Case 18-2868, Document 286, 08/09/2019, 2628248, Pagel of 55

EXHIBIT 

Case 18-2868, Document 286, 08/09/2019, 2628248, Page2 of 55

United States District Court
Southern District Of New York
--------------------------------------------------X

Plaintiff,
v.
Ghislaine Maxwell,
Defendant.
-----------------------------------------------X

...............................................

Virginia L. Giuffre,

15-cv-07433-RWS

DEFENDANT GHISLAINE MAXWELL’S
INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I.

IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq.
Haddon, Morgan & Foreman, P.C.
150 E. 10th Ave.
Denver, CO 80203
303-831-7364
LMenninger@HMFLaw.com
Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre
c/o Sigrid S. McCawley, Esq.
Boies, Schiller & Flexner LLP
401 East Las Olas Boulevard, Suite 1200

 Case 18-2868, Document 286, 08/09/2019, 2628248, Page3 of 55

Miami, Florida 33301
(954) 356-0011
smccawley@bsfllp.com
Ms. Giuffre is the Plaintiff and has knowledge concerning the matters at issue in
her Complaint, including the events of 1996-2015 and the publication of
statements in the press in 2011-2015.
3. Philip Barden
Devonshires Solicitors LLP
30 Finsbury Circus
London, United Kingdom
EC2M 7DT
DX: 33856 Finsbury Square
(020) 7628-7576
Philip.Barden@devonshires.co.uk
Mr. Barden has knowledge concerning press statements by Plaintiff and
Defendant in 2011-2015 at issue in this matter.
4. Paul Cassell
College of Law, University of Utah
383 South University Street
Salt Lake City, UT 84112
801-585-5202
paul.cassell@law.utah.edu
Mr. Cassell has knowledge concerning press statements by Plaintiff, Plaintiff’s
court pleadings, and Plaintiff’s sworn testimony.
5. Alan Dershowitz
c/o Richard A. Simpson, Esq.
WILEY REIN, LLP
1776 K Street NW
Washington, D.C. 20006
(202) 719-7000
Mr. Dershowitz has knowledge concerning Plaintiff’s false statements to the
press, in court pleadings, and in sworn testimony, at issue in this matter.
6. Bradley Edwards
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
425 N. Andrews Ave., Suite 2
Ft. Lauderdale, FL 33301
(954) 524-2820
brad@pathtojustice.com

2

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Dated: February 24, 2016.

Respectfully submitted,

s/ Laura A. Menninger
Laura A. Menninger (LM-1374)
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax:
303.832.2628
lmenninger@hmflaw.com
Attorney for Ghislaine Maxwell

CERTIFICATE OF SERVICE
I certify that on February 24, 2016, I electronically served this DEFENDANT
GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the
following:
Sigrid S. McCawley
BOIES, SCHILLER & FLEXNER, LLP
401 East Las Olas Boulevard, Ste. 1200
Ft. Lauderdale, FL 33301
smccawley@bsfllp.com
s/ Laura A. Menninger
Laura A. Menninger

7

  

 

Case 18-2868, Document 286, 08/09/2019, 2628248, PageS of 55

EXHIBIT OO

To: P3996 0f 55

From: Virginia Giuffre
Sent: Thur 5"12/2011 2:21 :43 AM

luportanoe: Normal
Subject: Re: Good News!!
Received: Thur 5/12/2011 2:21:43 AM

Thanks again Shazza, I'm bringing down the house with this book!?
xoxo Jenna

011 Wed, 11/5/11. Sha ?Sharon. y. uk> wrote:

From; Sha rou.Clturchc .co. uk maj .co. uk>
Subject: Re: Good News?

To: "Virginia Giu??rc" 
Received; W'?duesday, 1] May. 2011, 4.17 PM

Don't forget Alan Detshowitz. JE's buddy and lawyer..good name for your
pitch as he rapped Claus von Bulow and a movie was made about that
was Revetsal of Fortune. We all suspect Alan is a pedo and tho
no proof of that, you probahiy met him when he was hanging put .IE

 

 

 

 

 

 

 

 

 

 

 

 

 

lFrom: 
- 

MW Giu??rc vac?1


lTo: 

. - "i
 Sharon Churcher
'l

[Date
I 
I
-- I
I 23:00 
. I
l"



I

Good News?


Q~nuo? --

I I
 Hi Sharon> 



chUo gorgeous, I hope this message comes to you on a. bright} sunny dayHH
took your advice about what to offer Sandra. and she accepted. Were 
[drawing up a contract through her agent right now and getting busy to 

Com-nght Pmlecled Mutemtl
CONFIDENTIAL 

 

 

 

 

 

18-2 68 Document 286,, 08/09/2019, 2628248, Page7 of 55

. Gas?i . .
Im}: dcadimc. Just won 1 youhmc any minimization on yciu ham when I
2:11:11 were doing intewiews about the IE. story: I wanted to put the I
Iriames of some of these asshoies, mops, meant to say, IledO'F-i: that .E 
Ismt mu: to. With everything going on my brain fccis like mush and it wm?dl
lbs: 3 great dcai I
IHaving fun sweetie? I

IThanks? I
Ileaml I

 

wan-A JI-Irwu-u warm-I'?

 

i?his emaii has been scanned by the Messagaidabs Emaii System
Far more information please visit 



 

 

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uimr please noii 1" ihC sender immc?iaicly and then ii li?m?n your system. Phase be advised that {he views a?d
opinions in this c-maii may not re?ect the views and opinions of?ssuciatcd Newspapers Lim?cd or any of
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Associated Newspapers Ltd. Registered Of?ce: No?hciiffe House, '2 Derry Remington, oudoni 8 

Registered No 8412.; England,

I Cupyrighl i?riilmied Mumriaii




To: Sharon 2628248, P3998 0? 55

From: Virginia Giuffre
Sent: Wed 61812011 11:19:55 PM

Importance: Normal

Subject: Re: Virginia Roberts

Received: Wed 5/812011 11:19:55 PM
Hi Buddy,

You are absolutely biting is an understatement of the century??

We didn?t. have any trouble with spiders or anything like that it was more my daughter that gave everyone a
spook! She wandered off when I turned my back to look at homemade jam and found her outside in the bush chasing the
rods? My Own miniatmL? 

My ?ngers and toes me crossed and I'm thinking positive? 5!

Much Love,
Jenna

On W'ed, 816/11, Sharon ureher wrote.

