Document 204-11

Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 2 of 21 Confidential Page 2 1 2 APPEARANCES: 3 On Behalf of the Plaintiff: 4 BOIES SCHILLER & FLEXNER, LLP 333 Main Street Armonk, New York 10504 BY: DAVID BOIES, ESQUIRE BOIES SCHILLER & FLEXNER,LLP 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 BY: MEREDITH SCHULTZ, ESQUIRE SIGRID MCCAWLEY, ESQUIRE SANDRA PERKINS, PARALEGAL FARMER JAFFE WEISSING EDWARDS FISTOS & LEHRMAN, P.L. 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 BY: BRAD EDWARDS, ESQUIRE PAUL G. CASSELL, ESQUIRE 383 South University Street Salt Lake City, Utah 84112 J. STANLEY POTTINGER, PLLC 49 Twin Lakes Road South Salem, New York 10590 BY: STAN POTTINGER, ESQUIRE On Behalf of Defendant: HADDON MORGAN FOREMAN Attorneys for Defendant 150 East 10th Avenue Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE LAURA A. MENNIGER, ESQUIRE Also Present: MAGNA LEGAL SERVICES DOJ-OGR-00003601 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 3 of 21 Confidential Page 3 1 2 THE VIDEOGRAPHER: This is DVD No. 3 1, Volume II, of the continued video 4 recorded deposition of Ghislaine Maxwell 5 in the matter Virginia Giuffre against 6 Ghislaine Maxwell, in the United States 7 District Court, Southern District of New 8 York. 9 10 This deposition is being held at 11 575 Lexington Avenue, New York, New 12 York, on July 22, 2016 at approximately 13 9:04 a.m. 14 My name is Rodolfo Duran. I am the 15 legal video specialist. The court 16 reporter is Leslie Fagin, and we are 17 both in association with Magna Legal 18 Services. 19 Will counsel please introduce 20 themselves. 21 MR. BOIES: This is David Boies, of 22 Boies, Schiller & Flexner, counsel for 23 plaintiff. 24 MS. SCHULTZ: Meredith Schultz, 25 from Boies Schiller & Flexner, counsel for plaintiff. MAGNA LEGAL SERVICES --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 4 of 21 Confidential Page 4 1 2 MR. EDWARDS: Brad Edwards, also 3 representing the plaintiff, Virginia 4 Giuffre. 5 MR. POTTINGER: Stan Pottinger, 6 also representing the plaintiff. 7 MR. CASSELL: Paul Cassell, from 8 Salt Lake City, Utah, also representing 9 Ms. Giuffre. 10 MR. PAGLIUCA: Jeff Pagliuca and 11 Laura Menninger, on behalf of Ms. 12 Maxwell. 13 And Ms. McCawley has also entered 14 the room, and we have an assistant from 15 Boies Schiller from the Fort Lauderdale 16 office here today as well today. 17 THE VIDEOGRAPHER: Will the court 18 reporter please swear in the witness. 19 G H ISLAINE MAXWELL L, 20 called as a witness, having been duly 21 sworn by a Notary Public, was 22 examined and testified as follows: 23 EXAMINATION BY 24 MR. BOIES: 25 Q. Good morning, Ms. Maxwell. --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 6 of 21 Confidential Page 54 G. Maxwell - Confidential 1 2 MAGNA LEGAL SERVICES DOJ-OGR-00003605 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 8 of 21 Confidential Page 56 G. Maxwell - Confidential 1 2 MAGNA LEGAL SERVICES DOJ-OGR-00003607 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 11 of 21 Confidential Page 86 G. Maxwell - Confidential 1 and foundation. 2 A. 3 4 5 6 7 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. I don't know. 11 Q. Did any of them give you massages? 12 A. No. 13 Q. 14 15 16 17 MR. PAGLIUCA: Objection to form 18 and foundation. Asked and answered. 19 A. No. 20 Q. Were they ever in the Virgin 21 Islands? 22 MR. PAGLIUCA: Objection to form 23 and foundation. 24 A. No. 25 MAGNA LEGAL SERVICES DOJ-OGR-00003610 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 12 of 21 Confidential Page 87 G. Maxwell - Confidential 1 2 MR. PAGLIUCA: Objection to form 24 and foundation. 25 MAGNA LEGAL SERVICES DOJ-OGR-00003611 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 15 of 21 Confidential Page 90 G. Maxwell - Confidential MAGNA LEGAL SERVICES DOJ-OGR-00003614 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 16 of 21 Confidential Page 91 G. Maxwell - Confidential it to something in the case. MR. BOIES: I think it's tied, but if you instruct her not to answer, it goes into the -- MR. PAGLIUCA: Meat grinder. BY MR. BOIES: Q. [REDACTED] A. Can you repeat the question? Q. [REDACTED] MR. PAGLIUCA: Same objection. A. No. Q. Other than yourself and the blond brunette that you have identified as having been involved in three-way sexual activities, with whom did Mr. Epstein have MAGNA LEGAL SERVICES DOJ-OGR-00003615 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 18 of 21 Confidential Page 93 1 G. Maxwell - Confidential 2 25 Q. Do you know MAGNA LEGAL SERVICES DOJ-OGR-00003617 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 20 of 21 Confidential Page 113 1 G. Maxwell - Confidential 2 Q. Let's just tie that down. It is 3 your testimony that you've never given 4 anybody a massage? 5 A. I have not given anyone a massage. 