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Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 1 of 179
EXHIBIT 5
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO. 15-CV-07433-RWS
------------------------------------------x
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
May 18, 2016
9:04 a.m.
C O N F I D E N T I A L
Deposition of JOHANNA SJOBERG, pursuant
to notice, taken by Plaintiff, at the
offices of Boies Schiller & Flexner, 401
Las Olas Boulevard, Fort Lauderdale, Florida,
before Kelli Ann Willis, a Registered
Professional Reporter, Certified Realtime
Reporter and Notary Public within and
for the State of Florida.
MAGNA& LEGAL SERVICES
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1 A P P E A R A N C E S:
2 BOIES SCHILLER & FLEXNER, LLP
Attorneys for Plaintiff
3 401 East Las Olas Boulevard
Fort Lauderdale, Florida 33301
4 BY: SIGRID S. McCAWLEY, ESQ. and
MEREDITH SCHULTZ, ESQ.
5
6 HADDON MORGAN & FOREMAN, P.C.
Attorneys for Defendant
7 150 East 10th Avenue
Denver, Colorado 80203
8 BY: LAURA A. MENNINGER, ESQ.
9
10 SINCLAIR LOUIS & ZAVERTNIK, P.A.
Attorneys for Deponent
11 40 NW Third Street
Suite 200
12 Miami, Florida 33128
BY: MARSHALL DORE LOUIS, ESQ.
13
14
15 ALSO PRESENT: Ryan Kick, Videographer
16
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25
MAGNA& LEGAL SERVICES
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1
2 I N D E X
3 Examination by Ms. McCawley ................... 5
Examination by Ms. Menninger ................... 50
4 Further Examination by Ms. McCawley ............ 138
Further Examination by Ms. Menninger ........... 147
5
6
7 E X H I B I T S
8 Deposition Exhibit 1 ........................... 7
Deposition Notice
9
Deposition Exhibit 2 ........................... 7
10 Subpoena
11 Deposition Exhibit 3 ........................... 16
Flight log
12
Deposition Exhibit 4 ........................... 49
13 Palm Beach Police Department
Incident Report
14
Deposition Exhibit 5 ........................... 117
15 Red Ice Creations web article
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25
MAGNA& LEGAL SERVICES
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1 THE VIDEOGRAPHER: We are now on the
2 record. This is begins Videotape No. 1 in the
3 deposition of Johanna Sjoberg, in the matter of
4 Virginia Giuffre versus Ghislaine Maxwell.
5 Today is May 18th, 2016. The time is
6 9:04 a.m. This deposition is being taken at
7 401 East Las Olas Boulevard, Fort Lauderdale,
8 Florida.
9 The videographer is Ryan Kick. The court
10 reporter is Kelli Ann Willis. We both
11 represent Magna Legal Services.
12 Will counsel and all parties present state
13 their appearance and whom they represent.
14 MS. McCAWLEY: Yes. I'm Sigrid McCawley,
15 with the law firm of Boise Schiller & Flexner,
16 and I represent Virginia Giuffre. And I have
17 here two colleagues of mine, Meredith Schultz
18 and Sandra Perkins, from my firm as well.
19 MS. MENNINGER: Hi. I'm Laura Menninger
20 from Haddon Morgan & Foreman, and I represent
21 Ghislaine Maxwell.
22 MR. LOUIS: I'm Dore Louis from Sinclair
23 Louis & Zavertnik. I'm here on behalf of the
24 deponent.
25 Thereupon:
MAGNA& LEGAL SERVICES
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1 JOHANNA SJOBERG
2 a witness named in the notice heretofore filed,
3 being of lawful age and having been first duly
4 sworn, testified on her oath as follows:
5 E X A M I N A T I O N
6 BY MS. McCAWLEY:
7 Q. Good morning, Johanna. Thank you for
8 coming. I'm going to talk to you a little bit about
9 the deposition process before we get started to make
10 sure you understand what's going to happen here
11 today.
12 You just heard there's a videographer, and
13 he's going to be taking your video during this
14 deposition and generally what's happening in the
15 course of the deposition.
16 And then you have a court reporter here
17 who takes down the words that we say. And it's a
18 little bit tricky because I tend to speak quickly
19 sometimes and speak over people, and she needs to
20 get down all of the words. So I'll try to do my
21 best to go slower and make sure I'm not talking over
22 you.
23 And, similarly, if you've got an answer to
24 a question, make sure that you're verbally
25 responding, not just nodding or making a gesture
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1 because she can't get that down. We want to make
2 sure our responses are verbal. I'll try to remind
3 you of that if that happens.
4 Have you ever been deposed before?
5 A. No.
6 Q. No. Okay.
7 So what's going to happen is I'm going to
8 ask questions, and you'll give answers. And like I
9 said, everybody will be recording those.
10 Is there any reason, any medical reason,
11 anything you've taken today that would cause you to
12 not to be able to give truthful testimony today?
13 A. No.
14 Q. No. Okay.
15 All right. So we're going to get started,
16 and if you have any questions during the deposition
17 or you need to stop to take a break, you can just
18 let me know and we'll take that break.
19 So what I -- the only thing I ask is if
20 we're in the midst of a question, you finish the
21 answer before we take a break.
22 A. Sure.
23 Q. But I'll try to make sure that I take
24 regular breaks, as well.
25 You stated your name for the record. Can
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1 you tell me your date of birth?
2
3 Q. That makes you how old now?
4
5 Q. Okay. And where are you currently living?
6
7 Q. And I'm going to show you what I'm going
8 to mark as the first two exhibits in the matter.
9 And I'm going to ask the court reporter if I can
10 mark those.
11 (The referred-to document was marked by
12 the court reporter for Identification as
13 Sjoberg Exhibits 1 and 2.)
14 BY MS. McCAWLEY:
15 Q. Okay. I'm going to show you what I'm
16 marking as Exhibit 1. It's going to be the
17 re-notice of your videotaped deposition, which is
18 simply a notice I'm going to show you. And then
19 Exhibit 2 is the subpoena that we served on you.
20 So you're here today pursuant to our
21 Notice of Deposition and the subpoena that we served
22 on you.
23 Are you familiar with the subpoena? Have
24 you seen that document before?
25 A. Yes.
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1 Q. Okay. Great.
2 All right. Do you know a female by the
3 name of Ghislaine Maxwell?
4 A. Yes.
5 Q. And when did you first meet Ms. Maxwell?
6 A. 2001. March probably. End of
7 February/beginning of March.
8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I could tell her how to
13 find someone that would come and work at her house.
14 She wanted to know if there was, like, a bulletin
15 board or something that she could post, that she was
16 looking for someone to hire.
17 Q. And what did you discuss with her?
18 A. I told her where she could go to -- you
19 know, to put up a listing. And then she asked me if
20 I knew anyone that would be interested in working
21 for her.
22 Q. Did she describe what that work was going
23 to be?
24 A. She explained that she lived in Palm Beach
25 and didn't want butlers because they're too stuffy.
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1 And so she just liked to hire girls to work at the
2 house, answer phones, get drinks, do the job a
3 butler would do.
4 Q. And did she tell you what she would pay
5 for that kind of a job?
6 A. At that moment, no, but later in the day,
7 yes.
8 Q. And what did she say?
9 A. Twenty dollars an hour.
10 Q. Was there anybody else with Ms. Maxwell
11 when you met her?
12 A. There was another woman with her. I don't
13 recall her or what she looks like or how old she
14 was.
15 Q. And what happened next?
16 A. And then she asked me if I would be
17 interested in working for her. And she told me that
18 she was -- I could trust her and that I could jump
19 in her car and go check out the house at that moment
20 if I wanted.
21 And so I said, Sure, let's do it, and went
22 to her home with her.
23 Q. And where was that home?
24 A. In Palm Beach.
25 Q. And did she describe that home as being
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1 her home?
2 A. She described it as being her home and
3 alluded to the fact that it was her and Jeffrey's
4 home and that she had homes all over the world.
5 Yes.
6 Q. And what happened when you arrived at the
7 home?
8 A. I believe she just showed me around.
9 Q. Do you recall meeting anybody at the home?
10 A. I don't recall if I met Jeffrey at that
11 time or the next time that I was there.
12 Q. How did you meet Jeffrey? Did Maxwell
13 introduce you to Jeffrey?
14 A. Yes.
15 Q. What do you recall of your first meeting
16 with Jeffrey?
