1320-30.pdf

Case 1:15-cv-07433-LAP Document 1320-30 Filed 01/03/24 Page 1 of 27 EXHIBIT D Case 1:15-cv-07433-LAP Document 1320-30 Filed 01/03/24 Page 2 of 27 GIUFFRE vs. MAXWELL Deposition VIRGINIA GIUFFRE 05/03/2016 Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 3 of 27 01/03/24 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May 3, 2016 VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. APPEARANCES: FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954.524.2820 [email protected] Appearing on behalf of the Plaintiff BOIES, SCHILLER & FLEXNER LLP By Sigrid S. Mccawley, Esq. (For Portion) 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Phone: 954.356.0011 [email protected] Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016 1  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 4 of 27 01/03/24 1 APPEARANCES: (Continued) 2 HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. 3 Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue 4 Denver, CO 80203 Phone: 303.831.7364 5 [email protected] [email protected] 6 Appearing on behalf of the Defendant 7 Also Present: 8 Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 2  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 5 of 27 01/03/24 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF 3 VIRGINIA GIUFFRE, called by Defendant, was taken on 4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150 5 East 10th Avenue, Denver, Colorado, before Kelly A. 6 Mackereth, Certified Shorthand Reporter, Registered 7 Professional Reporter, Certified Realtime Reporter 8 and Notary Public within Colorado. 9 * * * * * * * 10 I N D E X 11 EXAMINATION PAGE 12 MS. MENNINGER 8 13 14 PRODUCTION REQUEST(S): 15 (None. ) 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 3  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 6 of 27 01/03/24 1 wanted to know about the Prince Andrew incident. 2 Q So that's a different piece of paper? 3 A Yeah, that's just random paper. 4 Q So you had a green spiral notebook that 5 you began sometime in 2011 or 2012 in which you wrote 6 down your recollections about what had happened to 7 you, and you burned that in a bonfire in 2013. 8 Did I get that right? 9 A You got that right. 10 Q And do you have no other names of people 11 to whom you claim Ghislaine Maxwell directed you to 12 have sex, correct? 13 A At this time, no. 14 Q Is there any document that would refresh 15 your recollection that you could look at? 16 A If you have a document you'd like to show 17 me, I would be glad to look at it and tell you the 18 names I recognize off of that. 19 Q I'm just asking you if there's a document 20 you know of that has this list of names in it? 21 A Not in front of me, no. 22 Q Where is the original of the photograph 23 that has been widely circulated in the press of you 24 with Prince Andrew? 25 A I probably still have it. It's not in my VIRGINIA GIUFFRE 5/3/2016 208  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 7 of 27 01/03/24 1 possession right now. 2 Q Where is it? 3 A Probably in some storage boxes. 4 Q Where? 5 A In Sydney. 6 Q Where in Sydney? 7 A At some family's house. We got the boxes 8 shipped to Australia, and they were picked up off the 9 porch by my nephews and brought to their house. 10 Q Which is where? 11 A In Sydney. 12 Q Where in Sydney? 13 A Bass Hill. 14 Q And who lives in that house? 15 A Well, it's owned by my mother-in-law and 16 father-in-law, but my nephews live in the house. 17 Q What are their names? 18 A I'm not giving you the names of my 19 nephews. 20 Q What's the address of the house? 21 A Why would you want that? 22 Q I want to know where the photograph is. 23 I'm asking you where the photograph is. And you've 24 just told me it's somewhere in Bass Hill? 25 A Yes. VIRGINIA GIUFFRE 5/3/2016 209  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 8 of 27 01/03/24 1 Q So where in Bass Hill is the photograph 2 located? 3 A If I can't 100 percent say that the 4 photograph is there, it could be at my house that I 5 presently live in. I'm not going to give you the 6 address of my nephews' residence. 