Browse by Document Type
Depositions (6,483 documents)
Case 1:15-cv-Agted? Bian dm GonettReporsin gfe Wineop/Erc.Page 24 of 89
Page 85 Page 87
1 February 2003, not true, correct? 1 experience than you had had, correct; that's what you
2 A Obviously, yes.
Case 1:15-cvAgHhe8-Bhin docCamAanRegnnGa g ki Mideo3 Inc. Page 4 of 89
Page 5 Page 7
1 1 * OK OK KOK KOK
INITIAL
2 DESCRIPTION REFERENCE 2 PROCEEDINGS
3 a a 3 THE VIDEOGRAPHER: We're on the record at
Case 1:15-cvAgre8-Bhin docCamAanRegnanGa g iMideoO3 Inc. Page 3 of 89
Page 1 Page 3
IN THE UNITED STATES DISTRICT COURT 1 Pursuant to Notice and the Federal Rules
SOUTHERN DISTRICT OF NEW YORK 2 of C
Case 1:15-cv-07433-LAP Document 1320-36 Filed 01/03/24 Page 3 of 3
14. Attached as Exhibit N (filed under seal) is a true and correct copy of Plaintiff,
Virginia Giuffre’s Third Revised Disclosure P
Case 1:15-cv-07433-LAP Document 1320-36 Filed 01/03/24 Page 2 of 3
5. Attached as Exhibit D (filed under seal) is a true and correct copy the Deposition
of Virginia Giuffre taken in the above caption
Case 1:15-cv-07433-LAP Document 1320-36 Filed 01/03/24 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
VIRGINIA L. GIUFFRE,
Plaintiff, :
v. i 15-cv-07433-RWS
GHISLAINE MAXWEL
Case 1:15-cv-07433-LAP Document 1320-34 Filed 01/03/24 Page 2 of 4
3. Attached as Exhibit B is a true and correct copy of excerpts from Plaintiffs
Amended and Supplemental Response and Objections to
Case 1:15-cv-07433-LAP Document 1320-34 Filed 01/03/24 Page 3 of 4
12. — Attached as Exhibit K (filed under seal) is a true and correct copy of excerpts
from the Deposition of Dr. Steven Olsen taken
Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 14 of 24
sworn interrogatory responses and has not produced any records from Dr. Lightfoot’s recent
treatment of Plaintiff. With less than
Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 8 of 24
Further, during the deposition of Dr. Olson on May 26, 2016, Ms. Maxwell learned that
he had additional records in his laptop that
Case 1:15-cv-07433-LAP Document 1320-32 Filed 01/03/24 Page 27 of 27
Biot ES. Seo rate 1 Niet ce) Rs ES SONS eS
40! EAST LAS OLAS BOULEVARD * SUITE 1200* FORT LAUDERDALE, FL 3330!-221/1* PH. 954.356
Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 7 of 24
For some providers, Plaintiff provided records, and the nature of treatment was identified
by reference to the records. For other p
Case 1:15-cv-07433-LAP Document 1320-31 Filed 01/03/24 Page 18 of 24
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 23rd day of May, 2016, I served the attached document
PLAINTIFF’S NOTICE OF T
DCDOMADUBWNHROWOWDAADUBWNHEH
Case 1:15-cv-07433-LAP Document 1320-29 Filed 01/03/24 Page 5 of 6
Page 130
R. Rizzo - Confidential
There is a privilege of spousal
privilege, so please don't disclos
DCDOMADUBWNHROWOWDAADUBWNHEH
Case 1:15-cv-07433-LAP Document 1320-29 Filed 01/03/24 Page 6 of 6
Page 134
R. Rizzo - Confidential
indicated to you that he wasn't going to be
your lawyer in connectio
Case 1:15-cv-07433-LAP Document 1320-29 Filed 01/03/24 Page 3 of 6
APPEARANCES:
FARMER JAFFE WEISSING EDWARDS FISTOS &
LEHRMAN, P.L.
Attorneys for Plaintiff
425 N. Andrews Avenue
Fort Lauderdale, Flo
Case 1:15-cvAgres -BhandocComAanRepanutg kicddideo3Inc. Page 3 of 27
IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Civil Action No. 15-cv-07433-RWS
CONFIDENTIAL VIDEOTAPED DEPOSIT
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Case 1:15-cvAgres -BhandocComAanRepanung icddideo3Inc. Page 5 of 27
Pursuant to Notice and the Federal Rules
of Civil Procedure, the VI
Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 27 of 32
fact through her errata sheet on May 31, and she refused to answer material questions at her
deposition on the advice of counsel,
Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 30 of 32
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ween eee eee eee xX
VIRGINIA L. GIUFFRE,
Plaintiff, :
v. : 15-cv-0743
Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 9 of 32
June 18, 2016). “Good cause” and diligence were not shown when a party raised the prospect of
a deposition nine days prior to the d
Case 1:15-cv-07433-LAP Document 1320-27 Filed 01/03/24 Page 5 of 15
Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this reply
in support of her Motion to Exceed Pres
Case 1:15-cv-07433-LAP Document 1320-27 Filed 01/03/24 Page 9 of 15
Defendant appears to be concealing critical evidence of the sexual abuse that other witnesses
have testified she possesseS. |
Re Y
Case 1:15-cv-07433-LAP Document 1320-26 Filed 01/03/24 Page 3 of 10
Page 21
Jeffrey's home when you arrived?
