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Bryan Keener on December 29, 2021

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William Burrell

Presented evidence of the Ghislaine Maxwell trial. Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant Case 18-2868, Document 280, 08/09/2019, 2628232, Page1 of 74 ... View MorePresented evidence of the Ghislaine Maxwell trial. Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant Case 18-2868, Document 280, 08/09/2019, 2628232, Page1 of 74 It is an Undisputed Fact That Multiple Witnesses Deposed in This Case Have Testified That Defendant Operated as Convicted Pedophile Jeffrey Epstein’s Procurer of Underage Girls It is an undisputed fact that Joanna Sjoberg testified Defendant lured her from her school to have sex with Epstein under the guise of hiring her for a job answering phones It is an undisputed fact that Tony Figueroa testified that Defendant would call him to bring over underage girls and that Defendant and Epstein would have threesomes with Ms. Giuffre. It is an undisputed fact that Rinaldo Rizzo testified that Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein. _____ _____ _____ _____ _____ _____ _____ _____ Presented evidence of the Ghislaine Maxwell trial. Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant Case 18-2868, Document 280, 08/09/2019, 2628232, Page1 of 74 It is an undisputed fact that Lyn Miller testified that she believed Defendant became Ms. Giuffre’s “new mama” It is an undisputed fact that Pilot David Rodgers testified that he flew Defendant and Ms. Giuffre at least 23 times on Epstein’s jet, the “Lolita Express” and that “GM” on the flight logs Stands for Ghislaine Maxwell It is an undisputed fact that Sarah Kellen, Nadia Marcinkova, and Jeffrey Epstein invoked the fifth amendment when asked about Defendant trafficking girls for Jeffery Epstein It is an undisputed fact that Juan Alessi testified that Defendant was one of the people who procured some of the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys. It is an undisputed fact that Defendant is unable to garner a single witness throughout discovery who can testify that she did not act as the procurer of underage girls and young women for Jeffrey Epstein.

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December 29, 2021