Case Document Filed Page of Case Document Filed Page of GIUFFRE vs MAXWELL Deposition VIRGINIA GIUFFRE Agren Blando Court Reporting Video Inc 16th Street Suite Denver Colorado Case Document Filed Page of Agren Blando Court Reporting Video Inc IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Civil Action No CONFIDENTIAL VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE May VIRGINIA GIUFFRE Plaintiff GHISLAINE MAXWELL Defendant APPEARANCES FAMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN P.L By Brad Edwards Esq Andrews Avenue Suite Fort Lauderdale FL Phone brad pathtojustice.com Appearing on behalf of the Plaintiff BOIES SCHILLER FLEXNER LLP By Sigrid Mccawley Esq For Portion East Las Olas Boulevard Suite Fort Lauderdale FL Phone smccawley bsfllp.com Appearing on behalf of the Plaintiff VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc APPEARANCES Continued HADDON MORGAN AND FORMAN P.C By Laura A Menninger Esq Jeffrey Pagliuca Esq East 10th Avenue Denver CO Phone lmenninger hmflaw.com jpagliuca hmflaw.com Appearing on behalf of the Defendant Also Present Brenda Rodriguez Paralegal Nicholas Borgia CLVS Videographer VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc Pursuant to Notice and the Federal Rules of Civil Procedure the VIDEOTAPED DEPOSITION OF VIRGINIA GIUFFRE called by Defendant was taken on Tuesday May commencing at a.m at East 10th Avenue Denver Colorado before Kelly A Mackereth Certified Shorthand Reporter Registered Professional Reporter Certified Realtime Reporter and Notary Public within Colorado EXAMINATION MS MENNINGER I PRODUCTION REQUEST None VIRGINIA GIUFFRE PAGE Case Document Filed Page of Agren Blando Court Reporting Video Inc wanted to know about the Prince Andrew incident A So thats a different piece of paper Yeah thats just random paper So you had a green spiral notebook that you began sometime in or in which you wrote down your recollections about what had happened to you and you burned that in a bonfire in Did I get that right A You got that right And do you have no other names of people to whom you claim Ghislaine Maxwell directed you to have sex correct A At this time no Is there any document that would refresh your recollection that you could look at A If you have a document youd like to show me I would be glad to look at it and tell you the names I recognize off of that Im just asking you if theres a document you know of that has this list of names in it A Not in front of me no Where is the original of the photograph that has been widely circulated in the press of you with Prince Andrew A I probably still have it Its not in my VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc possess i on right now A A A Where is it robably in some Where I Sydney Where in Sydney At some family storage boxes house We got th boxes sh i pped to Aust ralia an they were i cked up off the porch by my nephews and brough to he ir house A A A Wh i ch is where I Sydney Where in Sydney And who lives in that house Well it owned by my mo her i n-law and fath er in law but my nephews liv in the house A nephews A What are th ir names I not giving you the names of my What the address of the house Why wou you want that I want to know where the photograph is I asking you where he photograph i And youve just tol me it somewhere in A Yes VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc So where i i th photograph loca ted A If I can percent say that the photograph i there it could be at my house that I presently live i I not going to iv you he address of my nephews res i dence When i the ast tim you saw he photograph i person A When I packed and left Amer i ca A Co orado Yes A ll right So you had that photograph here it you in Colorado A A Yes Wha on he back of he photograph I sorry Is there anything on th back of the photograph A heres like the da te i was pr i nted but no writ i ng or anything A Okay Does i say where i was pr i nted I dont be i eve so I hi nk it ust dont rem embe I just remember there a da te on it Whose camera was i taken i th VIRGINIA GIUFFRE I Case Document Filed Page of Agren Blando Court Reporting Video Inc A A A A A printed A A My little yellow Kodak camera Who took the picture Jeffrey Epstein And where did you have it developed I believe when I got back to America So where I dont know Palm Beach I dont know What is the date the photograph was I believe its in March Okay But thats just off of my photographic memory I dont it could be different but I think its March You have a photographic memory A Im not saying I have a photographic memory But if Id look at the back of the photo and I remember what it says I believe it was March Did the photograph ever leave your possession for a while A A I gave it to the FBI Okay And when did you get it back When they took copies of it VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc When was that A When they came to interview you A Yes So from until you left Colorado it was in your personal possession Yes A What other documents related to this case are in that storage boxes in Australia A MR EDWARDS Object to the form