Link to the file for all the citations provided: gofile.io/?c=GqjNcB – Combined pdf
– more women then just Maxwell who got girls for Epstein is claimed.
– Maxwell ‘primary co-conspirator’.
– Maxwell and Epstein converted Giuffre into a sex slave
– Maxwell appreciated immunity from earlier case.
– Maxwell took photos
– Giuffre was trafficked to “powerful individuals” including internationally by Maxwell and Epstein.
– Forced to have sex with prince Andrew in Maxwell’s apartment. Maxwell acted as a ‘madam’ for Epstein.
– Giuffre was forced to watch other underaged girls have sex with Epstein, Maxwell and others.
Page 12 – 14
– Numerous witness corroborate the statements Giuffre made in her joinder motion
– Witness listed including flight logs, police reports, sex slave books order by Epstein, evidence sent by Maxwell, a black book Epstein had, psychological records, a message pad, hospital records, and named witnesses and depositions.
– Claimed to be forced to have sex with Alan Dershowitz, Jean Luc Brunel, and more including, prominent American politicians, Powerful business executives, Foreign President, well-know prime minister, other world leaders.
– After 4 years as a sex slave Giuffre escaped to foreign country and hid for years.
– However, it appears she was with him for two years between 2000-2002 after new evidence emerged.
– Giuffre suggested the government was part of the conspiracy when it secretly negotiated a NPA with Epstein and his co-conspirators. Alleges they did it because it would shin light on powerful individuals.
– Denies she has suggested this and mentions the CVRA Action relates to whether they failed in their responsibilities.
– Other jane doe cannot corroborate Giuffre but both appear to claim to not know each other and the patterns of abuse are similar in many regards.
– Giuffre has written a book on the events but not published it.
– Giuffre Flew with Epstein at least 32 times between Dec 11 2000 to July 28 2001, and June 21 2002 to august 21 2002.
– She worked at the Club at Mar-a-lago sometime in fall 2000 including many other places that year.
– At Mar-a-lago she worked as a “seasonal” spa attendant after turning 17.
– Giuffre disputes this claiming actual dates not listed by mar-a-lago and some records seem to indicate she worked there during the summer.
– Giuffre represented herself as a masseuse for Epstein, they met at mar-a-lago. She told her father she got a job for Epstein as a masseuse.
– Her father took her to Epstein’s house at least once, Epstein introduced himself.
– However, Giuffre denies this pointing out that working as a masseur would have been illegal for her to do as a minor with no high school diploma. She claims Maxwell approached her while she was spa attendant. Her father did drive her and Maxwell took her and then taught her how to give massages.
– Epstein and Maxwell turned that into a sexual encounter and offered money and better life in return for sexual demands.
– She served people for sex not as a masseur.
– Alessi states, Epstein’s house manager, would drive Maxwell to places prepared ahead to time to recruit girls.
– Another girl Sjoberg was also recruited.
– While one if Epstein’s regular pilots kept logs, Dave Rodgers, Epstein’s had another pilot who did not keep such logs and also traveled by commercial occasionally.
– Giuffre flew at least 32 times but claims more
– Maxwell admits the flights logs are incomplete and had multiple pilots with multiple aircraft and only Rodgers kept logs.
– Giuffre claims she received $10,000 after being forced to have sex with prince Andrew in London at Maxwell’s home and bought a car with the money.
– Giuffre traveled to Thailand in September 2002 to received formal training in masseuse.
– Giuffre claim she was also sent to Thailand to recruit another underaged girl.
– At this point rather then returning she escaped to Australia with her new husband and hid.
– Another co-conspirator named Kellen scheduled the appointments with underaged girls.
– After Giuffre escaped her ex boyfriend says he was recruited by Maxwell to procure underaged girls.
– Nothing to important it appears
Exhibit OO Page 82
– Sharon Churcher seems to admit Giuffre had no evidence or proof Alan Dershowitz was a pedo but seems to be asking if they ever hung out.
