Giuffre v. Maxwell Documents (July 2020)

Case 1:15-cv-07433-LAP Document 1090-1 Filed 07/30/20 Page 1 of 4
United States District Court

Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
V.
Ghislaine Maxwell,
Defendant.
I
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DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF
PLAINTIFF'S MOTION TO COMPEL DEFENDANT TO ANSWER
DEPOSITION QUESTIONS FILED UNDER SEAL
I, Sigrid S. Mccawley, declare that the below is true and correct to the best of my
knowledge as follows:
1. I am a partner with the law firm of Boies, Schiller & Flexner LLP and duly
licens ed to practice in Florida and before this Court pursuant to this Court's September 29, 2015
Order granting my Application to Appear Pro Hae Vice.
2. I respectfully submit this Declaration in support of Plaintiffs Motion to Compel
Defendant To Answer Deposition Questions Filed Under Seal.
3. Attached hereto as Exhibit 1, is a true and correct copy of page 21 of Defendant
Maxwell's April 22, 2016 Deposition transcript.
4. Attached hereto as Exhibit 2, are true and correct copies of page s 19-22 of
Defendant Maxwell's April 22, 2016 Deposition transcript.

5. Attached hereto as Exhibit 3, is a true and correct copy of the Palm Beach police
report.
6. Attached hereto as Exhibit 4, are true and correct copies of pages 60-62 of
Defendant Maxwell's April 22, 2016 Deposition transcript.
8. Attached hereto as Composite Exhibit 6, are true and correct copies of pages 52-
55; 64-65; 82; 92-93; 137-38; 307-09 of Defendant Maxwell's April 22, 2016 Deposition
transcript.
I declare under penalty of perjury that the foregoing is true and correct.
Dated: May 5, 2016.
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By:
ro Hae Vice)
Boies , Schiller Flexner LLP
401 E. Las Olas Blvd. , Suite
1200 Ft. Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies, Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
Ellen Brockman
575 Lexington Ave
New York, New York 10022
(212) 446-2300
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on May 5, 2016, I electronically filed the foregoing document
with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document
is being served this day on the individuals identified below via transmission of Notices of
Electronic Filing generated by CM/ECF .
Laura A. Menninger, Esq.

Jeffrey Paliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th A venue
Denver, Colorado 80203
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: lmenninger@hmflaw.com
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
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...
............................................
VIRGINIA L. GIUFFRE,
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
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DECLARATION OF JEFFREY S. PAGLIUCA IN SUPPORT OF DEFENDANT’S

COMBINED RESPONSE TO PLAINTIFF’S MOTION TO COMPEL DEFENDANT
TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL AND MOTION
TO TERMINATE OR LIMIT PURSUANT TO F.R.CIV.P. 30(d)(3)
I, Jeffrey S. Pagliuca, declare as follows:
1. I am an attorney at law duly licensed in the State of Colorado and admitted to
practice in the United States District Court for the Southern District of New York pro hac vice. I
am a member of the law firm Haddon, Morgan and Foreman. P.C., counsel of record for
Defendant Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration
in support of Maxwell’s Combined Response to Plaintiff’s Motion to Compel Defendant to
Answer Deposition Questions Filed Under Seal and Motion to Terminate or Limit Pursuant to
F.R.Civ.P. 30(d)(3).
2. Attached as Exhibit A is a true and correct copy of composite pages from
Defendant’s April 22 ,2016 Deposition Transcript.

I declare under penalty of perjury that the foregoing is true and correct. Executed on
May 10, 2016 in Denver, Colorado.
By: /s/ Jeffrey S. Pagliuca

Jeffrey S. Pagliuca
I certify that on May 10, 2016, I electronically served this DECLARATION OF

JEFFREY S. PAGLIUCA IN SUPPORT OF DEFENDANT’S COMBINED RESPONSE TO
PLAINTIFF’S MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS
FILED UNDER SEAL AND MOTION TO TERMINATE OR LIMIT PURSUANT TO F.R.CIV.P.
30(d)(3)via ECF on the following:
Sigrid S. McCawley Paul G. Cassell

Meridith Schultz S.J. Quinney College of Law, University of
BOIES, SCHILLER & FLEXNER, LLP Utah
401 East Las Olas Boulevard, Ste. 1200 383 S. University Street
Ft. Lauderdale, FL 33301 Salt Lake City, UT 84112
smccawley@bsfllp.com cassellp@law.utah.edu
mschultz@bsfllp.com
Bradley J. Edwards
FARMER, JAFFE, WEISSING, EDWARDS,
FISTOS & LEHRMAN, P.L.
425 North Andrews Ave., Ste. 2
Ft. Lauderdale, FL 33301
brad@pathtojustice.com
/s/ Nicole Simmons
Nicole Simmons
2

v.
Ghislaine Maxwell,
Defendant.
______________________________/
DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF

PLAINTIFF’S REPLY IN SUPPORT OF HER MOTION TO COMPEL DEFENDANT
TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL
I, Sigrid S. McCawley, declare that the below is true and correct to the best of my
licensed to practice in Florida and before this Court pursuant to this Court’s September 29,
2015 Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in support of Plaintiff’s Reply in Support of
her Motion to Compel Defendant To Answer Deposition Questions Filed Under Seal.
3. Attached hereto as Exhibit 1, is a true and correct copy of Excerpts from the
April 22, 2016 Deposition Transcript of Ghislaine Maxwell.
4. Attached hereto as Composite Exhibit 2, are true and correct copies of the Flight
Logs of Jeffrey Epstein’s private planes and summary charts.
5. Attached hereto as Exhibit 3, is a true and correct copy of the Palm Beach Police
Report.
6. Attached hereto as Exhibit 4, are true and correct copies of Excerpts from the
July 29, 2009 Deposition Transcript of Alfredo Rodriguez.
7. Attached hereto as Exhibit 5, is a true and correct copy of Excerpts from Juan
Alessi’s November 21, 2005 Sworn Statement.
September 8, 2009 Deposition Transcript of Juan Alessi.
August 7, 2009 Deposition Transcript of Alfredo Rodriguez.
/s/ Sigrid S. McCawley_________

Sigrid S. McCawley, Esq.
Dated: May 11, 2016.
By: /s/ Sigrid McCawley________________

Sigrid McCawley (Pro Hac Vice)
Boies, Schiller & Flexner LLP 401 E.
Las Olas Blvd., Suite 1200 Ft.
Lauderdale, FL 33301
(954) 356-0011
David Boies
Boies, Schiller & Flexner LLP 333
Main Street
Armonk, NY 10504
Bradley J. Edwards (Pro Hac Vice)

FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
(954) 524-2820
Paul G. Cassell (Pro Hac Vice)

S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake City, UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
I HEREBY CERTIFY that on May 11, 2016, I electronically filed the foregoing
document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of
Notices of Electronic Filing generated by CM/ECF.

150 East 10th Avenue
Tel: (303) 831-7364
Fax: (303) 832-2628
jpagliuca@hmflaw.com
/s/ Sigrid S. McCawley


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..
.............................................
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
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MOTION TO COMPEL ALL ATTORNEY-CLIENT COMMUNICATIONS AND

ATTORNEY WORK PRODUCT
PLACED AT ISSUE BY PLAINTIFF AND HER ATTORNEYS
Laura A. Menninger
Jeffrey S. Pagliuca
HADDON, MORGAN, AND FOREMAN, P.C.
East 10th Avenue
Denver, CO 80203
303.831.7364
TABLE OF CONTENTS
TABLE OF AUTHORITIES ....................................................................................................... ii
CERTIFICATE OF CONFERRAL ............................................................................................ 1
INTRODUCTION......................................................................................................................... 1
BACKGROUND FACTS RELEVANT TO DISPUTE ................................................................. 2
1. Correspondence re: Jane Doe #1 and Jane Doe #2 v. United States.................................... 2

2. Correspondence re: Giuffre v. Maxwell, 15-cv-07433-RWS .............................................. 2
3. Correspondence re: Bradley Edwards and Paul Cassell v. Alan Dershowitz ...................... 3
4. Correspondence re: Jane Doe No. 102 v. Jeffrey Epstein.................................................... 3
5. Categorical Entry re: correspondence potential legal action against entities and individuals
3
I. The Attorney-Client and Work Product Privilege Standards and Limitations ............. 7
a. The Attorney-Client Privilege .............................................................................................. 7

b. Work Product Privilege ....................................................................................................... 7
II. Plaintiff and her Attorneys Waived Attorney-Client and Work Product Privileges by
Putting Plaintiff’s Representation At Issue in the Dershowitz Case ............................... 8
a. Plaintiff’s Waiver of the Attorney-Client Privilege ........................................................... 10

b. Edwards and Cassell’s Waivers of Attorney-Client and Work Product Privilege in the
Dershowitz Case ............................................................................................................ 15
c. The elements for finding an at issue waiver are satisfied .................................................. 18
III. There is No Privilege as to Communications with Scarola ............................................ 22
a. There is no Attorney-Client Relationship .......................................................................... 22

b. Work Product Privilege has been Waived ......................................................................... 23
c. There is no basis to claim common interest or joint defense privilege .............................. 23
CONCLUSION ............................................................................................................................. 24
CERTIFICATE OF SERVICE ..................................................................................................... 25
i
TABLE OF AUTHORITIES
Bank Brussels Lambert v. Credit Lyonnais (Suisse), S.A., 210 F.R.D. 506, 509-10 (S.D.N.Y.
2002) ........................................................................................................................................... 9
Bowne of New York City, Inc. v. AmBase Corp., 150 F.R.D. 465, 488 (S.D.N.Y. 1993) ....... 15, 21
Calvin Klein Trademark Trust v. Wachner, 198 F.R.D. 53, 55 (S.D.N.Y. 2000) .......................... 8
Chevron Corp. v. Salazar, 275 F.R.D. 437, 445-46 (S.D.N.Y. 2011) .......................................... 10
Chin v. Rogoff & Co., P.C., No. 05 CIV. 8360(NRB), 2008 WL 2073934, at *6 (S.D.N.Y. May
8, 2008) ..................................................................................................................................... 21
Drimmer v. Appleton, 628 F.Supp. 1249, 1252 (S.D.N.Y.1986) .................................................. 20
In re Horowitz, 482 F.2d 72, 82 (2d Cir.) ..................................................................................... 20
In re von Bulow, 828 F.2d . ..................................................................................................... 15, 20
In re. Steinhardt Partners, 9 F.3d 230, 235 (2d Cir. 1993) …………………………………….9
Koumoulis v. Indep. Fin. Mktg. Grp., Inc., 295 F.R.D. 28, 39-40 (E.D.N.Y. 2013). ..................... 9
McGrath v. Nassau Cty. Health Care Corp., 204 F.R.D. 240, 244 (E.D.N.Y. 2001) .............. 9, 22
Schaeffler v. United States, 806 F.3d 34, 40 (2d Cir.2015)………………………………..........16
S.E.C. v. Yorkville Advisors, LLC, 300 F.R.D. 152, 162 (S.D.N.Y. 2014) ................................... 25
United States ex rel Edney v. Smith, 425 F.Supp. 1038, 1052 (E.D.N.Y. 1976) .......................... 20
United States v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir.1991 ................................................. 9, 15
United States v. Mejia, 655 F.3d 126, 132 (2d Cir. 2011) .............................................................. 8
ii
United States v. Nobles, 422 U.S. 225, 238 (1975). ....................................................................... 9
United States v. Schmidt, 105 F.3d 82, 89 (2d Cir. 1997) ............................................................ 15
Upjohn Co. v. United States, 449 U.S. 383, 389 (1981) ................................................................. 8
Urban Box Office Network, Inc. v. Interfase Managers, L.P., No. 01 Civ. 8854, 2004 WL
2375819, at *3–4 (S.D.N.Y. Oct. 21, 2004) ............................................................................. 10
Wultz v. Bank of China Ltd., 304 F.R.D. 384, 391 (S.D.N.Y.2015) ......................................... 8, 24
iii
Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Motion to Compel All
Attorney-Client Communications and Attorney Work Product Placed At Issue By Plaintiff and
Her Attorneys (“Motion”), and as grounds therefore states as follows:
CERTIFICATE OF CONFERRAL
Pursuant to Federal Rule of Civil Procedure 37(a)(1), undersigned counsel certifies that
she conferred with opposing counsel regarding the issues contained herein and was unable to
resolve the matter.
INTRODUCTION
Plaintiff and her attorneys have tied a Gordian knot of overlapping litigations, client
representations and joint defense agreements. Through these multiple litigations and
representations, they attempt to strategically leverage attorney-client communications and
attorney work product to their tactical advantage by selectively disclosing information.
Simultaneously, they desperately seek to avoid disclosure of related materials they know are
unfavorable, would destroy Plaintiff’s claim that she has been truthful, and reveal her attorneys’
knowledge of Plaintiff’s false statements in multiple sworn filings and her concerted media
campaign. The law, however, does not permit such a manipulation of the attorney-client and
work product privileges. Rather, the selective disclosure of privileged materials results in a
waiver of privilege as to all such material. This waiver is broad-sweeping when, as here, the
persons asserting the privileges have affirmatively put the subject matter of the materials at issue.
In the most recent of their serial litigations (apart from this case), Plaintiff’s own
attorneys Bradley Edwards (“Edwards) and Paul Cassell (“Cassell”) sued Harvard Law Professor
Alan Dershowitz (“Dershowitz”) for defamation in Florida state court. The subject matter of that
litigation concerned whether Mr. Dershowitz defamed Plaintiff’s attorneys by claiming
a) Plaintiff is lying; b) Edwards and Cassell knew Plaintiff is lying; c) Edwards and Cassell helped
1
Plaintiff lie and helped her concoct her stories; d) Edwards and Cassell failed to properly
investigate Plaintiff’s allegations before filing pleadings and sworn statements on Plaintiff’s
behalf; and e) Edwards and Cassell were motivated to take these actions by a desire to achieve
personal economic gain. This litigation put at issue all communications between Plaintiff and
her attorneys as well as her attorneys’ complete work product in the investigations of Plaintiff’s
stories and accusations. The truth of the matters put at issue in the Dershowitz litigation can only
be tested by examination of privileged materials, resulting in a sweeping waiver.
BACKGROUND FACTS RELEVANT TO DISPUTE
In her privilege log, Plaintiff has “categorically” logged five separate groups of
documents she has withheld on the basis of “AC Privilege and Work Product/joint
defense/common interest.” The documents are identified as:
1. Correspondence re: Jane Doe #1 and Jane Doe #2 v. United States, Case No. 08-
80736-CIV-Marra, pending in the Southern District of Florida. ("CVRA Case")
Plaintiff withheld documents purportedly to and from her attorneys (and others) related to
legal advice regarding the CVRA Case (to which Plaintiff is not a party), and documents
purportedly giving attorney mental impressions related to the CVRA Case and
“evidence” related thereto. Declaration of Laura A. Menninger (“Menninger Decl..”),
Exhibit A.
(i) The date range of the documents is 2011 – Present. Id.

(ii) Persons identified as involved in the communications are: Plaintiff Virginia
Giuffre (“Giuffre”), Brad Edwards (“Edwards”), Paul Cassell (“Cassell”),
Brittany Henderson (“Henderson”), Sigrid McCawley (“McCawley”),
Meredith Schultz (“Shultz”), David Boies (“Boies”), Jack Scarola (“Scarola”),
Stan Pottinger (“Pottinger”), Ellen Brockman (“Brockman”), Legal Assistants
(“Legal Assistants”), Professionals retained by attorneys to aid in the rendition
of legal advice and representation (“Other Professionals”). Id.
2. Correspondence re: Giuffre v. Maxwell, 15-cv-07433-RWS, pending in the

Southern District of New York (“Maxwell Case”). Id.
(i) The date range of the documents is September 21, 2015– Present. Id.
2
(ii) Persons identified as involved in the communications are: Giuffre, Edwards

Cassell, Henderson, McCawley, Schultz, Boies, Pottinger, Stephen Zach
(“Zach”), Brockman, Legal Assistants and Other Professionals. Id.
3. Correspondence re: Bradley Edwards and Paul Cassell v. Alan Dershowitz

(“Dershowitz Case”), Case No. 15000072, pending in the Seventeenth Judicial Circuit,
Broward County, Florida. (“Dershowitz Case”). Id.
(i) The date range of the documents is January 2015 -Present. Id.
Cassell, Henderson, McCawley, Schultz, Boies, Pottinger, Zach, Brockman,
Legal Assistants and Other Professionals. Id.
4. Correspondence re: Jane Doe No. 102 v. Jeffrey Epstein (“Epstein Case”), Case
No. 09-80656-CIV-Marra/Johnson (Southern District of Florida) (“Epstein case”)
(i) The date range of the documents is 2009 – Present

(ii) Persons identified as involved in the communications are: Giuffre, Bob
Josefsberg, Katherine W. Ezell, Amy Ederi, other Podhurst attorneys, Legal
Assistants, and Professionals retained by attorneys to aid in the rendition of
legal advice. Id.
5. “This categorical entry is regarding correspondence potential legal action against

entities and individuals.” (same description re potential litigation)
(i) The date range of the documents is from January 2015 –Present.
Cassell, Henderson, McCawley, Schultz, Boies, Pottinger, Zach, Brockman,
Legal Assistants and Other Professionals.
Plaintiff is withholding “Approx. 1.3 kilobytes [of documents] overlapping with other
cases” based on the categorically logged entries in Paragraph 1.
According to her most recent interrogatory response, Plaintiff has been represented in
various litigation matters identified above as follows:
(a) Pottinger, Boies, and McCawley (along with other Boies Schiller & Flexner LLP
(“Boies Schiller”) attorneys represent Ms. Giuffre as a non-party in the Dershowitz Case,
starting in February 2015.
(b) Edwards (along with other Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,
P.L. attorneys), Cassell, Pottinger, Boies and McCawley and Boies Schiller attorneys
represent Ms. Giuffre in the Maxwell case, “the complaint of which was filed in
September, 2015.” Id.
3
(c) Cassell represents Ms. Giuffre as a non-party in the CVRA Case, starting in May
of 2014. Id.
(d) Edwards and other Farmer, Jaffe attorneys represent Ms. Giuffre as a non-party in
the CVRA Case, starting in 2011. Id.
(e) Cassell provided Ms. Giuffre with legal advice concerning potential legal action
starting in early 2011. Id.
(f) Cassell, Edwards and other Farmer, Jaffe attorneys, Pottinger, Boies (along with
other Boies Schiller attorneys) represent Ms. Giuffre regarding investigations into
potential legal action starting in the second half of 2014. Id.
(g) According to Plaintiff, she has never been represented by Scarola.
Menninger Decl., Ex. B at 4.
The CVRA Case
In the CVRA Case, Edwards (starting in 2011) and Cassell (starting in May 2014) have
represented Plaintiff in attempting to obtain joinder in the pending action. On December 30,
2014, Cassell and Edwards filed a pleading titled "Jane Doe #3 and Jane Doe #4's Motion
Pursuant to Rule 21 for Joinder in Action" in the CVRA Case. Menninger Decl., Ex C (the
"Joinder Motion"). The Joinder Motion contained a number of allegations on behalf of “Jane
Doe # 3,” who is actually Ms. Giuffre, the Plaintiff in this case. The allegations include that
“Epstein also sexually trafficked the then-minor Jane Doe [#3], making her available for sex to
politically-connected and financially-powerful people." The "politically-connected and
financially powerful people" identified by Edwards and Cassell by name in the Joinder Motion
as having had sexual relations with Jane Doe #3 were Prince Andrew, Duke of York ("Prince
Andrew"), Ms. Maxwell, Jean Luc Brunel ("Brunel") and Alan Dershowitz (“Dershowitz”). Id.
at 3-6.1
1
The judge in the CVRA case subsequently struck these allegations, stating “[a]t this juncture in the proceedings,
these lurid details are unnecessary to the determination of whether Jane Doe 3 and Jane Doe 4 should be permitted
to join Petitioners’ claim that the Government violated their rights under the CVRA. The factual details regarding
with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent to this central claim
4
Following the Joinder Motion, Dershowitz made numerous public appearances in which
he vigorously denied the allegations, stated that Edwards and Cassell “are lying deliberately,”
and that if Cassell and Edwards “had just done an hours’ worth of work, they would have seen
she [Plaintiff] is lying through her teeth.” See Menninger Decl., Ex. E at 9-10.
The Dershowitz Case
On January 6, 2015, Edwards and Cassell initiated litigation against Dershowitz - the
Dershowitz Case. See Menninger Decl., Ex. F.
In the Dershowitz Case, Edwards and Cassell sued Dershowitz for defamation claiming
that Dershowitz’s public statements – that they and their client were lying and that they failed to
investigate their client’s claims – were false. The Complaint by Edwards and Cassell alleged that
“[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well-
founded pleading, Dershowitz initiated a massive public media assault on the reputation and
character of Bradley J. Edwards and Paul G. Cassell accusing them of intentionally lying in their
filing, of having leveled knowingly false accusations against the Dershowitz without ever
conducting any investigation of the credibility of the accusations, and of having acted unethically
to the extent that their willful misconduct warranted and required disbarment.” Menninger Decl.,
Ex. F, ¶ 17.
Edwards and Cassell claimed as false Dershowitz’s statements that “Edwards and Cassell
failed to minimally investigate the allegations advanced on behalf of their client [Virginia
Giuffre] and even that they sat down with her to contrive the allegations.” Menninger Decl., Ex.
E at 9. During the Dershowitz litigation, Edwards and Cassel responded to interrogatories and
requests for production issued by Dershowitz. Menninger Decl., Ex. G. Interrogatory No.1 asked:
(i.e., that they were known victims of Mr. Epstein and the Government owed them CVRA duties), especially
considering that these details involve non-parties who are not related to the respondent Government. These
unnecessary details shall be stricken.” See Menninger Decl., Ex. D.
5
“State verbatim or as close as possible Each statement by Dershowitz that You assert defamed You,”
to which Edwards and Cassel responded with nine pages of statements made by Dershowitz in the
press where Dershowitz states: 1) Plaintiff is lying; 2) Edwards and Cassel know Plaintiff is lying; 3)
Edwards and Cassel helped Plaintiff lie and “put words in her mouth”; and 4) Edwards and Cassel
failed to properly investigate Plaintiff’s allegations before publicizing Plaintiff’s statements.
Menninger Decl., Ex. G at 3-11.
Edwards and Cassell further stated that the listed Dershowitz press statements were
defamatory because “[t]he factual assertions contained or implied in the statements quoted in
answer to Interrogatory Number 1 were not true, notably with regard to claims that Edwards and
Cassell were deliberately lying, had failed to conduct an investigation of the allegations before
filing them, had manipulated or conspired with Jane Doe No. 3 to make intentionally false
allegations about Mr. Dershowitz, and that Plaintiffs were motivated to participate in the filing of
knowingly false accusations against the Defendant by a desire to achieve personal economic
gain.” Menninger Decl., Ex. G at 11, Response to Interrog. 2.
At the time the Dershowitz Case was filed, Edwards, Cassell and Boies represented
Plaintiff regarding “potential litigations.” See supra at ¶ 3f.
Plaintiff, Edwards and Cassell claim to be in a joint defense or common interest
agreement relating to the Dershowitz Case (Menninger Decl., Ex. H at 205:19-206:7), although
no such agreement has ever been produced.
Plaintiff and her counsel actively participated in the Dershowitz Case. Plaintiff provided
a declaration in the Dershowitz Case in support of the claims against Dershowitz. Menninger
Decl., Ex. I. Plaintiff also sat for a deposition in the Dershowitz Case and testified in a manner
expected to support Edwards’ and Cassell’s claims. Menninger Decl., Ex. H. Her counsel filed
12 pleadings in that matter.
6
I. The Attorney-Client and Work Product Privilege Standards and Limitations
a. The Attorney-Client Privilege
“The attorney-client privilege protects communications (1) between a client and his or
her attorney (2) that are intended to be, and in fact were, kept confidential (3) for the purpose of
obtaining or providing legal advice.” United States v. Mejia, 655 F.3d 126, 132 (2d Cir. 2011).
The purpose of the privilege “is to encourage full and frank communication between attorneys
and their clients and thereby promote broader public interests in the observance of law and
administration of justice.” Upjohn Co. v. United States, 449 U.S. 383, 389 (1981). “In order to
balance this protection of confidentiality with the competing value of public disclosure, however,
courts apply the privilege only where necessary to achieve its purpose and construe the privilege
narrowly because it renders relevant information undiscoverable.” Mejia, 655 F.3d at 132.
Because the privilege “stands in derogation of the search for truth so essential to the effective
operation of any system for justice ... the privilege must be narrowly construed.” Calvin Klein
Trademark Trust v. Wachner, 198 F.R.D. 53, 55 (S.D.N.Y. 2000) (citing United States v. Nixon,
418 U.S. 683, 710 (1974)). “The party invoking the privilege also has the burden to show that the
privilege has not been waived.” Wultz v. Bank of China Ltd., 304 F.R.D. 384, 391
(S.D.N.Y.2015).
b. Work Product Privilege
The work-product privilege protects documents either created by counsel or at counsel's
directive, in anticipation of litigation. See In re Grand Jury Subpoenas Dated March 19, 2002 &
August 2, 2002, 318 F.3d 379, 383 (2d Cir. 2003). The attorney work-product privilege “shelters
the mental processes of the attorney, providing a privileged area within which he can analyze and
prepare his client's case.” United States v. Nobles, 422 U.S. 225, 238 (1975). Again, the party
7
asserting the work-product privilege “bears the heavy burden of establishing its applicability.” In
re Grand Jury Subpoena Dated July 6, 2005, 510 F.3d 180, 183 (2d Cir. 2007). Work product
“includes both opinion work product, such as an attorney's mental impressions or legal theories,
and fact work product, such as factual investigation results.” Koumoulis v. Indep. Fin. Mktg.
Grp., Inc., 295 F.R.D. 28, 39-40 (E.D.N.Y. 2013), aff'd, 29 F. Supp. 3d 142 (E.D.N.Y. 2014).
“Both the attorney-client and work-product privileges may be waived if a party puts the
privileged communication at issue by relying on it to support a claim or defense.” Id.
II. Plaintiff and her Attorneys Waived Attorney-Client and Work Product Privileges
by Putting Plaintiff’s Representation At Issue in the Dershowitz Case
“The [attorney-client] privilege may implicitly be waived when [a party] asserts a claim
that in fairness requires examination of protected communications.” United States v. Bilzerian,
926 F.2d 1285, 1292 (2d Cir.1991); see also McGrath v. Nassau Cty. Health Care Corp., 204
F.R.D. 240, 244 (E.D.N.Y. 2001) (“Parties may waive any work product protection by putting
the privileged information at issue”). Courts determine whether a subject matter has been placed
at issue based on whether “(1) assertion of the privilege was a result of some affirmative act,
such as filing suit, by the asserting party; (2) through this affirmative act, the asserting party put
the protected information at issue by making it relevant to the case; and (3) application of the
privilege would have denied the opposing party to information vital to his defense.” Bank
Brussels Lambert v. Credit Lyonnais (Suisse), S.A., 210 F.R.D. 506, 509-10 (S.D.N.Y. 2002)
(quoting Hearn v. Rhay, 68 F.R.D. 574, 581 (E.D.Wash.1975)). “[C]ourts have generally
applied the Hearn [at issue] doctrine liberally, finding a broad waiver of attorney-client privilege
where a party asserts a position “the truth of which can only be assessed by examination of the
privileged communication.” Bank Brussels Lambert, 210 F.R.D. at 508.
8
After a party voluntarily discloses attorney-client communications or work-product
information “to an adversary in one proceeding, it cannot withhold the same documents on the
basis of privilege in a subsequent proceeding, even if that subsequent proceeding involves a
different adversary.” Chevron Corp. v. Salazar, 275 F.R.D. 437, 445-46 (S.D.N.Y. 2011); see
also In re Steinhardt Partners, 9 F.3d 230, 235 (2d. Cir. 1993) (“The waiver doctrine provides
that voluntary disclosure of work product to an adversary waives the privilege as to other parties
[in a subsequent proceeding].”); Urban Box Office Network, Inc. v. Interfase Managers, L.P.,
No. 01 Civ. 8854, 2004 WL 2375819, at *3–4 (S.D.N.Y. Oct. 21, 2004) (applying same principle
to waive attorney-client privilege). This, of course, makes sense because “where a party
voluntarily undertakes actions that will predictably lead to the disclosure of [a] document, then
waiver will follow.” Chevron Corp., 275 F.R.D. at 445-46 (internal citations omitted).
“The scope of the attorney-client privilege waiver is determined on a case by case basis
by considering the context of the waiver and the prejudice caused to the other party by permitting
partial disclosure of privileged communications.” McGrath, 204 F.R.D. at 244 (E.D.N.Y. 2001)
(citing In re Grand Jury Proceedings, 219 F.3d 175, 190 (2d Cir.2000)). “As in the attorney-
client context, fairness and prejudice concerns define the scope of any work product waiver.” Id.
at 192. Factors considered by the Second Circuit to find a broad waiver appropriate include
“(1) whether substantive information has been revealed; (2) prejudice to the opposing party
caused by partial disclosure; (3) whether partial disclosure would be misleading to a court; (4)
fairness; and (5) consistency.” Id.
9
a. Plaintiff’s Waiver of the Attorney-Client Privilege
Edwards and Cassell sued Dershowitz for defamation claiming that Dershowitz’s public
statements about their representation of client were false. At the time those claims were filed,
Edwards and Cassell represented Plaintiff in the CVRA Case. She was also represented by
Edwards, Cassell and Boies regarding “potential litigation.” The statements Edwards and
Cassell claimed as false included that “Edwards and Cassell failed to minimally investigate the
allegations advanced on behalf of their client [Virginia Giuffre] and even that they sat down with
her to contrive the allegations.” The allegations Edwards and Cassell failed to minimally
investigate and/or contrived where the allegations made by Plaintiff in the CVRA Joinder
Motion. Dershowitz counterclaimed against Edwards and Cassell suing them for 1) the
publication of the false allegations of Giuffre in the Joinder Motion and 2) defamation for their
extra-judicial false statements concerning Dershowitz and his alleged involvement with Giuffre.
Plaintiff and her counsel McCawley actively participated in the Dershowitz Case and
affirmatively waived any attorney-client privilege over Plaintiff’s communications. Plaintiff
produced documents, sat for a deposition (Menninger Decl., Ex. H) and provided a sworn
declaration (Menninger Decl., Ex. I). Through her participation in the case, Plaintiff specifically
discussed her communications with Edwards and Cassell. In her sworn declaration, she
discussed the following attorney communications:
 Her conversation with Brad Edwards in 2011 when she first told him her story. This was
followed by a telephone conversation with Edwards and his attorney, Scarola, which was
recorded with her knowledge and consent and which has been filed in multiple court
papers and given to the press2 (Menninger Decl., Ex I at ¶ 55-56);
2
Edwards participated in this call as Plaintiff’s attorney. Plaintiff believed that the conversation was covered by
attorney-client privilege. See Menninger Decl., Ex. J, (email between Plaintiff and Sharon Churcher crafting
communication to Edwards regarding publication of privileged communication). Yet, when the conversation was
sent to the press, and used in later court filings, Plaintiff did nothing to stop the publication of this privileged
10
 Her discussions with Edwards and Cassell of her representation in the CVRA Case (id. at
¶ 61);
 Her directions to counsel to pursue criminal charges (id. at ¶ 65);
 In her conversations with her attorneys “no one” has “pressured” her to identify
Dershowitz as a person who allegedly abused her (id. at ¶ 67);
 Her authorization to her attorney to file various affidavits including her stories (id. at
¶ 67);
 Her attorneys’ belief in the truth of her statements (id. at ¶ 68).
Plaintiff’s waiver of her attorney-client privilege was solidified during her deposition in
the Dershowitz Case. At the conclusion of questioning by Dershowitz’s counsel, and after off
the records discussions between and among McCawley, Edwards, Cassell and Jack Scarola
(counsel for Edwards and Cassell), Mr. Scarola then asked Plaintiff a series of questions directly
discussing her communications with her counsel. McCawley made no objection and Plaintiff
responded to each question. Scarola asked if Edwards pressured or encouraged her to lie:
Q. Has Brad [Edwards] ever pressured you or encouraged you in any way or under any
circumstances at any time to provide false information about Jeffrey Epstein?
-
A. Never.
Q. Has he ever pressured you or encouraged you at any time or in any way, under any
circumstances to provide false information about anyone or anything?
-
A. Never.
Menninger Decl., Ex. H at 202:5-202:12. Scarola asked similar questions concerning Cassell.
Id. at 202-03. The questioning, however, was not limited to Plaintiff’s conversations with
Edwards and Cassell. Scarola’s final question, again answered without objection by McCawley,
was:
communication. This alone is sufficient to waive the attorney-client privilege communication as between Edwards
and Plaintiff. See infra, p. 19-20.
11
Q. Apart from any efforts made by Jeffrey Epstein or agents on behalf of Jeffrey Epstein to
silence you or to have you refrain from providing true and accurate information about the
interactions that you had with Jeffrey Epstein and others to whom you were trafficked by Jeffrey
Epstein, has anyone apart from that circumstance pressured you or encouraged you to provide
false information about any of the topics that were covered during the course of your
examination? . . .
-
A. No.
Menninger Decl., Ex. H at 203:18-204:7.
There is no mechanism by which Plaintiff could respond to any of these questions with
the answer “never” unless she is recollecting and relying on the content of each and every
communication she had with Edwards, Cassell and any other person (including each and every
one of her attorneys) about the “topics covered” in the deposition. The topics covered in the
deposition were wide ranging including the full breadth of statements she and her counsel had
made in the CVRA Case, identification of the “high powered” individuals with whom she claims
to have had sexual relations, when and how she allegedly met Epstein, the timing and specifics
of her alleged encounters with Dershowitz, Prince Andrew, Maxwell and others, and her
interviews with and statements to media outlets. In other words, the topics included every story
Plaintiff has ever told concerning the time she claims she was a “sex slave.”
Notably, the Special Master overseeing Plaintiff’s deposition in the Dershowitz Case
immediately recognized the waiver. On re-direct, the following colloquy occurred:
Q BY MS. BORJA (Dershowitz’ counsel): Now, I understand from your testimony that Mr.
Edwards did not pressure you to give false information about this matter, is that fair?
A. That's fair.
Q. Tell me everything that Mr. Edwards told you about this matter?
MS. MCCAWLEY: Objection, that's privileged and she has not waived any privilege. She's not
here testifying as to what she discussed with her lawyers.
12
SPECIAL MASTER: You know, it's an interesting point. I'm going to grant your motion for
privilege, but I'm going to suggest to you that there might be a strong argument to be made that
those questions opened some of the door. I'm going to let the judge decide that. But you can go
ahead, ask the questions, we'll put it on the record for later determination, and it's going to force,
to be blunt, this among other things may force the witness to come back and complete the
deposition. Just let's be aware of that.
Menninger Decl., Ex. H at 205:15-206:10.
This testimony directly placed Plaintiff’s attorney-client communications and work
product at issue in the Dershowitz Case. Edwards and Cassell took the affirmative position that
Dershowitz’s statements that Edwards and Cassell helped Plaintiff fabricate her stories were
false and defamatory. See Menninger Decl., Ex E, p. 2 (“Dershowitz went so far as to repeatedly
accuse Edwards and Cassell of criminal misconduct in actively suborning perjury and fabricating
the allegations of misconduct against him - acts that would warrant their disbarment from the
legal profession. . . . Put simply, Dershowitz has made highly defamatory allegations that have
no basis in fact”). Communications between Plaintiff and her attorney were a central issue in the
claims brought by Edwards and Cassell, and Plaintiff voluntarily testified regarding those
communications.
Plaintiff was acutely aware of how the information was being utilized in the Dershowitz
Case. According to Plaintiff, she is a party to a joint defense or common interest agreement with
Messrs. Edwards and Cassell. When the Dershowitz Case was filed, a mere week after the filing
of the Joinder Motion on Plaintiff’s behalf, Edwards and Cassell represented Plaintiff, who
Dershowitz had also threatened to sue. Thus, Edwards and Cassell allegedly act both as
Plaintiff’s attorneys --
and her joint-defense or common interest partners. Plaintiff was aware that
what was, or in this case was allegedly not, said between her and her attorney would be
affirmatively used by her counsel/joint defense partners in support of their claims. She
authorized the disclosure and testified, both with the assistance of McCawley.
13
Plaintiff, on behalf of her joint defense partners, provided evidence to support the factual
claim neither Edwards or Cassell (nor anyone else) asked Plaintiff to lie about her stories of
alleged sexual abuse and trafficking. The only way the truth of that issue can be tested is
through the examination of all her communications about her stories, with attorneys or
otherwise. See Bowne v. AmBase Corporation, 150 F.R.D. 465, 488 (S.D.N.Y.1993), aff'd by
161 F.R.D. 258 (S.D.N.Y.1995) (otherwise privileged communications put in issue where party
“asserts a factual claim the truth of which can only be assessed by examination of a privileged
communication”); United States v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir.1991) (“[a] defendant
may not use the privilege to prejudice his opponent's case or to disclose some selected
communications for self-serving purposes. Thus, the privilege may implicitly be waived when
defendant asserts a claim that in fairness requires examination of protected communications.”);
In re von Bulow, 828 F.2d at 101–02 (“[I]t has been established law for a hundred years that
when the client waives the privilege by testifying about what transpired between her and her
attorney, she cannot thereafter insist that the mouth of the attorney be shut. From that has grown
the rule that testimony as to part of a privileged communication, in fairness, requires production
of the remainder.”); United States v. Schmidt, 105 F.3d 82, 89 (2d Cir. 1997) (criminal defendant
who testified that she was never advised by her attorney of the fifth amendment implications of
proceeding pro se put at issue all communications with her former attorney and her knowledge
of the law as informed by her attorney-client communications).
“[T]he attorney-client privilege cannot at once be used as a shield and a sword. . . . A
defendant may not use the privilege to prejudice his opponent's case or to disclose some selected
communications for self-serving purposes.” Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991)
(internal citations omitted); Locascio, 357 F.Supp.2d 536, 550 (E.D.N.Y. 2004) (“The privilege
14
may not simultaneously be used as a shield and a sword; where a defendant opens the door by
waiving the attorney-client privilege, . . . the [party] cannot open the door only to the information
he would like to admit.”) Plaintiff has used her attorney communications as a sword on behalf of
her joint defense partners, and therefore her communications with her attorneys are no longer
shielded.
Plaintiff also testified that she shared her conversations and communications with
Edwards to unrelated third parties. In particular, she shared her communications with a reporter
for the Daily Mail Online, Sharon Churcher. See Menninger Decl., Ex. K, at 297:5-300:6. There
is no doubt that sharing attorney-client communications with a third-party, particularly when that
third party is a member of the press, acts to waive any claim of privilege. Schaeffler v. United
States, 806 F.3d 34, 40 (2d Cir.2015). (“A party that shares otherwise privileged communications
with an outsider is deemed to waive the privilege by disabling itself from claiming that the
communications were intended to be confidential.”).
b. Edwards and Cassell’s Waivers of Attorney-Client and Work Product Privilege in

the Dershowitz Case
In addition to Plaintiff’s direct waiver, Plaintiff’s counsel/joint defense partners Edwards
and Cassell waived both attorney-client privilege and protection of their work product by putting
those matters at issue in the Dershowitz Case. The scope of the subject matter put at issue in the
Dershowitz Case could not be broader. Edwards and Cassell pleaded and argued at every
conceivable turn that: 1) they had a good faith belief that Ms. Giuffre’s allegations –
communicated to them by Giuffre -- were true; 2) they conducted a thorough investigation of
Ms. Giuffre’s claims (their work product regarding Plaintiff and her allegations); 3) that Ms.
Giuffre and her story were credible; 4) they did not have any communications or encourage
15
Plaintiff to fabricate facts or portions of her stories; and 5) they were not motivated in taking
their actions by potential financial gain . Edwards and Cassell point to both communications
with Plaintiff and their own work product in an attempt to prove their claims.
By way of example, in the Motion for Summary Judgement in the Dershowitz Case,
Edwards and Cassell make the following assertions, citing attorney-client-privileged
communications and work product documents in support of their claims and defenses:
 “Ms. Giuffre has submitted a sworn affidavit, not only attesting to the truthfulness of her
allegations against Dershowitz but also about the fact that she told her lawyers about
these claims.” (emphasis supplied) (attorney-client communications);
 “The assertions of sexual abuse are more than adequately corroborated by compelling
circumstantial evidence which is detailed at length by Cassell in his deposition.” (work
product/investigations);
 “Regardless of whether Dershowitz sexually abused Ms. Giuffre, Edwards and Cassell
clearly had a good faith basis for relying on the sworn representations of their client.”
(attorney-client communications, attorney thought process);
 “Edwards and Cassell had clearly conducted extensive investigation into the basis for Ms.
Giuffre's allegations” (work product);
 “the undisputed record evidence establishes that Edwards and Cassell had every right
following their detailed investigation to rely on Ms. Giuffre's credibility” (attorney-client
communication, work-product and investigations, thought process and credibility
assessments);
 “The good faith basis for Edwards and Cassell's reliance on Giuffre's allegations is laid
out in detail by Professor Cassell in more than 50 pages of sworn testimony during his
deposition. See Depo. Transcript of Paul Cassell (Oct. 16 & 17, 2015), at 61-117 (Exhibit
#3)” (attorney investigative activities, work-product and attorney thought process based
on what they “knew” through attorney-client communications).
 “Edwards and Cassell clearly had a powerful basis for believing their client's allegation
that she had been sexually abused by Dershowitz, particularly where she had made this
allegation to them as far back as 2011” (attorney-client communications)
 “Dershowitz made false and defamatory statements by alleging that two experienced and
capable attorneys who thoroughly investigated and believed Ms. Giuffre's allegations in
good faith should be disbarred” (work-product, investigation of alleged acts and
investigation of credibility).
Menninger Decl., Ex E, at 1-13.
16
In addition to the Motion for Summary Judgment, Mr. Cassell in his deposition spent
more than 50 pages detailing the investigations and assessment of all of the evidence used as a
factual basis for the Joinder Motion in the CVRA Case on behalf of Plaintiff. Menninger Decl.,
Ex. L at 61-117. During this soliloquy, Cassell details his and Edwards thought processes in
assessing the claims, their evaluation of the evidence they reviewed, and all other information
that he had to believe Plaintiff’s stories. He specifically refers to Plaintiff, their evaluation of the
evidence in light of the information they “knew” about Plaintiff, and their evaluation and thought
process of how the evidence supported her stories. Of course, the information they “knew”
about Plaintiff was a direct result of her attorney-client communications with them, and their
evaluation of that evidence in the case is clearly work product. In reciting the work product he
believes supports “Virginia’s” story, Cassell states that this is “important to Virginia” and “I
want to do a good job for Virginia Roberts on -- on representing all the -- the evidence that is
available to support her.” Menninger Decl.., Ex. L at 102:1-3 & 118:7-8. Having put these
matters directly at issue, and utilizing both their work-product and attorney-client
communications in support of the claims, there is a complete waiver of protection over 1) the
content of communications between Plaintiff and her attorneys, and 2) her attorneys’ work
product and thought process in investigating and “reasonable belief” in the claims.3
3
In a joint press release relating to the settlement of the Dershowitz Case, Plaintiff and her attorneys again
affirmatively cite to Plaintiff’s communications with them, their investigation of her statements, and their
assessment of her credibility. The references include the time frame prior to their initial filing as well as information
discovered throughout the course of the Dershowitz Cases. In that press release, Edwards and Cassel stated
“Edwards and Cassell maintain that they filed their client's allegations in good faith and performed the necessary
due diligence to do so, and have produced documents detailing those efforts.” Menninger Decl., Ex. M, p.1. The
press release continues in stating that it was a “mistake” to have filed sexual misconduct allegations against
Dershowitz citing, among other things, “the records and other documents produced by the parties.” Id. at 2. These
public statements provide a further waiver over the work product that led to the public acknowledgement that filing
the lawsuit and reliance on Plaintiff’s allegations was a “mistake.”
17
c. The elements for finding an at issue waiver are satisfied
As discussed above, “courts have generally applied the [at issue] doctrine liberally,
finding a broad waiver of attorney-client privilege where a party asserts a position “the truth of
which can only be assessed by examination of the privileged communication.” Bank Brussels
Lambert, 210 F.R.D. at 508. All of the factors for waiver have been met: “(1) assertion of the
privilege was a result of some affirmative act, such as filing suit, by the asserting party; (2)
through this affirmative act, the asserting party put the protected information at issue by making
it relevant to the case; and (3) application of the privilege would have denied the opposing party
to information vital to his defense.” Id. 210 F.R.D. at 509-10. Here, Edwards and Cassell, with
the full knowledge and consent of Plaintiff, took the affirmative act of filing and participating in
the Dershowitz Case. Through this affirmative act, they put at issues what Plaintiff told her
attorneys, whether it was true, whether her attorneys helped her concoct additional allegations
that would help her position, whether they adequately investigated her claims, their basis for
believing Plaintiff was credible, and if they and their client were motivated to file false claims by
a desire for financial gain.
As discussed above, Plaintiff voluntarily and affirmatively waived the attorney-client
privilege through her testimony. That alone is sufficient to find an at issue waiver. Plaintiff also
permitted the waiver of the attorney-client privilege by permitting Edwards and Cassell to put
her communications with them and her attorneys’ work product at issue with her full knowledge
and consent. Plaintiff is a party to a joint defense agreement with Edwards and Cassell. She and
her attorneys were involved in communication about the Dershowitz Case beginning in January
2015. The case was preemptively filed to beat Dershowitz to the courthouse, before he could act
on his public statements that he intended to sue both Plaintiff and her attorneys for, among other
18
things, defamation. Plaintiff did nothing to stop her counsel from filing the Complaint, despite
the fact that it would necessarily put her communications with her counsel at issue. And, she
actively participated in the litigation. Indeed, the testimony of Cassell makes clear that the
purpose of the litigation was for Plaintiff’s benefit, and that he wanted to do a “good job” for her.
Normally, an attorney cannot waive the attorney-client privilege without his client’s
knowledge and consent. In re von Bulow, 828 F.2d at 101. But, “[a] client may nonetheless by
his actions impliedly waive the privilege or consent to disclosure.” Id., 828 F.2d 94, 101 (2d Cir.
1987) (citing See United States ex rel Edney v. Smith, 425 F.Supp. 1038, 1052 (E.D.N.Y. 1976)
(implied waiver), aff'd, 556 F.2d 556 (2d Cir.), cert. denied, 431 U.S. 958 (1977); Drimmer v.
Appleton, 628 F.Supp. 1249, 1252 (S.D.N.Y.1986) (implied consent); Wigmore, supra, § 2327)).
In certain circumstances, an attorney may have “an implied authority to waive the privilege on
behalf of his client.” Drimmer, 628 F.Supp. at 1251; see also In re von Bulow, 828 F.2d at 101.
“It is the client's responsibility to ensure continued confidentiality of his communications.” Id.
If a client is aware of her attorney’s waiver of privilege and takes no action to preserve
confidentiality, the privilege is lost. Id.; In re Horowitz, 482 F.2d 72, 82 (2d Cir.), cert. denied,
414 U.S. 867 (1973) (“[i]t is not asking too much to insist that if a client wishes to preserve the
privilege under such circumstances, he must take some affirmative action to preserve
confidentiality”).
This situation is analogous to a client asserting advice of counsel as a defense, a situation
in which an at issue waiver of the full scope of attorney-client communications is automatic. See
Bilzerian, 926 F.2d at 1292 (defendant’s testimony that he thought his actions were legal would
have put his knowledge of the law and the basis for his understanding of what the law required
into issue, directly implicating his conversations with counsel); Chin v. Rogoff & Co., P.C., No.
19
05 CIV. 8360(NRB), 2008 WL 2073934, at *6 (S.D.N.Y. May 8, 2008) (in suit for damages
against tax advisor for negligence in providing tax advice, reliance and causation could only be
assessed through invading the attorney-client privilege and examining the nature of counsel’s
advice to determine different advice was given by attorneys). The at issue waiver is complete
“even if a party does not attempt to make use of a privileged communication” Bowne of New
York City, Inc. v. AmBase Corp., 150 F.R.D. 465, 488 (S.D.N.Y. 1993) (discussing Bilzerian,
926 F.2d 1285); Chin, 2008 WL 2073934, at *6 (waiver occur even where client does not
reference attorney communications if review of communications is necessary to establish an
element of a claim). Here, Edwards and Cassell put the issue of their “good faith” reliance on
Plaintiff’s communications to them affirmatively at issue, as well as their investigation of what
she told them in those communications. Having done so with Plaintiff’s knowledge and consent,
and without her protest, the waiver is complete.
The application of the privilege here, after it has been selectively waived, denies Ms.
Maxwell information vital to her defense. By way of very limited example, in the case at bar,
Plaintiff claims that she was defamed when Ms. Maxwell stated that the allegations Plaintiff
made in the Joinder Motion, included allegations regarding Dershowitz, Ms. Maxwell and Prince
Andrew, were false. In the Joinder Motion Edwards and Cassell boldly state “Epstein required
Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a
minor, not only in Florida but also on private planes, in New York, New Mexico, and the U.S.
Virgin Islands.” Menninger Decl., Ex. C at 4. Edwards and Cassell, however, had doubts about
Plaintiff’s allegations based on their own investigation, including whether Dershowitz and
Plaintiff were ever on Epstein’s plane together. Cassell identified flight logs Edwards and he
reviewed as supporting the allegations made by Plaintiff. Menninger Decl., Ex. L at 69-70. He
20
admits, however, that there is not a single log entry that put Dershowitz and Plaintiff on the same
plane.4 Having put at issue their investigation and “good faith belief” in Plaintiff’s stories, they
must provide all information about anything that both supports and undermines Plaintiff’s story
and their own belief in the credibility of that story.
Plaintiff will undoubtedly attempt to prop-up her claims that she was telling the truth
through use of the investigative material, work product, mental impressions and opinions on her
credibility offered by her attorneys/joint defense partners, Edwards and Cassell. Ms. Maxwell
cannot be denied access to information showing her attorney’s work and investigation shows
Plaintiff’s stories were fabricated, including the details uncovered demonstrating Plaintiff’s lack
of credibility.
Each of the factors considered by the Second Circuit to find a broad waiver weighs in
favor of finding such a waiver here. The factors are “(1) whether substantive information has
been revealed; (2) prejudice to the opposing party caused by partial disclosure; (3) whether
partial disclosure would be misleading to a court; (4) fairness; and (5) consistency.” McGrath v.
Nassau Cty. Health Care Corp., 204 F.R.D. 240, 244.
Cassell and Edwards have revealed in extensive detail their work-product demonstrating
why they believed Plaintiff’s allegations and incorporated them in the Joinder Motion. It would
be prejudicial for Plaintiff to be able to support her claim in this case that she is not a liar using
her attorney’s testimony and work product, while preventing discovery of work-product and
communications that would prove otherwise or cast doubts on Plaintiff’s credibility. It would be
4
My question, Mr. Cassell, is: You reviewed the flight logs, correct?
A. Correct.
Q. You reviewed them in some detail, correct?
A. Correct.
Q. Is there any entry on those flight lines -- logs that you read as putting Professor Dershowitz and Miss Roberts on
the same plane?
A. No.
Menninger Decl., Ex. L 206:3-11.
21
misleading to the court or any jury to hear testimony from Plaintiff’s counsel about all the factual
basis, work product and thought process on which they relied in making the allegations in the
Joinder Motion, but refusing to permit Ms. Maxwell discovering or presenting contradicting
information that Plaintiff’s attorneys had, including information that led them to conclude that it
was a “mistake” to have filed sexual misconduct allegations against Dershowitz. Fairness and
consistency require that Plaintiff and her attorneys be required to disclose all work product and
attorney-client communications relating their investigations of Plaintiff’s statements and story as
alleged in the CVRA Case, their investigations of the allegations, their assessment of the
credibility of the allegations, and contradictory evidence uncovered.
III. There is No Privilege as to Communications with Scarola
Plaintiff listed on her privilege log Jack Scarola, Edwards and Cassell’s attorney, as an
individual who received or sent communications or documents relating to the CVRA Case. The
log does not state what these documents are, instead including them as part of the “categorical”
logging. The “Types of Privileges” identified are Attorney Client, Work Product, and Joint
Defense/Common Interest. It is entirely unclear how any of these protections can be invoked
regarding communications including Scarola or over documents provided by or to him.
a. There is no Attorney-Client Relationship
Plaintiff specifically states in her interrogatory responses that Scarola is not and has never
been her attorney. Thus, there can be no attorney-client-communications between Plaintiff and
Scarola. If there were, Plaintiff has clearly and voluntarily waived any privilege.
22
b. Work Product Privilege has been Waived
In 2011, Scarola acted as Edward’s attorney in a case captioned Epstein v. Edwards, Case
No. 502009CA040800XXXMB, in the Circuit Court for the Fifteenth Judicial Circuit, Palm
Beach County, Florida (the “Epstein v. Edwards Case.”). That action is still pending. According
to the most recent discovery responses, Edwards represented Plaintiff in the CVRA Case at the
same time. SOF, ¶(d).
On April 7, 2011, Edwards, Scarola and Plaintiff had a telephone conversation, recorded
with the knowledge and consent of Plaintiff. Menninger Decl., Ex N at 1. The content of the
conversation is a detailed interview of Plaintiff recounting her story of her time with Epstein.
The transcript of that conversation, clearly marked “Work Product,” has been produced widely
and attached to multiple court filings. It was used affirmatively in the Epstein v. Edwards Case
and filed on May 17, 2011 in that case. See Menninger Decl., Ex. O (Notice of Filing). It was
also used affirmatively in the CVRA Case. See Menninger Decl., Ex. P, DE #290, Exhibit 3. It
was produced in this case and in the Dershowitz Case by Plaintiff and her counsel. See
Menninger Decl., Ex. Q. It apparently was also transmitted to the press. See Menninger Decl.,
Ex. J.
As discussed above, putting information contained in this “work product” document at
issue waives of any protection and extends to any and all work product of Scarola related to
Plaintiff or her claims and stories.
c. There is no basis to claim common interest or joint defense privilege
It bears repeating that “[t]he party asserting the privilege ... bears the burden of
establishing its essential elements.” Mejia, 655 F.3d at 132; see also Wultz v. Bank of China Ltd.,
23
304 F.R.D. 384, 391 (S.D.N.Y.2015) (“The party invoking the privilege also has the burden to
show that the privilege has not been waived.”).
Plaintiff provides no basis for claiming a common interest or joint defense with anyone
related to the CVRA case. The only two people Scarola represents, to Ms. Maxwell’s
knowledge, are Edwards and Cassell. They are the attorneys in the CVRA case, and by
definition should not have a personal or common interest with the parties in that litigation.
Regardless, it is Plaintiff’s burden to establish that such and interest exists, who is involved, and
Scarola’s role. Having failed to provide any of the information necessary to establish the
applicability of these privileges, they are waived. See S.E.C. v. Yorkville Advisors, LLC, 300
F.R.D. 152, 162 (S.D.N.Y. 2014) (failure to provide adequate descriptions of the subject matter,
authors and recipients of the withheld documents resulted in waiver of privilege). There is
simply no basis for withholding any communication with or work product of Scarola.
CONCLUSION
Plaintiff and her lawyers waived any privilege as to their communications related to the
subject matters of (a) the CVRA litigation and (b) the Edwards and Cassell v. Dershowitz Case.
Similarly, Plaintiff’s lawyers waived any claim of work product to material gathered in relation
to those litigations.
Accordingly, Ms. Maxwell requests that the Court enter an order finding (a) a waiver of
the attorney-client privilege as to the subject matter of the CVRA and Dershowitz litigations and
(b) a work product exemption for materials gathered in relation to those matters. She further
requests an Order directing Plaintiff to provide Ms. Maxwell with all documents as to which
such the attorney-client privilege and work product have been waived.

24
Respectfully submitted,
/s/ Laura A. Menninger

Laura A. Menninger (LM-1374)
Jeffrey S. Pagliuca (pro hac vice)
HADDON, MORGAN AND FOREMAN, P.C.
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
lmenninger@hmflaw.com
Attorneys for Ghislaine Maxwell
I certify that on May 26, 2016, I electronically served this Motion to Compel all
Communications and Work Product Put At Issue by Plaintiff and Her Attorneys via ECF on the
following:

Meridith Schultz 383 S. University Street
BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112
401 East Las Olas Boulevard, Ste. 1200 cassellp@law.utah.edu
smccawley@bsfllp.com
mschultz@bsfllp.com
Bradley J. Edwards
/s/ Nicole Simmons
Nicole Simmons
25

--------------------------------------------------X
..........................................
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration Of Laura A. Menninger In Support Of

Motion To Compel All Attorney-Client Communications and Attorney
Work Product Placed At Issue by Plaintiff and Her Attorneys
I, Laura A. Menninger, declare as follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of
Ms. Maxwell’s Motions to Compel All Attorney-Client Communications and Attornty Work
Product Placed At Issue by Plaintiff and Her Attorney.
2. Attached as Exhibit A is a true and correct copy of excerpts categorically logged
entries from Plaintiff Giuffre's Revised Supplemental Privilege Log dated April 29, 2016.
3. Attached as Exhibit B is a true and correct copy of Plaintiff Giuffre’s Discovery
Second Amended Supplemental Response to Interrogatory No. 3 concerning her attorney
representations, dated April 29, 2016.

4. Attached as Exhibit C (filed under seal) ·s a true and correct copy of the Motion to
lJoin in the Jane Doe #1 and Jane Doe #2 v. United States , Case No. 08-80736-CIV-Marra ,
United States District Court for the Southern District of Florida "CVRA Case" filed Decembe
0, 2014.
5. Attached as Exhibit D is a hue and conect copy of the Order in the CVRA Case
dated April 6, 2015.
6. Attached as Exhibit Ei s a h11eand conect copy of th e Motion for Summaiy
Judgment in th e Edwards and Cassell v. Dershowitz , Case No. 15-00072, In and for th e
Seventeenth Judicial Dish·ict, Broward County, Florida ("Dershowitz Case") dated November
25, 2015.
7. Attached as Exhibit F is a hue and con ect copy of the Complaint in the
Dershowitz Case dated Januaiy 6, 2015.
8. Attached as Exhibit G is a hue and conect copy of the Notice of Serving Answer s
to Intenogator ies in Dershowitz Case dated March 13, 20 15.
9. Attached as Exhibit H (filed under seal) is a true and correct co
from the Deposition of Virginia Giuffre taken in the matter on Jan 16, 2016
and desig_11ated
by Plaintiff as Confidential under the Protective Order.
10. Attached as Exhibit I is a hue and cone ct copy of the Declaratio n of Virginia
Giuffre in the Dershowitz Case dated November 20, 2015 .
11. Attached as Exhibit J (filed under seal) ·s a true and correct co y_of Email
corres ondence with Churcher re : Edwards Privile e communication .
2
12. Attached as Exhibit K (filed under seal) is a true and correct copy of excerpts
from the Deposition of Virginia Giuffre taken in the above captioned matter on May 3, 2016, and
designated by Plaitniff as Confidential under the Protective Order.
13. Attached as Exhibit L is a true and correct copy of the October 16, 2015
Deposition of Paul G. Cassell taken in the Edwards and Cassell v. Dershowitz, In and for the
Seventeenth Judicial District, Broward County, Florida matter.
14. Attached as Exhibit M is a true and correct copy of the press release issued by the
parties in the Dershowitz Case on April 8, 2016.
15. Attached as Exhibit N is a true and correct copy of the interview of Virginia
Roberts by Edwards and Scarola in the Epstein v. Rothstein, Edwards, and L.M, In and for the
Fifteenth Judicial District, Palm Beach County, Florida (“Epstein Case”).
16. Attached as Exhibit O is a true and correct copy of the May 17, 2011 Notice of
Filing of the interview in the Epstein Case.
17. Attached as Exhibit P is a true and correct copy of a portion of the ECF Docket
Sheet in the CVRA Case.
18. Attached as Exhibit Q is a true and correct copy of the document produced by
Plaintiff in this matter as GIUFFRE000862-000887.
By: /s/ Laura A. Menninger

Laura A. Menninger
3
I certify that on May 26, 2016, I electronically served this Declaration Of Laura A.
Menninger In Support Of Motion To Compel All Attorney-Client Communications and Attornty
Work Product Placed At Issue by Plaintiff and her Attorney via ECF on the following:

Meridith Schultz S.J. Quinney College of Law, University of
BOIES, SCHILLER & FLEXNER, LLP Utah
401 East Las Olas Boulevard, Ste. 1200 383 S. University Street
Ft. Lauderdale, FL 33301 Salt Lake City, UT 84112
smccawley@bsfllp.com cassellp@law.utah.edu
mschultz@bsfllp.com
Bradley J. Edwards
/s/ Nicole Simmons
Nicole Simmons
4
EXHIBIT C
Case 1:15-cv-07433-LAP
Case 9:08-cv-80736-KAM DocumentDocument 1090-6
279 Entered Filed Docket
on FLSD 07/30/20 Page 2 of Page
12/30/2014 10 1 of 13

SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Johnson
JANE DOE #1 and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”), by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe #2 (also referred to as “the current victims”). The new victims have
suffered the same violations of their rights under the Crime Victims’ Rights Act (CVRA) as the
current victims. Accordingly, they desire to join in this action to vindicate their rights as well.
Because the new victims will not re-litigate any issues previously litigated by the current victims
(and because they are represented by the same legal counsel as the current victims), the
Government will not be prejudiced if the Court grants the motion. The Court may “at any time”
add new parties to the action, Fed. R. Civ. P. 21. Accordingly, the Court should grant the
motion. 1
1
As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by
way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2 proceeded in this
1
12/30/2014 10 2 of 13
FACTUAL BACKGROUND
As the Court is aware, more than six years ago, Jane Doe #1 filed the present action
against the Government, alleging a violation of her rights under the CVRA, 18 U.S.C. § 3771.
DE1. She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the case, the Court allowed Jane Doe #2 to also join the
action. Both Jane Doe #1 and Jane Doe #2 specifically argued that the government had failed to
protect their CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with
fairness. In response, the Government argued that the CVRA rights did not apply to Jane Doe #1
and Jane Doe #2 because no federal charges had ever been filed against Jeffrey Epstein.
The Court has firmly rejected the United States’ position. In a detailed ruling, the Court
concluded that the CVRA extended rights to Jane Doe #1 and Jane Doe #2 even though federal
charges were never filed. DE 189. The Court explained that because the NPA barred
prosecution of crimes committed against them by Epstein, they had “standing” to assert
violations of the CVRA rights. Id. The Court deferred ruling on whether the two victims would
be entitled to relief, pending development of a fuller evidentiary record. Id.
Two other victims, who are in many respects similarly situated to the current victims,
now wish to join this action. The new victims joining at this stage will not cause any delay and
their joinder in this case is the most expeditious manner in which to pursue their rights. Because
the background regarding their abuse is relevant to the Court’s assessment of whether to allow
them to join, their circumstances are recounted here briefly.
fashion. Counsel for the new victims have made their true identities known to the Government.
2
12/30/2014 10 3 of 13
Jane Doe #3’s Circumstances
As with Jane Doe #1 and Jane Doe #2, Jane Doe #3 was repeatedly sexually abused by
Epstein. The Government then concealed from Jane Doe #3 the existence of its NPA from Jane
Doe #3, in violation of her rights under the CVRA. If allowed to join this action, Jane Doe #3
would prove the following:
In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his sexual abuse and sex trafficking scheme. In fact, it became known to the government that
Maxwell herself regularly participated in Epstein’s sexual exploitation of minors, including Jane
Doe #3. Maxwell persuaded Jane Doe #3 (who was then fifteen years old) to come to Epstein’s
mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators
coerced dozens of other children (including Jane Doe #1 and Jane Doe #2). When Jane Doe #3
began giving Epstein a “massage,” Epstein and Maxwell turned it into a sexual encounter, as
they had done with many other victims. Epstein then became enamored with Jane Doe #3, and
with the assistance of Maxwell converted her into what is commonly referred to as a “sex slave.”
Epstein kept Jane Doe #3 as his sex slave from about 1999 through 2002, when she managed to
escape to a foreign country and hide out from Epstein and his co-conspirators for years. From
1999 through 2002, Epstein frequently sexually abused Jane Doe #3, not only in West Palm
Beach, but also in New York, New Mexico, the U.S. Virgin Islands, in international airspace on
his Epstein’s private planes, and elsewhere.
Epstein also sexually trafficked the then-minor Jane Doe, making her available for sex to
politically-connected and financially-powerful people. Epstein’s purposes in “lending” Jane Doe
3
12/30/2014 10 4 of 13
(along with other young girls) to such powerful people were to ingratiate himself with them for
business, personal, political, and financial gain, as well as to obtain potential blackmail
information.
One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual
relations with was , a close friend of Epstein’s
. Epstein required Jane Doe #3 to have sexual
relations with
- on numerous occasions while she was a minor, not only in Florida but
also on private planes, in New York, New Mexico, and the U.S. Virgin Islands. In addition to
being a participant in the abuse of Jane Doe #3 and other minors,

- was an eye-witness
to the sexual abuse of many other minors by Epstein and several of Epstein’s co-conspirators.
--
Indeed,
would later play a significant role in negotiating the NPA on Epstein’s behalf.
helped negotiate an agreement that provided immunity from federal
prosecution in the Southern District of Florida not only to Epstein, but also to “any potential co-
conspirators of Epstein.” NPA at 5. Thus,

- helped negotiate an agreement with a
provision that provided protection for himself against criminal prosecution in Florida for
sexually abusing Jane Doe #3. Because this broad immunity would have been controversial if
disclosed,
- (along with other members of Epstein’s defense team) and the
Government tried to keep the immunity provision secret from all of Epstein’s victims and the
general public, even though such secrecy violated the Crime Victims’ Rights Act.
Ghislaine Maxwell was another person in Epstein’s inner circle and a co-conspirator in
Epstein’s sexual abuse. She was someone who consequently also appreciated the immunity
granted by the NPA for the crimes she committed in Florida. In addition to participating in the
4
12/30/2014 10 5 of 13
sexual abuse of Jane Doe #3 and others, Maxwell also took numerous sexually explicit pictures
of underage girls involved in sexual activities, including Jane Doe #3. She shared these
photographs (which constituted child pornography under applicable federal laws) with Epstein.
The Government is apparently aware of, and in certain instances possesses some of these
photographs.
Perhaps even more important to her role in Epstein’s sexual abuse ring, Maxwell had
direct connections to other powerful individuals with whom she could connect Epstein. For
instance, one such powerful individual Epstein forced Jane Doe #3 to have sexual relations with
was Jane Doe #3
was forced to have sexual relations with

- when she was a minor in three separate
geographical locations: in London (at Ghislaine Maxwell’s apartment), in New York, and on
Epstein’s private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged
girls). Epstein instructed Jane Doe #3 that she was to give

- whatever he demanded and
required Jane Doe #3 to report back to him on the details of the sexual abuse. Maxwell
facilitated acts of sexual abuse by acting as a “madame” for Epstein, thereby
assisting in internationally trafficking Jane Doe #3 (and numerous other young girls) for sexual
purposes.
Another person in Epstein’s inner circle of friends (who becomes apparent with almost
no investigative effort) is
- many times.
-
. Epstein sexually trafficked Jane Doe #3 to
-
was another of Epstein’s closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world.
- has been a
model scout for various modeling agencies for many years and apparently was able to get U.S.
5
12/30/2014 10 6 of 13
passports for young girls to “work” as models. He would bring young girls (ranging to ages as
young as twelve) to the United States for sexual purposes and farm them out to his friends,
especially Epstein.
- would offer the girls “modeling” jobs. Many of the girls came from
poor countries or impoverished backgrounds, and he lured them in with a promise of making
good money. Epstein forced Jane Doe #3 to observe him,

- and Maxwell engage in illegal
sexual acts with dozens of underage girls. Epstein also forced Jane Doe #3 to have sex with
- on numerous occasions, at places including Epstein’s mansion in West Palm Beach, Little
St. James Island in the U.S. Virgin Islands (many including orgies that were comprised of other
underage girls), New York City, New Mexico, Paris, the south of France, and California.
Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men,
including numerous prominent American politicians, powerful business executives, foreign
presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doe #3
to describe the events that she had with these men so that he could potentially blackmail them.
The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it
listed her as a victim in the attachment to the NPA. Moreover, even a rudimentary investigation
of Jane Doe #3’s relationship to Epstein would have revealed the fact that she had been
trafficked throughout the United States and internationally for sexual purposes. Nonetheless, the
Government secretly negotiated a non-prosecution agreement with Epstein precluding any
Federal prosecution in the Southern District of Florida of Epstein and his co-conspirators. As
with Jane Doe #1, and Jane Doe #2, the Government concealed the non-prosecution agreement
from Jane Doe #3 all in violation of her rights under the CVRA to avoid Jane Doe #3 from
raising powerful objections to the NPA that would have shed tremendous public light on Epstein
6
12/30/2014 10 7 of 13
and other powerful individuals and that would likely have been prevented it from being
concluded in the secretive manner in which it was.
Jane Doe #4’s Circumstances
If permitted to join this action, Jane Doe #4 would allege, and could prove at trial, that
she has CVRA claims similar to those advanced by Jane Doe #1 and Jane Doe #2, based on the
following:
As with the other Jane Does, Jane Doe #4 was repeatedly sexually abused by Epstein. In
or around the summer of 2002, Jane Doe #4, an economically poor and vulnerable sixteen-year-
old child, was told by another one of Epstein’s underage minor sex abuse victims, that she could
make $300 cash by giving an old man a massage on Palm Beach. An acquaintance of Jane Doe
#4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4
to go to Epstein’s house to give him a massage. During that call, Epstein himself got on the
phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to
his mansion in Palm Beach.
Jane Doe #4 then went to Epstein’s mansion and was escorted upstairs to Epstein’s large
bathroom by one of Epstein’s assistants. Shortly thereafter Jeffrey Epstein emerged and lay face
down on the table and told Jane Doe #4 to start massaging him. Epstein asked Jane Doe #3 her
age and she told him she had recently turned sixteen. Epstein subsequently committed illegal
sexual acts against Jane Doe #4 on many occasions.
Epstein used a means of interstate communication (i.e., a cell phone) to arrange for these
sexual encounters. Epstein also frequently travelled in interstate commerce (i.e., on his personal
jet) for purposes of illegally sexually abusing Jane Doe #4.
7
279 Entered FiledDocket
on FLSD 07/30/20 Page 9 ofPage
12/30/2014 10 12 of 13
January. In the meantime, however, counsel for the victims believe that it is no longer
appropriate to delay filing this motion and accordingly file it at this time. Because the
Government is apparently opposing this motion, Jane Doe #3 and Jane Doe #4 have described
the circumstances surrounding their claims so that the Court has appropriate information to rule
on the motion.
CONCLUSION
Jane Doe #3 and Jane Doe #4 should be allowed to join this action, pursuant to Rule 21
of the Federal Rules of Civil Procedure. Their joinder should be conditioned on the requirement
that they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe #2. A
proposed order to that effect is attached to this pleading.
DATED: December 30, 2014
/s/ Bradley J. Edwards

Bradley J. Edwards
Telephone (954) 524-2820
Facsimile (954) 524-2822
E-mail: brad@pathtojustice.com
And
Paul G. Cassell
Pro Hac Vice
S.J. Quinney College of Law at the
University of Utah
332 S. 1400 E.
Telephone: 801-585-5202
12
on FLSD 07/30/20 Page 10 ofPage
12/30/2014 10 13 of 13
Facsimile: 801-585-6833
E-Mail: cassellp@law.utah.edu
Attorneys for Jane Doe #1 and Jane Doe #2
I certify that the foregoing document was served on December 30, 2014, on the following
using the Court’s CM/ECF system:
Dexter Lee
A. Marie Villafaña
500 S. Australian Ave., Suite 400
West Palm Beach, FL 33401
(561) 820-8711
Fax: (561) 820-8777
E-mail: Dexter.Lee@usdoj.gov
E-mail: ann.marie.c.villafana@usdoj.gov
Attorneys for the Government
13
EXHIBIT H
1 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT

IN AND FOR BROWARD COUNTY, FLORIDA
2 CASE NO. 15-000072
3
BRADLEY J. EDWARDS and PAUL G.
4 CASSELL,
5 Plaintiffs,
6 -vs- CONFIDENTIAL
7 ALAN M. DERSHOWITZ,
8 Defendant.
/
9
10 VIDEOTAPED DEPOSITION OF VIRGINIA ROBERTS GIUFFRE
11
12 Saturday, January 16, 2016

9:07 a.m. - 2:48 p.m.
13
14 401 East Las Olas Blvd., Suite 1200

15
16
17
18 Reported By:
19 Deborah A. Harris, Court Reporter

Notary Public, State of Florida
20 Phone - 305.651.0706
21
Job No. JO277789
22
23
24
25
CONFIDENTIAL
GIUFFRE005093
CONFIDENTIAL
200
1 raises. Do you understand that?
2 MS. MCCAWLEY: I do. So let's take a
3 break. It's a moment to take a break and I'll
4 discuss with these folks and we'll come back.
5 THE VIDEOGRAPHER: Going off video record
6 2:25 p.m.
7 (A recess was taken.)
8 THE VIDEOGRAPHER: We're now back on video
9 record 2:32 p.m.
10
11
12
SPECIAL MASTER: Just for the record,
through counsel examined the witness
for four hours and seven minutes and there was a

-
13 request and it appears to be in agreement to
14 allow.
15 MR. SCOTT: No agreement.
16 SPECIAL MASTER: Hang on one second. Hang
17 on. Between Mr. Scarola and Ms. McCawley, to
18 allow Mr. Scarola a couple questions on
19 examination on cross and then my ruling is going
20 to be as follows: You can go ahead and ask
21 whatever questions you want, Mr. Scarola, at which
22 time I will give opportunity for re-direct based
23 upon the topics that you've raised.
24 MR. SCAROLA: With the understanding that
25 re-direct is going to be limited to the area of
CONFIDENTIAL
GIUFFRE005292
CONFIDENTIAL
201
1 inquiry that I am about to conduct. I am about to
2 conduct an inquiry.
3 SPECIAL MASTER: That is the understanding.
■
4 My understanding of my ruling, I know that .
5 team has objected to that. I also
6 understand that there might be -- this is no
7 impact or their right or anybody else's right to
8 go back to Judge Lynch and ask for more time from
9 this witness based upon my ruling or my reading of
10 the original order.
11 MS. MCCAWLEY: And there's also the motion
12 to strike the testimony that you allowed over the
13 ruling.
14 SPECIAL MASTER: And there's a series of
15 those things that might need to be cleaned up in a
16 subsequent sitting.
17 MR. SCOTT: It's my understanding this is
18 going to be limited to five minutes or less; is
19 that correct?
20 MR. SCAROLA: That's what I anticipate.
21 MR. SCOTT: Over our objection, okay.
22 SPECIAL MASTER: Let's rock and roll.
23 CROSS-EXAMINATION
24 BY MR. SCAROLA:
25 Q. Virginia, has Brad Edwards ever pressured
CONFIDENTIAL
GIUFFRE005293
CONFIDENTIAL
202
1 you or encouraged you in any way whatsoever at any time
2 and under any circumstances to provide false information
3 about
4 A. Never.
5 Q. Has Brad Edwards ever pressured you or
6 encouraged you in any way or under any circumstances at
7 any time to provide false information about Jeffrey
8 Epstein?
9 A. Never.
10 Q. Has he ever pressured you or encouraged you
11 at any time or in any way, under any circumstances to
12 provide false information about anyone or anything?
13 A. Never.
14 Q. Has Paul Cassell ever pressured you or
15 encouraged you in any way, at any time, under any
16
17
18
circumstances to provide false information about
A. Never.
-
19 Q. Has he ever pressured or encouraged you in
20 any way at any time, under any circumstances to provide
21 false information about Jeffrey Epstein?
22 A. Never.
23 MS. BORJA: Objection. I couldn't follow
24 who he was.
25 BY MR. SCAROLA:
CONFIDENTIAL
GIUFFRE005294
CONFIDENTIAL
203
1 Q. Mr. Cassell, Professor Cassell? You
2 understood that I was asking you that question about
3 Professor Cassell, right?
4 A. And he's never pressured me or encouraged
5 me in any way to talk --
6 MS. MCCAWLEY: I don't want you to go into
7 discussions with them if you're saying something
8 didn't happen --
9 SPECIAL MASTER: Just --
10 MS. MCCAWLEY: I'm preserving privilege. I
11 just want to make sure if something didn't happen
12 she can say that.
13 BY MR. SCAROLA:
14 Q. Has Professor Cassell ever pressured you or
15 encouraged you in any way to provide false information
16 about anyone or anything at any time?
17 A. Never.
18 Q. Apart from any efforts made by Jeffrey
19 Epstein or agents on behalf of Jeffrey Epstein to silence
20 you or to have you refrain from providing true and
21 accurate information about the interactions that you had
22 with Jeffrey Epstein and others to whom you were
23 trafficked by Jeffrey Epstein, has anyone apart from that
24 circumstance pressured you or encouraged you to provide
25 false information about any of the topics that were
CONFIDENTIAL
GIUFFRE005295
CONFIDENTIAL
204
1 covered during the course of your examination?
2 MS. BORJA: Objection. Objection to the
3 form. Leading, assumes facts not in evidence,
4 compound, misleading.
5 SPECIAL MASTER: Your form objection will
6 be reserved. You can answer.
7 A. No.
8 MR. SCAROLA: Thank you. I don't have any
9 further questions.
10 MR. SCOTT: Judge, excuse me, none of this
11 was covered on direct examination so we move to
12 exclude and strike the entire testimony because
13 none of this was covered on our direct. But we
14 would like to request a two-minute recess because
15 these are completely new areas.
16 SPECIAL MASTER: I'll grand your two-minute
17 recess.
18 THE VIDEOGRAPHER: Going off video record
19 2:37 p.m.
20 (A recess was taken.)
21 THE VIDEOGRAPHER: We are now back on video
22 record 2:41 p.m.
23 MR. SCAROLA: Could we have a reading how
24 much time is used in my examination.
25 SPECIAL MASTER: That's going to be
CONFIDENTIAL
GIUFFRE005296
CONFIDENTIAL
205
1 irrelevant at this point, but you can ask.
2 THE VIDEOGRAPHER: It's going to be about
3 eight minutes, seven minutes of change.
4 MR. SCAROLA: Hard for me to believe that
5 but if the counter says what the counter says.
6 SPECIAL MASTER: The overtime got three
7 minutes, let's go.
8 REDIRECT EXAMINATION
9 BY MS. BORJA:
10 Q. Before you were scheduled here under oath
11 today by Mr. Scarola, did you talk to him in the break
12 before that?
13 MS. MCCAWLEY: Objection to the extent you
14 discussed privileged information with your lawyers
15 you don't have to reveal.
16 BY MS. BORJA:
17 Q. I'm asking what she talked about with Mr.
18 Scott?
19 MS. MCCAWLEY: She's in a joint defense
20 agreement with Mr. Scarola.
21 BY MS. BORJA:
22 Q. Are you in a joint defense agreement with
23 Mr. Scarola?
24 MR. SCAROLA: I will tell you that there is
25 a joint defense, a common interest privilege
CONFIDENTIAL
GIUFFRE005297
CONFIDENTIAL
206
1 agreement between the witness and my clients, yes.
2 SPECIAL MASTER: Are you asserting that
3 privilege then?
4 MR. SCAROLA: Yes, we are asserting that
5 privilege and instructing the witness not to
6 answer on the basis of the privilege that exists
7 for Bradley Edwards and Professor Cassell.
8 SPECIAL MASTER: So with that I'm going to
9 grant the motion similar to what I did the other
10 day when was testifying and under
11 the reservation that that can be dealt with later
12 in front of the judge or in front of me, whichever
13 you choose.
14 BY MS. BORJA:
15 Q. Now, I understand from your testimony that
16 Mr. Edwards did not pressure you to give false
17 information about this matter, is that fair?
18 A. That's fair.
19 Q. Tell me everything that Mr. Edwards told
20 you about this matter?
21 MS. MCCAWLEY: Objection, that's privileged
22 and she has not waived any privilege. She's not
23 here testifying as to what she discussed with her
24 lawyers.
25 SPECIAL MASTER: You know, it's an
CONFIDENTIAL
GIUFFRE005298
CONFIDENTIAL
207
1 interesting point. I'm going to grant your motion
2 for privilege, but I'm going to suggest to you
3 that there might be a strong argument to be made
4 that those questions opened some of the door. I'm
5 going to let the judge decide that. But you can
6 go ahead, ask the questions, we'll put it on the
7 record for later determination, and it's going to
8 force, to be blunt, this among other things may
9 force the witness to come back and complete the
10 deposition. Just let's be aware of that.
11 MS. BORJA: And I can't make a proffer to
12 all of my questions because some of them will
13 depend on this witness' answers.
14 SPECIAL MASTER: I'm aware of that.
15 MS. BORJA: I want the record to be clear
16 that although I'm being asked for a proffer, I'm
17 constrained based on my inability to follow up.
18 SPECIAL MASTER: I understand that, but I'm
19 sure that you have a couple questions that you'd
20 like to proffer to give the record an idea of
21 where you might have gone without restraint to
22 what the answer might be and then a subsequent
23 question might lead from the answer, I understand
24 that.
25 BY MS. BORJA:
CONFIDENTIAL
GIUFFRE005299
CONFIDENTIAL
208
1 Q. Did Mr. Edwards ever suggest to you
2 anything regarding
3 MS. MCCAWLEY: Objection. Hang on, I'm
4 objecting. She's making a proffer and I need to
5 make my objection on the record. Do not answer.
6 Objection, attorney/client privilege.
7 SPECIAL MASTER: So I'm going to grant
8 within the reservation it be brought back later.
9 BY MS. BORJA:
10 Q. Did Paul Cassell ever tell you anything
11 about the topics that were covered in today's deposition?
12 MS. MCCAWLEY: Objection, attorney/client
13 privilege.
14 SPECIAL MASTER: Same ruling.
15 BY MS. BORJA:
16 Q. Did anyone from Boise, Schiller ever tell
17 you anything about the topics that were covered in
18 today's deposition?
19 MS. MCCAWLEY: Objection, privileged work
20 product.
21 SPECIAL MASTER: Same ruling.
22 BY MS. BORJA:
23 Q. Did Mr. Scarola ever tell you anything
24 about the topics that were covered in today's deposition?
25 MS. MCCAWLEY: Objection, attorney/client
CONFIDENTIAL
GIUFFRE005300
CONFIDENTIAL
EXHIBIT J
To: Brad Edwards[brad@pathtojustice.com]

Cc: Sharon Churcher[Sharon.Churcher@mailonsunday.co.uk]
From: Virginia Giuffre
Sent Thur6/9/2011 9:41:33 PM
Importance: Normal
Subject Fw:
Received: Thur 6/9/201 1 9 :41:33 PM
Hello ,
Please see below message from a paper in London.I don't know how they got tbis info, but it's a bit frighteoing to me. What
do you think?
Thanks,
Jenna
- On Thu, 9/6/11, Sandra White< rote:
Fro1ILSandra White •
Subject:
To: 111111111111111
Rec~ ll,4:37 PM
Hi Virginia
This was in the Daily telegraph here today and followed up by other papers . Did you kn ow abou t it?
SX
Question Duke of York over sex abuser, says victim

The Duke of York "knows the truth" about the sexual abuse of under-age girls by his friend
Jeffrey Epstein and should be made to testify about him, a former "sex slave" of the billionaire
financier has claimed.
By .Lo
n Swaim:
6:30AM DST 09 Jun 2011
GIUFFRE004875
CONFIDENTIAL
..
Virginia Robc11stold lawyers in Florida that the Duke could give a "valuable" insight into the behaviour of Epstein, a
convicted sex offender.
She said she was afraid to name friends of Epstein whom she was made to massage because some were ''influential''
and she was .,.scared".
MissRoberts, who was born in Califomia, alleges that, from the age of 15, she was paid to follow Epstein around the
world and be sexually exploited by him and his "adult male peers, iucludiug royalty".
She was one of at least 17 women anonymously to settle lawsuits with the fonner Wall Street money manager after
alleging in a criminal inquiry in 2005 that he had abused them as under-age girls.
Epstein was sentenced to 18 months in prison in 2008 after admitting soliciting prostitution and soliciting a minor for
prostitution.
Miss Roberts, who is now 27 and lives in Australia with her young family, revived the case in foebmarywhen she
admitted she was "Jane Doe 102" and claimed she had met the Duke three times.
She was inte1viewedlast month by a lawyer for a Florida attorney who represents several of the alleged victims and is
being sued by Epstein, who claims the cases against him are bogus. She was read a short list of Epstein's male
friends and asked which "would have relevant infonnation about Jeffrey's taking advantage of under-age girls" if
they were asked to give "sworn testimony".
"Prince Andrew," suggested the lawyer, Jack Scarola. "Yes, he wouJdknow a lot of the truth," she said.
"I don't know how much he would be oble to help you with. But seeing he's in a lot of trouble himself these days -·. I
think he may be valuable. I'm not too sure of bim."
Miss Roberts described bow she was made to gratify Epstein sexually, and that he paid her to do the same to about
eight of his male mends . "Are you able to name those people for me?" asked Mr Scarola. "No, not at this stage," she
said. '' I just, some of these people arc really influential in power ... I'm just afraid to say it 10 you." She added: "I'm
really scared of where this is gonna go."
Asked about Epstein's friendslup with the Duke, Miss Roberts said: "I am angry about how they arc still up 10 their
old ways together and that they're still hanging out."
The pair were pictured walking in Central Park in New York in December. It was later claimed that the Duke was
asking Epstein to help pay £ 15,000 of the debts of his former wife, Sarah Ferguson.
Miss Roberts indicated she had given fresh evidence to FBl agents, who are looking again at Epstein's case.
There is no suggestion that the Duke of York bas done anything wrong. Epstein's attorney did not respond to a
request for comment.
A source close to the Duke of York stressed that he had no involvement with young girls and insisted that he bad "no
knowledge whatsoever" of Mr Epstein's activities until they appeared in the media.
GIUFFRE004876
CONFIDENTIAi..
To: Sharon Churcher(Sharon .Churche r@mai lonsunday .co .uk]

Sent Thur 6/9/2011 11 :59:52 PM
lmp<>11ance: Normal
Subject : Re: draft ...how abo ut this?
Received: Thur 6/9/2011 11 :59 ·52 PM
Sony took so long to reply, my computerwas frozen. f think it's absolutelyperfect...tbaukyou for sendiog me this. l found
the "Teleconlntervie~ says nothing about being a sworn statementor testimony, and whoever publishedthat art icl e
took the phrase about- straightout of my captions.Not cool!!
Anyways1 am sending this to Brad right now...Maoy Thanks!!!
Jenna
- On Thu, 9/6/11, Sharon Churcher <Sh11ron.Ch11rche1@mailonsunday.co.uk>

wrote:
From: Sharon Churcher<Sharon.Churcher@mailonsunday.co.uk>

Subject: draft...how about this?
To: "Virginia Giuffre"
Received:Thursday, 9 unc,
Hi Brad,
t am very upset about !he fact that a purported account of an off-the-cuff con-..ersalion I believed was confidential has been filed without my
knowledge or approval in a court of law.
I understood that all conversations between us were governed by attorney-client privilege. Please advise me If this is correct.
.I recall telling you and Mr . Scarola I did not wish to be involved in the proceedings in which my purported statement has been filed. I though!
when you put me on the phone to him that I was giving him some confidential help as a favour to you.
I am grateful for your decision to accept me as a client but I must ask that 1he purported statement be withdrawn rromthe record .
It you continue lo represent me - and I hope that you will- I must request lhal you inform me in wriling of any filings in which my name is
involved and send them to me for prior review to ensure that they are accurate.
Sincerely ,·
Virginia Roberts
This email has been scanned by the Messagelabs Email Security System .
For more information please visit http:/!www .rnessagelabs .com1ema1I
GIUFFRE0048TT
CONFIDENTIAL
For more information please visit http://www.messagela bs.com/e ma,I
This e-mail and any attached tiles iire intended for the named addressee onJy. It contains infonuation , which may be
confidentia l and legally priviJeged and also protected by copyright. Unless you are tbe named addressee (or authorised to
receive for the addressee) you may not copy or use it, or disclose it to anyone else . If you received it in e1Torplease notify
the sender immediately and then delete it from your system . Please be advised that the views and opinions expressed in this
e-mail may not reflect lue views aud opinions of Associated Newspapers Limited or any of its subsidiary compauies. We
make every effort to keep our network free from viruses. However , you do need to check this e-mail aud any attachments to
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Associated Newspapers Ltd. Registered Office: Northcliffe House, 2 De1ry St, Kensington, London, W8 51T. Registered
No 8412 1 England.
GIUFFRE004878
CON FIDENTIAL
To: Sharon Churcher{Sharon.Churcher@mailonsunday

.co.uk)
Sent: Fri 6(10/201112:15:55 AM
lmpor1ance: Nonnal
Subject: RE: drafl...how about this?
Received: Fri 6/ 10/201112 :15:SSAM
Too late, but i don't think he'll catch on auyways. I changed a few words around so it sounds more like a unprofessional 20
something year old. Lets see what he sends back. Will let you know. Thanks Matie!' !
xoxox Jenna
- On Fri, 10/6/ 11, Sharon Churc her <Sh11ron.Ch urch cr([i}mt1ilnm,untllly.co.uk> wrote:
From: Sharon Churcher <Sharoo.Cburcher@mailonsunday.co.uk>

Subject: RE: drafl...how about this?
To: "Virginia Giuffre" ·
Received: Friday, IO June, 2011, 12:02 AM
Take the o out of favour! Gives me away!!!
From: VirginiaGiuffreI
Sent: 09 June 2011 20.
To: Sharon Churcher
Subject: Re: draft ...how about this?
Sorry took so long to reply, my computer was frozen. r think it's absolutely perfect...tbank you for sending me this. I found
the "Telecon Interview" and it says nothing about being a sworn statement or testimony,and whoever published that article
took the phrase about Andrew straight out of my captious. Not cool!!
Anyways I am sending this to Brad right oow...Many Thanks!!!
Jenna
--- On Thu, 9/6/11~Sharon Churcher <Sht1t·o11

. Cf111rchet(ti'J11ailonsunday.cn.
11k> wrote :
From: Sharon Churcht:r<Sharon.Chun:her@rnailonsundav.co.uk>

Subject: draft ...how about this?
To: "Virginia Giuffre"
Received: llmrsday, 9 June, 20 11, 11:34 PM
Hi Brad ,
I am very upset about the ract that a purported account of an off-lhe-cuff conversation I believed was confidential has been filed without my
GIUFFREO04879
CONFIDENTIAL
knowledge or approval in a court of law
is correct.
I understood that all conversations between us were governed by attorney-client privilege. Please advise me if this
.I recall lelling you and Mr. Scarola I did not wish lo be involved in the proceedings in which my purported statement has been filed.
I though1
when you put me on the phone to him that I was giving him some confidential help as a favour to you.
from the record.

I am grateful for your decision to accept me as a client but I must ask that the purported statement be withdrawn
ti you continue to represent me - and I hope that you will - I must request that you inform me in writing of any filings in which
myname is
involved and send them to me for prior review to ensure that they are accurate.
Sincerely,
Virginia Roberts
This ema~ has been scanned by the Messagelabs Email Secu1ity System
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the sender immediately and then delete it from your system. Please be advised that the views and opinions expressed in this
e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies. We
make every effort to keep our network free from viruses. However, you do need to check thts e-mail and any attachmentsto
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GIUFFRE004880
CONFIDENTIAL
For more information please visit http:/!www.me ssagelabs.com/ema ll
This e-mail and any attached files are intended for the named addressee only. It contains infonnation , which may be
confidential and legally privileged and also p1:01ec1edby copyright. Unless you arc ti.Jcnamed addressee (or authorised to
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Associated Newspapers Ltd . Registered Office : Nortbcliffe House, 2 De1ry St, Kensington, London, W8 5TI. Registered
No 84121 England.
GIUFFRE004881
CONFIDENTIAL
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v.
Ghislaine Maxwell,
Defendant.
______________________________/
NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF

PLAINTIFF’S MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN
FEDERAL RULE OF CIVIL PROCEDURE 30(A)(2)(a)(ii), FILED UNDER SEAL
licensed to practice in Florida and before this Court pursuant to this Court’s September 29,
2015 Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in support of Plaintiff’s Motion to Exceed
Presumptive Ten Deposition Limit In Federal Rule of Civil Procedure 30(A)(2)(a)(ii), Filed
Under Seal.
3. Attached hereto as Composite Exhibit 1, is a true and correct copy of the May 17,
2016 Email Correspondence from Sigrid McCawley.
4. Attached hereto as Exhibit 2, is a true and correct copy of the May 27, 2016
Email Correspondence from Laura Menninger.
5. Attached hereto as Exhibit 3, is a true and correct copy of the Notice of Service
and Subpoe na to Juan Ales si.
6. Attached hereto as Exhib it 4, is a hue an d conect copy of the May 26, 2016
Con espondence from Sigrid Mccaw ley.
7. Attached hereto as Exhibit 5, is a hu e and conect copy of the
8. Attached hereto as Composite Exhibit 6, is a hu e and con ect copy of the Apr il
22, 20 16 Deposition Transcr ipt of Ghislaine Maxwe ll.
9. Attached hereto as Exhibit 7, is a hue an d conect copy of the Palm Beach Police
Report.
10. Attached hereto as Exhibit 8, is a hue and con ect copy of the Nove mber 21, 2005
Sworn Statement of Juan Alessi.
11. Attached hereto as Exhibit 9, is a hue an d conect copy of the May 4, 20 16 Email
Con espondence from Laura Mennin ger.
I declare under penalty of pe1jmy that the foregoing is hue an d conect.
Isl Sigrid S. Mccawley

Sigrid S. Mccawley , Esq.
By: /s/ Sigrid McCawley________________

Meredith Schultz (Pro Hac Vice)
Boies, Schiller & Flexner LLP 401 E.
Las Olas Blvd., Suite 1200 Ft.
Lauderdale, FL 33301
Tel: (954) 356-0011
David Boies
Boies, Schiller & Flexner LLP 333
Main Street
Armonk, NY 10504

Tel: (954) 524-2820

University of Utah
383 University St.
Tel: (801) 585-52021
1
I HEREBY CERTIFY that on May 27, 2016, I electronically filed the foregoing
document is being served this day on the individuals identified below via transmission of
Notices of Electronic Filing generated by CM/ECF.

Tel: (303) 831-7364
Fax: (303) 832-2628


v.
Ghislaine Maxwell,
Defendant.
______________________________/
NON-REDACTED DECLARATION OF SIGRID S. MCCAWLEY IN SUPPORT OF

PLAINTIFF VIRGINIA GIUFFRE’S RESPONSE TO MOTION TO COMPEL
ATTORNEY-CLIENT COMMUNICATIONS AND ATTORNEY WORK PRODUCT
MATERIALS
1. I am an associate with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my
Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s
Response in Opposition to Defendant’s Motion to Compel Attorney Client Communications and
Attorney Work Product Materials.
3. Attached hereto as Exhibit 1, is a true and correct copy of Emergency Petition
(CVRA Complaint) filed in Jane Doe 1 v. United States, No. 9:08-cv-80736 (S.D. Fla. July 7,
2008.
4. Attached hereto as Exhibit 2, is a true and correct copy of the Jane Does’ 3 and 4
Corrected Joinder Motion (filed under seal).
5. Attached hereto as Exhibit 3, Response to Motion to Intervene (filed under seal).
6. Attached hereto as Exhibit 4, Order denying Jane Doe 3’s motion to join.
7. Attached hereto as Exhibit 5, is a true and correct copy of the Complaint in
Edwards and Cassell v. Dershowitz.
8. Attached hereto as Exhibit 6 is a true and correct copy of Motion to Compel.
9. Attached hereto as Exhibit 7 is a true and correct copy of Response in Opposition
to Motion to Compel.
10. Attached hereto as Exhibit 8 is a true and correct copy of Reply in Support of
Motion to Compel.
11. Attached hereto as Exhibit 9 is a true and correct copy of Sur-Reply in Support
Opposition to Motion to Compel
12. Attached hereto as Exhibit 10 is a true and correct copy of Order Denying Motion
to Compel.
13. Attached hereto as Exhibit 11 is a true and correct copy of Composite Exhibit of
Deposition Excerpts from the Deposition of Virginia Giuffre, at 22-23, 131-32; 173-74; 183; 200-
12 (filed under seal).
14. Attached hereto as Exhibit 12 is a true and correct copy of Notice of Withdrawal of
Summary Judgment Motion.
15. Attached hereto as Exhibit 13 is a true and correct copy of Affidavit of Ms. Giuffre
(May 30, 2016).

16. Attached hereto as Exhibit 14 is a true and correct copy of Deposition excerpt of
Paul Cassell, Volume I, dated Oct. 16, 2015, at 39:24 – 40:2.
17. Attached hereto as Exhibit 15 is a true and correct copy of Transcript of
Scarola/Edwards interview on April 7, 2011.
18. Attached hereto as Exhibit 16 is a true and correct copy of Common interest
-
agreement.
/s/ Sigrid McCawley

Sigrid McCawley
Dated: June 1, 2016
By: /s/ Sigrid McCawley

401 E. Las Olas Blvd., Suite 1200
Tel: (954) 356-0011
Email: smccawley@bsfllp.com
David Boies
333 Main Street
Armonk, NY 10504

Ronald N. Boyce Presidential Professor of
Criminal Law
University of Utah
383 S. University St.
Salt Lake City, UT 84112-0730
(801) 585-5202 (phone)
(801) 585-2750 (fax)
Email: cassellp@law.utah.edu
Bradley Edwards (Pro Hac Vice)

Farmer, Jaffe, Weissing, Edwards,
Fistos & Lehrman, P.L.
Tel: (954) 524-2820
Fax: (954) 524-2822
Email: brad@pathtojustice.com
I HEREBY CERTIFY that on May 4, 2016, I electronically filed the foregoing document
with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document
is being served this day on the individuals identified below via transmission of Notices of
Electronic Filing generated by CM/ECF.

Tel: (303) 831-7364
Fax: (303) 832-2628

Case
Case1:15-cv-07433-LAP
1:15-cv-07433-RWSDocument 1090-12
Document Filed 06/01/16
185-2 Filed 07/30/20 Page
Page 11 of
of 115
EXHIBIT 2
(Filed Under Seal)
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 1 of 14

SOUTHERN DISTRICT OF FLORIDA
Case No. 08-80736-Civ-Marra/Johnson
JANE DOE #1 and JANE DOE #2
v.
UNITED STATES
__________ ___,;/
JANE DOE #3 AND JANE DOE #4's CORRECTED MOTION PURSUANT TO RULE 21
FOR JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as ''the new victims"), by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe #2 (also referred to as ''the current victims"). The new victims have
suffered the same violations of their rights under the Crime Victims' Rights Act (CVRA) as the
current victims. Accordingly, they desire to join in this action to vindicate their rights as well.
Because the new victims will not re-litigate any issues previously litigated by the current victims
(and because they are represented by the same legal counsel as the current victims), the
Government will not be prejudiced if the Court grants the motion. The Court may "at any time"
add new parties to the action, Fed. R. Civ. P. 2 1. Accordingly, the Court should grant the
motion. 1
FACTUAL BACKGROUND
1
As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by
way of pseudonym for the same reasons that Jane Doe # 1 and Jane Doe #2 proceeded in this
fashion. Counsel for the new victims have made their true identities known to the Government.
1
GIUFFRE004288
CONFIDENTIAL
As the Court is aware, more than six years ago, Jane Doe #1 filed the present action
against the Government, alleging a violation of her rights under the CVRA, 18 U.S.C. § 3771.
DEL She alleged that Jeffrey Epstein had sexually abused her and that the United States had
entered into a secret non-prosecution agreement (NPA) regarding those crimes in violation of her
rights. At the first court hearing on the case, the Court allowed Jane Doe #2 to also join the
action. Both Jane Doe #1 and Jane Doe #2 specifically argued that the government had failed to
protect their CVRA rights (inter alia) to confer, to reasonable notice, and to be treated with
fairness. In response, the Government argued that the CVRA rights did not apply to Jane Doe # I
and Jane Doe #2 because no federal charges had ever been filed against Jeffrey Epstein.
The Court has firmly rejected the United States' position. In a detailed ruling, the Court
concluded that the CVRA extended rights to Jane Doe #1 and Jane Doe #2 even though federal
charges were never filed. DE 189. The Court explained that because the NPA barred
prosecution of crimes committed against them by Epstein, they had "standing" to assert
violations of the CVRA rights. Id The Court deferred ruling on whether the two victims would
be entitled to relief, pending development of a fuller evidentiary record. Id.
Two other victims, who are in many respects similarly situated to the current victims,
now wish to join this action. The new victims joining at this stage will not cause any delay and
their joinder in this case is the most expeditious manner in which to pursue their rights. Because
the background regarding their abuse is relevant to the Court's assessment of whether to allow
them to join, their circumstances are recounted here briefly.
Jane Doe #3's Circumstances
GIUFFRE004289
CONFIDENTIAL
As with Jane Doe #1 and Jane Doe #2, Jane Doe #3 was repeatedly sexually abused by
Epstein. The Government then concealed from Jane Doe #3 the existence of its NPA from Jane
Doe #3, in violation of her rights under the CVRA. If allowed to join this action, Jane Doe #3
would prove the following:
In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women
whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator
in his sexual abuse and sex trafficking scheme. In fact, it became known to the government that
Maxwell herself regularly participated in Epstein's sexual exploitation of minors, including Jane
Doe #3. Maxwell persuaded Jane Doe #3 (who was then fifteen years old) to come to Epstein's
mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators
coerced dozens of other children (including Jane Doe #1 and Jane Doe #2). When Jane Doe #3
began giving Epstein a "massage," Epstein and Maxwell turned it into a sexual encounter, as
they had done with many other victims. Epstein then became enamored with Jane Doe #3, and
with the assistance of Maxwell converted her into what is commonly referred to as a "sex slave."
Epstein kept Jane Doe #3 as his sex slave from about 1999 through 2002, when she managed to
escape to a foreign country and hide out from Epstein and his co-conspirators for years. From
1999 through 2002, Epstein frequently sexually abused Jane Doe #3, not only in West Palm
Beach, but also in New York, New Mexico, the U.S. Virgin Islands, in international airspace on
his Epstein's private planes, and elsewhere.
Epstein also sexually trafficked the then-minor Jane Doe, making her available for sex to
politically-connected and financially-powerful people. Epstein's purposes in "lending" Jane Doe
(along with other young girls) to such powerful people were to ingratiate himself with them for
GIUFFRE004290
CONFIDENTIAL
business, personal, political, and financial gain, as well as to obtain potential blackmail
information.
One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual
relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein's
and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual
relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but
also on private planes, in New York, New Mexico, and the U.S. Virgin Islands. In addition to
being a participant in the abuse of Jane Doe #3 and other minors, Deshowitz was an eye-witness
to the sexual abuse of many other minors by Epstein and several of Epstein's co-conspirators.
Dershowitz would later play a significant role in negotiating the NPA on Epstein's behalf.
Indeed, Dershowitz helped negotiate an agreement that provided immunity from federal
prosecution in the Southern District of Florida not only to Epstein, but also to "any potential co-
conspirators of Epstein." NPA at 5. Thus, Dershowitz helped negotiate an agreement with a
provision that provided protection for himself against criminal prosecution in Florida for
sexually abusing Jane Doe #3. Because this broad immunity would have been controversial if
disclosed, Dershowitz (along with other members of Epstein's defense team) and the
Government tried to keep the immunity provision secret from all of Epstein's victims and the
general public, even though such secrecy violated the Crime Victims' Rights Act.
Ghislaine Maxwell was another person in Epstein's inner circle and a co-conspirator in
Epstein's sexual abuse. She was someone who consequently also appreciated the immunity
granted by the NP A for the crimes she committed in Florida. In addition to participating in the
sexual abuse of Jane Doe #3 and others, Maxwell also took numerous sexually explicit pictures
GIUFFRE004291
CONFIDENTIAL
of underage girls involved in sexual activities, including Jane Doe #3. She shared these
photographs (which constituted child pornography under applicable federal laws) with Epstein.
The Government is apparently aware of, and in certain instances possesses some of these
photographs.
Perhaps even more important to her role in Epstein's sexual abuse ring, Maxwell had
direct connections to other powerful individuals with whom she could connect Epstein. For
instance, one such powerful individual Epstein forced Jane Doe #3 to have sexual relations with
was a member of the British Royal Family, Prince Andrew (a/k/a Duke of York). Jane Doe #3
was forced to have sexual relations with this Prince when she was a minor in three separate
geographical locations: in London (at Ghislaine Maxwell's apartment), in New York, and on
Epstein's private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged
girls). Epstein instructed Jane Doe #3 that she was to give the Prince whatever he demanded and
required Jane Doe #3 to report back to him on the details of the sexual abuse. Maxwell
facilitated Prince Andrew's acts of sexual abuse by acting as a "madame" for Epstein, thereby
assisting in internationally trafficking Jane Doe #3 (and numerous other young girls) for sexual
purposes.
Another person in Epstein's inner circle of friends (who becomes apparent with almost
no investigative effort) is Jean Luc Brunel. Epstein sexually trafficked Jane Doe #3 to Jean Luc
Brunel many times. Brunel was another of Epstein's closest friends and a regular traveling
companion, who had many contacts with young girls throughout the world. Brunel has been a
model scout for various modeling agencies for many years and apparently was able to get U.S.
passports for young girls to ''work" as models. He would bring young girls (ranging to ages as
GIUFFRE004292
CONFIDENTIAL
Case 9:0B-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 6 of 14
young as twelve) to the United States for sexual purposes and farm them out to his friends,
especially Epstein. Brunel would offer the girls "modeling" jobs. Many of the girls came from
poor countries or impoverished backgrounds, and he lured them in with a promise of making
good money. Epstein forced Jane Doe #3 to observe him, Brunel and Maxwell engage in illegal
sexual acts with dozens of underage girls. Epstein also forced Jane Doe #3 to have sex with
Brunel on numerous occasions, at places including Epstein's mansion in West Palm Beach, Little
St. James Island in the U.S. Virgin Islands (many including orgies that were comprised of other
underage girls), New York City, New Mexico, Paris, the south of France, and California.
Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men,
including numerous prominent American politicians, powerful business executives, foreign
presidents, a well-known Prime Minister, and other world leaders. Epstein required Jane Doe #3
to describe the events that she had with these men so that he could potentially blackmail them.
The Government was well aware of Jane Doe #3 when it was negotiating the NPA, as it
listed her as a victim in the attachment to the NP A. Moreover, even a rudimentary investigation
of Jane Doe #3's relationship to Epstein would have revealed the fact that she had been
trafficked throughout the United States and internationally for sexual purposes. Nonetheless, the
Government secretly negotiated a non-prosecution agreement with Epstein precluding any
Federal prosecution in the Southern District of Florida of Epstein and his co-conspirators. As
with Jane Doe #1, and Jane Doe #2, the Government concealed the non-prosecution agreement
from Jane Doe #3 - all in violation of her rights under the CVRA - to avoid Jane Doe #3 from
raising powerful objections to the NPA that would have shed tremendous public light on Epstein
GIUFFRE004293
CONFIDENTIAL
and other powerful individuals and that would likely have been prevented it from being
concluded in the secretive manner in which it was.
Jane Doe #4's Circumstances
If permitted to join this action, Jane Doe #4 would allege, and could prove at trial, that
she has CVRA claims similar to those advanced by Jane Doe #1 and Jane Doe #2, based on the
following:
As with the other Jane Does, Jane Doe #4 was repeatedly sexually abused by Epstein. In
or around the summer of 2002, Jane Doe #4, an economically poor and vulnerable sixteen-year-
old child, was told by another one of Epstein's underage minor sex abuse victims, that she could
make $300 cash by giving an old man a massage on Palm Beach. An acquaintance of Jane Doe
#4 (also a minor sexual abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4
to go to Epstein's house to give him a massage. During that call, Epstein himself got on the
phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to
his mansion in Palm Beach.
Jane Doe #4 then went to Epstein's mansion and was escorted upstairs to Epstein's large
bathroom by one of Epstein's assistants. Shortly thereafter Jeffrey Epstein emerged and lay face
down on the table and told Jane Doe #4 to start massaging him. Epstein asked Jane Doe #3 her
age and she told him she had recently turned sixteen. Epstein subsequently committed illegal
sexual acts against Jane Doe #4 on many occasions.
Epstein used a means of interstate communication (i.e., a cell phone) to arrange for these
sexual encounters. Epstein also frequently travelled in interstate commerce (i.e., on his personal
jet) for purposes of illegally sexually abusing Jane Doe #4.
GIUFFRE004294
CONFIDENTIAL
The acts Epstein committed against Jane Doe #4, constituted numerous federal sex
offenses, some of which do not carry a statute oflimitations and thus are not time-barred. See 18
U.S.C. § 3283. And these offenses were the kinds of offenses that the Federal Bureau of
Investigation (FBI) and U.S. Attorney's Office for the Southern District of Florida were pursuing
in 2007. So far as Jane Doe #4 is aware, the U.S. Attorney's Office made no serious effort to
locate her. Instead, after identifying approximately forty separate underage sexually abused
victims, and apparently preparing a 53-page federal indictment and with full awareness of the
existence of many victims like Jane Doe #4- unidentified and not interviewed- it entered into a
non-prosecution agreement barring prosecution of Epstein's federal crimes against these victims.
This is contrary to the Government's nonnal approach in prosecuting federal sex offenses. It
also violated Jane Doe #4's rights under the CVRA, including the fact that she had a
"reasonable" right to confer with the U.S. Attorney's Office before they entered into an
agreement with a sex offender barring prosecution of him for the crimes he committed against
her. 18 U.S.C. § 377l(a)(5).
MOTION FOR JOINDER
Jane Doe #3 and Jane Doe #4 now both move to join this action filed by Jane Doe #1 and
Jane Doe #2, pursuant to Rule 21 of the Federal Rules of Civil Procedure. Rule 21 provides that
"[o]n motion or on its own, the court may at any time, on just terms, add ... a party." Rule 21
"grants the court broad discretion to permit a change in the parties at any stage of a litigation."
Ford v. Air Line Pilots Ass'n Int'/, 268 F. Supp. 2d 271,295 (E.D.N.Y. 2003) (internal quotation
omitted). The new victims should be allowed to join the current victims in this action under Rule
21.
GIUFFRE004295
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The new victims will establish at trial that the Government violated their CVRA rights in
the same way as it violated the rights of the other victims. The new victims' participation in this
case is important because it appears that the Government intends to raise a factual defense that
somehow it did keep Jane Doe #1 and Jane Doe #2 properly informed of what was happening in
the criminal prosecution. Of course, if four victims all testify consistently that they were not
properly informed by the Government (as we believe they will), that provides a stronger case for
a CVRA violation.
In addition, Jane Doe #3 and Jane Doe #4's participation is relevant to a defense the
Court has allowed the Government to raise. The Court has previously ruled that the victims'
request for rescission of the NPA "implicates a fact-sensitive equitable defense which must be
considered in the historical factual context of the entire interface between Epstein, the relevant
prosecutorial authorities and the federal offense victims - including an assessment of the
allegation of a deliberate conspiracy between Epstein and federal prosecutors to keep the victims
in the dark on the pendency of negotiations between Epstein and federal authorities until well
after the fact and presentation of the non-prosecution agreement to them as afait accompli." DE
189 at 12 n.6 (emphasis added). Jane Doe #3's and Jane Doe #4's participation in this case will
help to show what the "entire interface" was between the Government and the victims and thus
to respond to the Government's estoppel arguments as well as other defenses that it appears to be
preparing to raise. See, e.g., DE 62 (52-page response from the Government to the victim's
summary judgment motion, raising numerous factually-based and other arguments against the
victim's position).
GIUFFRE004296
CONFIDENTIAL
Jane Doe #3's and Jane Doe #4's participation is also directly relevant to the discovery
disputes currently pending in this case. The Government has raised various relevancy objections
to the documents that Jane Doe #1 and Jane Doe #2 are attempting to obtain. The current
victims have responded by explaining how these documents are relevant, including explaining
how these documents might bear on the way in which Epstein used his powerful political and
social connections to secure a favorable plea deal, as well as provide proof of the Government's
motive to deliberately fail to investigate certain aspects of the victims' claims in an effort to
maintain the secrecy of the facts and resolve the case without the victims' knowledge. See, e.g.,
DE 266 at 6-10. Jane Doe #3 and Jane Doe #4's participation will help prove the relevancy of
these requests, as well as the need for those requests.
One clear example is Request for Production No. 8, which seeks documents regarding
Epstein's lobbying efforts to persuade the Government to give him a more favorable plea
arrangement and/or non-prosecution agreement, including efforts on his behalf by Prince
Andrew and former Harvard Law Professor Alan Dershowitz. Jane Doe #1 and Jane Doe #2
have alleged these materials are needed to prove their allegations that, after Epstein signed the
non-prosecution agreement, his performance was delayed while he used his significant social and
political connections to lobby the Justice Department to obtain a more favorable plea deal. See,
e.g., DE 225 at 7-8 (discussing DE 48 at 16-18). Jane Doe #3 has directly person knowledge of
Epstein's connection with some of these powerful people and thus how Epstein might have used
them to secure favorable treatment.
Adding two new victims to this case will not delay any of the proceedings. They will
simply join in motions that the current victims were going to file in any event. For example, the
GIUFFRE004297
CONFIDENT/AL
new victims will simply join in a single summary judgment motion that the current victims
anticipate filing after discovery has been completed.
Nor will adding the new victims prejudice the United States. As the court is aware, this
Court is still in its initial discovery stage. The Court is currently considering whether to reject
the Government's assertion of privilege over documents regarding the case. See DE 265
(victims' reassertion of objections to the Government privilege claims). The new victims do not
2
seek any additional discovery beyond that previously sought by the current victims.
Accordingly, the United States will not be prejudiced or burdened by adding them to this case.
The CVRA does not contain any statute of limitations for filing an action to enforce
rights under the statute. Accordingly, were the Court to deny this motion, the result might be
that the new victims would then be forced to file a separate suit raising their claims, which would
then possibly proceed on a separate litigation track. Rather than require duplicative litigation,
the Court should simply grant their motion to join.
Jane Doe #1 and Jane Doe #2 support the joinder motion. Counsel for the victims have
discussed this motion with the Government at length in an effort to avoid any need to file a
substantive pleading on the issue. Counsel for the victims asked the Government during the
summer for its position on joinder. The Government, however, took the matter under
advisement for months. Ultimately, after several inquiries from victims counsel, the
Government indicated without explanation that it opposes this motion. Counsel for the victims
has requested a meeting with the Government on this issue, which will hopefully occur in
2
Jane Doe #3 and Jane Doe #4 have asked the Government to provide them with the
record of their statements that they provided to the FBI. These FBI 302's should be only a few
pages long.
11
GIUFFRE004298
CONFIDENT/AL
January. In the meantime, however, counsel for the victims believe that it is no longer
appropriate to delay filing this motion and accordingly file it at this time. Because the
Government is apparently opposing this motion, Jane Doe #3 and Jane Doe #4 have described
the circumstances surrounding their claims so that the Court has appropriate information to rule
on the motion.
12
GIUFFRE004299
CONFIDENTIAL
CONCLUSION
Jane Doe #3 and Jane Doe #4 should be allowed to join this action, pursuant to Rule 21
of the Federal Rules of Civil Procedure. Their joinder should be conditioned on the requirement
that they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe #2. A
proposed order to that effect is attached to this pleading.
DATED: January 2, 2015

Bradley J. Edwards
FARMER, JAFFE, WEIS SING,
Telephone (954) 524-2820
Facsimile (954) 524-2822
E-mail: brad@pathtojustice.com
And
Paul G. Cassell
Pro Hae Vice
University of Utah•
332 S. 1400 E.
Telephone: 801-585-5202
Facsimile: 801-585-6833
E-Mail: cassellp@law.utah.edu
Attorneys for Jane Doe #1 and Jane Doe #2
• This daytime business address is provided for identification and correspondence

purposes only and is not intended to imply institutional endorsement by the University of Utah
13
GIUFFRE004300
CONFIDENTIAL
I certify that the foregoing document was served on January 2, 2015, on the following using
the Court's CM/ECF system:
Dexter Lee
A. Marie Villafana
500 S. Australian Ave., Suite 400
West Palm Beach, FL 33401
(561) 820-8711
Fax: (561) 820-8777
E-mail: Dexter.Lee@usdoj.gov
E-mail: ann.marie.c. villafana@usdoj.gov
Attorneys for the Government
Isl Bradley J. Edwards
14
GIUFFRE004301
CONFIDENTIAL
Case
1:15-cv-07433-RWS Document
Document1090-13
185-11 Filed
Filed 07/30/20
06/01/16 Page
Page 11 of
of 23
1
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07/30/20
1 A I believe this is when I was hoping to

2 join the CVRA case.
3 Q All right. And do you know when this
4 document was filed?
5 And actually, just to be clear, about
6 halfway there's actually a second document that was
7 filed. So this is a composite exhibit. Let me be
8 very clear.
9 So after page 14 -- I'm sorry, 13, there's
10 a second document that is styled Jane Doe #3 and Jane
11 Doe #4's Corrected Motion Pursuant to Rule 21 for
12 Joinder In Action.
13 Do you see that?
14 A Did you say page 14?
15 Q It is on the 14th page of this document.
16 Do you see that?
17 A I do.
18 Q And so this composite Exhibit 2 has both a
19 motion and a corrected motion.
20 Do you see that?
21 A Yes.
22 Q And were both of those pleadings
23 authorized by you to be filed?
24 A Yes.
25 Q In other words, you wanted to join the
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1 CVRA action in or about December 30th, 2014, correct?

2 A I -- I'm not aware of the exact dates.
3 There's no dates on this. But I did try to join the
4 motion, yes.
5 Q All right. If you can look at the top
6 line of the document.
7 A Yes.
8 Q Does it say, Entered on FLSD --
9 A Oh, it does, too, I'm sorry, yes.
10 Q That's all right. So does that refresh
11 your memory as to about when you first sought to join
12 the CVRA action?
13 A Yes.
14 Q December 30th, 2014, correct?
15 A Yes.
16 Q And the corrected motion was filed a few
17 days later, correct?
18 A Yes, correct.
19 Q If I could turn to Defendant's Exhibit 3,
20 which was January 21st.
21 (Exhibit 3 marked.)
22 MR. EDWARDS: Thank you.
23 Q (BY MS. MENNINGER) Do you recognize this
24 document?
25 A Yes, I do.
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1 physical features of Ghislaine Maxwell?

2 A I can tell you that she had very large
3 natural breasts. I can tell you that her pubic hair
4 was dark brown, nearly black. I don't remember any
5 specific birthmarks or moles that I could point out
6 that would be relevant.
7 Q Any scar?
8 A I don't remember any scars.
9 Q Any tattoos?
10 A No tattoos.
11 Q When did you next go to the El Brillo
12 house?
13 A I believe it would have been the next day.
14 Q You believe it would have been or was it?
15 MR. EDWARDS: Form.
16 A I know that it was consecutive, that I
17 continued to go there after my first -- the first
18 time that the abuse took place there. It was
19 consecutive that I was there, I believe, over the
20 next course of weeks.
21 Q (BY MS. MENNINGER) What day of the week
22 was the first time you went?
23 A I don't know.
24 Q Do you know whether you went the very next
25 day or not?
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1 A I believe I did.
2 Q All right. How did you get there the very
3 next day?
5 A I believe my dad dropped me off again.
6 Q (BY MS. MENNINGER) When you say you
7 believe, do you recall him doing that or are you
8 guessing?
9 A I don't -- well, this is how I figure
10 this. I don't remember Ghislaine picking me up from
11 Mar-a-Lago. I didn't have my own car. So the only
12 way I could have really gotten there would have been
13 my dad picking me up -- I mean, sorry, dropping me
14 off.
15 Q Do you have a distinct recollection of
16 your father dropping you off there more than one day
17 in a row?
18 A Yes.
19 Q You do not recall the car he was driving?
20 A Like I said, he always drove trucks.
21 That's as good as I can get.
22 Q And so -- and you worked on weekends as
23 well at Mar-a-Lago or no?
24 A No.
25 Q So the second day would have had to be
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1 A I wouldn't say directly.

2 Q How --
3 A I'd say I stayed with my parents for --
4 like, I think I finished school at Crestwood. So I
5 would have been in, I don't know, I guess eighth
6 grade, finished eighth grade. And then -- I don't
7 know. I really don't know. Around eighth grade.
8 Q You went to Growing Together?
9 A I think -- I think it was then.
10 Q And how many years did you live at Growing
11 Together?
12 A Over a year.
13 Q Were you ever in foster care?
14 A What Growing Together was, was like a
15 group home that sent you away to foster parents every
16 night.
17 Q So you lived in other people's homes
18 during the period of time you were assigned to
19 Growing Together?
20 A Well, you stayed at Growing Together
21 during the day and then at night you get sent home
22 with parents.
23 Q Did you go to school while you were at
24 Growing Together?
25 A Yeah, they offer education there.
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1 Q So the education was at Growing Together?

2 A Yeah.
3 Q You did not attend a Palm Beach County --
4 A I did, but you had to earn your levels up
5 to be able to go outside. So I don't remember what
6 level you have to get up to, to go out to another
7 school. I think there was like seven levels or
8 something. And you had to make it to, like, level 4
9 to be able to go to outside school.
10 Q So for some period of time you were
11 assigned to Growing Together and you were going to
12 school at Growing Together. And for some period of
13 time you were going to other schools and coming back
14 to Growing Together?
15 A Correct.
16 Q And then when you came back to Growing
17 Together, you were sent to spend the night at a
18 family's home?
19 A Yes.
20 Q So you never slept at Growing Together?
21 A No.
22 Q Did you live -- other than living at or
23 staying at Growing Together during the day and
24 sleeping at these other homes at night, is there
25 anywhere else that you recall living in the period
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1 a 3. I think it's
2 . I really can't make out
3 the telephone number.
4 Q Okay. Do you see Relationship? Can you
5 read that?
6 A Friend.
7 Q Okay. Do you see just below that there's
8 a line that says number 21?
9 A Do not stop -- sorry, Do not sign
10 application until requested to do so by
11 administrating an oath.
12 Q Okay.
13 A Applicant's signature age 13 or older.
14 Q Oh, it's by the signature line?
15 A Yeah.
16 Q And that's your signature?
17 A Yes.
18 Q All right. And this is the document that
19 you recall filling out for your first passport?
20 A I don't recall doing it, but yes, it's in
21 my handwriting and it's got all of my information on
22 it.
23 Q Okay. And on line -- box 23 it's got your
24 driver's license checked off, right?
25 A July 23. Yeah, I really can't make out
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1 And when they say massage, that means erotic, okay?

2 That's their term for it. I think there are plenty
3 of other witnesses that can attest to what massage
4 actually means.
5 And I'm telling you that Ghislaine told me
6 to go to and give him a massage, which
7 means sex.
8
10
Q Okay. So
you to go give a massage to

- -- Ghislaine Maxwell told
A Correct.
11 Q That's your testimony?
12 A That is my testimony.
13 Q All right. Ghislaine Maxwell told you to
14 go give a massage to , correct?
15 A Correct.
16 Q Ghislaine Maxwell told you to give a
17 massage to , correct?
18 A Correct.
19 Q Ghislaine Maxwell told you to give a
20 massage to , correct?
21 A Correct.
22 Q When did Ghislaine Maxwell tell you to
23 give a massage to ?
24 A I don't know dates.
25 Q Where were you?
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1 A When it happened?
2 Q When Ghislaine Maxwell used the words, Go
3 give a massage to Bill Richardson, where were you?
4 MR. EDWARDS: Object to the form.
5 Mischaracterizes her testimony.
6 A I can't tell you where we were. I know
7 where I was sent to. I don't know where we were when
8 she told me to do that.
9 Q (BY MS. MENNINGER) Where were you sent
10 to --
11 A New Mexico.
12 Q -- by Ghislaine Maxwell?
14 Mischaracterizes her testimony again.
15 A Are you smiling at me because --
16 Q (BY MS. MENNINGER) No, I'm asking you to
17 answer the question.
18 A I have answered the question. I was sent
19 to New Mexico.
20 Q Okay. Where were you sent from?
21 A I already answered that. I don't know
22 where I was sent from.
23 Q Okay.
24 A I was flying everywhere with these people.
25 Q Where were you sent by Ghislaine Maxwell
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1 to have sex with ?

3 Mischaracterized her testimony.
4 A Many places.
5 Q (BY MS. MENNINGER) Ghislaine Maxwell sent
6 you to many places to have sex with ?
8 A It happened at many places, yes.
9
10
Q (BY MS. MENNINGER) You had sex with
at many places is what you're saying,

-
11 correct?
12 A I was sent to at many
13 places to have sex with him.
14 Q When did Ghislaine Maxwell send you to a
15 place to have sex with ?
16 A You are asking --
18 A -- me to answer the impossible.
19 Q (BY MS. MENNINGER) All right. When did
20 Ghislaine Maxwell send you to have sex with the owner
21 of a large hotel chain?
23 Mischaracterization.
24 A I'm going to keep answering the questions
25 the same way that I keep answering them. I don't
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1 know where it was when she said to go do this.

2 Q (BY MS. MENNINGER) Okay. Where were you
3 sent to have sex with the owner of a large hotel
4 chain by Ghislaine Maxwell?
6 A I believe that was one time in France.
7 Q (BY MS. MENNINGER) Which time in France?
8 A I believe it was around the same time that
9 Naomi Campbell had a birthday party.
10 Q Where did you have sex with the owner of a
11 large hotel chain in France around the time of Naomi
12 Campbell's birthday party?
13 A In his own cabana townhouse thing. It was
14 part of a hotel, but I wouldn't call it a hotel.
15 Jeffrey was staying there. Ghislaine was
16 staying there. Emmy was staying there. I was
17 staying there. This other guy was staying there. I
18 don't know his name.
19 I was instructed by Ghislaine to go and
20 give him an erotic massage.
21 Q She used the words erotic massage?
22 A No, that's my word. The word massage is
23 what they would use. That's their code word.
24 Q Was she in the room when you gave this
25 erotic massage to the owner of a large hotel chain?
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1 A No, she was not in the room. She was in

2 another cabana.
3 Q And other than telling you to go give the
4 owner of this large hotel chain a massage, do you
5 remember any other words she used to you to direct
6 you in what you should do?
7 A Not at the time, no.
8 Q Where did -- where were you and where was
9 Ms. Maxwell when she directed you to go have sex with
10 Marvin Minsky?
12 A I don't know.
13 Q (BY MS. MENNINGER) Where did you go to
14 have sex with Marvin Minsky?
15 A I believe it was the U.S. Virgin Islands,
16 Jeff's -- sorry, Jeffrey Epstein's island in the U.S.
17 Virgin Islands.
18 Q And when was that?
19 A I don't know.
20 Q Do you have any time of year?
21 A No.
22 Q Do you know how old you were?
23 A No.
24 Q Other than Glenn Dubin, Stephen Kaufmann,
25 Prince Andrew, Jean Luc Brunel, Bill Richardson,
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1 another prince, the large hotel chain owner and

2 Marvin Minsky, is there anyone else that Ghislaine
3 Maxwell directed you to go have sex with?
4 A I am definitely sure there is. But can I
5 remember everybody's name? No.
6 Q Okay. Can you remember anything else
7 about them?
8 A Look, I've given you what I know right
9 now. I'm sorry. This is very hard for me and very
10 frustrating to have to go over this. I don't -- I
11 don't recall all of the people. There was a large
12 amount of people that I was sent to.
13 Q Do you have any notes of all these people
14 that you were sent to?
15 A No, I don't.
16 Q Where are your notes?
17 A I burned them.
18 Q When did you burn them?
19 A In a bonfire when I lived at Titusville
20 because I was sick of going through this shit.
21 Q Did you have lawyers who were representing
22 you at the time you built a bonfire and burned these
23 notes?
24 A I've been represented for a long time, but
25 it was not under the instruction of my lawyers to do
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1 this. My husband and I were pretty spiritual people

2 and we believed that these memories were worth
3 burning.
4 Q So you burned notes of the men with whom
5 you had sex while you were represented by counsel in
6 litigation, correct?
8 A This wasn't anything that was a public
9 document. This was my own private journal, and I
10 didn't want it anymore. So we burned it.
11 Q (BY MS. MENNINGER) When did you write
12 that journal?
13 A Just over time. I started writing it
14 probably in, I don't know, I can't speculate, 2012,
15 2011.
16 Q So you did not write this journal at the
17 time it happened?
18 A No.
19 Q You started writing this journal
20 approximately a decade after you claim you finished
21 being sexually trafficked, correct?
22 A Yes.
23 Q And you started writing a journal after
24 you had a lawyer, correct?
25 A Correct.
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1 Q Including Mr. Edwards, who is sitting

2 right here, correct?
3 A Correct.
4 Q What did that journal look like?
5 A It was green.
6 Q And what else?
7 A It was just a spiral notebook.
8 Q Okay. And what did you put into that
9 green spiral notebook?
10 A Bad memories. Things that I've gone
11 through, lots of things, you know. I can't tell you.
12 There was a lot of pages. It was over 300 pages in
13 that book.
14 Q Did you ever show that book to your
15 lawyers?
16 A No.
17 Q Did you show that book to anyone?
18 A My husband.
19 Q Did you show it to anyone else besides
20 your husband?
21 A No.
22 Q Did you tear out pages and give them to
23 Sharon Churcher?
24 A No, I wrote -- those pages that you're
25 talking about, I wrote for her specifically. She
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1 wanted to know about the Prince Andrew incident.

2 Q So that's a different piece of paper?
3 A Yeah, that's just random paper.
4 Q So you had a green spiral notebook that
5 you began sometime in 2011 or 2012 in which you wrote
6 down your recollections about what had happened to
7 you, and you burned that in a bonfire in 2013.
8 Did I get that right?
9 A You got that right.
10 Q And do you have no other names of people
11 to whom you claim Ghislaine Maxwell directed you to
12 have sex, correct?
13 A At this time, no.
14 Q Is there any document that would refresh
15 your recollection that you could look at?
16 A If you have a document you'd like to show
17 me, I would be glad to look at it and tell you the
18 names I recognize off of that.
19 Q I'm just asking you if there's a document
20 you know of that has this list of names in it?
21 A Not in front of me, no.
22 Q Where is the original of the photograph
23 that has been widely circulated in the press of you
24 with Prince Andrew?
25 A I probably still have it. It's not in my
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1 possession right now.

2 Q Where is it?
3 A Probably in some storage boxes.
4 Q Where?
5 A In Sydney.
6 Q Where in Sydney?
7 A At some family's house. We got the boxes
8 shipped to Australia, and they were picked up off the
9 porch by my nephews and brought to their house.
10 Q Which is where?
11 A In Sydney.
13 A .
14 Q And who lives in that house?
15 A Well, it's owned by my mother-in-law and
16 father-in-law, but my nephews live in the house.
17 Q What are their names?
18 A I'm not giving you the names of my
19 nephews.
20 Q What's the address of the house?
21 A Why would you want that?
22 Q I want to know where the photograph is.
23 I'm asking you where the photograph is. And you've
24 just told me it's somewhere in
25 A Yes.
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1 Q So where in is the photograph

2 located?
3 A If I can't 100 percent say that the
4 photograph is there, it could be at my house that I
5 presently live in. I'm not going to give you the
6 address of my nephews' residence.
7 Q When is the last time you saw the
8 photograph in person?
9 A When I packed and left America.
10 Q Colorado?
11 A Yes.
12 Q All right. So you had that photograph
13 here with you in Colorado?
14 A Yes.
15 Q What's on the back of the photograph?
16 A I'm sorry?
17 Q Is there anything on the back of the
18 photograph?
19 A There's like the date it was printed, but
20 no writing or anything.
21 Q Okay. Does it say where it was printed?
22 A I don't believe so. I think it just -- I
23 don't remember. I just remember there's a date on
24 it.
25 Q Whose camera was it taken with?
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1 A My little yellow Kodak camera.

2 Q Who took the picture?
3 A Jeffrey Epstein.
4 Q And where did you have it developed?
5 A I believe when I got back to America.
6 Q So where?
7 A I don't know.
8 Q Palm Beach?
9 A I don't know.
10 Q What is the date the photograph was
11 printed?
12 A I believe it's in March 2001.
13 Q Okay.
14 A But that's just off of my photographic
15 memory. I don't -- it could be different, but I
16 think it's March 2001.
17 Q You have a photographic memory?
18 A I'm not saying I have a photographic
19 memory. But if I'd look at the back of the photo and
20 I remember what it says, I believe it was March 2001.
21 Q Did the photograph ever leave your
22 possession for a while?
23 A I gave it to the FBI.
24 Q Okay. And when did you get it back?
25 A When they took copies of it.
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1 Q When was that?

2 A 2011.
3 Q When they came to interview you?
4 A Yes.
5 Q So from 2011 until you left Colorado it
6 was in your personal possession?
7 A Yes.
8 Q What other documents related to this case
9 are in that, storage boxes in Australia?
11 A Documents related to this case -- there --
12 I don't know. I really can't tell you. I mean,
13 there's seven boxes full of Nerf guns, my kids' toys,
14 photos. I don't know what other documents would be
15 in there.
16 Q (BY MS. MENNINGER) Did anyone search
17 those documents after you received discovery requests
18 from us in this case?
19 A I haven't been able to obtain those boxes.
20 I can't get them sent back up to me. It's going to
21 cost me a large amount of money. And right now I'm
22 trying to look after my family, so I'm not able to
23 afford to get them up.
24 Q You live in Australia, correct?
25 A I do.
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1 read it.
2 MS. MENNINGER: We're going off the
3 record.
4 MR. EDWARDS: Yeah, that's fine. She'll
5 read.
6 THE VIDEOGRAPHER: That concludes today's
7 proceedings. We're off the record at 5:28.
8 (Proceedings concluded at 5:28 p.m.)
9
10 * * * * * * *
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Case
Document1090-14 Filed 06/01/16
185-13 Filed 07/30/20 Page
Page 11 of
of 13
EXHIBIT 13
'JMFE6OEFS4FBM


v.
Ghislaine Maxwell,
Defendant.
________________________________/
AFFIDAVIT OF VIRGINIA GIUFFRE
I, Virginia Giuffre, swear and affirm as follows:
1. In around March 2011, I began discussions with attorney Bradley J. Edwards for the
purpose of retaining him as my legal counsel. It was my understanding that I was obtaining legal
services from him at that time.
2. In around March 2014, I hired attorneys Bradley J. Edwards and Paul G. Cassell to
represent me on legal matters, including a Crime Victims’ Rights Act (CVRA) action then
pending in Florida court in Florida. They have represented me (along with other attorneys)
continuously since then.
3. I have had confidential communications with Mr. Edwards and Mr. Cassell for the
purpose of seeking and receiving legal advice from them. I did not intend for any of my
confidential communications with them to be disclosed.
4. With regard to the defamation case known as Edwards and Cassell v. Dershowitz, I
did not authorize Mr. Edwards and Mr. Cassell to disclose any of my confidential
communications with them.
1
2
Case
Document1090-15 Filed 06/01/16
185-14 Filed 07/30/20 Page
Page 11 of
of 15
EXHIBIT 14
'JMFE 6OEFS 4FBM

1
1 IN THECIRCUITCOURT
OFTHESEVENTEENTH
JUDICIAL
CIRCUITIN ANDFOR
2 BROWARDCOUNTY,FLORIDA
3 CASENO. CACE15-000072
4
5 BRADLEY
J. EDWARDS
and PAULG. CASSELL,
6
Plaintiffs /Counterclaim Defendants,
7
vs.
8
9 ALAN
M. DERSHOWITZ,
10
Defendant/Counterclaim Plaintiff.
__________________ !
11
12
13
14 VIDEOTAPED
DEPOSITIONOF
15 PAULG. CASSELL
16 TAKEN
ONBEHALFOFTHEDEFENDANT
17 VOLUME
I, PAGES1 to 151
18
19
20 Friday, October 16, 2015
21 1 :33 p.m. - 4:31 p.m.
22
110 Southeast 6th Street
23 110 Tower - Suite 1850
24
25 Theresa Tomaselli, RMR
ESQUIREDEPOSITION
SOLUTIONS
(954 ) 331-4400
39
1 2014, you had a sufficient basis under the Federal Rules

2 of Procedure and applicable ethical rules to allege that
3 anyone who got a massage at Mr. Epstein's residences had
4 abused minors?
5 A. No.
6 Q. What -- I'm gonna back up now. With respect
7 again to other minors, as of December30th, 2014, had
8 anyone -- had any young woman,other than -- we will
9 put Virginia -- I'm going to ask about Virginia Roberts
10 separately.
11 A. Okay.
12 Q. had any other young womantold you she had
13 been abused
14 A. No other young womanhad told me that, no.
15 a. Had -- as of that date, had anyone told you
16 that had abused other minors?
17 A. Had
18 MS. McCAWLEY: I'm going to object for a
19 momenthere. To the extent that you're going to
20 be answering a question that requires you to
21 divulge any attorney/client communication with
22 Virginia Roberts, I have a standing objection
23 that I'm putting on the record right now.
24 Virginia Roberts does not waive her
25 attorney /client privilege with her lawyers, and
ESQUIREDEPOSITION
SOLUTIONS
(954) 331-4400
40
1 they are not entitled to testify as to

2 information that she intended to be confidential
3 that she communicatedto her lawyers.
4 MR.SCAROLA:And I would instruct you not to
5 answer the question on that basis.
6 MR.SIMPSON:All right.
7 BYMR.SIMPSON:
8 Q. I -- I disagree with the position on the
9 privilege, but I will -- you're going to follow the
10 instruction not to answer those questions?
11 A. I am.
12 Q. Okay. I want to put then aside, Virginia
13 Roberts. Had anyone else as of December30th, 2014,
14 told you that had abused any minor,
15 other than Virginia Roberts?
16 A. No one -- no other -- no other person -- no
17 other person had spoken to me and told me that directly,
18 no.
19 Q. And when you say, no other person, I'm -- I'm
20 including not just any -- any victims of Mr. Epstein,
21 but anyone else. No one had said to you, I have
22 knowledge that abused a minor, other
23 than Virginia Epstein [sic]; is that -- Virginia
24 Roberts; is that correct?
25 MR.SCAROLA:Let me ask you for a
ESQUIREDEPOSITION
SOLUTIONS
(954 ) 331-4400
146
1 A. If that's all you have, obviously not.

2 MR.SIMPSON:Okay.
3 MR.SCAROLA: Thank you.
4 MR.SIMPSON:Wewill break then and we will
5 talk off the record about logistics for tomorrow.
6 MR. SCAROLA: Okay.
7 THEVIDEOGRAPHER: Weare going off the video
8 record, 4:31 p.m.
9 (Witness excused.)
10 (Deposition was adjourned.)
11
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13
14
15
16
17
18
19
20
21
22
23
24
25
ESQUIREDEPOSITION
SOLUTIONS
(954 ) 331-4400
Case
Document1090-16
185-15 Filed
Filed 07/30/20
06/01/16 Page
Page 11 of
of 24
1
EXHIBIT 15
'JMFE6OEFS4FBM
PRIVILEGED PURSUANT TO FS 766.205(4) and/or WORK PRODUCT
TELECON
PARTICIPANTS: JACK SCAROLA

BRAD EDWARDS
VIRGINIA ROBERTS
RE: Edwards adv. Epstein

291874
DATE: April 07, 2011
JS: Virginia, Jack Scarola and Brad Edwards
BE: Hi Virginia.
V: Hi Jack! Hi Brad! How you guys doing?
JS: We're doing fine, thank you. I'm sorry for all of the trouble and before we go any
further, let me tell you, if I have your permission, I have started a tape recorder and I
want to be able to tape this conversation from the very beginning. Is that alright with
you?
V: Sure, that's fine, Jack. No problem
JS: Ok, good, thank you. I appreciate that. Let me start off by introducing myself . I know
that Brad has spoken to you about me but I am Brad's lawyer, and I assume that you can
confirm that you and I have never had any communication before. Is that right?
V: That's correct.
JS: Alright. I have, however, gotten some information from Brad about conversations that
you have had with him, and that will enable me, hopefully, to make this a little bit more
efficient and take up a minimum amouat of yorn-time url:Jilestill gettiRg tl:JeiRfurmatioA
that we think is going to be helpful to us and to any jury that might ultimately have to
hear these facts.
V: -~!
So, let me begin by asking you first to tell us what your full name is.
Louise Roberts. That's my maiden name . My married name is Virginia Louise
NON PARTY (VR) 000178
GIUFF RE00 2 l 77
Edwards adv. Epstein

Telephone interview with Virginia Roberts
Page 2of23
JS: Could you spell your last name for us? That is your married last name:
JS: Alright, thank you, and where are you living right now?
V: I live in Australia.
JS: And how long have you resided in Australia.
V: This is my 19th year.
JS: That is where you are right now, correct? We've reached you in Australia for this phone
conversation?
V: That is correct, yes.
JS: And what time is it in Australia right now?
V: I think it's about 9:00 now.
JS: Ok. That's 9am, correct?
V: That's correct.
JS: Alright. Virginia, the reason for this conversation is because it is our understanding that
you know a man by the name Jeffrey Epstein, and I want to begin by asking you please to
tell us about the circumstances of your first meeting Mr. Epstein.
V: Ok. I was introduced to Mr. Epstein by Ghislaine Maxwell. I was working at Donald
Trump's spa in Mar-a-Lago and I was prompted by Ghislaine to come to Jeffrey's
mansion in Palm Beach that afternoon after work to make some extra money and to learn
about massage. She met me at the spa, and I was reading a book about anatomy, so I was
already interested in massage therapy as it was and not having any of the education or
you know anything behind me, I thought this was a great opportunity to work for her and
go. So, I went to Jeffrey's mansion about 5 or 6 in the afternoon. My dad drove me
there. My dad worked at Mar-a-Lago with me, and he met Gfoslame and she seemed hke
a nice, proper English lady, and she knows, I mean, you know, one time then _once
before I left to travel overseas, she just seemed really nice and like she would like to help
me out. So my dad left, and I had no problem getting home that night, one of her drivers
would take me back after my trial. So she led me upstairs, and into Jeffrey's bedroom ,
and past that is Jeffrey's massage room, which has got his steam room and a shower and
a massage table, and there is actually an extra room that has, that nobody knows about it,
it's kinda like a secret room and it's got a whole bunch of decorative pictures of
pornographic literature and sex toys and I can _ ?_ what happened in there.
GIUFFR E002 l 78

Page 3 of23
JS: When you say that the room was hidden, Virginia, how was the room concealed?
V: It wasn't like a door that you would normally go into, like some kind of special opening,
you open that and then a little door, so it looks like it's a little closet so-to-speak, but
when you walk in there, it's obviously a lot bigger than just a closet. It wasn't too big,
but it was bigger, you know. It wasn't a gigantic room, it was just like a small room,
which you know, it probably could fit some shoes in there, _it had racks of shoes, boxes,
some sweatshirts neatly folded, and the ceiling to the floor was covered in pornographic
pictures of the girls that he had met.
JS: When you say ...
V: So anyways, that was getting there, and I was introduced to Jeffrey, he was laying naked
on top of the massage table, and obviously for one, I'm a 15 year old girl and seeing him
on the table was weird but, also learning about anatomy and massage, I thought th.is
would be part of it. So obviously, I thought it was part of the massage program, so I said
ok, th.is is fine. And, he then instructed me on how to touch the body, Jeffrey ' s body,
how to massage him, and for the first hour, it was actually a real massage, maybe not an
hour, maybe like 40 minutes or something, but of something like that _and that's when he
turned over on the other side and to expose himself fully. So then Ghislaine told me that
she wanted me to undress and began to take off my shirt and skirt, my white uniform
from Mar-A-Lago, she also took off her shirt and got undressed, and so I was there with
just my undies on, and she was completely bare, and made some kind of little flake about
the underwear that I was wearing because it wasn't my normal sexy girl underwear and
just like, I don't know, had red hearts on it or something like that; just your normal, you
know, real cute underwear. Anyways, so during all of th.is I'm kind of like what's going
on, how do I act, what do I say, I was so afraid of, not afraid or fearful for my life but
_unsure of how all this started and wanting to obtain a profession_ I was so afraid
th.inking about upsetting and disappointing them, I don't know, it's a weird situation by
far and I was expected to _Lick his nipples, instructed on how to do so by J.E_ and give
him oral sex while he wanted to fondle me, and then at the end, I was told by Ghislaine to
get on top and straddle Jeffrey sexually, and when we were done, we went and had a
shower in the room and Jeffrey told me to wash him up and down, you know with a bar
of soap and make sure he was all cleaned up. And then he took me downstairs and took
me to two of the guards and told John to bring me home. John was the butler at the time.
JS: Let me interrupt you for just a moment there if I could, Virginia. You mentioned as you
were recounting those details that you were 15 years old at the time. What is your date of
birth?
V: August 91\ 1983
JS: And can you tell us please, as best you're able to estimate it, what the date was when this
first encounter occurred?
GIUFFRE002 l 79

Page 4 of23
V: I've got it written down. It's like - I'm not good with math- hold on - I thought I VvTOte
it dov.n but I didn't. I'm not too sure, I think it was 1998 off the top of my head and
around June of 1998, I would say as I was turning 16 at the end of the summer.
JS: Alright. You talked about the room where Jeffrey had the pornographic photographs.
Did you actually see that room on the occasion of your first visit there?
V: No, I got to see that room a few visits after but I was just trying to describe that room to
you guys so you knew exactly what room I was talking about.
JS: Another question for you, and I don't mean to be prying into your personal life, and if I
ask you any questions at all that you're uncomfortable answering, then you just tell me
that and we'll move on, because I appreciate your cooperation and the last I thing I want
to do is impose upon that cooperation, but can you tell us please just generally what kind
of sexual experience you had had prior to this confrontation with Jeffrey?
V: Yeah, sure. A close family friend has sexually abused me, and I was on the streets at 13
years old. I was picked up by a 67 year old man named Ron _Eppinger_ who did exactly
what Jeffrey did with me abuse and violate my youthfulness _ & I was with him for 6
months. So, he was gone and then I had this boyfriend who was like my school friend
from young days but we just kept in contact with each other and we were on and off
constantly, and that was Tony Figeroua_, and there was also another younger guy was
near my age, Michael, I can't remember his last name, but yeah, there, I mean , there
wasn't like a string of men or anything, but there was Ron, like I told you, and he was the
first guy expecting me to do so-called disgusting affairs. Jeffrey actually knew Ron,
which was quite weird when I told Jeffrey the story about Ron, and Jeffrey had actually
met him, and yeah. Anyway, just another story, and yeah, there were a couple of men,
but that gives you an idea.
JS: Now when you described the photographs in the room as pornographic, tell me just a
little bit about the photographs , if you would please? First, how many of them were
there?
V: At least l 00, and like I said, they covered the room from the ceiling, not the ceiling but
from the top of the edge of the wall to the bottom of the floor. I want to say at least a
hundred, even more, there could have been more m the boxes _ Some of them were A4_
photographs, like the large size, some of naked women posing, you know, positions, sexy
pos1t10ns. Others were, you know, some girls had bikinis on, and it wasn't so
pornographic, but it was all women, and it was all in a sexual nature.
JS: Were there photographs where more than one person appeared?
V: Oh yeah, plenty of them. There were lots of naked photographs, I mean I was just trying
to give you a visual range. There was anything from 5x6s to 4x8s to 8x4s. Some of them
GIUFFRE002 l 80

Page 5 of23
had frames, some of them were out of frames, but they were all, like I said, they were all
women, they were all sexual in nature.
JS: Was it your impression that there were a hundred photos of a hundred different people or
were there multiple photos of the same woman or girl?
V: There was definitely a lot of different girls. I mean it wasn't easy to sit there and say,
you weren't finding 5 girls out of some photos, no. Were there a hundred different ones?
There could have been pictures of some girls, I really couldn't get close necessarily to
actually recognize faces or anything like that. But if you, you know, the range of them
were all different, majority of them were different, yeah.
JS: Did there ever come a point in time when you became aware that a photograph of you
had been added to the collection?
V: Yes, there was. Ghislaine took several nude photographs of me for Jeffrey. So, yeah,
there were pictures of me and there were pictures, he wasn't shy, that wasn't the only
place in his house that he kept the photos. He liked photos all over his house. If you
looked in his den or on his desk or in on the hall table, a giant hall table in his house ,
there were at least a hundred photos of girls in frames. Not all of them were naked, a lot
of the ones that were all around his house were not naked girls posing pornographically,
some were pictures of celebrities and politicians he had known_or things like that or had
pants on or whatever, but yeah, there was a lot of mixed photographs in the outside ones.
JS: Were there any photographs of girls or young women that you knew or that you
subsequently came to know that you saw in the house?
V: Yeah, yeah, there was. There was pictures of Nadia Bjournik____ ~ pictures
Sarah Keller, pictures Emmy, pictures of me, pictures of the regulars, but a lot of the
girls, sometimes Jeffrey could have like 7 girls a day, and he would only see those girls
once if he got bored. I don't know. These weren't my days. I heard he's gotten a lot
sloppier since I left. So, I don't know anyways, but when I knew him, there was just a, it
seemed, there was such an influx of girls corning in and out, so did I recognize a lot of
them? Maybe, maybe not, but then they were all definitely beautiful, they were all
ranging in age, some of them young, some of them older in their 20' s, I mean it was just
they were all beautiful.
JS: You've told us about the first visit. Was there any discussion on the occasion of that first
visit about your returning?
V: Yes, they were very pleased with me and after the encounter was finished, the sexual
encounter, he went and told me I did well and I have a lot of potential to become a
massage therapist and if I'd like I could return tomorrow, you know, and do the same
thing and get paid $200/hr, so Jeffrey insisted that I come after work, and over the next
few days, I guess the relationship grew into more, and within a couple of weeks, not even
GIUFFRE002 l 8 l

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a couple of weeks, maybe a week, I had quit Mar-a-Lago and I was working for Jeffrey
full time.
JS: Ok, let's talk about your job at Mar-a-Lago, if we could. You said that your Dad was
working there. What was his position at Mar-a-Lago?
V: He was a maintenance supervisor I think is what it was called? He like managed the
tennis courts and air conditioners and things like that.
JS: What is your Dad's full name?
V: Sky William Roberts.
JS: And is he still living here in South Florida now?
V: No, he's not, he's in California.
JS: Ok. Is your Dad aware of what is currently going on with regard to your having made
public statements about your relationship with Jeffrey?
V: Yes, he is well aware of it. I told my family even before all this stuff came out, because
they were the first ones contacted by the journalists from Mail on Sunday. I know that
they the Mail on Sunday printed that I had gone out and tried to, I mean I think one of the
photos said that I was angry that I saw Jeffrey and the Prince walking together and that is
why I came out and went public with everything. Not true. I mean, I am angry about
how they are still up to their old ways together and that they're still hanging out but I
didn't contact the Mail on Sunday and I didn't bring it out. I figured that everyone was
going to bring it out anyway and I better bring it out the right way. He's known
everything from the start, and my family is very supportive with everything going on.
JS: I'm kind of going to jump around a little bit and I apologize for that, but since the subject
has come up, tell me first of all why you are providing this cooperation to us, and I am
certainly very appreciative of it, but I want you to tell us why it is you've chosen to spend
time with us on the telephone and provide this information that you're now providing.
V: I' m out to help the bigger picture, you know, I think all ofus can make a big difference in
a lot of other people's hves and I thmk that this has gone on long enough and it's a big
slap in my face that he can get away with hurting me so bad let alone so many other girls
and laugh about it. I guess I talked to you guys out because I want to see the right thing
happen, not just to him, but I want people in the world to understand this is not the way
of life, you know, it's not acceptable to go out procure young girls and make them think
that, this is the way you should be living and that' s all. Yeah, I guess my reason for
doing it is to help the bigger picture, you know, I'm a big believer in karma and I believe
that good things will come back to you, so I guess that's why I'm doing this.
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JS: Just for the record, neither Brad, nor I, nor anyone representing that they have anything to
do with us has made any promises to you. Is that correct?
V: That is correct. I'll tell you, since this is our first conversation, that nobody has made me
feel like I've been bribed or bought or had to say anything. I've told you anything that I
know from my own self, not some things somebody told me. If anything, Brad's been
extra careful not to tell me anything and Jet me do all the talking, so it's quite opposite I
think.
JS: Alright. Let's get back then to the story of your relationship with Jeffrey, and we've
talked about your first encounter with him and how it evolved from that into your full
time employment with Jeffrey, but what were you doing at Mar-a-Lago before you quit
Mar-a-Lago?
V: I was just a locker room attendant and sometimes I did babysitting for the rich and
famous. So, I wasn't anything big. I worked in the spa area. That's why r was studying
anatomy, because I was really really interested in becoming a_ massage therapist_, and at
the locker room, I didn't do much. I mean I was making tea for a living, I would, you
know, make sure the toilet paper had a little triangle in it after everybody went to the
toilet, or wipe down the water from the basin, you know, it was a very easy peasy job.
JS: Did you get that job through your Dad?
V: Yes, my Dad got me the job.
JS: Ok, and you were only 15 years old at the time, were they aware of how old you were at
Mar-a-Lago?
V: Of course, definitely. We had to go through extensive, you know, we even had to get
drug tested and id test and so on and so forth. I mean, Mantas (?) is very strict on
employment, yeah, everybody knew.
JS: Ok. Was there ever any conversation with Ghislaine about how old you were before you
were taken to Jeffrey's mansion?
V: No. She didn 't ask me how old I was from the start, but when I did get to Jeffrey's
mansion, 1t was discussed how old I was.
JS: With whom?
V: During the entire hour of what I call the legitimate massage I was giving him, it was cat
and mouse games getting information from me to find out who I am, am I a willing
participant in these kind of things, and how would I react if they were about to take the
next step. But they got information off of me, they got my age, they got my, a little bit of
my history so they knew I was, you know, not very stable at home, and they knew that,
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you know, I was actually interested in making my life better by studying so what they
were offering me was a chance to become a legitimate masseuse but it was getting
trained. They would have people show me how to work the body and be called a
massage therapist and get me books on it, and you know, keep me interested, and every
time, you know, I was with Jeffrey, literally was about massages, I don't mean just going
in and have sex with him. I mean massage, because it would always start out with
massage and then it would lead into sometimes other things.
JS: Alright, once this evolved. into full time employment, what did full time employment
mean?
V: That was entirely having to travel with Jeffrey in every city. When he was in Palm
Beach, I stayed at my apartment, and he would call me to his house once or twice a day
sometimes, and that's, you know, do things with him. Sometimes we'd go out shopping,
sometimes we'd go out and watch a movie. You know, simple things like that, go to an
expo or a fair, whatever it was. But when we were in other cities, I was at my
apartment_, I lived with him full time. What I mean by full time is even in the middle of
the night, I could get a ring on my phone next to me and tell me to come in his room, you
know, so it was literally full time.
JS: When you say that when you were in Palm Beach you were living in your apartment,
were you living on your own or were you living with members of your family at that
time?
V: No, after I quit Mar-a-Lago, Jeffrey offered to get me an apartment in Palm Beach
somewhere, Royal Palm Beach, and it was a nice apartment. He furnished it for me, it
was absolutely beautiful, but yeah, that's the only time I would spend time away from
him really.
JS: This apartment was on Royal Palm Beach Boulevard or out in the Village of Royal Palm
Beach?
V: I so honestly don't remember. I've been trying to rack my brain because the FBI was
asking the same thing and were trying to find it, but yeah, I'm Not sur_. I didn 't get to
spend as much time in it, I was only there about an entire week out of every month
probably, but the majority of the time I was with Jeffrey anyways. It was somewhere in
Royal Palm Beach. I don't know about Royal Palm Beach dnve. I don't even remember
the Royal Palm Beach drive anymore so I'm not too sure.
JS: Ok, let me see if I can draw the distinction for you and maybe that will help you to help
us? Royal Palm Beach is a village that is ...
V: No, no, no, I got Royal Palm Beach, I just didn't know the Royal Palm Beach Drive, like
what street it's off of. Were you talking about a street?
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JS: Yes, I was talking about a street. Royal Palm Drive is on the island of Palm Beach, and
it's a street that is lined with large royal palm trees, and I'm wondering if this was an
apartment on the island or was this an apartment out west of town ...
V: No, it was actually in Royal Palm Beach, not on the island.
JS: Alright.
V: I would be driven, it was closer to my family than it was closer to him. I wanted to be
close enough to everybody else so that when I was in town, I could just go see them
quickly.
JS: Ok. So we're not talking about Royal Palm Boulevard. We're talking about the town of
Royal Palm west of town. Jeffrey got you an apartment out there.
V: That's correct.
JS: When he was in Palm Beach, you were generally not staying at the mansion, you were
staying at the apartment that he got for you out west of town.
V: That's correct.
JS: Ok.
V: I mean then there was times , I don't wanna say that every time I stayed at my apartment.
There was times we'd fly back from some city maybe too late at night to really want to
go back home, so you know, it's like 12:00 at night or 1:00 in the morning. I was just
staying in the yellow room, or something like that; one of the guest rooms in Palm Beach.
But majority of the time, I would definitely want to get back to my own apartment.
JS: Alright. What were the general hours of your full time employment when ... ?
V: There was not set hours. It wasn't like logging, and you know , hitting the shift button,
nothing like that. The way I would get paid would be, ok, if I was in Palm Beach, I
would get $200 an hour to massage Jeffrey or some of his friends and then go home. So
it would be like that. If I was traveling with him, it would be per massage, so I would be
getting paid per day. So I wouldn ' t be getting paid on an hourly rate. He wouldn ·t say
ok, today you're going to work for me from 7:00 in the morning until 8:00 at night. It
never like that. I was on call all the time.
JS: When you were here in Palm Beach, were you actually getting paid only for the time
spent massaging Jeffrey or were you getting paid from your arrival at his house until you
left the house?
V: From the time the massage started.
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JS: From the time the massage started. Ok.
V: Sometimes we'd go there and I would wait for a while or talk with Ghislaine and Jeffrey
about something or we'd meet somewhere and talk about something. A lot of times, I'd
meet him upstairs in his room where he was ready for me. But then there was a lot of
times where it didn't start right away, so he couldn't really pay me from the time I got
there sometimes unless it was just paid from the time I massaged him til the time the
massage was over.
JS: Alright. Did your duties for Jeffrey ever include anything other than providing him
massages and sex in connection with the massages? Did he ever give you any other
responsibilities to perform?
V: I was asked to do the same things that I did to Jeffrey to a few of his fellow colleagues as
well. Those were my duties. He looked at it this way is that I was going to be a
professional massage therapist, and maybe I needed some clientele, so he had me perform
erotic massages on a few people.
JS: Did that start here in Palm Beach County?
V: It did. The first one did.
JS: Ok, and how long after you first met Jeffrey did he first ask you to provide services for
one of his friends?
V: About 9 months, I think it was. It wasn't a full year, it wasn't 6 months, but between 6
months and a year, which is why I'm saying 9 months.
JS: And when you provided services to a friend of Jeffrey's, who paid you for those services?
V: Jeffrey would. I would get paid the next time I saw Jeffrey, so if I was invited to the
Breakers Hotel to give a massage, I would give a massage, I would go home, and the next
day when I saw Jeffrey, he would pay me for what I did. So, it was paid always by him,
it was set up by him, so he always knew what to pay me. I did get tips and things like
that, if you call it that, you know, like a hundred dollar tip or something from a few of
them, you know, yeah.
JS: Was there ..
V: There was always payment from Jeffrey.
JS: Was there ever any discussion with Jeffrey about what was expected to happen when you
provided massage services to one of Jeffrey' s fiiends?
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V: In a roundabout way, yes. In so many ways, Jeffrey really really had to train me, and that
was why Ghislaine said that she and Jeffrey enjoyed me so much was because they never
really had to speak much to me to tell me what they wanted me to do. You know, I
wasn't waiting for you know, their directions. Jeffrey would tell me to go give an erotic
massage to friends. He wouldn't give me much detail about it, but he would say to treat
them like you treat me.
JS: Did he refer to it as an erotic massage or are those your words?
V: Erotic massage is my words. That's exactly what it was, but he would tell me to treat
them how he wanted it, so I'd do what he wanted without having to say to me words
more. I mean, I complied with what he wanted because it was somewhat of a, I don't
know, I don't know how to say it, it was just very mindboggling how I let him have so
much control or power over me basically. The massages would be routine to what Jeffrey
wanted with my so called new clientele, and with their own words would ask me to
provide them with sexual pleasure after the massage.
JS: Did you ever report back to Jeffrey about what happened when you provided massages to
his friends?
V: Of course, of course, and I knew that his friends were reporting back to him as well
because there were times where he would instigate conversation by saying you know, so
and so had a great time, you did wonderful, you know so and so gave me a call and told
J.E how it went_ ...
JS: Did Jeffrey ever elicit details from you? "Tell me what happened, describe in detail what
went on?"
V: No, but he would have a laugh, he had a laugh with me a few times about some of their
different mannerisms, I guess you would say, like some of them, one guy had a foot
fetish and that was really weird and I mentioned it to Jeffrey, and we would have a laugh
over it. He didn't want to know details. He wasn't asking me "so tell me what did you
guys do exactly." No, he just basically gave me a slap on the back and said, you know ,
good job. And we had some kind of conversation about it. I can't recall any conversation
off the top ofmy head. I really don't know one. It's been that long. But yeah, we did
talk about it briefly.
JS: Can you give me an estimate as to the nwnber of friends for whom Jeffrey provided and
paid for your services?
V: There was about, you know, I don't know, 8 guys possibly.
JS: And are you able to name those people for me?
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V: No, not at this stage. I just, some of these people are really influential in power, and I
don't want to start another shitstorm with a few of them. I'll tell you that there was some
erotic massages given to, I'm just afraid to say it to you.
JS: Ok, Virginia.
V: It's like geez, I don't know ifl want to, T'm really scared of where this is gonna go.
JS: Alright. I understand that, and as I told you from the beginning, if I ask you a question
that you are uncomfortable answering, you just tell me that, and I will move on, and I
understand that at least right now, you are uncomfortable answering, and I am certainly
going to respect that.
V: Thank you so much, Jack.
JS: No, that's quite alright. I am very appreciate of the cooperation you are providing, and I
don't want you at any time to feel that we are taking unfair advantage of that cooperation,
so give me the information that you 're comfortable giving me, and if we get to a point
where you're uncomfortable, I will respect that and we'll move on from there.
V: Ok.
JS: I want to talk a little bit about the traveling that you did with Jeffrey. About how long
into your relationship with him did that first start?
V: Immediately. I started traveling immediately. Not internationally until I think about,

Gosh, I can't remember even, I think it was a year later that we started doing international
travel. Maybe like 9 months to a year again. Not too sure to be honest.
JS: So that would have been approximately the summer of 1999? Somewhere around there?
V: Yes. Somewhere around there. Somewhere around a year, somewhere around there, I
can't pinpoint it exactly. But like I said, we started doing domestic traveling
immediately, so my first destination with him was New York and Santa Fe and the
Carribean, California, I would take trips with him occasionally. Sometimes we would go
to St. Louis or New Orleans or Santa Cruz. We were traveling just about everywhere I
th1 .
JS: How did you travel?
V: Well, we took Jeffrey ' s private jet , and unless I was being sent somewhere by myself for
what we were just talking about before, then I would travel on a what do you call, a
public jet, whatever it is . . .
JS: commercial flight?
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V: Yes. Just a normal flight, an e-ticket.
JS: Like the rest ofus common folk.
V: But when I was traveling with Jeffrey, the majority of the time would be on the black jet.
JS: Now, when you say there would be times when you would travel by yourself because he
was sending you somewhere, tell me about that. How did that come about?
V: So, one of his colleagues would be at the Carribean or Santa Fe or even New York, or
wherever, and he would call me up on those days where I am not working with him or in
Palm Beach with him, and he would ask me to get on the next plane to so and so and go
meet so and so, and that's when I would take e-tickets. His secretary or special assistant,
whatever, would organize it for me and give me the details and I would just walk up the
line and they'd let me right through .
JS: Can you give me any ideas as to how many times it happened that Jeffrey would send
you off to meet some friend of his at some location outside of Palm Beach?
V: How many times it happened ? I'm not too sure. Probably about 10-15 times .
JS: Ok. And on those occasions, how much time would you spend with one of Jeffrey's
friends when you were sent to a location that you would have to travel to?
V: Only a couple of days . Only 2 days, that's it.
JS: And how were you paid for those trips?
V: I would be paid in cash upon my arrival back with Jeffrey. So, whenever I was back with
Jeffrey, he would count up how many days I've had, sometimes give me even more than
what I deserved, not deserved, but what I earned and give me a little extra.
JS: Was there a daily rate for those trips or was that per massage also?
V: Per massage. With Jeffrey, f would be honest. I wouldn't tell him I did 15 massages if I
didn't. He knew he could trust me. He could always come back to the other person that
he sent me to give massages and ask them as well, so you know, it was always by per
massage.
JS: Alright. When we've been talking about massages, tell me exactly what it is we 're
talking about when we speak about massages .
V: Same thing I would do to Jeffrey. Again, it would start out as a massage, which would
start with them being naked, and me giving him a legitimate massage to begin with, so
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I'd start with his feet, go up to his calves, up his legs, buttocks, back, his neck, his head,
his arms, yada yada, and then it would be time to flip over, and some of the men would
want me to continue on massaging the front side of them and they would instigate me to
begin having sex with them or foreplay, whatever you want to call it.
JS: So routinely, these massages involved sexual activity. Is that accurate?
V: That is accurate.
JS: Ok. Let's talk about the travel that you were involved in when you were on Jeffrey's
private plane. Generally speaking, who were the passengers on the plane when you
traveled.
V: Well, Larry was the pilot, and then there was a short, small solid guy, I don't know his
name, but he was a co-pilot, and then he changed and there was another guy brought in
later on. Generally speaking, there was always Jeffrey, sometimes Ghislaine , sometimes
Emmy, sometimes a whole bunch of other girls, sometimes famous people, sometimes
some politicians or yeah, just about anybody could fly on his plane. There was never no
any set routine who would come and who would go. It was an influx of people on
Jeffrey's airplane.
JS: I want to deal with these things separately in order to respect some of the reservations
that you have, so I'm going to ask you who the people were that you remember flying
with Jeffrey on his plane when you were personally present without regard to whether
there was any sexual activity that occurred on the plane or not. So I'm not asking you to
implicate any of these famous people in improper conduct, but just tell me what the
names of the people are that you remember that you consider to be famous people.
V: Ok, there was Naomi Campbell, Heidi Klum, there was Bill Clinton. There was Al (?)
Gore, there was a whole bunch of models, I wouldn't really honestly be able to give their
names. There was Matt Groning the producer of the simpons cartoon, Jack CCousteau' s
granddaughter a lot of interior designers , architects, politicians. I am just trying to think
of as many names as possible for you. Off the top of my head, that's as good as I can get
for now.
JS: Ok, alright, that's fine. And again, I am not implying by my questions , nor do I want
your answers to be mterpreted as your suggestmg iliat any of I.nosepeople that you have
just identified were engaged in any improper activities on any particular flight, but I want
to talk to you now about what went on on occasion on the airplane. Ok?
V: Ok. It was a lot of the same thing that went down on the ground. A lot of times, it would
be just be me and Jeffrey, or me and Jeffrey and Ghislaine, or me and Jeffrey and some
other girl, sometimes Emmy, Sarah, and Nadia Bjournik. There would be sexual conduct ,
there would be foreplay, there was a bed in there, so we could basically reenact exactly
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Telephone interview with Virgin .ia Roberts
Page 15 of23
what was happening in the house. It would start off with massaging or we would start off
with foreplay, sometimes it would lead to, you know, orgies.
JS: Were there occasions when you were in Jeffrey's company, whether on the ground or in
the air, where there were other girls present whom you knew to be under age 18?
V: Yes. There was a constant influx of girls coming in and going out. And we were all very
young. On occasion, there was some older girls, and I don't mean older as in like in their
30s or anything, I mean like 28, 29, something like that, just very rarely. The majority of
the girls that Jeffrey actually met or had on his plane or in his house were under age.
JS: Do you know how it is that Jeffrey established with any of these underage girls?
V: Yes, I do. He would send me personally or with other girls to clubs or shops, to _pick up
anywhere, I mean we were constantly on the look for other girls that might satisfy
Jeffrey.
JS: What instructions were you given about what to look for?
V: Young, pretty, you know, a fun personality . They couldn't be black. If they were any
other descent other than white, they had to be exotically beautiful. That was just about it.
JS: Who gave you those criteria?
V: They both gave us the instructions, and it wasn't just me, Jeffrey asked most girls to bring
a friend and make extra money. They would use us young girls So that way it probably
looked a lot more safer to a girl that we were procuring to younger girls that were already
doing it. That was the way that Jeffrey had it.
JS: Were you given any instruction at all on how to approach these girls?
V: Yes. Jeffrey and Ghislaine both taught me to, depending on the circumstances,
depending on the girl, you could offer them a job as a massage therapist or you could tell
them you have a really rich friend with, you know, great contacts in the acting world or
modeling world and he loves pretty girls, you should come back and meet him, make
some money, you know, we had a whole bunch of ways to be able to procure girls.
JS: Can you give me any idea as to the total number of underage girls that you know engaged
in sexual conduct with Jeffrey during the period of time you had your relationship with
him?
V: I would have no way of estimating that whatsoever. I mean, there could be a hundred,
there could be more, honestly I'm not too sure how many girls, really. I wish I did know.
I mean like I said there were so many over the course of 4 years with Jeffrey.
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JS: Let me see if we can try to narrow it down a little bit. Is there any doubt in your mind
that it was more than 10?
V: Yes, there was definitely more than 10.
JS: Ok, what I want you to do is to give me the highest number that you are comfortable in
saying there were definitely more than X number of underage girls that I know Jeffrey
Epstein engaged in sex with while I had a relationship with him. How would you fill in
that blank? Definitely more than how many?
V: I'd say definitely more than a hundred.
JS: Alright. Did Jeffrey ever help to pick out your clothes?
V: Oh yes. I mean he wasn't out to dress me like a porn star or anything. He would always
dress me very classy, but we'd just go shopping all the time together.
JS: Did he ever express any style preferences in terms of how he wanted you to dress?
Besides dressing classy, I'm, you know, any other suggestion to you about how he
wanted you dressed?
V: He didn't, like I said, wasn't trying to dress me in any prostitute way or anything like
that. It was nice, classy outfits I was wearing like Gucci, Dolce Gabbana., Chanel, things
like that. He was buying me a lot of very, very nice clothing. It was provocative. I mean
I was wearing miniskirts, and tight short shorts and little shirts that showed my belly and
my cleavage and everything, but they were very expensive clothes.
JS: Was there every any dress up role playing?
V: Yes. There was. Lots of it. Jeffrey loved the latex outfits Ghislane had for us girls, he
had bondage outfits, he had all different kinds of outfits, but his favorite was the
schoolgirl.
JS: Tell me about that.
V: Well, you know, Ghislaine would take me to dress me up to surprise J.E or Jeffrey would
ask me to get dressed up, that would mc!ude wearing a tiny little skitt with nothing
underneath, a white collared shirt that you would be wearing to school with a tie in it, tied
up _in a bow_, my hair in pigtails, stockings on up to my knees, and I would go in there
and act like a kid and we'd do role playing sexing.
JS: Did Jeffrey ever brag to you about the age of any of the girls with whom he had
relationships?
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V: Yes, he did. He did all the time. The worst one that I heard from his ov-mmouth was this
pretty 12 year old girls he had flown in for his birthday. It was a surprise birthday gift
from one of his friends and they were from France. I did see them, I did meet them.
Jeffrey bragged afterwards after he met them that they were 12 year olds and flown over
from France because they're really poor over there, and their parents needed the money
or whatever the case is and they were absolutely free to stay and flew out. Those were
the worst ones. He was constantly bragging about girls' ages or where he got them from
or their past and how terrible their past was and good he is making it for them.
JS: Where were the 12 year old girls flown to from France? Where did they come to?
V: Palm Beach.
JS: And were they flown in on Jeffs private plane or did they get transported?
V: No. They were transported by somebody else.
JS: Ok. Was the sexual activity that went on on the airplane conducted in such a way so that
any of the crew was aware of what was going on?
V: They were told to knock if they had to come out, if the crew had to come out. They were
told, you know, to come out as little as possible, so they weren't out there hanging out
watching everything, no, but it doesn't take an idiot to put two and two together to say
well there's a whole bunch of half dressed teenagers on board with this old man who is
constantly being massaged by them and he wants me to keep the door shut for what
reason? I mean, only they could put that together, but yeah, they knew.
JS: Did Mr. Epstein ever talk to you about people of power and influence owing him favors?
V: He would laugh about it, you know, I never really knew what to take serious from Jeffrey
because he was such a funny character at times. You never knew if what he was saying
was true or not. Yeah, lots of people owed him favors from what he told me. He's got
everybody in his pocket, and he would laugh about he helps people for the sole purpose
in the end they owe him something. That's why I believe he does so many favors in the
first place.
JS: When and how did you brst become aware that Mr. Epstem was m trouble with the law?
V: I was first informed by, I think someone from the FBI called me first and started to ask
me questions, and I started to answer the questions but then fear took over, and I just said
look, I don't know what's going on, I've got a young family that I don't want to risk , you
know, please don't bother me about this again, and it was real short simple conversation ,
and within a week or 2, l had gotten a call from Jeffrey's attorney, and then a week later,
Jeffrey himself.
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JS: Ok, well let's back up before we get to those conversations and tell me approximately
when it was that you were contacted by the person who you believe was with the FBI.
V: Ok. It's hard for me to pinpoint, ifl had to pinpoint it, it would be in 2007 sometime.
JS: Alright. And you were living in Australia at that time, correct?
V: Correct.
JS: You were contacted by telephone?
V: That's correct, by my cell phone.
JS: Ok and do you have any idea how your name came up leading to that contact.
V: No idea. No idea whatsoever. When I did ask, I was told that some girls had revealed
my name, I guess, and that's how everybody, the FBI knew to contact me.
JS: OK.
V: But I don't know offhand or sorry, I just walked into the wrong room.
JS: Ok.
V: Sorry go on.
JS: Yes & I'll never tell her you said that. Virginia, how long was it after that phone call
from the FBI person were you contacted by Mr. Epstein's lawyers.
V: Like a week. It was back to back to each other. I remember being so scared after talking
to the FBI thinking what's happening, what's going on. It's been like 6 years, 7 years at
that stage, how did they find me & what do I have to do with this? So yeal1, I do
remember that very well, and it was only about a week later I was called by his attorney.
JS: Who was it that contacted you, do you remember?
V: I want to say Bill Riley, but he nnght have been from the FBI. No, it was B111Riley. B111
Riley. Not sure if that's his correct name, but that's what is coming to mind
JS: What do you remember about that conversation?
V: I remember a Mr. Goldberger as well, I remember, there might have been two of them.
JS: Alright.
GIUFFRE002 l 94

