gov.uscourts.nysd.447706.1328.12.pdf

Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 1 of 35 EXHIBIT 5 (Filed Under Seal) Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 2 of 35 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 1328-12 Filed 01/05/24 Page 3 of 35 Page 8 1 Q. Okay. Great. 2 All right. Do you know a female by the 3 name of Ghislaine Maxwell? 4 A. Yes. 5 Q. And when did you first meet Ms. Maxwell? 6 A. 2001. March probably. End of 7 February/beginning of March. 8 Q. And how did you meet her? 9 A. She approached me while I was on campus at 10 Palm Beach Atlantic College. 11 Q. And what happened when she approached you? 12 A. She asked me if I could tell her how to 13 find someone that would come and work at her house. 14 She wanted to know if there was, like, a bulletin 15 board or something that she could post, that she was 16 looking for someone to hire. 17 Q. And what did you discuss with her? 18 A. I told her where she could go to -- you 19 know, to put up a listing. And then she asked me if 20 I knew anyone that would be interested in working 21 for her. 22 Q. Did she describe what that work was going 23 to be? 24 A. She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 4 of 35 Page 9 1 And so she just liked to hire girls to work at the 2 house, answer phones, get drinks, do the job a 3 butler would do. 4 Q. And did she tell you what she would pay 5 for that kind of a job? 6 A. At that moment, no, but later in the day, 7 yes. 8 Q. And what did she say? 9 A. Twenty dollars an hour. 10 Q. Was there anybody else with Ms. Maxwell 11 when you met her? 12 A. There was another woman with her. I don't 13 recall her or what she looks like or how old she 14 was. 15 Q. And what happened next? 16 A. And then she asked me if I would be 17 interested in working for her. And she told me that 18 she was -- I could trust her and that I could jump 19 in her car and go check out the house at that moment 20 if I wanted. 21 And so I said, Sure, let's do it, and went 22 to her home with her. 23 Q. And where was that home? 24 A. In Palm Beach. 25 Q. And did she describe that home as being MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 5 of 35 Page 13 1 Q. And how long did you work in that position 2 answering phones and doing -- 3 A. Just that one day. 4 Q. Just that one day. 5 And did your duties change? 6 A. Well, the next time she called me, she 7 asked me if I wanted to come over and make $100 an 8 hour rubbing feet. 9 Q. And what did you think of that offer? 10 A. I thought it was fantastic. 11 Q. And did you come over to the house for 12 that purpose? 13 A. Yes. 14 Q. And when you came over to the house, was 15 Maxwell present? 16 A. I don't recall. 17 Q. And what happened that second time you 18 came to the house? 19 A. At that point, I met Emmy Taylor, and she 20 took me up to Jeffrey's bathroom and he was present. 21 And her and I both massaged Jeffrey. She was 22 showing me how to massage. 23 And then she -- he took -- he got off the 24 table, she got on the table. She took off her 25 clothes, got on the table, and then he was showing MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 6 of 35 Page 14 1 me moves that he liked. And then I took my clothes 2 off. They asked me to get on the table so I could 3 feel it. Then they both massaged me. 4 Q. So it was more than a foot massage at that 5 point? 6 A. Yeah, it was mostly, like, legs and back. 7 Q. Was everybody in the room without clothes 8 on? 9 A. When they were on the massage table, yes. 10 Q. Did they -- when they got off the massage 11 table to perform the massage, did they dress or 12 did -- 13 A. Yes. 14 Q. They dressed. 15 And do you recall who paid you for that 16 first day that you did the massages? 17 A. I don't recall. 18 Q. Do you recall whether Maxwell was at the 19 house during that first day when you were doing the 20 massage with Emmy and Jeffrey? 21 MS. MENNINGER: Objection, asked and 22 answered. 23 BY MS. McCAWLEY: 24 Q. You can answer. 25 A. I don't recall. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 7 of 35 Page 20 1 A. No, I only -- to you, I said that to you. 2 I just saw her as perhaps someone who may not have 3 had a strong family, and they took her under their 4 wing. 5 Q. Now, you mentioned remembering going to 6 Atlantic City. 7 Did you go -- where did you go after 8 Atlantic City? 9 A. Once we landed in New York, Emmy and I 10 went in a car and drove around the city for a half 11 hour or so, just to see some of the city. 12 Q. And then where did you go after doing the 13 sightseeing? 