gov.uscourts.nysd.447706.1218.12.pdf

Exhibit G  1 1 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA 2 CASE NO. 15-000072 3 BRADLEY J. EDWARDS and PAUL G. 4 CASSELL, 5 Plaintiffs, 6 -vs- CONFIDENTIAL 7 ALAN M. DERSHOWITZ, 8 Defendant. ____________________________________/ 9 10 VIDEOTAPED DEPOSITION OF VIRGINIA ROBERTS GIUFFRE 11 12 Saturday, January 16, 2016 9:07 a.m. - 2:48 p.m. 13 14 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, Florida 33301 15 16 17 18 Reported By: 19 Deborah A. Harris, Court Reporter Notary Public, State of Florida 20 Phone - 305.651.0706 21 Job No. JO277789 22 23 24 25 CONFIDENTIAL  2 1 APPEARANCES: 2 On behalf of the Plaintiffs: Jack Scarola, Esquire 3 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 4 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 5 (561) 686-6300 6 On behalf of the Deponent: Sigrid McCawley, Esquire 7 BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, 8 Suite 1200 Fort Lauderdale, Florida 33301 9 (954) 356-0011 10 On behalf of the Defendant: Mary Borja, Esquire 11 WILEY REIN, LLP 1776 K Street NW 12 Washington, DC 20006 (202) 719-7000 13 On behalf of the Defendant: 14 Richard Simpson, Esquire WILEY REIN, LLP 15 1776 K Street NW Washington, DC 20006 16 (202) 719-7000 17 On behalf of the Defendant: Thomas E. Scott, Esquire 18 COLE, SCOTT & KISSANE, P.A. 9150 South Dadeland Boulevard, 19 14th Floor Miami, Florida 33156 20 (305) 350-5300 21 On behalf of the Defendant: Kenneth A. Sweder, Esquire 22 SWEDER & ROSS, LLP 131 Oliver Street. 23 Boston, Massachusetts 02110 (617) 646-4466 24 25 CONFIDENTIAL  3 1 ALSO PRESENT 2 Edward J. Pozzuoli, Special Master 3 Robert Pacheco, Videographer Ryan Kick, Videographer 4 Bradley J. Edwards Paul G. Cassell 5 Alan M. Dershowitz Brittany N. Henderson, Esq. 6 Meridith Schultz, Esquire 7 - - - 8 I N D E X 9 10 WITNESS DIRECT CROSS REDIRECT RECROSS 11 Virginia Roberts Giuffre By Ms. Borja 5 12 By Mr. Scarola 201 By Ms. Borja 204 13 - - - 14 E X H I B I T S 15 DEFENDANT VR EXHIBITS FOR ID 16 1 - Notice. 6 2 - Disclosure list. 26 17 3 - Order. 59 4 - E-mail. 92 18 5 - Photo (Confidential) 100 6 - Article. 124 19 7 - Daily Mail. 155 8 - Daily Mail. 168 20 9 - Declaration. 170 10- FBI doc. 187 21 REPORTER'S NOTE: Exhibit 5 marked confidential, sealed, 22 and retained by the Special Master. 23 24 25 CONFIDENTIAL  4 1 Deposition taken before Deborah A. Harris, 2 Florida Professional Court Reporter and Notary Public in 3 and for the State of Florida at Large, in the above 4 cause. 5 - - - 6 THE VIDEOGRAPHER: We are now on video 7 record. This is disk number one in the videotaped 8 deposition of Virginia Roberts in the matter of 9 Bradley J. Edwards and Paul G. Cassell, Plaintiff 10 versus Alan M. Dershowitz, Defendant. 11 The deposition is being held at the Law 12 Office of Boies, Schiller & Flexner located at 401 13 East Las Olas Boulevard, Suite 1200. Fort 14 Lauderdale, Florida 33301. Today's date is 15 January 16th, 2016. The time is 9:07 a.m. 16 My name is Robert Pacheco, I am the 17 videographer. The court reporter is Deborah 18 Harris, both from Esquire Deposition Solutions. 19 Would counsel please introduce yourselves and your 20 affiliation and the witness will be sworn in. 21 MS. MCCAWLEY: My name is Sigrid McCawley. 22 I'm with the Law Firm of Boies, Schiller & 23 Flexner. I'm here with my colleague, Meridith 24 Schultz and we represent non-party Virginia 25 Roberts Giuffre. CONFIDENTIAL  5 1 MR. SCAROLA: Jack Scarola, counsel on 2 behalf of Bradley Edwards and Paul Cassell. Mr. 3 Edwards and Mr. Cassell are also present. 4 MS. HENDERSON: Brittany Henderson also on 5 behalf of the Plaintiff. 6 MS. BORJA: Mary Borja for Defendant, Alan 7 Dershowitz. 8 MR. SCOTT: Thomas Scott for the Defendant. 9 MR. SIMPSON: Richard Simpson on behalf of 10 Professor Dershowitz. 11 MR. SWEDER: Ken Sweder of Sweder and Ross 12 on behalf of Professor Dershowitz. 13 SPECIAL MASTER: Ed Pozzuoli, Special 14 Master. 