gov.uscourts.nysd.447706.1327.29.pdf

Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 1 of 35 EXHIBIT E Case 1:15-cv-07433-LAP Document 1327-29 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 1327-29 Filed 01/05/24 Page 3 of 35 Page 19 1 in your view? 2 A. Yes. 3 Q. Did you ever -- did you at that time 4 wonder why she was traveling with Jeffrey? 5 A. At that time, I did not. 6 Q. Did you later wonder that? 7 A. Yes. 8 Q. And what was your impression? 9 MS. MENNINGER: Objection, vague, 10 speculative. 11 THE WITNESS: I -- we're jumping ahead; is 12 that okay? 13 BY MS. McCAWLEY: 14 Q. Yes, that's okay. 15 A. A few days later, I remember asking her 16 questions to try to figure out her role, why she was 17 there, and she gave me vague answers and was never 18 specific. 19 And so I thought perhaps she just was an 20 assistant, someone that did massages well. I wanted 21 to believe that she was innocent. 22 Q. Did you ever refer to her as being 23 orphan-like? 24 A. I did. 25 Q. And how did that come about? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 4 of 35 Page 25 1 And I can't recall if they were in the main living 2 areas. 3 Q. Did you see them in the stairwell up to 4 the second story of the house? 5 A. I can't recall. 6 Q. Do you know who -- who the people were in 7 those photos? Were you familiar with any of them? 8 A. No. 9 Q. Were you in any of those photos? 10 A. At one point, yes. 11 Q. And were you naked in that photo? 12 A. Topless. 13 Q. Do you recall seeing any naked photos of 14 Virginia Roberts? 15 A. I do not. 16 Q. Where did you go next, after the New York 17 visit? 18 A. I went to the Virgin Islands. 19 Q. And who told you that you would be going 20 to the Virgin Islands? 21 A. He asked me if I wanted to go, and I said 22 I would still like to go. 23 Q. And do you recall who you -- who went with 24 you to the Virgin Islands? 25 A. I believe -- well, I know Virginia was MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 5 of 35 Page 27 1 leading. 2 THE WITNESS: Jeffrey Epstein; Ghislaine 3 Maxwell; AP and PK are the two women I do not 4 recall; Virginia Roberts; and myself. 5 BY MS. McCAWLEY: 6 Q. Do you recall how you flew back from the 7 location in the US Virgin Islands? 8 A. They put me on a commercial flight. I 9 wanted to be home in time for Easter. 10 Q. When you say "they," do you recall who 11 made those arrangements for you? 12 A. It could have been Ghislaine. 13 Q. Did you -- do you recall performing 14 massages while you were in the US Virgin Islands? 15 A. Yes. 16 Q. Who was involved in -- was there more than 17 one? 18 A. Yes. I massaged Ghislaine at one point. 19 And I massaged Jeffrey, Virginia and I, both, on the 20 beach. 21 Q. Were you dressed during the massage that 22 was on the beach? 23 A. Yes. Bikinis probably, most likely. 24 Q. Do you recall what Virginia was wearing? 25 A. I believe she was wearing a bathing suit, MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 6 of 35 Page 29 1 Q. Did you ever see Ghislaine Maxwell during 2 that trip laying out by the pool? 3 A. There was one time where we were all by 4 the pool, yes. 5 Q. Was Ghislaine Maxwell ever nude or topless 6 by the pool? 7 A. I don't recall. She was nude when she 8 went swimming in the ocean. 9 Q. At that moment in the USVI home, did you 10 observe any photos there of nude females? 11 A. I don't recall. 12 Q. Besides Virginia, who you mentioned, you 13 observed to be young, did you observe any other 14 females that in your view appeared to be essentially 15 under the age of 18? 16 A. No. 17 Q. Did you observe any females who you 18 thought looked young, younger than you? 19 A. No. 20 Q. Do you remember an individual by the name 21 22 23 of - Epstein? A. that you met during your time with Jeffrey In Palm Beach? 24 Q. Yes. 25 A. Yes. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 7 of 35 Page 42 1 A. Sarah Kellen was there. Ghislaine was 2 there. That's all I recall. 3 Q. Do you recall why you went on the trip to 4 New Mexico? 