Virginia Giuffre Deposition
Virginia Giuffre Deposition
EXHIBIT D
Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 2 of 89
GIUFFRE
VS.
MAXWELL
Deposition
VIRGINIA GIUFFRE
05/03/2016
_______________________________________________________________________
Page 2 Page 4
1 APPEARANCES: (Continued) 1 INDEX OF EXHIBITS
2 HADDON, MORGAN AND FORMAN, P.C. 2
By Laura A. Menninger, Esq. INITIAL
3 Jeffrey S. Pagliuca, Esq. 3 DESCRIPTION REFERENCE
150 East 10th Avenue
4 Denver, CO 80203 4
Phone: 303.831.7364 Exhibit 1 Complaint and Demand for Jury 17
5 [email protected] 5 Trial re Jane Doe No. 102 v.
[email protected] Jeffrey Epstein
6 Appearing on behalf of the 6
Defendant Exhibit 2 Jane Doe #3 and Jane Doe #4's 21
7 7 Motion Pursuant to Rule 21 for
Also Present: Joinder in Action
8 Brenda Rodriguez, Paralegal 8
Nicholas F. Borgia, CLVS Videographer Exhibit 3 Declaration of Virginia L. 23
9 9 Giuffre re Jane Doe #1 and Jane
Doe #2 vs. United States of
10 10 America
11 11 Exhibit 4 Declaration of Jane Doe 3 re 31
Jane Doe #1 and Jane Doe #2 vs.
12 12 United States of America
13 13 Exhibit 5 Declaration of Virginia Giuffre 33
re Bradley J. Edwar
14 14 ssell vs.
15 15
Exhibit 6 FBI documentation, date of entry 36
16 16 7/5/13
17 17 Exhibit 7 Document titled Telecon, 39
Participants Jack Scarola, Brad
18 18 Edwards, Virginia Roberts. Re
Edwards adv. Epstein, 4/7/11,
19 19 (23 pages of transcription)
20 20 Exhibit 8 The Billionaire's Playboy Club, 41
By Virginia Roberts
21 21
Exhibit 9 Plaintiff's Response and 44
22 22 Objections to Defendant's First
Set of Discovery Requests to
23 23 Plaintiff re Giuffre v. Maxwell
24 24
25 25
Page 6 Page 8
1 1 I just wanted to make sure that we're clear, and I
INITIAL
2 DESCRIPTION REFERENCE 2 think that we are, that this deposition in total will
3 3 be treated as confidential until such time as we are
Exhibit 21 Compilation of e-mails between 284
4 Sharon Churcher and Virginia 4 able to review and de-designate.
Giuffre
5 5 MS. MENNINGER: Yes.
Exhibit 22 Compilation of e-mails among 287
6 Sharon Churcher, Michael Thomas, 6 MR. EDWARDS: Okay.
Virginia Giuffre and others
7 7 EXAMINATION
Exhibit 23 Compilation of May 2011 e-mails 288
8 among Sharon Churcher, Virginia 8 BY MS. MENNINGER:
Giuffre, Paulo Silva and others
9 9 Q Good morning, Ms. Giuffre.
Exhibit 24 Compilation of June 2011 e-mails 289
10 between Virginia Giuffre and 10 A Good morning, Laura.
Sharon Churcher
11 11 Q Can you please state your full name?
Exhibit 26 PR Hub Statement on Behalf of 300
12 Ghislaine Maxwell article 12 A Virginia Lee Giuffre.
13 Exhibit 27 1/2/15 e-mail from to 309 13 Q And where do you live right now,
To Whom It May Conce
14 14 Ms. Giuffre?
15 15 A
16 16
17 17 Q All right. And who lives with you there?
18 18 A My son, my other son, my daughter, my
19 19 husband and my in-laws.
20 20 Q And when did you return to the U.S. for
21 21 this visit?
22 22 A I believe it was around Thursday, the
23 23 29th, I think.
24 24 Q Okay. And who traveled with you?
25 25 A Myself.
Page 14 Page 16
1 question how many times have you had sex with 1 you don't.
2 do you know what that question means? 2 Do you have any reason to believe that any
3 A I believe so. 3 of your previous sworn statements that you have made
4 Q All right. And what is the answer to that 4 are not true?
5 question? 5 A No.
6 A I believe I was with once. 6 MR. EDWARDS: I just object and ask that
7 Q Okay. I would like to ask you about your 7 if we're going to ask the witness questions about any
8 prior sworn statement. 8 of her statements in whole or in part that the
9 You understand you're under oath today, 9 witness be allowed to see the statement, review the
10 correct? 10 statement and then answer your questions.
11 A Yes. 11 Q (BY MS. MENNINGER) You may answer the
12 Q All right. You've previously made 12 question.
13 statements under oath, correct? 13 A Can you reask the question? I'm sorry.
14 A Yes. 14 Q Do you have any reason to believe that any
15 Q And you've previously authorized pleadings 15 of your prior sworn statements are untrue?
16 to be filed on your behalf, correct? 16 A I have no reason to believe that my prior
17 A Yes. 17 statements are untrue.
18 Q By various attorneys, right? 18 Q Has anyone told you to say something that
19 A Yes. 19 was not true in connection with this case?
20 Q All right. You have included in your 20 A No, ma'am.
21 sworn statement allegations about my client, 21 Q All right. I'd like to start with a
22 Ghislaine Maxwell, correct? 22 lawsuit that you filed under the caption Jane Doe
23 A Yes. 23 versus Jeffrey Epstein.
24 Q And did you review any of those prior 24 Do you recall that lawsuit?
25 sworn statements before appearing here today? 25 A I believe so.
Page 18 Page 20
1 witness questions about the document. I did not ask 1 A No, she wasn't. I'm sorry for
2 you any questions about the document. 2 interrupting you. But no, she was not sued at this
3 Q (BY MS. MENNINGER) Ms. Giuffre, could you 3 time, no.
4 please take a look at what we have marked as 4 Q And why not?
