gov.uscourts.nysd.447706.1295.10.pdf

EXHIBIT 2 (File Under Seal)  Highly Confidential Page 1 HIGHLY CONFIDENTIAL AEO UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -----------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. Case No: 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. -----------------------------x HIGHLY CONFIDENTIAL DEPOSITION OF SARAH RANSOME NEW YORK, NEW YORK Friday, February 17, 2017 Reported by: JEREMY RICHMAN JOB NO: 300491 MAGNA LEGAL SERVICES 320 West 37th Street, 12th Floor New York, New York 10018 (866) 624-6221  Highly Confidential Page 10 1 HIGHLY CONFIDENTIAL AEO 2 A. No. It's more of a hobby, 3 really. 4 Q. Are you employed? 5 A. Nope. 6 Q. Do you have any source of 7 income? 8 A. My partner -- 9 MR. GUIRGUIS: I'm going to 10 object to that. Income is out. 11 You don't have to answer 12 that. 13 Q. Do you have any source of 14 income? 15 MR. GUIRGUIS: I just 16 objected to that. You don't have 17 to answer. 18 MS. MENNINGER: Is there a 19 privilege you're asserting? 20 MR. GUIRGUIS: I'm not sure 21 what the relevance is, and I'm 22 not going to allow -- 23 MS. MENNINGER: Do you 24 believe that relevance is a 25 proper objection during a  Highly Confidential Page 28 1 HIGHLY CONFIDENTIAL AEO 2 with Ms. McCawley over the phone? 3 A. On my partner's cell phone. 4 Q. What's his cell phone 5 number? 6 MS. MCCAWLEY: Objection. 7 What's the relevance of her 8 partner's cell phone? 9 Again, this is irrelevant. 10 It's harassing. It's -- you're 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q. What is your partner's cell 19 phone number? 20 MR. GUIRGUIS: I'm directing 21 the witness not to answer. 22 Q. How many hours have you 23 spent speaking with Mr. Pottinger? 24 A. I've been speaking to 25 Mr. Pottinger from November.  Highly Confidential Page 29 1 HIGHLY CONFIDENTIAL AEO 2 Q. When in November? 3 A. I can't remember. 4 Q. On your same cell phone that 5 you got rid of? 6 A. No, on my partner's cell 7 phone. 8 Q. And when did you first meet 9 Mr. Pottinger in person? 10 A. It was in the beginning of 11 January. 12 Q. And where was that meeting? 13 A. Barcelona. 14 Q. Where in Barcelona? 15 A. Barcelona. It's Barcelona. 16 We meet -- I can't remember the area. 17 Q. In a restaurant? In a 18 hotel? In an office? 19 A. In a hotel. 20 Q. And how long did you spend 21 with Mr. Pottinger on that occasion? 22 A. Two days. 23 Q. How many hours over the two 24 days? 25 A. Gosh, about 16.  Highly Confidential Page 172 1 HIGHLY CONFIDENTIAL AEO 2 I had to regularly pop in to see him 3 and Ghislaine. And Ghislaine would 4 often check how I was doing and blah, 5 blah, blah, etcetera. 6 Q. What were you doing to 7 prepare for your college application? 8 A. I had to write an essay. 9 Q. When did you -- 10 A. Also, I had to do -- like, 11 you know how you apply for college 12 applications; you've got your 13 application forms and such. So it was 14 more admin. 15 Q. And you were going to 16 Jeffrey's office to work on your 17 forms? 18 A. Yes. And to just say hi. I 19 was -- well, I never went on my own 20 accord. I was either invited or told 21 to be there by either Ghislaine or 22 Jeffrey. I also went to the offices 23 on a number of occasions for private 24 legal matter. 25 Q. What's the private legal  Highly Confidential Page 173 1 HIGHLY CONFIDENTIAL AEO 2 matter? 3 MR. GUIRGUIS: Objection. 4 I'm going to direct you not to 5 answer if it's unrelated to this 6 case. 7 Q. Was there an attorney 8 present? 9 A. Yes. 10 Q. What was the name of the 11 attorney who was present? 12 A. Alan Dershowitz. 13 Q. So I was asking about the 14 second time you met Ghislaine. It was 15 at Jeffrey's office in New York? 16 A. Yes. 17 Q. How did you come to be in 18 Jeffrey's office in New York where you 19 met Ghislaine the second time? 20 A. I was told to be there. 