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Virginia L. Giuffre, Plaintiff, V. Ghislaine Maxwell, Defendant. United States District Court Southern District of New York Case No.: 15-cv-07433-RWS I --------------- PLAINTIFF'S MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL 1 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 127 (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 131. 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 1320-2 Filed 01/03/24 Page 1 of 10