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Case 1:15-cv-Agted? Bian dm GonettRe poring fe Wines /EAc.Page 27 of 89 Page 97 Page 99 1 Colorado for part of the year, correct? 1 mischaracterized her testimony. She actually just 2 A For part of the year, yes. 2 testified that she may have heard that. 3 Q_ And then you moved to Australia, correct? 3 MS. MENNINGER: No, you're not testifying. 4 A Yes. 4 I've asked her -- 5 Qs You did not live in Florida at any point 5 MR. EDWARDS: I'm clearing the record up 6 in time during 2015, correct? 6 right now, though. 7 A I believe I left Titusville at the end of 7 MS. MENNINGER: You can object based on 8 2014. 8 form. That's a valid objection. You've made your 9 Q_ Okay. So you did not live in Florida 9 record. 10 =©during 2015, correct? 10 Q_ (BY MS. MENNINGER) Did you review records 11 A I believe so. 11 that clarified dates for you? 12 Q_ All right. So when you reviewed these 12 A I've either reviewed them or I've been 13. records sometime in 2015 that caused you to know the | 13 told about -- I can't remember. I'm sorry. I 14 real date of when you worked at Mar-a-Lago, where 14 know -- I know now that the dates are what they are, 15 were you physically located? 15 but I don't remember. 16 MR. EDWARDS: Object to the form and 16 Qs You don't know when you learned that the 17. ~mischaracterized her testimony. 17. dates are what they are? 18 A I don't remember where I saw these 18 A No, I don't. 19 records, when I saw these records. I know it wasn't 19 Q_ And your best guess is what? 20 a year ago. I know it was more recent. I can't 20 MR. EDWARDS: Objection. 21 pinpoint the date that I actually saw them, but I 21 If any of your answer is based on 22 recently, I believe -- I don't know. I don't want to 22 attorney-client privilege, I'm instructing you not to 23 sit here and speculate and then give you the wrong 23 answer. 24 answer. It's just new knowledge for me. 24 A I can't answer, then. 25 Q (BY MS. MENNINGER) All right. Did you 25 Q_ (BY MS. MENNINGER) Okay. So have your Page 98 Page 100 1 receive the records by e-mail? 1. attorneys told you to change your dates? 2 A I believe so. 2 MR. EDWARDS: Objection. 3 Q_ Okay. Did you use any e-mail address 3 Do not answer that question. This is a 4 other tha i 7_ 7 4 question intentionally devised to invade the 5 A No. 5 attorney-client privilege. 6 Q__ That's the only e-mail address that you've 6 She's not going to answer those questions. 7 used? 7 Q_ (BY MS. MENNINGER) You can answer a 8 A That's correct. 8 question about whether your attorneys had told you to 9 Q_ And the Mar-a-Lago records that you 9 lie. Because that would be a crime, and I'm sure -- 10 reviewed you received by e-mail at that e-mail 10 A Iwill -- 11 address? 11 Q_ _-- I'm sure you want to tell me that your 12 A Possibly. I mean, I can't say 12 attorneys did not tell you to lie, correct? 13 100 percent. I could have been told about them. I 13 A Ican tell you for a fact my attorneys 14 could have seen them on a piece of paper. I really 14 have never told me to lie. 15 don't know. This is a very hazy subject. All I know 15 Q_ Allright. And did your attorneys tell 16 is that I found out and that was able to clarify a 16 you to change a date? 17 lot of dates for us. 17 MR. EDWARDS: Objection. She's not 18 Q_ Okay. What other dates were clarified? 18 answering any questions about communications between 19 MR. EDWARDS: I object and instruct the 19 her lawyers and herself, period. 20 witness not to answer if any of your knowledge is 20 Q_ (BY MS. MENNINGER) So if I could also 21 based on any privileged communication that you had 21 direct your attention to Defendant's Exhibit 8. It's 22 between yourself and any of your lawyers. 22 the manuscript. If you could turn to page 40. 23 Q_ (BY MS. MENNINGER) Okay. You just said 23 THE VIDEOGRAPHER: I just have a quick 24 you reviewed records yourself, correct? 24 ~~ request, Counsel. 25 MR. EDWARDS: Object. That 25 Ms. Giuffre, would you mind bringing the VIRGINIA GIUFFRE 5/3/2016 25 (97 - 100)