1320-24.pdf

"Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant."

"Defendant (not Jeffrey Epstein) recruited and hired her under the pretext of being a personal assistant to provide sexual massages."

"her business was to provide girls for Jeffrey Epstein to have sex with."

"Plaintiff Virginia Giuffre, by and through her undersigned counsel... Sigrid McCawley"

"Sigrid McCawley BOIES, SCHILLER & FLEXNER LLP"

"Ms. Sjoberg’s deposition testimony in its entirety (DE 173-5)"

"direct evidence that Defendant defamed her when calling her a liar. Clearly... in this defamation case"

"Defendant Maxwell has produced several emails between Epstein and herself discussing Ms. Giuffre."

"Respectfully Submitted... By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice)"

"Sigrid McCawley... Boies Schiller & Flexner LLP 401 E. Las Olas Blvd."

"David Boies Boies Schiller & Flexner LLP 333 Main Street"

"Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301"

"I HEREBY CERTIFY that on the 14th day of June, 2016, I electronically filed the foregoing document with the Clerk of Court"

"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. "

"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."

"Bradley J. Edwards (Pro Hac Vice) ... Case 1:15-cv-07433-LAP"

"Paul G. Cassell (Pro Hac Vice) ... Case 1:15-cv-07433-LAP"

"Maxwell hired to recruit girls for Jeffrey Epstein... Defendant acted as Jeffrey Epstein’s madam"

"Defendant had threatened a terrified 15 year old girl and confiscated her passport... threatened by Ghislaine not to discuss this"

"Ghislaine was the one that instructed the girls... they called it the kissing game... Sitting right next to Jeffrey"

"Case 1:15-cv-07433-LAP... Ms. Giuffre is still working diligently with opposing counsel"

"Defendant served generally as a recruiter of girls for Epstein and that Epstein sexually abused the underage girls"

"Epstein... would fully confirm Ms. Giuffre’s account of her sexual abuse... avoid answering questions about his sexual abuse of Ms. Giuffre."

"she was on Epstein private jet with Ms. Giuffre over 20 times while Ms. Giuffre was a minor"

"she was on Epstein private jet with Ms. Giuffre over 20 times"

"Maxwell expected you to perform sexual acts when you were massaging Jeffrey? A. I can answer? Yes"

"Ms. Giuffre mentioned former President Bill Clinton’s close personal relationship with Defendant and Jeffrey Epstein."

"Ms. Giuffre mentioned former President Bill Clinton’s close personal relationship with Defendant and Jeffrey Epstein."

"recruitment and management of the girls for Jeffrey Epstein was a major aspect of Defendant’s job"

"make her have sex with Epstein on his private island... threatened again by Jeffrey and Ghislaine not to talk about what I had mentioned earlier, abou"

"Ms. Giuffre’s account of Defendant being a recruiter of females for Epstein... evidence of being recruited by Defendant and being sexually assaulted"

"other witnesses’ accounts of what Defendant’s job was for Epstein"

"Defendant recruited her for the same purposes and in the same manner."

"Apparently privy to her former boyfriend Epstein’s anticipated plans in this regard"

"It took Ms. Giuffre’s motion for alternative service (DE 160) to convince Jeffrey Epstein to allow his attorney to accept service of process."

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

"Sarah took her passport and phone and gave it to Ghislaine Maxwell"

"corroborates Ms. Giuffre’s accounts concerning her being trafficked to Prince Andrew"