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Case 1:15-cvAgHh68-BAin docCamAnRegnn-Ha g i AMideo3 Inc. Page 6 of 89 Page 13 Page 15 1 A I'd say in his 40s. 1 A Yes. 2 Q_ Okay. And where did you meet him? 2 Q_ And which ones did you review? 3 A I believe it was New Mexico. 3 A __ I'd have to see which ones you're 4 Q New Mexico? 4 specifically talking about. There's quite a lot of 5 A _ Possibly New Mexico. I'm sorry. It's 5 statements I've made. 6 really hard to go back and remember lots of different 6 Q_ Right. And which ones do you recall 7 events with lots of different people. 7 having reviewed before you attended this deposition 8 Q_ Okay. And is that the only foreign 8 today? 9 president that you have met? 9 A I've reviewed my affidavit. I'm nota 10 A _ I've met a lot of very high, powerful 10 lawyer so I really don't know legal terms to half of 11 people and I wasn't just introduced to them as who 11 the, you know, legal jargon of statements, which they 12 they were. It's only going back through photos in 12 are. If you showed me, I'd be able to tell you if 13 time to be able to realize who they are and what they 13 I've seen it or not. 14 are now. So it's hard for me to distinguish who I've 14 Q_ Okay. So to your knowledge, can you 15 actually met and when and where I've met them. 15 identify any sworn statement you reviewed before 16 Q__ So to your knowledge, you have only met 16 attending the deposition today? 17. one foreign president? 17 A Could I name what the statement is? 18 A To my knowledge at this time, yes. 18 Q_ Right. 19 Q_ And is there anything that might change 19 A The actual piece of paper that has the 20 your knowledge at a different time? 20 title at the top? 21 A __ If I were to see more photos of other 21 Q_ Right. 22 people. I mean, I've been able to distinguish the 22 A No, I don't. 23 majority of the people I've been lent out to, but 23 Q_ Can you describe it in any other fashion? 24 who's to say there's not more. 24 A I don't understand. I'm sorry. 25 Q_ Allright. If I were to ask you the 25 Q_ That's all right. You have to tell me if Page 14 Page 16 1 question how many times have you had sex with Tom | 1 ‘you don't. 2 Pritzker, do you know what that question means? 2 Do you have any reason to believe that any 3 A I believe so. 3 of your previous sworn statements that you have made 4 Q_ Allright. And what is the answer to that 4 are not true? 5 question? 5 A No. 6 A I believe I was with Tom once. 6 MR. EDWARDS: I just object and ask that 7 Q_ Okay. I would like to ask you about your 7 if we're going to ask the witness questions about any 8 prior sworn statement. 8 of her statements in whole or in part that the 9 You understand you're under oath today, 9 witness be allowed to see the statement, review the 10 correct? 10 statement and then answer your questions. 11 A Yes. 11 Q_ (BY MS. MENNINGER) You may answer the 12 Q_ Allright. You've previously made 12 question. 13 statements under oath, correct? 13 A Can you reask the question? I'm sorry. 14 A Yes. 14 Q__Do you have any reason to believe that any 15 Q_ And you've previously authorized pleadings 15 of your prior sworn statements are untrue? 16 to be filed on your behalf, correct? 16 A Ihave no reason to believe that my prior 17 A Yes. 17. statements are untrue. 18 Q__sBy various attorneys, right? 18 Q__ Has anyone told you to say something that 19 A Yes. 19 was not true in connection with this case? 20 Q_ Allright. You have included in your 20 A No, ma'am. 21 sworn statement allegations about my client, 21 Q_ Allright. I'd like to start witha 22 Ghislaine Maxwell, correct? 22 lawsuit that you filed under the caption Jane Doe 23 A Yes. 23 versus Jeffrey Epstein. 24 Q_ And did you review any of those prior 24 Do you recall that lawsuit? 25 sworn statements before appearing here today? 25 A I believe so. VIRGINIA GIUFFRE 5/3/2016 4 (13 - 16)