15 - - - 16 Thereupon, 17 VIRGINIA ROBERTS GIUFFRE, 18 having been first duly sworn or affirmed, was examined 19 and testified as follows: 20 THE WITNESS: Yes, I do. 21 DIRECT EXAMINATION 22 BY MS. BORJA: 23 Q. We have noticed this examination for you as 24 Virginia Roberts. I understand you have a different 25 married last name? CONFIDENTIAL  6 1 A. Yes. 2 Q. Could you pronounce that for me? 3 A. Giuffre. 4 Q. Giuffre. If I from time to time call you 5 Ms. Roberts, would that be okay with you today? 6 A. Absolutely. 7 (Thereupon, Defendant's VR Exhibit No. 1, 8 was Marked for Identification.) 9 BY MS. BORJA: 10 Q. I'm going to hand you a document that's 11 been marked as VR Exhibit Number 1, which is a notice of 12 taking video duces tecum. Ms. Roberts, are you appearing 13 here today pursuant to this notice of video deposition 14 duces tecum? 15 A. Yes. 16 Q. And you've seen this document before today? 17 A. No. 18 Q. Did you bring any documents with you today 19 pursuant to the duces tecum? 20 A. No. 21 Q. Were you asked to bring any documents with 22 you today? 23 A. No. 24 Q. You understand that you're under oath today 25 and that your testimony is being taken down by the court CONFIDENTIAL  7 1 reporter, correct? 2 A. Yes. 3 Q. And today's testimony is the same as if you 4 were testifying before a judge and a jury. Do you 5 understand that? 6 A. Yes. 7 Q. It's important that you allow me to finish 8 my question and I'll allow you to finish your answer 9 because the court reporter is very good, but she can only 10 type one of us talking at a time. Is that okay? 11 A. Yes. 12 Q. It's also important that all of your 13 answers be verbal since nodding your head or shaking your 14 head if you mean yes or no, you should give it a verbal 15 response. Is that agreeable? 16 A. Yes. 17 Q. What is your current home address? 18 MS. MCCAWLEY: We're going to object on the 19 record. You're welcome to notice anything to my 20 law office for Virginia. She's had some safety 21 issues with respect to her location so we're not 22 going to be putting that on the record. 23 MS. BORJA: That's fine. You're going to 24 accept service for her for all purposes in this 25 action? CONFIDENTIAL  8 1 MS. MCCAWLEY: Yes. 2 MS. BORJA: That's fine. Thank you. 3 MS. MCCAWLEY: Yes. If you need to serve 4 her with anything. 5 BY MS. BORJA: 6 Q. Ms. Roberts, are you taking medication that 7 would effect in any way your ability to testify? 8 A. No. 9 Q. Were you involved in collecting documents 10 for production in this case? 11 A. I don't understand. 12 Q. I'll get back to that in a little bit. Are 13 you aware of the action that your attorneys, Brad Edwards 14 and Paul Cassell, filed against the government? 15 A. Yes. 16 Q. If I call that the Federal action or the 17 CVRA action, will you understand the action that I'm 18 referring to? 19 A. Yes. 20 Q. And you sought to join that action, 21 correct? 22 A. Yes. 23 Q. And you understand that you were Jane Doe 24 #3 named in the motion for joinder, right? 25 A. Yes. CONFIDENTIAL  9 1 Q. I'm going to show you, I'm not going to 2 mark it as an exhibit, a copy of Jane Doe #3 and Jane Doe 3 #4 corrected motion pursuant to Rule 21 for joinder and 4 action. Do you have that in front of you right now? 5 A. Yes. 6 Q. And this was entered as Document 280 in the 7 docket for purposes of identification in our record here 8 today. Did you review this document before it was filed? 9 A. Not this specific document, no. 10 Q. Were you aware that this joinder motion was 11 being filed in the CVRA action? 12 A. I knew there was an action for the CVRA for 13 me to be joined, yes. 14 Q. And you're aware, are you not, that there 15 are allegations that you were sexually trafficked being 16 made in that action, correct? 17 A. I'm aware that there are allegations that I 18 was trafficked. 19 Q. If you turn to page 4 of this document the 20 numbers are on the bottom of the page. In that first 21 full paragraph in the third line down it says, Epstein 22 required Jane Doe #3 to have sexual relations with 23 Dershowitz on numerous occasions when she was a minor? 