gov.uscourts.nysd.447706.1137.3_1.pdf

Case 1:15-cv-07433-LAP Document 1137-3 Filed 10/22/20 Page 1 of 7 EXHIBIT 2 Case 1:15-cv-07433-LAP Document 1137-3 Filed 10/22/20 Page 2 of 7 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 12 00 Avenue of the Americas New York, New York 10026 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-3 Filed 10/22/20 Page 3 of 7 Page 2 1 2 APPEARANCES: 3 BOIES SCHILLER & FLEXNER , LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdatle , Florida , 333 01 BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ , ESQUIRE EMMA ROSEN, PARALEGAL 7 8 FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN , P.L. Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 333 01 11 BY: BRAD EDWARDS, ESQUIRE 12 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City , Utah 84112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 802 03 BY: JEFFREYS. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE 20 21 Also Present: 22 James Christe , videographer 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-3 Filed 10/22/20 Page 4 of 7 Page 19 1 G Maxwell - Confidential 2 absolutely everything that took place in that 3 first meeting. She has lied repeatedly , 4 often and is just an awful fantasist. So 5 very difficult for anything to take place 6 that she repeated because I was with her 7 mother the entire time. 8 Q. So did you have - - did you give a 9 massage with Virginia Roberts and Mr. Epstein 10 during the first time Virginia Roberts was at 11 the West Palm Beach house? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 Q. Yes or no? 15 A. No. 16 Q. Have you ever given a massage with 17 Virginia Roberts ln the room and Jeffrey 18 Epstein? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. No. 22 Q. Have you ever given Jeffrey Epstein 23 a massage? 24 MR. PAGLIUCA: Object to the form , 25 foundation. And I ' m going to instruct MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-3 Filed 10/22/20 Page 5 of 7 Page 2 0 1 G Maxwell - Confidential 2 you not to answer that question. I 3 don't have any problem with you asking 4 questions about what the subject matter 5 of this lawsuit is, which would be, as 6 you've termed it, sexual trafficking of 7 Ms. Roberts . 8 To the extent you are asking for 9 information relating to any consensual 10 adult interaction between my client and 11 Mr. Epstein, I'm going to instruct her 12 not to answer because it ' s not part of 13 this litigation and it is her private 14 confidential information , not subject to 15 this deposition. 16 MS. MCCAWLEY: You can instruct her 17 not to answer. That is your right. But 18 I will bring her back for another 19 deposition because it is part of the 20 subject matter of this litigation so she 21 should be answering these questions. 22 This is civil litigation, deposition and 23 she should be responsible for answering 24 these questions. 25 MR. PAGLIUCA: I disagree and you MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-3 Filed 10/22/20 Page 6 of 7 Page 21 1 G Maxwell - Confidential 2 understand the bounds that I put on it. 3 MS. McCAWLEY: No, I don't. I will 4 continue to ask my questions and you can 5 continue to make your objections . 6 Q. Did you ever participate from the 7 time period of 1992 to 2 00 9, did you ever 8 participate in a massage with Jeffrey Epstein 9 and another female? 10 MR. PAGLIUCA: Objection. Do not 11 answer that question. Again, to the 12 extent you are asking for some sort of 13 illegal activity as you've construed in 14 connection with this case I don't have 15 any problem with you asking that 16 question. To the extent these questions 17 involve consensual acts between adults, 18 frankly, they're none of your business 19 and I will instruct the witness not to 20 answer. 21 MS. McCAWLEY: This case involves 22 sexual trafficking , sexual abuse, 23 questions about her having interactions 24 with other females is relevant to this 25 case. She needs to answer these MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1137-3 Filed 10/22/20 Page 7 of 7 Page 22 1 G Maxwell - Confidential 2 questions. 3 MR. PAGLIUCA: I 'm instructing her 4 not to answer. 5 MS. McCAWLEY: Then we will be back 6 here again. 7 Q. Have you ever given a massage to 8 Mr. Epstein with a female that was under the 9 age of 18? 10 A. Can you repeat the question? 11 Q. Yes . Have you ever given a massage 12 to Mr. Epstein with a female that was under 13 the age of 18? 14 A. No. 15 Q. Have you ever observed Mr. Epstein 16 having a massage given by an individual, a 17 female, who was under the age of 18? 18 A. No. 19 Q. Have you ever observed females 20 under the age of 18 in the presence of 21 Jeffrey Epstein at his home? 22 MR. PAGLIUCA: Object to the form 23 and foundation. 24 A. Again, I have friends that have 25 children MAGNA9 LEGAL SERVICES