7 Q When is the last time you saw the 8 photograph in person? 9 A When I packed and left America. 10 Q Colorado? 11 A Yes. 12 Q All right. So you had that photograph 13 here with you in Colorado? 14 A Yes. 15 Q What's on the back of the photograph? 16 A I'm sorry? 17 Q Is there anything on the back of the 18 photograph? 19 A There's like the date it was printed, but 20 no writing or anything. 21 Q Okay. Does it say where it was printed? 22 A I don't believe so. I think it just I 23 don't remember. I just remember there's a date on 24 it. 25 Q Whose camera was it taken with? VIRGINIA GIUFFRE 5/3/2016 210  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 9 of 27 01/03/24 1 A My little yellow Kodak camera. 2 Q Who took the picture? 3 A Jeffrey Epstein. 4 Q And where did you have it developed? 5 A I believe when I got back to America. 6 Q So where? 7 A I don't know. 8 Q Palm Beach? 9 A I don't know. 10 Q What is the date the photograph was 11 printed? 12 A I believe it's in March 2001. 13 Q Okay. 14 A But that's just off of my photographic 15 memory. I don't -- it could be different, but I 16 think it's March 2001. 17 Q You have a photographic memory? 18 A I'm not saying I have a photographic 19 memory. But if I'd look at the back of the photo and 20 I remember what it says, I believe it was March 2001. 21 Q Did the photograph ever leave your 22 possession for a while? 23 A I gave it to the FBI. 24 Q Okay. And when did you get it back? 25 A When they took copies of it. VIRGINIA GIUFFRE 5/3/2016 211  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 10 of 27 01/03/24 1 Q When was that? 2 A 2011. 3 Q When they came to interview you? 4 A Yes. 5 Q So from 2011 until you left Colorado it 6 was in your personal possession? 7 A Yes. 8 Q What other documents related to this case 9 are in that, storage boxes in Australia? 10 MR. EDWARDS: Object to the form. 11 A Documents related to this case -- there 12 I don't know. I really can't tell you. I mean, 13 there's seven boxes full of Nerf guns, my kids' toys, 14 photos. I don't know what other documents would be 15 in there. 16 Q (BY MS. MENNINGER) Did anyone search 17 those documents after you received discovery requests 18 from us in this case? 19 A I haven't been able to obtain those boxes. 20 I can't get them sent back up to me. It's going to 21 cost me a large amount of money. And right now I'm 22 trying to look after my family, so I'm not able to 23 afford to get them up. 24 Q You live in Australia, correct? 25 A I do. VIRGINIA GIUFFRE 5/3/2016 212  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 11 of 27 01/03/24 1 Q Okay. How far away are the boxes from 2 where you live in Australia? 3 A Sydney is down here at the bottom. Cairns 4 is up here at the top. 5 Q Okay. 6 A It's probably a six-day drive. 7 Q Did you fly here through Sydney? 8 A No. 9 Q Have you been to Sydney since you've moved 10 back to Australia? 11 A I flew into Sydney with my three kids, but 12 it was a connecting flight to Brisbane. 13 Q Did you ask your nephews or anyone else to 14 search those boxes in response to discovery requests 15 that we issued in this case? 16 A They are my nephews. I would never let 17 them look at those. 18 Q Other than your green spiral notebook, 19 what else did you burn in this bonfire in 2013? 20 A That was it. 21 Q That's the only thing? 22 A Yes. 23 Q Did you use wood? 24 A Yes. 25 Q Charcoal? VIRGINIA GIUFFRE 5/3/2016 213  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 12 of 27 01/03/24 1 A My husband built the bonfire out of wood 2 and I don't know what else he put in it. He's the 3 one who always makes the fires, not me. 4 Q Who else was present? 5 A Just him and I. 6 Q Were your kids there? 7 A No. They were inside sleeping. 8 Q And what beach was this? 9 A It wasn't a beach. It was in my backyard. 10 Q What's your address? 11 A At that time? 12 Q Um-hum. 13 A Jane Doe 2 14 Q Jane Doe 2 15 A Yes. 16 Q Who were your neighbors? 17 A Sweet people. Ray and -- I could look on 18 my phone if you want. 19 Q No, thank you. Do they still live there? 