Virginia Giuffre Deposition May 2016

Case Document 1090-32 Filed 07/30/20 Page 1 of 89 EXHIBIT Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 2 of 89 GIUFFRE VS. MAXWELL Deposition VIRGINIA GIUFFRE 05/03/2016 _______________________________________________________________________ Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017 Agren Blando Court Reporting & Video, Inc. Page 3 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 1 IN THE UNITED STATES DISTRICT COURT Page 3 1 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. 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 GHISLAINE MAXWELL, Defendant. __________________________________________________ APPEARANCES: 11 12 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 ******* INDEX 10 EXAMINATION PAGE MS. MENNINGER 8 13 14 15 PRODUCTION REQUEST(S): (None.) 16 17 18 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 19 20 21 22 23 24 25 Page 2 1 2 3 4 5 6 7 8 9 APPEARANCES: (Continued) Page 4 INDEX OF EXHIBITS 1 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 Also Present: Brenda Rodriguez, Paralegal Nicholas F. Borgia, CLVS Videographer 2 3 4 5 6 7 8 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 DESCRIPTION INITIAL REFERENCE 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. 23 Giuffre re Jane Doe #1 and Jane Doe #2 vs. United States of America Exhibit 4 Declaration of Jane Doe 3 re 31 Jane Doe #1 and Jane Doe #2 vs. United States of America Exhibit 5 Declaration of Virginia Giuffre re Bradley J. Edwar ssell vs. 33 Exhibit 6 FBI documentation, date of entry 36 7/5/13 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 VIRGINIA GIUFFRE 5/3/2016 44 1 (1 - 4) Agren Blando Court Reporting & Video, Inc. Page 4 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 DESCRIPTION INITIAL REFERENCE Exhibit 10 Plaintiff's Supplemental Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff 46 THE VIDEOGRAPHER: We're on the record at 4 9 a.m. Today is May 3rd, 2016. This begins the 5 videotaped deposition of Virginia Giuffre in the 6 matter of Virginia L. Giuffre versus Ghislaine 7 Maxwell. We're located at 150 East 10th Street -- 8 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 PROCEEDINGS 2 3 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 Page 7 ******* 1 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 9 excuse me, 10th Ave., in Denver, Colorado. 10 Our court reporter is Kelly Mackereth. 11 The videographer is Nicholas F. Borgia, CLVS. Will counsel please introduce yourselves 12 13 for the record. MR. EDWARDS: Sure. Brad Edwards and 14 15 Sigrid McCawley on behalf of the plaintiff, 16 Ms. Giuffre. MS. MENNINGER: Laura Menninger and 17 18 Jeffrey Pagliuca on behalf of the defendant, 19 Ghislaine Maxwell. THE VIDEOGRAPHER: And will our court 20 21 reporter please swear in the deponent. VIRGINIA GIUFFRE, 22 25 23 being first duly sworn in the above cause, was 24 examined and testified as follows: MR. EDWARDS: Just before we get started, 25 Page 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 DESCRIPTION INITIAL REFERENCE Exhibit 21 Compilation of e-mails between Sharon Churcher and Virginia Giuffre 284 Exhibit 22 Compilation of e-mails among 287 Sharon Churcher, Michael Thomas, Virginia Giuffre and others Exhibit 23 Compilation of May 2011 e-mails 288 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 To Whom It May Conce 309 to Page 8 1 I just wanted to make sure that we're clear, and I 2 think that we are, that this deposition in total will 3 be treated as confidential until such time as we are 4 able to review and de-designate. 5 MS. MENNINGER: Yes. 6 MR. EDWARDS: Okay. EXAMINATION 7 8 BY MS. MENNINGER: 9 Q Good morning, Ms. Giuffre. 10 A Good morning, Laura. 11 Q Can you please state your full name? 12 A Virginia Lee Giuffre. Q And where do you live right now, 13 14 Ms. Giuffre? A 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 Q Okay. And who traveled with you? 25 25 A Myself. Q All right. And who lives with you there? A My son, my other son, my daughter, my husband and my in-laws. Q And when did you return to the U.S. for this visit? A I believe it was around Thursday, the 29th, I think. VIRGINIA GIUFFRE 5/3/2016 2 (5 - 8) Agren Blando Court Reporting & Video, Inc. Page 5 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 9 Page 11 under oath? 1 Q Yourself? 1 2 A Yes. 2 A 3 Q Are you able to travel freely between the 3 Q What does it mean to you? 4 A To tell the truth, the whole truth and 4 U.S. and Australia? Yes. nothing but the truth. 5 A Yes. 5 6 Q Are you married? 6 7 A Yes. 7 8 Q To whom? 8 A To be honest. 9 A 9 Q Is there more than one truth? 10 Q A Is there more than -- no, there's no more 11 All right. And did Mr. Giuffre travel with you back to the U.S.? 10 11 12 A No. 13 Q All right. Have you taken any medications 13 14 15 16 in the last 24 hours? A 14 I have taken -- I have a cold, but I have taken non-drowsy cold tablets and some DayQuil. 17 Q 18 A 19 Q 20 12 15 16 All right. And what does the word truth mean to you? than one truth. Q If you are confused by a question, you need to let me know that so I can clarify the question, okay? A Okay. Q For example, if I asked you the question All right. Anything else? 17 were you sexually trafficked to foreign presidents, No. 18 do you understand what that question means? All right. And what is your current 19 A Yes. 20 Q What does it mean? A Was I lent out for the purposes of sex to profession, Ms. Giuffre? 21 A I'm a housewife. 21 22 Q All right. And how long have you been a 22 23 Q housewife? 23 For the last ten years, since I've had a foreign person -- president. Q All right. And what is the answer to that question? 24 A 25 kids. 1 Q 2 in 2014? 2 presidents, do you understand what that question 3 A A housewife. 3 means? 4 Q All right. Any other profession? 4 A Yes. 5 A No. 5 Q And what is the answer to that question? Q All right. You understand that you're 6 A Yes. 7 Q All right. And if I asked you which 24 25 A Yes. 1 Q And if I ask you have you met any foreign Page 10 6 7 8 9 10 All right. And what was your profession under oath today? A Yes. Q And you understand that if you don't understand a question, you need to let me know that. Page 12 8 foreign presidents have you met, do you understand 9 what that question means? 10 A Yes. 11 A Okay. 11 Q What is the answer to that question? 12 Q And ask for clarification. 12 A What is the name of the person? 13 A Um-hum. 13 Q Yes. Who are the foreign presidents that 14 Q Do you understand? 14 15 A Yes. 15 16 Q You also understand, I'm assuming, that 16 17 you have to say yes or no in answer to a question, or 18 19 you have met? A I honestly can't remember his name at this time. I'm a very visual person so -Q All right. Can you describe him, then? you have to make a verbal response and not just shake 18 A Yes. He's Spanish. your head or something -- Q Okay. 17 19 20 A Yes. 20 A Tall, dark hair. 21 Q -- so the court reporter can get it. 21 Q All right. Anything else? And he's got a foreign tongue, accent. 22 A 23 correct? 23 Q And what age, approximately? 24 A Yes. 24 A Was I or was he? 25 Q Do you understand what it means to be 25 Q Was he. You have -- you have been deposed before, 22 VIRGINIA GIUFFRE 5/3/2016 3 (9 - 12) Agren Blando Court Reporting & Video, Inc. Page 6 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 13 Page 15 I'd say in his 40s. 1 A Q Okay. And where did you meet him? 2 Q And which ones did you review? A I believe it was New Mexico. 3 A I'd have to see which ones you're Q New Mexico? 4 specifically talking about. There's quite a lot of A statements I've made. 1 A 2 3 4 Yes. Possibly New Mexico. I'm sorry. It's 5 6 really hard to go back and remember lots of different 6 7 events with lots of different people. 7 having reviewed before you attended this deposition 8 today? 5 8 9 10 Q Okay. And is that the only foreign president that you have met? A 9 I've met a lot of very high, powerful Q A Right. And which ones do you recall I've reviewed my affidavit. I'm not a 10 lawyer so I really don't know legal terms to half of 11 people and I wasn't just introduced to them as who 11 the, you know, legal jargon of statements, which they 12 they were. It's only going back through photos in 12 are. If you showed me, I'd be able to tell you if 13 time to be able to realize who they are and what they 13 I've seen it or not. 14 are now. So it's hard for me to distinguish who I've 14 15 actually met and when and where I've met them. 15 identify any sworn statement you reviewed before 16 attending the deposition today? 16 17 Q So to your knowledge, you have only met one foreign president? Q 17 A Okay. So to your knowledge, can you Could I name what the statement is? 18 A To my knowledge at this time, yes. 18 Q Right. 19 Q And is there anything that might change 19 A The actual piece of paper that has the 20 your knowledge at a different time? A 20 If I were to see more photos of other title at the top? 21 Q Right. 22 people. I mean, I've been able to distinguish the 22 A No, I don't. 23 majority of the people I've been lent out to, but 23 Q Can you describe it in any other fashion? 24 who's to say there's not more. 24 A I don't understand. I'm sorry. 25 Q That's all right. You have to tell me if 21 25 Q All right. If I were to ask you the Page 16 Page 14 1 question how many times have you had sex with do you know what that question means? 2 3 4 5 Do you have any reason to believe that any 2 I believe so. 3 of your previous sworn statements that you have made Q All right. And what is the answer to that 4 are not true? question? 5 A I believe I was with 7 Q Okay. I would like to ask you about your once. A You understand you're under oath today, No. MR. EDWARDS: I just object and ask that 6 prior sworn statement. 9 7 if we're going to ask the witness questions about any 8 of her statements in whole or in part that the 9 witness be allowed to see the statement, review the correct? 10 11 A Yes. 11 12 Q All right. You've previously made 12 10 you don't. A 6 8 1 statement and then answer your questions. Q (BY MS. MENNINGER) You may answer the question. 13 A Can you reask the question? I'm sorry. 14 A Yes. 14 Q Do you have any reason to believe that any 15 Q And you've previously authorized pleadings 15 13 16 statements under oath, correct? to be filed on your behalf, correct? 17 A 18 19 16 Yes. 17 Q By various attorneys, right? 18 A Yes. 19 Q All right. You have included in your of your prior sworn statements are untrue? A I have no reason to believe that my prior statements are untrue. Q Has anyone told you to say something that was not true in connection with this case? 20 A No, ma'am. 21 sworn statement allegations about my client, 21 Q All right. I'd like to start with a 22 Ghislaine Maxwell, correct? 20 22 lawsuit that you filed under the caption Jane Doe 23 A Yes. 23 versus Jeffrey Epstein. 24 Q And did you review any of those prior 24 25 sworn statements before appearing here today? 25 Do you recall that lawsuit? A I believe so. VIRGINIA GIUFFRE 5/3/2016 4 (13 - 16) Agren Blando Court Reporting & Video, Inc. Page 7 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 19 Page 17 (Exhibit 1 marked.) 1 Q 1 (BY MS. MENNINGER) I'm going to show you Q No. I'm just -- did you find it? 2 A I can see paragraph 23. 3 an exhibit that we are marking as Defendant's 3 Q Okay. And do you see that there are 4 Exhibit 1. 4 allegations about a Ms. Maxwell contained in that complaint? 2 5 MR. EDWARDS: Can I see that for a second? 5 6 I'd just like to make an objection on the 6 7 record for the misidentification of this document. 7 8 While there was a lawsuit filed under the 8 style of Jane Doe versus Jeffrey Epstein, Jane Doe A Yes, I do. Q All right. And do you understand that to be Ghislaine Maxwell, my client? 9 A Yes. 10 was not Virginia Giuffre. And the lawsuit that's now 10 Q All right. And Ms. Maxwell was not sued 11 being handed to this witness is Jane Doe 102 versus 11 12 Jeffrey Epstein. 9 13 14 as a part of this case, correct? 12 MR. EDWARDS: Object to the form. Is that the document we're talking about? 13 THE DEPONENT: Does that mean I can MS. MENNINGER: Counsel, if you have an 14 answer? 15 objection, you should state the basis for your 15 MR. EDWARDS: Sure, you can answer. 16 objection in a non-leading, non-suggestive manner. 16 MS. MENNINGER: Right. 17 MR. EDWARDS: If you understand the If you have any other record to make, you 17 18 can do so in a pleading filed with the Court. 18 MR. EDWARDS: Sure. My objection is 19 question, answer it. 19 A Yes, Ms. Maxwell -- sorry, repeat the question. 20 you've misrepresented what you've handed the witness. 20 21 I want to make sure that the witness is holding what 21 Q 22 you actually want her to be holding as opposed to the 22 in this -- 23 lawsuit you said that you were going to hand her. (BY MS. MENNINGER) Was Ms. Maxwell sued 23 A No, she wasn't. 24 That's it. 24 Q -- in the case that's represented by 25 MS. MENNINGER: Counsel, I will ask the 25 Defendant's Exhibit 1? Page 18 Page 20 1 witness questions about the document. I did not ask 1 2 you any questions about the document. 2 interrupting you. But no, she was not sued at this 3 time, no. Q 3 Q (BY MS. MENNINGER) Ms. Giuffre, could you A No, she wasn't. I'm sorry for 4 please take a look at what we have marked as 4 5 Defendant's Exhibit 1. 5 MR. EDWARDS: I'd object and ask the 6 witness not answer that question because that would 7 be privileged, attorney-client privileged, 8 information that was between Ms. Giuffre and the 9 Podhurst Orseck firm at that time. Do you recognize that document, 6 7 8 9 Ms. Giuffre? A I believe so. Yes. Yes, I do. Q And do you see that the counsel on the And why not? 10 last page -- I'm sorry, not the last page, but the 10 11 third from the last page are Mr. Josefsberg and 11 12 Ms. Ezell from Podhurst Orseck? 12 Ms. Giuffre, did you make a decision yourself whether So I'm instructing you not to answer. Q (BY MS. MENNINGER) All right. 13 A Yes. 13 or not to sue Ms. Maxwell as a part of this lawsuit 14 Q Were those your lawyers? 14 against -- Jane Doe 102 versus Jeffrey Epstein? 15 A Yes, they were. 15 16 Q And did you authorize them to file Jane 16 17 Doe 102 versus Epstein on your behalf? 17 A I think I've been advised not to answer that question. Q This is a different question. 18 A Yes, I did. 18 A Oh, okay. 19 Q And is that this complaint that's been 19 Q So your counsel can assert a privilege, 20 21 22 marked as Defendant's Exhibit 1? 20 but that question did not call for privileged A I believe so. 21 information. Q In that document, if I could ask you to 22 MR. EDWARDS: I -- 23 turn to page -- well, I'll turn to page 9 and 23 24 paragraph 23. 24 -- what you decided to do. Whether you decided to 25 sue Ms. Maxwell or not at the time Jane Doe 102 25 A Would you like me to read it? Q (BY MS. MENNINGER) I'm asking about what VIRGINIA GIUFFRE 5/3/2016 5 (17 - 20) Agren Blando Court Reporting & Video, Inc. Page 8 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 21 1 versus Epstein was filed? MR. EDWARDS: And I disagree. And I 2 Page 23 1 2 CVRA action in or about December 30th, 2014, correct? A I -- I'm not aware of the exact dates. 3 object to this invading the attorney-client 3 There's no dates on this. But I did try to join the 4 privilege. 4 motion, yes. And I'm instructing you not to answer. 5 6 Q 5 (BY MS. MENNINGER) Can you answer that 6 Q All right. If you can look at the top line of the document. 7 question without revealing any attorney-client 7 A Yes. 8 communications, whether you made a decision to file a 8 Q Does it say, Entered on FLSD -- 9 lawsuit or not? 9 A Oh, it does, too, I'm sorry, yes. 10 Q That's all right. So does that refresh 10 11 12 A I'm going to have to listen to my attorney and not answer the question. Q All right. I would like to show you some 11 your memory as to about when you first sought to join 12 the CVRA action? 13 documents that were filed in what we'll call the CVRA 13 A 14 case, the Crime Victims' Rights Act case. 14 Q December 30th, 2014, correct? 15 A Yes. Q And the corrected motion was filed a few Do you know what I mean by that reference? 15 Yes. 16 A I am familiar with that. 16 17 Q Okay. I'm going to start with one on or 17 18 about December 30th, 2014. We will mark it as 18 A Yes, correct. 19 Defendant's Exhibit 2. 19 Q If I could turn to Defendant's Exhibit 3, 20 21 22 23 Q days later, correct? (Exhibit 2 marked.) 20 MR. EDWARDS: Thank you. 21 (Exhibit 3 marked.) 22 MR. EDWARDS: Thank you. (BY MS. MENNINGER) All right. Ms. Giuffre, do you recognize Defendant's Exhibit 2? 23 which was January 21st. Q 24 A Yes. 24 25 Q And what do you understand it to be? 25 A 1 A I believe this is when I was hoping to 1 Q (BY MS. MENNINGER) Do you recognize this document? Yes, I do. Page 22 2 3 4 join the CVRA case. Q 2 All right. And do you know when this document was filed? 3 4 And actually, just to be clear, about 5 Page 24 5 What do you understand this document to be? A It's a rough background of the years that I was abused by Ghislaine and Jeffrey. Q All right. And this is something I 6 halfway there's actually a second document that was 6 7 filed. So this is a composite exhibit. Let me be 7 A Just let me have a look. 8 very clear. 8 Q Sure. A I think I'm actually missing page 15. Oh, So after page 14 -- I'm sorry, 13, there's 9 9 believe that you on page 15 signed; is that true? 10 a second document that is styled Jane Doe #3 and Jane 10 11 Doe #4's Corrected Motion Pursuant to Rule 21 for 11 12 Joinder In Action. 12 top right. I apologize. I believe there was some 13 cover page or something that was excluded. Do you see that? 13 14 A 15 Q 17 18 19 22 23 Sorry. I'm looking at the numbers on the MR. EDWARDS: And just for the record, I'm 14 It is on the 14th page of this document. 15 going to object to the relevance of this document. 16 I'm going to allow the witness to answer the question, but I want my objection on the record. A I do. 17 Q And so this composite Exhibit 2 has both a 18 motion and a corrected motion. 19 Do you see that? MS. MENNINGER: Okay. Simple objection, relevance. 20 A Are we talking about this page? A Yes. 21 Q (BY MS. MENNINGER) Yes, the one with the Q And were both of those pleadings 22 black box, yes. Do you believe that to have 23 contained your signature? 20 21 Q Did you say page 14? Do you see that? 16 here we go. authorized by you to be filed? 24 A Yes. 24 A Yes. 25 Q In other words, you wanted to join the 25 Q All right. And you executed that on VIRGINIA GIUFFRE 5/3/2016 6 (21 - 24) Agren Blando Court Reporting & Video, Inc. Page 9 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 25 1 2 3 4 5 January 19th, 2015? A A 7 8 9 11 12 13 filed under oath is no longer true, correct? MR. EDWARDS: Object to the form. 2 3 The date it was filed. Is there a date just above the signature block? 6 10 At the very top of the page it says January 21st, 2015. Q Page 27 1 4 5 A I wouldn't say that it wasn't true. I was just unaware of the times and the dates. Q (BY MS. MENNINGER) Again, is there more than one truth, Ms. Roberts? Oh, yes, sorry. Yes, there is. 6 Q And what date -- what date was that? 7 A No, there's no more than one truth. A The 19th day of January, 2015. 8 Q All right. So a document in which you Q Okay. And this document is something that you believe contains the truth, correct? A To the best of my knowledge at the time, yes. Q 9 swore that you were 15 years old when you met 10 Ms. Ghislaine Maxwell is an untrue statement, 11 correct? MR. EDWARDS: Object to the form. 12 All right. Did something change between 13 A It's not that it's an untrue statement. 14 the time then and today that makes you believe that 14 It was a mistake. So it wasn't intentionally trying 15 it's not all accurate? 15 to say something that wasn't true. It was to my best Well, as you can see, in line 4 on page 1, 16 knowledge that I thought it was 1999. And when I got 17 I wasn't aware of my dates. I was just doing the 17 my records from Mar-a-Lago I was able to find out 18 best to guesstimate when I actually met them. 18 that it was 2000. And this was entered before I 19 found out the actual dates that I did work at Mar-a-Lago. 16 A Since then I've been able to find out that 19 20 through my Mar-a-Lago records that it was actually 20 21 the summer of 2000, not the summer of 1999. 21 Q (BY MS. MENNINGER) Okay. So a document Q Oh, I'm sorry. Are you back on page 1? 22 23 A On the first page. 23 A Um-hum. 24 Q Okay. 24 Q -- is now, you believe to be untrue, 25 A Yes. 25 correct? 1 Q And you're talking about line 4? 1 2 A Line 4. 2 3 Q Paragraph 4 or line 4? 3 A Oh, sorry. Number 4, the paragraph 4 22 that you filed under oath -- Page 26 4 5 6 7 8 number 4. Q In approximately -You can answer. 10 12 Okay. And what part of paragraph 4 do you MR. EDWARDS: Object to the form. 9 11 5 now believe to be untrue? A A Page 28 MR. EDWARDS: Objection. Asked and answered. Q MR. EDWARDS: Answer again. A In approximately 1999 when I was 15 years Again, I wouldn't say it's untrue. Untrue 6 would mean that I would have lied. And I didn't lie. 7 This was my best knowledge at the time. And I did my 8 very best to try to pinpoint time periods going back 9 such a long time ago. It wasn't until I found the facts that I 10 old I met Ghislaine Maxwell. (BY MS. MENNINGER) You may answer. 11 worked at Mar-a-Lago in 2000 that I was able to 12 figure that out. Q (BY MS. MENNINGER) And approximately when 13 Q (BY MS. MENNINGER) Okay. 13 14 A I now know that it was 2000, that I was 16 14 did you learn those facts about the dates you worked 15 at Mar-a-Lago? 15 16 years old when I met Ghislaine Maxwell. Q So when you signed this document under 16 A I would say it was mid-2015. Q Mid-2015 is the first time you became 17 penalty of perjury stating that it was true, you no 17 18 longer believe that to be true, correct? 18 19 A It was an honest mistake. We had no idea aware of the dates -- 19 A I don't know the exact -- 20 how to pinpoint without any kind of records or dates 20 Q If you could just let me finish. 21 or anything like that. I was just going back 21 A I'm sorry. 22 chronologically through time. And that's the best 22 Q That's all right. Approximately mid-2015 23 time that I thought it was. And now I know the 23 when you learned the true dates that you had worked 24 facts, so it's good to know. 24 at Mar-a-Lago? 25 Q So you now believe that a document you 25 A That's correct. Sorry. VIRGINIA GIUFFRE 5/3/2016 7 (25 - 28) Agren Blando Court Reporting & Video, Inc.Page 10 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 29 Q Page 31 And based on the fact that you learned the 1 2 fact you had worked at Mar-a-Lago in 2000 -- you 2 an exhibit filed on, I believe on or about 3 became aware in mid-2015 -- 3 February 6th of 2015. Defendant's Exhibit 4. 1 Q (BY MS. MENNINGER) I'm going to show you A Um-hum. 4 5 Q -- that you had met Ms. Maxwell in 2000, 5 6 correct? 6 7 A 7 attention to the heading line that says, Entered on 8 the docket February 6th, 2015. 4 That's -MR. EDWARDS: Object to the form. 8 9 A That's correct. 10 Q (BY MS. MENNINGER) All right. And you (Exhibit 4 marked.) MR. EDWARDS: Thank you. Q (BY MS. MENNINGER) And drawing your Do you see that? 9 10 A Yes. Q All right. And Declaration of Jane Doe 3, 11 became aware in mid-2015 that you were not 15 years 11 12 old when you met Ghislaine Maxwell, correct? 12 13 MR. EDWARDS: Object to the form. 13 14 A That's correct. 14 15 Q (BY MS. MENNINGER) Okay. And who 15 do you see that on the first page? A Yes. Q And it's in the CVRA case, correct, Jane Doe 1 and Jane Doe 2 versus United States of America? 16 provided you those Mar-a-Lago records in 16 A Yes. 17 approximately mid-2015? 17 Q All right. And do you recognize this 18 MR. EDWARDS: I'm going to object. 18 19 And to the extent that this invades the 19 A Yes. Q And what do you understand this document 20 attorney-client privilege, if it was your attorneys 20 21 that you spoke to and learned this information or 21 22 received this information from, then you're 22 23 instructed not to answer. 23 24 A I cannot answer that question. 24 25 Q (BY MS. MENNINGER) Did you yourself look 25 document? to be? A I believe it's more reason to why I should have been added to the CVRA case. MR. EDWARDS: Objection to the relevance, Counsel. Page 30 Page 32 1 at records in the middle of 2015 regardless of who 1 2 showed them to you? Q (BY MS. MENNINGER) Okay. And again, if 2 you look to the last page of the document, 3 MR. EDWARDS: Objection. And to the 3 paragraph 67 -- 4 extent that they were showed to you or shared by any 4 A The last page? 5 of your lawyers, you're instructed not to answer the 5 Q Yes, the very last. 6 question. It invades the attorney-client privilege. 6 A 67, yes. 7 Q All right. It says in paragraph 67: I 7 8 Q Mar-a-Lago records in the middle of 2015 yourself? MR. EDWARDS: She's not answering the 9 10 question. answering the question? 14 the attorney-client privilege. If she learned -I will instruct her if she learned by some 15 declare under penalty of perjury that the foregoing 9 is true and correct, right? 11 12 MR. EDWARDS: I just told you it invades 13 8 10 MS. MENNINGER: On what grounds is she not 11 12 (BY MS. MENNINGER) Did you look at And it was executed on or about the A like a 5. 15 16 17 with her, then she can answer the question. 17 (BY MS. MENNINGER) I'm asking you not to Q 5th day of February, 2015, correct? 14 other way than her attorneys sharing the information Q Yes. 13 16 18 A 18 Q It's a bit smudged, but it kind of looks All right. And then there's a signature block that's redacted that says Jane Doe 3, correct? A Correct. Q Do you believe that you signed this 19 tell me whether your attorneys showed you the record. 19 20 I'm asking you not to tell me the source of the 20 A Yes. 21 record. 21 Q All right. And again, is there anything 22 23 I'm asking you if you personally in the middle of 2015 looked at Mar-a-Lago records? document and it was later covered up by that block? 22 in this document that you believe today to not be 23 true? 24 MR. EDWARDS: Same objection. 24 25 Same instruction. 25 MR. EDWARDS: I just ask that you read through the entire document and answer the question. VIRGINIA GIUFFRE 5/3/2016 8 (29 - 32) Agren Blando Court Reporting & Video, Inc.Page 11 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 33 1 2 3 4 5 Q document before, Ms. Giuffre? A Q A 8 over. 9 11 12 All right. (Pause.) 7 Q Page 35 1 Thank you for giving me time to read that 4 don't have to -- 5 A No, I just don't know if I'm allowed -- 6 Q That's all right. A -- to say certain things about that. But, 7 Certainly. So have you had a chance to 9 10 A Yes. 11 Q All right. And what parts of this 12 document sworn by you under penalty of perjury are 13 14 not true? 14 A It's your understanding. You don't have to look at your lawyer if you don't understand. You 8 read it now? Again, the only thing that I see is the ; is that your understanding? 3 13 15 against 2 I'm sure I have, but it's always good to refresh your memory just looking over something. 6 10 (BY MS. MENNINGER) Have you seen this yes, I believe they were in a lawsuit. Q Okay. And that's against , right? A Correct. MR. EDWARDS: Object to the form. I object to the relevance of the document. Q (BY MS. MENNINGER) All right. 15 Ms. Giuffre, again, if you could turn to the last 16 mistake that I made, I first met Epstein when I was 16 page of this document. And do you see a signature on 17 15 years old. 17 that page? 18 Q Okay. And that's in paragraph 5? 18 A I do. 19 A That's in paragraph 5 on the first page. 19 Q Whose signature is that? 20 Q All right. And everything else you 20 A That is mine. Q And approximately when did you sign that 21 22 23 24 believe to be true? 21 document? A Yes. 22 Q Okay. If I could now turn to what I'll 23 A Executed this 20th day of November, 2015. 24 Q All right. So you signed that on mark as Defendant's Exhibit 5. (Exhibit 5 marked.) 25 25 November 20th, 2015, correct? Page 36 Page 34 A Correct. Q All right. And that was under penalty of 1 THE DEPONENT: Thank you. 1 2 MR. EDWARDS: Thank you. 2 3 MS. MENNINGER: I think I have one more. 3 4 MS. McCAWLEY: It's okay if you don't. 4 A Correct. 5 MS. MENNINGER: I don't think I have all 5 Q All right. If I could now turn to what perjury, correct? 6 of them. 6 7 Q 7 (Exhibit 6 marked.) 8 MR. EDWARDS: Thank you. 8 (BY MS. MENNINGER) All right. Do you recognize Defendant's Exhibit 5? 9 A Yes. 10 Q What is the title of that document? 10 11 A Declaration of Virginia Giuffre. 11 12 Q And that's you, correct? 12 13 A Yes. 13 14 Q And do you recognize which case this 14 15 16 17 18 19 20 21 A Q 15 Yes. Bradley Edwards and Paul Cassell, . All right. And who do you understand Mr. Edwards and Mr. Cassell to be? A MS. McCAWLEY: Thanks. 9 declaration was filed in? Plaintiff versus we'll mark as Defendant's Exhibit 6. Mr. Edwards is my lawyer sitting next to me. 16 17 (BY MS. MENNINGER) Do you recognize this document, Ms. Giuffre? A I do. Q All right. What do you believe this document to be? A I believe this is when I spoke to the FBI. Q Okay. And do you remember about when you spoke to the FBI? 18 A It says, Date of entry July 5th, 2013. 19 Q Do you believe that you spoke to the FBI 20 in 2013? 21 A 22 Q All right. 22 23 A And Mr. Cassell is another one of my 23 24 lawyers. 25 Q 24 All right. And they are in a lawsuit Q 25 I thought it was 2011 when I talked to them. Q Okay. I'm going to direct your attention to the bottom of that page. A Yes. VIRGINIA GIUFFRE 5/3/2016 9 (33 - 36) Agren Blando Court Reporting & Video, Inc.Page 12 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 37 Page 39 Q Okay. And have you reviewed any -- have Q The first page. Do you see that? 1 2 A Yes. 2 you at any time reviewed this document without those 3 Q The last few lines there have another 3 portions whited out? 4 date. 1 4 5 A Oh, yes, investigation of, yes. 5 6 Q All right. 6 7 A So that makes sense, okay. 7 8 Q Okay. What do you understand that to be? 8 9 10 11 12 13 14 15 And if it refreshes your recollection about when you spoke to the FBI, just let us know. A Yeah, March 17th, 2011 sounds more right than 2013. 9 without the portions. Q Okay. So you don't know, for example, what's behind those, other than what you recall -A No. Q -- having told the FBI at the time, correct? 11 A That's correct. Q Okay. I'm going to show you a new 12 document. Q Okay. And where did you speak to them? 13 A I believe this was in the office of the 14 A Okay. 15 Q You can just put that to the side. consulate, American Consulate, in Sydney. Q Sydney, Australia? 16 17 A Sydney, Australia. 17 18 Q Okay. And you were there in person with 18 these FBI agents? Defendant's Exhibit 7. (Exhibit 7 marked.) Q Correct. 20 21 Q And were they taking notes when they spoke 21 22 to you? (BY MS. MENNINGER) All right. MR. EDWARDS: Thanks. 19 A 20 I don't believe I've seen this document 10 16 19 A Q (BY MS. MENNINGER) And do you recognize this document? 22 A Yes. 23 A Yes. 23 Q And what do you understand it to be? 24 Q Were they recording the interview, to your 24 A This was a phone conversation that I had 25 knowledge? 25 between Jack Scarola and Brad Edwards. Page 40 Page 38 1 2 3 A I believe they were. 1 Q Okay. Have you had a chance to review 2 this report? 3 And I will make note for the record that 4 4 5 there are obviously many places that are blacked 5 6 out -- Q Okay. And do you see a date reflected on the front page? A April 7, 2011. Q Is that when you had that phone conversation with them? 6 A If it's dated like that, it must be, yes. 7 A Yeah. 7 Q Well, I just need you to say from your 8 Q -- or whited out. Is that fair? 8 memory, does that sound about right in terms of what 9 A Yes. 9 you recall having been the phone conversation? 10 Q All right. Have you had a chance to 10 A I'm sure it's correct. 11 review this one with whited-out portions of it before 11 Q Okay. 12 today? 12 A I don't have a good calendar in my brain. So, yes, I'm sure that that's the correct date. 13 A Yes. 13 14 Q All right. And you understood when you 14 Q 15 were speaking to the FBI that they were federal 15 correct? 16 agents, correct? 16 A Yes. Q Okay. Have you listened to the recording 17 18 19 A Yes. 17 Q And that you were supposed to tell them 18 the truth, correct? 19 20 A Absolutely. 20 21 Q And do you believe that you did, in fact, 21 22 23 tell them the truth? A To the best of my knowledge. Again, when Did you understand it was being recorded, of that phone call? A I don't believe I listened to the recording, but I have seen the document. Q All right. And again, you were speaking 22 the truth at the time you were speaking to them as 23 lawyers and officers of the court, correct? 24 it comes to dates and times, I was obviously off. 24 25 But everything else is absolutely 100 percent true. 25 A Yes. And again, to the best of my knowledge when it comes to dates. VIRGINIA GIUFFRE 5/3/2016 10 (37 - 40) Agren Blando Court Reporting & Video, Inc.Page 13 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 41 1 2 Q Okay. And then the last -- the last document, I hope, is -- Page 43 1 as you sit here right now, is there anything in that 2 manuscript about Ghislaine Maxwell that is untrue? 3 MS. MENNINGER: The big one. 3 4 (Exhibit 8 marked.) 4 I don't believe so. Like I said, there is a lot of stuff that I actually have left out of here. (BY MS. MENNINGER) All right. Do you 5 Q Um-hum. 6 recognize -- I'm going to -- I'm sorry, if I didn't 6 A So there is a lot more information I could 7 say it already. This is Defendant's Exhibit 8. 7 put in there. But as far as Ghislaine Maxwell goes, 8 I would like to say that there is 99.9 percent of it 9 would be to the correct knowledge. 5 Q A Do you recognize this document? 8 9 A Yes, I do. 10 Q And what is this document? 10 11 A This is a manuscript that I was writing, I 11 and I understand you're doing this from memory. Is Q All right. Is there anything that you -- 12 believe, back in 2011 regarding some of my life 12 there anything that you recall, as you're sitting 13 story. And just to make it known, this is a based on 13 here today, about Ghislaine Maxwell that is contained 14 true events. But I wouldn't say fictional, but just 14 in that manuscript, that is not true? 15 based on true events. 15 Not everything in it is -- not everything A You know, I haven't read this in a very 16 long time. I don't believe that there's anything in 17 is in there and not everything is, you know, correct. 17 here about Ghislaine Maxwell that is not true. 18 So there's a few mistakes in there. 18 16 19 Q Okay. Off the top of your head, do you MR. EDWARDS: I'd just ask, Counsel, if 19 you have anything specific to show her about Ghislaine Maxwell -- 20 recall any mistakes that are in there now without 20 21 reading the 140-page document? 21 MS. MENNINGER: I'll ask questions. 22 MR. EDWARDS: -- I'll have her look at it. 23 MS. MENNINGER: I'll ask questions. 24 MR. EDWARDS: I know, but I want the MR. EDWARDS: We're going to be here a 22 23 24 25 long time. A Yeah, we could be here a very long time. I mean, I'd like to say a majority of it is correct. 25 record clear that if she hasn't read it in a long Page 42 Page 44 1 Some names have been changed in order to protect 1 2 other people. 2 3 time, she -MS. MENNINGER: She made the record very Q (BY MS. MENNINGER) Protect their privacy? 3 clear. Thank you. She doesn't need you to make a A record. Protect their privacy, yeah, I would say, 4 5 just not getting them involved in, if this were to 5 6 ever go public. 6 you're making this last longer. There's no need for 7 this. This doesn't have to be an unpleasant process. 8 I want her to help you. 4 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 MS. MENNINGER: I don't find it 9 10 will help. MR. EDWARDS: I'm not making records, but unpleasant. I'm sorry if you do. MR. EDWARDS: Okay. Well, then, I object 11 12 to that last series of questions to the extent that 13 A Yes. 13 she was unable to look at what you wanted her to look 14 Q Is there anything -- well, first of all, 14 at. 15 did you author that entire manuscript? 16 A 17 Q 18 15 Q (BY MS. MENNINGER) I would like to next Yes, I did. 16 turn to a document filed on March 16th of this year. Did anyone else author part of that 17 Or actually, let me rephrase that. A document dated 18 March 16th of this year, which we will mark as 19 Defendant's Exhibit 9. manuscript? 19 A Do you mean did anyone else write this 20 with me? 20 21 Q Right. 21 22 A No. 22 23 Q That's all your writing? 23 A Yes, I do. 24 A This is my writing. 24 Q All right. And what is your understanding 25 Q Okay. To the best of your recollection, 25 (Exhibit 9 marked.) Q (BY MS. MENNINGER) Do you recognize this document, Ms. Giuffre? of what this document represents? VIRGINIA GIUFFRE 5/3/2016 11 (41 - 44) Agren Blando Court Reporting & Video, Inc.Page 14 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 45 A Page 47 Based upon the title, it is Plaintiff's 1 2 Response and Objections to Defendant's First Set of 2 3 Discovery Requests to Plaintiff. 3 A I do. Q All right. And then looking at 1 Do you see your attorney's signature and the date, March 22nd, 2016, correct? Q And are you the plaintiff? 4 5 A I am the plaintiff, yes. 5 Defendant's Exhibit 11, that's your declaration, 6 Q All right. So it's your response to 6 correct? 4 7 8 9 Ms. Maxwell's discovery request, correct? A Correct. Q All right. And if you look at the last 7 A Yes, it is. 8 Q And declaring under penalty of perjury as 9 of March 22nd, 2016 that the supplemental response 10 page -- or, I'm sorry, it would be the second to last 10 11 page -- you might see signatures of your attorney, 11 A 12 correct? 12 Q And you -- that's your signature? 13 A I see printed names. 13 A That is mine. 14 Q Printed. Electronic signature -- 14 Q And you are swearing under penalty of 15 A Okay. 15 perjury that Defendant's Exhibit 10 is true and 16 Q -- will have a little S in front of it. 16 correct? 17 A All right. 17 A Yes. 18 Q Do you see that? 18 Q As of March 22nd, 2016, right? 19 A I can see the, yeah the printed names. So 19 A Yes. 20 Q All right. And then one more on that. 20 21 22 if it's electronic signature, then yes. Q All right. And the date on that is 21 March 16th of 2016? and objections are true and correct, right? Correct. Defendant's Exhibit 12. (Exhibit 12 marked.) 22 23 A Correct. 23 24 Q All right. And so without revealing the 24 content of your conversations, you assisted in 25 A Yes. 1 Q Okay. And what is this document? A Plaintiff's Second Amended Supplemental 25 Q (BY MS. MENNINGER) And do you recognize this document? Page 46 1 preparing responses to discovery requests, correct? Page 48 2 A Yes. 2 3 Q All right. I'm going to show you a 3 Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff. 4 subsequent one marked Defendant's Exhibit 10 and 4 5 dated March 22nd. 5 (Exhibit 10 marked.) 6 7 Q (BY MS. MENNINGER) If you can take a look 8 at that. 9 A Thank you. Q And while we're at it, I'm going to give All right. And again, turning to the very 6 rear section, I think you'll see your attorney's 7 signatures again and the date of April 29th, 2016? 8 10 Q 9 10 A I do see that. Q All right. And again, you authorized this document to be filed, correct? 11 you Defendant's Exhibit 11 so you can look at them 11 A Correct. 12 together. 12 Q And the statements contained therein are (Exhibit 11 marked.) 13 13 true, to the best of your knowledge, correct? 14 Q (BY MS. MENNINGER) All right. 14 A Correct. 15 A Thank you. 15 Q And that's -- April 29th is just a few 16 Q All right. So looking at Defendant's 16 17 18 Exhibit 10, do you recognize that document? A Plaintiff's Supplemental Response and 17 18 19 Objections to Defendant's First Set of Discovery 19 20 Requests to Plaintiff. 