– Confidential Video deposition of Virginia Giuffre
– Defendant Ghislaine Maxwell
Pages from deposition missing
Page 97 (439)
– Giuffre claims that in Churcher’s article the statement “Donald Trump is a good friend of Jeffrey’s. He didn’t partake in any sex with any of us, but he flirted with me. He’d laugh and tell Jeffrey, ‘you’ve for the life‘” is incorrect.
Page 101 (442)
– Giuffre clarifies what is and isn’t true in the statement. Donald Trump was a friend of Epstein but did not have sex with any of the girls or flirt with Giuffre. He also never told Trump “you got the life”
Page 102 (443)
– Guiffre Clarifies she never say Donald have sex with any of the ‘girls’ in her presence but had met him a few times.
– Donald Trump was never in her presence with her with any of the ‘other girls’.
– Her Dad seems to have known Donald trump and talked when they say each other and was there at least once when they met.
Page 103 (444)
– Giuffre had never been in Donald Trump presence while at the same time being in the presence of Epstein.
– Jeffrey was the one who told Giuffre they were good friends, but she never observed them together.
– She never saw him at Epstein’s island, New Mexico, or New York that she can remember.
Page 105 (447)
– Giuffre worked for Epstein for about 2-1/2 years.
– Admits she would do whatever the pedo’s wanted for her.
Page 108 (450)
– Admits to meeting Al Gore
– Admit to meeting Heidi Klum
– Admits to meeting Naomi Campbell
– FBI told her Epstein is filming her even when she is in the washroom.
– FBI told her it was all illegal because she was underaged.
Page 109 (451)
– The was told to her after the article was printed by Sharon.
– Epstein invited two young brunettes to a dinner which he gave on his carribian island for mr Clinton shortly after he left office (says is true).
– Al-Gore and his wife Tipper were also guests of Epstein on his island.
– Senator George Mitchell Frequently visited Epstein’s NY residence, very close friend of Epstein.
– Ghislaine took nude phots of her lying naked in a hammock, legs open, that they gave Jeffrey for his birthday.
– Epstein would send her to locations to sleep with people at either the island or New Mexico.
– The encounter with prince Andrew was in the bathroom and he was licking her toes.
Exhibit RR – Video Deposition of Virginia Giuffre Page 122
– attempts to attack credibility of witness (my opinion) but witness says her self- written manuscript is 99.9% correct about details related to Maxwell.
– Defendant’s Reply to Plaintiff’s Statement of Contested Facts and Plaintiff’s “Undisputed Facts”
– Plaintiff’s father, Sky Roberts, was hired as a maintenance worker at the The Mar-aLago Club in Palm Beach, Florida, beginning on April 11, 2000. Ex.S. Mr. Roberts worked there year-round for approximately 3 years. Id.; Ex.T at 72-73. After working there for a period Case 18-2868, Document 284, 08/09/2019, 2628244, Page23 of 38 23 of time, Mr. Roberts became acquainted with the head of the spa area and recommended plaintiff for a job there. Id. at 72. Mar-a-Lago closes every Mother’s Day and reopens on November 1. Ex.U at Mar-a-Lago0212. Most of employees Mar-a-Lago, including all employees of the spa area such as “spa attendants,” are “seasonal” and work only when the club is open, i.e., between November 1 and Mother’s Day. Ex.T at 72-73; Ex.U at Mar-a-Lago0212; Ex.V. Plaintiff was hired as a “seasonal” spa attendant to work at the Mar-a-Lago Club in the fall of 2000 after she had turned 17.
