gov.uscourts.nysd.447706.1325.10.pdf

Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 1 of 13 EXHIBIT 3 (File Under Seal) Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 2 of 13 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 20, 2016 9:12 a.m. C O N F I D E N T I A L Deposition of Jane Doe 2 , pursuant to notice, taken by Plaintiff, at the offices of Podhurst Orseck, 25 West Flagler Street, Suite 800, Miami, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 3 of 13 Page 16 1 Jane Doe 2 2 know the extent of their relationship. But she 3 would schedule his appointments and handle clerical 4 things for him as far as I can see. 5 Q. All right. 6 And when you first went to his house, 7 where did -- where were you taken within the house? 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: Kitchen, up to the room, up 11 to his master suite. 12 BY MR. EDWARDS: 13 Q. And which stairwell did you go up to his 14 suite? 15 A. I do not remember. 16 Q. Was it the stairs off by the kitchen? 17 A. I do not recall. 18 Q. And when you went into his bedroom, were 19 you under the belief that it was going to be you 20 providing some sort of a massage? 21 A. It certainly didn't involve any sexual 22 activity. That's what I was under the assumption. 23 I don't recall exactly how I was propositioned to 24 get there. I just was there, and all of a sudden 25 something horrible happened to me. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 4 of 13 Page 17 1 Jane Doe 2 2 Q. Did you, at 16 years old or 17 years old, 3 have any massage training or experience? 4 A. No. 5 Q. Did Jane Doe 2 have any massage 6 experience? 7 A. I do not -- I can't speak to her 8 experience. I do not know. She was not really a 9 friend of mine. Barely an acquaintance. We maybe 10 spoke three times in our entire going to school 11 together and everything. 12 Q. Did you ever learn what her incentive was 13 to bring you to Jeffrey Epstein's house? 14 A. Later I found out that they would get 15 kickbacks for bringing people over. 16 Q. Do you remember seeing Jeffrey Epstein 17 give her money that day? 18 A. I don't recall, no. 19 Q. If you said that in your statement, that 20 21 22 - you remember Jane Doe 2 getting money for bringing you here that day, would that be a true statement? A. Yes, absolutely. Everything in there is 23 the truth. I do not remember from years ago at this 24 point. 25 MR. PAGLIUCA: Object to form and MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 5 of 13 Page 23 1 Jane Doe 2 2 into? 3 A. I worked very, very hard to not recall 4 anything specific about my sexual encounters with 5 this person as one of his victims. I cannot answer 6 your question. Things -- it wasn't supposed to be 7 sexual, but it was. That's as specific as I can 8 get. 9 Q. Fair to say that when Jeffrey Epstein or 10 his assistants used the term "massage," someone is 11 going to come give a massage, that that's always a 12 sexual encounter? 13 MR. PAGLIUCA: Object to form and 14 foundation. 15 THE WITNESS: "Always" is a strong word to 16 use. I'm not making that assumption, but 17 oftentimes that's exactly what it meant. 18 BY MR. EDWARDS: 19 Q. When Jeffrey Epstein was paying high 20 school girls for these alleged massages, he was 21 paying to turn it into a sexual encounter, fair? 22 MR. PAGLIUCA: Object to form and 23 foundation. 24 THE WITNESS: I would say yes, that is the 25 motivation. I'm not a mind-reader. I don't MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 6 of 13 Page 24 1 Jane Doe 2 2 know what he was thinking. It's fair to 3 assume. 4 BY MR. EDWARDS: 5 Q. All right. 6 Did you know how Jane Doe 2 met 7 Jeffrey Epstein? 8 A. No. 9 Q. Do you know someone named Hayley Robson? 10 A. No. 11 Q. Did you know Tony Figueroa? 12 A. No. It sounds like a familiar name, but I 13 do not know him. 14 Q. Did you know Ashley Davis? 15 A. I may have gone to high school with an 16 Ashley Davis, but that seems like a very common 17 name. 18 Q. Were you asked by Jeffrey Epstein to bring 19 other girls to him? 20 A. Yes. 21 Q. And for what purpose? 22 MR. PAGLIUCA: Object to form and 23 foundation. 24 BY MR. EDWARDS: 25 Q. What is his stated purpose? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 7 of 13 Page 25 1 Jane Doe 2 2 A. I was never present when he interacted 3 with those women. I don't know exactly what 4 happened. 5 Q. Did you bring other girls to him? 6 A. Yes. I brought friends over. 7 Q. And were they also of similar age to you? 8 A. Yes. They were my peers. 9 Q. High school girls? 10 A. Correct. 11 Q. Did any of them have massage experience? 12 A. I do not know. 13 MR. PAGLIUCA: Object to form. 14 BY MR. EDWARDS: 15 Q. Were you going out to look for a massage 16 therapist, a professional massage therapist to bring 17 to him? 18 A. No. 19 Q. What he wanted at his house was young high 20 school girls under the pretense of some massage? 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 BY MR. EDWARDS 24 Q. Is that fair? 25 MR. PAGLIUCA: Object to form and MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 8 of 13 Page 26 1 Jane Doe 2 2 foundation. 