EXHIBIT G¶
VS.¶
MAXWELL¶
Deposition¶
05/03/2016¶
Agren Blando Court Reporting & Video, Inc.¶
216 16th Street, Suite 600¶
Denver Colorado, 80202¶
303-296-0017¶
Page 205¶
1 another prince, the large hotel chain owner and 2 Marvin Minsky, is there anyone else that Ghislalne 3 Maxwell directed you to go have sex with? 4 A I am definitely sure there is. But can I 5 remember everybody's name? No. 6 Q Okay. Can you remember anything else 7 about them? A Look, I've given you what I know right 9 now. I'm sorry. This is very hard for me and very 10 frustrating to have to go over this. I don't -- I 11 don't recall all of the people. There was a large 12 amount of people that I was sent to. 13 Q Do you have any notes of all these people 14 that you were sent to? 15 A No, I don't. 16 Q Where are your notes? 17 A I burned them. 18 Q When did you burn them? 19 A In a bonfire when I lived at Titusville 20 because I was sick of going through this shit. 21 Q Did you have lawyers who were representing 22 you at the time you built a bonfire and burned these 23 notes? 24 A I've been represented for a long time, but 25 it was not under the instruction of my lawyers to do¶
Page 207¶
Q Including Mr. S who is sitting¶
2 right here, correct? 3 A Correct.¶
4 Q What did that journal look like?¶
A It was 6 Q And what else?¶
7 A It was just a spiral notebook.¶
8 Q Okay. And what did you put into that¶
9 spiral notebook?¶
10 A Bad memories. Things that I've gone 11 through, lots of things, you know. I can't tell you. 12 There was a lot of pages. It was over 300 pages in¶
13 that book.¶
14 Q Did you ever show that book to your¶
15 lawyers? 16 A No.¶
17 Q Did you show that book to anyone?¶
18 A My husband.¶
19 Q Did you show it to anyone else besides¶
20 your husband? 21 A No.¶
22 Q Did you tear out pages and give them to¶
23 Sharon Churcher?¶
24 A No, I wrote -- those pages that you're 25 talking about, I wrote for her specifically. She¶
Page 206¶
1 this. My husband and I were pretty spiritual people 2 and we believed that these memories were worth 3 burning. 4 Q So you burned notes of the men with whom 5 you had sex while you were represented by counsel In 6 litigation, correct? 7 MR. : Object to the form. 8 A This wasn't anything that was a public 9 document. This was my own private journal, and I 10 didn't want it anymore. So we burned it. 11 Q (BY MS. MENNINGER) When did you write 12 that journal? 13 A Just over time. I started writing it 14 probably in, I don't know, I can't speculate, 2012, 15 2011. 16 Q So you did not write this journal at the 17 time it happened? 18 A No. 19 Q You started writing this journal 20 approximately a decade after you claim you finished 21 being sexually trafficked, correct? 22 A Yes. 23 Q And you started writing a journal after 24 you had a lawyer, correct? 25 A Correct.¶
1 2 Q So that's a different piece of paper? 3 A Yeah, that's just random paper. 4 Q So you had a spiral notebook that 5 you began sometime in 2011 or 2012 in which you wrote 6 down your recollections about what had happened to 7 you, and you burned that in a bonfire in 2013. 8 Did I get that right? 9 A You got that right. 10 Q And do you have no other names of people 11 to whom you claim Ghislalne Maxwell directed you to 12 have sex, correct? 13 A At this time, no. 14 Q Is there any document that would refresh 15 your recollection that you could look at? 16 A If you have a document you'd like to show 17 me, I would be glad to look at It and tell you the 18 names I recognize off of that. 19 Q I'm just asking you if there's a document 20 you know of that has this list of names in it? 21 A Not in front of me, no. 22 Q Where Is the original of the photograph 23 that has been widely circulated in the press of you 24 with Prince Andrew? 25 A I probably still have it. It's not in my wanted to know about the Prince Andrew incident.¶
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3 A Probably in some storage boxes. 3 A Jeffrey Epstein.¶
4 Q Where? 4 Q And where did you have it developed?¶
5 A In Sydney. 5 A I believe when I got back to America.¶
6 Q Where in Sydney? 6 Q So where?¶
7 A At some family's house. We got the boxes 7 A I don't know. B shipped to Australia, and they were picked up off the s Q Palm Beach? 9 porch by my nephews and brought to their house. 9 A I don't know.¶
10 Q Which is where? 10 Q What is the date the photograph was¶
11 A In Sydney. 11 printed?¶
12 Q Where in Sydney? 12 A I believe it's In March 2001.¶
13 A 13 Q Okay.¶
14 Q And who lives in that house? 14 A But that's just off of my photographic¶
