gov.uscourts.nysd.447706.1327.8.pdf

Case 1:15-cv-07433-LAP Document 1327-8 Filed 01/05/24 Page 1 of 8 COMPOSITE EXHIBIT 2 (File Under Seal) Case 1:15-cv-07433-LAP Document 1327-8 Filed 01/05/24 Page 2 of 8 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff , V. GHISLAINE MAXWELL, Defendant. ___________ / VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 1 of 2 Pages 1 - 157 Taken at the Instance of the Defendant DATE: Friday, June 24 , 2016 TIME : Commenced: 8:59 a.m. Concluded: 1:22 p.m. PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 1:15-cv-07433-LAP Document 1327-8 Filed 01/05/24 Page 3 of 8 96 1 Q I guess my question is: Did she ever tell 2 you that she had started as a regular masseuse for 3 him and then transitioned to something other than a 4 masseuse? 5 A No She never said that it transitioned . 6 But she ended up explaining to me what had happened 7 before , so ... 8 Q What has -- what is that? 9 A That her and Ms. Maxwell and Jeffrey would 10 obviously be doing stuff, all three of them 11 together. Like I said, that they would all go out 12 to clubs to pick up girls and try and find them to 13 bring back for Jeffrey. And then she told me about 14 how, like I said, her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions . 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates . 18 Q Was it while you were still together? 19 A Yes . 20 Q Did you -- had you met Ms. Maxwell? 21 A Yeah, I had met her a couple of times . 22 Q When did you meet Ms. Maxwell? 23 A Dates, I ' m unsure of . But it was pretty 24 much, like I said, at Jeffrey's house in the 25 kitchen. Southern Reporting Company www. Southernreporting.com - (386)257-3663 Case 1:15-cv-07433-LAP Document 1327-8 Filed 01/05/24 Page 4 of 8 182 i Foundation. Vague as to time and place . 2 BY MR. EDWARDS: 3 Q Sorry. Let me rephrase the question. 4 During this 2001 period, if you were 5 driving Virginia and another girl to the house, what 6 type of girls would you be driving? 7 MS. MENNINGER: Objection. Form. 8 Foundation. 9 A Pretty much like young-looking teenager 10 girls. I mean, 16, 17. Really pretty. You know . 11 BY MR. EDWARDS: 12 Q All right . How did you know that that 1 s 13 what was being requested, that that age range and 14 that look and that 1 s what was 15 A I just assumed that that ' s what most guys 16 are into, you know, so ... 17 Q Girls who looked like Virginia? 18 A Yeah. 19 Q All right . When you would bring girls 20 over to the house, were you looking for some 21 professional masseuse or somebody with massage 22 experience? 23 A Like I said, I would just get friends that 24 I knew from school , so .. . 25 Q And that ' s what Jeffrey wanted? Southern Reporting Company www. Southernreporting.com - (386)257-3663  Case 1:15-cv-07433-LAP Document 1327-8 Filed 01/05/24 Page 5 of 8 193 1 you can think to one of the occasions where you 2 brought a girl into the kitchen other than 3 Virginia 4 A Uh-huh (affirmative). 5 Q and Ms. Maxwell is in the kitchen, did 6 you and this other girl that you were bringing over 7 sit there and together have this small talk with 8 Ms. Maxwell? 9 A Yeah. 10 MS. MENNINGER: Objection. Form. 11 Foundation . 12 A Yes. 13 BY MR. EDWARDS: 14 Q And how long would you and one of these 15 other girls sit there and have this small talk with 16 Ms. Maxwell? 17 A No more than , like, 10 or 15 minutes . 18 Q All right. And what were you waiting for? 19 A Pretty much her to take them upstairs. 20 And then I would leave. 21 Like, I would wait for them to be , like, 22 "All right. Well, we're ready. " 23 And I would be, like , "All right. See you 24 later. '' And then I ' d leave. And they would go do 25 whatever . Southern Reporting Company www.Southernreporting.com - (386 ) 257-3663  Case 1:15-cv-07433-LAP Document 1327-8 Filed 01/05/24 Page 6 of 8 200 1 MS . MENNINGER: Objection . Form. 2 Foundation. 3 A For Jeffrey. 4 BY MR. EDWARDS: 5 Q All right . Let me fix this. Ghislaine 6 when Ghislaine Maxwell would call you during the 7 time that you were living with Virginia, she would 8 ask you what, specifically? 9 MS. MENNINGER: Objection. Form . 10 Foundation. 11 A Just if I had found any other girls just 12 to bring to Jeffrey . 13 BY MR. EDWARDS: 14 Q Okay . 15 A Pretty much every time there was a 16 conversation with any of them, it was either asking 17 Virginia where she was at, or asking her to get 18 girls, or asking me to get girls. 19 Q All right. Let's go to that second 20 category you just identified, which is asking 21 Virginia to get girls. How many times were you in a 22 room where specifically Ghislaine Maxwell would ask 23 Virginia to bring girls? 24 A None that I can recall . 25 Q Okay . How many times -- when you say they Southern Reporting Company www.Southernreporting.com - (386)257-3663  Case 1:15-cv-07433-LAP Document 1327-8 Filed 01/05/24 Page 7 of 8 245 1 Q Okay. Any of the girls that you are aware 2 of having gone to the house either because you 3 brought them or Virginia -- as you sit here today , 4 do you believe any of them were brought over to be a 5 legitimate masseuse? 6 MS. MENNINGER: Objection. Form. 7 Foundation. Opinion. 8 A Nope. 9 BY MS. MENNINGER: 10 Q All right. How long aft er Virginia left 11 to go to Thailand did you continue to bring girls to 12 Jeffrey Epstein? 13 A Not, like, at all. Maybe, like, once. 14 Like I said, pretty much after she left and did not 15 come back, he was gone, I think, also. And then he 16 came back and was, like, "Oh, where is Virginia?" 17 And that was pretty much, like I said, he was just 18 throwing in, "Can you bring somebody b y ," just to 19 make it seem like he wanted me to still be around. 20 I was, like -- and pretty much after she was gone, 21 that was basically it. 22 Q All right. You described that every time 23 that you would bring girls, Jeffrey Epstein would 24 pay you $200 apiece; correct? 25 A Uh-huh (affirmative) . Southern Reporting Company www.Southernreporting.com - (386)257-3663  Case 1:15-cv-07433-LAP Document 1327-8 Filed 01/05/24 Page 8 of 8 257 1 CERTIFICATE OF OATH 2 3 STATE OF FLORIDA 4 COUNTY OF FLAGLER 5 6 7 I, the undersigned authority, certify that TONY 8 FIGUEROA personally appeared before me on 9 July 5, 2016, and was duly sworn . 10 11 WITNESS my hand and official seal this 5th day 12 of July, 2016 . 13 14 15 16 17 18 19 Leanne W. Fitzgerald 20 Notary Public - State of Florida My Commission No. FF060921 21 Expires: February 8, 2018 22 Digital Certificate Authenticated By Symantec 23 24 25 Southern Reporting Company www .Southernreporting.com - (386)257-3663