5 A. To work. 6 Q. Did you perform massages on that trip? 7 A. Yes. 8 Q. Did you -- do you recall whether you 9 performed massages with Sarah Kellen on that trip? 10 A. No. 11 Q. Do you recall in the New Mexico home ever 12 observing nude photos of females there? 13 A. I don't recall. 14 Q. When you would provide massages, would you 15 provide those massages naked? 16 A. On occasion. 17 Q. On average, would you be naked, if it was 18 100 percent of the time, more than 50 percent of the 19 time? 20 A. Can you repeat it? 21 Q. Sure. When you're performing the 22 massages, can you tell me -- you said on occasion. 23 Over the five years that you worked for him, how 24 often did you perform massages naked? 25 A. Somewhere between 25 and 50 percent of the MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 8 of 35 Page 55 1 observed her personality to be? 2 A. Sure. She definitely had a great sense of 3 humor, she loved making jokes. I mean, in a very 4 British way. I don't remember her ever laughing, 5 but she was funny. 6 And I remember just thinking, she -- the 7 first weekend that we flew to the Virgin Islands, 8 she flew the helicopter from Saint, wherever we were 9 to little Saint Jeff [sic] or whatever the name of 10 the island was, and I just thought, wow, who is this 11 woman. 12 Q. Would you say that you respected her? 13 A. Yes. 14 Q. When you ended up getting in the car with 15 her and this other woman and going back to the 16 house, who was driving the car? 17 A. She was driving. 18 Q. And where did she take you? 19 A. She took me to the house in Palm Beach. 20 Q. And can you describe the house in Palm 21 Beach? 22 A. Sure. It's at the end of El Brillo Way, 23 on the Intracoastal. The house was either white or 24 pink. It was pink at one time it may have been 25 painted. It was nothing fancy, it was large, it was MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 9 of 35 Page 85 1 something. That's all I recall. 2 Q. Did you go anywhere with Virginia? 3 A. Oh, my gosh, yes. We went to Phantom of 4 the Opera. 5 Q. Who else went? 6 A. I think it was just she and I. I forgot 7 about that. Thank you for that memory. 8 Q. It's my job. 9 Anything else you remember about that day 10 in New York? 11 A. No. 12 Q. You said you had given a massage to 13 Jeffrey while you were there on that trip or was it 14 a subsequent trip? 15 A. That trip. 16 Q. And how did that come to be? 17 A. Either he or somebody asked me to go and 18 do it. Someone showed me to the room, but I don't 19 remember who it was. 20 Q. Can you describe that room? 21 A. Yes. It was high ceilings, dark. There 22 were, like, dark red walls or dark blue walls or 23 dark blue carpeting or something. It had a massage 24 table set up in the middle, and there was a large -- 25 I want to say like a 15-foot photo, either photo or MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 10 of 35 Page 87 1 Q. Do you know personally whether anyone else 2 had said no to him? 3 A. No. 4 Q. Did anyone ever tell you that they had 5 been in a massage scenario and told him no? 6 A. No. 7 Q. Do you recall when in your trip the 8 massage occurred? 9 A. Well, it was not the day we landed. It 10 must have been that next day that we were there. 11 Q. Do you remember anything else about 12 Virginia from that trip other than the Prince Andrew 13 thing and Phantom of the Opera? 14 A. Well, we were getting ready to leave to go 15 to the airport, and we were waiting. She and I sat 16 on the steps in the foyer. I do remember just kind 17 of asking a few questions to try to understand her 18 role, because at that point now I knew what he 19 wanted from me in the massage. And -- but she did 20 not make it clear to me that she was participating 21 in that. So I was prodding gently to see if there 22 was anything happening that shouldn't have been, 23 because I was getting the impression that she was -- 24 she told me she was 17. 25 Q. She told you she was 17? MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 11 of 35 Page 88 1 A. Uh-huh. 2 Q. How did that come up? 3 A. I asked her. 4 Q. Was anyone else present during this 5 conversation? 