15 A Well, it's owned by my mother-in-law and 15 memory. I don't -- It could be different, but I 16 father-in-law, but my nephews live in the house. 16 think it's March 2001.¶
17 Q What are their names? 17 Q You have a photographic memory?¶
18 A I'm not giving you the names of my 18 A I'm not saying I have a photographic 19 nephews. 19 memory. But if I'd look at the back of the photo and¶
20 Q What's the address of the house? 20 I remember what it says, I believe it was March 2001.¶
21 A Why would you want that? 21 Q Did the photograph ever leave your¶
22 Q I want to know where the photograph is. 22 possession for a while?¶
23 I'm asking you where the photograph is. And you've 23 A I gave it to the FBI. 24 just told me it's somewhere in 24 Q Okay. And when did you get it back?¶
25 A Yes. 25 A When they took copies of it.¶
1 Q So where in Is the photograph 1 Q When was that? 2 located? 2 A 2011.¶
3 A If I can't 100 percent say that the 3 Q When they came to interview you? 4 photograph is there, it could be at my house that I 4 A Yes. 6 address of my nephews' residence. 6 was in your personal possession?¶
5 presently live in. I'm not going to give you the 5 Q So from 2011 until you left Colorado it¶
7 Q When is the last time you saw the 7 A Yes.¶
8 photograph in person? B Q What other documents related to this case¶
9 A When I packed and left America. 9 are in that, storage boxes in Australia?¶
10 Q Colorado? 10 MR. : Object to the form.¶
11 A Yes. 11 A Documents related to this case -- there --¶
12 Q All right. So you had that photograph 12 I don't know. I really can't tell you. I mean,¶
13 here with you in Colorado? 13 there's seven boxes full of Ned guns, my kids' toys, 14 A Yes. 14 photos. I don't know what other documents would be¶
15 Q What's on the back of the photograph? 15 in there.¶
16 A I'm sorry? 16 Q (BY MS. MENNINGER) Did anyone search 17 Q Is there anything on the back of the 17 those documents after you received discovery requests¶
18 photograph? 18 from us in this case?¶
19 A There's like the date it was printed, but 19 A I haven't been able to obtain those boxes.¶
20 no writing or anything. 20 I can't get them sent back up to me. It's going to 21 Q Okay. Does it say where it was printed? 21 cost me a large amount of money. And right now I'm¶
22 A I don't believe so. I think it just -- I 22 trying to look after my family, so I'm not able to 23 don't remember. I just remember there's a date on 23 afford to get them up. 24 it. 24 Q You live in Australia, correct?¶
1 Q Okay. How far away are the boxes from 1 We've had lots of bonfires there. 2 where you live in Australia? 2 Q Did you ever ride in a helicopter with a A Sydney is down here at the bottom. Cairns 3 Ghislaine Maxwell acting as pilot of the helicopter? 4 is up here at the top. 4 A Yes. 5 Q Okay. s Q Who else was on the flight? 6 A It's probably a six-day drive. 6 A I've been on the helicopter with her 7 Q Did you fly here through Sydney? 7 plenty of times. I can't mention how many people B A No. 8 were on the -- on the helicopter at the same time. 9 Q Have you been to Sydney since you've moved 9 Q How many times? 10 back to Australia? 10 A I don't know. Do you have helicopter 11 A I flew into Sydney with my three kids, but 11 records that you could show me? 12 it was a connecting flight to Brisbane. 12 Q I'm asking you how many times you were on 13 Q Did you ask your nephews or anyone else to 13 the helicopter with Ghislaine Maxwell acting as the 14 search those boxes in response to discovery requests 14 pilot -- 15 that we issued in this case? 15 A It's impossible for me to answer the 16 A They are my nephews. I would never let 16 question without having the actual physical records 17 them look at those. 17 in front of me. 18 Q Other than your spiral notebook, 18 Q I'm asking you to look into your memory 19 what else did you burn in this bonfire in 2013? 19 and tell me how many times you recall being on a 20 A That was it. 20 helicopter with Ghislaine Maxwell at the pilot seat? 21 Q That's the only thing? 21 A There is no number I can give you. 22 A Yes. 22 There's plenty of times I've been on her helicopter. 23 Q Did you use =? 23 Q Where did you go from and to on a 24 A Yes. 24 helicopter? 25 Q Charcoal? 25 A I believe it was -- don't quote me on this¶