20 A Yes. 21 Q Do you keep in touch with them? 22 A Last time I talked to them was a few 23 months ago. 24 Q Did they see the fire? 25 A They've seen many fires that we've had. VIRGINIA GIUFFRE 5/3/2016 214  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 13 of 27 01/03/24 1 We've had lots of bonfires there. 2 Q Did you ever ride in a helicopter with 3 Ghislaine Maxwell acting as pilot of the helicopter? 4 A Yes. 5 Q Who else was on the flight? 6 A I've been on the helicopter with her 7 plenty of times. I can't mention how many people 8 were on the -- on the helicopter at the same time. 9 Q How many times? 10 A I don't know. Do you have helicopter 11 records that you could show me? 12 Q I'm asking you how many times you were on 13 the helicopter with Ghislaine Maxwell acting as the 14 pilot -- 15 A It's impossible for me to answer the 16 question without having the actual physical records 17 in front of me. 18 Q I'm asking you to look into your memory 19 and tell me how many times you recall being on a 20 helicopter with Ghislaine Maxwell at the pilot seat? 21 A There is no number I can give you. 22 There's plenty of times I've been on her helicopter. 23 Q Where did you go from and to on a 24 helicopter? 25 A I believe it was -- don't quote me on this VIRGINIA GIUFFRE 5/3/2016 215  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 14 of 27 01/03/24 1 because I get confused on the islands there. I want 2 to say it was St. John's. It could have been 3 St. Barts. St. John or St. Barts, and then we would 4 fly straight to Jeffrey's island. 5 Q Okay. Did you ever go anywhere else on 6 the helicopter? 7 A No. 8 Q Were you ever on the helicopter with Bill 9 Clinton and Ghislaine Maxwell as the pilot of the 10 helicopter? 11 A No. 12 Q Were you ever on the helicopter with Bill 13 Clinton's Secret Service and Ghislaine Maxwell as the 14 pilot? 15 A No. 16 Q Do you recall telling Sharon Churcher that 17 you were? 18 A No. 19 Q Did you see the press article in which 20 Sharon Churcher reported that you were? 21 MR. EDWARDS: Objection. I'd just ask 22 that if you're going to ask this witness about a 23 specific article I'd like for her to see the article. 24 Otherwise she's not going to testify about it. 25 If you have something to show her, then, VIRGINIA GIUFFRE 5/3/2016 216  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 15 of 27 01/03/24 1 please. 2 Q (BY MS. MENNINGER) Do you recall seeing a 3 press article in which Sharon Churcher reported that 4 you were on a helicopter with Bill Clinton and 5 Ghislaine Maxwell as the pilot? 6 MR. EDWARDS: Again, I'll let you answer 7 the question once she's looking at the document that 8 you're being asked about. 9 MS. MENNINGER: You're not letting her 10 answer a question about whether she recalls a 11 particular press statement? 12 MR. EDWARDS: I will let her answer every 13 question about the press statement as long as she 14 sees the press statement. I'm okay with that. She 15 can answer all of them. 16 MS. MENNINGER: No, there is a rule of 17 civil procedure that allows you to direct a witness 18 not to answer a question when there's a claim of 19 privilege. 20 What privilege are you claiming to direct 21 her not to answer this question? 22 MR. EDWARDS: I thought that you wanted 23 accurate answers from this witness. If the 24 MS. MENNINGER: I asked her if she 25 recalled something -- VIRGINIA GIUFFRE 5/3/2016 217  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 16 of 27 01/03/24 1 MR. EDWARDS: If the sole purpose is to 2 just to harass her -- 3 MS. MENNINGER: I asked her if she 4 recalled something -- 5 MR. EDWARDS: Then that's just not going 6 to be what's happening today. 7 Q (BY MS. MENNINGER) All right. So you're 8 refusing to answer a question about whether you 9 recall a particular press statement 10 MR. EDWARDS: She's -- 11 Q (BY MS. MENNINGER) -- is that true? 12 MR. EDWARDS: She is not refusing to 13 answer any questions. She -- 14 A I'm not refusing to answer. I just want 15 to see the article you're talking about so I can be 16 clear in my statement. 