5 Defendant's Exhibit 1. 5 MR. EDWARDS: I'd object and ask the
6 Do you recognize that document, 6 witness not answer that question because that would
7 Ms. Giuffre? 7 be privileged, attorney-client privileged,
8 A I believe so. Yes. Yes, I do. 8 information that was between Ms. Giuffre and the
9 Q And do you see that the counsel on the 9 Podhurst Orseck firm at that time.
10 last page -- I'm sorry, not the last page, but the 10 So I'm instructing you not to answer.
11 third from the last page are Mr. Josefsberg and 11 Q (BY MS. MENNINGER) All right.
12 Ms. Ezell from Podhurst Orseck? 12 Ms. Giuffre, did you make a decision yourself whether
13 A Yes. 13 or not to sue Ms. Maxwell as a part of this lawsuit
14 Q Were those your lawyers? 14 against -- Jane Doe 102 versus Jeffrey Epstein?
15 A Yes, they were. 15 A I think I've been advised not to answer
16 Q And did you authorize them to file Jane 16 that question.
17 Doe 102 versus Epstein on your behalf? 17 Q This is a different question.
18 A Yes, I did. 18 A Oh, okay.
19 Q And is that this complaint that's been 19 Q So your counsel can assert a privilege,
20 marked as Defendant's Exhibit 1? 20 but that question did not call for privileged
21 A I believe so. 21 information.
22 Q In that document, if I could ask you to 22 MR. EDWARDS: I --
23 turn to page -- well, I'll turn to page 9 and 23 Q (BY MS. MENNINGER) I'm asking about what
24 paragraph 23. 24 -- what you decided to do. Whether you decided to
25 A Would you like me to read it? 25 sue Ms. Maxwell or not at the time Jane Doe 102
Page 22 Page 24
1 A I believe this is when I was hoping to 1 Q What do you understand this document to
2 join the CVRA case. 2 be?
3 Q All right. And do you know when this 3 A It's a rough background of the years that
4 document was filed? 4 I was abused by Ghislaine and Jeffrey.
5 And actually, just to be clear, about 5 Q All right. And this is something I
6 halfway there's actually a second document that was 6 believe that you on page 15 signed; is that true?
7 filed. So this is a composite exhibit. Let me be 7 A Just let me have a look.
8 very clear. 8 Q Sure.
9 So after page 14 -- I'm sorry, 13, there's 9 A I think I'm actually missing page 15. Oh,
10 a second document that is styled Jane Doe #3 and Jane 10 here we go.
11 Doe #4's Corrected Motion Pursuant to Rule 21 for 11 Q Sorry. I'm looking at the numbers on the
12 Joinder In Action. 12 top right. I apologize. I believe there was some
13 Do you see that? 13 cover page or something that was excluded.
14 A Did you say page 14? 14 MR. EDWARDS: And just for the record, I'm
15 Q It is on the 14th page of this document. 15 going to object to the relevance of this document.
16 Do you see that? 16 I'm going to allow the witness to answer the
17 A I do. 17 question, but I want my objection on the record.
18 Q And so this composite Exhibit 2 has both a 18 MS. MENNINGER: Okay. Simple objection,
19 motion and a corrected motion. 19 relevance.
20 Do you see that? 20 A Are we talking about this page?
21 A Yes. 21 Q (BY MS. MENNINGER) Yes, the one with the
22 Q And were both of those pleadings 22 black box, yes. Do you believe that to have
23 authorized by you to be filed? 23 contained your signature?
24 A Yes. 24 A Yes.
25 Q In other words, you wanted to join the 25 Q All right. And you executed that on
Page 26 Page 28
1 Q And you're talking about line 4? 1 MR. EDWARDS: Objection. Asked and
2 A Line 4. 2 answered.
3 Q Paragraph 4 or line 4? 3 Q (BY MS. MENNINGER) You may answer.
4 A Oh, sorry. Number 4, the paragraph 4 MR. EDWARDS: Answer again.
5 number 4. 5 A Again, I wouldn't say it's untrue. Untrue
6 Q Okay. And what part of paragraph 4 do you 6 would mean that I would have lied. And I didn't lie.
7 now believe to be untrue? 7 This was my best knowledge at the time. And I did my
8 A In approximately -- 8 very best to try to pinpoint time periods going back
9 MR. EDWARDS: Object to the form. 9 such a long time ago.
10 You can answer. 10 It wasn't until I found the facts that I
11 A In approximately 1999 when I was 15 years 11 worked at Mar-a-Lago in 2000 that I was able to
12 old I met Ghislaine Maxwell. 12 figure that out.
13 Q (BY MS. MENNINGER) Okay. 13 Q (BY MS. MENNINGER) And approximately when
14 A I now know that it was 2000, that I was 16 14 did you learn those facts about the dates you worked
15 years old when I met Ghislaine Maxwell. 15 at Mar-a-Lago?
16 Q So when you signed this document under 16 A I would say it was mid-2015.
17 penalty of perjury stating that it was true, you no 17 Q Mid-2015 is the first time you became
18 longer believe that to be true, correct? 18 aware of the dates --
19 A It was an honest mistake. We had no idea 19 A I don't know the exact --
20 how to pinpoint without any kind of records or dates 20 Q If you could just let me finish.
21 or anything like that. I was just going back 21 A I'm sorry.
22 chronologically through time. And that's the best 22 Q That's all right. Approximately mid-2015
23 time that I thought it was. And now I know the 23 when you learned the true dates that you had worked
24 facts, so it's good to know. 24 at Mar-a-Lago?
25 Q So you now believe that a document you 25 A That's correct. Sorry.
Page 30 Page 32
1 at records in the middle of 2015 regardless of who 1 Q (BY MS. MENNINGER) Okay. And again, if
2 showed them to you? 2 you look to the last page of the document,
3 MR. EDWARDS: Objection. And to the 3 paragraph 67 --
4 extent that they were showed to you or shared by any 4 A The last page?
5 of your lawyers, you're instructed not to answer the 5 Q Yes, the very last.
6 question. It invades the attorney-client privilege. 6 A 67, yes.
7 Q (BY MS. MENNINGER) Did you look at 7 Q All right. It says in paragraph 67: I
8 Mar-a-Lago records in the middle of 2015 yourself? 8 declare under penalty of perjury that the foregoing
9 MR. EDWARDS: She's not answering the 9 is true and correct, right?
10 question. 10 A Yes.
