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Ghislaine Maxwell Case 1:15-cv-07433-LAP Document 1090-1

Pages 100-122 of 638

EXHIBIT 11: GIUFFRE VS. MAXWELL Deposition VIRGINIA GIUFFRE 05/03/2016

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Ghislaine Maxwell Case 1:15-cv-07433-LAP Document 1090-1

Pages 123-125 of 638

EXHIBIT 13: United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell, Defendant. AFFIDAVIT OF VIRGINIA GIUFFRE

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Ghislaine Maxwell Case 1:15-cv-07433-LAP Document 1090-1

Pages 126-130 of 638

EXHIBIT 14: IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs/Counterclaim Defendants, vs. ALAN M. DERSHOWITZ, Defendant/Counterclaim Plaintiff. VIDEOTAPED DEPOSITION OF PAUL G. CASSELL TAKEN ON BEHALF OF THE DEFENDANT VOLUM I, PAGES 1 to 151

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Ghislaine Maxwell Case 1:15-cv-07433-LAP Document 1090-1

Pages 131-154 of 638

EXHIBIT 15 Virginia L. Giuffre, Plaintiff, v. Ghislaine Maxwell: Testimony of Virginia Louise Roberts on Jeffrey Epstein and Ghislaine Maxwell.

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The testimony of Virginia Louise Roberts

Who is Virginia?

Virginia worked with her dad on Mar-a-Lago in the spa as a locker room attendant. She was approached at the spa by Ghislaine Maxwell. She quite Mar-a-Lago to work for Epstein full time doing "massages" for him and guests. She didn't start "massages" others unit "working" for Epstein for around 9 months.

How long did she work for Epstein?

She worked for him from age 15 to 19. Starting around June 1998. During that time she slept with 8 guys other than Epstein. She was sent about 10-15 times for a couple of days.

Who did she sleep with on the plain?

She slept with Epstein, Maxwell and other girls. 


"It was a lot of the same thing that went down on the ground. A lot of times, it would be just be me and Jeffrey, or me and Jeffrey and Ghislaine, or me and Jeffrey and some other girl, sometimes Emmy, Sarah, and Nadia Bjourmik. There would be sexual conduct, there would be foreplay, there was a bed in there, so we could basically reenact exactly what was happening in the house. It would start off with massaging or we would start off with foreplay, sometimes in would lead to, you know, orgies."

Who did she talk about?

Bill Clinton. She speaks about him starting on page 22.


Prince Andrew. She speaks about him on page 24.

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Ghislaine Maxwell Case 1:15-cv-07433-LAP Document 1090-1

Pages 155-166 of 638

EXHIBIT 15: PRIVILEGED AND CONFIDENTIAL AGREEMENT ATTORNEY WORK PRODUCT ATTORNEY-CLIENT PRIVILAGE JOINT DEFENSE PRIVILEGE: PRIVILAGED AND CONFIDENTIAL JOINT DEFENSE AND COMMON INTEREST, PRIVILEGE, AND CONFIDENTIALITY AGREEMENT

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Joint Defense Agreement

The legal agreement between the 4 victims' lawyers in this trial.

These document is the legal agreements of the 4 women suing Maxwell. Nothing is disclosed in the document in regards to Epstein or Maxwell.

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Ghislaine Maxwell Case 1:15-cv-07433-LAP Document 1090-1

Pages 167-177 of 638

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YOUR: VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant: DEFENDANT'S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT

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Ghislaine Maxwell Response To Deposition Limit Increase

This is a request by Virginia L. Giuffre to increase the deposition limit.

"A deposition is the formal, recorded out-of-court testimony of a witness or party under oath, taken during the discovery phase of a lawsuit to gather information and evidence from the opposing side. Lawyers ask questions to understand a case's facts, evaluate witness credibility, and uncover potential evidence, with the answers transcribed by a court reporter and usable in court." - Google AI

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Ghislaine Maxwell Case 1:15-cv-07433-LAP Document 1090-1

Pages 178-179 of 638

UNITED STATES DISTRICT COUT SOUTHERN DISTRICT OF NEW YORK: VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. Declaration Of Laura A. Menninger In Support Of Defendant's Response in Opposition to Motion To Exceed Presumptive Ten Deposition Limit

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Deposition Limit Increase

Virginia L. Giuffre lawyer's request to increase the deposition limit.

"A deposition is the formal, recorded out-of-court testimony of a witness or party under oath, taken during the discovery phase of a lawsuit to gather information and evidence from the opposing side. Lawyers ask questions to understand a case's facts, evaluate witness credibility, and uncover potential evidence, with the answers transcribed by a court reporter and usable in court." - Google AI

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