21 Q. Who told you to be there? 22 A. I think it was Ghislaine. 23 Q. How did Ghislaine tell you 24 to be there? 25 A. I can't remember if it was  Highly Confidential Page 204 1 HIGHLY CONFIDENTIAL AEO 2 Q. Anything else? 3 MS. MCCAWLEY: I'm going to 4 object. There's no time frame on 5 this. You're talking about one 6 year? All the years from 2007 to 7 2015? Which I would say is 8 inappropriate for a nonparty 9 witness to talk about her -- if 10 you're talking generally about 11 prescriptions. 12  Highly Confidential Page 205 1 HIGHLY CONFIDENTIAL AEO 2 15  Highly Confidential Page 206 1 HIGHLY CONFIDENTIAL AEO 2 19  Highly Confidential Page 311 1 HIGHLY CONFIDENTIAL AEO 2 A. Yeah, we -- yeah. He was 3 really intimate all the time. We 4 had -- multiple times. I can't tell 5 you how many times I've slept with 6 Jeffrey. I mean, we were on rotation. 7 Every single day, it was -- sometimes 8 twice a day I was called. 9 You know, Ghislaine, 10 -- you know, it was -- yeah. I 11 mean, how -- we were on rotation 12 pretty much the whole time I was here. 13 Q. And when you say you were on 14 rotation, you mean you were having sex 15 with Jeffrey multiple times per day? 16 A. No. As in when I was 17 finished, another girl was called by 18 Ghislaine. And when they had 19 finished, another girl was called. 20 Q. How do you know that another 21 girl was called by Ghislaine? 22 A. Because I was there, and I 23 saw it and heard it with all my 24 senses. I saw Ghislaine call another 25 girl, and she called me herself, to go  Highly Confidential Page 312 1 HIGHLY CONFIDENTIAL AEO 2 give Jeffrey Epstein a sexual massage. 3 Q. What do you mean by call? I 4 guess I'm thinking like telephone. 5 That may be my -- 6 A. No. As in going up to the 7 person and going, Jeffrey wants to see 8 you in his bedroom, which meant it's 9 your turn to be abused. That kind of 10 thing. 11 Q. And this is on the island? 12 A. This is on the island. 13 Q. You heard -- as soon as you 14 were done with Jeffrey, you heard 15 Ghislaine go up to another girl and 16 say, it's your turn with Jeffrey? 17 A. So every single day, I 18 mean -- so I don't know how quickly 19 Jeffrey's sperm bank fills up. I 20 mean, I know guys can normally cum 21 once or twice a day, but Jeffrey's not 22 a normal person. 23 So, I mean, our rotation 24 changed every day that specific trip 25 we had in December.  Highly Confidential Page 420 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Okay. So on 3 the record -- we can carry on the 4 conversation, certainly, off the 5 record. 6 But while we're on the 7 record, I will say that my 8 understanding is that those 9 documents were all produced to 10 you, including all the emails 11 that you asked her about, and 12 where are the missing emails, and 13 she kept saying they'd been 14 produced to her attorneys. My 15 understanding is that the 16 attorneys did provide them to 17 defense counsel. 18 MS. MENNINGER: Well, 19 there's a current passport that 20 we know was not produced, there 21 is an FIT application that we 22 know was not produced, and I 23 believe there are emails that 24 were not produced. 25 And I'm happy to have the  Highly Confidential Page 421 1 HIGHLY CONFIDENTIAL AEO 2 conversation continue off the 3 record, but I'm telling you those 4 are some of my recollections. 5 MR. GUIRGUIS: Okay. And to 6 be clear so that I'm not 7 misrepresenting, I see that I 8 said there were documents and the 9 emails. I meant to clarify, as 10 in the emails I know were 11 produced. 12 I can't speak to any other 13 documents that you might want to 14 raise a dispute about. But with 15 respect to the emails that you 16 said, my understanding, at least 17 as I sit here, is that they were 18 produced. 19 That said, I think we can go 20 off the record and resolve any 21 other issues between counsel and 22 I. 23 (Time noted: 6:34 p.m.) 24 25