Giuffre Exhibits

Case 18-2868, Document 286, 08/09/2019, 2628248, Pagel of 55 EXHIBIT Case 18-2868, Document 286, 08/09/2019, 2628248, Page2 of 55 United States District Court Southern District Of New York --------------------------------------------------X Plaintiff, v. Ghislaine Maxwell, Defendant. -----------------------------------------------X ............................................... Virginia L. Giuffre, 15-cv-07433-RWS DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following disclosures: I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH PARTICULARITY IN THE PLEADINGS 1. Ghislaine Maxwell c/o Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave. Denver, CO 80203 303-831-7364 LMenninger@HMFLaw.com Ms. Maxwell is the Defendant and may have knowledge concerning matters at issue, including the events of 1999-2002 and the publication of statements in the press in 2011-2015. 2. Virginia Lee Roberts Giuffre c/o Sigrid S. McCawley, Esq. Boies, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Case 18-2868, Document 286, 08/09/2019, 2628248, Page3 of 55 Miami, Florida 33301 (954) 356-0011 smccawley@bsfllp.com Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue in her Complaint, including the events of 1996-2015 and the publication of statements in the press in 2011-2015. 3. Philip Barden Devonshires Solicitors LLP 30 Finsbury Circus London, United Kingdom EC2M 7DT DX: 33856 Finsbury Square (020) 7628-7576 Philip.Barden@devonshires.co.uk Mr. Barden has knowledge concerning press statements by Plaintiff and Defendant in 2011-2015 at issue in this matter. 4. Paul Cassell College of Law, University of Utah 383 South University Street Salt Lake City, UT 84112 801-585-5202 paul.cassell@law.utah.edu Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff’s court pleadings, and Plaintiff’s sworn testimony. 5. Alan Dershowitz c/o Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 (202) 719-7000 Mr. Dershowitz has knowledge concerning Plaintiff’s false statements to the press, in court pleadings, and in sworn testimony, at issue in this matter. 6. Bradley Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301 (954) 524-2820 brad@pathtojustice.com 2 Case 18-2868, Document 286, 08/09/2019, 2628248, Page4 of 55 Dated: February 24, 2016. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 lmenninger@hmflaw.com Attorney for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on February 24, 2016, I electronically served this DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the following: Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com s/ Laura A. Menninger Laura A. Menninger 7 Case 18-2868, Document 286, 08/09/2019, 2628248, PageS of 55 EXHIBIT OO To: P3996 0f 55 From: Virginia Giuffre Sent: Thur 5"12/2011 2:21 :43 AM luportanoe: Normal Subject: Re: Good News!! Received: Thur 5/12/2011 2:21:43 AM Thanks again Shazza, I'm bringing down the house with this book!? xoxo Jenna 011 Wed, 11/5/11. Sha ?Sharon. y. uk> wrote: From; Sha rou.Clturchc .co. uk maj .co. uk> Subject: Re: Good News? To: "Virginia Giu??rc" Received; W'?duesday, 1] May. 2011, 4.17 PM Don't forget Alan Detshowitz. JE's buddy and lawyer..good name for your pitch as he rapped Claus von Bulow and a movie was made about that was Revetsal of Fortune. We all suspect Alan is a pedo and tho no proof of that, you probahiy met him when he was hanging put .IE lFrom: - MW Giu??rc vac?1 lTo: . - "i Sharon Churcher 'l [Date I I -- I I 23:00 . I l" I Good News? Q~nuo? -- I I Hi Sharon> chUo gorgeous, I hope this message comes to you on a. bright} sunny dayHH took your advice about what to offer Sandra. and she accepted. Were [drawing up a contract through her agent right now and getting busy to Com-nght Pmlecled Mutemtl CONFIDENTIAL 18-2 68 Document 286,, 08/09/2019, 2628248, Page7 of 55 . Gas?i . . Im}: dcadimc. Just won 1 youhmc any minimization on yciu ham when I 2:11:11 were doing intewiews about the IE. story: I wanted to put the I Iriames of some of these asshoies, mops, meant to say, IledO'F-i: that .E Ismt mu: to. With everything going on my brain fccis like mush and it wm?dl lbs: 3 great dcai I IHaving fun sweetie? I IThanks? I Ileaml I wan-A JI-Irwu-u warm-I'? i?his emaii has been scanned by the Messagaidabs Emaii System Far more information please visit This c-maii and any attached ?ics are for the married addressee oniy. it contains infonnation, which may be confidential and icgaliy priviicgcd and also prorated by copyright. Unlesg you are the named (or anthm?ised to receive for the addressee) you may not copy or use it; or disclose it to anyone else? Ifyou received is in uimr please noii 1" ihC sender immc?iaicly and then ii li?m?n your system. Phase be advised that {he views a?d opinions in this c-maii may not re?ect the views and opinions of?ssuciatcd Newspapers Lim?cd or any of its subsidiary companias. We mak?t evm'y effort ?0 keap our network ?free from viruses. Naive-vat; 3:011 (in need In Check this c?maii and any attachments to it for viruses as we can take no responsibility For any computer virus which may be transferred by way of this e-maii. Use of this or any U?ler e?mail signifies consent to any interception we might Iawfu?y carry- out to prevent abuse of these facilities. Associated Newspapers Ltd. Registered Of?ce: No?hciiffe House, '2 Derry Remington, oudoni 8 Registered No 8412.; England, I Cupyrighl i?riilmied Mumriaii To: Sharon 2628248, P3998 0? 55 From: Virginia Giuffre Sent: Wed 61812011 11:19:55 PM Importance: Normal Subject: Re: Virginia Roberts Received: Wed 5/812011 11:19:55 PM Hi Buddy, You are absolutely biting is an understatement of the century?? We didn?t. have any trouble with spiders or anything like that it was more my daughter that gave everyone a spook! She wandered off when I turned my back to look at homemade jam and found her outside in the bush chasing the rods? My Own miniatmL? My ?ngers and toes me crossed and I'm thinking positive? 5! Much Love, Jenna On W'ed, 816/11, Sharon ureher wrote. From~ Sharon Subject: Re: Vir inia Roberts in Received: Wednesday, 8 June, 2011, 11:59 AM Rum. Yen lle?i?Tf" :?nmfte .. but did {~32 item: to duck urz-zlet wider They Wd?it: same-g hcween treat mien 3: went. KL: Litre-:1: it is; .1 nailbiung; art-1n but remember he 13 only me: 533mm 1-111. vex ?16113 it wind; [8 good. .ii?ne Lin-:31: go for it. there an: mhenz. Dii?i?eren-r. tea-ties. When (he. you tend Midi} From. Virginie (iinffi'e Sent: 11:00.03. 