HOLY FUCK ITS TRUE - PDF 143
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United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________/
PLAINTIFF’S REDACTED MOTION TO COMPEL DEFENDANT
TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL1
Plaintiff 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 females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the guise of being “massage therapists.” See Complaint, (DE 1), 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.
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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.” See Declaration 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 about subjects integral to this lawsuit, including questions about what the alleged “massage therapists” were doing at Jeffrey Epstein’s house and the sexual nature of those massages. For example, Defendant refused to answer questions about whether she had given Jeffrey Epstein a massage: Q. Have you ever given Jeffrey Epstein a massage? MR. PAGLIUCA: Object to the form, foundation. And I'm going to instruct you not to answer that question. I don't have any problem with you asking questions about what the subject matter of this lawsuit is, which would be, as you've termed it, sexual trafficking of Ms. Roberts. To the extent you are asking for information relating to any consensual adult interaction between my client and Mr. Epstein, I'm going to instruct her not to answer because it's not part of this litigation and it is her private confidential information, not subject to this deposition. MS. McCAWLEY: You can instruct her not to answer. That is your right. But I will bring her back for another deposition because it is part of the subject matter of this litigation so she should be answering these questions. This is civil litigation, deposition and she should be responsible for answering these questions. MR. PAGLIUCA: I disagree and you understand the bounds that I put on it. MS. McCAWLEY: No, I don't. I will continue to ask my questions and you can continue to make your objections. Q. Did you ever participate from the time period of 1992 to 2009, did you ever participate in a massage with Jeffrey Epstein and another female? MR. PAGLIUCA: Objection. Do not answer that question. Again, to the extent you are asking for some sort of illegal activity as you've construed in
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