gov.uscourts.nysd.447706.1328.37.pdf

Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 1 of 11 EXHIBIT D Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 2 of 11 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. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 3 of 11 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. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 4 of 11 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 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 5 of 11 Page 49 1 (The referred-to document was marked by 2 the court reporter for Identification as 3 Sjoberg Exhibit 4.) 4 BY MS. McCAWLEY: 5 Q. I'm just going to ask that you take a look 6 at that. As you can see, under the narrative line 7 there, there is a name. It says, "Reported by 8 Recarey, Joseph." Is that a name you recall meeting 9 with, a Detective Recarey? 10 A. Yes. I mean, I don't recall his name, 11 only except that he had been following me around, 12 and he left me cards, like, on my car and in my 13 door. I tried to avoid him for a long time. 14 Q. And can you just look at the text 15 underneath there? 16 A. Uh-huh. 17 Q. Take a moment to look at that. 18 A. Sure. 19 Q. Does that refresh your recollection as to 20 what you told the police during the investigation? 21 A. There are errors in here. I was not 23 22 when I met him. I was 21. 23 Q. Anything else that doesn't look correct? 24 A. The same error: That I had met him three 25 years ago, and it obviously had been closer to five. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 6 of 11 Page 50 1 There is also the error, he obviously 2 misunderstood me: He did not pay for my tuition at 3 college. I'm still paying those school loans. But 4 he did pay for me to go to massage school and to 5 cosmetology school. 6 Okay. It pretty much ends here. 7 Q. Yes. Right. About halfway through the 8 page. 9 A. Okay. 10 MS. McCAWLEY: So, Johanna, that concludes 11 my initial piece. I'm going to reserve the 12 rest of my time for redirect. I'm going to 13 turn it over to Laura. 14 MS. MENNINGER: Can we take just a little 15 break? 16 MS. McCAWLEY: Sure, no problem. 17 THE VIDEOGRAPHER: Off the record at 18 10:05. 19 (Thereupon, a recess was taken, after 20 which the following proceedings were held:) 21 THE VIDEOGRAPHER: On the record at 10:14. 22 E X A M I N A T I O N 23 BY MS. MENNINGER: 24 Q. Hi. 25 A. Hello. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 7 of 11 Page 51 1 Q. We've never met before today, correct? 2 A. Correct. 3 Q. Can you tell me a little bit about your 4 current job? 5 A. Sure. I just purchased a salon. I'm a 6 salon owner. I'm a hairstylist. 7 Q. Congratulations. 8 A. Thank you. 9 Q. How long have you been a hairstylist? 10 A. For 10 years. 11 Q. And what did you do before that? 12 A. I briefly did massage in a spa for about a 13 year and a half. And before that I was a nanny, and 14 before that I was in school. 15 Q. And I believe you said you studied 16 psychology in school? 17 A. Correct. 18 Q. Did you graduate? 19 A. Yes. 20 Q. With a degree in psychology? 21 A. Yes. 22 Q. Where did you get training to be a massage 23 therapist? 24 A. A school called Palm Beach Academy of 25 Health and Beauty in Lake Park, Florida. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 8 of 11 Page 52 1 Q. And when did do you that? 2 A. That would have been, I believe, in 2003. 3 Q. And how long did you study there? 4 A. I think it was a six-month program. 5 Q. And you worked in a spa thereafter? 6 A. I did. 7 Q. What was the name of the spa again? 8 A. The Lane Spa in Palm Beach Gardens. 9 Q. And are you married? 10 A. No. 11 Q. Do you have children? 12 A. No. 13 Q. And how old are you now? 14 A. Thirty-six. 15 Q. Can you tell me about your first meeting 16 with Ghislaine Maxwell? 17 A. Sure. I was sitting on a bench Jane Doe 2 ■ She approached me. 19 I was getting ready to go to a class. It was my 20 junior year. Yes, it was the second semester of my 21 junior year. And she and another woman approached 22 me. The other woman didn't speak that I recall. 23 And she asked me about -- she had a house 24 in Palm Beach, and she was looking for someone that 25 she could hire to work at the house, where she could MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 9 of 11 Page 99 1 Q. Ghislaine was not present when you were 2 giving massages to Jeffrey, correct? 3 MS. McCAWLEY: Objection. 4 THE WITNESS: Correct. 5 BY MS. MENNINGER: 6 Q. At some point Jeffrey became more 7 aggressive with you, correct? 8 A. Correct. 9 MS. McCAWLEY: Objection. 10 BY MS. MENNINGER: 11 Q. At what point was that? 12 A. In the last year. 13 Q. And what does that mean to you, "became 14 more aggressive"? 15 A. He was pressuring me to do more than I was 16 comfortable with doing. 17 Q. Is that what ultimately caused you to 18 leave working for Jeffrey? 19 A. What caused me to leave was when it was 20 made public what I was doing. 21 Q. What do you mean by that? 22 A. Well, after I had spoken with the police 23 report -- the police and there was a police report, 24 I did not realize that was public knowledge, 25 journalists would get a hold of. So at one point MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-37 Filed 01/05/24 Page 10 of 11 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 1328-37 Filed 01/05/24 Page 11 of 11 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