gov.uscourts.nysd.447706.1295.13.pdf

EXHIBIT A  Highly Confidential Page 1 HIGHLY CONFIDENTIAL AEO UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -----------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. Case No: 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. -----------------------------x HIGHLY CONFIDENTIAL DEPOSITION OF SARAH RANSOME NEW YORK, NEW YORK Friday, February 17, 2017 Reported by: JEREMY RICHMAN JOB NO: 300491 MAGNA LEGAL SERVICES 320 West 37th Street, 12th Floor New York, New York 10018 (866) 624-6221  Highly Confidential Page 2 1 HIGHLY CONFIDENTIAL AEO 2 3 4 February 17, 2017 5 9:00 a.m. 6 7 DEPOSITION of SARAH RANSOME, held 8 at the offices of Boies, Schiller & Flexner, 9 575 Lexington Avenue, New York, New York, 10 before JEREMY RICHMAN, a Shorthand Reporter and 11 Notary Public of the State of New York. 12 13 14 15 16 17 18 19 20 21 22 23 24 25  Highly Confidential Page 3 1 HIGHLY CONFIDENTIAL AEO 2 APPEARANCES: 3 4 BOIES, SCHILLER & FLEXNER, LLP 5 Attorneys for plaintiff 6 401 East Las Olas Boulevard, Suite 1200 7 Fort Lauderdale, FL 33301-2211 8 BY: SIGRID STONE MCCAWLEY, ESQ. 9 ([email protected]) 10 11 12 HADDON, MORGAN AND FOREMAN, P.C 13 Attorneys for Defendant 14 150 East 10th Avenue 15 Denver, CO 80230 16 BY: LAURA A. MENNINGER, ESQ. 17 JEFFREY S. PAGLIUCA, ESQ. 18 ([email protected]) 19 ([email protected]) 20 21 22 23 24 25  Highly Confidential Page 4 1 HIGHLY CONFIDENTIAL AEO 2 APPEARANCES (Continued): 3 4 J. STANLEY POTTINGER, PLLC 5 Attorneys for the witness 6 49 Twin Lakes Road, Suite 100 7 South Salem, NY 10590 8 BY: J. STANLEY POTTINGER, ESQ. 9 ([email protected]) 10 11 12 MINTZ & GOLD, LLP 13 Attorneys for the witness 14 600 Third Avenue 15 New York, NY 10016 16 BY: PETER GUIRGUIS, ESQ. 17 ([email protected]) 18 19 20 ALSO PRESENT: 21 GHISLAINE MAXWELL, via teleconference 22 23 24 25  Highly Confidential Page 9 1 HIGHLY CONFIDENTIAL AEO 2 just ask a question? I would 3 like to just clarify. When you 4 say objection, does that mean I 5 actually have to answer the 6 question? Because that's 7 irrelevant. 8 MR. GUIRGUIS: Right. 9 Unless I'm telling you not to 10 answer, you need to answer. 11 THE WITNESS: So I don't 12 need to answer? 13 MR. GUIRGUIS: No, you do 14 need to answer this. 15 A. Okay. We've been together 16 almost a year. 17 Q. And what is your current 18 occupation? 19 A. I'm a writer. 20 Q. And what do you write? 21 A. Just stuff, you know? Just 22 about factual stuff. You know, just a 23 bit of this, bit of that. 24 Q. Have you been paid for any 25 of your writing?  Highly Confidential Page 10 1 HIGHLY CONFIDENTIAL AEO 2 A. No. It's more of a hobby, 3 really. 4 Q. Are you employed? 5 A. Nope. 6 Q. Do you have any source of 7 income? 8 A. My partner -- 9 MR. GUIRGUIS: I'm going to 10 object to that. Income is out. 11 You don't have to answer 12 that. 13 Q. Do you have any source of 14 income? 15 MR. GUIRGUIS: I just 16 objected to that. You don't have 17 to answer. 18 MS. MENNINGER: Is there a 19 privilege you're asserting? 20 MR. GUIRGUIS: I'm not sure 21 what the relevance is, and I'm 22 not going to allow -- 23 MS. MENNINGER: Do you 24 believe that relevance is a 25 proper objection during a  Highly Confidential Page 11 1 HIGHLY CONFIDENTIAL AEO 2 deposition? 