11 MS. MENNINGER: On what grounds is she not 11 Q And it was executed on or about the
12 answering the question? 12 5th day of February, 2015, correct?
13 MR. EDWARDS: I just told you it invades 13 A It's a bit smudged, but it kind of looks
14 the attorney-client privilege. If she learned -- 14 like a 5.
15 I will instruct her if she learned by some 15 Q All right. And then there's a signature
16 other way than her attorneys sharing the information 16 block that's redacted that says Jane Doe 3, correct?
17 with her, then she can answer the question. 17 A Correct.
18 Q (BY MS. MENNINGER) I'm asking you not to 18 Q Do you believe that you signed this
19 tell me whether your attorneys showed you the record. 19 document and it was later covered up by that block?
20 I'm asking you not to tell me the source of the 20 A Yes.
21 record. 21 Q All right. And again, is there anything
22 I'm asking you if you personally in the 22 in this document that you believe today to not be
23 middle of 2015 looked at Mar-a-Lago records? 23 true?
24 MR. EDWARDS: Same objection. 24 MR. EDWARDS: I just ask that you read
25 Same instruction. 25 through the entire document and answer the question.
Page 34 Page 36
1 THE DEPONENT: Thank you. 1 A Correct.
2 MR. EDWARDS: Thank you. 2 Q All right. And that was under penalty of
3 MS. MENNINGER: I think I have one more. 3 perjury, correct?
4 MS. McCAWLEY: It's okay if you don't. 4 A Correct.
5 MS. MENNINGER: I don't think I have all 5 Q All right. If I could now turn to what
6 of them. 6 we'll mark as Defendant's Exhibit 6.
7 Q (BY MS. MENNINGER) All right. Do you 7 (Exhibit 6 marked.)
8 recognize Defendant's Exhibit 5? 8 MR. EDWARDS: Thank you.
9 A Yes. 9 MS. McCAWLEY: Thanks.
10 Q What is the title of that document? 10 Q (BY MS. MENNINGER) Do you recognize this
11 A Declaration of Virginia Giuffre. 11 document, Ms. Giuffre?
12 Q And that's you, correct? 12 A I do.
13 A Yes. 13 Q All right. What do you believe this
14 Q And do you recognize which case this 14 document to be?
15 declaration was filed in? 15 A I believe this is when I spoke to the FBI.
16 A Yes. Bradley Edwards and Paul Cassell, 16 Q Okay. And do you remember about when you
17 Plaintiff versus . 17 spoke to the FBI?
18 Q All right. And who do you understand 18 A It says, Date of entry July 5th, 2013.
19 Mr. Edwards and Mr. Cassell to be? 19 Q Do you believe that you spoke to the FBI
20 A Mr. Edwards is my lawyer sitting next to 20 in 2013?
21 me. 21 A I thought it was 2011 when I talked to
22 Q All right. 22 them.
23 A And Mr. Cassell is another one of my 23 Q Okay. I'm going to direct your attention
24 lawyers. 24 to the bottom of that page.
25 Q All right. And they are in a lawsuit 25 A Yes.
Page 38 Page 40
1 A I believe they were. 1 Q Okay. And do you see a date reflected on
2 Q Okay. Have you had a chance to review 2 the front page?
3 this report? 3 A April 7, 2011.
4 And I will make note for the record that 4 Q Is that when you had that phone
5 there are obviously many places that are blacked 5 conversation with them?
6 out -- 6 A If it's dated like that, it must be, yes.
7 A Yeah. 7 Q Well, I just need you to say from your
8 Q -- or whited out. Is that fair? 8 memory, does that sound about right in terms of what
9 A Yes. 9 you recall having been the phone conversation?
10 Q All right. Have you had a chance to 10 A I'm sure it's correct.
11 review this one with whited-out portions of it before 11 Q Okay.
12 today? 12 A I don't have a good calendar in my brain.
13 A Yes. 13 So, yes, I'm sure that that's the correct date.
14 Q All right. And you understood when you 14 Q Did you understand it was being recorded,
15 were speaking to the FBI that they were federal 15 correct?
16 agents, correct? 16 A Yes.
17 A Yes. 17 Q Okay. Have you listened to the recording
18 Q And that you were supposed to tell them 18 of that phone call?
19 the truth, correct? 19 A I don't believe I listened to the
20 A Absolutely. 20 recording, but I have seen the document.
21 Q And do you believe that you did, in fact, 21 Q All right. And again, you were speaking
22 tell them the truth? 22 the truth at the time you were speaking to them as
23 A To the best of my knowledge. Again, when 23 lawyers and officers of the court, correct?
24 it comes to dates and times, I was obviously off. 24 A Yes. And again, to the best of my
25 But everything else is absolutely 100 percent true. 25 knowledge when it comes to dates.
Page 42 Page 44
1 Some names have been changed in order to protect 1 time, she --
2 other people. 2 MS. MENNINGER: She made the record very
3 Q (BY MS. MENNINGER) Protect their privacy? 3 clear. Thank you. She doesn't need you to make a
4 A Protect their privacy, yeah, I would say, 4 record.
5 just not getting them involved in, if this were to 5 MR. EDWARDS: I'm not making records, but
6 ever go public. 6 you're making this last longer. There's no need for
7 Q Well, again, without rereading the whole 7 this. This doesn't have to be an unpleasant process.
8 manuscript -- 8 I want her to help you.
9 A Reading it, yeah. I'm trying to see if I 9 MS. MENNINGER: I don't find it
10 can -- see something in here. 10 unpleasant. I'm sorry if you do.
11 Q Let me narrow my question and maybe that 11 MR. EDWARDS: Okay. Well, then, I object
12 will help. 12 to that last series of questions to the extent that
13 A Yes. 13 she was unable to look at what you wanted her to look
14 Q Is there anything -- well, first of all, 14 at.
15 did you author that entire manuscript? 15 Q (BY MS. MENNINGER) I would like to next
16 A Yes, I did. 16 turn to a document filed on March 16th of this year.
17 Q Did anyone else author part of that 17 Or actually, let me rephrase that. A document dated
18 manuscript? 18 March 16th of this year, which we will mark as
19 A Do you mean did anyone else write this 19 Defendant's Exhibit 9.
20 with me? 20 (Exhibit 9 marked.)
