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Depositions (6,483 documents)
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 15 of 27
CMPNAMAWNE
Page 371
New York what were you doing getting to names and
phone numbers and then pictures of girls?
A. Iwas trying t
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 17 of 27
VON TM SBWNe
Page 379
pictures in the dining room and the library.
A. Yes.
Q, Photographs.
A. Yes,
Q. Okay, Was she taking -
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 6 of 27
WOWNAUAWNHE
Page 335
Q. Do you remember whether she came to the 1
house on more than one occasion? 2
A. I heard her name several
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 14 of 27
WDANANDWNE
Page 367
Q. Up to New York? 1
A. Yes. 2
Q. Were you going to pdf them? 3
A, Yes, 4
Q. And did she have a fax machine -
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 11 of 27
Page 355
Q. I'm not trying to make you a sex expert.
Also, I assume that when you've been in
CVS or Walgreens, for that matter Pu
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 10 of 27
WMBNAWAWNHY
was at that time?
A. No, I didn't know.
Q. If I was to tell you she was born in
December of '86 which would have ma
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 16 of 27
Page 375
1 A. Yes.
2 Q. Allright. And then you saw another
3 picture of a Brazilian woman who had traveled or
4 flown on the pl
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 20 of 27
Page 391 Page 393
1 Q. Allright. In terms of these wealthy 1 about what they do?
2 people that you've worked for, these individual
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 18 of 27
WOONOAUDAWNHH
Page 383
you about having driven J and you recalled
having had her in the Suburban specifically,
A. Yes.
Q. Do yo
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 7 of 27
WONAMNDWNY
22
23
24
25
Page 339
You're not required to speculate, you're
not required to guess, you're not required to
assume bec
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 13 of 27
WOMNAUDWNHE
Page 363
I don't know which room, sir.
Q. Okay. Did you recognize both the girls
or just one of the girls?
A. The
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 4 of 27
Page 299 Page 301
A. I don't remember, Ma'am. He came from video, even phones.
New Abany, Ohio. Q. Would he also repair the telev
Case 1:15-cv-07433-LAP Document 1331-15 Filed 01/05/24 Page 5 of 27
WOBNAHAUWNE
19 Q. When I asked you about Ms. Kellen whether Q. I believe you said they were more casual
20 she had a list of the g
Case 1:15-cv-07433-LAP Document 1331-14 Filed 01/05/24 Page 1 of 4
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
Vv.
Ghislaine
Case 1:15-cv-07433-LAP Document 1331-13 Filed 01/05/24 Page 14 of 22
Nevertheless, the Court need not resolve these evidentiary issues here, in a motion to
exclude testimony by Instead, the Court sho
Case 1:15-cv-07433-LAP Document 1331-13 Filed 01/05/24 Page 8 of 22
circumstances make it desirable — in the interest of justice and with due regard to the importance
of live testimony in open court
WONAUNDBUNY
Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 6 of 8
Page 463
Q. -- to sexually please Mr. Epstein.
Right?
MR. CRITTON; Form.
THE WITNESS: Yes.
BY MR, EDWARDS;
Q. I mean, t
WaANAHAWN
Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 5 of 8
Page 439
Q. And you said that that was - the massage
table was similar in kind to that used by Mr.
Epstein?
A. That's c
WCONTDUNEWNE
Page 467
that matter anyone else who was upstairs?
A. Yes.
MR. HOROWITZ: Form.
MR. EDWARDS: Form.
MR, WILLITS: Object to the form,
MR. CRITTON: Thank you,
MS. EZELL: I just have a couple
Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 4 of 8
RICHARD WILLITS, ESQ.
2290 10th AVenue North
Suite 404
Lake Worth, Florida 33461
Attomey for C.M.A.
Appeared via telephone.
BURMAN
Case 1:15-cv-07433-LAP Document 1331-10 Filed 01/05/24 Page 15 of 15
CE © CONFIDENTIAL
CERTIFICATE OF OATH
STATE OF FLORIDA )
COUNTY OF MIAMI-DADE )
I, the undersigned authority, certify that
SSS 7
Case 1:15-cv-07433-LAP Document 1331-11 Filed 01/05/24 Page 8 of 8
Page 473
1 THE STATE OF FLORIDA, )
2 COUNTY OF DADE. )
3
4
5 1, the undersigned authority, certify
6 that ALFREDO RODRIGUEZ persona
Case 1:15-cv-07433-LAP Document 1331-10 Filed 01/05/24 Page 8 of 15
Page 17
CONFIDENTIAL
QO. Did you, at 16 years old or 17 years old,
have any massage training or experience?
As No.
Q. Did ——————
Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 2 of 12
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
CASE NO. 15-CV-07433-RWS
VIRGINIA L. GIUFFRE,
Plaintiff,
Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 5 of 12
INDEX
WITNESS:
JEFFREY EDWARD EPSTEIN
DIRECT EXAMINATION
BY MR. CASSELL:
CROSS-EXAMINATION
BY MR. PAGLIUCA:
REDIRECT EXAMINATION
B
Case 1:15-cv-07433-LAP Document 1331-10 Filed 01/05/24 Page 2 of 15
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO. 15-CV-07433-RWS
VIRGINIA L. GIUFFRE,
Plaintiff,
Vv.