3 MR. GUIRGUIS: I believe 4 that if you go far afield with 5 this witness, that the judge is 6 not going to appreciate it, and 7 that I'm not going to just sit 8 here and be a potted plant and 9 allow her to answer any questions 10 on any subject that you see fit. 11 MS. MENNINGER: On 12 relevance? You're instructing 13 her not to answer on a relevance 14 objection? Is that what you're 15 saying? 16 MR. GUIRGUIS: I just 17 objected. 18 MS. MCCAWLEY: I'm going to 19 object on behalf of the 20 plaintiff, Virginia Giuffre, to 21 the extent that you're requesting 22 from a nonparty financial 23 information, which is not allowed 24 under New York law. 25 MS. MENNINGER: I have asked  Highly Confidential Page 12 1 HIGHLY CONFIDENTIAL AEO 2 her whether she has any source of 3 income, and you're going to 4 object -- 5 MS. MCCAWLEY: Yes. 6 MS. MENNINGER: -- and 7 instruct her not to answer as 8 well? 9 MS. MCCAWLEY: I'm not 10 instructing her not to answer. 11 I'm just making a record. 12 MR. GUIRGUIS: It's 13 financial information -- 14 MS. MENNINGER: And whether 15 she has a financial motive is 16 relevant. 17 Q. So I'm going to ask you a 18 last time: Do you have any source of 19 income? 20 MR. GUIRGUIS: I'm going to 21 instruct you again not to answer. 22 Q. Has any of your writing been 23 published by anyone? 24 A. No. 25 Q. Have you sought to have your  Highly Confidential Page 24 1 HIGHLY CONFIDENTIAL AEO 2 A. About 11 hours in total. 3 Q. When is the first time that 4 you met Mr. Guirguis? 5 MR. GUIRGUIS: Objection. 6 MS. MCCAWLEY: You can 7 answer. 8 MR. GUIRGUIS: You can 9 answer. 10 A. Yesterday. 11 Q. You met Mr. Guirguis 12 yesterday? Was that your answer? 13 A. Yes. 14 Q. And who is paying for 15 Mr. Guirguis's fees, if you know? 16 A. I have a pro-bono 17 arrangement. 18 Q. Do you know if he's 19 receiving money from anyone else in 20 exchange for representing you? 21 A. No. 22 Q. No, you don't know, or no, 23 he is not? 24 A. I don't know. 25 Q. How many hours have you  Highly Confidential Page 25 1 HIGHLY CONFIDENTIAL AEO 2 spent with Ms. McCawley? 3 A. Can I just clarify that 4 question? Does that mean on the 5 phone? Like what are you referring 6 to, in person or -- 7 Q. Either one. How many hours, 8 how much time have you spent with 9 Ms. McCawley in person? 10 A. I met with Ms. McCawley for 11 the first time in person yesterday, 12 but I've spent -- yeah, we've been -- 13 Ms. McCawley was the first person I 14 actually spoke to. 15 Q. And how many hours have you 16 spent with her on the phone? 17 A. Many, many hours. 18 Q. Approximately how many? 19 A. I don't know. 20 Q. Five? 21 MR. GUIRGUIS: Objection. 22 A. More than five. 23 Q. Ten? 24 MR. GUIRGUIS: Objection. 25 Q. Ten?  Highly Confidential Page 26 1 HIGHLY CONFIDENTIAL AEO 2 A. Well, 10, 15. She's been 3 with me the whole way since when I 4 came forward, so she's been a very 5 prominent person. 6 Q. And when did you first speak 7 with her on the phone? 8 A. I think it was -- 9 Q. Without telling me what you 10 said. 11 A. I think it was November. 12 Q. November what? 13 A. I can't remember the date. 14 Q. Early November? Late 15 November? 16 MR. GUIRGUIS: Objection. 17 A. I can't remember. 18 Q. Was she speaking to you on 19 your cell phone or a landline? 20 A. Cell phone. 21 Q. A mobile number or a 22 landline? 23 A. A cell phone. 24 Q. Okay. And what's that cell 25 phone number?  Highly Confidential Page 27 1 HIGHLY CONFIDENTIAL AEO 2 A. I don't have it anymore. 