gov.uscourts.nysd.447706.1296.10.pdf

EXHIBIT 1 (FILE UNDER SEAL)  Highly Confidential Page 1 HIGHLY CONFIDENTIAL AEO UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -----------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. Case No: 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. -----------------------------x HIGHLY CONFIDENTIAL DEPOSITION OF SARAH RANSOME NEW YORK, NEW YORK Friday, February 17, 2017 Reported by: JEREMY RICHMAN JOB NO: 300491 MAGNA LEGAL SERVICES 320 West 37th Street, 12th Floor New York, New York 10018 (866) 624-6221  Highly Confidential Page 2 1 HIGHLY CONFIDENTIAL AEO 2 3 4 February 17, 2017 5 9:00 a.m. 6 7 DEPOSITION of SARAH RANSOME, held 8 at the offices of Boies, Schiller & Flexner, 9 575 Lexington Avenue, New York, New York, 10 before JEREMY RICHMAN, a Shorthand Reporter and 11 Notary Public of the State of New York. 12 13 14 15 16 17 18 19 20 21 22 23 24 25  Highly Confidential Page 3 1 HIGHLY CONFIDENTIAL AEO 2 APPEARANCES: 3 4 BOIES, SCHILLER & FLEXNER, LLP 5 Attorneys for plaintiff 6 401 East Las Olas Boulevard, Suite 1200 7 Fort Lauderdale, FL 33301-2211 8 BY: SIGRID STONE MCCAWLEY, ESQ. 9 ([email protected]) 10 11 12 HADDON, MORGAN AND FOREMAN, P.C 13 Attorneys for Defendant 14 150 East 10th Avenue 15 Denver, CO 80230 16 BY: LAURA A. MENNINGER, ESQ. 17 JEFFREY S. PAGLIUCA, ESQ. 18 ([email protected]) 19 ([email protected]) 20 21 22 23 24 25  Highly Confidential Page 4 1 HIGHLY CONFIDENTIAL AEO 2 APPEARANCES (Continued): 3 4 J. STANLEY POTTINGER, PLLC 5 Attorneys for the witness 6 49 Twin Lakes Road, Suite 100 7 South Salem, NY 10590 8 BY: J. STANLEY POTTINGER, ESQ. 9 ([email protected]) 10 11 12 MINTZ & GOLD, LLP 13 Attorneys for the witness 14 600 Third Avenue 15 New York, NY 10016 16 BY: PETER GUIRGUIS, ESQ. 17 ([email protected]) 18 19 20 ALSO PRESENT: 21 GHISLAINE MAXWELL, via teleconference 22 23 24 25  Highly Confidential Page 5 1 HIGHLY CONFIDENTIAL AEO 2 IT IS HEREBY STIPULATED AND AGREED 3 by and between the attorneys for the respective 4 parties herein, that filing and sealing be and 5 the same are hereby waived. 6 IT IS FURTHER STIPULATED AND AGREED 7 that all objections, except as to form of the 8 question, shall be reserved to the time of the 9 trial. 10 IT IS FURTHER STIPULATED AND AGREED 11 that the within deposition may be sworn to and 12 signed before any officer authorized to 13 administer an oath, with the same force and 14 effect as if signed and sworn to before the 15 Court. 16 17 18 19 20 - oOo - 21 22 23 24 25  Highly Confidential Page 6 1 HIGHLY CONFIDENTIAL AEO 2 MS. MENNINGER: If we could 3 have counsel enter their 4 appearances for the record, 5 please. 6 MR. GUIRGUIS: Sure. My 7 name is Peter Guirguis. I'm 8 appearing on behalf of the 9 witness today. 10 MS. MCCAWLEY: Sigrid 11 McCawley on behalf of Virginia 12 Giuffre, the plaintiff in the 13 action. 14 MR. POTTINGER: Stan 15 Pottinger on behalf of the 16 witness. 17 MS. MENNINGER: Laura 18 Menninger and Jeffrey Pagliuca on 19 behalf of Ms. Maxwell, who is 20 appearing by telephone. 21 SARAH RANSOME, having been 22 called as a witness, having first 23 been duly sworn by a Notary 24 Public (Jeremy Richman) of the 25 State of New York, was examined  Highly Confidential Page 7 1 HIGHLY CONFIDENTIAL AEO 2 and testified as follows: 3 EXAMINATION BY 4 MS. MENNINGER: 5 Q. Good morning, Ms. Ransome. 6 A. Good morning. 7 Q. Can you please give us your 8 full name. 9 A. Sarah Emma Ashley Ransome. 10 Q. And what is your birth date? 11 A. 12 Q. And what is your current 13 address? 14 MR. GUIRGUIS: I'm going to 15 object to current address. 16 Q. You can answer. 17 MR. GUIRGUIS: You can give 18 your last permanent address. 19 A. 20 (An off-the-record 21 discussion was held.) 22 A. 24 Q. And what does that mean, 25 that's your last permanent address?  Highly Confidential Page 8 1 HIGHLY CONFIDENTIAL AEO 2 A. I reside there. 3 Q. Do you rent an apartment? 4 A. My partner does. 5 Q. Who is your partner? 6 MR. GUIRGUIS: Objection. 7 Q. Who is your partner? 8 THE WITNESS: Do I have to 9 answer that? 10 MR. GUIRGUIS: Yes. 11 A. 12 Q. I'm sorry? 13 A. 14 Q. How do you spell that last 15 name? 16 A. 17 Q. And how long has been 18 your partner? 19 MR. GUIRGUIS: I'm going to 20 object. I'm not sure what the 21 relevance of this is or where 22 you're going with this. 23 Q. How long has been your 24 partner? 