gov.uscourts.nysd.447706.1090.7.pdf

Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 1 of 11 EXHIBIT H  Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 2 of 11 1 1 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA 2 CASE NO. 15-000072 3 BRADLEY J. EDWARDS and PAUL G. 4 CASSELL, 5 Plaintiffs, 6 -vs- CONFIDENTIAL 7 ALAN M. DERSHOWITZ, 8 Defendant. / 9 10 VIDEOTAPED DEPOSITION OF VIRGINIA ROBERTS GIUFFRE 11 12 Saturday, January 16, 2016 9:07 a.m. - 2:48 p.m. 13 14 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, Florida 33301 15 16 17 18 Reported By: 19 Deborah A. Harris, Court Reporter Notary Public, State of Florida 20 Phone - 305.651.0706 21 Job No. JO277789 22 23 24 25 CONFIDENTIAL GIUFFRE005093 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 3 of 11 200 1 raises. Do you understand that? 2 MS. MCCAWLEY: I do. So let's take a 3 break. It's a moment to take a break and I'll 4 discuss with these folks and we'll come back. 5 THE VIDEOGRAPHER: Going off video record 6 2:25 p.m. 7 (A recess was taken.) 8 THE VIDEOGRAPHER: We're now back on video 9 record 2:32 p.m. 10 SPECIAL MASTER: Just for the record, 11 through counsel examined the witness 12 for four hours and seven minutes and there was a 13 request and it appears to be in agreement to 14 allow. 15 MR. SCOTT: No agreement. 16 SPECIAL MASTER: Hang on one second. Hang 17 on. Between Mr. Scarola and Ms. McCawley, to 18 allow Mr. Scarola a couple questions on 19 examination on cross and then my ruling is going 20 to be as follows: You can go ahead and ask 21 whatever questions you want, Mr. Scarola, at which 22 time I will give opportunity for re-direct based 23 upon the topics that you've raised. 24 MR. SCAROLA: With the understanding that 25 re-direct is going to be limited to the area of CONFIDENTIAL GIUFFRE005292 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 4 of 11 201 1 inquiry that I am about to conduct. I am about to 2 conduct an inquiry. 3 SPECIAL MASTER: That is the understanding. 4 My understanding of my ruling, I know that . 5 team has objected to that. I also 6 understand that there might be -- this is no 7 impact or their right or anybody else's right to 8 go back to Judge Lynch and ask for more time from 9 this witness based upon my ruling or my reading of 10 the original order. 11 MS. MCCAWLEY: And there's also the motion 12 to strike the testimony that you allowed over the 13 ruling. 14 SPECIAL MASTER: And there's a series of 15 those things that might need to be cleaned up in a 16 subsequent sitting. 17 MR. SCOTT: It's my understanding this is 18 going to be limited to five minutes or less; is 19 that correct? 20 MR. SCAROLA: That's what I anticipate. 21 MR. SCOTT: Over our objection, okay. 22 SPECIAL MASTER: Let's rock and roll. 23 CROSS-EXAMINATION 24 BY MR. SCAROLA: 25 Q. Virginia, has Brad Edwards ever pressured CONFIDENTIAL GIUFFRE005293 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 5 of 11 202 1 you or encouraged you in any way whatsoever at any time 2 and under any circumstances to provide false information 3 about 4 A. Never. 5 Q. Has Brad Edwards ever pressured you or 6 encouraged you in any way or under any circumstances at 7 any time to provide false information about Jeffrey 8 Epstein? 9 A. Never. 10 Q. Has he ever pressured you or encouraged you 11 at any time or in any way, under any circumstances to 12 provide false information about anyone or anything? 13 A. Never. 14 Q. Has Paul Cassell ever pressured you or 15 encouraged you in any way, at any time, under any 16 circumstances to provide false information about 17 18 A. Never. 19 Q. Has he ever pressured or encouraged you in 20 any way at any time, under any circumstances to provide 21 false information about Jeffrey Epstein? 22 A. Never. 23 MS. BORJA: Objection. I couldn't follow 24 who he was. 25 BY MR. SCAROLA: CONFIDENTIAL GIUFFRE005294 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 6 of 11 203 1 Q. Mr. Cassell, Professor Cassell? You 2 understood that I was asking you that question about 3 Professor Cassell, right? 4 A. And he's never pressured me or encouraged 5 me in any way to talk -- 6 MS. MCCAWLEY: I don't want you to go into 7 discussions with them if you're saying something 8 didn't happen -- 9 SPECIAL MASTER: Just -- 10 MS. MCCAWLEY: I'm preserving privilege. I 11 just want to make sure if something didn't happen 12 she can say that. 13 BY MR. SCAROLA: 14 Q. Has Professor Cassell ever pressured you or 15 encouraged you in any way to provide false information 16 about anyone or anything at any time? 17 A. Never. 18 Q. Apart from any efforts made by Jeffrey 19 Epstein or agents on behalf of Jeffrey Epstein to silence 20 you or to have you refrain from providing true and 21 accurate information about the interactions that you had 22 with Jeffrey Epstein and others to whom you were 23 trafficked by Jeffrey Epstein, has anyone apart from that 24 circumstance pressured you or encouraged you to provide 25 false information about any of the topics that were CONFIDENTIAL GIUFFRE005295 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 7 of 11 204 1 covered during the course of your examination? 2 MS. BORJA: Objection. Objection to the 3 form. Leading, assumes facts not in evidence, 4 compound, misleading. 