Documents related to this case there I dont know I really cant tell you I mean theres seven boxes full of Nerf guns my kids toys photos I dont know what other documents would be in there BY MS MENNINGER Did anyone search those documents after you received discovery requests from us in this case A I havent been able to obtain those boxes I cant get them sent back up to me Its going to cost me a large amount of money And right now Im trying to look after my family so Im not able to afford to get them up A You live in Australia correct I do VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc Okay How far away are the boxes from where you live in Australia A Sydney is down here at the bottom Cairns is up here at the top Okay Its probably a six-day drive Did you fly here through Sydney No A A Have you been to Sydney since youve moved back to Australia A I flew into Sydney with my three kids but it was a connecting flight to Brisbane Did you ask your nephews or anyone else to search those boxes in response to discovery requests that we issued in this case A They are my nephews I would never let them look at those Other than your green spiral notebook what else did you burn in this bonfire in A That was it A A Thats the only thing Yes Did you use wood Yes Charcoal VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc A My husband bu ilt th bon fir out wood and I dont know what ls he put in it Hes the one who always makes he fir es not me A A A A A A A Who se was present Just him and I Were your kids here No hey were i ns id ee ping And what beach was th i It wasnt a beach It was i my backyard Whats your address At that time Um-hum Yes Who were your neighbors Sweet peop Ray and I could look on my phone if you want A A months ago No thank you Do they still li ve here Yes Do you keep i touch i th th em Last time I talked to them was a few Did the see the fire A heyve seen many fires that we ve had VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc Weve had lots of bonfires there Did you ever ride in a helicopter with Ghislaine Maxwell acting as pilot of the helicopter A Yes Who else was on the flight A Ive been on the helicopter with her plenty of times I cant mention how many people were on the on the helicopter at the same time A How many times I dont know Do you have helicopter records that you could show me Im asking you how many times you were on the helicopter with Ghislaine Maxwell acting as the pilot A Its impossible for me to answer the question without having the actual physical records in front of me Im asking you to look into your memory and tell me how many times you recall being on a helicopter with Ghislaine Maxwell at the pilot seat A There is no number I can give you Theres plenty of times Ive been on her helicopter Where did you go from and to on a helicopter A I believe it was dont quote me on this VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc ecause I get con used on th i ands th I want to say it was St John It could have been St Barts St John or St Barts and then we would fly straight to Jeffreys i sland Okay Did you ever go anywhere else on th he icopt A No Were you eve on the he lic opter ith and Ghis a i ne Maxwell as th pilot of he helicopt er A ilo A you were A No Were you ever on the he li copter with and Gh i slaine Maxwell as the Do you eca ll telling Sharon Churcher that Di you see the press art icl i wh ic Sharon Churc her reporte that you were MR EDWARDS Object i on I just ask that if you going to ask this witness about a specif ic article Id lik for her to see he article Otherw i se shes not going to testify about it If you have something to show her hen VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc ease BY MS MENNINGER Do you recall seeing a press article in which Sharon Churcher reported that you were on a helicopter with and Ghislaine Maxwell as he pilot MR EDWARDS Again I ll et you answer th es tion once she looking at th documen that you being asked about MS MENNINGER You re not tting her answer a ques tion about whether she recalls a particular press statement MR EDWARDS I will let her answer every question about the press statement as long as she sees the press statement Im okay wi th hat She ca answer all of them MS MENNINGER No here is a rule of civil procedure that allows yo to direct a witness not to answer a ques tion when there a claim of privilege What privilege are you claiming to direct not to answer this ques tion MR EDWARDS I thought that you wanted accurate answers from this witness If the MS MENNINGER I asked her if she recalle something VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc MR EDWARDS If th so purpose is to just to harass her MS MENNINGER I asked her if she recalled something MR EDWARDS Then that just not going to be whats happening today BY MS MENNINGER All right So you fusing to answ a quest i on about whether you recall a part i cu ar press statement MR EDWARDS Shes BY MS MENNINGER is hat true MR EDWARDS She is not refus i ng to answer any quest i ons She A I not refusing to answer I just want see he ar ti you re alking abou so I