25 THE WITNESS: Sorry, can I  Highly Confidential Page 9 1 HIGHLY CONFIDENTIAL AEO 2 just ask a question? I would 3 like to just clarify. When you 4 say objection, does that mean I 5 actually have to answer the 6 question? Because that's 7 irrelevant. 8 MR. GUIRGUIS: Right. 9 Unless I'm telling you not to 10 answer, you need to answer. 11 THE WITNESS: So I don't 12 need to answer? 13 MR. GUIRGUIS: No, you do 14 need to answer this. 15 A. Okay. We've been together 16 almost a year. 17 Q. And what is your current 18 occupation? 19 A. I'm a writer. 20 Q. And what do you write? 21 A. Just stuff, you know? Just 22 about factual stuff. You know, just a 23 bit of this, bit of that. 24 Q. Have you been paid for any 25 of your writing?  Highly Confidential Page 10 1 HIGHLY CONFIDENTIAL AEO 2 A. No. It's more of a hobby, 3 really. 4 Q. Are you employed? 5 A. Nope. 6 Q. Do you have any source of 7 income? 8 A. My partner -- 9 MR. GUIRGUIS: I'm going to 10 object to that. Income is out. 11 You don't have to answer 12 that. 13 Q. Do you have any source of 14 income? 15 MR. GUIRGUIS: I just 16 objected to that. You don't have 17 to answer. 18 MS. MENNINGER: Is there a 19 privilege you're asserting? 20 MR. GUIRGUIS: I'm not sure 21 what the relevance is, and I'm 22 not going to allow -- 23 MS. MENNINGER: Do you 24 believe that relevance is a 25 proper objection during a  Highly Confidential Page 11 1 HIGHLY CONFIDENTIAL AEO 2 deposition? 3 MR. GUIRGUIS: I believe 4 that if you go far afield with 5 this witness, that the judge is 6 not going to appreciate it, and 7 that I'm not going to just sit 8 here and be a potted plant and 9 allow her to answer any questions 10 on any subject that you see fit. 11 MS. MENNINGER: On 12 relevance? You're instructing 13 her not to answer on a relevance 14 objection? Is that what you're 15 saying? 16 MR. GUIRGUIS: I just 17 objected. 18 MS. MCCAWLEY: I'm going to 19 object on behalf of the 20 plaintiff, Virginia Giuffre, to 21 the extent that you're requesting 22 from a nonparty financial 23 information, which is not allowed 24 under New York law. 25 MS. MENNINGER: I have asked  Highly Confidential Page 12 1 HIGHLY CONFIDENTIAL AEO 2 her whether she has any source of 3 income, and you're going to 4 object -- 5 MS. MCCAWLEY: Yes. 6 MS. MENNINGER: -- and 7 instruct her not to answer as 8 well? 9 MS. MCCAWLEY: I'm not 10 instructing her not to answer. 11 I'm just making a record. 12 MR. GUIRGUIS: It's 13 financial information -- 14 MS. MENNINGER: And whether 15 she has a financial motive is 16 relevant. 17 Q. So I'm going to ask you a 18 last time: Do you have any source of 19 income? 20 MR. GUIRGUIS: I'm going to 21 instruct you again not to answer. 22 Q. Has any of your writing been 23 published by anyone? 24 A. No. 25 Q. Have you sought to have your  Highly Confidential Page 13 1 HIGHLY CONFIDENTIAL AEO 2 writing published by anyone? 3 A. No. 4 Q. What is your partner's 5 occupation? 6 MR. GUIRGUIS: Objection. 7 MS. MCCAWLEY: Objection. 8 MR. GUIRGUIS: I'm going to 9 object, yeah. Same objection. 10 MS. MENNINGER: If you are 11 going to instruct the witness not 12 to answer, please say that 13 contemporaneous with your 14 objection, because there are two 15 different things: There are 16 objections and instructions not 17 to answer. 18 So are you instructing her 19 not to answer what her partner's 20 occupation is? 21 MR. GUIRGUIS: Right. Same 22 objection. I'm instructing the 23 witness not to answer on the 24 basis of both relevance and 25 because she is a third-party non-  Highly Confidential Page 14 1 HIGHLY CONFIDENTIAL AEO 2 -- I'm sorry -- nonparty witness 3 who you are asking for financial 4 information about -- 5 MS. MENNINGER: No, I asked 6 for an occupation. 7 MS. MCCAWLEY: I'm going to 8 object. That relates directly to 9 financial information, so it's 10 covered by New York law with 11 respect to nonparty witnesses. 12 Q. What are the names of your 13 parents? 14 A. 16 Q. How do you spell 17 A. 18 Q. And where do your parents 19 live? 20 A. I'm not comfortable giving 21 my mother's and my father's address to 22 you. 23 MS. MENNINGER: Are you 24 instructing her not to answer? 25 MS. MCCAWLEY: Do you want  Highly Confidential Page 15 1 HIGHLY CONFIDENTIAL AEO 2 to confer? 3 MR. GUIRGUIS: Give me a 4 moment on this. 5 THE WITNESS: We're really 6 well organized. 7 (Time noted: 9:21 a.m.) 8 (Recess.) 