gov.uscourts.nysd.447706.1200.14_1.pdf

EXHIBIT 2 (Filed Under Seal)  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  Page 57 1 G Maxwell - Confidential 2 asked and answered already. 3 Q. You can answer the question. 4 A. I have no idea what 5 did. 6 Q. You never observed 7 with girls under the age of 18 at Jeffrey's 8 home? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 A. The answer is no, I have no idea. 12 Q. Do you know 13 A. I do. 14 Q. What is your relationship with 15 16 MR. PAGLIUCA: Object to the form. 17 A. What do you mean what is my 18 relationship. 19 Q. Are you friendly with him, how do 20 you know him? 21 A. He is the husband of . 22 Q. Is one of your friends? 23 A. Yes. 24 Q. Did you ever send Virginia to 25 to give him a  Page 270 1 G Maxwell - Confidential 2 A. She helps with my not-for-profit 3 ocean foundation and any other related 4 activities that I may have. 5 Q. Is she paid for by Jeffrey Epstein? 6 A. No. 7 Q. She is paid for by you? 8 A. Yes. 9 Q. When did you first meet 10 ? 11 A. I don't recollect exactly, sometime 12 maybe 2002, 2003. 13 Q. How did you meet her? 14 A. I don't recollect exactly how we 15 met. 16 Q. Did Jeffrey introduce you to her? 17 A. I don't recollect how we met. 18 Q. Does she know Jeffrey Epstein? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. Can you ask again, please? 22 Q. Does know Jeffrey 23 Epstein? 24 A. What do you mean by know? 25 Q. Has she met her him before?  Page 271 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I can't recollect a time when 5 -- I've seen with Jeffrey but -- 6 Q. You are not sure -- 7 A. I know they know either other. I 8 can't testify to a meeting between them. 9 Q. Do you know where in New Jersey she 10 lives? 11 A. No 12 Q. You don't know a city? 13 A. No. 14 Q. How long has she worked for you? 15 A. Sometime 2002, 2003. 16 Q. To the present? 17 A. Yeah. 18 Q. Why do you think that 19 might know Jeffrey? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Because you know, I know Jeffrey. 23 Q. Have you seen them together? 24 A. I already testified I have not seen 25 them together, to my recollection.  Page 272 1 G Maxwell - Confidential 2 Q. Is it your testimony that 3 knows Jeffrey Epstein through the work 4 that she does for you? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I don't recollect, and I don't 8 recollect how I met and I can't testify 9 to what relationship is or is not with 10 Jeffrey. 11 Q. Have you ever talked to Jeffrey 12 about Dana? 13 A. I don't know what you mean. 14 Q. In any way, have you ever had a 15 conversation with Jeffrey about ? 16 A. In what context. 17 Q. In any context. Have you ever 18 talked to Jeffrey Epstein about ? 19 A. works for me so it's entirely 20 possible that in the course of conversations 21 since 2002, 2003 that a conversation in which 22 name would have come up is entirely 23 possible. 24 Q. I provided you with and I'm sorry, 25 I don't know all the numbers, but the  Page 273 1 G Maxwell - Confidential 2 statement that was issued by that 3 should be a single page still in your stack 4 of exhibits there. 5 MR. PAGLIUCA: Exhibit 10. 6 Q. Did you authorize to issue 7 that statement on your behalf in January of 8 2015? 9 A. I already testified that that was 10 done by my lawyers. 11 Q. So did you authorize your lawyers 12 to issue a statement on your behalf through 13 in January of 2015? 14 A. It was determined that I had to 15 make a statement in the United Kingdom 16 because of the appalling lies and I just 17 thought of some new ones. 18 Virginia's statement that I 19 celebrated her 16 birthday with her. We can 20 all agree that that's entirely impossible. I 21 didn't meet her until she was 17 and other 22 lies she perpetrated that she had a diary and 23 we all know is a complete fake. That's not a 24 diary. It was just a book she was writing 25 that you helped sell to the press, as if it  Page 361 1 G Maxwell - Confidential 2 (Maxwell Exhibit 17, email, marked 3 for identification.) 4 Q. This is an email from you on 5 January 10, 2015 to 6 . The statement you had before you 7 earlier, that, if you can pull that in front 8 of you, the one page press release that you 9 gave. You might know from memory. 10 Was the press release that you 11 issued with the statement about Virginia 12 issued in or around January 2, 2015? 13 A. As best as I can recollect. 14 Q. I want to turn your attention to 15 the document I just handed you which is Bates 16 No. 001044, from you to 17 . It says in the first sentence, I'm 18 out of my depth to understand defamation, 19 other legal hazards and I don't want to end 20 up in a lawsuit aimed at me from anyone, if I 21 can help it. Apparently, even saying 22 Virginia is a liar has hazards. 23 You knew at the time you called 24 Virginia a liar in early January of 2015 that 25 that was something that would result in a  Page 405 1 G Maxwell - Confidential 2 with Virginia Roberts. 3 Q. I'm marking this as Maxwell 25. 4 (Maxwell Exhibit 25, email, marked 5 for identification.) 6 Q. I'm showing you what has been 7 marked as Maxwell 25. 8 This is an email dated January 11, 9 2015 at the top? 10 Do you see that that from Jeffrey 11 to you? 12 A. Uh-huh. 13 Q. And then below there is an email 14 from to you and cc'ing 15 on January 11, 2015. 16 Do you see that? 17 A. Uh-huh. 18 Q. It says, Dear Ghislaine, as you 19 know I have been working behind the scenes 20 and this article comes from that. It helps 21 but doesn't answer the VR claims. I will get 22 the criminal allegations out. This shows the 23 MOS will print truth, not just a VR voice 24 piece. We can only make the truth by making 25 a statement.  Page 406 1 G Maxwell - Confidential 2 What did he mean when he said, I 3 will get the criminal allegations out, what 4 was he referring to? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I have no idea. 8 Q. Were there criminal allegations 9 about Virginia that either your lawyer or 10 were leaking to the press? 11 MR. PAGLIUCA: Objection to form 12 and foundation. 13 A. I have no idea. 14 Q. Did you ask him what he meant when 15 he said, I will get the criminal allegations 16 out? 17 A. I don't recollect the conversation. 18 Q. Did you direct him to leak to the 19 press criminal allegations about Virginia 20 Roberts? 21 A. I already testified that I have no 22 knowledge of what you are asking me. 23 Q. Were you copied on this email, 24 correct? 25 A. I was.  Page 416 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that the witness, 6 GHISLAINE MAXWELL, was duly sworn by me and 7 that the deposition is a true record of the 8 testimony given by the witness. 9 10 _______________________________ 11 Leslie Fagin, Registered Professional Reporter 12 Dated: April 22, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporter.) 20 21 22 23 24 25