17 Q (BY MS. MENNINGER) Do you recall seeing a 18 press article written by Sharon Churcher reporting 19 that you flew on a helicopter with Bill Clinton and 20 Ghislaine Maxwell as the pilot? 21 A No, I do not recall reading a press 22 article saying that I was on a helicopter with Bill 23 Clinton as Ghislaine is the pilot. 24 Q Do you recall telling Sharon Churcher that 25 you had conversations with Bill Clinton regarding him VIRGINIA GIUFFRE 5/3/2016 218  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 17 of 27 01/03/24 1 flying on a helicopter with Ghislaine Maxwell? 2 A I believe that it was taken out of 3 context. Ghislaine told me that she flew Bill 4 Clinton in. And Ghislaine likes to talk a lot of 5 stuff that sounds fantastical. And whether it's true 6 or not, that is what I do recall telling Sharon 7 Churcher. 8 Q So you told Sharon Churcher that Ghislaine 9 Maxwell is the one who told you that she flew Bill 10 Clinton in the helicopter? 11 A I told Sharon Churcher that Ghislaine flew 12 Bill Clinton onto the island, based upon what 13 Ghislaine had told me. 14 Q Not based upon what Bill Clinton had told 15 you, correct? 16 A Correct. 17 Q Did you ever ask Sharon Churcher to 18 correct anything that was printed under her name, 19 concerning your stories to Sharon Churcher? 20 A I wasn't given those stories to read 21 before they were printed. 22 Q After they were printed did you read them? 23 A I tried to stay away from them. They were 24 very hard. You have to understand it was a very hard 25 time for me and my husband to have to have this VIRGINIA GIUFFRE 5/3/2016 219  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 18 of 27 01/03/24 1 public -- we didn't think it was going to be this 2 publicly announced and that big. So we turned off 3 the news and we stopped reading so many things. 4 Q You didn't read the articles about your 5 stories to Sharon Churcher 6 A I've read some articles 7 Q Let me just finish. You did not read the 8 articles published by Sharon Churcher about your 9 stories to Sharon Churcher? 10 A I have read some articles about what 11 Sharon Churcher wrote. And a lot of the stuff that 12 she writes she takes things from my own mouth and 13 changes them into her own words as journalists do. 14 And I never came back to her and told her 15 to correct anything. What was done was done. There 16 was nothing else I can do. 17 Q So even if she printed something that were 18 untrue you didn't ask her to correct it, correct? 19 A There was things that she printed that 20 really pissed me off, but there was nothing I could 21 do about it. It's already out there. 22 Q She printed things that were untrue, 23 correct? 24 MR. EDWARDS: Objection to the form. 25 Mischaracterization. VIRGINIA GIUFFRE 5/3/2016 220  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 19 of 27 01/03/24 1 A I wouldn't say that they were untrue. I 2 would just say that she printed them as journalists 3 take your words and turn them into something else. 4 Q (BY MS. MENNINGER) She got it wrong? 5 MR. EDWARDS: Object to the form. 6 Mischaracterization. 7 A In some ways, yes. 8 Q (BY MS. MENNINGER) Did she print things 9 in her articles that you did not say to her? 10 MR. EDWARDS: I object and ask that the 11 witness be given the opportunity to see the document 12 so that she can review it and answer that question 13 accurately. Otherwise she's unable to answer the 14 question. I'm not going to allow her to answer. 15 MS. MENNINGER: You know the civil rules 16 tell you not to suggest answers to your client. 17 Q (BY MS. MENNINGER) And you understand 18 your lawyer is now directing you to not all of a 19 sudden remember what your answer is. That's what 20 he's suggesting that you say. So you're not supposed 21 to listen to him suggest that to you. You're 22 supposed to tell me from your memory. 