Professional Documents
Culture Documents
278
278
EXHIBIT A
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EXHIBIT B
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EXHIBIT C
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EXHIBIT D
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EXHIBIT E
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EXHIBIT F
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EXHIBIT G
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EXHIBIT H
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This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
Virginia L. Giuffre,
v.
Ghislaine Maxwell,
Defendant.
________________________________/
Pursuant to Federal Rules of Civil Procedure 26, 33, 34, Plaintiff hereby serves her
responses and objections to Defendant’s Second Set of Discovery Requests and serves her
GENERAL OBJECTIONS
Defendant’s Discovery Requests violate Rule 33, Fed. R. Civ. P., which provides “a party
may serve on any other party no more than 25 interrogatories, including all discrete subparts” –
in that Defendant has served a total of 59 interrogatories in this case, including subparts, in
Ms. Giuffre objects to Defendant’s Second Set of Discovery Requests to the extent they
seek information that is protected by any applicable privilege, including but not limited to,
attorney client privilege, work product privilege, joint defense privilege, public interest privilege,
1
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This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
on hundreds (if not thousands) of matters, and collectively have well over 100 years of combined
practice experience. Accordingly, a request that each of these attorneys list all communications
Additionally, Ms. Giuffre objects to this Interrogatory because a response would cause
Ms. Giuffre the incredible and undue burden of having to catalogue literally hundreds of
Moreover, Ms. Giuffre objects because this interrogatory calls for the production of
documents that are irrelevant to this action and not reasonably calculated to lead to the discovery
of admissible evidence. Communications with the media regarding cases that bear no relation to
the subject matter of this case, from decades in the past, are facially invalid and not calculated to
Ms. Giuffre additionally objects to the extent that this interrogatory seeks the
stringer, or any other employee of any media organization or independent consultant as such
interrogatory is overly broad and unduly burdensome. Furthermore, Ms. Giuffre is not obligated
Notwithstanding such objections, Ms. Giuffre has already produced her responsive
GIUFFRE007566.
“published globally, including within the Southern District of New York” as You contend in
5
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This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
c. the publishing entity and title of any publication containing the purportedly false
statement;
d. the URL or internet address for any internet version of such publication; and the
nature of the publication, whether in print, internet, broadcast or some other form of
media.
Ms. Giuffre objects because the information interrogatory above is in the possession of
Defendant who has failed to comply with her production obligations in this matter, and has failed
to comply with her production obligations with this very subject matter. See Document Request
No. 17 from Ms. Giuffre’s Second Request for Production of Documents to Defendant Ghislaine
Maxwell.1 Maxwell has not produced all “URL or Internet addresses for any internet version of
such publication” that she directed her agent, Ross Gow, to send.
1
Request No. 17 stated: Produce all documents concerning any statement made by You or on
Your behalf to the press or any other group or individual, including draft statements, concerning
Ms. Giuffre, by You, Ross Gow, or any other individual, from 2005 to the present, including the
dates of any publications, and if published online, the Uniform Resource Identifier (URL)
address. In response, Defendant stated: “Ms. Maxwell objects to this Request on the grounds that
it is cumulative and duplicative. Ms. Maxwell also objects to this Request to the extent it calls
for information that exists within the public domain, the internet or in public court records and
which are equally available to both parties and can be obtained from some other source that is
more convenient, less burdensome, and less expensive. Ms. Maxwell further objects to this
Request to the extent it seeks documents or information protected by the attorney/client
privilege, the work-product doctrine, or any other applicable privilege. Ms. Maxwell is not
producing documents that are available in the public domain. Ms. Maxwell has been unable to
locate any additional documents responsive to this Request.”
6
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This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
Ms. Giuffre further objects because the information requested above is in the possession
of Defendant’s agent, who caused the false statements to be issued to various media outlets. Ms.
Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer
remains incomplete. Consequently, Ms. Giuffre reserves the right to modify and/or supplement
her responses, as information is largely in the possession of the Defendant and her agent.
Ms. Giuffre objects to this interrogatory in that it violates Rule 33 as its subparts, in
combination with the other interrogatories, exceed the allowable twenty-five interrogatories. Ms.
Giuffre objects to this request because it is in the public domain. Ms. Giuffre also objects in that
it seeks information protected by the attorney-client/work product privilege, and any other
supplements such responsive documents with the following list of publications. While the
a good faith effort towards compliance, Ms. Giuffre provides the following examples, which are
2015 Each time the story is re told it changes with new salacious details about public
figures and world leaders and now it is alleged by Ms. Roberts that Alan
Dershowitz is involved in having sexual relations with her, which he denies.
Ms. Roberts’s claims are obvious lies and should be treated as such and not
publicized as news, as they are defamatory.
Ghislaine Maxwell's original response to the lies and defamatory claims remains the
same. Maxwell strongly denies allegations of an unsavoury nature, which have
appeared in the British press and elsewhere and reserves her right to seek redress at
7
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This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
2015
2015
2015
2015
2015
2015
2015 Broadca
st
2015 Broadca
st
8
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This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
Respectfully Submitted,
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on July 1, 2016, I electronically sent the foregoing document
43
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EXHIBIT I
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EXHIBIT J
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EXHIBIT K
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--------------------------------------------------X
..........................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
1. I am a Solicitor of the Senior Courts of England & Wales based in London, England.
4. I have represented Ms. Maxwell since 2011 regarding the allegations made by
Plaintiff Virginia Giuffre and as published in the United Kingdom. I continue to be retained in
this regard. I am familiar generally with the subject matter of this action.
5. I first represented Ms. Maxwell in this matter over the weekend of 5th and 6th March
2011, about the time when various UK national newspapers, in hard copy and on line, published
numerous and provocative allegations made by the Plaintiff Virginia Giuffre against
Ms. Maxwell. The articles by Sharon Churcher were among those published in this time frame.
6. I instructed British press agent Ross Gow to assist me in representing Ms. Maxwell.
1
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British Press over the weekend—March 5 and 6, 2011, and thereafter. I directed Mr. Gow to
distribute the statements to various media outlets that had published articles.
8. On December 30, 2014, Ms. Giuffre made numerous salacious and improper
allegations against Ms. Maxwell in a joinder motion publicly filed in a civil case involving
Jeffrey Epstein. Shortly afterward, the British media gained access to the motion and began
9. I continued to represent Ms. Maxwell at that time and I coordinated the response to
10. In liaison with Mr. Gow and my client, on January 2, 2015, I prepared a further
statement denying the allegations, and I instructed Mr. Gow to transmit it via email to members
of the British media who had made inquiry about plaintiff’s allegations about Ms. Maxwell.
Attached as Exhibit A1 is an email containing a true and correct copy of this statement. The
content, I prepared the vast majority of the statement and ultimately approved and adopted all of
11. As is evident from the timing and the typographical errors in the statement,
I prepared the statement in haste. I was not in the office on 2nd January 2015 as it was the Friday
immediately after New Years day which is a public holiday. Most people took 2nd January off
and many business closed that day. I don’t now recall where I was that day but I was hard to
reach and that indicates I was out with my family. I therefore would have prepared the statement
12. I recall that immediately after Ms. Giuffre’s motion was filed, media representatives
began contacting Mr. Gow and requesting Ms. Maxwell’s response to Ms. Giuffre’s allegations
2
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of criminal and other misconduct by Ms. Maxwell. I believed an immediate response was
imperative, even though this was happening in the midst of the holidays in the United Kingdom.
My communications with Mr. Gow and with Ms. Maxwell were sporadic, delayed and hurried
because of my and their own holiday schedules. I worked while on vacation and on Friday,
January 2, 2015, to ensure that the statement was issued as soon as possible after receiving the
media inquiries.
13. I did not ask Ms. Maxwell to respond point by point to Ms. Giuffre’s factual
allegations in the CVRA joinder motion. What we needed to do was issue an immediate denial
and that necessarily had to be short and to the point. It should have been obvious to the media
that Ms. Giuffre’s new and significantly more salacious allegations had no credibility because
they differed so substantially from her previous allegations, when she had the opportunity and
incentive to disclose all relevant facts about being a victim of alleged sexual abuse and sex
trafficking at the hands of the rich and powerful. I prepared the January 2015 statement based on
my knowledge of Ms. Giuffre’s past statements and her most recent statements in the joinder
motion, and made the point to the media-recipients that she and her new statements, which
differed so substantially from her former ones, were not credible—specifically, that the new
14. By way of example I recall that prior to the December 2014 filing of the joinder
motion and the subsequent press reports that Ms. Guiffre clearly stated she had not had sex with
Prince Andrew. Yet in her joinder motion she claimed she did have sex with Prince Andrew and
that the sex occurred in what can only be described as a very small bathtub, too small for a man
of Prince Andrew’s size to enjoy a bath in let alone sex. So as of December 2014 it was clear
Ms. Guiffre had made polar opposite statements. She was either lying when she said they did not
have sex or when she said they did. I made the inescapable inference that she is a liar, as clearly
3
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she is, since both statements cannot as a matter of fact be true. When someone says she did not
have sex and then says she did, in other words, there is an obvious lie.
15. I did not intend the January 2015 statement as a traditional press release solely to
disseminate information to the media. This is why I intentionally did not request that Mr. Gow or
any other public relations specialist prepare or participate in preparing the statement. Instead,
Mr. Gow served as my conduit to the media representatives who had requested a response to the
joinder motion allegations and who I believed might republish those allegations.
media representatives was twofold. First, I wanted to mitigate the harm to Ms. Maxwell’s
reputation from the press’s republication of plaintiff’s false allegations. I believed these ends
could be accomplished by suggesting to the media that, among other things, they should subject
plaintiff’s allegations to inquiry and scrutiny. For example, I noted that plaintiff’s allegations
changed dramatically over time, suggesting that they are “obvious lies” and therefore should not
be “publicised as news.”
17. Second, I intended the January 2015 statement to be “a shot across the bow” of the
media, which I believed had been unduly eager to publish plaintiff’s allegations without
conducting any inquiry of their own. This was the purpose of repeatedly stating that plaintiff’s
allegations were “defamatory.” In this sense, the statement was very much intended as a cease
and desist letter to the media-recipients, letting the media-recipients understand the seriousness
with which Ms. Maxwell considered the publication of plaintiff’s obviously false allegations and
18. It is important to understand that any story involving a member of the Royal Family,
especially a senior member such as Prince Andrew, gains huge media attention in the UK and a
story alleging he had a sex with the Plaintiff caused a feeding frenzy for the press. I wanted the
4
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press to stop and think before publishing, to cease and desist, and that if they continued then they
19. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with
the following language: “Please find attached a quotable statement on behalf of Ms Maxwell”
response—quoted in full, if it was to be used—to plaintiff’s December 30, 2014, allegations that
would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to
20. Selective and partial quotation and use of the statement would disserve my purposes.
It was intended to address Plaintiff’s behavior and allegations against Ms. Maxwell on a broad
scale, that is to say, Plaintiff’s history of making false allegations and innuendo to the media
against Ms. Maxwell. This is why the statement references Plaintiff’s “original allegations” and
points out that her story “changes”—i.e. is embellished—over time including the allegations
“now” that Professor Dershowitz allegedly had sexual relations with her. This is why I
distinguished in the statement between Plaintiff’s “original” allegations and her “new,” joinder-
motion allegations, which differed substantially from the original allegations. And this is why I
wrote, “Each time the story is re told [sic] it changes with new salacious details about public
figures and world leaders and now it is alleged by [Plaintiff] that Alan Derschowitz [sic] is
involved in having sexual relations with her, which he denies.” (Emphasis supplied.) Having
established the dramatic difference between Plaintiff’s two sets of allegations, which suggested
she was fabricating more and more-salacious allegations as she had more time to manufacture
them, I added the third paragraph: “[Ms. Giuffre’s] claims are obvious lies and should be treated
as such and not publicised as news, as they are defamatory.” (Emphasis supplied.) I believed
then, and believe now, that it was and remains a fair inference and conclusion that her claims
5
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were and are “obvious lies.” As noted, her claims not to have slept with Prince Andrew and to
have slept with Prince Andrew are a classic example of an obvious lie. One or other account is
21. As an example of her lack of credibility, the Plaintiff made allegations against
Professor Dershowitz, which I understand she has now withdrawn. Professor Dershowitz has
credibility because his story, insofar as I am familiar with it, has been consistent; Ms. Giuffre has
22. Further the Plaintiff’s account has become more salacious, for example, regarding
Prince Andrew. The Plaintiff clearly has been seeking publicity for her story and it is clear to me
that she understands retelling the same story doesn’t feed the media and generate publicity and
so each time she appears to create new allegations to generate media interest.
23. I understand the Plaintiff alleged in her Complaint in this action that the following
statements are defamatory. She alleges it was defamatory in the first paragraph of the January
2015 statement to state that “the allegations made by [the Plaintiff] against [Ms.] Maxwell are
untrue.” For the reasons stated above, it was and is my considered and firm opinion that, in fact,
her allegations are untrue. She alleges it was defamatory to state in the same paragraph that the
“original allegations” have been “shown to be untrue.” For the reasons stated above, it was and is
my considered and firm opinion that, in fact, her allegations are untrue. Finally, she alleges that it
was defamatory in the third paragraph to state that her claims are “obvious lies.” For the reasons
stated above, it was and is my considered and firm opinion that, in fact, her claims are obvious
lies.