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1 A My husband built the bonfire out of = 1 because I get confused on the islands there. I want 2 and I don't know what else he put in it. He's the 2 to say it was St. John's. It could have been 3 one who always makes the fires, not me. 3 St. Baits. St. John or St. Baits, and then we would 4 Q Who else was present? 4 fly straight to Jeffrey's island. 5 A Just him and I. 5 Q Okay. Did you ever go anywhere else on 6 Q Were your kids there? 6 the helicopter? 7 A No. They were inside sleeping. 7 A No. 8 Q And what beach was this? a Q Were you ever on the helicopter with-9 A It wasn't a beach. It was in my backyard. 9 and Ghislaine Maxwell as the pilot of the 10 Q What's your address? io helicopter? 11 A At that time? 11 A No. 12 Q Urn-hum. 12 Q Were you ever on the helicopter with. 13 A 13 and Ghislaine Maxwell as the 14 Q 14 pilot? 15 A Yes. 15 A No. 16 Q Who were your neighbors? 16 Q Do you recall telling Sharon Churcher that 17 A Sweet people. Ray and -- I could look on 17 you were? 18 my phone if you want. 18 A No. 19 Q No, thank you. Do they still live there? 19 Q Did you see the press article in which 20 A Yes. 20 Sharon Churcher reported that you were? 21 Q DO you keep in touch with them? 21 MR. : Objection. I'd just ask 22 A Last time I talked to them was a few 22 that if you're going to ask this witness about a 23 months ago. 23 specific article I'd like for her to see the article. 24 Q Did they see the fire? 24 Otherwise she's not going to testify about it. 25 A They've seen many fires that we've had. 25 If you have something to show her, then,¶
A like I said, I don't recognize it, but 2 it obviously comes from -- 3 Q Your e-mail address? 4 A Yes. 5 Q Now, what e-mail address is that, exactly, 6 on the first page of this exhibit? 7 A @icloud.com, that must be from a phone. 8 Q So that's different from the other e-mail 9 address? 10 A Yeah, I don't actually know about that 11 e-mail address. I obviously used it. 12 13 Q And is the e-mail signed by your husband? 14 A No, it's signed by me. 15 Q Okay. And in the subject line you wrote 16 (Jane Doe 102), correct? 17 A Subject line? 18 Q The very top line of that page. 19 A yeah, I see. 20 Q Okay. And it was to 21 jason.richards2@ic.fbi.gov, correct? 22 A Correct. 23 Q And is that Jason Richards we were just 24 referring to? 25 A Yes.¶
1 Q Right. 2 A But anything they had of me. 3 Q And Brad S who is sitting right 4 here, was your attorney at the time and you 5 identified him as such in the e-mail, correct? 6 A Correct. 7 Q You did not identify Mr. -- Judge Cassell 8 as your attorney in this e-mail, correct? 9 A I knew him as a former judge, and I just 10 wrote down, Judge Paul Cassal (sic) as it looks. But 11 he was my attorney -- I don't know if he was my 12 attorney at that time. But yes -- he's always -- 13 he's been with me since the beginning, so -- 14 Q So he's representing you in this case now, 15 correct? 16 A Yes. 17 Q But at that time you don't know if he was 18 your attorney? 19 A I think he was. I mean, I've been talking 20 with him since the beginning. And this is dated 21 2014. So I believe at this time he was my attorney 22 at the time as well. 23 Q Okay. When do you recall first speaking 24 with him? 25 A Speaking with Paul, I'm not too sure. I¶
1 Q All right. And you had some e-mails with 2 Jason Richards over time; is that fair? 3 A Sure. 4 Q These ones that came from your computer, 5 right? 6 A Sure, yes. 7 Q Okay. You talk about having spoken with 8 Judge Paul Cassell in this first page, correct? 9 A I am here to get this BS non-prosecution 10 agreement thrown out and speaking with Judge Paul 11 Cassal (sic). He suggested trying to get ahold of 12 any photos or video recordings released by the FBI to 13 assist our case further in providing (sic) how much 14 pedophilia occurred by Jeffrey and the many other 15 monsters he obliged with underage girls. 16 Q Okay. 17 A If this is a possibility, please let me 18 know so I can give you Brad (my attorney) his 19 contact details. Many thanks for your time and I 20 hope we should meet again. 21 Q Okay. And so you were going back to Jason 22 and trying to get any evidence that the FBI had about 23 your case, right? 24 A Correct. Any photographs pertaining to 25 what -- myself, not of anyone else.¶