23 MR. EDWARDS: That is not what I'm -- 24 Q (BY MS. MENNINGER) Did you -- 25 MR. EDWARDS: That's not what I'm doing. VIRGINIA GIUFFRE 5/3/2016 221  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 20 of 27 01/03/24 1 You don't get to just talk over me and 2 tell my client when not to listen to me. All you 3 have to do to get answers is show her the document 4 you're talking about, and I'll let her answer every 5 question. I don't know why we're so scared of the 6 actual documents. 7 MS. MENNINGER: I don't know why you're 8 scared of your client's recollection, Mr. Edwards. 9 But anyway 10 MR. EDWARDS: Why would you do this to 11 her? 12 Q (BY MS. MENNINGER) Did Sharon Churcher 13 print things that you did not say? 14 MR. EDWARDS: I'm going to instruct my 15 client not to answer unless you give her what it is 16 that you're talking about that was printed. And she 17 will tell you the answer, the accurate answer to your 18 question. Just without the document to refresh her 19 recollection and see it, she's not going to answer 20 the question. 21 Q (BY MS. MENNINGER) Did Sharon Churcher 22 print things that you did not say? 23 MR. EDWARDS: Same objection. Same 24 instruction not to answer. 25 I think I've made a very clear record as VIRGINIA GIUFFRE 5/3/2016 222  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 21 of 27 01/03/24 1 to why I want my client to answer all of these 2 questions, but I want her to have the fair 3 opportunity to see this document. 4 Q (BY MS. MENNINGER) Did Sharon Churcher 5 print things that you felt were inaccurate? 6 MR. EDWARDS: Same objection. Same 7 instruction. If she sees the document, she's going 8 to answer every one of these questions. 9 Q (BY MS. MENNINGER) Did any other reporter 10 print statements that you believe are inaccurate? 11 MR. EDWARDS: Same objection. Same 12 instruction. 13 Q (BY MS. MENNINGER) Did any reporter print 14 statements about Ghislaine Maxwell that were 15 inaccurate? 16 MR. EDWARDS: Same objection. Same 17 instruction. 18 This is harassing. This is harassing a 19 sexual abuse victim. And all I'm asking is for 20 fairness, that we just let her see the document so 21 she can answer this. 22 MS. MENNINGER: Mr. Edwards, please stop 23 saying anything other than an objection, what the 24 basis is, or instructing your client not to answer. 25 MR. EDWARDS: I will do that. VIRGINIA GIUFFRE 5/3/2016 223  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 22 of 27 01/03/24 1 MS. MENNINGER: That's what the Federal 2 Rules of Civil Procedure provide. 3 MR. EDWARDS: I hear you. They also 4 provide for fairness and civility. And all I'm 5 asking, very calmly, is for her to see this. 6 MS. MENNINGER: Mr. Edwards, this is not 7 your deposition. I'm asking your client what she 8 remembers. If she doesn't want to talk about what 9 she remembers, then let her not answer. But you 10 cannot instruct her not to answer unless there's a 11 privilege. 12 What privilege -- 13 MR. EDWARDS: I am instructing her not to 14 answer. 15 Q (BY MS. MENNINGER) All right. You are 16 refusing to answer questions about whether statements 17 to the press about Ghislaine Maxwell attributed to 18 you were inaccurate? 19 MR. EDWARDS: She's not refusing not to 20 answer. 21 A You are refusing to show me these 22 documents so I could answer properly. I would give 23 you an answer if you were to show me some documents. 24 Q (BY MS. MENNINGER) You can't say without 25 looking at a document whether the press attributed to VIRGINIA GIUFFRE 5/3/2016 224  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 23 of 27 01/03/24 1 you is accurate or inaccurate? 2 A Please show me the document. 3 Q You can't say from the top of your head 4 whether any inaccurate statement has been attributed 5 to you in the press? 6 A Please show me a document and I will tell 7 you. 8 Q Are you refusing to answer my questions 9 about your knowledge of whether inaccurate statements 10 have been attributed to you in the press? 11 A Are you refusing to give me the documents 12 to look at? 13 Q Are you refusing to answer the question? 14 A I am refusing to answer the question based 15 upon the fact that you are not being fair enough to 16 let me see the document in order to give you an 17 honest answer. 