24 MS. MCCAWLEY: Feel free to look at the 25 entire page. CONFIDENTIAL  10 1 MR. SCAROLA: It is a minor discrepancy, 2 but I think you read it as when she was a minor 3 and it's while she was a minor. 4 BY MS. BORJA: 5 Q. While she was a minor. Do you see where 6 I'm reading starting in the third line? 7 A. Yes. 8 Q. Is that allegation true? 9 A. Yes. 10 Q. If you go to page 6 of the document, do you 11 see the paragraph that's starts, Epstein also trafficked? 12 A. Yes. 13 Q. Is says Epstein also trafficked Jane Doe #3 14 for sexual purposes to many other powerful men including 15 numerous prominent American politicians, powerful 16 business executives, foreign presidents, a well-known 17 prime minister and other world leaders. Do you see that? 18 A. Yes. 19 Q. Is that allegation true? 20 A. Yes. 21 Q. The reference there to foreign presidents, 22 do you see that? 23 A. Yes. 24 Q. You were sexually trafficked to foreign 25 presidents? CONFIDENTIAL  11 1 A. No. 2 Q. So that's not true, you were not sexually 3 trafficked to foreign presidents? 4 A. I don't know what foreign president you're 5 talking about. 6 Q. Have you ever been sexually trafficked to 7 any foreign president? 8 MS. MCCAWLEY: I'm going to allow you to 9 ask that question, but with respect to specific 10 identification of an individual we're not going to 11 do that. At this point she has. 12 MS. BORJA: Counsel, your objection has 13 been made. No speaking objections, please. Let's 14 move on. 15 MS. MCCAWLEY: I can make my record, and my 16 record is she's not going to be speaking with 17 respect to individuals' names that are named in 18 generalities in this document. 19 SPECIAL MASTER: Objection overruled. You 20 can answer. 21 A. I understand well-known prime ministers and 22 other world leaders; as far as foreign presidents, I'm 23 not too sure, I don't know. 24 Q. Have you ever met any foreign presidents? 25 A. Foreign presidents as in overseas? CONFIDENTIAL  12 1 Q. Sure, okay, overseas. 2 A. No. 3 Q. Have you ever met any foreign presidents 4 from countries not overseas such as Canada or Mexico? 5 A. No. 6 Q. So you were not sexually trafficked to any 7 foreign presidents; is that correct? 8 A. As far as I know right now, yes. 9 Q. It's correct that you were not sexually 10 trafficked to them, right? 11 A. You've asked me this three times and I'm 12 telling you. 13 Q. Okay. A well-known prime minister. Were 14 you sexually trafficked to a well-known prime minister? 15 A. Yes. 16 Q. Who was that? 17 MS. MCCAWLEY: I'm going to object to this 18 line of questioning. This has to do with safety 19 concerns for her. 20 MS. BORJA: Counsel, this is under seal. 21 You can answer. 22 MS. MCCAWLEY: No, she's not going to 23 answer. 24 SPECIAL MASTER: Hang on one second. 25 MS. MCCAWLEY: Let me make my objection. CONFIDENTIAL  13 1 SPECIAL MASTER: Make your objection. 2 MS. MCCAWLEY: Regardless of it being under 3 seal, we've seen that in this case the client that 4 you represent has violated confidentiality orders 5 regularly so we have no sense of security with a 6 sense that this is a confidential record at this 7 point. We are doing that under the Court's order. 8 With respect to naming individuals who can 9 harm a victim of sexual trafficking, she's a 10 non-party in this action, not a plaintiff. She is 11 not going to be revealing any names today of an 12 individual who is going to harm her physically, 13 period. If we have to go to Judge Lynch on that 14 we will, I'm happy to do that, but she's not going 15 to be naming individuals where there's a threat to 16 her safety. 17 SPECIAL MASTER: Response. 18 MS. BORJA: It is under seal. I'm shocked 19 that counsel would suggest that a prime minister 20 is threatening the physical safety of this 21 witness. There's no foundation for that. The 22 suggestion that a foreign minister is going to 23 physically harm has no evidence in this case, and 24 it's being to be under seal. 25 Let's get the evidence out while the CONFIDENTIAL  14 1 witness is here. As you pointed out, she's a 2 non-party. Let's make our record and move on. 3 MS. MCCAWLEY: You may be shocked by that 4 but -- 5 SPECIAL MASTER: Hang on one second. The 6 reason why I'm here is so we don't have the back 7 and forth. 