1320-2.pdf

"Virginia L. Giuffre, Plaintiff, V. Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS"

"Johanna admitted that Maxwell recruited her to work for Epstein. See Mccawley Deel. at Exhibit 3, Giuffre000076-77 (police report indicating that Joha"

"Q. Do you know what tasks Johanna was hired to performance? A. She was tasked to answer telephones."

"Q. Did you ever have Johanna massage you? A. 1 did."

"MR. PAGLIUCA: Object to the form, foundation. And I'm going to instruct you not to answer that question."

"Tr. of Maxwell Depo. (Apr. 22, 2016) at 21."

"Maxwell recruited other females for an ostensibly proper position, such as therapeutic masseuse, with knowledge that the intent was for that person wo"

"Defendant lured her into a sexual situation with the offer of a job making money as a massage therapist... including underage females like Ms Giuffre."

"The Court should compel Defendant to answer all these questions."

"At the core of Ms. Giuffre's allegations is the allegation that Defendant lured her into a sexual situation"

"Sigrid cCawley... Boies Schiller & Flexner LLP"

"Paul G. Cassell (Pro Hae Vice) S.J. Quinney College of Law University of Utah"

"Ms. Giuffre must pursue questioning of Maxwell... See Mccawley Deel."

"Tr. of Maxwell Depo. (Apr. 22, 2016) at 82."

"Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C."

"Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C."

"HADDON, MORGAN & FOREMAN, P.C. 150 East 10 th Avenue Denver, Colorado 80203"

"Maxwell's role as one of the main women who Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator and participan"

"this defamation case involves Ms. Giuffre's assertions that she and other females were recruited by Defendant to be sexually abused by Jeffrey Epstein"

"Ms. Giuffre's testimony that she had sexual interactions of an identical nature with Epstein."

"Ms. Giuffre has explained that during her first sexual encounter with Jeffrey Epstein, it was Defendant who provided instruction on how to do it"

"Maxwell recruited other females... with knowledge that the intent was for that person would be pressured to provide sexual gratification to Epstein."

"using the CM/ECF system. I also certify that the foregoing document is being served this day"