– DEFENDANT’S PURPORTED FACTS 11. One of the non-parties Ms. Giuffre “named” repeatedly in the joinder motion was Ms. Maxwell. According to the “lurid details” of Ms. Giuffre included in the motion, Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: § Ms. Maxwell “approached” Ms. Giuffre in 1999 when Ms. Giuffre was “fifteen years old” to recruit her into the scheme. § Ms. Maxwell was “one of the main women” Epstein used to “procure under-aged girls for sexual activities.” § Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme. Case 18-2868, Document 281, 08/09/2019, 2628234, Page6 of 66 7 § She “persuaded” Ms. Giuffre to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” § At the mansion, when Ms. Giuffre began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” § Epstein “with the assistance of” Ms. Maxwell “converted [Ms. Giuffre] into . . . a ‘sex slave.’” Id. Ms. Giuffre was a “sex slave” from “about 1999 through 2002.” § Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” § Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” § Ms. Maxwell “participat[ed] in the sexual abuse of [Ms. Giuffre] and others.” § Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [Ms. Giuffre].” Id. She shared the photos with Epstein. § As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffic Ms. Giuffre to these persons. § Ms. Giuffre was “forced to have sexual relations” with Prince Andrew in § “[Ms. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” Ms. Giuffre’s § sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” § Ms. Maxwell “assist[ed] in internationally trafficking” Ms. Giuffre and “numerous other young girls for sexual purposes.” § Ms. Giuffre was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.”
– Picture of Maxwell, prince Andrew drew and Giuffre.
– Ms Giuffre travel records are incomplete, many examples. She was being flown by them without keeping records some of the time
– Detective Recarey knew that Maxwell was involved in the illegal sexual activities at Epstein’s house. He wanted to speak to her, but Maxwell did not return his calls. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 28:23-29:10.
– A walk through video taken during the execution of the search warrant revealed photos of topless females at the home, and there was even a photograph of Maxwell naked hanging in the home. The house staff who were deposed in the civil cases each testified to Maxwell being the boss in charge of everyone in the house. See McCawley Dec. at Exhibits 1, Case 18-2868, Document 281, 08/09/2019, 2628234, Page55 of 66 56 19, 21, Banasiak Dep. Tr. at 8:21-9:16; 14:20-15:6; Alessi Dep. Tr. at 23:11-23:20; Rodriguez Dep. Tr. at 169:1-169:4.
– Rodriguez, the house butler from 2004 through 2005, a time period that revealed daily sexual abuse of underage females, testified that Maxwell kept a list of the local girls who were giving massages at her desk, and that Maxwell kept nude photos of girls on her computer. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. at 238:4-238:22; 302:19-303:10; 306:1- 306:24.
– Recarey testified that when the search warrant was executed, the house had been sanitized and the computers removed from the home. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 72:25-73:15.
– Banaziak testified that the computers were removed by Adriana Ross, another employee who answered to Maxwell. See McCawley Dec. at Exhibit 19, Banaziak Dep. Tr. at 54:7-22.
– Tony Figueroa, Ms. Giuffre’s ex-boyfriend, did testify that Maxwell personally requested that he find and bring girls to Epstein for sex once Ms. Giuffre had escaped, and that when he brought the girls Maxwell interacted with them. See McCawley Dec. at Exhibit 4, Figueroa Dep. Tr. at 200:6-18; 228:23-229:21.
– Rodriguez testified unequivocally that Maxwell was “the boss” and that she knew everything that was going on. See McCawley Dec. at Exhibit 21, Rodriguez Dep. Tr. 169:1-169:4.
– Nude photographs were displayed throughout Epstein’s home. Furthermore, Alfredo Rodriguez testified to Maxwell having pornography on her computer. Rodriguez Dep. Tr. 150:10-17; 306:1-306:24.
– He also testified to there being a collage of nude photos in Epstein’s closet. Id. 253:14-254:18. That collage was eventually taken into evidence by Detective Recarey, who testified to that fact in his deposition. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 73:19-73:24.
– And those photos are still in the possession of the FBI or US Attorney’s Office. See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 74:2-74:7.
