9# Epstein and related persons lawsuits(Trump included - 16# Virginia Roberts Guiffre 2019.pdf

Case 18-2868, Document 286, 08/09/2019, 2628248, Page1 of 55 EXHIBIT NN  Case 18-2868, Document 286, 08/09/2019, 2628248, Page2 of 55 United States District Court Southern District Of New York --------------------------------------------------X ............................................... Virginia L. Giuffre, Plaintiff, v. 15-cv-07433-RWS Ghislaine Maxwell, Defendant. -----------------------------------------------X DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following disclosures: I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH PARTICULARITY IN THE PLEADINGS 1. Ghislaine Maxwell c/o Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave. Denver, CO 80203 303-831-7364 [email protected] Ms. Maxwell is the Defendant and may have knowledge concerning matters at issue, including the events of 1999-2002 and the publication of statements in the press in 2011-2015. 2. Virginia Lee Roberts Giuffre c/o Sigrid S. McCawley, Esq. Boies, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Case 18-2868, Document 286, 08/09/2019, 2628248, Page3 of 55 Miami, Florida 33301 (954) 356-0011 [email protected] Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue in her Complaint, including the events of 1996-2015 and the publication of statements in the press in 2011-2015. 3. Philip Barden Devonshires Solicitors LLP 30 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square (020) 7628-7576 [email protected] Mr. Barden has knowledge concerning press statements by Plaintiff and Defendant in 2011-2015 at issue in this matter. 4. Paul Cassell College of Law, University of Utah 383 South University Street Salt Lake City, UT 84112 801-585-5202 [email protected] Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff’s court pleadings, and Plaintiff’s sworn testimony. 5. Alan Dershowitz c/o Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 (202) 719-7000 Mr. Dershowitz has knowledge concerning Plaintiff’s false statements to the press, in court pleadings, and in sworn testimony, at issue in this matter. 6. Bradley Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301 (954) 524-2820 [email protected] 2  Case 18-2868, Document 286, 08/09/2019, 2628248, Page4 of 55 Dated: February 24, 2016. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 [email protected] Attorney for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on February 24, 2016, I electronically served this DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the following: Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] s/ Laura A. Menninger Laura A. Menninger 7 Case 18-2868, Document 286, 08/09/2019, 2628248, Page5 of 55 Case 18-2868, Document 286, 08/09/2019, 2628248, Page6 of 55 Case 18-2868, Document 286, 08/09/2019, 2628248, Page7 of 55 Case 18-2868, Document 286, 08/09/2019, 2628248, Page8 of 55 Case 18-2868, Document 286, 08/09/2019, 2628248, Page9 of 55 Case 18-2868, Document 286, 08/09/2019, 2628248, Page10 of 55 Case 18-2868, Document 286, 08/09/2019, 2628248, Page11 of 55 EXHIBIT PP  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page12 Inc. of 55 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II November 14, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Phone: 954.356.0011 [email protected] Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE VOLUME II 11/14/2016 348  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page13 Inc. of 55 1 APPEARANCES: (Continued) 2 HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. 3 Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue 4 Denver, CO 80203 Phone: 303.831.7364 5 [email protected] [email protected] 6 Appearing on behalf of the Defendant 7 Also Present: 8 Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 349  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page14 Inc. of 55 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the continued video 3 deposition of VIRGINIA GIUFFRE, called by Defendant, 4 was taken on Monday, November 14, 2016, commencing at 5 8:04 a.m., at 150 East 10th Avenue, Denver, Colorado, 6 before Pamela J. Hansen, Registered Professional 7 Reporter, Certified Realtime Reporter and Notary 8 Public within Colorado. 