Case 1:15-cv-07433-LAP Document 1320 Filed 01/03/24 Page 1 of 1 BOIES SCHILLER es FLEXNER January 3, 2024 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Pursuant to the Court’s December 18, 2023, unsealing order, and following conferral with Defendant, Plaintiff files this set of documents ordered unsealed. The filing of these documents ordered unsealed will be done on a rolling basis until completed. This filing also excludes documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with Chambers), 107, and 110 (see ECF No. 1319), while the Court’s review of those documents is ongoing. Respectfully, /s/ Sigrid S. McCawley Sigrid S. McCawley cc: Counsel of Record (via ECF) BOIES SCHILLER FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200. Fort Lauderdale, FL 33301 | (t) 954 356 0011 | (f) 954 356 0022 | www.bsfilp.com Case 1:15-cv-07433-LAP Document 1320-1 Filed 01/03/24 Page 1 of 2 EXHIBIT 4 Case 1:15-cv-07433-LAP Document 1320-1 Filed 01/03/24 Page 2 of 2 From: gmax1@ellmax.com Sent: Saturday, January 10, 2015 9:00 AM To: Philip Barden; Ross Gow | am out of my depth to understanding defamation and other legal hazards and don't want to end up ina law suit aimed at me from anyone if | can help it. Apparently even saying Virginia is a lier has hazard! | have never been in a suit criminal or civil and want it to stay that way. The US lawyers for the Jane Does are filling additional discovery motions and if | speak | open my self to being part of discovery apparently. | am trying to stay out of litigation and not have to employ lawyers for years as | get lost in US legal nightmare. | stand no legal risk currently on these old charges and civil suits against Jeffrey We need to consult with US lawyers on any statement | make and the complaints too Perhaps we make a statement of the legal risk of saying anything for potential defamation or something that prevents a full and frank detailed rebuttal + the press not being the place for that? Regardless, Philip plse call jeffrey lawyer and see what you can understand from him and pehaps craft something in conjunction with him? Either way | think you need to speak to him to understand my risk so you can help me understand it - too may cooks in the kitchen and | can't make good decisions. Plse reach out to him today + | have already suffered such a terrible and painful loss over the last few days that | can't even see what life after press he'll even looks like - statements that don't address all just lead to more questions..what is my relationship to clinton ? Andrew on and on. Let's rest till monday. | need head space THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INSTAGRAM PLEDGE THE DAILY CATCH PRIVILEGED GM_001044 CONFIDENTIALCase 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 1 of 10 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: [5-cv-07433-RWS ¥; Ghislaine Maxwell, Defendant, PLAINTIFE’S MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition, Defendant refused to answer numerous questions about allegedly “adult” sexual activity related to Jeffrey Epstein. Because this activity is highly relevant to this case, Defendant should be ordered to answer questions about it. As the Court is aware, this defamation case involves Ms. Giuflre’s assertions that she and other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the guise of being “massage therapists.” See Complaint. (DE 1), at § 27 (Giuftre “described Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”). In response to these assertions, Defendant has made the sweeping claim that Ms. Giuffre’s assertions are “entirely false” and “entirely untrue.” Complaint, DE 1, at § 31. ' Defendant has labelled her entire deposition transcript as Confidential at this time. Counsel for the parties conferred at the deposition regarding answering questions.Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 2 of 10 Yet during her deposition, Defendant refused to answer any questions that she construed as having something to do with “consensual adult sex.” Defense counsel supported that position that “frankly, [that’s] none of your business and I instruct the witness not to answer.” See Declaration of Sigrid S. McCawley (“McCawley Decl.”) at Exhibit 1, Tr. of Maxwell Depo. (Apr. 22, 2016) at 21. The result was that at a number of points throughout her deposition, Defendant refused to answer questions about subjects integral to this lawsuit, including questions about what the alleged “massage therapists” were doing at Jeffrey Epstein’s house and the sexual nature of those massages. For example, Defendant refused to answer questions about whether she had given Jeffrey Epstein a massage: Q. Have you ever given Jeffrey Epstein a massage? MR. PAGLIUCA: Object to the form, foundation, And I'm going to instruct you not to answer that question. 1 don't have any problem with you asking questions about what the subject matter of this lawsuit is, which would be, as you've termed it, sexual trafficking of Ms. Roberts. To the extent you are asking for information relating to any consensual adult interaction between my client and Mr. Epstein, /'m going to instruct her not (o answer because it's not part of this litigation and it is her private confidential information, not subject to this deposition, MS, MeCAWLEY: You can instruct her not to answer, That is your right. But | will bring her back for another deposition because it is part of the subject matter of this litigation so she should be answering these questions. This is civil litigation. deposition and she should be responsible for answering these questions. MR. PAGLIUCA; I disagree and you understand the bounds that I put on MS. McCAWLEY: No, I don't. | will continue to ask my questions and you can continue to make your objections, Q. Did you ever participate from the time period of 1992 to 2009, did you ever participate in a massage with Jeffrey Epstein and another female? MR. PAGLIUCA: Objection. Do not answer that question, Again, to the extent you are asking for some sort of illegal activity as you've construed in 2Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 3 of 10 connection with this case | don't have any problem with you asking that question. To the extent these questions involve consensual acts between adults, frankly, they're none of your business and J will instruct the witness not to answer MS. McCAWLEY: This case involves sexual trafficking, sexual abuse, questions about her having interactions with other females is relevant to this case. She needs to answer these questions. MR. PAGLIUCA: I'm instructing her not to answer, MS. McCAWLEY: Then we will be back here again. See McCawley Decl. at Exhibit 2, Tr. of Maxwell Depo. (Apr. 22, 2016) at 19-22 (emphasis added), Defendant’s participation in massages with Epstein is a central part of this case. Ms. Giuffre has explained that during her first sexual encounter with Jeffrey Epstein, it was Defendant who provided instruction on how to do it and how to turn the massage into a sexual event. Obviously, proof that Defendant had previously massaged Epstein — include massages with sexual component — would provide important corroboration for Ms. Giuffre’s testimony at trial, And proof that Defendant was involved in massages will further help prove that statements to the press that Virginia’s allegations were “obvious lies” was itself an obvious lie. As another example, Defendant refused to answer questions about her knowledge that Johanna Sjoberg was hired to work for Epstein and provided massages. In the police report, Johanna admitted that Maxwell recruited her to work for Epstein. See McCawlevy Decl, at Exhibit 3, Giuffre000076-77 (police report indicating that Johanna was recruited by Maxwell). Yet during Defendant's deposition, she refused to answer questions regarding Johanna Sjoberg, Q, Do you know what tasks Johanna was hired to performance? A. She was tasked to answer telephones. Q. Did you ever ask her to rub Jeffrey's feet? .. . A. | believe that I have read that, but I don't have any memory of it.Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 4 of 10 Q. Did you ever tell Johanna that she would get extra money if she provided Jeffrey massages? A. I was always happy to give career advice to people and | think that becoming somebody in the healthcare profession. cither exercise instructor or nutritionist or professional massage therapist is an excellent job opportunity, Hourly wages are around 7, 8, $9 and as a professional healthcare provider you can earn somewhere between as we have established 100 to $200 and to be able to travel and have a job that pays that is a wonderful job opportunity. So in the context of advising people for opportunities for work, it is possible that | would have said that she should explore that as an option. Q. Did you tell her she would get extra money if she massaged Jeffrey? A. I'm just saying, | cannot recall the exact conversation. I give career advice and [ have done that. Q. Did you ever have Johanna massage you? A. | did. Q. How many times? A. | don't recall how many times. Q. Was there sex involved? A.No.... Q, Did you ever have sexual contact with Johanna? MR. PAGLIUCA: Object to the form and foundation. You need to give me an opportunity to get in between the questions. Anything that involves consensual sex on your part, I'm instructing you not to answer. Q. Did you ever have sexual contact with Johanna? A. [MR. PAGLIUCA?] Again, she is an adult -- Q. I’m asking you, did you ever have sexual contact with Johanna? A. I've just been instructed not to answer. Q. On what basis? A. You have to ask my lawyer. See McCawley Decl. at Exhibit 4, Tr. of Maxwell Depo. (Apr. 22, 2016) at 60-62 (emphasis added).Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 5 of 10 Here again, this information is critical to the case. Among other things, these questions are designed to show a modus operant (“M.O”) for Epstein and Maxwell — specifically, how they recruited for a non-sexual massage than converted the massage into sexual activities. One last illustration comes from Defendant's refusal to answer about her knowledge of Epstein’s sexual interests during massages: Q. Does Jeffrey like to have his nipples pinched during sexual encounters? MR. PAGLIUCA: Objection to form and foundation, A. I'm not referring to any advice on my counsel. J]'m not talking about any adult sexual things when | was with him. Q. When Jeffrey would have a massage, would he request that the masseuse pinch his nipples while he was having a massage? A. I'm not talking about anything with consensual adult situation, See McCawley Decl, at Exhibit 5, Tr. of Maxwell Depo, (Apr, 22, 2016) at 82. While Epstein himself might also provide answers to these questions, it appears likely that he will assert his Fifth Amendment privilege regarding his sexual activities. Accordingly, Ms. Giuffre must pursue questioning of Maxwell to obtain information on this subject. Here again, information about Epstein’s sexual idiosyncrasies will provide important corroboration to Ms. Giuffre’s testimony that she had sexual interactions of an identical nature with Epstein. These refusals are not an isolated instance. Instead, similar refusals to answer questions occurred repeatedly throughout the deposition. See, e.g., McCawley Decl. at Composite Exhibit 6. 52-55; 64-65; 82; 92-93; 137-38; 307-09, The Court should compel Defendant to answer all these questions, In addition to the specific points made above, the “big picture” here reveals how vital such discovery is. At the core of Ms. Giuffre’s allegations is the allegation that Defendant lured her into a sexual situation with the offer of a job making money as a massage therapist; that Epstein always habitually triedCase 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 6 of 10 to turn massages into sex (that was his modus operandi and plan all along); and that Maxwell recruited other females for an ostensibly proper position, such as therapeutic masseuse, with knowledge that the intent was for that person would be pressured to provide sexual gratification to Epstein. As a result, Epstein’s use of massages for sexual purposes is a central part of this case. And Defendant’s role in those massages — and knowledge of the purposes of those massages — is a critical piece of evidence showing her state of mind when she attacked Ms. Giuffre’s assertions as “entirely untrue.” Ms. Giuffre intends to prove at trial that Defendant knew full well the sexual purpose for which she was recruiting females — including underage females like Ms. Giuffre. Ms. Giuffre is entitled to explore Defendant’s knowledge of the sexual activities that took place under the guise of “massages.” Otherwise Defendant will be able to portray to the jury an inaccurate picture of that what was happening at Epstein’s house what nothing more than run-of-the-mill massage therapy. See, e.g, McCawley Decl. at Exhibit 7, Tr. of Maxwell Depo. (Apr. 22, 2016) at 51 (“Q: Did [the pay for massage therapists] vary on what sexual acts they performed? ... A: No, it varied depending on how much time, some massage therapists charge more and some charge less.”). Defendant’s refusal to answer questions about alleged “adult” consensual sex also blocks Ms. Giuffre from seeking legitimate discovery in this case. By refusing to answer questions about her and Epstein’s sexual activities with alleged “adults,” Defendant is essentially given the ability to refuse to answer any sexual question she does not wish to answer. Defendant simply has to deem the question as involving “consensual adult sex” and no need be given. The result is to leave Ms. Giuffre with no way of exploring the identity of these alleged adults, the ages of these alleged adults, and indeed whether they were adults at all. This allows Defendant to claimCase 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 7 of 10 that she is unaware of any sexual activity involving underage females, because (she claims) the only sexual activity she was aware involved adults. The Court should compel Ms. Maxwell to answer all questions about her knowledge relating to sexual activities with Epstein and other females while at Epstein’s various homes. See Fed. R. Crim. P. 37(a)(3)(B)(i); see, e.g., Kelly v. Al Tech., No. 09 CIV. 962 LAK MHD, 2010 WL 1541585, at *20 (S.D.N.Y. Apr. 12, 2010) (‘Under the Federal Rules, when a party refuses to answer a question during a deposition, the questioning party may subsequently move to compel disclosure of the testimony that it sought. The court must determine the propriety of the deponent's objection to answering the questions, and can order the deponent to provide improperly withheld answers during a continued deposition” (internal citations omitted)). Of course, the party objecting to discovery must carry the burden of proving the validity of its objections, particularly in light of “the broad and liberal construction afforded the federal discovery rules....” John Wiley & Sons, Inc. v. Book Dog Books, LLC, 298 F.R.D. 184, 186 (S.D.N.Y. 2014). For purposes of a deposition, the information sought “need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence.” Chen-Oster v. Goldman, Sachs & Co., 293 F.R.D. 557, 561 (S.D.N.Y. 2013) (citing Fed.R.Civ.P. 26(b)(1)). Defendant cannot carry her burden of showing that the questions asked are not reasonably calculated to lead to the discovery of admissible evidence. This is a case in which sexual activities lie at the heart of the issues in dispute. As a result, it is hardly surprising to find that discovery pertains to alleged “adult” sexual activities — and questions about such subjects are entirely proper. See, e.g., Condit v. Dunne, 225 F.R.D, 100, 113 (S.D.N.Y. 2004) (in defamation case, “Plaintiff is hereby ordered to answer questions regarding his sexual relationships in so farCase 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 8 of 10 as they are relevant to a defense of substantial truth, mitigation of damages, or impeachment of plaintiff.”); Weber v. Multimedia Enim't, Inc., No. 97 CIV. 0682 PKL THK, 1997 WL 729039, at *3 (S.D.N.Y. Nov. 24, 1997) (“While discovery is not unlimited and may not unnecessarily intrude into private matters, in the instant case inquiry into private matters is clearly relevant to the subject matter of the suit. Accordingly, plaintiff Misty Weber shall respond to defendants' interrogatories concerning her sexual partners... .”). Generally speaking, instructions from attorneys to their clients not to answer questions at a deposition should be “limited to [issues regarding] privilege.” Morales v. Zondo, Inc., 204 F.R.D. 50, 54 (S.D.N.Y. 2001). In this case, defense counsel ranged far beyond the normal parameters of objections and sought to decide for himself what issues were relevant. That was improper and the Court should order a resumption of the Defendant’s deposition so that she can answer questions about her knowledge of sexual activity relating to Jeffrey Epstein. CONCLUSION Defendant should be ordered to sit for a follow-up deposition and directed to answer questions regarding her knowledge of alleged “adult” sexual activity. Dated: May 5, 2016 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: __ ZF Sigrid McCawley (Px6Hlac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLPCase 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 9 of 10 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-52027 * This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation.Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 10 of 10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 5th day of May, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C, 150 East 10" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com BRB 10Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 1 of 6 EXHIBIT 4 Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 2 of 6 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK _ _ awl _ -_ _ -_ - -_ —_ - -_ _ _ _ — - - - _ oaks VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants. - - - —_ - - - —_ - - - -_ _ = ~ - - - -_ -_ + ** CONFIDENTIAL» * Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 3 of 6 2 APPEARANCES : BOITES SCHILLER & FLEXNER, LLP 4 Attorneys for Plaintiff 401 Bast Las Olas Boulevard 5 Fort Lauderdatle, Florida, 33301 BY; SIGRID McCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ, ESQUIRE EMMA ROSEN, PARALEGAL FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN, P.L-~ Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 11 BY: BRAD EDWARDS, ESQUIRE 12 LS PAUL G, CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE 20 21 Also Present: 22 James Christe, videographer 23 24 25 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 4 of 6 10 11 12 13 14 Lé 16 Li 18 19 20 21 22 23 24 25 Page 60 G Maxwell - Confidential A. She was tasked to answer telephones. Q. Did you ever ask her to rub Jeffrey's feet? MR. PAGLIUCA: Objection to the form and foundation. Ac I believe that I have read that, but I don't have any memory of it. Q. Did you ever tell Johanna that she would get extra money if she provided Jeffrey massages? A. I was always happy to give career advice to people and I think that becoming somebody in the healthcare profession, either exercise instructor or nutritionist or professional massage therapist is an excellent job opportunity. Hourly wages are around 7, 8, $9 and as a professional healthcare provider you can earn somewhere between as we have established 100 to $200 and to be able to travel and have a job that pays that is a wonderful job opportunity. So in the context of advising people for opportunities for work, it is possible that I MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 5 of 6 10 dsb 12 13 14 15 16 17 18 19 20 24 22 23 24 25 Page 61 G Maxwell - Confidential would have said that she should explore that as an option. QO. Did you tell her she would get extra money if she massaged Jeffrey? A. I'm just saying, I cannot recall the exact conversation. I give career advice and I have done that. Q. Did you ever have Johanna massage you? A. I did. QO. How many times? A. I don't recall how many times. Qs Was there sex involved? A. No. Q. Did you ever instruct Johanna to massage Glenn Dubin? A. I don't believe -- I have no recollection of it. Q. Did you ever have sexual contact with Johanna? MR. PAGLIUCA: Object to the form and foundation. You need to give me an opportunity to get in between the questions. MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 6 of 6 Page 62 1 G Maxwell - Confidential 2 Anything that involves consensual 3 sex on your part, I'm instructing you 4 not to answer. 5 Q. Did you ever have sexual contact 6 with Johanna? 7 A. Again, she is an adult -- 8 Q. I'm asking you, did you ever have 9 sexual contact with Johanna? 10 A. I've just been instructed not to 11 answer. 12 Q. On what basis? 13 A. You have to ask my lawyer. 14 Q. Did you ever have sexual contact 15 with Johanna that was not consensual on 16 Johanna's part? LY MR. PAGLIUCA: You can answer 18 nonconsensual. 19 A. T've never had nonconsensual sex 20 with anybody. 21 Q. Not Annie Farmer? 22 MR. PAGLIUCA: Objection. 23 A. I just testified I never had 24 nonconsensual sex with anybody ever, at any 25 time, at anyplace, at any time, with anybody. MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 1 of 17 EXHIBIT 6 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 2 of 17 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - _ - - -_ — => -_ - - —_ = - - -_ - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.; -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants. ot _ - - - _ = - —_ - _ - ~ -_ - — - - - ~ ma ** CONF IDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 3 of 17 Page 2 2 APPEARANCES : BOTES SCHILLER & FLEXNER, LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdatle, Florida, 33301 BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ, ESQUIRE EMMA ROSEN, PARALEGAL 7 8 FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN, P.L. Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 il BY: BRAD EDWARDS, ESQUIRE 12 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE 20 21 Also Present: 22 James Christe, videographer 23 24 25 MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 4 of 17 Page 52 1 G Maxwell - Confidential 2 for sexual acts. 3 Q. I'm asking if they performed sexual 4 acts? 5 MR. PAGLIUCA: Object to the form 6 and foundation. 7 Q. Did any of the massage therapists 8 who were at the home perform sexual acts for 9 Jeffrey Epstein? 10 A. I don't know what you mean by LT sexual acts. 12 Q. Did any of the massage therapists 13 who were working at the home perform sexual 14 acts, including touching the breasts, 15 touching the vaginal area, being touched 16 while Jeffrey is masturbating, having TY intercourse, any of those things? 18 MR. PAGLIUCA: Objection. Form and 19 foundation. 20 To the extent any of this is asking Pl for to your knowledge any consensual sex 22 act that may or may not have involved 23 you, I'm instructing you not to answer 24 the question. 25 Q. I'm not asking about consensual sex MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 5 of 17 Page 53 1 G Maxwell - Confidential 2 acts. I'm asking whether any of the massage 3 therapists performed sexual acts for Mr- 4 Epstein, as I have just described? 5 A. I have never seen anybody have 6 sexual intercourse with with Jeffrey, ever. 7 Q. I'm not asking about sexual 8 intercourse. I'm asking about any sexual 9 act, touching of the breast -- did you ever 10 see -- can you read back the question? 11 (Record read.) 12 A. I'm not addressing any questions 13 about consensual adult sex. If you want to 14 talk about what the subject matter, which is 15 defamation and lying, Virginia Roberts, that 16 you and Virginia Roberts are participating in 17 perpetrating her lies, I'm happy to address 18 those. I never saw any inappropriate 19 underage activities with Jeffrey ever. 20 Q. I'm not asking about underage. I'm 21 asking about whether any of the masseuses 22 that were at the home perform sexual acts for a3 Jeffrey Epstein? 24 A. I have just answered the question. 25 Q. No, you haven't. MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 6 of 17 10 Lt 12 LS 14 15 16 Lk 18 ay 20 21 22 23 24 25 G Maxwell - Confidential A I have. Q. No, you haven't. A Yes, I have. Q. You are refusing to answer the question. A. Let's move on. Q. I'm in charge of the deposition. I say when we move on and when we don't. You are here to respond to my questions. If you are refusing to answer the court will bring you back for another deposition to answer these questions. Do you understand that? MR. PAGLIUCA: You don't need to threaten the witness. MS. McCAWLEY: I'm not threatening her. I'm making sure the record is clear. MR. PAGLIUCA: Certainly can you apply to have someone come back and the court may or may not have her come back again. Again, she is not answering questions that relate to adult consent Page 54 MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 7 of 17 Page 55 1 G Maxwell - Confidential 2 sex acts. Period. And that's the 3 instruction and we can take it up with 4 the court. 5 Q. Ms, Maxwell, are you aware of any 6 sexual acts with masseuses and Jeffrey 7* Epstein that were nonconsensual? 8 A. No. 9 Q. How do you know that? 10 A. All the time that I have been in oak the house I have never seen, heard, nor 12 witnessed, nor have reported to me that any 13 activities took place, that people were in 14 distress, either reported to me by the staff 15 or anyone else. I base my answer based on 16 that. 17 Q. Are you familiar with a person by 18 the name of Annie Farmer? 13 A. I am, 20 QO. Has Annie Farmer given a statement 22. to police about you performing sexual acts on 22 her? 23 A. I have not heard that. 24 QO. Has Annie Farmer given a statement 25 to police about Jeffrey Epstein performing MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 8 of 17 Page 64 1 G Maxwell - Confidential 2 QO. Did you have sex with her? 3 MR. PAGLIUCA: This is the same 4 instruction about consensual or 5 nonconsensual. 6 Q. Was Emmy under the age of 18 when 7 you hired her? 8 Ais No. I didn't hire her, as I said, 9 Jeffrey did. 10 Q. Did Emmy ever have sex with 42 Jeffrey? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. How would I know what somebody else 15 did. 16 QO. You weren't involved in the sex 17 between Jeffrey, Emmy and yourself? 18 A. We already -- 19 Q. Were you involved with sex between 20 Jeffrey, Emmy and yourself? 21 MR. PAGLIUCA: Everyone is talking 22 ever each other. You heard the 23 question. 24 Again, you you know what the 25 imstruction is. If there is any MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 9 of 17 Page 65 1 G Maxwell - Confidential 2 consensual issue involved, I instruct 3 you not to answer, A, Moving on. 5 Q. So you are refusing to answer that 6 question? 7 A. I've been instructed by my lawyer. 8 KY Did you ever have sex with Jeffrey, 9 Emmy, Virginia and yourself when Virginia was 10 underage? 11 A. Absolutely not. 12 MR. PAGLIUCA: We've been going for 13 about an hour. JI would like to take a 14 five-minute break, please. 15 MS. McCAWLEY: I'm almost done. 16 MR. PAGLIUCA: You are not going to PAY, allow a break. 18 MS. McCAWLEY: As soon as I get 19 through my line of questioning, which is 20 perfectly appropriate. 21 eG. Did Emmy Taylor travel with you and 22 Jeffrey to Europe? 23 A. I'm sure she did. 24 Q. What is she doing today? 25 A. I have no idea. MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 10 of 17 LO 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 82 G Maxwell - Confidential Q. Did you train Virginia on how to recruit other girls to perform sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. No. And it's absurd and her entire story is one giant tissue of lies and furthermore, she herself has -- if she says that, you have to ask her about what she did. Q. Does Jeffrey like to have his nipples pinched during sexual encounters? MR. PAGLIUCA: Objection to form and foundation. A. I'm not referring to any advice on my counsel. I'm not talking about any adult sexual things when I was with him. Q. When Jeffrey would have a massage, would he request that the masseuse pinch his nipples while he was having a massage? A. I'm not talking about anything with consensual adult situation. Q. What about with underage -- A. I am not aware of anything. QO. You are not aware of Jeffrey MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 11 of 17 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 92 G Maxwell - Confidential Q. In your responsibilities in working for Jeffrey, would you book massages for him on any given day so that he would have a massage scheduled? Would you take a call for example and book a massage for him? MR. PAGLIUCA: Objection to the form and foundation. QO. You can answer. A. Typically, that was not my responsibility. He would either book the massage himself or one of his other assistants would do that. Q. From time to time you had to do that? MR, PAGLIUCA: Objection to the form and foundation, A. Like I said, typically it was somebody else's responsibility. Q. If you were unable to book a girl for a massage on a given day, would that mean that you were responsible for giving him a sexual massage? MR. PAGLIUCA: Objection to the form and foundation and I instruct you MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 12 of 17 10 LL 12 13 14 15 16 Ae, 18 LQ 20 21 22 23 24 25 Page 93 G Maxwell - Confidential not to answer any questions about any of your consensual adult sexual activity. Q. So you are not going to answer that question? A, You just heard my counsel. Q. Have you ever said to anybody that recruiting other girls to perform sexual massages for Jeffrey Epstein takes the pressure off you? MR. PAGLIUCA: Object to the form and foundation, A, Repeat the question and break it out, Q. Have you ever said to anybody that you recruit girls -- A. Stop right there. I never recruited girls, let's stop there. Now breakdown the question. Q. Have you ever said to anybody -- A, By girls, we are talking about underage people -- you said girls, are you talking about underage -- we are not talking about consensual acts -- this is a defamation suit. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 13 of 17 Page 137 Hf G Maxwell - Confidential 2 the flights? 3 A. I can't recollect having a meal 4 with them, but just so we are clear, the 5 allegations that Clinton had a meal on 6 Jeffrey's island is 100 percent false. 7 Q. But he may have had a meal on 8 Jeffrey's plane? 9 A. I'm sure he had a meal on Jeffrey's 10 plane. 11 Q. You do know how many times he flew 12 on Jeffrey's plane? 13 A. I don't. 14 Q. Do you know who Doug Band is? 15 A. rT de. 16 Q. How do you know him? 1? A. He used to work or still works for 18 Bill Clinton. 19 Q. Did you ever have a relationship 20 with him? oh A. We are talking about adult 22 consensual relationships, it's off the 23 record. 24 Q. I'm not asking what you did with 25 him, I'm asking if you ever had a MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 14 of 17 Page 138 1 G Maxwell - Confidential 2 relationship with him? 3 MR. PAGLIUCA: If you understand 4 the term relationship, certainly you can 5 answer that. 6 A. Define relationship. 7 QO. Somebody that you would have spent 8 time together, either seeing them in a 9 romantic relationship or -- 10 A. You need to be, what do you mean by 11 romantic. I was friends with Doug but you 12 are suggesting something more so I want to he 13 clear what you are actually asking me. 14 9: You defined it. You said you were 15 friends with him. If that's what you were 16 that's all I need to know. 17 While you were on the trip with 18 President Clinton, do you recall where you 19 stayed at these locations, in other words, 20 would you leave the jet and stay overnight at 21 a hotel, do you have a recollection of this 22 trip? 23 A. I recollect the trip but if you're 24 asking me where we stayed, you can see it's a 25 very fast paced trip. It was very tiring and MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 15 of 17 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 307 G Maxwell - Confidential form and foundation. A. I don't know why the name is -- I'm sorry -- I can't -- I have no idea. I recognize the name but that's it. Q, Was Johanna Sjoberg a masseuse? MR. PAGLIUCA: Objection to the form and foundation. A. What are you asking me, I'm sorry? Q. When Johanna Sjoberg worked for Jeffrey Epstein, did she perform massages? A. I've testified that when Johanna came originally, she came to answer telephones. I believe at some point she became a masseuse. I don't recollect when and I personally had massages from Johanna. Q. What did Johanna do for Jeffrey Epstein, did she perform massages, anything else? MR. PAGLIUCA: Objection to the form and foundation. A. When she came she answered phones and at some point, I believe, I don't have any firm recollection, but I believe she went to school and became a masseuse and I had MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 16 of 17 Page 308 i, G Maxwell - Confidential 2 massages from her. 3 Q. Did you ever have any sexual 4 interaction with her? 5 MR. PAGLIUCA: Object to the form 6 and foundation and I'm going to instruct 7 you if we're talking about any 8 consensual adult contact, you are not 9 allowed to answer the question. 10 Q. Did you have any sexual contact a2 with her in the presence of Jeffrey Epstein? 12 MR, PAGLIUCA: Same instruction. 13 Q. Did you have any sexual contact 14 with her in the presence of anybody other 15 than Jeffrey Epstein? 16 MR. PAGLIUCA: Same instruction. 17 Q. How many massages did you receive 18 from Johanna? 19 A. I really don't recall but a fair 20 amount. 21 Q. Did the massages involve sex? 22 MR. PAGLIUCA: I'm going to 23 instruct you not to answer. 24 Q. Have you ever engaged in sex with 25 any female? MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 17 of 17 Page 309 1 G Maxwell - Confidential 2 MR. PAGLIUCA: I'm going to 3 instruct you not to answer. a MS. McCAWLEY: I want the record to 5 reflect that Ms. Maxwell's attorney is 6 directing her not to answer this series 7 of questions. 8 MR. PAGLIUCA: It definitely does. 9 Q. Were you responsible for 10 introducing Anuska to Jeffrey Epstein? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I already testified that I don't 14 really recall Anuska. 15 Q. Were you responsible for 16 introducing Johanna to Jeffrey Epstein? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. Again, I don't like the 20 characterization of introduction. Johanna 21 came to answer telephones. 22 Q. When did you -- were you the person 23 who brought or introduced or met Johanna for 24 purposes of bringing her to Jeffrey Epstein's 25 home? MAGNA® LEGAL SERVICES Case 1:15-cv-07433-LAP Documen t1320-5 Filed 01/03/24 Page 1 of 56 COMPOSITE EXHIBIT ACase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 2 of 56 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - |---| |= = ee eee ee eH He HH XX VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants. - 2-2. ee ee LL LLL LLL LL ** CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 Page 1 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 3 of 56 2 APPEARANCES: BOIES SCHILLER & FLEXNER, LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdatle, Florida, 33301 BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ, ESQUIRE EMMA ROSEN, PARALEGAL 7 8 FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN, P.L. Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 11 BY: BRAD EDWARDS, ESQUIRE 12 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE 20 21 Also Present: 22 James Christe, videographer 23 24 25 Page 2 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 4 of 56 Questions About People Under the Age of 18 at Epstein’s HomeCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 5 of 56 Page 13 1 G Maxwell - Confidential 2 Q. You can answer. 3 A. I have not any idea exactly of the 4 youngest adult employee that I hired for 5 Jeffrey. 6 Q. When you say adult employee, did 7 you ever hire someone that was under the age 8 of 18? 9 A. Never. 10 Q. Did you ever bring someone who was 11 under -- invite someone under the age of 18 12 to Jeffrey's home, any of his homes? 13 MR. PAGLIUCA: Object to the form 14 foundation. 15 A. Can you repeat the question? 16 Q. Did you ever invite anybody who was 17 under the age of 18 to Jeffrey's homes? 18 MR. PAGLIUCA: Same objections. 19 A. I have a number of friends that 20 have children and friends of mine that have 21 kids and in the invitation of my friends and 22 their kids, I'm sure I may have invited some 23 of my friend's kids to come. 24 Q. Anybody that is not a friend of 25 yours. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 6 of 56 Questions About Meeting the Plaintiff and Massages with PlaintiffCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 7 of 56 1 G Maxwell - Confidential 2 A. Ms. Roberts held herself out -- 3 Q. I'm not asking how she held herself 4 out. I'm asking how she arrived at the home. 5 Did you meet her and invite her to come to 6 the home or how did she arrive there? 7 MR. PAGLIUCA: Object to the form 8 and foundation. 9 A. Ms. Roberts held her to be a 10 masseuse and her mother drove her to the 11 house. 12 Q. When did you first meet Virginia 13 Roberts? 14 A. I don't have a recollection of the 15 first meeting. 16 Q. Do you recall meeting her at 17 Mar-a-Lago? 18 A. Like I said, I don't have a 19 recollection of meeting Ms. Roberts. 20 Q. So you recall Ms. Roberts being 21 brought to the home by her mother, is that 22 your testimony? 23 A. That is my testimony. 24 Q. And that is the first time you met 25 her? Page 16 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 8 of 56 1 G Maxwell - Confidential 2 A. Like I said, I don't recall meeting 3 her the first time. I do remember her mother 4 bringing her to the house. 5 Q. Are you a member at Mar-a-Lago? 6 A. No. 7 Q. Have you visited Mar-a-Lago? 8 A. Yes. 9 Q. Did you visit Mar-a-Lago in the 10 year 2000? 11 A. I'm pretty sure I did. 12 Q. When Ms. Roberts arrived at the 13 home with her mother, what happened? 14 A. I spoke to her mother outside of 15 the house and she -- what I don't recall is 16 exactly what happened because I was talking 17 to her mother the entire she was in the 18 house. 19 Q. Did you introduce Ms. Roberts to 20 Jeffrey Epstein? 21 A. I don't recall how she actually met 22 Mr. Epstein. As I said, I spoke to her 23 mother the entire time outside the house. 24 Q. Did you walk Ms. Roberts up to the 25 upstairs location at the Palm Beach house to Page 17 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 9 of 56 1 G Maxwell - Confidential 2 absolutely everything that took place in that 3 first meeting. She has lied repeatedly, 4 often and is just an awful fantasist. So 5 very difficult for anything to take place 6 that she repeated because I was with her 7 mother the entire time. 8 Q. So did you have -- did you give a 9 massage with Virginia Roberts and Mr. Epstein 10 during the first time Virginia Roberts was at 11 the West Palm Beach house? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 Q. Yes or no? 15 A. No. 16 Q. Have you ever given a massage with 17 Virginia Roberts in the room and Jeffrey 18 Epstein? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. No. 22 Q. Have you ever given Jeffrey Epstein 23 a massage? 24 MR. PAGLIUCA: Object to the form, 25 foundation. And I'm going to instruct Page 19 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 10 of 56 Questions About Massages with MinorsCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 11 of 56 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 22 G Maxwell - Confidential questions. MR. PAGLIUCA: I'm instructing her not to answer. MS. McCAWLEY: Then we will be back here again. Q. Have you ever given a massage to Mr. Epstein with a female that was under the age of 18? A. Can you repeat the question? Q. Yes. Have you ever given a massage to Mr. Epstein with a female that was under the age of 18? A. No. Q. Have you ever observed Mr. Epstein having a massage given by an individual, a female, who was under the age of 18? A. No. Q. Have you ever observed females under the age of 18 in the presence of Jeffrey Epstein at his home? MR. PAGLIUCA: Object to the form and foundation. A. Again, I have friends that have children -- MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 12 of 56 Questions About Hiring Massage TherapistsCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 13 of 56 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 31 G Maxwell - Confidential -- just another one of Virginia's many fictitious lies and stories to make this a Salacious event to get interest and press. It's absolute rubbish. Q. Were you in charge of hiring individuals to provide massages for Jeffrey Epstein? A. My job included hiring many people. There were six homes. As I sit here, I hired assistants, I hired architects, I hired decorators, I hired cooks, I hired cleaners, I hired gardeners, I hired pool people, I hired pilots, I hired all sorts of people. In the course and a very small part of my job was from from time to time to find adult professional massage therapists for Jeffrey. Q. When you say adult professional massage therapists, where did you find these massage therapists? A. From time to time I would visit professional spas, I would receive a massage and if the massage was good I would ask that man or woman if they did home visits. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 14 of 56 Questions About i and Nadia MarcinkovaCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 15 of 56 Page 37 1 G Maxwell - Confidential 2 here today I do not. 3 Q. Ms. Maxwell, when did you first 4 nect 5 MR. PAGLIUCA: Object to the form 6 and foundation. 7 A. I have no idea when I met her. 8 Q. Do you know how old she was when 9 you met her? 10 A. I have no idea how old she was when 11 I met her. 12 Q. Is it possible she was 13 years old 13 when you first met her? 14 MR. PAGLIUCA: Object to the form 15 and foundation. 16 Er SS 18 may have been in the house when Jeffrey was 19 in the house. I have no idea how old she 20 was. 21 Q. I understand she was with 9g 2 23 I'm asking if I was 13 24 years old when you first met her? 25 A. I have no idea. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 16 of 56 Page 38 1 G Maxwell - Confidential 2 Q. Was she under 18 when you first met 3 her? 4 A. I have no idea how old she was when 5 I first met her. 6 Q. Did she look like a child when you 7 first met her? 8 A. I don't remember what she looked 9 like at the time she was in the house. 10 Q. How many years have you known her? 11 A. I can only recall the last time I 12 saw her. 13 Q. When was the first time you met 14 her? 15 A. Again, I just told you, I don't 16 recall the first time I met her. 17 Q. Did MJ travel with you 18 on Jeffrey's planes? 19 A. I wouldn't remember if J was on 20 the plane or not. 21 Q. Did you ever have sex with yy 2 23 A. No. 24 Q. Did you ever observe Jeffrey having 25 sex with aT MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 17 of 56 1 G Maxwell - Confidential 2 A. No. 3 Q. Were you aware that Jeffrey was 4 having sexual contact with i when 5 she was 13 years old? 6 MR. PAGLIUCA: Object to the form 7 and foundation. 8 A. I would be very shocked and 9 surprised if that were true. 10 Q. Were you in the house when yy 0 6CP).swe's:s in the house in a private area 12 with Jeffrey Epstein? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 A. Can you repeat the question. 16 Q. Were you ever in the Palm Beach 17 house when Jeffrey Epstein was in the house 18 with i: 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. I've already testified that I have 22 met her and that she was there yyy 23 [ERR oT don't understand what your 24 question is asking. 25 Q. So you have never seen Page 39 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 18 of 56 Page 40 1 G Maxwell - Confidential 0 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 Q. Is that your testimony? 6 A. I already said I don't recall all 7 the times I've seen her and I have no memory 8 of that. 9 Q. Have you ever seen I in 10 the house with Jeffrey Epstein iy — | 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. I just told you I don't recall 15 seeing 16 Q. Were you ever involved in an orgy 17 wich 18 A. No, absolutely not. 19 Q. Can you tell me, do you know an 20 individual by the name of Nadia Marcinkova? 21 A. I do. 22 Q. How did you meet Nadia Marcinkova? 23 A. At some point she was a friend of 24 Jeffrey's and I recall meeting her at some 25 point. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 19 of 56 1 G Maxwell - Confidential 2 Q. Did Jeffrey arrange for a visa for 3 Nadia Marcinkova? 4 A. I don't know what Jeffrey did. I 5 cannot testify what Jeffrey did. 6 Q. Was Nadia involved in sex with 7 Jeffrey and other girls? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 Q. Girls under the age of 18? 11 MR. PAGLIUCA: Same objection. 12 A. I have no idea. 13 Q. Was Nadia involved with sex with 14 Jeffrey and girls over the age of 18? 15 MR. PAGLIUCA: Same objection. 16 A. I have no idea. 17 Q. Did Nadia recruit other girls for 18 sex with Jeffrey? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. I have no idea. 22 Q Do you still talk to Nadia? 23 A. No. 24 Q. Is she a pilot? 25 A I have no idea. Page 46 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 20 of 56 Questions About Mr. Epstein and SexCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 21 of 56 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 53 G Maxwell - Confidential acts. I'm asking whether any of the massage therapists performed sexual acts for Mr. Epstein, as I have just described? A. I have never seen anybody have sexual intercourse with with Jeffrey, ever. Q. I'm not asking about sexual intercourse. I'm asking about any sexual act, touching of the breast -- did you ever see -- can you read back the question? (Record read.) A. I'm not addressing any questions about consensual adult sex. If you want to talk about what the subject matter, which is defamation and lying, Virginia Roberts, that you and Virginia Roberts are participating in perpetrating her lies, I'm happy to address those. I never saw any inappropriate underage activities with Jeffrey ever. Q. I'm not asking about underage. I'm asking about whether any of the masseuses that were at the home perform sexual acts for Jeffrey Epstein? A. I have just answered the question. Q. No, you haven't. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 22 of 56 Questions About Sarah Kellen, Glen Dubin, Plaintiff, Johanna Sjoberg, Annie Farmer and SexCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 23 of 56 1 G Maxwell - Confidential 2 A. I have. 3 Q. No, you haven't. 4 A. Yes, I have. 5 Q. You are refusing to answer the 6 question. 7 A. Let's move on. 8 Q. I'm in charge of the deposition. I 9 say when we move on and when we don't. 10 You are here to respond to my 11 guestions. If you are refusing to answer the 12 court will bring you back for another 13 deposition to answer these questions. 14 Do you understand that? 15 MR. PAGLIUCA: You don't need to 16 threaten the witness. 17 MS. McCAWLEY: I'm not threatening 18 her. I'm making sure the record is 19 clear. 20 MR. PAGLIUCA: Certainly can you 21 apply to have someone come back and the 22 court may or may not have her come back 23 again. 24 Again, she is not answering 25 questions that relate to adult consent Page 54 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 24 of 56 Page 55 1 G Maxwell - Confidential 2 sex acts. Period. And that's the 3 instruction and we can take it up with 4 the court. 5 Q. Ms. Maxwell, are you aware of any 6 sexual acts with masseuses and Jeffrey 7 Epstein that were nonconsensual? 8 A. No. 9 Q. How do you know that? 10 A. All the time that I have been in 11 the house I have never seen, heard, nor 12 witnessed, nor have reported to me that any 13 activities took place, that people were in 14 distress, either reported to me by the staff 15 or anyone else. I base my answer based on 16 that. 17 Q. Are you familiar with a person by 18 the name of Annie Farmer? 19 A. IT am. 20 Q. Has Annie Farmer given a statement 21 to police about you performing sexual acts on 22 her? 23 A. I have not heard that. 24 Q. Has Annie Farmer given a statement 25 to police about Jeffrey Epstein performing MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 25 of 56 1 G Maxwell - Confidential 2 asked and answered already. 3 Q. You can answer the question. 4 A. I have no idea what Sarah Kellen 5 did. 6 Q. You never observed Sarah Kellen 7 with girls under the age of 18 at Jeffrey's 8 home? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 A. The answer is no, I have no idea. 12 Q Do you know Glenn Dubin? 13 A. I do. 14 Q What is your relationship with 15 Glenn Dubin? 16 MR. PAGLIUCA: Object to the form. 17 A. What do you mean what is my 18 relationship. 19 Q. Are you friendly with him, how do 20 you know him? 21 A. He is the husband of Eva Dubin. 22 Q. Is Eva Dubin one of your friends? 23 A. Yes. 24 Q. Did you ever send Virginia to 25 Glenn's condo at the Breakers to give hima Page 57 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 26 of 56 Page 58 1 G Maxwell - Confidential 2 massage? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. No. 6 Q. Did you ever instruct Virginia 7 Roberts to have sex with Glenn? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I have never instructed Virginia to 11 have sex with anybody ever. 12 Q. How old was Eva Anderson when she 13 met Jeffrey? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. I have no idea. 17 Q. What's she under the age of 18? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I just testified I have idea how 21 old she was. 22 Q. You testified she was your friend. 23 You don't know how old she was when she met 24 Jeffrey? 25 A. That happened sometime in the '70Os, MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 27 of 56 Page 59 1 G Maxwell - Confidential 2 how would I know, or '80s. I have no idea. 3 Can you testify to what your friends did 30 4 years ago? 5 Q. You don't ask the questions here, 6 Ms. Maxwell. 7 What about Johanna Sjoberg, when 8 did you first meet Johanna? 9 A. I don't recall the exact date. 10 Q. Did you hire Johanna? 11 A. I don't hire people, she came to 12 work at the house to answer phones. 13 Q. Where did you meet her? 14 A. I just testified, I don't recall 15 exactly when I met her. 16 Q. Was one of your job 17 responsibilities to interview people that 18 would be then hired by Jeffrey? 19 A. That was one of my 20 responsibilities. 21 Q. Do you recall interviewing Johanna? 22 A. I don't recall the exact interview, 23 no. 24 Q. Do you know what tasks Johanna was 25 hired to performance? MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 28 of 56 1 G Maxwell - Confidential 2 A. She was tasked to answer 3 telephones. 4 Q. Did you ever ask her to rub 5 Jeffrey's feet? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I believe that I have read that, 9 but I don't have any memory of it. 10 Q. Did you ever tell Johanna that she 11 would get extra money if she provided Jeffrey 12 massages? 13 A. I was always happy to give career 14 advice to people and I think that becoming 15 somebody in the healthcare profession, either 16 exercise instructor or nutritionist or 17 professional massage therapist is an 18 excellent job opportunity. Hourly wages are 19 around 7, 8, $9 and as a professional 20 healthcare provider you can earn somewhere 21 between as we have established 100 to $200 22 and to be able to travel and have a job that 23 pays that is a wonderful job opportunity. So 24 in the context of advising people for 25 opportunities for work, it is possible that I Page 60 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 29 of 56 1 G Maxwell - Confidential 2 would have said that she should explore that 3 as an option. 4 Q. Did you tell her she would get 5 extra money if she massaged Jeffrey? 