage therapists, where did you find these
21 massage therapists?
22 A. From time to time I would visit
23 professional spas, I would receive a massage
24 and if the massage was good I would ask that
25 man or woman if they did home visits.
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2 Q. Did you hire her?
3 A. First of all, I don't hire girls
4 like that, so let's be clear, I already
5 testified to that, and I have no idea what
6 you are referring to.
7 Q. When you say girls like that, what
8 do you mean?
9 A. I hire people who are professional
10 at the house. You are asking if I hired
11 somebody to do what, I don't know what you
12 are talking about. I hired people to work in
13 the homes.
14 Q. What was Nadia Marcinkova doing?
16 and foundation.
17 A. I have no idea what Nadia
18 Marcinkova was doing. I didn't hire her and
19 I don't know what you are referring to.
20 Q. You met Nadia Marcinkova?
21 A. I testified I did.
22 Q. Did she work for Jeffrey Epstein?
23 A. I have no idea what she did.
24 Q. Have you flown on planes with Nadia
25 Marcinkova?
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2 MR. PAGLIUCA: Objection to the
3 form and foundation.
4 A. I don't know what that means,
5 masseuse obligation, I don't know what you
6 are referring to. Would you like to ask the
7 question properly?
8 Q. I think it was proper. I will ask
9 it again.
10 Did you ever assist in getting
11 Virginia Roberts a cell phone to use during
12 the time that she worked for Jeffrey Epstein?
13 A. I have no recollection of doing
14 anything of that nature.
15 Q. Did you ever tell Virginia that you
16 wanted her to have a cell phone so that she
17 could be on call regularly?
18 A. I have no recollection of that
19 conversation.
20 Q. How often would Virginia come over
21 to the house in Palm Beach to give massages?
24 A. Ask the question again, please.
25 Q. How often did Virginia Roberts come
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2 over to the house in Palm Beach to give
3 massages?
4 A. It's important to understand that I
5 wasn't with Jeffrey all the time. In fact, I
6 was only in the house less than half the
7 time, so I cannot testify to when I wasn't in
8 the house how often she came when I wasn't
9 there.
10 What I can say is that I barely
11 would remember her, if not for all of this
12 rubbish, I probably wouldn't remember her at
13 all, except she did come from time to time
14 but I don't recollect her coming as often as
15 she portrayed herself.
16 Q. How many times a day on an average
17 day would Jeffrey Epstein get a massage?
20 A. When I was at the house and when I
21 was there with him, he received a massage, on
22 average, about once a day.
23 Q. Just once?
24 A. Yes.
25 Q. Were there days when he received
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2 four or five?
5 A. When I was present at the house, I
6 never saw something like that.
7 Q. Do you know if Virginia was
8 required to be on call at all times to come
9 to the house if Jeffrey wanted her there?
12 A. I have no idea of the arrangements
13 that Virginia made with Jeffrey.
14 Q. When Virginia was in New York,
15 would Virginia sleep at Jeffrey's mansion in
16 New York?
19 A. I don't recollect her being in New
20 York and I have no idea where she slept.
21 Q. You don't ever remember seeing
22 Virginia Roberts in New York?
25 A. I would barely recollect her at
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2 him at any of those homes?
3 A. Again, Virginia is absolutely
4 totally lying. This is a subject of
5 defamation about Virginia and the lies she
6 has told and one of lies she told was that
7 President Clinton was on the island where I
8 was present. Absolutely 1000 percent that is
9 a flat out total fabrication and lie.
10 Q. You did fly on planes, Jeffrey
11 Epstein's planes with President Clinton, is
12 that correct?
13 A. I have flown, yes.
14 Q. Would it be fair to say that
15 President Clinton and Jeffrey are friends?
16 A. I wouldn't be able to characterize
17 it like that, no.
18 Q. Are they acquaintances?
19 A. I wouldn't categorize it.
20 Q. He just allowed him to use his
21 plane?
22 A. I couldn't categorize Jeffrey's
23 relationship.
24 Q. When you were on the plane with
25 Jeffrey and President Clinton, did you
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2 building that you would have seen when you
3 were on the trip in Europe?
6 A. I can't possibly answer that.
7 Q. Do you recall Virginia ever taking
8 pictures?
9 A. I barely recall Virginia, period.
10 Q. Do you recall her ever taking
11 pictures?
12 A. No, I don't.
13 Q. I'm going to direct your attention,
14 still within the flight logs to -- starting
15 on the next page from where you just were
16 which is going to be 000747. And the date at
17 the top says 2001, you will see March and I'm
18 directing your attention down towards the
19 middle to the bottom where you will see the
20 numbers 27, 29 and 31.
21 A. Uh-huh.
22 Q. And we've got actually I'm going to
23 direct your attention to the one that starts
24 with TEB for Teterboro to SAF for Santa Fe
25 and the one below it Santa Fe to Palm Beach
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2 her but you would have to ask Jeffrey what he
3 brought her on the trip for.
4 Q. But she would travel with him when
5 there was a work trip like this?
6 A. I can't -- I'm seeing that she is
7 on this flight but I have no idea what she is
8 doing, he invited her, it would not be my
9 job.
10 Q. What about Nadia Bjorlin, would she
11 regularly travel with Jeffrey on flights?
12 A. I have no idea, you would have to
13 look through the flight logs. I have no
14 idea.
15 Q. Your recollection is -- what is
16 your recollection, do you recollect Nadia
17 traveling often on flights with Jeffrey?
18 A. Absolutely not. No, not at all. I
19 don't recollect her actually on the flight at
20 all.
21 Q. I think you can set that aside for
22 the moment.
23 (Maxwell Exhibit 9, message pad
24 pages, marked for identification.)
25 Q. We will mark as Exhibit 9 these
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2 excerpts from -- we will identify what they
3 are but from the message pads.
4 Did you want to correct anything?
5 A. I want to make an addendum.
6 Would you mind rereading the last
7 question back to me?
8 (Record read.)
9 A. I also just want to say that at
10 this point I cannot recollect flying to
11 parties. Jeffrey went for work so -- was
12 this in Santa Fe, this flight as well.
13 Q. The flight we were looking at, yes
14 but it was to Santa Fe --
15 A. I don't recall going to any parties
16 in Santa Fe at any time but certainly flying
17 to Santa Fe for a party seems highly
18 improbable.
19 Q. So I'm going to direct your
20 attention to the document that I set before
21 you which is Bates number SAO 01456 and it
22 has different Bates numbers because it's a
23 smaller version of the larger production.
24 These are the pages I will be asking about.
25 In the time that you were working
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2 with Jeffrey in Palm Beach, do you recall a
3 process for taking, anybody at the house
4 taking messages when incoming phone calls
5 came in?
6 A. You are supposed to take a message
7 and receive the message and write the message
8 down. Who was the message was for, what time
9 it was taken and who took it and what the
10 message was, obviously.
11 Q. Does what's in front of you look
12 familiar with respect to the message pads
13 that you would have used at the house?
14 A. It is familiar.
15 Q. I'm going to direct your attention
16 to the second page of it?
17 MR. PAGLIUCA: These all have SAO
18 numbers on them or Bates ranges and I
19 don't see any of your Bates ranges on
20 these. I know you have produced message
21 pads but those have your Bates range
22 numbers on them and I'm wondering if
23 these are different documents.
24 MS. McCAWLEY: It's the same, just
25 ours have the Bates underneath them.
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2 believe. Do you believe --
3 A. I can only testify --
4 Q. Let me finish the question so the
5 record is clear.
6 Do you believe Jeffrey Epstein
7 sexually abused minors?
10 Q. You can answer.
11 A. I can only testify to what I know.
12 I know that Virginia is a liar and I know
13 what she testified is a lie. So I can only
14 testify to what I know to be a falsehood and
15 half those falsehoods are enormous and so I
16 can only categorically deny everything she
17 has said and that is the only thing I can
18 talk about because I have no knowledge of
19 anything else.
20 Q. I'm not asking about Virginia. I'm
21 asking whether you believe that Jeffrey
22 Epstein sexually abused minors?
23 A. Again, I repeat, I can only go on
24 what I know and what I know is a falsehood
25 based on what Virginia said.
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2 What I'm asking you is whether you
3 believe Jeffrey Epstein abused minors?
4 MR. PAGLIUCA: I object to the form
5 and you made your record, she answered
6 the question. A fair reading of her
7 answer is she doesn't have a belief
8 because she doesn't have any personal
9 knowledge.
10 MS. McCAWLEY: Now you are
11 testifying for the witness. Let her
12 answer the question.
13 MR. PAGLIUCA: It's a fair answer
14 to the question.
15 A. Again, I testified my only personal
16 knowledge concerns Virginia and everything
17 Virginia has said is an absolute lie, which
18 is why we are here in this room. If you are
19 asking me to testify about things I have no
20 knowledge of other than the police report
21 that you showed me, I am not in a position to
22 make a statement based on that because you
23 are asking me to speculate and I cannot
24 speculate.
25 Q. I'm asking you about your belief.
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2 I'm not asking you to speculate at all. I'm
3 asking what you believe.
4 A. You are asking me to speculate and
5 I won't speculate.
6 Q. I'm not asking you to speculate.
7 I'm asking what you believe.
8 MR. PAGLIUCA: She answered the
9 question and we can move on.
10 MS. McCAWLEY: She hasn't answered
11 the question.
12 MR. PAGLIUCA: We are not going to
13 engage in this debate. She answered the
14 question. If you want to mark it and
15 move to compel an answer to the
16 question, have at it. Okay.
17 Q. Ms. Maxwell, is it your belief that
18 Jeffrey Epstein interacted sexually with
19 minors?
20 A. Again, you are asking me the same
21 type of question exactly but with different
22 language. Again, my only knowledge of
23 somebody who claims these things that I have
24 personal knowledge of is Virginia. Virginia
25 is an absolute liar and everything she has
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&<'%-:%''3
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2 said is a lie. Therefore, based on those
3 lies I cannot speculate on what anybody else
4 did or didn't do because if Virginia is the
5 example of what that story is and everything
6 she said is false, so everything that leads
7 from that is false.
8 Q. So the 30 other minor children in
9 the police report are also telling lies about
10 being sexually abused during massages with
11 Mr. Epstein?
13 form and foundation. Counsel, can you
14 show me in these police reports who the
15 30 minors are?
16 MS. McCAWLEY: I'm asking my
17 question.
18 MR. PAGLIUCA: You are making a
19 representation about numbers, you are
20 making a representation on the record
21 about what people said or didn't say.
22 We have no knowledge about that. These
23 are all redacted records so these are
24 bad questions. They don't lead to any
25 admissible evidence. It is only being
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2 A. I'm carrying on.
3 Q. I'm sorry. I thought you were
4 done.
5 A. Please. Her statement also that
6 she was driven by her father to Palm Beach.
7 She was driven by her mother, as a matter of
8 fact. Her whole entire characterization of
9 the first meeting with Jeffrey, as I was
10 outside speaking to her mother.
11 Q. Let me stop you there, so we don't
12 get too far ahead. Let me make sure I
13 understand your testimony.
14 The first, in the first piece when
15 you were talking, I believe you said and
16 correct me if I'm wrong, that her
17 characterization of the first meeting at
18 Mar-a-Lago was an obvious lie.
19 What part of that meeting was an
20 obvious lie?
21 A. By her own testimony, all her
22 various many different descriptions of what
23 she was or wasn't or where she was or wasn't,
24 they have all changed. She was either front
25 of house or bathroom attendant. I don't know
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2 what she was, so just by her own words, one
3 doesn't know what's true and what isn't true.
4 Q. Are you saying what position she
5 said she was working in, is that what you are
6 considering the obvious lie?
7 A. I said inconsistency within her own
8 statement from everything, so in the
9 beginning it starts off with different
10 statements.
11 Q. Then I believe you said the second
12 piece was that she was driven by her father?
13 A. I said she was driven by her
14 mother.
15 Q. That's the obvious lie?
16 A. It's an obvious lie to me.
17 Q. You said why don't you state it in
18 your own words but the characterization of
19 how she was with Jeffrey, what about that is
20 an obvious lie?
21 A. I was standing outside talking to
22 her mother so the entire story is a
23 fabrication.
24 Q. Did she not have sex with Jeffrey
25 Epstein during that first massage?
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2 up to the room and start a massage?
3 A. He would not.
4 Q. So the young girls in the police
5 report who say they came over and were led up
6 to the room on the first day, would they be
7 wrong about that?
8 MR. PAGLIUCA: Objection to form
9 and foundation.
10 A. I can't comment what happened when
11 I was not at the house. I can only comment
12 when I was at the house.
13 Q. Was there ever a time where a woman
14 came to the house for the first time to give
15 a massage and Jeffrey had the massage that
16 day?
19 A. Can we talk about adult
20 professional masseuses, please?
21 Q. I'm asking, whether adult or
22 underage?
23 A. I'm not interested in talking about
24 underage. I can only testify to what I know,
25 professional masseuses, adult, I cannot
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2 testify to anything else.
3 Q. Why can't you testify to an
4 underage girl that came over and was led up
5 to the room for a massage?
8 A. The police records you are
9 referring to?
10 Q. You are saying that didn't happen.
11 You're saying I can only testify to adults
12 that came for an interview and were led up to
13 the room. Why can't you testify to whether
14 an underage girl was brought in for an
15 interview and led up --
18 Q. Go ahead.
19 A. Can you reask the question.
20 Q. Why can't you testify as to an
21 underage girl who came over for an interview
22 and then was then led up to the room for the
23 massage?
24 A. You've mangled your entire
25 question. Can you please reask that in a way
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2 present at the home when a girl under the age
3 of 18 came over for the purposes of giving a
4 massage?
8 A. You can be a professional masseuse
9 at 17 in Florida, so as far as I am aware, a
10 professional masseuse showed up for a
11 massage. There is nothing inappropriate or
12 incorrect about that and your
13 mischaracterization of it, I think is
14 unfortunate.
15 Q. How many teenagers did he have that
16 were professional masseuses that worked in
17 his home?
20 Q. How many?
21 A. First of all, I am not aware of
22 teenagers who worked in his home.
23 Q. You are aware of Virginia Roberts
24 and you've stated she was 17 and she worked
25 for him, correct?
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2 A. No. I did not state that at all,
3 you are mischaracterizing my words and what I
4 said.
5 What I said was that we can all
6 agree and I think at this point there is not
7 one person in this room, however much you
8 would like her to be younger, to say she was
9 not 17 because that has been a very offensive
10 thing that you have all done. So she was 17.
11 At 17 you are allowed to be a professional
12 masseuse and as far as I'm concerned, she was
13 a professional masseuse. There is nothing
14 inappropriate or incorrect about her coming
15 at that time to give a massage. Her entire
16 characterization of her first time at the
17 house was to me an obvious lie, given it was
18 impossible for her entire story to take place
19 given I was speaking to her mother the entire
20 she was at the house.
21 Q. So it was impossible that day, that
22 first day she came and you were speaking to
23 the mother, for Virginia Roberts to have had
24 sex with Jeffrey Epstein during the time that
25 you were outside with her mother?
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2 absolutely 1000 percent that she did not have
3 any type of sexual relations as described by
4 you in your court papers that took place
5 because those allegedly according to her lies
6 involved some aspect of me.
7 As I was standing outside with her
8 mother the entire time, her entire story is a
9 lie. Therefore, to ask me what she did or
10 didn't do during that time, I can only
11 testify to what she said about me, which was
12 1000 percent false.
13 Q. So let's not take the first time,
14 let's take the next time she comes.
15 A. No no, how can do you that, when
16 the basis of this entire horrible story that
17 you have put out is based on this first
18 appalling story that was written, repeated,
19 multiply by the press that lied about her
20 age, lied about the first time she came, lied
21 about and characterized the entire first
22 time. I have been so absolutely appalled by
23 her story and appalled by the entire
24 characterization of it and I apologize
25 sincerely for my banging at the table
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2 earlier, I hope you accept my apology. It's
3 borne out of years of feeling the pressure of
4 this entire lie that she has perpetrated from
5 our first time and whilst I recognize that
6 was -- I hope you forgive me sincerely
7 because it was just the length of time that
8 that terrible story has been told and retold
9 and rehashed when I know it to be 100 percent
10 false.
11 Q. So not the first time she came, but
12 the second time she came or the third time or
13 any time she came, did you ever participate
14 in a massage with her in Jeffrey Epstein's
15 room?
16 A. I have never participated at any
17 time with Virginia in a massage with Jeffrey.
18 Q. Have you ever participated at any
19 time with Virginia in any kind of sexual
20 contact or sexual touching with Jeffrey and
21 Virginia?
22 A. I have not.
23 Q. So we were going through the list
24 of obvious lies and you were talking about
25 the first time which I believe we have
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2 of 18?
3 A. I think we can establish what adult
4 would be.
5 Q. You never interviewed or I know you
6 don't want to use the word hired, whatever
7 your role was, you brought in an exercise
8 instructor that was under the age of 18 to
9 work at the house?
11 and foundation.
12 A. I have already testified that what
13 I was responsible for was to find people who
14 had competencies in whatever area I was
15 looking for. The competencies I was looking
16 for were professional and adult.
17 Q. So there was no exercise instructor
18 that worked at the Palm Beach house or the
19 New York house or the New Mexico house or the
20 USVI under the age of 18?
23 A. I can only testify to when I was at
24 the house.
25 Q. Yes.
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4 A. That's not how I would characterize
5 that.
6 Q. How would you characterize it?
7 A. I have testified that I'm
8 responsible for finding professional people
9 to work in the homes, age appropriate adult
10 people, so from pool attendants, to
11 gardeners, to chefs, to housekeepers, to
12 butlers, to chauffeurs and one of the
13 functions was to be able to answer the
14 telephones and in the context of finding
15 someone to answer the telephones, I did look
16 to try to find appropriate people to answer
17 the phones.
18 Q. So did you find Johanna for
19 purposes of that role?
20 A. So in the course of looking for
21 somebody to answer phones at the house,
22 Johanna was one of the people who said that
23 she was willing to answer phones.
24 Q. Did you approach her at her school
25 campus?
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2 Q. List all of the girls you met and
3 brought to Jeffrey Epstein's home for the
4 purposes of employment that were under the
5 age of 18?
8 A. I've already characterized my job
9 was to find people, adults, professional
10 people to do the jobs I listed before; pool
11 person, secretary, house person, chef, pilot,
12 architect.
13 Q. I'm asking about individuals under
14 the age of 18, not adult persons, people
15 under the age of 18.
16 A. I looked for people or tried to
17 find people to fill professional jobs in
18 professional situations.
19 Q. So Virginia Roberts was under the
20 age of 18, correct?
21 A. I think we've established that
22 Virginia was 17.
23 Q. Is she the -- sorry, go ahead.
24 Is she the only individual that you
25 met for purposes of hiring someone for
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&64%-:%''3
Page 390
3 and foundation.
4 A. If you want to ask Jeffrey
5 questions about me, you would have to ask
6 him.
7 Q. Have you ever been involved in any
8 illegal activity in your lifetime?
11 A. I can't think of anything I have
12 done that is illegal.
13 Q. Have you ever been arrested?
14 A. I have a DUI in the U.K. a long
15 time ago.
16 Q. Is that the only arrest you have on
17 your record?
18 A. Yes.
19 Q. I will mark as Maxwell 22 this
20 email?
21 (Maxwell Exhibit 22, email, marked
22 for identification.)
23 Q. This is dated January 21, 2015.
24 It's from Jeffrey Epstein to you, forwarding
25 the Guardian and I would like you to look at
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&6&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&6)%-:%''3
Confidential
Page 1

- - - - - - - - - - - - - - - - - - - - x
Plaintiff,
Case No.:
GHISLAINE MAXWELL,
Defendant.
- - - - - - - - - - - - - - - - - - - - x
**CONFIDENTIAL**
Continued Videotaped Deposition of

GHISLAINE MAXWELL, the Defendant herein,
taken pursuant to subpoena, was held at
the law offices of Boies, Schiller &
Flexner, LLP, 575 Lexington Avenue, New
York, New York, commencing July 22,
2016, 9:04 a.m., on the above date,
before Leslie Fagin, a Court Reporter
and Notary Public in the State of New
York.
- - -
(866) 624-6221
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&63%-:%''3
Confidential
Page 44
1 G. Maxwell - Confidential
2 thought. I really don't recall her, so it's
3 hard for me to testify what I thought about
4 her age at the time.
5 Q. Was Virginia, in the period of
6 around 2000, the youngest person that, as you
7 understood it, was giving Mr. Epstein
8 massages?
10 and foundation.
11 A. Again, I can't testify to her age,
12 but everybody else that I can recall seemed
13 to be again, like I would say, adults.
14 Q. You didn't think Virginia was an
15 adult, did you?
17 and foundation.
18 A. Like I said, I don't recall her. I
19 don't recall thinking about -- my memory is
20 of adults giving Jeffrey massages, and as I
21 don't really remember Virginia around that
22 time, I don't know what I think.
23 Q. You do remember Virginia, about
24 that time back in the 2000s, giving
25 Mr. Epstein massages?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&67%-:%''3
Confidential
Page 45
3 and foundation.
4 A. I barely remember her at all.
5 Q. Whether you barely remember her or
6 not, you do remember that back in the period
7 around 2000, Virginia was giving Mr. Epstein
8 massages, right?
10 and foundation.
11 A. Only in the most general terms. It
12 would be somebody who would give him a
13 massage, and that's it.
14 Q. During the period of time back in
15 the period around 2000, when you knew that
16 Virginia was somebody who would give
17 Mr. Epstein a massage, was she somebody who
18 you considered an adult?
20 and foundation.
21 A. I didn't consider her at all
22 because she is not somebody that I really
23 interacted with.
24 Q. It is your testimony that Virginia
25 was not somebody that you interacted with, is
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&6;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&6*%-:%''3
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!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&6'%-:%''3
Confidential
Page 58
2 Q.
11
20
22 and foundation.
23
24
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$&66%-:%''3
Confidential
Page 86
2 and foundation.
3 A. No.
4 Q.

9 and foundation.
10 A. I don't know.
11

18 and foundation. Asked and answered.
19 A. No.
20 Q. Were they ever in the Virgin
21 Islands?
23 and foundation.
24 A. No.
25
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)44%-:%''3
Confidential
Page 87
1
17
23
25 and foundation.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)4&%-:%''3
Confidential
Page 91
2 it to something in the case.
3 MR. BOIES: I think it's tied, but
4 if you instruct her not to answer, it
5 goes into the --
6 MR. PAGLIUCA: Meat grinder.
7 BY MR. BOIES:
8 Q.
.
14 A. Can you repeat the question?
15 Q.
20 MR. PAGLIUCA: Same objection.

21 A. No.
22 Q.
24
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(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)&4%-:%''3
Page 1

------------------------------------------x
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
June 21, 2016

9:17 a.m.
Deposition of JOSEPH RECAREY, pursuant
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)&&%-:%''3
Page 25
2 BY MR. EDWARDS:
3 Q. All right.
4 Was SG a licensed massage therapist?
6 foundation.
7 THE WITNESS: No.
8 BY MR. EDWARDS:
9 Q. And at 14 years old, are you permitted to
10 be a licensed massage therapist?
11 A. Not to my knowledge.
12 Q. After speaking with SG and understanding
13 her account of what took place at Jeffrey Epstein's
14 home, what -- what happened next in the
15 investigation?
16 A. At some point the investigation was turned
17 over to me for follow-up. I know there was trash
18 pulled that was done prior to -- and surveillance
19 that was done prior to the case being turned over to
20 me; and trash pulls being an investigative technique
21 to acquire intelligence, information and evidence.
22 Q. Okay. If we go to page 17, at the top,
23 and, first of all, I will ask you from memory, do
24 you remember if identified Jeffrey
25 Epstein in a photo lineup?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)&)%-:%''3
Page 27
2 "a cross-reference"?
3 A. Uh-huh.
4 Q. How is a cross-reference performed? What
5 does that mean?
6 A. When -- when something is
7 cross-referenced, they -- they jot down license
8 plate numbers. They conduct their background into
9 the individuals; photographs, computer research.
10 Q. A cross-reference of Jeffrey Epstein's
11 residence revealed which affiliated names?
12 A. It revealed Nadia Marcinkova, Ghislane
13 Maxwell, Mark Epstein. Also, the cross-reference,
14 any previous reports from the residence as well.
15 Q. During your investigation, did you learn
16 of any involvement that Nadia Marcinkova had with
17 any of the activities you were investigating?
19 foundation.
21 BY MR. EDWARDS:
22 Q. And what involvement did you learn of
23 Nadia Marcinkova?
25 foundation.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)&3%-:%''3
Page 28
2 THE WITNESS: Nadia was involved sexually
3 with one of the victims at Epstein's request.
4 BY MR. EDWARDS:
5 Q. Okay. Do you remember which victim you're
6 remembering right now?
7 A. AH.
8 Q. Okay. If it indicates in the report that
9 she was also sexually involved with other victims,
10 is that possible as well?
11 A. Yes.
13 foundation.
14 BY MR. EDWARDS:
15 Q. Okay. The one that you remember in your
16 mind is AH?
18 foundation.
20 BY MR. EDWARDS:
21 Q. The other name that is on here as a
22 cross-reference is Ghislane Maxwell.
23 Did you speak with Ghislane Maxwell?
24 A. I did not.
25 Q. Did you ever attempt to speak with
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)&7%-:%''3
Page 29
2 Ghislane Maxwell?
3 A. I wanted to speak with everyone related to
4 this home, including Ms. Maxwell. My contact was
5 through Gus, Attorney Gus Fronstin, at the time, who
6 initially had told me that he would make everyone
7 available for an interview. And subsequent
8 conversations later, no one was available for
9 interview and everybody had an attorney, and I was
10 not going to be able to speak with them.
11 Q. Okay. During your investigation, what did
12 you learn in terms of Ghislane Maxwell's
13 involvement, if any?
15 foundation.
16 THE WITNESS: Ms. Maxwell, during her
17 research, was found to be Epstein's long-time
18 friend. During the interviews, Ms. Maxwell was
19 involved in seeking girls to perform massages
20 and work at Epstein's home.
22 foundation.
23 BY MR. EDWARDS:
24 Q. Did you interview -- how many girls did
25 you interview that were sought to give or that
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)&;%-:%''3
Page 30
2 actually gave massages at Epstein's home?
4 foundation.
5 BY MR. EDWARDS:
6 Q. Approximately.
8 THE WITNESS: I would say approximately
9 30; 30, 33.
10 BY MR. EDWARDS:
11 Q. And of the 30, 33 or so girls, how many
12 had massage experience?
14 foundation.
15 THE WITNESS: I believe two of them may
16 have been -- two of them.
17 BY MR. EDWARDS:
18 Q. Okay. And as we go through this report,
19 you may remember the names?
20 A. Correct. Let me correct myself. I
21 believe only one had.
22 Q. And was that -- was that one of similar
23 age to the other girls?
25 foundation.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)&*%-:%''3
Page 40
2 foundation.
3 THE WITNESS: Yes, I did.
4 BY MR. EDWARDS:
5 Q. And were trash pulls done at the property
6 of Jeffrey Epstein?
7 A. Yes.
8 Q. What is the purpose of a trash pull, and
9 what is a trash pull?
10 A. A trash pull is when property is
11 discarded, such as trash, we coordinate with the
12 sanitation department to collect the trash, once it
13 leaves the property, and it's put into an empty well
14 of the trash truck. We acquire the bags, and we
15 sift through the contents of the trash.
16 Q. Did you or another detective from the unit
17 observe each step of the trash pull to make sure
18 that you had a good chain of custody of the
19 evidence?
21 foundation.
22 THE WITNESS: Yes. The members of
23 the OCTAN unit at that time did.
24 BY MR. EDWARDS:
25 Q. Okay. And what is that process?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)&<%-:%''3
Page 41
2 A. The process --
4 foundation.
5 THE WITNESS: The process is when the --
6 once you coordinate a trash pull with the
7 sanitation supervisor, you meet with the
8 sanitation worker and ensure that either the
9 can that he's going to place in the well is
10 completely empty and you physically observe him
11 collect the trash and place it into the empty
12 container. And then you follow him to a
13 disclosed area, and we retrieve the bags and
14 you sift through the trash.
15 BY MR. EDWARDS:
16 Q. Okay. What were you looking for in terms
17 of evidentiary value from these trash pulls?
19 foundation.
20 THE WITNESS: We were looking for any --
21 any form of identification. You were looking
22 for -- to gather any kind of intelligence
23 and/or evidence.
24 BY MR. EDWARDS:
25 Q. Okay. If we go to page 20 of the report,
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)&'%-:%''3
Page 42
2 I guess I'll start with where it says on 4/4/2005, I
3 just want to ask you, was a voice mail message taken
4 into evidence from HR to SG?
5 A. Yes.
6 Q. Okay. And the purpose of that evidence is
7 to corroborate what?
9 foundation.
10 THE WITNESS: It was actually a phone call
11 from HR to SG confirming an appointment to go
12 work at Epstein's residence.
13 BY MR. EDWARDS:
14 Q. The next line down is what I wanted to
15 focus on, April 5th, 2005.
16 This trash pull, what evidence is yielded
17 from this particular trash pull?
19 foundation.
20 THE WITNESS: The trash pull indicated
21 that there were several messages with written
22 items on it. There was a message from HR
23 indicating that there would be an 11:00
24 appointment. There were other individuals that
25 had called during that day.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)&6%-:%''3
Page 43
2 BY MR. EDWARDS:
3 Q. And when you would -- when you would see
4 females' names and telephone numbers, would you take
5 those telephone numbers and match it to -- to a
6 person?
8 foundation.
9 THE WITNESS: We would do our best to
10 identify who that person was.
11 BY MR. EDWARDS:
12 Q. And is that one way in which you
13 discovered the identities of some of the other what
14 soon came to be known as victims?
16 foundation.
18 BY MR. EDWARDS:
19 Q. Okay. There's the second paragraph from
20 the bottom, it starts, "Detective Leigh provided
21 trash from 4/06, 4/07/2005."
22 Do you see that?
23 A. Yes.
24 Q. And what is the purpose of the indication
25 that "the following information was retrieved: Jet
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$))4%-:%''3
Page 45
2 BY MR. EDWARDS:
3 Q. And then some of the remaining messages,
4 "Johanna, work Sunday at 4 p.m.; A, Monday after
5 school; left message for Courtney W and NT," are
6 these individuals that you later learned were
7 underaged girls that had been to Jeffrey Epstein's
8 home?
10 foundation.
11 THE WITNESS: That's correct.
12 BY MR. EDWARDS:
13 Q. What types of documents do you remember
14 retrieving from the trash pulls from Jeffrey
15 Epstein's home?
16 A. There was numerous items. It was a lot of
17 handwritten notes on different -- different pads of
18 paper. Some of the pads had names on it, whether it
19 was Epstein, whether it was Ghislane Maxwell,
20 whether it was -- there were phone messages.
21 When I say "phone messages," I mean, you
22 know, the kind that come in a book. They are carbon
23 copied, so the yellow copy always stays with the
24 book, but the white copy is torn off. So there was
25 always a carbon copy of the actual phone message.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$))&%-:%''3
Page 72
3 BY MR. EDWARDS:
4 Q. And let me go back to the beginning six
5 pages of that exhibit, No. 4.
6 MR. PAGLIUCA: Why don't we just make a
7 copy of it now if we're going to ask questions
8 about it? I'm not trying to --
9 MR. EDWARDS: Yes, I know. It's just the
10 first six pages.
11 (A discussion was held off the record,
12 after which the following proceedings were
13 held:)
14 THE VIDEOGRAPHER: On the record at 10:32.
15 BY MR. EDWARDS:
16 Q. And what were some of the items that were
17 found in -- well, are the documents that you're
18 holding, 1 through 6, an accurate reflection of the
19 items that were found in Jeffrey Epstein's home
20 during the search warrant execution?
22 foundation.
24 BY MR. EDWARDS:
25 Q. And I believe that you described that some
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2 of the -- that the house appeared to be -- I don't
3 remember the word you used -- sanitized, for lack of
4 a better word?
6 foundation.
7 BY MR. EDWARDS:
8 Q. How did you know that?
9 A. The computers had been removed from the
10 home.
11 Q. How did you know the computers were
12 removed?
13 A. Based on -- based on the dangling wires
14 left behind, the monitors left, but the actual CPU
15 of it was missing.
16 When you went into the bedroom of Jeffrey
17 Epstein, everything was removed from the -- the
18 shelves, from the armoire.
19 Q. Did you find nude photographs of girls?
20 A. Yes.
21 Q. All right.
22 And what did you do with that evidence?
23 A. That was collected and placed into our
24 crime scene unit.
25 Q. And where is that evidence today?
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2 A. Any evidence that was not returned to its
3 rightful owner was turned over to the FBI.
4 Q. And evidence which would be nude
5 photographs of girls would be evidence not turned
6 back over to Epstein?
7 A. Correct.
9 foundation.
10 THE WITNESS: Some of the items that were
11 collected were later found to be personal items
12 of the houseman, Janush. I recall reviewing
13 his personal photographs on -- on a micro SD
14 card for, like, photos of him and his wife or
15 girlfriend at the time.
16 BY MR. EDWARDS:
17 Q. And the underaged girls that you had
18 spoken with during your investigation, had they
19 described seeing photographs of naked girls in the
20 house?
22 foundation.
23 THE WITNESS: Yes, they did.
24 BY MR. EDWARDS:
25 Q. That's something that ran consistent with
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2 BY MR. EDWARDS:
3 Q. Okay. Also reflected are the property
4 receipts?
6 foundation.
8 BY MR. EDWARDS:
9 Q. All right.
10 And where were those taken from, in terms
11 of whose property is that?
13 foundation.
14 THE WITNESS: This would have been taken
15 from the home of Jeffrey Epstein.
16 BY MR. EDWARDS:
17 Q. And in reviewing that evidence, were you
18 able to substantiate or corroborate certain victims'
19 accounts of their allegations of having been at the
20 house?
22 foundation.
24 BY MR. EDWARDS:
25 Q. Did you find names of other witnesses and
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2 people that you knew to have been associated with
3 the house in those message pads?
5 foundation.
6 THE WITNESS: Yes.
7 BY MR. EDWARDS:
8 Q. And so what was the evidentiary value to
9 you of the message pads collected from Jeffrey
10 Epstein's home in the search warrant?
12 foundation.
13 THE WITNESS: It was very important to
14 corroborate what the victims had already told
15 me as to calling in and for work.
16 BY MR. EDWARDS:
17 Q. Okay. And did you learn the identities of
18 some of the other individuals associated with
19 Jeffrey Epstein through the review of that
20 particular evidence?
22 foundation.
24 BY MR. EDWARDS:
25 Q. Okay. And what did you do with that
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2 BY MR. EDWARDS:
3 Q. In these messages, did you see messages
4 that were taken by Ghislane Maxwell or left for
5 Ghislane Maxwell?
7 foundation.
8 THE WITNESS: I do recall seeing messages
9 utilizing her pad, her stationery.
10 BY MR. EDWARDS:
11 Q. Okay. Do you remember messages
12 specifically that Ms. Maxwell, she is home, or calls
13 for Ms. Maxwell, or indicating that the person
14 taking the message is GM? Do you remember those?
15 A. Yes.
17 foundation.
18 BY MR. EDWARDS:
19 Q. And did that give you further reason to
20 want to speak to Ghislane Maxwell?
22 foundation.
23 THE WITNESS: Correct. I wanted to speak
24 with everyone in the home and everyone
25 associated with Jeffrey Epstein.
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2 anything that's found that has any kind of
3 identifiers, any kind of names, phone numbers,
4 anything that could be used to identify further
5 victims and/or to corroborate what the information
6 we already obtained, that information would be kept.
7 Q. Okay.
8 A. Be followed up on.
9 Q. You testified earlier about certain pieces
10 of paper that had Ghislane Maxwell's name on it that
11 were obtained.
12 Are the documents that are listed, the
13 first one, two, three, four pages of Exhibit 8, some
14 of the documents that you're referring to?
16 foundation.
17 THE WITNESS: That is correct.
18 BY MR. EDWARDS:
19 Q. And if we go through this stack of
20 documents, if you could just review them and tell me
21 if these are some of the items obtained through the
22 trash pulls at Jeffrey Epstein's home?
24 foundation.
25 THE WITNESS: That is correct. This is --
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2 these items were collected in the trash pull.
3 BY MR. EDWARDS:
4 Q. Okay. And these are items that you felt
5 had some evidentiary value?
7 foundation.
8 THE WITNESS: Yes.
9 BY MR. EDWARDS:
10 Q. Were there other items within the trash
11 that were discarded as not having any apparent
12 evidentiary value?
13 A. Correct. There was stuff like food trash
14 we're not going to keep. You know, an apple core.
15 None of that's going to be kept.
16 Q. Okay. And when you took this stuff into
17 evidence, how was it maintained?
18 A. It was placed in a -- in a sealed
19 container, a sealed Ziploc, and placed into
20 evidence.
21 Q. And then was that file later transferred
22 to the State Attorney's Office or the FBI?
24 foundation.
25 THE WITNESS: It was collected by the FBI.
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2
: ss
10 That JOSEPH RECAREY, the witness whose
19 my hand this 24th day of June, 2016.
20
21 __________________________
22
23
24
25
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)34%-:%''3
EXHIBIT 14
(Filed Under Seal)
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Page 1