21 Q Right. 21 Q (BY MS. MENNINGER) Do you recognize this
22 A No. 22 document, Ms. Giuffre?
23 Q That's all your writing? 23 A Yes, I do.
24 A This is my writing. 24 Q All right. And what is your understanding
25 Q Okay. To the best of your recollection, 25 of what this document represents?
Page 46 Page 48
1 preparing responses to discovery requests, correct? 1 Q Okay. And what is this document?
2 A Yes. 2 A Plaintiff's Second Amended Supplemental
3 Q All right. I'm going to show you a 3 Response and Objections to Defendant's First Set of
4 subsequent one marked Defendant's Exhibit 10 and 4 Discovery Requests to Plaintiff.
5 dated March 22nd. 5 Q All right. And again, turning to the very
6 (Exhibit 10 marked.) 6 rear section, I think you'll see your attorney's
7 Q (BY MS. MENNINGER) If you can take a look 7 signatures again and the date of April 29th, 2016?
8 at that. 8 A I do see that.
9 A Thank you. 9 Q All right. And again, you authorized this
10 Q And while we're at it, I'm going to give 10 document to be filed, correct?
11 you Defendant's Exhibit 11 so you can look at them 11 A Correct.
12 together. 12 Q And the statements contained therein are
13 (Exhibit 11 marked.) 13 true, to the best of your knowledge, correct?
14 Q (BY MS. MENNINGER) All right. 14 A Correct.
15 A Thank you. 15 Q And that's -- April 29th is just a few
16 Q All right. So looking at Defendant's 16 days ago, correct?
17 Exhibit 10, do you recognize that document? 17 A Yes.
18 A Plaintiff's Supplemental Response and 18 Q All right. Did you review this April 29th
19 Objections to Defendant's First Set of Discovery 19 document before it was filed or served?
20 Requests to Plaintiff. 20 A Like I said, I've seen a lot of documents
21 I've seen a lot of documents, and they all 21 and they all look alike, but I'm sure I've seen this
22 look the same. But I'm sure I've seen it. 22 one.
23 Q All right. And looking, again, at the 23 Q Okay. And if it's something that was
24 last page -- or I'm sorry, this time it will be the 24 served last Friday, does that refresh your
25 third to last page. 25 recollection that you reviewed it before it was
Page 50 Page 52
1 as a teenager or at any point in time, that you 1 A I volunteered at a bird aviary.
2 recall? 2 Q What was the name of that?
3 A Yes, that I recall. 3 A I don't know the name of it. But it
4 Q All right. Did you ever work at Taco 4 was -- I'm an animal lover. So --
5 Bell? 5 Q Okay.
6 A My ex-boyfriend used to work there and I 6 A -- it's something I enjoyed doing.
7 would help him out. I was never really -- I don't 7 Q Okay. Did you get a check from them?
8 think I was employed there. He was my boyfriend so I 8 A I volunteered. I think they eventually
9 stayed there with him all the time. 9 put me on some kind of payroll. I don't think it was
10 Q What was his name? 10 much, though.
11 A I called him but I think his real 11 Q Okay. So what year were you in helping
12 name was 12 out in a Taco Bell wearing the uniform and getting a
13 Q Okay. And so he was employed there, but 13 check?
14 you were not employed there? 14 A I have no idea when it comes to years.
15 A I used to go there and help him out. 15 Q Was it before or after Mar-a-Lago?
16 Q Did you have a uniform? 16 A Before Mar-a-Lago.
17 A I would have to wear a shirt when I was 17 Q Okay. And how --
18 there, yes. He was the manager, so -- 18 A Mar-a-Lago was my first real job so --
19 Q Oh, a Taco Bell shirt? 19 Q What's that?
20 A Yes. 20 A Mar-a-Lago was like my first real job.
21 Q Okay. And did you get a paycheck from 21 Q What do you mean by real job?
22 them? 22 A Like, you know, fully employed, sit down
23 A I believe paid me. 23 for an interview and, you know.
24 Q How did he pay you? 24 Q Okay. So Taco Bell, was Taco Bell the
25 A With a check. 25 first place you got a paycheck from?
Page 54 Page 56
1 before? 1 Q Whatever address you were living at, at
2 A I think it came -- like I said, don't 2 the time you started at Mar-a-Lago.
3 quote me on it, but I think Publix came before it. 3 A , Loxahatchee, Florida
4 Q And who were you living with when you 4 33470.
5 worked at Publix? 5 Q How is it that you came to work at
6 A My mom and my dad. 6 Mar-a-Lago?
7 Q And who were you living with when you 7 A My dad is a maintenance manager or
8 worked at the aviary? 8 supervisor, I don't know what you call it. But he
9 A My mom and my dad. 9 worked in the maintenance department, mostly on
10 Q Anywhere else that you got a paycheck from 10 tennis courts, working on the air conditioning,
11 before 2000? 11 helping set up for functions. And he got me a summer
12 A No, not that I can think of. 12 job there.
13 Q Okay. Anywhere else you wore a uniform? 13 Q Okay. And you said you were on a break?
14 A Besides Mar-a-Lago and -- yeah, that's it. 14 A Yes.
15 Q Okay. And so how long was it between 15 Q What were you on a break from?
16 working at any of those three places and the time 16 A I think like -- this is going back so long
17 that you worked at Mar-a-Lago? 17 now, but I was attempting to get my GED. And it,
18 A I have no idea. I'm sorry. Um -- 18 summer came, so school stops during the summertime
19 Q Years? Months? 19 here in America, and I got a summer job.
20 A Oh, we're going to go back 20 Q All right. And where were you in school?
21 chronologically. I was trying to get my GED and I -- 21 A I don't actually know the name of the
22 there was a summer break. And that's when I started 22 place. It's -- yeah, I know.
23 working for Mar-a-Lago. So that Mar-a-Lago we know 23 Q A GED place?
24 now is in the year 2000. So I would have to say a 24 A Yeah, it was, like, I was previously in
25 month. 25 Royal Palm Beach High School, but, I mean, because of
Page 58 Page 60
1 they said for me to come in for an interview. 1 name.