2011 01327 AM To Sharon C'luuehcr Subject: Re: Roberts Dearest Shazza, Once again you have really outdone MANY, I took the kids to the Australian Walkabout Park today and enjoyed the scenic walks and many kangaroos. Rob and I hat good chuckle about our adventures at the Reptile Park with you and Mike times! !3 Have you heard from Mike? I hope he is well and if you ever speak, tell him I sent 21 BK) hello. Ireally appreciate evelything you have helped with. as a friend you have gone beyond the call ofdutyl I hope we hear back from Jarred sooull xomxo Jenna On Wed, 8/6/11, Sharon ('Jhurcher wrote: From: Sharon Churchei? Subject: Virginia Roberts To: "jawedhalperin agent ?ari'ed?c'lloh'cctiveenmom <jarrcd@ohjcetivcentcomf'? Cc: "Virginia Giuffre" Received: Wednesday. 8 June, 201 1. 2:31 AM Comrighl Pmlecled Material (IINFIDENTML Glumz?rmozg Case 18-2868, Document 286, 08/09/2019, 2628248, Page9 of 55 Hi Jarred Hopefuily you have Virginia?a hank pitch by new, She has some amazing names; which she can share with you in confidence and i think she also has a human interest story that cauld appeal to the Omani/female set as welt as the Wall Streetere whe teltdw Epstein a hedge fund king. Here are a few of our stories about Virginia, plus some examples of the massive US and other internationai media pickup. Vanity Fair are riding a piece i believe in theirAugust issue. The FBI have reopened the Epstein case due to Virginia?s revelations. I also am attaching a link to a NY Magazine profile of Epstein written before his world combusted. The FBI believe he was essentially running a private and imbue brothel for some at the world's richest and meat in?uential men. He got off the ?rst time round after retaining Kenneth Starr (who witchhuntecl Biil Clinton) and Alan Dershowitz (van Butdw?s appeal lawyer, who inspired the movie Reversal of Fortune). The US Justice Dept is investigating corruptien altegations against at. least one prosecutor involved in the case. Best regards, Sharon tum-gr demurrer an .ti?i wraurtr?f mead? the? ism?dmt?n-unn t??l?fi??i??zilf??ii 1?5; 3935.353 :23 ?ill ?Mn nitrati-ixnranrarz2;ear i: menu tent nae eat. Bei- fir; Miner?..- izttp. first innai tea ie1vvt'aetz. 321:2; ?3'3 math."- Went: (This one, in Forbes Magazine, seems to require subscribing but you get the gist) latte. emanate; ee- it? denied are? a 32.3% ?333994 http:tf i139 1 2i This e-tnaii and any attached ?les are intended for the named addressee only It mutating which may be con?dential and legaliy privileged and also protected by copyright. Unless; you are the named addresses (or authorised to receive fer the addressee) you may not copy or use it; or disclose it to anyone else. If you received it in arm please notify the sender immediately and then delete it from your nyalem. Please he advised that the views; and opinions expressed in this email may not. re?ect the views and opininns Newspapers timitcd or any at? its subsidiary We make every effort. to keep 0111' network Free From viruaus. Hon-rover, you do need to check. this c-mait and any attachments it.) it. far viruses as we can take 110 for any computer virus which may he transferred by way of this e-mail. Use of this or any other Ewti?t?ll Facility signifies consent to any intei?eeptirm we might tau-"fully carry out to prevent aimed Associated Newspapers Ltd. Registered Office: Northciiffe Hausa, Derry St. Kensiugteh. London. W8 STT. Registered No 84121 England, 'i?hia email has been scanned by the MessageLahs Email Security System. For more atinn please visit This cmaii has: been scanned by the Messachabs Email Seetirity Sign; tcm. I Copyright Pmleuted Material Case 8-2868, Document 286, 08/09/2019 For more information is case Visit 2628248, PagelO of 55 This c-maii and any attached ?les are intcudcd for the named addresses only. it contains iuibmiatiou, which may be sordid entiz-ii and legaliy privileged and also protected by copyright. Unless you are the named addressee (or authmised to receive far the addressee) yeti may not copy or use it, or disclose it to anyone else, tfyou received it in carer please natif} the sea-tier immer?ately and then delete it from your system. P123358 be advised that the views and opinions expressed it} tl a-maii may tint reflect the views and npinirms of Associated Newspapers Limited or any of its subsidiary crimpanies. We make every ct?t'ort tr: mir network true from viruses. However, you do need to check this c-mail and any attachments it for Viruses as we can take no responsibility for any computer Vitus which may be transferred by way of this e?maii. Use this or any other c-mail facility signifies consult to any interception we. might lawfully {3311ij out to facilities. Assecistcci Newspapers Ltd. Registered Of?ce: House, Derry St, Kcnsington, London, W8 STT. Registered No 84121 E?glalld. Copyriglil Prulemted Material Case 18-2868, Document 286, 08/09/2019, 2628248, Pagell of 55 EXHIBIT PP Agren Document Blando Court Reporting 2628248, & Video, Page12 Inc. Case 18-2868, 286, 08/09/2019, of 55 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II November 14, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE VOLUME II 11/14/2016 348 Agren Document Blando Court Reporting 2628248, & Video, Page13 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 3 4 5 6 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura Menninger, Esq. Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant 7 8 Also Present: Ann Lundberg, Paralegal Maryvonne Tompkins, Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 349 Agren Document Blando Court Reporting 2628248, & Video, Page14 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the continued video 3 deposition of VIRGINIA GIUFFRE, called by Defendant, 4 was taken on Monday, November 14, 2016, commencing at 5 8:04 a.m., at 150 East 10th Avenue, Denver, Colorado, 6 before Pamela J. Hansen, Registered Professional 7 Reporter, Certified Realtime Reporter and Notary 8 Public within Colorado. 