17 A. I remember him being in a bathrobe. I
18 recall talking to him about how I was a major in
19 psychology. And he had studied psychology, and so
20 he spoke with me about different topics.
21 I remember thinking this guy is very
22 smart. That was my first impression.
23 Q. And when you refer to Jeffrey, are you
24 referring to Jeffrey Epstein?
25 A. Yes.
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1 Q. How did the meeting -- you said Maxwell
2 took you to the home. Do you remember how that
3 meeting ended?
4 A. Well, she dropped me back off at campus.
5 Q. And did you --
6 A. She got my number and I took her number.
7 And then she called me the next weekend to work.
8 Q. So at that point you started working for
9 Ms. Maxwell?
10 A. At that time, yes.
11 MS. MENNINGER: Objection, leading.
12 Sorry.
13 BY MS. McCAWLEY:
14 Q. Did you then start working for Ms. Maxwell
15 after that first meeting?
16 A. She called me and I went over to the home
17 the next Sunday to work.
18 Q. And what work -- can you describe for me
19 the first day at work, what work you performed?
20 A. Sure. I remember answering the phones and
21 taking messages. And at one point, she asked me to
22 go pick up printer ink, and I took her car to Office
23 Depot to get ink.
24 She asked me to go buy some magazines, so
25 I went to Palm Beach Daily News and bought a few
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1 magazines.
2 She and I went -- she wanted to take me
3 shopping to Worth Avenue, but it was a Sunday and
4 Nieman Marcus was closed, so we went back to, like,
5 a little book store. And I remember she bought, I
6 think, five pairs of reading glasses because she
7 thought Jeffrey would like them. He had them all
8 over the house. On every table there was reading
9 glasses.
10 And that's about it. It was a pretty
11 simple day.
12 Q. Were you paid that day for that work?
13 A. Yes.
14 Q. And how much were you paid? Do you
15 remember?
16 A. I don't remember how many hours I was
17 there -- I was there. She paid me cash.
18 Q. So Maxwell paid you?
19 A. Yes.
20 Q. And then was she the one who trained you
21 with what -- with respect to what you were supposed
22 to do during the day, directed you to, like you
23 said, go to --
24 A. I believe she was the one that was kind of
25 showing me around.
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1 Q. And how long did you work in that position
2 answering phones and doing --
3 A. Just that one day.
4 Q. Just that one day.
5 And did your duties change?
6 A. Well, the next time she called me, she
7 asked me if I wanted to come over and make $100 an
8 hour rubbing feet.
9 Q. And what did you think of that offer?
10 A. I thought it was fantastic.
11 Q. And did you come over to the house for
12 that purpose?
13 A. Yes.
14 Q. And when you came over to the house, was
15 Maxwell present?
16 A. I don't recall.
17 Q. And what happened that second time you
18 came to the house?
19 A. At that point, I met Emmy Taylor, and she
20 took me up to Jeffrey's bathroom and he was present.
21 And her and I both massaged Jeffrey. She was
22 showing me how to massage.
23 And then she -- he took -- he got off the
24 table, she got on the table. She took off her
25 clothes, got on the table, and then he was showing
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1 me moves that he liked. And then I took my clothes
2 off. They asked me to get on the table so I could
3 feel it. Then they both massaged me.
4 Q. So it was more than a foot massage at that
5 point?
6 A. Yeah, it was mostly, like, legs and back.
7 Q. Was everybody in the room without clothes
8 on?
9 A. When they were on the massage table, yes.
10 Q. Did they -- when they got off the massage
11 table to perform the massage, did they dress or
12 did --
13 A. Yes.
14 Q. They dressed.
15 And do you recall who paid you for that
16 first day that you did the massages?
17 A. I don't recall.
18 Q. Do you recall whether Maxwell was at the
19 house during that first day when you were doing the
20 massage with Emmy and Jeffrey?
21 MS. MENNINGER: Objection, asked and
22 answered.
23 BY MS. McCAWLEY:
24 Q. You can answer.
25 A. I don't recall.
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1 Q. Who did Emmy work for?
2 A. Ghislaine.
3 Q. Did Maxwell ever refer to Emmy by any
4 particular term?
5 A. She called her her slave.
6 Q. You said your job duties changed. Did you
7 start to travel as part of your job with Jeffrey and
8 Ghislaine?
9 A. Yes. The next time they called me, they
10 asked me to go to New York.
11 Q. And did you -- do you recall when that was
12 approximately?
13 A. That was Easter of 2001.
14 Q. And do you recall who was on the plane
15 with you for that trip?
16 MS. MENNINGER: Objection, leading, form.
17 MS. McCAWLEY: Actually, I'm going to stop
18 really quickly and I'm going to ask for the
19 next exhibit, please.
20 MS. MENNINGER: This is 3?
21 MS. McCAWLEY: Yes. I'm going to mark
22 this as Exhibit 3 for purposes of the
23 deposition.
24
25
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1 (The referred-to document was marked by
2 the court reporter for Identification as
3 Sjoberg Exhibit 3.)
4 BY MS. McCAWLEY:
5 Q. Johanna, I'm going to direct you -- I
6 flagged some pages, but for the record, I'm going to
7 say what pages they are before I hand you the
8 exhibit.
9 A. Sure.
10 Q. These are Giuffre 000748 and 000758, are
11 the two pages right now I may refer you to. The
12 document itself is 000721 through 789.
13 And these are flight logs from pilot David
14 Rogers that have been produced in this case.
15 MS. MENNINGER: Objection, foundation,
16 asking the witness any questions about this
17 document.
18 THE WITNESS: Can I touch it?
19 MS. McCAWLEY: Yes, you may.
20 MS. MENNINGER: I just have to say things
21 every now and then.
22 THE WITNESS: Okay.
23 BY MS. McCAWLEY:
24 Q. So you mentioned that you traveled to New
25 York. If you turn to page -- flagged page which
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1 should be 000748, at the top of that document you're
2 going to see a date of April 2001.
3 I'm just going to ask you to go down to
4 the -- if you look at the line on the left to where
5 it says 9 for the date, and look over where it has
6 the names.
7 Do you see -- can you identify your name
8 on that list?
9 A. Yes.
10 Q. And can you tell me -- I know there are
11 initials there -- who else to the extent you
12 remember was on the plane with you?
13 MS. MENNINGER: Objection, foundation,
14 leading, form of question.
15 BY MS. McCAWLEY:
16 Q. Johanna, do you recall who was on the
17 plane with you that day?
18 MS. MENNINGER: Objection, foundation,
19 form, leading.
20 The witness is reading the document.
21 BY MS. McCAWLEY:
22 Q. You can answer.
23 A. Okay. JE, Jeffrey Epstein; ET, Emmy
24 Taylor; VR, Virginia Roberts; BK, I do not recall;
25 and myself.
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1 MS. MENNINGER: Objection. The witness is
2 reading the document.
3 BY MS. McCAWLEY:
4 Q. And do you recall where you flew when you
5 went to -- when you traveled that first time with
6 Jeffrey Epstein?
7 A. We left from Palm Beach and landed in
8 Atlantic City for a few hours because there was a
9 storm in New York, and then got back on the plane a
10 few hours later and landed in Teterboro.
11 Q. And you said that you recall landing in
12 Atlantic City. Did you go into Atlantic City?
13 A. Yes, went to one of Trump's casinos.
14 Q. Did you actually go into the casino
15 itself?
16 A. Yes.
17 Q. Do you recall Virginia -- at the time
18 Virginia Roberts being present with you?
19 A. Yes.
20 Q. Do you recall if she went into the casino?
21 A. She was underage. I did not know anything
22 about how old you had to be to gamble legally. I
23 just knew she could not get in because of an ID
24 issue. So she and I did not gamble.
25 Q. In your opinion, did Virginia look young,
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1 in your view?
2 A. Yes.
3 Q. Did you ever -- did you at that time
4 wonder why she was traveling with Jeffrey?
5 A. At that time, I did not.
6 Q. Did you later wonder that?
7 A. Yes.
8 Q. And what was your impression?
9 MS. MENNINGER: Objection, vague,
10 speculative.
11 THE WITNESS: I -- we're jumping ahead; is
12 that okay?
13 BY MS. McCAWLEY:
14 Q. Yes, that's okay.
15 A. A few days later, I remember asking her
16 questions to try to figure out her role, why she was
17 there, and she gave me vague answers and was never
18 specific.