GHISLAIN
Case 1:15-cv-07433-LAP Document 1331-8 Filed 01/05/24 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ween teen eee eens xX
VIRGINIA L. GIUFFRE,
Plaintiff, :
Vv. : 15-cv-07433
Case 1:15-cv-07433-LAP Document 1331-8 Filed 01/05/24 Page 2 of 3
3. Attached as Exhibit B (filed under seal) are true and correct copies of excerpts from
the deposition of Detective Joseph Recarey o
Case 1:15-cv-07433-LAP Document 1331-6 Filed 01/05/24 Page 7 of 9
ED STATES DISTRICT COURT
THERN DISTRICT OF NEW YORK
CASE NO. 15-CV-07433-RWS
VIRGINIA L. GIUFFRE,
Plaintiff,
Vv.
GHISLAINE MAXWELL
Case 1:15-cv-07433-LAP Document 1331-6 Filed 01/05/24 Page 2 of 9
O4V- ad
Condensed Transcript
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVI
Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 14 of 21
psychologist, Judith Lightfoot. Ms. Lightfoot’s own records, written in 2011, describe
Defendant as Ms. Giuffre’s abuser:
. .. was
Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 15 of 21
Q. Was it while you were still together?
A. Yes.
Figueroa Dep. Tr. at 96:1-19.
When Defendant argues that the journal or the dream
Case 1:15-cv-07433-LAP Document 1331-5 Filed 01/05/24 Page 1 of 3
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine
Case 1:15-cv-07433-LAP Document 1331-5 Filed 01/05/24 Page 2 of 3
7. Attached hereto as Sealed Exhibit 5 is a true and correct copy of Excerpts from
October 2009, Deposition of Louella Rabuyo.
8. At
Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 5 of 9
testify what she did after receiving Epstein’s “ok.” The fact that Defendant was seeking Epstein’s
permission with respect to her me
Case 1:15-cv-07433-LAP Document 1331-2 Filed 01/05/24 Page 2 of 4
ED STATES DISTRICT COURT
HERN DISTRICT OF NEW YORK
CASE NO. 15-CV-07433-RWS
VIRGINIA L. GIUFFRE,
Plaintiff,
Vv.
GHISLAINE MAXW
D
Case 1:15-cv-07433-LAP Document 1331-1 Filed 01/05/24 Page 1 of 3
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff,
Case No.: 15-cv-07433-RWS
Vv.
Ghislaine
Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 4 of 15
Page 273
G Maxwell - Confidential
statement that was issued by Ross Gow that
should be a single page still in your stack
of exhibit
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 14 of 17
made no attempt to provide any proof or even proffer of relevance beyond mere speculation.
Thus, an adverse inference is impermiss
Case 1:15-cv-07433-LAP Document 1330-18 Filed 01/05/24 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ae xX
VIRGINIA L. GIUFFRE,
Plaintiff, :
Vv. : 15-cv-07433-RWS
GHISLAINE
Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 6 of 12
Q. This is an email from you on January 10, 2015 to Philip Barden and Ross
Gow. The statement you had before you earlier, that, if
Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 8 of 12
giving drafts to Epstein for his approval. Accordingly, Defendant was never
deposed on (1) why she was seeking Epstein’s permissio
Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 5 of 12
of British law. This is evidenced by the deposition testimony cited by Plaintiff (McCawley
Decl., Ex. 2), as well as multiple addit
Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 2 of 12
Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Response to Plaintiff's Motion
to Reopen Defendant’s Deposition, and states
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 16 of 43
MR, GOLDBERGER: Just so we're clear, the Fifth Amendment objection as to
actof production is going to apply to everything that --
Case 1:15-cv-07433-LAP Document 1330-14 Filed 01/05/24 Page 6 of 7
Page 60
1 THE WITNESS: I don't know.
2 BY MR. EDWARDS:
3 Q. We'll go back to that but I tell you why I
4 ask. If you don't know t
Case 1:15-cv-07433-LAP Document 1330-14 Filed 01/05/24 Page 4 of 7
Page 57
1 A. No.
2 Q. That's not something that you were, you
3 were privy to? You weren't, you weren't in the loop
4 of the sharing
Case 1:15-cv-07433-LAP Document 1330-14 Filed 01/05/24 Page 5 of 7
Page 58
1 Q. You have used the term organization, you
2 can share within the organization. What do you --
3 just so I can understand
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(561)
832-7500
Q. Is your computer in your office
A. Yes.
Q. Let me finish.
office linked up with the three computers
removed from the house?
the system and see what is
Case 1:15-cv-07433-LAP Document 1330-13 Filed 01/05/24 Page 3 of5
Page 223
JOHN ALESSI
You never received emails from either of
A. No, sir.
Q. So when there would be a message from one
of them whi