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1 United States District Court Southern District of New York Virginia L. Giuffre,Plaintiff, Case No.: 15-cv-07433-RWSv. Ghislaine Maxwell,Defendant. ________/PLAINTIFF’S REDACTED MOTION TO COMPEL DEFENDANTTO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL1Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition, Defendant refused to answer numerous questions about allegedly “adult” sexual activity related to Jeffrey Epstein. Because this activity is highly relevant to this case, Defendant should be ordered to answer questions about it.As the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and other femaleswere 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 and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”). In response to these assertions, Defendant has made the sweeping claim that Ms. Giuffre’s assertions are “entirely false” and “entirely untrue.” Complaint, DE 1, at ¶ 31.1 Defendant has labelled her entire deposition transcript as Confidential at this time. Counsel for the parties conferred at the deposition regarding answering questions. Case 1:15-cv-07433-LAP Document 143 Filed 05/05/16 Page 1 of 10

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Document 143 extracted text page 2

Yet during her deposition, Defendant refused to answer any questions that she construed as having something to do with “consensual adult sex.” Defense counsel supported that position that “frankly, [that’s] none of your business and I instruct the witness not to answer.” SeeDeclaration of Sigrid S. McCawley (“McCawley Decl.”)at Exhibit 1, Tr. of Maxwell Depo. (Apr. 22, 2016) at 21. The result was that at a number of points throughout her deposition, Defendant refused to answer questions aboutsubjects integral to this lawsuit, including questions about whatthe alleged “massage therapists” were doing at Jeffrey Epstein’s house and the sexual nature of those massages. For example, Defendantrefused to answer questions about whether she had given Jeffrey Epstein a massage:Q. Have you ever given Jeffrey Epsteina massage?MR. PAGLIUCA: Object to the form,foundation. And I'm going to instructyou not to answer that question. Idon't have any problem with you askingquestions about what the subject matterof this lawsuit is, which would be, asyou've termed it, sexual trafficking ofMs. Roberts.To the extent you are asking forinformation relating to any consensualadult interaction between my client andMr. Epstein, I'm going to instruct hernot to answer because it's not part ofthis litigation and it is her privateconfidential information, not subject tothis deposition.MS. McCAWLEY: You can instruct hernot to answer. That is your right. ButI will bring her back for anotherdeposition because it is part of thesubject matter of this litigation so sheshould be answering these questions.This is civil litigation, deposition andshe should be responsible for answeringthese questions.MR. PAGLIUCA: I disagree and youunderstand the bounds that I put on it.MS. McCAWLEY: No, I don't. I willcontinue to ask my questions and you cancontinue to make your objections.Q. Did you ever participate from thetime period of 1992 to 2009, did you everparticipate in a massage with Jeffrey Epsteinand another female?MR. PAGLIUCA: Objection. Do notanswer that question. Again, to theextent you are asking for some sort ofillegal activity as you've construed inCase 1:15-cv-07433-LAP Document 143 Filed 05/05/16 Page 2 of 10

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ok will hit the rest the documents that maxwell did not want released. Their redaction method sucks