20 I've seen a lot of documents, and they all 21 22 23 look the same. But I'm sure I've seen it. Q All right. And looking, again, at the days ago, correct? A Yes. Q All right. Did you review this April 29th document before it was filed or served? A Like I said, I've seen a lot of documents 21 and they all look alike, but I'm sure I've seen this 22 one. 23 Q Okay. And if it's something that was 24 last page -- or I'm sorry, this time it will be the 24 served last Friday, does that refresh your 25 third to last page. 25 recollection that you reviewed it before it was VIRGINIA GIUFFRE 5/3/2016 12 (45 - 48) Agren Blando Court Reporting & Video, Inc.Page 15 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 49 1 served on April 29th, 2016? Page 51 1 Q Written from Taco Bell? A You know, I don't know, sorry. I just -- 2 A I believe I have seen this. 2 3 Q And you were here in the U.S. last Friday? 3 I remember he asked me to come in and help him out, 4 A Yes. 4 and that's -- I didn't really consider myself an 5 Q So you saw it in person, correct? 5 employee there, but -- 6 A Yes, I was looking at a lot of documents 6 7 on Friday. 8 Q Okay. 9 A I believe this could definitely be one I 10 11 12 Q employee? attention to -- let me see, in that document -- 12 Well -MR. EDWARDS: Object to the form. Mischaracterizes her testimony. A Yeah, I know. I mean, it was my MR. EDWARDS: Exhibit 12? 13 boyfriend. I was helping him out. So that's the way MS. MENNINGER: Um-hum, Defendant's 14 I looked at it. Exhibit 12. Q A 10 11 14 15 paycheck didn't cause you to think you were an 8 All right. If I could direct your 13 Just wearing the shirt and getting a 7 9 looked at. Q 15 (BY MS. MENNINGER) -- to page -- sorry. Q (BY MS. MENNINGER) Is there any other 16 place that you wore a uniform and got a check from in 17 You're not the only one who's seen a lot of 17 the years from '96 to 2000? 18 documents. 18 16 19 Well, without asking you to look at a 19 20 page, can you tell me what your -- between 1996 20 21 22 23 24 25 A I did work at Publix as a bag girl, but that was only for a couple weeks, I think. Q Which Publix was that? and -- well, in 1996 to 2002, what was the first job 21 A I believe it was in Loxahatchee. that you held? Q Okay. Do you remember the street? 23 A No. 24 Q All right. Anywhere else you wore a A 22 I believe the first job that I held was in the year 2000, and that was at Mar-a-Lago. Q Okay. And is that the first job you held 25 uniform and got a paycheck? Page 50 Page 52 1 as a teenager or at any point in time, that you 1 A 2 recall? 2 Q What was the name of that? 3 A Yes, that I recall. 3 A I don't know the name of it. But it 4 Q All right. Did you ever work at Taco 4 5 Bell? A 5 My ex-boyfriend used to work there and I I volunteered at a bird aviary. was -- I'm an animal lover. So -Q Okay. 6 A -- it's something I enjoyed doing. 7 would help him out. I was never really -- I don't 7 Q Okay. Did you get a check from them? 8 think I was employed there. He was my boyfriend so I 8 A I volunteered. I think they eventually 9 stayed there with him all the time. 6 10 11 12 13 14 9 Q What was his name? 10 A I called him 11 but I think his real name was Q Okay. And so he was employed there, but you were not employed there? put me on some kind of payroll. I don't think it was much, though. Q Okay. So what year were you in helping 12 out in a Taco Bell wearing the uniform and getting a 13 check? 14 A I have no idea when it comes to years. 15 A I used to go there and help him out. 15 Q Was it before or after Mar-a-Lago? 16 Q Did you have a uniform? 16 A Before Mar-a-Lago. 17 A I would have to wear a shirt when I was 17 Q Okay. And how -- 18 A Mar-a-Lago was my first real job so -- Q Oh, a Taco Bell shirt? 19 Q What's that? 20 A Yes. 20 A Mar-a-Lago was like my first real job. 21 Q Okay. And did you get a paycheck from 21 Q What do you mean by real job? 22 A Like, you know, fully employed, sit down 18 19 22 there, yes. He was the manager, so -- them? 23 A I believe paid me. 24 Q How did he pay you? 24 25 A With a check. 25 23 for an interview and, you know. Q Okay. So Taco Bell, was Taco Bell the first place you got a paycheck from? VIRGINIA GIUFFRE 5/3/2016 13 (49 - 52) Agren Blando Court Reporting & Video, Inc.Page 16 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 53 MR. EDWARDS: Object to the form. 1 Page 55 1 2 A Uhm, I don't know, to be honest. 2 3 Q (BY MS. MENNINGER) And in what order did 3 4 Taco Bell, Publix and Mar-a-Lago go, and the aviary, 4 5 sorry? 5 6 A 7 8 Oh, I would have to guess. Do you want me Q you had immediately prior to Mar-a-Lago? A If I were correct, it would be the aviary that I volunteered at. Q Okay. And you believe you were living 6 with your parents at the time you worked at the to guess? 7 aviary? Q Sure. 8 A Yes. A Okay. And not living with Um, I would say Publix. And then, I think 9 Q 10 that's when I helped my boyfriend out at Taco Bell 10 A 11 and then I think the aviary. 11 9 Months. And what was the job you believe might have been living with me and my parents. 12 Q And where was the Taco Bell? 12 13 A I was living in Fort Lauder -- I think it 13 with you and your parents at the time you worked at the aviary? Q Okay. So you recall was living 14 was Fort Lauderdale. Don't quote me on that, but 14 15 somewhere in Florida, Broward County, something like 15 16 that. 16 17 Q And who were you living with at that time? 17 18 A Michael. His name is James, but Michael. 18 19 Q So you were living with Michael when you 19 with you and your parents at the time you started at 20 Mar-a-Lago? 20 worked at the Taco Bell, right? A Yes. MS. McCAWLEY: Objection. Mischaracterizes testimony. Q (BY MS. MENNINGER) And was 21 A Yes, I was living with him. 21 A Yes. 22 Q And you worked with Michael when you 22 Q And what address was worked at the Publix, correct? living living with 23 you and your parents at the time you started at 24 A No. 24 Mar-a-Lago? 25 Q Okay. So Publix came after Taco Bell or 25 A My parents' address? before? 1 Q Whatever address you were living at, at A 2 23 Page 54 1 2 3 4 5 I think it came -- like I said, don't quote me on it, but I think Publix came before it. Q And who were you living with when you worked at Publix? Page 56 3 4 5 6 A My mom and my dad. 6 7 Q And who were you living with when you 7 8 worked at the aviary? 9 A My mom and my dad. 10 Q Anywhere else that you got a paycheck from 11 before 2000? the time you started at Mar-a-Lago. A , Loxahatchee, Florida 33470. Q How is it that you came to work at Mar-a-Lago? A My dad is a maintenance manager or 8 supervisor, I don't know what you call it. But he 9 worked in the maintenance department, mostly on 10 tennis courts, working on the air conditioning, 11 helping set up for functions. And he got me a summer No, not that I can think of. 12 job there. Q Okay. Anywhere else you wore a uniform? 13 Q Okay. And you said you were on a break? A Besides Mar-a-Lago and -- yeah, that's it. 14 A Yes. Q Okay. And so how long was it between 12 A 13 14 15 Q What were you on a break from? 16 working at any of those three places and the time 16 A I think like -- this is going back so long 17 that you worked at Mar-a-Lago? 17 now, but I was attempting to get my GED. And it, 15 18 A I have no idea. I'm sorry. Um -- 18 summer came, so school stops during the summertime 19 Q Years? Months? 19 here in America, and I got a summer job. A Oh, we're going to go back 20 Q All right. And where were you in school? 21 chronologically. I was trying to get my GED and I -- 21 A I don't actually know the name of the 22 there was a summer break. And that's when I started 22 23 working for Mar-a-Lago. So that Mar-a-Lago we know 23 Q A GED place? 24 now is in the year 2000. So I would have to say a 24 A Yeah, it was, like, I was previously in 25 month. 25 20 place. It's -- yeah, I know. Royal Palm Beach High School, but, I mean, because of VIRGINIA GIUFFRE 5/3/2016 14 (53 - 56) Agren Blando Court Reporting & Video, Inc.Page 17 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 57 Page 59 Q Locker room attendant was the name? 2 A Of the position? 3 Q Yes. 4 A Yes. 1 a lot of the circumstances that I had been subjected 1 2 to, I decided I wanted to get my GED. 3 4 Q Okay. So you were going to an actual school to get your GED, that's what you're saying? 5 A Yes. 5 Q And did they give you any training? 6 Q And that school, whatever it was, where 6 A No. 7 you were getting your GED was not Palm Beach High 7 Q Did they show you how to work the lockers? 8 School, right? 8 A Well, I mean, there was a girl who already 9 A No. 10 Q And it -- whatever the school was where 11 9 you were getting your GED took a summer break? worked there at the front desk. I think she helped 10 make appointments and greeted people, and then she 11 just told me my duties in the locker room were to, 12 A I believe so, yes. 12 you know, make tea. I had never made tea before, so 13 Q And that was in 2000? 13 that was -- that was fun. Learn how to make tea. 14 A Now that we know the right dates, yes. 14 Clean up after the ladies who had been in the locker 15 Q And that's when your dad helped you get a 15 room. Make sure the bathrooms were kept nice and 16 tidy. You fold the toilet paper into a little 17 A Yes. 17 triangle every time anyone went to the toilet. Clean 18 Q All right. And that summer job was 18 up the sink area. It was a very crazy job. 16 19 20 21 quote-unquote summer job? Mar-a-Lago? 19 A Yes. 20 Q Okay. Now tell me how you sort of came 21 Q Do you remember the names of any of your coworkers who you worked with at Mar-a-Lago? A I believe the head of the spa area was Adriana or Adrienne. I can't remember exactly. 22 into Mar-a-Lago for the first time? He asked you to 22 23 come? They called you? What happened? 23 Q Okay. 24 A And the girl who trained me, I have a very 24 25 A My dad was very liked there. So I think he talked to the people who were in HR. And then 25 clear picture of her face, but I can't remember her Page 60 Page 58 1 they said for me to come in for an interview. 1 name. 2 Q Um-hum. 2 Q All right. What did she look like? 3 A To be interviewed for a locker room 3 A She had blonde hair, probably to her 4 5 assistant. 4 Q Um-hum. 5 A They liked me. I had to go through a shoulders, and it was curly. Q And how old was she? 6 A I'd say in her 20s. 7 series of drug tests, polygraph tests. I mean, it 7 Q All right. Did they check your 8 was a very extensive regime to get a job there. 8 identification when you went in for your job 9 interview or your -- 6 9 Q Yeah. 10 A And when all those came back good, I 11 12 started the job. Q So how long do you think it took for you 10 A It was very extensive. I'm sure they 11 would have had to check and make sure I was who I 12 was. 13 to go through that extensive series of drug tests and 13 Q And so you had a driver's license, right? 14 polygraph tests and -- 14 A I believe so. Q All right. And, let's see. Did you move 15 A I did them both in the same day. 15 16 Q Okay. When was the interview? Was it on 16 to a different position while you were there or did 17 you always stay as a locker room -- 17 18 19 20 21 the same day or a different day? A I believe it was like a few days beforehand. Q Okay. And do you remember who you interviewed with? 18 A I wasn't there very long. So I just -- 19 Q Just one second. Did you always stay as a 20 21 22 A No. 22 23 Q Do you remember the title of the job for 23 24 25 which you were interviewing? A Locker room attendant. 24 25 locker room attendant? A Yes. Q Okay. I just need to finish my question for the court reporter. A I know, I'm sorry. I have a tendency of jumping in. VIRGINIA GIUFFRE 5/3/2016 15 (57 - 60) Agren Blando Court Reporting & Video, Inc.Page 18 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 61 1 Q Okay. If I can direct your attention back Page 63 1 documents that you met Ghislaine Maxwell in '98 or '99, correct? 2 to Defendant's Exhibit 12 at page 15. And under the 2 3 heading Response to Interrogatory Number 9, do you 3 A Yes. 4 see that where it says -- 4 Q And you do admit that you told members of 5 A Yes. 5 the media that you met Ghislaine Maxwell in '98 or 6 Q -- Ms. Joffrey (pronouncing) -- Giuffre, 6 '99, correct? 7 8 9 10 excuse me, responds as follows? Yes. Q Okay. It says you worked as a locker room 8 attendant for the spa area, correct? 9 10 11 A Yes. 11 12 Q And it says records produced in this case 12 13 MR. EDWARDS: Form. 7 A identify the date of employment as 2000, correct? 13 14 A Yes. 14 15 Q What records that were produced in this 15 A That was my closest approximation to what I could actually remember, so -Q (BY MS. MENNINGER) You told the media that you met her in '98 or '99? MR. EDWARDS: Form. A Again, yes, as close as I can remember. Q (BY MS. MENNINGER) And the media published in the newspapers that you met Ghislaine Maxwell in '98 or '99, correct? 16 case cause you to believe that the employment began 16 17 in 2000? 17 18 A 18 A Yes, they did. 19 Q (BY MS. MENNINGER) And the news media 19 20 21 22 23 24 Uhm, is this going back to another question that I'm not allowed to answer? MR. EDWARDS: Form. Q No. 20 published in the newspapers what you told them, which A I have seen the documents, and I know that 21 is that you were 15 when you met Ghislaine Maxwell, 22 correct? my employment now was in 2000. Q What documents did you see that caused you to make that answer? 24 25 A The Mar-a-Lago employment documents. 1 Q Are they your Mar-a-Lago employment MR. EDWARDS: Form. 23 25 A Which is what I truly thought at the time, yes. Page 64 Page 62 2 3 documents? A MR. EDWARDS: Object to the form. 6 7 8 9 10 2 true that you were 15 when you met Ghislaine Maxwell, 3 correct? 4 A It was a mistake that I made, yes. 5 Q So that the printing in the newspaper that Q (BY MS. MENNINGER) Okay. Do you believe 6 you met Ghislaine Maxwell when she was -- when you 7 were 15 is not a true statement of fact, correct? them to be your Mar-a-Lago employment documents? A Q As far as I can tell. 8 Okay. So you were able to review your Mar-a-Lago employment documents -MR. EDWARDS: Object to the form. Q 9 10 (BY MS. MENNINGER) -- and respond to the 13 14 15 A Yes. 15 16 Q When did you review the documents that you 16 17 reviewed to cause you to respond to that answer that 17 18 way? 21 All right. And to the best of your 2015, correct? correct? 20 Q recollection, you found that out in the middle of question, as it says right there that you respond, 18 I don't think I found out till sometime It is an incorrect statement as I have now 12 14 A A found out, that my employment started in 2000. 11 13 19 (BY MS. MENNINGER) Okay. And it is not My name is on there. 11 12 Q A 4 5 Um -- 1 MS. McCAWLEY: Objection. A To the best of my recollection. I mean, I can't pinpoint an exact date I found out. But, yes. Q (BY MS. MENNINGER) About a year ago? MR. PAGLIUCA: Are we all participating in this deposition or just -- 19 MS. McCAWLEY: Same way you guys did. 20 MR. PAGLIUCA: We did not. Q Okay. 21 MS. MENNINGER: I did not. A I'm really not too sure. You know, I'm mid -- mid last year, I believe. 22 MS. McCAWLEY: You both objected. 23 sorry, dates and documents, there's too many to 23 MS. MENNINGER: No. 24 remember. But -- 24 MR. PAGLIUCA: No, we didn't. 25 MS. McCAWLEY: We can go back through the 22 25 Q Okay. You do admit that you filed in many VIRGINIA GIUFFRE 5/3/2016 16 (61 - 64) Agren Blando Court Reporting & Video, Inc.Page 19 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 65 1 record. Page 67 1 2 MR. PAGLIUCA: We sure can. 2 3 So if we're all participating, maybe I'll 3 4 have a few questions at the end of this. I think we 4 5 should limit this to one lawyer. And your statement 5 6 about two lawyers participating in the last 6 7 deposition is wrong. 7 MS. McCAWLEY: Well, I recall that she got 8 9 10 a microphone because she said she was going to be objecting. So -- Q All right. And what address did you put 13 14 back at the record. You know, it's not a problem. 14 15 Brad can make the objections. 15 MS. MENNINGER: I was about to say it's 20 21 been an hour. 22 23 24 at the top of your resume? A Q And when did you live at that address? 16 A I believe from 2013 to 2014. 17 Q Okay. And you said you created this 18 document, correct? 19 A Yes. 20 Q And did you send it out to any employers? A Do you have any attachments that this goes 21 MR. EDWARDS: Yeah. 22 with to say that I have? Because I'm not too sure. MS. MENNINGER: So this would be a good 23 I've created a lot of resumes. time to take a break. 24 MR. EDWARDS: Okay. Thanks. 25 Yes, I do. What is this document? 12 MR. EDWARDS: Can you tell me when you're Ms. Giuffre, do you recognize this document? This is a resume that I created myself. MS. McCAWLEY: Well, we can take a look at a good stopping point? (BY MS. MENNINGER) Okay. All right, A microphone and didn't speak through the whole thing. 19 (Exhibit 13 marked.) Q Q 13 18 Okay. I'm going to show you an exhibit 9 12 MR. PAGLIUCA: Okay. Let's take care of Q marked as Defendant's Exhibit 13. 10 11 it that way, then. Correct. A MR. PAGLIUCA: I know. She put on a 17 A 8 11 16 Mar-a-Lago? Q Okay. And hold on, I'll see if we do. MS. MENNINGER: All right. I'll mark this 25 Page 66 THE VIDEOGRAPHER: We're off the record at 1 2 10:12. 4 3 10:27 a.m.) 4 THE VIDEOGRAPHER: We're back on the 5 next as Defendant's Exhibit 14. (Exhibit 14 marked.) 2 (Recess taken from 10:12 a.m. to 3 Page 68 1 record at 10:27. 5 A Thank you. Q (BY MS. MENNINGER) All right. Do you recognize this document? 6 A Yes. (BY MS. MENNINGER) All right. 7 Q What is this document? 8 Ms. Giuffre, you testified that you first became 8 A This is me replying to ads for jobs. 9 aware that you -- your employment at Mar-a-Lago began Q Okay. And you were communicating with -- 6 7 10 Q in 2000, in mid-2015, correct? MR. EDWARDS: Object to the form. 11 12 13 Mischaracterizes her testimony. A 9 10 I don't know exactly when. It could be by your e-mail, correct? 11 A Yes. 12 Q All right. And I apologize. This one 13 actually has the resume attached to an e-mail. 14 towards the end of 2015. It could be towards the 14 A Um-hum. 15 beginning of 2016. I just know that I've learned 15 Q Do you see that, towards the back of the 16 about it recently. I'm not too sure exactly what 16 17 date I did learn about it. 17 A document? Yes, I do. (BY MS. MENNINGER) Okay. But to your 18 Q Okay. So -- 19 mind, it's been within the last 6 to 12 months; is 19 A Sorry. 20 that fair? 20 Q To whom -- to whom -- with whom were you 18 21 Q A I wouldn't say 12 months, no. I would 21 communicating about a job at this time? A Well, on the very top, Phil or Gary, and 22 just say up until -- I don't know when I was shown 22 23 that, when I actually first saw it, but it wasn't a 23 24 year ago. 24 Q Okay. 25 Q 25 A Um -- Saw your employment records from that was for a bartending position. VIRGINIA GIUFFRE 5/3/2016 17 (65 - 68) Agren Blando Court Reporting & Video, Inc.Page 20 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 71 Page 69 1 2 3 Q Was that something your brother had recommended or your father? I don't know who. A You know, I just looked at that, that's 1 you believe the one attached to Defendant's 2 Exhibit 14 is the one that you sent? 3 A there is. 4 kind of why I giggled. I don't know why my 4 5 brother -- that's my brother. That's the way we talk 5 6 to each other: Hi, stupid head. Good luck, smelly, 6 7 XOXOXO, sissie. 7 He's my little brother so you have to 8 8 Q There are differences, isn't there? Yes, Okay. What are the differences that you know? A It starts -- I mean, let me see. The very top introduction is the same. 9 Q Um-hum. 10 resume for hospitality, I'm not too sure why he would 10 A After the experience. 11 have gotten it, but apparently he did. 9 understand we kind of play around. But subject to my 11 Q Um-hum. Okay. And you see that your resume was 12 A That changes. The dates change. And then 13 attached to an e-mail communication you had with your 13 underneath Employment Training Recruitment is Indigo 14 brother? 14 Bar & Grill on Exhibit 14. On Exhibit 13 it's 15 A Yes, I do. 15 Mannway Logistics underneath Employment Training Q Right. And that's also your brother was 16 Recruitment. 12 16 Q And then underneath Mannway Logistics on 17 part of the e-mail chain with respect to an ad placed 17 18 on craigslist for a position, correct? 18 Exhibit 13 is Mar-a-Lago Resort and Spa. And on 19 Exhibit 14 is Gemma Catering/Wedding Receptions. So 20 there is quite a few differences. 19 A 20 then. 21 Q Sure. 21 22 A 1/20/2014, 1/21, so just within a day of 22 you sent out Defendant's Exhibit 13, or if you did, 23 to an employer? 23 24 25 He was on -- let me just check the dates, each other, yes. Q All right. And then the resume that's 24 attached is the address you were living at in 25 Q A Okay. Great. Do you have any idea when Unless you have something that's attached to it, I can't be sure that I did. Page 72 Page 70 1 January -- 1 Q Okay. Is the content in Defendant's 2 A Yes. 2 Exhibit 14, that you believe you sent out to an 3 Q -- of 2014, correct? 3 employer, correct? 4 A Correct. 4 5 Q All right. So you believe you created the 5 they are not correct. Through my experience I was in A Unfortunately, I have to tell you that 6 resume that's attached to Defendant's Exhibit 14, 6 the mind-set that I was unemployable. I had been 7 correct? 7 abused for many years and I was told by a job agency 8 A Correct. 8 that I need to show that I've consistently worked at Q And you sent it out with respect to this 9 various places and given experience. So it's not 9 10 employment you saw on craigslist, correct? 10 something that I'm proud of, but I have had to plump 11 A Correct. 11 up my resumes to make it look as though I could be 12 Q And you are the one who put into this 12 employed. 13 A 15 Q Q What do you mean by plump up your resume? Yes. 14 A Well, I couldn't -- I didn't feel that I All right. 15 could go to an employer and tell them that I had 16 held, you know, one job in the last 10 to 12 years 17 and before that I was trafficked for the purpose of MR. EDWARDS: We're talking about the 16 17 13 document the contents of the resume, right? 14 resume that's attached to Exhibit 14, right? 18 MS. MENNINGER: We are. 18 sex. And that's definitely something you don't want 19 MR. EDWARDS: Okay. Got it. 19 to put down on your resume, which makes you quite 20 MS. MENNINGER: Thank you for clarifying. 20 highly unemployable. 21 MR. EDWARDS: Got it. 21 22 MS. MENNINGER: Although, I don't know 22 23 24 25 So I did add places in, such as Indigo Bar & Grill, Calmao Flamenco Bar & Restaurant. there are any differences with Defendant's 23 Q Wait, wait. Which one? Exhibit 13. 24 A On Exhibit 14. (BY MS. MENNINGER) But just to be safe, 25 Q Um-hum. Q VIRGINIA GIUFFRE 5/3/2016 18 (69 - 72) Agren Blando Court Reporting & Video, Inc.Page 21 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 73 A 1 Underneath Experience, the dates are all Page 75 1 A I never worked there. Q The description that you typed out about 2 incorrect, as well. It's just to show that I was 2 3 consistently working, which I was not. And I needed 3 the things that you did at that Indigo Bar & Grill is 4 a job to help my family. I've got a family of five. 4 made up, correct? 5 So like I said, it's not something proud that I had 5 6 to do, but I felt it was the only way that I could 6 would do if you were a server or a waitress. But, 7 actually get employed. 7 like I said, I did not work at Indigo Bar & Grill. 8 9 Q You lied on your resume? A I made it look as though I had 8 9 A Q Well, it's -- it's generally what you So when you represented to an employer that you were applying for a job that you had done 10 continuously worked throughout the years so that way 10 these things, you had not actually done these things 11 an employer would see me as a potential candidate. 11 at Indigo Bar & Grill, correct? Q 12 13 Okay. Well, let's start with Employment Training and Recruitment, ET Australia. Did you work at that place of employment? 14 12 A Not at Indigo Bar & Grill, no. 13 Q All right. Can you read the first 14 15 A Q What dates did you actually work there? 16 Q Right. A I know I finished working for -- we call 17 A At this restaurant located inside of an A 16 17 18 it ET Australia, so if you don't mind me abbreviating 18 19 it. 19 20 21 sentence of your job description? I did work there. 15 Q However you want. 20 A I know I finished there in January of 2006 21 For Indigo Bar & Grill? RSL, we were never slow. Q Okay. So when you said, "We were never slow," you just made that up, correct? MR. EDWARDS: Form. A I tried to give as much information to my 22 right before my son was born, my first son was born. 22 23 And I believe I worked there for a year, I believe 23 potential employer to show that I could handle a 24 so. It might have been a little bit over a year, but 24 large amount of pressure and guests. So, yes, I put 25 just around a year. 25 that in there. Page 74 Q Page 76 All right. So you worked at a place for 1 2 about a year. And on your resume you typed that you 2 you were there working as a server or waitress and 3 worked there for nine years, correct? 3 that we were never slow. That is not true, correct? 1 Q (BY MS. MENNINGER) But you represented 4 A Correct. 4 5 Q And you did that, correct? 5 again, I was very highly unemployable, given my past. 6 A I did. 6 So I did whatever I could to make it look as though 7 Q Nobody else typed that for you? 7 my potential employer could hire me. 8 A No, I did it myself. 8 Q All right. And the next employment you 9 10 list here -- well, is your job description accurate? 9 10 11 A Yes, that is actually accurate. 11 12 Q Okay. And everything in there is what you 12 actually did? A Q Well, I never worked there, so it's -- Okay. You described your duties that were not -- those were fictional duties, correct? A They were duties that a waitress and a server would do. Q But you did not do at Indigo Bar -But I did not do them at Indigo Bar & 13 A A Yes, for ET Australia. 14 Grill. 15 Q Okay. Indigo Bar & Grill, did you type 15 16 that in? 16 service and your service with a smile to the guests. 17 A I did type that in. 17 That was not true, correct? Q And did you actually work at Indigo Bar & 18 A 19 correct. 13 14 18 19 Grill? Q Okay. You described your energetic Everything in Indigo Bar & Grill is not 20 A No, I did not. 20 Q 21 Q All right. So the dates that you put on 21 correct? 22 your resume are not true, correct? 22 23 A That's correct. 23 24 Q The title of your job at that place was 24 25 not correct; you didn't work there, right? 25 A And you created that entire description, For the sole purpose of being able to obtain employment, yes. Q To get money? MR. EDWARDS: Form. VIRGINIA GIUFFRE 5/3/2016 19 (73 - 76) Agren Blando Court Reporting & Video, Inc.Page 22 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 77 1 2 Page 79 A To make a wage for my family. 1 Q (BY MS. MENNINGER) All right. The next 2 Q And after you moved to Australia, which was what year? 3 job, Gemma Catering and Wedding Receptions, did it -- 3 A 4 is that a job that you actually held? 4 believe. 5 A I did actually work there. I don't know 5 Q I moved to Australia at the end of 2002, I All right. Do you recall going to work 6 the dates, but I was a server, waitress and 6 7 bartender. 7 A Yes. 8 Q How -- A I had to obtain my -- my ability to work 8 9 Q March of 2003 to April 2004, is that about when you worked there? 9 10 A 11 sure. 12 Q 13 A Q Did you have children -- had you already 14 14 15 16 17 It could be very close to it. I'm not too 10 there. So I think that took a couple months. You 11 can get a temporary visa that allows you to work You're not sure? 12 while you're waiting for your permanent resident No, I'm not sure. 13 status, and that's what we did. had children at the time you worked there? A shortly after you got to Australia? No, I do not believe I did. I became a stay-at-home mom when I had my first child. Q All right. Were you able to apply for 15 that temporary job permission before you actually got 16 married in Australia? 17 A I got married in Aus -- we were married in 18 Q And what year was that? 18 Thailand, really, but we made it official in January 19 A 2006. 19 of 2003. And within a couple of weeks, I was granted 20 Q Okay. So you believe you worked at Gemma 20 the permission to work in Australia legally. 21 22 23 24 Catering and Wedding Receptions before 2006? 21 Q Okay. So to the best of your A I believe so. 22 recollection, you got permission to work in Australia Q And other than that, you can't recall what 23 sometime in the spring of 2003? dates you worked there? 25 A 1 Q MR. EDWARDS: Form. 24 I'm sorry, I couldn't help, no. 25 A That's actually summer over there. All right. And then what were your 1 Q (BY MS. MENNINGER) Fair enough. The actual -- is that your actual job that you had there? 2 Page 78 2 3 A 4 5 6 7 8 Page 80 first quarter of the year, calendar year -- The description of it? 3 A Q The title, server, waitress, bartender? 4 Q -- 2003? A Yes. 5 A If we're going to be politically correct, Q All right. Is the description accurate? 6 A To a T. 7 Q That's what you recall? Q What's that? 8 A (Indicating.) 9 A To a T. 10 Q Okay. The next job you list is Mannway 11 Logistics, Logistics Receptionist. 11 Is that a job you actually held? 12 12 13 A It is a job I held. 13 14 Q And when did you hold it? 14 15 A Again, I'm very bad at dates. I'm not too 15 16 sure. 17 Q 18 have it? 18 19 A 19 20 21 22 All right. Approximately when did you I don't want to speculate and give you the wrong answer, so I'm not too sure. Q A 24 25 I'm sorry, yes. Q And is your description of Mannway Logistics correct? A Yes. Q All right. And how long did you work there? A I think that was less than a year that I 16 worked there. I would approximate about six, seven 17 months. 20 Did you have children at the time you worked there? 23 yes. 9 10 Yes. Q Can you name one coworker you had or boss or anybody else that worked there? A I know her name started with an M, but I 21 can't remember. I remember what she looks like. I 22 just don't remember her name. No. 23 Q Okay. And how much did you make there? Q So before 2006? 24 A I don't remember the exact amount. A Yes. 25 Approximately about $20 an hour, I think. VIRGINIA GIUFFRE 5/3/2016 20 (77 - 80) Agren Blando Court Reporting & Video, Inc.Page 23 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 83 Page 81 Q 1 And how many hours per week were you working for that six months to a year? 1 A Before I worked at ET Australia, I was 2 actually a job seeker there. And a job seeker, I 3 A I believe that was full time. 3 don't know if you're familiar with the term. 4 Q And is full time the same in Australia? 4 5 A Yeah it's a 40-hour week. 5 go to a job agency, and you go look on the computer. 6 Q Okay. 6 And you actually have somebody who helps you find A Well, 38 because you get two hours of 7 employment. And they are the ones who recommend that 8 you show that you've continuously worked throughout 9 your years. They ended up really liking me, so 2 7 8 lunch, so, yes. Q 9 10 All right. Have you been in touch with anyone from that employment in a while? 10 11 A No. 12 Q All right. The next job listed there is 13 11 12 what? Somebody who is looking for work and you that's how I got the job there. Q Okay. Was it a particular person there that gave you the advice to plump up your resume? 13 A It would have been one of the counselors. 14 A Calmao Flamenco Bar & Restaurant. 14 Q Which one? 15 Q Is that someplace you actually worked? 15 A I don't know. 16 A No, it's not. 16 Q Okay. Do you remember the names of any of 17 Q Is that a place that actually exists? 17 18 A I don't really know. 18 19 Q All right. 19 girls I worked with, but I don't remember -- I don't 20 A I mean, I think I looked on the Internet 20 remember anyone else's name. 21 and found something similar to what the description I 21 22 was needing to fill, and that was it. 22 Q 23 Okay. So when you were creating this 23 the counselors? A Q I only remember the name of one of the When did you first become a job seeker at ET Australia? A Well, if I finished there in 2006 and I 24 document in 2013/2014, right, that's when you had the 24 worked there for approximately a year, it would have 25 Titusville address? 25 been 2005 -- late 2004, 2005. I'm not too sure. Page 82 1 2 Page 84 A Yes. 1 Q All right. You went on the Internet and 2 3 you searched for a place that would be like the job 3 4 you were looking for? 4 5 6 7 first and then got employment there, right? A Yes. Q Okay. So the advice to plump up your Correct. 5 resume was while you were seeking a job or while you Q And you found the name of an actual place, 6 were employed there? Calmao Flamenco Bar & Restaurant. Did I get that right? A 9 Okay. So you were a job seeker there A 8 10 Q I'm not 100 percent on that, but I think so. 7 A While I was seeking a job. 8 Q All right. And you were assigned a 9 counselor? 10 A Yes. 11 Q One or more than one? 12 impress the employer you were applying for here in 12 A It changes on a daily basis. There's 13 the e-mail, correct? 11 Q Okay. And you did that in order to 13 somebody who comes into the office and they sit with 14 A Correct. 14 you and they help you with your resume. And then 15 Q All right. And you did that in order to 15 they help you go on the computer and look for open 16 get money from a job that you hoped to get from this 16 vacancies. 17 employer in the e-mail, correct? 17 A I was hoping to gain employment. And not Q So someone in approximately 2005 gave you 18 the advice to plump up your resume. That's what 19 having much experience, I put in there that I had 19 you're saying? 20 experience. 20 18 Q A To make it look like I've continuously Okay. And you said that you had been 21 22 advised to plump up your resume by a job agency; is 22 23 that right? 23 Restaurant, which is a place you found on the 21 worked, yes. Q Okay. So back to Calmao Flamenco Bar & 24 A Yes. 24 Internet but did not actually work. Is that, the 25 Q What was the name of that job agency? 25 dates for your employment there, December 2001 to VIRGINIA GIUFFRE 5/3/2016 21 (81 - 84) Agren Blando Court Reporting & Video, Inc.Page 24 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 85 1 2 February 2003, not true, correct? A Obviously, yes. At that time I was -- Page 87 1 experience than you had had, correct; that's what you 2 just said? A Correct, I mean given that my past had not 3 during 2001 I was with Jeffrey and Ghislaine being 3 4 trafficked. 4 enabled me to be able to look for work or I wasn't 5 able to put down what I actually had -- had to do in 6 my past. So I made it look as though I was able to be employed. 5 6 Q Um-hum. So you were not working at Calmao Flamenco Bar -- 7 A Obviously not, yes. 7 8 Q And you said you got to Australia in 8 9 10 11 12 13 14 15 16 17 late '02 and did not work there between late '02 and February of ' 03, correct? A I've never worked at Calmao Flamenco Bar & Grill, period. Q 9 10 All right. And the job description that you crafted there is also fictional, correct? the employer was looking for, right? A I couldn't put down on there that I was sex trafficked for a couple years and did not have 12 the experience to be able to apply for jobs and 13 provide for my family. So this is something that I said. Again, 14 A Yes. 15 I am not proud of, but I felt was necessary to do to Q All right. And Mar-a-Lago Resort and Spa 16 be able to gain employment. you put down as a place you had worked, correct? 17 A Correct. 18 19 Q And you typed in August 2000 to September 19 2001, correct? 20 21 A Correct. 21 22 Q And you created your job description 22 23 You did not have the past that you thought 11 18 20 Q there, correct? 23 24 A Correct. 24 25 Q All right. And then turning to the last 25 Q All right. So you were applying for a job at a restaurant, right? A At this -- according to the front e-mail, yes. Q All right. And you did not put down Taco Bell on this resume, correct? A No. The only jobs on here are the ones that we have mentioned. Q Right. And so why did you choose August Page 86 1 2 page you have your education, correct? A Page 88 1 Can I just make a statement to say that, 2 3 again, with the Mar-a-Lago Resort and Spa, I did have 3 4 to add dates to make it look as though I had 4 5 continuously worked. So those, again, are incorrect 5 6 dates. 6 7 8 Q But it is a date that you typed into a resume in 2013 or 2014 -- 9 A That is the date that -- 10 Q If you could just let me finish my 11 12 13 14 15 16 17 Q That is a date that you typed into your 13 Q On the last page it has some education. Which part of that is untrue? MR. EDWARDS: Object to the form. A I have received my business admin cert 3 14 from ET Australia. I've never held responsible 15 service of alcohol and gambling. 16 Q (BY MS. MENNINGER) Do you understand that Q All right. 17 to be a licensing of some sort or a class? Or what A do you understand that -- And, as well as the -- the position, 18 organizing, making and canceling appointments for 19 20 massage therapists. 21 I chose months and dates for every single that I was continuously employed. 19 18 A 9 11 That is the date that I did type in, but You chose a month. Why did you choose why I chose that month. It was just purely to show 12 A Q that month? 8 Sure. those are incorrect dates. It just looks as though I've given them a position on that resume. There is no specific reason A resume in 2013 or 2014, correct? A longstanding history of employment. 7 10 question. of 2000 as your start date for Mar-a-Lago? A In Australia you have to have something 20 called an RSA and RCG to be able to work as a Q All right. 21 waitress or bartender or anything. And I didn't know A I mean, I was their locker room attendant. 22 if it was the same out here in America. So I put 23 I just wanted it to sound like I had more 23 down that I had. 24 receptionist experience than I did. 24 22 25 Q You wanted it to look like you had more 25 I had taken a CPR and first aid. I don't remember when, but it's not current. VIRGINIA GIUFFRE 5/3/2016 22 (85 - 88) Agren Blando Court Reporting & Video, Inc.Page 25 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 89 And I did go to Royal Palm Beach High 1 Page 91 1 A I remember spending a birthday with them 2 School and I didn't put down a degree there or 2 on Jeffrey Epstein's island called Little Saint 3 anything. 3 Jeff's. I wouldn't say it was a party. It was just 4 Q 4 Ghislaine, me, Jeffrey. I believe 5 there. I got some presents from them. 5 So is it fair to say you never worked as a waitress in Australia. Is that what you just said? 6 A 7 Catering. 7 8 Q Oh, okay. 8 like boxes of different kinds of eye shadows and A I don't believe I needed my RSA to work 9 lipsticks and just makeup altogether. 9 10 11 I did work as a waitress at Gemma was 6 there. I'm not too sure. Q Q What presents did you get? A Ghislaine gave me a whole bunch of makeup, Jeffrey gave me a bracelet and, I think 10 All right. And if I could just ask you 11 earrings. 12 one other question about Gemma Catering. In the last 12 Q What kind of earrings? 13 line of the job description it says: This job was a 13 A They were what I believed to be diamonds. 14 second job. I would work in the evenings and 14 I don't know what they exactly were. I think Jeffrey 15 weekends for saving extra cash. 15 was talking about, they could have been passed off as 16 good knock-offs. But they appeared to be diamonds. What was it a second job to? 16 17 A If my time period is right, it would be my 17 18 second job to Mannway Logistics because they were 18 19 both -- Gemma Catering and Mannway Logistics were 19 20 both in Sydney, whereas ET Australia was on the 20 21 central coast. 21 22 23 Q All right. ET Australia is on the central coast? 22 23 24 A Correct. 24 25 Q And Gemma and Mannway are in Sydney? 25 1 A In Sydney, yeah. 1 2 Q All right. Got it. 2 Q Any other presents? A I remember the makeup and the jewelry. I don't remember much else. Q And that was your 17th birthday, you said? MR. EDWARDS: Form. A It's hard for me to really pinpoint exactly which birthday it was. Q (BY MS. MENNINGER) So it could have been your 18th or your 19th? Page 90 Do you know if those two organizations 3 4 5 still exist? A Page 92 3 4 Mannway, I would definitely say, it's a -- 5 A I don't want to lock down on which exact birthday it could have been without knowing. Q You don't know which birthday it was; is that what you're saying? A The one that I'm specifically telling you 6 it's a large logistic company. I would say it still 6 7 does exist. 