19 And so I thought perhaps she just was an
20 assistant, someone that did massages well. I wanted
21 to believe that she was innocent.
22 Q. Did you ever refer to her as being
23 orphan-like?
24 A. I did.
25 Q. And how did that come about?
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1 A. No, I only -- to you, I said that to you.
2 I just saw her as perhaps someone who may not have
3 had a strong family, and they took her under their
4 wing.
5 Q. Now, you mentioned remembering going to
6 Atlantic City.
7 Did you go -- where did you go after
8 Atlantic City?
9 A. Once we landed in New York, Emmy and I
10 went in a car and drove around the city for a half
11 hour or so, just to see some of the city.
12 Q. And then where did you go after doing the
13 sightseeing?
14 A. We went to the townhouse on East 71st.
15 Q. And can you describe that location for me?
16 A. Sure. Between Madison and Park. I think
17 the address might have been 9 East 71st Street.
18 Q. And who owned that home?
19 A. As far as I knew, Epstein.
20 Q. Can you describe for me physically what --
21 A. Palatial. When you walk up, it looks like
22 a normal door to a townhouse, and when you walk
23 in -- I thought there were four floors. I heard
24 there were seven floors. I didn't see them all.
25 Q. And do you recall who, if anybody, was at
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1 Jeffrey's home when you arrived?
2 A. Yes. When I first walked in the door, it
3 was just myself, and Ghislaine headed for the
4 staircase and said -- told me to come up to the
5 living room.
6 Q. And what happened at that point, when you
7 came up to the living room?
8 A. I came up and saw Virginia, Jeffrey,
9 Prince Andrew, Ghislaine in the room.
10 Q. And did you meet Prince Andrew at that
11 time?
12 A. Yes.
13 Q. And what happened next?
14 A. At one point, Ghislaine told me to come
15 upstairs, and we went into a closet and pulled out
16 the puppet, the caricature of Prince Andrew, and
17 brought it down. And there was a little tag on the
18 puppet that said "Prince Andrew" on it, and that's
19 when I knew who he was.
20 Q. And did -- what did the puppet look like?
21 A. It looked like him. And she brought it
22 down and presented it to him; and that was a great
23 joke, because apparently it was a production from a
24 show on BBC. And they decided to take a picture
25 with it, in which Virginia and Andrew sat on a
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1 couch. They put the puppet on Virginia's lap, and I
2 sat on Andrew's lap, and they put the puppet's hand
3 on Virginia's breast, and Andrew put his hand on my
4 breast, and they took a photo.
5 Q. Do you remember who took the photo?
6 A. I don't recall.
7 Q. Did you ever see the photo after it was
8 taken?
9 A. I did not.
10 Q. And Ms. Maxwell was present during the --
11 was Ms. Maxwell present during that?
12 A. Yes.
13 Q. What happened next?
14 A. The next thing I remember is just being
15 shown to which room I was going to be staying in.
16 Q. When you exited the room that you were in
17 where the picture was taken, do you recall who
18 remained in that room?
19 A. I don't.
20 Q. Do you recall seeing Virginia exit that
21 room?
22 A. I don't.
23 Q. During this trip to New York, did you have
24 to perform any work when you were at the New York
25 house?
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1 A. I performed at least one massage that I
2 recall.
3 Q. And who instructed you to give that
4 massage?
5 A. Jeffrey.
6 Q. And can you describe for me what happened
7 during that massage?
8 A. Near the end, he asked me to rub his
9 nipples while he masturbated.
10 Q. And did that take place?
11 A. It did not.
12 Q. And why not?
13 A. I was not comfortable with it. And so I
14 left the room.
15 Q. Did you have any -- did you say anything
16 to him before leaving the room?
17 A. I believe I said, "I'm done."
18 Q. Do you recall what his reaction was to
19 that?
20 A. I do not. At the time, at that moment, I
21 do not.
22 Q. Did you recall later what --
23 A. Well, we had a conversation a little
24 later, talking about his expectations, and that was
25 the conversation where he said that the next trip
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1 they were going on was to the island in the Virgin
2 Islands, and I would be invited; however, there
3 would be, quote, sex stuff happening.
4 Q. Can you describe for me -- can you
5 describe for me what that -- in New York, where you
6 massaged and what that looked like?
7 A. He had one room that was the massage room.
8 It was about the size of a spa room in a spa. It
9 had high ceilings. It had dark tapestry on the
10 walls. It was a very dark room. There was a very
11 large picture of a naked woman whom I don't recall.
12 That's all I remember.
13 Q. In the New York home, did you observe
14 photos around the house?
15 A. I don't recall.
16 Q. In the Palm Beach home that we were
17 talking about earlier, did you recall seeing photos
18 in that?
19 A. Yes.
20 Q. And did you recall seeing photos of naked
21 females in that home?
22 A. Yes.
23 Q. Approximately -- can you tell me where you
24 would see those in the home?
25 A. I definitely saw them in his bathroom.
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1 And I can't recall if they were in the main living
2 areas.
3 Q. Did you see them in the stairwell up to
4 the second story of the house?
5 A. I can't recall.
6 Q. Do you know who -- who the people were in
7 those photos? Were you familiar with any of them?
8 A. No.
9 Q. Were you in any of those photos?
10 A. At one point, yes.
11 Q. And were you naked in that photo?
12 A. Topless.
13 Q. Do you recall seeing any naked photos of
14 Virginia Roberts?
15 A. I do not.
16 Q. Where did you go next, after the New York
17 visit?
18 A. I went to the Virgin Islands.
19 Q. And who told you that you would be going
20 to the Virgin Islands?
21 A. He asked me if I wanted to go, and I said
22 I would still like to go.
23 Q. And do you recall who you -- who went with
24 you to the Virgin Islands?
25 A. I believe -- well, I know Virginia was
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1 with me. Ghislaine was there. Jeffrey. And there
2 were two other women that I don't recall their
3 names.
4 Q. Did you travel on Jeffrey's plane to get
5 to the Virgin Islands?
6 A. Yes.
7 Q. I want to show you again the flight log
8 that you have there in front of you. If you can
9 flip to --
10 MS. MENNINGER: I'm going to object to the
11 foundation again.
12 BY MS. McCAWLEY:
13 Q. It's that same page that you were on. The
14 date is the 11th.
15 A. Yes.
16 Q. Do you see the TEB to TIST there?
17 A. Yes.
18 MS. MENNINGER: Objection, leading. The
19 questioning is testifying now.
20 MS. McCAWLEY: Can you let me finish my
21 question, please?
22 BY MS. McCAWLEY:
23 Q. Can you tell me who the initials are there
24 that you see that were on the plane?
25 MS. MENNINGER: Objection, foundation,
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1 leading.
2 THE WITNESS: Jeffrey Epstein; Ghislaine
3 Maxwell; AP and PK are the two women I do not
4 recall; Virginia Roberts; and myself.
5 BY MS. McCAWLEY:
6 Q. Do you recall how you flew back from the
7 location in the US Virgin Islands?
8 A. They put me on a commercial flight. I
9 wanted to be home in time for Easter.
10 Q. When you say "they," do you recall who
11 made those arrangements for you?
12 A. It could have been Ghislaine.
13 Q. Did you -- do you recall performing
14 massages while you were in the US Virgin Islands?
15 A. Yes.
16 Q. Who was involved in -- was there more than
17 one?
18 A. Yes. I massaged Ghislaine at one point.
19 And I massaged Jeffrey, Virginia and I, both, on the
20 beach.
21 Q. Were you dressed during the massage that
22 was on the beach?
23 A. Yes. Bikinis probably, most likely.
24 Q. Do you recall what Virginia was wearing?
25 A. I believe she was wearing a bathing suit,
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1 as well.
2 Q. Were you paid for the massage on the beach
3 with Virginia?
4 A. At the end of -- before I left and flew
5 home, Ghislaine gave me $1,000.
6 Q. You mentioned that you massaged -- you
7 recall massaging Ghislaine on the trip to the USVI.
8 Do you recall when that took place?
9 A. I don't even recall what days we were
10 there, so...
11 Q. Do you recall where it took place?
12 A. I believe it was -- well, either in my
13 guest cottage or one of them. There were three
14 guest houses set up that were all similar and that I
15 was staying in. Virginia and I stayed in one
16 together. And it was either in there or in another
17 one that was identical.
