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Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 13 of 43 . Whether Defendant had meet Ms. Giuffre and introduced her to Epstein. Jd. at 33; . Whether massage therapists at Epstein’s mansions performed sexual acts. Jd. at 52-54. . Whether Defendant was ever present to view Ms. Giuffre massaging Epstein. Jd. at 75; . Whether Defendant could recall Ms. Giuffre staying at any of Epstein’s six homes, Jd, at 81. . Whether Defendant remembered taking a trip with Ms. Giuffre to travel over to Europe, including London. Jd. at 108. . Whether Defendant ever flew on one of Epstein’s planes with a 17 year old. /d. at 121-22, . Whether the notation “GM” on flight logs for passengers on Epstein’s planes represented the Defendant (i.e,, Ghislaine Maxwell). Jd, at 122-23. ° Whether Defendant could recall ever being on a flight on one of Epstein’s planes with Ms. Giuffre. /d. at 132-33. . Whether Defendant could explain why a minor would be calling Epstein to say they had a female for him. Jd. at 164. . Whether Defendant was aware of any interstate or international transportation of women, aged 18 to 28, for purposes of having sex with Epstein where they would receive compensation. /d. at 278-79. . Whether Defendant could recall interacting with anyone, other than Ms. Giuffre, under the age of 18 on any of Epstein’s properties. /d. at 384. See McCawley Decl. at Exhibit 2. 3, As this Court is aware from another pending case, Epstein is a registered sex offender who entered into a non-prosecution agreement (NPA), barring his prosecution for federal crime for his sexual abuse of Ms. Giuffre and multiple other victims. Several of Epstein’s sexual abuse victims have filed a suit alleging that they were not properly notified of lie