9 * * * * * * * 10 I N D E X 11 VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II 12 EXAMINATION PAGE 13 By Ms. Menninger 354 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 350  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page15 Inc. of 55 1 INDEX OF EXHIBITS (continued) 2 INITIAL 3 DESCRIPTION REFERENCE 4 Exhibit 1 Settlement Agreement and General 355 Release 5 Exhibit 2 List of names 370 6 Exhibit 3 Photocopy of photograph 408 7 Exhibit 4 Photocopy of photograph, with 411 8 attachments 9 Exhibit 5 Photocopy of photograph, with 417 attachments 10 Exhibit 6 Photocopy of photograph, with 423 11 attachments 12 Exhibit 7 Statements 437 13 Exhibit 8 History of education, with 462 attachment 14 Exhibit 9 Application for Employment, 474 15 with attachment 16 Exhibit 10 The Great Outdoors Community 481 Services Association, Inc. 17 Termination Form, with attachments 18 Exhibit 11 7/6/2016 letter to Schultz 484 19 from Hayek, with attachments 20 Exhibit 12 Patient Registration 490 Information, with attachments 21 Exhibit 13 CVS Prescription Records 502 22 document, 7/29/2016, with attachment 23 Exhibit 14 Affidavit of Custodian of 507 24 Records, Walgreen Company, with attachments 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 351  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page16 Inc. of 55 1 INITIAL DESCRIPTION REFERENCE 2 Exhibit 15 Patient Health Summary, Clifton 512 3 Beach Medical & Surgical, printed on 6/28/2016 4 Exhibit 16 Portions of deposition transcript 533 5 of Virginia Giuffre taken May 3, 2016 6 Exhibit 17 Amendment/Errata Sheet signed 540 7 May 31, 2016 by Virginia Giuffre 8 Exhibit 18 Ad for Mar-a-Lago Club 548 9 Exhibit 19 The Mar-a-Lago Club, L.C. 549 Employment Policies, October 28, 10 1995 11 Exhibit 20 Page from the Mar-a-Lago Club 550 Employment Policies, Revised 12 10/2001 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 352  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page17 Inc. of 55 1 didn't see them take pictures of the backs of them. 2 I'm not too sure who. 3 Q You don't remember sending to them a 4 photograph that included this wood around another 5 photograph? 6 A No. 7 Q Okay. You have mentioned a journalist by 8 the name of Sharon Churcher. 9 A Yes. 10 Q You are aware that Sharon Churcher 11 published news stories about you? 12 A Yes. 13 MS. MCCAWLEY: Objection. 14 Go ahead. 15 Q (BY MS. MENNINGER) Is anything that you 16 have read in Sharon Churcher's news stories about you 17 untrue? 18 A I think Sharon did print some things that 19 I think she elaborated or maybe misheard. But, I 20 mean, if you have a specific document to show me, I'd 21 love to look at it and read it and tell you what I 22 think. 23 Q Is there anything, as you sit here today, 24 that you know of that Sharon Churcher printed about 25 you that is not true? VIRGINIA GIUFFRE VOLUME II 11/14/2016 435  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page18 Inc. of 55 1 A Not off the top of my head. If you show 2 me, like, a news clipping article or something, I can 3 definitely read it for you. 4 Q Is there anything that you know of that 5 Sharon Churcher has printed about Ghislaine Maxwell 6 that is not true? 7 A No, not off -- no, not off the top of my 8 head. 9 Q Is there anything that you recall saying 10 to Sharon Churcher that she then printed something 11 different than what you had said to her? 12 A Yeah, I've read stuff. I mean, I just -- 13 I can't remember what, but I read something that I 14 think was, Oh, she got that wrong. I can't remember 15 an exact example off the top of my head. 16 Q Did you ever complain to Sharon Churcher 17 about things that she got wrong? 18 A I didn't see a point. I might have, but 19 I -- I didn't see a point really because it's already 20 printed, you know. 21 Q You had a fairly voluminous set of 22 communications with Sharon Churcher by e-mail, 23 correct? 