Giuffre_Maxwell_Batch1_p00810.png

Case 1:15-cv-Agted? Bian dm GonettReporsin gfe Wineop/Erc.Page 10 of 89 Page 29 Page 31 1 Q__ And based on the fact that you learned the 1 Q. (BY MS. MENNINGER) I'm going to show you 2 fact you had worked at Mar-a-Lago in 2000 -- you 2 an exhibit filed on, I believe on or about 3 became aware in mid-2015 -- 3 February 6th of 2015. Defendant's Exhibit 4. 4 A Um-hum. 4 (Exhibit 4 marked.) 5 Q_-- that you had met Ms. Maxwell in 2000, 5 MR. EDWARDS: Thank you. 6 correct? 6 Q. (BY MS. MENNINGER) And drawing your 7 A _ That's -- 7 attention to the heading line that says, Entered on 8 MR. EDWARDS: Object to the form. 8 the docket February 6th, 2015. 9 A __ That's correct. 9 Do you see that? 10 Q. (BY MS. MENNINGER) All right. And you 10 A Yes. 11 became aware in mid-2015 that you were not 15 years |11 Q_ Allright. And Declaration of Jane Doe 3, 12 old when you met Ghislaine Maxwell, correct? 12 do you see that on the first page? 13 MR. EDWARDS: Object to the form. 13 A Yes. 14 A __ That's correct. 14 Q And it's in the CVRA case, correct, Jane 15 Q. (BY MS. MENNINGER) Okay. And who 15 Doe 1 and Jane Doe 2 versus United States of America? 16 provided you those Mar-a-Lago records in 16 A Yes. 17 approximately mid-2015? 17 Qs Allright. And do you recognize this 18 MR. EDWARDS: I'm going to object. 18 document? 19 And to the extent that this invades the 19 A Yes. 20 attorney-client privilege, if it was your attorneys 20 Q_ And what do you understand this document 21 that you spoke to and learned this information or 21 tobe? 22 received this information from, then you're 22 A I believe it's more reason to why I should 23 instructed not to answer. 23 have been added to the CVRA case. 24 A I cannot answer that question. 24 MR. EDWARDS: Objection to the relevance, 25 Q (BY MS. MENNINGER) Did you yourself look 25 Counsel. Page 30 Page 32 1 at records in the middle of 2015 regardless of who 1 Q. (BY MS. MENNINGER) Okay. And again, if 2 showed them to you? 2 you look to the last page of the document, 3 MR. EDWARDS: Objection. And to the 3 paragraph 67 -- 4 extent that they were showed to you or shared by any 4 A The last page? 5 of your lawyers, you're instructed not to answer the 5 Q_ Yes, the very last. 6 question. It invades the attorney-client privilege. 6 A 67, yes. 7 Q. (BY MS. MENNINGER) Did you look at 7 Q. Allright. It says in paragraph 67: I 8 Mar-a-Lago records in the middle of 2015 yourself? 8 declare under penalty of perjury that the foregoing 9 MR. EDWARDS: She's not answering the 9 is true and correct, right? 10 question. 10 A Yes. 11 MS. MENNINGER: On what grounds is she not 11 Qs And it was executed on or about the 12 answering the question? 12 5th day of February, 2015, correct? 13 MR. EDWARDS: I just told you it invades 13 A It's a bit smudged, but it kind of looks 14 the attorney-client privilege. If she learned -- 14 like a5. 15 I will instruct her if she learned by some 15 Qs Allright. And then there's a signature 16 other way than her attorneys sharing the information 16 block that's redacted that says Jane Doe 3, correct? 17 with her, then she can answer the question. 17 A Correct. 18 Q. (BY MS. MENNINGER) I'm asking you not to 18 Q__—Do you believe that you signed this 19 tell me whether your attorneys showed you the record. |19 document and it was later covered up by that block? 20 I'm asking you not to tell me the source of the 20 A Yes. 21 record. 21 Qs Allright. And again, is there anything 22 I'm asking you if you personally in the 22 in this document that you believe today to not be 23 middle of 2015 looked at Mar-a-Lago records? 23 true? 24 MR. EDWARDS: Same objection. 24 MR. EDWARDS: I just ask that you read 25 Same instruction. 25 through the entire document and answer the question. VIRGINIA GIUFFRE 5/3/2016 8 (29 - 32)