EXHIBIT A¶
1 think I met Prince Andrew in 2001. And Glenn and Stephen Kaufmann were, like I said, the first people I was sent out to after my training. So I don't know. I'm not going to give you an exact time if I don't know it.¶
6 Q I asked you the relative order.¶
A And I'm trying to give you it.¶
8 Q And where does Alan Dershowitz fit into that group of people?¶
A Same. I can't tell you piece by piece by piece who -- I know Glenn was first.¶
12 Q Okay.¶
A And I know Stephen Kaufmann was one of the first I was sent to. Alan Dershowitz could have been between there. Between, sorry, between Glenn and Stephen. The first time I was with Alan Dershowitz was in New York, so I wasn't actually sent to him. It actually happened at one of Jeffrey's residences.¶
(Ms. McCawley left the deposition.)¶
A So it's very hard for me to chronologically give you each person individually.¶
Q (BY MS. MENNINGER) Okay. Name the other politically connected and financially powerful people that Ghislaine Maxwell told you to go have sex with?¶
1 because that's how it went. They instructed me to go to Mitchell, Jean Luc Brunel, Bill another prince that I don't know his name. A guy that owns a hotel, a really large hotel chain, I can't remember which hotel it was. Marvin Minsky.¶
There was, you know, another foreign president, I can't remember his name. He was Spanish. There's a whole bunch of them that I just -- it's hard for me to remember all of them. You know, I was told to do something by these people constantly, told to -- my whole life revolved around just pleasing these men and keeping Ghislaine and Jeffrey happy. Their whole entire lives revolved around sex.¶
They call massages sex. They call modeling sex. They call --¶
17 Q I asked you the names for people. Are you going to tell me any other names or is that all of them?¶
A I'm trying to think. That's the answer I'm trying to give to you. It's that it's so hard to just keep naming and naming and naming.¶
23 Q All right.¶
A A lot of times I would be introduced to them. I didn't know --¶
Confidential/Sealed Transcript Pursuant to Court Order
Videotaped Deposition of [REDACTED] (January 16, 2016)
Job No. J0277789¶
215¶
1 DEPOSITION ERRATA SHEET¶
2¶
3 Assignment no: J0277789¶
4 [REDACTED] 1. Edwards and Paul G. Cassell¶
5 vs.¶
6 Alan M. Dershowitz¶
7¶
**¶
8 DECLARATION UNDER PENALTY OF PERJURY¶
9¶
10 I declare under penalty of perjury that I
11 have read the entire transcript of my videotaped
12 deposition taken in the captioned matter or the same has
13 been read to me, and the same is true and accurate, save
14 and except for changes and/or corrections, if any, as
15 indicated by me on the DEPOSITION ERRATA SHEET hereof,
16 with the understanding that I offer these changes as if
17 still under oath.¶
18¶
19 signed on the 11 day of September¶
20 20 |k2.¶
21¶
22
23 Virginia Roberts Giuffre
24 -----
25 VIRGINIA ROBERTS GIUFFRE¶
26¶
27¶
Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of (January 16, 2016) Job No.10277789¶
l)El'OSITION ERRATA SHEET¶
Page No. 6 Line No. 17¶
Change to: "Yes. I signed the subpoena duces teem."¶
Reason for change: Did not initially recognize the document¶
Page No. 6 Line No. 20¶
Change to: "No. My lawyers worked with me to collect documents and my understanding is that we turned those documents over to Dershowitz's counsel prior to the deposition."¶
Reason for change: Clarification of answer¶
Page No. 9 Line No. 9¶
Chance to:"Yes"¶
Reason for change: Did not initially recognize the document¶
Page No. II Line No. I¶
Change to: "Yes"¶
Reason for change: Misunderstood the question¶
Page I I Line Nos. 4.5¶
Change to: "I'm confused. I don't know what foreign president you're talking about."¶
Reason fur change: Misunderstood the question¶
Page No. II line No. 23¶
Chance to: "I understand well-known prime ministers and other world leaders; as far as foreign presidents. I believe so."¶
Reason for change: Misunderstood the question¶
Page No. 12 Line No. 2¶
Change to: "Yes, assuming South America is considered overseas."¶
Reason for change: Misunderstood the question¶
Page No. 12 Line No. 8¶
Chance to: "As far as I know right now, yes. I was."¶
Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition o (January 16, 2016)¶
Job No. J0277789¶
Reason for change: Misunderstood the question¶
Page No. 38 Line No. I1¶
Change to: "I'll continue with the list here. Nadia Mareinkova I was not sent to her, but she was part of it with Jeff Epstein. Others on the list include Marvin Minsky and Tom Pritzker."¶
Reason lbr change: Clarification of answer¶
Page 38 Line 19¶
Change to: "Off the top of my head, once, but it could have been more."¶
Reason for change: Clarification of answer¶
Page No. 38 Line No. 21¶
Change t: "I believe Toni was at Mexico. I may have also been with him in other places."¶
Reason for change: Clarification of answer¶
Page No. 41 Line No. 8¶
Chance to: "On an airplane and in a limo."¶
Reason for change: Clarification of answer¶
Page No. 41 Line No. 10¶
Chance to: "One, each time."¶
Reason for change: Clarification of answer¶
Page No. 41 Line No. 12¶
Chance to: "On airplane, blond, young."¶
Reason for change: Clarification of answer¶
Page No. 98 Line No. 16¶
Change to: "As you can see in that answer I'm not even sure. It wasn't six months, but between six months and a year which is why I'm saying nine months. It was an assumption. It could have been six weeks."¶
Reason for change: Clarification of answer¶
Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition o (January 16, 2016) Job No.10277789¶
Page No. I 90 Line No. 22¶
Change to: "No. other than maybe you showing it to me today. It's in my pile. It's not in my pile, is it? I don't know. I haven't seen it. I was served with the subpoena, and I signed for it, and I reviewed it at that lime."¶
Reason for change: Clarification of answer¶
Page 191 Line 5¶
Chance to: "Why would I do — no. I did collect documents and gave them to my lawyers in response to this subpoena. And my understanding is those documents were produced."¶
Reason for change: Misunderstood the question¶
Page 191 Line 20¶
Chance to: "Yes, but I did not have any pictures of myself with Professor Dershowitz."¶
Reason for change: Misunderstood the question¶