Giuffre_Maxwell_Batch3_p00331.png

Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 25 of 27 A: No. Id. at 106-07. e He did not have any discussions with these females (who were adult) about what was entailed with the job other than massages. Jd. at 104-105. e Later in his testimony, upon leading questions from Mr. Edwards, Mr. Figueroa committed a complete about-face: Q: Would Ghislaine Maxwell call you? A: I think she might have actually called me once or twice. I’m not positive, but I’m pretty sure she did.... Q: ...What did you say? What did she say? A: She would just ask me if I had anybody lined up, so.....for Jeffrey. e Mr. Figueroa testified that he was arrested for grand theft the same night that he dropped Plaintiff off to go to Thailand, he served time, and only recently had his rights restored. Id. at 67-69. Rinaldo Rizzo. Mr. Rizzo was a butler for Mr. Glenn and Dr. Eva Dubin at their home in upstate New York. In addition to his history of litigation against the Dubins and his admitted hope to receive compensation from his testimony, his deposition is so palpably incredible as to be potentially sanctionab|e, i —S——CCSC‘=‘( SSCs NS Paclivcs Decl. Ex. Jat 11. In any event, none of Mr. Rizzo’s testimony related to Ms. Maxwell’s participation in massages, sex with underage minors, or sex with adults, and thus is further irrelevant to the issues presented by the Motion. CONCLUSION Because Ms. Maxwell fully answered all questions within the Court’s Order (and many that were not) at her continued deposition, she respectfully requests the Court deny Plaintiffs 23