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Case 1:15-cv-Agtes? Ban dm GonettReporsin g Se Wines /Erc.Page 69 of 89 Page 265 Page 267 1 Q. Allright. Since these e-mails come from 1 backwards. 2 your e-mail address to and from Paulo Silva, do you 2 Q_ Right. So if an e-mail is responding to 3 have any reason to doubt that they are your e-mails? 3 May 25th, is it more or less likely that it was 4 A Ihave no reason to doubt. 4 written on June 5th or May 6th? 5 Qs Allright. Do you recall a Sandra White? 5 MR. EDWARDS: Object to the form. 6 A Yes. She was a possible ghostwriter that 6 A I would say May 6th. 7 I was going to use. Sharon recommended that I got a 7 Q (BY MS. MENNINGER) So when responded to a 8 ghostwriter to be involved. And we nearly settled on 8 May 25th -- 9 some kind of agreement, but I wasn't really happy 9 A Oh, no, you're right. No, I'm sorry, I'm 10 with the agreement in the end, so I decided not to 10 going backwards because it's going up, isn't it? 11 use her. 11 Okay. Yes. 12 Q = You weren't happy with the terms of her 12 Qs Allright. 13 price, if you will? 13 A __ I'm confused, too. 14 A Yes. 14 Qs Anyway. In the last e-mail it says: I'm 15 Q_ And so you didn't come to an agreement 15 very sad we won't be able to work together as I've 16 with her, correct? 16 been very excited about the project. As you know, I 17 A We nearly did, but we in the end did not. 17 do not sell synopsis or individual chapters, and 18 Q. Allright. If I can show you Defendant's 18 especially not for those amounts. I'm merely 19 Exhibit -- whew -- 18. 19 intrigued about where you were getting advice from. 20 MR. EDWARDS: You did kill a tree there. 20 Rest assured what we have worked on is confidential. 21 Q. (BY MS. MENNINGER) Take a look at that. 21 If you change your mind, let me know. 22 (Exhibit 18 marked.) 22 So that was around June 5th? 23 THE DEPONENT: So put this one away? 23 A 2011. 24 MR. EDWARDS: Put these in some sort of 24 Q 2011, right? 25 order. They don't have to be perfect, but just so 25 A Yes. Page 266 Page 268 1 you know what you're looking at. 1 Q_ Allright. So you had been trying to 2 This is 18? 2. reach an agreement with Sandra White prior to 3 Q_ (BY MS. MENNINGER) All right. Again, do 3 June 5th? 4 you recognize that the e-mail address -- 4 A Correct. 5 A Is mine. 5 Q__ And were unable to do so? 6 Q__--is yours and it's from and to Sandra 6 A Yes. 7 White, correct? 7 Q___ And not that you need to read every page, 8 A Correct. 8 but is it fair to say that you exchanged some 9 Q_ And the date is in or around May 25th, 9 portions of your synopsis with Sandra during the 10 June 5th, something like that? 10 course of your interactions with her? 11 A It's Australian so it's backwards. So 11 A Yes. And she rewrote some portion of it 12 it's the 6th of May, 2011. 12 as well, which I don't even know, it might be in 13 Q_ Well, I would have thought that except the 13 here. It might not be in here. I don't know what 14 bottom e-mail is May 24th, the middle one is May 25th |14 I've kept or not kept. 15 and then the most recent one says 6/5. So I don't -- 15 Q_ Okay. And did you get advice from Sharon 16 Idon't know. I didn't write the document. 16 Churcher with respect to the terms upon which you 17 A Yeah. 17. should be looking for the ghostwriting agreement? 18 Qs But I'm asking if you believe it was in or 18 A __ Sharon is the one who introduced me to 19 around the end of May? 19 Sandra. I can't remember who was giving me the 20 A The only reason I can tell you that is 20 advice. It's going back so long ago, you know, I 21 because if you look here, 24/5/11 is the way that we 21 don't want to pinpoint somebody and say it was 22 actually do our dates in Australia, whereas in 22 definitely them if it wasn't. 23 America you would do 5/24/11. 23 So, yeah, I'm just not going to comment on 24 So right here where it's written makes it 24 that one without knowing. 25 nice and clear but just to be clear, the dates are 25 Q_ Okay. You probably have e-mails, though, VIRGINIA GIUFFRE 5/3/2016 67 (265 - 268)