7 Q Right. You don't know which one? 8 A No. Q All right. Do you remember spending more Gemma Catering, I'm not too sure if that 8 9 10 exists anymore or not. Q 9 Okay. All right. So did you spend your 10 than one birthday with Jeffrey Epstein and Ghislaine Maxwell? 11 16th birthday with Ghislaine Maxwell and Jeffrey 11 12 Epstein? 12 A No. I was 16 when I met them, now that I 13 14 know the correct dates. So I would have spent my 14 15 17th birthday with them. 15 13 16 Q So when you represented that you spent about? A Yes. Q Okay. Tell me about the other ones that you remember. A Well, I know my 19th birthday. I can't 16 remember, really, my 18th birthday. But my 19th 17 your 16th birthday with Ghislaine Maxwell and Jeffrey 17 birthday we celebrated it early, earlier than my 18 Epstein, that was not true, correct? 18 actual date of birth. And that's when he surprised At my ability at the time, that's what I 19 me with tickets to Thailand. 20 believed to be true. It wasn't until I found the 20 21 Mar-a-Lago records stating the year 2000. Me being 21 22 born in 1983 would make me turning 17 that year. 22 19 23 A Q So please describe for me your 17th 23 24 birthday that you claim you spent with Ghislaine 24 25 Maxwell and Jeffrey Epstein. 25 Q What do you mean he surprised you with tickets to Thailand? A He told me that the tickets for Thailand were for my birthday. Q Did he hand you something that looked like a ticket to Thailand? What do you mean? VIRGINIA GIUFFRE 5/3/2016 23 (89 - 92) Agren Blando Court Reporting & Video, Inc.Page 26 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 93 1 A He didn't hand me the tickets at that Page 95 1 2 time, but he told me that he had booked me in for 2 3 massage training at an institute in Chiang Mai. 3 4 Q And he told you he had booked you tickets 4 shortly before my birthday, but not my birthday. Q (BY MS. MENNINGER) Okay. And he told you he had booked you tickets to go to Thailand, right? A Correct. Q All right. So you remember one birthday 5 to a massage training in Chiang Mai, Thailand 5 6 sometime before your actual 19th birthday? 6 at which you received makeup, bracelet and earrings 7 and one birthday at which you received tickets to 8 Thailand. MR. EDWARDS: Form. 7 8 Q (BY MS. MENNINGER) Did I get that right? Do you remember any other birthdays that 9 A Yes. 10 Q Okay. Did he hand you -- 10 you spent with Jeffrey Epstein and/or Ghislaine 11 A Excuse me. 11 Maxwell? 12 Q -- hand you anything at that time? 12 13 A No, I don't think so. 13 Q And where were you located when he told 14 14 15 16 9 you this about the Thailand massage training? A Jeffrey, Ghislaine and I had just gone Q Okay. Well, I'm sorry, did you know for sure that the bracelet, earrings and makeup were from 16 your 17th birthday, or do you know? scuba -- not scuba diving, not with the big tanks, 17 18 but snorkeling with just the mask and the two-piece, 18 19 and on Jeffrey's island, by the way. 19 And we had gone out for a while. And we I'm sure there is, but I honestly can't 15 17 20 A remember what I did for my 18th birthday. 20 A I don't know. Q But you know they were not for your 16th birthday, right? A Correct. Q All right. If I could have you go back to 21 had come back. And he's got a pier where it's got a 21 22 ladder and you climb up. And we were wearing wet 22 23 suits. So we were taking off our flippers and our 23 A Defendant's, sorry, Exhibit 1? 24 wet suits and all of our gear. 24 Q Um-hum. Page 9, either at the bottom or And they said they wanted to sit down and 25 25 Defendant's Exhibit 1, I think. in the upper right-hand corner. Page 96 Page 94 Do you see that page? 1 talk to me, just the three of us. And he -- first, 1 2 he told me about the -- 2 A Page 9 of 27, yes. 3 Q All right. And paragraph 23, do you see 3 4 5 6 7 8 9 10 11 12 13 14 Q If I could just stop you. I think I asked where were you -- 4 that paragraph? A Oh, I'm sorry. 5 A Q -- when you had this conversation about 6 Q All right. 7 A I was just going to read it over quickly. 8 Q By all means. the -A Just the island. I'm just trying to I see the paragraph. 9 A I've read it. Q Oh, okay. 10 Q And the sentence, Defendant and A It was on the island, on the pier in the 11 Ms. Maxwell acknowledged and celebrated plaintiff's 12 16th birthday, is not a true statement, correct? describe the instance that he gave it to me. Caribbean. Q Okay. And it was sometime before your 19th birthday? 13 A Only upon learning about the fact that I 14 just found out my records. I assumed at the time it was my 16th birthday. But now we know different. 15 A Correct. 15 16 Q How much time before? 16 17 A I don't know. A couple -- six weeks, a 17 defendant and Ms. Maxwell did not celebrate your 16th birthday with you, correct? Q You admit, as you sit here today, that 18 couple of months. I don't know. Close to my 18 19 birthday. It was my birthday present, that's what he 19 A 20 told me. 20 Q Which you don't know when you saw? 21 Q 21 A I know it was, you know, it wasn't -- it 22 conversation? MR. EDWARDS: Form. 23 24 25 Okay. So you don't know when you had this A I mean, I -- no, I didn't record the time and the date, so I can only speculate. It was Correct, based upon the records. 22 wasn't a year ago, but it wasn't that long ago 23 either. So I'm not too sure. I can't tell you the 24 date that I actually saw them. 25 Q All right. Last year you lived in VIRGINIA GIUFFRE 5/3/2016 24 (93 - 96) Agren Blando Court Reporting & Video, Inc.Page 27 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 99 Page 97 1 Colorado for part of the year, correct? 1 mischaracterized her testimony. She actually just testified that she may have heard that. 2 A For part of the year, yes. 2 3 Q And then you moved to Australia, correct? 3 4 A Yes. 4 Q You did not live in Florida at any point 5 5 6 7 8 9 10 11 12 in time during 2015, correct? A 6 I believe I left Titusville at the end of I've asked her -MR. EDWARDS: I'm clearing the record up right now, though. MS. MENNINGER: You can object based on 7 2014. Q MS. MENNINGER: No, you're not testifying. Okay. So you did not live in Florida during 2015, correct? 8 form. That's a valid objection. You've made your 9 record. 10 A I believe so. 11 Q All right. So when you reviewed these 12 Q (BY MS. MENNINGER) Did you review records that clarified dates for you? A I've either reviewed them or I've been 13 records sometime in 2015 that caused you to know the 13 told about -- I can't remember. I'm sorry. I 14 real date of when you worked at Mar-a-Lago, where 14 know -- I know now that the dates are what they are, 15 were you physically located? 15 but I don't remember. MR. EDWARDS: Object to the form and 16 17 16 mischaracterized her testimony. 17 Q You don't know when you learned that the dates are what they are? I don't remember where I saw these 18 A No, I don't. 19 records, when I saw these records. I know it wasn't 19 Q And your best guess is what? 20 a year ago. I know it was more recent. I can't 20 21 pinpoint the date that I actually saw them, but I 21 22 recently, I believe -- I don't know. I don't want to 22 attorney-client privilege, I'm instructing you not to 23 sit here and speculate and then give you the wrong 23 answer. 24 answer. It's just new knowledge for me. 24 A I can't answer, then. 25 Q (BY MS. MENNINGER) Okay. So have your 18 25 A Q (BY MS. MENNINGER) All right. Did you MR. EDWARDS: Objection. If any of your answer is based on Page 98 1 receive the records by e-mail? Page 100 1 attorneys told you to change your dates? 2 A I believe so. 2 MR. EDWARDS: Objection. 3 Q Okay. Did you use any e-mail address 3 Do not answer that question. This is a 4 5 6 7 other than 4 question intentionally devised to invade the A No. 5 attorney-client privilege. Q That's the only e-mail address that you've 6 used? 7 She's not going to answer those questions. Q (BY MS. MENNINGER) You can answer a 8 A That's correct. 8 question about whether your attorneys had told you to 9 Q And the Mar-a-Lago records that you 9 lie. Because that would be a crime, and I'm sure -- 10 reviewed you received by e-mail at that e-mail 10 11 address? 11 12 A Possibly. I mean, I can't say 12 13 100 percent. I could have been told about them. I 13 14 could have seen them on a piece of paper. I really 14 15 don't know. This is a very hazy subject. All I know 15 16 is that I found out and that was able to clarify a 16 17 lot of dates for us. 17 Q Okay. What other dates were clarified? A I will -- Q -- I'm sure you want to tell me that your attorneys did not tell you to lie, correct? A I can tell you for a fact my attorneys have never told me to lie. Q All right. And did your attorneys tell you to change a date? MR. EDWARDS: Objection. She's not 18 answering any questions about communications between 19 MR. EDWARDS: I object and instruct the 19 her lawyers and herself, period. 20 witness not to answer if any of your knowledge is 20 21 based on any privileged communication that you had 21 direct your attention to Defendant's Exhibit 8. It's 22 between yourself and any of your lawyers. 22 the manuscript. If you could turn to page 40. 18 23 24 25 Q (BY MS. MENNINGER) Okay. You just said you reviewed records yourself, correct? MR. EDWARDS: Object. That 23 24 25 Q (BY MS. MENNINGER) So if I could also THE VIDEOGRAPHER: I just have a quick request, Counsel. Ms. Giuffre, would you mind bringing the VIRGINIA GIUFFRE 5/3/2016 25 (97 - 100) Agren Blando Court Reporting & Video, Inc.Page 28 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 103 Page 101 1 mic higher up on your jacket, please? 1 2 THE DEPONENT: Sure. 2 3 THE VIDEOGRAPHER: Thank you. 3 4 THE DEPONENT: Tell me if that's okay. 4 If you remember the answer, please tell her the answer. A I don't know the answer, where I spent my sweet 16th birthday. Q (BY MS. MENNINGER) Do you know who you 5 Better? 6 A Okay. Page 40? 6 Q (BY MS. MENNINGER) Right. Do you see the 7 A No, I don't. 8 Q Do you know where you lived on your sweet 7 8 5 first full paragraph on that page? 9 A I do. 10 Q The first line begins: I spent my sweet 9 A No, I don't. Q Were you living with your parents on your 16th birthday on his island in the Caribbean next to 11 12 Little (sic) St. James Isle. He liked to call it 12 13 Little St. Jeff's. His ego was enormous as his 13 14 appetite for fornicating. 14 Do you see that sentence? 15 16 A I do. 16 17 Q That is not true, correct? You were not 17 18 spending your sweet 16th birthday on Little St. James 18 19 Isle, correct? 19 20 A Based on my knowledge at the time that I 16th birthday? 10 11 15 were with on your sweet 16th birthday? 20 21 wrote this manuscript, I thought I did spend my 16th 21 22 birthday there. And so I put it down in there as 22 23 that. Now I know that it wasn't my 16th birthday. sweet 16th birthday? A I don't know. Q Were you living with on your sweet 16th birthday? A I don't know. I was a runaway a lot. I don't know where I lived at the time. Q Okay. Were you working at Taco Bell on your sweet 16th birthday? A I don't think so. I don't know. Q Were you working at Publix on your sweet 16th birthday? 23 A I don't know. 24 Q Or your sweet 16th birthday? 24 Q Were you working at an aviary on your 25 A Well, we -- 25 sweet 16th birthday? Page 102 MR. EDWARDS: Object to the form. 1 2 3 4 5 Harassing. Q 2 (BY MS. MENNINGER) Was it your sweet 16th birthday? A Page 104 1 3 4 Is it not custom to call your 16th 5 A Again, I don't know. Q Do you recall any present you actually got on your sweet 16th birthday? A No, I don't. I don't know where I spent it, who I spent it with or what I got. I'm sorry. 6 birthday sweet? Have you never heard that saying 6 Q How long did you work at Mar-a-Lago? 7 before? 7 A Best of my recollection, it was a summer 8 Q 9 10 Ms. Giuffre? A 15 16 MS. MENNINGER: She asked me a question, 17 18 19 20 actually. You're not testifying here. Q A 22 Q 23 As I thought, in the manuscript when I Okay. Now that you know it wasn't, where only worked there approximately two weeks, two, three weeks. 11 Q How many hours a week did you work? 12 A I want to say it was a -- I want to say 13 it's a full-time job. Q Do you recall it being a full-time job? A It was a summer job, but just thinking 16 back, my dad used to bring me in and bring me home. 17 So he worked full time, all day. So -- and I didn't 18 lounge around Mar-a-Lago so, yes, I think it would 19 have been a full-time job. 20 Q And how much did you make per hour? Well, I don't know. 21 A Approximately, I think I remember making Well, just give us your best guess. 22 did you spend your sweet 16th birthday? 21 9 (BY MS. MENNINGER) Was it your sweet 16th 15 wrote it, I thought it was my sweet 16th birthday. Q job. I believe I started in June. And I think I 14 birthday? A 8 10 It's been asked and answered. 13 14 As we -MR. EDWARDS: She's answered the question. 11 12 Was it your sweet 16th birthday, MR. EDWARDS: Objection. And she's not 23 $9 an hour. Q The bracelet and earrings you got for your 24 going to guess today. She's going to tell you the 24 birthday, some birthday, on Little -- or where was 25 answers as she remembers them. 25 that birthday party, at Little St. James? VIRGINIA GIUFFRE 5/3/2016 26 (101 - 104) Agren Blando Court Reporting & Video, Inc.Page 29 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 107 Page 105 MR. EDWARDS: Object to the form. 1 1 Q Well, all right. We'll come back to that 2 Q (BY MS. MENNINGER) Where was it? 2 in a minute. But the apartment that you left in 2002 3 A At Little Saint Jeff's. 3 was the one in Royal Palm Beach that you lived at 4 Q Okay. Where are those bracelet and 4 originally with 5 with 6 talking about? 5 earrings now? lived there? That's the one we're 6 A 7 Thailand. 7 A Correct. 8 Q Where did you leave them, exactly? 8 Q That's the apartment we're talking about? 9 A I had a storage facility and my apartment 10 11 12 I left everything behind me when I went to and then after breaking up that I lived in. Q So where were they, in the storage facility or in the apartment? 13 A 14 15 9 A That's not the one that -- 10 Q Okay. 11 A Sorry. I'm confused. Could you please 12 reask the question? Most likely in the apartment. 13 Q Okay. What apartment was that? 14 A Royal Palm Beach. I don't know the 15 A address, I'm sorry. Q All right. I asked you where you left your bracelet or earrings. You think you -Okay, yes. 16 Q -- left them in an apartment, correct? 17 Q You don't know the address at all? 17 A Okay. Yes. Yeah, not the one -- not the 18 A Not at all. 18 19 Q Okay. Where was it roughly located in 19 16 20 Royal Palm Beach? A 20 I don't know. It's been a long time since first one. The one where Q eventually moved into. That's the apartment you left the bracelet and earrings at? 21 A I believe so, yes. 22 I've been back to Royal Palm. I don't remember 22 Q So when you were working at Mar-a-Lago, 23 street names or anything. 23 21 you rode with your father every day? 24 Q Did it have one or two bedrooms? 24 A Yes. 25 A It was two bedrooms. 25 Q What car did he drive at the time? 1 Q Was it on the first or second floor? 1 A I don't know. 2 A The second floor. 2 Q Okay. Did you have a vehicle of your own 3 Q Who lived there with you? 3 4 A Page 106 5 6 7 8 And Q first lived there with me. 4 A No. 5 Q Did you have a driver's license at the lived there with me. 6 Okay. And that's the apartment that you left when you went to Thailand? A Yes. Q Did you live at more than one apartment 11 with 12 A Q A 16 Q 17 9 When I was a runaway, he let me stay at his apartment. 15 7 8 9 14 at the time? and I broke up shortly after living there. 10 13 Page 108 10 time? A Yes. I got my permit when I was 15 and my driver's license when I was 16. Q Okay. And how were you paid, by cash or check or some other method? 11 A I don't remember. 12 Q Did you have a bank account at that time? A I don't think I've ever had a bank 13 Was that a different apartment? 14 account -- well, up until recently, living here. I Yes. 15 don't remember having a bank account. All right. So you lived at 16 apartment when you were a runaway? 17 Q So you believe you got paid by unknown means and you did not deposit it into a bank? 18 A Correct. 18 A Correct. 19 Q And did you live anywhere else other than 19 Q What was your uniform when you worked 20 21 22 those two apartments with A We stayed at 20 parents' house, I think for a few weeks before the apartment. A At Mar-a-Lago? 22 Q Right. A It was a white miniskirt with a little 23 Q Okay. The apartment that you rented? 23 24 A The apartment that 24 25 rented. I think I was too young to go on a lease. there? 21 25 white polo top with the emblem of Mar-a-Lago on it. Q Did they give you more than one? VIRGINIA GIUFFRE 5/3/2016 27 (105 - 108) Agren Blando Court Reporting & Video, Inc.Page 30 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 109 Page 111 masseuses had their own uniforms. 1 A I don't know, maybe. 1 2 Q Did you wear it to and from work every 2 Q What did the masseuses' uniform look like? 3 day? 3 A I don't remember. 4 A Yes. 4 Q No recollection at all? Q Did you get new ones when you arrived that 5 A None whatsoever. 6 Q Color? 7 A No, sorry. I remember mine. 8 Q Okay. How did it come to pass that you 5 6 7 8 9 10 11 12 13 were clean or did you launder them at home? A I would have had to wash them when I got home, I suppose. Q And you think you had more than one or you don't recall? 9 weeks? A I was approached by Ghislaine Maxwell. Q Okay. And how long had you been working A I don't recall. 11 Q All right. Was that something you 12 purchased or did they give it to you? 13 at Mar-a-Lago when you were approached by Ghislaine Maxwell? 14 A They gave it to me. 14 15 Q And who else was wearing that uniform? 15 A The other locker -- the lady that did the 16 16 17 front desk next to the locker rooms. were no longer working at Mar-a-Lago in two to three 10 17 A Roughly two to three weeks. Q Okay. Where in the spa were you when you were approached by Ghislaine Maxwell? 18 Q She had the same one? 18 19 A Yes. 19 where the other girl that works there usually sits. 20 Q Was that Adriana? 20 She was away from the desk. I was reading a book on A I don't think Adriana wore a uniform. I 21 massage therapy. 21 22 think she just dressed professional. 22 A Just outside the locker room, sitting Q Was that indoors or outdoors? 23 A Outdoors. 24 see there at the spa at the time when you worked 24 Q Okay. And what -- were you in the sun or 25 there? 25 23 Q Okay. And what other employees did you in the shade? Page 110 1 A There were -- well, this is in the massage Page 112 1 A In the shade underneath a -- I don't know 2 area and there's also like a fitness area. So 2 what you'd like to call it, but, you know, underneath 3 there's spa and fitness. So there would be the 3 the complex, the building. 4 masseuses and then there would be the trainers. And 4 5 that was just located in that one area away from the 5 6 main house and stuff. Q All right. And what was Ghislaine Maxwell wearing when she approached you? 6 A I don't remember what she was wearing. 7 Q And is that the area in which you worked? 7 Q Any recollection, color of clothing or 8 A Yes. 8 9 Q In the spa area or the fitness area? 10 A The spa and the fitness area were in the 11 12 13 14 15 16 17 18 19 same complex. Q 9 A No. 10 Q Okay. Any details about her? Was she 11 Okay. What did the other people who worked in the spa area wear? anything? 12 carrying a purse or anything? A No. She looked like, from my memory, she 13 looked like she was either there for a massage or A I don't remember what they wore. 14 fitness. I remember she had a British accent. She Q All right. And what did the people in the 15 was very interested in the book that I was reading. fitness area wear? A I mean, we can get into some more details 16 I don't remember. I know it was -- we had our own uniforms. Everyone else had their own. 17 later if you'd like, but I don't remember any more 18 about what she was wearing that day. Q Who is we? 19 A Well, the girls that worked in the meet Q Did you have a cell phone at that time? 20 A No. 21 and greet area. Me and the other girl with the curly 21 Q Where were you living at that time? 22 hair I told you about -- 22 A At my parents'. Q And who else was living there with you at 20 23 Q Um-hum. 23 24 A -- had our own uniforms. And then the 24 fitness people had their own uniforms. And the 25 25 the time? A My mother and my dad and my brother. VIRGINIA GIUFFRE 5/3/2016 28 (109 - 112) Agren Blando Court Reporting & Video, Inc.Page 31 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 113 1 Q Which brother? Page 115 1 there's one in Royal Palm and Wellington, and I used 2 to go to both. 2 A 3 Q What about your other brother? 3 Q Did you have a card for both? 4 A I think he had moved out by then. 4 A Did I have a card? Q What forms of communication did you have? 5 Q A library card? 6 A Yeah. 5 6 Just a home phone number, or what? 7 A Yeah, there was a home phone. 7 Q For both places? 8 Q When do you recall ever getting a cell 8 A To be able to rent out a book, yeah. 9 phone? Q Okay. So the best of your recollection is 10 11 12 13 14 A 9 The first cell phone I ever got was the one that Ghislaine gave to me. Q So you never had -- your parents, did they have ones when you were working at Mar-a-Lago? A No, my dad used to -- like, we had phones 10 you used one of your library cards at one of those 11 two libraries to check out a book on massage and 12 anatomy? 13 14 A Correct. Q And when did you do that relative to 15 in the spa and maintenance area and so on, so forth. 15 16 And you could, so to speak, page people from around 16 17 the courts. 17 saw what the massage therapists got to do. I mean, 18 their jobs were so relaxing. The music, like the atmosphere, they always had happy clients. It just seems like an ideal job. 18 Q Okay. So tell me what you recall of the 19 first conversation that you had with Ghislaine 19 20 Maxwell. 20 21 A I'm sitting there reading my book about 21 starting at Mar-a-Lago? A Q Probably within the first week. I mean, I And so you were spurred to go to the 22 massage therapy, as I'm working in the spa. And I'm 22 23 getting my GE -- well, I was in the process of 23 24 getting my GED before I went to my summer job. I 24 massage therapists and they're the ones who first 25 decided that I would like to become a massage 25 intrigued me about what they do. And, you know, I library and check out a book? A Well, I had been talking with the other Page 114 Page 116 1 therapist one day. And the body really intrigued me, 1 wanted to aim for something higher than being a 2 you know, reading this massage was a lot about 2 locker room attendant one day. And. Yeah. 3 anatomy, blood flow. Everything to do with, you 3 4 know, touching somebody somewhere and then triggering 4 5 a result somewhere else. I just was very intrigued 5 6 by the whole anatomy thing. 6 She came up, Ghislaine, sorry. Ghislaine 7 8 came up and approached me at the desk that I was 9 sitting at. And my book was like this (indicating) 7 8 9 Q What was the name of the massage therapist that you were speaking with? A Oh, I have no idea. Q Can you give me any physical description of any of them? A Um, there was one who had blonde short hair. There was -- I would say there's probably 10 and she said, Oh, you're reading a book about 10 about four massage therapists that work in there. 11 massage. You want to do massage? And I told her, 11 So, I mean, I don't remember all of them. 12 Yes, you know, I'm very interested in it. One day I 12 13 would like to become a masseuse. 13 14 Q All right. Where did you get the book on Q Okay. What time of day was it? MR. EDWARDS: Object to the form. 14 A Afternoon. 15 Q (BY MS. MENNINGER) How late? 16 A Maybe the library. 16 A Anywhere between 2 to 4. 17 Q Maybe or do you recall? 17 Q And what time did you get off of work? 18 A I don't think I purchased it. So I'd have 18 A I believe I got off at 5. 19 Q And what was the rest of your conversation 15 19 massage? to say the library. 20 Q Okay. What library was that? 20 21 A Whichever library was close to my house. 21 Q Do you remember a library being close to 22 22 23 24 25 with Ms. Maxwell? I'm sorry, I don't think you finished. A Thank you. Well, she noticed I was 23 reading the massage book. And I started to have There's one in Wellington that I used to 24 chitchat with her just about, you know, the body and go to. Oh, no, there's one in Royal Palm. Yeah, 25 the anatomy and how I was interested in it. And she your house? A VIRGINIA GIUFFRE 5/3/2016 29 (113 - 116) Agren Blando Court Reporting & Video, Inc.Page 32 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 117 Page 119 1 told me that she knew somebody who was looking for a 1 A cell phone or a home phone, or do you have any 2 traveling masseuse. 2 idea? And I said, Well, I don't have any 3 3 A I have no idea. Ghislaine answered. So 4 accreditations. This is the first book I've ever 4 if it was a home phone, the butlers probably would 5 read. She goes, That's okay. I know somebody. We 5 have answered. So most likely it was her cell phone. 6 can train you. We can get you educated. You know, 6 7 we can help you along the way if you pass the 7 8 interview. 8 A If the guy likes you, then, you know, it Q All right. And what happened when you got off of work? My dad drove me to El Brillo Way. 9 Q Um-hum. 10 will work out for you. You'll travel. You'll make 10 A We arrived at a very large pink mansion. 11 good money. You'll be educated, and you'll finally 11 And we knocked on the door. My dad got out of the 12 get accredited one day. 12 car and we knocked on the door. 9 13 14 Q Okay. 13 A She finished off by, you know, giving me 14 Q Do you recall which car this was? A I don't know what he was driving at the 15 her number. And I told her I'd have to ask my dad. 15 time. My dad always drives trucks. So it would have 16 And I called my dad. I ran over, actually, to see my 16 been some kind of truck. 17 dad, talked to him. He said it would be okay. I 17 Q But you don't know which kind? 18 used the phone from Mar-a-Lago to call her and tell 18 A I don't know if it was a Ford or a Dodge 19 her that I was allowed to come over. 19 or -- 20 Q What kind of car does your mom drive? And she said, Great. Meet me here at -- I 20 21 don't remember the exact address, but it was 21 A Right now? 22 El Brillo Way in Palm Beach -- after you get off. 22 Q No, in 2000. 23 And my dad drove me. 23 A Oh, I have no idea. I don't remember. 24 25 Q Did you write down her add -- the address that she gave? 24 They change cars quite often. They like getting 25 different cars. Page 118 1 A 2 3 4 5 6 7 8 9 2 A After my trip to London to meet Prince 3 Andrew. 4 Q Okay. What kind of car did you get? 5 A A Dodge Dakota. 6 Q Did you write down her phone number? A Yes. Q So did you go run and talk to your dad while she was still there? A No, I believe she left. And she told me to ask my dad and then to give her a phone call. Q Okay. Did she ask you your age when she had that conversation with you? A 11 12 14 When did you get your first car? 1 10 13 Page 120 Q Yes. Q And did you purchase that yourself? 7 A Yes, I did. 8 Q And how much did it cost? A I don't remember off the top of my head 9 10 Q Did you tell her your age? 11 Q Who did you buy it from? A No, I did not. 12 A My dad helped me bargain with it. I don't Q And so somewhere you wrote down a phone 13 number to call her back at? 14 15 A Um-hum. 15 16 Q All right. And where did you write that 16 17 down? 18 19 how much it cost. No, she did not. A Probably just a piece of paper lying around the desk. remember where we bought it from. Q And was the title put in your name or your dad's name? A I think the title was put in my name. I 17 think. I mean, my dad was with me. I've never 18 registered a car or anything like that before. So -- 19 Q So that was your first time? 20 Q Okay. But you don't remember? 20 A Yes. 21 A I mean, no, I don't have that piece of 21 Q Memorable, right? 22 A Yes. Q When you got there, a butler or someone 22 paper anymore, so no. 23 Q Okay. And did you write down an address? 23 24 A Yes. 24 25 Q And what number do you think you called? 25 answered the door, is that what you said? A No, Ghislaine answered the door. VIRGINIA GIUFFRE 5/3/2016 30 (117 - 120) Agren Blando Court Reporting & Video, Inc.Page 33 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 121 1 Page 123 Q Okay. And then what happened? 1 A Q All right. Where did you see Mary? She shook hands with my dad. Like, she 2 A The same place, kitchen. 3 briefly opened the door. She stepped out, shook 3 Q Were they talking to one another? 4 hands with my dad. Told her (sic) she'd look after 4 A No. Mary was doing something with the 5 me and she'd make sure I get a ride home. And just 5 dishes. They were always either cleaning up or doing 6 very briefly, that was it. And my dad left, and I 6 stuff, so -- 7 went inside with Ghislaine. 7 Q And you saw them in the kitchen? 8 A In the kitchen area. I mean, you have to 2 8 9 10 11 Q Did Ghislaine and your dad have any discussion about what it was you were doing there, in your presence? A 9 10 You know, I can't recall exactly what was 11 understand there's like three parts to that kitchen. So it's very large. Q All right. What part did you see John in? A In the corner, left hand. And Mary was in 12 said. But I had already told my dad what was -- what 12 13 the interview was for. So -- 13 the same vicinity but not right next to him. They weren't chatting. 14 Q What did you tell your dad? 14 15 A That a very nice lady approached me and 15 Q What is also contained in the corner, left 16 told me that she would offer me an education to 16 17 become a massage therapist. And it was a great -- it 17 18 would be great experience for me to be able to get 18 don't know. Just shelves that I remember, you know, 19 educated and trained and eventually be accredited. 19 open door pantry stuff. 20 So he was very happy for me as well. 20 21 22 23 24 25 Q You told him that outside of the presence of Ghislaine? A 22 Yes, when I first ran to the tennis courts where he was at. Q 21 23 24 And then, in your presence at the home, 25 hand of the room? A Q There's like a -- like shelves with -- I What was Ms. Maxwell wearing when you arrived at the home? A I don't remember what she was wearing. Q The book that you were reading at the spa that day, do you recall the name of it? A No. I just know it was -- it said the Page 122 Page 124 1 did your dad and Ms. Maxwell have any conversation -- 1 word massage on the front of it. I don't know the 2 further conversation about what you were doing there? 2 title or the author. 3 A I don't recall. I think they probably 3 4 would have chatted for approximately -- maybe 30 4 5 seconds. It really wasn't a long chat. 5 The things that stick out in my mind were, 6 6 7 We will take good care of her and we'll be 7 8 bringing -- we will make sure she gets a ride home. 8 9 Q And how far away did you live? 10 A Approximately 30 minutes. 10 Q And that's with your parents' house, 11 12 9 right? Q Do you know the color of the book? A It was -- it was dark. It was a, like plastic covering. Q All right. And how big was it, if you can just demonstrate for the video? A Smaller than that. Maybe -- I don't -- maybe a little bit less than that. Q Can you hold it sideways for the video? 11 A (Complied.) 12 Q So you're saying the book size was a 13 A That was my parents' house. 13 14 Q Did you see any other employees or any 14 little bit less than half of -A Right. I mean, the book was a little bit 15 bigger. The pages were -- you know, this is very 16 A Yes. 16 small print. This is printed A4 longways, whereas, I 17 Q Who else did you see? 17 think. It wasn't A4 that way. I don't know. It was 18 A Juan Alessi. 18 just a book. And I don't know how many pages it had 19 Q Um-hum. 19 either. I mean, approximately, maybe 100 pages. A And Maria. But Jeffrey and Ghislaine like 20 15 20 21 other people inside the house on that day? to call them John and Mary. 21 Q Okay. So maybe my question wasn't a very good question. How big was the outside of the book, not 22 Q Okay. Where did you see John? 22 23 A Downstairs after the whole ordeal. 23 24 Q Um-hum. Which room? 24 A Maybe like here (indicating). 25 A The kitchen. 25 Q So a little bit bigger? the thickness, but the length and the width? VIRGINIA GIUFFRE 5/3/2016 31 (121 - 124) Agren Blando Court Reporting & Video, Inc.Page 34 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 125 1 A Longer than this, yeah. We're going to Page 127 1 A Yes. 2 fold it in half again, and then like that 2 Q Who else was at home when you got home? 3 (indicating). 3 A My mom, my dad and my brother. 4 Q Which brother? 5 A Sky. 6 Q And anyone else who was there at the time? A I believe Michael might have been living 4 5 Q 11 piece of paper? MR. EDWARDS: Form. 6 7 So larger than an 8 and a half and A I don't know what 8 and a half and 7 8 11 inches is. If this is 8 and a half and 11 inches, 8 9 then yes. It's (indicating). 9 10 Q (BY MS. MENNINGER) So when you fold it in 10 with me at that time. So he might have been there. Q Do you recall if he was there when you got home? 11 half, is that a little bit smaller, folded in half, 11 12 than the book -- 12 I did when I got home, that I basically made a 13 beeline for the bathroom. 13 A Yeah, if I were going to hold the book A I don't really remember. I remember what 14 like this, if I were going to sit there and read the 14 15 book like this, in my mind it would be a little bit 15 living with you at that home, at your parents' home 16 bigger than what I'm holding right here. 16 at the time, is your best recollection today; is that 17 right? 17 18 Q book as it's opened that way? 19 A 20 this. 21 Q 18 Yeah, let's just say I'm reading it like 19 20 Okay. Got it. MS. MENNINGER: I'm going to suggest we 22 23 All right. So you're demonstrating the Q take a short break. We can -- Let me ask you a question. Michael was A That's my best recollection, yes. Q When you say living with you, were you guys staying in the same room? 21 A Yes. 22 Q Were you engaged at that time to him? A That was a really weird relationship. He 23 24 MR. EDWARDS: Order -- 24 was a friend who looked after me, and he did propose 25 MS. MENNINGER: -- order lunch for you 25 to me and I did say yes. But my heart was never in Page 126 Page 128 1 guys and then do a little bit more before the lunch 1 2 gets here -- 2 3 4 5 MR. EDWARDS: Okay. 3 MS. MENNINGER: -- if that works for 4 everybody. it. He was somebody that helped me off the streets so I felt compelled to say yes to him. Q Okay. So when he proposed to you and you 5 said yes, did that take place before you started 6 MR. EDWARDS: Yeah, that's great. 6 working at Mar-a-Lago or after you started working at 7 MS. MENNINGER: All right. Let's do that. 7 Mar-a-Lago? 8 THE VIDEOGRAPHER: We're off the record at 8 9 11:38. 11 11:57 a.m.) THE VIDEOGRAPHER: We're back on the 12 13 14 15 9 (Recess taken from 11:38 a.m. to 10 record at 11:57. Q Before. Q And so if he were living with your parents 10 at that time, you were living in the same room; is 11 that correct? 12 13 (BY MS. MENNINGER) How long were you at 14 the El Brillo home on that first day you went? A 15 A I believe so. Q And your parents understood him to be your fiance? A I don't think they agreed with it, but I think they understood it as that. I mean -- 16 A Over two hours. 16 17 Q Okay. And who took you home? 17 18 A Juan Alessi. 18 19 Q And what car was he driving? 19 20 A I believe it was a black Suburban. 20 they obviously weren't very happy about it. And it 21 Q Did anyone else ride in the car with you? 21 wasn't my true intentions to ever marry him. 22 A Just Juan. 22 Q Okay. 23 Q What time approximately did you get home? 23 A But I did it to make him feel okay. I 24 A 8:30, approximately. 24 25 Q Was it dark? 25 Q I mean, you communicated to them that he had proposed and you had accepted? A Yeah, in not such a pretty way. I mean, didn't want to be mean. Q What did your mom say about your VIRGINIA GIUFFRE 5/3/2016 32 (125 - 128) Agren Blando Court Reporting & Video, Inc.Page 35 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 129 1 2 3 4 5 engagement to A A 2 I can tell you that she had very large 3 natural breasts. I can tell you that her pubic hair 4 was dark brown, nearly black. I don't remember any 5 specific birthmarks or moles that I could point out 6 that would be relevant. Q And what did you do in the bathroom? 7 Q Any scar? A I showered. 8 A I don't remember any scars. Q Okay. Did you have a conversation with 7 8 11 physical features of Ghislaine Maxwell? Correct. A 9 When you got home, you said you made a beeline for the bathroom? 6 10 Oh, they never thought it was going to go forward either. Q Page 131 1 anyone prior to going to the bathroom? A My mom came into the bathroom and -- and 9 Q Any tattoos? 10 A No tattoos. 11 Q When did you next go to the El Brillo 12 she, you know, she asked me how it went. And I told 12 house? 13 her I'd rather not talk about it. And she didn't 13 A 14 push me any further for any more conversation. 14 Q I believe it would have been the next day. You believe it would have been or was it? Q Okay. And then she left the bathroom? 15 16 A She left the bathroom. 16 17 Q Did anyone overhear that conversation? 17 continued to go there after my first -- the first 18 A No, the door was closed. 18 time that the abuse took place there. It was 19 Q Was your dad at home? 19 consecutive that I was there, I believe, over the 20 A Yes. 20 next course of weeks. Q Did you have a conversation with your dad 21 15 21 22 that night? 22 MR. EDWARDS: Form. A Q I know that it was consecutive, that I (BY MS. MENNINGER) What day of the week was the first time you went? 23 A Not that I remember, no. 23 A I don't know. 24 Q And did you have any other conversation 24 Q Do you know whether you went the very next 25 with your mother that night? 25 day or not? Page 130 1 2 3 4 5 6 No. 1 Q Did you have any conversation with your 2 brother that night? A 9 10 11 3 No. He's -- he's five years younger than me. It's not something I'd talk to him about. Q And did you have any conversation with A I could have. I don't remember having one, but I could have. Q night? 12 A No. 13 Q Who were your good friends at that time? 14 A (phonetic). That was I believe I did. Q All right. How did you get there the very MR. EDWARDS: Form. 4 6 A I believe my dad dropped me off again. Q (BY MS. MENNINGER) When you say you 7 believe, do you recall him doing that or are you 8 guessing? A 9 Did you call any of your friends that A next day? 5 that night? 7 8 Page 132 A I don't -- well, this is how I figure 10 this. I don't remember Ghislaine picking me up from 11 Mar-a-Lago. I didn't have my own car. So the only 12 way I could have really gotten there would have been 13 my dad picking me up -- I mean, sorry, dropping me 14 off. Q Do you have a distinct recollection of 15 really it. I didn't really have many friends. I 15 16 kept to myself a lot. 16 your father dropping you off there more than one day 17 in a row? 17 Q Did you call A I don't think that night? 18 A Yes. 19 on and off friends from middle school. And no reason 19 Q You do not recall the car he was driving? 20 on and off like we had an argument or something. We 20 A Like I said, he always drove trucks. 21 just got out of touch. 21 18 and I were -- we were 22 Q Um-hum. 22 23 A So, no, at that time I don't think I was 23 24 25 talking to him. Q Are you aware of any distinguishing That's as good as I can get. Q And so -- and you worked on weekends as well at Mar-a-Lago or no? 24 A No. 25 Q So the second day would have had to be VIRGINIA GIUFFRE 5/3/2016 33 (129 - 132) Agren Blando Court Reporting & Video, Inc.Page 36 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 133 1 another weekday or was it on a weekend? MR. EDWARDS: Form. 2 Page 135 1 A I don't know. 3 4 Q (BY MS. MENNINGER) Do you know if you 4 6 7 8 went after work at Mar-a-Lago? Yes. 6 Q So you went to work the very next day at 7 Mar-a-Lago? 9 A Yes. Q Did you have a conversation with anyone at Mar-a-Lago about the day before at El Brillo? So did you introduce yourself as Virginia or as Jenna? 