1320-10.pdf

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

"Jeffrey Epstein’s various private mansions"

"one of Epstein’s planes"

"Johanna Sjoberg (3 1/2 Hours)"

"Future Depositions Sought By Ms. Giuffre... Juan Alessi"

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

"this case involves allegations that Ms. Giuffre was a victim of sexual abuse when she was under the age of 18"

"Ghislaine Maxwell. Therefore, Ms. Giuffre is now required to take the deposition"

"After Ms. Sjoberg began to work for Defendant inside the home she shared with Epstein"

"Ms. Giuffre has alleged that Defendant recruited her and other young females, unexperienced in massage, for sex with Jeffrey Epstein"

"Ms. Maxwell, a stranger to her, approached her on her college campus, and told her she would hire Ms. Sjoberg as her personal assistant."

"Defendant revealed that Ms. Sjoberg’s true job was to complete sex acts with Jeffrey Epstein."

"Sarah Kellen recruited girls under the age of 18 to come to Epstein’s mansions."

"May 17, 2016 Email Correspondence from Sigrid McCawley... Ms. Giuffre’s ability to determine exactly which depositions would need to be taken"

"McCawley Decl. at Exhibit 1, May 17, 2016 Email Correspondence from Sigrid McCawley to Laura Menninger... Ms. Maxwell waited until one day before"

"flying to London on one of Epstein’s planes with Maxwell"

"Johanna confirmed that Maxwell recruited her to work as an assistant but she was almost immediately converted into a massage therapist"

"worked for Maxwell and Epstein from 2001 – 2006"

"Whether Defendant introduced Ms. Giuffre to Prince Andrew in London."

"Whether Ms. Giuffre ever stayed at Defendants home in London."

"Whether Defendant could recall the purpose of a trip to Thailand with Epstein and former President Clinton was."

"the flight logs produced by Dave Rogers (one of Epsteins pilots)"

"Whether Defendant knew what her press agent, Ross Gow, was referring to"

"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 didnt finish your"

"Johanna testified that Jeffrey made her perform sexual acts during massages including sexual toys and she had intercourse with him."

"She gave a name of a girl from a restaurant to Maxwell and Maxwell paid her $200.00 for the girls’ name."

"Mr. Alessi was one of the employees in Epstein’s mansion."

"Rodgers was one of the pilots for Epstein’s private jets"

"Jo Jo Fontanella... has been working as Jeffrey Epstein’s butler in his New York mansion"

"Mr. Gow is Defendant’s press agent who issued the press statement at issue in this case on Defendant’s behalf."

"he can testify that Defendant recruited females for sex with him, including Mrs. Giuffre, under the offer of being a massage therapist, and ultimately"

"Jeffrey Epstein, who is in a joint defense with Defendant"

"Emmy Taylor was Defendant’s assistant during the time Ms. Giuffre was being abused. Ms. Taylor was referred to by the Defendant as my slave"

"Ms. Marcinkova was specifically identified by the U.S. Attorney’s Office for the Southern District of Florida as a potential co-conspirator of Epstein"

"Epstein lies at the center of this case, and he can testify that Defendant recruited females for sex with him, including Mrs. Giuffre"

"Detective Recarey is expected to testify regarding his investigation, what he observed, the evidence he collected from Mr. Epstein’s Palm Beach mansio"

"He was the Police Chief who was responsible for overseeing the Palm Beach Epstein investigation."

"Maxwell's role in the recruitment of females. ... Defendant recruited females for sex with him, including Mrs. Giuffre"

"she observed the recruitment of underage girls for sex and, in fact, participated in sex acts with minors."

"Jeffrey Epstein is a pragmatically noncaptioned party in interest regarding issues of whether he and Defendant together sexually abused Ms. Giuffre."

"Defendant appears ready to brand Ms. Giuffre as a liar... regarding issues of whether he and Defendant together sexually abused Ms. Giuffre."

"And Defendant is in a joint defense agreement with Epstein."

"Ms. Giuffre respectfully requests that she be allowed to take a total seventeen depositions in this case."

"Case 1:15-cv-07433-LAP... Defendant appears ready to brand Ms. Giuffre as a liar"

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

"Ms. Giuffre has alleged that Defendant recruited females for Mr. Epstein, including underage females like herself"

"Defendant, instead, had to finish her job for her and cause Epstein and complete the sex act."

"Whether Defendant introduced Sjoberg to Prince Andrew."

"during the years that Defendant was working with him"

"Maxwell told Johanna to always act grateful to Jeffrey Epstein."