6 A. I'm just saying, I cannot recall 7 the exact conversation. I give career advice 8 and I have done that. 9 Q. Did you ever have Johanna massage 10 you? 11 A. I did. 12 Q. How many times? 13 A. I don't recall how many times. 14 Q. Was there sex involved? 15 A. No. 16 Q. Did you ever instruct Johanna to 17 massage Glenn Dubin? 18 A. I don't believe -- I have no 19 recollection of it. 20 Q. Did you ever have sexual contact 21 with Johanna? 22 MR. PAGLIUCA: Object to the form 23 and foundation. You need to give me an 24 opportunity to get in between the 25 questions. Page 61 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 30 of 56 1 G Maxwell - Confidential 2 Anything that involves consensual 3 sex on your part, I'm instructing you 4 not to answer. 5 Q. Did you ever have sexual contact 6 with Johanna? 7 A. Again, she is an adult -- 8 Q. I'm asking you, did you ever have 9 sexual contact with Johanna? 10 A. I've just been instructed not to 11 answer. 12 Q. On what basis? 13 A. You have to ask my lawyer. 14 Q. Did you ever have sexual contact 15 with Johanna that was not consensual on 16 Johanna's part? 17 MR. PAGLIUCA: You can answer 18 nonconsensual. 19 A. I've never had nonconsensual sex 20 with anybody. 21 Q. Not Annie Farmer? 22 MR. PAGLIUCA: Objection. 23 A. I just testified I never had 24 nonconsensual sex with anybody ever, at any 25 time, at anyplace, at any time, with anybody. Page 62 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 31 of 56 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 63 G Maxwell - Confidential Q. So if Johanna were to testify that she did not consent to a sexual act that you participated in -- A. I just told you I have never ever under any circumstances with anybody, at any time, in anyplace, in any form had nonconsensual relations with anybody. Q. Did you introduce Johanna to Prince Andrew? MR. PAGLIUCA: Objection to the form and foundation. A. I've, again, read that Johanna claimed that she met or that she said she met Prince Andrew. I don't know if I was the one who made the introduction or not. Q. Do you know a female by the name of Emmy Taylor? A. I do. How do you know her? Emmy was my assistant. Yes. Q A Q. So she worked for you? A QO Did you hire her? A Again, Jeffrey hired people. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 32 of 56 Questions About Emmy, Virginia, and Ms. Maxwell Regarding SexCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 33 of 56 Page 65 1 G Maxwell - Confidential 2 consensual issue involved, I instruct 3 you not to answer. 4 A. Moving on. 5 Q. So you are refusing to answer that 6 question? 7 A. I've been instructed by my lawyer. 8 Q. Did you ever have sex with Jeffrey, 9 Emmy, Virginia and yourself when Virginia was 10 underage? 11 A. Absolutely not. 12 MR. PAGLIUCA: We've been going for 13 about an hour. I would like to take a 14 five-minute break, please. 15 MS. McCAWLEY: I'm almost done. 16 MR. PAGLIUCA: You are not going to 17 allow a break. 18 MS. McCAWLEY: As soon as I get 19 through my line of questioning, which is 20 perfectly appropriate. 21 Q. Did Emmy Taylor travel with you and 22 Jeffrey to Europe? 23 A. I'm sure she did. 24 Q. What is she doing today? 25 A. I have no idea. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 34 of 56 Questions About Outfits and Sex ToysCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 35 of 56 Page 69 1 G Maxwell - Confidential 2 about. 3 Q. So you didn't provide her with 4 that? 5 A. As I just testified, I have no idea 6 what you are talking about. 7 Q. I was trying to interpret whether 8 you didn't understand what a school girl 9 outfit was or you are saying that didn't 10 happen? 11 A. I clearly know what a school girl 12 outfit is. I have no recollection of 13 providing anybody with a school girl outfit. 14 Q. Did you have a set of outfits used 15 by the massage therapists that would include 16 things like a school girl outfit or a black 17 patent leather outfit or anything of that 18 nature? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. That would be just another one of 22 Virginia's lies. 23 Q. You didn't have anything like that? 24 A. I did not. 25 Q. Did you have a basket of sex toys MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 36 of 56 1 G Maxwell - Confidential 2 that you kept in the Palm Beach house? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. First of all what do you mean. 6 Q. A laundry basket that contained sex 7 toys in it? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. Can you ask the question again? 11 Q. Did you have a laundry basket that 12 contained sex toys in it, in the Palm Beach 13 House? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 Q. Did you have a laundry basket of 17 sex toys in the Palm Beach house? 18 MR. PAGLIUCA: Same objection. 19 Q. You can answer. 20 A. I don't recollect anything about a 21 laundry basket of sex toys. 22 Q. Do you recollect having sex toys at 23 the Palm Beach house? 24 A. You have to define what are you 25 talking about. Page 70 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 37 of 56 Questions About Plaintiff and Epstein and SexCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 38 of 56 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 75 G Maxwell - Confidential Q. Do you recall having a basket full of sex toys? A. I already told you I did not. Q. We were talking a moment ago about Ms. Roberts and her position as a masseuse, do you know what she was paid for working as a masseuse for Jeffrey Epstein? A. I do not. Q. Did you ever pay her? A. I don't ever recall paying her. Q. Do you know what happened during the massage appointments with Jeffrey Epstein and Virginia Roberts? MR. PAGLIUCA: Objection to the form and foundation. A. No. Q. Were you ever present to view a massage between Jeffrey Epstein and Virginia Roberts? A. I don't recollect ever seeing Virginia and Jeffrey in a massage situation. Q. Do you ever recollect seeing them in a sexual situation? A. I never saw them in a sexual MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 39 of 56 1 G Maxwell - Confidential 2 Situation. 3 Q. Did you ever participate in sex 4 with Virginia Roberts and Jeffrey Epstein? 5 A. I never ever at any single time at 6 any point ever at all participated in 7 anything with Virginia and Jeffrey. And for 8 the record, she is an absolute total liar and 9 you all know she lied on multiple things and 10 that is just one other disgusting thing she 11 added. 12 Q. Did you help her obtain an 13 apartment in Palm Beach to live in? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 Q. Was that part of your 17 responsibilities for Jeffrey? 18 A. First of all, I didn't know she had 19 an apartment in Palm Beach. I only learned 20 that from the many times you guys have gone 21 to the press to sell stories, so no. 22 Q. Did you help her get a cell phone, 23 was that one of your responsibilities for 24 Jeffrey, to get her is a cell phone as part 25 of her masseuse obligations? Page 76 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 40 of 56 Questions About Training Plaintiff to Recruit Girls for MassagesCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 41 of 56 Page 81 1 G Maxwell - Confidential 2 form and foundation. 3 A. Like I told you, I don't recall her 4 being at the house at all. 5 Q. How many homes does Jeffrey have? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. When I was working for him, I think 9 he had six maybe. 10 Q. Would Virginia stay with him in 11 those homes? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I can only testify for when I was 15 present with him and I cannot say what she 16 did when I wasn't present with him. 17 Q. When you were present, would 18 Virginia stay in the homes with him? 19 A. I don't recall her staying in the 20 houses. 21 Q. Did you train Virginia on how to 22 recruit other girls for massages? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. No. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 42 of 56 Page 82 1 G Maxwell - Confidential 2 Q. Did you train Virginia on how to 3 recruit other girls to perform sexual 4 massages? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. No. And it's absurd and her entire 8 story is one giant tissue of lies and 9 furthermore, she herself has -- if she says 10 that, you have to ask her about what she did. 11 Q. Does Jeffrey like to have his 12 nipples pinched during sexual encounters? 13 MR. PAGLIUCA: Objection to form 14 and foundation. 15 A. I'm not referring to any advice on 16 my counsel. I'm not talking about any adult 17 sexual things when I was with him. 18 Q. When Jeffrey would have a massage, 19 would he request that the masseuse pinch his 20 nipples while he was having a massage? 21 A. I'm not talking about anything with 22 consensual adult situation. 23 Q. What about with underage -- 24 A. IT am not aware of anything. 25 Q. You are not aware of Jeffrey MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 43 of 56 Questions About Ms. Maxwell’s Relationship with Mr. EpsteinCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 44 of 56 Page 91 1 G Maxwell - Confidential 2 has perpetrated, cannot tell you what is true 3 or factual or not. 4 Q. You said you were in the home a 5 very limited time, so average in the year for 6 example, 2004, how many times would you have 7 been in his Palm Beach home? 8 A. Very hard for me to state but very 9 little. 10 Q. How about his New York home? 11 A. Same. 12 Q. Were you his girlfriend in that 13 year, in 2004? 14 A. Define what you mean by girlfriend. 15 Q. Were you in a relationship with him 16 where you would consider yourself his 17 girlfriend? 18 A. No. 19 Q. Did you ever consider yourself his 20 girlfriend? 21 A. That's a tricky question. There 22 were times when I would have liked to think 23 of myself as his girlfriend. 24 Q. When would that have been? 25 A. Probably in the early '90s. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 45 of 56 Questions About Recruiting Girls, an Underage Girl in London, and Foreign GirlsCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 46 of 56 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 97 G Maxwell - Confidential A. First of all I resent and despise the world recruit. Would you like to define what you mean by recruit and by girls, you mean underage people. I never had to do anything with underage people. So why don't you reask the question in a way that I am able to answer it. Q. I'm asking if you ever said that to anybody. So if you don't understand the word recruit and you never used that word then the answer to that question would be no. A. I have no memory as I sit here today having used that word. Q. Did you ever meet an underage girl in London to introduce her to Jeffrey to provide him with a massage? MR. PAGLIUCA: Objection to the form and foundation. A. Run that past me one more time. Q. Did you ever meet an underage girl in London to introduce her to Jeffrey to perform a massage? MR. PAGLIUCA: Same objection. A. Are you asking me if I met anybody MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 47 of 56 Page 98 1 G Maxwell - Confidential i) that was underage in London specifically to 3 provide a massage to Jeffrey, is that your 4 question? 5 Q. Yes. 6 A. No. 7 Q. Do you know who Alexander Dixon is? 8 A. I don't recall her right now. 9 Q. Do you know if -- strike that. 10 During the time that you were 11 working for Jeffrey, did you ever observe any 12 foreign females, so in other words, not from 13 the United States, that were brought to 14 Jeffrey's home to perform massages? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. Females, what age are we talking? 18 Q. Any age. 19 A. Can you repeat the question? 20 Q. During the time you were working 21 for Jeffrey, did you ever observe any foreign 22 females of any age that were at Jeffrey's 23 home to perform a massage? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 48 of 56 Page 99 1 G Maxwell - Confidential 2 A. Are you asking me if any foreigner, 3 not an American person, gave Jeffrey a 4 massage? 5 Q. Yes. 6 A. Well, as I sit here today, I can't 7 think of anyone who is foreign. Certainly -- 8 I just can't think of anybody right this 9 second. 10 Q. How about any foreign girls who 11 were under the age of 18? 12 A. I already testified to not knowing 13 anything about underage girls. 14 Q. Were there foreign girls who were 15 brought to Jeffrey's home by Jean Luc Brunel 16 for the purposes of providing massages? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I am not aware of Jean Luc bringing 20 girls. I have not no idea what you are 21 talking about. 22 Q. You have never been around foreign 23 girls who are under the age of 18 at 24 Jeffrey's homes? 25 MR. PAGLIUCA: Objection to the MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 49 of 56 Page 100 1 G Maxwell - Confidential 2 form and foundation. 3 A. I already testified about not 4 knowing about underage girls. 5 Q. Did you provide any assistance with 6 obtaining visas for foreign girls that were 7 under the age of 18? 8 A. I've never participated in helping 9 people of any age to get visas. 10 Q. Did Jeffrey, was it Jeffrey's 11 preference to start a massage with sex? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I think you should ask that 15 question of Jeffrey. 16 Q. Do you know? 17 A. I don't believe that was his 18 preference. I think -- you have to 19 understand, a massage -- perhaps you are not 20 really familiar with what massage is. 21 Q. I am, I don't need a lecture on 22 massage. 23 A. I think you do. 24 MR. PAGLIUCA: No question pending. 25 She will ask you another question now. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 50 of 56 Questions About Underage Girls, Sex with Jon Luc Brunel, and OutfitsCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 51 of 56 Page 116 1 G Maxwell - Confidential 2 Q. Were you present on the island when 3 Prince Andrew visited? 4 A. Yes. 5 Q How many times? 6 A. I can only remember once. 7 Q Were there any girls under the age 8 of 18 on the island during that one visit 9 that you remember that were not family or 10 friends of or daughters of your friends? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. There were no girls on the island 14 at all. No girls, no women, other than the 15 staff who work at the house. Girls meaning, 16 I assume you are asking underage, but there 17 was nobody female outside of the cooks and 18 the cleaners. 19 Q. Did you, as part of your duties in 20 working for Jeffrey, ever arrange for 21 Virginia to have sex with John Luc Brunel? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Just for the record, I have never 25 at any time, at anyplace, in any moment ever MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 52 of 56 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 117 G Maxwell - Confidential asked Virginia Roberts or whatever she is called now to have sex with anybody. Q. Did you ever provide Virginia Roberts with an outfit, an outfit of a sexual nature to wear for Les Wexner? MR. PAGLIUCA: Objection to the form and foundation. A. I think we addressed the outfit issue. Q. IT am asking you if you ever provided her with an outfit of a sexual nature to wear for Les Wexner? A. Categorically no. You did get that, I said categorically no Q. Don't worry I'm paying attention. A. You seemed very distracted in that moment. (Maxwell Exhibit 6, flight logs, marked for identification.) A. Do you mind if I take a break for the bathroom. Q. It's 11:08 and we are going to go off the record now. THE VIDEOGRAPHER: It's now 11:09. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 53 of 56 Questions About Pictures of Naked GirlsCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 54 of 56 Page 188 1 G Maxwell - Confidential 2 people could use -- just like you would use 3 if you needed to go online to get something, 4 that people could use. 5 Q. Was that on a desk that you would 6 use in your work capacity when you were at 7 the house? 8 A. It was a desk, it was a room I was, 9 I didn't really use that computer. 10 Q. Were there images of naked girls 11 whether they be under the age of 18 or over 12 the age of 18 on that computer? 13 A. I have no recollection of any naked 14 people on that computer when I was there in 15 2003, we are talking. 16 Q. What about from say '99 to 2003? 17 A. No, I can't recollect any naked 18 pictures. 19 Q. Why were the computers removed from 20 the house before the search warrant was 21 executed? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. I have no knowledge of anything 25 like that. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 55 of 56 Questions About Topless FemalesCase 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 56 of 56 Page 404 1 G Maxwell - Confidential 2 form and foundation. 3 A. I mean I've been to his -- in the 4 mid '90s, I would have communicated with 5 people who worked for him. 6 Q. Have you communicated with Leslie 7 Wexner about this case? 8 A. No. 9 Q. Have you ever seen a topless female 10 at any one of Jeffrey Epstein's properties? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. You've asked this 13 question, by the way, earlier on today. 14 A. Again, I testified that there are 15 people who from time to time in the privacy 16 of a swimming pool have maybe taken a bikini 17 top off or something but it's not common and 18 certainly when I was at the house I don't 19 really recollect seeing that kind of 20 activity. 21 Q. Have you ever smoked cigarettes? 22 A. Yes. 23 Q. Have you ever smoked cigarettes 24 with Virginia Roberts? 25 A. I don't recall smoking cigarettes MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 1 of 10 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS V. Ghislaine Maxwell, Defendant. PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Reply in Support of her Motion to Compel Defendant to Answer Deposition Questions. Instead of allowing Ms. Giuffre to take a full and complete deposition, Defendant flatly refused to answer questions critical to the key issues in this case. Contrary to Defendant’s assertions, Ms. Giuffre is not engaged in a “fishing expedition” but rather seeks to ask highly-focused questions specifically relevant to this case. In particular, Ms. Giuffre seeks to ask the Defendant questions regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this case, particularly where any answers will be maintained as confidential under the Protective Order entered in this case. As the Court is aware from previous pleadings, at the heart of this case lies the issue of Defendant’s knowledge that Ms. Giuffre was sexually abused by Jeffrey Epstein. Indeed, as the Defendant boldly acknowledges in her response (at p. 2), she intends to argue at trial that (among other things) she “never arranged for or asked [Ms. Giuffre] to have sex with anyone.” At trial,Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 2 of 10 Ms. Giuffre intends to strongly disprove Defendant’s false assertions and to demonstrate that Defendant recruited Ms. Giuffre to be involved in massages of a sexual nature with Epstein. To develop evidence to support her position, Ms. Giuffre recently deposed Defendant about the central subjects in her case. Defendant flatly refused to answer a number of questions, and for the majority of the others, gave varying versions of “I don’t recall.” For example, when faced with the police report which contains statements from approximately thirty (30) different victims during a time frame which the Defendant acknowledges she was actively working for Epstein at his various homes, Defendant challenged the veracity of the victims’ reports: “Q. Are you saying these 30 girls are lying when they gave these reports to police officers? A. I’m not testifying to their lies. I’m testifying to Virginia’s lies.” See Declaration of Sigrid McCawley (“McCawley Decl.”) at Exhibit 1, April 22, 2016 Deposition of Defendant at p. 89-90; 83-84. While Defendant was working with Epstein during the time period when these underage girls were visiting Jeffrey’s home, Defendant claimed to be at the house maybe once in 2005. /d. at p. 84. Yet, according to flight manifests, in that same general time period, Defendant was listed as a passenger at least eleven times either landing in or departing from West Palm Beach, Florida on Jeffrey Epstein’s private plane. See McCawley Decl. at Exhibit 1, April 22, 2016 Depo Tr. at p. 84; see also McCawley Decl. at Composite Exhibit 2, Flight Logs from Jeffrey Epstein’s private planes. Moreover, again according to flight logs, Defendant was on Epstein’s planes over 300 times — including 23 times with Ms. Giuffre when Ms. Giuffre was underage. Yet, quite remarkably, Defendant claimed she “couldn’t recall” even one of those flights. See McCawley Decl. at Exhibit 1, April 22, 2016 Deposition of Defendant at p. 120-122.Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 3 of 10 Defendant even testified that she did not recall having Ms. Giuffre at her London townhome with Prince Andrew. Defendant stuck to this incredible story despite flight logs establishing her traveling to London with Ms. Giuffre and despite a photograph the three — Ms. Giuffre, Prince Andrew and Defendant — all standing together in Defendant’s home. See McCawley Decl. at Exhibit 1, April 22, 2016 Deposition of Defendant at p. 108-111. Defendant’s deposition consisted almost entirely of “I don’t recalls” or “I refuse to answer that question”! and also included a physical outburst that knocked the court reporter’s computer off the conference room table. See McCawley Decl. at Exhibit 1, April 22, 2016 Deposition of Defendant at 207-208. Among the many questions that Defendant refused to answer at her deposition were a number of questions designed to show that Defendant was well aware that, for Epstein, a “massage” was actually a code word sexual activity — 1.e., not a therapeutic massage but rather activity that involved sexual gratification for Epstein. Defendant refused to answer all such questions, asserting that they involved “private adult sexual relationships” which did not “relate in any way” to Ms. Giuffre’s claims. /d. at p. 4. But Defendant’s involvement in such “relationships” with Epstein would show that she knew full well the fate that was in store for Ms. Giuffre when she accepted Defendant’s invitation to come and provide “massages” to Epstein. Defendant admitted that she worked for Epstein from 1992 to 2009. See McCawley Decl. at ' For example, when asked: “Q. Have you ever said to anybody that you recruit girls to take the pressure off you, so you won’t have to have sex with Jeffrey, have you said that? A. You don’t ask me questions like that. First of all, you are trying to trap me, I will not be trapped. You are asking me if I recruit. I told you no. Girls meaning underage, I already said I don’t do that with underage people and as to ask me about a specific conversation I had with language, we talking about almost 17 years ago when this took place. I cannot testify to an actual conversation or language that I used with anybody at any time.” See McCawley Decl. at Exhibit 1, April 22, 2016 Depo Tr. at p. 94-95.Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 4 of 10 Exhibit 1, April 22, 2016 Deposition of Defendant at p. 10-11, 410. As the Court knows, the Palm Beach Police Report demonstrates multiple incidents of “massages” being given by untrained minor children that involved sexual acts. See McCawley Decl. at Exhibit 3, Palm Beach Police Report. Defendant is also identified in that Palm Beach Police Report. See McCawley Decl. at Exhibit 3, Palm Beach Police Report at p. 75-76. And the details of Epstein’s sexual activities with Defendant (for example) are highly relevant to this case, because they will help corroborate Ms. Giuffre’s testimony that, while she was underage, she also engaged in sexual activity of an identical nature with Epstein. To allow Defendant to avoid answering these questions would preclude Ms. Giuffre from getting critical evidence in this case. Consider, for example, Defendant recruiting an eighteen year-old girl to be an “assistant,” bringing that girl to Epstein’s home, telling her she could make more money if she would give Epstein a massage, and then instructing her to give a massage that involved sexual acts. Under Defendant’s theory of discovery, Ms. Giuffre would be precluded from deposing her on that topic because the actions would culminate in “consensual adult sex.” Yet, that scenario would fully validate the pattern of events that occurred with Ms. Giuffre when she was under the age of eighteen. It would obviously show a “modus operandi” by Jeffrey Epstein and Defendant, which is clearly admissible under Fed. R. Evid. 404(b). Moreover, such inquiries are crucial to impeaching the Defendant at trial. During her deposition, Defendant attempted to characterize her work for Epstein as nothing more than a normal job handling hiring for the various mansions. See McCawley Decl. at Exhibit 1, April 22, 2016 Deposition Tr. of Defendant at p. 9-12. Ms. Giuffre should be able to contest that assertion by having Defendant fully answer questions about whether that alleged “job” involvedCase 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 5 of 10 sexual activities, including orchestrating the hiring of females and converting massages into sexual encounters. Defendant attempts to paint the picture that Ms. Giuffre somehow is interested in all sexual relationships that the Defendant may have been involved with. That is not true. Ms. Giuffre has no intention of asking unbridled questions. To be clear, Ms. Giuffre intends to ask Defendant only questions that involve the following very narrow and crucial subject areas: (1) Defendant’s sexual relationship with Epstein from 1992 to 2009 — the time period in which she worked for Jeffrey Epstein and which Epstein (with the assistance of Defendant) was engaging in sexual acts with females under the cover of “massage”; (2) Defendant’s sexual interactions with any person in Epstein’s presence during that time period; (3) Defendant’s sexual activities at Epstein’s residences, including his private island “Little St. Jeff's,” or his aircraft during that time period; (4) Defendant’s sexual activities with identified participants in Epstein’s sexual abuse during that time period; and (5) Defendant’s sexual interactions that occurred during or through what began as a “massage”; and (6) Defendant’s interactions with females to introduce to Jeffrey Epstein for the purpose of performing work, including sexual massages. Defendant claims that such questions are a mere “fishing expedition” without acknowledging the fact that these questions go to critical issues in this case. Other witnesses have testified regarding Defendant’s involvement in recruiting females for sex under the cover of a “massage.” During the investigation of Jeffrey Epstein, certain household staff was deposed. Alfredo Rodriguez, who was Jeffrey Epstein’s household manager, testified that the Defendant frequently stayed in Jeffrey Epstein’s home and assisted with bringing in young girls to act as “masseuses”’ for Jeffrey Epstein. Q. “Okay. Going back to where we started here was, does Ghislaine Maxwell have knowledge of the girls that would come over to Jeffrey Epstein’s house that are inCase 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 6 of 10 roughly the same age group as C. and T. (minor children) and to have a good time as you put it? A. Yes. Q. And what was her involvement and/or knowledge about that? A. She knew what was going on.” See McCawley Decl. at Exhibit 4, Alfredo Rodriguez July 29, 2009 Dep. Tr. at 176-177. See also McCawley Decl. at Exhibit 4, Alfredo Rodriguez July 29, 2009 Depo Tr. at 96-101 (noting that high school age girls come to the home where Jeffrey Epstein and Ms. Maxwell reside). Juan Alessi, another household employee, also testified that young girls were regularly present at Jeffrey Epstein’s home where Ghislaine Maxwell resides. See McCawley Decl. at Exhibit 5, Juan Alessi November 21, 2005 Sworn Statement at p. 15-16, 21. Specifically, Juan Alessi informed the Palm Beach Police Detective as follows: “Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at most.” (emphasis added.) See McCawley Decl. at Exhibit 3, Palm Beach Police Report at p. 57. During Juan Alessi’s November 21, 2005 Sworn Statement taken by the Palm Beach Police Department, Mr. Alessi revealed that girls would come over to give “massages” and he observed Ms. Maxwell going upstairs in the direction of the bedroom quarters. See McCawley Decl. at Exhibit 5, Juan Alessi November 21, 2005 Sworn Statement at 10. He also testified that after the massages, he would clean up sex toys that were kept in “Ms. Maxwell’s closet.” Jd. at 11-13. See also McCawley Decl. at Exhibit 6, Juan Alessi September 8, 2009 Depo Tr. at p. 76- 77. He added that he and his wife were concerned with what was going on at the house (/d. at 14) and that he observed girls at the house, including one named “Virginia.” Jd. at 21. Mr. Rodriguez also testified that Defendant also had naked pictures of girls performing sexual acts on her computer. See McCawley Decl. at Exhibit 7, Alfredo Rodriguez August 7, 2009 Dep. Tr. at 311-312; See also McCawley Decl. at Exhibit 6, Juan Alessi September 8, 2009Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 7 of 10 Depo Tr. at p. 40-41 (“I know she [Maxwell] went out and took pictures in the pool because later on I would see them at the desk or at the house. And nude - 99.9 percent of the time they were topless. They were European girls.”). Q. “Did they appear to be doing any sexual? A. Yes, ma’am. Q. And in these instances were there girls doing sexual things with other girls? A. Yes, ma’am. Q. And I’m still talking about the pictures on Ms. Maxwell’s computer. A. Yes, ma’am.” Upon leaving his employment, Rodriguez testified that Defendant threatened him that he should not tell anyone about what happened at the house: A. “I have to say something. Mrs. Maxwell called me and told me not to ever discuss or contact her again in a threaten(ing) way. Q. When was this? A. Right after I left because I call one of the friends for a job and she told me this, but, you know, I feel intimidated and so I want to keep her out... Q. She made a telephone call to you and what precisely did she say? A. She said I forbid you that you’re going to be — that I will be sorry if I contact any of her friends again...She said something like don’t open your mouth or something like that. I’m a civil humble, I came as an immigrant to service people, and right now you feel a little -’m 55 and I’m afraid. First of all, I don’t have a job, but I’m glad this is on tape because I don’t want nothing to happen to me. This is the way they treat you, better do this and you shut up and don’t talk to nobody and— Q. When you say this is the way they treat, who specifically are you talking about when you say that word they? A. Maxwell. ” See McCawley Decl. at Exhibit 4, Alfredo Rodriguez July 29, 2009 Dep. Tr. at 169 — 172. In sum, at the core of this case are statements made by Ms. Giuffre that she was recruited, by Defendant, to be paid as a masseuse, yet was enticed or coerced into engaging in sexual acts with Epstein and Defendant for money. She has further explained that the recruitment of females through the offer of some legitimate position was the typical way in which Defendant and Epstein lured unsuspecting females to the house before converting the relationship into a sexualCase 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 8 of 10 one. Ms. Giuffre has described the frequency of these “massages”, the sexual tendencies of the participants, the manner in which the massages became sexual in nature, and Defendant’s role at each stage. In response, Defendant has called Ms. Giuffre’s entire account “untrue” and “obvious lies.” Defendant has instead tried to portray her role as nothing more than an Epstein employee performing typical household management duties. Any personal knowledge Defendant has of Epstein’s sexual tendencies, habits, and use of massage for sex is entirely relevant to either corroborate Ms. Giuffre’s account. Likewise, Defendant’s participation in any sexual acts with Epstein, in his presence, on his properties, using his mode of converting massages into sex, or with females will directly corroborate Ms. Giuffre’s account. On the other hand, without access to the answers to these inquiries, Ms. Giuffre will be unable to expose the bias of Defendant, unable to thoroughly cross-examine Defendant’s position that she was just a lowly employee, and most importantly unable to demonstrate through the Defendant’s own admissions that Ms. Giuffre’s statements about Epstein and Defendant were absolutely true — and not “obvious lies.” Finally, Defendant fails to recognize that, for the discovery purposes at issue here, relevance “is an extremely broad concept.” Am. Fed'n of Musicians of the United States & Canada v. Sony Music Entm't, Inc., No. 15CV05249GBDBCM, 2016 WL 2609307, at *3 (S.D.N.Y. Apr. 29, 2016). And once relevance is shown, “the party resisting discovery bears the burden of demonstrating that, despite the broad and liberal construction afforded the federal discovery rules, the requests are irrelevant, or are overly broad, burdensome, or oppressive.” Jd. Here, the requests are not “overly broad” as Ms. Giuffre’s specific explanations of the targets of her questions make clear. Moreover, answering the questions is not “oppressive,” particularly given the fact that Defendant has placed a// substantive aspects of the Deposition under seal. OfCase 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 9 of 10 course, once Defendant answers the question — and her answers are placed under seal — the parties can file any further motions that may be required to determine whether the answers may be introduced at trial. CONCLUSION Defendant should be ordered to answer questions regarding sexual activity connected with Epstein’s sexual abuse and sexual trafficking organization as specifically identified above Dated: May 11, 2016 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202? ° This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation.Case 1:15-cv-07433-LAP Document 1320-6 Filed 01/03/24 Page 10 of 10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 11th day of May, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10°" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley 10Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 1 of 9 EXHIBIT 4 Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 2 of 9 Page 1 -b. UNITED STATES DISTRICT COURT : SOUTHERN DISTRICT OF FLORIDA z 3 JANE DOE NO. 2, Case No: 08-CV-80119 4 Plaintiff, 5 Vs 6 JEFFREY EPSTEIN, 7 Defendant. 8 JANE DOE NO. 3, Case NO: 08-CV-80232 9 Plaintiff, 10 Vs 11 JEFFREY EPSTEIN, 12 Defendant. 13 JANE DOE NO. 4, Case No: 08-CV-80380 14 Plaintifé, 15 Vs. 16 JEFFREY EPSTEIN, 17 Defendant. 18 19 JANE DOE NO. 5, Case No: 08-CV-80381 20 Plaintiff, Buk. Vs 22 JEFFREY EPSTEIN, 23 Defendant. 24 25 Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000247 GIUFFRE000935Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 3 of 9 Page 2 Page 4 1 JANE DOE NO, 6, Case No: 08-Cv-80994 1 VEIDEOTAPED 2 Plamufl, 2 DEPOSITION 3 V5 3 of 4 JEFFREY EPSTEIN, 4 ALFREDO RODRIGUEZ 5 Defendant s F _f 6 taken on behalf of the Plaintiffs pursuant 7 waRe-N of Taking Deposit: D Ti JANE DOE NO, 7, Case No. 08-CV-80993 8 SRE NOES ei pon Cones Tale) 7 g --< a Praintiff, 10 APPEARANCES: i . NE MERMELSTEIN & HOROWITZ, P.A, 12 BY: STUART MERMELSTEIN, ESQ. 10 JEFFREY'EPSTEIN, 18205 Biscayne Boulevard 13 Suite 2218 1 beferitant, “a Miami, Florida 33160 12 cA, Case No! 08-CV-BOB!! 14 ee for Jane Doe 2, 3, 4, 5, 13 __—~Plaintiff, ¥ , and 7. 14 Vs 1S JEFFREY EPSTEIN, 16 ROTHSTEIN ROSENFELDT ADLER 16 = Defendant. . BY: BRAD J, EDWARDS, ESQ., and } v7 CARA HOLMES, ESQ. 17 — Las Olas City Centre JANE DOE, Case No: G8-CV-80893 18 Suite 1650 19 401 East Las Olas Boulevard Plaintiff, 9 Fort Lauderdale, Florida 33301 19 Attorney for Jane Doe and E.W. Vs 20 And LM. 20 21 JEFFREY EPSTEIN, PODHURST ORSECK ai 22 BY: KATHERINE W, EZELL Defendant. 25 West Flagler Street 22 — } 23 Suite 800 23 Miami, Florida 33130 24 24 Attorney for Jane Doe 101 and 102. 25 25 Page 3 Page 5 1 JANE DOE NO, TI, Case No: D8-CV-80469 2 Plaintiff, APPEARANCES: 2 ; LEOPOLD-KUVIN : che ee ADAM 3, LANGINO, ESQ. BUT 4 2925 PGA Boulevard | Suite 200 6 5 Palm Beach Gardens, Florida 33410 JANE DOE NO. 101, Case No: 09-CV-80591 Attorney for B.B. 7 6 Plaintiff, 7? RICHARD WILLITS, ESQ. 2290 10th Avenue North Vs 8 Suite 404 8 Lake Worth, Florida 33461 JEFFREY EPSTEIN, Fr SEY IS ETN, 10 BURMAN, CRITTON, LUTTIER & Defendant. il COLEMAN, LLP it BY: ROBERT CRITTON, ESQ. 12 JANE DOE NO. 102, Case No; 09-CV-B0656 12 515 North Flagler Deve 13 Plaintiff, Suite 400 14 Vs 13 West Palm Beach, Flarida 33401 15 JEFFREY EPSTEIN, Attorney for Jeffrey Epstein. 16 Defendant. = Sa 16 7 ALSO PRESENT: 18 7 19 JOE LANGSAM, VIDEOGRAPHER 20 1031 Ives Dairy Road 18 Suite 228 13 21 North Miami, Florida 20 - July 29, 2008 iu 22 11:00 a.m. to 5:30 p,m. 2 23 23 24 24 2s 5 2 (Pages 2 to S) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000248 GIUFFRE000936Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 4 of 9 Page 94 Page 96 1 A. Idon't remember, sir. 3 Q. Okay. Do you recall on any occasion who 2 Q. The next page is a message in the upper 2 would travel with him to the Virgin Islands? 3 left dated January 13, 2005, from C.W. Correct? 3 MR, CRITTON: Form. 4 A. Yes, 4 THE WITNESS: No, sir. 5 Q. That's the same C. that we've been 5 BY MR. MERMELSTEIN: 6 talking about. Correct? 6 Q. I think we were talking about the money 7 A. Yes. 7 before, the household account, sometimes you gave 8 Q. That was at 7:30 p.m. Correct? 8 gifts? 9 A. Yes. 9 A. Yes, I was told to buy some gifts. 10 Q. And you don't recall what that particular 10 Q. For whom? 11 call was about. Right? 11 A. For the quests, 12 A. No, sir. 12 Q, Okay. And what kind of gifts? 13 Q. The message dated January 20, 2005, from | 13 A. Shoes, sweaters, clothes. 14 Maria. Do you see that on the bottom right? 14 Q. So were you instructed to buy something 15 A. Yes. 15 in particular at a particular store? 16 Q, Do you know who that is? 16 A. They would go to the store, if they like 17 A. I think I have a different page. 17, something I will go after and pay them and 18 Q. You're a little ahead of me. January 20, 18 retrieve it. 19 2005. 19 Q. Okay. So would this be a girl who was 20 MR. CRITTON: I think that's page 31. 20 staying at the house? 21 THE WITNESS: I don't remember who she 21 A. Yes, 22 was, sir. 22 Q, Okay. This was one of the girls who 23. BY MR. MERMELSTEIN: 23 travelled with Mr. Epstein to Palm Beach. 24 Q. You don't recall what that message was 24 Correct? 25 about? 25 A, Yes, Page 95 Page 97 1 A. No, sit. 1 Q. And so Mr. Epstein would instruct you to 2 Q. What about the next page there is a 2 go shopping with this girl? 3 message that Eva called? 3 A. Yes. 4 A. Yes. 4 Q. And instructed you to pay for whatever it 5 Q. Dated January 21, 2005? 5 is she wanted to buy? 6 A. Yes. 6 A. Yes. 7 Q. Do you know who Eva is? 7 Q. Was there a price limit or anything of 8 A. Yes. 8 that nature? 9 Q. Who is Eva? 9 A. No, sir. 10 A. The assistant comptroller from the New 10 Q. So when the girl decided what she wanted 11 York office. 11 you would -- 12 Q, Do you remember her last name? 12 A. T would write them a check. 13 A. Polish last name I guess. She was 13 Q. In that instance you would pay by check? 14 Russian. She is Russian actually, 14 A, Yes, 15 Q. Did you ever travel to any other 15 Q. Any other instances where you gave gifts 16 residences that Mr. Epstein had? 16 to girls at the instruction of Mr. Epstein? 17 A. No. 17 A, No. twas just totdyou-know, wher they—_—_$_—— 18 Q. Are you aware he had a residence in the 18 told me I will buy the item. 19 Virgin Islands? 19 Q. I'm sorry? 20 MR. CRITTON: Form. 20 A. You know, when I was told to purchase 21 THE WITNESS: Yes. 21 this Item for them, you know, I will do that, but 22 BY MR. MERMELSTEIN: 22 not on any other occasions. 23 Q. And would he sometimes travel to that 23 Q. What do you mean not in any locations? 24 residence from Palm Beach? 24 A. Any other occasions. 25 A. Yes, 25 Q. Not any other occasions. Okay. Did you 25 (Pages 94 to 97) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000271 GIUFFRE000959Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 5 of 9 17 were bringing the flowers to. Is that correct? 4 A. Yes, Q. Had you seen this girl before at the El Brillo Way property? . Yes, sir. You had seen her a number of times? Yes, sir. Do you recall her name? I don't remember her name, sir. > POPO Page 98 Page 100 1 ever buy flowers for a girl? 1 Q. Now, you said you never went inside the 2 A. Yes, sir. 2 theatre? 3 Q. Tell me about that. 3 A. No, sit. 4 A. Iwas told to buy flowers and roses for a 4 Q. Okay. How did you get to the flower 5 girl performing in high school. S store? 6 Q. Which girl was that? 6 A. I called the girl to her cell and she 7 A. I don't remember the name, sir. 7 will come to the back door and I give her the 8 Q. What was Mr. Epstein's relationship to 8 flowers. 9 this girl? 9 Q. Was anyone else around at the time? 10 MR. CRITTON: Form. 10 A. No, sir. 11 THE WITNESS: I think she was an 11 Q. And you mentioned this was a girl you had 12 acquaintance, friend, 12 seen before? 13. BY MR. MERMELSTEIN: 13 A. Yes. 14 Q. She was a friend? 14 Q. Was this girl who had come to give 15 A. Yes, sir. 15 massages to Mr. Epstein? 16 Q. Now, she was performing at the high 16 MR. CRITTON: Form. 17 school in what capacity? 17 THE WITNESS: I don't know if she was 18 A. There was like a — like a play in the 18 doing massages but she was at the house. 19 graduation for high school. 19 BY MR. MERMELSTEIN: 20 Q. A play for graduation? 20 Q. What would she have been there for? 21 A. Yes, in the high schoo! theatre there was 21 A. To visit him. 22 some kind of performance, 22 Q. This was a high school girl who was 23 Q. Was it like a theatre production? 23 coming to visit Mr. Epstein at the house? 24 A. Yeah, something like that. I didn't go 24 A. She came to the house, I open the door 25 inside so 1 didn't know what was going on inside. 25 and left, you know. Page 99 Page 101 1 Q. Why do you say it was for graduation? 1 Q. Did you take her to the kitchen like you 2 A. Because everybody was the graduation 2. did -- 3 outside, there were parents, there were a lot of 3 A. Yes. 4 people at the school. 4 Q. So you brought her to the kitchen just 5 Q. Okay. A lot of high schools have theatre 5 like you did for the girls who gave him massages. 6 production companies and they put on plays. 6 Correct? 7 Correct? 7 A. Yes, sir. 8 MR. CRITTON: Form. 8 Q, Did you ever pay her? 9 THE WITNESS: It was towards the end of 9 A. I don't remember, sir, but probably 1 10 the year. Well, I think I overheard that 10 did. 11 there was a graduation performance of some 11 MR. CRITTON: Form, move to strike, 12 kind. 12 speculation. 13. BY MR. MERMELSTEIN: 13. BY MR. MERMELSTEIN: 14 Q. But you didn't go in so you don't know? 14 Q. Why do you say you probably did? 15 A. No, sir. 15 A. Because I was the only one paying -- 16 Q. But this was a high school student you 16 well, not the only one but, you know, but chances particular instance that I gave her money. Q. Is it fair to say that the girls who came to the Palm Beach residence, these are not the girls who are staying there, the girls who came -- were there to give massages. Correct? MR. CRITTON: Form. THE WITNESS: Yes. BY MR. MERMELSTEIN: 17 —are Pai ter but Hon tremember-that——j——— 26 (Pages 98 fo 101) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000272 GIUFFRE00096 1Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 6 of 9 Page 166 Page 168 1 written down anywhere? 1 for now we'll call it a massage -- as well as 2 A. No. 2 anybody who brought that person over to the house, 3 Q. It's my understanding that C. and T. 3 they would both get paid cash, Are you familiar 4 either came to his house alone to visit with Mr. 4 with that? 5 Epstein or brought other girls in their age group 5 MR. CRITTON: Form, 6 to Mr. Epstein. 6 THE WITNESS: No. 7 Were you familiar with that type of 7 BY MR. EDWARDS: 8 recruitment process of girls bringing other girls? 8 Q. If C. brought another girl over to the 9 MR. CRITTON: Form, 9 house and C. stayed downstairs but this other girl 10 THE WITNESS: Yes. 10 went upstairs with Mr. Epstein, which one would 11 BY MR, EDWARDS: 11 you pay? 12 Q. Can you tell me more about what you know | 12 A. I don't know because I was told who to 13. about girls bringing other girls that are 13 pay. 14 relatively the same age to come to Jeffrey 14 Q. And Sarah Kellen always told you? 15 Epstein's house and to use your words, have a good | 15 A. Sarah tald me pay so and so. 16 time? 16 Q. So if we were going to ask anybody else 17 MR. CRITTON: Form. 17 about the exact method in terms of who would get 18 THE WITNESS: It's hard to know who they 18 paid and for what, who would the people be? I 19 knew. But I think that was -- they feel 19 mean, other than Mr. Epstein who else could we ask 20 better themselves when they're in a group 20 these questions? 21 than going by themselves, but I don't know 21 A. Sarah. 22 somebody recruiting. 22 Q. Sarah Kellen? 23. BY MR. EDWARDS: 23 A. Yes. 24 Q. Okay. And you've talked about, at least 24 Q. She would know this? 25 referred to yourself I believe to the police and 25 A. Yes. Page 167 Page 169 1 as well today as a human ATM machine. Right? 1 Q. What about Ghislaine Maxwell? 2 MR. CRITTON: Form. 2 MR, CRITTON: Form. 3 THE WITNESS: Something like that. I was 3 THE WITNESS: You're talking about the 4 supposed to carry cash at all times. 4 boss. I don't know, 5 BY MR. EDWARDS: 5 BY MR, EDWARDS: 6 Q. One of the primary reasons why you 6 Q. To your knowledge was Ghislaine Maxwell 7 carried cash was to pay the girls in this age 7 aware of these girls that are in the age group of 8 group of C. and T. for whatever happened at the 8 C. and T, coming to Jeffrey Epstein's house to 9 house. Right? 9 have a good time? 10 MR. CRITTON: Form, 10 MR, CRITTON: Form. 11 THE WITNESS: Yes. 11 THE WITNESS: I have to say something, 12 BY MR. EDWARDS: 12 Mrs. Maxwell called me and told me not to 13 Q. That's a fair statement. Right? 13 ever discuss or contact her again in a 14 MR. CRITTON: Form. 14 threaten way. 15 THE WITNESS: Yes. 15 BY MR. EDWARDS: 16 BY MR, EDWARDS; 16 Q. When was this? i : 7 : 18 example, would bring somebody else to the house, | 18 the friends for a job and she told me this, but, 19 did you pay C. as well as whomever she brought to |19 you know, I feel intimidated and so I want to keep 20 the house, pay them both? 20 her out. 21 A. No, I pay only one person. 21 Q. What exactly did she say? First of all, 22 Q. Okay. My understanding, and tell me if 22 was this a telephone call? 23 this is wrong or you can corroborate this, is that 23 A. Yes, she was in New York, 24 Mr. Epstein would pay the girl that was actually 24 Q. She called you on your cell phone? 25 performing whatever was happening in the room -- | 25 A. Yes. 43 (Pages 166 to 169) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000289 GIUFFREO00978Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 7 of 9 Page 170 Page 172 1 Q. Is this the cell phone that was issued to 1 precisely did she say? 2 you by Mr. Epstein? 2 A. She said I forbid you that you're going 3 A. No, it was my personal phone. I was 3. to be -- that I will be sorry if I contact any of 4 already -- 4 her friends again. 5 Q. Gone? 5 Q. Okay. Other than you will be sorry if 6 A. Yeah, this is three, four months down the 6 you contact any of my friends again did she say 7 road. 7 anything else about what you know about Mr. 8 Q. So if you left in -- 8 Epstein and/or what goes on at his house? 9 A. February, March -- it was May or June, 9 A, She said something like don't open your 10 Q. Of 2005? 10 mouth or something like that. But you have to 11 A. Yes. 11 understand, I'm a civil humble, I came as an 12 Q. And you got a call from Ghislaine Maxwell 12 immigrant to service people, and right now you 13 out of the blue? 13 feel a little -- I'm 55 and I'm afraid. First of 14 A. Yes. 14 all, I don't have a job, but I'm glad this is on 15 Q. And do you know what prompted that 15 tape because I don't want nothing to happen to me. 16 telephone call? 16 This is the way they treat you, better do this and 17 A. Because I contact somebody in New York to |17 you shut up and don't talk to nobody and -- 18 geta job. 18 Q. When you say this is the way they treat, 19 Q. Who was that person? 19 who specifically are you talking about when you 20 A. I contact Jean-Luc and I contact Eva, the 20 say the word they? 21 Swedish girl, she used to be very good friends 21 A. Maxwell. 22 with Mr. Epstein because she asked me she need 22 Q. And usually when you say the word they, 23 somebody in New York. 23 you're not only talking about one person 24 Q, What does Eva do? 24 A. Wealthy people. 25 A. Eva was a model many years ago and he 25 Q. Are you also putting Jeffrey Epstein in Page 171 Page 173 1 married -- Eva is the mother of the girl who was 1 that category? 2 on the wall. 2 MR. CRITTON: Form. 3 Q. Whois on the wall of Mr. Epstein's 3 THE WITNESS: I didn't talk to him 4 house? 4 directly most of the time. 5 A. Yeah. 5 BY MR, EDWARDS: 6 Q. Allright. There is a younger girl model 6 Q. What's the reason why if you were his 7 that's on the wall of Mr. Epstein’s house and this 7 head of security that you wouldn't have more 8 lady Eva is her mother? 8 direct contact with him? Why is that? 9 A. Yes. 9 MR. CRITTON: Form, 10 Q. And at some point in time you called her 10 THE WITNESS: He wanted that way, you 11 in New York to get a job? 11 know, so, yeah, I have to talk to Sarah, 12 A. That's right. 12 Sarah is not available talk to Lesley in New 13 Q. And you also called Jean-Luc Bernell? 13 York. He didn't want to be disturbed. 14 That's his name. Right? 14 BY MR. EDWARDS: 15 A. Jean-Luc, yeah, I don't remember his last 15 Q. Even while you were in the same house 16 name. 16 with him he still had other people you could talk 17 Q. Does that sound familiar to you, Jean-Luc‘ [17 to directly but he was not one of them? 18 Berneil? 18 A. Yeah. 19 A. Yeah. 19 Q. When you were fired you were not fired 20 Q. What did Eva and/or Jean-Luc say about 20. directly by him? 21 employing you? 21 A. No. 22 A. No, they said they're going to find out 22 Q. It was through somebody else? 23 and obviously the first thing they did was talk to 23 A. Ms. Maxwell. 24 Mrs. Maxwell, 24 Q. Okay. But it was for upsetting him for 25 Q. She made a telephone call to you and what | 25 _ taking the wrong car? 44 (Pages 170 to 173) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000290 GIUFFREO00979Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 8 of 9 Page 174 Page 176 1 A. Yes. 1 this. Because I went through -- the first 2 Q. Okay. Ever since this communication that 2 time I went to the deposition I was in Palm 3 Ms. Maxwell made to you where she called you 3 Beach and I did my duty, I mean, I tell what 4 sometime in May or June of 2005, and have you felt | 4 I know, but now I know there is more 5 threatened? 5 digging, all I want s this to be to get on 6 A. Yes. 6 with my normal life and stuff. 7 MR, CRITTON: Form. 7 BY MR. EDWARDS: 8 BY MR. EDWARDS: 8 Q. So when you come here today to testify, 9 Q. Have you felt reluctant to come forward 9 your main objective is to get back to your normal 10 and give truthful, honest, and full disclosure of 10 life and get out of the spotlight of this case, 11 all information that you know about this case? 11 Yes? 12 MR, CRITTON; Form, 12 A. Yes. 13 THE WITNESS: I said this off the record 13 Q. And in doing so have you held back some 14 but I will say it on the record, being in 14 of the details that you know about that happened iS the Epstein case for me resulted in two 15__ in this case to remove yourself from the 16 years I have -- I won't bring the names but 16 spotlight? 