gov.uscourts.nysd.447706.1327.7.pdf

Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 1 of 9 COMPOSITE EXHIBIT 1 (File Under Seal) Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 2 of 9 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 May 18 , 2016 9:04 a. m C O N F I D E N T I A L Deposition of JOHANNA SJOBERG, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, 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 1327-7 Filed 01/05/24 Page 3 of 9 Page 30 1 Q. Did you observe her to be young when you 2 met her? 3 MS . MENNINGER: Objection, vague as to 4 time . 5 THE WITNESS: All of the women were 6 generally young. I did not know the ages of 7 really anyone, so . . . 8 BY MS. MCCAWLEY: 9 Q. How many massages did Jeffrey receive on 10 average in a given day? 11 MS. MENNINGER: Objection, foundation . 12 THE WITNESS: Three a day. 13 BY MS McCAWLEY: 14 Q. Let me back up for a moment . 15 How long did you work for Jeffrey and 16 Ghislaine? 17 MS. MENNINGER: Objection, leading and 18 foundation. 19 THE WITNESS : I believe it was five years , 20 2001 to 2006 . 21 BY MS. McCAWLEY: 22 Q. And how many massages did Epstein receive 23 per day on average? 24 MS. MENNINGER: Objection, foundation. 25 THE WITNESS: Three. MAGNA8 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 4 of 9 Page 32 1 to object and then you can still answer. No 2 one is going to stop you from answering. I 3 just need to get the objection on the record, 4 in the same way she needs to be able to talk 5 before you. My apologies . I'm not trying to 6 cut you off , but I am supposed to get it in 7 before you answer . 8 BY MS. McCAWLEY: 9 Q. Did Jeffrey ever tell you why he received 10 so many massages from so many different girls? 11 MS. MENNINGER: Objection, hearsay. 12 BY MS . MCCAWLEY: 13 Q. You can answer. 14 A. He explained to me that, in his opinion, 15 he needed to have three orgasms a day. It was 16 biological, like eating. 17 Q. And what was your reaction to that 18 statement? 19 A. I thought it was a little crazy. 20 Q. And what did -- do you recall what when 21 you observed the other females giving massages, do 22 you recall what they would dress like? Did they 23 wear scrubs or did they typically wear normal 24 clothes? 25 A. Normal clothes . MAGNA8 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 5 of 9 Page 34 1 camera? 2 MS . MENNINGER: Objection, leading . 3 THE WITNESS: Yes . 4 BY MS . McCAWLEY: 5 Q. Was there anything you were supposed to do 6 in order to get the camera? 7 MS. MENNINGER: Objection, leading . 8 THE WITNESS: I did not know that there 9 were expectations of me to get the camera until 10 after. She had purchased the camera for me, 11 and I was over there giving Jeffrey a massage. 12 I did not know that she was in possession of 13 the camera until later. 14 She told me -- called me after I had left 15 and said, I have t h e camera for you, but you 16 cannot receive it yet because you came here and 17 didn 1 t finish your job and I had to finish it 18 for you. 19 BY MS. McCAWLEY: 20 Q. And did you -- what did you understand her 21 to mean? 22 A. She was implying that I did not get 23 Jeffrey off, and so she had to do it. 24 Q. And when you say 11 get Jeffrey off , 11 do you 25 mean bring him to orgasm? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 6 of 9 Page 35 1 A. Yes 2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 A. Model types. 5 Q. Did Ghislaine ever talk to you about how 6 you should act around Jeffrey? 7 A. She just had a conversation with me that I 8 should always act grateful. 9 Q. Did Jeffrey ever tell you that he took a 10 girl ' s virginity? 11 A. He did not tell me . He told a friend of 12 mine. 13 Q. And what do you recall about that? 14 MS. MENNINGER: Objection, hearsay , 15 foundation. 16 THE WITNESS : He wanted to have a friend 17 of mine come out who was cardio-kickboxer 18 instructor. She was a physical trainer. 19 And so I brought her over to the house 20 and he told my friend Rachel that -- he said, 21 You see that girl over there laying by the 22 pool? She was 19 . And he said, I just took 23 her virginity. And my friend Rachel was 24 mortified. 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 7 of 9 Page 142 1 exposed her bra, and she grabbed it and pulled it 2 down. 3 Q. Anything else? 4 A. That was the conversation that he had told 5 her that he had taken this girl ' s virginity, the 6 girl by the pool 7 Q. Okay. Did Maxwell ever say to you that it 8 takes the pressure off of her to have other girls 9 around? 10 A. She implied that , yes . 11 Q. In what way? 12 A. Sexually. 13 Q. And earlier Laura asked you, I believe, if 14 Maxwell ever asked you to perform any sexual acts, 15 and I believe your testimony was no, but then you 16 also previously stated that during the camera 17 incident that Maxwell had talked to you about not 18 finishing the job. 19 Did you understand "not finishing the job" 20 meaning bringing Jeffrey to orgasm? 21 MS. MENNINGER: Objection, leading, form. 22 BY MS . MCCAWLEY: 23 Q. I ' m sorry, Johanna, let me correct that 24 question. 25 What did you understand Maxwell to mean MAGNA9 LEGAL SE'.RVICES Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 8 of 9 Page 143 1 when she said you hadn 1 t finished the job, with 2 respect to the camera? 3 MS. MENNINGER: Objection, leading, form. 4 THE WITNESS: She implied that I had not 5 brought him to orgasm . 6 BY MS. McCAWLEY: 7 Q. So is it fair to say that Maxwell expected 8 you to perform sexual acts when you were massaging 9 Jeffrey? 10 MS . MENNINGER: Obj ection, leading, form, 11 foundation. 12 THE WITNESS: I can answer? 13 Yes , I took that conversation to mean that 14 is what was expected of me . 15 BY MS. McCAWLEY: 16 Q. And then you mentioned, I believe, when 17 you were testifying earlier that Jeffrey told you a 18 story about sex on the plane. What was that about? 19 MS. MENNINGER: Objection, hearsay . 20 THE WITNESS: He told me one time Emmy was 21 sleeping on the plane , and they were getting 22 ready to land. And he went and woke her up, 23 and she thought that meant he wanted a blow 24 job, so she started to unzip his pants, and he 25 said, No, no, no, you just have to be awake for MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-7 Filed 01/05/24 Page 9 of 9 Page 157 1 AFFIDAVIT 2 STATE OF FLORIDA ) COUNTY OF ) 3 4 I, , being first 5 duly sworn, do hereby acknowledge that I did read a true and certified copy of my deposition 6 which was taken in the case of GIUFFRE V. MAXWELL, taken on the 18th day of May, 2016 , 7 and the corrections I desire to make are as indicated on the attached Errata Sheet . 8 9 CERTIFICATE 10 11 STATE OF FLORIDA COUNTY OF 12 13 Before me personally appeared 14 to me well known/ known to me to be the 15 person described in and who executed the foregoing instrument and acknowledged to and 16 before me that he executed the said instrument in the capacity and for the purpose therein 17 expressed. 18 19 Witness my hand and official seal , this day of 20 21 22 (Notary Public) 23 24 My Commission Expires: 25 MAGNA9 LEGAL SERVICES