3 Q. That's okay. What's the 4 cell phone number? 5 A. I actually don't know. I 6 can't remember my cell phone number. 7 I don't have anything with me, so I 8 can't remember that number offhand. 9 Q. How long did you have that 10 cell phone? 11 A. About eight months. 12 Q. What happened to it? 13 A. I got rid of it. 14 Q. Why? 15 A. Because I fear for my life 16 because of Jeffrey Epstein and 17 Ghislaine Maxwell. 18 Q. What did you do with it? 19 A. I sold it. 20 Q. When? 21 A. November. 22 Q. Before or after you first 23 spoke with Ms. McCawley? 24 A. Before. 25 Q. So then how did you speak  Highly Confidential Page 28 1 HIGHLY CONFIDENTIAL AEO 2 with Ms. McCawley over the phone? 3 A. On my partner's cell phone. 4 Q. What's his cell phone 5 number? 6 MS. MCCAWLEY: Objection. 7 What's the relevance of her 8 partner's cell phone? 9 Again, this is irrelevant. 10 It's harassing. It's -- you're 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q. What is your partner's cell 19 phone number? 20 MR. GUIRGUIS: I'm directing 21 the witness not to answer. 22 Q. How many hours have you 23 spent speaking with Mr. Pottinger? 24 A. I've been speaking to 25 Mr. Pottinger from November.  Highly Confidential Page 36 1 HIGHLY CONFIDENTIAL AEO 2 any agreements regarding writing a 3 book -- 4 A. No. 5 Q. -- about your experience? 6 You have to wait for me to 7 finish my question. 8 Have you had any agreements 9 with your lawyers about media rights 10 in any form? 11 MR. GUIRGUIS: Objection to 12 the extent that you're asking 13 about communications with the 14 attorneys. 15 MS. MENNINGER: I'm asking 16 about her arrangement with her 17 attorneys, which is not 18 privileged. 19 A. Can you please repeat the 20 question. 21 Q. Have you reached any 22 agreement with your attorneys 23 regarding media rights for your story? 24 A. No. 25 Q. Have you talked to anyone  Highly Confidential Page 37 1 HIGHLY CONFIDENTIAL AEO 2 about publishing anything relating to 3 your story? 4 A. Can you repeat the question, 5 please. 6 MS. MENNINGER: Can you read 7 it back. 8 (Requested portion of the 9 record was read back.) 10 A. Yes, I have. 11 Q. Who have spoken to? 12 A. The New York Post. 13 Q. Who at the New York Post? 14 A. Maureen Callahan. 15 Q. And when did you speak with 16 her? 17 A. I think it was later 18 October. 19 Q. Have you spoken with her 20 since? 21 A. No. 22 Q. And how long did you speak 23 to her? 24 A. I spoke to her for, gosh, 25 about 30 minutes on the phone once.  Highly Confidential Page 38 1 HIGHLY CONFIDENTIAL AEO 2 Q. And what was -- what did you 3 tell her in your phone call? 4 A. I told her what Jeffrey 5 Epstein and Ghislaine Maxwell did to 6 me and the other girls. 7 Q. Did she give you any money 8 in exchange for that interview? 9 A. No. 10 Q. Did she publish anything 11 related to that interview? 12 A. No. 13 Q. How did you get in touch 14 with Ms. Callahan? 15 A. I emailed after I read an 16 article that she had written about 17 Jeffrey Epstein, and the last sentence 18 was -- it was on the 16th of October, 19 and one of the last sentences I 20 remember was, will we ever know the 21 true extent of Jeffrey Epstein's 22 victims. And I wrote her after that 23 because, well, it still continues, 24 doesn't it. 25 Q. Where is the email that you  Highly Confidential Page 39 1 HIGHLY CONFIDENTIAL AEO 2 wrote her? 3 A. It's on a -- it's on my 4 computer. 