gov.uscourts.nysd.447706.1325.12.pdf

Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 1 of 15 EXHIBIT 10 (File Under Seal) Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 2 of 15 GIUFFRE vs. MAXWELL Deposition STEVEN W OLSON 05/26/2016 Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017 Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 3 of 15 Agren Blando Court Reporting & Video, Inc. IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS CONFIDENTIAL DEPOSITION OF DR. STEVEN W. OLSON May 26, 2016 VIRGINIA L. GIUFFRE, Plaintiff, V. GHISLAINE MAXWELL, Defendant. APPEARANCES: S.J. QUINNEY COLLEGE OF LAW, UNIVERSITY OF UTAH By Paul G. Cassell, Esq. 383 S. University Street Salt Lake City, UT 84112 Phone: 801.585.5202 [email protected] Appearing on behalf of the Plaintiff HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 [email protected] Appearing on behalf of the Defendant STEVEN W OLSON 5/26/2016 1  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 4 of 15 Agren Blando Court Reporting & Video, Inc. 1 Pursuant to Subpoena, Notice and the 2 Federal Rules of Civil Procedure, the DEPOSITION OF 3 DR. STEVEN W. OLSON, called by Defendant, was taken 4 on Thursday, May 26, 2016, commencing at 8:54 a.m., 5 at 150 East 10th Avenue, Denver, Colorado, before 6 Kelly A. Mackereth, Certified Shorthand Reporter, 7 Registered Professional Reporter, Certified Realtime B Reporter and Notary Public within Colorado. 9 * * * * * * * 10 I N D E X 11 EXAMINATION PAGE 12 MS. MENNINGER 4 13 MR. CASSELL 109 MS. MENNINGER 127 14 MR. CASSELL 136 15 PRODUCTION REQUEST(S) 16 44 17 18 19 20 21 22 23 24 25 STEVEN W OLSON 5/26/2016 2  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 5 of 15 Agren Blando Court Reporting & Video, Inc. 1 INDEX OF EXHIBITS 2 INITIAL 3 DESCRIPTION REFERENCE 4 Exhibit 1 Authorization for the Release 7 5 and Disclosure of Protected Health Information and Medical 6 Records 7 Exhibit 2 Subpoena to Produce Documents, 7 Information, or Objects or to 8 Permit Inspection of Premises in a Civil Action 9 Exhibit 3 Subpoena to Testify at a 8 10 Deposition in a Civil Action 11 Exhibit 4 Document titled Centura Health 40 Physician Group Patient 12 Information 13 Exhibit 5 Visit note for Dr. Olson 43 14 Exhibit 6 Document titled Patient Health 100 Summary, The Entrance Medical 15 Centre 16 Exhibit 7 Document titled Patient Health 105 Summary from Central Coast 17 Family Medicine 18 19 20 21 22 23 24 25 STEVEN W OLSON 5/26/2016 3  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 6 of 15 Agren Blando Court Reporting & Video, Inc. 1 Q All right. Do you know how you came to be 2 the doctor for Virginia Giuffre? 3 A No. I -- she would have filled out a new 4 patient packet and showed up for a new patient 5 appointment for a particular reason. I reviewed it. 6 7 Jane Doe 2 8 Q Do you know where that new patient packet 9 is now? 10 A It's going to be scanned in the computer. 11 If you don't have it, I brought my computer. I can 12 probably scan it and print it out or just print it 13 out. 14 Q Is that among the documents that you have 15 next to you? 16 A The new patient packet isn't here, but I 17 have it I should have it on my computer. I could 18 probably log in and print it, to be honest. It 19 wouldn't be that hard. I assumed that the hospital 20 is taking care of all the documentation that was 21 requested. So I didn't actually bring it. 22 Q I understand. 23 A I actually have it, happen to have it with 24 me. 25 Q All right. Why don't we -- we can STEVEN W OLSON 5/26/2016 36  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 7 of 15 Agren Blando Court Reporting & Video, Inc. 1 probably do that when we take a break in just a few 2 minutes, and I can tell you how to get on the 3 Internet and we'll see if that works. 4 A Um-hum. 5 Q Do you know how many times that you saw 6 Virginia Giuffre? 7 A Once. 8 Q Do you know whether she was referred to 9 you by another doctor? 10 A No. 11 Q Do you mean no, you don't know or 12 A I have no idea. I have no idea. I don't 13 know why she would have been referred. Most the time 14 people are referring out. 15 Q Right. 