5 A 10 11 Q 2 3 5 time. A Most likely Jenna. Q Do you recall this or is this something that you're guessing about? A Well, considering that everybody knew me 8 as Jenna, I think I would have introduced myself as 9 Jenna. Q 10 You don't recall it? MR. EDWARDS: Form. 11 A I don't recall the exact answer to that, 12 A No. 12 13 Q You didn't talk to any of your coworkers 13 no, but just knowing I had everybody pretty much call 14 me Jenna. 14 about it? 15 A No. 15 16 17 Q Who was your boss at the time? 16 make a clear record about what you do remember and A No. 17 what you're guessing about. So when you say I think 18 Q Did you have a boss at the time? 18 I would have, it leads me to believe you don't recall 19 A I think Adriana or Adrienne. I don't 19 it. 20 remember the exact pronunciation of her name, but 20 21 it's along those lines. I believe she was my boss. Q (BY MS. MENNINGER) I'm just trying to If you mean something different by that -- 21 A I -- Q And you did not talk to her about it? 22 Q -- please feel free to clarify. I'm just 23 A No. 23 24 Q You surmise that your father dropped you 24 22 25 off because you can't think of another way you would 25 trying to explain to you what I'm asking. A Yes. And I'm doing the very best that I can tell you exactly what it is. But it's just hard Page 136 Page 134 1 have gotten there, correct? 1 for me to remember so long ago. And knowing that I 2 A Correct. 2 introduced myself as Jenna to everybody leads me to 3 Q And when you came the second day, did your 3 assume that I would have introduced myself to them as 4 Jenna as well. 4 5 6 7 8 father come to the door? A I don't think he came to the door that 5 time. I think I was just dropped off. Q Q All right. But if we were to speak to , she might have a different recollection, 6 All right. And what did you do when you 7 got there? fair to say? MR. EDWARDS: Form. 8 9 A Knocked on the door and -- 9 A 10 Q Who answered the door? 10 Q 11 A Juan Alessi. 11 12 Q Okay. Was anyone else there besides Juan 12 A 13 Alessi? 13 Q When were you asked to come back? 14 A Jeffrey, Ghislaine and 14 A The day before, after the encounter they 15 Q Okay. And where did you see 16 A 17 . ? 15 She could. (BY MS. MENNINGER) How is it that you knew to come there on this second day? I was asked to come back. told me to come back at the same time after work. She was downstairs. 16 Q Who is they? Q Did you speak to her? 17 A Jeffrey and Ghislaine. 18 A Just introductions. 18 Q Okay. Did they both simultaneously say 19 Q Tell me what you mean by introductions. 19 A My name is Virginia. Nice to meet you. 20 20 21 Her name, she introduced herself as 22 told me she was Ghislaine's personal assistant. 23 24 25 Q And she Did you call yourself Virginia at the time? A that or did one of them say it? A had with me separately. Jeffrey told me upstairs 22 after the whole entire abuse had happened that he 23 really liked me and he'd like me to come back. When I went downstairs -- 24 No, I think I've gone by Jenna for a long It was like a conversation that they both 21 25 Q Let me just stop you there. Did he say, I VIRGINIA GIUFFRE 5/3/2016 34 (133 - 136) Agren Blando Court Reporting & Video, Inc.Page 37 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 139 Page 137 1 want you to come back tomorrow? 1 2 A Yes. 2 3 Q Okay. Did he tell you what time tomorrow 3 4 5 6 7 8 9 10 11 12 he wanted you to come back? A Q Okay. And then you went downstairs and what happened? A Ghislaine told me I did a really good job Q That's what she said, I want you to come back tomorrow after work? It was continuous. Name one girl that A Emmy Taylor. I mean, that's a name that I 5 know well because Emmy was always around. 6 I'm trying to think of her name, sorry. 7 Sarah. Her name used to be Sarah Kellen. I think 8 she's changed it now that she's married. (phonetic) -- I can't 10 pronounce her last name properly, but it's around 11 those lines. 12 There were a lot of other girls that I Yes. 13 honestly can't remember their names. I'm sorry. I Q You recall those words being used by her? 14 wish I could help out more because I really would A Yes. 15 like to provide more witnesses for this, but I can't Q Did you ask them for a ride to get there 16 remember a lot of girls' names. 14 15 the next day? 17 18 A No. 18 19 Q You just said, I'll come back tomorrow. 19 20 A Yeah. I agreed to come back the next day. 20 21 Q How did you agree? 21 22 A Verbally. 22 Q Okay. Was anyone else present when 23 23 Q Ghislaine Maxwell had sex with in your presence. 9 and she wants me to come back tomorrow after work. A 17 No, he just said he wants me to come back tomorrow. 13 16 4 of girls. It was continuous. 24 Ghislaine said that to you and you responded, I'll 24 25 come back tomorrow? 25 Q So those are the three names of females that you observed Ghislaine Maxwell have sex with -MR. EDWARDS: Object to the form. Mischaracterizes testimony. Q (BY MS. MENNINGER) -- is that what I understand your answer to be? MR. EDWARDS: Objection. Mischaracterizes her testimony. A Those are -- those are some three of the Page 138 1 2 A I believe Juan Alessi was pretty much within ear distance. Page 140 1 names that I know very well. Like I said, there was 2 a lot more. Q (BY MS. MENNINGER) Okay. Do you know the Q Could you see him? 3 4 A Yes. 4 names of any other girl that you personally observed 5 Q Okay. 5 Ghislaine Maxwell have sex with? A Like I said, in ear distance, when I mean 6 3 6 7 ear distance like hearing, in the hearing vicinity. 7 8 And it was in the same time that she was asking him 8 9 to drop me off at home. 10 Q 9 Okay. When you were driving home the A Do you mind me taking a minute to just try to reflect? Q No. A Um, her name is on the tip of my tongue. 10 Her last name is I don't remember her 11 first night with Juan Alessi, did you have any 11 first name off the top of my head. I normally could 12 conversation with him? 12 remember it. 13 14 A No. I had told him my address. It was a very quiet ride. 13 Q Okay. 14 A There's just a blur of so many girls. 15 Q Did you ride in the front or the back? 15 It's really hard for me to remember. And you have to 16 A The front. 16 understand we weren't introduced to each other on a 17 Q It is your contention that, Ghislaine 17 first name basis half the time. A lot of these girls 18 Maxwell had sex with underage girls virtually every 18 would come and go and you'd never see them again. 19 day when I was around her, correct? 19 So, no, it's very difficult for me to 20 A Yes. 20 pinpoint exactly who they were. But those four that 21 Q All right. With whom did Ghislaine 21 I've given you are 100 percent. 22 23 Maxwell have sex in your presence? A 22 Well, there's a lot of girls that were Q Okay. Did you observe Ghislaine Maxwell 23 forcing any of those four girls to have sexual contact with her? 24 involved. We weren't on a first name basis with each 24 25 other. I wouldn't be able to give you lists of names 25 MR. EDWARDS: Form. VIRGINIA GIUFFRE 5/3/2016 35 (137 - 140) Agren Blando Court Reporting & Video, Inc.Page 38 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 141 Page 143 1 2 involved were truly willing participants doing it out 2 3 of their own wanting. I believe we were all there 3 4 for one purpose, and that was to keep Jeffrey and 4 wouldn't want to piss me and Jeffrey off. I mean 5 Ghislaine happy and to do our jobs, which was giving 5 that's one way of saying it. Other than -- 6 them erotic massages and keeping them pleased 6 7 sexually. 7 8 Q 8 9 10 11 A Mischaracterizes her testimony. I don't believe that any of the girls 1 (BY MS. MENNINGER) Okay. Do you know what the word force means, physical force? A 9 If you mean like held down or a gun put to the head, then no. 10 11 You can answer. A Q You wouldn't want to piss us off. You (BY MS. MENNINGER) Did she say, I don't want -- you would not want to piss me off? A Piss me off is probably my word, using piss, but it was along those lines. I don't remember the exact word that she used. Q And do you remember a specific occasion on which she said that to you? 12 Q Okay. 12 13 A But force in a word -- like a way of 13 A 14 coercion. There was definitely indirect threats that 14 Q Where were you? 15 you knew these people were powerful. They had a lot 15 A I believe it was during my, what I call 16 of contacts. They were very wealthy. They were 16 17 people you did not want to cross lines with on a bad 17 18 way. 18 19 Q 20 21 22 23 24 25 I remember very early on. the training period with Jeffrey and Ghislaine. Q Okay. And where were you? A For a specific -- and like I said, it 19 happened a lot. But for one specific, I remember 20 being out on the balcony in the house at El Brillo, 21 sitting outside with her. This is when I thought 22 that -- I didn't know that I worked for Jeffrey When did Ghislaine Maxwell remind you 23 immediately. I thought I worked for Ghislaine about the prominent people that she knows personally? 24 because she was the one who brought me in. And she 25 was the one offering the majority of the training to Okay. What threats did you hear Ghislaine Maxwell state to you? A Just the reminders of the prominent people that she knows personally. Q A It was on a constant basis. I mean, there Page 142 Page 144 1 was no just one time that she said it. It was like a 1 2 reminder, you know. And Jeffrey did a lot more of 2 3 that than she did. But she definitely made it aware 3 4 that we shouldn't cross boundaries with them. 4 5 me. So, yeah, it was on the balcony, outside, I believe the yellow room. Q She said, You would not want to piss me Q Or what would happen? 5 off because I know powerful people, or words to that A Like I said, it was more of an indirect 6 effect? 7 threat. And it doesn't take an intellect to figure 7 A Words to that effect, yes. 8 out what they mean when they say that they're 8 Q And did she say what would happen if you 9 powerful people and they're very wealthy and they 6 10 know a lot of people. A That statement alone was enough to let me 11 know. I was scared and I didn't want to -- I didn't used the word "they." I've asked you about Ghislaine 12 want to push any further into that question. I 13 Maxwell. 13 seemed like I would obey. 14 15 16 17 18 19 I need you to be very clear. You just pissed her off because she knows powerful people? 12 11 Q 9 10 A Okay. 14 Q So I just want to make sure you understand 15 the question. Q Up until that point in your life, had you met any powerful people? MR. EDWARDS: Form. 16 A Correct. 17 Q Because I don't want to have you, you 18 dangerous situations, being a runaway and having a 19 lot of bad things happen to me. Understanding the know, misunderstand the question. A I do believe that I've been put in very 20 A Correct. 20 word powerful people and things that could happen, 21 Q So I'm asking you, what did Ghislaine 21 I've put two and two together and knew what she meant. 22 Maxwell say would happen in regards to crossing a 22 23 line with respect to her knowledge of famous people? 23 24 25 A In a -MR. EDWARDS: Object to the form. Q (BY MS. MENNINGER) Okay. So you had met 24 powerful people before the day that Ghislaine Maxwell 25 said this to you; is that your testimony? VIRGINIA GIUFFRE 5/3/2016 36 (141 - 144) Agren Blando Court Reporting & Video, Inc.Page 39 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 145 1 A Nowhere near as powerful as Jeffrey and Page 147 1 of all the girls that were sent to Jeffrey and Ghislaine. That is my answer. 2 Ghislaine, nowhere near. But people that did scare 2 3 me, yes. 3 4 Q 4 about the girls who were sent to Jeffrey and 5 Ghislaine. I asked you about any girl that you 6 personally saw have sexual contact with Ghislaine Maxwell. 5 6 Okay. And you had met those people at what age? A I don't know what age I was. I'm sorry. 7 I was young. I was -- before I met Jeffrey and 7 8 Ghislaine. 8 Q Is there any girl who you personally Q (BY MS. MENNINGER) I did not ask you Do you understand that question? 9 A Do I know the ages of them? 10 observed to have sexual contact with Ghislaine 10 Q Do you know the age of any girl that you 11 Maxwell when she was under the age of 18? 11 9 12 A It's very hard to tell how many girls were 12 saw have sexual contact with Ghislaine Maxwell? A Well, for instance, I mean, 13 under the age of 18. My instruction from them was 13 was, I think, a year older than me. That's one way 14 the younger the better. 15 14 of putting it. Q And, again, them, who told you that? 15 older than me. A Them, both of them. They both -- I think was like a few years again, a few years older 16 than me. I mean, those are the girls that I can 17 Ghislaine did the majority of my training in the 17 actually name. 18 beginning. Jeffrey also insinuated and told me lots 18 19 of things as well. 19 names, there's no way for me to identify what age 20 they actually were. 16 20 Q Okay. So you don't know the age of any Without, not knowing the other girls' 21 other female that you saw have sexual contact with 21 22 Ghislaine Maxwell -- 22 other than the ones that you've named who you say you 24 Q 25 Okay. Describe for me any other girl 23 saw have sexual contact with Ghislaine Maxwell with (BY MS. MENNINGER) -- is that true? 24 your own two eyes. MR. EDWARDS: Object to the form of the 25 MR. EDWARDS: Object -- 23 Q A There's so many I don't know where you Page 148 Page 146 1 question. Mischaracterized her testimony. She 1 want me to start. I find it impossible to answer 2 wasn't finished with her answer. 2 that question with the amount of girls that I have 3 MS. MENNINGER: I wasn't finished with my 3 witnessed. And without being able to give you 4 question when you objected. And at the end of my 4 specific names, I don't think I'm able to answer that 5 question I said, "Is that true?" She can now restate 5 question. 6 it without you suggesting to her the answer. 6 MR. EDWARDS: I have no idea what the 7 8 question is to even object to at this point. Do you know the question? 9 10 11 A Ghislaine slept with. MS. MENNINGER: Can you please read back 12 13 the question? Okay. I asked you to describe them, so you could give me a height, a hair color, anything 8 else that comes to mind? 9 Do I know any underage girls that Q 7 A There were blondes, there were brunettes, 10 there were redheads. They were all beautiful girls. 11 I would say the ages ranged between 15 and 21. 12 13 Q And why do you believe the ages ranged from 15 to 21? 14 (Record read as requested.) 14 A Some of them looked really young. Some of 15 MR. EDWARDS: Hold on. She wasn't 15 them, I wouldn't say 21 looks old or anything like that, but it's hard to gauge another person's age 16 finished with her question, she told me. So that's 16 17 not the finished question. 17 without really asking them. But some of them looked 18 younger than me and some of them looked older than 19 me. MS. MENNINGER: You interrupted it. I 18 19 20 21 finished my question. She just read it to her. Q (BY MS. MENNINGER) Can you please answer 20 the question? 21 Q And in what physical locations did you see Ghislaine Maxwell have sexual contact with any girl? 22 A 100 percent, the U.S. V.I. 23 question as a mischaracterization of her testimony. 23 Q Where? 24 And she wasn't finished with her answer. 24 A Jeffrey's island. 25 Q Where? MR. EDWARDS: Then I object to that 22 25 A It is impossible for me to know the ages VIRGINIA GIUFFRE 5/3/2016 37 (145 - 148) Agren Blando Court Reporting & Video, Inc.Page 40 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 149 them as a woman. A woman is someone who is older. 2 But, yes, outside by the pool, down by the beach I do, thank you. 3 there's these -- they're little -- I wouldn't call it A In cabanas, in Jeffrey's room. 4 a hut. Little tiny wooden room that only could fit a Q Describe Jeffrey's room on U.S. V.I. for 5 bed in it. 6 Q I'm talking about outside. 7 A That's outside. 8 Q So let's start with by the pool. A 2 cabana? 3 Q 4 5 6 7 8 9 10 11 12 13 14 Page 151 1 1 In cabanas. Do you know what I mean by me. A So can I use this as an idea? Like if this is the island -- can I do that? Q I'm asking you to describe the inside of a room. A Oh, the inside of a room. I thought you meant located. 9 A Yes. 10 Q Is that a different occasion than the hut? 11 A I'm talking about many occasions. 12 Q Okay. Q Um-hum. 13 A Over time. A Okay. Large, stony. He had a king size 14 Q Let's just talk about the ones that you 15 bed with posts on it. There was a large door, I 15 16 think it's called a door, where you put your clothes. 16 A Okay. 17 There was an adjacent bathroom with a more stony 17 Q Okay? 18 look, giant tub. 18 A Yeah. Q Do you recall any such specific occasion saw happen outside, out of doors. 19 Q What color was the paint on the wall? 19 20 A It was stone. 20 21 Q What color was the bedspread? 21 22 A White. 22 Models were -- I think they were models -- were flown 23 Q What color were the sheets? 23 in. There were orgies held outside by the pool. 24 A White. 24 That's one occasion. 25 Q And you saw Ghislaine Maxwell have sexual 25 or is it just a big blur in your mind? A Q No, I mean, one occasion stands out. All right. Let's stick with that Page 150 Page 152 occasion. 1 contact with an unknown, unnamed female in that room, 1 2 correct? 2 A Okay. 3 A Absolutely. 3 Q What sexual contact did you observe Q All right. When were you there that you 4 Ghislaine Maxwell have with a female by the pool at 5 an orgy on the U.S. Virgin Islands? 4 5 6 saw this happen? A This happened on so many occasions. The 6 A Well, there was quite a few girls and it 7 island was a place where orgies were a constant thing 7 was -- excuse me, if I'm saying this in an inexplicit 8 that took place. And again, it's impossible to know 8 way, but I don't know how else to say it. So if you 9 how many. And, like I said, it wasn't just Jeffrey's 10 11 12 13 room. It was outside and, you know. It was -Q When you were outside did you see Ghislaine Maxwell have sexual contact with a female? A When you say sexual contact does that mean 9 don't understand, please let me know -- girl-on-girl 10 action. So there was a lot of -- what's the word for 11 it? Licking, licking vaginas, breasts. 12 13 Q Okay. Which -- A Fingers being used. She was involved with 14 fornicating or down to taking explicit photos or 14 that. I remember specifically I had to go down -- do 15 what -- can you define what you mean by sexual 15 you know what I mean by go down? 16 contact? 16 Q It's your testimony. Go ahead. 17 Q 17 A I had to go down on Ghislaine. Jeffrey Sure. It generally, in my mind, means 18 placing either mouth or intimate parts or hands on 18 19 the breasts, buttocks, or pubic area of another 19 20 person for sexual gratification. 21 22 was there as well. Q And this is -- we're still by the pool? We're still by the pool with lots of 20 A A Sure. 21 girls. Q Did you see Ghislaine Maxwell have sexual 22 23 contact with a woman outside on the U.S. Virgin 23 24 Islands? 24 25 A 25 I would say a female. I wouldn't define Q Can you name any of those girls that were there? A They didn't even speak English. But this was -- VIRGINIA GIUFFRE 5/3/2016 38 (149 - 152) Agren Blando Court Reporting & Video, Inc.Page 41 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 153 1 2 3 4 Page 155 Q Can you describe them physically? 1 A Beautiful, tall, some were blonde, some were sandy brown. They had a foreign tongue. Q More than 20? 2 A I would say more than 20. 3 Q More than 50? I don't think more than 50, but -- Q What -- what language were they speaking? 4 A A I'm not too sure. It could have been 5 Q Did -- 6 Russian. It could have been Czechoslovakian. It 6 A I don't have an exact number. I mean, 7 could have been -- I think it's between those two, to 7 if -- I think if you look at the flight logs, you 8 be honest. It could have been something else but, I 8 know, that helps, but then they're not fully 9 mean, I don't speak any other language other than 9 complete. We only have flight logs to one plane and 5 10 11 English, so I don't really know. Q All right. Any other time you saw 10 then there's a time I was flown commercially into the 11 island. 12 Ghislaine Maxwell have sexual contact with another 12 Q Um-hum. 13 female outdoors in the U.S. Virgin Islands other than 13 A So it's really hard for me to gauge a 14 this, models with the unknown language? 14 number. 15 Q 15 A 16 well? 17 Q Are we talking about besides with me as 16 I don't know if you participated. I'm 17 18 asking if you observed her have sexual contact with 18 19 another female? 19 20 A 21 22 Okay. Do you have any photographs of yourself on the island? A I know I used to, but they would be left in that apartment. Q What other locations did you participate Another female other than myself? 20 in sexual contact with Ghislaine Maxwell, other than Q You can answer it however you want. 21 the island? A Well, and the list keeps going on. 22 A Everywhere. New York, Palm Beach. 23 Ghislaine and I and Jeffrey and 23 Q Where in New York? 24 participated in, I guess what you would call a 24 A The mansion, Jeffrey's mansion. 25 foursome in the living room in the main house. 25 Q Okay. Anywhere else in New York? 1 A Not at her townhouse. 2 Q Anywhere else in New York? 3 A No. Page 154 1 2 3 Q Okay. I was asking about outdoors. Sorry. A Oh. Well, I don't know if you'd consider Page 156 4 this outdoors, but on the beach where those -- it's 4 Q In Palm Beach? 5 basically an outdoor setting. It's like a little 5 A At the house in Palm Beach. 6 wooden house. It's not a house, only a bed can fit 6 Q Anywhere else in Palm Beach? 7 in there. It's right on the beach. It's open. 7 A No. 8 Q In New Mexico? 9 A The house in New Mexico. 10 Q Anywhere else in New Mexico? Q Um-hum. 9 A Would you consider that outdoors? 10 Q I have never been there. So I don't know 8 whether it's outdoors or not. 11 A No. I would consider it outdoors. And -- 12 Q What other countries? Q How old were you at that time? 13 A France, uhm, England. Um -- we also -- I A I don't know. 14 mean, if we're going to talk about other countries 15 Q Okay. 15 we've got to talk about international travel space or 16 A I have no idea. Again, Ghislaine, myself, 16 plane space or whatever you want to call it because it happened all the time on the planes. 11 12 A 13 14 17 Jeffrey, another girl in this blue, outdoor -- I 17 18 don't know what you want to call it. Cabana, that a 18 Q Okay. 19 house -- just a bed could fit in. 19 A Going from different country to country. Q Where in France did you have sexual 20 Q How many times did you visit the island? 20 21 A I wouldn't be able to say. Lots of times. 21 22 Q More than five? 22 23 A Definitely more than five. 23 24 Q More than ten? 24 25 A More than ten. 25 contact with Ghislaine Maxwell? A There's a couple places in France that we used to go to. Q When you say you used to go to, how many times did you go to France? VIRGINIA GIUFFRE 5/3/2016 39 (153 - 156) Agren Blando Court Reporting & Video, Inc.Page 42 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 157 Page 159 1 A I think I've been to France three times. 1 with Ghislaine Maxwell at this hotel room overlooking 2 Q All right. How old were you when you went 2 the Champs-Elysees? 3 to France? 3 A Before she picked up the redhead. Q And was that just you and Ghislaine or was A I don't know. 4 5 Q Did you have a passport when you went to 5 6 France? 6 7 A I would have had to, yes. 7 8 Q You did have a passport when you went to 8 9 France? 4 anyone else a participant in that? A Jeffrey and Q And where else in France did you have sexual contact with Ghislaine Maxwell? 9 A The south of France. 10 A Yes. 10 Q Where? 11 Q And you went to France three times, you 11 A I wouldn't call it so much a hotel. I 12 believe? 12 don't know what you'd call it. It had like big 13 A Yes. 13 townhouse kind of things that you could rent out. Q And when you were in France those three 14 Q 15 times, how many of those three times did you have 15 trip? 16 sexual contact with Ghislaine Maxwell? 14 Was this on the same trip or a different 16 A Different trip. 17 A Every time. 17 Q Okay. Who else was present for that? 18 Q And in what locations in France did you 18 A Well, we were going to 19 20 have sexual contact with Ghislaine Maxwell? A The first time that I remember, we stayed at a really fancy hotel. 19 20 birthday party. It wasn't at the birthday party. Q Right. 21 A It was before the birthday party. Q In what city? 22 Q Oh, you had sexual contact with Ghislaine 23 A Paris. 23 Maxwell before you went to 24 Q Okay. 24 party? 25 A And it was within the view of the Champs- 25 21 22 MR. EDWARDS: Form. Page 158 1 2 3 4 Elysees. Q A Page 160 1 Did you have your own room or a separate room? We all stayed in the same room, but that 2 hotel room but with different rooms in it. 6 9 10 that you went? A She brought in a redheaded French girl. She walked up to her in Paris and, you know -- (BY MS. MENNINGER) And who else was Ghislaine Maxwell on this occasion? 6 8 Q 4 5 Okay. And anywhere else on that one trip That's correct. present during your supposed sexual contact with room had adjoining rooms to it. So, you know, one Q A 3 5 7 birthday 7 MR. EDWARDS: Object to the form of the question. A It wasn't supposed. It actually happened. 8 And Ghislaine was present, Jeffrey was present. I 9 believe 10 was present as well. Q (BY MS. MENNINGER) Anyone else? A There was someone else on that trip with 11 Q In your presence? 11 12 A In my presence. 12 us, but they weren't involved with the sexual 13 Q Um-hum. 13 activity at that time. 14 A And she walked up to this French girl to 14 Q France? Okay. And what was the other location in 15 show me how easy it was for her to procure girls. I 15 16 wasn't very good at it. And, you know, it was part 16 17 of my training was to bring in other girls. So she 17 18 walked up to her. Within five minutes she had her 18 19 number and that girl came over later that night to 19 20 the hotel and serviced Jeffrey. I didn't see 20 A Correct. 21 Ghislaine with her. I just know she told me what 21 Q And the second and third same places were 22 happened and Jeffrey told me what happened. 22 23 Q 24 A 25 Q A I believe the same exact place. I mean, we stayed there for a few days. Q Okay. So the three locations are hotel in Paris, same place, same place? on the same trip? So you were not there? 23 A Same trip. I did not see it. 24 Q Okay. And then you had a third trip to Okay. When did you have sexual contact 25 France where you did not have sexual contact with VIRGINIA GIUFFRE 5/3/2016 40 (157 - 160) Agren Blando Court Reporting & Video, Inc.Page 43 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 161 1 Ghislaine Maxwell? MR. EDWARDS: Form. 2 3 A I believe -- it's hard for me to remember. Page 163 1 MR. EDWARDS: Sounds good. 2 MS. MENNINGER: All right. 3 THE VIDEOGRAPHER: We're off the record at 4 I remember going to quite a few different countries 4 5 on that trip. I don't know if it was -- I don't know 5 6 if we did it in Paris or not, to be honest. We did 6 7 it in other places. But I've been to Paris three 7 8 times -- or not Paris, sorry, France. 8 9 Q (BY MS. MENNINGER) Okay. All right. 9 12:42. (Recess taken from 12:42 p.m. to 1:21 p.m.) THE VIDEOGRAPHER: We're back on the record at 1:21. Q (BY MS. MENNINGER) All right. 10 When did you first tell your parents that you would 10 Ms. Giuffre, I want to talk to you about where you 11 be traveling with Jeffrey Epstein? 11 were living in the late '90s. Do you recall -- you 12 testified earlier, I believe, that you were living at 13 your parents' house and you gave us an address at the 14 time you started at Mar-a-Lago. 12 13 14 15 16 A I'm not too sure when I actually told them. Q How long after you were working with Jeffrey Epstein did you travel with him? A 15 Well, I know my first trip was to New 16 17 York. I would say anywhere between six weeks -- I 17 18 would say after six weeks. 18 19 Q You were -- you had known Jeffrey Epstein A Yes. Q Do you remember where you lived previous to living at your parents' house at that time? A Like I said, I was a runaway, so there was 19 a lot of different places I lived. One of the places 20 for six weeks before you started traveling with 20 I lived was, like I told you earlier, with 21 him -- 21 parents. That was somewhere around Fort Lauderdale, I believe. 22 I believe, maybe a little bit outside of it. Q -- am I understanding that correct? 23 Q A I believe so. I mean, that's an 24 A 22 A 23 24 25 approximate answer. Okay. got an apartment and I lived in apartment for a short period. 25 Page 164 Page 162 Q And where do you recall that being? 2 A Somewhere in Fort Lauderdale, again. 3 Q Okay. And then you were living with your Q And your first trip was to New York? 1 2 A Yes. 3 Q And did you just go to New York and come 1 4 5 6 7 8 back or did you go somewhere else? A 4 I think I just went to New York, but I 5 can't remember if we went somewhere else. Q 6 Okay. And did you tell your parents you were going to New York? 9 A Yes. 10 Q And do you recall any part of your 7 8 9 10 11 conversation with your parents about going to New 11 12 York? 12 13 A I didn't get into details about what I was 13 parents or was there another place in between? A Then I lived with my parents. Q Okay. And then where is the next place that you moved? A An apartment that Jeffrey got for me in Royal Palm Beach. Q Okay. And you don't know the address of that? A No, I wish I could give it to you. I don't know it. Q And you stayed in that apartment until you 14 having to do with Ghislaine and Jeffrey. I didn't 14 15 tell them that, but I told them I was going to New 15 left for Thailand in the fall, later in the year in 16 York. 16 2002, correct? 17 Q 18 19 And you don't recall telling them anything else about it? A I don't know. I mean, I might have called 17 A Yes. 18 Q Right? 19 A Yes. Q All right. And when did you first stop 20 them from New York and told them it was cold and, you 20 21 know, just simple stuff. But I can't really recall 21 living with your parents? How old were you when you 22 what I spoke to them about. 22 first stopped living with your parents? 23 MS. MENNINGER: As I understand it, the MR. EDWARDS: Object to the form. 23 24 food is here. So I'm going to suggest that now is a 24 A The very first time? 25 good time to take a break. 25 Q (BY MS. MENNINGER) Um-hum. VIRGINIA GIUFFRE 5/3/2016 41 (161 - 164) Agren Blando Court Reporting & Video, Inc.Page 44 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 165 1 2 3 4 Page 167 A I believe I was 11. 1 Loxahatchee, Florida were made aware that you had run Q Okay. What caused you to stop living with 2 away from home at the age of 11? your parents when you were 11? A I just had some trouble and my parents 3 A Yes. 4 Q And what abuse had you suffered prior to 5 thought it would be better if they sent me to 5 6 California. 6 7 Q Okay. What trouble did you have? 7 8 A It's very hard for me to talk about. 8 the age of 11? A There was a very close family friend who was a very sick man. And he took advantage. Q What's his name? 9 A 10 know, made me so I -- I couldn't live with my parents 10 Q 11 anymore. 11 A What went on in your life that caused you 12 Q And where is 13 to not be able to live with your parents at the age 13 A I don't know where he is. 14 of 11? 14 Q Does anyone in your family keep in contact 9 12 15 16 17 There was stuff that went on in my life that, you Q today? A Do I have to answer this? 15 Q Well, did you talk to Sharon Churcher 16 A No. 17 Q What did he do to you? A Um, he touched me places I shouldn't be about being molested as a child? 18 A I did. 18 19 Q And you authorized Sharon Churcher to 19 20 what? publish that in a newspaper, correct? A with him? touched. He sexually abused me. 20 I don't think I authorized her to do it. Q For how long? 21 A I don't know how long. 22 I think she -- I wouldn't say she did it on her own 22 Q Did you tell that to your parents? 23 accord. But I talked to her about it and I wasn't 23 A They know. 24 aware of exactly what she was going to publish and 24 Q How do they know? 25 what she wasn't. 25 A I told them. 1 Q 21 Page 168 Page 166 1 2 3 4 5 Q So you were able to talk to a reporter for the Mail On Sunday about this, correct? A 2 I did tell her a little bit about my past and where I came from. Q All right. So what caused you to be sent Did you tell them when you were under the age of 11 or at the age of 11? 3 A I told them later. 4 Q When did you tell them? 5 A It took me a long time to forgive my 6 away from your parents' home at the age of 11 to 6 parents for sending me away. I didn't feel like 7 California? 7 anybody understood me. So not until later in my life 8 did I feel like I was able to talk to anyone about 9 it. 8 9 A Some of the prior abuse which led me to be a very troubled young teenager. I mean, I guess you Q Okay. Was it reported to the authorities? 11 A No. I went too late to talk to anybody 12 about it. 10 wouldn't call 11 a teenager yet, but led me to 10 11 running away a lot and -- and my family just thought 12 it was best that I get out of the area and move 13 somewhere else. 13 14 15 Q age of 11? 16 A 17 Q 18 A 20 21 23 14 15 Q Did the event of you being molested cause your parents to split up? A I think Sharon reported that, but I don't Yes. 16 think that's the case, no. My parents split up All right. Was that reported to the 17 because they were really messed up. authorities? 19 22 Okay. You had run away prior to being the 18 Q Your parents split up because they were really messed up? That I ran away? 19 Q Yes. 20 A Yes. 21 Q And where were your parents living at the 22 Q When did they split up? 23 A I don't really remember what year it was. age of 11? A Oh, they just didn't get along. There were a lot of marital problems. 24 A The same address I gave you earlier. 24 Q How old were you? 25 Q Okay. So the authorities associated with 25 A I believe I was living with Jeffrey at the VIRGINIA GIUFFRE 5/3/2016 42 (165 - 168) Agren Blando Court Reporting & Video, Inc.Page 45 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 171 Page 169 1 time. 2 Q With whom did you live in California? 2 Q (BY MS. MENNINGER) Yes? Yes or no? 3 A My 3 A Oh. Yes. 4 Q And who else? 4 Q And then when did you go back to Florida? THE REPORTER: I'm sorry, your -- 1 5 A 5 A I don't know. 6 Q And with who else? 6 Q Was your younger brother living with your 7 A That's it. 7 8 Q And for how long did you live with them? 8 9 A I don't really know how long, maybe over a 10 11 year, maybe two years. Q 9 10 And then what caused you to not live with them anymore? parents in Florida while you were in California? A Um-hum, yes. Q And was your older brother living with your parents in Florida while you were in California? 11 A I don't think so. 12 Q How much older than you is he? I kept running away from them, too. 13 A Five years. Q And where did you live in California? 14 Q And when you went back to Florida, where A I'm sorry? 15 Q Where in California did you live? 16 A A Where did they live? 17 School. 18 Q Where did you live with them? 18 Q 19 A Salinas. 19 20 Q And do you know the address? 20 A 21 A No. 21 Q Okay. What grades were middle school? 22 Q Do they still live there? 22 A Six, seven and eight. 23 A No. 23 Q Okay. And when you went back to live with 24 Q When did they stop living there? 24 your parents again, that was at the same address in 25 A I don't know. I haven't kept in contact 25 Loxahatchee? 12 13 A 14 15 16 17 did you go to school, when you got back? I believe I went to Crestwood Middle And did you complete your studies at Crestwood Middle School? Did I get out of middle school there, yes. Page 170 1 2 3 with them. Q Page 172 1 And you believe you lived with them for a little more than a year? 2 3 A Yes. Q And you don't believe your older brother was in the home at the time? 4 A 4 A No, he was sent to boarding school. 5 too sure. 5 Q Where did he go to boarding school? 6 Q Did you go to school there? 6 A Washington. 7 A Yes. 7 Q State or city? 8 Q Where did you go to school? 8 A Washington above California. 9 A Somewhere near Salinas, I'm assuming. Q When was the next time you stopped living 10 Q What grade were you in? 10 11 A Middle school. 11 12 Q Sixth grade, seventh grade? 12 13 A I think sixth grade. 13 Q Why? 14 Q And did you go there for more than one 14 A Because I kept running away. 15 Q Were the authorities alerted when you ran 15 16 17 18 19 Maybe a year, maybe two years. I'm not year or just one year? A Maybe -- I don't know. I'm sorry, I don't know. Q 9 16 17 Were the authorities in Salinas alerted to the fact that you ran away from home there? 18 19 with your parents? A They sent me to a group home called Growing Together. away? A Yes. Q And how old were you when you went to live at Growing Together? 20 A Yes. 20 21 Q How long was the longest you were away 21 back dates. Off the top of my head -- I don't want 22 to guess. I don't think I should guess. I don't know. 22 from home in Salinas, California? 23 A Two weeks. 23 24 Q And you were in middle school? 24 25 A (Indicating.) 25 A Q I don't know. It's hard for me to piece But you moved directly from living with your parents to living at Growing Together? VIRGINIA GIUFFRE 5/3/2016 43 (169 - 172) Agren Blando Court Reporting & Video, Inc.Page 46 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 173 1 A 2 3 Page 175 I wouldn't say directly. 1 between the ages of eighth grade and when you started Q How -- 2 working at Mar-a-Lago? A I'd say I stayed with my parents for -- 3 A Besides the ones I've told you about, you 4 like, I think I finished school at Crestwood. So I 4 know, I did run away from Growing Together quite 5 would have been in, I don't know, I guess eighth 5 often. And I did end up being -- being abused by 6 grade, finished eighth grade. And then -- I don't 6 another older guy who I stayed with for I don't know 7 know. I really don't know. Around eighth grade. 7 how long. Q You went to Growing Together? 9 A I think -- I think it was then. 10 Q And how many years did you live at Growing 8 11 8 9 Together? 10 Q How old were you then? A I don't know. I'm sorry. I really wish I could pinpoint dates. I don't know dates. 11 Q 12 A Over a year. 12 A 13 Q Were you ever in foster care? 13 Q A Okay. What was that man's name? And how long were you living -- were you What Growing Together was, was like a 14 15 group home that sent you away to foster parents every 15 A 16 night. 16 Q And for how long were you living with him? 17 A I don't know. 14 17 Q So you lived in other people's homes living with ? Yes. 18 during the period of time you were assigned to 18 Q Days? Weeks? Months? 19 Growing Together? 19 A I don't know. I mean, it wasn't days. I 20 A Well, you stayed at Growing Together 20 don't think it was weeks. It would have been close to maybe a few months. 21 during the day and then at night you get sent home 21 22 with parents. 22 23 24 Q Did you go to school while you were at Growing Together? 23 Q Okay. And was prosecuted by federal authorities in South Florida? 24 A Yes. 25 Q And you were located by the FBI, I 25 A Yeah, they offer education there. 1 Q So the education was at Growing Together? 1 2 A Yeah. 2 A Yes. 3 Q You did not attend a Palm Beach County -- 3 Q And you gave an interview to the FBI A I did, but you had to earn your levels up 4 Page 176 Page 174 4 5 to be able to go outside. So I don't remember what 5 6 level you have to get up to, to go out to another 6 7 school. I think there was like seven levels or 7 8 something. And you had to make it to, like, level 4 8 9 to be able to go to outside school. 10 Q 9 So for some period of time you were 10 believe? concerning your time with , correct? A Yes. Q Did you ever get a victim's notification letter regarding your status as a victim in federal criminal prosecution? A I don't know. My parents handled everything. 11 assigned to Growing Together and you were going to 11 Q 12 school at Growing Together. And for some period of 12 a letter? 