1 can't remember if I spoke to Paul in the phone in 2 Australia or if I met him in person in Florida. 3 Q Do you remember when you signed any kind 4 of fee agreement with him? 5 MR. : Object to the form. 6 A Um, the -- well, the first time I would 7 have signed an agreement would have been in Florida. 8 Q (BY MS. MENNINGER) When you were living 9 in Titusville? 10 A As far as my knowledge reminds me. I 11 mean, I'm looking at e-mails that I can't even 12 remember sending. It's a possibility I could have 13 signed earlier, but as far as I remember. 14 Q Okay. Do you recall ever having e-mail 15 communications with Sharon Churcher about her 16 publishing the first serial of your book? 17 A Serial, what does that mean? I'm sorry. 18 Q Like a sequel. 19 A A sequel to my book? 20 Q Um-hum. 21 A My book has never been published. 22 Q Right. Do you remember ever e-mailing 23 with Sharon about her being the one who would publish 24 any subsequent follow-up book? 25 A If you have something in front of you to¶
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I answered. Lacks predicate. 2 A I have been suffering from Ghislaine 3 Maxwell and Jeffrey Epstein since the summer of 2000. 4 So hearing again in 2011 that she's denied it, of course, it's going to hurt me. 6 Did I hear about this in 2011? I can't 7 tell you I honestly have. In 2015 is when I know that she denied it. 9 And again, I haven't stopped suffering from the 10 repercussions that they put me through. 11 Q (BY MS. MENNINGER) And I'm asking you to 12 separate, if you can, any symptoms that you 13 experienced anew in March of 2015 -- I mean, excuse 14 me, March of 2011, as a consequence of this statement 15 being issued, which I believe you said you don't 16 recall seeing at the time; is that fair? 17 A But you're asking me now about 2015? 18 Q Nope. March of 2011. Sorry, I misspoke 19 there. 20 A YOu're still on 2011? 21 Q Yes. Did you start taking any new 22 medications in March of 2011? 23 Let me ask you that. 24 A I've been taking medication to control my 25 since 2002.¶
1 can't believe you've been through this. I never 2 knew. I'm so sorry. You know, that kind of stuff. 3 So they never -- I never spoke to anybody about this 4 except for my husband. 5 Q All right. So the first time you recall 6 any sort of people in your community referencing 7 things to you is when the press picked up on it in 8 2014 or 2015? 9 A Yeah, I think it may be end of 2014, early 10 2015. 11 Q All right. And so in March of 2011 you 12 don't recall any neighbors or anybody saying anything 13 to you about this? 14 A No, I don't recall. 15 Q Did anyone tell you in March of 2011 about 16 Defendant's Exhibit 26, the statement on behalf of 17 Ghislaine Maxwell? 18 A No, otherwise I would have been able to 19 recall It. 20 Q Okay. Do you remember anyone in 2011 21 ridiculing you because of Defendant's Exhibit 26? 22 A well, because nobody knew me as Virginia, 23 everybody knows me as lenna, no one probably put two 24 and two together. And like I told you, I didn't tell 25 anybody. So there was nobody there to ridicule me in¶
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- 1 Q Okay. So did you take any new medications 2 or any additional amounts of medications in March of 3 2011? 4 A I have been taking the same medication 5 since 2002. 6 Q Okay. 7 A And that's due to
- 8 caused from the pain that I suffered at the hands of 9 Ghislaine Maxwell and Jeffrey Epstein. 10 Q Did you -- do you recall any neighbors or 11 other moms at the school or anybody in 2011 12 referencing to you in any way the fact that Ghislaine 13 Maxwell had issued a denial of the allegations about 14 her that had been published in the media in March of 15 2011? 16 A No. I didn't speak to any -- I didn't 17 speak to any moms about what I had gone through. I s mean, when it came out in the press, I don't think 19 any -- like, Australians don't pay attention to news, 20 number one. 21 Number two, the first time that my friends 22 contacted me they were shocked. And this was, I 23 believe in -- when the press picked it up again, I 24 think, was 2014/2015. And I got a whole bunch of 25 like Facebook texts from them saying, `my God,
Page 308¶
1 2011 over this. 2 Q Where were you living in 2011 when Shaza 3 came to see you -- 4 A a 5 Q Do you recall applying for any job in or 6 around 2011 and someone referencing Defendant's 7 Exhibit 26 and denying you a job? 8 A I don't -- I don't think I applied for a 9 job in 2011. 10 Q Okay. Did you go see a doctor and talk to 11 any doctor about Defendant's Exhibit 26? 12 A Not about this. Not about this paper 13 right here. But I have talked to doctors about my 14 abuse at the hands of Ghislaine and Jeffrey. 15 Q Have you talked to a doctor about any 16 statements in the press made by Ghislaine Maxwell? 17 A Recent statements, yes. 18 Q Which doctor did you speak to about that? 19 A Her name is Judith Lightfoot. 20 Q And where is she? 21 A She's in Australia. 22 Q Where in Australia? 23 A She's in Sydney, but we do phone 24 conversations. 25 Q Have you ever met her in person?¶