Page 19 of23
V: I can't remember which one it was. I want to say Bill Riley is the good one.
JS: Alright, so either Bill Riley or a Mr. Goldberger or both of them contacted you, and what
do you remember about that?
V: I don't know if it was the same guy who contacted me that week later who put me in
touch with Jeffrey. I think he was on the phone and he put speakerphone on with Jeffrey.
So he connected me with Jeffrey. I don't know if it was the same guy or different, but I
definitely know that Bill Riley was the first guy to contact me. I'm pretty sure about that.
JS: Ok. Tell me about that conversation .
V: He asked me what I knew about what's going on with Jeffrey and apparently, there was
an investigation being held about some of the girls who had come out and said that
Jeffrey had sexual contact with them under the age of a minor and that he was
discrediting lot of these girls and making them out to be drug addicts and prostitutes and
what have you so they wouldn't be looked upon as worthy in the court's eyes so to speak.
And you know, he told me in the first five minutes that, you know, if I stay quiet, that
"I'll be looked after". And that was the exact way it was said. It wasn't like you know,
I'm gonna pay you a zillion dollars or anything if you be quiet, but if I stay quiet, I would
"looked after". And I remember saying I don't want any part to do with this. You know,
this is not something I want to be a part of, I've got a young family. I wish the best for
everybody in this, you know, take care kind of thing. A week later, I was called after the
hearing by one of Jeffrey's lawyers. I can't tell you exactly which one it was but he had
Jeffrey on the other line and he connected Jeffrey and I, and Jeffrey tried to make some
simple conversation, "How are you? How have things been?" You know what I mean,
catching up.
JS: Do you know if the lawyer, did the lawyer stay on the line while Jeffrey was speaking to
you?
V: I'm pretty sure he did. That's why 1 think Jeffrey was on speaker phone because it
sounded a lot different, and I was never taken off the line to begin with or connected to
another line, so I was pretty sure Jeffrey was on speaker phone and the lawyer was
making the call. After the simple conversation, it led to what was going on again and you
know, Jeffrey couldn't believe it. You know, he thought he helped all these girls out. He
didn't think he was wrong in any circumstance here at all. A lot of these grrls were drug
addicts and just after drug money. You know, he was really putting down these women
or these girls I should say, not giving them the credit they deserved, and then he exactly
repeated what the lawyer said the week before is that he would look after me if I stayed
quiet, and if I need any help, you know, his lawyers would represent me and he would get
legal help for me, whatever I need, he would do, and I told him exactly, I said, "Jeffrey ,
I'm the mother of two children at that stage. I'm away from everything there, I don't
want to be a part of it. I'm not going to speak to anybody and I don't want to speak to
anybody, I don't want to be involved." That was the last time I heard from him. And the
GIUFFRE002195

Page 20 of23
next thing I knew, I was sent my victim's letter, my notification of being a victim through
the US Attorney's Office and that's when I knew it was well out there enough not to have
Jeffrey's lawyers come back on me and discredit me in the same way he had done to all
the other girls. So, I called up Joseph Bird who was the recommended lawyers on my
paperwork that they had given me and started going from there.
JS: So you contact Mr. Joseph Bergs' office and then you were dealing with his office from
that point forward.
V: That's correct.
JS: Tell me about the ending of your relationship with Jeffrey. That is, at what point in time
did your full time employment end and how did that happen?
V: Ok. So, it hadn't really ended. I walked away from it all. Jeffrey sent me to Thailand
where I met my husband and escaped to Australia, never to return back to the states.
About 6 months prior to that, he came up with a proposition that I thought was really
disgustingly sick. And it really showed me for the first time in 4 years I had been with
him that nothing was going to change and I was always just going to be used by him(?)
which I did not like. He offered me a mansion and some of his money every month, I
forget what he called it, a monthly income of what he made to bear one of his children.
The proposition was that if anything ever happened between Jeffrey and I, that I would
have to sign my child over to him basically and that the child would be his and
Ghislaine's, and I would be looking after it as long as nothing happened between Jeffrey
and I. So, I was kind of freaked out by all of that. I pushed Jeffrey more to please get me
some more training, you know, and I was getting older and not of as much interest to
Jeffrey anyways. I was 19 now, and he likes a female a lot younger. So he sent me to
Thailand , in September 2002_. I was first supposed to meet a girl there and bring her
back with me, but I never met up with her. I proceeded get a short course in Thai massage
so that was to shut me up about my training so I went there, and one of my friends from
school invited me to watch a fight, like a muay thai fight, which is like a form
kickboxing. So I went and watched it, and I saw this guy that was a really good fighter,
and a girl's word, looked really hot, so I asked my friend who knew him to introduce me.
We got introduced and fell in love immediately, 3 days later Rob proposed and 7 days
later I was being married in a buddist temple . I called Jeffrey and told him I'm sorry, I'm
never coming back. I've gotten married, I've fallen in love. I thought he'd vvish the best
for me but he was kmd of rude and he Just said have a good life" and hung up the phuue,
and that was the last time I'd talked to him ever until all this started again.
JS: Ok. Virginia, is there anything else that you would like to add to what you have told us
up to this point in time?
V: I'd like to know that this time around something ' s going to be done about it and that
Jeffrey and a lot of his colleagues, no matter how rich they are, will know that there is
GIUFFRE002 l 96

Page 21 of23
law and that there is people that still believe in it. So that's it. Thank you guys for
listening to me, hearing me out and helping me. It's kind of hard to get through.
JS: Thank you very much. Yes, I'm sure it has been very difficult and I am very appreciative
of the courage you have sho"'n in doing what you have done, which really brings me to
the last subject, and that is what was it that motivated you to go public with all of this?
V: Sharon Richard contacted me. I like her, I do, I like her a lot. I know she's a journalist ,
and journalists are normally bloodsucking leeches, but I like her for that, but she is an
honest bloodsucking leech. She told me a lot about what was still going on, and she
showed me a picture of Jeffrey with a little girl who looks like she could have been 12
years old. I mean it was disgusting. I agreed to talk with her, I never agreed to do
anything until she showed me some pictures, and at that stage, being a mother of 3
children and having a daughter who I would do anything for to protect, I would put my
neck on the line to make sure she never has to go through what I had to go through, and
knowing all of this, and knowing that he 's still out there doing the same exact thing with
no regrets, no remorse, no worry about what he's doing to those girls, and all those girls
feeling the same way that I did, so I, you know, I'm doing it because I believe in my heart
of hearts it's the right thing to do. It' s what I would want somebody to do for my
daughter or my sister or my friend, and it saddens me to know that it's still going on right
now. It's like the seashell story. I don't know if you're heard the story about the little kid
who throws back a starfish, you know, the little brother tries to ask his sister, "why do
you throw them in, they're all gonna die anyways, the little girl says "well, it's this one
that I can help, and this one that I can help," and that's what I feel like I'm doing. I'm
making a small dent in this big world we live in.
JS: I certainly appreciate that courage, and I have heard that story, and you're absolutely
right, that one person may not be able to make a difference for everyone, but one person
can make a difference for someone, and hopefully, you are making a difference for
someone, and we're gonna do the best we can to make sure you are making a difference
for as many people as possible.
V: Thanks Jack.
JS: Just a few other follow up things I want to ask you and again, if any of these questions
are questions that you're uncomfortable in responding to, then don't hesitate to tell me
that. Do you have any recollecuon of Jeffrey Epstein s specificatly telling you timt "Bill
Clinton owes me favors"?
V: Yes. I do. It was a laugh though. He would laugh it off. You know, I remember asking
Jeffrey what's Bill Clinton doing here kind of thing, and he laughed it off and said well
he owes me a favor. He never told me what favors they were. I never knew. I didn 't
know if he was serious. It was just a joke.
JS: Where was here?
GIUFFRE002 l 97

Page 22 of23
V: He told me a long time ago that everyone owes him favors. They're all in each other ' s
pockets.
JS: \Vben you say you asked him why is Bill Clinton here, where was here?
V: On the island.
JS: When you were present with Jeffrey Epstein and Bill Clinton on the island, who else was
there?
V: Ghislaine, Emmy, and there was 2 young girls that I could identify. l never really knew
them well anyways. It was just 2 girls from New York.
JS: .A.ndwere all of you staying at Jeffrey's house on the island including Bill Clinton?
V: That's correct. He had about 4 or 5 different villas on his island separate from the main
house, and we all stayed in the villas.
JS: Were sexual orgies a regular occurrence on the island at Jeffrey's house?
V: Yes.
JS: If we were to take sworn testimony from the people I am going to name, and if those
people were to tell the truth about what they knew, do you believe that any of the
following people would have relevant information about Jeffrey's taking advantage of
underage girls? So I'll just name a name, and you tell me yes if they told the truth, I
think they'd have relevant information or no, I don't think they would, or I don' t know
whether they would or not. Ok? You understand?
V: Yes.
JS: Ok. Les Wexner.
V: I think he has relevant information, but I don't think he'll tell you the truth.
JS: Ok. Alan Dershow1tz.
V: Yes.
JS: David Copperfield.
V: Don't know.
JS: Tommy Matola.
GIUFFRE002 l 98

Page 23 of23
V: Don't know.
JS: Prince Andrew.
V: Yes, he would know a lot of the truth. Again, I don't know how much he would be able
to help you with, but seeing he's in a lot of trouble himself these days, I think he might,
so I think he may be valuable. I'm not too sure of him.
JS: Ok. Virginia, I think that's all I have for you. Let me tell you what I would like to do.
As I told you in the beginning of this conversation, we've been recording it, and
hopefully, we've got a clear enough recording so that we've taken do\\11 everything
accurately and when it's transcribed, it will be clear and accurate, but what I would like
to do is transcribe it, send it to you, have you take a look at it, and if there's anything that
we got wrong in the statement, you can write back and you can make changes in the
transcript so that the transcript is accurate. Is that fair?
V: No worries. That is fair. No problem .
JS: Alright, great. I really do appreciate that and tell me what the best way is to send the
transcript to you.
V: Email. If you just want to send it by email or if you want to send it by mail, either or.
JS: Ok. Give me your email address if you would please.
V: *
JS: Let me read that back to you: *
V: Yep that's it.
BE: Thank you Jenna, appreciate it.
V: No problem, Brad.
JS: I hank you very very much. Bye Bye now.
V: Take care Jack. Nice meeting you.
JS: You too .
*Redaction has been made at the request of the witness.
GIUFFRE002 l 99
Case
Document1090-17
185-16 Filed
Filed 07/30/20
06/01/16 Page
Page 11 of
of 12
1
EXHIBIT 16
'JMFE 6OEFS 4FBM
PRIVILEGED AND CONFIDENTIALAGREEMENT

A TIORNEY-CLIENT PRIVILEGE
JOINT DEFENSE PRIVILEGE
PRIVILEGED AND CONFIDENTIAL

JOINT DEFENSE AND COMMON INTEREST,PRJVILEGE,AND
CONFIDENTIALITYAGREEMENT
This Joint Defense and Commo n Interest, Priv ilege, and Confidentiality Agreement
("Agree ment ") by and among Virginia Rob erts, Bradley J. Edwards, and Paul G. Cassell (the
"Parties") and Boies, Schiller & Flexner LLP, Stan Pottinger of J. Stanley Pottin ger PLLC, Jack
Scaro la of Searcy, Denney, Scarola, Barnhart & Shipley, P.A., and General Counsel John Morris
and Associate General Counsel Ro bert Payne, and Robert Adler, Dean at S.J. Quinney College
of Law, U niversit y of Utah memorializes and confirms the prior oral and written understandings
among the Parties by and through their respective counsel.
This Agreement is made with respect to the following recitals:
Where as, Bradley l Edwards of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. and
Paul G. Cassell represent Virginia Roberts in an action pending in the Southern District of
Florida under the caption Jane Does v. U.S.A.(the "Florida Litigation") , and Stan Pottinger of J.
Stanley Pott inger PLLC, Brad J. Edwards of Fanner, Jaff e, Weissing, Edward s, Fistos &
Lehrm an, P.L., and Paul G. Cassell represent Virginia Roberts ·withrespect to future actions that
may relate to or arise from the same alleged issues presented in the Florida Litigation;
Whereas, Bradley J. Edwards of Farmer , Jaffe , Weissing, Edwards, Fistos & Lehrman, P.L. and
Paul G. Cassell are named Plaintiffs and Coun terclaim Defendants in an action pending in the
Seventeenth Judicial Circuit , for Broward County, Florida (the "Defamation Action") and in
future actions that may relate to or arise from the same alleged issues presented in the Florida
Litigation;
Whereas, Jack Scarola of Searcy, Denney Scarola, Barnhart & Shipley, P.A. represents Brad
Edwards and Paul Casse ll in the Defamation Action;
Whereas, John Morris , General Counsel and Robert Payne, Associate General Counsel represent
the University of Utah and represent PauJ G. Cassell in connection w ith claim s that may arise
within the course and scope of Professor Cassell's employment with the University of Utah,
including the Counterclaims presented in the Defamation Action;
Whereas, Robert Adler, Dean at SJ. Quinney College of Law at the University of U tah, has
obtained advice in his capacity as Dean from John Morris and Robert Payne in connection with
the Defamation Action and Paul Cassell's participation in the Flori da Litigation;
Whereas, Virginia Roberts is a fact witness in the De famation Action, and is represented by
Boies , Schiller & Flexner LLP in that action, and may be represented by Boies, Schiller &
Flexner LLP in future actions that may relate to or arise from the same alleged issues presented
in the Defamation Action;
GIUFFRE005570
CONFIDENTIAL
PRIVILEGEDAND CONFIDENTIALAGREEMENT
ATTORNEYWORK PRODUCT
ATTORNEY-CLIENTPRIVILEGE
JOINT DEFENSEPRIVILEGE
Whereas, Boies, Schiller & Flexner LLP has been subpoenaed in the Defamation action;
Whereas, Virginia Roberts is investigaling potential claims and actions relating to her abuse
during the time she was a minor child, and is represented in that connection by Boies, Schiller &
Flexner LLP, Stan Pottinger of J. Stanley Pottinger PLLC, Bradley J. Edwards of Fam1er, Jaffe,
Weissing, Edwards, Fistos & Lehrman, P.L., and Paul G. Cass ell;
Whereas, the Parties both directly and through the ir respective counsel have individually
undertaken, and will undertake, factual and legal research and ana lysis, and on the basis of tha t
research and analysis believe and anticipate that the nature of their interests will present various
common legal and factua l issues and/or a mutuality of interest in connection with the Florida
Litigation and Defamation Action and any related suits and any related disputes (collective ly the
"Proceedings");
Whereas, the Parties have concluded that they have a separate but joint, mutual, and common
interest in preparing an appropriate defense, including developing joint strategies and defenses
and in join tly engaging in fact-gathering, investigation, legal analysis, and negotia tions, in the
Proceedings and any related suits;
Whereas, the Parties, for a significant pe 1iod of time , have already exchan ged confidential
information in anticipation of litigating the Proceedings and any related suits and have been
acting in accordance with a common interest/joint defense agreement while not previously
reduced to writ ing, it is the intention that all prior communications were protected and continue
to be protected;
Whereas, it is the intention and understanding of the Parties that past, present, and future
communications among and between the Parties and their counsel in anticipation of or relating to
the Proceedings and any related suits or disputes are, and shall continue to remain, confident ial
and protected by all available rights, privileges, immunities, and protections from disclosure to
any third party;
Whereas, the Parties wish to continue to pursue their separate but joint, mutual, and common
interests in the Proceedings and any related suits by lawfully communicating and sharing
documents and/or their contents, factual material , mental impressions, opinions, correspondence,
notes, memoranda, interview reports , trans cripts of testimony, debriefing memos, research,
analysis, strategy, and other information, including confidences shared by the Parties with their
respective counsel - all of which when obtained or communicated shall be referred to as "Joint
Defense Materials";
Whereas, it is the purpose of this Agreement to ensure that the past, present, or future sharing of
Joint Defense Materials contemplated herein does not diminish in any way the confidentiality of
such mater ials and info1mation and does not constitute a waiver of any app licable rights,
privileges, immunities, or protections: and;
GIUFFRE005571
CONFIDENTIAL
ATTORNEYWORK PRODUCT
Now, therefore, the Parties agree as follows:
1. The foregoing recitals are incorporated herein as a material part of this Agreement.
2. It is the intention and understand ing of the Parties and their respective counse l that Joint
Defense Materials exchanged pursua nt to this Agreement are being shared solely for
internal use of the Parties and their counsel in connection with the Proceedings and any
related suits , and that such Joint Defense Materials shall remain confidential and
protected from disclosure to any third party by the attorney-client, joint defense, common
interest, and self-critical analysis privileges, work product doctrine, or any other
applicable rights, privileges, immunities, or protections. It is the understanding of the
Parties and their respective counsel that materials obtained or prepared in connection with
Proceedings may be exchanged as Joint Defense Materials in order to allow the Parties to
pursue their joint, mutual, and common interests in defending the Proceedi ngs. It is the
intent of this Agreement that the confidentiality and all rights, privileges, immunit ies, or
protections applicable to the Joint Defense Materials shall apply to all Joint Defense
Materia ls shared pursuan t to th.is Agreement to same extent as if such Joint Defense
Materia ls had not been so shared . The Parties ' exchange of confidential and privileged
infonnation pursuant to this Agreement shall not waive and shall not be construed in any
way as a waiver of confidentiality or of any applicable right, privilege, immwuty , or
protection.
3. Each Party and their respective counsel agrees to honor the designat ions made by the
sharing Party with respect to whether Joint Defense Materials shared with another Party
are protected by the attorney-client, joint defense, common interest, or self-critical
analysis privileges , the attorney work product doctrine, or other applicable rights,
privileges, immunities, or protections . Each Party further agrees that any rights,
privileges, immunities , or protections asserted by the sharing Party with respect to any
Joint Defens e Materials cannot be waived by any Party other than the sharing Party, and
not without express prior written consent of the sharing Party.
4. Each Party agrees that the voluntary sharing of Joint Defense Materials hereunder is
necessary to the pursu it of the Parties' joint, mutual, and common interest in the defense
of the Proceedings and any related suits . Nothing in this Agreement, however, shall
obligate any Party to share or communicate any Join t Defense Materia ls with another
Party.
5. None of the Parties nor their respect ive counsel shall disclose Joint Defense Materia ls or
the contents thereof to anyone other than the persons set forth in Paragraph 6. It is
expressly understood that nothing contained in this Agreement shall limit the right of any
Party or their respective counsel to disclose to anyone as they see fit their own documents
or infonnation, or any documents or information obtained independently and not pursuant
to this Agreement.
GIUFFRE005572
CONFIDENTIAL
ATTORNEYWORKPRODUCT
6. Except as otherwise provided in this paragraph, Joint Defense Materials shared pursuant
to this Agreement may be disclosed to (a) the Parties ' respective counsel (and their
secretaries, clerical aides, and legal assistants) in the Proceeding s and any related suits;
and (b) any consultants, agents, and/or experts used in connection with the Proceedings
and any related suits who sign a copy of the confidentiality agreement attached hereto as
Exhibit A. A Party sharing Joint Defense Materials may limit the distribution of the Joint
Defense Materials further by stating the limitation at the time the Joint Defense Materials
are shared. Each person receiving Joint Defense Materials pursuant to this Agreement
shall maintain it in the strictest confidence, not disclose it to anyone other than the
persons specified above , and not use the infonnation for any purpose other than
represen tin g a Party to the Agreement in connection v..ith the Proceedings and any related
suits.
7. Neither Party to this Agreement nor the Parties' counsel will disclose the tenns of this
Agreement to any person not a Party nor the Parties' counsel except upon prior notice to
the other Party sufficient to allow for an opportunity for the Party to discuss the proposed
disclosure. If any Party receives a subpoena, request for production of documents or
otlier form of compulsory process, it will immediately notify the other Party and will
assert all appl icable rights, privileges, protections, and immunities, including the joint
defense privilege, in response thereto and provide not less than five (5) business days-
notice before production, or order to permit the other Party to talce appropriate action. If
five (5) days-notice cannot be provided, the Party upon which the demand or request is
made agrees to bring a motion to stay the proceedings in order to allow the other Party an
opportw1ity to respond.
8. Nothing in this Agreement shall be construed to (a) affect the independent representation
of each Party by its respective counsel; (b) alter any counsel's right or obligation to
advise its client according to what counsel believes to be the best interest of its client; (c)
bind or ob lige any Party or their respective counsel to agree to a single course of action or
to take any specific action with respect to the Proceedings and any related suits; (d)
preclude either Party from asserting any claim or defense in any proceeding or from
seeking dismissal of any claims or defenses or proceedings by motion or otherwise; or (e)
prevent any counsel from advising its client to settle any claim.
9. Nothing con tained in this Agreement is intended to create any attorney-client relationship
for the purposes of conflicts or otherwise. Each Party and its respective counsel
understands that such Party 's counsel has sole respo nsib ility to represen t that Party and
the attomeys representing other Parties to this Agreement have not assumed any such
responsibility. Moreover, the participation in, execution of, or receipt of any infonnation
pursuant to this Agreement shall not, preclude or be used as a basis for seeking to
disqualify any representative of a Party from (a) accepting any other future engagement
that may be adverse to another Party to this Agreement; or (b) representing its respective
client in the Proceed ings and any related suits.
GIUFFRE005573
CONFIDENTIAL
ATTORNEYWORKPRODUCT
JOJNT DEFENSEPRIVILEGE
10. This Agreement memorializes and reflects the earlier ag reements and understandings
betwee n the Parties pursuant to the Proceedings and any related suits or disputes for
which Joint Defense Materials may have been exchanged. This Agreement also confirms
that to the extent that the Parties have already been in communica tion v.ith each other
concerning any aspect of the issues raised in the Proceedings and any related suits, such
communications and any attorney work product were and are subject to any and all
applicable privi leges, including but not limited to, the joint defense privilege, the
common interest privilege, the attorney-client privilege, and the work product doctrine
and are now the subject of this Agreement. This Agreement is intended to be the written
embodiment of the Parties' prior oraJ and written understand ings.
11. Subject to the last two sentences of this paragraph, upon completion of the Proceedings
and any related suits, unless otherwise agreed in w1iting, the Parties shall, within 30 days,
return all Joint Defense Materia ls and copies thereof received pursuant to this Agreement
to the other Party or destroy all such Joint Defense Materials. A Party shall not be
required to return or destroy materials that embody the work product of counsel for the
Party. Outside counsel for either Party shall not be requ ired to return materials that are
part of that counsel's Proceedings' files and any related suit files.
12. Each Party specifically agrees and acknowledges that a remedy at law will be inadequate
as a result of any violation of the terms of this Agreement by any Party, counsel, or other
person found to have violated or about to violate any of the terms of this Agreement.
Therefore, in addition to any and all other legal or equitable remedies, the non-breaching
party will be entitled to injunctive relief for any breach of this Agreement.
13. The inadvertent disclosure of Joint Defense Materials to persons not authorized under this
Agreement to receive such Joint Defense Materials shall not be intended to constitute
waiver of any applicable privilege or protection afforded such Joint Defense Materials. A
Party inadvertently disclosing Joint Defense Materials to unauthorized persons shall
immediately notify the other Party and shall take all necessary steps to recover such Joint
Defense Materia ls from the unauthorized persons and to protect against the waiver of any
appl icable privilege or protection.
14. Each Party agrees to make this Agreement available to, and to bring it to the attention of,
any substitute or associated counsel who may appear on behalf of any Client, which
counsel shall be automatically bound to the terms hereof.
15.This Agreement shall not be subject to abrogation by any heir, assign , or other successor
in interest to any Party hereto . Nor shall such heir, assign, or successor in interest waive
any privilege or doctrine with regard to information shared by or among the Parties to
this Agreement.
GIUFFRE005574
CONFIDENTIAL
ATTOR.!"l'EY
WORKPRODUCT
A'rfORNEY-CLIENTPRIVILEGE
16. If any part of this Agreement is held to be invalid, unenfon::eable, or illegal, such
determination shall not affect any other provision of this Agreement, and this Agreement
shall then be construed as if the impermissible provision was not contained herein.
17. A person or entity that shares a mutual interest in a common and joint defense relating to
the Proceedings, whether cmTently pending or initiated hereafter, may join this
Agreement with the written consent of all Parties.
18. Modifications to this Agreement may only be made in writing and are effective upon
written signature of each Party.
19. This Agreement has no termination dace. Each Party to this Agreement has the right to
terminate his, her, or its participation at any time and to withdraw from the Agreement.
Termination shall be effective ten (10) days after the withdrawing Party tenders written
notice, including but not limited to e-mail notification, to all Parties to this Agreement
and their respective counsel.
20. Termination of a Party's participation under this Agreement shall be prospective only and
shall not operate as a waiver, or authorize violation, of this Agreement. A terminating
Party remains bound to maintain the confidentiality of Joint Defense Materials received
under this Agreement. The Agreement shall continue between and among the remaining
Parties.
21. A terminating Party shall, within thirty (30) days after the withdrawing Party tenders
written notice of withdrawal, return all Joint Defense Materials and copies thereof
received pursuant to this Agreement to the other Party or destroy all such Joint Defense
Materials. A Party shall not be required to return or destroy materials that embody the
work product of counsel for the Party. Outside counsel for either Party shall not be
required to return materials that are part of that counsel's Proceedings' files and any
related suit files.
GIUFFRE005575
CONFIDENTIAL
l'lUVILEGfW AN D CON F IDENT I AL AGREEMENT

ATTORNEY
WORKPRODUCT
ATTORNEY-CLffiNT PRJVILEGE
JOINT DEFE-1\SE PRJ VlLEGE
In witness whereof each of the fo?Jowing counsel on behalf of themselves, ihe;r respective
clienls, and !he other .iHom<.:ys
witbiu their orgnnizntions, huve executed tbis Agreement :is
of _ ____ duy in __ _ __ _, 2015.
Farmer, Jaffe, Weissing, Edwards, F'istos&

I'Bob, Sthil lcr & Flexner LLP
L ehrman, P.L.
-=- -- .' By :__
/., ,-?
:,_c:,_f'$ :;:!-;
~
By~ ~-- DavfdBo /
Brndley J. Edwards Sig1·itlS. McCuwley
425 North Andrews Avenue, Suite 2 401 Eost Las Olas Hlvd., Suite 1200
fon Lauderdale, Florida 3330 I Ft. Landerdale, FL 3330 I
INv.
Counselfor Virginia Rob1:ns(a.k.a. Jane Doe
3) and Plai11rifjin1'1eDef11matio11
Action
Courm•Ifor Vtrginln Roberts (c1.k a Jnne Doe
No. 3)
0,JJ@ __
Paul G. Cassell
Searcy, Denn~y,Scacol:t,Barnhart & Shipley, .
P.A. 1
!
Prcsidenl!al Pi-ofessorof Criminal Law
S.J. Quinney College of Lnw ot the University By :_ -·-·-- -- --- - --
of Utah Jack Sc<!rola
' 332 SouU11400 East, Room JOI 2139 Palm Beach Lakes Boukval'(l
Sall Lake City, U1ah84112-0730 West P.llm Dench,Florida 33409
Counsel for Virginia Roberts (a.le.cc wards and Paul G.

. Jane Dor: Cow,:,e/for iJl'adleyJ. J::d
t No. 3) and Plai11ti[(i11
the DefamationAction C,1~sell
'·-------- -- - -- --;---- --------·--
= ='-"C,,__~
By:,...,t:....---4" ____
John Mo ~is, General Counsel
_ By:
Rob~
/' ~/r-
-Jt ll~n{.A .. ?cYl~
~-;
GenerjJJ,{:ounse
l
University of Utah Of.fie of the • ene;dlCo~c(.
332 South 1400 fast, Room 101 Unj. ·ers1l f Ut9n _/
S,ilt Lake City, U,ah 84112 -0730 3.;2 S_pth 1400 East, Room l 01
,SaJd.ake City, Utah 841 12-0730
,,,/
Co1mselfar Paul G, Ca.1·sell
Cow,sd for Pwl G. Cassell
GIUFFRE005576
CONFIDENTIAL
PRIVILEGEDAND CONFIDENTIAL AGREEMENT

ATTORJ\IEY-CLIENTPRIVILEGE
JOINT DEFENSE PJUVILEGE
In witness whereof each of the following counsel on behalf of themselves, their respective
clients, and the other attorneys within their organizations, have executed this Agreement as
of _____ dayin _____ ~2015.
Farmer, Jaffe, Weissing, Edwards, Fistos & Boies, Schiller & Flexner LLP
Lehrman, P .L.
By:__________ _
By:__________ _ David Boies
Bradley J. Edwards Sigrid S. McCawley
425 North Andrews Avenue, Suite 2 40 l East Las Olas Blvd., Suite 1200
Fort Lauderdale, Florida 33301 Ft. Lauderdale, FL 33301
Counsel for Virginia Roberts (a. k.a. Jane Doe Counsel for Virginia Roberts (a.ka. Jane Doe
No. 3) and Plaintiff in the Defamat ion Action No . 3)
By:_________ _ _ ~&Shlpley,
Paul G. Cassell
Presidential Professor of Criminal Law
S.J. Quinney College of Law at the University
of Utah
332 South 1400 East, Room IOI
Salt Lake City, Utah 84112-0730
J~;~~L
213 Payrl Beach Lakes Boulevard
Wjs;Jalm Beach, Florida 33409
Counsel for Virginia Roberts (a.k.a. Jane Doe K.msel for Bradley J. Edwards and Paul G.
No. 3) and Plaintiff in the Defamation Action Cassell
By:__________ _ By:________ __ _
John Morris, General Counsel Robert Payne, Associate General CoW1sel
University of Utah Office of the General Counsel,
332 South 1400 East, Room JOI University of Utah
Salt Lake City, Utah 84112-0730 332 South 1400 East, Room IOI
Salt Lake City, Utah 84112-0730
Counsel/or Paul G. Cassell
Counsel for Paul G. Cassell
GIUFFRE005577
CONFIDENTIAL
PIUVlLEGED AND CONFJDE:'YTIALAGREEMENT

A'l'TOR..'-:EY
WORJ< PRODUCT
ATTORNEY-CLIENT PRIVlLEGE
J01NT DEFENSEPRIVILEGE
By: ~i!J.J.al20-.1-- 1B:·_ __ ____

'Rob:r! Ad ler, Dcun ··---·---
lS.J. Quin :iey C:o llege cf I.aw, Uni-..:rnl) ' uf
I
Virginia Rober',.sG:uffre
Utah
I332 South I4UC:last, Room JOl
Sall Lake City, Utah 84 l l 2-0730
J St ineerP Tc
By1----:,;~d-
h HJa.~"'1"1~'---,.
S1·"
49
, alem, NY JO
GIUFFRE005578
CONFIDENTIAL
f•:tr- .'1LEC£D AND CONFlnf. .','TJAJ. ;\GfU,J;:M~NT

,-,·1TOR.'-:R\'WOIU<"PrWD'lJCT
ATTOR.'\'E.Y CLl&t-.T J'>Hl\•1LEGE
-- ________
c':"
-• t"':,r·'\ •
.._..,..
,, /) ~
PR1VJu:c1~
JO:~, I' lJE.F!~NSC:
,V '/." 1., ·/1,/i'~

Bi. - - - -..,.-',:..v;,·:
l_•::l _::;·::.:::
_:.;.:!--··
Rc,~,:7! ,\di,::. L~-:~n
~~J t~u1r:,-!1 ( '1di~t:•: c.f f ;n;.• L,·1:;\: f ).i~ · ,:f
L'[~:
JJ:: Sout'.':I 4l '(. ::~~:, Rco:·1 ! ,; 1
s~lr l:!.kc:Ci! i', :;1:~n s.:, ; 2 C '"J
GIUFFRE005579
CONFIDENTIAL
PRIVILEGJ•;DAND CONFJDEl'iTIAL AGREE~1ENT

A TTOR.i'JEY-CLIENT PRJVTLEGE
JOINT DEFENSE PRIVILEGE
EXlflBJT ,.\
!, _\) .: ~ • Cl!v. ~,,b , 1_<,____G.✓•

r r.., residing ar haw:
read the fo
cgoing Joint Defense and Common Interest P • I ,I ' ment
(the "Ag reement ") and ;igree to be bound by the terms of rJic Agret:mcnr with respecr 10 Joint
Defense Materia ls furnished to me as set forth in the Agreement. I further 3gret: (a) not to
disclose to anyone any Joint Defense Matedah other than as set forth in the Agreement; and {b)
not to make copies of any w:-it,cn Joint Defense Materials except in accordance with the
Agrc~ment. r furtbcr consent to the jurisdiction of the .court before which proceedings in the
FloriJ o Litigation ,md Defam:,rtion Action and any related suits are then pending with regard ro
any proceedings 10 enforce the tcnns of this Agreement against me. I furth~r agree thst Joint
Defense l'vb tcrials fornished to rm: will be u,">edby me only for the purposes of thc:se Proceedings
and any related suits, aud for no o!he.r purpose, and will not be used by me in any business affairs
or my employer or my own; nor .,.:illthe infonnation contained therein be imparted by me to any
othcr person other than as provided for 1lnder the Agreement.
Title :
-·-- - --- ----
GIUFFRE 005580
CONFIDENTIAL

--------------------------------------------------X
.........................................
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
DEFENDANT’S RESPONSE IN OPPOSITION TO

MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT
Laura A. Menninger
Jeffrey S. Pagliuca
East 10th Avenue
Denver, CO 80203
303.831.7364
Defendant Ghislaine Maxwell (“Ms. Maxwell” ) files this Response in Opposition to
Plaintiff’s Motion to Exceed Presumptive Ten Deposition Limit, and states as follows:
INTRODUCTION
Despite having taken only three depositions to date, Plaintiff prematurely requests
permission to exceed the presumptive ten deposition limit imposed by Fed. R. Civ. P.
30(a)(2)(A)(i) and to conduct 17 separate depositions, almost twice the limit. Without legal
support, Plaintiff attempts to conflate the presumptive time limitation for each deposition of
seven hours with a right to take a total of 70 hours of depositions. This is an absurd reading of
the Federal Rules. The presumptive ten deposition limitation is an independent limitation, and
speaks to the number of separate deponents, not deposition time. Indeed, the two independent
limitations do not even appear in the same section of the rules.
The heart of Plaintiff’s argument is that Ms. Maxwell inconveniently testified and denied
Plaintiff’s claims, rather than invoking the Fifth Amendment. This dashed Plaintiff’s apparent
hope to obtain an adverse inference, rather than actually having to prove her case against Ms.
Maxwell. Instead, Ms. Maxwell fully testified for the entire 7 hours, responded to all questions
posed to her,1 and testified based on her actual knowledge. Ms. Maxwell’s testimony simply
bears no relevance to Plaintiff’s request to take more than 10 depositions of non-party witnesses.
Conspicuously absent from Plaintiff’s motion are (a) any actual information she believes
these witnesses may provide which is neither cumulative nor duplicative of other information
already disclosed in this case, (b) the fact the information can be obtained from other sources,
1
Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to
her, as the actual transcript amply demonstrates. Ms. Maxwell did not avoid any questions and answered
all questions to the best of her recollection relating to alleged events 15 years ago. The majority of the
bullet point “summary” of the matters about which Ms. Maxwell could not testify were based either on a
lack of any personal knowledge or the fact that the events claimed by Plaintiff did not actually happen.
1
and (c) facts demonstrating that the burden and expense of the discovery is justified by the needs
of this case. Indeed, she has not established that the testimony is even relevant to the actual
issues in this matter. Plaintiff’s inability to establish these factors requires denial of the motion.
I. PLAINTIFF’S REQUEST IS PREMATURE
First, the request to exceed the presumptive ten-deposition limit is premature. “[C]ourts
generally will not grant leave to expand the number of depositions until the moving party has
exhausted the ten depositions permitted as of right under Rule 30(a)(2)(A) or the number
stipulated to by the opposing party.” Gen. Elec. Co. v. Indem. Ins. Co. of N. Am., No. 3:06-CV-
232 (CFD), 2006 WL 1525970, at *2 (D. Conn. May 25, 2006).
This guideline makes sense because a “moving party must not only justify those
depositions it wishes to take, but also the depositions it has already taken.” Id. (citing Barrow v.
Greenville Indep. Sch. Dist., 202 F.R.D. 480, 482 (N.D.Tex. 2001)). This rule is in place because
“a party could indirectly circumvent the cap on depositions by exhausting the maximum allotted
number to those that she could not justify under the Rule 26(b)(2) standards, and then seek[ ]
leave to exceed the limit in order to take depositions that she could substantiate.” Id. at 483.
Here, Plaintiff seeks a pre-emptive determination that she should be permitted 17
depositions, almost twice the presumptive limit, yet her proposed depositions are not calculated
to lead to admissible evidence in this case. By way of example, Plaintiff identifies Nadia
Marcinkova, Sarah Kellen (a/k/a Sarah Kensignton or Sarah Vickers), and Jeffrey Epstein as
alleged “co-conspirators” with each other. She requests the depositions of each. Plaintiff
anticipates each will invoke the Fifth Amendment –in other words, she will not obtain any
discoverable information from them.
2
Plaintiff makes a bizarre argument that somehow this testimony can be used to create an
adverse inference against Ms. Maxwell,2 despite the fact that Ms. Maxwell did not invoke the
Fifth Amendment and she testified fully and answered every question posed to her with the only
exception the irrelevant and harassing questions Plaintiff posed to her concerning her adult,
consensual sexual activities. In other words, depositions of Marcincova, Kellen and Epstein
would serve Plaintiff’s goal to make a convoluted legal argument, not to actually seek
discoverable information. In light of this, the “burden or expense of the proposed discovery
outweighs its likely benefit, considering the needs of the case, the parties' resources, the
importance of the issues at stake in the action, and the importance of the discovery in resolving
the issues.” Atkinson v. Goord, No. 01 CIV. 0761 LAKHBP, 2009 WL 890682, at *1 (S.D.N.Y.
Apr. 2, 2009); Fed. R. Civ. P. 26(b)(1). If Plaintiff chooses to use her depositions in this manner,
she risks utilizing three of her available 10 depositions for an illegitimate purpose. She should
not be rewarded with a pre-emptive carte blanche in advance to take additional depositions.
II. THE PROPOSED DEPOSITIONS ARE CUMULATIVE, DUPLICATIVE, AND

NOT RELEVANT TO THE CENTRAL ISSUES OF THE DISPUTE
Plaintiff has not met the requisite showing to permit in excess of 10 depositions. In
Sigala v. Spikouris, 00 CV 0983(ILG), 2002 WL 721078 at *3 (E.D.N.Y. Mar. 7, 2002), the
Court set forth the general principles relevant to a party's application to conduct more than ten
depositions:
2
Invocation of the Fifth Amendment by a third party witness cannot be used to create an adverse
inference against a party in a civil action. See United States v. Dist. Council of New York City & Vicinity
of United Bhd. of Carpenters & Joiners of Am., No. 90 CIV. 5722 (CSH), 1993 WL 159959, at *5
(S.D.N.Y. May 12, 1993) (“the general rule [is] that an individual's claim of Fifth Amendment protection
is personal, and does not give rise to adverse inferences against others.” ); Brenner v. World Boxing
Council, 675 F.2d 445, 454 n. 7 (2d Cir.), cert denied, 459 U.S. 835 (1982) (“Furthermore, since King
was a non-party witness, no adverse inference against appellees could have been drawn from his refusal
to testify.” ).
3
The Federal Rules presumptively limit the number of depositions that each side
may conduct to ten. See Fed.R.Civ.P. 30(a)(2) (A) (“A party must obtain leave of
court, which shall be granted to the extent consistent with the principles stated in
Rule 26(b)(2), if ... a proposed deposition would result in more than ten
depositions being taken ....” ); accord Universal City Studios v. Reimerdes,104
F.Supp.2d 334, 342 (S.D.N.Y.2000); Landry v. St. James Parish Sch. Bd., No.
Civ. A 99-1438, 2000 WL 1741886, at *2 (E.D.La. Nov. 22, 2000). The purpose
of Rule 30(a)(2)(A) is to “enable courts to maintain a ‘tighter rein’on the extent
of discovery and to minimize the potential cost of ‘[w]ide-ranging discovery’. . .
.” Whittingham v. Amherst Coll., 163 F.R.D. 170, 171-72 (D.Mass.1995) (citation
omitted). Accordingly, “[t]he mere fact that many individuals may have
discoverable information does not necessarily entitle a party to depose each such
individual.” Dixon v. Certainteed Corp., 164 F.R.D. 685, 692 (D.Kan.1996).
“The factors relevant to determining whether a party should be entitled to more than ten
depositions are now set forth in Fed.R.Civ.P. 26(b)(2)(C)3 and include whether (1) the discovery
sought is unreasonably cumulative or duplicative or can be obtained from some other source that
is more convenient, less burdensome, or less extensive, (2) the party seeking discovery has had
ample opportunity to obtain the information by discovery in the action, and (3) the burden or
expense of the proposed discovery outweighs its likely benefit, considering the needs of the case,
the parties' resources, the importance of the issues at stake in the action, and the importance of
the discovery in resolving the issues.” Atkinson, 2009 WL 890682, at *1 (S.D.N.Y. Apr. 2, 2009)
(internal quotations omitted).
3
Rule 26(b)(1) has since been modified to read “(i) the discovery sought is unreasonably cumulative or duplicative,
or can be obtained from some other source that is more convenient, less burdensome, or less expensive; (ii) the party
seeking discovery has had ample opportunity to obtain the information by discovery in the action; or (iii) the
proposed discovery is outside the scope permitted by Rule 26(b)(1).” The scope of discovery permitted by 26(b)(1)
is “non-privileged matter that is relevant to any party's claim or defense and proportional to the needs of the case,
considering the importance of the issues at stake in the action, the amount in controversy, the parties’relative access
to relevant information, the parties’resources, the importance of the discovery in resolving the issues, and whether
the burden or expense of the proposed discovery outweighs its likely benefit.” Thus, the factors to be considered
have simply been moved to a new number with cross reference.
4
Weighing these factors, there is no basis for permitting more than the presumptive ten
deposition limit. First, as highlighted by the motion, the information purportedly sought is
cumulative and duplicative. By way of example, Plaintiff has already deposed Johanna Sjoberg
(a former Epstein employee), Juan Alessi (a former Epstein employee), and David Rodgers4
(former Epstein Pilot). She further seeks to depose Maria Alessi and Jo Fontanella (former
Epstein household employees), as well as Dana Burns and Emmy Taylor (identified as assistants
to Ms. Maxwell or Mr. Epstein). The information Plaintiff claims each of the witnesses may
have is identical to that of each other –what they observed while working for Epstein. Plaintiff
goes so far as to state that Maria Alessi’s deposition is expected to “corroborate” the
observations of her husband’s.
Plaintiff admits that the purpose in seeking the additional depositions is “obtaining
witnesses, like Ms. Sjoberg, who can corroborate that [Plaintiff] is telling the truth.” Yet, Ms.
Sjoberg did not “corroborate that [Plaintiff] is telling the truth.” Instead, she testified that
■
Regardless, Plaintiff is looking in vain for more testimony of exactly the same character,
precisely the type of testimony the presumptive limit is intended to prevent.
Similarly, the expected deposition testimony of former Palm Beach Detective Joe
Recarey and former Palm Beach Police Chief Michael Reiter are duplicative of each other.
4
Mr. Rodgers deposition, held last Friday and requiring a separate trip to Florida for Colorado counsel after the
scheduled court hearing on Thursday, served simply to authenticate flight logs. There are far more convenient, less
burdensome, and less expensive methods by which such information could have been obtained, such as a verifying
affidavit, yet Plaintiff chose to unnecessarily burden counsel, the witness and counsel for the witness with a 3 hour
deposition to accomplish the same end.
5
Putting aside the admissibility of this testimony, it appears that both men were involved in the
investigation of Mr. Epstein and are expected to testify about their investigation. Plaintiff’s
allegations were not a part of their investigation, which took place years after Plaintiff left the
country. Moreover, their investigation did not involve Ms. Maxwell. Again, such duplicative
and irrelevant deposition testimony speaks to the intended purpose of the ten-deposition limit,
not a reason to exceed that limit.
The same holds true for Nadia Marcinkova, Sarah Kellen (a/k/a Sarah Kensignton or
Sarah Vickers) and Jeffrey Epstein, each of whom Plaintiff anticipates will not respond to
questions and invoke their Fifth Amendment right. As discussed above, such invocation has no
bearing on the issues in this matter. Moreover, it is obviously cumulative and duplicative.
Plaintiff also identifies Rinaldo Rizzo and Jean Luc Brunel but fails to provide any
information from which Ms. Maxwell or the Court could identify the subject matter of their
expected testimony. Thus, it is unclear how these individuals have information that differs from
or would add to the other proposed deponents. It is the Plaintiff’s burden to explain to the Court
why these depositions should be permitted if they exceed the presumptive limit, why the
information would not be cumulative, and its relevance to the important issues in the action, or
the importance of the discovery in resolving those issues. She simply fails to provide any
information by which the Court can assess these factors, and thus should not be permitted to
exceed the deposition limit based on her proffer.
III. THE TESTIMONY SOUGHT IS IRRELEVANT TO THIS SINGLE COUNT

DEFAMATION CASE
This case is a simple defamation case. Plaintiff, through her counsel, filed a pleading
making certain claims regarding “Jane Doe No. #3” –the Plaintiff –and her alleged
6
“circumstances.” See Complaint. Ms. Maxwell denied the allegations made stating they were
“untrue” and “obvious lies.” Plaintiff claims these statements are defamatory because she has
been called a “liar.”
“A public figure claiming defamation under New York law must establish that ‘the
statements ... complain[ed] of were (1) of and concerning [the plaintiff], (2) likely to be
understood as defamatory by the ordinary person, (3) false, and (4) published with actual
malice.’” Biro v. Conde Nast, 963 F. Supp. 2d 255, 276 (S.D.N.Y. 2013), aff'd, 807 F.3d 541
(2d Cir. 2015), and aff'd, 622 F. App'x 67 (2d Cir. 2015).
If Ms. Maxwell’s statements are essentially true –Plaintiff lied –Plaintiff cannot
establish her claim, and it is an absolute defense.5 Further, if Plaintiff cannot prove actual malice
by Ms. Maxwell, her claim fails. See Contemporary Mission, Inc. v. New York Times Co., 842
F.2d 612, 621 (2d Cir. 1988) (limited purpose public figure must establish by clear and
convincing evidence that the defendant published the alleged defamatory statement with actual
malice, “that is, with knowledge that it was false or with reckless disregard of whether it was
false or not” ) (quoting New York Times, 376 U.S. 241, 280 (1964)). That is, Plaintiff must prove
that Ms. Maxwell permitted the publication of the statement knowing it to be untrue.
None of the witnesses identified are listed as having discoverable information regarding
any of the elements of this claim. None is claimed to have direct knowledge to confirm the truth
of Plaintiff’s claims about what happened to her, that the acts she claims she participated in
5
There is only one public statement that existed on January 2, 2015 to which Ms. Maxwell was responding in the
statement by her press agent. The document is the Joinder Motion filed in the Crime Victims’Rights Act case on
behalf of Plaintiff by her attorneys, Bradley Edwards and Paul Cassell. Menninger Decl., Ex. A, p. 4. The very first
line describing Jane Doe #3 Circumstances is false, as Plaintiff now concedes. It read: “In 1999, Jane Doe #3 was
approached by Ghislaine Maxwell,” and continuing that “Maxwell persuaded Jane Doe # 3 (who was only fifteen
years old) to come to Epstein's mansion . . .” Plaintiff now concedes that she did not meet Ms. Maxwell or Mr.
Epstein in 1999, and she was not 15 years old. Menninger Decl., Ex. A at 26-29. No amount of “circumstantial
evidence” can overcome the fact that Ms. Maxwell’s statement was correct and that statements in the Joinder
Motion were untrue.
7
occurred or that they occurred with the people she claims to have been involved. Rather, each
witness identified as being able to provide their observations regarding “other” allegedly
underage girls, their own personal experience,6 or beliefs about Plaintiff’s credibility. None of
this is relevant. This is not a case about Jeffery Epstein or the alleged “modus operandi of the
Epstein organization.” This is a simple case of if Ms. Maxwell’s denial of the allegations made
by Plaintiff about Plaintiff’s own interactions with Maxwell was defamatory, and if Ms. Maxwell
acted with actual malice in issuing the denial. Plaintiff’s attempt to amplify this proceeding into
something broader should not be condoned.
Because the evidence sought is nothing more than extraneous inadmissible
“circumstantial evidence” 7 irrelevant to proving the essential elements of the claim, “the burden
or expense of the proposed discovery outweighs its likely benefit, considering the needs of the
case, the parties' resources, the importance of the issues at stake in the action, and the importance
of the discovery in resolving the issues.” Atkinson, 2009 WL 890682, at *1. As such, the
request for the additional depositions should be denied.
WHEREFORE, Ms. Maxwell requests that the Motion to permit in excess of the
presumptive ten deposition limit be denied; alternatively, if in excess of ten depositions are
permitted, Ms. Maxwell requests that Plaintiff be required to pay all costs and attorney’s fees
6
The information sought is also inadmissible. Plaintiff seeks testimony from witness who she claims will testify to
experience similar to her stories and this will “corroborate Ms. Giuffre's account description of the motive, way in
which Epstein and his co-conspirators created opportunity, intent, plan, knowledge, and to the specifics that make up
the criminal signature of Epstein and his co-conspirators.” Motion at 15-16. Such evidence is prohibited by
FRE 404(b), which states “Evidence of a crime, wrong, or other act is not admissible to prove a person’s
character in order to show that on a particular occasion the person acted in accordance with the character.”
Furthermore, no other witness has claimed as Plaintiff does that Ghislaine Maxwell sexually abused them, sexually
trafficked them, or that she partook in daily sex with any underage girls. Plaintiff’s claim stands in isolation because
it is fictional.
7
This “circumstantial evidence” has no bearing on the truthfulness of the stories published by Plaintiff. It is equally
likely to show that Plaintiff became aware of the allegations of others and decided to hop on the band wagon. She
then made up similar claims for the purpose of getting paid hundreds of thousands of dollars by the media for
publicizing her allegations and identifying well know public figures whose names she has seen documents that she
reviewed or other stories she had read.
8
associated with attending any deposition occurring outside 100 miles of the Courthouse for the
Southern District of New York pursuant to S.D.N.Y L.Civ.R. 30.1.
Dated: June 6, 2016.

Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
9
I certify that on June 6, 2016, I electronically served this Defendant’s Response in Opposition to
Motion to Exceed Presumptive Ten Deposition Limit via ECF on the following:

mschultz@bsfllp.com
J. Stanley Pottinger
Bradley J. Edwards 49 Twin Lakes Rd.
FARMER, JAFFE, WEISSING, EDWARDS, South Salem, NY 10590
FISTOS & LEHRMAN, P.L. StanPottinger@aol.com
/s/ Nicole Simmons
Nicole Simmons
10

--------------------------------------------------X
..........................................
Plaintiff,
v. 15-cv-07433-RWS
......
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X

Defendant’s Response in Opposition to Motion To Exceed
Presumptive Ten Deposition Limit
Ghislaine Maxwell (“Maxwell” ) in this action. I respectfully submit this declaration in support of
Ms. Maxwell’s Response in Opposition to Motion To Exceed Presumptive Ten Deposition
Limit.
2. Attached as Exhibit A (filed under seal) is a true and correct copy of excerpts
from the Deposition of Virginia Giuffre taken in the above captioned matter on May 3, 2016, and
designated by Plaitniff as Confidential under the Protective Order.


Laura A. Menninger
I certify that on June 6, 2016, I electronically served this Declaration Of Laura A.

Menninger In Support Of Response in Opposition to Motion To Exceed Presumptive Ten
Deposition Limit via ECF on the following:

mschultz@bsfllp.com
/s/ Nicole Simmons
Nicole Simmons
2
EXHIBIT A
Agren Blando Court Reporting & Video, Inc.
IN THE UNITED STATES DISTRICT COURT
Civil Action No. 15-cv-07433-RWS
CONFIDENTIAL VIDEOTAPED DEPOSITION OF

VIRGINIA GIUFFRE May 3, 2016
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
APPEARANCES:
FAMER, JAFFE, WEISSING, EDWARDS, FISTOS &

LEHRMAN, P.L.
By Brad Edwards, Esq.
425 N. Andrews Avenue
Suite 2
Fort Lauderdale, FL 33301
Phone: 954.524.2820
Appearing on behalf of the
Plaintiff

By Sigrid S. Mccawley, Esq. (For Portion)
401 East Las Olas Boulevard
Suite 1200
Fort Lauderdale, FL 33301-2211
Phone: 954.356.0011
Plaintiff
VIRGINIA GIUFFRE 5/3/2016 1

1 APPEARANCES: (Continued)
2 HADDON, MORGANAND FORMAN, P.C.

By Laura A. Menninger, Esq.
3 Jeffrey S. Pagliuca, Esq.
4 Denver, CO 80203
Phone: 303.831.7364
5 lmenninger@hmflaw.com
6 Appearing on behalf of the
Defendant
7
Also Present:
8 Brenda Rodriguez, Paralegal
Nicholas F. Borgia, CLVS Videographer
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

1 Q And you're talking about line 4?
2 A Line 4.
3 Q Paragraph 4 or line 4?
4 A Oh, sorry. Number 4, the paragraph
5 number 4.
6 Q Okay. And what part of paragraph 4 do you
7 now believe to be untrue?
8 A In approximately
10 You can answer.
11 A In approximately 1999 when I was 15 years
12 old I met Ghislaine Maxwell.
13 Q (BY MS. MENNINGER) Okay.
14 A I now know that it was 2000, that I was 16
15 years old when I met Ghislaine Maxwell.
16 Q So when you signed this document under
17 penalty of perJury stating that it was true, you no
18 longer believe that to be true, correct?
19 A It was an honest mistake. We had no idea
20 how to pinpoint without any kind of records or dates
21 or anything like that. I was just going back
22 chronologically through time. And that's the best
23 time that I thought it was. And now I know the
24 facts, so it's good to know.
25 Q So you now believe that a document you

1 filed under oath is no longer true, correct?
3 A I wouldn't say that it wasn't true. I was
4 just unaware of the times and the dates.
5 Q (BY MS. MENNINGER) Again, is there more
6 than one truth, Ms. Roberts?
7 A No, there's no more than one truth.
8 Q All right. So a document in which you
9 swore that you were 15 years old when you met
10 Ms. Ghislaine Maxwell is an untrue statement,
11 correct?
13 A It's not that it's an untrue statement.
14 It was a mistake. So it wasn't intentionally trying
15 to say something that wasn't true. It was to my best
16 knowledge that I thought it was 1999. And when I got
17 my records from Mar-a-Lago I was able to find out
18 that it was 2000. And this was entered before I
19 found out the actual dates that I did work at
20 Mar-a-Lago.
21 Q (BY MS. MENNINGER) Okay. So a document
22 that you filed under oath --
23 A Um-hum.
24 Q -- is now, you believe to be untrue,
25 correct?

1 MR. EDWARDS: Objection. Asked and
2 answered.
3 Q (BY MS. MENNINGER) You may answer.
4 MR. EDWARDS: Answer again.
5 A Again, I wouldn't say it's untrue. Untrue
6 would mean that I would have lied. And I didn't lie.
7 This was my best knowledge at the time. And I did my
8 very best to try to pinpoint time periods going back
9 such a long time ago.
10 It wasn't until I found the facts that I
11 worked at Mar-a-Lago in 2000 that I was able to
12 figure that out.
13 Q (BY MS. MENNINGER) And approximately when
14 did you learn those facts about the dates you worked
15 at Mar-a-Lago?
16 A I would say it was mid-2015.
17 Q Mid-2015 is the first time you became
18 aware of the dates
19 A I don't know the exact --
20 Q If you could just let me finish.
21 A I'm sorry.
22 Q That's all right. Approximately mid-2015
23 when you learned the true dates that you had worked
24 at Mar-a-Lago?
25 A That's correct. Sorry.

1 Q And based on the fact that you learned the
2 fact you had worked at Mar-a-Lago in 2000 -- you
3 became aware in mid-2015
4 A Um-hum.
5 Q -- that you had met Ms. Maxwell in 2000,
6 correct?
7 A That's --
9 A That's correct.
10 Q (BY MS. MENNINGER) All right. And you
11 became aware in mid-2015 that you were not 15 years
12 old when you met Ghislaine Maxwell, correct?
14 A That's correct.
15 Q (BY MS. MENNINGER) Okay. And who
16 provided you those Mar-a-Lago records in
17 approximately mid-2015?
18 MR. EDWARDS: I'm going to object.
19 And to the extent that this invades the
20 attorney-client privilege, if it was your attorneys
21 that you spoke to and learned this information or
22 received this information from, then you're
23 instructed not to answer.
24 A I cannot answer that question.
25 Q (BY MS. MENNINGER) Did you yourself look


--------------------------------------------------X
..........................................
Plaintiff,
v. 15-cv-07433-RWS
......
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
DECLARATION OF LAURA A. MENNINGER IN SUPPORT OF REPLY IN SUPPORT

OF MOTION TO COMPEL ALL ATTORNEY-CLIENT COMMUNICATIONS AND
PLACED AT ISSUE BY PLAINTIFF AND HER ATTORNEYS
Ghislaine Maxwell in this action. I respectfully submit this declaration in support of Reply in
Support of Motion To Compel All Attorney-Client Communications and Attorney Work Product
Placed At Issue By Plaintiff And Her Attorneys.
2. Attached as Exhibit Q is a true and correct copy of portions of Defendant
Ghislaine Maxwell’s Responses and Objections to Plaintiff’s Second Request for Production of
Documents, served May 16, 2016.

3. Attached as Exhibit R is a true and correct copy the Complaint filed in Jane Doe
102 v. Epstein, Case 9:09-cv-80656-KAM, in the United States District Court for the Southern
District of Florida, filed on May 1, 2009.
4. Attached as Exhibit S (filed under seal) is a true and correct copy of excerpts from
the Deposition of Virginia Giuffre taken in the above captioned matter on May 3, 2016, and
designated by Plaintiff as Confidential under the Protective Order.

Laura A. Menninger
I certify that on June 6, 2016, I electronically served this Declaration Of Laura A. Menninger In
Support Of Reply In Support Of Motion To Compel All Attorney-Client Communications And
Attorney Work Product Placed At Issue By Plaintiff And Her Attorneys via ECF on the
following:

mschultz@bsfllp.com
Bradley J. Edwards
/s/ Nicole Simmons

Nicole Simmons
2
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9,5*,1,$*,8))5(

v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S

REPLY TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT
licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015
Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in Support of Plaintiff’s Reply to Motion to
Exceed Presumptive Ten Deposition Limit.
3. Attached hereto as Exhibit 1 is a true and correct copy of
Deposition Transcript excerpts dated May 18, 2016.
4. Attached hereto as Exhibit 2 is a true and correct copy of Rough
Deposition Transcript excerpts dated June 10, 2016.
5. Attached hereto as Exhibit 3 is a true and correct copy of Juan Alessi’s



Boies Schiller & Flexner LLP
(954) 356-0011
David Boies
333 Main Street
Armonk, NY 10504

(954) 524-2820

University of Utah
383 University St.
(801) 585-52021
1
2

I HEREBY CERTIFY that on the 13th day of June, 2016, I electronically filed the
foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the
foregoing document is being served this day on the individuals identified below via transmission
of Notices of Electronic Filing generated by CM/ECF.

Jeffrey Pagliuca, Esq.
Tel: (303) 831-7364
Fax: (303) 832-2628

Sigrid S. McCawley
3

Virginia L. Giuffre ,
Plaintiff , Case No.: 15-cv-07433-RWS
V.
Ghislaine Maxwell,
Defendant.
------------- I
CORRECTED 1 DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF

PLAINTIFF 'S REPLY TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION
LIMIT
I, Si.grid S. Mccawley, declare that the below is tme and correct to the best of my
1. I am a paiiner with the law fnm of Boies, Schill er & Flexn er LLP and duly
licensed to practice in Florida and before this Comt pursuant to this Comt 's September 29, 2015
Order granting my Appli cation to Appeai· Pro Ha e Vice.
2. I respectfully submit this Declarati on in Supp o1t of Plaintiffs Reply to Motion to
Exceed Presump tive Ten Deposi tion Limit.
3. Attached hereto as Exhibit 1 is a hu e and con ect copy of
Depo sition Transcript excerpts dated May 18, 20 16.
4. Attached hereto as Exhibit 2 is a hu e and con ect copy of Final
Depo sition Transcript excerpts dated June 10, 20 16.
1
On June 13, 2016 , Ms . Giuffre filed her Reply in Supp o1t of her Motion to Exceed the
Presumpti ve Ten Deposit ion Limit (DE 203). This brief contained exce1pts from
"rough " deposition h·anscript , as the final h·anscript had not yet been compl eted by the
stenographer. On June 14, 2016, the stenographer issued the "final" deposition h·anscript, and
Ms . Giuffre hereb y files the final h·anscript citations and exce1pts to repla ce the "rough "
h·anscript that accompanied her suppo1ting Declarati on (DE 204-2). There ai·e no other changes
to this docume nt.
5. Attached hereto as Exhibit 3 is a true and correct copy of Juan Alessi’s


(954) 356-0011
David Boies
333 Main Street
Armonk, NY 10504

(954) 524-2820

University of Utah
383 University St.
(801) 585-52022
2
3
foregoing document is being served this day on the individuals identified below via transmission
of Notices of Electronic Filing generated by CM/ECF.

Tel: (303) 831-7364
Fax: (303) 832-2628

Sigrid S. McCawley
4
--------------------------------------------------X
............................................
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration Of Laura A. Menninger In Support Of Defendant’s Response in

Opposition to Extending Deadline to Complete Depositions and
Motion for Sanctions for Violations of Rule 45
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of
Defendant’s Response in Opposition to Extending Deadline to Complete Depositions and
Motion for Sanctions for Violations of Rule 45.
2. Attached as Exhibit A (filed under seal) is a true and correct copy of excerpts
from the Deposition of Rinaldo Rizzo on June 10, 2016, and designated by Plaintiff as
Confidential under the Protective Order.
3. Attached as Exhibit B (filed under seal) is a true and correct copy of The
Billionaire Playboys Club book manuscript drafted by Plaintiff, designated by Plaintiff as

•
Confidential under the Protective Order
4. Attached as Exhibit C is a report by fo1mer FBI director, Louis Freeh.
5. Attached as Exhibit D (filed under seal) is a trne and co1Tect copy of exce1pts of
Plaintiff s deposition on May 3, 2016 , and designated by Plaintiff as Confidential under the
Protective Order.
6. Attached as Exhibit E are hue and co1Tectcopies of May 23, 2016 co1Tespondence
from Mered ith Shulz and May 25, 2016 co1Tespondence from myself.
7. Attached as Exhibit F are h11eand co1Tectcopies of Notices of Subpoena with
attachments for Jean Luc Brnnel , served on Febrnary 16, 2016 and May 23, 2016 , as well as
co1Tespondence regarding Mr. Brnnel 's deposition from counsel, Bradley Edward s.
8. Attached as Exhibit G is a Motion to Quash filed by counsel for Jeffrey Epstein in
Broward County, Florida in Edwards and Cassell v. Dershowitz , Case No . 15-0000072 on
September 10, 20 15.
9. Attached as Exhibit Hi s a hue and co1Tectcopy of the Notice of Deposition and
Subpoena for Jeffrey Epstein, served on counsel on April 27, 2016.
10. Attached as Exhbit I are trne and co1Tectcopies of the Notice s of Depo sition and
Subpoena for Sarah Kellen and Nadia Marcincova , served on counse l on April 27, 2016.
11. Attached as Exhibit J (filed under seal) are h11eand co1Tectcopies of
co1Tespondence produced in this case between Ms. Maxwell and Jeffrey Epstein from Janua1y
2015 , and designated as Confidential by Defendant under the Protective Order .
12. Attached as Exhibit K (filed under seal) are Notices of Deposition and Subpoena
for , Joe Recarey and Michael Reiter and a letter of production from Sigrid
Mccawley of June 17, 20 16, designated as Confident ial by Plaintiff under the Protective Order.
2
-
13.
14.
Attached as Exhibit L (filed under seal) is the certificate of service for
Attached as Exhibit M is a true and correct copy of my correspondence to

-
Plaintiff’s counsel of May 25, 2016.
15. Attached as Exhibit N is a Notice of Subpoena and Deposition for Sharon
Churcher on June 16, and the certificate of service dated June 4.

Laura A. Menninger
I certify that on June 20, 2016, I electronically served this Declaration Of Laura A.
Menninger In Support Of Defendant’s Response in Opposition to Extending Deadline to
Complete Depositions and Motion for Sanctions for Violations of Rule 45 via ECF on the
following:

mschultz@bsfllp.com
/s/ Nicole Simmons
Nicole Simmons
3
EXHIBIT B
The Billionaire's Playboy Club should've been my first queue to get out of there quick but with no where
to go, and so naive I didn't realize how much worse it could get. Setting
foot into that limo, I made my first entrance into a world that would
By Virginia Roberts
entrap me for many years to come.
He introduced himself immediately as Ron Eppinger, a businessman
To my true love Robbie who believes in me every step of the way and
and owner of a successful modeling agency, called "Perfect IO".
to all of my children, you are all my very inspirations!
Flaunting his oozing wealth by introducing one of his many girlfriends,
the beauty next to him was Yana, a supposed model from the Czech
Chaptert Republic who looked like she could be in her early twenties with the
heavy load of makeup she was wearing, but really was only in her late
Every single person in this shared world together has a unique story of teens. She kissed me on both cheeks and politely said "Hello" in a thick
his or her own to tell, this one is mine. Czech accent, making me feel a little more at ease. Convinced it couldn't
It was coming up to my third night camping out at Miami Beach in the be that bad there was another girl in the car, right? I couldn't be more
summer of 1997. I was thirteen years old and hiding from a world full of wrong.
hurt. Sitting on the shoreline for hours watching the sunset fall deeper What he didn't tell me to begin with was that his modeling agency was
into the horizon, my eyes were glazed over with tears, not from being only posing for an undercover trade. By the time I found out I thought it
wind-whipped by the rough sea breeze, but from reflecting on the abuse I was too late to run. His business was really an illegal immigrant
encountered as a young girl and how everyone in my life who was trafficking ring of young women mostly consisting of underage girls that
supposed to be there for me had now turned their backs on me in he was using as escorts to make him uber rich. Only available to a
abandonment. My fears crept up and the excitement of escaping all of selective clientele costing them anywhere from $1000.00 and over per
them faded now realizing how alone I really was now, and for the hunger hour of erotic entertainment, the girls were trained to fulfill every sexual
that was paining my belly. At this point, with nowhere to go and only desire asked of them, no matter how bizarre the requests might be. The
time to waste, I wiped the tears from my eyes and set out to find an high paid escorts, for Ron's super rich clientele, such as Yana and many
empathetic person that I could manage to get dinner money from. If not, other charismatic beauties would only benefit a fraction of their earnings
it wouldn't have been the first time I had gone hungry for the night. I for themselves, Ron reaping in the majority of the financial rewards and
walked to the nearest bus stop and asked a handful of people for any being they were all illegal immigrants they were further trapped by his
spare change, none of whom that could help me. Sitting down on a enslavement.
nearby curb disappointed in grief of my current state, I put my head into I proceeded to introduce myself, besides what he had found out about
my knees and began to sob. me on the curbside. Telling him my name and a little about how I ended
Out of nowhere, it seemed, a black stretch limousine turned the comer up on the streets explaining that I could take care of myself and didn't
and stopped in front of the curb where I had been hopelessly lost. The need my family or anyone to look after me anymore. Looking back later
back door opened to reveal a heavy weight and balding, old man with a in life I can now admit I was in a terrible state, but being such a
big cheesy smile. Neatly dressed in black trousers and a collared shirt, he headstrong teenager, I refused to give in. He asked my age and I told him
was sitting next to a striking young, blonde girl, drop dead beautiful and I was sixteen at first. He coyly replied, "Are you sure? I think you could
dressed in a foxy red mini dress she looked like a model just stepping off be telling me a fib? How old are you ... really? I wont be mad" Being a
a runway. terrible liar, I knew had been caught out and couldn't deny it any further.
Their smiles greeted me warmly and he kindly asked, "What is such a I told him the truth and he chuckled then paused and answered in a very
sweet little girl like you doing sitting alone on the street looking so serious tone "As long as you never lie to me again I will take you in"
upset?" Shocked from this strangers concern l was hesitant in telling him Right away I pondered to myself what did he mean ... take me in?
the truth. Reluctantly I decided to tell him that I was a runaway, not from He gave the driver the location of our destination and rolled the middle
around here and really hungry. Hoping at most, I would get some money window back up to then tell me a story of how his daughter had passed
for food from him. He instantly displayed a chilling excitement and away seven years ago from a horrific car accident in which four other
offered me to come into his car so we could talk some more. That teens were killed and he has never gotten over it. I reacted with sheer
□ Copyright Protected Material □ Copyright Protected Material