24. Both Mr. Gow and I understood that once the January 2015 statement was sent to the
media-representatives, we had no ability to control whether or how they would use the statement
and we made no effort to control whether or how they would use the statement.
6
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statement did not publish any part of the statement. I am unaware of any media-recipient
26. The issuance of the statement fully complied with my ethical obligations as a lawyer.
Indeed it was duty in representing my client’s interests to ensure that a denial was immediately
issued. I would have been remiss if I had sat back and not issued a denial, and the press had
published that Ms. Maxwell had not responded to enquiries and had not denied the new
allegations; the public might have taken the silence as an admission there was some truth in the
allegations.
27. The content of the statement was entirely based on information I acquired in
28. At the time I directed the issuance of the statement, I was contemplating litigation
against the press-recipients as an additional means to mitigate and prevent harm to Ms. Maxwell.
Whilst the limitation period for a pure defamation claim has now expired, claims are still being
considered for example for publishing a deliberate falsehood, conspiracy to inure and other
tortious acts.
29. In any such UK defamation, or other related, action Ms. Giuffre would be a
defendant or a witness.
30. I directed that the statement indicate Ms. Maxwell “strongly denie[d] the allegations
of an unsavoury nature,” declare the allegations to be false, give the press-recipients notice that
the publications of the allegations “are defamatory,” and inform them that Ms. Maxwell was
7
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EXHIBIT L
Case 18-2868, Document 278, 08/09/2019, 2628230, Page94 of 648 1
4 VIRGINIA GIUFFRE,
5 Plaintiff,
6 vs.
7 GHISLAINE MAXWELL
8 Defendant.
9 -----------------------------------------------------
10 VIDEO-DEPOSITION
OF: JAMES MICHAEL AUSTRICH
11
TAKEN BY: Defendant
12
REPORTED BY: Karla Layfield, RMR
13 Stenographic Court Reporter
Notary Public
14 State of Florida at Large
1 I N D E X
2 PAGE
WITNESS:
3
James Michael Austrich
4
Direct Examination by Ms. Menninger 4
5 Cross-Examination by Mr. Edwards 92
Redirect Examination by Ms. Menninger 121
6 Recross-Examination by Mr. Edwards 143
10
- - -
11
12
13 E X H I B I T S
14 PLAINTIFF
16 DEFENDANT
17 1. Photograph 26
18 2. Passport 27
21
22 (Exhibits attached.)
23
24
25
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page98 of 648 11
2 right?
3 A Yeah, yeah.
8 in Sunrise.
15 Park, that's when she came to work with you at Taco Bell?
16 A Yes.
18 happened?
20 meeting her.
24 Q I understand.
4 A No.
5 Q Why not?
12 and not in the rehab program at the time that you met
18 believe.
20 A At my dad's house.
4 A Weeks.
7 A Uh-hmm.
10 ago.
12 A Yes.
14 A Yes.
16 parents.
21 ago
22 A Yeah.
25 A Yes.
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page101 of 648 14
2 A No.
5 A Yes.
12 A 16.
14 A That's a guess.
16 she is?
22 months it was.
24 A Yes, a roommate.
4 someone else?
6 Taco Bell.
9 well?
14 A I don't remember.
18 A Yeah.
20 A Yes.
22 A Yes.
24 A Um-hmm?
1 A Yes.
5 bought out. But I'm not sure if when I got there they
7 Q Got it.
11 a little while.
13 Roberts?
19 BY MS. MENNINGER:
22 head. She might have just applied there, and didn't get
24 Q Okay.
5 A Yes.
7 BY MS. MENNINGER:
8 Q With Mario?
9 A Yeah.
11 A Yes.
13 Park apartment?
19 the house?
22 lived in.
24 back?
25 A No idea.
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page105 of 648 19
1 A No.
3 A Not really.
5 A When, what?
10 months?
14 A Yes.
18 about?
22 A Yes.
24 A Yes.
4 A When I left.
5 Q Left where?
7 our apartment.
10 A Yes.
14 A No.
16 A No.
18 A Yes.
19 Q Where is it?
20 A I have it.
21 Q Still?
3 A Yeah.
5 house and the time that you broke up, did you guys break
12 Beach.
16 A I did.
18 A Yes.
20 A Yes.
22 A I believe so.
24 right?
1 one I rented.
2 Q Okay.
8 on it.
25 third floor.
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page109 of 648 27
3 Defendant's Exhibit 2.
5 for identification.)
6 BY MS. MENNINGER:
11 Austrich".
13 A Yes.
14 Q Is that you?
15 A Yes.
17 A Yes.
22 one.
24 in this apartment?
5 BY MS. MENNINGER:
10 A (Witness complies.)
13 paragraph.
16 in touch.
25 animals.
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page111 of 648 39
1 BY MS. MENNINER:
9 A Yes.
13 Broward.
15 Broward?
16 A Not a clue.
18 ex-fiancé, correct?
19 A Yes.
22 A Yes.
2 apartment.
3 BY MS. MENNINGER:
6 on pets?
7 A Yes.
11 liked animals.
14 Tony?
15 A Yeah.
17 encountered them?
18 A No, outside.
21 A Yes.
25 apartment."
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page113 of 648 41
3 indicating that you both lived there. But that's not what
4 you remember?
13 A I don't remember.
16 pets?
20 a fan of cats.
2 Q Did you get that stuff from the pet store where
4 A Yes.
5 Q A discount, I hope?
11 Q No reptiles?
16 Q Spiders?
21 face?
22 A I don't remember.
25 remember.
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page115 of 648 43
25 saw that name, I'm like "Who the hell is John Perkins?"
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page116 of 648 44
4 A Yeah.
9 in Broward.
12 '01?
17 A Yeah, yeah.
24 long.
3 Q And since that time you have not had any contact
5 A No.
9 remember.
10 BY MS. MENNINGER:
12 A Yes.
17 A Yes.
19 BY MS. MENNINGER:
21 A Actions.
23 BY MS. MENNINGER:
1 A Sorry.
3 A Yes.
6 A Yes.
15 Q Did she tell you what she was doing for Jeff?
17 was told.
18 Q By her?
19 A Yes.
21 A Yes.
23 A Yes.
3 A I don't remember.
7 end?
9 the idiot.
10 Q So the fight --
14 and you guys got in a fight about her messing with Tony?
18 that's when I found out about that, with the idiot. Then,
20 remember.
8 A Yeah.
10 A Yes.
12 whereabouts?
15 BY MS. MENNINGER:
17 A Yes.
22 BY MS. MENNINGER:
13 Q Did she, Ms. Roberts ever tell you that she was
15 A No.
17 for photographs?
18 A No.
20 my client?
23 remember.
1 C E R T I F I C A T E
2 STATE OF FLORIDA
3 COUNTY OF MARION
18
19 ______________________________
Karla Layfield, RMR
20 Stenographic Court Reporter
21
22
23
24
25
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page123 of 648 147
1 CERTIFICATE OF OATH
2 STATE OF FLORIDA
3 COUNTY OF MARION
8 of June, 2016.
10
_______________________________
11 Karla Layfield, RMR
Notary Public
12 State of Florida at Large
My Commission No. FF942806
13 My Commission Expires 12/10/2019
14
15 ____Personally Known
____Professionally Known
16 X Produced Identification of FDL
Exp. 07/9/80
17
18
19
20
21
22
23
24
25
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page124 of 648
EXHIBIT M
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EXHIBIT N
Agren
Case 18-2868, Blando Court
Document Reporting2628230,
278, 08/09/2019, & Video, Inc.
Page127 of 648
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
__________________________________________________
APPEARANCES:
1 APPEARANCES: (Continued)
2 HADDON, MORGAN AND FORMAN, P.C.
By Laura A. Menninger, Esq.
3 Jeffrey S. Pagliuca, Esq.
150 East 10th Avenue
4 Denver, CO 80203
Phone: 303.831.7364
5 [email protected]
[email protected]
6 Appearing on behalf of the
Defendant
7
Also Present:
8 Brenda Rodriguez, Paralegal
Nicholas F. Borgia, CLVS Videographer
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
14 PRODUCTION REQUEST(S):
15 (None.)
16
17
18
19
20
21
22
23
24
25
1 INDEX OF EXHIBITS
2
INITIAL
3 DESCRIPTION REFERENCE
4
Exhibit 1 Complaint and Demand for Jury 17
5 Trial re Jane Doe No. 102 v.
Jeffrey Epstein
6
Exhibit 2 Jane Doe #3 and Jane Doe #4's 21
7 Motion Pursuant to Rule 21 for
Joinder in Action
8
Exhibit 3 Declaration of Virginia L. 23
9 Giuffre re Jane Doe #1 and Jane
Doe #2 vs. United States of
10 America
11 Exhibit 4 Declaration of Jane Doe 3 re 31
Jane Doe #1 and Jane Doe #2 vs.
12 United States of America
13 Exhibit 5 Declaration of Virginia Giuffre 33
re Bradley J. Edwards and
14 Paul G. Cassell vs. Alan M.
Dershowitz
15
Exhibit 6 FBI documentation, date of entry 36
16 7/5/13
17 Exhibit 7 Document titled Telecon, 39
Participants Jack Scarola, Brad
18 Edwards, Virginia Roberts. Re
Edwards adv. Epstein, 4/7/11,
19 (23 pages of transcription)
20 Exhibit 8 The Billionaire's Playboy Club, 41
By Virginia Roberts
21
Exhibit 9 Plaintiff's Response and 44
22 Objections to Defendant's First
Set of Discovery Requests to
23 Plaintiff re Giuffre v. Maxwell
24
25
1
INITIAL
2 DESCRIPTION REFERENCE
3
Exhibit 10 Plaintiff's Supplemental 46
4 Response and Objections to
Defendant's First Set of
5 Discovery Requests to Plaintiff
6 Exhibit 11 Undated Declaration of Virginia 46
Giuffre re Plaintiff's
7 Supplemental Response and
Objections to Defendant's First
8 Set of Discovery Requests served
on March 22, 2016
9
Exhibit 12 Plaintiff's Second Amended 47
10 Supplemental Response and
Objections to Defendant's First
11 Set of Discovery Requests to
Plaintiff
12
Exhibit 13 Mrs. Virginia Giuffre resume 67
13
Exhibit 14 Compilation of e-mails re Open 68
14 Position - Virginia Giuffre
15 Exhibit 15 Virginia Lee Roberts passport 180
application
16
Exhibit 16 Composite of e-mail strings 251
17
Exhibit 17 Compilation of e-mails between 259
18 Giuffre and Silva and others
19 Exhibit 18 Compilation of e-mails between 265
Virginia Giuffre and Sandra
20 White
21 Exhibit 19 Compilation of e-mails between 269
Marianne Strong and Virginia
22 Giuffre
23 Exhibit 20 Compilation of e-mails between 276
Virginia Roberts and Jason
24 Richards
25
1
INITIAL
2 DESCRIPTION REFERENCE
3
Exhibit 21 Compilation of e-mails between 284
4 Sharon Churcher and Virginia
Giuffre
5
Exhibit 22 Compilation of e-mails among 287
6 Sharon Churcher, Michael Thomas,
Virginia Giuffre and others
7
Exhibit 23 Compilation of May 2011 e-mails 288
8 among Sharon Churcher, Virginia
Giuffre, Paulo Silva and others
9
Exhibit 24 Compilation of June 2011 e-mails 289
10 between Virginia Giuffre and
Sharon Churcher
11
Exhibit 26 PR Hub Statement on Behalf of 300
12 Ghislaine Maxwell article
13 Exhibit 27 1/2/15 e-mail from Ross Gow to 309
To Whom It May Concern
14
15
16
17
18
19
20
21
22
23
24
25
1 Q Which brother?
2 A Sky.
3 Q What about your other brother?
4 A I think he had moved out by then.
5 Q What forms of communication did you have?
6 Just a home phone number, or what?
7 A Yeah, there was a home phone.
8 Q When do you recall ever getting a cell
9 phone?
10 A The first cell phone I ever got was the
11 one that Ghislaine gave to me.
12 Q So you never had -- your parents, did they
13 have ones when you were working at Mar-a-Lago?
14 A No, my dad used to -- like, we had phones
15 in the spa and maintenance area and so on, so forth.
16 And you could, so to speak, page people from around
17 the courts.
18 Q Okay. So tell me what you recall of the
19 first conversation that you had with Ghislaine
20 Maxwell.
21 A I'm sitting there reading my book about
22 massage therapy, as I'm working in the spa. And I'm
23 getting my GE -- well, I was in the process of
24 getting my GED before I went to my summer job. I
25 decided that I would like to become a massage
1 A Yes.
2 Q Who else was at home when you got home?
3 A My mom, my dad and my brother.
4 Q Which brother?
5 A Sky.
6 Q And anyone else who was there at the time?
7 A I believe Michael might have been living
8 with me at that time. So he might have been there.
9 Q Do you recall if he was there when you got
10 home?