6 A. No. 7 Q. You mentioned in your earlier testimony 8 that she seemed orphan-like. 9 A. Yes. 10 Q. But you said that was something you had 11 said to Ms. McCawley, correct? 12 A. Correct. 13 Q. That was not said at the time? 14 A. Right. No. At the time I was getting an 15 impression that she did not have a family or she had 16 walked away from her family. And it seemed to me, 17 you know, they had just sort of adopted her, not as 18 a child, but they would take care of her. 19 Q. Did you observe anyone speaking to her as 20 a child, like make up your bed? 21 A. No. 22 Q. Did you observe whether she was using 23 drugs during that trip? 24 A. No. 25 MS. McCAWLEY: Objection. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 12 of 35 Page 92 1 celebration or cake with candles. It was just 2 another day. 3 Q. You said that the Virgin Islands were a 4 part of that second trip, as well? 5 A. Yes. 6 Q. And do you remember Ghislaine being part 7 of the Virgin Islands the second time? 8 A. Yes. That's when she called -- went to 9 bed and kissed us all on the head and called us her 10 children. 11 Q. Who were the other participants in that 12 session? 13 A. That's who -- I don't recall who was 14 15 16 there. Q. A. I want to say that - But Virginia was not there? Virginia was not there. was. 17 Q. Do you recall the point in time in which 18 Virginia went away? 19 A. Sort of. After the trip to New York, I 20 was given her phone number to call. And I remember 21 one time I tried to get ahold of her. Her boyfriend 22 answered. A boyfriend, I would assume, and he 23 sounded like he was high. And I couldn't find out 24 where she was. And then from there on, she was out 25 of the picture. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 13 of 35 Page 93 1 Q. Do you recall how long after the New York 2 trip that occurred? 3 A. I would say it was probably within a month 4 or two. 5 Q. Did she tell you she was working 6 elsewhere? 7 A. No. 8 Q. Did you ask her? 9 A. No. 10 Q. Did she mention that she was a waitress? 11 A. No. 12 Q. And worked at Taco Bell? 13 A. Huh-huh. 14 Q. Did you speak to her boyfriend or a 15 boyfriend at any other time associated with her? 16 A. No. 17 Q. Did you meet her boyfriend? 18 A. No. 19 Q. Her fiancé? 20 A. No. 21 MS. McCAWLEY: Objection. 22 BY MS. MENNINGER: 23 Q. When you were on the plane with Jeffrey 24 during these two trips, he was present on all of 25 those flights? MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 14 of 35 Page 94 1 A. Yes. 2 Q. Did you observe any sexual behavior 3 happening on the plane? 4 A. No. He told me a story of something that 5 had happened one time. 6 Q. Did it involve Ghislaine Maxwell? 7 A. No. 8 Q. Did it involve Virginia Roberts? 9 A. No. 10 Q. And you didn't see anything? 11 A. No. 12 Q. You did give massages to Ghislaine 13 Maxwell, correct? 14 A. Yes. 15 Q. On how many occasions? 16 A. Maybe somewhere between five and 10. 17 Q. Was that over the course of the five 18 years? 19 A. Yes. 20 Q. Was there some point during that five 21 years where Ghislaine Maxwell was not around as 22 much? 23 A. Yes. 24 Q. Do you recall when that was? 25 A. In the middle. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 15 of 35 Page 95 1 Q. Did you know why that might be? 2 A. No. 3 Q. Is that about the time that you started 4 5 6 seeing A. - picture more. more frequently? Yeah, I guess she was probably in the Her and Sarah both had kind of been 7 around the most. 8 9 Q. Did you observe to act like Jeffrey's girlfriend?- or Sarah appearing 10 11 12 A. Q. A. - , not Sarah. What did you observe? She was just very loving, kissing him. 13 Q. Did you know how old she was? 14 A. I didn't know. 15 Q. So you gave massages to Ghislaine five or 16 10 times. Was there anything unusual about those 17 massages? 18 A. No. 19 Q. You've been quoted in the press perhaps as 20 saying that she wasn't very picky? 21 A. About massage? 22 Q. About her massages. 