18 Q Ms. Giuffre 19 A Yes. 20 Q -- we are talking about press that has 21 been published on the Internet, correct? 22 A Yes. 23 Q Do you have access to the Internet? 24 A Yes. 25 Q Have you looked on the Internet and read VIRGINIA GIUFFRE 5/3/2016 225  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 24 of 27 01/03/24 1 articles that attribute statements to you about 2 Ghislaine Maxwell? 3 A Yes. 4 Q Do you know any statement that has been 5 attributed to you in a press article on the Internet 6 about Ghislaine Maxwell that is untrue? 7 MR. EDWARDS: Same objection. Same 8 instruction. 9 A Please show me a specific document. 10 Q (BY MS. MENNINGER) Do you know of any 11 such statement about Ghislaine Maxwell attributed to 12 you by the press that is inaccurate? 13 A If you could please show me a specific 14 document. 15 Q Tell me what Sharon Churcher asked you to 16 write for her. 17 A Any knowledge that I had about my time 18 with Prince Andrew. 19 Q And did you write it? 20 A Um-hum. 21 Q What did you write it in or on? 22 A Paper. 23 Q What kind of paper? 24 A Lined paper. 25 Q Was it in a book or single sheets? VIRGINIA GIUFFRE 5/3/2016 226  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 25 of 27 01/03/24 1 A Single sheets. 2 Q And did you write a long document or a 3 short document? What was it? 4 A I can't recall how long the document was, 5 but I would say it would be a few pages. 6 Q And other than asking you to write 7 whatever you remember about Prince Andrew, did she 8 give you any other directions about what you should 9 write? 10 A She was interested in two things, really. 11 How Epstein got away with so many counts of child 12 trafficking for sex and how Prince Andrew was 13 involved in it. Those were her two main inquiries. 14 Q What did she ask you to write? 15 A She asked me to write about Prince Andrew. 16 Q Did she tell you to put it in your own 17 handwriting? 18 A No, she just asked me to write down what I 19 can remember. 20 Q Did you give her everything that you 21 wrote? 22 A Did I give her the whole entire pages that 23 I wrote? 24 Q Yes. 25 A Yeah, I wrote pages for her specifically. VIRGINIA GIUFFRE 5/3/2016 227  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 26 of 27 01/03/24 1 Q In your own handwriting? 2 A In my own handwriting. 3 Q And what you wrote, was that true? 4 A Yes. 5 Q And did you get paid for those pieces of 6 paper? 7 A Not for the papers, I don't believe. 8 Q Okay. Have you gotten paid when they've 9 been reprinted? 10 A No. 11 Q Have you negotiated any deal with Radar 12 Online? 13 A No. 14 Q Have you negotiated any deal with Sharon 15 Churcher for the purpose of publishing those pieces 16 of paper? 17 A Not those pieces of paper. 18 Q When did you write those pieces of paper? 19 MR. EDWARDS: Object to the form. 20 A A week before she came out. 21 Q (BY MS. MENNINGER) And when did you give 22 them to her? 23 A When she came out. 24 Q When was that? 25 A Sometime, I believe, in early 2011. VIRGINIA GIUFFRE 5/3/2016 228  Agren Blando Case 1:15-cv-07433-LAP Court Reporting Document & Video, 1320-30 Filed Inc. Page 27 of 27 01/03/24 1 Q What did you get paid for, if not for 2 those pieces of paper? 3 MR. EDWARDS: Object to the form. 4 A I was paid for the picture with Prince 5 Andrew with his arm around me, Ghislaine in the 6 background. And I was paid for the, I guess, the 7 print of the stories. 8 Q (BY MS. MENNINGER) Anything else? 9 A No. 10 Q You were not paid for those pieces of 11 paper? 12 A No. 13 Q All right. And how many pieces of paper 14 did you write? 15 A Like I said, I'm rounding it around three. 16 Q Three pieces of paper? 17 A That's what I -- I don't remember to be 18 exact on a number. I'm sorry. But over three pages. 19 Q And you wrote those sometime in 2011? 20 A The week that she was coming out to see 21 me. 22 Q And you gave them to her, right? 23 A I gave them to her. 24 Q Did you keep a copy of that? 25 A No. VIRGINIA GIUFFRE 5/3/2016 229