8 MS. MCCAWLEY: Sure. 9 SPECIAL MASTER: I'm going to rule on the 10 objection. Your objection at this point is 11 overruled. You can answer. And I want to 12 admonish everybody here that this is confidential 13 and the protection of this witness is of paramount 14 importance under the Confidentiality Order. So 15 Ms. Roberts, you can answer the question that's 16 been asked. 17 MS. MCCAWLEY: At this point we're going to 18 need to take a break because I'm not going to 19 allow her to answer a question that's going to 20 threaten her physical safety. So we can take a 21 break on that. 22 THE WITNESS: If I can just say, I 23 personally know that this is not a good person to 24 talk about and I'm not going to, point blank, I'm 25 not going to say his name. CONFIDENTIAL  15 1 SPECIAL MASTER: Okay. I can't twist her 2 arm and force her so we'll deal with it. 3 BY MS. BORJA: 4 Q. Okay. Other world leaders, what other 5 world leaders were you sexually trafficked to? 6 MS. MCCAWLEY: We have the same objection. 7 SPECIAL MASTER: And I would have the same 8 ruling based upon the arguments. 9 MS. MCCAWLEY: Let me just make my record. 10 To the extent that there's a name of an individual 11 that you can reveal that you do not feel would 12 harm your physical safety, you're welcome to 13 reveal them. Anybody else, you don't have to 14 reveal at this time and we'll take that to Judge 15 Lynch. 16 A. Okay. Prince Andrew for one. 17 Q. Other than Prince Andrew? 18 A. There is another individual that I honestly 19 do not know his name. 20 Q. What country is he from? 21 A. I'm not too sure, he spoke in a foreign -- 22 he did speak foreign tongue, he spoke English as well, 23 but I'm not too sure where he was from. 24 Q. How do you know he is world leader? 25 A. I was introduced to him as a prince. CONFIDENTIAL  16 1 Q. Okay. Did he have security with him? 2 A. I'm sure he did somewhere around, but not 3 when I was with him. 4 Q. Did you see security? 5 A. No. 6 Q. Did you -- where were you when you met him? 7 A. On this occasion the South of France. 8 Q. Are there witnesses to you being sexually 9 trafficked to this prince? 10 A. Yes. 11 Q. Name them. 12 A. Jeffrey Epstein, Ghislaine Maxwell. 13 Q. Anyone else? 14 A. There was a whole bunch of people in the 15 room so of course. 16 Q. Was this an orgy? 17 A. No. 18 Q. Who else was in the room? 19 A. I can't name them all, there was a lot. 20 Q. Name as many as you can name? 21 A. I don't know their names. I can't name 22 their names. 23 Q. They were present during sexual activity? 24 A. They were present before the sexual 25 activity and then I went to have sexual activity with him CONFIDENTIAL  17 1 alone. 2 Q. So he's the only witness to your sexual 3 activity, the prince? 4 A. On the instruction of Epstein and 5 Ghislaine, yes. 6 Q. Where in the South of France were you? 7 A. I don't know. 8 Q. Were you on a boat, were you in a house? 9 A. We were at a like a cabana, not cabana, 10 like a resort, but it was a big party. 11 Q. Who was throwing the party? 12 A. I don't know. I was just brought there. 13 Q. You also refer to powerful business 14 executives. What powerful business executives were you 15 sexually trafficked to? 16 MS. MCCAWLEY: Again, to the extent you can 17 reveal somebody without a safety concern you're 18 welcome to do that. 19 SPECIAL MASTER: Well, again -- 20 MS. MCCAWLEY: Right. I understand. 21 SPECIAL MASTER: Same objection, same 22 ruling. 23 A. George Mitchell. 24 Q. When were you sexually trafficked to George 25 Mitchell? CONFIDENTIAL  18 1 A. I am unable to give you times since we are 2 going back a very long time ago. 3 Q. Tell me the best that you can remember? 4 A. Roughly when I was 17. 5 Q. Where were you? 6 A. New Mexico and New York. 7 Q. Are there witnesses to this? 8 A. Not to the actual event itself. 9 Q. What other powerful business executives 10 were you sexually trafficked to? 11 A. . 