18 Q. And was that massage performed with
19 Virginia as well or by you alone?
20 A. I don't recall.
21 Q. Were there other females in the USVI on
22 that trip with you besides Virginia?
23 A. Two others.
24 Q. And do you recall who they were?
25 A. I do not.
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1 Q. Did you ever see Ghislaine Maxwell during
2 that trip laying out by the pool?
3 A. There was one time where we were all by
4 the pool, yes.
5 Q. Was Ghislaine Maxwell ever nude or topless
6 by the pool?
7 A. I don't recall. She was nude when she
8 went swimming in the ocean.
9 Q. At that moment in the USVI home, did you
10 observe any photos there of nude females?
11 A. I don't recall.
12 Q. Besides Virginia, who you mentioned, you
13 observed to be young, did you observe any other
14 females that in your view appeared to be essentially
15 under the age of 18?
16 A. No.
17 Q. Did you observe any females who you
18 thought looked young, younger than you?
19 A. No.
20 Q. Do you remember an individual by the name
21 of that you met during your time with Jeffrey
22 Epstein?
23 A. In Palm Beach?
24 Q. Yes.
25 A. Yes.
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1 Q. Did you observe her to be young when you
2 met her?
3 MS. MENNINGER: Objection, vague as to
4 time.
5 THE WITNESS: All of the women were
6 generally young. I did not know the ages of
7 really anyone, so...
8 BY MS. McCAWLEY:
9 Q. How many massages did Jeffrey receive on
10 average in a given day?
11 MS. MENNINGER: Objection, foundation.
12 THE WITNESS: Three a day.
13 BY MS. McCAWLEY:
14 Q. Let me back up for a moment.
15 How long did you work for Jeffrey and
16 Ghislaine?
17 MS. MENNINGER: Objection, leading and
18 foundation.
19 THE WITNESS: I believe it was five years,
20 2001 to 2006.
21 BY MS. McCAWLEY:
22 Q. And how many massages did Epstein receive
23 per day on average?
24 MS. MENNINGER: Objection, foundation.
25 THE WITNESS: Three.
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1 BY MS. McCAWLEY:
2 Q. Were the massages performed by the same
3 girl or different females?
4 A. Different.
5 MS. MENNINGER: Objection, foundation.
6 BY MS. McCAWLEY:
7 Q. What did the females who performed the
8 massages look like?
9 MS. MENNINGER: Objection, foundation.
10 THE WITNESS: They all looked different.
11 Some of them were ethnic, some were blond, some
12 were short, some were tall. Everyone was thin.
13 BY MS. McCAWLEY:
14 Q. Were the girls who performed the massages
15 young or old?
16 MS. MENNINGER: Objection, foundation.
17 THE WITNESS: I don't recall anyone being
18 old.
19 BY MS. McCAWLEY:
20 Q. Do you recall anybody being over the age
21 of, say, 25?
22 MS. MENNINGER: Objection, form.
23 THE WITNESS: Yeah, I believe there was
24 probably a few women that were older than 25.
25 MS. MENNINGER: I'm sorry. I get a chance
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1 to object and then you can still answer. No
2 one is going to stop you from answering. I
3 just need to get the objection on the record,
4 in the same way she needs to be able to talk
5 before you. My apologies. I'm not trying to
6 cut you off, but I am supposed to get it in
7 before you answer.
8 BY MS. McCAWLEY:
9 Q. Did Jeffrey ever tell you why he received
10 so many massages from so many different girls?
11 MS. MENNINGER: Objection, hearsay.
12 BY MS. McCAWLEY:
13 Q. You can answer.
14 A. He explained to me that, in his opinion,
15 he needed to have three orgasms a day. It was
16 biological, like eating.
17 Q. And what was your reaction to that
18 statement?
19 A. I thought it was a little crazy.
20 Q. And what did -- do you recall what -- when
21 you observed the other females giving massages, do
22 you recall what they would dress like? Did they
23 wear scrubs or did they typically wear normal
24 clothes?
25 A. Normal clothes.
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1 MS. MENNINGER: Objection, leading.
2 BY MS. McCAWLEY:
3 Q. Do you believe that from your
4 observations, Maxwell and Epstein were boyfriend and
5 girlfriend?
6 A. Initially, yes.
7 Q. Did Maxwell ever share with you whether it
8 bothered her that Jeffrey had so many girls around?
9 MS. MENNINGER: Objection, leading,
10 hearsay.
11 THE WITNESS: No. Actually, the opposite.
12 BY MS. McCAWLEY:
13 Q. What did she say?
14 A. She let me know that she was -- she would
15 not be able to please him as much as he needed and
16 that is why there were other girls around.
17 Q. Did there ever come a time -- did you ever
18 take a photography class in school?
19 A. Yes.
20 Q. And did there ever come a time when
21 Maxwell offered to buy you a camera?
22 A. Yes.
23 MS. MENNINGER: Objection, leading.
24 BY MS. McCAWLEY:
25 Q. Did Maxwell ever offer to buy you a
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1 camera?
2 MS. MENNINGER: Objection, leading.
3 THE WITNESS: Yes.
4 BY MS. McCAWLEY:
5 Q. Was there anything you were supposed to do
6 in order to get the camera?
7 MS. MENNINGER: Objection, leading.
8 THE WITNESS: I did not know that there
9 were expectations of me to get the camera until
10 after. She had purchased the camera for me,
11 and I was over there giving Jeffrey a massage.
12 I did not know that she was in possession of
13 the camera until later.
14 She told me -- called me after I had left
15 and said, I have the camera for you, but you
16 cannot receive it yet because you came here and
17 didn't finish your job and I had to finish it
18 for you.
19 BY MS. McCAWLEY:
20 Q. And did you -- what did you understand her
21 to mean?
22 A. She was implying that I did not get
23 Jeffrey off, and so she had to do it.
24 Q. And when you say "get Jeffrey off," do you
25 mean bring him to orgasm?
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1 A. Yes.
2 Q. Did Ghislaine ever describe to you what
3 types of girls Jeffrey liked?
4 A. Model types.
5 Q. Did Ghislaine ever talk to you about how
6 you should act around Jeffrey?
7 A. She just had a conversation with me that I
8 should always act grateful.
9 Q. Did Jeffrey ever tell you that he took a
10 girl's virginity?
11 A. He did not tell me. He told a friend of
12 mine.
13 Q. And what do you recall about that?
14 MS. MENNINGER: Objection, hearsay,
15 foundation.
16 THE WITNESS: He wanted to have a friend
17 of mine come out who was cardio-kickboxer
18 instructor. She was a physical trainer.
19 And so I brought her over to the house,
20 and he told my friend Rachel that -- he said,
21 You see that girl over there laying by the
22 pool? She was 19. And he said, I just took
23 her virginity. And my friend Rachel was
24 mortified.
25
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1 BY MS. McCAWLEY:
2 Q. Based on what you knew, did Maxwell know
3 that the type of massages Jeffrey was getting
4 typically involved sexual acts?
5 MS. MENNINGER: Objection, foundation,
6 leading.
7 THE WITNESS: Yes.
8 BY MS. McCAWLEY:
9 Q. What was Maxwell's main job with respect
10 to Jeffrey?
11 MS. MENNINGER: Objection, foundation.
12 THE WITNESS: Well, beyond companionship,
13 her job, as it related to me, was to find other
14 girls that would perform massages for him and
15 herself.
16 BY MS. McCAWLEY:
17 Q. Did Maxwell ever refer to the girls in a
18 particular way?
19 A. At one point when we were in the islands,
20 we were all watching a movie and she called us her
21 children.
22 Q. Did anybody respond to that?
23 A. I don't recall.
24 Q. Did she ever refer to herself as a mother?
25 A. Yes, like a mother hen.
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1 Q. Do you recall who was present at the time
2 that she made that comment about children?
3 A. This was the second trip that I took to
4 the Virgin Islands, so, no. I don't want to speak,
5 you know, incorrectly. I can't remember. I can't
6 really remember.
7 Q. Have you ever met David Copperfield?
8 A. Yes.
9 Q. And do you recall when you initially met
10 him?
11 A. Yes.
12 Q. Can you tell me what that was?
13 A. Sure. Someone called me from the house
14 and said that he would be there, and if I wanted to
15 come have dinner, then I could meet him.