– Ronaldo Rizzo, who visited the home on numerous occasions and who was reprimanded by Maxwell herself for looking at the nude photos. See McCawley Dec. at Exhibit 14, Rizzo Dep. Tr. at 25:19-26:20.
– Johanna Sjorberg testified that the Defendant bought her a camera for the specific purpose of her taking nude photos of herself. See McCawley Dec. at Exhibit 16 Sjoberg Tr. at 150.
– Virginia Giuffre testified that there was a nude photograph of her at the house. See McCawley Dec. at Exhibit 5 Virginia Giuffre Tr. at 232 and 333.
– Johanna Sjoberg, testified that Defendant recruited her under the guise of a legitimate assistant position, but asked her to perform sexual massages for Epstein, and punished her when she didn’t cause Epstein to orgasm.
– Tony Figueroa testified that Defendant contacted him to recruit high school-aged girls for Epstein, and also testified that Maxwell and Epstein participated in multiple threesomes with Virginia Giuffre.
– the butler for Defendant’s close friend witnessed, first-hand, a fifteen-year-old Swedish girl crying and shaking because Defendant was attempting to force her to have sex with Epstein and she refused.
– Call this the “yes-I’m-a-sextrafficker-but-only-of-sixteen-year-old-girls” defense.
– Flight logs even reveal twenty-three flights that Defendant shared with Ms. Giuffre – although Defendant claims she is unable to remember even a single one of those flights.
– Defendant’s heavy and extensive involvement in both Jeffrey Epstein’s sex trafficking ring and in recruiting Ms. Giuffre, living with her and Jeffrey Epstein in the same homes while Ms. Giuffre was a minor, and traveling with Ms. Giuffre and Jeffrey Epstein – including 23 documented flights. Even the house staff testified that Defendant and Ms. Giuffre were regularly together.
– The record evidence in this case shows that Defendant shared a household with convicted pedophile Jeffrey Epstein for many years. While there, she actively took part in recruiting underage girls and young women for sex with Epstein, as well as scheduling the girls to come over, and maintaining a list of the girls and their phone numbers.
– Ms. Giuffre was indisputably a minor when Defendant recruited her to have sex with convicted pedophile Jeffrey Epstein. Thereafter, Ms. Giuffre flew on Epstein’s private jets – the – Lolita Express” – with Defendant at least 23 times.
– Ms. Sjoberg’s account of her experiences with Defendant are chillingly similar. As with Ms. Giuffre, Defendant, a perfect stranger, approached Ms. Sjoberg while trolling Ms. Sjoberg’s school grounds. She lured Ms. Sjoberg into her and Epstein’s home under the guise of a legitimate job of answering phones, a pretext that lasted only a day. A young college student, Case 18-2868, Document 280, 08/09/2019, 2628232, Page12 of 74 5 nearly 2,000 miles from home, Defendant soon instructed Ms. Sjoberg to massage Epstein, and made it clear that Sjoberg’s purpose was to bring Epstein to orgasm during these massages so that Defendant did not have to do it.
– Ms. Sjoberg also testified about sexual acts that occurred with her, Prince Andrew, and Ms. Giuffre, when she and Defendant were staying at Epstein’s Manhattan mansion.
– Prince Andrew using a puppet to touch Ms. Giuffre’s breast while using a hand to touch Ms. Sjoberg’s breast.
– Tony Figueroa testified that Plaintiff told him about threesomes Ms. Giuffre had with Defendant and Epstein which included the use of strap-ons.
– Figueroa also testified that Defendant called him to ask if he had found any other girls for Epstein, thereby acting as procurer of girls for Epstein:
– Mr. Rizzo testified – through tears – how, while working at Dubin’s house, he observed Defendant bring a 15 year old Swedish girl to Dubin’s house. In distress, the 15 year old girl tearfully explained to him that Defendant tried to force her to have sex with Epstein through threats and stealing her passport.