5 Q. Okay. In your Yahoo 6 account? 7 A. Yes. 8 Q. Did you have any agreement 9 with her to have any additional 10 conversation? 11 A. Yes. 12 Q. And what was that agreement? 13 A. It wasn't an agreement per 14 such. What actually happened was I 15 came forward. As soon as I came 16 forward, there was -- where I live in 17 Barcelona, there's quite a lot -- it's 18 quite busy traffic with people. 19 I came forward to Maureen 20 Callahan. I wanted to tell my story, 21 and I want to run a campaign in which 22 all the girls that have been abused by 23 Ghislaine and Jeffrey can come 24 forward. And I wanted to run a 25 campaign with the New York Post to get  Highly Confidential Page 40 1 HIGHLY CONFIDENTIAL AEO 2 these girls to have the courage to 3 come forward, because I know a lot of 4 them are frightened like myself. 5 The email correspondence I 6 had with Maureen Callahan, she was 7 going away or something and she was 8 going to write a piece in the New York 9 Post about my story. During that time 10 it was the elections, so there was a 11 lot more other things going on. 12 There were two people 13 following me after I came forward to 14 Maureen Callahan. I went to -- I 15 walked downstairs. I walked around -- 16 I have a usual routine that I do. In 17 the morning I went out, I saw the same 18 two people. Later on that afternoon, 19 I saw the same two people again. I 20 was frightened. I'm frightened for my 21 life, absolutely frightened. So there 22 you go. 23 So that's what I was -- 24 communication stopped between Maureen 25 Callahan and I. I got really angry  Highly Confidential Page 41 1 HIGHLY CONFIDENTIAL AEO 2 with Maureen because she had obviously 3 told someone. Being the New York 4 Post, so, you know. 5 Q. So you had an email to 6 Ms. Callahan and an email back from 7 her? 8 A. Yes. 9 Q. More than one? 10 A. Yes. 11 Q. How many? 12 A. I can't remember. 13 Q. More than ten or less than 14 ten? 15 A. Less than ten. 16 Q. And you had one phone call 17 with her or more than one? 18 A. Just one. 19 Q. And it lasted about 30 20 minutes? 21 A. About that. 22 Q. And was that also on the 23 cell phone that you got rid of? 24 A. That was on my partner's 25 cell phone.  Highly Confidential Page 42 1 HIGHLY CONFIDENTIAL AEO 2 Q. And what had you read in the 3 press that caused you to get in touch 4 with Ms. Callahan? 5 MS. MCCAWLEY: Objection to 6 form. Go ahead. 7 A. You can read the article 8 yourself. It's on the 16th of 9 October, there's an article in the New 10 York Post written by Maureen Callahan. 11 You can read it. And that's what 12 inspired me to come forward. 13 Q. What do you recall about 14 that article? 15 A. Oh, I can't remember. The 16 one thing I do remember is the last 17 sentence of the article, which has 18 stuck with me and quite prominent, and 19 that is, will we ever know the true 20 extent of Jeffrey Epstein's victims. 21 Q. Do you recall anything else 22 about the article? 23 A. It's just the same. When I 24 read the article, the stuff that I had 25 experienced myself with Jeffrey, it's  Highly Confidential Page 43 1 HIGHLY CONFIDENTIAL AEO 2 just same old stuff, just continuing. 3 I thought he had stopped abusing 4 girls. 5 Q. What do you recall reading a 6 article that Jeffrey Epstein was 7 doing? 8 A. I can't remember. 9 Q. Anything at all? 10 A. You can read the article. I 11 can't remember. 