14 A. We went to the townhouse on East 71st. 15 Q. And can you describe that location for me? 16 A. Sure. Between Madison and Park. I think 17 the address might have been 9 East 71st Street. 18 Q. And who owned that home? 19 A. As far as I knew, Epstein. 20 Q. Can you describe for me physically what -- 21 A. Palatial. When you walk up, it looks like 22 a normal door to a townhouse, and when you walk 23 in -- I thought there were four floors. I heard 24 there were seven floors. I didn't see them all. 25 Q. And do you recall who, if anybody, was at MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 8 of 35 Page 21 1 Jeffrey's home when you arrived? 2 A. Yes. When I first walked in the door, it 3 was just myself, and Ghislaine headed for the 4 staircase and said -- told me to come up to the 5 living room. 6 Q. And what happened at that point, when you 7 came up to the living room? 8 A. I came up and saw Virginia, Jeffrey, 9 Prince Andrew, Ghislaine in the room. 10 Q. And did you meet Prince Andrew at that 11 time? 12 A. Yes. 13 Q. And what happened next? 14 A. At one point, Ghislaine told me to come 15 upstairs, and we went into a closet and pulled out 16 the puppet, the caricature of Prince Andrew, and 17 brought it down. And there was a little tag on the 18 puppet that said "Prince Andrew" on it, and that's 19 when I knew who he was. 20 Q. And did -- what did the puppet look like? 21 A. It looked like him. And she brought it 22 down and presented it to him; and that was a great 23 joke, because apparently it was a production from a 24 show on BBC. And they decided to take a picture 25 with it, in which Virginia and Andrew sat on a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 9 of 35 Page 22 1 couch. They put the puppet on Virginia's lap, and I 2 sat on Andrew's lap, and they put the puppet's hand 3 on Virginia's breast, and Andrew put his hand on my 4 breast, and they took a photo. 5 Q. Do you remember who took the photo? 6 A. I don't recall. 7 Q. Did you ever see the photo after it was 8 taken? 9 A. I did not. 10 Q. And Ms. Maxwell was present during the -- 11 was Ms. Maxwell present during that? 12 A. Yes. 13 Q. What happened next? 14 A. The next thing I remember is just being 15 shown to which room I was going to be staying in. 16 Q. When you exited the room that you were in 17 where the picture was taken, do you recall who 18 remained in that room? 19 A. I don't. 20 Q. Do you recall seeing Virginia exit that 21 room? 22 A. I don't. 23 Q. During this trip to New York, did you have 24 to perform any work when you were at the New York 25 house? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 10 of 35 Page 23 1 A. I performed at least one massage that I 2 recall. 3 Q. And who instructed you to give that 4 massage? 5 A. Jeffrey. 6 Q. And can you describe for me what happened 7 during that massage? 8 A. Near the end, he asked me to rub his 9 nipples while he masturbated. 10 Q. And did that take place? 11 A. It did not. 12 Q. And why not? 13 A. I was not comfortable with it. And so I 14 left the room. 15 Q. Did you have any -- did you say anything 16 to him before leaving the room? 17 A. I believe I said, "I'm done." 18 Q. Do you recall what his reaction was to 19 that? 20 A. I do not. At the time, at that moment, I 21 do not. 22 Q. Did you recall later what -- 23 A. Well, we had a conversation a little 24 later, talking about his expectations, and that was 25 the conversation where he said that the next trip MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 11 of 35 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. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 12 of 35 Page 31 1 BY MS. McCAWLEY: 2 Q. Were the massages performed by the same 3 girl or different females? 4 A. Different. 5 MS. MENNINGER: Objection, foundation. 6 BY MS. McCAWLEY: 7 Q. What did the females who performed the 8 massages look like? 9 MS. MENNINGER: Objection, foundation. 10 THE WITNESS: They all looked different. 11 Some of them were ethnic, some were blond, some 12 were short, some were tall. Everyone was thin. 13 BY MS. McCAWLEY: 14 Q. Were the girls who performed the massages 15 young or old? 16 MS. MENNINGER: Objection, foundation. 17 THE WITNESS: I don't recall anyone being 18 old. 19 BY MS. McCAWLEY: 20 Q. Do you recall anybody being over the age 21 of, say, 25? 