gov.uscourts.nysd.447706.1331.9.pdf

Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 1 of 12 EXHIBIT C· Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 2 of 12 Page 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS VIRGINIA L. GIUFFRE, Plaintiff, -against- GHISLAINE MAXWELL, Defendant. - - - - - - - - - - - - - - -I 250 N. Australian Avenue, Suite 1400 West Palm Beach, Florida 33401 Friday, September 9, 2016 8:35 a.m. - 2:08 p.m. C O N F I D E N T I A L VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Taken before Darline M. West, Registered Professional Reporter, Notary Public in and for the State of Florida At Large, pursuant to Notice of Taking Deposition filed by the Plaintiff in the above cause. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 3 of 12 Page 2 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 THE UNIVERSITY OF UTAH, S.J. QUINNEY COLLEGE OF LAW 4 383 South University Street Salt Lake City, Utah 84112 5 Phone: 801.585.5202 E-mail: [email protected] 6 By: PAUL G. CASSELL, ESQ. 7 -and- 8 BOIES SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard 9 Fort Lauderdale, Florida 33301 Phone: 954. 356. 0011 10 E-mail: [email protected] By: SIGRID S. MCCAWLEY, ESQ. 11 12 13 On behalf of the Defendant: 14 HADDON MORGAN FOREMAN 150 East 10th Avenue 15 Denver, Colorado 80203 Phone: 303.831.7364 16 E-mail: [email protected] By: JEFFREY PAGLIUCA, ESQ. 17 18 On behalf of the Witness, Jeffrey Epstein: 19 ATTERBURY GOLDBERGER & WEISS, P.A. One Clearlake Centre, Suite 1400 20 250 Australian Avenue South West Palm Beach, Florida 33401 21 Phone: 561.659.8300 E-mail: [email protected] 22 By: JACK A. GOLDBERGER, ESQ. 23 -and- 24 25 (Appearances continued on the next page) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 4 of 12 Page 3 1 APPEARANCES: 2 MARTING. WEINBERG, P.C. 20 Park Plaza, No. 1000 3 Boston, Massachusetts 02116 Phone: 617.227.3700 4 E-mail: [email protected] By: MARTING. WEINBERG, P.C. 5 (Appearing telephonically) 6 7 ALSO PRESENT: 8 RYAN KICK - Video Technician 9 DARLINE MARIE WEST - Court Stenographer 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 5 of 12 Page 4 1 I N D E X 2 WITNESS: PAGE: 3 JEFFREY EDWARD EPSTEIN 4 DIRECT EXAMINATION 8 BY MR. CASSELL: 5 CROSS-EXAMINATION 275 6 BY MR. PAGLIUCA: 7 REDIRECT EXAMINATION 324 BY MR. CASSELL: 8 CERTIFICATE OF OATH 375 9 REPORTER'S CERTIFICATE 376 10 11 12 E X H I B I T S 13 14 15 Description Page 16 Plaintiff's Exhibit JEl Transcript of the 54 deposition of 17 Ms. Maxwell taken on April 22nd, 2016 18 Plaintiff's Exhibit JE2 Document with titles 90 19 of books 20 Plaintiff's Exhibit JE3 Photograph depicting 101 Prince Andrew, 21 Maxwell, and Virginia 22 Plaintiff's Exhibit JE4 E-mail that Jeffrey 173 Epstein sent to 23 Maxwell on January 12th, 2015 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 6 of 12 Page 5 1 Plaintiff's Composite E-mail Jeffrey 180 Exhibit JES Epstein received from 2 Ms. Maxwell on about July 18th, 2009 3 Plaintiff's Exhibit JE6 E-mail string between 185 4 Jeffrey Epstein and Ms. Maxwell on about 5 March 25th, 2011 6 Plaintiff's Exhibit JE7 Transcription of a 189 string of e-mails 7 between Jeffrey Epstein and Ms. 8 Maxwell in about May of 2011 9 Plaintiff's Exhibit JES E-mail that Jeffrey 191 10 Epstein sent to Maxwell on 11 January 15th, 2015 12 Plaintiff's Exhibit JE9 Document 361-46 on 210 the public record in 13 the case Jane Doe versus United States 14 908CD80736 in the Southern District of 15 Florida, a document signed by Gerald 16 Lefcourt and Alan Dershowitz 17 Plaintiff's Exhibit Subpoena in this case 225 18 JEl0 for Jeffrey Epstein to appear at 19 deposition 20 Plaintiff's Exhibit Transcript of Ms. 347 JEll Maxwell, taken on 21 July 22, 2016 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 7 of 12 Page 6 1 QUESTIONS MARKED BY THE REQUEST OF COUNSEL: 2 PAGE/LINES 3 Page 69, lines 24 through 25 4 Page 70, lines 2 thorugh 16 (At the request of Mr. Pagliuca) 5 6 Page 280, lines 4 through 6 (At the request of Mr. Cassell) 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 8 of 12 Page 283 1 J. Epstein - Confidential 2 foundation. 