23 A. Not like Jeffrey, I guess. I mean, saying 24 that meant that, you know, I would do whatever I 25 wanted to do in the massage; whereas, Jeffrey was, MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 16 of 35 Page 96 1 like, Do my foot, do my leg. He would kind of 2 narrate what he wanted. She just wanted a massage. 3 So if that makes sense. 4 Q. She may have been naked under a towel -- 5 A. Definitely. 6 Q. -- in a regular massage fashion? 7 MS. McCAWLEY: Objection. 8 THE WITNESS: Yes. Actually, I do recall 9 an instance where I was massaging her and 10 Jeffrey came into the room and he did something 11 sort of sexual to her, whether it was fondling 12 her or slapping her butt or something, and she 13 brushed him off like she was embarrassed. 14 BY MS. MENNINGER: 15 Q. So she never asked you to touch her in a 16 sexual manner, correct? 17 A. No. 18 Q. And she did not rub her breasts on you, 19 for example? 20 A. No. 21 MS. McCAWLEY: Objection. 22 BY MS. MENNINGER: 23 Q. She did not demand that you perform oral 24 sex on her? 25 A. No. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 17 of 35 Page 97 1 Q. Did she did not demand that you undress 2 during your massages? 3 A. No. 4 Q. There was nothing from her that was sexual 5 during the massages that you gave to her? 6 MS. McCAWLEY: Objection. 7 THE WITNESS: Correct. 8 BY MS. McCAWLEY: 9 Q. Do you recall when the last time you gave 10 her a massage was? 11 A. I don't recall. 12 Q. Do you recall meeting with her in about 13 2006 when she was in town for some helicopter 14 training? 15 A. I do recall that. 16 Q. Do you recall giving her some massages 17 during that period? 18 A. Yes. 19 Q. Do you remember going out to dinner with 20 her and to a movie? 21 A. I remember to a movie, and I don't 22 remember if we went to dinner. I remember her 23 cooking dinner. That was another way she impressed 24 me: She knew how to cook like a chef. She had done 25 some culinary training. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 18 of 35 Page 98 1 Q. And you guys had a normal type 2 conversation? 3 A. Yes. It was very fun. 4 MS. McCAWLEY: Objection. 5 MS. MENNINGER: I would like to take about 6 a 5-, to 10-minute break, if that's okay. 7 THE VIDEOGRAPHER: Off the record at 8 11:05. 9 (Thereupon, a recess was taken, after 10 which the following proceedings were held:) 11 THE VIDEOGRAPHER: This is the beginning 12 of Disk 2. On the record at 11:25. 13 BY MS. MENNINGER: 14 Q. Hi. I believe when we left off I was 15 asking you about massages that you gave to 16 Ghislaine. 17 Did Ghislaine pay you when she got a 18 massage from you? 19 A. Yes. 20 Q. Do you know how much she paid you? 21 A. I believe it was 200. It was the going 22 rate. 23 Q. The same as you were getting paid by 24 Jeffrey, correct? 25 A. Yes. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 19 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 20 of 35 Page 102 1 reporter from the Mail on Sunday? 2 A. Yes. 3 Q. You told that reporter, I believe, that 4 the police report painted a picture that it was a 5 big orgy all the time, but it wasn't? 6 A. What I saw, I did not see anything out in 7 the open sexually. Me, personally. 8 Q. Right. You did not see orgies happening 9 in the pool, for example? 10 A. No. 11 Q. You did not see people engaging in sexual 12 conduct out in the open areas of the home, correct? 13 A. Right. 14 MS. McCAWLEY: Objection. 15 BY MS. MENNINGER: 16 Q. When you became aware of the allegations 17 against Jeffrey, those came as a surprise to you, 18 correct? 19 MS. McCAWLEY: Objection. 20 THE WITNESS: Correct. 21 BY MS. MENNINGER: 22 Q. And the surprise was that it involved 23 underaged girls making that allegation, correct? 24 MS. McCAWLEY: Objection. 25 THE WITNESS: Correct. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 21 of 35 Page 103 1 BY MS. MENNINGER: 2 Q. You were asked some questions with 3 Ms. McCawley about nude photographs that were 4 present in the home? Homes? 5 A. Uh-huh. 6 Q. In Palm Beach, I believe you said there 7 were some in the room where the massage table was? 8 A. Yes. 9 Q. Can you tell me what you recall seeing? 10 A. It wasn't candid photos. They were all, 11 like, staged. 