12 Q. The question is what you 13 remember. 14 A. I can't remember. 15 Q. You remember nothing else 16 about the article -- 17 MS. MCCAWLEY: Asked and 18 answered objection. 19 Q. -- except it was related to 20 Jeffrey Epstein and it ended with the 21 sentence that you've described? 22 MS. MCCAWLEY: Objection, 23 asked and answered. 24 A. Yes. 25 Q. What do you know about other  Highly Confidential Page 172 1 HIGHLY CONFIDENTIAL AEO 2 I had to regularly pop in to see him 3 and Ghislaine. And Ghislaine would 4 often check how I was doing and blah, 5 blah, blah, etcetera. 6 Q. What were you doing to 7 prepare for your college application? 8 A. I had to write an essay. 9 Q. When did you -- 10 A. Also, I had to do -- like, 11 you know how you apply for college 12 applications; you've got your 13 application forms and such. So it was 14 more admin. 15 Q. And you were going to 16 Jeffrey's office to work on your 17 forms? 18 A. Yes. And to just say hi. I 19 was -- well, I never went on my own 20 accord. I was either invited or told 21 to be there by either Ghislaine or 22 Jeffrey. I also went to the offices 23 on a number of occasions for private 24 legal matter. 25 Q. What's the private legal  Highly Confidential Page 173 1 HIGHLY CONFIDENTIAL AEO 2 matter? 3 MR. GUIRGUIS: Objection. 4 I'm going to direct you not to 5 answer if it's unrelated to this 6 case. 7 Q. Was there an attorney 8 present? 9 A. Yes. 10 Q. What was the name of the 11 attorney who was present? 12 A. Alan Dershowitz. 13 Q. So I was asking about the 14 second time you met Ghislaine. It was 15 at Jeffrey's office in New York? 16 A. Yes. 17 Q. How did you come to be in 18 Jeffrey's office in New York where you 19 met Ghislaine the second time? 20 A. I was told to be there. 21 Q. Who told you to be there? 22 A. I think it was Ghislaine. 23 Q. How did Ghislaine tell you 24 to be there? 25 A. I can't remember if it was  Highly Confidential Page 180 1 HIGHLY CONFIDENTIAL AEO 2 or the specific words used. 3 But it was surrounding my 4 FIT application and an essay I had to 5 write, and they both proofread my FIT 6 application as well. 7 Q. And did they both read your 8 essay? 9 A. Yes, they did. 10 Q. When did you write that 11 essay? 12 A. I can't remember. 13 Q. Before you went to South 14 Africa? 15 A. Yes. 16 Q. Do you know what the 17 application deadline was? 18 A. I don't know. I don't know. 19 I can't remember. 20 Q. When did you meet Alan 21 Dershowitz? 22 A. I don't remember the 23 specific date. It was a few months 24 after I had been here in New York. 25 Q. Was it after you had gone to  Highly Confidential Page 181 1 HIGHLY CONFIDENTIAL AEO 2 the island? 3 A. Yes. 4 Q. Do you know what time of 5 year? 6 A. I mean, I think it was 7 before winter. 8 Q. Well, you were here in the 9 fall. 10 A. Yeah. 11 Q. And you left in the winter? 12 A. Yeah. I left in May. 13 Q. So did you meet him before 14 you went to South Africa? 15 A. Yes. 16 Q. Well, let's be clear. You 17 were here until you went to South 18 Africa, and you left for a while and 19 then you came back, right? 20 A. Mm-hmm. 21 Q. How long were you gone? 22 A. I think about three -- about 23 three weeks. 24 Q. So you met him before you 25 went to South Africa?  Highly Confidential Page 182 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. And tell me about when you 4 met Alan. 5 A. I first met Alan at the 6 offices. 