12 Q. Are there witnesses? 13 A. Besides Epstein instructing me to do so, 14 no. 15 Q. What other powerful business executives 16 that you were sexually trafficked to? 17 A. Yes, I know what you're saying. 18 MS. MCCAWLEY: Take your time. Take a deep 19 breath. 20 A. . 21 Q. Who else? 22 MS. MCCAWLEY: To the extent you recall. 23 A. I'm just trying to think. This is all very 24 confronting for me. So at the same token I'm just trying 25 to recollect everybody. . CONFIDENTIAL  19 1 Q. You said , were you sexually 2 trafficked to more than one ? 3 A. No. 4 Q. Just to ? 5 A. Just to . 6 Q. 7 . 8 A. Yes. 9 Q. What other powerful business executives 10 were you sexually trafficked to? 11 A. None that I can remember off the top of my 12 head. 13 Q. Was one of the powerful business 14 executives that you were trafficked to? 15 A. Yes. 16 Q. So you can remember others. Who else is 17 there? 18 MS. MCCAWLEY: I'm going to object to that. 19 That's inappropriate. She gave you everyone she 20 could remember at the time when you mentioned a 21 name. 22 SPECIAL MASTER: Okay. Okay. Please move 23 on without -- 24 MS. BORJA: There's a question pending. 25 A. I said yes. CONFIDENTIAL  20 1 Q. What other powerful business executives? 2 A. Wasn't that just objected? 3 MS. MCCAWLEY: You can answer. 4 SPECIAL MASTER: You can answer. 5 A. I can't remember off the top of my head, 6 I'm sorry. 7 Q. You also referred to prominent American 8 politicians. What prominent American politicians other 9 than the ones we've already named were you sexually 10 trafficked to? 11 A. The ones I just told you about, 12 . 13 Q. How many times were you trafficked to 14 ? 15 A. I don't know, over two times. 16 Q. How old were you? 17 A. Approximately 17, 18. 18 Q. Are you sure you were underage during one 19 of those incidents? 20 A. I can't be 100 percent sure of anything. 21 It's not like I recorded the dates. I'm just giving you 22 an approximation. 23 Q. How many times were you sexually trafficked 24 to ? 25 A. Twice that I can recall. CONFIDENTIAL  21 1 Q. Were you underage during either of those? 2 A. I believe so. 3 Q. Both of them? 4 A. I can't be 100 perfect sure. 5 Q. When you were sexually trafficked to the 6 were you underage? 7 A. Not by standards. 8 Q. You weren't in , were you, you were 9 in the South of France? 10 MS. MCCAWLEY: Which ? You need to 11 clarify. 12 A. , sorry. I believe I would 13 have been 17. I don't know what their age -- 14 MS. MCCAWLEY: You don't have to know. You 15 don't have to know anything legal. Just answer 16 the question the best you can. 17 BY MS. BORJA: 18 Q. So how old were you when you were sexually 19 trafficked to ? 20 A. I don't know. 21 Q. What is your best guess? 22 A. I'm not going to speculate. 23 Q. How many times did you have sex with 24 ? 25 A. Once. CONFIDENTIAL  22 1 Q. How many times did you have sex with 2 ? 3 A. Multiple. 4 Q. What's the approximate range of number, 5 more than three? 6 A. More than three. 7 Q. More than five? 8 A. Possibly. 9 Q. More than ten? 10 A. No. 11 Q. Did ask you to wear any 12 particular clothing during your sexual trafficking? 13 MS. MCCAWLEY: Again, I'm going to object 14 to this line of questioning. To the extent that 15 you revealed something to me in work product 16 circumstance or attorney-client privilege, I don't 17 want you revealing that. 18 This case is about the defamation between 19 Paul Cassell and Brad Edwards and Mr. Dershowitz. 20 It's not about the individuals other than Mr. 21 Dershowitz who is the individual here who the 22 judge said we're here to talk about the issues in 23 this case, not the litany of other individuals. 24 MS. BORJA: Counsel, we have limited time. 25 SPECIAL MASTER: Hang on one second. I'm CONFIDENTIAL  23 1 going to deny the objection. You can answer the 2 question. I'm going to give some latitude on 3 this, but counsel, please understand it's some 4 latitude. So you can answer the question. 5 MS. BORJA: And Special Magistrate, I would 6 also ask for an instruction, we have limited time 7 here and speaking objections are inappropriate and 8 unnecessary for your ruling. 