16 A They don't refer back to a general 17 practitioner. 18 Q No one ever refers anyone to you? 19 A It generally goes the other direction. 20 Well, other patients might refer people to me, and 21 that happens, but 22 Q Okay. Do you know if you treat 23 Ms. Giuffre's children in your practice? 24 A Not that I'm aware of. 25 Q Do you know a woman by the name of Lynn STEVEN W OLSON 5/26/2016 37  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 8 of 15 Agren Blando Court Reporting & Video, Inc. 1 Miller? 2 A I know several Millers. 3 Q Who works at Saint Thomas More Hospital? 4 A I think so, yeah. That sounds familiar, 5 yeah. 6 Q Do you know her professionally? 7 A Not really. 8 Q Okay. 9 A I mean, her name sounds familiar. Q Do you know of any connection between Lynn 11 Miller and Virginia Giuffre? 12 A None. I have met Virginia once. I only 13 saw her once, a year ago. That's the extent of my -- 14 Q Have you ever read any media reports about 15 Ms. Giuffre? 16 A No. No, I haven't. I don't know anything 17 about it. 18 Q Okay. Do you know how long -- 19 A She -- I believe she mentioned that it was 20 some kind of -- mentioned something about being a 21 famous sexual abuse something. 22 Q You haven't read any of the reports? 23 A I have no idea. 24 Q Okay. I'm just trying to establish your 25 sources information. STEVEN W OLSON 5/26/2016 38  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 9 of 15 Agren Blando Court Reporting & Video, Inc. 1 A Yeah. 2 Q So if you had information about 3 Ms. Giuffre, other than your visit -- 4 A Yeah. 5 Q -- do you know another source? 6 A No. 7 Q From family members? 8 A No. 9 Q From community members, anything? 10 A Nothing. 11 Q Do you know how long your visit with her 12 lasted? 13 A It -- sometimes I document time spent, but 14 not always. I mean, it's not important. They're 15 half-hour visits typically. It would have been a 16 half hour or less, I would expect. 17 Q All right. Before looking at your 18 records, is there anything about Ms. Giuffre that you 19 recall just from the top of your head? 20 I understand you see many, many patients 21 and this was a year ago. So you tell me. 22 A Nothing. I saw her once. And when I went 23 back and read the note, I went, Oh, yeah, I remember 24 someone mentioning about being in a sexual abuse 25 trial or something, some kind of sexual abuse thing. STEVEN W OLSON 5/26/2016 39  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 10 of 15 Agren Blando Court Reporting & Video, Inc. 1 Q That's the only unusual part that stuck 2 out? 3 A Yeah, and I don't really remember anything 4 about her at all, actually, I don't. 5 Q Do you know what she looks like? 6 A No, I don't remember. It was one time a 7 year ago. I don't remember. 8 Q I understand. Okay. If it's okay with 9 you, I would like to take a break and see if we can 10 pull up the other records because I don't want to go 11 through my questions and then go back and look at 12 those records. I'd rather do it one time. 13 A Okay. 14 Q Is that all right? 15 A Yeah, I'm fine with that. 16 MS. MENNINGER: All right. Let's go off 17 the record. 18 (Recess taken from 9:41 a.m. to 19 10:07 a.m.) 20 (Exhibit 4 marked.) 21 Q (BY MS. MENNINGER) So we're back on the 22 record. All right. 23 I'm going to give you a document marked as 24 Exhibit 4 . And I'm going to make a small record 25 about what just took place off the record, which is STEVEN W OLSON 5/26/2016 40  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 11 of 15 Agren Blando Court Reporting & Video, Inc. 1 that you, as I understand it, and tell me if I'm 2 wrong, have access to medical records from your 3 office on your laptop, correct? 4 A Yes. 5 Q Okay. And you were able to get on your 6 laptop and print out records related to Ms. Giuffre 7 that you had on that laptop, correct? 8 A Yes. 9 Q And we printed that out and made copies 10 for everyone here, and that's what you see in front 11 of you as Exhibit 4, correct? 12 A Yes. 13 Q We made those printouts on a portable 14 printer. So they're not the best quality, correct? 15 A Correct. 