22 MS. MENNINGER: Objection, form. 23 THE WITNESS: Yeah, I believe there was 24 probably a few women that were older than 25. 25 MS. MENNINGER: I'm sorry. I get a chance MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 13 of 35 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. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 14 of 35 Page 33 1 MS. MENNINGER: Objection, leading. 2 BY MS. McCAWLEY: 3 Q. Do you believe that from your 4 observations, Maxwell and Epstein were boyfriend and 5 girlfriend? 6 A. Initially, yes. 7 Q. Did Maxwell ever share with you whether it 8 bothered her that Jeffrey had so many girls around? 9 MS. MENNINGER: Objection, leading, 10 hearsay. 11 THE WITNESS: No. Actually, the opposite. 12 BY MS. McCAWLEY: 13 Q. What did she say? 14 A. She let me know that she was -- she would 15 not be able to please him as much as he needed and 16 that is why there were other girls around. 17 Q. Did there ever come a time -- did you ever 18 take a photography class in school? 19 A. Yes. 20 Q. And did there ever come a time when 21 Maxwell offered to buy you a camera? 22 A. Yes. 23 MS. MENNINGER: Objection, leading. 24 BY MS. McCAWLEY: 25 Q. Did Maxwell ever offer to buy you a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 15 of 35 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 the camera for you, but you 16 cannot receive it yet because you came here and 17 didn'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 "get Jeffrey off," do you 25 mean bring him to orgasm? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 16 of 35 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 1328-12 Filed 01/05/24 Page 17 of 35 Page 36 1 BY MS. McCAWLEY: 2 Q. Based on what you knew, did Maxwell know 3 that the type of massages Jeffrey was getting 4 typically involved sexual acts? 5 MS. MENNINGER: Objection, foundation, 6 leading. 7 THE WITNESS: Yes. 8 BY MS. McCAWLEY: 9 Q. What was Maxwell's main job with respect 10 to Jeffrey? 11 MS. MENNINGER: Objection, foundation. 12 THE WITNESS: Well, beyond companionship, 13 her job, as it related to me, was to find other 14 girls that would perform massages for him and 15 herself. 16 BY MS. McCAWLEY: 17 Q. Did Maxwell ever refer to the girls in a 18 particular way? 19 A. At one point when we were in the islands, 20 we were all watching a movie and she called us her 21 children. 22 Q. Did anybody respond to that? 23 A. I don't recall. 24 Q. Did she ever refer to herself as a mother? 25 A. Yes, like a mother hen. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 18 of 35 Page 43 1 time. 2 Q. Did Epstein try to make the massages 3 sexual? 4 A. On occasion. 5 Q. Would Epstein have you rub his nipples? 6 A. Yes. 7 Q. Would he masturbate during the massages? 8 A. Yes. 9 Q. Did he use sex toys or vibrators on you? 10 A. Yes. 11 Q. Would he leave the sex toys or vibrators 12 out after the massage or would he clean up after 13 himself? 14 MS. MENNINGER: Objection, vague, form. 15 THE WITNESS: He did not ever clean up. 16 BY MS. McCAWLEY: 17 Q. Do you believe that your experience during 18 the years you were with Jeffrey and Maxwell damaged 19 you? 20 MS. MENNINGER: Objection, leading, form. 21 THE WITNESS: It affected me. "Damaged" 22 is a strong word. 23 BY MS. McCAWLEY: 24 Q. And in what way did it affect you? 25 A. It affected future relationships with men, MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 19 of 35 Page 44 1 trust issues, expectation issues. 2 Q. Did you observe Nadia Marcinkova and 3 Ghislaine at the house at the same time? 4 MS. MENNINGER: Objection, leading, form. 5 THE WITNESS: I don't recall. 6 BY MS. McCAWLEY: 7 Q. On the USVI trip, the second trip that you 8 took, do you recall Nadia Marcinkova being present? 9 A. I believe she was present at that trip. 10 Q. Do you recall Maxwell being present on 11 that trip? 12 A. Yes. 13 Q. Do you know an individual by the name of 14 Jane Doe 2 ? 15 A. Yes. 16 Q. And who is Jane Doe 2 ? 17 A. She was one of the girls that was around. 18 Q. Was Jane Doe 2 around both Jeffrey Epstein 19 and Ghislaine Maxwell? 20 A. I don't recall. ■ 21 23 - Q. ? A. In Palm Beach. - Do you recall where you first met Jane Doe 2 24 Q. At Jeffrey Epstein's home? 25 A. Yes. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 20 of 35 Page 45 1 Q. And what -- do you recall any observations 2 about Jane Doe 2 when you met her? 3 A. To speak with, she was a little rough 4 around the edges, and I could see the progression of 5 her being groomed a little. They got her braces. 