– Lyn Miller is Ms. Giuffre’s mother. She testified that when Ms. Giuffre started living with Defendant, Defendant became Ms. Giuffre’s “new momma.” 10 Incredulously, Defendant testified that she barely remembered Ms. Giuffre.
– Detective Recarey led the Palm Beach Police’s investigation of Epstein. He testified that Defendant procured girls for Epstein, and that he sought to question her in relation to his investigation, but could not contact her due to the interference of Epstein’s lawyer.
– Notably, at Defendant’s deposition, Defendant refused to admit that she flew with Ms. Giuffre, and denied that she appeared on Epstein’s pilot’s flight logs.13
– However, David Rodgers, Epstein pilot, testified that the passenger listed on his flight logs bearing the initials – GM – was, in fact, Ghislaine Maxwell, and that he was the pilot on at least 23 flights in which Defendant flew with Plaintiff. 14 The dates of those flights show that Ms. Giuffre was an underage child on many of them when she flew with Defendant.
– Both Sarah Kellen and Nadia Marcinkova lived with Jeffrey Epstein for many years. They both invoked the Fifth Amendment when asked about Defendant’s participation in recruiting underage girls for sex with Epstein.
– Jeffrey Epstein invoked the Fifth Amendment when asked about Defendant’s involvement in procuring underage girls for sex with him.
– Defendant has not been able to procure a single witness – not one – to testify that Defendant did not procure girls for sex with Epstein or participate in the sex.
– Even one of her own witnesses, Tony Figueroa, testified that she both procured girls and participated in the sex.
– Another one of Defendant’s witnesses, Ms. Giuffre’s mother, named Defendant as Ms. Giuffre’s “new mamma.” Indeed, those who knew her well, who spent considerable time with her in Epstein’s shared household, like Juan Alessi, Alfredo Rodriguez and Joanna Sjoberg, have testified that she was Epstein’s procuress.
– Others who lived with her – Jeffrey Epstein, Nadia Marcinkova, and Sarah Kellen – invoked the Fifth Amendment so as not to answer questions on the same. No one has testified to the contrary.
– Defendant has never offered a legal explanation for what she was doing with, and why she was traveling with, a minor child on 21 flights while she was a child, including 6 international flights, aboard a convicted pedophile’s private jet all over the world.
– Defendant never offered an explanation regarding Ms. Giuffre’s photographs of her, Defendant, and Epstein.
– She never offered a legal explanation for why Prince Andrew was photographed with his hand around Ms. Giuffre’s bare waist while she was a minor child, while posing with Defendant, inside Defendant’s house in London.
– This photograph corroborates Ms. Giuffre’s claims, and there is no other reasonable explanation why an American child should be in the company of adults not her kin, in the London house owned by the girlfriend of a now convicted sex offender.
– Ms. Giuffre also produced pictures of herself taken when she was in New York with Defendant and Epstein, and from a trip to Europe with Defendant and Epstein.
– Ms. Giuffre has produced a number of pictures of herself taken at the Zorro Ranch, Epstein’s New Mexico Ranch.
– Among other nude photos, which included full nudes of Defendant, Ms. Giuffre produced images of females that the Palm Beach Police confiscated during the execution of the 22 See McCawley Dec at Exhibit 42, GIUFFRE007175; 007173. Case 18-2868, Document 280, 08/09/2019, 2628232, Page22 of 74 15 warrant, including one photograph revealing the bare bottom of a girl who appears to be prepubescent.
– In 2008, the United States Attorney’s office for the Southern District of Florida identified Ms. Giuffre as a protected “victim” of Jeffrey Epstein’s sex abuse. The U.S. Attorney mailed Ms. Giuffre a notice of her rights as a crime victim under the CVRA.
