gov.uscourts.nysd.447706.1331.23.pdf

Case 1:15-cv-07433-LAP Document 1331-23 Filed 01/05/24 Page 1 of 4 EXHIBIT 3 (File Under Seal) Case 1:15-cv-07433-LAP Document 1331-23 Filed 01/05/24 Page 2 of 4 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-23 Filed 01/05/24 Page 3 of 4 Page 201 1 G Maxwell - Confidential 2 underage? 3 A. I can only testify to what I saw 4 and what I was present for, so if you are 5 asking me what I saw then I am happy to 6 testify. I cannot testify to what somebody 7 else did or didn't do. 8 Q. Did you issue a statement to your 9 press agent, Ross Gow in 2015, stating that 10 Virginia Roberts' claims were, quote, obvious 11 lies? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 Q. You can answer. 15 A. You need to reask me the question. 16 Q. Sure. 17 Did you issue a press statement 18 through your press agent, Ross Gow, in 19 January of 2015, stating that Virginia 20 Roberts' claims were, quote, obvious lies? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. Can you ask it a different way, 24 please? 25 Q. I will ask it again and you can MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-23 Filed 01/05/24 Page 4 of 4 Page 202 1 G Maxwell - Confidential 2 listen carefully. 3 Did you issue a press statement 4 through your press agent, Ross Gow, in 5 January of 2015, where you stated that 6 Virginia Roberts' claims were, quote, obvious 7 lies? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. So my lawyer, Philip Barden 11 instructed Ross Gow to issue a statement. 12 Q. Today, did you say that Virginia 13 lied about, quote, absolutely everything? 14 A. I said that there are some things 15 she may not have lied about. 16 Q. So are you saying it's an obvious 17 lie that Jeffrey Epstein engaged in sexual 18 contact with Virginia while Virginia was 19 underage? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Can you ask the question again, 23 please? 24 Q. Are you saying it's an obvious lie 25 that Jeffrey Epstein engaged in sexual MAGNA& LEGAL SERVICES