6 She had terrible posture. And with a lot of 7 massages, she learned to stand up straight. So I 8 just saw her become a much more confident person. 9 Q. Do you recall how old she was when you 10 first met her? 11 A. I assumed she was 18, but I do not know 12 her age. 13 MS. McCAWLEY: We're going to take a break 14 really quickly and then we will be back. So we 15 are going to go off the record. 16 THE VIDEOGRAPHER: Off the record at 9:48. 17 (Thereupon, a recess was taken, after 18 which the following proceedings were held:) 19 THE VIDEOGRAPHER: On the record at 9:58. 20 BY MS. McCAWLEY: 21 Q. I'm just going to resume. I have a few 22 more questions for you. 23 You mentioned visiting the US Virgin 24 Islands. 25 Do you recall doing any activities with MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 21 of 35 Page 46 1 Maxwell when you were on the visit to the USVI? 2 MS. MENNINGER: Objection, vague as to 3 time. 4 THE WITNESS: I don't recall. 5 BY MS. McCAWLEY: 6 Q. Do you recall ever going hiking with her? 7 A. Yes. 8 Q. Did Maxwell ever ask you to try to bring 9 other girls over for Jeffrey? 10 A. At that time? 11 Q. Yes. 12 A. No. 13 Q. Any other time? 14 A. Well, she had asked me if I knew anyone 15 that could perform massages that would come to the 16 house. 17 Q. And what was your understanding of that 18 request? 19 MS. MENNINGER: Objection. 20 THE WITNESS: Well -- 21 MS. MENNINGER: Form. 22 THE WITNESS: -- I just wondered why they 23 wouldn't just call me. 24 BY MS. McCAWLEY: 25 Q. And did you bring anybody else over to MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 22 of 35 Page 47 1 perform massages? 2 A. I did not. 3 Q. When you were either in the USVI or in 4 Palm Beach, did you ever observe any females either 5 topless or naked out by the pool? 6 A. Yes. 7 Q. What did you observe? 8 A. Mostly skinny-dipping. 9 Q. Do you know who the individuals were that 10 you observed? 11 A. Sarah Kellen and Ghislaine. 12 Q. Anybody else? 13 A. Yes, but I don't recall who. 14 Q. Did that happen on more than one occasion? 15 A. Yes. 16 Q. How often do you remember making those 17 observations? 18 A. Three times. 19 Q. Do you recall giving a statement to the 20 police regarding Jeffrey Epstein? 21 A. Yes. 22 Q. Do you recall when you gave that 23 statement? 24 A. I don't recall the date. 25 Q. Do you recall the year? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 23 of 35 Page 53 1 post that she needed help. 2 She then asked me if I knew anyone, and I 3 didn't know who she was, I didn't want to take the 4 responsibility of finding someone to work for her, 5 and so I said, Sorry, I don't. 6 And then she said, Well, maybe what about 7 you? 8 And I was at a point in life, I was super 9 spontaneous and willing to skip school. 10 So she said, Come to my house, come in my 11 car and check it out. 12 And so I did. 13 Q. Okay. So for those of you -- of us who 14 don't know, is this like a college campus, like a 15 traditional college campus, or is it in a city 16 setting? 17 A. It's in a city setting. I mean, Palm 18 Beach is not a big city. So it's on the 19 Intracoastal, and there was a big grassy area that 20 were surrounded by buildings, so she was inside of 21 the campus. 22 Q. And she was looking for a bulletin board 23 where she could post a job? 24 A. Something like that, yes. 25 Q. Did she have any kind of flyers -- MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 24 of 35 Page 100 1 the news channel 12 showed up at my door asking me 2 questions. 3 Q. When Jeffrey was pressuring you to do more 4 than you felt comfortable with, did you observe him 5 being more aggressive in general? Outside of the 6 massage context? 7 MS. McCAWLEY: Objection. 8 THE WITNESS: No. 9 BY MS. MENNINGER: 10 Q. Do you know whether he was taking any type 11 of steroids? 12 A. No. 13 Q. Did you ever see him wearing a patch or 14 something like that? 15 A. I don't recall. 16 Q. Did you tell anyone that Jeffrey was 17 becoming more aggressive with you contemporaneous 18 with when it was happening? 19 MS. McCAWLEY: Objection. 20 THE WITNESS: No. 21 BY MS. MENNINGER: 22 Q. When Jeffrey asked you to do other things 23 besides a normal massage, did he offer to pay you 24 additionally? 25 A. Yes. