E1 Case Document Filed Page of Page UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VIRGINIA GIUFFRE Plaintiff Case No against GHISLAINE MAXWELL Defendants CONFIDENTIAL Videotaped deposition of GHISLAINE MAXWELL taken pursuant to subpoena was held at the law offices of BOIES SCHILLER FLEXNER Lexington Avenue New York New York commencing April a.m on the above date before Leslie Fagin a Court Reporter and Notary Public in the State of New York MAGNA LEGAL SERVICES Avenue of the Americas New York New York Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential form and foundation of the question You can answer the question A First of all can you please clarify the question I dont understand what you mean by female I dont understand what you mean by recruit Please be more clear and specific about what you are suggesting Are you a female is that the sex that you are A I am a female Thats what Im referring to a female and Im asking you when you first the very first time you recruited a female to work for Mr Epstein A Again I dont understand what female I am a year old women Im not making it age any age of a female that you recruited to work for Mr Epstein A Again I was somebody who hired a number of people to work for Mr Epstein and hiring is one of my functions And when is the first time you Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential hired someone to work for Mr Epstein a female A As best as I can recollect a woman the age probably of about or was in sometime in How long did you work for Mr Epstein A I started working for him at some point in and the nature of my work relationship with him changed over time so from around the work lessened considerably When did you MR PAGLIUCA Can I interject for a moment If we are talking about background MS McCAWLEY Im in the middle of a question Let me finish it and then can you interject When you say to that the work lessened when did you complete working for Mr Epstein when was the last time you were employed by him the last date A I believe I still was doing Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential helping him in a very nominal way maybe an hour or two a year at sometime and MR PAGLIUCA So if you are going to be talking about general background I dont need to designate that as confidential So if you want to have them come back in thats fine I assumed by your first question you were going into more sensitive areas I will leave it up to you but if this is general background it will not be designated as confidential MS McCAWLEY I appreciate that I will jump back into my other questions MR PAGLIUCA So we will keep it as confidential When you were first employed by him in what were you hired to do A First I was consulting and what I did was I helped with decorating houses and in hiring staff to help run those houses Did your duties change over the course of to Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential MR PAGLIUCA Object to the form and foundation A My job entailed running the homes that he had but much more importantly most of the houses had construction and so whilst in there was no construction project there was construction projects that began after that time and I was in charge not only of hiring architects I was also in charge of all the filings or overseeing that like a general contractor would I also helped with hiring the architects hiring the builders reviewing the contracts for the builders coordinating the building projects coordinating how the projects would layout the timing of the projects and all the various materials that they would require to run a very substantial building project Thats the nature of the job I was dealing with How old was the youngest female you ever hired to work for Jeffrey MR PAGLIUCA Object to the form and foundation Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential girls A I did not count the number of girls and I did read the police report I can only testify to what I read So you are aware that the police report contains reports from underage girls A I cant testify to what the girls said I can only testify to the fact that I read a police report that stated that Were you working for Jeffrey you said you worked for him off an on until is that correct A I helped out from time to time So you were working with him during the time period when these underage girls were visiting Jeffreys home MR PAGLIUCA Objection to the form and foundation A I was not what year I need years How about lets say A Im not sure I was at the house at all in maybe one day maybe Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential knowledge there are people MS McCAWLEY Just like can you if you read through I will not argue with you counsel she can answer yes or no Are you aware there were over individuals who were minors who gave reports to police just like the one we just read that they were sexually assaulted by Jeffrey Epstein in the Palm Beach home during the years that you were working with him MR PAGLIUCA Objection to the form and foundation You can answer if you have knowledge A I already testified I was limited in the house a couple of days there is no way I knew I have read these reports I cannot testify to Given the experience Ive had with Virginias lies its very hard for me to testify about what I see I can tell from you my personal knowledge I did not know what you are referring to You did not know there were underage girls in the home that were being Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential assaulted by Jeffrey Epstein during the time you were working there A Based on the lies that I have already been told I cannot comment on any Are you saying these girls are lying when they gave these reports to police officers A Im not testifying to their lies Im testifying to Virginias lies I am not asking about Virginias lies A I can only testify to Virginias lies I can testify to having read these reports I cannot testify to anything else about them So your testimony is that during the time you were working there you did not know that these minor children were being abused in the home while you were there A What I have already told you and I will repeat I was in the house very limited times very few times I do not know what you are referring to Ive read these reports but based on the lies that Virginia Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential has perpetrated cannot tell you what is true or factual or not You said you were in the home a very limited time so average in the year for example how many times would you have been in his Palm Beach home A Very hard for me to state but very little How about his New York home A Same Were you his girlfriend in that year in A Define what you mean by girlfriend Were you in a relationship with him where you would consider yourself his girlfriend A No Did you ever consider yourself his girlfriend A Thats a tricky question There were times when I would have liked to think of myself as his girlfriend When would that have been A Probably in the early Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Im asking the questions I know what this case is about Im trying to I will ask you questions if you dont understand the question I can break it down for you Im happy to do that A Break it down a lot please I will do that The question is have you ever said to anybody that you recruit other girls A Why dont you stop there Let me finish my question Have you ever said to anybody that you recruit girls to take the pressure off you so you wont have to have sex with Jeffrey have you said that Thats the question A You dont ask me questions like that First of all you are trying to trap me I will not be trapped You are asking me if I recruit I told you no Girls meaning underage I already said I dont do that with underage people and as to ask me about a specific conversation I had with language we talking about almost years ago when this Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential took place I cannot testify to an actual conversation or language that I used with anybody at any time Have you ever said to anybody that you recruit other females over the age of to take the pressure off you to having to have sex with Jeffrey A I totally resent and find it disgusting that you use the word recruit I already told you I dont know what you are saying about that and your implication is repulsive Answer my question A I just did Have you ever said to anybody that you recruit females A I dont recruit anybody Thats an answer So you never said that A Im testifying that I cannot testify to an actual language Its a yes or no A I will not testify to an actual statement made years ago so I cannot Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential that he may have met socially through me Did you ever introduce Prince Andrew to Virginia in London A I understand her story about London but again her tissue of lies is extremely hard to pick apart what is true and what isnt Actually I wouldnt recollect her at all but for her tissue stories about this situation So did you ever introduce Prince Andrew to Virginia in London A I have no recollection Did Virginia ever stay at your home in London your town home A I know she claims she did but if you are asking me here today to remember specifically I cannot Do you remember taking a trip with Virginia to travel over to Europe including London A So I have seen her reports and I have seen the plane reports I see she says she was on that but again I really have no recollection of her Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Did you know that she was at the time of that trip MR PAGLIUCA Objection to the form and foundation A I have Did you know she was at the time of that trip MR PAGLIUCA Objection to the form and foundation A I didnt even know she was on the trip Did you hold her passport for her when she was traveling MR PAGLIUCA Objection to the form and foundation A I have no recollection whatsoever of her even being on the trip nor holding her passport Maxwell Exhibit picture marked for identification Im showing you what we marked as Maxwell Exhibit Can you take a look at that picture for me Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential A Ive looked at it Are you in that picture A I am Is that Prince Andrew in the picture as well A It is MR PAGLIUCA I dont believe this has been produced to us in discovery by you MS McCAWLEY The picture MR PAGLIUCA Yes MS McCAWLEY It has MS MENNINGER Is it the same exact photograph MS McCAWLEY I believe so We will find one The picture has been produced a number of times MR PAGLIUCA Ive seen different iterations of this I dont believe I have ever seen this MS McCAWLEY We had them blow it up on a page so she could see it We could use an article While you are looking for that I Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential will skip ahead Hold that until we can find one that has the Bates