CONFIDENTIAi. GIUFFRE0041J4 CONFIDENTIAi. GIUFFRE004l35
sympathy and gave him my pity, believing this man had a heart. His next name she came up with for me, being I was the youngest one among them
proposal was eerie, he said," If you wanted, I can be your new Daddy. or ever to be brought in by Ron for that matter. It became my new
Someone to take care of you and you'll be my new baby forever" he identity not even worrying to mention my real name to anyone anymore.
stroked my hair such as a caring parent would comfort a scared child. A My identity was no longer important to myself, I wanted to become
part ofme wanted to accept his words and believe he really could feel someone new and "Baby" is who I was.
that way, and then I also considered how hard it was living on the streets. A shocking first impression, the girls were completely nude revealing
In the end I convinced myself this would be the lesser of two evils. their voluptuous young bodies with such a careless ease and others were
The car stopped at a plaza on the water, surrounded by little boutique in just a G-string, similar to the one's Ron had bought me earlier. They
shops, restaurants, and little stalls with items for sale like sunglasses and were all stunning girls and full of life. Charismatic and beautiful, they
costume jewelry. I didn't know what to say or do or how to act, it all were the girls who should be on the front of billboards not selling their
happened so fast I just went along with everything he said, for now. bodies to old crewed men for sex. Doing each other's make-up in front of
We went to a take out restaurant and ate on the waterside, and the mirror and chatting away on the bed with no care in the world, aiming
afterwards he took me to G.A.P Kids co. to dress me in his idea of proper at persuading me to see the highlights of the life Ron gave them and they
attire, tiny cutoff shorts revealing the cusp ofmy buttocks and some shirts almost did. Ron left the room for a few moments, letting us all get to
that barely fit, even the sales assistant was shocked at what she thought know each other a little better and that's when I started to compile an
was my Grandfathers choice in clothing. I couldn't even believe it myself understanding of what really went on here.
only an hour ago I was begging for money living on the streets and now I Just catching a bit of their conversation from before my introduction, I
was dining alfresco and shopping at name brand outlets. We then hit a heard them chatting about the night they were preparing for. Speaking
couple of more specialty stores afterwards. He said he had to buy me a excitedly about some men they would be entertaining in a few hours, one
few more necessities to start with. Lacy G-strings and what looked to me girl was talking about going out to sea with one o these clients on a yacht
like lingerie pieces I had only seen grown women wearing in magazine for a few days. Since none of the girls seemed shy to talk about their
ad's or movies was now a part of my wardrobe, in my mind it was a big professions or anything for that matter, I decided to ask them a few
step up from being a little girl any longer. questions about what they did. They were more than happy to expand on
The driver took us back to Ron's grand apartment overlooking the isle their point of view in the conversation, attempting to paint a pretty picture
of Key Biscayne and a large bridge leading into a Miami Harbor. of what they were paid to do.
Entering his residence, I was blown away by the spectacular view, rich They all began to jump up and down with excitement like giddy school
decor, and white marble floors that were so glossy it looked as if I was girls at a slumber party. Another girl with jet-black hair and a thick
stepping on glass. He took my shopping bags to a large room at the back accent, wearing absolutely nothing at all, grabbed me onto the bed with
of the apartment and put them into a small closet. The room was them and into their fiasco, instantly making me feel accepted into their
considerably large with glass exterior walls that maximized the potential sorority, like I actually belonged somewhere for once. Yana went on to
of the panorama landscape soaking in the seascape of Miami. In the room explain a little more in detail," We accompany the wealthy friends of
was a gigantic round bed raised off the floor by three steps and mirrors on Ron. They want only beautiful girls by their side so we come and act
the ceiling. It looked like a honeymoon suite out of a raunchy hotel. He however they want us too but most importantly we make them think we
then exclaimed, "This is my room here and you will be sharing it with want them back too." Other girls began to jump in with their vivid points
me" When I asked him where I would sleep he then sickly replied "With of view while playing with my hair, they were taking turns brushing and
me silly, where else of course?" With no room for argument I pretended styling it as they were filling my head with all of the prospects I could
to be O.K with everything that my common sense was screaming out in have as an escort too. They made me feel beautiful like them, too
my head to run. beautiful for what a girl beyond my years should feel. I was simply being
Next I was taken down a long hall at the other end of the apartment to lured into a dangerous trap, just like they had been at a young age too.
meet five more exotic beauties. Three girls were in their late teens and the It pretty much all came down to two things in their game, the money
other two in were in their early twenties. All of them were from the they would make and the lifestyle they were given. Their enthusiasm only
Czech, here under false passports provided by Ron and his contacts. Yana interested me further, making it not only sound like an acceptable way of
held my hand while introducing me to the group of girls as "Baby" a pet living but also appearing to keep them all vivaciously satisfied. This way
3 4
□ CopyrightProtectedMaterial □ CopyrightProtectedMaterial
of life was just mind blowing to even comprehend at first. With such a introduced me to his business partner and told to go get dressed. He had
new outlook of the world to try and grasp at my young age I was listening my whole day planned out for me already. Booked into get my hair
to every word spoken to me with such attentiveness, I was going to try colored, a much lighter tint of blonde, and afterwards a day of shopping
and model what l was observing from the girls. l justified their way of with the girls l was becoming exactly what he wanted me too, a carbon
thinking in my head for now, thinking if all these girls seem happy copy of the teenage Barbie ... only I wasn't plastic and came with many
enough, why couldn't l try to be, it was this or the streets for me. benefits.
Ron came back for me not long after our conversation got out of hand Days turned into weeks, being a servant to the sexual desires of this
and took me to a bathroom down the hall. He opened the tap and filled a distorted pervert. I dreamt of escaping but where would I go and how
small plastic cup with water and handed me two small blue oval pills. would I get away from Ron with him controlling my every second ofmy
Telling me to take them both as they would help me to relax a little bit day. Separating myself from the other girls being so uncomfortable with
more. I swallowed the pills just following his orders. I put the cup on the enduring the everyday occurrences I was longing for the solitude of the
counter top and turned back around to face him. Backing me up against beach again. They were training me up to be an escort prodigy or
the wall and now cornered by this large man I felt his slithering hands something like it. Outrageous orgies were conducted as my lessons with
began to creep under my shirt, writhing my skin. I closed my eyes tightly the girls teaching me all of their tricks in the game, it was all for the sake
and turned my head away from him, hoping he would take my actions as of men's perverted fantasies, they didn't get anything from being sexually
a sign of being extremely uncomfortable but that wouldn't bother him at exploited and molesting each other, except getting paid for it. Everything
all. He was half enjoying my reaction from the smug look on his face, from oral sex too penetration with toys, I was expected to not only to join
and persisted through it. in but even perform ludicrous acts of hedonism.
Continuing to undress my clothes he said he wanted to look me over I was Thirteen years old and had never heard the terminology of these
and clean me up. It was so humiliating having to expose myself to this sexual acts before, and definitely shouldn't have been learning them first
ageing man and now I knew he was going to end up with his hands and hand. Thrown into a world of chaos, I didn't know what to do except be
whatever else all over me. All too soon I hated to be right, as I stood as compliant as possible, even when asked to do the most deb'fading
naked before his widened eyes, he told me "you're a hairy bugger I'll tasks. The excitement of the lifestyle he offered quickly diminished once
have to shave you right up young lady", and I didn't know he wasn't just I had to pay so dearly for it. The girls that subdued to this lifestyle and
talking about my legs. Standing with my legs wide apart while this man enjoyed it definitely put on a good act, but no little girl with hopes and
coaxed me through the entire ordeal of shaving, his hands made me feel dreams of their untainted future, turns to her mother and say's "one day I
so dirty. "Havel lost my mind?" l thought to myself but l had to play dream of being a prostitute, passed around from man to man, only to
nice until l had an opportunity to get away, this was not as fun as the girls grow older regretting so much of my life" It was all a part of an illusion
made it out to be after all, this was utterly disgusting. l had no idea what that Ron painted for us that made it seem so alluring in the first place.
was going to happen next with this guy, and due to whatever Spending my days with Ron, he took advantage at every chance given.
pharmaceuticals he gave me, I still don't know to this day. Even in his convertible with the top down I would be forced to go topless
Waking up the next morning my head was pounding in an agonizing while he drove around, when I asked him why one day, it was supposedly
thumping pain and I was so thirsty. The satin sheets thankfully covered so I could maintain an even suntan, but I knew it was his way of showing
my body, which was still nude from the night before, and I could hear off his treasures. It was a far cry from the simple country life I had been
hushed voices standing over the bed where I was pretending to still be raised in. Wearing designer miniskirts and tops that always revealed too
asleep. Listening in on their conversation I kept my eyes shut. I knew much, of course due to Ron and the girls determining everything I wore,
Ron's voice from two of the men but not recognizing the other guys I just ate, or spoke. We would spend our days at hair laser clinics, shopping,
stayed quiet hoping they'd soon leave. Ron was telling the other man tanning beds, and eating as little as possible. Through the nights we were
what atrocities he got up to the night before with me and l heard him say, expected to become party animals and greet Ron's clientele with the
"Doesn't she even look like an angel the way she sleeps? She's my own upmost flirtatious attention and doting as possible. Then whether we were
little angel!" He exclaimed proudly. l opened my eyes and rolled over to out for dinner, at a party, or at a club, the men would choose his girl and
face them both having to wrap the sheets over my body, really not take her home. Every girl had a different price and so did the charges
knowing what to say except "Good-morning" in a blushful tone. Ron depending on the various clienteles but Ron always kept me for himself.
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I would always dread the end of every night, fearing what new desires his tight clutches, crying myself all the way to sleep. He didn't even ask
he had in-store for the evening. Sometimes he would hurt me and tell me me what was wrong, probably because he knew already.
to try and enjoy it then do it over and over again until I gave him exactly Soon enough the crumbling of his evil empire in the underworld of
what he wanted, I always resisted until I could no more, he was too selling sex for his own advantage began with a single crack in his perfect
overpowering and relentless at getting the results he wanted. At other scheme, and proudly it all started with me. Ron got a scare one-day and
times he could be so gentle and caress my skin, worshiping every inch of rampaged through his apartment telling us girls to only pack our
my body, all relying upon on what mood he was in. Often though he liked important belongings and some clothes as we all had to leave right away.
to play the teacher role and instruct me on every motion and explain what I didn't have much belonging to me so I basically sat there watching
would happen when I did those certain things to him. No matter what he everyone rush around frantically and was curious what could've gotten a
did to me I was only disgusted with myself more and more. I still shudder man like Ron so scarred. Once we were packed up and in the limo he was
at the thought of how he used my body. trying to calm the frantic girls down after all the panic that spread through
I turned fourteen in Aub'l!Stthat same year and was spending my the apartment like wildfire, I was the only one sitting there half amused at
birthday loaded on a concoction ofphannaceuticals and alcohol, being the entire situation.
generously supplied by the very man who swore his devotion to caring He began by assuring us that everything was going to be fine. Calmly
for my every need. I didn't even know myself any longer, completely he continued to tell all ofus packed in tightly, even for a limo, that we
shying away from the girl I had grown up to be until to this point. The were all taking a long trip to Florida's countryside because someone has
apartment was empty except for me, for the time being, and that was reported an anonymous tip to the missing persons unit at the local police
God's own little present for me ... some solitude for once I thought. station identifying a very young girl as a possible victim of abuse living
Pouring myself another drink I opened the sliding glass doors to the at his apartment. Ron knew what a landmine of trouble he had brought
balcony and walked to the edge. Looking down from the many stories upon himself making an exhibition out of me on the streets of Miami, I
where Ron's apartment was, I wished myself a happy birthday out loud didn't pull off the older look like the other girls, I actually looked
and wondered ifmy family even remembered the day's occurrence. younger than my age with my blue eyes and freckles always giving the
Dwelling in my sadness for the fourteen years of suffering and impression ofmy youthful innocence.
loneliness I had already endured, the tears swelled up in my eyes, Now he just had to do whatever it took to ensure he stayed as far away
trickling downwards making my eyeliner inevitably leak down my from the authorities as possible. Arriving at a ranch in central Florida
cheeks. Inside I felt so trapped and began to entertain the thought of many hours later and I assumed it belonged to Ron knowing never to ask
jumping over the edge, it all seemed much easier, and the simple him things like that. I knew my purpose and it wasn't prying into his
blackness that death had to offer rather than the tangled mess I was so personal life outside of the bedroom. There was a main house, a few
tired of fighting to get out of seemed a much easier approach. Detached cottages, some staff quarters and paddocks where the horses were kept. I
from wanting to feel anything, I became so numb towards my life's own was in heaven .. .I thought at first. Finally, something I could really enjoy.
tragedies. I couldn't live like this any longer. I lifted my bare legs over Riding was my passion, basically growing up on the backs of horses since
the edge of the railing and sat looking at the ground beneath me so close I was just able to walk.
to even just slipping off the edge to my very death. I couldn't think of any Not surprisingly I began to despise Ron and all of the girls for the
reason not to fall. I thought I had made too many bad decisions to keep gross exploits they made me do with them. Beginning to isolate myself
going on but some force of a higher nature had other things in store for from everyone I'd rather spend my time sitting under a tree watching the
me. horses graze, writing in my journal or painting but mostly avoiding
The sliding door slammed open with a burst of speed and Ron scooped everyone possible unless Ron required me elsewhere. Nighttime was
me up in his big arms and brought me inside to our bedroom. Laying me always a reoccurring nightmare for me. Relived over and over again in
down and seeing the look of despair in my eyes from my tear stained face many various ways. Ron would always start by making me some drinks
he went into the bathroom cupboard and returned with three pink pills. and offering an assortment of pills before indulging himself by
Forcing me to swallow them using the angered tone of his voice he grotesquely putting his genitals in my mouth and tell me how to give him
thought he was turning my sorrows into a distant dream as I passed out in what he would call a "first-class blow-job", and I was being judged every
minute of it. Ordering me to slowdown or speedup or maintain a perfect
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rhythm I was constantly being criticized for my efforts in pleasing him. I the phone were nothing short of desperate plea to keep me on as long as
was eager when he actually gave me a compliment. The rest of the possible. I thought he was just trying to help in someway. Giving him
evening was always a surprise left up to a moments notice. Quite assurance in the fact I had survived this long obviously I can hold off a
regularly he would proceed with having the girls dress me up in some while longer I gave him my love and told him I'd be in touch.
sexy outfit and loads of makeup then entertain him with a lesbian Thinking I had slipped away unnoticed I entered into the room that I
reenactment revolving him in the center. Sometimes they would use shared with Ron, hoping I got away with my brief and very needed phone
dildos and other foreign sex toys, Ron liked to see us hurt during sex, call. The place looked empty and everyone else seemed to be out and
sometimes even penetrating me anally but I always resisted and would try about so I decided to have a bath in the spa and try to relax before the
to redirect him with another sexual desire of his but I had no excuses night's precautions. My body glided into the steamy water as I began to
when it came to me having to use the sex toys on him, he told me how think about T.J and how good it felt just to hear from a friendly voice. My
men have g-spots in their rectum and instructed me on how to precisely thoughts drifted into the days I missed when I felt I could be silly and
penetrate him. These nights went on what seemed like an eternal sentence childlike and I nearly forgot for a moment how grown up I was acting
for the price ofnot living on the streets, where unfortunately for the one's these days.
still there, I feared and knew from my own personal experience, could be My first glimpse at the image surrounding me when I resurfaced above
much worse. the water was daunting. There was Ron was standing over my tub,
Needing some contact with someone ofmy adolescent mentality I looking down at me with an eager display of his arousal. He began to
called one ofmy school friends from the past, whom I wont name out of undo his pants and take them down when he told me "put your lips on my
privacy, but I'll call him T.J. We were so close and I knew very well, so cock", I was too slow in responding to his request so he grabbed me by
well, I had memorized his number a long time before. He was my first the back of the head and forced me into his groin. I had tears streaming
puppy love sprung from of a childhood friendship. Being my very first down my face as I looked up to him with the saddest blue eyes hoping he
crush the summer before all of this happened he was the only person I would take pity and stop, but he never did. I was really hurt by his
could think of that would care enough to talk to me. aggression and he definitely knew it this time, which I believe only made
In the middle of the day, the least busy time to be noticed, I snuck into him more heated. I closed my eyes and began to count using the time to
one of the vacant guest rooms and used the phone to call my good friend. keep my thoughts elsewhere believing every number I counted only
The sound ofmy voice radiated a chill in him. "It's you, oh my God furthered me to the end of this. I just got over a hundred when he finally
Jenna! Are you okay?" he was so shocked to hear from me and the sheer exploded in fulfillment still half submerged in the deep bath I was
fact I was still alive. Nearly three months now without a single word to struggling to gain my bearings in as Ron was picked me up out of the
my family or friends, every one doubted my return. My attempt to forge a bath and carried me to go to the bedroom, which was just outside the
happy voice when I spoke to him failed and I absolutely crumbled when French adjoin doors. Still damp from the hot water in the spa I had goose
he was at a loss for kind words for me. I told him ofmy current state of bumps from the chill of the fresh air where he brought me to the bed and
affairs. Telling him of Ron and how I was terrified of him, trying to proceeded to deeply violate my every being. Eventually his scars that he
escape in the middle of nowhere was useless. It was like being kept in left were too deep ever to be healed and would even carry on through the
cage that I was unable to break free from. Going on to dump my issues on years to come.
T.J, I proceeded with how I longed to call my family and to be with my Upon his bursting with pleasure for the second time, he just got up
them for good but was too afraid they didn't want me, knowing I'd just and left, without even saying a word to me. Left alone I was awake for
be sent away somewhere else again and to me after all this time was like hours after that. There was no escaping the pain that night. I lay naked
going from one cage to another. wrapped in the sheets, sobbing in the dark. My feelings of being hurt and
He had been called by them numerously and promised me that they disgusted after his abusive ordeal "When will it ever stop" I prayed to
were very worried and even hired private investigators to try and find me. God and begged for death rather than face another day in my life. I woke
Given I was eleven years old the first time I was sent away, my trust in up still alone the next day and exasperated from the misery I felt the night
there sincerity he spoke about was seriously doubted. I kept the before. Ushering through my drawers to find something to throw on I
conversation short just in case my absence was being noticed and I left on could care less what lay in store for me today, couldn't be as bad as being
the note that I would speak to him again shortly. His attempts to get off raped by a scary man repeatedly.
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Starting my day with a few of the supplied oxytocin 'sand a bloody them that the confession came from the house-keeper who said she saw
mary, made by the live-in house chef. Having two celery sticks for my me use the room regularly but was never messed up, so Ron looked at the
breakfast, I wanted to lye out by the pool and forget the world. Ron hated recent telephone bills and found the same number dialed from that room
tan-lines so to be caught with a bikini top on was a big no-no in his rule consecutively, he knew it was me right away. At least he didn't know it
book but after my cries to stop were so blatantly ignored last night, I was was another guy, I thought to myselt~ or I probably wouldn't have made it
out to piss him off so I didn't remove my shirt. I put on my headphones out of there alive.
and before I knew it had fallen into a deep slumber from my self-made Ron came back to usher the girls out of my room and told me I had five
therapeutic cocktail, the only way I knew how to cope with the emotional minutes to pack my clothes, which he made clear were to be my only
turmoil on the inside. belongings to take with me. He washed his hands clean ofme that night,
Desperate to hear his voice I called my friend T.J a few more times that or so he thought. The driver came knocking at my door, just as Ron said,
week. I needed to feel like someone out there really knew me. Sometimes no longer than the five minutes that he had offered me and he took my
we could just chat like old friends with no care in the world and laugh at single bag to the car. I didn't want all the jewelry, music or books that he
a distant memory from too long ago. Then would come the good-bye part so caringly bought me as tokens of his twisted affection. Only taking my
of the conversation and we would both get teary-eyed not knowing what clothes and a wad of hundred dollar bills I had been saving, I slit a hole in
could happen next or if this would even be the last time we ever spoke to my scrunchie inserting my cash for a rainy day that I was more than sure
each other again. was just around the comer. .
My biggest fear came to reality when I was in our bedroom one We drove for hours, until I started seeing familiar surroundings. I
afternoon, just lounging around out of boredom. Ron came bursting in couldn't believe my own eyes. I was back in Miami, but not on the
through the door, red as a tomato. I couldn't help but feeling I was in big beaches, somewhere in the CBD this time. The Driver delivered me to the
trouble. His face was distorted and raging towards me. I knew right away front door with my one bag and waited at the door with me. Now I knew
he must have found out that I was calling T.J, but how, I had no idea. I how it felt to be a puppy picked from her litter as you can only hope your
had always tried to be as invisible as possible, soon enough it was all next owner would treat you with some sort of kindness.
explained. Another balding man answered the door but he wasn't so grotesquely
"Are you trying to get me caught? You are nothing but a stupid girl fat like Ron, but still a new owner at that. He looked me up and down and
you know that! What am I supposed to do with you now?" He was seemed amused as he snickered to himself. With one last look to the
tearing up the room while his rants gave me something else to think driver over my shoulder it was almost an appeal to him for some way to
about. What would he do with me if he had no use for me any longer? I help me. 1 knew he couldn't anyways, I was just hoping. He told me his
wasn't even thinking about him being caught for soliciting illegal name was Charlie but didn't even bother in asking me for mine. I was
immigrants for the purpose of prostitution. I was more worried that he sure Ron already filled in all ofmy details when he arranged this.
would be upset at the fact I was talking to another guy, maybe even Charlie picked up my bag and led me into his bachelor pad townhouse.
jealous that he was at least my age. I replied with simple sentences that I I was never given a welcoming tour of my new residence or made to feel
could manage to get out between all the shouting. I kept saying, "I'm comfortable. He walked me up the stairs and opened one of the doors in
sorry" and putting my head down in shame. He picked me up by my the small hallway. Telling me this would be my room, he showed me into
throat pinning me against the wall, "You are going away, far -far away it and told me to wait, he would be back shortly. I sat on my bed afraid to
from me and you better be nicer to the next man I send you to, I've heard touch anything and after the warning Ron gave me I knew I had to watch
he's not a nice as most would like. Are you fucking hearing me Bitch?" I my step around here. I put my head down onto the pillows my where
slid down the wall, choking on the first air entering my lungs, breathless world was falling apart and let my emotions downpour. Exhausted from
and terrified, I never thought Ron was a nice guy but I had never seen the days emotional turmoil I ended up falling asleep. I don't even know if
him lose it this bad. Now I was being sent me away to another stranger, he ever came in at all that night.
another man, it only terrified me more. The next morning I looked out of the window to see my new
The girls came in to say their good-byes all of them were crying and surroundings. It was a beautiful sunny day outside, unlike the dreary cell
asking me in their best English languages, why I had to call someone and I was locked away inside of. Feeling the sun warm up my face through
lose everything? I was able to find out through the broken sobs off of the glass, it radiated a familiar sense of comfort from the days of the good
11 12
parts ofmy childhood. 1 reminisced how it had used to be before all my knew what I had to do to get this over and done with as quick as possible,
life turned upside down. Before all of the fights with my family, before I but I was dreading this moment from the second he greeted me at the
had to look after myself, and before I was a slave to men. door last night.
Those days were too long gone now. With too many hard times passing I fell to my knees and gave into his demented perversions. Thankfully
me by it seemed surreal to think that life had ever even existed in the first it didn't last long before he climaxed and I was allowed to get myself
place. With that thought I shook myself out of reminiscing that way. dressed and ready to go out. I was nothing but money well spent in his
Whatever was going to happen was out ofmy control now, I just had to mind. This was another extremely wealthy man with a completely new
give myself some hope that I would have the strength to get myself out set of wants and needs asking a fourteen year old girl to affectionately
these circumstances before anything really bad happened. dote on sexual desires to a man in his mid forties. I really hated myself,
these men, and just about everything my life had boiled up to by this
point, but I knew from a young age that to survive in this harsh world I
Chapter 2 would have to do many things I would not willingly choose to.
At the shops he decided he would choose the clothes he paid for, which
I might as well have been declared a teenage prostitute. Just like Ron he
The house was quiet so I just assumed Charlie was still asleep. I
also liked it that way. The more degrading he was to me only proved his
decided to get cleaned up and have a shower. Not even a knock on the
door when Charlie walked in with ease. "Typical" I thought. It was an ownership ofmy body. He bought me tiny cocktail dresses, and skimpy
outfits, which I thought closely, resembled the lingerie he'd also bought
easy way for Charlie to break the ice. "You really are as beautiful as Ron
said" as he opened the curtain. Watching me rinse myself in the shower for me to wear for him. I noticed that day that he enjoyed parading me
and me knowing I had no way out of this except to go along with around the shopping mall and out for lunch at hooters, even joking with
the waitress that he'd like to buy her uniform because he thought it'd look
whatever he wanted. I just looked down at the mention of Ron's name,
sexy on his new girlfriend.
wondering what else he had told Charlie about me. Realizing later that he
wouldn't have said anything anyways, in fear I would've been a damaged We arrived at his two in one, Restaurant and Club, at around nine
o'clock in the evening. It was a revolving tower called "Hot Chocolates"
product that wouldn't make him the money that young girls go for.
in downtown Ft. Lauderdale. The food was delicious and for the first time
He just sat on the side of the vanity top and continued to take
since being with Ron, I ordered a hefty meal with steak and mashed
observations ofme standing submerged under the falling water. I avoided
potatoes with a scrumptious gravy smothered on top. Charlie ordered
looking at him and let him do all the talking, after all I knew what I had
strong cocktails for us both and before 1 knew it my head was spinning
to say was ofno importance, that is ifhe was anything like Ron. Between
and we were on the dance floor together. The music blared in my head
the water beating down over my head I could slightly hear him ramble on
and the rhythm ofmy body took over, completely forgetting about even
about some club and restaurant he owned in FT. Lauderdale. He said he
was going to take me shopping for some club outfits and we would party dancing with Charlie and letting the music take ahold and work it's
together tonight, as if I was supposed to be excited over this so-called magic.
treat of his.
It didn't do me any justice though as Charlie watched me imagining
I looked up and gave him a quick smile adding a compliant nod and what pleasures lay in store for him later on. Taking me home before the
club had even closed, he just couldn't wait to indulge on exactly what he
turned my attention to turning off the faucets and quickly i,rrabbingmy
towel. I was falling so far from who I used to be, shying away from my was fantasizing from beforehand. Once back at his townhouse he led me
up the stairs into his bedroom and pushed me down in the middle of his
outgoing personality to a quiet girl that didn't even recognize herself in
bed. The motions from the wavy mattress made me dizzy and feel even
the mirror anymore. I dried myself off and looked at the man standing
drunker when he lay on top of me. Coming at me like a hungered beast
between the doorway and me. He was still watching me with a sleazy
wanting to ravage his next meal, it was intimidating as he entered into me
look on his face but now preceded to move in my direction, arms wide
with a forceful thrust, he moaned out in delectable heaves. I looked away
open. He embraced me, running his hands up around my youthful curves,
while he self indulged his own gratifying needs using my body as his
licking my neck and earlobes. Then his large, rough hands cupped my
instrument in pleasure. I only grew stronger in my head letting the hatred
small breasts and continued downwards to feel in between my legs. I
for men desires intensify.
13 14
The next two weeks I was expected to be at Charlie's beckon call, never at first. I couldn't even comprehend what was happening so rapidly. I
aloud to leave his side, even making me sleep in his bed from the second thought Charlie could've been in some kind of trouble with a business
night onwards. I never even got the chance to call T.J again. It was too friend he had done wrong too, but then one of the men in black shouted
much ofa risk anyways. Thus pushing him further out ofmy memory, "F.B.I this is a raid get down with your hands on you head", in too much
too afraid, of the emotional repercussions. shock to move three of the men grabbed Charlie and threw him to the
Our typical routine was to wake up get showered and dressed and I floor and cuffed him. I sat up in bed with my sheets covering my naked
would put on my make-up while Charlie made his business calls for the body and watched as they dragged Charlie from the room. Still
day. We would leave the house mid-afternoon and run his errands do completely nude he wasn't even aloud to get dressed. Another agent had
some shopping, sometimes meeting his friends or business partners for to come back in to the room to find him a pair of shorts. I could hear him
lunch, none of the men he introduced me to seemed offended at his screaming at the top of his lungs all of the way outside He was screaming
choice of adolescent eye candy. They'd just continue to chat away as ifit and the last thing I heard him yell was "Tfyou say anything you know
was normal to be in public with his arms draped over a girl young enough who will find you!" I could hear more threats being yelled at me but I
to be his granddaughter, not too shy by giving me a flirty tap on my couldn't make out what it was that he was saying. I was in total confusion
bottom or even try to kiss me. and couldn't believe what was happening. There were so many uniformed
My last night was no different from every other night. We went agents I felt so small compared to all of them but they were all very kind
shopping that day and out for lunch alone. Later we headed to a club his and helped me out of bed allowing me to remain covered up with the bed
friend just launched and it was his grand opening that night. The club was sheets so I could get dressed. The first decency I had been showed in a
called "Iguana Joe's". We met up with his friend and said our hellos. long time. It was an odd feeling to acknowledge. I knew the life I had
They both seemed so excited about the club and Charlie was full of come accustomed to for the last six months was now over, and in so
compliments all around. The club did have a line out the door which many ways I was relieved but was also very nervous about what lay
looked a mile long coming in, luckily we didn't have to use the front ahead of me.
door. Charlie returned from the bar with two giant long-island iced teas, I excused myself to the bathroom to put some clothes on. Not having
which were his favorite drink to start with and then we just sat for a while anything half decent, like a normal pair of jeans and at-shirt. The best I
watching people dancing. Occasionally conversing about passing could come up with was a metallic blue miniskirt and a tiny matching top
thoughts. We danced for a while having a few more drinks and after that fell just below my breasts, hardly clothing at all it was more like
about two hours, Charlie said he was ready to go home. What a daunting scraps of cloth. Putting my hair up in a tight bun with the scrunchie that
time to look forward to, he always liked to have a brief sexual encounter held my five hundred dollar bills I was led out of Charlie's townhouse for
before drifting off to sleep with my naked body intertwined between his the very last time. Starting my life over. .. again, I wanted to leave behind
arms and legs. my every memory belonging to these horrid times. Only taking small
It was bad enough to have to entertain him at every given second of the sack containing my underwear, makeup bag, and journal with me.
day but his grip on me was so stifling I felt so chocked I could hardly The agents led me down the staircase and my last vision's of Charlie
breathe much less sleep. Eventually my over-worked mind would drift in- was bent over the hood of a police vehicle still screaming and
and-out of a restless sleep, but constantly on edge. I thought many of handcuffed. I slipped into the backseat of the car and was driven to
nights of escaping, but where would T go? Would one of Ron's ever-so- Broward County Police Station where the Federal Agents interviewed me
connected informants finds me and turns me into him to be disposed of about my entire whereabouts for the last six months. I was so scared of
for good? I just prayed that I wouldn't be another missing person to add what Ron would do ifl told the agents what really happened but at the
to the list of girls found in the local ditches. I knew that's where I was same token I knew he'd most likely kill me anyways for being such a
headed if I screwed this up for Ron again. liability.
As if my !,'llardian angel was there the whole time listening to my Over the next few hours I sat down and told the agents how Ron's
secret prayers, my rescue came the next morning with an abrupt bursting business worked and what I part I had to play to him. I was able to ask
through the bedroom door at about six am. Charlie and I were still lying how they found out I was at Charlie's house and they informed me that I
in bed together and his grip on me was still tight. The men dressed in all was being followed all the way from Ocala, Florida where Ron had me
black military gear had large guns and helmets on. It was so frightening stowed away for the last four months. T .J, my friend, called my parents
15 16
after our first phone conversation and ever since then, the F .B.l were whole life they ended up repeating the same attributes as the people who
tapping the phone lines and recording every conversation. Completely initially hurt them in the first place.
unaware of T.J's caring act of deceit, Twas in such shock that they had One very sad girl I'll never forget her, had a father who had been a
been tracking us for so long. I knew now, with or without my help, the heroine junkie and decided to play Russian Roulette with some of his
F.B.Thad enough on Ron to put him away for a very long time, if they addict friends and by fate or chance took the bullet straight through his
could catch him, that is. brain, killing him instantly. Her mother being a heroine addict herself
Having so many crooked people working for you can be an advantage spiraled downwards after his death and gave her four year old child to her
when you're in trouble. Like having a pair of eyes in every city. Ron was ageing grandmother that eventually had to put my twelve year old friend
somehow able to find out about Charlie's arrest and immediately deserted in this un-dire circumstance. I can only have he highest hopes for her
the country to avoid legal punishment, not to mention the discretization today but unfortunately for most girls that have been victimized by
of his esteemed clientele that the feds were now on to. Ron had so many society aren't able to ever stop being a victim for the rest of their lives or
countless charges put up against him, eventually when the F.B.I were go on to make other people victims themselves. A sad and unfortunate
able to track him down they were able to have him arrested in Yugoslavia fate for so many innocent, and it happens so much more than anyone
and extradited back to Miami, he was finally held accountable for being a would rather admit too instead of just trying to find a solution.
pedophile, soliciting women for prostitution, and running many
illegitimate and illegal businesses. By the time the F.B.I caught him he Chapter 3
was in his mid-seventies when he died of old age serving his second year
prison for a lengthy sentence. Coincidentally I was told of his punishment Hours later I was still twirling myself in the same office chair when I
and death many years later by one of the same F .B.l agents that had spun around to see my Father walking in my direction. Tnearly fell off
rescued me from Charlie's arms. my seat at the sight of him. Gripping the chairs handles I couldn't
Twas taken out of the interrogation room after the interview was over
imagine what in the world Twould say to the man Tonce used to call
with and told to sit at one of the officer's desk while I was waiting for Daddy but now hated for the abandonment and unforgiving wounds he
someone to pick me up. Uncertain of who that someone would be I instilled inside ofme. He contemplated putting his arms out to hold me
assumed it would be someone from the juvenile delinquents division to but instead anger and shame took over and he just shook his head. Tnever
take me back to some state operated !ockdown facility. Not the nicest of saw my Dad cry until that day and I have to say it made me feel young
places to call home, but T had no choice in this matter. again and sad I had disappointed my parents again. The agents now
Sitting back in the revolving chair I was twirling out of boredom and standing beside us led both of us together back into the interrogation
listening to the roaming conversations within the office. I pondered in room to re-tale my journey to my father who they said I had no choice to
fearful anticipation of the dreadful places that lay in store for me. Having tell, or they would have to tell him for me, being I was an under-aged
to of spent a lot of my adolescence in these kind of places for the sheer minor and Ron violated the statutory rape law, among many others, when
factor that my mother said "I was out of control and unable to handle" by
he took me back to his apartment and kept me as his sex slave. My Dad
eleven years old. There was plenty of just reason for me to be so scared of couldn't believe what he was hearing and for his lack of better choice in
those places. What I knew lay in store for me were constant fights words asked me to stop talking, he was just happy to know Twas alive.
between the rough girls being settled with violent raids then out came the
Like everyone I'd known in life they would rather brush it under the
pepper spray and then the strip-searches and worst of all, no sunlight. It carpet and not deal with the pain rather than realizing sooner or later it all
didn't matter if you were a quiet, shy girl that didn't belong there, when comes out sometime in our life even ifit transgresses into our future then
there was a fight, which was could be like a few times a week, every becomes what we are willing to accept out of partners, work, and people
person in the room was considered a threat and were treated like a violent in general. Simply saying in other ways than with words that our bad
criminal. I hated those places and the memories they gave me. That's decisions befall our tragedies later on in life.
why I always ended up back on the streets. No child or even a juvenile The next discussion was led to where I would go to from here. Before
should have to be subjected to such unreasonable force and neglect. Some anyone could put his or her suggestion forward I leapt in with my two
of the girls were so used to being subdued to this kind of treatment their
bits and made it obviously clear to my Dad that if I was sent away to
17 18
CONFIDENTIAi. GIUFFRE004 I 50 CONFIDENTIAi. GIUFFRE004l 51
another lockdown facility and ifhe betrayed my trust, again, he would conformity and unwilling to participate in their drilling regime. I didn't
never see me again. I would disappear for good this time and for all he feel like I owed any explanation to these people even when they brought
would know I could be dead in no time on the streets. He looked at me a physiologist in to speak with me, "What was the point when I would be
and for the first time in my life he saw the many years I had grown up in gone any day now" and as if any of these people even cared in the first
the time I was gone and heard the seriousness in the tone ofmy voice place, I was just another number in the system and they had a job to do.
when I made my vow to him. He put his head in his hands and told me There was one mega-bitch, female guard, named Evelyn and she used
the bad news, my Mom didn't want me to come home and she was to either really like you or really hate you and God-forbid you were one
making his life hell for even suggesting bringing me back into their lives. of the unfortunates that she didn't like, she'd make your entire stay their
I for some reason threatened her lifestyle and drove her crazy. I had been an agonizing nightmare. Constantly picking on girls who were not strong
surprised about a lot of things lately but not that one. The last time I saw enough to cope with their predicament or past issues, she'd stand them up
my Mom she ever so carefully lied to me and told me she was bringing and publicly humiliate them, and even when they begged her through
me to an eye-doctor for an infection. Instead we walked into this tall blue their sobs to let them sit down, she'd only torment them worse. Which
building with people in uniforms holding clipboards and a few muscly only made the strong girls want to antagonize the fragile one's with more
guards, she ushered me inside and hurried up to close the large auto lock malicious intent. Luckily when I had previously been there she didn't
doors behind her leaving me there alone and imprisoned, which is what take much notice ofme, but I stayed out of harms way with her,just
led me to recently living on the streets. My life was hell as long as she being quiet and observant.
was in control of it, so when she didn't want me back at home I was fine Being back here seemed like an eternity while I held my end of the
with that too, but there had to be somewhere else I could go. My dad said bargain but unfortunately my Father didn't. The first chance I saw to run
he had no choice but to put me back into the facility, but he made a I took it. I was being sent to go get my blood and urine taken for drug and
sincere promise that he would not take any longer than a week to try to disease analysis. My driver would be a volunteer from the community
find a place for me to stay and to go to school. A week I could deal with, and it was the perfect getaway for me. r was brought from the white
but I was still unsure ifl could trust my father and hold him to his word, solitaire room and led into the bright sun, feeling like today would be
but yet again, I had no choice. Being my legal guardian he could send me favorable in my escape. We got to the doctors office, my whereabouts
anywhere he wanted and there would be nothing I could do, except for told me I had plenty of ways to run and I scouted out the best looking
keep running. I gave in, and before he left the officers to take me back to route. My plan was to barge through the volunteer's inexperienced grip
the last facility I had run from, I gave him one last hug and reminded him and wriggle my way out if needed, then hit the asphalt, running until my
"one-week and I'm gone". Nodding his head and squeezing his arms legs couldn't carry me any further. Playing it out in my mind felt
tighter around me, I could only hope he meant it, but he didn't look too different to the anticipation that led up to actually doing it. The inner-
optimistic. strength I had was the only thing going to help me in this circumstance.
In the police car on the way back to the facility they had to handcuff me We arrived in the parking lot and I hadn't said a word to him the entire
in case I ran again, but I had no intentions to anyways. I was going to drive, the small framed Spanish man tried to make pleasant conversation
give my dad the week before I began to search for the right opportunity to but I couldn't see him as anything but a challenge, so I kept quiet instead,
jolt again. I was like a "ghost come back," said so many ofmy girlfriends i1:,'Iloringhis humorous attempts to befriend me. The car pulled to a stop
from the past and there was now a lot of new faces there too. At night and he came around the side to unlock my door, this was it, "here we go"
when we were all in bed and supposed to be sleeping, I would be I told myself, and pushed past the volunteer. His arms grabbed out at me
daydreaming of better days and imagine myself somewhere in a but only caught me by my shirt, he didn't even put up much of a struggle,
comfortable bed, actually enjoying my life for a change. A week went by like some of the other trained one's I had gotten before, they would put
in this facility spending most of my days locked up in what they called me into body locks of all sorts but he just tore at the collar of my shirt
"The White Room", a bare room with concrete flooring, no toilet or even letting me break free. I had done this many times before so I knew I
a chair to sit on. The only comfort I had was the blue sweater that was wasn't gone yet, I had to first get out of these clothes. The cops would be
provided as part of the uniform, and my hair scrunchie filled with my looking for someone of my description in the area with a blue shirt and
stowed away cash that no one had found during my unpleasant strip- khaki pants, so my first stop was a busy shopping complex. I took the
searches. I would spend hours in the white room for objecting to their money from my scrunchie and bought myself a pair of jeans, a shirt, and
19 20
a sweater for disguise and my next stop was Dunkin Doughnuts' to get a waited for me to come find her outback smoking cigarettes and having a
chocolate iced doughnut and a cup of coffee. I didn't have doubts about beer. She stood up from her seat and squinted her eyes loathing in her
getting out of the facility but I wasn't expecting it to be so easy this time. hatred she coldly slapped me hard in the face. The slap stung, but I
My past excursions all began with an abrupt struggle sometimes ending matched her look with a familiar stone-coldness that only she could
in a brutal state of affairs after being pepper sprayed and fastened into understand. Immediately we both started to cry and we washed away our
some painful lock by forceful men four- times my size, then tossed into anguish and resentment through our tears and consolidated our feelings
solitary until I saw my next chance to desert. I got to know the guards for the first time since the chaos first affected our lives. She didn't want
real well, as I spent a lot ofmy time being dragged down to the white to know much ofmy whereabouts and she still had a lot of anger to get
room by them. There was Jim, a large black man who could've doubled over but she asked me to stay home at least. My little brother ran through
for a "Miami Dolphin's" defensive linebacker. John was another big man the back door and hugged me so tight, I started to cry again and was
with a ponytail and a mustache, and he looked like someone who saddened by how much time I had missed the time I had lost just hanging
definitely owned a Harley. The last guy Scott had a smaller build but out with my brothers and it took me even longer to realize how precious
made up for it with his steroid injected muscles bulging out of his neck time really is. We were never going to be the average Joes next door but
and their was the added height from his curly fro. When they weren't at least this was better than nothing. I loved being with my family again.
restraining me and holding me captive in solitaire, they were actually We had BBQ's and hon-fires with each other and life began to slowly
pretty nice guys, not afraid to have a laugh after some explosive incident piece back together. It was bizarre how normal it was when I first got
and I held no contempt towards them either, they were just doing their home. I turned fifteen that year and it was the exact cup of tea that I had
jobs. needed to boost me up and get me on the right track.
It was de'ja'vous all over again, free at last but where would I go now. I decided to go school to acquire my general education diploma or G.E.D
With Ron's scouts on the lookout for me, and now the authorities being and got a summer job with my Dad at Mar-A-Lago, Donald Trumps
notified I was a runaway again, I would have a lot of people searching for exclusive country club in Palm Beach. Surrounded by lush acres of
me, so I knew I had to be careful where I went. My last stop before tropical landscapes, manicured gardens, and a mansion made into a beach
leaving the shopping center was to use a payphone to call my parents, my club for the rich and famous it is known as the "Jewel of Palm Beach". I
Dad answered completely surprised to hear me on the other end, I wanted was in sheer awe at the gold arched ceilings and the grandeur ballrooms.
to sarcastically thank him for breaking his promise to me and I hope he is The spa where I worked was world class, not only oozing in style but in
happy now, he just lost his daughter for good. I stopped to listen to what the way each and every clientele was treated with the upmost service. My
he was trying to say and he told me "I was getting you out in a few days, focus was now set on becoming a massage therapist, and working my
I found you somebody to stay with, she's a good person who has got way into a luxurious spa like the one I worked for now, only I was a
teenagers your age, I was just trying to convince your Mother to sign the locker-room attendant there. I studied many books about the anatomy of
papers to get you out of there". the human body and how you can affect a person's well-being and health
I was so outraged at her ability to put her own wants before the needs for the better through a simple healing touch. It was amazing to me the
of her own flesh and blood daughter. I told him to come pick me up and way the body responded to massage. I was more than just interested. I
bring me to the house so I could speak with her for the first time in over a was determined to become a therapist.
year, but if I felt threatened for one second I will be on my way quicker It was one of those anatomy books that I had my nose buried in one
than a blink ofan eye and on my own for good. He wasn't overjoyed at afternoon on a quiet Tuesday and it could get pretty lonely in the locker
my proposition, knowing what position this put him in as her husband but room, so if I weren't busy I'd sit outside by the spa's reception and read
as my father he decided to put me first for once and take me home to my books in the warmth of the Florida sun. A lovely looking woman in
confront my mother. her late thirties who spoke with a proper English accent approached me. I
I arrived at my house for the first time in a long time and everything assumed it was a general question, "like where's the ladies room or was
looked different. My parents refurnished and renovated the house. I didn't that the famous model from so-and-so?" but she was more interested in
even have a room anymore, my old belongings and bed were removed the book I was reading. Only believing at first we were just making small
and it was now the office. Of course my Mom didn't meet me at the gate talk she was really intrigued at my choice ofreading. She then asked if!
or the front door like her long lost offspring reunited. No, instead she
21 22
did massage on the side, 1 stated I was only reading the book and had not ever pleasantly. She said the boss was upstairs and waiting my arrival, so
yet began to study but one day I would love to practice massage therapy. with that I said bye to my dad and began to follow Ghislane up the stairs.
She introduced herself as Ghislane Maxwell. I would later find out that I was so nervous, but I didn't show it. I kept my reserve and demeanor
she was the daughter of the late prominent businessman and disgraced cool as ice, trying show maturity for the open position. We continued on
newspaper tycoon, Robert Maxwell. I told her my name is Jenna pointing to the massage room, passing by a grand crystal chandelier, and a couple
to my nametag on my shirt and offered her a cold or hot beverage, as lengthy wooden hall tables displaying a multitude of photos displaying
those were my instructed duties at work. She accepted a tea and went on young girls and beautiful women, trying not to gawk at them I didn't
to chat a bit about this rich guy that she worked for and she knew off- even notice that some of those girls were only wearing their smile.
hand that he was looking for a massage therapist. Just doing me a good Ghislane asked me how my day at work was and I told her it was easy
deed out of her kindness of her heart, I'm sure, she offered to introduce peasy as always just trying to make simple conversation. There was a
me to him. I declined her first proposition, thinking out loud, told her I fork at the end of the staircase and she led me to the right hand side. The
didn't know the body well enough to even attempt an interview. She lights were dimmed in the bedroom but I could still see the King Size bed
didn't seem worried at all by my fear of incompetence saying that ifhe in the middle of room, we did a U-tum around the bed, which led us into
liked me enough he would get me the best training in the industry. a massage room. Dripping in luxury I could've definitely compared it to
Ghislane thought I had a cheery persona and fit the quota for what he was the renowned Mar-a-Lago 's spa's, it had marble walls and a glass
looking for and as she put it an enthusiastic learner that she said she enclosed shower and self-automated steam room at the very end of the
gathered from the sticky notes popping out of the various sections in my Burberry carpeted room. There was a large mirror over a basin to the
book. I accepted her phone number and the house address and told her I right of the room with an array of oils, ointments, soaps, and lotions and a
will call her if I am able to come over after work. I rushed over to the small closed door, which I assumed must be a closet. The only thing that
tennis courts where my dad was working and told him of the news. We struck awkward about this room was the naked man laying face down
both thought this could be a wonderful opportunity to get my atop of the turquoise massage table in the center of it. "I had to be
accreditation in massage therapy. Seeing that it was a lady in her late prepared for this," I told myself Massage was something I had never
thirties who came off as more of a nurturer rather than a procurer, neither done before so I quickly brushed away my thoughts of possible schemes,
ofus saw any reason to be hesitant. wanting to believe whole-hearted this was going to be legit. Ghislane
introduced us to each other and 1 proceeded to make his acquaintance.
Chapter 4 Looking up at from his downwards position, he looked me over and
gave a smile to Ghislane, an obvious notion of his approval. He was
At around Five p.m. my dad drove me down to the bottom of"El Brillo Jeffrey Epstein as she pronounced for him, as if I supposed to recognize
Way." on the Palm Beach intercostal. We pulled into a short driveway his name or something. He affirmed, "It was his pleasure" and replied to
just call him Jeffrey, "No need for formalities" he answered, cleverly
beckoning a large pink mansion with heavy wooden doors. I was so
putting me at ease. This man did not look like someone to beware of.
excited about this chance and asked my dad to wish me luck. He gave me
Both him and Ghislane appeared to be very nice people and conscious of
a big squeeze and wished me the best. He walked me to the front door
their health as their need for massages and spa visits, no alarm bells went
and I rung the door chime. Moments later we were greeted by an older
off, yet. I was prepped by Ghislane to "treat this as a lesson from her and
gentleman dressed in a casual butler uniform. I told him I was here to
meet Ms. Maxwell for a massage trial and he opened the doors for my follow her exact lead, ifT did good tonight then maybe I would become
Jeffrey's Travelling Masseuse, seeing the world and getting paid well for
father and I telling us to wait in the entry as Ms. Maxwell would be on
it". I was very hopeful, a job like this could really make my dreams come
her way any second, and she was. Down the stairs she walked with a
warm smile, her short black hair seeming very proper and elegant, for true.
1 followed suit and washed my hands with warm water so the coldness
now. She shook my fathers hand and thanked him for bringing me and
would not shock Jeffery's naked body, then lathered them in rich body
kissed us both on the cheeks. They spoke briefly about whom she worked
butter. Ghislane told me to always keep one hand on Jeffrey, even when
for and about Mar-a-Lago where we worked. She was in hurry, you could
getting more lotion, so it didn't make him lose concentration on being
tell to end the conversation and say good-bye to my dad, which she did so
relaxed. She gave me a tip and told me to keep a blob oflotion high up on
23 24
my forearm so it prevented me from having to keep going back for more "what have I been trained up for until now". Nobody ever stopped to ask
and was less disruptive to Jet1rey. This all seemed for real to begin with, I if I was comfortable or if I wanted to stop, no, instead, Ghislane only
was being educated about the body and splitting Jet1rey's body with directed me to conclude the massage session by climbing up on the table
Ghislane, mimicking her every motion. Starting with his feet, we began to be fixated on Jeffrey, straddling him so he could penetrate me.
with his heels and arches of his soles. Pushing the blood up his calves in When it was all done and over with, I was taken into the steam room
upward strokes to rejuvenate the body's blood supply and being careful to with just Jeffrey to get further aquatinted, as Ghislane left the room to go
mind his leg hair didn't pull. I was keeping up with her and enjoying the get dressed. He asked me to grab his feet and rub them not saying a word
education. It was so interesting how the body worked and I couldn't about what just happened, like it was all normal and accepted. I listened
believe I was learning all of this for free. Once I got a bit of a groove to him ramble on about the health benefits of a sauna and the history of it,
following Ghislane, they began asking me all sorts of questions about my ignoring the fact of the matter of his pretentiousness degrading my spirit.
past and it didn't take long before the conversation led down the darker I figured I had gone too far already, what would be the point in throwing
experiences ofmy young life. When they found out that I hadn't led in the towel now after I had done exactly what these people wanted.
much of a normal existence they only probed me with more questions, Whilst we were sweating out our bodies' toxins, and the steam was
which being put on the spot answered honestly. The funny thing was they blasting my burning face I listened to his lessons, entertaining his ego, I
didn't seem appalled at all by my statements, rather entertained if let him become my teacher, he seemed to like that. He sounded like a
anything. Jeffrey called me a "naughty-girl" with that wry smile of his, very clever and intelligent man though. Telling me his story of how he
and half playful and half defensive, I answered "no I'm not, I'm really a made himself an empire of billions from being a middle-class professor to
good girl, just always in the wrong places" he then replied, "It's O.K, I an elite financial advisor for clientele with only billions in their bank
like naughty girls" and rolled over onto his front side to expose his accounts and through his so-called "lessons", He became my mentor and
complete nude self. He wasn't the first man to show me his penis, so I I emerged as his pupil, the teacher's pet.
wasn't shocked at the appearance of his manhood but I was incredibly After the sauna we went to the next glass door beside us where the
shocked at his complete ease to present himself with an erection. I tried to shower was. He turned tap outwards and stood underneath the water as I
ignore it waiting to follow the next directions off of Ghislane, who stood naked and cold from the temperature difference. Instead of asking
surprisingly now stood behind me bare breasted. Before I had a chance to me to join him under the warm stream, like I thought he was going to, he
even think of replying hastily she began to slowly undress me, while handed me a bar of soap and asked me to wash his body from top to toe.
Jeffrey started to stroke his manhood while watching us. She unbuttoned It didn't stop there I had to massage the shampoo and conditioner into his
my blouse and removed my bra, revealing my bosoms. Cupping them in scalp as well. I was bewildered someone would ask this off of someone
her hands she moved her lips across my nipples, licking and teasing them else, wasn't it belittling enough having to endure the illicit massage from
with her tongue making them cold and stiff. Next her hands moved down beforehand but now this. The surprises kept coming that night, as this
to my little white skirt, removing the final piece ofmy remaining was definitely not how I expected my interview to tum out, but that's
uniform. She slid my skirt down my legs with ease, for a moment keeping what I had learned in my short time on this earth, life was full of
on my love-heart panties, so they could both take notice ofmy apparent disappointment.
youth. They even snickered to each other about " How cute she still wears I let everyone else take the power of authority from myself and use me
little girl pantie's" Jeffrey said, and Ghislane joined in his laughter. in whatever way he or she wanted instead of standing up and giving
Acting as my madam, she instructed me to start by licking his nipples myself the respect I deserved, which in tum would've helped me get
and after I had sufficiently pleasured both of them, then prompted me to through life without all of the abuse I ended up copping. Not given the
go down on Jeffery orally while she rubbed her breasts along his body belief in myself from an early age on I suppose is what affected my sense
tantalizingly. She moved behind me again this time to remove my panties of control. Always letting the one's with power and strength reduce my
and start fondling the delicate folds between my legs. I was still in shock inner-self to shreds until l was cut so tiny in size I would be completely
from the initial degrading blow. I hadn't even let the reality sink in, it was subdued to only their wants and needs left ignoring mine. The men I had
all too much for me to emotionally handle so instead I hid behind my encountered in my short experience with them only repeated their
fears, which I told myself "I wasn't going to ever be worth anything at all inflictions convincing me there was no running away from the sick world
and this would probably be as good as it gets for me" after all I thought, I lived in, not yet understanding it all came down to the choices I had
25 26
made for myself, I needed some encouragement and the right words to About to be entrapped in the same life I had broken free from only
unlock my very soul. months ago.
Jeffrey told me the towels were on the heated rack just outside the Convincing myself in order to succeed I had to step up from being a
shower and asked me to get one and pat him down. Again putting himself girly teenager and start thinking like a young woman, it would be my
first as I sat there freezing while I compliantly patted down his body with ticket to a great career and a fortunate life. I told myself"So what if I had
the white fluffy towel until he was dried. I nearly expected him to ask me to bargain my body to this rich old geezer, some girls get themselves
to dress him as well, but not surprisingly that came later down the track through college by becoming a stripper and using their bodies to pay for
too. I dried myself off and wiped the make-up from under my eye's, degrees, others go down even worse paths." I guess it was just another
keeping quiet not sure what to really say and half-embarrassed from the way to fathom the road I was going down, the effectiveness of the lies I
entire evening's events that just took place. I just remained silent whilst forced myself to believe was working as I continued to tell myselfI had
we both got dressed until he brought me downstairs where Ghislane was to make it any way I could rather than ever letting myself sleep on the
sitting at a desk holding his black leather duffel bag. When she moved streets again. I was trading one shocking lifestyle for another, thinking I
from the chair to let Jeffrey sit down, she passed him the bag and began was choosing the right one. If I could go back in time to ever meet myself
to tell me that I had great potential to be a massage therapist, they really I would choose this time in my life. I'd start with a good hard smack to
liked my style and who knows where this could lead too. She asked to see my head to first shake some things up in there and next I would tell that
me again tomorrow, same time after work. He opened the bag, revealing girl she could actually make it on her own if she just worked hard at
stacks of brand-new hundred dollar bills separated with rubber bands to earning an honest wage and built her life up slowly. There is no rush or
count by the thousands. He grabbed one stack and took out two crisp time limit to ever stop reaching for achievement. Sadly enough I probably
notes, placing them in my hand. He laughed that it was nearly my whole wouldn't of even believed myself anyways, learning my life's hard
week's wage at Mar-A-Lago. Only there I didn't have to degrade myself lessons through the experiences I continued to suffer.
as his new little toy. I went to work at Mar-A Lago that day trying hard not to think of what
When I got home my parents were anticipating my arrival. I kept it lay ahead in the afternoon too come, but the later the hour got the more
simple and sweet with my folk's, only telling them of the lessons about distinguished the knots became in my stomach. I spoke to no one of the
the body I had received and the future prospects in massage therapy that details to my explicit interview but told one girl how I was so happy I
lie ahead. Nobody questioned who I was working for and complimented was now officially studying massage therapy, another lie. My friend was
my ability to be a hard worker. I quickly got out of that conversation surprised and intrigued that these people who could afford the best of the
afraid I might give away a hint of shame in my eyes but no one caught best of therapists in the world chose an untrained fifteen-year-old girl to
on. I excused myself to the bathroom to have a shower and stared into the perform a massage. She never said it in words, but her body language told
mirror for a moment, asking myself if I could really go through with this me she knew exactly why they wanted to use me and it wasn't for a
only to mentally respond by reminding myself this would be as good as it therapeutic reason either and deep down inside I understood.
gets for a girl ofmy stature and limitations. I scrubbed myselfrigidly in The rest of the afternoon slipped away quickly and before I knew it I
the shower as ifit would wash away the filthiness of the night, but it was standing before those large wooden doors again, giving a moments
didn't help, I could still feel their hands in me and all over me and inside pause but long enough to draw in my breath and exhale some of the
ofme. Trying to sleep that night was nearly impossible too, closing my anxiety before ringing the doorbell. Juan answered the door again and
eyes only to drift away to flashbacks of the moments I had to give myself told me Ghislane would be down in a few moments and asked to follow
to Jeffrey and Ghislane, each replay an exploitation of my vulnerability. him into the kitchen. There was a pleasant looking young girl with blonde
The next morning I awoke feeling anxious about the day ahead, trying to spirals in her hair that glanced up from the mound of paperwork before
push yesterday's memory from my thoughts, I was quiet for the whole her. Her shocking blue eye's and appealing English accent seemed
trip to work with my Dad. Before we got out of his car in the parking lot delightful and she introduced herself as "Emmy", Ghislane's Personal
he asked me if everything was okay, I lied, for his sake and mine. My life Assistant. I introduced myself as "Jenna" which is what most people
was being transformed and I didn't even know it yet, but soon enough I knew me as and told her I was on an employment trial to become
would be a brainwashed tool only used for the sexual pleasure of others. Jeffrey's massage therapist. She had a coy smile on her face that told me
she knew exactly what I was on trial for. Something in my b'llt told me
27 28
this wasn't the first time a young girl had been trialed for the same and temperamental in the seconds that she appeared. She told me I would
position I was about to fill. be on my own today as she had business to attend to, so make sure I
We were only chatting for a moment before Ghislane appeared and told remembered what she had taught me, as my trial depended on it.
me Jeffrey was ready for his massage. I was led through the extensively
large house to the winding staircase that would lead me up to the same Chapter 5
dreaded room where I would have to re-enact last night's performance. I
wasn't far from wrong. I gave Jeffrey a massage with Ghislane leading
the way again, this time we surprisingly made it to the front of his body
I walked up the stairs by myself this time, taking in more of the decor,
and she continued to show me how to massage all the way up to his noticing the more I looked around the more I noticed a different girl in
stomach pushing my hands in a spiraling clockwise circular motion to not each photograph in his collection of half-nude and topless girls on display
disrupt the bowels and then we came up to his chest. He couldn't dare
around his mansion. I couldn't believe how many girls there were, it's not
contain himself for one second longer, telling me to put my lips on his
like Jeffrey was much to look at. He was an aging man in his early fifties
nipples and give them a kiss. Jeffrey moaned in pleasure and Ghislane
with shiny grey hair and characteristic lines drawn down his face as ifhe
started to undress me from behind. Within moments I was completely
had seen harder days. With no prospects of ever settling down or having a
naked and Ghislane had her top off. She was caressing my body with her
family of his own, Jeffrey treated us girls like a piece of clothing he could
hands while Jeffrey moved his hands down to stroke his loins while he
try on for the day and get rid of the next. So why was there so many girls
watched her and I kiss and touch each other. I didn't know if she was
in these photo's? I wondered to 111yself if I would end up one of those
doing this for the sake of his eye-candy but she sure did act like she loved
girls among his collection of forgotten relationships and broken promises.
having the control over me telling me what to do throughout the entire I continued to make my way up the stairs, and as if all of my senses
threesome. Jeffrey's climax was always the end to our sessions and this
were heightened from my bare nerves being exposed, I could smell the
time he wanted to have me make him orgasm orally. Afterwards we went
cleaning detergents recently used by the housekeepers, my observations
for the ritualistic steam-room, this time Ghislane joining in with us for
of the shade oflighting through the concealed blinds as I entered Jeffrey's
conversation. She asked me to massage her feet this time while we were
bedroom appeared golden, and the sound of stillness except for the thud
in the steam room, showing me that Jeffrey wasn't the only one I had P?Y ofmy rapid beating heart all made me more aware of how nervous I was
my homage to. We all had a shower next and then we all went downstairs
to be on my own. Not that Ghislane was anything of a comfort, but I
to pay me and have Juan drop me off back home. didn't know what to expect or how I was going to lead myself into
The following afternoon I received a call at work, surprisingly it was
upholding my obligation in pleasing him. I would hope for the best I
Ghislane asking me to come over when I got off of work again. The thought, trying to uplift my confidence as I opened the door to the
compliant side took over and I told her I looked forward to meeting with
massage room with the typical scene of Jeffrey laying naked facedown in
them today, instead of telling her to go screw herself for lying to me and the massage bed waiting for his entertainment. It was de'ja'vous' all over
making me degrade myself more each time I saw them. I finished work again. Repeating what Ghislane had taught me, with him commenting on
for the day and my Dad brought me over to El Brillo Way again, where
what else I should be doing, until it got to the end and I was expected to
the vultures were patiently waiting in their lair, he wished me well as I grant him all of his spoken desires. We finished up with the shower again
hopped out of his big truck, looking ever so much like his little girl again.
and he seemed very pleased in my contribution of myself to him, giving
I gave him a smile and a wave as he drove down the long driveway, in to every request.
waiting for him to suddenly tum back and not leave me alone to my task.
He told me to go ask Juan to pay me, as he was lethargic after the
I shook myself out of that calamity and put on my "big girls" face.
massage and intimate affair between us and now was going to have sleep.
Juan brought me to the kitchen again as I waited for Ghislane. He
I walked back down stairs and told Juan that Jeffrey was asleep and said I
offered me a cold drink and some fruit on a platter, I accepted and was
had to ask him for my pay. He went to Jeffrey's desk and took out the
grateful for the rejuvenation before I went to work again. It wasn't long
exact amount I was owed without even asking how much I normally get
before Ghislane approached me from behind with a cold intense look in
paid. He then drove me home, only to be back the next afternoon.
her eye. I jumped from my seat, feeling like maybe I shouldn't have been
eating and drinking while on the job, as her demeanor seemed annoyed
29 30
The following week was a daily routine, providing Jeffrey with wall's built in jets. There was a bench coming out of the wall also made
massages and continuously being groomed to fulfill all his needs. Often out of marble that went from either side of the room and had a step
joined by Ms. Maxwell and her assistant Emmy for sexual trysts of all underneath it where I was instructed to sit on so that I could begin giving
kinds. I was mentally and physically exhausted from the week of working Jeffery his massage. Our conversation started off about simple things like
and having to keep up with Jeffrey's strenuous late night activities. I how was your day at work, and I asked Jeffrey how his day was lounging
couldn't believe what I was doing but it was all starting to sink in fast. around, just being polite to each other. He was acting out of character
Most nights when I got home, I'd briefly say "Hi" to Mom and Dad being a lot more attentive and conversing with me about other things than
before heading straight to my bedroom. I couldn't even sleep well sex or massages for once. Starting with his heels, ankles, toes and arches
anymore. Closing my eyes at night I would fight the inevitable flood of in the soles of his feet I massaged all the way up to his calves. It took a
thoughts, replaying the moments of shame that ate away myself piece by lot more strength to massage in the steam room without oils or lotions
piece. My only reasoning being I just had to keep telling myself it would and the constant blowing of steam in your face making me twice as
all be worth it in the end. exerted. I was beginning to really start to heat up when the door to the
This afternoon Ghislane appeared to be in a much better mood. Instead room suddenly opened to reveal two naked women. Ghislane and Emmy
of taking me straight up to Jeffrey she took me to a yellow guest room acted as if they came in to join us for a steam bath, but my instincts were
where Emmy mostly stayed. It had a balcony where Emmy was already telling me otherwise. At least the cold burst of air and escaped steam
outside reading a magazine and puffing on a cigarette. Ghislane lit one up revived me a bit.
too and then offered me one. I hadn't smoked cigarettes much before, So there was Jeffrey and Ghislane sitting on top of this marble bench,
besides trying to look cool in front of one of my friends, but never really each with a young girl at their feet. Emmy and I continued with the
took to them, so when I started to cough from the inhalation of smoke, massage until they were ready to head into the shower. There were two
the girls began to laugh and joke about my in-experience. It was an showerheads that Ghislane and Jeffrey both stood under while they were
icebreaker for all ofus to laugh and poke fun at me. I was then able to being lathered with soap bubbles as we washed their bodies. After the
give it back to them saying I would rather be an in-experienced non- shower Ghislane led us into Jeffrey's bed to finish today's session with
smoker than an old lady with a raspy smokers cough. I don't think Emmy, Ghislane and I performing lesbian acts of foreplay on each other
Ghislane was used to somebody giving it back to her, but she seemed to while Jeffrey laid back and watched. Stroking his manhood in much
like it, as long as she was able to have the last say. I knew my boundaries delight, he brought himself to climax, and the session was over within
and she liked that I wouldn't cross those invisible lines. All three of us moments. We all got dressed and went downstairs to the kitchen for some
chatted like friends and it started to feel like some kind of a strange refreshments. Like nothing had happened at all, it was all so bizarre for
relationship was budding. After about fifteen minutes of chatting away, me, the whole ordeal with them since this all began. I couldn't understand
Ghislane instructed me to wash my hands thoroughly, as Jeffrey hated the why Ghislane and Jeffrey had such an openly intimate relationship but
smell of smokers, and to follow her down the hallway to the massage yet never regarded themselves as partners. They rarely kissed and never
room where he'll be expecting me shortly. I did what she asked and held hands or even slept in the same bed. It was more like a sexual
sprayed myself with the body spray that I always carried in my purse and arrangement between the two of them. She brings in the girls for his
headed down the hall to Jeffrey's room. peculiar taste and he supplies the lavish lifestyle she was accustomed too
When I opened the door to the massage room surprisingly it was empty. before her family lost all of their fortunes. I wasn't sure how to act or
I sat down on the already made up massage table and was careful not to feel, always obliging to their needs but reserved enough not to get
mess up the neatly folded towels on the end of the bed. It was a good attached, as if there was this invisible hierarchy and by instinct I knew
fifteen more minutes before Jeffrey made his appearance. It was strange my place.
seeing him in clothes for the first time. He wasn't wearing what you'd We all hung out in the kitchen for a while before I asked when Juan
expect your typical billionaire's attire to be. He was wearing a pair of could bring me home as I had work in the morning and was tired. They
sweatpants and a Harvard sweatshirt, which he began to remove said no problem and called Juan on the intercom right away, but said
immediately. This time he wanted to commence our session in the steam we'd all have something to talk about tomorrow. I knew it had something
room, so I began to undress as well. We went into the steam room and he to do with my employment trial and from the way they were acting
pushed a few buttons and the steam began to pour in from the marble tonight, I could only assume I got the job, but you never know with these
31 32
types of people. Their friendships and partnerships can change like the James for a bit of relaxation. The temptation of his grandeur offer wasn't
weather. hard to give into, my vulnerability to be lewd into his grasp seemed
I went home that night still confused on how I could let myself sink so comforting at the time. The idea that females were nothing more than an
low, I had to put on an act like I enjoyed submitting my body and being empty shell of beauty bound by only a body to offer was a notion I had
their new subservient plaything all for the fact that I was making accepted a long time ago with my first teacher, Ron.
anywhere between $200-$400 for just a couple of hours. Then spent the My reaction had to be more than amusing for their egos, even though I
rest of the night regressing on the entire event in my head over and over was excited to be traveling I could only imagine the likeliness of having
again. I battled those thoughts with the hope that I was receiving a to be at their beckon call as well. In my head I just told myself we all do
profession out of this and making good money in the meantime. All I had what we have to do in our lives to succeed no matter what it takes, and
to do was keep lying to myself long enough until I eventually believed it. with no one knowing the truth, I had no one to talk me out of it. I
Arriving at Jeffrey's on time the next afternoon, as I always did, accepted his offer and knew from here on out I would be his servant to
understanding punctuality was a sign of respect and I wanted them to feel his sexual desires until one day I would gain my credentials and only then
as if they had my deepest appreciation for the once in a lifetime chance could I go out on my own and make it in this world that when so young
they had given to a girl of my history. This time when Juan answered the seems so unconquerable. The night advanced into the usual grooming of
door he told me Mr. Epstein and Ms. Maxwell were waiting for me his requirements, for the next hour and a half being exploited to satisfy
upstairs in the massage room. I began my hike up the familiar spiraling Jeffrey's every sexual whim.
staircase and through to the room where my arrival was being deeply My mom cornered me that night, before I had a chance to avoid
anticipated. They were already in the steam room awaiting me to join speaking to anyone, heading to the shower then my bedroom, like I had
them. I undressed out of my unifonn and folded them in a neat pile, been the last week. She knocked at my door with a hostile look in her
which I placed upon the marble basin. Having one last look in the mirror eyes, "Virginia, what exactly does an older couple want with a fifteen
before I exhaling a deep breath as if I was plunging into deep water, I year old girl, who has no credentials and with no experience in massage
knew today was a big day. I either accepted their offer and trade my therapy?" She used that stern tone of voice that she's always had, when I
morals for opportunity, or walk away with the prospect of one day many was in trouble.
years from now trying to make it on my own which I knew endowed Thus, as impressionable as I was, my blue eyes batted their innocence
hardships of there own. in her direction and I flashed her a girlish grin selling her the pitch that I
So confused about what decision to make, I just opened the door to the had been given earlier that night. Not mentioning the other side to the
steam room and let them do the talking. Used to the routine by now I sat glamorous lifestyle I would soon be living in. I told her about the money
below Jeffrey and began to massage his feet and legs as I listened in on I'd be earning, the places I'd be seeing, the people I could meet and most
their ongoing conversation about travel plans for the next few weeks. of all the trade I'd be learning. It all sounded so good, except it was a
Ghislane and Jeffrey turned their attention to me and he asked me how bunch oflies I had to tell her and myself to otherwise convince us, that
would I like to go see the big city of Manhattan. I told them I had never this was a once in a lifetime opportunity, and I had to take it.
visited New York before and it sounded like an adventure but my job at She asked when all of this would start, and I as shocking as it was to me
Mar-A-Lago was only a summer job and wouldn't be able to get the time too, I told her I had to go start packing. We were leaving the next
off, especially that summer was so busy anyways. morning off to N.Y.C. At fifteen most girls would be sucking up to their
Jeffrey then made his announcement, that I should just quit my job at parents to go to a high-school dance or to go on a date to the movies with
Mar-a-Lago and become his permanent travelling masseuse. He then a nervous chap, but I wasn't even asking her. I was simply letting her
further persuaded me with all of the luxuries that came along with my know that I would be away for the next couple weeks, maybe three and
acceptance. Rather than being paid $9 dollars per hour at my current job I would keep in contact when I got free time. Her daughter was lost a long
could be earning $200 dollars per massage, which he even said could be a time ago, and she just now realized it. Backing out of the bathroom, with
few times a day. Tomorrow we could be leaving Palm Beach together in nothing she could say, she left me wondering to myself who I was
his private jet first heading to his residence in the upper east side of becoming.
Manhattan, also the largest mansion in N.Y, and would next be setting off Instead of driving me to work the next morning my Dad dropped me off
to the Caribbean, where he owned a secluded island just past Little St. at Jeffrey's mansion, he told me not to worry about calling Mar-A-Lago,
33 34
he'd take care ofit for me. We said our good-byes outside in the often found it hard to sleep and was comforted in the early morning hours
driveway, Jeffrey even coming outside to meet with my father to shake with his literature, or sometimes in other ways I would come to find out.
his hands and assure him that his daughter will be more than looked after. There was a mantle piece and a sofa with two armchairs next to the grand
I hugged my dad tightly, feeling like I was on the verge of a steep cliff, piano that flaunted more of Jeffrey's beautiful conquests, young women
when he let go, so did the last of my innocence. posing in salacious pictures, suggesting I could be easily replaced next to
Juan drove Jeffrey, Ghislane and I to Palm Beaches' Private Airport one of those girls if 1 failed in keeping him satisfied. There were also
and the luggage handlers escorted us on the tar mat where we all boarded some pictures with recognizable political and royal figures either shaking
on Jaffrey's black jet. Larry was his main pilot, he had shiny grey hair Jeffrey's hand, or with an arm around each other, even one with Jeffrey
and long lanky legs, but a very sincere smile that instantly made you feel and the Dali Lama, although his church was the bank. He liked to use his
at ease. He greeted us at the staircase tl1at led into the main cabin. It was power, wealth, and money to manipulate everyone in his life.
as lavish as I imagined it would be. The seats were enveloped in the finest He made a phone call that sounded business like and I didn't mind, I
beige leather with polished wood grain finishes and there was a kitchen in was quite enjoying taking in all of the beauty around me, I was blinded
the back with an adjoining toilet. Jeffrey saw the amazement in my eyes by all ofit. I was still waiting for him when, Ghislane came in. She asked
and to make it more thrilling he brought me up to the cockpit and let me me what I thought so far ofmy trip to N.Y.C, I knew she was talking
watch with a bird's eye view of the take off. I was on a natural high when about the house, she loved to gloat, even though none of it actually
I came back to the cabin and was instantly brought back down when belonged to her, she wanted everyone to believe that it did. I
Jeffrey rested his bare feet on top of the reclined seat and instructed me to complimented her on the mid-evil looking tapestries and a few other
get to work and start massaging him. My future was in his hands now, so adornments, when she cut me off mid-sentence to compliment it herself,
when he wanted something, I wouldn't hesitate in giving it to him. telling me the history about one of the 17th century tapestry's which to an
unsophisticated eye, looked to me like a rug on the wall.
Chapter 6 Jeffrey hung the phone up and walked over to the sofa where we were
sitting next to the mantle piece and took a seat on one of the armchairs.
He didn't seem worried from the phone call but his mind was definitely
somewhere else from the hard look on his face. We all spoke for a few
Upon our arrival at New Jersey's Private Airstrip, the driver Jo-Jo met
moments more about the splendid decor before Jeffrey had enough small
us. His name was most likely shortened for something of his oriental
decent. Jeffrey liked to shorten the names of his multi-cultural staff into talk and needed some of his own relaxation time. He told Ghislane he
was going to show me to the massage room and he'd be back in a couple
American names. Even Juan and Maria were known as John and Mary.
hours. She agreed he looked like he could use some time to unwind and
We arrived in the Upper East Side of Manhattan. His principal place of
with that wry grin of hers, she gave me a look that told me precisely how
residence was the largest home in Manhattan, eight stories of opulence. It
used to be a Private School for boy's many years ago, until Les Wexner, he was expecting to be relaxed.
We left his office all together, Ghislane going downstairs, and Jeffrey
Jeffrey's best friend and mentor bought it for him as a mysterious gift.
showing me to the lifts. The lift looked like it's original that came with
There were two large Chinese gargoyles outside the entrance, and
beside the heavy looking wooden doors there was an intercom with a the school. It was made out of brass antique with archaic cuts throughout
the arches at the top. It wasn't the only lift in the house, but certainly the
camera overlooking us. I walked up the concrete steps into a realm of
wealth, glamour and most of all influence. My eye's glistened at the most beautiful. We walked down a long hall carpeted in a royal red and
golden trim, passing by a bronze pagan statue of the horny little goat God
splendor of his palace. Caramel colored marble tiles spread through the
"Pan". How adequate, I thought, fit Jeffrey to a tee. We walked into this
first floor, where his gounuet kitchen and dining hall were also located.
dimly lit room. Another daunting chamber that looked like we had
Then I came to this sweeping staircase that curved into the next level
stepped back in time to the dark ages. It took a second for my eyes to
where Jeffrey and I went into his office, even though it looked more like
adjust to the darkness, and Jeffrey beckoned me to follow him through
a museum exhibit. Ancient draperies that told lascivious stories of their
the room to the open adjoin shower, toilet and steam room. The room was
own covered parts of the elevated walls, and the remaining wall spaces
in black marble to accent the dreariness, and smaller than the one in Palm
were taken up by rows on top of rows of books. He loved to read, as he
35 36
Beach, but it had it's own witchery feel to it. Another unseen side to this into the artistry, the intercom buzzed on the telephone next to the bed and
Man I was coming to know. it was a housemaid letting me know Jeffrey wanted to see me in his office
We both undressed and I followed Jetlrey into the steam room first. He now. "Already" I thought to myself: I was just getting settled in. I was
loved feeling clean, teaching me that the steam would deplete the toxins worried I was going to get lost in this ancient museum, but I got myself
from your skin, which was great during a massage when your blood flow back to his office with no trouble, it was kind of hard to miss. I knocked
is being replenished. I grabbed his foot out of instinct, knowing I had to at the slightly ajar door and Jeffrey called for me to enter. I walked over
be constantly on alert to keep this man satisfied. He looked down at me to his desk, where he was just ending a phone call and he opened his
with a nod and reclined back against the wall as the steam pored in, this duffel bag full of money. "I'll be out at my other office for most of the
was his idea of alleviation. I worked up to his calves and within a few day, so instead of being locked inside I thought you should go do some
more minutes, he said he was ready for his massage on the bed. We got sightseeing for the day since it is your first trip to the Big Apple" He
out and towel dried oft: both still nude, he asked me to stay undressed, didn't count how much he was giving me he just handed me a bundle out
then we headed to massage bed in the middle of the room. He lay down of the banded $100 dollar bills. He knew just how pull the right strings,
on the bed and told me to tum on the CD player on the wall hutch, where making me squeal in delight and give him a kiss in the cheek, since we
all of the oils and lotions were set out, I hit play and a collection of mixed were never really emotionally intimate, it would be odd to act in any
classical symphonies began to fill the silence. I could tell he wasn't in other way, but he seemed to like it.
one of those moods to be uplifted with idle chat, so I remained silent, I ran upstairs to get dressed for "City" shopping and put my make-up
letting him enjoy my slow movements, making my way up his body. My on, then hit the streets of N.Y.C, looking for a place to start spending this
instincts told me I was right about his mood, as he seemed to appreciate load of dosh. When I got to the end of 72nd street on 5th Avenue, I had no
the quietness of moment and the leisurely of the strokes I was using to idea which way to tum, left or right. I thought I'd just follow the lights
massage him. When I got to his scalp he turned over, and b>rabbedmy past Central Park and see the local sights on my way. My eyes were once
hand to put on his erect manhood. No words spoken yet, I took the again peeled back in splendor. I had never imagined a place so busy with
gesture and initiated what I had been taught over the last week. While the hustle and bustle of all the walks of life. My first stop was to buy a
pleasing my master his hands groped my young flesh, penetrating my disposable camera and I was off taking photos of every wonder that
insides with his fingers, he was only concerned with what he wanted, as caught my attention. I didn't do much shopping as I had planned too; I
If I was a new car out for a test drive and he was pressing his new was having too much fun exploring this capacious metropolitan.
gadgets. His soft moans were soon brought to louder heaves of breath and When it started to hit dusk I began walking back to Jeffrey's but not
my job was done. No intimate kisses, or sweet pillow talk. He showed his before stopping off to enjoy a giant slice of pepperoni pizza, it was the
appreciation with money, never attachment. We concluded with a shower best I had ever had, and considering I was going back to Jeffrey's
and he told me he had some business to conduct. He walked me to the lift chickpea and tofu salad's or such. I really hated the healthy cuisine
and told me go to the next level and my room was the first one on the served by Jeffrey's personal chef. I was a naturally skinny girl, never
right, it had an intercom in which he can contact me when needed. watching what I ate and to eat that food I might as well have chewed on
I hit number 5 on the lift and took his directions to my room. I opened hay. I strolled back to Jeffrey's and was missed. Ghislane scolded me
the door to this massive loft, the size of an adequate house. I walked "You shouldn't have been gone so long young lady", "We need to know
down the long hall and my eyes took in the magnificence ofmy where you are at all times, you are on call for Jeffrey" I started to
surroundings. It was a room fit for royalty, and later would find out had apologize, feeling guilty, I didn't want them to think I didn't take my job
been stayed in by some. The room was trimmed in gold paint and had with them seriously. She cut off my explanation with a short conclusion
another eerie tapestry on the main wall as feature. There was a T.V and a to this conversation "We will get you a cell phone tomorrow, so we can
huge king sized bed, with goose feathered comforter and pillows. always find you". I thanked her for her generosity, and she dismissed me
All of the glitter from Jeffrey's lifestyle he was offering me finally to my room. So I wasn't even needed after all, it was just a way for her to
covered the last bit of sight I had left and I let go of my consciousness. place me deeper in their control. The next few days I was on call, as
Excited by my enthralling day, not having anyone around to have to act Ghislane said I'd be. Venturing out to the city for only an hour or so at a
reserved, I jumped into the soft bed and lay looking around, thinking time, I looked most forward to my outings. I would return to Jeffrey's
about how quick life could change based upon one swift decision. Dazing
37 38
mansion to attend to his sexual desires and when he was finished with happened within the next hour and be able to become someone without a
me, I'd be off to my adventures. battling conscious.
On the day before we were to be heading back to Palm Beach, Jeffrey I spent my sweet 16th birthday on his island in the Caribbean next to
had a new proposition for me. I could make double the money I was "St. James Isle" he liked to call it "Little St. Jeff's", his ego was as
making, ifI would look for pretty girls and convince them to come back enormous as his appetite for fornicating. I was given a birthday cake and
to Jeffrey's to be further persuaded with money to engage in bi-sexual a new collection of designer make-up from London. Ghislane made a
and sexual acts with Jeffrey and I. I asked him how does one actually joke after I blew out my array of candles and said, "I'd be soon getting
propose such a thing to a complete stranger? "Well" he said in a build up too old for Jeffrey's taste, and soon they'd have to trade me in." She was
to another kind of lesson. "If I were you I would use your charm to entice only half joking in a sad reality though. A few days after my birthday, a
them and my money to bring them, I would tell them you work for a girl was flying out to the island to join us for a few days before flying
multi-billionaire who has a taste for young, beautiful girls and with his back to N.Y.C. I was introduced to a pretty girl a few years my senior,
contacts in the acting, modeling, or rich husband world, your boss could named Sarah. She had long ash blonde hair and big brown eyes that
help them. All they have to do is come meet me first." IfI wasn't so hinted she had a cheeky nature. She had known Jeffrey before I had, and
naive at the time I would've seen that's exactly what he was doing with he was supposedly trying to help her get an acting job in L.A. She was
me, my prospects were massage credentials, but with too much pain from obviously accustomed to the lifestyle he provided her, making it ever so
my past, I could only have hope. Not that I was a shy girl, but picking up apparent with her prompt attention she lavished on him. She would do
girls for one reason alone, only to be endorsed for her body, didn't sound things like strip nude and bathe around the swimming pool, taunting him
like something I could do. But not wanting to displease my master, I told for sex. She was good at what she did, even putting me at ease with her
him that I would give it a go. You could tell he was instantly excited with cool persona and funny jokes. Jeffrey told me privately that she was one
my agreement, he started to reveal the politics of what kind of girls he of his best at procuring young girls into her entrapment and delivering
was looking for. He wasn't into multi-cultural girls, a very chauvinistic them to him when he was in town, and when it came to time in the private
perception; he said they had to be uniquely gorgeous to be accepted by chambers with Jeffrey, Her and I, it wasn't hard to comprehend. She was
him, but definitely no African-American girls, he was racist against devoted to the moment, giving Jeffrey every imaginable lustful desire he
anything different to his kind, a very narrow minded way of thinking for could fathom. On the last night there we all took a trip over to St. James
such a supposed brilliant man. The list went on and on. No girls with to go for a stroll, odd I thought, it was past 7pm and Jeffrey rarely strayed
tattoo's or piercing's, or gothics, no drug users, or prostitutes. Basically out past then, unless it was some event or dinner party. While Ghislane
he wanted everyone's daughter that looked like the girl next door, with and him looked the average couple strolling arm in arm through the
blue eyes and blonde curly ringlets. I just nodded and smiled, wanting streets, he said to Sarah and I, "Why don't you two hit the night club here
this to be over with and move on to another conversation, but so worked and see if there is anyone interesting to bring back for the evening?" It
up from our previous talk, instead he persisted to show me exactly what I was more of an order than a request and then I knew why we came out
was good for to him. He took me up to the highest loft in his large tonight and why Sarah was invited, tonight was all about training, and
mansion and he lay down on his large bed, expecting me to know exactly Sarah was going to show me the ropes in picking up girls. Although there
what he wanted done. As always, I complied. Part ofme hating him for was no one to accustom to Jeffrey's distinct taste to bring back, watching
having to degrade myself to be so subservient to his sexual whims, and Sarah flirt from girl to girl like a floating butterfly, gave me enough
another part ofme was telling myself to be grateful for the opportunities I insight into what I was expected to do.
was being given. Within Months I had become his handy little helper. Not only would I
The battles in my head were beginning to cause me too much anxiety, run to his beckon call, but I also aided Ghislane in bringing in more girls
when we got back to Palm Beach, I asked my Mom to make me a to keep the appetite of our sexually starving chief from going hungry. I
doctor's appointment for some headaches I had been getting lately, so she once asked Ghislane, why she did what she did for him, instead of having
wouldn't question me. I walked out of the doctor's with a prescription for a common monogamous relationship and getting jealous like normal
a mind-altering anxiety tablet called "Xanax", not only did it help with partners would? She replied simply "It takes the pressure off me having
anxiety but it also acted as blanket over terrible memories. So when I had to do it". That said it all, we were all under the shade of Jeffrey's money
to perform degrading acts, I would take a few pills and forget what tree, and not even someone like her could escape from its lure.
39 40
Just like Ghislane had trained me it was now my job to reiterate that Chapter 7
onto other girls and thus the cycle of girls trying to climb the chain of
hierarchy would start all over each time I brought a new one in. The
A knock came to my apartment door one lazy afternoon while we were
sessions rarely differed much. They would mostly start out with Jeffrey
in Palm Beach. I looked through the peephole and didn't recognize the
on top of the massage table already naked and me leading a girl into once familiar face. I asked from behind the closed door "Who is it"? The
massaging him until his instructions came to remove our clothing and if
voice of the reply was one I wasn't anticipating to ever hear again. It was
they ab>reedto that, then Jeffrey knew he had them in his pocket, and
my Junior-High crush and childhood friend, T.J. The last time I saw him I
could do what ever else he wanted. He was never turned down in the was a runaway and he had let me stay at his house for a few days, telling
many years I stayed with him. Never being shy, he would tell us to start his parents nothing, he kept me hidden away in his room. At nightfall he
kissing each other or depending on what he wanted we would perform
said to knock on his window and I could jump through and stay the night.
erotic acts sometimes with him fondling us, or just masturbating while he
Until I was picked up by authorities during school hours and questioned
watched. On explicit occasions, sex toys would be used on us girls,
why I wasn't in school they did some resourcing finding out I was a
making it all the more exciting for him to observe. Ending with a
runaway, then delivered me back to my angry parents.
payment of $200 for the new girl and $400 to me for bringing her. He
"Oh My God- You finally answer your door girl", and in a whirlwind,
would then wait for us to leave before adding the events details of names
T.J stormed back into my life. Even moving into my apartment, secretly,
and payments in a little black diary he kept with him wherever he went,
within two weeks of his arrival. He had changed so much from the last
so ifhe were in anyone of the city's he lived in, he would always have
time I had seen him. He used to be this hard looking rocker type, now he
contacts for sex.
was cleaned up wearing preppy clothes and shooting out Tupac Lyrics.
I was slowly climbing the ladder, as Jeffrey was happy taking me
He had the same old big brown eyes though, and when he told me he had
everywhere with him, within the States. Merely at home I distanced
heard I was back in town but he was unable to ever get ahold ofme he
myselffrom my Family altogether and with Jeffrey renting me an
just kept knocking at my door every so often, I was sold. How sweet I
apartment in Royal Palm Beach as well as a plush furnished apartment in thought, he must care about me ifhe was so intent on approaching me,
N.Y.C, there was hardly a need to see them. I just couldn't face everyone
not even thinking he would've spoken to the girls from our junior-high
thinking they all knew what I was really doing travelling around with a
circle and they would've mentioned him I was back in town, what I was
man old enough to be my grandfather who supposedly only wanted me
doing and where to find me. We were a drug-induced romance, which
for massages. Much further convincing myself of the lies I told myself, I
budded from fake emotions the affects made us feel. He got what he
took a liking to the Xanax, it felt like it was all a dream at times, even
wanted, a free ride and not having to work, and I got what I deserved, a
meeting up with old contacts from school years who experimented with man who could let me go away with this multi-billionaire I regarded as
drugs. I was flying around the country, seeing so many places in America
my second boyfriend.
I had only heard about in Movies and making more money than anyone I didn't want to alarm Jeffrey in me having a boyfriend so I kept it
my age and loving it. My friends didn't believe the lies I told them about
quiet, until during a massage I was giving to him one afternoon. We were
only being a massage therapist, some of them even asking if they can
having a conversation about some of my friends, the party girls I had
meet Jeffrey too. At this point in my life my heart went missing for a brought in to meet him. Jeffrey started asking questions about the
while and I stooped so low, I was even bringing my friends, I just saw
different types of drugs they used hearing them speak about it in his
them as easy commission. When I wasn't playing servant to my master, I presence. "I thought a person on drugs would be all strung out and
was partying hard, eventually using ecstasy pills, acid, and marijuana to
looking like hell, but the girls you know look great" he stated face down
disillusion the times I would've had away from Jeffrey to think about
during the massage.
what I was actually doing with my life. I realized something one day
That's when I told him I had been dabbling in ecstasy lately too, and I
while I was alone, although I had Jeffrey to attend to sexually, it was not
thought it was the most amazing feeling one could even fathom. I tried to
gratifying. I needed someone to come home to, someone I could call my
describe the euphoric feelings it gave me and even joked with him about
boyfriend and that showed me emotion not just a job to get done.
wanting to pet anything furry that was around and then there was the
constant need to flick my tongue-ring around my mouth. It was great
41 42
having such an open conversation about things Jeffrey had never her white uniform to reveal her beautiful nude body and a much darker
experienced before and he seemed okay with everything I was telling him side to her personality.
as we were having a good laugh together, so I thought I could push it a bit I couldn't believe it at first it was such a state of shock and I began to
further and tell him the truth about T .J, since it was bound to come out question t myself if this was normal in the massage profession to expect
sooner than later I'd rather not the latter, when it would look even worse this kind of clientele to request such degrading tasks even though they
that I kept the truth from him for so long. were professionals. At the end of the session she was paid $300 dollars an
"Well why were opening up about things together", I continued by additional hundred for helping to train me as well, and I was paid my
saying "I had met someone from my past and we have been hanging out a usual $200 dollars then we were both invited by Jeffrey to join him out
lot lately. When I haven't been travelling with you I have been with him by the pool for a cool dip. With Jeffrey making a few phone calls while
and I was wondering if you minded if I started to see this guy." He started her and I undressed again for a swim, I wanted to ask her a few personal
to laugh out loud, "Are you serious? Of course not, no one in this world is questions about what she's come to learn about the Massage Therapy
monogamous, why would I expect you to be?" I was smitten with relief, game, but I never got the chance as we were joined by Ghislane moments
but a little bit dis-heartened when I heard him speak that way and I later. She was asking how my training was going and booked the
wondered to myself if he'd had his own personal encounter with therapist in for herself in the following morning. Where she was invited
heartache. back to do another training session with me. It didn't take me long to
Of course the evening concluded in the same way it always had, the only figure out why.
reason I was really even there in the first place. Upon his request I I was at my apartment when I received a phone call from Jeffrey, I
straddled him on top of the table and let him explode with pleasure inside thought it was the usual call to come over to his house, but he surprised
ofme. Thinking the entire time about T.J, I felt so terrible but I quickly me. Instead I would be going to the exclusive hotel in Palm Beach
had to wipe the thoughts of guilt from my mind not to give Jeffrey the tonight, The Breaker's, where I would be meeting my first ever clients.
wrong impression. So I had myself busy with two men in my life, but Only told their first names I was given some instructions and the address
that's not what I really wanted for myself. [ wanted an occupation that where to meet Glen and Eva. They were a married couple with one on the
would eventually set me free from depending on a man as my source of way. I was quite concerned when I heard she was pregnant, being I really
survival. didn't know the body that well and didn't want to inflict any wrong doing
I asked Jeffrey before I left for the evening, when my real training was on the unborn baby but Jeffrey insisted I take this job. Just massage her
going to begin and he liked my assertiveness. I thought it meant to him gently where she wants to be rubbed and to save all ofmy energy for
that I was taking my job with him seriously, but it was all part of his Glen's massage, since it was going to be a four-hour job. In an
master plan to keep me by his side. Within a couple of weeks ofmy emphasized tone of voice I was being coached by Jeffrey to treat Glen
persistence, Jeffrey introduced me to a couple of real working massage with exactly whatever he wanted, just like I do for Jeffrey himself. It was
therapists, not only with credentials but with their own clientele too. I my last bit of preparation before he sent me out to his friends and my first
was in awe of their teachings, it all made so much sense about the body taste of responsibility in upholding his reputation.
and what they were saying. I felt like I had picked myself up out of the At around seven pm I took a taxi to the address I was given and found
lurches and had a direction again. them on the residential side of the giant hotel's extensive property. When
I was in the middle of another training session, with Jeffrey the I arrived in their apartment it was a far cry from the lavish place I was
recipient as usual, being it was rare for Ghislane to ask for a massage expecting, still really nice but had a cozier family feel to it. It was just
unless of course it was for Jeffrey's own pleasure to watch the punch line beginning to get dark when Eva and I went into the Master Bedroom and
of the session, when I was shocked to hear Jeffrey ask one of the she undressed to reveal the first naked pregnant body I had ever seen. It
therapists to now remove her shirt. He had no shame I thought. Even was fascinating to see her in the later stages of maternity, and strangely
though she was above his usual age criteria, she was still a pretty woman enough it was a miraculous and wondrous sight. She was a former model
in her early 30's with curly blonde hair and had an athletic body for a and one of Jeffrey's many entourages from his past that had gotten to old
mother of two children. She didn't hesitate in his request. It looked like for his taste and was married off to a wealthy colleague of his.
something out of a role-playing porn scene with the therapist removing Lying down on the bed I adjusted the pillows to try and make her more
comfortable and I began to massage her as Jeffrey had instructed me to,
43 44
softly and slowly. So at ease with her nude body she even asked me to Lying out on one of the pool decks blue and white striped lounge beds
massage her swelling breasts, in a non- sexual way. Not knowing any I was waiting for Jeffrey to finish his business so I could give him his
other way but that way, I was trying to oblige in her request doing the massage. He never took too long with his work, unless there was
very best I could to relieve her but couldn't help but giggle to myself at something wrong and then we would all have to wear his mood but today
the very sight of this. She said she was very happy at the end of the he seemed fine though, when we went up the stairs he told me we would
massage and rolled over to go to sleep, asking me to tum out the light at be leaving for his ranch in Santa Fe', New Mexico in the morning and I'd
the end of it. I closed the door gently as if not to disturb her, and went to need to be packed and ready tonight. They loved leaving in the spur of
find my other client. the moment, Jeffrey once said he checks with his pilot Larry on the best
The apartment's lights had been turned out for the sleeping children and weather before he heads to a different destination. I enjoyed spending
I found Glen awaiting for me in the lounge room where I had to call out time at his ranch being it was my favorite of all of his residences. He had
"Excuse me?" as I couldn't see him in the dark. There was a throw rug on a lavish Mediterranean looking castle on top of a hill that over looked his
the ground that he had already placed out as he began to strip down in extensive 7,500 acres of property. It has an indoor pool, gym, and all the
preparation of the massage. Lying frontwards facing me with his exposed trimmings of extravagance I could only imagine. I had a great time on the
and ever growing manhood, l asked him to roll over to begin the quad bikes, Sarah and I often got scolded for tipping one over going to
massage. He complied with a cheeky smile and from his eagerness to fast or trying to go up a steep hill, but we knew those weren't the things
show he was not shy indeed, I already knew where this was going to end he cared about, so it wouldn't matter. My favorite of it all was his little
up. town with it's own fire station and truck, stables full of horses, and little
I found it much more strenuous to massage on the floor but I wouldn't cottages where the housekeepers and ranch hands lived.
let that hold me back I wanted to have a career and this being my first On my own time I would take one of the quad bikes down to the
ever clients, I didn't want them to disapprove. Nearly four hours after I stables and saddle up on one of his beautiful horses and go for a ride in
had gotten there I was still hard at work. Mentally preparing for the end the open terrain. It was coming up to the end of a very cold winter and it
of the session he let me know when he was ready to begin the other side still had the snow covered mountaintops and brisk air that I loved to take
to my job and just like Jeffrey did the first time, he requested me to take in during my many trail rides. I have been an experienced horse rider
off my clothes starting with my shirt. When I complied, the requests kept since my childhood, and could honestly pinpoint some of the best
coming in and before I could change my mind and run away, I was memories of my life being on the back of a horse. 1acclaimed with thrill
having intercourse with this man that was so comfortable doing all of this in my voice "Great, I'll get packed as soon as I get back to my apartment"
while his pregnant wife and children slept in the room beside us. When he threw in "Pack for a few weeks, as we will also be making a pit stop
he had climaxed, we both got up and dressed and he paid me a large tip to L.A for some business afterwards and then to N.Y.C." I was used to
even though Jeffrey would be the one to actually pay me for my time these round trips with him, it was great as I was saving loads of cash and
spent there. Just like it had all started, it had also ended so quickly and about to buy myself my first car.
now that was that. I had to accept what my duties were and now I could Jeffrey, Ghislane, Emmy and I all left the following morning, as
go back to Jeffrey who would be further pleased in my demonstrations to planned. Arriving in only a few hours at his awe-inspiring Santa Fe
keep him happy. Palace was always a delight. Still frisk in the air, my petite frame looked
I was called the next morning to come over to Jeffrey's mansion that even smaller in these gigantic overcoats. Nonetheless I was looking
afternoon for lunch, a swim and of course a massage session. Knowing forward to spending time out in the fresh clean air and open land. After a
all too well they'd be expecting the gory details oflast nights events with few days of leisurely spending our time on the ranch, we went to the
my new clientele. I came there at 1pm as requested and sat down for a Indian markets in Albuquerque for a bit of shopping and sight seeing.
light lunch and a swim. Jeffrey was mostly conducting business from his Jeffrey wasn't the most off road kind of guy, so when we went sight
offside pool office, but he came to ask me if everything went well the seeing it was more like museums, boutique shopping, and local art
night before. I told him I did everything asked of me and I am quite galleries. Still a splendid trip though. With me picking up a few nifty
confident both my client's were more than pleased with me. He gave me collectables to bring back for my family and knowing how much my
a quick grin, before he headed back to the office, throwing a purple grape mom loves Indian apparel, I thought it would put me back in her good
down his throat as he walked away. books for awhile, I hoped at least. There was some lengthy time to put a
45 46
little water under the bridge between my folks and I. With my life something he'd say nice to all the girls, but in the time I had known him I
heading in a different direction I didn't see any use in holding on to so could honestly say it wasn't like him to compliment girls in any other
much hate especially that I didn't even have to see them that much. way than regards to a sexual performance or their looks. I was flattered at
We got back to "Zorro Ranch", the name Jeffrey chose to call the his praise and when the massage was over, so were the sentiments. I was
massive land he bought to build his fortress on, and Jeffrey told me that back to being used for my body and what I could do with it.
he was looking forward to one of my famous relaxing massages and with With him satisfied and off for a nap, I could go do what ever l wanted,
that notion he gave my bags of shopping to one of the many housemaids like usually I would go down to the stables or something adventurous, but
who greeted us at the front door and asked her to bring my bags to the today I was in a melancholy mood,just wanting to relax and unwind
exquisite room I was staying in. We headed straight downstairs just past myself in a giant tub in my bathroom. I got out some of the oils I used on
the massage room and gym there is an indoor heated pool, shower and Jeffrey putting them in the steaming water and popped two of my Xanax
spa. First Jeffrey wanted to wam1 up in the spa underneath a decorated pills, forgetting about my troubles and focusing on the quiet moment at
ceiling of clouds and blue skies. Starting the massage in the spa I rubbed hand, just wanting to soak up the peacefulness of it. Nearly slipping away
his feet while he reclined into the spa's jets. We spoke of the museum and to sleep in the tub, I was startled when I got the call on the intercom to
some of the knick-knacks I had bought and I thanked him for the come down for dinner.
turquoise earrings and necklace he had got for me as a gift, joking about Everybody seemed in good spirits at dinner, which helped to lift mine.
not ever knowing what to get for him, being that he was richest man I'd We all ate our meals and went into the movie room to watch a newly
ever known. By no far means did we ever have any kind of a mutual released movie. It was a ritualistic scenario, most nights that everyone
respectful bond between us, but there was a significant softer side he was at ease we would all sit in one of his various located movie rooms
began to share with me that was different from how he treated his other and hang out together. Just as he always would Jeffrey asked Emmy and
girls. Maybe it was my feet that filled the shoes for that time being, or the me to both grab a foot during the movie that night and just keep
fact my novelty hadn't worn off yet, but what ever it was I was getting massaging through the film. We were always on call for duty, no matter
confused from the double-sided life I was leading. where we were or what ever time it was. He would just plop a foot up or
He got up from the spa tub shortly thereafter and asked me to come pass over his hand at any given time and require a massage, even if the
wash him in the shower. It was nothing unordinary to me, I was used to film went on for over two hours, I would still be required to sit on the
his need to be nurtured and pampered. l perfom1ed his request with a floor rubbing his feet or hands, and even his scalp at times. After the
cheerful mannerism, letting him think I was taking care of him out ofmy credits had rolled Ghislane got up to close the door to the room and I
sheer sweetness. I got the towels ready for him to get out of the shower knew she had received the signals herself and would proceed to
and towel dried him, patting his skin instead of rubbing as previously manipulate, violate, and use us to satisfy Jeffrey's urges once more before
instructed. "You know you have a very maternal instinct, you'll make a he went to bed.
fine mother someday", he would constantly acclaim at my gentleness. "I The blue illumination from the empty T.V screen was glaring in the
hope so" I replied, I would love to have my own babies one day, but not tenebrous room as we watched her undress in a light that relied on the
any time soon". Laughing at the very thought of that. reflection of the moon through the windows peek to show it's proceeding
We walked up the steps and through the French doors into the gym's display. She walked back to the sofa where I was sitting at Jeffrey's feet
adjoining massage room. It was smaller room than in his other houses, still rubbing away and uncovered her shirt displaying ample bosoms for
placing the emphasis on the large massage bed in the center. I grabbed his appeal. Approaching me like a lioness hunting her prey she stood me
another clean towel to keep him wam1 while I prepared the music, lights, up and led me to the other couch across from Jeffrey and situated herself
and oils. He liked me to use mostly lavender or other aromatherapy on top ofme, sliding her fingers through my dress to unbutton my attire,
scents, which reminded me of woodlands in the spring. Always enjoying revealing my girlish figure and two small peaks. Pushing my head into
the beginning of the massage, I put my heart and soul into training in my her breasts I was being fondled by Emmy at the same time, which took
profession. I could just close my eyes I would see only with my hands the her cue when she saw Ghislane look in my direction. From an occasional
areas that needed the most work, and even though I wasn't a professional glance upwards, I could see that Jeffrey was up to his methodical foreplay
yet, Jeffrey could feel and told me there wasn't many that could please stroking his manhood while watching the build up to his main event.
him during a massage being untrained. I'm sure now it was just They both took turns making me moan from their touches and when
47 48
CONFIDENTIAi. GIUFFRE004 I 80 CONFIDENTIAi. GllJFfRE004181
Ghislane was ready too she would insinuate we do the same to her. She Jeffrey and I left two days later, heading off to Carmel in California for
urged me downwards, until my head was between her opened legs and a business trip of his, leaving Ghislane and Emmy to catch a commercial
giving into her wanton indulgence. Twenty minutes passed before Jeffrey flight back to N.Y.C, where we would meet up with them later. When we
exerted his last energies for the night, the only advantage of being with an arrived at the hotel we were given badges for the meeting tomorrow and
old man was they could never last long. settled into our rooms. We got adjoining rooms, keeping the doors open
Departing to our own separate quarters for the night, I called T.J for at all times, but sleeping in different beds. He liked sleeping alone, even
condolence. It was so important for me to feel like I had someone out after a late night session I would always go back to my own room. I think
there who saw me as more than a pretty girl with vulnerabilities. I needed that's why he liked me so much I never put pressure on him to become
to maintain some sort of a connection to my youthful side. But it would intimately more than what we were already, never giving him the
be to no avail as I was getting used to being badly disappointed by all the impression I wanted more than what we had. It seemed to keep him
men in my life. happy just the way we were together. I hung out with Jeffrey that night,
going to a restaurant for dinner and afterwards watching a movie back at
Chapter 8 the hotel.
The next morning we went for an early morning breakfast before the
conference and Jeffrey gave me some money to go shopping instead of
The phone nearly rang out and as I was about to hang up the receiver
attending the all day meeting with him. I was more than obliged to accept
when he finally picked up. On the other end of the phone I could hardly
his request, and wished him a good day before planning to meet back in
hear T.J above the background noises. When I asked where he was he
told me "At our place baby", meaning the apartment Jeffrey had rented the room around six pm. He gave me five hundred dollars. He said it was
for me to be staying in alone. He already sounded off his chops just enough to go have fun for the day and a girl ofmy means could find
plenty to do with that kind of money. I walked around the many
elongating his words and slurring his speech. There was music pumping
boutiques that lined the streets of the picturesque cozy town, and picked
and people shouting behind him and every one sounded like they were
having a great time. I was so sick of his friends coming over using my up some bits of clothing here and there and even met a girl who was
passing through on a road trip. She was somewhere in her late teens with
house as a place to party and then trashing it so bad I would even have to
golden sunshine tresses, olive skin and blue eyes. Her name escapes me,
sometimes throw my furniture out. I blew up at him over the phone and
as it was so unexpected, 1 think it was Tina or something like that but she
threatened to kick him out, back to his parent's house, so much for my
relaxing evening I thought to myself venturing on to tell him "You leech was your typical California carefree chic, offering me a few tokes of her
jay as we ducked down a side street together. I was so happy I had met
off me using the money I leave behind for you for drugs and throw these
gigantic parties while I'm away." Also mentioning the disastrous messes this girl, as she was fun spirited and charismatic a relief from the social
I would come home too. "I am so close to ending it with you", I would expectations I had come to know lately, but always being "on-call" as I
had been trained up to be, I ended up inviting her back to meet Jeffrey at
openly threaten, but he knew better than I did, that I just couldn't bring
our hotel later on as a surprise for him. Maybe she was just a bit too
myself to do so, needing some attachment to my youth through all of this.
carefree for Jeffrey's taste but anyhow she was pretty enough to let him
"Don't worry baby" he would say attempting to soothe me with his false
words going on to tell me how much he was missing me and how he was be the judge of that matter.
Over the next hour of hanging out together I found out that she was on
always thinking about me when I was away which was like all the time.
I would soon be buttered up and soft for serve. This was my penalty for a road trip with her best friend who was still sleeping off the hard night of
partying from the night before. She was originally from the southern
choosing a guy that accepted my lifestyle with my "Other-Man" as I had
states as she had a bit of draw still left in her accent, and she had recently
so eloquently put it to him once as not only acceptable but deemed it
left her boyfriend because he was leaving for a college too far away not
"Cool". The conversation ended with an easy good-bye and no "I-Love-
believing in long distance relationships. Then it was my tum to dish out
You's" or anything sweet. We weren't those kinds of partners yet, so
much time spent away from each other and the lifestyles we both led, I my contribution to the conversation of getting to know each other better. I
always got anxiety before I would tell a girl what I did for work and
couldn't expect much more from him than what we already had.
romance (as such), morally I was ashamed of who I was especially with a
girl having led somewhat of a normal life. Next, as always, I expected to
49 50
be probed with so many more questions and having to make Jeffrey collared shirt and put on his normal attire of sweatpants and a sweatshirt.
sound ideal and hot for the taste of a young girl and knew I would be Ushering him out the door for dinner when he was more relaxed I was
point blank lying, so I told her some of the truth which was that he was lucky when he said he was starving and quickly got dressed. We just
really rich and paid good money for a massage and useful to have around found a quite spot to eat that was next to the wharf and got back to the
as a contact. I told her he'd give her two hundred dollars for a two-hour hotel just in time for our surprise guest. He wanted to go have a shower
massage with me leading the way and warning her he was known to be and settle down for a massage, so I told him I'd join him in a minute, I
frisky during the session. Unexpectedly she said she could use the money just had to make a phone call real quick which he thought was odd and
and then came the part that I hated the most, but had to do so they asked me if everything was alright, I reinstated that I'd just be a minute,
wouldn't be as shocked as I was the first time I had met him. "He does trying not to let on about anything. The knock came quietly on my
like us to be nude though and sometimes asks for more than just the room's door just on time, as we had planned and I told her my idea to
massage itself'. All I could do was wait for a response after a shocking surprise him. I let her into the bathroom where she orchestrated my plan
sentence like that, and depending on the girl, most were sadly taken back perfectly. Jeffrey finished his shower without me and when he called out
by the money. Her carefree attitude seemed to disillusion for a moment for me I told him that I needed him to have a look at something in my
when she gave it some thought and asked me "He's not like, fat and ugly, room real quick. Not giving in to what it was that he would be looking at,
is he"?"" No ... no ... not at all" I replied, "He's got more ofa Richard he came into the room where I opened my bathroom door to reveal a
Gere appeal to him". Trying to make him sound a little more measurable beautiful nude girl bathing in a thick amount of soap bubbles in my tub
than just a rich old man that likes to be with girls younger than half his looking at him with an alluring intrigue. His grin went from ear to ear
age. "Well then, what time shall we meet tonight"? She asked next. when she stood up and introduced herselfletting the bubbles run down
Great, 1 thought, Jeffrey would be most pleased with my find. "Knock on her glistening body at an ever-slow pace. It was a proud moment for
my room quietly, you're going to be a surprise. Be there at around half Jeffrey, I had done well in his eyes, and she was not like the other girls I
past seven tonight and I will introduce you to Jeffrey". She threw the butt had brought to him before, degraded from a lifetime of abuse off the
of the second jay we shared in the bushes and we strolled into a streets. This girl was exactly his pro quo looking sweet and innocent as
homemade fudge boutique to get some relief for the munchies we now the girl next door. My efforts were to show him I knew that my only
had. responsibility was to keep him happy at all costs. I led her through the
When I got back to the hotel at around a quarter to six o'clock pm as massage on Jeffrey and of course afterwards gratifying his perversion
requested I'd be, nobody was back yet, so I took the time to set up the with his lustful requests to be fondled and watch us become more than
oils and bath in my room for his massage tonight. I thought I would plan just friends. I didn't feel too bad at the time with his coercion providing
it so the girl would be cleaning off, as Jeffrey liked before he had sexual many financial rewards making his scheme enticing to a young,
contact with a new girl and he could walk in and be surprised to find a impressionable teen not realizing the terrible memories left to come from
strange beautiful girl in my room who wanted to massage him. Jeffrey all of this. Afterwards he paid her the usual two hundred dollars he gave
walked through the door not long after I was done prepping for the night to everyone for their time and took down her name and phone number
ahead, looking like he had a rough day at the office, which was very rare writing it in his infamous little black book of the contacts he met in every
for him. He sat down on the bed and I asked him how his day was. He city but only the ones he really liked made it down in his records.
didn't want to talk much about it, saying it was boring and long, rather We went out the next afternoon as I had suggested last night and we ate
asking what I got up to for the day. Being coy about having a jay and his our clam chowder breadbaskets over looking the wharf's bay, watching
unexpected surprise to come, I told him it was a great day of shopping the seals playfully barking at each other on the rocks nearby. Shortly after
and sight seeing and I even brought him back some local made fudge we were driven to the private airstrip and took off for Los Angeles. On
from the shop that had fulfilled my chocolate cravings only hours ago. the plane was an unexpected visitor. Matt Groening the producer of the
Telling him of the places I ventured into I mentioned to him "We'd 'The Simpson's" T.V show was catching a ride with us. I was so excited,
have to hit the fisherman's wharf tomorrow. I saw some locals walking as I loved watching his show and acted like a star struck fan, asking him
around with breadbaskets filled with creamy clam chowder and it smelled everything from his initial idea for creating the show to where he got his
absolutely scrumptious." He said if the weather were nice we'd check it characters from. He told me it was all based on his own family make up,
out tomorrow before we left for L.A. He wanted to take off his jeans and
51 52
but without the crazy father and son scenes of Homers hand around Bart's apartment that Jeffrey rented for her on Malibu Beach. This was the first
throat. time Jeffrey came to visit and when we got there you could see why. It
I was enjoying our conversation, when Jeffrey insisted that I give Matt was a tiny one-bedroom shack, too small for his likes of accommodation,
a foot massage throughout the duration of the short flight. I never turned but she loved it and it was plain to see why, the waves lapped underneath
down a client but when I saw the shape of his feet, I nearly threw up at her porch twice a day, what else could anyone want. Before even walking
the thought of having to touch them. He had yellow crusty toenails that through her door, you could hear the commotion of excitedly screaming
even someone with a chainsaw would've had troubles cutting through females voices coming from inside. There were about five other girls in
and then there was the fluffy balls of leftover pieces of sock wedged Sarah's living room and she had invited them so Jeffrey could have a few
between the crevices of his sweaty toes, now that was the real icing on different girls to choose from. Jeffrey looked at Sarah and smiled, aren't
the cake for me, no way could I attempt this I thought. Then I had an you sweet, as all the girls rushed to introduce themselves, hoping for the
idea. I went to the back of the plane and rinsed a wash cloth in warm opportunities Sarah had offered them to come in the first place.
soapy water and returned for his dreaded foot massage but not before We all had some coffee and biscuits while the conversation kept getting
attempting to clean them first. louder and louder, every girl trying to talk over the next one. Jeffrey
In return for my services Matt was kind enough to draw me two quick could handle only so much of that before getting too annoyed. Instead of
sketches on blank paper from his briefcase ofmy two favorite characters, choosing one of the other new girls, Jeffrey wanted Sarah to show Nadia
Homer and Bart. I asked ifhe would make them out to my little brother and I into her bedroom. He was anticipating the introduction of his two
and dad, the true fans of the family not missing an episode during dinner favorite girls together, what mischief he had hoped we would get up to
over the past ten years or so. Next to the A-4 size drawing he was able to was apparent when he asked where Sarah had kept her play toys and not
fit in the quote 'To my greatest fan from Matt Groening" and their names the fisher price ones. Sarah brought out quite a collection of her personal
next to it. I knew they'd absolutely love it, and it was such a nice gesture toys and was giggling on her way out as she shut the door. Suddenly the
his feet were no longer an issue as I laughed it off and even made a joke room behind us went quiet, probably hoping to catch a moan or groans
to the comedian about getting a pedicure before hitting L.A's beaches. too laugh at and I felt so degraded having everyone knowing exactly what
The flight was only short and we arrived in busy L.A within the hour, was going on. Knowing my duties well I was baffled this time as there
saying Good-Bye to Matt, who was a pleasure to meet. Jeffrey had a was no ritualistic massage wanted. He immediately instructed us to start
meeting at a production studio for one of the girls he was keeping lured in kissing and fondling each other with the provided toys straight away
his grasps, so we were off yet again for more business. We were staying seeing his excitement grow watching us try and out do the other one with
with one of his old girlfriends, Jeffrey's code for "She got to old for my pleasure, he couldn't keep restraint any longer and started to have
taste, but was still nice enough to keep around". She was a tall blonde intercourse with the both of us, taking his erect penis out of the other to
with blue eyes, a stereotypical Barbie doll. In her younger years she had only swap to the other girl, back and forth. This continued for a good
been a successful model and now lived on the beaches of Santa Monica fifteen minutes or so while we continued to engage in lesbian acts on
with a sweeping view of the oceans landscape as her backyard. each other while the other girl was being subdued by Jeffrey's thrust's of
The next morning Jeffrey and I went out to breakfast. He said Sarah penetration. Nadia was just as dutiful as I was in fulfilling his demented
Keller, would be joining us with another one ofJeffrey's girls I hadn't requests, willing to lend her body to Jeffrey and those he sent her too, for
met yet, her name was Nadia Bjorlin and she was a Yugoslavian model the sake of keeping her acting career and putting on a good act at that.
turned aspiring actress, with the help of Jeffrey, as he so proudly She was never competition though. Once I found out where she actually
remarked at the table before they arrived shortly thereafter. She was a came from I took pity on her for the similar life of servitude we were both
stunning brunette with olive skin tones and shocking blue eyes. By far accustomed too and not that we ever became good friends but we had
one of the most beautiful girls I had ever met before. She and Sarah reason to relate to each other.
approached the table, shopping bags in hands already in the early hours of Later on Jeffrey, Nadia and I went to a production studio in L.A, where
the day. They both pulled out a chair and showed us their new pair of we had to meet with Nadia's agent as well as the producer of"Day's Of
Jimmy Choo's they had bought on their way here this morning, and Our Lives". The meeting lasted five minutes, with everyone in consent to
excitedly asked for Jeffrey's opinion. He loved the doting attention and the proposal. We flew all the way out there to talk about money, only to
anyone who could make him feel important. We all went back to Sarah's be leaving that evening back to N.Y.C. On the way to the airport we
53 54
CONFIDENTIAi. GIUFFRE004I 86 CONFIDENTIAi. GIUFFRE004l 87
stopped at a fifties looking diner and got a cheeseburger and vanilla Chapter 9
milkshake, the first and only time I saw Jeffrey eat what I considered to
be real food. Seven lanes to drive in and the freeway was still lined
We met Ghislane and Emmy in N.Y.C, and it wasn't a blissful reunion
bumper to bumper in the heavy rain. The sound of downpour on the
as J hoped for, wanting a break from all of this J was just looking forward
rooftop of the taxi and the rhythm of the windshield wipers was making to getting back to Palm Beach, not leaving for a further four more days. I
me sleepy. l was looking forward to sleeping through the long flight
got home late in the evening as Jeffrey invited me out to the movies after
back. Thank goodness we had a private jet to catch back, the trip would
we had relaxed at his house for a while after landing.
be comfortable and not rushed to get there on time through the daily peak
I put my keys through the door to my apartment and walked in to a
hour traffic. Jeffrey asked me what l thought of Nadia, more of a kiss and quiet house. Not thinking anyone was at home J set my suitcase on the
tell kind of thing for him, so proud to admit some of his tenacious acts of
floor and put my cell phone on charge as I always did to be accessible for
pedophilia to me that J knew most people would be embarrassed to even
whenever Jeffrey or Ghislane could call. J went to get a drink out of the
think aloud but I said what he wanted to hear when he asked me what I fridge when I heard some noises coming from the back ofmy apartment
had thought of her on the way back. J replied, "She is attractive, funny,
where my bedroom was. I started back there and slowly turned my
and seems to know what she is doing with you." Laughing at my
doorknob to reveal T ..Ton top of another girl. When they noticed they
statement, he then started to tell me the history behind where he got her.
weren't alone anymore, T.J got off her with promptness. I recognized the
Five years ago when she was merely a teenager just turned thirteen. Her girl from seeing her around at parties, and she was the town lowie,
father had recently passed away, leaving Nadia's mother in a tremendous
scattering her trail of guys along with her presumable diseases, and I
amount of debt and living in a third world country, she didn't have the
wasn't shy to verbalize that when she tried to open her mouth and calm
means necessary to raise her own daughter. When Ghislane approached
the heated situation between T.J and L She didn't like her cards on the
Nadia for the first time at a music school, she seemed like a maternal,
table in front of the guy she was screwing around with and got up in a fit
caring stepmother. Telling Nadia's mother if she let Nadia go with her,
of rage to attack me. Still nude with only my new white sheets to cover
she would se to it personally that Nadia receive the best education and her body, I threw her out of my house along with T.J. "J have been
chances in life to make it. In her customs it wasn't odd for a young girl to
paying your way for months, only finding out your sleeping with the
be married off to bring the family good fortune, so she kissed her baby
biggest slut in Royal Palm Beach, at least have some dignity and higher
girl good-bye and sent her off to commence her life of servitude. l sat
your standards." I didn't really have a leg to stand on since I had started
there speechless listening to Jeffrey brag about his endeavor to get her
this relationship giving him the knowledge I had a sugar daddy to answer
over here, shocked that he could stoop as low to use a barely teen to
to above him. "You're gone all the time and with that old man, what did
oblige his sexual desires. He was laughing and giddy as he replayed the you expect me to do"? He was right, l wanted what I couldn't have, but I
memories of her arrival over in his head, painting me a horrific picture l
needed some time to cool down and accept my situation. I loved having
had no choice but to imitate a smile to face him with. T.J around to come home too, and he used to be my best friend in my
No pretty girl is safe from the allurement of these villains procuring the
school days. I convinced myself of the lies I continued to accept.
youth off of every street in the world. J knew that day more than ever
Days later J was still not speaking with T.J, mentally adjusting to my
before those morals did not exist for people like this. Jeffrey once told me circumstances, J thought I'd have the day off to relax since J hadn't been
that every girl he has had sexual relations with has benefited in their
called all day. Until about five pm when Ghislane called and said Jeffrey
career, finances, or an achievement in marriage with a successful would like a massage in an hour. Grudgingly I got up from relaxing on
colleague of his. Mine was the massage career, ever so often still giving
the couch, got dressed and put my make-up on, meeting Juan downstairs
me a lesson from a professional, which kept me quiet for a while longer.
a half an hour later. Jeffrey was already lying on the massage table when
I thought I was already knee deep in this world, if I gave up after putting
I walked in. I started the massage being very quiet from my somber
myself through all of this hell it would've all been be fornothing. So I
mood, when Jeffrey picked up on it and said "you know it's not good to
treaded lightly, constantly at a risk of being replaced by another willing massage people when you're angry, you could pass on negative energy".
participant and playing the eager student he wanted me to be.
I wasn't sure ifhe was serious or just trying to be nice so I could speak
about what was bothering me. Ending up not being able to contain my
55 56
emotion any further I told him what happened with T.J and broke down dilated into little black diamonds. We were all having in depth
in tears, a little heart broken from living in such a lie. He turned around conversations about life and where we would all end up when this
from his massage and sincerely paused for a second thinking he was charade was all said done. Nobody got to sleep that night as the room
going to console me but instead he laughed at the very prospect ofmy slowly dwindled in numbers as people were finding their way home to
notion that monogamous relationships ever existed. "Are you serious, he recover from the repercussions of drugs wearing down out of their
was only doing what every guy in the world does, you can't hold that intoxicated system.
against him". I replied in a lighthearted gesture "whose side are you on When I flew out to N.Y.C to meet Jeffrey the next day, I was still in a
anyways"? His answer stuck with me for many years to come "I'm on horrible state. Not knowing what was wrong with me, thinking it was just
your side which is why I'm going to save you a lot of grief with this one a bad come down, I rushed out of the elevator and down the hall to my
tip, Never expect a man to be faithful and you '11never be let down, it's room, sweating profusely, to make it just in time to the toilet to throw up
just the way us men are genetically imprinted." The remainder of the bile again for the uncountable time since getting off the plane. I was
massage I had to pretend like I wasn't further saddened by his response, having intense cramps in my stomach and when I was called down to
but in fact having to act enlightened. I would never come to him for any meet Jeffrey in the massage room, I had to decline for the first time. I told
other relationship advice, ever again. He told me I'd be fine if I just the housekeeper that I was feeling very ill after the flight, maybe some off
listened to my mentor. He still loved role-playing the teacher and me the food for lunch and needed to lie down for a while. Nobody came up to
pupil, like the old days before he got rich and only used to be a college check on me for hours or even called. Waking up from my much-needed
professor. I finished the massage and fulfilled my sexual duties before nap, I pulled back the expensive white sheets to find myself in a pool of
being sent home wanting to collapse in anguish. my own sweat and blood. I was covered in the red stains that drenched
T.J was outside my apartment door when I got there, his mom waiting the pants I was wearing. I had no idea what was going on, I could only
downstairs in her minivan just in case I kicked him out again. He pleaded focus on the dire amount of pain I was in. In between the heaves of
his guilt and promised that he would never see her again, agreeing with throwing up and crying simultaneously I was able to reach the phone and
me that she was the town slut and he screwed up big time. I let him back called the housemaid on the intercom. I told her I needed to go to a
into my apartment and back into my life for that matter but more aware of hospital immediately and slammed the phone down only to fall back to
the world I was being led into believing was of normal conduct accepted the floor hurdled in a ball. She didn't hesitate in calling Ghislane who ran
by everyone in this sick world. Jeffrey was going back to N.Y.C and told up to see what was wrong. Ghislane then called Jeffrey who was in his
me to have a few days off before his assistant at his office would arrange office at the time and told him to hurry up to my level, stressing to him
an E-Ticket on a commercial flight for me to join him later in the week. I that it was an emergency. Thinking they really cared about me for the
hadjust made loads of money from my previous trip and wanted to relax first time since I had known them, they came with me to the hospital with
like any teenager does, so I threw a hotel party that weekend on Singer me. Now I realize I was only a liability in getting them caught and they
Island in Rivera Beach, inviting only a small group of friends to begin needed to get to the doctors before I could say anything incriminating.
with. They were suspecting the worst now and seeing he never wore a condom
The hotel room quickly filled up with a flood of teens and the pumping with me and from our previous conversations they knew I always made
music was blaring. The room had a balcony overlooking the pool and the T.J wear one, they feared the situation at hand.
beach that became the smoker's section. I wasn't a real smoker at that When he saw the catastrophic state I was in at that point, it was the
point, preferring to have a puff of a spiffed blunt instead so I made it my housemaid who helped me get up and assisted me down to the car where
rule to go outside trying to prevent holes in the carpet, but it didn't last Jo-Jo was waiting for me. He drove us to either Lennox Hill Hospital or
too long when our forbidden walls came tumbling down. Making so Mount Sinai, I can't remember, as it was so blurry in such a bad
much money that I could supply my wild parties with an assortment of condition. Rushed in for immediate testing I was uncontrollably vomiting
drugs like trips, ecstasy, and coke as well as an abundance of alcohol, that and in so much agony, I was given an injection to help me to subside the
T.J had all the contacts for, made my fellow teens admire me. It definitely intense pain. A nurse came in to ask who would pay for this and although
gave me a head swell, thinking here I was so young but so grown up I insisted my parents insurance still covered me, Jeffrey persisted that he
already with all ofmy peers from high school looking up to me. In the take care of all the medical bills and gave the nurse his information.
wee hours of the morning we were all still going hard with our eyes
57 58
When the pain relief kicked in, eve1y1hing and everyone dwindled compliment the sights mother nature that appealed t.o us . l didn 't feel as if
away until I felt like A lice in Wonderland who just swallowed the I owed this strange r anything but what was expected of me by Jeffrey and
shrinking tablet and everyone standing around me seemed to move so I cou ld be polite, I just couldn't be myse lf.
quick, speak so loud and hover above me. When I awoke from my We got back to the main vi lla to see what time dinner would be se rved
induced state, I was alone in a different room. No t knowing at all wha t so we could have time to unpack and clean up befo rehand . We both met
went on but feeling a little better, I called in the nurse who looked at six pm for dinner on the outside veranda. He sat at the head of the
through Illy charts and checked my vita l signs. Then told me the doctor table and I sa.t next. to bim, politely folding my napkin to put in my lap.
would be in shortly to iufonn me of the conclusion to my illness. The first time Jeffrey and Ghislane had see n me cut meat and eat with a
He was a tall man with dark hair, and a hardened look about hin1 fork and knife they we re so appa lled, making fun of my unsophisticated
obviously from his job and constantly seeing the worst ho1ro r stor ies man habits. Ghislane took the fork and knife in her hands and proceeded to
could think of, he just bluntly told me I had miscarried in early stages of show me how to politely cut my food and eat.. Now that my mannerisms
pregnancy. I should be fine lo go hom e as soon as my course of had improved they wouldn' t have to be worried about my etiquette when
intravenous antibiotics was comp lete. The new s sun k in fast and hit a someone important was around anyone . We both drank the red wine
deep nerve. I waited for the docto r to close the curtain befor e I let out any suppl ied on the tab le and it seemed to warm me up on the breezy night.
emotion and cried for my disas trous lifestyle that. was dragging me into a By the time dinner was served and another red wine bottle later, he
world that I wanted to break out of. This reoccuning cycle of bel ieving I seeme d to get funnier. I made fun of his tousled hair and he poked at me
needed men like Jeffrey to succeed in my life was draining the last bits of for my skinny legs, calling me a wanna-be- anorexic. When desse1t was
sens itivity left in 1t1y heart. I was picked up by Jeffrey himself who took brough t out, he asked ifhe could receive one of the delightful massa ges
the doctor alone to the side of the busy hallway to have a private he has been hearing about from Jeffrey. I gulped more red wine down and
conversa tion about someth ing. Jeffrey wasn 't comfort ing at all, instead he sweet ly comp lied with his offer . dreading the moment I'd have to see his
sent me back home to rest for a couple wee ks, and I only fell deeper into naked body, let alone touch it. I aske d the house kee per Kathy that had
a depress ion, using all forms of self -medication to treat. my sorrows. been serving us that nigl1t to please have someone set up a massage bed
Two weeks later, as if Jeffrey was trying to lighten my spirits, he to ld in one oftl1e cabana 's. I went to my room t.o down a few Xanax, telling
me I would be going to his island to meet a new client. He is a Harvard him I wanted to freshen up after dinner but to meet me in his cabana in
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him showing him arou nd the island, dining with him. and treating him to later, wit h the effects of the tab lets mixed with the red wine. and I wou ld
a massage whenever he wanted. Without Jeffrey even verbalizing the be free not to feel anything . He was still dressed when I got in tl1e cabana,
need to have sex with him, he to ld me to keep him happy like I had my obvious ly not accustomed to d1is and a lot shyer than what I had been
first client . l packed my suitcase with island apparel, and kissed T.J good- used to. I told him he'd need to undress and lie face down on the tab le.
bye, who had at least offered me a wann embrace upon the news of my putting a towel to cover his bare bottom to prevent him feeling
miscarriage but none other than that know ing it wasn 't his. embarrassed during the massage. I gave the massage my earnest as I
Stephen was a quir ky little man with white hair and a mad scientist look always had , and quickly got through having intercourse with him. Not
about him. We arrived separate ly and I gree ted him when one of the wanting to make any forep lay or anything ex travagan t out of it, I let him
housekeepers picked him up from the airport and arrived by boat, instead think that' s as good as it got, and by the smile on his face, rthought I had
of he licopter as Jeffrey and Ghisla ne often arrive on. We made our done enoug h.
acquaintances and he looked as ifhe was tripping over himse lf wi th Tiie next day I took him down to the beach for a real massage under a
words , obviousl y delighted with his compa ny and loca tion for the tiki-hut on the waters edge. It was one of Jeffrey 's favorite places to have
weeke nd. I showed him around as Jeffrey had asked and took him on an a massage , as he droned out to the sound of the waves and my gentle
adventurous quad bike ride around the small curvy paths , lead ing the way therapeutic. strokes. Afterwa rds we had lunch back at the main villa and
and letting loose my hair, doing something that gave me a natural high went back down to the beach to swim out to the water trampoline abou t
instead of the prescrip tion one. The sigh ts alone were breathtaking from one hundred meters off the dock. He didn 't do any bouncing around o r
the mountainous peaks of the untouched parts of the island, we sat at a anything like that. It was j ust a good base point for a rest spot aner a long
cliff and j ust sat there, not saying a word to each other bes ides 10
59 60
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swim. What was really cool about it though, was you could see through To my own amazement Rena was to be assisting me in Jeffrey's
the mesh and watch fish swimming underneath. massage this day, not being a total knockout or anything spectacular,
The rest of the afternoon we spent by the pool reading magazines and looks wise that is, but for some reason he seemed intrigued enough. As
eating fruit plates. Eventually he went to his cabana to have a nap later we made our way through his spectacular mansion she was in total awe at
on. That night after dinner and my mixed cocktail ofXanax and red wine, every corner. Commenting on the present artwork and decor that we
I asked if he'd like another massage before I went to bed. He just wanted passed in every hall, it no longer seemed so grandeur to me anymore but
to stay up watching movies in Jeffrey's theatre room. As peculiar as that hearing someone else speak about it in such excitement reminded me of
request was to me I didn't argue it, !just hoped I hadn't disappointed him the days when all of this seemed so unforeseen.
in any way that could make it back to Jeffrey. I showed him how to use When we got to the massage room, or "The Dungeon" as I used to put
the remote and turn off the T.V when he was finished before going to it for it's medieval looking appearance, we firstly out of custom all had a
bed. The next morning we were both catching a flight from St. Thomas steam shower, where Jeffrey expected me to walk her through a servants
and we had no time for anything other than breakfast and packing, which duties, telling her to take his other foot and start rubbing in small circles
saved me from having to be too polite as we said our good-bye's from the and stroking the arches of his foot rhythmically. Rena took the
terminal in the airport, both hurriedly off in separate directions, instructions well and began to massage him too. When we all went to the
thankfully. I arrived back in Palm Beach, only to be told to catch another shower next and she followed in my exact lead washing his body as well.
flight the next day to N.Y.C, where Jeffrey would fix me up the money he Jeffrey absolutely loved the fact that two teenage girls were dually
owed me for treating his colleague out to an entertaining weekend. pampering him. Jeffrey wanted to move to the massage bed and I had to
further begin to show her about the body, upon his accord. She mimicked
Chapter 10 my every move up his legs and buttocks, keeping up with every stroke
until he could not contain his arousal any longer and was already
requesting us to start kissing each other, the start of the very reason we
I was fixed up more than what I had usually made for two days, which
was great because that car I had been saving for was finally within my had even met in the first place.
He blatantly stopped the massage nowhere near being complete and
reach. I had been waiting for the freedom a car gives every teenager for a
turned over to announce his increased arousal in a physical abundance of
long time, and now that I had over fifteen thousand dollars saved up I
grotesqueness. Moving over to the small couch in the corner of the room
could pretty much afford to go buy myself a nice car outright. Looking
he made a space for her to lye me down on the massage table as she had
much better than the last time I saw him Jeffrey acknowledged it. I went
commanded him to do in such a domineering tone that he wasn't used to
to his office where he was waiting for me and he had a guest with him.
being spoken down to with. From that very moment onwards and from
She was unusual looking to the common stereotype drop dead gorgeous
the look on his face he was yearning for her to orchestrate an hour of
girls Jeffrey had normally introduced me to. Of Asian decent, her name
was Rena. Jeffrey had met her at an art gallery where some of her own deliverance upon my meek nature. He started to stroke his erect manhood
as he was being tantalized watching her take over every inch of my body
artwork was on display. She had a bubbly persona about her and I could
in a dominating act of seduction. I was left breathless and soar after my
then understand why Jeffrey liked her so much, she fit into the
subservient category that he liked his girls to fall under. It was apparent first introduction into the world of S&M.
Rena considered herself a dominatrix, she loved bondage, whipping
to me that they had already slept together in the short time span they had
hitting, and eventually cutting her sex partner with little sharp knives
met, as there closeness was oddly noticeable and I wondered what it was
until they subdued to her punishment in agonizing pain. She was
he was offering to her in exchange for her body. I found out later from
Jeffrey that he was buying her artwork, promising her the world as an absolutely crazy if you were to ask me, and I couldn't help but wonder
what got her into this in the first place. All I knew was that Jeffrey was
artist, telling her he'd have her work in the all the museums in N.Y.C and
absurdly taking into the appeal of watching us two interact, often with her
the best art exhibits. Everyone was promised something, and seemed to
acting as my mistress who would fondle me with an insurmountable
be bought off in someway or another to be in his company. It was only a
amount of whips and toys. Then she would love to finish off every
matter of time that the truth would come out.
session by hitting me across my face with a hard blow from the back of
her hand and sneering over my curled up body showing Jeffrey her ability
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to make others surrender to her extreme force. She could be so opposite seen him show a girl. Obviously moved by her gesture, he got her an
all of the sudden and be tenderly intimate with Jeffrey stroking his penis exhibit in N.Y.C's "Metropolitan Museum of Art" where she submitted
lovingly and even speaking in baby talk to him, which he seemed to her very own piece. She sculpted an image ofmy headshot out of clay,
adore. shaping it with the strands of my long hair blowing across my face. I was
He loved us pairing up so much that within months he made Rena an taken aback myself at her creation. She really did have an amazing talent
official even renting her an apartment at the same place he had one for me if not for her meaner streak she would've been a great friend. I will never
during my extensive trips out to N. Y .C. Sending us out shopping together forget Rena, for all of the ups and the downs we endured together.
at all of the underground seedy sex stores downtown we would bring him It wasn't too much longer before I finally had enough of the abuse in
back thousands of dollars worth of sexy outfits, sex toys and bondage the bedroom and I had to tell Jeffrey what I was feeling. She was getting
material. His favorite one was a black leather studded collar that lead even more violent as time went on, and with her questioning me and
down the back ofmy spine to cuff my hands and feet together, offering Jeffrey why she didn't get brought on long trips with him, she didn't get
Rena the most compromising positions to wield her afflictions, one she the fact that she was just a tool for him to use. Jeffrey said he was already
was excited to pick out for my usage. thinking about getting rid of her off of his "regular list". He said she was
She was good at eradicating my softer side though. Helping me forge becoming too clingy and he didn't like clinginess or jealousy. I never
an unpredictable scenario of me turning the tables on her, making her at even got to say good-bye or take the opportunity to keep her as a friend,
my will instead of me always being at her twisted discretion. Jeffrey like a girlfriend to catch up with once and awhile, but that's how it was
loved the rivalry between us, both striving to dominate the other one but with Jeffrey, one day you sat under the blanket of his comfortably and the
to me it was just another way of surviving her punishment. All for show I next without any warning you could be discarded like yesterdays news.
thought she was a madman let loose in a torturesome domain of violent She would've taken it hard but that's the game we were playing and it
sex and unbearable beatings. I wasn't sure how long I could hold off this was for those who knew what lines not to cross.
charade of S & M, I just didn't want Jeffrey to think I couldn't give him I was further surprised the next day when Jeffrey gave me a thousand
everything that she could, always being replaceable in his company. dollars to go shopping in downtown Manhattan to find a classy dress, on
She and I could often come across as good friends to his blind eye but top of being sent to the exclusive beauty salon of celebrity stylist
it was only a matter of time before the animosity inside ofme was going "Frederic Fekkai" for a new look. It was amazing, to be pampered like
to snap. Doing normal things too made it all half bearable. Having a lot of royalty. I walked out of there feeling like I had replaced a young girl with
similar interests we did fun things like go to the theatre to watch a young woman, I felt beautiful. He had yet another surprise in store for
"Phantom of the Opera" or visit several historical and art museums me. Ghislane called me and told me I need to go to a photo-developing
together, afterwards treating ourselves for a giant piece of greasy N.Y.C store and ask them for two l.D photos then bring them downtown to
style pizza. Like 1 said, we really liked each other purely as friends but Jeffrey's Manhattan office. Weird request I thought. I was more used to
the dominance in the massage chambers was taking it's toll on our posing in full body shots being sexually exposed as a gift for Jeffrey. I
strange friendship. One average trip back to N.Y.C, she surprised Jeffrey did as they asked and took my two photos into the office where Jeffrey's
with a six foot by six-foot oil painting of her and I lying nude in a ying assistant was waiting for my arrival. Still not telling me what the
and yang position facing each other. Although we were soliciting each headshots were for, she took them from me and told me to have a seat for
other with sexual innuendo the picture was still very carefully a second. A moment later I heard Jeffrey call me into the office. "I like
orchestrated to perfectly portray the darker side of Jeffrey's thrills. It was what you've done with your hair, you've gone more blonde, suits your
an amazing piece of work, besides the lewdness ofit, but she would've glowing tan". I replied with an appreciative "thank-you" for sending me
known that's exactly what kind of art Jeffrey liked. He was so astounded to such a renowned hairstylist, and shopping money. I showed him my
by her gift as he had previously asked her to construct a small painting of finds for the day, an elegant off the shoulder navy blue dress that had two
us together but was not expecting anything of this grand magnitude she layers that would swoosh and sway with my every stride. I couldn't wait
had presented him with. He lifted her from the ground and twirled her to wear it on a special occasion, and I wouldn't have to. The pictures I
around before he thanked her profusely and embellished her with his had to bring to him, as he would proceed to tell me, were for my first
profound gratitude, the only thing Jeffrey had to offer, he handed her a passport. I was so excited, we were going to France for a close friend of
small wad of cash as her payment. It was the most appreciation I had ever Jeffrey and Ghislane's birthday party, famed super-model Naomi
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Campbell. I was so over-joyed with excitement, what girl my age with a was, only to grab another glass of champagne every now and then. Every
background like mine was attending socialite parties and globetrotting the so often he'd introduce to me to someone new, pulling me aside to show
world. It only made it harder for me to see beyond the elusive walls I had off his eager young masseuse to his fellow pedo 's. These people had so
put up to protect myself from the appalling truth. much money pouring out of them. I don't know why he even thought
We left in early April first going to London, Paris and then our final they'd care in the first place. It made me feel good though. At least I
destination being St. Tropez in Southern France. If Hallmark had a knew I made him proud to have me in his company.
postcard, St. Tropez would definitely be on the front of it. It was beautiful Being surrounded by so many of Jeffrey's colleagues and his
spring weather and every where you looked women were dressed in likeminded people that were considered the most sophisticated and the
bikini tops branded with some kind of designer label embedded into it highly esteemed of today's world nearly made the way I was living lately
and the men were following them around like harping dogs in heat. In all more fathomable, at least to myself. I thought if everyone looks up to
of the elegance of the Mediterranean, "La Bastide De St. Tropez" was an these people and they are all accepting of it, it must be just the way the
impressive landmark. Jeffrey and Ghislane were staying in one of the world turns. I danced with a young prince that night and with all of the
private cottages, on the park on the grounds, while Emmy and I stayed in help from the bubbly champagne I couldn't remember his name for the
separate quarters inside the hotel. The old style cobblestone streets were life ofme. On one ofmy trips back to the table for another glass, Jeffrey
lined with boutique shops and beauty parlors. It was the hedonistic leaned over to quietly whisper in my ear that it was a prince that I had
stomping grounds of the beyond rich and famous. actually been dancing with and I didn't phase me in the least way. I went
The next day we went out to lunch at the grand opening of the back to the dance floor and continued to let my hair down. It was a fun
infamous Nikki Beach Club, where a cheap glass of champagne costs bash, the entire crowd sang "Happy Birthday" to Naomi and by the time
around two hundred dollars and if your not keeping the alcohol we got back in the car to retreat for the night, I was giddy from the
consumption flowing like water, you'd be asked to leave to make way for drinking and dancing all evening. We had a guest in the car, and
the constant flow of prospectus patrons. That's where I first got to meet apparently we had already been introduced, but I couldn't even remember
Naomi Campbell. She was wearing the typical attire strutting around his name in the first five minutes of our meeting again. He was the hotel
southern France, a D&G bikini top and a wrap around mini skirt to go owner of some large chain in America called "Hilton". Staying at one of
over the swimsuits bikini. She was so tall and stunningly beautiful. Her the cottages near Jeffrey, he saw it quaint to loan me out for a night's
charisma was energetic, funny, and everyone seemed to hang off of her massage to ruin an "almost" perfect evening. Jeffrey told me to come
every word and laugh at her every joke. Ghislane and Jeffrey kissed her back to his room after I was finished with Rick, thankfully he reminded
cheeks and wished her a happy birthday, and then I was introduced and me of his name but also odd I thought, being so late I would've never
followed in their suit. She was surrounded by a league of assistants, imagined Jeffrey could stay up this late but I never made a fuss out of his
friends and fans, which didn't make it easy for us to all converse but she requests. I gave him affinnation ofmy understood instructions and
got enough time in to invite us abroad a yacht of a fellow she was "kind headed off with this stranger into the darkness.
of seeing" at the time for the before party ahead of tonight's event. We I dimmed the bright lights in his bedroom to a softer tone as if it might
went back to the hotel and I gave Jeffrey a massage in his room before we aid the vision of this short, balding man with straggling remnants of curly
all headed down to the pool to soak in some of the year's first sun's rays. brown hair left to show for the remaining bits of youth left in him. I had
I loved wearing my new ball gown and feeling like a princess. It was to ask him to undress and lay on top of the towel that I had picked up
absolutely sensational and made me feel as ifl floated in the dress. I from the neatly folded pile at the end of his bed and spread it over the
swept up my long hair in a twisted clip, only letting down a few curly duvet. I didn't want to waste a second in his place, getting right to the
strands and layered on the mascara. Receiving many compliments very reason I was even there. Turning around while he was getting
throughout the evening when we eventually left the Yacht to make our undressed, being our first time together, I wanted to give him the
appearance at the main birthday bash, I couldn't help but feel excitement impression I was actually a therapist and not a finale to the end of the
for the party to come it was the first celebrity birthday bash I had ever nights entertainment. Not exactly what he had in mind though, given that
been to. Being introduced to model after model and the rich men that my impression was already made for me when Jeffrey arranged for our
followed them around became dizzying. Jeffrey sat back and watched as I meeting in the first place. His chuckle to my response was condescending
buoyantly worked the dance floor, coming back to the table where he as he came up behind me and unzipped my dress which floated to the
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bottom of the floor as he was saying "You can't really expect to give a our trip and commenced our flight back into the U.S. l was paid a
massage wearing this, here sweetie, I'll help you out of it." He just generous amount and set off to go car shopping as soon as I got back to
wanted to see the hidden bounty my clothes were hindering his eyes from Florida. Through a private seller, r was able to pay out right for my car. I
seeing. l just went about my way trying to get his hands off of me and to got a Dodge Dakota in cherry red, and immediately had an impressive
get him to lie down for a massage. Making quaint conversation with him sound system put in. She was my first pride and joy and taste of freedom.
was pointless as l was trying to send his thoughts elsewhere other than I would love to drive her down to Lakeworth Beach to sit in my car and
the apparent perverted schemes replaying in his mind from the heavy watch the waves while l listened to my stereo blare music and puffed on a
breathing he was making and the looks he was giving to me. I was using jay. Letting the rest of the world pass by while I sat back and watched
all of the tricks in the "turn-off' book even asking him about his wife and them walk past wondering to myself what their story was about.
kids. I turned seventeen that summer and had accumulated a string of exotic
Unquestionably he was in seventh heaven turning every one ofmy destinations that I had travelled in such a short time. I was given more
distractions into another flattering compliment. He was saying things like make-up and a pair of diamond earrings from Jeffrey. Ghislane only
"I love what you do you to me, I have never felt like this before, come wished me a happy day, wondering at times if she felt threatened by
stay with me and I will pay you double, no, triple whatever Jeffrey pays Jeffrey's and my closeness. We went to the island after we left N.Y.C and
you!" Knowing he was just a drunk idiot, I wasn't being lured in by any I asked If Sarah would be meeting us, mentioning it had been a while
of his offers of money or a privileged lifestyle, I knew these cages all too since we had last seen her. He said he had some bad news about her.
well and I was better off sticking with the one that I was at least Expecting the worse, thinking she had gotten hurt or something, l was
accustomed to already. Holding back any composure now, he was going astounded when Jeffrey told me that she had been sent to his island with
extremely wild ravishing at my body trying to tear off my panties like a one of his friends for a couple days and when the housekeepers were
hungered wild animal. After all of the champab'l!e I had drunk that night cleaning her room and they found a stash of cocaine left out carelessly in
it gave me the nerve that Tneeded to know exactly how to handle perverts the bathroom.
like this one, who had been no different from every other shmuck in my He said he had no choice but to let her go. Addicts with no respect for
life, and I quickly shut him up with a blowjob lasting no longer than two themselves or his wishes had no leeway in Jeffi-ey's book. He didn't mind
terrible minutes. It had only been shy of a half an hour before I was that I dabbled in drugs once in a while as long as I never brought them
already getting quickly get dressed and hurrying out his cottage door. along with us on any trips, except for my Xanax, which he didn't mind
When I got to Jeffrey's cottage I rushed through the door and told because it was pharmaceutical and most of all wouldn't cause him trouble
Jeffrey and Ghislane, who were sitting front of the fireplace reading a being a legal narcotic. Sarah took it too far when she crossed international
books, that l never ever wanted to see that b'llYever again. When they borders with an illegal drug, risking her welfare and almost costing
asked me what was the matter, l told them of every thing that had Jeffrey public attention. She lost her apartment and contacts in the acting
happened that night even how he offered me to come work for him world, only hearing from acquaintances once in a while that she was
getting paid triple. I established a lot of trust with Jeffrey that night. He sinking deeper and deeper into the black hole of addiction. It was sad to
asked me why I didn't accept the offer and I responded with "Who find out, as Talways did like her.
would look after you, if I were gone?" Like a caring grand father would At the island, Ghislane had just recently obtained her helicopter pilot's
do, he pulled me into his chest for a hug and told me that it meant a lot to license and wanted to get some practice airtime and flew Jeffrey and I to
him. Ttwas so late and Twas so tired but Tstill had to give Jeffrey his St. John where we picked up Alexandria Cousteau, the grand daughter to
massage that night. He asked me to just rub his feet as he fell asleep, and the inventor of the scuba tank and underwater explorer Jack Cousteau.
thankfully he was out like a light in no time. The next morning Ttook two Ghislane was out to set us affright in the air, but it was all talk, she was
headache tablets and a ginger ale instead of a coffee. Trying to contain actually an impressive pilot. Still a daredevil though, she got her kicks
my hangover as best as possible behind a pair of sunnies it was mid out of hearing us fret on the earmuffs intercom's. Jeffrey made it clear
afternoon by the time I had felt like myself again. We spent the day Yacht that Alexandria was a guest when I was told to adhere to her if she
hopping, soaking in the sunny weather while Jeffrey and Ghislane caught wanted a massage, which l obliged her with several times during our first
up with old acquaintances, Emmy and r were just accessories to look meeting. It was Jeffrey who instigated that her and I reenact as lovers in
good on the arms of them. The next day we wrapped up the tail end of lesbian acts of foreplay and penetration. l couldn't imagine a girl with
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such high prospects lowering herself to something of Jeffrey's standards, beautiful as it was it could be as equally dangerous. It took so long as we
but I later found out through Jeffrey that he had donated money to her had to veer away from so many desirable spots. Finally we found a good
continuous exploration into marine life and habitats. She had followed in place that the scuba instructor thought was safe. He buddied us up into
her family's footsteps, all of them involved in Marine Biology in some pairs and we jumped off the back of the boat into the crystal aqua blue
way or another. We actually got along really well, she was a real decent waters beginning our descent slowly into the darker regions of the oceans
girl, and loved talking about her passion, everything underneath the floor. We were situated on open water with a cavern of reefs to venture in
waters surface. and around down below. It seemed to be quite a choice to scuba in, one
When I wasn't busy giving massages to everyone around, her and I that our guide said he wasn't familiar with but to alleviate his bored
would hang out together. Often we go swimming in the crystal clear pool clientele deemed safe to swim around.
of ocean that the Caribbean had to offer. Once we swam out so far not It was Jeffrey and the Guide together, Ghislane and Emmy, and I was
paying attention to our location and were carried out to sea by the current. paired up with Alexandria. Miles, the houseman, came with us and stayed
We took turns on the backs of each other, taking breaks against the strong on the boat just in case something went wrong and lucky he did. We were
ocean tide. It was almost a possibility that we nearly drowned out there, if all too far under the water to hear his alarming screams of distress when
it weren't for some guys on a boat out fishing for the day when they shadow's lurking in the murky distance started appearing closer and
caught us in their view. They picked us up and brought us back to the closer. Ghislane actually looked frightened for once as she gave us the
island where we were reprimanded by a worried Jeffrey and Ghislane to signal to start ascending upwards, reminding us by holding her ears not to
first of all let someone know where we are going at all times, and never go up to quick or as we were previously warned before we could pop a
to lose sight of the shore while out for a swim. After that learning blood vessel in our brain and hemorrhage to death, not a very lovely
experience I took their heed and proceeded with caution. I had a image but neither was getting tom apart by sharks.Those giant shadows
newfound respect for the ocean and it's mysteries. became clearer and soon enough we could recognize their indistinct
Having such a lover of the water as a guest, made Jeffrey want to species as the terrifying and more aggressive breed of sharks, the
explore parts of his Caribbean he had never seen before. The next hammerhead. Grabbing Miles hand I was the last one ahead of the Guide
morning we were met by a scuba instructor in St. James and given a few to get on the boat imaging the worst as I waited behind Emmy and
lessons in how to use the gear and more tips like how to descend slowly Alexandria who were the next to follow after Jeffrey and Ghislane I was
to the ocean floor as not to cause blood clots as well as visual hand in too much shock to scream or cry, I just told myself I had to stay calm
signals to communicate underwater. It was so exhilarating beneath the to get out of this alive. Unlucky for us we found out later on that we were
waters surface. No voices to listen too, only the enchanting sights to take in their breeding territory and being sent a clear message that we were
in. We explored the surrounding reef and found a large squid, many of soon to be on the menu to their feeding frenzy.
sea urchins, and the magnificent colored coral that housed a many of the We all felt like we had cheated death and I know it wasn't only my
rich variety of the local species of fish. It was such a great sight to take heart that was still beating out ofmy chest when we headed back to
in. Holding a permanent mental picture of those adventures to carry in my Jeffrey's island. Jeffrey was pale as his designer sheets and looked like he
head for all times. had aged another ten years in such a scared state. Ghislane took the heat
We all had such a great time that Jeffrey hired the same scuba off herself even barely taking a notice of beforehand and decided to poke
instructor to come out the next day to scuba dive the safer parts around fun at all ofus frantically scurrying to get out of the water, it was just her
his island. We got bored quickly with not much to see but seaweed and a nature, as I had never seen her move so quickly either. We got back to the
fish here and there. It didn't take long before Ghislane decided for us all island and all collapsed our fatigued bodies in our own beds for a long
to explore other numerous locations by boat, Jeffrey needed a bit of nap. Freshened up and much more relaxed we regaled our horrendous
convincing at first and the instructor was quick to assure him that he story again over dinner, this time in laughter. The following afternoon
knew his way well around these waters, of course he would say that, he Ghislane piloted us all in the helicopter to St. John's Airport and we said
was getting paid a hell of a lot to do this in the first place, why not extend good-bye to Alexandra where we all parted ways. I met her a few more
it a few more hours? separate times in Palm Beach at Jeffrey's Mansion, but she wasn't a
The clear water glistened and the tropical array of marine life was on regular of his, probably not as easy as the troubled girls were to bribe.
display as we wanted to stop at so many places but you could see as
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Chapter 11 We also visited his up and coming Paris apartment. It was a modem,
typical flat being refurbished, and we went to see how it was all looking.
Jeffrey liked to fuss about every detail and harass the builder's about their
Throughout the remainder of the quickly passing year I was on a
work, changing last minute details at a whim.
constant move with Jeffrey. Attending various dinner parties, mostly with
Days and many croissants later we left for Spain feeling bloated and
other esteemed billionaires and widely acclaimed scientists. Jeffrey likes
sleepy. We only stayed in Spain for the afternoon, going to see another
to surround himself with the most brilliant and powerful of minds, filling
astounding Moroccan castle for Jeffrey to replicate at one of his many
his little black book with some of the most esteemed and even infamous
people in today's wealthy society. It was during those intellectual mansions. It was only a short plane ride to Tangier, Africa for more
gatherings that my body was also put on the banquet menu but this time castles hopping. We arrived at the historic landmark and the only five star
for a powerful senator George Mitchell and another prominent Nobel- hotel in Tangier called El Minzah in the village of Ville Nouvelle. The
city and outskirts were still very hostile at the time, females being warned
Prize winning scientist who's name would be mentioned but for all the
life ofme can no longer remember. They would be only some of the to not walk the streets alone and not to leave the house after dark or be at
risk of being raped or worse.
recognizable figures of the high society that became added to my list of
When we got to the room, it was oozing with every expected bit of
clientele, of course being introduced to for a lot more than just a client of
extravagance that a luxurious historical palace should offer until I was
massage.
As an amusement to Jeffrey's associates I also knew my place was to greeted with a pile of monkey poo in the very middle ofmy bed. Not a
happy camper I called Jeffrey, Ghislane and Emmy into my adjoining
entertain but not to every desired content. I was to show them a good time
room and they all had quite a good laugh at my expense. Within a
but not the way I would have to use technique and effort for Jeffrey. The
very teachings from Jeffrey himself, or my tutor, as he liked to so moments notice of a complaint call to the front desk and we had an
attendant cleaning up my bed linen. The cleaner noticed the window was
eloquently put it. Consistently being used and adored for the likeliness of
still opened, he warned not to leave it ajar at nighttime just in case
my youthful looks I was becoming very accustomed to my lifestyle with
Jeffrey, never really relaxing into it, but just accepting this as being as another monkey wanted to make himself comfortable in my quarters.
Ghislane joked that maybe I should keep it open I might find a suitable
good as it will ever get for me. I didn't think I should be complaining,
husband before I get any older. Always the instigator ofa good joke but
wasn't I being offered a life in exchange for servitude? Just letting the
unable to take one herself she didn't like when I poked back that it was
signs ofmy anxiety and depression pass me by while I blanketed them
more in her recent taste of men, since she loved to brag about her
with my pills, suffocating under a blanket of pain is all I was really doing.
rendezvous with her various lovers. Once she came back giddy as a
I spent Christmas and the New Years holidays with Jeffrey in N.Y.C,
schoolgirl with an explosion of news, with all the build up and excitement
who doesn't celebrate the occasion, as he is of Jewish descent. Not that
in her voice you'd think she was the next crown princess, but she had
he was a religious man anyways, I never even saw him celebrate
given George Clooney a blowjob in the bathroom at some random event,
Hanukah either. We firstly stayed at his ranch in Santa Fe for a week,
she never let that one down.
then left for a long plane trip to Paris, France where we all suffered jet lag
We all went to explore the towns surrounding Moroccan castles and
for the next twenty four hours. We all stayed in a grand hotel with a view
meet their royalty that lived in them. Jeffrey's personal interior designer's
the Champs' Elyse.
met us at the residences. They walked around hurriedly, scribbling notes
Emmy and I shared a room and with her gifted ability to make new
contacts in just a few hours, she brought out a jay to share on the rooftop into their clipboards and whispering between themselves. The palaces
were historically unique and beautiful but I wondered how could they live
at nighttime while we were overlooking the lit up Eiffel Tower. We never
so grandeur behind these walls when they lived in a city of such poverty
got really close as buddies but we both knew what we were indebted to
stricken squabble. Beggars lined the streets, people could just go missing
and felt each other's sorrows. All four of us went out shopping at Chanel,
and no one could care less, and you heard of barbaric murders happening
D&G, Ralph Lauren, and many other little exclusive boutiques the
every night. Against the advice of the Palace Attendant and Jeffrey's
following afternoon. As a gift Jeffrey bought me a white terry clothed
wishes, I decided to take a stroll one afternoon, mainly just to take photos
goose feathered sofa and had it sent back to my apartment in Florida, and
of exotic Africa and do some shopping in the village markets but I ended
bought some new tapestries to have sent back to Santa Fe for his ranch.
up being intrigued by a group of young children playing in the streets.
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When I was noticed watching them, about fifteen of them came up to me When we left for the final destination of our trip I was looking forward to
and began to beg for money and food. I was over taken by the poor, eating normal food again, not one to stray for foreign dishes, I'm a more
hungry children and I felt sad for them all and wished I could help out of a cheeseburger and pizza kind of girl, a true sign of my American
somehow. When the tide of kids washed away and the street went empty, heritage.
I was overcome with intrigue at these two little boys. Brothers I found out We landed at the Heathrow Int'! Airport and greeted by a driver that
later on, and there only toy was an empty can they were kicking to each would take us to Ghislane's town house in London's central that Jeffrey
other in the middle of the street. Intelligent kids, they were able to speak had recently bought and refurbished as a gift for her. Emmy said "Good-
three different languages, including English and I was interested to ask Bye" at the airport, leaving us to go to her hometown in the rural
them about life here. They didn't seem to notice or be bothered by their countryside nearby to visit family for a six-week holiday from work. It
poverty stricken lives. They told me about their school and parents and I wasn't a very long drive before we were in the heart of the city and at
thought I had just heard the saddest story ever but they were accustomed Ghislane's place. I thought it was a cheery townhouse that had character
to living like that like I had been so accustomed to my degrading lifestyle and the historical pub in front of it and cobblestone streets only added a
for so long. unique charm to its presence. They were going out for dinner and invited
I was compelled to empty out the contents ofmy purse, giving them me along with them but seeing I was so exhausted from all the travelling
over two thousand dollars in U.S currency. A passer-byer snapped a and looking a bit melancholy, I apologetically declined going out for
photo of the kids and me for 111yself to take home as a personal souvenir dinner that evening, I rather would be taking a few pills to catch up on
before they rushed home to proudly show there parents the money. I told some needed sleep. "Are you sure your Okay"? Ghislane asked as she
Jeffrey later on of my good deed and he couldn't believe I'd give away showed me to my room, more considerate than she normally was but I
my money so carelessly. He told me I had set up their parents with assured her that I was in absolute good health, just tired from all of the
enough money to feed and shelter their family for a year. Wasn't that a recent jet lag. Without another word said she whisked off downstairs, to
good thing? I couldn't believe it, not that I was well off or anything close the car where Jeffrey was waiting for her.
too it, but to realize how lucky I was and to not have compassion for the I took the liberty to call my parents house to say "Hello" and catch up
lesser off, especially children of a third- world country, I wouldn't be with them since I hadn't been home at all for the holiday season this year,
human anymore. Then again what did I expect from someone who could always too busy working. They sounded really happy to hear from me
numerously steal another man's daughter for the use of his own sexual and my mom put me on the phone to talk to my brothers as well. I got to
pleasure with great ease. tell them about my travels abroad and I had some cool tribal stuff from
We went out to lunch the following day with Jeffrey's team of Africa that I bought for them. They sounded so proud ofme, all of them,
designers to wrap things up and after Jeffrey's afternoon massage he went and why shouldn't they be? In everyone's convinced mind I was making
to the palace to have a nap. When I was all alone I thought I'd go see the great money, travelling the world, and meeting new faces everywhere I
culture of the local unique markets again and this time buy some trinkets went, why should I spoil anyone's delusions, especially mine. I took my
to bring home. I got to sightseeing and took pictures of the legs oflamb sleeping tablets and had a bath before falling into a deep and much
hung over the blood drenched doorway over people's homes as to warn needed sleep.
off evil spirits and the ghettos where the local villager's called home. I The next morning I was woken up by Ghislane who I could tell was in a
walked into many of the market's stalls and saw the most peculiar chirpy mood by the way she paraded through my closed door saying
antiques, such as weaponry with the blood of it's last victim stained on "Wake-up sleepy head" and opened the window's shutters to let in the
it's sharp blades and body pieces of various animal's for the use of bright sunlight, she had never done anything like this before and I knew
religious sacrifices. I was more interested in the different culture and immediately something big was happening. She sat down on my bed as I
respecting their ancient way of life with interest, instead of squirming like rolled over from my deep slumber and I was able to mutter for an
a tourist and getting grossed out. I thought it was so educational and explanation as to why she was awake so early. "Besides the fact it is ten
enthralling in fact, I ended up buying a few sacrificial trinkets to have o'clock in the morning and nearly time for brunch, we have a big day
sent to my apartment in Palm Beach. Not to say that I wasn't looking planned out for you today." She was waiting for my cue to ask her "What
forward to getting back to the luxuries of western civilization it was a bit are we doing", when I did, she responded with a convincing enthusiasm
like camping, fun and adventurous but as equally dangerous and thrilling. "We're going shopping for a new ensemble" she paused for a moment to
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build the suspense, before completing her sentence" To go dancing with the picture and in a hushed voice proceeded to tell me that it was a
a Prince of England this evening". Hoping it would be one of the younger portrait ofGhislane's childhood, the part she could be proud of. I never
generations, I was disappointed when she told me he was the Duke of realized how prominent her family's history was in England, apparently
York, Charles's younger brother Andrew. I looked at her with a fake as to Jeffrey's attest, her Father was born of poor Jewish decent in
surprised look, one I had to use on many occasions in my time with them, Czechoslovakia, most of his family being killed upon Nazi invasion in
to give an impression of excitement. "What ... wow!" I exclaimed with my 1939. Fleeing to join the British Army as a young man, he changed his
gifted acting ability. It is a sad realization but I had grown more name a few times and made a lot of contacts in the field. After the war, a
accustomed to seeing people for their significance rather than the good newfound Robert Maxwell went into publishing using his army contacts
qualities they possessed, and was able to grin & bear the thought of what to establish a business initially built upon publishing scientific books
I expected lay in store for me. from occupied Germany. In time, Maxwell acquired several British
Ghislane and I left shortly thereafter for the many lanes of designer newspapers, among them the Daily Mirror, countering his wits against
shops to choose from in London. Her pep talks to prepare me for my the likes of Rupert Murdoch along the way. However, whilst constructing
duties towards royalty went on and on, giving me the obscure impression his publishing empire, Maxwell compiled astronomical debts, and his
I was something of importance, at least for more than an evening. "Make equivocal financial dealings attracted the attention of governing
sure your bubbly and energetic, nobody want's a dead horse" was one of authorities that judged him not to be looking out for his companies best
the cheap tools she instilled me with. "Who knows where this could lead interest and in the end it transpired that Robert Maxwell had been using
for you" was another. As the day grew shorter my anxiety only proceeds from his employees pension funds to meet his financial debts,
heightened, anticipating the Prince's arrival and unable to decide on an ruining the futures of thousands of employees. Once an esteemed
outfit, I picked out three. Our last stop for the day was Burberry's for a Member of Parliament and publishing mob'lll, Robert's body was found
nice handbag to compliment our chosen attire. We got back to her floating in the Atlantic Ocean after he was found to be missing from his
townhouse with still a couple hours spare to get ready. After trying on all yacht, the Lady Ghislane (named after his favorite child), whilst cruising
three outfits and many mental debates with myself later, I decided on the the Canary Islands in 1991. Jeffrey went on to tell me that when her
pink mini-tee and dazzling pair of denims with horses embroidered into a Father died she was inconsolable, and in a very bad state. He picked her
pattern. It seemed a lot more my style and age group rather than the other up from the trenches of despair and took her under his wing, and it's there
two older looking sophisticated dresses I had picked out. I told myself I she has stayed comfortable ever since. To Ghislane his peculiar need to
was going dancing at a club not to an opera. As most young girls can be have so many woman around and even his taste in younger than legal
during their body changes into womanhood, I felt awkward, you know, one's didn't seem unconventional to her. It was her own Father who was
big feet, freckles and body hair in unwanted places. They're things you deemed a womanizer and even took a second wife whilst still married to
just don't want when your seventeen and then you see these iconic Ghislane's mother. I would have never guessed this carefree, spirited, and
billboards of what femininity is supposed to represent and just don't fit vivacious woman had ever endured such sorrows. I couldn't help but look
into that picture, never feeling what we all are already ... absolutely at her in a different light from then on, but not letting her know that I
perfect. By the time I had got ready I was a nervous wreck, but trying to knew, to avoid any altercations between us.
keep my cool on the outside was an act. I thought it'd be a good idea to Like clockwork Ghislane came downstairs five minutes before Prince
take a few Xanax before the evening unraveled and my anxiety went Andrew were to arrive, wearing a tight-fitted white wooly turtleneck
through the roof. singlet and a nice pair of loose fitting trousers. Looking elegant and
Jeffrey and I were sitting in the lounge room downstairs, waiting for casual at the same time, a very hard look to achieve but one Ghislane had
Ghislane to finish getting ready. The room was silent, only stillness in the always easily mastered. They both seemed at ease poking fun at my
air. I stared at the mural painted onto the wall that I was facing. It was an obvious nervous state, just another ordinary night out for this
interesting piece of artwork. In great detail it illustrated a happy looking extraordinary couple. The knock came at the door just after six o'clock in
family sitting on a bench overlooking a pond that resided on a large piece the evening. Ghislane greeted him and the guard who would wait for his
of land with a beautiful home displayed. There were also hunting hounds return in the car. She led him down the hall to where Jeffrey and I were
and the hunters chasing a game of fox like the notorious "English Hunt sitting. We both stood up and Jeffrey shook his hand, while Ghislane
Pieces" throughout history. Jeffrey took notice ofmy enchantment into proceeded to introduce me and as I was taught by her was English
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custom, we both kissed on the check. We all sat down on the lounges for that he was in public, he was whispering sweet nothings into my ear and
some tea and biscuits while conversing idle chitchat. By the sounds ofit, kissing my neck. I would just giggle not really knowing how to reply to
Ghislane knew well of his recently divorced x-wife Fergie, whom they an aging man with a bad smile and terrible moves, it would sound too
were all taking turns in slandering her for one reason or another. It was much of a lie if I retaliated back about his swagger. He was the most
apparent there were some fresh wounds still lingering on and as good incredibly hideous dancer I had ever seen and couldn't help but laughing
friends do, it was their way of helping him get over her. When his on the dance floor and shooting glances of embarrassment to Jeffrey and
daughters were mentioned, Ghislane and Jeffrey treaded lightly, only Ghislane who were having a good time laughing at my expense ... as the
speaking highly of them, and offering their sympathy to the young ones. always did.
The conversation turned to a much lighter subject. Andrew wanted to After an hour of pelvic smashing to the DJ's pumping mixes we finally
know more about this young guest they had to join them out for dinner exited the floor, his royal highness was dripping with sweat and ready to
and dancing that evening and then the spotlight turned on me. I was more embark onto a quieter scene where he said we could be alone, not
nervous than I had ever been before a night out with someone, probably knowing that it had already been arranged for all ofus to meet back at
the build-up Ghislane and Jeffrey had hyped this meeting up to be. To Ghislane's place but complied with his so called thoughtful request. I was
break the ice, she played her favorite guessing game ... "how old do you so anxious about getting back to the townhouse, knowing what
think Jenna is"? When Andrew guessed correctly, I was seventeen years expectations I would have to not only have meet but also exceed in this
old, she was surprised, thinking I could have passed for younger. "I guess case. Ghislane and Jeffrey seemed impressed at my attempts to entertain
we are going to have to trade you in soon" she laughed, always the first his royal highness, so far giving him exactly what he wanted the
one to throw in her quick-witted two bits, all of them chuckling along impression that I idolized him. They told me that he really liked me and
with her. Hardly a laugh at all, unknown to me at the time his eldest was having a great time, so far tonight. When we got to the townhouse,
daughter is only five years my junior. I was finding it hard to make much his guards walked him to the door, staying to wait outside in the car.
conversation in the beginning,just laughing when the occasion called for Ghislane met him and brought him upstairs where Jeffrey and I were in
it, and keeping up with Andrew's constant glances in my direction, was the study. We all chatted in the hall for a few minutes and I was able to
all I could manage. have Jeffrey snap a photo of us together, one that would cause much
The restaurant was a close drive for us with Andrew, his two guards and controversy for the Buckingham Palace in many years to come. The
his driver following behind us. I was seated next to the Prince for dinner conversation didn't linger on much longer before Jeffrey and Ghislane
and Ghislane and Jeffrey next to each other, an evening pre-ordained. I dispersed downstairs together, leaving me to my own sort of royal duties.
was supposed to flatter him with compliments and dote on his every word They walked away giddy as if they were teenagers imposing on young
spoken, but I didn't even do that for Jeffrey blatantly, it would've felt lovers about to embark on a romantic evening.
awkward to act like a bimbo for him. Instead I remained calm, cool, and Next to the study was the bathroom where I led him to next. The room
collected, hoping that my nervousness wouldn't spill out at any given was dimly lit masking the light from showing the disparity in my eyes. It
moment. The next place we were going was much more my style, and I was a beige marble tiled floor with porcelain Victorian style bathtub in
found it easier to relax. We pulled up next to a Nightclub called "Tramp", the middle of the room and nowhere near the size of Jeffrey's residences.
a member's only nightclub, and one of the most exclusive haunts in the I turned on the taps for the tub and the heat from the water began to steam
world for the rich and famous to be seen for the last forty or so years up the small room. On the basin were aromatic oils, lotions and soaps,
since it's doors first opened. Andrew's guards waited outside while we all loving the scent of floral notes, I poured in the lavender bath oil. Trying
went in to hit the dance floor. Jeffrey being the social introvert that he to do the best of my youthfulness to try and act seductive, I gradually
was found the first available empty seat in the comer but facing the dance began to strip off my clothing, piece by piece. Giving him time to savor
floor to spend the evening watching everyone else have fun and Andrew the moment to come. He loved every second ofit as I went over to where
went to the bar to grab us all drinks. He came back with sparkling water he was waiting and watching, then began to undress him at a much
for Jeffrey and a cocktail for the rest of us, already knowing that Jeffrey quicker pace. We kissed and touched each other before submersing into
never drank alcohol. We downed our glasses and made our way to the the hot water, where we both continued to reenact foreplay. He was
crowded dance floor, where I had the Prince's upmost attention. Moving adorning my young body, particularly my feet, caressing my toes and
his hands across the curves of my body, not to shy away from the fact licking my arches. That was definitely a first for me and I couldn't help
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but laugh, I hoped he didn't expect the same treatment back. Through my like minds. Jeffrey didn't want to know the grim details of how it all
recent experiences with Rena, I drew a line with extreme fetishes, happened on my intimate night with the Prince, he just asked simply if I
especially ones that would involve my tongue and feet in the same thought that I did well in keeping his friend happy. Knowing already that
sentence. It wasn't hard to get him wound up to the point where he just the evaluation ofmy performance 1 gave was already discussed between
wanted to have the rest ofme so we dried off from the cold and retired to them, I just as simply replied back with a nod of approval. Though I did
my bedchambers for the longest ten minutes of my life. Moments later have a laugh with Jeffrey about the Prince's weird fixation on my feet
and without any real emotional attachment, he burst in ecstasy, leaving and lets just say that he was quite tickled with Andrew's quirky
me to my own feelings of dismay. As relieved as I was to see the obsession, having a good ol'chuckle at my eccentric encounter. I was
experience come to pass with him, it was finally sinking in that I would paid extremely well this time, putting my money earned into nothing but
never be anything more than but a muse. Still trying to ascertain a surreal popping pills and alcohol by shouting my so called friends a good time,
dream a young girl once held but no longer the same girl I was no longer aiming for the attempt to forget about my experiences abroad. I partied
sure that the dream was even real anymore. In the whirlwind thrown like that to feel young again, my age and most of all to self-anesthetize
together by wealth, power, and privilege I was but a grain of sand and felt my troubles from within. It wasn't like I was waiting for someone to
helpless down the road 1 was naively being led down. When the real arrive on his white horse and take me away to a magical world. I simply
picture was unveiled, later in my life, I had nothing but memories filled yearned for more out of life than being someone's replaceable
with sorrow to remember of my teenage years. amusement. Still a romantic at heart I would often get lost in my
Jeffrey, Ghislane, and I left for the states to conclude our long journey daydreams, imagining a new beginning with a strong man that would
home to the U.S.A. I was so happy when we landed on our soil and called show me an enduring love, safety in his arms, and a lifetime friendship.
T.J from my cell phone to see if he'd meet me at the airport instead of Though the suggestion of true loves existence was only a dream for now,
going back to Jeffrey's, he'd be there within twenty minutes, he was so something I could only read about in novelistic fairytales but the passing
happy to hear my voice and that I was back in town. So ecstatic to be thought from time to time was wannly envisioned. With my inner most
getting away from my life of servitude for the next few days, I was sourly desires being locked away in a deep crevice of my heart, I knew my
disappointed when I got off the phone. As if he'd been listening to my romantic notions would be absurd in Jeffrey's eyes. For some unknown
entire conversation, Jeffrey told me he'd like a massage back at his place reason to me he couldn't allow himself to give love or receive someone's
and he could pay me at the same time for my trip with him. With much heart in return. Once he said to me when I asked him ifhe ever thought
dismay I had to call T.J back and cancel the arrangements, I wouldn't see he would settle down and find Mrs. Right and he told me he didn't
him until later that night, in which one of Jeffrey's staff would drive me believe that love with one monogamous partner was possible but he
home and I would be too exhausted to do anything. found that love with many was. 1 thought at the time it had something to
do with having so much money and everyone wanting him for that
instead of seeing him as a person and even felt bad for him, but now I can
understand from his recent lessons unlearned that it was a simple
equation of his twisted perversion to become infatuated with the
vulnerable youth off the streets. Spending so much time in the entrapment
Chapter 12 of Jeffrey's embrace, I was becoming numb to the feelings and aspiration
to ever climb above this deep hole I had dug myself into. I knew I wanted
to escape from this bizarre form of first class slavery but I still didn't
have the tools necessary to help me get out. How could I have? Everyone
When we got back to Jeffrey's mansion in Palm Beach he wanted to that knew me believed I was living this enchanting life, a rags to riches
thank me for showing his friend, the Prince, such a good time. Rewarding success story that most people dream of, only I knew the price to be paid
my diligence with an extra sum of money and luring me deeper into his for all of this and I was the only one who could pay for it.
goal of keeping me at his side as his personal amusement that he could Underestimating my true self, I was settled by Jeffrey's side for now
lend out at anytime. Further proving his capability of using the vulnerable considering him to be someone to look up to, my mentor. Such a
impressions ofa young girl to influence and intimidate his fellow peers of
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complicated battle within myself, it is one I still ache to fully comprehend encounters with Jeffrey's "staff' but I led the way anyways, as ifhe was
today. now my guest of honor. Entering into the dim room it took a few minutes
Sunny spring days melted away the ice off the frozen streets of New for my eyes to adjust to the darkness, but knowing my way around the
York and the harsh winter winds begun to gently blow away the dead room was enough to find the shower. I turned on the steam room and
leaves, making the caged trees appear to have some form of life again. I began to undress myself. Andrew followed my lead and disrobed,
hated the cold winters there, it would only add to my depression being throwing his attire to the floor. I wanted to run and hide feeling his hands
locked indoors. Give me hot Florida days blistering in the sun where I touch me again, but my servitude for Jeffrey kept me there. Getting out of
can swelter by a cool pool and sip cocktails with pieces of fruit and little his stronghold I turned my attention to the steam filling up and tried to
oriental umbrella's floating around. What a vision of solace? Looking tum his attention to the marble bench where I suggested he take a seat
around my extravagantly decorated mid-evil room I was reminded of the while I rubbed his feet. By the look in his eyes I knew he could care less
desolation that I was more than accustomed too. Knowing it wouldn't be about a foot massage, his real desires were being shown by the arousal
long before I was summoned again for another ritualistic occurrence in his body was forming. He indicated where he wanted me to touch him
fornicating with my master, I hardly bothered to leave my assigned and how. I fulfilled his seedy requests, but only just. There was no
chambers, scarcely being sent home for a moments break, I just accepted pleasure in this for me, the only thing I derived from this event was to
my fate. As I predicted the intercom buzzed momentarily and I heard sink further into my slumber of depression. I couldn't remember a time
Ghislane's voice come over and request to meet them in Jeffrey's study. when I felt needed for anything other than my body or amusements
Not an odd call, I would often meet him there first so he could tie up thereof. After his massage was thoroughly conducted I couldn't wait to
some unfinished business before heading to the dungeon, or what was get back to my room for another shower. Sitting on the floor of the
thought to be the massage room. Making my way down the hall, I had an shower under the harsh spray of water, I scrubbed my body where he
eerie feeling wash over me, as if I had several pairs of eyes on me, touched me. Feeling abhorrent and ashamed what I had become, I let the
watching my every move. A cold chill moved up my spine and I had to water wash away the grime.
move my thoughts elsewhere, too easy behind these walls to succumb to As the days progressed into nights and the nights followed a trail of
my fearsome anxieties. I punched in number one once inside the elevator destructive months, my outlook on life had diminished into utter sadness.
and it took me down to the floor where Jeffrey and his surprise guest I had lost my spark and my ability to look like I could handle the abusive
were waiting with anticipation behind closed doors. I cracked open the state of affairs I had drifted into. Sinking deeper in the euphoric state of
heavy wooden doors and a familiar face revealed itself. Definitely not being on coke and pills, not only was my mentality dwindling away but
expected or pre-warned on my part but I already knew what he was here also my looks. I sure as hell didn't feel like a seventeen year old anymore
for or at least why I was called down to the study. Prince Andrew had and now I wasn't looking like one. My eyes had dark circles underneath
that notorious cheesy grin slapped over his face, as he looked me up and them from not sleeping and my bones protruded from my skinny
down like a shiny new car on display and he was about to take it for a test waistline and chest. This made Jeffrey apprehensive in keeping me
drive. Ghislane led me to the decadent sofa he was lounging on and around as often and before I had a moments notice, I was out of money
twirled me around to give him a good lookover before sitting me down on and looking for a job. When I questioned him what was happening, he
his lap. Like a show pony I knew exactly how they wanted me to be told me I wasn't the same girl he had first met some time ago now and
paraded around, with the last of my dignity long lost, I had nothing more looked like I needed a break from working so much. " I'll call you next
to lose. It was easy to give them the reaction they desired, all I had too do time I'm in town" was the last thing he said to me.
was pretend to be entertained by their lewd gestures, and when Andrew
cupped my breast with a doll made in his image, I only giggled away.
Ghislane wanted to take a picture of the bizarre scene and even got Chapter 13
Johanna, another one of Jeffrey's so-called personal assistants, to come
Going back to an average teenagers life was more of a harder transition
sit on his other knee for the snapshot, giving the impression girls couldn't than I would've ever thought. Jeffrey stopped paying my expensive rent
stay away from Randy Andy. and I was forced to get off the drugs and look for a real job to feed and
Many crude jokes later and I was asked to show Andrew to the upstairs
shelter T .J and I. It was much harder than it sounded, but I was craving
massage room. I'm sure he already knew where it was from previous
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this in every possible way. Even though a week's wages for working a Obviously mentally distorted from whatever choice of drugs he was
full-time job as a waitress didn't come close to the money I had made in a smoking that night. He screamed down my apartment complex, going
couple hours of working for Jeffrey, I was happier than I had been in a mad and scaring my neighbors I felt like I had no choice but to let him
long time. I made some friends at my new job and found my duties to be inside. I tried talking to him as a good friend would, just wanting him to
easy and pleasant. I was good at making customers smile and keeping see what he was doing to himself and what he had become. Part ofme
them happy becoming the waitress that made the most tips for the night, still loved him and took pity on watching him spiral downwards. Taking
which in tum made my co-workers happy since we'd all split the tips at him back into my life was not a decision 1 made whole-heartedly, but was
the end of the week. For the first time in a long time I had boys my age something I did out of guilt and what I thought was loyalty. He moved his
hitting onto me, and not that I was ever taken aback by there attempts but clothes back to my place, which was all he ever owned anyways and we
it reminded me of how it felt to be around a younger crowd. I missed so tried to pick up the broken pieces. T .J being still badly addicted to many
much of what I couldn't get back and the more I tasted it, the more I drugs, I had to be very careful where I kept my jewelry and expensive
remembered how to smile. The relationship between T.J and I began to items. I decided to rent out a space at a local spot and store my cherished
falter in a way that was beyond reconciliation. Fights became physical items away, just taking the necessary precautions, I thought.
and I saw sides to him that only pushed me away more. He refused to Still not working I knew how he was scraping by money and 1 didn't
look for work to help pay bills and he became utterly frustrated not agree with it, T.J was a known thief and had been caught several times
having his usual cocktail of assorted drugs to keep him from feeling attempting to steal things, even as stupid as DVD's and PS2 or Xbox
anything at all. He didn't like the fact l was growing inside and thinking games from a local Blockbuster. He even stole from his parents, his sister
beyond his elusive world. I had gone through too much to accept another and his brother and would probably steal a piece of candy from a five
form of abuse and degradation. Making that point very clear to him by year old kid ifhe knew that it would get him his next fix. He hated the
kicking him out of my apartment back to live with his parents, I felt change in myself, realizing I couldn't be brought back down by his ways
liberated like never before. I kept up with my rent and cleaned my act up. but knowing I still stuck by his side and defended him from anything that
Enrolling in a yoga course and keeping my focus on staying fit and would hurt him wanting to believe that he still wanted show the bits of
healthy became my only source of enjoyment. I was free and living for human nature left in his empty heart.
myself. Unable to stand by and see me do well for myself he contemplated a
While out doing the grocery shopping one evening I couldn't help but way to try and bring me down. After a busy shift one night, he retaliated
stop at the local pet store and fell in love with a furry pooch. She was a with another show of control. I had just finished cleaning up my area and
Japanese Chow-Chow and a bundle of fur that more resembled a baby setting out the tables to be ready for the next day when I went to the bar
brown bear than a dog. 1 took her home with me and instantly she became to hang up my apron and put my nights tips in the tip bowl on the counter
my best friend. We went for several walks a day and she bore the brunt of by the beer tap. On one of his drug induced rampages he stormed into the
many tear filled conversations, she was my loyal companion who restaurant where 1was working and started to pick a fight with me. 1
understood more than anyone had before, all I really need was someone knew he was off his face when he started accusing me of sleeping with
to listen and funny enough it was her that filled that hole. my manager on shift that evening. Having no bias or ground to stand on
Nearly three months had gone by and not a word from Jeffrey or in his attempt to make me look bad in front of everyone, I just laughed
Ghislane. With T.J out of the picture now too all I had to concentrate on him off as a drunk idiot who needed to go home and sleep off the night's
was work, my parents and brothers, and of course my dog, Mary-Jane. I repercussions, although I was fuming inside that he embarrassed me but I
was going to family night dinners and hon fires again. My older brother still made excuses for him and told my boss I had to leave early to bring
was getting married to an amazing woman in a few weeks and I got to be him home.
apart of their beautiful ceremony. Small details oflife's journey that I The bar was deserted as T.J waited alone for me slumped in a barstool
already missed so much of and now being able to smile at the simple and looking worse for wear. l had to go to the back of the restaurant and
things day in day out really seemed to put the real value oflife into do some explaining to tl1e manager on duty, I couldn't afford to lose my
perspective for me. Everything seemed to be working out for itself and 1 job over this incident. Surprisingly he was sympathetic towards my
was really happy, until he came back, T.J thought he'd come over my dilemma and even told me I could do a lot better than that schmuck,
place one evening while I was sitting at home just watching TV. patting my back and telling me to have a couple days off. 1 punched out
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and headed to my car with T .J in tow. For the rest of the night he was desk and told me to have a seat across from him. He took a sip of water
oddly quiet and asked to be dropped off at his parent's house, I was more from an already poured glass and asked ifl'd like some. "Yes, Thank
than obliged to do so. Tcouldn't stand the sight of him let alone want to you" My reply was short and polite, already just wanting to get this
be around him tonight. Being so revved up it didn't yet dawn on me that meeting done and over with. His face was like steel and his expressions
something wasn't right. The next morning Twas woken up by an alerting were stem, Tfelt like a child in trouble sitting in the principles office.
phone call, I had the manager from the restaurant where I worked, on the He cut straight to the chase wanting to know "Are you on drugs
other end screaming at me and asking where the money is. I sat up in bed, anymore?" There was a moment's pause as I took a deep breath and told
completely awake now, and asked him back, "What are you talking him the entire truth. "I got really depressed for awhile and coped with my
about, what money?" His tone had calmed a bit and he could hear the emotions by blanketing them with mind-altering substances. Just smoking
earnestly in my voice and explained his accusations "The tip jar was a jay to relax wasn't good enough anymore. I needed to be high and
empty after you had left last night and there was over a hundred and fifty flying to believe Twas happy and dealing with all oflife's curveballs.
dollars in there, now it's missing". The answer hit me instantly and I got Snorting things like coke and popping amphetamines replaced my
a terrible knot in my stomach ... T..T.When Tleft him at the bar not even sorrows with an overflow of endorphins, making it possible to keep up
thinking about the tip bowl to talk with the manager, he saw an with everything, until I would come down and the cycle just kept on
opportunity to fund more drugs and he took it. That's why he didn't even repeating itself'.
want to come back to my apartment last night. It was all too clear for me He listened to me continue to tell him about the good things that have
now and I tried to explain to my manager about my boyfriend's sickness come from the break. Like my dog, yoga, and working at a restaurant,
and asked him to take the lost money out of my wages. "I have no choice making lots of new friends but most of all, I got my smile back, without
but to let you go and file a police report for the missing money". I the drugs this time. He was really happy to hear the upside of everything,
couldn't believe what I was hearing. How did things tum upside down so but there was one thing I was reluctant to tell him about. My recent
quickly? I exclaimed "Even though I'm paying you from my pocket for travail that T.J effortlessly caused at the restaurant where I was so happily
money I didn't even steal and you've never even had any problems from employed. As my manager had warned he had to file a police report
me before?". His apologies were short and icy, nothing that could be stating that after I had left, the tips were gone, putting the blame solely on
done. I slammed down the receiver only to pick it up again to dial I.J's me.
parents house and to no surprise he hadn't slept there last night and was Giving Jeffrey a clear picture of the entire ordeal he exclaimed "What
not able to be reached. Tfelt like Twas in a bad dream Tcouldn't wake up are you doing with this idiot Jenna, he is no good for you! Tknow you can
from and with no money to pay rent, eat, or even survive, I was back to do better for yourself, why do you let him drag you down every time?"
the drawing board. Nodding my head in concurrence I went on to finish my epic drama. "I
The week passed without hearing from T.J, he was in hiding, for now. received a phone call from the PBCP asking me to come in about the
When the phone rang early one morning I expected it to be him, instead it money, I told them what happened over the phone but they still want me
was a surprise phone call from a familiar voice. Jeffrey decided to give to come in. I don't want to have a record for something I never did or
me a call to invite me over to his Palm Beach mansion for some lunch ever would do!" Tput my face into my hands and covered the tears now
and to catch up, it really was just his way of finding out ifl was cleaned trickling down my cheeks. "I just can't believe this is happening to me
up and ready to come back to work for him. With my life in chaos once when everything has been going so uphill, now I'm out of work and in
again and having to borrow money off my parents for grocery food, Tsaw trouble" I wiped my face and looked up at him " What do I do?" Enabling
a quick solution to my situation and was even convinced this is what T him as my mentor once again, his sly grin said it all. Jeffrey normally
had to do to take care of myself. hated when girls made waves in any way and this one would be
He greeted me at the door and led me inside. Ghislane was at her usual considered a tsunami but this time it worked to his favor. He wanted me
spot, her desk working away, and we headed past her with a quick wave to come back to work for him, continuing my massage studies and I
and lip-synced a "Hello", not wanting to disturb her important sounding needed his help. In his eyes he was doing me a solid, which in return I
phone call. She glanced up quickly and gave a brisk wave my way, then would have to scratch more than his back for. Taking his time to
put her attention back to the computer. Once we were inside the poolside contemplate what to respond back and what solution he could offer, T
cabana, which was Jeffrey's office, & gym, Jeffrey took a seat behind his began to worry that maybe I shouldn't have done this.
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Pulling a few tissues out of the box, he passed them across the desk to ultimately became close pals and he invested one million dollars into
me. Trying to retract any damage done I said to him "I must look like Brunel's company. In return Jeffrey now had supply of girls on tap for
such a mess to you and making you listen to my saga, I am so sorry ... I him to choose from.
shouldn't have come to you with all of this." He looked surprised and With the assistance of each other, Brunel obtaining the illegitimate
sympathetic "Quite the opposite actually. I'm glad you've come to me for visas for underage-overseas girls and Jeffrey housing them at his
help. I have got a lot of connections especially with the Palm Beach brother's apartment complex on 301 E 66 th St, Manhattan, they were
County Police Department. I give them reh>ularhundred thousand dollar quite the team. Jeffrey and Bmnel would charge them for rent, forcing
donations, and after I speak with them there will be nothing more to them to work for them selling their bodies for money, nude pictures, and
worry about. To be honest I'm more in shock about how much can even pornography. These were what seemed like really nice people with
happen to you in such a short time, your life is one big soap opera" not so nice intentions setting an impression of how the dignified wealth
Now he was chuckling and trying to make light of my somber mood. play and behind closed doors they had as much civilized manners as a
Laughing along too I replied, " I know right? Drama just hangs around barbaric chimpanzee in heat. Giving a girl a step-up in finances by
me like a bad smell". We did some more light-hearted catching up and teaching them there only worth is what lay between their legs, us girls all
went out to the poolside for some lunch and a swim, concluding the were the same in the end, regardless of what country we came from, what
evening with an erotic massage upstairs. He paid me the usual two language we spoke or our cultural indifferences, we all were being used
hundred dollars and asked me to come back tomorrow. "In the meantime for one thing alone, our youthful looks and beautiful bodies.
I don't want you thinking about your sticky situation, consider it dealt Being Jeffrey's permanent sidekick, I would have to part-take in a
with". His attempt to brighten my spirits had worked relieved about many of the hedonistic exploitations that went on at one of his many
money and the police but now I owed myself to him feeling indebted to residences, which meant having to be uninhibited with many girls my age
him more now than ever. and younger. Being complete strangers was hard enough but we couldn't
even understand each other, speaking in different tongues we were
expected to excel at preforming many acts of lovemaking and foreplay on
Chapter 14 each other, while being observed by a man in a comer jerking off. Not
exactly what I would call an advantage in my stage oflife, but in my head
I was convinced we all had to do what we had to do to get on with life
As was promised I never heard back from the Police Department and
and if that meant doing all of this to keep Jeffrey happy, then I would do
Jeffrey had his favorite girl back by his side. We picked up where we left
that.
off ever better than before, I being entirely subservient to every sexual
It didn't take long in the accompaniment of Brunel for Jeffrey to hit an
desire of his engaging myself in any role he wanted me to play. As he
all time low, at least one that I knew about. Stupid enough or sick
was getting older his appetite for sex never hazed, if anything it only
enough, I don't know which one it is or both but Jeffrey bragged about
increased. The orgies with other girls got larger in numbers and his
his birthday present from Brunel, once accepting three, twelve year old
appeal to younger girls, new toys and wilder nights expanded from once
girls, sisters at that. He replayed the descriptive events with me telling me
and awhile to quite an often occurrence in Jeffrey's company. I put it
down his new friend and business investment, Jean-Luc Brunel. how they all massaged him and finished him off orally. He was so excited
about the entire event, replaying over and over again over the next course
A long time agent for young and upcoming models, Brunel, a French
citizen, was known for roaming the world in search of young, nai"ve of weeks how cute they were and how you could tell they were really
young by the small amount of hair growth in their pubic region and non-
beauties living in poverty stricken countries and willing to do just about
existent breasts. A twelve year old, are you serious? I thought to myself.
anything for money. He would procure them mostly from Clubs in South
I still can't shake the feeling of disgust when I recall the look on his face
America and the Former Soviet Republic. Filling their heads with
as he told me time and time again of how his lust brought him to that
fairytales of America and large amounts of money, he would promise
profound low. He went on to tell me how Brunel bought them in Paris,
them all of the finer things in life, sometimes even throwing a pill in their
France, from their parents. Offering them the usual sums of money, visas,
drink, if that meant getting them in his bed was becoming too much of a
and modeling career prospects was a bribe of the worst kind, they were
task. What he wanted is what he got, which is why him and Jeffrey
just children. Laughing the whole way through, Jeffrey thought it was
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absolutely brilliant how easily money seduced all walks of life ... nothing I still was given proper training in massage therapy from time to time,
or no one that couldn't be bought in his eyes. Behind the two of them keeping me from looking back at being a teenager with no responsibilities
followed a destructive trail of those in their path that were misused, to being a young adult with prospering titles. He knew I wanted to be self-
violated, degraded in a variety of ways for one purpose ... to satisfy the sufficient so bad I would do anything for it and by giving me this dream
desires of the perversion that rotted their hearts. to hold to only kept me in check. I looked forward to my training
The next couple of months I spent in Jeffrey's company, my life was sessions, holding onto every word passed down to me and after the
revolved around him and his petty happiness. Arising to the occasion, I session was complete I would hurry back to my room and transfer the
was no longer his teenage sidekick, I was growing into being a young information into a workbook with associating exercises.
woman and my body was blossoming like never before. Out of the Trying my new moves on Jeffrey always impressed him, he would get
awkward stages of my life, I now took to looking after myself like never excited hearing about my passion for knowledge and would tell me he
before. Regular sessions in tanning beds and keeping fit became my life could see it transfer into my massages, always giving it my all, my hands
outside of Jeffrey. He kept telling me what a beautiful woman I was were a focused energy when I was at work. Using every ounce of strength
developing into and would offer suggestions to help me look good. to apply on a body, many were astounded in what I could do for being
Sending me to dentists for regular teeth whitening consultations or such a small girl, and Jeffrey loved it, using me for a two-hour massage
helping me choose my attire for the evening, he was ushering me into a "with benefits" sometimes being over twice a day. Ghislane would
whole new position, training me up for something else, but I was unsure sometimes use me to massage her still but it wasn't as common, she
of what that was. preferred a man for that job.
Being a snotty little teenager was a girl of the past. Now I had to be his Then would come the odd client here and there, of course set up by
eloquent speaking, desirable to all and almost his personal porcelain doll. Jeffrey. Most of which were orchestrated to get beautiful girls
I went everywhere with him again, all of his eclectic dinner parties, comfortable and consequently naked then he would go in for the kill, so
conferences, and meetings with various members of parliament, famous to speak, touching them intimately, in their most private of places like
celebrities, and other esteemed billionaires ... most of whom lived by the their vagina, breasts or anal. When he had us where he wanted, willing
same rule of thumb as Jeffrey did. Quite an alarming realization having to and able, then would come the toys, outfits and so on. A scheme he has
accept this world the way it is. Jeffrey knew all of the right people in this used time and time again, telling those who know him well "he had never
game, and trading girls for favors is how he kept in the circle. He was at been turned down yet". It was starting to dawn on me how I wasn't
the center of it all, blackmail being the only thing next to money with the getting any clientele that weren't used for Jeffrey's benefit and would
ability to pull a many of strings, his conniving ulterior motive was to drag make me wonder if I just wasn't good enough for that, but I kept quiet,
all that he could down to his pitiful state of mind. Inviting easily tempted never wanting to make waves like I had before.
acquaintances to his island or his other various residences he would bring To give me a break from it all as if Jeffrey didn't want to overload me
out the assortment of young girls and pass them around like they were again, he would send me away to his ranch for a few days, what he knew
cocktails on a platter. No girl had a choice in whom they went with, only I considered being a small slice of heaven on earth. I'd spend my days
completing a task, we would have to charm and bedazzle these ageing fat roaming the hills, riding horses, and enjoying the solitude ofmy own
men who other than paying for it would've never had a shot at getting to company. One afternoon I was out exploring the land on Jeffrey's ranch
know a beautiful girl intimately. I personally belonging to Jeffrey rarely which covered hundred's of acres with nothing but a bottle of water, my
had to be loaned out and it was a big occasion, or should I say favor, if I sketchbook and a small case of oil paint. I was on the search for
was. I'll never really know what made me so important or special to something interesting to paint. A great pastime of mine, it made my soul
Jeffrey, it definitely had nothing to do with love. I guess in the end I will quiet by creating beauty with my brush. I loved to recreate the images I
always put it down to my capability of being whomever he wanted when saw on paper. I would paint anything beautiful that caught me eyes
he wanted, so compliant it just made it easy for him to have a personal interest, from underwater scenes, animals to people and even frnit, I loved
toy at his constant disposal. All I can say is I lived in a jail with no bars, vibrant colors and emotion on display but my favorite soon became the
and in a country where slavery was supposedly abolished a long time ago landscape of the Santa Fe's rolling hills and earthly green and beige tones
but still existed right underneath everybody's noses. Myself and so many and in certain light it would illuminate into a golden shine. To grasp that
other girls were walking proof of it. feeling I was absolved in at the hardest of times became my greatest inner-
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achievement, like taking a piece of that serenity and putting on paper for could become a sight for historical preservation and that means the
me to keep in my heart where it still is today, closing my eyes I am able government could ultimately own my land."
to see it, being there anytime I need to. I was enjoying the heat and taking I acknowledged his request and told them they were just a gift for my
in the deserts sights when I stumbled off the track and into the Mom, who was in love with Indians "Wait until she see's I brought her
wilderness. Exploring everything new to me was my second nature and back real artifacts, she is going to totally freak out." He didn't mind that I
never even entered my mind what would've happened if I went too far or was taking them. In fact he admired my curiosity and adventurous spirit.
got lost. I would rather face Mother Nature's wrath than humankind's any He reminded me that tomorrow was my last day. I would be driven to the
day! Albuquerque International Airport the day after next, to meet Jeffrey in
After about an hour of drifting offtrack I came to a pile of rubble, New York, for how long, only he knew. Giving Jeffrey many thanks for a
looking like the remnants of an old pueblo made out of clay and rock. I great week, letting him know how much I appreciated these small breaks
picked up what looked like half of a clay bowl and noted that it had away, we then said goodnight. Hanging up the phone I had caught my
Indian designs etched into the side of it. Excited about my findings I second wind and set out to the kitchen to find a late-night snack. Raiding
decided to do some more exploring around the fields surrounding the the fridge and pantry, I found some frozen pizzas and popcorn. I put on a
historic site. I collected rare pieces of arrowheads, utensils, and parts of movie and munched on the popcorn while the pizza cooked. Some 1980's
many broken bowls with artwork telling tales of their own. Time was of dreadful alien flick got the better of me that night. It was based on a true
no essence here and before I even realized the sun had sunk deeper into story about people abductions from extraterrestrial beings, which were,
the hills leaving me without any light to find my way back to the like I was, visiting a remote area. I suddenly hated being alone on a ranch
pathway. Feeling silly now after passing by a familiar looking boulder in the middle of nowhere. I munched down my burnt, crunchy pizza and
twice over, I was startled when l heard some poor animal become dinner became further enveloped in the thick plot. Leaving on the TV and the
for another, it's screams of agony only amplified louder and echoed in lights on that night, I spent my night tossing and turning, peeking through
my ear drums, heightening the hairs on the back ofmy neck and making the small open crevices of the comforter, half expecting to see an alien
my heart beat nearly out of my chest. being in my bedroom.
I was lost and confused before but now I was petrified with fear. Living through the night was a relief and I laughed at myself in the
Taking me over three hours to find my way back to the path and in the morning, how spooked did I get? When I got to New York, Jeffrey, and
direction of Jeffrey's mansion was a mission, so relieved in the end and Ghislane had a good laugh over my tale of survival in the wilderness and
so were the housemaids after I hadn't showed up for dinner, assuming I then the alien scare. "Your always having the best adventures" Ghislane
must've been out for one ofmy usual adventures. I went to bed exclaimed. We were similar in that way, both beings bit of free spirits it
strenuously exhausted that night and as I was falling asleep the phone was really only her non-existence of moral standards that differentiated
rang, it was a call from Jeffrey who had been alerted ofmy the two ofus, in that way. "How do you know you weren't abducted and
disappearance. "What happened tonight, one of the maids called me to probed? I mean look at you and all that time alone on the ranch, what do
tell me you hadn't come back from your walk this evening" Detecting a you think Jeffrey, could she pass off as an alien?" Expectedly, Ghislane
tone of anger in his voice I tried to distract him by telling him ofmy poked fun at me, her usual fun past time. Our relationship was an odd
findings and he scolded me for being gone for so long without anyone one, never threatened by each other but always precautious towards one
knowing where I was. Going back to the Indian remnants, I persisted on another nonetheless able to crack a joke together, but when it came time
telling him what I had found. In the end he was just worried about me to "work" it was no fun and games, she was intensely serious. "With a
becoming a liability, but had to make it sound as ifhe cared." Don't sense of humor like yours I would tend to think that you are the one from
worry Jeffrey, I won't be doing that again. I can honestly say I have another planet." Just friendly banter between the two of us, then Jeffrey
learned my lesson and the next time I want to explore I promise to take had to jump in with his two bits, "I think you might be onto something
someone with me". I satisfied his worry of me being a future nuisance Ghislane." I squinted my eyes and gave them both an exaggerated death
and with that I was finally able to tell him what I had discovered on my stare and pretended to grab my stomach in pain, "I think some things
walk. He was impressed but did not sound surprised. "You must've been trying to get out ofme", putting my fist in my shirt to reenact a scene
gone a long time if you found the old Indian pueblo's, just be careful you from Alien, I fell onto the couch and faked my death. "I knew it"
don't say anything about where you found the stuff on my property, it Ghislane shouted and jumped on me to begin tickling me all over and we
91 92
all broke out into laughter. lt was those fun times that made me feel like I joined him for a shower, steam bath and concluded his needs with a
we were all apart of this really perplexed family. We did everything massage while listening to classical music. I knew he didn't want
together similar to normal families like eat dinner, watch TV, and travel it anything sexual from me now seeing he got what he already wanted
was only the hedonistic and corrupt side to these two deviates that made downstairs, no this one was purely therapeutic. My favorite massages to
them a peculiar pair. give, making me feel like an actual real therapist. I lathered him in
Getting turned on at the two of us playing together, Jeffrey came over aromatic oils and let my hands discover the ways to unlock the stresses
to the couch we were on and pulled down his sweatpants revealing his that his body held. After the massage was concluded we were going
erect manhood. All of the laughter stopped, now it was time for work. downstairs to get ready to go see Ghislane's townhouse as he had
Pushing my head into his pubic region 1 had to give into his perverted promised her earlier. He loved taking the hidden staircase while I hated it.
wants. Ghislane started to undress me. Once I was bare she loved starting I was so creeped out by his choice of decor, the blood red carpets, violent
with my breasts. She cupped them in her hands and brushed her fingers medieval paintings, and sculptures of the pagan god Pan, all ofit
over my hardened nipples heading downwards pressing her lips deeply representing the darker side of hedonism his lifestyle provoked. Spiraling
into my skin, I had to maneuver my body on the couch in a complex down the hallway along with each step you took came with a pair of eyes
position to give them both what they wanted. And just like that, without that followed your every step. Brown, blue, green, hazel, all of the colors
even a moment's notice I could be put on the spot and have to amuse were there, staring at you the entire way down. As each step progressed,
them in any way they wanted. A shameful way to make someone feel like so would my anxiety to get out of there.
a used toy, I wasn't around for companionship I was there for one thing, I We found Ghislane where we had left her, in her office. She had just
was a compliant piece of eye candy. received an order in, a satellite camera with a twelve-inch flat screen. She
Twenty minutes later and Jeffrey had erupted in pleasure. Ghislane sat told us how it was used to pick up any person in any location with the
up, still fully dressed, and wiped the sides of her mouth with her hands, quick insert of an address. Quite a powerful new toy I thought, but it was
giving a vindictive little chuckle, "That was fun." Jeffrey concurred with only a minute display of what the rich could afford, what use they would
a sly grin arching his back for a stretch just looking able to utter the get out of it was another concern. Soon after she was done figuring out
request "Why don't you come up with me upstairs for a steam bath and the controls on the camera, we made a rare and first for me pit stop, the
massage, I need to be loosened up after that?" It was more of a statement security room. What I thought was our way out by the front door was
than a request, as if I had the choice to say "No thanks, I'm actually tired another hidden door. I was in shock as I was led into a room, so discreet
myself and would love to just relax" instead I would reply with my that in three years I never even knew it existed. I kept my head down
accustomed trained obedience, "No problem, when your ready lead the most of the time, knowing how secretive this must be being another door
way." I had to get dressed again being that we were in Ghislane's was an entire security base within his mansion. What I could see when I
downstairs office. Putting my clothes back on, Ghislane thought she had stole a glimpse here and there was an array of tiny screens, twenty odd or
buttered him up just where she wanted him to ask for him to come have a something. Small screens showing various rooms of the mansion I had
look at her new townhouse renovations when he was finished with his recognized. The images were constantly changing so I found it hard to
massage. A very strange relationship those two have, there's a definite pinpoint an exact location but from the decor and short glimpses I
love flowing between them but not a passionate one, more like a suddenly knew from then on that my feelings of my every move being
respectful business, he gets what he wants ... an uncountable number of watched inside his corridors was now more than a possibility but was
girls and she gets what she wants, simple and sweet ... an uncountable actually happening. Jeffrey spoke to an obese Spanish guy at the desk,
amount of money. The two things in life that can create such beautiful whose job was to disgustingly overlook all of the video feedback. Kill
moments or the most horrendously terrible of them all, is sex and money. two birds with one stone Jeffrey thought, free porn to share with all of his
pedophile friends and when the occasion called for it, a security system
all at one expense. Ever consumed with making money as well as saving
Chapter 15 it, I was again astonished at Jeffrey's capabilities. I didn't want to even
think how deep the video infiltrated, pretending like I never saw anything
at all I put the memory to the back of my mind and went on about my
day. Stopping at Ghislane's new townhouse, another gift bought and paid
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for by Jeffrey, he pointed out needed changes all over the place, driving fill his appetite, so on occasion I would meet a pretty girl around my age
the builders mad, as always. He wanted the place to scream out and invite her back to his place to make some quick money by offering
"GHISLANE" with a bold statement. Checkered floors and bold colors her a really good contact in the modeling and acting business. Keeping
was the theme, like the queen of hearts from Alice in Wonderland, very him satisfied and in need ofme was a tiring job. With so much
well suited I thought. competition I had to be on the ball, seeming ambitious to grant him all of
The dust from the walls being torn down chocked my throat and the his desires. It was a lot of pressure and a spotlight of a role to undertake
elevator was not in use, the stairs were hardly either. The whole house at such a young age but I told myself this is what my life's training had
was in bad shape then having to go up three flights of rickety steps was a led me up to be.
bit of a risk too but worth it once you made it to her future walk in My Birthday was around the corner and turning eighteen had lost all of
wardrobe or to us commoners, a closet the size of a small a house. its sparkle and pizzazz. There were no more surprises in store for me,
Complete with a dressing room, luxurious bathroom and plenty of storage nothing that would bedazzle me I hadn't done already. I spent my
for her every ensemble. Even without it being finished it was already a birthday on the island, having a quiet dinner and watching "Sex and the
work of art, a sanctuary for any woman. She adorned herself in her future City" on the couch with Jeffrey, Ghislane and Emmy. There was no cake
home, finally her own, relishing every inch of it, she already put in a or a celebration of any sort but I did get a couple of presents that I opened
work desk and spoke constantly of its ongoing renovations. About an outside underneath the main cabana. Jeffrey gave me a beautiful pair of
hour later we were off to pick out curtains and look at some paint samples sapphire and diamond encrusted earrings and Ghislane bought me another
at a couple different boutique looking shops. Easily passing off as an designer makeup case. I thanked the two of them with a tight squeeze and
ordinary couple for the day, they walked arm in arm strolling the streets a gratuitous short spiel. As it went quiet, I looked out to the ocean and
of the Upper East Side. Except to me, still replaying the early afternoon's wondered if across these waters was there ever going to be happier days
events, shaking my head over the echoed images in my mind, I followed spent with someone special to me. Would he be kind, compassionate, and
behind just waiting to be needed again. always be there when I needed him most? Or would I end up settling for
Over the course of the next few months was a constant influx of my final bit of training, a marriage to a greedy old scrooge? Either way
exorbitant excursions at Jeffrey's mansions, mainly to his island, to keep what I wanted most didn't matter right now, I was still bound by Jeffrey's
up with his ever-demanding sexual appetite with various young women hold over me and all I had to keep telling myself to get through this epic
and teenage girls. I got back on the Xanax, an old habit that I felt at the journey was, this is just the way it was for now.
time would stop my memories from flowing back, rehabilitate my Around the table for breakfast Jeffrey announced that he was expecting
problems and relax me enough to deal with any situation at hand, no a few guests coming over with Brunel, no one ofimportance,just his
matter what the circumstance revealed itself to be. It was a drug that usual entourage of beautiful girls. Russian models this time and Jeffrey
would blind my eyes to everything I should've been running from. was also having a photographer flown in to take modeling photos using
Having Brunel always in the picture these days wasn't helping me at all the island as the perfect background for a sexy shoot. All ofus girls were
either. Sending his girls for Jeffrey at all of his places now and at a ushered onto rocks, hammocks, dug into sand and displayed just about
vigorous flow, they had an abundance of girls at their disposal. IfI were anywhere they wanted. We were being photographed in next to nothing,
to count one girl for everyday of the week, it would be the like a netted fabric placed over us if the shot called for it, but the more
underestimated statement of the century. So many girls between the two provocative the more Jeffrey and Brunel loved it.
of them, some nights it would be a free for all frenzy for Jeffrey and After the photo shoot we did some outdoor watersports. While us girls
Brunel, seven or so girls giving them their upmost attention, doting on raced the jet skis around and jumped on the water trampoline, the men
their every moan and whimper, Jeffrey being the main concern since stayed on dry land to watch us from the beach. I was so used to this
Brunel worked for him and we were all aware of that too. If there were constant charade of girls and I didn't mind having a bit of fun but this
heaven on earth for men like Jeffrey, than he would be their God. Every was different, I had to be more than just polite because I already knew it
one of his inner most desires was fulfilled when his harem of women was wouldn't be long before we were all intimate with each other as well.
around. No wonder he didn't travel much abroad these days, all he ever Being the only girl that spoke English out of all of them was also a huge
wanted was right at his doorstep. I couldn't believe that he was still blunder. The only way we could communicate was through hand gestures
asking me to bring girls to him as well. There was never enough girls to
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and body language, a very primitive form of speaking, but what choice day or retiring for the evening, an outside shower was always splendid.
did we have? Under a thick dark cloak of the night sky only the moon and stars to shed
I did my best to get acquainted and as I had previously assumed after enough light for me to see my way around. I could feel the soft breeze
lunch on the beach we were again ushered into another part of the island, lick the droplets falling off ofmy bodies' curves in the reflection of the
Jeffrey's cabana. There was no need for words here, as the girls already moonlight. It only encouraged me to stay longer under the warmth from
knew exactly what to do. Without saying anything they undressed me and the spray of rushing water. I let the hot water run out before I was
began to ravage my body with their hands, tongues, lips and fingers. I sufficed enough to go back inside. Lounging around the bed in my
was delirious, never having done anything like this before with so many panties and a tank top I was still sweltering from the heat. Trying to tire
girls. It was sheer chaos; I don't honestly know how men could fantasize myself out, I did some reading and eventually fell asleep. I needed those
over this. Through the glimpses in between bodies crossing over me I times to unwind after such an ordeal, letting the Xanax wash away all of
could see Jeffrey and Brunel watching us, sitting in a chair with their the pain I could then forgive the mistakes I had made, blaming myself for
hands around their penises, stroking themselves together "The best part is staying around for this I had wished I was never born at all. The pills
they don't even speak English so there's never a need to have to keep would take all of that away for me. My heart was a tangled weave of
them amused" I could hear one of the men divulge and pretty sure it came deception and pain, only reassured by the lies that were told to me and the
from Jeffrey laughing out loud to Brunel. I just closed my eyes and went lies I would have to convince myself of.
somewhere else in my mind until it was all over. That was that, life went
on and we all moved on to eat dinner together. Chapter 16
It couldn't be more awkward as Jeffrey and Brunel were beside
themselves with their ego's beaming, and the girls chatted like busy little
When we flew back into Palm Beach, Juan drove me back to my
chipmunks with each other. Ghislane and Emmy on the other end of the
apartment. Lonely for some companionship I decided to call an old
table were being amused at the entire racquet around the table and then
friend. I was longing to be important to someone and unfortunately with
there was me. Sitting quietly and smiling in people's direction when
such little time to have a social life ofmy own I was compelled to call T.J
needed, I was counting down the minutes until I could go lay down in my
again. His Mom answered the phone and sounded quite surprised to hear
giant comfortable bed, slipping away to the gentle noises the island
my voice on the other end. She was always kind to me, I even used to
created and sink comfortably into a deep sleep with the assistance ofmy
bring her back "Cola" cans from other countries a bizarre hobby she
Xanax. Scratching at the plate in front of me with my fork out of loved collecting. She just didn't know what I saw in her son, even saying
boredom, I wasn't even hungry. I had lost my appetite for food. Rather
that to his face many times over. Not blind to his ways of cheating and
sipping on the champagne I wanted to feel as far away from here as
stealing, being a personal victim of it, she made it apparent that she did
possible. What seemed like hours for everyone to finish their meals we
not approve ofT.J's choice in lifestyle. It used to really hurt him how his
were finally all saying goodnight and goodbye to each other, as Brunel parents thought so badly of him, so he gave up trying to earn their love a
was off early in the morning and taking the eight beauties with him. long time ago. As long as he didn't steal from them anymore he was
"Thank God" I told myself, once was more than I could handle of that in
allowed to live there. Instead of that being a lesson to him, he would just
one day. try to be more clever in what he would steal, less obvious things. He
It didn't take me long to get back into my own comfort zone. Heading
would steal the toaster and sell it for five dollars ifhe knew it would help
straight back to my cabana after dessert was served nearly tripping over to get him his next high.
my own two feet as I tried to scuttle off in a hurry. As soon as I entered
Nonetheless and at my expense I had a sweet spot for him. With
my domain, I drew a breath and sighed a deep exhale outwards, finally
enough water under the bridge, I was able to forget about the troubles he
alone and at peace ... for now at least. Although the sun had set hours ago
caused. His Mom told me she'd pass on the message when he got home,
the high temperatures of the Caribbean were still an affliction, plaguing
but that could be days from now. The last time he had been home was
my cabana I was welcomed by a rush of warm air as I opened the door. I
over a couple of weeks now. He only stopped by to get something to eat,
hit the switch to the fan and stripped down for a shower. Preparing my
have a long sleep and to beg her for a few bucks, supposedly to help him
towel and toiletries I opened the back door to the outside shower and
buy food. Then he was off again without a single word said, only leaving
placed them on the floor. Whether I was cleaning up in the midst of a hot
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his parents to their own assumptions, which were pretty much correct by his allegations I could only mutter out a whisper "Did you just say that
anyways. Adam is dead, what happened?" "Oh snaps, I thought you knew, where
I then called around a couple of mutual friends to see if anyone had have you been girl, under a rock or something?" Marcus was less than
heard from him. Everyone I spoke to pointed their fingers in the same sensitive about his statements. "He got shot in the head by two black guys
direction and the worst place possible, Ritchie's house. One of his best who got suspicious when their usual supplier didn't show up, your boy
friends told me of how bad he was doing, "He's not the same guy T.J was so fucked up he didn't even remember to tum up at Ritchie's for
anymore, and all he cares about is the next high he gets. Ifwe don't get the delivery, so Ritchie sent Adam alone and now he's dead." Adam was
anything for him he just loses it and goes off somewhere." It was hard to a sweet kid who just happened to be born living on the wrong block. Best
hear how badly affected my best friend was and a part of me secretly friends with T.J since childhood, the two were inseparable until puberty
hoped they weren't right. Still defending him, I told everyone I had spoke hit and even then they would chase girls together. Adam followed in I.J's
too while trying to find him that T.J would be fine, he's just probably every footstep, mimicking his shadow, ifT.J jumped off the Eifel Tower
going through a bad phase, like we all do sometimes and needs people to then so would Adam so when T .J got hooked on drugs consequently
have his back more than ever now. I was pretty much laughed at on the Adam did too, leading ultimately to his death. Wanting to end the
spot, most people that I considered my friends at the time were only conversation with Marcus quickly I scribbled down the phone number on
friends by association. As long as we all looked the part, acted the part, a blank piece of paper in front of me and hung up the phone to call
and could handle the part, only then did they want to be around us. The Ritchie's place immediately.
last person I called was the last person I had hoped he wasn't with and it "Yeah?" It was Ritchie whom bluntly answered the phone after the first
turned out that everyone was right. ring. "Hi-Uh- Rich, It's Jenna, I.J's ex, we met a couple of times at a
He was with one of the biggest Coke dealers in our area, Ritchie-Rich, few parties" I was trying to remind him of who I was knowing how
as everyone used to call him. He didn't look like a typical strung out paranoid he was about people having his number. "Oh yeah, I know who
junkie or dealer. Instead he looked like your average preppy college grad you are, what is it you want?" He answered with a dry tone." I was
with aspiring propositions. He dressed well and acted like a nice guy to hoping you could tell me where I could find T.J, I've heard some stuff
imminent clients only to get them hooked on his drugs and then turns and am really worried about him, is he alright?" Ritchie snickered at my
them out onto the streets. He was a businessman and his business was concerns. "What are you his Mom or something? He's fine, he should be
thriving. He carried everything from most drugs to guns and knives. back here around five o'clock, I'll tell him you called." In the middle of
Having ears in all places made him a dangerous acquaintance. Using kids me saying "Thanks and good-bye" he hung up the phone, as there is no
off the local Palm Beach streets to nm his dirty errands and the errands of room for manners in his line of work. I waited until five o'clock watching
the others above him, he made his money by using these teenagers, who the minutes on the clock tick past and when five o'clock came and passed
as hard as it was to believe was once somebodies sweet child. by with still no phone call, I couldn't deny to myself that I wasn't
I knew T .J didn't have the finances to support himself or his drug habit stricken with distress. Falling asleep wasn't easy either. I ended up
so the likelihood of him being indebted to Ritchie in other ways was a crashing out on my sofa watching T. V, half expecting to hear of another
safe assumption. Obtaining Ritchie's number from one ofT.J's friends murder on the news and it being LT.
Marcus he asked me, "What do you want to call Ritchie for? Come over Forgetting to put on my eye mask before I went to bed, I was woken up
to my place and I can get you whatever you want" Marcus was a sleaze the next morning by rays of the sun beaming into my living room. When I
bag who would tirelessly continue to try to appeal to my lesser sense of sleep I am a creature of darkness, avoiding any window light at all costs.
judgment, never getting the hint or just not caring that I could never and Staggering to the coffee pot not used to getting up this early, my first
would never be interested in him. "No Thanks Marcus, can I just get the thought that day was T .J and why he hadn't called. A million thoughts
number please, it's very important that I get ahold ofT.J, I'm really rushed through my head like a steam train .. .is he ok? ls he not calling
worried about him." I hated having to call this guy let alone have to ask because he is still mad from our last breakup? Has he moved on to
him for something. "Is this about the Adam bullshit? Cause ifit is you someone else? Is he in any trouble? Did Ritchie even pass on my
can let him know what a fucking bitch he is for not showing up to be message? The thoughts were an endless infliction, consuming my entire
there for him, you can tell him from me that it's his fault and it should've day.
been him that's lying in the morgue now, not Adam" I was totally thrown
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Until finally he called my cell phone later in the afternoon, relief swept through the thin walls and trying to find the unit number was difficult
over me when I heard his voice on the other end. "Thank God you called, from the sporadic flickering of the fluorescent lights above me.
I have been so worried about you, are you alright?" I jumped in without At last I found Ritchie's one, quite astonished with myself that I even
letting him get past saying "Hello". "Yeah, I'm fine. Ritchie told me you made it this far. I had to knock loudly on the door a few times before a
called his house looking for me yesterday and gave me shit for it saying young girl answered the door with eyeliner bleeding down from her eyes,
you were upset or something, what's up?" I knew I would have to be her jet black hair was strung out and a mess and she looked off her face
delicate about asking what happened to Adam, thinking he'd be a mess on some hard drug. She had only her bra and a short skirt on to cover her
over it. "I heard from Marcus that something happened to Adam and I got private areas and a cigarette hung out of her mouth to complete the full
worried about you, what is going on?" T.J sounded scared, for what picture of terrible state she was in. She looked me down with contempt
reasons were beyond my knowledge but I was going to find out, he and snubbed at me "What do you want?" I maintained my politeness and
replied" I don't want to talk about it over the phone. Are you in town so told her T.J was expecting me. She opened the door and walked away,
we can meet up or something?" It was obvious I wanted him to know that leaving me by myself to venture through looking for T.J.
I was more than willing to lend my shoulder for his problems. 'Tm home Passing through the kitchen it looked like a hospital lab with syringes on
now if you want to come over whenever you feel like it." He didn't the counter tops and medicine containers lying around everywhere.
hesitate in taking me up on the offer. " But I won't be able to get there Minding my steps through the dirty house, I walked to the back to the
until later, I'm downtown at Ritchie's place unless you want to come pick living room and found T.J in a K-Hole strung out on a filthy couch.
meup." "Hey ... there" he acknowledged me with a giant smile spread across his
It was more of a request than a favor to myself which is what he was face. He probably didn't even know who I was from the dreadful state he
making it out to sound like, knowing him all to well I didn't make a fuss was in. My first look at him in months and I was in utter shock. My jaw
of his ill-contemplated attributes. I got the address off him and made my must have dropped to the floor at the very sight of him. Never seeing him
way into the ugliness of the not so dazzling parts of the Palm Beaches so skinny and unhealthy looking I took pity and wanted to help him
downtown area. Rolling up my windows and locking the doors to my before things got even worse and he ended up like Adam, dead.
truck I nervously drove through the rough streets trying to find Ritchie's "T.J, hey buddy its Jenna, remember I was coming to pick you up
apartment complex. Knowing all too well the history of the area, it's not a today. You don't look so good, what are you doing so messed up?" I
place a lone white girl in a nice truck wants to be seen, many reports of don't think he could even understand what I was even saying because he
the locals rushing up to a vehicles with a weapon demanding money, could only reply by giggling and rolling over, patting the couch as ifit
cars, or just angry and out to hurt someone. I was speeding through the were a fluffy animal. I stood over him now and raised my voice so he'd
streets wanting to get out of there as quick as I could. A sad world we live know I was serious and snap out ofit a bit. "Get Up T.J, Now!" I ushered
in with so much hurt everywhere you look and nobody wanting to do at him to get off the couch, repeating myself a few times over and with no
anything about it, just accepting the hopelessness of never being able to response I knew I had to get physical. Rolling him back over to face me
achieve anything more than what our civilization has succumbed to. again I smacked his face hard and I'm sure it stung but I got the reaction I
Being among one of those people, we were similar in so many ways. had wanted. He sat up and looked at me confused.
Only separated by our own personal fears and the different direction they At least now he was able to focus on my words requesting him to come
pulled us into. with me. He was getting up from the couch and stumbling around before
I drove straight through the open gates at the entrance to the complex falling down to the floor again. Putting his arm around my neck and
and parked on the gutter in front of Ritchie's block of units. A crowd of carrying the majority of his weight, I helped him up many times over and
people stood outside the blocks I was entering. Being hit on and offered down three flights of stairs into my truck and drove him back to my
drugs simultaneously my cheeks went flush and I put my head down not place. It was a triumph on it's own arriving downstairs in one piece.
saying a word. Walking up the corridors of the staircase looked like a Being the only person who really cared ifT.J lived or died I felt like the
scene out of a horror flick. Graffiti covered the peeling of green paint on responsibility of helping him was my concern alone.
the walls and the pungent stench of something rotting, only to the worst Thankfully Jeffrey was in Palm Beach for the next couple weeks
of my imagination, filled my nostrils. I could hear babies screaming entertaining royalty, which gave me a little time to try and clean T.J up. I
called a few of his friends that I knew and asked them not to score any
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drugs for him any more, pleading with them and telling all of them he that I hated every minute of it, seething through all ofmy duties until he
was on the brink of death, reminding them of the friendship between us climaxed.
all that once existed before the drugs corrupted so many ofus. Some of Most days I could take this kind of treatment, it was only seldom I
them laughed at me telling me I was wasting my time with T.J and others couldn't hold in the way Jeffrey disregarded my feelings. He had me just
were nice enough to at least lie to my face politely and promise not to where he wanted me, like a pawn piece on a checkers board I was his
help him feed his addiction. own personal sex slave. For the remainder of the evening I stayed quiet,
I just wanted to remedy all of his pain and problems but I felt so not sure of what to say after an episode like that. It was a vigorous
helpless fighting his battle against the streets. I bought some marijuana display of how calumniating he could really be. He required me to clean
for him to smoke hoping to subside the withdrawals he was facing over up his spilled semen off of his genitals with a wet warm washcloth before
the next few days but with no avail. The only thing that would help him he retired to his bedroom for a good night's sleep. Only a monstrous
was my Xanax, a few of those pills and he would go back to sleep, only creep could sleep easy at night knowing what pain he caused others.
waking up to get more of them. I would have to force him out of bed to I went downstairs and asked Juan, who was still in the kitchen to pay
have a shower once a day and make sure he ate something. He was more me for the evening telling him that Jeffrey had gone to sleep for the night.
like a baby right now than he was a boyfriend, too much in need of It wasn't an unusual request. Juan would often have to fix up "the girls"
something I couldn't give. after the sessions and sometimes even drive them home. He went to
Jeffrey's desk and underneath was his duffel bag that always held
insurmountable bundles of crisp hundred dollar bills. He took out two for
me and handed them over. I thanked him and said goodnight, as I was
always polite to Juan and his wife, Maria. His eyes were gentle and told
Chapter 17 me more than what he was allowed to say. I understood well. We all
needed to eat and pay bills unfortunately even sometimes at our own
moral expense.
Putting the keys into the ignition I started up the engine and reversed out
When I went to see Jeffrey over the next course of days he picked out
of Jeffrey's driveway with promptness. I didn't want to be there a
the dilemma I wore spread across my face straight away. "Your back with
moment longer than I had to. Not much to look forward too getting back
T.J aren't you" It was so funny that he knew me so well. "Yeah, he's in a
real bad place in his life right now and needs my help." He looked to my apartment either, I needed some time to filter my emotions.
Parking my truck in front of a nearby beach I took my shoes off gradually
astonished and replied, "You're a much better friend than I am, I know
people like him and trust me they never change, no use in even trying" I stepping out of the door into the fog. I walked down to the edge of the
believed him too knowing I was stupid for even attempting to change T.J, sand where the water licked at my toes. My life was slipping away from
but my heart felt differently, he was still a human being and a good friend me and I was really beginning to question the difference between living
and dying. I was so tired of everything, my whole existence revolved
of mine just down at his worst. 'That's what good friends are for" I
around being everything to everyone, forgetting about being something
laughed back at his remark, not wanting to take this conversation too
much further." I admire your loyalty at least, but take my word for it, he for myself altogether. Pretending to be someone else became an attribute
I was better than good at, probably much of why Jeffrey liked me in the
will hurt you again." His words were chilling but true, I had to find out
for myself though. first place. This time I held back my tears back and only let the anger
fester into a deep pit in my stomach. My rage was aimed at the very
Almost seeming like an actual friend for a second he ruined his brief
people who abandoned me to fend for myself in the first place and
momentary image by turning over from the unfinished massage that I was
accepted this life as nonnal for me, my parents.
giving to him and acquired his sexual longings from my worn down soul.
When I got back to my apartment I was expecting to have to look after
Not only did he know that I didn't want to endure any more demands
T.J, but to my surprise he had come around good that night. He greeted
tonight, but his energy enhanced from knowing it too. Looking up at him
me at the door and asked how my evening was. "It was all fine" I easily
during the foreplay, it was an easy observation from the look in my eyes
lied. I never let anyone inside close enough to see my vulnerabilities.
They were mine alone to battle. In my head they were too shameful to
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talk about anyways. He wanted to talk about something else anyways. together but I thought in this world and to these monsters, there didn't
Sitting me down at the dining room table he began his spiel. " I know you need to be a reason. To them it's nothing but a reenactment of their
don't think much ofme anymore, how could you? I'm a junkie who personal fantasies. To me it was a living nightmare.
steals and sells drugs for a living, but I promise that's all going to change Thankfully one of Jeffrey's assistants from New York called me on my
now. Adam is dead because ofme and the only way I can make it up to cell phone early in the morning on the second day to fill me in on my
him is to get away from it all. I promise things are going to get better." It next adventure. I had a flight booked for me to leave that afternoon to
was a convincing talk, but I knew him all too well. His demon inside arrive at La Guardia airport in the evening. Even though I had to go back
yearned for him to fail but who was I to second-guess him out loud, I to yet another controlling man, I was still relieved. At least I was used to
could only try to give him hope. "No one is perfect T.J. At least you're the confinements of Jeffrey's control and in some twisted way he was
trying now and that's all that matters to me. I am so proud of you." I gave more comforting than these strangers he sent me to. Overlooking the city
him a sincere hug and kissed him for the first time in a long time. "I love of New York as the plane landed felt like I was flying from one cage to
you," he said to me and I returned my love back. We slept in the same another. Entrapped by falling victim to the predators that lured me into
bed together that night and were officially back on together. their enclosure. I didn't know how I would ever get out again. That deep
Two days later I was gone again, beckoned to be in Santa Fe. Ghislane pit in my stomach began to churn again, a physical reaction to the anxiety
only told me that I was to meet someone there, not sure of whom that I was plagued with. Before getting off the plane I touched up my make-
was. It wasn't my place to ask questions. As far as I knew it could be up to hide any signs of the frailty I was feeling.
anyone and I had no choice but to be compliant to their needs. It was the Jo-Jo met me at the arrival terminal and picked up my luggage for me.
middle of the day when I arrived at the airport. One of the ranch hands He never said much at all, nodding to any reciprocating conversation. I
came to pick me up in a big work truck that smelled like dirt and sweat don't think he could really speak that good of English anyways. It was
but I didn't mind that's what I loved about the countryside. better for me as I preferred the quietness for the moment. He opened the
When we arrived at the mansion my guest was already there waiting for back door for me and we headed off for my next prison cell. When we got
me. I couldn't wipe the look off my face as he turned around from the to Jeffrey's mansion on 72"d,the place looked empty. I walked up the
bookshelf that he was standing at. "Hello" that same old cheesy grin staircase to Jeffrey's office and he wasn't there. Feeling a bit hungry I
greeted me once again. It was his highness Prince Andrew, and what a walked back down to where the kitchen was. I opened the fridge and
sight. He wrapped his arms around my waist and greeted me like an old found some leftovers that Adam, Jeffrey's chef, had cooked. I loved his
friend. I hugged him back rolling my eyes at the same time, already cooking, when it wasn't filled with beansprouts and tofu. He used to
dreading what lay in store over the next couple of days. My job was to make me the best pizza upon request, or whenever he was cooking
entertain him endlessly, whether that meant having to bestow him my seafood, which he knew I hated. He had an honest appeal about him and
body during an erotic massage or simply take him horseback riding. For never even took notice when on many occasions us girls would be
the next couple of days he was to be my only concern, but he wasn't. I prancing around topless, sometimes even stark naked around the pool or
called in checking on T.J a few times a day, not wanting to be a nag but beach. He would have to serve us our meals and would do it with such a
just hoping he hadn't had any thoughts about relapsing. He was doing casual professionalism, never making anyone uneasy at any occasion.
great, even applying for a couple jobs. Being reassured by him made my Halfway through my meal the kitchen doors swung open and incoming
time away less complicated and thankfully with the help ofmy ever- was Jeffrey and Ghislane. Choking down my bite of food down, I got up
ready Xanax I was able to cope with the ordeal. from my seat and kissed them both on the cheeks. " Hi guys, how are
The mansion was completely empty save a couple of maids who also you?" I greeted them and Ghislane answered for them both "Good, good.
cooked our dinners for us, and a couple bodyguards that we hardly even Sit down and finish your meal, don't let us interrupt you." I hated eating
saw at all. The time dragged by slowly for me as I was counting down the alone in front of people, chewing food and maintaining a conversation at
hours until I flew away again, anywhere but here I thought. It wasn't easy the same time didn't give off the best look. "I was just finishing anyways,
meeting the sexual desires of these strange men, the Prince being one of can I get you guys anything, maybe a tea or something?" Always playing
them. He loved my feet and even licked in between my toes. Then there my part, another reason to keep me around 1 b'lless, I went beyond the call
was the lack of passion in the intimacy we shared, to him I was just of duty and after the last period with them, I had been reminded ofmy
another girl and to me he was just another job. Not the right reasons to be place. "Yes, I'll take a one" Ghislane stated. "Jeffrey how about you,
105 106
anything I can get for you?" I asked again and he answered, "No thanks, reading the backs of interesting looking books. I bumped into a girl
we just ate and I'm still full" and they sat down together on the stools at looking down the same aisle I was down. "Sorry, I'm so clumsy" she was
the kitchen bench. apologizing for my mistake. "No, no, it was my fault, I wasn't looking at
I got out the shiny red kettle from the cupboard, knowing my way all where I was going. I get so wrapped up with my nose in a book and trip
too well around the kitchen and put it over the hot stove plate. Turning over my own two feet if I'm not careful enough." We were both giggling
around to face them, I thought they were acting peculiar. "So ... "Ghislane now and I further introduced myself to her. Her name was Valerie or
started the conversation, "How was the ranch with the Prince?" It was a Vickie or something like that, anyways she was a student at a school for
natural reaction for me to blush, knowing exactly what she was referring hairdressing nearby. Chatting away both young and similar interests in
too. Keeping busy preparing her cup of tea and avoiding eye contact with each other's choice of reading we found it easy to speak with one another.
both of them I started to unpack the counter where I had been eating, "I She wasn't from around here only being in the city for the last two
think he had a really good time, he seemed relaxed during the trip and months, her parents hated her being here, but were also supportive in her
when we said good-bye to each other he gave me a kiss." I went on to tell big decision to move from the countryside in hopes of her accomplishing
them what we did together "I took him horseback riding, nowhere to far her own dreams. Aside from not having her near them, they just wanted
just around the property, um ... we went swimming in the pool, and of her to be happy and supported in her big decision to move to the city,
course I gave him plenty of massages. He had a massage at least couple helping her pay some of the way.
times each day really seeming to enjoy his time there." It's what they She was a pretty girl with cherry red hair and soft white skin. Her long
wanted to hear, not the truth of how disb'llsting I had felt over the whole legs were emphasized by the short flowery dress that complimented her
thing but they already knew the truth anyways, it's what they had trained hourglass figure. She would definitely fit the pro quo for going down in
me for in the first place. one of Jeffrey's little black books. Only imagining the look on his face
Like two proud parents they both looked over me with such content. upon meeting her I could already see his sly grin spread from ear to ear.
"Good, you did really well" Jeffrey complimented me. Turning around to Knowing exactly what he would do with her and the very thought of him
the boiling kettle, I finished Ghislane's tea for her and the conversation tarnishing a sweet country girl such as her just couldn't be done. It was
led on to other subjects. We all ventured up to Jeffrey's office and out the beginning of a turning point in my life that started with realizing I had
came the infamous duffle bag that went wherever he did. I was given a choice at hand and the effect I could have on one person alone. "I must
close to a thousand dollars for my time in Santa Fe, more than what I be off, but it was really nice to meet you." Bidding her goodnight and
thought anybody at my young age could make for a couple days of work. paying for my books I turned around with one last glance over my
It was fulfilling the obscene vulgar needs of the so-called privileged that shoulder and said. "Good luck in the city!" Leaving that bookshop was a
earned me so much. small step in a growing abundance of larger strides to come. Turning the
comer onto 72nd street l had an undeniable feeling in the pit ofmy
stomach again but this time it wasn't the familiar hurl of anxiety I was
Chapter 18 used too after I had done something I had wrong that I had regretted, it
was a new feeling of pride and inner strength. I quite liked it a lot, I held
I spent the next few days in New York, venturing out to do some my head high and smiled on the inside when Jeffrey asked me how my
day was and what I got up to, not mentioning I had let one girl slip on
shopping therapy. I loved the eccentric parts of the city. Every street was
different but the same energetic vibe filled all of them, animated with all bye.
The icy winter winds faded away making way for the approaching
different walks oflife. Hanging out at coffee shops reading the newspaper
sunny days that blossomed the colorful shades of spring. This was my
or a good book was a favorite pastime while in the big apple. Being close
favorite time of the year. Making the most use of his island we spent
enough to get back to Jeffrey for when he needed me but also far enough
countless days of the increasingly hot days there. A constant array of
to get away from all of it. Most of the day slipped by without being
missed and I made my way back to Jeffrey's. visiting guests and plentiful young women to flock around keeping them
entertained was the typical lazy afternoon on Little St. Jeff's. We ate,
Making one last pit stop, l walked into an old bookshop to browse at
drank, and played under the blue blanket of cloudless skies. To many this
their assortment of old titles. l wasn't in any hurry so l took my time
lifestyle could seem idyllic, unless you were like me, the one on the other
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side of the fence where the grass wasn't so green. Fortunately for me and enough to find some old coins here and there. It wasn't easy though, both
in some ways not, I was mostly expected to attend to only Jeffrey's loving a challenge it was perfect for us. Enduring many scratches from
insurmountable of sexual desires. Whereas the other girls who came one the bushes we would be searching through and then the soar arms from
day and went the next were promised a multitude of open doors just for digging all day, but it was worth it in the end. After nearly two years of
there meager participation in sexual acts with random men, only to be collecting items and saving them, we made Jeffrey a mosaic table out of
disappointed when they realized they were nothing more than a single the remaining pieces left from the era of the pirate's day. Upon
night out for these geriatric senior citizens who most likely due completing it we were both astounded in our creation, it was such an item
Alzheimer's would sooner forget the entire experience let alone their first of rarity and an interesting piece of work. When we presented it to Jeffrey
name. he was even impressed not only in our amazing finds but what we did
Surrounded by those in our world who many looked up too but not with them. The table became an important work of art that Jeffrey
seeing them from where I was standing, I didn't have the highest of showed off inside the main house's lounge room, sparking a much
standards in humanity. Then I met Al Gore and his lovely wife during intrigue and table conversation by many of the visiting guests to his
one of those many weekends away in the Caribbean. I was blown away island.
by the amount of attention Al doted on his wife, it was so sweet to watch. The next morning was good-bye for most of the visitors, leaving just
They sat next to each other at the dinner table gazing into one another's the usual behind. Soaking in the sun and living it up in the lap of luxury is
eyes having an intimate conversation between them. Among the many how the next few weeks were spent before having to get back to the
guests visiting that night and many of them young beautiful women, not dredge of the city. Sometimes we'd have to go to St. Johns island for
once did Al's eye's stray elsewhere, to them they were the only ones Jeffrey to do some work in the office. It was so boring for me to sit in
there. He was up for a presidential election that year and he definitely had their listening to him on the phone or coming down on some poor
my vote. Anyone that could show that much devotion and passion employee for something stupid like not answering the phone correctly. If
towards his loved ones could have the same devotion towards running a I knew he was going to be awhile I would excuse myself for a bit of
country, or at least I thought so. He only left his wife's side to have a shopping. Not that the Caribbean had much to offer in the world of
walk down to the beach with the host of the weekend, Jeffrey. The fashion but there was never an amount of bikinis one girl could own and I
weather was still warm in the evening when I decided to break away from loved all the little knick knacks one could find there. Flying back on a
the idle chat around the table and take a stroll too. private jet was the best part because l could transport just about anything
Not wanting to interrupt the conversation between Jeffrey and Al, I I wanted back to my apartment, which was already filled with an
walked in the opposite direction plucking the washed up sea shells assortment from my shopping ventures and collection of seashells from
imbedded in the sand along the way. l enjoyed the serenity in the solitude the Caribbean.
of the island. So many nooks and crannies to get lost in, I could imagine The next big dinner party on the island had another significant guest
that I actually disappeared from the entire world for a moment. By the appearance being, the one and only, Bill Clinton. He is the only president
time I came back to the main house majority of the small crowd had been in the world to be dismissed from his role as a world leader because he
long gone retired to their cabanas. Even Jeffrey had gone off to bed but was caught with his trousers around his ankles and had the stain to prove
trust party animal Ghislane to still be up entertaining the remaining guests it. Publicly humiliating his wife and himself he retired from his title but
left at the table, regaling her wild stories of people and places she has not from his lifestyle. This wasn't a big party as such, only a few ofus
embarked on. Trying not to make eye contact as I walked past them on eating at the diner table. There was Jeffrey at the head of it all, as always.
my way back to my cabana carrying my seashells inside my curled up On the left side was Emmy, Ghislane and I. Sitting across the table from
blouse, I wasn't up for anymore pointless talking tonight. Emptying out us was Bill with two lovely girls who were visiting from New York.
my seashells into a plastic bag, I went over my new treasures one by one. Bill's wife, Hillary's absence from the night made it easy for his apparent
I loved collecting odd things, shells being one of my favorites. provocative cheeky side to come out. Teasing the girls on either side of
Ghislane and I shared that interest together. We would enjoy walk him with playful pokes and brassy comments, there was no modesty
abouts around the island searching for lost pieces of the remnants that between any of them. We all finished our meals and scattered in our own
pirate's had left behind centuries ago. It was mostly broken plates or different directions.
smashed glass from bottles of ale, and even occasionally getting lucky
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Jeffrey wanted his evening massage before bed and Ghislane and Jeffrey's business was running well from the looks of his attentiveness
Emmy went to their office to talk about something, leaving our guest of the office he owned in the Upper East Side of Manhattan. Alan
honor to find company elsewhere. Strolling into the darkness with two Dershowitz, his colleague in finances and personal solicitor, a bird of the
beautiful girls around either ann, Bill seemed content to retire for the same feather, l had seen hanging around the island and Jeffrey's
evening. He wanted to have a hot bath before bed while I began the Manhattan mansion, more and more these days. Alan's taste for the
massage in the tub. Starting with his feet and calves, he wanted to end the young and beautiful was a bias for a blooming business relationship
night quickly. Never showing any restraint he sat up on the edge of the between him and Jeffrey. After an explicit session of Jeffrey's vulgar
tub and asked me to prefonn on him orally. I did my job, but that's all our pilgrimage into my body, we were interrupted by a knock at the door by
relationship was these days, a dreadful job. Getting it over and done with Jeffrey's good friend, Alan. l wrapped myself up in Jeffrey's pink bed
as quick as possible was my hope but I couldn't let him pick up on those sheets, which is the color preference he chose to sleep in because it
vibes, to make him enticed I had to act like his little porn star, knowing reminded him of the same color of his own words "Pussy", and covered
exactly how he wanted it. Only then would my duties be fulfilled and I my face from the unexpected intrusion. Jeffrey got up and wrapped a
would be able to get back the reality ofmy complicated life. Before I towel around his loins and answered the door completely calm. Opening
could say goodnight, Jeffrey had one more request. He wanted me to tuck the bedroom door and letting Alan inside they began to converse about
him under the blankets and fluff his pillows for him. Then I had to reach business immediately, right in front ofme. Jeffrey started to tell Alan
under the covers and massage his feet while watching him fall asleep, he what needed to be done while he jostled some notes down quickly. I
even wanted me to wait like twenty minutes or so after he fell asleep peeked my head from underneath the covers thinking they were too
before I could leave. It wasn't unusual for him to ask it but God I hated it, wrapped up in their work to notice me get up and dressed, and Jeffrey
never offering it I would always wait for him to request it. Once he was turned back to me and told me to just stay there this would only take a
snoring gently I wiped my hands clean of the lotion and quietly closed the second. Going back to Alan he turned his focus back into work and
doors to his room. Making my way up the outdoor spiraling staircase, I hustled out a few more orders before letting Alan out of the door and
felt the breeze blow through my hair and looked up to the heavens. The returning his attention to me.
stars shown so bright out here in the middle of nowhere with no big city "Sorry about that, work never stops and neither will the money coming
lights to hinder their effect I could get lost in time staring into them. No in. How else am I going to make a million dollars while I'm sleeping?"
matter how far gone I really felt there was always something about a Jeffrey chuckled as he sat back down on the bed next to me. I laughed at
simple caress from the wind or the reflection of the star sweeping sky in his humorous and mostly true statement, then a strand of hair fell in front
the black glossy ocean that would always remind me ofmy fond love of ofmy face. Before l could get to it he put it back behind my ears and
nature's blessings. sweetly stroked my face, for a moment we just looked into each other's
Back in New York, there was nothing left of nature to adorn. It was a eyes and he nearly seemed almost human to me. It was bizarre how he
dwelling for those who no longer saw the use for trees without cages or could be so kind and gentle one moment and the second beforehand I was
blue skies without clouds of man made fumes and gases. Unfortunately if being treated like no more than a common plaything left out for display.
we weren't in the Caribbean, we were there in New York. Hardly going Nothing more than an ego trip, Jeffrey got off on letting the ones he
back to Palm Beach, barely even seeing my family, my dog or T.J these wanted to know that he could own anything and anyone he wanted in this
days at all. In my parents heads I was all grown up and educated in the world. Maybe for a brief minute I believed the sincerity behind his eyes
world of wealth not needing them any longer they would just wait for my but that vision would quickly fade away and I would be left second-
call once in a while to let them know how I was doing and that was the guessing why I even fell for his deceitful tricks for a moment.
extent to our restricted relationship. The road my life has led down never Jeffrey got up from the bed and asked me to join him for a shower. In
has kept me close to home anyways so to me it wasn't anything his bedroom, which was the entire top floor, he had a glass shower
unordinary but still a sad existence to be without a family ofmy own. It enclosed underneath a glass skylight right in the middle of the room. It
would've been nice to be missed though, rarely letting myself think like was perfectly accessible feature for a man that loved both being clean and
that. No room for pity in my heart, if l did, the floodgates could open and nude, but still an odd feature at that. As I always did whenever I
I'd have enough grief in one lifetime to go around a few times that they showered with him, I lathered a loofa with soapsuds and would scrub his
would've never been closed. body, up and down, in between his toes, even behind his ears and of
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course his genitals area. The sunlight shown through the glass ceilings It all came to a sudden conclusion one sunny afternoon in the Caribbean.
into where we were standing, making the moment feel even more surreal Jeffrey pulled himself up to the ladders first step and climbed up the next
on top of the already popped Xanax I had popped before for breakfast four steps to the top of the dock. His chest was heaving rapidly as he sat
earlier that morning. Jeffrey was in such a lighthearted mood that day, down catching his breath. Ghislane was the next one up and then I
making funny cracks at me, and acting like a flirt. When I was finished followed lastly behind them. To me it was an invigorating snorkel around
washing him he actually wanted to wash me too, which was another the shallow reefs within the radius of the dock, but to Jeffrey the half an
totally out of his character suggestion. hour swim in the ocean was enough to overexert his ageing limbs. I took
For the rest of the day, he took me everywhere with him, the office and off my snorkel gear and placed it in the storage bench, grabbing us a few
then to a friends place, even just wanting to hang out with me for a while. towels at the same time. Wrapping a towel around Jeffrey's backside and
I wasn't used to being treated like anything more than a dog on a leash, handing one to Ghislane, I sat down next to them on the dock and we
when he acted like this it just completely spun me around confusing me laughed how fatigued Jeffrey was, poking fun that he really is getting
even more. older. A very touchy subject for the vain at heart but he didn't seem to
We were spending heaps of time together these days, a lot more than mind it, probably knowing we'd never take the joke too far. We sat there
usual. At the ranch we would do things together, alone, and not just the in silence for a moment, an odd silence at that. Jeffrey looked at Ghislane
usual perverted things I was accustomed to doing with him alone. and then Ghislane looked at me, placing me once again in the spotlight.
Horseback riding on his ranch during weekends away by ourselves and They both scooted closer to where I was sitting and I felt something
movie nights snuggling up over a bucket of popcorn instead of having to stirring in the air. The biggest turning point of events in all of my time
massage his feet during the entire film became his way to alter my spent with them.
perception ofmy original notion that I wasn't just his sex slave, I thought Jeffrey sat next to me and put his hand on my back and looked at me
I was finally becoming his friend. with a certain kind of sincerity I hadn't seen in him before. "I want to
When we went quad biking he no longer wanted me to take my own first of all tell you that over the last few years you have shown me the
bike, he preferred me to sit on the back of his, holding onto him tightly kind of devotion and loyalty that I believe is rare to find among people
and he even tried to teach me how to drive a manual stick shift car. He these days, qualities I hold that high in regard." Bewildered by the whole
was definitely trying to show a softer side of himself, different to the scenario I just nodded every time he paused, trying to grasp what his
stone cold slave driver I had to come to respect out of fear over the many intentions were getting at. He continued to praise my nature saying " I
years. Still a hard image to change after all I had been through and seen hope you know my appreciation for your embracing ofmy lifestyle, you
over the years I had been with him. Nonetheless he was still my "boss" so have been achieving a name for yourself among the friends I have
I humored his attempts and matched his caring demeanor, giving him the introduced you to. Everybody says basically the same thing about you,
impression I was intrigued in our new kind of affair. the same thing I believe. You are a delightfully funny girl who has
developed into a mature graceful young woman and I could think of
nobody else I'd rather have a child than with than you."
Chapter 19 And just like that he created a whole new dilemma for me to face. In
utter shock from the completely unexpected proposition and before I
could even think of anything to respond with, Ghislane made the
His attentiveness led into the wanner months that commenced the finishing touches with the business end of the deal starting with the pros
before the cons "You would have around the clock nannies to help you.
beginning of long summer days that I looked forward too. I couldn't help
but enjoy his eagerness to see me more relaxed these days. He wasn't Jeffrey would pay for a mansion of your choice in either Palm Beach or
New York" and as if the drum rolls were beckoning " and ... you would
even bothering me to find alternate sources of girls for his twisted
have a hefty monthly allowance from Jeffrey's bank account" Astonished
satisfaction anymore and although I was still being used for his distorted
at their first offers I nearly took the bait. Then she continued to finish the
sexual enjoyments he further seduced me into believing I meant a lot
terms of our pre-agreement with "But you would have to travel with the
more to him than I ever did.
child where and when Jeffrey wanted you to be, and most importantly
you would have to sign a contract stating that Jeffrey and you are not
113 114
monogamous and that the child would belong in Jeffrey's custody in the glasses off while granting me a big smile. "Come over here and sit down
event of a falling out between the two of you." She kind of threw that last with me" as he ushered me to come sit on his lap. Pulling me onto him he
one in there quickly, as if she could get away with me not hearing that I had a funny look on his face, like he had something really big to tell me
would basically have to relinquish the rights to my own flesh in blood and was letting the anticipation build in the thickness of the silence.
and surrender them to a life of servitude and abuse with these people. My "What???" I laughed at the way he was looking at me now. "First of
maternal alarm bells went off straight away and I already knew my all. .. Happy birthday today." Was only the beginning of his
answer. No way I could I do that to any poor baby, God only knew what announcement and he proceeded to tell me "I know how much you have
these monsters had in store for me let alone a baby, but it was an instant wanted this for so long and you are more than deserving ofit. You are
reaction that saved me." I don't know guy's, I mean I'm really young going away to Thailand to learn authentic Thai Massage and within eight
and never really even thought about having kids yet. Wow, I just don't weeks you '11receive a certificate for being a qualified Thai Massage
know." I slicked my hand through my hair nervously and took in a silent Therapist." Astonished at his attempts to see me get what I wanted, not
breath. I had to go beyond what I was truly feeling and give them the exactly the type of massage I was interested in but it was a start and a
feeling that I'd never let them down. Putting an eager smile on my face first certificate for me to acquire. My eyes lit up and I threw my arms
and sucking up my gut's intuition I told them "You know what, let me get around his neck, planting a big kiss on his lips, which I rarely ever did.
my certificates in massage and have some time to prepare for this and get "Wow, I don't know what to say, this is beyond my wildest
healthy then next year we'll all think about having a baby together." It dreams ... thank you so much'" I did well to let him know I appreciated
was crazy to even hear me say out loud but from the expressions on their his grandeur offer. He went on to give me the details of where I'd be
faces I had fulfilled their wishes. staying, the school's schedules, and how much he loved Thai massage,
Much reason to celebrate that night they were both in a cheery mood apparently it was the next big thing to hit the shores of America. He had
around the dinner table. Except for me who had taken double the dosage planned out an entire itinerary for me. I was to depart at the end of
ofXanax to even cope with the high amounts of anxiety I had been August and he had already enrolled me in a class at "ITM Massage
suffering from since we got back from the dock. I wasn't sipping the School". I would only have a few days to settle in before I would be
champagne that night, I was gulping it and when their moods turned from attending classes five days a week over eight hours a day. He even had an
cheery to raunchy later that evening it wasn't hard for me to comply. assignment for me to do while I was over there. I was to meet up with a
From the full effects of the state I was in I would've agreed to just about girl who was also being put up at the "Princess Hotel" where I was
anything, allowing them to treat themselves to ravishing the tender parts staying. She had an Asian sounding name so I just assumed she was a
ofmybody. local girl hoping for an opportunity of a lifetime, if she only knew what
Over the next few weeks everything went on as it normally would, and she would be getting herself into. If I decided that she met Jeffrey's
not another mention of their proposal. My birthday was only a week away particular quota of approval then she would be sent over to the U .S to
and I was turning nineteen that year. All I wanted was to get my meet with him or one of his esteemed colleagues. Besides the guilt of
certificates before I got any older and get trapped into this life for good. having to decide a stranger's uncertain fate, everything else sounded
When my big day rolled around I was in New York with Jeffrey and more than wonderful. Eight weeks gone from Jeffrey sounded like a
Ghislane. Sitting on my bed listening to MTV's channel blare in the lifetime away and I couldn't be more excited at this chance. It was the
background ofmy room Twas painting my toenails when I was suddenly opportunity ofmy lifetime and I wasn't going to waste a second ofit.
buzzed on the intercom. It was Jeffrey calling himself to ask me to meet Ghislane came in a few minutes later and the look on her face told me
him in his office in ten minutes. Perfect timing to let my nails dry I she already knew. Tgot up from Jeffrey's lap and gave her a big hug and
thought to myself. Already contemplating his desire to come downstairs I told her, 'This is so nice of you guys, Thank you so much!" She didn't
knew it had something to do with my birthday present but I was more share my enthusiasm of excitement. In a dull tone she responded, "I
expecting the usual shopping money or piece of jewelry, definitely not didn't have a thing to do with it, it was all Jeffrey's idea but good-luck
what he had in store for me. anyways." She gave me her best impression of being human for a brief
I knocked on the slightly ajar door to Jeffrey's office and heard him second and hugged me back. It was just her way and I had come to accept
beckon me inside. "Hello, what cha up too?" I asked in a cutesy tone of it. Depending on the level of slander her insults provoked was just her
voice. Walking over to his desk he looked up at me taking his reading way of telling you she cares without really ever showing it. Probably
115 116
doesn't make sense to most sane people but after all of the time spent time so I just put my dog on the lead and took her for a walk to calm
with them, I had gotten to understand a few of their quirky ways. Even if down the situation and give me some time to be alone. Mary Jane was the
I didn't agree with them, they knew I would for their sake of opinion. only one I hated leaving behind. When we got back from the long walk
What did it matter anyways I thought, I had been degraded in every other she barricaded my suitcase while I was packing the horrendous amount of
physical way what's the difference from taking their mental abuse too. clothing that I always did. I was promising her I wouldn't be long and
Not the exact choice of employers I would've chosen over again if given told her how much I loved her giving her a big hug. I choked back on the
the opportunity but here I was and doing my very best to excel at their tears that were swelling up in my eyes, it was like she already knew the
demands. night before I flew out to New York that this would be my final trip.
I was sent home for a little over a week to pack for the long trip and There was a commercial flight booked for me in the morning and I
make the rounds visiting my family before I left overseas on my first trip needed the rest that night to fully recover from my binge of celebration
all by myself. It was great to see my family after such a long time away. drinking. T.J crept into bed later that night and tried to redeem his
My older brother and his wife even came down to visit for the well behavior with sweet nothings and dry humping my backside. It did
wishing ofmy departure. Everyone in my family seemed stoked at the nothing for me sexually. I didn't feel like that for him any longer and the
prospects my long journey had led me down. Here I was jet setting sooner he realized that, the better he'd be off. I told him I wasn't up for it
around the world in my teens and getting paid to study the course ofmy and he picked up a pillow and slammed the door behind him. It didn't
dreams at a cost that I only knew I would have to pay. It was a wonderful matter I told myself, the next day I was off and wouldn't have to deal
get together with all of them around, a great way to remember them. If I'd with him or anyone.
only known it would be the last time I would see any of them I would've T.J caught a cab with me to MIA, the airport in Miami. He walked with
emphasized to my brothers how much I really loved them both and how me to the furthest point he was allowed to go by the security gates and as
much I would miss them in the decade to come! But I didn't know what we stood in line together it was almost heartbreaking seeing him cry. I
my future held for me, I had nothing planned out I was just hoping for the told him I'd try to call him everyday, attempting to give him optimistic
right opportunities. ways to look at this time away from each other. In the end he had me
I also had a few good friends to catch up with before I went. Every crying and I had to give into my remaining feelings I had for him. One
night was another party and by the end of the week I had drunken enough last kiss under the x-ray bridge and he vanished out ofmy sight as I
to drown an Irishman on St. Patty's Day. I was given the lists to all ofmy furthered down the terminals long hall.
friends email address and told to keep in touch. Yeah right I thought, I
was going to be too busy having too much fun to be thinking about sitting
on a computer emailing people, but I told them I would anyways. Save Chapter 20
myself the point of having to explain that in many different ways to a
group of already tipsy slurring teenagers. Out of everyone who was really
happy for me, T.J wasn't. He hated the idea ofme leaving him to have a
It was only a short flight to New York and I just couldn't wait until next
non-stop party in Thailand without him. He was just starting to seem like
week when I'd be jetting ofto an exotic destination all by my lonesome
he was coming good and I didn't like having to leave him at such a
self. It was all I could think about talk about and dream about, finally my
vulnerable state but in my young years I had already realized I needed to
break. Ghislane did what she did best that week and prepped me for
do some things for myself and this was one of them. There was still a everything I could imagine under the sun. Do's and Don'ts, emergency
huge amount of broken trust between us, trust that could probably never
numbers and western union locations were among some things on the list
be rendered again so I thought I was being decent enough letting him stay
she gave me. Like l said, she showed her caring side in other ways.
at my apartment while I was gone, but he was not to drive my truck, at
There was also the name of the girl I was supposed to be meeting, the
all. I paid too much money on insurance for that thing and knowing his
room she was in and what dates she would be staying there.
driving record I didn't want the risk of something happening while I was When I got out ofGhislane's office I was instructed to meet Jeffrey in
gone for so long. He didn't agree with me at all, throwing a grown up
his office. She had to stay back for some paper work that she had to catch
tantrum all over my apartment. Hitting the walls and doors, shouting the
up on pronto. Making my way up the red and gold trimmed carpeted
entire complex down, there was nothing I could say or do at this point in
117 118
CONFIDENTIAi. GIUFFRE004250 CONFIDENTIAi. GIUFFRE00425 I
staircase I prepared myself for some major sucking up before I left, he Throw out your confetti because here I come Chang-Mai!! My
would be expecting it for his recent generosity, or so I had thought. celebrations started the second I landed, it didn't take me long to make
Opening those familiar heavy doors the first thing I saw was an myself aquatinted with a few fellow travelers and find the hot spots of the
unfamiliar face standing over Jeffrey's shoulder. hustling city. It was like nowhere I had ever been before. The streets were
She was a tall girl with blonde hair twisted up in a professional looking lined with stalls offering an assortment of souvenirs, clothing, and knick-
knot. Her big smile was flashing at him with hints of her cheekiness to knacks. Everyone lived so freely and was in such great spirits. The parties
come and she was dressed to kill with a short tight grey skirt and a raged on until the wee hours of the morning and people became best
matching suit jacket over her white buttoned down blouse, revealing her friends over night. From the second I got there I knew Thailand was
voluptuous ample cleavage. She looked like the old college professor's going to be a lot of fun and I was right! Popping bottles of champagne,
wet dream. When she introduced herself to me, a thick Czech accent dancing all night to the beat of every club's rhythm's along my way and
presented itself. Her name was Nadia Marcinkova and Jeffrey looked just carrying on like it was my birthday ... every night was a repetition I could
about as smitten as a victim of a love struck arrow from no one but the definitely get used too. During the day I was a real good girl, the teachers
cupids themselves. Jeffrey further introduced her as his new assistant and pet even. Showing the credibility ofmy experience in massage from over
masseuse while I would be away, barely taking his eyes off her for one the last few years and already ahead of the class the teacher was using me
second. It was a bit of a blow to take, being so easily replaced but also a to help instruct the others with demonstrations. Mostly in a class full of
part of me already knew this was expected off someone like him. Good males it wasn't a surprise that I made friends with quite a few of them,
for him I thought to myself, why should l have bitterness over someone l some of them with ulterior motives, but for the most part the sleazebags
never had intimate feelings for and knew had never really cared for me in were none of my concern, I had already dealt with a lifetime of them to
the first place. Kissing her on the cheeks and telling her my name, l was be able to spot one out and steer clear of his approaches. Out of the entire
doing my best to grin and bear it. We hugged for a brief show of class I had made friends with only one girl from Wisconsin. She was a
uniformity but it was just that, a show for Jeffrey to see. When he was plain looking girl with big brown puppy dog eyes and a long drawn out
away for the moment or she wasn't busy hanging off his every word, the accent. Her first time leaving the States or Wisconsin itself for that matter
way we all started out, she would snub me off to only head off in another so it was easy to acknowledge that she was a little taken aback by all of
direction. A real bitch if anyone was to ask me but no one would anyways the bustling city life so becoming her friend felt like I was doing a good
it wasn't my job to like her. deed showing her around the hot spots of the Chaing-Mai nightlife.
Over the next course of days it was my task to show her some of my Eventually I even ended up inviting her to stay with me at my hotel. She
techniques in massaging Jeffrey and the erotic side of finishing it off. was running out of money to party every night then pay for school on top
Nadia despised me even more when Jeffrey told her to follow my lead of her accommodation, it was all becoming too much out of her small
during the massage as she tried to take over and do her own thing a few budget. So I thought about it and offered her a bed in my room, I had two
times. To me it was quite funny her competitive side, I had nothing more of them anyways. Plus she was a really nice girl and if I could help make
to prove so watching her put on an act of seduction and scream out her her first time out of the country an unforgettable experience then I was
every body function during a faked orgasm was nothing but entertaining also gaining something from it as well.
in my eyes. After a few sessions together it was my time to be off on The first month in quickly passed me by. Having such an incredible
another adventure far, far away from here or from the chains that I wore time on my own and putting my heart into learning Thai Massage it
for way too long. Jeffrey had someone else to fit the chains that kept me seemed to just fly past. Routinely I had to call in and check in with
so close to him. Even though she wasn't the nicest of girls I still couldn't Jeffrey and Ghislane letting them know my whereabouts and progression
help but feel sorry for her. No girl should belong to someone out of in class. Counting down the time left until my course finished Jeffrey was
servitude, but unfortunately it is the way our civilization has been for anticipating my departure back to New York. "I can't wait to get my first
many centuries before us and I don't see changing any time soon or as Thai massage from you. l 've got you booked to come straight back to
long as perverts like Jeffrey are allowed to walk around freely and New York for my first one as soon as your course finishes next month."
procure our daughters off the streets all because he's got a lot of money to His eagerness put a twisted familiar knot in my stomach. Reminding me
pay many, many, many people off. of the dream I have to awake from soon and the reality of the certain
homecoming I would be arriving to. " It's such a great course, thank you
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so much for sending me here to learn this. You are going to love my new and shove to try to find a spot to watch from. The friends that we were
area of expertise! I am having such an amazing time over here!!" I had to hanging out with were meeting up with another group of guys that were
let him know how much I appreciated what he had done for me and he training for the kickboxing tournaments that we were watching.
loved the head swell that it would make him feel as well. Hating the Then it happened it was the first moment I laid eyes on the man that
thought of going back to him, I wasn't going to let that put a damper on would love me for the rest ofmy life. I wasn't expecting the most
my spirits while I was still out there. It was my time to party harder than amazing time ofmy life to happen right there and then but it did and I
ever before. Every night was a new adventure for me. Chang-Mai was a would never be the same again. Destiny fell right smack into my lap and
maze of places to get lost in and the vibrant city was my playground. The there was no stopping it! It wasn't just his smoldering appeal that was
way I saw it this was my last chance to get out and break free, letting obvious at first sight it was the entire package of mannerism and chivalry
loose my inner girl it felt so good to take the lead of my own life. that made him stand out of the crowd. Stepping right out of the pages of
the fairytales I used to read, he was nothing like I had ever come to know
before.
Chapter 21 Watching him from a close distance he was playfully shadow boxing
one of the guys from my massage class and it was at that moment that
this handsome stranger first caught me staring at him. From top to toe this
athletically built man was intriguing to watch, I couldn't take my eyes off
It was an average evening getting ready in front of the bathroom mirror him like I was magnetically drawn to his power of attraction. He further
on just an average Sunday, though unbeknownst to us girls as we sat interested me when he wasn't acting like the majority of harping dogs
there chatting away carelessly, this night was already written in the stars that would jump at the eyes I was giving him now. Instead he coyly
for me. It was a very long time ago now when I was still a young child played hard to get, making me work for any conversation with him. The
that I sat looking up to those same stars from my bedroom window with fight started and the men were going bezerk, screaming at the fighters in
my hands pressed tightly together as I cried for God to hear my prayers. the ring offering either fighter their support or discrimination depending
All I asked him for was death. My precious life was already such a on whom they were batting for. It was like watching a primitive scene out
hopeless battle that I felt too small to fight alone for. Begging him to of the days when the cavemen ruled the earth but it was as equally
deliver me from this cruel world I would pray for all ofmy pain would to alluring to watch unfold, the sweat, the blood and the absolute brut
away for good. My only clause in my prayers was the possibility that fascination ofit all.
there was somebody in this wide world that I was meant to love, After the fight and all of the men revved up from the fight, I suggested
something much bigger than I could have even imagined yet. This that we all head to the pizza joint in front of the Princess Hotel where I
invocation of mine was forgotten about long ago now, until tonight. was staying for a late night snack. I made it my goal to make myself
I wish I had known that night I sat crying beneath the stars that it known to this appealing stranger. In the tuk-tnk on the way there I made
would all be different one day and that I hadn't sold myself short to the sure I sat next to Robbie. Scooting my knees closer and closer to him on
accustomed lifestyle I was brought up to believing was acceptable. It was the short ride he continued his chase by moving further away from me, a
this night my very soul was about to cosmically collide with the man I game of cat and mouse that I loved. When he answered back the array of
was always meant for, the man my heart already belonged to and would my questions he had the cutest Aussie accent that drove me absolutely
know from the instant we met. This night would be the first day to the wild.
beginning ofmy new life to come. Gradually we got to know each other better over a pie of peperoni
I blushed my cheeks and put on my mascara before me and my pizza and two can's of coke. Too me he might as well have been the only
girlfriend headed out to hit the town. We were dressed to kill and looking other person in the restaurant, he knew he had my undivided attention and
for something to do when we ran into a few of our class mates at one of I think he liked it. There was no one like him that I had ever met before
our favorite drinking spots. They were meeting up for some drinks before and I knew there was no other who could make me feel the way that I felt
a Muay-Thai kickboxing tournament. It sounded like fun when they at the first sight of him. Being charming and suave was all an accidental
invited us along to watch it with them. The massive crowd lined the street front. It was easy to read him. Immediately it wasn't hard to see his sweet
where the fight was being held and once I got inside the arena it was push side, holding the door and pulling out my chair at the restaurant, I was
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already smitten. After pizza he walked me across the street to my hotel gave me his warmth and compassion as he wrapped his strong arms
where we made plans to meet up again. There was no kiss goodnight or around me, making me feel so meager and small but so safe at the same
anything like that. No, he was too polite for that, he wanted to prove time. Encouraging me to see the worthiness of myself and leave that life
himself different and different he was. Walking through the hotel's behind, he adorned me with a kind love that I wasn't accustomed too.
revolving doors I watched as he walked away and when he was finally He took me in and made me feel so at home. It was like I had known
out of sight, I sung my way up to my room. Floating on cloud nine I was him my whole life. I couldn't bear to be without him another second
free falling into a deep pit of love. while I was away on this dream holiday. When he wasn't training for
The next day I attended my class as usual but not able to concentrate Muay-Thai tournaments and I wasn't in school, nobody would ever see
like I normally did, too excited about when l 'd be seeing Robbie that us. Too enveloped in each other in my hotel room to care about anything
night again. As I walked out of class that afternoon even the teacher else. Which is why I asked him to come stay at my hotel with me, seeing
noticed a difference in my performance and asked me ifl was feeling he was never at his own anyways. My girlfriend was soon departing back
well, "On top of the world actually" I smiled back at the old instructor to Wisconsin, making my room more than available for him. Enchanted
and it wasn't far from the exact truth either. I hadn't ever felt the by his words and tender touch, the way he made love to me was again
churning of butterflies in my stomach and the constant thoughts of like nothing I had experienced before. Even down to after sex as I had
anyone else like this before. My girlfriend and I got a tuk-tuk back been routinely instructed by Jeffrey to get up for a warm washcloth to
together as we usually did after school and I couldn't shut up about the clean his genitals afterwards, he refused it, telling me I was no longer a
night before. She was laughing at my girlishness telling me that anyone slave and that he didn't want me acting like one. He'd just rather lay
who just met me would think I had never been let out before, but little did down together afterwards and repeat our sweet nothings with many
she know that I had more than my fair share in experience with men and adjoining kisses.
never had I ever come across anyone that could make me feel this way, On our third night together with nothing but the bed sheets between us,
and what spun me out even more was that it was such an instant we had spent all night looking into each other's eyes sharing such an
attraction. Never considering myself a person who believed in the undeniable passion for one another. In the deepest caverns of my heart I
existence of"Love at first sight", but a true romantic deep at heart, I knew this man would give me what I had never experienced
couldn't help but believe in it now. He is my walking proof of it! before ... True love. We were still laying in each others arms when the
Waiting for me in the hotel lobby was the very person I couldn't stop orange and pink sunrise began to rise slowly through the peak's ofmy
entertaining the thought of all day long, there he was looking ever so fine rooms windows, enticing me to come feel the freshness of the morning's
standing in front ofme now. The whole entire world faded away and all chill. Only the bed sheets were still wrapped around my body as I went
that was left for the moment was this complete stranger I had only met the balcony. It was overlooking the city in a valley surrounded by
last night but somehow captivated the very essence ofmy very heart. mountainous tops. My thoughts began to rampage through my head and I
There was no need for me to try and act cool now. He already knew I was knew this could only be a dream for me. It was getting serious now, too
snagged hook, line and sinker. Smiling all the way up the many stories in serious for the life that I led back home. As if he sensed my anxiety
the elevator up to my room he took notice of the posh decor of the hotel. Robbie walked up behind me and wrapped his strong arms around my
"You should see where I'm staying, this is a royal palace compared to it" waistline, gently kissing my neckline and pausing with his ever so
His first impression ofme he automatically thought I was going to be a thoughtful stares and gave me the exact opening that I needed to expel
spoiled high-maintenance girl that had money coming in from a parents my thoughts. "Back home, as you already know, I am going back to
hefty trust fund. Casually he got to find out through many deep and someone else, it's my job, and as much as I really like you, this guy that I
meaningful conversations that my life's grim story wasn't that pretty at kind of see is going to expect me to be putting him first, I am so sorry to
all. For some reason beyond my knowledge I had the need to tell this say all of this after such a wonderful few days we have spent together, but
stranger almost everything. you need to know this thing happening between us can't get anymore
Wanting to be judged and looked down upon for everything about my serious than what we have for now. I am so sorry" I looked down to the
life that I knew was wrong and being the first time I had spoken about my floor with nothing else I could say to alter his perception of me now that I
years with Jeffrey to anyone honestly like that ever before, I had felt like had told him the truth and it never dawned on me that thought he
I had deserved punishment. He offered me no judgment, instead only wouldn't be out the door before I could even finish my sentence but he
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continued to surprise me with his efforts to make me believe we were out. I still had to believe in something better than what I was accustomed
more than just friends with a summer cmsh. "You see ... your problem is too and here he was right smack dab in front of me.
that you don't see what I am looking at right here in front ofme, a Giggling at all of the lace and frills they were trying to dress me up in,
beautiful girl who is completely lost in a game that she has no control looking more like an antique porcelain doll than anything else I closed
over. Get out ofit now, take my hand and follow me back to my home in my eyes and pictured the day that I thought would never come, starting to
Australia." I heard what he had said but I found it hard to comprehend imagine the kind of dress I would like to wear I envisioned a simple
what he was actually talking about. "What?" I asked him with a look of sleekness, a complimentary figure hugging gown with a small train but
confusion on my face. "Your nobody's property, you can do this. Marry long enough to distinct it as an actual wedding dress. After we settled on
me." His statements got more and more profound as he went on. what we were going to wear for the big day, we would next have to
Repeating the question he got on one knee and proposed again "Jenna, I decide where we would hold the ceremony. Not before celebrating the
am in love with you and want to spend the rest ofmy life making you entire week beforehand though. We started our honeymoon early
happy. Please don't go back to him. I know that I am the only one for you celebrating every night spending our time between my hotel room and
and I will always treat you right. He paused for another second and sending our heads spinning on the dance floor at many different clubs.
repeated his question "Jenna, will you please marry me?" My hands fell Only with each other in sight, the dance floor was ours, we were out to
into my face after that and without even letting myself think through the give each other something to remember each night by. I whispered all of
answer, I let my heart do all of the talking. Looking back up at him I said the things I couldn't wait to do him once we got back to the hotel room
"Yes!" I almost shouted the answer at him, as if saying it louder would and watching him heat up on the dance floor I was never able to get
give the word more meaning. Wanting to believe him and everything that enough of him driving me crazy. Like a thirst I was unable to quench, his
he was saying felt like a vacation from all of the suffering and loneliness lips were like a fountain of deep springs that I could never reach the
that I had endured over a lifetime of abuse and degradation but knowing bottom of.
what you want and getting it are two different things that rarely went Seven days, exactly a week after his proposal I sat on my bed in distress,
hand in hand ... or so I thought. All I knew from the brief period I had contemplating what I would say to the man who I was about to call.
known this stranger was that he was offering me a life and love down an There was no nice way to go about it. I couldn't last forever with him and
unfamiliar path and it was a gamble to believe a complete stranger but this was my one chance to get out of it for good. I was leaving him, never
somehow I knew he was right. My heart was beating so loud I thought it to return to him ever again. I just had to go ahead and do it. Part of me
was going to jump right out of my chest. With the earnestly in my reply was hoping he'd be at least a little happy for me and the sudden change in
he picked me up in his strong arms and took me back to the bed and my life's direction but the other part ofme knew I was already asking too
reiterated his words in a more physical sense this time. Never had I felt muchofhim.
loved like this before, so swept off my feet and unable to even think, eat, Calling his office in New York I was transferred to Jeffrey's personal
or do anything for that matter which would involve leaving the hotel office. He picked up the phone on the third ring, pausing before I could
room without him. get any of the words to come out ofmy mouth but I mustered up my
Everyday after school would be my Robbie waiting to take me back to courage eventually and gave him my prepared spiel. Beginning with how
the hotel room for another night's passionate rendezvous, but a few much I had appreciated everything he has done for me up until this point.
nights after his proposal, he had another surprise in store. He didn't just I hoped he would be understanding but he just wanted me to hurry up and
want to get married someday. He wanted to get married now, this week get to the point. Trying to contagiously pass on my excitement through
even. I walked into the fabric store and was attended too by several the phone lines, I finally screamed out 'Tm getting married! Can you
seamstresses who were already be expecting my arrival. I was there to believe it?" No reply was given only a silence on the other end. Trying to
design and have fun designing my own dream wedding dress. While I make some conversation ridding the uncomfortable silence, I went on to
was busy picking out fabrics and having measurements taken I would tell him about Robbie and how 1 had fallen madly in love with him over
look away for a moment only to catch his tender eyes staring in my the last amazing few days we'd spent together. The absence of sound
direction. Such adoration behind his looks ... could it be real? I would made my thoughts begin to mn wild and to get some response I had to
often ponder it to myself just hoping for the gamble I was taking to work ask him what he thought about everything I was telling him. Finally a few
seconds later his reaction to the news sunk in and his only and final reply
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until many years to come was " Have a good life!" With that statement he Falling asleep was easy to do in his arms that night. I laid my head on
slammed down phone receiver. Leaving only an echo of the dial tone to top of his chest listening to the drum of his beating heart. I had never felt
answer back too. I was to paralyzed from the shocking response. "What like I was more at home than ever before in my life. He pulled me gently
have I just done?" was the first thing that entered my thoughts. in closer to him, letting me know that he was there for me even when the
Overwhelmed with guilt I felt like I was falling down a deep and dark lights went out and the thoughts would usually creep in. Amazing how he
hole and then the tears began to flood in. Here I was standing at the dawn knew what I needed without even asking for it. Wishing for something
of a new happy life for myself and I couldn't see past how bad I had let like this my whole life I thought I was being such a fool in so many ways,
Jeffrey down not yet seeing the hold he had on me. but I was so wrong. The way his pretty eyes looked at me with such an
Like my knight on a white horse, in came my hero to soothe my understanding and compassionate sincerity made me want to trust his
somberness. He rushed over to the bed where I was beating myself up words and believe the love that he was offering me was indeed real.
mentally and wiped the falling tears from my cheeks. "I take it that it The next morning, Robbie was up and out of bed early to pick up our
didn't go so well ... huh?" Sniffling through my sobs I managed to tell tailored wedding suits and dresses for our big day at Doi Cept Temple.
him that "It doesn't matter anymore all I care about is you and leaving all His best friend from high school days that was travelling with him from
of that life behind me!" I wrapped my arms around him and he asked me Australia met him in the hotel lobby at seven o'clock. He was going to be
in a half joking voice "Then why are you crying?" He got me almost joining us for the wedding as Robbie's best man. He still hadn't been able
laughing now too "I guess it's just so scary taking such a huge plunge to find black shoes to go with the suit, so after he dropped off my dress
away from what l 'm used too and taking such a big move to another back to me he was off again to try and find himself a pair of decent
country. It's just all so different and I'm just trying to comprehend looking ones. Overjoyed with excitement I was thrilled from the second I
everything that is happening in such a short time." Always out to lift my kissed Robbie good-bye for the last time before we were officially
spirits his next comments made me gush in laughter "You think that was married. Looking in the same mirror only a week ago I was now a
a hard phone call wait until I call my Sicilian mother! Watch this, I know different person, I felt like I was plunging into a bottomless abyss. Here I
exactly what she'll say. First it'll be a saga about how I'm killing her with go, I thought to myself as I plunged out the door letting the butterflies in
my selfish actions then it'll be about how she's going to kill herself for my stomach carry me all the way to my nearly husband.
doing such a terrible job raising normal children. Don't worry though, I had to go to the beauticians that morning for my pre- wedding makeup
she'll love every second of it. Wogs thrive off of the drama in their lives and dressing. The ladies who were doing my hair and face at the salon did
and off everybody else's for that matter!!" He was pretty much on the dot a great job making me feel so beautiful for my special occasion that every
when he told me how she'd react to the news. In the end after relentlessly girl dreams about their whole entire life. Requesting simplicity at best,
trying to change his mind, she sighed, "lfit was going to be anybody to not wanting to go overboard with all of the wedding apparel they tied my
do something as crazy as this, Robbie, it would be you!" It wasn't a long hair up into a knot wrapping around it a veil of flowers made up of
blessing as such but at least she wasn't threatening suicide any longer. baby's breath and small yellow and purple budding flowers. I couldn't
Calling the closest of our families the night before our wedding to share have dreamt it up better myself and when I met my husband to be at the
with them our announcement wasn't celebrated by any members of either bottom of the mountain he stood before me speechless "You look so ...
sides but that didn't discern us one bit. My parents took it well, beautiful!" were his first words that his mouth formed almost whispering
considering their only daughter was marrying a foreign man that they them. He took my hand and we walked into the sky lift together. Behind
didn't know from the next guy on the street and too top it off I was us followed an interpreter that Robbie hired to translate the Buddhist
moving to Australia, pemrnnently. When I asked my Dad many years Monks ceremony speech for us English only speakers and then his best
later why they hadn't put up a fight, he just simply replied that nobody friend, who only moments before gave him the best mans speech about
expected it too last very long. Fair enough, I thought. I don't think being the last chance to walk away from this and not get married to a girl
anyone did at first. .. even us at our toughest times. We were a rare he hardly knew, but my Robbie wouldn't hear a word of it. He already
attribute these days in the numb era we have all been accustomed to made up his mind the instant he proposed and I said yes, "I was born to
living in, turning nothing into something, which I had also come to be with this girl," he told his best mate. "Alright then lets go do this
realize, was the most precious gift in life ... Love. then!" Once he knew Robbie was sure in his decision he was more than
ecstatic for him. We were slowly lifted up the tremendous mountainside,
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surrounded by the floral green carpet of mossy grass that covered the whole life around and how I would dedicate my entire being to loving
earthly skyscraper and falling fog, it was like being carried to heaven or him and only him until I blew my final breath.
the closest thing to it! Taking my eyes off the scenery and catching him I meant every word that I said to him, this was it for me, wanting
adoringly staring at me again, 1 welled up with unstoppable tears. "I am nothing more out of life than to be with someone like him to raise a few
so lucky, is this really happening?" He squeezed my hands and replied kids together and grow old on the front porch letting the days fade us by.
back "You're the only one for me .. .I love you!" relieving the anxiety I know it probably sounds boring to most and it would've to me as well
written all over my tear stained face. many years ago but after the life I had led, I had enough experience in the
real world for my liking and now all I want to do is to enjoy the
Chapter 22 remaining days ofmy life for what it is ... a simple and satisfying
existence. Our day was so special but not only to us, even too the Monk
that married us. Upon our descent down the lifts he asked ifhe could take
Getting out of the carriage we were greeted by good fortune from the
Gods above. A sun shower cascaded over us at we advanced into the a photo with the bride and groom in front of their symbolic liberty bell
signifying the union between east and west. It represented a lot for us too,
ancient holy temple. My tears of joy dried and my happiness was glowing
it was the commencement of a new life together and just the beginning of
for all to see. The many visitors to the temple stopped and took photos of
battling each other's past demons together.
the passing bride and groom, no other foreigners had ever been married
Kissing the bridal party goodbye, who were just the local girls I had
there and certainly anyone wearing traditional western wedding attire,
met on some of our many nights out of having fun. I threw my arranged
such a sight had never been seen behind these religious walls, we became
bouquet of Thailand's white wedding floras mixed with colorful orchids
a permanent icon at the temple. The ceremony was done in the Buddhist
customs according to their ancestral accordance, and translated for us in to the screaming Thai women behind me and we were given one last
tradition to take with us, the release of caged doves. It was such an
our own lanb'llage. Both Robbie and I were anointed with a blessing from
incredible gesture, especially for me. Symbolizing their freedom as well
the monk with a splash of water and seven sacramental bracelets, each
as mine I opened the cage's door to let them free to decide our own fates.
one representing another meaning to the longevity of our union together.
As the wings on the birds began to spread open and they took their final
We signed our names in the Buddhist wedding registry of Doi Cept
decent into the blue skies granting themselves freedom I knew mine had
Temple and officially became Mr. & Mrs. Roberts at least officially in
finally come too. The relevance of watching them fly away and how I had
our hearts knowing the laws of Australia only recognize certified
weddings, meaning when we got back to his homeland we'd have to perceived my own day of marriage related to the identical feeling of
fleeing an entrapment of my own kind. I was liberated from the bounds of
make a run for the courthouse. This was our real wedding though, perfect
down to every detail. Walking up to the highest point of the temple to the slavery I had come to know over the many years I had spent with my fair
share of greedy perverted old men only to have serendipity mend my
balcony hanging over the edge of a cliff side over looking the city of
Chang-Mai, we knew we had found the perfect spot to recite our vows of scars with the powerful healing of what true love has to endeavor on.
As customary in the romance novels I had read as a young girl he
love to each other. Providing everything for me and more than I could
picked me up in the hallway before our hotel suite and carried me over
ever ask for, his vows were to love me unconditionally until death do we
part, shelter me from all the cruelty in the world that I was so accustomed the threshold, poufy dress and all. My arms were tightly squeezed around
his neck never once taking my eyes off of him until he revealed yet
too and to be like the bear, because the bear never forgets. Tears once
again streamed down from my eyes as he made this moment another sweet surprise. Besides the cleaners tiding up my room while we
were gone they were also given instructions by none other than the groom
unforgettable. Wiping the mascara fading underneath my eyelids whilst
himself to pick the petals off the stems ofred roses to place on our bed in
giggling at my embarrassment I took his hands back into mine again and
the shape of a giant heart. The rose petals led the way to where we
gave him the vows that were the sacred prepared words from my heart.
consummated our love physically and it was undeniably the first time in
My ears were thundering the sound of a million horses hoofs descending
my life I had really ever been made love too. Hours had passed by before
downhill and my heart was beating so fast my words barely trembled out
we thought about anything else besides one another's words of arousal,
ofmy mouth when I began to tell him how much he had changed my
tantalizing touches, and lingering kisses. We ate a quiet dinner at a local
restaurant and went straight back to the arms of each other again, so
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profoundly in love with one another it was the ideal display of what the intentions but still recovering from old wounds. It was only natural and
"honeymoon period" should have to show for. It was crazy, young and important that we fought just as much as we made passionate love
energetic, just what it should be between two blossoming lovers. together. Countlessly proving to one another the true intentions of each
The following morning we left the Princess Hotel, no longer under any other loves but sometimes in not so seemingly actions.
of Jeffrey's financial privileges or control so to speak, continuing our Finally arriving at the hotel it was like a scene out of a horror flick. We
love spree in another dwelling of our own accord. Three days later when were showed up to the room that looked like someone had been brutally
we finally showed our face for the first time since checking in downstairs killed in. The bed sheets were torn apart and the bed was stained with
in the new hotel lobby, besides to request fresh sheets and towels, the blood from some poor helpless victim. Nearly vomiting at the pure sight
entire staff of the hotel had a good laugh at our expenditure, from their of the room and the stench that accompanied it, I was now tearing at the
reaction it must've been nice to see a couple so affectionately fond of thought of even staying here for a single moment longer. "No way!" I
each other. told my new husband and from the tone in my voice he knew I was
Now we wanted to have another type of fun, Robbie had visited a serious. Not that I was not denying the fact I have never been an outback
tourist agent by himself before we got hitched to book a honeymoon type of girl. I was fine with that impression, I am no snob but give me the
itinerary for us to explore Thailand and beyond together, another surprise simple luxuries of a clean bed and a shower then I'll make myself at
he had in store for me. We left early in the morning and joined the home, but this was just the epitome of filth and even possibly an act of a
crowded bus for our journey beyond the border of Thailand to a village in horrendous event but who knows, the lady who showed us to the room
the war torn nation of Laos. When we got through the extremely armored seemed fine with it passing it off as a hooker on her period. In some ways
visa office eight hours off the beaten path, we then had to cross a flooding that was even worse ... "Yuk ... Okay Robbie it's time to go ... now!" we
river from a recent heavy downpour of rain in a slim banana boat that were heading back down hill back to the passport center declaring our
looked like it could barely handle our weight let alone the excess of my passage back into Thailand. Considering us a risk due to the short time
luggage that Robbie was so kind to trek around the world for me. we spent crossing the border and back, the officials held us at gunpoint
Unbelievably we did make it to the other side only to find that my while others rummaged through our luggage for drugs or whatnot.
honeymoon in the tropics wasn't exactly how it had been explained to Finding nothing of course they released us and stamped our passports,
me. Naked children ran through the dirty streets, with one boy that making us good for another three months ifwe wanted. We were thankful
decided to release his bladder on the pathway where we were walking as for escaping with our lives alone, although we had nothing to hide but
we passed by him on the way to our hotel. My doubts of his choice in still an endearing experience nonetheless in the first days of our
destinations became apparent after that sight. Robbie was getting hungry honeymoon of all days.
after we hadn't eaten the entire duration of the trip and being such a
rugged man he could digest just about anything. Deciding to stop on the Chapter 23
side of the road he ordered some kind of seafood dish ... daring I thought,
settling for some toast and jam, something safer I thought. Then I saw the
Arriving in Koh Samui for finally a bit of relaxation in the tropics, it
lady behind the counter dip some plates in a dirty bucket full of dirty
was my idea of how a holiday should be, sunny warm, and clean ... well,
water and then rinse in another bucket of water that didn't look as bad as
clean enough. We lived it up like kings for the next six weeks. Making it
the previous mud drenched one and then further proceeded to put my
an ideal way for two strangers to properly get acquainted. Dancing into
toast and his food on top of them serving it to us all in a clear view. I just the wee hours of the night and making love in the blistering heat of the
couldn't bring myself to even fathom it "I can't eat that!" I mouthed in a
sunny days we discovered everything on that island ... mostly being each
hushed voice trying to quietly make my point clear but was made public
other. We made friends of all sorts, mostly travelers, but everyone the
with his loud mouth outburst of "Why not? Looks fine to me. You have
same in being taken aback by our fairytale romance. With our captivated
to try and eat something, you haven't eaten all day!" I know it was just
eyes never straying too far from one another anyone could easily see the
his caring side that was trying to force me and to top it off he is Sicilian
strong chemistry between us.
and they're all about eating so it was our first debate and now we were
Trying to find the woman in me wasn't difficult, as I took to the bounds
officially married with many more marital conflicts to subsequently
of marriage with such ease, no longer a girl I loved the idea of being a
follow. Two head strong and stubborn people both with the right
131 132
wife and belonging to a husband like Robbie. Marriage was bliss for the and got on the phone immediately which sounded like a phone call to his
duration of our honeymoon until we had to ride coach on our way to superiors but I couldn't tell since it was in another language. A brief
Bangkok Airport to fly out to Australia. Chatting away with always so conversation but long enough to get me thinking, he then called over two
much to say to each other we watched a movie and finally got guards who took me by the anns and brought me into an empty room but
comfortable leaning up against each other as pillows. We both fell asleep for a desk and three chairs to be interrogated. No one would tell me what
on the long ride and when we woke up to the sound of the buses brakes was going on they all just scattered around in frenzy, ignoring all ofmy
coming to a halt we initially realized my purse and Robbie's wallet with hysterical inquisitions. Leaving me by myself and alone with my thoughts
all of our money and cards in it was missing. Stranded in the city of I couldn't help but panic even worse now.
Bangkok was frightening enough as it was but too make matters worse a This was a total bombshell of confusion on my part, what had I done
lady looking in her mid-seventies, scrawny and hunched over from an wrong? Minute's later a large-framed women in a green uniform entered
obvious lack of nutrition lifted up her skirt to a passer-byer with a she- the room with the guards from before and sat down across from me with
male hanging off his arm and began smacking her vagina blaring out a stern look in her eyes. She placed my documents on the desk in between
"Look! No cock ... Pussy, pussy! Only five baht" repeating herself many us. Not saying a word to me she was waiting for me to give her an
times over the man just walked on past as she sat back down on the curb explanation for something. "Can you please tell me what this is about,
waiting for the next alluring customer. Robbie and I shook our heads in have I done something wrong?" I asked her politely, trying to restraint
disgust and disbelief, things could really be that bad for someone, I would any animosity towards her. Her reply sounded as grim as she looked.
know best as it wasn't far off the life Jeffrey had been training me up for. "You have been in Thailand for three months and now you have only a
Completely broke at two o'clock in the morning and with no one to call one way ticket booked to Australia with no visa. What exactly are your
for help, I panicked right away. Robbie rubbed my back and his tired eyes plans once you get there, Ms. Roberts'>" To myself I wondered what
trying to make the situation better. Luckily we had made friends with business it was to her, don't people travel with one-way tickets all the
some really nice people from the resort on the island who gave us about time? Knowing I was in no position to be able to say anything like that or
two thousand baht when they saw how devastated Robbie and I were. even at all I just gave in nicely and told her my intentions to travel over
With just enough money to rent a really cheap room for the night at a there. Crying through my entire explanation I wasn't sure if I was going
backpackers hostel and pay for a taxi to the airport the following day, we to even make my flight now. She had to think about everything I had told
were saved. her for a moment, deciding whether or not she would grant me
Early the next morning we were off in separate planes, since Robbie's permission to meet my husband in Australia or send me back alone to
ticket was pre-booked and no available seats left for me to join him meant Bangkok. With only time on my side she had to make a hasty verdict
we would be landing in Australia separately. Fortunately we had found a now. One more question had to be answered before I was let go, she
corresponding flight that arrived within the same hour of each other but I wanted some proof. " If you have just got married can you show me your
would have to make a stop over to the Philippines. The lengthy hours of marriage certificate then'?" This didn't help my stories credibility at all
the duration on the flight seemed to stretch on with only the thoughts of seeing that we were married in a Buddhist temple and given woven
the journey ahead ofme I couldn't wait to get back to my husbands bracelets instead of certificates. Explaining to her that I didn't have one to
loving arms. The trip was going well, sleeping the majority of the flight show her yet but was already aware that I would have to obtain a legal
until I had to change planes in the Philippines. marriage certificate through a courthouse upon my arrival in Australia to
After the plane landed and before any passenger was allowed to get off stay there legally, it was only because ofmy husbands beliefs we wanted
we were handed a declaration statement that informed us that ifwe were to get married in a Buddhist ceremony. She must have shared a common
carrying any drugs or weaponry, we would be arrested and face charges interest in religion or something like that as she finally cracked a smile
with death as the ultimate penalty. Not that I had anything to worry about, upon the photos of the wedding day that I showed her and carrying in my
but what a thought to willingly sign over your life. I got the chills purse since getting them developed, if she wanted proof, well this is all I
handing over my signed declaration and traveling documents to the really had.
customs officer. Obtaining my passport he additionally asked to see my Handing me back my documents and ticket I was now free to leave but
departing ticket. No problem I thought, just I had done many of times, she wasn't leaving me much time to run through the airports terminal to
and I handed over the requested information. The officer looked me over get to my departing plane. Expeditiously bolting through the busy airport
133 134
my adrenaline was still pumping from the previous encounter with the taken a lot of hard work and doesn't come without its flaws but no matter
officials of the Philippines who had enough power to condemn me if they what it is just perfect for the two of us. He helped me how to remember to
had felt like it. I caught my plane in the knick of time and once I was smile again and life has slowly began to sort itself out. They say that time
settled in my seat my thoughts went back to my dear Robbie and how heals all wounds but what I had experienced in my young years wasn't
much I was missing him. I was just relieved that I was on my way to be nearly long enough to let all of the hurt go. Seeking help through many
back with him again soon. counselors and psychiatrists I was doing everything l could do to deal
Looking out the window l could see the red earth beneath me. As l with the scars and all of the pain left behind. Completely off of any
landed for the last time I took notice of the first steps I walked off the pharmaceuticals, since the last day of our honeymoon, and healing my
plane and onto a new soil for the first time. l had so much to be looking heart with love instead of hate our marriage is my foundation and Robbie
forward too in my new homeland. In my heart I knew this was all I ever is my solid rock. We have to be for one another, putting the bonds of our
wanted, this was going to be my haven. There was another surprise in union through the wringers and back, as neither ofus expected my past
store for me when two elder strangers walked up to me and asked my life eventually to come back and haunt me after so long.
name. "Are you Jenna?" Nodding at their question they gave me their Our blissful life came to a sudden halt one day when we were out
first names and wrapped their arms around my neck. My new mother-in visiting my in-laws at their nearby house on just another plain afternoon.
law then said," We are Robbie's parents. We wanted to be the first ones There was a knock on the front door and my father in law got up from
who welcomed you to Australia and into our family" It was my in-laws watching TV on the couch to answer it. He rushed back quickly coming
meeting me for the first time. Handing me some balloons and flowers into the dining room, where l was feeding my nineteen months and five
they even had gifts for their new daughter-in law. While waiting for month old boys at the table, and he blurted out, "Jenna there are three
Robbie's plane to arrive we all chatted about many things like the flight police officer's at the door asking for you by the name of Virginia
over from Thailand and the scare at the previous airport in the Roberts!" I asked my mother in law to stay with the babies to find out
Philippines. I asked them how they knew whom to look for? My father in what this was all about. I didn't even think it had anything to do with
law laughed, saying recognizing me was easy from Robbie's detailed Jeffrey at first and wasn't even worried when I opened the door to offer
description. He told them to look out for a petite, young blonde carrying them to come inside to talk.
an abundance ofluggage. Laughing together over a few more brief They weren't actually police officers and two federal agents of
conversations of getting to know each other better they seemed relieved Australia with one F.B.l agent from America. The American agent asked
to finally meet me compared how stressed she sounded in the ifI wouldn't mind actually coming outside so that I may speak with them
conversations I overheard Robbie having with her while in Thailand. in private. "Okay" l said, as well as mentally preparing myself for
Watching the arrivals board l knew Robbie's plane had landed ages ago something big from the look of it, it's not over a parking ticket or
but was just waiting for him to get out of customs. It didn't bother me anything small that you get three federal agents knocking at your in-laws
anyhow, l was enjoying get accompanied with his parents for the first front door asking to speak in private. "Can we first ask you if you are in
time. Eventually I saw my husband walking down the runway behind the fact Ms. Virginia Roberts and originally from Palm Beach County in the
gates, I just couldn't wait a second longer. I ducked underneath the gates United States?" I confirmed my name and previous state of residence
and ran all the way up the mnway to jump excitedly into his arms. I then they even asked, "May we see some identification please?" A
wrapped my arms and legs around him holding onto him for dear life. I different agent asked the question this time and I told him "I will have to
just missed him so much I knew I would never let him go, theoretically go and grab it, my purse is inside. I'll just be one second."
speaking that is, and I never have nearly a decade later. Robbie was standing on the other side of the door trying to figure out
what they were doing here talking to me and when I rushed through it to
grab my purse and saw him standing there looking puzzled, I told him I
Chapter 24 had no idea what this was about yet, but not too worry everything was
going too be just fine. Taking a deep breath and slowly exhaling
outwards, I opened the door to find out exactly what the agents wanted to
Over the near decade we spent together, Robbie and I have shared the
talk about.
common highs and lows that every determined marriage endures. It has
135 136
Pulling out my Australian drivers license from my wallet, I was going the house and went out to the back yard where I wanted a minute to
to hand it over to them but they were sufficed at a quick glance. There compose myself and process the information I had just been told. Robbie
was no meet and greet, they went straight to the point. One agent picked followed behind me but the stillness in my eyes convinced him to give
up a briefcase off the porch floor and opened it up taking out a stapled me that moment to compile my emotions.
stack of paper. Then that same agent asked me ifl had ever known an A few moments later and I was ready to talk. Collapsing into his arms
affiliate by the name of Mr. Jeffrey Epstein. All of the sudden my with such anguish, he just held me until my sobs subsided and I was able
stomach tangled in a familiar knot that I hadn't felt in many years from a to tell him what actually happened. Starting with an apolob'Y,I began to
past life that I was trying to forget about. I nodded in affirmation of their tell him how I was so sorry but my troubled past has come back to plague
question and said "It was a long time ago and he's no longer an affiliate our simply sweet lives and was just about to turn it all upside down. He
of mine, but yes, I did know him once." It was shameful enough to think was so understanding from the beginning of all this, telling me that he
about let alone talk about with them for the first time since I had started will always be behind every choice that I make in mending the sorrows of
my entire life over. His next response left me nothing short of speechless. my tormenting past and there he has been through all of the thick and
The United States Attorney's Office for the district of Florida was giving thins.
me a notification of being an identified victim. Jeffrey was finally caught Deciding to call the lawyers on the victim suit provided for me was a
for his atrocious acts of perversion on girls who were barely old enough big decision but one I had to do to seek the unanswered questions from
to even comprehend "the birds and the bees" so to speak. my battered heart. The two women at the firm that I spoke to treated me
On June 30th 2008, Jeffrey Epstein pleaded b'llilty for procurement of so wonderfully, like long term friends they counseled me not only in the
minors to engage in and solicitation of prostitution. More than a dozen terms of a lawsuit towards Jeffrey but also in the matters of being
girls had been named as victims of Jeffrey's federal offense's and without emotionally and sexually abused. I chose to proceed with the lawsuit at
ever stepping a day in court he was granted a plea bargain consenting to least to make a statement to a man that tried to make a degrading
charges that named him a registered pedophile for only two of the minor statement about me so long ago. Now it was my tum, I had the choice to
girls. Getting away with even serving only twelve of the sentenced turn the tables on him hoping he would feel embarrassed and in the
eighteen months behind bars be that in the evening alone and in the spotlight for everyone's entertainment where he had kept me for so many
morning he was released during the day. Restricted to the confinement of years.
his lavish mansion in Palm Beach only to be with his original sex slaves Winning my lawsuit against him was not enough to heal old wounds, I
from over ten years ago, Nadia Marcinkova and Sarah Kellen, and never got the chance to stand up in front of a jury and tell them how
knowing Jeffrey all too well, they wouldn't be the only ones there while much pain I had endured and still endure throughout the many nightmares
he was pulling his laughing stint of retribution. Even at nighttime the girls I face when darkness hits and the silence of the sleeping household fills
were still allowed to visit him, accounting to nearly seventy times while my head with pictures of reliving my past with him or the others he sent
serving his time in incarceration. me too. Or did I even get to hear him confess his guilt and suffer the way
No justice had been served for any ofus victims. Denied the very I did locked in confinement for many years? No, instead I got to see a
constitutional rights allegedly there to protect and serve us. We weren't picture of Jeffrey with his anns around a very youthful looking teenager,
allowed to have a voice in front of a jury and judge or even informed for if even that, parading the streets of New York, the very way he had with
that matter. Instead we were handed this notification of being a victim but me and so many other girls long before.
told we were all too late to do anything about. To make matters worse As if it were a public display intended for not only his many victims to
part of that plea bargain was that we had the option to sue him with the see but also a spectacle for the public justice system, it was bold show of
lawyers he provided for us, and conveniently enough I found out later insolence laughing in our faces while we all sat by not being able to do
they were also his lawyer's old friends from the college days. anything to help these young girls from the streets still suffering his
I felt my knees go weak and the anxiety churning in my stomach was perverted afflictions. Not much longer there was another story on Jeffrey
now making me feel sick. Taking the bundle of paperwork from the agent I saw in the papers of him and Prince Andrew having a stroll together in
who was now handing it to over me, I had to excuse myself before my Central Park. It instantly sparked my concerns for other girls in the very
legs actually buckled. Closing the door behind me I couldn't even find same position I was in so long ago and he was obviously up to the same
the words to tell my husband what was going on. I rushed to the back of old tricks, I had to do something now. Not being able to sit by any longer
137 138
with the knowledge of being able to help out in some way. I had to tell
my story no matter how shameful it was to even speak about. Putting my
shame aside I had to derive every bit of courage I could sustain and now I
am ready to tell it. The hardest lesson I had failed at learning until later
on in my life became my strength, the belief in my inner voice and the
ability to speak up. I do have a voice and now the world is going to hear
it in my whispered cries for justice. Swept away by a surge of media with
one phone call I sent Jeffrey's publicist into frenzy. Not to mention the
release of the photos showing the first night that Prince Andrew and I
shared together that I so happened to unveil for the public to see.
I spent too much ofmy life going out ofmy mind waiting for the
rescue that never came until it was too late and then the scars were
already imbedded deeply within. Thankfully I am now free from the
struggles that nearly destroyed the love inside ofmy heart. I only wish it
could be the same for the other victims, not just of Jeffiey's inflictions
but every person who has ever suffered at the hands of another.
I'm here to tell you from my own experience that the moon is yours if
that's what you want, all you have to do is stand up and take it. If some
girl off the streets of Florida, like me, can stand up against the tyrants that
run the deep pockets of our world, than anyone can. Just like I needed to
believe that someone stood up for me once like Robbie did long ago, I
now stand up for us. For all of us girls, the ones who are still on the
streets and think they don't deserve better or it's an unachievable dream
to be entitled to more out of life. For all of the beautiful girls who don't
see beyond they're outside appearance. For all the girls still trapped in
enslavement and unable to get out of the abuse that holds them down. But
most of all, I stand up for every girls belief in love, because it is the very
savior of my spirit and soul.
The End
Written and Illustrated by Virginia Roberts
139 140

