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Case 1:15-cv-07433-LAP Document 1325-7 Filed 01/04/24 Page 27 of 30 escort young girls he brought over to Epstein’s home to Epstein for sex acts, and testified that Defendant called him on the phone, asking him to bring girls over to Epstein’s house.'* Q And how long would you and one of these other girls sit there and have this small talk with Ms. Maxwell? A No more than 10 or 15 minutes. Q What were you waiting for? A Pretty much her to take them up stairs then I would leave. I would wait for them to be like we're ready. And I would be all right. See you later and I would leave. Q You were waiting for who to take who up stairs? A Thad seen Ms. Maxwell take a girl up there well not up there visibly but I watched her leave had room with one. Q Up stairs? 12 A Well, I didn't see the stairs. Like in the kitchen there's not like you have to go all around and all that shit. See McCawley Decl. at Exhibit 9, ROUGH Figueroa Tr. at 156:22-157:14. Q Let me fix this. Gill when Gillian Maxwell would call you during the time that you were living with Virginia she would ask you what specifically? A Just if I had found any ear girls just to bring the Jeffrey. Q Okay. A Pretty much everytime a conversation with any of them it was either asking Virginia where she was ask the asking her to get girls or asking me get girls. See McCawley Decl. at Exhibit 9, ROUGH Figueroa Tr. at 162:8-19. Accordingly, at this stage in discovery, it is not just the flight logs showing Defendant flying with Epstein and Ms. Giuffre over twenty times when she was a minor; it is not just the message pads from law enforcement’s trash pulls that show Defendant arranging to have an underage girl come over to Epstein’s house for “training;” it is not just the police report; it is not just the photographs of Defendant and other men with Ms. Giuffre when she was a minor. Now, there is actual, live testimonial evidence that Defendant was a procurer of young girls for sex with Jeffrey Epstein, with whom she shared a home and a life, thus validating Ms. Giuffre’s claims. Therefore, this baseless motion for sanctions is more a reflection of the 'S See McCawley Decl. at Exhibit 9, Excerpts from the June 24, 2016 ROUGH Deposition Transcript for the Deposition of Tony Figueroa. 23