- - - - - - - - - - - - - - - - - - - - x
Plaintiff,
Case No.:
GHISLAINE MAXWELL,
Defendant.
- - - - - - - - - - - - - - - - - - - - x
**CONFIDENTIAL**
Videotaped deposition of RINALDO

RIZZO, taken pursuant to subpoena, was
held at the law offices of Boies
Schiller & Flexner, 333 Main Street,
Armonk, New York, commencing June 10,
2016, 10:06 a.m., on the above date,
before Leslie Fagin, a Court Reporter
and Notary Public in the State of New
York.
- - -
(866) 624-6221
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)3)%-:%''3
Page 25
1 R. Rizzo - Confidential
2 even Nadia. And what I found very repulsive,
3 out of the ordinary, was Nadia was wearing a
4 swimsuit that was very revealing and
5 basically, her bottom basically went up her
6 butt, revealing all of her buttocks. So
7 again, in the context not very appropriate
8 for the situation.
9 Q. Could you tell the relationship of
10 age between the three girls that you have
11 described and Nadia, for instance?
13 and foundation.
14 A. Nadia seemed to be a bit older, I
15 would say.
16 Q. How does this end, or is there,
17 what do you do next? How does this meeting
18 that you've just described break up?
19 A. I asked to excuse myself and asked
20 where the bathroom was, so I'm pointed inside
21 the house, to go inside the house to the
22 bathroom.
23 I walk in there, and I walk, as I'm
24 walking to the bathroom, what caught my eye,
25 and I had to take a double lock, there were
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Page 26
2 pictures of naked women, half-dressed girls.
3 So I went to the bathroom, again, from
4 someone, myself working in private service, I
5 always know in houses there are cameras, so
6 again, I was very reluctant to stare, because
7 you never know when you are on camera.
8 So I used the bathroom, and I came
9 out, and you know, curiosity got the best of
10 me, and I leaned over and started looking at
11 these pictures for a brief minute, and it was
12 just so coincidental that as I did that, Ms.
13 Maxwell enters, and she immediately says to
14 me that Jeffrey would like for me to rejoin
15 the party immediately.
16 Q. How many pictures of nude females
17 did you see in Jeffrey Epstein's home?
19 and foundation.
20 A. I can't recall the exact number.
21 Q. Can you describe the pictures that
22 you saw in terms of what the people, what the
23 people or person within the picture was
24 wearing, what the age range would be of the
25 person that's in the photograph, any poses,
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2 Q. Did you learn whether your
3 perception was correct?
5 A. It was younger. Yes, I did.
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: Object to the form.
12 Foundation.
13 A. They proceed into the dining room
14 area, which is across from the living room
15 area. I go into the kitchen and I hear a
16 conversation start. Very muffled, I could
17 not hear any particulars about the
18 conversation whatsoever.
19 My wife and I are in the kitchen
20 preparing the evening meal. Eva brings the
21 young girl into the kitchen. In the kitchen,
22 there is an island with three barstools. Eva
23 instructs the young girl to sit to the
24 furthest barstool on the right.
25 Q. Describe for me what the girl
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Page 53
2 looked like, including her demeanor and
3 anything else you remember about her when she
4 walks into the kitchen.
5 A. Very attractive, beautiful young
6 girl. Makeup, very put together, casual
7 dress. But she seemed to be upset, maybe
8 distraught, and she was shaking, and as she
9 sat down, she sat down and sat in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was very nervous.
14 Q. What do you mean by distraught and
15 shaking, what do you mean by that?
16 A. Shaking, I mean literally
17 quivering.
18 Q. What happens next?
19 A. We were, again, the absurdity,
20 never introduced. Like you would walk into a
21 room and say this is -- so my wife and I are
22 in the kitchen and this young girl is sitting
23 there. It was a very uncomfortable moment.
24 I look at my wife. And so I want to ease the
25 moment, and so I introduced myself and I
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)3*%-:%''3
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2 introduced my wife, and she doesn't really
3 respond.
4 And I asked her, are you okay? And
5 she doesn't really respond. Nothing verbal,
6 no cues, her head is still down. I ask her
7 if she would like some water, tissue,
8 anything, and she basically doesn't respond.
9 Q. You ask her for a tissue?
10 A. If she would like a tissue or some
11 water at the time.
12 Q. Was she crying at the time?
13 A. My perception, she was on the verge
14 of crying. And I'm trying to loosen the
15 situation every way I know how, so the only
16 way I knew how, and I thought maybe this will
17 comfort her, I said oh, by the way, do you
18 work for Jeffrey.
19 And she says that, I guess kind of
20 made her feel comfortable, because maybe it
21 was that comment or my persistence, and she
22 said yes. So I said, what do you do? And
23 she says I'm Jeffrey's executive assistant,
24 personal assistant. Which, from looking at
25 her, just didn't seem to suit.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$)3<%-:%''3
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2 And I blurted out: You're his
3 executive personal assistant? What do you
4 do? And she says I was hired as his
5 executive personal assistant. I schedule his
6 appointments.
7 And I'm shocked, and I blurt out:
8 You seem quite young, how did you get a job?
9 How old are you? And she says to me, point
10 blank: I'm 15 years old.
11 And I said to her: You're 15 years
12 old and you have a position like that? At
13 that point she just breaks down hysterically,
14 so I feel like I just said something wrong,
15 and she will not stop crying. My wife and I
16 were at a loss for words, and I keep on
17 trying to console her, and nothing I was
18 saying, are you all right, do you need a
19 tissue, do you need water, consoles her.
20 And then in a state of shock, she
21 just lets it rip, and what she told me was
22 just unbelievable.
23 Q. What did she say?
25 and foundation.
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Page 56
2 A. She proceeds to tell my wife and I
3 that, and this is not -- this is blurting
4 out, not a conversation like I'm having a
5 casual conversation. That quickly, I was on
6 an island, I was on the island and there was
7 Ghislaine, there was Sarah, she said they
8 asked me for sex, I said no.
9 And she is just rambling, and I'm
10 like what, and she said -- I asked her, I
11 said what? And she says yes, I was on the
12 island, I don't know how I got from the
13 island to here. Last afternoon or in the
14 afternoon I was on the island and now I'm
15 here. And I said do you have a -- this is
16 not making any sense to me, and I said this
17 is nuts, do you have a passport, do you have
18 a phone?
19 And she says no, and she says
20 Ghislaine took my passport. And I said what,
21 and she says Sarah took her passport and her
22 phone and gave it to Ghislaine Maxwell, and
23 at that point she said that she was
24 threatened. And I said threatened, she says
25 yes, I was threatened by Ghislaine not to
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2 discuss this.
3 And I'm just shocked. So the
4 conversation, and she is just rambling on and
5 on, again, like I said, how she got here, she
6 doesn't know how she got here. Again, I
7 asked her, did you contact your parents and
8 she says no.
9 At that point, she says I'm not
10 supposed to talk about this. I said, but I
11 said: How did you get here. I don't
12 understand. We were totally lost for words.
13 And she said that before she got
14 there, she was threatened again by Jeffrey
15 and Ghislaine not to talk about what I had
16 mentioned earlier, about -- again, the word
17 she used was sex.
18 Q. And during this time that you're
19 saying she is rambling, is her demeanor
20 continues to be what you described it?
21 A. Yes.
22 Q. Was she in fear?
23 A. Yes.
25 and foundation.
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2 Q. You could tell?
3 A. Yes.
5 A. She was shaking uncontrollably.
6 Q. What happens with this 15-year-old
7 girl next?
9 and foundation.
10 A. As she is trying to explain, and
11 I'm asking questions because I'm as feared as
12 she is at this point. We hear people
13 approach and she just shuts up.
14 Q. What happens next?
15 A. Eva comes in and tells her that she
16 will be working for Eva in the city.
17 Q. As what?
18 A. As a nanny.
19 Q. Did you see this girl again?
20 A. Yes.
21 Q. And when?
22 A. On a flight maybe a month or so to
23 Sweden.
24 Q. What was the purpose of the flight?
25 A. We were going to Sweden for the
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2 summer.
3 Q. Who was on the flight?
4 A. The Dubin family.
5 Q. As well as this girl?
6 A. Yes.
7 Q. What happens?
8 A. One thing that I forgot to mention
9 is during our initial conversation, I asked
10 her what her name was she said her name
11 was
12 Q. What happened with ?
13 A. We flew to Sweden, we stopped at an
14 airport that we didn't usually stop at and
15 she got off the plane.
16 Q. Just so that I make sure I
17 understand, who it was that she says asked
18 her for sex on the island, who was that?
19 MR. PAGLIUCA: Object to the form.
20 Foundation.
21 A. She didn't specify who asked for
22 sex. She said that they asked for sex.
23 Immediately after that she put Ghislaine and
24 Sarah into the conversation.
25 Q. Taking her passport?
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2 A. Yes.
3 Q. From -- are there any other
4 incidents or occurrences that you observed
5 personally with Jeffrey Epstein and Ghislaine
6 Maxwell?
8 and foundation.
9 A. Not that I can recall.
10 Q. This last event that you described,
11 what's the timeframe when that occurred?
12 A. Late 2004, 2005.
13 Q. When did you resign your employment
14 from the Dubin family?
15 A. I think roughly October.
16 Q. Of what year?
17 A. 2005.
18 Q. Why?
19 A. My wife and I had discussed these
20 incidents, and this last one was just, we
21 couldn't deal with it.
22 Q. When you left your employment with
23 the Dubin family, did you have a job?
24 A. When we finally left, I stayed on
25 three months after my resignation, I had a
Page 141
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EXHIBIT 15
(Filed Under Seal)
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Confidential
Page 1

------------------------------------------x
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
June 3, 2016
9:07 a.m.
Deposition of DAVID RODGERS, pursuant

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1 DAVID RODGERS
2 flyer person, then you would reduce it to an
3 initial?
5 foundation.
6 MR. REINHART: You can answer the
7 question.
8 You can answer the question, if you can
9 answer the question. You are allowed to answer
10 the question, if you understand the question.
11 BY MR. EDWARDS:
12 Q. I'm trying to understand your testimony.
13 Is it, if you came to know that person --
14 A. Uh-huh.
15 Q. -- as a frequent flyer passenger, you
16 would begin to reduce that person's name to an
17 initial at some point?
19 THE WITNESS: Well, we don't really have a
20 frequent flyer program that we do, so to speak.
21 A lot of times I would do it because if you
22 would write out everybody's name there is not
23 enough space, you know, to get everybody's name
24 in that little square there.
25
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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?
7 Q. The years of this book, 1995 --
8 A. I wouldn't say through 2013. But, yes,
9 '95 through 2000 sometime. Probably, I would have
10 to go back and -- well, you can see in there.
11 Q. We will get to it.
12 A. There will be a point where you don't see
13 her much. But to say it went through 2013 would not
14 be accurate.
15 Q. Let's do it this way: The person that you
16 have reflected on numerous notations --
17 A. Yes.
18 Q. -- through here as GM --
19 A. Yes.
20 Q. -- just by the initials, are we able to
21 safely know that that is Ghislaine Maxwell?
22 A. Yes.
24 foundation.
25 MR. EDWARDS: Court reporter, did you get

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1 DAVID RODGERS
2 the answer?
3 THE REPORTER: Yes. The answer came
4 before the objection.
5 BY MR. EDWARDS:
6 Q. So on the next flight, the next day, from
7 Palm Beach to SAF. Is SAF Santa Fe?
8 A. Yes.
9 Q. And it indicates JE and GM.
10 Are we able to then know that those
11 passengers on that flight were Jeffrey Epstein and
12 Ghislaine Maxwell?
13 A. Yes.
15 foundation.
16 BY MR. EDWARDS:
17 Q. And where would you land at SAF? Is that
18 an airport?
19 A. It is an airport.
20 Q. Is it a private airport?
21 A. No. It's -- airlines go in there.
22 Q. Did Jeffrey Epstein also have a landing
23 strip at his property in New Mexico?
24 A. He did at one time.
25 Q. What would that -- do you remember what

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1 DAVID RODGERS
2 that code would be?
3 A. I don't believe there was a code.
4 Q. All right. Were there times that you
5 landed either the Gulfstream or the Boeing --
6 A. No.
7 Q. No.
8 MR. REINHART: Let him finish the question
9 before you answer.
10 THE WITNESS: Oh, I'm sorry.
11 BY MR. EDWARDS:
12 Q. Sure. We are doing fine so far. But the
13 court reporter is taking down all of our questions
14 and all of our answers. We are communicating well.
15 A. Okay.
16 Q. But when I go to read this back, we may
17 not get that.
18 A. Okay. Go ahead.
19 Q. So were there times where you landed one
20 of Jeffrey Epstein's planes on his private landing
21 strip at the New Mexico property?
22 A. Yes. But not the Gulfstream and not the
23 Boeing.
24 Q. What plane did you land on his property?
25 A. The Cessna 421. And probably a

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1 DAVID RODGERS
2 9:00, so it is 20 to 11:00 here.
3 BY MR. EDWARDS:
4 Q. So I want to go to page 41, and down to
5 December 9th. Sorry. December 11.
6 A. Okay.
7 Q. Palm Beach to Teterboro.
8 A. Yeah.
9 Q. And who are the passengers?
11 Tayler, Virginia.
12 Q. And this appears to be the first time that
13 Virginia's name appears in the log?
14 A. Right.
15 Q. Is there a -- is there a reason why the
16 first time -- I notice that the first time on some
17 of the other passengers, you use a first and last
18 name. Is there any reason why you didn't use her
19 first and last name?
20 A. I probably didn't know her last name.
21 Q. Just didn't catch it.
22 A. Yes.
23 Q. Okay. It was not that somebody told you
24 not to use the last name?
25 A. No. No.
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1 DAVID RODGERS
2 Q. So that flight goes from Palm Beach to
3 Teterboro.
4 Can you remember whether that's the first
5 time that you flew on a plane with Virginia Roberts?
6 MR. PAGLIUCA: Object to --
7 THE WITNESS: I believe it is.
9 foundation.
10 BY MR. EDWARDS:
11 Q. Do you remember the flight?
12 A. No.
13 Q. The next flight three days later goes from
14 Teterboro to Virgin Islands with Jeffrey Epstein,
15 Ghislaine Maxwell, Adam Perry Lang, and Virginia; is
16 that right?
17 A. Yes.
18 Q. And below that, it says, "Reposition."
19 What does that mean?
20 A. We were taking the airplane with no
21 passengers to go into maintenance, or an OPS2
22 inspection.
23 Q. Okay. This is -- this is the same
24 Gulfstream, is that right?
25 A. Yes.
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2 Q. How many passengers would that Gulfstream
3 allow?
4 A. Twelve passengers, I believe.
5 Q. And do you know how Jeffrey Epstein,
6 Ghislaine Maxwell, Adam Perry Lang, and Virginia get
7 off of St. Thomas or leave the island?
8 A. No. I do not. Probably a charter, I'm
9 guessing.
10 Q. If -- who would fly the -- well, is there
11 any other plane that Jeffrey Epstein was able to
12 access back then that was a private plane?
14 THE WITNESS: No. At that point in time
15 we don't have the Boeing yet.
16 BY MR. EDWARDS:
17 Q. So how many airplanes did Jeffrey Epstein
18 back then?
19 A. Well, we -- I don't know if we had the 421
20 then. We may or may not have. But it wouldn't --
21 you know, you wouldn't be flying the 421 down to
22 St. Thomas with Jeffrey. It is too long of a
23 flight.
24 Q. The Cessna?
25 A. The Cessna 421, correct.

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2 Q. Okay.
3 A. But I'm not even sure we still had it at
4 this point in time.
5 Q. Yeah. It shows up on the next page. We
6 will get there.
7 A. Does it? Okay.
8 So then, yes, the answer is, yeah, we
9 still had the airplane. But we wouldn't have used
10 that.
11 Q. So is there any way of telling how Jeffrey
12 Epstein, Ghislaine Maxwell, Adam Perry Lang, and
13 Virginia were in the Virgin Islands on that, from
14 December 14th, 2000 --
16 BY MR. EDWARDS:
17 Q. -- based on your knowledge or your logs or
18 anything else?
19 A. No, I wouldn't have any way of knowing.
20 Q. Okay.
21 A. Because the next flight that they are on
22 was like this Palm Beach one, January 16th. So I
23 wouldn't have any idea.
24 Q. Okay. To your knowledge, did Jeffrey
25 Epstein ever fly commercially?

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2 A. He probably has. Back then at this time,
3 I'm going to say probably not. But I know that he
4 has flown commercially. But usually that would be
5 like going to Europe, maybe.
6 Q. Okay. January 16th through the 25th,
7 those flights, do you see that block that I'm
8 talking about?
9 A. Yes.
10 Q. Jeffrey Epstein, Ghislaine Maxwell, Emmy
11 Tayler, and then at times Shelly Lewis, do you see
12 that?
13 A. Yes, right.
14 Q. The 25th it lands in Teterboro. And the
15 next day, on the 26th, leaves out of Teterboro with
17 Virginia Roberts. This time you wrote the whole
18 name.
19 A. Right. Right.
20 Q. So when you write the full name, does that
21 signify -- that's when you may have learned her last
22 name?
23 A. Correct.
24 Q. And do you know how she -- how she got up
25 to New Jersey or New York?

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2 A. I do not. I would guess the airlines.
3 Q. At this point in time, did you know what
4 her -- what her relationship was with Jeffrey
5 Epstein or Ghislaine Maxwell?
7 THE WITNESS: No.
8 BY MR. EDWARDS:
9 Q. Did you -- was she a masseuse?
11 THE WITNESS: I -- I'm not sure what she
12 was.
13 BY MR. EDWARDS:
14 Q. Did you form any -- any belief that she
15 was a friend or a business associate or anything?
17 THE WITNESS: Well, I mean, we had a lot
18 of people on the airplane. And Virginia was
19 just another one of those passengers.
20 BY MR. EDWARDS:
21 Q. Okay. So on the 26th, flies to Palm
22 Beach. And then -- and then I guess the 27th --
23 A. Right.
24 Q. -- leaves from Palm Beach to the Virgin
25 Islands --
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2 A. Yes.
3 Q. -- with Jeffrey Epstein, Ghislaine
4 Maxwell, Emmy Tayler, and Virginia Roberts, right?
5 A. Yes.
6 Q. And on the 30th, you fly it back. That's
7 still the Gulfstream, right?
8 A. Yes.
9 Q. From the Virgin Islands to Palm Beach with
10 the same four passengers, correct?
11 A. Yes.
12 Q. And that's Jeffrey Epstein, Ghislaine
13 Maxwell, Emmy Tayler, and Virginia Roberts?
14 A. Correct.
15 Q. And then what happens to that plane, the
16 Gulfstream, for the next month, from February 1st
17 through March 5th?
18 A. Well, I don't know what happened to it,
19 but I'm -- from, looks like February 17th, I'm going
20 to school to get a type rating on the Boeing. And
21 I'm gone for about three weeks.
22 Q. So this is when you're doing a simulator
23 on the Boeing?
24 A. Correct.
25 Q. And getting your certification to fly the

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2 Boeing?
3 A. Yes.
4 Q. The Boeing, was that previously owned by
5 The Limited or Les Wexner?
6 A. I'm not sure of the company name,
7 officially. But probably, yes.
8 Q. Some association with him?
9 A. Some association, yes.
10 Q. Do you know who flew the Gulfstream while
11 you were doing the simulator?
12 A. Well, it would have been Larry Visoski,
13 I'm not sure who the first officer was.
14 Q. Do you know if any logs were kept of the
15 passengers' names?
16 A. While I was at school?
17 Q. Right, while you were at school.
18 A. There probably were logs, but I don't know
19 where they are.
20 Q. Have you ever spoken with Larry about
21 whether he kept names of passengers?
22 A. I don't think he does.
23 Q. Do you know where Larry Visoski flew the
24 Gulfstream for the month that you were --
25 A. No.
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2 Q. Sorry. Just let me finish my question. I
3 know I was getting it out slow.
4 -- but for the month that you were
5 training on the Boeing?
6 A. No.
7 Q. All right. So the last flight that you
8 took in the Gulfstream before you began, before you
9 flew the Cessna for a day, I guess, right, from
10 Santa Fe to DFW --
11 A. Right.
12 Q. -- February 3rd --
13 A. Yes.
14 Q. And that's the Cessna with 908GM tail
15 number?
16 A. Yes.
17 Q. The last flight that you flew on the
18 Gulfstream was the flight back from St. Thomas with
20 Virginia Roberts, right?
21 A. Uh-huh.
22 Q. And then the next time that you're on the
23 plane is -- on the Gulfstream is when?
24 A. It looks like March the 5th.
25 Q. And who are the passengers on that flight?

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2 Where is it going to?
4 Tayler, Virginia Roberts.
5 Q. And then there's notation of Gary
6 Roxborough?
7 A. Yes.
8 Q. Do you know why that is?
9 A. Yeah. He was the first officer.
10 Q. Why did he become the first officer?
11 A. Because Larry was probably in training for
12 the Boeing.
13 Q. Okay. You took -- you alternated?
14 A. Right. We didn't go at the same time.
15 Q. All right. Then the Gulfstream has the
16 same aircraft make and model. That's the same
17 Gulfstream airplane, right?
18 A. Yes.
19 Q. But the aircraft identification mark
20 changes --
21 A. Correct.
22 Q. -- on March 5th, 2001.
23 A. Correct.
24 Q. And it changes to N -- it changes from
25 N908JE to N909JE.
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2 A. Yes.
3 Q. Why was that?
4 A. Because the N908JE went to the Boeing.
5 That was going to be on the Boeing now.
6 Q. And the new number for N909JE was
7 transferred to the Gulfstream?
8 A. Correct.
9 Q. And where does that first flight on the
10 5th go?
11 A. From Palm Beach to Stephenville up in
12 Newfoundland for a fuel stop.
13 Q. Okay. And then how do you know it is a
14 fuel stop?
15 A. Because we are going to Paris, and so we
16 have to stop there for fuel.
17 Q. Okay. I know how -- I know how you would
18 know that. But is there any indication on any of
19 the numbers that go off to the right that would tell
20 me that it's a fuel stop as opposed to --
21 A. No.
22 Q. No? Okay. All right. So there's no way
23 after today's deposition I can look at any of the
24 numbers; it's not going to tell me what it was for?
25 A. No. No. And it's -- obviously it looks

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2 different, because one day is the 5th; one day is
3 the 6th. But we landed there like at 11:50 at
4 night. And then when we took off, it was, you know,
5 the next day.
6 Q. Okay. Got it.
7 And then where do you go the next day?
8 A. We went from Stephenville to
9 Paris-Le Bourget.
10 Q. And who were the passengers going to
11 Paris?
15 A. On the 8th, from Paris to -- I believe
16 that is in Spain.
17 Q. Granada, Spain?
18 A. Granada, Spain. Correct.
19 Q. Okay. And who are the passengers on that
20 trip?
22 Tayler, Virginia Roberts, Alberto and Linda Pinto,
23 one female, and Ricardo, it looks like Orieta.
25 A. From there to Tangiers. From Granada to

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2 Tangiers.
3 Q. When you landed -- sorry to go back --
4 when you landed in -- what did we say LEGR was?
5 A. Granada, Spain.
6 Q. Where did -- where did you stay? Where do
7 you stay on those trips?
8 A. We didn't stay. We left the same day, I
9 believe.
10 Q. Okay. What if we go back to one flight to
11 LFPB?
12 A. Uh-huh. LFPB.
13 Q. That's Paris?
14 A. Yeah. We stayed in Paris.
15 Q. And do --
16 A. We stayed there.
17 Q. Do you know -- do you stay at the same
18 location where Jeffrey Epstein, Ghislaine Maxwell,
19 Emmy Tayler, and Virginia Roberts stay?
20 A. No.
21 Q. Where do you stay while you are in Paris?
22 A. Hotel.
23 Q. Where do they say?
25 THE WITNESS: He has a place there, in

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2 Paris.
3 BY MR. EDWARDS:
4 Q. Okay. Jeffrey Epstein has a home or a
5 house in Paris?
6 A. Right.
7 Q. Okay. Have you been to it?
8 A. Yes, I believe I have.
9 Q. Have you ever stayed there?
10 A. No.
11 Q. And getting to and from the airport, were
12 you ever in the car riding to or from the airport in
13 Paris with Jeffrey Epstein?
14 A. No.
15 Q. So going down to the 9th, then, where is
16 that flight?
17 A. That is from Tangiers to London Luton
18 Airport.
19 Q. And is Luton Airport, is that a major
20 airport?
21 A. For general aviation it is. There is
22 airline service in there, but it is not a huge one,
23 for sure.
24 Q. Who were the passengers?

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3 Q. And am I reading this correctly that the
4 next flight is two days later, on the 11th?
5 A. Yes.
6 Q. And where does the flight on the 11th go?
7 A. From Luton to Bangor, Maine.
8 Q. All right. While in London, do you know
9 what Jeffrey Epstein, Ghislaine Maxwell, Emmy
10 Tayler, and Virginia Roberts did?
11 A. No, I do not.
12 Q. Do you know who they saw?
13 A. No, I do not.
14 Q. After the flight to Maine, where is the
15 next flight?
16 A. Maine is from Bangor to Teterboro the same
17 day.
18 Q. Okay.
19 A. So that was a fuel stop.
20 MR. EDWARDS: All right. We are at a good
21 time to stop. The videographer has to change
22 tapes.
24 MR. EDWARDS: So we why don't we take a
25 five-minute break.
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3 THE VIDEOGRAPHER: Off the record at
4 10:57.
5 (Thereupon, a recess was taken, after
6 which the following proceedings were held:)
7 THE VIDEOGRAPHER: This is the beginning
8 of Disk 2. On the record at 11:12.
9 BY MR. EDWARDS:
10 Q. Sure. If we go back to page 41,
11 December 7th, 2000.
12 MR. PAGLIUCA: Give us a Bates page,
13 please.
14 MR. EDWARDS: Right, 41. For the
15 remainder, when I say "page," I'm really just
16 referring to the Bates number.
17 BY MR. EDWARDS:
18 Q. So page 41, December 7th, 2000.
19 A. Okay.
20 Q. Do you see that?
21 Where was that flight going from and to?
22 A. Luton to -- Luton -- that's going into
23 Marham Air Force Base.
24 Q. Do you remember why you would have flown
25 into the Air Force base?

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2 A. We flew in there to drop the passengers
3 off. And then these passengers that were on there,
4 we dropped them off. And then -- let's see. We
5 repositioned.
6 I don't remember. We dropped passengers
7 off, and we had to leave, I believe.
8 Q. Okay. That was --
9 A. We weren't allowed to stay there.
10 Q. That was Tom Pritzker?
11 A. Yes.
12 Q. And then did you also drop off Jeffrey
13 Epstein, Ghislaine Maxwell, Kelly Spamm?
14 A. Yes.
15 Q. Okay.
16 A. I believe everyone got off the airplane
17 there.
18 Q. And where did you reposition to?
19 A. It says, "Positioned in Norwich, England."
20 I guess it's Norwich.
21 Q. Sandringham, that is what it says right
22 above that. What is that?
23 A. Sandringham. I believe Sandringham is the
24 estate that the queen has --
25 Q. Okay.
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2 A. -- near there.
3 Q. All right. And the flight on
4 December 9th --
5 A. Uh-huh.
6 Q. That's Jeffrey Epstein, Ghislaine Maxwell,
7 Emmy Tayler, Kelly Spamm?
8 A. Right.
9 Q. And then what did you write in the
10 parenthesis under that?
11 A. "Blowing snow on runway." It was a great
12 weird phenomenon that happened that night.
13 Q. And then you're leaving out of that
14 Sandringham Airport; is that right?
15 A. We are -- which one are you on?
16 Q. On the 9th.
17 A. On the 9th --
18 Q. The first entry on the 9th.
19 A. The 9th, we're leaving, looks like
20 Norwich, England, I believe, EGSH, and we go to
21 Gander, Newfoundland --
22 Q. Okay?
23 A. -- for a fuel stop.
24 Q. I think before we took a break that we
25 were on page 43.

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2 A. Uh-huh.
3 Q. And the flight that began in Palm Beach,
4 before going to Paris and Belgium, Tangier, I think
5 you told me, it ended up in Maine --
6 A. Correct.
7 Q. -- on March 11th, 2001.
8 A. Right.
9 Q. Or, sorry, it ended up in Teterboro.
10 A. Teterboro.
11 Q. Okay. And then on the 15th, you fly
12 from -- on the Gulfstream out of Teterboro to ISP.
13 Do you know where that is?
14 A. Islip, New York.
15 Q. Okay. And Virginia Roberts was on the
16 flight that landed in Teterboro on the 11th,
17 correct?
19 foundation.
21 BY MR. EDWARDS:
22 Q. But leaving out of Teterboro, she's not
23 one of the passengers on the flight.
24 A. No.
25 Q. Any idea where she went?

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2 A. No.
3 Q. Okay.
4 MR. PAGLIUCA: Are you referring to
5 Bates 0041, the 11th through 14th? Is that
6 what you're talking about?
7 MR. EDWARDS: Forty-three.
8 MR. PAGLIUCA: Forty-three.
9 MR. EDWARDS: March 11th and March 15th,
10 2001.
11 MR. REINHART: If it will help there, the
12 flight numbers column, like the fifth or sixth
13 column over, are sequentially numbered and
14 unique numbers. So if you want to just say
15 "flight 1468" --
17 MR. REINHART: -- that might help
18 everybody --
19 MR. EDWARDS: Right.
20 MR. REINHART: -- follow along.
21 MR. EDWARDS: Okay. Thanks, Bruce.
22 MR. REINHART: Uh-huh.
23 BY MR. EDWARDS:
24 Q. So the flight now that I'm talking about
25 that leaves out of Teterboro on the 15th, flight

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2 No. 1471 --
3 A. Right.
4 Q. -- the passengers appear to be Jeffrey
5 Epstein, Ghislaine Maxwell, Adam Perry Lang, Alexia
6 Wallert and Banu Cukuglu?
7 A. I think so.
8 Q. Do you remember Banu?
9 A. I definitely remember that. It was a hard
10 name to spell.
11 Yeah. Sort of, I guess. I mean, if she
12 walked in right now, I probably wouldn't recognize
13 her.
14 Q. Well, it has been since 2001, so --
15 A. Yeah, I know.
16 Q. Okay. So then the next flight is 1472.
17 Where is that? Where is that going?
18 A. From Islip to Lake City, Florida.
19 Q. All right. And the passengers, again, are
20 who?
21 A. Jeffrey Epstein, Ghislaine Maxwell, Adam
22 Perry Lang, Alexia Wallert and Banu Cukuglu,
23 whatever her name is.
24 Q. Did you know what relationship she had, if
25 at all, with Jeffrey Epstein?

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2 A. No. No.
3 Q. Do you remember an Ed Tuttle?
4 A. Yes.
5 Q. And who was he?
6 A. I believe Ed was a, probably in
7 construction. I think he may have been around
8 before the Jeffrey -- well, let me think.
9 Q. If we skip down to March 16th, I see his
10 name. So I don't know if that's going to help you.
11 A. I believe -- I believe Ed Tuttle was like
12 maybe an architect, or somewhere in the
13 construction, real estate side, I believe.
14 Q. Okay. So flight No. 1477 --
15 A. Uh-huh.
16 Q. -- from LaGuardia to Palm Beach, is that
17 Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, Joe
18 Pagano, Eva Dubin?
19 A. Yes.
20 Q. Celina Dubin?
21 A. Yes.
22 Q. Jordan Dubin?
23 A. Right.
24 Q. Maya Dubin and two nannies?
25 A. Yes.
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2 Q. And Alexia Wallert? Is that what that is?
3 A. I would assume so, yes, AW.
4 Q. That is sort of what we talked about in
5 the beginning, where Alexia Wallert appears in full
6 name at the top --
7 A. Right.
8 Q. -- and it's AW, AW, AW.
9 A. And there's no room to write her name out
10 there --
11 Q. Right.
12 A. -- so she's AW.
13 Q. Okay. And then the next flight, the 27th,
14 leaves out of Palm Beach. Who are our passengers on
15 that flight and where's it going? 1478 is the
16 flight.
17 A. Yeah. Jeffrey Epstein, Ghislaine Maxwell,
18 Emmy Tayler, Virginia Roberts, two females, Banu,
19 and that's it.
20 Q. And do you know, in New York, when that
21 plane lands in Teterboro, where do you stay when the
22 plane is up there?
23 A. It is 2001. At an apartment there.
24 Q. Did you have your own apartment?
25 A. Yes.
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2 Q. Or did you stay at one of Jeffrey
3 Epstein's apartments?
4 A. No. It was his apartment, Jeffrey's
5 apartment.
6 Q. Was that one of the apartments at 301 East
7 66th Street?
8 A. Yes.
9 Q. And did any of the other passengers from
10 that flight, that 1478, did any of them stay at any
11 of those apartments?
12 A. Yeah. Emmy would have. Virginia probably
13 did.
14 Q. Did you see Virginia stay at the
15 apartment?
16 A. I don't know.
17 Q. When you were in New York and you left
18 from the airport, did you ride in the same car with
19 Virginia?
20 A. Not usually. I mean, I don't know if we
21 ever did. It's possible we did.
22 Q. Do you know whether Virginia Roberts
23 stayed at Jeffrey Epstein's townhouse or whether
24 Virginia Roberts stayed at the apartments?