6 Q. You never gave Mr. Epstein a 7 massage, is that your testimony? 8 A. That is my testimony. 9 Q. You never gave a 10 massage is your testimony? 11 A. I never gave a massage. 12 13 Q. Did you, or to your knowledge, 14 Mr. Epstein pay for to go to 15 Thailand? 16 MR. PAGLIUCA: Objection to form 17 and foundation. 18 A. I am not aware. 19 Q. Do you know whether went to Thailand? 20 21 A. I have no knowledge of anything 22 like that. 23 Q. Did you ever give anyone 24 instructions as to how to give a massage? 25 MR. PAGLIUCA: Objection to form MAGNA LEGAL SERVICES DOJ-OGR-00003619 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 5 of 21 Confidential Page 53 G. Maxwell - Confidential MR. PAGLIUCA: Why don't we both stop making speeches. BY MR. BOIES: [REDACTED TEXT] --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 7 of 21 Confidential Page 55 1 G. Maxwell - Confidential 2 Epstein's home in Palm Beach? 3 MR. PAGLIUCA: Objection to form 4 and foundation. 5 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 9 of 21 Confidential Page 57 G. Maxwell - Confidential MR. PAGLIUCA: Objection to form and foundation. MR. PAGLIUCA: Objection to form and foundation. MAGNA LEGAL SERVICES DOJ-OGR-00003608 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 10 of 21 Confidential Page 85 G. Maxwell - Confidential only area that the witness was precluded from talking about in the first deposition. So that's where we're at. MR. BOIES: I think that directly misreads the judge's order, including where it says: Defendant is ordered to answer questions relating to defendant's own sexual activity with or involving Jeffrey Epstein, with or involving plaintiff, with or involving underage females, involving or including massage with individuals defendant knew to be or believed might become known to Epstein. MR. PAGLIUCA: All of it is preceded by the word sexual activity. MR. BOIES: I think your point of view is an interesting one, but we will see what the judge rules on it. BY MR. BOIES: MAGNA LEGAL SERVICES DOJ-OGR-00003609 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 13 of 21 Confidential Page 88 G. Maxwell - Confidential 1 2 9 Q. Were you aware of the presence of 10 sex toys or devices used in sexual activities 11 in Mr. Epstein's Palm Beach house? 14 A. No, not that I recall. --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 14 of 21 Confidential Page 89 G. Maxwell - Confidential 1 2 Q. Do you know whether Mr. Epstein 8 possessed sex toys or devices used in sexual 9 activities? 10 13 A. No. --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 17 of 21 Confidential Page 92 1 G. Maxwell - Confidential 2 sexual activities? 5 A. I wasn't aware that he was having 6 sexual activities with anyone when I was with 7 him other than myself. 8 Q. I want to be sure that I'm clear. 9 Is it your testimony that in the 1990s and 10 2000s, you were not aware that Mr. Epstein 11 was having sexual activities with anyone 12 other than yourself and the blond and 13 brunette on those few occasions when they 14 were involved with you? 15 A. That is my testimony, that is 16 correct. MAGNA LEGAL SERVICES DOJ-OGR-00003616 --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 19 of 21 Confidential Page 112 1 G. Maxwell - Confidential 2 ever see ? 3 A. I don't recall ever seeing her. 4 Q. 5 A. 6 Q. Did ever engage in any 7 sexual activity with Mr. Epstein? 8 A. I wouldn't know. I would assume 9 not, but I don't know. 10 Q. Do you have any reason to believe 11 that Mr. Epstein engaged in any sexual 12 activity with ? 13 MR. PAGLIUCA: Objection to form 14 and foundation. 15 A. I wouldn't know. 16 Q. Did you ever give a massage to 17 anyone other than Mr. Epstein at any of Mr. 18 Epstein's properties? 19 A. First of all, I never said I gave 20 Mr. Epstein a massage. 21 Q. I will ask that question if you 22 want, but I was focusing on people other than 23 Mr. Epstein right now. 24 A. I don't give massages. --- PAGE BREAK --- Case 1:20-cr-00330-PAE Document 204-11 Filed 04/16/21 Page 21 of 21 Confidential Page 193 G. Maxwell - Confidential If there are questions that I have instructed the witness not to answer and it later turns out the judge disagrees with my characterization, we will be back to revisit it, but we are done as far as I'm concerned. MR. BOIES: The deposition is not closed. There are a number of instructions not to answer. I think it is a fair point that if the court were to conclude that none of the questions that have been instructed need to be answered, we're not going to be continuing the deposition, barring some additional information coming to light. MR. PAGLIUCA: I think we agree then. THE VIDEOGRAPHER: The time is 2:51 p.m., and we are going off the record. (Time noted: 2:51 p.m.) MAGNA LEGAL SERVICES DOJ-OGR-00003620