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 25 of 35 Page 101 1 Q. How much? 2 A. One hundred dollars extra. 3 Can I clarify? 4 Q. Absolutely. 5 A. He didn't ever say he would pay me more, 6 but when the massage was more than just a massage 7 and it was sexual, then he would pay me more. 8 Q. It wasn't a discussion; it's just what 9 happened? 10 A. Correct. 11 Q. Thank you for clarifying. 12 The things that took place with you and 13 Jeffrey behind closed doors were when you were a 14 consenting adult, correct? 15 A. Yes. 16 MS. McCAWLEY: Objection. 17 THE WITNESS: Correct. 18 BY MS. MENNINGER: 19 Q. And you did not have knowledge of what 20 took place with other women behind closed doors and 21 Jeffrey, correct? 22 MS. McCAWLEY: Objection. 23 THE WITNESS: Correct. 24 BY MS. MENNINGER: 25 Q. Do you recall giving an interview to a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 26 of 35 Page 122 1 story out, because this is when Dershowitz -- 2 Dershowitz was saying nothing was happening and 3 he was calling her a liar. And she was just 4 trying to find people to back up her story. 5 BY MS. MENNINGER: 6 Q. And what did you understand her story to 7 be? Did she tell you? 8 A. That she was recruited to give massages, 9 sexual massages, and have sex with people such as 10 Dershowitz and Andrew. But I knew none of that at 11 the time. 12 Q. Right. Did you tell them anything -- did 13 you tell them during that meeting that you knew of 14 anything about her being recruited to give sex to 15 either Jeffrey or to other people? 16 MS. McCAWLEY: Objection. 17 THE WITNESS: Can you rephrase? 18 BY MS. MENNINGER: 19 Q. Yes. That wasn't a very good question. 20 What did you say during this meeting with 21 Virginia and her investigator? 22 A. Basically that I believed her, even though 23 I -- she never spoke to me specifically about what 24 was going on; that once I learned everything that 25 happened based on reading the police report, I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 27 of 35 Page 123 1 believed her side of the story. 2 Q. And did she tell you what her side of the 3 story was? 4 A. You know, just that she wasn't a liar; 5 that, you know, she was there to have sex with men 6 that Jeffrey wanted her to sleep with. 7 Q. Did she tell you in that meeting who she 8 had sex with? 9 A. No. 10 Q. Did she name any of the famous people? 11 A. Only Dershowitz came up. 12 Q. Did you two talk about the incident in New 13 York with the puppet? 14 A. I don't recall. 15 Q. And you formed this opinion about whether 16 she was a liar based on things that you've read in 17 the police report? 18 MS. McCAWLEY: Objection. 19 THE WITNESS: I formed my opinion based on 20 my experience in the house. 21 BY MS. MENNINGER: 22 Q. Okay. And what experience in the house 23 helped you form your opinion that what Virginia is 24 saying is true? 25 A. You know, Jeffrey being open with me about MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 28 of 35 Page 133 1 A. Flight logs. 2 Q. Any other documents? 3 A. No. 4 Q. What did Ms. McCawley or Mr. Edwards or 5 any of the other lawyers say to you about Ghislaine 6 Maxwell? 7 A. They just asked impressions. They never 8 said anything about her. 9 Q. Were you shown a copy of any report that 10 came out of that interview? 11 A. Which interview? 12 Q. The one with the -- Virginia's attorneys. 13 MS. McCAWLEY: Objection. 14 THE WITNESS: No. 15 BY MS. MENNINGER: 16 Q. You testified earlier about an incident 17 with a camera that Ghislaine Maxwell had given you. 18 I want to ask you some questions about that. 19 A. Sure. 20 Q. Do you know when that was? 21 A. That was in 2002. 22 Q. And why does that date stick out? 23 A. Because I was living -- where I was living 24 specifically and where I had the phone call. 25 Q. Tell me what you remember about the MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 29 of 35 Page 134 1 conversation. 2 A. I had been over to her house prior 3 massaging Jeffrey. And I got a phone call from her, 4 and she told me she had a camera for me for my 5 photography class, but yet, she couldn't give it to 6 me yet because during the massage I didn't finish my 7 job and she had to finish it for me. 8 Q. Did she say what she meant? 9 A. No, but I knew. 10 Q. Was there any other time that you had 11 discussed with her finishing your job? 12 A. Not that I recall. 13 Q. Any other time you just recall discussing 14 with her anything about your sexual contact with 15 Jeffrey? 