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2 THE WITNESS: I don't know for sure.
4 BY MR. EDWARDS
5 Q. Can you recollect riding in a car with
6 her, or can you recollect whether she got in a car
7 with anyone else?
9 THE WITNESS: I can't.
11 MR. REINHART: I'm sorry. Are you asking
12 about that specific trip or --
13 MR. EDWARDS: Sorry.
14 BY MR. EDWARDS:
15 Q. I mean that specific trip.
16 A. No. I can't.
17 Q. How about in general at any time?
18 A. No. I don't recall. I mean, I can
19 recall, I would ride sometimes with Emmy, with Adam
20 I remember them being in the car. But, again, that
21 was unusual. Usually it would just be Larry and
22 myself. But on occasion, you know, somebody might
23 ride with us.
24 Q. When you would stay at the apartment in
25 New York on East 66th Street, would it always be in

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2 the same apartment?
3 A. Yes.
4 Q. All right. There are multiple apartments
5 owned by Jeffrey Epstein?
6 A. At that time, it was the same apartment.
7 Q. Okay. Have you stayed in other apartments
8 since that time?
9 A. Yes.
10 Q. All at that East 66th Street location?
11 A. Yes. I really don't -- I don't have an
12 apartment there now. We haven't gone there since
13 probably 2008.
14 Q. How about Banu? Would she have stayed at
15 301 East 66th Street?
17 THE WITNESS: Most likely.
18 BY MR. EDWARDS
19 Q. Why do you say that?
20 A. Well, if she's on the plane with us on
21 multiple trips, then most likely she probably stayed
22 there.
23 Q. Have you been to Jeffrey Epstein's
24 townhouse as 9 East 71st Street?
25 A. Yes.
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2 Q. And it's a pretty big place, right?
3 A. Pretty big.
4 Q. And it has numerous bedrooms?
5 A. Yes.
6 Q. Any reason why Banu would not have been
7 staying there?
10 BY MR. EDWARDS
11 Q. I'm just trying to get to, is there a
12 reason why you believe that Banu would have, I think
13 you said, probably have stayed at the apartment
14 versus the townhouse?
15 A. Well, I only say that because Emmy, you
16 know, stayed there.
17 Q. Stayed where?
18 A. At the -- at our apartments.
19 Q. Okay.
20 A. I'm pretty sure Adam, yeah, Adam stayed
21 there at the time. So most of the people that were
22 regulars on the flight, they would stay there in the
23 apartments.
24 Q. Okay. But do you remember Virginia or
25 Banu staying in the apartments?

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2 A. I do not specifically.
3 Q. Okay. The next flight on the next day,
4 1479, is flying from Teterboro to Santa Fe; is that
5 right?
6 A. Yes.
7 Q. And who are those passengers?
8 A. Jeffrey Epstein, Ghislaine Maxwell, Adam
9 Perry Lang, Virginia Roberts, Banu, Marvin Minsky,
10 Henry Jarecki.
11 Q. Do you remember Marvin and Henry?
12 A. I remember Henry. I don't really remember
13 Marvin.
14 Q. Okay. And then two days later -- again,
15 where would you have stayed if you landed in
16 Santa Fe on March 29th, 2001?
17 A. Probably would have stayed at the ranch.
18 Q. At the Zorro Ranch?
19 A. Yes.
20 Q. All right. Did the other passengers that
21 were on the plane, Jeffrey Epstein, Ghislaine
22 Maxwell, Adam Perry Lang, Virginia Roberts, Banu --
23 I'm not evening going to try her last name --
24 A. Right.
25 Q. -- Marvin Minsky and Henry Jarecki also

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2 have stayed at the ranch?
4 THE WITNESS: I'm going to say most likely
5 they did.
6 BY MR. EDWARDS
7 Q. Was there any other location in Santa Fe
8 where you are aware passengers would have stayed?
9 A. Not that I'm aware of.
10 Q. If you were all going to the same place,
11 is that an occasion where you would all ride in the
12 same vehicle from the airport to the ranch?
15 BY MR. EDWARDS
16 Q. You would still right in separate
17 vehicles?
18 A. Right. Because it takes us about an hour
19 to finish up at the airport.
20 Q. And then the 31st, so two days?
21 A. Let me go back to that one --
22 Q. Sure.
23 A. -- and say, it is possible. I think Adam
24 has ridden with us before. So I couldn't swear that
25 one way or the other. But he has probably ridden

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2 with us before to the airport; to or from the
3 airport.
4 Q. Two days later, flight No. 1408 out of
5 Santa Fe to Palm Beach, who were the passengers
6 there?
7 A. Jeffrey Epstein, Ghislaine Maxwell, Prince
8 Andrew, Virginia Roberts, Nadia Bjorlin, Henry
9 Jarecki, Marvin Minsky.
10 Q. Do you remember when you were at the ranch
11 Nadia Bjorlin arriving?
12 A. I would assume that she airlined in there.
13 Q. Do you remember her at the ranch? Did she
14 perform for you or anything?
15 A. No.
16 I don't remember her at the ranch. I
17 mean, I'm sure she was there. I just don't
18 remember.
19 Q. Okay. Do you remember a person named
20 Heather Mann? She's found on flight 1438 next to
21 Lydia.
22 A. Heather Mann, not really.
23 Q. Okay. The next flight, on page 45, is
24 1488. The flight number. April 9th, 2001.
25 A. Right.
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2 Q. Where does that flight take off from and
3 where does it go?
4 A. Palm Beach to Atlantic City.
5 Q. Who is on that flight?
6 A. Jeffrey Epstein, Emmy Tayler, Virginia
7 Roberts, Banu and Johanna.
8 Q. Do you remember Johanna Sjoberg?
9 A. I don't.
10 Q. On that same day, you take a flight to
11 Teterboro?
12 A. Right.
13 Q. Did you go to the casinos at all that day?
14 A. I don't think so.
15 Q. Would that be something that you would do
16 with them? Or you would stay back?
17 A. No. We would stay at the airport.
18 Q. All right.
19 And then two days later, on the 11th,
20 flight 1490, the plane flies out of Teterboro.
21 For that two-day period of time, the night
22 of the 9th and the night of the 10th, would you have
23 stayed at the apartment?
25 MR. EDWARDS: In New York.

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2 THE WITNESS: I would say, yes.
3 BY MR. EDWARDS:
4 Q. All right. Do you know where Virginia and
5 Banu and Johanna stayed?
6 A. No idea.
7 Q. You can't recollect whether they were --
8 you can't recollect seeing them at the apartments?
10 THE WITNESS: No.
11 BY MR. EDWARDS:
12 Q. All right.
13 Then on the 11th, you leave from Teterboro
14 and go to where?
15 A. St. Thomas.
16 Q. That is flight 1490. And on that flight,
17 Jeffrey Epstein, Ghislaine Maxwell, Prince Andrew,
18 Banu, Virginia Roberts and Johanna?
19 A. Yes.
20 Q. And that is -- that is a flight -- how
21 does -- how did those passengers get from -- does
22 Jeffrey Epstein have a place in St. Thomas?
24 THE WITNESS: Well, yes.
25
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2 BY MR. EDWARDS:
3 Q. Where is that?
4 A. In St. Thomas, he has an office. In St.
5 Thomas.
6 Q. Where does he stay in the Virgin Islands?
7 A. On Little St. James.
8 Q. And how do the passengers get from
9 St. Thomas to Little St. James?
10 A. Most likely, helicopter.
11 Q. How many people does the helicopter fit?
12 A. We didn't own a helicopter then.
13 Probably -- probably 5. It depends,
14 because they had different helicopters. I'm not
15 sure which one they used that day.
16 Q. What is the duration of the flight from
17 St. Thomas to Little St. James?
18 A. About six minutes.
19 Q. What is the duration of a boat trip from
20 Little St. James to St. Thomas?
21 A. Probably about, let's say, 15 to 20
22 minutes. But you are on the east side of the island
23 and the airport is almost to the west side of the
24 island.
25 Q. So you have to almost circle the island?

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2 A. To get from the island by boat, to get
3 to -- there's land there and take a car, it is
4 probably -- it is probably close to an hour, 45
5 minutes for sure.
6 Q. Are there passenger manifests that are
7 kept for the helicopters?
9 THE WITNESS: I'm not sure. I'm not sure.
10 BY MR. EDWARDS:
11 Q. Back in this time, in around April of
12 2001, did Jeffrey Epstein have a helicopter yet?
13 A. No, he did not have a helicopter.
14 Q. At that time?
15 A. Correct.
16 Q. And so do you remember the name of the
17 company or corporation that they rented or
18 transported?
19 A. I don't. It was the only -- helicopter
20 service there in St. Thomas is no longer there.
21 Q. Okay.
22 A. Air Center Helicopter.
23 Q. Was there a particular person at Air
24 Center Helicopter that you ever coordinated with?
25 A. We would, like, call a dispatcher. Or you

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2 know, whoever picked up the phone, we would call
3 them.
4 Q. All right. So 1491 is a flight from
5 St. Thomas to Palm Beach; is that right?
6 A. Yes.
7 Q. And Gwendolyn Beck is now on that flight?
8 A. Yes.
9 Q. Do you remember that flight at all, 1491?
10 A. Not really.
11 Q. Anything about it stick out in your mind?
12 A. No.
13 Q. All right. The next flight that -- do you
14 remember a female name Kelly Bovina?
15 A. I remember the name, but I don't remember
16 her.
17 Q. Was she an actress as well, do you
18 remember that?
20 Q. The next flight I want to direct your
21 attention is 1501, May 3rd, 2001.
22 A. Okay.
23 Q. What is that airport, ADS?
24 A. Addison, Texas. San Antonio, Texas.
25 Q. And who are the passengers on that?

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2 A. Jeffrey Epstein, Virginia Roberts.
3 Q. Do you know how Virginia Roberts got to
4 Addison, Texas?
5 A. No.
6 Q. Was that flight -- was the purpose of that
7 flight only to pick up Virginia Roberts?
9 foundation.
10 BY MR. EDWARDS:
11 Q. Can you tell by your logs?
12 A. Not really. Let's see. We -- no, I don't
13 know.
14 Q. The flight previous on the 3rd flies in
15 from where? Where is that?
16 A. Little Rock.
17 Q. Arkansas?
18 A. Correct.
19 Q. So the only passenger on that flight from
20 Little Rock, Arkansas, to Addison, Texas, flight
21 1500, is Jeffrey Epstein, right?
22 A. Right.
23 Q. And then you land in Addison before going
24 to Santa Fe?
25 A. That is actually San Antonio, I believe.

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2 Yes. That is San Antonio, SAT.
3 Q. How long is the flight from Addison to San
4 Antonio?
5 A. I would be guessing, probably an hour.
6 Q. Do you know what the purpose was for
7 landing --
8 A. Well, you know, I can tell you. It is
9 9/10s. Fifty-four minutes.
10 Q. Do you know what the purpose was to be to
11 land in Addison, Texas, before arriving in San
12 Antonio?
13 A. I do not. But it appears that we spent
14 the night in San -- oh, I see what you are saying.
15 No, I don't know. That I went to Addison probably
16 the same day.
17 Q. Went to Addison and picked up Virginia
18 Roberts?
19 A. It looks like it.
20 Q. And then in San Antonio, two days later,
21 who are your passengers on that flight, 1502?
22 A. Jeffrey Epstein, Virginia Roberts.
23 Q. Where do you fly?
24 A. From San Antonio to Palm Beach.
25 Q. And in May, on May 14th, 2001, flight

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2 1506, where is that flight leaving from?
3 A. St. Thomas.
4 Q. And going where?
5 A. Teterboro.
6 Q. And who are your passengers?
8 Tayler, Banu, Virginia Roberts and one female.
9 Q. And, again, do you remember who the one
10 female would have been with Virginia Roberts?
11 A. No.
12 Q. Can you tell by this how any of those
13 individuals that were on that flight leaving from
14 the Virgin Islands to Teterboro got to the Virgin
15 Islands?
16 A. No.
17 Q. What were the other possible avenues back
18 in those days for Jeffrey Epstein, Ghislaine Maxwell
19 to travel to the Virgin Islands?
20 A. They could have done a charter, possibly.
21 Q. Okay. Was there ever a time when, it
22 looks like that is the -- that is the Gulfstream
23 that you fly out of the Virgin Islands to Teterboro,
24 correct?
25 A. Correct.
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2 Q. Was there ever a time you were flying the
3 Gulfstream and -- well, let's go back a little bit.
4 A. Okay.
5 Q. On May 7th, at the top.
6 A. Right.
7 Q. Flight 1503, that is the Gulfstream
8 traveling from Palm Beach to CHO?
9 A. That is Charlottesville, I believe,
10 Virginia.
11 Q. And then on that same day from
12 Charlottesville to Teterboro?
13 A. Correct.
14 Q. So when does the Gulfstream get from
15 Teterboro to St. Thomas?
16 A. Hmm, I don't know. Because it appears
17 that I'm on vacation at that time. So I don't know.
18 Q. How did you get to St. Thomas for the 14th
19 to fly?
20 A. Airline.
21 Q. All right. So at some point in time,
22 between May 7th and May 14th --
23 A. Uh-huh.
24 Q. -- somebody flies the Gulfstream to the
25 Virgin Islands.
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2 A. Correct.
3 Q. And who would that be?
5 THE WITNESS: Larry Visoski and I don't
6 know who the other person would have been.
7 BY MR. EDWARDS:
8 Q. When you pick up passengers in the Virgin
9 Islands and you are taking them to Teterboro, do you
10 speak with Larry Visoski about when he arrived in
11 the Virgin Islands?
12 A. Yeah. Yeah. We would coordinate that. I
13 mean, usually we would go down there together. We
14 would ride in the same airline down.
15 Q. In this particular case, you were on
16 vacation?
17 A. Well, that is true. However, most likely
18 he airlined home once he got to St. Thomas. And
19 then most likely, we drove in a car to Miami and
20 road the same airline down there.
21 Q. That was something that you customarily
22 did?
23 A. Yes.
24 Q. Okay. So then you have -- we have no way
25 of knowing then who the passengers that flew to the

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2 Virgin Islands would have been, if there were any in
3 addition to those that left?
4 A. No.
5 Q. All right. You fly into Teterboro on
6 flight 1506 on May 14th, 2001, and fly out in the
7 Gulfstream on the 24th, 10 days later; is that
8 right?
9 A. Yes.
10 Q. And your passengers, 10 days later flying
11 to Palm Beach are Jeffrey Epstein, Ghislaine
12 Maxwell, Emmy Tayler, Adam Perry Lang and a female.
13 A. Right.
14 Q. Do you know where Virginia Roberts went
15 during that time after she landed in Teterboro on
16 the 14th?
17 A. I do not.
18 Q. Page 47, I'm going to go to flight
19 No. 1510. June 3rd, 2001.
20 Who is on that flight?
21 A. Jeffrey Epstein, Virginia Roberts, Banu.
22 Q. And you are flying from Palm Beach to
23 St. Thomas again?
24 A. St. Thomas, yes.
25 Q. And then from St. Thomas to Teterboro two

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2 days later, on June 5th?
3 A. Jeffrey Epstein, Virginia Roberts, and
4 Banu.
5 Q. All right. And then where is the next
6 flight on the 8th?
7 A. On the 8th, from Teterboro to Montreal.
8 Q. Do you know what -- so Virginia Roberts
9 and Banu were not on the flight on the 8th, right?
10 A. That's correct.
11 Q. Okay. Do you remember the flight on the
12 8th with Naomi Campbell, Rebecca White, Ana Malova?
13 A. Sort of. But not really.
14 Q. Okay. Do you remember who Rebecca White
15 is?
16 A. No.
17 Q. Do you remember how old Rebecca White was?
18 A. No.
19 Q. The next flight I want to direct your
20 attention to is on the 15th of June, flight 1516.
21 A. Uh-huh.
22 Q. Passengers: Jeffrey Epstein, Ghislaine
23 Maxwell, and then does that say Sheridan?
24 A. Yes.
25 Q. Do you remember a passenger named Sheridan

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2 Gibson?
3 A. Possibly.
4 Q. And then it says, Caroline. Do you know
5 who Caroline is?
6 A. I do not.
7 Q. And then one female?
8 A. Yeah, I don't know who the female is.
9 Q. Okay. On the 28th, there is a flight
10 1523.
11 A. Uh-huh.
12 Q. From -- is that Portugal to St. Thomas?
13 A. No. It is the Azores.
14 Q. LPAZ?
15 A. Yes. It was a fuel stop.
16 Q. To St. Thomas?
17 A. Right.
18 Q. And then on that flight is Jeffrey
19 Epstein, Ghislaine Maxwell, Emmy Tayler and Ed
20 Tuttle, right?
21 A. Yes.
22 Q. Six days later, leaving on July 4th from
23 St. Thomas, who are your passengers?
24 A. Jeffrey Epstein, Prince Andrew, Virginia
25 Roberts, one female.

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2 Q. And do you know how Virginia Roberts got
3 to the Virgin Islands?
4 A. No.
5 Q. Is there any -- is it possible that the
6 Cessna took her or the Boeing took her? Or any
7 other aircraft that is owned by Jeffrey?
9 THE WITNESS: No, I would -- if I had to
10 guess, I would guess the airlines.
11 BY MR. EDWARDS:
12 Q. Okay.
13 A. Well, I know it wasn't the Boeing, because
14 the Boeing is not in operation at that point in
15 time. We hadn't flown it. I mean, it hadn't had
16 any passengers on board yet. That is like in August
17 of 2001.
18 Q. Okay. And the Cessna, did you take that
19 from Florida to the Virgin Islands?
20 A. It has been to the Virgin Islands, but I
21 don't think we ever took any passengers down there.
22 Q. Okay. All right. The next flight is
23 1525.
24 A. Okay.
25 Q. On July 8th, 2001.

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2 A. Okay.
3 Q. That leaves out of Palm Beach?
4 A. Okay.
5 Q. Where do you go on that?
6 A. Teterboro.
9 Tayler, Prince Andrew, Virginia Roberts, Sheridan
10 Gibson, maybe Sheridan Gibson-Beaute, I guess, and
11 one female.
12 Q. And then three days later, you leave out
13 of Teterboro to CPS?
14 A. Yes.
15 Q. Where is that?
16 A. That is St. Louis, actually it is Cahokia,
17 Illinois, across the river from St. Louis.
18 Q. Who are your passengers?
20 Tayler, Virginia Roberts. We were actually en route
21 to Santa Fe. We had a mechanical problem. We had
22 to go into there for maintenance.
23 Q. Do you remember having a mechanical
24 problem or is the log just refreshing your memory?
25 A. No, I remember because that was the only

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2 time we landed at Cahokia with passengers on board.
3 Q. What was the problem?
4 A. We had a -- we had a static line that had
5 cracked and it was causing our altimeters to not
6 agree. And then we went to the alternate system,
7 things got really worse because it was stopped up
8 with a mud dauber somewhere in the system. That is
9 why I remember that flight.
10 Q. When you landed in St. Louis did the
11 passengers get off the plane?
12 A. Yes. And then they airlined -- I believe
13 they airlined. They could have taken a charter, I
14 don't recall. But I know they didn't leave with us.
15 Q. All right. And the passengers that got
16 off the plane would have been Jeffrey Epstein,
17 Ghislaine Maxwell, Emmy Tayler and Virginia Roberts?
18 A. Yes.
19 Q. And then on the 16th, those five days
20 later, those same passengers leave Santa Fe?
21 A. Right.
22 Q. And go back to Teterboro?
23 A. Correct.
24 Q. When Jeffrey Epstein would go to his
25 townhouse in New York, would you always fly into

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2 Teterboro?
3 A. Most of the time. It would depend on the
4 airplane, too. Like the Boeing, you are not allowed
5 to take it into Teterboro.
6 Q. So while you had the Gulfstream, it seemed
7 like Teterboro?
8 A. Yeah, it is -- I mean, occasionally there
9 would be a LaGuardia in there, but not really often.
10 Q. So on the 16th, you fly in to Teterboro.
11 And then six days later, it looks like, flight
12 No. 15 -- oh, wait. All right.
13 So flight No. 1528, you fly into
14 Teterboro, Jeffrey Epstein, Emmy Tayler, Ghislaine
15 Maxwell and Virginia Roberts. Do you see that?
16 A. Yes.
17 Q. Then the next flight I have listed is
18 1530.
19 Do you know where 1529 is?
20 A. No, other than I'm gone for some reason.
21 I wasn't on that flight.
22 Let's see. July, approximately. I see I
23 went on vacation.
24 Q. Okay. And the 23rd, there is a flight
25 from Palm Beach to St. Thomas with Jeffrey Epstein,

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2 Shelly Lewis. Do you see that?
3 A. Yes.
4 Q. Five days later, the flight that leaves
5 St. Thomas does not have Shelly Lewis; is that
6 right?
7 A. Correct.
8 Q. And then you fly to Palm Beach?
9 A. Yes.
10 Q. And who are your passengers at that time?
11 A. Jeffrey Epstein, Virginia Roberts, yes.
12 Q. When you had the mechanical problem, do
13 you remember any of the passengers being scared or
14 frightened?
15 A. No. Not really. I mean, they didn't
16 really know that we had a problem. We just informed
17 them that we couldn't continue on to Santa Fe.
18 Q. Okay. And August 7th, 2001, flight 2?
19 A. Uh-huh.
20 Q. Is that the first flight that the Boeing
21 makes with passengers?
22 A. Correct.
23 Q. And that is Jeffrey Epstein, Ghislaine
24 Maxwell, Emmy Tayler, Prince Andrew and two females.
25 Do you remember who the two females were on the

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2 first passenger flight of the Boeing?
3 A. I do not.
4 Q. And then on the 7th -- at that flight flew
5 from Los Angeles to Albuquerque, correct?
6 A. Uh-huh.
7 Q. On the 14th, you were flying the Cessna
8 that has the 908GM tag.
9 A. Correct. Right.
10 Q. And then the next entry with passengers is
11 on the 16th. And you are flying the Boeing again,
12 right?
13 A. Yes.
14 Q. All right. Do you know who flew the
15 Boeing for flight 3, 4 and 5?
16 A. For 3, 4 and 5, no. Oh, yes. I know it
17 wasn't me. I do remember that now.
18 I went on vacation. And it was a contract
19 guy that flew for us while I was gone.
20 Q. Do you remember a passenger named
21 Alexander Dixon?
22 A. Alexander Dixon, no.
23 Q. Flight No. 11 on the Boeing?
24 A. Uh-huh.
25 Q. Now, the Boeing has the tag 908JE?

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2 A. Correct.
3 Q. That is what you were explaining in the
4 beginning, correct?
5 A. Correct.
6 Q. So September 3rd, the Boeing flies from
7 St. Thomas to HPN?
8 A. Yes, White Plains, New York.
9 Q. And your passengers?
11 Tayler, Adam Perry Lane, Banu, Sarah Kellen,
12 Alexander Dixon.
13 Q. Do you remember Sarah Kellen?
14 A. Yes.
15 Q. And do you remember what -- is that your
16 first time meeting Sarah Kellen, when she appears?
17 A. I don't think so. I thought she was on an
18 earlier flight. Let's see. But it could be. It
19 could be, I'm not sure.
20 Q. Do you know how Sarah Kellen got to
21 St. Thomas to be leaving St. Thomas with you?
22 A. No.
23 Q. Do you know what her relationship was, if
24 any, with Jeffrey Epstein?
25 A. She was -- Sarah was sort of taking over

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2 Emmy's position. Like an assistant to Ghislaine.
3 Q. All right. Page 53. January 15th, 2002.
4 A. Okay.
5 Q. There is a flight from Bedford,
6 Massachusetts; is that right?
7 A. Yes.
8 Q. To where is that going?
9 A. White Plains.
10 Q. And it's Jeffrey Epstein and Jessica.
11 A. Yes.
12 Q. Do you remember who Jessica is?
13 A. I do not.
14 Q. From White Plains, who are the passengers
15 going to St. Thomas?
16 A. Jeffrey Epstein, Ghislaine Maxwell, Sarah
17 Kellen, Prince Andrew, Cindy Lopez, Johanna and one
18 female.
19 Q. Do you remember Cindy Lopez?
20 A. Yes.
21 Q. And what did she do?
22 A. I don't know what she did, but I do
23 remember Cindy Lopez.
24 Q. Was she somebody that you believed to be a
25 masseuse?
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2 A. I'm not sure what her position was. It is
3 possible.
4 Q. All right. February 9th, 2002, flight 57
5 on the Boeing.
6 A. Okay.
7 Q. From Miami to White Plains.
8 A. Yes.
9 Q. Your passengers include Bill Clinton, four
10 Secret Service.
11 Did the Secret Service ask that you not
12 identify them by name?
13 A. No.
14 Q. Any reason that you didn't identify them
15 by name?
16 A. Didn't know their name.
17 Q. Two males, one female.
18 A. Right.
19 Q. Jeffrey Epstein, Ghislaine Maxwell, Sarah
20 Kellen and Prince Andrew.
21 A. Correct.
22 Q. Was that your first time meeting Bill
23 Clinton?
24 A. Yes.
25 Q. At that point, did you have any

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2 understanding of what was the relationship between
3 Jeffrey Epstein and Bill Clinton or Ghislaine
4 Maxwell and Bill Clinton?
5 A. No, I didn't have any idea.
6 Q. Had you seen any pictures, prior to that
7 time, of Bill Clinton in any of Jeffrey Epstein's
8 planes or homes?
9 A. Not him I'm aware of.
10 Q. Have you ever seen a picture of Bill
11 Clinton in Jeffrey Epstein's plane?
12 A. In his plane? I don't think so.
13 Q. Have you ever seen one in his homes?
14 A. Not that I can recall.
15 Q. Okay.
16 A. Oh, wait, wait. Back up. A picture of
17 Bill Clinton in the plane? Do you mean the picture
18 is on the wall in the airplane or a picture taken of
19 Bill Clinton on the plane?
20 Q. A picture of Bill Clinton on the wall of
21 the airplane.
22 A. I have a picture of me and actually the
23 crew with Bill Clinton on the plane, but it is not
24 on the wall of the airplane.
25 Q. And when was the picture of you with Bill

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2 Clinton taken?
3 A. I think it was the first flight.
4 Q. The flight that we just looked at?
5 A. Yes.
6 Q. To the best of your knowledge, is that the
7 first time that Bill Clinton flew with Jeffrey
8 Epstein or Ghislaine Maxwell?
9 A. To the best of my knowledge. It was the
10 first time that we had flown him.
11 Q. Okay. On flight No. 72, which is page 54,
12 March 10th.
13 A. Okay.
14 Q. The Boeing flies from St. Thomas to JFK;
15 is that right?
16 A. Yes.
17 Q. Is there any way of knowing when the
18 Boeing got to St. Thomas by these logs?
19 A. Yes, it got there on the 28th. Because it
20 is trip No. 71 above it. Oh, wait. Oh. Wait.
21 State the question again.
22 Q. Yes, exactly.
23 Do we know how or when the Boeing got to
24 St. Thomas? It is leaving out of St. Thomas on
25 flight 72, but flight 71 seems to me to land in Palm

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2 Beach.
3 A. Correct.
4 Q. So I'm just missing the kind of connection
5 there.
6 A. Yes. Me, too.
7 Q. Okay.
8 A. Yeah, I don't have an answer for that.
9 Q. Okay. Would somebody else have flown the
10 Boeing, while you were doing this simulator, the 6th
11 and 7th and 8th?
12 A. It is possible.
13 Q. That is one possible conclusion, based
14 upon what we have here?
15 A. That is probably what happened.
16 Q. Okay.
17 So then March 10th -- sorry. March 10th,
18 you fly to JFK, right?
19 A. Yes.
20 Q. March 4th, from JFK to Palm Beach. March
21 the 17th, from Palm Beach back to JFK. And then
22 March 19th, 2002, you fly from JFK to -- where is
23 that?
24 A. Luton, London.

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2 A. Bill Clinton. Doug Band. Three Secret
3 Service, Jeffrey Epstein, Ghislaine Maxwell, Sarah
4 Kellen.
5 Q. And the next day -- or, sorry, two days
6 later.
7 Do you know where those passengers stayed
8 in London?
9 A. I have to think about this one second.
10 No, in fact, I don't think they did. Because we
11 didn't spend the night there. We went there. I got
12 to the hotel. As soon as I got to the hotel, I got
13 word from Secret Service that President Clinton
14 wanted to leave that night, so we left that night.
15 So we made it to the hotel, the crew did,
16 but we were there not that long. Two or three
17 hours, four hours, maybe.
18 Q. Do you remember why he wanted to leave
19 that night?
20 A. No. No, because when we went there, we
21 thought we were going to be there for like probably
22 at least a couple of nights. But it didn't turn
23 out -- we didn't even spend one night there.
24 Q. Okay. So does this probably mean that you
25 got there late at night on the 19th, the early

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2 morning on the 21st?
3 A. We took off the 19th. So when we land
4 there, it is really the 20th. And probably when we
5 took off there, it is like after midnight or
6 thereabouts.
7 Q. And that is when you fly back to JFK?
8 A. Back to JFK, yes.
9 Q. And you went there with three Secret
10 Service and came back with 10?
11 A. Yes.
12 Q. How did that happen?
13 A. Well, there was an advance party waiting
14 for us when we got there and then when we came back,
15 they just flew back with us.
16 Q. What was the events that you were
17 traveling to London for?
18 A. I'm not sure. I would imagine, he was
19 probably giving a speech.
20 Q. Okay. And you came back with Bill
21 Clinton, Doug Band?
22 A. Yes.
23 Q. Who was Doug Band?
24 A. Doug was Bill Clinton's, he's an attorney,
25 and he was like his right-hand guy, really, as far

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2 as doing anything.
3 Q. Okay. And you also flew back with Jeffrey
4 Epstein, Ghislaine Maxwell, Sarah Kellen and Naomi
5 Campbell?
6 A. Yes.
7 Q. How did it happen that Naomi Campbell
8 joined the plane to come home?
9 A. I don't know. The same way she joined it
10 before I guess in Montreal. I don't know how she
11 was there. And one male, too. It looks like.
12 Q. All right. The next page is page 56,
13 flight 96.
14 A. Okay.
15 Q. Sorry. Let's back up to 94.
16 When the Boeing takes off from JFK, do you
17 know sometime during that trip that you are going to
18 be picking up President Clinton?
19 A. I think so. Let me see. We went to
20 Paris.
21 Yes, oh, yes. We knew that was going to
22 be a long trip.
23 Q. Okay.
24 A. So we knew at that point in time. I'm
25 almost certain that we knew.

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2 Q. What did you know about that trip?
3 A. We knew that was going to be a long trip
4 because we were going to go around the world.
5 So when we departed, it was a about a week
6 later, as I recall, that we picked up Clinton. We
7 left JFK on the 11th, a little less than a week.
8 Half a week later, we picked up Clinton and from
9 there, we went to -- Hong Kong.
10 Q. So you fly in to -- on the 20th, flight
11 99, Jeffrey Epstein, Ghislaine Maxwell, and Sarah
12 Kellen.
13 A. Right.
14 Q. You fly in to a Naval air base in Japan?
15 A. Correct.
16 Q. How were you given access to stay in the
17 Naval air base?
19 THE WITNESS: The airplane, you mean?
20 BY MR. EDWARDS:
21 Q. Yes. It looks like it is there two days.
22 That is why --
23 A. I guess because we were picking up
24 President Clinton.
25 Q. And do you know where Jeffrey Epstein,

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2 Ghislaine Maxwell and Sarah Kellen stayed?
3 A. I do not.
4 Q. Was there a room for them on the Naval air
5 base?
6 A. No, I don't think -- nobody stayed at the
7 Naval air base.
8 Q. All right. And then on the 22nd, you
9 leave the Naval air base with -- who is that on that
10 flight?
12 Kellen, President Bill Clinton, Mike, Doug Band,
13 Janis and Jessica.
14 Q. You flew into the Naval air base with
15 Jeffrey Epstein?
16 A. Plus six other passengers.
17 Q. Okay. Are those secret service?
18 A. Most likely.
19 Q. You flew in to the Naval air base with
20 Jeffrey Epstein, Ghislaine Maxwell and Sarah Kellen
21 only, right?
22 A. Right.
23 Q. And nobody stayed on the Naval air base?
24 A. No.
25 Q. And you are there to pick up Bill Clinton?

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2 A. Yes.
3 Q. And you pick up Bill Clinton and six
4 passengers plus Mike?
5 A. Correct.
6 Q. Doug Band, who you have already explained
7 who that is with relation to Bill Clinton, and Janis
8 and Jessica.
9 A. Yes.
10 Q. Do you know who they are?
11 A. Yes.
12 Q. Who are Janis and Jessica?
13 A. Secret Service.
14 Q. How do you remember that?
15 A. Well, there is probably 8, 8 or 9 Secret
16 Service people there, two of them were women. The
17 other 7 -- and it was just easier to remember the
18 two women's names than the 7 other guys' names.
19 Q. This entry on January 22nd, 2002, Jessica,
20 is that the same or a different Jessica from --
21 A. On which one?
22 Q. Sure. Sorry. May 22nd. I think I
23 butchered the date before.
24 A. Right.
25 Q. May 22nd, 2002. Is that the same Jessica

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2 as January 15th, 2002, flying with Jeffrey Epstein?
3 A. January 15th.
4 MR. REINHART: Flight 48.
5 BY MR. EDWARDS:
6 Q. Right. It is flight 48.
7 A. I'm don't think -- no, I they wouldn't be
8 the same Jessica, no.
9 Q. Okay. After you pick up President Bill
10 Clinton, where did you fly?
11 A. We went to Hong Kong.
12 Q. Do you know what the purpose was?
13 A. I believe he was giving a speech.
14 Q. All right. And then from there, where did
15 you fly?
16 A. That would be Shenzhen, Japan -- or China.
17 Q. Okay. And do you remember the purpose
18 there?
19 A. Speech.
20 Q. And then where did you fly?
21 A. Singapore.
22 Q. Again, another speech?
23 A. Another speech.
24 Q. During the course of these days, where did
25 President Bill Clinton sleep?

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2 A. I guess at a hotel somewhere. I'm not
3 sure.
4 Q. Did he stay at the same place as Jeffrey
5 Epstein, Ghislaine Maxwell and Sarah Kellen?
6 MR. PAGLIUCA: Foundation.
8 BY MR. EDWARDS:
9 Q. All right. Were meals served on the
10 plane?
11 A. Something was served, but I don't know if
12 you would call it a meal. Probably. I'm sure we
13 had catering and stuff. I just don't recall.
14 Q. That was just typical back then to have
15 meals, especially for the President, right?
16 A. Normally we do not. And we probably did
17 have catering back then, but I don't recall.
18 Q. Okay. Where did you fly from Singapore?
19 A. Singapore, VTBD, I don't know. You have
20 your cheat sheet over there?
21 Q. VTBD, mine says Thailand.
22 A. I was going to guess Thailand.
23 Then from Thailand, I think we went to --
24 Q. My cheat sheet says Brunei?
25 A. Exactly. You don't want to go there.

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2 Q. You don't?
3 A. No.
4 Q. Okay. Was the purpose a speech at each
5 location to the best of your knowledge?
6 A. To the best of my knowledge, it was.
7 Q. All right. Do you know why it was that
8 Jeffrey Epstein and Ghislaine Maxwell and Sarah
9 Kellen accompanied him?
10 A. No.
11 Q. And then did you leave?
12 MR. REINHART: Did you answer that
13 question?
14 THE REPORTER: He said no.
15 MR. REINHART: I didn't hear it.
16 BY MR. EDWARDS:
17 Q. Did you leave President Bill Clinton and
18 Doug Band and the Secret Service in Brunei?
19 A. Hmm. It is possible.
20 What is WRR?
21 Q. Not found. Sorry.
22 A. Not good.
23 Q. That is the only entry in here that is not
24 found.
25 But the next one, VCBI says Sri Lanka?