7 Q. And tell me what happened. 8 A. I can't really tell you what 9 happened, because it's about a legal 10 matter. 11 Q. Was he your lawyer? 12 A. He was going to be assigned 13 to be my lawyer. 14 Q. Assigned to be your lawyer? 15 A. Through Jeffrey's 16 instruction. 17 Q. Okay. Was he your lawyer? 18 MS. MCCAWLEY: Objection, 19 asked and answered. 20 MS. MENNINGER: I don't know 21 if there's a privilege. 22 MR. GUIRGUIS: There's a 23 privilege whether he was retained 24 or not, right? I mean, if you're 25 at a cocktail party and you speak  Highly Confidential Page 183 1 HIGHLY CONFIDENTIAL AEO 2 to a lawyer, you know that 3 conversation is privileged. 4 So... 5 MS. MENNINGER: Well, I 6 don't, actually. 7 MR. GUIRGUIS: You're free 8 to research it. 9 MS. MENNINGER: I will ask 10 questions, then, to try to 11 establish whether or not there's 12 a good-faith basis. 13 Q. Did you approach Alan 14 Dershowitz for the purpose of seeking 15 legal advice? 16 A. I was introduced to Alan. 17 Q. By whom? 18 A. Jeffrey Epstein. 19 Q. On what day? 20 A. I don't recall what day. 21 Q. Was it related to some event 22 that had occurred just before that? 23 A. Yes, that's correct. 24 Q. Were you in touch with any 25 law enforcement authorities?  Highly Confidential Page 184 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Hmm? 4 A. No. 5 Q. Was Jeffrey Epstein in the 6 room when you were speaking with Alan 7 Dershowitz? 8 A. Yes. 9 Q. Did Jeffrey Epstein overhear 10 your conversation with Alan 11 Dershowitz? 12 A. Yes. 13 Q. What did you talk about with 14 Alan Dershowitz? 15 MR. GUIRGUIS: Objection. 16 A. It -- 17 MR. GUIRGUIS: Objection. I 18 direct the witness not to answer. 19 MS. MENNINGER: A third 20 party was in the room; you've 21 heard that, Counsel. And you 22 know that means that's a waiver. 23 MS. MCCAWLEY: No. I mean, 24 they would have been involved -- 25 we don't know what the situation  Highly Confidential Page 185 1 HIGHLY CONFIDENTIAL AEO 2 is. They could have been 3 involved together. There could 4 be a number of reasons why 5 Jeffrey had some sort of common 6 interest with her with that. 7 Q. Did you sign a common 8 interest agreement with Jeffrey? 9 MR. GUIRGUIS: Objection. 10 Do not answer. 11 MS. MENNINGER: Whether she 12 had a common interest agreement 13 with Jeffrey, you're instructing 14 her not to answer; is that right, 15 Counsel? 16 MR. GUIRGUIS: Do you have 17 realtime in front of you, 18 Counsel? 19 MS. MENNINGER: I don't. 20 MR. GUIRGUIS: You don't? 21 You can borrow mine. 22 MS. MENNINGER: I don't want 23 it. Thank you. 24 MR. GUIRGUIS: Okay. 25 Q. Anyone else in the room when  Highly Confidential Page 199 1 HIGHLY CONFIDENTIAL AEO 2 BY MS. MENNINGER: 3 Q. Going back to your first 4 conversation with Alan Dershowitz, at 5 any point in that conversation, had 6 Mr. Dershowitz agreed to act as your 7 lawyer? 8 A. Yes. 9 Q. Did he do anything in terms 10 of contacting anyone on your behalf? 11 MR. GUIRGUIS: Objection. 12 Do not answer. 13 Q. What was the specific legal 14 matter that you were seeking 15 representation for? 16 MS. MCCAWLEY: Objection. 17 MR. GUIRGUIS: Objection. 18 Do not answer. 19 Q. What did you understand the 20 purpose of Jeffrey Epstein being in 21 the room for during that conversation? 22 A. Jeffrey was there to support 23 me and Jeffrey was looking afte