16 MS. McCAWLEY: Objection. 17 THE WITNESS: No. 18 BY MS. MENNINGER: 19 Q. Did she give you the camera? 20 A. I did get the camera. 21 Q. Okay. When did she give you the camera? 22 A. I guess the next time I went to the house. 23 Q. What was said at that time? 24 A. I honestly don't know that she handed it 25 to me. I remember it being there for me. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 30 of 35 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 SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 31 of 35 Page 143 1 when she said you hadn'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: Objection, 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 1328-12 Filed 01/05/24 Page 32 of 35 Page 144 1 landing. 2 BY MS. McCAWLEY: 3 Q. Do you recall witnessing any sexual acts 4 on the plane? 5 A. No. 6 Q. Did Emmy ever talk to you about performing 7 sexual acts on the plane? 8 A. No. 9 Q. We looked earlier at the police report, 10 and I just want to clarify, you identified some 11 areas where there were discrepancies in that report. 12 And you can take another look at it if you 13 want, but other than the discrepancies you pointed 14 out, is that a recollection of what you remember 15 telling the detective? 16 A. Yes. 17 MS. MENNINGER: Objection, outside the 18 scope of cross. 19 BY MS. McCAWLEY: 20 Q. You mentioned that there was a time when 21 you noticed that Maxwell was around a little bit 22 less? 23 A. Uh-huh. 24 Q. And I believe you said that was during the 25 middle of the time you were with Jeffrey. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 33 of 35 Page 145 1 Do you remember approximately when that 2 was year-wise? 3 A. I don't. I would say it was probably 4 sometime between 2003 and 2004. 5 Q. And what made you think that? 6 A. I just saw her less and less at the house. 7 Q. Were you there more at the house during 8 that time period? 9 A. No, not necessarily. It's just at the 10 beginning, she was around a lot. And then I would 11 see her occasionally without him. The one time we 12 spent a few days together in 2006, she wasn't there 13 at all. 14 Q. So you saw her in the -- is it fair to say 15 that you saw her in the 2005 and 2006 time frame? 16 A. Yes. 17 Q. Then we were talking about the photography 18 earlier and about the photographs. 19 Did Maxwell ever ask you to take nude 20 photos of yourself for Jeffrey? 21 A. She asked me to take photos of myself for 22 Jeffrey, yes. 23 Q. And did you do that? 24 A. I did not. 25 Q. And the photos that were around that were MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 34 of 35 Page 146 1 in the bathroom, that you mentioned a couple of 2 times places that there were photos of you, who took 3 those? 4 A. He did. 5 Q. And when we were talking about the Palm 6 Beach house and you were describing an area where 7 there were just a lot of photographs, is it fair to 8 say that there could have been nude photographs 9 amongst those photos that you saw? 10 A. Yes. 11 Q. And earlier you testified that you don't 12 have knowledge of what happens behind closed doors, 13 but you also said that Jeffrey had told you what 14 other girls did for him and that he wanted you to do 15 those things for him. 16 Is it fair to say that you knew that other 17 girls were performing sexual acts? 18 A. Yes. 19 MS. MENNINGER: Objection, foundation, 20 form. 21 BY MS. McCAWLEY: 22 Q. And I know you mentioned previously that 23 your relationship and the interaction with him 24 progressed over time. 25 Did there come a time when you were MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-12 Filed 01/05/24 Page 35 of 35 Page 160 1 2 C E R T I F I C A T E 3 STATE OF FLORIDA ) : ss 4 COUNTY OF MIAMI-DADE ) 5 I, KELLI ANN WILLIS, a Registered 6 Professional, Certified Realtime Reporter and 7 Notary Public within and for The State of 8 Florida, do hereby certify: 9 That JOHANNA SJOBERG, the witness whose 10 deposition is hereinbefore set forth was duly 11 sworn by me and that such Deposition is a true 12 record of the testimony given by the witness. 13 I further certify that I am not related 14 to any of the parties to this action by blood 15 or marriage, and that I am in no way interested 16 in the outcome of this matter. 17 IN WITNESS WHEREOF, I have hereunto set 18 my hand this 18th day of May, 2016. 19 20 __________________________ KELLI ANN WILLIS, RPR, CRR 21 22 23 24 25 MAGNA9 LEGAL SERVICES