24 MS. MCCAWLEY: Objection. 25 A Voluminous, like a lot of them? VIRGINIA GIUFFRE VOLUME II 11/14/2016 436  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page19 Inc. of 55 1 Q (BY MS. MENNINGER) Yes. 2 A Yes. 3 Q And during any of those communications, do 4 you know whether she printed things about you after 5 you had any of those communications? 6 MS. MCCAWLEY: Objection. 7 A I don't know. I know a lot of stuff was 8 printed, and I never really stopped to read who 9 printed the article, or wrote the article, I should 10 say. Sorry. 11 Q (BY MS. MENNINGER) Okay. I'll show you 12 Defendant's Exhibit 7. 13 (Exhibit 7 marked.) 14 THE DEPONENT: Thank you. 15 Q (BY MS. MENNINGER) I'll let you read 16 through the statements on the first page there, and 17 if there is anything that is not absolutely true, 18 just put a check by it and we'll come back to it. 19 A It's not very clear how she wrote it. "I 20 flew to the Caribbean with Jeffrey and then Ghislaine 21 Maxwell went to pick up Bill in a huge black 22 helicopter that Jeffrey had bought her." 23 That wasn't an eyewitness statement. 24 Like, I didn't see her do it. Ghislaine was the one 25 who told me about that; that she's the one who flew VIRGINIA GIUFFRE VOLUME II 11/14/2016 437  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page20 Inc. of 55 1 Bill. 2 Q All right. If you just want to put a 3 check by it, then we'll just come back and talk about 4 each one. 5 A Okay. 6 Q Just to move things along. 7 A Okay. I have made three checkmarks. 8 Q All right. 9 MS. MCCAWLEY: And I just -- before you 10 continue, I just want to identify for the record, 11 since this doesn't have any identifiers on it, are 12 you representing that these are statements from 13 Sharon Churcher? 14 MS. MENNINGER: I'm not representing 15 anything. I'm asking the witness questions about 16 these statements. I asked her is anything on here 17 not true. That's all I asked her. 18 Q (BY MS. MENNINGER) So which ones did you 19 put checkmarks by, Ms. Giuffre? 20 A I'd have been -- I'm sorry. "I'd have 21 been about 17 at the time. I flew to the Caribbean 22 with Jeffrey and then Ghislaine Maxwell went to pick 23 up Bill in a huge black helicopter that Jeffrey had 24 bought her." 25 Q Okay. And what else did you put a check VIRGINIA GIUFFRE VOLUME II 11/14/2016 438  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page21 Inc. of 55 1 by? 2 A "I used to get frightened flying with her 3 but Bill had the Secret Service with him and I 4 remember him talking about what a good job" -- 5 sorry -- "job she did." 6 Q Okay. And what else did you put a check 7 by? 8 A "Donald Trump was also a good friend of 9 Jeffrey's. He didn't partake in any sex with any of 10 us but he flirted with me. He'd laugh and tell 11 Jeffrey, 'you've got the life.'" 12 Q Other than the three you've just 13 mentioned -- 14 A Yeah. 15 Q -- everything else on here is absolutely 16 accurate? 17 MS. MCCAWLEY: Objection. 18 A Yes. Well, to the best of my 19 recollection, yes. 20 Q (BY MS. MENNINGER) All right. What is 21 inaccurate about, "I'd have been about 17 at the 22 time. I flew to the Caribbean with Jeffrey and then 23 Ghislaine Maxwell went to pick up Bill in a huge 24 black helicopter that Jeffrey had bought her"? 25 A Because it makes it kind of sound like an VIRGINIA GIUFFRE VOLUME II 11/14/2016 439  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page22 Inc. of 55 1 eyewitness thing. 2 Q Okay. Did you say that statement to 3 Sharon Churcher? 4 A I said to Sharon that Ghislaine told me 5 that she flew Bill in the heli- -- the black 6 helicopter that Jeffrey bought her, and I just wanted 7 to clarify that I didn't actually see her do that. I 8 heard from Ghislaine that she did that. 9 Q You heard that from Ghislaine, and then 10 you reported to Sharon Churcher that you had heard 11 that from Ghislaine. 12 A Correct. 13 MS. MCCAWLEY: Objection. 14 A I heard a lot of things from Ghislaine 15 that sounded too true -- too outrageous to be true, 16 but you never knew what to believe, so... 17 Q (BY MS. MENNINGER) Okay. And after 18 Sharon Churcher printed what she said you said, did 19 you complain to her that it was inaccurate? 