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Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 5 of 10 sexual activities, including orchestrating the hiring of females and converting massages into sexual encounters. Defendant attempts to paint the picture that Ms. Giuffre somehow is interested in all sexual relationships that the Defendant may have been involved with. That is not true. Ms. Giuffre has no intention of asking unbridled questions. To be clear, Ms. Giuffre intends to ask Defendant only questions that involve the following very narrow and crucial subject areas: (1) Defendant’s sexual relationship with Epstein from 1992 to 2009 — the time period in which she worked for Jeffrey Epstein and which Epstein (with the assistance of Defendant) was engaging in sexual acts with females under the cover of “massage”; (2) Defendant’s sexual interactions with any person in Epstein’s presence during that time period; (3) Defendant’s sexual activities at Epstein’s residences, including his private island “Little St. Jeff's,” or his aircraft during that time period; (4) Defendant’s sexual activities with identified participants in Epstein’s sexual abuse during that time period; and (5) Defendant’s sexual interactions that occurred during or through what began as a “massage”; and (6) Defendant’s interactions with females to introduce to Jeffrey Epstein for the purpose of performing work, including sexual massages. Defendant claims that such questions are a mere “fishing expedition” without acknowledging the fact that these questions go to critical issues in this case. Other witnesses have testified regarding Defendant’s involvement in recruiting females for sex under the cover of a “massage.” During the investigation of Jeffrey Epstein, certain household staff was deposed. Alfredo Rodriguez, who was Jeffrey Epstein’s household manager, testified that the Defendant frequently stayed in Jeffrey Epstein’s home and assisted with bringing in young girls to act as “masseuses” for Jeffrey Epstein. Q. “Okay. Going back to where we started here was, does Ghislaine Maxwell have knowledge of the girls that would come over to Jeffrey Epstein’s house that are in