gov.uscourts.nysd.447706.1328.11.pdf

Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 1 of 11 COMPOSITE EXHIBIT 4 (Filed Under Seal) Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 2 of 11 Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 3 of 11 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ____________________/ VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 1 of 2 Pages 1 - 157 Taken at the Instance of the Defendant DATE: Friday, June 24, 2016 TIME: Commenced: 8:59 a.m. Concluded: 1:22 p.m. PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 4 of 11 96 1 Q I guess my question is: Did she ever tell 2 you that she had started as a regular masseuse for 3 him and then transitioned to something other than a 4 masseuse? 5 A No. She never said that it transitioned. 6 But she ended up explaining to me what had happened 7 before, so... 8 Q What has -- what is that? 9 A That her and Ms. Maxwell and Jeffrey would 10 obviously be doing stuff, all three of them 11 together. Like I said, that they would all go out 12 to clubs to pick up girls and try and find them to 13 bring back for Jeffrey. And then she told me about 14 how, like I said, her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still together? 19 A Yes. 20 Q Did you -- had you met Ms. Maxwell? 21 A Yeah, I had met her a couple of times. 22 Q When did you meet Ms. Maxwell? 23 A Dates, I'm unsure of. But it was pretty 24 much, like I said, at Jeffrey's house in the 25 kitchen. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 5 of 11 97 1 Q Was it earlier in the time you were with 2 her, or... 3 A It was about -- I'd say about six months 4 or so. I don't know. I'm not exactly positive. 5 Q All right. So at the time you met 6 Ms. Maxwell, had Ms. Roberts already told you that 7 she had been intimate? 8 A No. She had told me about that, I 9 believe, after I had max- -- after I had already met 10 her. 11 Q Okay. And tell me everything that you 12 remember about what Ms. Roberts said about being 13 intimate with Ms. Maxwell and Mr. Epstein at the 14 same time. 15 A I remember her talking about, like, 16 strap-ons and stuff like that. But, I mean, like I 17 said, all the details are not really that clear. 18 But I remember her talking about, like, how they 19 would always be using and stuff like that. 20 Q She and Ms. Maxwell and Mr Epstein would 21 used strap-ons? 22 A Uh-huh (affirmative). 23 Q How did you feel about that? 24 A I just -- obviously not happy about it. 25 Q What did you say? Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 6 of 11 103 1 A I did not. 2 Q When the FBI interviewed you, did you 3 mention this to them? 4 A I mentioned -- anything they asked me, I 5 did not hold anything back. 6 Q Okay. Do you recall specifically talking 7 about sex with the Prince? 8 A I -- I don't recall talking to them about 9 that, but, I mean, it's -- it could be possible. 10 Q Other than sex with the Prince, is there 11 anyone else that Jeffrey wanted Ms. Roberts to have 12 sex with that she relayed to you? 13 A Mainly, like I said, just Ms. Maxwell and 14 all the other girls. 15 Q Ms. Maxwell wanted -- Jeffrey wanted 16 Virginia to have sex with Ms. Maxwell? 17 A And him, yeah. 18 Q And did she tell you whether she had ever 19 done that? 20 A Yeah. She said that she did. 21 Q And when did she tell you that? 22 A I'm not sure on the date. 23 Q And what did she describe having happened? 24 A I believe I already told you that. With 25 the strap-ons and dildos and everything. Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 7 of 11 104 1 Q Was it one event or more than one event? 2 A I'm positive it was more than one. 3 Q Why do you say that? 4 A Because they were always with each other. 5 Like, any time she would talk to me about them going 6 to do stuff, it was with her and Ms. Maxwell. Like, 7 they were always out, like, trying to get girls and 8 whatnot. 9 Q Okay. Did you ever participate in getting 10 girls? 11 A Yes. But... 12 Q Tell me what you mean. What did you do? 13 When you say 'get girls,' what do you mean? 14 A Pretty much I got some of my friends that 15 I knew, because Virginia was looking for other girls 16 to go over there, because Jeffrey was giving us $200 17 apiece for every one that we brought over. And 18 I'll -- pretty much I would get friends that I went 19 to school with, and I would take them over there and 20 introduce them, and then I would just leave. 21 Q What did you tell them they were going to 22 do? 23 A A masseuse, like, and then I told them -- 24 I was, like, "Now, listen." I was, like, "I'm 25 letting you know I don't know what he's going to ask Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 8 of 11 157 1 CERTIFICATE OF REPORTER 2 STATE OF FLORIDA ) 3 ) COUNTY OF VOLUSIA ) 4 5 6 7 I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did 8 stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a 9 true record of my stenographic notes. 10 I further certify that I am not a relative, employee, attorney, or counsel of any of the 11 parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the 12 action, nor am I financially interested in the action. 13 Dated this 5th day of July, 2016. 14 15 16 17 18 19 __________________________________ 20 Leanne W. Fitzgerald, FPR Florida Professional Reporter 21 Digital Certificate Authenticated 22 By Symantec 23 24 25 Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 9 of 11 158 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ____________________/ VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 2 of 2 Pages 158 - 258 Taken at the Instance of the Defendant DATE: Friday, June 24, 2016 TIME: Commenced: 8:59 a.m. Concluded: 1:22 p.m. PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public 6RXWKHUQ5HSRUWLQJ&RPSDQ\ ZZZ6RXWKHUQUHSRUWLQJFRP   Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 10 of 11 200 1 MS. MENNINGER: Objection. Form. 2 Foundation. 3 A For Jeffrey. 4 BY MR. EDWARDS: 5 Q All right. Let me fix this. Ghislaine -- 6 when Ghislaine Maxwell would call you during the 7 time that you were living with Virginia, she would 8 ask you what, specifically? 9 MS. MENNINGER: Objection. Form. 10 Foundation. 11 A Just if I had found any other girls just 12 to bring to Jeffrey. 13 BY MR. EDWARDS: 14 Q Okay. 15 A Pretty much every time there was a 16 conversation with any of them, it was either asking 17 Virginia where she was at, or asking her to get 18 girls, or asking me to get girls. 19 Q All right. Let's go to that second 20 category you just identified, which is asking 21 Virginia to get girls. How many times were you in a 22 room where specifically Ghislaine Maxwell would ask 23 Virginia to bring girls? 24 A None that I can recall. 25 Q Okay. How many times -- when you say they Southern Reporting Company www.Southernreporting.com - (386)257-3663 Case 1:15-cv-07433-LAP Document 1328-11 Filed 01/05/24 Page 11 of 11 258 1 CERTIFICATE OF REPORTER 2 STATE OF FLORIDA ) 3 ) COUNTY OF VOLUSIA ) 4 5 6 7 I, Leanne W. Fitzgerald, Court Reporter, do hereby certify that I was authorized to and did 8 stenographically report the deposition of TONY FIGUEROA; and that the foregoing transcript is a 9 true record of my stenographic notes. 10 I further certify that I am not a relative, employee, attorney, or counsel of any of the 11 parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the 12 action, nor am I financially interested in the action. 13 Dated this 5th day of July, 2016. 14 15 16 17 18 19 __________________________________ 20 Leanne W. Fitzgerald, FPR Florida Professional Reporter 21 Digital Certificate Authenticated 22 By Symantec 23 24 25 Southern Reporting Company www.Southernreporting.com - (386)257-3663