20 A I might have verbally with her, but again, 21 I didn't see a point in making a hissy over it 22 because what was done was done. She had already 23 printed. 24 Q What was inaccurate about, "I used to get 25 frightened flying with her but Bill" said -- "had the VIRGINIA GIUFFRE VOLUME II 11/14/2016 440  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page23 Inc. of 55 1 Secret Service with him and I remember him talking 2 about what a good job she did"? 3 A I just don't remember saying that to her. 4 I don't remember saying I remember him talking about 5 what a good job she did. 6 Q All right. 7 A I just don't remember that at all. 8 Q Okay. And I guess, just to be clear, my 9 questions wasn't do you remember saying this to 10 Sharon Churcher; my question is, is that statement 11 accurate? 12 MS. MCCAWLEY: Well, objection. 13 Q (BY MS. MENNINGER) Did you used to get 14 frightened flying with her? 15 A Yes. 16 Q Okay. Did Bill have the Secret Service 17 with him? 18 A They were there, but not like on the -- 19 not where we were eating. 20 Q Do you remember Bill talking about what a 21 good job she did? 22 A I don't remember that. 23 Q So what is inaccurate about that 24 statement? 25 A I just -- it's inaccurate because I don't VIRGINIA GIUFFRE VOLUME II 11/14/2016 441  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page24 Inc. of 55 1 remember him talking about what a good job she did. 2 I don't remember that. 3 Q Does it inaccurately suggest that Bill had 4 the Secret Service with him on a helicopter? 5 MS. MCCAWLEY: Objection. 6 A Well, not being an eyewitness to it, I 7 wouldn't be able to tell you. I can't tell you what 8 I don't know. 9 Q (BY MS. MENNINGER) And do you believe you 10 said that statement to Sharon Churcher? 11 A I mean, Sharon and I talked a lot, and if 12 she misheard me or just wrote it in the way that she 13 thought she should, I have no control over that. So 14 I'm not too sure. 15 Q Did she record your interviews? 16 A Some of them. Some of them she didn't. I 17 mean, we, like -- we, like, met for like a week, and 18 we spent a lot of time together, and then even after 19 that we just continued, like, kind of a friendship. 20 Q All right. What's inaccurate about the 21 last statement on that page? 22 A "Donald Trump was also a good friend of 23 Jeffrey's." That part is true. 24 "He didn't partake in any" of -- "any sex 25 with any of us but he flirted with me." It's true VIRGINIA GIUFFRE VOLUME II 11/14/2016 442  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page25 Inc. of 55 1 that he didn't partake in any sex with us, and but 2 it's not true that he flirted with me. Donald Trump 3 never flirted with me. 4 Then the next sentence is, "He'd laugh and 5 tell Jeffrey, 'you've got the life.'" I never said 6 that to her. 7 Q When you say, "he didn't partake in any 8 sex with any of us," who is "us"? 9 A Girls. Just -- 10 Q How do you know who Donald Trump -- Trump 11 had sex with? 12 A Oh, I didn't physically see him have sex 13 with any of the girls, so I can't say who he had sex 14 with in his whole life or not, but I just know it 15 wasn't with me when I was with other girls. 16 Q And who were the other girls that you were 17 with in Donald Trump's presence? 18 A None. There -- I worked for Donald Trump, 19 and I've met him probably a few times. 20 Q When have you met him? 21 A At Mar-a-Lago. My dad and him, I wouldn't 22 say they were friends, but my dad knew him and they 23 would talk all the time -- well, not all the time but 24 when they saw each other. 25 Q Have you ever been in Donald Trump and VIRGINIA GIUFFRE VOLUME II 11/14/2016 443  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page26 Inc. of 55 1 Jeffrey Epstein's presence with one another? 2 A No. 3 Q What is the basis for your statement that 4 Donald Trump is a good friend of Jeffrey's? 5 A Jeffrey told me that Donald Trump is a 6 good friend of his. 7 Q But you never observed them together? 