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rrect? MR. YAREMA: Object to the form. A Fifth. Q This is a call from you indicating that '1= cannot work today be 1 2 3 4 5 6 7 8 48 Ghisiaine Maxwell's sexual interaction with Jane Doe-102 when she was a minor? MR. YAREMA: Object to the fonn. Q This is one of many underage minor females that was
ou 19 question. 19 have been made to perform on sexually? 20 Q Isn't it true that yourself, Chislalne 20 MR. YAREMA: Object to the form. 21 Maxwell and had access to a master 21 A Fifth. 22 of list of underage minor females names and phone 22 Q Jean Luc Brunel is somebody that you 23 numb
MR. YAREMA: Object to the font 17 Q Do you know Ghislaine Maxwell? 18 A Fifth. 18 A Fifth. 19 Q in ad
12 13 14 15 16 17 18 19 20 21 22 23 24 25 in either 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Did you, in fact, call A.G. to come to Jeffrey Epstein's home and give him a massage in a sexual nature in 2001 or 2002? MR. YAREMA: Object to the form. A Fifth. Q Dld you
for a massage of a sexual nature? MR. YAREMA: Object to the Iona. A Fifth. Q Did Jeffrey Epstein tell you it was his intent during the course of A.G.'s visit to his home to persuade, induce or entice her to engage in sexual activity? MR. YAREMA: Object to the form. A Fifth. Q Didn't Jeffrey Ep
his lik. mostly young. but there is no one of them to whom he has been able to commit. He describes his most public companion of the last decade. Ghislaine Maxwell. 41 the daughter of the late. disgraced media baron Roben Max- well. as simply his "best friend." He says she is not on his payroll, but she seems
ar Stearns source recalls a meet- ; ing in which Epstein chewed out a team making a presentation for Wexner as - mAICH 2003 C a h. d. M SDNY GM 02764640 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA 00251482 EFTA01334044 being so brutal as to be "irresponsible." On
Side dinners." the woman recalls. -Many seemed foreign and dressed a little bizarrely." This same guest also at- tended a cocktail party thrown by Maxwell that Prince Andrew attended. which was filled, she says. with young Russian mod- els. "Some of the guests were horrified." the woman says. "He's
s his most public companion of the last decade. Ghislaine Maxwell. 41 the daughter of the late. disgraced
a man who loves amok 71 new general. en—lots of them. moult,' Epstein had been running International young. Model types have *Assets Group Inc. tl.A.G.). a consulting been heard saying they aigi company. out of his apartment in the Solo full of gratitude to Eps4E building on East 66th Street in Ne
mployees and underlings to repeatedly find and bring minor girls to him. Epstein worked in concert as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexual gratification, but also for the sexual gratification of others. The FBI deter
f the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not on
as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girl
reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu
f the enterprise with others, including Obislane Maxwell and Jean Luc Brunel, to obtain minor girls not on
sonable opportunity for further investigation or discovery. Fed. R. Civ. P. I1(b). Rule 1 1 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe that his actions were factu
Entities connected to both Ghislaine Maxwell and A.G.

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
JPMorgan Chase
ORGANIZATION
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSONDoug Band
PERSON