11 A I don't really remember. I remember what
12 I did when I got home, that I basically made a
13 beeline for the bathroom.
14 Q Let me ask you a question. Michael was
15 living with you at that home, at your parents' home
16 at the time, is your best recollection today; is that
17 right?
18 A That's my best recollection, yes.
19 Q When you say living with you, were you
20 guys staying in the same room?
21 A Yes.
22 Q Were you engaged at that time to him?
23 A That was a really weird relationship. He
24 was a friend who looked after me, and he did propose
25 to me and I did say yes. But my heart was never in
1 it.
2 He was somebody that helped me off the
3 streets so I felt compelled to say yes to him.
4 Q Okay. So when he proposed to you and you
5 said yes, did that take place before you started
6 working at Mar-a-Lago or after you started working at
7 Mar-a-Lago?
8 A Before.
9 Q And so if he were living with your parents
10 at that time, you were living in the same room; is
11 that correct?
12 A I believe so.
13 Q And your parents understood him to be your
14 fiance?
15 A I don't think they agreed with it, but I
16 think they understood it as that. I mean --
17 Q I mean, you communicated to them that he
18 had proposed and you had accepted?
19 A Yeah, in not such a pretty way. I mean,
20 they obviously weren't very happy about it. And it
21 wasn't my true intentions to ever marry him.
22 Q Okay.
23 A But I did it to make him feel okay. I
24 didn't want to be mean.
25 Q What did your mom say about your
1 Mail on Sunday?
2 A Yes.
3 Q Where is that contract right now?
4 A I don't know. I've moved that many times.
5 I -- I lose paperwork wherever I go.
6 Q Is it possible it's in the boxes in
7 Sydney?
8 A I don't think I kept it, to be honest.
9 Q Did you ever refer back to it after you
10 signed it?
11 A I know I kept it for a short while, but I
12 mean, like I said, I've moved countries twice in the
13 last two years and three different houses. So the
14 paper trail is lost. I don't know where it would be.
15 Q Did you receive it via e-mail?
16 A No. I received it -- Sharon Churcher
17 handed it to me by paper.
18 Q And you signed it?
19 A I signed it.
20 Q And then did you make a copy of it?
21 A No.
22 Q You never had a copy of it?
23 A Well, I had my own copy. I'm sure she has
24 hers.
25 Q Do you recall there being a period of
1 STATE OF COLORADO)
2 ) ss. REPORTER'S CERTIFICATE
3 COUNTY OF DENVER )
4 I, Kelly A. Mackereth, do hereby certify
5 that I am a Registered Professional Reporter and
6 Notary Public within the State of Colorado; that
7 previous to the commencement of the examination, the
8 deponent was duly sworn to testify to the truth.
9 I further certify that this deposition was
10 taken in shorthand by me at the time and place herein
11 set forth, that it was thereafter reduced to
12 typewritten form, and that the foregoing constitutes
13 a true and correct transcript.
14 I further certify that I am not related to,
15 employed by, nor of counsel for any of the parties or
16 attorneys herein, nor otherwise interested in the
17 result of the within action.
18 In witness whereof, I have affixed my
19 signature this 11th day of May, 2016.
20 My commission expires April 21, 2019.
21
22 ____________________________
Kelly A. Mackereth, CRR, RPR, CSR
23 216 - 16th Street, Suite 600
Denver, Colorado 80202
24
25
EXHIBIT O
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EXHIBIT P
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Video Deposition of Tony Figueroa (Volume 1) 1
14
17
DATE: Friday, June 24, 2016
18
TIME: Commenced: 8:59 a.m.
19 Concluded: 1:22 p.m.
20 PLACE: Southern Reporting Company
B. Paul Katz Professional Center
21 (SunTrust Building)
One Florida Park Drive South
22 Suite 214
Palm Coast, Florida 32137
23
REPORTED BY: LEANNE W. FITZGERALD, FPR
24 Florida Professional Reporter
Court Reporter and Notary Public
25
1 APPEARANCE OF COUNSEL
2
15
18
19
20
21
22
23
24
25
1 INDEX
2
3 ----------------------------------------------------
4 VOLUME 1 (pages 1 - 157)
5 TONY FIGUEROA
Direct Examination by Ms. Menninger 5
6
OATH OF REPORTER 156
7
CERTIFICATE OF REPORTER 157
8
---------------------------------------------------
9
VOLUME 2 (Pages 158 - 258)
10
TONY FIGUEROA
11 Cross-Examination by Mr. Edwards 162
Redirect Examination by Ms. Menninger 218
12 Recross-Examination by Mr. Edwards 243
Further Direct Examination by 253
13 Ms. Menninger
14 OATH OF REPORTER 257
15 CERTIFICATE OF REPORTER 258
16 ---------------------------------------------------
17
- - -
18
19
20 STIPULATION
21 It is hereby stipulated and agreed by and
22 between counsel present at this deposition and by
23 the deponent that the witness review of this
24 deposition would be waived.
25
1 INDEX OF EXHIBITS
2
3
(MARKED BY THE DEFENDANT:)
4
Defendant's Exhibit 1 42
5 (Palm Beach County Sheriff's Reports -
Case Number 98041883)
6
Defendant's Exhibit 2 71
7 (Greenacres Reports)
8 Defendant's Exhibit 3 77
(Two Pictures of Apartment Building)
9
Defendant's Exhibit 4 83
10 (Palm Beach County Sheriff's Reports -
Case Number 02075321)
11
Defendant's Exhibit 5 134
12 (Royal Palm Beach Police Reports)
13 Defendant's Exhibit 6 144
(Robert's School Records)
14
15
16 - - -
17
23
- - -
24
25
1 BY MS. MENNINGER:
2 Q And where did you go after Royal Palm
3 Beach?
4 A I believe it was South Area. I'm pretty
5 sure it was South Area.
6 Q Did you go to another school after that?
7 A Yeah. I went to Gold Coast after that.
8 Q Is that also in Royal Palm Beach?
9 A No. That's -- South Area was in Lake
10 Worth. Gold Coast is in West Palm. They were both
11 alternative schools.
12 Q Did you ever go to a Survivors Charter
13 School?
14 A Yes. I went there, too.
15 Q When did you go there?
16 A I'm not exactly sure of the date. But it
17 was somewhere after either -- I'm pretty sure it
18 was -- maybe -- I can't remember if it was Gold
19 Coast first or Survivor. But one of the -- I'm
20 trying to remember. I honestly don't remember which
21 one came first.
22 Q That's all right.
23 Can you describe for me Survivors Charter
24 School? What is it like, or was it like?
25 A I mean, like I said, it was an alternative
1 BY MS. MENNINGER:
2 Q Mr. Figueroa, you mentioned that you and
3 Ms. Roberts attempted to go to back to school while
4 you were together --
5 A Yes.
6 Q -- to get your GED?
7 A Yeah. Yes.
8 Q And you believe that you went to the
9 Survivors Charter School?
10 A Yes.
11 MS. MENNINGER: Okay. I'm going to mark
12 Defendant's Exhibit 6.
13 (Defendant's Exhibit 6 was marked for
14 identification.)
15 BY MS. MENNINGER:
16 Q This is a school record for Ms. Roberts
17 that lists the names of various schools. And --
18 A So it was Survivors, obviously. That's
19 the only one on that list that isn't -- or that's
20 there that's on mine, as well.
21 Q Okay.
22 A Other than the other ones, but...
23 Q All right. So you recognize Survivors
24 Charter School on Ms. Roberts' school records?
25 A Yeah. That's what I'm saying. Since that
1 CERTIFICATE OF REPORTER
2
STATE OF FLORIDA )
3 )
COUNTY OF VOLUSIA )
4
15
16
17
18
19
__________________________________
20 Leanne W. Fitzgerald, FPR
Florida Professional Reporter
21
Digital Certificate Authenticated
22 By Symantec
23
24
25
EXHIBIT Q
$JUHQ%ODQGR&RXUW5HSRUWLQJ 9LGHR,QF
Case 18-2868, Document 278, 08/09/2019, 2628230, Page184 of 648
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
__________________________________________________
APPEARANCES:
9,5*,1,$*,8))5(92/80(,,
$JUHQ%ODQGR&RXUW5HSRUWLQJ 9LGHR,QF
Case 18-2868, Document 278, 08/09/2019, 2628230, Page185 of 648
1 APPEARANCES: (Continued)
2 HADDON, MORGAN AND FORMAN, P.C.
By Laura Menninger, Esq.
3 Jeffrey S. Pagliuca, Esq.
150 East 10th Avenue
4 Denver, CO 80203
Phone: 303.831.7364
5 [email protected]
[email protected]
6 Appearing on behalf of the
Defendant
7
Also Present:
8 Ann Lundberg, Paralegal
Maryvonne Tompkins, Videographer
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
9,5*,1,$*,8))5(92/80(,,
$JUHQ%ODQGR&RXUW5HSRUWLQJ 9LGHR,QF
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15
16
17
18
19
20
21
22
23
24
25
9,5*,1,$*,8))5(92/80(,,
$JUHQ%ODQGR&RXUW5HSRUWLQJ 9LGHR,QF
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9,5*,1,$*,8))5(92/80(,,
$JUHQ%ODQGR&RXUW5HSRUWLQJ 9LGHR,QF
Case 18-2868, Document 278, 08/09/2019, 2628230, Page188 of 648
1 INITIAL
DESCRIPTION REFERENCE
2
Exhibit 15 Patient Health Summary, Clifton 512
3 Beach Medical & Surgical,
printed on 6/28/2016
4
Exhibit 16 Portions of deposition transcript 533
5 of Virginia Giuffre taken
May 3, 2016
6
Exhibit 17 Amendment/Errata Sheet signed 540
7 May 31, 2016 by Virginia Giuffre
8 Exhibit 18 Ad for Mar-a-Lago Club 548
9 Exhibit 19 The Mar-a-Lago Club, L.C. 549
Employment Policies, October 28,
10 1995
11 Exhibit 20 Page from the Mar-a-Lago Club 550
Employment Policies, Revised
12 10/2001
13
14
15
16
17
18
19
20
21
22
23
24
25
9,5*,1,$*,8))5(92/80(,,
$JUHQ%ODQGR&RXUW5HSRUWLQJ 9LGHR,QF
Case 18-2868, Document 278, 08/09/2019, 2628230, Page189 of 648
1 A Yes.
2 Q And you believe the Neiman Marcus was
3 located in which city?
4 A Well, it's around Fort Lauderdale. I
5 can't tell you exactly. Fort Lauderdale is so big,
6 like Broward County? Is that the word for it?
7 Q And what did you do at Neiman Marcus?
8 A I worked in the changing rooms.
9 Q And what did you do in the changing room?
10 A I think I just like -- if I remember
11 right, I just put clothes away that people left in
12 there. Probably went out to get sizes, different
13 sizes for women who wanted different sizes of the
14 same product.
15 Q And where did you work after Neiman
16 Marcus?
17 A Taco Bell.
18 Q Did you work at Southeast Employee
19 Management Company?
20 A I don't recognize that. I don't know if
21 that's a payroll company or what it is. I don't know
22 what Southeast -- what is it called?
23 Q Southeast Employee Management Company.
24 A No, I don't remember that.
25 Q Did you ever work as a temp?
9,5*,1,$*,8))5(92/80(,,
$JUHQ%ODQGR&RXUW5HSRUWLQJ 9LGHR,QF
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$JUHQ%ODQGR&RXUW5HSRUWLQJ 9LGHR,QF
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9,5*,1,$*,8))5(92/80(,,
$JUHQ%ODQGR&RXUW5HSRUWLQJ 9LGHR,QF
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9,5*,1,$*,8))5(92/80(,,
$JUHQ%ODQGR&RXUW5HSRUWLQJ 9LGHR,QF
Case 18-2868, Document 278, 08/09/2019, 2628230, Page193 of 648
1 STATE OF COLORADO)
2 ) ss. REPORTER'S CERTIFICATE
3 COUNTY OF DENVER )
4 I, Pamela J. Hansen, do hereby certify that
5 I am a Registered Professional Reporter and Notary
6 Public within the State of Colorado; that previous to
7 the commencement of the examination, the deponent was
8 duly sworn to testify to the truth.
9 I further certify that this deposition was
10 taken in shorthand by me at the time and place herein
11 set forth, that it was thereafter reduced to
12 typewritten form, and that the foregoing constitutes
13 a true and correct transcript.
14 I further certify that I am not related to,
15 employed by, nor of counsel for any of the parties or
16 attorneys herein, nor otherwise interested in the
17 result of the within action.
18 In witness whereof, I have affixed my
19 signature this 23rd day of November, 2016.