From~ Sharon 
Subject: Re: Vir inia Roberts
in 
Received: Wednesday, 8 June, 2011, 11:59 AM
Rum. Yen lle?i?Tf" :?nmfte .. but did {~32 item: to duck urz-zlet wider They Wd?it: same-g hcween treat mien 3: went.
KL: Litre-:1: it is; .1 nailbiung; art-1n but remember he 13 only me: 533mm 1-111. vex ?16113 it wind; [8 good. .ii?ne Lin-:31: go for it. there
an: mhenz. Dii?i?eren-r. tea-ties. When (he. you tend 


Midi}

From. Virginie (iinffi'e

Sent: 11:00.03. 2011 01327 AM
To Sharon C'luuehcr

Subject: Re: Roberts

Dearest Shazza,
Once again you have really outdone MANY, 

I took the kids to the Australian Walkabout Park today and enjoyed the scenic walks and many kangaroos. Rob and I hat
good chuckle about our adventures at the Reptile Park with you and Mike times! !3 Have you heard from Mike? I
hope he is well and if you ever speak, tell him I sent 21 BK) hello.

Ireally appreciate evelything you have helped with. as a friend you have gone beyond the call ofdutyl 

I hope we hear back from Jarred sooull

xomxo Jenna

On Wed, 8/6/11, Sharon ('Jhurcher wrote:

From: Sharon Churchei? 

Subject: Virginia Roberts

To: "jawedhalperin agent ?ari'ed?c'lloh'cctiveenmom <jarrcd@ohjcetivcentcomf'?

Cc: "Virginia Giuffre" 
Received: Wednesday. 8 June, 201 1. 2:31 AM

 
 

Comrighl Pmlecled Material
(IINFIDENTML Glumz?rmozg

 

 

Case 18-2868, Document 286, 08/09/2019, 2628248, Page9 of 55
Hi Jarred

Hopefuily you have Virginia?a hank pitch by new,

She has some amazing names; which she can share with you in confidence and i think she also has a human interest
story that cauld appeal to the Omani/female set as welt as the Wall Streetere whe teltdw Epstein a hedge fund king.

Here are a few of our stories about Virginia, plus some examples of the massive US and other internationai media
pickup. Vanity Fair are riding a piece i believe in theirAugust issue. The FBI have reopened the Epstein case due to
Virginia?s revelations. I also am attaching a link to a NY Magazine profile of Epstein written before his world
combusted. The FBI believe he was essentially running a private and imbue brothel for some at the world's richest
and meat in?uential men.

He got off the ?rst time round after retaining Kenneth Starr (who witchhuntecl Biil Clinton) and Alan Dershowitz (van
Butdw?s appeal lawyer, who inspired the movie Reversal of Fortune). The US Justice Dept is investigating corruptien
altegations against at. least one prosecutor involved in the case.

 

Best regards,

Sharon

tum-gr demurrer an .ti?i wraurtr?f 
mead? the? ism?dmt?n-unn t??l?fi??i??zilf??ii 1?5; 3935.353 :23 ?ill ?Mn

nitrati-ixnranrarz2;ear i: menu tent nae eat. Bei- fir; 

 

Miner?..-

 

izttp. first innai tea ie1vvt'aetz. 321:2; ?3'3 math."- Went: (This one, in Forbes Magazine, seems to require subscribing but you
get the gist)


latte. emanate; ee- it? denied are? a 32.3% ?333994

http:tf i139 1 2i

 

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Registered No 84121 England,

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EXHIBIT PP

Agren Document
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IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Civil Action No. 15-cv-07433-RWS
__________________________________________________
CONFIDENTIAL VIDEO DEPOSITION OF
VIRGINIA GIUFFRE, VOLUME II
November 14, 2016
__________________________________________________
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
__________________________________________________
APPEARANCES:
BOIES, SCHILLER & FLEXNER LLP
By Sigrid S. McCawley, Esq.
401 East Las Olas Boulevard
Suite 1200
Fort Lauderdale, FL 33301
Phone: 954.356.0011
smccawley@bsfllp.com
Appearing on behalf of the Plaintiff

VIRGINIA GIUFFRE VOLUME II 11/14/2016

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1
2
3
4
5
6

APPEARANCES:

(Continued)

HADDON, MORGAN AND FORMAN, P.C.
By Laura Menninger, Esq.
Jeffrey S. Pagliuca, Esq.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
lmenninger@hmflaw.com
jpagliuca@hmflaw.com
Appearing on behalf of the
Defendant

7
8

Also Present:
Ann Lundberg, Paralegal
Maryvonne Tompkins, Videographer

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
VIRGINIA GIUFFRE VOLUME II 11/14/2016

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Pursuant to Notice and the Federal Rules

2

of Civil Procedure, the continued video

3

deposition of VIRGINIA GIUFFRE, called by Defendant,

4

was taken on Monday, November 14, 2016, commencing at

5

8:04 a.m., at 150 East 10th Avenue, Denver, Colorado,

6

before Pamela J. Hansen, Registered Professional

7

Reporter, Certified Realtime Reporter and Notary

8

Public within Colorado.

9

* * * * * * *
I N D E X

10
11

VIDEO DEPOSITION OF VIRGINIA GIUFFRE, VOLUME II

12

EXAMINATION

13

By Ms. Menninger

PAGE
354

14
15
16
17
18
19
20
21
22
23
24
25
VIRGINIA GIUFFRE VOLUME II 11/14/2016

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INDEX OF EXHIBITS (continued)

2

INITIAL
REFERENCE

3

DESCRIPTION

4

Exhibit 1

Settlement Agreement and General
Release

355

Exhibit 2

List of names

370

Exhibit 3

Photocopy of photograph

408

Exhibit 4

Photocopy of photograph, with
attachments

411

Exhibit 5

Photocopy of photograph, with
attachments

417

Exhibit 6

Photocopy of photograph, with
attachments

423

12

Exhibit 7

Statements

437

13

Exhibit 8

History of education, with
attachment

462

Exhibit 9

Application for Employment,
with attachment

474

Exhibit 10

The Great Outdoors Community
Services Association, Inc.
Termination Form, with
attachments

