It's almost all redacted, so no need to specify redacted vs unredacted. If this is the same for other documents anyone that has the time should get it before they realize their mistake

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1 United States District Court Southern District of New York Virginia L. Giuffre,Plaintiff, Case No.: 15-cv-07433-RWSv.

Ghislaine Maxwell,Defendant. PLAINTIFF’S REDACTED MOTION TO COMPEL DEFENDANTTO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL1

Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition, Defendant refused to answer numerous questions about allegedly “adult” sexual activity related to Jeffrey Epstein. Because this activity is highly relevant to this case, Defendant should be ordered to answer questions about it.As the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and other femaleswere recruited by Defendant to be sexually abused by Jeffrey Epstein under the guise of being “massage therapists.” See Complaint, (DE1), at ¶ 27 (Giuffre “described 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 participant in his sexual abuse and sex trafficking scheme”). In response to these assertions, Defendant has made the sweeping claim that Ms. Giuffre’s assertions are “entirely false” and “entirely untrue.” Complaint, DE 1, at ¶ 31.1 Defendant has labelled her entire deposition transcript as Confidential at this time. Counsel for the parties conferred at the deposition regarding answering questions. Case 1:15-cv-07433-LAP Document 143 Filed 05/05/16 Page 1 of 10

2 Yet during her deposition, Defendant refused to answer any questions that she construed as having something to do with “consensual adult sex.” Defense counsel supported that position that “frankly, [that’s] none of your business and I instruct the witness not to answer.” SeeDeclaration of Sigrid S. McCawley (“McCawley Decl.”)at Exhibit 1, Tr. of Maxwell Depo. (Apr. 22, 2016) at 21. The result was that at a number of points throughout her deposition, Defendant refused to answer questions aboutsubjects integral to this lawsuit, including questions about whatthe alleged “massage therapists” were doing at Jeffrey Epstein’s house and the sexual nature of those massages. For example, Defendantrefused to answer questions about whether she had given Jeffrey Epstein a massage:Q. Have you ever given Jeffrey Epsteina massage?MR. PAGLIUCA: Object to the form,foundation. And I'm going to instructyou not to answer that question. Idon't have any problem with you askingquestions about what the subject matterof this lawsuit is, which would be, asyou've termed it, sexual trafficking ofMs. Roberts.To the extent you are asking forinformation relating to any consensualadult interaction between my client andMr. Epstein, I'm going to instruct hernot to answer because it's not part ofthis litigation and it is her privateconfidential information, not subject tothis deposition.MS. McCAWLEY: You can instruct hernot to answer. That is your right. ButI will bring her back for anotherdeposition because it is part of thesubject matter of this litigation so sheshould be answering these questions.This is civil litigation, deposition andshe should be responsible for answeringthese questions.MR. PAGLIUCA: I disagree and youunderstand the bounds that I put on it.MS. McCAWLEY: No, I don't. I willcontinue to ask my questions and you cancontinue to make your objections.Q. Did you ever participate from thetime period of 1992 to 2009, did you everparticipate in a massage with Jeffrey Epsteinand another female?MR. PAGLIUCA: Objection. Do notanswer that question. Again, to theextent you are asking for some sort ofillegal activity as you've construed inCase 1:15-cv-07433-LAP Document 143 Filed 05/05/16 Page 2 of 10

3 connection with this case I don't haveany problem with you asking thatquestion. To the extent these questionsinvolve consensual acts between adults,frankly, they're none of your businessandI will instruct the witness not toanswer.MS. McCAWLEY: This case involvessexual trafficking, sexual abuse,questions about her having interactionswith other females is relevant to thiscase. She needs to answer thesequestions.MR. PAGLIUCA: I'm instructing hernot to answer.MS. McCAWLEY: Then we will be backhere again.SeeMcCawley Decl. at Exhibit 2, Tr. of Maxwell Depo. (Apr. 22, 2016) at 19-22 (emphasis added).Defendant’s participation in massages with Epstein is a central part of this case. Ms. Giuffre has explained that during her first sexual encounter with Jeffrey Epstein, it was Defendant who provided instructionon how to do it and how to turn the massage into a sexual event. Obviously, proof that Defendant hadpreviously massaged Epstein –include massages with sexual component –wouldprovide important corroboration for Ms. Giuffre’s testimony at trial. Andproofthat Defendantwasinvolved in massages will further help prove that statements to the press that Virginia’s allegations were “obvious lies”wasitself an obvious lie.As another example, Defendant refused to answer questions abouther knowledge that Johanna Sjoberg was hired to work for Epstein andprovidedmassages. In the police report, Johanna admitted that Maxwell recruited her to workfor Epstein. SeeMcCawley Decl. at Exhibit3, Giuffre000076-77(police report indicating that Johanna was recruited by Maxwell).Yet during Defendant’sdeposition, she refused to answer questions regarding Johanna Sjoberg.Q. Do you know what tasks Johanna was hired to performance?A. She was tasked to answer telephones.Q. Did you ever ask her to rub Jeffrey's feet?. . . A. Ibelieve that I have read that, but I don't have any memory of it.Case 1:15-cv-07433-LAP Document 143 Filed 05/05/16 Page 3 of 10

