gov.uscourts.nysd.447706.1137.6_3.pdf

Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 1 of 17 EXHIBIT 6 Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 2 of 17 Page l UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - X VIRGINIA L . GIUFFRE , Plaintiff , Case No . : - aga i nst - 15 - cv-07433 - RWS GHISLAINE MAXWELL, Defendants . - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Vi deotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena , was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date , before Leslie Fagin, a Court Reporter and Notary Publ i c in the State of New York. MAGNA LEGAL SERVICES 120 0 Avenue of the Americas New York, New York 10026 MAGNA9 L EGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 3 of 17 Page 2 1 2 APPEARANCES: 3 BOIES SCHILLER & FLEXNER, LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdatle , Florida, 33301 BY: SIGRID MCCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ, ESQUIRE EMMA ROSEN, PARALEGAL 7 8 FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN, P . L. Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 11 BY: BRAD EDWARDS, ESQUIRE 12 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84 112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREYS. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUI RE 20 21 Also Present: 22 James Christe , videographer 23 24 25 MAGNA9 L EGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 4 of 17 Page 52 1 G Maxwell - Confidential 2 for sexual acts. 3 Q. I'm asking if they performed sexual 4 acts? 5 MR. PAGLIUCA : Object to the form 6 and foundation. 7 Q. Did any of the massage therapists 8 who were at the home perform sexual acts for 9 Jeffrey Epstein? 10 A. I don ' t know what you mean by 11 sexual acts. 12 Q. Did any o f the massage therapists 13 who were working at the home perform sexual 14 acts, including touching the breasts, 15 touching the vaginal area, being touched 16 while Jeffrey is masturbating, having 17 intercourse, any of thos e things? 18 MR. PAGLIUCA: Objection. Form and 19 foundation. 20 To the extent any of this is asking 21 for to your knowl edge any consensual sex 22 act that may or may not have involved 23 you, I ' m instruct ing you not to answer 24 the question. 25 Q. I'm not asking about consensual sex MAGNA9 L EGAL S E RVICES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 5 of 17 Page 53 1 G Maxwell - Confidential 2 acts. I ' m asking whether any of the massage 3 therapists performed sexual acts for Mr. 4 Epstein, as I have just described? 5 A. I have never seen anybody have 6 sexual intercourse with with Jeffrey, ever. 7 Q. I ' m not asking about sexual 8 intercourse. I ' m asking about any sexual 9 act , touching of the breast - - did you ever 10 see - - can you read back the question? 11 (Record read.) 12 A. I ' m not addressing any questions 13 about consensual adult sex. If you want to 14 talk about what the subject matter, which is 15 defamation and lying, Virginia Roberts, that 16 you and Virginia Roberts are participating in 17 perpetrating her lies, I 1 m happy to address 18 those . I never saw any inappropriate 19 underage activities with Jeffrey ever. 20 Q. I'm not asking about underage. I 'm 21 asking about whether any of the masseuses 22 that were at the home perfor m sexual acts for 23 Jeffrey Epstein? 24 A. I have just answered the question. 25 Q. No, you haven't. MAGNA9 L EGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 6 of 17 Page 54 1 G Maxwell - Confidential 2 A. I have. 3 Q. No, you haven't . 4 A. Yes , I h ave. 5 Q. You are refusing to answer the 6 question. 7 A. Let ' s move on. 8 Q. I 'm in charge of the deposition. I 9 say when we move on and when we don't . 10 You are here to respond to my 11 questions. If you are r efusing to answer the 12 court will bring you back for another 13 deposition to answer these questions. 14 Do you understand that? 15 MR. PAGLIUCA: You don ' t need to 16 threaten the witness. 17 MS. McCAWLEY: I ' m not threatening 18 her. I'm making sure the record is 19 clear . 20 MR. PAGLIUCA : Certainly can you 21 apply to have someone come back and the 22 court may or may not have her come back 23 again. 24 Again, she is not answering 25 questions that relate to adult consent MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 7 of 17 Page 55 1 G Maxwell - Confidential 2 sex acts. Period. And that ' s the 3 instruction and we can take it up with 4 the court . 5 Q. Ms. Maxwell , are you aware of any 6 sexual acts with masseuses and Jeffrey 7 Epstein that were nonconsensual? 