9 * * * * * * * I N D E X 10 11 VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II 12 EXAMINATION 13 By Ms. Menninger PAGE 354 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 350 Agren Document Blando Court Reporting 2628248, & Video, Page15 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 INDEX OF EXHIBITS (continued) 2 INITIAL REFERENCE 3 DESCRIPTION 4 Exhibit 1 Settlement Agreement and General Release 355 Exhibit 2 List of names 370 Exhibit 3 Photocopy of photograph 408 Exhibit 4 Photocopy of photograph, with attachments 411 Exhibit 5 Photocopy of photograph, with attachments 417 Exhibit 6 Photocopy of photograph, with attachments 423 12 Exhibit 7 Statements 437 13 Exhibit 8 History of education, with attachment 462 Exhibit 9 Application for Employment, with attachment 474 Exhibit 10 The Great Outdoors Community Services Association, Inc. Termination Form, with attachments 481 Exhibit 11 7/6/2016 letter to Schultz from Hayek, with attachments 484 Exhibit 12 Patient Registration Information, with attachments 490 Exhibit 13 CVS Prescription Records document, 7/29/2016, with attachment 502 Exhibit 14 Affidavit of Custodian of Records, Walgreen Company, with attachments 507 5 6 7 8 9 10 11 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 351 Agren Document Blando Court Reporting 2628248, & Video, Page16 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 INITIAL REFERENCE DESCRIPTION 2 Exhibit 15 Patient Health Summary, Clifton Beach Medical & Surgical, printed on 6/28/2016 512 Exhibit 16 Portions of deposition transcript of Virginia Giuffre taken May 3, 2016 533 Exhibit 17 Amendment/Errata Sheet signed May 31, 2016 by Virginia Giuffre 540 8 Exhibit 18 Ad for Mar-a-Lago Club 548 9 Exhibit 19 The Mar-a-Lago Club, L.C. Employment Policies, October 28, 1995 549 Exhibit 20 Page from the Mar-a-Lago Club Employment Policies, Revised 10/2001 550 3 4 5 6 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 352 Agren Document Blando Court Reporting 2628248, & Video, Page17 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 didn't see them take pictures of the backs of them. 2 I'm not too sure who. 3 Q You don't remember sending to them a 4 photograph that included this wood around another 5 photograph? 6 A No. 7 Q Okay. 8 You have mentioned a journalist by the name of Sharon Churcher. 9 A Yes. 10 Q You are aware that Sharon Churcher 11 12 published news stories about you? A Yes. 13 MS. MCCAWLEY: 14 Go ahead. 15 Q Objection. (BY MS. MENNINGER) Is anything that you 16 have read in Sharon Churcher's news stories about you 17 untrue? 18 A I think Sharon did print some things that 19 I think she elaborated or maybe misheard. 20 mean, if you have a specific document to show me, I'd 21 love to look at it and read it and tell you what I 22 think. 23 Q But, I Is there anything, as you sit here today, 24 that you know of that Sharon Churcher printed about 25 you that is not true? VIRGINIA GIUFFRE VOLUME II 11/14/2016 435 Agren Document Blando Court Reporting 2628248, & Video, Page18 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 A Not off the top of my head. If you show 2 me, like, a news clipping article or something, I can 3 definitely read it for you. 4 Q Is there anything that you know of that 5 Sharon Churcher has printed about Ghislaine Maxwell 6 that is not true? 7 8 9 A No, not off -- no, not off the top of my head. Q Is there anything that you recall saying 10 to Sharon Churcher that she then printed something 11 different than what you had said to her? 12 A Yeah, I've read stuff. I mean, I just -- 13 I can't remember what, but I read something that I 14 think was, Oh, she got that wrong. 15 an exact example off the top of my head. 16 17 18 Q I can't remember Did you ever complain to Sharon Churcher about things that she got wrong? A I didn't see a point. I might have, but 19 I -- I didn't see a point really because it's already 20 printed, you know. 21 Q You had a fairly voluminous set of 22 communications with Sharon Churcher by e-mail, 23 correct? 24 25 MS. MCCAWLEY: A Objection. Voluminous, like a lot of them? VIRGINIA GIUFFRE VOLUME II 11/14/2016 436 Agren Document Blando Court Reporting 2628248, & Video, Page19 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Q (BY MS. MENNINGER) 2 A Yes. 3 Q And during any of those communications, do Yes. 4 you know whether she printed things about you after 5 you had any of those communications? 6 7 A MS. MCCAWLEY: Objection. I don't know. I know a lot of stuff was 8 printed, and I never really stopped to read who 9 printed the article, or wrote the article, I should 10 11 12 say. Sorry. Q (BY MS. MENNINGER) I'll show you Defendant's Exhibit 7. 13 (Exhibit 7 marked.) 14 THE DEPONENT: 15 Okay. Q Thank you. (BY MS. MENNINGER) I'll let you read 16 through the statements on the first page there, and 17 if there is anything that is not absolutely true, 18 just put a check by it and we'll come back to it. 19 A It's not very clear how she wrote it. "I 20 flew to the Caribbean with Jeffrey and then Ghislaine 21 Maxwell went to pick up Bill in a huge black 22 helicopter that Jeffrey had bought her." 23 That wasn't an eyewitness statement. 24 Like, I didn't see her do it. 25 who told me about that; that she's the one who flew Ghislaine was the one VIRGINIA GIUFFRE VOLUME II 11/14/2016 437 Agren Document Blando Court Reporting 2628248, & Video, Page20 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 Bill. Q All right. If you just want to put a 3 check by it, then we'll just come back and talk about 4 each one. 5 A Okay. 6 Q Just to move things along. 7 A Okay. 8 Q All right. 9 I have made three checkmarks. MS. MCCAWLEY: And I just -- before you 10 continue, I just want to identify for the record, 11 since this doesn't have any identifiers on it, are 12 you representing that these are statements from 13 Sharon Churcher? 14 MS. MENNINGER: 15 anything. 16 these statements. 17 not true. 18 19 20 Q I'm not representing I'm asking the witness questions about I asked her is anything on here That's all I asked her. (BY MS. MENNINGER) So which ones did you put checkmarks by, Ms. Giuffre? A I'd have been -- I'm sorry. "I'd have 21 been about 17 at the time. 22 with Jeffrey and then Ghislaine Maxwell went to pick 23 up Bill in a huge black helicopter that Jeffrey had 24 bought her." 25 Q Okay. I flew to the Caribbean And what else did you put a check VIRGINIA GIUFFRE VOLUME II 11/14/2016 438 Agren Document Blando Court Reporting 2628248, & Video, Page21 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 by? 2 A "I used to get frightened flying with her 3 but Bill had the Secret Service with him and I 4 remember him talking about what a good job" -- 5 sorry -- "job she did." 6 7 Q Okay. A "Donald Trump was also a good friend of by? 8 9 And what else did you put a check Jeffrey's. He didn't partake in any sex with any of 10 us but he flirted with me. 11 Jeffrey, 'you've got the life.'" 12 13 Q He'd laugh and tell Other than the three you've just mentioned -- 14 A Yeah. 15 Q -- everything else on here is absolutely 16 accurate? 17 MS. MCCAWLEY: 18 19 A Yes. Objection. Well, to the best of my recollection, yes. 20 Q (BY MS. MENNINGER) All right. What is 21 inaccurate about, "I'd have been about 17 at the 22 time. 23 Ghislaine Maxwell went to pick up Bill in a huge 24 black helicopter that Jeffrey had bought her"? 