8 A No, not that I can actually remember. I 9 mean, not off the top of my head, no. 10 Q When did Donald Trump flirt with you? 11 A He didn't. That's what's inaccurate. 12 Q Did you ever see Donald Trump at Jeffrey's 13 home? 14 A Not that I can remember. 15 Q On his island? 16 A No, not that I can remember. 17 Q In New Mexico? 18 A No, not that I can remember. 19 Q In New York? 20 A Not that I can remember. 21 Q All right. If you could turn to the 22 second page and read through those. Let me know if 23 any of those are inaccurate. Just put a check by 24 them and then we'll come back. 25 A Okay. VIRGINIA GIUFFRE VOLUME II 11/14/2016 444  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page27 Inc. of 55 1 MS. MCCAWLEY: Before you go, Virginia, 2 I'm going to object to the use of the second page of 3 this document. There's no time frame on it. There's 4 no source reference to it, so it's entirely unclear 5 where this has come from. 6 Q (BY MS. MENNINGER) Okay. Are you done? 7 A Yes. 8 Q Okay. What's the first one you've put a 9 check by? 10 A "The hammock photo was all over the 11 houses," in parentheses. And Bill Clinton and -- I'm 12 sorry, "Bill Clinton and Andrew," in parentheses, 13 "had to have seen it." 14 "All over the houses" is not my statement 15 and an exaggeration. They did have that picture in 16 the houses. And I believe, if I remember the 17 conversation correctly, she asked, Could have Bill 18 Clinton and Andrew seen the picture? And I said, 19 Yes, it's possible that they could have seen it. 20 So, I mean, it's just that -- it's not 21 that it's totally inaccurate. I just think it's like 22 journalist writing, had to have seen it. It doesn't 23 mean they saw it. I just think that if it was in 24 front of them, they would have seen it. 25 Q So she told you that -- you told her that VIRGINIA GIUFFRE VOLUME II 11/14/2016 445  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page28 Inc. of 55 1 the photograph was in the houses -- houses? 2 A Yes. I know he had it in New York on his 3 desk. I know he had it in Palm Beach. I know he had 4 it in the Caribbean. And I don't know if he had it 5 in New Mexico. I can't remember New Mexico. Maybe. 6 Q Where in Palm Beach was the photograph? 7 A The massage room. 8 Q Was that -- you did not say that they -- 9 it was all over the houses? 10 A Correct. All over the houses would imply 11 that it's everywhere in the house, so... 12 Q You did not say that Andrew and Clinton 13 had to have seen the photograph? 14 A Correct. I -- it was more of a, if they 15 were in front of it, they would have seen it, kind of 16 a thing. I'm not saying it right. But it wasn't, 17 like, had to have seen it. 18 Q All right. What's the next statement that 19 you put a check by? 20 A I'm sorry, excuse me. My kids shared a 21 beautiful cough with me again. 22 "I spent four years as a millionaire's 23 personal masseuse." 24 Q What is inaccurate about that statement? 25 A We now know, according to the timelines VIRGINIA GIUFFRE VOLUME II 11/14/2016 446  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page29 Inc. of 55 1 that Mar-a-Lago was able to provide for us, that it 2 was not four years. 3 Q How many years was it? 4 A More like 2-1/2, I think, if I'm right, or 5 two. I'm sorry, I'm really bad at math. But yes, 6 the two period. 7 Q What's the next statement that you have 8 put a check by? 9 A "I was a pedophile's dream." I think she 10 took that out of context and made that her own little 11 headline. 12 Q Did you say that to her? 13 A I said something along the line like, I -- 14 the -- the pedos loved me because I would do 15 everything that they wanted for them. But do I think 16 that -- yeah, I -- I know she made that line up 17 herself, the pedos -- pedophile's dream. 18 Q What's the next one you put a check by? 19 A I put a question mark next to the next 20 one. It says, "Three years later she was reunited 21 with her family." I don't know what that pertains 22 to. I don't know what timeline that means. 23 Q Was there a period of three years where 24 you were not with your family? 