gov.uscourts.nysd.447706.1295.3.pdf
EXHIBIT C
GIUFFRE
VS.
MAXWELL
Deposition
VIRGINIA GIUFFRE
05/03/2016
_______________________________________________________________________
Agren Blando Court Reporting & Video, Inc.
216 16th Street, Suite 600
Denver Colorado, 80202
303-296-0017
Agren Blando Court Reporting & Video, Inc.
1 filed under oath is no longer true, correct?
2 MR. EDWARDS: Object to the form.
3 A I wouldn't say that it wasn't true. I was
4 just unaware of the times and the dates.
5 Q (BY MS. MENNINGER) Again, is there more
6 than one truth, Ms. Roberts?
7 A No, there's no more than one truth.
8 Q All right. So a document in which you
9 swore that you were 15 years old when you met
10 Ms. Ghislaine Maxwell is an untrue statement,
11 correct?
12 MR. EDWARDS: Object to the form.
13 A It's not that it's an untrue statement.
14 It was a mistake. So it wasn't intentionally trying
15 to say something that wasn't true. It was to my best
16 knowledge that I thought it was 1999. And when I got
17 my records from Mar-a-Lago I was able to find out
18 that it was 2000. And this was entered before I
19 found out the actual dates that I did work at
20 Mar-a-Lago.
21 Q (BY MS. MENNINGER) Okay. So a document
22 that you filed under oath --
23 A Um-hum.
24 Q -- is now, you believe to be untrue,
25 correct?
VIRGINIA GIUFFRE 5/3/2016 27
Agren Blando Court Reporting & Video, Inc.
1 another prince, the large hotel chain owner and
2 Marvin Minsky, is there anyone else that Ghislaine
3 Maxwell directed you to go have sex with?
4 A I am definitely sure there is. But can I
5 remember everybody's name? No.
6 Q Okay. Can you remember anything else
7 about them?
8 A Look, I've given you what I know right
9 now. I'm sorry. This is very hard for me and very
10 frustrating to have to go over this. I don't -- I
11 don't recall all of the people. There was a large
12 amount of people that I was sent to.
13 Q Do you have any notes of all these people
14 that you were sent to?
15 A No, I don't.
16 Q Where are your notes?
17 A I burned them.
18 Q When did you burn them?
19 A In a bonfire when I lived at Titusville
20 because I was sick of going through this shit.
21 Q Did you have lawyers who were representing
22 you at the time you built a bonfire and burned these
23 notes?
24 A I've been represented for a long time, but
25 it was not under the instruction of my lawyers to do
VIRGINIA GIUFFRE 5/3/2016 205
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1 this. My husband and I were pretty spiritual people
2 and we believed that these memories were worth
3 burning.
4 Q So you burned notes of the men with whom
5 you had sex while you were represented by counsel in
6 litigation, correct?
7 MR. EDWARDS: Object to the form.
8 A This wasn't anything that was a public
9 document. This was my own private journal, and I
10 didn't want it anymore. So we burned it.
11 Q (BY MS. MENNINGER) When did you write
12 that journal?
13 A Just over time. I started writing it
14 probably in, I don't know, I can't speculate, 2012,
15 2011.
16 Q So you did not write this journal at the
17 time it happened?
18 A No.
19 Q You started writing this journal
20 approximately a decade after you claim you finished
21 being sexually trafficked, correct?
22 A Yes.
23 Q And you started writing a journal after
24 you had a lawyer, correct?
25 A Correct.
VIRGINIA GIUFFRE 5/3/2016 206
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1 Q Including Mr. Edwards, who is sitting
2 right here, correct?
3 A Correct.
4 Q What did that journal look like?
5 A It was green.
6 Q And what else?
7 A It was just a spiral notebook.
8 Q Okay. And what did you put into that
9 green spiral notebook?
10 A Bad memories. Things that I've gone
11 through, lots of things, you know. I can't tell you.
12 There was a lot of pages. It was over 300 pages in
13 that book.
14 Q Did you ever show that book to your
15 lawyers?
16 A No.
17 Q Did you show that book to anyone?
18 A My husband.
19 Q Did you show it to anyone else besides
20 your husband?
21 A No.
22 Q Did you tear out pages and give them to
23 Sharon Churcher?
24 A No, I wrote -- those pages that you're
25 talking about, I wrote for her specifically. She
VIRGINIA GIUFFRE 5/3/2016 207
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1 wanted to know about the Prince Andrew incident.
2 Q So that's a different piece of paper?
3 A Yeah, that's just random paper.
4 Q So you had a green spiral notebook that
5 you began sometime in 2011 or 2012 in which you wrote
6 down your recollections about what had happened to
7 you, and you burned that in a bonfire in 2013.
8 Did I get that right?
9 A You got that right.
10 Q And do you have no other names of people
11 to whom you claim Ghislaine Maxwell directed you to
12 have sex, correct?
13 A At this time, no.
14 Q Is there any document that would refresh
15 your recollection that you could look at?
16 A If you have a document you'd like to show
17 me, I would be glad to look at it and tell you the
18 names I recognize off of that.
19 Q I'm just asking you if there's a document
20 you know of that has this list of names in it?
21 A Not in front of me, no.
22 Q Where is the original of the photograph
23 that has been widely circulated in the press of you
24 with Prince Andrew?
25 A I probably still have it. It's not in my
VIRGINIA GIUFFRE 5/3/2016 208
GIUFFRE
VS.