481

Exhibit 11

7/6/2016 letter to Schultz
from Hayek, with attachments

484

Exhibit 12

Patient Registration
Information, with attachments

490

Exhibit 13

CVS Prescription Records
document, 7/29/2016, with
attachment

502

Exhibit 14

Affidavit of Custodian of
Records, Walgreen Company,
with attachments

507

5
6
7
8
9
10
11

14
15
16
17
18
19
20
21
22
23
24
25
VIRGINIA GIUFFRE VOLUME II 11/14/2016

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INITIAL
REFERENCE

DESCRIPTION
2

Exhibit 15

Patient Health Summary, Clifton
Beach Medical & Surgical,
printed on 6/28/2016

512

Exhibit 16

Portions of deposition transcript
of Virginia Giuffre taken
May 3, 2016

533

Exhibit 17

Amendment/Errata Sheet signed
May 31, 2016 by Virginia Giuffre

540

8

Exhibit 18

Ad for Mar-a-Lago Club

548

9

Exhibit 19

The Mar-a-Lago Club, L.C.
Employment Policies, October 28,
1995

549

Exhibit 20

Page from the Mar-a-Lago Club
Employment Policies, Revised
10/2001

550

3
4
5
6
7

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

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didn't see them take pictures of the backs of them.

2

I'm not too sure who.

3

Q

You don't remember sending to them a

4

photograph that included this wood around another

5

photograph?

6

A

No.

7

Q

Okay.

8

You have mentioned a journalist by

the name of Sharon Churcher.

9

A

Yes.

10

Q

You are aware that Sharon Churcher

11
12

published news stories about you?
A

Yes.

13

MS. MCCAWLEY:

14

Go ahead.

15

Q

Objection.

(BY MS. MENNINGER)

Is anything that you

16

have read in Sharon Churcher's news stories about you

17

untrue?

18

A

I think Sharon did print some things that

19

I think she elaborated or maybe misheard.

20

mean, if you have a specific document to show me, I'd

21

love to look at it and read it and tell you what I

22

think.

23

Q

But, I

Is there anything, as you sit here today,

24

that you know of that Sharon Churcher printed about

25

you that is not true?
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A

Not off the top of my head.

If you show

2

me, like, a news clipping article or something, I can

3

definitely read it for you.

4

Q

Is there anything that you know of that

5

Sharon Churcher has printed about Ghislaine Maxwell

6

that is not true?

7
8
9

A

No, not off -- no, not off the top of my

head.
Q

Is there anything that you recall saying

10

to Sharon Churcher that she then printed something

11

different than what you had said to her?

12

A

Yeah, I've read stuff.

I mean, I just --

13

I can't remember what, but I read something that I

14

think was, Oh, she got that wrong.

15

an exact example off the top of my head.

16
17
18

Q

I can't remember

Did you ever complain to Sharon Churcher

about things that she got wrong?
A

I didn't see a point.

I might have, but

19

I -- I didn't see a point really because it's already

20

printed, you know.

21

Q

You had a fairly voluminous set of

22

communications with Sharon Churcher by e-mail,

23

correct?

24
25

MS. MCCAWLEY:
A

Objection.

Voluminous, like a lot of them?
VIRGINIA GIUFFRE VOLUME II 11/14/2016

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Q

(BY MS. MENNINGER)

2

A

Yes.

3

Q

And during any of those communications, do

Yes.

4

you know whether she printed things about you after

5

you had any of those communications?

6
7

A

MS. MCCAWLEY:

Objection.

I don't know.

I know a lot of stuff was

8

printed, and I never really stopped to read who

9

printed the article, or wrote the article, I should

10
11
12

say.

Sorry.
Q

(BY MS. MENNINGER)

I'll show you

Defendant's Exhibit 7.

13

(Exhibit 7 marked.)

14

THE DEPONENT:

15

Okay.

Q

Thank you.

(BY MS. MENNINGER)

I'll let you read

16

through the statements on the first page there, and

17

if there is anything that is not absolutely true,

18

just put a check by it and we'll come back to it.

19

A

It's not very clear how she wrote it.

"I

20

flew to the Caribbean with Jeffrey and then Ghislaine

21

Maxwell went to pick up Bill in a huge black

22

helicopter that Jeffrey had bought her."

23

That wasn't an eyewitness statement.

24

Like, I didn't see her do it.

25

who told me about that; that she's the one who flew

Ghislaine was the one

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Bill.
Q

All right.

If you just want to put a

3

check by it, then we'll just come back and talk about

4

each one.

5

A

Okay.

6

Q

Just to move things along.

7

A

Okay.

8

Q

All right.

9

I have made three checkmarks.

MS. MCCAWLEY:

And I just -- before you

10

continue, I just want to identify for the record,

11

since this doesn't have any identifiers on it, are

12

you representing that these are statements from

13

Sharon Churcher?

14

MS. MENNINGER:

15

anything.

16

these statements.

17

not true.

18
19
20

Q

I'm not representing

I'm asking the witness questions about
I asked her is anything on here

That's all I asked her.
(BY MS. MENNINGER)

So which ones did you

put checkmarks by, Ms. Giuffre?
A

I'd have been -- I'm sorry.

"I'd have

21

been about 17 at the time.

22

with Jeffrey and then Ghislaine Maxwell went to pick

23

up Bill in a huge black helicopter that Jeffrey had

24

bought her."

25

Q

Okay.

I flew to the Caribbean

And what else did you put a check

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by?

2

A

"I used to get frightened flying with her

3

but Bill had the Secret Service with him and I

4

remember him talking about what a good job" --

5

sorry -- "job she did."

6
7

Q

Okay.

A

"Donald Trump was also a good friend of

by?

8
9

And what else did you put a check

Jeffrey's.

He didn't partake in any sex with any of

10

us but he flirted with me.

11

Jeffrey, 'you've got the life.'"

12
13

Q

He'd laugh and tell

Other than the three you've just

mentioned --

14

A

Yeah.

15

Q

-- everything else on here is absolutely

16

accurate?

17

MS. MCCAWLEY:

18
19

A

Yes.

Objection.

Well, to the best of my

recollection, yes.

20

Q

(BY MS. MENNINGER)

All right.

What is

21

inaccurate about, "I'd have been about 17 at the

22

time.

23

Ghislaine Maxwell went to pick up Bill in a huge

24

black helicopter that Jeffrey had bought her"?

25

I flew to the Caribbean with Jeffrey and then

A

Because it makes it kind of sound like an
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2
3
4

eyewitness thing.
Q

Okay.

Did you say that statement to

Sharon Churcher?
A

I said to Sharon that Ghislaine told me

5

that she flew Bill in the heli- -- the black

6

helicopter that Jeffrey bought her, and I just wanted

7

to clarify that I didn't actually see her do that.