12 Q. Like a model? 13 A. Yes. And my -- I don't recall necessarily 14 knowing any of the people in those photos. I 15 remember at one point there was a photo of myself, 16 but... 17 Q. Were they fully frontally nude or were 18 they staged, like, with, you know, parts of bodies 19 showing? 20 A. I really only remember topless photos. I 21 don't remember full frontal photos. 22 Q. So exposing the breasts, but not exposing 23 the genitalia? 24 A. Not that I recall. And Ghislaine's 25 bathroom, I believe there was a photo of her MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 22 of 35 Page 104 1 topless, or a painting. 2 Q. A painting? 3 A. Uh-huh. 4 Q. Did you see any nude or semi-clad photos 5 of young girls? 6 A. No. 7 Q. Preteens, for example? 8 A. No. 9 Q. Something you would consider child 10 pornography? 11 A. Never. 12 Q. Other than in the bathroom or the massage 13 room at the Palm Beach home, do you recall any other 14 place in the Palm Beach home where you saw any of 15 these topless photos of women? 16 A. I remember there being photos everywhere, 17 and the ones that stick out in my memory are the 18 ones -- there was a photo of Ghislaine with the 19 Pope. It would not surprise me if there were naked 20 photos around. I just didn't retain them in my 21 memory. 22 Q. So when you say there were photos 23 everywhere, you mean just photos in general? 24 A. Yes. They had a lot of photos around the 25 house. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 23 of 35 Page 105 1 MS. McCAWLEY: Objection. 2 BY MS. MENNINGER: 3 Q. And Ghislaine was not topless in a photo 4 with the Pope, just so I'm clear? 5 A. Correct. 6 Q. I just want to make sure we get that 7 record really clear. 8 So you recall there being photos 9 everywhere; you just remember a couple sticking out 10 in your brain as being topless? 11 A. Yes. 12 Q. And the walls on the staircase to the 13 upstairs were not just covered with nude 14 photographs, to your recollection? 15 A. To my recollection, I just -- I don't 16 remember. 17 Q. Did you observe what you would consider to 18 be child pornography on any computer in the home? 19 A. No. 20 Q. Did you observe anyone taking photographs 21 of young girls in the home? 22 A. No. 23 Q. The photograph of yourself that you saw, 24 was that something that you had posed for? 25 A. Not, like, professionally. But I was just MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 24 of 35 Page 106 1 sitting, and I believe Jeffrey took the photo. I 2 was just sitting on a couch upstairs in the 3 bathroom. 4 Q. It wasn't taken by a hidden camera? 5 A. No. No. I was smiling in the picture. 6 Q. And, likewise, in the New York home, did 7 you see anything -- you described a large painting 8 or a photograph that was in the massage room? 9 A. Yes. 10 Q. Do you recall any other photos of 11 semi-clad or naked females? 12 A. I don't recall. 13 Q. Anything that you would consider to be 14 child pornography that you saw in the New York home? 15 A. No. 16 Q. And, likewise, in New Mexico? 17 A. I don't recall. 18 Q. Do you recall seeing any semi-clad photos 19 in New Mexico at all? 20 A. I do not recall. 21 Q. And the Virgin Islands? 22 A. Yes, in his bathroom, master bathroom. 23 Q. And what do you recall, if anything, about 24 that photo? 25 A. There was a photo of me in there. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 25 of 35 Page 112 1 A. Right. 2 Q. And an increase corresponding to massages 3 you were giving to guests, correct? 4 A. Yes. 5 Q. Did any of the guests for whom you gave a 6 massage mention that they expected something sexual? 7 A. No. 8 Q. Did they ask you to engage in sexual 9 contact and you refused? 10 MS. McCAWLEY: Objection. 11 THE WITNESS: No. 12 BY MS. MENNINGER: 13 Q. Marvin Minsky? 14 A. I don't know that. 15 Q. George Lucas? 16 A. No. 17 Q. Donald Trump? 18 A. No. 19 Q. Did you ever massage Donald Trump? 20 A. No. 21 Q. Sorry, I have to ask, but did you ever 22 have sex with Alan Dershowitz in the back of a 23 limousine with Virginia and Jeffrey present? 24 MS. McCAWLEY: Objection. 