gov.uscourts.nysd.447706.1330.19.pdf

Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 1 of 15 EXHIBIT A Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 2 of 15 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 1330-19 Filed 01/05/24 Page 3 of 15 Page 272 1 G Maxwell - Confidential 2 3 4 - Q. Is it your testimony that - knows Jeffrey Epstein through the work that she does for you? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I don't recollect, and I don't 8 9 10 to what Jeffrey. - recollect how I met - and I can't testify relationship is or is not with 11 Q. Have you ever talked to Jeffrey 12 13 14 about - A. Q. I don't know what you mean. In any way, have you ever had a 15 conversation with Jeffrey about 16 A. In what context. 17 Q. In any context. Have you ever 18 talked to Jeffrey Epstein about 19 20 21 A. - works for me so it's entirely possible that in the course of conversations since 2002, 2003 that a conversation in which 22 23 24 - possible. Q. name would have come up is entirely I provided you with and I'm sorry, 25 I don't know all the numbers, but the MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 4 of 15 Page 273 1 G Maxwell - Confidential 2 statement that was issued by Ross Gow that 3 should be a single page still in your stack 4 of exhibits there. 5 MR. PAGLIUCA: Exhibit 10. 6 Q. Did you authorize Ross Gow to issue 7 that statement on your behalf in January of 8 2015? 9 A. I already testified that that was 10 done by my lawyers. 11 Q. So did you authorize your lawyers 12 to issue a statement on your behalf through 13 Ross Gow in January of 2015? 14 A. It was determined that I had to 15 make a statement in the United Kingdom 16 because of the appalling lies and I just 17 thought of some new ones. 18 Virginia's statement that I 19 celebrated her 16 birthday with her. We can 20 all agree that that's entirely impossible. I 21 didn't meet her until she was 17 and other 22 lies she perpetrated that she had a diary and 23 we all know is a complete fake. That's not a 24 diary. It was just a book she was writing 25 that you helped sell to the press, as if it MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 5 of 15 Page 274 1 G Maxwell - Confidential 2 was a diary, when it was just a story that 3 she is writing of fiction, fictional story 4 for money. 5 Q. How did you arrive at the words 6 that were put in that statement? 7 MR. PAGLIUCA: I'm going to object 8 and instruct you to the extent this 9 calls for any privileged communications 10 between yourself and Mr. Barden or 11 another lawyer representing you, we're 12 asserting privilege. If you can answer 13 that without that, feel free to answer. 14 Q. So what your counsel is saying, and 15 I will exclude any privileged communications 16 you had with your lawyers. 17 The question is, how did you arrive 18 at the words that were put in that statement, 19 if you can tell me without disclosing 20 privileged communications? 21 A. I'm not sure that I can. 22 Q. Is the statement that you issued 23 true? 24 A. What do you mean by that? 25 Q. Is the statement that you issued, MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 6 of 15 Page 337 1 G Maxwell - Confidential 2 Q. To become pregnant, did you or 3 Jeffrey Epstein ever ask any female to become 4 pregnant and carry Jeffrey Epstein's baby for 5 you or for Jeffrey? 6 MR. PAGLIUCA: Objection to form 7 and foundation. 8 A. You need to be very specific. I 9 have no idea what you are talking about. 10 That's completely rubbish. 11 Q. Did you or Jeffrey Epstein ask any 12 female to become pregnant and carry his baby 13 for either him or you? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. Go ahead. 16 A. I can't testify to anything Jeffrey 17 did or didn't do when I am not present, but I 18 have never asked anybody to carry a baby for 19 me. 20 Q. Or anything along those lines? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 Q. I want to make sure we are talking 24 about the same thing, not physically carry a 25 baby, I mean become pregnant with a baby? MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 7 of 15 Page 338 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 Q. I want to make sure we are clear. 5 A. I don't know what you are asking. 6 Q. That's why I want to make sure we 7 are clear. 8 A. We are clear. I never asked 9 anybody to carry a baby for me. 10 Q. Do you know if Jeffrey ever asked 11 anybody to carry a baby for him? 12 A. I'm not going to characterize any 13 conversation Jeffrey had with somebody else. 14 Q. You are not aware of that, is that 15 your testimony? 16 A. I am testifying I never have and I 17 will not testify for anything for Jeffrey. 18 Q. Did you ever hear Jeffrey ask 19 anybody to carry a baby for him? 20 A. I don't recollect conversation 21 about Jeffrey and babies in any form. 22 Q. Did Jeffrey ever tell he wanted to 23 have a baby? 24 A. I don't recollect baby 25 conversations with Jeffrey. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 8 of 15 Page 339 1 G Maxwell - Confidential 2 Q. So he never told you he wanted to 3 have a baby? 4 A. I don't recollect any baby 5 conversations with him saying he wanted to 6 have a baby. 7 Q. Did you ever bring any females to 8 the Dubin's house that were not your friends' 9 children that were under the age of 18? 10 MR. PAGLIUCA: Objection to form 11 and foundation. 12 A. I have never, to my knowledge, 13 brought anybody under the age of 18 that's 14 not a friend of my family or my nieces or 15 nephews to the Dubin household. 16 Q. Earlier today you testified, I 17 believe, that with respect to your town home 18 Jeffrey paid for some of that and then gave 19 you a loan, is that correct? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I said, actually I think it was a 23 loan, I believe it was a loan. 24 Q. The whole thing? 25 A. As best as I can recollect. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 9 of 15 Page 360 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I was not coordinating with 5 Jeffrey. He had details that I did not have. 6 I was not party to his case. I needed to 7 have information in order to be able to 8 respond so I was not coordinating with him. 9 I was merely asking for details that I could 10 have. 11 Q. Did Jeffrey write any of your press 12 statements for you? 13 A. No. 14 Q. He didn't draft any of them? 15 A. I have a lawyer who was working on 16 this and that was -- I asked, I believe as I 17 recollect asked him for information to make 18 sure I was being accurate in the 19 representations for whatever I was 20 discussing. 21 Q. Did Jeffrey provide you with any 22 drafts of statements to provide to the press? 23 A. I only recall drafts from my 24 lawyer. 25 Q. I will mark this as Maxwell 17. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 10 of 15 Page 361 1 G Maxwell - Confidential 2 (Maxwell Exhibit 17, email, marked 3 for identification.) 4 Q. This is an email from you on 5 January 10, 2015 to Philip Barden and Ross 6 Gow. The statement you had before you 7 earlier, that, if you can pull that in front 8 of you, the one page press release that you 9 gave. You might know from memory. 10 Was the press release that you 11 issued with the statement about Virginia 12 issued in or around January 2, 2015? 13 A. As best as I can recollect. 14 Q. I want to turn your attention to 15 the document I just handed you which is Bates 16 No. 001044, from you to Philip Barden and 17 Ross Gow. It says in the first sentence, I'm 18 out of my depth to understand defamation, 19 other legal hazards and I don't want to end 20 up in a lawsuit aimed at me from anyone, if I 21 can help it. Apparently, even saying 22 Virginia is a liar has hazards. 23 You knew at the time you called 24 Virginia a liar in early January of 2015 that 25 that was something that would result in a MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 11 of 15 Page 362 1 G Maxwell - Confidential 2 lawsuit, is that correct? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I have legal advice that I took. 6 Q. But you knew in early January by 7 making a statement calling Virginia a liar 8 that you were subjecting yourself to a legal 9 dispute with her? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I took legal advice as to what 13 should be said and not be said and the legal 14 advice that came from the United Kingdom 15 was -- 16 MR. PAGLIUCA: You are not allowed 17 to talk about any legal advice that you 18 got from anybody that's a lawyer. 19 A. Sorry. 20 Q. So is it correct without telling me 21 what you talked to your lawyers about that 22 you knew because this is dated January 10 23 that when you made this statement in early 24 January, January 2 of 2015 you knew that 25 calling Virginia a liar would subject you to MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 12 of 15 Page 363 1 G Maxwell - Confidential 2 a legal action, isn't that correct? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. As to what you 5 knew -- whatever she knows would be 6 privileged. 7 MS. McCAWLEY: I'm asking if she 8 knows. I'm not asking her to tell me 9 about her privileged communications. 10 A. All I can say is I asked a question 11 and received legal advice. 12 (Maxwell Exhibit 18, email, marked 13 for identification.) 14 Q. This is an email dated January 15, 15 2015 from Jeffrey Epstein to you? 16 A. Uh-huh. 17 Q. It states in the first line, do you 18 19 20 want - to come out and say she was the girlfriend during the time? MR. PAGLIUCA: Objection to the 21 form and foundation of the question and 22 actually the word is , there 23 is no vowel in there. 24 MS. McCAWLEY: I was just trying to 25 pronounce it. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 13 of 15 Page 392 1 G Maxwell - Confidential 2 This will now end? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I have no idea. 6 Q. Did you discuss with him what he 7 meant by the statement, This will now end? 8 A. I don't recall. 9 Q. Was he taking any action to ensure 10 that, quote, this will now end? 11 A. I have no idea. 12 (Maxwell Exhibit 23, email, marked 13 for identification.) 14 Q. This is an email from, if you look 15 at the chain at the top, you will see it's 16 from you to Jeffrey on January 27 and the 17 email at the bottom of the chain is from 18 Jeffrey to you on January 27. 19 He states, What happened to you and 20 your statement, question mark, question mark. 21 And you put at the top, I have not decided 22 what to do. 23 A. Uh-huh. 24 Q. Why was Jeffrey interested in you 25 making a statement to the press? MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 14 of 15 Page 393 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I don't know that he was 5 interested. We made a statement and then I 6 was being advised to make an additional 7 statement and I never did. 8 Q. Was Jeffrey communicating with you 9 regularly on what additional statement you 10 might make? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. No, I've communicated with him very 14 little, as little as possible. 15 Q. Why did you feel you had to keep 16 him informed of statements you were making to 17 the press? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I didn't feel I had to. 21 Q. Then why you were communicating 22 with him about statements you were making to 23 the press? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 15 of 15 Page 394 1 G Maxwell - Confidential 2 A. Insofar as this is the case, it's 3 really all about Jeffrey, it's not a case 4 about me. 5 Q. In 2009, did you direct your 6 lawyer, either directly or indirectly, to 7 tell Brad Edwards that you were unavailable 8 to attend a deposition? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. And this is a 11 privileged communication as I understand 12 the question, what someone said or 13 didn't say to their lawyer. So don't 14 answer the question. 15 Q. Can you answer that question 16 without revealing a privileged communication? 17 A. Can you ask the question again? 18 Q. In 2009, did you direct your lawyer 19 to tell Brad Edwards that you were 20 unavailable to attend a deposition? 21 MR. PAGLIUCA: Same instruction. 22 Q. Did you make any statement in 2009 23 to anybody that you were unavailable to 24 attend a deposition? 25 A. My mother was sick and I don't MAGNA& LEGAL SERVICES