13 time you were going to other schools and coming back 13 A I don't know. 14 to Growing Together? 14 Q Have you ever asked them? A No, I've never really brought it up with Do you know if your parents received such 15 A Correct. 15 16 Q And then when you came back to Growing 16 them. It really pissed them off a lot, so I never brought it up with them. 17 Together, you were sent to spend the night at a 17 18 family's home? 18 Q Yes. 19 with Q So you never slept at Growing Together? 20 A Yes. A No. 21 Q Why did it piss them off, if you know? Q Did you live -- other than living at or 22 A Well, I think they were just disgusted, 19 A 20 21 22 It pissed them off that you were living ? 23 staying at Growing Together during the day and 23 you know, that this happened to me again. And they 24 sleeping at these other homes at night, is there 24 didn't want to talk about it. They didn't want to 25 anywhere else that you recall living in the period 25 talk about it. VIRGINIA GIUFFRE 5/3/2016 44 (173 - 176) Agren Blando Court Reporting & Video, Inc.Page 47 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 177 Page 179 Mar-a-Lago, correct? Q But they were aware of it? 1 2 A Yes. 2 A Yes. 3 Q Your dad came and picked you up from the 3 Q Do I have that sequence right? 4 A So far, yes. Q And when did you stop living at your 1 4 police station? 5 A Yes. 5 6 Q And your dad would not let you come home? 6 parents' at the time you started working at A Well, I think it was more my mom didn't 7 Mar-a-Lago? How long after you started at Mar-a-Lago 8 do you stop living with your parents? 7 8 want me to come home. 9 Q Did she say why? 10 A She just probably thought I was just going 9 A I don't know exact dates. I was traveling 10 with Jeffrey a lot, and I was making -- he was giving 11 me lots of money for the sex that I had with him and 12 Q Did she say that to you? 12 Ghislaine. 13 A Well, I asked my dad at the police station 13 11 to keep running away again. And -- 14 if I could come home instead of going back to Growing 14 15 Together. And he said my mom didn't want me to come 15 16 home. And I told him if he didn't get me out within 16 17 a week, I'd run away again and he'd never hear from 17 18 me again. 18 19 20 Q And how is it that you came back to be living at their house, then? I'm not too sure, darling, I don't know. Q All right. Can you -MS. MENNINGER: I have no recollection of which number we're on in terms of exhibit. MS. RODRIGUEZ: 15. Q (MS. MENNINGER) Okay. I'd like to mark 20 as Defendant's Exhibit 15 a document and see if you can identify it. I ran away again and I called him up and I 21 22 said, This is your final chance. And they came and 22 23 picked me up and they let me live there. 23 21 A 19 And after, I would say, a short time -- 24 Q And when did you go live with 24 25 A Not long after that. 25 1 Q And when did you live with Actually, before I do that, when do you recall ever getting a passport? A I got my passport in New York. I don't know what age I was. Page 178 2 3 4 parents? A 2 Well, I lived with before I lived with parents 3 Q Okay. And did you -- how did you get it? Did you go somewhere or what happened? A Jeffrey had me fill out paperwork and go in his apartment. 4 to a Kodak shop or something similar of a Kodak shop And that was an apartment that 5 and get my picture taken. I gave him my picture and 6 my paperwork. He sent it away. And I think a week 7 later he said he got it expedited. 5 Q 6 rented? 7 A and his friend. I can't remember 8 his friend's name. Mario, I think his friend's name 9 was. 10 Q When did you live with A That was just a brief stint. I didn't 8 9 10 as parents? 11 12 Page 180 1 11 Q Did you physically go to an office in New York? A Jeffrey's office. Q An office associated with Immigration or 12 Homeland Security or whatever it was called back then? 13 really stay there very long, but it was -- I was a 13 14 runaway. That's in between times of -- I don't know. 14 A Not that I recall. Q And do you know how old you were? A No. I don't know how old you have to be 15 Q How old were you? 15 16 A I don't know. 16 17 Q I just want to be clear. rented 17 to get a passport, so I'm not too sure. (Exhibit 15 marked.) 18 an apartment that you moved into that he had rented, 18 19 correct? 19 20 A Correct. 20 21 Q And that was after you had lived with 21 22 A Yes. 23 A Yes. 23 Q Is this document the passport application 24 Q And that was prior to you and 24 and his parents, correct? 22 25 living with your parents when you started working at 25 Q (BY MS. MENNINGER) Okay. I'm going to show you Defendant's Exhibit 15. Do you recognize this document? that you filled out? A Yes. VIRGINIA GIUFFRE 5/3/2016 45 (177 - 180) Agren Blando Court Reporting & Video, Inc.Page 48 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 181 1 Q Is it in your handwriting? 2 A Yes. 3 Q Page 183 1 I really can't make out All right. What did you put down as your 3 4 address at this time to mail the passport to? It's 4 5 about the second line -- third line. 5 6 7 8 9 10 11 12 13 A Number 13? 6 Q Well, the third line says, Mail passport 7 to. What address did you put down? A 8 Are we talking about number 13, Permanent address, do not list P.O. box, street? Q No, I'm talking about the third line in the entire thing that says, Mail passport to. A Oh, I'm sorry, up here, the Q Okay. Do you see Relationship? Can you read that? A Friend. Q Okay. Do you see just below that there's a line that says number 21? A 9 Do not stop -- sorry, Do not sign 10 application until requested to do so by 11 administrating an oath. 12 Q Okay. 13 A Applicant's signature age 13 or older. 14 Q Oh, it's by the signature line? 15 A Yeah. 16 Q And that's your signature? passport mailed to you at your parents' address, 17 A Yes. 18 right? 18 Q All right. And this is the document that I don't know if it was mailed to my 19 20 parents' house, but that's the address I sent -- put 20 21 down, yes. 21 my handwriting and it's got all of my information on 22 it. 19 22 A All right. So you asked to have the the telephone number. 17 16 Q a 3. I think it's Q Okay. And if you look a little bit 23 further to the right, roughly equal with that line, 23 24 do you see a date that's stamped on there? 24 25 A 1 Q Yeah, January 12th, 2001. 25 you recall filling out for your first passport? A I don't recall doing it, but yes, it's in Q Okay. And on line -- box 23 it's got your driver's license checked off, right? A July 23. Yeah, I really can't make out Page 182 Okay. And then if you go down a little Page 184 1 2 bit further, as you pointed out, line number 13, you 2 3 gave your permanent address as your parents' address, 3 4 again, correct? 5 6 7 numbers and stuff, though. Q But the box, Driver's License is checked off? 4 A Yes. A Correct. 5 Q Okay. And then if you look in the lower Q If you look at box number 12 where it asks 6 right-hand corner of the page, do you see what we 7 call a Bates stamp number? I don't know if you know 8 what that means. for occupation, what did you write down? 8 A Masseuse. 9 Q Okay. If you look at line number 18, Have 9 A No. 10 you ever been issued a U.S. passport before, what did 10 Q Just the lower right-hand corner of the 11 you put down? 11 12 13 No. 12 A Q All right. And if you go down a little 13 Q 14 bit further than that, emergency contact, who did you 14 15 put down? 15 16 A 17 Q 18 19 20 21 16 Okay. So is that the fiancé you were 17 Giuffre 004721? Okay. Thank you. So at January 2001 was living A Well, he would have had to have been if I put it down there. 18 Q A Yes. 19 rented? Q In January of 2001 were you still his 20 talking about earlier? affianced? No, it's in Royal Palm Beach. The apartment he rented was in Fort Lauderdale. So this could be my apartment that he lived at with me. A Looks like it, yes. 22 23 Q And what address did you put down for 23 A It's kind of hard to read. I think that's 24 A Okay. Was that the apartment that he had 21 22 25 document. A 24 25 Q Okay. So his apartment where he lived with you was in Royal Palm Beach? A Yes. VIRGINIA GIUFFRE 5/3/2016 46 (181 - 184) Agren Blando Court Reporting & Video, Inc.Page 49 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 185 1 Q 2 3 4 1 Q Let me have you put the paper down. MR. EDWARDS: Object to the form. 2 A Yes. Q Do you recall applying for another Mischaracterization. A Page 187 And he rented that apartment? 3 He lived there with me for a short period. 4 passport? 5 I don't -- I don't know how long he lived there with 5 A No. 6 me for. 6 Q Okay. Do you recall ever applying for 7 8 9 10 11 12 13 14 Q (BY MS. MENNINGER) And who rented the apartment? A 8 Well, Jeffrey paid for the apartment. I was the occupant, and he was an occupant. 17 18 19 9 A Yes, I believe I had to sign the paperwork 12 13 So you were living at -- is it A I can't honestly read it. It looks like a C-a-c (sic), but that doesn't make sense. Q So January of 2001 you signed a document under oath putting Well, yeah, when I got to Australia I had to -- I don't have it on me right now, but I could because the other one ran out as expiree. 11 Q A tell you it's -- I had to apply for another one Did you ever see the lease? saying that I was living there. another passport, ever? 10 Q 15 16 7 Q So whenever one expired, you applied for another one from the U.S.? 14 A (Indicating.) 15 Q Have you ever gotten -Is that right? 16 17 A Yeah. 18 Q Have you ever gotten a passport from 19 Australia? 20 A An Australian passport? 21 A Yes. 21 Q Right. 22 Q And you put your permanent address and 22 A No. Q Have you ever lost a passport and had to 23 your mail your passport to at your parents' 23 24 address -- 24 25 A Yes. 1 Q -- is that right? get one replaced? 25 A 1 Q I don't think so. Page 186 And it's your position that that is the 2 Page 188 2 When was the first time that you came back to the U.S. from Australia? 3 apartment that Jeffrey paid for and you signed a 3 A 4 lease? 4 Q And did you come back before that? 5 A No. Q Did you ever tell Sharon Churcher or 5 A Yes, Jeffrey paid for it and I think I had October 16th, 2013. 6 to sign something that said I was going to occupy it. 6 7 I don't know if James ever did. 7 Sharon White or Marianne Strong that you were going 8 on a trip to New York in 2011? 8 9 10 11 Q Okay. And you stayed at that apartment from at least January 2001 until you left in the fall of 2002, right? A I would say before then, yes. Like I 9 A No. 10 Q Is it your contention that Ghislaine 11 Maxwell sexually trafficked you to famous people? A If you have a document in front of you 12 said, I can't really tell you the exact date that I 12 13 moved there, but -- 13 that you could show me so I could see what you're 14 talking about, yes. 14 Q Why did you have your passport sent to 15 your parent's house if you weren't living at your 15 16 parents' house? 16 Ghislaine Maxwell sexually trafficked you to famous 17 people? 17 18 19 A Um, I don't know. I guess a fail-safe. I'm not too sure. 18 Q When was the next passport that you got? 19 A Q A I'm asking you, is it your contention that Could you be more specific, like are we talking about rock stars or royalty or -Q Politically connected and financially I think I had to reapply for one in -- 20 21 well, this one expired in 2002. So I would have had 21 22 to apply for another one. 22 A Yes. 23 Q Okay. To whom did Ghislaine Maxwell 20 23 24 25 Q I'm asking do you remember when you got another passport? A This expired January 10th, 2002. 24 25 powerful people. sexually traffic you? A You have to understand that Jeffrey and VIRGINIA GIUFFRE 5/3/2016 47 (185 - 188) Agren Blando Court Reporting & Video, Inc.Page 50 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 189 Page 191 1 Ghislaine are joined hip by hip, okay? So they both 1 exactly what you would do for Jeffrey to him. Keep 2 trafficked me. Ghislaine brought me in for the 2 him happy. I can't remember her exact words, and I'm 3 purpose of being trafficked. Jeffrey was just as a 3 not going to put words in my mouth to make it sound 4 part of it as she was. She was just as a part of it 4 like what she said. But it was all along those 5 as he was. They trafficked me to many people. And 5 lines. 6 to be honest, there is people I could name and then 6 Q 7 there's people that are just a blur. There was so 7 8 much happening. 8 9 10 Q Okay. Please name a person that Ghislaine Maxwell directed you to go have sex with? . used to you in directing you to go have sex with ? MR. EDWARDS: Object to the form. 9 10 11 A 12 Q Okay. Who else? 12 13 A As a whole, they both trafficked me to 13 11 Those are words that Ghislaine Maxwell Mischaracterized her testimony. A Along those lines, yes. Q (BY MS. MENNINGER) Okay. Where were you located when she used those words with you? A It could have been Palm Beach. It could 14 people. It was under both of their direction. So 14 15 it's not easy just to say Ghislaine. When I say 15 16 they, I mean both of them. 16 Q You don't recall? 17 A I don't recall. Q Okay. How old were you when she used 17 Q Okay. Well, I need you to say a time when 18 Ghislaine Maxwell directed you to go have sex with 18 19 another person. So can you please tell me to whom 19 20 Ghislaine Maxwell asked you to go have sex with 20 21 another person? 21 MR. EDWARDS: Object to the form. 22 have been New York. those words to you? MR. EDWARDS: Object to the form. Mischaracterizes her testimony. 22 A I don't know. I would think I was 17. 23 A 23 Q (BY MS. MENNINGER) But you're not sure? 24 Q (BY MS. MENNINGER) Who else? 24 A Well, it was in the beginning, like after 25 A I'm going to continue to tell you that 25 my training. were Page 190 Page 192 1 they both directed me to do it. It was part of my 1 2 training. They both told me, you've got tickets to 2 3 go here. This is who you're meeting, and this is 3 4 what you're doing. 4 5 So 6 Q 7 sex with 9 Ghislaine Maxwell directed you to go have ? MR. EDWARDS: Object to the form to the 8 10 is another one. extent it mischaracterized her testimony. A Q Okay. Well, I was asking about okay? A Right. That's what I'm saying. If you 5 want me to categorically tell you when it happened 6 and why I think I was 17, because those were the two 7 first people I was sent to. 8 9 I'm trying to tell you that they both did, the two first people I was sent out to. 10 Q So you don't actually recall the conversation regarding ? You don't recall where you were, right? A I can't picture if it was New -- I know it 11 Ghislaine and Jeffrey both directed me. They both 11 12 paid me and they both directed me. 12 was either New York or Palm Beach. I don't remember 13 exactly which one. 13 14 Q (BY MS. MENNINGER) All right. When did Ghislaine Maxwell direct you to go have sex with ? 15 MR. EDWARDS: Object to the form. Same 16 17 objection. A I don't know the time. I don't -- you 14 Q You don't recall exactly what words were 15 used by Ghislaine Maxwell in speaking to you, 16 correct? 17 A I remember the tone that she used, the 18 type of words that she used. I can't word for word 19 know, I could tell you the place. I don't know the 19 replay what she said. 20 time. 20 21 Q 18 (BY MS. MENNINGER) What words did 22 Ghislaine Maxwell use in talking to you and asking 22 23 you to go have sex with 23 24 25 A ? We're sending you to a gentleman. We want you to show him a good time. We want you to do Q All right. And so when in time was ? 21 A was months, six months, I'm not too sure. 24 Q Six months what? 25 A Before VIRGINIA GIUFFRE 5/3/2016 . I don't know, I 48 (189 - 192) Agren Blando Court Reporting & Video, Inc.Page 51 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 193 Page 195 Q If you're going to tell me more names, 1 think I met Prince Andrew in 2001. And Glenn Dubin 1 2 and Stephen Kaufmann were, like I said, the first 2 3 people I was sent out to after my training. So I 3 A I'm trying to think. 4 don't know. I'm not going to give you an exact time 4 Q If you're just going to talk -- 5 if I don't know it. please continue your answer. 5 A I'm sorry. I'm trying to think. Q I asked you the relative order. 6 Q Okay. Let's take a break and then you can 7 A And I'm trying to give you it. 7 8 Q And where does Alan Dershowitz fit into 8 6 9 10 11 that group of people? A 9 Same. I can't tell you piece by piece by piece who -- I know Glenn Dubin was first. 11 THE VIDEOGRAPHER: We're back on the Q Okay. 12 A And I know Stephen Kaufmann was one of the 13 14 first I was sent to. Alan Dershowitz could have been 14 15 between there. Between, sorry, between Glenn and 15 16 Stephen. The first time I was with Alan Dershowitz 17 was in New York, so I wasn't actually sent to him. 18 19 22 2:01. (Recess taken from 2:01 p.m. to 2:09 p.m.) 13 21 THE VIDEOGRAPHER: We're off the record at 10 12 20 think over the break. record at 2:09. Q (BY MS. MENNINGER) Ms. Giuffre, you have filed a lawsuit against Ghislaine Maxwell, correct? A Yes. 16 Q You understand her to be my client, 17 correct? It actually happened at one of Jeffrey's residences. 18 A Yes. (Ms. McCawley left the deposition.) 19 Q I'm here today to talk to you about your A So it's very hard for me to 20 chronologically give you each person individually. Q (BY MS. MENNINGER) Okay. Name the other allegations against Ghislaine Maxwell. Do you understand that? 21 22 A Yes. Q I want you to tell me a single time that 23 politically connected and financially powerful people 23 24 that Ghislaine Maxwell told you to go have sex with? 24 you recall Ghislaine Maxwell using words to you and 25 directing you to go have sex with another person -- 25 A Again, I'm going to tell you "they" Page 194 Page 196 1 because that's how it went. They instructed me to go 1 2 to George Mitchell, Jean Luc Brunel, Bill Richardson, 2 3 another prince that I don't know his name. A guy 3 4 that owns a hotel, a really large hotel chain, I 4 5 can't remember which hotel it was. Marvin Minsky. 5 There was, you know, another foreign 6 MR. EDWARDS: Object. Q MR. EDWARDS: Objection. Asked and answered. To the extent that she can answer the 6 7 president, I can't remember his name. He was 7 8 Spanish. There's a whole bunch of them that I 8 9 just -- it's hard for me to remember all of them. 9 (BY MS. MENNINGER) -- not anybody else, Ghislaine Maxwell? question, I'd ask that she answer the question. A I have answered the question. The question that you're asking me is Ghislaine. And 10 You know, I was told to do something by these people 10 Ghislaine and Jeffrey worked together. They were one 11 constantly, told to -- my whole life revolved around 11 and the same of persons. They both directed me to do 12 just pleasing these men and keeping Ghislaine and 12 this. They both directed me to report back to them. 13 Jeffrey happy. Their whole entire lives revolved 13 They were both the same. 14 around sex. 14 They call massages sex. They call 15 16 17 15 modeling sex. They call -Q I asked you the names for people. Are you Q (BY MS. MENNINGER) You cannot recall a single instance in which Ghislaine -- 16 A I have to -- 17 Q Excuse me. 18 going to tell me any other names or is that all of 18 -- in which Ghislaine Maxwell alone 19 them? 19 directed you to have sex with another person -- A I'm trying to think. That's the answer 20 A I have to -- 21 I'm trying to give to you. It's that it's so hard to 21 Q -- correct? 22 just keep naming and naming and naming. 22 A 20 -- believe -- 23 Q All right. 23 MR. EDWARDS: Object. 24 A A lot of times I would be introduced to 24 MS. MENNINGER: I am going to finish my 25 them. I didn't know -- 25 question. VIRGINIA GIUFFRE 5/3/2016 49 (193 - 196) Agren Blando Court Reporting & Video, Inc.Page 52 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 197 1 Q MR. EDWARDS: Are you finished with your 2 3 question? MS. MENNINGER: Now you may make your 4 5 (BY MS. MENNINGER) Correct? objection. And then she may answer. was going to be trained as a masseuse and that she 2 instructed me to take off my clothes and to give oral 3 sex to Jeffrey Epstein. 4 5 MR. EDWARDS: Okay. Objection. 6 Page 199 1 6 7 Argumentative. Harassing for absolutely no reason. 7 8 Mischaracterizing the witness's testimony. 8 Answer, if you can. 9 10 A I have given you the names of the people 11 that Ghislaine herself has told me to go be sex 12 trafficked to, along with Jeffrey Epstein, okay? Q (BY MS. MENNINGER) Excuse me. I've asked you for the names. A I've just given you a name. Jeffrey Epstein is a big name. Q All right. 9 A She instructed me on that one. 10 Q So you're saying -MR. EDWARDS: The witness is finishing her 11 12 answer right now. She's in the process of explaining 13 She's the one who brought me to Jeffrey 13 one of the people Ghislaine told her to have sex 14 Epstein to be trafficked in the fucking first place. 14 with. 15 Q So I have given you as much information as 15 (BY MS. MENNINGER) So you're saying 16 I possibly can to let you know what she was about, 16 Ghislaine Maxwell directed you to have sex with 17 who she told me to go with, what she wanted me to do. 17 Jeffrey Epstein? 18 That is what I am stating and that's what I 18 A Correct. 19 previously stated to you. 19 Q Ghislaine Maxwell directed you to have sex 20 Q (BY MS. MENNINGER) And these names that 20 with Glenn Dubin? 21 you have just given are people to whom Ghislaine 21 A Correct. 22 Maxwell alone told you to go have sex? 22 Q What words did Ghislaine Maxwell tell you MR. EDWARDS: Objection. 23 23 24 25 Mischaracterization. A 24 Ghislaine and Jeffrey, I don't know how to go have sex with Glenn Dubin? A It was the same all the time, all right? 25 They want me to go provide these men with a massage. Page 198 Page 200 1 many times you want me to keep answering this 1 And when they say massage, that means erotic, okay? 2 question. Both told me to do this, okay? They both 2 That's their term for it. I think there are plenty 3 sent me to these people. 3 of other witnesses that can attest to what massage 4 actually means. How many times do you want me to answer 4 5 this? 6 to go to 7 answering a different question so that's why I'm 7 means sex. 8 going to ask you again. I am not asking you anything 8 9 about a time when Jeffrey and Ghislaine together told 6 Q And I'm telling you that Ghislaine told me 5 (BY MS. MENNINGER) I think you're 9 Q and give him a massage, which Okay. So -- Ghislaine Maxwell told you to go give a massage to 10 you to go do something. I'm asking you to name a 10 A 11 single time during which Ghislaine Maxwell acting 11 Q That's your testimony? 12 alone directed you to go have sex with another 12 A That is my testimony. 13 person? 13 Q All right. Ghislaine Maxwell told you to MR. EDWARDS: Objection. Asked and 14 15 16 answered. Harassing. Argumentative. A I've given you the names of the people 14 Correct. go give a massage to , correct? 15 A Correct. 16 Q Ghislaine Maxwell told you to give a 17 that Ghislaine instructed me to go have sexual 17 18 relations with. I am not discluding (sic) the fact 18 A Correct. 19 that Jeffrey also told me. 19 Q Ghislaine Maxwell told you to give a 20 Ghislaine told me from her mouth to do 20 massage to massage to 21 these things. Jeffrey told me from his mouth to do 21 22 these things with these people. Ghislaine instructed 22 23 me to do the things that I did with Jeffrey Epstein 23 24 on the very first meeting that I had with him. She 24 A I don't know dates. 25 brought me there under the preclusion (sic) that I 25 Q Where were you? , correct? , correct? A Correct. Q When did Ghislaine Maxwell tell you to give a massage to VIRGINIA GIUFFRE 5/3/2016 ? 50 (197 - 200) Agren Blando Court Reporting & Video, Inc.Page 53 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 203 Page 201 1 2 3 When it happened? 1 Q When Ghislaine Maxwell used the words, Go 2 give a massage to Bill Richardson, where were you? 3 sent to have sex with the owner of a large hotel 4 chain by Ghislaine Maxwell? MR. EDWARDS: Object to the form. 4 5 know where it was when she said to go do this. A Mischaracterizes her testimony. (BY MS. MENNINGER) Okay. Where were you MR. EDWARDS: Object to the form. 5 I can't tell you where we were. I know 6 A 7 where I was sent to. I don't know where we were when 7 Q (BY MS. MENNINGER) Which time in France? 8 she told me to do that. 8 A I believe it was around the same time that 6 A Q 9 Q 10 to -- (BY MS. MENNINGER) Where were you sent 9 10 I believe that was one time in France. Naomi Campbell had a birthday party. Q Where did you have sex with the owner of a 11 A New Mexico. 11 large hotel chain in France around the time of Naomi 12 Q -- by Ghislaine Maxwell? 12 Campbell's birthday party? MR. EDWARDS: Object to the form. 13 14 15 16 17 18 19 20 21 22 13 Mischaracterizes her testimony again. 14 A In his own cabana townhouse thing. It was part of a hotel, but I wouldn't call it a hotel. Jeffrey was staying there. Ghislaine was A Are you smiling at me because -- 15 Q (BY MS. MENNINGER) No, I'm asking you to 16 staying there. Emmy was staying there. I was 17 staying there. This other guy was staying there. I 18 don't know his name. answer the question. A I have answered the question. I was sent to New Mexico. I was instructed by Ghislaine to go and 19 Q Okay. Where were you sent from? 20 A I already answered that. I don't know 21 Q She used the words erotic massage? 22 A No, that's my word. The word massage is where I was sent from. 23 Q Okay. 23 24 A I was flying everywhere with these people. 24 25 Q Where were you sent by Ghislaine Maxwell 25 give him an erotic massage. what they would use. That's their code word. Q Was she in the room when you gave this erotic massage to the owner of a large hotel chain? Page 202 1 to have sex with Page 204 1 MR. EDWARDS: Object to the form. 2 3 ? 2 Mischaracterized her testimony. 3 A No, she was not in the room. She was in another cabana. Q And other than telling you to go give the 4 A Many places. 4 owner of this large hotel chain a massage, do you 5 Q (BY MS. MENNINGER) Ghislaine Maxwell sent 5 remember any other words she used to you to direct 6 you in what you should do? 6 you to many places to have sex with ? MR. EDWARDS: Object to the form. 7 7 8 A It happened at many places, yes. 9 Q (BY MS. MENNINGER) You had sex with at many places is what you're saying, 10 11 correct? 12 A 13 14 15 16 8 I was sent to 12 13 When did Ghislaine Maxwell send you to a place to have sex with A ? 14 15 You are asking -MR. EDWARDS: Form. 17 Not at the time, no. Q Where did -- where were you and where was Ms. Maxwell when she directed you to go have sex with Marvin Minsky? MR. EDWARDS: Object to the form. 11 at many places to have sex with him. Q 9 10 A A I don't know. Q (BY MS. MENNINGER) Where did you go to have sex with Marvin Minsky? A I believe it was the U.S. Virgin Islands, 16 Jeff's -- sorry, Jeffrey Epstein's island in the U.S. 17 Virgin Islands. 18 A -- me to answer the impossible. 18 Q And when was that? 19 Q (BY MS. MENNINGER) All right. When did 19 A I don't know. 20 Ghislaine Maxwell send you to have sex with the owner 20 Q Do you have any time of year? 21 of a large hotel chain? 21 A No. 22 Q Do you know how old you were? 23 A No. Q Other than Glenn Dubin, Stephen Kaufmann, MR. EDWARDS: Object to the form. 22 23 24 25 Mischaracterization. A I'm going to keep answering the questions the same way that I keep answering them. I don't 24 25 Prince Andrew, Jean Luc Brunel, Bill Richardson, VIRGINIA GIUFFRE 5/3/2016 51 (201 - 204) Agren Blando Court Reporting & Video, Inc.Page 54 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 205 Page 207 Q Including Mr. Edwards, who is sitting 1 another prince, the large hotel chain owner and 1 2 Marvin Minsky, is there anyone else that Ghislaine 2 3 Maxwell directed you to go have sex with? 3 A Correct. 4 Q What did that journal look like? 5 A It was green. 6 Q And what else? 7 A It was just a spiral notebook. 8 Q Okay. And what did you put into that 4 5 6 7 8 9 A I am definitely sure there is. But can I remember everybody's name? No. Q Okay. Can you remember anything else about them? A Look, I've given you what I know right now. I'm sorry. This is very hard for me and very 9 right here, correct? green spiral notebook? A Bad memories. Things that I've gone 10 frustrating to have to go over this. I don't -- I 10 11 don't recall all of the people. There was a large 11 through, lots of things, you know. I can't tell you. 12 amount of people that I was sent to. 12 There was a lot of pages. It was over 300 pages in 13 that book. 13 14 Q Do you have any notes of all these people that you were sent to? 15 A 16 17 14 Q Did you ever show that book to your lawyers? No, I don't. 15 Q Where are your notes? 16 A No. A I burned them. 17 Q Did you show that book to anyone? 18 Q When did you burn them? 18 A My husband. 19 A In a bonfire when I lived at Titusville 19 Q Did you show it to anyone else besides because I was sick of going through this shit. 20 20 your husband? 21 A No. 22 you at the time you built a bonfire and burned these 22 Q Did you tear out pages and give them to 23 notes? 23 24 A 21 25 Q Did you have lawyers who were representing I've been represented for a long time, but it was not under the instruction of my lawyers to do 24 25 Sharon Churcher? A No, I wrote -- those pages that you're talking about, I wrote for her specifically. She Page 206 Page 208 1 this. My husband and I were pretty spiritual people 1 2 and we believed that these memories were worth 2 Q So that's a different piece of paper? 3 burning. 3 A Yeah, that's just random paper. Q So you had a green spiral notebook that 4 Q So you burned notes of the men with whom 4 wanted to know about the Prince Andrew incident. 5 you had sex while you were represented by counsel in 5 you began sometime in 2011 or 2012 in which you wrote 6 litigation, correct? 6 down your recollections about what had happened to 7 you, and you burned that in a bonfire in 2013. MR. EDWARDS: Object to the form. 7 8 9 10 11 12 A This wasn't anything that was a public document. This was my own private journal, and I didn't want it anymore. So we burned it. Q (BY MS. MENNINGER) When did you write that journal? 9 A You got that right. 10 Q And do you have no other names of people 11 to whom you claim Ghislaine Maxwell directed you to 12 have sex, correct? Just over time. I started writing it 13 A At this time, no. 14 probably in, I don't know, I can't speculate, 2012, 14 Q Is there any document that would refresh 15 2011. 15 13 16 17 A Did I get that right? 8 Q So you did not write this journal at the time it happened? 16 your recollection that you could look at? A If you have a document you'd like to show 17 me, I would be glad to look at it and tell you the names I recognize off of that. 18 A No. 18 19 Q You started writing this journal 19 20 approximately a decade after you claim you finished 20 21 being sexually trafficked, correct? 21 Q I'm just asking you if there's a document you know of that has this list of names in it? A Not in front of me, no. Q Where is the original of the photograph 22 A Yes. 22 23 Q And you started writing a journal after 23 that has been widely circulated in the press of you 24 with Prince Andrew? 24 25 you had a lawyer, correct? A Correct. 25 A I probably still have it. It's not in my VIRGINIA GIUFFRE 5/3/2016 52 (205 - 208) Agren Blando Court Reporting & Video, Inc.Page 55 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 209 1 possession right now. Page 211 1 A My little yellow Kodak camera. 2 Q Where is it? 2 Q Who took the picture? 3 A Probably in some storage boxes. 3 A Jeffrey Epstein. 4 Q Where? 4 Q And where did you have it developed? 5 A In Sydney. 5 A I believe when I got back to America. 6 Q Where in Sydney? 6 Q So where? A At some family's house. We got the boxes 7 A I don't know. 8 Q Palm Beach? 7 8 shipped to Australia, and they were picked up off the 9 porch by my nephews and brought to their house. 9 A I don't know. 10 Q Which is where? 10 Q What is the date the photograph was 11 A In Sydney. 11 printed? 12 Q Where in Sydney? 12 A I believe it's in March 2001. 13 A 13 Q Okay. 14 Q And who lives in that house? 14 A But that's just off of my photographic 15 A Well, it's owned by my mother-in-law and 15 memory. I don't -- it could be different, but I 16 think it's March 2001. 16 father-in-law, but my nephews live in the house. 17 Q What are their names? 17 18 A I'm not giving you the names of my 18 19 20 Q You have a photographic memory? A I'm not saying I have a photographic nephews. 19 memory. But if I'd look at the back of the photo and Q What's the address of the house? 20 I remember what it says, I believe it was March 2001. 21 A Why would you want that? 21 22 Q I want to know where the photograph is. 22 Q Did the photograph ever leave your possession for a while? 23 I'm asking you where the photograph is. And you've 23 A I gave it to the FBI. 24 just told me it's somewhere in 24 Q Okay. And when did you get it back? 25 A When they took copies of it. 1 Q When was that? 25 A Yes. 1 Q So where in 2 located? 2 A 2011. 3 A If I can't 100 percent say that the 3 Q When they came to interview you? 4 photograph is there, it could be at my house that I 4 A Yes. 5 presently live in. I'm not going to give you the 5 Q So from 2011 until you left Colorado it 6 address of my nephews' residence. 6 Page 210 Q 7 8 is the photograph When is the last time you saw the photograph in person? Page 212 was in your personal possession? 7 A Yes. 8 Q What other documents related to this case 9 A When I packed and left America. 10 Q Colorado? 10 11 A Yes. 11 12 Q All right. So you had that photograph 12 I don't know. I really can't tell you. I mean, 9 are in that, storage boxes in Australia? MR. EDWARDS: Object to the form. A Documents related to this case -- there -- 13 there's seven boxes full of Nerf guns, my kids' toys, 14 A Yes. 14 photos. I don't know what other documents would be 15 Q What's on the back of the photograph? 15 in there. 16 A I'm sorry? 16 Q 17 Q Is there anything on the back of the 17 those documents after you received discovery requests 18 from us in this case? 13 18 here with you in Colorado? photograph? A 19 There's like the date it was printed, but 19 A (BY MS. MENNINGER) Did anyone search I haven't been able to obtain those boxes. 20 I can't get them sent back up to me. It's going to 21 Q Okay. Does it say where it was printed? 21 cost me a large amount of money. And right now I'm 22 A 20 no writing or anything. I don't believe so. I think it just -- I 22 trying to look after my family, so I'm not able to 23 don't remember. I just remember there's a date on 23 afford to get them up. 24 it. 24 Q You live in Australia, correct? 25 A I do. 25 Q Whose camera was it taken with? VIRGINIA GIUFFRE 5/3/2016 53 (209 - 212) Agren Blando Court Reporting & Video, Inc.Page 56 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 213 1 2 3 4 Q Okay. How far away are the boxes from where you live in Australia? A Page 215 1 2 Sydney is down here at the bottom. Cairns is up here at the top. 3 We've had lots of bonfires there. Q Did you ever ride in a helicopter with Ghislaine Maxwell acting as pilot of the helicopter? 4 A Yes. 5 Q Okay. 5 Q Who else was on the flight? 6 A It's probably a six-day drive. 6 A I've been on the helicopter with her 7 Q Did you fly here through Sydney? 7 plenty of times. I can't mention how many people 8 A No. 8 were on the -- on the helicopter at the same time. Q Have you been to Sydney since you've moved 9 10 11 12 13 back to Australia? A I flew into Sydney with my three kids, but it was a connecting flight to Brisbane. Q 9 Q How many times? 10 A I don't know. Do you have helicopter 11 12 Did you ask your nephews or anyone else to records that you could show me? Q I'm asking you how many times you were on 13 the helicopter with Ghislaine Maxwell acting as the 14 search those boxes in response to discovery requests 14 pilot -- 15 that we issued in this case? 15 A 16 17 18 19 A They are my nephews. I would never let them look at those. Q It's impossible for me to answer the 16 question without having the actual physical records 17 in front of me. Q I'm asking you to look into your memory Other than your green spiral notebook, 18 what else did you burn in this bonfire in 2013? 19 and tell me how many times you recall being on a That was it. 20 helicopter with Ghislaine Maxwell at the pilot seat? 20 A 21 Q That's the only thing? 21 22 A Yes. 22 23 Q Did you use wood? 23 24 A Yes. 24 25 Q Charcoal? 25 1 A A There is no number I can give you. There's plenty of times I've been on her helicopter. Q Where did you go from and to on a helicopter? A I believe it was -- don't quote me on this Page 214 Page 216 My husband built the bonfire out of wood 1 because I get confused on the islands there. I want 2 and I don't know what else he put in it. He's the 2 to say it was St. John's. It could have been 3 one who always makes the fires, not me. 3 St. Barts. St. John or St. Barts, and then we would fly straight to Jeffrey's island. 4 Q Who else was present? 4 5 A Just him and I. 5 6 Q Were your kids there? 6 7 A No. They were inside sleeping. 7 A No. 8 Q And what beach was this? 8 Q Were you ever on the helicopter with 9 A It wasn't a beach. It was in my backyard. 10 Q What's your address? 10 11 A At that time? 11 A No. 12 Q Um-hum. 12 Q Were you ever on the helicopter with 13 A Q Okay. Did you ever go anywhere else on the helicopter? and Ghislaine Maxwell as the pilot of the 9 helicopter? and Ghislaine Maxwell as the 13 14 15 A Yes. 15 16 Q Who were your neighbors? 16 17 A Sweet people. Ray and -- I could look on 17 pilot? A No. Q Do you recall telling Sharon Churcher that you were? 18 A No. Q No, thank you. Do they still live there? 19 Q Did you see the press article in which 20 A Yes. 20 21 Q Do you keep in touch with them? 21 22 A Last time I talked to them was a few 22 that if you're going to ask this witness about a 23 specific article I'd like for her to see the article. Otherwise she's not going to testify about it. 18 19 23 my phone if you want. months ago. 24 Q Did they see the fire? 24 25 A They've seen many fires that we've had. 25 Sharon Churcher reported that you were? MR. EDWARDS: Objection. I'd just ask If you have something to show her, then, VIRGINIA GIUFFRE 5/3/2016 54 (213 - 216) Agren Blando Court Reporting & Video, Inc.Page 57 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 217 1 please. (BY MS. MENNINGER) Do you recall seeing a 2 3 press article in which Sharon Churcher reported that 3 4 you were on a helicopter with 4 5 Ghislaine Maxwell as the pilot? 2 Q Page 219 1 and MR. EDWARDS: Again, I'll let you answer 6 in. And Ghislaine likes to talk a lot of stuff that sounds fantastical. And whether it's true or not, that is what I do recall telling Sharon Churcher. the question once she's looking at the document that 7 you're being asked about. 8 9 10 answer a question about whether she recalls a 10 11 particular press statement? 11 12 MR. EDWARDS: I will let her answer every 12 13 question about the press statement as long as she 13 14 sees the press statement. I'm okay with that. She 14 15 can answer all of them. 15 MS. MENNINGER: No, there is a rule of I believe that it was taken out of 6 8 MS. MENNINGER: You're not letting her A context. Ghislaine told me that she flew 5 7 9 flying on a helicopter with Ghislaine Maxwell? Q So you told Sharon Churcher that Ghislaine Maxwell is the one who told you that she flew in the helicopter? A I told Sharon Churcher that Ghislaine flew onto the island, based upon what Ghislaine had told me. Q Not based upon what had told you, correct? 16 A Correct. 17 civil procedure that allows you to direct a witness 17 Q Did you ever ask Sharon Churcher to 18 not to answer a question when there's a claim of 18 correct anything that was printed under her name, 19 privilege. 19 concerning your stories to Sharon Churcher? 