1320-6.pdf

"Defendant admitted that she worked for Epstein from 1992 to 2009."

"at the heart of this case lies the issue of Defendant’s knowledge that Ms. Giuffre was sexually abused by Jeffrey Epstein."

"Defendant was on Epstein’s planes over 300 times"

"23 times with Ms. Giuffre when Ms. Giuffre was underage."

"a photograph the three – Ms. Giuffre, Prince Andrew and Defendant – all standing together in Defendant’s home."

"Plaintiff Virginia Giuffre"

"Ghislaine Maxwell, Defendant."

"Alfredo Rodriguez, who was Jeffrey Epstein’s household manager"

"Juan Alessi, another household employee, also testified that young girls were regularly present at Jeffrey Epstein’s home"

"statements made by Ms. Giuffre that she was recruited, by Defendant, to be paid as a masseuse, yet was enticed or coerced into engaging in sexual acts"

"Mrs. Maxwell called me and told me not to ever discuss or contact her again in a threaten(ing) way... She said I forbid you that you’re going to be – "

"Alfredo Rodriguez July 29, 2009 Dep. Tr. at 176-177"

"she was recruited... to be paid as a masseuse, yet was enticed or coerced into engaging in sexual acts with Epstein"

"Sigrid McCawley (Pro Hac Vice)... Boies Schiller & Flexner LLP"

"Boies Schiller & Flexner LLP... /s/ Sigrid S. McCawley"

"Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L."

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

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

"Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law"

"I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system."

"foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. "

"foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. "

"Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504"

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

"Defendant recruited Ms. Giuffre to be involved in massages of a sexual nature with Epstein."

"Ms. Giuffre at her London townhome with Prince Andrew... a photograph the three – Ms. Giuffre, Prince Andrew and Defendant – all standing together in "

"Defendant’s interactions with females to introduce to Jeffrey Epstein for the purpose of performing work, including sexual massages"

"noting that high school age girls come to the home where Jeffrey Epstein and Ms. Maxwell reside"

"he would clean up sex toys that were kept in Ms. Maxwell’s closet... he observed girls at the house, including one named Virginia"

"Defendant’s sexual relationship with Epstein from 1992 to 2009"