25 I flew to the Caribbean with Jeffrey and then A Because it makes it kind of sound like an VIRGINIA GIUFFRE VOLUME II 11/14/2016 439 Agren Document Blando Court Reporting 2628248, & Video, Page22 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 3 4 eyewitness thing. Q Okay. Did you say that statement to Sharon Churcher? A I said to Sharon that Ghislaine told me 5 that she flew Bill in the heli- -- the black 6 helicopter that Jeffrey bought her, and I just wanted 7 to clarify that I didn't actually see her do that. 8 heard from Ghislaine that she did that. 9 Q You heard that from Ghislaine, and then 10 you reported to Sharon Churcher that you had heard 11 that from Ghislaine. 12 A 13 14 Correct. MS. MCCAWLEY: A Objection. I heard a lot of things from Ghislaine 15 that sounded too true -- too outrageous to be true, 16 but you never knew what to believe, so... 17 Q (BY MS. MENNINGER) Okay. And after 18 Sharon Churcher printed what she said you said, did 19 you complain to her that it was inaccurate? 20 A I might have verbally with her, but again, 21 I didn't see a point in making a hissy over it 22 because what was done was done. 23 printed. 24 25 Q I She had already What was inaccurate about, "I used to get frightened flying with her but Bill" said -- "had the VIRGINIA GIUFFRE VOLUME II 11/14/2016 440 Agren Document Blando Court Reporting 2628248, & Video, Page23 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Secret Service with him and I remember him talking 2 about what a good job she did"? 3 A I just don't remember saying that to her. 4 I don't remember saying I remember him talking about 5 what a good job she did. 6 Q All right. 7 A I just don't remember that at all. 8 Q Okay. 9 And I guess, just to be clear, my questions wasn't do you remember saying this to 10 Sharon Churcher; my question is, is that statement 11 accurate? 12 13 14 MS. MCCAWLEY: Q (BY MS. MENNINGER) A Yes. 16 Q Okay. 18 19 20 21 Did you used to get frightened flying with her? 15 17 Well, objection. Did Bill have the Secret Service with him? A They were there, but not like on the -- not where we were eating. Q Do you remember Bill talking about what a good job she did? 22 A I don't remember that. 23 Q So what is inaccurate about that 24 25 statement? A I just -- it's inaccurate because I don't VIRGINIA GIUFFRE VOLUME II 11/14/2016 441 Agren Document Blando Court Reporting 2628248, & Video, Page24 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 remember him talking about what a good job she did. 2 I don't remember that. 3 4 Q Does it inaccurately suggest that Bill had the Secret Service with him on a helicopter? 5 6 MS. MCCAWLEY: A Objection. Well, not being an eyewitness to it, I 7 wouldn't be able to tell you. 8 I don't know. 9 10 11 Q (BY MS. MENNINGER) I can't tell you what And do you believe you said that statement to Sharon Churcher? A I mean, Sharon and I talked a lot, and if 12 she misheard me or just wrote it in the way that she 13 thought she should, I have no control over that. 14 I'm not too sure. 15 Q Did she record your interviews? 16 A Some of them. So Some of them she didn't. 17 mean, we, like -- we, like, met for like a week, and 18 we spent a lot of time together, and then even after 19 that we just continued, like, kind of a friendship. I 20 21 Q All right. last statement on that page? 22 A 23 Jeffrey's." 24 25 What's inaccurate about the "Donald Trump was also a good friend of That part is true. "He didn't partake in any" of -- "any sex with any of us but he flirted with me." VIRGINIA GIUFFRE VOLUME II 11/14/2016 It's true 442 Agren Document Blando Court Reporting 2628248, & Video, Page25 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 that he didn't partake in any sex with us, and but 2 it's not true that he flirted with me. 3 never flirted with me. 4 Then the next sentence is, "He'd laugh and 5 tell Jeffrey, 'you've got the life.'" 6 that to her. 7 8 Donald Trump Q I never said When you say, "he didn't partake in any sex with any of us," who is "us"? 9 A Girls. 10 Q How do you know who Donald Trump -- Trump 11 12 Just -- had sex with? A Oh, I didn't physically see him have sex 13 with any of the girls, so I can't say who he had sex 14 with in his whole life or not, but I just know it 15 wasn't with me when I was with other girls. 16 17 18 19 Q And who were the other girls that you were with in Donald Trump's presence? A None. There -- I worked for Donald Trump, and I've met him probably a few times. 20 Q When have you met him? 21 A At Mar-a-Lago. My dad and him, I wouldn't 22 say they were friends, but my dad knew him and they 23 would talk all the time -- well, not all the time but 24 when they saw each other. 25 Q Have you ever been in Donald Trump and VIRGINIA GIUFFRE VOLUME II 11/14/2016 443 Agren Document Blando Court Reporting 2628248, & Video, Page26 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Jeffrey Epstein's presence with one another? 2 A No. 3 Q What is the basis for your statement that 4 Donald Trump is a good friend of Jeffrey's? 5 6 A Jeffrey told me that Donald Trump is a good friend of his. 7 Q But you never observed them together? 8 A No, not that I can actually remember. 9 I mean, not off the top of my head, no. 10 Q When did Donald Trump flirt with you? 11 A He didn't. 12 Q Did you ever see Donald Trump at Jeffrey's 13 That's what's inaccurate. home? 14 A Not that I can remember. 15 Q On his island? 16 A No, not that I can remember. 17 Q In New Mexico? 18 A No, not that I can remember. 19 Q In New York? 20 A Not that I can remember. 21 Q All right. If you could turn to the 22 second page and read through those. 23 any of those are inaccurate. 24 them and then we'll come back. 25 A Let me know if Just put a check by Okay. VIRGINIA GIUFFRE VOLUME II 11/14/2016 444 Agren Document Blando Court Reporting 2628248, & Video, Page27 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 MS. MCCAWLEY: Before you go, Virginia, 2 I'm going to object to the use of the second page of 3 this document. 4 no source reference to it, so it's entirely unclear 5 where this has come from. There's no time frame on it. 6 Q (BY MS. MENNINGER) 7 A Yes. 8 Q Okay. 9 10 Okay. There's Are you done? What's the first one you've put a check by? A "The hammock photo was all over the 11 houses," in parentheses. 12 sorry, "Bill Clinton and Andrew," in parentheses, 13 "had to have seen it." 14 And Bill Clinton and -- I'm "All over the houses" is not my statement 15 and an exaggeration. 16 the houses. 17 conversation correctly, she asked, Could have Bill 18 Clinton and Andrew seen the picture? 19 Yes, it's possible that they could have seen it. 20 They did have that picture in And I believe, if I remember the And I said, So, I mean, it's just that -- it's not 21 that it's totally inaccurate. 