141
□ Copyright Protected Material

CONFIDENTIAi. GIUFFRE004274
EXHIBIT B
The Billionaire's Playboy Club should've been my first queue to get out of there quick but with no where
to go, and so naive I didn't realize how much worse it could get. Setting
foot into that limo, I made my first entrance into a world that would
By Virginia Roberts
entrap me for many years to come.
He introduced himself immediately as Ron Eppinger, a businessman
To my true love Robbie who believes in me every step of the way and
and owner of a successful modeling agency, called "Perfect IO".
to all of my children, you are all my very inspirations!
Flaunting his oozing wealth by introducing one of his many girlfriends,
the beauty next to him was Yana, a supposed model from the Czech
Chaptert Republic who looked like she could be in her early twenties with the
heavy load of makeup she was wearing, but really was only in her late
Every single person in this shared world together has a unique story of teens. She kissed me on both cheeks and politely said "Hello" in a thick
his or her own to tell, this one is mine. Czech accent, making me feel a little more at ease. Convinced it couldn't
It was coming up to my third night camping out at Miami Beach in the be that bad there was another girl in the car, right? I couldn't be more
summer of 1997. I was thirteen years old and hiding from a world full of wrong.
hurt. Sitting on the shoreline for hours watching the sunset fall deeper What he didn't tell me to begin with was that his modeling agency was
into the horizon, my eyes were glazed over with tears, not from being only posing for an undercover trade. By the time I found out I thought it
wind-whipped by the rough sea breeze, but from reflecting on the abuse I was too late to run. His business was really an illegal immigrant
encountered as a young girl and how everyone in my life who was trafficking ring of young women mostly consisting of underage girls that
supposed to be there for me had now turned their backs on me in he was using as escorts to make him uber rich. Only available to a
abandonment. My fears crept up and the excitement of escaping all of selective clientele costing them anywhere from $1000.00 and over per
them faded now realizing how alone I really was now, and for the hunger hour of erotic entertainment, the girls were trained to fulfill every sexual
that was paining my belly. At this point, with nowhere to go and only desire asked of them, no matter how bizarre the requests might be. The
time to waste, I wiped the tears from my eyes and set out to find an high paid escorts, for Ron's super rich clientele, such as Yana and many
empathetic person that I could manage to get dinner money from. If not, other charismatic beauties would only benefit a fraction of their earnings
it wouldn't have been the first time I had gone hungry for the night. I for themselves, Ron reaping in the majority of the financial rewards and
walked to the nearest bus stop and asked a handful of people for any being they were all illegal immigrants they were further trapped by his
spare change, none of whom that could help me. Sitting down on a enslavement.
nearby curb disappointed in grief of my current state, I put my head into I proceeded to introduce myself, besides what he had found out about
my knees and began to sob. me on the curbside. Telling him my name and a little about how I ended
Out of nowhere, it seemed, a black stretch limousine turned the comer up on the streets explaining that I could take care of myself and didn't
and stopped in front of the curb where I had been hopelessly lost. The need my family or anyone to look after me anymore. Looking back later
back door opened to reveal a heavy weight and balding, old man with a in life I can now admit I was in a terrible state, but being such a
big cheesy smile. Neatly dressed in black trousers and a collared shirt, he headstrong teenager, I refused to give in. He asked my age and I told him
was sitting next to a striking young, blonde girl, drop dead beautiful and I was sixteen at first. He coyly replied, "Are you sure? I think you could
dressed in a foxy red mini dress she looked like a model just stepping off be telling me a fib? How old are you ... really? I wont be mad" Being a
a runway. terrible liar, I knew had been caught out and couldn't deny it any further.
Their smiles greeted me warmly and he kindly asked, "What is such a I told him the truth and he chuckled then paused and answered in a very
sweet little girl like you doing sitting alone on the street looking so serious tone "As long as you never lie to me again I will take you in"
upset?" Shocked from this strangers concern l was hesitant in telling him Right away I pondered to myself what did he mean ... take me in?
the truth. Reluctantly I decided to tell him that I was a runaway, not from He gave the driver the location of our destination and rolled the middle
around here and really hungry. Hoping at most, I would get some money window back up to then tell me a story of how his daughter had passed
for food from him. He instantly displayed a chilling excitement and away seven years ago from a horrific car accident in which four other
offered me to come into his car so we could talk some more. That teens were killed and he has never gotten over it. I reacted with sheer