25 A There's been longer periods than that VIRGINIA GIUFFRE VOLUME II 11/14/2016 447  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page30 Inc. of 55 1 that -- when I wasn't with my family. That's what I 2 mean, I don't understand where that comes from. 3 "Three years later she was reunited with her family." 4 Q Prior to 2002, was there a period of three 5 years where you were not with your family? 6 A No. 7 Q Okay. Did you say to Sharon Churcher, 8 three years later, she was reunited with her family? 9 A That's what I don't understand. I don't 10 even know what that time periods pertains to. 11 Q Do you recall saying that to Sharon 12 Churcher? 13 A No. 14 Q What's the next one you put a check by? 15 A "After about two years he started to ask 16 me to entertain his friends." 17 Q What's wrong with that statement? 18 A It wasn't two years. I don't know where 19 she got that from. 20 Q Okay. How long was it? 21 A Like, I can't give you an exact time 22 period, but it wasn't right in the beginning. It was 23 after my training, or so to speak training. So, I 24 mean, my best guesstimate would be anywhere between 25 four to six months. VIRGINIA GIUFFRE VOLUME II 11/14/2016 448  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page31 Inc. of 55 1 Q So you did not say to Sharon Churcher, 2 "After about two years he asked me to entertain his 3 friends"? 4 A Correct. 5 Q What's the next one you put a check by? 6 A That's it. That's all I put a checkmark 7 next to. 8 Q So the rest of these are absolutely 9 accurate? 10 A Nothing a journalist writes is absolutely 11 accurate, but it's -- it sounds accurate, yes. 12 Q Do you recall Jeffrey Epstein saying to 13 you, "I've got a good friend and I need you to fly to 14 the island to entertain him, massage him and make him 15 feel how you make me feel"? 16 MS. MCCAWLEY: Objection. 17 Go ahead. 18 A I do remember him saying that, and I think 19 that's more of a general- -- generalization for all 20 the times that I was sent to the -- where is this -- 21 the island to entertain people. And that would be a 22 quote that she made but from my words saying that's 23 what he said to me when I had to go be with these 24 people that he sent me to. 25 Q (BY MS. MENNINGER) Did you say that VIRGINIA GIUFFRE VOLUME II 11/14/2016 449  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page32 Inc. of 55 1 sentence to her? 2 MS. MCCAWLEY: Objection. 3 A I -- I can't remember. Like I said, I 4 think it's more of a generalization. 5 Q (BY MS. MENNINGER) Did you meet Al Gore? 6 A Yes. 7 Q Did you meet Heidi Klum? 8 A Yes. 9 Q Did you meet Naomi Campbell? 10 A Yes. 11 Q Did you go on a six-week trip with Epstein 12 in 2001? 13 A Yeah. Yes. Sorry. 14 Q When in 2001 did you go on a six-week trip 15 with him? 16 A I don't remember exactly when it was, but 17 it's that -- it's the one where we went to Tangier, 18 Morocco, England. I can't remember where else we 19 went. France. 20 Q Did the FBI tell you that Epstein had 21 hidden cameras watching you the entire time, even 22 when you were in the bathroom? 23 A Yes. 24 Q Did the FBI tell you "Everything he did 25 was illegal because I was under age"? VIRGINIA GIUFFRE VOLUME II 11/14/2016 450  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page33 Inc. of 55 1 A Yes. 2 Q Who in the FBI told you that? 3 A Whichever agent I was talking to. 4 Q Which agent were you talking to? 5 A I can't remember. I know I was talking to 6 Jason Richards, and there was a girl, I think -- I 7 want -- I want to say her name was Christina Pryor, 8 just off the top of my head. And then I think there 9 was two other agents actually at the consulate 10 building. I don't remember their names. Very hazy. 11 Q When was this conversation with the FBI? 12 A After Sharon printed the articles, the 13 first articles that came out. I don't know how many 14 she printed, but when the first articles came out, 15 after that the FBI contacted me. 16 Q And was the statement that the FBI told 17 you "Everything he did was illegal because I was 18 under age," in response to you telling them that you 19 were age 15 when you met Jeffrey? 