16 So when I arrived at the house, he wasn't
17 there yet, but I wa
EXHIBIT 5
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Page 1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO. 15-CV-07433-RWS
------------------------------------------x
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
May 18, 2016
9:04 a.m.
C O N F I D E N T I A L
Deposition of JOHANNA SJOBERG, pursuant
to notice, taken by Plaintiff, at the
offices of Boies Schiller & Flexner, 401
Las Olas Boulevard, Fort Lauderdale, Florida,
before Kelli Ann Willis, a Registered
Professional Reporter, Certified Realtime
Reporter and Notary Public within and
for the State of Florida.
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1 A P P E A R A N C E S:
2 BOIES SCHILLER & FLEXNER, LLP
Attorneys for Plaintiff
3 401 East Las Olas Boulevard
Fort Lauderdale, Florida 33301
4 BY: SIGRID S. McCAWLEY, ESQ. and
MEREDITH SCHULTZ, ESQ.
5
6 HADDON MORGAN & FOREMAN, P.C.
Attorneys for Defendant
7 150 East 10th Avenue
Denver, Colorado 80203
8 BY: LAURA A. MENNINGER, ESQ.
9
10 SINCLAIR LOUIS & ZAVERTNIK, P.A.
Attorneys for Deponent
11 40 NW Third Street
Suite 200
12 Miami, Florida 33128
BY: MARSHALL DORE LOUIS, ESQ.
13
14
15 ALSO PRESENT: Ryan Kick, Videographer
16
17
18
19
20
21
22
23
24
25
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1
2 I N D E X
3 Examination by Ms. McCawley ................... 5
Examination by Ms. Menninger ................... 50
4 Further Examination by Ms. McCawley ............ 138
Further Examination by Ms. Menninger ........... 147
5
6
7 E X H I B I T S
8 Deposition Exhibit 1 ........................... 7
Deposition Notice
9
Deposition Exhibit 2 ........................... 7
10 Subpoena
11 Deposition Exhibit 3 ........................... 16
Flight log
12
Deposition Exhibit 4 ........................... 49
13 Palm Beach Police Department
Incident Report
14
Deposition Exhibit 5 ........................... 117
15 Red Ice Creations web article
16
17
18
19
20
21
22
23
24
25
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1 THE VIDEOGRAPHER: We are now on the
2 record. This is begins Videotape No. 1 in the
3 deposition of Johanna Sjoberg, in the matter of
4 Virginia Giuffre versus Ghislaine Maxwell.
5 Today is May 18th, 2016. The time is
6 9:04 a.m. This deposition is being taken at
7 401 East Las Olas Boulevard, Fort Lauderdale,
8 Florida.
9 The videographer is Ryan Kick. The court
10 reporter is Kelli Ann Willis. We both
11 represent Magna Legal Services.
12 Will counsel and all parties present state
13 their appearance and whom they represent.
14 MS. McCAWLEY: Yes. I'm Sigrid McCawley,
15 with the law firm of Boise Schiller & Flexner,
16 and I represent Virginia Giuffre. And I have
17 here two colleagues of mine, Meredith Schultz
18 and Sandra Perkins, from my firm as well.
19 MS. MENNINGER: Hi. I'm Laura Menninger
20 from Haddon Morgan & Foreman, and I represent
21 Ghislaine Maxwell.
22 MR. LOUIS: I'm Dore Louis from Sinclair
23 Louis & Zavertnik. I'm here on behalf of the
24 deponent.
25 Thereupon:
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1 JOHANNA SJOBERG
2 a witness named in the notice heretofore filed,
3 being of lawful age and having been first duly
4 sworn, testified on her oath as follows:
5 E X A M I N A T I O N
6 BY MS. McCAWLEY:
7 Q. Good morning, Johanna. Thank you for
8 coming. I'm going to talk to you a little bit about
9 the deposition process before we get started to make
10 sure you understand what's going to happen here
11 today.
12 You just heard there's a videographer, and
13 he's going to be taking your video during this
14 deposition and generally what's happening in the
15 course of the deposition.
16 And then you have a court reporter here
17 who takes down the words that we say. And it's a
18 little bit tricky because I tend to speak quickly
19 sometimes and speak over people, and she needs to
20 get down all of the words. So I'll try to do my
21 best to go slower and make sure I'm not talking over
22 you.
23 And, similarly, if you've got an answer to
24 a question, make sure that you're verbally
25 responding, not just nodding or making a gesture
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1 because she can't get that down. We want to make
2 sure our responses are verbal. I'll try to remind
3 you of that if that happens.
4 Have you ever been deposed before?
5 A. No.
6 Q. No. Okay.
7 So what's going to happen is I'm going to
8 ask questions, and you'll give answers. And like I
9 said, everybody will be recording those.
10 Is there any reason, any medical reason,
11 anything you've taken today that would cause you to
12 not to be able to give truthful testimony today?
13 A. No.
14 Q. No. Okay.
15 All right. So we're going to get started,
16 and if you have any questions during the deposition
17 or you need to stop to take a break, you can just
18 let me know and we'll take that break.
19 So what I -- the only thing I ask is if
20 we're in the midst of a question, you finish the
21 answer before we take a break.
22 A. Sure.
23 Q. But I'll try to make sure that I take
24 regular breaks, as well.
25 You stated your name for the record. Can
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1 you tell me your date of birth?
2
3 Q. That makes you how old now?
4
5 Q. Okay. And where are you currently living?
6
7 Q. And I'm going to show you what I'm going
8 to mark as the first two exhibits in the matter.
9 And I'm going to ask the court reporter if I can
10 mark those.
11 (The referred-to document was marked by
12 the court reporter for Identification as
13 Sjoberg Exhibits 1 and 2.)
14 BY MS. McCAWLEY:
15 Q. Okay. I'm going to show you what I'm
16 marking as Exhibit 1. It's going to be the
17 re-notice of your videotaped deposition, which is
18 simply a notice I'm going to show you. And then
19 Exhibit 2 is the subpoena that we served on you.
20 So you're here today pursuant to our
21 Notice of Deposition and the subpoena that we served
22 on you.
23 Are you familiar with the subpoena? Have
24 you seen that document before?
25 A. Yes.
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1 Q. Okay. Great.
2 All right. Do you know a female by the
3 name of Ghislaine Maxwell?
4 A. Yes.
5 Q. And when did you first meet Ms. Maxwell?
6 A. 2001. March probably. End of
7 February/beginning of March.
8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I could tell her how to
13 find someone that would come and work at her house.
14 She wanted to know if there was, like, a bulletin
15 board or something that she could post, that she was
16 looking for someone to hire.
17 Q. And what did you discuss with her?
18 A. I told her where she could go to -- you
19 know, to put up a listing. And then she asked me if
20 I knew anyone that would be interested in working
21 for her.
22 Q. Did she describe what that work was going
23 to be?
24 A. She explained that she lived in Palm Beach
25 and didn't want butlers because they're too stuffy.
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1 And so she just liked to hire girls to work at the
2 house, answer phones, get drinks, do the job a
3 butler would do.
4 Q. And did she tell you what she would pay
5 for that kind of a job?
6 A. At that moment, no, but later in the day,
7 yes.
8 Q. And what did she say?
9 A. Twenty dollars an hour.
10 Q. Was there anybody else with Ms. Maxwell
11 when you met her?
12 A. There was another woman with her. I don't
13 recall her or what she looks like or how old she
14 was.
15 Q. And what happened next?
16 A. And then she asked me if I would be
17 interested in working for her. And she told me that
18 she was -- I could trust her and that I could jump
19 in her car and go check out the house at that moment
20 if I wanted.
21 And so I said, Sure, let's do it, and went
22 to her home with her.
23 Q. And where was that home?
24 A. In Palm Beach.
25 Q. And did she describe that home as being
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1 her home?
2 A. She described it as being her home and
3 alluded to the fact that it was her and Jeffrey's
4 home and that she had homes all over the world.
5 Yes.
6 Q. And what happened when you arrived at the
7 home?
8 A. I believe she just showed me around.
9 Q. Do you recall meeting anybody at the home?
10 A. I don't recall if I met Jeffrey at that
11 time or the next time that I was there.
12 Q. How did you meet Jeffrey? Did Maxwell
13 introduce you to Jeffrey?
14 A. Yes.
15 Q. What do you recall of your first meeting
16 with Jeffrey?