8

heard from Ghislaine that she did that.

9

Q

You heard that from Ghislaine, and then

10

you reported to Sharon Churcher that you had heard

11

that from Ghislaine.

12

A

13
14

Correct.
MS. MCCAWLEY:

A

Objection.

I heard a lot of things from Ghislaine

15

that sounded too true -- too outrageous to be true,

16

but you never knew what to believe, so...

17

Q

(BY MS. MENNINGER)

Okay.

And after

18

Sharon Churcher printed what she said you said, did

19

you complain to her that it was inaccurate?

20

A

I might have verbally with her, but again,

21

I didn't see a point in making a hissy over it

22

because what was done was done.

23

printed.

24
25

Q

I

She had already

What was inaccurate about, "I used to get

frightened flying with her but Bill" said -- "had the
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Secret Service with him and I remember him talking

2

about what a good job she did"?

3

A

I just don't remember saying that to her.

4

I don't remember saying I remember him talking about

5

what a good job she did.

6

Q

All right.

7

A

I just don't remember that at all.

8

Q

Okay.

9

And I guess, just to be clear, my

questions wasn't do you remember saying this to

10

Sharon Churcher; my question is, is that statement

11

accurate?

12
13
14

MS. MCCAWLEY:
Q

(BY MS. MENNINGER)

A

Yes.

16

Q

Okay.

18
19
20
21

Did you used to get

frightened flying with her?

15

17

Well, objection.

Did Bill have the Secret Service

with him?
A

They were there, but not like on the --

not where we were eating.
Q

Do you remember Bill talking about what a

good job she did?

22

A

I don't remember that.

23

Q

So what is inaccurate about that

24
25

statement?
A

I just -- it's inaccurate because I don't
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remember him talking about what a good job she did.

2

I don't remember that.

3
4

Q

Does it inaccurately suggest that Bill had

the Secret Service with him on a helicopter?

5
6

MS. MCCAWLEY:
A

Objection.

Well, not being an eyewitness to it, I

7

wouldn't be able to tell you.

8

I don't know.

9
10
11

Q

(BY MS. MENNINGER)

I can't tell you what

And do you believe you

said that statement to Sharon Churcher?
A

I mean, Sharon and I talked a lot, and if

12

she misheard me or just wrote it in the way that she

13

thought she should, I have no control over that.

14

I'm not too sure.

15

Q

Did she record your interviews?

16

A

Some of them.

So

Some of them she didn't.

17

mean, we, like -- we, like, met for like a week, and

18

we spent a lot of time together, and then even after

19

that we just continued, like, kind of a friendship.

I

20
21

Q

All right.

last statement on that page?

22

A

23

Jeffrey's."

24
25

What's inaccurate about the

"Donald Trump was also a good friend of
That part is true.
"He didn't partake in any" of -- "any sex

with any of us but he flirted with me."
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that he didn't partake in any sex with us, and but

2

it's not true that he flirted with me.

3

never flirted with me.

4

Then the next sentence is, "He'd laugh and

5

tell Jeffrey, 'you've got the life.'"

6

that to her.

7
8

Donald Trump

Q

I never said

When you say, "he didn't partake in any

sex with any of us," who is "us"?

9

A

Girls.

10

Q

How do you know who Donald Trump -- Trump

11
12

Just --

had sex with?
A

Oh, I didn't physically see him have sex

13

with any of the girls, so I can't say who he had sex

14

with in his whole life or not, but I just know it

15

wasn't with me when I was with other girls.

16
17
18
19

Q

And who were the other girls that you were

with in Donald Trump's presence?
A

None.

There -- I worked for Donald Trump,

and I've met him probably a few times.

20

Q

When have you met him?

21

A

At Mar-a-Lago.

My dad and him, I wouldn't

22

say they were friends, but my dad knew him and they

23

would talk all the time -- well, not all the time but

24

when they saw each other.

25

Q

Have you ever been in Donald Trump and
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Jeffrey Epstein's presence with one another?

2

A

No.

3

Q

What is the basis for your statement that

4

Donald Trump is a good friend of Jeffrey's?

5
6

A

Jeffrey told me that Donald Trump is a

good friend of his.

7

Q

But you never observed them together?

8

A

No, not that I can actually remember.

9

I

mean, not off the top of my head, no.

10

Q

When did Donald Trump flirt with you?

11

A

He didn't.

12

Q

Did you ever see Donald Trump at Jeffrey's

13

That's what's inaccurate.

home?

14

A

Not that I can remember.

15

Q

On his island?

16

A

No, not that I can remember.

17

Q

In New Mexico?

18

A

No, not that I can remember.

19

Q

In New York?

20

A

Not that I can remember.

21

Q

All right.

If you could turn to the

22

second page and read through those.

23

any of those are inaccurate.

24

them and then we'll come back.

25

A

Let me know if

Just put a check by

Okay.
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MS. MCCAWLEY:

Before you go, Virginia,

2

I'm going to object to the use of the second page of

3

this document.

4

no source reference to it, so it's entirely unclear

5

where this has come from.

There's no time frame on it.

6

Q

(BY MS. MENNINGER)

7

A

Yes.

8

Q

Okay.

9
10

Okay.

There's

Are you done?

What's the first one you've put a

check by?
A

"The hammock photo was all over the

11

houses," in parentheses.

12

sorry, "Bill Clinton and Andrew," in parentheses,

13

"had to have seen it."

14

And Bill Clinton and -- I'm

"All over the houses" is not my statement

15

and an exaggeration.

16

the houses.

17

conversation correctly, she asked, Could have Bill

18

Clinton and Andrew seen the picture?

19

Yes, it's possible that they could have seen it.

20

They did have that picture in

And I believe, if I remember the

And I said,

So, I mean, it's just that -- it's not

21

that it's totally inaccurate.

22

journalist writing, had to have seen it.

23

mean they saw it.

24

front of them, they would have seen it.

25

Q

I just think it's like
It doesn't

I just think that if it was in

So she told you that -- you told her that
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the photograph was in the houses -- houses?

2

A

Yes.

I know he had it in New York on his

3

desk.

4

it in the Caribbean.

5

in New Mexico.

I know he had it in Palm Beach.

I know he had

And I don't know if he had it

I can't remember New Mexico.

Maybe.

6

Q

Where in Palm Beach was the photograph?