– Ms. Giuffre has provided extensive medical records in this case, including medical records from the time when Defendant was sexually abusing and trafficking her. Ms. Giuffre produced records supporting her claim of being sexually abused in New York resulting in both 23 See McCawley Dec at Exhibit 44, GIUFFRE007584. 24 See McCawley Dec. at Exhibit 30, GIUFFRE 002216-002218, Victim Notification Letter. Case 18-2868, Document 280, 08/09/2019, 2628232, Page23 of 74 16 Defendant and Epstein taking Plaintiff to New York Presbyterian Hospital in New York while she was a minor. The dates on the hospital records show she was seventeen years old.
– Defendant propounded wildly overbroad requests for production concerning the past eighteen years of Ms. Giuffre’s medical history. Defendant repeatedly and vehemently argued to the Court that it was essential to procure every page of these records in a fanfare of unnecessary motion practice
– Defendant propounded wildly overbroad requests for production concerning the past eighteen years of Ms. Giuffre’s medical history. Defendant repeatedly and vehemently argued to the Court that it was essential to procure every page of these records in a fanfare of unnecessary motion practice.
– Ms. Giuffre sought counseling from a psychologist for the trauma she continued to experience after being abused by Defendant and Epstein. A 2011 psychological treatment record, written by her treating psychologist, unambiguously describes Defendant as Ms. Giuffre’s abuser.
– Years before Defendant defamed her, Ms. Giuffre confided in her treating psychologist that Maxwell recruited her for sex with Epstein.
– Detective Recarey, the lead investigator of the criminal investigation into Epstein and his associates’ sex crimes, recovered carbon copies of hand-written messages taken by various staff, including Defendant, at Epstein’s Palm Beach residence.
– The messages raise a question of fact as to Maxwell’s involvement in the sexual abuse of minors and are relevant to refute Maxwell’s denial of any involvement with Epstein during relevant time periods, and, accordingly her denial of knowledge of certain events.
– Messages reveals that Maxwell, “GM,” took messages at the residence, including from underage girls who were calling to schedule a time to come over to see Epstein.
– One message pad reflects , who is identified in the Palm Beach Police Report as a minor, contacting Jeffrey Epstein for “work” explaining that she does not have any money. The term “work” was often used by members of Jeffrey Epstein’s sexual trafficking ring to refer to sexual massages.
– Giuffre 001462: July 5th no year to JE from ”I need work. I mean I don’t have money. Do you have some work for me?”
– Other message pads reflect who was a minor, calling and leaving a message at the Palm Beach mansion that she has recruited another girl for Jeffrey Epstein. The second message demonstrates that Jeffrey Epstein required different girls to be scheduled every day of the week. The third shows an offer to have two minor girls come to the home at the same time to provide sexual massages. These type of messages indicate the lack of secrecy of the fact that multiple young females were visiting every day and at least raises a question of fact whether Maxwell was knowledgeable and involved as Giuffre has said, or whether Giuffre was lying and Maxwell was not at all involved or aware of this activity, as Defendant would attempt to have the world believe
– Giuffre 001428 – undated Jeffrey From – “Has girl for tonight” ;Giuffre 001432 (pictured above)– 7/9/04 – Mr. Epstein From – “ is available on Tuesday no one for tomorrow”; GIUFFRE 001433 /1/17/04 – Mr. Epstein from – “Me and _____ can come tomorrow any time or alone” ; Giuffre – 001452 – undated Jeffrey from “Has girl for tonight.”
– Other message pads demonstrate that there was a pattern and practice of using young females to recruit additional young females to provide sexual massages on a daily basis.
– Giuffre 001413 (pictured above)– JE from “N” – “ hasn’t confirmed for 11:00 yet, so she is keeping on hold in case doesn’t call back; Giuffre 001448 -8/20/05 JE from – confirmed ___ at 4 pm. Who is scheduled for morning? I believe wants to work.”
– This message pad reflects that a friend of Jeffrey Epstein is sending him a sixteen year old Russian girl for purposes of sex.