17 1 was in the third interview to get hired as 17 MR. CRITTON: Form. 18 a household manager in Palm Beach and they | 18 THE WITNESS: No, Sir. 19 told me you are the Jeffrey Epstein guy. 19 BY MR. EDWARDS: 20 Not in the sense I did something wrong 20 Q. Okay. Have you ever talked to Ghislaine 21 because of the scandal, so they shun the job 21 Maxwell after that telephone call where she called 22 away from me. And so I was afraid that -- 22 you and you felt threatened? 23 this is very powerful people and one phone 23 A. No. 24 call and you finish, so I'm the little guy. 24 Q. Okay. So going back to where we started 25 Even I'm wearing a tie I'm a -- I'm talking 25 here was, does Ghislaine Maxwell have knowledge of Page 175 Page 177 1 from my heart. This is the way it is. 1 the girls that would come over to Jeffrey 2 BY MR. EDWARDS: 2 Epstein's house that are in roughly the same age 3 Q. I feel for you, I'm sorry that you have 3 group as C. and T. and to have a good time as you 4 to be in this position. 4 putit? 5 MR. CRITTON: Move to strike this. 5 MR, CRITTON: Form, 6 BY MR. EDWARDS: 6 THE WITNESS: Yes. 7 Q. Well, when you applied for these jobs and 7 BY MR. EDWARDS: 8 they turned you down and gave you the reason that | 8 Q. And what was her involvement and/or 9 you're the person involved in the Jeffrey Epstein 9 knowledge about that? 10 scandal, was it that they are associated or 10 MR, CRITTON: Form, 11 friends with Jeffrey Epstein or is it that you 11 THE WITNESS: She knew what was going on, 12 have information and you have this confidentiality {12 BY MR. EDWARDS: 13 but you're revealing some certain information that 13 Q. You referred to her at one point in time 14 Mr. Epstein would not like? 14 as Jeffrey Epstein's companion. But then later on 15 MR. CRITTON: Form. 15 you Said that if she flew she flew on a different 16 THE WITNESS: Both. 16 airplane and oftentimes or sometimes she slept in 17 BY MR. EDWARDS: 17 a Offerent bed trom Mr. Epstein, Dic that seen 7—__——£— 18 Q. Both? 18 unusual to you? 19 A. Both. 19 MR. CRITTON: Form, 20 Q. And since then given what you just told 20 THE WITNESS: It was odd but, I mean, and 21 us about these people being very powerful, are you | 21 again, everything is odd in Palm Beach, 22 afraid for your life given the fact that you're 22 BY MR. EDWARDS: 23 involved to some extent in this case? 23 Q, Okay, I don't mean to laugh, 24 MR, CRITTON: Form. 24 A. Mr, Epstein fly to Jet Aviation, she fly 25 THE WITNESS: J just start thinking about 25 to Galaxy Aviation, but they never flew the same 45 (Pages 174 to 177) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000291 GIUFFREOO0980Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 9 of 9 Page 266 Page 268 1 BY MR, LANGINO: 1 THE STATE OF FLORIDA, ) 2 Q. Are you currently in fear of Mr. Epstein? 2 COUNTY OF DADE. ) 3 A. Not at this particular moment but it's 3 4 something I have to be worry about, yes. 4 ‘ | 5 Q. Are you personally afraid of criminal 5 I, the undersigned authority, certify 6 prosecution? 6 that ALFREDO RODRIGUEZ personally appeared before 7 A. No. 7 meon the 29th day of July, 2009 and was duly 8 Q. Do you believe that you did anything ; SWOMT- 9 illegal? x % 10 WITNESS my hand and official seal this A Bleaay, 11 ist day of July, 2009 rl MR. LANGINO: I have no further 3 wey Sans Se 12 questions. Thank you. 13 13 MR. CRITTON: We're going to break in 14 14 about 15 minutes. Do you want to start and 15 15 go for 15 minutes or do you want to -- it's MICHELLE PAYNE, Court Reporter ig bp tor yin 16 Notary Public - State of Florida 17 MS. EZELL: I'll start. 17 18 MR. WILLITS: When are we going to quit, 18 19 folks? 19 20 MR. CRITTON: In 15 minutes. 20 21 THE VIDEOGRAPHER: Might as well change | 2i 22 tapes. 22 23 MR. EDWARDS: Bob has to get back so 23 24 we've agreed we're going to come back some | 24 25 other time. 25 Page 267 Page: 269 1 MR. WILLITS: Why don't we just stop now? | } CERTIFICATE 2 MS. EZELL: Okay. The State OF Florida, +?) 3 MR. EDWARDS: Rather than you start. ; County OF Davie- 4 MS. EZELL: Yeah, I won't get very far. 5 I, MICHELLE PAYNE, Court Reporter and 5 MR. EDWARDS: Sorry to do this with you, Notary Pulic in and for the State. of Florida at 6 we didn't finish. Omnia auruigecticany yesorsthe videotaped 7 MR, CRITTON: So we're stopped? 7 depositton of ALFREDO RODRIGUEZ; that a review of 8 MR. EDWARDS: We're stopped. g: keedeeis anaowiheet wilt. 9 THE VIDEOGRAPHER: Off the record. inclusive, are a true and correct transcription of 10 (Thereupon, the videotaped deposition was |g eee eee seotaney 11 adjourned at 5:30 p.m.) deposition was taken at the time and place 11 hereinabo' t forth and that the taki f Said 12 re Mureuenteghaan tak poteawa salted 13 12 as hereinabove set out. 13 I further certify that Lam not an 14 attorney or counsel of any of the parties, nor am 15 14 1a relative or employee of any attorney or 16 counsel of party connected with the acbon, nor am 15. I financially interested in the action. if . Souci some his te any reproduction of 17 the same by any means unless under the direct 19 control and/or direction of the certifying 18 % * 19 re ATED this 3ist day of July, 2009. 20 2 fe : MICHELLE PAYNE, Court Reporter 22 24 23 24 25 25 68 (Pages 266 to 269) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000314 GIUFFREO01 003Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 1 of 12 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS V. Ghislaine Maxwell, Defendant. PLAINTIFF’S NON-REDACTED MOTION FOR LEAVE TO SERVE THREE DEPOSITION SUBPOENAS BY MEANS OTHER THAN PERSONAL SERVICE Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Motion for Leave to Serve Three Deposition Subpoenas by Means Other Than Personal Service. The three persons to be subpoenaed — Jeffrey Epstein, Sarah Kellen and Nadia Marcinkova — were each involved in the sexual abuse and sexual trafficking at issue in this case. It appears that all three of them have evaded attempts to personally serve them (and two of the persons, Epstein and Kellen, have attorneys who have not been authorized by their clients to accept service). Ms. Giuffre seeks leave to provide service by several alternative means that are designed to assure actual notice is provided to these persons. See Declaration of Sigrid McCawley (“McCawley Decl.’’) at Composite Exhibit 1, Subpoenas for Jeffrey Epstein, Sarah Kellen (aka Sarah Kensington and Sarah Vickers) and Nadia Marcinkova. This Court has repeatedly held that Fed. R. Civ. P. 45 permits alternative service in appropriate circumstances, and this case presents such circumstances. Accordingly, the Court should grant Ms. Giuffre leave to serve deposition subpoenas by alternative means.Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 2 of 12 BACKGROUND At the heart of this case lies Ms. Giuffre’s allegations that that she was sexually abused by Jeffrey Epstein and the Defendant. Ms. Giuffre has also alleged that Epstein and the Defendant were aided by others who played keys roles in the sex trafficking organization, including Sarah Kellen and Nadia Marcinkova. Defendant has called Ms. Giuffre a “liar” and Ms. Giuffre is now in the process of assembling testimony and evidence to prove the truth of her allegations. Apart from the Defendant in this case, Jeffrey Epstein is the most important person for Ms. Giuffre to depose. It was Epstein who gave the directions to Maxwell to recruit Ms. Giuffre and bring her to Epstein’s mansions to be sexually abused. At several points during her recent deposition, Ms. Maxwell refused to answer Ms. Giuffre’s questions about Epstein, but instead told her she should go ask Epstein about the subject. See, e.g., Tr. of Depo. of Defendant (Apr. 22, 2016) at 100 (“Q: ... [W]as it Jeffrey’s preference to start a massage with sex? ... A: I think you should ask that question of Jeffrey.”); id. at 146-47 (“Q: So would [Ms. Giuffre] be brought on trips that were for the purpose of work and decorating the house? A: Like I said, I never worked with her but you would have to ask Jeffrey what he brought her on the trip for.”’); id. at 389-90 (“Q: Does [Epstein]... have any knowledge of any illegal activity that you’ ve conducted? ... A: If you want to ask Jeffrey questions about me, you would have to ask him.”). See McCawley Decl. at Exhibit 2. Because of Epstein’s importance to this case, Ms. Giuffre has diligently tried to personally serve Epstein with a subpoena for his deposition. Epstein, however, appears to have no interest in answering questions under oath about the scope of his sex trafficking organization and he has not authorized his lawyer to accept service of the subpoena. On March 7, 2016, Ms.Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 3 of 12 Giuffre’s counsel contacted counsel for Epstein to seek agreement that he would accept service of the subpoena in this matter. See McCawley Decl. at Composite Exhibit 3, Electronic Correspondence to Attorney Marty Weinberg. Ms. Giuffre was unable to obtain that agreement so she retained an investigative company to attempt to locate Epstein for purposes of personal service’. As explained in the attached affidavit, the Alpha Group Investigators commenced efforts to personally serve Epstein on April 26, 2016. See McCawley Decl. at Exhibit 4 Affidavit of Douglas G. Mercer, Chief Investigator Alpha Group. Those efforts have continued for weeks, and included over sixteen (16) attempts to personally serve Epstein, including as recently as May 18, 2016, at which time the investigator affixed the subpoena to the front door of Epstein’s residence and mailed copies of the subpoena to both of his New York addresses along with a witness check. Counsel for Ms. Giuffre also provided a copy of the subpoena to Marty Weinberg, Epstein’s attorney. Jeffrey Epstein is not the only key witness who has been evading Ms. Giuffre’s efforts to depose them. The next echelon in the sex trafficking organization below Epstein and the Defendant includes Sarah Kellen and Nadia Marcinkova. Ms. Giuffre alleges that they were heavily involved in the sex trafficking. Both Kellen and Marcinkova appear repeatedly on the flight logs of Jeffrey Epstein’s aircraft. The U.S. Attorney’s Office for the Southern District of Florida specifically identified both Kellen and Marcinkova as among four named “potential co- conspirators of Epstein” in the non-prosecution agreement it executed with Epstein as part of his guilty plea to Florida state sex offense charges. See Non-Prosecution Agreement, /n re: Investigation of Jeffrey Epstein at 7. Additionally, both Kellen and Marcinkova previously ' As recently as today, Ms. Giuffre’s counsel continues to attempt to negotiate acceptance of service of the subpoena for Mr. Epstein, which now includes a request that his deposition take place in the U.S. Virgin Islands but has still not received an agreement to accept service. See McCawley Decl. at Composite Exhibit 3, Correspondence with Marty Weinberg, counsel for Jeffrey Epstein. 3Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 4 of 12 invoked their Sth amendment privileges when asked about their involvement in Epstein and Defendant’s sex trafficking ring. At her recent deposition, Defendant appeared to be well aware of the fact that Epstein had potential co-conspirators. See,e.g., Tr. of Depo. of Defendant (Apr. 22, 2016) at 49 (“Q: Are you aware that Sarah Kellen was . . . named as a co-conspirator in the case involving Jeffrey Epstein? ... A: 1am aware.”). See McCawley Decl. at Exhibit 2. As with Epstein, however, Kellen and Marcinkova appear to be evading efforts to serve them. On March 31, 2016, Ms. Giuffre’s counsel reached out to Sarah Kellen’s counsel to seek agreement that she would accept service of the subpoena in this matter. See McCawley Decl. at Exhibit 5, Electronic Correspondence with Bruce Reinhart, of McDonald Hopkins, LLP in West Palm Beach, Florida. Mr. Reinhart represented that Ms. Kellen refused to allow her counsel to accept service of the subpoena, so Ms. Giuffre was forced to commence the efforts to attempt to personally serve her with the subpoena. As explained in the attached affidavit, the Alpha Group Investigators commenced efforts to personally serve Kellen on April 26, 2016. See McCawley Decl. at 4, Affidavit of Douglas G. Mercer, Chief Investigator Alpha Group. Those efforts have continued with over nineteen (19) attempts at service and concluded as recently as May 18, 2016, at which time the investigator affixed the subpoena to the front door of Kellen’s residence and mailed copies of the subpoena to both of her New York addresses. Ms. Giuffre’s counsel also provided a copy of the subpoena to Kellen’s attorney. Marcinkova has also been evading service. Ms. Giuffre has had her investigators make efforts to attempt to personally serve Marcinkova at her New York residence, and also made efforts to try to personally serve her while on a trip to California, but has been unable to obtain personal service. Ms. Giuffre’s investigators made over ten (10) attempts to personally serve Marcinkova. See McCawley Decl. at Exhibit 4, Affidavit of Douglas G. Mercer, ChiefCase 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 5 of 12 Investigator Alpha Group. In addition, counsel for Ms. Giuffre reached out to Ms. Marcinkova’s former counsel but he indicated that he could not accept service as he no longer represents her. See McCawley Decl. at Exhibit 6, Electronic Correspondence with Jack Goldberger, at Atterbury, Goldberger & Weiss, P.A., in West Palm Beach, Florida. In other litigation relating to Jeffrey Epstein, both Marcinkova and Kellen asserted their fifth amendment rights when asked questions about Defendant’s recruitment of underage girls. Q Do you know Ghislaine Maxwell? A Fifth. Q Is that somebody who helped Jeffrey Epstein to devise the scheme to allow him access to various and a variety of underage minor females? A Fifth. Q Is Sarah Kellen somebody that was also involved in the planning of this scheme to gain access to underage minor females? A Fifth. See McCawley Decl. at Exhibit 7, Nadia Marcinkova April 13, 2010 Dep. Tr. at p. 29-30 (GIUFFRE001171-1172) Q Isn’t it true that yourself, Ghislaine Maxwell and Sarah Kellen had access to a master of list of underage minor females names and phone numbers so they could be called for the purpose of coming to Jeffrey Epstein’s house to be sexually molested? A Fifth. See McCawley Decl. at Exhibit 7, Nadia Marcinkova April 13, 2010 Dep. Tr. at p. 33-34 (GIUFFRE001173) Q Do you know Jane Doe-102 [Virginia Giuffre]? A Fifth. See McCawley Decl. at Exhibit 7, Nadia Marcinkova April 13, 2010 Dep. Tr. at p. 47-48 (GIUFFRE001176)Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 6 of 12 Q Are you aware of Jeffrey Epstein and Ghislaine Maxwell’s sexual interaction with Jane Doe-102 when she was a minor? Q This is one of many underage minor females that was trafficked basically around the globe to be sexually exploited and abused; is that correct? A Fifth. Q Was that typical of Jeffrey Epstein and Ghislaine Maxwell to sexually abuse minors on Jeffrey Epstein’s airplane? A Fifth. Q And also typical of Ghislaine Maxwell and Jeffrey Epstein to prostitute or pimp out underage minors to friends? A Fifth. See McCawley Decl. at Exhibit 7, Nadia Marcinkova April 13, 2010 Dep. Tr. at p. 47-48 (GIUFFRE001176) Q Ghislaine Maxwell is somebody who you know to be bi-sexual, true? A Fifth. Q You know that Ghislaine Maxwell engaged in sexual acts with underage minor females, true? A Fifth. See McCawley Decl. at Exhibit 7, Nadia Marcinkova April 13, 2010 Dep. Tr. at p. 58-59 (GIUFFRE001179) Q. Did Ghislaine Maxwell introduce you to Jeffrey Epstein for the first time? THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. See McCawley Decl. at Exhibit 8, Sarah Kellen March 24, 2010 Dep. Tr. p.21 (GIUFFRE001676) Q. All right. All right. Ms. Kellen, would you agree with me that there was an agreement between Jeffrey Epstein, Ghislaine Maxwell, Jean-Luc Brunel, yourself and Nadia Marcinkova to bring in girls from out of state that were underage? THE WITNESS: On the instruction of my lawyer, I must invoke my Fifth Amendment right. See McCawley Decl. at Exhibit 8, Sarah Kellen March 24, 2010 Dep. Tr. p. 38 (GIUFFRE001680)Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 7 of 12 Q. Would you agree with me that Ghislaine Maxwell provides underage girls to Mr. Epstein for sex? THE WITNESS: Upon the instruction of my lawyer, I must invoke my Fifth Amendment privilege. See McCawley Decl. at Exhibit 8, Sarah Kellen March 24, 2010 Dep. Tr. p. 100 (GIUFFRE001695). Both Marcinkova and Kellen are key witnesses in this action because they were present with Mr. Epstein and Maxwell during the time period when Virginia Giuffre was with Epstein and Maxwell. ARGUMENT A. The Court Should Permit Alternative Service In the unique circumstances of this case, this Court should grant Ms. Giuffre leave to serve Jeffrey Epstein, Sarah Kellen, and Nadia Marcincova via means other than personal service, because they are evading service of process and there are other means to assure actual notice. Under Rule 45(b)(1) of the Federal Rules of Civil Procedure, “[s]erving a subpoena requires delivering a copy to the named person... .” The purpose of “requiring delivery to a named person is to ‘ensure receipt, so that notice will be provided to the recipient, and enforcement of the subpoena will be consistent with the requirements of due process.’” Aristocrat Leisure Ltd. v. Deutsche Bank Trust Co. Americas, 262 F.R.D. 293, 304 (S.D.N.Y. 2009) (quoting Med. Diagnostic Imaging, PLLC v. CareCore Nat., LLC, Nos. 06 Civ. 7764 & 06 Civ. 13516, 2008 WL 3833238, at *2 (S.D.N.Y. Aug.15, 2008) (internal quotation marks omitted)). See also First City, Texas-Houston, N.A. v. Rafidain Bank, 197 F.R.D. 250, 255 (S.D.N.Y.2000) (finding that attaching a subpoena to the door, and mailing another copy to counsel of record was sufficient). Cases not only from this Court, but also from others in the Second Circuit, have interpreted that rule “liberally” to allow service so long as the “the type ofCase 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 8 of 12 service used ‘was calculated to provide timely actual notice.’” Aristocrat Leisure Ltd., 262 F.R.D. at 304 (quoting CareCore, 2008 WL 3833238, at *2 (noting that “nothing in the word ‘delivering’ [in Rule 45(b)(1)] indicates personal service, and a personal service requirement can be unduly restrictive”); see also Cordius Trust v. Kummerfeld, No. 99 Civ. 3200, 2000 WL 10268, at *2 (S.D.N.Y. Jan. 3, 2000) (holding that because “alternative service by means of certified mail reasonably insures actual receipt of the subpoena by the witness, the ‘delivery’ requirement of Rule 45 will be met”); JPMorgan Chase Bank, N.A. v. IDW Grp., LLC, No. 08 CIV. 9116(PGG), 2009 WL 1313259, at *2 (S.D.N.Y. May 11, 2009) (“this Court joins other courts in this District in holding that effective service [of a deposition subpoena] under Rule 45 is not limited to personal service” (internal quotation omitted). A prerequisite for using means other than personal service is typically that the party “requesting the accommodation diligently attempted to effectuate personal service.” OceanFirst Bank v. Hartford Fire Ins. Co., 794 F. Supp. 2d 752, 754 (E.D. Mich. 2011) (citing Franklin v. State Farm Afire and Casualty Co., 2009 WL 3152993, at *2 (E.D. Mich. 2009). Here, Ms. Giuffre has diligently attempted to make personal service on each of the three individuals, having made multiple attempts to personal service them, including going to different locations at different times on different days, and attempting to reach them through their attorneys. See McCawley Decl. at Exhibit 4, Affidavit of Douglas G. Mercer, Chief Investigator Alpha Group. Indeed, it appears that the only reason that personal service has been unsuccessful thus far is that the important witnesses Ms. Giuffre is attempting to serve are fully aware of her efforts and are attempting to evade service. This Court will recall that efforts to evade service are a familiar practice of Jeffrey Epstein and his colleagues. As described in earlier pleadings in this case, for example, the Defendant herself refused to comply with a deposition subpoena in an earlier caseCase 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 9 of 12 brought by one of Jeffrey Epstein’s sexual assault victims. See Decl. of Sigrid McCawley at Composite Exhibit 9, Maxwell Deposition Notice; Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail Article. Ms. Giuffre proposes that she be permitted to serve her deposition notices by means other than personal service. Ms. Giuffre asks this Court to rule that she be permitted to serve each of the three individuals in ways that are reasonably calculated to give them actual notice. The specific means that Ms. Giuffre proposes are the means that her investigators took on May 18" of posting the subpoenas to the addresses associated with each of the witnesses and mailing the subpoenas to those addresses with the witness fee check and providing copies of the subpoenas via e-mail to the witnesses known counsel. See McCawley Decl. at Exhibit 4, Affidavit of Douglas G. Mercer, Chief Investigator Alpha Group. Means such as those described above have been approved by this Court in other cases. For example, in Medical Diagnostic Imaging, PLLC v. Carecore National, LLC, 2008 WL 3833238 (S.D.N.Y. 2008) (Katz, J.), this Court allowed service of a deposition subpoena to be made through mailing a copy of the subpoena to the witness’ place of employment along with a copy of the Court’s order directing the witness to comply with the subpoena or face sanctions. Id. at *3. Similarly, in JPMorgan Chase Bank, N.A. v. IDW Grp., LLC, No. 08 CIV. 9116(PGG), 2009 WL 1313259, at *3 (S.D.N.Y. May 11, 2009), this Court allowed service of a deposition subpoena to be made by sending a copy of the deposition subpoena to the witness’ place of business and residence by certified mail; leaving a copy of the deposition subpoena at the witness’ residence and place of business with a person of suitable age and discretion; and remitting a copy of the deposition subpoena by electronic mail and certified mail to counsel for a related corporation. And, in at least two cases, this Court has found that certified mailing of aCase 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 10 of 12 subpoena to the witness alone satisfies Rule 45. See Cordius Trust v.. Kummerfeld, 1999 U.S. Dist. Lexis 19980, *5—*6 (S.D.N.Y.1999); Ultradent Products, Inc. v. Hayman, No. M8-85 RPP, 2002 WL 31119425, at *3 (S.D.N.Y. Sept. 24, 2002). Here, the means of service exceed those approved in those other cases and should be permitted. CONCLUSION Ms. Giuffre should be granted leave to serve Jeffrey Epstein, Sarah Kellen, and Nadia Marcincova with deposition subpoenas by means other than personal service. As Ms. Giuffre has made multiple attempts at personal service, Ms. Giuffre should be granted leave to serve deposition subpoenas by the means employed by her investigators of posting the subpoenas to the known locations and also sending the subpoenas via U.S. mail. Dated: May 25, 2016 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 10Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 11 of 12 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202? * This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 11Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 12 of 12 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 25th day of May, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10°" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com Copies of this filing were also provided by e-mail to: Marty Weinberg, counsel for Jeffrey Epstein Bruce Reinhart counsel for Sarah Kellen /s/ Sigrid S. McCawley Sigrid S. McCawley 12Case 1:15-cv-07433-LAP Document 1320-9 Filed 01/03/24 Page 1 of 10 EXHIBIT CCase 9:08Ga580728-RAN/ 4Bedrenbacumentd e200) Hritad BbMal242/Baqe 20f Age 1 of 13 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 Vv. UNITED STATES JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR JOINDER IN ACTION COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims’), by and through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21 to join this action, on the condition that they not re-litigate any issues already litigated by Jane Doe #1 and Jane Doe #2 (also referred to as “the current victims”). The new victims have suffered the same violations of their rights under the Crime Victims’ Rights Act (CVRA) as the current victims. Accordingly, they desire to join in this action to vindicate their rights as well. Because the new victims will not re-litigate any issues previously litigated by the current victims (and because they are represented by the same legal counsel as the current victims), the Government will not be prejudiced if the Court grants the motion. The Court may “at any time” add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the motion. ! ' As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2 proceeded in this 1Case 9:08GAa580726-RAN/ 4Bedrenbecumentd e200) Hritad BbOal242/Bage B0f Age 2 of 13 FACTUAL BACKGROUND As the Court is aware, more than six years ago, Jane Doe #1 filed the present action against the Government, alleging a violation of her rights under the CVRA, 18 U.S.C. § 3771. DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her rights. At the first court hearing on the case, the Court allowed Jane Doe #2 to also join the action. Both Jane Doe #1 and Jane Doe #2 specifically argued that the government had failed to protect their CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with fairness. In response, the Government argued that the CVRA rights did not apply to Jane Doe #1 and Jane Doe #2 because no federal charges had ever been filed against Jeffrey Epstein. The Court has firmly rejected the United States’ position. In a detailed ruling, the Court concluded that the CVRA extended rights to Jane Doe #1 and Jane Doe #2 even though federal charges were never filed. DE 189. The Court explained that because the NPA barred prosecution of crimes committed against them by Epstein, they had “standing” to assert violations of the CVRA rights. Jd. The Court deferred ruling on whether the two victims would be entitled to relief, pending development of a fuller evidentiary record. Id. Two other victims, who are in many respects similarly situated to the current victims, now wish to join this action. The new victims joining at this stage will not cause any delay and their joinder in this case is the most expeditious manner in which to pursue their rights. Because the background regarding their abuse is relevant to the Court’s assessment of whether to allow them to join, their circumstances are recounted here briefly. fashion. Counsel for the new victims have made their true identities known to the Government. 2Case 9:08Ga580728-RAN/ 4Bedenbacumentdee0o) Hritad BbOe/242/Baage t0f Age 3 of 13 Jane Doe #3’s Circumstances As with Jane Doe #1 and Jane Doe #2, Jane Doe #3 was repeatedly sexually abused by Epstein. The Government then concealed from Jane Doe #3 the existence of its NPA from Jane Doe #3, in violation of her rights under the CVRA. If allowed to join this action, Jane Doe #3 would prove the following: In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator in his sexual abuse and sex trafficking scheme. In fact, it became known to the government that Maxwell herself regularly participated in Epstein’s sexual exploitation of minors, including Jane Doe #3. Maxwell persuaded Jane Doe #3 (who was then fifteen years old) to come to Epstein’s mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children (including Jane Doe #1 and Jane Doe #2). When Jane Doe #3 began giving Epstein a “massage,” Epstein and Maxwell turned it into a sexual encounter, as they had done with many other victims. Epstein then became enamored with Jane Doe #3, and with the assistance of Maxwell converted her into what is commonly referred to as a “sex slave.” Epstein kept Jane Doe #3 as his sex slave from about 1999 through 2002, when she managed to escape to a foreign country and hide out from Epstein and his co-conspirators for years. From 1999 through 2002, Epstein frequently sexually abused Jane Doe #3, not only in West Palm Beach, but also in New York, New Mexico, the U.S. Virgin Islands, in international airspace on his Epstein’s private planes, and elsewhere. Epstein also sexually trafficked the then-minor Jane Doe, making her available for sex to politically-connected and financially-powerful people. Epstein’s purposes in “lending” Jane Doe 3Case 9:08GAa580726-RAN/ 4Bedrenbacumentd e200) Hritad BbGal242/Bage f40f Age 4 of 13 (along with other young girls) to such powerful people were to ingratiate himself with them for business, personal, political, and financial gain, as well as to obtain potential blackmail information. One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein’s and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, New Mexico, and the U.S. Virgin Islands. In addition to being a participant in the abuse of Jane Doe #3 and other minors, Deshowitz was an eye-witness to the sexual abuse of many other minors by Epstein and several of Epstein’s co-conspirators. Dershowitz would later play a significant role in negotiating the NPA on Epstein’s behalf. Indeed, Dershowitz helped negotiate an agreement that provided immunity from federal prosecution in the Southern District of Florida not only to Epstein, but also to “‘any potential co- conspirators of Epstein.” NPA at 5. Thus, Dershowitz helped negotiate an agreement with a provision that provided protection for himself against criminal prosecution in Florida for sexually abusing Jane Doe #3. Because this broad immunity would have been controversial if disclosed, Dershowitz (along with other members of Epstein’s defense team) and the Government tried to keep the immunity provision secret from all of Epstein’s victims and the general public, even though such secrecy violated the Crime Victims’ Rights Act. Ghislaine Maxwell was another person in Epstein’s inner circle and a co-conspirator in Epstein’s sexual abuse. She was someone who consequently also appreciated the immunity granted by the NPA for the crimes she committed in Florida. In addition to participating in the 4Case 9:08GAa5807:26-RAN/ 4Bedrenbacumentd e200) Hritad BbMel242/Baage f0f Age 5 of 13 sexual abuse of Jane Doe #3 and others, Maxwell also took numerous sexually explicit pictures of underage girls involved in sexual activities, including Jane Doe #3. She shared these photographs (which constituted child pornography under applicable federal laws) with Epstein. The Government is apparently aware of, and in certain instances possesses some of these photographs. Perhaps even more important to her role in Epstein’s sexual abuse ring, Maxwell had direct connections to other powerful individuals with whom she could connect Epstein. For instance, one such powerful individual Epstein forced Jane Doe #3 to have sexual relations with was a member of the British Royal Family, Prince Andrew (a/k/a Duke of York). Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell’s apartment), in New York, and on Epstein’s private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls). Epstein instructed Jane Doe #3 that she was to give the Prince whatever he demanded and required Jane Doe #3 to report back to him on the details of the sexual abuse. Maxwell facilitated Prince Andrew’s acts of sexual abuse by acting as a “madame” for Epstein, thereby assisting in internationally trafficking Jane Doe #3 (and numerous other young girls) for sexual purposes. Another person in Epstein’s inner circle of friends (who becomes apparent with almost no investigative effort) is Jean Luc Brunel. Epstein sexually trafficked Jane Doe #3 to Jean Luc Brunel many times. Brunel was another of Epstein’s closest friends and a regular traveling companion, who had many contacts with young girls throughout the world. Brunel has been a model scout for various modeling agencies for many years and apparently was able to get U.S. 5Case 9:08GAa580726-RAN/ 4Bedrenbacumentdee20o) Hritad BbMel242/Baq@740f Age 6 of 13 passports for young girls to “work” as models. He would bring young girls (ranging to ages as young as twelve) to the United States for sexual purposes and farm them out to his friends, especially Epstein. Brunel would offer the girls “modeling” jobs. Many of the girls came from poor countries or impoverished backgrounds, and he lured them in with a promise of making good money. Epstein forced Jane Doe #3 to observe him, Brunel and Maxwell engage in illegal sexual acts with dozens of underage girls. Epstein also forced Jane Doe #3 to have sex with Brunel on numerous occasions, at places including Epstein’s mansion in West Palm Beach, Little St. James Island in the U.S. Virgin Islands (many including orgies that were comprised of other underage girls), New York City, New Mexico, Paris, the south of France, and California. Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doe #3 to describe the events that she had with these men so that he could potentially blackmail them. The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it listed her as a victim in the attachment to the NPA. Moreover, even a rudimentary investigation of Jane Doe #3’s relationship to Epstein would have revealed the fact that she had been trafficked throughout the United States and internationally for sexual purposes. Nonetheless, the Government secretly negotiated a non-prosecution agreement with Epstein precluding any Federal prosecution in the Southern District of Florida of Epstein and his co-conspirators. As with Jane Doe #1, and Jane Doe #2, the Government concealed the non-prosecution agreement from Jane Doe #3 — all in violation of her rights under the CVRA — to avoid Jane Doe #3 from raising powerful objections to the NPA that would have shed tremendous public light on Epstein 6Case 9:08Ga580728-RAN/ 4Bedrenbacumentd e200) Hritsd BbOMal242/Baqe B0f Age 7 of 13 and other powerful individuals and that would likely have been prevented it from being concluded in the secretive manner in which it was. Jane Doe #4’s Circumstances If permitted to join this action, Jane Doe #4 would allege, and could prove at trial, that she has CVRA claims similar to those advanced by Jane Doe #1 and Jane Doe #2, based on the following: As with the other Jane Does, Jane Doe #4 was repeatedly sexually abused by Epstein. In or around the summer of 2002, Jane Doe #4, an economically poor and vulnerable sixteen-year- old child, was told by another one of Epstein’s underage minor sex abuse victims, that she could make $300 cash by giving an old man a massage on Palm Beach. An acquaintance of Jane Doe #4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4 to go to Epstein’s house to give him a massage. During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein’s mansion and was escorted upstairs to Epstein’s large bathroom by one of Epstein’s assistants. Shortly thereafter Jeffrey Epstein emerged and lay face down on the table and told Jane Doe #4 to start massaging him. Epstein asked Jane Doe #3 her age and she told him she had recently turned sixteen. Epstein subsequently committed illegal sexual acts against Jane Doe #4 on many occasions. Epstein used a means of interstate communication (i.e., a cell phone) to arrange for these sexual encounters. Epstein also frequently travelled in interstate commerce (1.e., on his personal jet) for purposes of illegally sexually abusing Jane Doe #4. 7Case 9:08-aso 731A 743 S8cLARnDoGumanteted Qi? FiRKEd ARS (24 /stage1F Oye 12 of 13 January. In the meantime, however, counsel for the victims believe that it is no longer appropriate to delay filing this motion and accordingly file it at this time. Because the Government is apparently opposing this motion, Jane Doe #3 and Jane Doe #4 have described the circumstances surrounding their claims so that the Court has appropriate information to rule on the motion. CONCLUSION Jane Doe #3 and Jane Doe #4 should be allowed to join this action, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Their joinder should be conditioned on the requirement that they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe #2. A proposed order to that effect is attached to this pleading. DATED: December 30, 2014 12 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: brad@pathtojustice.com And Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202Case 9:08Ga580726-RUNW 4Bedenbarumentde20o% Heit BEMe/242/BaG@19 O64Ge 13 of 13 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu Attorneys for Jane Doe #1 and Jane Doe #2 CERTIFICATE OF SERVICE I certify that the foregoing document was served on December 30, 2014, on the following using the Court’s CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: Dexter. Lee@usdoj.gov E-mail: ann.marie.c.villafana@usdoj.gov Attorneys for the Government /s/ Bradley J. Edwards 13Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 1 of 28 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS V. Ghislaine Maxwell, Defendant. / PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii) Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 Tel: (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 Tel: (801) 585-5202! ' This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation.Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 2 of 28 TABLE OF CONTENTS Page TABLE OF AUTHORITIES 1... ..cccceceecceseesceseeseeseeseesecaeesecseeeceaeeseeaecaeesecaessecaaeecaeeseeaecaeeaeeneeeeenes il I. FACTUAL BACKGROUND .0....ccceccecesessseesceseeseeseeseesecaeesecaeesecaaeaeesecaaeeeeeaeeseeaeeaeeaeeneeeees 2 A. Depositions Taken Thus Far By Ms. Giuffre. 2.0.0... ecceeseeeteeeneeeeneeeeeeeeseeeseeens 4 1. Ghislaine Maxwell (7 Hours) .......c.cccccccccsssecesscecssscecsseeeceeeecsseeecsseeecseeeesaes 4 2. Johanna Sjoberg (3 2 Hours). ....c.cccccescesccesceeseeceeceeeeeeeeeeseecseeeeeeeeeeesaeenes 9 B. Future Depositions Sought By Ms. Giuffire...... cece ceccceceeceenceeeeeceteeeeteeeeeeenaees 11 3. Juan Alessi (3 2 HOUrS),. ....ccccccccccssccesssecseseeceeseecesseecseeeecseeecsseeeeseeeesseeees 11 4. Maria Alessi (3 2 HOuUmS) .......cccccccssccssscecssececssececsseeecsseeecsseeecsseeeesseeeesseeees 12 5. David Rodgers (3 2 HOurs)........c:ccccccssecsseceseeeeeeeeeeceeeeeeesseeesseeseeeeeeeeseees 12 6. Rinaldo Rizzo (3 2 HOUMS)........cccescccesscecssececesececesececsseeecseeeesseeeesseeeesseeees 12 7. Jean Luc Brunel (3 2 Hours). ......ccccccccccccsscecssscecssececssececsseeeeseeeeseeeesseeees 13 8. Ross Gow (3 2 HOUIS). ..ccccccccccscccccsssccececsessececsesececssseeeececsesaeeeceseeesssseeees 13 9. Dana Burns (3 2 HOUurs).........cccccccccssscececesececeesececseseeeeeeesseseeecseaeeesssseeess 13 10. Jo Jo Fontanella (3 Y2 HOUMS).........cccecccccesseceesseceeseecesseecesseecsseeecsseeecsseeeees 13 11. Detective Joe Recarey (3 2 Hours). .....ccccecceesceesceeseceteceeeeeeeeeeeeenseenteeees 14 12. Michael Reiter (3 2 HOUIrS)..........cccccccsscccssscecssececsseeecseeecseeeesseeeesseeeesseeees 14 13. = Emmy Taylor (3 2 Hours). ...ceccccccceccceeceeesceececeseceseceeeeeeseeceaeeneeeeeeenseees 15 14. Alexandra Hall (3 2 Hours). .......cccccccccssccesssccesseecesseecesseecsseeecsseeecseeecsseees 15 15. Nadia Marcinkova (3 2 HOurs)........ccccccccsssccssscecssscecsseceesseeeessecesseeeeseeeesas 16 16. Sarah Kellen Vickers (3 2 HOUurs). .......cccccccessccssscecesscecssececsseeeeseeeeseeeenes 16 17. — Jeffrey Epstein (3 2 HoOurs).......ccecccecccescceeseeesseceseceeeceeeeeeseecnaeeneeeeeeeeseees 17 I. DISCUSSION... ceeceeccesecesecsseeseeeseeeeesseceaecseecaeeeseseeeaecsaecsaecaeeeaeeeeeeseceaecaecaeeeseeeeeeaeeeaeente 17Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 3 of 28 CONCLUSION ilCase 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 4 of 28 TABLE OF AUTHORITIES Page Cases In re Weatherford International Sec. Litigation, No. 11 CIV. 1646 (LAK) (JCF), 2013 WL 5762923 (S.D.N.Y. Oct. 24, 2013)... 19 LiButti v. United States, 107 F.3d 110 (2d Cir. 1997) woo. ccccccccccscccssccssecssecesscecseeessecsseceseeecsecessecseceseeeesesessecsseeeeseeseeenes 21 Raniola v. Bratton, 243 F.3d 610 (2d Cir. 2001) oo... ccccccccccssccssecesseeeseecsseceseceeeeessecssecsecesseeessecsseceseeeesesesseesseeeseeees 19 Scott v. City of Sioux City, Iowa, 298 F.R.D. 400 (N.D. Lowa 2014) oo. cccccceccsccssscesscesseeessecssecessceeseeessceseceeseeesaecsseceseceeaeeessecsaeeeas 19 Other Authorities Federal Rule of Civil Procedure 29 o.......cccccecccccccccesssececessseccceeesssecccsesseeeceesseseccenssseecesssaeeeceessaeeees 17 Federal Rule of Civil Procedure 30 .........cccccccccssccccsssscceceessecececssscececsessececseseseceenssseeceeesseeeceesaeeess 19 iiCase 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 5 of 28 Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this motion to take approximately seven additional depositions in this case beyond the presumptive ten deposition limit. Ms. Giuffre’s requests is still within the total number of hours allowed by the ten deposition limit because the parties have agreed that they will split the time for all third party witnesses such that Ms. Giuffre will only be expending at most 3 % hours at those additional depositions. In an abundance of caution, even though Ms. Giuffre will not likely be exceeding the total number of hours allowed for depositions, she seeks leave from this Court to confirm that she may proceed with the additional depositions for the reasons stated below. Ms. Giuffre has alleged that Defendant recruited females for Mr. Epstein, including underage females like herself, under the guise of working in a legitimate position - such as an assistant or as a massage therapist - only to almost immediately be coerced or enticed into engaging in sex for money. Defendant has challenged the veracity of Ms. Giuffre, and appears to intend to argue that Ms. Giuffre cannot support the allegation that Ms. Maxwell recruited females for Mr. Epstein or that the females were coerced or enticed into sex. The sexual abuse that lies at the heart of this case took place behind closed doors — doors of Jeffrey Epstein’s various private mansions. Unsurprisingly, Ms. Giuffre must find supporting circumstantial evidence to support her claims. Moreover, because Mr. Epstein and Defendant were travelling between Mr. Epstein's numerous homes and thus many of the events relevant to this case took place more than 100 miles from the courthouse, Ms. Giuffre cannot compel most of the witnesses to appear via a trial subpoena. Accordingly, Ms. Giuffre seeks leave to take more than the standard ten depositions in this case. At this time, she seeks leave to take seven additional depositions, as articulated below.” * Ms. Giuffre’s counsel met and conferred with Defendant’s counsel both in person and by phone in an effort to obtain agreement to proceed with these depositions but was unable to obtain an agreement. SeeCase 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 6 of 28 I. FACTUAL BACKGROUND The Court is aware of the scope of this case from earlier pleadings and numerous hearings. Initially, Ms. Giuffre anticipated the scope of discovery on this case would be narrow, because many of the events (such as flying to London on one of Epstein’s planes with Maxwell) were supported by seemingly indisputable evidence, such as flight logs, and because the Defendant’s counsel initially suggested that she may invoke her Fifth Amendment rights. Instead, during her recent deposition, Defendant simply failed to recall many of the most significant events in this case or refused to respond directly to many important questions. As a result, Ms. Giuffre is now in a position where she has to call multiple witnesses to establish fundamental facts in the case. For example, Defendant would not even admit that the initials “GM” which are on the private plane flight logs over 300 times, represent her initials for McCawley Decl. at Exhibit 1, May 17, 2016 Email Correspondence from Sigrid McCawley to Laura Menninger and Jeff Pagliuca with proposed deposition calendar. Ms. Giuffre’s ability to determine exactly which depositions would need to be taken was hamstrung by the Defendant’s refusal to sit for her deposition. As the Court will recall, Ms. Giuffre made efforts to set Defendant’s deposition starting in February 2016, yet Defendant did not sit for her deposition until after being ordered by the Court on April 22, 2016. During that deposition, Defendant refused to answer a number of questions and refused to acknowledge basic facts in this case, thereby causing Ms. Giuffre to have to depose a number of unanticipated witnesses. Ms. Giuffre’s counsel started conferring with Defendant’s counsel in February 2016 and has actively engaged in discussion about these depositions that Ms. Giuffre knew she needed to take. On May 9, 2016, the parties conferred regarding deposition scheduling and Ms. Giuffre noticed depositions in accordance with the dates and locations that Defendant’s counsel said were available, and, on May 17, 2016, provided her with a calendar outlining those dates. See McCawley Decl. at Exhibit 1, May 17, 2016 Email Correspondence from Sigrid McCawley. Ms. Maxwell waited until one day before the first deposition scheduled to take place on May 31, 2016 to inform Ms. Giuffre’s counsel that she refuses to attend the deposition of this subpoenaed witness unless Ms. Giuffre drops her request to seek additional depositions by way of this motion. “If you intend to seek more than 10 depositions or to continue the discovery cut-off post July 1, then we will not be appearing at the depositions next week...” See McCawley Decl. at Exhibit 2, May 27, 2016 e-mail Correspondence from Laura Menninger to Bradley Edwards. This obstruction of discovery by refusing to attend subpoenaed depositions that were noticed to her about one month ago on May 4, 2016 should not be condoned. See McCawley Decl. at Exhibit 3, May 4, 2016 Notice of Service and Subpoena to Juan Alessi. Defendant’s counsel is also apparently refusing to appear at the other two depositions set for next week, of Maria Alessi set for Wednesday, June 1, 2016 and originally noticed on May 4, 2016 and Dave Rodgers set for Friday, June 3, 2016 and originally noticed on May 4, 2016. While Ms. Giuffre had originally hoped to be able to conclude discovery on July 1, 2016, Defendant’s refusal to attend depositions and agree to scheduling is putting Ms. Giuffre in a position where she will need additional time to complete discovery. See McCawley Decl. at Exhibit 4, May 26, 2016 Letter from Sigrid McCawley.Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 7 of 28 Ghislaine Maxwell. Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave Rodgers to authenticate his pilot logs and the identity of the individuals on various flights. In addition, as the Court knows, this case involves allegations that Ms. Giuffre was a victim of sexual abuse when she was under the age of 18 after being recruited by Ghislaine Maxwell and Jeffrey Epstein. Ms. Giuffre has alleged that Defendant recruited her and other young females, unexperienced in massage, for sex with Jeffrey Epstein by lying to them and telling them that the job was to be her personal assistant or a massage therapist. That was a ruse. Instead, Defendant recruited these females for sex with Jeffrey Epstein and, often, with herself, and “massage” was a euphemism for sex in Defendant’s household. Defendant has stated that these claims are obvious lies. Aside from the deposition of the Defendant, Ms. Giuffre has taken the deposition of one other witness, Johanna Sjoberg, on May 18, 2016. Ms. Sjoberg testified that, while a twenty- year-old college student with no massage training, Ms. Maxwell, a stranger to her, approached her on her college campus, and told her she would hire Ms. Sjoberg as her personal assistant. After Ms. Sjoberg began to work for Defendant inside the home she shared with Epstein, Defendant revealed that Ms. Sjoberg’s true “job” was to complete sex acts with Jeffrey Epstein. Defendant was explicit with her instructions, at one point scolding Ms. Sjoberg for failing to “finish [her] job” after Ms. Sjoberg massaged Epstein without completing the sex act, and because of this failure, Defendant, instead, had to “finish [her] job for her” and cause Epstein and complete the sex act. See McCawley Decl. at Exhibit 5, Deposition of Johanna Sjoberg. Accordingly, in this manner, Ms. Giuffre needs to depose other witnesses to show the veracity of her claim that Defendant recruited young females, unexperienced in massage, for sex with Jeffrey Epstein, proving that Defendant was lying when she called Ms. Giuffre a liar, and knewCase 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 8 of 28 at the time she made the defamatory statement that it was untrue. Testimony like that from Ms. Sjoberg’s refutes Defendant’s testimony, and goes to her credibility, and goes to the claim at the center of this case. Additionally, to prove Ms. Giuffre’s allegations, that span multiple years, on multiple continents, and multiple locations, Ms. Giuffre has arranged a series of depositions of persons with direct knowledge of the relevant issues. To prove her case, Ms. Giuffre believes that a minimum of seventeen depositions will be required. In reviewing this list of depositions, it is important to understand that only one of them — the Defendant’s — will consume a full seven hours of questioning by Ms. Giuffre’s counsel, as permitted under the rules. See Fed. R. Civ. P. 30(d)(1). Apart from the Defendant’s deposition, all of the other depositions set by Ms. Giuffre have been pursuant to an agreement with Defendant’s counsel that Ms. Giuffre will be given half of the seven hours to ask questions. In the descriptions below, the time Ms. Giuffre will have to ask questions (or thus far has asked questions) is indicated: A. Depositions Taken Thus Far By Ms. Giuffre 1. Ghislaine Maxwell (7 hours). The defendant, of course, has relevant information in this case. But when Defendant was deposed, she refused to answer numerous questions about alleged adult consensual sex. Those refusals are currently before the Court in a pending motion to compel. DE 155. And, more broadly, Defendant’s deposition makes it clear that she intends to contest many of the points that earlier had appeared to be potentially uncontested. For example, in pleadings before her deposition, Defendant had suggested that she might invoke her Fifth Amendment right to remain silent during questioning. Indeed, just a week before her deposition, Defendant filed a motion seeking the alternative relief of staying further proceedings so that she could get more information about whether to take the Fifth. See DE 101 at 2-4.Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 9 of 28 During her deposition, however, Defendant did not take the Fifth. Instead, she testified that she suffered from a series of memory lapses and could not recall many of the key issues in dispute in this case. As a result of Defendant’s inability to remember events, a variety of issues are now in dispute. For example, at her deposition, Defendant indicated that she lacked recollection of or was otherwise unable to specifically answer the following questions: e Whether Defendant observed a female under the age of 18 at Jeffrey Epstein’s home in Palm Beach. See McCawley Decl. at Exhibit 6, Maxwell Depo. at 29. e Whether Defendant had meet Ms. Giuffre and introduced her to Epstein. /d. at 33. e Whether Defendant, in 2011, could recall having met Ms. Giuffre at the Mar-a-Lago in Palm Beach and then writing that fact in an email. /d. at 35. + Whether when Defendant ist e Whether Defendant could recall being on a plane with iii and Ms. Giuffre. [| e Whether the Defendant knew what Nadia Marcinkova was doing at Epstein’s mansion. Td. at 41, 44. e Whether Defendant knew the nature of the relationship between Epstein and Sarah Kellen. Jd. at 47-48. e Whether Defendant knew that Sarah Kellen recruited girls under the age of 18 to come to Epstein’s mansions. Jd. at 56-57. e Whether massage therapists at Epstein’s mansions performed sexual acts. Jd. at 52-54. e Whether Defendant knew the age of Eva Dubin when she (Dubin) met Epstein. /d. at 58- 59. e Whether Defendant advised Johanna Sjoberg that she (Sjoberg) could obtain extra money if she massaged Epstein. Jd. at 61. e Whether Defendant introduced Sjoberg to Prince Andrew. Jd. at 63. e Whether Defendant could recall Emmy Taylor brought masseuses to Epstein’s mansion. Id. at 67.Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 10 of 28 Whether Defendant knew what Ms. Giuffre was required to wear while providing massages to Epstein. /d. at 68-69. Whether Defendant could recall having a laundry basket of sex toys in Epstein’s Palm Beach mansion, as described by Juan Alessi. Jd. at 70-75. Whether Defendant could recall paying Ms. Giuffre. Jd. at 75. Whether Defendant was ever present to view Ms. Giuffre massaging Epstein. /d. at 75. Whether Defendant could recall telling Ms. Giuffre that she needed a cell phone so that she could be on call regularly. Jd. at 77. Whether Defendant was required to be on call to come to Epstein’s mansion when he wanted her to come. /d. at 79. Whether Defendant could recall Ms. Giuffre being at Epstein’s New York mansion when Prince Andrew came to visit. Jd. at 80-81. Whether Defendant could recall Ms. Giuffre staying at any of Epstein’s six homes. /d. at 81. Whether Defendant was aware that there were over 30 individuals who were minors who gave reports to the Palm Beach Police Department who said they were sexually assaulted by Epstein during the years that Defendant was working with him. /d. at 89-91. Whether Defendant introduced Ms. Giuffre to Prince Andrew in London. /d. at 108. Whether Ms. Giuffre ever stayed at Defendant’s home in London. /d. at 108. Whether Defendant remembered taking a trip with Ms. Giuffre to travel over to Europe, including London. /d. at 108. Whether Defendant could recall Prince Andrew being present in New York for a party where Johanna Sjoberg was also present. Jd. at 112-13. Whether a picture depicting Prince Andrew, Ms. Giuffre and Defendant was taken at Defendant’s London town home. Jd. at 113-14. Whether Defendant ever flew on one of Epstein’s planes with a 17 year old. /d. at 121- 22. Whether the notation “GM” on flight logs for passengers on Epstein’s planes represented the Defendant (i.e., Ghislaine Maxwell). Jd. at 122-23.Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 11 of 28 Whether Defendant knew that the flight logs produced by Dave Rogers (one of Epstein’s pilots) were accurate. Jd. at 128-29. Whether Defendant could recall ever being on a flight on one of Epstein’s planes with Ms. Giuffre. Jd. at 132-33. Whether Defendant could recall Epstein and former President Clinton being friendly towards each other. Jd. at 135-36. Whether Defendant could recall the purpose of a trip to Thailand with Epstein and former President Clinton was. Jd. at 140. Whether Defendant could recall Ms. Giuffre taking pictures on trips. Jd. at 144. Whether Defendant could recollect writing down messages on memo pads from various individuals at Epstein’s Palm Beach mansion. /d. at 150-57; 159-60. Whether Defendant could recall receiving a message on a memo pad concerning a Whether Defendant could explain why a minor would be calling Epstein to say they had a female for him. /d. at 164. Whether Defendant could recall a sixteen-year-old Russian girl who came to Epstein’s mansion? Jd. at 167. Whether Defendant believed that Epstein sexually abused minors. Jd. at 171-80. Whether Defendant was present at Epstein’s Florida mansion when police executed a search warrant. Id. at 186. Whether Defendant took a picture at one of Epstein’s properties of a person in either a naked or semi-naked state. Jd. at 193. Whether Defendant could recall what Epstein told her about the criminal investigation of him. Jd. at 194-95. Whether Epstein told Defendant that he never had sex with Ms. Giuffre. Jd. at 197. Whether it was an “obvious lie” that Epstein engaged in sexual conduct with Ms. Giuffre while she was under the age of 18. Jd. at 202-06. Whether Defendant knew whether Epstein had sex with a minor. /d. at 239.Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 12 of 28 e Whether it was a lie for Ms. Giuffre to say that Defendant approached females to bring them to Epstein. Jd. at 244-46. e Whether Defendant knew Epstein had a sexual preference for minors. Jd. at 251-53. e Whether Defendant knew that asked girls to come over to see Epstein for purposes of sexual massage. e Whether Defendant could recall seeing P| and Epstein together. a. e Whether Defendant was aware of any interstate or international transportation of women, aged 18 to 28, for purposes of having sex with Epstein where they would receive compensation. Jd. at 278-79. e Whether Defendant could recall anything about a puppet or caricature of Prince Andrew in Epstein’s home when Prince Andrew was there, including whether Ms. Giuffre was sitting on Prince Andrew’s lap with the puppet or caricature. Jd. at 289-93. e Whether Defendant could remember entering any telephone numbers into a contact book maintained by Epstein. Jd. at 320-22. e Whether a document with Epstein’s contacts (including “massage” contacts) was located on Defendant’s computer. /d. at 331-34. e Whether, if Alfredo Rodriguez said that Defendant had knowledge that underage girls were coming over to Epstein’s Florida mansion for purposes of sex, that would be a true statement. Jd. at 329-30. e Whether Defendant could recall any representative of hers informing the press that Ms. Giuffre committed grand theft. Jd. at 344-45. e Whether Defendant knew what her press agent, Ross Gow, was referring to when he talked in an email about “helpful leakage.” Jd. at 349-50, 406. e Whether Defendant could recall interacting with anyone, other than Ms. Giuffre, under the age of 18 on any of Epstein’s properties. /d. at 384. e Whether Defendant had discussed with Prince Andrew any of the details of Ms. Giuffre’s allegations against him. Jd. at 400. Because Defendant refused to answer those questions, Ms. Giuffre needs to depose other witnesses who have the requisite knowledge to testify concerning those issues.Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 13 of 28 2. Johanna Sjorberg (3 % hours). Ms. Sjorberg’s deposition was taken on May 18, 2016, in Fort Lauderdale. She testified as follows: e Johanna confirmed that Maxwell recruited her to work as an assistant but she was almost immediately converted into a massage therapist and worked for Maxwell and Epstein from 2001 — 2006. See McCawley Decl. at Exhibit 5, (May 18, 2016 Deposition Tr. at p. 8-9) e Johanna confirms that she knew Virginia was underage when she met her on the trip to NY with Jeffrey in 2001 because Virginia couldn’t get into the casino and then later Johanna asked her and Virginia said she was 17. (p. 18). Johanna testified that Virginia looked young. (p. 18-19). Johanna added: “At the time I had the impression that she did not have a family or she had walked away from her family. And it seemed to me, you know, they had just sort of adopted her, not as a child, but they would take care of her.” (p. 88) e Johanna testified that Jeffrey had to have three (3) massages a day from different girls. (p. 30) e Johanna testified that Jeffrey told her that he had three (3) massages a day because “he needed to have three orgasms a day. It was biological, like eating.” (p. 32) e Johanna testified that Maxwell “let me know that she was — she would not be able to please him as much as he needed and that is why there were other girls around.” (p. 33) “She (Maxwell) said she doesn’t have the time or the desire to please him as much as he needs and that’s why there were other girls around.” (p. 150-151) e Johanna confirmed that she witnessed Virginia when she was seventeen (17) in Jeffrey Epstein’s New York mansion with Prince Andrew and Ghislaine Maxwell. (p. 87) Johanna also testified that Prince Andrew sat with Virginia and Johanna and took a picture with a puppet in his image that had its hand and Prince Andrew’s hand on their respective breasts. (p. 83) e Johanna testified that Maxwell bought a camera for her and asked her to take naked pictures of herself for Jeffrey. (p. 145) e Johanna testified that Maxwell would not give her the camera because Johanna “didn’t finish the job” when massaging Jeffrey so Maxwell had to do it and was not happy. (p. 34) “She told me — called me after I had left and said, I have the camera for you but you cannot receive it yet because you came here and didn’t finish your job and I had to finish it for you...She was implying that I did not get Jeffrey off and so she had to do it.” Q When you say ‘get Jeffrey off do you mean bring him to orgasm?’ A. Yes.” (p. 34-35) e Maxwell told Johanna to always act “grateful” to Jeffrey Epstein. (p. 35)Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 14 of 28 Maxwell called Johanna and the other girls her “children” when they were on a trip to the USVI. (p. 36) David Copperfield was at a dinner at Epstein’s and there was another girl present who looked young and Johanna asked what school she went to and Johanna did not recognize the school name as being a college and she said it was possible it was a high school aged girl. Johanna said Copperfield “questioned me if I was aware that girls were getting paid to find other girls” (p. 37-38) Johanna testified she heard Jeffrey call someone to try to find girls in Hawaii to send over the Fredrick Fekkai. (p. 38-39) Johanna testified Jeffrey told her “Clinton likes them young, referring to girls.” (p. 41) Johanna testified that she was naked for 25 — 50% of all massages. (p. 42) Johanna testified that Jeffrey made her perform sexual acts during massages including sexual toys and she had intercourse with him. (p. 43, 146-147) Johanna testified that Nadia Marcinkova and Maxwell were both with her in the USVI in 2005. (p. 44). Johanna testified that Maxwell asked her to find other girls to perform massages at the house. (p. 141) She gave a name of a girl from a restaurant to Maxwell and Maxwell paid her $200.00 for the girls’ name. “Did Maxwell ever ask you to bring other girls over for Jeffrey” (p. 46) A. Yes....”And I recall Ghislaine giving me money to bring her over...” (p. 141) Johanna testified that if a massage involved sexual acts that Jeffrey paid Johanna more than the normal $200.00. (p. 100-101) She testified that Defendant called Emmy Taylor her “slave.” (p. 15). Later she testified that Jeffrey: “He told me one time Emmy was sleeping on the plane and they were getting ready to land and he went and woke her up and she thought that meant he wanted a [sex act], so she started to unzip his pants, and he said, No, no, no you just have to wake up for landing.” (p. 143-144) Johanna said Defendant flew her in the helicopter from the main island to the USVI. (p. 55) Johanna said she believes what Virginia is saying about being abused by Jeffrey and Maxwell. “Basically that I believed her, even though she never spoke to me specifically about what was going on; that once I learned everything that happened based on reading the police report, I believed her side of the story.” (p. 122-123). “Q. And what experience in the house helped you form your opinion that what Virginia is saying is true? A. You know, Jeffrey being open with me about what other girls did for him and 10Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 15 of 28 that I was not one of those girls. He was always trying to recruit me almost in a way that I could be one of them and travel with him and live the life of luxury if I only — if I only did this. So after five years of learning what was happening, I can look back knowing — I only knew Virginia a short time. Looking back, I can make assumptions about what was required of her.” (p. 123-124) e She said she recalls that Defendant went to dinner with Governor Bill Richardson one time when Johanna was visiting the ranch in New Mexico (p. 110). B. Future Depositions Sought by Ms. Giuffre Ms. Giuffre has also scheduled the following depositions. 3. Juan Alessi (3 2 hours). Mr. Alessi’s deposition is scheduled for May 31, 2016, in Florida’. Mr. Alessi was one of the employees in Epstein’s mansion. Mr. Alessi provided witness statements to police during the criminal investigation in Palm Beach, and was previously deposed in civil cases previously brought against Mr. Epstein. Specifically, Juan Alessi informed the Palm Beach Police Detective as follows: “Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at most.” (emphasis added.) See McCawley Decl. at Composite Exhibit 7, Palm Beach Police Incident Report at p. 57. On November 21, 2005, the Palm Beach Police Department took a sworn statement from house employee Juan Alessi in which he revealed that girls would come over to give “massages” and he observed Ms. Maxwell going upstairs in the direction of the bedroom quarters. See McCawley Decl. at Exhibit 8, November 21, 2005 Sworn Statement at 10. He also testified that after the massages, he would clean up sex toys that were kept in “Ms. Maxwell’s closet.” Jd. at 12-13. He added that he and his wife were concerned with what was going on at the house (/d. at 14) and that he observed girls at the house, including one named “Virginia.” /d. at 21. It is anticipated that he will testify consistently with that previous testimony. * As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set for Tuesday, May 31, 2016 (Monday is Memorial Day). See McCawley Decl. at Exhibit 2. 11Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 16 of 28 4. Maria Alessi (3 2 hours). Ms. Alessi’s deposition is scheduled for June 1, 2016, in Florida. She was, with her husband, household staff for Epstein in the Palm Beach home he shared with Defendant, and, it is anticipated, will corroborate many of the observations of her husband about minor girls and massages inside of Epstein’s Florida mansion. Mr. Alessi referenced during his prior deposition the things that Ms. Alessi observed with respect to the sexual massages and involvement of minor girls. Mrs. Alessi is also anticipated to testify regarding Ms. Maxwell's close association with Mr. Epstein and knowledge the visitors. 5. Dave Rodgers (3% hours). Mr. Rodgers's deposition is scheduled for June 3, 2016, in Florida. Rodgers was one of the pilots for Epstein’s private jets and will, it is anticipated, authenticate his flight logs showing Defendant and Ms. Giuffre together on the same flights. Defendant refused to admit that her name is reflected in the flight logs despite her initials “GM” appearing over 300 times. Therefore, such authentication is necessary because Defendant testified at her deposition she could not remember even the most basic things about flights in the flight logs. For example, when asked if “GM” represented her initials on the flight log, Defendant responded: “How do you know GM is me,” (See McCawley Decl. at Exhibit 5, Maxwell Depo. at 29 at. 122) and “GM can stand for any level, it could be Georgina, George.” (Id. at 123). Ms. Giuffre is also seeking additional flight logs in Mr. Rodgers possession that will further corroborate Defendant’s involvement with Jeffrey Epstein. 6. Rinaldo Rizzo (3 % hours). Mr. Rizzo is scheduled for June 10, 2016 and will be able to testify regarding his observations of Defendant and Epstein with underage girls (girls less than 18 years of age). Mr. Rizzo was originally set for deposition on May 13, 2016 which was noticed on April 11, 2016, and Defendant requested that Ms. Giuffre reschedule that deposition just days before the scheduled date. 12Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 17 of 28 7. Jean Luc Brunel (3_% hours). Mr. Brunel’s deposition is set for June 7, 2016, in New York. He has relevant information because he has known Maxwell and Epstein for many years and was present with Epstein and Defendant on many occasions at Epstein’s homes in New York, Palm Beach and the USVI, and he has personal knowledge of the disputed issues in this case 8. Ross Gow (3 % hours). Mr. Gow is Defendant’s press agent who issued the press statement at issue in this case on Defendant’s behalf. He will be able to testify regarding the defamatory statement, its distribution, any other defamatory statements that were distributed, and any information he had regarding the basis for the statement. Ms. Giuffre has requested that Defendant agree to produce Mr. Gow rather than requiring the time and expense of having to serve a subpoena on Mr. Gow, located in London, under the Hague convention, but counsel for Defendant has not agreed to produce Ross Gow for deposition. 9. Dana Burns (3 % hours). Ms. Burns’ deposition is set for June 8, 2016, in New Q > < 10. Jo Jo Fontanella (3 % hours). Jo Jo Fontanella is a critical witness because he has been working as Jeffrey Epstein’s butler in his New York mansion for a number of yearsCase 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 18 of 28 including during the time that Ms. Giuffre was staying the night at the mansion when she was a minor child. Virginia interacted with Mr. Fontanella frequently during the time she was with Mr. Epstein and the Defendant. Mr. Fontanella will be able to testify to what he observed at the New York mansion including his observation regarding the age and number of females who visited the house each day. Mr. Fontanella will be able to testify regarding Defendant’s presence at the home at various times and what he observed Defendant doing while she was at the New York mansion. 11. Detective Joe Recarey (3% hours). During Defendant’s deposition, Defendant questioned the veracity of the Palm Beach Police report containing the accounts of the numerous minor children who were also sexually abused by Jeffrey Epstein. Defendant referred to at least one of those children as a prostitute, which is false. See McCawley Decl. at Exhibit 5, Maxwell Deposition at 173:8-12; 359:11-18. The Palm Beach police report also includes statements about the Defendant. Detective Recarey is expected to testify regarding his investigation, what he observed, the evidence he collected from Mr. Epstein’s Palm Beach mansion, the modus operandi of the Epstein organization, and the interviews he conducted with a number of females who were subject to abuse at the Palm Beach mansion. He will also testify regarding Jeffrey Epstein’s, who is in a joint defense with Defendant, and his campaign to attack the credibility of the numerous minor children who reported sex offenses against him. Attacking the credibility of their victims, including Ms. Giuffre, is a part of Epstein and Defendant’s modus operandi. 12. Former Palm Beach Police Chief Michael Reiter (3 % hours). Chief Reiter is scheduled for deposition on June 20, 2016. He was the Police Chief who was responsible for overseeing the Palm Beach Epstein investigation. He has made public statements about the 40 14Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 19 of 28 victims of Jeffrey Epstein’s abuse. He has made public statements about the fact that after he started the investigation into the crimes that took place at the Palm Beach mansion, he was followed by strange men and “investigated”. He also has made public statements that he sent to victims regarding the failure of the government to properly handle the matter. Reiter is relevant to many issues, among others, Defendant’s claimed innocence by the fact that she was never formally charged. 13. Emmy Taylor (3% hours). Emmy Taylor was Defendant’s “assistant” during the time Ms. Giuffre was being abused. Ms. Taylor is on flight logs to Europe with Ms. Giuffre and other locations in the United States. Johanna Sjoberg testified that Emmy Taylor was referred to by the Defendant as “my slave” and that Ms. Taylor trained Ms. Sjoberg to give massages while Ms. Sjoberg was naked. Emmy Taylor will be able to testify as to what she observed and experienced during the years she was with Defendant and Epstein. Ms. Giuffre is still attempting to locate Ms. Taylor, but she is believed to reside in London. — - 15Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 20 of 28 15. Nadia Marcinkova (3 % hours). Ms. Marcinkova’s deposition is set for June 16, 2016, in New York.* Ms. Marcinkova was specifically identified by the U.S. Attorney’s Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non- prosecution agreement it executed with Mr. Epstein as part of his guilty plea. She has relevant information because she observed the recruitment of underage girls for sex and, in fact, participated in sex acts with minors. She was also on numerous flights with Defendant (in contradiction to Defendant’s testimony), and she can provide valuable testimony about Maxwell's role in the recruitment of females. 16. Sarah Kellen (a/k/a Sarah Kensignton or Sarah Vickers) (3 2 hours). Ms. Kellen’s deposition is set for June 22, 2016, in New York. Ms. Kellen specifically identified by the U.S. Attorney’s Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non-prosecution agreement it executed with Mr. Epstein as part of his guilty plea. She has relevant information because she was present during the time when Virginia was with Epstein and the Defendant, and she travelled with all of them during this critical time period. It is believed that she worked at the direction of, and directly under, Ms. Maxwell and was taught by Ms. Maxwell how to recruit females for sex with Mr. Epstein. * Marcinkova, Kellen and Epstein have not been personally served and are all subject to Ms. Giuffre’s Motion for Alternative Service [D.E. 160]. 16Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 21 of 28 17. Jeffrey Epstein (3% hours). Ms. Giuffre’s counsel have been in touch with Epstein’s counsel and is continuing to work to schedule his deposition. Epstein lies at the center of this case, and he can testify that Defendant recruited females for sex with him, including Mrs. Giuffre, under the offer of being a massage therapist, and ultimately paid these females for sex. He can testify that Defendant lured dozens if not hundreds of young females, including many underage females, to his residences for sexual purposes. II. DISCUSSION Ms. Giuffre has attempted to conduct discrete, focused discovery in this case to limit any burdens on the Defendant and on the Court. Nonetheless, this case presents numerous challenges that require that she take more than ten depositions — not the least of which is Defendant’s extraordinary lack of memory about many events that would appear to have indisputably taken place. Ms. Giuffre, however, is not seeking to exceed the allotted hours for depositions under Rule 45 -- only the number of depositions. Ms. Giuffre seeks leave of Court to 7 additional depositions, for a total of seventeen depositions. Under the rules, each party is entitled to take ten depositions which total seven hours each. Fed. R. Civ. P. 29(d)(1). Thus, the presumptive time limit for depositions is a total of seventy hours (10 depositions x 7 hours per deposition). For the convenience of opposing counsel, Ms. Giuffre has stipulated that they may have half of the seven hour deposition time for each third party witness. Thus, if the Court grants Ms. Giuffre’s motion, she will end up taking less than seventy hours of deposition testimony. Specifically, she will only take one deposition of seven hours (Defendant’s) and sixteen depositions of three-and-a-half hours — a total of 66 and Y2 hours of depositions. 17Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 22 of 28 In light of the accommodation she had extended to opposing counsel, Ms. Giuffre requested that opposing counsel agree that both sides could schedule additional depositions beyond the presumptive limit of ten. Defendant refused to agree and is also in disagreement about the proposed schedule for depositions, despite the fact that Ms. Giuffre scheduled depositions based on the dates Defendant’s counsel represented were available for depositions in this case. At Defendant's counsel's request Ms. Giuffre scheduled depositions of witnesses who lived in the same geographical location on consecutive days to limit the travel time and expense. See McCawley Decl. at Exhibit 1. Sadly, it appears that Defendant’s counsel may be attempting to delay Ms. Giuffre’s ability to obtain depositions because certain witnesses are avoiding service and others were difficult to locate, and the time period for the close of discovery is swiftly approaching. The Court will recall that the Defendant managed to delay her deposition until April 22, 2016, through unnecessary motion practice. And now that the need to depose other witnesses has been established, Defendant’s counsel are employing other delay tactics. The Court currently has before it, for example, Ms. Giuffre’s motion for leave to serve three deposition subpoenas by means other than personal service. DE 160. As recounted at greater length in that motion, three of the critical witnesses in this case — Jeffrey Epstein, Sarah Kellan, and Nadia Marcinkova — have all thus far managed to evade service of process, despite repeated, diligent, and expensive efforts at personal service. Of course, all three of these witnesses are persons who have worked very closely with Defendant in the past. Epstein is also in a joint defense agreement with Defendant. In other situations, Ms. Giuffre has been forced to delay taking depositions because of Defense Counsel. For example, Ms. Giuffre served a subpoena on Mr. Rizzo and opposing 18Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 23 of 28 counsel on April 11, 2016 for a deposition a month later on May 13, 2016. Just days before the deposition, Defendant’s counsel said they didn’t realize the deposition was scheduled and that they could not proceed forward on that date. See McCawley Decl. at Exhibit 9, May 5, 2016 E- mail Correspondence Regarding Scheduled Depositions. This forced Ms. Giuffre’s counsel to have to reset the witness for June 10, 2016. Of course, with each delay, Ms. Giuffre is hamstrung in identifying which further witnesses need to be deposed. Under Rule 30(a) of the Federal Rules of Civil Procedure, any party who wishes to conduct more than ten depositions without stipulation by the opposing party must seek leave of the court. Fed.R.Civ.P. 30(a)(2)(A)(i). Once such a motion is made, “[t]he court must grant a request to exceed ten depositions unless the additional depositions would be unreasonably cumulative or duplicative, the requesting party had a prior opportunity in discovery to obtain the information sought, or the burden or expense of additional depositions would outweigh any likely benefit.” In re Weatherford Int'l Sec. Litig., No. 11 CIV. 1646 LAK JCF, 2013 WL 5762923, at *2 (S.D.N.Y. Oct. 24, 2013) (citing Fed.R.Civ.P. 26(b)(2)(C); Raniola v. Bratton, 243 F.3d 610, 628 (2d Cir.2001)). Given the liberal discovery allowed by the rules, the burden on the party seeking additional depositions is not great. Rule 30(a)(2)'s ten-deposition limit is “a useful and appropriate ‘Stop’ sign, not as a ‘Road Closed’ sign. Once any party has taken ten depositions, it makes perfect sense to require that party to demonstrate the need for more. But that showing need not be onerous. If the need exists, discovery should not be prevented.” Scott v. City of Sioux City, Iowa, 298 F.R.D. 400, 402-03 (N.D. Iowa 2014). As the Court can readily determine from the summary of anticipated testimony above, none of the anticipated testimony is unreasonably cumulative or duplicative. Rather, all of the anticipated testimony goes to central and now-disputed issues in the case. The Court should be 19Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 24 of 28 aware that, at every turn, Defendant appears ready to brand Ms. Giuffre as a “liar” who cannot be believed. Thus, obtaining witnesses, like Ms. Sjoberg, who can corroborate that she is telling the truth is more important in this case than it would be in many others. It is equally important that Ms. Giuffre be able to depose the witnesses who can refute Defendant's testimony. The Court can also readily determine that Ms. Giuffre has not had any prior opportunity to obtain discovery of the witnesses she seeks to depose. The case is only now in the fact discovery phase, and she has had no opportunity to previously depose these third-party witnesses. Finally, there is no substantial burden involved with deposing seven additional witnesses. Any assessment of burden must take into account the scope of the underlying case. Ms. Giuffre is seeking both compensatory and punitive damages that would total millions of dollars. Against that backdrop, a handful of additional depositions cannot be seen as unduly burdensome. Moreover, this is not a situation where Defendant lacks means to pay for counsel to attend the depositions. Defendant’s vast wealth does not appear to be in doubt. During the meet-and-confer on this issue, the Defendant’s substantive reason for not stipulating to these additional depositions is that, with regard to three of the witnesses (Epstein, Kellan, and Marcinkova), it appears likely that they will invoke their Fifth Amendment right to refuse to answer some questions about Defendant’s involvement in in the sexual abuse of Ms. Giuffre. But until those witnesses actually take the Fifth, the conclusion that they will actually *Defendant has thus far refused produce documents regarding the extent of her assets, arguing that until the punitive damages phase of this proceeding is reached the discovery is not relevant. Nonetheless, public information suggests significant assets — and the possibility that she is transferring assets outside the reach of the Court’s jurisdiction. See, e.g., Alleged Epstein Madam Sells $16M Manhattan Townhouse, New York Post, Apr. 28, 2016 (available at http://nypost.com/2016/04/28/alleged-epstein- madam-sells-16m-manhattan-townhouse/). 20Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 25 of 28 take the Fifth is, ata minimum, premature.° The witness may, for example, answer some questions and not others. And, in any event, even if they take the Fifth when asked about Defendant’s sexual abuse of minors, those invocations will quite likely be admissible against the Defendant at trial. The Second Circuit has squarely held that a witness’ invocation of Fifth Amendment rights can in proper circumstances be used against a party. The Second Circuit’s seminal decision is LiButti v. United States, 107 F.3d 110, 121 (2d Cir. 1997), which upheld the drawing of adverse inferences based on a non-party’s invocation of a Fifth Amendment right to remain silent. The Second Circuit instructed that, the circumstances of given case, rather than status of particular nonparty witness, determines whether nonparty witness' invocation of privilege against self-incrimination is admissible in course of civil litigation. Jd. atl122-23. The Circuit also held that, in determining whether nonparty witness’ invocation of privilege against self-incrimination in course of civil litigation and drawing of adverse inferences is admissible, court may consider the following nonexclusive factors: (1) nature of witness' relationship with and loyalty to party; (2) degree of control which party has vested in witness in regard to key facts and subject matter of litigation; (3) whether witness is pragmatically noncaptioned party in interest and whether assertion of privilege advances interests of witness and party in outcome of litigation; and (4) whether witness was key figure in litigation and played controlling role in respect to its underlying aspects. Id. at 124-25. Clearly, many of these factors are going to weigh heavily in favor of drawing an adverse inference against Defendant. For example, Jeffrey Epstein is a “pragmatically noncaptioned ° The Court should be aware that these are also the three witnesses who have been attempted to evade service of process. 21Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 26 of 28 party in interest” regarding issues of whether he and Defendant together sexually abused Ms. Giuffre. And Defendant is in a joint defense agreement with Epstein. Also, some of the most important events in this case took place in private bedroom where just three people were present — Ms. Giuffre, Defendant, and Epstein. With Defendant denying these events, the fact that Epstein may take the Fifth could provide decisive information to the jury. But the Court need not make any determinations now as to precisely how these factors will play out. Instead, it is enough to note that very important and unique evidence may be secured from the deposition of each of these three individuals and therefore Ms. Giuffre should be permitted to take their deposition. CONCLUSION Ms. Giuffre respectfully requests that she be allowed to take a total seventeen depositions in this case. Dated: May 27, 2016 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 22Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 27 of 28 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-5202’ ’ This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 23Case 1:15-cv-07433-LAP Document 1320-10 Filed 01/03/24 Page 28 of 28 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 27th day of May, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10°" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley 24Case 1:15-cv-07433-LAP Document 1320-11 Filed 01/03/24 Page 1 of 4 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS V. Ghislaine Maxwell, Defendant. / NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN FEDERAL RULE OF CIVIL PROCEDURE 30(A)(2)(a)(ii), FILED UNDER SEAL I, Sigrid S. McCawley, declare that the below is true and correct to the best of my knowledge as follows: 1. I am a partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015 Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in support of Plaintiff's Motion to Exceed Presumptive Ten Deposition Limit In Federal Rule of Civil Procedure 30(A)(2)(a)(ii), Filed Under Seal. 3. Attached hereto as Composite Exhibit 1, is a true and correct copy of the May 17, 2016 Email Correspondence from Sigrid McCawley. 4. Attached hereto as Exhibit 2, is a true and correct copy of the May 27, 2016 Email Correspondence from Laura Menninger. 5. Attached hereto as Exhibit 3, is a true and correct copy of the Notice of ServiceCase 1:15-cv-07433-LAP Document 1320-11 Filed 01/03/24 Page 2 of 4 and Subpoena to Juan Alessi. 6. Attached hereto as Exhibit 4, is a true and correct copy of the May 26, 2016 Correspondence from Sigrid McCawley. 7. Attached hereto as Exhibit 5, is a true and correct copy of the May 18, 2016 Deposition Transcript of Johanna Sjoberg. 8. Attached hereto as Composite Exhibit 6, is a true and correct copy of the April 22, 2016 Deposition Transcript of Ghislaine Maxwell. 9. Attached hereto as Exhibit 7, is a true and correct copy of the Palm Beach Police Report. 10. Attached hereto as Exhibit 8, is a true and correct copy of the November 21, 2005 Sworn Statement of Juan Alessi. 11. | Attached hereto as Exhibit 9, is a true and correct copy of the May 4, 2016 Email Correspondence from Laura Menninger. I declare under penalty of perjury that the foregoing is true and correct. /s/ Sigrid S. McCawley Sigrid S. McCawley, Esq.Case 1:15-cv-07433-LAP Document 1320-11 Filed 01/03/24 Page 3 of 4 Dated: May 27, 2016. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies, Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 Tel: (954) 356-0011 David Boies Boies, Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 Tel: (801) 585-5202! ' This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation.Case 1:15-cv-07433-LAP Document 1320-11 Filed 01/03/24 Page 4 of 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 27, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Paliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10" Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley, Esq. Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 1 of 179 EXHIBIT 5 Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 2 of 179 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS poe x VIRGINIA L. GIUFFRE, Plaintiff, Vv. GHISLAINE MAXWELL, Defendant. Hoe x May 18, 2016 9:04 a.m. CONFIDENTIAL Deposition of JOHANNA SJOBERG, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 3 of 179 1 APPEARANCE S: BOITES SCHILLER & FLEXNER, LLP Attorneys for Plaintiff 3 401 Bast Las Olas Boulevard Fort Lauderdale, Florida 33301 4 BY: SIGRID S. McCAWLEY, ESQ. and MEREDITH SCHULTZ, ESQ. HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 7 150 East 10th Avenue Denver, Colorado 80203 BY: LAURA A. MENNINGER, ESQ. 10 SINCLAIR LOUIS & ZAVERTNIK, P.A. Attorneys for Deponent 11 40 NW Third Street Suite 200 12 Miami, Florida 33128 BY: MARSHALL DORE LOUIS, ESQ. 13 14 15 ALSO PRESENT: Ryan Kick, Videographer 16 17 18 19 20 21 22 23 24 25 Page 2 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 4 of 179 co yao UO 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX Examination by Ms. McCawley ........ Examination by Ms. Menninger ........ Further Examination by Ms. McCawley . Further Examination by Ms. Menninger EXHIBITS Deposition Exhibit 1 ................ Deposition Notice Deposition Exhibit 2 ................ Subpoena Deposition Exhibit 3 ................ Flight log Deposition Exhibit 4 ................ Palm Beach Police Department Incident Report Deposition Exhibit 5 ................ Red Ice Creations web article Page 3 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 5 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 4 THE VIDEOGRAPHER: We are now on the record. This is begins Videotape No. 1 in the deposition of Johanna Sjoberg, in the matter of Virginia Giuffre versus Ghislaine Maxwell. Today is May 18th, 2016. The time is 9:04 a.m. This deposition is being taken at 401 East Las Olas Boulevard, Fort Lauderdale, Florida. The videographer is Ryan Kick. The court reporter is Kelli Ann Willis. We both represent Magna Legal Services. Will counsel and all parties present state their appearance and whom they represent. MS. McCAWLEY: Yes. I'm Sigrid McCawley, with the law firm of Boise Schiller & Flexner, and I represent Virginia Giuffre. And I have here two colleagues of mine, Meredith Schultz and Sandra Perkins, from my firm as well. MS. MENNINGER: Hi. I'm Laura Menninger from Haddon Morgan & Foreman, and I represent Ghislaine Maxwell. MR. LOUIS: I'm Dore Louis from Sinclair Louis & Zavertnik. I'm here on behalf of the deponent. Thereupon: MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 6 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 5 JOHANNA SJOBERG a witness named in the notice heretofore filed, being of lawful age and having been first duly sworn, testified on her oath as follows: EXAMINATION BY MS. McCAWLEY: Q. Good morning, Johanna. Thank you for coming. I'm going to talk to you a little bit about the deposition process before we get started to make sure you understand what's going to happen here today. You just heard there's a videographer, and he's going to be taking your video during this deposition and generally what's happening in the course of the deposition. And then you have a court reporter here who takes down the words that we say. And it's a little bit tricky because I tend to speak quickly sometimes and speak over people, and she needs to get down all of the words. So I'll try to do my best to go slower and make sure I'm not talking over you. And, Similarly, if you've got an answer to a question, make sure that you're verbally responding, not just nodding or making a gesture MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 7 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 6 because she can't get that down. We want to make sure our responses are verbal. I'll try to remind you of that if that happens. Have you ever been deposed before? A. No. Q. No. Okay. So what's going to happen is I'm going to ask questions, and you'll give answers. And like I said, everybody will be recording those. Is there any reason, any medical reason, anything you've taken today that would cause you to not to be able to give truthful testimony today? A. No. Q. No. Okay. All right. So we're going to get started, and if you have any questions during the deposition or you need to stop to take a break, you can just let me know and we'll take that break. So what I -- the only thing I ask is if we're in the midst of a question, you finish the answer before we take a break. A. sure. Q. But I'll try to make sure that I take regular breaks, as well. You stated your name for the record. Can MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 8 of 179 Page 7 1 you tell me your date of birth? 2 3 Q. That makes you how old now? 4 5 Q. Okay. And where are you currently living? 6 7 Q. And I'm going to show you what I'm going 8 to mark as the first two exhibits in the matter. 9 And I'm going to ask the court reporter if I can 10 mark those. 11 (The referred-to document was marked by 12 the court reporter for Identification as 13 Sjoberg Exhibits 1 and 2.) 14 BY MS. McCAWLEY: 15 Q. Okay. I'm going to show you what I'm 16 marking as Exhibit 1. It's going to be the 17 re-notice of your videotaped deposition, which is 18 simply a notice I'm going to show you. And then 19 Exhibit 2 is the subpoena that we served on you. 20 So you're here today pursuant to our 21 Notice of Deposition and the subpoena that we served 22 on you. 23 Are you familiar with the subpoena? Have 24 you seen that document before? 25 A. Yes. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 9 of 179 Page 8 1 Q. Okay. Great. 2 All right. Do you know a female by the 3 name of Ghislaine Maxwell? 4 A. Yes. 5 Q. And when did you first meet Ms. Maxwell? 6 A. 2001. March probably. End of 7 February/beginning of March. 8 Q. And how did you meet her? 9 A. She approached me while I was on campus at 10 Palm Beach Atlantic College. 11 Q. And what happened when she approached you? 12 A. She asked me if I could tell her how to 13 find someone that would come and work at her house. 14 She wanted to know if there was, like, a bulletin 15 board or something that she could post, that she was 16 looking for someone to hire. 17 Q. And what did you discuss with her? 18 A. I told her where she could go to -- you 19 know, to put up a listing. And then she asked me if 20 I knew anyone that would be interested in working 21 for her. 22 Q. Did she describe what that work was going 23 to be? 24 A. She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 10 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 9 And so she just liked to hire girls to work at the house, answer phones, get drinks, do the job a butler would do. Q. And did she tell you what she would pay for that kind of a job? A. At that moment, no, but later in the day, yes. Q. And what did she say? A. Twenty dollars an hour. Q. Was there anybody else with Ms. Maxwell when you met her? A. There was another woman with her. I don't recall her or what she looks like or how old she was. Q. And what happened next? A. And then she asked me if I would be interested in working for her. And she told me that she was -- I could trust her and that I could jump in her car and go check out the house at that moment if I wanted. And so I said, Sure, let's do it, and went to her home with her. Q. And where was that home? A. In Palm Beach. Q. And did she describe that home as being MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 11 of 179 Page 10 1 her home? 2 A. She described it as being her home and 3 alluded to the fact that it was her and Jeffrey's 4 home and that she had homes all over the world. 5 Yes. 6 Q. And what happened when you arrived at the 7 home? 8 A. I believe she just showed me around. 9 Q. Do you recall meeting anybody at the home? 10 A. I don't recall if I met Jeffrey at that 11 time or the next time that I was there. 12 Q. How did you meet Jeffrey? Did Maxwell 13 introduce you to Jeffrey? 14 A. Yes. 15 Q. What do you recall of your first meeting 16 with Jeffrey? 17 A. I remember him being in a bathrobe. I 18 recall talking to him about how I was a major in 19 psychology. And he had studied psychology, and so 20 he spoke with me about different topics. 21 I remember thinking this guy is very 22 smart. That was my first impression. 23 Q. And when you refer to Jeffrey, are you 24 referring to Jeffrey Epstein? 25 A. Yes. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 12 of 179 Page 11 1 Q. How did the meeting -- you said Maxwell 2 took you to the home. Do you remember how that 3 meeting ended? 4 A. Well, she dropped me back off at campus. 5 Q. And did you -- 6 A. She got my number and I took her number. 7 And then she called me the next weekend to work. 8 Q. So at that point you started working for 9 Ms. Maxwell? 10 A. At that time, yes. 11 MS. MENNINGER: Objection, leading. 12 Sorry. 13 BY MS. McCAWLEY: 14 Q. Did you then start working for Ms. Maxwell 15 after that first meeting? 16 A. She called me and I went over to the home 17 the next Sunday to work. 18 Q. And what work -- can you describe for me 19 the first day at work, what work you performed? 20 A. Sure. I remember answering the phones and 21 taking messages. And at one point, she asked me to 22 go pick up printer ink, and I took her car to Office 23 Depot to get ink. 24 She asked me to go buy some magazines, so 25 I went to Palm Beach Daily News and bought a few MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 13 of 179 Page 12 1 magazines. 2 She and I went -- she wanted to take me 3 shopping to Worth Avenue, but it was a Sunday and 4 Nieman Marcus was closed, so we went back to, like, 5 a little book store. And I remember she bought, I 6 think, five pairs of reading glasses because she 7 thought Jeffrey would like them. He had them all 8 over the house. On every table there was reading 9 glasses. 10 And that's about it. It was a pretty 11 Simple day. 12 Q. Were you paid that day for that work? 13 A. Yes. 14 Q. And how much were you paid? Do you 15 remember? 16 A. I don't remember how many hours I was 17 there -- I was there. She paid me cash. 18 Q. So Maxwell paid you? 19 A. Yes. 20 Q. And then was she the one who trained you 21 with what -- with respect to what you were supposed 22 to do during the day, directed you to, like you 23 said, go to -- 24 A. I believe she was the one that was kind of 25 showing me around. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 14 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 13 Q. And how long did you work in that position answering phones and doing -- A. Just that one day. Q. Just that one day. And did your duties change? A. Well, the next time she called me, she asked me if I wanted to come over and make $100 an hour rubbing feet. Q. And what did you think of that offer? A. I thought it was fantastic. Q. And did you come over to the house for that purpose? A. Yes. Q. And when you came over to the house, was Maxwell present? A. I don't recall. Q. And what happened that second time you came to the house? A. At that point, I met Emmy Taylor, and she took me up to Jeffrey's bathroom and he was present. And her and I both massaged Jeffrey. She was showing me how to massage. And then she -- he took -- he got off the table, she got on the table. She took off her clothes, got on the table, and then he was showing MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 15 of 179 Page 14 1 me moves that he liked. And then I took my clothes 2 off. They asked me to get on the table so I could 3 feel it. Then they both massaged me. 4 Q. So it was more than a foot massage at that 5 point? 6 A. Yeah, it was mostly, like, legs and back. 7 Q. Was everybody in the room without clothes 8 on? 9 A. When they were on the massage table, yes. 10 Q. Did they -- when they got off the massage 11 table to perform the massage, did they dress or 12 did -- 13 A. Yes. 14 Q. They dressed. 15 And do you recall who paid you for that 16 first day that you did the massages? 17 A. I don't recall. 18 Q. Do you recall whether Maxwell was at the 19 house during that first day when you were doing the 20 massage with Emmy and Jeffrey? 21 MS. MENNINGER: Objection, asked and 22 answered. 23 BY MS. McCAWLEY: 24 Q. You can answer. 25 A. I don't recall. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 16 of 179 Page 15 1 Q. Who did Emmy work for? 2 A. Ghislaine. 3 Q. Did Maxwell ever refer to Emmy by any 4 particular term? 5 A. She called her her slave. 6 Q. You said your job duties changed. Did you 7 start to travel as part of your job with Jeffrey and 8 Ghislaine? 9 A. Yes. The next time they called me, they 10 asked me to go to New York. 11 Q. And did you -- do you recall when that was 12 approximately? 13 A. That was Easter of 2001. 14 Q. And do you recall who was on the plane 15 with you for that trip? 16 MS. MENNINGER: Objection, leading, form. 17 MS. McCAWLEY: Actually, I'm going to stop 18 really quickly and I'm going to ask for the 19 next exhibit, please. 20 MS. MENNINGER: This is 3? 21 MS. McCAWLEY: Yes. I'm going to mark 22 this as Exhibit 3 for purposes of the 23 deposition. 24 25 MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 17 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 16 (The referred-to document was marked by the court reporter for Identification as Sjoberg Exhibit 3.) BY MS. McCAWLEY: Q. Johanna, I'm going to direct you -- I flagged some pages, but for the record, I'm going to say what pages they are before I hand you the exhibit. A. sure. Q. These are Giuffre 000748 and 000758, are the two pages right now I may refer you to. The document itself is 000721 through 789. And these are flight logs from pilot David Rogers that have been produced in this case. MS. MENNINGER: Objection, foundation, asking the witness any questions about this document. THE WITNESS: Can I touch it? MS. McCAWLEY: Yes, you may. MS. MENNINGER: I just have to say things every now and then. THE WITNESS: Okay. BY MS. McCAWLEY: Q. So you mentioned that you traveled to New York. If you turn to page -- flagged page which MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 18 of 179 2 going to see a date of April 2001. 3 I'm just going to ask you to go down to 4 the -- if you look at the line on the left to where 5 it says 9 for the date, and look over where it has 6 the names. 7 Do you see -- can you identify your name 8 on that list? 9 A. Yes. 10 Q. And can you tell me -- I know there are 11 initials there -- who else to the extent you 12 remember was on the plane with you? 13 MS. MENNINGER: Objection, foundation, 14 leading, form of question. 15 BY MS. McCAWLEY: 16 Q. Johanna, do you recall who was on the 17 plane with you that day? 18 MS. MENNINGER: Objection, foundation, 19 form, leading. 20 The witness is reading the document. 21 BY MS. McCAWLEY: 22 Q. You can answer. 23 A. Okay. JE, Jeffrey Epstein; ET, Emmy 24 Taylor; VR, Virginia Roberts; BK, I do not recall; 25 and myself. Page 17 1 should be 000748, at the top of that document you're MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 19 of 179 Page 18 1 MS. MENNINGER: Objection. The witness is 2 reading the document. 3 BY MS. McCAWLEY: 4 Q. And do you recall where you flew when you 5 went to -- when you traveled that first time with 6 Jeffrey Epstein? 7 A. We left from Palm Beach and landed in 8 Atlantic City for a few hours because there was a 9 storm in New York, and then got back on the plane a 10 few hours later and landed in Teterboro. 11 Q. And you said that you recall landing in 12 Atlantic City. Did you go into Atlantic City? 13 A. Yes, went to one of Trump's casinos. 14 Q. Did you actually go into the casino 15 itself? 16 A. Yes. 17 Q. Do you recall Virginia -- at the time 18 Virginia Roberts being present with you? 19 A. Yes. 20 Q. Do you recall if she went into the casino? 21 A. She was underage. I did not know anything 22 about how old you had to be to gamble legally. I 23 just knew she could not get in because of an ID 24 issue. So she and I did not gamble. 25 Q. In your opinion, did Virginia look young, MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 20 of 179 1 in your view? 2 A. Yes. 3 Q. Did you ever -- did you at that time 4 wonder why she was traveling with Jeffrey? 5 A. At that time, I did not. 6 QO Did you later wonder that? 7 A. Yes. 8 Q And what was your impression? 