7

A

The massage room.

8

Q

Was that -- you did not say that they --

9
10
11
12
13
14

it was all over the houses?
A

Correct.

All over the houses would imply

that it's everywhere in the house, so...
Q

You did not say that Andrew and Clinton

had to have seen the photograph?
A

Correct.

I -- it was more of a, if they

15

were in front of it, they would have seen it, kind of

16

a thing.

17

like, had to have seen it.

18
19
20
21

Q

All right.

But it wasn't,

What's the next statement that

you put a check by?
A

I'm sorry, excuse me.

My kids shared a

beautiful cough with me again.

22
23

I'm not saying it right.

"I spent four years as a millionaire's
personal masseuse."

24

Q

What is inaccurate about that statement?

25

A

We now know, according to the timelines
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that Mar-a-Lago was able to provide for us, that it

2

was not four years.

3

Q

How many years was it?

4

A

More like 2-1/2, I think, if I'm right, or

5

two.

6

the two period.

7
8

I'm sorry, I'm really bad at math.

Q

But yes,

What's the next statement that you have

put a check by?

9

A

"I was a pedophile's dream."

I think she

10

took that out of context and made that her own little

11

headline.

12

Q

Did you say that to her?

13

A

I said something along the line like, I --

14

the -- the pedos loved me because I would do

15

everything that they wanted for them.

16

that -- yeah, I -- I know she made that line up

17

herself, the pedos -- pedophile's dream.

But do I think

18

Q

What's the next one you put a check by?

19

A

I put a question mark next to the next

20

one.

21

with her family."

22

to.

23
24
25

It says, "Three years later she was reunited
I don't know what that pertains

I don't know what timeline that means.
Q

Was there a period of three years where

you were not with your family?
A

There's been longer periods than that
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that -- when I wasn't with my family.

2

mean, I don't understand where that comes from.

3

"Three years later she was reunited with her family."

4
5

Q

Prior to 2002, was there a period of three

years where you were not with your family?

6

A

No.

7

Q

Okay.

8
9
10
11
12

That's what I

Did you say to Sharon Churcher,

three years later, she was reunited with her family?
A

That's what I don't understand.

I don't

even know what that time periods pertains to.
Q

Do you recall saying that to Sharon

Churcher?

13

A

No.

14

Q

What's the next one you put a check by?

15

A

"After about two years he started to ask

16

me to entertain his friends."

17

Q

What's wrong with that statement?

18

A

It wasn't two years.

19

I don't know where

she got that from.

20

Q

Okay.

21

A

Like, I can't give you an exact time

How long was it?

22

period, but it wasn't right in the beginning.

23

after my training, or so to speak training.

24

mean, my best guesstimate would be anywhere between

25

four to six months.
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Q

So you did not say to Sharon Churcher,

2

"After about two years he asked me to entertain his

3

friends"?

4

A

Correct.

5

Q

What's the next one you put a check by?

6

A

That's it.

7
8
9
10
11
12

That's all I put a checkmark

next to.
Q

So the rest of these are absolutely

accurate?
A

Nothing a journalist writes is absolutely

accurate, but it's -- it sounds accurate, yes.
Q

Do you recall Jeffrey Epstein saying to

13

you, "I've got a good friend and I need you to fly to

14

the island to entertain him, massage him and make him

15

feel how you make me feel"?

16

MS. MCCAWLEY:

17

Go ahead.

18

A

Objection.

I do remember him saying that, and I think

19

that's more of a general- -- generalization for all

20

the times that I was sent to the -- where is this --

21

the island to entertain people.

22

quote that she made but from my words saying that's

23

what he said to me when I had to go be with these

24

people that he sent me to.

25

Q

(BY MS. MENNINGER)

And that would be a

Did you say that

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sentence to her?

2

MS. MCCAWLEY:

3
4

A

Objection.

I -- I can't remember.

Like I said, I

think it's more of a generalization.

5

Q

(BY MS. MENNINGER)

6

A

Yes.

7

Q

Did you meet Heidi Klum?

8

A

Yes.

9

Q

Did you meet Naomi Campbell?

10

A

Yes.

11

Q

Did you go on a six-week trip with Epstein

12

Did you meet Al Gore?

in 2001?

13

A

Yeah.

14

Q

When in 2001 did you go on a six-week trip

15

Yes.

Sorry.

with him?

16

A

I don't remember exactly when it was, but

17

it's that -- it's the one where we went to Tangier,

18

Morocco, England.

19

went.

20

I can't remember where else we

France.
Q

Did the FBI tell you that Epstein had

21

hidden cameras watching you the entire time, even

22

when you were in the bathroom?

23

A

Yes.

24

Q

Did the FBI tell you "Everything he did

25

was illegal because I was under age"?
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A

Yes.

2

Q

Who in the FBI told you that?

3

A

Whichever agent I was talking to.

4

Q

Which agent were you talking to?

5

A

I can't remember.

I know I was talking to

6

Jason Richards, and there was a girl, I think -- I

7

want -- I want to say her name was Christina Pryor,

8

just off the top of my head.

9

was two other agents actually at the consulate

10

building.

And then I think there

I don't remember their names.

Very hazy.

11

Q

When was this conversation with the FBI?

12

A

After Sharon printed the articles, the

13

first articles that came out.

14

she printed, but when the first articles came out,

15

after that the FBI contacted me.

16

Q

I don't know how many

And was the statement that the FBI told

17

you "Everything he did was illegal because I was

18

under age," in response to you telling them that you

19

were age 15 when you met Jeffrey?

20
21
22

MS. MCCAWLEY:
A

Objection.

Well, that was the closest proximity I had

to go off of.

23

Q

(BY MS. MENNINGER)

24

A

So, yes.

25

Okay.

Although I still was under age,

I mean, even if I was 16 and 17.
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1

Q

Okay.

And then if you could do the last

2

page, same way; a check by anything that's not

3

absolutely accurate.

4

MS. MCCAWLEY:

Okay.

I'm going to object

5

to this as the last page has no identifier of time or

6

source on it.

7

A

Okay.

8

Q

(BY MS. MENNINGER)

9
10

I'm ready.
All right.

Which ones

are inaccurate?
A

The first one is, "Virginia got a

11

part-time job as a changing room assistant."

12

full-time person there.

I was a

Sorry.

13

Q

Okay.

14

A

Again, I don't remember that exact

So did you say that to Sharon?