9 (Time noted: 9:23 a.m.) 10 Q. Ms. Ransome, there was a 11 question pending when you took a break 12 with your lawyers. Can you please 13 answer the question. 14 MR. GUIRGUIS: I'm 15 instructing the witness not to 16 answer questions regarding 17 current information about her own 18 location, her family's location, 19 things of that nature. 20 The witness has expressed to 21 me fears of harassment and the 22 belief that she's being followed, 23 and my understanding is that 24 there are other witnesses that 25 have had similar fears and  Highly Confidential Page 16 1 HIGHLY CONFIDENTIAL AEO 2 concerns. 3 And unless you make some 4 sort of proffer of the actual 5 relevance of her parents' 6 addresses, wherever those are, 7 I'm not going to have her answer. 8 MS. MENNINGER: Okay. Where 9 does that understanding come 10 from, please, Mr. Guirguis? 11 Mr. Guirguis, where does 12 your understanding come from? 13 You just made a factual 14 representation. I would like to 15 know where your understanding 16 comes from. 17 MR. GUIRGUIS: Yeah, I'm not 18 being deposed. I'm not going to 19 answer your questions. 20 MS. MENNINGER: All right. 21 Q. Ms. Ransome, did you agree 22 to be a witness in the case of Giuffre 23 versus Maxwell? 24 A. Yes. 25 Q. Did you voluntarily agree to  Highly Confidential Page 17 1 HIGHLY CONFIDENTIAL AEO 2 do that? 3 A. Yes. 4 Q. Were you promised anything 5 in exchange for your testimony in the 6 Giuffre versus Maxwell case? 7 A. No. 8 Q. Were you provided legal 9 counsel? 10 A. Sorry, does that mean -- 11 MS. MCCAWLEY: You have a 12 lawyer, yes? 13 MR. GUIRGUIS: Yes. 14 A. Yes. 15 Q. Okay. How many lawyers do 16 you have now? 17 A. Three. 18 MS. MENNINGER: I would like 19 the record to reflect that 20 witness is checking with the 21 lawyers to get answers to these 22 questions. 23 MR. POTTINGER: Wait, wait, 24 wait. Objection. 25 MR. GUIRGUIS: There is  Highly Confidential Page 18 1 HIGHLY CONFIDENTIAL AEO 2 absolutely no exchange. No words 3 were spoken by -- 4 MS. MENNINGER: 5 Mr. Pottinger, did you put up a 6 number of fingers? 7 Did you put up a number of 8 fingers, Mr. Pottinger? 9 MR. POTTINGER: You said, 10 I'm going to object because the 11 witness is answering these 12 questions, in the plural. 13 MS. MENNINGER: Mm-hmm. 14 MR. POTTINGER: That is 15 inaccurate. When she looked at 16 me to ask how many lawyers she 17 had, I said three with three 18 fingers. That is a single 19 request on her part and a single 20 answer, not multiple. 21 MS. MENNINGER: No. She has 22 looked to her lawyers for 23 previous answers. 24 We'll just make a record as 25 we go along. Thank you.  Highly Confidential Page 19 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: You could 3 have had a videotape here so that 4 we would have a record of that, 5 because I think your verbal 6 record is inaccurate, so... 7 MR. POTTINGER: And, in 8 fact, she -- this is Mr. 9 Pottinger speaking. 10 And, in fact, she has not 11 looked at me during this 12 deposition except one time, which 13 was for what I took to be a 14 request to know how many lawyers 15 she has. 16 MS. MENNINGER: So are you 17 being deposed, Mr. Pottinger? 18 MR. POTTINGER: I am not. 19 Q. Ms. Ransome, how many 20 lawyers do you think you have? 21 A. Three. 22 Q. Can you please name them? 23 A. Peter, Sigrid and Stan. 24 Q. Is Mr. Bradley Edwards 25 representing you?  Highly Confidential Page 20 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. Is Mr. Paul Cassell 4 representing you? 5 A. No. 6 Q. Is Mr. David Boies 7 representing you? 8 A. Yes. 9 MS. MCCAWLEY: I just want 10 to be clear for the record if 11 you're talking about representing 12 generally or you're talking about 13 a particular matter. Because we 14 have a couple matters. 15 MS. MENNINGER: I'm asking 16 questions here. 17 MS. MCCAWLEY: No, I 18 understand that you have to make 19 the record clear -- 20 MS. MENNINGER: Ms. 21 McCawley, if you want to ask her 22 questions later, you are more 23 than welcome to do so. I am 24 going to ask questions of the 25 witness I am deposing.  Highly Confidential Page 21 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: Well, we want 3 the record to be clear that there 4 are more than one action -- 5 MS. MENNINGER: You can ask 6 questions when you're doing your 7 questioning. I'm doing my 8 questioning now, and so I will 9 ask the questions. 