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2 A. Okay. Then if that says Sri Lanka, then,
3 yes, we probably did leave Clinton in Brunei, I
4 think. And I think we went from there down to Bali.
5 We went to Bali without --
6 Q. Without Bill Clinton?
7 A. Yes.
8 Q. What was the purpose of the trip to Bali?
9 A. Just to get away.
10 Q. And then to Sri Lanka?
11 A. Sri Lanka was just a fuel stop on the way
12 to Paris. Two fuel stops.
13 Q. That's in Dubai?
14 A. Yes.
15 Q. And then you get to Paris?
16 A. Correct.
17 Q. And then you fly back to London?
18 A. Yes. Yes.
19 Q. All right. Do you remember the purpose of
20 the trip to London?
21 A. Yes.
22 Q. What was that?
23 A. We had to have our APU changed on the
24 airplane. It quit working in Paris. And we landed
25 there.
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2 Q. All right. The next page, page 57,
3 June 21st. Flight 1570. Where is that flight
4 leaving from?
5 A. Palm Beach to the Bahamas.
6 Q. And who is on the flight from Palm Beach
7 to the Bahamas?
9 Kellen, Cindy Lopez, Jean-Luc Brunel, Virginia
10 Roberts.
11 Q. All right. And that is on June 21st?
12 A. Yes.
13 Q. All right. And then there is a couple of
14 entries that say "reposition."
15 A. Right.
16 Q. That is flying back to Palm Beach and then
17 back down to the Bahamas?
18 A. Correct. Yeah, we left them there. And
19 we flew the airplane home.
20 Q. And then did you leave out of the Bahamas
21 on the 23rd.
22 A. Yes.
23 Q. Up to Teterboro.
24 And who are your passengers on flight
25 1573?
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3 Kellen, Cindy Lopez, Juliana Borres, I guess,
4 Jean-Luc Brunel, Melissa Stahl.
5 Q. A Virginia Roberts was taken to the
6 Bahamas. Do you know where she went from there?
7 A. I do not.
8 Q. Do you remember a Frederic Fekkai?
9 A. What is the name again?
10 Q. Fekkai, F-E-K-K-A-I. Frederic Fekkai?
11 A. First name?
12 Q. Fred.
13 A. Fred.
14 Q. Hairdresser?
15 A. The last name sounds familiar.
16 Q. All right. He's on a flight No. 116 on
17 the Boeing.
18 A. Uh-huh.
19 Q. June 27th?
20 A. Okay. I see.
21 Q. And there are -- it looks like a bunch of
22 passengers. Do you remember Daralyn Priest?
23 A. No. Where is she?
24 Q. Middle column.
25 A. Daralyn. Oh, yes, I see her. Right. I

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2 don't remember her.
3 Q. Do you remember that flight?
4 A. To Paris. Not really. It was a big
5 flight. We had a lot of people on it, which was
6 unusual, going to Paris. No, I don't.
7 Q. You don't remember it.
8 A. No.
9 Q. So you don't remember the purpose of the
10 flight?
11 A. No.
12 Q. July 2002, it is page 58. Go to flight
13 120.
14 A. Okay.
15 Q. LF?
16 A. That is Nice.
17 Q. And where do you go?
18 A. Tangiers.
19 Q. And then from Tangiers to?
20 A. To another place in Morocco. Marrakesh.
21 I think it is Marrakesh. I could be wrong on that
22 one. It is definitely Morocco.
23 Q. From there, is that where you pick up Bill
24 Clinton?
25 A. Let's see. GMME would be Rabat, the

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2 capital of Morocco, I believe.
3 Q. Did you know before this flight that you
4 at some point would be picking up Bill Clinton?
5 A. I think we did, yes.
6 Q. Who was on the flight with Bill Clinton?
8 Kellen, Prince Andrew, Cindy Lopez, President
9 Clinton, Doug Band, Mike, with Secret Service and 8
10 Secret Service people. So probably 9 Secret Service
11 people.
12 Q. So Mike is a person that is also -- that
13 is?
14 A. He's Secret Service, yes. That is just
15 what I recall. He was the lead guy of the Secret
16 Service.
17 Q. Where do you take Bill Clinton?
18 A. We went to the Azores for a fuel stop and
19 then we went to JFK. Kennedy, New York.
20 Q. Then on August 5th, in the Gulfstream, on
21 flight 1586, you leave from Teterboro and go to
22 Santa Fe; is that correct?
23 A. Correct.
24 Q. On that flight, you have Jeffrey
25 Epstein -- sorry, Jeffrey Epstein, Sarah Kellen and

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2 two females?
3 A. Yes.
4 Q. Do you know who those two females were?
5 A. No.
6 Q. How long does the plane, the Gulfstream,
7 stay in Santa Fe?
8 A. Let's see. 1586, Gulfstream. I don't
9 really know, because apparently, we had 1586 and the
10 next one I see is 1589. So it flew three places,
11 but I wasn't on that trip.
12 Q. 1587 and 1588 are missing, right?
13 A. That is what I'm saying.
14 Q. Because you are not on it?
15 A. I'm not on the trip.
16 Q. And 1589?
17 A. Uh-huh.
18 Q. Leaving out of Santa Fe, who are the
19 passengers?
21 Kellen, Cindy Lopez, Virginia Roberts, Dan Moran,
22 Eduardo, Alfred, Margarita and Nick Simmons.
23 Q. Do you know how Virginia Roberts got to
24 Santa Fe?
25 A. No.
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2 Q. Is there any way to get to Santa Fe from,
3 say, Florida -- well, strike that.
4 MR. PAGLIUCA: Bus, train, car.
5 BY MR. EDWARDS:
6 Q. Did you ever know Virginia Roberts to take
7 a train?
8 A. Not that I'm aware.
9 Q. Did you ever know her to take a bus?
10 MR. REINHART: To go to New Mexico?
11 THE WITNESS: Not that I'm aware. Maybe
12 she has, but I don't know about it.
13 BY MR. EDWARDS:
14 Q. Okay. I have a picture of her on
15 horseback at the ranch, so who knows.
16 Let's see. August 17th, sorry,
17 August 18th.
18 A. Okay.
19 Q. From Teterboro to Palm Beach?
20 A. Right.
21 Q. Who are your passengers?
22 A. Jeffrey Epstein, Virginia Roberts, one
23 female.
24 Q. All right. Do you remember who that
25 female was?
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5
6 that DAVID RODGERS personally appeared before
me and was duly sworn.
this 8th day of June, 2016.
8
9
11 + + + + + + + + + + + + + + + + + +
12 CERTIFICATE

17 foregoing deposition of DAVID RODGERS; that a
stenographic notes.
in the action.
22 Dated this 8th day of June, 2016.
23
25
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EXHIBIT 16
(Filed Under Seal)
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------------------------------------------x
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
May 18, 2016

9:04 a.m.
Deposition of JOHANNA SJOBERG, pursuant
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1 Q. Okay. Great.
2 All right. Do you know a female by the
3 name of Ghislaine Maxwell?
4 A. Yes.
5 Q. And when did you first meet Ms. Maxwell?
6 A. 2001. March probably. End of
7 February/beginning of March.
8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I could tell her how to
13 find someone that would come and work at her house.
14 She wanted to know if there was, like, a bulletin
15 board or something that she could post, that she was
16 looking for someone to hire.
17 Q. And what did you discuss with her?
18 A. I told her where she could go to -- you
19 know, to put up a listing. And then she asked me if
20 I knew anyone that would be interested in working
21 for her.
22 Q. Did she describe what that work was going
23 to be?
24 A. She explained that she lived in Palm Beach
25 and didn't want butlers because they're too stuffy.
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1 And so she just liked to hire girls to work at the
2 house, answer phones, get drinks, do the job a
3 butler would do.
4 Q. And did she tell you what she would pay
5 for that kind of a job?
6 A. At that moment, no, but later in the day,
7 yes.
8 Q. And what did she say?
9 A. Twenty dollars an hour.
10 Q. Was there anybody else with Ms. Maxwell
11 when you met her?
12 A. There was another woman with her. I don't
13 recall her or what she looks like or how old she
14 was.
15 Q. And what happened next?
16 A. And then she asked me if I would be
17 interested in working for her. And she told me that
18 she was -- I could trust her and that I could jump
19 in her car and go check out the house at that moment
20 if I wanted.
21 And so I said, Sure, let's do it, and went
22 to her home with her.
23 Q. And where was that home?
24 A. In Palm Beach.
25 Q. And did she describe that home as being
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1 magazines.
2 She and I went -- she wanted to take me
3 shopping to Worth Avenue, but it was a Sunday and
4 Nieman Marcus was closed, so we went back to, like,
5 a little book store. And I remember she bought, I
6 think, five pairs of reading glasses because she
7 thought Jeffrey would like them. He had them all
8 over the house. On every table there was reading
9 glasses.
10 And that's about it. It was a pretty
11 simple day.
12 Q. Were you paid that day for that work?
13 A. Yes.
14 Q. And how much were you paid? Do you
15 remember?
16 A. I don't remember how many hours I was
17 there -- I was there. She paid me cash.
18 Q. So Maxwell paid you?
19 A. Yes.
20 Q. And then was she the one who trained you
21 with what -- with respect to what you were supposed
22 to do during the day, directed you to, like you
23 said, go to --
24 A. I believe she was the one that was kind of
25 showing me around.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3)<%-:%''3
Page 13
1 Q. And how long did you work in that position
2 answering phones and doing --
3 A. Just that one day.
4 Q. Just that one day.
5 And did your duties change?
6 A. Well, the next time she called me, she
7 asked me if I wanted to come over and make $100 an
8 hour rubbing feet.
9 Q. And what did you think of that offer?
10 A. I thought it was fantastic.
11 Q. And did you come over to the house for
12 that purpose?
13 A. Yes.
14 Q. And when you came over to the house, was
15 Maxwell present?
17 Q. And what happened that second time you
18 came to the house?
19 A. At that point, I met Emmy Taylor, and she
20 took me up to Jeffrey's bathroom and he was present.
21 And her and I both massaged Jeffrey. She was
22 showing me how to massage.
23 And then she -- he took -- he got off the
24 table, she got on the table. She took off her
25 clothes, got on the table, and then he was showing
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3)'%-:%''3
Page 14
1 me moves that he liked. And then I took my clothes
2 off. They asked me to get on the table so I could
3 feel it. Then they both massaged me.
4 Q. So it was more than a foot massage at that
5 point?
6 A. Yeah, it was mostly, like, legs and back.
7 Q. Was everybody in the room without clothes
8 on?
9 A. When they were on the massage table, yes.
10 Q. Did they -- when they got off the massage
11 table to perform the massage, did they dress or
12 did --
13 A. Yes.
14 Q. They dressed.
15 And do you recall who paid you for that
16 first day that you did the massages?
18 Q. Do you recall whether Maxwell was at the
19 house during that first day when you were doing the
20 massage with Emmy and Jeffrey?
21 MS. MENNINGER: Objection, asked and
22 answered.
23 BY MS. McCAWLEY:
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3)6%-:%''3
Page 15
1 Q. Who did Emmy work for?
2 A. Ghislaine.
3 Q. Did Maxwell ever refer to Emmy by any
4 particular term?
5 A. She called her her slave.
6 Q. You said your job duties changed. Did you
7 start to travel as part of your job with Jeffrey and
8 Ghislaine?
9 A. Yes. The next time they called me, they
10 asked me to go to New York.
11 Q. And did you -- do you recall when that was
12 approximately?
13 A. That was Easter of 2001.
14 Q. And do you recall who was on the plane
15 with you for that trip?
16 MS. MENNINGER: Objection, leading, form.
17 MS. McCAWLEY: Actually, I'm going to stop
18 really quickly and I'm going to ask for the
19 next exhibit, please.
20 MS. MENNINGER: This is 3?
21 MS. McCAWLEY: Yes. I'm going to mark
22 this as Exhibit 3 for purposes of the
23 deposition.
24
25
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$334%-:%''3
Page 27
1 leading.
2 THE WITNESS: Jeffrey Epstein; Ghislaine
3 Maxwell; AP and PK are the two women I do not
4 recall; Virginia Roberts; and myself.
5 BY MS. McCAWLEY:
6 Q. Do you recall how you flew back from the
7 location in the US Virgin Islands?
8 A. They put me on a commercial flight. I
9 wanted to be home in time for Easter.
10 Q. When you say "they," do you recall who
11 made those arrangements for you?
12 A. It could have been Ghislaine.
13 Q. Did you -- do you recall performing
14 massages while you were in the US Virgin Islands?
15 A. Yes.
16 Q. Who was involved in -- was there more than
17 one?
18 A. Yes. I massaged Ghislaine at one point.
19 And I massaged Jeffrey, Virginia and I, both, on the
20 beach.
21 Q. Were you dressed during the massage that
22 was on the beach?
23 A. Yes. Bikinis probably, most likely.
24 Q. Do you recall what Virginia was wearing?
25 A. I believe she was wearing a bathing suit,
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$33&%-:%''3
Page 32
1 to object and then you can still answer. No
2 one is going to stop you from answering. I
3 just need to get the objection on the record,
4 in the same way she needs to be able to talk
5 before you. My apologies. I'm not trying to
6 cut you off, but I am supposed to get it in
7 before you answer.
8 BY MS. McCAWLEY:
9 Q. Did Jeffrey ever tell you why he received
10 so many massages from so many different girls?
11 MS. MENNINGER: Objection, hearsay.
12 BY MS. McCAWLEY:
14 A. He explained to me that, in his opinion,
15 he needed to have three orgasms a day. It was
16 biological, like eating.
17 Q. And what was your reaction to that
18 statement?
19 A. I thought it was a little crazy.
20 Q. And what did -- do you recall what -- when
21 you observed the other females giving massages, do
22 you recall what they would dress like? Did they
23 wear scrubs or did they typically wear normal
24 clothes?
25 A. Normal clothes.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$33)%-:%''3
Page 33
1 MS. MENNINGER: Objection, leading.
2 BY MS. McCAWLEY:
3 Q. Do you believe that from your
4 observations, Maxwell and Epstein were boyfriend and
5 girlfriend?
6 A. Initially, yes.
7 Q. Did Maxwell ever share with you whether it
8 bothered her that Jeffrey had so many girls around?
9 MS. MENNINGER: Objection, leading,
10 hearsay.
11 THE WITNESS: No. Actually, the opposite.
12 BY MS. McCAWLEY:
13 Q. What did she say?
14 A. She let me know that she was -- she would
15 not be able to please him as much as he needed and
16 that is why there were other girls around.
17 Q. Did there ever come a time -- did you ever
18 take a photography class in school?
19 A. Yes.
20 Q. And did there ever come a time when
21 Maxwell offered to buy you a camera?
22 A. Yes.
24 BY MS. McCAWLEY:
25 Q. Did Maxwell ever offer to buy you a
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$333%-:%''3
Page 34
1 camera?
3 THE WITNESS: Yes.
4 BY MS. McCAWLEY:
5 Q. Was there anything you were supposed to do
6 in order to get the camera?
8 THE WITNESS: I did not know that there
9 were expectations of me to get the camera until
10 after. She had purchased the camera for me,
11 and I was over there giving Jeffrey a massage.
12 I did not know that she was in possession of
13 the camera until later.
14 She told me -- called me after I had left
15 and said, I have the camera for you, but you
16 cannot receive it yet because you came here and
17 didn't finish your job and I had to finish it
18 for you.
19 BY MS. McCAWLEY:
20 Q. And did you -- what did you understand her
21 to mean?
22 A. She was implying that I did not get
23 Jeffrey off, and so she had to do it.
24 Q. And when you say "get Jeffrey off," do you
25 mean bring him to orgasm?
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$337%-:%''3
Page 35
1 A. Yes.
2 Q. Did Ghislaine ever describe to you what
3 types of girls Jeffrey liked?
4 A. Model types.
5 Q. Did Ghislaine ever talk to you about how
6 you should act around Jeffrey?
7 A. She just had a conversation with me that I
8 should always act grateful.
9 Q. Did Jeffrey ever tell you that he took a
10 girl's virginity?
11 A. He did not tell me. He told a friend of
12 mine.
13 Q. And what do you recall about that?
14 MS. MENNINGER: Objection, hearsay,
15 foundation.
16 THE WITNESS: He wanted to have a friend
17 of mine come out who was cardio-kickboxer
18 instructor. She was a physical trainer.
19 And so I brought her over to the house,
20 and he told my friend Rachel that -- he said,
21 You see that girl over there laying by the
22 pool? She was 19. And he said, I just took
23 her virginity. And my friend Rachel was
24 mortified.
25
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$33;%-:%''3
Page 36
1 BY MS. McCAWLEY:
2 Q. Based on what you knew, did Maxwell know
3 that the type of massages Jeffrey was getting
4 typically involved sexual acts?
5 MS. MENNINGER: Objection, foundation,
6 leading.
7 THE WITNESS: Yes.
8 BY MS. McCAWLEY:
9 Q. What was Maxwell's main job with respect
10 to Jeffrey?
11 MS. MENNINGER: Objection, foundation.
12 THE WITNESS: Well, beyond companionship,
13 her job, as it related to me, was to find other
14 girls that would perform massages for him and
15 herself.
16 BY MS. McCAWLEY:
17 Q. Did Maxwell ever refer to the girls in a
18 particular way?
19 A. At one point when we were in the islands,
20 we were all watching a movie and she called us her
21 children.
22 Q. Did anybody respond to that?
24 Q. Did she ever refer to herself as a mother?
25 A. Yes, like a mother hen.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$33*%-:%''3
Page 64
1 Q. Do you remember anything notable about the
2 phone calls?
3 A. I just remember I always had to say, He's
4 unavailable, can I take a message?
5 Q. And where did you take a message?
6 A. On a little notepad next to the phone.
7 Q. Do you recall any small children calling
8 the house that day?
9 A. No.
10 Q. Were you speaking to anyone about their
11 school experience or anything like that?
12 A. No.
13 Q. Did you take any messages for famous
14 people?
15 A. They could have been famous and I would
16 have been clueless.
17 Q. Did you take messages at any other point
18 during the time that you worked with Jeffrey?
19 A. No.
20 Q. And you said you remember at the end of
21 that day being paid by Ghislaine?
22 A. Yes.
23 Q. And you were paid for doing the errands
24 and answering phones and whatever else you did?
25 A. Yes.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$33<%-:%''3
Page 82
1 Q. When you came upstairs, where was Virginia
2 sitting?
3 A. I don't remember.
4 Q. Do you remember what she was wearing?
5 A. No.
6 Q. She was already there when you got back
7 from sightseeing?
8 A. Yes.
9 Q. Tell me what happened with the caricature.
10 A. Ghislaine asked me to come to a closet.
11 She just said, Come with me. We went to a closet
12 and grabbed the puppet, the puppet of Prince Andrew.
13 And I knew it was Prince Andrew because I had
14 recognized him as a person. I didn't know who he
15 was.
16 And so when I saw the tag that said Prince
17 Andrew, then it clicked. I'm like, that's who it
18 is.
19 And we went down -- back down to the
20 living room, and she brought it in. It was just
21 funny because -- he thought it was funny because it
22 was him.
23 Q. Tell me how it came to be that there was a
24 picture taken.
25 MS. McCAWLEY: Objection.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$33'%-:%''3
Page 83
1 THE WITNESS: I just remember someone
2 suggesting a photo, and they told us to go get
3 on the couch. And so Andrew and Virginia sat
4 on the couch, and they put the puppet, the
5 puppet on her lap.
6 And so then I sat on Andrew's lap, and I
7 believe on my own volition, and they took the
8 puppet's hands and put it on Virginia's breast,
9 and so Andrew put his on mine.
11 Q. And this was done in a joking manner?
12 MS. McCAWLEY: Objection.
15 Q. Do you recall a photo being taken of that
16 event?
17 A. Yes.
18 Q. You've never seen the photo?
19 A. No.
20 Q. You don't know whose camera it was?
21 A. No.
22 Q. Virginia was sitting on the couch next to
23 Andrew, not in a big leather armchair?
24 A. Maybe. I'm just trying to remember how I
25 remember it.
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$336%-:%''3
Page 142
1 exposed her bra, and she grabbed it and pulled it
2 down.
3 Q. Anything else?
4 A. That was the conversation that he had told
5 her that he had taken this girl's virginity, the
6 girl by the pool.
7 Q. Okay. Did Maxwell ever say to you that it
8 takes the pressure off of her to have other girls
9 around?
10 A. She implied that, yes.
11 Q. In what way?
12 A. Sexually.
13 Q. And earlier Laura asked you, I believe, if
14 Maxwell ever asked you to perform any sexual acts,
15 and I believe your testimony was no, but then you
16 also previously stated that during the camera
17 incident that Maxwell had talked to you about not
18 finishing the job.
19 Did you understand "not finishing the job"
20 meaning bringing Jeffrey to orgasm?
22 BY MS. McCAWLEY:
23 Q. I'm sorry, Johanna, let me correct that
24 question.
25 What did you understand Maxwell to mean
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$374%-:%''3
Page 143
1 when she said you hadn't finished the job, with
2 respect to the camera?
4 THE WITNESS: She implied that I had not
5 brought him to orgasm.
6 BY MS. McCAWLEY:
7 Q. So is it fair to say that Maxwell expected
8 you to perform sexual acts when you were massaging
9 Jeffrey?
10 MS. MENNINGER: Objection, leading, form,
11 foundation.
12 THE WITNESS: I can answer?
13 Yes, I took that conversation to mean that
14 is what was expected of me.
15 BY MS. McCAWLEY:
16 Q. And then you mentioned, I believe, when
17 you were testifying earlier that Jeffrey told you a
18 story about sex on the plane. What was that about?
19 MS. MENNINGER: Objection, hearsay.
20 THE WITNESS: He told me one time Emmy was
21 sleeping on the plane, and they were getting
22 ready to land. And he went and woke her up,
23 and she thought that meant he wanted a blow
24 job, so she started to unzip his pants, and he
25 said, No, no, no, you just have to be awake for
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$37&%-:%''3
Page 150
1 A. No.
2 Q. Was it in the context of anything?
3 A. About the camera that she had bought for
4 me.
5 Q. What did she say in relationship to the
6 camera that she bought for you and taking
7 photographs of you?
8 A. Just that Jeffrey would like to have some
9 photos of me, and she asked me to take photos of
10 myself.
11 Q. What did you say?
12 A. I don't remember saying no, but I never
13 ended up following through. I think I tried once.
14 Q. This was the pre-selfie era, correct?
15 A. Exactly.
16 Q. I want to go back to this: You testified
17 to two things just now with Sigrid that you said
18 were implied to you.
19 A. Okay.
20 Q. The first one was it would take pressure
21 off of Maxwell to have more girls around?
22 A. Right.
23 Q. What exactly did Maxwell say to you that
24 led you to believe that was her implication?
25 A. She said she doesn't have the time or
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$37)%-:%''3
Page 160
1
: ss
9 That JOHANNA SJOBERG, the witness whose
18 my hand this 18th day of May, 2016.
19
20 __________________________
21
22
23
24
25
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$373%-:%''3
EXHIBIT 17
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$377%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$37;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$37*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$37<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$37'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$376%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;4%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;3%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;7%-:%''3
EXHIBIT 18
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3;6%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3*4%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3*&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3*)%-:%''3
EXHIBIT 19
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3*3%-:%''3
Page 1
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO:502008CA028051XXXXMB AB
L.M.
Plaintiff,
-vs-
JEFFREY EPSTEIN
AND SARAH KELLEN,
Defendants.
______________________________/
DEPOSITION OF JANUSZ BANASIAK
Tuesday, February 16, 2010

10:09 - 2:30 p.m.
250 Australian Avenue South

Suite 1500
West Palm Beach, Florida 33401
Reported By:
Cynthia Hopkins, RPR, FPR
Notary Public, State of Florida
Prose Court Reporting
Job No.: 1317
(561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506

Electronically signed by cynthia hopkins (601-051-976-2934)
Electronically signed by cynthia hopkins (601-051-976-2934) 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e
GIUFFRE004424
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3*7%-:%''3
Page 8
1 Q. What family was that?
2 A. It's, it was an older house in New York. I
3 worked there for seven years, no, five years before I
4 get the job in the Seagram company. So, I guess I had
5 some experience to continue.
6 Q. Do you remember the name of the family
7 that you worked with for seven years in New York?
8 A. Frank, Frank.
9 Q. His name is something Frank, F-r-a-n-k?
10 A. Yes.
11 Q. Do you remember the first name?
12 A. Fredrick.
13 Q. And were your duties as house manager for
14 Fredrick Frank similar to your duties as house
15 manager for Jeffrey Epstein?
16 A. Yes, yes.
17 Q. And when you started in 2005 when you
18 heard that there was a job position with Jeffrey
19 Epstein, did you interview for that position?
20 A. Yes.
21 Q. Who did you interview with?
22 A. First I got interviewed with Ghislaine
23 Maxwell.
24 Q. And that's G-h-i-s-l-a-i-n-e, Maxwell?
25 A. Right, right.

GIUFFRE004431
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3*;%-:%''3
Page 9
1 Q. Where did that interview take place?
2 A. In New York.
3 Q. And it was for the position as house
4 manager in the Palm Beach house, correct?
5 A. Right.
6 Q. That's at 358 Albrillo way?
7 A. Correct.
8 Q. Why were you interviewed in New York, if
9 you know?
10 A. Because at that time I was living in New York
11 with my friends and so --
12 Q. Where did the interview take place in New
13 York?
14 A. In her house on 65th Street.
15 Q. Whose house, do you know?
16 A. Ghislaine Maxwell.
17 Q. So, Ghislaine Maxwell interviewed you back
18 in 2005 at her house in New York for a position at
19 Jeffrey Epstein's house in Palm Beach?
20 A. Right.
21 Q. And what did the interview consist of?
22 What did she ask you?
23 A. She asked me basic questions, you know, what's
24 my previous employer, how long I work for them and
25 basically she was checking my resume.

GIUFFRE004432
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3**%-:%''3
Page 14
1 Q. Okay. So, I assume then that your wife
2 that you are separated from I guess at the time, she
3 didn't come down to Palm Beach?
4 A. No, no.
5 Q. And this is somebody who still lives
6 somewhere other than Florida?
7 A. Correct.
8 Q. So, you came down in February 2005 and
9 began working. What did you, what did you first
10 start doing for Jeffrey Epstein?
11 A. First I doing? I don't remember nothing
12 special.
13 Q. Okay. Well, were you working -- I will
14 rephrase it. Were you working only for Jeffrey
15 Epstein or were you working also for Ghislaine
16 Maxwell, the other person who interviewed you, or
17 anybody else in the house?
18 A. I guess only for him because she was visiting
19 a few times house, but I am employed by him.
20 Q. Okay. What was your understanding at that
21 time as to the relationship between Ghislaine
22 Maxwell and Jeffrey Epstein?
23 A. They were like partners in business.
24 Q. Okay. What business was that, if you
25 know?

GIUFFRE004437
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3*<%-:%''3
Page 15
1 A. I don't know what kind of business but she was
2 the one who organized I would say employment with this
3 organization. So, whatever I need, if I have some kind
4 of problem, I contact her. She was the one who decided
5 what I have to answer my problems with, what I was
6 supposed to do.
7 Q. How many times did you have problems where
8 you had to go through her?
9 A. Well, not big problems. Just a question of
10 what certain, how to do certain things. For example,
11 what kind of flowers I have to buy, what kind of things
12 he likes, what time I supposed to serve him coffee in
13 the mornings, sort of organizing things.
14 Q. Those are things that you wouldn't ask
15 Jeffrey Epstein directly?
16 A. No, no. He doesn't like those things to ask
17 him directly. He would like to prefer either through
18 his assistant or like I say, Ghislaine Maxwell.
19 Q. Is that still the same today?
20 A. Yes, still the same. Unless, something happen
21 that I need to, nobody is around and I need to urgently
22 contact him, I go to him directly.
23 Q. So, for the most part if you have a
24 question or at least -- let's go back to 2005, you
25 had a question about what needed to be done in the

GIUFFRE004438
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3*'%-:%''3
Page 54
1 A. (Witness shakes head.)
2 Q. And I'm sorry.
3 A. No.
4 Q. I understood you when you shook your head.
5 A. I realize what you told me but I am sorry.
6 Q. I told you it was easy to forget.
7 Do you remember who it was that personally
8 removed the computers and equipment from the
9 property? Was it Mr. Epstein, was it a lawyer, was
10 it, do you remember?
11 A. It was Adriana.
12 Q. All right. And I am of the understanding
13 that there were several computers that were removed
14 from the house, correct?
15 MR. GOLDBERGER: Form.
16 THE WITNESS: Yes, three of them.
17 BY MR. EDWARDS:
18 Q. Three? And to your knowledge Adriana
19 removed all of them?
20 A. She show up one day with gentleman. I don't
21 remember his name. And she told me that they are moving
22 out those computers.
23 Q. And where were the computers? Which rooms
24 were the computers in that were removed by Adriana
25 and this gentleman you're describing?

GIUFFRE004477
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Page 191
2 THE STATE OF FLORIDA
5
6 I, the undersigned authority, certify that
7 JANUSZ BANASIAK personally appeared before me
8 and was duly sworn on the 16th day of February,
9 2010.
10
11 Dated this 28th day of February, 2010.
12
13
14
15
_________________________________
16
17 Notary Public - State of Florida
My Commission Expires: February 25, 2011
18 My Commission No.: DD 643788
19
20
21
22
23
24
25

GIUFFRE004614
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<4%-:%''3
Page 192
2 THE STATE OF FLORIDA
4
5 I, Cynthia Hopkins, Registered Professional
Reporter, Florida Professional Reporter and Notary
6 Public in and for the State of Florida at large, do
7 report said deposition in stenotype; and that the
foregoing pages are a true and correct transcription
8 of my shorthand notes of said deposition.
9 I further certify that said deposition was
taken at the time and place hereinabove set forth
10 and that the taking of said deposition was commenced
and completed as hereinabove set out.
11
I further certify that I am not attorney or
12 counsel of any of the parties, nor am I a relative
or employee of any attorney or counsel of party
13 connected with the action, nor am I financially
interested in the action.
14
The foregoing certification of this transcript
15 does not apply to any reproduction of the same by
any means unless under the direct control and/or
16 direction of the certifying reporter.
17 Dated this 28th day of February, 2010.
18
19
20
21 _____________________________________
22
23
24
25

GIUFFRE004615
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<&%-:%''3
EXHIBIT 20
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<)%-:%''3
GIUFFRE004386
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<3%-:%''3
GIUFFRE004388
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<7%-:%''3
GIUFFRE004408
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<;%-:%''3
GIUFFRE004420
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<*%-:%''3
EXHIBIT 21
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3<6%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3'4%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3'&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3')%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3'3%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3'7%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3';%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3'*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3'<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3''%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$3'6%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$364%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$36&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$36)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$363%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$367%-:%''3
EXHIBIT 22
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$36;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$36*%-:%''3
14. 2015.01.11 - E-Mails 1059- Jeffrey Epstein Ghislaine Maxwell Common Interest Communication
2015.01.17 1083 re: legal advice
15. 2015.01.13 E-Mail 1067- Ghislaine Maxwell Jeffrey Epstein Common Interest Communication
1073 re: legal advice
16. 2015.01.13 E-Mail 1069- Philip Barden, Esq. Martin Weinberg, Esq. Common Interest Communication
1073, re: legal advice
1076-
1079
17. 2015.01.13 E-Mails 1068- Philip Barden, Esq. Ghislaine Maxwell Mark Attorney / Client Communication
1069, Cohen re: legal advice
1074-
1076
18. 2015.01.21 E-Mail 1088- Ross Gow Philip Barden, Esq., Ghislaine Agent / Attorney / Communication
1090 Maxwell Client re: legal advice
19. 2015.01.21 - E-Mails 1084- Jeffrey Epstein Ghislaine Maxwell Common Interest Communication
2015.01.27 1098 re: legal advice
20. 2015.01.21- E-Mails 1099 Ghislaine Maxwell Jeffrey Epstein Common Interest Communication
2015.01.27 re: legal advice
21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding
message from
Martin Weinberg,
labeled “Attorney
Client Privilege”
with attachment
22. Various E-mails Agent of Haddon, Agent of Haddon, Morgan & Agent of attorney and Attorney work
Morgan & Foreman; Foreman; Laura Menninger Attorney product
Laura Menninger
23. Various E-mails Mary Borja; Laura Mary Borja; Laura Menninger Attorney Work Attorney work
Menninger Product product
24. 2015.10.21 - E-mail Darren Indyke; Laura Darren Indyke; Laura Menninger Attorneys for parties Common Interest
2015.10.22 chain with Menninger to Common Interest Agreement
attachment Agreement
25. 2015.01.06 Attorney/Client Document
prepared by
Ghislaine
Maxwell at the
direction of Philip
Barden
2
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$36<%-:%''3
26. 2015.01.23 Attorney/Client Document

prepared by
Ghislaine
Maxwell at the
direction of Philip
Barden
3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$36'%-:%''3
EXHIBIT 23
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$366%-:%''3
Expert Report of Professor Terry Coonan, J.D.

