Case Document Filed Page of 0B 0B 0B 0B 0B 0B 0B 0B 0B 0B 0B 0B 0B 0B 0B 0B 0B Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of 0F 0B Case Document Filed Page of Case Document Filed Page of 0B Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of During her deposition however Defendant did not take the Fifth Instead she testified that she suffered from a series of memory lapses and could not recall many of the key issues in dispute in this case As a result of Defendants inability to remember events a va1iety of issues are now in dispute For example at her deposition Defendant indicated that she lacked recollection of or was otherwise unable to specifically answer the following questions Whether Defendant observed a female under the age of at Jeffrey Epsteins home in Palm Beach See Mccawley Deel at Exhibit Maxwell Depo at Whether Defendant had meet Ms Giuffre and introduced her to Epstein Id at Whether Defendant in could recall having met Ms Giuffre at the Mar-a-Lago in Palm Beach and then writing that fact in an email Id at Whether when Defendant first met Whether Defendant knew the nature of the relationship between Epstein and Whether Defendant recruited girls 1mder the age of to come to Epsteins mansions Whether massage therapists at Epsteins mansions perfo1med sexual acts Id at Whether Defendant knew the age of when she met Epstein Whether Defendant advised if she massaged Epstein Whether Defendant introduced Whether Defendant could recall that she could obtain extra money brought masseuses to Epstein mansion Case Document Filed Page of Whether Defendant knew what Ms Giuffre was required to wear while providing massages to Epstein Id at Whether Defendant could recall P.aying Ms Giuffre Id at Whether Defendant was ever present to view Ms Giuffre massaging Epstein Id at Whether Defendant could recall telling Ms Giuffre that she needed a cell phone so that she could be on call regularly Id at Whether Defendant was required to be on call to come to Epsteins mansion when he wanted her to come Id at Whether Defendant could recall Ms Giuffre being at Epsteins New York mansion when Whether Defendant could recall Ms Giuffre staying at any of Epstein six homes Id at Whether Defendant was aware that there were over individuals who were minors who gave reports to the Palm Beach Police Department who said they were sexually assaulted by Epstein during the years that Defendant was working with him Id at Whether Defendant introduced Ms Giuffre to Whether Ms Giuffre ever stayed at Defendant home in London Id at Whether Defendant remembered taking a trip with Ms Giuffre to travel over to Europe including London Id at Whether a picture depicting_ Ms Giuffre and Defendant was taken at Defendants London town Whether Defendant ever flew on one of Epsteins planes with a year old Id at Whether the notation GM on flight logs for passengers on Epsteins planes represented the Defendant i.e Ghislaine Maxwell Id at Case Document Filed Page of Whether Defendant knew that the flight logs produced by pilots were accurate Id at one of Epsteins Whether Defendant could recall ever being on a flight on one of Epsteins planes with Ms Giuffre Id at Whether Defendant could recall Epstein and being friendly towards each other Whether Defendant could rec.all the purpose of a u-ip to Thailand with Epstein and Whether Defendant could recall Ms Giuffre talcing pictures on trips Id at Whether Defendant could recollect writing down messages on memo pads from various individuals at Epsteins Palm Beach mansion Id at Whether Defendant could recall receiving a message on a memo pad concerning Whether Defendant could explain why a minor would be calling Epstein to say they had a female for him Id at Whether Defendant could recall a sixteen-year-old Russian girl who came to Epstein mansion Id at Whether Defendant believed that Epstein sexually abused minors Id at Whether Defendant was present at Epsteins Florida mansion when police executed a search wanant Id at Whether Defendant took a picture at one of Epstein prope1iies of a person in either a naked or semi-naked state Id at Whether Defendant could recall what Epstein told her about the criminal investigation of him Id at Whether Epstein told Defendant that he never had sex with Ms Giuffre Id at Whether it was an obvious lie that Epstein engaged in sexual conduct with Ms Giuffre while she was under the age of Id at Whether Defendant knew whether Epstein had sex with a minor Id at Case Document Filed Page of Whether it was a lie for Ms Giuffre to say that Defendant approached fema es to bring them to Epstein Id at Whether Defendant kuew Epstein had a sexual preference for minors Id at Whether Defendant kuew that purposes of sexual massage asked girls to come over to see Epstein for Whether Defendant could recall seeing and Epstein together Whether Defendant was aware of any interstate or international transportation of women