sympathy and gave him my pity, believing this man had a heart. His next name she came up with for me, being I was the youngest one among them
proposal was eerie, he said," If you wanted, I can be your new Daddy. or ever to be brought in by Ron for that matter. It became my new
Someone to take care of you and you'll be my new baby forever" he identity not even worrying to mention my real name to anyone anymore.
stroked my hair such as a caring parent would comfort a scared child. A My identity was no longer important to myself, I wanted to become
part ofme wanted to accept his words and believe he really could feel someone new and "Baby" is who I was.
that way, and then I also considered how hard it was living on the streets. A shocking first impression, the girls were completely nude revealing
In the end I convinced myself this would be the lesser of two evils. their voluptuous young bodies with such a careless ease and others were
The car stopped at a plaza on the water, surrounded by little boutique in just a G-string, similar to the one's Ron had bought me earlier. They
shops, restaurants, and little stalls with items for sale like sunglasses and were all stunning girls and full of life. Charismatic and beautiful, they
costume jewelry. I didn't know what to say or do or how to act, it all were the girls who should be on the front of billboards not selling their
happened so fast I just went along with everything he said, for now. bodies to old crewed men for sex. Doing each other's make-up in front of
We went to a take out restaurant and ate on the waterside, and the mirror and chatting away on the bed with no care in the world, aiming
afterwards he took me to G.A.P Kids co. to dress me in his idea of proper at persuading me to see the highlights of the life Ron gave them and they
attire, tiny cutoff shorts revealing the cusp ofmy buttocks and some shirts almost did. Ron left the room for a few moments, letting us all get to
that barely fit, even the sales assistant was shocked at what she thought know each other a little better and that's when I started to compile an
was my Grandfathers choice in clothing. I couldn't even believe it myself understanding of what really went on here.
only an hour ago I was begging for money living on the streets and now I Just catching a bit of their conversation from before my introduction, I
was dining alfresco and shopping at name brand outlets. We then hit a heard them chatting about the night they were preparing for. Speaking
couple of more specialty stores afterwards. He said he had to buy me a excitedly about some men they would be entertaining in a few hours, one
few more necessities to start with. Lacy G-strings and what looked to me girl was talking about going out to sea with one o these clients on a yacht
like lingerie pieces I had only seen grown women wearing in magazine for a few days. Since none of the girls seemed shy to talk about their
ad's or movies was now a part of my wardrobe, in my mind it was a big professions or anything for that matter, I decided to ask them a few
step up from being a little girl any longer. questions about what they did. They were more than happy to expand on
The driver took us back to Ron's grand apartment overlooking the isle their point of view in the conversation, attempting to paint a pretty picture
of Key Biscayne and a large bridge leading into a Miami Harbor. of what they were paid to do.
Entering his residence, I was blown away by the spectacular view, rich They all began to jump up and down with excitement like giddy school
decor, and white marble floors that were so glossy it looked as if I was girls at a slumber party. Another girl with jet-black hair and a thick
stepping on glass. He took my shopping bags to a large room at the back accent, wearing absolutely nothing at all, grabbed me onto the bed with
of the apartment and put them into a small closet. The room was them and into their fiasco, instantly making me feel accepted into their
considerably large with glass exterior walls that maximized the potential sorority, like I actually belonged somewhere for once. Yana went on to
of the panorama landscape soaking in the seascape of Miami. In the room explain a little more in detail," We accompany the wealthy friends of
was a gigantic round bed raised off the floor by three steps and mirrors on Ron. They want only beautiful girls by their side so we come and act
the ceiling. It looked like a honeymoon suite out of a raunchy hotel. He however they want us too but most importantly we make them think we
then exclaimed, "This is my room here and you will be sharing it with want them back too." Other girls began to jump in with their vivid points
me" When I asked him where I would sleep he then sickly replied "With of view while playing with my hair, they were taking turns brushing and
me silly, where else of course?" With no room for argument I pretended styling it as they were filling my head with all of the prospects I could
to be O.K with everything that my common sense was screaming out in have as an escort too. They made me feel beautiful like them, too
my head to run. beautiful for what a girl beyond my years should feel. I was simply being
Next I was taken down a long hall at the other end of the apartment to lured into a dangerous trap, just like they had been at a young age too.
meet five more exotic beauties. Three girls were in their late teens and the It pretty much all came down to two things in their game, the money
other two in were in their early twenties. All of them were from the they would make and the lifestyle they were given. Their enthusiasm only
Czech, here under false passports provided by Ron and his contacts. Yana interested me further, making it not only sound like an acceptable way of
held my hand while introducing me to the group of girls as "Baby" a pet living but also appearing to keep them all vivaciously satisfied. This way
3 4
of life was just mind blowing to even comprehend at first. With such a introduced me to his business partner and told to go get dressed. He had
new outlook of the world to try and grasp at my young age I was listening my whole day planned out for me already. Booked into get my hair
to every word spoken to me with such attentiveness, I was going to try colored, a much lighter tint of blonde, and afterwards a day of shopping
and model what l was observing from the girls. l justified their way of with the girls l was becoming exactly what he wanted me too, a carbon
thinking in my head for now, thinking if all these girls seem happy copy of the teenage Barbie ... only I wasn't plastic and came with many
enough, why couldn't l try to be, it was this or the streets for me. benefits.
Ron came back for me not long after our conversation got out of hand Days turned into weeks, being a servant to the sexual desires of this
and took me to a bathroom down the hall. He opened the tap and filled a distorted pervert. I dreamt of escaping but where would I go and how
small plastic cup with water and handed me two small blue oval pills. would I get away from Ron with him controlling my every second ofmy
Telling me to take them both as they would help me to relax a little bit day. Separating myself from the other girls being so uncomfortable with
more. I swallowed the pills just following his orders. I put the cup on the enduring the everyday occurrences I was longing for the solitude of the
counter top and turned back around to face him. Backing me up against beach again. They were training me up to be an escort prodigy or
the wall and now cornered by this large man I felt his slithering hands something like it. Outrageous orgies were conducted as my lessons with
began to creep under my shirt, writhing my skin. I closed my eyes tightly the girls teaching me all of their tricks in the game, it was all for the sake
and turned my head away from him, hoping he would take my actions as of men's perverted fantasies, they didn't get anything from being sexually
a sign of being extremely uncomfortable but that wouldn't bother him at exploited and molesting each other, except getting paid for it. Everything
all. He was half enjoying my reaction from the smug look on his face, from oral sex too penetration with toys, I was expected to not only to join
and persisted through it. in but even perform ludicrous acts of hedonism.
Continuing to undress my clothes he said he wanted to look me over I was Thirteen years old and had never heard the terminology of these
and clean me up. It was so humiliating having to expose myself to this sexual acts before, and definitely shouldn't have been learning them first
ageing man and now I knew he was going to end up with his hands and hand. Thrown into a world of chaos, I didn't know what to do except be
whatever else all over me. All too soon I hated to be right, as I stood as compliant as possible, even when asked to do the most deb'fading
naked before his widened eyes, he told me "you're a hairy bugger I'll tasks. The excitement of the lifestyle he offered quickly diminished once
have to shave you right up young lady", and I didn't know he wasn't just I had to pay so dearly for it. The girls that subdued to this lifestyle and
talking about my legs. Standing with my legs wide apart while this man enjoyed it definitely put on a good act, but no little girl with hopes and
coaxed me through the entire ordeal of shaving, his hands made me feel dreams of their untainted future, turns to her mother and say's "one day I
so dirty. "Havel lost my mind?" l thought to myself but l had to play dream of being a prostitute, passed around from man to man, only to
nice until l had an opportunity to get away, this was not as fun as the girls grow older regretting so much of my life" It was all a part of an illusion
made it out to be after all, this was utterly disgusting. l had no idea what that Ron painted for us that made it seem so alluring in the first place.
was going to happen next with this guy, and due to whatever Spending my days with Ron, he took advantage at every chance given.
pharmaceuticals he gave me, I still don't know to this day. Even in his convertible with the top down I would be forced to go topless
Waking up the next morning my head was pounding in an agonizing while he drove around, when I asked him why one day, it was supposedly
thumping pain and I was so thirsty. The satin sheets thankfully covered so I could maintain an even suntan, but I knew it was his way of showing
my body, which was still nude from the night before, and I could hear off his treasures. It was a far cry from the simple country life I had been
hushed voices standing over the bed where I was pretending to still be raised in. Wearing designer miniskirts and tops that always revealed too
asleep. Listening in on their conversation I kept my eyes shut. I knew much, of course due to Ron and the girls determining everything I wore,
Ron's voice from two of the men but not recognizing the other guys I just ate, or spoke. We would spend our days at hair laser clinics, shopping,
stayed quiet hoping they'd soon leave. Ron was telling the other man tanning beds, and eating as little as possible. Through the nights we were
what atrocities he got up to the night before with me and l heard him say, expected to become party animals and greet Ron's clientele with the
"Doesn't she even look like an angel the way she sleeps? She's my own upmost flirtatious attention and doting as possible. Then whether we were
little angel!" He exclaimed proudly. l opened my eyes and rolled over to out for dinner, at a party, or at a club, the men would choose his girl and
face them both having to wrap the sheets over my body, really not take her home. Every girl had a different price and so did the charges
knowing what to say except "Good-morning" in a blushful tone. Ron depending on the various clienteles but Ron always kept me for himself.
5 6
CONFIDENTIAi. GIUFFRE0041J8 CONFIDENTIAi. GIUFFRE004l 39
I would always dread the end of every night, fearing what new desires his tight clutches, crying myself all the way to sleep. He didn't even ask
he had in-store for the evening. Sometimes he would hurt me and tell me me what was wrong, probably because he knew already.
to try and enjoy it then do it over and over again until I gave him exactly Soon enough the crumbling of his evil empire in the underworld of
what he wanted, I always resisted until I could no more, he was too selling sex for his own advantage began with a single crack in his perfect
overpowering and relentless at getting the results he wanted. At other scheme, and proudly it all started with me. Ron got a scare one-day and
times he could be so gentle and caress my skin, worshiping every inch of rampaged through his apartment telling us girls to only pack our
my body, all relying upon on what mood he was in. Often though he liked important belongings and some clothes as we all had to leave right away.
to play the teacher role and instruct me on every motion and explain what I didn't have much belonging to me so I basically sat there watching
would happen when I did those certain things to him. No matter what he everyone rush around frantically and was curious what could've gotten a
did to me I was only disgusted with myself more and more. I still shudder man like Ron so scarred. Once we were packed up and in the limo he was
at the thought of how he used my body. trying to calm the frantic girls down after all the panic that spread through
I turned fourteen in Aub'l!Stthat same year and was spending my the apartment like wildfire, I was the only one sitting there half amused at
birthday loaded on a concoction ofphannaceuticals and alcohol, being the entire situation.
generously supplied by the very man who swore his devotion to caring He began by assuring us that everything was going to be fine. Calmly
for my every need. I didn't even know myself any longer, completely he continued to tell all ofus packed in tightly, even for a limo, that we
shying away from the girl I had grown up to be until to this point. The were all taking a long trip to Florida's countryside because someone has
apartment was empty except for me, for the time being, and that was reported an anonymous tip to the missing persons unit at the local police
God's own little present for me ... some solitude for once I thought. station identifying a very young girl as a possible victim of abuse living
Pouring myself another drink I opened the sliding glass doors to the at his apartment. Ron knew what a landmine of trouble he had brought
balcony and walked to the edge. Looking down from the many stories upon himself making an exhibition out of me on the streets of Miami, I
where Ron's apartment was, I wished myself a happy birthday out loud didn't pull off the older look like the other girls, I actually looked
and wondered ifmy family even remembered the day's occurrence. younger than my age with my blue eyes and freckles always giving the
Dwelling in my sadness for the fourteen years of suffering and impression ofmy youthful innocence.
loneliness I had already endured, the tears swelled up in my eyes, Now he just had to do whatever it took to ensure he stayed as far away
trickling downwards making my eyeliner inevitably leak down my from the authorities as possible. Arriving at a ranch in central Florida
cheeks. Inside I felt so trapped and began to entertain the thought of many hours later and I assumed it belonged to Ron knowing never to ask
jumping over the edge, it all seemed much easier, and the simple him things like that. I knew my purpose and it wasn't prying into his
blackness that death had to offer rather than the tangled mess I was so personal life outside of the bedroom. There was a main house, a few
tired of fighting to get out of seemed a much easier approach. Detached cottages, some staff quarters and paddocks where the horses were kept. I
from wanting to feel anything, I became so numb towards my life's own was in heaven .. .I thought at first. Finally, something I could really enjoy.
tragedies. I couldn't live like this any longer. I lifted my bare legs over Riding was my passion, basically growing up on the backs of horses since
the edge of the railing and sat looking at the ground beneath me so close I was just able to walk.
to even just slipping off the edge to my very death. I couldn't think of any Not surprisingly I began to despise Ron and all of the girls for the
reason not to fall. I thought I had made too many bad decisions to keep gross exploits they made me do with them. Beginning to isolate myself
going on but some force of a higher nature had other things in store for from everyone I'd rather spend my time sitting under a tree watching the
me. horses graze, writing in my journal or painting but mostly avoiding
The sliding door slammed open with a burst of speed and Ron scooped everyone possible unless Ron required me elsewhere. Nighttime was
me up in his big arms and brought me inside to our bedroom. Laying me always a reoccurring nightmare for me. Relived over and over again in
down and seeing the look of despair in my eyes from my tear stained face many various ways. Ron would always start by making me some drinks
he went into the bathroom cupboard and returned with three pink pills. and offering an assortment of pills before indulging himself by
Forcing me to swallow them using the angered tone of his voice he grotesquely putting his genitals in my mouth and tell me how to give him
thought he was turning my sorrows into a distant dream as I passed out in what he would call a "first-class blow-job", and I was being judged every
minute of it. Ordering me to slowdown or speedup or maintain a perfect
7 8
rhythm I was constantly being criticized for my efforts in pleasing him. I the phone were nothing short of desperate plea to keep me on as long as
was eager when he actually gave me a compliment. The rest of the possible. I thought he was just trying to help in someway. Giving him
evening was always a surprise left up to a moments notice. Quite assurance in the fact I had survived this long obviously I can hold off a
regularly he would proceed with having the girls dress me up in some while longer I gave him my love and told him I'd be in touch.
sexy outfit and loads of makeup then entertain him with a lesbian Thinking I had slipped away unnoticed I entered into the room that I
reenactment revolving him in the center. Sometimes they would use shared with Ron, hoping I got away with my brief and very needed phone
dildos and other foreign sex toys, Ron liked to see us hurt during sex, call. The place looked empty and everyone else seemed to be out and
sometimes even penetrating me anally but I always resisted and would try about so I decided to have a bath in the spa and try to relax before the
to redirect him with another sexual desire of his but I had no excuses night's precautions. My body glided into the steamy water as I began to
when it came to me having to use the sex toys on him, he told me how think about T.J and how good it felt just to hear from a friendly voice. My
men have g-spots in their rectum and instructed me on how to precisely thoughts drifted into the days I missed when I felt I could be silly and
penetrate him. These nights went on what seemed like an eternal sentence childlike and I nearly forgot for a moment how grown up I was acting
for the price ofnot living on the streets, where unfortunately for the one's these days.
still there, I feared and knew from my own personal experience, could be My first glimpse at the image surrounding me when I resurfaced above
much worse. the water was daunting. There was Ron was standing over my tub,
Needing some contact with someone ofmy adolescent mentality I looking down at me with an eager display of his arousal. He began to
called one ofmy school friends from the past, whom I wont name out of undo his pants and take them down when he told me "put your lips on my
privacy, but I'll call him T.J. We were so close and I knew very well, so cock", I was too slow in responding to his request so he grabbed me by
well, I had memorized his number a long time before. He was my first the back of the head and forced me into his groin. I had tears streaming
puppy love sprung from of a childhood friendship. Being my very first down my face as I looked up to him with the saddest blue eyes hoping he
crush the summer before all of this happened he was the only person I would take pity and stop, but he never did. I was really hurt by his
could think of that would care enough to talk to me. aggression and he definitely knew it this time, which I believe only made
In the middle of the day, the least busy time to be noticed, I snuck into him more heated. I closed my eyes and began to count using the time to
one of the vacant guest rooms and used the phone to call my good friend. keep my thoughts elsewhere believing every number I counted only
The sound ofmy voice radiated a chill in him. "It's you, oh my God furthered me to the end of this. I just got over a hundred when he finally
Jenna! Are you okay?" he was so shocked to hear from me and the sheer exploded in fulfillment still half submerged in the deep bath I was
fact I was still alive. Nearly three months now without a single word to struggling to gain my bearings in as Ron was picked me up out of the
my family or friends, every one doubted my return. My attempt to forge a bath and carried me to go to the bedroom, which was just outside the
happy voice when I spoke to him failed and I absolutely crumbled when French adjoin doors. Still damp from the hot water in the spa I had goose
he was at a loss for kind words for me. I told him ofmy current state of bumps from the chill of the fresh air where he brought me to the bed and
affairs. Telling him of Ron and how I was terrified of him, trying to proceeded to deeply violate my every being. Eventually his scars that he
escape in the middle of nowhere was useless. It was like being kept in left were too deep ever to be healed and would even carry on through the
cage that I was unable to break free from. Going on to dump my issues on years to come.
T.J, I proceeded with how I longed to call my family and to be with my Upon his bursting with pleasure for the second time, he just got up
them for good but was too afraid they didn't want me, knowing I'd just and left, without even saying a word to me. Left alone I was awake for
be sent away somewhere else again and to me after all this time was like hours after that. There was no escaping the pain that night. I lay naked
going from one cage to another. wrapped in the sheets, sobbing in the dark. My feelings of being hurt and
He had been called by them numerously and promised me that they disgusted after his abusive ordeal "When will it ever stop" I prayed to
were very worried and even hired private investigators to try and find me. God and begged for death rather than face another day in my life. I woke
Given I was eleven years old the first time I was sent away, my trust in up still alone the next day and exasperated from the misery I felt the night
there sincerity he spoke about was seriously doubted. I kept the before. Ushering through my drawers to find something to throw on I
conversation short just in case my absence was being noticed and I left on could care less what lay in store for me today, couldn't be as bad as being
the note that I would speak to him again shortly. His attempts to get off raped by a scary man repeatedly.
9 10
Starting my day with a few of the supplied oxytocin 'sand a bloody them that the confession came from the house-keeper who said she saw
mary, made by the live-in house chef. Having two celery sticks for my me use the room regularly but was never messed up, so Ron looked at the
breakfast, I wanted to lye out by the pool and forget the world. Ron hated recent telephone bills and found the same number dialed from that room
tan-lines so to be caught with a bikini top on was a big no-no in his rule consecutively, he knew it was me right away. At least he didn't know it
book but after my cries to stop were so blatantly ignored last night, I was was another guy, I thought to myselt~ or I probably wouldn't have made it
out to piss him off so I didn't remove my shirt. I put on my headphones out of there alive.
and before I knew it had fallen into a deep slumber from my self-made Ron came back to usher the girls out of my room and told me I had five
therapeutic cocktail, the only way I knew how to cope with the emotional minutes to pack my clothes, which he made clear were to be my only
turmoil on the inside. belongings to take with me. He washed his hands clean ofme that night,
Desperate to hear his voice I called my friend T.J a few more times that or so he thought. The driver came knocking at my door, just as Ron said,
week. I needed to feel like someone out there really knew me. Sometimes no longer than the five minutes that he had offered me and he took my
we could just chat like old friends with no care in the world and laugh at single bag to the car. I didn't want all the jewelry, music or books that he
a distant memory from too long ago. Then would come the good-bye part so caringly bought me as tokens of his twisted affection. Only taking my
of the conversation and we would both get teary-eyed not knowing what clothes and a wad of hundred dollar bills I had been saving, I slit a hole in
could happen next or if this would even be the last time we ever spoke to my scrunchie inserting my cash for a rainy day that I was more than sure
each other again. was just around the comer. .
My biggest fear came to reality when I was in our bedroom one We drove for hours, until I started seeing familiar surroundings. I
afternoon, just lounging around out of boredom. Ron came bursting in couldn't believe my own eyes. I was back in Miami, but not on the
through the door, red as a tomato. I couldn't help but feeling I was in big beaches, somewhere in the CBD this time. The Driver delivered me to the
trouble. His face was distorted and raging towards me. I knew right away front door with my one bag and waited at the door with me. Now I knew
he must have found out that I was calling T.J, but how, I had no idea. I how it felt to be a puppy picked from her litter as you can only hope your
had always tried to be as invisible as possible, soon enough it was all next owner would treat you with some sort of kindness.
explained. Another balding man answered the door but he wasn't so grotesquely
"Are you trying to get me caught? You are nothing but a stupid girl fat like Ron, but still a new owner at that. He looked me up and down and
you know that! What am I supposed to do with you now?" He was seemed amused as he snickered to himself. With one last look to the
tearing up the room while his rants gave me something else to think driver over my shoulder it was almost an appeal to him for some way to
about. What would he do with me if he had no use for me any longer? I help me. 1 knew he couldn't anyways, I was just hoping. He told me his
wasn't even thinking about him being caught for soliciting illegal name was Charlie but didn't even bother in asking me for mine. I was
immigrants for the purpose of prostitution. I was more worried that he sure Ron already filled in all ofmy details when he arranged this.
would be upset at the fact I was talking to another guy, maybe even Charlie picked up my bag and led me into his bachelor pad townhouse.
jealous that he was at least my age. I replied with simple sentences that I I was never given a welcoming tour of my new residence or made to feel
could manage to get out between all the shouting. I kept saying, "I'm comfortable. He walked me up the stairs and opened one of the doors in
sorry" and putting my head down in shame. He picked me up by my the small hallway. Telling me this would be my room, he showed me into
throat pinning me against the wall, "You are going away, far -far away it and told me to wait, he would be back shortly. I sat on my bed afraid to
from me and you better be nicer to the next man I send you to, I've heard touch anything and after the warning Ron gave me I knew I had to watch
he's not a nice as most would like. Are you fucking hearing me Bitch?" I my step around here. I put my head down onto the pillows my where
slid down the wall, choking on the first air entering my lungs, breathless world was falling apart and let my emotions downpour. Exhausted from
and terrified, I never thought Ron was a nice guy but I had never seen the days emotional turmoil I ended up falling asleep. I don't even know if
him lose it this bad. Now I was being sent me away to another stranger, he ever came in at all that night.
another man, it only terrified me more. The next morning I looked out of the window to see my new
The girls came in to say their good-byes all of them were crying and surroundings. It was a beautiful sunny day outside, unlike the dreary cell
asking me in their best English languages, why I had to call someone and I was locked away inside of. Feeling the sun warm up my face through
lose everything? I was able to find out through the broken sobs off of the glass, it radiated a familiar sense of comfort from the days of the good
11 12
parts ofmy childhood. 1 reminisced how it had used to be before all my knew what I had to do to get this over and done with as quick as possible,
life turned upside down. Before all of the fights with my family, before I but I was dreading this moment from the second he greeted me at the
had to look after myself, and before I was a slave to men. door last night.
Those days were too long gone now. With too many hard times passing I fell to my knees and gave into his demented perversions. Thankfully
me by it seemed surreal to think that life had ever even existed in the first it didn't last long before he climaxed and I was allowed to get myself
place. With that thought I shook myself out of reminiscing that way. dressed and ready to go out. I was nothing but money well spent in his
Whatever was going to happen was out ofmy control now, I just had to mind. This was another extremely wealthy man with a completely new
give myself some hope that I would have the strength to get myself out set of wants and needs asking a fourteen year old girl to affectionately
these circumstances before anything really bad happened. dote on sexual desires to a man in his mid forties. I really hated myself,
these men, and just about everything my life had boiled up to by this
point, but I knew from a young age that to survive in this harsh world I
Chapter 2 would have to do many things I would not willingly choose to.
At the shops he decided he would choose the clothes he paid for, which
I might as well have been declared a teenage prostitute. Just like Ron he
The house was quiet so I just assumed Charlie was still asleep. I
also liked it that way. The more degrading he was to me only proved his
decided to get cleaned up and have a shower. Not even a knock on the
door when Charlie walked in with ease. "Typical" I thought. It was an ownership ofmy body. He bought me tiny cocktail dresses, and skimpy
outfits, which I thought closely, resembled the lingerie he'd also bought
easy way for Charlie to break the ice. "You really are as beautiful as Ron
said" as he opened the curtain. Watching me rinse myself in the shower for me to wear for him. I noticed that day that he enjoyed parading me
and me knowing I had no way out of this except to go along with around the shopping mall and out for lunch at hooters, even joking with
the waitress that he'd like to buy her uniform because he thought it'd look
whatever he wanted. I just looked down at the mention of Ron's name,
sexy on his new girlfriend.
wondering what else he had told Charlie about me. Realizing later that he
wouldn't have said anything anyways, in fear I would've been a damaged We arrived at his two in one, Restaurant and Club, at around nine
o'clock in the evening. It was a revolving tower called "Hot Chocolates"
product that wouldn't make him the money that young girls go for.
in downtown Ft. Lauderdale. The food was delicious and for the first time
He just sat on the side of the vanity top and continued to take
since being with Ron, I ordered a hefty meal with steak and mashed
observations ofme standing submerged under the falling water. I avoided
potatoes with a scrumptious gravy smothered on top. Charlie ordered
looking at him and let him do all the talking, after all I knew what I had
strong cocktails for us both and before 1 knew it my head was spinning
to say was ofno importance, that is ifhe was anything like Ron. Between
and we were on the dance floor together. The music blared in my head
the water beating down over my head I could slightly hear him ramble on
and the rhythm ofmy body took over, completely forgetting about even
about some club and restaurant he owned in FT. Lauderdale. He said he
was going to take me shopping for some club outfits and we would party dancing with Charlie and letting the music take ahold and work it's
together tonight, as if I was supposed to be excited over this so-called magic.
treat of his.
It didn't do me any justice though as Charlie watched me imagining
I looked up and gave him a quick smile adding a compliant nod and what pleasures lay in store for him later on. Taking me home before the
club had even closed, he just couldn't wait to indulge on exactly what he
turned my attention to turning off the faucets and quickly i,rrabbingmy
towel. I was falling so far from who I used to be, shying away from my was fantasizing from beforehand. Once back at his townhouse he led me
up the stairs into his bedroom and pushed me down in the middle of his
outgoing personality to a quiet girl that didn't even recognize herself in
bed. The motions from the wavy mattress made me dizzy and feel even
the mirror anymore. I dried myself off and looked at the man standing
drunker when he lay on top of me. Coming at me like a hungered beast
between the doorway and me. He was still watching me with a sleazy
wanting to ravage his next meal, it was intimidating as he entered into me
look on his face but now preceded to move in my direction, arms wide
with a forceful thrust, he moaned out in delectable heaves. I looked away
open. He embraced me, running his hands up around my youthful curves,
while he self indulged his own gratifying needs using my body as his
licking my neck and earlobes. Then his large, rough hands cupped my
instrument in pleasure. I only grew stronger in my head letting the hatred
small breasts and continued downwards to feel in between my legs. I
for men desires intensify.
13 14
The next two weeks I was expected to be at Charlie's beckon call, never at first. I couldn't even comprehend what was happening so rapidly. I
aloud to leave his side, even making me sleep in his bed from the second thought Charlie could've been in some kind of trouble with a business
night onwards. I never even got the chance to call T.J again. It was too friend he had done wrong too, but then one of the men in black shouted
much ofa risk anyways. Thus pushing him further out ofmy memory, "F.B.I this is a raid get down with your hands on you head", in too much
too afraid, of the emotional repercussions. shock to move three of the men grabbed Charlie and threw him to the
Our typical routine was to wake up get showered and dressed and I floor and cuffed him. I sat up in bed with my sheets covering my naked
would put on my make-up while Charlie made his business calls for the body and watched as they dragged Charlie from the room. Still
day. We would leave the house mid-afternoon and run his errands do completely nude he wasn't even aloud to get dressed. Another agent had
some shopping, sometimes meeting his friends or business partners for to come back in to the room to find him a pair of shorts. I could hear him
lunch, none of the men he introduced me to seemed offended at his screaming at the top of his lungs all of the way outside He was screaming
choice of adolescent eye candy. They'd just continue to chat away as ifit and the last thing I heard him yell was "Tfyou say anything you know
was normal to be in public with his arms draped over a girl young enough who will find you!" I could hear more threats being yelled at me but I
to be his granddaughter, not too shy by giving me a flirty tap on my couldn't make out what it was that he was saying. I was in total confusion
bottom or even try to kiss me. and couldn't believe what was happening. There were so many uniformed
My last night was no different from every other night. We went agents I felt so small compared to all of them but they were all very kind
shopping that day and out for lunch alone. Later we headed to a club his and helped me out of bed allowing me to remain covered up with the bed
friend just launched and it was his grand opening that night. The club was sheets so I could get dressed. The first decency I had been showed in a
called "Iguana Joe's". We met up with his friend and said our hellos. long time. It was an odd feeling to acknowledge. I knew the life I had
They both seemed so excited about the club and Charlie was full of come accustomed to for the last six months was now over, and in so
compliments all around. The club did have a line out the door which many ways I was relieved but was also very nervous about what lay
looked a mile long coming in, luckily we didn't have to use the front ahead of me.
door. Charlie returned from the bar with two giant long-island iced teas, I excused myself to the bathroom to put some clothes on. Not having
which were his favorite drink to start with and then we just sat for a while anything half decent, like a normal pair of jeans and at-shirt. The best I
watching people dancing. Occasionally conversing about passing could come up with was a metallic blue miniskirt and a tiny matching top
thoughts. We danced for a while having a few more drinks and after that fell just below my breasts, hardly clothing at all it was more like
about two hours, Charlie said he was ready to go home. What a daunting scraps of cloth. Putting my hair up in a tight bun with the scrunchie that
time to look forward to, he always liked to have a brief sexual encounter held my five hundred dollar bills I was led out of Charlie's townhouse for
before drifting off to sleep with my naked body intertwined between his the very last time. Starting my life over. .. again, I wanted to leave behind
arms and legs. my every memory belonging to these horrid times. Only taking small
It was bad enough to have to entertain him at every given second of the sack containing my underwear, makeup bag, and journal with me.
day but his grip on me was so stifling I felt so chocked I could hardly The agents led me down the staircase and my last vision's of Charlie
breathe much less sleep. Eventually my over-worked mind would drift in- was bent over the hood of a police vehicle still screaming and
and-out of a restless sleep, but constantly on edge. I thought many of handcuffed. I slipped into the backseat of the car and was driven to
nights of escaping, but where would T go? Would one of Ron's ever-so- Broward County Police Station where the Federal Agents interviewed me
connected informants finds me and turns me into him to be disposed of about my entire whereabouts for the last six months. I was so scared of
for good? I just prayed that I wouldn't be another missing person to add what Ron would do ifl told the agents what really happened but at the
to the list of girls found in the local ditches. I knew that's where I was same token I knew he'd most likely kill me anyways for being such a
headed if I screwed this up for Ron again. liability.
As if my !,'llardian angel was there the whole time listening to my Over the next few hours I sat down and told the agents how Ron's
secret prayers, my rescue came the next morning with an abrupt bursting business worked and what I part I had to play to him. I was able to ask
through the bedroom door at about six am. Charlie and I were still lying how they found out I was at Charlie's house and they informed me that I
in bed together and his grip on me was still tight. The men dressed in all was being followed all the way from Ocala, Florida where Ron had me
black military gear had large guns and helmets on. It was so frightening stowed away for the last four months. T .J, my friend, called my parents
15 16
after our first phone conversation and ever since then, the F .B.l were whole life they ended up repeating the same attributes as the people who
tapping the phone lines and recording every conversation. Completely initially hurt them in the first place.
unaware of T.J's caring act of deceit, Twas in such shock that they had One very sad girl I'll never forget her, had a father who had been a
been tracking us for so long. I knew now, with or without my help, the heroine junkie and decided to play Russian Roulette with some of his
F.B.Thad enough on Ron to put him away for a very long time, if they addict friends and by fate or chance took the bullet straight through his
could catch him, that is. brain, killing him instantly. Her mother being a heroine addict herself
Having so many crooked people working for you can be an advantage spiraled downwards after his death and gave her four year old child to her
when you're in trouble. Like having a pair of eyes in every city. Ron was ageing grandmother that eventually had to put my twelve year old friend
somehow able to find out about Charlie's arrest and immediately deserted in this un-dire circumstance. I can only have he highest hopes for her
the country to avoid legal punishment, not to mention the discretization today but unfortunately for most girls that have been victimized by
of his esteemed clientele that the feds were now on to. Ron had so many society aren't able to ever stop being a victim for the rest of their lives or
countless charges put up against him, eventually when the F.B.I were go on to make other people victims themselves. A sad and unfortunate
able to track him down they were able to have him arrested in Yugoslavia fate for so many innocent, and it happens so much more than anyone
and extradited back to Miami, he was finally held accountable for being a would rather admit too instead of just trying to find a solution.
pedophile, soliciting women for prostitution, and running many
illegitimate and illegal businesses. By the time the F.B.I caught him he Chapter 3
was in his mid-seventies when he died of old age serving his second year
prison for a lengthy sentence. Coincidentally I was told of his punishment Hours later I was still twirling myself in the same office chair when I
and death many years later by one of the same F .B.l agents that had spun around to see my Father walking in my direction. Tnearly fell off
rescued me from Charlie's arms. my seat at the sight of him. Gripping the chairs handles I couldn't
Twas taken out of the interrogation room after the interview was over
imagine what in the world Twould say to the man Tonce used to call
with and told to sit at one of the officer's desk while I was waiting for Daddy but now hated for the abandonment and unforgiving wounds he
someone to pick me up. Uncertain of who that someone would be I instilled inside ofme. He contemplated putting his arms out to hold me
assumed it would be someone from the juvenile delinquents division to but instead anger and shame took over and he just shook his head. Tnever
take me back to some state operated !ockdown facility. Not the nicest of saw my Dad cry until that day and I have to say it made me feel young
places to call home, but T had no choice in this matter. again and sad I had disappointed my parents again. The agents now
Sitting back in the revolving chair I was twirling out of boredom and standing beside us led both of us together back into the interrogation
listening to the roaming conversations within the office. I pondered in room to re-tale my journey to my father who they said I had no choice to
fearful anticipation of the dreadful places that lay in store for me. Having tell, or they would have to tell him for me, being I was an under-aged
to of spent a lot of my adolescence in these kind of places for the sheer minor and Ron violated the statutory rape law, among many others, when
factor that my mother said "I was out of control and unable to handle" by
he took me back to his apartment and kept me as his sex slave. My Dad
eleven years old. There was plenty of just reason for me to be so scared of couldn't believe what he was hearing and for his lack of better choice in
those places. What I knew lay in store for me were constant fights words asked me to stop talking, he was just happy to know Twas alive.
between the rough girls being settled with violent raids then out came the
Like everyone I'd known in life they would rather brush it under the
pepper spray and then the strip-searches and worst of all, no sunlight. It carpet and not deal with the pain rather than realizing sooner or later it all
didn't matter if you were a quiet, shy girl that didn't belong there, when comes out sometime in our life even ifit transgresses into our future then
there was a fight, which was could be like a few times a week, every becomes what we are willing to accept out of partners, work, and people
person in the room was considered a threat and were treated like a violent in general. Simply saying in other ways than with words that our bad
criminal. I hated those places and the memories they gave me. That's decisions befall our tragedies later on in life.
why I always ended up back on the streets. No child or even a juvenile The next discussion was led to where I would go to from here. Before
should have to be subjected to such unreasonable force and neglect. Some anyone could put his or her suggestion forward I leapt in with my two
of the girls were so used to being subdued to this kind of treatment their
bits and made it obviously clear to my Dad that if I was sent away to
17 18
another lockdown facility and ifhe betrayed my trust, again, he would conformity and unwilling to participate in their drilling regime. I didn't
never see me again. I would disappear for good this time and for all he feel like I owed any explanation to these people even when they brought
would know I could be dead in no time on the streets. He looked at me a physiologist in to speak with me, "What was the point when I would be
and for the first time in my life he saw the many years I had grown up in gone any day now" and as if any of these people even cared in the first
the time I was gone and heard the seriousness in the tone ofmy voice place, I was just another number in the system and they had a job to do.
when I made my vow to him. He put his head in his hands and told me There was one mega-bitch, female guard, named Evelyn and she used
the bad news, my Mom didn't want me to come home and she was to either really like you or really hate you and God-forbid you were one
making his life hell for even suggesting bringing me back into their lives. of the unfortunates that she didn't like, she'd make your entire stay their
I for some reason threatened her lifestyle and drove her crazy. I had been an agonizing nightmare. Constantly picking on girls who were not strong
surprised about a lot of things lately but not that one. The last time I saw enough to cope with their predicament or past issues, she'd stand them up
my Mom she ever so carefully lied to me and told me she was bringing and publicly humiliate them, and even when they begged her through
me to an eye-doctor for an infection. Instead we walked into this tall blue their sobs to let them sit down, she'd only torment them worse. Which
building with people in uniforms holding clipboards and a few muscly only made the strong girls want to antagonize the fragile one's with more
guards, she ushered me inside and hurried up to close the large auto lock malicious intent. Luckily when I had previously been there she didn't
doors behind her leaving me there alone and imprisoned, which is what take much notice ofme, but I stayed out of harms way with her,just
led me to recently living on the streets. My life was hell as long as she being quiet and observant.
was in control of it, so when she didn't want me back at home I was fine Being back here seemed like an eternity while I held my end of the
with that too, but there had to be somewhere else I could go. My dad said bargain but unfortunately my Father didn't. The first chance I saw to run
he had no choice but to put me back into the facility, but he made a I took it. I was being sent to go get my blood and urine taken for drug and
sincere promise that he would not take any longer than a week to try to disease analysis. My driver would be a volunteer from the community
find a place for me to stay and to go to school. A week I could deal with, and it was the perfect getaway for me. r was brought from the white
but I was still unsure ifl could trust my father and hold him to his word, solitaire room and led into the bright sun, feeling like today would be
but yet again, I had no choice. Being my legal guardian he could send me favorable in my escape. We got to the doctors office, my whereabouts
anywhere he wanted and there would be nothing I could do, except for told me I had plenty of ways to run and I scouted out the best looking
keep running. I gave in, and before he left the officers to take me back to route. My plan was to barge through the volunteer's inexperienced grip
the last facility I had run from, I gave him one last hug and reminded him and wriggle my way out if needed, then hit the asphalt, running until my
"one-week and I'm gone". Nodding his head and squeezing his arms legs couldn't carry me any further. Playing it out in my mind felt
tighter around me, I could only hope he meant it, but he didn't look too different to the anticipation that led up to actually doing it. The inner-
optimistic. strength I had was the only thing going to help me in this circumstance.
In the police car on the way back to the facility they had to handcuff me We arrived in the parking lot and I hadn't said a word to him the entire
in case I ran again, but I had no intentions to anyways. I was going to drive, the small framed Spanish man tried to make pleasant conversation
give my dad the week before I began to search for the right opportunity to but I couldn't see him as anything but a challenge, so I kept quiet instead,
jolt again. I was like a "ghost come back," said so many ofmy girlfriends i1:,'Iloringhis humorous attempts to befriend me. The car pulled to a stop
from the past and there was now a lot of new faces there too. At night and he came around the side to unlock my door, this was it, "here we go"
when we were all in bed and supposed to be sleeping, I would be I told myself, and pushed past the volunteer. His arms grabbed out at me
daydreaming of better days and imagine myself somewhere in a but only caught me by my shirt, he didn't even put up much of a struggle,
comfortable bed, actually enjoying my life for a change. A week went by like some of the other trained one's I had gotten before, they would put
in this facility spending most of my days locked up in what they called me into body locks of all sorts but he just tore at the collar of my shirt
"The White Room", a bare room with concrete flooring, no toilet or even letting me break free. I had done this many times before so I knew I
a chair to sit on. The only comfort I had was the blue sweater that was wasn't gone yet, I had to first get out of these clothes. The cops would be
provided as part of the uniform, and my hair scrunchie filled with my looking for someone of my description in the area with a blue shirt and
stowed away cash that no one had found during my unpleasant strip- khaki pants, so my first stop was a busy shopping complex. I took the
searches. I would spend hours in the white room for objecting to their money from my scrunchie and bought myself a pair of jeans, a shirt, and
19 20
a sweater for disguise and my next stop was Dunkin Doughnuts' to get a waited for me to come find her outback smoking cigarettes and having a
chocolate iced doughnut and a cup of coffee. I didn't have doubts about beer. She stood up from her seat and squinted her eyes loathing in her
getting out of the facility but I wasn't expecting it to be so easy this time. hatred she coldly slapped me hard in the face. The slap stung, but I
My past excursions all began with an abrupt struggle sometimes ending matched her look with a familiar stone-coldness that only she could
in a brutal state of affairs after being pepper sprayed and fastened into understand. Immediately we both started to cry and we washed away our
some painful lock by forceful men four- times my size, then tossed into anguish and resentment through our tears and consolidated our feelings
solitary until I saw my next chance to desert. I got to know the guards for the first time since the chaos first affected our lives. She didn't want
real well, as I spent a lot ofmy time being dragged down to the white to know much ofmy whereabouts and she still had a lot of anger to get
room by them. There was Jim, a large black man who could've doubled over but she asked me to stay home at least. My little brother ran through
for a "Miami Dolphin's" defensive linebacker. John was another big man the back door and hugged me so tight, I started to cry again and was
with a ponytail and a mustache, and he looked like someone who saddened by how much time I had missed the time I had lost just hanging
definitely owned a Harley. The last guy Scott had a smaller build but out with my brothers and it took me even longer to realize how precious
made up for it with his steroid injected muscles bulging out of his neck time really is. We were never going to be the average Joes next door but
and their was the added height from his curly fro. When they weren't at least this was better than nothing. I loved being with my family again.
restraining me and holding me captive in solitaire, they were actually We had BBQ's and hon-fires with each other and life began to slowly
pretty nice guys, not afraid to have a laugh after some explosive incident piece back together. It was bizarre how normal it was when I first got
and I held no contempt towards them either, they were just doing their home. I turned fifteen that year and it was the exact cup of tea that I had
jobs. needed to boost me up and get me on the right track.
It was de'ja'vous all over again, free at last but where would I go now. I decided to go school to acquire my general education diploma or G.E.D
With Ron's scouts on the lookout for me, and now the authorities being and got a summer job with my Dad at Mar-A-Lago, Donald Trumps
notified I was a runaway again, I would have a lot of people searching for exclusive country club in Palm Beach. Surrounded by lush acres of
me, so I knew I had to be careful where I went. My last stop before tropical landscapes, manicured gardens, and a mansion made into a beach
leaving the shopping center was to use a payphone to call my parents, my club for the rich and famous it is known as the "Jewel of Palm Beach". I
Dad answered completely surprised to hear me on the other end, I wanted was in sheer awe at the gold arched ceilings and the grandeur ballrooms.
to sarcastically thank him for breaking his promise to me and I hope he is The spa where I worked was world class, not only oozing in style but in
happy now, he just lost his daughter for good. I stopped to listen to what the way each and every clientele was treated with the upmost service. My
he was trying to say and he told me "I was getting you out in a few days, focus was now set on becoming a massage therapist, and working my
I found you somebody to stay with, she's a good person who has got way into a luxurious spa like the one I worked for now, only I was a
teenagers your age, I was just trying to convince your Mother to sign the locker-room attendant there. I studied many books about the anatomy of
papers to get you out of there". the human body and how you can affect a person's well-being and health
I was so outraged at her ability to put her own wants before the needs for the better through a simple healing touch. It was amazing to me the
of her own flesh and blood daughter. I told him to come pick me up and way the body responded to massage. I was more than just interested. I
bring me to the house so I could speak with her for the first time in over a was determined to become a therapist.
year, but if I felt threatened for one second I will be on my way quicker It was one of those anatomy books that I had my nose buried in one
than a blink ofan eye and on my own for good. He wasn't overjoyed at afternoon on a quiet Tuesday and it could get pretty lonely in the locker
my proposition, knowing what position this put him in as her husband but room, so if I weren't busy I'd sit outside by the spa's reception and read
as my father he decided to put me first for once and take me home to my books in the warmth of the Florida sun. A lovely looking woman in
confront my mother. her late thirties who spoke with a proper English accent approached me. I
I arrived at my house for the first time in a long time and everything assumed it was a general question, "like where's the ladies room or was
looked different. My parents refurnished and renovated the house. I didn't that the famous model from so-and-so?" but she was more interested in
even have a room anymore, my old belongings and bed were removed the book I was reading. Only believing at first we were just making small
and it was now the office. Of course my Mom didn't meet me at the gate talk she was really intrigued at my choice ofreading. She then asked if!
or the front door like her long lost offspring reunited. No, instead she
21 22
did massage on the side, 1 stated I was only reading the book and had not ever pleasantly. She said the boss was upstairs and waiting my arrival, so
yet began to study but one day I would love to practice massage therapy. with that I said bye to my dad and began to follow Ghislane up the stairs.
She introduced herself as Ghislane Maxwell. I would later find out that I was so nervous, but I didn't show it. I kept my reserve and demeanor
she was the daughter of the late prominent businessman and disgraced cool as ice, trying show maturity for the open position. We continued on
newspaper tycoon, Robert Maxwell. I told her my name is Jenna pointing to the massage room, passing by a grand crystal chandelier, and a couple
to my nametag on my shirt and offered her a cold or hot beverage, as lengthy wooden hall tables displaying a multitude of photos displaying
those were my instructed duties at work. She accepted a tea and went on young girls and beautiful women, trying not to gawk at them I didn't
to chat a bit about this rich guy that she worked for and she knew off- even notice that some of those girls were only wearing their smile.
hand that he was looking for a massage therapist. Just doing me a good Ghislane asked me how my day at work was and I told her it was easy
deed out of her kindness of her heart, I'm sure, she offered to introduce peasy as always just trying to make simple conversation. There was a
me to him. I declined her first proposition, thinking out loud, told her I fork at the end of the staircase and she led me to the right hand side. The
didn't know the body well enough to even attempt an interview. She lights were dimmed in the bedroom but I could still see the King Size bed
didn't seem worried at all by my fear of incompetence saying that ifhe in the middle of room, we did a U-tum around the bed, which led us into
liked me enough he would get me the best training in the industry. a massage room. Dripping in luxury I could've definitely compared it to
Ghislane thought I had a cheery persona and fit the quota for what he was the renowned Mar-a-Lago 's spa's, it had marble walls and a glass
looking for and as she put it an enthusiastic learner that she said she enclosed shower and self-automated steam room at the very end of the
gathered from the sticky notes popping out of the various sections in my Burberry carpeted room. There was a large mirror over a basin to the
book. I accepted her phone number and the house address and told her I right of the room with an array of oils, ointments, soaps, and lotions and a
will call her if I am able to come over after work. I rushed over to the small closed door, which I assumed must be a closet. The only thing that
tennis courts where my dad was working and told him of the news. We struck awkward about this room was the naked man laying face down
both thought this could be a wonderful opportunity to get my atop of the turquoise massage table in the center of it. "I had to be
accreditation in massage therapy. Seeing that it was a lady in her late prepared for this," I told myself Massage was something I had never
thirties who came off as more of a nurturer rather than a procurer, neither done before so I quickly brushed away my thoughts of possible schemes,
ofus saw any reason to be hesitant. wanting to believe whole-hearted this was going to be legit. Ghislane
introduced us to each other and 1 proceeded to make his acquaintance.
Chapter 4 Looking up at from his downwards position, he looked me over and
gave a smile to Ghislane, an obvious notion of his approval. He was
At around Five p.m. my dad drove me down to the bottom of"El Brillo Jeffrey Epstein as she pronounced for him, as if I supposed to recognize
Way." on the Palm Beach intercostal. We pulled into a short driveway his name or something. He affirmed, "It was his pleasure" and replied to
just call him Jeffrey, "No need for formalities" he answered, cleverly
beckoning a large pink mansion with heavy wooden doors. I was so
putting me at ease. This man did not look like someone to beware of.
excited about this chance and asked my dad to wish me luck. He gave me
Both him and Ghislane appeared to be very nice people and conscious of
a big squeeze and wished me the best. He walked me to the front door
their health as their need for massages and spa visits, no alarm bells went
and I rung the door chime. Moments later we were greeted by an older
off, yet. I was prepped by Ghislane to "treat this as a lesson from her and
gentleman dressed in a casual butler uniform. I told him I was here to
meet Ms. Maxwell for a massage trial and he opened the doors for my follow her exact lead, ifT did good tonight then maybe I would become
Jeffrey's Travelling Masseuse, seeing the world and getting paid well for
father and I telling us to wait in the entry as Ms. Maxwell would be on
it". I was very hopeful, a job like this could really make my dreams come
her way any second, and she was. Down the stairs she walked with a
warm smile, her short black hair seeming very proper and elegant, for true.
1 followed suit and washed my hands with warm water so the coldness
now. She shook my fathers hand and thanked him for bringing me and
would not shock Jeffery's naked body, then lathered them in rich body
kissed us both on the cheeks. They spoke briefly about whom she worked
butter. Ghislane told me to always keep one hand on Jeffrey, even when
for and about Mar-a-Lago where we worked. She was in hurry, you could
getting more lotion, so it didn't make him lose concentration on being
tell to end the conversation and say good-bye to my dad, which she did so
relaxed. She gave me a tip and told me to keep a blob oflotion high up on
23 24
my forearm so it prevented me from having to keep going back for more "what have I been trained up for until now". Nobody ever stopped to ask
and was less disruptive to Jet1rey. This all seemed for real to begin with, I if I was comfortable or if I wanted to stop, no, instead, Ghislane only
was being educated about the body and splitting Jet1rey's body with directed me to conclude the massage session by climbing up on the table
Ghislane, mimicking her every motion. Starting with his feet, we began to be fixated on Jeffrey, straddling him so he could penetrate me.
with his heels and arches of his soles. Pushing the blood up his calves in When it was all done and over with, I was taken into the steam room
upward strokes to rejuvenate the body's blood supply and being careful to with just Jeffrey to get further aquatinted, as Ghislane left the room to go
mind his leg hair didn't pull. I was keeping up with her and enjoying the get dressed. He asked me to grab his feet and rub them not saying a word
education. It was so interesting how the body worked and I couldn't about what just happened, like it was all normal and accepted. I listened
believe I was learning all of this for free. Once I got a bit of a groove to him ramble on about the health benefits of a sauna and the history of it,
following Ghislane, they began asking me all sorts of questions about my ignoring the fact of the matter of his pretentiousness degrading my spirit.
past and it didn't take long before the conversation led down the darker I figured I had gone too far already, what would be the point in throwing
experiences ofmy young life. When they found out that I hadn't led in the towel now after I had done exactly what these people wanted.
much of a normal existence they only probed me with more questions, Whilst we were sweating out our bodies' toxins, and the steam was
which being put on the spot answered honestly. The funny thing was they blasting my burning face I listened to his lessons, entertaining his ego, I
didn't seem appalled at all by my statements, rather entertained if let him become my teacher, he seemed to like that. He sounded like a
anything. Jeffrey called me a "naughty-girl" with that wry smile of his, very clever and intelligent man though. Telling me his story of how he
and half playful and half defensive, I answered "no I'm not, I'm really a made himself an empire of billions from being a middle-class professor to
good girl, just always in the wrong places" he then replied, "It's O.K, I an elite financial advisor for clientele with only billions in their bank
like naughty girls" and rolled over onto his front side to expose his accounts and through his so-called "lessons", He became my mentor and
complete nude self. He wasn't the first man to show me his penis, so I I emerged as his pupil, the teacher's pet.
wasn't shocked at the appearance of his manhood but I was incredibly After the sauna we went to the next glass door beside us where the
shocked at his complete ease to present himself with an erection. I tried to shower was. He turned tap outwards and stood underneath the water as I
ignore it waiting to follow the next directions off of Ghislane, who stood naked and cold from the temperature difference. Instead of asking
surprisingly now stood behind me bare breasted. Before I had a chance to me to join him under the warm stream, like I thought he was going to, he
even think of replying hastily she began to slowly undress me, while handed me a bar of soap and asked me to wash his body from top to toe.
Jeffrey started to stroke his manhood while watching us. She unbuttoned It didn't stop there I had to massage the shampoo and conditioner into his
my blouse and removed my bra, revealing my bosoms. Cupping them in scalp as well. I was bewildered someone would ask this off of someone
her hands she moved her lips across my nipples, licking and teasing them else, wasn't it belittling enough having to endure the illicit massage from
with her tongue making them cold and stiff. Next her hands moved down beforehand but now this. The surprises kept coming that night, as this
to my little white skirt, removing the final piece ofmy remaining was definitely not how I expected my interview to tum out, but that's
uniform. She slid my skirt down my legs with ease, for a moment keeping what I had learned in my short time on this earth, life was full of
on my love-heart panties, so they could both take notice ofmy apparent disappointment.
youth. They even snickered to each other about " How cute she still wears I let everyone else take the power of authority from myself and use me
little girl pantie's" Jeffrey said, and Ghislane joined in his laughter. in whatever way he or she wanted instead of standing up and giving
Acting as my madam, she instructed me to start by licking his nipples myself the respect I deserved, which in tum would've helped me get
and after I had sufficiently pleasured both of them, then prompted me to through life without all of the abuse I ended up copping. Not given the
go down on Jeffery orally while she rubbed her breasts along his body belief in myself from an early age on I suppose is what affected my sense
tantalizingly. She moved behind me again this time to remove my panties of control. Always letting the one's with power and strength reduce my
and start fondling the delicate folds between my legs. I was still in shock inner-self to shreds until l was cut so tiny in size I would be completely
from the initial degrading blow. I hadn't even let the reality sink in, it was subdued to only their wants and needs left ignoring mine. The men I had
all too much for me to emotionally handle so instead I hid behind my encountered in my short experience with them only repeated their
fears, which I told myself "I wasn't going to ever be worth anything at all inflictions convincing me there was no running away from the sick world
and this would probably be as good as it gets for me" after all I thought, I lived in, not yet understanding it all came down to the choices I had
25 26
made for myself, I needed some encouragement and the right words to About to be entrapped in the same life I had broken free from only
unlock my very soul. months ago.
Jeffrey told me the towels were on the heated rack just outside the Convincing myself in order to succeed I had to step up from being a
shower and asked me to get one and pat him down. Again putting himself girly teenager and start thinking like a young woman, it would be my
first as I sat there freezing while I compliantly patted down his body with ticket to a great career and a fortunate life. I told myself"So what if I had
the white fluffy towel until he was dried. I nearly expected him to ask me to bargain my body to this rich old geezer, some girls get themselves
to dress him as well, but not surprisingly that came later down the track through college by becoming a stripper and using their bodies to pay for
too. I dried myself off and wiped the make-up from under my eye's, degrees, others go down even worse paths." I guess it was just another
keeping quiet not sure what to really say and half-embarrassed from the way to fathom the road I was going down, the effectiveness of the lies I
entire evening's events that just took place. I just remained silent whilst forced myself to believe was working as I continued to tell myselfI had
we both got dressed until he brought me downstairs where Ghislane was to make it any way I could rather than ever letting myself sleep on the
sitting at a desk holding his black leather duffel bag. When she moved streets again. I was trading one shocking lifestyle for another, thinking I
from the chair to let Jeffrey sit down, she passed him the bag and began was choosing the right one. If I could go back in time to ever meet myself
to tell me that I had great potential to be a massage therapist, they really I would choose this time in my life. I'd start with a good hard smack to
liked my style and who knows where this could lead too. She asked to see my head to first shake some things up in there and next I would tell that
me again tomorrow, same time after work. He opened the bag, revealing girl she could actually make it on her own if she just worked hard at
stacks of brand-new hundred dollar bills separated with rubber bands to earning an honest wage and built her life up slowly. There is no rush or
count by the thousands. He grabbed one stack and took out two crisp time limit to ever stop reaching for achievement. Sadly enough I probably
notes, placing them in my hand. He laughed that it was nearly my whole wouldn't of even believed myself anyways, learning my life's hard
week's wage at Mar-A-Lago. Only there I didn't have to degrade myself lessons through the experiences I continued to suffer.
as his new little toy. I went to work at Mar-A Lago that day trying hard not to think of what
When I got home my parents were anticipating my arrival. I kept it lay ahead in the afternoon too come, but the later the hour got the more
simple and sweet with my folk's, only telling them of the lessons about distinguished the knots became in my stomach. I spoke to no one of the
the body I had received and the future prospects in massage therapy that details to my explicit interview but told one girl how I was so happy I
lie ahead. Nobody questioned who I was working for and complimented was now officially studying massage therapy, another lie. My friend was
my ability to be a hard worker. I quickly got out of that conversation surprised and intrigued that these people who could afford the best of the
afraid I might give away a hint of shame in my eyes but no one caught best of therapists in the world chose an untrained fifteen-year-old girl to
on. I excused myself to the bathroom to have a shower and stared into the perform a massage. She never said it in words, but her body language told
mirror for a moment, asking myself if I could really go through with this me she knew exactly why they wanted to use me and it wasn't for a
only to mentally respond by reminding myself this would be as good as it therapeutic reason either and deep down inside I understood.
gets for a girl ofmy stature and limitations. I scrubbed myselfrigidly in The rest of the afternoon slipped away quickly and before I knew it I
the shower as ifit would wash away the filthiness of the night, but it was standing before those large wooden doors again, giving a moments
didn't help, I could still feel their hands in me and all over me and inside pause but long enough to draw in my breath and exhale some of the
ofme. Trying to sleep that night was nearly impossible too, closing my anxiety before ringing the doorbell. Juan answered the door again and
eyes only to drift away to flashbacks of the moments I had to give myself told me Ghislane would be down in a few moments and asked to follow
to Jeffrey and Ghislane, each replay an exploitation of my vulnerability. him into the kitchen. There was a pleasant looking young girl with blonde
The next morning I awoke feeling anxious about the day ahead, trying to spirals in her hair that glanced up from the mound of paperwork before
push yesterday's memory from my thoughts, I was quiet for the whole her. Her shocking blue eye's and appealing English accent seemed
trip to work with my Dad. Before we got out of his car in the parking lot delightful and she introduced herself as "Emmy", Ghislane's Personal
he asked me if everything was okay, I lied, for his sake and mine. My life Assistant. I introduced myself as "Jenna" which is what most people
was being transformed and I didn't even know it yet, but soon enough I knew me as and told her I was on an employment trial to become
would be a brainwashed tool only used for the sexual pleasure of others. Jeffrey's massage therapist. She had a coy smile on her face that told me
she knew exactly what I was on trial for. Something in my b'llt told me
27 28
this wasn't the first time a young girl had been trialed for the same and temperamental in the seconds that she appeared. She told me I would
position I was about to fill. be on my own today as she had business to attend to, so make sure I
We were only chatting for a moment before Ghislane appeared and told remembered what she had taught me, as my trial depended on it.
me Jeffrey was ready for his massage. I was led through the extensively
large house to the winding staircase that would lead me up to the same Chapter 5
dreaded room where I would have to re-enact last night's performance. I
wasn't far from wrong. I gave Jeffrey a massage with Ghislane leading
the way again, this time we surprisingly made it to the front of his body
I walked up the stairs by myself this time, taking in more of the decor,
and she continued to show me how to massage all the way up to his noticing the more I looked around the more I noticed a different girl in
stomach pushing my hands in a spiraling clockwise circular motion to not each photograph in his collection of half-nude and topless girls on display
disrupt the bowels and then we came up to his chest. He couldn't dare
around his mansion. I couldn't believe how many girls there were, it's not
contain himself for one second longer, telling me to put my lips on his
like Jeffrey was much to look at. He was an aging man in his early fifties
nipples and give them a kiss. Jeffrey moaned in pleasure and Ghislane
with shiny grey hair and characteristic lines drawn down his face as ifhe
started to undress me from behind. Within moments I was completely
had seen harder days. With no prospects of ever settling down or having a
naked and Ghislane had her top off. She was caressing my body with her
family of his own, Jeffrey treated us girls like a piece of clothing he could
hands while Jeffrey moved his hands down to stroke his loins while he
try on for the day and get rid of the next. So why was there so many girls
watched her and I kiss and touch each other. I didn't know if she was
in these photo's? I wondered to 111yself if I would end up one of those
doing this for the sake of his eye-candy but she sure did act like she loved
girls among his collection of forgotten relationships and broken promises.
having the control over me telling me what to do throughout the entire I continued to make my way up the stairs, and as if all of my senses
threesome. Jeffrey's climax was always the end to our sessions and this
were heightened from my bare nerves being exposed, I could smell the
time he wanted to have me make him orgasm orally. Afterwards we went
cleaning detergents recently used by the housekeepers, my observations
for the ritualistic steam-room, this time Ghislane joining in with us for
of the shade oflighting through the concealed blinds as I entered Jeffrey's
conversation. She asked me to massage her feet this time while we were
bedroom appeared golden, and the sound of stillness except for the thud
in the steam room, showing me that Jeffrey wasn't the only one I had P?Y ofmy rapid beating heart all made me more aware of how nervous I was
my homage to. We all had a shower next and then we all went downstairs
to be on my own. Not that Ghislane was anything of a comfort, but I
to pay me and have Juan drop me off back home. didn't know what to expect or how I was going to lead myself into
The following afternoon I received a call at work, surprisingly it was
upholding my obligation in pleasing him. I would hope for the best I
Ghislane asking me to come over when I got off of work again. The thought, trying to uplift my confidence as I opened the door to the
compliant side took over and I told her I looked forward to meeting with
massage room with the typical scene of Jeffrey laying naked facedown in
them today, instead of telling her to go screw herself for lying to me and the massage bed waiting for his entertainment. It was de'ja'vous' all over
making me degrade myself more each time I saw them. I finished work again. Repeating what Ghislane had taught me, with him commenting on
for the day and my Dad brought me over to El Brillo Way again, where
what else I should be doing, until it got to the end and I was expected to
the vultures were patiently waiting in their lair, he wished me well as I grant him all of his spoken desires. We finished up with the shower again
hopped out of his big truck, looking ever so much like his little girl again.
and he seemed very pleased in my contribution of myself to him, giving
I gave him a smile and a wave as he drove down the long driveway, in to every request.
waiting for him to suddenly tum back and not leave me alone to my task.
He told me to go ask Juan to pay me, as he was lethargic after the
I shook myself out of that calamity and put on my "big girls" face.
massage and intimate affair between us and now was going to have sleep.
Juan brought me to the kitchen again as I waited for Ghislane. He
I walked back down stairs and told Juan that Jeffrey was asleep and said I
offered me a cold drink and some fruit on a platter, I accepted and was
had to ask him for my pay. He went to Jeffrey's desk and took out the
grateful for the rejuvenation before I went to work again. It wasn't long
exact amount I was owed without even asking how much I normally get
before Ghislane approached me from behind with a cold intense look in
paid. He then drove me home, only to be back the next afternoon.
her eye. I jumped from my seat, feeling like maybe I shouldn't have been
eating and drinking while on the job, as her demeanor seemed annoyed
29 30
The following week was a daily routine, providing Jeffrey with wall's built in jets. There was a bench coming out of the wall also made
massages and continuously being groomed to fulfill all his needs. Often out of marble that went from either side of the room and had a step
joined by Ms. Maxwell and her assistant Emmy for sexual trysts of all underneath it where I was instructed to sit on so that I could begin giving
kinds. I was mentally and physically exhausted from the week of working Jeffery his massage. Our conversation started off about simple things like
and having to keep up with Jeffrey's strenuous late night activities. I how was your day at work, and I asked Jeffrey how his day was lounging
couldn't believe what I was doing but it was all starting to sink in fast. around, just being polite to each other. He was acting out of character
Most nights when I got home, I'd briefly say "Hi" to Mom and Dad being a lot more attentive and conversing with me about other things than
before heading straight to my bedroom. I couldn't even sleep well sex or massages for once. Starting with his heels, ankles, toes and arches
anymore. Closing my eyes at night I would fight the inevitable flood of in the soles of his feet I massaged all the way up to his calves. It took a
thoughts, replaying the moments of shame that ate away myself piece by lot more strength to massage in the steam room without oils or lotions
piece. My only reasoning being I just had to keep telling myself it would and the constant blowing of steam in your face making me twice as
all be worth it in the end. exerted. I was beginning to really start to heat up when the door to the
This afternoon Ghislane appeared to be in a much better mood. Instead room suddenly opened to reveal two naked women. Ghislane and Emmy
of taking me straight up to Jeffrey she took me to a yellow guest room acted as if they came in to join us for a steam bath, but my instincts were
where Emmy mostly stayed. It had a balcony where Emmy was already telling me otherwise. At least the cold burst of air and escaped steam
outside reading a magazine and puffing on a cigarette. Ghislane lit one up revived me a bit.
too and then offered me one. I hadn't smoked cigarettes much before, So there was Jeffrey and Ghislane sitting on top of this marble bench,
besides trying to look cool in front of one of my friends, but never really each with a young girl at their feet. Emmy and I continued with the
took to them, so when I started to cough from the inhalation of smoke, massage until they were ready to head into the shower. There were two
the girls began to laugh and joke about my in-experience. It was an showerheads that Ghislane and Jeffrey both stood under while they were
icebreaker for all ofus to laugh and poke fun at me. I was then able to being lathered with soap bubbles as we washed their bodies. After the
give it back to them saying I would rather be an in-experienced non- shower Ghislane led us into Jeffrey's bed to finish today's session with
smoker than an old lady with a raspy smokers cough. I don't think Emmy, Ghislane and I performing lesbian acts of foreplay on each other
Ghislane was used to somebody giving it back to her, but she seemed to while Jeffrey laid back and watched. Stroking his manhood in much
like it, as long as she was able to have the last say. I knew my boundaries delight, he brought himself to climax, and the session was over within
and she liked that I wouldn't cross those invisible lines. All three of us moments. We all got dressed and went downstairs to the kitchen for some
chatted like friends and it started to feel like some kind of a strange refreshments. Like nothing had happened at all, it was all so bizarre for
relationship was budding. After about fifteen minutes of chatting away, me, the whole ordeal with them since this all began. I couldn't understand
Ghislane instructed me to wash my hands thoroughly, as Jeffrey hated the why Ghislane and Jeffrey had such an openly intimate relationship but
smell of smokers, and to follow her down the hallway to the massage yet never regarded themselves as partners. They rarely kissed and never
room where he'll be expecting me shortly. I did what she asked and held hands or even slept in the same bed. It was more like a sexual
sprayed myself with the body spray that I always carried in my purse and arrangement between the two of them. She brings in the girls for his
headed down the hall to Jeffrey's room. peculiar taste and he supplies the lavish lifestyle she was accustomed too
When I opened the door to the massage room surprisingly it was empty. before her family lost all of their fortunes. I wasn't sure how to act or
I sat down on the already made up massage table and was careful not to feel, always obliging to their needs but reserved enough not to get
mess up the neatly folded towels on the end of the bed. It was a good attached, as if there was this invisible hierarchy and by instinct I knew
fifteen more minutes before Jeffrey made his appearance. It was strange my place.
seeing him in clothes for the first time. He wasn't wearing what you'd We all hung out in the kitchen for a while before I asked when Juan
expect your typical billionaire's attire to be. He was wearing a pair of could bring me home as I had work in the morning and was tired. They
sweatpants and a Harvard sweatshirt, which he began to remove said no problem and called Juan on the intercom right away, but said
immediately. This time he wanted to commence our session in the steam we'd all have something to talk about tomorrow. I knew it had something
room, so I began to undress as well. We went into the steam room and he to do with my employment trial and from the way they were acting
pushed a few buttons and the steam began to pour in from the marble tonight, I could only assume I got the job, but you never know with these
31 32
types of people. Their friendships and partnerships can change like the James for a bit of relaxation. The temptation of his grandeur offer wasn't
weather. hard to give into, my vulnerability to be lewd into his grasp seemed
I went home that night still confused on how I could let myself sink so comforting at the time. The idea that females were nothing more than an
low, I had to put on an act like I enjoyed submitting my body and being empty shell of beauty bound by only a body to offer was a notion I had
their new subservient plaything all for the fact that I was making accepted a long time ago with my first teacher, Ron.
anywhere between $200-$400 for just a couple of hours. Then spent the My reaction had to be more than amusing for their egos, even though I
rest of the night regressing on the entire event in my head over and over was excited to be traveling I could only imagine the likeliness of having
again. I battled those thoughts with the hope that I was receiving a to be at their beckon call as well. In my head I just told myself we all do
profession out of this and making good money in the meantime. All I had what we have to do in our lives to succeed no matter what it takes, and
to do was keep lying to myself long enough until I eventually believed it. with no one knowing the truth, I had no one to talk me out of it. I
Arriving at Jeffrey's on time the next afternoon, as I always did, accepted his offer and knew from here on out I would be his servant to
understanding punctuality was a sign of respect and I wanted them to feel his sexual desires until one day I would gain my credentials and only then
as if they had my deepest appreciation for the once in a lifetime chance could I go out on my own and make it in this world that when so young
they had given to a girl of my history. This time when Juan answered the seems so unconquerable. The night advanced into the usual grooming of
door he told me Mr. Epstein and Ms. Maxwell were waiting for me his requirements, for the next hour and a half being exploited to satisfy
upstairs in the massage room. I began my hike up the familiar spiraling Jeffrey's every sexual whim.
staircase and through to the room where my arrival was being deeply My mom cornered me that night, before I had a chance to avoid
anticipated. They were already in the steam room awaiting me to join speaking to anyone, heading to the shower then my bedroom, like I had
them. I undressed out of my unifonn and folded them in a neat pile, been the last week. She knocked at my door with a hostile look in her
which I placed upon the marble basin. Having one last look in the mirror eyes, "Virginia, what exactly does an older couple want with a fifteen
before I exhaling a deep breath as if I was plunging into deep water, I year old girl, who has no credentials and with no experience in massage
knew today was a big day. I either accepted their offer and trade my therapy?" She used that stern tone of voice that she's always had, when I
morals for opportunity, or walk away with the prospect of one day many was in trouble.
years from now trying to make it on my own which I knew endowed Thus, as impressionable as I was, my blue eyes batted their innocence
hardships of there own. in her direction and I flashed her a girlish grin selling her the pitch that I
So confused about what decision to make, I just opened the door to the had been given earlier that night. Not mentioning the other side to the
steam room and let them do the talking. Used to the routine by now I sat glamorous lifestyle I would soon be living in. I told her about the money
below Jeffrey and began to massage his feet and legs as I listened in on I'd be earning, the places I'd be seeing, the people I could meet and most
their ongoing conversation about travel plans for the next few weeks. of all the trade I'd be learning. It all sounded so good, except it was a
Ghislane and Jeffrey turned their attention to me and he asked me how bunch oflies I had to tell her and myself to otherwise convince us, that
would I like to go see the big city of Manhattan. I told them I had never this was a once in a lifetime opportunity, and I had to take it.
visited New York before and it sounded like an adventure but my job at She asked when all of this would start, and I as shocking as it was to me
Mar-A-Lago was only a summer job and wouldn't be able to get the time too, I told her I had to go start packing. We were leaving the next
off, especially that summer was so busy anyways. morning off to N.Y.C. At fifteen most girls would be sucking up to their
Jeffrey then made his announcement, that I should just quit my job at parents to go to a high-school dance or to go on a date to the movies with
Mar-a-Lago and become his permanent travelling masseuse. He then a nervous chap, but I wasn't even asking her. I was simply letting her
further persuaded me with all of the luxuries that came along with my know that I would be away for the next couple weeks, maybe three and
acceptance. Rather than being paid $9 dollars per hour at my current job I would keep in contact when I got free time. Her daughter was lost a long
could be earning $200 dollars per massage, which he even said could be a time ago, and she just now realized it. Backing out of the bathroom, with
few times a day. Tomorrow we could be leaving Palm Beach together in nothing she could say, she left me wondering to myself who I was
his private jet first heading to his residence in the upper east side of becoming.
Manhattan, also the largest mansion in N.Y, and would next be setting off Instead of driving me to work the next morning my Dad dropped me off
to the Caribbean, where he owned a secluded island just past Little St. at Jeffrey's mansion, he told me not to worry about calling Mar-A-Lago,
33 34
he'd take care ofit for me. We said our good-byes outside in the often found it hard to sleep and was comforted in the early morning hours
driveway, Jeffrey even coming outside to meet with my father to shake with his literature, or sometimes in other ways I would come to find out.
his hands and assure him that his daughter will be more than looked after. There was a mantle piece and a sofa with two armchairs next to the grand
I hugged my dad tightly, feeling like I was on the verge of a steep cliff, piano that flaunted more of Jeffrey's beautiful conquests, young women
when he let go, so did the last of my innocence. posing in salacious pictures, suggesting I could be easily replaced next to
Juan drove Jeffrey, Ghislane and I to Palm Beaches' Private Airport one of those girls if 1 failed in keeping him satisfied. There were also
and the luggage handlers escorted us on the tar mat where we all boarded some pictures with recognizable political and royal figures either shaking
on Jaffrey's black jet. Larry was his main pilot, he had shiny grey hair Jeffrey's hand, or with an arm around each other, even one with Jeffrey
and long lanky legs, but a very sincere smile that instantly made you feel and the Dali Lama, although his church was the bank. He liked to use his
at ease. He greeted us at the staircase tl1at led into the main cabin. It was power, wealth, and money to manipulate everyone in his life.
as lavish as I imagined it would be. The seats were enveloped in the finest He made a phone call that sounded business like and I didn't mind, I
beige leather with polished wood grain finishes and there was a kitchen in was quite enjoying taking in all of the beauty around me, I was blinded
the back with an adjoining toilet. Jeffrey saw the amazement in my eyes by all ofit. I was still waiting for him when, Ghislane came in. She asked
and to make it more thrilling he brought me up to the cockpit and let me me what I thought so far ofmy trip to N.Y.C, I knew she was talking
watch with a bird's eye view of the take off. I was on a natural high when about the house, she loved to gloat, even though none of it actually
I came back to the cabin and was instantly brought back down when belonged to her, she wanted everyone to believe that it did. I
Jeffrey rested his bare feet on top of the reclined seat and instructed me to complimented her on the mid-evil looking tapestries and a few other
get to work and start massaging him. My future was in his hands now, so adornments, when she cut me off mid-sentence to compliment it herself,
when he wanted something, I wouldn't hesitate in giving it to him. telling me the history about one of the 17th century tapestry's which to an
unsophisticated eye, looked to me like a rug on the wall.
Chapter 6 Jeffrey hung the phone up and walked over to the sofa where we were
sitting next to the mantle piece and took a seat on one of the armchairs.
He didn't seem worried from the phone call but his mind was definitely
somewhere else from the hard look on his face. We all spoke for a few
Upon our arrival at New Jersey's Private Airstrip, the driver Jo-Jo met
moments more about the splendid decor before Jeffrey had enough small
us. His name was most likely shortened for something of his oriental
decent. Jeffrey liked to shorten the names of his multi-cultural staff into talk and needed some of his own relaxation time. He told Ghislane he
was going to show me to the massage room and he'd be back in a couple
American names. Even Juan and Maria were known as John and Mary.
hours. She agreed he looked like he could use some time to unwind and
We arrived in the Upper East Side of Manhattan. His principal place of
with that wry grin of hers, she gave me a look that told me precisely how
residence was the largest home in Manhattan, eight stories of opulence. It
used to be a Private School for boy's many years ago, until Les Wexner, he was expecting to be relaxed.
We left his office all together, Ghislane going downstairs, and Jeffrey
Jeffrey's best friend and mentor bought it for him as a mysterious gift.
showing me to the lifts. The lift looked like it's original that came with
There were two large Chinese gargoyles outside the entrance, and
beside the heavy looking wooden doors there was an intercom with a the school. It was made out of brass antique with archaic cuts throughout
the arches at the top. It wasn't the only lift in the house, but certainly the
camera overlooking us. I walked up the concrete steps into a realm of
wealth, glamour and most of all influence. My eye's glistened at the most beautiful. We walked down a long hall carpeted in a royal red and
golden trim, passing by a bronze pagan statue of the horny little goat God
splendor of his palace. Caramel colored marble tiles spread through the
"Pan". How adequate, I thought, fit Jeffrey to a tee. We walked into this
first floor, where his gounuet kitchen and dining hall were also located.
dimly lit room. Another daunting chamber that looked like we had
Then I came to this sweeping staircase that curved into the next level
stepped back in time to the dark ages. It took a second for my eyes to
where Jeffrey and I went into his office, even though it looked more like
adjust to the darkness, and Jeffrey beckoned me to follow him through
a museum exhibit. Ancient draperies that told lascivious stories of their
the room to the open adjoin shower, toilet and steam room. The room was
own covered parts of the elevated walls, and the remaining wall spaces
in black marble to accent the dreariness, and smaller than the one in Palm
were taken up by rows on top of rows of books. He loved to read, as he
35 36
Beach, but it had it's own witchery feel to it. Another unseen side to this into the artistry, the intercom buzzed on the telephone next to the bed and
Man I was coming to know. it was a housemaid letting me know Jeffrey wanted to see me in his office
We both undressed and I followed Jetlrey into the steam room first. He now. "Already" I thought to myself: I was just getting settled in. I was
loved feeling clean, teaching me that the steam would deplete the toxins worried I was going to get lost in this ancient museum, but I got myself
from your skin, which was great during a massage when your blood flow back to his office with no trouble, it was kind of hard to miss. I knocked
is being replenished. I grabbed his foot out of instinct, knowing I had to at the slightly ajar door and Jeffrey called for me to enter. I walked over
be constantly on alert to keep this man satisfied. He looked down at me to his desk, where he was just ending a phone call and he opened his
with a nod and reclined back against the wall as the steam pored in, this duffel bag full of money. "I'll be out at my other office for most of the
was his idea of alleviation. I worked up to his calves and within a few day, so instead of being locked inside I thought you should go do some
more minutes, he said he was ready for his massage on the bed. We got sightseeing for the day since it is your first trip to the Big Apple" He
out and towel dried oft: both still nude, he asked me to stay undressed, didn't count how much he was giving me he just handed me a bundle out
then we headed to massage bed in the middle of the room. He lay down of the banded $100 dollar bills. He knew just how pull the right strings,
on the bed and told me to tum on the CD player on the wall hutch, where making me squeal in delight and give him a kiss in the cheek, since we
all of the oils and lotions were set out, I hit play and a collection of mixed were never really emotionally intimate, it would be odd to act in any
classical symphonies began to fill the silence. I could tell he wasn't in other way, but he seemed to like it.
one of those moods to be uplifted with idle chat, so I remained silent, I ran upstairs to get dressed for "City" shopping and put my make-up
letting him enjoy my slow movements, making my way up his body. My on, then hit the streets of N.Y.C, looking for a place to start spending this
instincts told me I was right about his mood, as he seemed to appreciate load of dosh. When I got to the end of 72nd street on 5th Avenue, I had no
the quietness of moment and the leisurely of the strokes I was using to idea which way to tum, left or right. I thought I'd just follow the lights
massage him. When I got to his scalp he turned over, and b>rabbedmy past Central Park and see the local sights on my way. My eyes were once
hand to put on his erect manhood. No words spoken yet, I took the again peeled back in splendor. I had never imagined a place so busy with
gesture and initiated what I had been taught over the last week. While the hustle and bustle of all the walks of life. My first stop was to buy a
pleasing my master his hands groped my young flesh, penetrating my disposable camera and I was off taking photos of every wonder that
insides with his fingers, he was only concerned with what he wanted, as caught my attention. I didn't do much shopping as I had planned too; I
If I was a new car out for a test drive and he was pressing his new was having too much fun exploring this capacious metropolitan.
gadgets. His soft moans were soon brought to louder heaves of breath and When it started to hit dusk I began walking back to Jeffrey's but not
my job was done. No intimate kisses, or sweet pillow talk. He showed his before stopping off to enjoy a giant slice of pepperoni pizza, it was the
appreciation with money, never attachment. We concluded with a shower best I had ever had, and considering I was going back to Jeffrey's
and he told me he had some business to conduct. He walked me to the lift chickpea and tofu salad's or such. I really hated the healthy cuisine
and told me go to the next level and my room was the first one on the served by Jeffrey's personal chef. I was a naturally skinny girl, never
right, it had an intercom in which he can contact me when needed. watching what I ate and to eat that food I might as well have chewed on
I hit number 5 on the lift and took his directions to my room. I opened hay. I strolled back to Jeffrey's and was missed. Ghislane scolded me
the door to this massive loft, the size of an adequate house. I walked "You shouldn't have been gone so long young lady", "We need to know
down the long hall and my eyes took in the magnificence ofmy where you are at all times, you are on call for Jeffrey" I started to
surroundings. It was a room fit for royalty, and later would find out had apologize, feeling guilty, I didn't want them to think I didn't take my job
been stayed in by some. The room was trimmed in gold paint and had with them seriously. She cut off my explanation with a short conclusion
another eerie tapestry on the main wall as feature. There was a T.V and a to this conversation "We will get you a cell phone tomorrow, so we can
huge king sized bed, with goose feathered comforter and pillows. always find you". I thanked her for her generosity, and she dismissed me
All of the glitter from Jeffrey's lifestyle he was offering me finally to my room. So I wasn't even needed after all, it was just a way for her to
covered the last bit of sight I had left and I let go of my consciousness. place me deeper in their control. The next few days I was on call, as
Excited by my enthralling day, not having anyone around to have to act Ghislane said I'd be. Venturing out to the city for only an hour or so at a
reserved, I jumped into the soft bed and lay looking around, thinking time, I looked most forward to my outings. I would return to Jeffrey's
about how quick life could change based upon one swift decision. Dazing
37 38
mansion to attend to his sexual desires and when he was finished with happened within the next hour and be able to become someone without a
me, I'd be off to my adventures. battling conscious.
On the day before we were to be heading back to Palm Beach, Jeffrey I spent my sweet 16th birthday on his island in the Caribbean next to
had a new proposition for me. I could make double the money I was "St. James Isle" he liked to call it "Little St. Jeff's", his ego was as
making, ifI would look for pretty girls and convince them to come back enormous as his appetite for fornicating. I was given a birthday cake and
to Jeffrey's to be further persuaded with money to engage in bi-sexual a new collection of designer make-up from London. Ghislane made a
and sexual acts with Jeffrey and I. I asked him how does one actually joke after I blew out my array of candles and said, "I'd be soon getting
propose such a thing to a complete stranger? "Well" he said in a build up too old for Jeffrey's taste, and soon they'd have to trade me in." She was
to another kind of lesson. "If I were you I would use your charm to entice only half joking in a sad reality though. A few days after my birthday, a
them and my money to bring them, I would tell them you work for a girl was flying out to the island to join us for a few days before flying
multi-billionaire who has a taste for young, beautiful girls and with his back to N.Y.C. I was introduced to a pretty girl a few years my senior,
contacts in the acting, modeling, or rich husband world, your boss could named Sarah. She had long ash blonde hair and big brown eyes that
help them. All they have to do is come meet me first." IfI wasn't so hinted she had a cheeky nature. She had known Jeffrey before I had, and
naive at the time I would've seen that's exactly what he was doing with he was supposedly trying to help her get an acting job in L.A. She was
me, my prospects were massage credentials, but with too much pain from obviously accustomed to the lifestyle he provided her, making it ever so
my past, I could only have hope. Not that I was a shy girl, but picking up apparent with her prompt attention she lavished on him. She would do
girls for one reason alone, only to be endorsed for her body, didn't sound things like strip nude and bathe around the swimming pool, taunting him
like something I could do. But not wanting to displease my master, I told for sex. She was good at what she did, even putting me at ease with her
him that I would give it a go. You could tell he was instantly excited with cool persona and funny jokes. Jeffrey told me privately that she was one
my agreement, he started to reveal the politics of what kind of girls he of his best at procuring young girls into her entrapment and delivering
was looking for. He wasn't into multi-cultural girls, a very chauvinistic them to him when he was in town, and when it came to time in the private
perception; he said they had to be uniquely gorgeous to be accepted by chambers with Jeffrey, Her and I, it wasn't hard to comprehend. She was
him, but definitely no African-American girls, he was racist against devoted to the moment, giving Jeffrey every imaginable lustful desire he
anything different to his kind, a very narrow minded way of thinking for could fathom. On the last night there we all took a trip over to St. James
such a supposed brilliant man. The list went on and on. No girls with to go for a stroll, odd I thought, it was past 7pm and Jeffrey rarely strayed
tattoo's or piercing's, or gothics, no drug users, or prostitutes. Basically out past then, unless it was some event or dinner party. While Ghislane
he wanted everyone's daughter that looked like the girl next door, with and him looked the average couple strolling arm in arm through the
blue eyes and blonde curly ringlets. I just nodded and smiled, wanting streets, he said to Sarah and I, "Why don't you two hit the night club here
this to be over with and move on to another conversation, but so worked and see if there is anyone interesting to bring back for the evening?" It
up from our previous talk, instead he persisted to show me exactly what I was more of an order than a request and then I knew why we came out
was good for to him. He took me up to the highest loft in his large tonight and why Sarah was invited, tonight was all about training, and
mansion and he lay down on his large bed, expecting me to know exactly Sarah was going to show me the ropes in picking up girls. Although there
what he wanted done. As always, I complied. Part ofme hating him for was no one to accustom to Jeffrey's distinct taste to bring back, watching
having to degrade myself to be so subservient to his sexual whims, and Sarah flirt from girl to girl like a floating butterfly, gave me enough
another part ofme was telling myself to be grateful for the opportunities I insight into what I was expected to do.
was being given. Within Months I had become his handy little helper. Not only would I
The battles in my head were beginning to cause me too much anxiety, run to his beckon call, but I also aided Ghislane in bringing in more girls
when we got back to Palm Beach, I asked my Mom to make me a to keep the appetite of our sexually starving chief from going hungry. I
doctor's appointment for some headaches I had been getting lately, so she once asked Ghislane, why she did what she did for him, instead of having
wouldn't question me. I walked out of the doctor's with a prescription for a common monogamous relationship and getting jealous like normal
a mind-altering anxiety tablet called "Xanax", not only did it help with partners would? She replied simply "It takes the pressure off me having
anxiety but it also acted as blanket over terrible memories. So when I had to do it". That said it all, we were all under the shade of Jeffrey's money
to perform degrading acts, I would take a few pills and forget what tree, and not even someone like her could escape from its lure.
39 40
Just like Ghislane had trained me it was now my job to reiterate that Chapter 7
onto other girls and thus the cycle of girls trying to climb the chain of
hierarchy would start all over each time I brought a new one in. The
A knock came to my apartment door one lazy afternoon while we were
sessions rarely differed much. They would mostly start out with Jeffrey
in Palm Beach. I looked through the peephole and didn't recognize the
on top of the massage table already naked and me leading a girl into once familiar face. I asked from behind the closed door "Who is it"? The
massaging him until his instructions came to remove our clothing and if
voice of the reply was one I wasn't anticipating to ever hear again. It was
they ab>reedto that, then Jeffrey knew he had them in his pocket, and
my Junior-High crush and childhood friend, T.J. The last time I saw him I
could do what ever else he wanted. He was never turned down in the was a runaway and he had let me stay at his house for a few days, telling
many years I stayed with him. Never being shy, he would tell us to start his parents nothing, he kept me hidden away in his room. At nightfall he
kissing each other or depending on what he wanted we would perform
said to knock on his window and I could jump through and stay the night.
erotic acts sometimes with him fondling us, or just masturbating while he
Until I was picked up by authorities during school hours and questioned
watched. On explicit occasions, sex toys would be used on us girls,
why I wasn't in school they did some resourcing finding out I was a
making it all the more exciting for him to observe. Ending with a
runaway, then delivered me back to my angry parents.
payment of $200 for the new girl and $400 to me for bringing her. He
"Oh My God- You finally answer your door girl", and in a whirlwind,
would then wait for us to leave before adding the events details of names
T.J stormed back into my life. Even moving into my apartment, secretly,
and payments in a little black diary he kept with him wherever he went,
within two weeks of his arrival. He had changed so much from the last
so ifhe were in anyone of the city's he lived in, he would always have
time I had seen him. He used to be this hard looking rocker type, now he
contacts for sex.
was cleaned up wearing preppy clothes and shooting out Tupac Lyrics.
I was slowly climbing the ladder, as Jeffrey was happy taking me
He had the same old big brown eyes though, and when he told me he had
everywhere with him, within the States. Merely at home I distanced
heard I was back in town but he was unable to ever get ahold ofme he
myselffrom my Family altogether and with Jeffrey renting me an
just kept knocking at my door every so often, I was sold. How sweet I
apartment in Royal Palm Beach as well as a plush furnished apartment in thought, he must care about me ifhe was so intent on approaching me,
N.Y.C, there was hardly a need to see them. I just couldn't face everyone
not even thinking he would've spoken to the girls from our junior-high
thinking they all knew what I was really doing travelling around with a
circle and they would've mentioned him I was back in town, what I was
man old enough to be my grandfather who supposedly only wanted me
doing and where to find me. We were a drug-induced romance, which
for massages. Much further convincing myself of the lies I told myself, I
budded from fake emotions the affects made us feel. He got what he
took a liking to the Xanax, it felt like it was all a dream at times, even
wanted, a free ride and not having to work, and I got what I deserved, a
meeting up with old contacts from school years who experimented with man who could let me go away with this multi-billionaire I regarded as
drugs. I was flying around the country, seeing so many places in America
my second boyfriend.
I had only heard about in Movies and making more money than anyone I didn't want to alarm Jeffrey in me having a boyfriend so I kept it
my age and loving it. My friends didn't believe the lies I told them about
quiet, until during a massage I was giving to him one afternoon. We were
only being a massage therapist, some of them even asking if they can
having a conversation about some of my friends, the party girls I had
meet Jeffrey too. At this point in my life my heart went missing for a brought in to meet him. Jeffrey started asking questions about the
while and I stooped so low, I was even bringing my friends, I just saw
different types of drugs they used hearing them speak about it in his
them as easy commission. When I wasn't playing servant to my master, I presence. "I thought a person on drugs would be all strung out and
was partying hard, eventually using ecstasy pills, acid, and marijuana to
looking like hell, but the girls you know look great" he stated face down
disillusion the times I would've had away from Jeffrey to think about
during the massage.
what I was actually doing with my life. I realized something one day
That's when I told him I had been dabbling in ecstasy lately too, and I
while I was alone, although I had Jeffrey to attend to sexually, it was not
thought it was the most amazing feeling one could even fathom. I tried to
gratifying. I needed someone to come home to, someone I could call my
describe the euphoric feelings it gave me and even joked with him about
boyfriend and that showed me emotion not just a job to get done.
wanting to pet anything furry that was around and then there was the
constant need to flick my tongue-ring around my mouth. It was great
41 42
having such an open conversation about things Jeffrey had never her white uniform to reveal her beautiful nude body and a much darker
experienced before and he seemed okay with everything I was telling him side to her personality.
as we were having a good laugh together, so I thought I could push it a bit I couldn't believe it at first it was such a state of shock and I began to
further and tell him the truth about T .J, since it was bound to come out question t myself if this was normal in the massage profession to expect
sooner than later I'd rather not the latter, when it would look even worse this kind of clientele to request such degrading tasks even though they
that I kept the truth from him for so long. were professionals. At the end of the session she was paid $300 dollars an
"Well why were opening up about things together", I continued by additional hundred for helping to train me as well, and I was paid my
saying "I had met someone from my past and we have been hanging out a usual $200 dollars then we were both invited by Jeffrey to join him out
lot lately. When I haven't been travelling with you I have been with him by the pool for a cool dip. With Jeffrey making a few phone calls while
and I was wondering if you minded if I started to see this guy." He started her and I undressed again for a swim, I wanted to ask her a few personal
to laugh out loud, "Are you serious? Of course not, no one in this world is questions about what she's come to learn about the Massage Therapy
monogamous, why would I expect you to be?" I was smitten with relief, game, but I never got the chance as we were joined by Ghislane moments
but a little bit dis-heartened when I heard him speak that way and I later. She was asking how my training was going and booked the
wondered to myself if he'd had his own personal encounter with therapist in for herself in the following morning. Where she was invited
heartache. back to do another training session with me. It didn't take me long to
Of course the evening concluded in the same way it always had, the only figure out why.
reason I was really even there in the first place. Upon his request I I was at my apartment when I received a phone call from Jeffrey, I
straddled him on top of the table and let him explode with pleasure inside thought it was the usual call to come over to his house, but he surprised
ofme. Thinking the entire time about T.J, I felt so terrible but I quickly me. Instead I would be going to the exclusive hotel in Palm Beach
had to wipe the thoughts of guilt from my mind not to give Jeffrey the tonight, The Breaker's, where I would be meeting my first ever clients.
wrong impression. So I had myself busy with two men in my life, but Only told their first names I was given some instructions and the address
that's not what I really wanted for myself. [ wanted an occupation that where to meet Glen and Eva. They were a married couple with one on the
would eventually set me free from depending on a man as my source of way. I was quite concerned when I heard she was pregnant, being I really
survival. didn't know the body that well and didn't want to inflict any wrong doing
I asked Jeffrey before I left for the evening, when my real training was on the unborn baby but Jeffrey insisted I take this job. Just massage her
going to begin and he liked my assertiveness. I thought it meant to him gently where she wants to be rubbed and to save all ofmy energy for
that I was taking my job with him seriously, but it was all part of his Glen's massage, since it was going to be a four-hour job. In an
master plan to keep me by his side. Within a couple of weeks ofmy emphasized tone of voice I was being coached by Jeffrey to treat Glen
persistence, Jeffrey introduced me to a couple of real working massage with exactly whatever he wanted, just like I do for Jeffrey himself. It was
therapists, not only with credentials but with their own clientele too. I my last bit of preparation before he sent me out to his friends and my first
was in awe of their teachings, it all made so much sense about the body taste of responsibility in upholding his reputation.
and what they were saying. I felt like I had picked myself up out of the At around seven pm I took a taxi to the address I was given and found
lurches and had a direction again. them on the residential side of the giant hotel's extensive property. When
I was in the middle of another training session, with Jeffrey the I arrived in their apartment it was a far cry from the lavish place I was
recipient as usual, being it was rare for Ghislane to ask for a massage expecting, still really nice but had a cozier family feel to it. It was just
unless of course it was for Jeffrey's own pleasure to watch the punch line beginning to get dark when Eva and I went into the Master Bedroom and
of the session, when I was shocked to hear Jeffrey ask one of the she undressed to reveal the first naked pregnant body I had ever seen. It
therapists to now remove her shirt. He had no shame I thought. Even was fascinating to see her in the later stages of maternity, and strangely
though she was above his usual age criteria, she was still a pretty woman enough it was a miraculous and wondrous sight. She was a former model
in her early 30's with curly blonde hair and had an athletic body for a and one of Jeffrey's many entourages from his past that had gotten to old
mother of two children. She didn't hesitate in his request. It looked like for his taste and was married off to a wealthy colleague of his.
something out of a role-playing porn scene with the therapist removing Lying down on the bed I adjusted the pillows to try and make her more
comfortable and I began to massage her as Jeffrey had instructed me to,
43 44
softly and slowly. So at ease with her nude body she even asked me to Lying out on one of the pool decks blue and white striped lounge beds
massage her swelling breasts, in a non- sexual way. Not knowing any I was waiting for Jeffrey to finish his business so I could give him his
other way but that way, I was trying to oblige in her request doing the massage. He never took too long with his work, unless there was
very best I could to relieve her but couldn't help but giggle to myself at something wrong and then we would all have to wear his mood but today
the very sight of this. She said she was very happy at the end of the he seemed fine though, when we went up the stairs he told me we would
massage and rolled over to go to sleep, asking me to tum out the light at be leaving for his ranch in Santa Fe', New Mexico in the morning and I'd
the end of it. I closed the door gently as if not to disturb her, and went to need to be packed and ready tonight. They loved leaving in the spur of
find my other client. the moment, Jeffrey once said he checks with his pilot Larry on the best
The apartment's lights had been turned out for the sleeping children and weather before he heads to a different destination. I enjoyed spending
I found Glen awaiting for me in the lounge room where I had to call out time at his ranch being it was my favorite of all of his residences. He had
"Excuse me?" as I couldn't see him in the dark. There was a throw rug on a lavish Mediterranean looking castle on top of a hill that over looked his
the ground that he had already placed out as he began to strip down in extensive 7,500 acres of property. It has an indoor pool, gym, and all the
preparation of the massage. Lying frontwards facing me with his exposed trimmings of extravagance I could only imagine. I had a great time on the
and ever growing manhood, l asked him to roll over to begin the quad bikes, Sarah and I often got scolded for tipping one over going to
massage. He complied with a cheeky smile and from his eagerness to fast or trying to go up a steep hill, but we knew those weren't the things
show he was not shy indeed, I already knew where this was going to end he cared about, so it wouldn't matter. My favorite of it all was his little
up. town with it's own fire station and truck, stables full of horses, and little
I found it much more strenuous to massage on the floor but I wouldn't cottages where the housekeepers and ranch hands lived.
let that hold me back I wanted to have a career and this being my first On my own time I would take one of the quad bikes down to the
ever clients, I didn't want them to disapprove. Nearly four hours after I stables and saddle up on one of his beautiful horses and go for a ride in
had gotten there I was still hard at work. Mentally preparing for the end the open terrain. It was coming up to the end of a very cold winter and it
of the session he let me know when he was ready to begin the other side still had the snow covered mountaintops and brisk air that I loved to take
to my job and just like Jeffrey did the first time, he requested me to take in during my many trail rides. I have been an experienced horse rider
off my clothes starting with my shirt. When I complied, the requests kept since my childhood, and could honestly pinpoint some of the best
coming in and before I could change my mind and run away, I was memories of my life being on the back of a horse. 1acclaimed with thrill
having intercourse with this man that was so comfortable doing all of this in my voice "Great, I'll get packed as soon as I get back to my apartment"
while his pregnant wife and children slept in the room beside us. When he threw in "Pack for a few weeks, as we will also be making a pit stop
he had climaxed, we both got up and dressed and he paid me a large tip to L.A for some business afterwards and then to N.Y.C." I was used to
even though Jeffrey would be the one to actually pay me for my time these round trips with him, it was great as I was saving loads of cash and
spent there. Just like it had all started, it had also ended so quickly and about to buy myself my first car.
now that was that. I had to accept what my duties were and now I could Jeffrey, Ghislane, Emmy and I all left the following morning, as
go back to Jeffrey who would be further pleased in my demonstrations to planned. Arriving in only a few hours at his awe-inspiring Santa Fe
keep him happy. Palace was always a delight. Still frisk in the air, my petite frame looked
I was called the next morning to come over to Jeffrey's mansion that even smaller in these gigantic overcoats. Nonetheless I was looking
afternoon for lunch, a swim and of course a massage session. Knowing forward to spending time out in the fresh clean air and open land. After a
all too well they'd be expecting the gory details oflast nights events with few days of leisurely spending our time on the ranch, we went to the
my new clientele. I came there at 1pm as requested and sat down for a Indian markets in Albuquerque for a bit of shopping and sight seeing.
light lunch and a swim. Jeffrey was mostly conducting business from his Jeffrey wasn't the most off road kind of guy, so when we went sight
offside pool office, but he came to ask me if everything went well the seeing it was more like museums, boutique shopping, and local art
night before. I told him I did everything asked of me and I am quite galleries. Still a splendid trip though. With me picking up a few nifty
confident both my client's were more than pleased with me. He gave me collectables to bring back for my family and knowing how much my
a quick grin, before he headed back to the office, throwing a purple grape mom loves Indian apparel, I thought it would put me back in her good
down his throat as he walked away. books for awhile, I hoped at least. There was some lengthy time to put a
45 46
little water under the bridge between my folks and I. With my life something he'd say nice to all the girls, but in the time I had known him I
heading in a different direction I didn't see any use in holding on to so could honestly say it wasn't like him to compliment girls in any other
much hate especially that I didn't even have to see them that much. way than regards to a sexual performance or their looks. I was flattered at
We got back to "Zorro Ranch", the name Jeffrey chose to call the his praise and when the massage was over, so were the sentiments. I was
massive land he bought to build his fortress on, and Jeffrey told me that back to being used for my body and what I could do with it.
he was looking forward to one of my famous relaxing massages and with With him satisfied and off for a nap, I could go do what ever l wanted,
that notion he gave my bags of shopping to one of the many housemaids like usually I would go down to the stables or something adventurous, but
who greeted us at the front door and asked her to bring my bags to the today I was in a melancholy mood,just wanting to relax and unwind
exquisite room I was staying in. We headed straight downstairs just past myself in a giant tub in my bathroom. I got out some of the oils I used on
the massage room and gym there is an indoor heated pool, shower and Jeffrey putting them in the steaming water and popped two of my Xanax
spa. First Jeffrey wanted to wam1 up in the spa underneath a decorated pills, forgetting about my troubles and focusing on the quiet moment at
ceiling of clouds and blue skies. Starting the massage in the spa I rubbed hand, just wanting to soak up the peacefulness of it. Nearly slipping away
his feet while he reclined into the spa's jets. We spoke of the museum and to sleep in the tub, I was startled when I got the call on the intercom to
some of the knick-knacks I had bought and I thanked him for the come down for dinner.
turquoise earrings and necklace he had got for me as a gift, joking about Everybody seemed in good spirits at dinner, which helped to lift mine.
not ever knowing what to get for him, being that he was richest man I'd We all ate our meals and went into the movie room to watch a newly
ever known. By no far means did we ever have any kind of a mutual released movie. It was a ritualistic scenario, most nights that everyone
respectful bond between us, but there was a significant softer side he was at ease we would all sit in one of his various located movie rooms
began to share with me that was different from how he treated his other and hang out together. Just as he always would Jeffrey asked Emmy and
girls. Maybe it was my feet that filled the shoes for that time being, or the me to both grab a foot during the movie that night and just keep
fact my novelty hadn't worn off yet, but what ever it was I was getting massaging through the film. We were always on call for duty, no matter
confused from the double-sided life I was leading. where we were or what ever time it was. He would just plop a foot up or
He got up from the spa tub shortly thereafter and asked me to come pass over his hand at any given time and require a massage, even if the
wash him in the shower. It was nothing unordinary to me, I was used to film went on for over two hours, I would still be required to sit on the
his need to be nurtured and pampered. l perfom1ed his request with a floor rubbing his feet or hands, and even his scalp at times. After the
cheerful mannerism, letting him think I was taking care of him out ofmy credits had rolled Ghislane got up to close the door to the room and I
sheer sweetness. I got the towels ready for him to get out of the shower knew she had received the signals herself and would proceed to
and towel dried him, patting his skin instead of rubbing as previously manipulate, violate, and use us to satisfy Jeffrey's urges once more before
instructed. "You know you have a very maternal instinct, you'll make a he went to bed.
fine mother someday", he would constantly acclaim at my gentleness. "I The blue illumination from the empty T.V screen was glaring in the
hope so" I replied, I would love to have my own babies one day, but not tenebrous room as we watched her undress in a light that relied on the
any time soon". Laughing at the very thought of that. reflection of the moon through the windows peek to show it's proceeding
We walked up the steps and through the French doors into the gym's display. She walked back to the sofa where I was sitting at Jeffrey's feet
adjoining massage room. It was smaller room than in his other houses, still rubbing away and uncovered her shirt displaying ample bosoms for
placing the emphasis on the large massage bed in the center. I grabbed his appeal. Approaching me like a lioness hunting her prey she stood me
another clean towel to keep him wam1 while I prepared the music, lights, up and led me to the other couch across from Jeffrey and situated herself
and oils. He liked me to use mostly lavender or other aromatherapy on top ofme, sliding her fingers through my dress to unbutton my attire,
scents, which reminded me of woodlands in the spring. Always enjoying revealing my girlish figure and two small peaks. Pushing my head into
the beginning of the massage, I put my heart and soul into training in my her breasts I was being fondled by Emmy at the same time, which took
profession. I could just close my eyes I would see only with my hands the her cue when she saw Ghislane look in my direction. From an occasional
areas that needed the most work, and even though I wasn't a professional glance upwards, I could see that Jeffrey was up to his methodical foreplay
yet, Jeffrey could feel and told me there wasn't many that could please stroking his manhood while watching the build up to his main event.
him during a massage being untrained. I'm sure now it was just They both took turns making me moan from their touches and when
47 48
CONFIDENTIAi. GIUFFRE004 I 80 CONFIDENTIAi. GllJFfRE004181
Ghislane was ready too she would insinuate we do the same to her. She Jeffrey and I left two days later, heading off to Carmel in California for
urged me downwards, until my head was between her opened legs and a business trip of his, leaving Ghislane and Emmy to catch a commercial
giving into her wanton indulgence. Twenty minutes passed before Jeffrey flight back to N.Y.C, where we would meet up with them later. When we
exerted his last energies for the night, the only advantage of being with an arrived at the hotel we were given badges for the meeting tomorrow and
old man was they could never last long. settled into our rooms. We got adjoining rooms, keeping the doors open
Departing to our own separate quarters for the night, I called T.J for at all times, but sleeping in different beds. He liked sleeping alone, even
condolence. It was so important for me to feel like I had someone out after a late night session I would always go back to my own room. I think
there who saw me as more than a pretty girl with vulnerabilities. I needed that's why he liked me so much I never put pressure on him to become
to maintain some sort of a connection to my youthful side. But it would intimately more than what we were already, never giving him the
be to no avail as I was getting used to being badly disappointed by all the impression I wanted more than what we had. It seemed to keep him
men in my life. happy just the way we were together. I hung out with Jeffrey that night,
going to a restaurant for dinner and afterwards watching a movie back at
Chapter 8 the hotel.
The next morning we went for an early morning breakfast before the
conference and Jeffrey gave me some money to go shopping instead of
The phone nearly rang out and as I was about to hang up the receiver
attending the all day meeting with him. I was more than obliged to accept
when he finally picked up. On the other end of the phone I could hardly
his request, and wished him a good day before planning to meet back in
hear T.J above the background noises. When I asked where he was he
told me "At our place baby", meaning the apartment Jeffrey had rented the room around six pm. He gave me five hundred dollars. He said it was
for me to be staying in alone. He already sounded off his chops just enough to go have fun for the day and a girl ofmy means could find
plenty to do with that kind of money. I walked around the many
elongating his words and slurring his speech. There was music pumping
boutiques that lined the streets of the picturesque cozy town, and picked
and people shouting behind him and every one sounded like they were
having a great time. I was so sick of his friends coming over using my up some bits of clothing here and there and even met a girl who was
passing through on a road trip. She was somewhere in her late teens with
house as a place to party and then trashing it so bad I would even have to
golden sunshine tresses, olive skin and blue eyes. Her name escapes me,
sometimes throw my furniture out. I blew up at him over the phone and
as it was so unexpected, 1 think it was Tina or something like that but she
threatened to kick him out, back to his parent's house, so much for my
relaxing evening I thought to myself venturing on to tell him "You leech was your typical California carefree chic, offering me a few tokes of her
jay as we ducked down a side street together. I was so happy I had met
off me using the money I leave behind for you for drugs and throw these
gigantic parties while I'm away." Also mentioning the disastrous messes this girl, as she was fun spirited and charismatic a relief from the social
I would come home too. "I am so close to ending it with you", I would expectations I had come to know lately, but always being "on-call" as I
had been trained up to be, I ended up inviting her back to meet Jeffrey at
openly threaten, but he knew better than I did, that I just couldn't bring
our hotel later on as a surprise for him. Maybe she was just a bit too
myself to do so, needing some attachment to my youth through all of this.
carefree for Jeffrey's taste but anyhow she was pretty enough to let him
"Don't worry baby" he would say attempting to soothe me with his false
words going on to tell me how much he was missing me and how he was be the judge of that matter.
Over the next hour of hanging out together I found out that she was on
always thinking about me when I was away which was like all the time.
I would soon be buttered up and soft for serve. This was my penalty for a road trip with her best friend who was still sleeping off the hard night of
partying from the night before. She was originally from the southern
choosing a guy that accepted my lifestyle with my "Other-Man" as I had
states as she had a bit of draw still left in her accent, and she had recently
so eloquently put it to him once as not only acceptable but deemed it
left her boyfriend because he was leaving for a college too far away not
"Cool". The conversation ended with an easy good-bye and no "I-Love-
believing in long distance relationships. Then it was my tum to dish out
You's" or anything sweet. We weren't those kinds of partners yet, so
much time spent away from each other and the lifestyles we both led, I my contribution to the conversation of getting to know each other better. I
always got anxiety before I would tell a girl what I did for work and
couldn't expect much more from him than what we already had.
romance (as such), morally I was ashamed of who I was especially with a
girl having led somewhat of a normal life. Next, as always, I expected to
49 50
be probed with so many more questions and having to make Jeffrey collared shirt and put on his normal attire of sweatpants and a sweatshirt.
sound ideal and hot for the taste of a young girl and knew I would be Ushering him out the door for dinner when he was more relaxed I was
point blank lying, so I told her some of the truth which was that he was lucky when he said he was starving and quickly got dressed. We just
really rich and paid good money for a massage and useful to have around found a quite spot to eat that was next to the wharf and got back to the
as a contact. I told her he'd give her two hundred dollars for a two-hour hotel just in time for our surprise guest. He wanted to go have a shower
massage with me leading the way and warning her he was known to be and settle down for a massage, so I told him I'd join him in a minute, I
frisky during the session. Unexpectedly she said she could use the money just had to make a phone call real quick which he thought was odd and
and then came the part that I hated the most, but had to do so they asked me if everything was alright, I reinstated that I'd just be a minute,
wouldn't be as shocked as I was the first time I had met him. "He does trying not to let on about anything. The knock came quietly on my
like us to be nude though and sometimes asks for more than just the room's door just on time, as we had planned and I told her my idea to
massage itself'. All I could do was wait for a response after a shocking surprise him. I let her into the bathroom where she orchestrated my plan
sentence like that, and depending on the girl, most were sadly taken back perfectly. Jeffrey finished his shower without me and when he called out
by the money. Her carefree attitude seemed to disillusion for a moment for me I told him that I needed him to have a look at something in my
when she gave it some thought and asked me "He's not like, fat and ugly, room real quick. Not giving in to what it was that he would be looking at,
is he"?"" No ... no ... not at all" I replied, "He's got more ofa Richard he came into the room where I opened my bathroom door to reveal a
Gere appeal to him". Trying to make him sound a little more measurable beautiful nude girl bathing in a thick amount of soap bubbles in my tub
than just a rich old man that likes to be with girls younger than half his looking at him with an alluring intrigue. His grin went from ear to ear
age. "Well then, what time shall we meet tonight"? She asked next. when she stood up and introduced herselfletting the bubbles run down
Great, 1 thought, Jeffrey would be most pleased with my find. "Knock on her glistening body at an ever-slow pace. It was a proud moment for
my room quietly, you're going to be a surprise. Be there at around half Jeffrey, I had done well in his eyes, and she was not like the other girls I
past seven tonight and I will introduce you to Jeffrey". She threw the butt had brought to him before, degraded from a lifetime of abuse off the
of the second jay we shared in the bushes and we strolled into a streets. This girl was exactly his pro quo looking sweet and innocent as
homemade fudge boutique to get some relief for the munchies we now the girl next door. My efforts were to show him I knew that my only
had. responsibility was to keep him happy at all costs. I led her through the
When I got back to the hotel at around a quarter to six o'clock pm as massage on Jeffrey and of course afterwards gratifying his perversion
requested I'd be, nobody was back yet, so I took the time to set up the with his lustful requests to be fondled and watch us become more than
oils and bath in my room for his massage tonight. I thought I would plan just friends. I didn't feel too bad at the time with his coercion providing
it so the girl would be cleaning off, as Jeffrey liked before he had sexual many financial rewards making his scheme enticing to a young,
contact with a new girl and he could walk in and be surprised to find a impressionable teen not realizing the terrible memories left to come from
strange beautiful girl in my room who wanted to massage him. Jeffrey all of this. Afterwards he paid her the usual two hundred dollars he gave
walked through the door not long after I was done prepping for the night to everyone for their time and took down her name and phone number
ahead, looking like he had a rough day at the office, which was very rare writing it in his infamous little black book of the contacts he met in every
for him. He sat down on the bed and I asked him how his day was. He city but only the ones he really liked made it down in his records.
didn't want to talk much about it, saying it was boring and long, rather We went out the next afternoon as I had suggested last night and we ate
asking what I got up to for the day. Being coy about having a jay and his our clam chowder breadbaskets over looking the wharf's bay, watching
unexpected surprise to come, I told him it was a great day of shopping the seals playfully barking at each other on the rocks nearby. Shortly after
and sight seeing and I even brought him back some local made fudge we were driven to the private airstrip and took off for Los Angeles. On
from the shop that had fulfilled my chocolate cravings only hours ago. the plane was an unexpected visitor. Matt Groening the producer of the
Telling him of the places I ventured into I mentioned to him "We'd 'The Simpson's" T.V show was catching a ride with us. I was so excited,
have to hit the fisherman's wharf tomorrow. I saw some locals walking as I loved watching his show and acted like a star struck fan, asking him
around with breadbaskets filled with creamy clam chowder and it smelled everything from his initial idea for creating the show to where he got his
absolutely scrumptious." He said if the weather were nice we'd check it characters from. He told me it was all based on his own family make up,
out tomorrow before we left for L.A. He wanted to take off his jeans and
51 52
but without the crazy father and son scenes of Homers hand around Bart's apartment that Jeffrey rented for her on Malibu Beach. This was the first
throat. time Jeffrey came to visit and when we got there you could see why. It
I was enjoying our conversation, when Jeffrey insisted that I give Matt was a tiny one-bedroom shack, too small for his likes of accommodation,
a foot massage throughout the duration of the short flight. I never turned but she loved it and it was plain to see why, the waves lapped underneath
down a client but when I saw the shape of his feet, I nearly threw up at her porch twice a day, what else could anyone want. Before even walking
the thought of having to touch them. He had yellow crusty toenails that through her door, you could hear the commotion of excitedly screaming
even someone with a chainsaw would've had troubles cutting through females voices coming from inside. There were about five other girls in
and then there was the fluffy balls of leftover pieces of sock wedged Sarah's living room and she had invited them so Jeffrey could have a few
between the crevices of his sweaty toes, now that was the real icing on different girls to choose from. Jeffrey looked at Sarah and smiled, aren't
the cake for me, no way could I attempt this I thought. Then I had an you sweet, as all the girls rushed to introduce themselves, hoping for the
idea. I went to the back of the plane and rinsed a wash cloth in warm opportunities Sarah had offered them to come in the first place.
soapy water and returned for his dreaded foot massage but not before We all had some coffee and biscuits while the conversation kept getting
attempting to clean them first. louder and louder, every girl trying to talk over the next one. Jeffrey
In return for my services Matt was kind enough to draw me two quick could handle only so much of that before getting too annoyed. Instead of
sketches on blank paper from his briefcase ofmy two favorite characters, choosing one of the other new girls, Jeffrey wanted Sarah to show Nadia
Homer and Bart. I asked ifhe would make them out to my little brother and I into her bedroom. He was anticipating the introduction of his two
and dad, the true fans of the family not missing an episode during dinner favorite girls together, what mischief he had hoped we would get up to
over the past ten years or so. Next to the A-4 size drawing he was able to was apparent when he asked where Sarah had kept her play toys and not
fit in the quote 'To my greatest fan from Matt Groening" and their names the fisher price ones. Sarah brought out quite a collection of her personal
next to it. I knew they'd absolutely love it, and it was such a nice gesture toys and was giggling on her way out as she shut the door. Suddenly the
his feet were no longer an issue as I laughed it off and even made a joke room behind us went quiet, probably hoping to catch a moan or groans
to the comedian about getting a pedicure before hitting L.A's beaches. too laugh at and I felt so degraded having everyone knowing exactly what
The flight was only short and we arrived in busy L.A within the hour, was going on. Knowing my duties well I was baffled this time as there
saying Good-Bye to Matt, who was a pleasure to meet. Jeffrey had a was no ritualistic massage wanted. He immediately instructed us to start
meeting at a production studio for one of the girls he was keeping lured in kissing and fondling each other with the provided toys straight away
his grasps, so we were off yet again for more business. We were staying seeing his excitement grow watching us try and out do the other one with
with one of his old girlfriends, Jeffrey's code for "She got to old for my pleasure, he couldn't keep restraint any longer and started to have
taste, but was still nice enough to keep around". She was a tall blonde intercourse with the both of us, taking his erect penis out of the other to
with blue eyes, a stereotypical Barbie doll. In her younger years she had only swap to the other girl, back and forth. This continued for a good
been a successful model and now lived on the beaches of Santa Monica fifteen minutes or so while we continued to engage in lesbian acts on
with a sweeping view of the oceans landscape as her backyard. each other while the other girl was being subdued by Jeffrey's thrust's of
The next morning Jeffrey and I went out to breakfast. He said Sarah penetration. Nadia was just as dutiful as I was in fulfilling his demented
Keller, would be joining us with another one ofJeffrey's girls I hadn't requests, willing to lend her body to Jeffrey and those he sent her too, for
met yet, her name was Nadia Bjorlin and she was a Yugoslavian model the sake of keeping her acting career and putting on a good act at that.
turned aspiring actress, with the help of Jeffrey, as he so proudly She was never competition though. Once I found out where she actually
remarked at the table before they arrived shortly thereafter. She was a came from I took pity on her for the similar life of servitude we were both
stunning brunette with olive skin tones and shocking blue eyes. By far accustomed too and not that we ever became good friends but we had
one of the most beautiful girls I had ever met before. She and Sarah reason to relate to each other.
approached the table, shopping bags in hands already in the early hours of Later on Jeffrey, Nadia and I went to a production studio in L.A, where
the day. They both pulled out a chair and showed us their new pair of we had to meet with Nadia's agent as well as the producer of"Day's Of
Jimmy Choo's they had bought on their way here this morning, and Our Lives". The meeting lasted five minutes, with everyone in consent to
excitedly asked for Jeffrey's opinion. He loved the doting attention and the proposal. We flew all the way out there to talk about money, only to
anyone who could make him feel important. We all went back to Sarah's be leaving that evening back to N.Y.C. On the way to the airport we
53 54
CONFIDENTIAi. GIUFFRE004I 86 CONFIDENTIAi. GIUFFRE004l 87
stopped at a fifties looking diner and got a cheeseburger and vanilla Chapter 9
milkshake, the first and only time I saw Jeffrey eat what I considered to
be real food. Seven lanes to drive in and the freeway was still lined
We met Ghislane and Emmy in N.Y.C, and it wasn't a blissful reunion
bumper to bumper in the heavy rain. The sound of downpour on the
as J hoped for, wanting a break from all of this J was just looking forward
rooftop of the taxi and the rhythm of the windshield wipers was making to getting back to Palm Beach, not leaving for a further four more days. I
me sleepy. l was looking forward to sleeping through the long flight
got home late in the evening as Jeffrey invited me out to the movies after
back. Thank goodness we had a private jet to catch back, the trip would
we had relaxed at his house for a while after landing.
be comfortable and not rushed to get there on time through the daily peak
I put my keys through the door to my apartment and walked in to a
hour traffic. Jeffrey asked me what l thought of Nadia, more of a kiss and quiet house. Not thinking anyone was at home J set my suitcase on the
tell kind of thing for him, so proud to admit some of his tenacious acts of
floor and put my cell phone on charge as I always did to be accessible for
pedophilia to me that J knew most people would be embarrassed to even
whenever Jeffrey or Ghislane could call. J went to get a drink out of the
think aloud but I said what he wanted to hear when he asked me what I fridge when I heard some noises coming from the back ofmy apartment
had thought of her on the way back. J replied, "She is attractive, funny,
where my bedroom was. I started back there and slowly turned my
and seems to know what she is doing with you." Laughing at my
doorknob to reveal T ..Ton top of another girl. When they noticed they
statement, he then started to tell me the history behind where he got her.
weren't alone anymore, T.J got off her with promptness. I recognized the
Five years ago when she was merely a teenager just turned thirteen. Her girl from seeing her around at parties, and she was the town lowie,
father had recently passed away, leaving Nadia's mother in a tremendous
scattering her trail of guys along with her presumable diseases, and I
amount of debt and living in a third world country, she didn't have the
wasn't shy to verbalize that when she tried to open her mouth and calm
means necessary to raise her own daughter. When Ghislane approached
the heated situation between T.J and L She didn't like her cards on the
Nadia for the first time at a music school, she seemed like a maternal,
table in front of the guy she was screwing around with and got up in a fit
caring stepmother. Telling Nadia's mother if she let Nadia go with her,
of rage to attack me. Still nude with only my new white sheets to cover
she would se to it personally that Nadia receive the best education and her body, I threw her out of my house along with T.J. "J have been
chances in life to make it. In her customs it wasn't odd for a young girl to
paying your way for months, only finding out your sleeping with the
be married off to bring the family good fortune, so she kissed her baby
biggest slut in Royal Palm Beach, at least have some dignity and higher
girl good-bye and sent her off to commence her life of servitude. l sat
your standards." I didn't really have a leg to stand on since I had started
there speechless listening to Jeffrey brag about his endeavor to get her
this relationship giving him the knowledge I had a sugar daddy to answer
over here, shocked that he could stoop as low to use a barely teen to
to above him. "You're gone all the time and with that old man, what did
oblige his sexual desires. He was laughing and giddy as he replayed the you expect me to do"? He was right, l wanted what I couldn't have, but I
memories of her arrival over in his head, painting me a horrific picture l
needed some time to cool down and accept my situation. I loved having
had no choice but to imitate a smile to face him with. T.J around to come home too, and he used to be my best friend in my
No pretty girl is safe from the allurement of these villains procuring the
school days. I convinced myself of the lies I continued to accept.
youth off of every street in the world. J knew that day more than ever
Days later J was still not speaking with T.J, mentally adjusting to my
before those morals did not exist for people like this. Jeffrey once told me circumstances, J thought I'd have the day off to relax since J hadn't been
that every girl he has had sexual relations with has benefited in their
called all day. Until about five pm when Ghislane called and said Jeffrey
career, finances, or an achievement in marriage with a successful would like a massage in an hour. Grudgingly I got up from relaxing on
colleague of his. Mine was the massage career, ever so often still giving
the couch, got dressed and put my make-up on, meeting Juan downstairs
me a lesson from a professional, which kept me quiet for a while longer.
a half an hour later. Jeffrey was already lying on the massage table when
I thought I was already knee deep in this world, if I gave up after putting
I walked in. I started the massage being very quiet from my somber
myself through all of this hell it would've all been be fornothing. So I
mood, when Jeffrey picked up on it and said "you know it's not good to
treaded lightly, constantly at a risk of being replaced by another willing massage people when you're angry, you could pass on negative energy".
participant and playing the eager student he wanted me to be.
I wasn't sure ifhe was serious or just trying to be nice so I could speak
about what was bothering me. Ending up not being able to contain my
55 56
emotion any further I told him what happened with T.J and broke down dilated into little black diamonds. We were all having in depth
in tears, a little heart broken from living in such a lie. He turned around conversations about life and where we would all end up when this
from his massage and sincerely paused for a second thinking he was charade was all said done. Nobody got to sleep that night as the room
going to console me but instead he laughed at the very prospect ofmy slowly dwindled in numbers as people were finding their way home to
notion that monogamous relationships ever existed. "Are you serious, he recover from the repercussions of drugs wearing down out of their
was only doing what every guy in the world does, you can't hold that intoxicated system.
against him". I replied in a lighthearted gesture "whose side are you on When I flew out to N.Y.C to meet Jeffrey the next day, I was still in a
anyways"? His answer stuck with me for many years to come "I'm on horrible state. Not knowing what was wrong with me, thinking it was just
your side which is why I'm going to save you a lot of grief with this one a bad come down, I rushed out of the elevator and down the hall to my
tip, Never expect a man to be faithful and you '11never be let down, it's room, sweating profusely, to make it just in time to the toilet to throw up
just the way us men are genetically imprinted." The remainder of the bile again for the uncountable time since getting off the plane. I was
massage I had to pretend like I wasn't further saddened by his response, having intense cramps in my stomach and when I was called down to
but in fact having to act enlightened. I would never come to him for any meet Jeffrey in the massage room, I had to decline for the first time. I told
other relationship advice, ever again. He told me I'd be fine if I just the housekeeper that I was feeling very ill after the flight, maybe some off
listened to my mentor. He still loved role-playing the teacher and me the food for lunch and needed to lie down for a while. Nobody came up to
pupil, like the old days before he got rich and only used to be a college check on me for hours or even called. Waking up from my much-needed
professor. I finished the massage and fulfilled my sexual duties before nap, I pulled back the expensive white sheets to find myself in a pool of
being sent home wanting to collapse in anguish. my own sweat and blood. I was covered in the red stains that drenched
T.J was outside my apartment door when I got there, his mom waiting the pants I was wearing. I had no idea what was going on, I could only
downstairs in her minivan just in case I kicked him out again. He pleaded focus on the dire amount of pain I was in. In between the heaves of
his guilt and promised that he would never see her again, agreeing with throwing up and crying simultaneously I was able to reach the phone and
me that she was the town slut and he screwed up big time. I let him back called the housemaid on the intercom. I told her I needed to go to a
into my apartment and back into my life for that matter but more aware of hospital immediately and slammed the phone down only to fall back to
the world I was being led into believing was of normal conduct accepted the floor hurdled in a ball. She didn't hesitate in calling Ghislane who ran
by everyone in this sick world. Jeffrey was going back to N.Y.C and told up to see what was wrong. Ghislane then called Jeffrey who was in his
me to have a few days off before his assistant at his office would arrange office at the time and told him to hurry up to my level, stressing to him
an E-Ticket on a commercial flight for me to join him later in the week. I that it was an emergency. Thinking they really cared about me for the
hadjust made loads of money from my previous trip and wanted to relax first time since I had known them, they came with me to the hospital with
like any teenager does, so I threw a hotel party that weekend on Singer me. Now I realize I was only a liability in getting them caught and they
Island in Rivera Beach, inviting only a small group of friends to begin needed to get to the doctors before I could say anything incriminating.
with. They were suspecting the worst now and seeing he never wore a condom
The hotel room quickly filled up with a flood of teens and the pumping with me and from our previous conversations they knew I always made
music was blaring. The room had a balcony overlooking the pool and the T.J wear one, they feared the situation at hand.
beach that became the smoker's section. I wasn't a real smoker at that When he saw the catastrophic state I was in at that point, it was the
point, preferring to have a puff of a spiffed blunt instead so I made it my housemaid who helped me get up and assisted me down to the car where
rule to go outside trying to prevent holes in the carpet, but it didn't last Jo-Jo was waiting for me. He drove us to either Lennox Hill Hospital or
too long when our forbidden walls came tumbling down. Making so Mount Sinai, I can't remember, as it was so blurry in such a bad
much money that I could supply my wild parties with an assortment of condition. Rushed in for immediate testing I was uncontrollably vomiting
drugs like trips, ecstasy, and coke as well as an abundance of alcohol, that and in so much agony, I was given an injection to help me to subside the
T.J had all the contacts for, made my fellow teens admire me. It definitely intense pain. A nurse came in to ask who would pay for this and although
gave me a head swell, thinking here I was so young but so grown up I insisted my parents insurance still covered me, Jeffrey persisted that he
already with all ofmy peers from high school looking up to me. In the take care of all the medical bills and gave the nurse his information.
wee hours of the morning we were all still going hard with our eyes
57 58
When the pain relief kicked in, eve1y1hing and everyone dwindled compliment the sights mother nature that appealed t.o us . l didn 't feel as if
away until I felt like A lice in Wonderland who just swallowed the I owed this strange r anything but what was expected of me by Jeffrey and
shrinking tablet and everyone standing around me seemed to move so I cou ld be polite, I just couldn't be myse lf.
quick, speak so loud and hover above me. When I awoke from my We got back to the main vi lla to see what time dinner would be se rved
induced state, I was alone in a different room. No t knowing at all wha t so we could have time to unpack and clean up befo rehand . We both met
went on but feeling a little better, I called in the nurse who looked at six pm for dinner on the outside veranda. He sat at the head of the
through Illy charts and checked my vita l signs. Then told me the doctor table and I sa.t next. to bim, politely folding my napkin to put in my lap.
would be in shortly to iufonn me of the conclusion to my illness. The first time Jeffrey and Ghislane had see n me cut meat and eat with a
He was a tall man with dark hair, and a hardened look about hin1 fork and knife they we re so appa lled, making fun of my unsophisticated
obviously from his job and constantly seeing the worst ho1ro r stor ies man habits. Ghislane took the fork and knife in her hands and proceeded to
could think of, he just bluntly told me I had miscarried in early stages of show me how to politely cut my food and eat.. Now that my mannerisms
pregnancy. I should be fine lo go hom e as soon as my course of had improved they wouldn' t have to be worried about my etiquette when
intravenous antibiotics was comp lete. The new s sun k in fast and hit a someone important was around anyone . We both drank the red wine
deep nerve. I waited for the docto r to close the curtain befor e I let out any suppl ied on the tab le and it seemed to warm me up on the breezy night.
emotion and cried for my disas trous lifestyle that. was dragging me into a By the time dinner was served and another red wine bottle later, he
world that I wanted to break out of. This reoccuning cycle of bel ieving I seeme d to get funnier. I made fun of his tousled hair and he poked at me
needed men like Jeffrey to succeed in my life was draining the last bits of for my skinny legs, calling me a wanna-be- anorexic. When desse1t was
sens itivity left in 1t1y heart. I was picked up by Jeffrey himself who took brough t out, he asked ifhe could receive one of the delightful massa ges
the doctor alone to the side of the busy hallway to have a private he has been hearing about from Jeffrey. I gulped more red wine down and
conversa tion about someth ing. Jeffrey wasn 't comfort ing at all, instead he sweet ly comp lied with his offer . dreading the moment I'd have to see his
sent me back home to rest for a couple wee ks, and I only fell deeper into naked body, let alone touch it. I aske d the house kee per Kathy that had
a depress ion, using all forms of self -medication to treat. my sorrows. been serving us that nigl1t to please have someone set up a massage bed
Two weeks later, as if Jeffrey was trying to lighten my spirits, he to ld in one oftl1e cabana 's. I went to my room t.o down a few Xanax, telling
me I would be going to his island to meet a new client. He is a Harvard him I wanted to freshen up after dinner but to meet me in his cabana in
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him showing him arou nd the island, dining with him. and treating him to later, wit h the effects of the tab lets mixed with the red wine. and I wou ld
a massage whenever he wanted. Without Jeffrey even verbalizing the be free not to feel anything . He was still dressed when I got in tl1e cabana,
need to have sex with him, he to ld me to keep him happy like I had my obvious ly not accustomed to d1is and a lot shyer than what I had been
first client . l packed my suitcase with island apparel, and kissed T.J good- used to. I told him he'd need to undress and lie face down on the tab le.
bye, who had at least offered me a wann embrace upon the news of my putting a towel to cover his bare bottom to prevent him feeling
miscarriage but none other than that know ing it wasn 't his. embarrassed during the massage. I gave the massage my earnest as I
Stephen was a quir ky little man with white hair and a mad scientist look always had , and quickly got through having intercourse with him. Not
about him. We arrived separate ly and I gree ted him when one of the wanting to make any forep lay or anything ex travagan t out of it, I let him
housekeepers picked him up from the airport and arrived by boat, instead think that' s as good as it got, and by the smile on his face, rthought I had
of he licopter as Jeffrey and Ghisla ne often arrive on. We made our done enoug h.
acquaintances and he looked as ifhe was tripping over himse lf wi th Tiie next day I took him down to the beach for a real massage under a
words , obviousl y delighted with his compa ny and loca tion for the tiki-hut on the waters edge. It was one of Jeffrey 's favorite places to have
weeke nd. I showed him around as Jeffrey had asked and took him on an a massage , as he droned out to the sound of the waves and my gentle
adventurous quad bike ride around the small curvy paths , lead ing the way therapeutic. strokes. Afterwa rds we had lunch back at the main villa and
and letting loose my hair, doing something that gave me a natural high went back down to the beach to swim out to the water trampoline abou t
instead of the prescrip tion one. The sigh ts alone were breathtaking from one hundred meters off the dock. He didn 't do any bouncing around o r
the mountainous peaks of the untouched parts of the island, we sat at a anything like that. It was j ust a good base point for a rest spot aner a long
cliff and j ust sat there, not saying a word to each other bes ides 10
59 60
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swim. What was really cool about it though, was you could see through To my own amazement Rena was to be assisting me in Jeffrey's
the mesh and watch fish swimming underneath. massage this day, not being a total knockout or anything spectacular,
The rest of the afternoon we spent by the pool reading magazines and looks wise that is, but for some reason he seemed intrigued enough. As
eating fruit plates. Eventually he went to his cabana to have a nap later we made our way through his spectacular mansion she was in total awe at
on. That night after dinner and my mixed cocktail ofXanax and red wine, every corner. Commenting on the present artwork and decor that we
I asked if he'd like another massage before I went to bed. He just wanted passed in every hall, it no longer seemed so grandeur to me anymore but
to stay up watching movies in Jeffrey's theatre room. As peculiar as that hearing someone else speak about it in such excitement reminded me of
request was to me I didn't argue it, !just hoped I hadn't disappointed him the days when all of this seemed so unforeseen.
in any way that could make it back to Jeffrey. I showed him how to use When we got to the massage room, or "The Dungeon" as I used to put
the remote and turn off the T.V when he was finished before going to it for it's medieval looking appearance, we firstly out of custom all had a
bed. The next morning we were both catching a flight from St. Thomas steam shower, where Jeffrey expected me to walk her through a servants
and we had no time for anything other than breakfast and packing, which duties, telling her to take his other foot and start rubbing in small circles
saved me from having to be too polite as we said our good-bye's from the and stroking the arches of his foot rhythmically. Rena took the
terminal in the airport, both hurriedly off in separate directions, instructions well and began to massage him too. When we all went to the
thankfully. I arrived back in Palm Beach, only to be told to catch another shower next and she followed in my exact lead washing his body as well.
flight the next day to N.Y.C, where Jeffrey would fix me up the money he Jeffrey absolutely loved the fact that two teenage girls were dually
owed me for treating his colleague out to an entertaining weekend. pampering him. Jeffrey wanted to move to the massage bed and I had to
further begin to show her about the body, upon his accord. She mimicked
Chapter 10 my every move up his legs and buttocks, keeping up with every stroke
until he could not contain his arousal any longer and was already
requesting us to start kissing each other, the start of the very reason we
I was fixed up more than what I had usually made for two days, which
was great because that car I had been saving for was finally within my had even met in the first place.
He blatantly stopped the massage nowhere near being complete and
reach. I had been waiting for the freedom a car gives every teenager for a
turned over to announce his increased arousal in a physical abundance of
long time, and now that I had over fifteen thousand dollars saved up I
grotesqueness. Moving over to the small couch in the corner of the room
could pretty much afford to go buy myself a nice car outright. Looking
he made a space for her to lye me down on the massage table as she had
much better than the last time I saw him Jeffrey acknowledged it. I went
commanded him to do in such a domineering tone that he wasn't used to
to his office where he was waiting for me and he had a guest with him.
being spoken down to with. From that very moment onwards and from
She was unusual looking to the common stereotype drop dead gorgeous
the look on his face he was yearning for her to orchestrate an hour of
girls Jeffrey had normally introduced me to. Of Asian decent, her name
was Rena. Jeffrey had met her at an art gallery where some of her own deliverance upon my meek nature. He started to stroke his erect manhood
as he was being tantalized watching her take over every inch of my body
artwork was on display. She had a bubbly persona about her and I could
in a dominating act of seduction. I was left breathless and soar after my
then understand why Jeffrey liked her so much, she fit into the
subservient category that he liked his girls to fall under. It was apparent first introduction into the world of S&M.
Rena considered herself a dominatrix, she loved bondage, whipping
to me that they had already slept together in the short time span they had
hitting, and eventually cutting her sex partner with little sharp knives
met, as there closeness was oddly noticeable and I wondered what it was
until they subdued to her punishment in agonizing pain. She was
he was offering to her in exchange for her body. I found out later from
Jeffrey that he was buying her artwork, promising her the world as an absolutely crazy if you were to ask me, and I couldn't help but wonder
what got her into this in the first place. All I knew was that Jeffrey was
artist, telling her he'd have her work in the all the museums in N.Y.C and
absurdly taking into the appeal of watching us two interact, often with her
the best art exhibits. Everyone was promised something, and seemed to
acting as my mistress who would fondle me with an insurmountable
be bought off in someway or another to be in his company. It was only a
amount of whips and toys. Then she would love to finish off every
matter of time that the truth would come out.
session by hitting me across my face with a hard blow from the back of
her hand and sneering over my curled up body showing Jeffrey her ability
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to make others surrender to her extreme force. She could be so opposite seen him show a girl. Obviously moved by her gesture, he got her an
all of the sudden and be tenderly intimate with Jeffrey stroking his penis exhibit in N.Y.C's "Metropolitan Museum of Art" where she submitted
lovingly and even speaking in baby talk to him, which he seemed to her very own piece. She sculpted an image ofmy headshot out of clay,
adore. shaping it with the strands of my long hair blowing across my face. I was
He loved us pairing up so much that within months he made Rena an taken aback myself at her creation. She really did have an amazing talent
official even renting her an apartment at the same place he had one for me if not for her meaner streak she would've been a great friend. I will never
during my extensive trips out to N. Y .C. Sending us out shopping together forget Rena, for all of the ups and the downs we endured together.
at all of the underground seedy sex stores downtown we would bring him It wasn't too much longer before I finally had enough of the abuse in
back thousands of dollars worth of sexy outfits, sex toys and bondage the bedroom and I had to tell Jeffrey what I was feeling. She was getting
material. His favorite one was a black leather studded collar that lead even more violent as time went on, and with her questioning me and
down the back ofmy spine to cuff my hands and feet together, offering Jeffrey why she didn't get brought on long trips with him, she didn't get
Rena the most compromising positions to wield her afflictions, one she the fact that she was just a tool for him to use. Jeffrey said he was already
was excited to pick out for my usage. thinking about getting rid of her off of his "regular list". He said she was
She was good at eradicating my softer side though. Helping me forge becoming too clingy and he didn't like clinginess or jealousy. I never
an unpredictable scenario of me turning the tables on her, making her at even got to say good-bye or take the opportunity to keep her as a friend,
my will instead of me always being at her twisted discretion. Jeffrey like a girlfriend to catch up with once and awhile, but that's how it was
loved the rivalry between us, both striving to dominate the other one but with Jeffrey, one day you sat under the blanket of his comfortably and the
to me it was just another way of surviving her punishment. All for show I next without any warning you could be discarded like yesterdays news.
thought she was a madman let loose in a torturesome domain of violent She would've taken it hard but that's the game we were playing and it
sex and unbearable beatings. I wasn't sure how long I could hold off this was for those who knew what lines not to cross.
charade of S & M, I just didn't want Jeffrey to think I couldn't give him I was further surprised the next day when Jeffrey gave me a thousand
everything that she could, always being replaceable in his company. dollars to go shopping in downtown Manhattan to find a classy dress, on
She and I could often come across as good friends to his blind eye but top of being sent to the exclusive beauty salon of celebrity stylist
it was only a matter of time before the animosity inside ofme was going "Frederic Fekkai" for a new look. It was amazing, to be pampered like
to snap. Doing normal things too made it all half bearable. Having a lot of royalty. I walked out of there feeling like I had replaced a young girl with
similar interests we did fun things like go to the theatre to watch a young woman, I felt beautiful. He had yet another surprise in store for
"Phantom of the Opera" or visit several historical and art museums me. Ghislane called me and told me I need to go to a photo-developing
together, afterwards treating ourselves for a giant piece of greasy N.Y.C store and ask them for two l.D photos then bring them downtown to
style pizza. Like 1 said, we really liked each other purely as friends but Jeffrey's Manhattan office. Weird request I thought. I was more used to
the dominance in the massage chambers was taking it's toll on our posing in full body shots being sexually exposed as a gift for Jeffrey. I
strange friendship. One average trip back to N.Y.C, she surprised Jeffrey did as they asked and took my two photos into the office where Jeffrey's
with a six foot by six-foot oil painting of her and I lying nude in a ying assistant was waiting for my arrival. Still not telling me what the
and yang position facing each other. Although we were soliciting each headshots were for, she took them from me and told me to have a seat for
other with sexual innuendo the picture was still very carefully a second. A moment later I heard Jeffrey call me into the office. "I like
orchestrated to perfectly portray the darker side of Jeffrey's thrills. It was what you've done with your hair, you've gone more blonde, suits your
an amazing piece of work, besides the lewdness ofit, but she would've glowing tan". I replied with an appreciative "thank-you" for sending me
known that's exactly what kind of art Jeffrey liked. He was so astounded to such a renowned hairstylist, and shopping money. I showed him my
by her gift as he had previously asked her to construct a small painting of finds for the day, an elegant off the shoulder navy blue dress that had two
us together but was not expecting anything of this grand magnitude she layers that would swoosh and sway with my every stride. I couldn't wait
had presented him with. He lifted her from the ground and twirled her to wear it on a special occasion, and I wouldn't have to. The pictures I
around before he thanked her profusely and embellished her with his had to bring to him, as he would proceed to tell me, were for my first
profound gratitude, the only thing Jeffrey had to offer, he handed her a passport. I was so excited, we were going to France for a close friend of
small wad of cash as her payment. It was the most appreciation I had ever Jeffrey and Ghislane's birthday party, famed super-model Naomi
63 64
Campbell. I was so over-joyed with excitement, what girl my age with a was, only to grab another glass of champagne every now and then. Every
background like mine was attending socialite parties and globetrotting the so often he'd introduce to me to someone new, pulling me aside to show
world. It only made it harder for me to see beyond the elusive walls I had off his eager young masseuse to his fellow pedo 's. These people had so
put up to protect myself from the appalling truth. much money pouring out of them. I don't know why he even thought
We left in early April first going to London, Paris and then our final they'd care in the first place. It made me feel good though. At least I
destination being St. Tropez in Southern France. If Hallmark had a knew I made him proud to have me in his company.
postcard, St. Tropez would definitely be on the front of it. It was beautiful Being surrounded by so many of Jeffrey's colleagues and his
spring weather and every where you looked women were dressed in likeminded people that were considered the most sophisticated and the
bikini tops branded with some kind of designer label embedded into it highly esteemed of today's world nearly made the way I was living lately
and the men were following them around like harping dogs in heat. In all more fathomable, at least to myself. I thought if everyone looks up to
of the elegance of the Mediterranean, "La Bastide De St. Tropez" was an these people and they are all accepting of it, it must be just the way the
impressive landmark. Jeffrey and Ghislane were staying in one of the world turns. I danced with a young prince that night and with all of the
private cottages, on the park on the grounds, while Emmy and I stayed in help from the bubbly champagne I couldn't remember his name for the
separate quarters inside the hotel. The old style cobblestone streets were life ofme. On one ofmy trips back to the table for another glass, Jeffrey
lined with boutique shops and beauty parlors. It was the hedonistic leaned over to quietly whisper in my ear that it was a prince that I had
stomping grounds of the beyond rich and famous. actually been dancing with and I didn't phase me in the least way. I went
The next day we went out to lunch at the grand opening of the back to the dance floor and continued to let my hair down. It was a fun
infamous Nikki Beach Club, where a cheap glass of champagne costs bash, the entire crowd sang "Happy Birthday" to Naomi and by the time
around two hundred dollars and if your not keeping the alcohol we got back in the car to retreat for the night, I was giddy from the
consumption flowing like water, you'd be asked to leave to make way for drinking and dancing all evening. We had a guest in the car, and
the constant flow of prospectus patrons. That's where I first got to meet apparently we had already been introduced, but I couldn't even remember
Naomi Campbell. She was wearing the typical attire strutting around his name in the first five minutes of our meeting again. He was the hotel
southern France, a D&G bikini top and a wrap around mini skirt to go owner of some large chain in America called "Hilton". Staying at one of
over the swimsuits bikini. She was so tall and stunningly beautiful. Her the cottages near Jeffrey, he saw it quaint to loan me out for a night's
charisma was energetic, funny, and everyone seemed to hang off of her massage to ruin an "almost" perfect evening. Jeffrey told me to come
every word and laugh at her every joke. Ghislane and Jeffrey kissed her back to his room after I was finished with Rick, thankfully he reminded
cheeks and wished her a happy birthday, and then I was introduced and me of his name but also odd I thought, being so late I would've never
followed in their suit. She was surrounded by a league of assistants, imagined Jeffrey could stay up this late but I never made a fuss out of his
friends and fans, which didn't make it easy for us to all converse but she requests. I gave him affinnation ofmy understood instructions and
got enough time in to invite us abroad a yacht of a fellow she was "kind headed off with this stranger into the darkness.
of seeing" at the time for the before party ahead of tonight's event. We I dimmed the bright lights in his bedroom to a softer tone as if it might
went back to the hotel and I gave Jeffrey a massage in his room before we aid the vision of this short, balding man with straggling remnants of curly
all headed down to the pool to soak in some of the year's first sun's rays. brown hair left to show for the remaining bits of youth left in him. I had
I loved wearing my new ball gown and feeling like a princess. It was to ask him to undress and lay on top of the towel that I had picked up
absolutely sensational and made me feel as ifl floated in the dress. I from the neatly folded pile at the end of his bed and spread it over the
swept up my long hair in a twisted clip, only letting down a few curly duvet. I didn't want to waste a second in his place, getting right to the
strands and layered on the mascara. Receiving many compliments very reason I was even there. Turning around while he was getting
throughout the evening when we eventually left the Yacht to make our undressed, being our first time together, I wanted to give him the
appearance at the main birthday bash, I couldn't help but feel excitement impression I was actually a therapist and not a finale to the end of the
for the party to come it was the first celebrity birthday bash I had ever nights entertainment. Not exactly what he had in mind though, given that
been to. Being introduced to model after model and the rich men that my impression was already made for me when Jeffrey arranged for our
followed them around became dizzying. Jeffrey sat back and watched as I meeting in the first place. His chuckle to my response was condescending
buoyantly worked the dance floor, coming back to the table where he as he came up behind me and unzipped my dress which floated to the
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bottom of the floor as he was saying "You can't really expect to give a our trip and commenced our flight back into the U.S. l was paid a
massage wearing this, here sweetie, I'll help you out of it." He just generous amount and set off to go car shopping as soon as I got back to
wanted to see the hidden bounty my clothes were hindering his eyes from Florida. Through a private seller, r was able to pay out right for my car. I
seeing. l just went about my way trying to get his hands off of me and to got a Dodge Dakota in cherry red, and immediately had an impressive
get him to lie down for a massage. Making quaint conversation with him sound system put in. She was my first pride and joy and taste of freedom.
was pointless as l was trying to send his thoughts elsewhere other than I would love to drive her down to Lakeworth Beach to sit in my car and
the apparent perverted schemes replaying in his mind from the heavy watch the waves while l listened to my stereo blare music and puffed on a
breathing he was making and the looks he was giving to me. I was using jay. Letting the rest of the world pass by while I sat back and watched
all of the tricks in the "turn-off' book even asking him about his wife and them walk past wondering to myself what their story was about.
kids. I turned seventeen that summer and had accumulated a string of exotic
Unquestionably he was in seventh heaven turning every one ofmy destinations that I had travelled in such a short time. I was given more
distractions into another flattering compliment. He was saying things like make-up and a pair of diamond earrings from Jeffrey. Ghislane only
"I love what you do you to me, I have never felt like this before, come wished me a happy day, wondering at times if she felt threatened by
stay with me and I will pay you double, no, triple whatever Jeffrey pays Jeffrey's and my closeness. We went to the island after we left N.Y.C and
you!" Knowing he was just a drunk idiot, I wasn't being lured in by any I asked If Sarah would be meeting us, mentioning it had been a while
of his offers of money or a privileged lifestyle, I knew these cages all too since we had last seen her. He said he had some bad news about her.
well and I was better off sticking with the one that I was at least Expecting the worse, thinking she had gotten hurt or something, l was
accustomed to already. Holding back any composure now, he was going astounded when Jeffrey told me that she had been sent to his island with
extremely wild ravishing at my body trying to tear off my panties like a one of his friends for a couple days and when the housekeepers were
hungered wild animal. After all of the champab'l!e I had drunk that night cleaning her room and they found a stash of cocaine left out carelessly in
it gave me the nerve that Tneeded to know exactly how to handle perverts the bathroom.
like this one, who had been no different from every other shmuck in my He said he had no choice but to let her go. Addicts with no respect for
life, and I quickly shut him up with a blowjob lasting no longer than two themselves or his wishes had no leeway in Jeffi-ey's book. He didn't mind
terrible minutes. It had only been shy of a half an hour before I was that I dabbled in drugs once in a while as long as I never brought them
already getting quickly get dressed and hurrying out his cottage door. along with us on any trips, except for my Xanax, which he didn't mind
When I got to Jeffrey's cottage I rushed through the door and told because it was pharmaceutical and most of all wouldn't cause him trouble
Jeffrey and Ghislane, who were sitting front of the fireplace reading a being a legal narcotic. Sarah took it too far when she crossed international
books, that l never ever wanted to see that b'llYever again. When they borders with an illegal drug, risking her welfare and almost costing
asked me what was the matter, l told them of every thing that had Jeffrey public attention. She lost her apartment and contacts in the acting
happened that night even how he offered me to come work for him world, only hearing from acquaintances once in a while that she was
getting paid triple. I established a lot of trust with Jeffrey that night. He sinking deeper and deeper into the black hole of addiction. It was sad to
asked me why I didn't accept the offer and I responded with "Who find out, as Talways did like her.
would look after you, if I were gone?" Like a caring grand father would At the island, Ghislane had just recently obtained her helicopter pilot's
do, he pulled me into his chest for a hug and told me that it meant a lot to license and wanted to get some practice airtime and flew Jeffrey and I to
him. Ttwas so late and Twas so tired but Tstill had to give Jeffrey his St. John where we picked up Alexandria Cousteau, the grand daughter to
massage that night. He asked me to just rub his feet as he fell asleep, and the inventor of the scuba tank and underwater explorer Jack Cousteau.
thankfully he was out like a light in no time. The next morning Ttook two Ghislane was out to set us affright in the air, but it was all talk, she was
headache tablets and a ginger ale instead of a coffee. Trying to contain actually an impressive pilot. Still a daredevil though, she got her kicks
my hangover as best as possible behind a pair of sunnies it was mid out of hearing us fret on the earmuffs intercom's. Jeffrey made it clear
afternoon by the time I had felt like myself again. We spent the day Yacht that Alexandria was a guest when I was told to adhere to her if she
hopping, soaking in the sunny weather while Jeffrey and Ghislane caught wanted a massage, which l obliged her with several times during our first
up with old acquaintances, Emmy and r were just accessories to look meeting. It was Jeffrey who instigated that her and I reenact as lovers in
good on the arms of them. The next day we wrapped up the tail end of lesbian acts of foreplay and penetration. l couldn't imagine a girl with
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CONFIDENTIAi. GIUFFRE004200 CONFIDENTIAi. GIUFFRE00420I
such high prospects lowering herself to something of Jeffrey's standards, beautiful as it was it could be as equally dangerous. It took so long as we
but I later found out through Jeffrey that he had donated money to her had to veer away from so many desirable spots. Finally we found a good
continuous exploration into marine life and habitats. She had followed in place that the scuba instructor thought was safe. He buddied us up into
her family's footsteps, all of them involved in Marine Biology in some pairs and we jumped off the back of the boat into the crystal aqua blue
way or another. We actually got along really well, she was a real decent waters beginning our descent slowly into the darker regions of the oceans
girl, and loved talking about her passion, everything underneath the floor. We were situated on open water with a cavern of reefs to venture in
waters surface. and around down below. It seemed to be quite a choice to scuba in, one
When I wasn't busy giving massages to everyone around, her and I that our guide said he wasn't familiar with but to alleviate his bored
would hang out together. Often we go swimming in the crystal clear pool clientele deemed safe to swim around.
of ocean that the Caribbean had to offer. Once we swam out so far not It was Jeffrey and the Guide together, Ghislane and Emmy, and I was
paying attention to our location and were carried out to sea by the current. paired up with Alexandria. Miles, the houseman, came with us and stayed
We took turns on the backs of each other, taking breaks against the strong on the boat just in case something went wrong and lucky he did. We were
ocean tide. It was almost a possibility that we nearly drowned out there, if all too far under the water to hear his alarming screams of distress when
it weren't for some guys on a boat out fishing for the day when they shadow's lurking in the murky distance started appearing closer and
caught us in their view. They picked us up and brought us back to the closer. Ghislane actually looked frightened for once as she gave us the
island where we were reprimanded by a worried Jeffrey and Ghislane to signal to start ascending upwards, reminding us by holding her ears not to
first of all let someone know where we are going at all times, and never go up to quick or as we were previously warned before we could pop a
to lose sight of the shore while out for a swim. After that learning blood vessel in our brain and hemorrhage to death, not a very lovely
experience I took their heed and proceeded with caution. I had a image but neither was getting tom apart by sharks.Those giant shadows
newfound respect for the ocean and it's mysteries. became clearer and soon enough we could recognize their indistinct
Having such a lover of the water as a guest, made Jeffrey want to species as the terrifying and more aggressive breed of sharks, the
explore parts of his Caribbean he had never seen before. The next hammerhead. Grabbing Miles hand I was the last one ahead of the Guide
morning we were met by a scuba instructor in St. James and given a few to get on the boat imaging the worst as I waited behind Emmy and
lessons in how to use the gear and more tips like how to descend slowly Alexandria who were the next to follow after Jeffrey and Ghislane I was
to the ocean floor as not to cause blood clots as well as visual hand in too much shock to scream or cry, I just told myself I had to stay calm
signals to communicate underwater. It was so exhilarating beneath the to get out of this alive. Unlucky for us we found out later on that we were
waters surface. No voices to listen too, only the enchanting sights to take in their breeding territory and being sent a clear message that we were
in. We explored the surrounding reef and found a large squid, many of soon to be on the menu to their feeding frenzy.
sea urchins, and the magnificent colored coral that housed a many of the We all felt like we had cheated death and I know it wasn't only my
rich variety of the local species of fish. It was such a great sight to take heart that was still beating out ofmy chest when we headed back to
in. Holding a permanent mental picture of those adventures to carry in my Jeffrey's island. Jeffrey was pale as his designer sheets and looked like he
head for all times. had aged another ten years in such a scared state. Ghislane took the heat
We all had such a great time that Jeffrey hired the same scuba off herself even barely taking a notice of beforehand and decided to poke
instructor to come out the next day to scuba dive the safer parts around fun at all ofus frantically scurrying to get out of the water, it was just her
his island. We got bored quickly with not much to see but seaweed and a nature, as I had never seen her move so quickly either. We got back to the
fish here and there. It didn't take long before Ghislane decided for us all island and all collapsed our fatigued bodies in our own beds for a long
to explore other numerous locations by boat, Jeffrey needed a bit of nap. Freshened up and much more relaxed we regaled our horrendous
convincing at first and the instructor was quick to assure him that he story again over dinner, this time in laughter. The following afternoon
knew his way well around these waters, of course he would say that, he Ghislane piloted us all in the helicopter to St. John's Airport and we said
was getting paid a hell of a lot to do this in the first place, why not extend good-bye to Alexandra where we all parted ways. I met her a few more
it a few more hours? separate times in Palm Beach at Jeffrey's Mansion, but she wasn't a
The clear water glistened and the tropical array of marine life was on regular of his, probably not as easy as the troubled girls were to bribe.
display as we wanted to stop at so many places but you could see as
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Chapter 11 We also visited his up and coming Paris apartment. It was a modem,
typical flat being refurbished, and we went to see how it was all looking.
Jeffrey liked to fuss about every detail and harass the builder's about their
Throughout the remainder of the quickly passing year I was on a
work, changing last minute details at a whim.
constant move with Jeffrey. Attending various dinner parties, mostly with
Days and many croissants later we left for Spain feeling bloated and
other esteemed billionaires and widely acclaimed scientists. Jeffrey likes
sleepy. We only stayed in Spain for the afternoon, going to see another
to surround himself with the most brilliant and powerful of minds, filling
astounding Moroccan castle for Jeffrey to replicate at one of his many
his little black book with some of the most esteemed and even infamous
people in today's wealthy society. It was during those intellectual mansions. It was only a short plane ride to Tangier, Africa for more
gatherings that my body was also put on the banquet menu but this time castles hopping. We arrived at the historic landmark and the only five star
for a powerful senator George Mitchell and another prominent Nobel- hotel in Tangier called El Minzah in the village of Ville Nouvelle. The
city and outskirts were still very hostile at the time, females being warned
Prize winning scientist who's name would be mentioned but for all the
life ofme can no longer remember. They would be only some of the to not walk the streets alone and not to leave the house after dark or be at
risk of being raped or worse.
recognizable figures of the high society that became added to my list of
When we got to the room, it was oozing with every expected bit of
clientele, of course being introduced to for a lot more than just a client of
extravagance that a luxurious historical palace should offer until I was
massage.
As an amusement to Jeffrey's associates I also knew my place was to greeted with a pile of monkey poo in the very middle ofmy bed. Not a
happy camper I called Jeffrey, Ghislane and Emmy into my adjoining
entertain but not to every desired content. I was to show them a good time
room and they all had quite a good laugh at my expense. Within a
but not the way I would have to use technique and effort for Jeffrey. The
very teachings from Jeffrey himself, or my tutor, as he liked to so moments notice of a complaint call to the front desk and we had an
attendant cleaning up my bed linen. The cleaner noticed the window was
eloquently put it. Consistently being used and adored for the likeliness of
still opened, he warned not to leave it ajar at nighttime just in case
my youthful looks I was becoming very accustomed to my lifestyle with
Jeffrey, never really relaxing into it, but just accepting this as being as another monkey wanted to make himself comfortable in my quarters.
Ghislane joked that maybe I should keep it open I might find a suitable
good as it will ever get for me. I didn't think I should be complaining,
husband before I get any older. Always the instigator ofa good joke but
wasn't I being offered a life in exchange for servitude? Just letting the
unable to take one herself she didn't like when I poked back that it was
signs ofmy anxiety and depression pass me by while I blanketed them
more in her recent taste of men, since she loved to brag about her
with my pills, suffocating under a blanket of pain is all I was really doing.
rendezvous with her various lovers. Once she came back giddy as a
I spent Christmas and the New Years holidays with Jeffrey in N.Y.C,
schoolgirl with an explosion of news, with all the build up and excitement
who doesn't celebrate the occasion, as he is of Jewish descent. Not that
in her voice you'd think she was the next crown princess, but she had
he was a religious man anyways, I never even saw him celebrate
given George Clooney a blowjob in the bathroom at some random event,
Hanukah either. We firstly stayed at his ranch in Santa Fe for a week,
she never let that one down.
then left for a long plane trip to Paris, France where we all suffered jet lag
We all went to explore the towns surrounding Moroccan castles and
for the next twenty four hours. We all stayed in a grand hotel with a view
meet their royalty that lived in them. Jeffrey's personal interior designer's
the Champs' Elyse.
met us at the residences. They walked around hurriedly, scribbling notes
Emmy and I shared a room and with her gifted ability to make new
contacts in just a few hours, she brought out a jay to share on the rooftop into their clipboards and whispering between themselves. The palaces
were historically unique and beautiful but I wondered how could they live
at nighttime while we were overlooking the lit up Eiffel Tower. We never
so grandeur behind these walls when they lived in a city of such poverty
got really close as buddies but we both knew what we were indebted to
stricken squabble. Beggars lined the streets, people could just go missing
and felt each other's sorrows. All four of us went out shopping at Chanel,
and no one could care less, and you heard of barbaric murders happening
D&G, Ralph Lauren, and many other little exclusive boutiques the
every night. Against the advice of the Palace Attendant and Jeffrey's
following afternoon. As a gift Jeffrey bought me a white terry clothed
wishes, I decided to take a stroll one afternoon, mainly just to take photos
goose feathered sofa and had it sent back to my apartment in Florida, and
of exotic Africa and do some shopping in the village markets but I ended
bought some new tapestries to have sent back to Santa Fe for his ranch.
up being intrigued by a group of young children playing in the streets.
71 72
When I was noticed watching them, about fifteen of them came up to me When we left for the final destination of our trip I was looking forward to
and began to beg for money and food. I was over taken by the poor, eating normal food again, not one to stray for foreign dishes, I'm a more
hungry children and I felt sad for them all and wished I could help out of a cheeseburger and pizza kind of girl, a true sign of my American
somehow. When the tide of kids washed away and the street went empty, heritage.
I was overcome with intrigue at these two little boys. Brothers I found out We landed at the Heathrow Int'! Airport and greeted by a driver that
later on, and there only toy was an empty can they were kicking to each would take us to Ghislane's town house in London's central that Jeffrey
other in the middle of the street. Intelligent kids, they were able to speak had recently bought and refurbished as a gift for her. Emmy said "Good-
three different languages, including English and I was interested to ask Bye" at the airport, leaving us to go to her hometown in the rural
them about life here. They didn't seem to notice or be bothered by their countryside nearby to visit family for a six-week holiday from work. It
poverty stricken lives. They told me about their school and parents and I wasn't a very long drive before we were in the heart of the city and at
thought I had just heard the saddest story ever but they were accustomed Ghislane's place. I thought it was a cheery townhouse that had character
to living like that like I had been so accustomed to my degrading lifestyle and the historical pub in front of it and cobblestone streets only added a
for so long. unique charm to its presence. They were going out for dinner and invited
I was compelled to empty out the contents ofmy purse, giving them me along with them but seeing I was so exhausted from all the travelling
over two thousand dollars in U.S currency. A passer-byer snapped a and looking a bit melancholy, I apologetically declined going out for
photo of the kids and me for 111yself to take home as a personal souvenir dinner that evening, I rather would be taking a few pills to catch up on
before they rushed home to proudly show there parents the money. I told some needed sleep. "Are you sure your Okay"? Ghislane asked as she
Jeffrey later on of my good deed and he couldn't believe I'd give away showed me to my room, more considerate than she normally was but I
my money so carelessly. He told me I had set up their parents with assured her that I was in absolute good health, just tired from all of the
enough money to feed and shelter their family for a year. Wasn't that a recent jet lag. Without another word said she whisked off downstairs, to
good thing? I couldn't believe it, not that I was well off or anything close the car where Jeffrey was waiting for her.
too it, but to realize how lucky I was and to not have compassion for the I took the liberty to call my parents house to say "Hello" and catch up
lesser off, especially children of a third- world country, I wouldn't be with them since I hadn't been home at all for the holiday season this year,
human anymore. Then again what did I expect from someone who could always too busy working. They sounded really happy to hear from me
numerously steal another man's daughter for the use of his own sexual and my mom put me on the phone to talk to my brothers as well. I got to
pleasure with great ease. tell them about my travels abroad and I had some cool tribal stuff from
We went out to lunch the following day with Jeffrey's team of Africa that I bought for them. They sounded so proud ofme, all of them,
designers to wrap things up and after Jeffrey's afternoon massage he went and why shouldn't they be? In everyone's convinced mind I was making
to the palace to have a nap. When I was all alone I thought I'd go see the great money, travelling the world, and meeting new faces everywhere I
culture of the local unique markets again and this time buy some trinkets went, why should I spoil anyone's delusions, especially mine. I took my
to bring home. I got to sightseeing and took pictures of the legs oflamb sleeping tablets and had a bath before falling into a deep and much
hung over the blood drenched doorway over people's homes as to warn needed sleep.
off evil spirits and the ghettos where the local villager's called home. I The next morning I was woken up by Ghislane who I could tell was in a
walked into many of the market's stalls and saw the most peculiar chirpy mood by the way she paraded through my closed door saying
antiques, such as weaponry with the blood of it's last victim stained on "Wake-up sleepy head" and opened the window's shutters to let in the
it's sharp blades and body pieces of various animal's for the use of bright sunlight, she had never done anything like this before and I knew
religious sacrifices. I was more interested in the different culture and immediately something big was happening. She sat down on my bed as I
respecting their ancient way of life with interest, instead of squirming like rolled over from my deep slumber and I was able to mutter for an
a tourist and getting grossed out. I thought it was so educational and explanation as to why she was awake so early. "Besides the fact it is ten
enthralling in fact, I ended up buying a few sacrificial trinkets to have o'clock in the morning and nearly time for brunch, we have a big day
sent to my apartment in Palm Beach. Not to say that I wasn't looking planned out for you today." She was waiting for my cue to ask her "What
forward to getting back to the luxuries of western civilization it was a bit are we doing", when I did, she responded with a convincing enthusiasm
like camping, fun and adventurous but as equally dangerous and thrilling. "We're going shopping for a new ensemble" she paused for a moment to
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build the suspense, before completing her sentence" To go dancing with the picture and in a hushed voice proceeded to tell me that it was a
a Prince of England this evening". Hoping it would be one of the younger portrait ofGhislane's childhood, the part she could be proud of. I never
generations, I was disappointed when she told me he was the Duke of realized how prominent her family's history was in England, apparently
York, Charles's younger brother Andrew. I looked at her with a fake as to Jeffrey's attest, her Father was born of poor Jewish decent in
surprised look, one I had to use on many occasions in my time with them, Czechoslovakia, most of his family being killed upon Nazi invasion in
to give an impression of excitement. "What ... wow!" I exclaimed with my 1939. Fleeing to join the British Army as a young man, he changed his
gifted acting ability. It is a sad realization but I had grown more name a few times and made a lot of contacts in the field. After the war, a
accustomed to seeing people for their significance rather than the good newfound Robert Maxwell went into publishing using his army contacts
qualities they possessed, and was able to grin & bear the thought of what to establish a business initially built upon publishing scientific books
I expected lay in store for me. from occupied Germany. In time, Maxwell acquired several British
Ghislane and I left shortly thereafter for the many lanes of designer newspapers, among them the Daily Mirror, countering his wits against
shops to choose from in London. Her pep talks to prepare me for my the likes of Rupert Murdoch along the way. However, whilst constructing
duties towards royalty went on and on, giving me the obscure impression his publishing empire, Maxwell compiled astronomical debts, and his
I was something of importance, at least for more than an evening. "Make equivocal financial dealings attracted the attention of governing
sure your bubbly and energetic, nobody want's a dead horse" was one of authorities that judged him not to be looking out for his companies best
the cheap tools she instilled me with. "Who knows where this could lead interest and in the end it transpired that Robert Maxwell had been using
for you" was another. As the day grew shorter my anxiety only proceeds from his employees pension funds to meet his financial debts,
heightened, anticipating the Prince's arrival and unable to decide on an ruining the futures of thousands of employees. Once an esteemed
outfit, I picked out three. Our last stop for the day was Burberry's for a Member of Parliament and publishing mob'lll, Robert's body was found
nice handbag to compliment our chosen attire. We got back to her floating in the Atlantic Ocean after he was found to be missing from his
townhouse with still a couple hours spare to get ready. After trying on all yacht, the Lady Ghislane (named after his favorite child), whilst cruising
three outfits and many mental debates with myself later, I decided on the the Canary Islands in 1991. Jeffrey went on to tell me that when her
pink mini-tee and dazzling pair of denims with horses embroidered into a Father died she was inconsolable, and in a very bad state. He picked her
pattern. It seemed a lot more my style and age group rather than the other up from the trenches of despair and took her under his wing, and it's there
two older looking sophisticated dresses I had picked out. I told myself I she has stayed comfortable ever since. To Ghislane his peculiar need to
was going dancing at a club not to an opera. As most young girls can be have so many woman around and even his taste in younger than legal
during their body changes into womanhood, I felt awkward, you know, one's didn't seem unconventional to her. It was her own Father who was
big feet, freckles and body hair in unwanted places. They're things you deemed a womanizer and even took a second wife whilst still married to
just don't want when your seventeen and then you see these iconic Ghislane's mother. I would have never guessed this carefree, spirited, and
billboards of what femininity is supposed to represent and just don't fit vivacious woman had ever endured such sorrows. I couldn't help but look
into that picture, never feeling what we all are already ... absolutely at her in a different light from then on, but not letting her know that I
perfect. By the time I had got ready I was a nervous wreck, but trying to knew, to avoid any altercations between us.
keep my cool on the outside was an act. I thought it'd be a good idea to Like clockwork Ghislane came downstairs five minutes before Prince
take a few Xanax before the evening unraveled and my anxiety went Andrew were to arrive, wearing a tight-fitted white wooly turtleneck
through the roof. singlet and a nice pair of loose fitting trousers. Looking elegant and
Jeffrey and I were sitting in the lounge room downstairs, waiting for casual at the same time, a very hard look to achieve but one Ghislane had
Ghislane to finish getting ready. The room was silent, only stillness in the always easily mastered. They both seemed at ease poking fun at my
air. I stared at the mural painted onto the wall that I was facing. It was an obvious nervous state, just another ordinary night out for this
interesting piece of artwork. In great detail it illustrated a happy looking extraordinary couple. The knock came at the door just after six o'clock in
family sitting on a bench overlooking a pond that resided on a large piece the evening. Ghislane greeted him and the guard who would wait for his
of land with a beautiful home displayed. There were also hunting hounds return in the car. She led him down the hall to where Jeffrey and I were
and the hunters chasing a game of fox like the notorious "English Hunt sitting. We both stood up and Jeffrey shook his hand, while Ghislane
Pieces" throughout history. Jeffrey took notice ofmy enchantment into proceeded to introduce me and as I was taught by her was English
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custom, we both kissed on the check. We all sat down on the lounges for that he was in public, he was whispering sweet nothings into my ear and
some tea and biscuits while conversing idle chitchat. By the sounds ofit, kissing my neck. I would just giggle not really knowing how to reply to
Ghislane knew well of his recently divorced x-wife Fergie, whom they an aging man with a bad smile and terrible moves, it would sound too
were all taking turns in slandering her for one reason or another. It was much of a lie if I retaliated back about his swagger. He was the most
apparent there were some fresh wounds still lingering on and as good incredibly hideous dancer I had ever seen and couldn't help but laughing
friends do, it was their way of helping him get over her. When his on the dance floor and shooting glances of embarrassment to Jeffrey and
daughters were mentioned, Ghislane and Jeffrey treaded lightly, only Ghislane who were having a good time laughing at my expense ... as the
speaking highly of them, and offering their sympathy to the young ones. always did.
The conversation turned to a much lighter subject. Andrew wanted to After an hour of pelvic smashing to the DJ's pumping mixes we finally
know more about this young guest they had to join them out for dinner exited the floor, his royal highness was dripping with sweat and ready to
and dancing that evening and then the spotlight turned on me. I was more embark onto a quieter scene where he said we could be alone, not
nervous than I had ever been before a night out with someone, probably knowing that it had already been arranged for all ofus to meet back at
the build-up Ghislane and Jeffrey had hyped this meeting up to be. To Ghislane's place but complied with his so called thoughtful request. I was
break the ice, she played her favorite guessing game ... "how old do you so anxious about getting back to the townhouse, knowing what
think Jenna is"? When Andrew guessed correctly, I was seventeen years expectations I would have to not only have meet but also exceed in this
old, she was surprised, thinking I could have passed for younger. "I guess case. Ghislane and Jeffrey seemed impressed at my attempts to entertain
we are going to have to trade you in soon" she laughed, always the first his royal highness, so far giving him exactly what he wanted the
one to throw in her quick-witted two bits, all of them chuckling along impression that I idolized him. They told me that he really liked me and
with her. Hardly a laugh at all, unknown to me at the time his eldest was having a great time, so far tonight. When we got to the townhouse,
daughter is only five years my junior. I was finding it hard to make much his guards walked him to the door, staying to wait outside in the car.
conversation in the beginning,just laughing when the occasion called for Ghislane met him and brought him upstairs where Jeffrey and I were in
it, and keeping up with Andrew's constant glances in my direction, was the study. We all chatted in the hall for a few minutes and I was able to
all I could manage. have Jeffrey snap a photo of us together, one that would cause much
The restaurant was a close drive for us with Andrew, his two guards and controversy for the Buckingham Palace in many years to come. The
his driver following behind us. I was seated next to the Prince for dinner conversation didn't linger on much longer before Jeffrey and Ghislane
and Ghislane and Jeffrey next to each other, an evening pre-ordained. I dispersed downstairs together, leaving me to my own sort of royal duties.
was supposed to flatter him with compliments and dote on his every word They walked away giddy as if they were teenagers imposing on young
spoken, but I didn't even do that for Jeffrey blatantly, it would've felt lovers about to embark on a romantic evening.
awkward to act like a bimbo for him. Instead I remained calm, cool, and Next to the study was the bathroom where I led him to next. The room
collected, hoping that my nervousness wouldn't spill out at any given was dimly lit masking the light from showing the disparity in my eyes. It
moment. The next place we were going was much more my style, and I was a beige marble tiled floor with porcelain Victorian style bathtub in
found it easier to relax. We pulled up next to a Nightclub called "Tramp", the middle of the room and nowhere near the size of Jeffrey's residences.
a member's only nightclub, and one of the most exclusive haunts in the I turned on the taps for the tub and the heat from the water began to steam
world for the rich and famous to be seen for the last forty or so years up the small room. On the basin were aromatic oils, lotions and soaps,
since it's doors first opened. Andrew's guards waited outside while we all loving the scent of floral notes, I poured in the lavender bath oil. Trying
went in to hit the dance floor. Jeffrey being the social introvert that he to do the best of my youthfulness to try and act seductive, I gradually
was found the first available empty seat in the comer but facing the dance began to strip off my clothing, piece by piece. Giving him time to savor
floor to spend the evening watching everyone else have fun and Andrew the moment to come. He loved every second ofit as I went over to where
went to the bar to grab us all drinks. He came back with sparkling water he was waiting and watching, then began to undress him at a much
for Jeffrey and a cocktail for the rest of us, already knowing that Jeffrey quicker pace. We kissed and touched each other before submersing into
never drank alcohol. We downed our glasses and made our way to the the hot water, where we both continued to reenact foreplay. He was
crowded dance floor, where I had the Prince's upmost attention. Moving adorning my young body, particularly my feet, caressing my toes and
his hands across the curves of my body, not to shy away from the fact licking my arches. That was definitely a first for me and I couldn't help
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but laugh, I hoped he didn't expect the same treatment back. Through my like minds. Jeffrey didn't want to know the grim details of how it all
recent experiences with Rena, I drew a line with extreme fetishes, happened on my intimate night with the Prince, he just asked simply if I
especially ones that would involve my tongue and feet in the same thought that I did well in keeping his friend happy. Knowing already that
sentence. It wasn't hard to get him wound up to the point where he just the evaluation ofmy performance 1 gave was already discussed between
wanted to have the rest ofme so we dried off from the cold and retired to them, I just as simply replied back with a nod of approval. Though I did
my bedchambers for the longest ten minutes of my life. Moments later have a laugh with Jeffrey about the Prince's weird fixation on my feet
and without any real emotional attachment, he burst in ecstasy, leaving and lets just say that he was quite tickled with Andrew's quirky
me to my own feelings of dismay. As relieved as I was to see the obsession, having a good ol'chuckle at my eccentric encounter. I was
experience come to pass with him, it was finally sinking in that I would paid extremely well this time, putting my money earned into nothing but
never be anything more than but a muse. Still trying to ascertain a surreal popping pills and alcohol by shouting my so called friends a good time,
dream a young girl once held but no longer the same girl I was no longer aiming for the attempt to forget about my experiences abroad. I partied
sure that the dream was even real anymore. In the whirlwind thrown like that to feel young again, my age and most of all to self-anesthetize
together by wealth, power, and privilege I was but a grain of sand and felt my troubles from within. It wasn't like I was waiting for someone to
helpless down the road 1 was naively being led down. When the real arrive on his white horse and take me away to a magical world. I simply
picture was unveiled, later in my life, I had nothing but memories filled yearned for more out of life than being someone's replaceable
with sorrow to remember of my teenage years. amusement. Still a romantic at heart I would often get lost in my
Jeffrey, Ghislane, and I left for the states to conclude our long journey daydreams, imagining a new beginning with a strong man that would
home to the U.S.A. I was so happy when we landed on our soil and called show me an enduring love, safety in his arms, and a lifetime friendship.
T.J from my cell phone to see if he'd meet me at the airport instead of Though the suggestion of true loves existence was only a dream for now,
going back to Jeffrey's, he'd be there within twenty minutes, he was so something I could only read about in novelistic fairytales but the passing
happy to hear my voice and that I was back in town. So ecstatic to be thought from time to time was wannly envisioned. With my inner most
getting away from my life of servitude for the next few days, I was sourly desires being locked away in a deep crevice of my heart, I knew my
disappointed when I got off the phone. As if he'd been listening to my romantic notions would be absurd in Jeffrey's eyes. For some unknown
entire conversation, Jeffrey told me he'd like a massage back at his place reason to me he couldn't allow himself to give love or receive someone's
and he could pay me at the same time for my trip with him. With much heart in return. Once he said to me when I asked him ifhe ever thought
dismay I had to call T.J back and cancel the arrangements, I wouldn't see he would settle down and find Mrs. Right and he told me he didn't
him until later that night, in which one of Jeffrey's staff would drive me believe that love with one monogamous partner was possible but he
home and I would be too exhausted to do anything. found that love with many was. 1 thought at the time it had something to
do with having so much money and everyone wanting him for that
instead of seeing him as a person and even felt bad for him, but now I can
understand from his recent lessons unlearned that it was a simple
equation of his twisted perversion to become infatuated with the
vulnerable youth off the streets. Spending so much time in the entrapment
Chapter 12 of Jeffrey's embrace, I was becoming numb to the feelings and aspiration
to ever climb above this deep hole I had dug myself into. I knew I wanted
to escape from this bizarre form of first class slavery but I still didn't
have the tools necessary to help me get out. How could I have? Everyone
When we got back to Jeffrey's mansion in Palm Beach he wanted to that knew me believed I was living this enchanting life, a rags to riches
thank me for showing his friend, the Prince, such a good time. Rewarding success story that most people dream of, only I knew the price to be paid
my diligence with an extra sum of money and luring me deeper into his for all of this and I was the only one who could pay for it.
goal of keeping me at his side as his personal amusement that he could Underestimating my true self, I was settled by Jeffrey's side for now
lend out at anytime. Further proving his capability of using the vulnerable considering him to be someone to look up to, my mentor. Such a
impressions ofa young girl to influence and intimidate his fellow peers of
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complicated battle within myself, it is one I still ache to fully comprehend encounters with Jeffrey's "staff' but I led the way anyways, as ifhe was
today. now my guest of honor. Entering into the dim room it took a few minutes
Sunny spring days melted away the ice off the frozen streets of New for my eyes to adjust to the darkness, but knowing my way around the
York and the harsh winter winds begun to gently blow away the dead room was enough to find the shower. I turned on the steam room and
leaves, making the caged trees appear to have some form of life again. I began to undress myself. Andrew followed my lead and disrobed,
hated the cold winters there, it would only add to my depression being throwing his attire to the floor. I wanted to run and hide feeling his hands
locked indoors. Give me hot Florida days blistering in the sun where I touch me again, but my servitude for Jeffrey kept me there. Getting out of
can swelter by a cool pool and sip cocktails with pieces of fruit and little his stronghold I turned my attention to the steam filling up and tried to
oriental umbrella's floating around. What a vision of solace? Looking tum his attention to the marble bench where I suggested he take a seat
around my extravagantly decorated mid-evil room I was reminded of the while I rubbed his feet. By the look in his eyes I knew he could care less
desolation that I was more than accustomed too. Knowing it wouldn't be about a foot massage, his real desires were being shown by the arousal
long before I was summoned again for another ritualistic occurrence in his body was forming. He indicated where he wanted me to touch him
fornicating with my master, I hardly bothered to leave my assigned and how. I fulfilled his seedy requests, but only just. There was no
chambers, scarcely being sent home for a moments break, I just accepted pleasure in this for me, the only thing I derived from this event was to
my fate. As I predicted the intercom buzzed momentarily and I heard sink further into my slumber of depression. I couldn't remember a time
Ghislane's voice come over and request to meet them in Jeffrey's study. when I felt needed for anything other than my body or amusements
Not an odd call, I would often meet him there first so he could tie up thereof. After his massage was thoroughly conducted I couldn't wait to
some unfinished business before heading to the dungeon, or what was get back to my room for another shower. Sitting on the floor of the
thought to be the massage room. Making my way down the hall, I had an shower under the harsh spray of water, I scrubbed my body where he
eerie feeling wash over me, as if I had several pairs of eyes on me, touched me. Feeling abhorrent and ashamed what I had become, I let the
watching my every move. A cold chill moved up my spine and I had to water wash away the grime.
move my thoughts elsewhere, too easy behind these walls to succumb to As the days progressed into nights and the nights followed a trail of
my fearsome anxieties. I punched in number one once inside the elevator destructive months, my outlook on life had diminished into utter sadness.
and it took me down to the floor where Jeffrey and his surprise guest I had lost my spark and my ability to look like I could handle the abusive
were waiting with anticipation behind closed doors. I cracked open the state of affairs I had drifted into. Sinking deeper in the euphoric state of
heavy wooden doors and a familiar face revealed itself. Definitely not being on coke and pills, not only was my mentality dwindling away but
expected or pre-warned on my part but I already knew what he was here also my looks. I sure as hell didn't feel like a seventeen year old anymore
for or at least why I was called down to the study. Prince Andrew had and now I wasn't looking like one. My eyes had dark circles underneath
that notorious cheesy grin slapped over his face, as he looked me up and them from not sleeping and my bones protruded from my skinny
down like a shiny new car on display and he was about to take it for a test waistline and chest. This made Jeffrey apprehensive in keeping me
drive. Ghislane led me to the decadent sofa he was lounging on and around as often and before I had a moments notice, I was out of money
twirled me around to give him a good lookover before sitting me down on and looking for a job. When I questioned him what was happening, he
his lap. Like a show pony I knew exactly how they wanted me to be told me I wasn't the same girl he had first met some time ago now and
paraded around, with the last of my dignity long lost, I had nothing more looked like I needed a break from working so much. " I'll call you next
to lose. It was easy to give them the reaction they desired, all I had too do time I'm in town" was the last thing he said to me.
was pretend to be entertained by their lewd gestures, and when Andrew
cupped my breast with a doll made in his image, I only giggled away.
Ghislane wanted to take a picture of the bizarre scene and even got Chapter 13
Johanna, another one of Jeffrey's so-called personal assistants, to come
Going back to an average teenagers life was more of a harder transition
sit on his other knee for the snapshot, giving the impression girls couldn't than I would've ever thought. Jeffrey stopped paying my expensive rent
stay away from Randy Andy. and I was forced to get off the drugs and look for a real job to feed and
Many crude jokes later and I was asked to show Andrew to the upstairs
shelter T .J and I. It was much harder than it sounded, but I was craving
massage room. I'm sure he already knew where it was from previous
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this in every possible way. Even though a week's wages for working a Obviously mentally distorted from whatever choice of drugs he was
full-time job as a waitress didn't come close to the money I had made in a smoking that night. He screamed down my apartment complex, going
couple hours of working for Jeffrey, I was happier than I had been in a mad and scaring my neighbors I felt like I had no choice but to let him
long time. I made some friends at my new job and found my duties to be inside. I tried talking to him as a good friend would, just wanting him to
easy and pleasant. I was good at making customers smile and keeping see what he was doing to himself and what he had become. Part ofme
them happy becoming the waitress that made the most tips for the night, still loved him and took pity on watching him spiral downwards. Taking
which in tum made my co-workers happy since we'd all split the tips at him back into my life was not a decision 1 made whole-heartedly, but was
the end of the week. For the first time in a long time I had boys my age something I did out of guilt and what I thought was loyalty. He moved his
hitting onto me, and not that I was ever taken aback by there attempts but clothes back to my place, which was all he ever owned anyways and we
it reminded me of how it felt to be around a younger crowd. I missed so tried to pick up the broken pieces. T .J being still badly addicted to many
much of what I couldn't get back and the more I tasted it, the more I drugs, I had to be very careful where I kept my jewelry and expensive
remembered how to smile. The relationship between T.J and I began to items. I decided to rent out a space at a local spot and store my cherished
falter in a way that was beyond reconciliation. Fights became physical items away, just taking the necessary precautions, I thought.
and I saw sides to him that only pushed me away more. He refused to Still not working I knew how he was scraping by money and 1 didn't
look for work to help pay bills and he became utterly frustrated not agree with it, T.J was a known thief and had been caught several times
having his usual cocktail of assorted drugs to keep him from feeling attempting to steal things, even as stupid as DVD's and PS2 or Xbox
anything at all. He didn't like the fact l was growing inside and thinking games from a local Blockbuster. He even stole from his parents, his sister
beyond his elusive world. I had gone through too much to accept another and his brother and would probably steal a piece of candy from a five
form of abuse and degradation. Making that point very clear to him by year old kid ifhe knew that it would get him his next fix. He hated the
kicking him out of my apartment back to live with his parents, I felt change in myself, realizing I couldn't be brought back down by his ways
liberated like never before. I kept up with my rent and cleaned my act up. but knowing I still stuck by his side and defended him from anything that
Enrolling in a yoga course and keeping my focus on staying fit and would hurt him wanting to believe that he still wanted show the bits of
healthy became my only source of enjoyment. I was free and living for human nature left in his empty heart.
myself. Unable to stand by and see me do well for myself he contemplated a
While out doing the grocery shopping one evening I couldn't help but way to try and bring me down. After a busy shift one night, he retaliated
stop at the local pet store and fell in love with a furry pooch. She was a with another show of control. I had just finished cleaning up my area and
Japanese Chow-Chow and a bundle of fur that more resembled a baby setting out the tables to be ready for the next day when I went to the bar
brown bear than a dog. 1 took her home with me and instantly she became to hang up my apron and put my nights tips in the tip bowl on the counter
my best friend. We went for several walks a day and she bore the brunt of by the beer tap. On one of his drug induced rampages he stormed into the
many tear filled conversations, she was my loyal companion who restaurant where 1was working and started to pick a fight with me. 1
understood more than anyone had before, all I really need was someone knew he was off his face when he started accusing me of sleeping with
to listen and funny enough it was her that filled that hole. my manager on shift that evening. Having no bias or ground to stand on
Nearly three months had gone by and not a word from Jeffrey or in his attempt to make me look bad in front of everyone, I just laughed
Ghislane. With T.J out of the picture now too all I had to concentrate on him off as a drunk idiot who needed to go home and sleep off the night's
was work, my parents and brothers, and of course my dog, Mary-Jane. I repercussions, although I was fuming inside that he embarrassed me but I
was going to family night dinners and hon fires again. My older brother still made excuses for him and told my boss I had to leave early to bring
was getting married to an amazing woman in a few weeks and I got to be him home.
apart of their beautiful ceremony. Small details oflife's journey that I The bar was deserted as T.J waited alone for me slumped in a barstool
already missed so much of and now being able to smile at the simple and looking worse for wear. l had to go to the back of the restaurant and
things day in day out really seemed to put the real value oflife into do some explaining to tl1e manager on duty, I couldn't afford to lose my
perspective for me. Everything seemed to be working out for itself and 1 job over this incident. Surprisingly he was sympathetic towards my
was really happy, until he came back, T.J thought he'd come over my dilemma and even told me I could do a lot better than that schmuck,
place one evening while I was sitting at home just watching TV. patting my back and telling me to have a couple days off. 1 punched out
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and headed to my car with T .J in tow. For the rest of the night he was desk and told me to have a seat across from him. He took a sip of water
oddly quiet and asked to be dropped off at his parent's house, I was more from an already poured glass and asked ifl'd like some. "Yes, Thank
than obliged to do so. Tcouldn't stand the sight of him let alone want to you" My reply was short and polite, already just wanting to get this
be around him tonight. Being so revved up it didn't yet dawn on me that meeting done and over with. His face was like steel and his expressions
something wasn't right. The next morning Twas woken up by an alerting were stem, Tfelt like a child in trouble sitting in the principles office.
phone call, I had the manager from the restaurant where I worked, on the He cut straight to the chase wanting to know "Are you on drugs
other end screaming at me and asking where the money is. I sat up in bed, anymore?" There was a moment's pause as I took a deep breath and told
completely awake now, and asked him back, "What are you talking him the entire truth. "I got really depressed for awhile and coped with my
about, what money?" His tone had calmed a bit and he could hear the emotions by blanketing them with mind-altering substances. Just smoking
earnestly in my voice and explained his accusations "The tip jar was a jay to relax wasn't good enough anymore. I needed to be high and
empty after you had left last night and there was over a hundred and fifty flying to believe Twas happy and dealing with all oflife's curveballs.
dollars in there, now it's missing". The answer hit me instantly and I got Snorting things like coke and popping amphetamines replaced my
a terrible knot in my stomach ... T..T.When Tleft him at the bar not even sorrows with an overflow of endorphins, making it possible to keep up
thinking about the tip bowl to talk with the manager, he saw an with everything, until I would come down and the cycle just kept on
opportunity to fund more drugs and he took it. That's why he didn't even repeating itself'.
want to come back to my apartment last night. It was all too clear for me He listened to me continue to tell him about the good things that have
now and I tried to explain to my manager about my boyfriend's sickness come from the break. Like my dog, yoga, and working at a restaurant,
and asked him to take the lost money out of my wages. "I have no choice making lots of new friends but most of all, I got my smile back, without
but to let you go and file a police report for the missing money". I the drugs this time. He was really happy to hear the upside of everything,
couldn't believe what I was hearing. How did things tum upside down so but there was one thing I was reluctant to tell him about. My recent
quickly? I exclaimed "Even though I'm paying you from my pocket for travail that T.J effortlessly caused at the restaurant where I was so happily
money I didn't even steal and you've never even had any problems from employed. As my manager had warned he had to file a police report
me before?". His apologies were short and icy, nothing that could be stating that after I had left, the tips were gone, putting the blame solely on
done. I slammed down the receiver only to pick it up again to dial I.J's me.
parents house and to no surprise he hadn't slept there last night and was Giving Jeffrey a clear picture of the entire ordeal he exclaimed "What
not able to be reached. Tfelt like Twas in a bad dream Tcouldn't wake up are you doing with this idiot Jenna, he is no good for you! Tknow you can
from and with no money to pay rent, eat, or even survive, I was back to do better for yourself, why do you let him drag you down every time?"
the drawing board. Nodding my head in concurrence I went on to finish my epic drama. "I
The week passed without hearing from T.J, he was in hiding, for now. received a phone call from the PBCP asking me to come in about the
When the phone rang early one morning I expected it to be him, instead it money, I told them what happened over the phone but they still want me
was a surprise phone call from a familiar voice. Jeffrey decided to give to come in. I don't want to have a record for something I never did or
me a call to invite me over to his Palm Beach mansion for some lunch ever would do!" Tput my face into my hands and covered the tears now
and to catch up, it really was just his way of finding out ifl was cleaned trickling down my cheeks. "I just can't believe this is happening to me
up and ready to come back to work for him. With my life in chaos once when everything has been going so uphill, now I'm out of work and in
again and having to borrow money off my parents for grocery food, Tsaw trouble" I wiped my face and looked up at him " What do I do?" Enabling
a quick solution to my situation and was even convinced this is what T him as my mentor once again, his sly grin said it all. Jeffrey normally
had to do to take care of myself. hated when girls made waves in any way and this one would be
He greeted me at the door and led me inside. Ghislane was at her usual considered a tsunami but this time it worked to his favor. He wanted me
spot, her desk working away, and we headed past her with a quick wave to come back to work for him, continuing my massage studies and I
and lip-synced a "Hello", not wanting to disturb her important sounding needed his help. In his eyes he was doing me a solid, which in return I
phone call. She glanced up quickly and gave a brisk wave my way, then would have to scratch more than his back for. Taking his time to
put her attention back to the computer. Once we were inside the poolside contemplate what to respond back and what solution he could offer, T
cabana, which was Jeffrey's office, & gym, Jeffrey took a seat behind his began to worry that maybe I shouldn't have done this.
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Pulling a few tissues out of the box, he passed them across the desk to ultimately became close pals and he invested one million dollars into
me. Trying to retract any damage done I said to him "I must look like Brunel's company. In return Jeffrey now had supply of girls on tap for
such a mess to you and making you listen to my saga, I am so sorry ... I him to choose from.
shouldn't have come to you with all of this." He looked surprised and With the assistance of each other, Brunel obtaining the illegitimate
sympathetic "Quite the opposite actually. I'm glad you've come to me for visas for underage-overseas girls and Jeffrey housing them at his
help. I have got a lot of connections especially with the Palm Beach brother's apartment complex on 301 E 66 th St, Manhattan, they were
County Police Department. I give them reh>ularhundred thousand dollar quite the team. Jeffrey and Bmnel would charge them for rent, forcing
donations, and after I speak with them there will be nothing more to them to work for them selling their bodies for money, nude pictures, and
worry about. To be honest I'm more in shock about how much can even pornography. These were what seemed like really nice people with
happen to you in such a short time, your life is one big soap opera" not so nice intentions setting an impression of how the dignified wealth
Now he was chuckling and trying to make light of my somber mood. play and behind closed doors they had as much civilized manners as a
Laughing along too I replied, " I know right? Drama just hangs around barbaric chimpanzee in heat. Giving a girl a step-up in finances by
me like a bad smell". We did some more light-hearted catching up and teaching them there only worth is what lay between their legs, us girls all
went out to the poolside for some lunch and a swim, concluding the were the same in the end, regardless of what country we came from, what
evening with an erotic massage upstairs. He paid me the usual two language we spoke or our cultural indifferences, we all were being used
hundred dollars and asked me to come back tomorrow. "In the meantime for one thing alone, our youthful looks and beautiful bodies.
I don't want you thinking about your sticky situation, consider it dealt Being Jeffrey's permanent sidekick, I would have to part-take in a
with". His attempt to brighten my spirits had worked relieved about many of the hedonistic exploitations that went on at one of his many
money and the police but now I owed myself to him feeling indebted to residences, which meant having to be uninhibited with many girls my age
him more now than ever. and younger. Being complete strangers was hard enough but we couldn't
even understand each other, speaking in different tongues we were
expected to excel at preforming many acts of lovemaking and foreplay on
Chapter 14 each other, while being observed by a man in a comer jerking off. Not
exactly what I would call an advantage in my stage oflife, but in my head
I was convinced we all had to do what we had to do to get on with life
As was promised I never heard back from the Police Department and
and if that meant doing all of this to keep Jeffrey happy, then I would do
Jeffrey had his favorite girl back by his side. We picked up where we left
that.
off ever better than before, I being entirely subservient to every sexual
It didn't take long in the accompaniment of Brunel for Jeffrey to hit an
desire of his engaging myself in any role he wanted me to play. As he
all time low, at least one that I knew about. Stupid enough or sick
was getting older his appetite for sex never hazed, if anything it only
enough, I don't know which one it is or both but Jeffrey bragged about
increased. The orgies with other girls got larger in numbers and his
his birthday present from Brunel, once accepting three, twelve year old
appeal to younger girls, new toys and wilder nights expanded from once
girls, sisters at that. He replayed the descriptive events with me telling me
and awhile to quite an often occurrence in Jeffrey's company. I put it
down his new friend and business investment, Jean-Luc Brunel. how they all massaged him and finished him off orally. He was so excited
about the entire event, replaying over and over again over the next course
A long time agent for young and upcoming models, Brunel, a French
citizen, was known for roaming the world in search of young, nai"ve of weeks how cute they were and how you could tell they were really
young by the small amount of hair growth in their pubic region and non-
beauties living in poverty stricken countries and willing to do just about
existent breasts. A twelve year old, are you serious? I thought to myself.
anything for money. He would procure them mostly from Clubs in South
I still can't shake the feeling of disgust when I recall the look on his face
America and the Former Soviet Republic. Filling their heads with
as he told me time and time again of how his lust brought him to that
fairytales of America and large amounts of money, he would promise
profound low. He went on to tell me how Brunel bought them in Paris,
them all of the finer things in life, sometimes even throwing a pill in their
France, from their parents. Offering them the usual sums of money, visas,
drink, if that meant getting them in his bed was becoming too much of a
and modeling career prospects was a bribe of the worst kind, they were
task. What he wanted is what he got, which is why him and Jeffrey
just children. Laughing the whole way through, Jeffrey thought it was
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absolutely brilliant how easily money seduced all walks of life ... nothing I still was given proper training in massage therapy from time to time,
or no one that couldn't be bought in his eyes. Behind the two of them keeping me from looking back at being a teenager with no responsibilities
followed a destructive trail of those in their path that were misused, to being a young adult with prospering titles. He knew I wanted to be self-
violated, degraded in a variety of ways for one purpose ... to satisfy the sufficient so bad I would do anything for it and by giving me this dream
desires of the perversion that rotted their hearts. to hold to only kept me in check. I looked forward to my training
The next couple of months I spent in Jeffrey's company, my life was sessions, holding onto every word passed down to me and after the
revolved around him and his petty happiness. Arising to the occasion, I session was complete I would hurry back to my room and transfer the
was no longer his teenage sidekick, I was growing into being a young information into a workbook with associating exercises.
woman and my body was blossoming like never before. Out of the Trying my new moves on Jeffrey always impressed him, he would get
awkward stages of my life, I now took to looking after myself like never excited hearing about my passion for knowledge and would tell me he
before. Regular sessions in tanning beds and keeping fit became my life could see it transfer into my massages, always giving it my all, my hands
outside of Jeffrey. He kept telling me what a beautiful woman I was were a focused energy when I was at work. Using every ounce of strength
developing into and would offer suggestions to help me look good. to apply on a body, many were astounded in what I could do for being
Sending me to dentists for regular teeth whitening consultations or such a small girl, and Jeffrey loved it, using me for a two-hour massage
helping me choose my attire for the evening, he was ushering me into a "with benefits" sometimes being over twice a day. Ghislane would
whole new position, training me up for something else, but I was unsure sometimes use me to massage her still but it wasn't as common, she
of what that was. preferred a man for that job.
Being a snotty little teenager was a girl of the past. Now I had to be his Then would come the odd client here and there, of course set up by
eloquent speaking, desirable to all and almost his personal porcelain doll. Jeffrey. Most of which were orchestrated to get beautiful girls
I went everywhere with him again, all of his eclectic dinner parties, comfortable and consequently naked then he would go in for the kill, so
conferences, and meetings with various members of parliament, famous to speak, touching them intimately, in their most private of places like
celebrities, and other esteemed billionaires ... most of whom lived by the their vagina, breasts or anal. When he had us where he wanted, willing
same rule of thumb as Jeffrey did. Quite an alarming realization having to and able, then would come the toys, outfits and so on. A scheme he has
accept this world the way it is. Jeffrey knew all of the right people in this used time and time again, telling those who know him well "he had never
game, and trading girls for favors is how he kept in the circle. He was at been turned down yet". It was starting to dawn on me how I wasn't
the center of it all, blackmail being the only thing next to money with the getting any clientele that weren't used for Jeffrey's benefit and would
ability to pull a many of strings, his conniving ulterior motive was to drag make me wonder if I just wasn't good enough for that, but I kept quiet,
all that he could down to his pitiful state of mind. Inviting easily tempted never wanting to make waves like I had before.
acquaintances to his island or his other various residences he would bring To give me a break from it all as if Jeffrey didn't want to overload me
out the assortment of young girls and pass them around like they were again, he would send me away to his ranch for a few days, what he knew
cocktails on a platter. No girl had a choice in whom they went with, only I considered being a small slice of heaven on earth. I'd spend my days
completing a task, we would have to charm and bedazzle these ageing fat roaming the hills, riding horses, and enjoying the solitude ofmy own
men who other than paying for it would've never had a shot at getting to company. One afternoon I was out exploring the land on Jeffrey's ranch
know a beautiful girl intimately. I personally belonging to Jeffrey rarely which covered hundred's of acres with nothing but a bottle of water, my
had to be loaned out and it was a big occasion, or should I say favor, if I sketchbook and a small case of oil paint. I was on the search for
was. I'll never really know what made me so important or special to something interesting to paint. A great pastime of mine, it made my soul
Jeffrey, it definitely had nothing to do with love. I guess in the end I will quiet by creating beauty with my brush. I loved to recreate the images I
always put it down to my capability of being whomever he wanted when saw on paper. I would paint anything beautiful that caught me eyes
he wanted, so compliant it just made it easy for him to have a personal interest, from underwater scenes, animals to people and even frnit, I loved
toy at his constant disposal. All I can say is I lived in a jail with no bars, vibrant colors and emotion on display but my favorite soon became the
and in a country where slavery was supposedly abolished a long time ago landscape of the Santa Fe's rolling hills and earthly green and beige tones
but still existed right underneath everybody's noses. Myself and so many and in certain light it would illuminate into a golden shine. To grasp that
other girls were walking proof of it. feeling I was absolved in at the hardest of times became my greatest inner-
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achievement, like taking a piece of that serenity and putting on paper for could become a sight for historical preservation and that means the
me to keep in my heart where it still is today, closing my eyes I am able government could ultimately own my land."
to see it, being there anytime I need to. I was enjoying the heat and taking I acknowledged his request and told them they were just a gift for my
in the deserts sights when I stumbled off the track and into the Mom, who was in love with Indians "Wait until she see's I brought her
wilderness. Exploring everything new to me was my second nature and back real artifacts, she is going to totally freak out." He didn't mind that I
never even entered my mind what would've happened if I went too far or was taking them. In fact he admired my curiosity and adventurous spirit.
got lost. I would rather face Mother Nature's wrath than humankind's any He reminded me that tomorrow was my last day. I would be driven to the
day! Albuquerque International Airport the day after next, to meet Jeffrey in
After about an hour of drifting offtrack I came to a pile of rubble, New York, for how long, only he knew. Giving Jeffrey many thanks for a
looking like the remnants of an old pueblo made out of clay and rock. I great week, letting him know how much I appreciated these small breaks
picked up what looked like half of a clay bowl and noted that it had away, we then said goodnight. Hanging up the phone I had caught my
Indian designs etched into the side of it. Excited about my findings I second wind and set out to the kitchen to find a late-night snack. Raiding
decided to do some more exploring around the fields surrounding the the fridge and pantry, I found some frozen pizzas and popcorn. I put on a
historic site. I collected rare pieces of arrowheads, utensils, and parts of movie and munched on the popcorn while the pizza cooked. Some 1980's
many broken bowls with artwork telling tales of their own. Time was of dreadful alien flick got the better of me that night. It was based on a true
no essence here and before I even realized the sun had sunk deeper into story about people abductions from extraterrestrial beings, which were,
the hills leaving me without any light to find my way back to the like I was, visiting a remote area. I suddenly hated being alone on a ranch
pathway. Feeling silly now after passing by a familiar looking boulder in the middle of nowhere. I munched down my burnt, crunchy pizza and
twice over, I was startled when l heard some poor animal become dinner became further enveloped in the thick plot. Leaving on the TV and the
for another, it's screams of agony only amplified louder and echoed in lights on that night, I spent my night tossing and turning, peeking through
my ear drums, heightening the hairs on the back ofmy neck and making the small open crevices of the comforter, half expecting to see an alien
my heart beat nearly out of my chest. being in my bedroom.
I was lost and confused before but now I was petrified with fear. Living through the night was a relief and I laughed at myself in the
Taking me over three hours to find my way back to the path and in the morning, how spooked did I get? When I got to New York, Jeffrey, and
direction of Jeffrey's mansion was a mission, so relieved in the end and Ghislane had a good laugh over my tale of survival in the wilderness and
so were the housemaids after I hadn't showed up for dinner, assuming I then the alien scare. "Your always having the best adventures" Ghislane
must've been out for one ofmy usual adventures. I went to bed exclaimed. We were similar in that way, both beings bit of free spirits it
strenuously exhausted that night and as I was falling asleep the phone was really only her non-existence of moral standards that differentiated
rang, it was a call from Jeffrey who had been alerted ofmy the two ofus, in that way. "How do you know you weren't abducted and
disappearance. "What happened tonight, one of the maids called me to probed? I mean look at you and all that time alone on the ranch, what do
tell me you hadn't come back from your walk this evening" Detecting a you think Jeffrey, could she pass off as an alien?" Expectedly, Ghislane
tone of anger in his voice I tried to distract him by telling him ofmy poked fun at me, her usual fun past time. Our relationship was an odd
findings and he scolded me for being gone for so long without anyone one, never threatened by each other but always precautious towards one
knowing where I was. Going back to the Indian remnants, I persisted on another nonetheless able to crack a joke together, but when it came time
telling him what I had found. In the end he was just worried about me to "work" it was no fun and games, she was intensely serious. "With a
becoming a liability, but had to make it sound as ifhe cared." Don't sense of humor like yours I would tend to think that you are the one from
worry Jeffrey, I won't be doing that again. I can honestly say I have another planet." Just friendly banter between the two of us, then Jeffrey
learned my lesson and the next time I want to explore I promise to take had to jump in with his two bits, "I think you might be onto something
someone with me". I satisfied his worry of me being a future nuisance Ghislane." I squinted my eyes and gave them both an exaggerated death
and with that I was finally able to tell him what I had discovered on my stare and pretended to grab my stomach in pain, "I think some things
walk. He was impressed but did not sound surprised. "You must've been trying to get out ofme", putting my fist in my shirt to reenact a scene
gone a long time if you found the old Indian pueblo's, just be careful you from Alien, I fell onto the couch and faked my death. "I knew it"
don't say anything about where you found the stuff on my property, it Ghislane shouted and jumped on me to begin tickling me all over and we
91 92
all broke out into laughter. lt was those fun times that made me feel like I joined him for a shower, steam bath and concluded his needs with a
we were all apart of this really perplexed family. We did everything massage while listening to classical music. I knew he didn't want
together similar to normal families like eat dinner, watch TV, and travel it anything sexual from me now seeing he got what he already wanted
was only the hedonistic and corrupt side to these two deviates that made downstairs, no this one was purely therapeutic. My favorite massages to
them a peculiar pair. give, making me feel like an actual real therapist. I lathered him in
Getting turned on at the two of us playing together, Jeffrey came over aromatic oils and let my hands discover the ways to unlock the stresses
to the couch we were on and pulled down his sweatpants revealing his that his body held. After the massage was concluded we were going
erect manhood. All of the laughter stopped, now it was time for work. downstairs to get ready to go see Ghislane's townhouse as he had
Pushing my head into his pubic region 1 had to give into his perverted promised her earlier. He loved taking the hidden staircase while I hated it.
wants. Ghislane started to undress me. Once I was bare she loved starting I was so creeped out by his choice of decor, the blood red carpets, violent
with my breasts. She cupped them in her hands and brushed her fingers medieval paintings, and sculptures of the pagan god Pan, all ofit
over my hardened nipples heading downwards pressing her lips deeply representing the darker side of hedonism his lifestyle provoked. Spiraling
into my skin, I had to maneuver my body on the couch in a complex down the hallway along with each step you took came with a pair of eyes
position to give them both what they wanted. And just like that, without that followed your every step. Brown, blue, green, hazel, all of the colors
even a moment's notice I could be put on the spot and have to amuse were there, staring at you the entire way down. As each step progressed,
them in any way they wanted. A shameful way to make someone feel like so would my anxiety to get out of there.
a used toy, I wasn't around for companionship I was there for one thing, I We found Ghislane where we had left her, in her office. She had just
was a compliant piece of eye candy. received an order in, a satellite camera with a twelve-inch flat screen. She
Twenty minutes later and Jeffrey had erupted in pleasure. Ghislane sat told us how it was used to pick up any person in any location with the
up, still fully dressed, and wiped the sides of her mouth with her hands, quick insert of an address. Quite a powerful new toy I thought, but it was
giving a vindictive little chuckle, "That was fun." Jeffrey concurred with only a minute display of what the rich could afford, what use they would
a sly grin arching his back for a stretch just looking able to utter the get out of it was another concern. Soon after she was done figuring out
request "Why don't you come up with me upstairs for a steam bath and the controls on the camera, we made a rare and first for me pit stop, the
massage, I need to be loosened up after that?" It was more of a statement security room. What I thought was our way out by the front door was
than a request, as if I had the choice to say "No thanks, I'm actually tired another hidden door. I was in shock as I was led into a room, so discreet
myself and would love to just relax" instead I would reply with my that in three years I never even knew it existed. I kept my head down
accustomed trained obedience, "No problem, when your ready lead the most of the time, knowing how secretive this must be being another door
way." I had to get dressed again being that we were in Ghislane's was an entire security base within his mansion. What I could see when I
downstairs office. Putting my clothes back on, Ghislane thought she had stole a glimpse here and there was an array of tiny screens, twenty odd or
buttered him up just where she wanted him to ask for him to come have a something. Small screens showing various rooms of the mansion I had
look at her new townhouse renovations when he was finished with his recognized. The images were constantly changing so I found it hard to
massage. A very strange relationship those two have, there's a definite pinpoint an exact location but from the decor and short glimpses I
love flowing between them but not a passionate one, more like a suddenly knew from then on that my feelings of my every move being
respectful business, he gets what he wants ... an uncountable number of watched inside his corridors was now more than a possibility but was
girls and she gets what she wants, simple and sweet ... an uncountable actually happening. Jeffrey spoke to an obese Spanish guy at the desk,
amount of money. The two things in life that can create such beautiful whose job was to disgustingly overlook all of the video feedback. Kill
moments or the most horrendously terrible of them all, is sex and money. two birds with one stone Jeffrey thought, free porn to share with all of his
pedophile friends and when the occasion called for it, a security system
all at one expense. Ever consumed with making money as well as saving
Chapter 15 it, I was again astonished at Jeffrey's capabilities. I didn't want to even
think how deep the video infiltrated, pretending like I never saw anything
at all I put the memory to the back of my mind and went on about my
day. Stopping at Ghislane's new townhouse, another gift bought and paid
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for by Jeffrey, he pointed out needed changes all over the place, driving fill his appetite, so on occasion I would meet a pretty girl around my age
the builders mad, as always. He wanted the place to scream out and invite her back to his place to make some quick money by offering
"GHISLANE" with a bold statement. Checkered floors and bold colors her a really good contact in the modeling and acting business. Keeping
was the theme, like the queen of hearts from Alice in Wonderland, very him satisfied and in need ofme was a tiring job. With so much
well suited I thought. competition I had to be on the ball, seeming ambitious to grant him all of
The dust from the walls being torn down chocked my throat and the his desires. It was a lot of pressure and a spotlight of a role to undertake
elevator was not in use, the stairs were hardly either. The whole house at such a young age but I told myself this is what my life's training had
was in bad shape then having to go up three flights of rickety steps was a led me up to be.
bit of a risk too but worth it once you made it to her future walk in My Birthday was around the corner and turning eighteen had lost all of
wardrobe or to us commoners, a closet the size of a small a house. its sparkle and pizzazz. There were no more surprises in store for me,
Complete with a dressing room, luxurious bathroom and plenty of storage nothing that would bedazzle me I hadn't done already. I spent my
for her every ensemble. Even without it being finished it was already a birthday on the island, having a quiet dinner and watching "Sex and the
work of art, a sanctuary for any woman. She adorned herself in her future City" on the couch with Jeffrey, Ghislane and Emmy. There was no cake
home, finally her own, relishing every inch of it, she already put in a or a celebration of any sort but I did get a couple of presents that I opened
work desk and spoke constantly of its ongoing renovations. About an outside underneath the main cabana. Jeffrey gave me a beautiful pair of
hour later we were off to pick out curtains and look at some paint samples sapphire and diamond encrusted earrings and Ghislane bought me another
at a couple different boutique looking shops. Easily passing off as an designer makeup case. I thanked the two of them with a tight squeeze and
ordinary couple for the day, they walked arm in arm strolling the streets a gratuitous short spiel. As it went quiet, I looked out to the ocean and
of the Upper East Side. Except to me, still replaying the early afternoon's wondered if across these waters was there ever going to be happier days
events, shaking my head over the echoed images in my mind, I followed spent with someone special to me. Would he be kind, compassionate, and
behind just waiting to be needed again. always be there when I needed him most? Or would I end up settling for
Over the course of the next few months was a constant influx of my final bit of training, a marriage to a greedy old scrooge? Either way
exorbitant excursions at Jeffrey's mansions, mainly to his island, to keep what I wanted most didn't matter right now, I was still bound by Jeffrey's
up with his ever-demanding sexual appetite with various young women hold over me and all I had to keep telling myself to get through this epic
and teenage girls. I got back on the Xanax, an old habit that I felt at the journey was, this is just the way it was for now.
time would stop my memories from flowing back, rehabilitate my Around the table for breakfast Jeffrey announced that he was expecting
problems and relax me enough to deal with any situation at hand, no a few guests coming over with Brunel, no one ofimportance,just his
matter what the circumstance revealed itself to be. It was a drug that usual entourage of beautiful girls. Russian models this time and Jeffrey
would blind my eyes to everything I should've been running from. was also having a photographer flown in to take modeling photos using
Having Brunel always in the picture these days wasn't helping me at all the island as the perfect background for a sexy shoot. All ofus girls were
either. Sending his girls for Jeffrey at all of his places now and at a ushered onto rocks, hammocks, dug into sand and displayed just about
vigorous flow, they had an abundance of girls at their disposal. IfI were anywhere they wanted. We were being photographed in next to nothing,
to count one girl for everyday of the week, it would be the like a netted fabric placed over us if the shot called for it, but the more
underestimated statement of the century. So many girls between the two provocative the more Jeffrey and Brunel loved it.
of them, some nights it would be a free for all frenzy for Jeffrey and After the photo shoot we did some outdoor watersports. While us girls
Brunel, seven or so girls giving them their upmost attention, doting on raced the jet skis around and jumped on the water trampoline, the men
their every moan and whimper, Jeffrey being the main concern since stayed on dry land to watch us from the beach. I was so used to this
Brunel worked for him and we were all aware of that too. If there were constant charade of girls and I didn't mind having a bit of fun but this
heaven on earth for men like Jeffrey, than he would be their God. Every was different, I had to be more than just polite because I already knew it
one of his inner most desires was fulfilled when his harem of women was wouldn't be long before we were all intimate with each other as well.
around. No wonder he didn't travel much abroad these days, all he ever Being the only girl that spoke English out of all of them was also a huge
wanted was right at his doorstep. I couldn't believe that he was still blunder. The only way we could communicate was through hand gestures
asking me to bring girls to him as well. There was never enough girls to
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and body language, a very primitive form of speaking, but what choice day or retiring for the evening, an outside shower was always splendid.
did we have? Under a thick dark cloak of the night sky only the moon and stars to shed
I did my best to get acquainted and as I had previously assumed after enough light for me to see my way around. I could feel the soft breeze
lunch on the beach we were again ushered into another part of the island, lick the droplets falling off ofmy bodies' curves in the reflection of the
Jeffrey's cabana. There was no need for words here, as the girls already moonlight. It only encouraged me to stay longer under the warmth from
knew exactly what to do. Without saying anything they undressed me and the spray of rushing water. I let the hot water run out before I was
began to ravage my body with their hands, tongues, lips and fingers. I sufficed enough to go back inside. Lounging around the bed in my
was delirious, never having done anything like this before with so many panties and a tank top I was still sweltering from the heat. Trying to tire
girls. It was sheer chaos; I don't honestly know how men could fantasize myself out, I did some reading and eventually fell asleep. I needed those
over this. Through the glimpses in between bodies crossing over me I times to unwind after such an ordeal, letting the Xanax wash away all of
could see Jeffrey and Brunel watching us, sitting in a chair with their the pain I could then forgive the mistakes I had made, blaming myself for
hands around their penises, stroking themselves together "The best part is staying around for this I had wished I was never born at all. The pills
they don't even speak English so there's never a need to have to keep would take all of that away for me. My heart was a tangled weave of
them amused" I could hear one of the men divulge and pretty sure it came deception and pain, only reassured by the lies that were told to me and the
from Jeffrey laughing out loud to Brunel. I just closed my eyes and went lies I would have to convince myself of.
somewhere else in my mind until it was all over. That was that, life went
on and we all moved on to eat dinner together. Chapter 16
It couldn't be more awkward as Jeffrey and Brunel were beside
themselves with their ego's beaming, and the girls chatted like busy little
When we flew back into Palm Beach, Juan drove me back to my
chipmunks with each other. Ghislane and Emmy on the other end of the
apartment. Lonely for some companionship I decided to call an old
table were being amused at the entire racquet around the table and then
friend. I was longing to be important to someone and unfortunately with
there was me. Sitting quietly and smiling in people's direction when
such little time to have a social life ofmy own I was compelled to call T.J
needed, I was counting down the minutes until I could go lay down in my
again. His Mom answered the phone and sounded quite surprised to hear
giant comfortable bed, slipping away to the gentle noises the island
my voice on the other end. She was always kind to me, I even used to
created and sink comfortably into a deep sleep with the assistance ofmy
bring her back "Cola" cans from other countries a bizarre hobby she
Xanax. Scratching at the plate in front of me with my fork out of loved collecting. She just didn't know what I saw in her son, even saying
boredom, I wasn't even hungry. I had lost my appetite for food. Rather
that to his face many times over. Not blind to his ways of cheating and
sipping on the champagne I wanted to feel as far away from here as
stealing, being a personal victim of it, she made it apparent that she did
possible. What seemed like hours for everyone to finish their meals we
not approve ofT.J's choice in lifestyle. It used to really hurt him how his
were finally all saying goodnight and goodbye to each other, as Brunel parents thought so badly of him, so he gave up trying to earn their love a
was off early in the morning and taking the eight beauties with him. long time ago. As long as he didn't steal from them anymore he was
"Thank God" I told myself, once was more than I could handle of that in
allowed to live there. Instead of that being a lesson to him, he would just
one day. try to be more clever in what he would steal, less obvious things. He
It didn't take me long to get back into my own comfort zone. Heading
would steal the toaster and sell it for five dollars ifhe knew it would help
straight back to my cabana after dessert was served nearly tripping over to get him his next high.
my own two feet as I tried to scuttle off in a hurry. As soon as I entered
Nonetheless and at my expense I had a sweet spot for him. With
my domain, I drew a breath and sighed a deep exhale outwards, finally
enough water under the bridge, I was able to forget about the troubles he
alone and at peace ... for now at least. Although the sun had set hours ago
caused. His Mom told me she'd pass on the message when he got home,
the high temperatures of the Caribbean were still an affliction, plaguing
but that could be days from now. The last time he had been home was
my cabana I was welcomed by a rush of warm air as I opened the door. I
over a couple of weeks now. He only stopped by to get something to eat,
hit the switch to the fan and stripped down for a shower. Preparing my
have a long sleep and to beg her for a few bucks, supposedly to help him
towel and toiletries I opened the back door to the outside shower and
buy food. Then he was off again without a single word said, only leaving
placed them on the floor. Whether I was cleaning up in the midst of a hot
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his parents to their own assumptions, which were pretty much correct by his allegations I could only mutter out a whisper "Did you just say that
anyways. Adam is dead, what happened?" "Oh snaps, I thought you knew, where
I then called around a couple of mutual friends to see if anyone had have you been girl, under a rock or something?" Marcus was less than
heard from him. Everyone I spoke to pointed their fingers in the same sensitive about his statements. "He got shot in the head by two black guys
direction and the worst place possible, Ritchie's house. One of his best who got suspicious when their usual supplier didn't show up, your boy
friends told me of how bad he was doing, "He's not the same guy T.J was so fucked up he didn't even remember to tum up at Ritchie's for
anymore, and all he cares about is the next high he gets. Ifwe don't get the delivery, so Ritchie sent Adam alone and now he's dead." Adam was
anything for him he just loses it and goes off somewhere." It was hard to a sweet kid who just happened to be born living on the wrong block. Best
hear how badly affected my best friend was and a part of me secretly friends with T.J since childhood, the two were inseparable until puberty
hoped they weren't right. Still defending him, I told everyone I had spoke hit and even then they would chase girls together. Adam followed in I.J's
too while trying to find him that T.J would be fine, he's just probably every footstep, mimicking his shadow, ifT.J jumped off the Eifel Tower
going through a bad phase, like we all do sometimes and needs people to then so would Adam so when T .J got hooked on drugs consequently
have his back more than ever now. I was pretty much laughed at on the Adam did too, leading ultimately to his death. Wanting to end the
spot, most people that I considered my friends at the time were only conversation with Marcus quickly I scribbled down the phone number on
friends by association. As long as we all looked the part, acted the part, a blank piece of paper in front of me and hung up the phone to call
and could handle the part, only then did they want to be around us. The Ritchie's place immediately.
last person I called was the last person I had hoped he wasn't with and it "Yeah?" It was Ritchie whom bluntly answered the phone after the first
turned out that everyone was right. ring. "Hi-Uh- Rich, It's Jenna, I.J's ex, we met a couple of times at a
He was with one of the biggest Coke dealers in our area, Ritchie-Rich, few parties" I was trying to remind him of who I was knowing how
as everyone used to call him. He didn't look like a typical strung out paranoid he was about people having his number. "Oh yeah, I know who
junkie or dealer. Instead he looked like your average preppy college grad you are, what is it you want?" He answered with a dry tone." I was
with aspiring propositions. He dressed well and acted like a nice guy to hoping you could tell me where I could find T.J, I've heard some stuff
imminent clients only to get them hooked on his drugs and then turns and am really worried about him, is he alright?" Ritchie snickered at my
them out onto the streets. He was a businessman and his business was concerns. "What are you his Mom or something? He's fine, he should be
thriving. He carried everything from most drugs to guns and knives. back here around five o'clock, I'll tell him you called." In the middle of
Having ears in all places made him a dangerous acquaintance. Using kids me saying "Thanks and good-bye" he hung up the phone, as there is no
off the local Palm Beach streets to nm his dirty errands and the errands of room for manners in his line of work. I waited until five o'clock watching
the others above him, he made his money by using these teenagers, who the minutes on the clock tick past and when five o'clock came and passed
as hard as it was to believe was once somebodies sweet child. by with still no phone call, I couldn't deny to myself that I wasn't
I knew T .J didn't have the finances to support himself or his drug habit stricken with distress. Falling asleep wasn't easy either. I ended up
so the likelihood of him being indebted to Ritchie in other ways was a crashing out on my sofa watching T. V, half expecting to hear of another
safe assumption. Obtaining Ritchie's number from one ofT.J's friends murder on the news and it being LT.
Marcus he asked me, "What do you want to call Ritchie for? Come over Forgetting to put on my eye mask before I went to bed, I was woken up
to my place and I can get you whatever you want" Marcus was a sleaze the next morning by rays of the sun beaming into my living room. When I
bag who would tirelessly continue to try to appeal to my lesser sense of sleep I am a creature of darkness, avoiding any window light at all costs.
judgment, never getting the hint or just not caring that I could never and Staggering to the coffee pot not used to getting up this early, my first
would never be interested in him. "No Thanks Marcus, can I just get the thought that day was T .J and why he hadn't called. A million thoughts
number please, it's very important that I get ahold ofT.J, I'm really rushed through my head like a steam train .. .is he ok? ls he not calling
worried about him." I hated having to call this guy let alone have to ask because he is still mad from our last breakup? Has he moved on to
him for something. "Is this about the Adam bullshit? Cause ifit is you someone else? Is he in any trouble? Did Ritchie even pass on my
can let him know what a fucking bitch he is for not showing up to be message? The thoughts were an endless infliction, consuming my entire
there for him, you can tell him from me that it's his fault and it should've day.
been him that's lying in the morgue now, not Adam" I was totally thrown
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CONFIDENTIAi. GIUFFRE0042J2 CONFIDENTIAi. GIUFFRE0042.B
Until finally he called my cell phone later in the afternoon, relief swept through the thin walls and trying to find the unit number was difficult
over me when I heard his voice on the other end. "Thank God you called, from the sporadic flickering of the fluorescent lights above me.
I have been so worried about you, are you alright?" I jumped in without At last I found Ritchie's one, quite astonished with myself that I even
letting him get past saying "Hello". "Yeah, I'm fine. Ritchie told me you made it this far. I had to knock loudly on the door a few times before a
called his house looking for me yesterday and gave me shit for it saying young girl answered the door with eyeliner bleeding down from her eyes,
you were upset or something, what's up?" I knew I would have to be her jet black hair was strung out and a mess and she looked off her face
delicate about asking what happened to Adam, thinking he'd be a mess on some hard drug. She had only her bra and a short skirt on to cover her
over it. "I heard from Marcus that something happened to Adam and I got private areas and a cigarette hung out of her mouth to complete the full
worried about you, what is going on?" T.J sounded scared, for what picture of terrible state she was in. She looked me down with contempt
reasons were beyond my knowledge but I was going to find out, he and snubbed at me "What do you want?" I maintained my politeness and
replied" I don't want to talk about it over the phone. Are you in town so told her T.J was expecting me. She opened the door and walked away,
we can meet up or something?" It was obvious I wanted him to know that leaving me by myself to venture through looking for T.J.
I was more than willing to lend my shoulder for his problems. 'Tm home Passing through the kitchen it looked like a hospital lab with syringes on
now if you want to come over whenever you feel like it." He didn't the counter tops and medicine containers lying around everywhere.
hesitate in taking me up on the offer. " But I won't be able to get there Minding my steps through the dirty house, I walked to the back to the
until later, I'm downtown at Ritchie's place unless you want to come pick living room and found T.J in a K-Hole strung out on a filthy couch.
meup." "Hey ... there" he acknowledged me with a giant smile spread across his
It was more of a request than a favor to myself which is what he was face. He probably didn't even know who I was from the dreadful state he
making it out to sound like, knowing him all to well I didn't make a fuss was in. My first look at him in months and I was in utter shock. My jaw
of his ill-contemplated attributes. I got the address off him and made my must have dropped to the floor at the very sight of him. Never seeing him
way into the ugliness of the not so dazzling parts of the Palm Beaches so skinny and unhealthy looking I took pity and wanted to help him
downtown area. Rolling up my windows and locking the doors to my before things got even worse and he ended up like Adam, dead.
truck I nervously drove through the rough streets trying to find Ritchie's "T.J, hey buddy its Jenna, remember I was coming to pick you up
apartment complex. Knowing all too well the history of the area, it's not a today. You don't look so good, what are you doing so messed up?" I
place a lone white girl in a nice truck wants to be seen, many reports of don't think he could even understand what I was even saying because he
the locals rushing up to a vehicles with a weapon demanding money, could only reply by giggling and rolling over, patting the couch as ifit
cars, or just angry and out to hurt someone. I was speeding through the were a fluffy animal. I stood over him now and raised my voice so he'd
streets wanting to get out of there as quick as I could. A sad world we live know I was serious and snap out ofit a bit. "Get Up T.J, Now!" I ushered
in with so much hurt everywhere you look and nobody wanting to do at him to get off the couch, repeating myself a few times over and with no
anything about it, just accepting the hopelessness of never being able to response I knew I had to get physical. Rolling him back over to face me
achieve anything more than what our civilization has succumbed to. again I smacked his face hard and I'm sure it stung but I got the reaction I
Being among one of those people, we were similar in so many ways. had wanted. He sat up and looked at me confused.
Only separated by our own personal fears and the different direction they At least now he was able to focus on my words requesting him to come
pulled us into. with me. He was getting up from the couch and stumbling around before
I drove straight through the open gates at the entrance to the complex falling down to the floor again. Putting his arm around my neck and
and parked on the gutter in front of Ritchie's block of units. A crowd of carrying the majority of his weight, I helped him up many times over and
people stood outside the blocks I was entering. Being hit on and offered down three flights of stairs into my truck and drove him back to my
drugs simultaneously my cheeks went flush and I put my head down not place. It was a triumph on it's own arriving downstairs in one piece.
saying a word. Walking up the corridors of the staircase looked like a Being the only person who really cared ifT.J lived or died I felt like the
scene out of a horror flick. Graffiti covered the peeling of green paint on responsibility of helping him was my concern alone.
the walls and the pungent stench of something rotting, only to the worst Thankfully Jeffrey was in Palm Beach for the next couple weeks
of my imagination, filled my nostrils. I could hear babies screaming entertaining royalty, which gave me a little time to try and clean T.J up. I
called a few of his friends that I knew and asked them not to score any
101 102
drugs for him any more, pleading with them and telling all of them he that I hated every minute of it, seething through all ofmy duties until he
was on the brink of death, reminding them of the friendship between us climaxed.
all that once existed before the drugs corrupted so many ofus. Some of Most days I could take this kind of treatment, it was only seldom I
them laughed at me telling me I was wasting my time with T.J and others couldn't hold in the way Jeffrey disregarded my feelings. He had me just
were nice enough to at least lie to my face politely and promise not to where he wanted me, like a pawn piece on a checkers board I was his
help him feed his addiction. own personal sex slave. For the remainder of the evening I stayed quiet,
I just wanted to remedy all of his pain and problems but I felt so not sure of what to say after an episode like that. It was a vigorous
helpless fighting his battle against the streets. I bought some marijuana display of how calumniating he could really be. He required me to clean
for him to smoke hoping to subside the withdrawals he was facing over up his spilled semen off of his genitals with a wet warm washcloth before
the next few days but with no avail. The only thing that would help him he retired to his bedroom for a good night's sleep. Only a monstrous
was my Xanax, a few of those pills and he would go back to sleep, only creep could sleep easy at night knowing what pain he caused others.
waking up to get more of them. I would have to force him out of bed to I went downstairs and asked Juan, who was still in the kitchen to pay
have a shower once a day and make sure he ate something. He was more me for the evening telling him that Jeffrey had gone to sleep for the night.
like a baby right now than he was a boyfriend, too much in need of It wasn't an unusual request. Juan would often have to fix up "the girls"
something I couldn't give. after the sessions and sometimes even drive them home. He went to
Jeffrey's desk and underneath was his duffel bag that always held
insurmountable bundles of crisp hundred dollar bills. He took out two for
me and handed them over. I thanked him and said goodnight, as I was
always polite to Juan and his wife, Maria. His eyes were gentle and told
Chapter 17 me more than what he was allowed to say. I understood well. We all
needed to eat and pay bills unfortunately even sometimes at our own
moral expense.
Putting the keys into the ignition I started up the engine and reversed out
When I went to see Jeffrey over the next course of days he picked out
of Jeffrey's driveway with promptness. I didn't want to be there a
the dilemma I wore spread across my face straight away. "Your back with
moment longer than I had to. Not much to look forward too getting back
T.J aren't you" It was so funny that he knew me so well. "Yeah, he's in a
real bad place in his life right now and needs my help." He looked to my apartment either, I needed some time to filter my emotions.
Parking my truck in front of a nearby beach I took my shoes off gradually
astonished and replied, "You're a much better friend than I am, I know
people like him and trust me they never change, no use in even trying" I stepping out of the door into the fog. I walked down to the edge of the
believed him too knowing I was stupid for even attempting to change T.J, sand where the water licked at my toes. My life was slipping away from
but my heart felt differently, he was still a human being and a good friend me and I was really beginning to question the difference between living
and dying. I was so tired of everything, my whole existence revolved
of mine just down at his worst. 'That's what good friends are for" I
around being everything to everyone, forgetting about being something
laughed back at his remark, not wanting to take this conversation too
much further." I admire your loyalty at least, but take my word for it, he for myself altogether. Pretending to be someone else became an attribute
I was better than good at, probably much of why Jeffrey liked me in the
will hurt you again." His words were chilling but true, I had to find out
for myself though. first place. This time I held back my tears back and only let the anger
fester into a deep pit in my stomach. My rage was aimed at the very
Almost seeming like an actual friend for a second he ruined his brief
people who abandoned me to fend for myself in the first place and
momentary image by turning over from the unfinished massage that I was
accepted this life as nonnal for me, my parents.
giving to him and acquired his sexual longings from my worn down soul.
When I got back to my apartment I was expecting to have to look after
Not only did he know that I didn't want to endure any more demands
T.J, but to my surprise he had come around good that night. He greeted
tonight, but his energy enhanced from knowing it too. Looking up at him
me at the door and asked how my evening was. "It was all fine" I easily
during the foreplay, it was an easy observation from the look in my eyes
lied. I never let anyone inside close enough to see my vulnerabilities.
They were mine alone to battle. In my head they were too shameful to
103 104
talk about anyways. He wanted to talk about something else anyways. together but I thought in this world and to these monsters, there didn't
Sitting me down at the dining room table he began his spiel. " I know you need to be a reason. To them it's nothing but a reenactment of their
don't think much ofme anymore, how could you? I'm a junkie who personal fantasies. To me it was a living nightmare.
steals and sells drugs for a living, but I promise that's all going to change Thankfully one of Jeffrey's assistants from New York called me on my
now. Adam is dead because ofme and the only way I can make it up to cell phone early in the morning on the second day to fill me in on my
him is to get away from it all. I promise things are going to get better." It next adventure. I had a flight booked for me to leave that afternoon to
was a convincing talk, but I knew him all too well. His demon inside arrive at La Guardia airport in the evening. Even though I had to go back
yearned for him to fail but who was I to second-guess him out loud, I to yet another controlling man, I was still relieved. At least I was used to
could only try to give him hope. "No one is perfect T.J. At least you're the confinements of Jeffrey's control and in some twisted way he was
trying now and that's all that matters to me. I am so proud of you." I gave more comforting than these strangers he sent me to. Overlooking the city
him a sincere hug and kissed him for the first time in a long time. "I love of New York as the plane landed felt like I was flying from one cage to
you," he said to me and I returned my love back. We slept in the same another. Entrapped by falling victim to the predators that lured me into
bed together that night and were officially back on together. their enclosure. I didn't know how I would ever get out again. That deep
Two days later I was gone again, beckoned to be in Santa Fe. Ghislane pit in my stomach began to churn again, a physical reaction to the anxiety
only told me that I was to meet someone there, not sure of whom that I was plagued with. Before getting off the plane I touched up my make-
was. It wasn't my place to ask questions. As far as I knew it could be up to hide any signs of the frailty I was feeling.
anyone and I had no choice but to be compliant to their needs. It was the Jo-Jo met me at the arrival terminal and picked up my luggage for me.
middle of the day when I arrived at the airport. One of the ranch hands He never said much at all, nodding to any reciprocating conversation. I
came to pick me up in a big work truck that smelled like dirt and sweat don't think he could really speak that good of English anyways. It was
but I didn't mind that's what I loved about the countryside. better for me as I preferred the quietness for the moment. He opened the
When we arrived at the mansion my guest was already there waiting for back door for me and we headed off for my next prison cell. When we got
me. I couldn't wipe the look off my face as he turned around from the to Jeffrey's mansion on 72"d,the place looked empty. I walked up the
bookshelf that he was standing at. "Hello" that same old cheesy grin staircase to Jeffrey's office and he wasn't there. Feeling a bit hungry I
greeted me once again. It was his highness Prince Andrew, and what a walked back down to where the kitchen was. I opened the fridge and
sight. He wrapped his arms around my waist and greeted me like an old found some leftovers that Adam, Jeffrey's chef, had cooked. I loved his
friend. I hugged him back rolling my eyes at the same time, already cooking, when it wasn't filled with beansprouts and tofu. He used to
dreading what lay in store over the next couple of days. My job was to make me the best pizza upon request, or whenever he was cooking
entertain him endlessly, whether that meant having to bestow him my seafood, which he knew I hated. He had an honest appeal about him and
body during an erotic massage or simply take him horseback riding. For never even took notice when on many occasions us girls would be
the next couple of days he was to be my only concern, but he wasn't. I prancing around topless, sometimes even stark naked around the pool or
called in checking on T.J a few times a day, not wanting to be a nag but beach. He would have to serve us our meals and would do it with such a
just hoping he hadn't had any thoughts about relapsing. He was doing casual professionalism, never making anyone uneasy at any occasion.
great, even applying for a couple jobs. Being reassured by him made my Halfway through my meal the kitchen doors swung open and incoming
time away less complicated and thankfully with the help ofmy ever- was Jeffrey and Ghislane. Choking down my bite of food down, I got up
ready Xanax I was able to cope with the ordeal. from my seat and kissed them both on the cheeks. " Hi guys, how are
The mansion was completely empty save a couple of maids who also you?" I greeted them and Ghislane answered for them both "Good, good.
cooked our dinners for us, and a couple bodyguards that we hardly even Sit down and finish your meal, don't let us interrupt you." I hated eating
saw at all. The time dragged by slowly for me as I was counting down the alone in front of people, chewing food and maintaining a conversation at
hours until I flew away again, anywhere but here I thought. It wasn't easy the same time didn't give off the best look. "I was just finishing anyways,
meeting the sexual desires of these strange men, the Prince being one of can I get you guys anything, maybe a tea or something?" Always playing
them. He loved my feet and even licked in between my toes. Then there my part, another reason to keep me around 1 b'lless, I went beyond the call
was the lack of passion in the intimacy we shared, to him I was just of duty and after the last period with them, I had been reminded ofmy
another girl and to me he was just another job. Not the right reasons to be place. "Yes, I'll take a one" Ghislane stated. "Jeffrey how about you,
105 106
anything I can get for you?" I asked again and he answered, "No thanks, reading the backs of interesting looking books. I bumped into a girl
we just ate and I'm still full" and they sat down together on the stools at looking down the same aisle I was down. "Sorry, I'm so clumsy" she was
the kitchen bench. apologizing for my mistake. "No, no, it was my fault, I wasn't looking at
I got out the shiny red kettle from the cupboard, knowing my way all where I was going. I get so wrapped up with my nose in a book and trip
too well around the kitchen and put it over the hot stove plate. Turning over my own two feet if I'm not careful enough." We were both giggling
around to face them, I thought they were acting peculiar. "So ... "Ghislane now and I further introduced myself to her. Her name was Valerie or
started the conversation, "How was the ranch with the Prince?" It was a Vickie or something like that, anyways she was a student at a school for
natural reaction for me to blush, knowing exactly what she was referring hairdressing nearby. Chatting away both young and similar interests in
too. Keeping busy preparing her cup of tea and avoiding eye contact with each other's choice of reading we found it easy to speak with one another.
both of them I started to unpack the counter where I had been eating, "I She wasn't from around here only being in the city for the last two
think he had a really good time, he seemed relaxed during the trip and months, her parents hated her being here, but were also supportive in her
when we said good-bye to each other he gave me a kiss." I went on to tell big decision to move from the countryside in hopes of her accomplishing
them what we did together "I took him horseback riding, nowhere to far her own dreams. Aside from not having her near them, they just wanted
just around the property, um ... we went swimming in the pool, and of her to be happy and supported in her big decision to move to the city,
course I gave him plenty of massages. He had a massage at least couple helping her pay some of the way.
times each day really seeming to enjoy his time there." It's what they She was a pretty girl with cherry red hair and soft white skin. Her long
wanted to hear, not the truth of how disb'llsting I had felt over the whole legs were emphasized by the short flowery dress that complimented her
thing but they already knew the truth anyways, it's what they had trained hourglass figure. She would definitely fit the pro quo for going down in
me for in the first place. one of Jeffrey's little black books. Only imagining the look on his face
Like two proud parents they both looked over me with such content. upon meeting her I could already see his sly grin spread from ear to ear.
"Good, you did really well" Jeffrey complimented me. Turning around to Knowing exactly what he would do with her and the very thought of him
the boiling kettle, I finished Ghislane's tea for her and the conversation tarnishing a sweet country girl such as her just couldn't be done. It was
led on to other subjects. We all ventured up to Jeffrey's office and out the beginning of a turning point in my life that started with realizing I had
came the infamous duffle bag that went wherever he did. I was given a choice at hand and the effect I could have on one person alone. "I must
close to a thousand dollars for my time in Santa Fe, more than what I be off, but it was really nice to meet you." Bidding her goodnight and
thought anybody at my young age could make for a couple days of work. paying for my books I turned around with one last glance over my
It was fulfilling the obscene vulgar needs of the so-called privileged that shoulder and said. "Good luck in the city!" Leaving that bookshop was a
earned me so much. small step in a growing abundance of larger strides to come. Turning the
comer onto 72nd street l had an undeniable feeling in the pit ofmy
stomach again but this time it wasn't the familiar hurl of anxiety I was
Chapter 18 used too after I had done something I had wrong that I had regretted, it
was a new feeling of pride and inner strength. I quite liked it a lot, I held
I spent the next few days in New York, venturing out to do some my head high and smiled on the inside when Jeffrey asked me how my
day was and what I got up to, not mentioning I had let one girl slip on
shopping therapy. I loved the eccentric parts of the city. Every street was
different but the same energetic vibe filled all of them, animated with all bye.
The icy winter winds faded away making way for the approaching
different walks oflife. Hanging out at coffee shops reading the newspaper
sunny days that blossomed the colorful shades of spring. This was my
or a good book was a favorite pastime while in the big apple. Being close
favorite time of the year. Making the most use of his island we spent
enough to get back to Jeffrey for when he needed me but also far enough
countless days of the increasingly hot days there. A constant array of
to get away from all of it. Most of the day slipped by without being
missed and I made my way back to Jeffrey's. visiting guests and plentiful young women to flock around keeping them
entertained was the typical lazy afternoon on Little St. Jeff's. We ate,
Making one last pit stop, l walked into an old bookshop to browse at
drank, and played under the blue blanket of cloudless skies. To many this
their assortment of old titles. l wasn't in any hurry so l took my time
lifestyle could seem idyllic, unless you were like me, the one on the other
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side of the fence where the grass wasn't so green. Fortunately for me and enough to find some old coins here and there. It wasn't easy though, both
in some ways not, I was mostly expected to attend to only Jeffrey's loving a challenge it was perfect for us. Enduring many scratches from
insurmountable of sexual desires. Whereas the other girls who came one the bushes we would be searching through and then the soar arms from
day and went the next were promised a multitude of open doors just for digging all day, but it was worth it in the end. After nearly two years of
there meager participation in sexual acts with random men, only to be collecting items and saving them, we made Jeffrey a mosaic table out of
disappointed when they realized they were nothing more than a single the remaining pieces left from the era of the pirate's day. Upon
night out for these geriatric senior citizens who most likely due completing it we were both astounded in our creation, it was such an item
Alzheimer's would sooner forget the entire experience let alone their first of rarity and an interesting piece of work. When we presented it to Jeffrey
name. he was even impressed not only in our amazing finds but what we did
Surrounded by those in our world who many looked up too but not with them. The table became an important work of art that Jeffrey
seeing them from where I was standing, I didn't have the highest of showed off inside the main house's lounge room, sparking a much
standards in humanity. Then I met Al Gore and his lovely wife during intrigue and table conversation by many of the visiting guests to his
one of those many weekends away in the Caribbean. I was blown away island.
by the amount of attention Al doted on his wife, it was so sweet to watch. The next morning was good-bye for most of the visitors, leaving just
They sat next to each other at the dinner table gazing into one another's the usual behind. Soaking in the sun and living it up in the lap of luxury is
eyes having an intimate conversation between them. Among the many how the next few weeks were spent before having to get back to the
guests visiting that night and many of them young beautiful women, not dredge of the city. Sometimes we'd have to go to St. Johns island for
once did Al's eye's stray elsewhere, to them they were the only ones Jeffrey to do some work in the office. It was so boring for me to sit in
there. He was up for a presidential election that year and he definitely had their listening to him on the phone or coming down on some poor
my vote. Anyone that could show that much devotion and passion employee for something stupid like not answering the phone correctly. If
towards his loved ones could have the same devotion towards running a I knew he was going to be awhile I would excuse myself for a bit of
country, or at least I thought so. He only left his wife's side to have a shopping. Not that the Caribbean had much to offer in the world of
walk down to the beach with the host of the weekend, Jeffrey. The fashion but there was never an amount of bikinis one girl could own and I
weather was still warm in the evening when I decided to break away from loved all the little knick knacks one could find there. Flying back on a
the idle chat around the table and take a stroll too. private jet was the best part because l could transport just about anything
Not wanting to interrupt the conversation between Jeffrey and Al, I I wanted back to my apartment, which was already filled with an
walked in the opposite direction plucking the washed up sea shells assortment from my shopping ventures and collection of seashells from
imbedded in the sand along the way. l enjoyed the serenity in the solitude the Caribbean.
of the island. So many nooks and crannies to get lost in, I could imagine The next big dinner party on the island had another significant guest
that I actually disappeared from the entire world for a moment. By the appearance being, the one and only, Bill Clinton. He is the only president
time I came back to the main house majority of the small crowd had been in the world to be dismissed from his role as a world leader because he
long gone retired to their cabanas. Even Jeffrey had gone off to bed but was caught with his trousers around his ankles and had the stain to prove
trust party animal Ghislane to still be up entertaining the remaining guests it. Publicly humiliating his wife and himself he retired from his title but
left at the table, regaling her wild stories of people and places she has not from his lifestyle. This wasn't a big party as such, only a few ofus
embarked on. Trying not to make eye contact as I walked past them on eating at the diner table. There was Jeffrey at the head of it all, as always.
my way back to my cabana carrying my seashells inside my curled up On the left side was Emmy, Ghislane and I. Sitting across the table from
blouse, I wasn't up for anymore pointless talking tonight. Emptying out us was Bill with two lovely girls who were visiting from New York.
my seashells into a plastic bag, I went over my new treasures one by one. Bill's wife, Hillary's absence from the night made it easy for his apparent
I loved collecting odd things, shells being one of my favorites. provocative cheeky side to come out. Teasing the girls on either side of
Ghislane and I shared that interest together. We would enjoy walk him with playful pokes and brassy comments, there was no modesty
abouts around the island searching for lost pieces of the remnants that between any of them. We all finished our meals and scattered in our own
pirate's had left behind centuries ago. It was mostly broken plates or different directions.
smashed glass from bottles of ale, and even occasionally getting lucky
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Jeffrey wanted his evening massage before bed and Ghislane and Jeffrey's business was running well from the looks of his attentiveness
Emmy went to their office to talk about something, leaving our guest of the office he owned in the Upper East Side of Manhattan. Alan
honor to find company elsewhere. Strolling into the darkness with two Dershowitz, his colleague in finances and personal solicitor, a bird of the
beautiful girls around either ann, Bill seemed content to retire for the same feather, l had seen hanging around the island and Jeffrey's
evening. He wanted to have a hot bath before bed while I began the Manhattan mansion, more and more these days. Alan's taste for the
massage in the tub. Starting with his feet and calves, he wanted to end the young and beautiful was a bias for a blooming business relationship
night quickly. Never showing any restraint he sat up on the edge of the between him and Jeffrey. After an explicit session of Jeffrey's vulgar
tub and asked me to prefonn on him orally. I did my job, but that's all our pilgrimage into my body, we were interrupted by a knock at the door by
relationship was these days, a dreadful job. Getting it over and done with Jeffrey's good friend, Alan. l wrapped myself up in Jeffrey's pink bed
as quick as possible was my hope but I couldn't let him pick up on those sheets, which is the color preference he chose to sleep in because it
vibes, to make him enticed I had to act like his little porn star, knowing reminded him of the same color of his own words "Pussy", and covered
exactly how he wanted it. Only then would my duties be fulfilled and I my face from the unexpected intrusion. Jeffrey got up and wrapped a
would be able to get back the reality ofmy complicated life. Before I towel around his loins and answered the door completely calm. Opening
could say goodnight, Jeffrey had one more request. He wanted me to tuck the bedroom door and letting Alan inside they began to converse about
him under the blankets and fluff his pillows for him. Then I had to reach business immediately, right in front ofme. Jeffrey started to tell Alan
under the covers and massage his feet while watching him fall asleep, he what needed to be done while he jostled some notes down quickly. I
even wanted me to wait like twenty minutes or so after he fell asleep peeked my head from underneath the covers thinking they were too
before I could leave. It wasn't unusual for him to ask it but God I hated it, wrapped up in their work to notice me get up and dressed, and Jeffrey
never offering it I would always wait for him to request it. Once he was turned back to me and told me to just stay there this would only take a
snoring gently I wiped my hands clean of the lotion and quietly closed the second. Going back to Alan he turned his focus back into work and
doors to his room. Making my way up the outdoor spiraling staircase, I hustled out a few more orders before letting Alan out of the door and
felt the breeze blow through my hair and looked up to the heavens. The returning his attention to me.
stars shown so bright out here in the middle of nowhere with no big city "Sorry about that, work never stops and neither will the money coming
lights to hinder their effect I could get lost in time staring into them. No in. How else am I going to make a million dollars while I'm sleeping?"
matter how far gone I really felt there was always something about a Jeffrey chuckled as he sat back down on the bed next to me. I laughed at
simple caress from the wind or the reflection of the star sweeping sky in his humorous and mostly true statement, then a strand of hair fell in front
the black glossy ocean that would always remind me ofmy fond love of ofmy face. Before l could get to it he put it back behind my ears and
nature's blessings. sweetly stroked my face, for a moment we just looked into each other's
Back in New York, there was nothing left of nature to adorn. It was a eyes and he nearly seemed almost human to me. It was bizarre how he
dwelling for those who no longer saw the use for trees without cages or could be so kind and gentle one moment and the second beforehand I was
blue skies without clouds of man made fumes and gases. Unfortunately if being treated like no more than a common plaything left out for display.
we weren't in the Caribbean, we were there in New York. Hardly going Nothing more than an ego trip, Jeffrey got off on letting the ones he
back to Palm Beach, barely even seeing my family, my dog or T.J these wanted to know that he could own anything and anyone he wanted in this
days at all. In my parents heads I was all grown up and educated in the world. Maybe for a brief minute I believed the sincerity behind his eyes
world of wealth not needing them any longer they would just wait for my but that vision would quickly fade away and I would be left second-
call once in a while to let them know how I was doing and that was the guessing why I even fell for his deceitful tricks for a moment.
extent to our restricted relationship. The road my life has led down never Jeffrey got up from the bed and asked me to join him for a shower. In
has kept me close to home anyways so to me it wasn't anything his bedroom, which was the entire top floor, he had a glass shower
unordinary but still a sad existence to be without a family ofmy own. It enclosed underneath a glass skylight right in the middle of the room. It
would've been nice to be missed though, rarely letting myself think like was perfectly accessible feature for a man that loved both being clean and
that. No room for pity in my heart, if l did, the floodgates could open and nude, but still an odd feature at that. As I always did whenever I
I'd have enough grief in one lifetime to go around a few times that they showered with him, I lathered a loofa with soapsuds and would scrub his
would've never been closed. body, up and down, in between his toes, even behind his ears and of
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course his genitals area. The sunlight shown through the glass ceilings It all came to a sudden conclusion one sunny afternoon in the Caribbean.
into where we were standing, making the moment feel even more surreal Jeffrey pulled himself up to the ladders first step and climbed up the next
on top of the already popped Xanax I had popped before for breakfast four steps to the top of the dock. His chest was heaving rapidly as he sat
earlier that morning. Jeffrey was in such a lighthearted mood that day, down catching his breath. Ghislane was the next one up and then I
making funny cracks at me, and acting like a flirt. When I was finished followed lastly behind them. To me it was an invigorating snorkel around
washing him he actually wanted to wash me too, which was another the shallow reefs within the radius of the dock, but to Jeffrey the half an
totally out of his character suggestion. hour swim in the ocean was enough to overexert his ageing limbs. I took
For the rest of the day, he took me everywhere with him, the office and off my snorkel gear and placed it in the storage bench, grabbing us a few
then to a friends place, even just wanting to hang out with me for a while. towels at the same time. Wrapping a towel around Jeffrey's backside and
I wasn't used to being treated like anything more than a dog on a leash, handing one to Ghislane, I sat down next to them on the dock and we
when he acted like this it just completely spun me around confusing me laughed how fatigued Jeffrey was, poking fun that he really is getting
even more. older. A very touchy subject for the vain at heart but he didn't seem to
We were spending heaps of time together these days, a lot more than mind it, probably knowing we'd never take the joke too far. We sat there
usual. At the ranch we would do things together, alone, and not just the in silence for a moment, an odd silence at that. Jeffrey looked at Ghislane
usual perverted things I was accustomed to doing with him alone. and then Ghislane looked at me, placing me once again in the spotlight.
Horseback riding on his ranch during weekends away by ourselves and They both scooted closer to where I was sitting and I felt something
movie nights snuggling up over a bucket of popcorn instead of having to stirring in the air. The biggest turning point of events in all of my time
massage his feet during the entire film became his way to alter my spent with them.
perception ofmy original notion that I wasn't just his sex slave, I thought Jeffrey sat next to me and put his hand on my back and looked at me
I was finally becoming his friend. with a certain kind of sincerity I hadn't seen in him before. "I want to
When we went quad biking he no longer wanted me to take my own first of all tell you that over the last few years you have shown me the
bike, he preferred me to sit on the back of his, holding onto him tightly kind of devotion and loyalty that I believe is rare to find among people
and he even tried to teach me how to drive a manual stick shift car. He these days, qualities I hold that high in regard." Bewildered by the whole
was definitely trying to show a softer side of himself, different to the scenario I just nodded every time he paused, trying to grasp what his
stone cold slave driver I had to come to respect out of fear over the many intentions were getting at. He continued to praise my nature saying " I
years. Still a hard image to change after all I had been through and seen hope you know my appreciation for your embracing ofmy lifestyle, you
over the years I had been with him. Nonetheless he was still my "boss" so have been achieving a name for yourself among the friends I have
I humored his attempts and matched his caring demeanor, giving him the introduced you to. Everybody says basically the same thing about you,
impression I was intrigued in our new kind of affair. the same thing I believe. You are a delightfully funny girl who has
developed into a mature graceful young woman and I could think of
nobody else I'd rather have a child than with than you."
Chapter 19 And just like that he created a whole new dilemma for me to face. In
utter shock from the completely unexpected proposition and before I
could even think of anything to respond with, Ghislane made the
His attentiveness led into the wanner months that commenced the finishing touches with the business end of the deal starting with the pros
before the cons "You would have around the clock nannies to help you.
beginning of long summer days that I looked forward too. I couldn't help
but enjoy his eagerness to see me more relaxed these days. He wasn't Jeffrey would pay for a mansion of your choice in either Palm Beach or
New York" and as if the drum rolls were beckoning " and ... you would
even bothering me to find alternate sources of girls for his twisted
have a hefty monthly allowance from Jeffrey's bank account" Astonished
satisfaction anymore and although I was still being used for his distorted
at their first offers I nearly took the bait. Then she continued to finish the
sexual enjoyments he further seduced me into believing I meant a lot
terms of our pre-agreement with "But you would have to travel with the
more to him than I ever did.
child where and when Jeffrey wanted you to be, and most importantly
you would have to sign a contract stating that Jeffrey and you are not
113 114
monogamous and that the child would belong in Jeffrey's custody in the glasses off while granting me a big smile. "Come over here and sit down
event of a falling out between the two of you." She kind of threw that last with me" as he ushered me to come sit on his lap. Pulling me onto him he
one in there quickly, as if she could get away with me not hearing that I had a funny look on his face, like he had something really big to tell me
would basically have to relinquish the rights to my own flesh in blood and was letting the anticipation build in the thickness of the silence.
and surrender them to a life of servitude and abuse with these people. My "What???" I laughed at the way he was looking at me now. "First of
maternal alarm bells went off straight away and I already knew my all. .. Happy birthday today." Was only the beginning of his
answer. No way I could I do that to any poor baby, God only knew what announcement and he proceeded to tell me "I know how much you have
these monsters had in store for me let alone a baby, but it was an instant wanted this for so long and you are more than deserving ofit. You are
reaction that saved me." I don't know guy's, I mean I'm really young going away to Thailand to learn authentic Thai Massage and within eight
and never really even thought about having kids yet. Wow, I just don't weeks you '11receive a certificate for being a qualified Thai Massage
know." I slicked my hand through my hair nervously and took in a silent Therapist." Astonished at his attempts to see me get what I wanted, not
breath. I had to go beyond what I was truly feeling and give them the exactly the type of massage I was interested in but it was a start and a
feeling that I'd never let them down. Putting an eager smile on my face first certificate for me to acquire. My eyes lit up and I threw my arms
and sucking up my gut's intuition I told them "You know what, let me get around his neck, planting a big kiss on his lips, which I rarely ever did.
my certificates in massage and have some time to prepare for this and get "Wow, I don't know what to say, this is beyond my wildest
healthy then next year we'll all think about having a baby together." It dreams ... thank you so much'" I did well to let him know I appreciated
was crazy to even hear me say out loud but from the expressions on their his grandeur offer. He went on to give me the details of where I'd be
faces I had fulfilled their wishes. staying, the school's schedules, and how much he loved Thai massage,
Much reason to celebrate that night they were both in a cheery mood apparently it was the next big thing to hit the shores of America. He had
around the dinner table. Except for me who had taken double the dosage planned out an entire itinerary for me. I was to depart at the end of
ofXanax to even cope with the high amounts of anxiety I had been August and he had already enrolled me in a class at "ITM Massage
suffering from since we got back from the dock. I wasn't sipping the School". I would only have a few days to settle in before I would be
champagne that night, I was gulping it and when their moods turned from attending classes five days a week over eight hours a day. He even had an
cheery to raunchy later that evening it wasn't hard for me to comply. assignment for me to do while I was over there. I was to meet up with a
From the full effects of the state I was in I would've agreed to just about girl who was also being put up at the "Princess Hotel" where I was
anything, allowing them to treat themselves to ravishing the tender parts staying. She had an Asian sounding name so I just assumed she was a
ofmybody. local girl hoping for an opportunity of a lifetime, if she only knew what
Over the next few weeks everything went on as it normally would, and she would be getting herself into. If I decided that she met Jeffrey's
not another mention of their proposal. My birthday was only a week away particular quota of approval then she would be sent over to the U .S to
and I was turning nineteen that year. All I wanted was to get my meet with him or one of his esteemed colleagues. Besides the guilt of
certificates before I got any older and get trapped into this life for good. having to decide a stranger's uncertain fate, everything else sounded
When my big day rolled around I was in New York with Jeffrey and more than wonderful. Eight weeks gone from Jeffrey sounded like a
Ghislane. Sitting on my bed listening to MTV's channel blare in the lifetime away and I couldn't be more excited at this chance. It was the
background ofmy room Twas painting my toenails when I was suddenly opportunity ofmy lifetime and I wasn't going to waste a second ofit.
buzzed on the intercom. It was Jeffrey calling himself to ask me to meet Ghislane came in a few minutes later and the look on her face told me
him in his office in ten minutes. Perfect timing to let my nails dry I she already knew. Tgot up from Jeffrey's lap and gave her a big hug and
thought to myself. Already contemplating his desire to come downstairs I told her, 'This is so nice of you guys, Thank you so much!" She didn't
knew it had something to do with my birthday present but I was more share my enthusiasm of excitement. In a dull tone she responded, "I
expecting the usual shopping money or piece of jewelry, definitely not didn't have a thing to do with it, it was all Jeffrey's idea but good-luck
what he had in store for me. anyways." She gave me her best impression of being human for a brief
I knocked on the slightly ajar door to Jeffrey's office and heard him second and hugged me back. It was just her way and I had come to accept
beckon me inside. "Hello, what cha up too?" I asked in a cutesy tone of it. Depending on the level of slander her insults provoked was just her
voice. Walking over to his desk he looked up at me taking his reading way of telling you she cares without really ever showing it. Probably
115 116
doesn't make sense to most sane people but after all of the time spent time so I just put my dog on the lead and took her for a walk to calm
with them, I had gotten to understand a few of their quirky ways. Even if down the situation and give me some time to be alone. Mary Jane was the
I didn't agree with them, they knew I would for their sake of opinion. only one I hated leaving behind. When we got back from the long walk
What did it matter anyways I thought, I had been degraded in every other she barricaded my suitcase while I was packing the horrendous amount of
physical way what's the difference from taking their mental abuse too. clothing that I always did. I was promising her I wouldn't be long and
Not the exact choice of employers I would've chosen over again if given told her how much I loved her giving her a big hug. I choked back on the
the opportunity but here I was and doing my very best to excel at their tears that were swelling up in my eyes, it was like she already knew the
demands. night before I flew out to New York that this would be my final trip.
I was sent home for a little over a week to pack for the long trip and There was a commercial flight booked for me in the morning and I
make the rounds visiting my family before I left overseas on my first trip needed the rest that night to fully recover from my binge of celebration
all by myself. It was great to see my family after such a long time away. drinking. T.J crept into bed later that night and tried to redeem his
My older brother and his wife even came down to visit for the well behavior with sweet nothings and dry humping my backside. It did
wishing ofmy departure. Everyone in my family seemed stoked at the nothing for me sexually. I didn't feel like that for him any longer and the
prospects my long journey had led me down. Here I was jet setting sooner he realized that, the better he'd be off. I told him I wasn't up for it
around the world in my teens and getting paid to study the course ofmy and he picked up a pillow and slammed the door behind him. It didn't
dreams at a cost that I only knew I would have to pay. It was a wonderful matter I told myself, the next day I was off and wouldn't have to deal
get together with all of them around, a great way to remember them. If I'd with him or anyone.
only known it would be the last time I would see any of them I would've T.J caught a cab with me to MIA, the airport in Miami. He walked with
emphasized to my brothers how much I really loved them both and how me to the furthest point he was allowed to go by the security gates and as
much I would miss them in the decade to come! But I didn't know what we stood in line together it was almost heartbreaking seeing him cry. I
my future held for me, I had nothing planned out I was just hoping for the told him I'd try to call him everyday, attempting to give him optimistic
right opportunities. ways to look at this time away from each other. In the end he had me
I also had a few good friends to catch up with before I went. Every crying and I had to give into my remaining feelings I had for him. One
night was another party and by the end of the week I had drunken enough last kiss under the x-ray bridge and he vanished out ofmy sight as I
to drown an Irishman on St. Patty's Day. I was given the lists to all ofmy furthered down the terminals long hall.
friends email address and told to keep in touch. Yeah right I thought, I
was going to be too busy having too much fun to be thinking about sitting
on a computer emailing people, but I told them I would anyways. Save Chapter 20
myself the point of having to explain that in many different ways to a
group of already tipsy slurring teenagers. Out of everyone who was really
happy for me, T.J wasn't. He hated the idea ofme leaving him to have a
It was only a short flight to New York and I just couldn't wait until next
non-stop party in Thailand without him. He was just starting to seem like
week when I'd be jetting ofto an exotic destination all by my lonesome
he was coming good and I didn't like having to leave him at such a
self. It was all I could think about talk about and dream about, finally my
vulnerable state but in my young years I had already realized I needed to
break. Ghislane did what she did best that week and prepped me for
do some things for myself and this was one of them. There was still a everything I could imagine under the sun. Do's and Don'ts, emergency
huge amount of broken trust between us, trust that could probably never
numbers and western union locations were among some things on the list
be rendered again so I thought I was being decent enough letting him stay
she gave me. Like l said, she showed her caring side in other ways.
at my apartment while I was gone, but he was not to drive my truck, at
There was also the name of the girl I was supposed to be meeting, the
all. I paid too much money on insurance for that thing and knowing his
room she was in and what dates she would be staying there.
driving record I didn't want the risk of something happening while I was When I got out ofGhislane's office I was instructed to meet Jeffrey in
gone for so long. He didn't agree with me at all, throwing a grown up
his office. She had to stay back for some paper work that she had to catch
tantrum all over my apartment. Hitting the walls and doors, shouting the
up on pronto. Making my way up the red and gold trimmed carpeted
entire complex down, there was nothing I could say or do at this point in
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CONFIDENTIAi. GIUFFRE004250 CONFIDENTIAi. GIUFFRE00425 I
staircase I prepared myself for some major sucking up before I left, he Throw out your confetti because here I come Chang-Mai!! My
would be expecting it for his recent generosity, or so I had thought. celebrations started the second I landed, it didn't take me long to make
Opening those familiar heavy doors the first thing I saw was an myself aquatinted with a few fellow travelers and find the hot spots of the
unfamiliar face standing over Jeffrey's shoulder. hustling city. It was like nowhere I had ever been before. The streets were
She was a tall girl with blonde hair twisted up in a professional looking lined with stalls offering an assortment of souvenirs, clothing, and knick-
knot. Her big smile was flashing at him with hints of her cheekiness to knacks. Everyone lived so freely and was in such great spirits. The parties
come and she was dressed to kill with a short tight grey skirt and a raged on until the wee hours of the morning and people became best
matching suit jacket over her white buttoned down blouse, revealing her friends over night. From the second I got there I knew Thailand was
voluptuous ample cleavage. She looked like the old college professor's going to be a lot of fun and I was right! Popping bottles of champagne,
wet dream. When she introduced herself to me, a thick Czech accent dancing all night to the beat of every club's rhythm's along my way and
presented itself. Her name was Nadia Marcinkova and Jeffrey looked just carrying on like it was my birthday ... every night was a repetition I could
about as smitten as a victim of a love struck arrow from no one but the definitely get used too. During the day I was a real good girl, the teachers
cupids themselves. Jeffrey further introduced her as his new assistant and pet even. Showing the credibility ofmy experience in massage from over
masseuse while I would be away, barely taking his eyes off her for one the last few years and already ahead of the class the teacher was using me
second. It was a bit of a blow to take, being so easily replaced but also a to help instruct the others with demonstrations. Mostly in a class full of
part of me already knew this was expected off someone like him. Good males it wasn't a surprise that I made friends with quite a few of them,
for him I thought to myself, why should l have bitterness over someone l some of them with ulterior motives, but for the most part the sleazebags
never had intimate feelings for and knew had never really cared for me in were none of my concern, I had already dealt with a lifetime of them to
the first place. Kissing her on the cheeks and telling her my name, l was be able to spot one out and steer clear of his approaches. Out of the entire
doing my best to grin and bear it. We hugged for a brief show of class I had made friends with only one girl from Wisconsin. She was a
uniformity but it was just that, a show for Jeffrey to see. When he was plain looking girl with big brown puppy dog eyes and a long drawn out
away for the moment or she wasn't busy hanging off his every word, the accent. Her first time leaving the States or Wisconsin itself for that matter
way we all started out, she would snub me off to only head off in another so it was easy to acknowledge that she was a little taken aback by all of
direction. A real bitch if anyone was to ask me but no one would anyways the bustling city life so becoming her friend felt like I was doing a good
it wasn't my job to like her. deed showing her around the hot spots of the Chaing-Mai nightlife.
Over the next course of days it was my task to show her some of my Eventually I even ended up inviting her to stay with me at my hotel. She
techniques in massaging Jeffrey and the erotic side of finishing it off. was running out of money to party every night then pay for school on top
Nadia despised me even more when Jeffrey told her to follow my lead of her accommodation, it was all becoming too much out of her small
during the massage as she tried to take over and do her own thing a few budget. So I thought about it and offered her a bed in my room, I had two
times. To me it was quite funny her competitive side, I had nothing more of them anyways. Plus she was a really nice girl and if I could help make
to prove so watching her put on an act of seduction and scream out her her first time out of the country an unforgettable experience then I was
every body function during a faked orgasm was nothing but entertaining also gaining something from it as well.
in my eyes. After a few sessions together it was my time to be off on The first month in quickly passed me by. Having such an incredible
another adventure far, far away from here or from the chains that I wore time on my own and putting my heart into learning Thai Massage it
for way too long. Jeffrey had someone else to fit the chains that kept me seemed to just fly past. Routinely I had to call in and check in with
so close to him. Even though she wasn't the nicest of girls I still couldn't Jeffrey and Ghislane letting them know my whereabouts and progression
help but feel sorry for her. No girl should belong to someone out of in class. Counting down the time left until my course finished Jeffrey was
servitude, but unfortunately it is the way our civilization has been for anticipating my departure back to New York. "I can't wait to get my first
many centuries before us and I don't see changing any time soon or as Thai massage from you. l 've got you booked to come straight back to
long as perverts like Jeffrey are allowed to walk around freely and New York for my first one as soon as your course finishes next month."
procure our daughters off the streets all because he's got a lot of money to His eagerness put a twisted familiar knot in my stomach. Reminding me
pay many, many, many people off. of the dream I have to awake from soon and the reality of the certain
homecoming I would be arriving to. " It's such a great course, thank you
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so much for sending me here to learn this. You are going to love my new and shove to try to find a spot to watch from. The friends that we were
area of expertise! I am having such an amazing time over here!!" I had to hanging out with were meeting up with another group of guys that were
let him know how much I appreciated what he had done for me and he training for the kickboxing tournaments that we were watching.
loved the head swell that it would make him feel as well. Hating the Then it happened it was the first moment I laid eyes on the man that
thought of going back to him, I wasn't going to let that put a damper on would love me for the rest ofmy life. I wasn't expecting the most
my spirits while I was still out there. It was my time to party harder than amazing time ofmy life to happen right there and then but it did and I
ever before. Every night was a new adventure for me. Chang-Mai was a would never be the same again. Destiny fell right smack into my lap and
maze of places to get lost in and the vibrant city was my playground. The there was no stopping it! It wasn't just his smoldering appeal that was
way I saw it this was my last chance to get out and break free, letting obvious at first sight it was the entire package of mannerism and chivalry
loose my inner girl it felt so good to take the lead of my own life. that made him stand out of the crowd. Stepping right out of the pages of
the fairytales I used to read, he was nothing like I had ever come to know
before.
Chapter 21 Watching him from a close distance he was playfully shadow boxing
one of the guys from my massage class and it was at that moment that
this handsome stranger first caught me staring at him. From top to toe this
athletically built man was intriguing to watch, I couldn't take my eyes off
It was an average evening getting ready in front of the bathroom mirror him like I was magnetically drawn to his power of attraction. He further
on just an average Sunday, though unbeknownst to us girls as we sat interested me when he wasn't acting like the majority of harping dogs
there chatting away carelessly, this night was already written in the stars that would jump at the eyes I was giving him now. Instead he coyly
for me. It was a very long time ago now when I was still a young child played hard to get, making me work for any conversation with him. The
that I sat looking up to those same stars from my bedroom window with fight started and the men were going bezerk, screaming at the fighters in
my hands pressed tightly together as I cried for God to hear my prayers. the ring offering either fighter their support or discrimination depending
All I asked him for was death. My precious life was already such a on whom they were batting for. It was like watching a primitive scene out
hopeless battle that I felt too small to fight alone for. Begging him to of the days when the cavemen ruled the earth but it was as equally
deliver me from this cruel world I would pray for all ofmy pain would to alluring to watch unfold, the sweat, the blood and the absolute brut
away for good. My only clause in my prayers was the possibility that fascination ofit all.
there was somebody in this wide world that I was meant to love, After the fight and all of the men revved up from the fight, I suggested
something much bigger than I could have even imagined yet. This that we all head to the pizza joint in front of the Princess Hotel where I
invocation of mine was forgotten about long ago now, until tonight. was staying for a late night snack. I made it my goal to make myself
I wish I had known that night I sat crying beneath the stars that it known to this appealing stranger. In the tuk-tnk on the way there I made
would all be different one day and that I hadn't sold myself short to the sure I sat next to Robbie. Scooting my knees closer and closer to him on
accustomed lifestyle I was brought up to believing was acceptable. It was the short ride he continued his chase by moving further away from me, a
this night my very soul was about to cosmically collide with the man I game of cat and mouse that I loved. When he answered back the array of
was always meant for, the man my heart already belonged to and would my questions he had the cutest Aussie accent that drove me absolutely
know from the instant we met. This night would be the first day to the wild.
beginning ofmy new life to come. Gradually we got to know each other better over a pie of peperoni
I blushed my cheeks and put on my mascara before me and my pizza and two can's of coke. Too me he might as well have been the only
girlfriend headed out to hit the town. We were dressed to kill and looking other person in the restaurant, he knew he had my undivided attention and
for something to do when we ran into a few of our class mates at one of I think he liked it. There was no one like him that I had ever met before
our favorite drinking spots. They were meeting up for some drinks before and I knew there was no other who could make me feel the way that I felt
a Muay-Thai kickboxing tournament. It sounded like fun when they at the first sight of him. Being charming and suave was all an accidental
invited us along to watch it with them. The massive crowd lined the street front. It was easy to read him. Immediately it wasn't hard to see his sweet
where the fight was being held and once I got inside the arena it was push side, holding the door and pulling out my chair at the restaurant, I was
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already smitten. After pizza he walked me across the street to my hotel gave me his warmth and compassion as he wrapped his strong arms
where we made plans to meet up again. There was no kiss goodnight or around me, making me feel so meager and small but so safe at the same
anything like that. No, he was too polite for that, he wanted to prove time. Encouraging me to see the worthiness of myself and leave that life
himself different and different he was. Walking through the hotel's behind, he adorned me with a kind love that I wasn't accustomed too.
revolving doors I watched as he walked away and when he was finally He took me in and made me feel so at home. It was like I had known
out of sight, I sung my way up to my room. Floating on cloud nine I was him my whole life. I couldn't bear to be without him another second
free falling into a deep pit of love. while I was away on this dream holiday. When he wasn't training for
The next day I attended my class as usual but not able to concentrate Muay-Thai tournaments and I wasn't in school, nobody would ever see
like I normally did, too excited about when l 'd be seeing Robbie that us. Too enveloped in each other in my hotel room to care about anything
night again. As I walked out of class that afternoon even the teacher else. Which is why I asked him to come stay at my hotel with me, seeing
noticed a difference in my performance and asked me ifl was feeling he was never at his own anyways. My girlfriend was soon departing back
well, "On top of the world actually" I smiled back at the old instructor to Wisconsin, making my room more than available for him. Enchanted
and it wasn't far from the exact truth either. I hadn't ever felt the by his words and tender touch, the way he made love to me was again
churning of butterflies in my stomach and the constant thoughts of like nothing I had experienced before. Even down to after sex as I had
anyone else like this before. My girlfriend and I got a tuk-tuk back been routinely instructed by Jeffrey to get up for a warm washcloth to
together as we usually did after school and I couldn't shut up about the clean his genitals afterwards, he refused it, telling me I was no longer a
night before. She was laughing at my girlishness telling me that anyone slave and that he didn't want me acting like one. He'd just rather lay
who just met me would think I had never been let out before, but little did down together afterwards and repeat our sweet nothings with many
she know that I had more than my fair share in experience with men and adjoining kisses.
never had I ever come across anyone that could make me feel this way, On our third night together with nothing but the bed sheets between us,
and what spun me out even more was that it was such an instant we had spent all night looking into each other's eyes sharing such an
attraction. Never considering myself a person who believed in the undeniable passion for one another. In the deepest caverns of my heart I
existence of"Love at first sight", but a true romantic deep at heart, I knew this man would give me what I had never experienced
couldn't help but believe in it now. He is my walking proof of it! before ... True love. We were still laying in each others arms when the
Waiting for me in the hotel lobby was the very person I couldn't stop orange and pink sunrise began to rise slowly through the peak's ofmy
entertaining the thought of all day long, there he was looking ever so fine rooms windows, enticing me to come feel the freshness of the morning's
standing in front ofme now. The whole entire world faded away and all chill. Only the bed sheets were still wrapped around my body as I went
that was left for the moment was this complete stranger I had only met the balcony. It was overlooking the city in a valley surrounded by
last night but somehow captivated the very essence ofmy very heart. mountainous tops. My thoughts began to rampage through my head and I
There was no need for me to try and act cool now. He already knew I was knew this could only be a dream for me. It was getting serious now, too
snagged hook, line and sinker. Smiling all the way up the many stories in serious for the life that I led back home. As if he sensed my anxiety
the elevator up to my room he took notice of the posh decor of the hotel. Robbie walked up behind me and wrapped his strong arms around my
"You should see where I'm staying, this is a royal palace compared to it" waistline, gently kissing my neckline and pausing with his ever so
His first impression ofme he automatically thought I was going to be a thoughtful stares and gave me the exact opening that I needed to expel
spoiled high-maintenance girl that had money coming in from a parents my thoughts. "Back home, as you already know, I am going back to
hefty trust fund. Casually he got to find out through many deep and someone else, it's my job, and as much as I really like you, this guy that I
meaningful conversations that my life's grim story wasn't that pretty at kind of see is going to expect me to be putting him first, I am so sorry to
all. For some reason beyond my knowledge I had the need to tell this say all of this after such a wonderful few days we have spent together, but
stranger almost everything. you need to know this thing happening between us can't get anymore
Wanting to be judged and looked down upon for everything about my serious than what we have for now. I am so sorry" I looked down to the
life that I knew was wrong and being the first time I had spoken about my floor with nothing else I could say to alter his perception of me now that I
years with Jeffrey to anyone honestly like that ever before, I had felt like had told him the truth and it never dawned on me that thought he
I had deserved punishment. He offered me no judgment, instead only wouldn't be out the door before I could even finish my sentence but he
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continued to surprise me with his efforts to make me believe we were out. I still had to believe in something better than what I was accustomed
more than just friends with a summer cmsh. "You see ... your problem is too and here he was right smack dab in front of me.
that you don't see what I am looking at right here in front ofme, a Giggling at all of the lace and frills they were trying to dress me up in,
beautiful girl who is completely lost in a game that she has no control looking more like an antique porcelain doll than anything else I closed
over. Get out ofit now, take my hand and follow me back to my home in my eyes and pictured the day that I thought would never come, starting to
Australia." I heard what he had said but I found it hard to comprehend imagine the kind of dress I would like to wear I envisioned a simple
what he was actually talking about. "What?" I asked him with a look of sleekness, a complimentary figure hugging gown with a small train but
confusion on my face. "Your nobody's property, you can do this. Marry long enough to distinct it as an actual wedding dress. After we settled on
me." His statements got more and more profound as he went on. what we were going to wear for the big day, we would next have to
Repeating the question he got on one knee and proposed again "Jenna, I decide where we would hold the ceremony. Not before celebrating the
am in love with you and want to spend the rest ofmy life making you entire week beforehand though. We started our honeymoon early
happy. Please don't go back to him. I know that I am the only one for you celebrating every night spending our time between my hotel room and
and I will always treat you right. He paused for another second and sending our heads spinning on the dance floor at many different clubs.
repeated his question "Jenna, will you please marry me?" My hands fell Only with each other in sight, the dance floor was ours, we were out to
into my face after that and without even letting myself think through the give each other something to remember each night by. I whispered all of
answer, I let my heart do all of the talking. Looking back up at him I said the things I couldn't wait to do him once we got back to the hotel room
"Yes!" I almost shouted the answer at him, as if saying it louder would and watching him heat up on the dance floor I was never able to get
give the word more meaning. Wanting to believe him and everything that enough of him driving me crazy. Like a thirst I was unable to quench, his
he was saying felt like a vacation from all of the suffering and loneliness lips were like a fountain of deep springs that I could never reach the
that I had endured over a lifetime of abuse and degradation but knowing bottom of.
what you want and getting it are two different things that rarely went Seven days, exactly a week after his proposal I sat on my bed in distress,
hand in hand ... or so I thought. All I knew from the brief period I had contemplating what I would say to the man who I was about to call.
known this stranger was that he was offering me a life and love down an There was no nice way to go about it. I couldn't last forever with him and
unfamiliar path and it was a gamble to believe a complete stranger but this was my one chance to get out of it for good. I was leaving him, never
somehow I knew he was right. My heart was beating so loud I thought it to return to him ever again. I just had to go ahead and do it. Part of me
was going to jump right out of my chest. With the earnestly in my reply was hoping he'd be at least a little happy for me and the sudden change in
he picked me up in his strong arms and took me back to the bed and my life's direction but the other part ofme knew I was already asking too
reiterated his words in a more physical sense this time. Never had I felt muchofhim.
loved like this before, so swept off my feet and unable to even think, eat, Calling his office in New York I was transferred to Jeffrey's personal
or do anything for that matter which would involve leaving the hotel office. He picked up the phone on the third ring, pausing before I could
room without him. get any of the words to come out ofmy mouth but I mustered up my
Everyday after school would be my Robbie waiting to take me back to courage eventually and gave him my prepared spiel. Beginning with how
the hotel room for another night's passionate rendezvous, but a few much I had appreciated everything he has done for me up until this point.
nights after his proposal, he had another surprise in store. He didn't just I hoped he would be understanding but he just wanted me to hurry up and
want to get married someday. He wanted to get married now, this week get to the point. Trying to contagiously pass on my excitement through
even. I walked into the fabric store and was attended too by several the phone lines, I finally screamed out 'Tm getting married! Can you
seamstresses who were already be expecting my arrival. I was there to believe it?" No reply was given only a silence on the other end. Trying to
design and have fun designing my own dream wedding dress. While I make some conversation ridding the uncomfortable silence, I went on to
was busy picking out fabrics and having measurements taken I would tell him about Robbie and how 1 had fallen madly in love with him over
look away for a moment only to catch his tender eyes staring in my the last amazing few days we'd spent together. The absence of sound
direction. Such adoration behind his looks ... could it be real? I would made my thoughts begin to mn wild and to get some response I had to
often ponder it to myself just hoping for the gamble I was taking to work ask him what he thought about everything I was telling him. Finally a few
seconds later his reaction to the news sunk in and his only and final reply
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until many years to come was " Have a good life!" With that statement he Falling asleep was easy to do in his arms that night. I laid my head on
slammed down phone receiver. Leaving only an echo of the dial tone to top of his chest listening to the drum of his beating heart. I had never felt
answer back too. I was to paralyzed from the shocking response. "What like I was more at home than ever before in my life. He pulled me gently
have I just done?" was the first thing that entered my thoughts. in closer to him, letting me know that he was there for me even when the
Overwhelmed with guilt I felt like I was falling down a deep and dark lights went out and the thoughts would usually creep in. Amazing how he
hole and then the tears began to flood in. Here I was standing at the dawn knew what I needed without even asking for it. Wishing for something
of a new happy life for myself and I couldn't see past how bad I had let like this my whole life I thought I was being such a fool in so many ways,
Jeffrey down not yet seeing the hold he had on me. but I was so wrong. The way his pretty eyes looked at me with such an
Like my knight on a white horse, in came my hero to soothe my understanding and compassionate sincerity made me want to trust his
somberness. He rushed over to the bed where I was beating myself up words and believe the love that he was offering me was indeed real.
mentally and wiped the falling tears from my cheeks. "I take it that it The next morning, Robbie was up and out of bed early to pick up our
didn't go so well ... huh?" Sniffling through my sobs I managed to tell tailored wedding suits and dresses for our big day at Doi Cept Temple.
him that "It doesn't matter anymore all I care about is you and leaving all His best friend from high school days that was travelling with him from
of that life behind me!" I wrapped my arms around him and he asked me Australia met him in the hotel lobby at seven o'clock. He was going to be
in a half joking voice "Then why are you crying?" He got me almost joining us for the wedding as Robbie's best man. He still hadn't been able
laughing now too "I guess it's just so scary taking such a huge plunge to find black shoes to go with the suit, so after he dropped off my dress
away from what l 'm used too and taking such a big move to another back to me he was off again to try and find himself a pair of decent
country. It's just all so different and I'm just trying to comprehend looking ones. Overjoyed with excitement I was thrilled from the second I
everything that is happening in such a short time." Always out to lift my kissed Robbie good-bye for the last time before we were officially
spirits his next comments made me gush in laughter "You think that was married. Looking in the same mirror only a week ago I was now a
a hard phone call wait until I call my Sicilian mother! Watch this, I know different person, I felt like I was plunging into a bottomless abyss. Here I
exactly what she'll say. First it'll be a saga about how I'm killing her with go, I thought to myself as I plunged out the door letting the butterflies in
my selfish actions then it'll be about how she's going to kill herself for my stomach carry me all the way to my nearly husband.
doing such a terrible job raising normal children. Don't worry though, I had to go to the beauticians that morning for my pre- wedding makeup
she'll love every second of it. Wogs thrive off of the drama in their lives and dressing. The ladies who were doing my hair and face at the salon did
and off everybody else's for that matter!!" He was pretty much on the dot a great job making me feel so beautiful for my special occasion that every
when he told me how she'd react to the news. In the end after relentlessly girl dreams about their whole entire life. Requesting simplicity at best,
trying to change his mind, she sighed, "lfit was going to be anybody to not wanting to go overboard with all of the wedding apparel they tied my
do something as crazy as this, Robbie, it would be you!" It wasn't a long hair up into a knot wrapping around it a veil of flowers made up of
blessing as such but at least she wasn't threatening suicide any longer. baby's breath and small yellow and purple budding flowers. I couldn't
Calling the closest of our families the night before our wedding to share have dreamt it up better myself and when I met my husband to be at the
with them our announcement wasn't celebrated by any members of either bottom of the mountain he stood before me speechless "You look so ...
sides but that didn't discern us one bit. My parents took it well, beautiful!" were his first words that his mouth formed almost whispering
considering their only daughter was marrying a foreign man that they them. He took my hand and we walked into the sky lift together. Behind
didn't know from the next guy on the street and too top it off I was us followed an interpreter that Robbie hired to translate the Buddhist
moving to Australia, pemrnnently. When I asked my Dad many years Monks ceremony speech for us English only speakers and then his best
later why they hadn't put up a fight, he just simply replied that nobody friend, who only moments before gave him the best mans speech about
expected it too last very long. Fair enough, I thought. I don't think being the last chance to walk away from this and not get married to a girl
anyone did at first. .. even us at our toughest times. We were a rare he hardly knew, but my Robbie wouldn't hear a word of it. He already
attribute these days in the numb era we have all been accustomed to made up his mind the instant he proposed and I said yes, "I was born to
living in, turning nothing into something, which I had also come to be with this girl," he told his best mate. "Alright then lets go do this
realize, was the most precious gift in life ... Love. then!" Once he knew Robbie was sure in his decision he was more than
ecstatic for him. We were slowly lifted up the tremendous mountainside,
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surrounded by the floral green carpet of mossy grass that covered the whole life around and how I would dedicate my entire being to loving
earthly skyscraper and falling fog, it was like being carried to heaven or him and only him until I blew my final breath.
the closest thing to it! Taking my eyes off the scenery and catching him I meant every word that I said to him, this was it for me, wanting
adoringly staring at me again, 1 welled up with unstoppable tears. "I am nothing more out of life than to be with someone like him to raise a few
so lucky, is this really happening?" He squeezed my hands and replied kids together and grow old on the front porch letting the days fade us by.
back "You're the only one for me .. .I love you!" relieving the anxiety I know it probably sounds boring to most and it would've to me as well
written all over my tear stained face. many years ago but after the life I had led, I had enough experience in the
real world for my liking and now all I want to do is to enjoy the
Chapter 22 remaining days ofmy life for what it is ... a simple and satisfying
existence. Our day was so special but not only to us, even too the Monk
that married us. Upon our descent down the lifts he asked ifhe could take
Getting out of the carriage we were greeted by good fortune from the
Gods above. A sun shower cascaded over us at we advanced into the a photo with the bride and groom in front of their symbolic liberty bell
signifying the union between east and west. It represented a lot for us too,
ancient holy temple. My tears of joy dried and my happiness was glowing
it was the commencement of a new life together and just the beginning of
for all to see. The many visitors to the temple stopped and took photos of
battling each other's past demons together.
the passing bride and groom, no other foreigners had ever been married
Kissing the bridal party goodbye, who were just the local girls I had
there and certainly anyone wearing traditional western wedding attire,
met on some of our many nights out of having fun. I threw my arranged
such a sight had never been seen behind these religious walls, we became
bouquet of Thailand's white wedding floras mixed with colorful orchids
a permanent icon at the temple. The ceremony was done in the Buddhist
customs according to their ancestral accordance, and translated for us in to the screaming Thai women behind me and we were given one last
tradition to take with us, the release of caged doves. It was such an
our own lanb'llage. Both Robbie and I were anointed with a blessing from
incredible gesture, especially for me. Symbolizing their freedom as well
the monk with a splash of water and seven sacramental bracelets, each
as mine I opened the cage's door to let them free to decide our own fates.
one representing another meaning to the longevity of our union together.
As the wings on the birds began to spread open and they took their final
We signed our names in the Buddhist wedding registry of Doi Cept
decent into the blue skies granting themselves freedom I knew mine had
Temple and officially became Mr. & Mrs. Roberts at least officially in
finally come too. The relevance of watching them fly away and how I had
our hearts knowing the laws of Australia only recognize certified
weddings, meaning when we got back to his homeland we'd have to perceived my own day of marriage related to the identical feeling of
fleeing an entrapment of my own kind. I was liberated from the bounds of
make a run for the courthouse. This was our real wedding though, perfect
down to every detail. Walking up to the highest point of the temple to the slavery I had come to know over the many years I had spent with my fair
share of greedy perverted old men only to have serendipity mend my
balcony hanging over the edge of a cliff side over looking the city of
Chang-Mai, we knew we had found the perfect spot to recite our vows of scars with the powerful healing of what true love has to endeavor on.
As customary in the romance novels I had read as a young girl he
love to each other. Providing everything for me and more than I could
picked me up in the hallway before our hotel suite and carried me over
ever ask for, his vows were to love me unconditionally until death do we
part, shelter me from all the cruelty in the world that I was so accustomed the threshold, poufy dress and all. My arms were tightly squeezed around
his neck never once taking my eyes off of him until he revealed yet
too and to be like the bear, because the bear never forgets. Tears once
again streamed down from my eyes as he made this moment another sweet surprise. Besides the cleaners tiding up my room while we
were gone they were also given instructions by none other than the groom
unforgettable. Wiping the mascara fading underneath my eyelids whilst
himself to pick the petals off the stems ofred roses to place on our bed in
giggling at my embarrassment I took his hands back into mine again and
the shape of a giant heart. The rose petals led the way to where we
gave him the vows that were the sacred prepared words from my heart.
consummated our love physically and it was undeniably the first time in
My ears were thundering the sound of a million horses hoofs descending
my life I had really ever been made love too. Hours had passed by before
downhill and my heart was beating so fast my words barely trembled out
we thought about anything else besides one another's words of arousal,
ofmy mouth when I began to tell him how much he had changed my
tantalizing touches, and lingering kisses. We ate a quiet dinner at a local
restaurant and went straight back to the arms of each other again, so
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profoundly in love with one another it was the ideal display of what the intentions but still recovering from old wounds. It was only natural and
"honeymoon period" should have to show for. It was crazy, young and important that we fought just as much as we made passionate love
energetic, just what it should be between two blossoming lovers. together. Countlessly proving to one another the true intentions of each
The following morning we left the Princess Hotel, no longer under any other loves but sometimes in not so seemingly actions.
of Jeffrey's financial privileges or control so to speak, continuing our Finally arriving at the hotel it was like a scene out of a horror flick. We
love spree in another dwelling of our own accord. Three days later when were showed up to the room that looked like someone had been brutally
we finally showed our face for the first time since checking in downstairs killed in. The bed sheets were torn apart and the bed was stained with
in the new hotel lobby, besides to request fresh sheets and towels, the blood from some poor helpless victim. Nearly vomiting at the pure sight
entire staff of the hotel had a good laugh at our expenditure, from their of the room and the stench that accompanied it, I was now tearing at the
reaction it must've been nice to see a couple so affectionately fond of thought of even staying here for a single moment longer. "No way!" I
each other. told my new husband and from the tone in my voice he knew I was
Now we wanted to have another type of fun, Robbie had visited a serious. Not that I was not denying the fact I have never been an outback
tourist agent by himself before we got hitched to book a honeymoon type of girl. I was fine with that impression, I am no snob but give me the
itinerary for us to explore Thailand and beyond together, another surprise simple luxuries of a clean bed and a shower then I'll make myself at
he had in store for me. We left early in the morning and joined the home, but this was just the epitome of filth and even possibly an act of a
crowded bus for our journey beyond the border of Thailand to a village in horrendous event but who knows, the lady who showed us to the room
the war torn nation of Laos. When we got through the extremely armored seemed fine with it passing it off as a hooker on her period. In some ways
visa office eight hours off the beaten path, we then had to cross a flooding that was even worse ... "Yuk ... Okay Robbie it's time to go ... now!" we
river from a recent heavy downpour of rain in a slim banana boat that were heading back down hill back to the passport center declaring our
looked like it could barely handle our weight let alone the excess of my passage back into Thailand. Considering us a risk due to the short time
luggage that Robbie was so kind to trek around the world for me. we spent crossing the border and back, the officials held us at gunpoint
Unbelievably we did make it to the other side only to find that my while others rummaged through our luggage for drugs or whatnot.
honeymoon in the tropics wasn't exactly how it had been explained to Finding nothing of course they released us and stamped our passports,
me. Naked children ran through the dirty streets, with one boy that making us good for another three months ifwe wanted. We were thankful
decided to release his bladder on the pathway where we were walking as for escaping with our lives alone, although we had nothing to hide but
we passed by him on the way to our hotel. My doubts of his choice in still an endearing experience nonetheless in the first days of our
destinations became apparent after that sight. Robbie was getting hungry honeymoon of all days.
after we hadn't eaten the entire duration of the trip and being such a
rugged man he could digest just about anything. Deciding to stop on the Chapter 23
side of the road he ordered some kind of seafood dish ... daring I thought,
settling for some toast and jam, something safer I thought. Then I saw the
Arriving in Koh Samui for finally a bit of relaxation in the tropics, it
lady behind the counter dip some plates in a dirty bucket full of dirty
was my idea of how a holiday should be, sunny warm, and clean ... well,
water and then rinse in another bucket of water that didn't look as bad as
clean enough. We lived it up like kings for the next six weeks. Making it
the previous mud drenched one and then further proceeded to put my
an ideal way for two strangers to properly get acquainted. Dancing into
toast and his food on top of them serving it to us all in a clear view. I just the wee hours of the night and making love in the blistering heat of the
couldn't bring myself to even fathom it "I can't eat that!" I mouthed in a
sunny days we discovered everything on that island ... mostly being each
hushed voice trying to quietly make my point clear but was made public
other. We made friends of all sorts, mostly travelers, but everyone the
with his loud mouth outburst of "Why not? Looks fine to me. You have
same in being taken aback by our fairytale romance. With our captivated
to try and eat something, you haven't eaten all day!" I know it was just
eyes never straying too far from one another anyone could easily see the
his caring side that was trying to force me and to top it off he is Sicilian
strong chemistry between us.
and they're all about eating so it was our first debate and now we were
Trying to find the woman in me wasn't difficult, as I took to the bounds
officially married with many more marital conflicts to subsequently
of marriage with such ease, no longer a girl I loved the idea of being a
follow. Two head strong and stubborn people both with the right
131 132
wife and belonging to a husband like Robbie. Marriage was bliss for the and got on the phone immediately which sounded like a phone call to his
duration of our honeymoon until we had to ride coach on our way to superiors but I couldn't tell since it was in another language. A brief
Bangkok Airport to fly out to Australia. Chatting away with always so conversation but long enough to get me thinking, he then called over two
much to say to each other we watched a movie and finally got guards who took me by the anns and brought me into an empty room but
comfortable leaning up against each other as pillows. We both fell asleep for a desk and three chairs to be interrogated. No one would tell me what
on the long ride and when we woke up to the sound of the buses brakes was going on they all just scattered around in frenzy, ignoring all ofmy
coming to a halt we initially realized my purse and Robbie's wallet with hysterical inquisitions. Leaving me by myself and alone with my thoughts
all of our money and cards in it was missing. Stranded in the city of I couldn't help but panic even worse now.
Bangkok was frightening enough as it was but too make matters worse a This was a total bombshell of confusion on my part, what had I done
lady looking in her mid-seventies, scrawny and hunched over from an wrong? Minute's later a large-framed women in a green uniform entered
obvious lack of nutrition lifted up her skirt to a passer-byer with a she- the room with the guards from before and sat down across from me with
male hanging off his arm and began smacking her vagina blaring out a stern look in her eyes. She placed my documents on the desk in between
"Look! No cock ... Pussy, pussy! Only five baht" repeating herself many us. Not saying a word to me she was waiting for me to give her an
times over the man just walked on past as she sat back down on the curb explanation for something. "Can you please tell me what this is about,
waiting for the next alluring customer. Robbie and I shook our heads in have I done something wrong?" I asked her politely, trying to restraint
disgust and disbelief, things could really be that bad for someone, I would any animosity towards her. Her reply sounded as grim as she looked.
know best as it wasn't far off the life Jeffrey had been training me up for. "You have been in Thailand for three months and now you have only a
Completely broke at two o'clock in the morning and with no one to call one way ticket booked to Australia with no visa. What exactly are your
for help, I panicked right away. Robbie rubbed my back and his tired eyes plans once you get there, Ms. Roberts'>" To myself I wondered what
trying to make the situation better. Luckily we had made friends with business it was to her, don't people travel with one-way tickets all the
some really nice people from the resort on the island who gave us about time? Knowing I was in no position to be able to say anything like that or
two thousand baht when they saw how devastated Robbie and I were. even at all I just gave in nicely and told her my intentions to travel over
With just enough money to rent a really cheap room for the night at a there. Crying through my entire explanation I wasn't sure if I was going
backpackers hostel and pay for a taxi to the airport the following day, we to even make my flight now. She had to think about everything I had told
were saved. her for a moment, deciding whether or not she would grant me
Early the next morning we were off in separate planes, since Robbie's permission to meet my husband in Australia or send me back alone to
ticket was pre-booked and no available seats left for me to join him meant Bangkok. With only time on my side she had to make a hasty verdict
we would be landing in Australia separately. Fortunately we had found a now. One more question had to be answered before I was let go, she
corresponding flight that arrived within the same hour of each other but I wanted some proof. " If you have just got married can you show me your
would have to make a stop over to the Philippines. The lengthy hours of marriage certificate then'?" This didn't help my stories credibility at all
the duration on the flight seemed to stretch on with only the thoughts of seeing that we were married in a Buddhist temple and given woven
the journey ahead ofme I couldn't wait to get back to my husbands bracelets instead of certificates. Explaining to her that I didn't have one to
loving arms. The trip was going well, sleeping the majority of the flight show her yet but was already aware that I would have to obtain a legal
until I had to change planes in the Philippines. marriage certificate through a courthouse upon my arrival in Australia to
After the plane landed and before any passenger was allowed to get off stay there legally, it was only because ofmy husbands beliefs we wanted
we were handed a declaration statement that informed us that ifwe were to get married in a Buddhist ceremony. She must have shared a common
carrying any drugs or weaponry, we would be arrested and face charges interest in religion or something like that as she finally cracked a smile
with death as the ultimate penalty. Not that I had anything to worry about, upon the photos of the wedding day that I showed her and carrying in my
but what a thought to willingly sign over your life. I got the chills purse since getting them developed, if she wanted proof, well this is all I
handing over my signed declaration and traveling documents to the really had.
customs officer. Obtaining my passport he additionally asked to see my Handing me back my documents and ticket I was now free to leave but
departing ticket. No problem I thought, just I had done many of times, she wasn't leaving me much time to run through the airports terminal to
and I handed over the requested information. The officer looked me over get to my departing plane. Expeditiously bolting through the busy airport
133 134
my adrenaline was still pumping from the previous encounter with the taken a lot of hard work and doesn't come without its flaws but no matter
officials of the Philippines who had enough power to condemn me if they what it is just perfect for the two of us. He helped me how to remember to
had felt like it. I caught my plane in the knick of time and once I was smile again and life has slowly began to sort itself out. They say that time
settled in my seat my thoughts went back to my dear Robbie and how heals all wounds but what I had experienced in my young years wasn't
much I was missing him. I was just relieved that I was on my way to be nearly long enough to let all of the hurt go. Seeking help through many
back with him again soon. counselors and psychiatrists I was doing everything l could do to deal
Looking out the window l could see the red earth beneath me. As l with the scars and all of the pain left behind. Completely off of any
landed for the last time I took notice of the first steps I walked off the pharmaceuticals, since the last day of our honeymoon, and healing my
plane and onto a new soil for the first time. l had so much to be looking heart with love instead of hate our marriage is my foundation and Robbie
forward too in my new homeland. In my heart I knew this was all I ever is my solid rock. We have to be for one another, putting the bonds of our
wanted, this was going to be my haven. There was another surprise in union through the wringers and back, as neither ofus expected my past
store for me when two elder strangers walked up to me and asked my life eventually to come back and haunt me after so long.
name. "Are you Jenna?" Nodding at their question they gave me their Our blissful life came to a sudden halt one day when we were out
first names and wrapped their arms around my neck. My new mother-in visiting my in-laws at their nearby house on just another plain afternoon.
law then said," We are Robbie's parents. We wanted to be the first ones There was a knock on the front door and my father in law got up from
who welcomed you to Australia and into our family" It was my in-laws watching TV on the couch to answer it. He rushed back quickly coming
meeting me for the first time. Handing me some balloons and flowers into the dining room, where l was feeding my nineteen months and five
they even had gifts for their new daughter-in law. While waiting for month old boys at the table, and he blurted out, "Jenna there are three
Robbie's plane to arrive we all chatted about many things like the flight police officer's at the door asking for you by the name of Virginia
over from Thailand and the scare at the previous airport in the Roberts!" I asked my mother in law to stay with the babies to find out
Philippines. I asked them how they knew whom to look for? My father in what this was all about. I didn't even think it had anything to do with
law laughed, saying recognizing me was easy from Robbie's detailed Jeffrey at first and wasn't even worried when I opened the door to offer
description. He told them to look out for a petite, young blonde carrying them to come inside to talk.
an abundance ofluggage. Laughing together over a few more brief They weren't actually police officers and two federal agents of
conversations of getting to know each other better they seemed relieved Australia with one F.B.l agent from America. The American agent asked
to finally meet me compared how stressed she sounded in the ifI wouldn't mind actually coming outside so that I may speak with them
conversations I overheard Robbie having with her while in Thailand. in private. "Okay" l said, as well as mentally preparing myself for
Watching the arrivals board l knew Robbie's plane had landed ages ago something big from the look of it, it's not over a parking ticket or
but was just waiting for him to get out of customs. It didn't bother me anything small that you get three federal agents knocking at your in-laws
anyhow, l was enjoying get accompanied with his parents for the first front door asking to speak in private. "Can we first ask you if you are in
time. Eventually I saw my husband walking down the runway behind the fact Ms. Virginia Roberts and originally from Palm Beach County in the
gates, I just couldn't wait a second longer. I ducked underneath the gates United States?" I confirmed my name and previous state of residence
and ran all the way up the mnway to jump excitedly into his arms. I then they even asked, "May we see some identification please?" A
wrapped my arms and legs around him holding onto him for dear life. I different agent asked the question this time and I told him "I will have to
just missed him so much I knew I would never let him go, theoretically go and grab it, my purse is inside. I'll just be one second."
speaking that is, and I never have nearly a decade later. Robbie was standing on the other side of the door trying to figure out
what they were doing here talking to me and when I rushed through it to
grab my purse and saw him standing there looking puzzled, I told him I
Chapter 24 had no idea what this was about yet, but not too worry everything was
going too be just fine. Taking a deep breath and slowly exhaling
outwards, I opened the door to find out exactly what the agents wanted to
Over the near decade we spent together, Robbie and I have shared the
talk about.
common highs and lows that every determined marriage endures. It has
135 136
Pulling out my Australian drivers license from my wallet, I was going the house and went out to the back yard where I wanted a minute to
to hand it over to them but they were sufficed at a quick glance. There compose myself and process the information I had just been told. Robbie
was no meet and greet, they went straight to the point. One agent picked followed behind me but the stillness in my eyes convinced him to give
up a briefcase off the porch floor and opened it up taking out a stapled me that moment to compile my emotions.
stack of paper. Then that same agent asked me ifl had ever known an A few moments later and I was ready to talk. Collapsing into his arms
affiliate by the name of Mr. Jeffrey Epstein. All of the sudden my with such anguish, he just held me until my sobs subsided and I was able
stomach tangled in a familiar knot that I hadn't felt in many years from a to tell him what actually happened. Starting with an apolob'Y,I began to
past life that I was trying to forget about. I nodded in affirmation of their tell him how I was so sorry but my troubled past has come back to plague
question and said "It was a long time ago and he's no longer an affiliate our simply sweet lives and was just about to turn it all upside down. He
of mine, but yes, I did know him once." It was shameful enough to think was so understanding from the beginning of all this, telling me that he
about let alone talk about with them for the first time since I had started will always be behind every choice that I make in mending the sorrows of
my entire life over. His next response left me nothing short of speechless. my tormenting past and there he has been through all of the thick and
The United States Attorney's Office for the district of Florida was giving thins.
me a notification of being an identified victim. Jeffrey was finally caught Deciding to call the lawyers on the victim suit provided for me was a
for his atrocious acts of perversion on girls who were barely old enough big decision but one I had to do to seek the unanswered questions from
to even comprehend "the birds and the bees" so to speak. my battered heart. The two women at the firm that I spoke to treated me
On June 30th 2008, Jeffrey Epstein pleaded b'llilty for procurement of so wonderfully, like long term friends they counseled me not only in the
minors to engage in and solicitation of prostitution. More than a dozen terms of a lawsuit towards Jeffrey but also in the matters of being
girls had been named as victims of Jeffrey's federal offense's and without emotionally and sexually abused. I chose to proceed with the lawsuit at
ever stepping a day in court he was granted a plea bargain consenting to least to make a statement to a man that tried to make a degrading
charges that named him a registered pedophile for only two of the minor statement about me so long ago. Now it was my tum, I had the choice to
girls. Getting away with even serving only twelve of the sentenced turn the tables on him hoping he would feel embarrassed and in the
eighteen months behind bars be that in the evening alone and in the spotlight for everyone's entertainment where he had kept me for so many
morning he was released during the day. Restricted to the confinement of years.
his lavish mansion in Palm Beach only to be with his original sex slaves Winning my lawsuit against him was not enough to heal old wounds, I
from over ten years ago, Nadia Marcinkova and Sarah Kellen, and never got the chance to stand up in front of a jury and tell them how
knowing Jeffrey all too well, they wouldn't be the only ones there while much pain I had endured and still endure throughout the many nightmares
he was pulling his laughing stint of retribution. Even at nighttime the girls I face when darkness hits and the silence of the sleeping household fills
were still allowed to visit him, accounting to nearly seventy times while my head with pictures of reliving my past with him or the others he sent
serving his time in incarceration. me too. Or did I even get to hear him confess his guilt and suffer the way
No justice had been served for any ofus victims. Denied the very I did locked in confinement for many years? No, instead I got to see a
constitutional rights allegedly there to protect and serve us. We weren't picture of Jeffrey with his anns around a very youthful looking teenager,
allowed to have a voice in front of a jury and judge or even informed for if even that, parading the streets of New York, the very way he had with
that matter. Instead we were handed this notification of being a victim but me and so many other girls long before.
told we were all too late to do anything about. To make matters worse As if it were a public display intended for not only his many victims to
part of that plea bargain was that we had the option to sue him with the see but also a spectacle for the public justice system, it was bold show of
lawyers he provided for us, and conveniently enough I found out later insolence laughing in our faces while we all sat by not being able to do
they were also his lawyer's old friends from the college days. anything to help these young girls from the streets still suffering his
I felt my knees go weak and the anxiety churning in my stomach was perverted afflictions. Not much longer there was another story on Jeffrey
now making me feel sick. Taking the bundle of paperwork from the agent I saw in the papers of him and Prince Andrew having a stroll together in
who was now handing it to over me, I had to excuse myself before my Central Park. It instantly sparked my concerns for other girls in the very
legs actually buckled. Closing the door behind me I couldn't even find same position I was in so long ago and he was obviously up to the same
the words to tell my husband what was going on. I rushed to the back of old tricks, I had to do something now. Not being able to sit by any longer
137 138
with the knowledge of being able to help out in some way. I had to tell
my story no matter how shameful it was to even speak about. Putting my
shame aside I had to derive every bit of courage I could sustain and now I
am ready to tell it. The hardest lesson I had failed at learning until later
on in my life became my strength, the belief in my inner voice and the
ability to speak up. I do have a voice and now the world is going to hear
it in my whispered cries for justice. Swept away by a surge of media with
one phone call I sent Jeffrey's publicist into frenzy. Not to mention the
release of the photos showing the first night that Prince Andrew and I
shared together that I so happened to unveil for the public to see.
I spent too much ofmy life going out ofmy mind waiting for the
rescue that never came until it was too late and then the scars were
already imbedded deeply within. Thankfully I am now free from the
struggles that nearly destroyed the love inside ofmy heart. I only wish it
could be the same for the other victims, not just of Jeffiey's inflictions
but every person who has ever suffered at the hands of another.
I'm here to tell you from my own experience that the moon is yours if
that's what you want, all you have to do is stand up and take it. If some
girl off the streets of Florida, like me, can stand up against the tyrants that
run the deep pockets of our world, than anyone can. Just like I needed to
believe that someone stood up for me once like Robbie did long ago, I
now stand up for us. For all of us girls, the ones who are still on the
streets and think they don't deserve better or it's an unachievable dream
to be entitled to more out of life. For all of the beautiful girls who don't
see beyond they're outside appearance. For all the girls still trapped in
enslavement and unable to get out of the abuse that holds them down. But
most of all, I stand up for every girls belief in love, because it is the very
savior of my spirit and soul.
The End
Written and Illustrated by Virginia Roberts
139 140

141
□ Copyright Protected Material

CONFIDENTIAi. GIUFFRE004274
EXHIBIT D
GIUFFRE
vs.
MAXWELL
Deposition
VIRGINIA GIUFFRE
05/03/2016

216 16th Street, Suite 600
Denver Colorado, 80202
303-296-0017
IN THE UNITED STATES DISTRICT COURT
Civil Action No. 15-cv-07433-RWS

VIRGINIA GIUFFRE May 3, 2016
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
APPEARANCES:
FAMER, JAFFE, WEISSING, EDWARDS, FISTOS &

LEHRMAN, P.L.
By Brad Edwards, Esq.
Suite 2
Phone: 954.524.2820
Plaintiff

By Sigrid S. Mccawley, Esq. (For Portion)
401 East Las Olas Boulevard
Suite 1200
Fort Lauderdale, FL 33301-2211
Phone: 954.356.0011
Plaintiff

1 APPEARANCES: (Continued)
2 HADDON, MORGANAND FORMAN, P.C.

By Laura A. Menninger, Esq.
3 Jeffrey S. Pagliuca, Esq.
4 Denver, CO 80203
Phone: 303.831.7364
5 lmenninger@hmflaw.com
6 Appearing on behalf of the
Defendant
7
Also Present:
8 Brenda Rodriguez, Paralegal
Nicholas F. Borgia, CLVS Videographer
9
10
11
12
13
14
15
16
17
18
19
20
21
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25

1 Pursuant to Notice and the Federal Rules
2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF
3 VIRGINIA GIUFFRE, called by Defendant, was taken on
4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150
5 East 10th Avenue, Denver, Colorado, before Kelly A.
6 Mackereth, Certified Shorthand Reporter, Registered
7 Professional Reporter, Certified Realtime Reporter
8 and Notary Public within Colorado.
* * * * * * *
10 I N D E X
11
EXAMINATION PAGE
12
MS. MENNINGER 8
13
14 PRODUCTION REQUEST(S):
15 (None. )
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25

1 wanted to know about the Prince Andrew incident.
2 Q So that's a different piece of paper?
3 A Yeah, that's just random paper.
4 Q So you had a green spiral notebook that
5 you began sometime in 2011 or 2012 in which you wrote
6 down your recollections about what had happened to
7 you, and you burned that in a bonfire in 2013.
8 Did I get that right?
9 A You got that right.
10 Q And do you have no other names of people
11 to whom you claim Ghislaine Maxwell directed you to
12 have sex, correct?
13 A At this time, no.
14 Q Is there any document that would refresh
15 your recollection that you could look at?
16 A If you have a document you'd like to show
17 me, I would be glad to look at it and tell you the
18 names I recognize off of that.
19 Q I'm just asking you if there's a document
20 you know of that has this list of names in it?
21 A Not in front of me, no.
22 Q Where is the original of the photograph
23 that has been widely circulated in the press of you
24 with Prince Andrew?
25 A I probably still have it. It's not in my

1 possess i on right now.
2 Q Where is it?
3 A Probably in some storage boxes.