8 A. No. 9 Q. How do you know that? 10 A. All the time that I have been in 11 the house I have never seen , heard, nor 12 witnessed, nor have reported to me that any 13 activities took place, that people were in 14 distress, either reported to me by the staff 15 or anyone else. I base my answer based on 16 that. 17 Q. Are you familiar wi th a person by 18 the name of 19 A. I am. 20 Q. Has given a statement 21 to police about you performing sexual acts on 22 her? 23 A. I have not heard that. 24 Q. Has given a statement 25 to police about Jeffrey Epstein performing MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 8 of 17 Page 64 1 G Maxwell - Confidential 2 Q. Di d you have sex with her? 3 MR . PAGLIUCA: Th is is the same 4 instruction about consensual or 5 nonconsensual. 6 Q. Was - under the age of 18 when 7 you hired her? 8 A. No. I d i dn ' t hi r e h e r , as I said , 9 Jeffrey did. 10 Q. Did ever have sex wi th 11 Jeffrey? 12 MR. PAGLIUCA: Objection to the 13 form and f oundation. 14 A. How woul d I know what somebody else 15 did. 16 Q. You weren't involved in the sex 17 between Jeffrey, and yourself? 18 A. We already 19 Q. Were you involved wi th sex between 20 Jeffrey , - and yourself? 21 MR. PAGLIUCA : Everyone is t alking 22 over each other . You heard the 23 question. 24 Again , you you know what the 25 instruction is. If there is any MAGNA9 LEGAL SERVIC ES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 9 of 17 Page 65 1 G Maxwell - Confidential 2 consensual issue involved, I instruct 3 you not to answer. 4 A. Moving on. 5 Q. So you are refusing to answer that 6 question? 7 A. I ' ve been instructed by my lawyer. 8 Q. Did you ever have sex with Jeffrey , 9 Virginia and yourself when Virginia was 10 underage? 11 A. Absolutely not. 12 MR. PAGLIUCA: We ' ve been going for 13 about an hour. I would like to take a 14 five-minute break, please . 15 MS. MCCAWLEY: I'm almost done. 16 MR. PAGLIUCA: You are not going to 17 allow a break. 18 MS. McCAWLEY: As soon as I get 19 through my line of questioning, which is 20 perfectly appropriat e . 21 Q. Did travel with you and 22 Jeffrey to Europe? 23 A. I'm sure she did. 24 Q. What is she doing today? 25 A. I have no idea. MAGNA9 L EGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 10 of 17 Page 82 l G Maxwell - Confidential 2 Q. Did you train Virginia on how to 3 recruit other girls to perform sexual 4 massages? 5 MR . PAGLIUCA: Objection to the 6 form and foundation. 7 A. No . And it ' s absurd and her entire 8 story is one giant tissue of lies and 9 furthermore, she herself has if she says 10 that , you have to ask her about what she did. 11 Q. Does Jeffrey like to have his 12 nipp l es pinched during sexual encounters? 13 MR. PAGLIUCA: Objection to form 14 and foundation. 15 A. I ' m not referring to any advice on 16 my counsel. I'm not talking about any adult 17 sexual things when I was with him. 18 Q. When Jeffrey would have a massage, 19 would he request that the masseuse pinch his 20 nipples while he was having a massage? 21 A. I ' m not talking about anything with 22 consensual adult situation. 23 Q. What about with underage 24 A. I am not aware of anything. 25 Q. You are not aware of Jeffrey MAGNA9 LEG AL S E R VIC E S Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 11 of 17 Page 92 1 G Maxwell - Confidential 2 Q. In your responsibilities in working 3 for Jeffrey, would you book massages for him 4 on any given day so that he would have a 5 massage scheduled? Would you take a call for 6 example and book a massage for him? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 Q. You can answer. 10 A. Typically, that was not my 11 responsibility. He would either book the 12 massage himself or one of his other 13 assistants would do that. 14 Q. From time to t ime you had to do 15 that? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Like I said, typically it was 19 somebody else 1 s responsibility. 20 Q. If you were unable to book a girl 21 for a massage on a given day , would that mean 22 that you were responsible for giving him a 23 sexual massage? 24 MR. PAGLIUCA: Objection to the 25 form and foundation and I instruct you MAGNA9 L EGAL SERVIC E S Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 12 of 17 Page 9 3 1 G Maxwell - Confidential 2 not to answer any questions about any of 3 your consensual adult sexua l activity. 4 Q. So you are not going to answer that 5 question? 6 A. You just heard my counsel. 7 Q. Have you ever said to anybody that 8 recruit i ng other girls to perform sexual 9 massages for Jeffrey Epstein takes the 10 pressure off you? 11 MR. PAGLI UCA: Object to the form 12 and f oundation. 13 A. Repea t the question and break it 14 out . 15 Q. Have you ever said to anybody that 16 you recruit girls - - 17 A. Stop right there. I never 18 recruited girls, let's stop there. Now 19 breakdown the question. 