20 My commission expires September 3, 2018.
21
22 _______________________________
Pamela J. Hansen, CRR, RPR, RMR
23 216 - 16th Street, Suite 600
Denver, Colorado 80202
24
25
9,5*,1,$*,8))5(92/80(,,
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EXHIBIT R
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EXHIBIT S
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MAR-A-LAGO-0001
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TERMINATIONS
Page 1 of 17
MAR-A-LAGO 0161
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TERMINATIONS
Page 2 of 17
MAR-A-LAGO 0162
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TERMINATIONS
Page 3 of 17
MAR-A-LAGO 0163
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TERMINATIONS
Page 4 of 17
MAR-A-LAGO 0164
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TERMINATIONS
Page 5 of 17
MAR-A-LAGO 0165
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TERMINATIONS
Page 6 of 17
MAR-A-LAGO 0166
Case 18-2868, Document 278, 08/09/2019, 2628230, Page209 of 648
TERMINATIONS
Page 7 of 17
MAR-A-LAGO 0167
Case 18-2868, Document 278, 08/09/2019, 2628230, Page210 of 648
TERMINATIONS
Page 8 of 17
MAR-A-LAGO 0168
Case 18-2868, Document 278, 08/09/2019, 2628230, Page211 of 648
TERMINATIONS
Page 9 of 17
MAR-A-LAGO 0169
Case 18-2868, Document 278, 08/09/2019, 2628230, Page212 of 648
TERMINATIONS
Page 10 of 17
MAR-A-LAGO 0170
Case 18-2868, Document 278, 08/09/2019, 2628230, Page213 of 648
TERMINATIONS
Page 11 of 17
MAR-A-LAGO 0171
Case 18-2868, Document 278, 08/09/2019, 2628230, Page214 of 648
TERMINATIONS
Page 12 of 17
MAR-A-LAGO 0172
Case 18-2868, Document 278, 08/09/2019, 2628230, Page215 of 648
TERMINATIONS
Page 13 of 17
MAR-A-LAGO 0173
Case 18-2868, Document 278, 08/09/2019, 2628230, Page216 of 648
TERMINATIONS
Page 14 of 17
MAR-A-LAGO 0174
Case 18-2868, Document 278, 08/09/2019, 2628230, Page217 of 648
TERMINATIONS
Page 15 of 17
MAR-A-LAGO 0175
Case 18-2868, Document 278, 08/09/2019, 2628230, Page218 of 648
TERMINATIONS
Page 16 of 17
MAR-A-LAGO 0176
Case 18-2868, Document 278, 08/09/2019, 2628230, Page219 of 648
TERMINATIONS
Page 17 of 17
MAR-A-LAGO 0177
Case 18-2868, Document 278, 08/09/2019, 2628230, Page220 of 648
EXHIBIT T
Case 18-2868, Document 278, 08/09/2019, 2628230, Page221 of 648 1
3
Civil Action No. 15-cv-07433-RWS
4
VIRGINIA GIUFFRE,
5
Plaintiff,
6
vs.
7
GHISLAINE MAXWELL,
8
Defendant.
9 -----------------------------------------------------
1 I N D E X
2 PAGE
WITNESS:
3
Sky Roberts
4
Direct Examination by Ms. Menninger 4
5 Cross-Examination by Mr. Edwards 133
Redirect Examination by Ms. Menninger 135
6 Recross-Examination by Mr. Edwards 141
7
Reporter's Certificate 143
8 Certificate of Oath 144
10 - - -
11
12
E X H I B I T S
13
Defendant's Exhibit 1 6
14 Defendant's Exhibit 2 28
Defendant's Exhibit 3 48
15 Defendant's Exhibit 4 52
Defendant's Exhibit 5 58
16 Defendant's Exhibit 6 116
Defendant's Exhibit 7 122
17 Defendant's Exhibit 8 125
Defendant's Exhibit 9 137
18
19 (Exhibits attached.)
20
21
22
23
24
25
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page223 of 648 72
2 you felt like was appropriate for Virginia or did you just
3 go out and talk to the woman who ran the spa area on your
4 own?
7 to be a full-time job?
22 period of time?
23 A Yes.
25 period of time?
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page224 of 648 73
1 A Yes.
3 there?
4 A Every year.
6 it's so hot?
10 know.
16 Q I understand.
19 I think that was her name, Angela. But it's kind of the
2 Q Uh-huh.
4 lady in the spa area named Ms. Maxwell. I don't know her.
6 But just she said Ms. Maxwell said she can get
9 you know, and that she was going to learn massage therapy.
12 don't remember.
13 Q I understand.
15 Mar-a-Lago?
17 little bit, you know, and then she told me, yes, that she
19 Q Okay.
20 A You know.
25 BY MS. MENNINGER:
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page226 of 648 82
4 A Once.
7 came out and I met him and seemed just fine to me. I
10 read that he's not a good guy. But you can't tell. You
12 know.
18 A Yeah.
19 Q Was it later?
21 Because I wanted to see where she was at, you know. And
25 very nice.
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page227 of 648 83
2 with him?
5 somewhere, I just want to meet the guy and see what was
12 A Yes.
14 A No.
16 A No.
22 A No.
24 A No.
1 massage therapy.
4 in any way?
8 A Not to me.
11 A No.
18 A No.
20 Mr. Epstein?
21 A No.
24 A No.
1 C E R T I F I C A T E
2 STATE OF FLORIDA
3 COUNTY OF MARION
11 of my ability.
18
19
Karla Layfield, RMR
20 Stenographic Court Reporter
21
22
23
24
25
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page230 of 648 144
1 CERTIFICATE OF OATH
2 STATE OF FLORIDA
3 COUNTY OF MARION
8 of May 2016.
10
14
15 Personally Known
Professionally Known
16 Produced Identification of FDL
17
18
19
20
21
22
23
24
25
Owen & Associates Court Reporters
P.O. Box 157, Ocala, Florida
352.624.2258 * [email protected]
Case 18-2868, Document 278, 08/09/2019, 2628230, Page231 of 648
EXHIBIT U
Case 18-2868, Document 278, 08/09/2019, 2628230, Page232 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page233 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page234 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page235 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page236 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page237 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page238 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page239 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page240 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page241 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page242 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page243 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page244 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page245 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page246 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page247 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page248 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page249 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page250 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page251 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page252 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page253 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page254 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page255 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page256 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page257 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page258 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page259 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page260 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page261 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page262 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page263 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page264 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page265 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page266 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page267 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page268 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page269 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page270 of 648
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page276 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page277 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page278 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page279 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page280 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page281 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page282 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page283 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page284 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page285 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page286 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page287 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page288 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page289 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page290 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page291 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page292 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page293 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page294 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page295 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page296 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page297 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page298 of 648
EXHIBIT V
Case 18-2868, Document 278, 08/09/2019, 2628230, Page299 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page300 of 648
EXHIBIT W
Case 18-2868, Document 278, 08/09/2019, 2628230, Page301 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page302 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page303 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page304 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page305 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page306 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page307 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page308 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page309 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page310 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page311 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page312 of 648
EXHIBIT X
Case 18-2868, Document 278, 08/09/2019, 2628230, Page313 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page314 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page315 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page316 of 648
EXHIBIT Y
Case 18-2868, Document 278, 08/09/2019, 2628230, Page317 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page318 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page319 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page320 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page321 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page322 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page323 of 648
EXHIBIT Z
Case 18-2868, Document 278, 08/09/2019, 2628230, Page324 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page325 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page326 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page327 of 648
EXHIBIT AA
Case 18-2868, Document 278, 08/09/2019, 2628230, Page328 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page329 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page330 of 648
EXHIBIT BB
Case 18-2868, Document 278, 08/09/2019, 2628230, Page331 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page332 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page333 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page334 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page335 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page336 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page337 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page338 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page339 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page340 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page341 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page342 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page343 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page344 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page345 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page346 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page347 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page348 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page349 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page350 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page351 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page352 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page353 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page354 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page355 of 648
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page361 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page362 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page363 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page364 of 648
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page367 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page368 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page369 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page370 of 648
Case 18-2868, Document 278, 08/09/2019, 2628230, Page371 of 648
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page374 of 648
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page438 of 648
EXHIBIT CC
Case 18-2868, Document 278, 08/09/2019, 2628230, Page439 of 648
Confidential
Page 1
------------------------------------------x
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
June 3, 2016
9:07 a.m.
C O N F I D E N T I A L
Page 2
2
3 A P P E A R A N C E S:
4 BOIES SCHILLER & FLEXNER, LLP
Attorneys for Plaintiff
5 401 East Las Olas Boulevard
Fort Lauderdale, Florida 33301
6 BY: BRADLEY EDWARDS, ESQ.
7
8 HADDON MORGAN & FOREMAN, P.C.
Attorneys for Defendant
9 150 East 10th Avenue
Denver, Colorado 80203
10 BY: JEFFREY PAGLIUCA, ESQ.
11
12
13 ALSO PRESENT: Sandy Perkins, Paralegal
Boies Schiller & Flexner
14
Ryan Kick, Videographer
15
16
17
18
19
20
21
22
23
24
25
Case 18-2868, Document 278, 08/09/2019, 2628230, Page441 of 648
Confidential
Page 3
2
3 I N D E X
8 E X H I B I T S
23
24
25
Case 18-2868, Document 278, 08/09/2019, 2628230, Page442 of 648
Confidential
Page 6
1 DAVID RODGERS
2 A. Yes.
10 A. Yes.
12 BY MR. EDWARDS:
21 the subpoena.
Page 7
1 DAVID RODGERS
2 BY MR. EDWARDS:
4 there --
5 A. Okay.
7 A. Okay.
12 A. Yes.
16 log.
19 A. I did.
22 one second.
25 thought.
Case 18-2868, Document 278, 08/09/2019, 2628230, Page444 of 648
Confidential
Page 8
1 DAVID RODGERS
3 last page.
7 exhibit.
13 page.
23 BY MR. EDWARDS:
Page 9
1 DAVID RODGERS
11 A. Correct.
13 in your logbook?
14 A. As accurately as I can.
15 Q. Okay.
16 A. Yes.
18 exhibit?
19 A. Uh-huh.
22 A. Uh-huh.
24 A. Correct.
Page 10
1 DAVID RODGERS
3 A. Yes.
6 1995?
7 A. Yes.
10 A. Yes.
13 that number?
19 aircraft.
Page 11
1 DAVID RODGERS
3 A. Yes.
6 A. That's correct.
9 A. Right.
21 A. Uh-huh.
23 A. Yes.
Page 12
1 DAVID RODGERS
5 chosen?
7 requested.
9 Jeffrey Epstein?
10 A. No.
12 Epstein?
13 A. July of 1991.
17 Q. Okay.
21 A. Yes.
24 A. Yes.
Page 13
1 DAVID RODGERS
8 Epstein?
10 so, but --
12 passenger --
13 A. Yes.
14 Q. -- on that airplane?
15 A. Yes.
Page 14
1 DAVID RODGERS
3 Q. Okay.
8 we answer Juliet.
10 jurisdictional code?
11 A. No.
13 aircraft?
14 A. Right. Right.
22 A. Yes.
25 Q. To the Boeing?
Case 18-2868, Document 278, 08/09/2019, 2628230, Page451 of 648
Confidential
Page 15
1 DAVID RODGERS
3 Q. Okay.
6 A. Yes.
8 A. Columbus, Ohio.
10 A. Airport identifier.
12 a particular airport?
13 A. Correct.
15 A. Yes.
16 Q. Where is that?
19 "Miles Flown."
20 A. Right.
22 A. I don't.
25 flight number?
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Confidential
Page 99
1 DAVID RODGERS
2 Q. Okay.
10 that.
16 BY MR. EDWARDS:
18 anything else?
20 Q. Okay.
Page 100
1 DAVID RODGERS
8 talking about?
9 A. Yes.
12 that?
13 A. Yes, right.
18 name.
19 A. Right. Right.
22 name?
23 A. Correct.
Page 103
1 DAVID RODGERS
2 Boeing?
3 A. Yes.
15 passengers' names?
25 A. No.
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Confidential
Page 107
1 DAVID RODGERS
9 Paris-Le Bourget.
11 Paris?
16 that is in Spain.
17 Q. Granada, Spain?
20 trip?
Page 219
1 DAVID RODGERS
2 CERTIFICATE OF OATH
3 STATE OF FLORIDA )
4 COUNTY OF MIAMI-DADE )
5
I, the undersigned authority, certify
6 that DAVID RODGERS personally appeared before
me and was duly sworn.
7 WITNESS my hand and official seal
this 8th day of June, 2016.
8
9
Kelli Ann Willis, RPR, CRR
10 Notary Public, State of Florida
Commission FF928291, Expires 2-16-20
11 + + + + + + + + + + + + + + + + + +
12 CERTIFICATE
13 STATE OF FLORIDA )
14 COUNTY OF MIAMI-DADE )
23
25
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EXHIBIT DD
INTENTIONALLY
LEFT BLANK
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EXHIBIT EE
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EXHIBIT FF
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EXHIBIT GG
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Page 1
------------------------------------------x
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
-------------------------------------------x
C O N F I D E N T I A L
Deposition of JOSEPH RECAREY, 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.
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Page 2
2 A P P E A R A N C E S:
3
4 BOIES SCHILLER & FLEXNER, LLP
5 Attorneys for Plaintiff
401 East Las Olas Boulevard
6 Fort Lauderdale, Florida 33301
BY: BRADLEY EDWARDS, ESQ.