A Yes. 1 the same. Maxwell strongly denies -- excuse me. Q When? 2 Excuse me -- strongly denies allegations of an Q All right. And is she affiliated with an 4 press and elsewhere and reserves her right to seek office or a hospital or what? 5 redress at the repetition of such old defamatory A She's a psychiatrist. 6 claims. since 2011? 6 before? A No, because I've lived so far away and 9 A I've seen it recently, yes. she's kind of the only person that -- like, I've seen 10 Q All right. What -- have you discussed it's really hard for them to break down the walls and 12 she's a doctor or what. be comfortable enough to talk to them about this 13 A Psychiatrist, yeah. stuff. Judith is different. She's somebody that 1 14 Q Is she an MD? feel I can trust. She's 76 and she's just a very 15 A I don't know what her levels of credential lovely lady. 16 are. I'm sure she is. 18 my pain and suffering. And I continue to see her 18 the statement? over the phone because I can't see her in person. 19 A This full statement I have only seen Defendant's Exhibit 26? 21 in the press was, claims are obvious A I can't recall ever seeing this exhibit. 22 lies and so on, so forth. I don't remember seeing 23 SO -- 23 this in the press. Q Okay. 24 Q Okay. So the part that you remember (Exhibit 27 marked.) 25 seeing in the press is claims are¶
A In 2011. 3 unsavory nature, which have appeared in the British Q All right. Have you seen her in person 7 Q All right. Have you seen this statement a lot of doctors. And I can honestly tell you -- 11 this statement with Ms. Lightfoot? I don't know if And she offers me other ways to deal with 17 Q Okay. When is the first time that you saw Q Do you recall ever discussing with her 20 through discovery. The original statement that I saw¶
Q (BY MS. MENNINGER) I'm going to give you 1 obvious lies? Defendant's Exhibit 27. 2 A Yes. A Yes. 3 Q Anything else about this? Q All right. Have you seen this document 4 A I can't remember what else she printed in before? 5 the press. It's a very horrible thing for her to do, 6 A Yes. 6 turn around and call me a liar after everything that Q And what do you understand it to be? 7 she knows she's done. And I didn't expect her to A sounds like a PR, if 8 come out and be truthful. Fm not right -- if I'm not wrong. Sent -- or 9 Jeffrey Epstein hasn't even issued a subject is Ghislaine Maxwell. I don't know 10 statement. 11 , 11 Q Sorry. I'm sorry if you misunderstood my 12 12 question. It says: To whom it may concern, Please 13 A Yes. find attached credible statement on behalf of 14 Q Was there anything else within this 16 And then it goes on, to hear about that 16 the line, claims are obvious lies? she is saying: Each time the story is retold it 17 A Without saying 100 percent, I think that 18 changes with new salacious details about public 18 the original allegations are not new and have been figures and world leaders and now it is alleged by 19 fully responded to be shown to be untrue. I don't that Alan Dershowitz is involved in 20 know if that's in the press or not, but I've read having sexual relations with her, which he denies. 21 this before. claims are obvious lies and 22 So I don't know if I'm confusing this with should be treated as such and not publicized as news, 23 what I've read out of this or what I've read in the as they are defamatory. Ghislaine Maxwell's original 24 press. The main thing is, I know she called me a response to the lies and defamatory claims remains 25 liar, and that's what she publicized.¶
Ms. Maxwell. 15 statement that you recall seeing in the press besides¶
1 Q And when you say she called you a liar, 1 a liar from the people that abused me. 2 that's the claims are obvious Iles part? 2 Q Okay. Do you recall specifically 3 A Yes. 3 mentioning to him Ghislaine Maxwell's statement to 4 Q Okay. When is the first time that you saw 4 the press? 5 this whole document? 5 A I mentioned a lot of names to him. 6 A I guess when you guys handed it over for 6 Q Okay. What new symptoms did you T discovery. 7 experience following January 2nd, 2015? s Q Okay. And who showed it to you? 8 A I think it's one thing to be a victim of 9 A It was sent to me by e-mail. 9 sexual abuse and survive it and come out trying to 10 Q Okay. Just through the course of 10 tell the world my story, and then another thing for 11 communicating with your attorneys? it it to be shut down because these people, Ms. Maxwell 12 A Yes. 12 and others are calling me liars (sic). 