2 Q Um-hum. 2 Q All right. What did she look like?
3 A To be interviewed for a locker room 3 A She had blonde hair, probably to her
4 assistant. 4 shoulders, and it was curly.
5 Q Um-hum. 5 Q And how old was she?
6 A They liked me. I had to go through a 6 A I'd say in her 20s.
7 series of drug tests, polygraph tests. I mean, it 7 Q All right. Did they check your
8 was a very extensive regime to get a job there. 8 identification when you went in for your job
9 Q Yeah. 9 interview or your --
10 A And when all those came back good, I 10 A It was very extensive. I'm sure they
11 started the job. 11 would have had to check and make sure I was who I
12 Q So how long do you think it took for you 12 was.
13 to go through that extensive series of drug tests and 13 Q And so you had a driver's license, right?
14 polygraph tests and -- 14 A I believe so.
15 A I did them both in the same day. 15 Q All right. And, let's see. Did you move
16 Q Okay. When was the interview? Was it on 16 to a different position while you were there or did
17 the same day or a different day? 17 you always stay as a locker room --
18 A I believe it was like a few days 18 A I wasn't there very long. So I just --
19 beforehand. 19 Q Just one second. Did you always stay as a
20 Q Okay. And do you remember who you 20 locker room attendant?
21 interviewed with? 21 A Yes.
22 A No. 22 Q Okay. I just need to finish my question
23 Q Do you remember the title of the job for 23 for the court reporter.
24 which you were interviewing? 24 A I know, I'm sorry. I have a tendency of
25 A Locker room attendant. 25 jumping in.
Page 62 Page 64
1 Q Are they your Mar-a-Lago employment 1 Q (BY MS. MENNINGER) Okay. And it is not
2 documents? 2 true that you were 15 when you met Ghislaine Maxwell,
3 A Um -- 3 correct?
4 MR. EDWARDS: Object to the form. 4 A It was a mistake that I made, yes.
5 A My name is on there. 5 Q So that the printing in the newspaper that
6 Q (BY MS. MENNINGER) Okay. Do you believe 6 you met Ghislaine Maxwell when she was -- when you
7 them to be your Mar-a-Lago employment documents? 7 were 15 is not a true statement of fact, correct?
8 A As far as I can tell. 8 A It is an incorrect statement as I have now
9 Q Okay. So you were able to review your 9 found out, that my employment started in 2000.
10 Mar-a-Lago employment documents -- 10 Q All right. And to the best of your
11 MR. EDWARDS: Object to the form. 11 recollection, you found that out in the middle of
12 Q (BY MS. MENNINGER) -- and respond to the 12 2015, correct?
13 question, as it says right there that you respond, 13 MS. McCAWLEY: Objection.
14 correct? 14 A To the best of my recollection. I mean, I
15 A Yes. 15 can't pinpoint an exact date I found out. But, yes.
16 Q When did you review the documents that you 16 Q (BY MS. MENNINGER) About a year ago?
17 reviewed to cause you to respond to that answer that 17 MR. PAGLIUCA: Are we all participating in
18 way? 18 this deposition or just --
19 A I don't think I found out till sometime 19 MS. McCAWLEY: Same way you guys did.
20 mid -- mid last year, I believe. 20 MR. PAGLIUCA: We did not.
21 Q Okay. 21 MS. MENNINGER: I did not.
22 A I'm really not too sure. You know, I'm 22 MS. McCAWLEY: You both objected.
23 sorry, dates and documents, there's too many to 23 MS. MENNINGER: No.
24 remember. But -- 24 MR. PAGLIUCA: No, we didn't.
25 Q Okay. You do admit that you filed in many 25 MS. McCAWLEY: We can go back through the
Page 66 Page 68
1 THE VIDEOGRAPHER: We're off the record at 1 next as Defendant's Exhibit 14.
2 10:12. 2 (Exhibit 14 marked.)
3 (Recess taken from 10:12 a.m. to 3 A Thank you.
4 10:27 a.m.) 4 Q (BY MS. MENNINGER) All right. Do you
5 THE VIDEOGRAPHER: We're back on the 5 recognize this document?
6 record at 10:27. 6 A Yes.
7 Q (BY MS. MENNINGER) All right. 7 Q What is this document?
8 Ms. Giuffre, you testified that you first became 8 A This is me replying to ads for jobs.
9 aware that you -- your employment at Mar-a-Lago began 9 Q Okay. And you were communicating with --
10 in 2000, in mid-2015, correct? 10 by your e-mail, correct?
11 MR. EDWARDS: Object to the form. 11 A Yes.
12 Mischaracterizes her testimony. 12 Q All right. And I apologize. This one
13 A I don't know exactly when. It could be 13 actually has the resume attached to an e-mail.
14 towards the end of 2015. It could be towards the 14 A Um-hum.
15 beginning of 2016. I just know that I've learned 15 Q Do you see that, towards the back of the
16 about it recently. I'm not too sure exactly what 16 document?
17 date I did learn about it. 17 A Yes, I do.
18 Q (BY MS. MENNINGER) Okay. But to your 18 Q Okay. So --
19 mind, it's been within the last 6 to 12 months; is 19 A Sorry.
20 that fair? 20 Q To whom -- to whom -- with whom were you
21 A I wouldn't say 12 months, no. I would 21 communicating about a job at this time?
22 just say up until -- I don't know when I was shown 22 A Well, on the very top, Phil or Gary, and
23 that, when I actually first saw it, but it wasn't a 23 that was for a bartending position.
24 year ago. 24 Q Okay.
25 Q Saw your employment records from 25 A Um --
Page 70 Page 72
1 January -- 1 Q Okay. Is the content in Defendant's
2 A Yes. 2 Exhibit 14, that you believe you sent out to an
3 Q -- of 2014, correct? 3 employer, correct?
4 A Correct. 4 A Unfortunately, I have to tell you that
5 Q All right. So you believe you created the 5 they are not correct. Through my experience I was in
6 resume that's attached to Defendant's Exhibit 14, 6 the mind-set that I was unemployable. I had been
7 correct? 7 abused for many years and I was told by a job agency
8 A Correct. 8 that I need to show that I've consistently worked at
9 Q And you sent it out with respect to this 9 various places and given experience. So it's not
10 employment you saw on craigslist, correct? 10 something that I'm proud of, but I have had to plump
11 A Correct. 11 up my resumes to make it look as though I could be
12 Q And you are the one who put into this 12 employed.
13 document the contents of the resume, right? 13 Q What do you mean by plump up your resume?