can be ear i my statement BY MS MENNINGER Do you recall seeing a press artic wr itt en Sharon Churcher reporting that you flew on a he li copter it and Ghisla i ne Maxwel as he il ot A No I do not eca ll ead i ng a press article say i ng that I was on a helicopter i as Ghislaine i the pilot Do you recall telling Sharon Churcher that you had conversations i th VIRGINIA GIUFFRE regardi ng i Case Document Filed Page of Agren Blando Court Reporting Video Inc fl in on a he li copter it Gh i a in Maxwe ll A I bel i eve that i was taken out of co ex Ghislai ne tol me that she fl ew ill li nton in And Ghis lai ne li es to tal a lot of stuff at sounds fantastical And whet her it true or not that is what I do eca ll lli ng haron Churcher So you to Sharon rch that Gh i a i ne Maxwel is he on who old you ha sh fl i he licopt er A I tol Sharon Churcher that Gh i slaine flew onto the isla nd based upon what Ghisla i ne had to me ot based upon what had told you correct A Correct Did eve ask Sharon Churcher to correct anything that wa printed under her name co ncern ing your stories to Sharon hurcher A I wasn i ven ose stor i es to rea be ore th ey were print ed A ft they were print ed i you read them A I tried to stay away from th em They were very har You have to understand it was a very hard time for me an my husband to have to have this VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc public we didnt think it was going to be this publicly announced and that big So we turned off the news and we stopped reading so many things You didnt read the articles about your stories to Sharon Churcher A Ive read some articles Let me just finish You did not read the articles published by Sharon Churcher about your stories to Sharon Churcher A I have read some articles about what Sharon Churcher wrote And a lot of the stuff that she writes she takes things from my own mouth and changes them into her own words as journalists do And I never came back to her and told her to correct anything What was done was done There was nothing else I can do So even if she printed something that were untrue you didnt ask her to correct it correct A There was things that she printed that really pissed me off but there was nothing I could do about it Its already out there She printed things that were untrue correct MR EDWARDS Objection to the form Mischaracterization VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc A I wouldnt say that they were untrue I would just say that she printed them as journalists take your words and turn them into something else BY MS MENNINGER She got it wrong MR EDWARDS Object to the form Mischaracterization A In some ways yes BY MS MENNINGER Did she print things in her articles that you did not say to her MR EDWARDS I object and ask that the witness be given the opportunity to see the document so that she can review it and answer that question accurately Otherwise shes unable to answer the question Im not going to allow her to answer MS MENNINGER You know the civil rules tell you not to suggest answers to your client BY MS MENNINGER And you understand your lawyer is now directing you to not all of a sudden remember what your answer is Thats what hes suggesting that you say So youre not supposed to listen to him suggest that to you Youre supposed to tell me from your memory MR EDWARDS That is not what Im BY MS MENNINGER Did you MR EDWARDS Thats not what Im doing VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc You dont get to just talk over me and tell my client when not to listen to me All you have to do to get answers is show her the document youre talking about and Ill let her answer every question I dont know why were so scared of the actual documents MS MENNINGER I dont know why youre scared of your clients recollection Mr Edwards But anyway MR EDWARDS Why would you do this to her BY MS MENNINGER Did Sharon Churcher print things that you did not say MR EDWARDS Im going to instruct my client not to answer unless you give her what it is that youre talking about that was printed And she will tell you the answer the accurate answer to your question Just without the document to refresh her recollection and see it shes not going to answer the question BY MS MENNINGER Did Sharon Churcher print things that you did not say MR EDWARDS Same objection Same instruction not to answer I think Ive made a very clear record as VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc to why I want my client to answer all of these questions but I want her to have the fair opportunity to see this document BY MS MENNINGER Did Sharon Churcher print things that you felt were inaccurate MR EDWARDS Same objection Same instruction If she sees the document shes going to answer every one of these questions BY MS MENNINGER Did any other reporter print statements that you believe are inaccurate MR EDWARDS Same objection Same instruction BY MS MENNINGER Did any reporter print statements about Ghislaine Maxwell that were inaccurate MR EDWARDS Same objection Same instruction This is harassing This is harassing a sexual abuse victim And all Im asking