20 Q. Have you ever said to anybody -- 21 A. By girls , we are talking about 22 underage people -- you said girls, are you 23 talking about underage -- we are not talking 24 about consensual acts -- this is a defamation 25 suit. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 13 of 17 Page 13 7 l G Maxwell - Confidential 2 the flights? 3 A. I can't reco llect h avi ng a meal 4 with them , but just so we are c l ear, the 5 allegations that had a meal on 6 Jeffrey ' s island is 100 percent false. 7 Q. But he may have had a meal on 8 Jeffrey's plane? 9 A. I ' m sure he had a meal on Jeffrey's lO plane. 11 Q. You do know how many t i mes he flew 12 on Jeffrey's plane? 13 A. I don't. 14 Q. Do you know who i s? lS A. I do. l6 Q. How do you know him? l7 A. He used to work or stil l works for 18 19 Q. Did you ever have a relationship 20 with him? 21 A. We are talking about adult 22 consensual relationships , it ' s off the 23 record . 24 Q. I ' m not asking what you did with 25 him , I ' m asking if you ever had a MAGNA& LEGAL S E RV I C E S Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 14 of 17 Page 138 1 G Maxwell - Confident ial 2 relationshi p with him? 3 MR. PAGLIUCA: If you understand 4 the term relationship, certainly you can 5 answer that. 6 A. Define relationship. 7 Q. Somebody that you would have spent 8 time together, either seeing them in a 9 romantic relationship or -- 10 A. You need to be , what do you mean by 11 romantic. I was friends with ~ ut you 12 are suggesting something more so I want to be 13 clear what you are actually asking me. 14 Q. You defined it. You said you were 15 friends wi th him. If that ' s what you were 16 that 1 s all I need to kn ow . 17 While you were on the trip with 18 do you recall where you 19 stayed at these locations, in other words, 20 would you leave the jet and stay overnight at 21 a hotel, do you have a recollection of this 22 trip? 23 A. I recollect the trip but if you ' re 24 asking me where we stayed, you can see it ' s a 25 very fast paced trip. It was very tiring and MAGNA9 L EGAL SERV I CES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 15 of 17 Page 307 1 G Maxwell - Confidential 2 form and foundation. 3 A. I don't know why the name is - - I' m 4 sorry - - I can't -- I have no idea. I 5 recognize the name but that's it. 6 Q. Was a masseuse ? 7 MR. PAGLIUCA: Ob jection to the 8 form and foundation . 9 A. What are you asking me, I'm sorry? 10 Q. When worked for 11 Jeffrey Epstein, did she perform massages? 12 A. I've testified that when 13 came originally, she came to answer 14 telephones. I believe at some point she 15 became a masseuse. I don ' t recollect when 16 and I personally had massages from 17 Q. What did o for Jeffrey 18 Epstein, did she perform massages, anything 19 else? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. When she came she answered phones 23 and at some point, I believe , I don't have 24 any firm recollection, but I believe she went 25 to school and became a masseuse and I had MAGNA9 L EGAL SERVI CES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 16 of 17 Page 308 1 G Maxwell - Confidential 2 massages from her. 3 Q. Did you ever have any sexual 4 interaction with h er? 5 MR. PAGLIUCA: Object to the form 6 and foundation and I'm going to instruct 7 you if we're ta lking about any 8 consensual adult contact, you are not 9 allowed to answer the question . 10 Q. Did you have any sexual contact 11 with her in the presence of Jeffrey Epstein? 12 MR. PAGLIUCA: Same instruction. 13 Q. Did you have any sexual contact 14 with her in the presence of anybody other 15 than Jef frey Epstein? 16 MR. PAGLIUCA: Same instruction. 17 Q. How many massages did you receive 18 from 19 A. I really don 't recall but a fair 20 amount. 21 Q. Did the massages involve sex? 22 MR. PAGLIUCA: I'm going to 23 instruct you not to answer. 24 Q. Have you ever engaged in sex with 25 any female? MAGNA9 LE GAL SERVICES Case 1:15-cv-07433-LAP Document 1137-6 Filed 10/22/20 Page 17 of 17 Page 309 1 G Maxwell - Confidential 2 MR. PAGLIUCA: I ' m go i ng to 3 instruct you not to answer. 4 MS. McCAWLEY: I want the record to 5 reflect that Ms. Maxwell ' s attorney is 6 d irecting her not to answer this series 7 of questions . 8 MR. PAGLIUCA: It definitely does. 9 Q. Were you responsible for 10 introducing to Jeffrey Epstein? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I already testified that I don't 14 really recall 15 Q. Were you responsible for 16 introduc i ng - to Jeffrey Epstein? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. Again, I don't like the 20 characterization of introduc tion . 21 came to answer telephones. 22 Q. When did you - - were you the person 23 who brought or introduced or met or 24 purposes of bringing her to Jeffrey Epstein ' s 25 home? MAGNA9 L EGAL SERVICES