16 Q And some portions are not printing out as 17 well? 18 A Yes. 19 Q And you, I think, would be okay with 20 sending us a more complete set later? 21 A Yes. 22 Q All right. I'm going to take just a 23 minute to review it. 24 Can you tell us what the records that you 25 just printed out in Exhibit 4 represent? STEVEN W OLSON 5/26/2016 41  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 12 of 15 Agren Blando Court Reporting & Video, Inc. 1 A Generally it's demographics information 2 and then a list of medications, a list of surgeries, 3 a list of family medical history, and then a list of 4 physical complaints that there's some -- it's called 5 review of systems, things someone has been feeling 6 and self-reported in the last two weeks. 7 Q Okay. So is this typically is this 8 patient information document typically in the 9 patient's handwriting? 10 A Yes. 11 Q And I presume you don't know Ms. Giuffre's 12 handwriting? 13 A No. 14 Q But it's a practice to ask the patient to 15 fill these forms out? 16 A Yes, and then have it there before their 17 appointment. 18 Q All right. So if I see the date reflected 19 on the top of the first page as May 21st, 2015 -- 20 A Um-hum. 21 Q -- do you believe that to be the date that 22 you actually saw Ms. Giuffre? 23 A Probably, yes. 24 Q Okay. 25 A Sometimes people will bring it in early, STEVEN W OLSON 5/26/2016 42  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 13 of 15 Agren Blando Court Reporting & Video, Inc. 1 but yeah. 2 Q Okay. Why don't we go ahead and mark 3 Exhibit 5, which will be helpful as we're going 4 through this. 5 (Exhibit 5 marked.) 6 Q (BY MS. MENNINGER) And I'm going to ask 7 you to keep 4 and 5 kind of close by, and we'll talk 8 about them. 9 Do you recognize Exhibit 5? 10 A Yes. That's the visit note. 11 Q And the visit note of Ms. Giuffre's visit 12 with you? 13 A Yes. Q In your office? 15 A Yes. Q And after looking at Exhibit 5, can you 17 tell what date it is that you actually saw 18 Ms. Giuffre? 19 A 5/21/2015. 20 Q Okay. Is that also the same date as the 21 patient intake form 22 A Yes. 23 Q -- in Exhibit 4? 24 A Yes. 25 Q All right. Do you recall whether you STEVEN W OLSON 5/26/2016 43  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 14 of 15 Agren Blando Court Reporting & Video, Inc. 1 STATE OF COLORADO) 2 ss. REPORTER'S CERTIFICATE 3 COUNTY OF DENVER 4 I, Kelly A. Mackereth, do hereby certify 5 that I am a Registered Professional Reporter and 6 Notary Public within the State of Colorado; that 7 previous to the commencement of the examination, the 8 deponent was duly sworn to testify to the truth. 9 I further certify that this deposition was 10 taken in shorthand by me at the time and place herein 11 set forth, that it was thereafter reduced to 12 typewritten form, and that the foregoing constitutes 13 a true and correct transcript. 14 I further certify that I am not related to, 15 employed by, nor of counsel for any of the parties or 16 attorneys herein, nor otherwise interested in the 17 result of the within action. 18 In witness whereof, I have affixed my 19 signature this 31st day of May, 2016. 20 My commission expires April 21, 2019. 21 22 Kelly A. Mackereth, CRR, RPR, CSR 23 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 STEVEN W OLSON 5/26/2016 140  Case 1:15-cv-07433-LAP Document 1325-12 Filed 01/04/24 Page 15 of 15 Agren Blando Court Reporting & Video, Inc. 1 AGREN BLANDO COURT REPORTING & VIDEO, INC. 216 - 16th Street, Suite 600 2 Denver, Colorado 80202 4450 Arapahoe Avenue, Suite 100 3 Boulder, Colorado 80303 4 5 6 DR. STEVEN W. OLSON May 26, 2016 7 Giuffre v. Maxwell Case No. 15-cv-07433-RWS 8 9 The original deposition was filed with 10 Laura Menninger, Esq., on approximately the 11 31st day of May, 2016. 12 XXX Signature waived. 13 Unsigned; signed signature page and 14 amendment sheets, if any, to be filed at trial. 15 Reading and signing not requested pursuant 16 to C.R.C.P. Rule 30(e). 17 Unsigned; amendment sheets and/or signature pages should be forwarded to Agren Blando to 18 be filed in the envelope attached to the sealed original. 19 20 21 Thank you. 22 AGREN BLANDO COURT REPORTING & VIDEO, INC. 23 cc: All Counsel 24 25 STEVEN W OLSON 5/26/2016 141