3 THE WITNESS: Fifth. 4 BY MR. PAGLIUCA: 5 Q. In 2009, you entered into a settlement 6 agreement with Ms. Giuffre, formerly known as 7 Ms. Roberts, the Plaintiff in this case, correct? 8 MR. CASSELL: Object to form and 9 foundation. 10 THE WITNESS: Fifth. 11 MR. GOLDBERGER: And attorney-client 12 privilege. And to the extent that there's 13 an agreement that exists that's 14 confidential, we will not waive the 15 confidentiality agreement. 16 MR. PAGLIUCA: And we can have -- you 17 can have a standing objection to that on 18 those grounds related to any question I ask 19 about the settlement agreement with 20 Ms. Giuffre, if that makes it easier. 21 MR. GOLDBERGER: Yeah. That makes it 22 easier. Thank you. 23 BY MR. PAGLIUCA: 24 Q. I've not seen the settlement agreement. 25 But let me ask you if you can tell me what the terms MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 9 of 12 Page 284 1 J. Epstein - Confidential 2 of that agreement are, Mr. Epstein. 3 MR. CASSELL: Object to form and 4 foundation. 5 THE WITNESS: Fifth. 6 BY MR. PAGLIUCA: 7 Q. Does the settlement agreement contain a 8 release of any claims that Ms. Giuffre had or would 9 have against you? 10 MR. CASSELL: Object to form and 11 foundation. 12 THE WITNESS: Fifth. 13 BY MR. PAGLIUCA: 14 Q. Did the settlement agreement provide for a 15 release by you of any claims against Giuffre? 16 MR. CASSELL: Form and foundation. 17 THE WITNESS: Fifth. 18 BY MR. PAGLIUCA: 19 Q. It's true, is it not, Mr. Epstein, you have 20 no economic interest in this litigation? 21 MR. CASSELL: Form and foundation. 22 Calls for a legal conclusion. 23 THE WITNESS: Fifth. 24 BY MR. PAGLIUCA: 25 Q. And by "this litigation," I mean the MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 10 of 12 Page 375 1 CERTIFICATE OF OATH 2 3 STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 6 7 I, the undersigned authority, certify that 8 JEFFREY EPSTEIN personally appeared before me and was 9 duly sworn on September 9, 2016. 10 11 WITNESS my hand and official seal this 13th day 12 of September 2016. 13 14 15 16 DARLINE MARIE WEST Notary Public 17 18 19 My Commission Expires: October 26, 2017 20 #FF 060662 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 11 of 12 Page 376 1 RE PORTER ' S CERTIF I CATE 2 STATE OF FLORIDA 3 COUN TY OF PALM BEACH 4 5 I , DARLINE MARIE WEST , RPR , certify that I was 6 authorized to and did stenographically report the 7 foregoing deposition ; and that the transcript i s a· 8 true record thereof . 9 10 I further certify that I am not a relative , 11 employee , attorney , or counsel of any of the parties, 12 nor am I a relative or employee of any of the 13 parties ' attorney or counsel connected with the 14 action , nor a m I financially i nterested in the 15 action . 16 17 Dated t hi s 13th day of September 2016 . 18 19 20 21 22 DARLINE MARIE WEST , RPR 23 24 25 MAGNA& L E GAL S E RVICES Case 1:15-cv-07433-LAP Document 1331-9 Filed 01/05/24 Page 12 of 12 Page 377 1 C E R T I F I C A T E 2 STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, JEFFREY EPSTEIN, hereby certify that I 6 have read the foregoing transcript of my deposition 7 and that the statements contained therein, together 8 with any additions or corrections made on the 9 attached Errata Sheet, are true and correct. 10 11 12 Dated this day of - - - - - - - , 2016. 13 14 15 16 JEFFREY EPSTEIN 17 18 19 The foregoing certificate was subscribed to before me this ___ day of __________ , 2016, 20 by the witness who has produced a as identification and who did 21 not take an additional oath. 22 23 24 Notary Public 25 my commission expires: MAGNA9 LEGAL SERVICES