13 Q You've never seen it published? 13 Q And I asked you what symptoms had you 14 A Not this whole e-mail, no. 14 experienced -- 15 Q All right. Did you -- I'm sorry, did you 15 MR. She's going to finish her 16 discuss this publication of what you saw in the press 16 answer to this question. You cut her off so many 17 with Judith Lightfoot? 17 times. 18 A Yes. 18 MS. MENNINGER: It has nothing to do with 19 Q All right. And when did you discuss it 19 this. 20 with her? 20 MR. It absolutely does. Because 21 A When I got back to Australia, Judith and I 21 this is a psychological damages claim, and she Is 22 started seeing each other again. Before then, I 22 trying to explain to you what those damages are. 23 spoke with a doctor in Colorado about this. His name 23 Q (BY MS. MENNINGER) Okay. What are your 24 is Dr. Olsen. And it was causing me a lot of 24 symptoms that you experienced since January 2nd, 2015 25 distress to have to deal with being called a liar all 25 that are new?¶
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1 over again, when I know I'm standing up doing the 1 A Very strong anxiety attacks, bad panic 2 right thing. And the doctor prescribed me 2 attacks. My throat closes up, I can't breathe. I 3 And, yeah. 3 vomit when I have anxiety attacks. My -- this is 4 Q Okay. So my question was, when did you 4 personal, but my sex life has suffered. My marriage 5 discuss it with Judith Lightfoot? 5 has suffered. Psychologically, it's just hurt me all 6 I think I now understand you did that 6 over again. I mean, they've hurt me before, and now 7 after you returned to Australia in November or so of 7 they've hurt me again by doing this. 8 2015; is that right? 8 And I felt like I was in the process of 9 A I returned to Australia in October, and 9 healing before this came out because I had opened up 10 that's when I picked up talking to her again. 10 this wonderful charity called Victims Refuse Silence. 11 Q All right. And you're saying that at 11 And then my aim was to heal by helping other girls 12 another point in time you talked to another doctor, 12 get out of the situations that I was in before. 13 Dr. Olsen, in Colorado, correct? 13 And my lawyers were nice enough to help 14 A Correct. 14 me. I have this beautiful website where you can 15 Q And when did you meet with Dr. Olsen? 15 click on in any state and you can find a place. I 16 A I don't know the first date that I met 16 have personally called all of them and they will help 17 with him. 17 you get out of the situation that you're in. They 18 Q Did you meet with him more than once? Is will get you medical help. They will get you legal 19 A I believe so. 19 advice. I think I was in the really good process of 20 Q And you believe you spoke with him about 20 healing. And when this came out, it just ruined me 21 Ghislaine Maxwell's published statement in the press 21 all over again. 22 that claims are obvious lies. 22 Q (BY MS. MENNINGER) All right. Tell me 23 That's what you believe you spoke with 23 all of the damages that you claim occurred to you 24 Dr. Olsen about? 24 because of Defendant's Exhibit 27. 25 A I spoke with Dr. Olsen about being called 25 A My reputation, my psychological abuse,¶
3¶
3 question.¶
I 4 A Can I point to a person -- I'm sorry. I¶
I S don't understand. Can you rephrase it for me --¶
I 6 Q (BY MS. MENNINGER) All right.¶
I 7 A -- so I can understand what you mean?¶
0 MR. Form. 8 Q Where you live in Australia now, has¶
9 9 anyone referenced the name Ghislaine Maxwell to you?¶
10 Q (BY MS. MENNINGER) How do you know which 10 A After all of the news hits, after the¶
11 harm you've suffered is attributable to Ghislaine 11 press hits in 2015 and, you know, everyone is calling¶
12 Maxwell's denial versus Alan Dershowitz's denial 12 me a liar, all of my friends in Australia called me¶
• 13 and talked to me and said, I can't believe this. I¶
14 A Ghislaine Maxwell brought me into the sex 14 can't believe what you went through.¶
15 trafficking industry. She's the one who abused me on 15 That was very embarrassing for something¶
16 a regular basis. She's the one that procured me, 16 that I tried to keep separate from my other life¶
17 told me what to do, trained me as a sex slave, abused 17 where I would like to help victims. I didn't want¶
18 me physically, abused me mentally. 18 the friends of my kids parents knowing about that¶
19 She's the one who I believe, in my heart 19 stuff. You know, and of course they all felt sorry¶