5 SPECIAL MASTER: Your form objection will 6 be reserved. You can answer. 7 A. No. 8 MR. SCAROLA: Thank you. I don't have any 9 further questions. 10 MR. SCOTT: Judge, excuse me, none of this 11 was covered on direct examination so we move to 12 exclude and strike the entire testimony because 13 none of this was covered on our direct. But we 14 would like to request a two-minute recess because 15 these are completely new areas. 16 SPECIAL MASTER: I'll grand your two-minute 17 recess. 18 THE VIDEOGRAPHER: Going off video record 19 2:37 p.m. 20 (A recess was taken.) 21 THE VIDEOGRAPHER: We are now back on video 22 record 2:41 p.m. 23 MR. SCAROLA: Could we have a reading how 24 much time is used in my examination. 25 SPECIAL MASTER: That's going to be CONFIDENTIAL GIUFFRE005296 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 8 of 11 205 1 irrelevant at this point, but you can ask. 2 THE VIDEOGRAPHER: It's going to be about 3 eight minutes, seven minutes of change. 4 MR. SCAROLA: Hard for me to believe that 5 but if the counter says what the counter says. 6 SPECIAL MASTER: The overtime got three 7 minutes, let's go. 8 REDIRECT EXAMINATION 9 BY MS. BORJA: 10 Q. Before you were scheduled here under oath 11 today by Mr. Scarola, did you talk to him in the break 12 before that? 13 MS. MCCAWLEY: Objection to the extent you 14 discussed privileged information with your lawyers 15 you don't have to reveal. 16 BY MS. BORJA: 17 Q. I'm asking what she talked about with Mr. 18 Scott? 19 MS. MCCAWLEY: She's in a joint defense 20 agreement with Mr. Scarola. 21 BY MS. BORJA: 22 Q. Are you in a joint defense agreement with 23 Mr. Scarola? 24 MR. SCAROLA: I will tell you that there is 25 a joint defense, a common interest privilege CONFIDENTIAL GIUFFRE005297 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 9 of 11 206 1 agreement between the witness and my clients, yes. 2 SPECIAL MASTER: Are you asserting that 3 privilege then? 4 MR. SCAROLA: Yes, we are asserting that 5 privilege and instructing the witness not to 6 answer on the basis of the privilege that exists 7 for Bradley Edwards and Professor Cassell. 8 SPECIAL MASTER: So with that I'm going to 9 grant the motion similar to what I did the other 10 day when was testifying and under 11 the reservation that that can be dealt with later 12 in front of the judge or in front of me, whichever 13 you choose. 14 BY MS. BORJA: 15 Q. Now, I understand from your testimony that 16 Mr. Edwards did not pressure you to give false 17 information about this matter, is that fair? 18 A. That's fair. 19 Q. Tell me everything that Mr. Edwards told 20 you about this matter? 21 MS. MCCAWLEY: Objection, that's privileged 22 and she has not waived any privilege. She's not 23 here testifying as to what she discussed with her 24 lawyers. 25 SPECIAL MASTER: You know, it's an CONFIDENTIAL GIUFFRE005298 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 10 of 11 207 1 interesting point. I'm going to grant your motion 2 for privilege, but I'm going to suggest to you 3 that there might be a strong argument to be made 4 that those questions opened some of the door. I'm 5 going to let the judge decide that. But you can 6 go ahead, ask the questions, we'll put it on the 7 record for later determination, and it's going to 8 force, to be blunt, this among other things may 9 force the witness to come back and complete the 10 deposition. Just let's be aware of that. 11 MS. BORJA: And I can't make a proffer to 12 all of my questions because some of them will 13 depend on this witness' answers. 14 SPECIAL MASTER: I'm aware of that. 15 MS. BORJA: I want the record to be clear 16 that although I'm being asked for a proffer, I'm 17 constrained based on my inability to follow up. 18 SPECIAL MASTER: I understand that, but I'm 19 sure that you have a couple questions that you'd 20 like to proffer to give the record an idea of 21 where you might have gone without restraint to 22 what the answer might be and then a subsequent 23 question might lead from the answer, I understand 24 that. 25 BY MS. BORJA: CONFIDENTIAL GIUFFRE005299 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1090-7 Filed 07/30/20 Page 11 of 11 208 1 Q. Did Mr. Edwards ever suggest to you 2 anything regarding 3 MS. MCCAWLEY: Objection. Hang on, I'm 4 objecting. She's making a proffer and I need to 5 make my objection on the record. Do not answer. 6 Objection, attorney/client privilege. 7 SPECIAL MASTER: So I'm going to grant 8 within the reservation it be brought back later. 9 BY MS. BORJA: 10 Q. Did Paul Cassell ever tell you anything 11 about the topics that were covered in today's deposition? 12 MS. MCCAWLEY: Objection, attorney/client 13 privilege. 14 SPECIAL MASTER: Same ruling. 15 BY MS. BORJA: 16 Q. Did anyone from Boise, Schiller ever tell 17 you anything about the topics that were covered in 18 today's deposition? 19 MS. MCCAWLEY: Objection, privileged work 20 product. 21 SPECIAL MASTER: Same ruling. 22 BY MS. BORJA: 23 Q. Did Mr. Scarola ever tell you anything 24 about the topics that were covered in today's deposition? 25 MS. MCCAWLEY: Objection, attorney/client CONFIDENTIAL GIUFFRE005300 CONFIDENTIAL