9 MS. MCCAWLEY: I'm allowed to make my 10 record. 11 SPECIAL MASTER: Counsel, she needs to make 12 the record, however, the four hours in my mind is 13 not a hard and fast four hours based upon how we 14 proceed in this deposition. So I'll take that 15 into consideration as we approach the four hours. 16 A. Yes, I wore lingerie for him. 17 Q. At his request? 18 A. It wasn't his request, it was Ghislaine who 19 set it up for me. 20 Q. And did she specify baby doll lingerie to 21 be worn? 22 A. All different types of lingerie. 23 Q. Was it specifically Victoria Secret 24 lingerie? 25 A. I didn't write the brand. CONFIDENTIAL  24 1 Q. Have you alleged that you were required to 2 wear Victoria Secret lingerie for ? 3 A. No. 4 MS. MCCAWLEY: Alleged in what context? 5 BY MS. BORJA: 6 Q. She's already answered. Now, other than 7 the people you've already named for me today, were you 8 sexually trafficked to anyone else during your period 9 between 1999 and 2002? 10 A. Yes. 11 Q. Who else? 12 MS. MCCAWLEY: To the extent you can 13 recall. 14 SPECIAL MASTER: Counsel, let her think it 15 through. 16 A. Alan Dershowitz, , the obvious 17 people that I've already stated. , 18 Jeffrey Epstein obviously, Ghislaine Maxwell, you know, 19 there's people that I just -- I honestly can't think of 20 everybody right now. I do feel like I am under a lot of 21 pressure to answer the questions and I'm doing the best 22 that I can honestly. 23 Q. Were you sexually trafficked to 24 ? 25 A. Yes. CONFIDENTIAL  25 1 Q. Were you sexually trafficked to a man last 2 name ? 3 A. Who? 4 Q. , if the name doesn't ring a bell, 5 just tell me? 6 A. No. 7 Q. How many times were sexually trafficked to 8 ? 9 A. Once. 10 Q. How old were you? 11 A. I don't know. 12 Q. You're sure it was one time, correct? 13 A. I'm not sure of anything. There was a lot 14 of people that Jeffrey sent me to and it was a long time 15 ago. I can't be a thousand percent correct on that. 16 Q. Who is ? 17 A. He is an older gentleman. 18 Q. Do you know what's does for a living? 19 A. I think he's a , but I don't want 20 to 100 percent say. 21 Q. Who is ? 22 A. I think he's a . 23 Q. Do you know where? 24 A. Possibly , I think, or maybe . 25 I'm not too sure. I'm just speculating. CONFIDENTIAL  26 1 Q. Where did you meet ? 2 A. , at the islands. 3 Q. And when you say the islands, do you mean 4 Jeffrey Epstein's estate? 5 A. Yes. 6 Q. And where did you meet ? 7 A. was at the islands as well. 8 Q. Did you ever meet him anywhere else? 9 A. Yes. 10 Q. Did you have sex with him in other 11 locations? 12 A. No. 13 Q. Did you ever fly in a plane with him? 14 A. No. 15 Q. Did you ever have sex is ? 16 A. No, not that I know of. The name does not 17 ring a bell. You have to understand that there were a 18 lot of gentlemen that I was lent out to by Jeffrey 19 Epstein. So it is very hard for me to remember all of 20 their names and who they were and what they did. 21 (Thereupon, Defendant's VR Exhibit No. 2, 22 was Marked for Identification.) 23 BY MS. BORJA: 24 Q. Ms. Roberts, when you refer to 25 , did you mean ? CONFIDENTIAL  27 1 A. No. 2 Q. Have you ever met a ? 3 A. Possibly. 4 Q. Do you know one way or the other? 5 A. Do I know? 6 Q. You said possibly? 7 A. I was introduced lots of political 8 scientific, academic, so there is a possibility I could 9 have met him. 10 Q. Did you ever have sex with ? 11 A. No. 12 Q. Were you ever sexually trafficked to 13 ? 14 A. No, not that I know of. 15 Q. I'm handing you a document that's been 16 marked as VR Exhibit 2, which is Plaintiff, Virginia L. 17 Giuffre's, I apologize, disclosure pursuant to Federal 18 Rule of Civil Procedure 26. 19 This is a document that was entered in your 20 lawsuit against Ghislaine Maxwell in the Southern 21 District of New York. Have you ever seen this document 22 before? 