gov.uscourts.nysd.447706.1137.11_3.pdf

Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 1 of 23 EXHIBIT 1 Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 2 of 23 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 3 of 23 Page 9 1 G Maxwell - Confidential 2 form and foundation of the question. 3 Q. You can answer the question. 4 A. First of all, can you please 5 clarify the question. I don't understand 6 what you mean by female, I don't understand 7 what you mean by recruit. Please be more 8 clear and specific about what you are 9 suggesting. 10 Q. Are you a female, is that the sex 11 that you are? 12 A. I am a female. 13 Q. That's what I'm referring to a 14 female and I'm asking you when you first, the 15 very first time you recruited a female to 16 work for Mr. Epstein? 17 A. Again, I don't understand what 18 female -- I am a 54 year old women. 19 Q. I'm not making it age, any age of a 20 female that you recruited to work for Mr. 21 Epstein? 22 A. Again, I was somebody who hired a 23 number of people to work for Mr. Epstein and 24 hiring is one of my functions. 25 Q. And when is the first time you Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 4 of 23 Page 10 1 G Maxwell - Confidential 2 hired someone to work for Mr. Epstein, a 3 female? 4 A. As best as I can recollect, a woman 5 the age probably of about 40 or 50 was in 6 sometime in 1992. 7 Q. How long did you work for Mr. 8 Epstein? 9 A. I started working for him at some 10 point in 1992 and the nature of my work 11 relationship with him changed over time so 12 from around 2002, 2003, the work lessened 13 considerably. 14 Q. When did you -- 15 MR. PAGLIUCA: Can I interject for 16 a moment. If we are talking about 17 background -- 18 MS. McCAWLEY: I'm in the middle of 19 a question. Let me finish it and then 20 can you interject. 21 Q. When you say 2002 to 2003 that the 22 work lessened, when did you complete working 23 for Mr. Epstein; when was the last time you 24 were employed by him, the last date? 25 A. I believe I still was doing -- Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 5 of 23 Page 11 1 G Maxwell - Confidential 2 helping him in a very nominal way, maybe an 3 hour or two a year at sometime 2008 and 2009. 4 MR. PAGLIUCA: So if you are going 5 to be talking about general background, 6 I don't need to designate that as 7 confidential. So if you want to have 8 them come back in, that's fine. 9 I assumed by your first question 10 you were going into more sensitive 11 areas. I will leave it up to you, but 12 if this is general background it will 13 not be designated as confidential. 14 MS. McCAWLEY: I appreciate that. 15 I will jump back into my other 16 questions. 17 MR. PAGLIUCA: So we will keep it 18 as confidential. 19 Q. When you were first employed by him 20 in 1992, what were you hired to do? 21 A. First, I was consulting and what I 22 did was I helped with decorating houses and 23 in hiring staff to help run those houses. 24 Q. Did your duties change over the 25 course of 1992 to 2009? Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 6 of 23 Page 12 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. My job entailed running the homes 5 that he had but much more importantly, most 6 of the houses had construction and so whilst 7 in 1992 there was no construction project, 8 there was construction projects that began 9 after that time and I was in charge not only 10 of hiring architects, I was also in charge of 11 all the filings or overseeing that, like a 12 general contractor would. 13 I also helped with hiring the 14 architects, hiring the builders, reviewing 15 the contracts for the builders, coordinating 16 the building projects, coordinating how the 17 projects would layout, the timing of the 18 projects and all the various materials that 19 they would require to run a very substantial 20 building project. That's the nature of the 21 job I was dealing with. 22 Q. How old was the youngest female you 23 ever hired to work for Jeffrey? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 7 of 23 Page 84 1 G Maxwell - Confidential 2 30 girls -- 3 A. I did not count the number of girls 4 and I did read the police report. I can only 5 testify to what I read. 6 Q. So you are aware that the police 7 report contains reports from 30 underage 8 girls? 9 A. I can't testify to what the girls 10 said. I can only testify to the fact that I 11 read a police report that stated that. 12 Q. Were you working for Jeffrey -- you 13 said you worked for him off an on until 2009, 14 is that correct? 15 A. I helped out from time to time. 16 Q. So you were working with him during 17 the time period when these underage girls 18 were visiting Jeffrey's home? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I was not -- what year, I need 22 years. 23 Q. How about let's say 2005? 24 A. I'm not sure I was at the house at 25 all in 2005, maybe one day, maybe. Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 8 of 23 Page 89 1 G Maxwell - Confidential 2 knowledge there are 30 people -- 3 MS. McCAWLEY: Just like can you if 4 you read through -- I will not argue 5 with you counsel.. she can answer yes or 6 no. 7 Q. Are you aware there were over 30 8 individuals who were minors who gave reports 9 to police just like the one we just read that 10 they were sexually assaulted by Jeffrey 11 Epstein in the Palm Beach home during the 12 years that you were working with him? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. You can answer if 15 you have knowledge. 16 A. I already testified I was limited 17 in the house, a couple of days, there is no 18 way I knew. I have read these reports. I 19 cannot testify to 30. Given the experience 20 I've had with Virginia's lies, it's very hard 21 for me to testify about what I see. I can 22 tell from you my personal knowledge I did not 23 know what you are referring to. 24 Q. You did not know there were 25 underage girls in the home that were being Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 9 of 23 Page 90 1 G Maxwell - Confidential 2 assaulted by Jeffrey Epstein during the time 3 you were working there? 4 A. Based on the lies that I have 5 already been told, I cannot comment on any -- 6 Q. Are you saying these 30 girls are 7 lying when they gave these reports to police 8 officers? 9 A. I'm not testifying to their lies. 10 I'm testifying to Virginia's lies. 11 Q. I am not asking about Virginia's 12 lies. 13 A. I can only testify to Virginia's 14 lies. I can testify to having read these 15 reports. I cannot testify to anything else 16 about them. 17 Q. So your testimony is that during 18 the time you were working there, you did not 19 know that these minor children were being 20 abused in the home while you were there? 21 A. What I have already told you and I 22 will repeat, I was in the house very limited 23 times, very few times. I do not know what 24 you are referring to. I've read these 25 reports but based on the lies that Virginia Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 10 of 23 Page 91 1 G Maxwell - Confidential 2 has perpetrated, cannot tell you what is true 3 or factual or not. 4 Q. You said you were in the home a 5 very limited time, so average in the year for 6 example, 2004, how many times would you have 7 been in his Palm Beach home? 8 A. Very hard for me to state but very 9 little. 10 Q. How about his New York home? 11 A. Same. 12 Q. Were you his girlfriend in that 13 year, in 2004? 14 A. Define what you mean by girlfriend. 15 Q. Were you in a relationship with him 16 where you would consider yourself his 17 girlfriend? 18 A. No. 19 Q. Did you ever consider yourself his 20 girlfriend? 21 A. That's a tricky question. There 22 were times when I would have liked to think 23 of myself as his girlfriend. 24 Q. When would that have been? 25 A. Probably in the early '90s. Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 11 of 23 Page 94 1 G Maxwell - Confidential 2 Q. I'm asking the questions. I know 3 what this case is about. I'm trying to -- I 4 will ask you questions if you don't 5 understand the question I can break it down 6 for you. I'm happy to do that. 7 A. Break it down a lot please. 8 Q. I will do that. 9 The question is, have you ever said 10 to anybody that you recruit other girls -- 11 A. Why don't you stop there. 12 Q. Let me finish my question. 13 Have you ever said to anybody that 14 you recruit girls to take the pressure off 15 you, so you won't have to have sex with 16 Jeffrey, have you said that? 17 That's the question? 18 A. You don't ask me questions like 19 that. First of all, you are trying to trap 20 me, I will not be trapped. You are asking me 21 if I recruit, I told you no. Girls meaning 22 underage, I already said I don't do that with 23 underage people and as to ask me about a 24 specific conversation I had with language, we 25 talking about almost 17 years ago when this Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 12 of 23 Page 95 1 G Maxwell - Confidential 2 took place. I cannot testify to an actual 3 conversation or language that I used with 4 anybody at any time. 5 Q. Have you ever said to anybody that 6 you recruit other females over the age of 18 7 to take the pressure off you to having to 8 have sex with Jeffrey? 9 A. I totally resent and find it 10 disgusting that you use the word recruit. I 11 already told you I don't know what you are 12 saying about that and your implication is 13 repulsive. 14 Q. Answer my question. 