gov.uscourts.nysd.447706.1158.0.pdf

Case 1:15-cv-07433-LAP Document 1158 Filed 11/20/20 Page 1 of 1 Sigrid S. McCawley Telephone: (954) 356-0011 Email: [email protected] November 20, 2020 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Pursuant to the Court’s order dated November 20, 2020 (ECF No. 1157), and in light of Does 1 and 2 not submitting any objection to unsealing within 14 days of being served with their relevant excerpts, Plaintiff files excerpts of Doe 1’s deposition transcript (DEs 204-3, 212-3) as attachments hereto. Sincerely, /s/ Sigrid S. McCawley Sigrid S. McCawley, Esq. cc: Counsel of Record (via ECF) Case 1:15-cv-07433-LAP Document 1158-1 Filed 11/20/20 Page 1 of 8 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 1, 2016 9:12 a.m. C O N F I D E N T I A L Deposition of JOHN ALESSI, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 1:15-cv-07433-LAP Document 1158-1 Filed 11/20/20 Page 2 of 8 Page 36 1 JOHN ALESSI 2 A. She was a -- she was very avid with 3 photographs. She had this high-tech camera. She 4 was constantly taking photographs. Not only 5 photographs, but I think it was -- she had this 6 special camera. I don't know what was it. She took 7 photographs, yes. 8 Q. In fact, you described her as a fanatic 9 about photographs? 10 A. Exactly. Yes. 11 Q. You would agree -- 12 A. Because of the equipment that she had. 13 She had this fantastic equipment. 14 Q. And did she take photographs and pictures 15 by the pool in Jeffrey Epstein's house? 16 A. I think she did some, yes. 17 Q. Did she take pictures of topless girls at 18 the pool? 19 A. I saw pictures of topless girls, yes, I 20 did. Saw it. 21 Q. And were the majority of the pictures that 22 she took of topless or nude girls? 23 MR. PAGLIUSCA: Object to form and 24 foundation. 25 THE WITNESS: I never saw any nude photos. Case 1:15-cv-07433-LAP Document 1158-1 Filed 11/20/20 Page 3 of 8 Page 37 1 JOHN ALESSI 2 I saw topless pictures of girls. I don't think 3 I can remember seeing nude photos. 4 BY MR. EDWARDS: 5 Q. Okay. I want you to go to your 6 deposition, and -- 7 MR. PAGLIUSCA: Which exhibit number? 8 BY MR. EDWARDS: 9 Q. Right. It's going to be Exhibit No. 2, 10 page 40, line 15. 11 A. Okay. 12 Q. Through page 41, line 7. 13 MR. PAGLIUSCA: And, again, I'm going to 14 object to the form of this process. 15 THE WITNESS: Okay. 16 BY MR. EDWARDS: 17 Q. Okay. Did you read that testimony? 18 A. Yes. 19 Q. Okay. So do you remember back in 2009 20 testifying: 21 "QUESTION: Did you ever observe her doing 22 a photo shoot of any of the young women whose names 23 you mentioned? 24 "ANSWER: Young women? 25 "QUESTION: Yes. Case 1:15-cv-07433-LAP Document 1158-1 Filed 11/20/20 Page 4 of 8 Page 38 1 JOHN ALESSI 2 "ANSWER: No, I can't remember. I know 3 that she went out and took pictures in the pool, 4 because later I would see them at the desk or at the 5 house; and nude, 99.9 percent of the time they were 6 topless. They were European girls." 7 A. Yes. 8 Q. Is that truthful testimony? 9 A. It is truthful. 10 Q. Okay. So it's true that 99.9 percent of 11 the photographs that Ms. Maxwell would take were, in 12 your words, nude, they were topless? 13 A. Topless, not nude. Topless. 14 Q. Do you see where I got the word "nude" 15 from, though, right? That's a word you used? 16 A. Let me tell you something. 17 Q. Sure. 18 A. When these girls came to the house, most 19 of the European -- there were some Americans; they 20 also took their top off -- they would go in the sun, 21 they would go in the pool without the tops. I don't 22 remember seeing nude girls. Nude, with me, means 23 nothing on. They would have the bottoms on and no 24 tops. Some of them. Some will go with a full 25 swimming costume. Case 1:15-cv-07433-LAP Document 1158-1 Filed 11/20/20 Page 5 of 8 Page 39 1 JOHN ALESSI 2 Q. And did Ms. Maxwell keep these photographs 3 in an album? 