EXHIBIT Case Document Filed Page of Video Deposition of Tony Figueroa Volume Southern Reporting Company UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE VIRGINIA GIUFFRE Plaintiff GHISLAINE MAXWELL Defendant VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume of Pages Taken at the Instance of the Defendant DATE Friday June TIME Commenced a.m Concluded p.m PLACE Southern Reporting Company Paul Katz Professional Center SunTrust Building One Florida Park Drive South Suite Palm Coast Florida REPORTED BY LEANNE FITZGERALD FPR Florida Professional Reporter Court Reporter and Notary Public Case Document Filed Page of Video Deposition of Tony Figueroa Volume Southern Reporting Company APPEARANCE OF COUNSEL ON BEHALF OF THE PLAINTIFF BRADLEY EDWARDS Esquire Farmer Jaffe Weissing Edwards Fistos Lehrman P.L North Andrews Avenue Ft Lauderdale Florida Brad pathtojustice.com ON BEHALF OF THE DEFENDANT LAURA A MENNINGER Esquire Haddon Morgan and Foreman P.C East 10th Avenue Denver Colorado Lmenninger hmflaw.com Nsimmons hmflaw.com Also appearing Jenny Martin Videographer from Abel Virginia Giuffre Plaintiff Case Document Filed Page of Video Deposition of Tony Figueroa Volume Southern Reporting Company BY MS MENNINGER And where did you go after Royal Palm Beach A I believe it was South Area Im pretty sure it was South Area Did you go to another school after that A Yeah I went to Gold Coast after that Is that also in Royal Palm Beach A No Thats South Area was in Lake Worth Gold Coast is in West Palm They were both alternative schools Did you ever go to a Survivors Charter School A Yes I went there too When did you go there A Im not exactly sure of the date But it was somewhere after either Im pretty sure it was maybe I cant remember if it was Gold Coast first or Survivor But one of the Im trying to remember I honestly dont remember which one came first Thats all right Can you describe for me Survivors Charter School What is it like or was it like A I mean like I said it was an alternative Case Document Filed Page of Video Deposition of Tony Figueroa Volume Southern Reporting Company school It was just pretty much a bunch of bad kids you know who have gotten kicked out And it was pretty much like a last chance kind of school you know what I mean Does it look like a school A Kind of I mean it had like a cafeteria and then it had a whole bunch of like portables and stuff around there And it was under it was like right near the Lake Worth I remember there was like a bridge that went over the interstate right by it But I mean it was just a little you know little crappy school Was it during the day or at night A It was during the day So regular school hours A Yeah Well it was actually a little bit shorter hours I cant remember exactly But I know it was not like the full days Because I mean at the alternative schools its obviously not up to regular high school standards I mean they just do pretty much stuff to get people to get out of school you know so Get the credits that you need A Yeah So that way they can finish high school and not drop out and whatnot so Case Document Filed Page of Video Deposition of Tony Figueroa Volume Southern Reporting Company You actually go there in the morning though and take classes A Yeah And get checked in at attendance A Yeah And then you may leave a little earlier than a regular school day A Uh-huh affirmative All right Its not a online program A No it was not online When you were at Survivors Charter School did you ever see Ms Roberts there A Was it Survivors I dont remember if it was Survivors Or was it because Im pretty sure we were both was it I know we both went to one of the schools Im pretty sure it was Survivors maybe Did you see her there A Now when we went to the school like we were together afterwards But I dont remember exactly which one it was I know it was one of those alternative schools that we went to though Okay Did you was Wellington an alternative school A No Wellington is a is a real high Case Document Filed Page of Video Deposition of Tony Figueroa Volume Southern Reporting Company school like a regular high school Do you know if Wellington has an adult program A They might I mean I really dont know Im not sure Did you ever take night classes there A No So you believe when you reunited with Ms Roberts in or around she had also gone to one of those alternative schools A When I reunited with her no We ended up like trying to go finish school Tell me about that A I mean we just ended up going to one of those alternative schools and didnt even finish that So you two had both left school but went back together A Yeah to one of the alternative schools A Yeah And that may have been Survivors Charter School A Yeah Im pretty sure it probably was Im pretty sure Case Document Filed Page of Video Deposition of Tony Figueroa Volume Southern Reporting Company You both wanted to get your GEDs A Yeah Get better jobs A Uh-huh affirmative Things like that was the plan A Yeah But it did not work out A Yeah Do you know how long the two of you went to Survivors Charter School A I honestly dont remember Okay You do have a recollection of going with her though A Yeah Seeing her there A Uh-huh affirmative Im trying to get a little bit of a time frame on the time that you reunited with Ms Roberts I know you said you lived you remember being in an apartment with her in September of right A Yeah Do you think you had been together with her for a while at that point A It was probably Id say like a month or Case Document Filed Page of Video Deposition of Tony Figueroa Volume Southern Reporting Company BY MS MENNINGER Mr Figueroa you mentioned that you and Ms Roberts attempted to go to back to school while you were together A Yes to get your GED A Yeah Yes And you believe that you went to the Survivors Charter School A Yes MS MENNINGER Okay Im going to mark Defendants Exhibit Defendants Exhibit was marked for identification BY MS MENNINGER This is a school record for Ms Roberts that lists the names of various schools And A So it was Survivors obviously Thats the only one on that list that isnt or thats there thats on mine as well Okay A Other than the other ones but All right So you recognize Survivors Charter School on Ms Roberts school records A Yeah Thats what Im saying Since that Case Document Filed Page of Video Deposition of Tony Figueroa Volume Southern Reporting Company is the one on here thats thats completely clear I could not remember if it was that one or Gold Coast Okay There is an entry date for Ms Roberts at Survivors Charter School of and a withdrawal on of Do you see that A I mean its this right I mean thats the top The entry date of withdrawal at Survivors A Okay I did not know what those numbers I did not realize that that was a date I understand And I know you did not make this record So Im just wanting to know if thats consistent with your recollection that you guys went to school in the fall of until the A Yeah that sounds about right March of It sounds right A Yeah And you both went to school together A Uh-huh affirmative In the mornings A Yeah Case Document Filed Page of Video Deposition of Tony Figueroa Volume Southern Reporting Company And got out of school at some earlier time than a regular school day A Yeah Do you recall Ms Roberts going to Royal Palm Beach High Again this is in the time frame A I I dont recall I really dont Do you recall her during the time you were with her taking any night classes at Wellington High School A I dont recall Is it possible A Its a possibility MR EDWARDS Object to the form BY MS MENNINGER Do you know whether Wellington has a night school program A Like I said before I dont know They could You went there in ninth grade A Yeah It was during the day though I have no clue about night school Got it But you do have a memory about Survivors Charter School Case Document Filed Page of
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