16 What privilege are you claiming to direct 20 21 her not to answer this question? accurate answers from this witness. If the -- 22 23 MS. MENNINGER: I asked her if she 24 25 21 MR. EDWARDS: I thought that you wanted 22 23 20 recalled something -- A I wasn't given those stories to read before they were printed. Q After they were printed did you read them? A I tried to stay away from them. They were 24 very hard. You have to understand it was a very hard 25 time for me and my husband to have to have this Page 218 MR. EDWARDS: If the sole purpose is to 1 2 just to harass her -MS. MENNINGER: I asked her if she 3 4 recalled something -- public -- we didn't think it was going to be this 2 publicly announced and that big. So we turned off 3 the news and we stopped reading so many things. 4 MR. EDWARDS: Then that's just not going 5 Page 220 1 5 Q You didn't read the articles about your stories to Sharon Churcher -- 6 A I've read some articles -- (BY MS. MENNINGER) All right. So you're 7 Q Let me just finish. You did not read the 8 refusing to answer a question about whether you 8 articles published by Sharon Churcher about your 9 recall a particular press statement -- 9 stories to Sharon Churcher? 6 7 to be what's happening today. Q MR. EDWARDS: She's -- 10 11 Q 14 (BY MS. MENNINGER) -- is that true? MR. EDWARDS: She is not refusing to 12 13 10 answer any questions. She -A I'm not refusing to answer. I just want A I have read some articles about what 11 Sharon Churcher wrote. And a lot of the stuff that 12 she writes she takes things from my own mouth and 13 changes them into her own words as journalists do. And I never came back to her and told her 14 15 to see the article you're talking about so I can be 15 to correct anything. What was done was done. There 16 clear in my statement. 16 was nothing else I can do. 17 Q (BY MS. MENNINGER) Do you recall seeing a 17 18 press article written by Sharon Churcher reporting 18 19 that you flew on a helicopter with 19 20 Ghislaine Maxwell as the pilot? 21 22 A 25 No, I do not recall reading a press article saying that I was on a helicopter with as Ghislaine is the pilot. 23 24 and Q Do you recall telling Sharon Churcher that you had conversations with Q So even if she printed something that were untrue you didn't ask her to correct it, correct? A There was things that she printed that 20 really pissed me off, but there was nothing I could 21 do about it. It's already out there. 22 Q 23 correct? 24 regarding him 25 She printed things that were untrue, MR. EDWARDS: Objection to the form. Mischaracterization. VIRGINIA GIUFFRE 5/3/2016 55 (217 - 220) Agren Blando Court Reporting & Video, Inc.Page 58 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 223 Page 221 1 A I wouldn't say that they were untrue. I 1 to why I want my client to answer all of these 2 would just say that she printed them as journalists 2 questions, but I want her to have the fair 3 take your words and turn them into something else. 3 opportunity to see this document. 4 Q MR. EDWARDS: Object to the form. 5 6 (BY MS. MENNINGER) She got it wrong? 4 5 Mischaracterization. Q (BY MS. MENNINGER) Did Sharon Churcher print things that you felt were inaccurate? MR. EDWARDS: Same objection. Same 6 7 A In some ways, yes. 7 instruction. If she sees the document, she's going 8 Q (BY MS. MENNINGER) Did she print things 8 to answer every one of these questions. 9 in her articles that you did not say to her? 9 MR. EDWARDS: I object and ask that the 10 Q (BY MS. MENNINGER) Did any other reporter 10 print statements that you believe are inaccurate? MR. EDWARDS: Same objection. Same 11 witness be given the opportunity to see the document 11 12 so that she can review it and answer that question 12 13 accurately. Otherwise she's unable to answer the 13 14 question. I'm not going to allow her to answer. 14 statements about Ghislaine Maxwell that were 15 inaccurate? MS. MENNINGER: You know the civil rules 15 16 17 tell you not to suggest answers to your client. Q instruction. Q (BY MS. MENNINGER) Did any reporter print MR. EDWARDS: Same objection. Same 16 (BY MS. MENNINGER) And you understand 17 instruction. 18 your lawyer is now directing you to not all of a 18 This is harassing. This is harassing a 19 sudden remember what your answer is. That's what 19 sexual abuse victim. And all I'm asking is for 20 he's suggesting that you say. So you're not supposed 20 fairness, that we just let her see the document so 21 to listen to him suggest that to you. You're 21 she can answer this. 22 supposed to tell me from your memory. 22 MR. EDWARDS: That is not what I'm -- 23 24 Q (BY MS. MENNINGER) Did you -MR. EDWARDS: That's not what I'm doing. 25 MS. MENNINGER: Mr. Edwards, please stop 23 saying anything other than an objection, what the 24 basis is, or instructing your client not to answer. MR. EDWARDS: I will do that. 25 Page 222 You don't get to just talk over me and 1 Page 224 MS. MENNINGER: That's what the Federal 1 Rules of Civil Procedure provide. 2 tell my client when not to listen to me. All you 2 3 have to do to get answers is show her the document 3 4 you're talking about, and I'll let her answer every 4 provide for fairness and civility. And all I'm 5 question. I don't know why we're so scared of the 5 asking, very calmly, is for her to see this. 6 actual documents. 6 MS. MENNINGER: I don't know why you're 7 MR. EDWARDS: I hear you. They also MS. MENNINGER: Mr. Edwards, this is not 7 your deposition. I'm asking your client what she 8 scared of your client's recollection, Mr. Edwards. 8 remembers. If she doesn't want to talk about what 9 But anyway -- 9 she remembers, then let her not answer. But you 10 cannot instruct her not to answer unless there's a 11 privilege. MR. EDWARDS: Why would you do this to 10 11 12 13 her? Q (BY MS. MENNINGER) Did Sharon Churcher print things that you did not say? MR. EDWARDS: I am instructing her not to 13 MR. EDWARDS: I'm going to instruct my 14 What privilege -- 12 14 answer. 15 client not to answer unless you give her what it is 15 16 that you're talking about that was printed. And she 16 refusing to answer questions about whether statements 17 will tell you the answer, the accurate answer to your 17 to the press about Ghislaine Maxwell attributed to 18 question. Just without the document to refresh her 18 you were inaccurate? 19 recollection and see it, she's not going to answer 19 20 the question. 20 answer. 21 A 21 22 23 24 25 Q (BY MS. MENNINGER) Did Sharon Churcher print things that you did not say? MR. EDWARDS: Same objection. Same instruction not to answer. (BY MS. MENNINGER) All right. You are MR. EDWARDS: She's not refusing not to You are refusing to show me these 22 documents so I could answer properly. I would give 23 you an answer if you were to show me some documents. 24 I think I've made a very clear record as Q 25 Q (BY MS. MENNINGER) You can't say without looking at a document whether the press attributed to VIRGINIA GIUFFRE 5/3/2016 56 (221 - 224) Agren Blando Court Reporting & Video, Inc.Page 59 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 227 Page 225 1 you is accurate or inaccurate? 1 2 A Please show me the document. 2 3 Q You can't say from the top of your head 3 4 whether any inaccurate statement has been attributed 4 5 to you in the press? 5 6 A 7 you. 8 9 10 11 12 13 Q Please show me a document and I will tell Are you refusing to answer my questions about your knowledge of whether inaccurate statements have been attributed to you in the press? A 6 Single sheets. Q And did you write a long document or a short document? What was it? A I can't recall how long the document was, but I would say it would be a few pages. Q And other than asking you to write 7 whatever you remember about 8 give you any other directions about what you should 9 write? 10 Are you refusing to give me the documents A A , did she She was interested in two things, really. 11 How Epstein got away with so many counts of child 12 trafficking for sex and how Q Are you refusing to answer the question? 13 involved in it. Those were her two main inquiries. A I am refusing to answer the question based to look at? was 14 Q What did she ask you to write? 15 upon the fact that you are not being fair enough to 15 A She asked me to write about 16 let me see the document in order to give you an 16 Q Did she tell you to put it in your own 17 honest answer. 17 14 handwriting? A 18 Q Ms. Giuffre -- 18 19 A Yes. 19 20 Q -- we are talking about press that has 20 Q 21 . No, she just asked me to write down what I can remember. Did you give her everything that you 21 wrote? Yes. 22 A Q Do you have access to the Internet? 23 I wrote? A Yes. 24 Q Yes. Q Have you looked on the Internet and read 25 A Yeah, I wrote pages for her specifically. Q In your own handwriting? been published on the Internet, correct? 22 A 23 24 25 Did I give her the whole entire pages that Page 226 Page 228 1 articles that attribute statements to you about 1 2 Ghislaine Maxwell? 3 2 A In my own handwriting. A Yes. 3 Q And what you wrote, was that true? Q Do you know any statement that has been 4 A Yes. 5 attributed to you in a press article on the Internet 5 Q And did you get paid for those pieces of 6 about Ghislaine Maxwell that is untrue? 6 paper? 7 A Not for the papers, I don't believe. 8 Q Okay. Have you gotten paid when they've 4 MR. EDWARDS: Same objection. Same 7 8 instruction. 9 A Please show me a specific document. 10 Q (BY MS. MENNINGER) Do you know of any 9 10 11 such statement about Ghislaine Maxwell attributed to 11 12 you by the press that is inaccurate? 13 14 15 16 17 A 12 If you could please show me a specific document. Q Tell me what Sharon Churcher asked you to write for her. A Any knowledge that I had about my time A No. Q Have you negotiated any deal with Radar Online? 13 A No. 14 Q Have you negotiated any deal with Sharon 15 Churcher for the purpose of publishing those pieces 16 of paper? 17 A Q Not those pieces of paper. . 18 Q And did you write it? 19 20 A Um-hum. 20 A A week before she came out. 21 Q What did you write it in or on? 21 Q (BY MS. MENNINGER) And when did you give 22 A Paper. 22 23 Q What kind of paper? 23 A When she came out. 24 A Lined paper. 24 Q When was that? 25 Q Was it in a book or single sheets? 25 A Sometime, I believe, in early 2011. 18 19 with been reprinted? When did you write those pieces of paper? MR. EDWARDS: Object to the form. them to her? VIRGINIA GIUFFRE 5/3/2016 57 (225 - 228) Agren Blando Court Reporting & Video, Inc.Page 60 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 229 1 2 Q What did you get paid for, if not for those pieces of paper? 2 MR. EDWARDS: Object to the form. 3 3 I was paid for the picture with 4 5 with his arm around me, Ghislaine in the 5 6 background. And I was paid for the, I guess, the 6 7 print of the stories. 7 4 8 A Page 231 1 Q (BY MS. MENNINGER) Anything else? 9 A No. 10 Q You were not paid for those pieces of 11 paper? 8 9 that you were 16 years old? A No. I think -- I think they had played the guessing game and I was 17. Q And so Ghislaine Maxwell did not tell that you were only 16? MR. EDWARDS: Object to the form. Speculation. Q (BY MS. MENNINGER) In your presence? A I don't remember the exact conversation. 10 I just remember they liked to play the guessing game 11 a lot. 12 A No. 12 13 Q All right. And how many pieces of paper 13 telling 14 quote, only, really only 16, right? 14 did you write? 15 A 16 17 18 Like I said, I'm rounding it around three. 15 Q Three pieces of paper? 16 A That's what I -- I don't remember to be 17 exact on a number. I'm sorry. But over three pages. 18 19 Q And you wrote those sometime in 2011? 19 20 A The week that she was coming out to see 20 And so you don't recall Ghislaine Maxwell in your presence that you were A Correct, I don't remember that. Q And if that were in the paper, that would be untrue, correct? A Correct. MS. MENNINGER: I think now might be a good time for a break. 21 THE DEPONENT: Thank you. Q And you gave them to her, right? 22 MR. EDWARDS: Okay. Sounds good. 23 A I gave them to her. 23 24 Q Did you keep a copy of that? 24 25 A No. 25 1 Q Did you rip them out to make them look 21 22 me. Q THE VIDEOGRAPHER: We're off the record at 2:45. (Recess taken from 2:45 p.m. to 2:55 p.m.) Page 230 2 3 4 5 like they came out of a journal? Page 232 THE VIDEOGRAPHER: We're back on the 1 2 record at 2:55. Q (BY MS. MENNINGER) Do you have any A No. 3 Q Were you directed to make them look like 4 photographs of yourself either nude or in a sexually 5 compromising position that you claim were taken by Ghislaine Maxwell? they came out of a journal? 6 A No. 6 7 Q Do you know why your lawyer would have 7 8 told the federal judge in New York that that's what 9 you did? MR. EDWARDS: Object to the form. 10 A I do not have any of those in my evidence. 8 But if you ask Ghislaine Maxwell, she would have 9 plenty. 10 Q Do you have any in your storage boxes in 11 A My lawyer in New York? 11 Sydney? 12 Q (BY MS. MENNINGER) Um-hum. 12 A No. 13 A Ripped them out of a journal? 13 Q Do you know whether your attorneys have 14 Q Said that you had. Do you know why she 14 any such photographs that you claim were taken by 15 Ghislaine Maxwell? 15 would have said that? Maybe she thought that I did. 16 A No. Q But you didn't? 17 Q You don't know or they don't have them? A They were just pieces of paper written for 18 A I don't know. And I don't think they have 16 A 17 18 19 20 21 Sharon Churcher's purpose. Q And not directed to look like they came from a journal? 19 them. If they had them, they would have told me. 20 You should ask your client. She's got plenty of 21 them. Nobody told me to make them look like they 22 Q 23 came from a journal. They were just pieces of paper 23 use? 24 that I wrote down for Sharon Churcher. 24 A 22 25 A Q Did Ghislaine Maxwell tell 25 What type of camera did Ghislaine Maxwell It was a black camera. And it had a, I don't know the types and names of them, but the lens VIRGINIA GIUFFRE 5/3/2016 58 (229 - 232) Agren Blando Court Reporting & Video, Inc.Page 61 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 233 1 that goes out. Page 235 1 you were doing with Ghislaine Maxwell? 2 Q Was it digital or single reflex? 2 A Yes. 3 A Again, I don't know types of cameras. I 3 Q Did you tell him what you were doing to 4 mean, I use my phone for using a camera. So it's a 4 5 black camera and it had a lens that you could put out 5 6 further or bring back. 6 7 Q 8 you? Did you ask her to take any photographs of other people? A I don't think I told him about many other people, no. 7 Q What people did you tell him about? 8 A Mainly Ghislaine and Jeffrey. 9 A No. She asked to take photographs of me. 9 Q When did you tell him that? 10 Q Was it a film or a digital camera? 10 A From the start. 11 A I never saw how she printed them out. 11 Q When was the start that you told him? Q What's the first time you told anybody 12 A From, I wouldn't say the first meeting, 12 13 that you had been sexually trafficked? MR. EDWARDS: Form. 14 15 13 A 14 Tony Figueroa, my ex-boyfriend, knew some 15 but I told him around that time. Q And what did tell you to do? A He didn't mind what I had to do. Again, 16 of the stuff that was happening, though I did not go 16 17 in great detail to him, being that he's my boyfriend. 17 he was another guy that used me because I made lots 18 And then the first person I really opened up to about 18 of money, and he didn't tell me to do anything. 19 everything was my husband. 19 Q Did he tell you not to tell the police? (BY MS. MENNINGER) Did you tell Tony 20 A No, he didn't tell me not to do anything. 21 Figueroa that you were forced to have sex with 21 Q Did he tell you to tell the police? 22 Jeffrey Epstein? 22 A Again, he told me not -- he didn't tell me 20 Q 23 A Yes. 23 24 Q Did you tell Tony Figueroa you were forced 24 25 to have sex with Ghislaine Maxwell? 25 to do anything. Q When did you tell your parents that you were sexually trafficked by Jeffrey Epstein? Page 234 1 2 3 A Yes. Q Did you tell that Ghislaine Maxwell sent you to have sex with famous people? 4 A Yes. 5 Q When did you tell A During conversations. Like, I'd call him 6 Page 236 1 2 3 4 that? 5 6 A After I had my kids. Q When did you tell your parents that you were sexually trafficked by Ghislaine Maxwell? A I told them the same time about Jeffrey and Ghislaine. So sometime after I had my children. Q After you had had all three children or 7 from places that I was at and just talk to him. And 7 8 like I said, I wouldn't get into great detail about 8 A 9 things. But, you know, I had to be with this person 9 children. 10 or that person today and -- 11 Q 12 police? 13 14 15 A Did you tell 10 not to call the 12 No. enjoyed his lifestyle with me. 13 So he wouldn't have gone to the police. Q 11 Did you tell that you were sexually trafficked? after you had your first child? Q I think after I had all three of my What was the last year in which you had a child? A 2010. Q So you believe you told your parents 14 sometime after 2010 that you had been sexually 15 trafficked? 16 A Yes. You know, I don't know what I told 17 Q You didn't tell your parents that you had 18 at the time. I know he asked me and I think I told 18 a lawsuit entitled Jane Doe 102 versus Jeffrey 19 him, but I didn't get into detail with him. 19 Epstein in 2009? 16 17 A 20 Q What do you think you told him? 20 A I wasn't very close with my parents. 21 A That I wasn't just massaging these people. 21 Q Why not? 22 Q Did you tell him what you were doing with 22 A We just had a hard relationship. 23 Q Why? 24 A Because we did. I don't know why. Some 23 Jeffrey Epstein? 24 A Yes. 25 Q Did you tell what 25 people just don't get along. VIRGINIA GIUFFRE 5/3/2016 59 (233 - 236) Agren Blando Court Reporting & Video, Inc.Page 62 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 237 Page 239 Q Do you get along with your parents now? 1 been through. I think for ten, however long many 2 A I get along with my parents now, yes. 2 years, I mean, over ten years, I had tried to start a 3 Q Okay. Have you ever told anyone that you 3 new life, become a new person. And I wanted to put 4 all that stuff behind me and not think about it. But 5 after you have children, something changes in you and 6 you just want to stand up and do the right thing and 1 4 5 6 were a sex slave for four years? A Under the assumption that I got my dates wrong, yes, I probably have. 7 Q And that's not true, correct? 7 protect any other children from having to go through 8 A Not because I didn't mean it to be true. 8 this. 9 10 Just because I didn't know my dates. Q 9 So four years is not two years, correct? MR. EDWARDS: Object to the form. 11 Q Did you tell your parents how much money 10 you received from your settlement with Jeffrey 11 Epstein? A No. That is a -- I think there's like a 12 A Four years is not two years. 12 13 Q (BY MS. MENNINGER) What did your parents 13 non-disclosure statement. I don't know exactly what the legal term is, but -- 14 say when you told them that you had been sexually 14 15 trafficked by Jeffrey Epstein and Ghislaine Maxwell? 15 Q Did you send any money to your parents? A No, I don't -- no. No, I've never sent 16 A I believe they were disgusted. 16 17 Q What did they tell you to do or to not do? 17 18 A I don't remember the exact conversations 18 Q Who is 19 A One of 20 Q Did you talk to 19 20 21 that we had, but they weren't happy. Q Were they both on the phone at the same time? 22 A 23 Q 21 ? shady friends. about your involvement with Jeffrey Epstein? No. 22 A Who was on the phone first? 23 Q Did you ever live with 24 A No, he used to come over to my house. 25 Q Between 2000 and 2002 did you ever have MR. EDWARDS: Object to the form. 24 money to my parents. 25 A I don't know. 1 Q (BY MS. MENNINGER) You were in Australia No. ? Page 238 2 at the time, correct? 2 A Yes. 3 Q When? Q They were not? 4 A When I tried to break away from Jeffrey A Yes. 5 and Ghislaine, I started making myself unavailable. Q Have they ever been to see you in 6 And I got a job at Road House Grill. And Tony used 7 to come pick me up in the afternoons, at nighttime, 8 and he'd sit at the bar. And there's this big cup 9 that's got tips in it. A 4 5 7 8 9 10 any interactions with law enforcement? Yes. 3 6 Page 240 1 Australia? A My dad has. Q Has your mom ever been to see you in Australia? 10 I was in the back room. And I had to -- 11 A No, my mom is afraid of flying. 11 first you have to sign out and you have to take off 12 Q When did your dad come to see you in 12 your aprons, put your aprons away. And there's a 13 whole bunch of cleaning up stuff you have to do. 14 In that time period, Tony grabbed money 13 14 Australia? A The birth of my son, my first one in 2006. 15 And then, I believe in 2010 when my daughter was 15 from a cup that had money in it. That was for the 16 born. 16 bartenders for their tips. My boss called me the 17 Q 17 next day. He told me that I had stolen the money, 18 which I hadn't. And I came back and I returned the 19 money after I confronted Tony about it. Gave the 20 money back to him and he said, I'm sorry, but it's 21 just law that I have to call the police. So he 22 called the police. 18 19 20 21 22 And did you have this conversation with your dad about this in person or on the phone? A I've had conversations with him about it since. Q I'm talking about the first time you had a conversation with your dad. 23 A On the phone. 23 24 Q What caused you to tell him in 2010? 24 Beach Police Department in his pocket, I went to 25 A I was just starting to accept what I had 25 Jeffrey Epstein and I told him what had happened. And knowing that Jeffrey has got the Palm VIRGINIA GIUFFRE 5/3/2016 60 (237 - 240) Agren Blando Court Reporting & Video, Inc.Page 63 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 241 Page 243 1 And Jeffrey said, Don't worry about it. Let me take 1 2 care of it for you. 2 3 4 Q Okay. I'm sorry. When did you have interaction with law enforcement, then? 3 A What year? 5 6 Q Did you speak with a law enforcement 6 7 officer? 7 8 A 8 9 I don't believe I spoke to them. Jeffrey handled everything. Q Q 9 Okay. And you said that you had finished 10 Did you ever check to see if you had a warrant out? 4 5 10 never heard anything about it ever again. A No. Jeffrey told me that he took care of Q Do you think it's a problem to leave the it. country when you have an outstanding warrant? MR. EDWARDS: Object to the form. Foundation. Lack of predicate. A I don't think I have an outstanding 11 your shift at -- this is at the Road House Grill, 11 warrant. Why would I -- do you have a document that 12 correct? 12 says I have an outstanding warrant? 13 A Correct. 13 14 Q You had finished your shift? 14 you believe it's a bad thing to leave the country 15 A Yeah, it was the end of the shift. 15 when you have an outstanding warrant? Q Okay. And you had cleaned up and were 16 A Absolutely. 17 Q And you would never assist someone in 16 17 18 19 20 checking out, correct? A Yeah, it's a completely separate part of 18 Q (BY MS. MENNINGER) I'm just asking you if doing that, correct? the -- it's like back of the house. Do you know what 19 A Correct. that means, like in waitering terms? 20 Q During the year 2015, have you spoken to 21 Q (Indicating.) 21 law enforcement about any topic other than Ghislaine 22 A Yeah, back of the house. 22 Maxwell? Q And what was -- who was this boss that you 23 A In 2015? 24 Q Um-hum. 25 A Did I talk to any law enforcement about 23 24 spoke to? 25 A I can't remember his name. 1 Q Okay. 1 A But, I mean, he was very nice. He didn't 2 Page 242 2 Page 244 Ghislaine Maxwell? Q About anything other than Ghislaine 3 want to but he just had to because it's just the law. 3 4 You know, the money was returned to him, but he still 4 5 had to do what he had to do. 5 this point in time and instruct the witness not to Maxwell? MR. EDWARDS: And I would just object at 6 Q You paid him back the money the next day? 6 convey any answers as to who she has or who she has 7 A Very next day. 7 not disclosed until such time as the Court rules on 8 Q And did you ever speak with the Palm Beach 8 the current outstanding motion. 9 10 County Sheriff's Office about it? A I know that we have some obligations to 9 You know, I don't know if they called me 10 fulfill by the 4th. We intend to do that. And I 11 or not, but I know that since my boss told me he had 11 also recognize we may be back to answer some of these 12 to call the police, I went to Jeffrey. And Jeffrey 12 questions. But for today, she's not going to answer 13 said he'd handle it. 13 those questions. Q How old were you at the time? 14 15 A I don't know, 18, maybe 19. 15 16 Q You weren't a juvenile, were you? 16 17 A Well, juvenile being under 18, no. 17 Q Is that the only interaction with law 18 law enforcement in Colorado since the beginning of enforcement that you had between 2000 and 2002? 19 January 2015? 14 18 19 20 A Correct. 20 21 Q Were you, in fact, charged with theft 21 based on that case? MS. MENNINGER: Well, I'm just going to ask them and -MR. EDWARDS: I understand. Q A (BY MS. MENNINGER) Have you spoken to any I can't answer that question right now. MR. EDWARDS: Hold on one second. I may 22 be able to get you an answer to that question. Can I 23 A No charges were ever brought to me. 23 take -- can I just take a quick break, and I think I 24 Q Do you know if they were filed? 24 can answer that particular question for you? 25 A No. Jeffrey told me he'd handle it, and I 25 22 MS. MENNINGER: I'm not asking you to VIRGINIA GIUFFRE 5/3/2016 61 (241 - 244) Agren Blando Court Reporting & Video, Inc.Page 64 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 245 1 answer any questions -- Page 247 1 2 MR. EDWARDS: Fine. 2 3 MS. MENNINGER: -- Mr. Edwards. 3 4 MR. EDWARDS: Fine. 4 MS. MENNINGER: I appreciate it, but I'm 5 6 asking the witness to answer these questions. MR. EDWARDS: I know, I'm just trying to 7 8 help you today. A No. He went to everything that he was supposed to go to. Q Has he paid his fines? 5 A Yes, as far as I know. 6 Q Describe for me the contract that you had 7 8 For today, don't answer the questions. 9 other terms of his probationary period? 9 with the Mail On Sunday? A Could you be a little bit more specific? Like -Q Have you had more than one contract with 10 THE DEPONENT: I don't mind explaining. 10 11 MR. EDWARDS: I know, but you -- 11 12 THE DEPONENT: Okay. 12 13 MR. EDWARDS: I wanted to help. 13 picture. And that was to pay me 140,000 for the THE DEPONENT: Okay. 14 picture. And then two stories were printed after 15 that for the amount of 10,000 each. 14 15 Q (BY MS. MENNINGER) So have you spoken to 16 any law enforcement officers in Colorado since 16 17 January of 2015 until today? 17 18 A I am not answering that question. 18 19 Q Have your attorneys spoken to any law 19 20 enforcement officers in Colorado since the beginning 20 21 of 2015 until today? 22 23 24 25 the Mail On Sunday? A Q Well, there was one contract for the Is that the only money that you received from the Mail On Sunday? A Correct. Q Did you receive any money for syndication of the photograph? 21 A Isn't that what the 140 was for? A I'm not answering that question. 22 Q I'm asking you. Q Have you been living with your husband in 23 A Well, I don't really know what syndication 24 means. 25 Q Australia since October of 2015? A Yes. Did you have a written contract with the Page 246 1 Page 248 1 2 A Yes. 3 Q Where is that contract right now? A I don't know. I've moved that many times. 4 5 . 7 Q Q 7 Sydney? 8 A I don't think I kept it, to be honest. Q Did you ever refer back to it after you 10 11 15 11 Q signed it? A I know I kept it for a short while, but I mean, like I said, I've moved countries twice in the 13 last two years and three different houses. So the 14 paper trail is lost. I don't know where it would be. 16 17 25 Is it possible it's in the boxes in 12 15 . I -- I lose paperwork wherever I go. 6 9 . Mail on Sunday? Q Did you receive it via e-mail? A No. I received it -- Sharon Churcher handed it to me by paper. 18 Q And you signed it? 19 A I signed it. 20 Q And then did you make a copy of it? 21 A No. 22 Q You never had a copy of it? 23 A Well, I had my own copy. I'm sure she has 24 hers. 25 Q Do you recall there being a period of VIRGINIA GIUFFRE 5/3/2016 62 (245 - 248) Agren Blando Court Reporting & Video, Inc.Page 65 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 249 1 exclusivity? Page 251 1 who have been interested in it and I still don't know 2 A Yes. 2 if I want to do it yet. I mean, I think there's a 3 Q What was that period? 3 lot more that can go into it, you know. 4 A I believe it was like a three-month period 4 5 6 7 8 9 or something. Q Okay. And what other terms of the contract, do you recall? A publication about the story. You were actively sending the manuscript 5 to people for purposes of having them reach a deal 6 with you and publish it, correct? 7 I couldn't talk to any other news Q A No deal was ever talked about. What we 8 talked about was the possibility of publishing it, is 9 it publishing-worthy, would I need to get a 10 Q Anything else? 10 ghostwriter. You know, this is the first time I've 11 A Not that I know of. 11 ever written a manuscript so I didn't know what I was 12 Q Were you happy when the period was up? 12 doing. 13 A Well, I mean, at that time I wanted to 13 Q Okay. You contacted Jarred Weisfeld, 14 write about my story. So I guess, yes, I was happy 14 correct? 15 when that period was up. 15 A Correct. Q I'm going to mark a document as 16 17 Q And you were actively writing a book at that time, correct? 16 17 Defendant's Exhibit 16. It is a composite exhibit. 18 A My manuscript. I've never published it. 18 (Exhibit 16 marked.) 19 Q You were writing the manuscript at the 19 MR. EDWARDS: Thank you. Q (BY MS. MENNINGER) I'm not going to ask 20 time of your period of exclusivity with Sharon 20 21 Churcher, correct? 21 you to read every single page of this, but if you 22 look at the first page. 22 23 24 25 A Those three months were just craziness. I think I started after that. Q You think you started writing the book after the 90 days were up? 23 A Um-hum. 24 Q Can you tell what this is in terms of what 25 type of document? Page 250 1 2 3 Page 252 A Yeah. 1 Q And then you attempted to sell that 2 manuscript, correct? A 3 I didn't attempt to sell it. I went to A It's an e-mail from me to Jarred. Q Okay. And there's also e-mails from Jarred to you on the same page, correct? 4 A Yes. 5 other publications, like, what do you call them? 5 Q And can you tell -- I just presume that 6 People -- I'm trying to think of the name of the 6 you know that you have turned over documents in this 7 word. People who publish books, not like a newspaper 7 case; is that true? 8 or anything. And I inquired about what they thought 8 9 of my manuscript and if they thought it was, you 4 10 11 know, a good story. And, yeah. Q So you sent the manuscript to these people 9 A Yes. Q All right. And do you see at the bottom 10 it's got your name and some page numbers in the 11 bottom right-hand corner? 12 for the purposes of trying to publish the book, 12 A 13 correct? 13 Q Right. 14 A Some people, yes. 14 A Yes. Q And you were trying to get money from the 15 Q So you understood that your lawyers sought 15 16 book publication, correct? 17 A 18 for free. 19 Q 20 21 16 Well, I wasn't going to sell it to them But you were unsuccessful in finding someone to publish it, correct? A Well, I was always on the fence with it. Giuffre 003529? from you e-mails, for example? 17 A Yes. 18 Q And searched your computer, correct? 19 A Correct. 20 Q And printed out e-mails, correct? 21 A Yes. 22 I wasn't too sure if I wanted to or didn't want to. 22 Q And these look like some of the e-mails? 23 I was more seeking judgment based upon these people 23 A Yes. 24 who have done this plenty and plenty of times. 24 Q Okay. Do you have any reason to believe 25 Still to this day, I mean, I've had people 25 that e-mails produced by your lawyers with your name VIRGINIA GIUFFRE 5/3/2016 63 (249 - 252) Agren Blando Court Reporting & Video, Inc.Page 66 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 253 Page 255 1 on the e-mail address line are anything other than 1 2 your e-mail? 2 A Yes. MR. EDWARDS: I object just to the 3 A No, they're my e-mails. 3 4 Q Okay. Did anyone else use your e-mail 4 MS. MENNINGER: Of 2012? 5 account? 5 MR. EDWARDS: Being the first e-mails. No. 6 MS. MENNINGER: I only meant the first Q Okay. 7 A I mean, well, my husband uses it 8 6 A 7 8 9 apparent mischaracterization. sometimes. My kids use it for games. pages of this composite exhibit. MR. EDWARDS: Okay. MS. MENNINGER: But I appreciate your 9 10 Q Okay. 10 11 A But that's about it. 11 12 Q So if an e-mail is signed XOXO Jenna -- 12 13 A Yes. 13 this composite exhibit are dated July of 2012, 14 Q -- is that you? 14 correct? 15 A Correct. 15 A Q All right. And do you believe anyone else 16 16 17 in your family was communicating with 17 18 A No, no one else. 19 20 Q All right. What was the purpose of you 20 22 MR. EDWARDS: Okay. Q communicating with Jarred? A We were trying to figure out if my book (BY MS. MENNINGER) The first e-mails of Correct. MR. EDWARDS: The first page. As opposed to the first in the chronological timeline. MS. MENNINGER: Yes. 18 19 21 clarification. MR. EDWARDS: Okay. Q (BY MS. MENNINGER) If you flip sort of 21 anywhere towards the back, can you also see that 22 you -- there are e-mails between yourself and Jarred 23 was -- my manuscript was ever published or 23 in 2011? 24 publishable. And this was at a time where there was 24 A Excuse me. And which page? 25 a lot of controversy about what's going on around JE. 25 Q Really, you can take your pick anywhere Page 254 And when I say JE, I mean Jeffrey Epstein. 1 Page 256 1 2 It was a very scary thing for a lot of publishers to 2 3 even consider taking it on because Jeffrey is a very 3 4 powerful person. 4 from the back of that exhibit? A Yeah, yeah, I see what you're talking about. Q Here. Why don't I direct you to the Q Did you send your manuscript to Jarred? 5 bottom right is Giuffre 3563. Now, it's going to be 6 A I believe I did. 6 a little tricky to find, but it's about eight 7 Q All right. Did you ask Jarred to send it 7 pages -- I'm sorry, six pages from the back of the 8 composite exhibit. 5 8 on to other people like MR. EDWARDS: Object to the form. 9 10 11 12 A met Q I can't -- I can't recall. I believe I through Jarred. 9 A Yes. 10 Q Do you see on that page an e-mail from 11 (BY MS. MENNINGER) Okay. I'm going to 12 yourself to Jarred from June 7th of 2011? A Yes. Q And in that e-mail you write: Dear Jarred 13 ask you to turn -- well, on the first page, the 13 14 second e-mail says, is Epstein too big for 14 Weisfeld, We spoke on the phone going back a couple 15 months regarding the story I am writing called, The 16 Billionaires Playboy Club. Does that refresh your recollection that 15 16 17 Jarred and had something to do with one another? A Yes. 17 Q Okay. And on the second page in the Right? 18 A Correct. 19 middle of the page, just to be clear, is that an 19 Q I am no longer under any contract and 20 indication that, 20 would like to ask you to review my synopsis and if 21 book, XOXO Jenna. 21 you are interested I would love for you to represent 22 me as my literary agent. 18 Is that what you wrote? 22 23 24 25 definitely does not want the A Yes. 23 Q And these first e-mails are in 2000 -- 24 A Correct. 25 Q I've included some of the press that has July of 2012, correct? Correct? VIRGINIA GIUFFRE 5/3/2016 64 (253 - 256) Agren Blando Court Reporting & Video, Inc.Page 67 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 259 Page 257 one? All right. 1 covered the ongoing case of Jeffrey Epstein, the 1 2 world's richest pedophile. And my good friend and 2 MR. EDWARDS: What are we on now, 17? 3 journalist Sharon Churcher has a few from her 3 MS. MENNINGER: 17. 4 articles that she has written to send to you as well. 4 (Exhibit 17 marked.) 6 Q (BY MS. MENNINGER) Very similarly, can Correct? 5 A Correct. 6 you take a look at this exhibit? It is a composite Q 5 I am very serious about getting my book 7 of documents produced by your attorneys with various 8 published and believe this story will cover many 8 Bates ranges, Bates numbers in between Giuffre 2750 9 genres of interest, not only by those following the 9 and 3928. 7 10 lengthy case, but it is also a woman's story of 10 A 2750 and -- 11 glitz, glamour, sorrow, compassion, and true love. I 11 Q I think -- I think the last page is 3927, 12 hope you enjoy. 13 12 but it does not contain all of -- I'm sorry, 3928. Correct? 13 But it does not contain all of the pages in between, just to let you know. 14 A Correct. 14 15 Q Signed, yourself? 15 16 A Yes. 16 17 Q So in about June you sent to Jarred 17 A Okay. Is there one specific that you want me to look at? Q No, if you can just take a look at the first page. 18 Weisfeld a synopsis and were asking him to represent 18 19 you as your literary agent to sell the book, correct? 19 A Okay. Q And tell me if you know who this person A Paulo Silva is somebody who works for the 20 21 22 A Yes. 20 Q And you characterized Sharon Churcher as 21 your good friend, correct? 22 is? 23 Mail On Sunday. And he was the one in charge of 24 understand, Jarred and Sharon are very close. Sharon 24 paying me. 25 is the one who introduced me to Jarred. And that's 25 Q Paying you for what? 1 A The 140 plus the 10 and the 10. Q Okay. And did he also pay you on an 23 A Well, at that time -- you have to Page 260 Page 258 1 2 3 4 5 6 7 8 9 just being nice. Q Do you disagree that Sharon Churcher was your good friend at that time? A Well, at that time I did trust her a lot more than what I do now. Q 3 ongoing basis for further sales of the photograph of 4 yourself and 5 Why did you change your opinion of Sharon Churcher? A 2 You know, I -- I just -- I think -- I think talking to some journalists can be very A ? No, it was a set fee of 140 plus the 10 6 and 10. But they broke it up for some reason. So as 7 you can see here, Thanks for transferring the money. 8 I will let you know when it reaches my bank account 9 but just a little bit confused as I have a previous 10 dangerous, especially sometimes how words can get 10 e-mail with the amount owed at 4100. Is there still 11 taken out of context. And I'm not saying that she's 11 an outstanding amount yet to be paid. 12 a bad person. I'm just saying that just, I wouldn't 12 13 call her up and ask her what she's cooking for dinner 13 different fractions but it still equaled the 140 plus 14 tonight or how the family is doing. 14 the 10 and the 10. 15 Q 16 stylist? 17 A 18 19 20 21 Did you ever introduce her to your hair 15 So they broke it up into quite a lot of Q Okay. If I could ask you to flip back to 16 Giuffre 2758. They're in sequential order, so it No. 17 should be about eight pages back. Q All right. 18 A Yes. A Oh, actually, yes, I did. She did get a 19 Q All right. Do you see -- do you see that haircut where I was at. Q All right. that's an e-mail from Paulo Silva to your e-mail 21 account? 22 A Yes. 23 e-mails with Paulo Silva, please. I'm going to mark 23 Q On or about March 28th, 2011? 24 these Defendant's Exhibit -- 18 -- 17. 24 A Yes. 25 Q All right. And it appears to be his 22 25 MS. MENNINGER: So if I could have the 20 Oh, I don't know if that's -- is that just VIRGINIA GIUFFRE 5/3/2016 65 (257 - 260) Agren Blando Court Reporting & Video, Inc.Page 68 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 263 Page 261 1 introductory e-mail to you. Is that a fair 1 what the terms of your agreement were with this 2 characterization of it? 2 syndication, Solo Syndication? 3 A It would be hard to say. Like, I'd have 3 A of -- 4 to look at the first one. That's June 24th. This is 4 5 March 28th. I suppose so, if he's introducing 5 6 himself as Paulo Silva. 6 7 Q All right. And in this e-mail he 8 introduces himself by name and tells you that he 9 works for Solo Syndication and represents they are quite frequently over the last few weeks. So far we've been able to sell it to the following clients. 9 It lists names. 10 11 Mail On Sunday and that he's been overseeing the 11 12 syndication of your image, correct? 12 14 Correct. Q All right. And then he tells you that 13 So far the total sales, as of last Friday, is the number listed there. Therefore, your share is 4,487. Q So let me be clear. I guess I'm asking, 14 do -- do you recall what your deal was with Solo 15 Syndication? 