4 A. Yes, there was an album, because I knew, 5 when I clean out the desk, I have to put everything 6 in the house back together. Sometimes I saw these 7 albums, and there were pictures of girls at the 8 pool. 9 Q. And there were also nude photographs -- or 10 sorry -- topless photographs -- strike that. 11 Were there photographs of girls topless 12 that were displayed in the Palm Beach house? 13 MR. PAGLIUSCA: Object to form and 14 foundation. 15 THE WITNESS: Not when I was there. Not 16 when I was there. 17 BY MR. EDWARDS: 18 Q. When is the last time that you spoke with 19 Ghislaine Maxwell? 20 A. I did not spoke to her after we left. 21 Q. When was the last time you spoke to 22 Jeffrey Epstein? 23 A. Jeffrey Epstein, I talked to him while I 24 was -- basically, I was attacked by the media at my 25 house. Case 1:15-cv-07433-LAP Document 1158-1 Filed 11/20/20 Page 6 of 8 Page 40 1 JOHN ALESSI 2 Q. When was that? 3 A. When was that? 2014, after all of this -- 4 after the -- the -- Jeffrey got in trouble with the 5 law. After that, the media came to my house trying 6 to get me to talk, trying to get me to basically put 7 him in trouble. And I didn't know anything about 8 it. And I wanted them to be out of my house, out of 9 my life. 10 And I want this thing to get over in my 11 life, too, because I am getting sick and tired of 12 this constant coming back to me, and it's -- I need 13 to be left alone. 14 Q. Okay. I understand. 15 Have you had any communication with anyone 16 who represents the interests of Ghislaine Maxwell in 17 the last -- 18 A. Absolutely not. 19 Q. Okay. 20 A. I didn't know there was a case against 21 Ms. Maxwell. 22 Q. Where did Ms. Maxwell keep the album of 23 topless females? 24 MR. PAGLIUSCA: Object to form and 25 characterization. Case 1:15-cv-07433-LAP Document 1158-1 Filed 11/20/20 Page 7 of 8 Page 41 1 JOHN ALESSI 2 THE WITNESS: I think it was on her desk. 3 BY MR. EDWARDS: 4 Q. Where was Ms. Maxwell's desk within the 5 house? 6 A. It was in the first floor. It was in the 7 opposite end of Mr. Epstein, with a partition wall 8 in the middle. So it was not viewable for him, her 9 desk, and she could not see him and his desk. 10 Q. Okay. And did Ms. Maxwell have her own 11 computer at her desk? 12 A. She had a computer. She had a laptop at 13 her desk. 14 Q. Was one of your job duties to transport 15 any of the girls that would come over to give 16 massages? 17 A. Occasionally. 18 Q. All right. 19 And would there be occasion where 20 Ms. Maxwell would ask you to go pick up a certain 21 girl and bring her over to the house? 22 A. It was basically him. He would ask me. 23 Q. Mr. Epstein? 24 A. Uh-huh. 25 Q. I guess my real question is: Would you Case 1:15-cv-07433-LAP Document 1158-1 Filed 11/20/20 Page 8 of 8 Page 236 1 JOHN ALESSI 2 CERTIFICATE OF OATH 3 STATE OF FLORIDA ) 4 COUNTY OF MIAMI-DADE ) 5 I, the undersigned authority, certify 6 that JOHN ALESSI personally appeared before me and was duly sworn. 7 WITNESS my hand and official seal this 1st day of June, 2016. 8 9 Kelli Ann Willis, RPR, CRR 10 Notary Public, State of Florida Commission FF928291, Expires 2-16-20 11 + + + + + + + + + + + + + + + + + + 12 CERTIFICATE 13 STATE OF FLORIDA ) 14 COUNTY OF MIAMI-DADE ) 15 I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime 16 Reporter do hereby certify that I was authorized to and did stenographically report the 17 foregoing deposition of JOHN ALESSI; that a review of the transcript was not requested; and that the 18 transcript is a true record of my stenographic notes. 