4 Q Where?
5 A I n Sydney.
7 A At some family ' s house. We got th e boxes
8 sh i pped to Aust ralia , an d they were p i cked up off the
9 porch by my nephews and brough t to t he ir house .
10 Q Whi ch is where?
11 A I n Sydney.
13 A
14 Q And who lives in that house?
15 A Well, it ' s owned by my mot her- i n-law and
16 fath er- in - law , but my nephews liv e in the house.
17 Q What are th e ir names?

18 A I ' m not giving you the names of my
19 nephews .
20 Q What ' s the address of the house?
21 A Why wou l d you want that?
22 Q I want to know where the photograph is .
23 I ' m asking you where t he photograph is. And you've
24 just tol d me it ' s somewhere in
25 A Yes.

1 Q So where in i s th e photograph
2 loca ted?
3 A If I can ' t 100 percent say that the
4 photograph i s there, it could be at my house that I
5 presently live i n. I ' m not going to g iv e you t he
6 address of my nephews' res i dence.
7 Q When i s the l ast tim e you saw t he
8 photograph i n person?
9 A When I packed and left Amer i ca .

10 Q Co l orado?
11 A Yes.
12 Q All right . So you had that photograph
13 here wit h you in Colorado?

14 A Yes.
15 Q What ' s on t he back of t he photograph?
16 A I ' m sorry?
17 Q Is there anything on th e back of the
18 photograph?
19 A There's like the da te i t was pr i nted, but
20 no writ i ng or anything.
21 Q Okay. Does i t say where i t was pr i nted?

22 A I don't be l i eve so . I t hi nk it j ust I
23 don't rem embe r . I just remember there 's a da te on
24 it .
25 Q Whose camera was i t taken wi th?

1 A My little yellow Kodak camera.
2 Q Who took the picture?
3 A Jeffrey Epstein.
4 Q And where did you have it developed?
5 A I believe when I got back to America.
6 Q So where?
7 A I don't know.
8 Q Palm Beach?
9 A I don't know.
10 Q What is the date the photograph was
11 printed?
12 A I believe it's in March 2001.
13 Q Okay.
14 A But that's just off of my photographic
15 memory. I don't -- it could be different, but I
16 think it's March 2001.
17 Q You have a photographic memory?
18 A I'm not saying I have a photographic
19 memory. But if I'd look at the back of the photo and
20 I remember what it says, I believe it was March 2001.
21 Q Did the photograph ever leave your
22 possession for a while?
23 A I gave it to the FBI.
24 Q Okay. And when did you get it back?
25 A When they took copies of it.

1 Q When was that?
2 A 2011.
3 Q When they came to interview you?
4 A Yes.
5 Q So from 2011 until you left Colorado it
6 was in your personal possession?
7 A Yes.
8 Q What other documents related to this case
9 are in that, storage boxes in Australia?
11 A Documents related to this case -- there
12 I don't know. I really can't tell you. I mean,
13 there's seven boxes full of Nerf guns, my kids' toys,
14 photos. I don't know what other documents would be
15 in there.
16 Q (BY MS. MENNINGER) Did anyone search
17 those documents after you received discovery requests
18 from us in this case?
19 A I haven't been able to obtain those boxes.
20 I can't get them sent back up to me. It's going to
21 cost me a large amount of money. And right now I'm
22 trying to look after my family, so I'm not able to
23 afford to get them up.
24 Q You live in Australia, correct?
25 A I do.

1 Q Okay. How far away are the boxes from
2 where you live in Australia?
3 A Sydney is down here at the bottom. Cairns
4 is up here at the top.
5 Q Okay.
6 A It's probably a six-day drive.
7 Q Did you fly here through Sydney?
8 A No.
9 Q Have you been to Sydney since you've moved
10 back to Australia?
11 A I flew into Sydney with my three kids, but
12 it was a connecting flight to Brisbane.
13 Q Did you ask your nephews or anyone else to
14 search those boxes in response to discovery requests
15 that we issued in this case?
16 A They are my nephews. I would never let
17 them look at those.
18 Q Other than your green spiral notebook,
19 what else did you burn in this bonfire in 2013?
20 A That was it.
21 Q That's the only thing?
22 A Yes.
23 Q Did you use wood?
24 A Yes.
25 Q Charcoal?

1 A My husband bu ilt th e bon fir e out o f wood
2 and I don't know what e ls e he put in it . He's the
3 one who always makes t he fir es, not me .

4 Q Who e l se was present?
5 A Just him and I.
6 Q Were your kids t here?
7 A No. They were i ns id e s l ee ping .
8 Q And what beach was th i s?
9 A It wasn't a beach. It was i n my backyard.

10 Q What's your address?
11 A At that time?
12 Q Um-hum.
13 A
14 Q
15 A Yes.
16 Q Who were your neighbors?
17 A Sweet peop l e. Ray and -- I could look on
18 my phone if you want.
19 Q No, thank you . Do they still li ve t here?

20 A Yes.
21 Q Do you keep i n touch wi th th em?
22 A Last time I talked to them was a few
23 months ago .
24 Q Did the y see the fire?
25 A They've seen many fires that we ' ve had.

1 We've had lots of bonfires there.
2 Q Did you ever ride in a helicopter with
3 Ghislaine Maxwell acting as pilot of the helicopter?

4 A Yes.
5 Q Who else was on the flight?
6 A I've been on the helicopter with her
7 plenty of times. I can't mention how many people
8 were on the -- on the helicopter at the same time.
9 Q How many times?

10 A I don't know. Do you have helicopter
11 records that you could show me?
12 Q I'm asking you how many times you were on
13 the helicopter with Ghislaine Maxwell acting as the
14 pilot --
15 A It's impossible for me to answer the
16 question without having the actual physical records
17 in front of me.
18 Q I'm asking you to look into your memory
19 and tell me how many times you recall being on a
20 helicopter with Ghislaine Maxwell at the pilot seat?
21 A There is no number I can give you.
22 There's plenty of times I've been on her helicopter.
23 Q Where did you go from and to on a
24 helicopter?
25 A I believe it was -- don't quote me on this

1 b ecause I get con f used on th e i s l ands th e r e. I want
2 to say it was St. John ' s . It could have been
3 St . Barts . St . John or St. Barts , and then we would
4 fly straight to Jeffrey's i sland .

5 Q Okay. Did you ever go anywhere else on
6 th e he l icopt e r?
7 A No.
8 Q Were you eve r on the he lic opter with
9 and Ghis l a i ne Maxwell as th e pilot of t he
10 helicopt er?
11 A No.
12 Q Were you ever on the he li copter with
13 and Ghi slaine Maxwell as the
14 p ilo t?
15 A No .
16 Q Do you r eca ll telling Sharon Churcher that
17 you were?
18 A No .
19 Q Di d you see the press art icl e i n whic h
20 Sharon Churc her reporte d that you were?

21 MR. EDWARDS
: Object i on. I 'd just ask
22 that if you ' r e going to ask this witness about a
23 specif ic article I'd lik e for her to see t he article .
24 Otherw i se she's not going to testify about it .
25 If you have something to show her, t hen,
VIRGINIA GIUFFRE 5/3 /2 016 216

1 p l ease.
2 Q (BY MS. MENNINGER) Do you recall seeing a
3 press article in which Sharon Churcher reported that
4 you were on a helicopter with and
5 Ghislaine Maxwell as t he pilot?
6 MR. EDWARDS
: Again , I ' ll l et you answer
7 th e ques tion once she ' s looking at th e documen t that
8 you ' r e being asked about.

9 MS. MENNINGER: You ' re not l e tting her
10 answer a ques tion about whether she recalls a
11 particular press statement?

12 MR. EDWARDS
: I will let her answer every
13 question about the press statement as long as she
14 sees the press statement. I'm okay wi th t hat. She
15 ca n answer all of them .

16 MS. MENNINGER: No, t here is a rule of
17 civil procedure that allows yo u to direct a witness
18 not to answer a ques tion when there ' s a claim of

19 privilege .
20 What privilege are you claiming to direct
21 he r not to answer this ques tion?

22 MR. EDWARDS
: I thought that you wanted
23 accurate answers from this witness . If the

24 MS. MENNINGER
: I asked her if she
25 recalle d something --
1 MR. EDWARDS
: If th e so l e purpose is to
2 just to harass her --

3 MS. MENNINGER
: I asked her if she
4 recalled something --
5 MR. EDWARDS
: Then that ' s just not going
6 to be what's happening today .

7 Q (BY MS. MENNINGER) All right . So you ' r e
8 r e fusing to answ e r a quest i on about whether you
9 recall a part i cu l ar press statement

10 MR. EDWARDS: She's --
11 Q (BY MS. MENNINGER) -- is t hat true?
12 MR. EDWARDS
: She is not refus i ng to
13 answer any quest i ons . She --

14 A I ' m not refusing to answer. I just want
15 t o see t he ar ti c l e you ' re t alking abou t so I can be
16 c l ear i n my statement .
17 Q (BY MS. MENNINGER) Do you recall seeing a
18 press artic l e wr itt en b y Sharon Churcher reporting
19 that you flew on a he li copter wit h and
20 Ghisla i ne Maxwel l as t he p il ot?

21 A No, I do not r eca ll r ead i ng a press
22 article say i ng that I was on a helicopter wi t h

23 as Ghislaine i s the pilot .
24 Q Do you recall telling Sharon Churcher that
25 you had conversations wi th regardi ng h i m
VIRGINIA GIUFFRE 5/3/201 6 218
1 fl y in g on a he li copter wit h Ghi s l a in e Maxwell ?
2 A I bel i eve that i t was taken out of
3 co n t ex t . Ghislai ne tol d me that she fl ew Bill
4 Cli nton in . And Ghis lai ne li kes to tal k a lot of
5 stuff t h at sounds fantastical . And whet her it ' s true
6 or not , that is what I do r eca ll t e lli ng Sharon
7 Churcher.
8 Q So you to l d Sharon Ch u rch e r that Ghi s l a i ne
9 Maxwel l is t he on e who t old you t ha t sh e fl e w

10 i n t he h e licopt er?
11 A I tol d Sharon Churcher that Ghi slaine flew
12 onto the isla nd, based upon what
13 Ghisla i ne had to l d me.

14 Q Not based upon what had told
15 you , correct?
16 A Correct.
17 Q Did y ou eve r ask Sharon Churcher to
18 correct anything that wa s printed under her name,
19 co ncern ing your stories to Sharon Churcher?

20 A I wasn ' t g i ven t h ose stor i es to rea d
21 be f ore th ey were print ed.
22 Q Aft e r they were print ed d i d you read them?
23 A I tried to stay away from th em. They were
24 very har d. You have to understand it was a very hard
25 time for me an d my husband to have to have this

1 public -- we didn't think it was going to be this
2 publicly announced and that big. So we turned off
3 the news and we stopped reading so many things.

4 Q You didn't read the articles about your
5 stories to Sharon Churcher
6 A I've read some articles
7 Q Let me just finish. You did not read the
8 articles published by Sharon Churcher about your
9 stories to Sharon Churcher?
10 A I have read some articles about what
11 Sharon Churcher wrote. And a lot of the stuff that
12 she writes she takes things from my own mouth and
13 changes them into her own words as journalists do.
14 And I never came back to her and told her
15 to correct anything. What was done was done. There
16 was nothing else I can do.
17 Q So even if she printed something that were
18 untrue you didn't ask her to correct it, correct?

19 A There was things that she printed that
20 really pissed me off, but there was nothing I could
21 do about it. It's already out there.

22 Q She printed things that were untrue,
23 correct?
24 MR. EDWARDS: Objection to the form.

1 A I wouldn't say that they were untrue. I
2 would just say that she printed them as journalists
3 take your words and turn them into something else.
4 Q (BY MS. MENNINGER) She got it wrong?
7 A In some ways, yes.

8 Q (BY MS. MENNINGER) Did she print things
9 in her articles that you did not say to her?
10 MR. EDWARDS: I object and ask that the
11 witness be given the opportunity to see the document
12 so that she can review it and answer that question
13 accurately. Otherwise she's unable to answer the
14 question. I'm not going to allow her to answer.
15 MS. MENNINGER: You know the civil rules
16 tell you not to suggest answers to your client.
17 Q (BY MS. MENNINGER) And you understand
18 your lawyer is now directing you to not all of a
19 sudden remember what your answer is. That's what
20 he's suggesting that you say. So you're not supposed
21 to listen to him suggest that to you. You're
22 supposed to tell me from your memory.

23 MR. EDWARDS: That is not what I'm --
24 Q (BY MS. MENNINGER) Did you --
25 MR. EDWARDS: That's not what I'm doing.

1 You don't get to just talk over me and
2 tell my client when not to listen to me. All you
3 have to do to get answers is show her the document
4 you're talking about, and I'll let her answer every
5 question. I don't know why we're so scared of the
6 actual documents.
7 MS. MENNINGER: I don't know why you're
8 scared of your client's recollection, Mr. Edwards.
9 But anyway
10 MR. EDWARDS: Why would you do this to
11 her?
12 Q (BY MS. MENNINGER) Did Sharon Churcher
13 print things that you did not say?
14 MR. EDWARDS: I'm going to instruct my
15 client not to answer unless you give her what it is
16 that you're talking about that was printed. And she
17 will tell you the answer, the accurate answer to your
18 question. Just without the document to refresh her
19 recollection and see it, she's not going to answer
20 the question.
22 print things that you did not say?
23 MR. EDWARDS: Same objection. Same
24 instruction not to answer.
25 I think I've made a very clear record as

1 to why I want my client to answer all of these
2 questions, but I want her to have the fair
3 opportunity to see this document.
5 print things that you felt were inaccurate?
7 instruction. If she sees the document, she's going
8 to answer every one of these questions.
9 Q (BY MS. MENNINGER) Did any other reporter
10 print statements that you believe are inaccurate?

12 instruction.
13 Q (BY MS. MENNINGER) Did any reporter print
14 statements about Ghislaine Maxwell that were
15 inaccurate?
17 instruction.
18 This is harassing. This is harassing a
19 sexual abuse victim. And all I'm asking is for
20 fairness, that we just let her see the document so
21 she can answer this.
22 MS. MENNINGER: Mr. Edwards, please stop
23 saying anything other than an objection, what the
24 basis is, or instructing your client not to answer.
25 MR. EDWARDS: I will do that.

1 MS. MENNINGER: That's what the Federal
2 Rules of Civil Procedure provide.
3 MR. EDWARDS: I hear you. They also
4 provide for fairness and civility. And all I'm
5 asking, very calmly, is for her to see this.
6 MS. MENNINGER: Mr. Edwards, this is not
7 your deposition. I'm asking your client what she
8 remembers. If she doesn't want to talk about what
9 she remembers, then let her not answer. But you
10 cannot instruct her not to answer unless there's a
11 privilege.
12 What privilege --
13 MR. EDWARDS: I am instructing her not to
14 answer.
15 Q (BY MS. MENNINGER) All right. You are
16 refusing to answer questions about whether statements
17 to the press about Ghislaine Maxwell attributed to
18 you were inaccurate?

19 MR. EDWARDS: She's not refusing not to
20 answer.
21 A You are refusing to show me these

22 documents so I could answer properly. I would give
23 you an answer if you were to show me some documents.
24 Q (BY MS. MENNINGER) You can't say without
25 looking at a document whether the press attributed to

1 you is accurate or inaccurate?
2 A Please show me the document.
3 Q You can't say from the top of your head
4 whether any inaccurate statement has been attributed
5 to you in the press?
6 A Please show me a document and I will tell
7 you.
8 Q Are you refusing to answer my questions
9 about your knowledge of whether inaccurate statements
10 have been attributed to you in the press?
11 A Are you refusing to give me the documents
12 to look at?
13 Q Are you refusing to answer the question?
14 A I am refusing to answer the question based
15 upon the fact that you are not being fair enough to
16 let me see the document in order to give you an
17 honest answer.
18 Q Ms. Giuffre
19 A Yes.
20 Q -- we are talking about press that has
21 been published on the Internet, correct?

22 A Yes.
23 Q Do you have access to the Internet?
24 A Yes.
25 Q Have you looked on the Internet and read

1 articl es that attr i bute stat emen ts to you about
2 Ghisla i ne Maxwell?
3 A Yes .
4 Q Do y ou kno w any statement that has been
5 attribute d to you i n a press article on the Internet
6 about Ghisl aine Maxwell that is unt ru e?

7 MR. EDWARDS
: Sarne object i on. Sarne
8 i nstruct i on.
9 A Pl ease show me a spec ifi c doc umen t .

10 Q (BY MS. MENNINGER) Do you know of any
11 such statement about Ghi slaine Maxwell attr i buted to
12 you by the press that is i nacc urate?
13 A If you cou l d please show me a specific
14 document.
15 Q Tell me wha t Sharon Churcher ask ed you to
16 writ e for he r .
17 A Any knowledge that I had about my tim e

18 wit h
19 Q And d i d you wr ite it?
20 A Um- hum.
21 Q What d i d you writ e it in or on?
22 A Pap e r .
23 Q What kind of paper?
24 A Lined paper .
25 Q Was it i n a book or s in g le sheets?

1 A Si ng l e sheets.
2 Q And did you write a l ong document or a
3 short document? What was it ?

4 A I can ' t recall how long the d oc umen t was ,
5 but I wou ld say it would be a few pages.

6 Q And other than asking you to write
7 whatever you remember about d id she
8 g i ve you any other d ir ect ions about what you shou l d
9 wr it e?
10 A She was inter es te d in two things , really .
11 How Epstein got away with so many counts of ch il d
12 trafficking for sex and how was
13 involved in it . Those were her two main i nqu iries .

14 Q What did she ask you to write?
15 A She asked me to wri t e abou t
16 Q Did she te ll you to put it in your own
17 handwr iti ng?

18 A No , she just asked me to wr ite down what I
19 can remember .
20 Q Di d you give her everything that you
21 wrote?
22 A Did I give her the whole entire pages t hat
23 I wrote?
24 Q Yes .
25 A Yeah , I wrote pages for her specifically .

1 Q In your own handwriting?
2 A In my own handwriting.
3 Q And what you wrote, was that true?
4 A Yes.
5 Q And did you get paid for those pieces of
6 paper?
7 A Not for the papers, I don't believe.
8 Q Okay. Have you gotten paid when they've
9 been reprinted?
10 A No.
11 Q Have you negotiated any deal with Radar
12 Online?
13 A No.
14 Q Have you negotiated any deal with Sharon
15 Churcher for the purpose of publishing those pieces
16 of paper?
17 A Not those pieces of paper.
18 Q When did you write those pieces of paper?
20 A A week before she came out.
21 Q (BY MS. MENNINGER) And when did you give
22 them to her?
23 A When she came out.
24 Q When was that?
25 A Sometime, I believe, in early 2011.

1 Q What d i d you get pa i d f o r , if not f or
2 those pieces of paper?
3 MR. EDWARDS: Object to the form .

4 A I was paid for the p i cture with
5 wi th h i s arm around me, Ghi sla i ne i n the
6 background. And I was paid for the , I guess, the
7 pr i nt of the stor i es.
8 Q (BY MS. MENNINGER) Anyt hi ng e l se?
9 A No.
10 Q You were not pa i d for those pieces of
11 paper?
12 A No.
13 Q All r i ght . And how many p i eces of paper
14 d i d you write?
15 A Like I said , I ' m round i ng i t around t hree.
16 Q Three p i eces of paper?
17 A That ' s what I -- I don ' t remember to be
18 exact on a number . I ' m sorry . But over three pages .
19 Q And you wrote those somet i me in 201 1 ?
20 A The week that she was com i ng out to see
21 me.
22 Q And you gave t hem t o her, right?
23 A I gave them to her .

24 Q Di d you keep a copy of that?
25 A No.
VIRGINIA GIUFFRE 5/3 /2 016 22 9

EXHIBIT J
From: jeffrey E. <jeevacation@gmail.com>

Sent: Wednesday, January 21, 2015 12:01 PM
To: Gmax
Since JE was charged in 2007 for solicitation of a prostitute I have been

the target of outright lies, innuendo, slander, defamation and salacious
gossip and harrasment; headlines made up of quotes I have never given,
statements I have never made, trips with people to places I have never
been, holidays with people I have never met, false allegations of
impropriety and offensive behavior that I abhor and have never ever been
party to, witness to events that I have never seen, living off trust funds that
I have never ever had, party to stories that have changed materially both in
time place and event depending on what paper you read, and the list goes
on.
I have never been a party in any criminal action pertaining to JE
For the record:
At the time of Jeffrey's plea I was in a very long-term committed

relationship with another man and no longer working with Jeffrey. Whilst
I remained on friendly terms with him up until his plea, , I have had
limited contact since
Every story in the press innuendo and comment has been taken from civil
depositions against JE, which were settled many years ago. None of the
depositions were ever subject to cross examination , not one. any
PRIVILEGED GM_001085
CONFIDENTIAL
standard of truth and were used for those who claimed they were victims
to receive financial payment to be shared between them and their lawyers,
One firm created and sold fake cases against Mr, Epstein - the firm
subsequently imploded and the Rothstein, the owner of the firm was sent
to jail for 50 years for his crime. The lawyer who is currently representing
Virgina was his partner. need I say morel
These so called 'new revelations' stem from an alleged diary from VR that
reads like the memoirs she is purporting to be selling. Also perhaps
pertinent - in a previous complaint against others, her claims were rejected
by the police
"due to .. VR ,Jack of credibility "
The new interest in this old settled case results from lawyers representing
some of JE victims filed a suit against the US government not JE , They
contend that the Us govt violated their rights,
The document and deal that JE negotiated with the government was given
to the lawyers 6 years ago and is a public document.
I am not part of, nor did you have anything to do with, JE plea bargain
I have never even seen the proceedings nor any of the depositions
2
CONFIDENTIAL
I reserve my right to file complaint and sue for defamation and slander
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to jeevacation@gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
3
PRIVILEGED GM 00'1087
CONFIDENTIAL
From: jeffrey E. <jeevacation@gmail.com>

Sent: Sunday, January 25, 2015 4:41 AM
To: G Maxwell
Subject: Re:
ok, with me, You have done nothing wrong and i woudl urge you to start acting like it. go outside, head high,
not as an esacping convict. go to parties. deal with it. . i had lisa svenson the swedish ocean
ambassador yesteady she said no one on her ocean panel takes this stuff seriously and you would be welcoe to
the ocean conferenec water conference etc.
On Sat, Jan 24, 20 I 5 at I :22 PM, G Maxwell <GMax l@ellmax.com> wrote:

I would appreciate it if shelley would come out and say she was your g'friend - I think she was from end 99 to
2002
THE TERRAMAR PROJECT

FACEBOOK
TWITTER
G+
PINTEREST
INST AGRAM
PLEDGE
THE DAILY CATCH
please note
The information contained in this communication is
confidential, may be attorney-client privileged, may
constitute inside information, and is intended only for
the use of the addressee. It is the property of
JEE
Unauthorized use, disclosure or copying of this
communication or any part thereof is strictly prohibited
and may be unlawful. If you have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to ieevacation@,gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
1
CONFIDENTIAL
EXHIBIT K
From: Meredith Schultz

To: Laura Menninger
Cc: Sigrid McCawley; Paul Cassell (cassellp@law.utah.edu); "brad@pathtojustice.com" (brad@pathtojustice.com);
Jeff Pagliuca
Subject: Notice of Subpoena
Date: Tuesday, May 17, 2016 5:10:02 AM
Attachments: 2016-05-16 Notice of Service & Subpoena for Deposition to
Laura,

Please see the attached.

Thanks,

Meredith

Meredith L. Schultz
401 East Las Olas Blvd., Suite 1200
Phone: 954-356-0011 ext. 4204
Fax: 954-356-0022
http://www.bsfllp.com

The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and
may contain information that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from
disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible
to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use of this
communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately
notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1]

--------------------------------------------------X
.............................................
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
MOTION TO REOPEN DEPOSITION OF PLAINTIFF VIRGINIA GIUFFRE
Laura A. Menninger
Jeffrey S. Pagliuca
East 10th Avenue
Denver, CO 80203
303.831.7364
TABLE OF CONTENTS
INTRODUCTION .......................................................................................................................... 1
ARGUMENT .................................................................................................................................. 1
I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER DEPOSITION

NECESSITATES ADDITIONAL EXAMINATION ............................................................. 3
A. Plaintiff failed to identify her health care providers and produce their records prior to
her deposition, despite this Court’s order .................................................................... 3
B. Plaintiff failed to produce emails form her iCloud and hotmail accounts ....................... 6
C. Plaintiff has failed to produce her employment records .................................................. 8
D. Plaintiff has failed to produce her education records ....................................................... 9
E. Plaintiff has filed amended Rule 26 disclosures identifying new witnesses .................... 9
II. PLAINTIFF’S COUNSEL INSTRUCTED PLAINTIFF NOT TO ANSWER

RELEVANT, NON-PRIVILEGED QUESTIONS IN HER FIRST DEPOSITION ......... 10
III. PLAINTIFF MADE MATERIAL CHANGES TO HER DEPOSITION THAT

COMPLETELY CONTRADICT HER SWORN TESTIMONY ...................................... 13
i
TABLE OF AUTHORITIES
Ganci v. U.S. Limousine, Ltd., No. 10-3027, 2011 WL 4407461, at *2 (E.D.N.Y. Sept. 21, 2011)
..................................................................................................................................................... 1
Harris v. Bornhorst, 513 F.3d 503, 525-26 (6th Cir. 2008) ......................................................... 10
Hlinko v. Virgin Alt. Airways, No. 96 Civ. 2873(KMW)(THK), 1997 WL 68563, at *1 (S.D.N.Y.
Feb. 19, 1997) ....................................................................................................................... 2, 12
Keck, 1997 WL 411931, at *2 (S.D.N.Y. July 22, 1997) ............................................................... 1
Miller v. Massad-Zion Motor Sales Co., No. 3:12 CV 1363, 2014 WL 4979349, at *2 (D. Conn.
Oct. 6, 2014) ............................................................................................................................... 2
Official Comm. of Unsecured Creditors of Exeter Holdings, Ltd. v. Haltman, No.

CV135475JSAKT, 2016 WL 1180194, at *3 (E.D.N.Y. Mar. 25, 2016) ............................ 1,2,3
Quantachrome Corp. v. Micromeritics Instrument Corp., 189 F.R.D. 697, 701 (S.D. Fla. 1999)10
Redwood v. Dobson, 476 F.3d 462, 467-68 (7th Cir. 2007) ........................................................... 9
Vincent v. Mortman, No. 04 Civ. 491, 2006 WL 726680, at *1–2 (D. Conn. Mar. 17, 2006) ....... 1
ii
Pursuant to Federal Rule of Civil Procedure 30(a)(2), Defendant Ghislaine Maxwell
seeks leave of the Court to reopen the deposition of Plaintiff Virginia Giuffre, and as grounds
therefore states as follows:
INTRODUCTION
Plaintiff has engaged in an active effort to hide relevant information and prevent the fair
examination of Plaintiff on her claims. Due to these multiple and repeated discovery violations,
key information and documents were unavailable to Ms. Maxwell prior to Plaintiff’s depositions
on May 3, 2016. Some obviously relevant documents and disclosures remain concealed and are
the subject of pending frivolous efforts by Plaintiff to evade her discovery obligations.
Recently, Plaintiff completely changed her Rule 26(a) initial disclosures and added
multiple new witnesses while deleting many others. In addition, in the initial deposition,
Plaintiff’s counsel improperly prevented Plaintiff from testifying regarding key relevant non-
privileged information without basis or justification.
Finally, Plaintiff has now provided an errata sheet to her sworn depositions testimony in
which she materially and substantially contradicts her own testimony. For these reasons,
Plaintiff’s depositions must be reopened to examine her on newly discovered evidence and her
contradictory statements.
ARGUMENT
“A person who has previously been deposed in a matter may be deposed again, but only
with leave of the court.” Official Comm. of Unsecured Creditors of Exeter Holdings, Ltd. v.
Haltman, No. CV135475JSAKT, 2016 WL 1180194, at *3 (E.D.N.Y. Mar. 25, 2016) (quoting
Sentry Ins. v. Brand Mgmt. Inc., No. 10 Civ. 347, 2012 WL 3288178, at *8 (E.D.N.Y. Aug. 10,
2012); Fed. R. Civ. P. 30(a)(2)(B). Under Rule 30(a)(2)(B), courts “frequently permit a
1
deposition to be reopened where the witness was inhibited from providing full information at the
first deposition” or “where new information comes to light triggering questions that the
discovering party would not have thought to ask at the first deposition.” Vincent v. Mortman,
No. 3:04 CV 491 (JBA), 2006 WL 726680, at *1 (D. Conn. Mar. 17, 2006) (quoting Keck v.
Union Bank of Switzerland, 1997 WL 411931, at *1 (S.D.N.Y. July 22, 1997). “Leave should be
granted to the extent that doing so is consistent with the factors set forth in Rule 26(b)(2), such as
'whether the second deposition of the witness would be unnecessarily cumulative, whether the
party requesting the deposition has had other opportunities to obtain the same information, and
whether the burden of a second deposition outweighs its potential benefit.’” Official Comm. of
Unsecured Creditors of Exeter Holdings, Ltd., 2016 WL 1180194, at *3 (quoting Sentry Ins.,
2012 WL 3288178, at *8).
“Courts will typically re-open a deposition where there is new information on which a
witness should be questioned.” Id. (quoting Ganci v. U.S. Limousine, Ltd., No. 10-3027, 2011
WL 4407461, at *2 (E.D.N.Y. Sept. 21, 2011)). This encompasses situations in which other
discovery has disclosed conflicting evidence on which a party should be questioned, when
discovery responses and relevant information are produced after the previous deposition, and
when affidavits produced conflict with the deponent’s previous testimony. See, e.g, Vincent v.
Mortman, No. 04 Civ. 491, 2006 WL 726680, at *1–2 (D. Conn. Mar. 17, 2006) (allowing
plaintiff to reopen deposition when one witness' deposition contradicted defendants' deposition
and medical records); Keck, 1997 WL 411931, at *2 (S.D.N.Y. July 22, 1997) (deposition
reopened where affidavit provided evidence conflicting with witness testimony); Sentry Ins.,
2012 WL 3288178, at *8 (permitting reopening of deposition based on production of document
deponent unjustifiably failed to produce prior to deposition).
2
Requests to reopen depositions routinely are granted after a deponent materially changes
her prior testimony in contradiction to previous sworn testimony. Miller v. Massad-Zion Motor
Sales Co., No. 3:12 CV 1363, 2014 WL 4979349, at *2 (D. Conn. Oct. 6, 2014); Hlinko v. Virgin
Alt. Airways, No. 96 Civ. 2873(KMW)(THK), 1997 WL 68563, at *1 (S.D.N.Y. Feb. 19, 1997).
“In addition, courts will also re-open a deposition ‘where the witness was inhibited from
providing full information at the first deposition.’” Official Comm. of Unsecured Creditors of
Exeter Holdings, Ltd., 2016 WL 1180194, at *3 (quoting Miller, 2014 WL 4979349, at *2 (D.
Conn. Oct. 6, 2014)). All of these factors are present in this case, necessitating the re-opening of
Plaintiff’s deposition.
I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER

DEPOSITION NECESSITATES ADDITIONAL EXAMINATION
A. Plaintiff failed to identify her health care providers and produce their
records prior to her deposition, despite this Court’s order
On April 21, 2016 this Court ordered Plaintiff to produce her medical records and
identify all of her health care providers from 1999 to present and produce their medical records.
Menninger Decl., Ex. A at 20-21. Undersigned counsel diligently followed up via phone and
correspondence and requested that all information relating to Plaintiff’s medical treatment be
provided prior to Plaintiff’s May 3, 2016 deposition precisely so that the deposition would not
need to be reopened. Menninger Decl., Ex. B. On April 29, 2016, after telling this Court that
she had disclosed all of her health care providers, Plaintiff served Second Amended
Supplemental Responses & Objections, identifying 15 new health care providers. Menninger
Decl., Ex. C at 18-20.1 For some providers, records were produced; for many, they were not. Id.
1
Treatment providers identified included 1) Dr. Steven Olson, 2) Dr. Chris Donahue, 3) Dr. John Harris 4) Dr.
Majaliyana 5) Dr. Wah, 6) Dr. Sellathuri, 7) Royal Oaks Medical Center, 8) Dr. Carol Hayek, 9) NY Presbyterian
Hospital, 10) Campbelltown Hospital, 11) Sydney West Hospital, 12) Westmead Hospital, 13) Dr. Karen Kutikoff,
14) Wellington Imaging Associates, and 15) Growing Together.
3
At Plaintiff s May 3, 2016 deposition , Plaintiff identified an additional health care
provider not identified in her Inten ogato 1y responses and for whom no records had been
produced. Specifically , Plaintiff identified a psychiatrist , Judith Lightfoot , who is located in
Australia. Menninger Deel. , Ex . D at 308-14 & 328-31. Plaintiff specific ally claims that she has
talked with Dr. Lightfoot regarding the impact of Ms. Maxwell's allegedly defamato1y
statement. Id. at 313-14. She claim s to have been talking to Dr. Lightfoot from October 2015 to
the present on a weekly basis. Id. at 334. Dr. Lightfoot also allegedly treated Plaintiff in 2011
(prior to the acts giving rise to this lawsuit), and apparently diagno sed Plaintiff ....
. Id. at 329. On June 12, 2016 (after Plaintiff s deposition),
Plaintiff produced a single record from Dr . Lightfoot , an intake fo1m from 2011. Menninger
Deel., Ex. E. The remaining document s from Dr. Lightfoot , including record s related to
treatment from 2015 to pre sent, have not been produced. Infonn ation relating to this treatment is
critical, and Ms. Maxwell has not been able to thoroughl y examine Plaintiff on her treatment by
Dr. Lightfoot because her identity was not disclosed prior to Plaintiff s deposition, and her
complete records still have not been produced.
At her deposition , Plaintiff also identified one of her cunent treatin g physicians as Dr.
Donahue ,
Menninger Deel. , Ex . D at 335-38.
. Id. Yet, to date, his records have
not been provided.
On May 25, 2016, Plaintiff sent Ms . Maxwell additional records obtained from Plaintiff s
treatment at Centura in June 2015. Those document s identify another medical provider , Dr.
Michele Streeter, never previously disclosed. Menninger Deel., Ex.F at 4 .
4
Lynn Mi ller, Plaintiffs m other, was deposed on May 24, 20 16. Durin g that depositio n,
Ms. Maxwell learned that Plaintiff was treated for
Mennin ger Deel. , Ex . G at 144. On Jun e 1, 20 16, Plaintiff produce d addit ional docume ntation
. These docum ents identi fy thr ee additional un disclosed health car e
profess ionals who treate d Plaintiff , includin g Dr. Scott Robert Geige r, Dr. Jose ph Heaney , and
Donna Oliver P .A. Mennin ger Deel., Ex . H .
One of the medical prov iders that was disclosed, an d for whom some docum ents had
been produced prior to Plaintiffs deposit ion was Dr. Steven Olson. Durin g Dr. Olson 's
deposition on May 26, 2016, Ms. Maxwell learned that he had recor ds in his laptop th at had not
been produced prior to hi s deposition. Aga in, these recor ds were prod uced after Plaintiff was
deposed.2 Mennin ger Deel., Ex . I at 36 .
In sho1t, at Plaintiffs first deposition, Ms. Maxwell learn ed of the identity of Plaintiffs
treating psyc hiatrist, bu t did not have the ability to fully question Plaintiff regarding her
treatm ent beca use of the late disclos ur e. Since then, at least four additional health care prov iders
have been identified . Post-depositio n medical recor ds for at least four different physician visits,
includ ing Plaintiffs trea tm ent
pre -dating the alleged defamatory statement have been produced. Plaintiff still has failed to
produce any recor ds from : (a) Dr. Donahu e, (b) Dr. Hayek, (c) Dr. Kutik off , (d) Wellington
Imaging Associates, (e) Grow ing Toget her, (f) post 2011 recor ds from Dr. Lightfoo t, and (g) the
remaining docum ents for treatment by Dr. Olson . All of the new info1m ation that has come to
2
At the deposition, copies were produced that were difficult to read. Despite requests , legible copies have not been
provided.
5
light, and the information that has yet to be produced, justifies the reopening of Plaintiff’s
deposition.
B. Plaintiff failed to produce emails form her iCloud and hotmail accounts
By interrogatory, Plaintiff was asked to identify “email address, email account, cellphone
number and cellphone provider, social media account and login or screen name, text or instant
messaging account name and number, that You have used, applied for or been supplied between
1998 and the present.” Menninger Decl., Ex. C at 8-9. Plaintiff responded, identifying a single
email address and three telephone numbers. Plaintiff’s counsel verified those discovery requests
pursuant to Rule 33(b)(5).
Through a detailed review of the documents produced by Plaintiff in discovery, Ms.
Maxwell uncovered Plaintiff has used at least three other email accounts – one on iCloud, one on
live.com, and one on hotmail.com during the relevant time periods. Plaintiff’s counsel confesses
that prior to being confronted on the issue, they never reviewed the emails in the accounts for
relevant information. Menninger Decl., Ex. J. The claims that counsel did not know these email
accounts exist is belied by the fact that they have now included “privileged” communications
from at least one of the accounts on their privilege log demonstrating and indicating there are
probably privileged communications in the account they have not reviewed. Thus, they both
knew about the accounts and corresponded with Plaintiff using those accounts, yet failed to
disclose the accounts or to review them for relevant information.
It was not until Ms. Maxwell subpoenaed records from Apple on June 8, 2016, that – two
days later – Plaintiff finally produced emails from the iCloud account. Menninger Decl., Ex. K.
Plaintiff still has failed to review or produce any documents from her live.com account or her
6
hotmail account.3 Plaintiff’s attorneys claim they cannot access these accounts, or that those
accounts have been closed. See Doc. #207. Through the service of a subpoena on Microsoft,
Ms. Maxwell’s counsel has learned this is untrue. The hotmail account remains “active” and
Microsoft has preserved the information in that account. Ms. Maxwell’s counsel provided the
release from Microsoft so that the emails can be accessed. Menninger Decl. Ex. L. Plaintiff has
refused to execute the release to permit the document production. The hotmail account is active,
can be accessed, and Plaintiff has simply failed to review these accounts for relevant information
or permit discovery of relevant evidence.
The limited information produced from the iCloud account shows that responsive
information exists. The production includes Plaintiff’s communications with FBI agent Jason
Richards in 2014 and suggests that Plaintiff was in regular communication with him at various
times, particularly in mid-2014. Despite this, few pieces of correspondence with Agent Richards
have been produced. Plaintiff also produced an email to Christina Pyror of the FBI but not any
response to that email.
-
The iCloud account also discloses a previously undisclosed potential witness, Sharon
Rikard, a person working at a not-for-profit relating to sexual trafficking victims. Apparently, in

-
March 2015 (well after the alleged defamatory statement), Plaintiff for the first time was doing
something to attempt to make Victims Refuse Silence look like a real organization. This timing
is important because it demonstrates Plaintiff was not in the purported profession of helping
victims prior to the alleged defamatory statements (January 2015), and therefore cannot claim
that the alleged defamatory statement related to her profession at the time the statement occurred.
3
Ms. Maxwell has issued subpoena for records from all of these accounts. Plaintiff had filed a motion for protective
order, and thus is still trying to prevent access to relevant discovery.
7
It is completely unknown what other relevant and probative information will be
uncovered in Plaintiff’s previously hidden accounts, including her hotmail account. What is
clear is that Ms. Maxwell has had no opportunity to depose Plaintiff about these issues,
necessitating the reopening of her deposition.
C. Plaintiff has failed to produce her employment records
In the April 21, 2016, hearing, the Court also ordered that Plaintiff produce records
relating to her employment history, including identifying her employer, dates of employment,
nature of employment and earnings. Menninger Decl., Ex. A at 25. These documents are
directly related to Plaintiff’s damages claims for lost earnings and loss of earning potential – i.e.
Plaintiff’s own actual historic earnings necessarily informs the basis for any claimed loss of
earnings. Based on the resumes provided by Plaintiff in discovery, Ms. Maxwell also requested
personnel record releases for all employers listed on Plaintiff’s resume, which were provided on
April 29, 2016. Prior to Plaintiff’s deposition, no employment records had been produced.
At Plaintiff’s deposition, Plaintiff admitted that much of her resume was fabricated and
replete with lies. Menninger Decl., Ex. D at 67-90. At least 3 of the employers included on the
resume were jobs she never held – she researched the internet to find places where she might
have worked, listed them as actual jobs, and then fictionalized her job description. With respect
to other employers, she expanded the end date of employment to fabricate a continual work
history. Plaintiff ultimately admitted that she has not held a single paid employment position
-
since 2006.
After Plaintiff’s deposition, Plaintiff provided additional documentation concerning her
employment history. Through employment records releases (requested well before Plaintiff’s
deposition), Ms. Maxwell obtained employment records from Employment and Training
Australia, one of Plaintiff’s non-fabricated employers. Those records include pay history,
8
showing that Plaintiff’s wage rate was under $28,000 per year.4 Until now, Ms. Maxwell has not
had the information necessary to examine Plaintiff on this lost income aspect of her damages
claims.
D. Plaintiff has failed to produce her education records
In the April 21, 2016, hearing, the Court also ordered Plaintiff to turn over her education
records. Again, this information, or forms to permit the release of the information, were
provided well in advance of the Plaintiff’s scheduled deposition, specifically February 12, to
permit full examination on these issues. Again, Plaintiff did not provide the releases until mere
days before her deposition, and only after this Court’s order. Since Plaintiff’s deposition,
various education documents have been obtained through those releases, specifically documents
from Plaintiff’s various high schools, including Wellington High School, Royal Palm High, and
Survivor’s Charter School. The records contain substantial information conflicting with
Plaintiff’s previous testimony. Ms. Maxwell is entitled to examine Plaintiff on this previously
undisclosed evidence.
E. Plaintiff has filed amended Rule 26 disclosures identifying new witnesses
Finally, on June 1, 2016, weeks after her deposition and in the final month of the fact
discovery period, Plaintiff filed her “Third Revised” Rule 26 disclosures. She has expanded her
■
list of witnesses with relevant information from 69 specific witnesses to 87. She curiously
removed witnesses previously disclosed. With regard to all of these witnesses, she fails to
identify who they are and what information they allegedly have that is relevant to the case. The
stock description for each person is “Has knowledge of Ghislaine Maxwell and Jeffery Epstein’s
sexual trafficking conduct and interaction with underage minors.” Menninger Decl, Ex. N at 14.
4
Plaintiff’s Rule 26(a) disclosure claims lost income as “estimated lost income of $180,000 annually, Present value
of $3,461,000 to $5,407,000. This is based solely on the “average” earning of a woman Plaintiff’s age. Obviously,
any actual lost earnings must be based on Plaintiff’s own earning history and work records, which is vastly different.
9
These disclosures provide no actual information, such as the type of alleged knowledge, basis of
the knowledge or how the information is in any way relevant to this single count defamation
case. She also has amended her document disclosures list but has failed to produce any of the
new documents she has identified, despite repeated requests for these documents. Id. at 16.
These late disclosures are clearly improper and should be stricken under Rule 37(c), a
matter for a different motion. Nevertheless, these material changes include witnesses that were
obviously known to Plaintiff since the inception of the case. Ms. Maxwell is entitled to question
Plaintiff on these disclosures to determine what, if any, relevant information these newly
disclosed witnesses might have.
In total, Plaintiff has produced over 256 additional documents since her deposition, and
other documents have been obtained through previously withheld releases. As will be briefed
separately, there are multiple additional documents that have still not been produced. Of the
information uncovered, much of it directly contradicts Plaintiff’s previous sworn discovery
responses and her sworn deposition testimony. This is precisely the type of situation that
requires reopening Plaintiff’s deposition.

RELEVANT, NON-PRIVILEGED QUESTIONS IN HER FIRST DEPOSITION
Plaintiff was instructed by her attorney not to answer certain questions during her
deposition without basis. The questions did not seek privileged information, were completely
appropriate, and directly relevant to issues in case.
It is axiomatic that counsel at a deposition “may instruct a deponent not to answer only
when necessary to preserve a privilege, to enforce a limitation ordered by the court, or to present
a motion under Rule 30(d)(3).” Fed. R. Civ. P. 30(c)(2); Redwood v. Dobson, 476 F.3d 462,
467-68 (7th Cir. 2007) (“Counsel for the witness may halt the deposition and apply for a
10
protective order, see [Rule 30(d)(3)], but must not instruct the witness to remain silent.”);
Quantachrome Corp. v. Micromeritics Instrument Corp., 189 F.R.D. 697, 701 (S.D. Fla. 1999)
(counsel “may instruct the witness not to answer or may halt the deposition. Fed.R.Civ.P.
30(d)(3). Counsel may do so, though, only if he intends to move for a protective order under
Rule 30(d)(3)”); Harris v. Bornhorst, 513 F.3d 503, 525-26 (6th Cir. 2008) (“despite the lack of
relevancy of the questions to the claims asserted, absent a privilege or protective order, a
deponent must answer questions posed at a discovery deposition”). Where counsel improperly
instructs a witness not to answer, courts routinely require the deposition to be reopened. Keck,
1997 WL 411931, at *1.
At Plaintiff’s first deposition, Plaintiff was instructed not to answer three different areas
of inquiry where there was simply no basis for claiming any privilege or right to protection.
Plaintiff has never moved for a protective order on these lines of inquiry because there is no
basis for prohibiting the discovery.
First, Plaintiff was asked to identify any statements printed or published by Sharon
Churcher, the Daily Mail reporter who spent several days meeting with Plaintiff and published
numerous stories regarding Plaintiff in 2011 and thereafter. Plaintiff testified that despite her
very close relationship with Ms. Churcher, she no longer trusts Ms. Churcher and that Churcher
did not accurately report portions of what Plaintiff told her. Menninger Decl., Ex. D at 216-26.
When Plaintiff was asked to describe the statements Ms. Churcher reported that were inaccurate,
Plaintiff’s counsel refused to allow testimony unless Plaintiff was given all of Ms. Churcher’s
articles and had a chance to review them. Menninger Decl., Ex. D at 215-26. He refused to let
Plaintiff testify based on her own independent recollection. Id. This is simply improper, and
alone serves as a valid basis for reopening the deposition.
11
The second area of inquiry on which Plaintiff was prohibited from testifying was her
■
communications with law enforcement since 2014, in particular regarding Ms. Maxwell.
Menninger Decl. Ex. D at 244-45. Counsel refused to let Plaintiff answer these questions despite
this Court’s order that Plaintiff was to turn over all documents concerning communications with
law enforcement, excepting only Plaintiff’s own statements to law enforcement which would be
provided for in camera review. Menninger Decl., Ex. A at 24. Rather than complying with this
very clear order, Plaintiff’s counsel refused to provide any documents regarding communications
with law enforcement agencies (including their own), and submitted all documents for in camera
review. Ms. Maxwell is entitled to all documents concerning contacts with law enforcement
(both her attorney’s communications, which have been ordered to be produced, and her own
statements, which the Court should order be produced), and to question Plaintiff regarding the
1111
same.
The third question Plaintiff was prohibited from answering concerned her consultations
with an undisclosed psychiatrist sometime after 2015. Plaintiff’s counsel indicated this is a
consulting expert. Even if that is the case, Ms. Maxwell is entitled to the identity of this health
care provider. Manzo v. Stanley Black & Decker Inc., No. CV 13-3963 JFB SIL, 2015 WL
136011, at *2 (E.D.N.Y. Jan. 9, 2015) (identity of non-testifying experts discoverable); Baki v.
B.F. Diamond Constr. Co., 71 F.R.D. 179, 181–82 (D. Md. 1976) (same); Eisai Co. v. Teva
Pharm. USA, Inc., 247 F.R.D. 440, 441–42 (D.N.J. 2007) (same).
In light of the clearly improper instructions not to answer non-privileged relevant
questions, Plaintiff’s deposition must be reopened.
12
III. PLAINTIFF MADE MATERIAL CHANGES TO HER DEPOSITION THAT

COMPLETELY CONTRADICT HER SWORN TESTIMONY
The final and perhaps most compelling reason to reopen Plaintiff’s deposition is the fact
that Plaintiff filed an errata sheet for her deposition in which she materially contradicts her prior
sworn testimony. Menninger Decl., Ex. M. A court may reopen a deposition if the changes to
the transcript are made without adequate reasons, or if they are so substantial as to render the
transcript incomplete or useless. See Hlinko, 1997 WL 68563, at*1 (citing Allen & Co. v.
Occidental Petroleum Corp., 49 F.R.D. 337, 341 (S.D.N.Y.1970)); see also Miller, 2014 WL
4979349, at *2.
Plaintiff’s errata changes are astounding, literally reflecting complete contradictions of
her actual sworn testimony by changing “yes” answers to “no,” and indicating “clarification of
answer” as the basis for total revision. A vast majority of the 20 changes regard a very specific
date testified to by Plaintiff in her deposition that has a profound impact in this matter, as her
attorneys are fully aware. Specifically, Plaintiff was confronted with the fact that on no less than
10 occasions she has sworn under oath she met Ms. Maxwell in 1999, when she was 15 years
old. This is a lie. Plaintiff pinpoints this date based on the fact that she was working at the Mar-
A-Lago spa. Discovery has uncovered that Plaintiff did not work for the Mar-A-Lago until
2000, and Plaintiff’s self-prepared resume states that it was not until August of 2000 when she
was 17 years old. Plaintiff had been well coached on how to answer to the prior perjured
testimony, being prompted to claim that her sworn statements were a “mistake,” and that she
only learned her dates of employment at the Mar-A-Lago through discovery. Menninger Decl.,
Ex. D at 26. The question was then posed about when she “learned” of her mistake based on
discovery, to which Plaintiff clearly and unequivocally responded on no less than six occasions
that she learned her dates of employment at Mar-A-Lago in mid-2015 – before many of her
13
sworn statements. After a break in the deposition and being coached by her counsel, Plaintiff
pulled back on her conviction regarding the date, and became less certain of the time frame, but
still put the time frame in late 2015. Id. at 66. After her deposition, she completely changed the
date she “learned” she was employed at Mar-A-Lago in 2000 to a firm date of mid-February
2016, over six months later than the date to which she originally testified based on her own
independent recollection. Menninger Decl., Ex. M.
This is not the only substantive and completely contradictory change in the testimony.
Plaintiff revised her very clear and distinct answer that she traveled to France three times to
claims that she travelled to France “a few” times, and modified the credentials of her mental
health care provider – the previously undisclosed Dr. Judith Lightfoot – from psychiatrist to
psychologist.
The impact of the original (presumably true) testimony is a matter for another motion, as
is the effect of the true reasons the changes were made. For purposes of this motion, what is
important is that substantive contradictory changes by errata require that, at a minimum, Plaintiff
be examined on the revisions.
WHEREFORE, for the foregoing reasons, Ms. Maxwell requests that the Court permit
Plaintiff’s deposition to be reopened for up to seven additional hours of examination, and order
that Plaintiff pay the costs and fees associated with deposition pursuant to Fed. R. Civ. P.
30(d)(2).
14
Dated: June 20, 2016

Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
15
I certify that on June 20, 2016, I electronically served this DEFENDANT’S MOTION TO
REOPEN DEPOSITION OF PLAINTIFF VIRGINIA GIUFFRE via ECF on the following:

mschultz@bsfllp.com
/s/ Nicole Simmons
Nicole Simmons
16
--------------------------------------------------X
VIRGINlA L. GIUFFRE,
Plaintiff,
v. 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
-------• --••• --------------. ----------------•-----X
Declaration Of Laura A. Menninger In Support Of Defendant's Motion

to Reopen Deposition of Plaintiff Virginia Giuffre
member of the Jaw finn Haddon, Morgan & Foreman, P.C., counsel ofrecord for Defendant
Ghislaine Maxwell ("Maxwell") in this action. I resp ectfully submit this declaration in support of
Defendant's Motion to Reopen Deposition of Plaintiff Virginia Giuffre.
2. Attached as Exhibit A is a true and correct copy of the transcrip t of the hearing
held before this Court on April 21, 20 l 6.
3. Attached as Exhibit B is a true and correct copy of a letter from Laura A.
Menninger to Sigrid Mccawley dated April 25, 2016 concerning discovery.
4. Attached as Exhibit C is a true and correct copy of Plaintiffs Second Amended
Supplemental Response and Objections to Defendant's First Set of Discovery Requests to
Plaintiff, served April 29, 2016.

5. Attached as Exhibit D (filed under seal) is a true and correct copy the Deposition
of Virginia Giuffre taken in the above captioned matter on May 3, 2016, and designated by
Plaintiff as Confidential under the Protective Order.
6. Attached as Exhibit E (filed under seal) is a true and correct copy of medical
records bates labeled GIUFFRE00543l -5438, produced by Plaintiff on May 12,2016.
7. Attached as Exhibit F (filed under seal) is a true and correct copy of medical
records bates labeled GI UFFRE005492-5496, produced by Plaintiff on May 25, 2016.
8. Attached as Exhibit G (fikd under seal) is a true and correct copy of excerpts
from the Deposition o- taken in the above captioned matter on May 24, 2016.
and designated by Plaintiff as Confidential under the Protective Order.
9. Attached as Exhibit H (filed under seal) is a true and correct copy of medical
records bates labeled GIUFFRE005498-005569. produced by Plaintiff on June 1, 2016.
10. Attached as Exhibit I (filed unde r seal) is a true and correct copy of excerpt5 from
the Deposition of Dr. Steven Olsen taken in the above captioned matter on May 26, 20 I 6, and
designated by Plaintiff as Confidential under the Protective Order.
11. Attach ed as Exhibit K (filed under seal) is a true and correct copy of a letter from
Sigrid Mccawley to Laura A. Menninger enclosing documents bates labeled GlUFFRE005607-
5613, produced by Plaintiff on June IO, 2016.
12. Attached as Exhibit L is a true and correct copy of a letter from Laura A.
Menninger to Sigrid Mccawley and Meredith Shultz dated June 13, 2016 concerning discovery.
13. Attached as Exh ibit M (filed under seal) is a true and correct copy of the Errata
Sheet served relating to the Deposition of Virginia Giuffre taken in the above captioned matter,
served on June 1.2016.
2
14. Attached as Exhibit N (filed under seal) is a true and correct copy of Plaintiff,
Virginia Giuffre's Third Revised Disclosure Pursuant to Fed. R . Civ. P. 26, served June 1, 2016.
By: Isl Laura A. Menninger

Laura A. Menninger
CERTIFICATEOF SERVICE
I certify that on June 20, 2016, Telectronically served this Declaration Of Laura A.
Menninger In Support Of Defendant's Motion to Reopen Deposition of Plaintiff Virginia Giuffre
via ECF on the following:

Meridith Schultz 383 S. Un ive rs ity Street
BOTES, SCHILLER& F LEXNER, LLP Salt Lake City, UT 84112
40 l East Las Olas Boulevard, Ste. 1200 cas sellp@law.utah.edu
smccaw ley@bsfllp .com
mschultz @bsfllp.com
FARMER,JAFFE, WEISSING, EDWARDS, South Salem, NY 10590
FTSTOS & LEHRMAN, P.L. StanPottinger@aol.com
Ft. Lauderdale, FL 3330 I
brad@pathtojustice .com
Isl Nicole Simmons
Nicole Simmons
3
EXHIBIT A
EXHIBIT D
GIUFFRE
VS.
MAXWELL
Deposition
VIRGINIA GIUFFRE
05/03/2016
_______________________________________________________________________

216 16th Street, Suite 600
Denver Colorado, 80202
303-296-0017
Agren Blando
Case 1:15-cv-07433-LAP Court Reporting
Document & Video,
1090-32 Filed Inc. Page 3 of 89
07/30/20
l
I
Page 1 I
Page 3
IN THE UNITED STATES DISTRICT COURT 1 Pursuant to Notice and the Federal Rules
SOUTHERN DISTRICT OF NEW YORK 2 of Civil Procedure, the VIDEOTAPED DEPOSITION OF
Civil Action No. 15-cv-07433-RWS 3 VIRGINIA GIUFFRE, called by Defendant, was taken on
__________________________________________________
4 Tuesday, May 3, 2016, commencing at 9:00 a.m., at 150
VIRGINIA GIUFFRE May 3, 2016 5 East 10th Avenue, Denver, Colorado, before Kelly A.
__________________________________________________
6 Mackereth, Certified Shorthand Reporter, Registered
7 Professional Reporter, Certified Realtime Reporter
Plaintiff,
8 and Notary Public within Colorado.
v.
9
GHISLAINE MAXWELL, *******
10 INDEX
Defendant.
__________________________________________________ 11
EXAMINATION PAGE
APPEARANCES: 12
MS. MENNINGER 8
FAMER, JAFFE, WEISSING, EDWARDS, FISTOS & 13
LEHRMAN, P.L.
By Brad Edwards, Esq. 14 PRODUCTION REQUEST(S):
Suite 2 15 (None.)
Phone: 954.524.2820 16
Appearing on behalf of the 17
Plaintiff
18
BOIES, SCHILLER & FLEXNER LLP 19
By Sigrid S. McCawley, Esq. (For Portion)
401 East Las Olas Boulevard 20
Suite 1200
Fort Lauderdale, FL 33301-2211 21
Phone: 954.356.0011
smccawley@bsfllp.com 22
Plaintiff 23
24
25
Page 2 Page 4
1 APPEARANCES: (Continued) 1 INDEX OF EXHIBITS
2 HADDON, MORGAN AND FORMAN, P.C. 2
By Laura A. Menninger, Esq. INITIAL
3 Jeffrey S. Pagliuca, Esq. 3 DESCRIPTION REFERENCE
4 Denver, CO 80203 4
Phone: 303.831.7364 Exhibit 1 Complaint and Demand for Jury 17
5 lmenninger@hmflaw.com 5 Trial re Jane Doe No. 102 v.
jpagliuca@hmflaw.com Jeffrey Epstein
6 Appearing on behalf of the 6
Defendant Exhibit 2 Jane Doe #3 and Jane Doe #4's 21
7 7 Motion Pursuant to Rule 21 for
Also Present: Joinder in Action
8 Brenda Rodriguez, Paralegal 8
Nicholas F. Borgia, CLVS Videographer Exhibit 3 Declaration of Virginia L. 23
9 9 Giuffre re Jane Doe #1 and Jane
Doe #2 vs. United States of
10 10 America
11 11 Exhibit 4 Declaration of Jane Doe 3 re 31
Jane Doe #1 and Jane Doe #2 vs.
12 12 United States of America
- -
13 13 Exhibit 5 Declaration of Virginia Giuffre 33
re Bradley J. Edwar
14 14 ssell vs.
15 15
Exhibit 6 FBI documentation, date of entry 36
16 16 7/5/13
17 17 Exhibit 7 Document titled Telecon, 39
Participants Jack Scarola, Brad
18 18 Edwards, Virginia Roberts. Re
Edwards adv. Epstein, 4/7/11,
19 19 (23 pages of transcription)
20 20 Exhibit 8 The Billionaire's Playboy Club, 41
By Virginia Roberts
21 21
Exhibit 9 Plaintiff's Response and 44
22 22 Objections to Defendant's First
Set of Discovery Requests to
23 23 Plaintiff re Giuffre v. Maxwell
24 24
25 25
I
VIRGINIA GIUFFRE 5/3/2016 1 (1 - 4)
Agren Blando
Document & Video,
07/30/20
Page 5 Page 7
1 1 *******
INITIAL
2 DESCRIPTION REFERENCE 2 PROCEEDINGS
3 3 THE VIDEOGRAPHER: We're on the record at
Exhibit 10 Plaintiff's Supplemental 46
4 Response and Objections to 4 9 a.m. Today is May 3rd, 2016. This begins the
Defendant's First Set of
5 Discovery Requests to Plaintiff 5 videotaped deposition of Virginia Giuffre in the
6 Exhibit 11 Undated Declaration of Virginia 46 6 matter of Virginia L. Giuffre versus Ghislaine
Giuffre re Plaintiff's
7 Supplemental Response and 7 Maxwell.
Objections to Defendant's First
8 Set of Discovery Requests served 8 We're located at 150 East 10th Street --
on March 22, 2016
9 9 excuse me, 10th Ave., in Denver, Colorado.
Exhibit 12 Plaintiff's Second Amended 47
10 Supplemental Response and 10 Our court reporter is Kelly Mackereth.
Objections to Defendant's First
11 Set of Discovery Requests to 11 The videographer is Nicholas F. Borgia, CLVS.
Plaintiff
12 12 Will counsel please introduce yourselves
Exhibit 13 Mrs. Virginia Giuffre resume 67
13 13 for the record.
Exhibit 14 Compilation of e-mails re Open 68
14 Position - Virginia Giuffre 14 MR. EDWARDS: Sure. Brad Edwards and
15 Exhibit 15 Virginia Lee Roberts passport 180 15 Sigrid McCawley on behalf of the plaintiff,
application
16 16 Ms. Giuffre.
Exhibit 16 Composite of e-mail strings 251
17 17 MS. MENNINGER: Laura Menninger and
Exhibit 17 Compilation of e-mails between 259
18 Giuffre and Silva and others 18 Jeffrey Pagliuca on behalf of the defendant,
19 Exhibit 18 Compilation of e-mails between 265 19 Ghislaine Maxwell.
Virginia Giuffre and Sandra
20 White 20 THE VIDEOGRAPHER: And will our court
21 Exhibit 19 Compilation of e-mails between 269 21 reporter please swear in the deponent.
Marianne Strong and Virginia
22 Giuffre 22 VIRGINIA GIUFFRE,
23 Exhibit 20 Compilation of e-mails between 276 23 being first duly sworn in the above cause, was
Virginia Roberts and Jason
24 Richards 24 examined and testified as follows:
25 25 MR. EDWARDS: Just before we get started,
Page 6 Page 8
1 1 I just wanted to make sure that we're clear, and I
INITIAL
2 DESCRIPTION REFERENCE 2 think that we are, that this deposition in total will
3 3 be treated as confidential until such time as we are
Exhibit 21 Compilation of e-mails between 284
4 Sharon Churcher and Virginia 4 able to review and de-designate.
Giuffre
5 5 MS. MENNINGER: Yes.
Exhibit 22 Compilation of e-mails among 287
6 Sharon Churcher, Michael Thomas, 6 MR. EDWARDS: Okay.
Virginia Giuffre and others
7 7 EXAMINATION
Exhibit 23 Compilation of May 2011 e-mails 288
8 among Sharon Churcher, Virginia 8 BY MS. MENNINGER:
Giuffre, Paulo Silva and others
9 9 Q Good morning, Ms. Giuffre.
Exhibit 24 Compilation of June 2011 e-mails 289
10 between Virginia Giuffre and 10 A Good morning, Laura.
Sharon Churcher
11 11 Q Can you please state your full name?
Exhibit 26 PR Hub Statement on Behalf of 300
12 Ghislaine Maxwell article 12 A Virginia Lee Giuffre.
13 Exhibit 27 1/2/15 e-mail from to 309 13 Q And where do you live right now,
To Whom It May Conce
14 14 Ms. Giuffre?
15
16
17
18
19
15
16
17
18
19
- A
Q
A
All right. And who lives with you there?
My son, my other son, my daughter, my
husband and my in-laws.
20 20 Q And when did you return to the U.S. for
21 21 this visit?
22 22 A I believe it was around Thursday, the
23 23 29th, I think.
24 24 Q Okay. And who traveled with you?
25 25 A Myself.

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Page 9 Page 11
1 Q Yourself? 1 under oath?
2 A Yes. 2 A Yes.
3 Q Are you able to travel freely between the 3 Q What does it mean to you?
4 U.S. and Australia? 4 A To tell the truth, the whole truth and
5 A Yes. 5 nothing but the truth.
6 Q Are you married? 6 Q All right. And what does the word truth
7 A Yes. 7 mean to you?
8
9
10
11
12
Q
A
Q
-
To whom?
All right. And did Mr. Giuffre travel

with you back to the U.S.?
A No.
8
9
10
11
12
A
Q
A
Q
To be honest.
Is there more than one truth?
Is there more than -- no, there's no more
than one truth.
If you are confused by a question, you
13 Q All right. Have you taken any medications 13 need to let me know that so I can clarify the
14 in the last 24 hours? 14 question, okay?
15 A I have taken -- I have a cold, but I have 15 A Okay.
16 taken non-drowsy cold tablets and some DayQuil. 16 Q For example, if I asked you the question
17 Q All right. Anything else? 17 were you sexually trafficked to foreign presidents,
18 A No. 18 do you understand what that question means?
19 Q All right. And what is your current 19 A Yes.
20 profession, Ms. Giuffre? 20 Q What does it mean?
21 A I'm a housewife. 21 A Was I lent out for the purposes of sex to
22 Q All right. And how long have you been a 22 a foreign person -- president.
23 housewife? 23 Q All right. And what is the answer to that
24 A For the last ten years, since I've had 24 question?
25 kids. 25 A Yes.
Page 10 Page 12
1 Q All right. And what was your profession 1 Q And if I ask you have you met any foreign
2 in 2014? 2 presidents, do you understand what that question
3 A A housewife. 3 means?
4 Q All right. Any other profession? 4 A Yes.
5 A No. 5 Q And what is the answer to that question?
6 Q All right. You understand that you're 6 A Yes.
7 under oath today? 7 Q All right. And if I asked you which
8 A Yes. 8 foreign presidents have you met, do you understand
9 Q And you understand that if you don't 9 what that question means?
10 understand a question, you need to let me know that. 10 A Yes.
11 A Okay. 11 Q What is the answer to that question?
12 Q And ask for clarification. 12 A What is the name of the person?
13 A Um-hum. 13 Q Yes. Who are the foreign presidents that
14 Q Do you understand? 14 you have met?
15 A Yes. 15 A I honestly can't remember his name at this
16 Q You also understand, I'm assuming, that 16 time. I'm a very visual person so --
17 you have to say yes or no in answer to a question, or 17 Q All right. Can you describe him, then?
18 you have to make a verbal response and not just shake 18 A Yes. He's Spanish.
19 your head or something -- 19 Q Okay.
20 A Yes. 20 A Tall, dark hair.
21 Q -- so the court reporter can get it. 21 Q All right. Anything else?
22 You have -- you have been deposed before, 22 A And he's got a foreign tongue, accent.
23 correct? 23 Q And what age, approximately?
24 A Yes. 24 A Was I or was he?
25 Q Do you understand what it means to be 25 Q Was he.

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1 A I'd say in his 40s. 1 A Yes.
2 Q Okay. And where did you meet him? 2 Q And which ones did you review?
3 A I believe it was New Mexico. 3 A I'd have to see which ones you're
4 Q New Mexico? 4 specifically talking about. There's quite a lot of
5 A Possibly New Mexico. I'm sorry. It's 5 statements I've made.
6 really hard to go back and remember lots of different 6 Q Right. And which ones do you recall
7 events with lots of different people. 7 having reviewed before you attended this deposition
8 Q Okay. And is that the only foreign 8 today?
9 president that you have met? 9 A I've reviewed my affidavit. I'm not a
10 A I've met a lot of very high, powerful 10 lawyer so I really don't know legal terms to half of
11 people and I wasn't just introduced to them as who 11 the, you know, legal jargon of statements, which they
12 they were. It's only going back through photos in 12 are. If you showed me, I'd be able to tell you if
13 time to be able to realize who they are and what they 13 I've seen it or not.
14 are now. So it's hard for me to distinguish who I've 14 Q Okay. So to your knowledge, can you
15 actually met and when and where I've met them. 15 identify any sworn statement you reviewed before
16 Q So to your knowledge, you have only met 16 attending the deposition today?
17 one foreign president? 17 A Could I name what the statement is?
18 A To my knowledge at this time, yes. 18 Q Right.
19 Q And is there anything that might change 19 A The actual piece of paper that has the
20 your knowledge at a different time? 20 title at the top?
21 A If I were to see more photos of other 21 Q Right.
22 people. I mean, I've been able to distinguish the 22 A No, I don't.
23 majority of the people I've been lent out to, but 23 Q Can you describe it in any other fashion?
24 who's to say there's not more. 24 A I don't understand. I'm sorry.
25 Q All right. If I were to ask you the 25 Q That's all right. You have to tell me if
1
2
3
4
question how many times have you had sex with
A
Q
do you know what that question means?
I believe so.
All right. And what is the answer to that
-
Page 14
1
2
3
4
you don't.
Do you have any reason to believe that any
of your previous sworn statements that you have made
are not true?
Page 16
5
6
7
8
9
question?
A
Q
I believe I was with
- once.
Okay. I would like to ask you about your
prior sworn statement.
You understand you're under oath today,
5
6
7
8
9
A No.
MR. EDWARDS: I just object and ask that
if we're going to ask the witness questions about any
of her statements in whole or in part that the
witness be allowed to see the statement, review the
10 correct? 10 statement and then answer your questions.
11 A Yes. 11 Q (BY MS. MENNINGER) You may answer the
12 Q All right. You've previously made 12 question.
13 statements under oath, correct? 13 A Can you reask the question? I'm sorry.
14 A Yes. 14 Q Do you have any reason to believe that any
15 Q And you've previously authorized pleadings 15 of your prior sworn statements are untrue?
16 to be filed on your behalf, correct? 16 A I have no reason to believe that my prior
17 A Yes. 17 statements are untrue.
18 Q By various attorneys, right? 18 Q Has anyone told you to say something that
19 A Yes. 19 was not true in connection with this case?
20 Q All right. You have included in your 20 A No, ma'am.
21 sworn statement allegations about my client, 21 Q All right. I'd like to start with a
22 Ghislaine Maxwell, correct? 22 lawsuit that you filed under the caption Jane Doe
23 A Yes. 23 versus Jeffrey Epstein.
24 Q And did you review any of those prior 24 Do you recall that lawsuit?
25 sworn statements before appearing here today? 25 A I believe so.

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Page 17 Page 19
1 (Exhibit 1 marked.) 1 Q No. I'm just -- did you find it?
2 Q (BY MS. MENNINGER) I'm going to show you 2 A I can see paragraph 23.
3 an exhibit that we are marking as Defendant's 3 Q Okay. And do you see that there are
4 Exhibit 1. 4 allegations about a Ms. Maxwell contained in that
5 MR. EDWARDS: Can I see that for a second? 5 complaint?
6 I'd just like to make an objection on the 6 A Yes, I do.
7 record for the misidentification of this document. 7 Q All right. And do you understand that to
8 While there was a lawsuit filed under the 8 be Ghislaine Maxwell, my client?
9 style of Jane Doe versus Jeffrey Epstein, Jane Doe 9 A Yes.
10 was not Virginia Giuffre. And the lawsuit that's now 10 Q All right. And Ms. Maxwell was not sued
11 being handed to this witness is Jane Doe 102 versus 11 as a part of this case, correct?
12 Jeffrey Epstein. 12 MR. EDWARDS: Object to the form.
13 Is that the document we're talking about? 13 THE DEPONENT: Does that mean I can
14 MS. MENNINGER: Counsel, if you have an 14 answer?
15 objection, you should state the basis for your 15 MR. EDWARDS: Sure, you can answer.
16 objection in a non-leading, non-suggestive manner. 16 MS. MENNINGER: Right.
17 If you have any other record to make, you 17 MR. EDWARDS: If you understand the
18 can do so in a pleading filed with the Court. 18 question, answer it.
19 MR. EDWARDS: Sure. My objection is 19 A Yes, Ms. Maxwell -- sorry, repeat the
20 you've misrepresented what you've handed the witness. 20 question.
21 I want to make sure that the witness is holding what 21 Q (BY MS. MENNINGER) Was Ms. Maxwell sued
22 you actually want her to be holding as opposed to the 22 in this --
23 lawsuit you said that you were going to hand her. 23 A No, she wasn't.
24 That's it. 24 Q -- in the case that's represented by
25 MS. MENNINGER: Counsel, I will ask the 25 Defendant's Exhibit 1?
Page 18 Page 20
1 witness questions about the document. I did not ask 1 A No, she wasn't. I'm sorry for
2 you any questions about the document. 2 interrupting you. But no, she was not sued at this
3 Q (BY MS. MENNINGER) Ms. Giuffre, could you 3 time, no.
4 please take a look at what we have marked as 4 Q And why not?
5 Defendant's Exhibit 1. 5 MR. EDWARDS: I'd object and ask the
6 Do you recognize that document, 6 witness not answer that question because that would
7 Ms. Giuffre? 7 be privileged, attorney-client privileged,
8 A I believe so. Yes. Yes, I do. 8 information that was between Ms. Giuffre and the
9 Q And do you see that the counsel on the 9 Podhurst Orseck firm at that time.
10 last page -- I'm sorry, not the last page, but the 10 So I'm instructing you not to answer.
11 third from the last page are Mr. Josefsberg and 11 Q (BY MS. MENNINGER) All right.
12 Ms. Ezell from Podhurst Orseck? 12 Ms. Giuffre, did you make a decision yourself whether
13 A Yes. 13 or not to sue Ms. Maxwell as a part of this lawsuit
14 Q Were those your lawyers? 14 against -- Jane Doe 102 versus Jeffrey Epstein?
15 A Yes, they were. 15 A I think I've been advised not to answer
16 Q And did you authorize them to file Jane 16 that question.
17 Doe 102 versus Epstein on your behalf? 17 Q This is a different question.
18 A Yes, I did. 18 A Oh, okay.
19 Q And is that this complaint that's been 19 Q So your counsel can assert a privilege,
20 marked as Defendant's Exhibit 1? 20 but that question did not call for privileged
21 A I believe so. 21 information.
22 Q In that document, if I could ask you to 22 MR. EDWARDS: I --
23 turn to page -- well, I'll turn to page 9 and 23 Q (BY MS. MENNINGER) I'm asking about what
24 paragraph 23. 24 -- what you decided to do. Whether you decided to
25 A Would you like me to read it? 25 sue Ms. Maxwell or not at the time Jane Doe 102

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Page 21 Page 23
1 versus Epstein was filed? 1 CVRA action in or about December 30th, 2014, correct?
2 MR. EDWARDS: And I disagree. And I 2 A I -- I'm not aware of the exact dates.
3 object to this invading the attorney-client 3 There's no dates on this. But I did try to join the
4 privilege. 4 motion, yes.
5 And I'm instructing you not to answer. 5 Q All right. If you can look at the top
6 Q (BY MS. MENNINGER) Can you answer that 6 line of the document.
7 question without revealing any attorney-client 7 A Yes.
8 communications, whether you made a decision to file a 8 Q Does it say, Entered on FLSD --
9 lawsuit or not? 9 A Oh, it does, too, I'm sorry, yes.
10 A I'm going to have to listen to my attorney 10 Q That's all right. So does that refresh
11 and not answer the question. 11 your memory as to about when you first sought to join
12 Q All right. I would like to show you some 12 the CVRA action?
13 documents that were filed in what we'll call the CVRA 13 A Yes.
14 case, the Crime Victims' Rights Act case. 14 Q December 30th, 2014, correct?
15 Do you know what I mean by that reference? 15 A Yes.
16 A I am familiar with that. 16 Q And the corrected motion was filed a few
17 Q Okay. I'm going to start with one on or 17 days later, correct?
18 about December 30th, 2014. We will mark it as 18 A Yes, correct.
19 Defendant's Exhibit 2. 19 Q If I could turn to Defendant's Exhibit 3,
20 (Exhibit 2 marked.) 20 which was January 21st.
21 MR. EDWARDS: Thank you. 21 (Exhibit 3 marked.)
22 Q (BY MS. MENNINGER) All right. 22 MR. EDWARDS: Thank you.
23 Ms. Giuffre, do you recognize Defendant's Exhibit 2? 23 Q (BY MS. MENNINGER) Do you recognize this
24 A Yes. 24 document?
25 Q And what do you understand it to be? 25 A Yes, I do.
Page 22 Page 24
1 A I believe this is when I was hoping to 1 Q What do you understand this document to
2 join the CVRA case. 2 be?
3 Q All right. And do you know when this 3 A It's a rough background of the years that
4 document was filed? 4 I was abused by Ghislaine and Jeffrey.
5 And actually, just to be clear, about 5 Q All right. And this is something I
6 halfway there's actually a second document that was 6 believe that you on page 15 signed; is that true?
7 filed. So this is a composite exhibit. Let me be 7 A Just let me have a look.
8 very clear. 8 Q Sure.
9 So after page 14 -- I'm sorry, 13, there's 9 A I think I'm actually missing page 15. Oh,
10 a second document that is styled Jane Doe #3 and Jane 10 here we go.
11 Doe #4's Corrected Motion Pursuant to Rule 21 for 11 Q Sorry. I'm looking at the numbers on the
12 Joinder In Action. 12 top right. I apologize. I believe there was some
13 Do you see that? 13 cover page or something that was excluded.
14 A Did you say page 14? 14 MR. EDWARDS: And just for the record, I'm
15 Q It is on the 14th page of this document. 15 going to object to the relevance of this document.
16 Do you see that? 16 I'm going to allow the witness to answer the
17 A I do. 17 question, but I want my objection on the record.
18 Q And so this composite Exhibit 2 has both a 18 MS. MENNINGER: Okay. Simple objection,
19 motion and a corrected motion. 19 relevance.
20 Do you see that? 20 A Are we talking about this page?
21 A Yes. 21 Q (BY MS. MENNINGER) Yes, the one with the
22 Q And were both of those pleadings 22 black box, yes. Do you believe that to have
23 authorized by you to be filed? 23 contained your signature?
24 A Yes. 24 A Yes.
25 Q In other words, you wanted to join the 25 Q All right. And you executed that on

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1 January 19th, 2015? 1 filed under oath is no longer true, correct?
2 A At the very top of the page it says 2 MR. EDWARDS: Object to the form.
3 January 21st, 2015. 3 A I wouldn't say that it wasn't true. I was
4 Q The date it was filed. Is there a date 4 just unaware of the times and the dates.
5 just above the signature block? 5 Q (BY MS. MENNINGER) Again, is there more
6 A Oh, yes, sorry. Yes, there is. 6 than one truth, Ms. Roberts?
7 Q And what date -- what date was that? 7 A No, there's no more than one truth.
8 A The 19th day of January, 2015. 8 Q All right. So a document in which you
9 Q Okay. And this document is something that 9 swore that you were 15 years old when you met
10 you believe contains the truth, correct? 10 Ms. Ghislaine Maxwell is an untrue statement,
11 A To the best of my knowledge at the time, 11 correct?
12 yes. 12 MR. EDWARDS: Object to the form.
13 Q All right. Did something change between 13 A It's not that it's an untrue statement.
14 the time then and today that makes you believe that 14 It was a mistake. So it wasn't intentionally trying
15 it's not all accurate? 15 to say something that wasn't true. It was to my best
16 A Well, as you can see, in line 4 on page 1, 16 knowledge that I thought it was 1999. And when I got
17 I wasn't aware of my dates. I was just doing the 17 my records from Mar-a-Lago I was able to find out
18 best to guesstimate when I actually met them. 18 that it was 2000. And this was entered before I
19 Since then I've been able to find out that 19 found out the actual dates that I did work at
20 through my Mar-a-Lago records that it was actually 20 Mar-a-Lago.
21 the summer of 2000, not the summer of 1999. 21 Q (BY MS. MENNINGER) Okay. So a document
22 Q Oh, I'm sorry. Are you back on page 1? 22 that you filed under oath --
23 A On the first page. 23 A Um-hum.
24 Q Okay. 24 Q -- is now, you believe to be untrue,
25 A Yes. 25 correct?
Page 26 Page 28
1 Q And you're talking about line 4? 1 MR. EDWARDS: Objection. Asked and
2 A Line 4. 2 answered.
3 Q Paragraph 4 or line 4? 3 Q (BY MS. MENNINGER) You may answer.
4 A Oh, sorry. Number 4, the paragraph 4 MR. EDWARDS: Answer again.
5 number 4. 5 A Again, I wouldn't say it's untrue. Untrue
6 Q Okay. And what part of paragraph 4 do you 6 would mean that I would have lied. And I didn't lie.
7 now believe to be untrue? 7 This was my best knowledge at the time. And I did my
8 A In approximately -- 8 very best to try to pinpoint time periods going back
9 MR. EDWARDS: Object to the form. 9 such a long time ago.
10 You can answer. 10 It wasn't until I found the facts that I
11 A In approximately 1999 when I was 15 years 11 worked at Mar-a-Lago in 2000 that I was able to
12 old I met Ghislaine Maxwell. 12 figure that out.
13 Q (BY MS. MENNINGER) Okay. 13 Q (BY MS. MENNINGER) And approximately when
14 A I now know that it was 2000, that I was 16 14 did you learn those facts about the dates you worked
15 years old when I met Ghislaine Maxwell. 15 at Mar-a-Lago?
16 Q So when you signed this document under 16 A I would say it was mid-2015.
17 penalty of perjury stating that it was true, you no 17 Q Mid-2015 is the first time you became
18 longer believe that to be true, correct? 18 aware of the dates --
19 A It was an honest mistake. We had no idea 19 A I don't know the exact --
20 how to pinpoint without any kind of records or dates 20 Q If you could just let me finish.
21 or anything like that. I was just going back 21 A I'm sorry.
22 chronologically through time. And that's the best 22 Q That's all right. Approximately mid-2015
23 time that I thought it was. And now I know the 23 when you learned the true dates that you had worked
24 facts, so it's good to know. 24 at Mar-a-Lago?
25 Q So you now believe that a document you 25 A That's correct. Sorry.

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1 Q And based on the fact that you learned the 1 Q (BY MS. MENNINGER) I'm going to show you
2 fact you had worked at Mar-a-Lago in 2000 -- you 2 an exhibit filed on, I believe on or about
3 became aware in mid-2015 -- 3 February 6th of 2015. Defendant's Exhibit 4.
4 A Um-hum. 4 (Exhibit 4 marked.)
5 Q -- that you had met Ms. Maxwell in 2000, 5 MR. EDWARDS: Thank you.
6 correct? 6 Q (BY MS. MENNINGER) And drawing your
7 A That's -- 7 attention to the heading line that says, Entered on
8 MR. EDWARDS: Object to the form. 8 the docket February 6th, 2015.
9 A That's correct. 9 Do you see that?
10 Q (BY MS. MENNINGER) All right. And you 10 A Yes.
11 became aware in mid-2015 that you were not 15 years 11 Q All right. And Declaration of Jane Doe 3,
12 old when you met Ghislaine Maxwell, correct? 12 do you see that on the first page?
13 MR. EDWARDS: Object to the form. 13 A Yes.
14 A That's correct. 14 Q And it's in the CVRA case, correct, Jane
15 Q (BY MS. MENNINGER) Okay. And who 15 Doe 1 and Jane Doe 2 versus United States of America?
16 provided you those Mar-a-Lago records in 16 A Yes.
17 approximately mid-2015? 17 Q All right. And do you recognize this
18 MR. EDWARDS: I'm going to object. 18 document?
19 And to the extent that this invades the 19 A Yes.
20 attorney-client privilege, if it was your attorneys 20 Q And what do you understand this document
21 that you spoke to and learned this information or 21 to be?
22 received this information from, then you're 22 A I believe it's more reason to why I should
23 instructed not to answer. 23 have been added to the CVRA case.
24 A I cannot answer that question. 24 MR. EDWARDS: Objection to the relevance,
25 Q (BY MS. MENNINGER) Did you yourself look 25 Counsel.
Page 30 Page 32
1 at records in the middle of 2015 regardless of who 1 Q (BY MS. MENNINGER) Okay. And again, if
2 showed them to you? 2 you look to the last page of the document,
3 MR. EDWARDS: Objection. And to the 3 paragraph 67 --
4 extent that they were showed to you or shared by any 4 A The last page?
5 of your lawyers, you're instructed not to answer the 5 Q Yes, the very last.
6 question. It invades the attorney-client privilege. 6 A 67, yes.
7 Q (BY MS. MENNINGER) Did you look at 7 Q All right. It says in paragraph 67: I
8 Mar-a-Lago records in the middle of 2015 yourself? 8 declare under penalty of perjury that the foregoing
9 MR. EDWARDS: She's not answering the 9 is true and correct, right?
10 question. 10 A Yes.
11 MS. MENNINGER: On what grounds is she not 11 Q And it was executed on or about the
12 answering the question? 12 5th day of February, 2015, correct?
13 MR. EDWARDS: I just told you it invades 13 A It's a bit smudged, but it kind of looks
14 the attorney-client privilege. If she learned -- 14 like a 5.
15 I will instruct her if she learned by some 15 Q All right. And then there's a signature
16 other way than her attorneys sharing the information 16 block that's redacted that says Jane Doe 3, correct?
17 with her, then she can answer the question. 17 A Correct.
18 Q (BY MS. MENNINGER) I'm asking you not to 18 Q Do you believe that you signed this
19 tell me whether your attorneys showed you the record. 19 document and it was later covered up by that block?
20 I'm asking you not to tell me the source of the 20 A Yes.
21 record. 21 Q All right. And again, is there anything
22 I'm asking you if you personally in the 22 in this document that you believe today to not be
23 middle of 2015 looked at Mar-a-Lago records? 23 true?
24 MR. EDWARDS: Same objection. 24 MR. EDWARDS: I just ask that you read
25 Same instruction. 25 through the entire document and answer the question.

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1 Q (BY MS. MENNINGER) Have you seen this 1 against ; is that your understanding?
2 document before, Ms. Giuffre? 2 It's your understanding. You don't have
3 A I'm sure I have, but it's always good to 3 to look at your lawyer if you don't understand. You
4 refresh your memory just looking over something. 4 don't have to --
5 Q All right. 5 A No, I just don't know if I'm allowed --
6 (Pause.) 6 Q That's all right.
7 A Thank you for giving me time to read that 7 A -- to say certain things about that. But,
8 over. 8 yes, I believe they were in a lawsuit.
9 Q Certainly. So have you had a chance to 9 Q Okay. And that's against ,
10 read it now? 10 right?
11 A Yes. 11 A Correct.
12 Q All right. And what parts of this 12 MR. EDWARDS: Object to the form. I
13 document sworn by you under penalty of perjury are 13 object to the relevance of the document.
14 not true? 14 Q (BY MS. MENNINGER) All right.
15 A Again, the only thing that I see is the 15 Ms. Giuffre, again, if you could turn to the last
16 mistake that I made, I first met Epstein when I was 16 page of this document. And do you see a signature on
17 15 years old. 17 that page?
18 Q Okay. And that's in paragraph 5? 18 A I do.
19 A That's in paragraph 5 on the first page. 19 Q Whose signature is that?
20 Q All right. And everything else you 20 A That is mine.
21 believe to be true? 21 Q And approximately when did you sign that
22 A Yes. 22 document?
23 Q Okay. If I could now turn to what I'll 23 A Executed this 20th day of November, 2015.
24 mark as Defendant's Exhibit 5. 24 Q All right. So you signed that on
25 (Exhibit 5 marked.) 25 November 20th, 2015, correct?
Page 34 Page 36
1 THE DEPONENT: Thank you. 1 A Correct.
2 MR. EDWARDS: Thank you. 2 Q All right. And that was under penalty of
3 MS. MENNINGER: I think I have one more. 3 perjury, correct?
4 MS. McCAWLEY: It's okay if you don't. 4 A Correct.
5 MS. MENNINGER: I don't think I have all 5 Q All right. If I could now turn to what
6 of them. 6 we'll mark as Defendant's Exhibit 6.
7 Q (BY MS. MENNINGER) All right. Do you 7 (Exhibit 6 marked.)
8 recognize Defendant's Exhibit 5? 8 MR. EDWARDS: Thank you.
9 A Yes. 9 MS. McCAWLEY: Thanks.
10 Q What is the title of that document? 10 Q (BY MS. MENNINGER) Do you recognize this
11 A Declaration of Virginia Giuffre. 11 document, Ms. Giuffre?
12 Q And that's you, correct? 12 A I do.
13 A Yes. 13 Q All right. What do you believe this
14 Q And do you recognize which case this 14 document to be?
15 declaration was filed in? 15 A I believe this is when I spoke to the FBI.
16 A Yes. Bradley Edwards and Paul Cassell, 16 Q Okay. And do you remember about when you
17 Plaintiff versus . 17 spoke to the FBI?
18 Q All right. And who do you understand 18 A It says, Date of entry July 5th, 2013.
19 Mr. Edwards and Mr. Cassell to be? 19 Q Do you believe that you spoke to the FBI
20 A Mr. Edwards is my lawyer sitting next to 20 in 2013?
21 me. 21 A I thought it was 2011 when I talked to
22 Q All right. 22 them.
23 A And Mr. Cassell is another one of my 23 Q Okay. I'm going to direct your attention
24 lawyers. 24 to the bottom of that page.
25 Q All right. And they are in a lawsuit 25 A Yes.

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1 Q The first page. Do you see that? 1 Q Okay. And have you reviewed any -- have
2 A Yes. 2 you at any time reviewed this document without those
3 Q The last few lines there have another 3 portions whited out?
4 date. 4 A I don't believe I've seen this document
5 A Oh, yes, investigation of, yes. 5 without the portions.
6 Q All right. 6 Q Okay. So you don't know, for example,
7 A So that makes sense, okay. 7 what's behind those, other than what you recall --
8 Q Okay. What do you understand that to be? 8 A No.
9 And if it refreshes your recollection about when you 9 Q -- having told the FBI at the time,
10 spoke to the FBI, just let us know. 10 correct?
11 A Yeah, March 17th, 2011 sounds more right 11 A That's correct.
12 than 2013. 12 Q Okay. I'm going to show you a new
13 Q Okay. And where did you speak to them? 13 document.
14 A I believe this was in the office of the 14 A Okay.
15 consulate, American Consulate, in Sydney. 15 Q You can just put that to the side.
16 Q Sydney, Australia? 16 Defendant's Exhibit 7.
17 A Sydney, Australia. 17 (Exhibit 7 marked.)
18 Q Okay. And you were there in person with 18 Q (BY MS. MENNINGER) All right.
19 these FBI agents? 19 MR. EDWARDS: Thanks.
20 A Correct. 20 Q (BY MS. MENNINGER) And do you recognize
21 Q And were they taking notes when they spoke 21 this document?
22 to you? 22 A Yes.
23 A Yes. 23 Q And what do you understand it to be?
24 Q Were they recording the interview, to your 24 A This was a phone conversation that I had
25 knowledge? 25 between Jack Scarola and Brad Edwards.
Page 38 Page 40
1 A I believe they were. 1 Q Okay. And do you see a date reflected on
2 Q Okay. Have you had a chance to review 2 the front page?
3 this report? 3 A April 7, 2011.
4 And I will make note for the record that 4 Q Is that when you had that phone
5 there are obviously many places that are blacked 5 conversation with them?
6 out -- 6 A If it's dated like that, it must be, yes.
7 A Yeah. 7 Q Well, I just need you to say from your
8 Q -- or whited out. Is that fair? 8 memory, does that sound about right in terms of what
9 A Yes. 9 you recall having been the phone conversation?
10 Q All right. Have you had a chance to 10 A I'm sure it's correct.
11 review this one with whited-out portions of it before 11 Q Okay.
12 today? 12 A I don't have a good calendar in my brain.
13 A Yes. 13 So, yes, I'm sure that that's the correct date.
14 Q All right. And you understood when you 14 Q Did you understand it was being recorded,
15 were speaking to the FBI that they were federal 15 correct?
16 agents, correct? 16 A Yes.
17 A Yes. 17 Q Okay. Have you listened to the recording
18 Q And that you were supposed to tell them 18 of that phone call?
19 the truth, correct? 19 A I don't believe I listened to the
20 A Absolutely. 20 recording, but I have seen the document.
21 Q And do you believe that you did, in fact, 21 Q All right. And again, you were speaking
22 tell them the truth? 22 the truth at the time you were speaking to them as
23 A To the best of my knowledge. Again, when 23 lawyers and officers of the court, correct?
24 it comes to dates and times, I was obviously off. 24 A Yes. And again, to the best of my
25 But everything else is absolutely 100 percent true. 25 knowledge when it comes to dates.

Agren Blando
Document & Video,
07/30/20
Page 41 Page 43
1 Q Okay. And then the last -- the last 1 as you sit here right now, is there anything in that
2 document, I hope, is -- 2 manuscript about Ghislaine Maxwell that is untrue?
3 MS. MENNINGER: The big one. 3 A I don't believe so. Like I said, there is
4 (Exhibit 8 marked.) 4 a lot of stuff that I actually have left out of here.
5 Q (BY MS. MENNINGER) All right. Do you 5 Q Um-hum.
6 recognize -- I'm going to -- I'm sorry, if I didn't 6 A So there is a lot more information I could
7 say it already. This is Defendant's Exhibit 8. 7 put in there. But as far as Ghislaine Maxwell goes,
8 Do you recognize this document? 8 I would like to say that there is 99.9 percent of it
9 A Yes, I do. 9 would be to the correct knowledge.
10 Q And what is this document? 10 Q All right. Is there anything that you --
11 A This is a manuscript that I was writing, I 11 and I understand you're doing this from memory. Is
12 believe, back in 2011 regarding some of my life 12 there anything that you recall, as you're sitting
13 story. And just to make it known, this is a based on 13 here today, about Ghislaine Maxwell that is contained
14 true events. But I wouldn't say fictional, but just 14 in that manuscript, that is not true?
15 based on true events. 15 A You know, I haven't read this in a very
16 Not everything in it is -- not everything 16 long time. I don't believe that there's anything in
17 is in there and not everything is, you know, correct. 17 here about Ghislaine Maxwell that is not true.
18 So there's a few mistakes in there. 18 MR. EDWARDS: I'd just ask, Counsel, if
19 Q Okay. Off the top of your head, do you 19 you have anything specific to show her about
20 recall any mistakes that are in there now without 20 Ghislaine Maxwell --
21 reading the 140-page document? 21 MS. MENNINGER: I'll ask questions.
22 MR. EDWARDS: We're going to be here a 22 MR. EDWARDS: -- I'll have her look at it.
23 long time. 23 MS. MENNINGER: I'll ask questions.
24 A Yeah, we could be here a very long time. 24 MR. EDWARDS: I know, but I want the
25 I mean, I'd like to say a majority of it is correct. 25 record clear that if she hasn't read it in a long
Page 42 Page 44
1 Some names have been changed in order to protect 1 time, she --
2 other people. 2 MS. MENNINGER: She made the record very
3 Q (BY MS. MENNINGER) Protect their privacy? 3 clear. Thank you. She doesn't need you to make a
4 A Protect their privacy, yeah, I would say, 4 record.
5 just not getting them involved in, if this were to 5 MR. EDWARDS: I'm not making records, but
6 ever go public. 6 you're making this last longer. There's no need for
7 Q Well, again, without rereading the whole 7 this. This doesn't have to be an unpleasant process.
8 manuscript -- 8 I want her to help you.
9 A Reading it, yeah. I'm trying to see if I 9 MS. MENNINGER: I don't find it
10 can -- see something in here. 10 unpleasant. I'm sorry if you do.
11 Q Let me narrow my question and maybe that 11 MR. EDWARDS: Okay. Well, then, I object
12 will help. 12 to that last series of questions to the extent that
13 A Yes. 13 she was unable to look at what you wanted her to look
14 Q Is there anything -- well, first of all, 14 at.
15 did you author that entire manuscript? 15 Q (BY MS. MENNINGER) I would like to next
16 A Yes, I did. 16 turn to a document filed on March 16th of this year.
17 Q Did anyone else author part of that 17 Or actually, let me rephrase that. A document dated
18 manuscript? 18 March 16th of this year, which we will mark as
19 A Do you mean did anyone else write this 19 Defendant's Exhibit 9.
20 with me? 20 (Exhibit 9 marked.)
21 Q Right. 21 Q (BY MS. MENNINGER) Do you recognize this
22 A No. 22 document, Ms. Giuffre?
23 Q That's all your writing? 23 A Yes, I do.
24 A This is my writing. 24 Q All right. And what is your understanding
25 Q Okay. To the best of your recollection, 25 of what this document represents?

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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 I do.
4 Q And are you the plaintiff? 4 Q All right. And then looking at
5 A I am the plaintiff, yes. 5 Defendant's Exhibit 11, that's your declaration,
6 Q All right. 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 All right. 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 I can see the, yeah the printed names. So 19 A Yes.
20 if it's electronic signature, then yes. 20 Q All right. And then one more on that.
21 Q All right. 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 All right. 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 All right. 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 All right. 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 I do see that.
9 A Thank you. 9 Q All right. 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 All right. 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 All right. 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 All right. 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

Agren Blando
Document & Video,
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Page 49 Page 51
1 served on April 29th, 2016? 1 Q Written from Taco Bell?
2 A I believe I have seen this. 2 A You know, I don't know, sorry. I just --
3 Q And you were here in the U.S. last Friday? 3 I remember he asked me to come in and help him out,
4 A Yes. 4 and that's -- I didn't really consider myself an
5 Q So you saw it in person, correct? 5 employee there, but --
6 A Yes, I was looking at a lot of documents 6 Q Just wearing the shirt and getting a
7 on Friday. 7 paycheck didn't cause you to think you were an
8 Q Okay. 8 employee?
9 A I believe this could definitely be one I 9 A Well --
10 looked at. 10 MR. EDWARDS: Object to the form.
11 Q All right. If I could direct your 11 Mischaracterizes her testimony.
12 attention to -- let me see, in that document -- 12 A Yeah, I know. I mean, it was my
13 MR. EDWARDS: Exhibit 12? 13 boyfriend. I was helping him out. So that's the way
14 MS. MENNINGER: Um-hum, Defendant's 14 I looked at it.
15 Exhibit 12. 15 Q (BY MS. MENNINGER) Is there any other
16 Q (BY MS. MENNINGER) -- to page -- sorry. 16 place that you wore a uniform and got a check from in
17 You're not the only one who's seen a lot of 17 the years from '96 to 2000?
18 documents. 18 A I did work at Publix as a bag girl, but
19 Well, without asking you to look at a 19 that was only for a couple weeks, I think.
20 page, can you tell me what your -- between 1996 20 Q Which Publix was that?
21 and -- well, in 1996 to 2002, what was the first job 21 A I believe it was in Loxahatchee.
22 that you held? 22 Q Okay. Do you remember the street?
23 A I believe the first job that I held was in 23 A No.
24 the year 2000, and that was at Mar-a-Lago. 24 Q All right. Anywhere else you wore a
25 Q Okay. And is that the first job you held 25 uniform and got a paycheck?
Page 50 Page 52
1 as a teenager or at any point in time, that you 1 A I volunteered at a bird aviary.
2 recall? 2 Q What was the name of that?
3 A Yes, that I recall. 3 A I don't know the name of it. But it
4 Q All right. Did you ever work at Taco 4 was -- I'm an animal lover. So --
5 Bell? 5 Q Okay.
6 A My ex-boyfriend used to work there and I 6 A -- it's something I enjoyed doing.
7 would help him out. I was never really -- I don't 7 Q Okay. Did you get a check from them?
8 think I was employed there. He was my boyfriend so I 8 A I volunteered. I think they eventually
9 stayed there with him all the time. 9 put me on some kind of payroll. I don't think it was
10 Q What was his name? 10 much, though.
11
12
13
14
15
A
name was
Q
-
I called him
you were not employed there?

A
but I think his real
Okay. And so he was employed there, but
I used to go there and help him out.

11
12
13
14
15
Q
check?
A
Q
Okay. So what year were you in helping
out in a Taco Bell wearing the uniform and getting a
I have no idea when it comes to years.

Was it before or after Mar-a-Lago?
16 Q Did you have a uniform? 16 A Before Mar-a-Lago.
17 A I would have to wear a shirt when I was 17 Q Okay. And how --
18 there, yes. He was the manager, so -- 18 A Mar-a-Lago was my first real job so --
19 Q Oh, a Taco Bell shirt? 19 Q What's that?
20 A Yes. 20 A Mar-a-Lago was like my first real job.
21 Q Okay. And did you get a paycheck from 21 Q What do you mean by real job?
22
23
24
25
them?
A
Q
A
I believe
-
How did he pay you?
With a check.
paid me.
22
23
24
25
A
Q
Like, you know, fully employed, sit down
for an interview and, you know.
Okay. So Taco Bell, was Taco Bell the
first place you got a paycheck from?

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Document & Video,
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Page 53 Page 55
1 MR. EDWARDS: Object to the form. 1 Q Months. And what was the job you believe
2 A Uhm, I don't know, to be honest. 2 you had immediately prior to Mar-a-Lago?
3 Q (BY MS. MENNINGER) And in what order did 3 A If I were correct, it would be the aviary
4 Taco Bell, Publix and Mar-a-Lago go, and the aviary, 4 that I volunteered at.
5 sorry? 5 Q Okay. And you believe you were living
6 A Oh, I would have to guess. Do you want me 6 with your parents at the time you worked at the
7 to guess? 7 aviary?
8 Q Sure. 8 A Yes.
9
10
11
12
13
A
Q
A
Um, I would say Publix. And then, I think
that's when I helped my boyfriend out at Taco Bell
and then I think the aviary.
And where was the Taco Bell?
I was living in Fort Lauder -- I think it
9
10
11
12
13
Q
A
Q
-Okay. And not living with
my parents.
might have been living with me and
Okay. So you recall was living

with you and your parents at the time you worked at
14 was Fort Lauderdale. Don't quote me on that, but 14 the aviary?
15 somewhere in Florida, Broward County, something like 15 A Yes.
16 that. 16 MS. McCAWLEY: Objection.
17 Q And who were you living with at that time? 17 Mischaracterizes testimony.
18 A Michael. His name is James, but Michael. 18 Q (BY MS. MENNINGER) And was living
19 Q So you were living with Michael when you 19 with you and your parents at the time you started at
20 worked at the Taco Bell, right? 20 Mar-a-Lago?
21 A Yes, I was living with him. 21 A Yes.
22 Q And you worked with Michael when you 22 Q And what address was living with
23 worked at the Publix, correct? 23 you and your parents at the time you started at
24 A No. 24 Mar-a-Lago?
25 Q Okay. So Publix came after Taco Bell or 25 A My parents' address?
Page 54 Page 56
1 before? 1 Q Whatever address you were living at, at
2 A I think it came -- like I said, don't 2 the time you started at Mar-a-Lago.
3 quote me on it, but I think Publix came before it. 3 A , Loxahatchee, Florida
4 Q And who were you living with when you 4 33470.
5 worked at Publix? 5 Q How is it that you came to work at
6 A My mom and my dad. 6 Mar-a-Lago?
7 Q And who were you living with when you 7 A My dad is a maintenance manager or
8 worked at the aviary? 8 supervisor, I don't know what you call it. But he
9 A My mom and my dad. 9 worked in the maintenance department, mostly on
10 Q Anywhere else that you got a paycheck from 10 tennis courts, working on the air conditioning,
11 before 2000? 11 helping set up for functions. And he got me a summer
12 A No, not that I can think of. 12 job there.
13 Q Okay. Anywhere else you wore a uniform? 13 Q Okay. And you said you were on a break?
14 A Besides Mar-a-Lago and -- yeah, that's it. 14 A Yes.
15 Q Okay. And so how long was it between 15 Q What were you on a break from?
16 working at any of those three places and the time 16 A I think like -- this is going back so long
17 that you worked at Mar-a-Lago? 17 now, but I was attempting to get my GED. And it,
18 A I have no idea. I'm sorry. Um -- 18 summer came, so school stops during the summertime
19 Q Years? Months? 19 here in America, and I got a summer job.
20 A Oh, we're going to go back 20 Q All right. And where were you in school?
21 chronologically. I was trying to get my GED and I -- 21 A I don't actually know the name of the
22 there was a summer break. And that's when I started 22 place. It's -- yeah, I know.
23 working for Mar-a-Lago. So that Mar-a-Lago we know 23 Q A GED place?
24 now is in the year 2000. So I would have to say a 24 A Yeah, it was, like, I was previously in
25 month. 25 Royal Palm Beach High School, but, I mean, because of

Agren Blando
Document & Video,
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Page 57 Page 59
1 a lot of the circumstances that I had been subjected 1 Q Locker room attendant was the name?
2 to, I decided I wanted to get my GED. 2 A Of the position?
3 Q Okay. So you were going to an actual 3 Q Yes.
4 school to get your GED, that's what you're saying? 4 A Yes.
5 A Yes. 5 Q And did they give you any training?
6 Q And that school, whatever it was, where 6 A No.
7 you were getting your GED was not Palm Beach High 7 Q Did they show you how to work the lockers?
8 School, right? 8 A Well, I mean, there was a girl who already
9 A No. 9 worked there at the front desk. I think she helped
10 Q And it -- whatever the school was where 10 make appointments and greeted people, and then she
11 you were getting your GED took a summer break? 11 just told me my duties in the locker room were to,
12 A I believe so, yes. 12 you know, make tea. I had never made tea before, so
13 Q And that was in 2000? 13 that was -- that was fun. Learn how to make tea.
14 A Now that we know the right dates, yes. 14 Clean up after the ladies who had been in the locker
15 Q And that's when your dad helped you get a 15 room. Make sure the bathrooms were kept nice and
16 quote-unquote summer job? 16 tidy. You fold the toilet paper into a little
17 A Yes. 17 triangle every time anyone went to the toilet. Clean
18 Q All right. And that summer job was 18 up the sink area. It was a very crazy job.
19 Mar-a-Lago? 19 Q Do you remember the names of any of your
20 A Yes. 20 coworkers who you worked with at Mar-a-Lago?
21 Q Okay. Now tell me how you sort of came 21 A I believe the head of the spa area was
22 into Mar-a-Lago for the first time? He asked you to 22 Adriana or Adrienne. I can't remember exactly.
23 come? They called you? What happened? 23 Q Okay.
24 A My dad was very liked there. So I think 24 A And the girl who trained me, I have a very
25 he talked to the people who were in HR. And then 25 clear picture of her face, but I can't remember her
Page 58 Page 60
1 they said for me to come in for an interview. 1 name.
2 Q Um-hum. 2 Q All right. What did she look like?
3 A To be interviewed for a locker room 3 A She had blonde hair, probably to her
4 assistant. 4 shoulders, and it was curly.
5 Q Um-hum. 5 Q And how old was she?
6 A They liked me. I had to go through a 6 A I'd say in her 20s.
7 series of drug tests, polygraph tests. I mean, it 7 Q All right. Did they check your
8 was a very extensive regime to get a job there. 8 identification when you went in for your job
9 Q Yeah. 9 interview or your --
10 A And when all those came back good, I 10 A It was very extensive. I'm sure they
11 started the job. 11 would have had to check and make sure I was who I
12 Q So how long do you think it took for you 12 was.
13 to go through that extensive series of drug tests and 13 Q And so you had a driver's license, right?
14 polygraph tests and -- 14 A I believe so.
15 A I did them both in the same day. 15 Q All right. And, let's see. Did you move
16 Q Okay. When was the interview? Was it on 16 to a different position while you were there or did
17 the same day or a different day? 17 you always stay as a locker room --
18 A I believe it was like a few days 18 A I wasn't there very long. So I just --
19 beforehand. 19 Q Just one second. Did you always stay as a
20 Q Okay. And do you remember who you 20 locker room attendant?
21 interviewed with? 21 A Yes.
22 A No. 22 Q Okay. I just need to finish my question
23 Q Do you remember the title of the job for 23 for the court reporter.
24 which you were interviewing? 24 A I know, I'm sorry. I have a tendency of
25 A Locker room attendant. 25 jumping in.

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Page 61 Page 63
1 Q Okay. If I can direct your attention back 1 documents that you met Ghislaine Maxwell in '98 or
2 to Defendant's Exhibit 12 at page 15. And under the 2 '99, correct?
3 heading Response to Interrogatory Number 9, do you 3 A Yes.
4 see that where it says -- 4 Q And you do admit that you told members of
5 A Yes. 5 the media that you met Ghislaine Maxwell in '98 or
6 Q -- Ms. Joffrey (pronouncing) -- Giuffre, 6 '99, correct?
7 excuse me, responds as follows? 7 MR. EDWARDS: Form.
8 A Yes. 8 A That was my closest approximation to what
9 Q Okay. It says you worked as a locker room 9 I could actually remember, so --
10 attendant for the spa area, correct? 10 Q (BY MS. MENNINGER) You told the media
11 A Yes. 11 that you met her in '98 or '99?
12 Q And it says records produced in this case 12 MR. EDWARDS: Form.
13 identify the date of employment as 2000, correct? 13 A Again, yes, as close as I can remember.
14 A Yes. 14 Q (BY MS. MENNINGER) And the media
15 Q What records that were produced in this 15 published in the newspapers that you met Ghislaine
16 case cause you to believe that the employment began 16 Maxwell in '98 or '99, correct?
17 in 2000? 17 MR. EDWARDS: Form.
18 A Uhm, is this going back to another 18 A Yes, they did.
19 question that I'm not allowed to answer? 19 Q (BY MS. MENNINGER) And the news media
20 Q No. 20 published in the newspapers what you told them, which
21 A I have seen the documents, and I know that 21 is that you were 15 when you met Ghislaine Maxwell,
22 my employment now was in 2000. 22 correct?
23 Q What documents did you see that caused you 23 MR. EDWARDS: Form.
24 to make that answer? 24 A Which is what I truly thought at the time,
25 A The Mar-a-Lago employment documents. 25 yes.
Page 62 Page 64
1 Q Are they your Mar-a-Lago employment 1 Q (BY MS. MENNINGER) Okay. And it is not
2 documents? 2 true that you were 15 when you met Ghislaine Maxwell,
3 A Um -- 3 correct?
4 MR. EDWARDS: Object to the form. 4 A It was a mistake that I made, yes.
5 A My name is on there. 5 Q So that the printing in the newspaper that
6 Q (BY MS. MENNINGER) Okay. Do you believe 6 you met Ghislaine Maxwell when she was -- when you
7 them to be your Mar-a-Lago employment documents? 7 were 15 is not a true statement of fact, correct?
8 A As far as I can tell. 8 A It is an incorrect statement as I have now
9 Q Okay. So you were able to review your 9 found out, that my employment started in 2000.
10 Mar-a-Lago employment documents -- 10 Q All right. And to the best of your
11 MR. EDWARDS: Object to the form. 11 recollection, you found that out in the middle of
12 Q (BY MS. MENNINGER) -- and respond to the 12 2015, correct?
13 question, as it says right there that you respond, 13 MS. McCAWLEY: Objection.
14 correct? 14 A To the best of my recollection. I mean, I
15 A Yes. 15 can't pinpoint an exact date I found out. But, yes.
16 Q When did you review the documents that you 16 Q (BY MS. MENNINGER) About a year ago?
17 reviewed to cause you to respond to that answer that 17 MR. PAGLIUCA: Are we all participating in
18 way? 18 this deposition or just --
19 A I don't think I found out till sometime 19 MS. McCAWLEY: Same way you guys did.
20 mid -- mid last year, I believe. 20 MR. PAGLIUCA: We did not.
21 Q Okay. 21 MS. MENNINGER: I did not.
22 A I'm really not too sure. You know, I'm 22 MS. McCAWLEY: You both objected.
23 sorry, dates and documents, there's too many to 23 MS. MENNINGER: No.
24 remember. But -- 24 MR. PAGLIUCA: No, we didn't.
25 Q Okay. You do admit that you filed in many 25 MS. McCAWLEY: We can go back through the

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Page 65 Page 67
1 record. 1 Mar-a-Lago?
2 MR. PAGLIUCA: We sure can. 2 A Correct.
3 So if we're all participating, maybe I'll 3 Q Okay. I'm going to show you an exhibit
4 have a few questions at the end of this. I think we 4 marked as Defendant's Exhibit 13.
5 should limit this to one lawyer. And your statement 5 (Exhibit 13 marked.)
6 about two lawyers participating in the last 6 Q (BY MS. MENNINGER) Okay. All right,
7 deposition is wrong. 7 Ms. Giuffre, do you recognize this document?
8 MS. McCAWLEY: Well, I recall that she got 8 A Yes, I do.
9 a microphone because she said she was going to be 9 Q What is this document?
10 objecting. So -- 10 A This is a resume that I created myself.
11 MR. PAGLIUCA: I know. She put on a 11 Q All right. And what address did you put
12 microphone and didn't speak through the whole thing. 12 at the top of your resume?
13
14
15
16
17
MS. McCAWLEY: Well, we can take a look
back at the record. You know, it's not a problem.
Brad can make the objections.
MR. PAGLIUCA: Okay. Let's take care of
it that way, then.
13
14
15
16
17
- A
Q
A
Q
And when did you live at that address?
I believe from 2013 to 2014.
Okay. And you said you created this
18 MR. EDWARDS: Can you tell me when you're 18 document, correct?
19 at a good stopping point? 19 A Yes.
20 MS. MENNINGER: I was about to say it's 20 Q And did you send it out to any employers?
21 been an hour. 21 A Do you have any attachments that this goes
22 MR. EDWARDS: Yeah. 22 with to say that I have? Because I'm not too sure.
23 MS. MENNINGER: So this would be a good 23 I've created a lot of resumes.
24 time to take a break. 24 Q Okay. And hold on, I'll see if we do.
25 MR. EDWARDS: Okay. Thanks. 25 MS. MENNINGER: All right. I'll mark this
Page 66 Page 68
1 THE VIDEOGRAPHER: We're off the record at 1 next as Defendant's Exhibit 14.
2 10:12. 2 (Exhibit 14 marked.)
3 (Recess taken from 10:12 a.m. to 3 A Thank you.
4 10:27 a.m.) 4 Q (BY MS. MENNINGER) All right. Do you
5 THE VIDEOGRAPHER: We're back on the 5 recognize this document?
6 record at 10:27. 6 A Yes.
7 Q (BY MS. MENNINGER) All right. 7 Q What is this document?
8 Ms. Giuffre, you testified that you first became 8 A This is me replying to ads for jobs.
9 aware that you -- your employment at Mar-a-Lago began 9 Q Okay. And you were communicating with --
10 in 2000, in mid-2015, correct? 10 by your e-mail, correct?
12 Mischaracterizes her testimony. 12 Q All right. And I apologize. This one
13 A I don't know exactly when. It could be 13 actually has the resume attached to an e-mail.
14 towards the end of 2015. It could be towards the 14 A Um-hum.
15 beginning of 2016. I just know that I've learned 15 Q Do you see that, towards the back of the
16 about it recently. I'm not too sure exactly what 16 document?
17 date I did learn about it. 17 A Yes, I do.
18 Q (BY MS. MENNINGER) Okay. But to your 18 Q Okay. So --
19 mind, it's been within the last 6 to 12 months; is 19 A Sorry.
20 that fair? 20 Q To whom -- to whom -- with whom were you
21 A I wouldn't say 12 months, no. I would 21 communicating about a job at this time?
22 just say up until -- I don't know when I was shown 22 A Well, on the very top, Phil or Gary, and
23 that, when I actually first saw it, but it wasn't a 23 that was for a bartending position.
24 year ago. 24 Q Okay.
25 Q Saw your employment records from 25 A Um --

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Page 69 Page 71
1 Q Was that something your brother had 1 you believe the one attached to Defendant's
2 recommended or your father? I don't know who. 2 Exhibit 14 is the one that you sent?
3 A You know, I just looked at that, that's 3 A There are differences, isn't there? Yes,
4 kind of why I giggled. I don't know why my 4 there is.
5 brother -- that's my brother. That's the way we talk 5 Q Okay. What are the differences that you
6 to each other: Hi, stupid head. Good luck, smelly, 6 know?
7 XOXOXO, sissie. 7 A It starts -- I mean, let me see. The very
8 He's my little brother so you have to 8 top introduction is the same.
9 understand we kind of play around. But subject to my 9 Q Um-hum.
10 resume for hospitality, I'm not too sure why he would 10 A After the experience.
11 have gotten it, but apparently he did. 11 Q Um-hum.
12 Q Okay. And you see that your resume was 12 A That changes. The dates change. And then
13 attached to an e-mail communication you had with your 13 underneath Employment Training Recruitment is Indigo
14 brother? 14 Bar & Grill on Exhibit 14. On Exhibit 13 it's
15 A Yes, I do. 15 Mannway Logistics underneath Employment Training
16 Q Right. And that's also your brother was 16 Recruitment.
17 part of the e-mail chain with respect to an ad placed 17 And then underneath Mannway Logistics on
18 on craigslist for a position, correct? 18 Exhibit 13 is Mar-a-Lago Resort and Spa. And on
19 A He was on -- let me just check the dates, 19 Exhibit 14 is Gemma Catering/Wedding Receptions. So
20 then. 20 there is quite a few differences.
21 Q Sure. 21 Q Okay. Great. Do you have any idea when
22 A 1/20/2014, 1/21, so just within a day of 22 you sent out Defendant's Exhibit 13, or if you did,
23 each other, yes. 23 to an employer?
24 Q All right. And then the resume that's 24 A Unless you have something that's attached
25 attached is the address you were living at in 25 to it, I can't be sure that I did.
Page 70 Page 72
1 January -- 1 Q Okay. Is the content in Defendant's
2 A Yes. 2 Exhibit 14, that you believe you sent out to an
3 Q -- of 2014, correct? 3 employer, correct?
4 A Correct. 4 A Unfortunately, I have to tell you that
5 Q All right. So you believe you created the 5 they are not correct. Through my experience I was in
6 resume that's attached to Defendant's Exhibit 14, 6 the mind-set that I was unemployable. I had been
7 correct? 7 abused for many years and I was told by a job agency
8 A Correct. 8 that I need to show that I've consistently worked at
9 Q And you sent it out with respect to this 9 various places and given experience. So it's not
10 employment you saw on craigslist, correct? 10 something that I'm proud of, but I have had to plump
11 A Correct. 11 up my resumes to make it look as though I could be
12 Q And you are the one who put into this 12 employed.
13 document the contents of the resume, right? 13 Q What do you mean by plump up your resume?
14 A Yes. 14 A Well, I couldn't -- I didn't feel that I
15 Q All right. 15 could go to an employer and tell them that I had
16 MR. EDWARDS: We're talking about the 16 held, you know, one job in the last 10 to 12 years
17 resume that's attached to Exhibit 14, right? 17 and before that I was trafficked for the purpose of
18 MS. MENNINGER: We are. 18 sex. And that's definitely something you don't want
19 MR. EDWARDS: Okay. Got it. 19 to put down on your resume, which makes you quite
20 MS. MENNINGER: Thank you for clarifying. 20 highly unemployable.
21 MR. EDWARDS: Got it. 21 So I did add places in, such as Indigo Bar
22 MS. MENNINGER: Although, I don't know 22 & Grill, Calmao Flamenco Bar & Restaurant.
23 there are any differences with Defendant's 23 Q Wait, wait. Which one?
24 Exhibit 13. 24 A On Exhibit 14.
25 Q (BY MS. MENNINGER) But just to be safe, 25 Q Um-hum.

Agren Blando
Document & Video,
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Page 73 Page 75
1 A Underneath Experience, the dates are all 1 A I never worked there.
2 incorrect, as well. It's just to show that I was 2 Q The description that you typed out about
3 consistently working, which I was not. And I needed 3 the things that you did at that Indigo Bar & Grill is
4 a job to help my family. I've got a family of five. 4 made up, correct?
5 So like I said, it's not something proud that I had 5 A Well, it's -- it's generally what you
6 to do, but I felt it was the only way that I could 6 would do if you were a server or a waitress. But,
7 actually get employed. 7 like I said, I did not work at Indigo Bar & Grill.
8 Q You lied on your resume? 8 Q So when you represented to an employer
9 A I made it look as though I had 9 that you were applying for a job that you had done
10 continuously worked throughout the years so that way 10 these things, you had not actually done these things
11 an employer would see me as a potential candidate. 11 at Indigo Bar & Grill, correct?
12 Q Okay. Well, let's start with Employment 12 A Not at Indigo Bar & Grill, no.
13 Training and Recruitment, ET Australia. 13 Q All right. Can you read the first
14 Did you work at that place of employment? 14 sentence of your job description?
15 A I did work there. 15 A For Indigo Bar & Grill?
16 Q What dates did you actually work there? 16 Q Right.
17 A I know I finished working for -- we call 17 A At this restaurant located inside of an
18 it ET Australia, so if you don't mind me abbreviating 18 RSL, we were never slow.
19 it. 19 Q Okay. So when you said, "We were never
20 Q However you want. 20 slow," you just made that up, correct?
21 A I know I finished there in January of 2006 21 MR. EDWARDS: Form.
22 right before my son was born, my first son was born. 22 A I tried to give as much information to my
23 And I believe I worked there for a year, I believe 23 potential employer to show that I could handle a
24 so. It might have been a little bit over a year, but 24 large amount of pressure and guests. So, yes, I put
25 just around a year. 25 that in there.
Page 74 Page 76
1 Q All right. So you worked at a place for 1 Q (BY MS. MENNINGER) But you represented
2 about a year. And on your resume you typed that you 2 you were there working as a server or waitress and
3 worked there for nine years, correct? 3 that we were never slow. That is not true, correct?
4 A Correct. 4 A Well, I never worked there, so it's --
5 Q And you did that, correct? 5 again, I was very highly unemployable, given my past.
6 A I did. 6 So I did whatever I could to make it look as though
7 Q Nobody else typed that for you? 7 my potential employer could hire me.
8 A No, I did it myself. 8 Q Okay. You described your duties that were
9 Q All right. And the next employment you 9 not -- those were fictional duties, correct?
10 list here -- well, is your job description accurate? 10 A They were duties that a waitress and a
11 A Yes, that is actually accurate. 11 server would do.
12 Q Okay. And everything in there is what you 12 Q But you did not do at Indigo Bar --
13 actually did? 13 A But I did not do them at Indigo Bar &
14 A Yes, for ET Australia. 14 Grill.
15 Q Okay. Indigo Bar & Grill, did you type 15 Q Okay. You described your energetic
16 that in? 16 service and your service with a smile to the guests.
17 A I did type that in. 17 That was not true, correct?
18 Q And did you actually work at Indigo Bar & 18 A Everything in Indigo Bar & Grill is not
19 Grill? 19 correct.
20 A No, I did not. 20 Q And you created that entire description,
21 Q All right. So the dates that you put on 21 correct?
22 your resume are not true, correct? 22 A For the sole purpose of being able to
23 A That's correct. 23 obtain employment, yes.
24 Q The title of your job at that place was 24 Q To get money?
25 not correct; you didn't work there, right? 25 MR. EDWARDS: Form.

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Page 77 Page 79
1 A To make a wage for my family. 1 Q And after you moved to Australia, which
2 Q (BY MS. MENNINGER) All right. The next 2 was what year?
3 job, Gemma Catering and Wedding Receptions, did it -- 3 A I moved to Australia at the end of 2002, I
4 is that a job that you actually held? 4 believe.
5 A I did actually work there. I don't know 5 Q All right. Do you recall going to work
6 the dates, but I was a server, waitress and 6 shortly after you got to Australia?
7 bartender. 7 A Yes.
8 Q March of 2003 to April 2004, is that about 8 Q How --
9 when you worked there? 9 A I had to obtain my -- my ability to work
10 A It could be very close to it. I'm not too 10 there. So I think that took a couple months. You
11 sure. 11 can get a temporary visa that allows you to work
12 Q You're not sure? 12 while you're waiting for your permanent resident
13 A No, I'm not sure. 13 status, and that's what we did.
14 Q Did you have children -- had you already 14 Q All right. Were you able to apply for
15 had children at the time you worked there? 15 that temporary job permission before you actually got
16 A No, I do not believe I did. I became a 16 married in Australia?
17 stay-at-home mom when I had my first child. 17 A I got married in Aus -- we were married in
18 Q And what year was that? 18 Thailand, really, but we made it official in January
19 A 2006. 19 of 2003. And within a couple of weeks, I was granted
20 Q Okay. So you believe you worked at Gemma 20 the permission to work in Australia legally.
21 Catering and Wedding Receptions before 2006? 21 Q Okay. So to the best of your
22 A I believe so. 22 recollection, you got permission to work in Australia
23 Q And other than that, you can't recall what 23 sometime in the spring of 2003?
24 dates you worked there? 24 MR. EDWARDS: Form.
25 A I'm sorry, I couldn't help, no. 25 A That's actually summer over there.
Page 78 Page 80
1 Q All right. And then what were your 1 Q (BY MS. MENNINGER) Fair enough. The
2 actual -- is that your actual job that you had there? 2 first quarter of the year, calendar year --
3 A The description of it? 3 A Yes.
4 Q The title, server, waitress, bartender? 4 Q -- 2003?
5 A Yes. 5 A If we're going to be politically correct,
6 Q All right. Is the description accurate? 6 yes.
7 A To a T. 7 Q That's what you recall?
8 Q What's that? 8 A (Indicating.)
9 A To a T. 9 I'm sorry, yes.
10 Q Okay. The next job you list is Mannway 10 Q And is your description of Mannway
11 Logistics, Logistics Receptionist. 11 Logistics correct?
12 Is that a job you actually held? 12 A Yes.
13 A It is a job I held. 13 Q All right. And how long did you work
14 Q And when did you hold it? 14 there?
15 A Again, I'm very bad at dates. I'm not too 15 A I think that was less than a year that I
16 sure. 16 worked there. I would approximate about six, seven
17 Q All right. Approximately when did you 17 months.
18 have it? 18 Q Can you name one coworker you had or boss
19 A I don't want to speculate and give you the 19 or anybody else that worked there?
20 wrong answer, so I'm not too sure. 20 A I know her name started with an M, but I
21 Q Did you have children at the time you 21 can't remember. I remember what she looks like. I
22 worked there? 22 just don't remember her name.
23 A No. 23 Q Okay. And how much did you make there?
24 Q So before 2006? 24 A I don't remember the exact amount.
25 A Yes. 25 Approximately about $20 an hour, I think.

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Page 81 Page 83
1 Q And how many hours per week were you 1 A Before I worked at ET Australia, I was
2 working for that six months to a year? 2 actually a job seeker there. And a job seeker, I
3 A I believe that was full time. 3 don't know if you're familiar with the term.
4 Q And is full time the same in Australia? 4 Somebody who is looking for work and you
5 A Yeah it's a 40-hour week. 5 go to a job agency, and you go look on the computer.
6 Q Okay. 6 And you actually have somebody who helps you find
7 A Well, 38 because you get two hours of 7 employment. And they are the ones who recommend that
8 lunch, so, yes. 8 you show that you've continuously worked throughout
9 Q All right. Have you been in touch with 9 your years. They ended up really liking me, so
10 anyone from that employment in a while? 10 that's how I got the job there.
11 A No. 11 Q Okay. Was it a particular person there
12 Q All right. The next job listed there is 12 that gave you the advice to plump up your resume?
13 what? 13 A It would have been one of the counselors.
14 A Calmao Flamenco Bar & Restaurant. 14 Q Which one?
15 Q Is that someplace you actually worked? 15 A I don't know.
16 A No, it's not. 16 Q Okay. Do you remember the names of any of
17 Q Is that a place that actually exists? 17 the counselors?
18 A I don't really know. 18 A I only remember the name of one of the
19 Q All right. 19 girls I worked with, but I don't remember -- I don't
20 A I mean, I think I looked on the Internet 20 remember anyone else's name.
21 and found something similar to what the description I 21 Q When did you first become a job seeker at
22 was needing to fill, and that was it. 22 ET Australia?
23 Q Okay. So when you were creating this 23 A Well, if I finished there in 2006 and I
24 document in 2013/2014, right, that's when you had the 24 worked there for approximately a year, it would have
25 Titusville address? 25 been 2005 -- late 2004, 2005. I'm not too sure.
Page 82 Page 84
1 A Yes. 1 Q Okay. So you were a job seeker there
2 Q All right. You went on the Internet and 2 first and then got employment there, right?
3 you searched for a place that would be like the job 3 A Yes.
4 you were looking for? 4 Q Okay. So the advice to plump up your
5 A Correct. 5 resume was while you were seeking a job or while you
6 Q And you found the name of an actual place, 6 were employed there?
7 Calmao Flamenco Bar & Restaurant. 7 A While I was seeking a job.
8 Did I get that right? 8 Q All right. And you were assigned a
9 A I'm not 100 percent on that, but I think 9 counselor?
10 so. 10 A Yes.
11 Q Okay. And you did that in order to 11 Q One or more than one?
12 impress the employer you were applying for here in 12 A It changes on a daily basis. There's
13 the e-mail, correct? 13 somebody who comes into the office and they sit with
14 A Correct. 14 you and they help you with your resume. And then
15 Q All right. And you did that in order to 15 they help you go on the computer and look for open
16 get money from a job that you hoped to get from this 16 vacancies.
17 employer in the e-mail, correct? 17 Q So someone in approximately 2005 gave you
18 A I was hoping to gain employment. And not 18 the advice to plump up your resume. That's what
19 having much experience, I put in there that I had 19 you're saying?
20 experience. 20 A To make it look like I've continuously
21 Q Okay. And you said that you had been 21 worked, yes.
22 advised to plump up your resume by a job agency; is 22 Q Okay. So back to Calmao Flamenco Bar &
23 that right? 23 Restaurant, which is a place you found on the
24 A Yes. 24 Internet but did not actually work. Is that, the
25 Q What was the name of that job agency? 25 dates for your employment there, December 2001 to

Agren Blando
Document & Video,
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Page 85 Page 87
1 February 2003, not true, correct? 1 experience than you had had, correct; that's what you
2 A Obviously, yes. At that time I was -- 2 just said?
3 during 2001 I was with Jeffrey and Ghislaine being 3 A Correct, I mean given that my past had not
4 trafficked. 4 enabled me to be able to look for work or I wasn't
5 Q Um-hum. So you were not working at Calmao 5 able to put down what I actually had -- had to do in
6 Flamenco Bar -- 6 my past. So I made it look as though I was able to
7 A Obviously not, yes. 7 be employed.
8 Q And you said you got to Australia in 8 Q You did not have the past that you thought
9 late '02 and did not work there between late '02 and 9 the employer was looking for, right?
10 February of ' 03, correct? 10 A I couldn't put down on there that I was
11 A I've never worked at Calmao Flamenco Bar & 11 sex trafficked for a couple years and did not have
12 Grill, period. 12 the experience to be able to apply for jobs and
13 Q All right. And the job description that 13 provide for my family.
14 you crafted there is also fictional, correct? 14 So this is something that I said. Again,
15 A Yes. 15 I am not proud of, but I felt was necessary to do to
16 Q All right. And Mar-a-Lago Resort and Spa 16 be able to gain employment.
17 you put down as a place you had worked, correct? 17 Q All right. So you were applying for a job
18 A Correct. 18 at a restaurant, right?
19 Q And you typed in August 2000 to September 19 A At this -- according to the front e-mail,
20 2001, correct? 20 yes.
21 A Correct. 21 Q All right. And you did not put down Taco
22 Q And you created your job description 22 Bell on this resume, correct?
23 there, correct? 23 A No. The only jobs on here are the ones
24 A Correct. 24 that we have mentioned.
25 Q All right. And then turning to the last 25 Q Right. And so why did you choose August
Page 86 Page 88
1 page you have your education, correct? 1 of 2000 as your start date for Mar-a-Lago?
2 A Can I just make a statement to say that, 2 A It just looks as though I've given them a
3 again, with the Mar-a-Lago Resort and Spa, I did have 3 longstanding history of employment.
4 to add dates to make it look as though I had 4 Q You chose a month. Why did you choose
5 continuously worked. So those, again, are incorrect 5 that month?
6 dates. 6 A I chose months and dates for every single
7 Q But it is a date that you typed into a 7 position on that resume. There is no specific reason
8 resume in 2013 or 2014 -- 8 why I chose that month. It was just purely to show
9 A That is the date that -- 9 that I was continuously employed.
10 Q If you could just let me finish my 10 Q On the last page it has some education.
11 question. 11 Which part of that is untrue?
12 A Sure. 12 MR. EDWARDS: Object to the form.
13 Q That is a date that you typed into your 13 A I have received my business admin cert 3
14 resume in 2013 or 2014, correct? 14 from ET Australia. I've never held responsible
15 A That is the date that I did type in, but 15 service of alcohol and gambling.
16 those are incorrect dates. 16 Q (BY MS. MENNINGER) Do you understand that
17 Q All right. 17 to be a licensing of some sort or a class? Or what
18 A And, as well as the -- the position, 18 do you understand that --
19 organizing, making and canceling appointments for 19 A In Australia you have to have something
20 massage therapists. 20 called an RSA and RCG to be able to work as a
21 Q All right. 21 waitress or bartender or anything. And I didn't know
22 A I mean, I was their locker room attendant. 22 if it was the same out here in America. So I put
23 I just wanted it to sound like I had more 23 down that I had.
24 receptionist experience than I did. 24 I had taken a CPR and first aid. I don't
25 Q You wanted it to look like you had more 25 remember when, but it's not current.

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Page 89 Page 91
1 And I did go to Royal Palm Beach High 1 A I remember spending a birthday with them
2 School and I didn't put down a degree there or 2 on Jeffrey Epstein's island called Little Saint
3 anything. 3 Jeff's. I wouldn't say it was a party. It was just
4 Q So is it fair to say you never worked as a 4 Ghislaine, me, Jeffrey. I believe was
5 waitress in Australia. Is that what you just said? 5 there. I got some presents from them.
6 A I did work as a waitress at Gemma 6 Q What presents did you get?
7 Catering. 7 A Ghislaine gave me a whole bunch of makeup,
8 Q Oh, okay. 8 like boxes of different kinds of eye shadows and
9 A I don't believe I needed my RSA to work 9 lipsticks and just makeup altogether.
10 there. I'm not too sure. 10 Jeffrey gave me a bracelet and, I think
11 Q All right. And if I could just ask you 11 earrings.
12 one other question about Gemma Catering. In the last 12 Q What kind of earrings?
13 line of the job description it says: This job was a 13 A They were what I believed to be diamonds.
14 second job. I would work in the evenings and 14 I don't know what they exactly were. I think Jeffrey
15 weekends for saving extra cash. 15 was talking about, they could have been passed off as
16 What was it a second job to? 16 good knock-offs. But they appeared to be diamonds.
17 A If my time period is right, it would be my 17 Q Any other presents?
18 second job to Mannway Logistics because they were 18 A I remember the makeup and the jewelry. I
19 both -- Gemma Catering and Mannway Logistics were 19 don't remember much else.
20 both in Sydney, whereas ET Australia was on the 20 Q And that was your 17th birthday, you said?
21 central coast. 21 MR. EDWARDS: Form.
22 Q All right. ET Australia is on the central 22 A It's hard for me to really pinpoint
23 coast? 23 exactly which birthday it was.
24 A Correct. 24 Q (BY MS. MENNINGER) So it could have been
25 Q And Gemma and Mannway are in Sydney? 25 your 18th or your 19th?
Page 90 Page 92
1 A In Sydney, yeah. 1 A I don't want to lock down on which exact
2 Q All right. Got it. 2 birthday it could have been without knowing.
3 Do you know if those two organizations 3 Q You don't know which birthday it was; is
4 still exist? 4 that what you're saying?
5 A Mannway, I would definitely say, it's a -- 5 A The one that I'm specifically telling you
6 it's a large logistic company. I would say it still 6 about?
7 does exist. 7 Q Right. You don't know which one?
8 Gemma Catering, I'm not too sure if that 8 A No.
9 exists anymore or not. 9 Q All right. Do you remember spending more
10 Q Okay. All right. So did you spend your 10 than one birthday with Jeffrey Epstein and Ghislaine
11 16th birthday with Ghislaine Maxwell and Jeffrey 11 Maxwell?
12 Epstein? 12 A Yes.
13 A No. I was 16 when I met them, now that I 13 Q Okay. Tell me about the other ones that
14 know the correct dates. So I would have spent my 14 you remember.
15 17th birthday with them. 15 A Well, I know my 19th birthday. I can't
16 Q So when you represented that you spent 16 remember, really, my 18th birthday. But my 19th
17 your 16th birthday with Ghislaine Maxwell and Jeffrey 17 birthday we celebrated it early, earlier than my
18 Epstein, that was not true, correct? 18 actual date of birth. And that's when he surprised
19 A At my ability at the time, that's what I 19 me with tickets to Thailand.
20 believed to be true. It wasn't until I found the 20 Q What do you mean he surprised you with
21 Mar-a-Lago records stating the year 2000. Me being 21 tickets to Thailand?
22 born in 1983 would make me turning 17 that year. 22 A He told me that the tickets for Thailand
23 Q So please describe for me your 17th 23 were for my birthday.
24 birthday that you claim you spent with Ghislaine 24 Q Did he hand you something that looked like
25 Maxwell and Jeffrey Epstein. 25 a ticket to Thailand? What do you mean?

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1 A He didn't hand me the tickets at that 1 shortly before my birthday, but not my birthday.
2 time, but he told me that he had booked me in for 2 Q (BY MS. MENNINGER) Okay. And he told you
3 massage training at an institute in Chiang Mai. 3 he had booked you tickets to go to Thailand, right?
4 Q And he told you he had booked you tickets 4 A Correct.
5 to a massage training in Chiang Mai, Thailand 5 Q All right. So you remember one birthday
6 sometime before your actual 19th birthday? 6 at which you received makeup, bracelet and earrings
7 MR. EDWARDS: Form. 7 and one birthday at which you received tickets to
8 Q (BY MS. MENNINGER) Did I get that right? 8 Thailand.
9 A Yes. 9 Do you remember any other birthdays that
10 Q Okay. Did he hand you -- 10 you spent with Jeffrey Epstein and/or Ghislaine
11 A Excuse me. 11 Maxwell?
12 Q -- hand you anything at that time? 12 A I'm sure there is, but I honestly can't
13 A No, I don't think so. 13 remember what I did for my 18th birthday.
14 Q And where were you located when he told 14 Q Okay. Well, I'm sorry, did you know for
15 you this about the Thailand massage training? 15 sure that the bracelet, earrings and makeup were from
16 A Jeffrey, Ghislaine and I had just gone 16 your 17th birthday, or do you know?
17 scuba -- not scuba diving, not with the big tanks, 17 A I don't know.
18 but snorkeling with just the mask and the two-piece, 18 Q But you know they were not for your
19 and on Jeffrey's island, by the way. 19 16th birthday, right?
20 And we had gone out for a while. And we 20 A Correct.
21 had come back. And he's got a pier where it's got a 21 Q All right. If I could have you go back to
22 ladder and you climb up. And we were wearing wet 22 Defendant's Exhibit 1, I think.
23 suits. So we were taking off our flippers and our 23 A Defendant's, sorry, Exhibit 1?
24 wet suits and all of our gear. 24 Q Um-hum. Page 9, either at the bottom or
25 And they said they wanted to sit down and 25 in the upper right-hand corner.
Page 94 Page 96
1 talk to me, just the three of us. And he -- first, 1 Do you see that page?
2 he told me about the -- 2 A Page 9 of 27, yes.
3 Q If I could just stop you. I think I asked 3 Q All right. And paragraph 23, do you see
4 where were you -- 4 that paragraph?
5 A Oh, I'm sorry. 5 A I see the paragraph.
6 Q -- when you had this conversation about 6 Q All right.
7 the -- 7 A I was just going to read it over quickly.
8 A Just the island. I'm just trying to 8 Q By all means.
9 describe the instance that he gave it to me. 9 A I've read it.
10 Q Oh, okay. 10 Q And the sentence, Defendant and
11 A It was on the island, on the pier in the 11 Ms. Maxwell acknowledged and celebrated plaintiff's
12 Caribbean. 12 16th birthday, is not a true statement, correct?
13 Q Okay. And it was sometime before your 13 A Only upon learning about the fact that I
14 19th birthday? 14 just found out my records. I assumed at the time it
15 A Correct. 15 was my 16th birthday. But now we know different.
16 Q How much time before? 16 Q You admit, as you sit here today, that
17 A I don't know. A couple -- six weeks, a 17 defendant and Ms. Maxwell did not celebrate your 16th
18 couple of months. I don't know. Close to my 18 birthday with you, correct?
19 birthday. It was my birthday present, that's what he 19 A Correct, based upon the records.
20 told me. 20 Q Which you don't know when you saw?
21 Q Okay. So you don't know when you had this 21 A I know it was, you know, it wasn't -- it
22 conversation? 22 wasn't a year ago, but it wasn't that long ago
23 MR. EDWARDS: Form. 23 either. So I'm not too sure. I can't tell you the
24 A I mean, I -- no, I didn't record the time 24 date that I actually saw them.
25 and the date, so I can only speculate. It was 25 Q All right. Last year you lived in

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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 Q 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 Q 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 than 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 I will --
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 I can 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 All right. 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

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1 mic higher up on your jacket, please? 1 If you remember the answer, please tell
2 THE DEPONENT: Sure. 2 her the answer.
3 THE VIDEOGRAPHER: Thank you. 3 A I don't know the answer, where I spent my
4 THE DEPONENT: Tell me if that's okay. 4 sweet 16th birthday.
5 Better? 5 Q (BY MS. MENNINGER) Do you know who you
6 A Okay. Page 40? 6 were with on your sweet 16th birthday?
7 Q (BY MS. MENNINGER) Right. Do you see the 7 A No, I don't.
8 first full paragraph on that page? 8 Q Do you know where you lived on your sweet
9 A I do. 9 16th birthday?
10 Q The first line begins: I spent my sweet 10 A No, I don't.
11 16th birthday on his island in the Caribbean next to 11 Q Were you living with your parents on your
12 Little (sic) St. James Isle. He liked to call it 12 sweet 16th birthday?
13 Little St. Jeff's. His ego was enormous as his 13 A I don't know.
14 appetite for fornicating. 14 Q Were you living with on your sweet
15 Do you see that sentence? 15 16th birthday?
16 A I do. 16 A I don't know. I was a runaway a lot. I
17 Q That is not true, correct? You were not 17 don't know where I lived at the time.
18 spending your sweet 16th birthday on Little St. James 18 Q Okay. Were you working at Taco Bell on
19 Isle, correct? 19 your sweet 16th birthday?
20 A Based on my knowledge at the time that I 20 A I don't think so. I don't know.
21 wrote this manuscript, I thought I did spend my 16th 21 Q Were you working at Publix on your sweet
22 birthday there. And so I put it down in there as 22 16th birthday?
23 that. Now I know that it wasn't my 16th birthday. 23 A I don't know.
24 Q Or your sweet 16th birthday? 24 Q Were you working at an aviary on your
25 A Well, we -- 25 sweet 16th birthday?
Page 102 Page 104

1 MR. EDWARDS: Object to the form. 1 A Again, I don't know.
2 Harassing. 2 Q Do you recall any present you actually got
3 Q (BY MS. MENNINGER) Was it your sweet 16th 3 on your sweet 16th birthday?
4 birthday? 4 A No, I don't. I don't know where I spent
5 A Is it not custom to call your 16th 5 it, who I spent it with or what I got. I'm sorry.
6 birthday sweet? Have you never heard that saying 6 Q How long did you work at Mar-a-Lago?
7 before? 7 A Best of my recollection, it was a summer
8 Q Was it your sweet 16th birthday, 8 job. I believe I started in June. And I think I
9 Ms. Giuffre? 9 only worked there approximately two weeks, two, three
10 A As we -- 10 weeks.
11 MR. EDWARDS: She's answered the question. 11 Q How many hours a week did you work?
12 It's been asked and answered. 12 A I want to say it was a -- I want to say
13 MS. MENNINGER: She asked me a question, 13 it's a full-time job.
14 actually. You're not testifying here. 14 Q Do you recall it being a full-time job?
15 Q (BY MS. MENNINGER) Was it your sweet 16th 15 A It was a summer job, but just thinking
16 birthday? 16 back, my dad used to bring me in and bring me home.
17 A As I thought, in the manuscript when I 17 So he worked full time, all day. So -- and I didn't
18 wrote it, I thought it was my sweet 16th birthday. 18 lounge around Mar-a-Lago so, yes, I think it would
19 Q Okay. Now that you know it wasn't, where 19 have been a full-time job.
20 did you spend your sweet 16th birthday? 20 Q And how much did you make per hour?
21 A Well, I don't know. 21 A Approximately, I think I remember making
22 Q Well, just give us your best guess. 22 $9 an hour.
23 MR. EDWARDS: Objection. And she's not 23 Q The bracelet and earrings you got for your
24 going to guess today. She's going to tell you the 24 birthday, some birthday, on Little -- or where was
25 answers as she remembers them. 25 that birthday party, at Little St. James?

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1 MR. EDWARDS: Object to the form. 1 Q Well, all right. We'll come back to that
2 Q (BY MS. MENNINGER) Where was it? 2 in a minute. But the apartment that you left in 2002
3 A At Little Saint Jeff's. 3 was the one in Royal Palm Beach that you lived at
4 Q Okay. Where are those bracelet and 4 originally with and then after breaking up
5 earrings now? 5 with lived there? That's the one we're
6 A I left everything behind me when I went to 6 talking about?
7 Thailand. 7 A Correct.
8 Q Where did you leave them, exactly? 8 Q That's the apartment we're talking about?
9 A I had a storage facility and my apartment 9 A That's not the one that --
10 that I lived in. 10 Q Okay.
11 Q So where were they, in the storage 11 A Sorry. I'm confused. Could you please
12 facility or in the apartment? 12 reask the question?
13 A Most likely in the apartment. 13 Q All right. I asked you where you left
14 Q Okay. What apartment was that? 14 your bracelet or earrings. You think you --
15 A Royal Palm Beach. I don't know the 15 A Okay, yes.
16 address, I'm sorry. 16 Q -- left them in an apartment, correct?
17
18
19
20
21
Q
A
Q
A
You don't know the address at all?
Not at all.
Okay. Where was it roughly located in
Royal Palm Beach?
I don't know. It's been a long time since
17
18
19
20
21
A
first one. The one where
Q
A
-
Okay. Yes. Yeah, not the one -- not the
eventually moved into.
That's the apartment you left the bracelet
and earrings at?
I believe so, yes.
22 I've been back to Royal Palm. I don't remember 22 Q So when you were working at Mar-a-Lago,
23 street names or anything. 23 you rode with your father every day?
24 Q Did it have one or two bedrooms? 24 A Yes.
25 A It was two bedrooms. 25 Q What car did he drive at the time?
Page 106 Page 108

1 Q Was it on the first or second floor? 1 A I don't know.
2 A The second floor. 2 Q Okay. Did you have a vehicle of your own
---
3 Q Who lived there with you? 3 at the time?
4 A first lived there with me. 4 A No.
5 and I broke up shortly after living there. 5 Q Did you have a driver's license at the
6 And lived there with me. 6 time?
7 Q Okay. And that's the apartment that you 7 A Yes. I got my permit when I was 15 and my
8 left when you went to Thailand? 8 driver's license when I was 16.
9 A Yes. 9 Q Okay. And how were you paid, by cash or
10
11
12
13
14
-Q
with
A
Did you live at more than one apartment
When I was a runaway, he let me stay at

his apartment.
Q Was that a different apartment?
10
11
12
13
14
check or some other method?
A
Q
A
I don't remember.
Did you have a bank account at that time?
I don't think I've ever had a bank
account -- well, up until recently, living here. I
15
16
17
18
Q
A Yes.
All right. So you lived at
apartment when you were a runaway?
A Correct.
- 15
16
17
18
don't remember having a bank account.
Q So you believe you got paid by unknown
means and you did not deposit it into a bank?
A Correct.
--
19 Q And did you live anywhere else other than 19 Q What was your uniform when you worked
20 those two apartments with 20 there?
21 A We stayed at parents' house, I 21 A At Mar-a-Lago?
22 think for a few weeks before the apartment. 22 Q Right.
23
24
25
Q
A
-
Okay. The apartment that you rented?
The apartment that
think I was too young to go on a lease.
rented. I
23
24
25
A It was a white miniskirt with a little
white polo top with the emblem of Mar-a-Lago on it.
Q
VIRGINIA GIUFFRE 5/3/2016

Did they give you more than one?
27 (105 - 108)
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1 A I don't know, maybe. 1 masseuses had their own uniforms.
2 Q Did you wear it to and from work every 2 Q What did the masseuses' uniform look like?
3 day? 3 A I don't remember.
4 A Yes. 4 Q No recollection at all?
5 Q Did you get new ones when you arrived that 5 A None whatsoever.
6 were clean or did you launder them at home? 6 Q Color?
7 A I would have had to wash them when I got 7 A No, sorry. I remember mine.
8 home, I suppose. 8 Q Okay. How did it come to pass that you
9 Q And you think you had more than one or you 9 were no longer working at Mar-a-Lago in two to three
10 don't recall? 10 weeks?
11 A I don't recall. 11 A I was approached by Ghislaine Maxwell.
12 Q All right. Was that something you 12 Q Okay. And how long had you been working
13 purchased or did they give it to you? 13 at Mar-a-Lago when you were approached by Ghislaine
14 A They gave it to me. 14 Maxwell?
15 Q And who else was wearing that uniform? 15 A Roughly two to three weeks.
16 A The other locker -- the lady that did the 16 Q Okay. Where in the spa were you when you
17 front desk next to the locker rooms. 17 were approached by Ghislaine Maxwell?
18 Q She had the same one? 18 A Just outside the locker room, sitting
19 A Yes. 19 where the other girl that works there usually sits.
20 Q Was that Adriana? 20 She was away from the desk. I was reading a book on
21 A I don't think Adriana wore a uniform. I 21 massage therapy.
22 think she just dressed professional. 22 Q Was that indoors or outdoors?
23 Q Okay. And what other employees did you 23 A Outdoors.
24 see there at the spa at the time when you worked 24 Q Okay. And what -- were you in the sun or
25 there? 25 in the shade?
Page 110 Page 112

1 A There were -- well, this is in the massage 1 A In the shade underneath a -- I don't know
2 area and there's also like a fitness area. So 2 what you'd like to call it, but, you know, underneath
3 there's spa and fitness. So there would be the 3 the complex, the building.
4 masseuses and then there would be the trainers. And 4 Q All right. And what was Ghislaine Maxwell
5 that was just located in that one area away from the 5 wearing when she approached you?
6 main house and stuff. 6 A I don't remember what she was wearing.
7 Q And is that the area in which you worked? 7 Q Any recollection, color of clothing or
8 A Yes. 8 anything?
9 Q In the spa area or the fitness area? 9 A No.
10 A The spa and the fitness area were in the 10 Q Okay. Any details about her? Was she
11 same complex. 11 carrying a purse or anything?
12 Q Okay. What did the other people who 12 A No. She looked like, from my memory, she
13 worked in the spa area wear? 13 looked like she was either there for a massage or
14 A I don't remember what they wore. 14 fitness. I remember she had a British accent. She
15 Q All right. And what did the people in the 15 was very interested in the book that I was reading.
16 fitness area wear? 16 I mean, we can get into some more details
17 A I don't remember. I know it was -- we had 17 later if you'd like, but I don't remember any more
18 our own uniforms. Everyone else had their own. 18 about what she was wearing that day.
19 Q Who is we? 19 Q Did you have a cell phone at that time?
20 A Well, the girls that worked in the meet 20 A No.
21 and greet area. Me and the other girl with the curly 21 Q Where were you living at that time?
22 hair I told you about -- 22 A At my parents'.
23 Q Um-hum. 23 Q And who else was living there with you at
24 A -- had our own uniforms. And then the 24 the time?
25 fitness people had their own uniforms. And the 25 A My mother and my dad and my brother.