– Giuffre 001563 (pictured above)- 6/1/05 For Jeffrey From Jean Luc “He has a teacher for you to teach you how to speak Russian. She is 2X8 years old not blonde. Lessons are free and you can have your 1st today if you call.”
– This message pad directly refutes Maxwell’s sworn testimony that she was not present during the year 2005 at Jeffrey Epstein’s Palm Beach mansion because this shows leaving a message for Jeffrey at the Palm Beach home that she was going to work out 30 See McCawley Dec. at Exhibit 28. Case 18-2868, Document 280, 08/09/2019, 2628232, Page28 of 74 21 with the Defendant on September 10, 2005. The police were only able to retrieve a fraction of these message pads during their trash pull but even in the few they recovered, it shows Maxwell was regularly at the Palm Beach home during the time period she claimed she was not. To the contrary, she was both sending and receiving messages and messages, like this one, reflect her presence at the mansion.
– Giuffre 001412 – 9/10/05 (during the year Maxwell says she was never around) JE from – “I went to Sarah and made her water bottle and I went to work out with GM.”
– These message pads further corroborate that Defendant lied in her testimony and she was in fact in regular contact with Jeffrey Epstein during the years 2004 and 2005. For example, the message from “Larry” demonstrates that Defendant is at the Palm Beach mansion so frequently that people, including Epstein’s main pilot Larry Visoski, are leaving messages for Maxwell at the Palm Beach house.
– Giuffre 001435 7/25/04 – Mr. Epstein from Ms. Maxwell – “tell him to call me”; Giuffre – 001449 – 8/22/05 – JE from GM; Giuffre – 001453 – 4/25/04 for Ms. Maxwell From Larry “returning your call”;
– This message pad shows that Defendant was clearly actively involved in Jeffrey Epstein’s life and the activities at his Palm Beach mansion.
– Giuffre – 001454 – undated Jeffrey From Ghislaine – “Would be helpful to have ___________ come to Palm Beach today to stay here and help train new staff with Ghislaine.”
– This message pad clearly reflects an underage female (noted by the police redaction of the name) leaving a message asking if she can come to the house at a later time because she needs to “stay in school.”
– ” Giuffre 001417 (pictured above)– Jeffrey 2/28/05 Redacted name “She is wondering if 2:30 is o.k. She needs to stay in school.”
– This message pad reflects a message from who was under the age of eighteen at the time she was going over to Jeffrey Epstein’s home to provide sexual massages according to the Palm Beach Investigative Report.
– Giuffre 001421 3/4/05 to Jeffrey from “It is o.k. for to stop by and drop something?”
– These message pads reflect the pattern of underage girls (noted by the police redaction of the name on the message pad) calling the Palm Beach mansion to leave a message about sending a “female” over to provide a sexual massage.
– Giuffre 001423 11/08/04 To Mr. JE – redacted from – “I have a female for him”Giuffre 001426 (pictured above) – 1/09/05 JE To JE from Redacted – “I have a female for him.”
– This message pad reflects the pattern and practice of having young girls bring other young girls to the house to perform sexual massages. Indeed the “ ” reflected in this message pad corresponds in name to the ” that Tony Figueroa testified he initially brought to Jeffrey Epstein during the time period that the Defendant was requesting that Tony find some young females to bring to Jeffrey Epstein’s home. See Figueroa at 184- 185. The Palm Beach Police Report reflects that “ ” and “ ” also brought seventeen year old to the home to perform sexual massages. See GIUFFRE 05641. thereafter recruited a number of other young girls to perform sexual Case 18-2868, Document 280, 08/09/2019, 2628232, Page29 of 74 22 massages as reflected in the Palm Beach Police Report.
– Giuffre 001427 (pictured above) – 1/2/03 – JE from “Wants to know if she should bring her friend with tonight.”
– This message pad reflects multiple sexual massages being scheduled for the same day which corroborates Virginia GIUFFRE, and Johanna Sjorberg’s testimony that Jeffrey Epstein required that he have multiple orgasms in a day which occurred during these sexual massages.
