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Case 1:15-cv-Agted? Bian dm GonettReporsin gfe Wieop/Erc.Page 58 of 89 Page 221 Page 223 1 A I wouldn't say that they were untrue. I 1. to why I want my client to answer all of these 2 would just say that she printed them as journalists 2 questions, but I want her to have the fair 3 take your words and turn them into something else. 3 opportunity to see this document. 4 Q_ (BY MS. MENNINGER) She got it wrong? 4 Q_ (BY MS. MENNINGER) Did Sharon Churcher 5 MR. EDWARDS: Object to the form. 5 print things that you felt were inaccurate? 6 Mischaracterization. 6 MR. EDWARDS: Same objection. Same 7 A In some ways, yes. 7 instruction. If she sees the document, she's going 8 Q_ (BY MS. MENNINGER) Did she print things 8 to answer every one of these questions. 9 in her articles that you did not say to her? 9 Q_ (BY MS. MENNINGER) Did any other reporter 10 MR. EDWARDS: I object and ask that the 10 _— print statements that you believe are inaccurate? 11 witness be given the opportunity to see the document 11 MR. EDWARDS: Same objection. Same 12 so that she can review it and answer that question 12 instruction. 13. accurately. Otherwise she's unable to answer the 13 Q. (BY MS. MENNINGER) Did any reporter print 14 question. I'm not going to allow her to answer. 14 statements about Ghislaine Maxwell that were 15 MS. MENNINGER: You know the civil rules 15 inaccurate? 16 tell you not to suggest answers to your client. 16 MR. EDWARDS: Same objection. Same 17 Q. (BY MS. MENNINGER) And you understand 17 instruction. 18 your lawyer is now directing you to not all of a 18 This is harassing. This is harassing a 19 sudden remember what your answer is. That's what 19 sexual abuse victim. And all I'm asking is for 20 he's suggesting that you say. So you're not supposed /20 fairness, that we just let her see the document so 21 to listen to him suggest that to you. You're 21 she can answer this. 22 supposed to tell me from your memory. 22 MS. MENNINGER: Mr. Edwards, please stop 23 MR. EDWARDS: That is not what I'm -- 23. saying anything other than an objection, what the 24 Q. (BY MS. MENNINGER) Did you -- 24 basis is, or instructing your client not to answer. 25 MR. EDWARDS: That's not what I'm doing. 25 MR. EDWARDS: I will do that. Page 222 Page 224 1 You don't get to just talk over me and 1 MS. MENNINGER: That's what the Federal 2 tell my client when not to listen to me. All you 2 Rules of Civil Procedure provide. 3 have to do to get answers is show her the document 3 MR. EDWARDS: I hear you. They also 4 you're talking about, and I'll let her answer every 4 provide for fairness and civility. And all I'm 5 question. I don't know why we're so scared of the 5 asking, very calmly, is for her to see this. 6 actual documents. 6 MS. MENNINGER: Mr. Edwards, this is not 7 MS. MENNINGER: I don't know why you're 7 your deposition. I'm asking your client what she 8 scared of your client's recollection, Mr. Edwards. 8 remembers. If she doesn't want to talk about what 9 But anyway -- 9 she remembers, then let her not answer. But you 10 MR. EDWARDS: Why would you do this to 10 cannot instruct her not to answer unless there's a 11 her? 11 privilege. 12 Q_ (BY MS. MENNINGER) Did Sharon Churcher 12 What privilege -- 13 print things that you did not say? 13 MR. EDWARDS: I am instructing her not to 14 MR. EDWARDS: I'm going to instruct my 14 answer. 15 client not to answer unless you give her what it is 15 Q_ (BY MS. MENNINGER) Allright. You are 16 that you're talking about that was printed. And she 16 refusing to answer questions about whether statements 17. will tell you the answer, the accurate answer to your 17. to the press about Ghislaine Maxwell attributed to 18 question. Just without the document to refresh her 18 you were inaccurate? 19 recollection and see it, she's not going to answer 19 MR. EDWARDS: She's not refusing not to 20 the question. 20 answer. 21 Q_ (BY MS. MENNINGER) Did Sharon Churcher 21 A You are refusing to show me these 22 print things that you did not say? 22 documents so I could answer properly. I would give 23 MR. EDWARDS: Same objection. Same 23 you an answer if you were to show me some documents. 24 instruction not to answer. 24 Q_ (BY MS. MENNINGER) You can't say without 25 I think I've made a very clear record as 25 looking at a document whether the press attributed to VIRGINIA GIUFFRE 5/3/2016 56 (221 - 224)