23 A. No. 24 Q. If you take a look, there's a list of 25 witnesses starting at page 1 and continues on? CONFIDENTIAL  28 1 A. Yes. 2 Q. I'm wondering whether this list might help 3 you. Can you look at the names on this list and tell me 4 who from these names you were sexually trafficked to? 5 A. . I wasn't 6 trafficked to her. She was just a part of some of the 7 trafficking. 8 Q. Hold on. What part did she have in the 9 trafficking? 10 A. She was involved in some of the orgies. 11 Q. So she was a sexual participant in the 12 orgies? 13 A. Yes. 14 Q. That you were a participant in as well? 15 A. Yes. 16 Q. Were these orgies that was 17 involved in with any of the individuals that you have 18 named so far today? 19 A. Not that I can remember right now. 20 Q. Do you know what gentlemen were involved in 21 the orgies with you and ? 22 A. As far as I can recall Jeffrey Epstein. 23 Q. Okay. 24 A. , does 25 ring a bell, but I don't want to 100 percent say that. CONFIDENTIAL  29 1 Q. Ring a bell in terms of what? 2 A. The name rings a bell. I mean, you have to 3 understand there was a lot, a lot, a lot of girls around 4 to remember all of their names. 5 Q. My question is, was a 6 participant in sexual activities with you? 7 A. I don't know and I'm not going to 8 speculate. 9 Q. I'm not asking you to speculate. I'm 10 asking you under oath today was she a participant, as far 11 as you can recall today, in sexual activities -- 12 MS. MCCAWLEY: Objection, asked and 13 answered. Sorry, I didn't mean to interrupt. 14 BY MS. BORJA: 15 Q. -- with you? 16 A. I'm telling you under oath that I'm not 17 sure about being in sexual orgies with me 18 but the name does ring a bell. 19 Q. And ? 20 A. Yes, she was involved, but I'm not going to 21 speak about her. She has the right to her own privacy. 22 She's been hurt, she's a victim, so I'm not going there. 23 Q. Did she participate in any of the sexual 24 activities with others that you've named today? 25 A. Yes. CONFIDENTIAL  30 1 Q. With whom? 2 A. I'm not answering that. 3 MS. MCCAWLEY: We're going to object. To 4 the extent that you're concerned about the safety 5 of one of these individuals, we're not going to 6 testify. We can go to the judge and we can come 7 back if he says you have to testimony regarding 8 that but -- 9 MS. BORJA: We already have the names of 10 the gentlemen. 11 SPECIAL MASTER: Hang on one second. For 12 purposes of the record, have you made your record? 13 MS. MCCAWLEY: Well, let's make a record. 14 So was underage at the time this 15 occurred so she, herself, is a victim. So to the 16 extent that, you know, if you want to bring her 17 counsel in and have them present during something 18 like this, that's fine, but this witness who is a 19 non-party to this litigation who's a victim 20 herself doesn't have to speak about other 21 under-aged victims. 22 SPECIAL MASTER: Counsel? 23 MS. BORJA: I'm entitled to know the names 24 of witnesses who can either verify or discredit 25 the allegations. CONFIDENTIAL  31 1 MS. MCCAWLEY: She's given you the name. 2 SPECIAL MASTER: Counsel, let her make her 3 record. 4 MS. BORJA: As to specific individuals, and 5 I do not want to bring up her name with 6 individuals with whom she's not alleged to have 7 had sexual activity, that would be unfair to this 8 witness; but what would be fair to my client who 9 is being sued in this case is to be able to check 10 the allegations with a neutral third party, and if 11 this is a witness -- 12 MS. MCCAWLEY: Why don't you ask her if 13 that's somebody who was involved with your client, 14 which is what we're here on today, Alan 15 Dershowitz, not all of these other individuals. 16 SPECIAL MASTER: Okay. All right. Have 17 you made your record? 18 MS. BORJA: Yes. 19 SPECIAL MASTER: I'm going to overrule the 20 objection. I understand that you're going to 21 instruct the witness not to answer, right? 22 MS. MCCAWLEY: Yes. 23 SPECIAL MASTER: So that will have to be 24 dealt with in front of Judge Lynch for a 25 subsequent time because I do think that it's CONFIDENTIAL  32 1 incumbent upon, especially on this question, it's 2 incumbent upon you to lay the predicate as to why 3 you're instructing the witness not to answer. 