10 MS. MCCAWLEY: I'm going to 11 object. The record should be 12 clear there is more than one 13 action pending here. She is 14 represented here as a nonparty 15 witness, and she also has her own 16 action pending. 17 MR. PAGLIUCA: Thank you for 18 that speaking objection, Ms. 19 McCawley, and communicating that 20 information to the witness, which 21 you know is totally improper. 22 MS. MCCAWLEY: Now, that's 23 two people objecting right now. 24 Is it going to be Laura taking 25 this deposition or you, Jeff?  Highly Confidential Page 22 1 HIGHLY CONFIDENTIAL AEO 2 You guys have done this to me 3 before, and it's not a position 4 where you're allowed to object 5 and she's allowed to object. You 6 guys pulled that at the last 7 deposition, so please do not do 8 this here. 9 MR. PAGLIUCA: I was just 10 thanking you. 11 Q. All right. So the number of 12 lawyers we're up to so far is 13 Mr. Guirguis, Ms. McCawley, 14 Mr. Pottinger, Mr. Edwards, Mr. Boies. 15 That's five, correct? 16 A. Can I just ask you a 17 question? 18 Q. No, you cannot. 19 A. Okay. 20 Q. Are those five lawyers that 21 are representing you? 22 MR. GUIRGUIS: Objection. 23 Q. Yes or no? 24 A. Yes. 25 Q. All right. Anyone else  Highly Confidential Page 23 1 HIGHLY CONFIDENTIAL AEO 2 representing you? 3 A. No. 4 Q. Ms. Schultz? Is 5 Ms. Meredith Schultz representing you? 6 A. No. 7 Q. How much are you paying for 8 any of those lawyers? 9 A. It's on a pro-bono basis. 10 Q. Do you know what each of 11 those lawyers' normal hourly rates 12 are? 13 A. No. 14 Q. Do you know how many hours 15 you have spent with your attorneys? 16 A. No. 17 MR. GUIRGUIS: Objection. 18 Q. How many hours have you 19 spent with Mr. Guirguis? 20 MR. GUIRGUIS: Objection. 21 Q. Without communicating to me 22 any information you and he have 23 shared. 24 A. A few, maybe. 25 Q. How many?  Highly Confidential Page 24 1 HIGHLY CONFIDENTIAL AEO 2 A. About 11 hours in total. 3 Q. When is the first time that 4 you met Mr. Guirguis? 5 MR. GUIRGUIS: Objection. 6 MS. MCCAWLEY: You can 7 answer. 8 MR. GUIRGUIS: You can 9 answer. 10 A. Yesterday. 11 Q. You met Mr. Guirguis 12 yesterday? Was that your answer? 13 A. Yes. 14 Q. And who is paying for 15 Mr. Guirguis's fees, if you know? 16 A. I have a pro-bono 17 arrangement. 18 Q. Do you know if he's 19 receiving money from anyone else in 20 exchange for representing you? 21 A. No. 22 Q. No, you don't know, or no, 23 he is not? 24 A. I don't know. 25 Q. How many hours have you  Highly Confidential Page 25 1 HIGHLY CONFIDENTIAL AEO 2 spent with Ms. McCawley? 3 A. Can I just clarify that 4 question? Does that mean on the 5 phone? Like what are you referring 6 to, in person or -- 7 Q. Either one. How many hours, 8 how much time have you spent with 9 Ms. McCawley in person? 10 A. I met with Ms. McCawley for 11 the first time in person yesterday, 12 but I've spent -- yeah, we've been -- 13 Ms. McCawley was the first person I 14 actually spoke to. 15 Q. And how many hours have you 16 spent with her on the phone? 17 A. Many, many hours. 18 Q. Approximately how many? 19 A. I don't know. 20 Q. Five? 21 MR. GUIRGUIS: Objection. 22 A. More than five. 23 Q. Ten? 24 MR. GUIRGUIS: Objection. 25 Q. Ten?  Highly Confidential Page 26 1 HIGHLY CONFIDENTIAL AEO 2 A. Well, 10, 15. She's been 3 with me the whole way since when I 4 came forward, so she's been a very 5 prominent person. 6 Q. And when did you first speak 7 with her on the phone? 8 A. I think it was -- 9 Q. Without telling me what you 10 said. 11 A. I think it was November. 12 Q. November what? 13 A. I can't remember the date. 14 Q. Early November? Late 15 November? 16 MR. GUIRGUIS: Objection. 17 A. I can't remember. 18 Q. Was she speaking to you on 19 your cell phone or a landline? 20 A. Cell phone. 21 Q. A mobile number or a 22 landline? 23 A. A cell phone. 24 Q. Okay. And what's that cell 25 phone number?  Highly Confidential Page 27 1 HIGHLY CONFIDENTIAL AEO 2 A. I don't have it anymore. 3 Q. That's okay. What's the 4 cell phone number? 5 A. I actually don't know. I 6 can't remember my cell phone number. 7 I don't have anything with me, so I 8 can't remember that number offhand. 9 Q. How long did you have that 10 cell phone? 11 A. About eight months. 12 Q. What happened to it? 13 A. I got rid of it. 14 Q. Why? 15 A. Because I fear for my life 16 because of Jeffrey Epstein and 17 Ghislaine Maxwell. 