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Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 10 of 28
Whether Defendant knew what Ms. Giuffre was required to wear while providing
massages to Epstein. Id. at 68-69.
Whether Defendant could recall having a laundry basket of sex toys in Epstein’s Palm
Beach mansion, as described by Juan Alessi. Jd. at 70-75.
Whether Defendant could recall paying Ms. Giuffre. Jd. at 75.
Whether Defendant was ever present to view Ms. Giuffre massaging Epstein. Jd. at 75.
Whether Defendant could recall telling Ms. Giuffre that she needed a cell phone so that
she could be on call regularly. /d. at 77.
Whether Defendant was required to be on call to come to Epstein’s mansion when he
wanted her to come. Jd. at 79.
Whether Defendant could recall Ms. Giuffre being at Epstein’s New York mansion when
Prince Andrew came to visit. Id. at 80-81.
Whether Defendant could recall Ms. Giuffre staying at any of Epstein’s six homes. Id. at
81.
Whether Defendant was aware that there were over 30 individuals who were minors who
gave reports to the Palm Beach Police Department who said they were sexually assaulted
by Epstein during the years that Defendant was working with him. /d. at 89-91.
Whether Defendant introduced Ms. Giuffre to Prince Andrew in London. Jd. at 108.
Whether Ms. Giuffre ever stayed at Defendant’s home in London. Jd. at 108.
Whether Defendant remembered taking a trip with Ms. Giuffre to travel over to Europe,
including London. /d. at 108.
Whether Defendant could recall Prince Andrew being present in New York for a party
where Johanna Sjoberg was also present. Jd. at 112-13.
Whether a picture depicting Prince Andrew, Ms. Giuffre and Defendant was taken at
Defendant’s London town home. /d. at 113-14.
Whether Defendant ever flew on one of Epstein’s planes with a 17 year old. Jd. at 121-
22.
Whether the notation “GM” on flight logs for passengers on Epstein’s planes represented
the Defendant (i.e., Ghislaine Maxwell). Jd. at 122-23.
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Document Details
| Filename | Giuffre_Maxwell_Batch1_p00143.png |
| File Size | 325.4 KB |
| OCR Confidence | 93.6% |
| Has Readable Text | Yes |
| Text Length | 1,970 characters |
| Indexed | 2026-02-04 12:32:27.352763 |