9 MS. MENNINGER: Objection, vague, 10 speculative. 11 THE WITNESS: I -- we're jumping ahead; 12 that okay? 13 BY MS. McCAWLEY: 14 Q. Yes, that's okay. 15 A. A few days later, I remember asking her 16 questions to try to figure out her role, why she was 17 there, and she gave me vague answers and was never 18 specific. 19 And so I thought perhaps she just was an 20 assistant, someone that did massages well. I wanted 21 to believe that she was innocent. 22 Q. Did you ever refer to her as being 23 orphan-like? 24 A. I did. 25 Q. And how did that come about? Page 19 MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 21 of 179 Page 20 1 A. No, I only -- to you, I said that to you. 2 I just saw her as perhaps someone who may not have 3 had a strong family, and they took her under their 4 wing. 5 Q. Now, you mentioned remembering going to 6 Atlantic City. 7 Did you go -- where did you go after 8 Atlantic City? 9 A. Once we landed in New York, Emmy and I 10 went in a car and drove around the city for a half 11 hour or so, just to see some of the city. 12 Q. And then where did you go after doing the 13 sightseeing? 14 A. We went to the townhouse on East 71st. 15 Q. And can you describe that location for me? 16 A. Sure. Between Madison and Park. I think 17 the address might have been 9 Fast 71st Street. 18 Q. And who owned that home? 19 A As far as I knew, Epstein. 20 Q. Can you describe for me physically what -- 21 A Palatial. When you walk up, it looks like 22 a normal door to a townhouse, and when you walk 23 in -- I thought there were four floors. I heard 24 there were seven floors. I didn't see them all. 25 Q. And do you recall who, if anybody, was at MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 22 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 21 Jeffrey's home when you arrived? A. Yes. When I first walked in the door, it was just myself, and Ghislaine headed for the staircase and said -- told me to come up to the living room. Q. And what happened at that point, when you came up to the living room? A. I came up and saw Virginia, Jeffrey, Prince Andrew, Ghislaine in the room. Q. And did you meet Prince Andrew at that time? A. Yes. Q. And what happened next? A. At one point, Ghislaine told me to come upstairs, and we went into a closet and pulled out the puppet, the caricature of Prince Andrew, and brought it down. And there was a little tag on the puppet that said "Prince Andrew" on it, and that's when I knew who he was. Q. And did -- what did the puppet look like? A. It looked like him. And she brought it down and presented it to him; and that was a great joke, because apparently it was a production from a show on BBC. And they decided to take a picture with it, in which Virginia and Andrew sat ona MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 23 of 179 Page 22 1 couch. They put the puppet on Virginia's lap, and I 2 sat on Andrew's lap, and they put the puppet's hand 3 on Virginia's breast, and Andrew put his hand on my 4 breast, and they took a photo. 5 Q. Do you remember who took the photo? 6 A. I don't recall. 7 Q. Did you ever see the photo after it was 8 taken? 9 A. I did not. 10 Q. And Ms. Maxwell was present during the -- 11 was Ms. Maxwell present during that? 12 A. Yes. 13 Q. What happened next? 14 A. The next thing I remember is just being 15 shown to which room I was going to be staying in. 16 Q. When you exited the room that you were in 17 where the picture was taken, do you recall who 18 remained in that room? 19 A. I don't. 20 Q. Do you recall seeing Virginia exit that 21 room? 22 A. I don't. 23 Q. During this trip to New York, did you have 24 to perform any work when you were at the New York 25 house? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 24 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 23 A. I performed at least one massage that I recall. Q. And who instructed you to give that massage? A. Jeffrey. Q. And can you describe for me what happened during that massage? A. Near the end, he asked me to rub his nipples while he masturbated. Q. And did that take place? A. It did not. Q. And why not? A. I was not comfortable with it. And so I left the room. Q. Did you have any -- did you say anything to him before leaving the room? A. I believe I said, "I'm done." Q. Do you recall what his reaction was to that? A. I do not. At the time, at that moment, I do not. Q. Did you recall later what -- A. Well, we had a conversation a little later, talking about his expectations, and that was the conversation where he said that the next trip MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 25 of 179 Page 24 1 they were going on was to the island in the Virgin 2 Islands, and I would be invited; however, there 3 would be, quote, sex stuff happening. 4 Q. Can you describe for me -- can you 5 describe for me what that -- in New York, where you 6 massaged and what that looked like? 7 A. He had one room that was the massage room. 8 It was about the size of a spa room ina spa. It 9 had high ceilings. It had dark tapestry on the 10 walls. It was a very dark room. There was a very 11 large picture of a naked woman whom I don't recall. 12 That's all I remember. 13 Q. In the New York home, did you observe 14 photos around the house? 15 A. I don't recall. 16 Q. In the Palm Beach home that we were 17 talking about earlier, did you recall seeing photos 18 in that? 19 A. Yes. 20 Q. And did you recall seeing photos of naked 21 females in that home? 22 A. Yes. 23 Q. Approximately -- can you tell me where you 24 would see those in the home? 25 A. I definitely saw them in his bathroom. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 26 of 179 Page 25 1 And I can't recall if they were in the main living 2 areas. 3 Q. Did you see them in the stairwell up to 4 the second story of the house? 5 A. I can't recall. 6 Q. Do you know who -- who the people were in 7 those photos? Were you familiar with any of them? 8 A. No. 9 Q. Were you in any of those photos? 10 A. At one point, yes. 11 Q. And were you naked in that photo? 12 A. Topless. 13 Q. Do you recall seeing any naked photos of 14 Virginia Roberts? 15 A. I do not. 16 Q. Where did you go next, after the New York 17 visit? 18 A. I went to the Virgin Islands. 19 Q. And who told you that you would be going 20 to the Virgin Islands? 21 A. He asked me if I wanted to go, and I said 22 I would still like to go. 23 Q. And do you recall who you -- who went with 24 you to the Virgin Islands? 25 A. I believe -- well, I know Virginia was MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 27 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 26 with me. Ghislaine was there. Jeffrey. And there were two other women that I don't recall their names. Q. Did you travel on Jeffrey's plane to get to the Virgin Islands? A. Yes. Q. I want to show you again the flight log that you have there in front of you. If you can flip to -- MS. MENNINGER: I'm going to object to the foundation again. BY MS. McCAWLEY: Q. It's that same page that you were on. The date is the 11th. A. Yes. Q. Do you see the TEB to TIST there? A. Yes. MS. MENNINGER: Objection, leading. The guestioning is testifying now. MS. McCAWLEY: Can you let me finish my question, please? BY MS. McCAWLEY: Q. Can you tell me who the initials are there that you see that were on the plane? MS. MENNINGER: Objection, foundation, MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 28 of 179 Page 27 1 leading. 2 THE WITNESS: Jeffrey Epstein; Ghislaine 3 Maxwell; AP and PK are the two women I do not 4 recall; Virginia Roberts; and myself. 5 BY MS. McCAWLEY: 6 Q. Do you recall how you flew back from the 7 location in the US Virgin Islands? 8 A. They put me on a commercial flight. I 9 wanted to be home in time for Easter. 10 Q. When you say "they," do you recall who 11 made those arrangements for you? 12 A. It could have been Ghislaine. 13 Q. Did you -- do you recall performing 14 massages while you were in the US Virgin Islands? 15 A. Yes. 16 Q. Who was involved in -- was there more than 17 one? 18 A. Yes. I massaged Ghislaine at one point. 19 And I massaged Jeffrey, Virginia and I, both, on the 20 beach. 21 Q. Were you dressed during the massage that 22 was on the beach? 23 A. Yes. Bikinis probably, most likely. 24 Q. Do you recall what Virginia was wearing? 25 A. I believe she was wearing a bathing suit, MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 29 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 28 as well. Q. Were you paid for the massage on the beach with Virginia? A. At the end of -- before I left and flew home, Ghislaine gave me $1,000. Q. You mentioned that you massaged -- you recall massaging Ghislaine on the trip to the USVI. Do you recall when that took place? A. IT don't even recall what days we were there, so... Q. Do you recall where it took place? A. I believe it was -- well, either in my guest cottage or one of them. There were three guest houses set up that were all similar and that I was staying in. Virginia and I stayed in one together. And it was either in there or in another one that was identical. Q. And was that massage performed with Virginia as well or by you alone? A. I don't recall. Q. Were there other females in the USVI on that trip with you besides Virginia? A. Two others. Q. And do you recall who they were? A. I do not. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 30 of 179 Page 29 1 Q. Did you ever see Ghislaine Maxwell during 2 that trip laying out by the pool? 3 A. There was one time where we were all by 4 the pool, yes. 5 Q. Was Ghislaine Maxwell ever nude or topless 6 by the pool? 7 A. I don't recall. She was nude when she 8 went swimming in the ocean. 9 Q. At that moment in the USVI home, did you 10 observe any photos there of nude females? 11 A. I don't recall. 12 Q. Besides Virginia, who you mentioned, you 13 observed to be young, did you observe any other 14 females that in your view appeared to be essentially 15 under the age of 18? 16 A. No. 17 Q. Did you observe any females who you 18 thought looked young, younger than you? 19 A. No. 20 Q. Do you remember an individual by the name 21 of that you met during your time with Jeffrey 22 Epstein? 23 A. In Palm Beach? 24 QO. Yes. 25 A. Yes. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 31 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 30 Q. Did you observe her to be young when you met her? MS. MENNINGER: Objection, vague as to time. THE WITNESS: All of the women were generally young. I did not know the ages of really anyone, so... BY MS. McCAWLEY: Q. How many massages did Jeffrey receive on average in a given day? MS. MENNINGER: Objection, foundation. THE WITNESS: Three a day. BY MS. McCAWLEY: Q. Let me back up for a moment. How long did you work for Jeffrey and Ghislaine? MS. MENNINGER: Objection, leading and foundation. THE WITNESS: I believe it was five years, 2001 to 2006. BY MS. McCAWLEY: Q. And how many massages did Epstein receive per day on average? MS. MENNINGER: Objection, foundation. THE WITNESS: Three. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 32 of 179 Page 31 1 BY MS. McCAWLEY: 2 Q. Were the massages performed by the same 3 girl or different females? 4 A. Different. 5 MS. MENNINGER: Objection, foundation. 6 BY MS. McCAWLEY: 7 Q. What did the females who performed the 8 massages look like? 9 MS. MENNINGER: Objection, foundation. 10 THE WITNESS: They all looked different. 11 Some of them were ethnic, some were blond, some 12 were short, some were tall. Everyone was thin. 13 BY MS. McCAWLEY: 14 Q. Were the girls who performed the massages 15 young or old? 16 MS. MENNINGER: Objection, foundation. 17 THE WITNESS: I don't recall anyone being 18 old. 19 BY MS. McCAWLEY: 20 Q. Do you recall anybody being over the age 21 of, say, 25? 22 MS. MENNINGER: Objection, form. 23 THE WITNESS: Yeah, I believe there was 24 probably a few women that were older than 25. 25 MS. MENNINGER: I'm sorry. I get a chance MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 33 of 179 1 to object and then you can still answer. No 2 one is going to stop you from answering. I 3 just need to get the objection on the record, 4 in the same way she needs to be able to talk 5 before you. My apologies. I'm not trying to 6 cut you off, but I am supposed to get it in 7 before you answer. 8 BY MS. McCAWLEY: 9 Q. Did Jeffrey ever tell you why he received 10 so many massages from so many different girls? 11 MS. MENNINGER: Objection, hearsay. 12 BY MS. McCAWLEY: 13 Q. You can answer. 14 A. He explained to me that, in his opinion, 15 he needed to have three orgasms a day. It was 16 biological, like eating. 17 Q. And what was your reaction to that 18 statement? 19 A. I thought it was a little crazy. 20 Q. And what did -- do you recall what -- when 21 you observed the other females giving massages, do 22 you recall what they would dress like? Did they 23 wear scrubs or did they typically wear normal 24 clothes? 25 A. Normal clothes. Page 32 MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 34 of 179 Page 33 1 MS. MENNINGER: Objection, leading. 2 BY MS. McCAWLEY: 3 Q. Do you believe that from your 4 observations, Maxwell and Epstein were boyfriend and 5 girlfriend? 6 A. Initially, yes. 7 Q. Did Maxwell ever share with you whether it 8 bothered her that Jeffrey had so many girls around? 9 MS. MENNINGER: Objection, leading, 10 hearsay. 11 THE WITNESS: No. Actually, the opposite. 12 BY MS. McCAWLEY: 13 Q. What did she say? 14 A. She let me know that she was -- she would 15 not be able to please him as much as he needed and 16 that is why there were other girls around. 17 Q. Did there ever come a time -- did you ever 18 take a photography class in school? 19 A. Yes. 20 Q. And did there ever come a time when 21 Maxwell offered to buy you a camera? 22 A. Yes. 23 MS. MENNINGER: Objection, leading. 24 BY MS. McCAWLEY: 25 Q. Did Maxwell ever offer to buy you a MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 35 of 179 Page 34 1 camera? 2 MS. MENNINGER: Objection, leading. 3 THE WITNESS: Yes. 4 BY MS. McCAWLEY: 5 Q. Was there anything you were supposed to do 6 in order to get the camera? 7 MS. MENNINGER: Objection, leading. 8 THE WITNESS: I did not know that there 9 were expectations of me to get the camera until 10 after. She had purchased the camera for me, 11 and I was over there giving Jeffrey a massage. 12 I did not know that she was in possession of 13 the camera until later. 14 She told me -- called me after I had left 15 and said, I have the camera for you, but you 16 cannot receive it yet because you came here and 17 didn't finish your job and I had to finish it 18 for you. 19 BY MS. McCAWLEY: 20 Q. And did you -- what did you understand her 21 to mean? 22 A. She was implying that I did not get 23 Jeffrey off, and so she had to do it. 24 Q. And when you say "get Jeffrey off," do you 25 mean bring him to orgasm? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 36 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 35 A. Yes. Q. Did Ghislaine ever describe to you what types of girls Jeffrey liked? A. Model types. Q. Did Ghislaine ever talk to you about how you should act around Jeffrey? A. She just had a conversation with me that I should always act grateful. Q. Did Jeffrey ever tell you that he took a girl's virginity? A. He did not tell me. He told a friend of mine. Q. And what do you recall about that? MS. MENNINGER: Objection, hearsay, foundation. THE WITNESS: He wanted to have a friend of mine come out who was cardio-kickboxer instructor. She was a physical trainer. And so I brought her over to the house, and he told my friend Rachel that -- he said, You see that girl over there laying by the pool? She was 19. And he said, I just took her virginity. And my friend Rachel was mortified. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 37 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 36 BY MS. McCAWLEY: Q. Based on what you knew, did Maxwell know that the type of massages Jeffrey was getting typically involved sexual acts? MS. MENNINGER: Objection, foundation, leading. THE WITNESS: Yes. BY MS. McCAWLEY: Q. What was Maxwell's main job with respect to Jeffrey? MS. MENNINGER: Objection, foundation. THE WITNESS: Well, beyond companionship, her job, as it related to me, was to find other girls that would perform massages for him and herself. BY MS. McCAWLEY: Q. Did Maxwell ever refer to the girls ina particular way? A. At one point when we were in the islands, we were all watching a movie and she called us her children. Q. Did anybody respond to that? A I don't recall. Q. Did she ever refer to herself as a mother? A Yes, like a mother hen. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 38 of 179 Page 37 1 Q. Do you recall who was present at the time 2 that she made that comment about children? 3 A. This was the second trip that I took to 4 the Virgin Islands, so, no. I don't want to speak, 5 you know, incorrectly. I can't remember. I can't 6 really remember. 7 Q. Have you ever met David Copperfield? 8 A. Yes. 9 Q. And do you recall when you initially met 10 him? 11 A. Yes. 12 Q. Can you tell me what that was? 13 A. Sure. Someone called me from the house 14 and said that he would be there, and if I wanted to 15 come have dinner, then I could meet him. 16 So when I arrived at the house, he wasn't 17 there yet, but I waited with, I believe, Sarah 18 Kellen, and there was another girl there which I had 19 never met and never seen. She seemed young to me. 20 And I asked her what school she went to, 21 kind of prodding to see if she went to one of the 22 area colleges, and I did not recognize the name of 23 the school. 24 And so I thought she could be younger than 25 college age, but I had to assume for my own sanity MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 39 of 179 Page 38 1 that she was a daughter of one of his friends. 2 Q. But it was possible she was the school -- 3 is it possible that the school she referred to was a 4 high school? 5 A. Yes. 6 Q. And what happened at that dinner, if 7 anything? 8 A. He did some magic tricks. 9 Q. Did you observe David Copperfield to be a 10 friend of Jeffrey Epstein's? 11 A. Yes. 12 Q. Did Copperfield ever discuss Jeffrey's 13 involvement with young girls with you? 14 A. He questioned me if I was aware that girls 15 were getting paid to find other girls. 16 Q. Did he tell you any of the specifics of 17 that? 18 A. No. 19 Q. Did he say whether they were teenagers or 20 anything along those lines? 21 A. He did not. 22 MS. MENNINGER: Objection, leading, calls 23 for hearsay. 24 BY MS. McCAWLEY: 25 Q. Did you ever hear or observe Jeffrey MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 40 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 39 talking on the phone about Frederic Fekkai? A. Yes. MS. MENNINGER: Objection, leading. BY MS. McCAWLEY: Q. What did you hear? A. I heard him call someone, and say, Fekkai is in Hawaii. Can we find some girls for him? Q. And what was your reaction to that? A. Well, I was massaging and I didn't have a reaction. I tried to remain reactionless the whole five years. Q. Did Jeffrey ever take you shopping? A Yes. Q. Can you describe for me what happened? A Sure. He took me to Victoria's Secret. I believe he picked out everything and went into the room with me, the fitting room, which was very odd. Q. Did he make any comments about being in the fitting room with you? A. He joked that one time he was in there with another girl, and she said something like "Dad." But that's all I recall. Q. Did Jeffrey ever talk to you -- let me back up a moment. Have you ever been propositioned by anyone MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 41 of 179 Page 40 1 to have a baby for someone? 2 A. Yes. 3 Q And who propositioned you? 4 A Jeffrey asked me. 5 Q. Did he ask you more than once? 6 A Yes. 7 Q And what did he say? 8 A Basically just said, I want you to be the 9 mother of my baby. 10 Q. And do you recall your response to that? 11 A. Um, I don't believe that I said flat-out 12 no. I didn't agree to it. I would just say, Oh, 13 yeah, really? OkKay. 14 Q. Did you ever bring other girls over as 15 Maxwell had requested? 16 MS. MENNINGER: Objection, leading, 17 hearsay, form. 18 THE WITNESS: One time. 19 BY MS. McCAWLEY: 20 Q. Let me back up a minute, just to make it a 21 clean question. 22 Did you ever bring friends over to massage 23 Jeffrey? 24 A. No. 25 Q. And why did you not bring friends over to MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 42 of 179 Page 41 1 massage Jeffrey? 2 A. I was living in secret about what I was 3 doing during the massages, and I did not want my 4 friends to be -- to know what I was doing. So I did 5 not want anyone else coming into that. 6 Q. Was Bill Clinton a friend of Jeffrey 7 Epstein? 8 MS. MENNINGER: Objection, foundation. 9 BY MS. McCAWLEY: 10 Q. Let me back up. 11 Do you know if Bill Clinton was a friend 12 of Jeffrey Epstein? 13 A. I knew he had dealings with Bill Clinton. 14 I did not know they were friends until I read the 15 Vanity Fair article about them going to Africa 16 together. 17 Q. Did Jeffrey ever talk to you about Bill 18 Clinton? 19 A. He said one time that Clinton likes them 20 young, referring to girls. 21 Q. Did you ever -- do you recall ever taking 22 a trip to Jeffrey Epstein's home in New Mexico? 23 A. Yes. 24 Q. And do you recall who you went on that 25 trip with? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 43 of 179 Page 42 1 A. Sarah Kellen was there. Ghislaine was 2 there. That's all I recall. 3 Q. Do you recall why you went on the trip to 4 New Mexico? 5 A. To work. 6 Q. Did you perform massages on that trip? 7 A. Yes. 8 Q. Did you -- do you recall whether you 9 performed massages with Sarah Kellen on that trip? 10 A. No. 11 Q. Do you recall in the New Mexico home ever 12 observing nude photos of females there? 13 A. I don't recall. 14 Q. When you would provide massages, would you 15 provide those massages naked? 16 A. On occasion. 17 Q. On average, would you be naked, if it was 18 100 percent of the time, more than 50 percent of the 19 time? 20 A. Can you repeat it? 21 Q. Sure. When you're performing the 22 massages, can you tell me -- you said on occasion. 23 Over the five years that you worked for him, how 24 often did you perform massages naked? 25 A. Somewhere between 25 and 50 percent of the MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 44 of 179 Page 43 1 time. 2 Q. Did Epstein try to make the massages 3 sexual? 4 A. On occasion. 5 Q. Would Epstein have you rub his nipples? 6 A. Yes. 7 Q. Would he masturbate during the massages? 8 A. Yes. 9 Q. Did he use sex toys or vibrators on you? 10 A. Yes. 11 Q. Would he leave the sex toys or vibrators 12 out after the massage or would he clean up after 13 himself? 14 MS. MENNINGER: Objection, vague, form. 15 THE WITNESS: He did not ever clean up. 16 BY MS. McCAWLEY: 17 Q. Do you believe that your experience during 18 the years you were with Jeffrey and Maxwell damaged 19 you? 20 MS. MENNINGER: Objection, leading, form. 21 THE WITNESS: It affected me. "Damaged" 22 is a strong word. 23 BY MS. McCAWLEY: 24 Q. And in what way did it affect you? 25 A. It affected future relationships with men, MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 45 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 44 trust issues, expectation issues. Q. Ghislaine Did you observe Nadia Marcinkova and at the house at the same time? MS. MENNINGER: Objection, leading, form. THE WITNESS: I don't recall. BY MS. McCAWLEY: Q. On the USVI trip, the second trip that you took, do you recall Nadia Marcinkova being present? A. Q. that trip? A. Q. > IO -P Q. I believe she was present at that trip. Do you recall Maxwell being present on Yes. Do you know an individual by the name of ? Yes. And who is ? She was one of the girls that was around. Was around both Jeffrey Epstein and Ghislaine Maxwell? A. Q. I don't recall. Do you recall where you first met In Palm Beach. At Jeffrey Epstein's home? Yes. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 46 of 179 Page 45 1 Q. And what -- do you recall any observations 2 about when you met her? 3 A. To speak with, she was a little rough 4 around the edges, and I could see the progression of 5 her being groomed a little. They got her braces. 6 She had terrible posture. And with a lot of 7 massages, she learned to stand up straight. Sol 8 just saw her become a much more confident person. 9 Q. Do you recall how old she was when you 10 first met her? 11 A. I assumed she was 18, but I do not know 12 her age. 13 MS. McCAWLEY: We're going to take a break 14 really quickly and then we will be back. So we 15 are going to go off the record. 16 THE VIDEOGRAPHER: Off the record at 9:48. 17 (Thereupon, a recess was taken, after 18 which the following proceedings were held:) 19 THE VIDEOGRAPHER: On the record at 9:58. 20 BY MS. McCAWLEY: 21 Q. I'm just going to resume. I have a few 22 more questions for you. 23 You mentioned visiting the US Virgin 24 Islands. 25 Do you recall doing any activities with MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 47 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 46 Maxwell when you were on the visit to the USVI? MS. MENNINGER: Objection, vague as to time. THE WITNESS: I don't recall. BY MS. McCAWLEY: Q. Do you recall ever going hiking with her? A. Yes. Q. Did Maxwell ever ask you to try to bring other girls over for Jeffrey? At that time? Yes. No. Any other time? > OO PF OO PF Well, she had asked me if I knew anyone that could perform massages that would come to the house. Q. And what was your understanding of that request? MS. MENNINGER: Objection. THE WITNESS: Well -- MS. MENNINGER: Form. THE WITNESS: -- I just wondered why they wouldn't just call me. BY MS. McCAWLEY: Q. And did you bring anybody else over to MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 48 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 47 perform massages? A. I did not. Q. When you were either in the USVI or in Palm Beach, did you ever observe any females either topless or naked out by the pool? A. Yes. Q. What did you observe? A. Mostly skinny-dipping. Q. Do you know who the individuals were that you observed? A. Sarah Kellen and Ghislaine. Q Anybody else? A. Yes, but I don't recall who. Q Did that happen on more than one occasion? A Yes. Q. How often do you remember making those observations? A. Three times. Q. Do you recall giving a statement to the police regarding Jeffrey Epstein? A. Yes. Q. Do you recall when you gave that statement? A. I don't recall the date. Q. Do you recall the year? MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 49 of 179 Page 48 1 A. I want to say it was early 2006 or late 2 2005. 3 Q Do you recall who you met with? 4 A. No. 5 Q Do you recall what you told the police? 6 A. It was similar to this. They were asking 7 me a lot of questions that I answered. They knew a 8 lot. They knew what the bathroom looked like. They 9 knew that the couch had a hot pink throw on it with 10 green tassels. 11 I assumed that there had been videos and 12 they had seen me. They had seen the videos. That's 13 what I had assumed. I didn't know that maybe people 14 had already come forward and given them statements. 15 Q. Did they talk to you at all about the 16 videos? 17 A. They said, Were you aware that there were 18 video cameras in the house? 19 I said, No, but it would not surprise me. 20 MS. McCAWLEY: And I'm going to mark as 21 Exhibit 4 -- do you have an extra -- sorry. 22 Did you get one? Okay. Giuffre 0002 through 23 89. 24 And I'm going to direct you to page 00076, 25 and I'm going to hand it to you. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 50 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 49 (The referred-to document was marked by the court reporter for Identification as Sjoberg Exhibit 4.) BY MS. McCAWLEY: Q. I'm just going to ask that you take a look at that. As you can see, under the narrative line there, there is a name. It says, "Reported by Recarey, Joseph." Is that a name you recall meeting with, a Detective Recarey? A. Yes. I mean, I don't recall his name, only except that he had been following me around, and he left me cards, like, on my car and in my door. I tried to avoid him for a long time. Q. And can you just look at the text underneath there? A. Uh-huh. Q. Take a moment to look at that. A. sure. Q. Does that refresh your recollection as to what you told the police during the investigation? A. There are errors in here. I was not 23 when I met him. I was 21. Q. Anything else that doesn't look correct? A. The same error: That I had met him three years ago, and it obviously had been closer to five. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 51 of 179 Page 50 1 There is also the error, he obviously 2 misunderstood me: He did not pay for my tuition at 3 college. I'm still paying those school loans. But 4 he did pay for me to go to massage school and to 5 cosmetology school. 6 Okay. It pretty much ends here. 7 Q. Yes. Right. About halfway through the 8 page. 9 A. Okay. 10 MS. McCAWLEY: So, Johanna, that concludes 11 my initial piece. I'm going to reserve the 12 rest of my time for redirect. I'm going to 13 turn it over to Laura. 14 MS. MENNINGER: Can we take just a little 15 break? 16 MS. McCAWLEY: Sure, no problem. 17 THE VIDEBOGRAPHER: Off the record at 18 10:05. 19 (Thereupon, a recess was taken, after 20 which the following proceedings were held:) 21 THE VIDEOGRAPHER: On the record at 10:14. 22 EXAMINATION 23 BY MS. MENNINGER: 24 Q. Hi. 25 A. Hello. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 52 of 179 Page 51 1 Q. We've never met before today, correct? 2 A. Correct. 3 Q. Can you tell me a little bit about your 4 current job? 5 A. Sure. I just purchased a salon. I'ma 6 salon owner. I'ma hairstylist. 7 Q Congratulations. 8 A Thank you. 9 Q. How long have you been a hairstylist? 10 A For 10 years. 11 Q And what did you do before that? 12 A I briefly did massage in a spa for about a 13 year and a half. And before that I was a nanny, and 14 before that I was in school. 15 Q. And I believe you said you studied 16 psychology in school? 17 A. Correct. 18 Q Did you graduate? 19 A. Yes. 20 Q. With a degree in psychology? 21 A Yes. 22 Q. Where did you get training to be a massage 23 therapist? 24 A. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 53 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 52 Q. And when did do you that? A. That would have been, I believe, in Q. And how long did you study there? A. I think it was a six-month program. Q. And you worked in a spa thereafter? A. I did. Q. What was the name of the spa again? A. Q. And are you married? A. No. Q. Do you have children? A. No. Q. And how old are you now? A. Q. Can you tell me about your first meeting with Ghislaine Maxwell? A. Sure. I was sitting on a bench yyy DS «== 2p 02ched ne. I was getting ready to go to a class. It was my Junior year. Yes, it was the second semester of my Junior year. And she and another woman approached me. The other woman didn't speak that I recall. And she asked me about -- she had a house in Palm Beach, and she was looking for someone that she could hire to work at the house, where she could MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 54 of 179 Page 53 1 post that she needed help. 2 She then asked me if I knew anyone, and I 3 didn't know who she was, I didn't want to take the 4 responsibility of finding someone to work for her, 5 and so I said, Sorry, I don't. 6 And then she said, Well, maybe what about 7 you? 8 And I was at a point in life, I was super 9 spontaneous and willing to skip school. 10 So she said, Come to my house, come in my 11 car and check it out. 12 And so I did. 13 Q. Okay. So for those of you -- of us who 14 don't know, is this like a college campus, like a 15 traditional college campus, or is it ina city 16 setting? 17 A. It's in a city setting. I mean, Palm 18 Beach is not a big city. So it's on the 19 Intracoastal, and there was a big grassy area that 20 were surrounded by buildings, so she was inside of 21 the campus. 22 Q. And she was looking for a bulletin board 23 where she could post a job? 24 A. Something like that, yes. 25 Q. Did she have any kind of flyers -- MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 55 of 179 Page 54 1 A. Not that I recall. 2 Q. But that's what she asked you, for 3 directions to a bulletin board where she could post 4 a job? 5 A. Yes. 6 MS. McCAWLEY: Objection. 7 BY MS. MENNINGER 8 Q. And it sounds like you guys got into a 9 conversation; is that fair? 10 A. Yes. 11 Q. Can you describe Ghislaine Maxwell's 12 personality? 13 A. Well, I instantly picked up on the fact 14 that she was British. She had on, like, workout 15 clothes. I believe she was wearing all black. And 16 she -- I mean, she was a little snarky, but I felt 17 comfortable enough to get in the car with her. 18 Q. And it sounds like you had contact with 19 her over the next several years; is that fair? 20 A. Yes. 21 Q. And did you get to know more about her 22 personality over those five years, four or five 23 years? 24 A. Yes. 25 Q. And can you describe her for me, how you MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 56 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 55 observed her personality to be? A. Sure. She definitely had a great sense of humor, she loved making jokes. I mean, in a very British way. I don't remember her ever laughing, but she was funny. And I remember just thinking, she -- the first weekend that we flew to the Virgin Islands, she flew the helicopter from Saint, wherever we were to little Saint Jeff [sic] or whatever the name of the island was, and I just thought, wow, who is this woman. Q. Would you say that you respected her? A. Yes. Q. When you ended up getting in the car with her and this other woman and going back to the house, who was driving the car? A. She was driving. Q. And where did she take you? A. She took me to the house in Palm Beach. Q. And can you describe the house in Palm Beach? A. Sure. It's at the end of El Brillo Way, on the Intracoastal. The house was either white or pink. It was pink at one time it may have been painted. It was nothing fancy, it was large, it was MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 57 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 56 like a beach house. Q. And when you got there, do you remember meeting other people while you were there that first time? A. I remember other people being in the home. I don't really remember who was there. Q. Do you remember meeting, like, a butler or -- A. Potentially, a chef. Someone in the kitchen. Maybe a house manager, yeah. Q. What was your impression of this other woman that was with Ms. Maxwell at this time? A. Zero. She left zero impression on me. Q. Age, height, hair color? Nothing? A. I want to say she was brunette. Age, 20s. Yeah. Q. And you were going for the purposes of checking out potentially working at this job? A. Yes. Q. It sounds like you met Jeffrey Epstein that first time that you did go to the house, right? MS. McCAWLEY: Objection. THE WITNESS: I believe I either met him that time or the next time. I can't recall. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 58 of 179 Page 57 1 BY MS. MENNINGER: 2 Q. Okay. And tell me about your first 3 meeting with him. 4 A. Sure. I met him, I believe it was in the 5 hallway right beside the kitchen. There was a 6 hallway. It was actually more like a room, a pantry 7 type of room. That's where all of the pieces of 8 paper with the phone messages would lay. 9 And I remember sitting on the counter and 10 speaking with him, and he was in a bathrobe, and he 11 spoke with me about me being in college and studying 12 psychology. 13 Q. And did you form an opinion of him in that 14 first meeting? 15 A. I -- yeah. I believed that he was smart. 16 He was personable and could speak to anyone. 17 Q. Did he give off any sexual vibes in the 18 first meeting? 19 A. No. 20 Q. And where was Ghislaine when you were 21 speaking with Mr. Epstein? 22 A. I don't recall. 23 Q. Do you recall going to a second floor of 24 the home during that first meeting? 25 A. I don't recall. Ghislaine said at one MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 59 of 179 Page 58 1 point, You might get a massage today. That was -- 2 sorry, that was the second time when I was in the 3 home working. And I just thought it was crazy that 4 I would get a massage while I was working. But it 5 did not end up happening because the masseuse could 6 not stay. 7 Q. Do you know who the masseuse was that 8 could not stay? 9 A. No. 10 Q. But that didn't happen on the first 11 meeting; you believe that was the second meeting? 12 A. Yes, that was when I was there to work. 13 Q. How long -- how did the first trip to the 14 house end? 15 A. She gave me her phone number, and she took 16 my phone number, and she took me back to school. 17 Q. And were you full-time at school at the 18 time? 19 A. Yes. 20 Q. And how many classes were you taking, if 21 you remember? 22 A. Probably four or five. 23 Q. How did you -- how long was it before you 24 heard from Ms. Maxwell again? 25 A. Within probably three days. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 60 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 59 Q. And how did she contact you? A. She called me on my -- at that time I had a cell phone. It could have been on my cell phone. It could have been on my house phone. We had house phones back then. Q. I remember. Where were you living at the time? A. I was in an apartment in West Palm Beach. Q. And did you have a roommate or with family? A. I had a roommate. Q. So when Ms. Maxwell called you on whatever phone it was, do you remember what she said? A. Yeah. She said, Do you want to come over and work on Sunday? Q. And what did you say? A. I said, Sure. Q. And did you? A. I did. Q. How did you get there? A. That I don't recall, because I did not have a car. Q. Did you -- A. I think my roommate dropped me off, honestly. I can remember what I was wearing. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 61 of 179 Page 60 1 Q You do? 2 A. I do. 3 Q What were you wearing? 4 A. I had a -- I still have the shirt. It's 5 an old, weathered, blue, North Carolina Tech Tar 6 Heels T-shirt. 7 Q. Because you -- did Ms. Maxwell explain to 8 you what you would be doing on that Sunday when you 9 came to work or was that part of the prior 10 conversation? 11 MS. McCAWLEY: Objection. 12 THE WITNESS: About what I was wearing? 13 BY MS. MENNINGER: 14 Q. No. About what you were going to do at 15 work. 16 A. She had explained that she just wanted 17 someone to help out around the house, answering 18 phones, you know, grabbing drinks if someone wanted 19 a drink, running errands. 20 Q. And so you dressed appropriate to what you 21 believed -- 22 A. I did not know how to dress properly, 23 apparently. I should not have worn that. But I was 24 in college. 25 Q. Did anyone say anything to you? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 62 of 179 Page 61 1 A. No. 2 Q. So when you got there, what happened? 3 This is your second time to the house, but your 4 first time working, right? 5 A. Yes. 6 I was probably introduced to a few people 7 that were there. I mean, I was there for several 8 hours. Do I recall every minute? No. TI just 9 recall when I would actually have to work, answer 10 the phone, pour some drinks for people. Just water; 11 they didn't drink alcohol. And run errands. There 12 were a few errands that I ran. 13 Q. You described those errands earlier? 14 A. I did. In her car. 15 Q. You used her car? 16 A. Yes. 17 Q. What kind of car was it? 18 A. It was a Mercedes convertible. 19 Q. Did anyone go with you? 20 A. No. 21 Q. You described a shopping trip. Was that 22 in the same car? 23 A. Yes. 24 Q. Was that a separate trip than when you 25 went to run errands? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 63 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. and sh Q. than o A. Q A. Q there A. Q. A. Q. discus discus A. just s may ge Q. A. you sa her. A. Q. Page 62 Yes. That's when Ghislaine went with me e drove. Okay. So you ran errands, came back, more nce? Twice. And then you went on a shopping trip? Yes. During the time you were at the home, was anything that made you suspicious? No. Or leery? No. You mentioned there may have been some sion of a massage. Do you recall that sion? IT had never had a massage before. So she aid there was a massage therapist coming and I t one. Did she say who it was? No. So when you went shopping on this trip, id Ghislaine drove the car and you went with Was anyone else there? No. And where did you all go? MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 64 of 179 Page 63 1 A. We went to Worth Avenue in Palm Beach, but 2 because it was Sunday, the stores were closed. 3 Bless you. 4 MR. LOUIS: Thank you. 5 THE WITNESS: So from there, we went to -- 6 I believe it was Palm Beach Daily News, which 7 was like a little book store. And I remember 8 her purchasing reading glasses for Jeffrey and 9 some magazines. 10 BY MS. MENNINGER: 11 Q. Were those things for the home? 12 A. Yes. 13 Q. And earlier on your errands, you had been 14 purchasing things for the home or office? 15 A. Yes. Yes. 16 Q. Besides the printer cartridge, ink 17 cartridge, do you remember anything else? 18 A. Well, yes. Like they wanted specific 19 magazines. JI don't know if it was, like, Scientific 20 American or something to that effect. It was 21 wasn't, like, Playboy. 22 Q Okay. Did you ever answer phones? 23 A. Yes. 24 Q. When did you answer phones? 25 A That day. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 65 of 179 Page 64 1 Q. Do you remember anything notable about the 2 phone calls? 3 A. I just remember I always had to say, He's 4 unavailable, can I take a message? 5 Q. And where did you take a message? 6 A. On a little notepad next to the phone. 7 Q. Do you recall any small children calling 8 the house that day? 9 A. No. 10 Q. Were you speaking to anyone about their 11 school experience or anything like that? 12 A. No. 13 Q. Did you take any messages for famous 14 people? 15 A. They could have been famous and I would 16 have been clueless. 17 Q. Did you take messages at any other point 18 during the time that you worked with Jeffrey? 19 A. No. 20 Q. And you said you remember at the end of 21 that day being paid by Ghislaine? 22 A. Yes. 23 Q. And you were paid for doing the errands 24 and answering phones and whatever else you did? 25 A. Yes. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 66 of 179 Page 65 1 MS. McCAWLEY: Objection. 2 BY MS. MENNINGER: 3 Q. Did you do anything else that day in terms 4 of errands or things around the house that you 5 remember? 6 A. Not that I recall. 7 Q. Did you come back to answer phones and do 8 errands any other day? 9 A. No. 10 Q That was the only day you did it? 11 A. Yes. 12 Q All right. 13 Tell me the second time -- how long was it 14 before you got another sort of contact from anybody 15 at the home? 16 A. Okay. Well, after that -- I remember 17 actually that day of working, I sat with Ghislaine 18 outside on this -- outside table on the patio by the 19 pool. I told her that I was getting ready to go to 20 Nicaragua for spring break on a mission trip. I 21 remember her going, Why would you ever go to 22 Nicaragua? So I was going to be gone the next week 23 for spring break. 24 So she called, after I returned, and asked 25 if I wanted to make $100 an hour rubbing feet. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 67 of 179 Page 66 1 Q. Was that the whole conversation? 2 A. That was pretty much it. I said, Okay, 3 sure, tell me when. 4 Q. And were you excited about the prospect of 5 rubbing feet and making $100? 6 A. I was actually with -- while I was on the 7 trip in Nicaragua, I was rubbing feet, I was 8 massaging people, their feet. So it just seemed 9 kind of crazy that it all happened at the same time. 10 Q. How was it rubbing feet? 11 A. I guess I just liked doing it. I didn't 12 know that I did, but I was massaging people's feet. 13 Q. Were these strangers? 14 A. No, no, no. They were -- it was a group 15 of us that went on the trip. So we were all very 16 close. 17 Q. What kind of trip was it? 18 A. It was a -- well, a PBA, you had to do 19 these things called Workship hours, which you had to 20 do community service, 40 hours every year. And so 21 that was the way to do them all, and you would go on 22 these trips and help build a school or feed children 23 or do some sort of -- something nice. 24 Q. Nice. 25 What other trips did you take while you MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 68 of 179 Page 67 1 were there? 2 A. I did a trip and worked with Habitat for 3 Humanity in Baltimore. And then I went back to 4 Nicaragua the next year and did the same thing. 5 Q. Very nice. 6 And you were there for a whole week? 7 A. Yes. 8 Q. All right. 9 So you got a call from Ghislaine after you 10 returned? 11 A. Yes. 12 Q. And that's when she asked you about 13 rubbing feet? 14 A. Yes. 15 Q. And did she tell you when she would like 16 you to come over? 17 A. It was either that night or the next day. 18 Q And do you know how you got there? 19 A No. 20 Q. Do you know what you were wearing? 21 A No, I don't remember. 22 Q When you got there, I think you said you 23 don't remember if Ghislaine was actually there the 24 second time? 25 A. I want to believe that she was there MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 69 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 68 because she was my main contact, and so I would assume that she was probably at the house and greeted me; however, I do not recall if she was there. Q It sounds like you met Emmy Taylor? A. Yes. Q How did you meet Emmy Taylor? A. She was at the house the first day that I worked running errands. And I realized she was also a personal assistant type of person. Q. Do you know who she worked for? A. She, well, Ghislaine, it appeared to me that she worked for Ghislaine. Ghislaine sort of told her what to do and where to go. Q. And I believe you mentioned she called her her slave? A. She did. It was in a joking way, but she said, Yes, that's my slave. Q. You did not see her in any type of slavery Situation? A. Not any chains or anything of the sort, no. Q. So tell me what you remember about the second time you went. A. The third time? MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 70 of 179 Page 69 1 MS. McCAWLEY: Objection. 2 BY MS. MENNINGER: 3 Q. I'm sorry. You're right. Third time. 4 The second time you went to work, but the third time 5 you were there. 6 A. Correct. 7 So I was escorted up to the bathroom, 8 which is where 99 percent of the massages happened. 9 And Emmy Taylor was with me and Jeffrey. And I 10 don't remember the order, but Emmy was on the table 11 at one point. She took all of her clothes off, got 12 on the table. 13 I remember thinking, Okay, she's just 14 going to strip naked and get on the table. Well, 15 that's cool. We're cool. That's what we do. 16 And Jeffrey was showing me how to massage 17 on her body. And then IT took my clothes off and got 18 on the table, and then they showed me what it felt 19 like with the both of them. 20 And then Jeffrey got on the table and Emmy 21 showed me how to massage. 22 Q. So Ghislaine was not in the room? 23 A. No. 24 Q. You said that 99 percent of the massages 25 took place in the bathroom. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 71 of 179 Page 70 1 Did you see massages take place in other 2 places of the house at all? 3 A. Did I see any? No, besides us maybe 4 hanging out on the couch and someone massaging his 5 foot or me massaging his foot. But not, like, ona 6 table. 7 Q. So just casual foot-rubbing might happen 8 elsewhere in the home, but not a full-blown, full 9 body massage? 10 MS. McCAWLEY: Objection. 11 THE WITNESS: Yes. 12 BY MS. MENNINGER: 13 Q. Did you see any full-blown, full body 14 massages out by the pool? 15 A. Not that I recall. 16 Q. And do you remember ever giving any 17 yourself? 18 A. By the pool? 19 Q Out by the pool, yes. 20 A On a table? 21 Q. Yes. 22 A No. 23 Q All right. 24 You said that you had subsequently been 25 trained as a massage therapist, correct? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 72 of 179 Page 71 1 A. Correct. 2 Q. Would you describe it as normal massage 3 protocol for a person to be naked under a towel 4 during a massage, a regular massage? 5 MS. McCAWLEY: Objection. 6 THE WITNESS: Naked under a towel during a 7 massage, the person getting massaged? 8 BY MS. MENNINGER: 9 Q. Yes. 10 A. Yes. 11 Q. And as a massage therapist, you're trained 12 how to drape the person so that they're covered in 13 the right places, correct? 14 A. Yes. 15 Q. So when you were being trained by Emmy and 16 Jeffrey on some massage techniques, did anyone say 17 anything sexual during that conversation? 18 A. Not that I recall. 19 Q. What was the mood like? Was it, you know, 20 laughing? 21 A. Yes. Comfortable. 22 Q. And just to clarify, the people who were 23 giving the massages at the various points in time 24 were clothed while they were doing that, correct? 25 MS. McCAWLEY: Objection. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 73 of 179 Page 72 1 BY MS. MENNINGER: 2 Q. In this period you just described with 3 Emmy Taylor and Jeffrey in a bathroom upstairs on 4 your third visit to the house, people giving the 5 massages had their clothes on, correct? 6 A. Correct. 7 Q. All right. 8 What was the next time you remember coming 9 to the house there? 10 A. The next time was to do a massage. All by 11 myself. 12 Q. Okay. And how did that one come about? 13 A. Hmm, someone must have called me, but I 14 don't remember who. 15 Q. And to whom did you give the massage on 16 this next visit to the house? 17 A. Jeffrey. 18 Q. Was Ghislaine present during that massage? 19 A. No. 20 Q. Did anything unusual occur during that 21 massage? 22 A. After. 23 Q. What happened? After the massage? 24 A. He asked me how well do I orgasm. And I 25 said, I don't, I'm avirgin. And he was quite MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 74 of 179 Page 73 1 surprised. 2 Q. Where were you when you were having this 3 discussion? 4 A. In the bathroom. 5 Q. Were you clothed? 6 A. Yes. 7 Q. Was he clothed? 8 A. I don't remember him being naked. He was 9 probably either wrapped with a towel or ina 10 bathrobe. 11 Q. Were you caught off guard by this 12 question? 13 A. Yes. 14 Q. Was that the first time anyone had said 15 anything sexual to you during this -- 16 A. Ever? Yes. 17 Q. Did he say anything else that you recall 18 during that conversation? 19 A. I mean, we had a little bit of a 20 conversation about it, but I don't recall 21 specifically. 22 Q. And how did that massage encounter end? 23 A. Normal. There was nothing I had to do, 24 just normal massage. 25 Q. Did he pay you? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 75 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 74 A. Yes. Q. How much did he pay you? A. $200. Q. How did he pay you? A. Cash. Q. And where was the cash? A. I don't recall specifically. It was either -- he brought it upstairs with him or it would have been down on his desk. Q. And I'm assuming that you had other massages that you gave him under similar circumstances in the next years, right? A. Many, right. Q. So recalling this particular one is not sticking out in your mind? A. Yes. MS. McCAWLEY: Objection. BY MS. MENNINGER: Q. Do you remember the next time after that? A. I don't. I mean, from there, it's just a blur of random invites to come over and do it. Massage was, like, I would see him maybe three days a row, and I wouldn't see him for two months. It would be kind of that irregular schedule. Q. Do you ever recall a time where you came MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 76 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 over half. him? Page 75 every day for three weeks in a row? A. No. Q. Were you paid $200 per massage? A. Yes. Q. And how long did the massages last? A. Anywhere from 30 minutes to an hour anda Q. Did you ever give a four-hour massage to A. Good grief, no, not that I recall. Q. Have you ever given a four-hour massage to anyone in your whole life? A. No, I haven't. Q. Tell me how the whole idea of traveling to New York came up. A. I actually was not home. They called my -- my apartment. My roommate answered. When I got home, she said, You need to call Jeffrey Epstein immediately. He wants to take you to New York, but they are leaving at 4:00. And I was excited because I had never been to New York. Q. Are you from A. I am. Q. But you never went to New York? MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 77 of 179 Page 76 1 A. Just flying over it. 2 Q. When you said they called, do you know who 3 called your roommate? 