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Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 15 of 28 that I was not one of those girls. He was always trying to recruit me almost in a way that I could be one of them and travel with him and live the life of luxury if I only — if I only did this. So after five years of learning what was happening, I can look back knowing — I only knew Virginia a short time. Looking back, I can make assumptions about what was required of her.” (p. 123-124) e She said she recalls that Defendant went to dinner with Governor Bill Richardson one time when Johanna was visiting the ranch in New Mexico (p. 110). B. Future Depositions Sought by Ms. Giuffre Ms. Giuffre has also scheduled the following depositions. 3. Juan Alessi (3% hours). Mr. Alessi’s deposition is scheduled for May 31, 2016, in Florida’. Mr. Alessi was one of the employees in Epstein’s mansion. Mr. Alessi provided witness statements to police during the criminal investigation in Palm Beach, and was previously deposed in civil cases previously brought against Mr. Epstein. Specifically, Juan Alessi informed the Palm Beach Police Detective as follows: “Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at most.” (emphasis added.) See McCawley Decl. at Composite Exhibit 7, Palm Beach Police Incident Report at p. 57. On November 21, 2005, the Palm Beach Police Department took a sworn statement from house employee Juan Alessi in which he revealed that girls would come over to give “massages” and he observed Ms. Maxwell going upstairs in the direction of the bedroom quarters. See McCawley Decl. at Exhibit 8, November 21, 2005 Sworn Statement at 10. He also testified that after the massages, he would clean up sex toys that were kept in “Ms. Maxwell’s closet.” Jd. at 12-13. He added that he and his wife were concerned with what was going on at the house (/d. at 14) and that he observed girls at the house, including one named “Virginia.” Jd. at 21. It is anticipated that he will testify consistently with that previous testimony. > As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set for Tuesday, May 31, 2016 (Monday is Memorial Day). See McCawley Decl. at Exhibit 2. 11