22 journalist writing, had to have seen it. 23 mean they saw it. 24 front of them, they would have seen it. 25 Q I just think it's like It doesn't I just think that if it was in So she told you that -- you told her that VIRGINIA GIUFFRE VOLUME II 11/14/2016 445 Agren Document Blando Court Reporting 2628248, & Video, Page28 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 the photograph was in the houses -- houses? 2 A Yes. I know he had it in New York on his 3 desk. 4 it in the Caribbean. 5 in New Mexico. I know he had it in Palm Beach. I know he had And I don't know if he had it I can't remember New Mexico. Maybe. 6 Q Where in Palm Beach was the photograph? 7 A The massage room. 8 Q Was that -- you did not say that they -- 9 10 11 12 13 14 it was all over the houses? A Correct. All over the houses would imply that it's everywhere in the house, so... Q You did not say that Andrew and Clinton had to have seen the photograph? A Correct. I -- it was more of a, if they 15 were in front of it, they would have seen it, kind of 16 a thing. 17 like, had to have seen it. 18 19 20 21 Q All right. But it wasn't, What's the next statement that you put a check by? A I'm sorry, excuse me. My kids shared a beautiful cough with me again. 22 23 I'm not saying it right. "I spent four years as a millionaire's personal masseuse." 24 Q What is inaccurate about that statement? 25 A We now know, according to the timelines VIRGINIA GIUFFRE VOLUME II 11/14/2016 446 Agren Document Blando Court Reporting 2628248, & Video, Page29 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 that Mar-a-Lago was able to provide for us, that it 2 was not four years. 3 Q How many years was it? 4 A More like 2-1/2, I think, if I'm right, or 5 two. 6 the two period. 7 8 I'm sorry, I'm really bad at math. Q But yes, What's the next statement that you have put a check by? 9 A "I was a pedophile's dream." I think she 10 took that out of context and made that her own little 11 headline. 12 Q Did you say that to her? 13 A I said something along the line like, I -- 14 the -- the pedos loved me because I would do 15 everything that they wanted for them. 16 that -- yeah, I -- I know she made that line up 17 herself, the pedos -- pedophile's dream. But do I think 18 Q What's the next one you put a check by? 19 A I put a question mark next to the next 20 one. 21 with her family." 22 to. 23 24 25 It says, "Three years later she was reunited I don't know what that pertains I don't know what timeline that means. Q Was there a period of three years where you were not with your family? A There's been longer periods than that VIRGINIA GIUFFRE VOLUME II 11/14/2016 447 Agren Document Blando Court Reporting 2628248, & Video, Page30 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 that -- when I wasn't with my family. 2 mean, I don't understand where that comes from. 3 "Three years later she was reunited with her family." 4 5 Q Prior to 2002, was there a period of three years where you were not with your family? 6 A No. 7 Q Okay. 8 9 10 11 12 That's what I Did you say to Sharon Churcher, three years later, she was reunited with her family? A That's what I don't understand. I don't even know what that time periods pertains to. Q Do you recall saying that to Sharon Churcher? 13 A No. 14 Q What's the next one you put a check by? 15 A "After about two years he started to ask 16 me to entertain his friends." 17 Q What's wrong with that statement? 18 A It wasn't two years. 19 I don't know where she got that from. 20 Q Okay. 21 A Like, I can't give you an exact time How long was it? 22 period, but it wasn't right in the beginning. 23 after my training, or so to speak training. 24 mean, my best guesstimate would be anywhere between 25 four to six months. VIRGINIA GIUFFRE VOLUME II 11/14/2016 It was So, I 448 Agren Document Blando Court Reporting 2628248, & Video, Page31 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Q So you did not say to Sharon Churcher, 2 "After about two years he asked me to entertain his 3 friends"? 4 A Correct. 5 Q What's the next one you put a check by? 6 A That's it. 7 8 9 10 11 12 That's all I put a checkmark next to. Q So the rest of these are absolutely accurate? A Nothing a journalist writes is absolutely accurate, but it's -- it sounds accurate, yes. Q Do you recall Jeffrey Epstein saying to 13 you, "I've got a good friend and I need you to fly to 14 the island to entertain him, massage him and make him 15 feel how you make me feel"? 16 MS. MCCAWLEY: 17 Go ahead. 18 A Objection. I do remember him saying that, and I think 19 that's more of a general- -- generalization for all 20 the times that I was sent to the -- where is this -- 21 the island to entertain people. 22 quote that she made but from my words saying that's 23 what he said to me when I had to go be with these 24 people that he sent me to. 25 Q (BY MS. MENNINGER) And that would be a Did you say that VIRGINIA GIUFFRE VOLUME II 11/14/2016 449 Agren Document Blando Court Reporting 2628248, & Video, Page32 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 sentence to her? 2 MS. MCCAWLEY: 3 4 A Objection. I -- I can't remember. Like I said, I think it's more of a generalization. 5 Q (BY MS. MENNINGER) 6 A Yes. 7 Q Did you meet Heidi Klum? 8 A Yes. 9 Q Did you meet Naomi Campbell? 10 A Yes. 11 Q Did you go on a six-week trip with Epstein 12 Did you meet Al Gore? in 2001? 13 A Yeah. 14 Q When in 2001 did you go on a six-week trip 15 Yes. Sorry. with him? 16 A I don't remember exactly when it was, but 17 it's that -- it's the one where we went to Tangier, 18 Morocco, England. 19 went. 20 I can't remember where else we France. Q Did the FBI tell you that Epstein had 21 hidden cameras watching you the entire time, even 22 when you were in the bathroom? 23 A Yes. 24 Q Did the FBI tell you "Everything he did 25 was illegal because I was under age"? VIRGINIA GIUFFRE VOLUME II 11/14/2016 450 Agren Document Blando Court Reporting 2628248, & Video, Page33 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 A Yes. 2 Q Who in the FBI told you that? 3 A Whichever agent I was talking to. 4 Q Which agent were you talking to? 5 A I can't remember. I know I was talking to 6 Jason Richards, and there was a girl, I think -- I 7 want -- I want to say her name was Christina Pryor, 8 just off the top of my head. 9 was two other agents actually at the consulate 10 building. And then I think there I don't remember their names. Very hazy. 11 Q When was this conversation with the FBI? 12 A After Sharon printed the articles, the 13 first articles that came out. 14 she printed, but when the first articles came out, 15 after that the FBI contacted me. 16 Q I don't know how many And was the statement that the FBI told 17 you "Everything he did was illegal because I was 18 under age," in response to you telling them that you 19 were age 15 when you met Jeffrey? 