Giuffre_Maxwell_Batch3_p00061.png

Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 1 of 17 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. / PLAINTIFF’S MOTION TO ENFORCE THE COURT’S ORDER AND DIRECT DEFENDANT TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL’ Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Motion to Compel Defendant to Answer Deposition Questions. On June 20, 2016, this Court Ordered Defendant to sit for a second deposition because her refusal to answer questions posed in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet, during her second deposition, Defendant again refused to answer numerous questions regarding sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the Court should direct her to fully answer the relevant questions. FACTUAL BACKGROUND As the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the guise of being “‘massage therapists.” See Complaint, DE1, at §] 27 (Giuffre “described Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for sexual activities ' Defendant has labelled her entire deposition transcript as Confidential at this time. 1