Pursuant to Federal Rule of Civil Procedure 26(a)(2)(B)
Giuffre v. Maxwell
Case No. 15-cv-07433-RWS
1
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$744%-:%''3
international commercial dimensions of the sex trafficking scheme recounted by Ms. Giuffre. It
is both factually and legally correct to characterize what Ms. Giuffre experienced as
victimization in a sex trafficking conspiracy.
Conclusion 4
Virginia Roberts Giuffre’s account appears credible and consistent in its most salient parts
with the testimony of other witnesses and with contemporary trends in U.S. sex trafficking.
The description of exploitation recounted by Ms. Giuffre, while not the most common
sex trafficking scenario (many cases involve even more brutal forms of pimp-driven prostitution)
nonetheless is quite consistent with larger patterns of commercial sexual exploitation. The
conspiracy in this case was premised upon the exploitation of minors and young women who
seem to have had certain identifiable vulnerabilities that rendered them prone to exploitation.
The criminal scheme that emerges from the depositions and police reports involved a very
calculated pattern of recruiting, grooming, and an attempt to “normalize” the repeated
exploitation of its victims.
While the accounts of witnesses vary in some of their details, the essential elements of a
sex trafficking conspiracy clearly emerge when viewed in the totality of the circumstances that
are recounted in the case record. Ms. Giuffre refers to herself at times as a “sex slave.” This is
not factually incorrect, given her experiences, though current U.S. law might prefer to
characterize her as a victim of sex trafficking. Popular understandings of the term “sex slave”
might still connote images of violent pimps, white slavery, or of victims chained to a bed in a
brothel in the minds of some people. To call Ms. Giuffre a victim of sex trafficking would
however very accurately convey the reality that she along with a great many other victims of
contemporary forms of slavery are often exploited by the “invisible chains” of fraud and
psychological coercion.
20
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$74&%-:%''3
EXHIBIT 24
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$74)%-:%''3
Expert Witness Report of
Dr. Bernard J. Jansen

Professor
College of Information Sciences and Technology
The Pennsylvania State University
Regarding the case of:
Virginia Giuffre
v.
Ghislaine Maxwell
(U.S. District Court for the Southern District of New York)
9 September 2016
1
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$743%-:%''3
I. INTRODUCTION
1. I have been retained by the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos
& Lehrman, P.L. to provide expert analysis and opinion on behalf of Ms. Virginia Giuffre in
VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-
cv-07433, which is pending in the United States District Court Southern District of New York.
II. QUALIFICATIONS
2. I am a tenured, full professor at the College of Information Sciences and
Technology at The Pennsylvania State University, University Park, Pennsylvania, where I have
been employed since 2001. I am the Director of the Information Searching and Learning
Laboratory at the College of Information Sciences and Technology at The Pennsylvania State
University. I am also a principal scientist at the Qatar Computing Research Institute. I was a
Senior Fellow at the Pew Internet & American Life Project, which is part of the Pew Research
Center, from 2010 through 2012. I was also a University Expert at the National Ground
Intelligence Center from 2011 through 2014. Prior to my employment at The Pennsylvania State
University, I was a Lecturer in the Computer Science Program at the University of Maryland
(Asian Division) for 1 year. Before that I was an Assistant Professor and Lecturer in the
Department of Electrical Engineering and Computer Science at the United States Military
Academy, a.k.a. West Point, for 3 years.
3. In addition to my academic credentials, my professional experience includes 20
years of practice in the U.S. military, working primarily in a variety of technology-related and
leadership positions.
4. I have authored approximately 250 academic publications, focusing on the areas of
Web data, digital analytics, Web analytics, Web searching, Web search engines, social media
analytics, and related areas. Approximately 200 of my publications address aspects of search
2
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$747%-:%''3
analytics, Web analytics, online advertising, search engines, or Web searching. My recent research
work focuses on online news analytics, which is the investigation of the online qualitative and
quantitative attributes of news stories, along with other digital content. I am also the editor-in-chief
of the academic journal Information Processing and Management, and I was previously the editor-
in-chief for 5 years of the academic journal, Internet Research. I have authored, co-authored, or
co-edited four books, including Web Search: Public Searching of the Web (2007), Understanding
User – Web Interactions via Web Analytics (2009) and Understanding Sponsored Search (2011).
A copy of my complete curriculum vitae, which includes a list of all publications I have authored
in the past 10 years, is attached as Appendix A.
5. My fields of professional expertise include web analytics, search engines, web
searching, social media, online advertising, and related areas. In the course of my academic career,
I have worked with a variety of search engines and information searching applications in order to
understand user searching behavior on the Web and other environments. For example, as part of
my Master’s program in computer science, I designed and coded a text-based search engine. For
my Doctorate program in computer science, I developed a program interface for Web search
engines and implemented it on the Gigabyte search engine. In subsequent research, I have worked
with the Microsoft Internet Information Services (IIS) and Verity commercial searching systems.
6. Concerning user searching behaviors on the Web using web analytics, I have
worked directly with real-user searching data from several search engines, including AOL, Alta
Vista, Dogpile, Excite, and MSN Live. I’ve also analyzed web data of visitor traffic and other
attributes from a variety of websites and social media platforms. I’ve analyzed real-user data from
online search marketing campaigns and user referral traffic to websites. I have conduct research
and teaching concerning aspects of websites and social media platforms, including keyword
3
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advertising. I’ve developed web analytics models and processes for analysis of business goals,
and I have used web analytics data and commercial tools in both my research and teaching. I’ve
also conducted other research on user searching and related online behaviors. I have advised
governmental agencies and companies in consulting and expert witnessing matters. A list of cases
in which I have testified as an expert in deposition or trial in the past four years is attached as
Appendix B. I am being compensated for my work on this case at the rate of $300 per hour.
III. ASSIGNMENT AND MATERIALS CONSIDERED
7. In providing my expert opinion, I have been asked to respond to the following
question:
8. What is the dissemination of the statements from Ms. Maxwell referring to
Ms. Giuffre’s declarations as “untrue” and “lies” from when the statements were made on 2
January 2015 to the date that I filed this report?
9. For brevity, I refer to references to the statements denoting Ms. Giuffre’s
declarations as “untrue” and “lies”, any related accounts referring to those original statements, or
similar statements from Ms. Maxwell or her representatives referring to Ms. Giuffre as the
statements made against Ms. Giuffre, the statements from Ms. Maxwell’s message, or the message
from Mr. Gow1.
10. My analysis is based on my experience, training, knowledge, and education and is
formed through the application of that experience, training, knowledge, and education in the
principles of web data collection, web analytics, web search, search engines, web sites, web traffic
analysis, and related market analysis.
11. The materials that I considered in preparing this report are listed in Appendix C.
1
See, para. 30 and 32, Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433.
4
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IV. SUMMARY OF OPINIONS
12. Based on my research and analysis in connection with this assignment, which is
described in more detail in the body of this report, along with my own experience, training,
knowledge, and education as stated below, I have reached the following opinion:
13. The statements made against Ms. Giuffre have been disseminated to at least
115 online media or other sites in 178 separate stories or articles with a combined
66,909,965 potential unique visitors since 2 January 2015 to the date that I filed this report,
inclusive.
14. This is a conservative estimate, and it is more likely than not, the statements made
by Ms. Maxwell against Ms. Giuffre have received wider dissemination due to factors such as:
a. I used a set of online websites to measure dissemination, and it is
reasonable that I have not located all references to the statements made against Ms. Giuffre on
every website by the time of the submission of this report.
b. I examined only online sources referencing the statements made against
Ms. Giuffre and not print or broadcast media dissemination of the statements made against Ms.
Giuffre.
c. I have not attempted to measure face-to-face dissemination of articles
containing the statements against Ms. Giuffre.
d. I do not have access to certain online sources where articles containing the
statements against Ms. Giuffre may have been disseminated (e.g., email messages, personal
social media messages, articles behind firewalls, etc.).
e. There are possibly sites that have hosted the statements made against Ms.
Giuffre that I could not locate or where the statements have been removed.
5
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$74<%-:%''3
f. There are sites that hosted the articles containing the statements made
against Ms. Giuffre where the visitor data is not accessible or where I could not confirm the
number of visitors.
g. I did not consider the dissemination via social media platforms of articles
containing the statements made against Ms. Giuffre.
h. Many sites published multiple articles on multiple days that contained or
referenced the statements made against Ms. Giuffre; however, I did not include these multiple
publication dates in calculating unique daily visitors.
i. I did not include unique daily visitors to articles that link from that article
to one or more of the articles containing the statements made against Ms. Giuffre.
j. Finally, I did not include the counts of those who may have been searching
and seen the statements made against Ms. Giuffre in the search results listing.
V. BACKGROUND WEB ANALYTICS FOR TRAFFIC ANALYSIS
15. In the course of forming this opinion, I implemented numerous web analytics and
related techniques commonly used in the industry. In order to more clearly discuss these
techniques, I define the following terms:
x Direct Traffic: visitors to a website that come from entering a website link
into a browser location bar (e.g., not coming via a link on another website).
x Dissemination: the act of spreading or the circulation of information or
articles.
x Domain: a specific Internet website that are administered as a unit and
defined by an Internet Protocol (IP) address.
6
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x Reach: the percentage or number of people who visit a website out of the
total targeted population.
x Referral Traffic: visitors to a site that come from websites other than
search engines.
x Repeat Visits: visitor traffic to a website in a given period that just includes
multiple visits from the same set of IP addresses (i.e., IP addresses with more than one visit);
provides a count of the people who have visited a site more than once in a given period. An
individual is usually defined by a combination of IP address and browser within a given period but
can also be defined by more sophisticated methods.
x Search Engine: a program and associated hardware and processes that
allows people to find information on the Web, typically via the submission of queries consisting
of terms.
x Search Traffic: visitors to a site that come from search engines rather than
from other websites or via direct navigation.
x Search: a submission of a query to a search engine, usually in the form of
terms forming a query.
x Share: sharing of an article or webpage typically via some social media
platform.
x Social Media: content that is shared via a social networking website.
x Unique Visits: visitor traffic to a website within a given period that includes
only the first visit (i.e., subsequent visits are ignored), which excludes repeat visits; provides a
count of the individuals who have visited a site in a given period.
7
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x Unique Daily Visitors: visitor traffic to a website who visits a site at least
once in a given 24-hour period. Each visitor, to the site, is counted once during the reporting period,
which means it excludes repeat visits; provides a count of the individuals who have visited a site
on a given day.
x Visits: a count of all the traffic to a website in a given period, including both
unique and repeat visits.
x Web Analytics: the measurement, collection, analysis and reporting of web
data.
VI. METHODOLOGY
16. I was asked to determine the dissemination of articles containing the statements
made against Ms. Giuffre.
17. In forming my opinion, I utilized accepted web analytics and related
methodologies in developing my assessment.
18. To that end, I employed various publicly available online analytic services, as well
as some subscription-based services in conducting my research, including:
x Alexa: an online service that provides web traffic data and analysis.
x Compete: an online service that provides web traffic data and analysis.
x Google Keyword Tool: an online service that provides the number of
searches for a given set of keywords in a given month on the Google search engine.
x Google Trends: an online service that shows how often a particular term is
relatively searched on the Google search engine in a given period.
x SimiliarWeb: an online service that provides web traffic data and analysis.
x SpyFu: an online service providing search data and analytics, including for
both paid (i.e., advertisements) and organic (i.e., natural or algorithmic) channels.
x W3Snoop: an online service that provides web traffic data and analysis.
8
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19. These tools offer a variety of data and analysis services, and they are frequently
utilized by industry professionals in the search engine optimization, web analytics, and search
engine marketing fields for market, customer, and competitive analysis. Furthermore, where
possible, I did my own assessments, as outlined below, in order to validate the data and analysis
results.
20. I also utilized search engines, primarily Google and Bing, to assess the
dissemination of articles containing the statements made against Ms. Giuffre.
21. Whenever possible, I used multiple data sources, which is a data verification
technique known as triangulation2, where one uses multiple and disparate sources for analysis
and then compare the results from the separate analysis. If the results are similar, it reinforces
the conclusion that the overall data analysis is valid.
22. In all of my assessments, I have used the most conservative numbers, meaning
that I use the smallest value in arriving at the dissemination of articles containing the statements
made against Ms. Giuffre. If I had not employed this conservative estimate, the number of
potential dissemination of the articles containing the statements made against Ms. Giuffre would
be 102,740,816 (i.e., more than 102 million) daily unique visitors.
23. In situations where I believed that I could not adequately verify the number of
individuals or did not have confidence in the numbers in those situations, I did not include those
numbers in the calculation of daily unique visitors.
24. My analysis is based on my experience, training, knowledge, and education and is
formed through the application of that experience, training, knowledge, and education in the
2
Triangulation (social science) http://en.wikipedia.org/wiki/Triangulation_%28social_science%29
9
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principles of web data collection, web analytics, web search, search engines, web sites, and
related areas.
VII. DISSEMINATION OF THE STATEMENTS MADE AGAINST MS. GIUFFRE
25. My opinion is that articles containing the statements made against Ms. Giuffre
have been disseminated to at least 115 online media and others sites in 178 separate stories or
articles with a combine 66,909,965 unique daily visitors.
26. This is a conservative estimate, and it is more likely than not, the statements have
received wider dissemination due to factors such as:
a. I used a set of online websites (115) to calculate the dissemination of
articles, and it is reasonable that I have not located all references to the statements made against
Ms. Giuffre by the time of the submission of this report. So, there may be more sites with
articles containing the statements made against Ms. Giuffre that are not included in my
calculations.
b. My focus of analysis was the online dissemination of the statements made
against Ms. Giuffre. Therefore, I examined only online sources and not dissemination of the
statements made against Ms. Giuffre via print or broadcast media. It is reasonable to assume that
the statements made against Ms. Giuffre were disseminated via these other channels.
c. I have not attempted to measure face-to-face dissemination of the
statements made against Ms. Giuffre. Therefore, these sources of dissemination are not included
in the count of daily unique visitors.
d. I did not have access to certain online sources where the statements
against Ms. Giuffre may have been disseminated (e.g., email messages, social media messages,
10
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7&)%-:%''3
articles behind firewalls, etc.). Therefore, these sources are not included in the count of daily
unique visitors.
e. There may be sites that have hosted articles containing the statements
made against Ms. Giuffre where the articles have been removed. Therefore, I did not include
these sites in my calculation of the unique daily visitors.
f. There are sites where the visitor data is not accessible or where I could not
reasonably check the number of visitors. In these cases, even though I had confirmed the site
had posted one or more articles containing the statements made against Ms. Giuffre, I did not
include these sites in my calculation of the unique daily visitors.
g. I did not consider the dissemination via social media platforms of articles
h. Many sites published multiple articles on multiple days that contain or
reference the statements made against Ms. Giuffre; however, I did not use these multiple articles
from the same site with different publication dates in my calculations in determining the number
of daily unique visitors who have been exposed to the articles containing the statements made
against Ms. Giuffre.
i. I did not include articles that link to one or more of the articles containing
the statements made against Ms. Giuffre. Unless the article directly referenced the statements
made against Ms. Giuffre, I did not include it in my analysis.
j. Finally, I did not include people who may been searching and may have
seen the statements made against Ms. Giuffre in the search results, without needing to visit the
actual articles posted on the websites.
11
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VIII. METHODOLOGY TO DETERMINE THE DISSEMINATION OF THE
STATEMENTS MADE AGAINST MS. GIUFFRE
27. I have been informed that the statements made against Ms. Giuffre were
originally contained in an email message from Mr. Ross Gow3, of Acuity Reputation, acting on
behalf of Ms. Maxwell, that was sent on 2 January 2015 at 8:38 pm4 to, based on the email
addresses5, people at The Mail Online6, The Independent7, The Mirror8, The Times9, and the
BBC10. The email message from Mr. Gow contained the statements made against Ms. Giuffre. A
screen shot of the email message is shown in Figure 1.
28. Figure 1: Email message from Mr. Ross Gow containing the statements made
against Ms. Giuffre.
3
GM_00068 (Gow E-Mail)
4
I am assuming, based on the location of Mr. Gow’s company, Acuity Reputation, that this is date-time stamp for the United Kingdom.
5
Note: For some reason, the contact at the Mail Online is on the cc: line, while the other recipients are in the to: line. Also, the email message is
sent to two recipients at the BBC.
6
https://en.wikipedia.org/wiki/Mail_Online
7
https://en.wikipedia.org/wiki/The_Independent
8
https://en.wikipedia.org/wiki/Daily_Mirror
9
https://en.wikipedia.org/wiki/The_Times
10
https://en.wikipedia.org/wiki/BBC_News
12
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7&7%-:%''3
29. I have been informed that the statements made against Ms. Giuffre were
confirmed by Ms. Maxwell in a news article and video11 aired on 5 January 2015, which I have
established by reviewing the video referenced in the news article12.
11
GIUFFRE001120
12
http://www.nydailynews.com/news/world/alleged-madame-accused-supplying-prince-andrew-article-1.2065505
13
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7&;%-:%''3
30. Additionally, on 8 January 2015, agents reportedly acting on behalf of Ms.
Maxwell made statements that the allegations against her were a “web of lies and deceit”13,
which are similar to the statements made against Ms. Giuffre in the message from Mr. Gow.
31. Similarly, on 1 February 2015, like statements were quoted as “These allegations
are untrue and defamatory”14, which are similar to the statements made against Ms. Giuffre in
the message from Mr. Gow.
32. Based on my investigation and research, news stories, articles, and postings
containing direct reference to or quotes from the statements made against Ms. Giuffre appeared
the same day (i.e., 2 January 2015) as the email from Mr. Gow, with several news organizations
and other sites publishing other articles containing direct reference to or quotes from the
statements made against Ms. Giuffre in the immediately following days. News articles
containing direct reference to or quotes of the statements made against Ms. Giuffre have
continued to appear in news articles and other postings nearly up to the date that I submitted this
report.
33. A timeline of events relating to the dissemination of the statements made against
Ms. Giuffre is shown in Figure 2.
34. Figure 2: Timeline of events relating to the dissemination of the statements
made against Ms. Giuffre from 2 January 2015 onwards.
13
https://www.thesun.co.uk/archives/news/6754/prince-andrews-pal-ghislaine-groped-teen-girls/
14
http://www.mirror.co.uk/news/uk-news/prince-andrews-pal-ghislaine-maxwell-5081971
14
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7&*%-:%''3
35. Concerning the procedure employed in determining the dissemination of the
statements made against Ms. Giuffre, nearly every major news site15 that I investigated, along
with other specific news sites in the United States, the United Kingdom, Canada, and Australia,
as well as other countries, have carried some aspects of the overall story related to Ms. Giuffre
and/or Ms. Maxwell, or other parties involved.
36. In fact, there are tens of thousands of news articles and postings concerning the
general story from news outlets worldwide, with combined potential viewership in the multi-
millions, as searches on the major search engines, such as Google and Bing, show.
15
Including the largest online news sites, such as Yahoo! News, Google News, Huffington Post, CNN, NY Times, Fox News, NBC News, Daily
Mail, Washington Post, The Guardian, Wall Street Journal, ABC News, BBC News, USA Today, LA Times (see
http://www.ebizmba.com/articles/news-websites)
15
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7&<%-:%''3
37. However, I was not interested in news articles that just discussed the story in
general or other aspects of the story. Also, I was not interested in those articles where Ms.
Maxwell or those acting on her behalf, such as Mr. Gow, would just generally deny the
allegations in the complaint16. I was specifically interested in only those articles that referenced
directly or quoted the statements made against Ms. Giuffre in the 2 January 2015 email message
from Mr. Gow, Ms. Maxwell’s subsequent confirmation of the statements, or similar statements
as those in the message from Mr. Gow. Naturally, this narrow focus is a smaller subset of news
articles than are the articles addressing the overall story.
38. To isolate these articles of interest, I generated a series of 10 queries17 that
specifically targeted news articles from the case that addressed the statements made against Ms.
Maxwell (e.g., Ghislaine Maxwell obvious lies) to retrieve a set of articles that directly related to
the statements made against Ms. Giuffre18. I employed a modified snowball technique19, starting
with one seed query, adding and modifying terms, until I was not retrieving new results. I also
located some articles via navigating from the set of retrieved articles.
39. I set the search range date from 2 January 2015 onward, so articles prior to that
date were not included in the search results. For each article used in my analysis, I also verified
the date that the article was published to ensure it was published on or after 2 January 2015 and
that the articles directly referenced in some way the statements made against Ms. Giuffre.
40. An example of a search engine results page in response to one of these queries is
shown in Figure 3.
16
Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. CASE NO. 1:15-cv-07433.
17
Ghislaine Maxwell obvious lies, Ghislaine Maxwell Roberts obvious lies cnn, Ghislaine Maxwell Virginia Roberts, Giuffre Maxwell obvious
lies, new york daily news alleged madam andrews, Prince Andrew Maxwell Roberts, Prince Andrew obvious lies, prince andrew's sex slave
scandal who is maxwell, Ross Gow obvious lies, sex slave obvious lies.
18
In addition to the queries, I located some articles via direction navigation.
19
https://en.wikipedia.org/wiki/Snowball_sampling
16
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7&'%-:%''3
41. Figure 3: Google News search results for the search Ghislaine Maxwell
obvious lies with a date delimiter beginning on 2 January 2015.
42. I then personally verified that each article, by reviewing each article, used in my
analysis directly referenced in some way the statements made against Ms. Giuffre.
43. So, articles relating to the overall story that did not mention Ms. Maxwell’s
statements made against Ms. Giuffre were not included in the analysis. Articles relating to the
overall story that referred to Ms. Maxwell simply denying the charges were not included.
44. I also personally performed a site search20 of the top 15 online media sites
worldwide21 of articles related to the case, and I reviewed the results to identify if any of these
20
https://www.google.com/advanced_search
21
Yahoo! News, Google News, Huffington Post, CNN, NY Times, Fox News, NBC News, Daily Mail, Washington Post, The Guardian, Wall
Street Journal, ABC News, BBC News, USA Today, LA Times (see http://www.ebizmba.com/articles/news-websites)
17
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7&6%-:%''3
articles referred to the statements against Ms. Giuffre. I also did the same for many country-
specific news sites in the United States, the United Kingdom, Canada, and Australia.
45. In the end, I had a set of 178 online news and other articles from 2 January 2105
to the date that I filed this report that specifically referenced the statements made against Ms.
Giuffre to conduct my analysis, as outlined below.
46. Each of these 178 online articles was posted online. The 178 online articles were
distributed among 115 unique domain websites (i.e., some websites posted multiple articles that
contain the statements made against Ms. Giuffre). These 115 domains are:
x http://beforeitsnews.com
x http://boltonbnp.blogspot.com
x http://businessnewsusa.org
x http://dukefmduluth.com
x http://dukefmfargo.com
x http://home.bt.com
x http://jewishbusinessnews.com
x http://jewishnews.timesofisrael.com
x http://kdal610.com
x http://kfgo.com
x http://motivatornews.com
x http://mrharrywales.tumblr.com
x http://muhammad-ali-ben-marcus.blogspot.com
x http://news.sky.com
x http://news.trust.org
x http://newsbite.it
x http://newstoday.club
x http://normanfinkelstein.com
x http://onewayempire.com
x http://pagesix.com
x http://planetinvestigations.com
x http://softwaresuites.ne
x http://thisviral.com
x http://townhall.com
x http://ugandansatheart.blogspot.com
x http://uk.reuters.com
x http://whatiswrongwiththispicture2012.blogspot.com
x http://whbl.com
x http://whtc.com
18
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7)4%-:%''3
x http://wibqam.com
x http://wifc.com
x http://wincountry.com
x http://wkzo.com
x http://worlddailynews.info
x http://wsau.com
x http://wtaq.com
x http://wtvbam.com
x http://www.anorak.co.uk
x http://www.aol.co.uk
x http://www.asianimage.co.uk
x http://www.bailiwickexpress.com
x http://www.bannednews.net
x http://www.bbc.com
x http://www.belfasttelegraph.co.uk
x http://www.bournemouthecho.co.uk
x http://www.businessinsider.com
x http://www.business-standard.com
x http://www.capitalbay.news
x http://www.clactonandfrintongazette.co.uk
x http://www.courthousenews.com
x http://www.dailylife.com.au
x http://www.dailymail.co.uk
x http://www.dailyrecord.co.uk
x http://www.darkpolitricks.com
x http://www.dudleynews.co.uk
x http://www.eveningtimes.co.uk
x http://www.express.co.uk
x http://www.faceiraq.com
x http://www.ghanagrio.com
x http://www.ghanareview.com
x http://www.govtslaves.info
x http://www.headlines-news.com
x http://www.huffingtonpost.co.uk
x http://www.ibtimes.co.uk
x http://www.independent.ie
x http://www.infiniteunknown.net
x http://www.iol.co.za
x http://www.irishexaminer.com
x http://www.irishmirror.ie
x http://www.irishtimes.com
x http://www.itv.com
x http://www.lancashiretelegraph.co.uk
x http://www.lse.co.uk
19
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7)&%-:%''3
x http://www.mgtowhq.com
x http://www.mirror.co.uk
x http://www.msn.com
x http://www.nationalenquirer.com
x http://www.newindianexpress.com
x http://www.newscopia.com
x http://www.newsday.com
x http://www.newsgrio.com
x http://www.nigeriadailynews.news
x http://www.nydailynews.com
x http://www.nzherald.co.nz
x http://www.oneworldofnations.com
x http://www.oxfordmail.co.uk
x http://www.pressreader.com
x http://www.reuters.com
x http://www.scmp.com
x http://www.scotsman.com
x http://www.somersetlive.co.uk
x http://www.srnnews.com
x http://www.swindonadvertiser.co.uk
x http://www.telegraph.co.uk
x http://www.theargus.co.uk
x http://www.theboltonnews.co.uk
x http://www.thedailybeast.com
x http://www.thetelegraphandargus.co.uk
x http://www.thetruthseeker.co.uk
x http://www.twimovies.news
x http://www.westernmorningnews.co.uk
x http://www.wirralglobe.co.uk
x http://www.yorkpress.co.uk
x http://www.yorkshirepost.co.uk
x https://blairzhit.wordpress.com
x https://bol.bna.com
x https://ca.news.yahoo.com
x https://circusbuoy.wordpress.com
x https://quartetbooks.wordpress.com
x https://thetruth24.info
x https://www.eveningtelegraph.co.uk
x https://www.theguardian.com
x https://www.thesun.co.uk
x https://www.yahoo.com
x http://ferddyjay.blogspot.com
20
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7))%-:%''3
47. As seen from the list of domains that have published articles or stories containing
references to the statement made against Ms. Giuffre, many of these domains are those of major
news organizations or sources, including AOL News, BBC, Huffington Post, International
Business Times, Irish Times, MSN News, National Enquirer, New York Daily News, New
Zealand Herald, Page Six, Radar Online, Reuters, The Daily Beast, The Daily Mail, The
Express, The Guardian, The Mirror, The Sun, The Telegraph, Yahoo! News, etc.
48. I then used a variety of web analytics traffic services and other sources to get the
unique daily visitor traffic for each of these domains. I used multiple services when available to
verify the unique daily visitor traffic for each of these domains, as these traffic services may use
different techniques to arrive at their traffic numbers.
49. In cases of conflicting unique daily visitor traffic numbers, I utilized the most
conservative (i.e., smallest) number.
50. In cases where I determined I could not get unique daily visitor traffic numbers or
the unique daily visitor traffic were not reliable, in my opinion, I did not include the unique daily
visitor traffic numbers for that domain in the numbers. This usually occurred for the sites with a
smaller number of daily visitors or sites with an extremely large number of daily visitors.
51. Unique daily visitors measure is an industry standard web analytics metric for
measuring people that visit a website in a given day, also known as unique audience22. It is
generally averaged out over multiple days with a given period, such as week or month, as there
are normal daily fluctuations.
52. Table 1 shows the unique daily visitor traffic for the listed domains that posted
articles or stories referencing the statements made against Ms. Giuffre and the associated unique
22
http://digitalmeasurement.nielsen.com/files/metrics-guidelines.pdf
21
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7)3%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7)7%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7);%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7)*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7)<%-:%''3
would have substantial impact on visitors to that site. Examples of such articles headlines
(examples of actual headlines from the 178 articles) are:
x British socialite to face Epstein accuser's defamation lawsuit
x Alleged Epstein madam denies calling teen ‘sex slave’ a liar
x Sex-Trafficking Denials Aren't Libel, Brit Says
x U.S. woman who claimed she was forced to have sex with Prince Andrew
sues British socialite for denying that she recruited her to be a sex slave
x British 'madam' accused of recruiting teenage 'sex slave' Virginia Roberts
for Prince Andrew's friend Jeffrey Epstein denies calling her a liar
x Ghislaine Maxwell denies calling Virginia Roberts a liar
x Bill Clinton Pedophile Sex Scandal: Socialite Denies Calling ENQUIRER
Source A Liar, Woman files defamation suit against British publishing magnate
x Jeffrey Epstein sex slave accuser sues Brit socialite for defamation
x Lawyers for British socialite accused of pimping 'sex slave' to Jeffrey
Epstein push to dismiss defamation lawsuit.
57. This is a conservative estimate, and more likely than not, articles containing the
statements made against Ms. Giuffre have been disseminated to more individuals.
X. WHY THE ESTIMATE IS LOW
58. This (66,909,965 individual unique daily traffic) is a conservative estimate, and it
is more likely than not, the statements have received wider dissemination due to factors such as:
a. Although I spend considerable effort to locate published articles that
contained the statements made against Ms. Giuffre, it is reasonable to assume that I have not
located all such articles by the time of the submission of this report. So, there are possibly more
26
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7)'%-:%''3
sites with articles containing the statements made against Ms. Giuffre that are not included in my
calculations, which would increase the dissemination of the articles.
b. The focus of my analysis was the dissemination of online articles
containing the statements made against Ms. Giuffre, and I examined only online sources and not
print or broadcast media. Many of the media outlets that I did identify have consider print
distribution25, which are not included in my calculations, for example, such as:
x The Sun (print circulation) 1,741,838
x Daily Mail (print circulation) 1,562,361
x The Daily Telegraph (print circulation) 472,936
x The Times (print circulation) 402,752
x The Guardian (print circulation) 161,152
c. In my analysis, I did not attempt to measure face-to-face dissemination
that may have occurred after individuals may have read articles containing the statements made
against Ms. Giuffre, which would increase the count.
d. Naturally, I could not access certain online sources where the statements
made against Ms. Giuffre may have been disseminated (e.g., email messages, social media
messages, articles behind firewalls, etc.). Therefore, these numbers are not included in my
calculations.
e. Also, there are possibly sites that have hosted articles containing the
statements made against Ms. Giuffre where the articles have been removed. Therefore, they are
not included in my calculations.
25
www.theguardian.com/media/2016/mar/17/independent-mirror-express-and-star-suffer-sharp-fall-in-traffic
27
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$7)6%-:%''3
f. For sites where one or more of the articles containing the statements made
against Ms. Giuffre are posted but where I could not locate or not determine reliable daily unique
visitor traffic, I have not included these sites in my calculations. There are 59 (of the 115 sites,
51.3%) where I could not get or not get verifiable traffic data. For example, the traffic numbers
for the MSN News (Microsoft) and Yahoo! News are not separated by news and other services,
such as search, so I did not include these in the number of people to which the articles containing
the statements made against were disseminated.
g. I did not include the dissemination of the articles containing the statements
made against Ms. Giuffre directly to social media platforms. However, many of the articles
containing the statements made against Ms. Giuffre do include counts of the number of times
that individuals shared the article to a social media networks, as shown in Table 2.
i. Table 2: Number of social media shares by published article
Shares Date Domain

12576 2-Jan-15 https://www.theguardian.com
201 3-Jan-15 http://muhammad-ali-ben-marcus.blogspot.qa
1600 3-Jan-15 http://www.dailymail.co.uk
130 3-Jan-15 http://www.huffingtonpost.co.uk
45 3-Jan-15 http://www.ibtimes.co.uk
6436 3-Jan-15 http://www.mirror.co.uk
55 4-Jan-15 http://newsbite.it
56 4-Jan-15 http://ugandansatheart.blogspot.com
1813 4-Jan-15 http://www.dailyrecord.co.uk
9 4-Jan-15 http://www.express.co.uk
198 4-Jan-15 http://www.irishmirror.ie
174 4-Jan-15 http://www.nigeriadailynews.news
51 4-Jan-15 http://www.nzherald.co.nz
28
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$734%-:%''3
Shares Date Domain

216 4-Jan-15 http://www.telegraph.co.uk
105 5-Jan-15 http://www.dailylife.com.au
96 5-Jan-15 http://www.nydailynews.com
1 10-Jan-15 http://www.infiniteunknown.net
1 13-Jan-15 http://whatiswrongwiththispicture2012.blogspot.qa
319 22-Jan-15 http://www.irishmirror.ie
21 1-Feb-15 http://www.mirror.co.uk
342 7-Feb-15 https://www.theguardian.com
107 21-Sep-15 http://www.nydailynews.com
33 22-Sep-15 http://www.dailymail.co.uk
205 22-Sep-15 http://www.mirror.co.uk
1 15-Jan-16 http://jewishbusinessnews.com
17 15-Jan-16 http://www.nationalenquirer.com
7 n.d. http://www.govtslaves.info
33,758
ii. As shown in Table 2, the articles containing the statements made against
Ms. Giuffre have been shared 33,758 times, mostly on Facebook.
iii. Given that the median number of Facebook ‘friends’ is 20026, this equates
to a possible 6,751,600 individuals, in addition to the 33,758 individuals who originally shared
26
http://www.pewresearch.org/fact-tank/2014/02/03/6-new-facts-about-facebook/
29
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$73&%-:%''3
the articles, to which the articles containing the statements made against Ms. Giuffre could have
been disseminated, assuming these individuals are all unique and have not already read one of
the articles.
iv. However, I did not include these social media shares in my calculations.
v. Since news article viewing follows a power law27 distribution28, there is no
direct linear ratio of number of social media shares to readership. There is published research
that does report average of views of an article on a news website and also average social media
shares29. In a direct calculation with numbers from this article30, 23 articles views per social
media share, using 33,758 social media shares, this would be 776,434 article views. However,
this ratio would vary by website, number of daily unique visitors, type of news article, time for
accumulating shares, and possibly other factors. Plus, this number would not account for the
people receiving the social media share that viewed the title, post, and snippet but did not click
on the share to view the article on the website, thereby undercounting views of the articles.
vi. Also, given the topical nature of the underlying news story, one could
expect lower social media sharing but higher article viewing, as people will tend to read articles
on such topics privately but not share on social media31. So, I would expect the social media
number itself to be an undercount.
h. I did not include articles that link to one of the articles containing the
statements made against Ms. Giuffre in my calculations of dissemination. Unless the article
27
https://en.wikipedia.org/wiki/Power_law
28
See for example, Tatar, A., de Amorim, M. D., Fdida, S., & Antoniadis, P. (2014). A survey on predicting the popularity of web content.
Journal of Internet Services and Applications, 5(1), 1.
29
See for example, Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February). Characterizing the life cycle of online news stories
using social media reactions. In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211-
223). ACM.
30
Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February). Characterizing the life cycle of online news stories using social
media reactions. In Proceedings of the 17th ACM conference on Computer supported cooperative work & social computing (pp. 211-223). ACM.
31
See for example, Agarwal, D., Chen, B. C., and Wang, X. Multi-faceted ranking of news articles using post-read actions. In Proc. of CIKM,
ACM (2012), 694-703.
30
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$73)%-:%''3
directly mentioned the statements made against Ms. Giuffre, I did not include that article in my
calculations. So, unless the linking article actually mentioned, referenced, or quoted the
statements made against Ms. Giuffre, I did not include it in the calculations.
i. Many sites published multiple articles on multiple days that quoted or
referenced the statements made against Ms. Giuffre; however, I did not use these multiple
publication dates from the same site in my calculations of unique visitor traffic. If a domain
published only one article containing the statements against Ms. Giuffre, then I directly used the
unique daily visitors number. If a domain published multiple articles concerning the statements
against Ms. Giuffre, I did not count the traffic for the subsequent articles containing the
statements made against Ms. Giuffre, even though research shows that repeat traffic to websites
is generally only about 30%32, meaning that 70% of the traffic would be unique. However, I was
not comfortable using this figure given the natural of these sites, which might have higher repeat
visitors day-to-day. Therefore, I did not include the unique visitors to multiple articles in my
calculations.
j. Finally, I did not include the count of people who may been searching and
may have seen the statements made against Ms. Giuffre in the search results, without needing to
visit the actual articles, as shown in Figure 4.
k. Figure 4: Example of search results with the statements made against
Ms. Giuffre appearing in the result snippets, requiring no need to visit the articles
themselves.
32
Teevan, J., Adar, E., Jones, R. and Potts, M. (2006). History repeats itself: repeat queries in Yahoo's logs. In Proceedings of the 29th annual
international ACM SIGIR conference on Research and development in information retrieval (SIGIR '06). ACM, New York, NY, USA, 703-704.
31
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$733%-:%''3
XI. ACCURACY OF THE TRAFFIC NUMBERS AND ADDITIONAL
VERIFICATION
32
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$737%-:%''3
59. Concerning the accuracy of the analysis, the number of domains where the
statements made against Ms. Giuffre have been disseminated is reliable, as this is straightforward
to verify (i.e., the article is either posted on a site or it is not). If anything, this is an undercount,
as some domains, for example, may have removed such articles, making them no longer
available. There are possibly articles containing the statements that I have not been able to
locate by the time that I submitted this report.
60. Concerning traffic numbers for domains, a unique visitor is typically identified by
an identifier stored in a text file, which is based on an individual computer’s browser, although
more sophisticated methods are also being used. In locating traffic numbers for the domains, I
used multiple services when available and attempted to verify via other sources. In case with
varying traffic data, I utilized the most conservative (i.e., smallest) number available.
61. I also verified findings from my analysis via other methods and my own
experience and training. For example, there are periods of increased publishing of articles
containing the statements made against Ms. Giuffre and related stories. One would expect,
increases in associated searching during these periods. Using the Google Keyword Tool, which
provides search volume for search queries by month, I examined search volume from January
2015 to the date that I filed this report. There was an 54,518% increase in search volume for the
keywords Virginia Giuffre Virginia Roberts Ghislaine Maxwell in January 2015, relative to the
prior 7 months, in the US, and a 44,822% increase for the United Kingdom (UK) in January
2015, relative to the prior 7 months. This is in line with the increase in posting of articles during
the same month33. So, one sees the expected increase in searching for key terms based on the
increase posting of articles.
33
Note: I use the US and the UK as sample countries since there are aspect of the story that relate to each country.
33
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62. Figure 5 shows increase in searching volume in January 2015 for the US and UK
relative to the previous 7 months.
63. Figure 5: Increase in search volume in January 2015 for the US and UK
relative to the previous 7 months for the keyphrase Virginia Giuffre Virginia Roberts
Ghislaine Maxwell.
XII SUMMARY
64. The statements made against Ms. Giuffre have been disseminated to at least
115 online media or other sites in 178 separate stories or articles with a combined
66,909,965 individual unique visitors from 2 January 2015 to the date that I filed this
report, inclusive. More likely than not, this is a conservative estimate.
65. Right to Amend: Although I have had access to materials publicly available
pertaining to claims in this dispute, I have not been able to review all the material by the deadline
for completion of this report. I reserve the right to review and rely on any such material,
including at the time of trial. I also reserve the right to issue a supplemental or an amended
report if my review of such material results in any significant change or addition to my opinion.
34
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DATED: 09 September 2016
By
Dr. Bernard J. Jansen

Professor
College of Information Sciences and Technology
The Pennsylvania State University
University Park, PA, 16802
Phone: 434-249-8687
Email: jjansen@acm.orq
URL: http://ist.psu.edu/faculty pages/jjansen/
35
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Appendix B Testimony Cases
Year Deliverables Retained by Case