20 21 22 MS. MCCAWLEY: A Objection. Well, that was the closest proximity I had to go off of. 23 Q (BY MS. MENNINGER) 24 A So, yes. 25 Okay. Although I still was under age, I mean, even if I was 16 and 17. VIRGINIA GIUFFRE VOLUME II 11/14/2016 451 Agren Document Blando Court Reporting 2628248, & Video, Page34 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Q Okay. And then if you could do the last 2 page, same way; a check by anything that's not 3 absolutely accurate. 4 MS. MCCAWLEY: Okay. I'm going to object 5 to this as the last page has no identifier of time or 6 source on it. 7 A Okay. 8 Q (BY MS. MENNINGER) 9 10 I'm ready. All right. Which ones are inaccurate? A The first one is, "Virginia got a 11 part-time job as a changing room assistant." 12 full-time person there. I was a Sorry. 13 Q Okay. 14 A Again, I don't remember that exact So did you say that to Sharon? 15 conversation, but I know it was a full-time job, 16 and -- I mean, full-time as in the, you know, the 9 17 to 5 or whatever hours it was, so it wasn't 18 part-time. 19 that we had. 20 21 22 Q I don't remember the exact conversation Okay. What's the next thing you put a check by? A I put a question mark next to, "Another 23 lady led me into Jeffrey's bedroom. 24 me straight through into the massage room." 25 The lady walked I have no idea what circumstance that VIRGINIA GIUFFRE VOLUME II 11/14/2016 452 Agren Document Blando Court Reporting 2628248, & Video, Page35 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 pertains to. 2 don't even know what other lady she's talking about. 3 So... 4 5 Q Again, I don't know what that means. So you don't recall saying that to Sharon Churcher? 6 A Correct. 7 Q Okay. 8 I I don't even know what it means. What's the next one you have a check by? 9 A "Afterwards, she was given two $100 bills 10 and told to return the next day. 11 beginning of the four years she spent with Epstein." 12 13 Q All right. That was the What's wrong about that statement? 14 A Well, again, I just want to say that the 15 four years was inaccurate based upon memory and not 16 an actual timeline that we were able to get. 17 18 Q Did you say that to Sharon Churcher, that it was four years? 19 A I don't know if I said that to her or -- 20 oh, yeah, did I tell her it was four years? 21 did. Yes, I I'm sorry. 22 Q Okay. 23 A Well, this one is a question mark again. What else did you put a check by? 24 "Radar online has obtained exclusive diary entries of 25 a Teen Sex Slave." VIRGINIA GIUFFRE VOLUME II 11/14/2016 453 Agren Document Blando Court Reporting 2628248, & Video, Page36 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 It wasn't really a diary. It was, like, I 2 don't know how many pages of something that I wrote, 3 and Sharon used it, so... 4 Q 5 entry? 6 A She knew it wasn't a diary entry. 7 Q Okay. 8 A Yes. 9 Q What's the next one you have a checkmark A "I also saw Prince Andrew at a Ranch in 10 11 12 Did you tell Sharon it was your diary No. Were you a teen sex slave? by? New Mexico." 13 Q Did you tell that to Sharon Churcher? 14 A No. And I think it's a mistake. Maybe 15 she meant somewhere else, but because we had been 16 talking about so much, maybe she just put New Mexico. 17 I don't think Sharon intentionally lied on any of 18 these. 19 period of a week, and then after that we had phone 20 conversations, and so on and so forth, that some of 21 the information just got misheard or mishandled, or 22 whatever. I just -- I think we talked so much over a 23 Q And what was printed was inaccurate? 24 A Was that printed? 25 I don't -- I don't remember reading that in the papers, but if it was VIRGINIA GIUFFRE VOLUME II 11/14/2016 454 Agren Document Blando Court Reporting 2628248, & Video, Page37 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 3 4 printed it's inaccurate. Q Do you recall reading any of the ones that you put a checkmark by in the papers? A There's been so much printed, it's hard 5 for me to remember. 6 stuff I read before. 7 8 Q I mean, yes, it does sound like When you spoke with Sharon Churcher, you agreed to waive your anonymity, right? 9 A I did. 10 Q Why did you agree to do that? 11 A I felt it was time for me to tell my 12 story. 13 forward. 14 that it would be good for other people to hear what's 15 going on, how it's happening, how vulnerable other 16 girls can be and not even know the damage that it 17 causes later in life. 18 the right thing to do to come forward. I felt it was a good time for me to come I had done so much healing, and I thought And I just thought it would be 19 Q You authorized her to publish your name? 20 A I did. 21 Q And your photograph? 22 A Yes. 23 Q In 2011? 24 A I think that was the year, yes. 25 Q You posed for photographs with her, VIRGINIA GIUFFRE VOLUME II 11/14/2016 455 Agren Document Blando Court Reporting 2628248, & Video, Page38 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 I, VIRGINIA GIUFFRE, do hereby certify that 2 I have read the foregoing transcript and that the 3 same and accompanying amendment sheets, if any, 4 constitute a true and complete record of my 5 testimony. 6 ____________________________ Signature of Deponent 7 ( ) No amendments ( ) Amendments attached 8 9 10 11 Acknowledged before me this _______ day of _____________, 20___. 12 13 Notary Public: ___________________ 14 My Commission Expires: ___________ 15 Seal: 16 PJH 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 562 Agren Document Blando Court Reporting 2628248, & Video, Page39 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 STATE OF COLORADO) 2 ) 3 COUNTY OF DENVER ) 4 ss. REPORTER'S CERTIFICATE I, Pamela J. Hansen, do hereby certify that 5 I am a Registered Professional Reporter and Notary 6 Public within the State of Colorado; that previous to 7 the commencement of the examination, the deponent was 8 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 19 20 In witness whereof, I have affixed my signature this 23rd day of November, 2016. My commission expires September 3, 2018. 