14 A Yes. 14 A Well, I couldn't -- I didn't feel that I
15 Q All right. 15 could go to an employer and tell them that I had
16 MR. EDWARDS: We're talking about the 16 held, you know, one job in the last 10 to 12 years
17 resume that's attached to Exhibit 14, right? 17 and before that I was trafficked for the purpose of
18 MS. MENNINGER: We are. 18 sex. And that's definitely something you don't want
19 MR. EDWARDS: Okay. Got it. 19 to put down on your resume, which makes you quite
20 MS. MENNINGER: Thank you for clarifying. 20 highly unemployable.
21 MR. EDWARDS: Got it. 21 So I did add places in, such as Indigo Bar
22 MS. MENNINGER: Although, I don't know 22 & Grill, Calmao Flamenco Bar & Restaurant.
23 there are any differences with Defendant's 23 Q Wait, wait. Which one?
24 Exhibit 13. 24 A On Exhibit 14.
25 Q (BY MS. MENNINGER) But just to be safe, 25 Q Um-hum.
Page 74 Page 76
1 Q All right. So you worked at a place for 1 Q (BY MS. MENNINGER) But you represented
2 about a year. And on your resume you typed that you 2 you were there working as a server or waitress and
3 worked there for nine years, correct? 3 that we were never slow. That is not true, correct?
4 A Correct. 4 A Well, I never worked there, so it's --
5 Q And you did that, correct? 5 again, I was very highly unemployable, given my past.
6 A I did. 6 So I did whatever I could to make it look as though
7 Q Nobody else typed that for you? 7 my potential employer could hire me.
8 A No, I did it myself. 8 Q Okay. You described your duties that were
9 Q All right. And the next employment you 9 not -- those were fictional duties, correct?
10 list here -- well, is your job description accurate? 10 A They were duties that a waitress and a
11 A Yes, that is actually accurate. 11 server would do.
12 Q Okay. And everything in there is what you 12 Q But you did not do at Indigo Bar --
13 actually did? 13 A But I did not do them at Indigo Bar &
14 A Yes, for ET Australia. 14 Grill.
15 Q Okay. Indigo Bar & Grill, did you type 15 Q Okay. You described your energetic
16 that in? 16 service and your service with a smile to the guests.
17 A I did type that in. 17 That was not true, correct?
18 Q And did you actually work at Indigo Bar & 18 A Everything in Indigo Bar & Grill is not
19 Grill? 19 correct.
20 A No, I did not. 20 Q And you created that entire description,
21 Q All right. So the dates that you put on 21 correct?
22 your resume are not true, correct? 22 A For the sole purpose of being able to
23 A That's correct. 23 obtain employment, yes.
24 Q The title of your job at that place was 24 Q To get money?
25 not correct; you didn't work there, right? 25 MR. EDWARDS: Form.
Page 78 Page 80
1 Q All right. And then what were your 1 Q (BY MS. MENNINGER) Fair enough. The
2 actual -- is that your actual job that you had there? 2 first quarter of the year, calendar year --
3 A The description of it? 3 A Yes.
4 Q The title, server, waitress, bartender? 4 Q -- 2003?
5 A Yes. 5 A If we're going to be politically correct,
6 Q All right. Is the description accurate? 6 yes.
7 A To a T. 7 Q That's what you recall?
8 Q What's that? 8 A (Indicating.)
9 A To a T. 9 I'm sorry, yes.
10 Q Okay. The next job you list is Mannway 10 Q And is your description of Mannway
11 Logistics, Logistics Receptionist. 11 Logistics correct?
12 Is that a job you actually held? 12 A Yes.
13 A It is a job I held. 13 Q All right. And how long did you work
14 Q And when did you hold it? 14 there?
15 A Again, I'm very bad at dates. I'm not too 15 A I think that was less than a year that I
16 sure. 16 worked there. I would approximate about six, seven
17 Q All right. Approximately when did you 17 months.
18 have it? 18 Q Can you name one coworker you had or boss
19 A I don't want to speculate and give you the 19 or anybody else that worked there?
20 wrong answer, so I'm not too sure. 20 A I know her name started with an M, but I
21 Q Did you have children at the time you 21 can't remember. I remember what she looks like. I
22 worked there? 22 just don't remember her name.
23 A No. 23 Q Okay. And how much did you make there?
24 Q So before 2006? 24 A I don't remember the exact amount.
25 A Yes. 25 Approximately about $20 an hour, I think.
2 working for that six months to a year? 2 actually a job seeker there. And a job seeker, I
3 A I believe that was full time. 3 don't know if you're familiar with the term.
4 Q And is full time the same in Australia? 4 Somebody who is looking for work and you
5 A Yeah it's a 40-hour week. 5 go to a job agency, and you go look on the computer.
6 Q Okay. 6 And you actually have somebody who helps you find
7 A Well, 38 because you get two hours of 7 employment. And they are the ones who recommend that
8 lunch, so, yes. 8 you show that you've continuously worked throughout
9 Q All right. Have you been in touch with 9 your years. They ended up really liking me, so
10 anyone from that employment in a while? 10 that's how I got the job there.
12 Q All right. The next job listed there is 12 that gave you the advice to plump up your resume?
21 and found something similar to what the description I 21 Q When did you first become a job seeker at
23 Q Okay. So when you were creating this 23 A Well, if I finished there in 2006 and I
24 document in 2013/2014, right, that's when you had the 24 worked there for approximately a year, it would have
25 Titusville address? 25 been 2005 -- late 2004, 2005. I'm not too sure.
Page 82 Page 84
1 A Yes. 1 Q Okay. So you were a job seeker there
2 Q All right. You went on the Internet and 2 first and then got employment there, right?
3 you searched for a place that would be like the job 3 A Yes.