20 of hearts, deserves to come forward and have justice 20 for me. And you know, like I said. I didn't know¶
21 happen to her more than anybody. Being a woman, it's 21 anybody in Penrose. So there's nobody that could¶
22 disgusting. 22 have come up to me and talked to me about it. My¶
23 Q So you cannot delineate what harm you have 23 mom.¶
24 suffered in terms of all of the psychological damage 24 Q This question was about Australia, sorry.¶
25 you just disclosed? 25 A a sorry, I thought you were talking¶
1 A `of course. 1 about pointing out people.¶
2 Q -- if that is attributable to Ghislaine 2 Q No.¶
3 Maxwell's statement on January 2nd versus Alan 3 A Okay, well in Australia, yes, at least a¶
4 Dershowitz calling you a serial liar on Good Morning 4 dozen friends.¶
5 America? 5 Q They came up and they mentioned Ghislaine¶
6 A Of course, it all hurts. Okay? I know 6 Maxwell's denial to the press to you?¶
7 Alan Dershowitz is lying himself. 7 A They couldn't believe what I had been¶
8 Of course those hurt. It 8 through and, you know, that these were, you know,¶
9 doesn't feel good to have people who have done 9 being denied, and they felt sorry for me. And, you¶
10 something to you deny something that's happened, when 10 know, it was the whole circumference of things.¶
11 I'm actually brave enough to come forward and talk n Q So the people in Australia that came up to 12 about it. 12 you had sympathy for you and believed you, correct?¶
13 What hurts me the worst is that Ghislaine 13 A Yes.¶
14 Maxwell brought me into this. Not only has she hurt 14 Q All right. And when you spoke to¶
15 me once, but she's hurt me twice coming forward and 15 Dr. Olsen you recall specifically mentioning¶
16 saying, This is not true, this is categorically 16 Ghislaine Maxwell's press release?¶
17 untrue and obvious lies. 17 MR. : Object to the form.¶
18 That to me is a stick in the mud and that 18 A Yes, I remember mentioning her, as well as¶
19 to me is what caused the most harm to me. 19 the press release, as well as other press releases.¶
20 Q Okay. And so can you point to any person 20 And the abuse that I had occurred (sic) from the¶
21 who has referenced Ghislaine Maxwell's denial in the 21 hands of Jeffrey and Ghislaine.¶
22 press or to your face or anywhere? 22 Q (BY MS. MENNINGER) Okay. When have you¶
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1 Q When were you first told that? I just got to Australia and Judith Lightfoot was 2 A Well, early in -- early in 2003, I believe 2 helping me. 3 Is the first time that I was suffering from 3 4 And then my doctor, Judith 4 . And I told him the reason. 5 Ughtfoot, has in 2011 5 Q And this Is since you returned to 6 6 Australia? 7 And, you know, I've recently seen another 7 A Correct. 6 doctor who said that I've got the exact same symptoms 8 Q And this Is the first time you had seen 9 that Judith Lightfoot mentioned, which Is 9 that doctor? 10 10 A I've seen that doctor twice now. 11 11 Q I'm sorry, what was the name again? I 12 Q Which doctor is that? 12 know you already said it, but I just -- 13 A You know, I don't honestly know his name. 13 A Dr. Donahue. 14 Q When did you see this new doctor? 14 Q Donahue, all right. 15 A Urn -- 15 This doctor that you haven't yet 17 to a doctor that's been sent to you by one of your 17 country? 18 lawyers -- 18 A United States. 19 THE DEPONENT: yes. 19 Q And in what state? 20 MR. : -- at this time, I'm 20 A San Francisco. 21 Instructing you not to answer. 21 Q And when did you see that doctor? 22 THE DEPONENT: Okay. 22 A Um, Friday. Last Friday. 24 seen a doctor and you're not going to answer what 24 doctor? 25 doctor you've seen? 25 A Once. Well, twice actually. I saw him¶
16 MR. : Sorry. If you're referring 16 disclosed, where did you see that person? In what 23 MS. MENNINGER: Wait. What is it? You've 23 Q And how many times have you seen that¶
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1 MR. Sure. If it's a consulting 1 the next day, too. 2 witness in this case that has seen her at the 2 Q All right. Did you suffer from anxiety 3 direction of an attorney, that has not yet been 3 before meeting Jeffrey Epstein? 4 disclosed per any expert witness disclosure, then Fm 4 A I was never prescribed anything for 5 instructing her not to answer that question. 5 anxiety before I met Jeffrey Epstein. 6 If that's what you're referring to. I 6 Q That wasn't my question. 7 don't know if that's what you're referring to. 7 A Did I -- 8 THE DEPONENT: That's what I'm referring 8 Q Were you suffering from anxiety before you 9 to. 9 met Jeffrey Epstein? 