Giuffre_Maxwell_Batch1_p00807.png

Case 1:15-cvAgr68-Bhin docCamAanRegnunGa g i MideoO3 Inc. Page 7 of 89 Page 17 Page 19 1 (Exhibit 1 marked.) 1 Q_ No. I'm just -- did you find it? 2 Q_ (BY MS. MENNINGER) I'm going to show you 2 A Ican see paragraph 23. 3 an exhibit that we are marking as Defendant's 3 Q_ Okay. And do you see that there are 4 Exhibit 1. 4 allegations about a Ms. Maxwell contained in that 5 MR. EDWARDS: Can I see that for a second? 5 complaint? 6 I'd just like to make an objection on the 6 A Yes, I do. 7 record for the misidentification of this document. 7 Q_ All right. And do you understand that to 8 While there was a lawsuit filed under the 8 be Ghislaine Maxwell, my client? 9 style of Jane Doe versus Jeffrey Epstein, Jane Doe 9 A Yes. 10 was not Virginia Giuffre. And the lawsuit that's now 10 Q_ Allright. And Ms. Maxwell was not sued 11 being handed to this witness is Jane Doe 102 versus 11 as a part of this case, correct? 12 Jeffrey Epstein. 12 MR. EDWARDS: Object to the form. 13 Is that the document we're talking about? 13 THE DEPONENT: Does that mean I can 14 MS. MENNINGER: Counsel, if you have an 14 answer? 15 objection, you should state the basis for your 15 MR. EDWARDS: Sure, you can answer. 16 objection in a non-leading, non-suggestive manner. 16 MS. MENNINGER: Right. 17 If you have any other record to make, you 17 MR. EDWARDS: If you understand the 18 can do so in a pleading filed with the Court. 18 question, answer it. 19 MR. EDWARDS: Sure. My objection is 19 A Yes, Ms. Maxwell -- sorry, repeat the 20 you've misrepresented what you've handed the witness. 20 question. 21 I want to make sure that the witness is holding what 21 Q (BY MS. MENNINGER) Was Ms. Maxwell sued 22. you actually want her to be holding as opposed to the 22 in this -- 23 lawsuit you said that you were going to hand her. 23 A No, she wasn't. 24 That's it. 24 Q__ --in the case that's represented by 25 MS. MENNINGER: Counsel, I will ask the 25 Defendant's Exhibit 1? Page 18 Page 20 1. witness questions about the document. I did not ask 1 A No, she wasn't. I'm sorry for 2 you any questions about the document. 2 interrupting you. But no, she was not sued at this 3 Q_ (BY MS. MENNINGER) Ms. Giuffre, could you 3 time, no. 4 please take a look at what we have marked as 4 Q_ And why not? 5 Defendant's Exhibit 1. 5 MR. EDWARDS: I'd object and ask the 6 Do you recognize that document, 6 witness not answer that question because that would 7 Ms. Giuffre? 7 be privileged, attorney-client privileged, 8 A I believe so. Yes. Yes, I do. 8 information that was between Ms. Giuffre and the 9 Q_ And do you see that the counsel on the 9 Podhurst Orseck firm at that time. 10 last page -- I'm sorry, not the last page, but the 10 So I'm instructing you not to answer. 11 third from the last page are Mr. Josefsberg and 11 Q. (BY MS. MENNINGER) All right. 12 Ms. Ezell from Podhurst Orseck? 12 Ms. Giuffre, did you make a decision yourself whether 13 A Yes. 13. or not to sue Ms. Maxwell as a part of this lawsuit 14 Q_ Were those your lawyers? 14 against -- Jane Doe 102 versus Jeffrey Epstein? 15 A Yes, they were. 15 A I think I've been advised not to answer 16 Q__ And did you authorize them to file Jane 16 that question. 17. Doe 102 versus Epstein on your behalf? 17 Q_sThis is a different question. 18 A Yes, I did. 18 A Oh, okay. 19 Q_ And is that this complaint that's been 19 Q_ So your counsel can assert a privilege, 20 marked as Defendant's Exhibit 1? 20 but that question did not call for privileged 21 A I believe so. 21 information. 22 Q__sIn that document, if I could ask you to 22 MR. EDWARDS: I -- 23 turn to page -- well, I'll turn to page 9 and 23 Q_ (BY MS. MENNINGER) I'm asking about what 24 paragraph 23. 24 -- what you decided to do. Whether you decided to 25 A Would you like me to read it? 25 sue Ms. Maxwell or not at the time Jane Doe 102 VIRGINIA GIUFFRE 5/3/2016 5 (17 - 20)