18 Q. What did you do with it? 19 A. I sold it. 20 Q. When? 21 A. November. 22 Q. Before or after you first 23 spoke with Ms. McCawley? 24 A. Before. 25 Q. So then how did you speak  Highly Confidential Page 28 1 HIGHLY CONFIDENTIAL AEO 2 with Ms. McCawley over the phone? 3 A. On my partner's cell phone. 4 Q. What's his cell phone 5 number? 6 MS. MCCAWLEY: Objection. 7 What's the relevance of her 8 partner's cell phone? 9 Again, this is irrelevant. 10 It's harassing. It's -- you're 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q. What is your partner's cell 19 phone number? 20 MR. GUIRGUIS: I'm directing 21 the witness not to answer. 22 Q. How many hours have you 23 spent speaking with Mr. Pottinger? 24 A. I've been speaking to 25 Mr. Pottinger from November.  Highly Confidential Page 29 1 HIGHLY CONFIDENTIAL AEO 2 Q. When in November? 3 A. I can't remember. 4 Q. On your same cell phone that 5 you got rid of? 6 A. No, on my partner's cell 7 phone. 8 Q. And when did you first meet 9 Mr. Pottinger in person? 10 A. It was in the beginning of 11 January. 12 Q. And where was that meeting? 13 A. Barcelona. 14 Q. Where in Barcelona? 15 A. Barcelona. It's Barcelona. 16 We meet -- I can't remember the area. 17 Q. In a restaurant? In a 18 hotel? In an office? 19 A. In a hotel. 20 Q. And how long did you spend 21 with Mr. Pottinger on that occasion? 22 A. Two days. 23 Q. How many hours over the two 24 days? 25 A. Gosh, about 16.  Highly Confidential Page 30 1 HIGHLY CONFIDENTIAL AEO 2 Q. How many hours did you spend 3 with Mr. Edwards? 4 MS. MCCAWLEY: Objection. 5 A. The same amount. 6 Q. He was with Mr. Pottinger? 7 A. Yeah, yes. 8 Q. And Mr. Boies, how much time 9 have you spent with Mr. Boies? 10 A. I haven't spent any time 11 with him yet. 12 Q. Have you met him? 13 A. No. 14 Q. Have you spoken to him on 15 the phone? 16 A. No. 17 Q. And you have not paid any 18 money for any of those lawyers' time, 19 correct? 20 A. Yes. 21 Q. In addition to your free 22 legal counsel, were you given anything 23 else in exchange for your agreement to 24 be a witness in this case? 25 MR. GUIRGUIS: Objection.  Highly Confidential Page 31 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Did you fly over here? 4 A. Yes. 5 Q. From Barcelona? 6 A. Yes. 7 Q. Did you pay for the plane 8 ticket? 9 A. Yes. 10 Q. How much was the plane 11 ticket? 12 A. It was -- I think it was 13 1,000 -- it was 1,000 -- I can't 14 remember the exact total. 15 Q. Has anyone agreed to 16 reimburse you for that? 17 A. No. 18 Q. And you're staying where 19 while you're here? 20 MR. GUIRGUIS: Objection. 21 And direct you not to answer 22 that. 23 Q. Are you staying in a hotel 24 while you're here? 25 MR. GUIRGUIS: You can  Highly Confidential Page 32 1 HIGHLY CONFIDENTIAL AEO 2 answer that. 3 A. Yeah. 4 Q. Are you paying for that? 5 MR. GUIRGUIS: Objection. 6 I'm directing you not to 7 answer. 8 MS. MCCAWLEY: You can 9 answer. 10 MR. GUIRGUIS: I think you 11 can answer. 12 MS. MCCAWLEY: Yeah, I think 13 you can answer. 14 MR. GUIRGUIS: That's fine. 15 I agree. 16 MS. MCCAWLEY: You're a 17 nonparty witness. You can answer 18 that question. 19 MS. MENNINGER: Who is -- 20 MS. MCCAWLEY: I am 21 representing Virginia. He is 22 representing the witness. 23 MS. MENNINGER: Well, you're 24 representing the witness as well, 25 right?  Highly Confidential Page 33 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: I'm not. 3 MS. MENNINGER: Well, did 4 you just tell her she can answer 5 a question? 6 MS. MCCAWLEY: I did. 7 Q. Are you paying for the 8 hotel? 9 A. No. 10 Q. Who's paying for the hotel? 11 A. It's on expenses, I think, 12 of a witness. It's expenses from -- 13 yeah, I don't know, actually. 14 Q. You don't know who is paying 15 for your hotel? 16 A. No. 17 Q. It's not you? 18 A. No. 19 Q. And how much per night is 20 your hotel? 21 A. I have no idea. 22 Q. How long are you staying 23 here on this trip? 24 A. Just for the deposition. 25 Q. Okay. When did you arrive?  Highly Confidential Page 34 1 HIGHLY CONFIDENTIAL AEO 2 A. It was Tuesday, late Tuesday 3 night. 4 Q. And when are you leaving? 5 A. Tomorrow evening. 6 Q. In addition to your legal 7 counsel and your hotel, is there 8 anything else you've been given in 9 exchange for your -- 10 A. No. 11 Q. -- to be a witness in this 12 case? 13 You have to wait for me to 14 finish my question before you answer. 