range on it Do you recall Virginia being at your London town home A I do not Do you recall going to dinner with Prince Andrew Jeffrey Epstein and Virginia Roberts in London at any time A I do not Do you recall going to a place called Club Tramp with Prince Andrew Jeffrey Epstein and yourself and Virginia Roberts A I would just like to state for the record that Prince Andrew is a very famous person I know you are aware because you like to use him so often in your press stories please let me finish Were he at Tramp at any time that would be reported by the press I do not have any recollection of it and I doubt it actually happened You dont recall that Do you recall taking Virginia shopping when you were in London to buy an outfit to meet Prince Andrew Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential So Im directing your attention to the bottom two lines up from the bottom there is a flight MR PAGLIUCA Are you on MS McCAWLEY So this flight is from the one Im looking at I think its highlighted on your copy On the far corner on the date it says at the top and this would be the and then the are the two Im going to direct your attention to On that first one on the you will see the column reading PBI in the from column to TEB in the to column and you will see some initials you will see JE for Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential have an issue so with respect to this flight do you recall being on a flight in the going from Palm Beach to Teterboro A No I dont recall any specific flight Do you recall flying with Virginia on a flight with Emmy Taylor and Jeffrey Epstein at any time A I dont How often did you fly on a plane with a year old MR PAGLIUCA Objection to form and foundation A I have no idea what you are talking about other than friends of mine that had kids Did you regularly fly on Jeffreys plane with individuals who were under the age of MR PAGLIUCA Objection to the form and foundation A Can you repeat the question Did you regularly fly on Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Epsteins planes with individuals who were under the age of A I regularly flew on Jeffrey Epsteins airplane but I cannot testify as to flying with people under the age I dont believe that I did Why wouldnt you remember flying with a year old MR PAGLIUCA Objection to the form and foundation A How would I know one that she is how would you know that how do you know Im on the plane Are you saying you are not on this flight so this is a Palm Beach to Teterboro Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential obvious lie that you approached Virginia while she was under age at Mar-a-Lago MR PAGLIUCA Objection to the form and foundation A First of all we can all agree here all of you sitting here that the lies that you perpetrated in the press that she was and we should all agree now that that is fake a lie that was perpetrated between all of you to make the story more exciting can we agree on that That is not my question A Can we agree she was not the age she said and you put that in the press that is obviously manifestly absolutely totally a lie MS McCAWLEY I am going to put on the record Ms Maxwell very inappropriately and very harshly pounded our law firm table in an inappropriate manner I ask she take a deep breath and calm down I know this is a difficult position but physical assault or threats is not appropriate so no Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential pounding no stomping no thats not appropriate A Can we be clear I didnt threaten anybody MR PAGLIUCA Stop you made your record there is no dent in the table I dont see any chips Can we take a break now MS McCAWLEY I think its appropriate to take a break THE VIDEOGRAPHER Its and we are off the record Recess THE VIDEOGRAPHER Its now were starting disk No and we are back on the record Ms Maxwell how old was Virginia Roberts when you met her in Mar-a-Lago MR PAGLIUCA Objection to the form and foundation A I know today that she was years old Are you saying that its an obvious lie that Virginia traveled on Jeffrey Case Document Filed Page of MAGNA9 LEGAL SERVICES Page Maxwell Confidential Were there other flights that you recall flying on with Jeffrey Epstein that were on flights that where Dave Rogers was not the pilot A Dave Rogers was not always the pilot How many planes did Jeffrey Epstein have during the time you were with him MR PAGLIUCA Objection to the form and foundation A So you need to give me a date range During the time period of through when you left your employment which I think you said was in A So in the he had one plane and at some point in the he had two planes but I cant testify to anything past what happened to his planes after that Do you know what travel agency if any Jeffrey would use when he would send someone for example you or one of his other employees on a flight somewhere Did he use a particular travel agency to make those Case Document Filed Page of MAGNA9 LEGAL SERVICES Page ACKNOWLEDGMENT OF DEPONENT I do hereby certify that I have read the foregoing pages and that the same is a correct transcription of the answers given by me to the questions therein propounded except for the corrections or changes in form or substance if any noted in the attached Errata Sheet GHISLAINE MAXWELL DATE Subscribed and sworn to before me this day of My commission expires Notary Public Case Document Filed Page of MAGNA9 LEGAL SERVICES
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