4 A. I don't know who called my roommate. 5 Q. In this sort of pre-trip to New York 6 period, do you recall discussing any of the 7 particulars of your massages with Jeffrey, with 8 Ghislaine? 9 MS. McCAWLEY: Objection. 10 BY MS. MENNINGER: 11 Q. If that makes sense. 12 A. No. 13 Q. So before you got this call, had anyone 14 mentioned the idea of traveling to you? 15 A. No. 16 Q Did you call Jeffrey immediately? 17 A. I did. 18 Q And what conversation did you have with 19 him? 20 A. Basically he said, I want to take you 21 to -- to New York City. Can you be here quickly? 22 And I got to the house, and he said, Do 23 you have your passport? 24 I said, No. 25 He said, Go get it. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 78 of 179 Page 77 1 So I went back and picked up my passport, 2 and went back to the house before we went to the 3 airport. 4 Q. And why did you need your passport? 5 A. I was ready to find out. I had no idea. 6 Q. This was the spontaneous phase? 7 A. Exactly. 8 Q. So you went and got your passport. You 9 came back. And then what happened? 10 A. Then we went to the airport. 11 Q. And who is we? 12 A. So, I don't remember the ride to the 13 airport, but the people that I recall being on the 14 plane was Jeffrey, Ghislaine, Virginia and I. 15 Q. And when was the first time you met 16 Virginia? 17 A. I believe it was that day. 18 Q. In your previous visits to the house, had 19 you seen her there? 20 A. Not that I recall. 21 Q. And what was your impression the first day 22 you met her? 23 A. She seemed young and blond and cute. 24 Q. What was her personality like? 25 A. I honestly don't recall her personality. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 79 of 179 Page 78 1 Bubbly. 2 Q. Did you see her in the plane or on the 3 trip to New York engaged in any kind of affectionate 4 or sexual contact with Jeffrey? 5 A. No. 6 Q. With Ghislaine? 7 A. No. 8 Q. How did it come to be that you were ina 9 casino in Atlantic City? 10 A. We, as we were flying, Jeffrey said, Why 11 don't you go sit in the cockpit to check out the 12 landing? 13 So we were sitting there, and the pilots 14 told me to go back and tell him that we can't land 15 in New York and that we were going to have to land 16 in Atlantic City. 17 Jeffrey said, Great, we'll call up Trump 18 and we'll go to -- I don't recall the name of the 19 casino, but -- we'll go to the casino. 20 Q. And what happened with an ID issue? 21 MS. McCAWLEY: Objection: 22 THE WITNESS: All I knew is that she was 23 not going to be allowed to gamble, and so I 24 spent time with her. We were just walking 25 around. I don't remember what we did. Because MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 80 of 179 Page 79 1 either she didn't have an ID or she was too 2 young. I don't remember specifically why. I 3 just knew that she could not gamble. 4 BY MS. MENNINGER: 5 Q. Okay. So you walked around with her in 6 Atlantic City? 7 A. Uh-huh. In the casino. We never left the 8 casino. 9 Q. Were you disappointed that you couldn't 10 gamble? 11 A. No. 12 Q. When you were walking around and talking 13 to her, did you learn anything about her? 14 A. Not that I recall. 15 Q. Did you have an impression about why she 16 was on the trip? 17 A. At that point, no. I was so new to the 18 whole thing, I was just trying to figure out my 19 position and who everybody was. At that point, I 20 had no idea -- I didn't know anything sexual was 21 happening at all. So I just felt like she was just 22 another visitor. 24 been to New York with Jeffrey before? 25 A. Not that I recall. 23 Q. Did she tell you at that time that she had MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 81 of 179 1 Q. Did she tell you anything about Ghislaine 2 during that walk-about? 3 A. No. 4 Q. And then you all traveled on to New York 5 that same night? 6 A. Yes. 7 Q. How long were you in New York for that 8 visit? 9 A. It was maybe two nights. 10 Q. And where did you sleep at night? 11 A. I slept in one of the guest rooms at his 12 townhouse on 71st Street. 13 Q. And did you stay in the same room as 14 Virginia? 15 A. No. 16 Q Do you know where she stayed? 17 A. No. 18 Q All right. 19 And then when you got into Manhattan, how 20 did it come to be that you were doing some 21 sightseeing? 22 A. Well, they knew that I had never been, so 23 I believe Jeffrey asked the driver and Emmy just to 24 drive me around to see the Empire State Building. 25 That's all I remember. It was late. It was dark. Page 80 MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 82 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 It wasn't Q. happened? A. Ghislaine and asked Q. A. Page 81 long, maybe 30 minutes. When you got back to the house, what I walked into the front door, and stuck her head over the grand staircase me to come upstairs into the living room. And can you describe the living room? Oh, it was very large and very formal. And Jeffrey and her and Virginia and Prince Andrew were there. Q. What were they all doing when you came in? A. Just socializing. I don't remember them doing an activity. It was just being together. Q. Was anyone unclothed? A. No. Q. Was this the same room where Jeffrey had a desk? A. It could have been, but I can't remember. Q. Did you go to New York more than one time? A. Yes. Q. How many times did you go to New York? A. Two times. Q. This was the only time that you met Prince Andrew in A. New York, though? Yes. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 83 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 82 Q. When you came upstairs, where was Virginia sitting? A. I don't remember. Q. Do you remember what she was wearing? A. No. Q. She was already there when you got back from sightseeing? A. Yes. Q. Tell me what happened with the caricature. A. Ghislaine asked me to come to a closet. She just said, Come with me. We went to a closet and grabbed the puppet, the puppet of Prince Andrew. And I knew it was Prince Andrew because I had recognized him as a person. I didn't know who he was. And so when I saw the tag that said Prince Andrew, then it clicked. I'm like, that's who it is. And we went down -- back down to the living room, and she brought it in. It was just funny because -- he thought it was funny because it was him. Q. Tell me how it came to be that there was a picture taken. MS. McCAWLEY: Objection. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 84 of 179 Page 83 1 THE WITNESS: I just remember someone 2 suggesting a photo, and they told us to go get 3 on the couch. And so Andrew and Virginia sat 4 on the couch, and they put the puppet, the 5 puppet on her lap. 6 And so then I sat on Andrew's lap, and I 7 believe on my own volition, and they took the 8 puppet's hands and put it on Virginia's breast, 9 and so Andrew put his on mine. 10 BY MS. MENNINGER: 11 Q. And this was done in a joking manner? 12 MS. McCAWLEY: Objection. 13 THE WITNESS: Yes. 14 BY MS. MENNINGER: 15 Q. Do you recall a photo being taken of that 16 event? 17 A. Yes. 18 Q. You've never seen the photo? 19 A. No. 20 Q. You don't know whose camera it was? 21 A. No. 22 Q. Virginia was sitting on the couch next to 23 Andrew, not in a big leather armchair? 24 A. Maybe. I'm just trying to remember how I 25 remember it. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 85 of 179 Page 84 1 Q. To the best of your recollection, you went 2 and sat on Andrew's lap, correct? 3 A. Yes. 4 Q. On his knee? 5 A. Yes. 6 Q. And Virginia was not sitting on his knee, 7 correct? 8 A. I don't recall. I just remember I was -- 9 she might have been on his other knee, like Santa. 10 I don't remember. 11 Q. After that, do you remember any other 12 pieces of that social engagement? 13 A. No. 14 Q Do you know where you went? 15 A. From there, I went to bed. 16 Q. Were people drinking? 17 A No. 18 Q. Did you hear Ghislaine Maxwell tell 19 Virginia to do anything while you were in that room? 20 A. No. 21 Q. Do you recall what happened the next day 22 in New York? 23 A. Bits. I mean, that was the day I went to 24 Victoria's Secret. I went and walked around by 25 myself and went to a souvenir shop, got a mug or MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 86 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 85 something. That's all I recall. Q. Did you go anywhere with Virginia? A. Oh, my gosh, yes. We went to Phantom of the Opera. Q. Who else went? A. I think it was just she and I. I forgot about that. Thank you for that memory. Q. It's my job. Anything else you remember about that day in New York? A. No. Q. You said you had given a massage to Jeffrey while you were there on that trip or was it a subseguent trip? A. That trip. Q. And how did that come to be? A. Either he or somebody asked me to go and do it. Someone showed me to the room, but I don't remember who it was. Q. Can you describe that room? A. Yes. It was high ceilings, dark. There were, like, dark red walls or dark blue walls or dark blue carpeting or something. It had a massage table set up in the middle, and there was a large -- I want to say like a 15-foot photo, either photo or MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 87 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 86 painting of a naked girl. Q. Pornographic or artistic? A. No. No, I wouldn't say pornographic. Artistic. Q. Artistic. Was Ghislaine present during that massage? A. No. Q. Did something about that particular massage session stand out to you? A. Yes. That was when I was first asked to squeeze and rub his nipples while he pleasured himself. Q. And did he say that's what he was going to do? A. He -- yes, he was just very blunt about it. He said, Rub my nipples, I'm going to jerk off. I was like, No, done. Q. And you walked out? A. I did. Q. Were there any repercussions of you walking out? A. Amazingly, no. Knowing what I know now, I'm surprised I was ever called back. But, no, I just stood my ground and walked out. I'm not comfortable with that. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 88 of 179 Page 87 1 Q. Do you know personally whether anyone else 2 had said no to him? 3 A. No. 4 Q. Did anyone ever tell you that they had 5 been in a massage scenario and told him no? 6 A. No. 7 Q. Do you recall when in your trip the 8 massage occurred? 9 A. Well, it was not the day we landed. It 10 must have been that next day that we were there. 11 Q. Do you remember anything else about 12 Virginia from that trip other than the Prince Andrew 13 thing and Phantom of the Opera? 14 A. Well, we were getting ready to leave to go 15 to the airport, and we were waiting. She and I sat 16 on the steps in the foyer. I do remember just kind 17 of asking a few questions to try to understand her 18 role, because at that point now I knew what he 19 wanted from me in the massage. And -- but she did 20 not make it clear to me that she was participating 21 in that. So I was prodding gently to see if there 22 was anything happening that shouldn't have been, 23 because I was getting the impression that she was -- 24 she told me she was 17. 25 Q. She told you she was 17? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 89 of 179 Page 88 1 A. Uh-huh. 2 Q. How did that come up? 3 A. I asked her. 4 Q. Was anyone else present during this 5 conversation? 6 A. No. 7 Q. You mentioned in your earlier testimony 8 that she seemed orphan-like. 9 A. Yes. 10 Q. But you said that was something you had 11 said to Ms. McCawley, correct? 12 A. Correct. 13 Q. That was not said at the time? 14 A. Right. No. At the time I was getting an 15 impression that she did not have a family or she had 16 walked away from her family. And it seemed to me, 17 you know, they had just sort of adopted her, not as 18 a child, but they would take care of her. 19 Q. Did you observe anyone speaking to her as 20 a child, like make up your bed? 21 A. No. 22 Q. Did you observe whether she was using 23 drugs during that trip? 24 A. No. 25 MS. McCAWLEY: Objection. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 90 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 89 BY MS. MENNINGER: Q A Q A Q A. Q A Q A Q York? A. Did you ever observe her using drugs? Not that I recall. Did she tell you that she was using Xanax? No. Cocaine? No. Ecstasy? No. Heroin? No. When was the second trip you took to New Later. Maybe 2005. I don't know. I could look in the flight record. so after? A. Q. That's all right. I don't remember exactly. That's all right. You just recall it being several years or Yes. Several years later. And just so I'm clear, can you just list for me the places you recall traveling with Jeffrey? A. Yes. That first trip was New York and the Virgin Islands. And then not again until around MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 91 of 179 Page 90 1 2005, we went to New Mexico and to New York City and 2 the Virgin Islands. 3 Q. So you were in New York twice and the 4 Virgin Islands twice and New Mexico once? 5 A. Yes. 6 Q Anywhere else? 7 A No. 8 Q. Were those primarily on the private plane? 9 A Yes. 10 Q You said you flew commercially once to get 11 back? 12 A. Yes. 13 Q. Did you recall any other commercial 14. flights? 15 A. He bought a couple of flights for me when 16 I wanted to go up to New York for personal reasons. 17 One time I went to New York commercially, and I was 18 there with friends, but I did go over to his house 19 while I was in the city. 20 Q. And that's not the trip to New York? 21 A. No. Separate. 22 Q. Would you characterize your relationship 23 with Jeffrey as friendly? 24 MS. McCAWLEY: Objection. 25 THE WITNESS: Yes. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 92 of 179 Page 91 1 BY MS. MENNINGER: 2 Q. If you asked him to buy a ticket to New 3 York, that might be something that he would do? 4 A. I never asked him to do anything for me, 5 but I told him I was interested in something, and he 6 always offered. 7 Q. The second trip to New York, anything 8 memorable about that? The one -- I'm sorry, the one 9 that you mentioned that was with Jeffrey. 10 A. I do recall Nadia being there. While I 11 massaged, she gave him a facial, but nothing sexual 12 happened. 13 Q. And do you recall if Ghislaine was part of 14 that trip or not? 15 A. I remember her being in New Mexico. 16 Q. What do you remember about her being in 17 New Mexico? 18 A. I remember she took me to -- when they 19 were building the ranch, they had a little 20 three-bedroom home, just like a prefab house. She 21 took me over there. So we went for a little walk. 22 I remember she had two new puppies named 23 Max and Mini, little Yorkies. And I want to say 24 that it was around Jeffrey's birthday when we were 25 there, but nothing -- there was no, like, MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 93 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 92 celebration or cake with candles. It was just another day. Q. You said that the Virgin Islands were a part of that second trip, as well? A. Yes. Q. And do you remember Ghislaine being part of the Virgin Islands the second time? A. Yes. That's when she called -- went to bed and kissed us all on the head and called us her children. Q. Who were the other participants in that session? A. That's who -- I don't recall who was there. I want to say that Nadia was. Q. But Virginia was not there? A. Virginia was not there. Q. Do you recall the point in time in which Virginia went away? A. Sort of. After the trip to New York, I was given her phone number to call. And I remember one time I tried to get ahold of her. Her boyfriend answered. A boyfriend, I would assume, and he sounded like he was high. And I couldn't find out where she was. And then from there on, she was out of the picture. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 94 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. trip that A. or two. Q. elsewhere? Pr O FF OO PF O Q. boyfriend A. Q A. Q. A Page 93 Do you recall how long after the New York occurred? I would say it was probably within a month Did she tell you she was working No. Did you ask her? No. Did she mention that she was a waitress? No. And worked at Taco Bell? Huh-huh. Did you speak to her boyfriend or a at any other time associated with her? No. Did you meet her boyfriend? No. Her fiancé? No. MS. McCAWLEY: Objection. BY MS. MENNINGER: Q. When you were on the plane with Jeffrey during these two trips, he was present on all of those flights? MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 95 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. Page 94 Yes. Did you observe any sexual behavior happening on the plane? A. No. He told me a story of something that had happened one time. Q. Maxwell, A. Q. A Q A Q. A Q 1 Did it involve Ghislaine Maxwell? No. Did it involve Virginia Roberts? No. And you didn't see anything? No. You did give massages to Ghislaine correct? Yes. On how many occasions? Maybe somewhere between five and 10. Was that over the course of the five Yes. Was there some point during that five years where Ghislaine Maxwell was not around as much? A. Q. Yes. Do you recall when that was? In the middle. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 96 of 179 Page 95 1 Q. Did you know why that might be? 2 A. No. 3 Q. Is that about the time that you started 4 seeing Nadia more frequently? 5 A. Yeah, I guess she was probably in the 6 picture more. Her and Sarah both had kind of been 7 around the most. 8 Q. Did you observe Nadia or Sarah appearing 9 to act like Jeffrey's girlfriend? 10 A. Nadia, not Sarah. 11 Q. What did you observe? 12 A. She was just very loving, kissing him. 13 Q. Did you know how old she was? 14 A. I didn't know. 15 Q. So you gave massages to Ghislaine five or 16 10 times. Was there anything unusual about those 17 massages? 18 A. No. 19 Q. You've been quoted in the press perhaps as 20 saying that she wasn't very picky? 21 A. About massage? 22 Q. About her massages. 23 A. Not like Jeffrey, I guess. I mean, saying 24 that meant that, you know, I would do whatever I 25 wanted to do in the massage; whereas, Jeffrey was, MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 97 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 96 like, Do my foot, do my leg. He would kind of narrate what he wanted. She just wanted a massage. So if that makes sense. She may have been naked under a towel -- A. Definitely. Q. -- in a regular massage fashion? MS. McCAWLEY: Objection. THE WITNESS: Yes. Actually, I do recall an instance where I was massaging her and Jeffrey came into the room and he did something sort of sexual to her, whether it was fondling her or slapping her butt or something, and she brushed him off like she was embarrassed. BY MS. MENNINGER: Q. So she never asked you to touch her ina sexual manner, correct? A. No. Q. And she did not rub her breasts on you, for example? A. No. MS. McCAWLEY: Objection. BY MS. MENNINGER: Q. She did not demand that you perform oral sex on her? A. No. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 98 of 179 Page 97 1 Q. Did she did not demand that you undress 2 during your massages? 3 A. No. 4 Q. There was nothing from her that was sexual 5 during the massages that you gave to her? 6 MS. McCAWLEY: Objection. 7 THE WITNESS: Correct. 8 BY MS. McCAWLEY: 9 Q. Do you recall when the last time you gave 10 her a massage was? 11 A. I don't recall. 12 Q. Do you recall meeting with her in about 13 2006 when she was in town for some helicopter 14 training? 15 A. I do recall that. 16 Q. Do you recall giving her some massages 17 during that period? 18 A. Yes. 19 Q. Do you remember going out to dinner with 20 her and to a movie? 21 A. I remember to a movie, and I don't 22 remember if we went to dinner. JI remember her 23 cooking dinner. That was another way she impressed 24 me: She knew how to cook like a chef. She had done 25 some culinary training. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 99 of 179 Page 98 1 Q. And you guys had a normal type 2 conversation? 3 A. Yes. It was very fun. 4 MS. McCAWLEY: Objection. 5 MS. MENNINGER: I would like to take about 6 a 5-, to 10-minute break, if that's okay. 7 THE VIDEBOGRAPHER: Off the record at 8 11:05. 9 (Thereupon, a recess was taken, after 10 which the following proceedings were held:) 11 THE VIDEOGRAPHER: This is the beginning 12 of Disk 2. On the record at 11:25. 13 BY MS. MENNINGER: 14 Q. Hi. I believe when we left off I was 15 asking you about massages that you gave to 16 Ghislaine. 17 Did Ghislaine pay you when she got a 18 massage from you? 19 A. Yes. 20 Q. Do you know how much she paid you? 21 A. I believe it was 200. It was the going 22 rate. 23 Q. The same as you were getting paid by 24 Jeffrey, correct? 25 A. Yes. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 100 of 179 Page 99 1 Q. Ghislaine was not present when you were 2 giving massages to Jeffrey, correct? 3 MS. McCAWLEY: Objection. 4 THE WITNESS: Correct. 5 BY MS. MENNINGER: 6 Q. At some point Jeffrey became more 7 aggressive with you, correct? 8 A. Correct. 9 MS. McCAWLEY: Objection. 10 BY MS. MENNINGER: 11 Q. At what point was that? 12 A. In the last year. 13 Q. And what does that mean to you, "became 14 more aggressive"? 15 A. He was pressuring me to do more than I was 16 comfortable with doing. 17 Q. Is that what ultimately caused you to 18 leave working for Jeffrey? 19 A. What caused me to leave was when it was 20 made public what I was doing. 21 Q. What do you mean by that? 22 A. Well, after I had spoken with the police 23 report -- the police and there was a police report, 24 I did not realize that was public knowledge, 25 journalists would get a hold of. So at one point MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 101 of 179 Page 100 1 the news channel 12 showed up at my door asking me 2 questions. 3 Q. When Jeffrey was pressuring you to do more 4 than you felt comfortable with, did you observe him 5 being more aggressive in general? Outside of the 6 massage context? 7 MS. McCAWLEY: Objection. 8 THE WITNESS: No. 9 BY MS. MENNINGER: 10 Q. Do you know whether he was taking any type 11 of steroids? 12 A. No. 13 Q. Did you ever see him wearing a patch or 14 something like that? 15 A. I don't recall. 16 Q. Did you tell anyone that Jeffrey was 17 becoming more aggressive with you contemporaneous 18 with when it was happening? 19 MS. McCAWLEY: Objection. 20 THE WITNESS: No. 21 BY MS. MENNINGER: 22 Q. When Jeffrey asked you to do other things 23 besides a normal massage, did he offer to pay you 24 additionally? 25 A. Yes. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 102 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 101 Q. How much? A. One hundred dollars extra. Can I clarify? Q. Absolutely. A. He didn't ever say he would pay me more, but when the massage was more than just a massage and it was sexual, then he would pay me more. Q. It wasn't a discussion; it's just what happened? A. Correct. Q. Thank you for clarifying. The things that took place with you and Jeffrey behind closed doors were when you were a consenting adult, correct? A. Yes. MS. McCAWLEY: Objection. THE WITNESS: Correct. BY MS. MENNINGER: Q. And you did not have knowledge of what took place with other women behind closed doors and Jeffrey, correct? MS. McCAWLEY: Objection. THE WITNESS: Correct. BY MS. MENNINGER: Q. Do you recall giving an interview to a MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 103 of 179 Page 102 1 reporter from the Mail on Sunday? 2 A. Yes. 3 Q. You told that reporter, I believe, that 4 the police report painted a picture that it was a 5 big orgy all the time, but it wasn't? 6 A. What I saw, I did not see anything out in 7 the open sexually. Me, personally. 8 Q. Right. You did not see orgies happening 9 in the pool, for example? 10 A. No. 11 Q. You did not see people engaging in sexual 12 conduct out in the open areas of the home, correct? 13 A. Right. 14 MS. McCAWLEY: Objection. 15 BY MS. MENNINGER: 16 Q. When you became aware of the allegations 17 against Jeffrey, those came aS a Surprise to you, 18 correct? 19 MS. McCAWLEY: Objection. 20 THE WITNESS: Correct. 21 BY MS. MENNINGER: 22 Q. And the surprise was that it involved 23 underaged girls making that allegation, correct? 24 MS. McCAWLEY: Objection. 25 THE WITNESS: Correct. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 104 of 179 Page 103 1 BY MS. MENNINGER: 2 Q. You were asked some questions with 3 Ms. McCawley about nude photographs that were 4 present in the home? Homes? 5 A. Uh-huh. 6 Q. In Palm Beach, I believe you said there 7 were some in the room where the massage table was? 8 A. Yes. 9 Q. Can you tell me what you recall seeing? 10 A. It wasn't candid photos. They were all, 11 like, staged. 12 Q. Like a model? 13 A. Yes. And my -- I don't recall necessarily 14 knowing any of the people in those photos. I 15 remember at one point there was a photo of myself, 16 but... 17 Q. Were they fully frontally nude or were 18 they staged, like, with, you know, parts of bodies 19 showing? 20 A. IT really only remember topless photos. I 21 don't remember full frontal photos. 22 Q. So exposing the breasts, but not exposing 23 the genitalia? 24 A. Not that I recall. And Ghislaine's 25 bathroom, I believe there was a photo of her MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 105 of 179 Page 104 1 topless, or a painting. 2 Q. A painting? 3 A. Uh-huh. 4 Q. Did you see any nude or semi-clad photos 5 of young girls? 6 A. No. 7 Q. Preteens, for example? 8 A. No. 9 Q. Something you would consider child 10 pornography? 11 A. Never. 12 Q. Other than in the bathroom or the massage 13 room at the Palm Beach home, do you recall any other 14 place in the Palm Beach home where you saw any of 15 these topless photos of women? 16 A. I remember there being photos everywhere, 17 and the ones that stick out in my memory are the 18 ones -- there was a photo of Ghislaine with the 19 Pope. It would not surprise me if there were naked 20 photos around. I just didn't retain them in my 21 memory. 22 Q. So when you say there were photos 23 everywhere, you mean just photos in general? 24 A. Yes. They had a lot of photos around the 25 house. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 106 of 179 Page 105 1 MS. McCAWLEY: Objection. 2 BY MS. MENNINGER: 3 Q. And Ghislaine was not topless in a photo 4 with the Pope, just so I'm clear? 5 A. Correct. 6 Q. I just want to make sure we get that 7 record really clear. 8 So you recall there being photos 9 everywhere; you just remember a couple sticking out 10 in your brain as being topless? 11 A. Yes. 12 Q. And the walls on the staircase to the 13 upstairs were not just covered with nude 14 photographs, to your recollection? 15 A. To my recollection, I just -- I don't 16 remember. 17 Q. Did you observe what you would consider to 18 be child pornography on any computer in the home? 19 A. No. 20 Q. Did you observe anyone taking photographs 21 of young girls in the home? 22 A. No. 23 Q. The photograph of yourself that you saw, 24 was that something that you had posed for? 25 A. Not, like, professionally. But I was just MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 107 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 106 Sitting, and I believe Jeffrey took the photo. I was just sitting on a couch upstairs in the bathroom. Q. It wasn't taken by a hidden camera? A. No. No. I was smiling in the picture. Q. And, likewise, in the New York home, did you see anything -- you described a large painting or a photograph that was in the massage room? A. Yes. Q. Do you recall any other photos of semi-clad or naked females? A. I don't recall. Q. Anything that you would consider to be child pornography that you saw in the New York home? A No. Q. And, likewise, in New Mexico? A. I don't recall. Q Do you recall seeing any semi-clad photos in New Mexico at all? A. I do not recall. Q. And the Virgin Islands? A. Yes, in his bathroom, master bathroom. Q. And what do you recall, if anything, about that photo? A. There was a photo of me in there. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 108 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. were okay A. Q. knowingly correct? Page 107 And, again, was that something that you with? Yes. Jeffrey Epstein never told you that he had sexual contact with an underaged girl, MS. McCAWLEY: Objection. THE WITNESS: When I asked him if the accusations were true, after I spoke with the police, he said yes, but they lied about their age. BY MS. MENNINGER: Q. A. to me and Q. girls? A. Q. How did that conversation come about? He asked me if the police had ever spoken I asked him, is it true. And you were talking about underaged Correct. And he said that he had been lied to by those girls? > OO PF OO PF Yes. Did he say anything else to you about it? No. Did you ask him anything else about it? No. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 109 of 179 Page 108 1 Q. Did you attempt to have any conversation 2 like that with Ghislaine Maxwell? 3 A. No. 4 Q. I saw one press report that said you had 5 met Cate Blanchett or Leonardo DiCaprio? 6 A. I did not meet them, no. When I spoke 7 about them, it was when I was massaging him, and he 8 would get off -- he would be on the phone a lot at 9 that time, and one time he said, Oh, that was 10 Leonardo, or, That was Cate Blanchett, or Bruce 11 Willis. That kind of thing. 12 Q. So name-dropping? 13 A. Yes. 14 Q. So you had not met Cate Blanchett or 15 Leonardo DiCaprio? 16 A. I have not. 17 Q Would you remember if you had? 18 A I would hope I would remember. 19 Q Did you meet Cameron Diaz? 20 A No. 21 Q. Bill Clinton? 22 A No. 23 Q Did you see Bill Clinton on the island? 24 A No. 25 Q Did you see Bill Clinton in a helicopter MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 110 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 109 being flown by Ghislaine Maxwell? A. No. Q. Did Ghislaine Maxwell ever tell you that she had flown Bill Clinton in her helicopter? MS. McCAWLEY: Objection. THE WITNESS: I don't recall her saying that. BY MS. MENNINGER: Q. Did you ever meet Senator ? A. I don't know what he looks like. I might have. Q. If I told you he was from Maine, would that stick out in your mind? A. It should, but I do not recall meeting him. Q. Do you ever remember meeting Prime Minister Ehud Barak from Israel? A. No. Do you recall meeting any prime minister? No. Any foreign president? No. Nobel Prize winners? Not to my knowledge. Oo FP OO FP O FP HO Naomi Campbell? MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 111 of 179 Page 110 1 A. No. 2 Q. Al Gore? 3 A. No. 4 Q. Alan Dershowitz? 5 A. No. 6 Q. Les Wexner? 7 A. No. 8 Q. Tom Pritzker? 9 A. No. 10 Q. Kevin Spacey? I may have already asked 11 you, but have you met Kevin Spacey? 12 A. No. 13 Q. Did you meet Governor Bill Richardson of 14 New Mexico? 15 A. Hmm, I want to say that he was supposed to 16 come to dinner when we were in New Mexico. I don't 17 know if I met him. I believe that he and Ghislaine 18 had dinner separate from myself. 19 Q. Jean Luc Brunel? 20 A Yes. 21 Q. You did meet him? 22 A. Yes. 23 Q Tell me about that. 24 A. He was just in the house at one time in 25 Palm Beach. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 112 of 179 Page 111 1 Q. Socializing? 2 A. Yes. 3 Q. Did you observe him to be with underaged 4 girls? 5 A. I don't recall. 6 Q. Did you give him a massage? 7 A. I don't think I did. I gave a lot of 8 guests massages. I don't remember any of their 9 names. So it could have been any of those people 10 besides the movie stars. 11 Q. You would know? 12 A. Exactly. 13 Q. And did you engage in sexual contact with 14 any of the guests for whom you gave a massage? 15 A. No. That's why he would call me for his 16 guests, because I was not comfortable with the 17 sexual contact. So he still wanted to employ me as 18 a massage therapist, but it was all normal. 19 Q. So this was an actual conversation that 20 you had? 21 A. No, but I -- I noticed. I noticed that I 22 wasn't -- I was massaging him less and less and 23 massaging his guests more. 24 Q. So there was a change in the frequency 25 with which you were giving Jeffrey Epstein massages? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 113 of 179 Page 112 1 A. Right. 2 Q. And an increase corresponding to massages 3 you were giving to guests, correct? 4 A. Yes. 5 Q. Did any of the guests for whom you gave a 6 massage mention that they expected something sexual? 7 A. No. 8 Q. Did they ask you to engage in sexual 9 contact and you refused? 10 MS. McCAWLEY: Objection. 11 THE WITNESS: No. 12 BY MS. MENNINGER: 13 Q. Marvin Minsky? 14 A. I don't know that. 15 Q. George Lucas? 16 A. No. 17 Q. Donald Trump? 18 A. No. 19 Q. Did you ever massage Donald Trump? 20 A. No. 21 Q. Sorry, I have to ask, but did you ever 22 have sex with Alan Dershowitz in the back of a 23 limousine with Virginia and Jeffrey present? 24 MS. McCAWLEY: Objection. 25 THE WITNESS: Absolutely not. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 114 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 113 BY MS. MENNINGER: Q A. Q. A Q. Do you know who Alan Dershowitz is? I do. You would remember -- I would remember that. Did you ever see Virginia Roberts with any of the people that I just asked you about? A. Q. No. Did Virginia ever talk to you about having been with any of those people? MS. McCAWLEY: Objection. THE WITNESS: No. BY MS. MENNINGER: Q. Did she tell you that she had met any of those people? A. No. Q. I believe you saw in that police report a reference to a friend of Jeffrey named Glenn and his wife? A. Uh-huh. Q. Do you remember them? A. Vaguely. Q. Tell me what you remember. A. I remember they had an apartment in -- on Breakers Row. I went up there and massaged. It may MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 115 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have Page 114 been more than once, but I only really remember one time. But there was nothing sexual. Q. Neither with the wife, nor with Glenn? A. Right. Q. Do you remember the apartment? A. I only remember that I had to carry my massage table up some stairs. Q. So you actually gave the massage ona massage table? when some A. Yes. Q. Does that help you place it in time as to that might have occurred? In other words -- A. Well -- Q. -- did you get your massage license at point and a massage table? MS. McCAWLEY: Objection. THE WITNESS: Yes. He bought me my massage table around the time that I went to massage school. So it could have been any time after. If I thought really hard, I could remember when I went to school. But it -- I want to say it's around 2003. BY MS. MENNINGER: Q. Nothing sexual happened with Glenn? A. No. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 116 of 179 i) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q. the floor > FP Oo FP OO FP O FP O Q. Page 115 Did Glenn ask you to give him a massage on of the home? I don't recall. Did you ever discuss Glenn with Virginia? Not to my recollection. Did you ever go to Virginia's home? No. Do you know where she lived? No. Did she talk about it? Not that I remember. Did you see anything in your interactions with Virginia that led you to believe that she was a sex slave? MS. McCAWLEY: Objection. THE WITNESS: No. BY MS. MENNINGER: Q. Did you see anyone forcing her to remain in the home? A. Q. point? No. Did you see her look traumatized at some MS. McCAWLEY: Objection. THE WITNESS: No. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 117 of 179 Page 116 1 BY MS. MENNINGER: 2 Q. Did you see anything that led you to 3 believe Virginia Roberts had been trafficked, 4 sexually trafficked to third parties? 5 MS. McCAWLEY: Objection. 6 THE WITNESS: No. 7 BY MS. MENNINGER: 8 Q. Did Virginia ever tell you that she had 9 been trafficked? 10 A. No. 11 MS. McCAWLEY: Objection. 12 BY MS. MENNINGER: 13 Q. Did you hear anyone direct Virginia 14 Roberts to go have sex with someone? 15 A. No. 16 Q. Did Jeffrey ever ask you to go have sex 17 with another person? 18 A. No. 19 Q. Did Ghislaine Maxwell ever ask you to go 20 have sex with another person? 21 A. No. 22 Q. Did Ghislaine Maxwell ever ask you to give 23 a massage to someone else? 24 A. No. 25 Q. Did Ghislaine Maxwell ever ask you to MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 118 of 179 Page 117 1 dress up in any outfit? 2 A. No. 3 Q. Did she ever buy you an outfit for you to 4 wear in terms of a sexual profile? 5 A. No. 6 Q. Did she tell you what kind of clothes you 7 should buy? 8 A. No. 9 Q. Did she direct you to go get Brazilian 10 bikini waxes? 11 A. No. 12 Q. Did she direct you to go get your teeth 13 whitened? 14 A. No. 15 MS. MENNINGER: I would like to mark as an 16 exhibit -- I have no recollection what number 17 we're on. Thank you. Exhibit 5. 18 (The referred-to document was marked by 19 the court reporter for Identification as 20 Sjoberg Exhibit 5.) 21 BY MS. MENNINGER: 22 Q. Have you seen this article before? 23 A. It has followed me everywhere. 24 MS. McCAWLEY: I'm sorry. Can I just ask 25 you to put the Bates numbers on the record? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 119 of 179 Page 118 1 MS. MENNINGER: Sure. It's Bates marked 2 Giuffre 1131 through 1138. 3 BY MS. MENNINGER: 4 Q. What do you mean it has followed you 5 everywhere? 6 A. Well, if you Google me, it comes up. 7 Q. I wanted to just ask you a couple of 8 questions. 9 On the third page, towards the bottom, 10 there is a photograph that begins "we had a picture 11 taken," and just to orient you, this is in the 12 discussion around the Prince Andrew meeting you had. 13 Did you meet Prince Andrew any other time 14 besides the time you already described in your 15 testimony? 16 A. No. 17 Q. Tf you want to take a look at that 18 paragraph before I ask you questions. 19 A. Okay. 20 Q. In that paragraph, it describes that 21 Andrew -- Virginia sat on the chair, and then Andrew 22 sat on another chair, and you sat on his lap. 23 MS. McCAWLEY: Objection. 24 BY MS. MENNINGER: 25 Q. Is that what it says? MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 120 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 119 A. That's what it says. Q. Do you recall telling that to the reporter? A. Yes. QO And this was back in 2007 or so? A. Yes. Q As you sit here today, does that make it -- does that refresh your recollection that Virginia was sitting in one chair and you were sitting on another, with Andrew? A. Yeah. If I said that, then I remember it that way. I'm just trying to remember. Whether we were on a couch or a chair, I just remember the boobs part, the hand on the boobs. Q. IT understand that part stands out. And I also completely understand if you don't remember things that happened a long time ago. A. Right. Q. I'm just wondering if, having looked at this news article, it refreshes your memory that Virginia was sitting ina different place? A. In a different chair? Q. Does it? A. It does say that. Does it refresh my memory? MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 121 of 179 Page 120 1 Q. Okay. That's fine. 2 A. Yeah, sure. 3 Q. If it doesn't, it doesn't. I'm just 4 asking. 5 Did Virginia say anything to you about 6 having met Prince Andrew before this time in New 7 York? 8 MS. McCAWLEY: Objection. 9 THE WITNESS: She did not say. 10 BY MS. MENNINGER: 11 Q. Did Prince Andrew say or do anything that 12 led you to believe that he had met Virginia prior to 13 that time? 14 A. I don't recall. 15 Q. Did you ever see Al Gore on the island? 16 A. No. 17 Q. Did you see his wife, Tipper Gore, on the 18 island? 19 A. No. 20 Q. What is your understanding of what the 21 lawsuit we are here today is about? 22 A. I understand that Ghislaine is calling 23 Virginia a liar, and so Ghislaine is suing Virginia. 24 I'm sorry. Strike that. Reverse it. 25 Right, Virginia is suing Ghislaine for MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 122 of 179 Page 121 1 defamation. 2 Q. And do you know what Virginia said about 3 Ghislaine? 4 A. That Ghislaine recruited her. 5 Q. Do you know anything else that Virginia 6 said about Ghislaine? 7 A. Only what was spoken to me. 8 Q. And I should clarify. Don't tell me 9 anything your lawyer has conveyed to you. 10 A. Exactly. That's all I know. I've met 11 with Virginia once last summer. 12 Q. Okay. Tell me about that. 13 A. She -- there was a moderator between us, 14 like an investigator. And she was in Palm Beach. 15 And it was more about Jeffrey. It was less about 16 Ghislaine. I don't remember specifically about 17 Ghislaine at all. 18 Q. So you met with Virginia and an 19 investigator at the same time? 20 A. Yes. 21 Q. And they were what, talking to you about 22 Jeffrey in what context? 23 MS. McCAWLEY: Objection. 24 THE WITNESS: Basically, they were trying 25 to find people that would help her get her MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 123 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 122 story out, because this is when Dershowitz -- Dershowitz was saying nothing was happening and he was calling her a liar. And she was just trying to find people to back up her story. BY MS. MENNINGER: Q. And what did you understand her story to be? Did she tell you? A. That she was recruited to give massages, sexual massages, and have sex with people such as Dershowitz and Andrew. But I knew none of that at the time. Q. Right. Did you tell them anything -- did you tell them during that meeting that you knew of anything about her being recruited to give sex to either Jeffrey or to other people? MS. McCAWLEY: Objection. THE WITNESS: Can you rephrase? BY MS. MENNINGER: Q. Yes. That wasn't a very good question. What did you say during this meeting with Virginia and her investigator? A. Basically that I believed her, even though I -- she never spoke to me specifically about what was going on; that once I learned everything that happened based on reading the police report, I MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 124 of 179 Page 123 1 believed her side of the story. 2 Q. And did she tell you what her side of the 3 story was? 4 A. You know, just that she wasn't a liar; 5 that, you know, she was there to have sex with men 6 that Jeffrey wanted her to sleep with. 7 Q. Did she tell you in that meeting who she 8 had sex with? 9 A. No. 10 Q. Did she name any of the famous people? 11 A. Only Dershowitz came up. 12 Q. Did you two talk about the incident in New 13 York with the puppet? 14 A. I don't recall. 15 Q. And you formed this opinion about whether 16 she was a liar based on things that you've read in 17 the police report? 18 MS. McCAWLEY: Objection. 19 THE WITNESS: I formed my opinion based on 20 my experience in the house. 21 BY MS. MENNINGER: 22 Q. Okay. And what experience in the house 23 helped you form your opinion that what Virginia is 24 saying is true? 25 A. You know, Jeffrey being open with me about MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 125 of 179 Page 124 1 what other girls did for him and that I was not one 2 of those girls. 3 He was always trying to recruit me almost 4 in a way that I could be one of them and travel with 5 him and live the life of luxury if I only -- if only 6 I did this. 7 So after five years of learning what was 8 happening, I can look back knowing -- I only knew 9 Virginia for a very short time. Looking back, I can 10 make assumptions about what was required of her. 11 Q. Did she tell you how old she was when she 12 said she started working with Jeffrey? 13 A. She didn't. 14 Q. Did she tell how long she had worked with 15 Jeffrey? 16 A. No. 17 Q. Have you read all the things that have 18 been attributed to her in the press? 19 A. Many of them. 20 MS. McCAWLEY: Objection. 21 THE WITNESS: I don't know that I've read 22 all of them, but I have read some. 23 BY MS. MENNINGER: 24 Q. In this meeting with Virginia and the 25 investigator, you said Ghislaine Maxwell did not MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 126 of 179 Page 125 1 come up? 2 A. Not that -- not that I recall. 3 Q. Do you know the name of the investigator? 4 A. Valerie Rivera. 5 Q. Have you read the statement that Ghislaine 6 Maxwell issued to the press? 7 A. No. 8 Q. Do you know what it says? 9 A. No. 10 Q. You said you have read some of Virginia's 11 statements to the press but not all of them? 12 A. I don't know how many there are. I know I 13 read something. I don't know if I read all of them. 14 Q. Have you read her book manuscript? 15 A. No. 16 MS. McCAWLEY: Objection. 17 BY MS. MENNINGER: 18 Q. Did she tell you that she was writing a 19 book? 20 A. No. 21 Q. Did she tell you she was trying to get a 22 book deal? 23 MS. McCAWLEY: Objection. 24 THE WITNESS: No. 25 MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 127 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 126 BY MS. MENNINGER: Q. Did she tell you that he hired a ghost rider? A. No. MS. McCAWLEY: Objection. BY MS. MENNINGER: Q. Did she tell you that she hired a literary agent? MS. McCAWLEY: Objection. THE WITNESS: No. BY MS. MENNINGER: Q Did you speak with John Connelly? A. Yes. Q. When did you speak with John Connelly? A He was first calling me around the time that everything was coming out in 2006. And I didn't say a lot to him, but I did say a few things. And I asked him not to use my name, and he used my name. And then he quoted me as saying things I never said. Q. Do you know to whom he quoted things that you had never said? A. I don't remember the news outlet, no. Q. So it was published somewhere? A. Somewhere on the Internet. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 128 of 179 Page 127 1 Q. Something that you said to John Connelly 2 got twisted? 3 A. Yes. He put words in my mouth. 4 Q. And it was misreported and published? 5 MS. McCAWLEY: Objection. 6 THE WITNESS: Correct. 7 BY MS. MENNINGER: 8 Q. Have you spoken to him lately? 9 A. No. He called me again at the beginning 10 of last year, around New Year's last year, but I did 11 not return his call. 12 Q. Do you recall what it is he attributed to 13 you falsely? 14 A. It was mostly about how I felt about 15 certain things. I don't remember specifically what 16 he said, but he was giving an opinion for me that I 17 never spoke to him about. 18 Q. And that you did not hold? 19 A. Well, I can't remember what it was. Yeah. 20 Q. Okay. Do you know whether Virginia has 21 lied about any of her experience? 22 MS. McCAWLEY: Objection. 23 THE WITNESS: I don't know that she has 24 lied. 25 MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 129 of 179 Page 128 1 BY MS. MENNINGER: 2 Q. Do you know that she has told the truth? 3 A. As far as I know, she has. 4 Q. Do you know whether the press has 5 accurately reported everything that Virginia has 6 said? 7 MS. McCAWLEY: Objection. 8 THE WITNESS: I don't know. 9 BY MS. MENNINGER: 10 Q. Other than John Connelly and the police, 11 who else have you spoken to about your experience? 12 A. Well, the woman from the Daily Mail. Her 13 name is Wendy Leigh. 14 Q. And that's Defendant's Exhibit 5 -- not 15 Defendant's Exhibit, just Exhibit 5, correct? 16 A. Correct. 17 Q. Did Wendy Leigh accurately report your 18 statements? 19 A. She did a little bit of embellishment, as 20 well, but the facts are all true. 21 Q. And what parts do you believe are 22 embellished? 23 A. Near the end, when she was doing a 24 summary, when she wrote, "Sure, I had a good time, 25 but I also think it damaged me a bit." I don't MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 130 of 179 Page 129 1 recall saying that. 2 And there's another part in here where she 3 said I said that I made a deal with the devil, which 4 I never would have said that. The words she used. 5 Q. On page 2 of 8, it's about -- it's about 6 even with the hem of your skirt. 7 A. "T made a pack with the devil in exchange 8 for excitement and glamour. I was only a college 9 student. I was hard-up and foolish." 10 That I never said, any of that. Iwasa 11 college student, that's true. "Hard-up and 12 foolish," I would have never called myself foolish. 13 Q. Were you paid any money for this 14 interview? 15 A. I was paid $1,500. 16 Q And how long did the interview last? 17 A. A couple of hours. 18 Q. Where did it take place? 19 A At Cafe Boulud in the Brazilian Court 20 Hotel in Palm Beach. 21 Q. Who else besides Wendy Leigh and John 22 Connelly and the police -- 23 MS. McCAWLEY: Objection. 24 BY MS. MENNINGER: 25 Q. -- and Virginia and the investigator -- MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 131 of 179 i) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 130 MS. McCAWLEY: Objection. BY MS. MENNINGER: Q -- did you talk to about your experience? A. Family and friends. Q. Did you speak to any other reporters? A I had other reporters calling me. I avoided almost all of the calls. I had someone coming at me, stalking me. I do not know who he was. He offered me $25,000 to give a story, and I turned him down. Q. Who? A. He showed up in my work multiple times. Q. There were other stories printed in the Daily Mail, not by Wendy Leigh, later. Did you see any of those stories? I'm sorry. Let me be a little clearer. That attributed comments to you. A. I don't recall specifically, but I feel like I stayed on top of it, and I wasn't surprised when my name was brought up. Q. Do you recall giving another interview? A. No, never. Q. Do you recall anything that was printed other than the John Connelly thing that you believe to be inaccurate? MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 132 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A. Q. Page 131 No. Was there anybody else present when you were interviewing with Wendy Leigh? A. Q A. Q. A Q. recording A. Q. A. Q. No. Was she recording it on a recorder? Yes. Have you ever heard that recording? No. Do you know whether the police were their interview with you? Yes. Have you ever heard that recording? No. Did you ever receive notification that you were named as a victim in any of Jeffrey Epstein's criminal cases? A. Q. No. Other than the $1,500 from Wendy Leigh, did you receive any other money for making any statements A. Q. attorneys? A. 2 No. Did you give an interview to Virginia's Yes. Right? MS. McCAWLEY: You can say yes. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 133 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 132 BY MS. MENNINGER: Q A Q. A Q A When was that? Two weeks ago, roughly. And who was present during that meeting? My lawyer and several others. Several other what? Lawyers. I don't know. I don't know who they all are. Q. > IO P there. Oo FP OO PF OO remember. Q. it? A. Q. meeting? So Ms. McCawley you recall being there? Yes. Ms. Schultz you recall being there? No. I didn't learn it, no. You weren't Brad Edwards? Yes. Paul Cassell? Maybe. I don't remember. And was that interview recorded? IT don't know. It may have been. TI don't Did anyone ask your permission to record Maybe. I don't recall. Were you shown any documents during that MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 134 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 > O P Q. Page 133 Flight logs. Any other documents? No. What did Ms. McCawley or Mr. Edwards or any of the other lawyers say to you about Ghislaine Maxwell? A. They just asked impressions. They never said anything about her. Q. Were you shown a copy of any report that came out of that interview? A. Q. BY MS. Q. Which interview? The one with the -- Virginia's attorneys. MS. McCAWLEY: Objection. THE WITNESS: No. MENNINGER: You testified earlier about an incident with a camera that Ghislaine Maxwell had given you. I want to ask you some questions about that. A. Q. A. Q. A. sure. Do you know when that was? That was in 2002. And why does that date stick out? Because I was living -- where I was living specifically and where I had the phone call. Q. Tell me what you remember about the MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 135 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 134 conversation. A. I had been over to her house prior massaging Jeffrey. And I got a phone call from her, and she told me she had a camera for me for my photography class, but yet, she couldn't give it to me yet because during the massage I didn't finish my job and she had to finish it for me. Q. Did she say what she meant? A. No, but I knew. Q. Was there any other time that you had discussed with her finishing your job? A. Not that I recall. Q. Any other time you just recall discussing with her anything about your sexual contact with Jeffrey? MS. McCAWLEY: Objection. THE WITNESS: No. BY MS. MENNINGER: Did she give you the camera? I did get the camera. Q A Q. Okay. When did she give you the camera? A I guess the next time I went to the house. Q What was said at that time? A I honestly don't know that she handed it to me. I remember it being there for me. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 136 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 > O PP oO anymore. Q. > OO PF ~O Pp class and Q. A. Page 135 What kind of camera was it? A Canon Rebel 35-millimeter. Do you still have it? I do not. No one uses 35-millimeter What's that? No one uses 35-millimeter. Back to the cell phone conversation. Right. Was it your birthday? It was just I was taking a photography I needed a camera. Do you know her to be a photographer? Not a professional, but I knew she was interested in photography. Did you see her with cameras? Yes. Did you see her taking photographs of nude No. Did she ever ask you to take a photograph of you semi-clad or naked? A. Q. Did she ever ask to take a photo of me? Semi-clad or naked. No. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 137 of 179 Page 136 1 Q. Did she ever ask to take a photograph of 2 you at any point? 3 A. I don't remember. 4 Q. Did you tell anyone else about this 5 conversation: You couldn't give it to me now 6 because I hadn't finished my job? 7 A. No. 8 MS. MENNINGER: I think I'm going to 9 reserve the rest of my time for recross, so you 10 all, I guess, can take a break. 11 MR. LOUIS: Can I have one second? 12 MS. MENNINGER: sure. 13 MS. McCAWLEY: We can go off the record? 14 THE VIDEBOGRAPHER: Off the record at 15 12:09. 16 (Thereupon, a recess was taken, after 17 which the following proceedings were held:) 18 THE VIDEOGRAPHER: On the record at 12:10. 19 BY MS. MENNINGER: 20 Q. Sorry, just a couple of more questions. 21 It sounds like maybe there was an 22 additional telephone conference that one might 23 construe as a meeting with attorneys; is that true? 24 A. Correct. 25 Q. All right. Tell me about that. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 138 of 179 1 A. They just wanted to -- we had met prior, 3 a few more questions. 4 Q. Okay. What did they clarify? 5 A. Any other specific times that I had, you 6 know, seen Ghislaine naked, or if I had, you know, 7 had any sexual massages with her, any type of 8 guestions like that. 9 Q. Okay. And what did you tell them about 10 having any sexual massages with Ghislaine? 11 A. That I was not asked to do -- to perform 12 anything with her. 13 Q. And you did not? 14 A. Correct. 15 Q. And what did you tell them about specific 16 times of seeing Ghislaine Maxwell naked? 17 A. Only when she would swim or get a massage. 18 Q. And that's swimming -- you mentioned 19 earlier skinny-dipping? 20 A. Correct. 21 Q. And I think you said perhaps some other 22 time that you saw her jump off a dock and swim -- 23 A. Correct, yes. 24 Q. -- in the nude? 25 A. Yes. Page 137 2 and they just wanted to clarify a few things and ask MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 139 of 179 Page 138 1 Q. And then you saw her under a towel during 2 massages? 3 A. Yes. 4 Q. Is there any other time that you recall 5 seeing Ghislaine Maxwell naked? 6 A. No. 7 Q. Is there anything else about that 8 telephone conference with the attorneys to clarify 9 that you recall, the topics? 10 A. No. 11 MS. MENNINGER: All right. Thank you. I 12 think we can go off the record now. 13 THE VIDEBOGRAPHER: Off the record at 14 12:12. 15 (Thereupon, a lunch recess was taken, 16 after which the following proceedings were 17 held:) 18 THE VIDEOGRAPHER: On the record at 12:54. 19 FURTHER EXAMINATION 20 BY MS. McCAWLEY: 21 Q. Johanna, I'm going to ask you a couple of 22 more just follow-up questions. 23 When Laura was talking to you, she 24 mentioned some names of famous people that you -- 25 most of which you had not met. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 140 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 139 Did you ever meet anybody famous when you were with Jeffrey? A. I met Michael Jackson. Q. Oh, really? And where was that? A. At his house in Palm Beach. At Jeffrey's house in Palm Beach. Q. Did you massage him? A. I did not. Q. Anybody else you remember? I know you mentioned David Copperfield earlier. Anybody else? A. No, I'd remember that. Q. I believe you also testified that you had never had a massage before you started working with Jeffrey and Ghislaine; is that correct? A. I don't recall having a massage before then. Q. And I think you said on the first day, when you were doing the clerical work, Maxwell mentioned that you might be able to get a massage; is that correct? A. Yes. Q. Did you tell Maxwell that you had never had a massage at that point? A. I don't remember. Q. Did you remember telling Jeffrey that you MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 141 of 179 Page 140 1 had never had a massage? 2 A. No. 3 Q. And then you were talking about the 4 massage -- the first massage when you were being in 5 the room with Jeffrey and Emmy? 6 A. Uh-huh. 7 Q. And I know you said Emmy was naked or took 8 off her clothes at some point? 9 A. Uh-huh. 10 Q. And then laid on the table. 11 And then you changed positions with her; 12 is that what happened? 13 A. Yes. I don't remember the sequence, but 14 at one point she was, I was, and Jeffrey was. 15 Q. And in the -- in the time when there was 16 changeover, for example, when you're on the table 17 and Emmy is not on the table and Jeffrey is not on 18 the table, did Emmy at that point remain naked or 19 did she actually stop and get dressed and continue 20 massaging? 21 A. I don't recall her getting dressed, but I 22 would probably remember if she massaged naked. 23 Q. Do you know if Jeffrey remained naked 24 during that massage? 25 A. He was never, like, naked standing up. He MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 142 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 141 always covered himself with a towel. Q. I believe I asked this, but I just want to clarify to make sure that I did: Did Maxwell ever ask you to bring other girls over to -- for Jeffrey? A. Yes. Q. Yes? A. Yes. Q. And what did you -- did you do anything in response to that? A. I did bring one girl named -- no. -- it was some girl named that I had worked with at a restaurant. And I recall Ghislaine giving me money to bring her over; however, they never called her to come. Q. And then I believe you mentioned that one of your physical fitness instructors, you brought a physical fitness instructor; was that correct? A. Correct. Q. And what did she do? A. She gave him a -- like a training session, twice. Q. Twice. Did anything sexual in nature happen during the session? A. At one point he lifted up her shirt and MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 143 of 179 Page 142 1 exposed her bra, and she grabbed it and pulled it 2 down. 3 Q. Anything else? 4 A. That was the conversation that he had told 5 her that he had taken this girl's virginity, the 6 girl by the pool. 7 Q. Okay. Did Maxwell ever say to you that it 8 takes the pressure off of her to have other girls 9 around? 10 A. She implied that, yes. 11 Q. In what way? 12 A. Sexually. 13 Q. And earlier Laura asked you, I believe, if 14 Maxwell ever asked you to perform any sexual acts, 15 and I believe your testimony was no, but then you 16 also previously stated that during the camera 17 incident that Maxwell had talked to you about not 18 finishing the job. 19 Did you understand "not finishing the job" 20 meaning bringing Jeffrey to orgasm? 21 MS. MENNINGER: Objection, leading, form. 22 BY MS. McCAWLEY: 23 Q. I'm sorry, Johanna, let me correct that 24 question. 25 What did you understand Maxwell to mean MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 144 of 179 Page 143 1 when she said you hadn't finished the job, with 2 respect to the camera? 3 MS. MENNINGER: Objection, leading, form. 4 THE WITNESS: She implied that I had not 5 brought him to orgasm. 6 BY MS. McCAWLEY: 7 Q. So is it fair to say that Maxwell expected 8 you to perform sexual acts when you were massaging 9 Jeffrey? 10 MS. MENNINGER: Objection, leading, form, 11 foundation. 12 THE WITNESS: I can answer? 13 Yes, I took that conversation to mean that 14 is what was expected of me. 15 BY MS. McCAWLEY: 16 Q. And then you mentioned, I believe, when 17 you were testifying earlier that Jeffrey told you a 18 story about sex on the plane. What was that about? 19 MS. MENNINGER: Objection, hearsay. 20 THE WITNESS: He told me one time Emmy was 21 sleeping on the plane, and they were getting 22 ready to land. And he went and woke her up, 23 and she thought that meant he wanted a blow 24 job, so she started to unzip his pants, and he 25 said, No, no, no, you just have to be awake for MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 145 of 179 Page 144 1 landing. 2 BY MS. McCAWLEY: 3 Q. Do you recall witnessing any sexual acts 4 on the plane? 5 A. No. 6 Q. Did Emmy ever talk to you about performing 7 sexual acts on the plane? 8 A. No. 9 Q. We looked earlier at the police report, 10 and I just want to clarify, you identified some 11 areas where there were discrepancies in that report. 12 And you can take another look at it if you 13 want, but other than the discrepancies you pointed 14 out, is that a recollection of what you remember 15 telling the detective? 16 A. Yes. 17 MS. MENNINGER: Objection, outside the 18 scope of cross. 19 BY MS. McCAWLEY: 20 Q. You mentioned that there was a time when 21 you noticed that Maxwell was around a little bit 22 less? 23 A. Uh-huh. 24 Q. And I believe you said that was during the 25 middle of the time you were with Jeffrey. MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 146 of 179 Page 145 1 Do you remember approximately when that 2 was year-wise? 3 A. I don't. I would say it was probably 4 sometime between 2003 and 2004. 5 Q. And what made you think that? 6 A. I just saw her less and less at the house. 7 Q. Were you there more at the house during 8 that time period? 9 A. No, not necessarily. It's just at the 10 beginning, she was around a lot. And then I would 11 see her occasionally without him. The one time we 12 spent a few days together in 2006, she wasn't there 13 at all. 14 Q. So you saw her in the -- is it fair to say 15 that you saw her in the 2005 and 2006 time frame? 16 A. Yes. 17 Q. Then we were talking about the photography 18 earlier and about the photographs. 19 Did Maxwell ever ask you to take nude 20 photos of yourself for Jeffrey? 21 A. She asked me to take photos of myself for 22 Jeffrey, yes. 23 Q. And did you do that? 24 A. I did not. 25 Q. And the photos that were around that were MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 147 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 146 in the bathroom, that you mentioned a couple of times places that there were photos of you, who took those? A. He did. Q. And when we were talking about the Palm Beach house and you were describing an area where there were just a lot of photographs, is it fair to say that there could have been nude photographs amongst those photos that you saw? A. Yes. Q. And earlier you testified that you don't have knowledge of what happens behind closed doors, but you also said that Jeffrey had told you what other girls did for him and that he wanted you to do those things for him. Is it fair to say that you knew that other girls were performing sexual acts? A. Yes. MS. MENNINGER: Objection, foundation, form. BY MS. McCAWLEY: Q. And I know you mentioned previously that your relationship and the interaction with him progressed over time. Did there come a time when you were MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 148 of 179 Page 147 1 expected to have sexual intercourse with Jeffrey? 2 A. Yes. 3 Q. And when was that? 4 A. 2005. 5 MS. McCAWLEY: That's it. I just do want 6 to also put on the record that we're 7 designating the testimony as confidential under 8 the protective order. 9 FURTHER EXAMINATION 10 BY MS. MENNINGER: 11 Q. Okay. You just testified that you have 12 knowledge -- you had knowledge that -- of what 13 Jeffrey was doing behind closed doors with other 14 girls. Was that your testimony? 15 A. Based on what he had told me. 16 Q. Okay. So Jeffrey told you things that he 17 had done with other girls? 18 A. Yes. 19 Q You did not observe any of those things? 20 A. No. 21 Q You did not talk to any of those girls 22 about what they had done with Jeffrey behind closed 23 doors? 24 MS. McCAWLEY: Objection. 25 MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 149 of 179 1 BY MS. MENNINGER: 2 Q. Correct? 3 A. No. Correct. 4 Q. The only source of knowledge you have is 5 based on what Jeffrey told you he had done with 6 other girls? 7 A. Correct. 8 MS. McCAWLEY: Objection. 9 BY MS. MENNINGER: 10 Q. You said that there were possibly nude 11 photos amongst the other photos that you saw on 12 various walls at the Palm Beach house, correct? 13 A. Correct. 14 Q None of them stood out to you? 15 A. Correct. 16 Q. None of them appeared pornographic? 17 A No. 18 Q. You didn't see any fully frontally nude 19 photographs, correct? 20 A. No, not that I recall. 21 Q. And you don't recall seeing any girls that 22 appeared to be underaged, correct? 23 A. No. 24 Q. You said Ghislaine asked you to take 25 photos of yourself for Jeffrey, correct? Page 148 MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 150 of 179 1 A. Correct. 2 Q. Did she ask you to take a nude photograph 3 of yourself or just a photograph of yourself? 4 A. A nude photograph of myself. 5 Q. What exactly did she say to you? 6 A. I don't remember exactly, but I know that 7 I never felt comfortable. I would have felt fine 8 taking photos of myself, my face, but I knew I was 9 never comfortable with it because I had to take 10 photos of my body. And I also didn't know how to 11 take a photo from standing behind. You have to have 12 someone else involved. 13 Q. That's my question. How would you take a 14 nude photograph of yourself? 15 A. Exactly. Someone else would have to do 16 it. 17 Q. Do you recall any of the particulars of 18 what she said to you that led you to believe she 19 wanted you to do that? 20 A. No, just asking for the photos. 21 Q. Do you know when in your time there? 22 A. It was near the beginning, because that's 23 when I was interested in the photography. 24 Q. Was it in the context of your discussion 25 of your photography class? Page 149 MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 151 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 150 A. No. Q. Was it in the context of anything? A. About the camera that she had bought for me. Q. What did she say in relationship to the camera that she bought for you and taking photographs of you? A. Just that Jeffrey would like to have some photos of me, and she asked me to take photos of myself. Q. What did you say? A. I don't remember saying no, but I never ended up following through. I think I tried once. Q. This was the pre-selfie era, correct? A. Exactly. Q. I want to go back to this: You testified to two things just now with Sigrid that you said were implied to you. A. Okay. Q. The first one was it would take pressure off of Maxwell to have more girls around? A. Right. Q. What exactly did Maxwell say to you that led you to believe that was her implication? A. She said she doesn't have the time or MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 152 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 151 desire to please him as much as he needs, and that's why there Q. were other girls around. And did she refer specifically to any other girls? > O© PF OO P Q. that were A. Q. correct? A. Q. A. No. Did she talk about underaged girls? No. Was she talking about massage therapists? Not specifically. Okay. There were other girls in the house not massage therapists, correct? Yes. Nadia is another person that was around, Yes. There were other people he traveled with? Uh-huh. MS. McCAWLEY: Objection. BY MS. MENNINGER: Q A Q. A Q A Correct? Correct. Other girls? Yes. Adults? Yes. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 153 of 179 Page 152 1 Q. When I say "girl," I really mean women, 2 correct? 3 A. Correct. 4 Q. There were other women around who hung out 5 with Jeffrey, and you don't know what they did 6 behind closed doors, correct? 7 A. Correct. 8 Q. So when you heard the implication that she 9 wanted other girls around to take the pressure off 10 of her sexually, in your mind that meant other adult 11 women that he had in his life, correct? 12 MS. McCAWLEY: Objection. 13 THE WITNESS: Correct, doing what I was 14 expected to do in a massage, you know. 15 BY MS. MENNINGER: 16 Q. Ghislaine didn't have anything to do with 17 you bringing this woman over for a physical workout 18 with Jeffrey, correct? 19 A. Correct. 20 Q. She asked you to bring another girl to 21 be -- to perform massages at the home? 22 A. Yes. Well, she was always asking if I 23 knew anyone else. And so I brought this one girl 24 that I didn't even know I worked with her at a 25 restaurant. So I didn't care what she thought of me MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 154 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 153 if anything happened. And so -- but it never turned into anything. Q. She was an adult? A. She was an adult. Q. Working at a restaurant with you? A. Yes. Q. What restaurant was that? A. It's a restaurant that's closed. It's called Q. You were asked about the famous people. You said you met Michael Jackson? A. Yes. Q. But you did not give him a massage? A. No. Q. There were other famous people, perhaps, who were around Jeffrey's home that you didn't meet, correct? A. Correct. Q. Do you know whether Virginia Roberts has told the truth about the age she was when she met Ghislaine Maxwell? MS. McCAWLEY: Objection. Exceeds the scope of cross. THE WITNESS: I don't have any idea what she told them in terms of her age. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 155 of 179 1 BY MS. MENNINGER: 3 the truth about whether she spent her sweet 16th 4 birthday with Jeffrey and Ghislaine Maxwell? 5 MS. McCAWLEY: Objection. 6 THE WITNESS: I don't know anything about 7 that. 8 BY MS. MENNINGER: 9 Q. Do you know whether Virginia Roberts is 10 telling the truth about whether Ghislaine Maxwell 11 sexually assaulted her on her first day on the job? 12 MS. McCAWLEY: Objection. 13 THE WITNESS: I have not knowledge of 14 that. 15 BY MS. MENNINGER: 16 Q. Do you have any knowledge of whether 17 Virginia Roberts is telling the truth about 18 Virginia -- excuse me -- about Ghislaine Maxwell 19 forcing Virginia Roberts to "go down" on her? 20 MS. McCAWLEY: Objection. 21 THE WITNESS: No knowledge. 22 BY MS. MENNINGER: 23 Q. Do you have any knowledge about whether 25 Ghislaine Maxwell forced her to participate in Page 154 2 Q. Do you know if Virginia Roberts is telling 24 Virginia Roberts is telling the truth about whether MAGNA®© LEGAL SERVICESCase 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 156 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 155 orgies with other women? MS. McCAWLEY: Objection. THE WITNESS: No. BY MS. MENNINGER: Q. Do you have any Knowledge about whether Virginia Roberts is telling the truth about whether Ghislaine Maxwell directed her to have sex with Prince Andrew? MS. McCAWLEY: Objection. THE WITNESS: No. Only based on what I've read in the media. BY MS. MENNINGER: Q. And Alan Dershowitz? MS. McCAWLEY: Objection. THE WITNESS: The same. BY MS. MENNINGER: Q. Prime ministers? MS. McCAWLEY: Objection. THE WITNESS: No. BY MS. MENNINGER: Q. Do you have any Knowledge about whether Virginia Roberts is telling the truth about foreign presidents? MS. McCAWLEY: Objection. THE WITNESS: No knowledge. MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 157 of 179 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 156 BY MS. MENNINGER: Q. Do you know whether Virginia Roberts is telling the truth about Ghislaine Maxwell forcing her to participate in an orgy with Prince Andrew and other underaged girls on the island? MS. McCAWLEY: Objection. THE WITNESS: No knowledge. BY MS. MENNINGER: Q. Did Ghislaine Maxwell ever ask you to have her baby? MS. McCAWLEY: Objection. THE WITNESS: No. MS. MENNINGER: No further questions. MS. McCAWLEY: Thank you for your time. THE WITNESS: We are done. MS. McCAWLEY: We are off the record. THE VIDEOGRAPHER: The time is 1:11. This concludes the video deposition. Off the record. (Thereupon, the taking of the deposition was concluded at 1:11 p.m.) MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 158 of 179 i) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 157 AFFIDAVIT STATE OF FLORIDA ) COUNTY OF ) I, , being first duly sworn, do hereby acknowledge that I did read a true and certified copy of my deposition which was taken in the case of GIUFFRE V. MAXWELL, taken on the 18th day of May, 2016, and the corrections I desire to make are as indicated on the attached Errata Sheet. CERTIFICATE STATE OF FLORIDA ) COUNTY OF ) Before me personally appeared 7 to me well known / known to me to be the person described in and who executed the foregoing instrument and acknowledged to and before me that he executed the said instrument in the capacity and for the purpose therein expressed. Witness my hand and official seal, this _ day of ' (Notary Public) My Commission Expires: MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 159 of 179 Oo AN vn Oo FP W NY FP 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ERRATA SHEET PAGE LINE REMARKS Page 158 Signature of Witness (Notary Public) Dated this day of MY Commission Expires: MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 160 of 179 PF Oo WO Oo JN WD Oo FBP W NY FP RoR 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 159 CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF MIAMI-DADE ) I, the undersigned authority, certify that JOHANNA SJOBERG personally appeared before me and was duly sworn. WITNESS my hand and official seal this 18th day of May, 2016. KELLI ANN WILLIS, RPR, CRR Notary Public, State of Florida My Commission No. FF911443 Expires: 2/16/21 ++ et etet ete tet testes MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 161 of 179 CO NY BD OO WB 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 160 CERTIFICATE STATE OF FLORIDA ) ss COUNTY OF MIAMI-DADE ) I, KELLI ANN WILLIS, a Registered Professional, Certified Realtime Reporter and Notary Public within and for The State of Florida, do hereby certify: That JOHANNA SJOBERG, the witness whose deposition is hereinbefore set forth was duly sworn by me and that such Deposition is a true record of the testimony given by the witness. I further certify that I am not related to any of the parties to this action by blood Or marriage, and that I am in no way interested in the outcome of this matter. IN WITNESS WHEREOF, I have hereunto set my hand this 18th day of May, 2016. KELLI ANN WILLIS, RPR, CRR MAGNA®© LEGAL SERVICES MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 163 of 179 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 164 of 179 Page 3 MAGNA®© LEGAL SERVICES MAGNA®©® MAGNA®Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 167 of 179 Page 6 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 168 of 179 MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 169 of 179 MAGNA®© LEGAL SERVICES MAGNA®© LEGAL SERVICES MAGNA®MAGNA®© LEGAL SERVICES MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 174 of 179 DP MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 175 of 179 Page 14 MAGNA®© LEGAL SERVICES MAGNA®© LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 177 of 179 Page 16 MAGNA®© LEGAL SERVICES MAGNA®© LEGAL SERVICES MAGNA®© LEGAL SERVICES EXHIBIT 7 PART 2 Geese sq AR33 LAW s DeuMmAetI4GE3 AiKenCBHOSIat FRagexcatap wee ae we er re ere ee ee ee ae ee nr er en ee ae ne a a ee eee eee ee ae a en a a a ew ee ee ee ee ewe ee ee Yate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 45 Time: 15:01:37 Incident Report Program: CMS301L tase No. . . . : 1-05-000368 (Continued) photographed by CSI Pavlik and then videotaped by myself. ‘The search was concluded at approximately 3:05 p.m. whereupon Detective Recarey and I were the last two officers in the house. Upon securing the residence we met with the gentleman who identified himself to Detective Recarey as the lawyer for the defendant and he was informed that the residence was secured and that copies of the inventory return had been left on the first floor table of the personal assistant's office. Detective Recarey and I returned to Police Headquarters and secured for the day. KKK EKER KEKKEKKKEHKRKEKKEEKKKaE N AR R A - I Vv EB # 14 Re eR KKK KKH HAM KEK KH KEEKEE a Reported By: DAWSON, MICHAEL C. 11/07/05 Entered By.: ALTOMARO, NICKIE A. 11/07/05 On October 20, 2005, I assisted Defective Recarey in the execution of a search warrant at 358 El Brillo Way, Palm Beach, Florida, 33480, Upon the announcement of the search warrant, immediate contact was made with three white males who came out of the house or surrounding structures. Those males were identified as Janusz Banasiak, Daniel Estes, and Mark Zeff. As other members of the police department cleared the home, I kept watch over these three males. Once the house was cleared, those males were turned over to Detective Recarey. Detective Dicks and I were assigned to assist in the search of the main house, the cabana and the servant's guarters. We started in the garage. All areas of the garage were searched to include four vehicles, These vehicles were three black Mercedes Benz cars registered to Jeffrey Epstein. The fourth vehicle was a Harley Davidson motorcycle, green in color, registered to Jeffrey Epstein Nothing was recovered from the garage- A towel closet and pantry located off the kitchen were searched and yielded negative results. The kitchen was searched and taken into evidence was a phone message book that was located near a house phone. North of the kitchen was an office room which contained a computer. The room had a closet that contained a locked gun locker, The combination was entered by Banasiak in the presence of Sgt. Frick and the safe was opened. Items were taken from the room. See the completed property receipt for a detailed list. A green bathroom located on the first floor was searched and nothing was taken. A closet located just west of the green bathroom was searched. Two massage tables were located in the closet along with a photo of a nude GIUFFRE000046Geese sq ARR LAW s DerumeetI4G+3 AiKenRHOSIa4 FRageBoata Yate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 46 fime: 15:01:37 Incident Report Program: CMS301L tase No. . . . : 1-05-000368 (Continued) female from the waist up. See the property receipt for details. I searched two bedrooms and their adjoining bathrooms, which were located on the second floor on the East side of the house. In the Northeast bedroom closet I found adult sex toys called Twin Torpedoes. Soap made in the shape of a penis and vagina were also found in these upstair bedrooms. See the property receipt for details. I searched the pool cabana located on the South side of the pool. Photos were taken from the wall. See the property receipt for details. I assisted in the search of Banasiak's living quarters. Numerous CD s along with a message book was seized. See the property receipt for details. KER AKRKR HEE EEREE KEKE AKAHAERHAKEEEE N A R R A TT I V E # 15 REE EER KEKE HEE HEKKEKEE 4 Reported By: RECAREY, JOSEPH 11/08/05 Entered By.: ALTOMARO, NICKIE A. 11/08/05 On November 1, 2005, I was contacted by Atty. Gus Fronstin, who advised he was willing to assist with the investigation. Atty. Fronstin advised he would try to have his client, Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would return my call once he received confirmation on the interviews. On November 6, 2005, I attempted contact with Gig at her residence. I left a business card for her to return my call. Upon returning to the police department, I had received a telephone call [on os a I returned her call at EES ond spoke with She made arrangements to respond to the station to provide an interview. At approximately 3:30 pm, she arrived at the Palm Beach Police Station with her boyfriend. Her boyfriend was allowed to sit in the lobby area while Ms, QM was interviewed. I took Ms @aMe to the Detective Bureau Interview room. I closed the door for privacy and explained to her that I appreciated her coming to the police station for the interview. During the sworn taped statement, she advised she was at Jeffrey Epstein s house one time. Approximately two months ago, she was approached by a girl, eam who was dating her roommate, to make some quick money. advised she was in need to make some quick cash to make the rent that month. She agreed to go to the house. She had been told by QM that the massage would have to be done in her underwear. She advised QQ drove with her and brought her into the house. They walked into the kitchen area and took the stairs upstairs. Qiyyyp further stated she was brought into a master bedroom area. She advised she recalled seeing portraits of naked women throughout the room. A massage table was already out near the sauna/shower area in the master bedroom. Epstein entered the room wearing only a towel and GIUFFREQ00047Geese Ls cw Oi AR33 LAW s DeRumRetIzG+3 AiKeNCBHOSIat FRagedt cata late: 7/13/06 PALM BEACH POLICE DEPARTMENT Page: 47 ‘Ime; 15:01:37 Incident Report Program: CMS301L ‘ase No. . - . : 1-05-000368 5 (Continued) introduced himself as Jeff. Q@M advised she recalled she and removed their clothing down to their panties, Epstein lay on his stomach area and they provided a massage on his legs and feet area. I asked @@MMMM if she had any formal massage training and she replied no. QRBMMMMBadvised she was topless and the panties she wore were the boy shorts lace panties. She and4§iililcontinued the massage until the last ten minutes of the massage, Epstein, told QMMMMMto leave the room so that @Q§g could finish the massage. QM Gott dressed and Epstein turned over onto his back. Epstein then removed the towel, which had been around his waist. Epstein laid there naked and requested that @MM—Brub his chest area. stated as she did this, Epstein, began masturbating as she rubbed his chest. QM stated he pulled down her boy short panties and he produced a large white vibrator with a large head. She stated it was within a drawer in his master bathroom. He rubbed the vibrator on her vagina area. WM advised he never penetrated her vagina with the vibrator. He continued to rub her vagina with the vibrator as he continued to masturbate. Gm stated she was very uncomfortable during the incident but knew it was almost over. Epstein climaxed and started to remove himself from the table. He wiped himself with the towel he had on previously and went into the shower area. QQ got dressed and met with@@in the kitchen area. Epstein came into the kitchen and provided@gg $200.00 for bringing @MMMMMB and paid $200.00 to@q— for providing the massage. was told to leave her telephone number with Sarah, his assistant for future contact. Ql provided her cellular telephone number for future contact. was asked if she was recently contacted about this investigation by anyone from the Epstein organization. She replied she was called but it was for work. She stated she was called by Sarah for her to return to work for Epstein. @§@MMMMMBstated work is the term used by Sarah to provide the massage in underwear. QQ advised she declined, as she was not comfortable in providing that type of work. The interview was concluded@ and the videotape was placed into evidence. Investigation Continues.. ERK ERA RHEE RARE EEEEEEEAEE NARRATIVE Ho1LG REKE RH HKHK HARARE HRARK KR RE Reported By: RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 On November 7, 2005, I made telephone contact with (iD Gg who advised she would be able to meet with me at her home. Det. Sandman and I traveled to her home in SR @MmMm™mBand made contact with Qi During a sworn taped statement, GMMR stated she met Jeffrey Epstein through Haley Robson. Robson would approach females who wished to work for him. MMMM stated she was asked to.work for him but declined. QP explained that work means give massages. She was asked about any formal training in providing massages to which she said no. QM said she accompanied Robson and other females GIUFFRE000048Geese sq Oe AR33 LAW s Demet I4G-E3 AiKeACBHOSIa4 FRagescata we eee ee we ew eww eww ew ee ew ew ew ee See ee ei ewe eR Be ee wee eB we ee ee ee ee ee eee eS eee ee Kw — SS = wee ee ee vate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page; 48 “ime: 15:01:37 Incident Report Program: CMS301L lase No. . . 1-05-000368 (Continued) who were taken to Epstein s house to provide massages. further stated she had been to the house approximately 4 or 5 times in the past year. She accompanied Robson a a am, the 14-year-old victim, and Each time the girls were taken over, they were previously told they would have to provide a massage, possibly naked. It was also told that should Epstein require them to do anything extra and they were not comfortable just-to tell him and he would stop. QQ stated Robson received $200.00 for each girl she brought over to massage Jeffrey Epstein. When I asked which girl appeared to be the youngest, the victim, as she stated she was fifteen years old at she replied, the most; she looked really young. QM further stated each time she went to the house, she sat in the kitchen and waited with Robson until the massage was over. She further stated that the cook would make lunch or a snack for them as they waited. I asked her if there was anything that caught her attention within the home. stated there were a lot of naked girls in photographs throughout the house. The interview was concluded and the tape was turned into evidence. Investigation Continues... REAR KAKEAEAEEHERKKEEKEKAEH NARRATIVE HLT RRR R RHR ER EHH REA REE Reported By; RECAREY, JOSEPH 11/10/05 Entered By.: ALTOMARO, NICKIE A. 11/10/05 Det. Dawson and I attempted contact with QR Qi i» ques, “Qa «=6t left my business card at her front door. Ms qi returned my call and arranged a meeting with me at the Palm Beach Police Department for November 8, 2005. At approximately 2:00pm, arrived at the Palm Beach Police Department. She was brought into the interview room and the door was closed for privacy. She was told that I appreciated her coming to the police station for questioning regarding an on going investigation. She was told that I was investigating a crime involving Jeffrey Epstein and knew, based on the investigation, that she had encounters with him in the past. During a sworn taped statement, QM® stated she had met Epstein approximately two years ago. She was first introduced to Epstein by Haley Robson. Robson approached her about working for Epstein and providing a massage to him for $200.00. The arrangements were made and as Robson could not take her the day the arrangements were made, took (MN G@NNMMIaalso attended QQ and was familiar with Epstein. QQ ecalled she was brought there and entered through the back kitchen door. She had met with an assistant Sarah and another assistant Adrianna. Sarah brought her upstairs as she observed several photographs of naked females throughout the house. iz stated Epstein came in the room, wearing only a towel, and laid on the table. stated he picked out the oils he wanted her to use and requested she remove her clothing to provide the massage. @i77i7iz: stated that on the first massage she provided she did not remove her GIUFFRE000049Jate: Time: Jase kkkk A GeeGe lt tsa CARR LAW s DeumeetI4G+3 AiKenCBHOSIa4 FRagedcaiap 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 4g 15:02:37 Incident Report Program: CMS301L No. . . - 7 1-05-000368 (Continued) clothing. QB stated she had returned several times after that. Bach time she returned more things happened. Q@MMNMM stated that the same thing would happen. Epstein would walk into the master bedroom/bathroom area wearing only a towel. He would masturbate as she provided a massage. QM stated she was unsure if he climaxed as he masturbated under the towel. Additionally she never looked blow his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion, Epstein would use a massager/vibrator, which she described as white in color with a large head, on her. Every time she provided a massage he would masturbate. Q§M—Madded she has no formal training in providing a massage. QGgg—stated she brought two females during her visits to provide massages, Stated she brought a girl named {ill and from stated she received $200.00 for each girl she brought. Additionally, Gi@ilz was given $200.00 for taking her in the very beginning. The interview was concluded and the tape was placed into evidence. Investigation continues... KEEKKKKEKKEKEHEKKHAKEEKRH NARRATIVE # LQ FEE KEKEEKHKRKKKKR KK KRHKEKKHE Reported By: RECAREY, JOSEPH 11/13/05 Entered By.: ALTOMARO, NICKIE A, 11/14/05 On November 8, 2005, I made telephone contact with quay w/r, at her residence, @MBMMMMBresponded to the police station for an interview reference an ongoing investigation. At approximately 2:30 pm, she arrived at the Palm Beach Police Station and was brought into the interview room for the interview, The door was closed for privacy and she was told that I appreciated her cooperation in this case. During a sworn taped statement, @@@@™MBstated she had met Jeffrey Epstein approximately one year ago, She was approached by a subject known to her a had asked her if she wanted to make money providing massages to Epstein, ad heard that several girls from were doing this and making money. She agreed and was taken to the house by had introduced her to Sarah and Epstein and brought her upstairs to a master bedroom and Master bathroom where a massage table was prepared and the proper oils were taken out. eft the room and waited downstairs for stated Epstein entered the room wearing a towel and she provided a massage wearing only her thong panties. @QBMEP advised Epstein had masturbated every time she provided a massage. She stated Epstein continued to masturbate until he climaxed; once that occurred the massage was over. She felt the whole situation was weird but she advised she was paid $200.00 for providing the massage. She also statec@@lll—received $200.00 for bring Gq to Epstein. QBN stated she had gone a total of 15 times to his residence to provide a massage and things had escalated From just providing a GIUFFRE000050Geese ts cw OAR LAW s DerumRetI4G+3 AiKenCRHOsIa4 FRage7/ cata Jase No. Date: 7/19/06 PALM BEACH POLICE DEPARTMENT Page; 50 Time: 15:01:37 Incident Report Program: CMS301L 1-05-000368 (Continued) massage. Epstein began touching her on her buttocks and grabbed her closer to him as he masturbated, Epstein also grabbed her breasts and fondled her breast with his hands as she provided the massage. stated on one occasion, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. stated Epstein penetrated her vagina with his penis and began having intercourse with her until he reached the point of climax. Epstein removed his penis from her vagina and climaxed onto the massage table, GUD received $350.00 for her massage. I asked her if she had any formal training in providing massages, BEEN stated she did not, continued to state on one other occasion, Epstein introduced his assistant, Nada, into the massage. Nada was brought into room with to provide a massage, Epstein had them kiss and fondle each other around the breasts and buttocks as they provided a massage to Epstein. Epstein, watched and masturbated as this occurred. On other occasions, Epstein introduced the large white vibrator/massager during the massage. Epstein stroked the vibrator/massager on vagina as she provided the massage. QQ stated the last time she spoke with anyone at the house, was with Sarah during the weekend of October 2 or 3, 2005. @@M® stated she had brought two people to the Epstein house. She provided the names of ana and QM (unknown last name). It should noted Gimmie had been previously identified as Qyqymmp GMM and had been previously interviewed. The interview was concluded and the videotape was placed into evidence via the locker system. On November 9, 2005, Sgt Frick and I traveled to 6751 Fairway Lakes Drive in Boynton Beach, Florida in hopes to interview Juan Alessi, the former houseman of Epstein's home. As no one was home, a business card was left for him to return my call. We then traveled to 11349 SW 86th Lane in Miami in hopes to interview Alfredo Rodriguez, a former house man of Epstein. We did not locate them at home. I left a business card for him to return my call. We. then traveled to@qgly WHRMMMBeand met with Dean of Students, Mr. We requested to speak with gay @QQM—M—Mwes re interviewed, as she still was in possession of the rental car that Epstein had acquired for her. GUD stated that Sarah, Epstein's assistant, had called her on her cellular telephone and informed her that rental was extended for her. Sarah stated she had paid an additional $625.00 for her to keep the rental an extra month. Gay was asked if she had any additional contact with either Epstein or anyone from his organization. @MBMNM® stated she did not, other than the telephone call informing her that she could keep the car for an extra month. Q§MMMMMBdid not provide any additional information. On November 10, 2005, at approximately 9:47 am, Alfredo Rodriguez had telephoned reference my business card found on his door. Rodriguez stated he had worked with Epstein for approximately six months after GIUFFREO00051Geese sq A AR33 LAW s DeumeetI4G+3 AiKeRCBHOSIa4 FRageBoatap jee emer ee me nmr tem ere tee mene ee ae ea a a ae ae ee a ew ee a a ee ew we we we ee ae eee eee ee ee eee late: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 51 ‘ime: 15:01:37 Incident Report Program: CMS301L ‘ase No. 1-05-000368 (Continued) the previous houseman left. Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a massage in the morning and one in the afternoon. Mr. Rodriguez stated he would rather speak about this in private. He advised he would come to the police station to speak with me. Rodriguez stated he would return my call on Monday, November 14, 2005. I then made telephone contact with Juan Alessi. He advised he found my card on his door and wanted to know what I needed to speak with him about. I explained to Alessi that I was conducting an investigation on his former employer, Mr. Epstein. Alessi stated he would return my call shortly as he was in the middle of a project at his home. I received a telephone call from Attorney Donald Morrell from 686-2700. Mr. Morrell stated he represented Mr. Alessi and did not want me speaking with his client. I then made telephone contact with the State Attorney s Office and confirmed that subpoenas would be issued to the former employees to assist in the investigation. I then made telephone contact with Attorney Guy Fronstin, attorney for Mr. Epstein, I explained to Mr. Fronstin that I would like to speak with Mr. Epstein. He stated Mr. Epstein is not in residence in Florida at this time and would check with him to ascertain if he could be here by Wednesday November 16, 2005 for an interview. Mr. Fronstin stated he would return my call should Mr. Epstein decide to come in to the police station for an interview. Investigation continues. KEKKEKKEENKAKE KKK KKK KKEHKEEKE NARRATIVE # LQ BEER ER KEKEKEA KEKE Reported By: RECAREY, JOSEPH 11/15/05 Entered By.: ALTOMARO, NICKIE A, 11/16/05 On November 14, 2005, Det. Sandman and I traveled toi > 3 Se GE and spoke with ee |: was told of the ongoing investigation involving Epstein. advised she had gone to the house on several occasions. During a sworn taped statement, she advised she started going to the house approximately one year ago and was brought — (Unknown last name). stated brought her into the house and she was introduced to a girl named Sarah. Once she met her, Sarah brought her upstairs into a master bedroom bathroom, stated she met Jeffrey in the bathroom. He lay on the table and picked the massage oils. She provided the massage, as he lay naked on the massage bed. She stated she rubbed his calves and back area. Upon the end of the massage, Epstein removed himself from the massage table and paid her $300.00 for the massage. tated she had only been at the house approximately five or Six times. @§RREEEMMM said each time she went to the house she was notified by Sarah, Epstein's assistant, that Epstein was in town and would like her to work. stated she returned to the house and was again led upstairs by Sarah. She provided the massage, clothed. GIUFFRE000052Geese sq Oi AR33 LAW s DeRuMmAeI4GE3 AiKeACBHOSIa4 FRagePcAiaS Yate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 52 Time: 15:01:37 Incident Report Program: CMS30iL lase No. . . . : 1-05-000368 (Continued) aa advised it wasn't really weird until later on Gq was asked if she ever removed her clothing to provide a massage. stated it was not until the third time she went that she removed her clothing. @Q@MMMbstated she was notified by Sarah that Epstein wanted her to come to work. She arrived at the house and was led upstairs by Sarah. She started providing the massage when Epstein asked her to remove her clothing. G@iiimpremoved her pants, shirt and bra. She stayed in her thong panties and continued rubbing Epstein. Epstein turned over onto his back and she rubbed his chest area, QQ stated she knew he was masturbating himself as she providing the massage. QE stated she believed he climaxed based on his breathing, She did not want to view either the climax or the fact that he was masturbating. qa stated once the breathing relaxed he got up and told her to get dressed. She was paid $300.00 For her services. Guu stated on the last time she went to provide assage, she ee, stated was notified by Sarah to come to the house and work. she was now dating her current boyfriend and did not feel comfortable going. She recalled it was approximately January 2005. She said she went, already thinking that this would be the last time. She went upstairs and went into the master bathroom. She met with Epstein, who was wearing only a towel as he entered the room to lie on the table, @Qigymm stated Epstein caught her looking at the clock on several occasions. Epstein asked her if she was in a hurry. stated her boyfriend was in the car waiting for her. Qa forther stated that Epstein got upset, as she wasn't enjoying the massage. She told him that she didn't want to continue and she would not be back. Epstein told her to leave as she was ruining his massage. asked her if she had any contact with Epstein's organization, she stated she received $200.00 from Western Union in Royal Palm Beach and Okeechobee Blvd as a Christmas gift, GE advised she had no formal training in provide any massages. Q@#MMMMMMmalso stated she was sixteen years old when she first went to Epstein's house. I At approximately 4:22 pm, I made telephone contact with Ci Giz at GYR Ss She agreed to meet with me at a public place. TI suggested she come to the police station for an interview. WRB did not want to meet at the police station. I recommended we meet at the Palm Beach Gardens Mall in the food court area, She agreed and an appointment was made for November 15, 2005 at 5:00 pm at the food court. Investigations Continue. CHA KKKKKHKREKARKEHEEKEXEEEK NARRATIVE Ho 20 FHRHH ARERR KER ERR EA AE HEE Reported By: SANDMAN, JENNIFER R. 11/16/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 On 10/20/2005, I assisted executing a search warrant at 358 El Brillo Way in the Town of Palm Beach, Palm Beach County Florida under the direction of affiant Detective Joe Recarey. GIUFFRE000053Geese lt sq OARS LAW/s Dement I4GE3 AiKenRHOSIa4 FRagettoptat> — eee men ee a ae ee nee een eee a a ae a a a a a a a a a a a a ee ae ee ee eee ee ee ee Date: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 53 Time: 15:01:37 Incident Report Program: CMS301L tase No. . . . : 1-05-000368 {Continued) Detective Melnichok and I searched the pantry room that is west next to the kitchen. This room had all white cabinets with a dark grey and black counter top. We did not find anything in this room. We searched the yellow and blue room that is west next to the pantry room. This room had a very large statue of man with a bow. Taken into evidence from this room were nine photographs in frames of various women. We searched the main entrance foyer that is to the north of the yellow and blue room. This room contained two bamboo chairs and ottomans with cushions. It also contained a round table with numerous books. We searched another blue room that is west of the foyer. This room had a stereo system and book shelves that were from the floor to the ceiling, Taken into evidence from this room were eight photographs in frames of various women and/or Epstein, the owner of the residence. We searched the room to the west of the blue room that has sliding glass doors that lead out to the pool. In this room in a dresser were two DVD's and two VCR tapes. These items were taken into evidence. We searched a 2004 black Chevy Suburban bearing Florida tag X99-EGL, registered to Jeffrey Epstein DOB 01/20/53, which was located on the east side of the driveway facing south. I found a Thrifty rental agreement between the passenger seat and the middle console. The name on the rental agreement was Johanna Sjoberg from 622 Holly Drive Palm Beach Gardens, Florida 33410. The phone number on the rental agreement was (561) 714-0546. The vehicle rented was a white 2005 Chrysler Sebring bearing Florida tag W99-FUN. The vehicle was rented on 9/25/05 at 17:58 hours and was returned on 9/26/05 at 16:52 hours. The last four numbers of the credit card used are 9821. Detective Melnichok found a piece of paper in the middle console that Said I used the cash in here to fill up the tank and was signed by Johanna. I searched the 2005 black Cadillac Bscalade ESV bearing Florida tag Q29-9GT, registered to Jeffrey Epstein dob 01/20/53, which was located on the west side of the driveway facing south. I did not find anything in this vehicle. All of the items that were taken into evidence were photographed in the place they were located and then turned over to crime scene. RR RRR KE REAR EREAAEKEAERA NARRATIVE FED ARR HER KERR EE HERE RE Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 GIUFFREO00054Geese lt tsa ARBs LAW s DeumRentIzG+3 ArikenRHOsIa4 FRagerhl optatp ame ee a a a i a ea a a a a a a a ae ae ee eB ee ae we em ee Be eee ee ee ee ee ee eee ee a ee eee ee ee eee ee ate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 54 ime: 15:01:37 Incident Report Program: CMS301L ase No. . . . : 1-05-000368 (Continued) On November 15, 2005, Det, Sandman and I traveled to (i> Gam > i: Geeeeee. Ve cet vith eam, 2 seventeen-year old juvenile who was not in school this day due to a cold from which she was suffering. QQMP was told that I needed to speak with her in reference to an ongoing investigation involving a subject she would know as Jeffrey Epstein. Prior to speaking with her, I explained that because of the fact that she is a minor, I needed to speak with her parents prior to speaking with her. She telephoned her father, Mr. on his cell phone and explained to him that Det. Sandman and I were there to speak with her. I spoke with Mr. on the telephone and informed him I needed to speak with his daughter in reference to an ongoing investigation. Mr. @QMMEMMM «advised he had no problem with us speaking