2016 Testimony Plaintiff ERIN ANDREWS, Plaintiff, vs MARRIOTT
Deposition INTERNATIONAL, INC., a Delaware
Corporation; WESTEND HOTEL PARTNERS,
LLC dba NASHVILLE MARRIOTT AT
VANDERBILT UNIVERSITY, a Delaware
Limited Liability Company, and MICHAEL
DAVID BARRETT, an individual, Defendants.
CASE NO. 11C4831, which is pending in the
Circuit Court for Davidson County Tennessee at
Nashville.
Law Firm: Greene Broillet & Wheeler LLP

2015 Deposition Plaintiff ENCORE MEDIA METRICS, LLC fka SPUR
DIGITAL L.P., dba SPUR INTERACTIVE and
STEVE LATHAM VS ADOMETRY, INC. fka
CLICK FORENSICS, INC. Cause 2012-44351 /
Court: 281. (The District Court of Travis County,
Texas.)
Law Firm: Watts & Guerra LLP and DiNovo Price

Ellwanger & Hardy LLP
2014 Deposition Defendant M.B. AS NEXT FRIEND OF J.B., A MINOR
Plaintiffs, V. CAMP STEWART FOR BOYS,
INC., AMERICAN INSTITUTE FOR FOREIGN
STUDY, INC. D/B/A CAMP AMERICA, AND
SCOTT ASH JAMES ZIRUS Defendant. NO.
5:12-CV-1133 (Western District of Texas)
Law Firm: Rymer, Moore, Jackson, & Echols PC

2014 Testimony, Defendant REAL LOCAL PAGE PARTNERS, LLC,
Deposition Claimant, v. PAYMENT ALLIANCE
INTERNATIONAL, INC., Respondent &
PAYMENT ALLIANCE INTERNATIONAL,
INC. Counter-Claimant, v. REAL LOCAL PAGE
PARTNERS, LLC, Counter-Respondent. CASE
NO. 32 147 Y 0021413. AMERICAN
ARBITRATION ASSOCIATION, MIAMI,
FLORIDA
Law Firm: Kirkland & Ellis LLP

2013 Deposition Plaintiff CABLE WHOLESALE.COM, INC. v. SF
CABLE, INC. Case No. CV 11-2966 EMC
(Northern District of California)
Law Firm: Law Offices of James G. Schwartz P.C.
88
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Appendix C Documents Referenced
Web Services
x Alexa www.alexa.com/
x Bing Search Engine https://www.bing.com/
x Compete https://www.compete.com/
x Google Keyword Tool https://adwords.google.com/KeywordPlanner
x Google Search Engine www.google.com/
x Google Trends https://www.google.com/trends/
x Microsoft Bing Keyword Tool www.bing.com/toolbox/keywords
x Million Short https://millionshort.com/
x SimiliarWeb www.similarweb.com/
x SpyFu www.spyfu.com/
x W3Snoop http://www.w3snoop.com/
Documents
x Agarwal, D., Chen, B. C., and Wang, X. Multi-faceted ranking of news articles using
post-read actions. In Proc. of CIKM, ACM (2012), 694-703.
x Aikat, D. News on the web: usage trends of an on-line newspaper. Convergence: The
International Journal of Research into New Media Technologies 4, 4 (Dec. 1998), 94-
110.
x BBC News https://en.wikipedia.org/wiki/BBC_News
x Castillo, C., El-Haddad, M., Pfeffer, J., & Stempeck, M. (2014, February).
Characterizing the life cycle of online news stories using social media reactions. In
Proceedings of the 17th ACM conference on Computer supported cooperative work &
social computing (pp. 211-223). ACM.
x Complaint, VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant.
CASE NO. 1:15-cv-07433
x Daily Mirror https://en.wikipedia.org/wiki/Daily_Mirror
x GIUFFRE001120
x GM_00068 (Gow E-Mail)
x http://digitalmeasurement.nielsen.com/files/metrics-guidelines.pdf
x http://www.ebizmba.com/articles/news-websites
x http://www.mirror.co.uk/news/uk-news/prince-andrews-pal-ghislaine-maxwell-5081971
x http://www.nydailynews.com/news/world/alleged-madame-accused-supplying-prince-
andrew-article-1.2065505
x http://www.pewresearch.org/fact-tank/2014/02/03/6-new-facts-about-facebook/
x https://www.google.com/advanced_search
x https://www.thesun.co.uk/archives/news/6754/prince-andrews-pal-ghislaine-groped-teen-
girls/
x Mail Online https://en.wikipedia.org/wiki/Mail_Online
x Power Law https://en.wikipedia.org/wiki/Power_law
x Snowball sampling https://en.wikipedia.org/wiki/Snowball_sampling
89
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x Tatar, A., de Amorim, M. D., Fdida, S., & Antoniadis, P. (2014). A survey on predicting
the popularity of web content. Journal of Internet Services and Applications, 5(1), 1.
x Teevan, J., Adar, E., Jones, R. and Potts, M. (2006). History repeats itself: repeat queries
in Yahoo's logs. In Proceedings of the 29th annual international ACM SIGIR conference
on Research and development in information retrieval (SIGIR '06). ACM, New York,
NY, USA, 703-704.
x The Independent https://en.wikipedia.org/wiki/The_Independent
x The Times https://en.wikipedia.org/wiki/The_Times
x Triangulation (social science)
http://en.wikipedia.org/wiki/Triangulation_%28social_science%29
x www.theguardian.com/media/2016/mar/17/independent-mirror-express-and-star-suffer-s
harp-fall-in-traffic
90
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EXHIBIT 25
(Filed Under Seal)
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!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$76*%-:%''3
EXHIBIT 26
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$76<%-:%''3
GM_00068
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$76'%-:%''3
EXHIBIT 27
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$766%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;44%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;4&%-:%''3
EXHIBIT 28
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;4)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;43%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;47%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;4;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;4*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;4<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;4'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;46%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;&4%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;&&%-:%''3
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!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;&6%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;)4%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;)&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;))%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;)3%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;)7%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;);%-:%''3
EXHIBIT 29
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;)*%-:%''3
EXHIBIT 30
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;)<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;)'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;)6%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;34%-:%''3
EXHIBIT 31
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;3&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;3)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;33%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;37%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;3;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;3*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;3<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;3'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;36%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;74%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;7&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;7)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;73%-:%''3
EXHIBIT 32
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;77%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;7;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;7*%-:%''3
EXHIBIT 33
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;7<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;7'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;76%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;4%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;3%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;7%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;;6%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;*4%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;*&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;*)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;*3%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;*7%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;*;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;**%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;*<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;*'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;*6%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<4%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<3%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<7%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;<6%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;'4%-:%''3
EXHIBIT 34
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;'&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;')%-:%''3
EXHIBIT 35
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;'3%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;'7%-:%''3
EXHIBIT 36
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;';%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;'*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;'<%-:%''3
EXHIBIT 37
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;''%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;'6%-:%''3
EXHIBIT 38
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;64%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;6&%-:%''3
GIUFFRE005434
CONFIDENTIAL
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;6)%-:%''3
GIUFFRE005435
CONFIDENTIAL
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;63%-:%''3
GIUFFRE005436
CONFIDENTIAL
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;67%-:%''3
GIUFFRE005437
CONFIDENTIAL
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;6;%-:%''3
GIUFFRE005438
CONFIDENTIAL
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;6*%-:%''3
EXHIBIT 39
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;6<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;6'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$;66%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*44%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*4&%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*4)%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*43%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*47%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*4;%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*4*%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*4<%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*4'%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*46%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*&4%-:%''3
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!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*))%-:%''3
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*)3%-:%''3
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EXHIBIT 40
(Filed Under Seal)
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*';%-:%''3
GIUFFRE006581
CONFIDENTIAL
!"#$%&'()'*'+%,-./0$12%)'3+%4'5465)4&6+%)*)')7&+%8"9$*'*%-:%''3
EXHIBIT 41
(Filed Under Seal)
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02/11/2015 Page 2298 Public Records Request No.: 16-268
GIUFFRE007836
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TERMINATIONS

Rinker Ross Box #7
Rivera Pablo Box #3
Rivera Eduardo Box #2
Rivero Alicia Box #7
Robbins Jody Box #4
Roberts Virginia Box #4
Roberts Walter Box #4
Roberts Diane Box #3
Robsham Lydie Box #7
Rodriguez Francisco Box #4
Rodriguez Abel Box #3
Rodriguez Kenia Box #3
Rodriguez Aristalia Box #2
Rogers Howard Box #2
Romeus Melege Box #2
Rony Jean Box #2
Roqueta Maria Box #2
Rose Cheryl Box #2
Rosenberg Bradley Box #2
Rosier Sandra Box #2
Rotchford Bernadette Box #4
Rubio Pascual Box #2
Rueda Maria Box #4
Ruiz Juan Box #2
Russeau Heidi Box #4
Russell Kathryn Box #4
Russotto Vincent Box #7
Ryan Megan Box #2
Ryan Michael Box #7
Saint Gerard Manes Box #7
Saint Surin Jacquest Box #2
Salloum Adib Box #2
Salman David Box #2
Salvador Marian Box #2
Sanford Kevin Box #5
Santos Elimos Box #2
Sasaki Shoko Box #7
Saunders Sarah Box #2
Savage Angelia Box #5
Savoie Terry Box #2
Scanlan Peter Box #5
Schlechter Melissa Box #5
Schmantowsky Craig Box #2
Schoonover Richard Box #2
Schroeder Glenn Box #5
Schumacher Patricia Box #2
Schwab Emily Box #2
Scotland Jaycen Box #7
Scott Cecelia Box #2
Page 13 of 17
MAR-A-LAGO 0173
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TERMINATIONS

Vasquez Sosmar Box #5
Vasquez Christian Box #2
Vaughn Matthew Box #2
Velasquez Rodollfo Box #2
Vidalis Chantal Box #2
Voluck Justin Box #2
Vyskrebentsev Aleksey Box #5
Wahl Steven Box #5
Walker Sylvia Box #7
Walkowiak Toni Box #7
Wallace Philip Box #2
Ward Terry Box #5
Webb Jacob Box #7
Weber Ronald Box #2
Weidner James Box #7
Weisman Brian Box #2
Wentworth Gayle Box #2
Weslowski Elaine Box #2
White Scott Box #5
Whitley Deborah Box #7
Whitney Moriah Box #7
Whittle Tamara Box #2
Wilburn Jennifer Box #2
Williams Arhon Box #2
Williams Gretchen Box #2
Williams Jacqueline Box #2
Williams Ellen Box #7
Williams Kristin Box #7
Willoughby William Box #2
Willson Howard Box #5
Willson Joseph Box #2
Woolf Elena Box #2
Wynn Beverly Box #2
Yancey Kathryn Box #2
Yancey Scott Box #7
Yeskey Dean Martin Box #5
Young Todd Box #2
Zervoulis Matthew Box #2
Zivkovic Milo Box #2
Zorn Christopher Box #7
Zwick Danielle Box #2
Box #1 1998 terms

Box #2 1998 & 1999 terms
Box #3 1999 terms
Box #4 2000 terms
Box #5 2000 terms
Box #6 2001 terms
Page 16 of 17
MAR-A-LAGO 0176
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Generated: 08/09/2019 10:07:40


--------------------------------------------------X
.............................................
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------
Defendant’s Reply to Plaintiff’s Statement of

Contested Facts and Plaintiff’s “Undisputed Facts”
Pursuant to Local Civil Rule 56.1
Laura A. Menninger
Jeffrey S. Pagliuca
Denver, CO 80203
303.831.7364
Pursuant to Rule 56.1 of the Local Civil Rules of this Court, defendant Ghislaine
Maxwell submits this Reply to Plaintiff’s Statement of Contested Facts and Plaintiff’s
Undisputed Facts (“Response”), Doc. 586-1.
INTRODUCTION
Plaintiff’s Response fails under both the Federal Rules of Evidence and the Local Civil
Rules of Procedure.
First, Plaintiff largely failed to provide any “citation to evidence which would be
admissible” to challenge Defendant’s Statement of Material Undisputed Facts and therefore
Ms. Maxwell’s undisputed facts should be deemed admitted.
Second, rather than set forth “additional material facts as to which it is contended that
there exists a genuine issue to be tried” (Local Civil Rule 56.1(b)), Plaintiff instead set forth her
own purportedly “undisputed facts.” Because Plaintiff did not cross-move for summary
judgment, her supposedly “undisputed facts” are not permitted by the Rules and should be
stricken.
I. Ms. Maxwell’s reply in support of statement of undisputed facts.
1. Undisputed Fact 1: In early 2011 plaintiff in two British tabloid interviews made
numerous false and defamatory allegations against Ms. Maxwell. In the articles, plaintiff made
no direct allegations that Ms. Maxwell was involved in any improper conduct with Jeffrey
Epstein, who had pleaded guilty in 2007 to procuring a minor for prostitution. Nonetheless,
plaintiff suggested that Ms. Maxwell worked with Epstein and may have known about the crime
for which he was convicted. Exs. A and B.
a. Reply: Plaintiff cites no admissible evidence to contest these undisputed facts.
McCawley Ex.34 (GIUFFRE368) is an email from Sharon Churcher to Plaintiff. It is Ms.
Churcher’s hearsay and therefore inadmissible. In any event, it does not speak to the
1
contents of Plaintiff’s interviews with Churcher. McCawley Decl. Ex. 31 is an FBI
interview, also inadmissible hearsay, which again does not describe Plaintiff’s interviews
in news articles. In the absence of contrary evidence, Undisputed Fact 1 should be
deemed admitted.
2. Undisputed Fact 2: In the articles, plaintiff alleged she had sex with Prince
Andrew, “a well-known businessman,” a “world-renowned scientist,” a “respected liberal
politician,” and a “foreign head of state.” Exs. A-B at 5.
a. Reply: Plaintiff does not contest these facts and they therefore should be
deemed admitted.
3. Undisputed Fact 3: In response to the allegations Ms. Maxwell’s British attorney,
working with Mr. Gow, issued a statement on March 9, 2011, denying “the various allegations
about [Ms. Maxwell] that have appeared recently in the media. These allegations are all entirely
false.” Ex.C.
a. Reply: Plaintiff “denies” that Mr. Barden “issued a statement,” but offers no
admissible evidence to refute this point. Further, she acknowledges that the Statement
was issued “By Devonshires Solicitors,” Mr. Barden’s law firm.
4. Undisputed Fact 4: The statement read in full:

By Devonshires Solicitors, PRNE
Wednesday, March 9, 2011
London, March 10, 2011 - Ghislaine Maxwell denies the various allegations about
her that have appeared recently in the media. These allegations are all entirely
false.
It is unacceptable that letters sent by Ms Maxwell’s legal representatives to
certain newspapers pointing out the truth and asking for the allegations to be
withdrawn have simply been ignored.
In the circumstances, Ms Maxwell is now proceeding to take legal action against
those newspapers.
2
However, the allegations made against me are abhorrent and entirely untrue and
I ask that they stop,” said Ghislaine Maxwell.
“A number of newspapers have shown a complete lack of accuracy in their
reporting of this story and a failure to carry out the most elementary investigation
or any real due diligence. I am now taking action to clear my name,” she said.
Media contact:
Ross Gow
Acuity Reputation
Tel: +44-203-008-7790
Mob: +44-7778-755-251
Media contact: Ross Gow, Acuity Reputation, Tel: +44-203-
008-7790, Mob: +44-7778-755-251, Email: ross at acuityreputation.com
Ex.C.
a. Reply: Plaintiff does dispute the contents of the 2011 statement and therefore it
should be deemed admitted.
5. Undisputed Fact 5: Plaintiff’s gratuitous and “lurid” accusations in an unrelated
action. In 2008 two alleged victims of Epstein brought an action under the Crime Victims’
Rights Act against the United States government purporting to challenge Epstein’s plea
agreement. They alleged the government violated their CVRA rights by entering into the
agreement. Ex.D, at 2.
a. Reply: Plaintiff “stipulates” to the facts contained in paragraph 5 and therefore
they should be deemed admitted.
6. Undisputed Fact 6: Seven years later, on December 30, 2014, Ms. Giuffre moved
to join the CVRA action, claiming she, too, had her CVRA rights violated by the government.
On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. Ex.D at 1, 9.
a. Reply: Plaintiff “agreed” to this paragraph.
3
7. Undisputed Fact 7: The issue presented in her joinder motion was narrow: whether
she should be permitted to join the CVRA action as a party under Federal Rule of Civil
Procedure 21, specifically, whether she was a “known victim[] of Mr. Epstein and the
Government owed them CVRA duties.” Yet, “the bulk of the [motion] consists of copious
factual details that [plaintiff] and [her co-movant] ‘would prove . . . if allowed to join.’” Ms.
Giuffre gratuitously included provocative and “lurid details” of her alleged sexual activities as an
alleged victim of sexual trafficking. Ex.E, at 5.
a. Reply: Plaintiff does not dispute that Judge Marra made the findings detailed in
Undisputed Fact 7. Further, she admits that the Government refused to stipulate that she
“had been sexually abused by Jeffrey Epstein and his co-conspirators (including co-
conspirator Alan Dershowitz), which would make her a ‘victim’ of a broad sex
trafficking conspiracy.” Although she now submits there were other reasons for
inclusion of such lurid details, those reasons were rejected by Judge Marra. As she does
not offer any admissible evidence to contradict the findings made by Judge Marra, this
“fact,” specifically Judge Marra’s findings, should be deemed admitted. In any event, we
request under Fed. R. Evid. 201(c)(2) that the Court take judicial notice of the contents of
Judge Marra’s ruling and order.
8. Undisputed Fact 8: At the time they filed the motion, Ms. Giuffre and her lawyers
knew that the media had been following the Epstein criminal case and the CVRA action. While
they deliberately filed the motion without disclosing Ms. Giuffre’s name, claiming the need for
privacy and secrecy, they made no attempt to file the motion under seal. Quite the contrary, they
filed the motion publicly. Ex.D, at 1 & n.1.
4
a. Reply: Plaintiff offers no admissible evidence to refute these facts and they
therefore should be deemed admitted. Specifically, she does not offer any evidence to
dispute that she knew the media had been following Epstein and the CVRA action, nor
does she dispute that her attorneys made no attempt to file the motion under seal, rather
filing it publicly. The facts are thus admitted.
9. Undisputed Fact 9: As the district court noted in ruling on the joinder motion,
Ms. Giuffre “name[d] several individuals, and she offers details about the type of sex acts
performed and where they took place.” The court ruled that “these lurid details are
unnecessary”: “The factual details regarding whom and where the Jane Does engaged in sexual
activities are immaterial and impertinent . . ., especially considering that these details involve
non-parties who are not related to the respondent Government.” Accordingly, “[t]hese
unnecessary details shall be stricken.” Id. The court then struck all Ms. Giuffre’s factual
allegations relating to her alleged sexual activities and her allegations of misconduct by non-
parties. The court said the striking of the “lurid details” was a sanction for Ms. Giuffre’s
improper inclusion of them in the motion. Ex.E at 5-7.
therefore should be deemed admitted. See Reply to Undisputed Fact 7, supra. In any
event, we request under Fed. R. Evid. 201(c)(2) that the Court take judicial notice of the
contents of Judge Marra’s ruling and order.
10. Undisputed Fact 10: The district court found not only that the “lurid details” were
unnecessary but also that the entire joinder motion was “entirely unnecessary.” Ms. Giuffre and
her lawyers knew the motion with all its “lurid details” was unnecessary because the motion
5
itself recognized that she would be able to participate as a fact witness to achieve the same result
she sought as a party. The court denied plaintiff’s joinder motion. Id. at 7-10.
therefore should be deemed admitted. See Reply to Undisputed Fact 7, supra.
11. Undisputed Fact 11: One of the non-parties Ms. Giuffre “named” repeatedly in the
joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the
motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme”
created by Epstein:
 Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years
old” to recruit her into the scheme.
 Ms. Maxwell was “one of the main women” Epstein used to “procure under-
aged girls for sexual activities.”
 Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme.
 She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar

to the manner in which Epstein and his other co-conspirators coerced dozens of
other children.”
 At the mansion, when plaintiff began giving Epstein a massage, he and

Ms. Maxwell “turned it into a sexual encounter.”
 Epstein “with the assistance of” Ms. Maxwell “converted [plaintiff] into . . . a
‘sex slave.’” Id. Plaintiff was a “sex slave” from “about 1999 through 2002.”
 Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.”
 Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea
agreement, because the immunity protected her from prosecution “for the crimes
she committed in Florida.”
 Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.”
 Ms. Maxwell “took numerous sexually explicit pictures of underage girls

involved in sexual activities, including [plaintiff].” Id. She shared the photos
with Epstein.
6
 As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]”
Epstein with “powerful individuals” so that Epstein could traffick plaintiff to
these persons.
 Plaintiff was “forced to have sexual relations” with Prince Andrew in

“[Ms. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” plaintiff’s
sex with Prince Andrew “by acting as a ‘madame’ for Epstein.”
 Ms. Maxwell “assist[ed] in internationally trafficking” plaintiff and “numerous

 Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in
Id. at 3-6.
a. Reply: Plaintiff offers no admissible evidence to refute the facts actually stated
in the paragraph, i.e., that the “lurid” details (as coined by Judge Marra) were included in
her CVRA Joinder Motion. Plaintiff claims to offer “admissible evidence” to
“corroborate the statements [she] made in the joinder motion.” Setting aside for the
moment that most of the cited documents are inadmissible hearsay, as addressed later,
such evidence should be disregarded because none of the offered documents speak to fact
that these “lurid” details were actually included in the joinder motion, as a simple reading
of Ex.D reveals. Because Plaintiff does not refute that point, the fact that the details were
in the Joinder Motion should be deemed admitted. In any event, we request under Fed. R.
Evid. 201(c)(2) that the Court take judicial notice of the contents of plaintiff’s CVRA
joinder motion.
12. Undisputed Fact 12: In the joinder motion, plaintiff also alleged she was “forced”
to have sex with Harvard law professor Alan Dershowitz, “model scout” Jean Luc Brunel, and
“many other powerful men, including numerous prominent American politicians, powerful
business executives, foreign presidents, a well-known Prime Minister, and other world leaders.”
Id. at 4-6.
7
a. Reply: Again, Plaintiff offers no evidence that these “lurid details” were
included in the Joinder Motion, as indeed they were, and thus the fact that they were
13. Undisputed Fact 13: Plaintiff said after serving for four years as a “sex slave,” she
“managed to escape to a foreign country and hide out from Epstein and his co-conspirators for
years.” Id.at 3
a. Reply: Plaintiff does not dispute that she made this statement in her joinder
motion and it is admitted.
14. Undisputed Fact 14: Plaintiff suggested the government was part of Epstein’s
“conspiracy” when it “secretly” negotiated a non-prosecution agreement with Eptstein
precluding federal prosecution of Epstein and his “co-conspirators.” The government’s secrecy,
plaintiff alleged, was motivated by its fear that plaintiff would raise “powerful objections” to the
agreement that would have “shed tremendous public light on Epstein and other powerful
individuals. Id. at 6-7.
a. Reply: Plaintiff does not contest the quoted contents of the joinder motion, but
rather offers argument regarding Plaintiff’s purported “belief.” Plaintiff did not submit
an affidavit attesting to such “belief” and therefore no admissible evidence was cited or
offered. The facts should therefore be deemed admitted.
15. Undisputed Fact 15: Notably, the other “Jane Doe” who joined plaintiff’s motion
who alleged she was sexually abused “many occasions” by Epstein was unable to corroborate
any of plaintiff’s allegations. Id. at 7-8.
a. Reply: Plaintiff states the facts are “untrue” but offers no admissible evidence
to support that statement. She has no affidavit or other statement from “the other ‘Jane
8
Doe’ (who was represented by Plaintiff’s counsel, and therefore had the ability to furnish
such an affidavit). Indeed, Plaintiff acknowledges that the “other Jane Doe” “does not
know Ms. Giuffre.” These facts must be deemed admitted. , who is NOT
the other Jane Doe, is irrelevant to the undisputed fact asserted. She also offers no
corroboration of the ‘same pattern of abuse,’ and in fact does not “remember” any such
facts, as already briefed. See Doc. 567 at 12-14.
16. Undisputed Fact 16: Also notably, in her multiple and lengthy consensual
interviews with Ms. Churcher three years earlier, plaintiff told Ms. Churcher of virtually none of
the details she described in the joinder motion. Exs. A-B.
a. Reply: Plaintiff’s protestation aside, the Churcher articles (attached to Ms.
Churcher’s sworn affidavit filed in this case at Doc. 216 and 216-1 through 216-8) fail to
include the vast majority of details included in Plaintiff’s CVRA joinder motion, as any
side-by-side comparison will reveal. Plaintiff’s simple facile response is that she “did
reveal details in 2011 consistent with those in the joinder motion.” She offers no
admissible evidence of these details she “revealed” to Ms. Churcher, instead citing to a
heavily redacted interview she purportedly gave to the FBI, not Ms. Churcher. The
purported FBI report is itself hearsay, not to mention, redacted and prepared years after
any supposed interview of Plaintiff. McCawley Decl. Ex.31. Because Plaintiff offers no
admissible evidence to contradict the discrepancies between the Churcher articles and the
joinder motion, these facts should be deemed admitted.
17. Undisputed Fact 17: Ms. Maxwell’s response to plaintiff’s “lurid” accusations:
the January 2015 statement. As plaintiff and her lawyers expected, before District Judge Marra
in the CVRA action could strike the “lurid details” of plaintiff’s allegations in the joinder
9
motion, members of the media obtained copies of the motion. Ex.G at 31:2-36:4 & Depo. Exs.
3-4.
a. Reply: Plaintiff cites no contrary evidence and therefore the facts should be
deemed admitted.
18. Undisputed Fact 18: At Mr. Barden’s direction, on January 2, 2015, Mr. Gow sent
to numerous representatives of British media organizations an email containing “a quotable
statement on behalf of Ms Maxwell.” EX.F; EX.G, at 33:8-23. The email was sent to more than 6
and probably less than 30 media representatives. See Ex.G, at 33:8-34:3. It was not sent to non-
media representatives. See id. at 31:2-35:21.
a. Reply: Plaintiff disputes as “blatant falsehood,” without admissible evidence,
that it was Mr. Barden who directed that the January 2 email be sent to media
organizations. She then goes on to quote the very section of Mr. Gow’s deposition in
which he surmises (but does not know, indicated by his statement it was his
“understanding”) that it was something that had been sent to Maxwell by Barden.
Indeed, Mr. Barden clears up this confusion in his Declaration, in which he unequivocally
swore,
10
Ex.K ¶ 10. Mr. Gow’s surmise as to how the statement was “forwarded to him” and by whom
does not controvert the sworn testimony of Mr. Barden himself. Again, without admissible
evidence to the contrary, the facts must be deemed admitted.
With regard to the number of media representatives to whom he sent the email, Mr. Gow
testified it was between 6 and 30. Ex.G at 33-34. His further testimony, offered by Plaintiff, that
he spoke to “over 30 journalists” does not contradict that statement. Nowhere does Plaintiff
offer testimony that he read the statement to over 30 journalists. Instead, Mr. Gow
acknowledged it was “very possible” that he had “ever read[] the statement to press or media
over the phone,” not that he read it to “over 30 journalists.” Plaintiff’s selective cutting and
pasting undercuts her so called evidence that the facts in Paragraph 18 are “false,” and thus they
ought be deemed admissible.
19. Undisputed Fact 19: Among the media representatives were Martin Robinson of
the Daily Mail; P. Peachey of The Independent; Nick Sommerlad of The Mirror; David Brown of
The Times; and Nick Always and Jo-Anne Pugh of the BBC; and David Mercer of the Press
Association. These representatives were selected based on their request—after the joinder motion
was filed—for a response from Ms. Maxwell to plaintiff’s allegations in the motion. See, e.g.,
EX.G, at 30:23-35:21 & Depo.Ex.3.
a. Reply: While Plaintiff decries the second sentence as “false,” her cited
evidence contradicts her conclusion. Mr. Gow testified that “any time there was an
incoming query it was either dealt with on the telephone by referring them back to the
two statements…or someone would email them the statement. So no one was left
unanswered.” McCawley Decl., Ex.6 at 67. As his testimony makes clear, Mr. Gow sent
11
the statement to those journalists who made inquiry; he did not sent it to anyone who did
not. Based on the admissible evidence, this fact remains undisputed.
20. Undisputed Fact 20: The email to the media members read:

