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Case 1:15-cv-Agted? Ban dm GonettReporsin g Se Wieop/EAc.Page 14 of 89 Page 45 Page 47 1 A __ Based upon the title, it is Plaintiff's 1 Do you see your attorney's signature and 2 Response and Objections to Defendant's First Set of 2 the date, March 22nd, 2016, correct? 3 Discovery Requests to Plaintiff. 3 A Ido. 4 Q_ And are you the plaintiff? 4 Qs Allright. And then looking at 5 A Iam the plaintiff, yes. 5 Defendant's Exhibit 11, that's your declaration, 6 Q_ Allright. So it's your response to 6 correct? 7 Ms. Maxwell's discovery request, correct? 7 A Yes, it is. 8 A Correct. 8 Q_ And declaring under penalty of perjury as 9 Q_ Allright. And if you look at the last 9 of March 22nd, 2016 that the supplemental response 10 page -- or, I'm sorry, it would be the second to last |10 and objections are true and correct, right? 11 page -- you might see signatures of your attorney, 11 A Correct. 12 correct? 12 Q__ And you -- that's your signature? 13 A I see printed names. 13 A That is mine. 14 Q_ ‘Printed. Electronic signature -- 14 Q_ And you are swearing under penalty of 15 A Okay. 15 perjury that Defendant's Exhibit 10 is true and 16 Q__-- will have a little S in front of it. 16 correct? 17 A All right. 17 A Yes. 18 Q__Do you see that? 18 Q_ As of March 22nd, 2016, right? 19 A Ican see the, yeah the printed names. So 19 A Yes. 20 _ if it's electronic signature, then yes. 20 Q_ Allright. And then one more on that. 21 Q_ Allright. And the date on that is 21 Defendant's Exhibit 12. 22 March 16th of 2016? 22 (Exhibit 12 marked.) 23 A Correct. 23 Q_ (BY MS. MENNINGER) And do you recognize 24 Q_ Allright. And so without revealing the 24 this document? 25 content of your conversations, you assisted in 25 A Yes. Page 46 Page 48 1 preparing responses to discovery requests, correct? | 1 Q_ Okay. And what is this document? 2 A Yes. 2 A __ Plaintiff's Second Amended Supplemental 3 Q_ Allright. I'm going to show you a 3 Response and Objections to Defendant's First Set of 4 subsequent one marked Defendant's Exhibit 10 and 4 Discovery Requests to Plaintiff. 5 dated March 22nd. 5 Q_ Allright. And again, turning to the very 6 (Exhibit 10 marked.) 6 rear section, I think you'll see your attorney's 7 Q_ (BY MS. MENNINGER) If you can take a look | 7 signatures again and the date of April 29th, 2016? 8 at that. 8 A Ido see that. 9 A Thank you. 9 Q_ Allright. And again, you authorized this 10 Q__ And while we're at it, I'm going to give 10 document to be filed, correct? 11 you Defendant's Exhibit 11 so you can look at them |11 A Correct. 12 together. 12 Q__ And the statements contained therein are 13 (Exhibit 11 marked.) 13 true, to the best of your knowledge, correct? 14 Q (BY MS. MENNINGER) All right. 14 A Correct. 15 A Thank you. 15 Q__ And that's -- April 29th is just a few 16 Q_ Allright. So looking at Defendant's 16 days ago, correct? 17. Exhibit 10, do you recognize that document? 17 A Yes. 18 A Plaintiff's Supplemental Response and 18 Q_ Allright. Did you review this April 29th 19 Objections to Defendant's First Set of Discovery 19 document before it was filed or served? 20 Requests to Plaintiff. 20 A Like I said, I've seen a lot of documents 21 I've seen a lot of documents, and they all 21 and they all look alike, but I'm sure I've seen this 22 look the same. But I'm sure I've seen it. 22 ~~ one. 23 Q_ Allright. And looking, again, at the 23 Q_ Okay. And if it's something that was 24 last page -- or I'm sorry, this time it will be the 24 served last Friday, does that refresh your 25 third to last page. 25 recollection that you reviewed it before it was VIRGINIA GIUFFRE 5/3/2016 12 (45 - 48)