25 THE WITNESS: Absolutely not. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 26 of 35 Page 113 1 BY MS. MENNINGER: 2 Q. Do you know who Alan Dershowitz is? 3 A. I do. 4 Q. You would remember -- 5 A. I would remember that. 6 Q. Did you ever see Virginia Roberts with any 7 of the people that I just asked you about? 8 A. No. 9 Q. Did Virginia ever talk to you about having 10 been with any of those people? 11 MS. McCAWLEY: Objection. 12 THE WITNESS: No. 13 BY MS. MENNINGER: 14 Q. Did she tell you that she had met any of 15 those people? 16 A. No. 17 Q. I believe you saw in that police report a 18 reference to a friend of Jeffrey named Glenn and his 19 wife? 20 A. Uh-huh. 21 Q. Do you remember them? 22 A. Vaguely. 23 Q. Tell me what you remember. 24 A. I remember they had an apartment in -- on 25 Breakers Row. I went up there and massaged. It may MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 27 of 35 Page 114 1 have been more than once, but I only really remember 2 one time. But there was nothing sexual. 3 Q. Neither with the wife, nor with Glenn? 4 A. Right. 5 Q. Do you remember the apartment? 6 A. I only remember that I had to carry my 7 massage table up some stairs. 8 Q. So you actually gave the massage on a 9 massage table? 10 A. Yes. 11 Q. Does that help you place it in time as to 12 when that might have occurred? In other words -- 13 A. Well -- 14 Q. -- did you get your massage license at 15 some point and a massage table? 16 MS. McCAWLEY: Objection. 17 THE WITNESS: Yes. He bought me my 18 massage table around the time that I went to 19 massage school. So it could have been any time 20 after. If I thought really hard, I could 21 remember when I went to school. But it -- I 22 want to say it's around 2003. 23 BY MS. MENNINGER: 24 Q. Nothing sexual happened with Glenn? 25 A. No. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 28 of 35 Page 115 1 Q. Did Glenn ask you to give him a massage on 2 the floor of the home? 3 A. I don't recall. 4 Q. Did you ever discuss Glenn with Virginia? 5 A. Not to my recollection. 6 Q. Did you ever go to Virginia's home? 7 A. No. 8 Q. Do you know where she lived? 9 A. No. 10 Q. Did she talk about it? 11 A. Not that I remember. 12 Q. Did you see anything in your interactions 13 with Virginia that led you to believe that she was a 14 sex slave? 15 MS. McCAWLEY: Objection. 16 THE WITNESS: No. 17 BY MS. MENNINGER: 18 Q. Did you see anyone forcing her to remain 19 in the home? 20 A. No. 21 Q. Did you see her look traumatized at some 22 point? 23 MS. McCAWLEY: Objection. 24 THE WITNESS: No. 25 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 29 of 35 Page 116 1 BY MS. MENNINGER: 2 Q. Did you see anything that led you to 3 believe Virginia Roberts had been trafficked, 4 sexually trafficked to third parties? 5 MS. McCAWLEY: Objection. 6 THE WITNESS: No. 7 BY MS. MENNINGER: 8 Q. Did Virginia ever tell you that she had 9 been trafficked? 10 A. No. 11 MS. McCAWLEY: Objection. 12 BY MS. MENNINGER: 13 Q. Did you hear anyone direct Virginia 14 Roberts to go have sex with someone? 15 A. No. 16 Q. Did Jeffrey ever ask you to go have sex 17 with another person? 18 A. No. 19 Q. Did Ghislaine Maxwell ever ask you to go 20 have sex with another person? 21 A. No. 22 Q. Did Ghislaine Maxwell ever ask you to give 23 a massage to someone else? 24 A. No. 25 Q. Did Ghislaine Maxwell ever ask you to MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 30 of 35 Page 120 1 Q. Okay. That's fine. 2 A. Yeah, sure. 3 Q. If it doesn't, it doesn't. I'm just 4 asking. 5 Did Virginia say anything to you about 6 having met Prince Andrew before this time in New 7 York? 8 MS. McCAWLEY: Objection. 9 THE WITNESS: She did not say. 10 BY MS. MENNINGER: 11 Q. Did Prince Andrew say or do anything that 12 led you to believe that he had met Virginia prior to 13 that time? 14 A. I don't recall. 15 Q. Did you ever see Al Gore on the island? 16 A. No. 17 Q. Did you see his wife, Tipper Gore, on the 18 island? 19 A. No. 20 Q. What is your understanding of what the 21 lawsuit we are here today is about? 