3 THE WITNESS: Yes, that's fair. I mean, I 4 have to think. Sometimes I would go over and I 5 would just swim and I would get paid, or I 6 would take a nap and I'd get paid, or I would 7 just hang out and I'd get paid. So that should 8 be in my statement as well. 9 It wasn't my assumption that they were 10 coming over to do anything. I did not know, 11 once the door was closed or once they went to 12 another area of the home. I often just went 13 over and did my own thing while they were doing 14 whatever they were doing. It was none of my 15 business. 16 BY MR. EDWARDS: 17 Q. When you would say you would just hang out 18 at the pool, who would you be with? 19 A. I don't remember anyone. None of those 20 girls were any friends. We were all there just 21 through that mutual connection. 22 Q. I just have a list of girls, and I want 23 you to tell me whether you know who they are or you 24 don't. 25 Do you know Felicia Esposito? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 9 of 13 Page 54 1 Jane Doe 2 2 BY MR. EDWARDS: 3 Q. When you got to his house, you were 4 requested to give a massage? 5 MR. PAGLIUCA: Object to foundation and 6 form. 7 THE WITNESS: I don't exactly remember. I 8 don't remember if I was asked in the kitchen. 9 I don't remember if -- I don't remember. 10 BY MR. EDWARDS: 11 Q. Massage was part of the game, though? 12 MR. PAGLIUCA: Object to form and 13 foundation. 14 THE WITNESS: I don't remember. I'm 15 sorry. 16 BY MR. EDWARDS: 17 Q. But even during this deposition today, we 18 have described at times you giving him a massage? 19 A. Yes. You're asking about my first 20 encounter, though. 21 Q. Sorry, I'm just trying to sum up the whole 22 thing. 23 A. Okay. 24 Q. Was massage part of the lure to get you 25 specifically to his house? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 10 of 13 Page 55 1 Jane Doe 2 2 A. Yes. 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 BY MR. EDWARDS: 6 Q. And at the time, you are 15, 16 or 17 7 years old? 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: Yes. 11 BY MR. EDWARDS: 12 Q. No massage experience? 13 A. No. 14 Q. You were told to bring other girls to his 15 house? 16 MR. PAGLIUCA: Object to form and 17 foundation. 18 THE WITNESS: After a while, yes. 19 BY MR. EDWARDS: 20 Q. These massages were turned sexual by 21 Jeffrey, as opposed to by anyone else? 22 A. Jeffrey took my clothes off without my 23 consent the first time I met him. 24 Q. The massages were scheduled by people 25 working for Jeffrey? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 11 of 13 Page 56 1 Jane Doe 2 2 A. I don't recall. 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 BY MR. EDWARDS: 6 Q. Jeffrey Epstein, during these massages, 7 would use sex toys or have sex toys used? 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: Well, at that point, it's no 11 longer a massage. Something else is going on. 12 But, yes, he would take out adult toys and 13 different things. 14 BY MR. EDWARDS: 15 Q. While you were a teenager, Jeffrey Epstein 16 asked you to live with him? 17 A. Yes. He wanted me to be emancipated. 18 Q. Jeffrey Epstein encouraged girl-on-girl 19 sex? 20 MR. PAGLIUCA: Object to form and 21 foundation. 22 THE WITNESS: Yes. 23 BY MR. EDWARDS: 24 Q. And after you cooperated with the police, 25 you were intimidated by people working for Jeffrey MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 12 of 13 Page 57 1 Jane Doe 2 2 Epstein? 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 THE WITNESS: Yes. 6 MR. EDWARDS: All right. I don't have 7 anything further for you. I apologize that we 8 even had to go through this, all right? 9 THE WITNESS: Okay. 10 E X A M I N A T I O N 11 BY MR. PAGLIUCA: 12 Q. Jane Doe 2 by name is Jeff Pagluica. I 13 live in Denver, Colorado. And, like you, I don't 14 want to be here today either, okay? I would rather 15 be in Denver. 16 I just want to -- as I understand it, and 17 I'm not trying to get into any of your treatment 18 over the last, let's say, 10 years, because I don't 19 know how long it's been, but as I understand what 20 you and your lawyer have said here today, you have 21 been involved in some number of years of therapy, in 22 which the purpose -- part of the purpose of the 23 therapy has been to forget all of these events that 24 Mr. Edwards was asking you questions about; is that 25 correct? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 13 of 13 Page 71 1 Jane Doe 2 2 CERTIFICATE OF OATH 3 STATE OF FLORIDA ) 4 COUNTY OF MIAMI-DADE ) 5 I, the undersigned authority, certify that 6 Jane Doe 2 personally appeared before me and was duly sworn. 7 WITNESS my hand and official seal this 23rd 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 Jane Doe 2 that a review of the transcript was not requested; and 18 that the 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 23rd day of June, 2016. 23 24 KELLI ANN WILLIS, RPR, CRR 25 MAGNA9 LEGAL SERVICES