4 you were looking for? 4 Q Okay. So the advice to plump up your
5 A Correct. 5 resume was while you were seeking a job or while you
6 Q And you found the name of an actual place, 6 were employed there?
7 Calmao Flamenco Bar & Restaurant. 7 A While I was seeking a job.
8 Did I get that right? 8 Q All right. And you were assigned a
9 A I'm not 100 percent on that, but I think 9 counselor?
10 so. 10 A Yes.
11 Q Okay. And you did that in order to 11 Q One or more than one?
12 impress the employer you were applying for here in 12 A It changes on a daily basis. There's
13 the e-mail, correct? 13 somebody who comes into the office and they sit with
14 A Correct. 14 you and they help you with your resume. And then
15 Q All right. And you did that in order to 15 they help you go on the computer and look for open
16 get money from a job that you hoped to get from this 16 vacancies.
17 employer in the e-mail, correct? 17 Q So someone in approximately 2005 gave you
18 A I was hoping to gain employment. And not 18 the advice to plump up your resume. That's what
19 having much experience, I put in there that I had 19 you're saying?
20 experience. 20 A To make it look like I've continuously
21 Q Okay. And you said that you had been 21 worked, yes.
22 advised to plump up your resume by a job agency; is 22 Q Okay. So back to Calmao Flamenco Bar &
23 that right? 23 Restaurant, which is a place you found on the
24 A Yes. 24 Internet but did not actually work. Is that, the
25 Q What was the name of that job agency? 25 dates for your employment there, December 2001 to
Page 86 Page 88
1 page you have your education, correct? 1 of 2000 as your start date for Mar-a-Lago?
2 A Can I just make a statement to say that, 2 A It just looks as though I've given them a
3 again, with the Mar-a-Lago Resort and Spa, I did have 3 longstanding history of employment.
4 to add dates to make it look as though I had 4 Q You chose a month. Why did you choose
5 continuously worked. So those, again, are incorrect 5 that month?
6 dates. 6 A I chose months and dates for every single
7 Q But it is a date that you typed into a 7 position on that resume. There is no specific reason
8 resume in 2013 or 2014 -- 8 why I chose that month. It was just purely to show
9 A That is the date that -- 9 that I was continuously employed.
10 Q If you could just let me finish my 10 Q On the last page it has some education.
11 question. 11 Which part of that is untrue?
12 A Sure. 12 MR. EDWARDS: Object to the form.
13 Q That is a date that you typed into your 13 A I have received my business admin cert 3
14 resume in 2013 or 2014, correct? 14 from ET Australia. I've never held responsible
15 A That is the date that I did type in, but 15 service of alcohol and gambling.
16 those are incorrect dates. 16 Q (BY MS. MENNINGER) Do you understand that
17 Q All right. 17 to be a licensing of some sort or a class? Or what
18 A And, as well as the -- the position, 18 do you understand that --
19 organizing, making and canceling appointments for 19 A In Australia you have to have something
20 massage therapists. 20 called an RSA and RCG to be able to work as a
21 Q All right. 21 waitress or bartender or anything. And I didn't know
22 A I mean, I was their locker room attendant. 22 if it was the same out here in America. So I put
23 I just wanted it to sound like I had more 23 down that I had.
24 receptionist experience than I did. 24 I had taken a CPR and first aid. I don't
25 Q You wanted it to look like you had more 25 remember when, but it's not current.
Page 90 Page 92
1 A In Sydney, yeah. 1 A I don't want to lock down on which exact
2 Q All right. Got it. 2 birthday it could have been without knowing.
3 Do you know if those two organizations 3 Q You don't know which birthday it was; is
4 still exist? 4 that what you're saying?
5 A Mannway, I would definitely say, it's a -- 5 A The one that I'm specifically telling you
6 it's a large logistic company. I would say it still 6 about?
7 does exist. 7 Q Right. You don't know which one?
8 Gemma Catering, I'm not too sure if that 8 A No.
9 exists anymore or not. 9 Q All right. Do you remember spending more
10 Q Okay. All right. So did you spend your 10 than one birthday with Jeffrey Epstein and Ghislaine
11 16th birthday with Ghislaine Maxwell and Jeffrey 11 Maxwell?
12 Epstein? 12 A Yes.
13 A No. I was 16 when I met them, now that I 13 Q Okay. Tell me about the other ones that
14 know the correct dates. So I would have spent my 14 you remember.
15 17th birthday with them. 15 A Well, I know my 19th birthday. I can't
16 Q So when you represented that you spent 16 remember, really, my 18th birthday. But my 19th
17 your 16th birthday with Ghislaine Maxwell and Jeffrey 17 birthday we celebrated it early, earlier than my
18 Epstein, that was not true, correct? 18 actual date of birth. And that's when he surprised
19 A At my ability at the time, that's what I 19 me with tickets to Thailand.
20 believed to be true. It wasn't until I found the 20 Q What do you mean he surprised you with
21 Mar-a-Lago records stating the year 2000. Me being 21 tickets to Thailand?
22 born in 1983 would make me turning 17 that year. 22 A He told me that the tickets for Thailand
23 Q So please describe for me your 17th 23 were for my birthday.
24 birthday that you claim you spent with Ghislaine 24 Q Did he hand you something that looked like
25 Maxwell and Jeffrey Epstein. 25 a ticket to Thailand? What do you mean?
Page 94 Page 96
1 talk to me, just the three of us. And he -- first, 1 Do you see that page?
2 he told me about the -- 2 A Page 9 of 27, yes.
3 Q If I could just stop you. I think I asked 3 Q All right. And paragraph 23, do you see
4 where were you -- 4 that paragraph?
5 A Oh, I'm sorry. 5 A I see the paragraph.
6 Q -- when you had this conversation about 6 Q All right.
7 the -- 7 A I was just going to read it over quickly.
8 A Just the island. I'm just trying to 8 Q By all means.
9 describe the instance that he gave it to me. 9 A I've read it.