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1
2
3
4
5
Q
A
Q
A
Q
-
Which brother?
What about your other brother?

I think he had moved out by then.
What forms of communication did you have?
1
2
3
4
5
there's one in Royal Palm and Wellington, and I used
to go to both.
Q
A
Q
Did you have a card for both?
Did I have a card?
A library card?
6 Just a home phone number, or what? 6 A Yeah.
7 A Yeah, there was a home phone. 7 Q For both places?
8 Q When do you recall ever getting a cell 8 A To be able to rent out a book, yeah.
9 phone? 9 Q Okay. So the best of your recollection is
10 A The first cell phone I ever got was the 10 you used one of your library cards at one of those
11 one that Ghislaine gave to me. 11 two libraries to check out a book on massage and
12 Q So you never had -- your parents, did they 12 anatomy?
13 have ones when you were working at Mar-a-Lago? 13 A Correct.
14 A No, my dad used to -- like, we had phones 14 Q And when did you do that relative to
15 in the spa and maintenance area and so on, so forth. 15 starting at Mar-a-Lago?
16 And you could, so to speak, page people from around 16 A Probably within the first week. I mean, I
17 the courts. 17 saw what the massage therapists got to do. I mean,
18 Q Okay. So tell me what you recall of the 18 their jobs were so relaxing. The music, like the
19 first conversation that you had with Ghislaine 19 atmosphere, they always had happy clients. It just
20 Maxwell. 20 seems like an ideal job.
21 A I'm sitting there reading my book about 21 Q And so you were spurred to go to the
22 massage therapy, as I'm working in the spa. And I'm 22 library and check out a book?
23 getting my GE -- well, I was in the process of 23 A Well, I had been talking with the other
24 getting my GED before I went to my summer job. I 24 massage therapists and they're the ones who first
25 decided that I would like to become a massage 25 intrigued me about what they do. And, you know, I
Page 114 Page 116

1 therapist one day. And the body really intrigued me, 1 wanted to aim for something higher than being a
2 you know, reading this massage was a lot about 2 locker room attendant one day. And. Yeah.
3 anatomy, blood flow. Everything to do with, you 3 Q What was the name of the massage therapist
4 know, touching somebody somewhere and then triggering 4 that you were speaking with?
5 a result somewhere else. I just was very intrigued 5 A Oh, I have no idea.
6 by the whole anatomy thing. 6 Q Can you give me any physical description
7 She came up, Ghislaine, sorry. Ghislaine 7 of any of them?
8 came up and approached me at the desk that I was 8 A Um, there was one who had blonde short
9 sitting at. And my book was like this (indicating) 9 hair. There was -- I would say there's probably
10 and she said, Oh, you're reading a book about 10 about four massage therapists that work in there.
11 massage. You want to do massage? And I told her, 11 So, I mean, I don't remember all of them.
12 Yes, you know, I'm very interested in it. One day I 12 Q Okay. What time of day was it?
13 would like to become a masseuse. 13 MR. EDWARDS: Object to the form.
14 Q All right. Where did you get the book on 14 A Afternoon.
15 massage? 15 Q (BY MS. MENNINGER) How late?
16 A Maybe the library. 16 A Anywhere between 2 to 4.
17 Q Maybe or do you recall? 17 Q And what time did you get off of work?
18 A I don't think I purchased it. So I'd have 18 A I believe I got off at 5.
19 to say the library. 19 Q And what was the rest of your conversation
20 Q Okay. What library was that? 20 with Ms. Maxwell?
21 A Whichever library was close to my house. 21 I'm sorry, I don't think you finished.
22 Q Do you remember a library being close to 22 A Thank you. Well, she noticed I was
23 your house? 23 reading the massage book. And I started to have
24 A There's one in Wellington that I used to 24 chitchat with her just about, you know, the body and
25 go to. Oh, no, there's one in Royal Palm. Yeah, 25 the anatomy and how I was interested in it. And she

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1 told me that she knew somebody who was looking for a 1 A cell phone or a home phone, or do you have any
2 traveling masseuse. 2 idea?
3 And I said, Well, I don't have any 3 A I have no idea. Ghislaine answered. So
4 accreditations. This is the first book I've ever 4 if it was a home phone, the butlers probably would
5 read. She goes, That's okay. I know somebody. We 5 have answered. So most likely it was her cell phone.
6 can train you. We can get you educated. You know, 6 Q All right. And what happened when you got
7 we can help you along the way if you pass the 7 off of work?
8 interview. 8 A My dad drove me to El Brillo Way.
9 If the guy likes you, then, you know, it 9 Q Um-hum.
10 will work out for you. You'll travel. You'll make 10 A We arrived at a very large pink mansion.
11 good money. You'll be educated, and you'll finally 11 And we knocked on the door. My dad got out of the
12 get accredited one day. 12 car and we knocked on the door.
13 Q Okay. 13 Q Do you recall which car this was?
14 A She finished off by, you know, giving me 14 A I don't know what he was driving at the
15 her number. And I told her I'd have to ask my dad. 15 time. My dad always drives trucks. So it would have
16 And I called my dad. I ran over, actually, to see my 16 been some kind of truck.
17 dad, talked to him. He said it would be okay. I 17 Q But you don't know which kind?
18 used the phone from Mar-a-Lago to call her and tell 18 A I don't know if it was a Ford or a Dodge
19 her that I was allowed to come over. 19 or --
20 And she said, Great. Meet me here at -- I 20 Q What kind of car does your mom drive?
21 don't remember the exact address, but it was 21 A Right now?
22 El Brillo Way in Palm Beach -- after you get off. 22 Q No, in 2000.
23 And my dad drove me. 23 A Oh, I have no idea. I don't remember.
24 Q Did you write down her add -- the address 24 They change cars quite often. They like getting
25 that she gave? 25 different cars.
Page 118 Page 120

1 A Yes. 1 Q When did you get your first car?
2 Q Did you write down her phone number? 2 A After my trip to London to meet Prince
3 A Yes. 3 Andrew.
4 Q So did you go run and talk to your dad 4 Q Okay. What kind of car did you get?
5 while she was still there? 5 A A Dodge Dakota.
6 A No, I believe she left. And she told me 6 Q And did you purchase that yourself?
7 to ask my dad and then to give her a phone call. 7 A Yes, I did.
8 Q Okay. Did she ask you your age when she 8 Q And how much did it cost?
9 had that conversation with you? 9 A I don't remember off the top of my head
10 A No, she did not. 10 how much it cost.
11 Q Did you tell her your age? 11 Q Who did you buy it from?
12 A No, I did not. 12 A My dad helped me bargain with it. I don't
13 Q And so somewhere you wrote down a phone 13 remember where we bought it from.
14 number to call her back at? 14 Q And was the title put in your name or your
15 A Um-hum. 15 dad's name?
16 Q All right. And where did you write that 16 A I think the title was put in my name. I
17 down? 17 think. I mean, my dad was with me. I've never
18 A Probably just a piece of paper lying 18 registered a car or anything like that before. So --
19 around the desk. 19 Q So that was your first time?
20 Q Okay. But you don't remember? 20 A Yes.
21 A I mean, no, I don't have that piece of 21 Q Memorable, right?
22 paper anymore, so no. 22 A Yes.
23 Q Okay. And did you write down an address? 23 Q When you got there, a butler or someone
24 A Yes. 24 answered the door, is that what you said?
25 Q And what number do you think you called? 25 A No, Ghislaine answered the door.

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1 Q Okay. And then what happened? 1 Q All right. Where did you see Mary?
2 A She shook hands with my dad. Like, she 2 A The same place, kitchen.
3 briefly opened the door. She stepped out, shook 3 Q Were they talking to one another?
4 hands with my dad. Told her (sic) she'd look after 4 A No. Mary was doing something with the
5 me and she'd make sure I get a ride home. And just 5 dishes. They were always either cleaning up or doing
6 very briefly, that was it. And my dad left, and I 6 stuff, so --
7 went inside with Ghislaine. 7 Q And you saw them in the kitchen?
8 Q Did Ghislaine and your dad have any 8 A In the kitchen area. I mean, you have to
9 discussion about what it was you were doing there, in 9 understand there's like three parts to that kitchen.
10 your presence? 10 So it's very large.
11 A You know, I can't recall exactly what was 11 Q All right. What part did you see John in?
12 said. But I had already told my dad what was -- what 12 A In the corner, left hand. And Mary was in
13 the interview was for. So -- 13 the same vicinity but not right next to him. They
14 Q What did you tell your dad? 14 weren't chatting.
15 A That a very nice lady approached me and 15 Q What is also contained in the corner, left
16 told me that she would offer me an education to 16 hand of the room?
17 become a massage therapist. And it was a great -- it 17 A There's like a -- like shelves with -- I
18 would be great experience for me to be able to get 18 don't know. Just shelves that I remember, you know,
19 educated and trained and eventually be accredited. 19 open door pantry stuff.
20 So he was very happy for me as well. 20 Q What was Ms. Maxwell wearing when you
21 Q You told him that outside of the presence 21 arrived at the home?
22 of Ghislaine? 22 A I don't remember what she was wearing.
23 A Yes, when I first ran to the tennis courts 23 Q The book that you were reading at the spa
24 where he was at. 24 that day, do you recall the name of it?
25 Q And then, in your presence at the home, 25 A No. I just know it was -- it said the
Page 122 Page 124

1 did your dad and Ms. Maxwell have any conversation -- 1 word massage on the front of it. I don't know the
2 further conversation about what you were doing there? 2 title or the author.
3 A I don't recall. I think they probably 3 Q Do you know the color of the book?
4 would have chatted for approximately -- maybe 30 4 A It was -- it was dark. It was a, like
5 seconds. It really wasn't a long chat. 5 plastic covering.
6 The things that stick out in my mind were, 6 Q All right. And how big was it, if you can
7 We will take good care of her and we'll be 7 just demonstrate for the video?
8 bringing -- we will make sure she gets a ride home. 8 A Smaller than that. Maybe -- I don't --
9 Q And how far away did you live? 9 maybe a little bit less than that.
10 A Approximately 30 minutes. 10 Q Can you hold it sideways for the video?
11 Q And that's with your parents' house, 11 A (Complied.)
12 right? 12 Q So you're saying the book size was a
13 A That was my parents' house. 13 little bit less than half of --
14 Q Did you see any other employees or any 14 A Right. I mean, the book was a little bit
15 other people inside the house on that day? 15 bigger. The pages were -- you know, this is very
16 A Yes. 16 small print. This is printed A4 longways, whereas, I
17 Q Who else did you see? 17 think. It wasn't A4 that way. I don't know. It was
18 A Juan Alessi. 18 just a book. And I don't know how many pages it had
19 Q Um-hum. 19 either. I mean, approximately, maybe 100 pages.
20 A And Maria. But Jeffrey and Ghislaine like 20 Q Okay. So maybe my question wasn't a very
21 to call them John and Mary. 21 good question.
22 Q Okay. Where did you see John? 22 How big was the outside of the book, not
23 A Downstairs after the whole ordeal. 23 the thickness, but the length and the width?
24 Q Um-hum. Which room? 24 A Maybe like here (indicating).
25 A The kitchen. 25 Q So a little bit bigger?

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1 A Longer than this, yeah. We're going to 1 A Yes.
2 fold it in half again, and then like that 2 Q Who else was at home when you got home?
3 (indicating). 3 A My mom, my dad and my brother.
4 Q So larger than an 8 and a half and 4 Q Which brother?
5 11 piece of paper? 5 A Sky.
6 MR. EDWARDS: Form. 6 Q And anyone else who was there at the time?
7 A I don't know what 8 and a half and 7 A I believe Michael might have been living
8 11 inches is. If this is 8 and a half and 11 inches, 8 with me at that time. So he might have been there.
9 then yes. It's (indicating). 9 Q Do you recall if he was there when you got
10 Q (BY MS. MENNINGER) So when you fold it in 10 home?
11 half, is that a little bit smaller, folded in half, 11 A I don't really remember. I remember what
12 than the book -- 12 I did when I got home, that I basically made a
13 A Yeah, if I were going to hold the book 13 beeline for the bathroom.
14 like this, if I were going to sit there and read the 14 Q Let me ask you a question. Michael was
15 book like this, in my mind it would be a little bit 15 living with you at that home, at your parents' home
16 bigger than what I'm holding right here. 16 at the time, is your best recollection today; is that
17 Q All right. So you're demonstrating the 17 right?
18 book as it's opened that way? 18 A That's my best recollection, yes.
19 A Yeah, let's just say I'm reading it like 19 Q When you say living with you, were you
20 this. 20 guys staying in the same room?
21 Q Okay. Got it. 21 A Yes.
22 MS. MENNINGER: I'm going to suggest we 22 Q Were you engaged at that time to him?
23 take a short break. We can -- 23 A That was a really weird relationship. He
24 MR. EDWARDS: Order -- 24 was a friend who looked after me, and he did propose
25 MS. MENNINGER: -- order lunch for you 25 to me and I did say yes. But my heart was never in
Page 126 Page 128

1 guys and then do a little bit more before the lunch 1 it.
2 gets here -- 2 He was somebody that helped me off the
3 MR. EDWARDS: Okay. 3 streets so I felt compelled to say yes to him.
4 MS. MENNINGER: -- if that works for 4 Q Okay. So when he proposed to you and you
5 everybody. 5 said yes, did that take place before you started
6 MR. EDWARDS: Yeah, that's great. 6 working at Mar-a-Lago or after you started working at
7 MS. MENNINGER: All right. Let's do that. 7 Mar-a-Lago?
8 THE VIDEOGRAPHER: We're off the record at 8 A Before.
9 11:38. 9 Q And so if he were living with your parents
10 (Recess taken from 11:38 a.m. to 10 at that time, you were living in the same room; is
11 11:57 a.m.) 11 that correct?
12 THE VIDEOGRAPHER: We're back on the 12 A I believe so.
13 record at 11:57. 13 Q And your parents understood him to be your
14 Q (BY MS. MENNINGER) How long were you at 14 fiance?
15 the El Brillo home on that first day you went? 15 A I don't think they agreed with it, but I
16 A Over two hours. 16 think they understood it as that. I mean --
17 Q Okay. And who took you home? 17 Q I mean, you communicated to them that he
18 A Juan Alessi. 18 had proposed and you had accepted?
19 Q And what car was he driving? 19 A Yeah, in not such a pretty way. I mean,
20 A I believe it was a black Suburban. 20 they obviously weren't very happy about it. And it
21 Q Did anyone else ride in the car with you? 21 wasn't my true intentions to ever marry him.
22 A Just Juan. 22 Q Okay.
23 Q What time approximately did you get home? 23 A But I did it to make him feel okay. I
24 A 8:30, approximately. 24 didn't want to be mean.
25 Q Was it dark? 25 Q What did your mom say about your

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1 engagement to 1 physical features of Ghislaine Maxwell?
2 A Oh, they never thought it was going to go 2 A I can tell you that she had very large
3 forward either. 3 natural breasts. I can tell you that her pubic hair
4 Q When you got home, you said you made a 4 was dark brown, nearly black. I don't remember any
5 beeline for the bathroom? 5 specific birthmarks or moles that I could point out
6 A Correct. 6 that would be relevant.
7 Q And what did you do in the bathroom? 7 Q Any scar?
8 A I showered. 8 A I don't remember any scars.
9 Q Okay. Did you have a conversation with 9 Q Any tattoos?
10 anyone prior to going to the bathroom? 10 A No tattoos.
11 A My mom came into the bathroom and -- and 11 Q When did you next go to the El Brillo
12 she, you know, she asked me how it went. And I told 12 house?
13 her I'd rather not talk about it. And she didn't 13 A I believe it would have been the next day.
14 push me any further for any more conversation. 14 Q You believe it would have been or was it?
15 Q Okay. And then she left the bathroom? 15 MR. EDWARDS: Form.
16 A She left the bathroom. 16 A I know that it was consecutive, that I
17 Q Did anyone overhear that conversation? 17 continued to go there after my first -- the first
18 A No, the door was closed. 18 time that the abuse took place there. It was
19 Q Was your dad at home? 19 consecutive that I was there, I believe, over the
20 A Yes. 20 next course of weeks.
21 Q Did you have a conversation with your dad 21 Q (BY MS. MENNINGER) What day of the week
22 that night? 22 was the first time you went?
23 A Not that I remember, no. 23 A I don't know.
24 Q And did you have any other conversation 24 Q Do you know whether you went the very next
25 with your mother that night? 25 day or not?
Page 130 Page 132

1 A No. 1 A I believe I did.
2 Q Did you have any conversation with your 2 Q All right. How did you get there the very
3 brother that night? 3 next day?
4 A No. He's -- he's five years younger than 4 MR. EDWARDS: Form.
5 me. It's not something I'd talk to him about. 5 A I believe my dad dropped me off again.
6 Q And did you have any conversation with 6 Q (BY MS. MENNINGER) When you say you
7 that night? 7 believe, do you recall him doing that or are you
8 A I could have. I don't remember having 8 guessing?
9 one, but I could have. 9 A I don't -- well, this is how I figure
10 Q Did you call any of your friends that 10 this. I don't remember Ghislaine picking me up from
11 night? 11 Mar-a-Lago. I didn't have my own car. So the only
12 A No. 12 way I could have really gotten there would have been
13 Q Who were your good friends at that time? 13 my dad picking me up -- I mean, sorry, dropping me
14 A (phonetic). That was 14 off.
15 really it. I didn't really have many friends. I 15 Q Do you have a distinct recollection of
16 kept to myself a lot. 16 your father dropping you off there more than one day
17
18
19
20
21
Q
A
Did you call
I don't think
- that night?
and I were -- we were
on and off friends from middle school. And no reason
on and off like we had an argument or something. We
just got out of touch.
17
18
19
20
21
in a row?
A
Q
A
Yes.
You do not recall the car he was driving?
Like I said, he always drove trucks.
That's as good as I can get.
22 Q Um-hum. 22 Q And so -- and you worked on weekends as
23 A So, no, at that time I don't think I was 23 well at Mar-a-Lago or no?
24 talking to him. 24 A No.
25 Q Are you aware of any distinguishing 25 Q So the second day would have had to be

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1 another weekday or was it on a weekend? 1 time.
2 MR. EDWARDS: Form. 2 Q So did you introduce yourself as Virginia
3 A I don't know. 3 or as Jenna?
4 Q (BY MS. MENNINGER) Do you know if you 4 A Most likely Jenna.
5 went after work at Mar-a-Lago? 5 Q Do you recall this or is this something
6 A Yes. 6 that you're guessing about?
7 Q So you went to work the very next day at 7 A Well, considering that everybody knew me
8 Mar-a-Lago? 8 as Jenna, I think I would have introduced myself as
9 A Yes. 9 Jenna.
10 Q Did you have a conversation with anyone at 10 Q You don't recall it?
11 Mar-a-Lago about the day before at El Brillo? 11 MR. EDWARDS: Form.
12 A No. 12 A I don't recall the exact answer to that,
13 Q You didn't talk to any of your coworkers 13 no, but just knowing I had everybody pretty much call
14 about it? 14 me Jenna.
15 A No. 15 Q (BY MS. MENNINGER) I'm just trying to
16 Q Who was your boss at the time? 16 make a clear record about what you do remember and
17 A No. 17 what you're guessing about. So when you say I think
18 Q Did you have a boss at the time? 18 I would have, it leads me to believe you don't recall
19 A I think Adriana or Adrienne. I don't 19 it.
20 remember the exact pronunciation of her name, but 20 If you mean something different by that --
21 it's along those lines. I believe she was my boss. 21 A I --
22 Q And you did not talk to her about it? 22 Q -- please feel free to clarify. I'm just
23 A No. 23 trying to explain to you what I'm asking.
24 Q You surmise that your father dropped you 24 A Yes. And I'm doing the very best that I
25 off because you can't think of another way you would 25 can tell you exactly what it is. But it's just hard
Page 134 Page 136

1 have gotten there, correct? 1 for me to remember so long ago. And knowing that I
2 A Correct. 2 introduced myself as Jenna to everybody leads me to
3 Q And when you came the second day, did your 3 assume that I would have introduced myself to them as
4 father come to the door? 4 Jenna as well.
5 A I don't think he came to the door that 5 Q All right. But if we were to speak to
6 time. I think I was just dropped off. 6 , she might have a different recollection,
7 Q All right. And what did you do when you 7 fair to say?
8 got there? 8 MR. EDWARDS: Form.
9 A Knocked on the door and -- 9 A She could.
10 Q Who answered the door? 10 Q (BY MS. MENNINGER) How is it that you
11 A Juan Alessi. 11 knew to come there on this second day?
12 Q Okay. Was anyone else there besides Juan 12 A I was asked to come back.
13 Alessi? 13 Q When were you asked to come back?
14 A Jeffrey, Ghislaine and . 14 A The day before, after the encounter they
15 Q Okay. And where did you see ? 15 told me to come back at the same time after work.
16 A She was downstairs. 16 Q Who is they?
17 Q Did you speak to her? 17 A Jeffrey and Ghislaine.
18 A Just introductions. 18 Q Okay. Did they both simultaneously say
19 Q Tell me what you mean by introductions. 19 that or did one of them say it?
20
21
22
23
24
A
Her name, she introduced herself as
-
My name is Virginia. Nice to meet you.
told me she was Ghislaine's personal assistant.

Q
time?
Did you call yourself Virginia at the
And she
20
21
22
23
24
A It was like a conversation that they both
had with me separately. Jeffrey told me upstairs
after the whole entire abuse had happened that he
really liked me and he'd like me to come back.
When I went downstairs --
25 A No, I think I've gone by Jenna for a long 25 Q Let me just stop you there. Did he say, I

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1 want you to come back tomorrow? 1 of girls. It was continuous.
2 A Yes. 2 Q It was continuous. Name one girl that
3 Q Okay. Did he tell you what time tomorrow 3 Ghislaine Maxwell had sex with in your presence.
4 he wanted you to come back? 4 A Emmy Taylor. I mean, that's a name that I
5 A No, he just said he wants me to come back 5 know well because Emmy was always around.
6 tomorrow. 6 I'm trying to think of her name, sorry.
7 Q Okay. And then you went downstairs and 7 Sarah. Her name used to be Sarah Kellen. I think
8 what happened? 8 she's changed it now that she's married.
9 A Ghislaine told me I did a really good job 9 (phonetic) -- I can't
10 and she wants me to come back tomorrow after work. 10 pronounce her last name properly, but it's around
11 Q That's what she said, I want you to come 11 those lines.
12 back tomorrow after work? 12 There were a lot of other girls that I
13 A Yes. 13 honestly can't remember their names. I'm sorry. I
14 Q You recall those words being used by her? 14 wish I could help out more because I really would
15 A Yes. 15 like to provide more witnesses for this, but I can't
16 Q Did you ask them for a ride to get there 16 remember a lot of girls' names.
17 the next day? 17 Q So those are the three names of females
18 A No. 18 that you observed Ghislaine Maxwell have sex with --
19 Q You just said, I'll come back tomorrow. 19 MR. EDWARDS: Object to the form.
20 A Yeah. I agreed to come back the next day. 20 Mischaracterizes testimony.
21 Q How did you agree? 21 Q (BY MS. MENNINGER) -- is that what I
22 A Verbally. 22 understand your answer to be?
23 Q Okay. Was anyone else present when 23 MR. EDWARDS: Objection. Mischaracterizes
24 Ghislaine said that to you and you responded, I'll 24 her testimony.
25 come back tomorrow? 25 A Those are -- those are some three of the
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1 A I believe Juan Alessi was pretty much 1 names that I know very well. Like I said, there was
2 within ear distance. 2 a lot more.
3 Q Could you see him? 3 Q (BY MS. MENNINGER) Okay. Do you know the
4 A Yes. 4 names of any other girl that you personally observed
5 Q Okay. 5 Ghislaine Maxwell have sex with?
6 A Like I said, in ear distance, when I mean 6 A Do you mind me taking a minute to just try
7 ear distance like hearing, in the hearing vicinity. 7 to reflect?
8 And it was in the same time that she was asking him 8 Q No.
9 to drop me off at home. 9 A Um, her name is on the tip of my tongue.
10 Q Okay. When you were driving home the 10 Her last name is I don't remember her
11 first night with Juan Alessi, did you have any 11 first name off the top of my head. I normally could
12 conversation with him? 12 remember it.
13 A No. I had told him my address. It was a 13 Q Okay.
14 very quiet ride. 14 A There's just a blur of so many girls.
15 Q Did you ride in the front or the back? 15 It's really hard for me to remember. And you have to
16 A The front. 16 understand we weren't introduced to each other on a
17 Q It is your contention that, Ghislaine 17 first name basis half the time. A lot of these girls
18 Maxwell had sex with underage girls virtually every 18 would come and go and you'd never see them again.
19 day when I was around her, correct? 19 So, no, it's very difficult for me to
20 A Yes. 20 pinpoint exactly who they were. But those four that
21 Q All right. With whom did Ghislaine 21 I've given you are 100 percent.
22 Maxwell have sex in your presence? 22 Q Okay. Did you observe Ghislaine Maxwell
23 A Well, there's a lot of girls that were 23 forcing any of those four girls to have sexual
24 involved. We weren't on a first name basis with each 24 contact with her?
25 other. I wouldn't be able to give you lists of names 25 MR. EDWARDS: Form.

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1 A I don't believe that any of the girls 1 Mischaracterizes her testimony.
2 involved were truly willing participants doing it out 2 You can answer.
3 of their own wanting. I believe we were all there 3 A You wouldn't want to piss us off. You
4 for one purpose, and that was to keep Jeffrey and 4 wouldn't want to piss me and Jeffrey off. I mean
5 Ghislaine happy and to do our jobs, which was giving 5 that's one way of saying it. Other than --
6 them erotic massages and keeping them pleased 6 Q (BY MS. MENNINGER) Did she say, I don't
7 sexually. 7 want -- you would not want to piss me off?
8 Q (BY MS. MENNINGER) Okay. Do you know 8 A Piss me off is probably my word, using
9 what the word force means, physical force? 9 piss, but it was along those lines. I don't remember
10 A If you mean like held down or a gun put to 10 the exact word that she used.
11 the head, then no. 11 Q And do you remember a specific occasion on
12 Q Okay. 12 which she said that to you?
13 A But force in a word -- like a way of 13 A I remember very early on.
14 coercion. There was definitely indirect threats that 14 Q Where were you?
15 you knew these people were powerful. They had a lot 15 A I believe it was during my, what I call
16 of contacts. They were very wealthy. They were 16 the training period with Jeffrey and Ghislaine.
17 people you did not want to cross lines with on a bad 17 Q Okay. And where were you?
18 way. 18 A For a specific -- and like I said, it
19 Q Okay. What threats did you hear Ghislaine 19 happened a lot. But for one specific, I remember
20 Maxwell state to you? 20 being out on the balcony in the house at El Brillo,
21 A Just the reminders of the prominent people 21 sitting outside with her. This is when I thought
22 that she knows personally. 22 that -- I didn't know that I worked for Jeffrey
23 Q When did Ghislaine Maxwell remind you 23 immediately. I thought I worked for Ghislaine
24 about the prominent people that she knows personally? 24 because she was the one who brought me in. And she
25 A It was on a constant basis. I mean, there 25 was the one offering the majority of the training to
Page 142 Page 144

1 was no just one time that she said it. It was like a 1 me.
2 reminder, you know. And Jeffrey did a lot more of 2 So, yeah, it was on the balcony, outside,
3 that than she did. But she definitely made it aware 3 I believe the yellow room.
4 that we shouldn't cross boundaries with them. 4 Q She said, You would not want to piss me
5 Q Or what would happen? 5 off because I know powerful people, or words to that
6 A Like I said, it was more of an indirect 6 effect?
7 threat. And it doesn't take an intellect to figure 7 A Words to that effect, yes.
8 out what they mean when they say that they're 8 Q And did she say what would happen if you
9 powerful people and they're very wealthy and they 9 pissed her off because she knows powerful people?
10 know a lot of people. 10 A That statement alone was enough to let me
11 Q I need you to be very clear. You just 11 know. I was scared and I didn't want to -- I didn't
12 used the word "they." I've asked you about Ghislaine 12 want to push any further into that question. I
13 Maxwell. 13 seemed like I would obey.
14 A Okay. 14 Q Up until that point in your life, had you
15 Q So I just want to make sure you understand 15 met any powerful people?
16 the question. 16 MR. EDWARDS: Form.
17 A Correct. 17 A I do believe that I've been put in very
18 Q Because I don't want to have you, you 18 dangerous situations, being a runaway and having a
19 know, misunderstand the question. 19 lot of bad things happen to me. Understanding the
20 A Correct. 20 word powerful people and things that could happen,
21 Q So I'm asking you, what did Ghislaine 21 I've put two and two together and knew what she
22 Maxwell say would happen in regards to crossing a 22 meant.
23 line with respect to her knowledge of famous people? 23 Q (BY MS. MENNINGER) Okay. So you had met
24 A In a -- 24 powerful people before the day that Ghislaine Maxwell
25 MR. EDWARDS: Object to the form. 25 said this to you; is that your testimony?

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1 A Nowhere near as powerful as Jeffrey and 1 of all the girls that were sent to Jeffrey and
2 Ghislaine, nowhere near. But people that did scare 2 Ghislaine. That is my answer.
3 me, yes. 3 Q (BY MS. MENNINGER) I did not ask you
4 Q Okay. And you had met those people at 4 about the girls who were sent to Jeffrey and
5 what age? 5 Ghislaine. I asked you about any girl that you
6 A I don't know what age I was. I'm sorry. 6 personally saw have sexual contact with Ghislaine
7 I was young. I was -- before I met Jeffrey and 7 Maxwell.
8 Ghislaine. 8 Do you understand that question?
9 Q Is there any girl who you personally 9 A Do I know the ages of them?
10 observed to have sexual contact with Ghislaine 10 Q Do you know the age of any girl that you
11 Maxwell when she was under the age of 18? 11 saw have sexual contact with Ghislaine Maxwell?
12 A It's very hard to tell how many girls were 12 A Well, for instance, I mean,
13
14
15
16
17
under the age of 18. My instruction from them was
the younger the better.
Q
A
And, again, them, who told you that?
Them, both of them. They both --
Ghislaine did the majority of my training in the
13
14
15
16
17
of putting it.
older than me.
-
was, I think, a year older than me. That's one way
I think was like a few years
again, a few years older
than me. I mean, those are the girls that I can
actually name.
18 beginning. Jeffrey also insinuated and told me lots 18 Without, not knowing the other girls'
19 of things as well. 19 names, there's no way for me to identify what age
20 Q Okay. So you don't know the age of any 20 they actually were.
21 other female that you saw have sexual contact with 21 Q Okay. Describe for me any other girl
22 Ghislaine Maxwell -- 22 other than the ones that you've named who you say you
23 MR. EDWARDS: Object -- 23 saw have sexual contact with Ghislaine Maxwell with
24 Q (BY MS. MENNINGER) -- is that true? 24 your own two eyes.
25 MR. EDWARDS: Object to the form of the 25 A There's so many I don't know where you
Page 146 Page 148

1 question. Mischaracterized her testimony. She 1 want me to start. I find it impossible to answer
2 wasn't finished with her answer. 2 that question with the amount of girls that I have
3 MS. MENNINGER: I wasn't finished with my 3 witnessed. And without being able to give you
4 question when you objected. And at the end of my 4 specific names, I don't think I'm able to answer that
5 question I said, "Is that true?" She can now restate 5 question.
6 it without you suggesting to her the answer. 6 Q Okay. I asked you to describe them, so
7 MR. EDWARDS: I have no idea what the 7 you could give me a height, a hair color, anything
8 question is to even object to at this point. 8 else that comes to mind?
9 Do you know the question? 9 A There were blondes, there were brunettes,
10 A Do I know any underage girls that 10 there were redheads. They were all beautiful girls.
11 Ghislaine slept with. 11 I would say the ages ranged between 15 and 21.
12 MS. MENNINGER: Can you please read back 12 Q And why do you believe the ages ranged
13 the question? 13 from 15 to 21?
14 (Record read as requested.) 14 A Some of them looked really young. Some of
15 MR. EDWARDS: Hold on. She wasn't 15 them, I wouldn't say 21 looks old or anything like
16 finished with her question, she told me. So that's 16 that, but it's hard to gauge another person's age
17 not the finished question. 17 without really asking them. But some of them looked
18 MS. MENNINGER: You interrupted it. I 18 younger than me and some of them looked older than
19 finished my question. She just read it to her. 19 me.
20 Q (BY MS. MENNINGER) Can you please answer 20 Q And in what physical locations did you see
21 the question? 21 Ghislaine Maxwell have sexual contact with any girl?
22 MR. EDWARDS: Then I object to that 22 A 100 percent, the U.S. V.I.
23 question as a mischaracterization of her testimony. 23 Q Where?
24 And she wasn't finished with her answer. 24 A Jeffrey's island.
25 A It is impossible for me to know the ages 25 Q Where?

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1 A In cabanas. Do you know what I mean by 1 them as a woman. A woman is someone who is older.
2 cabana? 2 But, yes, outside by the pool, down by the beach
3 Q I do, thank you. 3 there's these -- they're little -- I wouldn't call it
4 A In cabanas, in Jeffrey's room. 4 a hut. Little tiny wooden room that only could fit a
5 Q Describe Jeffrey's room on U.S. V.I. for 5 bed in it.
6 me. 6 Q I'm talking about outside.
7 A So can I use this as an idea? Like if 7 A That's outside.
8 this is the island -- can I do that? 8 Q So let's start with by the pool.
9 Q I'm asking you to describe the inside of a 9 A Yes.
10 room. 10 Q Is that a different occasion than the hut?
11 A Oh, the inside of a room. I thought you 11 A I'm talking about many occasions.
12 meant located. 12 Q Okay.
13 Q Um-hum. 13 A Over time.
14 A Okay. Large, stony. He had a king size 14 Q Let's just talk about the ones that you
15 bed with posts on it. There was a large door, I 15 saw happen outside, out of doors.
16 think it's called a door, where you put your clothes. 16 A Okay.
17 There was an adjacent bathroom with a more stony 17 Q Okay?
18 look, giant tub. 18 A Yeah.
19 Q What color was the paint on the wall? 19 Q Do you recall any such specific occasion
20 A It was stone. 20 or is it just a big blur in your mind?
21 Q What color was the bedspread? 21 A No, I mean, one occasion stands out.
22 A White. 22 Models were -- I think they were models -- were flown
23 Q What color were the sheets? 23 in. There were orgies held outside by the pool.
24 A White. 24 That's one occasion.
25 Q And you saw Ghislaine Maxwell have sexual 25 Q All right. Let's stick with that
Page 150 Page 152

1 contact with an unknown, unnamed female in that room, 1 occasion.
2 correct? 2 A Okay.
3 A Absolutely. 3 Q What sexual contact did you observe
4 Q All right. When were you there that you 4 Ghislaine Maxwell have with a female by the pool at
5 saw this happen? 5 an orgy on the U.S. Virgin Islands?
6 A This happened on so many occasions. The 6 A Well, there was quite a few girls and it
7 island was a place where orgies were a constant thing 7 was -- excuse me, if I'm saying this in an inexplicit
8 that took place. And again, it's impossible to know 8 way, but I don't know how else to say it. So if you
9 how many. And, like I said, it wasn't just Jeffrey's 9 don't understand, please let me know -- girl-on-girl
10 room. It was outside and, you know. It was -- 10 action. So there was a lot of -- what's the word for
11 Q When you were outside did you see 11 it? Licking, licking vaginas, breasts.
12 Ghislaine Maxwell have sexual contact with a female? 12 Q Okay. Which --
13 A When you say sexual contact does that mean 13 A Fingers being used. She was involved with
14 fornicating or down to taking explicit photos or 14 that. I remember specifically I had to go down -- do
15 what -- can you define what you mean by sexual 15 you know what I mean by go down?
16 contact? 16 Q It's your testimony. Go ahead.
17 Q Sure. It generally, in my mind, means 17 A I had to go down on Ghislaine. Jeffrey
18 placing either mouth or intimate parts or hands on 18 was there as well.
19 the breasts, buttocks, or pubic area of another 19 Q And this is -- we're still by the pool?
20 person for sexual gratification. 20 A We're still by the pool with lots of
21 A Sure. 21 girls.
22 Q Did you see Ghislaine Maxwell have sexual 22 Q Can you name any of those girls that were
23 contact with a woman outside on the U.S. Virgin 23 there?
24 Islands? 24 A They didn't even speak English. But this
25 A I would say a female. I wouldn't define 25 was --

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1 Q Can you describe them physically? 1 Q More than 20?
2 A Beautiful, tall, some were blonde, some 2 A I would say more than 20.
3 were sandy brown. They had a foreign tongue. 3 Q More than 50?
4 Q What -- what language were they speaking? 4 A I don't think more than 50, but --
5 A I'm not too sure. It could have been 5 Q Did --
6 Russian. It could have been Czechoslovakian. It 6 A I don't have an exact number. I mean,
7 could have been -- I think it's between those two, to 7 if -- I think if you look at the flight logs, you
8 be honest. It could have been something else but, I 8 know, that helps, but then they're not fully
9 mean, I don't speak any other language other than 9 complete. We only have flight logs to one plane and
10 English, so I don't really know. 10 then there's a time I was flown commercially into the
11 Q All right. Any other time you saw 11 island.
12 Ghislaine Maxwell have sexual contact with another 12 Q Um-hum.
13 female outdoors in the U.S. Virgin Islands other than 13 A So it's really hard for me to gauge a
14 this, models with the unknown language? 14 number.
15 A Are we talking about besides with me as 15 Q Okay. Do you have any photographs of
16 well? 16 yourself on the island?
17 Q I don't know if you participated. I'm 17 A I know I used to, but they would be left
18 asking if you observed her have sexual contact with 18 in that apartment.
19 another female? 19 Q What other locations did you participate
20 A Another female other than myself? 20 in sexual contact with Ghislaine Maxwell, other than
21 Q You can answer it however you want. 21 the island?
22 A Well, and the list keeps going on. 22 A Everywhere. New York, Palm Beach.
23 Ghislaine and I and Jeffrey and 23 Q Where in New York?
24 participated in, I guess what you would call a 24 A The mansion, Jeffrey's mansion.
25 foursome in the living room in the main house. 25 Q Okay. Anywhere else in New York?
Page 154 Page 156

1 Q Okay. I was asking about outdoors. 1 A Not at her townhouse.
2 Sorry. 2 Q Anywhere else in New York?
3 A Oh. Well, I don't know if you'd consider 3 A No.
4 this outdoors, but on the beach where those -- it's 4 Q In Palm Beach?
5 basically an outdoor setting. It's like a little 5 A At the house in Palm Beach.
6 wooden house. It's not a house, only a bed can fit 6 Q Anywhere else in Palm Beach?
7 in there. It's right on the beach. It's open. 7 A No.
8 Q Um-hum. 8 Q In New Mexico?
9 A Would you consider that outdoors? 9 A The house in New Mexico.
10 Q I have never been there. So I don't know 10 Q Anywhere else in New Mexico?
11 whether it's outdoors or not. 11 A No.
12 A I would consider it outdoors. And -- 12 Q What other countries?
13 Q How old were you at that time? 13 A France, uhm, England. Um -- we also -- I
14 A I don't know. 14 mean, if we're going to talk about other countries
15 Q Okay. 15 we've got to talk about international travel space or
16 A I have no idea. Again, Ghislaine, myself, 16 plane space or whatever you want to call it because
17 Jeffrey, another girl in this blue, outdoor -- I 17 it happened all the time on the planes.
18 don't know what you want to call it. Cabana, that a 18 Q Okay.
19 house -- just a bed could fit in. 19 A Going from different country to country.
20 Q How many times did you visit the island? 20 Q Where in France did you have sexual
21 A I wouldn't be able to say. Lots of times. 21 contact with Ghislaine Maxwell?
22 Q More than five? 22 A There's a couple places in France that we
23 A Definitely more than five. 23 used to go to.
24 Q More than ten? 24 Q When you say you used to go to, how many
25 A More than ten. 25 times did you go to France?

Agren Blando
Document & Video,
07/30/20
Page 157 Page 159
1 A I think I've been to France three times. 1 with Ghislaine Maxwell at this hotel room overlooking
2 Q All right. How old were you when you went 2 the Champs-Elysees?
3 to France? 3 A Before she picked up the redhead.
4 A I don't know. 4 Q And was that just you and Ghislaine or was
5
6
7
8
9
Q
France?
A
Q
France?
Did you have a passport when you went to
I would have had to, yes.

You did have a passport when you went to
5
6
7
8
9
A
Q
A
Jeffrey and
-
anyone else a participant in that?
And where else in France did you have

sexual contact with Ghislaine Maxwell?
The south of France.
10 A Yes. 10 Q Where?
11 Q And you went to France three times, you 11 A I wouldn't call it so much a hotel. I
12 believe? 12 don't know what you'd call it. It had like big
13 A Yes. 13 townhouse kind of things that you could rent out.
14 Q And when you were in France those three 14 Q Was this on the same trip or a different
15 times, how many of those three times did you have 15 trip?
16 sexual contact with Ghislaine Maxwell? 16 A Different trip.
17 A Every time. 17 Q Okay. Who else was present for that?
18 Q And in what locations in France did you 18 A Well, we were going to
19 have sexual contact with Ghislaine Maxwell? 19 birthday party. It wasn't at the birthday party.
20 A The first time that I remember, we stayed 20 Q Right.
21 at a really fancy hotel. 21 A It was before the birthday party.
22 Q In what city? 22 Q Oh, you had sexual contact with Ghislaine
23 A Paris. 23 Maxwell before you went to birthday
24 Q Okay. 24 party?
25 A And it was within the view of the Champs- 25 MR. EDWARDS: Form.
Page 158 Page 160

1 Elysees. 1 A That's correct.
2 Q Did you have your own room or a separate 2 Q (BY MS. MENNINGER) And who else was
3 room? 3 present during your supposed sexual contact with
4 A We all stayed in the same room, but that 4 Ghislaine Maxwell on this occasion?
5 room had adjoining rooms to it. So, you know, one 5 MR. EDWARDS: Object to the form of the
6 hotel room but with different rooms in it. 6 question.
7 Q Okay. And anywhere else on that one trip 7 A It wasn't supposed. It actually happened.
8 that you went? 8 And Ghislaine was present, Jeffrey was present. I
9 A She brought in a redheaded French girl. 9 believe was present as well.
10 She walked up to her in Paris and, you know -- 10 Q (BY MS. MENNINGER) Anyone else?
11 Q In your presence? 11 A There was someone else on that trip with
12 A In my presence. 12 us, but they weren't involved with the sexual
13 Q Um-hum. 13 activity at that time.
14 A And she walked up to this French girl to 14 Q Okay. And what was the other location in
15 show me how easy it was for her to procure girls. I 15 France?
16 wasn't very good at it. And, you know, it was part 16 A I believe the same exact place. I mean,
17 of my training was to bring in other girls. So she 17 we stayed there for a few days.
18 walked up to her. Within five minutes she had her 18 Q Okay. So the three locations are hotel in
19 number and that girl came over later that night to 19 Paris, same place, same place?
20 the hotel and serviced Jeffrey. I didn't see 20 A Correct.
21 Ghislaine with her. I just know she told me what 21 Q And the second and third same places were
22 happened and Jeffrey told me what happened. 22 on the same trip?
23 Q So you were not there? 23 A Same trip.
24 A I did not see it. 24 Q Okay. And then you had a third trip to
25 Q Okay. When did you have sexual contact 25 France where you did not have sexual contact with

Agren Blando
Document & Video,
07/30/20
Page 161 Page 163
1 Ghislaine Maxwell? 1 MR. EDWARDS: Sounds good.
2 MR. EDWARDS: Form. 2 MS. MENNINGER: All right.
3 A I believe -- it's hard for me to remember. 3 THE VIDEOGRAPHER: We're off the record at
4 I remember going to quite a few different countries 4 12:42.
5 on that trip. I don't know if it was -- I don't know 5 (Recess taken from 12:42 p.m. to
6 if we did it in Paris or not, to be honest. We did 6 1:21 p.m.)
7 it in other places. But I've been to Paris three 7 THE VIDEOGRAPHER: We're back on the
8 times -- or not Paris, sorry, France. 8 record at 1:21.
9 Q (BY MS. MENNINGER) Okay. All right. 9 Q (BY MS. MENNINGER) All right.
10 When did you first tell your parents that you would 10 Ms. Giuffre, I want to talk to you about where you
11 be traveling with Jeffrey Epstein? 11 were living in the late '90s. Do you recall -- you
12 A I'm not too sure when I actually told 12 testified earlier, I believe, that you were living at
13 them. 13 your parents' house and you gave us an address at the
14 Q How long after you were working with 14 time you started at Mar-a-Lago.
15 Jeffrey Epstein did you travel with him? 15 A Yes.
16 A Well, I know my first trip was to New 16 Q Do you remember where you lived previous
17 York. I would say anywhere between six weeks -- I 17 to living at your parents' house at that time?
18 would say after six weeks. 18 A Like I said, I was a runaway, so there was
19 Q You were -- you had known Jeffrey Epstein 19 a lot of different places I lived. One of the places
20 for six weeks before you started traveling with 20 I lived was, like I told you earlier, with
21 him -- 21 parents. That was somewhere around Fort Lauderdale,
22 A I believe. 22 I believe, maybe a little bit outside of it.
23
24
25
1
Q
A
-- am I understanding that correct?
I believe so. I mean, that's an
approximate answer.
Q And your first trip was to New York?

Page 162
23
24
25
1
Q
A
Q
-
Okay.
got an apartment and I lived in
apartment for a short period.
And where do you recall that being?

Page 164
2 A Yes. 2 A Somewhere in Fort Lauderdale, again.

3 Q And did you just go to New York and come 3 Q Okay. And then you were living with your
4 back or did you go somewhere else? 4 parents or was there another place in between?
5 A I think I just went to New York, but I 5 A Then I lived with my parents.
6 can't remember if we went somewhere else. 6 Q Okay. And then where is the next place
7 Q Okay. And did you tell your parents you 7 that you moved?
8 were going to New York? 8 A An apartment that Jeffrey got for me in
9 A Yes. 9 Royal Palm Beach.
10 Q And do you recall any part of your 10 Q Okay. And you don't know the address of
11 conversation with your parents about going to New 11 that?
12 York? 12 A No, I wish I could give it to you. I
13 A I didn't get into details about what I was 13 don't know it.
14 having to do with Ghislaine and Jeffrey. I didn't 14 Q And you stayed in that apartment until you
15 tell them that, but I told them I was going to New 15 left for Thailand in the fall, later in the year in
16 York. 16 2002, correct?
17 Q And you don't recall telling them anything 17 A Yes.
18 else about it? 18 Q Right?
19 A I don't know. I mean, I might have called 19 A Yes.
20 them from New York and told them it was cold and, you 20 Q All right. And when did you first stop
21 know, just simple stuff. But I can't really recall 21 living with your parents? How old were you when you
22 what I spoke to them about. 22 first stopped living with your parents?
23 MS. MENNINGER: As I understand it, the 23 MR. EDWARDS: Object to the form.
24 food is here. So I'm going to suggest that now is a 24 A The very first time?
25 good time to take a break. 25 Q (BY MS. MENNINGER) Um-hum.

Agren Blando
Document & Video,
07/30/20
Page 165 Page 167
1 A I believe I was 11. 1 Loxahatchee, Florida were made aware that you had run
2 Q Okay. What caused you to stop living with 2 away from home at the age of 11?
3 your parents when you were 11? 3 A Yes.
4 A I just had some trouble and my parents 4 Q And what abuse had you suffered prior to
5 thought it would be better if they sent me to 5 the age of 11?
6 California. 6 A There was a very close family friend who
7 Q Okay. What trouble did you have? 7 was a very sick man. And he took advantage.
8
9
10
11
12
A
anymore.
Q
It's very hard for me to talk about.
There was stuff that went on in my life that, you
know, made me so I -- I couldn't live with my parents
What went on in your life that caused you

8
9
10
11
12
Q
A
Q
A
Q
--
What's his name?
what?
And where is today?

13 to not be able to live with your parents at the age 13 A I don't know where he is.
14 of 11? 14 Q Does anyone in your family keep in contact
15 A Do I have to answer this? 15 with him?
16 Q Well, did you talk to Sharon Churcher 16 A No.
17 about being molested as a child? 17 Q What did he do to you?
18 A I did. 18 A Um, he touched me places I shouldn't be
19 Q And you authorized Sharon Churcher to 19 touched. He sexually abused me.
20 publish that in a newspaper, correct? 20 Q For how long?
21 A I don't think I authorized her to do it. 21 A I don't know how long.
22 I think she -- I wouldn't say she did it on her own 22 Q Did you tell that to your parents?
23 accord. But I talked to her about it and I wasn't 23 A They know.
24 aware of exactly what she was going to publish and 24 Q How do they know?
25 what she wasn't. 25 A I told them.
Page 166 Page 168

1 Q So you were able to talk to a reporter for 1 Q Did you tell them when you were under the
2 the Mail On Sunday about this, correct? 2 age of 11 or at the age of 11?
3 A I did tell her a little bit about my past 3 A I told them later.
4 and where I came from. 4 Q When did you tell them?
5 Q All right. So what caused you to be sent 5 A It took me a long time to forgive my
6 away from your parents' home at the age of 11 to 6 parents for sending me away. I didn't feel like
7 California? 7 anybody understood me. So not until later in my life
8 A Some of the prior abuse which led me to be 8 did I feel like I was able to talk to anyone about
9 a very troubled young teenager. I mean, I guess you 9 it.
10 wouldn't call 11 a teenager yet, but led me to 10 Q Okay. Was it reported to the authorities?
11 running away a lot and -- and my family just thought 11 A No. I went too late to talk to anybody
12 it was best that I get out of the area and move 12 about it.
13 somewhere else. 13 Q Did the event of you being molested cause
14 Q Okay. You had run away prior to being the 14 your parents to split up?
15 age of 11? 15 A I think Sharon reported that, but I don't
16 A Yes. 16 think that's the case, no. My parents split up
17 Q All right. Was that reported to the 17 because they were really messed up.
18 authorities? 18 Q Your parents split up because they were
19 A That I ran away? 19 really messed up?
20 Q Yes. 20 A Oh, they just didn't get along. There
21 A Yes. 21 were a lot of marital problems.
22 Q And where were your parents living at the 22 Q When did they split up?
23 age of 11? 23 A I don't really remember what year it was.
24 A The same address I gave you earlier. 24 Q How old were you?
25 Q Okay. So the authorities associated with 25 A I believe I was living with Jeffrey at the

Agren Blando
Document & Video,
07/30/20
Page 169 Page 171
1 time. 1 THE REPORTER: I'm sorry, your --
2 Q With whom did you live in California? 2 Q (BY MS. MENNINGER) Yes? Yes or no?
3 A My 3 A Oh. Yes.
4 Q And who else? 4 Q And then when did you go back to Florida?
5 A 5 A I don't know.
6 Q And with who else? 6 Q Was your younger brother living with your
7 A That's it. 7 parents in Florida while you were in California?
8 Q And for how long did you live with them? 8 A Um-hum, yes.
9 A I don't really know how long, maybe over a 9 Q And was your older brother living with
10 year, maybe two years. 10 your parents in Florida while you were in California?
11 Q And then what caused you to not live with 11 A I don't think so.
12 them anymore? 12 Q How much older than you is he?
13 A I kept running away from them, too. 13 A Five years.
14 Q And where did you live in California? 14 Q And when you went back to Florida, where
15 A I'm sorry? 15 did you go to school, when you got back?
16 Q Where in California did you live? 16 A I believe I went to Crestwood Middle
17 A Where did they live? 17 School.
18 Q Where did you live with them? 18 Q And did you complete your studies at
19 A Salinas. 19 Crestwood Middle School?
20 Q And do you know the address? 20 A Did I get out of middle school there, yes.
21 A No. 21 Q Okay. What grades were middle school?
22 Q Do they still live there? 22 A Six, seven and eight.
23 A No. 23 Q Okay. And when you went back to live with
24 Q When did they stop living there? 24 your parents again, that was at the same address in
25 A I don't know. I haven't kept in contact 25 Loxahatchee?
Page 170 Page 172

1 with them. 1 A Yes.
2 Q And you believe you lived with them for a 2 Q And you don't believe your older brother
3 little more than a year? 3 was in the home at the time?
4 A Maybe a year, maybe two years. I'm not 4 A No, he was sent to boarding school.
5 too sure. 5 Q Where did he go to boarding school?
6 Q Did you go to school there? 6 A Washington.
7 A Yes. 7 Q State or city?
8 Q Where did you go to school? 8 A Washington above California.
9 A Somewhere near Salinas, I'm assuming. 9 Q When was the next time you stopped living
10 Q What grade were you in? 10 with your parents?
11 A Middle school. 11 A They sent me to a group home called
12 Q Sixth grade, seventh grade? 12 Growing Together.
13 A I think sixth grade. 13 Q Why?
14 Q And did you go there for more than one 14 A Because I kept running away.
15 year or just one year? 15 Q Were the authorities alerted when you ran
16 A Maybe -- I don't know. I'm sorry, I don't 16 away?
17 know. 17 A Yes.
18 Q Were the authorities in Salinas alerted to 18 Q And how old were you when you went to live
19 the fact that you ran away from home there? 19 at Growing Together?
20 A Yes. 20 A I don't know. It's hard for me to piece
21 Q How long was the longest you were away 21 back dates. Off the top of my head -- I don't want
22 from home in Salinas, California? 22 to guess. I don't think I should guess. I don't
23 A Two weeks. 23 know.
24 Q And you were in middle school? 24 Q But you moved directly from living with
25 A (Indicating.) 25 your parents to living at Growing Together?

Agren Blando
Document & Video,
07/30/20
Page 173 Page 175
1 A I wouldn't say directly. 1 between the ages of eighth grade and when you started
2 Q How -- 2 working at Mar-a-Lago?
3 A I'd say I stayed with my parents for -- 3 A Besides the ones I've told you about, you
4 like, I think I finished school at Crestwood. So I 4 know, I did run away from Growing Together quite
5 would have been in, I don't know, I guess eighth 5 often. And I did end up being -- being abused by
6 grade, finished eighth grade. And then -- I don't 6 another older guy who I stayed with for I don't know
7 know. I really don't know. Around eighth grade. 7 how long.
8 Q You went to Growing Together? 8 Q How old were you then?
9 A I think -- I think it was then. 9 A I don't know. I'm sorry. I really wish I
10 Q And how many years did you live at Growing 10 could pinpoint dates. I don't know dates.
11 Together? 11 Q Okay. What was that man's name?
12 A Over a year. 12 A
13 Q Were you ever in foster care? 13 Q And how long were you living -- were you
14 A What Growing Together was, was like a 14 living with ?
15 group home that sent you away to foster parents every 15 A Yes.
16 night. 16 Q And for how long were you living with him?
17 Q So you lived in other people's homes 17 A I don't know.
18 during the period of time you were assigned to 18 Q Days? Weeks? Months?
19 Growing Together? 19 A I don't know. I mean, it wasn't days. I
20 A Well, you stayed at Growing Together 20 don't think it was weeks. It would have been close
21 during the day and then at night you get sent home 21 to maybe a few months.
22 with parents. 22 Q Okay. And was prosecuted
23 Q Did you go to school while you were at 23 by federal authorities in South Florida?
24 Growing Together? 24 A Yes.
25 A Yeah, they offer education there. 25 Q And you were located by the FBI, I
Page 174 Page 176

1 Q So the education was at Growing Together? 1 believe?
2 A Yeah. 2 A Yes.
3 Q You did not attend a Palm Beach County -- 3 Q And you gave an interview to the FBI
4 A I did, but you had to earn your levels up 4 concerning your time with , correct?
5 to be able to go outside. So I don't remember what 5 A Yes.
6
7
8
9
10
level you have to get up to, to go out to another
school. I think there was like seven levels or
something. And you had to make it to, like, level 4
to be able to go to outside school.
Q So for some period of time you were
6
7
8
9
10
Q
A
Did you ever get a victim's notification
letter regarding your status as a victim in
federal criminal prosecution?
I don't know. My parents handled
everything.
-
11 assigned to Growing Together and you were going to 11 Q Do you know if your parents received such
12 school at Growing Together. And for some period of 12 a letter?
13 time you were going to other schools and coming back 13 A I don't know.
14 to Growing Together? 14 Q Have you ever asked them?
15 A Correct. 15 A No, I've never really brought it up with
16 Q And then when you came back to Growing 16 them. It really pissed them off a lot, so I never
17 Together, you were sent to spend the night at a 17 brought it up with them.
18 family's home? 18 Q It pissed them off that you were living
19 A Yes. 19 with ?
20 Q So you never slept at Growing Together? 20 A Yes.
21 A No. 21 Q Why did it piss them off, if you know?
22 Q Did you live -- other than living at or 22 A Well, I think they were just disgusted,
23 staying at Growing Together during the day and 23 you know, that this happened to me again. And they
24 sleeping at these other homes at night, is there 24 didn't want to talk about it. They didn't want to
25 anywhere else that you recall living in the period 25 talk about it.

Agren Blando
Document & Video,
07/30/20
Page 177 Page 179
1 Q But they were aware of it? 1 Mar-a-Lago, correct?
2 A Yes. 2 A Yes.
3 Q Your dad came and picked you up from the 3 Q Do I have that sequence right?
4 police station? 4 A So far, yes.
5 A Yes. 5 Q And when did you stop living at your
6 Q And your dad would not let you come home? 6 parents' at the time you started working at
7 A Well, I think it was more my mom didn't 7 Mar-a-Lago? How long after you started at Mar-a-Lago
8 want me to come home. 8 do you stop living with your parents?
9 Q Did she say why? 9 A I don't know exact dates. I was traveling
10 A She just probably thought I was just going 10 with Jeffrey a lot, and I was making -- he was giving
11 to keep running away again. And -- 11 me lots of money for the sex that I had with him and
12 Q Did she say that to you? 12 Ghislaine.
13 A Well, I asked my dad at the police station 13 And after, I would say, a short time --
14 if I could come home instead of going back to Growing 14 I'm not too sure, darling, I don't know.
15 Together. And he said my mom didn't want me to come 15 Q All right. Can you --
16 home. And I told him if he didn't get me out within 16 MS. MENNINGER: I have no recollection of
17 a week, I'd run away again and he'd never hear from 17 which number we're on in terms of exhibit.
18 me again. 18 MS. RODRIGUEZ: 15.
19 Q And how is it that you came back to be 19 Q (MS. MENNINGER) Okay. I'd like to mark
20 living at their house, then? 20 as Defendant's Exhibit 15 a document and see if you
21 A I ran away again and I called him up and I 21 can identify it.
22 said, This is your final chance. And they came and 22 Actually, before I do that, when do you
23 picked me up and they let me live there. 23 recall ever getting a passport?
24 Q And when did you go live with 24 A I got my passport in New York. I don't
25 A Not long after that. 25 know what age I was.
Page 178 Page 180

1 Q And when did you live with 1 Q Okay. And did you -- how did you get it?
2 parents? 2 Did you go somewhere or what happened?
3
4
5
A
before I lived with
Q
-
Well, I lived with parents
in his apartment.
And that was an apartment that
3
4
5
A Jeffrey had me fill out paperwork and go
to a Kodak shop or something similar of a Kodak shop
and get my picture taken. I gave him my picture and
6
7
8
9
10
rented?
A
was.
Q
- and his friend. I can't remember
his friend's name. Mario, I think his friend's name
When did you live with

6
7
8
9
10
my paperwork. He sent it away. And I think a week
later he said he got it expedited.
Q
York?
A
Did you physically go to an office in New
Jeffrey's office.
11 as parents? 11 Q An office associated with Immigration or
12 A That was just a brief stint. I didn't 12 Homeland Security or whatever it was called back
13 really stay there very long, but it was -- I was a 13 then?
14 runaway. That's in between times of -- I don't know. 14 A Not that I recall.
15 Q How old were you? 15 Q And do you know how old you were?
16 A I don't know. 16 A No. I don't know how old you have to be
17 Q I just want to be clear. rented 17 to get a passport, so I'm not too sure.
18 an apartment that you moved into that he had rented, 18 (Exhibit 15 marked.)
19 correct? 19 Q (BY MS. MENNINGER) Okay. I'm going to
20 A Correct. 20 show you Defendant's Exhibit 15.
21 Q And that was after you had lived with 21 Do you recognize this document?
22 and his parents, correct? 22 A Yes.
23 A Yes. 23 Q Is this document the passport application
24 Q And that was prior to you and 24 that you filled out?
25 living with your parents when you started working at 25 A Yes.

Agren Blando
Document & Video,
07/30/20
Page 181 Page 183
1 Q Is it in your handwriting? 1 a 3. I think it's
2 A Yes. I I really can't make out
3 Q All right. What did you put down as your 3 the telephone number.
4 address at this time to mail the passport to? It's 4 Q Okay. Do you see Relationship? Can you
5 about the second line -- third line. 5 read that?
6 A Number 13? 6 A Friend.
7 Q Well, the third line says, Mail passport 7 Q Okay. Do you see just below that there's
8 to. What address did you put down? 8 a line that says number 21?
9 A Are we talking about number 13, Permanent 9 A Do not stop -- sorry, Do not sign
10 address, do not list P.O. box, street? 10 application until requested to do so by
11 Q No, I'm talking about the third line in 11 administrating an oath.
12 the entire thing that says, Mail passport to. 12 Q Okay.
13 A Oh, I'm sorry, up here, the 13 A Applicant's signature age 13 or older.
Q Oh, it's by the signature line?
■
14
A Yeah.
■
15
16 Q All right. So you asked to have the 16 Q And that's your signature?
17 passport mailed to you at your parents' address, 17 A Yes.
18 right? 18 Q All right. And this is the document that
19 A I don't know if it was mailed to my 19 you recall filling out for your first passport?
20 parents' house, but that's the address I sent -- put 20 A I don't recall doing it, but yes, it's in
21 down, yes. 21 my handwriting and it's got all of my information on
22 Q Okay. And if you look a little bit 22 it.
23 further to the right, roughly equal with that line, 23 Q Okay. And on line -- box 23 it's got your
24 do you see a date that's stamped on there? 24 driver's license checked off, right?
25 A Yeah, January 12th, 2001. 25 A July 23. Yeah, I really can't make out
Page 182 Page 184

1 Q Okay. And then if you go down a little 1 numbers and stuff, though.
2 bit further, as you pointed out, line number 13, you 2 Q But the box, Driver's License is checked
3 gave your permanent address as your parents' address, 3 off?
4 again, correct? 4 A Yes.
5 A Correct. 5 Q Okay. And then if you look in the lower
6 Q If you look at box number 12 where it asks 6 right-hand corner of the page, do you see what we
7 for occupation, what did you write down? 7 call a Bates stamp number? I don't know if you know
8 A Masseuse. 8 what that means.
9 Q Okay. If you look at line number 18, Have 9 A No.
10 you ever been issued a U.S. passport before, what did 10 Q Just the lower right-hand corner of the
11 you put down? 11 document.
12 A No. 12 A Giuffre 004721?
13 Q All right. And if you go down a little 13 Q Okay. Thank you.
14 bit further than that, emergency contact, who did you 14 So at January 2001 was
15 put down? 15 living
16 A 16 A Well, he would have had to have been if I
17 Q Okay. So is that the fiancé you were 17 put it down there.
18 talking about earlier? 18 Q Okay. Was that the apartment that he had
19 A Yes. 19 rented?
20 Q In January of 2001 were you still his 20 A No, it's in Royal Palm Beach. The
21 affianced? 21 apartment he rented was in Fort Lauderdale. So this
22 A Looks like it, yes. 22 could be my apartment that he lived at with me.
23 Q And what address did you put down for 23 Q Okay. So his apartment where he lived
24 24 with you was in Royal Palm Beach?
25 A It's kind of hard to read. I think that's 25 A Yes.

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1 Q And he rented that apartment? 1 Q Let me have you put the paper down.
3 Mischaracterization. 3 Q Do you recall applying for another
4 A He lived there with me for a short period. 4 passport?
5 I don't -- I don't know how long he lived there with 5 A No.
6 me for. 6 Q Okay. Do you recall ever applying for
7 Q (BY MS. MENNINGER) And who rented the 7 another passport, ever?
8 apartment? 8 A Well, yeah, when I got to Australia I had
9 A Well, Jeffrey paid for the apartment. I 9 to -- I don't have it on me right now, but I could
10 was the occupant, and he was an occupant. 10 tell you it's -- I had to apply for another one
11 Q Did you ever see the lease? 11 because the other one ran out as expiree.
12 A Yes, I believe I had to sign the paperwork 12 Q So whenever one expired, you applied for
13 saying that I was living there. 13 another one from the U.S.?
14 Q So you were living at -- is it 14 A (Indicating.)
15 15 Q Have you ever gotten --
16 A I can't honestly read it. It looks like a 16 Is that right?
17 C-a-c (sic), but that doesn't make sense. 17 A Yeah.
18 Q So January of 2001 you signed a document 18 Q Have you ever gotten a passport from
19 under oath putting 19 Australia?
A An Australian passport?
■
20
21 A Yes. 21 Q Right.
22 Q And you put your permanent address and 22 A No.
23 your mail your passport to at your parents' 23 Q Have you ever lost a passport and had to
24 address -- 24 get one replaced?
25 A Yes. 25 A I don't think so.
Page 186 Page 188
1 Q -- is that right? 1 Q When was the first time that you came back
2 And it's your position that that is the 2 to the U.S. from Australia?
3 apartment that Jeffrey paid for and you signed a 3 A October 16th, 2013.
4 lease? 4 Q And did you come back before that?
5 A Yes, Jeffrey paid for it and I think I had 5 A No.
6 to sign something that said I was going to occupy it. 6 Q Did you ever tell Sharon Churcher or
7 I don't know if James ever did. 7 Sharon White or Marianne Strong that you were going
8 Q Okay. And you stayed at that apartment 8 on a trip to New York in 2011?
9 from at least January 2001 until you left in the fall 9 A No.
10 of 2002, right? 10 Q Is it your contention that Ghislaine
11 A I would say before then, yes. Like I 11 Maxwell sexually trafficked you to famous people?
12 said, I can't really tell you the exact date that I 12 A If you have a document in front of you
13 moved there, but -- 13 that you could show me so I could see what you're
14 Q Why did you have your passport sent to 14 talking about, yes.
15 your parent's house if you weren't living at your 15 Q I'm asking you, is it your contention that
16 parents' house? 16 Ghislaine Maxwell sexually trafficked you to famous
17 A Um, I don't know. I guess a fail-safe. 17 people?
18 I'm not too sure. 18 A Could you be more specific, like are we
19 Q When was the next passport that you got? 19 talking about rock stars or royalty or --
20 A I think I had to reapply for one in -- 20 Q Politically connected and financially
21 well, this one expired in 2002. So I would have had 21 powerful people.
22 to apply for another one. 22 A Yes.
23 Q I'm asking do you remember when you got 23 Q Okay. To whom did Ghislaine Maxwell
24 another passport? 24 sexually traffic you?
25 A This expired January 10th, 2002. 25 A You have to understand that Jeffrey and

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1 Ghislaine are joined hip by hip, okay? So they both 1 exactly what you would do for Jeffrey to him. Keep
2 trafficked me. Ghislaine brought me in for the 2 him happy. I can't remember her exact words, and I'm
3 purpose of being trafficked. Jeffrey was just as a 3 not going to put words in my mouth to make it sound
4 part of it as she was. She was just as a part of it 4 like what she said. But it was all along those
5 as he was. They trafficked me to many people. And 5 lines.
6 to be honest, there is people I could name and then 6 Q Those are words that Ghislaine Maxwell
7 there's people that are just a blur. There was so 7 used to you in directing you to go have sex with
8 much happening. 8 ?
9 Q Okay. Please name a person that Ghislaine 9 MR. EDWARDS: Object to the form.
10 Maxwell directed you to go have sex with? 10 Mischaracterized her testimony.
11 A . 11 A Along those lines, yes.
12 Q Okay. Who else? 12 Q (BY MS. MENNINGER) Okay. Where were you
13 A As a whole, they both trafficked me to 13 located when she used those words with you?
14 people. It was under both of their direction. So 14 A It could have been Palm Beach. It could
15 it's not easy just to say Ghislaine. When I say 15 have been New York.
16 they, I mean both of them. 16 Q You don't recall?
17 Q Okay. Well, I need you to say a time when 17 A I don't recall.
18 Ghislaine Maxwell directed you to go have sex with 18 Q Okay. How old were you when she used
19 another person. So can you please tell me to whom 19 those words to you?
20 Ghislaine Maxwell asked you to go have sex with 20 MR. EDWARDS: Object to the form.
21 another person? 21 Mischaracterizes her testimony.
22 MR. EDWARDS: Object to the form. 22 A I don't know. I would think I was 17.
23 A 23 Q (BY MS. MENNINGER) But you're not sure?
24 Q (BY MS. MENNINGER) Who else? 24 A Well, it was in the beginning, like after
25 A I'm going to continue to tell you that 25 my training. were
Page 190 Page 192

1 they both directed me to do it. It was part of my 1 the two first people I was sent out to.
2 training. They both told me, you've got tickets to 2 Q Okay. Well, I was asking about
3 go here. This is who you're meeting, and this is 3 okay?
4 what you're doing. 4 A Right. That's what I'm saying. If you
5 So is another one. 5 want me to categorically tell you when it happened
6 Q Ghislaine Maxwell directed you to go have 6 and why I think I was 17, because those were the two
7 sex with ? 7 first people I was sent to.
8 MR. EDWARDS: Object to the form to the 8 Q So you don't actually recall the
9 extent it mischaracterized her testimony. 9 conversation regarding ? You don't
10 A I'm trying to tell you that they both did, 10 recall where you were, right?
11 Ghislaine and Jeffrey both directed me. They both 11 A I can't picture if it was New -- I know it
12 paid me and they both directed me. 12 was either New York or Palm Beach. I don't remember
13 Q (BY MS. MENNINGER) All right. When did 13 exactly which one.
14 Ghislaine Maxwell direct you to go have sex with 14 Q You don't recall exactly what words were
15 ? 15 used by Ghislaine Maxwell in speaking to you,
16 MR. EDWARDS: Object to the form. Same 16 correct?
17 objection. 17 A I remember the tone that she used, the
18 A I don't know the time. I don't -- you 18 type of words that she used. I can't word for word
19 know, I could tell you the place. I don't know the 19 replay what she said.
20 time. 20 Q All right. And so when in time was
21 Q (BY MS. MENNINGER) What words did 21 ?
22 Ghislaine Maxwell use in talking to you and asking 22 A was months, six months,
23 you to go have sex with ? 23 I'm not too sure.
24 A We're sending you to a gentleman. We want 24 Q Six months what?
25 you to show him a good time. We want you to do 25 A Before . I don't know, I

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Page 193 Page 195
1 think I met Prince Andrew in 2001. And Glenn Dubin 1 Q If you're going to tell me more names,
2 and Stephen Kaufmann were, like I said, the first 2 please continue your answer.
3 people I was sent out to after my training. So I 3 A I'm trying to think.
4 don't know. I'm not going to give you an exact time 4 Q If you're just going to talk --
5 if I don't know it. 5 A I'm sorry. I'm trying to think.
6 Q I asked you the relative order. 6 Q Okay. Let's take a break and then you can
7 A And I'm trying to give you it. 7 think over the break.
8 Q And where does Alan Dershowitz fit into 8 THE VIDEOGRAPHER: We're off the record at
9 that group of people? 9 2:01.
10 A Same. I can't tell you piece by piece by 10 (Recess taken from 2:01 p.m. to 2:09 p.m.)
11 piece who -- I know Glenn Dubin was first. 11 THE VIDEOGRAPHER: We're back on the
12 Q Okay. 12 record at 2:09.
13 A And I know Stephen Kaufmann was one of the 13 Q (BY MS. MENNINGER) Ms. Giuffre, you have
14 first I was sent to. Alan Dershowitz could have been 14 filed a lawsuit against Ghislaine Maxwell, correct?
15 between there. Between, sorry, between Glenn and 15 A Yes.
16 Stephen. The first time I was with Alan Dershowitz 16 Q You understand her to be my client,
17 was in New York, so I wasn't actually sent to him. 17 correct?
18 It actually happened at one of Jeffrey's residences. 18 A Yes.
19 (Ms. McCawley left the deposition.) 19 Q I'm here today to talk to you about your
20 A So it's very hard for me to 20 allegations against Ghislaine Maxwell.
21 chronologically give you each person individually. 21 Do you understand that?
22 Q (BY MS. MENNINGER) Okay. Name the other 22 A Yes.
23 politically connected and financially powerful people 23 Q I want you to tell me a single time that
24 that Ghislaine Maxwell told you to go have sex with? 24 you recall Ghislaine Maxwell using words to you and
25 A Again, I'm going to tell you "they" 25 directing you to go have sex with another person --
Page 194 Page 196

1 because that's how it went. They instructed me to go 1 MR. EDWARDS: Object.
2 to George Mitchell, Jean Luc Brunel, Bill Richardson, 2 Q (BY MS. MENNINGER) -- not anybody else,
3 another prince that I don't know his name. A guy 3 Ghislaine Maxwell?
4 that owns a hotel, a really large hotel chain, I 4 MR. EDWARDS: Objection. Asked and
5 can't remember which hotel it was. Marvin Minsky. 5 answered.
6 There was, you know, another foreign 6 To the extent that she can answer the
7 president, I can't remember his name. He was 7 question, I'd ask that she answer the question.
8 Spanish. There's a whole bunch of them that I 8 A I have answered the question. The
9 just -- it's hard for me to remember all of them. 9 question that you're asking me is Ghislaine. And
10 You know, I was told to do something by these people 10 Ghislaine and Jeffrey worked together. They were one
11 constantly, told to -- my whole life revolved around 11 and the same of persons. They both directed me to do
12 just pleasing these men and keeping Ghislaine and 12 this. They both directed me to report back to them.
13 Jeffrey happy. Their whole entire lives revolved 13 They were both the same.
14 around sex. 14 Q (BY MS. MENNINGER) You cannot recall a
15 They call massages sex. They call 15 single instance in which Ghislaine --
16 modeling sex. They call -- 16 A I have to --
17 Q I asked you the names for people. Are you 17 Q Excuse me.
18 going to tell me any other names or is that all of 18 -- in which Ghislaine Maxwell alone
19 them? 19 directed you to have sex with another person --
20 A I'm trying to think. That's the answer 20 A I have to --
21 I'm trying to give to you. It's that it's so hard to 21 Q -- correct?
22 just keep naming and naming and naming. 22 A -- believe --
23 Q All right. 23 MR. EDWARDS: Object.
24 A A lot of times I would be introduced to 24 MS. MENNINGER: I am going to finish my
25 them. I didn't know -- 25 question.

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1 Q (BY MS. MENNINGER) Correct? 1 was going to be trained as a masseuse and that she
2 MR. EDWARDS: Are you finished with your 2 instructed me to take off my clothes and to give oral
3 question? 3 sex to Jeffrey Epstein.
4 MS. MENNINGER: Now you may make your 4 Q (BY MS. MENNINGER) Excuse me. I've asked
5 objection. And then she may answer. 5 you for the names.
6 MR. EDWARDS: Okay. Objection. 6 A I've just given you a name. Jeffrey
7 Argumentative. Harassing for absolutely no reason. 7 Epstein is a big name.
8 Mischaracterizing the witness's testimony. 8 Q All right.
9 Answer, if you can. 9 A She instructed me on that one.
10 A I have given you the names of the people 10 Q So you're saying --
11 that Ghislaine herself has told me to go be sex 11 MR. EDWARDS: The witness is finishing her
12 trafficked to, along with Jeffrey Epstein, okay? 12 answer right now. She's in the process of explaining
13 She's the one who brought me to Jeffrey 13 one of the people Ghislaine told her to have sex
14 Epstein to be trafficked in the fucking first place. 14 with.
15 So I have given you as much information as 15 Q (BY MS. MENNINGER) So you're saying
16 I possibly can to let you know what she was about, 16 Ghislaine Maxwell directed you to have sex with
17 who she told me to go with, what she wanted me to do. 17 Jeffrey Epstein?
18 That is what I am stating and that's what I 18 A Correct.
19 previously stated to you. 19 Q Ghislaine Maxwell directed you to have sex
20 Q (BY MS. MENNINGER) And these names that 20 with Glenn Dubin?
21 you have just given are people to whom Ghislaine 21 A Correct.
22 Maxwell alone told you to go have sex? 22 Q What words did Ghislaine Maxwell tell you
23 MR. EDWARDS: Objection. 23 to go have sex with Glenn Dubin?
24 Mischaracterization. 24 A It was the same all the time, all right?
25 A Ghislaine and Jeffrey, I don't know how 25 They want me to go provide these men with a massage.
Page 198 Page 200

1 many times you want me to keep answering this 1 And when they say massage, that means erotic, okay?
2 question. Both told me to do this, okay? They both 2 That's their term for it. I think there are plenty
3 sent me to these people. 3 of other witnesses that can attest to what massage
4 How many times do you want me to answer 4 actually means.
5 this? 5 And I'm telling you that Ghislaine told me
6 Q (BY MS. MENNINGER) I think you're 6 to go to and give him a massage, which
7
8
9
10
11
answering a different question so that's why I'm
going to ask you again. I am not asking you anything
about a time when Jeffrey and Ghislaine together told
you to go do something. I'm asking you to name a
single time during which Ghislaine Maxwell acting
7
8
9
10
11
means sex.
Q Okay. So
-
you to go give a massage to
A
Q
Correct.
-- Ghislaine Maxwell told
That's your testimony?

12 alone directed you to go have sex with another 12 A That is my testimony.
13 person? 13 Q All right. Ghislaine Maxwell told you to
14 MR. EDWARDS: Objection. Asked and 14 go give a massage to , correct?
15 answered. Harassing. Argumentative. 15 A Correct.
16 A I've given you the names of the people 16 Q Ghislaine Maxwell told you to give a
17 that Ghislaine instructed me to go have sexual 17 massage to , correct?
18 relations with. I am not discluding (sic) the fact 18 A Correct.
19 that Jeffrey also told me. 19 Q Ghislaine Maxwell told you to give a
20 Ghislaine told me from her mouth to do 20 massage to , correct?
21 these things. Jeffrey told me from his mouth to do 21 A Correct.
22 these things with these people. Ghislaine instructed 22 Q When did Ghislaine Maxwell tell you to
23 me to do the things that I did with Jeffrey Epstein 23 give a massage to ?
24 on the very first meeting that I had with him. She 24 A I don't know dates.
25 brought me there under the preclusion (sic) that I 25 Q Where were you?

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1 A When it happened? 1 know where it was when she said to go do this.
2 Q When Ghislaine Maxwell used the words, Go 2 Q (BY MS. MENNINGER) Okay. Where were you
3 give a massage to Bill Richardson, where were you? 3 sent to have sex with the owner of a large hotel
4 MR. EDWARDS: Object to the form. 4 chain by Ghislaine Maxwell?
5 Mischaracterizes her testimony. 5 MR. EDWARDS: Object to the form.
6 A I can't tell you where we were. I know 6 A I believe that was one time in France.
7 where I was sent to. I don't know where we were when 7 Q (BY MS. MENNINGER) Which time in France?
8 she told me to do that. 8 A I believe it was around the same time that
9 Q (BY MS. MENNINGER) Where were you sent 9 Naomi Campbell had a birthday party.
10 to -- 10 Q Where did you have sex with the owner of a
11 A New Mexico. 11 large hotel chain in France around the time of Naomi
12 Q -- by Ghislaine Maxwell? 12 Campbell's birthday party?
13 MR. EDWARDS: Object to the form. 13 A In his own cabana townhouse thing. It was
14 Mischaracterizes her testimony again. 14 part of a hotel, but I wouldn't call it a hotel.
15 A Are you smiling at me because -- 15 Jeffrey was staying there. Ghislaine was
16 Q (BY MS. MENNINGER) No, I'm asking you to 16 staying there. Emmy was staying there. I was
17 answer the question. 17 staying there. This other guy was staying there. I
18 A I have answered the question. I was sent 18 don't know his name.
19 to New Mexico. 19 I was instructed by Ghislaine to go and
20 Q Okay. Where were you sent from? 20 give him an erotic massage.
21 A I already answered that. I don't know 21 Q She used the words erotic massage?
22 where I was sent from. 22 A No, that's my word. The word massage is
23 Q Okay. 23 what they would use. That's their code word.
24 A I was flying everywhere with these people. 24 Q Was she in the room when you gave this
25 Q Where were you sent by Ghislaine Maxwell 25 erotic massage to the owner of a large hotel chain?
Page 202 Page 204

1 to have sex with ? 1 A No, she was not in the room. She was in
2 MR. EDWARDS: Object to the form. 2 another cabana.
3 Mischaracterized her testimony. 3 Q And other than telling you to go give the
4 A Many places. 4 owner of this large hotel chain a massage, do you
5 Q (BY MS. MENNINGER) Ghislaine Maxwell sent 5 remember any other words she used to you to direct
6 you to many places to have sex with ? 6 you in what you should do?
7 MR. EDWARDS: Object to the form. 7 A Not at the time, no.
8
9
10
11
12
A
Q
correct?
A
It happened at many places, yes.
(BY MS. MENNINGER) You had sex with
at many places is what you're saying,
I was sent to at many

- 8
9
10
11
12
Q Where did -- where were you and where was
Ms. Maxwell when she directed you to go have sex with
Marvin Minsky?
A
MR. EDWARDS: Object to the form.
I don't know.
13 places to have sex with him. 13 Q (BY MS. MENNINGER) Where did you go to
14 Q When did Ghislaine Maxwell send you to a 14 have sex with Marvin Minsky?
15 place to have sex with ? 15 A I believe it was the U.S. Virgin Islands,
16 A You are asking -- 16 Jeff's -- sorry, Jeffrey Epstein's island in the U.S.
17 MR. EDWARDS: Form. 17 Virgin Islands.
18 A -- me to answer the impossible. 18 Q And when was that?
19 Q (BY MS. MENNINGER) All right. When did 19 A I don't know.
20 Ghislaine Maxwell send you to have sex with the owner 20 Q Do you have any time of year?
21 of a large hotel chain? 21 A No.
22 MR. EDWARDS: Object to the form. 22 Q Do you know how old you were?
23 Mischaracterization. 23 A No.
24 A I'm going to keep answering the questions 24 Q Other than Glenn Dubin, Stephen Kaufmann,
25 the same way that I keep answering them. I don't 25 Prince Andrew, Jean Luc Brunel, Bill Richardson,

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1 another prince, the large hotel chain owner and 1 Q Including Mr. Edwards, who is sitting
2 Marvin Minsky, is there anyone else that Ghislaine 2 right here, correct?
3 Maxwell directed you to go have sex with? 3 A Correct.
4 A I am definitely sure there is. But can I 4 Q What did that journal look like?
5 remember everybody's name? No. 5 A It was green.
6 Q Okay. Can you remember anything else 6 Q And what else?
7 about them? 7 A It was just a spiral notebook.
8 A Look, I've given you what I know right 8 Q Okay. And what did you put into that
9 now. I'm sorry. This is very hard for me and very 9 green spiral notebook?
10 frustrating to have to go over this. I don't -- I 10 A Bad memories. Things that I've gone
11 don't recall all of the people. There was a large 11 through, lots of things, you know. I can't tell you.
12 amount of people that I was sent to. 12 There was a lot of pages. It was over 300 pages in
13 Q Do you have any notes of all these people 13 that book.
14 that you were sent to? 14 Q Did you ever show that book to your
15 A No, I don't. 15 lawyers?
16 Q Where are your notes? 16 A No.
17 A I burned them. 17 Q Did you show that book to anyone?
18 Q When did you burn them? 18 A My husband.
19 A In a bonfire when I lived at Titusville 19 Q Did you show it to anyone else besides
20 because I was sick of going through this shit. 20 your husband?
21 Q Did you have lawyers who were representing 21 A No.
22 you at the time you built a bonfire and burned these 22 Q Did you tear out pages and give them to
23 notes? 23 Sharon Churcher?
24 A I've been represented for a long time, but 24 A No, I wrote -- those pages that you're
25 it was not under the instruction of my lawyers to do 25 talking about, I wrote for her specifically. She
Page 206 Page 208
1 this. My husband and I were pretty spiritual people 1 wanted to know about the Prince Andrew incident.
2 and we believed that these memories were worth 2 Q So that's a different piece of paper?
3 burning. 3 A Yeah, that's just random paper.
4 Q So you burned notes of the men with whom 4 Q So you had a green spiral notebook that
5 you had sex while you were represented by counsel in 5 you began sometime in 2011 or 2012 in which you wrote
6 litigation, correct? 6 down your recollections about what had happened to
7 MR. EDWARDS: Object to the form. 7 you, and you burned that in a bonfire in 2013.
8 A This wasn't anything that was a public 8 Did I get that right?
9 document. This was my own private journal, and I 9 A You got that right.
10 didn't want it anymore. So we burned it. 10 Q And do you have no other names of people
11 Q (BY MS. MENNINGER) When did you write 11 to whom you claim Ghislaine Maxwell directed you to
12 that journal? 12 have sex, correct?
13 A Just over time. I started writing it 13 A At this time, no.
14 probably in, I don't know, I can't speculate, 2012, 14 Q Is there any document that would refresh
15 2011. 15 your recollection that you could look at?
16 Q So you did not write this journal at the 16 A If you have a document you'd like to show
17 time it happened? 17 me, I would be glad to look at it and tell you the
18 A No. 18 names I recognize off of that.
19 Q You started writing this journal 19 Q I'm just asking you if there's a document
20 approximately a decade after you claim you finished 20 you know of that has this list of names in it?
21 being sexually trafficked, correct? 21 A Not in front of me, no.
22 A Yes. 22 Q Where is the original of the photograph
23 Q And you started writing a journal after 23 that has been widely circulated in the press of you
24 you had a lawyer, correct? 24 with Prince Andrew?
25 A Correct. 25 A I probably still have it. It's not in my

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1 possession right now. 1 A My little yellow Kodak camera.
2 Q Where is it? 2 Q Who took the picture?
3 A Probably in some storage boxes. 3 A Jeffrey Epstein.
4 Q Where? 4 Q And where did you have it developed?
5 A In Sydney. 5 A I believe when I got back to America.
6 Q Where in Sydney? 6 Q So where?
7 A At some family's house. We got the boxes 7 A I don't know.
8 shipped to Australia, and they were picked up off the 8 Q Palm Beach?
9 porch by my nephews and brought to their house. 9 A I don't know.
10 Q Which is where? 10 Q What is the date the photograph was
11 A In Sydney. 11 printed?
12 Q Where in Sydney? 12 A I believe it's in March 2001.
13 A 13 Q Okay.
14 Q And who lives in that house? 14 A But that's just off of my photographic
15 A Well, it's owned by my mother-in-law and 15 memory. I don't -- it could be different, but I
16 father-in-law, but my nephews live in the house. 16 think it's March 2001.
17 Q What are their names? 17 Q You have a photographic memory?
18 A I'm not giving you the names of my 18 A I'm not saying I have a photographic
19 nephews. 19 memory. But if I'd look at the back of the photo and
20 Q What's the address of the house? 20 I remember what it says, I believe it was March 2001.
21 A Why would you want that? 21 Q Did the photograph ever leave your
22 Q I want to know where the photograph is. 22 possession for a while?
23 I'm asking you where the photograph is. And you've 23 A I gave it to the FBI.
24 just told me it's somewhere in 24 Q Okay. And when did you get it back?
25 A Yes. 25 A When they took copies of it.
Page 210 Page 212

1 Q So where in is the photograph 1 Q When was that?
2 located? 2 A 2011.
3 A If I can't 100 percent say that the 3 Q When they came to interview you?
4 photograph is there, it could be at my house that I 4 A Yes.
5 presently live in. I'm not going to give you the 5 Q So from 2011 until you left Colorado it
6 address of my nephews' residence. 6 was in your personal possession?
7 Q When is the last time you saw the 7 A Yes.
8 photograph in person? 8 Q What other documents related to this case
9 A When I packed and left America. 9 are in that, storage boxes in Australia?
10 Q Colorado? 10 MR. EDWARDS: Object to the form.
11 A Yes. 11 A Documents related to this case -- there --
12 Q All right. So you had that photograph 12 I don't know. I really can't tell you. I mean,
13 here with you in Colorado? 13 there's seven boxes full of Nerf guns, my kids' toys,
14 A Yes. 14 photos. I don't know what other documents would be
15 Q What's on the back of the photograph? 15 in there.
16 A I'm sorry? 16 Q (BY MS. MENNINGER) Did anyone search
17 Q Is there anything on the back of the 17 those documents after you received discovery requests
18 photograph? 18 from us in this case?
19 A There's like the date it was printed, but 19 A I haven't been able to obtain those boxes.
20 no writing or anything. 20 I can't get them sent back up to me. It's going to
21 Q Okay. Does it say where it was printed? 21 cost me a large amount of money. And right now I'm
22 A I don't believe so. I think it just -- I 22 trying to look after my family, so I'm not able to
23 don't remember. I just remember there's a date on 23 afford to get them up.
24 it. 24 Q You live in Australia, correct?
25 Q Whose camera was it taken with? 25 A I do.

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1 Q Okay. How far away are the boxes from 1 We've had lots of bonfires there.
2 where you live in Australia? 2 Q Did you ever ride in a helicopter with
3 A Sydney is down here at the bottom. Cairns 3 Ghislaine Maxwell acting as pilot of the helicopter?
4 is up here at the top. 4 A Yes.
5 Q Okay. 5 Q Who else was on the flight?
6 A It's probably a six-day drive. 6 A I've been on the helicopter with her
7 Q Did you fly here through Sydney? 7 plenty of times. I can't mention how many people
8 A No. 8 were on the -- on the helicopter at the same time.
9 Q Have you been to Sydney since you've moved 9 Q How many times?
10 back to Australia? 10 A I don't know. Do you have helicopter
11 A I flew into Sydney with my three kids, but 11 records that you could show me?
12 it was a connecting flight to Brisbane. 12 Q I'm asking you how many times you were on
13 Q Did you ask your nephews or anyone else to 13 the helicopter with Ghislaine Maxwell acting as the
14 search those boxes in response to discovery requests 14 pilot --
15 that we issued in this case? 15 A It's impossible for me to answer the
16 A They are my nephews. I would never let 16 question without having the actual physical records
17 them look at those. 17 in front of me.
18 Q Other than your green spiral notebook, 18 Q I'm asking you to look into your memory
19 what else did you burn in this bonfire in 2013? 19 and tell me how many times you recall being on a
20 A That was it. 20 helicopter with Ghislaine Maxwell at the pilot seat?
21 Q That's the only thing? 21 A There is no number I can give you.
22 A Yes. 22 There's plenty of times I've been on her helicopter.
23 Q Did you use wood? 23 Q Where did you go from and to on a
24 A Yes. 24 helicopter?
25 Q Charcoal? 25 A I believe it was -- don't quote me on this
Page 214 Page 216

1 A My husband built the bonfire out of wood 1 because I get confused on the islands there. I want
2 and I don't know what else he put in it. He's the 2 to say it was St. John's. It could have been
3 one who always makes the fires, not me. 3 St. Barts. St. John or St. Barts, and then we would
4 Q Who else was present? 4 fly straight to Jeffrey's island.
5 A Just him and I. 5 Q Okay. Did you ever go anywhere else on
6 Q Were your kids there? 6 the helicopter?
7 A No. They were inside sleeping. 7 A No.
8
9
10
Q
Q
A
And what beach was this?
It wasn't a beach. It was in my backyard.
What's your address?
8
9
10
Q
helicopter?
Were you ever on the helicopter with
and Ghislaine Maxwell as the pilot of the •
11 A At that time? 11 A No.
12
13
■
Q
I
A
Um-hum. 12
13
14
Q
pilot?
Were you ever on the helicopter with
•
and Ghislaine Maxwell as the
15 A Yes. 15 A No.
16 Q Who were your neighbors? 16 Q Do you recall telling Sharon Churcher that
17 A Sweet people. Ray and -- I could look on 17 you were?
18 my phone if you want. 18 A No.
19 Q No, thank you. Do they still live there? 19 Q Did you see the press article in which
20 A Yes. 20 Sharon Churcher reported that you were?
21 Q Do you keep in touch with them? 21 MR. EDWARDS: Objection. I'd just ask
22 A Last time I talked to them was a few 22 that if you're going to ask this witness about a
23 months ago. 23 specific article I'd like for her to see the article.
24 Q Did they see the fire? 24 Otherwise she's not going to testify about it.
25 A They've seen many fires that we've had. 25 If you have something to show her, then,

Agren Blando
Document & Video,
07/30/20
Page 217 Page 219
1 please. 1 flying on a helicopter with Ghislaine Maxwell?
2 Q (BY MS. MENNINGER) Do you recall seeing a 2 A I believe that it was taken out of
3
4
5
6
7
press article in which Sharon Churcher reported that
you were on a helicopter with
Ghislaine Maxwell as the pilot?
-
MR. EDWARDS: Again, I'll let you answer

and
the question once she's looking at the document that

3
4
5
6
7
-
context. Ghislaine told me that she flew
■
in. And Ghislaine likes to talk a lot of
stuff that sounds fantastical. And whether it's true
or not, that is what I do recall telling Sharon
Churcher.
8 you're being asked about. 8 Q So you told Sharon Churcher that Ghislaine
10
11
9 MS. MENNINGER: You're not letting her
answer a question about whether she recalls a
particular press statement?
9
10
11
Maxwell is the one who told you that she flew
A
in the helicopter?
I told Sharon Churcher that Ghislaine flew
•
12 MR. EDWARDS: I will let her answer every 12 onto the island, based upon what
13 question about the press statement as long as she 13 Ghislaine had told me.
-
sees the press statement. I'm okay with that. She Q Not based upon what had told
14
15 can answer all of them.
14
15 you, correct?
-
16 MS. MENNINGER: No, there is a rule of 16 A Correct.
17 civil procedure that allows you to direct a witness 17 Q Did you ever ask Sharon Churcher to
18 not to answer a question when there's a claim of 18 correct anything that was printed under her name,
19 privilege. 19 concerning your stories to Sharon Churcher?
20 What privilege are you claiming to direct 20 A I wasn't given those stories to read
21 her not to answer this question? 21 before they were printed.
22 MR. EDWARDS: I thought that you wanted 22 Q After they were printed did you read them?
23 accurate answers from this witness. If the -- 23 A I tried to stay away from them. They were
24 MS. MENNINGER: I asked her if she 24 very hard. You have to understand it was a very hard
25 recalled something -- 25 time for me and my husband to have to have this
Page 218 Page 220

1 MR. EDWARDS: If the sole purpose is to 1 public -- we didn't think it was going to be this
2 just to harass her -- 2 publicly announced and that big. So we turned off
3 MS. MENNINGER: I asked her if she 3 the news and we stopped reading so many things.
4 recalled something -- 4 Q You didn't read the articles about your
5 MR. EDWARDS: Then that's just not going 5 stories to Sharon Churcher --
6 to be what's happening today. 6 A I've read some articles --
7 Q (BY MS. MENNINGER) All right. So you're 7 Q Let me just finish. You did not read the
8 refusing to answer a question about whether you 8 articles published by Sharon Churcher about your
9 recall a particular press statement -- 9 stories to Sharon Churcher?
10 MR. EDWARDS: She's -- 10 A I have read some articles about what
11 Q (BY MS. MENNINGER) -- is that true? 11 Sharon Churcher wrote. And a lot of the stuff that
12 MR. EDWARDS: She is not refusing to 12 she writes she takes things from my own mouth and
13 answer any questions. She -- 13 changes them into her own words as journalists do.
14 A I'm not refusing to answer. I just want 14 And I never came back to her and told her
15 to see the article you're talking about so I can be 15 to correct anything. What was done was done. There
16 clear in my statement. 16 was nothing else I can do.
17 Q (BY MS. MENNINGER) Do you recall seeing a 17 Q So even if she printed something that were
18 press article written by Sharon Churcher reporting 18 untrue you didn't ask her to correct it, correct?
-
19 that you flew on a helicopter with and 19 A There was things that she printed that
-
20 Ghislaine Maxwell as the pilot? 20 really pissed me off, but there was nothing I could
21 A No, I do not recall reading a press 21 do about it. It's already out there.
22
23
24
25
~
-
article saying that I was on a helicopter with
Q
as Ghislaine is the pilot.
■
Do you recall telling Sharon Churcher that
you had conversations with regarding him 25
22
23
24
Q
correct?
She printed things that were untrue,
MR. EDWARDS: Objection to the form.

Mischaracterization.

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Document & Video,
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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) All right. 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

Agren Blando
Document & Video,
07/30/20
Page 225 Page 227
1 you is accurate or inaccurate? 1 A Single sheets.
2 A Please show me the document. 2 Q And did you write a long document or a
3 Q You can't say from the top of your head 3 short document? What was it?
4 whether any inaccurate statement has been attributed 4 A I can't recall how long the document was,
5 to you in the press? 5 but I would say it would be a few pages.
6 A Please show me a document and I will tell 6 Q And other than asking you to write
7 you. 7 whatever you remember about , did she
8 Q Are you refusing to answer my questions 8 give you any other directions about what you should
9 about your knowledge of whether inaccurate statements 9 write?
10 have been attributed to you in the press? 10 A She was interested in two things, really.
11 A Are you refusing to give me the documents 11 How Epstein got away with so many counts of child
12 to look at? 12 trafficking for sex and how was
13 Q Are you refusing to answer the question? 13 involved in it. Those were her two main inquiries.
14 A I am refusing to answer the question based 14 Q What did she ask you to write?
15 upon the fact that you are not being fair enough to 15 A She asked me to write about .
16 let me see the document in order to give you an 16 Q Did she tell you to put it in your own
17 honest answer. 17 handwriting?
18 Q Ms. Giuffre -- 18 A No, she just asked me to write down what I
19 A Yes. 19 can remember.
20 Q -- we are talking about press that has 20 Q Did you give her everything that you
21 been published on the Internet, correct? 21 wrote?
22 A Yes. 22 A Did I give her the whole entire pages that
23 Q Do you have access to the Internet? 23 I wrote?
24 A Yes. 24 Q Yes.
25 Q Have you looked on the Internet and read 25 A Yeah, I wrote pages for her specifically.
Page 226 Page 228

1 articles that attribute statements to you about 1 Q In your own handwriting?
2 Ghislaine Maxwell? 2 A In my own handwriting.
3 A Yes. 3 Q And what you wrote, was that true?
4 Q Do you know any statement that has been 4 A Yes.
5 attributed to you in a press article on the Internet 5 Q And did you get paid for those pieces of
6 about Ghislaine Maxwell that is untrue? 6 paper?
7 MR. EDWARDS: Same objection. Same 7 A Not for the papers, I don't believe.
8 instruction. 8 Q Okay. Have you gotten paid when they've
9 A Please show me a specific document. 9 been reprinted?
10 Q (BY MS. MENNINGER) Do you know of any 10 A No.
11 such statement about Ghislaine Maxwell attributed to 11 Q Have you negotiated any deal with Radar
12 you by the press that is inaccurate? 12 Online?
13 A If you could please show me a specific 13 A No.
14 document. 14 Q Have you negotiated any deal with Sharon
15 Q Tell me what Sharon Churcher asked you to 15 Churcher for the purpose of publishing those pieces
16 write for her. 16 of paper?
17 A Any knowledge that I had about my time 17 A Not those pieces of paper.
18 with . 18 Q When did you write those pieces of paper?
19 Q And did you write it? 19 MR. EDWARDS: Object to the form.
20 A Um-hum. 20 A A week before she came out.
21 Q What did you write it in or on? 21 Q (BY MS. MENNINGER) And when did you give
22 A Paper. 22 them to her?
23 Q What kind of paper? 23 A When she came out.
24 A Lined paper. 24 Q When was that?
25 Q Was it in a book or single sheets? 25 A Sometime, I believe, in early 2011.

Agren Blando
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1 Q What did you get paid for, if not for 1 that you were 16 years old?
2 those pieces of paper? 2 A No. I think -- I think they had played
3
4
5
6
7
- A
I was paid for the picture with
-
with his arm around me, Ghislaine in the
background. And I was paid for the, I guess, the
print of the stories.
3
4
5
6
7
the guessing game and I was 17.
Q And so Ghislaine Maxwell did not tell
Speculation.
that you were only 16?
8 Q (BY MS. MENNINGER) Anything else? 8 Q (BY MS. MENNINGER) In your presence?
9 A No. 9 A I don't remember the exact conversation.
10 Q You were not paid for those pieces of 10 I just remember they liked to play the guessing game
11 paper? 11 a lot.
12 A No. 12 Q And so you don't recall Ghislaine Maxwell
13 Q All right. And how many pieces of paper 13 telling in your presence that you were
14 did you write? 14 quote, only, really only 16, right?
15 A Like I said, I'm rounding it around three. 15 A Correct, I don't remember that.
16 Q Three pieces of paper? 16 Q And if that were in the paper, that would
17 A That's what I -- I don't remember to be 17 be untrue, correct?
18 exact on a number. I'm sorry. But over three pages. 18 A Correct.
19 Q And you wrote those sometime in 2011? 19 MS. MENNINGER: I think now might be a
20 A The week that she was coming out to see 20 good time for a break.
21 me. 21 THE DEPONENT: Thank you.
22 Q And you gave them to her, right? 22 MR. EDWARDS: Okay. Sounds good.
23 A I gave them to her. 23 THE VIDEOGRAPHER: We're off the record at
24 Q Did you keep a copy of that? 24 2:45.
25 A No. 25 (Recess taken from 2:45 p.m. to 2:55 p.m.)
Page 230 Page 232

1 Q Did you rip them out to make them look 1 THE VIDEOGRAPHER: We're back on the
2 like they came out of a journal? 2 record at 2:55.
3 A No. 3 Q (BY MS. MENNINGER) Do you have any
4 Q Were you directed to make them look like 4 photographs of yourself either nude or in a sexually
5 they came out of a journal? 5 compromising position that you claim were taken by
6 A No. 6 Ghislaine Maxwell?
7 Q Do you know why your lawyer would have 7 A I do not have any of those in my evidence.
8 told the federal judge in New York that that's what 8 But if you ask Ghislaine Maxwell, she would have
9 you did? 9 plenty.
10 MR. EDWARDS: Object to the form. 10 Q Do you have any in your storage boxes in
11 A My lawyer in New York? 11 Sydney?
12 Q (BY MS. MENNINGER) Um-hum. 12 A No.
13 A Ripped them out of a journal? 13 Q Do you know whether your attorneys have
14 Q Said that you had. Do you know why she 14 any such photographs that you claim were taken by
15 would have said that? 15 Ghislaine Maxwell?
16 A Maybe she thought that I did. 16 A No.
17 Q But you didn't? 17 Q You don't know or they don't have them?
18 A They were just pieces of paper written for 18 A I don't know. And I don't think they have
19 Sharon Churcher's purpose. 19 them. If they had them, they would have told me.
20 Q And not directed to look like they came 20 You should ask your client. She's got plenty of
21 from a journal? 21 them.
22 A Nobody told me to make them look like they 22 Q What type of camera did Ghislaine Maxwell
23 came from a journal. They were just pieces of paper 23 use?
24 that I wrote down for Sharon Churcher. 24 A It was a black camera. And it had a, I
25 Q Did Ghislaine Maxwell tell 25 don't know the types and names of them, but the lens

Agren Blando
Document & Video,
07/30/20
Page 233 Page 235
1 that goes out. 1 you were doing with Ghislaine Maxwell?
2 Q Was it digital or single reflex? 2 A Yes.
3 A Again, I don't know types of cameras. I 3 Q Did you tell him what you were doing to
4 mean, I use my phone for using a camera. So it's a 4 other people?
5 black camera and it had a lens that you could put out 5 A I don't think I told him about many other
6 further or bring back. 6 people, no.
7 Q Did you ask her to take any photographs of 7 Q What people did you tell him about?
8 you? 8 A Mainly Ghislaine and Jeffrey.
9 A No. She asked to take photographs of me. 9 Q When did you tell him that?
10 Q Was it a film or a digital camera? 10 A From the start.
11 A I never saw how she printed them out. 11 Q When was the start that you told him?
12 Q What's the first time you told anybody 12 A From, I wouldn't say the first meeting,
13 that you had been sexually trafficked? 13 but I told him around that time.
14 MR. EDWARDS: Form. 14 Q And what did tell you to
15 A Tony Figueroa, my ex-boyfriend, knew some 15 do?
16 of the stuff that was happening, though I did not go 16 A He didn't mind what I had to do. Again,
17 in great detail to him, being that he's my boyfriend. 17 he was another guy that used me because I made lots
18 And then the first person I really opened up to about 18 of money, and he didn't tell me to do anything.
19 everything was my husband. 19 Q Did he tell you not to tell the police?
20 Q (BY MS. MENNINGER) Did you tell Tony 20 A No, he didn't tell me not to do anything.
21 Figueroa that you were forced to have sex with 21 Q Did he tell you to tell the police?
22 Jeffrey Epstein? 22 A Again, he told me not -- he didn't tell me
23 A Yes. 23 to do anything.
24 Q Did you tell Tony Figueroa you were forced 24 Q When did you tell your parents that you
25 to have sex with Ghislaine Maxwell? 25 were sexually trafficked by Jeffrey Epstein?
Page 234 Page 236

1 A Yes. 1 A After I had my kids.
2 Q Did you tell that Ghislaine 2 Q When did you tell your parents that you
3 Maxwell sent you to have sex with famous people? 3 were sexually trafficked by Ghislaine Maxwell?
4 A Yes. 4 A I told them the same time about Jeffrey
5 Q When did you tell that? 5 and Ghislaine. So sometime after I had my children.
6 A During conversations. Like, I'd call him 6 Q After you had had all three children or
7 from places that I was at and just talk to him. And 7 after you had your first child?
8 like I said, I wouldn't get into great detail about 8 A I think after I had all three of my
9 things. But, you know, I had to be with this person 9 children.
10 or that person today and -- 10 Q What was the last year in which you had a
11 Q Did you tell not to call the 11 child?
12
13
14
15
police?
A No.
- enjoyed his lifestyle with me.

So he wouldn't have gone to the police.
Q Did you tell that
12
13
14
15
A
Q
2010.
So you believe you told your parents
sometime after 2010 that you had been sexually
trafficked?
16
17
18
19
20
you were sexually trafficked?
A You know, I don't know what I told
him, but I didn't get into detail with him.

Q What do you think you told him?
-
at the time. I know he asked me and I think I told
16
17
18
19
20
A
Q
Yes.
You didn't tell your parents that you had
a lawsuit entitled Jane Doe 102 versus Jeffrey
Epstein in 2009?
A I wasn't very close with my parents.
21 A That I wasn't just massaging these people. 21 Q Why not?
22 Q Did you tell him what you were doing with 22 A We just had a hard relationship.
23 Jeffrey Epstein? 23 Q Why?
24 A Yes. 24 A Because we did. I don't know why. Some
25 Q Did you tell what 25 people just don't get along.

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Document & Video,
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Page 237 Page 239
1 Q Do you get along with your parents now? 1 been through. I think for ten, however long many
2 A I get along with my parents now, yes. 2 years, I mean, over ten years, I had tried to start a
3 Q Okay. Have you ever told anyone that you 3 new life, become a new person. And I wanted to put
4 were a sex slave for four years? 4 all that stuff behind me and not think about it. But
5 A Under the assumption that I got my dates 5 after you have children, something changes in you and
6 wrong, yes, I probably have. 6 you just want to stand up and do the right thing and
7 Q And that's not true, correct? 7 protect any other children from having to go through
8 A Not because I didn't mean it to be true. 8 this.
9 Just because I didn't know my dates. 9 Q Did you tell your parents how much money
10 Q So four years is not two years, correct? 10 you received from your settlement with Jeffrey
11 MR. EDWARDS: Object to the form. 11 Epstein?
12 A Four years is not two years. 12 A No. That is a -- I think there's like a
13 Q (BY MS. MENNINGER) What did your parents 13 non-disclosure statement. I don't know exactly what
14 say when you told them that you had been sexually 14 the legal term is, but --
15 trafficked by Jeffrey Epstein and Ghislaine Maxwell? 15 Q Did you send any money to your parents?
16 A I believe they were disgusted. 16 A No, I don't -- no. No, I've never sent
17 Q What did they tell you to do or to not do? 17 money to my parents.
18
19
20
21
22
A
time?
A
I don't remember the exact conversations
that we had, but they weren't happy.
Q Were they both on the phone at the same
No.
18
19
20
21
22
Q
Q
A
A
Who is
One of
-
Did you talk to
shady friends.
your involvement with Jeffrey Epstein?

No.
?
about
23 Q Who was on the phone first? 23 Q Did you ever live with ?
24 MR. EDWARDS: Object to the form. 24 A No, he used to come over to my house.
25 A I don't know. 25 Q Between 2000 and 2002 did you ever have
Page 238 Page 240

1 Q (BY MS. MENNINGER) You were in Australia 1 any interactions with law enforcement?
2 at the time, correct? 2 A Yes.
3 A Yes. 3 Q When?
4 Q They were not? 4 A When I tried to break away from Jeffrey
5 A Yes. 5 and Ghislaine, I started making myself unavailable.
6 Q Have they ever been to see you in 6 And I got a job at Road House Grill. And Tony used
7 Australia? 7 to come pick me up in the afternoons, at nighttime,
8 A My dad has. 8 and he'd sit at the bar. And there's this big cup
9 Q Has your mom ever been to see you in 9 that's got tips in it.
10 Australia? 10 I was in the back room. And I had to --
11 A No, my mom is afraid of flying. 11 first you have to sign out and you have to take off
12 Q When did your dad come to see you in 12 your aprons, put your aprons away. And there's a
13 Australia? 13 whole bunch of cleaning up stuff you have to do.
14 A The birth of my son, my first one in 2006. 14 In that time period, Tony grabbed money
15 And then, I believe in 2010 when my daughter was 15 from a cup that had money in it. That was for the
16 born. 16 bartenders for their tips. My boss called me the
17 Q And did you have this conversation with 17 next day. He told me that I had stolen the money,
18 your dad about this in person or on the phone? 18 which I hadn't. And I came back and I returned the
19 A I've had conversations with him about it 19 money after I confronted Tony about it. Gave the
20 since. 20 money back to him and he said, I'm sorry, but it's
21 Q I'm talking about the first time you had a 21 just law that I have to call the police. So he
22 conversation with your dad. 22 called the police.
23 A On the phone. 23 And knowing that Jeffrey has got the Palm
24 Q What caused you to tell him in 2010? 24 Beach Police Department in his pocket, I went to
25 A I was just starting to accept what I had 25 Jeffrey Epstein and I told him what had happened.

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Document & Video,
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Page 241 Page 243
1 And Jeffrey said, Don't worry about it. Let me take 1 never heard anything about it ever again.
2 care of it for you. 2 Q Did you ever check to see if you had a
3 Q Okay. I'm sorry. When did you have 3 warrant out?
4 interaction with law enforcement, then? 4 A No. Jeffrey told me that he took care of
5 A What year? 5 it.
6 Q Did you speak with a law enforcement 6 Q Do you think it's a problem to leave the
7 officer? 7 country when you have an outstanding warrant?
8 A I don't believe I spoke to them. Jeffrey 8 MR. EDWARDS: Object to the form.
9 handled everything. 9 Foundation. Lack of predicate.
10 Q Okay. And you said that you had finished 10 A I don't think I have an outstanding
11 your shift at -- this is at the Road House Grill, 11 warrant. Why would I -- do you have a document that
12 correct? 12 says I have an outstanding warrant?
13 A Correct. 13 Q (BY MS. MENNINGER) I'm just asking you if
14 Q You had finished your shift? 14 you believe it's a bad thing to leave the country
15 A Yeah, it was the end of the shift. 15 when you have an outstanding warrant?
16 Q Okay. And you had cleaned up and were 16 A Absolutely.
17 checking out, correct? 17 Q And you would never assist someone in
18 A Yeah, it's a completely separate part of 18 doing that, correct?
19 the -- it's like back of the house. Do you know what 19 A Correct.
20 that means, like in waitering terms? 20 Q During the year 2015, have you spoken to
21 Q (Indicating.) 21 law enforcement about any topic other than Ghislaine
22 A Yeah, back of the house. 22 Maxwell?
23 Q And what was -- who was this boss that you 23 A In 2015?
24 spoke to? 24 Q Um-hum.
25 A I can't remember his name. 25 A Did I talk to any law enforcement about
Page 242 Page 244

1 Q Okay. 1 Ghislaine Maxwell?
2 A But, I mean, he was very nice. He didn't 2 Q About anything other than Ghislaine
3 want to but he just had to because it's just the law. 3 Maxwell?
4 You know, the money was returned to him, but he still 4 MR. EDWARDS: And I would just object at
5 had to do what he had to do. 5 this point in time and instruct the witness not to
6 Q You paid him back the money the next day? 6 convey any answers as to who she has or who she has
7 A Very next day. 7 not disclosed until such time as the Court rules on
8 Q And did you ever speak with the Palm Beach 8 the current outstanding motion.
9 County Sheriff's Office about it? 9 I know that we have some obligations to
10 A You know, I don't know if they called me 10 fulfill by the 4th. We intend to do that. And I
11 or not, but I know that since my boss told me he had 11 also recognize we may be back to answer some of these
12 to call the police, I went to Jeffrey. And Jeffrey 12 questions. But for today, she's not going to answer
13 said he'd handle it. 13 those questions.
14 Q How old were you at the time? 14 MS. MENNINGER: Well, I'm just going to
15 A I don't know, 18, maybe 19. 15 ask them and --
16 Q You weren't a juvenile, were you? 16 MR. EDWARDS: I understand.
17 A Well, juvenile being under 18, no. 17 Q (BY MS. MENNINGER) Have you spoken to any
18 Q Is that the only interaction with law 18 law enforcement in Colorado since the beginning of
19 enforcement that you had between 2000 and 2002? 19 January 2015?
20 A Correct. 20 A I can't answer that question right now.
21 Q Were you, in fact, charged with theft 21 MR. EDWARDS: Hold on one second. I may
22 based on that case? 22 be able to get you an answer to that question. Can I
23 A No charges were ever brought to me. 23 take -- can I just take a quick break, and I think I
24 Q Do you know if they were filed? 24 can answer that particular question for you?
25 A No. Jeffrey told me he'd handle it, and I 25 MS. MENNINGER: I'm not asking you to

Agren Blando
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1 answer any questions -- 1 other terms of his probationary period?
2 MR. EDWARDS: Fine. 2 A No. He went to everything that he was
3 MS. MENNINGER: -- Mr. Edwards. 3 supposed to go to.
4 MR. EDWARDS: Fine. 4 Q Has he paid his fines?
5 MS. MENNINGER: I appreciate it, but I'm 5 A Yes, as far as I know.
6 asking the witness to answer these questions. 6 Q Describe for me the contract that you had
7 MR. EDWARDS: I know, I'm just trying to 7 with the Mail On Sunday?
8 help you today. 8 A Could you be a little bit more specific?
9 For today, don't answer the questions. 9 Like --
10 THE DEPONENT: I don't mind explaining. 10 Q Have you had more than one contract with
11 MR. EDWARDS: I know, but you -- 11 the Mail On Sunday?
12 THE DEPONENT: Okay. 12 A Well, there was one contract for the
13 MR. EDWARDS: I wanted to help. 13 picture. And that was to pay me 140,000 for the
14 THE DEPONENT: Okay. 14 picture. And then two stories were printed after
15 Q (BY MS. MENNINGER) So have you spoken to 15 that for the amount of 10,000 each.
16 any law enforcement officers in Colorado since 16 Q Is that the only money that you received
17 January of 2015 until today? 17 from the Mail On Sunday?
18 A I am not answering that question. 18 A Correct.
19 Q Have your attorneys spoken to any law 19 Q Did you receive any money for syndication
20 enforcement officers in Colorado since the beginning 20 of the photograph?
21 of 2015 until today? 21 A Isn't that what the 140 was for?
22 A I'm not answering that question. 22 Q I'm asking you.
23 Q Have you been living with your husband in 23 A Well, I don't really know what syndication
24 Australia since October of 2015? 24 means.
25 A Yes. 25 Q Did you have a written contract with the
Page 246 Page 248
1 1 Mail on Sunday?
I
I
I
I
I
I - 2
3
4
5
A
Q
A
Yes.
Where is that contract right now?
I don't know. I've moved that many times.
I -- I lose paperwork wherever I go.
I
7
I
I
Q • . 6
7
8
Q
Sydney?
A
Is it possible it's in the boxes in
I don't think I kept it, to be honest.
I 9 Q Did you ever refer back to it after you
■
11
I
I • . 10
11
signed it?
A I know I kept it for a short while, but I
mean, like I said, I've moved countries twice in the
■
12
I last two years and three different houses. So the

■
13
paper trail is lost. I don't know where it would be.
■
14
15 Q 15 Q Did you receive it via e-mail?
A No. I received it -- Sharon Churcher
■
16
I handed it to me by paper.
■
17
Q And you signed it?
■
18
A I signed it.
■
19
Q And then did you make a copy of it?
■
20
■
■
■
■
25
I
I
I
I
I
- .
21
22
23
24
25
A
Q
A
hers.
Q
No.
You never had a copy of it?
Well, I had my own copy. I'm sure she has
Do you recall there being a period of

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1 exclusivity? 1 who have been interested in it and I still don't know
2 A Yes. 2 if I want to do it yet. I mean, I think there's a
3 Q What was that period? 3 lot more that can go into it, you know.
4 A I believe it was like a three-month period 4 Q You were actively sending the manuscript
5 or something. 5 to people for purposes of having them reach a deal
6 Q Okay. And what other terms of the 6 with you and publish it, correct?
7 contract, do you recall? 7 A No deal was ever talked about. What we
8 A I couldn't talk to any other news 8 talked about was the possibility of publishing it, is
9 publication about the story. 9 it publishing-worthy, would I need to get a
10 Q Anything else? 10 ghostwriter. You know, this is the first time I've
11 A Not that I know of. 11 ever written a manuscript so I didn't know what I was
12 Q Were you happy when the period was up? 12 doing.
13 A Well, I mean, at that time I wanted to 13 Q Okay. You contacted Jarred Weisfeld,
14 write about my story. So I guess, yes, I was happy 14 correct?
15 when that period was up. 15 A Correct.
16 Q And you were actively writing a book at 16 Q I'm going to mark a document as
17 that time, correct? 17 Defendant's Exhibit 16. It is a composite exhibit.
18 A My manuscript. I've never published it. 18 (Exhibit 16 marked.)
19 Q You were writing the manuscript at the 19 MR. EDWARDS: Thank you.
20 time of your period of exclusivity with Sharon 20 Q (BY MS. MENNINGER) I'm not going to ask
21 Churcher, correct? 21 you to read every single page of this, but if you
22 A Those three months were just craziness. I 22 look at the first page.
23 think I started after that. 23 A Um-hum.
24 Q You think you started writing the book 24 Q Can you tell what this is in terms of what
25 after the 90 days were up? 25 type of document?
Page 250 Page 252

1 A Yeah. 1 A It's an e-mail from me to Jarred.
2 Q And then you attempted to sell that 2 Q Okay. And there's also e-mails from
3 manuscript, correct? 3 Jarred to you on the same page, correct?
4 A I didn't attempt to sell it. I went to 4 A Yes.
5 other publications, like, what do you call them? 5 Q And can you tell -- I just presume that
6 People -- I'm trying to think of the name of the 6 you know that you have turned over documents in this
7 word. People who publish books, not like a newspaper 7 case; is that true?
8 or anything. And I inquired about what they thought 8 A Yes.
9 of my manuscript and if they thought it was, you 9 Q All right. And do you see at the bottom
10 know, a good story. And, yeah. 10 it's got your name and some page numbers in the
11 Q So you sent the manuscript to these people 11 bottom right-hand corner?
12 for the purposes of trying to publish the book, 12 A Giuffre 003529?
13 correct? 13 Q Right.
14 A Some people, yes. 14 A Yes.
15 Q And you were trying to get money from the 15 Q So you understood that your lawyers sought
16 book publication, correct? 16 from you e-mails, for example?
17 A Well, I wasn't going to sell it to them 17 A Yes.
18 for free. 18 Q And searched your computer, correct?
19 Q But you were unsuccessful in finding 19 A Correct.
20 someone to publish it, correct? 20 Q And printed out e-mails, correct?
21 A Well, I was always on the fence with it. 21 A Yes.
22 I wasn't too sure if I wanted to or didn't want to. 22 Q And these look like some of the e-mails?
23 I was more seeking judgment based upon these people 23 A Yes.
24 who have done this plenty and plenty of times. 24 Q Okay. Do you have any reason to believe
25 Still to this day, I mean, I've had people 25 that e-mails produced by your lawyers with your name

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1 on the e-mail address line are anything other than 1 A Yes.
2 your e-mail? 2 MR. EDWARDS: I object just to the
3 A No, they're my e-mails. 3 apparent mischaracterization.
4 Q Okay. Did anyone else use your e-mail 4 MS. MENNINGER: Of 2012?
5 account? 5 MR. EDWARDS: Being the first e-mails.
6 A No. 6 MS. MENNINGER: I only meant the first
7 Q Okay. 7 pages of this composite exhibit.
8 A I mean, well, my husband uses it 8 MR. EDWARDS: Okay.
9 sometimes. My kids use it for games. 9 MS. MENNINGER: But I appreciate your
10 Q Okay. 10 clarification.
11 A But that's about it. 11 MR. EDWARDS: Okay.
12 Q So if an e-mail is signed XOXO Jenna -- 12 Q (BY MS. MENNINGER) The first e-mails of
13 A Yes. 13 this composite exhibit are dated July of 2012,
14 Q -- is that you? 14 correct?
15 A Correct. 15 A Correct.
16 Q All right. And do you believe anyone else 16 MR. EDWARDS: The first page. As opposed
17 in your family was communicating with 17 to the first in the chronological timeline.
18 18 MS. MENNINGER: Yes.
19 A No, no one else. 19 MR. EDWARDS: Okay.
20 Q All right. What was the purpose of you 20 Q (BY MS. MENNINGER) If you flip sort of
21 communicating with Jarred? 21 anywhere towards the back, can you also see that
22 A We were trying to figure out if my book 22 you -- there are e-mails between yourself and Jarred
23 was -- my manuscript was ever published or 23 in 2011?
24 publishable. And this was at a time where there was 24 A Excuse me. And which page?
25 a lot of controversy about what's going on around JE. 25 Q Really, you can take your pick anywhere
Page 254 Page 256

1 And when I say JE, I mean Jeffrey Epstein. 1 from the back of that exhibit?
2 It was a very scary thing for a lot of publishers to 2 A Yeah, yeah, I see what you're talking
3 even consider taking it on because Jeffrey is a very 3 about.
4 powerful person. 4 Q Here. Why don't I direct you to the
5 Q Did you send your manuscript to Jarred? 5 bottom right is Giuffre 3563. Now, it's going to be
6 A I believe I did. 6 a little tricky to find, but it's about eight
7
8
9
Q
on to other people like
-
All right. Did you ask Jarred to send it

7
8
9
pages -- I'm sorry, six pages from the back of the
composite exhibit.
A Yes.
10
11
12
met
A
Q - I can't -- I can't recall. I believe I

through Jarred.
(BY MS. MENNINGER) Okay. I'm going to
10
11
12
Q Do you see on that page an e-mail from
yourself to Jarred from June 7th of 2011?
A Yes.
13
14
15
16
17
ask you to turn -- well, on the first page, the
second e-mail says, is Epstein too big for
Jarred and
A Yes.
-
Does that refresh your recollection that
-
had something to do with one another?
13
14
15
16
17
Q And in that e-mail you write: Dear Jarred
Weisfeld, We spoke on the phone going back a couple
months regarding the story I am writing called, The
Billionaires Playboy Club.
Right?
18 Q Okay. And on the second page in the 18 A Correct.
19
20
21
22
23 A
-
middle of the page, just to be clear, is that an
indication that,
book, XOXO Jenna.
definitely does not want the
Is that what you wrote?

Yes.
19
20
21
22
23
Q I am no longer under any contract and
would like to ask you to review my synopsis and if
you are interested I would love for you to represent
me as my literary agent.
Correct?
24 Q And these first e-mails are in 2000 -- 24 A Correct.
25 July of 2012, correct? 25 Q I've included some of the press that has

Agren Blando
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1 covered the ongoing case of Jeffrey Epstein, the 1 one? All right.
2 world's richest pedophile. And my good friend and 2 MR. EDWARDS: What are we on now, 17?
3 journalist Sharon Churcher has a few from her 3 MS. MENNINGER: 17.
4 articles that she has written to send to you as well. 4 (Exhibit 17 marked.)
5 Correct? 5 Q (BY MS. MENNINGER) Very similarly, can
6 A Correct. 6 you take a look at this exhibit? It is a composite
7 Q I am very serious about getting my book 7 of documents produced by your attorneys with various
8 published and believe this story will cover many 8 Bates ranges, Bates numbers in between Giuffre 2750
9 genres of interest, not only by those following the 9 and 3928.
10 lengthy case, but it is also a woman's story of 10 A 2750 and --
11 glitz, glamour, sorrow, compassion, and true love. I 11 Q I think -- I think the last page is 3927,
12 hope you enjoy. 12 but it does not contain all of -- I'm sorry, 3928.
13 Correct? 13 But it does not contain all of the pages in between,
14 A Correct. 14 just to let you know.
15 Q Signed, yourself? 15 A Okay. Is there one specific that you want
16 A Yes. 16 me to look at?
17 Q So in about June you sent to Jarred 17 Q No, if you can just take a look at the
18 Weisfeld a synopsis and were asking him to represent 18 first page.
19 you as your literary agent to sell the book, correct? 19 A Okay.
20 A Yes. 20 Q And tell me if you know who this person
21 Q And you characterized Sharon Churcher as 21 is?
22 your good friend, correct? 22 A Paulo Silva is somebody who works for the
23 A Well, at that time -- you have to 23 Mail On Sunday. And he was the one in charge of
24 understand, Jarred and Sharon are very close. Sharon 24 paying me.
25 is the one who introduced me to Jarred. And that's 25 Q Paying you for what?
Page 258 Page 260

1 just being nice. 1 A The 140 plus the 10 and the 10.
2 Q Do you disagree that Sharon Churcher was 2 Q Okay. And did he also pay you on an
3 your good friend at that time? 3 ongoing basis for further sales of the photograph of
4 A Well, at that time I did trust her a lot 4 yourself and ?
5 more than what I do now. 5 A No, it was a set fee of 140 plus the 10
6 Q Why did you change your opinion of Sharon 6 and 10. But they broke it up for some reason. So as
7 Churcher? 7 you can see here, Thanks for transferring the money.
8 A You know, I -- I just -- I think -- I 8 I will let you know when it reaches my bank account
9 think talking to some journalists can be very 9 but just a little bit confused as I have a previous
10 dangerous, especially sometimes how words can get 10 e-mail with the amount owed at 4100. Is there still
11 taken out of context. And I'm not saying that she's 11 an outstanding amount yet to be paid.
12 a bad person. I'm just saying that just, I wouldn't 12 So they broke it up into quite a lot of
13 call her up and ask her what she's cooking for dinner 13 different fractions but it still equaled the 140 plus
14 tonight or how the family is doing. 14 the 10 and the 10.
15 Q Did you ever introduce her to your hair 15 Q Okay. If I could ask you to flip back to
16 stylist? 16 Giuffre 2758. They're in sequential order, so it
17 A No. 17 should be about eight pages back.
18 Q All right. 18 A Yes.
19 A Oh, actually, yes, I did. She did get a 19 Q All right. Do you see -- do you see that
20 haircut where I was at. 20 that's an e-mail from Paulo Silva to your e-mail
21 Q All right. 21 account?
22 MS. MENNINGER: So if I could have the 22 A Yes.
23 e-mails with Paulo Silva, please. I'm going to mark 23 Q On or about March 28th, 2011?
24 these Defendant's Exhibit -- 18 -- 17. 24 A Yes.
25 Oh, I don't know if that's -- is that just 25 Q All right. And it appears to be his

Agren Blando
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1 introductory e-mail to you. Is that a fair 1 what the terms of your agreement were with this
2 characterization of it? 2 syndication, Solo Syndication?
3 A It would be hard to say. Like, I'd have 3 A Well, like you said, it looks like half
4
5
6
7
8
to look at the first one. That's June 24th. This is
March 28th. I suppose so, if he's introducing
himself as Paulo Silva.
Q All right. And in this e-mail he
introduces himself by name and tells you that he
4
5
6
7
8
of --
In regards to your image with
-
I can confirm we've been able to sell it
quite frequently over the last few weeks. So far
we've been able to sell it to the following clients.
9 works for Solo Syndication and represents they are 9 It lists names.
10 the official syndication agency for Daily Mail and 10 So far the total sales, as of last Friday,
11 Mail On Sunday and that he's been overseeing the 11 is the number listed there.
12 syndication of your image, correct? 12 Therefore, your share is 4,487.
13 A Correct. 13 Q So let me be clear. I guess I'm asking,
14 Q All right. And then he tells you that 14 do -- do you recall what your deal was with Solo
15 with regard to your image with he can 15 Syndication?
16 confirm that they've been able to sell it frequently 16 A No, I do not recall it. I just remember
17 over the last couple of weeks. And he listed the 17 Sharon writing up the contract saying 140 plus the 10
18 names of various news agencies to whom they had sold 18 and the 10. I completely forgot about the
19 the image, correct? 19 syndication for $4,000 and 487 cents (sic).
20 A Correct. 20 Q Okay. I'm going to ask you to turn back
21 Q And then he tells you what the sales were 21 to 2754.
22 as of last Friday and then what your share of it is, 22 A 2754?
23 correct? 23 Q Correct.
24 A Correct. 24 A Okay.
25 Q And your share of it was approximately 25 Q And it's a document with the heading Solo
Page 262 Page 264

1 half of whatever the sales were, correct? 1 Syndication Limited. Is that the right page you're
2 A Yes, it looks that way. 2 on?
3 Q All right. And so then he gave you their 3 A Yes.
4 general payment terms, correct? 4 Q Dated May 23rd, 2011, correct?
5 A (Deponent perused document.) 5 A Yes.
6 Yes. Yep. 6 Q All right. And there's some handwriting
7 Q And is that syndication deal separate and 7 in the middle of the page towards the bottom.
8 apart from your deal with the Mail On Sunday to get 8 A Not my handwriting.
9 paid for the stories and a chunk -- 9 Q It's not your handwriting?
10 A Yes. 10 A No.
11 Q -- for the image? 11 Q Do you know whose it is?
12 A So I will have to correct my previous 12 A No.
13 statement. 13 Q All right.
14 Q Okay. 14 A I don't even know what it says. Does it
15 A So I forgot completely about the fact that 15 say Chai canceled and something mode? I have no idea
16 I received 4,487.50 for -- for the pictures that got 16 what it even says.
17 sold. 17 Q Okay. And it's not your handwriting?
18 Q And is it possible it was sold some more 18 A No.
19 after this date, for which you received some money, 19 Q It was produced by your attorneys,
20 correct? 20 correct?
21 A I don't believe so. I -- I didn't even 21 A I'm sorry?
22 remember this one, to be honest. So if there's any 22 Q It was produced to us by your attorneys,
23 others that you can show me, I'd be happy to look at 23 correct?
24 them. 24 A Yes. They went through and gave you guys
25 Q Well, I'm just asking you if you remember 25 everything you asked for.

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1 Q All right. 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 I have no reason to doubt. 4 written on June 5th or May 6th?
5 Q All right. 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 Q All right.
13 price, if you will? 13 A I'm confused, too.
14 A Yes. 14 Q 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 All right. 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 All right. 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 I don'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 Q 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,

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1 do you think, perhaps? 1 A Thank you.
2 A I haven't seen these e-mails since 2011. 2 So it cuts off after that, does it?
3 So -- 3 Q Um-hum.
4 Q Okay. I'm going to show you Defendant's 4 A Oh, sorry. (Pause.)
5 Exhibit 19. 5 Yep, I've read it.
6 (Exhibit 19 marked.) 6 Q All right. Do you remember that e-mail
7 Q (BY MS. MENNINGER) Who is Marianne 7 now?
8 Strong? 8 A It's going back a long time ago, but it's
9 A She's my literary agent. 9 definitely my kind of writing.
10 Q All right. And can you identify 10 Q Okay. So in the -- on the bottom of the
11 Defendant's Exhibit 19? 11 first page, 3417 --
12 A I'm sorry? 12 A Um-hum.
13 Q Can you identify what Defendant's 13 Q -- you represented to Marianne Strong that
14 Exhibit 19 is? 14 you had served four years as Jeffrey Epstein's
15 A Defendant's Exhibit 19, like the number at 15 personal and abused sex slave, correct?
16 the bottom? 16 A Correct.
17 Q No, do you know what kind of document this 17 Q That is not true, correct?
18 is? 18 A Since we have now found out the actual
19 A Oh, it's an e-mail from me to Marianne 19 dates, it is not correct.
20 Strong. 20 Q Okay. I want to turn the page, the second
21 Q All right. And at roughly what time 21 page. On the first line, the first full sentence
22 frame? 22 that begins on the first line:
23 A February 20th, 2014. 23 Even though there is over 40 women that
24 Q All right. And what were you speaking 24 were once vulnerable girls that looked like the sweet
25 with Marianne or writing with Marianne Strong about? 25 girl next door but now that they have been taken
Page 270 Page 272

1 A Can I just read it real quick and I'll 1 advantage of by this disgusting Wall Street tyrant,
2 tell you? 2 most of them have led a very unhealthy lifestyle
3 Q Sure. 3 since having served Jeffrey, such as drug addictions
4 (Pause.) 4 and prostitution and do not hold accreditation to
5 A Sure. 5 talk.
6 Q Do you remember now the topic upon which 6 You wrote that, correct?
7 you and Marianne Strong were exchanging 7 A Correct.
8 communication? 8 Q Who are the 40 women that you are talking
9 A I don't recall talking about 9 about here?
10 10 A When I spoke to the FBI, they told me that
11 . I don't know who Emily is. But I 11 there were -- and this is maybe just a guesstimate,
12 do understand what she's saying. If I win, then my 12 maybe there was more, maybe there was less that they
13 story would be a much better story to write. 13 said. But they had told me that there was a lot of
14 Q And what case was she referring to, if you 14 other victims involved in this case. And this is
15 know? 15 when I believed that after the FBI came to see me
16 A I think this was regarding probably the 16 that they were willing to reopen the case and do
17 time when I was in -- trying to get involved with the 17 something about it.
18 CVRA case. 18 Q Okay. So the FBI is the one that told you
19 Q In February of 2014? 19 that there were 40 women?
20 A Correct. 20 A It could be less than 40. It could be
21 Q Okay. And at the bottom of the page 21 more than 40. I think I just summed it up to 40.
22 there's an e-mail from you to her, correct? 22 Q You came up with 40?
23 A I haven't read that part yet. Give me one 23 A Well, I didn't just come out with 40. I
24 moment. 24 think it was around that number. It could be 46. It
25 Q Yeah. 25 could be 39. I'm not too sure to be exact.

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1 Q All right. But you based it on -- 1 the assumption that the case was being reopened, that
2 A On my speaking -- 2 they still were investigating.
3 Q -- what? 3 Q Okay. Did you believe that the FBI had
4 A -- with the FBI. 4 reopened their case in 2011?
5 Q Okay. And -- 5 A I believe that's when they first started
6 MR. EDWARDS: Just let her finish her 6 to reinvestigate and reopen it.
7 question before you answer. 7 Q And then sometime when you were in Florida
8 THE DEPONENT: Okay. 8 Jason Richards told you that they were not actually
9 MR. EDWARDS: I just want the record 9 going to continue investigating the case?
10 clear. 10 A I believe I was in Florida, yes. And he
11 Q (BY MS. MENNINGER) Who at the FBI did you 11 didn't say that -- he just said his hands were tied
12 speak with? 12 and up above, I don't know, chain of command, it
13 A I can't think of his name. I spoke to -- 13 just -- it didn't look like it was going anywhere.
14 oh, God, I can't even think of his name right now. I 14 There was no definite no and a definite yes. It was
15 spoke to a male and a female. And I also spoke to 15 just, right now there's really nothing that we can
16 Marie Villafana about everything that was happening. 16 do.
17 Q Is it Jason Richards? 17 Q All right. In the third paragraph from
18 A Jason Richards, yes. 18 the top, you said there's another major paper that
19 Q Did Jason Richards tell you that the FBI 19 has followed the story for a while that has worked
20 was reopening their case? 20 with me before and they were asking you for the
21 A He wanted to reopen the case. And the 21 exclusive story but updated and obviously the end
22 last conversation that I had with him, I can't 22 outcome from the judicial decision.
23 remember when it was, he said that he was having 23 Who was the other major paper that had
24 trouble doing it from the people above him. 24 followed the story for a while and was asking you for
25 Q Okay. When was that? 25 an exclusive story?
Page 274 Page 276

1 A Like I said, I don't know. 1 A That would -- that, just coming to mind
2 Q Was it like a year ago or two years ago or 2 must be the Daily Mail. If I said I've worked with
3 three years ago? 3 them before, the only other -- the only other, what
4 A I don't remember the last time I talked to 4 do you call them, press, that I had worked with was
5 him. I think I was in Florida the last time I spoke 5 the Daily Mail, so --
6 to him. 6 Q Okay. But you said you had held out on
7 Q And was that on the phone or in person? 7 them because Marianne had told you about her contact
8 A On the phone. 8 with Emily at the New York City Post, right?
9 Q Hmm? 9 A I have held out because you told me about
10 A On the phone. 10 your contact with Emily with the New York Post, and I
11 Q On the phone. Where was he located, if 11 appreciate you trying to make big headlines for the
12 you know, when you spoke to him? 12 story and hopefully one day the book. Yes.
13 A I don't know. 13 Q Okay. And then the last line of that
14 Q Do you have his phone number? 14 paragraph you say: I would also like to know that
15 A I have his card somewhere. Probably not 15 I'm going to profit from this as well, correct?
16 on me anymore. Like I told you, my paper trail is 16 A Correct. I'm not going to give it for
17 (indicating). 17 free.
18 Q Okay. So in the fourth line you say: 18 Q Right. All right.
19 Miraculously since I came to light with the truth in 19 (Exhibit 20 marked.)
20 speaking out against him in 2011, the FBI have 20 MS. MENNINGER: Defendant's Exhibit 20.
21 reopened the case. Which as you know, has current 21 Q (BY MS. MENNINGER) Do you recognize these
22 proceedings in which I am involved in. 22 documents -- this document, which is another
23 So what current proceeding were you 23 composite exhibit?
24 involved in on February 19th, 2014? 24 A Yes.
25 A Well, just speaking with the FBI, I was in 25 Q Do you recognize it?

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1 A Oh, like I said, I don't recognize it, but 1 Q Right.
2 it obviously comes from -- 2 A But anything they had of me.
3 Q Your e-mail address? 3 Q And Brad Edwards, who is sitting right
4 A Yes. 4 here, was your attorney at the time and you
5 Q Now, what e-mail address is that, exactly, 5 identified him as such in the e-mail, correct?
6 on the first page of this exhibit? 6 A Correct.
7 A @icloud.com, that must be from a phone. 7 Q You did not identify Mr. -- Judge Cassell
8 Q So that's different from the other e-mail 8 as your attorney in this e-mail, correct?
9 address? 9 A I knew him as a former judge, and I just
10 A Yeah, I don't actually know about that 10 wrote down, Judge Paul Cassal (sic) as it looks. But
11 e-mail address. I obviously used it. 11 he was my attorney -- I don't know if he was my
attorney at that time. But yes -- he's always --
■
12
13 Q And is the e-mail signed by your husband? 13 he's been with me since the beginning, so --
14 A No, it's signed by me. 14 Q So he's representing you in this case now,
15 Q Okay. And in the subject line you wrote 15 correct?
16 Virginia Roberts (Jane Doe 102), correct? 16 A Yes.
17 A Subject line? 17 Q But at that time you don't know if he was
18 Q The very top line of that page. 18 your attorney?
19 A Oh, yeah, I see. 19 A I think he was. I mean, I've been talking
20 Q Okay. And it was to 20 with him since the beginning. And this is dated
21 jason.richards2@ic.fbi.gov, correct? 21 2014. So I believe at this time he was my attorney
22 A Correct. 22 at the time as well.
23 Q And is that Jason Richards we were just 23 Q Okay. When do you recall first speaking
24 referring to? 24 with him?
25 A Yes. 25 A Speaking with Paul, I'm not too sure. I
Page 278 Page 280

1 Q All right. And you had some e-mails with 1 can't remember if I spoke to Paul in the phone in
2 Jason Richards over time; is that fair? 2 Australia or if I met him in person in Florida.
3 A Sure. 3 Q Do you remember when you signed any kind
4 Q These ones that came from your computer, 4 of fee agreement with him?
5 right? 5 MR. EDWARDS: Object to the form.
6 A Sure, yes. 6 A Um, the -- well, the first time I would
7 Q Okay. You talk about having spoken with 7 have signed an agreement would have been in Florida.
8 Judge Paul Cassell in this first page, correct? 8 Q (BY MS. MENNINGER) When you were living
9 A I am here to get this BS non-prosecution 9 in Titusville?
10 agreement thrown out and speaking with Judge Paul 10 A As far as my knowledge reminds me. I
11 Cassal (sic). He suggested trying to get ahold of 11 mean, I'm looking at e-mails that I can't even
12 any photos or video recordings released by the FBI to 12 remember sending. It's a possibility I could have
13 assist our case further in providing (sic) how much 13 signed earlier, but as far as I remember.
14 pedophilia occurred by Jeffrey and the many other 14 Q Okay. Do you recall ever having e-mail
15 monsters he obliged with underage girls. 15 communications with Sharon Churcher about her
16 Q Okay. 16 publishing the first serial of your book?
17 A If this is a possibility, please let me 17 A Serial, what does that mean? I'm sorry.
18 know so I can give you Brad Edwards (my attorney) his 18 Q Like a sequel.
19 contact details. Many thanks for your time and I 19 A A sequel to my book?
20 hope we should meet again. 20 Q Um-hum.
21 Q Okay. And so you were going back to Jason 21 A My book has never been published.
22 and trying to get any evidence that the FBI had about 22 Q Right. Do you remember ever e-mailing
23 your case, right? 23 with Sharon about her being the one who would publish
24 A Correct. Any photographs pertaining to 24 any subsequent follow-up book?
25 what -- myself, not of anyone else. 25 A If you have something in front of you to

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1 see and show me I would look at it. Like I said, 1 family?
2 there's a million e-mails here. I mean, there's a 2 A We've been doing well.
3 whole dead tree with e-mails I don't remember 3 Q You've been doing well?
4 sending. So -- 4 A Yes.
5 Q So you don't remember that e-mail chain, 5 Q What is your source of income right now?
6 as you sit here? 6 A My husband is the main income -- he's the
7 A Yes. 7 breadwinner and I'm a stay-at-home mom.
8 Q Okay. You have signed contingency fee 8 Q And what is his job?
9 agreements with Boies, Schiller, correct? 9 A
A Yes.
■
10
Q You've signed contingency fees with .
■
11
12 Mr. Cassell, correct? 12 Q And how long has he had that job?
13 A Correct. 13 A He got that job, I believe, in December or
14 Q Mr. Edwards and his firm? 14 January. December 2015 or January 2016. I know he
15 A Correct. 15 got the job and then we had to go through all these
16 Q Stan Pottinger; is that correct? 16 preliminary tests and everything to make sure you
17 A Correct. 17 qualify. So --
18 Q And pursuant to those fee agreements you 18 Q And what is the last paid employment that
19 understand that you would get a recovery of any money 19 you had?
20 that you won in this case, correct? 20 A The last paid employment that I had was --
21 A Correct. 21 there was that -- do you remember going back through
22 Q And what percent is that? 22 the e-mails where I had that resume and I sent it and
23 A I don't know off the top of my head. I 23 they said, What time do you want to come for an
24 think it's 40 percent. I'm not too sure, to be 24 interview?
25 honest. 25 I ended up getting the job there for two
Page 282 Page 284

1 Q Do you remember having any conversations 1 days because the place was disgusting and the boss
2 with about money that you hoped to 2 was just horrible.
3 obtain from this case or from any other source 3 I didn't get paid from them, but I got
4 related to this? 4 employed by them. And other than that, the last time
5 A I remember talking to as a 5 I worked was in -- ended in 2006 for ET Australia.
6 girlfriend telling her what cases I was involved 6 Q Did you quit that job after two days
7 with. I don't believe we ever spoke about any 7 because the place was disgusting?
8 monetary settlements. There was no number that was 8 A It was vile. Okay. They had the -- the
9 ever mentioned. I told her that I was involved in 9 whole place was closed down. The restaurant was
10 these cases. And, you know, it was just girlfriend 10 closed down for a period of, like, six months. And
11 talk between girlfriends. I never expected her to 11 he wanted me to go into this freezer area that had a
12 turn around and consort with the enemy. 12 dead rat in it and like this thick (indicating) layer
13 Q Well, it's fair to say you do hope to make 13 of mold at the bottom. And he wanted me to clean it.
14 money from bringing this lawsuit, correct? 14 Q All right.
15 MR. EDWARDS: Form. 15 A And I was just like, No.
16 A I hope to win, but that's not the only 16 Q Just checking, did you quit or did he fire
17 reason I want to win. I want to see justice come 17 you?
18 through. 18 A No, I definitely walked out of that one,
19 Q (BY MS. MENNINGER) Is money one of the 19 hands up.
20 reasons you want to win? 20 Q Okay. I'm going to do one more document I
21 MR. EDWARDS: Same objection. 21 have, quickly.
22 A More than the money, I want to see 22 (Exhibit 21 marked.)
23 Ghislaine and Jeffrey own up to what they have done 23 Q (BY MS. MENNINGER) I'll show you
24 and pay for the price, yes. 24 Defendant's Exhibit 21, another composite exhibit.
25 Q (BY MS. MENNINGER) Is money tight in your 25 Do you recognize the to and froms on this e-mail?

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1 A To Sharon Churcher from myself, yes. 1 Supposedly JE purchased her at age 14 from her
2 Q And this is the Sharon Churcher from Mail 2 family.
3 On Sunday we were discussing earlier? 3 Q Okay. And then you asked her to call to
4 A That's correct. 4 discuss that, correct?
5 Q And these are from February of 2011, 5 A I tried to call. The line was busy.
6 correct? 6 Could you call concerning the question you asked?
7 A Yes. 7 Q Right.
8 Q Okay. 8 A Yes.
9 A I mean, it's just assuming that we're not 9 Q All right. Defendant's Exhibit 22.
10 looking at Australian backwards dates. 10 (Exhibit 22 marked.)
11 Q Okay. Well, a few pages back, where it 11 THE DEPONENT: Thank you.
12 says 2/19/2011. 12 Q (BY MS. MENNINGER) Okay. Do you
13 A Oh, yeah, yeah. 13 recognize these series of e-mails?
14 Q All right. If I could direct your 14 A So far. I mean, it's definitely from me
15 attention to one of the pages, it's 3676 in the lower 15 to her. Or actually, Michael Thomas is the
16 right-hand corner. 16 photographer that worked with her, just to be clear.
17 A 3676. 17 Q And is she one of the two -- the
18 Q Now, these are in sequential order. 18 recipients of the first-page e-mail? You and she
19 They're not in Bates stamp order so you might have to 19 received an e-mail from Michael Thomas; is that
20 look at the dates on the top to find one that's 20 right?
21 February 19th of 2011. 21 A Yes.
22 THE DEPONENT: Do you know which page it 22 Q Okay.
23 is? 23 MR. EDWARDS: I think she wants you to
24 MR. EDWARDS: Well -- 24 look and make sure you recognize them.
25 MS. MENNINGER: It's almost in the middle. 25 Q (BY MS. MENNINGER) Yeah, do you recognize
Page 286 Page 288

1 MR. EDWARDS: It's like what she's saying 1 the document, the e-mails?
2 is that -- 2 A Like I said, these are back in 2011, but
3 MS. MENNINGER: If you look at the date at 3 it's from my e-mail address. I recognize that. I
4 the top -- 4 recognize Sharon's name and I recognize Michael
5 MR. EDWARDS: If you look at the top it 5 Thomas.
6 says 2/19/2011. That's not it. It's like half a 6 Q Do you have any reason to doubt that the
7 page. Keep going. 7 e-mails from March of 2011 --
8 A 2/13, 2/17, 2/18, 2/19 -- 2/19/2011. 8 A I don't have any --
9 Q (BY MS. MENNINGER) If it says 3676 in the 9 Q -- from yourself and Ms. Churcher are
10 lower right-hand corner? 10 accurately reflected from the documents taken from
11 A Yes. 11 your computer here?
12 Q Okay. Is that an e-mail that you sent to 12 A I have no reason to doubt that.
13 Sharon Churcher in response to an e-mail that Sharon 13 Q Okay.
14 Churcher sent to you? 14 (Exhibit 23 marked.)
15 A To Sharon Churcher from Jenna, Subject 15 Q (BY MS. MENNINGER) Defendant's
16 R-E, received, yes. 16 Exhibit 23. Again, e-mails between your e-mail
17 I tried to call the line was busy. Could 17 address and Sharon Churcher from May of 2011.
18 you call concerning the question you asked? 18 Do you recognize your e-mail address?
19 Q All right. And that was in response to an 19 A Yes.
20 e-mail just below it you received from Sharon 20 Q And Sharon Churcher's e-mail address?
21 Churcher, correct? 21 A Yes.
22 A Yes. 22 Q And you're signing your e-mails to her,
23 Q And what did Sharon Churcher write to you 23 Much love, XOXO Jenna. And she's signing her e-mails
24 on February 19th of 2011? 24 to you, Love Shaza, correct?
25 A Do you know a ? 25 A Correct.

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1 Q And Shaza is a name that you call her? 1 phrase sex trafficked as that is a heads up about the
2 A In Australia we kind of shorten the names 2 book revealing more than be printed.
3 of people and put z-a on the end, so yes. 3 Q All right. So is Sharon Churcher writing
4 Q So she became Shaza? 4 to you about -- actually, it's cc'd to Brad, correct?
5 A She became Shaza, correct. 5 A Yes.
6 Q And do you recall having e-mail 6 Q And I only use Brad, not his last name
7 communications with her in which you referred to her 7 because it's brad@pathtojustice.com, correct?
8 as Shaza and -- 8 A Yes.
9 A Yes. 9 Q All right. And that's Brad Edwards, who
10 Q -- she referred to herself as Shaza? 10 is sitting here, right?
11 A She's the same person we're talking about, 11 A Yes.
12 yes. 12 Q All right. And so in the e-mail from
13 Q All right. So it's coming from her e-mail 13 Sharon Churcher to you regarding whether or not you
14 address as Sharon Churcher, right? 14 should let Vanity Fair buy your picture, she's also
15 A Yes. 15 recommending in the last line that you should have
16 Q All right. And I think the last -- 16 Brad use the phrase sex trafficked, correct?
17 MR. EDWARDS: Are you at a stopping point? 17 A If a statement is made, yes. I don't
18 MS. MENNINGER: Almost. 18 think Vanity Fair ever did, anyway.
19 MR. EDWARDS: Okay. Okay. I just have to 19 Q And the picture that they're talking about
20 a make a quick call, but I can wait a while so -- 20 there is the one with , correct?
21 MS. MENNINGER: I understand. Almost 21 A That's -- yeah, the big one.
22 done. 22 Q The one that was previously sold?
23 MR. EDWARDS: Okay. 23 A Yes.
24 (Exhibit 24 marked.) 24 Q And Paulo Silva was syndicating that one,
25 Q (BY MS. MENNINGER) This is Exhibit 24, 25 correct?
Page 290 Page 292

1 e-mails between yourself and Sharon Churcher from 1 A Yes. Yeah.
2 June of 2011? 2 Q And on that second page there's a
3 A Um-hum. Yes, sorry. 3 redaction. Who is -- who is in that redaction?
4 Q And, again, Shaza and Jenna, Shaza, Jenna, 4 A I have no idea.
5 Jenna, Shaza, right? 5 Q You don't know?
6 A Yes. 6 A No, I don't know.
7 Q And at the bottom of this first page, is 7 Q So who are the two world's most respected
8 Sharon Churcher giving you advice regarding the 8 politicians? and who?
9 purchase by Vanity Fair 9 A I don't know.
10 10 Q Do you recall ever telling Sharon Churcher
11 A May I have time to read it, please? 11 that you were trafficked to two of the world's most
12 Q Please. 12 respected politicians, and somebody
13 A Are we talking about the very bottom one 13 else?
14 or the one in the kind of middle bottom? 14 MR. EDWARDS: Object to form.
15 Q The very bottom one. 15 A Is that her wording? This is from her.
16 A I would let VF buy your picture via Brad. 16 So this is her wording.
17 The big gamble would be to let him also give them a 17 Q (BY MS. MENNINGER) Right.
18 statement. 18 A If she considered them to be the world's
19 Q Right. 19 most respected politicians, that would be her
20 A (Deponent perused document, sotto voce.) 20 opinion, not mine.
21 The reason this is a gamble is Jeffrey 21 Q Okay. But you received this e-mail and
22 knows some of the most powerful people in publishing 22 responded to it, correct?
23 and, once altered, will inevitably try to scare off 23 A Is the top one above that what I responded
24 potential buyers. But the upside is it should help 24 to? Sorry. It just confuses me because it goes
25 you get a good agent. I would have Brad use the 25 upwards, doesn't it, not downwards. We're not

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1 reading chronologically down, are we? 1 case. How fantastic, Jenna! Have you asked him how
2 Q You can probably look at the dates and 2 he'd feel about reviving your book? It would be an
3 figure it out. I need you to do that, not me? 3 incredible shame if the other project lifts your
4 A Okay the 30th of the fifth, 31st of the 4 story, which it could at least somewhat. Jarred is
5 fifth, 6th of the first. Right. So I still don't 5 still very keen to represent you. I'm afraid I
6 know who she's talking about there. 6 screwed you by steering you to Mimi.
7 Q You don't know if you received this 7 I just had a great weekend in LA on a
8 e-mail? 8 celebrity story. Got to go to Rodeo Drive!!!
9 A No, I received this e-mail, obviously, but 9 Much love, Shaza.
10 I don't know who's redacted there. 10 Yes.
11 Q Okay. And in the e-mail that you 11 Q So she's encouraging you to have David
responded to, you're talking about -- you used Boies also help you in the book writing department,
12
13 correct?
■ 12
13 right?
14 A It does concern me what they could want to 14 MR. EDWARDS: Object to the form.
15 write about me considering tha walked 15 Mischaracterizes the exhibit.
16 into VF and threatened them not to write sex 16 A Is the question pending?
17 trafficking articles about his good friend JE. 17 Q (BY MS. MENNINGER) Yes.
18 Q Right. Does that refresh your memory that 18 A She -- yeah, she encouraged me to -- I
19 when you got this e-mail unredacted was 19 mean, once she saw that, you know, there was more
20 included as well as ? 20 litigation going on, she thought -- like she says,
21 MR. EDWARDS: Object to the form. 21 How fantastic. And up until recently she's still
22 Q (BY MS. MENNINGER) In the line referred 22 been trying to get me to get the book out.
23 to as two of the world's most respected politicians? 23 Q And in May of 2015, do you have -- did you
24 A It could be. But, again, I would be 24 have any active agreement to publish your book?
25 making an assumption because I don't know who that 25 A In May of 2015, no. Jarred wanted to do
Page 294 Page 296

1 name is. 1 something again, but his only thing was, he wanted
2 Q I don't either. 2 Sharon to be in on it as like a ghostwriter. And I
3 A Okay. 3 said, Look, Sharon is all well and good, but I don't
4 Q Maybe our lawyers can tell us. 4 want a journalist, you know, as they can twist things
5 MS. MENNINGER: All right. Last one, and 5 around writing my story.
6 then you can get your break. 6 So he was like, Well, I'm sorry, I don't
7 (Exhibit 25 marked.) 7 want to work with you then. And I said, Well, that's
8 Q (BY MS. MENNINGER) Defendant's 8 fine. No problem.
9 Exhibit 25. Again, e-mails to and from yourself and 9 Q Do you, as you sit here today, have any
10 Sharon Churcher, correct? 10 agreement to publish your story in written form?
11 A Yes. 11 A No, we have no agreement.
12 Q And in this e-mail, it's dated 4/12/2015 12 Q Do you have an agreement for anyone else
13 on the first page of this composite e-mail? 13 to write your story?
14 A Yes. 14 A No.
15 Q She is encouraging you to do a book, 15 Q Have you got any ghostwriter in the book?
16 correct? 16 A Besides Sandra, who I didn't like, no.
17 A As she has from the beginning, yes. 17 MS. MENNINGER: All right. I think now is
18 Q Right. And she suggested a roman a clef. 18 a good time for a break. And then --
19 Do you know what that means? 19 MR. EDWARDS: Okay.
20 A No. 20 THE VIDEOGRAPHER: We are off the record
21 Q On the third page back, she wrote you to 21 at 4:12.
22 compliment you about David Boies taking your case, 22 (Recess taken from 4:12 p.m. to 4:22 p.m.)
23 correct? 23 THE VIDEOGRAPHER: We are back on the
24 A (Deponent perused document sotto voce.) 24 record at 4:22.
25 Just reading about David Boies taking your 25 Q (BY MS. MENNINGER) When you were

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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 In relationship 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 So I 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 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 Because 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 All right. 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 All right. 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 All right. And Mr. Edwards was your 18 Q 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.

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1 MS. MENNINGER: That's okay. 1 A It doesn't surprise me, but I don't
2 THE DEPONENT: Yeah. Sorry about that. 2 remember reading this. I know that, you know, there
3 MS. MENNINGER: Okay. 3 was a lot of stories in press going on and a lot of
4 MR. EDWARDS: One is right on top of the 4 them I decided I just didn't want to read. There was
5 other. 5 a lot of stuff in there that just, I didn't want to
6 Q (BY MS. MENNINGER) I don't doubt you. I 6 go through.
7 was just looking for it. 7 Q Okay. Were you harmed on March 10th or
8 A Okay. 8 March 11th, 2011 by the issuance of a statement on
9 Q All right. So after the word London, 9 behalf of Ghislaine Maxwell?
10 March 10th, 2011, correct? 10 A I am harmed by Ghislaine Maxwell denying
11 A Correct. 11 anything that has ever happened between us, whether
12 Q And above that is a title, Statement on 12 it's in 2002 or 2011 or 2015. I think that she knows
13 behalf of Ghislaine Maxwell, right? 13 what she did, and she should be held accountable for
14 A Yes. 14 them. And not only has she hurt me once, but she's
15 Q By Devonshires Solicitors, PRNE, correct? 15 hurt me apparently twice and now three times.
16 A Correct. 16 Q So on March 11th, 2011, say, how were you
17 Q And then Wednesday, March 9th, 2011, 17 harmed by the issuance of this press statement?
18 correct? 18 A She's denied that she had any involvement
19 A Correct. 19 in the procuring of me and other young girls.
20 Q And you understand that March 9th or 20 Q Um-hum.
21 March 10th, 2011 is roughly the time your original 21 A And she tries to make herself look like
22 stories were published in the press -- 22 she had no partake in it.
23 A Correct. 23 Q Did you suffer any physical symptoms on
24 Q -- internationally, correct? 24 March 11th, 2011 after this statement was issued, as
25 A Correct. 25 a consequence of this statement being issued?
Page 302 Page 304

1 Q And this statement issued by Ghislaine 1 A Not being able to remember reading this in
2 Maxwell or issued by Devonshires Solicitors on her 2 2011, it's hard to say. But it's the same thing that
3 behalf denied allegations about her that have 3 I'm going through right now. I mean, she's denied it
4 appeared recently in the media, correct? 4 again. And it is painful. It's physically painful.
5 A Correct. 5 I am taking medication to help me deal with this.
6 Q It says, These allegations are all 6 And --
7 entirely false, correct? 7 Q Okay. I'm just limiting you right now to
8 Did I read that properly? 8 March of 2011.
9 A Ghislaine Maxwell denies the various 9 MR. EDWARDS: I would just ask that she's
10 allegations about her -- oh, yeah, right -- yeah, 10 able to finish her answer, though, please.
11 right below that. These allegations are entirely 11 MS. MENNINGER: Well, the answer is
12 false. 12 nonresponsive, so --
13 Q All right. In 2011, were you aware that 13 MR. EDWARDS: In your opinion it's not
14 Ghislaine Maxwell issued a statement denying the 14 responsive.
15 allegations about her that had appeared in the media? 15 Q (BY MS. MENNINGER) I want you to
16 A I'm not too sure what I recall from 2011 16 understand that the question is related to any
17 about Ghislaine Maxwell denying it. I know that she 17 physical symptoms you suffered in March of 2011 as a
18 denied it recently in 2015. I know that for a fact. 18 consequence of Defendant's Exhibit 26 being issued.
19 Q So you don't know whether she denied it in 19 A If I would have seen this in March 10th,
20 2011? 20 2011, this would have been harmful to me.
21 A I can't recall back to 2011, if I do 21 Q Okay. Do you recall, as you sit here
22 remember that. 22 today, experiencing any physical symptoms as a
23 Q And you don't know whether she put out a 23 consequence of Defendant's Exhibit 26 being issued to
24 press statement that said these allegations are all 24 the press?
25 entirely false, correct? 25 MR. EDWARDS: Objection. Asked and

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1 answered. Lacks predicate. 1 can't believe you've been through this. I never
2 A I have been suffering from Ghislaine 2 knew. I'm so sorry. You know, that kind of stuff.
3 Maxwell and Jeffrey Epstein since the summer of 2000. 3 So they never -- I never spoke to anybody about this
4 So hearing again in 2011 that she's denied it, of 4 except for my husband.
5 course, it's going to hurt me. 5 Q All right. So the first time you recall
6 Did I hear about this in 2011? I can't 6 any sort of people in your community referencing
7 tell you I honestly have. 7 things to you is when the press picked up on it in
8 In 2015 is when I know that she denied it. 8 2014 or 2015?
9 And again, I haven't stopped suffering from the 9 A Yeah, I think it may be end of 2014, early
10 repercussions that they put me through. 10 2015.
11 Q (BY MS. MENNINGER) And I'm asking you to 11 Q All right. And so in March of 2011 you
12 separate, if you can, any symptoms that you 12 don't recall any neighbors or anybody saying anything
13 experienced anew in March of 2015 -- I mean, excuse 13 to you about this?
14 me, March of 2011, as a consequence of this statement 14 A No, I don't recall.
15 being issued, which I believe you said you don't 15 Q Did anyone tell you in March of 2011 about
16 recall seeing at the time; is that fair? 16 Defendant's Exhibit 26, the statement on behalf of
17 A But you're asking me now about 2015? 17 Ghislaine Maxwell?
18 Q Nope. March of 2011. Sorry, I misspoke 18 A No, otherwise I would have been able to
19 there. 19 recall it.
20 A You're still on 2011? 20 Q Okay. Do you remember anyone in 2011
21 Q Yes. Did you start taking any new 21 ridiculing you because of Defendant's Exhibit 26?
22 medications in March of 2011? 22 A Well, because nobody knew me as Virginia,
23 Let me ask you that. 23 everybody knows me as Jenna, no one probably put two
24 A I've been taking medication to control my 24 and two together. And like I told you, I didn't tell
25 since 2002. 25 anybody. So there was nobody there to ridicule me in
Page 306 Page 308

1 Q Okay. So did you take any new medications 1 2011 over this.
2 or any additional amounts of medications in March of 2 Q Where were you living in 2011 when Shaza
3 2011? 3 came to see you --
4 A I have been taking the same medication 4 A Oh, .
5 since 2002. 5 Q Do you recall applying for any job in or
6 Q Okay. 6 around 2011 and someone referencing Defendant's
7 A And that's due to 7 Exhibit 26 and denying you a job?
8 caused from the pain that I suffered at the hands of 8 A I don't -- I don't think I applied for a
9 Ghislaine Maxwell and Jeffrey Epstein. 9 job in 2011.
10 Q Did you -- do you recall any neighbors or 10 Q Okay. Did you go see a doctor and talk to
11 other moms at the school or anybody in 2011 11 any doctor about Defendant's Exhibit 26?
12 referencing to you in any way the fact that Ghislaine 12 A Not about this. Not about this paper
13 Maxwell had issued a denial of the allegations about 13 right here. But I have talked to doctors about my
14 her that had been published in the media in March of 14 abuse at the hands of Ghislaine and Jeffrey.
15 2011? 15 Q Have you talked to a doctor about any
16 A No. I didn't speak to any -- I didn't 16 statements in the press made by Ghislaine Maxwell?
17 speak to any moms about what I had gone through. I 17 A Recent statements, yes.
18 mean, when it came out in the press, I don't think 18 Q Which doctor did you speak to about that?
19 any -- like, Australians don't pay attention to news, 19 A Her name is Judith Lightfoot.
20 number one. 20 Q And where is she?
21 Number two, the first time that my friends 21 A She's in Australia.
22 contacted me they were shocked. And this was, I 22 Q Where in Australia?
23 believe in -- when the press picked it up again, I 23 A She's in Sydney, but we do phone
24 think, was 2014/2015. And I got a whole bunch of 24 conversations.
25 like Facebook texts from them saying, Oh, my God, I 25 Q Have you ever met her in person?