15 A. I just did. 16 Q. Have you ever said to anybody that 17 you recruit females -- 18 A. I don't recruit anybody. 19 Q. That's an answer. So you never 20 said that? 21 A. I'm testifying that I cannot 22 testify to an actual language -- 23 Q. It's a yes or no. 24 A. I will not testify to an actual 25 statement made 17 years ago, so I cannot Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 13 of 23 Page 108 1 G Maxwell - Confidential 2 that he may have met socially through me. 3 Q. Did you ever introduce to Virginia in London? 5 A. I understand her story about London 6 but again, her tissue of lies is extremely 7 hard to pick apart what is true and what 8 isn't. Actually I wouldn't recollect her at 9 all but for her tissue stories about this 10 situation. 11 Q. So did you ever introduce to Virginia in London? 13 A. I have no recollection. 14 Q. Did Virginia ever stay at your home 15 in London, your town home? 16 A. I know she claims she did but if 17 you are asking me here today to remember 18 specifically, I cannot. 19 Q. Do you remember taking a trip with 20 Virginia to travel over to Europe, including 21 London? 22 A. So I have seen her reports and I 23 have seen the plane reports. I see she says 24 she was on that but again, I really have no 25 recollection of her. Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 14 of 23 Page 109 1 G Maxwell - Confidential 2 Q. Did you know that she was 17 at the 3 time of that trip? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I have -- 7 Q. Did you know she was 17 at the time 8 of that trip? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I didn't even know she was on the 12 trip. 13 Q. Did you hold her passport for her 14 when she was traveling? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I have no recollection whatsoever 18 of her even being on the trip nor holding her 19 passport. 20 (Maxwell Exhibit 4, picture, marked 21 for identification.) 22 Q. I'm showing you what we marked as 23 Maxwell Exhibit 4. 24 Can you take a look at that picture 25 for me? Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 15 of 23 Page 110 1 G Maxwell - Confidential 2 A. I've looked at it. 3 Q. Are you in that picture? 4 A. I am. 5 Q. 7 A. It is. 8 MR. PAGLIUCA: I don't believe this 9 has been produced to us in discovery by 10 you. 11 MS. McCAWLEY: The picture? 12 MR. PAGLIUCA: Yes. 13 MS. McCAWLEY: It has. 14 MS. MENNINGER: Is it the same 15 exact photograph. 16 MS. McCAWLEY: I believe so. We 17 will find one. The picture has been 18 produced a number of times. 19 MR. PAGLIUCA: I've seen different 20 iterations of this, I don't believe I 21 have ever seen this. 22 MS. McCAWLEY: We had them blow it 23 up on a page so she could see it. We 24 could use an article. 25 While you are looking for that, I Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 16 of 23 Page 111 1 G Maxwell - Confidential 2 will skip ahead. Hold that until we can 3 find one that has the Bates range on it. 4 Q. Do you recall Virginia being at 5 your London town home? 6 A. I do not. 7 Q. Do you recall going to dinner with 8 Jeffrey Epstein and Virginia 9 Roberts in London, at any time? 10 A. I do not. 11 Q. Do you recall going to a place 12 called , Jeffrey 13 Epstein and yourself and Virginia Roberts? 14 A. I would just like to state for the 15 record I do not have any recollection of it 21 and I doubt it actually happened. 22 Q. You don't recall that. 23 Do you recall taking Virginia 24 shopping when you were in London to buy an 25 outfit to meet Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 17 of 23 Page 120 1 G Maxwell - Confidential 2 Q. So I'm directing your attention to 3 the bottom, two lines up from the bottom, 4 there is a flight -- 5 MR. PAGLIUCA: Are you on 6 MS. McCAWLEY: 7 Q. So this flight is from, the one I'm 8 looking at, I think it's highlighted on your 9 copy. On the far corner on the date, it says 10 at the top and this would be the 11 and then the are the two I'm going to 12 direct your attention to. 13 Q. On that first one on the you 14 will see the column reading PBI in the from 15 column to TEB in the to column and you will 16 see some initials, you will see JE for 17 Jeffrey Epstein, GM for Ghislaine Maxwell, 18 for and then Virginia? 19 A. I have to object. 20 MR. PAGLIUCA: You don't get to 21 object. 22 Q. She is turning into a lawyer 23 already? 24 A. I would like to. 25 Q. Let me ask the question and if you Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 18 of 23 Page 121 1 G Maxwell - Confidential 2 have an issue -- so with respect to this 3 flight, do you recall being on a flight in 4 the -- going from Palm Beach to 5 Teterboro? 6 A. No, I don't recall any specific 7 flight. 