– Giuffre 001449 (pictured above) – 9/03/05 JE from – “I left message for to confirm for 11:00 a.m. and for 4:30 p.m.”
– This message pad shows a friend of Jeffrey Epstein’s discussing with him how he had sex with an 18 year old who had also been with Jeffrey Epstein.
– Giuffre – 001456 (pictured above)– undated JE from Jean Luc – “He just did a good one – 18 years – she spoke to me and said “I love Jeffrey.”
– Law enforcement was able to confirm identities of underage victims through the use of the names and telephone numbers in these message pads
The Black Book
– Palm Beach Police confiscated an extensive lists of contacts with their phone numbers form Defendant and Epstein’s residence.32 Ghislaine Maxwell maintained a contact list in an 31 See McCawley Dec. at Exhibit 13, Recarey Dep. Tr. at 42:14-43:17; 78:25:-79:15. Case 18-2868, Document 280, 08/09/2019, 2628232, Page30 of 74 23 approximately 100-page-long hard copy, which was openly available to other house employees.
– It consisted primarily of telephone numbers, addresses, or email addresses for various personal friends, associates, employees, or personal or business connections of Epstein or Defendant. Prior to being terminated by Defendant, the Palm Beach house butler Alfredo Rodriguez printed a copy of this document and ultimately provided it to the FBI.
– This document reflects the numerous phone numbers of Defendant, Epstein as well as staff phone numbers.
– Additionally, and importantly, there are several sections entitled “Massage” alongside a geographical designation with names of females and corresponding telephone numbers. These numbers included those of underage females (with no training in massage therapy ) – including – identified during the criminal investigation of Epstein. This document is an authentic reflection of the people who were associated with Epstein, Defendant, and the management of their properties, and the knowledge each had of the contents of the document.
Sex Slave Amazon.com Book Receipt
– Detective Recarey authenticated an Amazon.com receipt that the Palm Beach Police collected from Jeffrey Epstein’s trash.
– The books he ordered are titled:
(1) SM 101: A Realistic Introduction, Wiseman, Jay;
(2) SlaveCraft: Roadmaps for Erotic Servitude – Principles, Skills and Tools by Guy Baldwin; and (3) Training with Miss Abernathy: A Workbook for Erotic Slaves and Their Owners, by Christina Abernathy, as shown below: 32 See McCawley Dec. at Exhibit 45, Phone List, Public Records Request No.: 16-268 at 2282 – 2288. Case 18-2868, Document 280, 08/09/2019, 2628232, Page31 of 74 24
– This disturbing 2005 purchase corroborate Ms. Giuffre’s account of being sexually exploited by Defendant and Epstein – not to mention the dozens of underage girls in the Palm Beach Police Report. Additionally, Defendant testified that she was not with Jeffrey Epstein in 2005 and 2006 when he was ordering books on how to use sex slaves; however, record evidence contradicts that testimony.
Thailand Folder with Defendant’s Phone Number
– Defendant also was integral in arranging to have Virginia go to Thailand. While Epstein had paid for a massage therapy session in Thailand, there was a catch.
– Defendant told Virginia she had to meet young girls in Thailand and bring her back to the U.S. for Epstein and Defendant.
– On the travel records and tickets Defendant gave to Virginia, Defendant wrote on the back the name of the girl Virginia was supposed to meet, and she was also instructed to check in frequently with Defendant as it was further signified by the words “Call Ms. Maxwell (917) !” on Virginia’s travel documents. In this case, Virginia also produced the hard copy records from her hotel stay in Thailand paid for by Epstein.
– The FBI report and the Churcher emails reference Ms. Giuffre’s accounts of sexual activity with Prince Andrew that she made in 2011, contrary to Defendant’s argument that Ms. Giuffre never made such claims until 2014.