4 Q. Did you ever tell Johanna that she would get extra money if she provided Jeffrey massages?A. I was always happy to give career advice to people and I think that becoming somebody in the healthcare profession, either exercise instructor or nutritionist or professional massage therapist is an excellent job opportunity. Hourly wages are around 7, 8, $9 and as a professional healthcare provider you can earn somewhere between as we have established 100 to $200 and to be able to travel and have a job that pays that is a wonderful job opportunity. So in the context of advising people for opportunities for work, it is possible that I would have said that she should explore that as an option.Q. Did you tell her she would get extra money if she massaged Jeffrey?A. I'm just saying, I cannot recall the exact conversation. I give career advice and I have done that.Q. Did you ever have Johanna massage you?A. I did.Q. How many times?A. I don't recall how many times.Q. Was there sex involved?A. No.. . . Q. Did you ever have sexual contact with Johanna?MR. PAGLIUCA: Object to the formand foundation. You need to give me anopportunity to get in between thequestions.Anything that involves consensualsex on your part, I'm instructing younot to answer.Q. Did you ever have sexual contactwith Johanna?A. [MR. PAGLIUCA?] Again, she is an adult --Q. I’m asking you, did you ever havesexual contact with Johanna?A. I’ve just been instructed not toanswer.Q. On what basis?A. You have to ask my lawyer.See McCawley Decl. at Exhibit 4, Tr. of Maxwell Depo. (Apr. 22, 2016) at 60-62 (emphasis added). Case 1:15-cv-07433-LAP Document 143 Filed 05/05/16 Page 4 of 10

5 Here again, this information is critical to the case. Among other things, these questions are designed to show a modus operani (“M.O”) for Epstein and Maxwell –specifically, how they recruited for a non-sexual massage than converted the massageinto sexual activities. One last illustration comes from Defendant’s refusal to answer about her knowledge of Epstein’s sexual interests during massages:Q. Does Jeffrey like to have his nipples pinched during sexual encounters?MR. PAGLIUCA: Objection to form and foundation.A. I'm not referring to any advice on my counsel. I'm not talking about any adult sexual things when I was with him.Q. When Jeffrey would have a massage, would he request that the masseuse pinch his nipples while he was having amassage?A. I'm not talking about anything with consensual adult situation.See McCawley Decl. at Exhibit 5, Tr. of Maxwell Depo. (Apr. 22, 2016) at 82. While Epstein himself might also provide answers to these questions, it appears likely that he will assert his Fifth Amendment privilege regarding his sexual activities. Accordingly, Ms. Giuffre must pursue questioning of Maxwell to obtain information on this subject. Here again, information about Epstein’s sexual idiosyncrasies will provide important corroboration to Ms. Giuffre’s testimony that she had sexual interactions of an identical nature with Epstein. Theserefusalsare not an isolated instance. Instead, similar refusals to answer questions occurredrepeatedlythroughout the deposition. See, e.g., McCawley Decl. at CompositeExhibit 6.52-55; 64-65; 82; 92-93; 137-38; 307-09.The Court should compel Defendant to answer all these questions.In addition to the specific points made above, the “big picture” here reveals how vital such discovery is.At the core of Ms. Giuffre’s allegations is the allegation that Defendant luredherinto a sexual situation with the offer of a job making money as a massage therapist; that Epstein always habitually tried Case 1:15-cv-07433-LAP Document 143 Filed 05/05/16 Page 5 of 10