19 I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any 20 of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected 21 with the action, nor am I financially interested in the action. 22 Dated this 1st day of June, 2016. 23 24 KELLI ANN WILLIS, RPR, CRR 25 Case 1:15-cv-07433-LAP Document 1158-2 Filed 11/20/20 Page 1 of 8 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 1, 2016 9:12 a.m. C O N F I D E N T I A L Deposition of JOHN ALESSI, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 1:15-cv-07433-LAP Document 1158-2 Filed 11/20/20 Page 2 of 8 Page 36 1 JOHN ALESSI 2 A. She was a -- she was very avid with 3 photographs. She had this high-tech camera. She 4 was constantly taking photographs. Not only 5 photographs, but I think it was -- she had this 6 special camera. I don't know what was it. She took 7 photographs, yes. 8 Q. In fact, you described her as a fanatic 9 about photographs? 10 A. Exactly. Yes. 11 Q. You would agree -- 12 A. Because of the equipment that she had. 13 She had this fantastic equipment. 14 Q. And did she take photographs and pictures 15 by the pool in Jeffrey Epstein's house? 16 A. I think she did some, yes. 17 Q. Did she take pictures of topless girls at 18 the pool? 19 A. I saw pictures of topless girls, yes, I 20 did. Saw it. 21 Q. And were the majority of the pictures that 22 she took of topless or nude girls? 23 MR. PAGLIUSCA: Object to form and 24 foundation. 25 THE WITNESS: I never saw any nude photos. Case 1:15-cv-07433-LAP Document 1158-2 Filed 11/20/20 Page 3 of 8 Page 37 1 JOHN ALESSI 2 I saw topless pictures of girls. I don't think 3 I can remember seeing nude photos. 4 BY MR. EDWARDS: 5 Q. Okay. I want you to go to your 6 deposition, and -- 7 MR. PAGLIUSCA: Which exhibit number? 8 BY MR. EDWARDS: 9 Q. Right. It's going to be Exhibit No. 2, 10 page 40, line 15. 11 A. Okay. 12 Q. Through page 41, line 7. 13 MR. PAGLIUSCA: And, again, I'm going to 14 object to the form of this process. 15 THE WITNESS: Okay. 16 BY MR. EDWARDS: 17 Q. Okay. Did you read that testimony? 18 A. Yes. 19 Q. Okay. So do you remember back in 2009 20 testifying: 21 "QUESTION: Did you ever observe her doing 22 a photo shoot of any of the young women whose names 23 you mentioned? 24 "ANSWER: Young women? 25 "QUESTION: Yes. Case 1:15-cv-07433-LAP Document 1158-2 Filed 11/20/20 Page 4 of 8 Page 38 1 JOHN ALESSI 2 "ANSWER: No, I can't remember. I know 3 that she went out and took pictures in the pool, 4 because later I would see them at the desk or at the 5 house; and nude, 99.9 percent of the time they were 6 topless. They were European girls." 7 A. Yes. 8 Q. Is that truthful testimony? 9 A. It is truthful. 10 Q. Okay. So it's true that 99.9 percent of 11 the photographs that Ms. Maxwell would take were, in 12 your words, nude, they were topless? 13 A. Topless, not nude. Topless. 14 Q. Do you see where I got the word "nude" 15 from, though, right? That's a word you used? 16 A. Let me tell you something. 17 Q. Sure. 18 A. When these girls came to the house, most 19 of the European -- there were some Americans; they 20 also took their top off -- they would go in the sun, 21 they would go in the pool without the tops. I don't 22 remember seeing nude girls. Nude, with me, means 23 nothing on. They would have the bottoms on and no 24 tops. Some of them. Some will go with a full 25 swimming costume. Case 1:15-cv-07433-LAP Document 1158-2 Filed 11/20/20 Page 5 of 8 Page 39 1 JOHN ALESSI 2 Q. And did Ms. Maxwell keep these photographs 3 in an album? 