7
8 HADDON MORGAN & FOREMAN, P.C.
Attorneys for Defendant
9 150 East 10th Avenue
Denver, Colorado 80203
10 BY: JEFFREY PAGLIUCA, ESQ.
11
12 JONES FOSTER JOHNSTON & STUBBS, P.A.
Attorneys for Deponent
13 505 South Flagler Drive
Suite 1100
14 West Palm Beach, Florida 33401
BY: JOANNE O'CONNOR, ESQ.
15
16 ALSO PRESENT: Sandy Perkins, Paralegal
Boies Schiller & Flexner
17
Ryan Kick, Videographer
18
19
20
21
22
23
24
25
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Page 3
2
3 I N D E X
4 Examination by Mr. Edwards .................... 9
Examination by Ms. Schultz ..................... 123
5 Examination by Mr. Pagliuca .................... 165
Further Examination by Ms. Schultz ............. 329
6 Further Examination by Mr. Pagliuca ............ 355
7
8 E X H I B I T S
9 Deposition Exhibit 1 ........................... 11
Palm Beach Police Department
10 Incident Report
11 Deposition Exhibit 2 ........................... 59
AH statement
12
Deposition Exhibit 3 ........................... 66
13 CD with video (retained by Boies)
14 Deposition Exhibit 4 ........................... 69
Search warrant return
15
Deposition Exhibit 5 ........................... 76
16 Property receipts
17 Deposition Exhibit 6 ........................... 77
Additional search warrant returns
18
Deposition Exhibit 7 ........................... 84
19 Probably cause affidavit
20 Deposition Exhibit 8 ........................... 96
Trash pull return
21
Deposition Exhibit 9 ........................... 102
22 Folder with evidence
23
24
25
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Page 4
2 Deposition Exhibit 10 .......................... 119
Investigative report
3
Deposition Exhibit 11 .......................... 165
4 CD with audio recording (retained by Boies)
5 Deposition Exhibit 11 .......................... 178
Supplement to incident report
6
Deposition Exhibit 12 .......................... 259
7 Rule 26 disclosure
8 Deposition Exhibit 13 .......................... 282
Vol. 2 of prior Recarey transcript
9
Deposition Exhibit 14 .......................... 292
10 Vol. 1 of prior Recarey transcript
11
12
13 *** Exhibit 11 was used on two different exhibits.
14
15
16
17
18
19
20
21
22
23
24
25
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Page 10
1 JOSEPH RECAREY - CONFIDENTIAL
2 Q. Most of the events that we are going to
3 discuss today occurred, at least the investigation
4 that we're going to discuss today, occurred in 2005
5 and 2006.
6 So can you just tell us what your position
7 was with the Palm Beach Police Department at that
8 time?
9 A. I was a police detective.
10 Q. And did you investigate a person by the
11 name of Jeffrey Epstein?
12 A. I did.
13 Q. All right.
14 What was your role in the investigation of
15 Jeffrey Epstein?
16 A. I was the lead detective once the case was
17 turned over to me by Michelle Pagan.
18 Q. Okay. And as the lead detective, did you
19 review all of the history of the investigation up to
20 the point it was turned over to you?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Correct.
24 BY MR. EDWARDS:
25 Q. And was that one of your jobs as the lead
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Page 11
1 JOSEPH RECAREY - CONFIDENTIAL
2 investigator over a case, is to acclimate yourself
3 to the history of the case?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Yes.
7 BY MR. EDWARDS:
8 Q. Just so that the record is clear, will you
9 just give a brief pause in case Mr. Pagliuca has an
10 objection?
11 A. All right.
12 Q. So they can also capture your answer.
13 A. Okay.
14 Q. In reviewing the history of the case, did
15 you review prior police reports, police reports
16 prior to you becoming involved personally?
17 A. I did.
18 Q. Okay. And I've handed you what is marked
19 as Plaintiff's Exhibit 1.
20 (The referred-to document was marked by
21 the court reporter for Identification as
22 Deposition Exhibit 1.)
23 BY MR. EDWARDS:
24 Q. Do you recognize that?
25 A. Yes.
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1 JOSEPH RECAREY - CONFIDENTIAL
2 Police Department incident report as suspects?
3 MS. SCHULTZ: Object to form and
4 foundation.
5 BY MR. PAGLIUCA:
6 Q. These people, right?
7 A. At that time, yes.
8 Q. Well, and then are you aware -- were there
9 any suspects added in any subsequent reports, to
10 your knowledge?
11 A. Not that I'm aware of.
12 Q. In fact, you did not seek a probable cause
13 warrant for any other suspects in this case,
14 correct?
15 MS. SCHULTZ: Object to form and
16 foundation.
17 THE WITNESS: That's correct.
18 BY MR. PAGLIUCA:
19 Q. And Ms. Ghislaine Maxwell is not listed in
20 any of your Palm Beach Police Department incident
21 reports as a suspect in this case, correct?
22 MS. SCHULTZ: Object to form and
23 foundation.
24 THE WITNESS: Not -- no, not as a suspect
25 in this case, no.
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1 JOSEPH RECAREY - CONFIDENTIAL
2 Exhibit 1. Are you with me?
3 A. Uh-huh.
4 Q. Okay. Again, this was information that
5 was obtained by Detective Pagan, correct?
6 A. Correct.
7 Q. And it's true, is it not, that this
8 alleged victim never claimed to have been recruited
9 by Ghislaine Maxwell; true?
10 MS. SCHULTZ: Object to form and
11 foundation.
12 THE WITNESS: Correct.
13 BY MR. PAGLIUCA:
14 Q. And this individual, alleged victim No. 1,
15 never identified Ghislaine Maxwell as being at
16 Mr. Epstein's house when she was there, correct?
17 MS. SCHULTZ: Object to form and
18 foundation.
19 THE WITNESS: I don't believe so.
20 BY MR. PAGLIUCA:
21 Q. You don't believe so --
22 A. I don't believe so.
23 Q. That she ever identified Ghislaine Maxwell
24 as being in the house?
25 A. Right.
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1 JOSEPH RECAREY - CONFIDENTIAL
2 Q. Okay. She never -- this individual,
3 victim No. 1, never claimed that Ghislaine Maxwell
4 paid her any money, correct?
5 A. Correct.
6 Q. And this individual No. 1 never claimed
7 that Ms. Maxwell instructed her what to wear,
8 correct?
9 A. Right.
10 Q. This individual never claimed that
11 Ghislaine Maxwell told her how to act, correct?
12 A. Correct.
13 Q. This individual never claimed to have met
14 Ghislaine Maxwell ever, correct?
15 A. I don't believe so, no.
16 Q. This individual never claimed to even have
17 spoken to Ghislaine Maxwell ever, correct?
18 A. I don't believe so, no.
19 Q. And when you say "I don't believe so, no,"
20 that means my statement to you is correct; is that
21 right?
22 MS. SCHULTZ: Object to form, foundation.
23 THE WITNESS: Well, you're saying "ever."
24 I don't know if she's ever, ever spoken to --
25
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1 JOSEPH RECAREY - CONFIDENTIAL
2 BY MR. PAGLIUCA:
3 Q. To Detective Pagan.
4 A. Right. To my knowledge, I don't know,
5 because Detective Pagan is the one who actually
6 interviewed her. So I don't know to the answer of
7 "ever." So not to my knowledge.
8 Q. Certainly, nothing in Exhibit 1, Narrative
9 1 reflects that this individual ever met or talked
10 to or spoke to Ghislaine Maxwell, right?
11 A. Right. Not to my knowledge.
12 Q. And, indeed, you would agree with me that
13 if this individual claimed that Ms. Maxwell had
14 something to do with the events listed in Narrative
15 1, you would have folded up on it, as the
16 investigating detective, right?
17 MS. SCHULTZ: Object to the form.
18 THE WITNESS: Either myself or Detective
19 Pagan would have.
20 BY MR. PAGLIUCA:
21 Q. Sure. And when you got the case six
22 months later, if there hadn't been follow-up, you
23 would have followed up on it, right?
24 MS. SCHULTZ: Object to form.
25 THE WITNESS: Correct.
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1 JOSEPH RECAREY - CONFIDENTIAL
2 Q. Okay. The person alleged to have brought
3 the alleged victim No. 1 to Mr. Epstein's house is
4 this Hayley Robson individual, correct?
5 A. Yes.
6 Q. Okay. Then with regard to alleged victim
7 No. 2, then this individual did not claim to have
8 been recruited by Ms. Maxwell, correct?
9 MS. SCHULTZ: Object.
10 THE WITNESS: Who would be victim No. 2?
11 BY MR. PAGLIUCA:
12 Q. Well, you can either go to the second page
13 of Exhibit 1 and we can just follow down the victim
14 information, or you can go to the body of the
15 report, whichever is easier for you.
16 MS. SCHULTZ: Can you use the initials?
17 MR. PAGLIUCA: Sure. I can call them 1 or
18 AH or whatever you want to call them. That's
19 fine with me.
20 BY MR. PAGLIUCA:
21 Q. So I'll just say alleged victim AH never
22 claimed to have been recruited by Ms. Maxwell,
23 correct?
24 A. Correct.
25 Q. And alleged victim AH did not claim to
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1 JOSEPH RECAREY - CONFIDENTIAL
2 have spoken to Ms. Maxwell ever, correct?
3 MS. SCHULTZ: Object to form.
4 THE WITNESS: It's been a while since I
5 read this report.
6 BY MR. PAGLIUCA:
7 Q. Sure. Is it fair to say, Detective, that
8 this investigation occurred some 12 years ago,
9 right?
10 A. Yeah. Well, yeah.
11 Q. And is it fair to say that you've
12 conducted quite a few investigations over your
13 career?
14 A. Yes.
15 Q. All right.
16 And it's fair to say that it would be
17 impossible for you to remember all the details of
18 this investigation as you sit here today, correct?
19 A. Correct.
20 Q. And you've been referring to Exhibit 1
21 frequently throughout this deposition, correct?
22 A. Yes.
23 Q. And that's because you don't have any
24 present memory of these details, correct?
25 MS. SCHULTZ: Object to form, foundation.
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1 JOSEPH RECAREY - CONFIDENTIAL
2 THE WITNESS: I have some recollection,
3 but I'm not going to have exact dates and times
4 off the top of my head.
5 BY MR. PAGLIUCA:
6 Q. Sure.
7 A. You know, I spoke to over 33 girls
8 regarding this case. So when you say an initial, it
9 takes me a little while to go through the entire
10 list. But to have specifics, I'm not going to be
11 able to remember the exact specifics of -- of the
12 report.
13 Q. I appreciate that.
14 So we can take our time, but do you
15 recall, did AH ever identify Ms. Maxwell has someone
16 she spoke to?
17 A. I don't recall.
18 Q. You don't recall at all?
19 A. I don't recall that she had mentioned
20 Ms. Maxwell.
21 Q. And if she had, you would have put that in
22 your report, correct?
23 A. I believe so, yes, I would have.
24 Q. All right.
25 And so the absence of alleged victim AH
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Page 190
1 JOSEPH RECAREY - CONFIDENTIAL
2 referring to Ms. Maxwell means that she didn't,
3 right?
4 MS. SCHULTZ: Object to form.
5 THE WITNESS: Say the question one more
6 time.
7 BY MR. PAGLIUCA:
8 Q. When we go through this report, and I've
9 gone through it, if any of the alleged victims had
10 identified Ms. Maxwell as someone that they spoke to
11 at Mr. Epstein's house, you would have listed that
12 in your report, right?
13 MS. SCHULTZ: Object to form.
14 THE WITNESS: I believe I would have, yes.
15 BY MR. PAGLIUCA:
16 Q. Yeah.
17 You tried to be thorough and accurate when
18 you were writing your reports, right?
19 A. Yes.
20 Q. And, certainly, you've indicated on direct
21 examination that the identity of people who were at
22 the house was something that was important to your
23 investigation, correct?
24 A. Yes.
25 Q. And that's why you did trash pulls, right?
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1 JOSEPH RECAREY - CONFIDENTIAL
2 A. Yes.
3 Q. And then you asked various individuals who
4 was there when you went to Mr. Epstein's house,
5 right?
6 A. Correct.
7 Q. And you then, to the best of your ability,
8 recorded those answers, I take it, as to who was
9 there, right?
10 A. Yes.
11 Q. And with regard to AH, she never said
12 anything about Ghislaine Maxwell being at
13 Mr. Epstein's house, did she?
14 MS. SCHULTZ: Object to form and
15 foundation.
16 BY MR. PAGLIUCA:
17 Q. To you?
18 A. I don't believe she did.
19 Q. Okay. And if she did, it's likely that
20 you would have recorded it, correct?
21 A. Correct, and it would be on the -- it
22 would be on the tape.
23 Q. Right.
24 She never claimed, AH, that Ms. Maxwell
25 paid her, right?
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1 JOSEPH RECAREY - CONFIDENTIAL
2 MS. SCHULTZ: Object to form and
3 foundation.
4 THE WITNESS: Correct.
5 BY MR. PAGLIUCA:
6 Q. She never claimed that -- AH never claimed
7 that Ms. Maxwell instructed her about what to wear,
8 correct?
9 MS. SCHULTZ: Object to the form.
10 THE WITNESS: Correct.
11 BY MR. PAGLIUCA:
12 Q. AH never claimed that Ms. Maxwell told her
13 how to act at Mr. Epstein's house, correct?