10 Q (BY MS. MENNINGER) All right. So you 10 A I think a person who has gone through as 11 recall seeing Dr. Lightfoot. You recall seeing 11 much trauma as I have in my life would suffer from 12 Dr. Olsen. And you recall seeing a new unnamed 12 quite a few problems. But like I said, I was never 13 doctor recently. 13 prescribed anything until I met Jeffrey Epstein. 14 Anyone else you've seen since January 2nd, 14 Q Did you suffer from panic attacks before 15 2015? 15 meeting Jeffrey Epstein? 16 A Dr. Olsen, Dr. Lightfoot. n 16 A Nowhere near as bad, no. 17 Dr. Donahue. 17 Q So you did suffer from 18 Q Where is Dr. Donahue located? 18 They just weren't as severe; is that what your 19 A He's in my suburb or he's a suburb next to 19 testimony is? 20 me in Australia. 20 A No, what I'm trying to say is I did have 21 Q And is that a psychiatric-type doctor, a 21 I did have . I had lived a very 22 medical-type doctor? 22 hard life prior to meeting Jeffrey Epstein as well. 23 A He's medical. 23 After meeting Jeffrey Epstein and 24 Q And what did you see him for or her for? 24 Ghislaine Maxwell, everything escalated. That's when 25 A I didn't have anybody to basically -- I 25 I started to take Xanax and smoke marijuana to help¶
1 calm the anxiety and everything down. 2 Q Before you met Jeffrey Epstein, had you 3 used any drugs? 4 A Sure, yes. 5 Q Which drugs had you used prior to meeting 6 Jeffrey Epstein? 7 A I smoked pot. I've taken Ecstasy. Q Cocaine? 9 A Yeah, I would have snorted cocaine, 10 urn-hum. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Did you ever abuse alcohol before meeting Jeffrey Epstein? A No, I was -- I wasn't even of age to be able to buy it. I mean, if there was alcohol at parties I would have drank it, but I wouldn't say I abused it. Q Okay. Were there ever occasions upon which you were observed to be drunk by other people, prior to meeting Jeffrey Epstein? A If you're drinking, the possibility of getting drunk is always there. I don't -- I can't recall exact situation where that was the case, but -- Q Were you diagnosed as a drug addict prior to meeting Jeffrey Epstein?¶
1 Q How much does it cost you every time you 2 talk to Dr. Lightfoot? 3 A Her normal fee is 5200. 4 Q And how much do you pay? A She doesn't charge me anything anymore. 6 Q When did she stop charging you? 7 A Since I got back to Australia. Q So before you left for Titusville, 9 Florida, you saw her and you were paying $200 per 10 session? 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. Q And what has Dr. Lightfoot recommended that you do in order to get better? A She loves what I'm doing with speaking out. She thinks the more that I speak out about it, the stronger I'll become. She recommends that I write my book, I tell my story. She thinks not only will it help me, but by helping me it'll help others find a way to get out of the situation and to know that there's other girls who have gone through what I've gone through and what they're going through. She recommends meditation, breathing techniques, focus techniques. Q Does she prescribe medications for you? A No, she doesn't. She's a spiritual¶
1 A No, I was not diagnosed as a drug addict. 2 Q Were you sent to live at a rehabilitation 3 facility because of your use of drugs? 4 A No, that was more of a group home. Yes, 5 it was also a rehab facility, but it wasn't because I 6 was a drug addict. I wasn't coming off of anything. 7 Q Had you abused drugs prior to meeting 8 Jeffrey Epstein? 9 A I took drugs. I didn't abuse them, but I 10 took them. 11 Q Okay. 12 A Recreationally. 13 Q How often do you see Dr. Lightfoot? 14 A Once a week every Monday. I've skipped 15 this week because I've been over here and it's 16 expensive to call back home right now, unless you 17 FaceTime, but -- 18 Q Has Dr. Lightfoot recommended that you see 19 a treating doctor in person? 20 A No, she's -- she knows my history pretty 21 well. And she's a very wonderful woman and I 22 honestly wouldn't -- Dr. Donahue wants me to go see 23 another psychiatrist in person, but I prefer to stay 24 with Judith because she's someone I can personally 25 relate to.¶
1 doctor. 2 Q Is there anything that she's recommended 3 that you do that you're not doing? 4 A Is there anything that I do that she 5 recommends I don't? Sorry, say that one more time. 6 Q That's okay. Is there anything that 7 Dr. Lightfoot has recommended that you do that you 8 are not actually doing? 9 Are you following her advice? 10 A Yes, I am. 11 Q Okay. And what has Dr. Donahue 12 recommended that you do?¶