15

conversation, but I know it was a full-time job,

16

and -- I mean, full-time as in the, you know, the 9

17

to 5 or whatever hours it was, so it wasn't

18

part-time.

19

that we had.

20
21
22

Q

I don't remember the exact conversation

Okay.

What's the next thing you put a

check by?
A

I put a question mark next to, "Another

23

lady led me into Jeffrey's bedroom.

24

me straight through into the massage room."

25

The lady walked

I have no idea what circumstance that
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pertains to.

2

don't even know what other lady she's talking about.

3

So...

4
5

Q

Again, I don't know what that means.

So you don't recall saying that to Sharon

Churcher?

6

A

Correct.

7

Q

Okay.

8

I

I don't even know what it means.

What's the next one you have a

check by?

9

A

"Afterwards, she was given two $100 bills

10

and told to return the next day.

11

beginning of the four years she spent with Epstein."

12
13

Q

All right.

That was the

What's wrong about that

statement?

14

A

Well, again, I just want to say that the

15

four years was inaccurate based upon memory and not

16

an actual timeline that we were able to get.

17
18

Q

Did you say that to Sharon Churcher, that

it was four years?

19

A

I don't know if I said that to her or --

20

oh, yeah, did I tell her it was four years?

21

did.

Yes, I

I'm sorry.

22

Q

Okay.

23

A

Well, this one is a question mark again.

What else did you put a check by?

24

"Radar online has obtained exclusive diary entries of

25

a Teen Sex Slave."
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It wasn't really a diary.

It was, like, I

2

don't know how many pages of something that I wrote,

3

and Sharon used it, so...

4

Q

5

entry?

6

A

She knew it wasn't a diary entry.

7

Q

Okay.

8

A

Yes.

9

Q

What's the next one you have a checkmark

A

"I also saw Prince Andrew at a Ranch in

10
11
12

Did you tell Sharon it was your diary

No.

Were you a teen sex slave?

by?

New Mexico."

13

Q

Did you tell that to Sharon Churcher?

14

A

No.

And I think it's a mistake.

Maybe

15

she meant somewhere else, but because we had been

16

talking about so much, maybe she just put New Mexico.

17

I don't think Sharon intentionally lied on any of

18

these.

19

period of a week, and then after that we had phone

20

conversations, and so on and so forth, that some of

21

the information just got misheard or mishandled, or

22

whatever.

I just -- I think we talked so much over a

23

Q

And what was printed was inaccurate?

24

A

Was that printed?

25

I don't -- I don't

remember reading that in the papers, but if it was
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1
2
3
4

printed it's inaccurate.
Q

Do you recall reading any of the ones that

you put a checkmark by in the papers?
A

There's been so much printed, it's hard

5

for me to remember.

6

stuff I read before.

7
8

Q

I mean, yes, it does sound like

When you spoke with Sharon Churcher, you

agreed to waive your anonymity, right?

9

A

I did.

10

Q

Why did you agree to do that?

11

A

I felt it was time for me to tell my

12

story.

13

forward.

14

that it would be good for other people to hear what's

15

going on, how it's happening, how vulnerable other

16

girls can be and not even know the damage that it

17

causes later in life.

18

the right thing to do to come forward.

I felt it was a good time for me to come
I had done so much healing, and I thought

And I just thought it would be

19

Q

You authorized her to publish your name?

20

A

I did.

21

Q

And your photograph?

22

A

Yes.

23

Q

In 2011?

24

A

I think that was the year, yes.

25

Q

You posed for photographs with her,
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1

I, VIRGINIA GIUFFRE, do hereby certify that

2

I have read the foregoing transcript and that the

3

same and accompanying amendment sheets, if any,

4

constitute a true and complete record of my

5

testimony.

6

____________________________
Signature of Deponent

7

( ) No amendments
( ) Amendments attached

8
9
10
11

Acknowledged before me this _______ day
of _____________, 20___.

12
13

Notary Public:

___________________

14

My Commission Expires:

___________

15

Seal:
16

PJH
17
18
19
20
21
22
23
24
25
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1

STATE OF COLORADO)

2

)

3

COUNTY OF DENVER )

4

ss.

REPORTER'S CERTIFICATE

I, Pamela J. Hansen, do hereby certify that

5

I am a Registered Professional Reporter and Notary

6

Public within the State of Colorado; that previous to

7

the commencement of the examination, the deponent was

8

duly sworn to testify to the truth.

9

I further certify that this deposition was

10

taken in shorthand by me at the time and place herein

11

set forth, that it was thereafter reduced to

12

typewritten form, and that the foregoing constitutes

13

a true and correct transcript.

14

I further certify that I am not related to,

15

employed by, nor of counsel for any of the parties or

16

attorneys herein, nor otherwise interested in the

17

result of the within action.

18
19
20

In witness whereof, I have affixed my
signature this 23rd day of November, 2016.
My commission expires September 3, 2018.

21
22
23

_______________________________
Pamela J. Hansen, CRR, RPR, RMR
216 - 16th Street, Suite 600
Denver, Colorado 80202

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 Case 18-2868, Document 286, 08/09/2019, 2628248, Page40 of 55

Epstein did invite two young brunettes to a dinner which he gave on his Caribbean island for Mr.
Clinton shortly after he left of?ce.

I'd have been about 17 at the time. I ?ew to the Caribbean with Jeffrey and then Ghislaine
Maxwell went to pick up Bill in a huge black helicopter that Jeffrey had bought her.

I remember she was very excited because she got her license around the ?rst year we met.

I I used to get frightened ?ying with her but Bill had the secret service with him and I remember
him talking about what a good job she did.

I don't remember seeing Bill again on the trip but I assume Ghislaine ?ew him back.

Virginia disclosed that Mr. Clinton's vice-president Al Gore and his wife, Tipper, were also
guests of Epstein on his island.

Virginia said that yet another American liberal icon, Senator George Mitchell, frequently visited
Epstein?s New York residence. Mr. Mitchell, aged 77, was very close to Jeffrey, Virginia
recalled.

I also met Naomi Campbell at a birthday party of hers on a yacht in the South of France. She is a
friend of Ghislaine's but she was a real bitch to me.

1 Donald Trump was also a good friend of effrey's. He didn't partake in any sex with any of us
but he ?irted with me. He'd laugh and tell Jeffrey, ?you?ve got the life.?

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Case 18-2868, Document 286, 08/09/2019, 2628248, Page4l of 55

Ghislaine took nude picture of me lying naked in a hammock, posed with my legs open, a bit
provocatively that I gave to Jeffrey for his birthday.

