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Case 1:15-cv-Agted? Bian dm GonettReQorsin gfe Wines /Erc.Page 13 of 89 Page 41 Page 43 1 Q_ Okay. And then the last -- the last 1 as you sit here right now, is there anything in that 2 document, I hope, is -- 2 manuscript about Ghislaine Maxwell that is untrue? 3 MS. MENNINGER: The big one. 3 A I don't believe so. Like I said, there is 4 (Exhibit 8 marked.) 4 a lot of stuff that I actually have left out of here. 5 Q_ (BY MS. MENNINGER) All right. Do you 5 Q Um-hum. 6 recognize -- I'm going to -- I'm sorry, if I didn't 6 A __ So there is a lot more information I could 7 say it already. This is Defendant's Exhibit 8. 7 putin there. But as far as Ghislaine Maxwell goes, 8 Do you recognize this document? 8 I would like to say that there is 99.9 percent of it 9 A Yes, I do. 9 would be to the correct knowledge. 10 Q_ And what is this document? 10 Q_ Allright. Is there anything that you -- 11 A __ This is a manuscript that I was writing, I 11 and I understand you're doing this from memory. Is 12 believe, back in 2011 regarding some of my life 12 there anything that you recall, as you're sitting 13 story. And just to make it known, this is a based on 13 here today, about Ghislaine Maxwell that is contained 14 true events. But I wouldn't say fictional, but just 14 in that manuscript, that is not true? 15 based on true events. 15 A You know, I haven't read this in a very 16 Not everything in it is -- not everything 16 long time. I don't believe that there's anything in 17 _ is in there and not everything is, you know, correct. 17 here about Ghislaine Maxwell that is not true. 18 So there's a few mistakes in there. 18 MR. EDWARDS: I'd just ask, Counsel, if 19 Q_ Okay. Off the top of your head, do you 19 you have anything specific to show her about 20 recall any mistakes that are in there now without 20 Ghislaine Maxwell -- 21 reading the 140-page document? 21 MS. MENNINGER: I'll ask questions. 22 MR. EDWARDS: We're going to be here a 22 MR. EDWARDS: -- I'll have her look at it. 23 long time. 23 MS. MENNINGER: I'll ask questions. 24 A Yeah, we could be here a very long time. 24 MR. EDWARDS: I know, but I want the 25 I mean, I'd like to say a majority of it is correct. 25 record clear that if she hasn't read it in a long Page 42 Page 44 1 Some names have been changed in order to protect 1 time, she -- 2 other people. 2 MS. MENNINGER: She made the record very 3 Q_ (BY MS. MENNINGER) Protect their privacy? | 3 clear. Thank you. She doesn't need you to make a 4 A __ Protect their privacy, yeah, I would say, 4 record. 5 just not getting them involved in, if this were to 5 MR. EDWARDS: I'm not making records, but 6 ever go public. 6 you're making this last longer. There's no need for 7 Q_ Well, again, without rereading the whole 7 this. This doesn't have to be an unpleasant process. 8 manuscript -- 8 I want her to help you. 9 A Reading it, yeah. I'm trying to see if I 9 MS. MENNINGER: I don't find it 10 can -- see something in here. 10 unpleasant. I'm sorry if you do. 11 Q___Let me narrow my question and maybe that |11 MR. EDWARDS: Okay. Well, then, I object 12 ~~ will help. 12 to that last series of questions to the extent that 13 A Yes. 13 she was unable to look at what you wanted her to look 14 Q__sIs there anything -- well, first of all, 14 at. 15 did you author that entire manuscript? 15 Q_ (BY MS. MENNINGER) I would like to next 16 A Yes, I did. 16 turn to a document filed on March 16th of this year. 17 Q__ Did anyone else author part of that 17. Or actually, let me rephrase that. A document dated 18 manuscript? 18 March 16th of this year, which we will mark as 19 A Do you mean did anyone else write this 19 Defendant's Exhibit 9. 20 with me? 20 (Exhibit 9 marked.) 21 Q_ Right. 21 Q_ (BY MS. MENNINGER) Do you recognize this 22 A No. 22 document, Ms. Giuffre? 23 Q That's all your writing? 23 A Yes, I do. 24 A __ This is my writing. 24 Q_ Allright. And what is your understanding 25 Q_ Okay. To the best of your recollection, 25 of what this document represents? VIRGINIA GIUFFRE 5/3/2016 11 (41 - 44)