10 Q Oh, okay. 10 Q And the sentence, Defendant and
11 A It was on the island, on the pier in the 11 Ms. Maxwell acknowledged and celebrated plaintiff's
12 Caribbean. 12 16th birthday, is not a true statement, correct?
13 Q Okay. And it was sometime before your 13 A Only upon learning about the fact that I
14 19th birthday? 14 just found out my records. I assumed at the time it
15 A Correct. 15 was my 16th birthday. But now we know different.
16 Q How much time before? 16 Q You admit, as you sit here today, that
17 A I don't know. A couple -- six weeks, a 17 defendant and Ms. Maxwell did not celebrate your 16th
18 couple of months. I don't know. Close to my 18 birthday with you, correct?
19 birthday. It was my birthday present, that's what he 19 A Correct, based upon the records.
20 told me. 20 Q Which you don't know when you saw?
21 Q Okay. So you don't know when you had this 21 A I know it was, you know, it wasn't -- it
22 conversation? 22 wasn't a year ago, but it wasn't that long ago
23 MR. EDWARDS: Form. 23 either. So I'm not too sure. I can't tell you the
24 A I mean, I -- no, I didn't record the time 24 date that I actually saw them.
25 and the date, so I can only speculate. It was 25 Q All right. Last year you lived in
3 Q Okay. Did you use any e-mail address 3 Do not answer that question. This is a
6 Q That's the only e-mail address that you've 6 She's not going to answer those questions.
8 A That's correct. 8 question about whether your attorneys had told you to
9 Q And the Mar-a-Lago records that you 9 lie. Because that would be a crime, and I'm sure --
12 A Possibly. I mean, I can't say 12 attorneys did not tell you to lie, correct?
13 100 percent. I could have been told about them. I 13 A I can tell you for a fact my attorneys
14 could have seen them on a piece of paper. I really 14 have never told me to lie.
15 don't know. This is a very hazy subject. All I know 15 Q All right. And did your attorneys tell
16 is that I found out and that was able to clarify a 16 you to change a date?
18 Q Okay. What other dates were clarified? 18 answering any questions about communications between
19 MR. EDWARDS: I object and instruct the 19 her lawyers and herself, period.
20 witness not to answer if any of your knowledge is 20 Q (BY MS. MENNINGER) So if I could also
21 based on any privileged communication that you had 21 direct your attention to Defendant's Exhibit 8. It's
22 between yourself and any of your lawyers. 22 the manuscript. If you could turn to page 40.
23 Q (BY MS. MENNINGER) Okay. You just said 23 THE VIDEOGRAPHER: I just have a quick
25 MR. EDWARDS: Object. That 25 Ms. Giuffre, would you mind bringing the
2 and we believed that these memories were worth 2 Q So that's a different piece of paper?
4 Q So you burned notes of the men with whom 4 Q So you had a green spiral notebook that
5 you had sex while you were represented by counsel in 5 you began sometime in 2011 or 2012 in which you wrote
7 MR. EDWARDS: Object to the form. 7 you, and you burned that in a bonfire in 2013.
8 A This wasn't anything that was a public 8 Did I get that right?
9 document. This was my own private journal, and I 9 A You got that right.
10 didn't want it anymore. So we burned it. 10 Q And do you have no other names of people
11 Q (BY MS. MENNINGER) When did you write 11 to whom you claim Ghislaine Maxwell directed you to
14 probably in, I don't know, I can't speculate, 2012, 14 Q Is there any document that would refresh
16 Q So you did not write this journal at the 16 A If you have a document you'd like to show
17 time it happened? 17 me, I would be glad to look at it and tell you the
19 Q You started writing this journal 19 Q I'm just asking you if there's a document
20 approximately a decade after you claim you finished 20 you know of that has this list of names in it?
23 Q And you started writing a journal after 23 that has been widely circulated in the press of you
2 that's the Ms. Roberts' claims are obvious lies part? 2 Q Okay. Do you recall specifically
4 Q Okay. When is the first time that you saw 4 the press?
6 A I guess when you guys handed it over for 6 Q Okay. What new symptoms did you
8 Q Okay. And who showed it to you? 8 A I think it's one thing to be a victim of
9 A It was sent to me by e-mail. 9 sexual abuse and survive it and come out trying to
10 Q Okay. Just through the course of 10 tell the world my story, and then another thing for
11 communicating with your attorneys? 11 it to be shut down because these people, Ms. Maxwell
13 Q You've never seen it published? 13 Q And I asked you what symptoms had you
15 Q All right. Did you -- I'm sorry, did you 15 MR. EDWARDS: She's going to finish her
16 discuss this publication of what you saw in the press 16 answer to this question. You cut her off so many
21 A When I got back to Australia, Judith and I 21 this is a psychological damages claim, and she is
22 started seeing each other again. Before then, I 22 trying to explain to you what those damages are.
23 spoke with a doctor in Colorado about this. His name 23 Q (BY MS. MENNINGER) Okay. What are your
24 is Dr. Olsen. And it was causing me a lot of 24 symptoms that you experienced since January 2nd, 2015
25 distress to have to deal with being called a liar all 25 that are new?
15 Q All right.
16 MS. MENNINGER: I'm going to ask that we
17 take just a brief break and that I can hopefully then
18 come back and just ask a few final follow-up
19 questions, okay?
20 THE DEPONENT: Okay.
21 THE VIDEOGRAPHER: We are off the record
22 at 5:16.
23 (Recess taken from 5:16 p.m. to 5:25 p.m.)
24 THE VIDEOGRAPHER: We're back on the
25 record at 5:25.
22
Page 346
1 AGREN BLANDO COURT REPORTING & VIDEO, INC.
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3 Boulder, Colorado 80303 Videotaped Deposition of VIRGINIA GIUFFRE
May 3, 2016
4 May 11, 2016 Giuffre v. Maxwell
Case No. 15-cv-07433-RWS
5 Sigrid S. McCawley, Esq.
BOIES, SCHILLER & FLEXNER LLP The deponent wishes to make the following changes in
6 401 East Las Olas Boulevard the testimony as originally given:
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8 Re: Videotaped Deposition of VIRGINIA GIUFFRE ____ ____ ______________________________ ______
Giuffre v. Maxwell
9 Case No. 15-cv-07433-RWS ____ ____ ______________________________ ______
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