The hammock photo was "all over the houses? and Bill Clinton and Andrew "had to have seen"
4 it. 

I spent four years as millionaire's personal masseuse.
I was living on the streets, beaten up and slept with at least two older men in return for food.
While on the streets, I slept with men for money.
I was a paedophile?s dream.
KL Three years later she was reunited with her family.
After about two years, he started to ask me to 'entertain' his friends.

She recalls he said ?I?ve got a good friend and I need you to ?y to the island to entertain him,
massage him and make him feel how you make me feel.?

The way it usually worked was I'd been sent to meet a man on the private island Jeffrey owned in
the Caribbean, or at his ranch in New Mexico, which was really isolated.

I met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell.

She was, she says, delighted when Epstein invited her to accompany him on a six-week trip in
2001.

FBI told me that Epstein had hidden cameras watching me the entire time even when I was in the
bathroom. I was so embarrassed.

The FBI told me everything he did was illegal because I was under age.

 Case 18-2868, Document 286, 08/09/2019, 2628248, Page42 of 55

Virginia got a part~time job as a changing room assistant.

I told Ghisla-ine I wanted to become a masseuse and she said she worked for a very wealthy
gentleman who was looking for a traveling masseuse. I?d get training and be paid well.

(-3, Another lady led me into Jeffrey's bedroom. The lady walked me straight through into the
a massage room.

Afterwards, she was given two $100 bills and told to return the next day. That was the beginning
of the four years she spent with Epstein.

Radar Online has obtained exclusive "Diary entries" of "Teen Sex Slave".
I led Prince Andrew into the upstairs bathroom next to the room I was staying in.

I was doing my best trying to put on a good show for him by slowly undressing and started to
pour a bath.

He was caressing every part of my naked body and ?lling my head with endless compliments
about my blossoming ?gure.

He paid careful attention to my toes and was licking them.

1 I also saw Prince Andrew at the Ranch in New Mexico.

Case 18-2868, Document 286, 08/09/2019, 2628248, Page43 of 55

EXHIBIT QQ

 2628248, Page44 of 55
Sent: Fri 55/20/2011 2:20:09 AM

Importance: Normal

Subject: How ya doing??

Received: Fri 5/20/2011 2:20:09 AM
Hi Buddy,

I hope you are stopping to smell the daffodils once in a while and having a good day!! I am so excited today because I ca]
go sign with an agent as my contract is finished with "Mail On Sandra and I have been working really
hard to get me ready for my trip to the US in a few weeks and I was wondering if I could use your advice again. She has
got an agent who is interested in speaking with me and I don?t want to say "Yes" to the first bite because I?m not su
what to look for in an agent. What could you recommend that I do? I will send Jarred and Irene (your recommended agen
a copy of the synopsis and sample chapters but how do I choose the right one for "The Story"? Do you know anyone else
that might be interested in this as well? If so, i am keen on speaking with anyone who might be. I am excited
about this and will keep you updated with the progressing events. When I am in New York we have to meet up for some
city shopping and take the kids to Central Park to see the Zoo, given there will be no masturbating kangaroo's for you to
make friends with, but who know's? I am looking forward to showing Robbie around and he's got some family out there 2
well we have to catch up with. Such busy times, but I?m loving it!! Anyways I hope your taking care and catch me up on 
your fun times?!

Take care,
Jenna

CONFIDENTLAL GIUFFRE003959

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EXHIBIT RR

Agren Document
Blando Court
Reporting 2628248,
& Video, Page46
Inc.
Case 18-2868,
286, 08/09/2019,
of 55

IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Civil Action No. 15-cv-07433-RWS
__________________________________________________
CONFIDENTIAL VIDEOTAPED DEPOSITION OF
VIRGINIA GIUFFRE
May 3, 2016
__________________________________________________
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
__________________________________________________
APPEARANCES:
FAMER, JAFFE, WEISSING, EDWARDS, FISTOS &
LEHRMAN, P.L.
By Brad Edwards, Esq.
425 N. Andrews Avenue
Suite 2
Fort Lauderdale, FL 33301
Phone: 954.524.2820
brad@pathtojustice.com
Appearing on behalf of the
Plaintiff
BOIES, SCHILLER & FLEXNER LLP
By Sigrid S. McCawley, Esq. (For Portion)
401 East Las Olas Boulevard
Suite 1200
Fort Lauderdale, FL 33301-2211
Phone: 954.356.0011
smccawley@bsfllp.com
Appearing on behalf of the
Plaintiff

VIRGINIA GIUFFRE 5/3/2016

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APPEARANCES:

(Continued)

HADDON, MORGAN AND FORMAN, P.C.
By Laura A. Menninger, Esq.
Jeffrey S. Pagliuca, Esq.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
lmenninger@hmflaw.com
jpagliuca@hmflaw.com
Appearing on behalf of the
Defendant

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Also Present:
Brenda Rodriguez, Paralegal
Nicholas F. Borgia, CLVS Videographer

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1

Pursuant to Notice and the Federal Rules

2

of Civil Procedure, the VIDEOTAPED DEPOSITION OF

3

VIRGINIA GIUFFRE, called by Defendant, was taken on

4

Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150

5

East 10th Avenue, Denver, Colorado, before Kelly A.

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Mackereth, Certified Shorthand Reporter, Registered

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Professional Reporter, Certified Realtime Reporter

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and Notary Public within Colorado.

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* * * * * * *
I N D E X

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EXAMINATION

PAGE

12

MS. MENNINGER

8

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PRODUCTION REQUEST(S):
(None.)