15 A. Sorry. 16 Q. Have you been given anything 17 else? 18 A. No. 19 Q. Have you been promised 20 anything else? 21 A. No. 22 Q. Have you been promised that 23 you would have counsel to help you 24 bring a lawsuit against a number of 25 people?  Highly Confidential Page 35 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: Objection. 3 To the extent this gets into 4 attorney/client privileged 5 information, you're not allowed 6 to answer. 7 Q. Have your lawyers agreed to 8 bring a lawsuit on your behalf against 9 a number of people? 10 A. Yes. 11 Q. And are you paying for that 12 counsel? 13 A. No. 14 Q. Have you reached any 15 agreement about a contingency fee for 16 that case? 17 A. Can you explain what 18 contingency means? Sorry. 19 Q. Do you expect to receive 20 money as a result of that lawsuit? 21 A. Oh, no. No. 22 Q. You're not asking to receive 23 any money as a result of that lawsuit? 24 A. No. No. 25 Q. All right. So have you had  Highly Confidential Page 36 1 HIGHLY CONFIDENTIAL AEO 2 any agreements regarding writing a 3 book -- 4 A. No. 5 Q. -- about your experience? 6 You have to wait for me to 7 finish my question. 8 Have you had any agreements 9 with your lawyers about media rights 10 in any form? 11 MR. GUIRGUIS: Objection to 12 the extent that you're asking 13 about communications with the 14 attorneys. 15 MS. MENNINGER: I'm asking 16 about her arrangement with her 17 attorneys, which is not 18 privileged. 19 A. Can you please repeat the 20 question. 21 Q. Have you reached any 22 agreement with your attorneys 23 regarding media rights for your story? 24 A. No. 25 Q. Have you talked to anyone  Highly Confidential Page 37 1 HIGHLY CONFIDENTIAL AEO 2 about publishing anything relating to 3 your story? 4 A. Can you repeat the question, 5 please. 6 MS. MENNINGER: Can you read 7 it back. 8 (Requested portion of the 9 record was read back.) 10 A. Yes, I have. 11 Q. Who have spoken to? 12 A. The New York Post. 13 Q. Who at the New York Post? 14 A. Maureen Callahan. 15 Q. And when did you speak with 16 her? 17 A. I think it was later 18 October. 19 Q. Have you spoken with her 20 since? 21 A. No. 22 Q. And how long did you speak 23 to her? 24 A. I spoke to her for, gosh, 25 about 30 minutes on the phone once.  Highly Confidential Page 38 1 HIGHLY CONFIDENTIAL AEO 2 Q. And what was -- what did you 3 tell her in your phone call? 4 A. I told her what Jeffrey 5 Epstein and Ghislaine Maxwell did to 6 me and the other girls. 7 Q. Did she give you any money 8 in exchange for that interview? 9 A. No. 10 Q. Did she publish anything 11 related to that interview? 12 A. No. 13 Q. How did you get in touch 14 with Ms. Callahan? 15 A. I emailed after I read an 16 article that she had written about 17 Jeffrey Epstein, and the last sentence 18 was -- it was on the 16th of October, 19 and one of the last sentences I 20 remember was, will we ever know the 21 true extent of Jeffrey Epstein's 22 victims. And I wrote her after that 23 because, well, it still continues, 24 doesn't it. 25 Q. Where is the email that you  Highly Confidential Page 39 1 HIGHLY CONFIDENTIAL AEO 2 wrote her? 3 A. It's on a -- it's on my 4 computer. 5 Q. Okay. In your Yahoo 6 account? 7 A. Yes. 8 Q. Did you have any agreement 9 with her to have any additional 10 conversation? 11 A. Yes. 12 Q. And what was that agreement? 13 A. It wasn't an agreement per 14 such. What actually happened was I 15 came forward. As soon as I came 16 forward, there was -- where I live in 17 Barcelona, there's quite a lot -- it's 18 quite busy traffic with people. 19 I came forward to Maureen 20 Callahan. I wanted to tell my story, 21 and I want to run a campaign in which 22 all the girls that have been abused by 23 Ghislaine and Jeffrey can come 24 forward. And I wanted to run a 25 campaign with the New York Post to get  Highly Confidential Page 40 1 HIGHLY CONFIDENTIAL AEO 2 these girls to have the courage to 3 come forward, because I know a lot of 4 them are frightened like myself. 