14 MS. SCHULTZ: Object to form.
15 THE WITNESS: Correct.
16 BY MR. PAGLIUCA:
17 Q. AH never claimed to have met Ghislaine
18 Maxwell anywhere, correct?
19 MS. SCHULTZ: Object to form.
20 THE WITNESS: I don't believe so, no.
21 BY MR. PAGLIUCA:
22 Q. Okay. If we go on to individual alleged
23 victim No. 3, AY, the same question: AY never
24 identified Ms. Maxwell as someone she knew or
25 interacted with in any fashion, correct?
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1 JOSEPH RECAREY - CONFIDENTIAL
2 MS. SCHULTZ: Object to form.
3 THE WITNESS: No.
4 BY MR. PAGLIUCA:
5 Q. No, she did not?
6 A. No, she did not.
7 Q. Okay. The same with individual No. 4,
8 alleged victim FP: Again, FP never claimed to have
9 met with Ms. Maxwell, correct?
10 MS. SCHULTZ: Object to form and
11 foundation.
12 THE WITNESS: I don't believe so, no.
13 BY MR. PAGLIUCA:
14 Q. Okay. And FP never identified Ms. Maxwell
15 as someone being at Mr. Epstein's house, correct?
16 MS. SCHULTZ: Object to form and
17 foundation.
18 BY MR. PAGLIUCA:
19 Q. And if you need to look at your report --
20 A. No, I don't -- I don't believe so. The
21 only people that recalled Ghislaine at the house
22 was --
23 Q. Sjoberg?
24 A. Johanna Sjoberg.
25 Q. Who was over the age of 18, correct?
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Page 194
1 JOSEPH RECAREY - CONFIDENTIAL
2 MS. SCHULTZ: Object to form and
3 foundation.
4 THE WITNESS: And Venero, Christina
5 Venero.
6 BY MR. PAGLIUCA:
7 Q. Who is an adult as well?
8 MS. O'CONNOR: Object to form.
9 THE WITNESS: Yes.
10 BY MR. PAGLIUCA:
11 Q. So out of your entire report, the only two
12 people who ever said anything about Ms. Maxwell were
13 Ms. Sjoberg, who I believe was 23 when you
14 interviewed her?
15 A. Right, but she was --
16 MS. SCHULTZ: Object to form and
17 foundation.
18 THE WITNESS: She was -- she had worked
19 there for quite some time, so you would have to
20 back up, I think, a year or two.
21 BY MR. PAGLIUCA:
22 Q. She was an adult when she worked there?
23 A. Right. She was over the age of 18, right,
24 let's put it that way.
25 Q. And she was not listed by you as a victim
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1 JOSEPH RECAREY - CONFIDENTIAL
2 as part of this case, right?
3 A. Correct, because it was between two
4 consenting adults.
5 Q. Exactly.
6 And so that's Ms. Sjoberg, and then the
7 other individual, I think you said Bolero; is that
8 right?
9 A. Venero, Christina Venero. She's a --
10 Q. Adult masseuse, correct?
11 A. Yes. I remember she had lots of tattoos.
12 Q. Tatts, right.
13 But the 17 individuals that you listed in
14 Exhibit 1, none of those individuals ever said the
15 word -- the words "Ghislaine Maxwell" during the
16 course of this investigation to you, correct?
17 MS. SCHULTZ: Object to form and
18 foundation.
19 THE WITNESS: I don't believe so. It
20 would be on the tapes if they did.
21 BY MR. PAGLIUCA:
22 Q. Well, or it would be in your report,
23 right?
24 MS. SCHULTZ: Object to form and
25 foundation.
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1 JOSEPH RECAREY - CONFIDENTIAL
2 THE WITNESS: Either in the report or on
3 the tapes.
4 BY MR. PAGLIUCA:
5 Q. That's an interesting point, so let's talk
6 about that for a moment.
7 This report, this Palm Beach Police
8 Department incident report, Exhibit 1, is a summary
9 of your investigation, correct?
10 A. Correct.
11 Q. And these recitations of your interviews
12 are abbreviated summaries, correct?
13 A. Correct.
14 Q. And so you're typing into this report
15 parts of it but not every word verbatim into the
16 report, correct?
17 A. Right.
18 Q. And, again, the originals of these tapes
19 are somewhere with the FBI at this point, correct?
20 MS. SCHULTZ: Object to form and
21 foundation.
22 THE WITNESS: Correct. Or at the State
23 Attorney's Office.
24 BY MR. PAGLIUCA:
25 Q. Are you aware of any of these originals
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1 JOSEPH RECAREY - CONFIDENTIAL
2 That would be one. Probably victim JB would be
3 another. I believe there was a victim ML, as well.
4 Q. Let me ask this question: As you sit here
5 today, do you know who the subjects of the four
6 counts that are referenced on the first page of
7 Exhibit 7 are?
8 A. If I went through the entire PC affidavit,
9 I could -- I could tell you who. But I just named
10 three.
11 Q. Okay.
12 A. So, like I said, I can go through it and
13 tell you who exactly those four counts were for.
14 Q. Okay. We are limited to four, though,
15 right?
16 A. Four instances.
17 MS. SCHULTZ: Object to form.
18 BY MR. PAGLIUCA:
19 Q. Right.
20 And then throughout this entire 22-page,
21 Palm Beach Police Department affidavit,
22 Ms. Maxwell's name does not appear in here once,
23 does it?
24 MS. SCHULTZ: Object to form.
25 THE WITNESS: I don't believe so, no.
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1 JOSEPH RECAREY - CONFIDENTIAL
2 A. Correct.
3 Q. And then Mr. Epstein is arrested and ends
4 up pleading guilty and all of that, right?
5 MS. SCHULTZ: Object to form.
6 THE WITNESS: I think there was a
7 non-prosecution agreement prepared between the
8 Feds and some kind of agreement was made. But,
9 yes, he did end up pleading guilty.
10 BY MR. PAGLIUCA:
11 Q. All right.
12 Now, based on the questions that were
13 asked of you in the grand jury, it's fair to say
14 that Ms. Maxwell was not a target of the grand
15 jury's investigation, correct?
16 MS. SCHULTZ: Object to form and
17 foundation.
18 THE WITNESS: Not based on the questions
19 that the state was asking me, no, the state
20 wasn't...
21 BY MR. PAGLIUCA:
22 Q. In fact, it's fair to say that you never
23 said Ms. Maxwell's name in the grand jury, right?
24 MS. SCHULTZ: Object to form and
25 foundation.
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1 JOSEPH RECAREY - CONFIDENTIAL
2 THE WITNESS: No. Based on the questions
3 that the state was asking, no.
4 BY MR. PAGLIUCA:
5 Q. Were you aware of who was being issued
6 subpoenas by the grand jury?
7 A. No. But it wasn't the actual subpoena
8 from the grand jury; it came from the State
9 Attorney's Office.
10 Q. At the direction of the grand jury,
11 though, right?
12 MS. SCHULTZ: Object to form and
13 foundation.
14 THE WITNESS: I don't know. Again, I
15 don't know.
16 BY MR. PAGLIUCA:
17 Q. I would like to talk a little bit about
18 the surveillance that you initiated at Mr. Epstein's
19 house, okay?
20 Can you tell me when the surveillance
21 began?
22 A. It would have started under Detective
23 Pagan and gone through --
24 Q. The entire investigation?
25 A. Pretty much trash pulls. We stopped the
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2 actual physical surveillance sometime during the
3 investigation. But it would have started under
4 Pagan.
5 Q. Okay. Do you recall in what -- well, how
6 was surveillance conducted, if you recall?
7 A. I didn't conduct it personally, no. That
8 would have been under plainclothes unit team. They
9 would have sent out a vehicle and recorded vehicles
10 coming and going and actual physical surveillance.
11 Q. So physical surveillance means eyes on the
12 property, correct?
13 A. Right.
14 Q. And eyes on the property by a police
15 officer, correct?
16 A. Correct.
17 Q. And that police officer would be charged
18 with the obligation of recording the incomings and
19 outgoings of people to the property, correct?
20 A. Correct.
21 Q. Is there a log that's maintained during
22 surveillance?
23 A. I'm not sure who -- if there was a log or
24 not. I know that they set up a vehicle with cameras
25 facing -- facing Epstein's residence.
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2 Q. And so these were video cameras?
3 A. Correct.
4 Q. And so whoever was coming and going,
5 whenever -- an officer saw somebody coming or going,
6 they would videotape that person; is that correct?
7 A. Or they would just leave the video
8 rolling, time lapse.
9 Q. And did you have the opportunity to
10 observe any of that video?
11 A. I did observe a couple, but the person who
12 actually set it up would review it and then submit a
13 supplement to the report.
14 Q. Okay. It's true that none of the video of
15 the surveillance led to the identification of
16 Ghislaine Maxwell as coming or leaving the house
17 during the time of surveillance, correct?
18 MS. SCHULTZ: Object to form and
19 foundation.
20 THE WITNESS: I don't know. I didn't see
21 all of the video, so I can't -- I can't attest
22 to that.
23 BY MR. PAGLIUCA:
24 Q. Okay. Did anybody report to you that
25 Ms. Maxwell was seen coming or going?
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2 MS. SCHULTZ: Object to form, foundation.
3 THE WITNESS: I don't recall.
4 BY MR. PAGLIUCA:
5 Q. If someone had reported to you that
6 Ms. Maxwell was seen coming or going, you would have
7 recorded it in your Palm Beach Police Department
8 incident report, Exhibit No. 1, correct?
9 MS. SCHULTZ: Object to form and
10 foundation.
11 THE WITNESS: I would have told the
12 officer who was conducting the surveillance or
13 reviewing the video to document it in the
14 supplements.
15 BY MR. PAGLIUCA:
16 Q. And there is no documentation in the
17 supplement of Ms. Maxwell either coming or going
18 from Mr. Epstein's house during this time frame,
19 correct?
20 MS. SCHULTZ: Object to the form.
21 THE WITNESS: I don't believe so. I
22 don't -- I don't -- I don't believe so.
23 BY MR. PAGLIUCA:
24 Q. And, again, so we're on the same page,
25 when you say "I don't believe so," I interpret that
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1 JOSEPH RECAREY - CONFIDENTIAL
2 THE WITNESS: Correct.
3 BY MR. PAGLIUCA:
4 Q. And none of these individuals was employed
5 as a massage therapist at the time of their alleged
6 involvement with Mr. Epstein, correct?
7 A. Correct.
8 Q. Each of these individuals, as I recall,
9 claimed to have been paid directly by Mr. Epstein or
10 Ms. Kellen, correct?
11 MS. SCHULTZ: Object to form and
12 foundation.
13 THE WITNESS: Correct.
14 BY MR. PAGLIUCA:
15 Q. Most often, these individuals, these 17
16 individuals, were paid directly by Mr. Epstein,
17 correct?
18 MS. SCHULTZ: Object to form and
19 foundation.
20 THE WITNESS: Mr. Epstein or Sarah Kellen.
21 BY MR. PAGLIUCA:
22 Q. Okay. None of these individuals identify
23 Ms. Maxwell as someone who was paying them money,
24 correct?
25 MS. SCHULTZ: Object to form and
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2 foundation.
3 THE WITNESS: I don't believe so, no.
4 BY MR. PAGLIUCA:
5 Q. And each of these individuals identified
6 receiving cash, correct?
7 MS. SCHULTZ: Object to the form.
8 THE WITNESS: Correct.
9 BY MR. PAGLIUCA:
10 Q. Each of these individuals claimed varying
11 amounts, generally between $200 and up to $1,000,
12 correct?
13 MS. SCHULTZ: Object to form.
14 THE WITNESS: Correct.
15 BY MR. PAGLIUCA:
16 Q. According to each of these individuals,
17 Mr. Epstein, when the massage was over, would either
18 hand them the money -- that happened according to
19 these individuals, right?
20 MS. SCHULTZ: Object to form.
21 THE WITNESS: At times, yes.
22 BY MR. PAGLIUCA:
23 Q. Or Mr. Epstein had laid out the money
24 somewhere and directed them to where to go get it,
25 correct?
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2 A. I don't believe clothing was seized.
3 Q. To your knowledge, did you seize any
4 property belonging to Ghislaine Maxwell from the
5 home?
6 MS. SCHULTZ: Object to form and
7 foundation.
8 THE WITNESS: I'm not sure. Not to my
9 knowledge.
10 BY MS. SCHULTZ:
11 Q. Okay. No one ever came to you and said,
12 Could you please return these items to Ms. Maxwell,
13 correct?
14 MS. SCHULTZ: Object to form.
15 THE WITNESS: No.
16 BY MS. SCHULTZ:
17 Q. All right.
18 You did that with Janush?
19 A. Yes, he had photos and --
20 Q. But nothing like that ever happened with
21 Ms. Maxwell, correct?
22 MS. SCHULTZ: Object to form.
23 THE WITNESS: No.
24 BY MS. SCHULTZ:
25 Q. Ms. Maxwell was not present when you
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2 Q. Any way that you get contacted by a police
3 officer, if they put it into your database, it will
4 come up when you do the CAD search, correct?