20 MS. MCCAWLEY: Objection. 21 A Well, that was the closest proximity I had 22 to go off of. 23 Q (BY MS. MENNINGER) Okay. 24 A So, yes. Although I still was under age, 25 I mean, even if I was 16 and 17. VIRGINIA GIUFFRE VOLUME II 11/14/2016 451  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page34 Inc. of 55 1 Q Okay. And then if you could do the last 2 page, same way; a check by anything that's not 3 absolutely accurate. 4 MS. MCCAWLEY: Okay. I'm going to object 5 to this as the last page has no identifier of time or 6 source on it. 7 A Okay. I'm ready. 8 Q (BY MS. MENNINGER) All right. Which ones 9 are inaccurate? 10 A The first one is, "Virginia got a 11 part-time job as a changing room assistant." I was a 12 full-time person there. Sorry. 13 Q Okay. So did you say that to Sharon? 14 A Again, I don't remember that exact 15 conversation, but I know it was a full-time job, 16 and -- I mean, full-time as in the, you know, the 9 17 to 5 or whatever hours it was, so it wasn't 18 part-time. I don't remember the exact conversation 19 that we had. 20 Q Okay. What's the next thing you put a 21 check by? 22 A I put a question mark next to, "Another 23 lady led me into Jeffrey's bedroom. The lady walked 24 me straight through into the massage room." 25 I have no idea what circumstance that VIRGINIA GIUFFRE VOLUME II 11/14/2016 452  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page35 Inc. of 55 1 pertains to. Again, I don't know what that means. I 2 don't even know what other lady she's talking about. 3 So... 4 Q So you don't recall saying that to Sharon 5 Churcher? 6 A Correct. I don't even know what it means. 7 Q Okay. What's the next one you have a 8 check by? 9 A "Afterwards, she was given two $100 bills 10 and told to return the next day. That was the 11 beginning of the four years she spent with Epstein." 12 Q All right. What's wrong about that 13 statement? 14 A Well, again, I just want to say that the 15 four years was inaccurate based upon memory and not 16 an actual timeline that we were able to get. 17 Q Did you say that to Sharon Churcher, that 18 it was four years? 19 A I don't know if I said that to her or -- 20 oh, yeah, did I tell her it was four years? Yes, I 21 did. I'm sorry. 22 Q Okay. What else did you put a check by? 23 A Well, this one is a question mark again. 24 "Radar online has obtained exclusive diary entries of 25 a Teen Sex Slave." VIRGINIA GIUFFRE VOLUME II 11/14/2016 453  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page36 Inc. of 55 1 It wasn't really a diary. It was, like, I 2 don't know how many pages of something that I wrote, 3 and Sharon used it, so... 4 Q Did you tell Sharon it was your diary 5 entry? 6 A She knew it wasn't a diary entry. No. 7 Q Okay. Were you a teen sex slave? 8 A Yes. 9 Q What's the next one you have a checkmark 10 by? 11 A "I also saw Prince Andrew at a Ranch in 12 New Mexico." 13 Q Did you tell that to Sharon Churcher? 14 A No. And I think it's a mistake. Maybe 15 she meant somewhere else, but because we had been 16 talking about so much, maybe she just put New Mexico. 17 I don't think Sharon intentionally lied on any of 18 these. I just -- I think we talked so much over a 19 period of a week, and then after that we had phone 20 conversations, and so on and so forth, that some of 21 the information just got misheard or mishandled, or 22 whatever. 23 Q And what was printed was inaccurate? 24 A Was that printed? I don't -- I don't 25 remember reading that in the papers, but if it was VIRGINIA GIUFFRE VOLUME II 11/14/2016 454  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page37 Inc. of 55 1 printed it's inaccurate. 2 Q Do you recall reading any of the ones that 3 you put a checkmark by in the papers? 4 A There's been so much printed, it's hard 5 for me to remember. I mean, yes, it does sound like 6 stuff I read before. 7 Q When you spoke with Sharon Churcher, you 8 agreed to waive your anonymity, right? 