Please find attached a quotable statement on behalf of Ms Maxwell.
Best
Ross
Ross Gow
ACUITY Reputation
Victoria Roberts against Ghislaine Maxwell are untrue. The original allegations
are not new and have been fully responded to and shown to be untrue.
Each time the story is re told [sic] it changes with new salacious details about
public figures and world leaders and now it is alleged by Ms Roberts [sic] that
Alan Derschowitz [sic] is involved in having sexual relations with her, which he
denies.
Ms Roberts claims are obvious lies and should be treated as such and not
publicised as news, as they are defamatory.
Ghislaine Maxwell’s original response to the lies and defamatory claims remains
the same. Maxwell strongly denies allegations of an unsavoury nature, which
have appeared in the British press and elsewhere and reserves her right to seek
redress at the repetition of such old defamatory claims.
Ex.F.
a. Reply: Plaintiff does not dispute the contents of the email and therefore it
21. Undisputed Fact 21: Mr. Barden, who prepared the January 2015 statement, did
not intend it as a traditional press release solely to disseminate information to the media. So he
intentionally did not pass it through a public relations firm, such as Mr. Gow’s firm, Acuity
Reputation. EX.K ¶¶ 10,15.
12
a. Reply: Plaintiff makes two responses. As to the first sentence, she asserts
without evidentiary support that “the Court should not consider” the Barden Declaration.
This argument is frivolous for the reasons given on pages 8, 11-12, 18-19 of the Reply
Brief in Support of Motion for Summary Judgment. It is a Declaration provided by an
attorney with knowledge of the facts, Mr. Barden, disclosed by Defendant in her Rule 26
witnesses, whom Plaintiff chose not to depose. As to the second sentence, Plaintiff offers
two pieces of evidence which she argues dispute the facts in question; they do not. That
Mr. Gow forwarded the statement, prepared by Mr. Barden, to the media is not disputed.
Rather, as Mr. Barden asserted in his declaration, and Plaintiff failed to cite contradictory
evidence, he was the one who prepared the vast majority of the statement and instructed
Mr. Gow to transmit it via email to members of the British media. Ex.K ¶¶ 10. He
likewise avers that he “did not intend the January 2015 statement as a traditional press
release solely to disseminate information to the media [and] this is why I intentionally did
not request that Mr. Gow or any other public relations specialist prepare or participate in
preparing the statement.” Id. at ¶ 15. Plaintiff fails to contradict Mr. Barden’s sworn
statement.
22. Undisputed Fact 22: The January 2015 statement served two purposes. First, Mr.
Barden intended that it mitigate the harm to Ms. Maxwell’s reputation from the press’s
republication of plaintiff’s false allegations. He believed these ends could be accomplished by
suggesting to the media that, among other things, they should subject plaintiff’s allegations to
inquiry and scrutiny. For example, he noted in the statement that plaintiff’s allegations changed
dramatically over time, suggesting that they are “obvious lies” and therefore should not be
“publicised as news.” Id. ¶ 11.
13
a. Reply: This paragraph, eliciting Mr. Barden’s intent, is uncontroverted by
Plaintiff. She fails to cite any contradictory admissible evidence, instead making legal
arguments. Her arguments are not admissible evidence (e.g., “it is her statement and she
directed that it be sent to the media and public,” lacks any citation to record evidence).
Plaintiff’s list of evidence she contends “corroborates” Plaintiff’s claims should be
ignored as they do not pertain to Mr. Barden’s purposes in drafting the January 2
statement.
23. Undisputed Fact 23: Second, Mr. Barden intended the January 2015 statement to
be “a shot across the bow” of the media, which he believed had been unduly eager to publish
plaintiff’s allegations without conducting any inquiry of their own. Accordingly, in the statement
he repeatedly noted that plaintiff’s allegations were “defamatory.” In this sense, the statement
was intended as a cease and desist letter to the media-recipients, letting the media-recipients
understand the seriousness with which Ms. Maxwell considered the publication of plaintiff’s
obviously false allegations and the legal indefensibility of their own conduct. Id. ¶ 17.
a. Reply: Again, Plaintiff “disputes” Mr. Barden’s intent without citation to
record evidence. Plaintiff claims that Barden did not “note” anything in the statement,
but the statement itself contains the phrase: “Ms. Roberts claims are obvious lies and
should be treated as such and not publicized as news, as they are defamatory.”
Plaintiff’s unsupported arguments should be ignored and these facts pertaining to Mr.
Barden’s intent deemed admitted.
24. Undisputed Fact 24: Consistent with those two purposes, Mr. Gow’s emails
prefaced the statement with the following language: “Please find attached a quotable statement
on behalf of Ms Maxwell” (emphasis supplied). The statement was intended to be a single, one-
14
time-only, comprehensive response—quoted in full—to plaintiff’s December 30, 2014,
allegations that would give the media Ms. Maxwell’s response. Id. ¶ 18. The purpose of the
prefatory statement was to inform the media-recipients of this intent. Id.
a. Reply: Plaintiff again “disputes” any statement related to Mr. Barden’s purpose
or intent, but offers no evidence contradicting his purpose or intent. She simply points
out that Ms. Maxwell retained Mr. Gow in early 2015, and that he works for a public
relations firm, which is non-responsive to the fact at issue, i.e., Mr. Barden’s intent with
respect to language included in the statement. No one has contested that it was Mr. Gow
who actually forwarded the statement to select members of the media who had requested
a response. The fact set forth should be deemed admitted.
25. Undisputed Fact 25: Plaintiff’s activities to bring light to the rights of victims of
sexual abuse. Plaintiff has engaged in numerous activities to bring attention to herself, to the
prosecution and punishment of wealthy individuals such as Epstein, and to her claimed interest
of bringing light to the rights of victims of sexual abuse.
a. Reply: Plaintiff offers no evidence to dispute the facts cited and so they should
be deemed admitted.
26. Undisputed Fact 26: Plaintiff created an organization, Victims Refuse Silence, Inc.,
a Florida corporation, directly related to her alleged experience as a victim of sexual abuse. Doc.
1 (Complaint), ¶¶ 24-25.
a. Reply: Plaintiff does not dispute this statement.
27. Undisputed Fact 27: The “goal” of Victims Refuse Silence “was, and continues to
be, to help survivors surmount the shame, silence, and intimidation typically experienced by
15
victims of sexual abuse.” Toward this end, plaintiff has “dedicated her professional life to
helping victims of sex trafficking.” Id.
a. Reply: Plaintiff “agrees.”
28. Undisputed Fact 28: Plaintiff repeatedly has sought out media organizations to
discuss her alleged experience as a victim of sexual abuse. This Reply Statement at ¶¶ 51-54
(citing inter alia Doc. 216 ¶¶ 2-11 and referenced exhibits, Doc. 261-1 to 216-8; Exs. N, KK,
LL, MM).
a. Reply: Plaintiff “denies” this contention, points to an email from Sharon
Churcher seeking to interview her, and asserts that it was the media that sought her out.
The weight of evidence, cited by Defendant at paragraphs 51-54, in addition to Plaintiff’s
own documents, belie this assertion. She through her attorneys sought out a videotaped
interview with ABC News, she sent her “book manuscript” to publishers and literary
agents, and expressed anticipation and frustration that her “exclusive contract” with The
Mail prevented her for a period of time from marketing her book. See, e.g., EXHIBIT QQ
at GIUFFRE003959.
16
Plaintiff has disputed none of these activities she freely engaged in for years, and thus these
facts should be deemed admitted.
29. Undisputed Fact 29: On December 30, 2014, plaintiff publicly filed an “entirely
unnecessary” joinder motion laden with “unnecessary,” “lurid details” about being “sexually
abused” as a “minor victim[]” by wealthy and famous men and being “trafficked” all around the
world as a “sex slave.” Ex.J ¶ 24; Ex.K ¶¶ 2-3.
a. Reply: Plaintiff argues that her “lurid details” were necessary legally. Judge
Marra, however, has already held that they were not and her legal arguments,
unsupported by any actual evidence in this case, cannot serve to controvert his findings as
quoted.
30. Undisputed Fact 30: The plaintiff’s alleged purpose in filing the joinder motion
was to “vindicate” her rights under the CVRA, expose the government’s “secretly negotiated”
“non-prosecution agreement” with Epstein, “shed tremendous public light” on Epstein and “other
powerful individuals” that would undermine the agreement, and support the CVRA plaintiffs’
request for documents that would show how Epstein “used his powerful political and social
connections to secure a favorable plea deal” and the government’s “motive” to aid Epstein and
his “co-conspirators.” Ex.D, at 1, 6-7, 10 (emphasis supplied).
a. Reply: Plaintiff fails to offer any evidence to controvert the contents of her
CVRA Joinder Motion and thus, the fact should be deemed admitted.
31. Undisputed Fact 31: Plaintiff has written the manuscript of a book she has been
trying to publish detailing her alleged experience as a victim of sexual abuse and of sex
trafficking in Epstein’s alleged “sex scheme.” Ex.KK.
17
a. Reply: Plaintiff directs the Court to her response to paragraph 52 and suggests
the factual statement is misleading. She, however, offers no contradictory admissible
evidence and thus the fact should be deemed admitted.
32. Undisputed Fact 32: Republication alleged by plaintiff. Plaintiff was required by
Interrogatory No. 6 to identify any false statements attributed to Ms. Maxwell that were
“‘published globally, including within the Southern District of New York,’” as plaintiff alleged
in Paragraph 9 of Count I of her complaint. In response, plaintiff identified the January 2015
statement and nine instances in which various news media published portions of the January
2015 statement in news articles or broadcast stories. Ex.H, at 7-8; Ex.I, at 4.
a. Reply: Her argument aside, Plaintiff offers no admissible evidence to
controvert the interrogatory request and her response, which was limited to “nine
instances” in which the press published “portions of the January 2015 statement.” For
example, Plaintiff does not point to a single news story that published the entirety of the
January 2015 statement. In the absence of contrary evidence, the fact should be deemed
admitted.
33. Undisputed Fact 33: In none of the nine instances was there any publication of the
entire January 2015 statement. Ex.H, at 7-8; Ex.I, at 4.
a. Reply: Plaintiff does not and cannot point to any of the nine publications she
disclosed, or any other publication, that published the entire January 2015 statement, and
this fact thus must be deemed admitted.
34. Undisputed Fact 34: Ms. Maxwell and her agents exercised no control or authority
over any media organization, including the media identified in plaintiff’s response to
18
Interrogatory No. 6, in connection with the media’s publication of portions of the January 2015
statement. Ex.J ¶ 24; Ex.K ¶¶ 2-3.
a. Reply: Plaintiff’s proffered evidence, testimony from Mr. Gow, fails to support
her argument and fails to controvert the Barden Declaration as cited by the defendant.
Nothing in the testimony establishes, as Plaintiff argues, that “Defendant hired Gow
because his position allowed him to influence the press to publish her defamatory
statement.” The testimony is irrelevant to the factual point. The Gow testimony at most
relates to why Ms. Maxwell engaged Mr. Gow. It does not bear on the factual point, i.e.,
that Ms. Maxwell, Mr. Gow or Mr. Barden did not exercise any control or authority over
the media in the media’s republication of portions of the statement. On this point plaintiff
has failed to introduce any contrary evidence. Accordingly, the fact should be deemed
admitted.
35. Undisputed Fact 35: Plaintiff’s defamation action against Ms. Maxwell. Eight
years after Epstein’s guilty plea, plaintiff brought this action, repeating many of the allegations
she made in her CVRA joinder motion. Doc. 1, ¶ 9.
a. Reply: Plaintiff “agrees.”
36. Undisputed Fact 36: The complaint alleged that the January 2015 statement
“contained the following deliberate falsehoods”:
Doc. 1 ¶ 30 (boldface and underscoring omitted).
(a) Reply: Plaintiff “agreed.”
19
37. Undisputed Fact 37: Plaintiff lived independently from her parents with her
fiancé long before meeting Epstein or Ms. Maxwell. After leaving the Growing Together drug
rehabilitation facility in 1999, plaintiff moved in with the family of a fellow patient. Ex.L at 7-8,
12-14. There she met, and became engaged to, her friend’s brother, James Michael Austrich. Id.
and at 19. She and Austrich thereafter rented an apartment in the Ft. Lauderdale area with
another friend and both worked at various jobs in that area. Id. at 11, 13-17. Later, they stayed
briefly with plaintiff’s parents in the Palm Beach/ Loxahatchee, Florida area before Austrich
rented an apartment for the couple on Bent Oak Drive in Royal Palm Beach. Id. at 17, 19, 25-27.
Although plaintiff agreed to marry Austrich, she never had any intention of doing so. Ex.N at
127-128.
a. Reply: Plaintiff offers argument, without an affidavit or any other contradictory
evidence, regarding whether Plaintiff “voluntarily live[d] independently” or whether a
“reasonable person” could assert she was “engaged.” Mr. Austrich and Plaintiff agreed
that they were engaged and testified accordingly, as cited. In the absence of admissible
evidence to the contrary, the facts as described by her fiancé in his deposition should be
deemed admitted.
38. Undisputed Fact 38: Plaintiff re-enrolled in high school from June 21, 2000
until March 7, 2002. After finishing the 9th grade school year at Forest Hills High School on
June 9, 1999, plaintiff re-enrolled at Wellington Adult High School on June 21, 2000, again on
August 16, 2000 and on August 14, 2001. Ex.O. On September 20, 2001, Plaintiff then enrolled
at Royal Palm Beach High School. Id. A few weeks later, on October 12, 2001, she matriculated
at Survivors Charter School. Id. Survivor’s Charter School was an alternative school designed to
assist students who had been unsuccessful at more traditional schools. Ex.P at 23-24. Plaintiff
20
remained enrolled at Survivor’s Charter School until March 7, 2002. Ex.O. She was present 56
days and absent 13 days during her time there. Id. Plaintiff never received her high school
diploma or GED. Ex.Q at 475, 483. Plaintiff and Figueroa went “back to school” together at
Survivor’s Charter School. Ex.P at 23-27. The school day there lasted from morning until early
afternoon. Id. at 23-27, 144-146.
a. Reply: Plaintiff argues, again without evidentiary support, that the “codes” on
the school records indicate “semester start and end dates” rather than dates Plaintiff was
in school. Her mis-reading of the records is apparent from their face. One column is
labelled “Entry date,” and the next “Withdrawal Date.” Neither say “semester start date”
or “semester end” date. Moreover, the “codes” simply prove the point: Plaintiff
“entered” school (codes E01 and EA1) on the designated “entry date” and withdrew
(either prior to completion, to enter another training program, or who “will continue in
the class/program the next term or school year”) on the dates designated “withdrawal.”
The school records display entry and withdrawal dates for Wellington High School Adult
Program, from June 21, 2000 – August 15, 2000, from August 16, 2000 – August 13,
2001, and from August 14, 2001- September 20, 2001 and then an entry, that same day,
September 20, 2001 at Survivor’s Charter School. Plaintiff would have one believe that
the records show a school on Plaintiff’s official transcript that she never went to,
Wellington High School Adult Program, that indicates she withdrew the very day she
concededly entered Survivor’s Charter School. Her intentional misreading of the record
is yet another attempt to obfuscate Plaintiff’s lack of memory regarding where and when
she went to school, just like she failed to remember 8 jobs she held in 2000 whereas she
claimed to have had one. The test is admissible evidence to the contrary, and Plaintiff
21
offers none. The flight logs (which show trips in early 2001) do not contradict the
evidence because they are during the period of time she was enrolled in “Adult High
School,” a place where night classes were taught and where one might circumstantially
infer, careful attendance records were not kept.
39. Undisputed Fact 39: During the year 2000, plaintiff worked at numerous jobs.
In 2000, while living with her fiancé, plaintiff held five different jobs: at Aviculture Breeding
and Research Center, Southeast Employee Management Company, The Club at Mar-a-Lago,
Oasis Outsourcing, and Neiman Marcus. Ex.R. Her taxable earnings that year totaled nearly
$9,000. Id. Plaintiff cannot now recall either the Southeast Employee Management Company or
the Oasis Outsourcing jobs. Ex.Q at 470-471.
a. Reply: Plaintiff does not dispute the facts as presented, merely argues regarding
their significance. The Social Security Administration records detail the five jobs at
which she worked in 2000; the month and day of the jobs are irrelevant for purposes of
this recitation of facts. Likewise, Plaintiff does not dispute the taxable earnings she made
that year, or that she does not “remember” the jobs associated with Southeast Employee
Management Company or Oasis Outsourcing (whether they were payroll or not), where
she made $3,212 and $2,037 that year. She also “forgot” about her job at Neiman
Marcus, where she made $1,440 in 2000, until she was confronted with the SSA records.
McCawley Dec. Ex.5 at 53, 470.
40. Undisputed Fact 40: Plaintiff’s employment at the Mar-a-Lago spa began in
fall 2000. Plaintiff’s father, Sky Roberts, was hired as a maintenance worker at the The Mar-a-
Lago Club in Palm Beach, Florida, beginning on April 11, 2000. Ex.S. Mr. Roberts worked
there year-round for approximately 3 years. Id.; Ex.T at 72-73. After working there for a period
22
of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff
for a job there. Id. at 72. Mar-a-Lago closes every Mother’s Day and reopens on November 1.
Ex.U at Mar-a-Lago0212. Most of employees Mar-a-Lago, including all employees of the spa
area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between
November 1 and Mother’s Day. Ex.T at 72-73; Ex.U at Mar-a-Lago0212; Ex.V. Plaintiff was
hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she
had turned 17.
a. Reply: Plaintiff’s response is misleading. First, she does not dispute that Mr.
Roberts, her father began working at Mar-a-Lago in April 2000, nor that he worked there
for some time, became acquainted with the head of the spa area and recommended his
daughter for a job.
Second, Plaintiff contends that “job postings and job descriptions” “from 2002 and
later are irrelevant.” There are no such “job postings” cited. Rather, the job posting cited
was from October 2000, the same time that Plaintiff was hired. Compare Ex.V (posting
for “Saturday October 14 and Sunday October 15”) with calendar for year 2000, showing
Saturday and Sundays in October corresponding to those dates.
Finally, Plaintiff points to her own “recollection” as contrary proof. Her
“recollection” about when she worked at Mar-a-Lago has shifted dramatically over time.
First, she claimed it was 1998. See Jane Doe 102 complaint. Then, it was 1999. See
Doc. 1, Complaint in this matter. Now, in this response she has changed her answer to
2000. Her vague recollections about what year have been off base, no credit should be
given to her newfound recollection of which month she worked there. In any event, she
presents no admissible credible evidence to contradict Mar-a-Lago’s own records. Ex.U
23
at Mar-a-Lago0212 (spa not open from Mother’s Day until November 1). Even
Plaintiff’s father, a longtime employee of Mar-a-lago admitted that the place “closed
down” in the summer. Ex.T at 72-73. Plaintiff simply is not credible in her testimony
that she recalls it being a “summer job,” and the fact that she did not work at the spa until
at least November 2000 at the age of 17 should be deemed admitted.
41. Undisputed Fact 41: Plaintiff represented herself as a masseuse for Jeffrey
Epstein. While working at the Mar-a-Lago spa and reading a library book about massage,
plaintiff met Ms. Maxwell. Plaintiff thereafter told her father that she got a job working for
Jeffrey Epstein as a masseuse. Ex.T at 79. Plaintiff’s father took her to Epstein’s house on one
occasion around that time, and Epstein came outside and introduced himself to Mr. Roberts. Id.
at 82-83. Plaintiff commenced employment as a traveling masseuse for Mr. Epstein. Plaintiff
was excited about her job as a masseuse, about traveling with him and about meeting famous
people. Ex.L at 56; Ex.P at 126. Plaintiff represented that she was employed as a masseuse
beginning in January 2001. Ex.M; Ex.N. Plaintiff never mentioned Ms. Maxwell to her then-
fiancé, Austrich. Ex.L at 74. Plaintiff’s father never met Ms. Maxwell. Ex.T at 85.
a. Reply: Plaintiff does not actually refute any of the facts set forth above, but
rather spends her time discussing different facts. Plaintiff’s father testified to what she
told him, that she “was going to learn massage therapy.” Ex.T at 79. She does not
contest her father’s testimony that Mr. Epstein came out of the house and greeted her
father and that her father never met Ms. Maxwell. See Reply to Undisputed Fact 41.
Whether someone can receive a “massage license” under Florida law without a high
school equivalency diploma is of no moment. Plaintiff does not dispute she represented
24
herself as a masseuse to others, in her own handwriting, beginning in January 2001. Exs.
M and N. These facts should be deemed admitted.
42. Undisputed Fact 42: Plaintiff resumed her relationship with convicted felon
Anthony Figueroa. In spring 2001, while living with Austrich, plaintiff lied to and cheated on
him with her high school boyfriend, Anthony Figueroa. Ex.L at 68, 72. Plaintiff and Austrich
thereafter broke up, and Figueroa moved into the Bent Oak apartment with plaintiff. Ex.L at 20;
Ex.P at 28. When Austrich returned to the Bent Oak apartment to check on his pets and retrieve
his belongings, Figueroa in Plaintiff’s presence punched Austrich in the face. Ex.X; Ex.L at 38-
45. Figueroa and plaintiff fled the scene before police arrived. Ex.X. Figueroa was then a
convicted felon and a drug abuser on probation for possession of a controlled substance. Ex.Y.
a. Reply: Plaintiff argues relevance regarding these facts, but contests none of
them. They should be deemed admitted. Plaintiff’s lies, cheating, and association with a
convicted felon and known drug abuser all are relevant in this defamation case
concerning her reputation, purported damage to such reputation, and whether she was a
known liar, as the January 2015 statement contends.
43. Undisputed Fact 43: Plaintiff freely and voluntarily contacted the police to
come to her aid in 2001 and 2002 but never reported to them that she was Epstein’s “sex
slave.” In August 2001 at age 17, while living in the same apartment, plaintiff and Figueroa
hosted a party with a number of guests. Ex.Z. During the party, according to plaintiff, someone
entered plaintiff’s room and stole $500 from her shirt pocket. Id. Plaintiff contacted the police.
She met and spoke with police officers regarding the incident and filed a report. She did not
disclose to the officer that she was a “sex slave.” A second time, in June 2002, plaintiff
contacted the police to report that her former landlord had left her belongings by the roadside and
25
had lit her mattress on fire. Ex.AA. Again, plaintiff met and spoke with the law enforcement
officers but did not complain that she was the victim of any sexual trafficking or abuse or that
she was then being held as a “sex slave.” Id.
a. Reply: Plaintiff, again, presents no admissible evidence to contradict these
facts, instead arguing their relevance. They should be deemed admitted.
44. From August 2001 until September 2002, Epstein and Maxwell were almost
entirely absent from Florida on documented travel unaccompanied by Plaintiff. Flight logs
maintained by Epstein’s private pilot Dave Rodgers evidence the substantial number of trips
away from Florida that Epstein and Maxwell took, unaccompanied by Plaintiff, between August
2001 and September 2002. Ex.BB. Rodgers maintained a log of all flights on which Epstein and
Maxwell traveled with him. Ex.CC at 6-15. Epstein additionally traveled with another pilot who
did not keep such logs and he also occasionally traveled via commercial flights. Id. at 99-100,
103. For substantially all of thirteen months of the twenty-two months (from November 2000
until September 2002) that Plaintiff lived in Palm Beach and knew Epstein, Epstein was
traveling outside of Florida unaccompanied by Plaintiff. Ex.BB. During this same period of
time, Plaintiff was employed at various jobs, enrolled in school, and living with her boyfriend.
a. Reply: Plaintiff goes to great lengths to dispute facts other than those presented
as Undisputed Fact 44. Her voluminous, repetitive recitation of the flights that Plaintiff
was on do nothing to demonstrate the 13 months of flights from July 2001 until August
2002 that Epstein and Maxwell were on without Plaintiff, as reflected in the logs. Her
assertions regarding the other flights that she took, commercial or on another plane, do
nothing to establish all of the many flights she was not on during 13 of the 22 month
period during which Epstein and Maxwell were away from Palm Beach. Plaintiff does
26
not dispute that Epstein and Maxwell were on the flights without her. The facts as
presented by Defendant should be deemed admitted.
45. Undisputed Fact 45: Plaintiff and Figueroa shared a vehicle during 2001 and
2002. Plaintiff and Figueroa shared a ’93 white Pontiac in 2001 and 2002. Ex.P at 67; Ex.EE.
Plaintiff freely traveled around the Palm Beach area in that vehicle. Id. In August 2002, Plaintiff
acquired a Dodge Dakota pickup truck from her father. Ex.P at 67-68. Figueroa used that
vehicle in a series of crimes before and after Plaintiff left for Thailand. Id.; Ex.FF.
a. Reply: Again, the Response has nothing to do with the facts stated. As Plaintiff
concedes, she and Mr. Figueroa had one car that they both used. In fact, they traveled to
and from school together. Ex.P at 67-68. She also does not dispute that she traveled
freely around the Palm Beach area in that vehicle, or that “her car” was used in a series of
thefts while she was in Thailand. All should be deemed admitted.
46. Undisputed Fact 46: Plaintiff held a number of jobs in 2001 and 2002. During
2001 and 2002, plaintiff was gainfully employed at several jobs. She worked as a waitress at
Mannino’s Restaurant, at TGIFriday’s restaurant (aka CCI of Royal Palm Inc.), and at
Roadhouse Grill. Ex.R. She also was employed at Courtyard Animal Hospital (aka Marc
Pinkwasser DVM). Id.; Ex.W.
a. Reply: Plaintiff admits all of the facts set forth above, aside from the use of the
word “gainfully.” They should be deemed admitted.
47. Undisputed Fact 47: In September 2002, Plaintiff traveled to Thailand to
receive massage training and while there, met her future husband and eloped with him.
Plaintiff traveled to Thailand in September 2002 to receive formal training as a masseuse.
Figueroa drove her to the airport. While there, she initially contacted Figueroa frequently,
27
incurring a phone bill of $4,000. Ex.P at 35. She met Robert Giuffre while in Thailand and
decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until
two days before Mr. Figueroa’s deposition in this matter in May 2016. Id. at 29, 37.
a. Reply: Again, Plaintiff does not refute the facts set forth, she simply offers her
own interpretation of those facts. In the absence of any contrary evidence, they should be
deemed admitted.
48. Undisputed Fact 48: Detective Recarey’s investigation of Epstein failed to
uncover any evidence that Ms. Maxwell was involved in sexual abuse of minors, sexual
trafficking or production or possession of child pornography. Joseph Recarey served as the
lead detective from the Palm Beach Police Department charged with investigating Jeffrey
Epstein. Ex.GG at 10. That investigation commenced in 2005. Id. Recarey worked only on the
Epstein case for an entire year. Id. at 274. He reviewed previous officers’ reports and interviews,
conducted numerous interviews of witnesses and alleged victims himself, reviewed surveillance
footage of the Epstein home, participated in and had knowledge of the search warrant executed
on the Epstein home, and testified regarding the case before the Florida state grand jury against
Epstein. Id. at 212-215. Detective Recarey’s investigation revealed that not one of the alleged
Epstein victims ever mentioned Ms. Maxwell’s name and she was never considered a suspect by
the government. Id. at 10-11, 180-82, 187-96, 241-42, 278. None of Epstein’s alleged victims
said they had seen Ms. Maxwell at Epstein’s house, nor said they had been “recruited by her,”
nor paid any money by her, nor told what to wear or how to act by her. Id. Indeed, none of
Epstein’s alleged victims ever reported to the government they had met or spoken to Ms.
Maxwell. Maxwell was not seen coming or going from the house during the law enforcement
surveillance of Epstein’s home. Id. at 214-215. The arrest warrant did not mention Ms. Maxwell
28
and her name was never mentioned before the grand jury. Id. at 203, 211. No property belonging
to Maxwell, including “sex toys” or “child pornography,” was seized from Epstein’s home
during execution of the search warrant. Id. at 257. Detective Recarey, when asked to describe
“everything that you believe you know about Ghislaine Maxwell’s sexual trafficking conduct,”
replied, “I don’t.” Id. at 278. He confirmed he has no knowledge about Ms. Maxwell sexually
trafficking anybody. Id. at 278-79. Detective Recarey also has no knowledge of Plaintiff’s
conduct that is subject of this lawsuit. Id. at 259-260.
a. Reply: Plaintiff offers several misleading “contrary” facts, none of which
actually address the facts presented herein, namely whether Ms. Maxwell was ever
mentioned by any of Epstein’s alleged victims, whether she was the target of their
investigation, and whether any of her property was seized from Epstein’s home. Plaintiff
cites to numerous inadmissible pieces of evidence on facts other than those. Mr.
Rodriguez, a convicted felon for obstructing justice related to the Epstein case, is dead
and his deposition testimony is the subject of a motion in limine because Ms. Maxwell
has never had the opportunity to cross examine him. Doc. 567 at 14. Ms. Rabuyo
likewise is not a witness who has been deposed in this case, and therefore her
“testimony” is not admissible against Ms. Maxwell. The message pads are not
authenticated by anyone, as will be the subject of a forthcoming motion in limine. And
there is not one shred of evidence that any child pornography, as opposed to a topless
photo of a very adult Ms. Maxwell, were ever found in Epstein’s home. The facts should
be deemed admitted, as those proferred by Defendant are based on admissible evidence.
49. Undisputed Fact 49: No nude photograph of Plaintiff was displayed in
Epstein’s home. Epstein’s housekeeper, Juan Alessi, “never saw any photographs of Virginia
29
Roberts in Mr. Epstein’s house.” Ex.HH at ¶ 17. Detective Recarey entered Epstein’s home in
2002 to install security cameras to catch a thief and did not observe any “child pornography”
within the home, including on Epstein’s desk in his office. Ex.GG at 289-90.
a. Reply: Plaintiff offered no evidence that a nude photograph of her was
displayed in Epstein’s home. All of the testimony she submits has nothing to do with a
nude photograph of herself. The fact should be deemed admitted.
50. Undisputed Fact 50: Plaintiff intentionally destroyed her “journal” and
“dream journal” regarding her “memories” of this case in 2013 while represented by
counsel. Plaintiff drafted a “journal” describing individuals to whom she claims she was sexually
trafficked as well as her memories and thoughts about her experiences with Epstein. Ex.II at 64-
65, 194; Ex.N at 205-08. In 2013, she and her husband created a bonfire in her backyard in
Florida and burned the journal together with other documents in her possession. Id. Plaintiff also
kept a “dream journal” regarding her thoughts and memories that she possessed in January 2016.
Ex.II at 194-96. To date, Plaintiff cannot locate the “dream journal.” Id.
a. Reply: Plaintiff offers no contrary admissible regarding her destruction of her
journal and it should be deemed admitted.
51. Undisputed Fact 51: Plaintiff publicly peddled her story beginning in 2011.
Plaintiff granted journalist Sharon Churcher extensive interviews that resulted in seven (7)
widely distributed articles from March 2011 through January 2015. Doc. 216 ¶¶ 2-11 and
referenced exhibits; Doc. 261-1 to 216-8, incorporated by reference. Churcher regularly
communicated with plaintiff and her “attorneys or other agents” from “early 2011” to “the
present day.” Plaintiff received approximately $160,000 for her stories and pictures that were
published by many news organizations. Ex.N at 247-248.
30
a. Reply: Plaintiff offers no evidence to contradict the facts asserted and they
should therefore be deemed admitted. Plaintiff’s unsupported spin of those facts should
be stricken.
52. Undisputed Fact 52: Plaintiff drafted a 144-page purportedly autobiographical
book manuscript in 2011 which she actively sought to publish. In 2011, contemporaneous
with her Churcher interviews, plaintiff drafted a book manuscript which purported to document
plaintiff’s experiences as a teenager in Florida, including her interactions with Epstein and
Maxwell. Ex.KK. Plaintiff communicated with literary agents, ghost writers and potential
independent publishers in an effort to get her book published. She generated marketing materials
and circulated those along with book chapters to numerous individuals associated with
publishing and the media.
a. Reply: Plaintiff cites inadmissible evidence, and attorney argument, in
contradiction of these facts. They should be ignored. The “Victim Notification Letter” is
inadmissible hearsay. The psychologist records likewise are inadmissible hearsay. The
FBI interview is inadmissible hearsay. Plaintiff’s counsel then flatly misrepresents to the
Court her own client’s characterization of the book manuscript, calling it a “fictionalized
account.” Plaintiff, contradicting her counsel, testified that the book manuscript is “99%
true.”
Q Is there anything -- well, first of all, did you author that entire manuscript?
A Yes, I did.
Q Did anyone else author part of that manuscript?
A Do you mean did anyone else write this with me?
Q Right.
A No.
Q That's all your writing?
31
A This is my writing.
Q Okay. To the best of your recollection as you sit here right now, is there anything
in that manuscript about Ghislaine Maxwell that is untrue?
A I don't believe so. Like I said, there is a lot of stuff that I actually have left out of
here.
Q Um-hum.
A. So there is a lot more information I could put in there. But as far as
Ghislaine Maxwell goes, I would like to say that there is 99.9 percent of it would
be to the correct knowledge.
Q All right. Is there anything that you -- and I understand you're doing this from
memory. Is there anything that you recall, as you're sitting here today, about
Ghislaine Maxwell that is contained in that manuscript, that is not true?
A You know, I haven't read this in a very long time. I don't believe that there's
anything in here about Ghislaine Maxwell that is not true.
EXHIBIT RR at 42-43 (emphasis added).
Plaintiff clearly now would like to spin the book manuscript as “fictionalized” because
she is well aware that the “facts” presented by her in that manuscript are contradicted by many
other documentary and testimonial records. Yet she offers no admissible evidence that Plaintiff
intended the manuscript to be fictional. Citations to social scientists who have not testified in
this case and whose work has not even be cited by any expert in this case is wholly improper and
should be stricken.
53. Undisputed Fact 53: Plaintiff’s publicly filed “lurid” CVRA pleadings initiated
a media frenzy and generated highly publicized litigation between her lawyers and Alan
Dershowitz. On December 30, 2014, plaintiff, through counsel, publicly filed a joinder motion
that contained her “lurid allegations” about Ms. Maxwell and many others, including Alan
Dershowitz, Prince Andrew, Jean-Luc Brunel. The joinder motion was followed by a
“corrected” motion (Ex.D) and two further declarations in January and February 2015, which
repeated many of plaintiff’s claims. These CVRA pleadings generated a media maelstrom and
spawned highly publicized litigation between plaintiff’s lawyers, Edwards and Cassell, and Alan
32
Dershowitz. After plaintiff publicly alleged Mr. Dershowitz of sexual misconduct, Mr.
Dershowitz vigorously defended himself in the media. He called plaintiff a liar and accused her
lawyers of unethical conduct. In response, attorneys Edwards and Cassell sued Dershowitz who
counterclaimed. This litigation, in turn, caused additional media attention by national and
international media organizations. Doc. 363 at 363-1 through 363-14.
a. Reply: Plaintiff offers no contrary facts and so they should be deemed
admitted.
54. Undisputed Fact 54: Plaintiff formed non-profit Victims Refuse Silence to
attract publicity and speak out on a public controversy. In 2014, plaintiff, with the assistance
of the same counsel, formed a non-profit organization, Victims Refuse Silence. According to
plaintiff, the purpose of the organization is to promote plaintiff’s professed cause against sex
slavery. The stated goal of her organization is to help survivors surmount the shame, silence,
and intimidation typically experienced by victims of sexual abuse. Ex.LL. Plaintiff attempts to
promote Victims Refuse Silence at every opportunity. Ex.MM at 17-18. For example, plaintiff
participated in an interview in New York with ABC to promote the charity and to get her mission
out to the public. Id. at 28.
a. Reply: Plaintiff offers no contrary evidence and the facts should be deemed
admitted.
II. The Court should strike plaintiff’s statement of “undisputed facts.”
The summary-judgment procedure is well established. When the summary-judgment non-
movant bears the burden of proof at trial, as in the case at bar, the movant may show a prima
facie entitlement to summary judgment in one of two ways: (1) the movant may point to
evidence that negates the non-movant’s claims, or (2) the movant may identify those portions of
its opponent’s evidence that demonstrate the absence of a genuine issue of material fact.
33
Salahuddin v. Goord, 467 F.3d 263, 272-73 (2d Cir. 2006). If the movant makes this showing in
either manner, the burden shifts to the nonmovant to identify record evidence creating a genuine
issue of material fact. Id. at 273.
Local Civil Rule 56.1(a) carries out this summary-judgment procedure by requiring the
summary-judgment movant to set forth “material facts as to which she contends there is no
genuine issue to be tried.” Subsection (b) of the rule requires the party opposing summary
judgment to set forth a “statement of additional material facts as to which it is contended that
there exists a genuine issue to be tried” (emphasis supplied).
Ms. Maxwell has moved for summary judgment; plaintiff has not. As movant,
Ms. Maxwell is required under Local Civil Rule 56.1 to enumerate the facts she is asserting as
undisputed; as the party opposing summary judgment, plaintiff is permitted—if she can—to
introduce admissible evidence creating a genuine issue of material fact. See Fed. R. Civ. P.
56(c)(1).
Plaintiff is confused. Plaintiff believes she—the party opposing summary judgment—
must enumerate facts she is asserting as undisputed, and so she has submitted her own Rule 56.1
statement of “undisputed facts.” That gets the summary-judgment procedure exactly backwards.
Plaintiff’s “undisputed facts” are irrelevant. Plaintiff cannot avoid summary judgment by
proposing “undisputed facts”; she may only do so by creating a genuine issue of material fact as
to Ms. Maxwell’s statement of undisputed facts. Accordingly, this Court should strike plaintiff’s
statement of “undisputed facts.”
Although Ms. Maxwell as the summary-judgment movant has no duty to respond to
plaintiff’s alleged “undisputed facts,” we hasten to add that Ms. Maxwell in fact opposes and
disputes most of plaintiff’s alleged “undisputed facts.” For example, Defendant’s Undisputed
34
Fact 40 includes the statement, “Ms. Giuffre was hired as a ‘seasonal’ spa attendant to work at
the Mar-a-Lago Club in the fall of 2000 after she had turned 17.” Yet, Plaintiff sets forth as her
own “Undisputed Fact 58” that “Virginia [got] job at Mar-a-Lago in 2000, either months before
or just after [her] 17th birthday.” Plaintiff has done nothing more than set forth her “dispute”
with Defendant’s Undisputed Fact 40 as her own “undisputed fact.” It makes no sense. See also
Plaintiff’s “Undisputed Fact” 63. The other alleged undisputed facts are simply Plaintiff’s
assertion of her deposition testimony, and hearsay of her statements to other witnesses, couched
as “Undisputed Facts.” Ms. Maxwell strenuously disputes almost all of the alleged “undisputed
facts” claiming that she engaged in any sexual acts, misconduct or communications with plaintiff
or others; indeed, over the course of two days and thirteen hours of deposition Ms. Maxwell
disputed all such allegations.
Because none of Plaintiff’s “undisputed facts” have anything to do with the issues raised
by Defendant’s Motion for Summary Judgment, Ms. Maxwell moves to strike plaintiff’s
statement of “undisputed facts.”
Conclusion
For the foregoing reasons, Ms. Maxwell requests that the Court deem her Undisputed
Facts admitted, and that the Court strike plaintiff’s statement of “undisputed facts.”
35
Dated: February 10, 2017
/s/ Laura A. Menninger

Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
Attorneys for Ghislaine Maxwell
36
I certify that on February 10, 2017, I electronically served this Defendant’s Reply to
Plaintiff’s Statement of Contested Facts and Plaintiff’s “Undisputed Facts” Pursuant to Local
Civil Rule 56.1 via ECF on the following:

Boies, Schiller & Flexner, LLP Salt Lake City, UT 84112
mschultz@bsfllp.com
Farmer, Jaffe, Weissing, Edwards, Fistos & South Salem, NY 10590
Lehrman, P.L. StanPottinger@aol.com
/s/ Nicole Simmons
Nicole Simmons
37

--------------------------------------------------X
.......................................
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration of Laura A. Menninger in Support of

Defendant’s Reply in Support of Motion for Summary Judgment
I, Laura A. Menninger, declare as follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of
Ms. Maxwell’s Reply in Support of Motion for Summary Judgment.1
2. In Defendant’s Memorandum of Law in Support of Motion for Summary Judgment
(filed Jan. 9, 2017), I included numbered paragraphs corresponding to undisputed facts from the
movant’s perspective as contemplated by Local Civil Rule 56.1(a), together with the citation to
admissible evidence as required by Fed. R. Civ. P. 56(c). See Doc. 541, passim.
1
At trial, defendant intends to produce either the custodian of record relevant to any
disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902.
See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition
documents herein were either produced by plaintiff or obtained with releases signed by plaintiff.
3. On January 9, 2017, I also prepared and served on the Court and counsel, under seal,
Defendant’s Statement of Material Undisputed Facts Pursuant to Local Civil Rule 56.1
(“Statement”). Those paragraphs mirror the numbered paragraphs contained within the
Memorandum of Law, minus the citations to the evidentiary record. The Statement was filed
with the Court in hard-copy and placed in the vault (see Doc.543).
4. Through a clerical oversight, a redacted version of the Statement was not appended
to the filed ECF version of the Notice of Motion for Summary Judgment (Doc. 537). However,
as noted in the previous two paragraphs, Ms. Maxwell enumerated all undisputed facts in
accordance with Local Civil Rule 56.1(a) in:
 Ms. Maxwell’s Memorandum of Law in Support of Motion for Summary Judgment
(Doc.541); and
 the Local Rule 56.1 Statement served on the the Court and counsel and filed in hard
copy with the Court.
5. Attached as Exhibit NN (filed under seal) is a true and correct copy of Defendant,
Ghislaine Maxwell’s Initial Disclosure Pursuant to Fed. R. Civ. P. 26, served February 24, 2016.
6. Attached as Exhibit OO (filed under seal) is a true and correct copy of an email
correspondence from Plaintiff to Sharon Churcher, dated May 12, 2011, Bates stamped
GIUFFRE004096-7; 004028-30.
7. Attached as Exhibit PP (filed under seal) are true and correct copies of excerpts from
the November 14, 2016 deposition of Virginia Giuffre, designated Confidential under the
Protective Order.
2
8. Attached as Exhibit QQ (filed under seal) is a true and correct copy of an email
correspondence from Plaintiff to Sharon Churcher, dated May 12, 2011, Bates stamped
GIUFFRE003959.
9. Attached as Exhibits RR (filed under seal) are true and correct copies of excerpts
from the May 3, 2016 deposition of Virginia Giuffre, designated Confidential under the
Protective Order.
Executed on February 10, 2017.
Laura A. Menninger
3
I certify that on February 10, 2017, I electronically served this Declaration of Laura A.
Menninger in Support of Defendant’s Reply to Her Motion for Summary Judgment via ECF on
the following:

mschultz@bsfllp.com
/s/ Nicole Simmons
Nicole Simmons
4
EXHIBIT NN

Southern District Of New York
--------------------------------------------------X
...............................................
Plaintiff,
v. 15-cv-07433-RWS
Ghislaine Maxwell,
Defendant.
-----------------------------------------------X
DEFENDANT GHISLAINE MAXWELL’S

INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE

INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq.
Haddon, Morgan & Foreman, P.C.
150 E. 10th Ave.
Denver, CO 80203
303-831-7364
LMenninger@HMFLaw.com
Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre

c/o Sigrid S. McCawley, Esq.
Boies, Schiller & Flexner LLP
401 East Las Olas Boulevard, Suite 1200
Miami, Florida 33301

(954) 356-0011
Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue in
her Complaint, including the events of 1996-2015 and the publication of
statements in the press in 2011-2015.
3. Philip Barden
Devonshires Solicitors LLP
30 Finsbury Circus
London, United Kingdom
EC2M 7DT
DX: 33856 Finsbury Square
(020) 7628-7576
Philip.Barden@devonshires.co.uk
Mr. Barden has knowledge concerning press statements by Plaintiff and

Defendant in 2011-2015 at issue in this matter.
4. Paul Cassell
College of Law, University of Utah
383 South University Street
801-585-5202
paul.cassell@law.utah.edu
Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff’s

court pleadings, and Plaintiff’s sworn testimony.
5. Alan Dershowitz
c/o Richard A. Simpson, Esq.
WILEY REIN, LLP
1776 K Street NW
Washington, D.C. 20006
(202) 719-7000
Mr. Dershowitz has knowledge concerning Plaintiff’s false statements to the

press, in court pleadings, and in sworn testimony, at issue in this matter.
6. Bradley Edwards
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
425 N. Andrews Ave., Suite 2
(954) 524-2820
2
Dated: February 24, 2016.
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
Attorney for Ghislaine Maxwell
I certify that on February 24, 2016, I electronically served this DEFENDANT

GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the
following:
Sigrid S. McCawley
BOIES, SCHILLER & FLEXNER, LLP
401 East Las Olas Boulevard, Ste. 1200
Laura A. Menninger
7
EXHIBIT PP
Agren Document
Case 18-2868, Blando Court Reporting 2628248,
286, 08/09/2019, & Video, Page12
Inc. of 55

__________________________________________________
CONFIDENTIAL VIDEO DEPOSITION OF

VIRGINIA GIUFFRE, VOLUME II
November 14, 2016
__________________________________________________
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
__________________________________________________
APPEARANCES:

By Sigrid S. McCawley, Esq.
Suite 1200
Phone: 954.356.0011
Appearing on behalf of the Plaintiff
VIRGINIA GIUFFRE VOLUME II 11/14/2016 348

Agren Document
286, 08/09/2019, & Video, Page13
Inc. of 55
By Laura Menninger, Esq.
4 Denver, CO 80203
Phone: 303.831.7364
Defendant
7
Also Present:
8 Ann Lundberg, Paralegal
Maryvonne Tompkins, Videographer
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Agren Document
286, 08/09/2019, & Video, Page14
Inc. of 55

2 of Civil Procedure, the continued video
3 deposition of VIRGINIA GIUFFRE, called by Defendant,
4 was taken on Monday, November 14, 2016, commencing at
5 8:04 a.m., at 150 East 10th Avenue, Denver, Colorado,
6 before Pamela J. Hansen, Registered Professional
7 Reporter, Certified Realtime Reporter and Notary
8 Public within Colorado.
9
* * * * * * *
10 I N D E X
11 VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II
12 EXAMINATION PAGE
13 By Ms. Menninger 354
14
15
16
17
18
19
20
21
22
23
24
25

Agren Document
286, 08/09/2019, & Video, Page15
Inc. of 55
1 INDEX OF EXHIBITS (continued)

2
INITIAL
4 Exhibit 1 Settlement Agreement and General 355
Release
5
Exhibit 2 List of names 370
6
Exhibit 3 Photocopy of photograph 408
7
8 attachments
9 Exhibit 5 Photocopy of photograph, with 417
attachments
10
11 attachments
12 Exhibit 7 Statements 437
13 Exhibit 8 History of education, with 462
attachment
14
Exhibit 9 Application for Employment, 474
15 with attachment
16 Exhibit 10 The Great Outdoors Community 481
Services Association, Inc.
17 Termination Form, with
attachments
18
Exhibit 11 7/6/2016 letter to Schultz 484
19 from Hayek, with attachments
20 Exhibit 12 Patient Registration 490
Information, with attachments
21
Exhibit 13 CVS Prescription Records 502
22 document, 7/29/2016, with
attachment
23
Exhibit 14 Affidavit of Custodian of 507
24 Records, Walgreen Company,
with attachments
25

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1 INITIAL
DESCRIPTION REFERENCE
2
Exhibit 15 Patient Health Summary, Clifton 512
3 Beach Medical & Surgical,
printed on 6/28/2016
4
Exhibit 16 Portions of deposition transcript 533
5 of Virginia Giuffre taken
May 3, 2016
6
Exhibit 17 Amendment/Errata Sheet signed 540
7 May 31, 2016 by Virginia Giuffre
8 Exhibit 18 Ad for Mar-a-Lago Club 548
9 Exhibit 19 The Mar-a-Lago Club, L.C. 549
Employment Policies, October 28,
10 1995
11 Exhibit 20 Page from the Mar-a-Lago Club 550
Employment Policies, Revised
12 10/2001
13
14
15
16
17
18
19
20
21
22
23
24
25

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1 didn't see them take pictures of the backs of them.