5 A. Right.
6 Q. And that's all that came up with regard to
7 Ms. Maxwell, was her name was somewhere in the
8 system. Do you know or not know?
9 MS. SCHULTZ: Object to form and
10 foundation.
11 THE WITNESS: I don't know.
12 MR. PAGLIUCA: Okay.
13 (The referred-to document was marked by
14 the court reporter for Identification as
15 Deposition Exhibit 12.)
16 BY MR. PAGLIUCA:
17 Q. I have handed you what has been marked as
18 Deposition Exhibit 12, which I will represent to you
19 are the Plaintiff in this case, Ms. Giuffre's Rule
20 26 disclosure.
21 I want to just go through very quickly and
22 ask you if you know any of these individuals.
23 So, let's start with No. 1, Virginia
24 Giuffre. Have you ever met Virginia Giuffre?
25 A. No.
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2 Q. Have you ever talked to her?
3 A. I don't recall.
4 Q. Do you know what information that she may
5 have that's referenced below? Conducted is the
6 subject of this action. Do you have any knowledge
7 of that?
8 MS. O'CONNOR: Object to form.
9 THE WITNESS: No.
10 BY MR. PAGLIUCA:
11 Q. Number 2, Ghislaine Maxwell, I'm going to
12 come back to her.
13 Number 3, Juan Alessi, you did interview
14 Mr. Alessi, correct?
15 A. Yes.
16 Q. I have seen a transcript of that
17 interview, and I have seen Exhibit 2, which is a
18 transcript of the interview with Ms. . I want
19 to ask you a couple of questions about the
20 transcription process.
21 As I understand your testimony previously,
22 the electronic recordings are sent somewhere, you
23 don't know where, for transcription; is that right?
24 MS. SCHULTZ: Object to form.
25 THE WITNESS: I didn't request a
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2 different investigators Mr. Black uses in a
3 particular calendar year, do you?
4 MS. SCHULTZ: Object to form.
5 THE WITNESS: No.
6 BY MR. PAGLIUCA:
7 Q. And so you don't know whether Mr. Black's
8 association with this law firm was in connection
9 with Mr. Epstein's case or some other case, do you?
10 MS. SCHULTZ: Object to form.
11 THE WITNESS: I worked this case,
12 nothing -- nothing but this case for an entire
13 year. This was my only case for a year.
14 BY MR. PAGLIUCA:
15 Q. Okay. That's it?
16 A. If it walks like a duck.
17 MS. SCHULTZ: Objection.
18 BY MR. PAGLIUCA:
19 Q. Okay. So we're finished with Dershowitz.
20 Keep on going.
21 A. Number 28, obviously, .
22 Q. Okay. And you've talked about her?
23 A. Right.
24 Q. And, again, she never discussed Ghislaine
25 Maxwell with you, correct?
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2 Q. Right. So you're 75. So I want you -- I
3 want to take a moment and read what's under 75:
4 "Detective Recarey was the chief investigator of the
5 crimes committed at Jeffrey Epstein's Palm Beach
6 mansion." Is that true?
7 MS. SCHULTZ: Object to form.
8 THE WITNESS: Yes.
9 BY MR. PAGLIUCA:
10 Q. "And has information about Ghislaine
11 Maxwell and Jeffrey Epstein's sexual trafficking
12 conduct and interaction with underaged minors."
13 Tell me everything that you believe you
14 know about Ghislaine Maxwell's sexual trafficking
15 conduct.
16 MS. SCHULTZ: Object to form.
17 THE WITNESS: I don't.
18 BY MR. PAGLIUCA:
19 Q. So that's inaccurate, then? I mean, you
20 have no knowledge about Ghislaine Maxwell sexually
21 trafficking anybody, do you?
22 MS. SCHULTZ: Object to form.
23 THE WITNESS: Not with -- not with the
24 girls that I spoke with, no.
25
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2 BY MR. PAGLIUCA:
3 Q. But that's your investigation, right?
4 A. Right.
5 Q. Okay.
6 A. Right.
7 Let's see. Seventy-six.
8 Q. Okay. And you've talked about her.
9 Whatever happened to her, do you know?
10 MS. SCHULTZ: Object to form.
11 BY MR. PAGLIUCA:
12 Q. Haley Robson?
13 A. No.
14 Q. She was never charged, as I understand it,
15 correct?
16 A. Correct.
17 Q. And after you spoke to her in connection
18 with your investigation, did you ever speak to her
19 again?
20 A. No.
21 Q. Okay.
22 A. David Rogers, 77.
23 Q. And you know him because he was identified
24 as one of the pilots for Mr. Epstein, right?
25 A. Right.
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1 JOSEPH RECAREY - CONFIDENTIAL
2 in your mind, right? Correct?
3 MS. SCHULTZ: Object to the form.
4 THE WITNESS: Yes.
5 BY MR. PAGLIUCA:
6 Q. And you're a peace officer, obligated to
7 arrest when a felony is committed in your presence,
8 correct?
9 A. Correct.
10 Q. And the possession of child pornography is
11 a felony, correct?
12 A. Correct.
13 Q. And had you seen any child pornography in
14 Mr. Epstein's house when you were there installing
15 these cameras, you would have done something about
16 it, correct?
17 MS. SCHULTZ: Object for form.
18 THE WITNESS: Right.
19 BY MR. PAGLIUCA:
20 Q. You wouldn't have just walked out and
21 said, Nice pics, have a nice day, correct?
22 A. Correct.
23 Q. So is it fair to say the entire time you
24 were in Epstein's house, whether it's 2002, 2003,
25 you did not observe any child pornography, right?
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2 MS. SCHULTZ: Object to the form.
3 THE WITNESS: Not in the areas I was in.
4 BY MR. PAGLIUCA:
5 Q. You don't recall seeing any pictures of
6 naked women, do you?
7 MS. SCHULTZ: Object to form.
8 THE WITNESS: Again, I was only confined
9 to where that desk was. That's where I set up
10 the camera, and then after it was set up, I
11 left.
12 BY MR. PAGLIUCA:
13 Q. Okay. But, again, all I'm asking you is
14 wherever you were, you didn't see any pictures of
15 naked women?
16 A. Right. No, I didn't see any.
17 Q. And at the time you recall that he had
18 these surveillance cameras already installed; is
19 that true? Other cameras, the clock cameras?
20 MS. SCHULTZ: Object to form.
21 THE WITNESS: I'm not sure if he had the
22 cameras installed or not. I can't recall.
23 BY MR. PAGLIUCA:
24 Q. Why would he need your cameras if he
25 already had cameras?
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2 None of these alleged victims claimed to
3 have ever traveled with Mr. Epstein, correct?
4 MS. SCHULTZ: Object to form.
5 THE WITNESS: No.
6 BY MR. PAGLIUCA:
7 Q. No, they did not? They did not travel
8 with Mr. Epstein, right?
9 MS. SCHULTZ: Object to form.
10 THE WITNESS: I don't believe so, no.
11 BY MR. PAGLIUCA:
12 Q. None of them reported that to you?
13 A. Not reported, correct.
14 Q. None of them reported to you that they
15 ever spent the night with Mr. Epstein, did they?
16 MS. SCHULTZ: Object to form.
17 THE WITNESS: I don't believe so.
18 BY MR. PAGLIUCA:
19 Q. None of them ever reported being
20 trafficked by Mr. Epstein to other men, correct?
21 MS. SCHULTZ: Object to form, foundation.
22 THE WITNESS: I don't believe so.
23 BY MR. PAGLIUCA:
24 Q. The only other men that any of these
25 alleged victims -- the only man that any of these
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1 JOSEPH RECAREY - CONFIDENTIAL
2 alleged victims ever claimed to have any contact
3 with that was sexual in nature was Mr. Epstein,
4 correct?
5 MS. SCHULTZ: Object to form and
6 foundation.
7 THE WITNESS: Yes.
8 BY MR. PAGLIUCA:
9 Q. Okay. None of these alleged victims ever
10 claimed to have been sent to another location to
11 have sex with another man, correct?
12 MS. SCHULTZ: Object to form and
13 foundation.
14 THE WITNESS: I don't believe so.
15 BY MR. PAGLIUCA:
16 Q. Meaning my statement is correct; is that
17 right?
18 MS. SCHULTZ: Object to form.
19 BY MR. PAGLIUCA:
20 Q. I'm just trying to --
21 A. Meaning I don't believe they've ever said
22 that. I don't recall any of them ever saying...
23 Q. Had they claimed that they were sent
24 somewhere else to have sex with another man, you
25 would have followed up on that, correct?
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2 MS. SCHULTZ: Object to form.
3 THE WITNESS: Correct.
4 BY MR. PAGLIUCA:
5 Q. And none of them ever claimed to have been
6 sent to another location to give another man a
7 massage, correct?
8 MS. SCHULTZ: Object to form.
9 THE WITNESS: No, not the victims.
10 BY MR. PAGLIUCA:
11 Q. Right. That's who I'm talking about.
12 A. I believe did.
13 Q. Who is an adult, right?
14 MS. SCHULTZ: Object to form.
15 THE WITNESS: Right.
16 BY MR. PAGLIUCA:
17 Q. We covered this, I believe: None of them
18 ever was on Mr. Epstein's airplane, correct?
19 MS. SCHULTZ: Object to form.
20 THE WITNESS: I believe one of the victims
21 were, but not to a private island. I think
22 they went -- they didn't go to a private
23 island; they went to some other trip.
24 BY MR. PAGLIUCA:
25 Q. I think maybe you're referring to AH, who
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2 went to New York but on a commercial flight. Does
3 that jog your memory?
4 MS. SCHULTZ: Object to form.
5 THE WITNESS: No.
6 BY MR. PAGLIUCA:
7 Q. Okay. Do you recall who it is?
8 A. It would have been FP.
9 Q. Okay. Was on Mr. Epstein's airplane?
10 MS. SCHULTZ: Object to form.
11 THE WITNESS: I believe so.
12 BY MR. PAGLIUCA:
13 Q. Would that be reflected in Exhibit 1?
14 MS. SCHULTZ: Object to form.
15 THE WITNESS: But she flew alone. It
16 wasn't like Epstein was there. She went
17 someplace else, not to his private island,
18 nothing to do with Epstein. It was something
19 she wanted to do. And I think she flew on his
20 plane, but it was, like, her by herself.
21 BY MR. PAGLIUCA:
22 Q. Alone.
23 A. Right.
24 Q. With a pilot?
25 A. Right.
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2 MS. SCHULTZ: Object to form.
3 BY MR. PAGLIUCA:
4 Q. None of the alleged victims in your
5 investigation claimed to have gone to the Caribbean
6 island of Little St. James, correct?
7 MS. SCHULTZ: Object to form.
8 THE WITNESS: No.
9 BY MR. PAGLIUCA:
10 Q. "No" meaning they never went there,
11 correct?
12 MS. SCHULTZ: Object to form.
13 THE WITNESS: Not that I'm aware of.
14 BY MR. PAGLIUCA:
15 Q. None of the alleged victims ever went to
16 Mr. Epstein's New York residence, to your knowledge,
17 correct?
18 MS. SCHULTZ: Object to form.
19 THE WITNESS: Not that I'm aware of.
20 BY MR. PAGLIUCA:
21 Q. None of them ever reported that to you?
22 MS. SCHULTZ: Object to form.
23 THE WITNESS: No.
24 BY MR. PAGLIUCA:
25 Q. Okay. And none of them ever claimed to
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2 have been outside of the country with Mr. Epstein,
3 ever, correct?
4 MS. SCHULTZ: Object to the form.
5 THE WITNESS: Not that I'm aware of.
6 MR. PAGLIUCA: Can we go off for a second?
7 Time check.
8 THE VIDEOGRAPHER: Off the record at 4:13.
9 (Thereupon, a recess was taken, after
10 which the following proceedings were held:)
11 THE VIDEOGRAPHER: On the record at 4:14.
12 BY MR. PAGLIUCA:
13 Q. Can you take a look at Exhibit 4, please?
14 A. Which one is 4?
15 Q. Four is the True Copy. That's what it
16 says at the top. Exhibit 4. Six pages.
17 A. Yes.
18 Q. Do you have that?
19 A. Yes, sir.
20 Q. There's yellow highlighting on the exhibit
21 that's in front of you.
22 Do you know how that got there?
23 A. No.
24 Q. And there's a -- there are numbers, item
25 numbers. Do you see that in the left column?
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Page 365
2
3 CERTIFICATE OF OATH
4 STATE OF FLORIDA )
5 COUNTY OF MIAMI-DADE )
6
7 I, the undersigned authority, certify
8 that JOSEPH RECAREY personally appeared before me
9 and was duly sworn.
10 WITNESS my hand and official seal this
11 24th day of June, 2016.
12
13
KELLI ANN WILLIS, RPR, CRR
14 Notary Public, State of Florida
My Commission No. EE911443
15 Expires: 2/16/16
16 + + + + + + + + + + + + + + + + + +
17
18
19
20
21
22
23
24
25
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2
3 C E R T I F I C A T E
4 STATE OF FLORIDA )
: ss
5 COUNTY OF MIAMI-DADE )
6 I, KELLI ANN WILLIS, a Registered
7 Professional, Certified Realtime Reporter and
8 Notary Public within and for The State of
9 Florida, do hereby certify:
10 That JOSEPH RECAREY, the witness whose
11 deposition is hereinbefore set forth was duly
12 sworn by me and that such Deposition is a true
13 record of the testimony given by the witness.