4 A. Yes, there was an album, because I knew, 5 when I clean out the desk, I have to put everything 6 in the house back together. Sometimes I saw these 7 albums, and there were pictures of girls at the 8 pool. 9 Q. And there were also nude photographs -- or 10 sorry -- topless photographs -- strike that. 11 Were there photographs of girls topless 12 that were displayed in the Palm Beach house? 13 MR. PAGLIUSCA: Object to form and 14 foundation. 15 THE WITNESS: Not when I was there. Not 16 when I was there. 17 BY MR. EDWARDS: 18 Q. When is the last time that you spoke with 19 Ghislaine Maxwell? 20 A. I did not spoke to her after we left. 21 Q. When was the last time you spoke to 22 Jeffrey Epstein? 23 A. Jeffrey Epstein, I talked to him while I 24 was -- basically, I was attacked by the media at my 25 house. Case 1:15-cv-07433-LAP Document 1158-2 Filed 11/20/20 Page 6 of 8 Page 40 1 JOHN ALESSI 2 Q. When was that? 3 A. When was that? 2014, after all of this -- 4 after the -- the -- Jeffrey got in trouble with the 5 law. After that, the media came to my house trying 6 to get me to talk, trying to get me to basically put 7 him in trouble. And I didn't know anything about 8 it. And I wanted them to be out of my house, out of 9 my life. 10 And I want this thing to get over in my 11 life, too, because I am getting sick and tired of 12 this constant coming back to me, and it's -- I need 13 to be left alone. 14 Q. Okay. I understand. 15 Have you had any communication with anyone 16 who represents the interests of Ghislaine Maxwell in 17 the last -- 18 A. Absolutely not. 19 Q. Okay. 20 A. I didn't know there was a case against 21 Ms. Maxwell. 22 Q. Where did Ms. Maxwell keep the album of 23 topless females? 24 MR. PAGLIUSCA: Object to form and 25 characterization. Case 1:15-cv-07433-LAP Document 1158-2 Filed 11/20/20 Page 7 of 8 Page 41 1 JOHN ALESSI 2 THE WITNESS: I think it was on her desk. 3 BY MR. EDWARDS: 4 Q. Where was Ms. Maxwell's desk within the 5 house? 6 A. It was in the first floor. It was in the 7 opposite end of Mr. Epstein, with a partition wall 8 in the middle. So it was not viewable for him, her 9 desk, and she could not see him and his desk. 10 Q. Okay. And did Ms. Maxwell have her own 11 computer at her desk? 12 A. She had a computer. She had a laptop at 13 her desk. 14 Q. Was one of your job duties to transport 15 any of the girls that would come over to give 16 massages? 17 A. Occasionally. 18 Q. All right. 19 And would there be occasion where 20 Ms. Maxwell would ask you to go pick up a certain 21 girl and bring her over to the house? 22 A. It was basically him. He would ask me. 23 Q. Mr. Epstein? 24 A. Uh-huh. 25 Q. I guess my real question is: Would you Case 1:15-cv-07433-LAP Document 1158-2 Filed 11/20/20 Page 8 of 8 Page 236 1 JOHN ALESSI 2 CERTIFICATE OF OATH 3 STATE OF FLORIDA ) 4 COUNTY OF MIAMI-DADE ) 5 I, the undersigned authority, certify 6 that JOHN ALESSI personally appeared before me and was duly sworn. 7 WITNESS my hand and official seal this 1st day of June, 2016. 8 9 Kelli Ann Willis, RPR, CRR 10 Notary Public, State of Florida Commission FF928291, Expires 2-16-20 11 + + + + + + + + + + + + + + + + + + 12 CERTIFICATE 13 STATE OF FLORIDA ) 14 COUNTY OF MIAMI-DADE ) 15 I, Kelli Ann Willis, Registered Professional Reporter and Certified Realtime 16 Reporter do hereby certify that I was authorized to and did stenographically report the 17 foregoing deposition of JOHN ALESSI; that a review of the transcript was not requested; and that the 18 transcript is a true record of my stenographic notes. 19 I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any 20 of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected 21 with the action, nor am I financially interested in the action. 22 Dated this 1st day of June, 2016. 23 24 KELLI ANN WILLIS, RPR, CRR 25