with his daughter. During a sworn taped statement, QM stated she met Jeffrey Epstein over a year ago, She was sixteen years of age and was approached by who informed her that she could make monies providing a massage to Epstein for $200.00. @ggigphad informed her that she would have to provide this massage topless. (Hil made the arrangements with Epstein and his assistants and took GH to the house. QE stated @MM—M—B and she entered through a glass door that led into a kitchen. @§MMMMM®took her upstairs, to a master bedroom and master bathroom. She recalled the bathroom had a large pink couch, sauna and matching shower. Epstein entered into the room wearing only a towel. Qipeeee 3.cemmme removes their clothing remaining only in thong underwear. She further stated that Epstein lay on his chest on the table. Epstein selected which oils to use for the massage. Both Psd provided the massage on his legs, back and feet. Forty minutes into the massage, Epstein turned over onto his back and requested gg wait downstairs in the kitchen area for Epstein instructed QM to finish the massage. As QB got dressed, QM starting rubbing his chest. Qaim left the room, and Epstein began masturbating himself asqaymp rubbed Epstein s chest, stated he continued masturbating until he climaxed on the towel he was wearing. When asked if he had removed the towel she stated he turned the towel around so that the opening would allow him to expose himself. After he cleaned himself off with the towel, he instructed QM® the massage was done and to get dressed and met with him downstairs. Q@MMBMMMMBoot dressed and met with Epstein in the kitchen area. She was paid $200.00 dollars for providing the massage. @§MMMMMMestated she was aware that QW also received monies for the same thing, The second time she went to the house she was again approached by asked if she wanted to return to the house to provide another massage; @MEEENP agreed and the arrangements were made by or her to return to the house. gayi) stateccgmmmmig drove her to the house and knocked on the same glass door that leads to the kitchen area. They were allowed entry into the house by one of the staff members. @MMMM@ted her upstairs to the master bedroom and GIUFFRE000055Geese lt sq ARBs LAW /s Dement I4G+3 AiKenRHOsIa4 FRage ite catatp ate 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 55 ime: 15:01:37 Incident Report Program: CMS301L ase No. . . . : 1-05-000368 (Continued) master bathroom area. @@@—MMleft GGMNENMMMB this time to do the massage alone. Epstein entered the room again wearing only a towel. Qqggm began removing her clothing as she did the last time she was at the house. Epstein instructed her to get naked, He lay on the table on his stomach as@@MMMMMM® began massaging his legs and back. As @9QN finished with Epstein's back and legs, Epstein then turned over onto his back. QQ started to rub his chest and he began masturbating himself. As Q@@MNBMM® rubbed his chest, Epstein leaned over and produced a massager/vibrator, He turned it on and began rubbing —— ee and masturbating himself at the same time. stated she continued to rub his chest as this was occurring. She described the vibrator/massager as large, grey with a large head. Epstein rubbed her vagina for approximately two to three minutes with the massager/vibrator. He then removed the vibrator from her vaginal area and concentrated on masturbating himself, q@a@—M® stated he climaxed onto the towel again and informed her that the massage was done. @@MMMMMMMe sot dressed and met with @@MM®who was waiting in the kitchen area. She received $200.00 for the massage. Gm said she never returned to the house and had no desire to return to the house. was asked if she received any formal massage training. She advised she had no formal training. QQ was asked if Epstein knew her real age. stated he knew as he asked her questions about herself and high school. He was aware she attended and is still attending gemma qm GU. . The interview was concluded. I sugqgesteqg@mmMM inform her parents of what occurred at the Epstein house. WM stated she would tell her father as he was unaware this had occurred. I left my business card for any questions they may have. We left the area and returned to the police station. The tape was placed into evidence. Investigation Continues. KEKE KAKAREKEKREK NAR RAT IVE # QQ RRERRERKEAAREAAKEREEKKKEEH Reported By: RECAREY, JOSEPH 11/17/05 Entered By.: ALTOMARO, NICKIE A. 11/17/05 On November 15, 2005, Officer Munyan and I responded to the Palm Beach Gardens Mall food court section to meet with (i> Gm. At approximately 5:10 p.m.,@@@@@ll/Barrived and met with us at the food court, rovided a sworn taped statement in which she stated she had been at the Epstein house over fifty times. She began going to Epstein's house when she turned eighteen years old, Q(B was asked if she knew of the on-going investigation, M@—BMMM——MBstated she Was, aware there was an investigation as she had been told by other girls that were interviewed. Additionally, she has had several telephone conversations with Epstein's assistants as to what had been going on during the investigation. I asked @MMMMMMBhow she was introduced to Epstein. Q@MMMMM—MBstated she did not want to disclose who brought her to the house but she would GIUFFRE000056lase Geese lt sq ARBs LAW /s DemumeentI4G+3 AiKenRHOSIa4 FRage 18 o9tatp 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 56 15:01:37 Incident Report Program: CMS301L No, . - . : 1-05-000368 (Continued) respond to any other questions. When I asked her what happened at the house, @MMMMMMMB stated everything happened. It all began with the massages. Each time she went more things happened. She would massage Epstein and he would masturbate and climax. She stated things escalated from there. She provided oral sex on Epstein and he provided oral sex on her. She stated he would also use a massager/vibrator on her vagina to stimulate her as she massaged him. He introduced his assistant Nadia or Nada to have vaginal intercourse with QM =6She stated Nada or Nadia would utilize a strap-on (synthetic penis) to have intercourse with her. She was told to masturbate herself as Epstein and Nada had sexual intercourse. All this was done at Epstein's direction- gm could not provide exact dates as she had been to the house so many times. stated Epstein inserted his fingers in her vagina to stimulate her as she massaged him. When I asked her if there had been any vaginal intercourse with Epstein, she stated she did not have sex with him. She did admit having sex with Nada, his assistant. WHEE stated not every time she went involved sexual favors. om ** ‘ etimes she would just talk with him and get paid. I asked her how much she was paid each time she went to Epstein s residence. Gz stated she got paid $300.00 every time she went to the house, She was told to bring other girls to him to provide massages. Mm declined stating that she does what she does and did not want to introduce anyone else to do what she does. QM stated she had never received any formal training in providing massages. I showed Qi a photo line up in which Nada Marcinkova was placed in position six. She reviewed the six photographs and immediately identified Nada Marcinkova as the person with whom she had intercourse. Additionally, it was the same person she watched have intercourse with Epstein. She signed the photo line-up under Nada Marcinkova s photo as the person she identified. We then left the mall and returned to the police station. The photo line up and tape were placed in to evidence. Investigation Continues... HERE EKKEAKEAKHAEEKEEEX NARRATIVE Ho D3 HHEKH RRR HKHIEKAE KAKA RK RK EH Reported By: RECAREY, JOSEPH 11/29/05 Entered By-: ALTOMARO, NICKIE A. 12/01/05 On November 17, 2005, I received a phone message from Atty. Guy Fronstin who advised to call his cellular phone reference his client Jeffrey Epstein. I telephoned his cell phone and left a message for him to return my call. I did not receive a call back on Thursday, November 17, 2005. On Friday, November 18 2005, I retrieved another voice mail from my work phone from Mr. Fronstin advising he would not produce his client Jeffrey Epstein for any statement. Fronstin stated he had spoken with ASA Lana Belohlavek and expressed Mr. Epstein has a passion for massages. I called ASA Lana Belohlavek and confirmed that GIUFFRE000087Geese lt sq ARRs LAW /s DemumeentI4G+3 ArKenRHOsIa4 FRage A dptatp Yate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 57 fime: 15:01:37 Incident Report Program: CMS301L ‘tase No. - . . : 1-05-000368 {Continued) Fronstin had telephoned her reference this case, Although nothing was discussed, Mr. Fronstin did advise her that Epstein is very passionate about massages. I also spoke with ASA Daliah Weiss reference the previous employees, Juan and Maria Alessi. She advised that they had been served through a@ subpoena process server. They were both scheduled to appear on Monday November 21, 2005 at 12:00 p.m, On November 21, 2005, I met with ASA Weiss, Atty. Donnie Murrell and Juan and Maria Alessi at the State Attorney Office. ASA Weiss had requested a court reporter to be present to take the statement of the Alessi s. I spoke with Maria Alessi, in the presence of her attorney, Donnie Murrell. She advised she had worked for Epstein for eight years, from the period of 1994 through 2002. She advised she had never had any direct conversations with him. She stated it was her husband who spoke directly with Epstein. Her work consisted of doing house cleaning, shopping and other preparations when Epstein would arrive in town. Alessi stated the preparations consisted of preparing the house and bathrooms for his arrival. She advised she did view several masseuses that arrived at the house. She advised that two or three girls would come during a day and provide the massages. The girls that arrived looked young in age. Mrs. Alessi did not know any of the girls personally and were always different. She was told that when Epstein was in residence he did not want to encounter the Alessis during his stay in Palm Beach. I then spoke with Mr. Alessi in the presence of his attorney, Donnie Murrell. Mr. Alessi stated that he was employed for eleven years with Mx, Epstein. He originally was hired as a part time employee and then moved up into a full time position. His duties included everything. Alessi stated he was the house manager, driver and house maintenance person. It was his responsibility to prepare the house for Epstein s arrival. When asked about cooks or assistants, Alessi stated they traveled with Epstein on his private plane. He remembered dealing with his girlfriend, Ms. Maxwell originally and then dealt with Epstein directly. I asked Mr. Alessi about massages that occurred within the home. Mr. Alessi stated Mr. Epstein had up to three massages a day. Each masseuse that visited the house was different. Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at the most. The massages would occur in Epstein's bedroom or bathroom. There were times he recalled that he would set up the massage tables either in Epstein s bedroom or in his bathroom. I asked if there were things going on other than a massage. Alessi stated that there were times towards the end of his employment that he would have to wash off a massager/vibrator and a long rubber penis, which were in the sink after the massage. Additionally, he stated the bed would almost always have to be made after the massage. Alessi was never privy to what went on during the GIUPFREOQ00058Geese lt sq Oi AR33 LAW s Dement I4G+3 AiKenRHOSIa4 FRage ropa Jate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 58 Pime: 15:01:37 Incident Report Program: CMS301L ‘ase No. 1-05-000368 (Continued) massages. He was asked if he remembered any names of the girls that massaged Epstein. He tried to remember and was unable to provide any exact names of any girls. Alessi was asked about any contact with anyone from the Epstein organization. Alessi said he did speak with Mr. Epstein shortly after my initial contact with him to find out what was going on. Alessi also stated that approximately on November 11, 2005, he was contacted by a private investigator from the Law Office of Roy Black. The investigator had called him to meet with him to ascertain what he was going to tell the police. Alessi stated they met at the Carrabba s Restaurant in Boynton Beach and discussed the same questions I was asking him. I informed Mr. Alessi and Mr. Morrell that as this is an ongoing investigation and anything we discuss should be confidential. They both acknowledged the fact that the information would be kept confidential. It should be noted that a court reporter was present during the interviews and would be providing a copy of the statements to me when they become available. On November 21, 2005, I received a voice mail from Mr. Fronstin who advised he would not be making Mr. Epstein available for any Statements. He did have some words that he wanted to relay on behalf of Mr. Epstein. I telephoned his office and left a message for him to return my call. On November 29, 2005, I received a call back from Mr. Fronstin who left a voice mail after hours on November 28, 2005, advising he would return my call during normal business hours to speak with me reference the case on November 29, 2005. KEKE EKEKKEKERKKEKKKAEKES NDRRAT IVA HD RRR RIOR RRR TO RK Reported By: RECAREY, JOSEPH 11/29/05 Entered By.: ALTOMARO, NICKIE A. 12/01/05 On November 29, 2005, at approximately 2:30 p.m. I received a telephone call on the department issued cell phone. Mr. Fronstin stated he was calling to relay information that Mr. Epstein wished he could relay. Mr. Fronstin stated that he would not allow Mr. Epstein to speak with me at this time. He further stated that Mr. Epstein is very passionate about massages. He continued that Mr. Epstein had allegedly donated over $100,000 to the Ballet of Florida for massages. The massages are therapeutic and spiritually sound for him that is why he has had many massages. Mr. Fronstin stated he appreciated the way the investigation has not been leaked out into the media. I explained to Mr. Fronstin that it is as important to protect the innocent if the allegations are not substantiated. Mr. Fronstin was told of the allegations that the private investigators assigned to the case have been portraying themselves as police officers. Additionally, I explained that my cell phone had been called by the private investigators. Mr. Fronstin advised he was not aware of that and advised they were under the direction of Attorney Roy Black in GIUFFREO00059Geese lt sq ARBs LAW s DemumeentI4G+3 AiKenCRHOsIa4 FRage tbh optatp tt ele Te Date: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 59 Time: 15:01:37 Incident Report Program: CMS301L Case No. .. . 3 1-05-000368 (Continued) Miami. Mr. Fronstin further stated Epstein had originally called Mr. Dershorwitz in Boston, who recommended Roy Black in Miami, who asked Mr. Fronstin to assist. I informed him that if and when any charges would be presented I would notify him. The call was then terminated. Investigation continues CHER EKEEKAKKAKEEKREREAHKKEXERKE NARRATIVE HDS RHR AK KK KEK KAA EE RARE KR JA Reported By; RECAREY, JOSEPH 12/15/05 Entered By.: ALTOMARO, NICKIE A. 12/16/05 A review of the telephone message books, which were obtained during the search warrant, was conducted in which various messages from different dates were made to Jeffrey Epstein. The telephone message books have a duplicate copy (Carbon Copy) which, once a phone message is written into the book, the top copy is then torn on the perforated edge and the carbon copy is left in the book. First names of girls, dates and telephone numbers were on the copy of the messages. I recognized various numbers and names of girls that had already been interviewed. The body of the messages was time of the day that they called for confirmation of "work." Other names and telephone numbers were located in which the body of the messages were, "I have girls for him" or "I have 2 girls for him." These messages were taken by Sarah for Jeffrey Epstein. Based on the context of the body of the messages, I requested subpoenas for subscriber information on the telephone numbers and the time frame involved. Copies of the messages were made for evidentiary purposes. I obtained Qt aummiammn qgygypammme yearbooks for 2005, 2004 and 2003. I first reviewed the 2005 yearbook and located most of the girls I had spoken with. Additionally, I located => Gam Based on the corrected name spelling, I was able to locate her to her residence in On December 8, 2005, Det. Caristo and I js 1 lockted i Sra, responded to i her home. She advised she is attending qqygy> a> QED and is participating in the early release program so she can maintain her part time job. As she is still a minor, I left my business card to have her mother return my call to request an interview with her daughter. We then left the area. I also had previously researched the telephone number for Sg and telephone number MM A subpoena had been issued for the information on lien number was registered to of A query of QR revealed that she is the daughter of and is currently residing at Det. Caristo and I attempted contact withQ@@Mwith negative results. I left my business card on her front door requesting she return my call. We then responded to I also attempted contact with I left my business card for him to Mr @@@M with necative results. return my call GIUFFRE000060Geese lt sq ARBs LAW /s Dement I4G+3 AiKenRHOSIa4 FRageil/ ata Yate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 60 Time: 15:01:37 Incident Report Program: CMS301L tase No, ; 1-05-000368 (Continued) On December 3, 2005, I received a telephone call from@Qyyy Gaiam ED GEE: )S mother, who was made aware of the on going investigation in Palm Beach. @Q@MM—advised she was told of everything that occurred at Epstein's house involving Epstein and his staff. She advised she would allow me to question her daughter about what occurred and would cooperate with the investigation, Sm provided me with@g@® cellular telephone number to schedule an appointment for an official interview. I telephoned her cellular telephone and made a tentative appointment for Monday, December 12, 2005. IT then received a telephone call fron am father of Quy who stated he found the business card on his door. If explained that I was conducting an investigation and needed to speak with QB as she may have information that could assist in the investigation. Mr .“@MMMMMsstated that his daughter no longer resides with him and has her own trailer in another trailer park. He advised he would tell her to call me. On December 12, 2005, due to a conflict with schedules, arrangements were made to meet with Qi QM on Tuesday, December 13, 2005 at 5:00 pm. On December 2005, Det, Dawson and I traveled to bay “Unie 9 during « sworn taped Ge 2nd met with statement, stated that when she was sixteen years old, she was taken to Epstein's house to provide a massage for money. Gy GEREN approached stated it was before Christmas last year when her and asked if she needed to make money for Christmas; @@MB stated she did and agreed to provide a massage for money. QB made arrangements to take to the house and drove Simp to the house to "work." Qi stated she could not remember the street name but would be able to drive to the street. They drove to the last house on the street and pulled in the last house on left side. They walked up the driveway and entered through a side gate which led to a kitchen door. They knocked on the door and were encountered by an employee who @/iiiEdescribed as a "Spanish looking lady." They informed her that they were expected. They were then encountered by a white female with long blond hair. @MBBBMM—Bwas unable to remember the name of the white female with blond hair but knew she was Epstein's assistant. She was led upstairs by the white female who explained that there would be lotions out already and Epstein would choose the lotion he wanted her to use. She was led through a spiral staircase which led to a master bedroom and bathroom. The massage table was already set up in the bathroom. Sagmmm—mpdescribed the bathroom as a large spacious bathroom with a steam room and shower beside it with a sink to the right. @@MMM—MBwas introduced to Jeff who was on the phone when she entered. Jeff was wearing a white towel and lay on his stomach so that Qi may massage his feet and calves, Q¥MMMMg started the massage with the massage oil Jeff chose and rubbed his feet and Calves. Jeff got off the phone and requested she massage his back as well. QM began rubbing his back and got to the smali of his back. During the rubbing of his back Jeff asked her to get comfortable. He GIUFFRE000061Geese lt sq ARR LAW s Dement I4GE3 AiKenRHOsIA4 FRage 1B optat> Jate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 61 Cime: 215;01:37 Incident Report Program: CMS301L ’ase No. . . . : 1-05-000368 (Continued) requested she remove her pants and shirt. @§MpPremoved her shirt and pulled her pants off. Q@MMMMM—Bstayed in her bra and thong panties, As she finished the small of the back, Jeff then turned onto his back. He instructed she rub his chest and pinch his nipples. As she began to rub his chest, Jeff asked her questions about herself. Gimmes remembered telling him she attended @Qummemm. Jeff asked her if she was sexually active. Before could answer, he also asked what sexual positions does she enjoy. stated she was shy didn't like talking about those things. She continued rubbing his chest. Epstein reached up and unsnapped her bra from the front. Qjg™—®explained the bra she used had a front snapping device. Epstein rubbed her breasts and asked her if she like having her breasts rubbed. q@iilip said "no, I don't like that." Epstein then removed his towel and lay on the hed naked exposing his penis tCHM He began touching his penis and masturbated as he touched her breasts. Sallie explained Jeff then touched her vagina area by rubbing her vagina with his fingers on the outside of her thong panties, QiMetensed up and stated Jeff was aware that she was uncomfortable. tated that Jeff told her , "Relax, I'm not going inside." She further explained Jeff commented to her how beautiful and sexy she was. Jeff then moved her thong panties to one side and now was stroking her clitoris. said "Jeff commented how hard my clit was." He then inserted two fingers in her vagina and was stroking her within her vagina. She tried pulling back to pull out his fingers from within her vagina. Jeff removed his fingers from within her vagina and apologized for putting his fingers inside her. During this time he kept his hand on her vagina area rubbing her vagina. stated he rubbed her real hard as he was masturbating. dM said he climaxed onto the towel he had been previously wearing and got up from the table. Jeff told her there was $200.00 dollars for her on the dresser within the master bathroom. Jeff also told her that there was an additional $100.00 that was to be given tq@i—R for bringing her there to massage him. Jeff told her to leave her telephone number with his assistant as he wanted to see her again. Jeff stated his assistant would contact her to work again soon. I asked her if she ever received any formal massage training to which WM stated she did not. WHMMm stated it was the only time she ever went to work for Jeff and knew what happened to her was wrong- She stated she no longer speaks to@@MMMM&\because she was upset that took her there. She further stated that she had never been contacted for any additional work. The interview was terminated and we left the area. Investigation Continues... CKERAEKEHHAKAEKARHAKERAHRE NARRATIVE HDG KHER EK AKER HAERARH KARE Reported By: DICKS, ALLEN C. 12/18/05 Entered By.: ALTOMARO, NICKIE A 12/19/05 GIUFFRE000062Geese lt sq AR33 LAW /s Dement I4G+3 AiKenRHOSIa4 FRage1tecptatp Jate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 62 Time: 15:01:37 Incident Report Program: CMS301L tase No. . - . : 1-05-000368 (Continued) On 102005 at approx 0930hrs I assisted with the execution of a search warrant at 358 El Brillo Ave, Palm Beach. Initially I was assigned to enter the residence and conduct a sweep of the premises for safety purposes. I then accompanied CSEU tech Pavlik while she photographed the exterior of the house. Once this was complete I was assigned to search certain areas of the house with Det. Dawson as part of the search warrant. We began in the garage, searching three Mercedes Benz vehicles, a Harley Davidson motorcycle and adjacent closets in the garage. Nothing of evidentiary value was located, We then searched two closets off the kitchen area on the east side. These can best be described as pantry or storage closets. Nothing of evidentiary value was obtained. A small office with adjoining bath was then searched. In the bath area I located a phone message book with recent messages. This item was seized as evidence. Please note this bath and shower area are not used as designed but are storage areas containing a variety of items ta include a gun safe in the shower and assorted household items. We then searched a bath area and closet at the base of the main stairs in the foyer. Inside the closet two massage tables were located as well as partial nude female photographs. These items were later seized as evidence. Nothing of evidentiary value was noted in the bathroom. We then searched two bedrooms upstairs on the east side of the residence. Located in the bath room of the south bedroom was penis shaped soap. Located in the bedroom of the northern bedroom was penis and vagina shaped soap as well as an adult sex toy. These items were seized as evidence. We then searched the pool cabana located in the south west corner of the property. Several photographs of nude females were seized as evidence - I was then assigned to stand by with a person I believe was Douglas Schoettle. Mr. Schoettle was in the residence at the beginning of the search warrant. He was present during the warrant service and subsequent search. I stood by with him until the search was completed and I departed the residence. I had no conversation with him regarding the reason for our presence. Regarding seized evidence, all items were photographed in place and then collected by CSEU personnel. This concludes my involvement in this case. GIUFFREO00063Geese lt sq ARBs LAW /s Dement I4G+3 AiKenRHOSIA4 FRageaNoptatp wee we a eer srr a a a a a a a ee a a a a a a aw ee ae ae ee eee ee ee Yate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 63 Time: 15:01;37 Incident Report Program: CMS301L tase No. . - . : 1-05-000368 (Continued) KEKE KE KRHEKE KEKE ERK EKEESE N A R R ATIWV B # 27 KE KKH KK REE KEKE KEKE KES IA Reported By: KRAUEL, CURTIS D. 12/21/05 Entered By.: ALTOMARO, NICKIE A. 12/21/05 On Thursday, October 20, 2005 at approximately 0936 hours, I assisted in the execution of a search warrant located at 358 El Brililo Way, Palm Beach, Florida, residence of Jeffrey Epstein. I was instructed by Case Agent Det. Joseph Recarey, to secure all computer and media related material from the residence. Upon my arrival I was directed by Det. Recarey to a room designated as the Kitchen Staff Office. I observed a, Silver in color, CPU with the left side cover removed, exposing the CPU s hardware sitting on floor next to a glass type desk. The CPU had no discernable identifiers or features indicating a make or model. This CPU was powered off with the power cord not plugged in. The keyboard and mouse were atop the CPU. It should be noted that the CPU was not connected to a monitor, printer, or other media device. On the back Panel of the CPU, I observed an A/V card with RCA jacks attached. This type of hardware would allow audio and video to be downloaded onto the CPU s hard disk. The ends of the RCA jacks were unattached at the time of the search and no external camera was located within this room. The CPU was located on the right side of a desk that held a flat panel LCD screen. The desk also held another keyboard and mouse, indicative of a second computer; however, no other computer was found. [It appeared as though a second computer had been recently removed as the cables ends from the monitor, keyboard and mouse were in the same area. A further search of the room revealed no media storage devices, i.e. CD s, Floppy Disks, Zip Disks, etc. This type of media is commonly stored in an area where computers are placed, yet no media was found. After completing a search of this room, I secured the CPU and turned all items over to the Evidence Custodian for future forensic analysis via a property receipt. I was then directed by Det. Recarey to a room designated as the Garden Room, where I observed a wooden desk facing west. The desk held a flat screen LCD monitor, keyboard, mouse, media card reader and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. Det. Recarey directed me to a third location designated as the Cabana room, which is detached from the residence and located just south of the pool. In the South East corner of the room, I observed an office type setting, with an L-shaped desk holding a flat screen LCD monitor, keyboard, mouse and printer; however, no CPU was located. All of the cables were removed from an area where a computer had once been. A search of the desk area revealed no signs of any media devices. GIUFFRE000064Jate: ime : ‘ase a ed \ Geese lt sq ABRs LAW s Dement I4GE3 AKenRHOsIa4 FRagedloptatp we ew Re em em em ew ee a a a ea ee wee ewe ee ew ee ee ee ew ewe em ee ee ee ee en a a a a ee ew eee eee eee ee 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 64 15:01:37 Incident Report Program: CMS301L Ne. - - . : 1-05-000368 (Continued) Det. Recarey directed me to a second detached structure located on the South East corner of the property. This area of this structure was assigned with single letters to identify a particular part of the room. In the office area, designated as Room B, I observed a powered on Dell Dimension 2350, attached to an LCD flat panel monitor. The screen displayed an open Microsoft Internet Explorer browser with URL address of http://home.bellsouth.net/. I observed no other active windows in the Start panel window and photographed screen. The power cord was removed from the back of the Dell CPU and I disconnected the cable modem to prevent remote access. At that time, the Dell CPU, marked with Serial Number 6WTVN21, was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room B, which were recorded onto a property receipt and turned over the Evidence Custodians. I then responded to a Bedroom designated as Room F, where I observed a white in color CPU marked Premio. The Premio CPU was in a computer desk which held a white CRT monitor, both of which were powered on. The CRT monitor displayed a message from Norton Antivirus software, warning of an expired subscription. I observed no other active windows in the Start panel window and photographed screen. I removed the power cable from the back of the Premio CPU and shutdown all other media. The Premio CPU, marked with Serial Number 2000091078, was secured and turned over the evidence custodian for future forensic analysis via property receipt. I also located several media related items within Room F, which were recorded onto a property receipt and turned over the Evidence Custodians. This concluded my participation in the search of the residence. ESKER KK AKEEEAOASE NARRATIVE Ho QQ KRAKKHAK ERK ER ERE REE KEANE Reported By: RECAREY, JOSEPH 12/21/05 Entered By-: ALTOMARO, NICKIE A. 12/21/05 On December 20, 2005, I contacted ASA Daliah Weiss in an attempt to subpoena the Epstein former houseman, Alfredo Rodriguez. Rodriguez, who resides in Miami, had eluded the process servers previously and was not served the investigative subpoena. A telephone message was left as she is not available during the week of 12/19/2005. I made contact with State Attorney Inv Theresa Wyatt and requested the same via telephone message. I then researched the victim's@jgj@cellular telephone subpoena data which had been received from a previous subpoena request. I analyzed the records which depict several calls from Haley Robson. The telephone calls start on February 6, 2005 at 12:49 pm.; the same day which the victim and the victim's father stated the incident occurred at Epstein s house. The first incoming call was from Robson's residence at 561 333-0180. The second incoming call from Robson's GIUFFRE000065ime: ase No. .. . : 1-05-000368 Geese lt sq Oi AR3s LAW /s Demme IZGE3 AiKenRHOSIa4 FRagedeatatp 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 65 15:01:37 Incident Report Program: CMS301L (Continued) cellular phone 561-308-0282 occurred at 1:02 pm. The call durations were one minute or less. The time frame was within thirteen minutes apart. It should be noted that Robson s residence was in close proximity to the victim's. The next call occurred at 5:50 pm when the victim telephoned Robson s residence. Several calls were made after the above mentioned calls both incoming and outgoing to Robson, Further analysis showed no telephone calls to either Robson's cellular telephone or Robson's residence were registered prior to February 6, 2005. Additionally, I also conducted an analysis on the telephone calls from 305-710-5165. The subscriber information confirmed that the number is registered to Paul A Lavery from Hialeah, Florida. The address was crossed referenced to the Office of Kiraly and Riley Private Investigators. I researched the web page www.rileykiraly.com which also showed various cases in which they assisted. I also located another web site under www.coralspringssparklandrotary.org in which Mr. Riley attended a Miami Rotary meeting and confirmed Atty. Roy Black is among his clientele. The telephone calls revealed Lavery had telephone contact with 9p and Qype GMM either just after I attempted to interview them, or just prior. A background was conducted on Lavery which revealed he holds a current Private Investigator License. A criminal arrest record revealed he had been previously arrested for possession of cocaine and solicitation of prostitution. I also researched the girls using www.myspace.com. This web site is a new social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. The site allows one to establish your own myspace.com page and decorate the page any way one wishes. I found the following people have myspace sites: Haley Robson, qq, Saas eS > GED GD 2°. KHKKKKKEKKKAKEARKKARKKHEKEEKAE NARRATIVE Ges registered to I received a Cingular Wireless packet which contained a CD which contained the results of the subpoena request for verbatim calls on An analysis will be conducted in the near future on the phone numbers called. Investigation Continues # ZQD HE KEKHREKRAKKEKEKEREKERE EKER Reported By: RECAREY, JOSEPH 12/27/05 Entered By.: ALTOMARO, NICKIE A, 12/29/05 Upon doing research on the message books recovered in the search warrant, I located the identity of The telephone number She currently is seventeen years old and is attending the I GIUFFRE000066Geese lt tsa Oi ARBs LAW /s Dement I4GE3 ArKeRRHOSIa4 FRageaBoptatp ate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 66 ime: 15:01:37 Incident Report Program: CMS301L ase No. . . . : 1-05-000368 (Continued) responded to (i i also known as the i! aeesiee. I located they i 1 )ocat cdqauem inside the foundation and informed her that I was investigating a case against Jeffrey Epstein and knew she had been at the house. Gee started to ery and advised she had put that part of her life behind her. I explained that although she is seventeen years old I needed to inform her parents that she would be interviewed. She provided her home telephone number. I attempted contact and left voice mail messages at the house to speak with her parents. Det. Caristo and I then located jump @Q@MMp at her residence located at a | ae. 9k attempted to interview her about Jeffrey Epstein. She advised she is so in love with Jeff Epstein and would do anything for him, She further explained that she would not speak with us about him either negative or positive. She asked us to leave her property. I informed her that although she did not wish to speak with us, I had sufficient information at this point in the investigation to know she was at Epstein's house and provided girls to Epstein to work. I also explained that prior to our arrival at her residence I had telephone contact with her father, Qa Qu, «who was told she would be interviewed. Ce currently seventeen years old and as a juvenile, parental notification would be required. We then left the area and returned to the police station. While at the police station, I left another telephone message for parents. I began an analysis of Sarah Kellen's Cellular telephone. The telephone number 317-855-3363 is assigned to Sarah Kellen and the financially responsible party is Jeffrey Epstein of 457 Madison Ave. in New York City, New York. The time frame which was subpoenaed was September 2005, through October 2005. There were eighty seven pages of calls made either to the cell phone or from the cell phone. The local (561) numbers were analyzed. A spread sheet was prepared and placed into the attachment file of who was called. The unknown numbers were researched using FoneFinder.com and subpoenas were requested to determine subscriber information, This was done to identify additional victims or witnesses. The analysis revealed that Kellen had called the victim/witnesses frequently when Epstein was in the Town of Palm Beach to "work." This confirms what the girls interviewed had previously stated. Kellen would notify them when Epstein was in town and their willingness to "work." The CD was placed into evidence. Investigation Continues. EKKEKEKHEEAKEHEEKEKEKKEEEKE NBR RA T IV E # AQ KRHA EKERAH ERE EEK Reported By: RECAREY, JOSEPH 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On December 29, 2005, I received a facsimile from National Compliance GIUFFREO00067Geese lt sq OARS LAW /s Dement I4GE3 AiKeRRHOSIa4 FRageddoptato — ee eer em Ree ee eee em ee ee ee me ee a a a ee eer ee ee te eee ee ee ee ee late: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 67 Time: 15:01:37 Incident Report Program: CMS301L ‘ase No. » . : 1-05-000368 (Continued) Center from Cingular Wireless for telephone number 561-308-0282. This was the telephone number for Haley Robson during the time frame when the victim, was brought to the Epstein house to "work." An analysis of the phone records, of all incoming and outgoing calls, showed that on February 6, 2005, the day the victim, 4g was brought to the house, Robson first called Sarah Kellen, Epstein's assistant, at 917-855-3363at 12:50 pm (EST). The next call was made to Epstein's house in Palm Beach, at 12:52 pm (EST), The following call was made to the victim,q@jfat 1:01 pm (EST) and at 1:02 pm (EST). This confirms the information provided by the victim and victim's father. I photo copied the records and enlarged the page 8 of 10 to show the calls made by Robson on February 6, 2005. To this date, I have not heard fron@gyp GRD parents. 1 will attempt to establish contact with them during the evening hours. I received a package from Atty. Guy Fronstin, which was hand delivered at the police station. Within the package, was a letter from Alan Dershowitz, and two www.myspace.com profiles. The profiles were that of and MySpace.com is a social networking service that allows members to create unique personal profiles online in order to find and communicate with old and new friends. This package was in response to a previous meeting in which Mr. Dershowitz called to assist in the investigation in providing any additional witnesses such as house employees who have been reluctant to speak with law enforcement. I reviewed the profiles Mr, Dershowitz enclosed. Q@@MMMMM who designed her blog to be edhiteepesnyeere, still attends (iii: Saree sends and receives messages from friends which contain some profanity. Upon reviewing her friends' comments section from Myspace, most of her good friends sent messages to establish contact and invite her to go out. T then reviewed Gi GHEE web blog which was provided by Mr. es Her blog Dershowitz. Ms, designed her blog to be states that her interests include music, theater and weed (Marijuana) . I reviewed her packet in which @—declares her love for her live-in coe She also describes using marijuana with her boyfriend iii The letter Mr. Dershowitz sent advised he was looking into the allegation that one of the private investigators used by the private attorneys of Epstein, attempted to impersonate or state that they were police officers from Palm Beach. Mr, Dershowitz advised that the investigators used to interview had "quite a distinct speech impediment", did not claim to be nor did they impersonate themselves as a police officer, This package was sent to both ASA Lana Belohlavic and ASA Daliah Weiss at the State Attorney's Office. IT made telephone contact with ASA Weiss to confirm she received the package and request an interview with Sarah Kellen, Nada Marcinkova, and Janusz Banasiak. She advised she would assist in attempting to GIUFFRE000068Geese lt sq Oi AR33 LAW /s Dement I4GE3 AiKeRCRHOSIa4 FRaged>optatp fate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page; 6B ‘"ime; 15:01:37 Incident Report Program: CMS301L ase No... . : 1-05-000368 (Continued) contact Mr. Dershowitz, On January 3,' 2006, I received a telephone call from ASA Weiss who informed me that she made telephone contact with Mr? Dershowitz. She had requested the employees be available the week of January 3, 2006, Mr. Dershowitz informed her that the assistants are out of the country and would require additional time to locate them and make them available. Investigation Continues. LKR KKKEKAAEEEKAKKKREKAKHEES NARRATIVE 31 RRR KHAKI K HARE RAKE KEE EE 4 Reported By: MINOT, LORI S. 1/03/06 Entered By.: ALTOMARO, NICKIE A. 1/03/06 On Thursday, 03/31/05, I started conducting surveillance at 358 Bl Brillo. At this point I observed at 1155 hours, a Tan Altima bearing FL tag A303AN in Roadway, Black SL bearing FL tag V55RFW in drive, Tan Honda Civic bearing FL tag X98APM in Roadway, Black Chevy Suburban in driveway and a Black Caddy Escalade in driveway. At 1325 Hours I observed Tan Honda Civic X98APM in roadway, Black Chevy Suburban in driveway, Black Caddy Escalade in drive and a White Kia car bearing FL tag D651BQ. At 1615 hours I observed a Tan Honda Civic, X9B8APM in roadway, Black Chevy Suburban in drive, Black Caddy Escalade in driveway and a White Kia car D651BQ in roadway. On Friday, 04/01/05, I continued surveillance at 358 El Brillo. At 1130 hours I observed a Tan Honda Civic bearing FL tag X98APM in roadway, Black Caddy Escalade in driveway and a Tan unknown make/model bearing FL tag A303AN in roadway. At 1227 hours, I observed a Tan Honda Civic X98APM in roadway, Black Caddy Escalade in driveway and a Black Chevy SUV located behind the Escalade, At 1345 hours, I observed a Tan Honda Civic X$8APM in roadway and a Black Chevy SUV in driveway. At 1558 hours, I observed a Tan Honda Civic X98APM in roadway, Black Chevy SUV in driveway, Black Caddy Escalade in driveway and a dark unknown model/make car parked in garage. On Saturday, 04/02/05, I continued surveillance at 358 El Brillo, At 0713 hours, I observed a Red Explorer bearing FL tag J98JEI in roadway and a Black Caddy Escalade in driveway. At 0814 hours, I observed a Red Explorer J98JEI in roadway, Black Caddy Escalade in driveway and a Tan Honda Civic X98APM. At 0952 hours, I observed a Red Explorer J98JEI in roadway, Black Caddy Escalade in driveway, Tan Honda Civic X98APM in roadway and also a Grey unknown make/model with a B.M in trunk retrieving landscaping tools. At 1155 hours, I observed a Grey Camaro bearing FL tag QR parking in the roadway in front of 358 El Brillo. A W/F, blond hair, teens to early 20's, thin and tall wearing a white tank top and short blue jean shorts, exited the vehicle and walked to the rear of the house. I also observed a Red Explorer J98JEI in roadway, Tan Honda Civic X98APM in roadway and a Black Caddy Escalade in driveway. At 1310 hours, I GIUFFREQ00069Date; Time: Tase tke \ Geese lt osc ARBs LAW /s Dement I4G+3 AiKenRHOSIa4 FRagedeboptatp were ee ee ee ewe em mer me eR mm mer eae ne ae a ee we ee ee ee ae ee eee ee ee eee 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 63 15:01:37 Incident Report Program: CMS301L No. - . . + 1-05-000368 (Continued) observed a Red Explorer W/F driver leaving the area, Tan subcompact on roadway and a Red Neon bearing FL tag coe Then observed 3 W/Fs, approximately 16 to 18 years of age jogging. All 3 females ran into the driveway. There were 2 with blond hair and one brown hair. On Sunday, 04/03/05, I continued surveillance at 358 El Brille. At 0719 hours I observed a Tan Honda Civic X98APM in roadway and a Black Caddy Escalade. At 0934 hours, I observed a Tan Honda Civic X9S8APM in roadway and a Black Caddy Escalade in driveway. At 1057 hours I observed only the Tan Honda Civic X9BAPM. On Tuesday, 04/05/05, I continued surveillance at 358 El Brillo. At 1052 hours, I observed a Red Explorer J98JEI in roadway, a Green Explorer, bearing FL tag F9IKAK in roadway, a Grey Altima bearing FL tag A303AN in roadway, White Ford Truck H58LRA in roadway, Black Mercedes in driveway being washed by a B/M and an unknown dark car parked in the garage. At 1059 hours a Blue Chevy Suburban drove to the house of 358 £1 Brillo and parked in the driveway. At 1119 hours, I observed the White Fort Truck H58LRA leave the area and the drive was the pool man. At 1126 hours, I observed a Grey unknown make/model car park in roadway. W/M got out of the car and walked to a house on the south side of El Brillo. At 1406 hours, I observed a Red Explorer parked on roadway and a large white box truck parked behind the surveillance suburban, HEEKKRHKKAKE ERK KEREEA NARRATIVE HQ RRR RA EAA RAKE KERR AR EED Reported By: BATES, MICHAEL J. 1/03/06 Entered By.; ALTOMARO, NICKIE A. 1/03/06 On 03/31/05, at approximately 1500 hours while conducting surveillance at 358 El Brillo, I observed a Black Cadillac Escalade, unknown tag, a Black Chevrolet Suburban, unknown tag, a Black Mercedes 8600 FL tag US0BOL parked in the east driveway next to the 3-car garage. There was a Tan Honda Civic FL tag X98APM parked on the street in front of the residence. At approximately 1700 hours, I observed the Black Suburban, Black Escalade, Black Mercedes and Tan Honda Civic parked in the same place. At 1750 hours, there was no change in vehicles. At 1840 hours, I observed the Black Escalade, Black Suburban and Black Mercedes along with a Silver Hyundai Accent FL tag Al36AN all parked in the east driveway and a Red Ford Explorer FL tag J98JEI parked on the street in front of the residence. At 2000 hours, I observed the Black Escalade, Black Suburban parked in the ease driveway and the Red Explorer and Tan Civic parked on the street. On Friday, 04/01/05 at approximately 1700 hours, I observed the Black GIUFFREO00070Geese lt sq Oi AR3s LAW /s Dement I4G-E3 AiKenRHOSIa4 FRaged7/ Ata a ee ee ee eee ee ee eee eee eee ate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 70 ime: 15:01:37 Incident Report Program: CMS301L ase No. . . . : 1-05-000368 (Continued) Escalade and Black Suburban parked in the east driveway and the Tan Honda Civic parked on the street in front of the residence. At 16820 hours, I observed the Suburban and Civic in the same place and a Gold Chevrolet Camaro FL tag parked on the street in front of the residence. At 2250 there was no change. At 2330, I observed the Black Escalade parked in the driveway and the Red Explorer parked on the street in front of the residence. On Saturday, 04/02/05 at approximately 1700 hours, I observed a Black Escalade, unknown tag, parked in the driveway and a Tan Honda Civic FL tag X98AMP parked in the street in front of the residence. At 1805 hours the Escalade and Civic were in the same position and the Black Mercedes FL tag USOBOQL was also parked in the east driveway. At 1920 hours the Escalade and Civic were the only vehicles and both were in the same position. At 2030 hours and 2145 hours there were no vehicles observed. At 2115 hours, I observed a Black Mercedes, 4-door parked in the east driveway FL tag G14CT. At 2300 hours, 2350 hours and 0045 hours, the Black Mercedes was the only vehicle observed. KER KKEARERAA RE RRR REEKERE NARRATIVE HZ R RRR R KKH RAR KERR HERE EREEE Reported By: RECAREY, JOSEPH 1/05/06 Entered By.: ALTOMARO, NICKIE A. 1/05/06 I made contact with Mr, Gq GUM 4father of QE Sa who was told that I wished to interview his daughter. Mr. stated he was aware and had spoken with his daughter about the incident. He stated that his daughter had previously told him that she was hired to model lingerie at a Palm Beach mansion. Mr. Qyyap stated he knew nothing else about what she did when she went to "work." Mr. COE eclvisee he would cooperate with the investigation and make his daughter available for interviews. I asked if she was available for an interview, stated she was not at home at the moment. I informed him I would make contact with her at a later time. Mr. GUN © Pressed his interest in the resolution in this matter as he stated this information has affected his daughter emotionally. On January 4, 2005, I acquired the subpoenas from the State Attorney's Office for Cingular Wireless, Metro PCS, Verizon, Bell South Telecommunications and Sprint for the unknown telephone numbers from Sarah Kellen's cellular telephone. The subpoenas were sent to the respective telephone carriers for subscriber information. I received a telephone call from State Attorney's Office, who informed me that the former houseman for Jeffrey Epstein, Alfredo Rodriguez, was present at the State Attorney's Office for an interview. Rodriguez was issued an investigative subpoena for an interview on the on-goings at Epstein's house during his employ. I responded to the State Attorney's Office and encountered Mr. Rodriguez waiting in the lobby. I brought Mr. Rodriguez to the interview room. GIUFFRE0000? |Date: Time: ~ase Geese lt sq Oi ARBs LAW s DemumrentIZG+3 AiKenRHOSIa4 FRageaeBoptatp 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 71 15:01:37 Incident Report Program: CMS301L No. . . . : 1-05-000368 (Continued) During a sworn taped statement, Mr, Rodriguez stated he was employed by Jeffrey Epstein for approximately six months. He was referred by associates and his employment lasted the months of November 2004 through May 2005. His responsibilities as house manager included being the butler, chauffer, chef, houseman, run errands for Mr, Epstein and provide for Epstein’s guests. Rodriguez advised he had very limited contact with Mr, Epstein. If Rodriguez needed to relay a message to Mr. Epstein, he would have to notify Epstein's secretary "Leslie" in New York City, who would then notify Epstein's personal assistant, Sarah, who would relay the message to Epstein. Rodriguez stated Epstein did not want to see or hear the staff when he was in residence. I asked Rodriguez if Epstein received many guests during his stay in Palm Beach. Rodriguez advised he had many guests. I asked specifically about masseuses coming to the house. Rodriguez stated he would have two massages a day. Epstein would have one massage in the morning and one massage in the afternoon everyday he was in residence. Rodriguez stated he would be informed to expect someone and make them comfortable until either Sarah or Epstein would meet with them, Rodriguez stated once the masseuses would arrive, he would allow them entry into the kitchen area and offer them something to drink or eat. They would then be encountered by either Sarah or Epstein. They would be taken upstairs to provide the massage. I asked Rodriguez if any of the masseuses appeared young in age. He advised he didn't ask their ages but felt they were very young. Rodriguez stated they ate like his own daughter who is in high school. Rodriguez stated they would eat tons of cereal and drink milk all the time. Rodriguez stated the girls that would come appeared to be too young to be Masseuses. He stated one time under stein's direction, he delivered a dozen roses Caan...