17 A. I remember him being in a bathrobe. I
18 recall talking to him about how I was a major in
19 psychology. And he had studied psychology, and so
20 he spoke with me about different topics.
21 I remember thinking this guy is very
22 smart. That was my first impression.
23 Q. And when you refer to Jeffrey, are you
24 referring to Jeffrey Epstein?
25 A. Yes.
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1 Q. How did the meeting -- you said Maxwell
2 took you to the home. Do you remember how that
3 meeting ended?
4 A. Well, she dropped me back off at campus.
5 Q. And did you --
6 A. She got my number and I took her number.
7 And then she called me the next weekend to work.
8 Q. So at that point you started working for
9 Ms. Maxwell?
10 A. At that time, yes.
11 MS. MENNINGER: Objection, leading.
12 Sorry.
13 BY MS. McCAWLEY:
14 Q. Did you then start working for Ms. Maxwell
15 after that first meeting?
16 A. She called me and I went over to the home
17 the next Sunday to work.
18 Q. And what work -- can you describe for me
19 the first day at work, what work you performed?
20 A. Sure. I remember answering the phones and
21 taking messages. And at one point, she asked me to
22 go pick up printer ink, and I took her car to Office
23 Depot to get ink.
24 She asked me to go buy some magazines, so
25 I went to Palm Beach Daily News and bought a few
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1 magazines.
2 She and I went -- she wanted to take me
3 shopping to Worth Avenue, but it was a Sunday and
4 Nieman Marcus was closed, so we went back to, like,
5 a little book store. And I remember she bought, I
6 think, five pairs of reading glasses because she
7 thought Jeffrey would like them. He had them all
8 over the house. On every table there was reading
9 glasses.
10 And that's about it. It was a pretty
11 simple day.
12 Q. Were you paid that day for that work?
13 A. Yes.
14 Q. And how much were you paid? Do you
15 remember?
16 A. I don't remember how many hours I was
17 there -- I was there. She paid me cash.
18 Q. So Maxwell paid you?
19 A. Yes.
20 Q. And then was she the one who trained you
21 with what -- with respect to what you were supposed
22 to do during the day, directed you to, like you
23 said, go to --
24 A. I believe she was the one that was kind of
25 showing me around.
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1 Q. And how long did you work in that position
2 answering phones and doing --
3 A. Just that one day.
4 Q. Just that one day.
5 And did your duties change?
6 A. Well, the next time she called me, she
7 asked me if I wanted to come over and make $100 an
8 hour rubbing feet.
9 Q. And what did you think of that offer?
10 A. I thought it was fantastic.
11 Q. And did you come over to the house for
12 that purpose?
13 A. Yes.
14 Q. And when you came over to the house, was
15 Maxwell present?
16 A. I don't recall.
17 Q. And what happened that second time you
18 came to the house?
19 A. At that point, I met Emmy Taylor, and she
20 took me up to Jeffrey's bathroom and he was present.
21 And her and I both massaged Jeffrey. She was
22 showing me how to massage.
23 And then she -- he took -- he got off the
24 table, she got on the table. She took off her
25 clothes, got on the table, and then he was showing
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1 me moves that he liked. And then I took my clothes
2 off. They asked me to get on the table so I could
3 feel it. Then they both massaged me.
4 Q. So it was more than a foot massage at that
5 point?
6 A. Yeah, it was mostly, like, legs and back.
7 Q. Was everybody in the room without clothes
8 on?
9 A. When they were on the massage table, yes.
10 Q. Did they -- when they got off the massage
11 table to perform the massage, did they dress or
12 did --
13 A. Yes.
14 Q. They dressed.
15 And do you recall who paid you for that
16 first day that you did the massages?
17 A. I don't recall.
18 Q. Do you recall whether Maxwell was at the
19 house during that first day when you were doing the
20 massage with Emmy and Jeffrey?
21 MS. MENNINGER: Objection, asked and
22 answered.
23 BY MS. McCAWLEY:
24 Q. You can answer.
25 A. I don't recall.
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1 Q. Who did Emmy work for?
2 A. Ghislaine.
3 Q. Did Maxwell ever refer to Emmy by any
4 particular term?
5 A. She called her her slave.
6 Q. You said your job duties changed. Did you
7 start to travel as part of your job with Jeffrey and
8 Ghislaine?
9 A. Yes. The next time they called me, they
10 asked me to go to New York.
11 Q. And did you -- do you recall when that was
12 approximately?
13 A. That was Easter of 2001.
14 Q. And do you recall who was on the plane
15 with you for that trip?
16 MS. MENNINGER: Objection, leading, form.
17 MS. McCAWLEY: Actually, I'm going to stop
18 really quickly and I'm going to ask for the
19 next exhibit, please.
20 MS. MENNINGER: This is 3?
21 MS. McCAWLEY: Yes. I'm going to mark
22 this as Exhibit 3 for purposes of the
23 deposition.
24
25
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1 (The referred-to document was marked by
2 the court reporter for Identification as
3 Sjoberg Exhibit 3.)
4 BY MS. McCAWLEY:
5 Q. Johanna, I'm going to direct you -- I
6 flagged some pages, but for the record, I'm going to
7 say what pages they are before I hand you the
8 exhibit.
9 A. Sure.
10 Q. These are Giuffre 000748 and 000758, are
11 the two pages right now I may refer you to. The
12 document itself is 000721 through 789.
13 And these are flight logs from pilot David
14 Rogers that have been produced in this case.
15 MS. MENNINGER: Objection, foundation,
16 asking the witness any questions about this
17 document.
18 THE WITNESS: Can I touch it?
19 MS. McCAWLEY: Yes, you may.
20 MS. MENNINGER: I just have to say things
21 every now and then.
22 THE WITNESS: Okay.
23 BY MS. McCAWLEY:
24 Q. So you mentioned that you traveled to New
25 York. If you turn to page -- flagged page which
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1 should be 000748, at the top of that document you're
2 going to see a date of April 2001.
3 I'm just going to ask you to go down to
4 the -- if you look at the line on the left to where
5 it says 9 for the date, and look over where it has
6 the names.
7 Do you see -- can you identify your name
8 on that list?
9 A. Yes.
10 Q. And can you tell me -- I know there are
11 initials there -- who else to the extent you
12 remember was on the plane with you?
13 MS. MENNINGER: Objection, foundation,
14 leading, form of question.
15 BY MS. McCAWLEY:
16 Q. Johanna, do you recall who was on the
17 plane with you that day?
18 MS. MENNINGER: Objection, foundation,
19 form, leading.
20 The witness is reading the document.
21 BY MS. McCAWLEY:
22 Q. You can answer.
23 A. Okay. JE, Jeffrey Epstein; ET, Emmy
24 Taylor; VR, Virginia Roberts; BK, I do not recall;
25 and myself.
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1 MS. MENNINGER: Objection. The witness is
2 reading the document.
3 BY MS. McCAWLEY:
4 Q. And do you recall where you flew when you
5 went to -- when you traveled that first time with
6 Jeffrey Epstein?
7 A. We left from Palm Beach and landed in
8 Atlantic City for a few hours because there was a
9 storm in New York, and then got back on the plane a
10 few hours later and landed in Teterboro.
11 Q. And you said that you recall landing in
12 Atlantic City. Did you go into Atlantic City?
13 A. Yes, went to one of Trump's casinos.
14 Q. Did you actually go into the casino
15 itself?
16 A. Yes.
17 Q. Do you recall Virginia -- at the time
18 Virginia Roberts being present with you?
19 A. Yes.
20 Q. Do you recall if she went into the casino?
21 A. She was underage. I did not know anything
22 about how old you had to be to gamble legally. I
23 just knew she could not get in because of an ID
24 issue. So she and I did not gamble.
25 Q. In your opinion, did Virginia look young,
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1 in your view?
2 A. Yes.
3 Q. Did you ever -- did you at that time
4 wonder why she was traveling with Jeffrey?
5 A. At that time, I did not.
6 Q. Did you later wonder that?
7 A. Yes.
8 Q. And what was your impression?
9 MS. MENNINGER: Objection, vague,
10 speculative.
11 THE WITNESS: I -- we're jumping ahead; is
12 that okay?
13 BY MS. McCAWLEY:
14 Q. Yes, that's okay.
15 A. A few days later, I remember asking her
16 questions to try to figure out her role, why she was
17 there, and she gave me vague answers and was never
18 specific.