5 The email correspondence I 6 had with Maureen Callahan, she was 7 going away or something and she was 8 going to write a piece in the New York 9 Post about my story. During that time 10 it was the elections, so there was a 11 lot more other things going on. 12 There were two people 13 following me after I came forward to 14 Maureen Callahan. I went to -- I 15 walked downstairs. I walked around -- 16 I have a usual routine that I do. In 17 the morning I went out, I saw the same 18 two people. Later on that afternoon, 19 I saw the same two people again. I 20 was frightened. I'm frightened for my 21 life, absolutely frightened. So there 22 you go. 23 So that's what I was -- 24 communication stopped between Maureen 25 Callahan and I. I got really angry  Highly Confidential Page 41 1 HIGHLY CONFIDENTIAL AEO 2 with Maureen because she had obviously 3 told someone. Being the New York 4 Post, so, you know. 5 Q. So you had an email to 6 Ms. Callahan and an email back from 7 her? 8 A. Yes. 9 Q. More than one? 10 A. Yes. 11 Q. How many? 12 A. I can't remember. 13 Q. More than ten or less than 14 ten? 15 A. Less than ten. 16 Q. And you had one phone call 17 with her or more than one? 18 A. Just one. 19 Q. And it lasted about 30 20 minutes? 21 A. About that. 22 Q. And was that also on the 23 cell phone that you got rid of? 24 A. That was on my partner's 25 cell phone.  Highly Confidential Page 42 1 HIGHLY CONFIDENTIAL AEO 2 Q. And what had you read in the 3 press that caused you to get in touch 4 with Ms. Callahan? 5 MS. MCCAWLEY: Objection to 6 form. Go ahead. 7 A. You can read the article 8 yourself. It's on the 16th of 9 October, there's an article in the New 10 York Post written by Maureen Callahan. 11 You can read it. And that's what 12 inspired me to come forward. 13 Q. What do you recall about 14 that article? 15 A. Oh, I can't remember. The 16 one thing I do remember is the last 17 sentence of the article, which has 18 stuck with me and quite prominent, and 19 that is, will we ever know the true 20 extent of Jeffrey Epstein's victims. 21 Q. Do you recall anything else 22 about the article? 23 A. It's just the same. When I 24 read the article, the stuff that I had 25 experienced myself with Jeffrey, it's  Highly Confidential Page 43 1 HIGHLY CONFIDENTIAL AEO 2 just same old stuff, just continuing. 3 I thought he had stopped abusing 4 girls. 5 Q. What do you recall reading a 6 article that Jeffrey Epstein was 7 doing? 8 A. I can't remember. 9 Q. Anything at all? 10 A. You can read the article. I 11 can't remember. 12 Q. The question is what you 13 remember. 14 A. I can't remember. 15 Q. You remember nothing else 16 about the article -- 17 MS. MCCAWLEY: Asked and 18 answered objection. 19 Q. -- except it was related to 20 Jeffrey Epstein and it ended with the 21 sentence that you've described? 22 MS. MCCAWLEY: Objection, 23 asked and answered. 24 A. Yes. 25 Q. What do you know about other  Highly Confidential Page 44 1 HIGHLY CONFIDENTIAL AEO 2 girls being frightened? 3 A. I know that the girls on the 4 island and in New York during my time 5 with Jeffrey and Ghislaine, that they 6 were frightened. 7 Q. Okay. What are the names of 8 those girls? 9 A. . 10 -- I don't know her surname. I can't 11 remember her surname. 12 Q. How do you spell the first 13 name? 14 A. I'm just taking a 15 guess, , I'm guessing, I 16 think. 17 MR. GUIRGUIS: I'm going to 18 remind the witness I told her not 19 to speculate, but that's okay. 20 Q. In addition to 21 and what are the 22 names of the other girls who you 23 believe are frightened? 24 A. There were a 25 couple other girls I met during my  Highly Confidential Page 45 1 HIGHLY CONFIDENTIAL AEO 2 time with Ghislaine and Jeffrey that 3 were frightened. 4 Q. What were the names of the 5 girls that you met that were 6 frightened? 7 A. There was 8 . And there were two 9 other girls, I can't remember their 10 names. 11 Q. Okay. Please describe them. 12 A. The -- describe all the 13 girls or -- 14 Q. No. We're talking about the 15 girls that you met on the island that 16 you described as frightened. 17 A. Okay. On the island -- 18 MR. GUIRGUIS: Objection. 19 You seem to be suggesting that 20 all those girls are from the 21 island. I'm not sure that's the 22 testimony. 23 Q. All right. You said girls 24 on the island and in New York who are 25 frightened. I asked you for their  Highly Confidential Page 46 1 HIGHLY CONFIDENTIAL AEO 2 names. 3 You gave me three, correct? 4 A. Yes. 5 Q. You said there were two 6 others, correct? 7 A. Mm-hmm. 8 Q. What did those two other 9 girls look like? 10 A. I can't really remember. 11 One had blonde hair; long, blonde 12 hair. 13 Q. Anything else about that? 14 A. I can't remember. 15 Q. The other girl, can you 16 remember her hair color? 