21 22 23 _______________________________ Pamela J. Hansen, CRR, RPR, RMR 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 VIRGINIA GIUFFRE VOLUME II 11/14/2016 563 Case 18-2868, Document 286, 08/09/2019, 2628248, Page40 of 55 Epstein did invite two young brunettes to a dinner which he gave on his Caribbean island for Mr. Clinton shortly after he left of?ce. I'd have been about 17 at the time. I ?ew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her. I remember she was very excited because she got her license around the ?rst year we met. I I used to get frightened ?ying with her but Bill had the secret service with him and I remember him talking about what a good job she did. I don't remember seeing Bill again on the trip but I assume Ghislaine ?ew him back. Virginia disclosed that Mr. Clinton's vice-president Al Gore and his wife, Tipper, were also guests of Epstein on his island. Virginia said that yet another American liberal icon, Senator George Mitchell, frequently visited Epstein?s New York residence. Mr. Mitchell, aged 77, was very close to Jeffrey, Virginia recalled. I also met Naomi Campbell at a birthday party of hers on a yacht in the South of France. She is a friend of Ghislaine's but she was a real bitch to me. 1 Donald Trump was also a good friend of effrey's. He didn't partake in any sex with any of us but he ?irted with me. He'd laugh and tell Jeffrey, ?you?ve got the life.? $7 ft 'n74/4M~ AGREN BLANDQ P0 if}; Case 18-2868, Document 286, 08/09/2019, 2628248, Page4l of 55 Ghislaine took nude picture of me lying naked in a hammock, posed with my legs open, a bit provocatively that I gave to Jeffrey for his birthday. The hammock photo was "all over the houses? and Bill Clinton and Andrew "had to have seen" 4 it. I spent four years as millionaire's personal masseuse. I was living on the streets, beaten up and slept with at least two older men in return for food. While on the streets, I slept with men for money. I was a paedophile?s dream. KL Three years later she was reunited with her family. After about two years, he started to ask me to 'entertain' his friends. She recalls he said ?I?ve got a good friend and I need you to ?y to the island to entertain him, massage him and make him feel how you make me feel.? The way it usually worked was I'd been sent to meet a man on the private island Jeffrey owned in the Caribbean, or at his ranch in New Mexico, which was really isolated. I met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. She was, she says, delighted when Epstein invited her to accompany him on a six-week trip in 2001. FBI told me that Epstein had hidden cameras watching me the entire time even when I was in the bathroom. I was so embarrassed. The FBI told me everything he did was illegal because I was under age. Case 18-2868, Document 286, 08/09/2019, 2628248, Page42 of 55 Virginia got a part~time job as a changing room assistant. I told Ghisla-ine I wanted to become a masseuse and she said she worked for a very wealthy gentleman who was looking for a traveling masseuse. I?d get training and be paid well. (-3, Another lady led me into Jeffrey's bedroom. The lady walked me straight through into the a massage room. Afterwards, she was given two $100 bills and told to return the next day. That was the beginning of the four years she spent with Epstein. Radar Online has obtained exclusive "Diary entries" of "Teen Sex Slave". I led Prince Andrew into the upstairs bathroom next to the room I was staying in. I was doing my best trying to put on a good show for him by slowly undressing and started to pour a bath. He was caressing every part of my naked body and ?lling my head with endless compliments about my blossoming ?gure. He paid careful attention to my toes and was licking them. 1 I also saw Prince Andrew at the Ranch in New Mexico. Case 18-2868, Document 286, 08/09/2019, 2628248, Page43 of 55 EXHIBIT QQ 2628248, Page44 of 55 Sent: Fri 55/20/2011 2:20:09 AM Importance: Normal Subject: How ya doing?? Received: Fri 5/20/2011 2:20:09 AM Hi Buddy, I hope you are stopping to smell the daffodils once in a while and having a good day!! I am so excited today because I ca] go sign with an agent as my contract is finished with "Mail On Sandra and I have been working really hard to get me ready for my trip to the US in a few weeks and I was wondering if I could use your advice again. She has got an agent who is interested in speaking with me and I don?t want to say "Yes" to the first bite because I?m not su what to look for in an agent. What could you recommend that I do? I will send Jarred and Irene (your recommended agen a copy of the synopsis and sample chapters but how do I choose the right one for "The Story"? Do you know anyone else that might be interested in this as well? If so, i am keen on speaking with anyone who might be. I am excited about this and will keep you updated with the progressing events. When I am in New York we have to meet up for some city shopping and take the kids to Central Park to see the Zoo, given there will be no masturbating kangaroo's for you to make friends with, but who know's? I am looking forward to showing Robbie around and he's got some family out there 2 well we have to catch up with. Such busy times, but I?m loving it!! Anyways I hope your taking care and catch me up on your fun times?! Take care, Jenna CONFIDENTLAL GIUFFRE003959 Case 18-2868, Document 286, 08/09/2019, 2628248, Page45 of 55 EXHIBIT RR Agren Document Blando Court Reporting 2628248, & Video, Page46 Inc. Case 18-2868, 286, 08/09/2019, of 55 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No. 15-cv-07433-RWS __________________________________________________ CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May 3, 2016 __________________________________________________ VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. By Brad Edwards, Esq. 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954.524.2820 brad@pathtojustice.com Appearing on behalf of the Plaintiff BOIES, SCHILLER & FLEXNER LLP By Sigrid S. McCawley, Esq. (For Portion) 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 Phone: 954.356.0011 smccawley@bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE 5/3/2016 1 Agren Document Blando Court Reporting 2628248, & Video, Page47 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 3 4 5 6 APPEARANCES: (Continued) HADDON, MORGAN AND FORMAN, P.C. By Laura A. Menninger, Esq. Jeffrey S. Pagliuca, Esq. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 lmenninger@hmflaw.com jpagliuca@hmflaw.com Appearing on behalf of the Defendant 7 8 Also Present: Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 2 Agren Document Blando Court Reporting 2628248, & Video, Page48 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Pursuant to Notice and the Federal Rules 2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF 3 VIRGINIA GIUFFRE, called by Defendant, was taken on 4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150 5 East 10th Avenue, Denver, Colorado, before Kelly A. 6 Mackereth, Certified Shorthand Reporter, Registered 7 Professional Reporter, Certified Realtime Reporter 8 and Notary Public within Colorado. 