14 I further certify that I am not related
15 to any of the parties to this action by blood
16 or marriage, and that I am in no way interested
17 in the outcome of this matter.
18 IN WITNESS WHEREOF, I have hereunto set
19 my hand this 24th day of June, 2016.
20
21 __________________________
KELLI ANN WILLIS, RPR, CRR
22
23
24
25
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EXHIBIT HH
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GM_01197
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GM_01198
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GM_01200
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GM_01201
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EXHIBIT II
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EXHIBIT JJ
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GIUFFRE005310
CONFIDENTIAL
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GIUFFRE005311
CONFIDENTIAL
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GIUFFRE005312
CONFIDENTIAL
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GIUFFRE005313
CONFIDENTIAL
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GIUFFRE005314
CONFIDENTIAL
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EXHIBIT KK
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When the pain relief kicked in, everything and everyone dwindled compliment the sights mother nature that appealed to us. I didn't feel as if
away until I felt like Alice in Wonderland who just swallowed the I owed this stranger anything but what was expected of me by Jeffrey and
shrinking tablet and everyone standing around me seemed to move so I could be polite, f just couldn't be myself.
quick, speak so loud and hover above me. When I awoke from my We got back to the main villa to see what time dinner would be se1ved
induced state, I was alone in a different room. Not knowing at all what so we could have time to unpack and clean up beforehand. We both met
went on but feeling a little better, I called in the nurse who looked at six pm for dinner on the outside veranda. He sat at the head of the
through my charts and checked my vital signs. Then told me the doctor table and I sat next to him, politely folding my napkin to put in my lap.
would be in shortly to inform me of the conclusion to my illness. The first time Jeffrey and Ghislane had seen me cut meat and eat with a
He was a tall man with dark hair, and a hardened look about him fork and knife they were so appalled, making fun of my unsophisticated
obviously from his job and constantly seeing the worst horror stories man habits. Ghislane took the fork and knife in her hands and proceeded to
could think of, he just bluntly told me I had miscarried in early stages of show me how to politely cut my food and eat. Now that my mannerisms
pregnancy. I should be fine to go home as soon as my course of had improved they wouldn't have to be worried about my etiquette when
intravenous antibiotics was complete. The news sunk in fast and hit a someone important was around anyone. We both drank the red wine
deep nerve. I waited for the doctor to close the curtain before I let out any supplied on the table and it seemed to wam1 me up on the breezy night
emotion and cried for my disastrous lifestyle that was dragging me into a By the time dinner was served and another red wine bottle later, he
world that I wanted to break out of. This reoccurring cycle of believing I seemed to get funnier. I made fun of his tousled hair and he poked at me
needed men like Jeffrey to succeed in my life was draining the last bits of for my skinny legs, calling me a wanna be- anorexic. When dessert was
sensitivity left in my heart. I was picked up by Jeffrey himself who took brought out, he asked if he could receive one of the delightful massages
the doctor alone to the side of the busy hallway to have a private he has been hearing about from Jeffrey. I gulped more red wine down and
conversation about something. Jeffrey wasn't comforting at all, instead he sweetly complied with his offer, dreading the moment I'd have to see his
sent me back home to rest for a couple weeks, and I only fell deeper into naked body, let alone touch it. I asked the housekeeper Kathy that had
a depression, using all forms of self medication to treat my sorrows. been serving us that night to please have someone set up a massage bed
Two weeks later, as if Jeffrey was trying to lighten my spirits, he told in one of the cabana's. 1 went to my room to down a few Xanax, telling
me I would be going to his island to meet a new client He is a Harvard him I wanted to freshen up after dinner but to meet me in his cabana in
Professor, named Stephen . I would be spending two days with twenty minutes or so. I was ready to go as I had said, twenty minutes
him showing him around the island, dining with him, and treating him to later, with the effects of the tablets mixed with the red wine, and I would
a massage whenever he wanted. Without Jeffrey even verbalizing the be free not to feel anything. He was still dressed when I got in the cabana,
need to have sex with him, he told me to keep him happy like I had my obviously not accustomed to this and a lot shyer than what I had been
first client. 1 packed my suitcase with island apparel, and kissed T.J good used to, I told him he'd need to undress and lie face down on the table,
bye, who had at least offered me a warm embrace upon the news of my putting a towel to cover his bare bottom to prevent him feeling
miscarriage but none other than that knowing it wasn't his. embarrassed during the massage. I gave the massage my earnest as 1
Stephen was a quirky little man with white hair and a mad scientist look always had, and quickly got through having intercourse with him. Not
about him. We arrived separately and I greeted him when one of the wanting to make any foreplay or anything extravagant out of it, I let him
housekeepers picked him up from the airport and arrived by boat, instead think that's as good as it got, and by the smile on his face, I thought I bad
of helicopter as Jeffrey and Ghislane often arrive on. We made our done enough.
acquaintances and he looked as if he was tripping over himself with The next day I took him down to the beach for a real massage under a
words, obviously delighted with his company and location for the tiki-hut on the waters edge. ft was one of Jeffrey's favorite places to have
weekend. I showed him around as Jeffrey had asked and took him on an a massage, as he droned out to the sound of the waves and my gentle
adventurous quad bike ride around the small curvy paths, leading the way therapeutic strokes. Afterwards we had lunch back at the main villa and
and letting loose my hair, doing something that gave me a natural high went back down to the beach to swim out to the water trampoline about
instead of the prescription one. The sights alone were breathtaking from one hundred meters off the dock. He didn't do any bouncing around or
the mountainous peaks of the untouched parts of the island, we sat at a anything like that. It was just a good base point for a rest spot after a long
cliff and just sat there, not saying a word to each other besides to
59 60
EXHIBIT LL
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EXHIBIT MM
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VIRGINIA L. GIUFFRE,
Plaintiff.
-vs-
GHISLAINE MAXWELL,
Defendant.
______________________________________/
1 APPEARANCES:
2 On Behalf of the Plaintiff:
3 BOEIS, SCHILLER & FLEXNER, P.A.
401 East Las Olas Boulevard, Suite 1200
4 Fort Lauderdale, Florida 33301
[email protected]
5 BY: SIGRID MCCAWLEY, ESQUIRE
6 On Behalf of the Plaintiff and Victims Refuse
Silence, Inc.:
7
FARMER JAFFE WEISSING EDWARDS FISTO LEHRMAN
8 425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
9 (954) 524-2820
[email protected]
10 BY: BRADLEY J. EDWARDS, ESQUIRE
11 On Behalf of the Defendant:
12 HADDON, MORGAN & FOREMAN
150 East 10th Avenue
13 Denver, Colorado 80203
(303) 831-7364
14 [email protected]
BY: JEFFREY PAGLIUCA, ESQUIRE
15
Also Present:
16
Ryan Kick, Videographer
17
18
19
20
21
22
23
24
25
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Page 3
1 INDEX OF PROCEEDINGS
2 VIDEO DEPOSITION OF BRITTANY HENDERSON PAGE
3 Direct Examination by Mr. Pagliuca 4
4 Certificate of Oath 73
Certificate of Reporter 74
5 Witness Letter 75
Errata Sheet 76
6
7 DEFENDANT'S EXHIBITS
8 NUMBER DESCRIPTION PAGE
9 Exhibit 1 Amended NOD 14
10 Exhibit 2 Motion to Quash Composite 20
11 Exhibit 3 Bates Stamped 01 - 064 31
12 Exhibit 4 Bates Stamped 064 - 091 32
13 Exhibit 5 Articles of Incorporation 36
14 Exhibit 6 Bank Statements 41
15 Exhibit 7 2015 Annual Report 62
16 Exhibit 8 2016 Annual Report 62
17
18 (Exhibits Retained by the Court Reporter)
19
20
21
22
23
24
25
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Page 17
1 she has continued to try and promote Victims Refuse
2 Silence at every possible chance she gets with -- the
3 story she told me was that someone had come to her
4 door, knocked on the door, selling something or talking
5 about something totally different, and she explained
6 what our mission was and tried to get them to, then, go
7 and spread the word for victims of human trafficking,
8 as well.
9 Q And this would be in Australia this
10 conversation occurred?
11 A Correct.
12 Q Okay. To your knowledge, is VRS incorporated
13 in any fashion in the country of Australia?
14 A It is not.
15 Q To your knowledge, does VRS have any website
16 presence in Australia?
17 A I believe that the internet works everywhere,
18 so I would say yes, because, if you Google Victims
19 Refuse Silence, we do have a website. So I would
20 imagine that that's something that would come up in
21 Australia.
22 Q Okay. Other than the somebody knocking at
23 her door, that conversation, did she report to you
24 anything else that she has done on behalf of Victims
25 Refuse Silence in the last year, let's say?
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Page 18
1 MR. EDWARDS: Objection --
2 THE WITNESS: During this telephone
3 conversation --
4 BY MR. PAGLIUCA:
5 Q Yes.
6 A -- or in general?
7 Q During this telephone conversation?
8 A She did explain that, when she goes to her
9 kids' schools and when she is out, she tries to promote
10 the organization, as well, and just talk to people, and
11 general awareness and understanding to raise -- for
12 issues of human trafficking, yes.
13 Q And did she report anything else to you
14 during this phone conversation?
15 A During this particular conversation?
16 Q Yes.
17 A No.
18 Q Okay. Then, you indicated that you reviewed
19 your file for all the paperwork, and we'll talk about
20 the documents produced in this case in a moment.
21 Can you tell me, other than what has been
22 produced as part of the response to subpoena issued to
23 VRS, what other documents are in the file that you
24 reviewed?
25 A I have saved every piece of mail that has
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1 "publication," would be the Facebook page; correct?
2 A In addition to the website, yes.
3 Q Okay. Number 11, documents relating to all
4 appearances. As I understand it, there are no
5 documents that exist that comply with this request;
6 correct?
7 A Correct; to my knowledge.
8 Q Do you know, has anybody on behalf of VRS
9 made a public appearance on behalf of VRS?
10 A I believe that there was a scheduled
11 appearance, yes, one.
12 Q And when was that?
13 A I honestly don't know when that took place.
14 I would imagine in the beginning of 2015.
15 Q And do you know who was scheduled to appear
16 in the beginning of 2015?
17 A Ms. Giuffre.
18 Q And do you know where she was scheduled to
19 appear?
20 A I believe in New York with ABC.
21 Q And that would have also been with Mr.
22 Edwards and Ms. McCawley; is that correct?
23 A I believe so, yes.
24 Q And in fact, she did go to ABC and give a
25 taped interview, correct?
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1 MS. MCCAWLEY: Objection.
2 THE WITNESS: It's my understanding, yes.
3 BY MR. PAGLIUCA:
4 Q Okay. Is it your understanding that that was
5 on behalf of VRS?
6 A I do not believe her appearance there was
7 made on behalf of VRS, but I do believe that -- I know
8 that she wanted to promote the charity, so that we
9 could start helping people and that she could start
10 getting her mission out to the public.
11 Q Okay. Number 12, all contacts received by
12 VRS through its website, or otherwise, to schedule -- I
13 think it should say "an event," and "and event."
14 There are none of those, as I understand it?
15 A No, that is not correct. We produced a --
16 yes, we did produce something to you. I'm not sure
17 what the Bates Stamp number is, but it was a contact
18 received by another victim of sexual assault who had
19 reached out to the organization.
20 Q An email, I think it's in December of 2015,
21 maybe; is that what you're referring to?
22 A I believe -- I'm not sure of the date. I
23 guess.
24 Q We'll look at it. And that would be the only
25 contact received by VRS; is that correct?
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1 C E R T I F I C A T E OF OATH
2
3 STATE OF FLORIDA
4 COUNTY OF BROWARD
5
6
7 I, Rinat Katz, Reporter, Notary Public, State
8 of Florida, certify that BRITTANY HENDERSON
9 personally appeared before me on the 8th day of
10 September, 2016, and was duly sworn.
11
12 Signed this 22nd day of September, 2016.
13
14
15 _________________________________
Rinat Katz, Reporter
16 Notary Public, State of Florida
Commission No.: FF4576
17 Commission Expires: 04-03-2017
18
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20
21
22
23
24
25
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Page 73
1 CERTIFICATE OF REPORTER
2
3 STATE OF FLORIDA
4 COUNTY OF BROWARD
5
6 I, Rinat Katz, Reporter, certify that I was
7 authorized to and did report the deposition of
8 BRITTANY HENDERSON, that a review of the
9 transcript was requested; and that the transcript
10 is a true and correct record of my stenographic
11 notes.
12 I further certify that I am not a relative,
13 employee, attorney, or counsel of any of the
14 parties, nor am I a relative or employee of any of
15 the parties' attorneys or counsel connected with
16 the action, nor am I financially interested in the
17 action.
18 Dated this 22nd day of September, 2016.
19
20
21 ____________________________________
Rinat Katz, Reporter
22
23
24
25