15 with regard to your image with 16 confirm that they've been able to sell it frequently 16 17 over the last couple of weeks. And he listed the 17 Sharon writing up the contract saying 140 plus the 10 18 names of various news agencies to whom they had sold 18 and the 10. I completely forgot about the 19 the image, correct? 19 syndication for $4,000 and 487 cents (sic). 20 he can I can confirm we've been able to sell it 8 the official syndication agency for Daily Mail and A In regards to your image with 7 10 13 Well, like you said, it looks like half A A Correct. 20 Q Q No, I do not recall it. I just remember Okay. I'm going to ask you to turn back And then he tells you what the sales were 21 to 2754. 22 as of last Friday and then what your share of it is, 22 A 23 correct? 23 Q Correct. 24 A Correct. 24 A Okay. 25 Q And your share of it was approximately 25 Q And it's a document with the heading Solo 21 2754? Page 262 1 half of whatever the sales were, correct? Page 264 1 Syndication Limited. Is that the right page you're on? 2 A Yes, it looks that way. 2 3 Q All right. And so then he gave you their 3 A 4 Q Dated May 23rd, 2011, correct? 5 A Yes. Q All right. And there's some handwriting 4 5 general payment terms, correct? A Yes. Yep. 6 7 8 9 (Deponent perused document.) Q 6 And is that syndication deal separate and apart from your deal with the Mail On Sunday to get 7 Yes. in the middle of the page towards the bottom. 8 A Not my handwriting. 9 Q It's not your handwriting? Yes. 10 A No. paid for the stories and a chunk -- 10 A 11 Q -- for the image? 11 Q Do you know whose it is? 12 A So I will have to correct my previous 12 A No. 13 Q All right. 14 Q Okay. 14 A I don't even know what it says. Does it 15 A 13 statement. So I forgot completely about the fact that 15 say Chai canceled and something mode? I have no idea 16 I received 4,487.50 for -- for the pictures that got 16 what it even says. 17 sold. 17 Q And is it possible it was sold some more Q Okay. And it's not your handwriting? 18 A No. 19 after this date, for which you received some money, 19 Q It was produced by your attorneys, 20 correct? 20 correct? 21 A 21 A I'm sorry? It was produced to us by your attorneys, 18 I don't believe so. I -- I didn't even 22 remember this one, to be honest. So if there's any 22 Q 23 others that you can show me, I'd be happy to look at 23 correct? 24 them. 24 25 Q Well, I'm just asking you if you remember 25 A Yes. They went through and gave you guys everything you asked for. VIRGINIA GIUFFRE 5/3/2016 66 (261 - 264) Agren Blando Court Reporting & Video, Inc.Page 69 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 265 1 Q All right. Since these e-mails come from Page 267 1 backwards. 2 your e-mail address to and from Paulo Silva, do you 2 3 have any reason to doubt that they are your e-mails? 3 May 25th, is it more or less likely that it was I have no reason to doubt. 4 written on June 5th or May 6th? 4 A 5 Q All right. Do you recall a Sandra White? 5 6 A Yes. She was a possible ghostwriter that 6 7 I was going to use. Sharon recommended that I got a 7 8 ghostwriter to be involved. And we nearly settled on 8 Q Right. So if an e-mail is responding to MR. EDWARDS: Object to the form. A I would say May 6th. Q (BY MS. MENNINGER) So when responded to a May 25th -- 9 some kind of agreement, but I wasn't really happy 9 10 with the agreement in the end, so I decided not to 10 going backwards because it's going up, isn't it? 11 use her. 11 Okay. Yes. 12 13 Q You weren't happy with the terms of her price, if you will? A Oh, no, you're right. No, I'm sorry, I'm 12 Q All right. 13 A I'm confused, too. Q Anyway. In the last e-mail it says: I'm 14 A Yes. 14 15 Q And so you didn't come to an agreement 15 very sad we won't be able to work together as I've 16 17 18 19 with her, correct? 16 been very excited about the project. As you know, I A We nearly did, but we in the end did not. 17 do not sell synopsis or individual chapters, and Q All right. If I can show you Defendant's 18 especially not for those amounts. I'm merely 19 intrigued about where you were getting advice from. 20 Rest assured what we have worked on is confidential. 21 If you change your mind, let me know. Exhibit -- whew -- 18. MR. EDWARDS: You did kill a tree there. 20 21 Q (BY MS. MENNINGER) Take a look at that. 22 (Exhibit 18 marked.) 22 23 THE DEPONENT: So put this one away? 23 A 2011. 24 MR. EDWARDS: Put these in some sort of 24 Q 2011, right? 25 A Yes. 1 Q 25 order. They don't have to be perfect, but just so So that was around June 5th? Page 266 1 you know what you're looking at. This is 18? 2 3 4 5 6 7 8 9 10 11 12 Q (BY MS. MENNINGER) All right. Again, do you recognize that the e-mail address -- Page 268 All right. So you had been trying to 2 reach an agreement with Sandra White prior to 3 June 5th? 4 A Correct. A Is mine. 5 Q And were unable to do so? Q -- is yours and it's from and to Sandra 6 A Yes. 7 Q And not that you need to read every page, White, correct? A Correct. Q And the date is in or around May 25th, June 5th, something like that? A but is it fair to say that you exchanged some 9 portions of your synopsis with Sandra during the 10 It's Australian so it's backwards. So 11 it's the 6th of May, 2011. Q 8 Well, I would have thought that except the course of your interactions with her? A Yes. And she rewrote some portion of it 12 as well, which I don't even know, it might be in 13 here. It might not be in here. I don't know what 14 bottom e-mail is May 24th, the middle one is May 25th 14 I've kept or not kept. 15 and then the most recent one says 6/5. So I don't -- 15 16 I don't know. I didn't write the document. 16 Churcher with respect to the terms upon which you should be looking for the ghostwriting agreement? 13 17 18 19 A Yeah. 17 Q But I'm asking if you believe it was in or 18 around the end of May? A Okay. And did you get advice from Sharon Sharon is the one who introduced me to 19 Sandra. I can't remember who was giving me the The only reason I can tell you that is 20 advice. It's going back so long ago, you know, I 21 because if you look here, 24/5/11 is the way that we 21 don't want to pinpoint somebody and say it was 22 actually do our dates in Australia, whereas in 22 definitely them if it wasn't. 23 America you would do 5/24/11. 23 20 A Q 24 So right here where it's written makes it 24 25 nice and clear but just to be clear, the dates are 25 So, yeah, I'm just not going to comment on that one without knowing. Q Okay. You probably have e-mails, though, VIRGINIA GIUFFRE 5/3/2016 67 (265 - 268) Agren Blando Court Reporting & Video, Inc.Page 70 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 269 1 do you think, perhaps? 2 A 3 So -- 4 Q 5 I haven't seen these e-mails since 2011. Okay. I'm going to show you Defendant's Exhibit 19. 7 Q 8 Strong? 3 Q Um-hum. 4 A Oh, sorry. (Pause.) 7 8 9 A She's my literary agent. Q All right. And can you identify 9 10 Defendant's Exhibit 19? Thank you. So it cuts off after that, does it? 2 6 (BY MS. MENNINGER) Who is Marianne 10 11 A Yep, I've read it. 5 (Exhibit 19 marked.) 6 Page 271 1 11 Q All right. Do you remember that e-mail now? A It's going back a long time ago, but it's definitely my kind of writing. Q Okay. So in the -- on the bottom of the first page, 3417 -- 12 A I'm sorry? 12 A Um-hum. 13 Q Can you identify what Defendant's 13 Q -- you represented to Marianne Strong that 14 Exhibit 19 is? A 15 16 Defendant's Exhibit 19, like the number at the bottom? Q No, do you know what kind of document this 19 A Oh, it's an e-mail from me to Marianne 20 Strong. 17 18 is? 21 Q 22 frame? 14 you had served four years as Jeffrey Epstein's 15 personal and abused sex slave, correct? 16 A Correct. 17 Q That is not true, correct? 18 A Since we have now found out the actual 19 20 All right. And at roughly what time dates, it is not correct. Q Okay. I want to turn the page, the second 21 page. On the first line, the first full sentence 22 that begins on the first line: 23 A February 20th, 2014. 23 24 Q All right. And what were you speaking 24 were once vulnerable girls that looked like the sweet with Marianne or writing with Marianne Strong about? 25 girl next door but now that they have been taken 25 Even though there is over 40 women that Page 270 1 A 2 3 6 Page 272 1 advantage of by this disgusting Wall Street tyrant, tell you? 2 most of them have led a very unhealthy lifestyle Q 3 since having served Jeffrey, such as drug addictions Sure. (Pause.) 4 and prostitution and do not hold accreditation to A Sure. 5 talk. Q Do you remember now the topic upon which 6 4 5 Can I just read it real quick and I'll 7 you and Marianne Strong were exchanging 7 8 communication? 8 9 A I don't recall talking about 9 10 10 . I don't know who Emily is. But I You wrote that, correct? A Correct. Q Who are the 40 women that you are talking about here? A When I spoke to the FBI, they told me that 11 there were -- and this is maybe just a guesstimate, 12 do understand what she's saying. If I win, then my 12 maybe there was more, maybe there was less that they 13 story would be a much better story to write. 13 said. But they had told me that there was a lot of 14 other victims involved in this case. And this is 15 when I believed that after the FBI came to see me 16 that they were willing to reopen the case and do something about it. 11 14 Q 15 know? 16 A And what case was she referring to, if you I think this was regarding probably the 17 time when I was in -- trying to get involved with the 17 18 CVRA case. 18 Q In February of 2014? 19 20 A Correct. 20 21 Q Okay. And at the bottom of the page 21 19 22 there's an e-mail from you to her, correct? I haven't read that part yet. Give me one Q Okay. So the FBI is the one that told you that there were 40 women? A It could be less than 40. It could be more than 40. I think I just summed it up to 40. 22 Q You came up with 40? 23 A Well, I didn't just come out with 40. I 23 A 24 moment. 24 think it was around that number. It could be 46. It 25 Q 25 could be 39. I'm not too sure to be exact. Yeah. VIRGINIA GIUFFRE 5/3/2016 68 (269 - 272) Agren Blando Court Reporting & Video, Inc.Page 71 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 273 Page 275 Q All right. But you based it on -- 1 the assumption that the case was being reopened, that 2 A On my speaking -- 2 they still were investigating. 3 Q -- what? 3 4 A -- with the FBI. 4 5 Q Okay. And -- 5 1 MR. EDWARDS: Just let her finish her 6 7 6 question before you answer. MR. EDWARDS: I just want the record 9 Q (BY MS. MENNINGER) Who at the FBI did you 11 I can't think of his name. I spoke to -- And then sometime when you were in Florida going to continue investigating the case? 11 A Q 9 10 speak with? I believe that's when they first started Jason Richards told you that they were not actually clear. 13 A to reinvestigate and reopen it. 8 10 12 Okay. Did you believe that the FBI had reopened their case in 2011? 7 THE DEPONENT: Okay. 8 Q A I believe I was in Florida, yes. And he didn't say that -- he just said his hands were tied 12 and up above, I don't know, chain of command, it 13 just -- it didn't look like it was going anywhere. 14 oh, God, I can't even think of his name right now. I 14 There was no definite no and a definite yes. It was 15 spoke to a male and a female. And I also spoke to 15 just, right now there's really nothing that we can 16 Marie Villafana about everything that was happening. 16 do. Q All right. In the third paragraph from 17 Q Is it Jason Richards? 17 18 A Jason Richards, yes. 18 the top, you said there's another major paper that 19 Q Did Jason Richards tell you that the FBI 19 has followed the story for a while that has worked 20 with me before and they were asking you for the 20 was reopening their case? A He wanted to reopen the case. And the 21 exclusive story but updated and obviously the end 22 last conversation that I had with him, I can't 22 outcome from the judicial decision. 23 remember when it was, he said that he was having 23 Who was the other major paper that had 24 trouble doing it from the people above him. 24 followed the story for a while and was asking you for 25 an exclusive story? 21 25 Q Okay. When was that? 1 A Like I said, I don't know. 1 Q Was it like a year ago or two years ago or 2 must be the Daily Mail. If I said I've worked with 3 them before, the only other -- the only other, what Page 274 2 3 three years ago? Page 276 A That would -- that, just coming to mind I don't remember the last time I talked to 4 do you call them, press, that I had worked with was 5 him. I think I was in Florida the last time I spoke 5 the Daily Mail, so -- 6 to him. 6 4 A Q Okay. But you said you had held out on 7 Q And was that on the phone or in person? 7 them because Marianne had told you about her contact 8 A On the phone. 8 with Emily at the New York City Post, right? 9 Q Hmm? 10 A On the phone. 10 your contact with Emily with the New York Post, and I Q On the phone. Where was he located, if 11 appreciate you trying to make big headlines for the 12 story and hopefully one day the book. Yes. 11 12 9 you know, when you spoke to him? A Q I have held out because you told me about Okay. And then the last line of that 13 A I don't know. 13 14 Q Do you have his phone number? 14 paragraph you say: I would also like to know that 15 A I'm going to profit from this as well, correct? I have his card somewhere. Probably not 15 16 on me anymore. Like I told you, my paper trail is 16 A 17 (indicating). 17 free. Q Okay. So in the fourth line you say: 18 19 Miraculously since I came to light with the truth in 19 20 speaking out against him in 2011, the FBI have 20 21 reopened the case. Which as you know, has current 21 22 proceedings in which I am involved in. 18 Q So what current proceeding were you 23 24 25 involved in on February 19th, 2014? A Well, just speaking with the FBI, I was in Correct. I'm not going to give it for Right. All right. (Exhibit 20 marked.) MS. MENNINGER: Defendant's Exhibit 20. Q (BY MS. MENNINGER) Do you recognize these 22 documents -- this document, which is another 23 composite exhibit? 24 A Yes. 25 Q Do you recognize it? VIRGINIA GIUFFRE 5/3/2016 69 (273 - 276) Agren Blando Court Reporting & Video, Inc.Page 72 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 277 1 2 A Oh, like I said, I don't recognize it, but it obviously comes from -- Page 279 1 Q Right. 2 A But anything they had of me. Q And Brad Edwards, who is sitting right 3 Q Your e-mail address? 3 4 A Yes. 4 here, was your attorney at the time and you Q Now, what e-mail address is that, exactly, 5 identified him as such in the e-mail, correct? 5 6 on the first page of this exhibit? 6 7 A @icloud.com, that must be from a phone. 7 8 Q So that's different from the other e-mail 8 9 10 11 address? A 9 Yeah, I don't actually know about that e-mail address. I obviously used it. A Correct. Q You did not identify Mr. -- Judge Cassell as your attorney in this e-mail, correct? A I knew him as a former judge, and I just 10 wrote down, Judge Paul Cassal (sic) as it looks. But 11 he was my attorney -- I don't know if he was my 12 attorney at that time. But yes -- he's always -- Q And is the e-mail signed by your husband? 13 he's been with me since the beginning, so -- 14 A No, it's signed by me. 14 Q 15 Q Okay. And in the subject line you wrote 15 correct? 13 Virginia Roberts (Jane Doe 102), correct? So he's representing you in this case now, 16 A Yes. 17 A Subject line? 17 Q But at that time you don't know if he was 18 Q The very top line of that page. 18 19 A Oh, yeah, I see. 19 20 Q Okay. And it was to 20 with him since the beginning. And this is dated jason.richards2@ic.fbi.gov, correct? 16 21 22 23 24 your attorney? A I think he was. I mean, I've been talking 21 2014. So I believe at this time he was my attorney A Correct. 22 at the time as well. Q And is that Jason Richards we were just 23 referring to? 25 A 1 Q 24 Yes. 25 Q Okay. When do you recall first speaking with him? A Speaking with Paul, I'm not too sure. I Page 278 2 3 4 5 All right. And you had some e-mails with Jason Richards over time; is that fair? Page 280 1 can't remember if I spoke to Paul in the phone in 2 Australia or if I met him in person in Florida. A Sure. 3 Q These ones that came from your computer, 4 right? A Sure, yes. 6 7 Q Okay. You talk about having spoken with 7 9 Judge Paul Cassell in this first page, correct? A I am here to get this BS non-prosecution 8 9 Do you remember when you signed any kind of fee agreement with him? MR. EDWARDS: Object to the form. 5 6 8 Q A Um, the -- well, the first time I would have signed an agreement would have been in Florida. Q (BY MS. MENNINGER) When you were living in Titusville? 10 agreement thrown out and speaking with Judge Paul 10 11 Cassal (sic). He suggested trying to get ahold of 11 mean, I'm looking at e-mails that I can't even 12 any photos or video recordings released by the FBI to 12 remember sending. It's a possibility I could have 13 assist our case further in providing (sic) how much 13 signed earlier, but as far as I remember. 14 pedophilia occurred by Jeffrey and the many other 14 15 monsters he obliged with underage girls. A Q As far as my knowledge reminds me. I Okay. Do you recall ever having e-mail 15 communications with Sharon Churcher about her 16 Q Okay. 16 publishing the first serial of your book? 17 A If this is a possibility, please let me 17 A Serial, what does that mean? I'm sorry. 18 know so I can give you Brad Edwards (my attorney) his 18 Q Like a sequel. 19 contact details. Many thanks for your time and I 19 A A sequel to my book? 20 hope we should meet again. 20 Q Um-hum. 21 A My book has never been published. Q Right. Do you remember ever e-mailing 21 Q Okay. And so you were going back to Jason 22 and trying to get any evidence that the FBI had about 22 23 your case, right? 23 with Sharon about her being the one who would publish 24 any subsequent follow-up book? 24 25 A Correct. Any photographs pertaining to what -- myself, not of anyone else. 25 A If you have something in front of you to VIRGINIA GIUFFRE 5/3/2016 70 (277 - 280) Agren Blando Court Reporting & Video, Inc.Page 73 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 281 Page 283 family? 1 see and show me I would look at it. Like I said, 1 2 there's a million e-mails here. I mean, there's a 2 A We've been doing well. 3 whole dead tree with e-mails I don't remember 3 Q You've been doing well? 4 sending. So -- 4 A Yes. 5 Q What is your source of income right now? 6 A My husband is the main income -- he's the 5 6 Q So you don't remember that e-mail chain, as you sit here? breadwinner and I'm a stay-at-home mom. 7 A Yes. 7 8 Q Okay. You have signed contingency fee 8 Q 9 A 9 10 11 12 agreements with Boies, Schiller, correct? A Yes. Q You've signed contingency fees with . 12 Q And how long has he had that job? Correct. 13 A He got that job, I believe, in December or Q Mr. Edwards and his firm? 14 January. December 2015 or January 2016. I know he A Correct. 15 got the job and then we had to go through all these Q Stan Pottinger; is that correct? 16 preliminary tests and everything to make sure you A Correct. 17 qualify. So -- Q And pursuant to those fee agreements you 18 Mr. Cassell, correct? 13 A 14 15 16 17 18 And what is his job? 19 understand that you would get a recovery of any money 19 20 that you won in this case, correct? 20 Q And what is the last paid employment that you had? A The last paid employment that I had was -- 21 A Correct. 21 there was that -- do you remember going back through 22 Q And what percent is that? 22 the e-mails where I had that resume and I sent it and A I don't know off the top of my head. I 23 they said, What time do you want to come for an 24 think it's 40 percent. I'm not too sure, to be 24 interview? 25 honest. 25 23 I ended up getting the job there for two Page 282 Q 2 with 3 obtain from this case or from any other source 3 4 related to this? 4 employed by them. And other than that, the last time 5 I worked was in -- ended in 2006 for ET Australia. 5 A Do you remember having any conversations Page 284 1 about money that you hoped to I remember talking to as a 1 days because the place was disgusting and the boss 2 was just horrible. 6 girlfriend telling her what cases I was involved 6 7 with. I don't believe we ever spoke about any 7 8 monetary settlements. There was no number that was 8 9 ever mentioned. I told her that I was involved in I didn't get paid from them, but I got Q Did you quit that job after two days because the place was disgusting? A It was vile. Okay. They had the -- the 9 whole place was closed down. The restaurant was 10 these cases. And, you know, it was just girlfriend 10 closed down for a period of, like, six months. And 11 talk between girlfriends. I never expected her to 11 he wanted me to go into this freezer area that had a 12 turn around and consort with the enemy. 12 dead rat in it and like this thick (indicating) layer 13 of mold at the bottom. And he wanted me to clean it. 13 14 Q MR. EDWARDS: Form. 15 16 Well, it's fair to say you do hope to make money from bringing this lawsuit, correct? A I hope to win, but that's not the only 14 Q All right. 15 A And I was just like, No. 16 Q Just checking, did you quit or did he fire you? 17 reason I want to win. I want to see justice come 17 18 through. 18 19 Q 19 20 (BY MS. MENNINGER) Is money one of the reasons you want to win? 20 MR. EDWARDS: Same objection. 21 No, I definitely walked out of that one, Q Okay. I'm going to do one more document I have, quickly. More than the money, I want to see 22 23 Ghislaine and Jeffrey own up to what they have done 23 24 and pay for the price, yes. 24 Defendant's Exhibit 21, another composite exhibit. 25 Do you recognize the to and froms on this e-mail? 22 25 A 21 A hands up. Q (BY MS. MENNINGER) Is money tight in your (Exhibit 21 marked.) Q (BY MS. MENNINGER) I'll show you VIRGINIA GIUFFRE 5/3/2016 71 (281 - 284) Agren Blando Court Reporting & Video, Inc.Page 74 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 287 Page 285 1 2 3 A To Sharon Churcher from myself, yes. 1 Supposedly JE purchased her at age 14 from her Q And this is the Sharon Churcher from Mail 2 family. On Sunday we were discussing earlier? 3 Q Okay. And then you asked her to call to A That's correct. 4 5 Q And these are from February of 2011, 5 6 correct? 6 7 A Yes. 7 Q Right. 8 Q Okay. 8 A Yes. A I mean, it's just assuming that we're not 9 Q 4 9 10 looking at Australian backwards dates. Q 11 12 Okay. Well, a few pages back, where it says 2/19/2011. 13 14 discuss that, correct? A I tried to call. The line was busy. Could you call concerning the question you asked? All right. Defendant's Exhibit 22. 10 (Exhibit 22 marked.) 11 THE DEPONENT: Thank you. 12 A Oh, yeah, yeah. 13 Q All right. If I could direct your 14 Q (BY MS. MENNINGER) Okay. Do you recognize these series of e-mails? A So far. I mean, it's definitely from me 15 attention to one of the pages, it's 3676 in the lower 15 to her. Or actually, Michael Thomas is the 16 right-hand corner. 16 photographer that worked with her, just to be clear. 17 A 3676. 17 Q Now, these are in sequential order. Q And is she one of the two -- the 18 recipients of the first-page e-mail? You and she 19 They're not in Bates stamp order so you might have to 19 received an e-mail from Michael Thomas; is that 20 look at the dates on the top to find one that's 20 right? 21 February 19th of 2011. 21 A Yes. 22 Q Okay. 18 THE DEPONENT: Do you know which page it 22 23 is? MR. EDWARDS: I think she wants you to 23 24 MR. EDWARDS: Well -- 24 25 MS. MENNINGER: It's almost in the middle. 25 1 MR. EDWARDS: It's like what she's saying look and make sure you recognize them. Q (BY MS. MENNINGER) Yeah, do you recognize Page 286 2 is that -- 4 2 MS. MENNINGER: If you look at the date at 3 the top -MR. EDWARDS: If you look at the top it 5 Page 288 1 4 recognize Sharon's name and I recognize Michael 5 Thomas. says 2/19/2011. That's not it. It's like half a 6 page. Keep going. 7 9 10 2/13, 2/17, 2/18, 2/19 -- 2/19/2011. Q (BY MS. MENNINGER) If it says 3676 in the lower right-hand corner? 8 9 Q A I don't have any -- Q -- from yourself and Ms. Churcher are 10 accurately reflected from the documents taken from your computer here? A Yes. 11 12 Q Okay. Is that an e-mail that you sent to 12 A 13 Sharon Churcher in response to an e-mail that Sharon 13 Q 14 Churcher sent to you? 16 A R-E, received, yes. I tried to call the line was busy. Could 17 18 19 you call concerning the question you asked? Q 15 Okay. Q (BY MS. MENNINGER) Defendant's 16 Exhibit 23. Again, e-mails between your e-mail 17 address and Sharon Churcher from May of 2011. Do you recognize your e-mail address? 18 All right. And that was in response to an I have no reason to doubt that. (Exhibit 23 marked.) 14 To Sharon Churcher from Jenna, Subject Do you have any reason to doubt that the e-mails from March of 2011 -- 11 15 Like I said, these are back in 2011, but it's from my e-mail address. I recognize that. I 7 A A 3 6 8 the document, the e-mails? 19 A Yes. 20 e-mail just below it you received from Sharon 20 Q And Sharon Churcher's e-mail address? 21 Churcher, correct? 21 A Yes. Q And you're signing your e-mails to her, 22 A Yes. 22 23 Q And what did Sharon Churcher write to you 23 Much love, XOXO Jenna. And she's signing her e-mails 24 to you, Love Shaza, correct? 24 25 on February 19th of 2011? A Do you know a ? 25 A Correct. VIRGINIA GIUFFRE 5/3/2016 72 (285 - 288) Agren Blando Court Reporting & Video, Inc.Page 75 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 289 1 2 3 Page 291 Q And Shaza is a name that you call her? 1 phrase sex trafficked as that is a heads up about the A In Australia we kind of shorten the names 2 book revealing more than be printed. of people and put z-a on the end, so yes. 3 Q All right. So is Sharon Churcher writing Q So she became Shaza? 4 5 A She became Shaza, correct. 5 A Yes. 6 Q And do you recall having e-mail 6 Q And I only use Brad, not his last name 4 7 communications with her in which you referred to her 7 8 as Shaza and -- 8 9 A Yes. 10 Q -- she referred to herself as Shaza? 10 11 A She's the same person we're talking about, 11 12 13 14 9 yes. Q 12 All right. So it's coming from her e-mail address as Sharon Churcher, right? 15 A 16 Q Yes. Q All right. And that's Brad Edwards, who is sitting here, right? A Yes. Q All right. And so in the e-mail from 14 should let Vanity Fair buy your picture, she's also Yes. 15 recommending in the last line that you should have All right. And I think the last -- 16 Brad use the phrase sex trafficked, correct? 17 18 MS. MENNINGER: Almost. 18 19 MR. EDWARDS: Okay. Okay. I just have to 19 22 A Sharon Churcher to you regarding whether or not you MR. EDWARDS: Are you at a stopping point? a make a quick call, but I can wait a while so -MS. MENNINGER: I understand. Almost 21 because it's brad@pathtojustice.com, correct? 13 17 20 to you about -- actually, it's cc'd to Brad, correct? done. 20 A If a statement is made, yes. I don't think Vanity Fair ever did, anyway. Q And the picture that they're talking about there is the one with , correct? 21 A That's -- yeah, the big one. 22 Q The one that was previously sold? 23 MR. EDWARDS: Okay. 23 A Yes. 24 (Exhibit 24 marked.) 24 Q And Paulo Silva was syndicating that one, 25 correct? 25 Q (BY MS. MENNINGER) This is Exhibit 24, Page 290 Page 292 1 e-mails between yourself and Sharon Churcher from 1 2 June of 2011? 2 3 4 5 A Yes. Yeah. Q And on that second page there's a A Um-hum. Yes, sorry. 3 Q And, again, Shaza and Jenna, Shaza, Jenna, 4 A I have no idea. 5 Q You don't know? Jenna, Shaza, right? redaction. Who is -- who is in that redaction? 6 A Yes. 6 A No, I don't know. 7 Q And at the bottom of this first page, is 7 Q So who are the two world's most respected 8 Sharon Churcher giving you advice regarding the 9 purchase by Vanity Fair 10 8 politicians? and who? 9 A I don't know. 10 Q Do you recall ever telling Sharon Churcher 11 A May I have time to read it, please? 11 that you were trafficked to two of the world's most 12 Q Please. 12 respected politicians, A Are we talking about the very bottom one 13 else? 13 14 or the one in the kind of middle bottom? Q The very bottom one. 15 16 A I would let VF buy your picture via Brad. 16 17 The big gamble would be to let him also give them a 17 18 statement. 18 19 Q 20 A 21 MR. EDWARDS: Object to form. 14 15 and somebody A Is that her wording? This is from her. So this is her wording. Q (BY MS. MENNINGER) Right. A If she considered them to be the world's Right. 19 most respected politicians, that would be her (Deponent perused document, sotto voce.) 20 opinion, not mine. The reason this is a gamble is Jeffrey 21 Q Okay. But you received this e-mail and 22 knows some of the most powerful people in publishing 22 23 and, once altered, will inevitably try to scare off 23 24 potential buyers. But the upside is it should help 24 to? Sorry. It just confuses me because it goes 25 you get a good agent. I would have Brad use the 25 upwards, doesn't it, not downwards. We're not responded to it, correct? A Is the top one above that what I responded VIRGINIA GIUFFRE 5/3/2016 73 (289 - 292) Agren Blando Court Reporting & Video, Inc.Page 76 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 293 1 2 3 4 reading chronologically down, are we? Q You can probably look at the dates and figure it out. I need you to do that, not me? A Okay the 30th of the fifth, 31st of the Page 295 1 case. How fantastic, Jenna! Have you asked him how 2 he'd feel about reviving your book? It would be an 3 incredible shame if the other project lifts your 4 story, which it could at least somewhat. Jarred is 5 fifth, 6th of the first. Right. So I still don't 5 still very keen to represent you. I'm afraid I 6 know who she's talking about there. 6 screwed you by steering you to Mimi. 7 Q 8 e-mail? 9 10 11 12 A You don't know if you received this 8 No, I received this e-mail, obviously, but 14 11 responded to, you're talking about -- you used correct? A Much love, Shaza. Yes. 10 Okay. And in the e-mail that you 13 celebrity story. Got to go to Rodeo Drive!!! 9 I don't know who's redacted there. Q I just had a great weekend in LA on a 7 It does concern me what they could want to Q 12 Boies also help you in the book writing department, 13 right? MR. EDWARDS: Object to the form. 14 15 write about me considering tha 16 into VF and threatened them not to write sex 16 A Is the question pending? 17 trafficking articles about his good friend JE. 17 Q (BY MS. MENNINGER) Yes. A She -- yeah, she encouraged me to -- I 18 Q walked So she's encouraging you to have David Right. Does that refresh your memory that 19 when you got this e-mail unredacted 20 included as well as 23 24 25 was ? MR. EDWARDS: Object to the form. 21 22 15 Q (BY MS. MENNINGER) In the line referred to as two of the world's most respected politicians? A It could be. But, again, I would be 18 19 mean, once she saw that, you know, there was more 20 litigation going on, she thought -- like she says, 21 How fantastic. And up until recently she's still 22 been trying to get me to get the book out. 23 24 making an assumption because I don't know who that Mischaracterizes the exhibit. 25 Q And in May of 2015, do you have -- did you have any active agreement to publish your book? A In May of 2015, no. Jarred wanted to do Page 294 Page 296 1 name is. 1 something again, but his only thing was, he wanted 2 Q I don't either. 2 Sharon to be in on it as like a ghostwriter. And I 3 A Okay. 3 said, Look, Sharon is all well and good, but I don't 4 Q Maybe our lawyers can tell us. 4 want a journalist, you know, as they can twist things 5 around writing my story. MS. MENNINGER: All right. Last one, and 5 6 then you can get your break. 8 9 10 Q So he was like, Well, I'm sorry, I don't 6 (Exhibit 25 marked.) 7 (BY MS. MENNINGER) Defendant's Exhibit 25. Again, e-mails to and from yourself and Sharon Churcher, correct? 7 want to work with you then. And I said, Well, that's 8 fine. No problem. 9 10 Q Do you, as you sit here today, have any agreement to publish your story in written form? 11 A Yes. 11 A No, we have no agreement. 12 Q And in this e-mail, it's dated 4/12/2015 12 Q Do you have an agreement for anyone else 13 on the first page of this composite e-mail? 13 to write your story? 14 A Yes. 14 A No. 15 Q She is encouraging you to do a book, 15 Q Have you got any ghostwriter in the book? 16 correct? 16 A 17 A As she has from the beginning, yes. 17 Q Right. And she suggested a roman a clef. 18 a good time for a break. And then -- 19 MR. EDWARDS: Okay. 18 19 Do you know what that means? 20 A No. 20 21 Q On the third page back, she wrote you to 21 Besides Sandra, who I didn't like, no. MS. MENNINGER: All right. I think now is THE VIDEOGRAPHER: We are off the record at 4:12. 22 compliment you about David Boies taking your case, 22 (Recess taken from 4:12 p.m. to 4:22 p.m.) 23 correct? 23 THE VIDEOGRAPHER: We are back on the 24 A (Deponent perused document sotto voce.) 24 Just reading about David Boies taking your 25 25 record at 4:22. Q (BY MS. MENNINGER) When you were VIRGINIA GIUFFRE 5/3/2016 74 (293 - 296) Agren Blando Court Reporting & Video, Inc.Page 77 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 297 Page 299 1 e-mailing and speaking with Sharon Churcher in 2011 1 2 about the Vanity Fair possibly purchasing your 2 3 photograph -- 3 Q Um-hum. A I believe there was a time when she was -- 4 A Um-hum. 4 Q -- do you recall whether you shared with A I believe there was -- and this is just going off my recollection. 5 oh, God, I can't remember. I really can't remember 6 Sharon Churcher anything that you had discussed with 6 and don't want to say anything without looking at 7 your attorney, Mr. Edwards? 7 that exact e-mail. Do you have it to show me? 5 8 9 A In relationship to what? Like, have I 8 identified people to her? 9 Q Well, I'm sure it's probably in there but I don't want to take the time to look for it now. 10 Q Right. 10 A Okay. 11 A Yes. 11 Q So I understand you're just repeating what Q Okay. So you -- you identified people to 12 13 her and you then looped back to her about your 13 14 conversations with Mr. Edwards, correct? 14 12 MR. EDWARDS: Object to the form. 15 16 17 18 19 20 21 22 A 15 I'm sorry, can you rephrase? I don't 17 (BY MS. MENNINGER) All right. So you were e-mailing with her -A Um-hum. Q -- getting her advice about whether or not to sell your A Yes. Q And it may not be accurate because you're not looking at the document. I've got that caveat. What do you recall, just as you're sitting 16 understand. Q you recall from your memory. to Vanity Fair? 18 there? A I know there was e-mails that Sharon sent 19 to me suggesting to say to Brad Edwards, I know that. 20 I don't remember or recall exactly what was in those 21 statements. 22 Q Okay. And did you send those e-mails to 23 A Right. 23 24 Q She asked you to run some information by 24 Mr. Edwards, as you recall today? A I don't know. I'm sorry. 25 Brad -- 25 Q And do you know if you went back to Sharon Page 298 1 2 3 Page 300 A Yes. 1 Churcher and told her about the conversations or Q -- Edwards. And you said that you were 2 e-mails you had with Mr. Edwards? going to do that? 3 A Some of them, I'm sure, yes. Q Because you were in fairly regular contact 4 A Um-hum. 4 5 Q And then you spoke to Mr. Edwards, 5 6 correct? 6 A Right, at that time. 7 A 7 Q All right. I want to introduce to you 8 I don't know if I spoke to him or if I e-mailed him. Okay. And then did you report back to 9 10 Sharon Churcher what you had discussed with 10 11 Mr. Edwards? 11 9 12 Q 8 A I'm not too sure. Like I said, going back 12 with Sharon Churcher at that time, correct? Defendant's Exhibit 26. (Exhibit 26 marked.) Q (BY MS. MENNINGER) Have you seen this document before? A I don't know if I've seen this specific 13 to the 2011 e-mails, look at this pile here. It's 13 document before, but I've seen something close to it, 14 impossible for me to know. 14 I think. 15 Q 15 16 17 18 19 Q So you were having a lot of communications with Sharon Churcher in 2011? 16 All right. Do you see the date on the document? A In 2011, yes. 17 A Q All right. And Mr. Edwards was your 18 Q March 9th? 19 A I see March 10th, sorry. attorney in 2011, correct? March 10th, 2011. 20 A Yes. 20 Q Hmm. 21 Q And did you ever have Sharon Churcher 21 A London, March 10th, 2011. 22 draft for you e-mail to send to Mr. Edwards? 23 A 24 Q 25 22 MR. EDWARDS: Both dates are there. Yes, I believe -- I believe she did. 23 MS. MENNINGER: I'm sure they are. I'm And why did she draft e-mails for you to 24 send to Mr. Edwards? 25 just not seeing the one that you're seeing. THE DEPONENT: Oh, I'm sorry. VIRGINIA GIUFFRE 5/3/2016 75 (297 - 300) Agren Blando Court Reporting & Video, Inc.Page 78 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 301 Page 303 A It doesn't surprise me, but I don't 1 MS. MENNINGER: That's okay. 1 2 THE DEPONENT: Yeah. Sorry about that. 2 remember reading this. I know that, you know, there 3 MS. MENNINGER: Okay. 3 was a lot of stories in press going on and a lot of 4 MR. EDWARDS: One is right on top of the 4 them I decided I just didn't want to read. There was 5 a lot of stuff in there that just, I didn't want to 6 go through. 5 6 7 other. Q (BY MS. MENNINGER) I don't doubt you. I was just looking for it. 7 8 A Okay. 9 Q All right. So after the word London, 10 11 12 13 March 10th, 2011, correct? Q Okay. Were you harmed on March 10th or 8 March 11th, 2011 by the issuance of a statement on 9 behalf of Ghislaine Maxwell? 10 A I am harmed by Ghislaine Maxwell denying A Correct. 11 anything that has ever happened between us, whether Q And above that is a title, Statement on 12 it's in 2002 or 2011 or 2015. I think that she knows 13 what she did, and she should be held accountable for behalf of Ghislaine Maxwell, right? 14 A Yes. 14 them. And not only has she hurt me once, but she's 15 Q By Devonshires Solicitors, PRNE, correct? 15 hurt me apparently twice and now three times. 16 A Correct. 16 17 Q And then Wednesday, March 9th, 2011, 17 18 correct? 18 19 A Correct. 19 20 Q And you understand that March 9th or 20 21 March 10th, 2011 is roughly the time your original 21 22 stories were published in the press -- 22 Q So on March 11th, 2011, say, how were you harmed by the issuance of this press statement? A She's denied that she had any involvement in the procuring of me and other young girls. Q Um-hum. A And she tries to make herself look like she had no partake in it. Q Did you suffer any physical symptoms on 23 A Correct. 23 24 Q -- internationally, correct? 24 March 11th, 2011 after this statement was issued, as 25 A Correct. 25 a consequence of this statement being issued? 1 Q Page 302 And this statement issued by Ghislaine Page 304 1 A Not being able to remember reading this in 2 Maxwell or issued by Devonshires Solicitors on her 2 2011, it's hard to say. But it's the same thing that 3 behalf denied allegations about her that have 3 I'm going through right now. I mean, she's denied it 4 appeared recently in the media, correct? 5 6 7 4 again. And it is painful. It's physically painful. A Correct. 5 I am taking medication to help me deal with this. Q It says, These allegations are all 6 And -- entirely false, correct? Did I read that properly? 8 9 7 A 8 Ghislaine Maxwell denies the various allegations about her -- oh, yeah, right -- yeah, 10 11 right below that. These allegations are entirely 11 12 false. 12 Q All right. In 2011, were you aware that Ghislaine Maxwell issued a statement denying the 14 15 allegations about her that had appeared in the media? 15 16 A MR. EDWARDS: I would just ask that she's I'm not too sure what I recall from 2011 able to finish her answer, though, please. MS. MENNINGER: Well, the answer is nonresponsive, so -MR. EDWARDS: In your opinion it's not 13 14 Okay. I'm just limiting you right now to March of 2011. 9 10 13 Q responsive. Q (BY MS. MENNINGER) I want you to 16 understand that the question is related to any 17 about Ghislaine Maxwell denying it. I know that she 17 physical symptoms you suffered in March of 2011 as a 18 denied it recently in 2015. I know that for a fact. 18 consequence of Defendant's Exhibit 26 being issued. 