is for fairness that we just let her see the document so she can answer this MS MENNINGER Mr Edwards please stop saying anything other than an objection what the basis is or instructing your client not to answer MR EDWARDS I will do that VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc MS MENNINGER Thats what the Federal Rules of Civil Procedure provide MR EDWARDS I hear you They also provide for fairness and civility And all Im asking very calmly is for her to see this MS MENNINGER Mr Edwards this is not your deposition Im asking your client what she remembers If she doesnt want to talk about what she remembers then let her not answer But you cannot instruct her not to answer unless theres a privilege What privilege MR EDWARDS I am instructing her not to answer BY MS MENNINGER All right You are refusing to answer questions about whether statements to the press about Ghislaine Maxwell attributed to you were inaccurate MR EDWARDS Shes not refusing not to answer A You are refusing to show me these documents so I could answer properly I would give you an answer if you were to show me some documents BY MS MENNINGER You cant say without looking at a document whether the press attributed to VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc you is accurate or inaccurate A Please show me the document You cant say from the top of your head whether any inaccurate statement has been attributed to you in the press A Please show me a document and I will tell you Are you refusing to answer my questions about your knowledge of whether inaccurate statements have been attributed to you in the press A Are you refusing to give me the documents to look at Are you refusing to answer the question A I am refusing to answer the question based upon the fact that you are not being fair enough to let me see the document in order to give you an honest answer A Ms Giuffre Yes we are talking about press that has been published on the Internet correct A A Yes Do you have access to the Internet Yes Have you looked on the Internet and read VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc articl es that attr i bute stat emen ts to you about Ghisla i ne Maxwe ll A Yes Do kno any statement that has been attribute to you i a press article on the Internet about Gh isl aine Maxwe ll that is unt ru MR EDWARDS Sarne object i on Sarne i nstruct i on A ease show me a spec ifi doc um en BY MS NNING Do you know of any such statement about Gh i slaine Maxwe ll attr i buted to you by the press that is i nacc urate A If you cou please show me a specific document Tell me wha Sharon Churcher ask ed you to rit for A Any knowledge that I had about my tim it A A A And i you wr ite it Um hum What i you rit it in or on ap What kind of paper ined paper as it i a book or in le sheets VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc A i ng sheets And did you write a ong document or a short document Wha was it A I can recall how long the oc umen was but I wou ld say it would be a few pages And other than asking you to write whatever you remember about id she i ve you any other ir ect ions about what you shou wr it A She was inter es te in two things really How Epstein got away ith so many counts of ch il trafficking for sex and how was involved in it Those were her two main i nqu iries What did she ask you to write A She asked me to wri abou Did she te ll you to put it in your own handwr iti ng A she just asked me to wr ite down what I can remember wrote A I wrote A Di you give her everything that you Did I give her the whole entire pages hat Yes Yeah I wrote pages for her specifically VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc A A paper A In your own handwriting In my own handwriting And what you wrote was that true Yes And did you get paid for those pieces of Not for the papers I dont believe Okay Have you gotten paid when theyve been reprinted A Online A No Have you negotiated any deal with Radar No Have you negotiated any deal with Sharon Churcher for the purpose of publishing those pieces of paper A A Not those pieces of paper When did you write those pieces of paper MR EDWARDS Object to the form A week before she came out BY MS MENNINGER And when did you give them to her A A When she came out When was that Sometime I believe in early VIRGINIA GIUFFRE Case Document Filed Page of Agren Blando Court Reporting Video Inc What i you get pa i if not or those pieces of paper A MR EDWARDS Object to the form I was paid for the i cture with i th i arm around me Gh i sla i ne i the background And I was paid for the I guess the pr i nt of the stor i es A paper A BY MS MENNINGER Anyt hi ng se No You were not pa i for those pieces of No All i ght And how many i eces of paper i you write A A ike I said I round i ng i around hree hree i eces of paper That what I I don remember to be exact on a number I sorry But over three pages me A A A And you wrote those somet i me in he week that she was com i ng out to see And you gave hem her right I gave them to her i you keep a copy of that No VIRGINIA GIUFFRE
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