A. Yes. When I first walked in the door, it
was just myself, and Ghislaine headed for the
Case 1:15-cv-07433-LAP Document 1320-24 Filed 01/03/24 Page 5 of 16
Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this reply
in support of her Motion to Exceed Pres
Case 1:15-cv-07433-LAP Document 1320-26 Filed 01/03/24 Page 2 of 10
VIRGINIA L. GIUFFR
Vv.
GHISLAINE MAXW
ED STATES DISTRICT COURT
HERN DISTRICT OF NEW YORK
CASE NO. 15-CV-07433-RWS
Plaintiff,
Case 1:15-cv-07433-LAP Document 1320-23 Filed 01/03/24 Page 3 of 10
Page 21
Jeffrey's home when you arrived?
A. Yes. When I first walked in the door, it
was just myself, and Ghislaine headed for the
Case 1:15-cv-07433-LAP Document 1320-23 Filed 01/03/24 Page 2 of 10
VIRGINIA L. GIUFFR
Vv.
GHISLAINE MAXW
ED STATES DISTRICT COURT
HERN DISTRICT OF NEW YORK
CASE NO. 15-CV-07433-RWS
Plaintiff,
Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 4 of 15
Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this reply
in support of her Motion to Exceed Pres
Case 1:15-cv-07433-LAP Document 1320-20 Filed 01/03/24 Page 2 of 11
Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Response in Opposition to
Plaintiff's Motion to Exceed Presumptive Ten Depo
Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 33 of 40
Second, the questions highlighted by Defendant asked Ms. Giuffre whether she had ever
communicated with her attorneys Cassell and
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 153 of 179
Page 152
Q. When I say "girl," I really mean women,
correct?
A. Correct.
Q. There were other women around who hung out
with J
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 150 of 179
Page 149
A. Correct.
Q. Did she ask you to take a nude photograph
of yourself or just a photograph of yourself?
A. A nude pho
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 141 of 179
Page 140
had never had a massage?
A. No.
Q. And then you were talking about the
massage -- the first massage when you were bein
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 130 of 179
Page 129
recall saying that.
And there's another part in here where she
said I said that I made a deal with the devil, which
I
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 123 of 179
Page 122
story out, because this is when Dershowitz --
Dershowitz was saying nothing was happening and
he was calling her a liar
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 125 of 179
Page 124
what other girls did for him and that I was not one
of those girls.
He was always trying to recruit me almost
in a wa
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 92 of 179
Page 91
BY MS. MENNINGER:
Q. If you asked him to buy a ticket to New
York, that might be something that he would do?
A. I neve
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 88 of 179
Page 87
Q. Do you know personally whether anyone else
had said no to him?
A. Oo.
Q. Did anyone ever tell you that they had
been i
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 70 of 179
MS. McCAWLEY: Objection.
BY MS. MENNINGER:
Q. I'm sorry. You're right. Third time.
The second time you went to work, but the thi
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 67 of 179
Page 66
Q. Was that the whole conversation?
A. That was pretty much it. I said, Okay,
sure, tell me when.
Q. And were you exci
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 56 of 179
Page 55
observed her personality to be?
A. Sure. She definitely had a great sense of
humor, she loved making jokes. I mean, in a
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 50 of 179
Page 49
(The referred-to document was marked by
the court reporter for Identification as
Sjoberg Exhibit 4.)
BY MS. McCAWLEY:
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 38 of 179
Page 37
Q. Do you recall who was present at the time
that she made that comment about children?
A. This was the second trip tha
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 40 of 179
talking on the phone about Frederic Fekkai?
A. Yes.
MS. MENNINGER: Objection, leading.
BY MS. McCAWLEY:
Q. What did you hear?
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 22 of 179
Page 21
Jeffrey's home when you arrived?
A. Yes. When I first walked in the door, it
was just myself, and Ghislaine headed for t
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 19 of 179
Page 18
MS. MENNINGER: Objection. The witness is
reading the document.
BY MS. McCAWLEY:
Q. And do you recall where you flew w
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 25 of 179
Page 24
they were going on was to the island in the Virgin
Islands, and I would be invited; however, there
would be, quote, sex s
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 12 of 179
Page 11
Q. How did the meeting -- you said Maxwell
took you to the home. Do you remember how that
meeting ended?
A. Well, she d
Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 21 of 179
Page 20
A. No, I only -- to you, I said that to you.
I just saw her as perhaps someone who may not have
had a strong family, and