22 A. I understand that Ghislaine is calling 23 Virginia a liar, and so Ghislaine is suing Virginia. 24 I'm sorry. Strike that. Reverse it. 25 Right, Virginia is suing Ghislaine for MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 31 of 35 Page 141 1 always covered himself with a towel. 2 Q. I believe I asked this, but I just want to 3 clarify to make sure that I did: Did Maxwell ever 4 ask you to bring other girls over to -- for Jeffrey? 5 A. Yes. 6 Q. Yes? 7 A. Yes. 8 Q. And what did you -- did you do anything in 9 response to that? 10 A. I did bring one girl named Jane Doe 2 -- 11 no. Jane Doe 2 -- it was some girl named Jane Doe 2 12 that I had worked with at a restaurant. And I 13 recall Ghislaine giving me money to bring her over; 14 however, they never called her to come. 15 Q. And then I believe you mentioned that one 16 of your physical fitness instructors, you brought a 17 physical fitness instructor; was that correct? 18 A. Correct. 19 Q. And what did she do? 20 A. She gave him a -- like a training session, 21 twice. 22 Q. Twice. 23 Did anything sexual in nature happen 24 during the session? 25 A. At one point he lifted up her shirt and MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 32 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 33 of 35 Page 147 1 expected to have sexual intercourse with Jeffrey? 2 A. Yes. 3 Q. And when was that? 4 A. 2005. 5 MS. McCAWLEY: That's it. I just do want 6 to also put on the record that we're 7 designating the testimony as confidential under 8 the protective order. 9 F U R T H E R E X A M I N A T I O N 10 BY MS. MENNINGER: 11 Q. Okay. You just testified that you have 12 knowledge -- you had knowledge that -- of what 13 Jeffrey was doing behind closed doors with other 14 girls. Was that your testimony? 15 A. Based on what he had told me. 16 Q. Okay. So Jeffrey told you things that he 17 had done with other girls? 18 A. Yes. 19 Q. You did not observe any of those things? 20 A. No. 21 Q. You did not talk to any of those girls 22 about what they had done with Jeffrey behind closed 23 doors? 24 MS. McCAWLEY: Objection. 25 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 34 of 35 Page 152 1 Q. When I say "girl," I really mean women, 2 correct? 3 A. Correct. 4 Q. There were other women around who hung out 5 with Jeffrey, and you don't know what they did 6 behind closed doors, correct? 7 A. Correct. 8 Q. So when you heard the implication that she 9 wanted other girls around to take the pressure off 10 of her sexually, in your mind that meant other adult 11 women that he had in his life, correct? 12 MS. McCAWLEY: Objection. 13 THE WITNESS: Correct, doing what I was 14 expected to do in a massage, you know. 15 BY MS. MENNINGER: 16 Q. Ghislaine didn't have anything to do with 17 you bringing this woman over for a physical workout 18 with Jeffrey, correct? 19 A. Correct. 20 Q. She asked you to bring another girl to 21 be -- to perform massages at the home? 22 A. Yes. Well, she was always asking if I 23 knew anyone else. And so I brought this one girl 24 that I didn't even know I worked with her at a 25 restaurant. So I didn't care what she thought of me MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-29 Filed 01/05/24 Page 35 of 35 Page 153 1 if anything happened. And so -- but it never turned 2 into anything. 3 Q. She was an adult? 4 A. She was an adult. 5 Q. Working at a restaurant with you? 6 A. Yes. 7 Q. What restaurant was that? 8 A. It's a restaurant that's closed. It's 9 called BD's Mongolian Barbecue. 10 Q. You were asked about the famous people. 11 You said you met Michael Jackson? 12 A. Yes. 13 Q. But you did not give him a massage? 14 A. No. 15 Q. There were other famous people, perhaps, 16 who were around Jeffrey's home that you didn't meet, 17 correct? 18 A. Correct. 19 Q. Do you know whether Virginia Roberts has 20 told the truth about the age she was when she met 21 Ghislaine Maxwell? 22 MS. McCAWLEY: Objection. Exceeds the 23 scope of cross. 24 THE WITNESS: I don't have any idea what 25 she told them in terms of her age. MAGNA9 LEGAL SERVICES