17 A. No, I can't remember. 18 Q. Do you know the height of 19 either one of them? 20 A. No, I can't remember. 21 Q. Do you have a photograph of 22 either one of them? 23 A. No. 24 Q. And where did you meet these 25 two other girls?  Highly Confidential Page 47 1 HIGHLY CONFIDENTIAL AEO 2 A. In New York. 3 Q. Where in New York? 4 A. I can't remember. 5 Q. You don't know the location 6 at all? 7 A. No. It was ten years ago. 8 Q. Was it in a home or in a 9 commercial setting? 10 A. I met girls commercially and 11 in home settings. 12 Q. Where did you meet these two 13 other girls you described as being 14 frightened? 15 A. I can't remember. 16 Q. What is 's last 17 name? 18 A. I don't know. 19 Q. What does look 20 like? 21 A. She's got long, blonde hair. 22 Q. How long? 23 A. Long, long hair. 24 Q. Longer than your hair now? 25 A. I think so. I think it was  Highly Confidential Page 48 1 HIGHLY CONFIDENTIAL AEO 2 longer. 3 Q. So middle of her back? 4 A. I can't -- I can't remember 5 on how long her hair is. 6 Q. Where did you meet 7 A. I met first in New 8 York. 9 Q. Where in New York? 10 A. I can't remember. 11 Q. Anywhere in New York? You 12 can't remember at all? 13 A. I can't remember the 14 location. 15 Q. Was it at Mr. Epstein's 16 home? 17 MR. GUIRGUIS: Objection. 18 You have asked her now almost 20 19 questions about where she met 20 these girls, and she has 21 consistently said that she does 22 not remember. 23 Q. Was it in Mr. Epstein's 24 home? 25 A. No.  Highly Confidential Page 49 1 HIGHLY CONFIDENTIAL AEO 2 Q. Was it at a club? 3 MR. GUIRGUIS: Are we going 4 to spend seven hours with her 5 saying I can't remember where she 6 met these two girls? 7 Q. Was it at a club? 8 A. One was at a club. 9 Q. Which one? 10 A. . 11 Q. Where did you meet 12 A. I first met on the 13 island. 14 Q. Did you meet her a second 15 time? 16 A. Yes. 17 Q. Where did you meet her the 18 second time? 19 A. I can't remember. 20 Q. State? 21 A. Can't remember. 22 Q. Country? 23 A. Well, U.S. 24 THE WITNESS: Sorry, can I 25 have a break? I actually need to  Highly Confidential Page 50 1 HIGHLY CONFIDENTIAL AEO 2 go to the bathroom. Sorry. 3 MS. MENNINGER: Yes, I don't 4 think I have a question pending. 5 We'll go off the record now. 6 (Time noted: 9:52 a.m.) 7 (Recess.) 8 (Time noted: 10:07 a.m.) 9 Q. So I want to return to your 10 conversations with Ms. Callahan, 11 conversation with Ms. Callahan. 12 Did you have any further 13 communications with her after the 14 phone call you described? 15 A. There were, I think, a few 16 emails exchanged, but nothing ever 17 came about it. 18 Q. And, again, those are emails 19 from your Yahoo account? 20 A. Yes. 21 Q. Did you ask Ms. Callahan for 22 compensation in exchange for your 23 story? 24 MS. MCCAWLEY: Objection, 25 asked and answered.  Highly Confidential Page 51 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Had you seen any other 4 stories in the press about Jeffrey 5 Epstein? 6 A. Through the last ten years, 7 I've seen a few articles written about 8 Jeffrey Epstein. 9 Q. What do you recall about 10 those articles? 11 A. The way he used to abuse 12 girls. Basically articles written 13 very similar to my own story -- well, 14 identical, so... 15 Q. And have you written down 16 your story? 17 A. No. 18 Q. Nowhere? 19 A. No. 20 Q. Did you see any articles 21 about Virginia Roberts? 22 A. Yes. 23 Q. Which articles did you see 24 about Virginia Roberts? 25 A. I can't remember. It was  Highly Confidential Page 52 1 HIGHLY CONFIDENTIAL AEO 2 quite some time ago. 3 Q. What do you recall about it? 4 A. She came forward and I 5 was -- it was a few years ago that she 6 came forward, and her story was 7 exactly the same as mine. 8 I can't remember 9 specifically what article I read, but 10 every single article I did read during 11 the duration of that time, she 12 experienced the same thing I did. 13 So it was more or less the 14 same context and it's the same story 15 in all articles, really. 16 Q. So you were reading these 17 articles over the course of a period 18 of ten years, you think? 19 A. Yeah. I didn't pay much 20 attention to it because I've spent the 21 last ten years trying to get over that 22 experience, and I've been frightened 23 to come forward. 24 Q. And when you read the 25 articles, you noticed that there were  Highly Confidential Page 53 1