MAXWELL
Deposition
VIRGINIA GIUFFRE
05/03/2016
_______________________________________________________________________
Agren Blando Court Reporting & Video, Inc.
216 16th Street, Suite 600
Denver Colorado, 80202
303-296-0017
Agren Blando Court Reporting & Video, Inc.
1 filed under oath is no longer true, correct?
2 MR. EDWARDS: Object to the form.
3 A I wouldn't say that it wasn't true. I was
4 just unaware of the times and the dates.
5 Q (BY MS. MENNINGER) Again, is there more
6 than one truth, Ms. Roberts?
7 A No, there's no more than one truth.
8 Q All right. So a document in which you
9 swore that you were 15 years old when you met
10 Ms. Ghislaine Maxwell is an untrue statement,
11 correct?
12 MR. EDWARDS: Object to the form.
13 A It's not that it's an untrue statement.
14 It was a mistake. So it wasn't intentionally trying
15 to say something that wasn't true. It was to my best
16 knowledge that I thought it was 1999. And when I got
17 my records from Mar-a-Lago I was able to find out
18 that it was 2000. And this was entered before I
19 found out the actual dates that I did work at
20 Mar-a-Lago.
21 Q (BY MS. MENNINGER) Okay. So a document
22 that you filed under oath --
23 A Um-hum.
24 Q -- is now, you believe to be untrue,
25 correct?
VIRGINIA GIUFFRE 5/3/2016 27
Agren Blando Court Reporting & Video, Inc.
1 another prince, the large hotel chain owner and
2 Marvin Minsky, is there anyone else that Ghislaine
3 Maxwell directed you to go have sex with?
4 A I am definitely sure there is. But can I
5 remember everybody's name? No.
6 Q Okay. Can you remember anything else
7 about them?
8 A Look, I've given you what I know right
9 now. I'm sorry. This is very hard for me and very
10 frustrating to have to go over this. I don't -- I
11 don't recall all of the people. There was a large
12 amount of people that I was sent to.
13 Q Do you have any notes of all these people
14 that you were sent to?
15 A No, I don't.
16 Q Where are your notes?
17 A I burned them.
18 Q When did you burn them?
19 A In a bonfire when I lived at Titusville
20 because I was sick of going through this shit.
21 Q Did you have lawyers who were representing
22 you at the time you built a bonfire and burned these
23 notes?
24 A I've been represented for a long time, but
25 it was not under the instruction of my lawyers to do
VIRGINIA GIUFFRE 5/3/2016 205
Agren Blando Court Reporting & Video, Inc.
1 this. My husband and I were pretty spiritual people
2 and we believed that these memories were worth
3 burning.
4 Q So you burned notes of the men with whom
5 you had sex while you were represented by counsel in
6 litigation, correct?
7 MR. EDWARDS: Object to the form.
8 A This wasn't anything that was a public
9 document. This was my own private journal, and I
10 didn't want it anymore. So we burned it.
11 Q (BY MS. MENNINGER) When did you write
12 that journal?
13 A Just over time. I started writing it
14 probably in, I don't know, I can't speculate, 2012,
15 2011.
16 Q So you did not write this journal at the
17 time it happened?
18 A No.
19 Q You started writing this journal
20 approximately a decade after you claim you finished
21 being sexually trafficked, correct?
22 A Yes.
23 Q And you started writing a journal after
24 you had a lawyer, correct?
25 A Correct.
VIRGINIA GIUFFRE 5/3/2016 206
Agren Blando Court Reporting & Video, Inc.
1 Q Including Mr. Edwards, who is sitting
2 right here, correct?
3 A Correct.
4 Q What did that journal look like?
5 A It was green.
6 Q And what else?
7 A It was just a spiral notebook.
8 Q Okay. And what did you put into that
9 green spiral notebook?
10 A Bad memories. Things that I've gone
11 through, lots of things, you know. I can't tell you.
12 There was a lot of pages. It was over 300 pages in
13 that book.
14 Q Did you ever show that book to your
15 lawyers?
16 A No.
17 Q Did you show that book to anyone?
18 A My husband.
19 Q Did you show it to anyone else besides
20 your husband?
21 A No.
22 Q Did you tear out pages and give them to
23 Sharon Churcher?
24 A No, I wrote -- those pages that you're
25 talking about, I wrote for her specifically. She
VIRGINIA GIUFFRE 5/3/2016 207
Agren Blando Court Reporting & Video, Inc.
1 wanted to know about the Prince Andrew incident.
2 Q So that's a different piece of paper?
3 A Yeah, that's just random paper.
4 Q So you had a green spiral notebook that
5 you began sometime in 2011 or 2012 in which you wrote
6 down your recollections about what had happened to
7 you, and you burned that in a bonfire in 2013.
8 Did I get that right?
9 A You got that right.
10 Q And do you have no other names of people
11 to whom you claim Ghislaine Maxwell directed you to
12 have sex, correct?
13 A At this time, no.
14 Q Is there any document that would refresh
15 your recollection that you could look at?
16 A If you have a document you'd like to show
17 me, I would be glad to look at it and tell you the
18 names I recognize off of that.
19 Q I'm just asking you if there's a document
20 you know of that has this list of names in it?
21 A Not in front of me, no.
22 Q Where is the original of the photograph
23 that has been widely circulated in the press of you
24 with Prince Andrew?
25 A I probably still have it. It's not in my
VIRGINIA GIUFFRE 5/3/2016 208