gov.uscourts.nysd.447706.1331.18.pdf

Case 1:15-cv-07433-LAP Document 1331-18 Filed 01/05/24 Page 1 of 8 EXHIBIT F Case 1:15-cv-07433-LAP Document 1331-18 Filed 01/05/24 Page 2 of 8 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 20, 2016 9:12 a.m. C O N F I D E N T I A L Deposition of pursuant to notice, taken by Plaintiff, at the offices of Podhurst Orseck, 25 West Flagler Street, Suite 800, Miami, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-18 Filed 01/05/24 Page 3 of 8 Page 2 2 3 4 A P P E A R A N C E S: 5 BOIES SCHILLER & FLEXNER, LLP Attorneys for Plaintiff 6 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 7 BY: BRADLEY EDWARDS, ESQ. 8 9 HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 10 150 East 10th Avenue Denver, Colorado 80203 11 BY: JEFFREY PAGLIUCA, ESQ. 12 13 PODHURST ORSECK, P.A. Attorneys for Deponent 14 25 West Flagler Street Suite 800 15 Miami, Florida 33130 BY: ROBERT JOSEFSBURG, ESQ. 16 17 18 19 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-18 Filed 01/05/24 Page 4 of 8 Page 3 2 3 I N D E X 4 Examination by Mr. Edwards .................... 4 Examination by Mr. Pagliuca .................... 57 5 Further Examination by Mr. Edwards ............. 68 6 7 8 E X H I B I T S 9 Deposition Exhibit 1 ........................... 6 Police Interview 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-18 Filed 01/05/24 Page 5 of 8 Page 10 1 - CONFIDENTIAL 2 A. No, sir, I do not. 3 Q. Do you remember that the police officers 4 tape-recorded the statement with you? 5 A. Vaguely, yes. 6 Q. Do you remember how old you were when you 7 met Jeffrey Epstein? 8 A. Sixteen or 17. 9 Q. Okay. And have you reviewed -- 10 A. I may have been 15. I don't recall. I 11 apologize. 12 Q. If you told the police officer 16, you 13 were telling the truth? 14 A. At the time, they were fresh. 15 MR. PAGLIUCA: Object to form and 16 foundation. 17 THE WITNESS: The facts were fresh at the 18 time. But 12 years later, I don't recall. 19 MR. PAGLIUCA: If you can just do a little 20 pause in between his question and your answer. 21 I need an opportunity to object to any form or 22 foundation problem with his question. 23 THE WITNESS: Sure. 24 MR. PAGLIUCA: It helps the court reporter 25 if the three of us are not talking at the same MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-18 Filed 01/05/24 Page 6 of 8 Page 43 1 - CONFIDENTIAL 2 THE WITNESS: I do remember having several 3 conversations about Bill Clinton and others. 4 BY MR. EDWARDS: 5 Q. What do you remember saying about Bill 6 Clinton? 7 A. They went on a trip to Africa with Kevin 8 Spacey and that it really -- there was nothing 9 specific about Bill Clinton other than I think it 10 was a trip where they -- it was very vague. It was 11 implied that they enjoyed themselves, however that 12 was. 13 There were specific things said about 14 Spacey, but I cannot recall anything about Clinton. 15 Q. Okay. After speaking to the police or 16 while speaking to the police, do you remember 17 telling them that you're not safe because you're 18 talking about this? 19 MR. PAGLIUCA: Object to form and 20 foundation. 21 THE WITNESS: Yes. 22 BY MR. EDWARDS: 23 Q. And that you had heard Jeffrey Epstein 24 making threats to people on the telephone? 25 MR. PAGLIUCA: Object to form and MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-18 Filed 01/05/24 Page 7 of 8 Page 44 1 - CONFIDENTIAL 2 foundation. 3 THE WITNESS: Yes. He wasn't always 4 friendly. 5 BY MR. EDWARDS: 6 Q. What type of threats do you remember 7 hearing Jeffrey Epstein make to anyone? 8 A. Nothing specific. I do remember hostile 9 conversations where he was upset with people, and I 10 assumed that it was business and none of my 11 business. 12 Q. Okay. You were asked by the detectives, 13 "Things like, You're going to die; you're going to 14 break your legs." And your response was: "All of 15 the above." 16 MR. PAGLIUCA: Objection. 17 BY MR. EDWARDS: 18 Q. Do you remember those type of things? 19 MR. PAGLIUCA: Object to form and 20 foundation. 21 THE WITNESS: Not specifically, no. 22 BY MR. EDWARDS: 23 Q. Do you remember where you were when you 24 heard these conversations? 25 A. Most of the time he was on the phone when MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-18 Filed 01/05/24 Page 8 of 8 Page 71 1 - CONFIDENTIAL 2 CERTIFICATE OF OATH 3 STATE OF FLORIDA ) 4 COUNTY OF MIAMI-DADE ) 5 I, the undersigned authority, certify that 6 personally appeared before me and was duly sworn. 7 WITNESS my hand and official seal this 23rd day of June, 2016. 8 9 Kelli Ann Willis, RPR, CRR 10 Notary Public, State of Florida Commission FF928291, Expires 2-16-20 11 + + + + + + + + + + + + + + + + + + 12 CERTIFICATE 13 STATE OF FLORIDA ) 14 COUNTY OF MIAMI-DADE ) 15 I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime 16 Reporter do hereby certify that I was authorized to and did stenographically report the 17 foregoing deposition of ; that a review of the transcript was not requested; and 18 that the transcript is a true record of my stenographic notes. 19 I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any 20 of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected 21 with the action, nor am I financially interested in the action. 22 Dated this 23rd day of June, 2016. 23 24 KELLI ANN WILLIS, RPR, CRR 25 MAGNA9 LEGAL SERVICES