gov.uscourts.nysd.447706.1330.10.pdf

COMPOSITE EXHIBIT 2 (File Under Seal)  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  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  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  Page 203 1 G Maxwell - Confidential 2 conduct with Virginia while Virginia was 3 underage? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 Q. You can answer. 7 A. Try again, please. 8 Q. Are you saying that it's an obvious 9 lie that Jeffrey Epstein engaged in sexual 10 conduct with Virginia while Virginia was 11 underage? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. Again, I'm telling you, first of 15 all, it was a statement that was issued by my 16 lawyer and -- through my lawyer to Ross Gow. 17 Q. I understand that. I'm asking you, 18 are you saying that it's an obvious lie that 19 Jeffrey Epstein engaged in sexual conduct 20 with Virginia while Virginia was underage. 21 Is that a lie? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 Q. You can answer. 25 A. So I cannot testify to what Ross MAGNA& LEGAL SERVICES  Page 204 1 G Maxwell - Confidential 2 Gow and Philip Barden decided to put -- I can 3 testify to what Virginia's obvious lies are 4 as regards to me. I cannot make 5 representations about all the many lies she 6 may or may not have told about Jeffrey. 7 Q. So is Virginia lying when she says, 8 is it an obvious lie when she says that she 9 had sex with Jeffrey Epstein while she was 10 underage? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. Again, I'm testifying to what I 14 know to be true. I can only testify to all 15 the many lies she told about me. I cannot 16 testify to what lies she told about somebody 17 else. Given she told so many about me, one 18 can probably infer she is lying about 19 everything. 20 Q. So you think she is lying when she 21 said she had sex with Jeffrey Epstein when 22 she was underage? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Again, I can only talk about what I MAGNA& LEGAL SERVICES