19 And so I thought perhaps she just was an
20 assistant, someone that did massages well. I wanted
21 to believe that she was innocent.
22 Q. Did you ever refer to her as being
23 orphan-like?
24 A. I did.
25 Q. And how did that come about?
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1 A. No, I only -- to you, I said that to you.
2 I just saw her as perhaps someone who may not have
3 had a strong family, and they took her under their
4 wing.
5 Q. Now, you mentioned remembering going to
6 Atlantic City.
7 Did you go -- where did you go after
8 Atlantic City?
9 A. Once we landed in New York, Emmy and I
10 went in a car and drove around the city for a half
11 hour or so, just to see some of the city.
12 Q. And then where did you go after doing the
13 sightseeing?
14 A. We went to the townhouse on East 71st.
15 Q. And can you describe that location for me?
16 A. Sure. Between Madison and Park. I think
17 the address might have been 9 East 71st Street.
18 Q. And who owned that home?
19 A. As far as I knew, Epstein.
20 Q. Can you describe for me physically what --
21 A. Palatial. When you walk up, it looks like
22 a normal door to a townhouse, and when you walk
23 in -- I thought there were four floors. I heard
24 there were seven floors. I didn't see them all.
25 Q. And do you recall who, if anybody, was at
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1 Jeffrey's home when you arrived?
2 A. Yes. When I first walked in the door, it
3 was just myself, and Ghislaine headed for the
4 staircase and said -- told me to come up to the
5 living room.
6 Q. And what happened at that point, when you
7 came up to the living room?
8 A. I came up and saw Virginia, Jeffrey,
9 Prince Andrew, Ghislaine in the room.
10 Q. And did you meet Prince Andrew at that
11 time?
12 A. Yes.
13 Q. And what happened next?
14 A. At one point, Ghislaine told me to come
15 upstairs, and we went into a closet and pulled out
16 the puppet, the caricature of Prince Andrew, and
17 brought it down. And there was a little tag on the
18 puppet that said "Prince Andrew" on it, and that's
19 when I knew who he was.
20 Q. And did -- what did the puppet look like?
21 A. It looked like him. And she brought it
22 down and presented it to him; and that was a great
23 joke, because apparently it was a production from a
24 show on BBC. And they decided to take a picture
25 with it, in which Virginia and Andrew sat on a
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1 couch. They put the puppet on Virginia's lap, and I
2 sat on Andrew's lap, and they put the puppet's hand
3 on Virginia's breast, and Andrew put his hand on my
4 breast, and they took a photo.
5 Q. Do you remember who took the photo?
6 A. I don't recall.
7 Q. Did you ever see the photo after it was
8 taken?
9 A. I did not.
10 Q. And Ms. Maxwell was present during the --
11 was Ms. Maxwell present during that?
12 A. Yes.
13 Q. What happened next?
14 A. The next thing I remember is just being
15 shown to which room I was going to be staying in.
16 Q. When you exited the room that you were in
17 where the picture was taken, do you recall who
18 remained in that room?
19 A. I don't.
20 Q. Do you recall seeing Virginia exit that
21 room?
22 A. I don't.
23 Q. During this trip to New York, did you have
24 to perform any work when you were at the New York
25 house?
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1 A. I performed at least one massage that I
2 recall.
3 Q. And who instructed you to give that
4 massage?
5 A. Jeffrey.
6 Q. And can you describe for me what happened
7 during that massage?
8 A. Near the end, he asked me to rub his
9 nipples while he masturbated.
10 Q. And did that take place?
11 A. It did not.
12 Q. And why not?
13 A. I was not comfortable with it. And so I
14 left the room.
15 Q. Did you have any -- did you say anything
16 to him before leaving the room?
17 A. I believe I said, "I'm done."
18 Q. Do you recall what his reaction was to
19 that?
20 A. I do not. At the time, at that moment, I
21 do not.
22 Q. Did you recall later what --
23 A. Well, we had a conversation a little
24 later, talking about his expectations, and that was
25 the conversation where he said that the next trip
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1 they were going on was to the island in the Virgin
2 Islands, and I would be invited; however, there
3 would be, quote, sex stuff happening.
4 Q. Can you describe for me -- can you
5 describe for me what that -- in New York, where you
6 massaged and what that looked like?
7 A. He had one room that was the massage room.
8 It was about the size of a spa room in a spa. It
9 had high ceilings. It had dark tapestry on the
10 walls. It was a very dark room. There was a very
11 large picture of a naked woman whom I don't recall.
12 That's all I remember.
13 Q. In the New York home, did you observe
14 photos around the house?
15 A. I don't recall.
16 Q. In the Palm Beach home that we were
17 talking about earlier, did you recall seeing photos
18 in that?
19 A. Yes.
20 Q. And did you recall seeing photos of naked
21 females in that home?
22 A. Yes.
23 Q. Approximately -- can you tell me where you
24 would see those in the home?
25 A. I definitely saw them in his bathroom.
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1 And I can't recall if they were in the main living
2 areas.
3 Q. Did you see them in the stairwell up to
4 the second story of the house?
5 A. I can't recall.
6 Q. Do you know who -- who the people were in
7 those photos? Were you familiar with any of them?
8 A. No.
9 Q. Were you in any of those photos?
10 A. At one point, yes.
11 Q. And were you naked in that photo?
12 A. Topless.
13 Q. Do you recall seeing any naked photos of
14 Virginia Roberts?
15 A. I do not.
16 Q. Where did you go next, after the New York
17 visit?
18 A. I went to the Virgin Islands.
19 Q. And who told you that you would be going
20 to the Virgin Islands?
21 A. He asked me if I wanted to go, and I said
22 I would still like to go.
23 Q. And do you recall who you -- who went with
24 you to the Virgin Islands?
25 A. I believe -- well, I know Virginia was
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1 with me. Ghislaine was there. Jeffrey. And there
2 were two other women that I don't recall their
3 names.
4 Q. Did you travel on Jeffrey's plane to get
5 to the Virgin Islands?
6 A. Yes.
7 Q. I want to show you again the flight log
8 that you have there in front of you. If you can
9 flip to --
10 MS. MENNINGER: I'm going to object to the
11 foundation again.
12 BY MS. McCAWLEY:
13 Q. It's that same page that you were on. The
14 date is the 11th.
15 A. Yes.
16 Q. Do you see the TEB to TIST there?
17 A. Yes.
18 MS. MENNINGER: Objection, leading. The
19 questioning is testifying now.
20 MS. McCAWLEY: Can you let me finish my
21 question, please?
22 BY MS. McCAWLEY:
23 Q. Can you tell me who the initials are there
24 that you see that were on the plane?
25 MS. MENNINGER: Objection, foundation,
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1 leading.
2 THE WITNESS: Jeffrey Epstein; Ghislaine
3 Maxwell; AP and PK are the two women I do not
4 recall; Virginia Roberts; and myself.
5 BY MS. McCAWLEY:
6 Q. Do you recall how you flew back from the
7 location in the US Virgin Islands?
8 A. They put me on a commercial flight. I
9 wanted to be home in time for Easter.
10 Q. When you say "they," do you recall who
11 made those arrangements for you?
12 A. It could have been Ghislaine.
13 Q. Did you -- do you recall performing
14 massages while you were in the US Virgin Islands?
15 A. Yes.
16 Q. Who was involved in -- was there more than
17 one?
18 A. Yes. I massaged Ghislaine at one point.
19 And I massaged Jeffrey, Virginia and I, both, on the
20 beach.
21 Q. Were you dressed during the massage that
22 was on the beach?
23 A. Yes. Bikinis probably, most likely.
24 Q. Do you recall what Virginia was wearing?
25 A. I believe she was wearing a bathing suit,
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1 as well.
2 Q. Were you paid for the massage on the beach
3 with Virginia?
4 A. At the end of -- before I left and flew
5 home, Ghislaine gave me $1,000.
6 Q. You mentioned that you massaged -- you
7 recall massaging Ghislaine on the trip to the USVI.
8 Do you recall when that took place?
9 A. I don't even recall what days we were
10 there, so...
11 Q. Do you recall where it took place?
12 A. I believe it was -- well, either in my
13 guest cottage or one of them. There were three
14 guest houses set up that were all similar and that I
15 was staying in. Virginia and I stayed in one
16 together. And it was either in there or in another
17 one that was identical.