9 A I did. 10 Q Why did you agree to do that? 11 A I felt it was time for me to tell my 12 story. I felt it was a good time for me to come 13 forward. I had done so much healing, and I thought 14 that it would be good for other people to hear what's 15 going on, how it's happening, how vulnerable other 16 girls can be and not even know the damage that it 17 causes later in life. And I just thought it would be 18 the right thing to do to come forward. 19 Q You authorized her to publish your name? 20 A I did. 21 Q And your photograph? 22 A Yes. 23 Q In 2011? 24 A I think that was the year, yes. 25 Q You posed for photographs with her, VIRGINIA GIUFFRE VOLUME II 11/14/2016 455  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page38 Inc. of 55 1 I, VIRGINIA GIUFFRE, do hereby certify that 2 I have read the foregoing transcript and that the 3 same and accompanying amendment sheets, if any, 4 constitute a true and complete record of my 5 testimony. 6 ____________________________ Signature of Deponent 7 ( ) No amendments 8 ( ) Amendments attached 9 10 Acknowledged before me this _______ day 11 of _____________, 20___. 12 13 Notary Public: ___________________ 14 My Commission Expires: ___________ 15 Seal: 16 PJH 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 562  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page39 Inc. of 55 1 STATE OF COLORADO) 2 ) ss. REPORTER'S CERTIFICATE 3 COUNTY OF DENVER ) 4 I, Pamela J. Hansen, do hereby certify that 5 I am a Registered Professional Reporter and Notary 6 Public within the State of Colorado; that previous to 7 the commencement of the examination, the deponent was 8 duly sworn to testify to the truth. 9 I further certify that this deposition was 10 taken in shorthand by me at the time and place herein 11 set forth, that it was thereafter reduced to 12 typewritten form, and that the foregoing constitutes 13 a true and correct transcript. 14 I further certify that I am not related to, 15 employed by, nor of counsel for any of the parties or 16 attorneys herein, nor otherwise interested in the 17 result of the within action. 18 In witness whereof, I have affixed my 19 signature this 23rd day of November, 2016. 20 My commission expires September 3, 2018. 21 22 _______________________________ Pamela J. Hansen, CRR, RPR, RMR 23 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 563 Case 18-2868, Document 286, 08/09/2019, 2628248, Page40 of 55 Case 18-2868, Document 286, 08/09/2019, 2628248, Page41 of 55 Case 18-2868, Document 286, 08/09/2019, 2628248, Page42 of 55 Case 18-2868, Document 286, 08/09/2019, 2628248, Page43 of 55 EXHIBIT QQ Case 18-2868, Document 286, 08/09/2019, 2628248, Page44 of 55 Case 18-2868, Document 286, 08/09/2019, 2628248, Page45 of 55 EXHIBIT RR  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page46 Inc. of 55 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May 3, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954.524.2820 [email protected] Appearing on behalf of the Plaintiff BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. (For Portion) 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Phone: 954.356.0011 [email protected] Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016 1  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page47 Inc. of 55 1 APPEARANCES: (Continued) 2 HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. 3 Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue 4 Denver, CO 80203 Phone: 303.831.7364 5 [email protected] [email protected] 6 Appearing on behalf of the Defendant 7 Also Present: 8 Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 2  Agren Document Case 18-2868, Blando Court Reporting 2628248, 286, 08/09/2019, & Video, Page48 Inc. of 55 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF 3 VIRGINIA GIUFFRE, called by Defendant, was taken on 4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150 5 East 10th Avenue, Denver, Colorado, before Kelly A. 6 Mackereth, Certified Shorthand Reporter, Registered 7 Professional Reporter, Certified Realtime Reporter 8 and Notary Public within Colorado. 9 * * * * * * * 10 I N D E X 11 EXAMINATION PAGE 12 MS. MENNINGER 8 13 14 PRODUCTION REQUEST(S): 15 (None.) 16 17 18 19 20 21 22 23