4 MS. MCCAWLEY: And I believe I have. 5 SPECIAL MASTER: I understand. We're not 6 here to do that. So I'm going to, for purposes of 7 the record, I'm going to overrule your objection. 8 And now make your instruction so we have a clean 9 record to deal with. 10 MS. MCCAWLEY: Sure. With respect to 11 because she was an underaged victim at the 12 time, I'm instructing you not to answer questions 13 with respect to her other than identifying her as 14 being one of the victims involved. 15 BY MS. BORJA: 16 Q. Are you going to follow your counsel's 17 instructions? 18 A. Absolutely. 19 Q. And you understand that we're going to 20 reserve the right to bring you back for another 21 deposition in the event that the judge overrules your 22 counsel's objections. Do you still want to keep abiding 23 by those? 24 A. Go for it. 25 Q. I'm sorry? CONFIDENTIAL  33 1 SPECIAL MASTER: Yes. Yes. 2 A. No problem. 3 Q. We were looking at the list of names and 4 you were going through to see if they refresh your 5 recollection as to the names of individuals to whom you 6 were sexually trafficked? 7 A. On page 3, . 8 Q. Who is ? 9 A. I think she also goes underneath the name 10 , if it's the same woman that I'm thinking of 11 and she was one of Jeffrey's, I would like to say, 12 co-conspirators. She had sex with underaged girls and 13 myself. 14 . He was not 15 only a witness, but also another co-conspirator. Again, 16 sounds familiar, but I'm not going 17 to attempt to put her out of place and I'm not too sure. 18 Q. Do you know who the names of the others 19 are, or , do you know who 20 they are? 21 A. I think I have heard of as 22 another victim, but I don't recall meeting her. 23 Q. Do you know who is? 24 A. No. 25 Q. Okay. CONFIDENTIAL  34 1 A. Number 19, Alan Dershowitz; 2 ; . 3 Q. Before you move on, were you sexually 4 trafficked to ? 5 MS. MCCAWLEY: This has been asked and 6 answered. 7 SPECIAL MASTER: No, it has not. 8 Overruled. 9 A. No, I was not trafficked to . 10 . 11 Q. Let my ask you this, were you sexually 12 trafficked to ? 13 A. No. 14 MS. MCCAWLEY: With a question pending, I 15 think she's lost the question, Counsel. Ask the 16 question. 17 MS. BORJA: Okay, counsel, I'll ask the 18 question. 19 MS. MCCAWLEY: Thank you. 20 BY MS. BORJA: 21 Q. The question is, when you look at this list 22 of names does it refresh your recollection as to who you 23 were sexually trafficked to? 24 A. Some of the people that I mentioned, yes. 25 Q. Okay. So, let's continue reviewing the CONFIDENTIAL  35 1 list. I'm looking for the names of the people that you 2 allege you were sexually trafficked to? 3 A. Okay. ; number 27, 4 Jeffrey Epstein; , she was an 5 older woman who participated. 6 Q. Participated in what? 7 A. In sexual acts. 8 Q. With whom? 9 A. With Jeffrey Epstein. 10 Q. How do you know that? 11 A. I was there with her. 12 Q. Okay, who else was there? 13 A. Ghislaine Maxwell, . 14 Q. Anyone else? 15 A. No. Did I say ? 16 Q. No. 17 A. Okay, is another one. 18 Q. Is another what? 19 A. Another older woman that was a part of the 20 sexual endeavors. 21 Q. With whom? 22 A. Ghislaine, Jeffrey and me. 23 Q. Anyone else? 24 A. 25 Q. I'm sorry, I'm still talking about CONFIDENTIAL  36 1 . When you said involved, you said involved with 2 sexual activity with Ghislaine, Jeffrey and yourself. 3 Was there anybody else involved? 4 A. Not that I can remember. 5 Q. Was this a single incident? 6 A. No. 7 Q. Okay. 8 A. , 9 , she was involved with, very heavily 10 involved with lots of incidents of sex. 11 Q. With yourself? 12 A. With myself. 13 Q. And who else? 14 MS. MCCAWLEY: To the extent you can 15 answer. If it's multiple incidents you can take 16 them one at a time. 17 A. It was multiple incidents so it's going to 18 be nearly impossible for me to remember every one. But 19 obviously Jeffrey Epstein, Ghislaine Maxwell, , 20 . I'm sure there's more, but I 21 just can't remember off the top of my head. 22 Q. How do know that she had sex with 23 ? 24 A. I was there. 25 Q. How do you know she had sex with CONFIDENTIAL  37 1 ? 2