19 20 21 Q So you don't know whether she denied it in 2011? A 19 20 I can't recall back to 2011, if I do 21 remember that. A If I would have seen this in March 10th, 2011, this would have been harmful to me. Q Okay. Do you recall, as you sit here 22 today, experiencing any physical symptoms as a And you don't know whether she put out a 23 consequence of Defendant's Exhibit 26 being issued to 24 press statement that said these allegations are all 24 the press? 25 entirely false, correct? 25 22 23 Q MR. EDWARDS: Objection. Asked and VIRGINIA GIUFFRE 5/3/2016 76 (301 - 304) Agren Blando Court Reporting & Video, Inc.Page 79 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 305 1 answered. Lacks predicate. A I have been suffering from Ghislaine Page 307 1 can't believe you've been through this. I never 2 knew. I'm so sorry. You know, that kind of stuff. 3 Maxwell and Jeffrey Epstein since the summer of 2000. 3 So they never -- I never spoke to anybody about this 4 So hearing again in 2011 that she's denied it, of 4 except for my husband. 5 course, it's going to hurt me. 5 2 Did I hear about this in 2011? I can't 6 7 tell you I honestly have. In 2015 is when I know that she denied it. 8 9 10 11 And again, I haven't stopped suffering from the Q 7 things to you is when the press picked up on it in 8 2014 or 2015? 10 (BY MS. MENNINGER) And I'm asking you to All right. So the first time you recall any sort of people in your community referencing 9 repercussions that they put me through. Q 6 11 A Yeah, I think it may be end of 2014, early 2015. Q All right. And so in March of 2011 you 12 separate, if you can, any symptoms that you 12 don't recall any neighbors or anybody saying anything 13 experienced anew in March of 2015 -- I mean, excuse 13 to you about this? 14 me, March of 2011, as a consequence of this statement 14 A No, I don't recall. 15 being issued, which I believe you said you don't 15 Q Did anyone tell you in March of 2011 about 16 recall seeing at the time; is that fair? 17 18 19 20 21 22 16 Defendant's Exhibit 26, the statement on behalf of A But you're asking me now about 2015? 17 Ghislaine Maxwell? Q Nope. March of 2011. Sorry, I misspoke 18 A 19 recall it. Q there. A You're still on 2011? 20 Q Yes. Did you start taking any new 21 medications in March of 2011? Let me ask you that. 23 24 22 A No, otherwise I would have been able to Okay. Do you remember anyone in 2011 ridiculing you because of Defendant's Exhibit 26? A Well, because nobody knew me as Virginia, 23 everybody knows me as Jenna, no one probably put two I've been taking medication to control my 24 and two together. And like I told you, I didn't tell since 2002. 25 anybody. So there was nobody there to ridicule me in 25 Page 308 Page 306 1 Q Okay. So did you take any new medications 1 2 or any additional amounts of medications in March of 2 3 2011? 3 4 5 A I have been taking the same medication since 2002. 2011 over this. Q Where were you living in 2011 when Shaza came to see you -- 4 A Oh, 5 Q Do you recall applying for any job in or . 6 Q Okay. 6 around 2011 and someone referencing Defendant's 7 A And that's due to 7 Exhibit 26 and denying you a job? 8 caused from the pain that I suffered at the hands of 9 Ghislaine Maxwell and Jeffrey Epstein. 10 Q 8 9 Did you -- do you recall any neighbors or 10 A I don't -- I don't think I applied for a job in 2011. Q Okay. Did you go see a doctor and talk to 11 other moms at the school or anybody in 2011 11 12 referencing to you in any way the fact that Ghislaine 12 13 Maxwell had issued a denial of the allegations about 13 right here. But I have talked to doctors about my 14 her that had been published in the media in March of 14 abuse at the hands of Ghislaine and Jeffrey. 15 2011? 15 16 A No. I didn't speak to any -- I didn't 16 any doctor about Defendant's Exhibit 26? A Q Not about this. Not about this paper Have you talked to a doctor about any statements in the press made by Ghislaine Maxwell? 17 speak to any moms about what I had gone through. I 17 A 18 mean, when it came out in the press, I don't think 18 Q Which doctor did you speak to about that? 19 any -- like, Australians don't pay attention to news, 19 A Her name is Judith Lightfoot. 20 number one. Recent statements, yes. 20 Q And where is she? 21 Number two, the first time that my friends 21 A She's in Australia. 22 contacted me they were shocked. And this was, I 22 Q Where in Australia? 23 believe in -- when the press picked it up again, I 23 A She's in Sydney, but we do phone 24 think, was 2014/2015. And I got a whole bunch of 24 25 like Facebook texts from them saying, Oh, my God, I 25 conversations. Q Have you ever met her in person? VIRGINIA GIUFFRE 5/3/2016 77 (305 - 308) Agren Blando Court Reporting & Video, Inc.Page 80 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 309 1 A 2 3 4 5 6 7 8 Page 311 Yes. 1 the same. Maxwell strongly denies -- excuse me. Q When? 2 Excuse me -- strongly denies allegations of an A In 2011. 3 unsavory nature, which have appeared in the British Q All right. And is she affiliated with an 4 press and elsewhere and reserves her right to seek office or a hospital or what? 5 redress at the repetition of such old defamatory A She's a psychiatrist. 6 claims. Q All right. Have you seen her in person 7 Q 8 before? since 2011? 9 A I've seen it recently, yes. 10 she's kind of the only person that -- like, I've seen 10 Q All right. What -- have you discussed 11 a lot of doctors. And I can honestly tell you -- 11 this statement with Ms. Lightfoot? I don't know if 12 it's really hard for them to break down the walls and 12 she's a doctor or what. 13 be comfortable enough to talk to them about this 13 A 14 stuff. Judith is different. She's somebody that I 14 Q Is she an MD? 15 feel I can trust. She's 76 and she's just a very 15 A I don't know what her levels of credential 16 lovely lady. 16 9 A No, because I've lived so far away and All right. Have you seen this statement And she offers me other ways to deal with 17 17 18 my pain and suffering. And I continue to see her 18 19 over the phone because I can't see her in person. 19 20 21 Q Do you recall ever discussing with her Defendant's Exhibit 26? 22 A 23 So -- 24 Q I can't recall ever seeing this exhibit. Okay. are. I'm sure she is. Q Okay. When is the first time that you saw the statement? A This full statement I have only seen 20 through discovery. The original statement that I saw 21 in the press was, Ms. Roberts' claims are obvious 22 lies and so on, so forth. I don't remember seeing 23 this in the press. 24 (Exhibit 27 marked.) 25 Psychiatrist, yeah. 25 Q Okay. So the part that you remember seeing in the press is Ms. Roberts' claims are Page 310 1 Q (BY MS. MENNINGER) I'm going to give you Defendant's Exhibit 27. Page 312 1 obvious lies? 2 A Yes. A Yes. 3 Q Anything else about this? 4 Q All right. Have you seen this document 4 A I can't remember what else she printed in 5 before? 2 3 5 the press. It's a very horrible thing for her to do, 6 A Yes. 6 turn around and call me a liar after everything that 7 Q And what do you understand it to be? 7 she knows she's done. And I didn't expect her to 8 A sounds like a PR, if 8 come out and be truthful. 9 10 I'm not right -- if I'm not wrong. Sent -- or Jeffrey Epstein hasn't even issued a 9 subject is Ghislaine Maxwell. I don't know 10 11 12 It says: To whom it may concern, Please statement. Q Sorry. I'm sorry if you misunderstood my question. 13 A Yes. 14 find attached credible statement on behalf of 14 Q Was there anything else within this 15 Ms. Maxwell. 15 statement that you recall seeing in the press besides 16 the line, Ms. Roberts' claims are obvious lies? 13 16 And then it goes on, to hear about that 17 she is saying: Each time the story is retold it 17 18 changes with new salacious details about public 18 the original allegations are not new and have been 19 figures and world leaders and now it is alleged by 19 fully responded to be shown to be untrue. I don't 20 Ms. Roberts that 20 know if that's in the press or not, but I've read 21 having sexual relations with her, which he denies. 21 this before. 22 is involved in Ms. Roberts' claims are obvious lies and 22 A Without saying 100 percent, I think that So I don't know if I'm confusing this with 23 should be treated as such and not publicized as news, 23 what I've read out of this or what I've read in the 24 as they are defamatory. Ghislaine Maxwell's original 24 press. The main thing is, I know she called me a 25 response to the lies and defamatory claims remains 25 liar, and that's what she publicized. VIRGINIA GIUFFRE 5/3/2016 78 (309 - 312) Agren Blando Court Reporting & Video, Inc.Page 81 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 313 1 2 Q And when you say she called you a liar, that's the Ms. Roberts' claims are obvious lies part? Page 315 1 2 a liar from the people that abused me. Q Okay. Do you recall specifically 3 A Yes. 3 mentioning to him Ghislaine Maxwell's statement to 4 Q Okay. When is the first time that you saw 4 the press? 5 6 7 this whole document? A I guess when you guys handed it over for discovery. Okay. And who showed it to you? 9 A It was sent to me by e-mail. 10 Q Okay. Just through the course of 11 A I mentioned a lot of names to him. 6 Q Okay. What new symptoms did you 7 Q 8 5 8 communicating with your attorneys? experience following January 2nd, 2015? A I think it's one thing to be a victim of 9 sexual abuse and survive it and come out trying to 10 tell the world my story, and then another thing for 11 it to be shut down because these people, Ms. Maxwell and others are calling me liars (sic). 12 A Yes. 12 13 Q You've never seen it published? 13 14 A Not this whole e-mail, no. 14 15 Q All right. Did you -- I'm sorry, did you 15 MR. EDWARDS: She's going to finish her 16 discuss this publication of what you saw in the press 16 answer to this question. You cut her off so many 17 with Judith Lightfoot? 17 times. 18 A Yes. 18 19 Q All right. And when did you discuss it 19 20 with her? A Q experienced -- MS. MENNINGER: It has nothing to do with this. MR. EDWARDS: It absolutely does. Because 20 When I got back to Australia, Judith and I And I asked you what symptoms had you 21 this is a psychological damages claim, and she is 22 started seeing each other again. Before then, I 22 trying to explain to you what those damages are. 23 spoke with a doctor in Colorado about this. His name 23 24 is Dr. Olsen. And it was causing me a lot of 24 symptoms that you experienced since January 2nd, 2015 25 distress to have to deal with being called a liar all 25 that are new? 21 Q (BY MS. MENNINGER) Okay. What are your Page 314 Page 316 A Very strong anxiety attacks, bad panic 1 over again, when I know I'm standing up doing the 1 2 right thing. And the doctor prescribed me 2 attacks. My throat closes up, I can't breathe. I 3 vomit when I have anxiety attacks. My -- this is 4 personal, but my sex life has suffered. My marriage 5 has suffered. Psychologically, it's just hurt me all . And, yeah. 3 4 5 Q Okay. So my question was, when did you discuss it with Judith Lightfoot? 6 I think I now understand you did that 6 over again. I mean, they've hurt me before, and now 7 after you returned to Australia in November or so of 7 they've hurt me again by doing this. 8 2015; is that right? 8 9 10 A I returned to Australia in October, and that's when I picked up talking to her again. 9 And I felt like I was in the process of healing before this came out because I had opened up 10 this wonderful charity called Victims Refuse Silence. All right. And you're saying that at 11 And then my aim was to heal by helping other girls 12 another point in time you talked to another doctor, 12 get out of the situations that I was in before. 13 Dr. Olsen, in Colorado, correct? 13 11 Q And my lawyers were nice enough to help 14 A Correct. 14 me. I have this beautiful website where you can 15 Q And when did you meet with Dr. Olsen? 15 click on in any state and you can find a place. I 16 A I don't know the first date that I met 16 have personally called all of them and they will help 17 with him. 17 you get out of the situation that you're in. They 18 Q Did you meet with him more than once? 18 will get you medical help. They will get you legal 19 A I believe so. 19 advice. I think I was in the really good process of Q And you believe you spoke with him about 20 healing. And when this came out, it just ruined me 21 Ghislaine Maxwell's published statement in the press 21 all over again. 22 that Ms. Roberts' claims are obvious lies. 22 20 That's what you believe you spoke with 23 24 25 Dr. Olsen about? A I spoke with Dr. Olsen about being called Q (BY MS. MENNINGER) All right. Tell me 23 all of the damages that you claim occurred to you 24 because of Defendant's Exhibit 27. 25 A My reputation, my psychological abuse, VIRGINIA GIUFFRE 5/3/2016 79 (313 - 316) Agren Blando Court Reporting & Video, Inc.Page 82 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 317 Page 319 1 physical ailments. My marriage has suffered, my 1 2 family life has suffered. I'm constantly battling 2 that's -- that was my voice for other people to get 3 depression. I feel like I've taken 10 steps forward 3 help. And I don't think that people want to get help 4 and 12 steps back since this all happened. 4 from somebody who's being called a liar in the press, 5 somebody who is claiming to be a victim that isn't. 6 I mean, I wouldn't want to get help from somebody who did that, you know. Q 5 6 Okay. And by since this all happened, do you mean since January 2nd, 2015? A Well, number one, my charity. I mean, 7 A That's correct. 7 8 Q All right. Have you lost any income since 8 And I know when I introduce myself to 9 people these days, I don't introduce myself as 9 10 January 2nd, 2015 as a consequence of Defendant's Exhibit 27? A 11 Well, I believe that my charity that was 10 Virginia anymore. I introduce myself as another name 11 because I'm afraid that if people read papers or if 12 going to go forward and help other victims was going 12 people Google or find out who I am that they'll think 13 to not only bring in income but also be able to 13 differently of me. 14 provide women with shelters and food and assistance 14 Q What do you introduce yourself as? 15 that I wanted to help them with. 15 A I tell everybody my name is Jenna. Q In what country or location has your 16 I haven't been able to get a job or work 16 17 or anything like that. You know, financially, my 17 reputation been damaged as a consequence of 18 husband brings home the money for me. But as myself 18 Defendant's Exhibit 27? 19 goes, I couldn't work right now with everything going 19 20 on. 20 I would saying England, America, Australia. You 21 know, friends in Australia were seeing my face on 22 national TV. Like I said, I can't remember if it was 23 2014 or 2015. And I have since not been in contact 24 with those friends. I thanked them for their 25 sympathies, but it's not something I want people to 21 22 23 24 25 Q How much income were you making prior to December 30th, 2014? A Well, I've been a stay-at-home mom since 2006. Q So how much income have you lost as a A Considering this is worldwide publication, Page 320 Page 318 1 2 result of Defendant's Exhibit 27? A 1 I could only imagine, you know, being the know about. You know, especially people close to me. I mean, I want to go out there and I want 2 3 head of a corporation, a charity, I would be earning 3 to help other victims. But being called a liar and 4 a decent wage. It's hard to say how much I would be 4 people having to sit there and second guess if I'm 5 earning because it is a non for-profit. 5 telling the truth or not doesn't really give me much 6 incentive to want to make friends. But because of these statements telling 6 7 everybody in the world that I'm a liar, my charity 7 8 has not been able to take off. And as a consequence 8 9 of that, I have missed out on the results of not 10 11 12 13 being able to go forward with it. Q Okay. Have you applied for any job that you've been denied since January 2nd, 2015? A I haven't been denied a job. I haven't -- Q Did anyone in Penrose, Colorado approach you and mention Ghislaine Maxwell's name? 9 A We have reporters at our door. 10 Q Did anyone in Penrose, Colorado approach 11 12 13 you and mention Ghislaine Maxwell's name? A What, reporters? Yes, plenty of them. Q Did anyone who lives in Penrose, Colorado approach you and mention Ghislaine Maxwell's name? 14 I've just -- I thought about applying for jobs, but I 14 15 mean, the second that you Google my name, people are 15 16 going to know exactly who I am. And these days, 16 it's in the middle of nowhere. So you really -- I 17 employers Google everything, and it makes me fearful 17 didn't have friends in Penrose. There was nobody 18 that if I do go apply for a job, which I would like 18 that I knew there. 19 to. I mean, my kids are all at school now. I'd like 19 20 to get back into the work force. 20 A Q Have you ever been to Penrose? It's -- All right. And which reporters mentioned you and Maxwell's name to you in Penrose, Colorado? A We have reporters chasing us down the 21 But I'm afraid if I do, my past is going 21 22 to stop me from being able to do that. No one wants 22 street, in car parks, taking my kids to the doctor's, 23 to hire a sex slave. 23 going to the grocery store. You know, asking me all 24 kinds of questions about it. And I didn't talk to 25 any journalists or reporters about it. 24 25 Q How has your reputation been harmed by Defendant's Exhibit 27? VIRGINIA GIUFFRE 5/3/2016 80 (317 - 320) Agren Blando Court Reporting & Video, Inc.Page 83 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 321 1 2 3 4 Q And what do you recall any reporter saying to you that included the name Ghislaine Maxwell? A Asking me -- I don't remember what they Page 323 1 Trafficking Coalition sometime after January 2nd, 2 2015? 3 asked me, to be honest. There was regarding 4 5 I did give -- I did go for a speaking engagement. I don't remember when. 5 Ghislaine and 6 mean, it was an array -- you know how reporters can 6 7 be when they're hashing at you. 7 A I can't remember off the top of my head. 8 Q All right. You founded Victims Refuse 8 9 Q and Jeffrey Epstein. I A Okay. So no one in Penrose, Colorado who lived there mentioned Ghislaine Maxwell by name to 9 Q Was there any speaking engagement you had booked that was canceled after January 2nd, 2015? Silence in February of 2014, correct? A It was -- it was a process because, 10 you? 11 A Besides reporters? 11 obviously, you have to go through all the bylaws and Q Right. People who live in Penrose, 12 everything. I think we started it in October of 13 2014, but it wasn't official until January, I think. 12 13 14 15 16 17 10 Colorado. A Right. I didn't know anyone in Penrose, except for my mom. Q Okay. Now, in March or April of 2015 did you fly to New York? 14 Q Okay. So in the period it was in 15 operations before January 2nd, 2015, had you gotten 16 any -- had you been paid any salary by Victims Refuse 17 Silence? 18 A I'm sorry, what date? 18 A No, I hadn't. 19 Q March or April of 2015, did you fly to New 19 Q Had -- 20 A I mean, it was just up and running. So 20 York? 21 A It's a possibility. 21 22 Q Did you stay at the Ritz-Carlton? 22 23 A It's definitely a possibility. 23 24 Q Were you there with Mr. Edwards and 24 25 Mr. Cassell and Sigrid McCawley? 25 there was no -Q Had any contributions been made to Victims Refuse Silence before January 2nd, 2015? A I can't recall. You know, we've only had a few contributions. I don't know what dates they Page 322 1 A I've been to New York quite a few times. Page 324 1 2 So I'd have to refresh my memory. But I have been to 2 3 New York with Brad Edwards and Paul Cassell and 3 4 Sigrid McCawley. were put in. Q Has anyone else called you a liar in the press? 4 A Yes. Q Was that after January 2nd, 2015? 5 Q Who? 6 A Definitely could be. 6 A 7 Q Did you give an interview to ABC News on 7 Q Anyone else? 8 camera? 8 A Ghislaine Maxwell, obviously. 5 . 9 A I did. 9 Q Anyone else? 10 Q And that was after January 2nd, 2015? 10 A Not that I know of. 11 A I did. 11 Q Has anyone else publicly denied your 12 Q Did you give an interview to Good Morning 12 13 14 15 America? 13 A From what Ghislaine Maxwell said? A No. 14 Q Have you seen any press in which another Q All right. Did you correspond at all with 15 16 Good Morning America about the publication of your 16 17 story? 17 18 allegations? A I can't remember if ABC and Good Morning 18 person has denied your allegations? MR. EDWARDS: Objection. Vague. A I've seen allegations denied by Ms. Maxwell. And I've seen the allegations denied by 19 America wanted to do something together. I can't -- 19 20 all I know is I was interviewed by one person at ABC. 20 21 I never was interviewed by anyone from Good Morning 21 actually went on TV and called you a serial liar, 22 America. Maybe they were going to show the same 22 correct? 23 airing in the same show, but powers that be, of 23 A Very correct. 24 course, wouldn't let it go forward. 24 Q You saw that, correct? 25 A Yes. 25 Q Did you give a lecture to the Human . Q (BY MS. MENNINGER) And VIRGINIA GIUFFRE 5/3/2016 81 (321 - 324) Agren Blando Court Reporting & Video, Inc.Page 84 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 325 Page 327 Q And that hurt your feelings? 1 2 A Badly. 2 3 Q 1 question. 4 A 9 A 10 Q don't understand. Can you rephrase it for me -(BY MS. MENNINGER) All right. 7 A -- so I can understand what you mean? 8 Q Where you live in Australia now, has 9 (BY MS. MENNINGER) How do you know which Can I point to a person -- I'm sorry. I Q 6 MR. EDWARDS: Form. MR. EDWARDS: Object to the form of the 3 5 8 context? 10 anyone referenced the name Ghislaine Maxwell to you? A After all of the news hits, after the 11 harm you've suffered is attributable to Ghislaine 11 press hits in 2015 and, you know, everyone is calling 12 Maxwell's denial versus 12 me a liar, all of my friends in Australia called me 13 and talked to me and said, I can't believe this. I 14 can't believe what you went through. 14 A Ghislaine Maxwell brought me into the sex That was very embarrassing for something 15 trafficking industry. She's the one who abused me on 15 16 a regular basis. She's the one that procured me, 16 that I tried to keep separate from my other life 17 told me what to do, trained me as a sex slave, abused 17 where I would like to help victims. I didn't want 18 me physically, abused me mentally. 18 the friends of my kids parents knowing about that 19 stuff. You know, and of course they all felt sorry She's the one who I believe, in my heart 19 20 of hearts, deserves to come forward and have justice 20 for me. And you know, like I said. I didn't know 21 happen to her more than anybody. Being a woman, it's 21 anybody in Penrose. So there's nobody that could 22 disgusting. 22 have come up to me and talked to me about it. My 23 mom. 23 Q So you cannot delineate what harm you have 24 suffered in terms of all of the psychological damage 24 Q This question was about Australia, sorry. 25 you just disclosed? 25 A Oh, sorry, I thought you were talking Page 326 Page 328 about pointing out people. 1 A Oh, of course. 1 2 Q -- if that is attributable to Ghislaine 2 Q No. 3 A Okay, well in Australia, yes, at least a 3 Maxwell's statement on January 2nd versus calling you a serial liar on Good Morning 4 5 6 America? A 4 5 Of course, it all hurts. Okay? I 6 7 Of course those hurt. It 9 doesn't feel good to have people who have done Q They came up and they mentioned Ghislaine Maxwell's denial to the press to you? A They couldn't believe what I had been 8 through and, you know, that these were, you know, 9 being denied, and they felt sorry for me. And, you 10 something to you deny something that's happened, when 10 11 I'm actually brave enough to come forward and talk 11 12 about it. 12 What hurts me the worst is that Ghislaine dozen friends. know, it was the whole circumference of things. Q So the people in Australia that came up to you had sympathy for you and believed you, correct? 13 A Yes. 14 Maxwell brought me into this. Not only has she hurt 14 Q All right. And when you spoke to 15 me once, but she's hurt me twice coming forward and 15 Dr. Olsen you recall specifically mentioning 16 saying, This is not true, this is categorically 16 Ghislaine Maxwell's press release? 17 untrue and obvious lies. 17 13 That to me is a stick in the mud and that 18 19 to me is what caused the most harm to me. 18 MR. EDWARDS: Object to the form. A Yes, I remember mentioning her, as well as 19 the press release, as well as other press releases. 20 And the abuse that I had occurred (sic) from the 21 who has referenced Ghislaine Maxwell's denial in the 21 hands of Jeffrey and Ghislaine. 22 press or to your face or anywhere? 22 20 23 24 25 Q Okay. And so can you point to any person A Can I point to a person? 23 Q Can you point to any time that someone has 24 referenced Ghislaine Maxwell's denial to you in any 25 Q (BY MS. MENNINGER) Okay. When have you been diagnosed with a mental health condition, first? A I don't know. I mean, I've been told that I've VIRGINIA GIUFFRE 5/3/2016 . You know -- 82 (325 - 328) Agren Blando Court Reporting & Video, Inc.Page 85 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 331 Page 329 1 2 3 Q When were you first told that? 1 just got to Australia and Judith Lightfoot was A Well, early in -- early in 2003, I believe 2 helping me. is the first time that I was suffering from 5 And I told him the reason. And then my doctor, Judith 4 Lightfoot, has in 2011 5 6 6 And, you know, I've recently seen another 7 8 doctor who said that I've got the exact same symptoms 9 that Judith Lightfoot mentioned, which is . And this is since you returned to 7 A Correct. 8 Q And this is the first time you had seen 9 10 Q Australia? that doctor? 10 A I've seen that doctor twice now. 11 Q I'm sorry, what was the name again? I 12 Q Which doctor is that? 12 13 A You know, I don't honestly know his name. 13 A 14 Q When did you see this new doctor? 14 Q 15 A Um -- 15 know you already said it, but I just -Dr. Donahue. Donahue, all right. This doctor that you haven't yet 16 MR. EDWARDS: Sorry. If you're referring 16 disclosed, where did you see that person? In what 17 to a doctor that's been sent to you by one of your 17 country? 18 lawyers -- 18 A United States. 19 THE DEPONENT: Yes. 19 Q And in what state? 20 MR. EDWARDS: -- at this time, I'm 20 A San Francisco. 21 21 Q And when did you see that doctor? THE DEPONENT: Okay. 22 A Um, Friday. Last Friday. MS. MENNINGER: Wait. What is it? You've And how many times have you seen that instructing you not to answer. 22 23 Q 24 seen a doctor and you're not going to answer what 24 doctor? 25 doctor you've seen? 25 A 23 Once. Well, twice actually. I saw him Page 330 MR. EDWARDS: Sure. If it's a consulting 1 Page 332 1 2 witness in this case that has seen her at the 2 3 direction of an attorney, that has not yet been 3 4 disclosed per any expert witness disclosure, then I'm 4 5 instructing her not to answer that question. 5 If that's what you're referring to. I 6 7 don't know if that's what you're referring to. THE DEPONENT: That's what I'm referring 8 9 10 to. (BY MS. MENNINGER) All right. So you Q All right. Did you suffer from anxiety before meeting Jeffrey Epstein? A I was never prescribed anything for anxiety before I met Jeffrey Epstein. 6 Q That wasn't my question. 7 A Did I -- 8 Q Were you suffering from anxiety before you 9 Q the next day, too. 10 met Jeffrey Epstein? A I think a person who has gone through as 11 recall seeing Dr. Lightfoot. You recall seeing 11 much trauma as I have in my life would suffer from 12 Dr. Olsen. And you recall seeing a new unnamed 12 quite a few problems. But like I said, I was never 13 doctor recently. 13 prescribed anything until I met Jeffrey Epstein. Anyone else you've seen since January 2nd, 14 15 16 17 2015? A 14 15 Dr. Olsen, Dr. Lightfoot. Oh, Dr. Donahue. Q Did you suffer from panic attacks before meeting Jeffrey Epstein? 16 A Nowhere near as bad, no. 17 Q So you did suffer from . 18 Q Where is Dr. Donahue located? 18 They just weren't as severe; is that what your 19 A He's in my suburb or he's a suburb next to 19 testimony is? 20 21 me in Australia. Q 20 And is that a psychiatric-type doctor, a 21 A No, what I'm trying to say is I did have I did have I had lived a very 22 hard life prior to meeting Jeffrey Epstein as well. 23 A He's medical. 23 After meeting Jeffrey Epstein and 24 Q And what did you see him for or her for? 24 Ghislaine Maxwell, everything escalated. That's when 25 A I didn't have anybody to basically -- I 25 I started to take Xanax and smoke marijuana to help 22 medical-type doctor? VIRGINIA GIUFFRE 5/3/2016 83 (329 - 332) Agren Blando Court Reporting & Video, Inc.Page 86 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 335 Page 333 1 2 3 4 5 6 calm the anxiety and everything down. Q 1 Before you met Jeffrey Epstein, had you used any drugs? 2 Q How much does it cost you every time you talk to Dr. Lightfoot? 3 A Her normal fee is $200. Q And how much do you pay? A Sure, yes. 4 Q Which drugs had you used prior to meeting 5 A She doesn't charge me anything anymore. 6 Q When did she stop charging you? Jeffrey Epstein? 7 A I smoked pot. I've taken Ecstasy. 7 A Since I got back to Australia. 8 Q Cocaine? 8 Q So before you left for Titusville, A Yeah, I would have snorted cocaine, 9 9 Florida, you saw her and you were paying $200 per 10 um-hum. 10 session? 11 Q 11 A Yes. Q And what has Dr. Lightfoot recommended 12 13 Did you ever abuse alcohol before meeting Jeffrey Epstein? A 12 No, I was -- I wasn't even of age to be 13 that you do in order to get better? 14 able to buy it. I mean, if there was alcohol at 14 15 parties I would have drank it, but I wouldn't say I 15 out. She thinks the more that I speak out about it, 16 abused it. A She loves what I'm doing with speaking 16 the stronger I'll become. She recommends that I Okay. Were there ever occasions upon 17 write my book, I tell my story. She thinks not only 18 which you were observed to be drunk by other people, 18 will it help me, but by helping me it'll help others 19 prior to meeting Jeffrey Epstein? 19 find a way to get out of the situation and to know 20 that there's other girls who have gone through what I've gone through and what they're going through. 17 20 Q A If you're drinking, the possibility of 21 getting drunk is always there. I don't -- I can't 21 22 recall exact situation where that was the case, 22 23 but -- 23 24 25 Q Were you diagnosed as a drug addict prior to meeting Jeffrey Epstein? She recommends meditation, breathing techniques, focus techniques. 24 Q Does she prescribe medications for you? 25 A No, she doesn't. She's a spiritual Page 334 1 2 3 Page 336 A No, I was not diagnosed as a drug addict. 1 Q Were you sent to live at a rehabilitation 2 facility because of your use of drugs? No, that was more of a group home. Yes, 4 5 it was also a rehab facility, but it wasn't because I 5 6 was a drug addict. I wasn't coming off of anything. 6 4 7 8 9 10 A 3 Q Had you abused drugs prior to meeting Jeffrey Epstein? A I took drugs. I didn't abuse them, but I took them. Okay. 11 Recreationally. 12 13 Q How often do you see Dr. Lightfoot? 13 14 A Once a week every Monday. I've skipped FaceTime, but -- 18 19 20 Q Q That's okay. Is there anything that Are you following her advice? 9 A expensive to call back home right now, unless you Is there anything that I do that she are not actually doing? Q 17 A recommends I don't? Sorry, say that one more time. 8 12 this week because I've been over here and it's Is there anything that she's recommended Dr. Lightfoot has recommended that you do that you 11 16 Q that you do that you're not doing? 7 10 15 doctor. A Yes, I am. Q Okay. And what has Dr. Donahue recommended that you do? Has Dr. Lightfoot recommended that you see a treating doctor in person? A No, she's -- she knows my history pretty 21 well. And she's a very wonderful woman and I 22 honestly wouldn't -- Dr. Donahue wants me to go see 23 another psychiatrist in person, but I prefer to stay 24 with Judith because she's someone I can personally 25 relate to. VIRGINIA GIUFFRE 5/3/2016 84 (333 - 336) Agren Blando Court Reporting & Video, Inc.Page 87 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 339 Page 337 1 1 15 Q All right. MS. MENNINGER: I'm going to ask that we 16 17 take just a brief break and that I can hopefully then 18 come back and just ask a few final follow-up 19 questions, okay? THE DEPONENT: Okay. 20 THE VIDEOGRAPHER: We are off the record 21 22 at 5:16. 23 (Recess taken from 5:16 p.m. to 5:25 p.m.) 24 THE VIDEOGRAPHER: We're back on the 25 record at 5:25. Page 338 1 Page 340 1 Q 8 22 VIRGINIA GIUFFRE 5/3/2016 85 (337 - 340) Agren Blando Court Reporting & Video, Inc.Page 88 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 341 Page 343 1 Q When was it? 1 2 A I don't know the exact date. 2 3 Q What's your best recollection? 3 4 A I don't know. I would have to have dates 4 5 in front of me. If you've got something that has a 5 6 date on there, I'm happy to look at it and tell you 6 7 it's right or wrong. 7 8 Q 9 ago? 10 A 11 It was a few months ago or many months read it. MS. MENNINGER: We're going off the record. MR. EDWARDS: Yeah, that's fine. She'll read. THE VIDEOGRAPHER: That concludes today's proceedings. We're off the record at 5:28. (Proceedings concluded at 5:28 p.m.) 8 9 Um, to my best recollection, it was about a year ago. ******* 10 11 12 MS. MENNINGER: I have no further 12 13 questions for you at this time. As you know, there 13 14 are some questions that you refused to answer and 14 15 other questions that your attorney directed you not 15 16 to answer. So we will take those up with the Court 16 17 and may see you again. 17 18 THE DEPONENT: Okay. 18 19 MR. EDWARDS: And just as a matter of 19 20 clarification, I don't believe that there's anything 20 21 she's refused to answer. There may be things that 21 22 I've instructed her not to answer because I believe 22 23 that they were privileged or for whatever reason I 23 24 instructed her not to answer but she hasn't refused 24 25 to answer them. 25 Page 342 Page 344 Either way, the record is what it is. 1 2 MS. MENNINGER: I was going to say, do you 2 I have read the foregoing transcript and that the 3 dispute that the court reporter has been taking down 3 same and accompanying amendment sheets, if any, 4 what was said this entire time? 1 5 6 4 constitute a true and complete record of my MR. EDWARDS: I'll read it. She'll read. 5 testimony. MS. MENNINGER: Actually, that's a good 6 7 question. 7 8 Q 8 9 10 11 (BY MS. MENNINGER) Do you have any questions that I've asked you today that you don't feel like you understood? A I, VIRGINIA GIUFFRE, do hereby certify that ________________________________ Signature of Deponent ( ) No Amendments ( ) Amendments Attached 9 10 No, I don't think that there's questions Acknowledged before me this 11 12 that you've asked me that I don't think I've 12 13 understood. But, you know, I really just want to 13 14 state something for my own piece of mind, if that's 14 Notary Public: ________________________ 15 okay, if I'm allowed to do that. 15 Address: _____________________________ 16 17 Q No, that's not really what this forum is about. 17 My commission expires _________________ Seal: A Okay. 18 19 Q There are other forums. 19 MR. EDWARDS: That will only be good for 20 21 them. There is no reason to say that. 21 22 THE DEPONENT: Okay. 22 23 MR. EDWARDS: You get a chance to talk 23 24 25 later. _____________________________ 16 18 20 _____ day of ______________, 2016. KAM 24 Do you have an order form? And she'll 25 VIRGINIA GIUFFRE 5/3/2016 86 (341 - 344) Agren Blando Court Reporting & Video, Inc.Page 89 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 345 1 2 3 4 STATE OF COLORADO) ) ss. Page 347 1 REPORTER'S CERTIFICATE 2 COUNTY OF DENVER ) 3 I, Kelly A. Mackereth, do hereby certify 4 5 that I am a Registered Professional Reporter and 5 6 Notary Public within the State of Colorado; that 6 7 previous to the commencement of the examination, the 7 8 deponent was duly sworn to testify to the truth. 8 9 I further certify that this deposition was 9 10 taken in shorthand by me at the time and place herein 10 11 set forth, that it was thereafter reduced to 11 12 typewritten form, and that the foregoing constitutes 12 13 a true and correct transcript. 13 14 I further certify that I am not related to, 14 15 employed by, nor of counsel for any of the parties or 15 16 attorneys herein, nor otherwise interested in the 16 17 result of the within action. 17 18 19 20 In witness whereof, I have affixed my 18 signature this 11th day of May, 2016. 23 VIRGINIA GIUFFRE May 3, 2016 Giuffre v. Maxwell Case No. 15-cv-07433-RWS The original videotaped deposition was filed with Laura A. Menninger, Esq., on approximately the 11th day of May, 2016. _____ Signature waived. _____ Unsigned; signed signature page and amendment sheets, if any, to be filed at trial. _____ Reading and signing not requested pursuant to C.R.C.P. Rule 30(e). _XXX_ Unsigned; amendment sheets and/or signature pages should be forwarded to Agren Blando to be filed in the envelope attached to the sealed original. 19 My commission expires April 21, 2019. 20 21 22 AGREN BLANDO COURT REPORTING & VIDEO, INC. 216 - 16th Street, Suite 600 Denver, Colorado 80202 4450 Arapahoe Avenue, Suite 100 Boulder, Colorado 80303 ____________________________ Kelly A. Mackereth, CRR, RPR, CSR 216 - 16th Street, Suite 600 Denver, Colorado 80202 21 Thank you. 22 AGREN BLANDO COURT REPORTING & VIDEO, INC. 23 cc: All Counsel 24 24 25 25 Page 346 3 AGREN BLANDO COURT REPORTING & VIDEO, INC. 216 - 16th Street, Suite 600 Denver, Colorado 80202 4450 Arapahoe Avenue, Suite 100 Boulder, Colorado 80303 4 May 11, 2016 5 Sigrid S. McCawley, Esq. BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard Suite 1200 Fort Lauderdale, FL 33301-2211 1 2 6 7 - AMENDMENT SHEET Videotaped Deposition of VIRGINIA GIUFFRE May 3, 2016 Giuffre v. Maxwell Case No. 15-cv-07433-RWS The deponent wishes to make the following changes in the testimony as originally given: Page Line Should Read Reason ____ ____ ______________________________ ______ Re: Videotaped Deposition of VIRGINIA GIUFFRE Giuffre v. Maxwell Case No. 15-cv-07433-RWS ____ ____ ______________________________ ______ The aforementioned deposition is ready for reading and signing. Please attend to this matter by following BOTH of the items indicated below: ____ ____ ______________________________ ______ _____ Call 303-296-0017 and arrange with us to read and sign the deposition in our office. ____ ____ ______________________________ ______ _XXX_ Have the deponent read your copy and sign the signature page and amendment sheets, if applicable; the signature page is attached. ____ ____ ______________________________ ______ ____ ____ ______________________________ ______ 17 _____ Read the enclosed copy of the deposition and sign the signature page and amendment sheets, if applicable; the signature page is attached. 18 _XXX_ WITHIN 30 DAYS OF THE DATE OF THIS LETTER 19 _____ By ______ due to a trial date of _______ 20 Please be sure the original signature page and amendment sheets, if any, are SIGNED BEFORE A NOTARY PUBLIC and returned to Agren Blando for filing with the original deposition. A copy of these changes should also be forwarded to counsel of record. Thank you. 8 9 10 11 12 13 14 15 16 21 22 23 AGREN BLANDO COURT REPORTING & VIDEO, INC. 24 25 cc: All Counsel ____ ____ ______________________________ ______ ____ ____ ______________________________ ______ ____ ____ ______________________________ ______ ____ ____ ______________________________ ______ ____ ____ ______________________________ ______ ____ ____ ______________________________ ______ ____ ____ ______________________________ ______ Signature of Deponent: ____________________ Acknowledged before me this ____ day of ______________, 2016. Notary's signature ________________ (seal) My commission expires ____________. VIRGINIA GIUFFRE 5/3/2016 87 (345 - 348)