8 Q. Do you recall flying with Virginia 9 on a flight with and Jeffrey 10 Epstein at any time? 11 A. I don't. 12 Q. How often did you fly on a plane 13 with a 17 year old? 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. I have no idea what you are talking 17 about, other than friends of mine that had 18 kids. 19 Q. Did you regularly fly on Jeffrey's 20 plane with individuals who were under the age 21 of 18? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Can you repeat the question? 25 Q. Did you regularly fly on Jeffrey Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 19 of 23 Page 122 1 G Maxwell - Confidential 2 Epstein's planes with individuals who were 3 under the age of 18? 4 A. I regularly flew on Jeffrey 5 Epstein's airplane but I cannot testify as to 6 flying with people under the age. I don't 7 believe that I did. 8 Q. Why wouldn't you remember flying 9 with a 17 year old? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. How would I know, one, that she is 13 17, how would you know that, how do you know 14 I'm on the plane. 15 Q. Are you saying you are not on this 16 flight, so this is a Palm Beach to Teterboro. 17 This says the JE, GM and Virginia. The GM 18 you are saying is not you? 19 MR. PAGLIUCA: I object to the 20 form. You can answer the question if 21 you know. 22 A. How do you know the GM is me. 23 Q. Is it your testimony that on the 24 flight logs when it represents GM that it is 25 not you flying on the plane? Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 20 of 23 Page 207 1 G Maxwell - Confidential 2 obvious lie that you approached Virginia 3 while she was under age at Mar-a-Lago? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. First of all, we can all agree 7 here, all of you sitting here that the lies 8 that you perpetrated in the press that she 9 was 15 and we should all agree now that that 10 is fake, a lie that was perpetrated between 11 all of you to make the story more exciting, 12 can we agree on that? 13 Q. That is not my question. 14 A. Can we agree she was not the age 15 she said and you put that in the press, that 16 is obviously, manifestly, absolutely, totally 17 a lie. 18 MS. McCAWLEY: I am going to put on 19 the record, Ms. Maxwell very 20 inappropriately and very harshly pounded 21 our law firm table in an inappropriate 22 manner. I ask she take a deep breath, 23 and calm down. I know this is a 24 difficult position but physical assault 25 or threats is not appropriate, so no Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 21 of 23 Page 208 1 G Maxwell - Confidential 2 pounding, no stomping, no, that's not 3 appropriate,. 4 A. Can we be clear, I didn't threaten 5 anybody. 6 MR. PAGLIUCA: Stop, you made your 7 record, there is no dent in the table. 8 I don't see any chips. Can we take a 9 break now. 10 MS. McCAWLEY: I think it's 11 appropriate to take a break. 12 THE VIDEOGRAPHER: It's 1:56 and we 13 are off the record. 14 (Recess.) 15 THE VIDEOGRAPHER: It's now 2:13, 16 we're starting disk No. 5 and we are 17 back on the record. 18 Q. Ms. Maxwell, how old was Virginia 19 Roberts when you met her in Mar-a-Lago? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I know today that she was 17 years 23 old. 24 Q. Are you saying that it's an obvious 25 lie that Virginia traveled on Jeffrey Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 22 of 23 Page 410 1 G Maxwell - Confidential 2 Q. Were there other flights that you 3 recall flying on with Jeffrey Epstein that 4 were on flights that -- where was 5 not the pilot? 6 A. was not always the 7 pilot. 8 Q. How many planes did Jeffrey Epstein 9 have during the time you were with him? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. So you need to give me a date 13 range. 14 Q. During the time period of 1992 15 through when you left your employment which I 16 think you said was in 2009? 17 A. So in the '90s he had one plane and 18 at some point in the 2000s he had two planes 19 but I can't testify to anything past 2002, 20 2003, what happened to his planes after that. 21 Q. Do you know what travel agency, if 22 any, Jeffrey would use when he would send 23 someone, for example, you or one of his other 24 employees on a flight somewhere? Did he use 25 a particular travel agency to make those Case 1:15-cv-07433-LAP Document 1137-11 Filed 10/22/20 Page 23 of 23 Page 417 1 2 ACKNOWLEDGMENT OF DEPONENT 3 I, , do hereby 4 certify that I have read the foregoing pages, and that the same is a correct transcription 5 of the answers given by me to the questions therein propounded, except for the 6 corrections or changes in form or substance, if any, noted in the attached Errata Sheet. 7 8 9 GHISLAINE MAXWELL DATE 10 11 Subscribed and sworn to before me this 12 day of , 2016. 13 My commission expires: 14 Notary Public 15 16 17 18 19 20 21 22 23 24 25