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Case 1:15-cv-Agted? Bian dm GaonettRe porting Se Wineop/EAc.Page 77 of 89 Page 297 Page 299 1 e-mailing and speaking with Sharon Churcher in 2011 1 A __ I believe there was -- and this is just 2 about the Vanity Fair possibly purchasing your 2 going off my recollection. 3 photograph -- 3 Q Um-hum. 4 A Um-hum. 4 A __ I believe there was a time when she was -- 5 Q_ -- do you recall whether you shared with 5 oh, God, I can't remember. I really can't remember 6 Sharon Churcher anything that you had discussed with 6 and don't want to say anything without looking at 7 your attorney, Mr. Edwards? 7 that exact e-mail. Do you have it to show me? 8 A __ Inrelationship to what? Like, have I 8 Q_ ‘Well, I'm sure it's probably in there but 9 identified people to her? 9 I don't want to take the time to look for it now. 10 Q_ Right. 10 A Okay. 11 A Yes. 11 Q. SoTI understand you're just repeating what 12 Q_ Okay. So you -- you identified people to 12 you recall from your memory. 13 her and you then looped back to her about your 13 A Yes. 14 conversations with Mr. Edwards, correct? 14 Q_ And it may not be accurate because you're 15 MR. EDWARDS: Object to the form. 15 not looking at the document. I've got that caveat. 16 A I'm sorry, can you rephrase? I don't 16 What do you recall, just as you're sitting 17. understand. 17. ~+there? 18 Q. (BY MS. MENNINGER) All right. So you 18 A I know there was e-mails that Sharon sent 19 were e-mailing with her -- 19 to me suggesting to say to Brad Edwards, I know that. 20 A Um-hum. 20 I don't remember or recall exactly what was in those 21 Q_ -- getting her advice about whether or not 21 statements. 22 to sell your Prince Andrew picture to Vanity Fair? 22 Q_ Okay. And did you send those e-mails to 23 A _ Right. 23 Mr. Edwards, as you recall today? 24 Q_ She asked you to run some information by 24 A I don't know. I'm sorry. 25 Brad -- 25 Q_ And do you know if you went back to Sharon Page 298 Page 300 1 A Yes. 1 Churcher and told her about the conversations or 2 Q_ -- Edwards. And you said that you were 2 e-mails you had with Mr. Edwards? 3 going to do that? 3 A Some of them, I'm sure, yes. 4 A Um-hum. 4 Q__sBecause you were in fairly regular contact 5 Q__ And then you spoke to Mr. Edwards, 5 with Sharon Churcher at that time, correct? 6 correct? 6 A _ Right, at that time. 7 A __ I don't know if I spoke to him or if I 7 Q_ Allright. I want to introduce to you 8 e-mailed him. 8 Defendant's Exhibit 26. 9 Q_ Okay. And then did you report back to 9 (Exhibit 26 marked.) 10 Sharon Churcher what you had discussed with 10 Q. (BY MS. MENNINGER) Have you seen this 11 Mr. Edwards? 11 document before? 12 A I'm not too sure. Like I said, going back 12 A __ I don't know if I've seen this specific 13 to the 2011 e-mails, look at this pile here. It's 13 document before, but I've seen something close to it, 14 impossible for me to know. 14 I think. 15 Q_ So you were having a lot of communications |15 Q_ Allright. Do you see the date on the 16 with Sharon Churcher in 2011? 16 document? 17 A In 2011, yes. 17 A March 10th, 2011. 18 Q_ Allright. And Mr. Edwards was your 18 Qs March 9th? 19 attorney in 2011, correct? 19 A __ I see March 10th, sorry. 20 A Yes. 20 Q Hmm. 21 Q_ And did you ever have Sharon Churcher 21 A London, March 10th, 2011. 22 ~~ draft for you e-mail to send to Mr. Edwards? 22 MR. EDWARDS: Both dates are there. 23 A Yes, I believe -- I believe she did. 23 MS. MENNINGER: I'm sure they are. I'm 24 Q_ And why did she draft e-mails for you to 24 just not seeing the one that you're seeing. 25 send to Mr. Edwards? 25 THE DEPONENT: Oh, I'm sorry. VIRGINIA GIUFFRE 5/3/2016 75 (297 - 300)