18 Q. And was that massage performed with
19 Virginia as well or by you alone?
20 A. I don't recall.
21 Q. Were there other females in the USVI on
22 that trip with you besides Virginia?
23 A. Two others.
24 Q. And do you recall who they were?
25 A. I do not.
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1 Q. Did you ever see Ghislaine Maxwell during
2 that trip laying out by the pool?
3 A. There was one time where we were all by
4 the pool, yes.
5 Q. Was Ghislaine Maxwell ever nude or topless
6 by the pool?
7 A. I don't recall. She was nude when she
8 went swimming in the ocean.
9 Q. At that moment in the USVI home, did you
10 observe any photos there of nude females?
11 A. I don't recall.
12 Q. Besides Virginia, who you mentioned, you
13 observed to be young, did you observe any other
14 females that in your view appeared to be essentially
15 under the age of 18?
16 A. No.
17 Q. Did you observe any females who you
18 thought looked young, younger than you?
19 A. No.
20 Q. Do you remember an individual by the name
21 of that you met during your time with Jeffrey
22 Epstein?
23 A. In Palm Beach?
24 Q. Yes.
25 A. Yes.
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1 Q. Did you observe her to be young when you
2 met her?
3 MS. MENNINGER: Objection, vague as to
4 time.
5 THE WITNESS: All of the women were
6 generally young. I did not know the ages of
7 really anyone, so...
8 BY MS. McCAWLEY:
9 Q. How many massages did Jeffrey receive on
10 average in a given day?
11 MS. MENNINGER: Objection, foundation.
12 THE WITNESS: Three a day.
13 BY MS. McCAWLEY:
14 Q. Let me back up for a moment.
15 How long did you work for Jeffrey and
16 Ghislaine?
17 MS. MENNINGER: Objection, leading and
18 foundation.
19 THE WITNESS: I believe it was five years,
20 2001 to 2006.
21 BY MS. McCAWLEY:
22 Q. And how many massages did Epstein receive
23 per day on average?
24 MS. MENNINGER: Objection, foundation.
25 THE WITNESS: Three.
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1 BY MS. McCAWLEY:
2 Q. Were the massages performed by the same
3 girl or different females?
4 A. Different.
5 MS. MENNINGER: Objection, foundation.
6 BY MS. McCAWLEY:
7 Q. What did the females who performed the
8 massages look like?
9 MS. MENNINGER: Objection, foundation.
10 THE WITNESS: They all looked different.
11 Some of them were ethnic, some were blond, some
12 were short, some were tall. Everyone was thin.
13 BY MS. McCAWLEY:
14 Q. Were the girls who performed the massages
15 young or old?
16 MS. MENNINGER: Objection, foundation.
17 THE WITNESS: I don't recall anyone being
18 old.
19 BY MS. McCAWLEY:
20 Q. Do you recall anybody being over the age
21 of, say, 25?
22 MS. MENNINGER: Objection, form.
23 THE WITNESS: Yeah, I believe there was
24 probably a few women that were older than 25.
25 MS. MENNINGER: I'm sorry. I get a chance
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1 to object and then you can still answer. No
2 one is going to stop you from answering. I
3 just need to get the objection on the record,
4 in the same way she needs to be able to talk
5 before you. My apologies. I'm not trying to
6 cut you off, but I am supposed to get it in
7 before you answer.
8 BY MS. McCAWLEY:
9 Q. Did Jeffrey ever tell you why he received
10 so many massages from so many different girls?
11 MS. MENNINGER: Objection, hearsay.
12 BY MS. McCAWLEY:
13 Q. You can answer.
14 A. He explained to me that, in his opinion,
15 he needed to have three orgasms a day. It was
16 biological, like eating.
17 Q. And what was your reaction to that
18 statement?
19 A. I thought it was a little crazy.
20 Q. And what did -- do you recall what -- when
21 you observed the other females giving massages, do
22 you recall what they would dress like? Did they
23 wear scrubs or did they typically wear normal
24 clothes?
25 A. Normal clothes.
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1 MS. MENNINGER: Objection, leading.
2 BY MS. McCAWLEY:
3 Q. Do you believe that from your
4 observations, Maxwell and Epstein were boyfriend and
5 girlfriend?
6 A. Initially, yes.
7 Q. Did Maxwell ever share with you whether it
8 bothered her that Jeffrey had so many girls around?
9 MS. MENNINGER: Objection, leading,
10 hearsay.
11 THE WITNESS: No. Actually, the opposite.
12 BY MS. McCAWLEY:
13 Q. What did she say?
14 A. She let me know that she was -- she would
15 not be able to please him as much as he needed and
16 that is why there were other girls around.
17 Q. Did there ever come a time -- did you ever
18 take a photography class in school?
19 A. Yes.
20 Q. And did there ever come a time when
21 Maxwell offered to buy you a camera?
22 A. Yes.
23 MS. MENNINGER: Objection, leading.
24 BY MS. McCAWLEY:
25 Q. Did Maxwell ever offer to buy you a
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1 camera?
2 MS. MENNINGER: Objection, leading.
3 THE WITNESS: Yes.
4 BY MS. McCAWLEY:
5 Q. Was there anything you were supposed to do
6 in order to get the camera?
7 MS. MENNINGER: Objection, leading.
8 THE WITNESS: I did not know that there
9 were expectations of me to get the camera until
10 after. She had purchased the camera for me,
11 and I was over there giving Jeffrey a massage.
12 I did not know that she was in possession of
13 the camera until later.
14 She told me -- called me after I had left
15 and said, I have the camera for you, but you
16 cannot receive it yet because you came here and
17 didn't finish your job and I had to finish it
18 for you.
19 BY MS. McCAWLEY:
20 Q. And did you -- what did you understand her
21 to mean?
22 A. She was implying that I did not get
23 Jeffrey off, and so she had to do it.
24 Q. And when you say "get Jeffrey off," do you
25 mean bring him to orgasm?
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1 A. Yes.
2 Q. Did Ghislaine ever describe to you what
3 types of girls Jeffrey liked?
4 A. Model types.
5 Q. Did Ghislaine ever talk to you about how
6 you should act around Jeffrey?
7 A. She just had a conversation with me that I
8 should always act grateful.
9 Q. Did Jeffrey ever tell you that he took a
10 girl's virginity?
11 A. He did not tell me. He told a friend of
12 mine.
13 Q. And what do you recall about that?
14 MS. MENNINGER: Objection, hearsay,
15 foundation.
16 THE WITNESS: He wanted to have a friend
17 of mine come out who was cardio-kickboxer
18 instructor. She was a physical trainer.
19 And so I brought her over to the house,
20 and he told my friend Rachel that -- he said,
21 You see that girl over there laying by the
22 pool? She was 19. And he said, I just took
23 her virginity. And my friend Rachel was
24 mortified.
25
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1 BY MS. McCAWLEY:
2 Q. Based on what you knew, did Maxwell know
3 that the type of massages Jeffrey was getting
4 typically involved sexual acts?
5 MS. MENNINGER: Objection, foundation,
6 leading.
7 THE WITNESS: Yes.
8 BY MS. McCAWLEY:
9 Q. What was Maxwell's main job with respect
10 to Jeffrey?
11 MS. MENNINGER: Objection, foundation.
12 THE WITNESS: Well, beyond companionship,
13 her job, as it related to me, was to find other
14 girls that would perform massages for him and
15 herself.
16 BY MS. McCAWLEY:
17 Q. Did Maxwell ever refer to the girls in a
18 particular way?
19 A. At one point when we were in the islands,
20 we were all watching a movie and she called us her
21 children.
22 Q. Did anybody respond to that?
23 A. I don't recall.
24 Q. Did she ever refer to herself as a mother?
25 A. Yes, like a mother hen.
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1 Q. Do you recall who was present at the time
2 that she made that comment about children?
3 A. This was the second trip that I took to
4 the Virgin Islands, so, no. I don't want to speak,
5 you know, incorrectly. I can't remember. I can't
6 really remember.
7 Q. Have you ever met David Copperfield?
8 A. Yes.
9 Q. And do you recall when you initially met
10 him?
11 A. Yes.
12 Q. Can you tell me what that was?
13 A. Sure. Someone called me from the house
14 and said that he would be there, and if I wanted to
15 come have dinner, then I could meet him.
16 So when I arrived at the house, he wasn't
17 there yet, but I wa