9 * * * * * * * I N D E X 10 11 EXAMINATION PAGE 12 MS. MENNINGER 8 13 14 15 PRODUCTION REQUEST(S): (None.) 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 3 Agren Document Blando Court Reporting 2628248, & Video, Page49 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 INDEX OF EXHIBITS 2 3 INITIAL REFERENCE DESCRIPTION 4 Exhibit 1 Complaint and Demand for Jury Trial re Jane Doe No. 102 v. Jeffrey Epstein 17 Exhibit 2 Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in Action 21 Exhibit 3 Declaration of Virginia L. Giuffre re Jane Doe #1 and Jane Doe #2 vs. United States of America 23 Exhibit 4 Declaration of Jane Doe 3 re Jane Doe #1 and Jane Doe #2 vs. United States of America 31 Exhibit 5 Declaration of Virginia Giuffre re Bradley J. Edwards and Paul G. Cassell vs. Alan M. Dershowitz 33 Exhibit 6 FBI documentation, date of entry 7/5/13 36 Exhibit 7 Document titled Telecon, Participants Jack Scarola, Brad Edwards, Virginia Roberts. Re Edwards adv. Epstein, 4/7/11, (23 pages of transcription) 39 Exhibit 8 The Billionaire's Playboy Club, By Virginia Roberts 41 Exhibit 9 Plaintiff's Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff re Giuffre v. Maxwell 44 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 4 Agren Document Blando Court Reporting 2628248, & Video, Page50 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 INITIAL REFERENCE DESCRIPTION 3 Exhibit 10 Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff 46 Exhibit 11 Undated Declaration of Virginia Giuffre re Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests served on March 22, 2016 46 Exhibit 12 Plaintiff's Second Amended Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff 47 Exhibit 13 Mrs. Virginia Giuffre resume 67 Exhibit 14 Compilation of e-mails re Open Position - Virginia Giuffre 68 Exhibit 15 Virginia Lee Roberts passport application 180 Exhibit 16 Composite of e-mail strings 251 Exhibit 17 Compilation of e-mails between Giuffre and Silva and others 259 Exhibit 18 Compilation of e-mails between Virginia Giuffre and Sandra White 265 Exhibit 19 Compilation of e-mails between Marianne Strong and Virginia Giuffre 269 Exhibit 20 Compilation of e-mails between Virginia Roberts and Jason Richards 276 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 5 Agren Document Blando Court Reporting 2628248, & Video, Page51 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 2 INITIAL REFERENCE DESCRIPTION 3 Exhibit 21 Compilation of e-mails between Sharon Churcher and Virginia Giuffre Exhibit 22 Compilation of e-mails among 287 Sharon Churcher, Michael Thomas, Virginia Giuffre and others Exhibit 23 Compilation of May 2011 e-mails among Sharon Churcher, Virginia Giuffre, Paulo Silva and others Exhibit 24 Compilation of June 2011 e-mails 289 between Virginia Giuffre and Sharon Churcher Exhibit 26 PR Hub Statement on Behalf of Ghislaine Maxwell article 300 Exhibit 27 1/2/15 e-mail from Ross Gow to To Whom It May Concern 309 4 284 5 6 7 8 288 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 6 Agren Document Blando Court Reporting 2628248, & Video, Page52 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 Some names have been changed in order to protect 2 other people. 3 Q (BY MS. MENNINGER) 4 A Protect their privacy, yeah, I would say, Protect their privacy? 5 just not getting them involved in, if this were to 6 ever go public. 7 8 9 10 11 12 Q Well, again, without rereading the whole manuscript -A Reading it, yeah. I'm trying to see if I can -- see something in here. Q Let me narrow my question and maybe that will help. 13 A Yes. 14 Q Is there anything -- well, first of all, 15 did you author that entire manuscript? 16 A Yes, I did. 17 Q Did anyone else author part of that 18 manuscript? 19 A 20 Do you mean did anyone else write this with me? 21 Q Right. 22 A No. 23 Q That's all your writing? 24 A This is my writing. 25 Q Okay. To the best of your recollection, VIRGINIA GIUFFRE 5/3/2016 42 Agren Document Blando Court Reporting 2628248, & Video, Page53 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 as you sit here right now, is there anything in that 2 manuscript about Ghislaine Maxwell that is untrue? 3 4 A I don't believe so. Like I said, there is a lot of stuff that I actually have left out of here. 5 Q Um-hum. 6 A So there is a lot more information I could 7 put in there. 8 I would like to say that there is 99.9 percent of it 9 would be to the correct knowledge. 10 Q But as far as Ghislaine Maxwell goes, All right. Is there anything that you -- 11 and I understand you're doing this from memory. 12 there anything that you recall, as you're sitting 13 here today, about Ghislaine Maxwell that is contained 14 in that manuscript, that is not true? 15 A You know, I haven't read this in a very 16 long time. 17 here about Ghislaine Maxwell that is not true. 18 I don't believe that there's anything in MR. EDWARDS: I'd just ask, Counsel, if 19 you have anything specific to show her about 20 Ghislaine Maxwell -- 21 MS. MENNINGER: 22 MR. EDWARDS: 23 MS. MENNINGER: 24 MR. EDWARDS: 25 Is I'll ask questions. -- I'll have her look at it. I'll ask questions. I know, but I want the record clear that if she hasn't read it in a long VIRGINIA GIUFFRE 5/3/2016 43 Agren Document Blando Court Reporting 2628248, & Video, Page54 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 I, VIRGINIA GIUFFRE, do hereby certify that 2 I have read the foregoing transcript and that the 3 same and accompanying amendment sheets, if any, 4 constitute a true and complete record of my 5 testimony. 6 7 8 ________________________________ Signature of Deponent ( ) No Amendments ( ) Amendments Attached 9 10 11 12 Acknowledged before me this _____ day of ______________, 2016. 13 14 Notary Public: ________________________ 15 Address: _____________________________ 16 _____________________________ 17 My commission expires _________________ 18 Seal: 19 20 21 KAM 22 23 24 25 VIRGINIA GIUFFRE 5/3/2016 344 Agren Document Blando Court Reporting 2628248, & Video, Page55 Inc. Case 18-2868, 286, 08/09/2019, of 55 1 STATE OF COLORADO) 2 ) 3 COUNTY OF DENVER ) 4 ss. REPORTER'S CERTIFICATE 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 19 20 In witness whereof, I have affixed my signature this 11th day of May, 2016. My commission expires April 21, 2019. 21 22 23 ____________________________ Kelly A. Mackereth, CRR, RPR, CSR 216 - 16th Street, Suite 600 Denver, Colorado 80202 24 25 VIRGINIA GIUFFRE 5/3/2016 345