aged to for purposes of having sex with Epstein where they wou receive compensation Id at Whether Defendant could remember entering any te ephone numbers into a contact book maintained by Epstein Id at Whether a document with Epstein contacts including massage contacts was located on Defendants computer Id at Whether Defendant could recall any representative of hers infonni the press that Ms Giuffre committed grand theft Id at Whether Defendant could rec.all interacting with anyone other than Ms Giuffre under the age of on any of Epsteins properties Id at Whether Defendant had discussed with allegations against him any of the details of Ms Giuffres Because Defendant refused to answer those questions Ms Giuffre needs to depose other witnesses who have the requisite kuow edge to testify concerning those issues Case Document Filed Page of I I I I Case Document Filed Page of I I I Case Document Filed Page of I Future Depositions Sought by Ms Giuffre Ms Giuffre has also scheduled the following depositions Juan Alessi hours Mr Alessi deposition is scheduled for May in Florida Mr Alessi was one of the employees in Epstein mansion Mr Alessi provided witness statements to polic dming the criminal investigation in Palm Beach and was previously deposed in civil cases previously brought against Mr Epstein Specifically Juan Alessi info1med the Palm Beach Police Detective as follows Alessi stated that towards the end of his employment the masseuses were younger and younger When asked how young Mr Alessi stated they appeared to be sixteen or seventeen yearn of age at most emphasis added See Mccawley Deel at Composite Exhibit Palm Beach Police Incident Repo1i at On November the Palm Beach Police Depmiment took a sworn statement from house employee Juan Alessi in which he revealed that girls would come over to give massages and he observed Ms Maxwell going upstairs in the direction of the bedroom quaiiers See McCawley Deel at Exhibit November Sworn Statement at He also testified that after the massages he would clean up sex toys that were kept in Ms Maxwells closet Id at He added that he and his wife were concerned with what was going on at the house Id at and that he observed girls at the house including one named Virginia Id at It is anticipated that he will test i fy consistently with that previous testimony As explained above as of today Defendant counsel sent an email refusing to attend this deposition set for Tuesday May Monday is Memorial Day See Mccawley Deel at Exhibit 0F 0B 0B Case Document Filed Page of 0B Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of 0F Case Document Filed Page of 0F 0E Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of aware that at eve1y turn Defendant appears ready to brand Ms Giuffre as a liar who cannot be believed Thus obtaining witnesses like who can con-oborate that she is telling the tmth is more important in this case than it would be in many others It is equally important that Ms Giuffre be able to depose the witnesses who can refute Defendants testimony The Court can also readily detennine that Ms Giuffre has not had any prior opportunity to obtain discove1y of the witnesses she seeks to depose The case is only now in the fact discove1y phase and she has had no opp01tunity to previously depose these third paiiy witnesses Finally there is no substantial burden involved with deposing seven additional witnesses Any assessment of burden must take into account the scope of the underlying case Ms Giuffre is seeking both compensato1y and punitive damages that would total Inillions of dollars Against that backdrop a handful of additional depositions cannot be seen as unduly burdensome Moreover this is not a situation where Defendant lacks means to pay for counsel to attend the depositions Defendants vast wealth does not appear to be in doubt During the meet-and confer on this issue the Defendants substantive reason for not stipulating to these additional depositions is that with regai to three of the witnesses Epstein Kellan and Marcinkova it appeai likely that they will invoke their Fifth Amendment right to refuse to answer some questions about Defendants involvement in in the sexual abuse of Ms Giuffre But until those witnesses actually take the Fifth the conclusion that they will ach1ally Defendant has thus far refused produce documents regarding the extent of her assets arguing that until the punitive damages phase of this proceeding is reached the discove1y is not relevant Nonetheless public inf01mation suggests significant assets and the possibility that she is transfeITing assets outside the reach of the Court urisdiction See e.g Alleged Ep tein Madam Sells Manhattan Townhouse New York Post Apr available at http nypost.com/2016 alleged epstein madam-sells manhattan townhouse Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of Case Document Filed Page 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