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VIRGINIA GIUFFRE 5/3/2016

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1

INDEX OF EXHIBITS

2
3

INITIAL
REFERENCE

DESCRIPTION

4

Exhibit 1

Complaint and Demand for Jury
Trial re Jane Doe No. 102 v.
Jeffrey Epstein

17

Exhibit 2

Jane Doe #3 and Jane Doe #4's
Motion Pursuant to Rule 21 for
Joinder in Action

21

Exhibit 3

Declaration of Virginia L.
Giuffre re Jane Doe #1 and Jane
Doe #2 vs. United States of
America

23

Exhibit 4

Declaration of Jane Doe 3 re
Jane Doe #1 and Jane Doe #2 vs.
United States of America

31

Exhibit 5

Declaration of Virginia Giuffre
re Bradley J. Edwards and
Paul G. Cassell vs. Alan M.
Dershowitz

33

Exhibit 6

FBI documentation, date of entry
7/5/13

36

Exhibit 7

Document titled Telecon,
Participants Jack Scarola, Brad
Edwards, Virginia Roberts. Re
Edwards adv. Epstein, 4/7/11,
(23 pages of transcription)

39

Exhibit 8

The Billionaire's Playboy Club,
By Virginia Roberts

41

Exhibit 9

Plaintiff's Response and
Objections to Defendant's First
Set of Discovery Requests to
Plaintiff re Giuffre v. Maxwell

44

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6
7
8
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2

INITIAL
REFERENCE

DESCRIPTION

3

Exhibit 10

Plaintiff's Supplemental
Response and Objections to
Defendant's First Set of
Discovery Requests to Plaintiff

46

Exhibit 11

Undated Declaration of Virginia
Giuffre re Plaintiff's
Supplemental Response and
Objections to Defendant's First
Set of Discovery Requests served
on March 22, 2016

46

Exhibit 12

Plaintiff's Second Amended
Supplemental Response and
Objections to Defendant's First
Set of Discovery Requests to
Plaintiff

47

Exhibit 13

Mrs. Virginia Giuffre resume

67

Exhibit 14

Compilation of e-mails re Open
Position - Virginia Giuffre

68

Exhibit 15

Virginia Lee Roberts passport
application

180

Exhibit 16

Composite of e-mail strings

251

Exhibit 17

Compilation of e-mails between
Giuffre and Silva and others

259

Exhibit 18

Compilation of e-mails between
Virginia Giuffre and Sandra
White

265

Exhibit 19

Compilation of e-mails between
Marianne Strong and Virginia
Giuffre

269

Exhibit 20

Compilation of e-mails between
Virginia Roberts and Jason
Richards

276

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INITIAL
REFERENCE

DESCRIPTION

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Exhibit 21

Compilation of e-mails between
Sharon Churcher and Virginia
Giuffre

Exhibit 22

Compilation of e-mails among
287
Sharon Churcher, Michael Thomas,
Virginia Giuffre and others

Exhibit 23

Compilation of May 2011 e-mails
among Sharon Churcher, Virginia
Giuffre, Paulo Silva and others

Exhibit 24

Compilation of June 2011 e-mails 289
between Virginia Giuffre and
Sharon Churcher

Exhibit 26

PR Hub Statement on Behalf of
Ghislaine Maxwell article

300

Exhibit 27

1/2/15 e-mail from Ross Gow to
To Whom It May Concern

309

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284

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6
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8

288

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Some names have been changed in order to protect

2

other people.

3

Q

(BY MS. MENNINGER)

4

A

Protect their privacy, yeah, I would say,

Protect their privacy?

5

just not getting them involved in, if this were to

6

ever go public.

7
8
9
10
11
12

Q

Well, again, without rereading the whole

manuscript -A

Reading it, yeah.

I'm trying to see if I

can -- see something in here.
Q

Let me narrow my question and maybe that

will help.

13

A

Yes.

14

Q

Is there anything -- well, first of all,

15

did you author that entire manuscript?

16

A

Yes, I did.

17

Q

Did anyone else author part of that

18

manuscript?

19

A

20

Do you mean did anyone else write this

with me?

21

Q

Right.

22

A

No.

23

Q

That's all your writing?

24

A

This is my writing.

25

Q

Okay.

To the best of your recollection,

VIRGINIA GIUFFRE 5/3/2016

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as you sit here right now, is there anything in that

2

manuscript about Ghislaine Maxwell that is untrue?

3
4

A

I don't believe so.

Like I said, there is

a lot of stuff that I actually have left out of here.

5

Q

Um-hum.

6

A

So there is a lot more information I could

7

put in there.

8

I would like to say that there is 99.9 percent of it

9

would be to the correct knowledge.

10

Q

But as far as Ghislaine Maxwell goes,

All right.

Is there anything that you --

11

and I understand you're doing this from memory.

12

there anything that you recall, as you're sitting

13

here today, about Ghislaine Maxwell that is contained

14

in that manuscript, that is not true?

15

A

You know, I haven't read this in a very

16

long time.

17

here about Ghislaine Maxwell that is not true.

18

I don't believe that there's anything in

MR. EDWARDS:

I'd just ask, Counsel, if

19

you have anything specific to show her about

20

Ghislaine Maxwell --

21

MS. MENNINGER:

22

MR. EDWARDS:

23

MS. MENNINGER:

24

MR. EDWARDS:

25

Is

I'll ask questions.
-- I'll have her look at it.
I'll ask questions.
I know, but I want the

record clear that if she hasn't read it in a long
VIRGINIA GIUFFRE 5/3/2016

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I, VIRGINIA GIUFFRE, do hereby certify that

2

I have read the foregoing transcript and that the

3

same and accompanying amendment sheets, if any,

4

constitute a true and complete record of my

5

testimony.

6
7
8

________________________________
Signature of Deponent
( ) No Amendments
( ) Amendments Attached

9
10
11
12

Acknowledged before me this
_____ day of ______________, 2016.

13
14

Notary Public: ________________________

15

Address:

_____________________________

16

_____________________________

17

My commission expires _________________

18

Seal:

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20
21

KAM

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VIRGINIA GIUFFRE 5/3/2016

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STATE OF COLORADO)

2

)

3

COUNTY OF DENVER )

4

ss.

REPORTER'S CERTIFICATE

I, Kelly A. Mackereth, do hereby certify

5

that I am a Registered Professional Reporter and

6

Notary Public within the State of Colorado; that

7

previous to the commencement of the examination, the

8

deponent was duly sworn to testify to the truth.

9

I further certify that this deposition was

10

taken in shorthand by me at the time and place herein

11

set forth, that it was thereafter reduced to

12

typewritten form, and that the foregoing constitutes

13

a true and correct transcript.

14

I further certify that I am not related to,

15

employed by, nor of counsel for any of the parties or

16

attorneys herein, nor otherwise interested in the

17

result of the within action.

18
19
20

In witness whereof, I have affixed my
signature this 11th day of May, 2016.
My commission expires April 21, 2019.

21
22
23

____________________________
Kelly A. Mackereth, CRR, RPR, CSR
216 - 16th Street, Suite 600
Denver, Colorado 80202

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VIRGINIA GIUFFRE 5/3/2016

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