1320-3.pdf

Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 1 of 6 EXHIBIT4 Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 2 of 6 Pagel UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - X VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against - 15-cv- 0 7433 - 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 0 0 Avenue of the Americas New York, New York 10026 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 3 of 6 Page 2 1 2 APPEARANCES: 3 BOIES SCHILLER & FLEXNER , LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdatle, Florida , 33301 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 1320-3 Filed 01/03/24 Page 4 of 6 Page 60 1 G Maxwell - Confidential 2 A. She was tasked to answer 3 telephones. 4 Q. Did y ou ever ask her to rub 5 Jeffrey 1 s feet? 6 MR . PAGLIUCA: Objection to the 7 form and foundation. 8 A. I believe that I have read that , 9 but I don 1 t have any memory of it. 10 Q. Did you ever tell Johanna that she 11 would get extra money if she provided Jeffrey 12 massages? 13 A. I was always happy to give career 14 advice to people and I think that becoming 15 somebody in the healthcare profession, either 16 exercise instructor or nutritionist or 17 professional massage therapist is an 18 excellent job opportunity. Hourly wages are 19 around 7 , 8, $9 and as a professional 20 healthcare provider you can earn somewhere 21 between as we have established 10 0 to $2 00 22 and to be able to travel and have a job that 23 pays that is a wonderful job opportunity. So 24 in the context of advising people for 25 opportunities for work, it is possible that I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 5 of 6 Page 61 1 G Maxwell - Confidential 2 would have said that she should explore that 3 as an option. 4 Q. Did you tell her she would get 5 extra money if she massaged Jeffrey? 6 A. I ' m just saying, I cannot recall 7 the exact conversation. I give career advice 8 and I have done that. Q. Did you ever have Johanna massage 10 you? 11 A. I did Q. How many times? A. I don't recall how many times. 14 Q. Was there sex involved? 15 A. 16 Q. Did you ever instruct Johanna to 17 massage Glenn Dubin? 18 A. I don ' t believe -- I have no 19 recollection of it. 20 Q. Did you ever have sexual contact 21 with Johanna? 22 MR. PAGLIUCA: Object to the form 23 and foundation. You need to give me an 24 opportunity to get in between the 25 questions. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 6 of 6 Page 62 1 G Maxwell - Confidential 2 Anything that involves consensual 3 sex on your part , I 'm instructing you 4 not to answer. 5 Q. Did you ever have sexual contact 6 with Johanna? 7 A. Again, she is an adult -- 8 Q. I'm asking you, did you ever have 9 sexual contact with Johanna? 10 A. I ' ve just been instructed not to 11 answer. 12 Q. On what basis? 13 A. You have to ask my lawyer . 14 Q. Did you ever have sexual contact 15 with Johanna that was not consensual on 16 Johanna ' s part? 17 MR. PAGLIUCA: You can answer 18 nonconsensual. 19 A. I've never had nonconsensual sex 20 with anybody. 21 Q. Not Annie Farmer? 22 MR. PAGLIUCA: Objection. 23 A. I just testified I never had 24 nonconsensual sex with anybody ever, at any 25 time, at anyplace, at any time, with anybody. MAGNA& LEGAL SERVICES