2 I'm not too sure who.
3 Q You don't remember sending to them a
4 photograph that included this wood around another
5 photograph?
6 A No.
7 Q Okay. You have mentioned a journalist by
8 the name of Sharon Churcher.
9 A Yes.
10 Q You are aware that Sharon Churcher
11 published news stories about you?
12 A Yes.
14 Go ahead.
15 Q (BY MS. MENNINGER) Is anything that you
16 have read in Sharon Churcher's news stories about you
17 untrue?
18 A I think Sharon did print some things that
19 I think she elaborated or maybe misheard. But, I
20 mean, if you have a specific document to show me, I'd
21 love to look at it and read it and tell you what I
22 think.
23 Q Is there anything, as you sit here today,
24 that you know of that Sharon Churcher printed about
25 you that is not true?

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1 A Not off the top of my head. If you show

2 me, like, a news clipping article or something, I can
3 definitely read it for you.
4 Q Is there anything that you know of that
5 Sharon Churcher has printed about Ghislaine Maxwell
6 that is not true?
7 A No, not off -- no, not off the top of my
8 head.
9 Q Is there anything that you recall saying
10 to Sharon Churcher that she then printed something
11 different than what you had said to her?
12 A Yeah, I've read stuff. I mean, I just --
13 I can't remember what, but I read something that I
14 think was, Oh, she got that wrong. I can't remember
15 an exact example off the top of my head.
16 Q Did you ever complain to Sharon Churcher
17 about things that she got wrong?
18 A I didn't see a point. I might have, but
19 I -- I didn't see a point really because it's already
20 printed, you know.
21 Q You had a fairly voluminous set of
22 communications with Sharon Churcher by e-mail,
23 correct?
25 A Voluminous, like a lot of them?

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1 Q (BY MS. MENNINGER) Yes.

2 A Yes.
3 Q And during any of those communications, do
4 you know whether she printed things about you after
5 you had any of those communications?
7 A I don't know. I know a lot of stuff was
8 printed, and I never really stopped to read who
9 printed the article, or wrote the article, I should
10 say. Sorry.
11 Q (BY MS. MENNINGER) Okay. I'll show you
12 Defendant's Exhibit 7.
13 (Exhibit 7 marked.)
14 THE DEPONENT: Thank you.
15 Q (BY MS. MENNINGER) I'll let you read
16 through the statements on the first page there, and
17 if there is anything that is not absolutely true,
18 just put a check by it and we'll come back to it.
19 A It's not very clear how she wrote it. "I
20 flew to the Caribbean with Jeffrey and then Ghislaine
21 Maxwell went to pick up Bill in a huge black
22 helicopter that Jeffrey had bought her."
23 That wasn't an eyewitness statement.
24 Like, I didn't see her do it. Ghislaine was the one
25 who told me about that; that she's the one who flew

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1 Bill.
2 Q All right. If you just want to put a
3 check by it, then we'll just come back and talk about
4 each one.
5 A Okay.
6 Q Just to move things along.
7 A Okay. I have made three checkmarks.
8 Q All right.
9 MS. MCCAWLEY: And I just -- before you
10 continue, I just want to identify for the record,
11 since this doesn't have any identifiers on it, are
12 you representing that these are statements from
13 Sharon Churcher?
14 MS. MENNINGER: I'm not representing
15 anything. I'm asking the witness questions about
16 these statements. I asked her is anything on here
17 not true. That's all I asked her.
18 Q (BY MS. MENNINGER) So which ones did you
19 put checkmarks by, Ms. Giuffre?
20 A I'd have been -- I'm sorry. "I'd have
21 been about 17 at the time. I flew to the Caribbean
22 with Jeffrey and then Ghislaine Maxwell went to pick
23 up Bill in a huge black helicopter that Jeffrey had
24 bought her."
25 Q Okay. And what else did you put a check

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1 by?
2 A "I used to get frightened flying with her
3 but Bill had the Secret Service with him and I
4 remember him talking about what a good job" --
5 sorry -- "job she did."
6 Q Okay. And what else did you put a check
7 by?
8 A "Donald Trump was also a good friend of
9 Jeffrey's. He didn't partake in any sex with any of
10 us but he flirted with me. He'd laugh and tell
11 Jeffrey, 'you've got the life.'"
12 Q Other than the three you've just
13 mentioned --
14 A Yeah.
15 Q -- everything else on here is absolutely
16 accurate?
18 A Yes. Well, to the best of my
19 recollection, yes.
20 Q (BY MS. MENNINGER) All right. What is
21 inaccurate about, "I'd have been about 17 at the
22 time. I flew to the Caribbean with Jeffrey and then
23 Ghislaine Maxwell went to pick up Bill in a huge
24 black helicopter that Jeffrey had bought her"?
25 A Because it makes it kind of sound like an

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1 eyewitness thing.
2 Q Okay. Did you say that statement to
3 Sharon Churcher?
4 A I said to Sharon that Ghislaine told me
5 that she flew Bill in the heli- -- the black
6 helicopter that Jeffrey bought her, and I just wanted
7 to clarify that I didn't actually see her do that. I
8 heard from Ghislaine that she did that.
9 Q You heard that from Ghislaine, and then
10 you reported to Sharon Churcher that you had heard
11 that from Ghislaine.
12 A Correct.
14 A I heard a lot of things from Ghislaine
15 that sounded too true -- too outrageous to be true,
16 but you never knew what to believe, so...
17 Q (BY MS. MENNINGER) Okay. And after
18 Sharon Churcher printed what she said you said, did
19 you complain to her that it was inaccurate?
20 A I might have verbally with her, but again,
21 I didn't see a point in making a hissy over it
22 because what was done was done. She had already
23 printed.
24 Q What was inaccurate about, "I used to get
25 frightened flying with her but Bill" said -- "had the

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1 Secret Service with him and I remember him talking

2 about what a good job she did"?
3 A I just don't remember saying that to her.
4 I don't remember saying I remember him talking about
5 what a good job she did.
6 Q All right.
7 A I just don't remember that at all.
8 Q Okay. And I guess, just to be clear, my
9 questions wasn't do you remember saying this to
10 Sharon Churcher; my question is, is that statement
11 accurate?
12 MS. MCCAWLEY: Well, objection.
13 Q (BY MS. MENNINGER) Did you used to get
14 frightened flying with her?
15 A Yes.
16 Q Okay. Did Bill have the Secret Service
17 with him?
18 A They were there, but not like on the --
19 not where we were eating.
20 Q Do you remember Bill talking about what a
21 good job she did?
22 A I don't remember that.
23 Q So what is inaccurate about that
24 statement?
25 A I just -- it's inaccurate because I don't

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1 remember him talking about what a good job she did.

2 I don't remember that.
3 Q Does it inaccurately suggest that Bill had
4 the Secret Service with him on a helicopter?
6 A Well, not being an eyewitness to it, I
7 wouldn't be able to tell you. I can't tell you what
8 I don't know.
9 Q (BY MS. MENNINGER) And do you believe you
10 said that statement to Sharon Churcher?
11 A I mean, Sharon and I talked a lot, and if
12 she misheard me or just wrote it in the way that she
13 thought she should, I have no control over that. So
14 I'm not too sure.
15 Q Did she record your interviews?
16 A Some of them. Some of them she didn't. I
17 mean, we, like -- we, like, met for like a week, and
18 we spent a lot of time together, and then even after
19 that we just continued, like, kind of a friendship.
20 Q All right. What's inaccurate about the
21 last statement on that page?
22 A "Donald Trump was also a good friend of
23 Jeffrey's." That part is true.
24 "He didn't partake in any" of -- "any sex
25 with any of us but he flirted with me." It's true

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1 that he didn't partake in any sex with us, and but

2 it's not true that he flirted with me. Donald Trump
3 never flirted with me.
4 Then the next sentence is, "He'd laugh and
5 tell Jeffrey, 'you've got the life.'" I never said
6 that to her.
7 Q When you say, "he didn't partake in any
8 sex with any of us," who is "us"?
9 A Girls. Just --
10 Q How do you know who Donald Trump -- Trump
11 had sex with?
12 A Oh, I didn't physically see him have sex
13 with any of the girls, so I can't say who he had sex
14 with in his whole life or not, but I just know it
15 wasn't with me when I was with other girls.
16 Q And who were the other girls that you were
17 with in Donald Trump's presence?
18 A None. There -- I worked for Donald Trump,
19 and I've met him probably a few times.
20 Q When have you met him?
21 A At Mar-a-Lago. My dad and him, I wouldn't
22 say they were friends, but my dad knew him and they
23 would talk all the time -- well, not all the time but
24 when they saw each other.
25 Q Have you ever been in Donald Trump and

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1 Jeffrey Epstein's presence with one another?

2 A No.
3 Q What is the basis for your statement that
4 Donald Trump is a good friend of Jeffrey's?
5 A Jeffrey told me that Donald Trump is a
6 good friend of his.
7 Q But you never observed them together?
8 A No, not that I can actually remember. I
9 mean, not off the top of my head, no.
10 Q When did Donald Trump flirt with you?
11 A He didn't. That's what's inaccurate.
12 Q Did you ever see Donald Trump at Jeffrey's
13 home?
14 A Not that I can remember.
15 Q On his island?
16 A No, not that I can remember.
17 Q In New Mexico?
18 A No, not that I can remember.
19 Q In New York?
20 A Not that I can remember.
21 Q All right. If you could turn to the
22 second page and read through those. Let me know if
23 any of those are inaccurate. Just put a check by
24 them and then we'll come back.
25 A Okay.

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1 MS. MCCAWLEY: Before you go, Virginia,

2 I'm going to object to the use of the second page of
3 this document. There's no time frame on it. There's
4 no source reference to it, so it's entirely unclear
5 where this has come from.
6 Q (BY MS. MENNINGER) Okay. Are you done?
7 A Yes.
8 Q Okay. What's the first one you've put a
9 check by?
10 A "The hammock photo was all over the
11 houses," in parentheses. And Bill Clinton and -- I'm
12 sorry, "Bill Clinton and Andrew," in parentheses,
13 "had to have seen it."
14 "All over the houses" is not my statement
15 and an exaggeration. They did have that picture in
16 the houses. And I believe, if I remember the
17 conversation correctly, she asked, Could have Bill
18 Clinton and Andrew seen the picture? And I said,
19 Yes, it's possible that they could have seen it.
20 So, I mean, it's just that -- it's not
21 that it's totally inaccurate. I just think it's like
22 journalist writing, had to have seen it. It doesn't
23 mean they saw it. I just think that if it was in
24 front of them, they would have seen it.
25 Q So she told you that -- you told her that

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1 the photograph was in the houses -- houses?

2 A Yes. I know he had it in New York on his
3 desk. I know he had it in Palm Beach. I know he had
4 it in the Caribbean. And I don't know if he had it
5 in New Mexico. I can't remember New Mexico. Maybe.
6 Q Where in Palm Beach was the photograph?
7 A The massage room.
8 Q Was that -- you did not say that they --
9 it was all over the houses?
10 A Correct. All over the houses would imply
11 that it's everywhere in the house, so...
12 Q You did not say that Andrew and Clinton
13 had to have seen the photograph?
14 A Correct. I -- it was more of a, if they
15 were in front of it, they would have seen it, kind of
16 a thing. I'm not saying it right. But it wasn't,
17 like, had to have seen it.
18 Q All right. What's the next statement that
19 you put a check by?
20 A I'm sorry, excuse me. My kids shared a
21 beautiful cough with me again.
22 "I spent four years as a millionaire's
23 personal masseuse."
24 Q What is inaccurate about that statement?
25 A We now know, according to the timelines

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1 that Mar-a-Lago was able to provide for us, that it

2 was not four years.
3 Q How many years was it?
4 A More like 2-1/2, I think, if I'm right, or
5 two. I'm sorry, I'm really bad at math. But yes,
6 the two period.
7 Q What's the next statement that you have
8 put a check by?
9 A "I was a pedophile's dream." I think she
10 took that out of context and made that her own little
11 headline.
12 Q Did you say that to her?
13 A I said something along the line like, I --
14 the -- the pedos loved me because I would do
15 everything that they wanted for them. But do I think
16 that -- yeah, I -- I know she made that line up
17 herself, the pedos -- pedophile's dream.
18 Q What's the next one you put a check by?
19 A I put a question mark next to the next
20 one. It says, "Three years later she was reunited
21 with her family." I don't know what that pertains
22 to. I don't know what timeline that means.
23 Q Was there a period of three years where
24 you were not with your family?
25 A There's been longer periods than that

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1 that -- when I wasn't with my family. That's what I

2 mean, I don't understand where that comes from.
3 "Three years later she was reunited with her family."
4 Q Prior to 2002, was there a period of three
5 years where you were not with your family?
6 A No.
7 Q Okay. Did you say to Sharon Churcher,
8 three years later, she was reunited with her family?
9 A That's what I don't understand. I don't
10 even know what that time periods pertains to.
11 Q Do you recall saying that to Sharon
12 Churcher?
13 A No.
15 A "After about two years he started to ask
16 me to entertain his friends."
17 Q What's wrong with that statement?
18 A It wasn't two years. I don't know where
19 she got that from.
20 Q Okay. How long was it?
21 A Like, I can't give you an exact time
22 period, but it wasn't right in the beginning. It was
23 after my training, or so to speak training. So, I
24 mean, my best guesstimate would be anywhere between
25 four to six months.

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1 Q So you did not say to Sharon Churcher,

2 "After about two years he asked me to entertain his
3 friends"?
4 A Correct.
6 A That's it. That's all I put a checkmark
7 next to.
8 Q So the rest of these are absolutely
9 accurate?
10 A Nothing a journalist writes is absolutely
11 accurate, but it's -- it sounds accurate, yes.
12 Q Do you recall Jeffrey Epstein saying to
13 you, "I've got a good friend and I need you to fly to
14 the island to entertain him, massage him and make him
15 feel how you make me feel"?
17 Go ahead.
18 A I do remember him saying that, and I think
19 that's more of a general- -- generalization for all
20 the times that I was sent to the -- where is this --
21 the island to entertain people. And that would be a
22 quote that she made but from my words saying that's
23 what he said to me when I had to go be with these
24 people that he sent me to.
25 Q (BY MS. MENNINGER) Did you say that

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1 sentence to her?
3 A I -- I can't remember. Like I said, I
4 think it's more of a generalization.
5 Q (BY MS. MENNINGER) Did you meet Al Gore?
6 A Yes.
7 Q Did you meet Heidi Klum?
8 A Yes.
9 Q Did you meet Naomi Campbell?
10 A Yes.
11 Q Did you go on a six-week trip with Epstein
12 in 2001?
13 A Yeah. Yes. Sorry.
14 Q When in 2001 did you go on a six-week trip
15 with him?
16 A I don't remember exactly when it was, but
17 it's that -- it's the one where we went to Tangier,
18 Morocco, England. I can't remember where else we
19 went. France.
20 Q Did the FBI tell you that Epstein had
21 hidden cameras watching you the entire time, even
22 when you were in the bathroom?
23 A Yes.
24 Q Did the FBI tell you "Everything he did
25 was illegal because I was under age"?

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1 A Yes.
2 Q Who in the FBI told you that?
3 A Whichever agent I was talking to.
4 Q Which agent were you talking to?
5 A I can't remember. I know I was talking to
6 Jason Richards, and there was a girl, I think -- I
7 want -- I want to say her name was Christina Pryor,
8 just off the top of my head. And then I think there
9 was two other agents actually at the consulate
10 building. I don't remember their names. Very hazy.
11 Q When was this conversation with the FBI?
12 A After Sharon printed the articles, the
13 first articles that came out. I don't know how many
14 she printed, but when the first articles came out,
15 after that the FBI contacted me.
16 Q And was the statement that the FBI told
17 you "Everything he did was illegal because I was
18 under age," in response to you telling them that you
19 were age 15 when you met Jeffrey?
21 A Well, that was the closest proximity I had
22 to go off of.
23 Q (BY MS. MENNINGER) Okay.
24 A So, yes. Although I still was under age,
25 I mean, even if I was 16 and 17.

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1 Q Okay. And then if you could do the last

2 page, same way; a check by anything that's not
3 absolutely accurate.
4 MS. MCCAWLEY: Okay. I'm going to object
5 to this as the last page has no identifier of time or
6 source on it.
7 A Okay. I'm ready.
8 Q (BY MS. MENNINGER) All right. Which ones
9 are inaccurate?
10 A The first one is, "Virginia got a
11 part-time job as a changing room assistant." I was a
12 full-time person there. Sorry.
13 Q Okay. So did you say that to Sharon?
14 A Again, I don't remember that exact
15 conversation, but I know it was a full-time job,
16 and -- I mean, full-time as in the, you know, the 9
17 to 5 or whatever hours it was, so it wasn't
18 part-time. I don't remember the exact conversation
19 that we had.
20 Q Okay. What's the next thing you put a
21 check by?
22 A I put a question mark next to, "Another
23 lady led me into Jeffrey's bedroom. The lady walked
24 me straight through into the massage room."
25 I have no idea what circumstance that

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1 pertains to. Again, I don't know what that means. I

2 don't even know what other lady she's talking about.
3 So...
4 Q So you don't recall saying that to Sharon
5 Churcher?
6 A Correct. I don't even know what it means.
7 Q Okay. What's the next one you have a
8 check by?
9 A "Afterwards, she was given two $100 bills
10 and told to return the next day. That was the
11 beginning of the four years she spent with Epstein."
12 Q All right. What's wrong about that
13 statement?
14 A Well, again, I just want to say that the
15 four years was inaccurate based upon memory and not
16 an actual timeline that we were able to get.
17 Q Did you say that to Sharon Churcher, that
18 it was four years?
19 A I don't know if I said that to her or --
20 oh, yeah, did I tell her it was four years? Yes, I
21 did. I'm sorry.
22 Q Okay. What else did you put a check by?
23 A Well, this one is a question mark again.
24 "Radar online has obtained exclusive diary entries of
25 a Teen Sex Slave."

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1 It wasn't really a diary. It was, like, I

2 don't know how many pages of something that I wrote,
3 and Sharon used it, so...
4 Q Did you tell Sharon it was your diary
5 entry?
6 A She knew it wasn't a diary entry. No.
7 Q Okay. Were you a teen sex slave?
8 A Yes.
9 Q What's the next one you have a checkmark
10 by?
11 A "I also saw Prince Andrew at a Ranch in
12 New Mexico."
13 Q Did you tell that to Sharon Churcher?
14 A No. And I think it's a mistake. Maybe
15 she meant somewhere else, but because we had been
16 talking about so much, maybe she just put New Mexico.
17 I don't think Sharon intentionally lied on any of
18 these. I just -- I think we talked so much over a
19 period of a week, and then after that we had phone
20 conversations, and so on and so forth, that some of
21 the information just got misheard or mishandled, or
22 whatever.
23 Q And what was printed was inaccurate?
24 A Was that printed? I don't -- I don't
25 remember reading that in the papers, but if it was

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1 printed it's inaccurate.

2 Q Do you recall reading any of the ones that
3 you put a checkmark by in the papers?
4 A There's been so much printed, it's hard
5 for me to remember. I mean, yes, it does sound like
6 stuff I read before.
7 Q When you spoke with Sharon Churcher, you
8 agreed to waive your anonymity, right?
9 A I did.
10 Q Why did you agree to do that?
11 A I felt it was time for me to tell my
12 story. I felt it was a good time for me to come
13 forward. I had done so much healing, and I thought
14 that it would be good for other people to hear what's
15 going on, how it's happening, how vulnerable other
16 girls can be and not even know the damage that it
17 causes later in life. And I just thought it would be
18 the right thing to do to come forward.
19 Q You authorized her to publish your name?
20 A I did.
21 Q And your photograph?
22 A Yes.
23 Q In 2011?
24 A I think that was the year, yes.
25 Q You posed for photographs with her,

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1 I, VIRGINIA GIUFFRE, do hereby certify that

2 I have read the foregoing transcript and that the
3 same and accompanying amendment sheets, if any,
4 constitute a true and complete record of my
5 testimony.
6 ____________________________
Signature of Deponent
7
( ) No amendments
8 ( ) Amendments attached
9
10 Acknowledged before me this _______ day

11 of _____________, 20___.
12
13
Notary Public: ___________________
14
My Commission Expires: ___________
15
Seal:
16
PJH
17
18
19
20
21
22
23
24
25

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4 I, Pamela J. Hansen, do hereby certify that
5 I am a Registered Professional Reporter and Notary
6 Public within the State of Colorado; that previous to
7 the commencement of the examination, the deponent was
8 duly sworn to testify to the truth.
19 signature this 23rd day of November, 2016.
20 My commission expires September 3, 2018.
21
22 _______________________________
Pamela J. Hansen, CRR, RPR, RMR
24
25

EXHIBIT QQ
EXHIBIT RR
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__________________________________________________
CONFIDENTIAL VIDEOTAPED DEPOSITION OF

VIRGINIA GIUFFRE May 3, 2016
__________________________________________________
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
__________________________________________________
APPEARANCES:
FAMER, JAFFE, WEISSING, EDWARDS, FISTOS &

LEHRMAN, P.L.
By Brad Edwards, Esq.
425 N. Andrews Avenue
Suite 2
Phone: 954.524.2820
Plaintiff

By Sigrid S. McCawley, Esq. (For Portion)
Suite 1200
Fort Lauderdale, FL 33301-2211
Phone: 954.356.0011
Plaintiff

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By Laura A. Menninger, Esq.
4 Denver, CO 80203
Phone: 303.831.7364
Defendant
7
Also Present:
8 Brenda Rodriguez, Paralegal
Nicholas F. Borgia, CLVS Videographer
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

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2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF
3 VIRGINIA GIUFFRE, called by Defendant, was taken on
4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150
5 East 10th Avenue, Denver, Colorado, before Kelly A.
6 Mackereth, Certified Shorthand Reporter, Registered
7 Professional Reporter, Certified Realtime Reporter
8 and Notary Public within Colorado.
9
* * * * * * *
10 I N D E X
11
EXAMINATION PAGE
12
MS. MENNINGER 8
13
14 PRODUCTION REQUEST(S):
15 (None.)
16
17
18
19
20
21
22
23
24
25

Agren Document
286, 08/09/2019, & Video, Page49
Inc. of 55
1 INDEX OF EXHIBITS
2
INITIAL
4
Exhibit 1 Complaint and Demand for Jury 17
5 Trial re Jane Doe No. 102 v.
Jeffrey Epstein
6
Exhibit 2 Jane Doe #3 and Jane Doe #4's 21
7 Motion Pursuant to Rule 21 for
Joinder in Action
8
Exhibit 3 Declaration of Virginia L. 23
9 Giuffre re Jane Doe #1 and Jane
Doe #2 vs. United States of
10 America
11 Exhibit 4 Declaration of Jane Doe 3 re 31
Jane Doe #1 and Jane Doe #2 vs.
12 United States of America
13 Exhibit 5 Declaration of Virginia Giuffre 33
re Bradley J. Edwards and
14 Paul G. Cassell vs. Alan M.
Dershowitz
15
Exhibit 6 FBI documentation, date of entry 36
16 7/5/13
17 Exhibit 7 Document titled Telecon, 39
Participants Jack Scarola, Brad
18 Edwards, Virginia Roberts. Re
Edwards adv. Epstein, 4/7/11,
19 (23 pages of transcription)
20 Exhibit 8 The Billionaire's Playboy Club, 41
By Virginia Roberts
21
Exhibit 9 Plaintiff's Response and 44
22 Objections to Defendant's First
Set of Discovery Requests to
23 Plaintiff re Giuffre v. Maxwell
24
25

Agren Document
286, 08/09/2019, & Video, Page50
Inc. of 55
1
INITIAL
3
Exhibit 10 Plaintiff's Supplemental 46
4 Response and Objections to
Defendant's First Set of
5 Discovery Requests to Plaintiff
6 Exhibit 11 Undated Declaration of Virginia 46
Giuffre re Plaintiff's
8 Set of Discovery Requests served
on March 22, 2016
9
Exhibit 12 Plaintiff's Second Amended 47
11 Set of Discovery Requests to
Plaintiff
12
Exhibit 13 Mrs. Virginia Giuffre resume 67
13
Exhibit 14 Compilation of e-mails re Open 68
14 Position - Virginia Giuffre
15 Exhibit 15 Virginia Lee Roberts passport 180
application
16
Exhibit 16 Composite of e-mail strings 251
17
18 Giuffre and Silva and others
Virginia Giuffre and Sandra
20 White
Marianne Strong and Virginia
22 Giuffre
Virginia Roberts and Jason
24 Richards
25

Agren Document
286, 08/09/2019, & Video, Page51
Inc. of 55
1
INITIAL
3
4 Sharon Churcher and Virginia
Giuffre
5
Exhibit 22 Compilation of e-mails among 287
6 Sharon Churcher, Michael Thomas,
Virginia Giuffre and others
7
Exhibit 23 Compilation of May 2011 e-mails 288
8 among Sharon Churcher, Virginia
Giuffre, Paulo Silva and others
9
Exhibit 24 Compilation of June 2011 e-mails 289
10 between Virginia Giuffre and
Sharon Churcher
11
Exhibit 26 PR Hub Statement on Behalf of 300
12 Ghislaine Maxwell article
13 Exhibit 27 1/2/15 e-mail from Ross Gow to 309
To Whom It May Concern
14
15
16
17
18
19
20
21
22
23
24
25

Agren Document
286, 08/09/2019, & Video, Page52
Inc. of 55
1 Some names have been changed in order to protect

2 other people.
3 Q (BY MS. MENNINGER) Protect their privacy?
4 A Protect their privacy, yeah, I would say,
5 just not getting them involved in, if this were to
6 ever go public.
7 Q Well, again, without rereading the whole
8 manuscript --
9 A Reading it, yeah. I'm trying to see if I
10 can -- see something in here.
11 Q Let me narrow my question and maybe that
12 will help.
13 A Yes.
14 Q Is there anything -- well, first of all,
15 did you author that entire manuscript?
16 A Yes, I did.
17 Q Did anyone else author part of that
18 manuscript?
19 A Do you mean did anyone else write this
20 with me?
21 Q Right.
22 A No.
23 Q That's all your writing?
24 A This is my writing.
25 Q Okay. To the best of your recollection,

Agren Document
286, 08/09/2019, & Video, Page53
Inc. of 55
1 as you sit here right now, is there anything in that

2 manuscript about Ghislaine Maxwell that is untrue?
3 A I don't believe so. Like I said, there is
4 a lot of stuff that I actually have left out of here.
5 Q Um-hum.
6 A So there is a lot more information I could
7 put in there. But as far as Ghislaine Maxwell goes,
8 I would like to say that there is 99.9 percent of it
9 would be to the correct knowledge.
10 Q All right. Is there anything that you --
11 and I understand you're doing this from memory. Is
12 there anything that you recall, as you're sitting
13 here today, about Ghislaine Maxwell that is contained
14 in that manuscript, that is not true?
15 A You know, I haven't read this in a very
16 long time. I don't believe that there's anything in
17 here about Ghislaine Maxwell that is not true.
18 MR. EDWARDS: I'd just ask, Counsel, if
19 you have anything specific to show her about
20 Ghislaine Maxwell --
21 MS. MENNINGER: I'll ask questions.
22 MR. EDWARDS: -- I'll have her look at it.
23 MS. MENNINGER: I'll ask questions.
24 MR. EDWARDS: I know, but I want the
25 record clear that if she hasn't read it in a long

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286, 08/09/2019, & Video, Page54
Inc. of 55
1 I, VIRGINIA GIUFFRE, do hereby certify that

2 I have read the foregoing transcript and that the
3 same and accompanying amendment sheets, if any,
4 constitute a true and complete record of my
5 testimony.
6
8
________________________________
9 Signature of Deponent
( ) No Amendments
10 ( ) Amendments Attached
11 Acknowledged before me this
12 _____ day of ______________, 2016.
13
14 Notary Public: ________________________

15 Address: _____________________________
16 _____________________________
17 My commission expires _________________
18 Seal:
19
20
21 KAM
22
23
24
25

Agren Document
286, 08/09/2019, & Video, Page55
Inc. of 55
4 I, Kelly A. Mackereth, do hereby certify
5 that I am a Registered Professional Reporter and
6 Notary Public within the State of Colorado; that
7 previous to the commencement of the examination, the
8 deponent was duly sworn to testify to the truth.
19 signature this 11th day of May, 2016.
20 My commission expires April 21, 2019.
21
22 ____________________________
Kelly A. Mackereth, CRR, RPR, CSR
24
25


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Case 18-2868, Document 271, 08/09/2019, 2628203, Page1 of 1

UNITED STATES COURT OF APPEALS

Julie Brown, Miami Herald Media Company,

IT IS HEREBY ORDERED that the petition is denied.

FOR THE COURT:

Filed Document Description Page Docket Text

UNITED STATES COURT OF APPEALS

Before: José A. Cabranes,

Julie Brown, Miami Herald Media Company,

Alan M. Dershowitz, Michael Cernovich,

For the Court:

Catherine O’Hagan Wolfe,

UNITED STATES COURT OF APPEALS

Before: José A. Cabranes,

Julie Brown, Miami Herald Media Company,

For the Court:

Catherine O’Hagan Wolfe,

MANDATE ISSUED ON 08/09/2019

Intervenors‐Appellants Alan Dershowitz, Michael Cernovich,

District Court failed to conduct the requisite particularized review

Intervenors‐Appellants Alan M. Dershowitz (“Dershowitz”),

Dershowitz moved to intervene, seeking to “strike the

defense or any redundant, immaterial, impertinent, or scandalous

On September 21, 2015, Giuffre filed the underlying action

future sealing requests. In total, 167 documents—nearly one‐fifth of

On January 6, 2017, Maxwell filed a motion for summary

The Appellants timely appealed from each of the orders

summary judgment materials and individualized review of the

When reviewing a district court’s decision to seal a filing or

Second, in contravention of our precedent, the District Court

Finally, upon reviewing the summary judgment materials in

The remaining sealed materials at issue here include filings

The Supreme Court has explained that “[e]very court has

2019 Edition, Rule 6.1,

pleadings, complaints, and briefs—while supposedly based on

Moreover, court filings are, in some respects, particularly

broadly, they nevertheless maintain an important (if rarely implemented)

(1) Materials submitted in connection with a motion for

(3) Materials submitted in connection with, and relevant to,

UNITED STATES DISTRICT COURT

DEFENDANT’S STATEMENT OF MATERIAL UNDISPUTED

objections by making this submission.

1. Ms. Maxwell’s response to publications of plaintiff’s false allegations: the

businessman,” a “world-renowned scientist,” a “respected liberal politician,” and a “foreign head

3. In response to the allegations Ms. Maxwell’s British attorney, working with

4. The statement read in full:

Statement on Behalf of Ghislaine Maxwell

It is unacceptable that letters sent by Ms Maxwell’s legal representatives to

5. Plaintiff’s gratuitous and “lurid” accusations in an unrelated action. In 2008 two

government violated their CVRA rights by entering into the agreement.

Ms. Giuffre filed a “corrected” joinder motion.

The court denied plaintiff’s joinder motion.

 Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme.

 She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar

 At the mansion, when plaintiff began giving Epstein a massage, he and

 Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.”

 Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.”

 Ms. Maxwell “took numerous sexually explicit pictures of underage girls

 Plaintiff was “forced to have sexual relations” with Prince Andrew in

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