Giuffre_Maxwell_Batch4_p00169.png
Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 8 of 12
See McCawley Decl. at Exhibit 2, June 20, 2016 Sealed Order at p. 10 (Emphasis added).
As articulated in the moving brief, Defendant refused to answer four categories of
questions that were directly within the ambit of this Court’s Order.
First, Defendant refused to answer many questions about Johanna Sjoberg, who was
recruited by Defendant, and subsequently abused by and had sex with Jeffrey Epstein. Questions
relating to her involvement with Epstein and Defendant are directly within the ambit of the
Court’s Order. The Court should direct the Defendant to answer questions relating to Johanna
Sjoberg because they are “questions relating to [Defendant’s] knowledge of sexual activities of
others with or involving Epstein.”
Second, Defendant refused to answers concerning Maria and Annie Farmer. Defendant
was involved in Epstein’s sexual abuse, and grooming for sexual abuse, of Maria Farmer and
Annie Farmer, respectively. Notably, Annie Farmer was only 16 years old at the time: a familiar
yet still disturbing theme running through Defendant and Epstein’s lifestyle. Therefore, questions
relating to Defendant’s involvement with, knowledge of, and observations of both Annie and
Maria Farmer are within the ambit of this Court’s Order because they are “questions relating to
[Defendant’s] knowledge of sexual activities of others with or involving Epstein.”
Third, Defendant refused to answer questions regarding girls brought to “massage”
Epstein by Tony Figueroa. Questions regarding the girls who Defendant asked Mr. Figueroa to
bring to the house to “massage” Epstein are also directly within the ambit of this Court’s Order.
Fourth, and related to the third topic, questions about Maxwell’s knowledge of, and
interactions with, any of the girls who came over to “massage” Epstein are all within the ambit of
the Court’s Order. Questions concerning Defendant’s knowledge of and involvement with these
girls are (1) “questions relating to [Defendant’s] knowledge of sexual activities of others with or
Extracted Information
Dates
Document Details
| Filename | Giuffre_Maxwell_Batch4_p00169.png |
| File Size | 303.6 KB |
| OCR Confidence | 95.5% |
| Has Readable Text | Yes |
| Text Length | 2,089 characters |
| Indexed | 2026-02-04 12:41:13.164387 |