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1 A Yes. 1 the same. Maxwell strongly denies -- excuse me.
2 Q When? 2 Excuse me -- strongly denies allegations of an
3 A In 2011. 3 unsavory nature, which have appeared in the British
4 Q All right. And is she affiliated with an 4 press and elsewhere and reserves her right to seek
5 office or a hospital or what? 5 redress at the repetition of such old defamatory
6 A She's a psychiatrist. 6 claims.
7 Q All right. Have you seen her in person 7 Q All right. Have you seen this statement
8 since 2011? 8 before?
9 A No, because I've lived so far away and 9 A I've seen it recently, yes.
10 she's kind of the only person that -- like, I've seen 10 Q All right. What -- have you discussed
11 a lot of doctors. And I can honestly tell you -- 11 this statement with Ms. Lightfoot? I don't know if
12 it's really hard for them to break down the walls and 12 she's a doctor or what.
13 be comfortable enough to talk to them about this 13 A Psychiatrist, yeah.
14 stuff. Judith is different. She's somebody that I 14 Q Is she an MD?
15 feel I can trust. She's 76 and she's just a very 15 A I don't know what her levels of credential
16 lovely lady. 16 are. I'm sure she is.
17 And she offers me other ways to deal with 17 Q Okay. When is the first time that you saw
18 my pain and suffering. And I continue to see her 18 the statement?
19 over the phone because I can't see her in person. 19 A This full statement I have only seen
20 Q Do you recall ever discussing with her 20 through discovery. The original statement that I saw
21 Defendant's Exhibit 26? 21 in the press was, Ms. Roberts' claims are obvious
22 A I can't recall ever seeing this exhibit. 22 lies and so on, so forth. I don't remember seeing
23 So -- 23 this in the press.
24 Q Okay. 24 Q Okay. So the part that you remember
25 (Exhibit 27 marked.) 25 seeing in the press is Ms. Roberts' claims are
Page 310 Page 312

1 Q (BY MS. MENNINGER) I'm going to give you 1 obvious lies?
2 Defendant's Exhibit 27. 2 A Yes.
3 A Yes. 3 Q Anything else about this?
4 Q All right. Have you seen this document 4 A I can't remember what else she printed in
5 before? 5 the press. It's a very horrible thing for her to do,
6 A Yes. 6 turn around and call me a liar after everything that
7 Q And what do you understand it to be? 7 she knows she's done. And I didn't expect her to
8 A sounds like a PR, if 8 come out and be truthful.
10
■
■
13
9 I'm not right -- if I'm not wrong. Sent -- or
subject is Ghislaine Maxwell. I don't know
-
It says: To whom it may concern, Please
9
10
11
12
13
statement.
Q
question.
A
Jeffrey Epstein hasn't even issued a
Sorry. I'm sorry if you misunderstood my
Yes.
14 find attached credible statement on behalf of 14 Q Was there anything else within this
15 Ms. Maxwell. 15 statement that you recall seeing in the press besides
16 And then it goes on, to hear about that 16 the line, Ms. Roberts' claims are obvious lies?
17 she is saying: Each time the story is retold it 17 A Without saying 100 percent, I think that
18 changes with new salacious details about public 18 the original allegations are not new and have been
19 figures and world leaders and now it is alleged by 19 fully responded to be shown to be untrue. I don't
20 Ms. Roberts that is involved in 20 know if that's in the press or not, but I've read
21 having sexual relations with her, which he denies. 21 this before.
22 Ms. Roberts' claims are obvious lies and 22 So I don't know if I'm confusing this with
23 should be treated as such and not publicized as news, 23 what I've read out of this or what I've read in the
24 as they are defamatory. Ghislaine Maxwell's original 24 press. The main thing is, I know she called me a
25 response to the lies and defamatory claims remains 25 liar, and that's what she publicized.
~

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1 Q And when you say she called you a liar, 1 a liar from the people that abused me.
2 that's the Ms. Roberts' claims are obvious lies part? 2 Q Okay. Do you recall specifically
3 A Yes. 3 mentioning to him Ghislaine Maxwell's statement to
4 Q Okay. When is the first time that you saw 4 the press?
5 this whole document? 5 A I mentioned a lot of names to him.
6 A I guess when you guys handed it over for 6 Q Okay. What new symptoms did you
7 discovery. 7 experience following January 2nd, 2015?
8 Q Okay. And who showed it to you? 8 A I think it's one thing to be a victim of
9 A It was sent to me by e-mail. 9 sexual abuse and survive it and come out trying to
10 Q Okay. Just through the course of 10 tell the world my story, and then another thing for
11 communicating with your attorneys? 11 it to be shut down because these people, Ms. Maxwell
12 A Yes. 12 and others are calling me liars (sic).
13 Q You've never seen it published? 13 Q And I asked you what symptoms had you
14 A Not this whole e-mail, no. 14 experienced --
15 Q All right. Did you -- I'm sorry, did you 15 MR. EDWARDS: She's going to finish her
16 discuss this publication of what you saw in the press 16 answer to this question. You cut her off so many
17 with Judith Lightfoot? 17 times.
18 A Yes. 18 MS. MENNINGER: It has nothing to do with
19 Q All right. And when did you discuss it 19 this.
20 with her? 20 MR. EDWARDS: It absolutely does. Because
21 A When I got back to Australia, Judith and I 21 this is a psychological damages claim, and she is
22 started seeing each other again. Before then, I 22 trying to explain to you what those damages are.
23 spoke with a doctor in Colorado about this. His name 23 Q (BY MS. MENNINGER) Okay. What are your
24 is Dr. Olsen. And it was causing me a lot of 24 symptoms that you experienced since January 2nd, 2015
25 distress to have to deal with being called a liar all 25 that are new?
Page 314 Page 316

1 over again, when I know I'm standing up doing the 1 A Very strong anxiety attacks, bad panic
2 right thing. And the doctor prescribed me 2 attacks. My throat closes up, I can't breathe. I
3 . And, yeah. 3 vomit when I have anxiety attacks. My -- this is
4 Q Okay. So my question was, when did you 4 personal, but my sex life has suffered. My marriage
5 discuss it with Judith Lightfoot? 5 has suffered. Psychologically, it's just hurt me all
6 I think I now understand you did that 6 over again. I mean, they've hurt me before, and now
7 after you returned to Australia in November or so of 7 they've hurt me again by doing this.
8 2015; is that right? 8 And I felt like I was in the process of
9 A I returned to Australia in October, and 9 healing before this came out because I had opened up
10 that's when I picked up talking to her again. 10 this wonderful charity called Victims Refuse Silence.
11 Q All right. And you're saying that at 11 And then my aim was to heal by helping other girls
12 another point in time you talked to another doctor, 12 get out of the situations that I was in before.
13 Dr. Olsen, in Colorado, correct? 13 And my lawyers were nice enough to help
14 A Correct. 14 me. I have this beautiful website where you can
15 Q And when did you meet with Dr. Olsen? 15 click on in any state and you can find a place. I
16 A I don't know the first date that I met 16 have personally called all of them and they will help
17 with him. 17 you get out of the situation that you're in. They
18 Q Did you meet with him more than once? 18 will get you medical help. They will get you legal
19 A I believe so. 19 advice. I think I was in the really good process of
20 Q And you believe you spoke with him about 20 healing. And when this came out, it just ruined me
21 Ghislaine Maxwell's published statement in the press 21 all over again.
22 that Ms. Roberts' claims are obvious lies. 22 Q (BY MS. MENNINGER) All right. Tell me
23 That's what you believe you spoke with 23 all of the damages that you claim occurred to you
24 Dr. Olsen about? 24 because of Defendant's Exhibit 27.
25 A I spoke with Dr. Olsen about being called 25 A My reputation, my psychological abuse,

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1 physical ailments. My marriage has suffered, my 1 A Well, number one, my charity. I mean,
2 family life has suffered. I'm constantly battling 2 that's -- that was my voice for other people to get
3 depression. I feel like I've taken 10 steps forward 3 help. And I don't think that people want to get help
4 and 12 steps back since this all happened. 4 from somebody who's being called a liar in the press,
5 Q Okay. And by since this all happened, do 5 somebody who is claiming to be a victim that isn't.
6 you mean since January 2nd, 2015? 6 I mean, I wouldn't want to get help from somebody who
7 A That's correct. 7 did that, you know.
8 Q All right. Have you lost any income since 8 And I know when I introduce myself to
9 January 2nd, 2015 as a consequence of Defendant's 9 people these days, I don't introduce myself as
10 Exhibit 27? 10 Virginia anymore. I introduce myself as another name
11 A Well, I believe that my charity that was 11 because I'm afraid that if people read papers or if
12 going to go forward and help other victims was going 12 people Google or find out who I am that they'll think
13 to not only bring in income but also be able to 13 differently of me.
14 provide women with shelters and food and assistance 14 Q What do you introduce yourself as?
15 that I wanted to help them with. 15 A I tell everybody my name is Jenna.
16 I haven't been able to get a job or work 16 Q In what country or location has your
17 or anything like that. You know, financially, my 17 reputation been damaged as a consequence of
18 husband brings home the money for me. But as myself 18 Defendant's Exhibit 27?
19 goes, I couldn't work right now with everything going 19 A Considering this is worldwide publication,
20 on. 20 I would saying England, America, Australia. You
21 Q How much income were you making prior to 21 know, friends in Australia were seeing my face on
22 December 30th, 2014? 22 national TV. Like I said, I can't remember if it was
23 A Well, I've been a stay-at-home mom since 23 2014 or 2015. And I have since not been in contact
24 2006. 24 with those friends. I thanked them for their
25 Q So how much income have you lost as a 25 sympathies, but it's not something I want people to
Page 318 Page 320

1 result of Defendant's Exhibit 27? 1 know about. You know, especially people close to me.
2 A I could only imagine, you know, being the 2 I mean, I want to go out there and I want
3 head of a corporation, a charity, I would be earning 3 to help other victims. But being called a liar and
4 a decent wage. It's hard to say how much I would be 4 people having to sit there and second guess if I'm
5 earning because it is a non for-profit. 5 telling the truth or not doesn't really give me much
6 But because of these statements telling 6 incentive to want to make friends.
7 everybody in the world that I'm a liar, my charity 7 Q Did anyone in Penrose, Colorado approach
8 has not been able to take off. And as a consequence 8 you and mention Ghislaine Maxwell's name?
9 of that, I have missed out on the results of not 9 A We have reporters at our door.
10 being able to go forward with it. 10 Q Did anyone in Penrose, Colorado approach
11 Q Okay. Have you applied for any job that 11 you and mention Ghislaine Maxwell's name?
12 you've been denied since January 2nd, 2015? 12 A What, reporters? Yes, plenty of them.
13 A I haven't been denied a job. I haven't -- 13 Q Did anyone who lives in Penrose, Colorado
14 I've just -- I thought about applying for jobs, but I 14 approach you and mention Ghislaine Maxwell's name?
15 mean, the second that you Google my name, people are 15 A Have you ever been to Penrose? It's --
16 going to know exactly who I am. And these days, 16 it's in the middle of nowhere. So you really -- I
17 employers Google everything, and it makes me fearful 17 didn't have friends in Penrose. There was nobody
18 that if I do go apply for a job, which I would like 18 that I knew there.
19 to. I mean, my kids are all at school now. I'd like 19 Q All right. And which reporters mentioned
20 to get back into the work force. 20 you and Maxwell's name to you in Penrose, Colorado?
21 But I'm afraid if I do, my past is going 21 A We have reporters chasing us down the
22 to stop me from being able to do that. No one wants 22 street, in car parks, taking my kids to the doctor's,
23 to hire a sex slave. 23 going to the grocery store. You know, asking me all
24 Q How has your reputation been harmed by 24 kinds of questions about it. And I didn't talk to
25 Defendant's Exhibit 27? 25 any journalists or reporters about it.

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1 Q And what do you recall any reporter saying 1 Trafficking Coalition sometime after January 2nd,
2 to you that included the name Ghislaine Maxwell? 2 2015?
3 A Asking me -- I don't remember what they 3 A I did give -- I did go for a speaking
4 asked me, to be honest. There was regarding 4 engagement. I don't remember when.
5 Ghislaine and and Jeffrey Epstein. I 5 Q Was there any speaking engagement you had
6 mean, it was an array -- you know how reporters can 6 booked that was canceled after January 2nd, 2015?
7 be when they're hashing at you. 7 A I can't remember off the top of my head.
8 Q Okay. So no one in Penrose, Colorado who 8 Q All right. You founded Victims Refuse
9 lived there mentioned Ghislaine Maxwell by name to 9 Silence in February of 2014, correct?
10 you? 10 A It was -- it was a process because,
11 A Besides reporters? 11 obviously, you have to go through all the bylaws and
12 Q Right. People who live in Penrose, 12 everything. I think we started it in October of
13 Colorado. 13 2014, but it wasn't official until January, I think.
14 A Right. I didn't know anyone in Penrose, 14 Q Okay. So in the period it was in
15 except for my mom. 15 operations before January 2nd, 2015, had you gotten
16 Q Okay. Now, in March or April of 2015 did 16 any -- had you been paid any salary by Victims Refuse
17 you fly to New York? 17 Silence?
18 A I'm sorry, what date? 18 A No, I hadn't.
19 Q March or April of 2015, did you fly to New 19 Q Had --
20 York? 20 A I mean, it was just up and running. So
21 A It's a possibility. 21 there was no --
22 Q Did you stay at the Ritz-Carlton? 22 Q Had any contributions been made to Victims
23 A It's definitely a possibility. 23 Refuse Silence before January 2nd, 2015?
24 Q Were you there with Mr. Edwards and 24 A I can't recall. You know, we've only had
25 Mr. Cassell and Sigrid McCawley? 25 a few contributions. I don't know what dates they
Page 322 Page 324

1 A I've been to New York quite a few times. 1 were put in.
2 So I'd have to refresh my memory. But I have been to 2 Q Has anyone else called you a liar in the
3 New York with Brad Edwards and Paul Cassell and 3 press?
4 Sigrid McCawley. 4 A Yes.
5 Q Was that after January 2nd, 2015? 5 Q Who?
6 A Definitely could be. 6 A .
7 Q Did you give an interview to ABC News on 7 Q Anyone else?
8 camera? 8 A Ghislaine Maxwell, obviously.
9 A I did. 9 Q Anyone else?
10 Q And that was after January 2nd, 2015? 10 A Not that I know of.
11 A I did. 11 Q Has anyone else publicly denied your
12 Q Did you give an interview to Good Morning 12 allegations?
13 America? 13 A From what Ghislaine Maxwell said?
14 A No. 14 Q Have you seen any press in which another
15 Q All right. Did you correspond at all with 15 person has denied your allegations?
16 Good Morning America about the publication of your 16 MR. EDWARDS: Objection. Vague.
17 story? 17 A I've seen allegations denied by
18 A I can't remember if ABC and Good Morning 18 Ms. Maxwell. And I've seen the allegations denied by
19 America wanted to do something together. I can't -- 19 .
20 all I know is I was interviewed by one person at ABC. 20 Q (BY MS. MENNINGER) And
21 I never was interviewed by anyone from Good Morning 21 actually went on TV and called you a serial liar,
22 America. Maybe they were going to show the same 22 correct?
23 airing in the same show, but powers that be, of 23 A Very correct.
24 course, wouldn't let it go forward. 24 Q You saw that, correct?
25 Q Did you give a lecture to the Human 25 A Yes.

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1 Q And that hurt your feelings? 1 context?
2 A Badly. 2 MR. EDWARDS: Object to the form of the
-
3 Q 3 question.
I - 4 A Can I point to a person -- I'm sorry. I
-
-
I I 5 don't understand. Can you rephrase it for me --
I
I
I
-
- 6
7
Q
A
(BY MS. MENNINGER) All right.
-- so I can understand what you mean?
8 MR. EDWARDS: Form. 8 Q Where you live in Australia now, has
9 AI 9 anyone referenced the name Ghislaine Maxwell to you?
10 Q (BY MS. MENNINGER) How do you know which 10 A After all of the news hits, after the
11 harm you've suffered is attributable to Ghislaine 11 press hits in 2015 and, you know, everyone is calling
12 Maxwell's denial versus 12 me a liar, all of my friends in Australia called me
■
14 A
-
Ghislaine Maxwell brought me into the sex
13
14
and talked to me and said, I can't believe this. I
can't believe what you went through.
15 trafficking industry. She's the one who abused me on 15 That was very embarrassing for something
16 a regular basis. She's the one that procured me, 16 that I tried to keep separate from my other life
17 told me what to do, trained me as a sex slave, abused 17 where I would like to help victims. I didn't want
18 me physically, abused me mentally. 18 the friends of my kids parents knowing about that
19 She's the one who I believe, in my heart 19 stuff. You know, and of course they all felt sorry
20 of hearts, deserves to come forward and have justice 20 for me. And you know, like I said. I didn't know
21 happen to her more than anybody. Being a woman, it's 21 anybody in Penrose. So there's nobody that could
22 disgusting. 22 have come up to me and talked to me about it. My
23 Q So you cannot delineate what harm you have 23 mom.
24 suffered in terms of all of the psychological damage 24 Q This question was about Australia, sorry.
25 you just disclosed? 25 A Oh, sorry, I thought you were talking
Page 326 Page 328

1 A Oh, of course. 1 about pointing out people.
2
3
4
Q -- if that is attributable to Ghislaine
Maxwell's statement on January 2nd versus
-
calling you a serial liar on Good Morning
2
3
4
Q
A
No.
Okay, well in Australia, yes, at least a
dozen friends.
5
6
I
I
9
America?
-
A Of course, it all hurts. Okay? I
-
-
doesn't feel good to have people who have done
-
Of course those hurt. It
5
6
7
8
9
Q They came up and they mentioned Ghislaine
Maxwell's denial to the press to you?
A They couldn't believe what I had been
through and, you know, that these were, you know,
being denied, and they felt sorry for me. And, you
10 something to you deny something that's happened, when 10 know, it was the whole circumference of things.
11 I'm actually brave enough to come forward and talk 11 Q So the people in Australia that came up to
12 about it. 12 you had sympathy for you and believed you, correct?
13 What hurts me the worst is that Ghislaine 13 A Yes.
14 Maxwell brought me into this. Not only has she hurt 14 Q All right. And when you spoke to
15 me once, but she's hurt me twice coming forward and 15 Dr. Olsen you recall specifically mentioning
16 saying, This is not true, this is categorically 16 Ghislaine Maxwell's press release?
17 untrue and obvious lies. 17 MR. EDWARDS: Object to the form.
18 That to me is a stick in the mud and that 18 A Yes, I remember mentioning her, as well as
19 to me is what caused the most harm to me. 19 the press release, as well as other press releases.
20 Q Okay. And so can you point to any person 20 And the abuse that I had occurred (sic) from the
21 who has referenced Ghislaine Maxwell's denial in the 21 hands of Jeffrey and Ghislaine.
22 press or to your face or anywhere? 22 Q (BY MS. MENNINGER) Okay. When have you
23 A Can I point to a person? 23 been diagnosed with a mental health condition, first?
24 Q Can you point to any time that someone has 24 A I don't know. I mean, I've been told that
25 referenced Ghislaine Maxwell's denial to you in any 25 I've . You know --
~

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1 Q When were you first told that? 1 just got to Australia and Judith Lightfoot was
2 A Well, early in -- early in 2003, I believe 2 helping me.
3
4
5
6
7
is the first time that I was suffering from
Lightfoot, has in 2011

And then my doctor, Judith
And, you know, I've recently seen another

I
I
5
6
7
- Q
Australia?
A
And I told him the reason.
And this is since you returned to
Correct.
8 doctor who said that I've got the exact same symptoms 8 Q And this is the first time you had seen
9 that Judith Lightfoot mentioned, which is 9 that doctor?
10 10 A I've seen that doctor twice now.
. Q I'm sorry, what was the name again? I
■
11
12 Q Which doctor is that? 12 know you already said it, but I just --
13 A You know, I don't honestly know his name. 13 A Dr. Donahue.
14 Q When did you see this new doctor? 14 Q Donahue, all right.
15 A Um -- 15 This doctor that you haven't yet
16 MR. EDWARDS: Sorry. If you're referring 16 disclosed, where did you see that person? In what
17 to a doctor that's been sent to you by one of your 17 country?
18 lawyers -- 18 A United States.
19 THE DEPONENT: Yes. 19 Q And in what state?
20 MR. EDWARDS: -- at this time, I'm 20 A San Francisco.
21 instructing you not to answer. 21 Q And when did you see that doctor?
22 THE DEPONENT: Okay. 22 A Um, Friday. Last Friday.
23 MS. MENNINGER: Wait. What is it? You've 23 Q And how many times have you seen that
24 seen a doctor and you're not going to answer what 24 doctor?
25 doctor you've seen? 25 A Once. Well, twice actually. I saw him
Page 330 Page 332

1 MR. EDWARDS: Sure. If it's a consulting 1 the next day, too.
2 witness in this case that has seen her at the 2 Q All right. Did you suffer from anxiety
3 direction of an attorney, that has not yet been 3 before meeting Jeffrey Epstein?
4 disclosed per any expert witness disclosure, then I'm 4 A I was never prescribed anything for
5 instructing her not to answer that question. 5 anxiety before I met Jeffrey Epstein.
6 If that's what you're referring to. I 6 Q That wasn't my question.
7 don't know if that's what you're referring to. 7 A Did I --
8 THE DEPONENT: That's what I'm referring 8 Q Were you suffering from anxiety before you
9 to. 9 met Jeffrey Epstein?
10 Q (BY MS. MENNINGER) All right. So you 10 A I think a person who has gone through as
11 recall seeing Dr. Lightfoot. You recall seeing 11 much trauma as I have in my life would suffer from
12 Dr. Olsen. And you recall seeing a new unnamed 12 quite a few problems. But like I said, I was never
13 doctor recently. 13 prescribed anything until I met Jeffrey Epstein.
14 Anyone else you've seen since January 2nd, 14 Q Did you suffer from panic attacks before
15 2015? 15 meeting Jeffrey Epstein?
16 A Dr. Olsen, Dr. Lightfoot. Oh, 16 A Nowhere near as bad, no.
17 Dr. Donahue. 17 Q So you did suffer from .
18 Q Where is Dr. Donahue located? 18 They just weren't as severe; is that what your
19 A He's in my suburb or he's a suburb next to 19 testimony is?
20 me in Australia. 20 A No, what I'm trying to say is I did have
21 Q And is that a psychiatric-type doctor, a 21 I did have I had lived a very
22 medical-type doctor? 22 hard life prior to meeting Jeffrey Epstein as well.
23 A He's medical. 23 After meeting Jeffrey Epstein and
24 Q And what did you see him for or her for? 24 Ghislaine Maxwell, everything escalated. That's when
25 A I didn't have anybody to basically -- I 25 I started to take Xanax and smoke marijuana to help

Agren Blando
Document & Video,
07/30/20
Page 333 Page 335
1 calm the anxiety and everything down. 1 Q How much does it cost you every time you
2 Q Before you met Jeffrey Epstein, had you 2 talk to Dr. Lightfoot?
3 used any drugs? 3 A Her normal fee is $200.
4 A Sure, yes. 4 Q And how much do you pay?
5 Q Which drugs had you used prior to meeting 5 A She doesn't charge me anything anymore.
6 Jeffrey Epstein? 6 Q When did she stop charging you?
7 A I smoked pot. I've taken Ecstasy. 7 A Since I got back to Australia.
8 Q Cocaine? 8 Q So before you left for Titusville,
9 A Yeah, I would have snorted cocaine, 9 Florida, you saw her and you were paying $200 per
10 um-hum. 10 session?
11 Q Did you ever abuse alcohol before meeting 11 A Yes.
12 Jeffrey Epstein? 12 Q And what has Dr. Lightfoot recommended
13 A No, I was -- I wasn't even of age to be 13 that you do in order to get better?
14 able to buy it. I mean, if there was alcohol at 14 A She loves what I'm doing with speaking
15 parties I would have drank it, but I wouldn't say I 15 out. She thinks the more that I speak out about it,
16 abused it. 16 the stronger I'll become. She recommends that I
17 Q Okay. Were there ever occasions upon 17 write my book, I tell my story. She thinks not only
18 which you were observed to be drunk by other people, 18 will it help me, but by helping me it'll help others
19 prior to meeting Jeffrey Epstein? 19 find a way to get out of the situation and to know
20 A If you're drinking, the possibility of 20 that there's other girls who have gone through what
21 getting drunk is always there. I don't -- I can't 21 I've gone through and what they're going through.
22 recall exact situation where that was the case, 22 She recommends meditation, breathing
23 but -- 23 techniques, focus techniques.
24 Q Were you diagnosed as a drug addict prior 24 Q Does she prescribe medications for you?
25 to meeting Jeffrey Epstein? 25 A No, she doesn't. She's a spiritual
Page 334 Page 336

1 A No, I was not diagnosed as a drug addict. 1 doctor.
2 Q Were you sent to live at a rehabilitation 2 Q Is there anything that she's recommended
3 facility because of your use of drugs? 3 that you do that you're not doing?
4 A No, that was more of a group home. Yes, 4 A Is there anything that I do that she
5 it was also a rehab facility, but it wasn't because I 5 recommends I don't? Sorry, say that one more time.
6 was a drug addict. I wasn't coming off of anything. 6 Q That's okay. Is there anything that
7 Q Had you abused drugs prior to meeting 7 Dr. Lightfoot has recommended that you do that you
8 Jeffrey Epstein? 8 are not actually doing?
9 A I took drugs. I didn't abuse them, but I 9 Are you following her advice?
10 took them. 10 A Yes, I am.
11 Q Okay. 11 Q Okay. And what has Dr. Donahue
12 A Recreationally. 12 recommended that you do?
13 Q How often do you see Dr. Lightfoot? 13 I
A Once a week every Monday. I've skipped
■
14
this week because I've been over here and it's
■
15
expensive to call back home right now, unless you
■
16
FaceTime, but --
■
17
Q Has Dr. Lightfoot recommended that you see
■
18
a treating doctor in person?
■
19
A No, she's -- she knows my history pretty
■
20
21
22
23
24
25
well. And she's a very wonderful woman and I
honestly wouldn't -- Dr. Donahue wants me to go see
another psychiatrist in person, but I prefer to stay
with Judith because she's someone I can personally
relate to.
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Document & Video,
07/30/20
Page 337 Page 339
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MS. MENNINGER: I'm going to ask that we
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I take just a brief break and that I can hopefully then

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I come back and just ask a few final follow-up

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■
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I THE DEPONENT: Okay.

■
20
THE VIDEOGRAPHER: We are off the record
■
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at 5:16.
■
22
(Recess taken from 5:16 p.m. to 5:25 p.m.)
■
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I THE VIDEOGRAPHER: We're back on the

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record at 5:25.
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Page 338 Page 340

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Agren Blando
Document & Video,
07/30/20
Page 341 Page 343
1 Q When was it? 1 read it.
2 A I don't know the exact date. 2 MS. MENNINGER: We're going off the
3 Q What's your best recollection? 3 record.
4 A I don't know. I would have to have dates 4 MR. EDWARDS: Yeah, that's fine. She'll
5 in front of me. If you've got something that has a 5 read.
6 date on there, I'm happy to look at it and tell you 6 THE VIDEOGRAPHER: That concludes today's
7 it's right or wrong. 7 proceedings. We're off the record at 5:28.
8 Q It was a few months ago or many months 8 (Proceedings concluded at 5:28 p.m.)
9 ago? 9
10 A Um, to my best recollection, it was about 10 *******
11 a year ago. 11
12 MS. MENNINGER: I have no further 12
13 questions for you at this time. As you know, there 13
14 are some questions that you refused to answer and 14
15 other questions that your attorney directed you not 15
16 to answer. So we will take those up with the Court 16
17 and may see you again. 17
18 THE DEPONENT: Okay. 18
19 MR. EDWARDS: And just as a matter of 19
20 clarification, I don't believe that there's anything 20
21 she's refused to answer. There may be things that 21
22 I've instructed her not to answer because I believe 22
23 that they were privileged or for whatever reason I 23
24 instructed her not to answer but she hasn't refused 24
25 to answer them. 25
Page 342 Page 344

1 Either way, the record is what it is. 1 I, VIRGINIA GIUFFRE, do hereby certify that
2 MS. MENNINGER: I was going to say, do you 2 I have read the foregoing transcript and that the
3 dispute that the court reporter has been taking down 3 same and accompanying amendment sheets, if any,
4 what was said this entire time? 4 constitute a true and complete record of my
5 MR. EDWARDS: I'll read it. She'll read. 5 testimony.
6 MS. MENNINGER: Actually, that's a good 6
7 question. 7
8 Q (BY MS. MENNINGER) Do you have any 8
________________________________
9 questions that I've asked you today that you don't 9 Signature of Deponent
( ) No Amendments
10 feel like you understood? 10 ( ) Amendments Attached
11 A No, I don't think that there's questions 11 Acknowledged before me this
12 that you've asked me that I don't think I've 12 _____ day of ______________, 2016.
13 understood. But, you know, I really just want to 13
14 state something for my own piece of mind, if that's 14 Notary Public: ________________________
15 okay, if I'm allowed to do that. 15 Address: _____________________________
16 Q No, that's not really what this forum is 16 _____________________________
17 about. 17 My commission expires _________________
18 A Okay. 18 Seal:
19 Q There are other forums. 19
20 MR. EDWARDS: That will only be good for 20
21 them. There is no reason to say that. 21 KAM
22 THE DEPONENT: Okay. 22
23 MR. EDWARDS: You get a chance to talk 23
24 later. 24
25 Do you have an order form? And she'll 25

Agren Blando
Document & Video,
07/30/20
Page 345 Page 347
1 STATE OF COLORADO) 1 AGREN BLANDO COURT REPORTING & VIDEO, INC.
216 - 16th Street, Suite 600
2 ) ss. REPORTER'S CERTIFICATE 2 Denver, Colorado 80202
4450 Arapahoe Avenue, Suite 100
3 COUNTY OF DENVER ) 3 Boulder, Colorado 80303
4 I, Kelly A. Mackereth, do hereby certify 4
5 that I am a Registered Professional Reporter and 5
6 Notary Public within the State of Colorado; that 6 VIRGINIA GIUFFRE
May 3, 2016
7 previous to the commencement of the examination, the 7 Giuffre v. Maxwell
Case No. 15-cv-07433-RWS
8 deponent was duly sworn to testify to the truth. 8
9 I further certify that this deposition was 9
The original videotaped deposition was filed with
10 taken in shorthand by me at the time and place herein 10
Laura A. Menninger, Esq., on approximately the
11 set forth, that it was thereafter reduced to 11
11th day of May, 2016.
12 typewritten form, and that the foregoing constitutes 12
_____ Signature waived.
13 a true and correct transcript. 13
_____ Unsigned; signed signature page and
14 I further certify that I am not related to, 14 amendment sheets, if any, to be filed at
trial.
15 employed by, nor of counsel for any of the parties or 15
_____ Reading and signing not requested pursuant
16 attorneys herein, nor otherwise interested in the 16 to C.R.C.P. Rule 30(e).
17 result of the within action. 17 _XXX_ Unsigned; amendment sheets and/or signature
pages should be forwarded to Agren Blando to
18 In witness whereof, I have affixed my 18 be filed in the envelope attached to the
sealed original.
19 signature this 11th day of May, 2016. 19
20 My commission expires April 21, 2019. 20
21 21 Thank you.
22 ____________________________ 22 AGREN BLANDO COURT REPORTING & VIDEO, INC.
Kelly A. Mackereth, CRR, RPR, CSR
23 216 - 16th Street, Suite 600 23 cc: All Counsel
24 24
25 25
Page 346
1 AGREN BLANDO COURT REPORTING & VIDEO, INC.
216 - 16th Street, Suite 600 - AMENDMENT SHEET -
2 Denver, Colorado 80202
4450 Arapahoe Avenue, Suite 100
3 Boulder, Colorado 80303 Videotaped Deposition of VIRGINIA GIUFFRE
May 3, 2016
4 May 11, 2016 Giuffre v. Maxwell
5 Sigrid S. McCawley, Esq.
BOIES, SCHILLER & FLEXNER LLP The deponent wishes to make the following changes in
6 401 East Las Olas Boulevard the testimony as originally given:
Suite 1200 Page Line Should Read Reason
7 Fort Lauderdale, FL 33301-2211 ____ ____ ______________________________ ______
8 Re: Videotaped Deposition of VIRGINIA GIUFFRE ____ ____ ______________________________ ______
Giuffre v. Maxwell
9 Case No. 15-cv-07433-RWS ____ ____ ______________________________ ______
10 The aforementioned deposition is ready for reading ____ ____ ______________________________ ______
and signing. Please attend to this matter by
11 following BOTH of the items indicated below: ____ ____ ______________________________ ______
12 _____ Call 303-296-0017 and arrange with us to read ____ ____ ______________________________ ______
and sign the deposition in our office.
13 ____ ____ ______________________________ ______
_XXX_ Have the deponent read your copy and sign
14 the signature page and amendment sheets, if
applicable; the signature page is attached. ____ ____ ______________________________ ______
15 ____ ____ ______________________________ ______
_____ Read the enclosed copy of the deposition and
16 sign the signature page and amendment
sheets, if applicable; the signature page is ____ ____ ______________________________ ______
17 attached.
____ ____ ______________________________ ______
18 _XXX_ WITHIN 30 DAYS OF THE DATE OF THIS LETTER
____ ____ ______________________________ ______
19 _____ By ______ due to a trial date of _______
____ ____ ______________________________ ______
20 Please be sure the original signature page and
amendment sheets, if any, are SIGNED BEFORE A NOTARY Signature of Deponent: ____________________
21 PUBLIC and returned to Agren Blando for filing with
the original deposition. A copy of these changes
22 should also be forwarded to counsel of record. Acknowledged before me this ____ day of
Thank you. ______________, 2016.
23 Notary's signature ________________
AGREN BLANDO COURT REPORTING & VIDEO, INC. (seal)
24
My commission expires ____________.
25 cc: All Counsel

EXHIBIT E
B O I E S, S CH I L L E R & F L E X N E R LL P
401 EAST LAS OLAS BOULEVARD• SUITE 1200 • FORT LAUDERDALE , FL 33301 - 22 I• PH. 954.356.00 1 • FAX 954.356.0022
Meredith Schultz, Esq.

E-mail: mschultz@bstllp.com
May 23, 2016
VIA E-MAIL

lmenn inger @hmtlaw .com
Re: Giuffre v. Maxwell

Dear Laura :
This letter is to seek your agreement to produce Ross Gow for deposition, as the agent of
your client, Ms. Maxwell. We can work with Mr. Gow ' s schedule to minimize inconvenience.
Please advise by Wednesday, May 25, 2016, whether you will produce Mr. Gow, or whether we
will need to seek relief from the Court with respect to his deposition.
Sincerely ,
MLS:dk
WWW .BSFLLP.COM
Haddon,MorganandForeman, P.C
LauraA.Menninger

PH 303.831.7364 FX 303.832.2628
www.hmflaw.com
May 25, 2016
VIA EMAIL
Meredith Schultz
mschultz@bsfllp.com
Re: Giuffre v. Maxwell, Case No. 15-cv-07433-RWS
Dear Ms. Schultz:
I am not aware of any legal authority that would allow Ms. Maxwell to
“produce” Ross Gow for a deposition and you do not cite to any rule or case that
would either enable or require her to do so. If you are aware of any authority for this
request please provide it to me and I will consider it.
Sincerely,

Laura A. Menninger
B O I E S . S C H I L L E R & F L E X N E R L L P
401 EAST LAS OLAS BOULEVARD • SUITE 1200• FORT LAUDERDALE, FL 33301 - 22 1 • PH. 954,356.00 I • FAX 954.356.0022
Sigrid S. Mccawley, Esq,

E-mail: smccawlev@bstllp,com
May 12, 2016
VIA E-MAIL

Jeffrey Pagliuca, ESQ.
HADDON, MORGAN AND FOREMAN, P .C.

Dear Ms. Menninger:
Please find enclosed Bates-stamped GIUFFRE005370 through GIUFFRE005438, which

are being produced pursuant to Defendant's Request for Production. Certain of the documents
within this production have been designated as CONFIDENTIAL in accordance with the
Protective Order. Please treat these documents accordingly.
If you have any questions concerning the foregoing, or ifthere are any issues with the
media, please do not hesitate to contact me at (954) 356-0011.
Sincerely,
Sigrid S. Mccawley
SSM/ep
Enclosures
WWW.BSFLLP.COM
Authorization to Disclose Protected Health Information

Name: Virginia Giuffre
I hereby authorize the use and/or disclosure of my protected health information as

described in this authorization.
l. Specific person/organization (or class of persons) authorized to provide the

information:
Judith Lightfoot
2. Specific person/organization (or class of persons) authorized to receive

and use the information:
Sigrid Mccawley
3. Specific description of the information: Medical records from 1999 to the

present, including, but not limited to, all ofmy office medical records, hospital medical
records, patient information sheets, questionnaires, x-rays, other diagnostic studies and
laboratory tests, emergency room records, out-patient records, consultation records,
therapy records, and all other in-patient or out-patient hospital notes, charts, documents,
all personal notes and all billing records.
4. Specific purpose for the use and/or disclosure of the protected health
information: At my request in connection with litigation pending in the County District
Court.
5. I understand this authorization will expire, without my express revocation,

one year from the date of signing, or ifl am a minor, on the date I become an adult
according to state law. I understand that I may revoke this authorization in writing at any
time except to the extent that action has been taken based on this authorization. I
understand that revocation will not apply to infonnation that has already been released as
specified by this authorization or to my insurance company when the law provides my
insurer with the right to contest a claim under my policy or the policy itself.
GIUFFRE005431
CONFIDENTIAL
6. I understand that the medical information released by this authorization

may include infom1ation concerning treatment of physical and mental illness,
alcohol/drug abuse and past medical history.
7. r understand that after this information is disclosed, federal law might

not protect it and the recipient might disclose it.
8. [ understand that I am entitled to receive a copy ofth1s authorization.
9. I understand that l may refuse to sign this authorization and that my

refusal to sign will not affect my ability to obtain treatment from the above-named
medical provider.
l 0 .. (\Photopopies of this authorization are to be given the same effect as the

original. \/. _...·
(,~t~ 5 /J / l (.·· i
Signatur'i? ) Date
GIUFFRE005432
CONFIDENTIAL
EXHIBIT H
B O I E S , S C H I L L E R & F L E X N E R L L P
401 EAST LAS OLAS BOULEVARD• SUITE 1200 • FORT LAUDERDALE. FL 33301 - 22 1I • PH 954.356 .001 1 • FAX 954.356.002 2
Meredith Schultz. Esq.

E-n>aiI: mschultz@bst1Ip.com
June 1, 20 16
VlAE-MAIL
Laura A. Menninger, Esq .

Jeffrey Pag liuca, ESQ.
Denve r, Colorado 80203
Re: Giuffre v. Max well

Case No . 15-cv-07433-RW S
Dear Counsel:
On behalf of the Plaintiff Virg inia Giuffre , documents, Bates-stamped

GUIFFRE005498- GIUFFRE005569; GIUFFRE005570- GIUFFRE005580; GIUFFRE005581-
GITJFFRE005606 are being produced pursuant to Defendant's Request for Production.
Documents are designated confidential pursuant to this Court's Protective Order;

pkase treat them accordingly.
If you have any questions concerning the foregoing, or if there are any issues with the
media. please do not hesitate to contact me at (954) 356-0011.
Sincerely .
1/SL;lc
Mere dith Schu ~
R
MS/sp
Enclosure
WWW .BSFL LP .COM

EXHIBIT I
Agren Blando
Document 1090-35 & Video,
Filed Inc. Page 2 of 2
07/30/20
Page 33 Page 35
1 document that in the computer. 1 A Um-hum, yes.
2 Q All right. So you might take notes while 2 I would say that the majority of the notes
3 you're meeting with a patient? 3 get done immediately because the medical assistant is
4 A (Indicating.) 4 writing down in the, oh, the HPI section why they're
5 Q And then when do you enter it into a 5 there. And the assessments, I do everything
6 computer? 6 electronic. I put all the orders in. I put all the
7 A I'd say the majority of the time it's 7 labs in, medications, and I make sure that the
8 either right after if I can, if I have time, or at 8 assessment plan is laid out that -- that day so that
9 lunch if I can. If it's at the end of the day, it 9 if I do get behind, I have to do it later or a couple
10 would probably be the next morning. I'd show up at 10 days later on the weekend.
11 least an hour early to do the afternoon notes in the 11 Basically it's just clicking a button, but
12 morning, the following morning. But there are 12 all of the pertinent information is already filled
13 occasions where I catch up a good day or two later on 13 out in the assessment plan.
14 the weekends. 14 Q Okay.
15 Q It doesn't sound like you're a person who 15 A So it's mostly done. I would say if
16 dictates? 16 they're not done, they're 70 percent complete and I
17 A No, I don't dictate. 17 just -- there's a lot of radial buttons for us to
18 Q So you, yourself, are the one who enters 18 click to complete the medical record.
19 it -- 19 Q Okay. And I presume during the course of
20 A Yeah. 20 your work as a resident and then at Saint Thomas
21 Q -- into a computer? 21 More, you strive to keep accurate records in your
22 A Yes. 22 practice?
23 Q And do you make a notation when you enter 23 A Yes.
24 it into the computer as to the time you entered it 24 Q You've been trained to do that?
25 relative to the time the information was taken? 25 A Yes.
Page 34 Page 36
1 A No. 1 Q All right. Do you know how you came to be
2 Q So, for example, in old school medical 2 the doctor for Virginia Giuffre?
3 records where it might say dictated on a later date, 3 A No. I -- she would have filled out a new
4 your system doesn't reflect that? 4 patient packet and showed up for a new patient
5 A I have to go in -- there might be a thing 5 appointment for a particular reason. I reviewed it.
6 that says when it was signed. 6
7 Q So there was a provision for an electronic 7
8 signature? 8 Q Do you know where that new patient packet
9 A Yeah, I mean, I electronically sign all 9 is now?
10 the notes. So that might say the time. I guess I 10 A It's going to be scanned in the computer.
11 look at it. 11 If you don't have it, I brought my computer. I can
12 Q And what is the purpose in your mind of 12 probably scan it and print it out or just print it
13 keeping good records of your patient visits? 13 out.
14 A One, so that I or somebody else can see 14 Q Is that among the documents that you have
15 what happened at the visit to see what happened and 15 next to you?
16 get an idea of what happened in the past and what to 16 A The new patient packet isn't here, but I
17 do going forward. 17 have it -- I should have it on my computer. I could
18 Q Fair to say it's important for purposes of 18 probably log in and print it, to be honest. It
19 future treatment of that patient, correct? 19 wouldn't be that hard. I assumed that the hospital
20 A Yes. 20 is taking care of all the documentation that was
21 Q For example, medications need to be well 21 requested. So I didn't actually bring it.
22 documented? 22 Q I understand.
23 A Yes. 23 A I actually have it, happen to have it with
24 Q And complaints of symptoms would be 24 me.
25 documented? 25 Q All right. Why don't we -- we can
STEVEN W OLSON 5/26/2016 9 (33 - 36)

EXHIBIT K
B O I ES. SCHILL ER & F LE X NE R LL P

401 EAST LAS OLAS BOULEVARD• SUITE 1200 · FORT LAUDERDALE. FL 33301·2211• PH. 954.356.0011 • FAX 954.356.0022
Sigrid S. McCawley,Esq.
E-mail: smccawley@bsfllp. cotn
June 10, 2016
VIA E-MAIL

lrnenninger@hmflaw.com

Dear Ms. Menninger:
On behalf of the Plaintiff , Virginia Giuffre, documents, Bates-stamped GIUFFRE005607

through GIUFFRE005613, are being produced pursuant to Defendant's Request for Production.
Certain of the docwnents within this production have been designated as CONFIDENTJALin
accordance with your proposed Protective Order. Please treat these documents accordingly.
This production consists solely of all data that is responsive to Defendant's various
requests for production from Ms. Giu:ffre's iCloud account.
Attached to this letter, please also find an updated privilege log.
If you have any questions concerning the foregoing , or if there are any issues with the
media, please do not hesitate to contact me at (954) 356-0011.
Sincerely,
SSM:dk
Enclosures
WWW.SSFLLP.COM
From: Richards, Jason R.

To: Robert Giuffre
Subject: RE: Hi There
Date: Wednesday, August 27, 2014 10:44:32 AM
Hi Jenna,
My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information
you are looking for because I am not able to release information (should there be any) from FBI
regarding your recovery. Hope this helps.
Best wishes,
-
records. You need to include as many details as possible so they can focus and narrow the search.
Explain that you are looking for information related to your recovery as a victim of . The
process may take some time but it is the appropriate method for you to obtain any possible records
Jason
-----Original Message-----
From:
Sent: Wednesday, August 27, 2014 9:49 AM
To: Richards, Jason R.
Subject: Hi There
G'day Jason,
I know I am a pain in your rear right now and I don't want to be but I am so close to wrapping up an
era, just need a couple dates confirmed is all.
If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton
Manors police dept upside down looking through records and come up w nada. What was your
acquaintance's name that took my statement about Is it possible that it wasn't Wilton
Manors and maybe it was somewhere else?
I'm really racking my brain about this!! It would be a personal favor to me and I am so very much
appreciative of anything you might know!!
Thanks a lot mate!!
Jenna
Sent from my iPhone
GIUFFRE005607
CONFIDENTIAL
From: Richards, Jason R.

To:
Subject: Re: Hi There
Date: Wednesday, August 27, 2014 10:50:27 AM
Feel free to reach out to me any time.

Take care.
Jason
----- Original Message -----

From:
To: Richards, Jason R.
Sent: Wed Aug 27 10:46:50 2014
Subject: Re: Hi There
Thank you Jason. I hope all has been well for you and yours!
All the best, I won't bother you again.
Jenna
Sent from my iPhone
> On Aug 27, 2014, at 10:44 AM, "Richards, Jason R." <Jason.Richards2@ic.fbi.gov> wrote:
>
> Hi Jenna,
>
> My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the
information you are looking for because I am not able to release information (should there be any) from
-
FBI records. You need to include as many details as possible so they can focus and narrow the search.
Explain that you are looking for information related to your recovery as a victim of
process may take some time but it is the appropriate method for you to obtain any possible records
regarding your recovery. Hope this helps.
>
> Best wishes,
. The
>
> Jason
>
> -----Original Message-----
> From:
> Sent: Wednesday, August 27, 2014 9:49 AM
> To: Richards, Jason R.
> Subject: Hi There
>
> G'day Jason,
>
> I know I am a pain in your rear right now and I don't want to be but I am so close to wrapping up an
era, just need a couple dates confirmed is all.
>
> If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton
acquaintance's name that took my statement about

Manors and maybe it was somewhere else?
> -
Manors police dept upside down looking through records and come up w nada. What was your
? Is it possible that it wasn't Wilton
> I'm really racking my brain about this!! It would be a personal favor to me and I am so very much
appreciative of anything you might know!!
GIUFFRE005608
CONFIDENTIAL
>
> Thanks a lot mate!!
>
> Jenna
>
> Sent from my iPhone
GIUFFRE005609
CONFIDENTIAL
From:
To: Jason.Richards2@ic.fbi.gov
Subject: Virginia Roberts(Jane doe 102)
Date: Tuesday, April 15, 2014 9:50:31 AM
Hi Jason,
Long time, no talk. I hope all has been well for you and yours!! I am now back in the USA, not too
many people know about that and I'd like to keep it that way as my case against Jeffrey Epstein has
intensified!! I am here to get this BS non- prosecution agreement thrown out and speaking w Judge
Paul Cassal he suggested trying to get ahold of any photos and/or video recordings released by the FBI
to assist our case further in proving how much pedophilia occurred by Jeffrey and the many other
monsters he obliged w underage girls. If this is a possibility please let me know so I can give you Brad
Edwards( my attorney) his contact details. Many thanks for your time and I hope we should meet again.
-
Kindest Regards,
Virginia Roberts
Phone 8
Sent from my iPhone
GIUFFRE005610
CONFIDENTIAL
From:
To: christina.pyror@ic.fbi.gov
Subject: Virginia Roberts re: Jeffrey Epstein Case
Date: Wednesday, April 16, 2014 1:52:05 PM
Hi Christina,
I was wondering if you remember me from Sydney Consulate, I am a victim in the investigation from
the Jeffrey Epstein case and was wondering if you could tell me if I would be able to get ahold of any
of the pics and/or videos that the FBI might have confiscated from any of Epstein's residences? Also can
I ask if you might have any of the flight logs that include my name in them to be sent to me as well.
It's all for evidential purposes and would prove a many of things to help my case.
Kindest Regards,
Virginia Roberts
Sent from my iPhone
GIUFFRE005611
CONFIDENTIAL
From: sharonrikard@gmail.com on behalf of Sharon Rikard

To: Virginia Giuffre
Subject: Re: Victims Refuse Silence
Date: Saturday, March 28, 2015 9:49:55 AM
Hi Virginia,
So sorry for the late response. Our organization currently works with survivors of
sex trafficking provided continuing education, life skills and counseling. We will help
with transportation and their basic necessities. Our ultimate goal is a home for
domestic minor sex trafficking survivors.
Our contact information is:
doorstofreedom.com
infor@doorstofreedom.com
843-817-0740
I am going to forward your information to our Attorney Generals office as

Marie Sazehn has compiled a list of organizations in our state of people/organizations
and their involvement in helping survivors.
Thanks for all you are doing to help others!
Blessings,
Sharon Rikard
GIUFFRE005612
CONFIDENTIAL

To: sharon@doorstofreedom.com
Subject: Victims Refuse Silence
Date: Wednesday, March 18, 2015 12:19:06 PM
Hi Sharon,
This is Virginia, we spoke earlier and I just wanted to say thank you for your time and what your doing
to help the victims in your area. The mentality has to be changed!! Good luck!!
Kindest Regards,
Virginia Roberts
Sent from my iPhone
GIUFFRE005613
CONFIDENTIAL
Log Privilege Doc
ID Email Sent Date Email From Email To CC Address Subject Matter Type of Privilege Action Page Count Type
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Edwards and Cassell re attorney defense/commo
1 2/12/2015 6:14 Virginia Giuffre smccawley@bsfllp.com impressions and legal advice relating to deposition testimony n interest Withheld 3 msg
AC Privilege and
Work
2 2/16/2015 1:05 StanPottinger@aol.com

ad@pathtojustice.com,
-
Smccawley@BSFLLP.com,br
Discussion of evidence among client and attorneys

Product/joint
defense/commo
n interest
Attorney
Client/joint
Withheld 2 msg
defense/commo
Email chain with Giuffre, McCawley, Pottinger and Edwards re n interest/work
3 2/16/2015 15:37 Virginia Giuffre Smccawley@BSFLLP.com information provided by client to assist in legal advice product Withheld 2 msg
Attorney
Client/joint
defense/commo
4 2/16/2015 16:15 Sigrid McCawley information provided by client to assist in legal advice product Withheld 2 msg
Attorney
Client/joint
defense/commo
5 2/16/2015 16:24 Virginia Giuffre Smccawley@BSFLLP.com information provided by client to assist in legal advice product Withheld 2 msg
Attorney
Client/joint
defense/commo
6 2/16/2015 16:24 Sigrid McCawley information provided by client to assist in legal advice product Withheld 2 msg
AC Privilege and
StanPottinger@aol.com,bra Work
7 2/21/2015 16:45 Sigrid McCawley

p@law.utah.edu,
-
d@pathtojustice.com,cassell
Smccawley@BSFLLP.com Discussion of evidence among client and attorneys

Product/joint
defense/commo
n interest Withheld 2 msg
Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
Log Privilege Doc
AC Privilege and
Work
Product/joint
defense/commo
8 2/21/2015 16:58 Virginia Giuffre Smccawley@BSFLLP.com Discussion of evidence among client and attorney n interest Withheld 2 msg
AC Privilege and
Work
StanPottinger@aol.com,cassellp@l Product/joint
aw.utah.edu, defense/commo
9 2/21/2015 17:05 Brad Edwards Smccawley@BSFLLP.com Discussion of evidence among client and attorneys n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
defense/commo
10 2/21/2015 17:10 Sigrid McCawley r Discussion of evidence among client and attorney n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
defense/commo
11 2/21/2015 17:16 Virginia Giuffre Smccawley@BSFLLP.com Discussion of evidence among client and attorneys n interest Withheld 3 msg
AC Privilege and
Work
StanPottinger@aol.com,brad@pat Product/joint
htojustice.com,cassellp@law.utah. defense/commo
12 2/23/2015 14:21 Sigrid McCawley edu Discussion of thoughts and impressions of attorneys n interest Withheld 1 msg
AC Privilege and
Work
Product/joint
Smccawley@BSFLLP.com,ro brad@pathtojustice.com,cassellp@ defense/commo
13 2/23/2015 14:29 StanPottinger@aol.com law.utah.edu Discussion of thoughts and impressions of attorneys n interest Withheld 1 msg
AC Privilege and
Work
StanPottinger@aol.com,brad@pat Product/joint
htojustice.com,cassellp@law.utah. defense/commo
14 2/23/2015 16:01 Virginia Giuffre Smccawley@BSFLLP.com edu Discussion of thoughts and impressions of attorneys n interest Withheld 1 msg
Log Privilege Doc
AC Privilege and
Work
Product/joint
Email chain with McCawley, Giuffre, and Paralegals re seeking defense/commo
15 2/24/2015 17:51 Sigrid McCawley information to assist in legal advice, with attachment n interest Withheld 4 msg
AC Privilege and
Work
Product/joint
defense/commo
16 Attached case research n interest Withheld 14 rtf
AC Privilege and
Work
Product/joint
Email chain with Giuffre, McCawley and legal assistant re legal defense/commo
17 2/26/2015 12:59 Virginia Giuffre Smccawley@BSFLLP.com document, with attachment n interest Withheld 1 msg
AC Privilege and
Work
Product/joint
defense/commo
18 Attached draft legal document n interest Withheld 1 jfif
AC Privilege and
Work
Product/joint
Email with Giuffre, McCawley, Edwards and Henderson re defense/commo
19 2/28/2015 17:47 Virginia Giuffre Smccawley@BSFLLP.com discussion of draft statement n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
Smccawley@BSFLLP.com,brad@pa Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
20 3/13/2015 17:29 Stan Pottinger thtojustice.com Pottinger re legal advice on media issues n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Edwards, McCawley and Pottinger re defense/commo
21 3/13/2015 17:49 Virginia Giuffre stanpottinger@aol.com legal advice on media issues n interest Withheld 2 msg
Log Privilege Doc
AC Privilege and
Work
Product/joint
Smccawley@BSFLLP.com,brad@pa Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
22 3/13/2015 17:56 StanPottinger@aol.com thtojustice.com Pottinger re legal advice on media issues n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
StanPottinger@aol.com, Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
23 3/13/2015 18:00 Brad Edwards ■ Smccawley@BSFLLP.com Pottinger re legal advice on media issues n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
24 3/13/2015 18:24 Virginia Giuffre brad@pathtojustice.com Pottinger re legal advice on media issues n interest Withheld 4 msg
AC Privilege and
Work
Product/joint
25 3/13/2015 18:25 Virginia Giuffre StanPottinger@aol.com Pottinger re legal advice on media issues n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
Smccawley@BSFLLP.com,StanPotti Email chain with Giuffre, Edwards, McCawley, Henderson and defense/commo
26 3/13/2015 21:53 Virginia Giuffre brad@pathtojustice.com nger@aol.com Pottinger re legal advice on media issues n interest Withheld 4 msg
AC Privilege and
Work
Product/joint
27 3/13/2015 23:38 Brad Edwards Pottinger re legal advice on media issues n interest Withheld 4 msg
AC Privilege and
Work
Product/joint
28 3/13/2015 23:40 Virginia Giuffre brad@pathtojustice.com Pottinger re legal advice on media issues n interest Withheld 4 msg
Log Privilege Doc
Attorney
Client/joint
Smccawley@BSFLLP.com,br defense/commo
ad@pathtojustice.com,stan Providing information to assist in legal advice re potential legal n interest/work
29 3/17/2015 15:20 Virginia Giuffre pottinger@aol.com action, with attachments product Withheld 1 msg
Attorney
Client/joint
30 3/17/2015 18:40 Stan

ad@pathtojustice.com,
-
Smccawley@BSFLLP.com,br
Email chain with Giuffre, Edwards, Pottinger and McCawley re
legal advice related to VRS
defense/commo
n interest/work
product
Attorney
Client/joint
Withheld 1 msg
defense/commo
Email chain with Giuffre, Edwards, Pottinger and McCawley re n interest/work
31 3/17/2015 19:42 Virginia Giuffre stanpottinger@aol.com legal advice related to VRS product Withheld 1 msg
Attorney
Client/joint
brad@pathtojustice.com, I defense/commo
tan aortiz@BSFLLP.com,brittany@path Email chain with Giuffre, Edwards, Henderson, Pottinger, n interest/work
32 3/20/2015 15:43 Sigrid McCawley pottinger@aol.com tojustice.com McCawley and BSF staff re legal advice related to VRS product Withheld 1 msg
Attorney
Client/joint
defense/commo
n interest/work
33 3/20/2015 15:57 Sigrid McCawley Providing legal advice re potential deposition product Withheld 1 msg
Attorney
Client/joint
defense/commo
Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work
34 3/24/2015 21:19 Sigrid McCawley aortiz@BSFLLP.com BSF staff re legal advice related to VRS product Withheld 2 msg
Log Privilege Doc
Attorney
Client/joint
defense/commo
35 3/24/2015 21:21 Virginia Giuffre Smccawley@BSFLLP.com aortiz@BSFLLP.com BSF staff re legal advice related to VRS product Withheld 2 msg
Attorney
Client/joint
defense/commo
Smccawley@BSFLLP.com, I Email chain with Giuffre, Edwards, Henderson, McCawley and n interest/work
36 3/24/2015 21:36 Andres Ortiz BSF staff re legal advice related to VRS product Withheld 2 msg
Attorney
Client/joint
defense/commo
37 3/24/2015 22:21 Virginia Giuffre aortiz@BSFLLP.com BSF staff re legal advice related to VRS product Withheld 3 msg
Attorney
Smccawley@BSFLLP.com,StanPotti Client/joint
nger@aol.com,brad@pathtojustice defense/commo
.com,brittany@pathtojustice.com,e Email chain with Giuffre, Edwards, Henderson, Pottinger, n interest/work
38 3/26/2015 2:00 Sigrid McCawley perez@BSFLLP.com McCawley and BSF staff re legal advice related to VRS product Withheld 1 msg
Attorney
Client/joint
defense/commo
39 3/26/2015 2:21 Virginia Giuffre Smccawley@BSFLLP.com BSF staff re legal advice related to VRS product Withheld 2 msg
Attorney
Client/joint
defense/commo
40 3/26/2015 2:22 Sigrid McCawley BSF staff re legal advice related to VRS product Withheld 2 msg
Log Privilege Doc
Attorney
Client/joint
defense/commo
41 3/26/2015 3:00 Virginia Giuffre Smccawley@BSFLLP.com BSF staff re legal advice related to VRS product Withheld 2 msg
Attorney
Client/joint
defense/commo
Giuffre conveying information sought by attorney to assist in n interest/work
42 4/1/2015 21:32 Virginia Giuffre Smccawley@BSFLLP.com legal advice with attachments product Withheld 1 msg
Attorney
Client/joint
defense/commo
Providing draft legal document for client review, with n interest/work
43 4/2/2015 7:01 Brittany HendersonI eperez@BSFLLP.com attachment product Withheld 1 msg
AC Privilege and
Work
Product/joint
defense/commo
44 Attached Draft legal document n interest Withheld 15 pdf
AC Privilege and
Work
Product/joint
brad@pathtojustice.com,eperez@ Email chain with Giuffre, Henderson, Edwards and legal defense/commo
45 4/3/2015 15:32 Brittany Henderson BSFLLP.com assistant re legal document, with attachment n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
defense/commo
46 Attached draft legal document n interest 15 pdf
Log Privilege Doc
Attorney
Client/joint
defense/commo
n interest/work
47 4/8/2015 20:34 Virginia Giuffre Smccawley@BSFLLP.com Seeking legal advice related to VRS product Withheld 1 msg
Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re advice re legal filings, n interest/work
48 4/9/2015 3:23 Virginia Giuffre Smccawley@BSFLLP.com with attachments product Withheld 2 msg
Attorney
Client/joint
49 4/9/2015 7:16 Sigrid McCawley

d@pathtojustice.com,
-
StanPottinger@aol.com,bra
brittany@pathtojustice.com,sperki Email chain with Giuffre, Edwards, Henderson, McCawley and
ns@BSFLLP.com BSF staff re legal advice re media issues
defense/commo
n interest/work
product
Attorney
Client/joint
Withheld 2 msg
defense/commo
Email chain with Giuffre, Edwards, and McCawley re legal advice n interest/work
50 4/9/2015 9:26 Brad Edwards Smccawley@BSFLLP.com re media issues product Withheld 1 msg
Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re legal advice re media n interest/work
51 4/9/2015 9:33 Sigrid McCawley issues product Withheld 2 msg
AC Privilege and
Work
Product/joint
Conveying legal advice re draft legal documents to client, with defense/commo
52 4/9/2015 12:46 Sigrid McCawley attachments n interest Withheld 1 msg
Log Privilege Doc
AC Privilege and
Work
Product/joint
53 attachments n interest Withheld 14 docx
AC Privilege and
Work
Product/joint
AC Privilege and
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Product/joint
Attorney
Client/joint
defense/commo
StanPottinger@aol.com,brad@pat n interest/work
56 4/10/2015 14:59 Sigrid McCawley htojustice.com Providing legal advice re media issues product Withheld 1 msg
Attorney
Client/joint
defense/commo
n interest/work
57 4/10/2015 15:37 Virginia Giuffre Smccawley@BSFLLP.com Regarding legal advice re media issues product Withheld 1 msg
AC Privilege and
Work
StanPottinger@aol.com,brad@pat Email chain with Giuffre, McCawley, Henderson, Edwards, Product/joint
htojustice.com,brittany@pathtojus Pottinger and legal assistant re legal documents, with defense/commo
58 4/10/2015 17:31 Sigrid McCawley tice.com,eperez@BSFLLP.com attachments n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
defense/commo
59 Attached draft legal document n interest Withheld 3 pdf
Log Privilege Doc
AC Privilege and
Work
Product/joint
defense/commo
60 Attached draft legal document n interest Withheld 21 pdf
Attorney
Client/joint
defense/commo
Email chain with Giuffre, McCawley and BSF staff regarding legal n interest/work
61 4/10/2015 17:40 Virginia Giuffre Smccawley@BSFLLP.com advice related to VRS product Withheld 2 msg
Attorney
Client/joint
defense/commo
Attorney
Client/joint
defense/commo
63 4/10/2015 19:28 Sigrid McCawley advice related to VRS product Withheld 2 msg
Attorney
Client/joint
defense/commo
Attorney
Client/joint
defense/commo
Log Privilege Doc
Attorney
Client/joint
defense/commo
Attorney
Client/joint
defense/commo
AC Privilege and
Work
Email chain with Giuffre, McCawley legal assistant re seeking Product/joint
and providing information sought by attorney to assist in defense/commo
68 4/10/2015 23:46 Virginia Giuffre Smccawley@BSFLLP.com providing legal advice, with attachments n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
StanPottinger@aol.com,brad@pat Email chain with Giuffre, Pottinger, Edwards and McCawley re defense/commo
69 4/13/2015 13:52 Sigrid McCawley htojustice.com legal advice regarding potential public statements n interest Withheld 3 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, Pottinger, Edwards and McCawley re defense/commo
70 4/13/2015 13:56 Virginia Giuffre Smccawley@BSFLLP.com legal advice regarding media issues n interest Withheld 3 msg
Attorney
Smccawley@BSFLLP.com,bri Client/joint
ttany@pathtojustice.com defense/commo
■
stan n interest/work
71 4/14/2015 23:38 Brad Edwards pottinger@aol.com Providing legal advice related to VRS product Withheld 1 msg
Log Privilege Doc
Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re legal advice regarding n interest/work
72 4/16/2015 11:14 Virginia Giuffre Smccawley@BSFLLP.com media issues product Withheld 2 msg
Attorney
Client/joint
defense/commo
73 4/16/2015 11:47 Sigrid McCawley media issues product Withheld 2 msg
Attorney
Client/joint
defense/commo
n interest/work
74 4/24/2015 19:22 Sigrid McCawley Providing legal advice re records retention, with attachments product Withheld 1 msg
Attorney
Client/joint
defense/commo
n interest/work
75 Attached letter providing legal advice re document retention product Withheld 2 pdf
Attorney
Client/joint
defense/commo
76 4/24/2015 19:59 Virginia Giuffre Smccawley@BSFLLP.com potential deposition product Withheld 1 msg
Attorney
Client/joint
defense/commo
n interest/work
77 4/27/2015 21:20 Brad Edwards Smccawley@BSFLLP.com Seeking information to assist in providing legal advice product Withheld 1 msg
Log Privilege Doc
AC Privilege and
Work
Smccawley@BSFLLP.com,brad@pa Product/joint
thtojustice.com, defense/commo
78 4/30/2015 6:42 Brittany Henderson eperez@BSFLLP.com Legal documents provided to assist in providing legal advice n interest Withheld 1 msg
Attorney
Client/joint
defense/commo
Email chain with Giuffre, Henderson and paralegal re seeking n interest/work
79 4/30/2015 7:02 Brittany Henderson and providing information to assist in providing legal advice product Withheld 2 msg
AC Privilege and
Work
Email chain with Giuffre, Henderson, Edwards, McCawley and Product/joint
legal assistant re seeking information to assist in providing legal defense/commo
80 4/30/2015 7:05 Virginia Giuffre brittany@pathtojustice.com advice n interest Withheld 2 msg
AC Privilege and
Work
Email chain with Giuffre, Henderson, Edwards, McCawley and Product/joint
legal assistant re seeking information to assist in providing legal defense/commo
81 5/4/2015 20:04 Virginia Giuffre brittany@pathtojustice.com advice, with attachment n interest Withheld 2 msg
AC Privilege and
Work
Email chain with McCawley, Giuffre, Edwards, Pottinger, Product/joint
Henderson and Paralegal re seeking and providing information defense/commo
82 5/11/2015 18:20 Sigrid McCawley Smccawley@BSFLLP.com to assist in legal advice, with attachments n interest Withheld 1 msg
AC Privilege and
Work
Email chain with Giuffre, McCawley, Edwards, Pottinger and Product/joint
Paralegal re seeking information to assist in providing legal defense/commo
83 5/11/2015 18:34 Virginia Giuffre Smccawley@BSFLLP.com advice re potential litigation n interest Withheld 2 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre and McCawley re case research, with defense/commo
84 5/11/2015 18:40 Sigrid McCawley attachment n interest Withheld 2 msg
Log Privilege Doc
AC Privilege and
Work
Product/joint
brad@pathtojustice.com, I Providing and seeking information to assist in legal advice re defense/commo
85 5/11/2015 18:45 Sigrid McCawley potential legal action, with attachment n interest Withheld 1 msg
Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re seeking information n interest/work
86 5/11/2015 18:47 Virginia Giuffre Smccawley@BSFLLP.com to assist in providing legal advice re potential litigation product Withheld 1 msg
AC Privilege and
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Email chain with Giuffre, McCawley, Edwards, Pottinger and Product/joint
Paralegal re seeking information to assist in providing legal defense/commo
87 5/11/2015 18:56 Virginia Giuffre brad@pathtojustice.com advice re potential litigation n interest Withheld 2 msg
Attorney
Client/joint
defense/commo
n interest/work
88 5/17/2015 22:37 Sigrid McCawley Providing litigation documents to client, with attachments product Withheld 3 msg
AC Privilege and
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Product/joint
defense/commo
89 Attached draft legal agreement n interest Withheld 10 pdf
Attorney
Client/joint
defense/commo
n interest/work
90 5/17/2015 22:40 Sigrid McCawley Providing legal advice re legal agreement, with attachment product Withheld 1 msg
AC Privilege and
Work
Product/joint
defense/commo
91 5/18/2015 18:40 Virginia Giuffre Smccawley@BSFLLP.com Discussion of confidential agreement, with attachments n interest Withheld 1 msg
Log Privilege Doc
Attorney
Client/joint
defense/commo
n interest/work
92 Attached confidential agreement page product Withheld 1 jfif
Attorney
Client/joint
defense/commo
n interest/work
93 Attached confidential agreement page product Withheld 1 jfif
Attorney
Client/joint
defense/commo
n interest/work
94 6/5/2015 19:16 Sigrid McCawley Conveying attorney mental impression regarding hearing product Withheld 1 msg
Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re attorney mental n interest/work
95 6/6/2015 17:20 Virginia Giuffre Smccawley@BSFLLP.com impression regarding hearing product Withheld 1 msg
Attorney
Client/joint
defense/commo
n interest/work
96 6/25/2015 2:26 Sigrid McCawley Providing advice re status and strategy of ongoing legal matters product Withheld 6 msg
Attorney
Client/joint
defense/commo
Discussion with S. McCawley regarding file related to n interest/work
97 7/17/2015 14:19 Sigrid McCawley eperez@BSFLLP.com representation by B. Josefsberg product Withheld 4 msg
Log Privilege Doc
Attorney
Client/joint
defense/commo
Providing information to assist in legal advice re potential n interest/work
98 7/27/2015 21:53 Virginia Giuffre Smccawley@BSFLLP.com litigation product Withheld 1 msg
Attorney
Client/joint
defense/commo
n interest/work
99 7/29/2015 19:45 Sigrid McCawley StanPottinger@aol.com Conveying legal advice on media issues product Withheld 1 msg
AC Privilege and
Work
Product/joint
Email chain with Giuffre, McCawley and paralegals re defense/commo
100 8/5/2015 19:51 Sigrid McCawley information sought to assist in providing legal advice n interest Withheld 1 msg
AC Privilege and
Work
Email chain with Giuffre, McCawley, legal intern and paralegal Product/joint
re seeking information to assist in providing legal advice re defense/commo
101 8/6/2015 2:14 Sigrid McCawley potential litigation n interest Withheld 2 msg
AC Privilege and
Work
Email chain with Giuffre, McCawley, legal intern, Edwards and Product/joint
paralegal re seeking information to assist in providing legal defense/commo
102 8/6/2015 2:45 Sigrid McCawley brad@pathtojustice.com advice re potential litigation n interest Withheld 2 msg
AC Privilege and
Work
103 8/6/2015 2:55 Virginia Giuffre Smccawley@BSFLLP.com potential litigation n interest Withheld 2 msg
AC Privilege and
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Product/joint
Smccawley@BSFLLP.com,brad@pa Email chain with McCawley, Giuffre, and Paralegals re seeking defense/commo
104 8/6/2015 3:48 Sigrid McCawley thtojustice.com information to assist in legal advice, with attachments n interest Withheld 2 msg
Log Privilege Doc
AC Privilege and
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105 8/6/2015 3:51 Virginia Giuffre Smccawley@BSFLLP.com potential litigation n interest Withheld 2 msg
AC Privilege and
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Product/joint
brad@pathtojustice.com,brittany@ Providing and seeking information to assist in legal advice re defense/commo
106 9/1/2015 18:54 Sigrid McCawley pathtojustice.com potential legal action, with attachment n interest Withheld 2 msg
Attorney
Client/joint
brad@pathtojustice.com,sm defense/commo
ccawley@bsfllp.com,stanpot Providing information sought by attorneys to provide legal n interest/work
107 9/7/2015 18:24 Virginia Giuffre tinger@aol.com advice, with attachment product Withheld 1 msg
AC Privilege and
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Product/joint
Attached Information sought by attorneys to provide legal defense/commo
108 advice n interest Withheld 4 docx
Attorney
Client/joint
brad@pathtojustice.com,I Email chain with Giuffre, Edwards, Pottinger and McCawley re defense/commo
,stan collection of information to assist in providing legal advice re n interest/work
109 9/7/2015 18:58 Sigrid McCawley pottinger@aol.com potential litigation product Withheld 1 msg
Attorney
Client/joint
defense/commo
Email chain with Giuffre and McCawley re draft legal document n interest/work
110 9/15/2015 21:58 Virginia Giuffre Smccawley@BSFLLP.com relating to litigation product Withheld 1 msg
Log Privilege Doc
Attorney
Client/joint
defense/commo
111 9/15/2015 22:04 Sigrid McCawley relating to litigation product Withheld 2 msg
Attorney
Client/joint
defense/commo
112 9/15/2015 22:07 Virginia Giuffre Smccawley@BSFLLP.com relating to litigation product Withheld 2 msg
Attorney
Client/joint
defense/commo
n interest/work
113 9/20/2015 12:15 Sigrid McCawley brad@pathtojustice.com Conveying information about potential legal action. product Withheld 1 msg
Attorney
Client/joint
defense/commo
n interest/work
114 9/20/2015 14:47 Virginia Giuffre Smccawley@BSFLLP.com Email chain with Giuffre and McCawley re potential legal action. product Withheld 1 msg
Attorney
Client/joint
defense/commo
n interest/work
Attorney
Client/joint
defense/commo
n interest/work
116 9/20/2015 19:29 Sigrid McCawley Email chain with Giuffre and McCawley re potential legal action. product Withheld 2 msg
Log Privilege Doc
Attorney
Client/joint
defense/commo
n interest/work
AC Privilege and
Work
Product/joint
defense/commo
118 9/21/2015 14:48 Sigrid McCawley Communication re initiation of lawsuit, with attachments n interest Withheld 1 msg
AC Privilege and
Work
Product/joint
defense/commo
119 Attached draft legal document relating to litigation n interest Withheld 12 pdf
Attorney
Client/joint
defense/commo
n interest/work
120 Attached draft legal document relating to litigation product Withheld 2 pdf
Attorney
Client/joint
defense/commo
n interest/work
Attorney
Client/joint
defense/commo
n interest/work
Log Privilege Doc
Attorney
Client/joint
defense/commo
n interest/work
Plaintiff has objected that Defendant’s requests are overly

broad and unduly burdensome, as individually logging all
privileged responsive documents would be overly burdensome.
Plaintiff contends that requests targeting such privileged
information are not reasonably calculated to lead to the
discovery of admissible evidence, are not important to resolving
the issues, are not relevant to any party’s claim or defense, are
not proportional to the needs of the case, and creates a heavy
burden on Plaintiff that outweighs its benefit. Therefore,
Plaintiff has employed categorical logging pursuant to Local Civil
Rule 26.2(c). Correspondence re: Jane Doe #1 and Jane Doe #2
Virginia Giuffre, Brad
v. United States ("CVRA case"), Case no. 08-80736-CIV-Marra,
Edwards, Paul Cassell,
pending in the Southern District of Florida. Documents withheld
Brittany Henderson (and Virginia Giuffre, Brad
pursuant to the privileges asserted included communications
other , Sigrid McCawley, Edwards, Paul Cassell,
from Ms. Giuffre to the attorneys listed seeking legal advice
Meredith Schultz, David Brittany Henderson, Sigrid
related to the CVRA case, communications from the attorneys
Boies, Jack Scarola, Stan McCawley, Meredith
to Ms. Giuffre giving legal advice or giving attorney mental
Pottinger, Ellen Schultz, David Boies, Jack
impressions related to the CVRA case, communications sending
Brockman, Legal Scarola, Stan Pottinger, Ellen
or attaching attorney work product related to the CVRA case,
Assistants, Professionals Brockman, Legal Assistants, AC Privilege and Approx. 1.3K
and/or communications sending or attaching client revisions to
retained by attorneys to Professionals retained by Work docs
attorney work product related to the CVRA case, and
Emails, letters, and aid in the rendition of attorneys to aid in the Product/joint overlapping
communications re evidence.
other communications legal advice and rendition of legal advice and defense/commo with other
125 from 2011 - Present representation representation n interest Withheld cases
Log Privilege Doc

Virginia Giuffre, Brad Rule 26.2(c). Correspondence re: Giuffre v. Maxwell (“Maxwell
Edwards, Paul Cassell, case”), 15-cv-07433-RWS, pending in the Southern District of
Brittany Henderson, Virginia Giuffre, Brad New York, since the date of filing, September 21, 2015.
Sigrid McCawley, Edwards, Paul Cassell, Documents withheld pursuant to the privileges asserted
Meredith Schultz, David Brittany Henderson, Sigrid included communications from Ms. Giuffre to the attorneys
Boies, Stephen Zach, McCawley, Meredith listed seeking legal advice related to the Maxwell case,
Stan Pottinger, Ellen Schultz, David Boies, communications from the attorneys to Ms. Giuffre giving legal
Brockman, Legal Stephen Zach, Stan advice or giving attorney mental impressions related to the
Assistants, Professionals Pottinger, Ellen Brockman, Maxwell case, communications sending or attaching attorney AC Privilege and Approx. 1.3K
retained by attorneys to Legal Assistants, work product related to the Maxwell case, and/or Work docs
Emails, letters, and aid in the rendition of Professionals retained by communications sending or attaching client revisions to Product/joint overlapping
other communications legal advice and attorneys to aid in the attorney work product related to the Maxwell case, and defense/commo with other
126 from 9/21/15 - Present representation rendition of legal advice and communications re evidence. n interest Withheld cases
Log Privilege Doc

Virginia Giuffre, Brad Rule 26.2(c). Correspondence re: Bradley Edwards and Paul
Edwards, Paul Cassell, Cassell v.
Brittany Henderson, Virginia Giuffre, Brad pending in the Seventeenth Judicial Circuit, Broward
Sigrid McCawley, Edwards, Paul Cassell, County, Florida. Documents withheld pursuant to the privileges
Meredith Schultz, David
Boies, Stephen Zach,
Stan Pottinger, Ellen
Brockman, Legal
Brittany Henderson, Sigrid
McCawley, Meredith
Schultz, David Boies,
Stephen Zach, Stan
-
asserted included communications from Ms. Giuffre to the
attorneys listed seeking legal advice related to the
case, communications from the attorneys to Ms. Giuffre giving
legal advice or giving attorney mental impressions related to the
127
Emails, letters, and
Assistants, Professionals
retained by attorneys to
other communications aid in the rendition of
from January 2015 - legal advice and
Present representation
Pottinger, Ellen Brockman,
Legal Assistants,
Professionals retained by
attorneys to aid in the
rendition of legal advice and
work product related to the
--
case, communications sending or attaching attorney
attorney work product related to the

communications re evidence.
case, and/or
communications sending or attaching client revisions to
case, and
AC Privilege and
Work
Product/joint
defense/commo
n interest Withheld
Approx. 1.3K
docs
overlapping
with other
cases
Log Privilege Doc

Rule 26.2(c). Correspondence re: Jane Doe No. 102 v. Jeffrey
Epstein (“Epstein case”), Case No. 09-80656-CIV-Marra/Johnson
(Southern District of Florida). Documents withheld pursuant to
the privileges asserted included communications from Ms.
Virginia Giuffre, Bob Virginia Giuffre, Bob Giuffre to the attorneys listed seeking legal advice related to the
Josefsberg, Katherine W. Josefsberg, Katherine W. Epstein case, communications from the attorneys to Ms. Giuffre
Ezell, Amy Ederi, other Ezell, Amy Ederi, other giving legal advice or giving attorney mental impressions related
Podhurst attorneys, Podhurst attorneys, Legal to the Epstein case, communications sending or attaching AC Privilege and Approx. 1.3K
Legal Assistants, and Assistants, and Professionals attorney work product related to the Epstein case, and/or Work docs
Emails, letters, and Professionals retained by retained by attorneys to aid communications sending or attaching client revisions to Product/joint overlapping
other communications attorneys to aid in the in the rendition of legal attorney work product related to the Epstein case, and defense/commo with other
128 from 2009 - Present rendition of legal advice advice communications re evidence. n interest Withheld cases
Email chain with Giuffre and McCawley seeking information to
129 6/10/2015 Virginia Giuffre assist with attorney advice. Attorney Client Withheld 2 msg
Letter from Virginia Giuffre to David Boies conveying requested AC Privilege and
130 information to assist in providing legal advice. Work Product Withheld 26 pdf
Smccawley@BSFLLP.com,brad@pa
thtojustice.com, AC Privilege and
131 4/30/2015 Brittany Henderson eperez@BSFLLP.com Communication re VRS registrations Work Product Withheld 1 msg
thtojustice.com,garvin@lclark.edu, Email chain with McCawley, Edwards, Garvin, Henderson, AC Privilege and
132 4/29/2015 Andres Ortiz bh699@nova.edu Giuffre and BSF staff re legal advice re VRS communications. Work Product Withheld 1 msg
thtojustice.com,garvin@lclark.edu, AC Privilege and
133 4/29/2015 brittany henderson aortiz@BSFLLP.com Communication re legal advice re VRS communications. Work Product Withheld 1 msg
Log Privilege Doc
Smccawley@BSFLLP.com,brittany Email chain with Cassell, McCawley, Edwards, Garvin, Beloof,

@pathtojustice.com,eperez@BSFLL Henderson, Giuffre and BSF staff re legal advice re VRS AC Privilege and
134 4/17/2015 Paul Cassell brad@pathtojustice.com P.com registrations. Work Product Withheld 5 msg
brittany@pathtojustice.com,eperez Email chain with Cassell, McCawley, Edwards, Garvin, Beloof,
brad@pathtojustice.com,cas @BSFLLP.com, Henderson, Giuffre and BSF staff re legal advice re VRS AC Privilege and
135 4/17/2015 Sigrid McCawley sellp@law.utah.edu registrations. Work Product Withheld 4 msg
Smccawley@BSFLLP.com,brittany Email chain with Cassell, McCawley, Edwards, Garvin, Beloof,

@pathtojustice.com,eperez@BSFLL Henderson, Giuffre and BSF staff re legal advice re VRS AC Privilege and
136 4/17/2015 Brad Edwards cassellp@law.utah.edu P.com registrations. Work Product Withheld 4 msg
137 2/26/2015 Sigrid McCawley Email chain with Giuffre and McCawley re non-testifying expert. Attorney Client Withheld 1 msg
138 2/26/2015 Sigrid McCawley Communication re non-testifying expert. Attorney Client Withheld 1 msg
Email chain with Giuffre, McCawley, Edwards, Pottinger and BSF
139 2/11/2016 Sigrid McCawley staff re media communications. Attorney Client Redacted 3 msg
StanPottinger@aol.com Lcarlsen@BSFLLP.com,brad@patht Email chain with Giuffre, McCawley, Edwards, Pottinger and BSF
140 2/11/2016 Sigrid McCawley ojustice.com staff re media communications. Attorney Client Redacted 3 msg
Lcarlsen@BSFLLP.com,Smccawley
@BSFLLP.com,brad@pathtojustice. Email chain with Giuffre, McCawley, Edwards, Pottinger and BSF
141 2/11/2016 StanPottinger@aol.com com staff re media communications. Attorney Client Redacted 3 msg
Email chain with Giuffre and Pottinger re media
142 2/9/2016 StanPottinger@aol.com communications. Attorney Client Redacted 2 msg
143 information to assist in providing legal advice. Work Product Withheld 26 pdf
144 information to assist in providing legal advice. Work Product Withheld 23 docx
145 6/10/2015 Virginia Giuffre Email chain with Giuffre and McCawley re ongoing litigation. Attorney Client Withheld 2 msg
Smccawley@BSFLLP.com,bh699@n
ova.edu,brad@pathtojustice.com,g Email chain with Henderson, McCawey, Edwards, Garvin and
146
147
148
4/29/2015
4/10/2015
2/26/2015
Virginia Giuffre
Virginia Giuffre
Virginia Giuffre
aortiz@BSFLLP.com
Smccawley@BSFLLP.com
arvin@lclark.edu
Email chain with
-
BSF staff re VRS communications.
Giuffre, McCawley, and BSF staff re
legal advice re VRS registrations.
Email confirming legal advice re non-testifying expert.
Attorney Client
Attorney Client
Attorney Client
Withheld
Withheld
Withheld
2
2
1
msg
msg
msg
Log Privilege Doc
Email chain with Giuffre and Pottinger re media
149 2/11/2015 Virginia Giuffre StanPottinger@aol.com communications Attorney Client Redacted 3 msg
Email chain with Giuffre, McCawley, Pottinger and BSF staff re
150 2/11/2015 Virginia Giuffre Smccawley@BSFLLP.com media communications. Attorney Client Redacted 3 msg
AC Privilege and
151 1/13/2015 Virginia Giuffre StanPottinger@aol.com Email chain with Pottinger and Giuffre re anticipated litigation. Work Product Withheld 1 msg

privileged responsive documents would be overly
burdensome. Plaintiff contends that requests targeting
such privileged information are not reasonably calculated
to lead to the discovery of admissible evidence, are not
important to resolving the issues, are not relevant to any
party’s claim or defense, are not proportional to the
needs of the case, and creates a heavy burden on Plaintiff
that outweighs its benefit. Therefore, Plaintiff has
employed categorical logging pursuant to Local Civil Rule
26.2(c). This categorical entry is regarding correspondence
re potential legal action against entities and individuals.
Virginia Giuffre, Brad Documents withheld pursuant to the privileges asserted
Edwards, Paul Cassell, Virginia Giuffre, Brad included communications from Ms. Giuffre to the
Brittany Henderson, Edwards, Paul Cassell, attorneys listed seeking legal advice related to potential
Sigrid McCawley, Brittany Henderson, Sigrid law suits, communications from the attorneys to Ms.
Meredith Schultz, David McCawley, Meredith
Giuffre giving legal advice or giving attorney mental
Boies, Stephen Zach, Schultz, David Boies,
impressions related to the law suits, communications
Stan Pottinger, Ellen Stephen Zach, Stan
Brockman, Legal Pottinger, Ellen Brockman, sending or attaching attorney work product related to AC Privilege and
Emails, letters, and Assistants, Professionals Legal Assistants, potential lawsuits, and/or communications sending or Work Approx. 1.3K
other communications retained by attorneys to Professionals retained by attaching client revisions to attorney work product related Product/joint overlapping
from January 2015 - aid in the rendition of attorneys to aid in the to potential lawsuits, and communications re evidence. defense/commo with other
152 Present legal advice rendition of legal advice n interest Withheld cases
Log Privilege Doc

privileged responsive documents would be overly
burdensome. Plaintiff contends that requests targeting
such privileged information are not reasonably calculated
to lead to the discovery of admissible evidence, are not
important to resolving the issues, are not relevant to any
party’s claim or defense, are not proportional to the
needs of the case, and creates a heavy burden on Plaintiff
The law enforcement that outweighs its benefit. Therefore, Plaintiff has
entity, Virginia Giuffre, The law enforcement entity, employed categorical logging pursuant to Local Civil Rule
David Boies, Stan Virginia Giuffre, David Boies, 26.2(c). This categorical entry is regarding correspondence
Pottinger, Sigrid Stan Pottinger, Sigrid
re the currently ongoing criminal investigation of
Email and letter McCawley, Paul Cassell, McCawley, Paul Cassell, Brad approx. 57
Defendant and others.
153 communications Brad Edwards Edwards Public Interest Withheld documents
Email chain discussing efforts to obtain assistance from FBI AC Privilege and
154 8/27/2014 Virginia Giuffre Brad Edwards agent in obtaining information to assist in providing legal advice. Work Product Withheld 1 msg
EXHIBIT M
Confident ial/Sealed Tran script Pursuant to Comt Order
May 3, 2016 Videotaped Deposition of Virginia Giuffr e
-AME NDMENT /ERRATA SHEET-
May 3 1, 2016
Agren Blando Comt Rep o1t ing & Video, Inc.

Pro duction Depaitment
2 16 16th Street, Suite 600
Attn: Lam-en Cheney
Re: Giuffre v. Maxwell, Case No . 15-cv-07433-RW S
The deponent wishes to mak e the following changes in the testimony as originally given:
Change Reason for Change

A : I would say it was approximately mid-Febrnaiy
28: 16 28 :16 Clarific ation of answer
2016.
28:25 28 :25 A :No . Clai·ification of answer
29:4 29:4 A :No . Clai·ification of answer
A : N o. I became awai·e approximatel y mid-Febrna1y
29: 14 29:14 Clarifi cation of answer
2016.
A : I believe I found out approximatel y mid-Febrna1y of
this ear .
A : To the best of my recollection, it was approximately
64 : 14 64: 15 Clarifi cation of answer
mid-Fe brnai of this ear.
A : I don 't know exactly when. It was approximately
mid-Fe brnaiy 2016. I ju st know that I've learned about
it recently. I'm not too sme exact ly what date I did
learn about it.
9 1:4 91 :4 Name miss elled
96:2 1 A : It was approximatel y mid-Febrna1y 2016 . I can 't tell
96:2 1 Clarifi cation of answer
ou the date that I actuall saw them .
A : I don't remember where I saw these records or when
I saw these records. I know it was n't a ye ai· ago. I
know it was more recent. I can 't pinp oint the date that I
97: 18 97 :24 actually saw them, but I believe it was approximate ly Clarifi cation of answer
mid- Febmaiy of this yeai·. I don't want to sit here and
speculate and then give you the wrong answer. It's j ust
new knowled e for me.
A : I think the title was put in my name. My dad was
120 :16 120:18 with me. I've never registered a car or anything like Clarifi cation of answer
that before. So it 's possible the title was in his name .
----+-----◄-
139:9 139:9
--- ---1-
------------1
Name miss elled
Clai·ification of answer
155:4 155:4 A : No . Clai·ificat ion of answer
157: 1 157: 1 A: I think I've been to France a few times. Clai·ification of answer
157: 13 157: 13 A: I believe I've been to France a few times. Clai·ification of answer
Confid~u!ll/Seafoo'rr~scnpt Pwsuttnt co Coult Order

May t 2016 V,d;;ot.1pcdOept,~lmn of Varr,imu(i11sffrc
-AMt:NUM£NT/ERRATA SHEl!.7-'
~
17'>.12 17
~)•,) , h ;01>h "-"he·s :a1:-~·rh ,1loP:a
s1
HJ.13
•H I t !PS\<:hol09jst_, c:dl.
311. 16 31 I : ll1 Omia"I'm sure she i.s.."'
S,gn~twc c,( Ilc1mncnt.

-
EXHIBIT N

Southern District Of New York
--------------------------------------------------X
..........................................
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
DEFENDANT GHISLAINE MAXWELL’S

THIRD SUPPLEMENTAL F.R.C.P. 26(A)(1)(A) DISCLOSURES
Pursuant to F.R.C.P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE

INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq.
Haddon, Morgan & Foreman, P.C.
150 E. 10th Ave.
Denver, CO 80203
303-831-7364
LMenninger@HMFLaw.com
Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre

c/o Sigrid S. McCawley, Esq.
401 East Las Olas Boulevard, Suite 1200
Miami , Florida 3330 1

(954) 356 -0011
smccaw ley@bsfllp .com
Ms . Giuffre is the Plaintiff and has kn owledge concern ing the matt ers at issue in
her Compl aint , includin g the events of 1996-2015 and the publica tion of
statements in the press in 20 11-2015.
3.
Addre ss unkn own at this time
Telephone numb er unkn own at thi s time
- has kn owledge about matters at issue, includin g Plaintiff' s

~urin g 2000 -2002 and her false claims conce rnin g Defendant and
oth ers.
4.
has knowledge about m atters at issue , includin g Pl aintiffs

wher eabo uts durin g 2000 -2002 and her false claims concernin g Defendant and
others.
5.
has kn owledge concernin g m atters at issue in the Complain t,

includin g events of 1996-2002.
6.
- has kn owledge concernin g press state ments by Plaintiff and

Defendant in 2011 -20 15 at issue in this m atter.
7.
2
- has knowledge concerning matters at issue in the Complaint,

including her own whereabouts and activities during the period 2000-2002.
8. David Boies
Boies, Schiller, Flexner LLP
575 Lexington Ave.
New York, NY 10022
(212) 446-2300
Mr. Boies has knowledge concerning matters at issue in the Complaint and in
particular her publicly filed allegations concerning Defendant and
9. Laura Boothe
The Mar-a-Lago Club, LC.
-
Plaintiff’s pleadings and sworn statements in other litigations, including in
-
1100 South Ocean Boulevard,
Palm Beach, FL 33480
-
Ms. Boothe has knowledge concerning matters at issue, including the date that
began working at the Mar-a-Lago Club, and the human resources
department at Mar-A-Lago.
10. Evelyn Boulet

Address unknown at this time
Telephone number unknown at this time
Ms. Boulet may have knowledge concerning Plaintiff’s false claims against
Defendant.
11.
12.
- has knowledge concerning Plaintiff during the relevant time period
including claims for damages, motive and bias.
has knowledge concerning Plaintiff’s credibility, including false

claims of sexual assault.
13.
3
- may have knowledge concern ing Plaintiff s false claims against

Defendant.
14. Paul Cassell

383 South University Street
801-585-5202
paul.cassell@law.utah. edu
Mr. Cassell has knowledge concerning pres s statements by Plaintiff , Plaintiff' s

comt pleadings, and Plaintiffs sworn testimony.
15. Sharon Church er

3 Deveau Road
N . Salem, NY 10560
Ms. Churcher has knowledge concern ing matters at issue, including Plaintiff s
statements regarding Defendant and others.
16. Alexan dra Cousteau

Ms. Cousteau may have knowledge concernin g Plaintiffs false claims against
17.
has knowledge concern ing Plaintiffs false statements to the

press, in court pleadings, and in sworn testimony , at issue in this matter.
18.
has knowledge about matters at issue, including Plaintiff' s

whereabouts during 2001 and her claimed damages .
4
19.
Address unkn own at this time
Telephone numb er unkn own at this time
- may have knowledge concerning Plaintiff's false claim s against

Defendant.
20. Bradle y Edwards

Faimer , Jaffe , Weissing , Edwai·ds, Fistos & Lehrman , P.L.
425 N . Andrews Ave., Suite 2
Ft. Lauderdale , FL 33301
(954) 524-2820
brad@pathtoju stice .com
Mr. Edwai·ds has knowledge concerning Plaintiffs false statements to the press,
in court pleadings , and in sworn testimony at issue in this matter. Mr. Edwai·ds
also has knowledge concerning "Vict im 's Refuse Silence, Inc."
21. Amanda Ellison

561-628-4338
Ms . Ellison has knowledge concerning Plaintiff' s false allegations concerning

Defendant.
22.
has knowledge concerning Plaintiff's false allegations concerning

Defendant.
23. Jeffrey Epstein

c/o Tonja Haddad Coleman, Esq .
315 SE 7th Sti·eet, Suite 301
Fo1t Lauderdale , FL 33301
(954) 467-1223
Mr. Epstein has knowledge concerning Plaintiff's false statements to the pre ss and
in court pleadings , as well as the events of 1999-2002 concerning Plaintiff and
Defendant.
·ess l own at this time

5
- may have kn owledge concernin g Plaintiff' s false claims against

Defendant.
25.
I!!!'- may have kn owledge concernin g Plaintiff' s false claims against
26.
Teleph one numb er unkn own at thi s time
- m ay have kn owledge concernin g Pl aintiff' s false claims against

ma y have kn owledge concernin g matters at issue, inclu ding

Plaintif f's activities dming 1996 - 2002
28.
- has kn owledge concerning matters at issue, inclu ding Plaintif f's

~in g 1996 - 2002 .
29.
- m ay have kn owledge concernin g trnve l of -
30. -
~mkn own at this time
Telephone numb er lmknown at thi s time
- may have kn ow ledge concernin g Plaintiff whereabouts dming 2000-

2002 and her false claim s against Defendant.
31. Meg Garvin

Lewis & Clark Law School
6
10015 S.W . Te1williger Boulevard MSC 51

Po1tland, Oregon 97219
Ms. Garvin has knowledge conce rnin g matter s at issue includ ing Victims Refuse
Silence and Plaintiff s damage s.
32. Sheridan Gib son-Butt e

Telephone number unkn own at thi s time
Ms. Gibson-Butte may have kn owledge concernin g Plaintiff's false claims
against Defendant.
33.
- is may have knowledge concernin g matters at issue, including

Plaintiff' s activit ies dming 2002 -2016 and her damages allegations .
34.
- may have kn owledge concernin g matters at issue, inclu ding the

pub lication of statements in the pre ss in 2011 -2015 concern ing Plain tiff and
Defendant.
35. Fred Graff

Add ress unkn own at this time
Mr. Graff may have knowledge concern ing Plaint iff' s false claims again st
Defendant.
36.
may have knowledge concern ing matters at issue, includin g

Plaintiff' s activit ies dming 1996 - 2002.
37.
7
- may have kn owledge concerning matters at issue .
38 .
Teleph one number unkn own at this time
m ay have kn owledge concernin g Plaintiff' s false claims against

Defendant.
39.
- m ay have knowledge concernin g Plaintif f's false claim s against

Defendant.
40. Brittan y Hender son

Faimer , Jaffe , Weissing , Edw ards, Fistos & Lehrman , P .L.
425 N . Andrew s Ave. , Suite 2
Ft. Lauder dale, FL 33301
Ms. Hender son has kn owledge concerning m atters at issue includin g Victims
Refu se Silence and Plaintiff' s dainages.
41. Brett Jaffe

Mr. Jaffe has kn owled ge concernin g Plaintiff' s false claim s concerning Ms .

Maxwe ll includin g her compliance with any deposition subpoena in the CVRA
matt er .
42.
- may have kn ow ledge concerning m atters at issue , includin g Plaintiff' s

activities dming 1996 - 2002 .
43. Dr. Kai·en Kutik off

12957 Palms W Drive #101
8
Loxaha tchee, FL 33470
Dr. Kutifkoff may have knowledge concerning matters at issue, including

Plaintiff s whereabouts during 1998-2002 and Plaintiff's damages.
44.
may have knowledge concerning Plaintiff' s false claim s against

Defendant.
45. Tony Lyons

Skyhorse Publishing, fuc.
307 West 36th Street, 11th Floor
New York, NY 10018
Mr. Lyons may have knowledge concerning matters at issue, including Plaintiff' s
false allegatio ns concerning Defendant and others.
46.
- may have knowledge concerning Plaintiff's false claims against

Defendant.
47.
h as kn owledge concerning Plaintiff's hone sty and huthfulness.
48.
- may have knowledge concerning matters at issue, includin g Plaintiff' s

activities during 1996 - 2002 .
49.
Telephone number unkn own at this time
9
50.
- may have knowledge concerning Plaintiff’s false claims against

-
Defendant.
51. David Mullen

may have knowledge concerning Plaintiff’s false claims against

Mr. Mullen may have knowledge concerning Plaintiff’s false claims against
Defendant.
52. Joe Pagano

Mr. Pagano may have knowledge concerning Plaintiff’s false claims against
Defendant.
53. Mary Paluga

Ms. Paluga may have knowledge concerning Plaintiff’s false claims against
Defendant.
54. J. Stanley Pottinger

49 Twin Lakes Rd.
South Salem, NY 10590
914-763-8333
Mr. Pottinger may have knowledge concerning matters at issue, including

Plaintiff’s attempts to sell her story to the media and her contacts with the media.
55. Joseph Recarey

2753 Misty Oaks Circle
Royal Palm Beach, FL 33441
Mr. Recarey may have knowledge concerning Plaintiff’s false claims against
Defendant.
10
56. Michael Reiter

2335 So. Ocean Blvd ., Apt. 15
Mr. Reiter may have knowledge concernin g Plaintiff's false claims against
Defendant.
57. Jason Richar ds

Federal Bureau of Investigations
Mr. Richards has knowledge conc~i ssue, inclu ding Plaintiff's

stateme nts conce rning Defendant , _ and other individuals.
58.
may have knowledge concernin g Plaintiff's false claims against

59.
- may have knowledge concerning matters at issue, inclu ding

Plaintiff's activities during 1996 - 2002.
60.
has knowledge concernin g Plaintiff' s civil claims against Jeffrey
61. Forest Sawyer

Mr. Sawyer may have knowledge concerning Plaintif f's false claims against
Defendant.
62. Doug Schoetlle

11
Mr. Schoettle may have knowledge concerning Plaintiff’s false claims against
Defendant.
63.
- may have knowledge concerning Plaintiff’s false claims against

Defendant.
64. Mark Tafoya

Mr. Tafoya may have knowledge concerning Plaintiff’s false claims against
Defendant.
65. Brent Tindall

66.
has knowledge concerning Plaintiff’s credibility, including false

claims of sexual assault.
67. Ed Tuttle
Mr. Tuttle may have knowledge concerning Plaintiff’s false claims against
Defendant.
68. Emma Vaghan

Ms. Vaghan may have knowledge concerning Plaintiff’s false claims against
Defendant.
69. Kimberly Vaughan-Edwards

Believed to be in the UK
12
Ms. Vaughan-Edwards has knowledge concerning facts relevant to this dispute

and Ms . Maxwe ll's character.
70. Cresenda Valdes

Ms. Valdes may have know ledge concerning Plaintiff's false claims against
Defendant.
71.
may have knowledge concernin g matters at issue, including

Plaintiff's activities dmin g 1996 - 2002.
72. Maritza Vazquez

Ms. Vazquez may have knowledge concerning Plaintiff's false claims against
Defendant.
73. Vicky Ward

Ms. Ward may have knowledge concernin g Plaintiff's false claims against
Defendant.
74. Ja1TedWeisfeld
Mr. Weisfeld may have knowledge concerning matters at issue, including

Plaintiff's attempted publicat ion of false allegations concernin g Defendant and
others.
75.
- may have knowledge concerning Plaintiff's false claims against

Defendant.
76.
13
77.
- may have knowledge concerning matters at issue, including Plaintiff’s
activities during 1996 – 2002.

- has knowledge concerning Plaintiff’s false statements to the press, in

court pleadings, and in sworn testimony as well as the events of 1999-2002.
78. Witnessed identified by Plaintiff in any of the various versions of her Rule 26
disclosures.
79. Witnesses whose identities and contact information can be identified in law
enforcement reports disclosed herein.
80. Any other witness learned through the discovery process.
Defendant Ghislaine Maxwell reserves her right to supplement these disclosures as

additional witnesses are learned through the discovery process, or endorsed by
Plaintiff.
II. DOCUMENTS, DATA, COMPILATIONS AND TANGIBLE THINGS IN

POSSESSION, CUSTODY OR CONTROL OF DEFENDANT THAT MAY
BE USED TO SUPPORT DEFENDANT’S CLAIM OR DEFENSES
1. Documents received from any other party through disclosures and/or in

discovery, including any deposition exhibits, will not be identified or
produced, though they technically may fall within this category “II”, and
Defendant reserves the right to utilize such documents at any hearing or trial
on this matter.
2. News articles from the internet:
a. “Sordid friends and why he isn't fit for the job: Duke of York risks
losing ambassador role,” Daily Mail Online (Feb. 28, 2011).
b. “Prince Andrew and the 17-year-old girl his sex offender friend flew
to Britain to meet him,” Daily Mail Online (corrected Mar. 2, 2011).
c. “Unsavoury association: How Robert Maxwell's daughter 'procured

young girls' for Prince Andrew's billionaire friend,” Daily Mail Online
(Mar. 5, 2011).
14
d. “Virginia Roberts' account of the explosive Prince Andrew 'sex slave'

drama,” Daily Mail Online (Jan. 3, 2015).
e. “Court papers put daughter of Robert Maxwell at centre of ‘sex slave’

scandal,” The Guardian (Jan. 4, 2015).
f. “Prince Andrew denies sexual abuse allegations in unprecedented

Buckingham Palace statement: The Duke of York denies having
relations with alleged ‘sex slave,’” The Independent (Jan. 4, 2015).
g. “Prince Andrew story runs and runs - but editors should beware,” The
Guardian (Jan. 5, 2015).
h. “US lawyer sues in Prince Andrew sex claims case,” Time (Jan 6,
2015).
i. “Harvard professor Alan Dershowitz denies charges of sex with

underage girl,” Boston Globe (Jan. 22, 2015).
j. “Virginia Roberts’s Aunt Reveals Jeffrey Epstein Girl Says I Am In

Fear for My Life,” Daily Mail Online, (Jan. 10, 2015).
k. “EXCLUSIVE: Alleged ‘sex slave’ of Jeffrey Epstein, Prince Andrew

accused two men of rape in 1998, but was found not credible,” NY
Daily News (Feb. 23, 2015).
l. “Jeffrey Epstein accuser was not a sex slave, but a money-hungry sex
kitten, her former friends say,” NY Daily News (Mar. 1, 2015).
m. “Twat Claims She Was Underage Sex Slave Bedding Prince Andrew,”
http://www.mgtowhq.com/viewtopic.php?f=2&t=6676 (Jan. 5, 2015).
n. “Exclusive: Prince Andrew at Heidi Klum’s ‘Hookers and Pimps’

party with the New York socialite accused of procuring underage girls
for his billionaire pedophile friend” Daily Mail Online (May 10,
2016).
3. Email from
- to various news organizations, Subject: “Ghislaine
Maxwell,” (Jan. 2, 2015).
4. “Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges

Against Professor Dershowitz,” Joint Statement of Brad Edwards, Paul
Cassell and Alan Dershowitz (Apr. 8, 2016).
5. Edwards and Cassell v. Dershowitz, In the Circuit Court of the Seventeenth

Judicial District In and For Broward County Florida to include:
15
a. Deposition testimony of Paul G. Cassell, dated October 16, 2015 and

October 17, 2015.
6. Jane Doe #1 and #2 v. United States, U.S. District Court for the Southern
District of Florida, 08-cv-80736-KAM pleadings to include:
a. Motion for Limited Appearance, Consent to Designation and Request

to Electronically Receive Notices of Electronic Filing (July 28, 2008)
(Doc. # 16)
b. Notice of Change of Address and Firm Affiliation (Apr. 9, 2009) (Doc.

# 37)
c. Order Denying Petitioners’ Motion to Join Under Rule 21 and Motion

to Amend Under Rule 15 (Apr. 7, 2015) (Doc. #324)
d. Order Scheduling Settlement Conference Before the Magistrate Judge,

U.S. District Court (Mar. 31, 2016) (Doc. #378)
7. Epstein v. Scott Rothstein and Bradley J. Edwards, In the Circuit Court of the
Fifteenth Judicial Circuit in and for Palm Beach County, Florida, 09-ca-
040800, pleadings to include:
a. Complaint (Dec. 7, 2009).
8. Law enforcement records obtained from the Palm Beach County (Florida)
Sheriff’s Office, the Royal Palm Beach (Florida) Police Department, the
County Court in and for Palm Beach County (Florida), the Greenacres
(Florida) Department of Public Safety, and the Fremont County (Colorado)
Sheriff’s Office.
9. Employment records obtained from ET Employment Training and Recruiting

Australia.
10. Education records obtained from Royal Palm Beach Community High School
and Forest Hills High School.
11. Documents received from Palm Beach County Library System.
12. Documents received from any other party through disclosures and/or in
discovery, including any deposition exhibits, will not be identified or
produced, though they technically may fall within this category “II”, and
Defendant reserves the right to utilize such documents at any hearing or trial
on this matter.
16
Defendant reserves the right to identify additional documents, data, compilations

and tangible things as discovery continues and to supplement this list accordingly.
III. DESCRIPTION OF CATEGORIES OF DAMAGES SOUGHT AND

COMPUTATION OF ECONOMIC DAMAGES CLAIMED BY THE
DISCLOSING PARTY
Not applicable at this time Ms. Maxwell reserves her right to supplement these
disclosures as necessary.
IV. INSURANCE AGREEMENT UNDER WHICH ANY PERSON CARRYING

ON AN INSURANCE BUSINESS MAY BE LIABLE TO SATISFY A PART
OR ALL OF A JUDGMENT
Ms. Maxwell’s AIG Homeowners and Excess Liability insurance policies.

Coverage has been denied by AIG, as their letter of April 18, 2016 to Ms.
Maxwell, copied to Ms. McCawley, attests.

s/ Laura A. Menninger
Laura A. Menninger
Jeffrey S. Pagliuca
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
17
I certify that on June 17, 2016, I electronically served this DEFENDANT GHISLAINE
MAXWELL’S THIRD SUPPLEMENTAL F.R.C.P. 26(A)(1) DISCLOSURES via e-mail on the
following:

Meredith Schultz 383 S. University Street
mschultz@bsfllp.com
s/
18

v.
Ghislaine Maxwell,
Defendant.
______________________________/
DECLARATION OF SIGRID S. MCCAWLEY REPLY IN SUPPORT OF MOTION TO

EXTEND THE DEADLINE TO COMPLETE DEPOSITIONS AND OPPOSITION TO
MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45
1. I am a Partner with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my
Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in response to Defendant’s Opposition to
Motion to Extend Deadline to Complete Depositions and Motion for Sanctions for Violation of
Rule 45.
3. Attached hereto as Exhibit 1, is a true and correct copy of Sigrid McCawley’s
March 7, 2016 Correspondence to Martin G. Weinberg, Esquire.
4. Attached hereto as Exhibit 2, is a true and correct copy of Sigrid McCawley’s May
25, 2016 Correspondence to Martin G. Weinberg.
23, 2016 Correspondence to Martin G. Weinberg.
17, 2016 Correspondence to Opposing Counsel.
7. Attached hereto as Exhibit 5, is a true and correct copy of Gregory Poe’s June 16,
2016 correspondence to Bradley Edwards.
8. Attached hereto Exhibit 6, is a true and correct copy of Sigrid McCawley’s March
31, 2016 Correspondence to Bruce Reinhart.
9. Attached hereto Exhibit 7, is a true and correct copy of Douglas G. Mercer’s
Affidavit of Service dated May 24, 2016.
10. Attached hereto as Exhibit 8, is a true and correct copy of Jack Goldberg’s May
23, 2016 Correspondence to Sigrid McCawley.
11. Attached hereto Exhibit 9, is a true and correct copy of Sigrid McCawley’s June
21, 2016 Correspondence to Bruce Reinhart.
12. Attached hereto Exhibit 10, is a true and correct copy of Plaintiff’s Notice of
Taking Videotaped Deposition of Jean Luc Brunel.
13. Attached hereto Composite Exhibit 11, is a true and correct copy of Brad Edwards
June 14, 2016 Correspondence to Ross Gow.
14. Attached hereto Exhibit 12, is a true and correct copy of transcript of May24, 2016
Phone Conference with Plaintiff’s Attorney, Defendant’s Attorney and Judge Robert Sweet.
-
15. Attached hereto Exhibit 13, is a true and correct copy of Defendant’s Rule 26
-
Disclosures.
16. Attached hereto Composite Exhibit 14, is a true and correct copy of Meredith
Schultz Correspondence to Opposing Counsel.
17. Attached hereto Exhibit 15, is a true and correct copy of Meredith Schultz
Correspondence to Opposing Counsel.
18. Attached hereto Exhibit 16, is a true and correct copy of Meredith Schultz June
13, 2016 Correspondence to Defendant’s Counsel.
/s/ Sigrid McCawley

Sigrid McCawley
Dated: June 22, 2016

Tel: (954) 356-0011
David Boies
333 Main Street
Armonk, NY 10504

Ronald N. Boyce Presidential Professor of
Criminal Law
University of Utah
383 S. University St.
Salt Lake City, UT 84112-0730
(801) 585-5202 (phone)
(801) 585-2750 (fax)
Email: cassellp@law.utah.edu
Bradley Edwards (Pro Hac Vice)

Farmer, Jaffe, Weissing, Edwards,
Fistos & Lehrman, P.L.
Tel: (954) 524-2820
Fax: (954) 524-2822
Email: brad@pathtojustice.com
I HEREBY CERTIFY that on June 22, 2016, I electronically filed the foregoing
document is being served to all parties of record via transmission of the Electronic Court Filing
System generated by CM/ECF.

Tel: (303) 831-7364
Fax: (303) 832-2628

EXHIBIT4
(Filed Under Seal)

Sigrid Mccawley
From: Sigrid Mccawley

Sent: Tuesday, May 17, 2016 3:53 PM
To: Laura Menninger; Meredith Schultz; Jeff Pagliuca
Cc: 'b rad@pathtojust ice.com' (brad@pathtojustice.com); Paul Cassell
(cassellp@law.utah.edu)
Subject: RE: Notice of Subpoena
Attachm ents: May-June 2016 Deposition Calendar.pdf
Hello laura - We are working on the calendar and I have it almost complete but I was awaiting confirmatio n on a date
from Mr. - counsel so I did n't want to send it out prematurely and that was delaying me.
We were serving subpoenas on dates that we thought are grouped within t he locat ions/date ranges we discussed during
the mee t and confer and since we have been having an extraordinarily difficult time serving witnesses who appear to be
attempting to evade service we need to keep that process moving .
We do intend to work with you on dates as we discussed. Attached is the proposed calendar wit h the caveat that dat es
may shift if witnesses make change requests but we are doing our best to group locations together where possible.
Again - th is is not final as I not ed I believe yo u had some dates you were gone but were checking with Jeff to det ermine
his availabi lity.
Finally, we are writing to confer whether you w ill stipulate that we may exceed the 10 deposition li mit to complete
discovery in this case or whether we need to file a motion with t he Court on that issue.
Thank you,
Sigrid
Sigrid S. McCawley
Partner
SOIES, SClllLbER & FL EXNER bl ,
40 I East Las Olas Blvd., Suite 1200
Fort Lauderdale, FL 3330 1
Phone: 954-356-0011 ext. 4223
Fax: 954-356-0022
http://www.bsfll p.com
From: Laura Menninger [mailto:lmenninge r@hmflaw.com]

Sent: Tuesday, May 17, 2016 3:19 PM
To: Meredith Schultz; Jeff Pagliuca
Cc: Sigrid Mccawley; 'brad@pat htojust ice.com' (~); Paul cassell (cassellp@law.utah.edu)
Subject: Re: Notice of Subpoena
Sigrid and Brad -
We had a conferral last week in which you promised to provide for conferral purposes a proposed schedule for deposit ions we
both had requested in various locations. Rather t han provide any such schedule, you have instead sent us notices for
approximately 7 deposit ions in NY and Flor ida, one for an individual who you did not mention deposing and who does not
appear among the extensive list of witnesses in your Rule 26 disclosures.
If you do not intend to abide by the representations you made in our confer ral, then please advise and we will once again be
forced to seek inte rvent ion of the Court . See Local Rule 26.4.
-Laura
From : Meredith Schultz <mschultz@BSFLLP.com>

Date: Tuesday, May 17, 2016 at 1:08 PM
To: Laura Menninger <lmen ninger@hmflaw .com>, Jeff Pagliuca <jpagliuca@hmflaw.com>
Cc:Sigrid Mccaw ley <smccawley@bsfllp .com>, Brad Edwards <brad@pathtoiustice.com>, Paul Cassell
<cassellp@law.utah.edu>
Subject: Not ice of Subpoena
Laura,
Please see th e attac hed documents.
Thanks,
Mered it h
Meredith L. Schultz
BOlE S. SCillLLER & FLEXNE R LLP
401 East Las Ola s Blvd., Su ite 1200
Fort Lauderdale , FL 33301
Phone: 954-356-0011 ext. 4204
Fax: 954-356-0022
http://\vww.bsfllp.com
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2
Virginia Giuffre v. Ghislaine Maxwell
Case no . l 5-cv-07433-RWS
MAY 2016

Sunday Monda Tuesda Wednesda Thursda Frida, Saturda
2 3 4 5 6 7
8 9 11 12 13 14
15 16 17 18 19 20 21
Deposition of -
oll' L
(confirmed)
..
22 23 24 25 26 27 28
Deposition of Deposition of Dr.
Steven Olson
Denver , CO
(confirmed ( confirmed)
although location
may change per
Mennin er
29 30 31
Deposition of
Juan Alessi
Ft. Lauderdale , FL
(subpoena served)
Case no. 15-cv-07433-RWS
June 2016

Sunda Monda Tuesda Wednesday Thursda Frida Saturday
2 "
..)
Deposition of
Maria Ales si
Ft. Lauderdale, FL Ocala, FL Ft. Lauderdal e, FL Ft. Lauderdale,
(subpoena serve d) (subpoena serve d but (subpoena served) FL
and/or Maxwell's counsel (served)
needs to confirm
date change with
witness)
Dep
liiifl
D
--- --
5 6 7 8 9 IO 11
D-- f
New York, NY New York/New Armonk, NY
(possible date) Jersey New York, NY (confirmed)
12 13
..
14
New York, NY
15
Deposition of
Jared Weisfeld/
Sharon Churcher
(or find additional
date if they will be
16
Deililiiir
Am1onk, NY
17 18
too Ion )
19 20 21 22 23
--
24 25
Deposition of
Detective Joe
Recarey Ft. Lauderdale, FL New York, NY
Ft. Lauderdale, FL
Case no. l 5-cv-07433 -R WS
26 27 28 29 30

(Other California Deposition of .
witnesses if ■
a I om1aor needed) (pos I e ate)
London
(possible date not
served with
subpoena et
***Week of June 20-24 may be bad for Maxwell's counsel (please confirm)
****Week of June 27 -Ju ly l st may be bad for Maxwell's counsel (please confirm)
*****Need to confirm Maxwell will accept service for her agent Ross Gow.
There may be a few other witnesses that we may need to add if they can't confirm attendance at trial.
EXHIBIT 13
(Filed Under Seal)


V.
Ghislaine Maxwell,
Defendant.
__ ___________ /
PLAINTIFF, VIRGINIA GIUFFRE'S THIRD REVISED DISCLOSURE

PURSUANT TO FED. R. CIV. P. 26
COMES NOW the Plaintiff, Virgin ia L. Giuffre, by and through her undersigned counsel,
and serves this revised disclosure pursuant to Fed. R. Civ. P. 26 and states as follows:
A. Witnesses:
1. Virginia L. Gi uf:fre
c/o Sigrid S. Mccawley, Esq .
401 East Las Olas Boulevard, Suite 1200
Miami, Florida 33301
Tel: (954) 356-0011
Plaintiff - Information regarding Defendant, Ghislaine Maxwell's conduct that is

the subject of this action.
2. Ghislaine Maxwell
c/o Laura A. Menninger, Esq.
HADDON, MORGAN & FOREMAN, P.C .
Tel: (303) 831-7364
Ema il: lmenninger@hmflaw.com
Defendant in this action.
CONFIDENTIAL
3. Juan Alessi
Boynton Beach, FL 33472

Telephone nwnber unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein' s sexual
trafficking conduct and interaction with underage minors.
4.
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexual
trafficking conduct and interaction with underage minors .
5.
May have information about Ghislaine Maxweli and Jeffrey Epstein's sexual
6.
May have information about Ghislaine Maxwe ll and Jeffrey Epstein's sexual
7.
~ sent on flights with Jeffrey Epstein and Ghislaine Maxwell and -

-- and may have knowledge of Jeffrey Epstein and Ghislaine Maxwell's
sexual trafficking conduct and interactions with minors.
8.
9.
CONFIDENTIAL
May have inform ation about Ghislaine Maxwell and Jeffrey Epstein's sexual
10.
Was present on flights with Jeffrey Epstein , Ghislaine Maxwell and Virginia
Guiffre and may have information about Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
11.
May have information relating to Ghislaine Maxwell and Jeffrey Epstein 's sexual
12.
13.
Was present on flights with Jeffrey Epstein, Gh islaine Maxwell and Virginia
Guiffre and has information about Ghislaine Maxwell and Jeffrey Epste in' s sexual
trafficking conduct and interacti on with underage minors .
14.
Has know ledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
15.
3
CONFIDENTIAL
Worked for Ghislaine Maxwell and has information about Ghislaine Maxwell's
recruiting of girls for Jeffrey Epstein.
16.
May have information about Ghislaine Maxwell and Jeffrey Epstein 's sexual
17.
Worked for Jeffrey Epstein as a masseuse during the time that Virginia Giuffre was
living and traveling with Jeffrey Epstein and Ghislaine Maxwell, and has
information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
18.
Travelled with Jeffrey Epstein and Ghislaine Maxwell and may have information
about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking conduct.
19.
trafficking conduct.
20.
trafficking conduct.
21.
4
CONFIDENTIAL
Was present on flights with Jeffrey Epstein, Ghis laine Maxwell and may have
conduct and interaction with underage minors.
22 .
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and may have
23 .
May have information about Ghislaine Maxwell and Jeffrey Epstein's sexua l
24 .
Has knowledge of Defendant's conduct that is the subject of this action .
25.
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein 's sexual trafficking
conduct.
26.
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has
information about Ghislaine Maxw ell and Jeffr ey Epstein's sexual trafficking
conduct and interaction with unde rage minors.
27 .
CONFIDENTIAL
Was present on flights with Jeffrey Epstein, Ghislaine Maxwell and has
28.
29.
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking

conduct and interaction with underage minors, including Virginia Giuffre.
30.

31. Jeffrey Epstein

c/o Marty Weinberg, Esq.
20 Park Plaza, Suite 1000, Boston, MA 02116
Tel: (617) 227-3700
Has knowledge of Defendant's conduct that is the subject of this action and
knowledge of his sexual trafficking operat ion and other co-conspirators.
32.
33.

6
CONFIDEN TIAL
34.
Has knowledge of Ghislaine Maxwell and Jeffrey Eps tein's sexual trafficking
conduct and interac tion with underage minors, including Virginia Giuffre.
35. Vicky Ward

Telephone unknown at this time
Has knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexua l trafficking

conduct and interaction with underage minors, including Virginia Giuffre .
36.
Has knowledge of Defendant's conduct that is the subject of this action .
37.
Has knowledge of Defendant's conduct that is the subjec t of this action.
38.
Jeffrey Epstein's staff member in his various homes and may have know ledge of
Defendant and Jeffrey Epstein's inappropriate conduct with underage girls .
39.
May have knowledge of Defendant's conduct that is the subject of this action.
40 .
Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with minors.
41.
7
CONFIDENTIAL
Former house staff and may have knowledge of Ghislaine Maxwell and Jeffrey
Epstein's sexual trafficking conduct and interaction with minors.
42.
Defendant 's press agent who has knowledge of the defamatory statements in this
case.
43 .
May have information about Ghisla ine Maxwell and Jeffrey Epstein 's sexual
trafficking conduct and interaction with underage minors
44 .
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein ' s sexual trafficking
conduct.
45.
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
46.
May have knowledge of Ghislaine Maxwe ll and Jeffrey Epstein's sexua l trafficking
conduct.
47.
8
CONFIDENTIAL
Has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and abuse and interac tion with underage minors.
48.

conduct and interac tion with underage minors.
49 .
50.
conduct and interact ion with underage minors.
51. Brett Jaffe

Address noted on Defendant's Rule 26 ctisclosures
Defendant's attorney.
52.

53.
9
CONFIDENTIAL

conduct and interactions with minors.
54.
55.

56.
Traveling chef for Je ffrey Eps tein and Gh islaine Maxwell and may have know ledge
of Ghislaine Maxwell and Jeffrey Epstein's sexua l trafficking conduct and
interaction with underage minors.
57.
conduct and interaction with underage minors .
58.
May have know ledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct.
59.
May have know ledge of Ghislaine Maxwell and Jeffrey Epstein's sexua l trafficking
60.
CONFIDENTIAL
61.
conduct and interaction with w1derage minors.
62.
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein ' s sexual trafficking
conduc t and interaction with underage minors.
63.
Has knowledge of Ghislaine Maxwell and Jeffrey Eps tein ' s sexual traffick ing
conduct and interaction with Wlderage minors .
64 .
May have informatio n about Ghis laine Maxwell and Jeffrey Epstei n 's sexual
trafficking conduct and interaction with underage minor s.
65.
May have know ledge of Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
conduct and interaction with unde rage minors.
66.
11
CONFIDENTIAL
House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epstein · s
sexua l trafficking conduct and interaction with underage minors.
67.
House staff who may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual tra fficking conduct and interaction with underage minors.
68.

conduct and interaction with und erage minors .
69.
Kno wledge of Defendant's conduct that is the subject of this action.
70.
House staff that may have know ledge of Ghislaine Maxwell and Jeffrey Epste in's
sexua l trafficking conduct and interaction with und erage minors.
71.
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual traffick ing conduct and interaction with underage minors .
72.

73 .
12
CONFIDENTIAL
May have knowledge of Defendant's conduct in this action.
74.
House staff that may have knowledge of Ghislaine Maxwell and Jeffrey Epstein's
sexual trafficking conduct and interaction with underage minors.
75. Joseph Recarey

2753 Misty Oaks Circle
Royal Palm Beach, FL 33441
Telephone number unknown at this time.
Detective Recarey was the chief investigator of the crimes committed at Jeffrey
Epstein's Palm Beach mansion and has information about Ghislaine Maxwell and
Jeffrey Epstein's sexual trafficking conduct and interaction with underage minors.
73. Chief Michael Reiter

2335 So. Ocean Blvd., Apt. 15
Telephone number unknown at this time.
Police Chief Reiter oversaw the investigation of the crin1es committed at Jeffrey
Epstein 's Palm Beach mansion and has information about Ghislaine Maxwell and
Jeffrey Epstein's sexual trafficking conduct and abuse of underage minors.
74.

75.

76.
13
CONFIDENTIAL

77.

78.

cond uct and interaction with underage minors.
79.
Worked for Jeffrey Epstein during the time when Virginia Giuffre was living and
trave ling with Jeffrey Epstein and Ghislaine Maxwell. Johanna Sjobjerg was also
present at an occasion with Prince Andrew, Ghislaine Maxwell, and Virginia
Giuffre when Ms. Giuffre was a minor.
80.
May have knowledge of Ghislaine Maxwe ll and Jeffrey Epstein's sexua l trafficking
81.
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein's sexual traf ficking
82.
14
CONFIDENTIA L

83.
May have knowledge of Ghislaine Maxwell and Jeffrey Epstein' s sexual trafficking
conduct.
84.

85.

86.
Has information about Ghislaine Maxwell and Jeffrey Epstein's sexual trafficking
87.

88. All females identified in the police reports or identified through the United State's
Attorney's office during or through the criminal investigation of Jeffrey Epstein
and his co-conspirators.
15
CONFIDENTIAL
89. All other then-minor girls, recruited by Ghislaine Maxwell , whose identities Ms .
Giuffre will attempt to determine, with whom Defendant, Ghisla ine Maxwell and
Je ffrey Epste in, have engaged in sexua l activity.
90. All pilots, chauffeurs, chefs, and other employees of either Defendant Maxwell or
Jeffrey Epstein with knowledge of Defendant and Jeffrey Epstein's inappropria te
conduct ·with underage girls .
91. All staff and employees at the Mar-a-Lago Club during 1999-2002.
92. All other witnesses learn ed through discovery process.
B. Relevant Documents:
1. All files held by the Palm Beach Police Department or the Palm Beach State
Attorney's office which are publicaUy available.
2. All press releases of Ghislaine Maxwell or on her behalf.
3. The video(s) of Ghislaine Maxwell adopting the January, 20 15 press statement.
4. All newspaper or other media where Ghislaine Maxwell's press relea se appears.
5. All evidence obtained by the Federal Bureau of Investigations which relate in any
way to Jeffrey Epstein or Ghislain e Maxwell.
6. All 302 statements that relate in any way to Jeffrey Epstein or Ghislaine Maxwell.
7. All evidence obtained by the FBI or United States Attorney's office by or through
the criminal investiga tio n of
8. All documents relating to the previous subpoenas served on Defendant for her
deposition and all documents related in any way to that deposi tion.
9. All documents evidencing visitors or passengers at any of Jeffrey Epstein owned or

controlled property or aircraft .
10. All documents demonstrating the relationship between and Jeffrey

Epstein or Ghislaine Maxwell.
11. All photos of Ghislaine Maxwell at
12. All documents or information refuting statements made by Ghislaine Maxwell.
13. All documents and informat ion relating to ravel, including travel
to New York City and the Caribbean, in 1999 to 2002.
16
CONFIDENTIAL
C. Exhibits:
1. Palm Beach Police Department report and documents contained within Jeffrey
Epstein's crimina l files, attached hereto as Exhib it 1.
2. March 10, 2011 Statement on behalf of Ghislaine Maxwell by Media agent Ross
Gow, attached hereto as Exhibit 2.
3. September 3, 2008 Victim Notification Letter, attached hereto as Exhibit 3.
4. May 1, 2009 Complaint in Jane Doe No . 102 v. Jeffrey Epstein, CIV-09-80656, in

the Southern District of Florida, attached hereto as Exhibit 4.
5. FBI 302 Statement, attached hereto as Exhibit 5.
6. Flight Logs, attached hereto as Composite Exhibit 6.
7. Message Pads from Law Enforcement from trash pull of Jeffrey Epstein 's Palm
Beach home, attached hereto as Exhib it 7.
8. Jeffrey Epstein's Phone Book, also referred to as his "Black Book," attached hereto
as Exhibit 8.
9. Deposition o attached hereto as Composite Exhibit 9.
10. Deposit ion Transcripts of Juan Alessi, attached hereto as Ex hibit 10.
11. Deposition Transcripts of attached hereto as Exhibit 11.
12. Janu ary 2, 2015 Corrected Joinder Motion [DE 280] filed in the CVRA action
pending in the Southern District of Florida , attached hereto as Exhib it 12. [All
paragraphs between "The Government then concealed from Jane Doe No. 3
the existence of the NP A (pg. 3) and "The Government was well aware of Jane
Doe No. 3 when it was negotiating the NPA" (pg. 6) were stricken by Judge
Marra.]
13. January 21, 2015 Declara tion of Jane Doe No. 3 filed in the CVRA action pending
in the Southern District of Florida, attached hereto as Exhibit 13. [Paragraphs 4, 5,
7, 11, 13, 15, 19-53, and 59 were stricken by Judge Marra]
14. February 6, 2015 Declaration of Jane Doe No. 3 filed in the CVRA action pending
in the Southern Distric t of Florida, attached hereto as Exhibit 14. [Paragraphs 7-
12, 16, 39 and 49 were stricken by Judge Marra.]
15. November 25, 2015 Affidavit of Virginia Giuffre, filed in the Bradley Edwards and
Paul Cassell v. Alan Dershowitz matter, pending in the Seventeenth Judicia l
Circuit, Broward County, Florida, attached hereto as Exhibit 15.
16. Virginia Roberts' passport, attached hereto as Exhibit 16.
17
CONFIDENTIAL
17. Judge Thomas Lynch's January 12, 20 16 Confidentiality Order regarding Virginia
Giuffre's deposition, attached hereto as Exhibit 17.
18. Documents produced and bates labelled Non-Party VR 000001 - Non-Party VR

000644, in the Bradley Edwards and Paul Cassell v. Alan Dershowitz matter,
pending in the Seventeenth Judicial Circuit, Broward County, Florida, attached
hereto as Exhibit 18.
19. Victims Refuse Silence Articles of Incorporation and Amendment, attached hereto
as Composite Exhibit 19.
20. Victims Refus e Silence By-laws, attached hereto as Exhibit 20 .
21. Victims Refuse Silence 2016 Annual Report, attached hereto as Exhibit 21.
22. January 3, 2015 Daily Mail article: "Harvard Law Professor Named Alongside
Prince Andrew in ' Sex Slave' Case Accuses Alleged Victim of 'Making Up
Stories,"' attached hereto as Exhibit 22 .
23. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in
"Ghislaine Maxwell: I was not a madam for paedophile," attached as Exhibit 23.
24. January 4, 2015 Statement by Ghislaine Maxwell to New York Daily News
Reporter "Alleged Madam Accused of Supplying Prince Andrew With Underage
Teen for Sex Spotted in NYC - As He's Seen Cutting Swiss Vacation Short to Face
Queen," attached hereto as Exhibit 24.
25. February 1, 2015 Min-or article: "Prince Andrew's Pal Ghislaine Maxwell May Sue
Over Madam Allegations ," attached hereto as Exhibit 25.
26. September 23, 2007 Red lee Creations Article "Prince Andrew's Friend, Ghislaine
Maxwell, Some Underage Girls, and A Very Disturbing Story," attached hereto as
Exhibit 26.
27. Photographs , attached hereto as Exhibit 27.
28. April 13, 2010 Deposition Transcript of Nadia Marcinkova, attached hereto as
Exhibit 28.
D. Computation of Damages:
l. Physical, psychological and psychiatric injuries and resulting medical expenses - in

an amount of approximately $ 102,200 present value.
a. Computation Analysis:
1. Giuffre has had to receive treatment for the psychological harm as a

result of Maxwell' s condu ct towards Giuffre.
18
CONFIDENTIAL
11. The average annual expenditures for mental health services for adults
18-64 in the United States is $1,751.
m. Giuffre needs continuing care as a result of the harm she has suffered .
Ms . Giuffre was born August 9, 1983 and was 31.4 years old at the
beginning of 2015 when the alleged harm occurred. The average
remaining life expectancy for a 31 year old female is 51.1 years .
1v. Based on a remaining life expectancy of 51. 1 years, annual healthcare

cost growth of 3.3% and a discount rate of2 .7%, the present value of
expected treatment costs is$ 102,200 as of 1/1/2015 .
b. Supporting Evidence:
1. Ms. Giuffre is in the process of collecting records from her physicians
ii. Ms. Giuffre's testimony
m. Ms. Giuffre is in the process of retaining an expert to calculate

damages, and will provide further information through expert
disclosure.
2. Past, present and future pa in and suffering, mental anguish, humiliation,

embarrassment, Joss of self-esteem, loss of standing in the community, loss of
dignity and invasion of privacy in her public and private life not less than
$30,000,000 .00.
a. Computation Analysis
1. Under New York law, defamation per seas alleged in this case
presumes damages and specia l damages do not need to be plead and
proven. See Celle v. Filipino Reporter Enterprises Inc., 209 F.3d 163,
179 (2 nd Cir. 2000) (Second Circuit holding that •[i]f a statement is
defamatory per se, injury is assumed. In such a case •even where the
plaintiff can show no actual damages at all, a plaintiff who has
otherwise shown defamation may recover at least nominal damages'
and the Second Circ uit also confirmed an award of punitive
damages). Ms. Giuffre has been severe ly damaged by the defamation
of the defendant, by calling her claims of sexual abuse "obvious lies".
The defamation caused Ms. Giuffre to re-l ive the sexual abuse she
previously endured. Ms. Giuffre has suffered and continues to suffer
from the pain, mental anguish, humiliation, em barrassment, loss of
self-esteem, loss of standing in the community, loss of dignity and
invasion of privacy in her public and private life. The computation of
this amount is in the province of the jury but Ms. Giu ffre contends,
19
CONFIDENTIAL
including but not limited to, awards in other similar matters, that the
amount is not less than $30,000,000.00. Ms. Giuffre is in the process
of retaining an expert, and will provide further information through
expert disclosure.
b. Supporting Evidence
1. Ms. Giuffre's testimony
11. Witness testimony
111. A wards in similar matters
iv. Ms. Giuffre is in the process ofretaining an expert, and will provide
further information through expert disclosure.
3. Estimated lost income of$180,000 annually. Present value of$3,461,000 to

$5,407,000.
a. Computation Analysis
1. Ms. Giuffre's estimated compensation capacity is $180,000 annually.

Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the
beginning of 2015 when the alleged injury occurred. Her expected
remaining work life based on mortality and probability of continued
work was 20 .2 years. Based on these factors, a 2% annual growth rate
and a 2.4% discount rate, the present value of lost compensation is
$3,461,000 as of 1/1/2015 .
11. Alternatively , if Ms. Giuffre is assumed to work until a normal

retirement age of 65, or 33.6 years from her age at the beginning of
2015, and based on an annual growth rate of2 .0% and a discount rate
of 2.7%, the present value of lost compensation is $5,407,000 as of
1/1/20 15.
b. Supporting Evidence
1. Materials regarding compensation and work life expectancy
1) 2010 Life Table for Females, National Vital Statistics Report,

November 6, 2014, U.S. Department of Health & Human
Services , Centers for Disease Contro l & Prevention, National
Center for Health Statistics.
20
CONFIDENTIAL
2) "Calculation of Work life Expectancy Using the Life,

Participation, Employment Method," Vocational Econometrics,
Inc.
3) Consumer Price Index for Urban Wage Earners and Clerical

Workers, United States Department of Labor, Bureau of Labor
Statistics.
4) Federal Reserve Statistical Release H.15, 1/5/2015 .
11. Ms. Giuffre's testimony
m. Ms. Giuffre is in the process of retaining a damages expert and will provide
further information through expert disclosures.
4. Punitive Damages - to be based upon all relevant factors, including the egregious
nature of Defendant, Ghislaine Maxwell's conduct and the need for a large award to
punish and deter conduct in view of the vast wealth of Defendant Maxwell, in an
amount not less than $50,000,000 .00.
a. This calculation is in the province of the jury .
21
CONFIDENTIAL
Dated : June 1, 2016.
By : Isl Sigrid McCawley

Sigrid Mccawley (Pro Hae Vice)
Meredith Schultz (Pro Hae Vice)
(954) 356-0011
David Boies
333 Main Street
Armonk, NY 10504
Bradley J. Edwards (Pro Hae Vice)

EDWARDS, FISTOS & LEHRMAN , P.L.
425 North Andrews A venue, Suite 2
(954) 524-2820
Paul G. Cassell (Pro Hae Vice)

University of Utah
383 University St.
SaJt Lake City, UT 84112
(801) 585 -5202 1
1
This daytime business address is provided for identifica tion and correspondence purpo ses only and is not intended to
imply institutional endo rsement by the University of Utah for th is private repre sentation .
22
CONFIDE NT IAL
CERTIFICATEOF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the above and foregoing
Disclosure Pursuan t to Fed. R. Civ. P. 26 has been provided by United States mail and electronic
mail to all counsel of record identified belo w, on this 1st day of June, 2016.
Laura A. Menn inger, Esq.

Jeffrey S. Pagliuca, , Esq.
HADDO N, MORGAN & FOREMAN, P.C.
Tel: (303) 831-7364
Fax: (303) 832-2628
Email: lmenninger{@hmflaw.com
Email: jpagliuca@ hm f1aw.com
By: Isl Sigrid McCawlev

Sigrid McCawley
23
CONFIDENTIAL
COMPOSITE
EXHIBIT 14
(Filed Under Seal)

Sandra Perkins

Sent: Thursday, June 16, 2016 4:56 PM
To: Laura Menninger (lmenn ing er@hmflaw .com)
Cc: Sigrid Mccawley; Paul Cassell (cassellp@law.utah.edu); 'brad@pathto j ustice.com '
(brad@pathtojustice .com)
Subject: Proof of Service - Second Email
Attachments: Proof of Services
Laura,
I am writing to follow up on my June 13, 2016, letter and my June 14, 2016 email (attached), where I requested that you
provide me with your proofs of service for the subpoenas you issued in this case. I requested that you provide them to
me yesterday, but you have not done so. You made the same request of us and we provided our proofs of service to
you earlier this week.
We are in the process of making travel arrangements for t he deposit ions you noticed next week and scheduling around
other matters and want to confirm that those witnesses have all been served with subpoenas and are attending the
depositions set for th below:
nd
-- Wednesday, June 22 9:00 a.m. - Fort Lauderdale 401 E. LasOlas at Gray Robinson's office - suite
1000.
-- Thursday June 23rd 9:00 a.m. - Ocala Florida - Owens & Associates - 108 N. Magnolia Ave
- Friday June 24th - 9:00 a.m. - 1 Florida Park Drive, U.S. , Suite 214, Palm Coast Florida
Accordingly, kindly provide me - today - your proofs of service for all of the subpoenas you have issued in this case.
Thank you,
Meredith
Meredi th L. Schult z
:'3(J:ES, SC IIILLEI{ 8'. CLf:{N ER LJ,P
Fort Lau derdale, FL 33301
Phone: 954- 356 -001 l ext. 4204
Fax : 954-35 6-0022
http ://www.b sfllp.com
Sandra Perkins

Sent: Tuesday, June 14, 2016 3:15 PM
To: Laura Menninger (lmenninger@hmflaw.com)
Cc: Sigrid Mccawley; Sandra Perkins; Deborah Knowlton
Subject: Proof of Services
Attachments: PROOFOF SERVICES.PDF
Laura,
I'm following up on my June 14, 2016, letter, wherein, I agreed, as a courtesy, to provide you with proofs of service. They
are attached. In the same letter, I requested that you do the same, and provide me with your proofs of service
associated with t he subpoenas you have issued in this case. Having made the request of me and hav ing received a
response, I am sure you w ill agree to do so. Please send them to me by tomorrow.
Meredith
Meredith L. Schultz
l.1(J1ES.~CHILLER & FLE:<Ni::RLLP
401 East .Las Olas Blvd. , Suite 1200
Fon Lauderdale, FL 33301
Phone: 954-356-0011 ext. 4204
Fax: 954-356-0022
http://www.bstllp.com
1
Meredith L. Schu ltz, Esq.
Email: mschultz@b sfllp .com
June 13, 2016
V iaCM/ECF
Lau ra A. Menninger, Esq.

Haddon, Morgan and Foreman, P.C.
150 East 10th Ave.
Denver, CO 80203

Case no. 15-cv-07433- R\ VS - Regardi ng Certifica tes of Service
Dear Laura,
~ served the witnesses in this case, and have undertaken great effo1t to
scrve ---- and - An affidavit from the process server engaged in that
effort documenting such efforts was served upon you and filed with this Court. I'm familiar with
Rule 45, and there is no requirement that certificates of service be served upon opposing counsel.
Notice is all that is required under the Rules . You, yourself, have not served such certificates of
service in this case . I completely reject your arbitrary statement that "[i]ailure to provide them ..
. will be underst ood as an acknowledgement that you have not, in fact, undertaken the good faith
efforts ." We have said we did. I acknowledge no such thing, and such a statement is nonsense .
In recognition of your request, I am jn the proce ss of gather ing the certificates of service .
I will serve them on you, merely as a courtesy, as I collect them. Please likevvise provide all
certificates of services for the witnesses you have noticed .
While we are on the topic of absences of responses , you did not res ponds to my June 8,
2016, letter requesting a meet and confer call. Therefore, I write again to schedule a meet-and-
confer call regarding your grossly deficien t production and improper objec tions in response to
Plaintiffs Second Request for Production. I am available for a meet and confer call on this
matter any time tomorrow and Wednesday, June J 5, 2016, from I 0:00 AM EST to 4:00 PM
EST. Please advise, by tomorrow, what time such a call works for your schedule.
Thanks,
~J?L& ~
Meredith Schultz
WIHl , OS FLl P . COM
W WW .B SFL L P.COM
EXHIBIT 15
(Filed Under Seal)

Meredith L. Schultz, Esq.

E-mail: mschultz@bsfllp.com
CONFIDENTIAL
June 8, 2016
VIAE-MAIL

th
150 East I 0 A venue
Denver , Colorado 80203
Re: Giuffre v. lv/axwel!

Dear Jeffrey,
This letter is in response to your Responses and Objections to Plaintiff's Second Request
for Productionof Docwnents, and to follow up on the designations of Confidentiality that have
arisen in this case.
In general, at various stages you have complained about our production; however, we
have produced an eno rmous volume of documents. On the other hand, you have produced
virtually nothing. We would like some good faith cooperation in the discovery process . You
cannot actually believe that we are not entitled to anything . I am hopefu l that you will quickly
reconsider your numerous unwarranted obj ections so that we are not forced to fight to get readily
available discoverable information from you.
Regarding the Responses and Objections, I would like to set up a meet-and-confer call
concerning the following issues.
Document Request No. 1
You state that you have "made available documents related to some of Ms. Oiuffre's
false allegations of sexual as sault s in her Second Supplemental Fed . R. Civ. P. 26(a)(l )(A)
disclosures." I assume that you are referring to the police reports documenting sexual assault
agains t Ms. Giuffre as a 14-year -old -girl. Looking past your inaccurate description of such
reports as "false," you sti ll have failed to produce the documents you relied upon in the March
21 , 2016 meet-and-confer call when you stat ed that Ms . Giu ffre "cried rape ."
The police reports you produced bear date-stamps on them from the issuing agency, all of
the date-stamps post -date the March 21, 2016, phone call. Indeed, the earliest date is from April
of 2016. Accordingly, these are not the documents you relied upon in the March 21, 2016, meet-
WWW .S SF Ll.P .C OM
' s . H - L R F t E XN R L p

June8, 2016
Page 2 of 4
and-confer, as the date on the documents show that you did not have them at that time. It is
obvious that you obtained copies of these police reports ( or detailed descriptions of them) by
other means prior to the March 21, 2016, meet and confer. Accordingly, you have not made any
production in response to this Request. That fact that you went to the trouble of getting copies of
these reports in April - after the meet-and-confer and after Ms. Giuffre issued her Request -
instead of simply producing the copies you already have, raises questions, as police reports of
minors, especially those detailing sexual crimes by and against minors, are protected from public
dissemination by Florida law. 1 Therefore, please provide all documents you reviewed or relied
upon in making the statements referred to in Document Request No. 1 by Monday, June 13,
2016.
Document Request No. 2 and 3
The response to Document Request No. 2 is inadequate for the reasons stated above, and
because there is no attorney-client or work product privilege associated in communications or
other documents used to obtain public records, particularly as no privilege attaches to such
communications and the existence of the public records themselves has already been revealed
and used by you. Therefore, the communications concerning your procurement of these
documents are responsive, not privileged, and not properly withheld. Additionally, there is no
work product protection for illegally acquired documents, and police reports documenting the
sexual assault of children are not publically available in Florida Additionally, any statements or
communications made by public officials in law enforcement or the state attorney's office are not
privileged and are not protected by the work-product doctrine, and you cite no authority for such
a proposition. Your failure to respond to these Requests is indicia that it is possible the police
reports you relie d upon in March were procured by improper means by whichever individual
2
furnished you with them, particularly since Florida law protects such reports and keeps them
confidential. In short, how did you get materials that are protected from public disclosure by
Florida law? How did your client get them? It appears many Florida statutes may well have been
violated in obtaining these documents - violated prior to March 16, 2016, and information
concerning how, and by whom, they were violated is responsive to Ms. Giuffre's requests.
Document Request Nos. 6, 7, 9, and 10
1
First, Florida statutes protect"[ a)ny information in a videotaped statement of a minor who is alleged to be or who
is a victim of sexual battery . .. which reveals that minor's identity." Fla. Stat.§ 119.071. Additionally, Fla. Stat.
985.036 protects records where a juvenile is a victim of a crime. Further, Section 794.026, Fla. Stat., creates a civil
right of action against an individual who communicates to others, identifying infonnation concerning the victim of a
sexual offense. Additionally, Second, Fla. Stat. § 985.04 and Fla. Stat. § 985.054 make juvenile law enforcement
records confidential from members of the public. , and states that infonnation obtained by a law enforcement agent
participating in the assessment of a juvenile is confidential. Finally, certain of the police reports implicate Ms.
Giuffre's involvement with the Florida Department of Children and Families, see e.g., GM_00750, and if such
reports are part of the State's Department of Children and Families' records, they are confidential pursuant to Fla.
Stat. § 39.202(6).
2
Id.
r~ I S • S C H I L L R ~ F L E- X N R L L P

June 8, 2016
Page 3 of4
Please explain, and cite any authority, as to why you believe a Joint Defense Agreement,
or documents relating to such an agreement, with Jeffrey Epstein is protected by the
attorney/client privilege, the work product doctrine, the common interest privilege or any other
applicable privilege. You have demanded that our client produce her Joint Defense Agreement
and she did, yet you continue to withhold your client's Joint Defense Agreements. How can you,
in good faith, strenuously argue your entitlement to our Joint defense agreement while
simultaneously lodging an objection to producing yours?
In this Court's previous Order requiring you to turn over the vast majority of the
documents on your fir~ s Court ordered you to turn over your client's
communications with - because it ruled that such communications are not
privileged. Yet, once again, you are apparently ignoring the Court~ d wrongfully
try ing to claim privilege over your client's communications with ~ Interestingly,
you claim to be withholding communications with - because they "concern joint
defense or common interest matters," yet you claim that your client is "unable to locate" her IDA
with As you know, it is your burden to show a join t defense agreement exists, and
cannot rightly claim a joint defense privilege while simultaneously failing to produce the joint
defense agreement. Accordingly, based upon the foregoing and this Court's prior order, you are
required to produce these documents.
You state that "Ms. Maxwell and her counsel are not going to review every document in
their possession for any additional documents response to this Request." I would like to discuss
why you don't electronically nm targeted search terms (such as Virginia, Jenna, Roberts, VR,
Giuffre) over the electronic information. A key stroke would foreclose the need to "review[] ..
every single document in their possession," and doing so would not be burdensome. We have
repeatedly complied with your expansive discovery requests and you have an obligation to
participate in discovery in good faith.
Request Nos. 17 and 18
Please explain why you are not producing documents concerning the defamatory
statement at issue in this case. These documents go to the heart of the matter, and you have not
asserted a good-faith basis for refusal to produce them. You client defamed Ms. Giuffre on a
global stage, but now is "unable to locate" documents concerning her statement? This response
indicates absence of a thorough search of your client's documents, and I urge that you reconsider
your decision to fail to produce documents concerning Ms . Maxwell's defamatory statements.
BO LS , S C H • l.L !' R f F L F: N E R L LIJ

June 8, 2016
Page 4 of 4
Document Request No . 19
The response to this request does not indicate that you are withholding any documents
responsive to this request, but it seems likely that there exist responsive documents . Are you
withholding any documents responsive to this request, and, if so, why?
Additionally, pursuant to my May 20, 2016, lett er, please identify all individuals with
whom you have shared any copy of the police reports Bates labeled GM_00784-00801 and
GM_00755-00775 by Friday, June 10, 2016.
Finally, Paragraph 11 of the Protective Order states that "L1Jfthe parties cannot resolve
the objection within ten (10) business days after the time the notice is received, it shall be the
obligation of the party designating the information as CONFIDENTIAL to file an appropriate
motion requesting that the Court determine whether the disputed information should be subject
to the terms of the Protective Order." It was my understanding that the objection was resolved
when I wrote to you in my May 20, 2016, letter setting forth the multiple bases for our
confidentiality designation since I did not receive any response from you contradicting those
bases or maintaining your objection. Accordingly , I cons ider the issue resolved, and I consider
the confidentiality designation to stand. However, if you take a different view, please advise.
Rather than litigate this issue it would seem a more productive use of all part ies' time to discuss
this matter and see if we can resolve it. If you intend, as you suggest, to treat as non-confidential
the police reports which we maintain are confidential, without further discussion please let me
know so that we can file the appropriate motion to protect our client. Lastly, it seems you are
interpreting paragraph 11 to mean that if one party objects to the confidential status of a
document and the other party does not file a motion to maintain the status then the document is
immediately deemed non-confidential. That is not my interpretation of that paragraph but if that
is yours then I would like to know .
I look forward to talking about all of these issues and hopefully resolving some. I am
available any time tomorrow afte r 11 :00 AM EST, and any time on Friday prior to 4:00 PM EST
to discuss.
Sincerely,
MS :aa
1rl~L_ll~
Meredith Schultz ,,,,r

v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID S. McCAWLEY IN PLAINTIFF’S OPPOSITION TO

DEFENDANT’S MOTION TO REOPEN DEPOSITION OF PLAINTIFF
licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015
Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in Opposition of Defendant’s Motion to
Reopen Deposition of Plaintiff.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Judith Lightfoot
Redacted Medical Records (Giuffre005431-005438).
4.
-
Attached hereto as Sealed Exhibit 2 is a true and correct copy of Judith
Lightfoot’s June 27, 2016 Correspondence (GIUFFRE006636).


(954) 356-0011
David Boies
333 Main Street
Armonk, NY 10504

(954) 524-2820

University of Utah
383 University St.
(801) 585-5202 1
1
2
foregoing document is being served to all parties of record via transmission of the Electronic
Court Filing System generated by CM/ECF.

Tel: (303) 831-7364
Fax: (303) 832-2628

Sigrid S. McCawley
3
EXHIBIT 1
(File Under Seal)
Authorization to Disclose Prot ected Health Information
Name:
Address:
Date ofBirth:
Soc. Sec.#
I hereby authorize the use and/or disclosure of my protected health infonnation as

described in this authorization.
1. Specific person/organization (or class of persons) authorized to prov ide the

information:
Judith Lightfoot
2. Specific person/organization (or cl ass of persons) authorized to re ceive

and use the infonnation:
Sigrid McCawley
F ort Lauderdale, FL 33301
3. Specific description of the infonnation: Medical records fr om 1999 to the
present, including, but not limited to, all ofmy office medical records , hospital medical
recor ds, patient infonnation sheets, questionnaires, x-rays, other diagnostic studies and
laboratory tests, emergency room records, out-patient records, consultation records,
thera py records, and all other in-patient or out-patient hospita l notes, charts, documents,
all personal notes and all billing records .
4. Specific purpose for the use and/or disclosure of the pr otected health
infonnation: At my request in connection with litigation pending in the County District
Court .
5. I understand this authorization will exp ire, without my express revocation,

one year from the date of signing, or if I am a minor, on the date I become an adult
according to state law. I unde rstand that I may revoke this authorization in writing at any
time except to the extent that action has been taken based on this authorization . I
understand that revoc ation will not apply to information that has already been released as
specified by this author ization or to my insurance company when the law prov ides my
insurer with the right to contest a claim under my policy or the policy itself.
GIUFFRE005431
CONFIDENTIAL
6. I understand that the medical information released by this authorization

may include inforn1ation concerning treatment of physical and mental illness,
alcohol/drug abuse and past medical history.
7. I understand that after this information is disclosed, federal law might

not protect it and the recipient might disclose it.
8. [ understand that I am entitled to receive a copy ofth1s authorization.

9. I understand that [ may refuse to sign this authorization and that my
refusal to sign will not affect my ability to obtain treatment from the above-named
medical provider.
10.. (\Photopopies of this authorization are to be given the same effect as the
original. \/ . _...·
(,~t~ 5 /J / l C-· i
Signatur'i ) Date
GIUFFRE005432
CONFIDENTIAL
EXHIBIT 2
(File Under Seal)
Meredith Schultz
From: Bernadette Martin < bernadette@mbe-accounting.com.au >

Sent: Monday, June 27, 2016 10:33 PM
To: Meredith Schultz
Subject: Virginia Giuffre
Dear Sir/Madam
Ms Judith A Lightfoot has requested I forward this to you:
This will serve to advise all records of a psychological nature have been presented.
Judith A Lightfoot
Consulting Psychologist
28 June 2016
Kind Regards
Bernadette Martin
Ph: 02 43533630
Fax: 02 43533629
Bernadette@mbe-accounting.com.au
Suite lg
154-156 Pacific Highway
TUGGERAH2259
PO Box 3435, TUGGERAH2259
This email message and any accompanying attachments may contain information this is confidential and is subject to
legal privilege. If you are not the intended recipient, do not read, use, disseminate, distribute or copy this message or
attachments. If you have received this message in error, please notify the sender immediately and delete this message
together with any attachments.
GIUFFRE006636
CONFIDENTIAL

--------------------------------------------------X
.............................................
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
REPLY IN SUPPORT OF MOTION TO REOPEN DEPOSITION OF PLAINTIFF

VIRGINIA GIUFFRE
Laura A. Menninger
Jeffrey S. Pagliuca
East 10th Avenue
Denver, CO 80203
303.831.7364
TABLE OF CONTENTS
INTRODUCTION .......................................................................................................................... 1
ARGUMENT .................................................................................................................................. 2
I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER DEPOSITION

NECESSITATES ADDITIONAL EXAMINATION ............................................................. 2
A. Plaintiff failed to identify her health care providers and produce their records prior to
her deposition, despite this Court’s order ........................................................................ 2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue of her employment records ............................................ 5
D. Newly obtained education records and other witness testimony contradict Plaintiff’s
deposition ......................................................................................................................... 5
E. Plaintiff identified new witnesses in her Rule 26 disclosures after her deposition .......... 6
II. PLAINTIFF’S COUNSEL INSTRUCTED PLAINTIFF NOT TO ANSWER RELEVANT,

NON-PRIVILEGED QUESTIONS IN HER FIRST DEPOSITION ...................................... 7
III. PLAINTIFF CONCEDES THAT HER ERRATA SHEET IS PROPERLY THE SUBJECT
FOR RE-OPENED DEPOSITION.......................................................................................... 9
IV. RESTRICTIONS TO TWO HOURS AND VIA VIDEOTAPE UNJUSTIFIED ................... 9
i
Defendant Ghislaine Maxwell submits this Reply to Plaintiff’s Opposition (“Response”)
to Motion to Reopen Deposition of Plaintiff (“Motion”), and as grounds therefore states as
follows:
INTRODUCTION1
Plaintiff concedes the reopening of her deposition based on (a) the late production of
records concerning Plaintiff’s medical and mental health treatment, (b) her unjustifiable refusal
to answer questions related to statements the media “got wrong,” (c) material edits to her
deposition testimony through her errata sheet. Plaintiff did not address her newly disclosed
employment records and thus it should be deemed admitted. Apparently, she still contests
questions regarding other items not disclosed until after her deposition, including (a) iCloud and
Hotmail emails, (b) school records from Forest Hills High School, Wellington High School and
-
Survivors Charter school, and (c) witnesses newly identified in her Third and Fourth Revised
Rule 26 disclosures. There is no legally principled reason to exclude these topics during
Plaintiff’s reopened deposition and Ms. Maxwell should be permitted to examine Plaintiff based
on this information produced after her deposition although requested before.
The other limitations proposed by Plaintiff are not appropriate. Due to the quantity of
documents and the number of topics, two hours will be insufficient to appropriately inquire.
Moreover, Plaintiff’s deposition should be in person; she chose to move to Australia from
-
Colorado during the pendency of this case and has been in the US for weeks attending witness
depositions and other litigation matters by her own choosing. Deposition by videoconference
will be extremely cumbersome to accomplish given the hundreds of pages of documents to be
1
Defendant conferred with counsel for Plaintiff regarding this Motion prior to its filing. By email of May 8, 2016,
Mr. Pagliuca requested conferral regarding Plaintiff’s refusal to answer questions at her deposition. That conferral
was held on May 9 and May 10. Mr. Edwards offered, for example, to consider whether a verified representation by
Plaintiff all of the statements that the media “got wrong” would suffice instead of a re-opened deposition.
1
covered and which were necessitated by Plaintiffs late disclosures and refusal to answer
questions at her first deposition .
ARGUMENT
I. PLAINTIFF'S PRODUCTION OF KEY DOCUMENTS AFTER HER

DEPOSITION NECESSITATES ADDITIONAL EXAMINATION
A. Plaintiff failed to identify her health care providers and produce their
records prior to her depo sition, despite this Court's order
Plaintiff concedes that num erous medical records were not produced until after her May
3rd deposition , to wit:
I --
I
2
Fmt henn ore, there remain nlllllerous doctors from the relevant time frame for whom no
records have been prov ided . In addition to all of the treatment providers from 1999-2002 , no
records have been prov ided by Plaintiff for:
I -
I
I
Menninger Deel., Ex . 0.
Plaintiff, while not opposing the reopening of the deposition for doclllllents produced
after that date, writes to refute supposed "baseless suggestio ns of impropriety ." Yet, her
Response contains additional impropriety. Plaintiff repeatedly asse11s that she has produced and
disclosed doclllllents but her chaii and her arguments neglect to mention that those doclllllents
were only sought and produced after the deposition, indeed up to and including th e very same
day she filed her Respo nse on June 28. Her claim that she could not "remember" Dr. Donohue
or Judith Lightfoot until her deposition is hard to believe given she had consulted with them in
the days and weeks j ust before her Inte1Togato1y Responses. Id .; Ex. D at 334-35 . Fmi her, all of
the 20 15-20 16 medical records from Colorado were only produced because the defense, not
2
Defendan t's Inten-ogatories sought the identities and locations of Plaintiff's health care providers, the dates of
treatment , the nature of the treatment , medical expenses to date, and releases for each. Inexplicably , despite this
Court's Order to answer the inten-ogatory, Plaintiff still has not provided the dates of treatment , the nature of
treatment or any information conceming expenses for any of her providers.
3
Plaintiff, sent a subp oena to Dr. Olson and his hospital for records and then learned that Plaintiff
had been seen by other doctors there and secured a release which the defense sent to Plaintiff.
As detailed more fulsomely in the Reply in Suppo1i of Sanctions filed contemp oraneously, the
late disclosure s were not due to Ms. Giuffre and her attorneys going to "great lengths " to track
down records; they have only responded to reque sts for doctor 's record s when the defense has
brought to their attention missing doctors and records.
Given Plaintiff' s agreement to submi t to questioning based on the late-disclosed records,
it is hardly wo1i h the Comi or counsel 's time to again co1Tect the record as to each of Plaintiff's
misstatement s. In lieu, Ms. Maxwell hereby incorporates by reference her Reply in Supp o1i of
Motion for Sanctions which addresses man y of Plaintiff' s mis statement s concerning production
of her health care provider s ' identitie s and their records.
B. Plaintiff failed to produce emails from her iCloud and Hobnail accounts
Plaintiff objects to fmiher questioning regarding emails from her iCloud and Hotmail
accounts and submit s that Ms. Maxwell 's claims regarding these missing emails "are simply
false" because she ''produced eve1y relevant document from her iCloud account. " Resp. at 8.
Plaintiff ignores the most impo1iant fact: she pro duced them after the depo sition and only after
Ms. Maxwell issued a subpoena to the email providers . The emails were produ ced on June 10,
more than one month after Plaintiff's depositio n . See Mennin ger Deel., Ex. K.
Similarly, following Ms. Maxwell 's subp oena to Hotm~ that compan y has now
confinn ed that Plaintiff has an active account with them and that the account has been used by
4
Plaintiff since the beginning of this case. Plaintiff concededly did not search that account for
responsive documents but has represented to this Court that she will sign the release provided by
Microsoft, obtain the records and search the account. Thus, any responsive emails from that
account likewise will not have been available at the time of Plaintiff’s deposition.
Plaintiff does not argue the responsive emails are not relevant, nor can she. Thus, Ms.
Maxwell should be entitled to reopen Plaintiff’s deposition to inquire regarding those emails as
C.
-
well as any that are produced from the Hotmail account.
Plaintiff failed to address issue of her employment records
In her Response, Plaintiff did not address Ms. Maxwell’s request to reopen Plaintiff’s
deposition regarding late-disclosed employment records. Accordingly, the issue should be
deemed admitted and inquiry into Plaintiff’s employment based on the new records permitted.
D. Newly obtained education records and other witness testimony contradict

Plaintiff’s deposition
Plaintiff testified at her deposition that she began working at Mar-a-Lago during a break
from her GED classes, that she believed it was a summer job, and that while she cannot pinpoint
the exact date, it was to the best of her recollection in or about June 2000 when she was still 16
-
years old. Menninger Decl., Ex. D at 57. This Court ordered Plaintiff to produce her education
records and, mere days before her deposition, Plaintiff signed releases for some of the
institutions she attended in Florida. Defendant obtained records pursuant to those releases after
the deposition (despite having sought them by discovery request in February). The transcripts
from Royal Palm Beach and Forest Hills High School directly contradict Plaintiff’s story. In
fact, they are highly relevant because they show that Plaintiff was in school during the summer
of 2000, finishing on August 15, 2000, when she was 17 years old. Appropriate areas of inquiry
at a reopened deposition of Plaintiff would be matching her story up to the records and
5
demonstrating that she did not sta1t workin g at Mar-a-Lago until she was 17 years old --- despite
her we ll-publi cized claims that she was a "sex slave" for Jeffrey Epstein from the age of 15 years
old beginnin g in 1998 .
Fmt henn ore, testim ony from other witnesses in this case , includin g Plaintif fs fo1mer
boyfriend , materially contradi ct Plain tiff s claim s. -- testified on Jun e
24 that he and Plaintiff were em olled in an all-da y high school and that they atte nded school
together every day and that Plaintiff was not workin g for Epstein. Mennin ger Deel., Ex. P.
Based on th ese newly discove red records, -- confnm ed that time period as October
200 1 - March 2002, direc tly contrad icting Plain tiff s deposition testimony that she was a "sex
slave" for 4 years from 1998-2002 and that she was with Epstein constantly durin g that four year
period .
Based on th e newly discove red education records and other witness testi mony concernin g
th ose records, Ms. Maxwe ll shoul d be entitled to questio n Plaintiff at her continued deposit ion
about those records. Ms. Maxwe ll lacked those records at the time of Plaintiffs depos ition
because Plaintiff refused to produce her education recor ds, Ms. Maxwe ll had to file a Mot ion to
Compel and obtain a Court Order before Plaintiff would sign a release for the records.
Therefore, there is no bas is for Plaintiff to object to a continu ed deposition regar ding the newly
obtained records and witness test imony.
E. Plaintiff identified new witne sses in her Rule 26 disclo sures after her
deposition
Plaintiff does not address the fact that she added 28 new witnesses to her Rul e 26
disclosures after her deposit ion .3 The new witnesses added by Ms. Maxwell to her Rul e 26 list
3
The only mention Plaintiff makes is asking the Court to deny Ms. Maxwell 's motion to strike the new witnesses.
Ms . Maxwell stated that her motion to strike would be by separate motion (Mot. at 10), thus there is no motion to
strike .
6
are almost entirely ones that were taken off Plaintiff’s list. Presumably, they have information
relevant to this case and Ms. Maxwell is entitled to question Plaintiff on these disclosures to
determine what, if any, relevant information these newly disclosed witnesses might have.

RELEVANT, NON-PRIVILEGED QUESTIONS IN HER FIRST DEPOSITION
Plaintiff’s counsel glosses over their instruction to Plaintiff not to answer questions at her
deposition regarding non-privileged issues.
During her deposition, the following exchange occurred:
Q: You did not read the articles published by Sharon Churcher about your stories
to Sharon Churcher?
A: I have read some articles about what Sharon Churcher wrote. And a lot of the stuff
that she writes she takes things from my own mouth and changes them into her own
words as journalists do. And I never came back to her and told her to correct anything.
What was done was done. There was nothing else I can do.
Q: So even if she printed something that were untrue you didn't ask her to correct
it, correct?
A: There was things that she printed that really pissed me off, but there was nothing I
could do about it. It's already out there.
Q: She printed things that were untrue, correct?

A: I wouldn't say that they were untrue. I would just say that she printed them as
journalists take your words and turn them into something else.
Q: She got it wrong?

A: In some ways, yes.
Q: Did she print things in her articles that you did not say to her?
MR. EDWARDS: I object and ask that the witness be given the opportunity to see the
document so that she can review it and answer that question accurately. Otherwise she's
unable to answer the question. I'm not going to allow her to answer.
Q: Did Sharon Churcher print things that you did not say?
MR. EDWARDS: I'm going to instruct my client not to answer unless you give her what
it is that you're talking about that was printed. And she will tell you the answer, the
accurate answer to your question. Just without the document to refresh her recollection
and see it, she's not going to answer the question.
Q: Did Sharon Churcher print things that you did not say?
MR. EDWARDS: Same objection. Same instruction not to answer.
7
Q: Did Sharon Churcher print things that you felt were inaccurate?
MR. EDWARDS: Same objection. Same instruction. If she sees the document, she's
going to answer every one of these questions.
Q: Did any other reporter print statements that you believe are inaccurate?
MR. EDWARDS: Same objection. Same instruction.
Q: Did any reporter print statements about Ghislaine Maxwell that were
inaccurate?
MR. EDWARDS: Same objection. Same instruction.
Menninger Decl., Ex. D at 220-23.
At no time did Plaintiff say she “could not remember” what Churcher “got wrong.” Mr.
Edwards refused to allow her to answer the question unless her recollection was “refreshed,”
even though she never said she lacked a recollection. This is a patently improper instruction not
to answer, as well as improper suggestion to his client that she needed to have a “refreshed”
memory by looking at articles from Ms. Churcher. The instruction not to answer was improper
and Plaintiff should be required to answer all questions regarding inaccuracies in the media
reports of this case. Indeed, it is hard to conceive of an area more directly relevant to this single-
count defamation case in which Ms. Maxwell has said that Plaintiff’s statements to the press
were lies, and now even Plaintiff is saying that the press “got it wrong”.
Plaintiff’s counsel similarly would not allow Plaintiff to answer questions regarding her
communications with law enforcement, specifically regarding Ms. Maxwell. Ms. Maxwell
respectfully disagrees that this area should be off limits. Efforts by a Plaintiff to have another
party charged with a crime, including any statement made during the course of those efforts, are
clearly relevant, reflect bias and motive, and may be used for impeachment. There is no
privilege which attaches to a civil litigant’s prior statements to law enforcement and to the extent
8
any such statemen ts exis t, Ms. Maxwell should be penni tted to inquire regarding the statemen ts
and the circums tances of su1Toundin g their issuance , durin g Plaintiffs reopened deposition .
Ms . Maxwell disagrees with Plaintiffs contention regarding the identity of her expe1i but
agrees not to inquir e into that topic during the reopened deposition in light of the upcoming
expert disclosure deadline s.
fu light of the clearly improper instructions not to answer non-pri vilege d relevan t
questions , Plaintiff s deposition must be reopened.
III. PLAINTIFF CONCEDES THAT HER ERRATA SHEET IS PROPERLY THE

SUBJECT FOR RE-OPENED DEPOSITION
Because Plaintiff concedes, as she must, that changes to her deposition testimony as
reflected on her e1rnta sheet are prop er areas of inquny , Ms . Maxwell perceives no need for
additional argument regarding the materiality of Plaintiff s changes although they were not based
on "misspellings and the like" as Plaintiff avers .
IV. RESTRICTIONS TO TWO HOURS AND VIA VIDEOTAPE UNJUSTIFIED
Ms . Maxwell has identified a significant number of areas of inquir y for reopened
deposi tion and two hours is insufficient to accompli sh that goal. Ms. Maxwell seeks leave to
reopen Plaintiffs deposition regarding belatedly disclosed records from:
• Email records from iCloud and Hotmail regarding interactions with the FBI
• School records regarding the tim e period of 1999- 2002
• 18 newly listed witnesses
• Any published news stories that Plaintiff concedes were inaccurate
• Plaintiff s interactions with law enforcement regarding Ms . Maxwell.
9
All of these are properly the subject of additional inquiry at a deposition and to address
them will require more than two hours. While Ms. Maxwell does not believe that seven hours
will be necessary, she did not use all of the first seven hours based on Plaintiff’s refusal to
answer relevant non-privileged questions and believes that she will be able to finish her
examination on these topics within a reasonable period of time, most likely between 4-5 hours.
Further, such deposition should be done live and in person, not via videotape from
Australia. Video conference depositions are exceedingly difficult and cumbersome when
handling the number of records at issue here – medical records, school records, employment
records and emails, as well as press statements, errata sheets and the like. Counsel will not have
the ability to hand over documents to the witness as needed.
Plaintiff argues that her childcare needs require her to be in Australia. Notably, Plaintiff
has spent several weeks in the U.S. attending in person the depositions of her former fiancé and
boyfriend in Florida (and calling them in advance of their testimony) and, upon information and
belief, attending to other litigation and personal matters. Plaintiff lived in Colorado at the time
she filed this litigation and made a decision to return to Australia after doing so. She and her
counsel failed to disclose relevant doctors and medical records, emails, employment and school
records in advance of her deposition, and she was instructed not to answer relevant, non-
privileged questions. She chose to change her deposition testimony after the fact.
WHEREFORE, Ms. Maxwell respectfully requests a reopened deposition of Plaintiff to
include the topics of:
1. Any documents disclosed after May 3 regarding:

a. Plaintiff’s medical and mental care
b. Plaintiff’s employment
c. Plaintiff’s education
d. Plaintiff’s emails from her iCloud and Hotmail accounts
10
2. Any question she was instructed not to answer regarding:

a. Inaccurate statements attributed to her in the press;
b. Her communications with law enforcement about Ms. Maxwell;
3. Any changes to her deposition testimony as reflected on her errata sheet.
Ms. Maxwell asks the Court to deny Plaintiff’s request that the reopened deposition be
limited to two hours or occur via remote means. Finally, Ms. Maxwell requests costs incurred in
bringing this Motion based on counsel’s improper instructions not to answer relevant and non-
privileged questions.
Dated: July 8, 2016

Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
11
I certify that on July 8, 2016, I electronically served this REPLY IN SUPPORT OF

DEFENDANT’S MOTION TO REOPEN DEPOSITION OF PLAINTIFF VIRGINIA GIUFFRE
via ECF on the following:

mschultz@bsfllp.com
/s/ Nicole Simmons
Nicole Simmons
12
--------------------------
------------------------X
VIRGINIA L. GIDFFRE,
Plaintiff,
V. 15-cv-07433-RW S
GHISLAINE MAXWE LL,
Defendant.
-----------------------
---------------------------X

Reply to Plaintiff' s Oppo sition to Defendant 's Motion To Reopen
Plaintiff' s Depo sition
practice in the United States District Court for the South ern Disti·ict of New York. I am a
member of the law fnm Haddon, Morgan & Foreman, P.C., counsel ofr ecord for Defendant
Ghislaine Maxwe ll ("Maxwe ll") in this action. I respectfully submit this declarat ion in supp o1i of
Reply to Plaintiff s Opposition to Defendant 's Motio n To Reopen Plaintiffs Deposition .
2. Attached as Exhibit O (filed under seal) are ti11e and conect copies of select pages
of Plaintiffs medical records bates labeled GIDF FRE 5089, 5316-18, 6631, designated as
Confidential under the Protective Order.
3. Attached as Exhibit P (filed under seal) are ti11e and con ect copies of excerpts
from the deposition o~ , designated as Confidential under the Protective Order.

Dated: July 8, 2016

Laura A. Menninger
I certify that on July 8, 2016, I electronically served this Declaration Of Laura A.
Menninger In Support Of Reply to Plaintiff’s Opposition to Defendant’s Motion To Reopen
Plaintiff’s Deposition via ECF on the following:

mschultz@bsfllp.com
/s/ Nicole Simmons
Nicole Simmons

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Case 1:15-cv-07433-LAP Document 1090-1 Filed 07/30/20 Page 1 of 4

United States District Court

Plaintiff, Case No.: 15-cv-07433-RWS

Order granting my Application to Appear Pro Hae Vice.

2. I respectfully submit this Declaration in support of Plaintiffs Motion to Compel

Defendant To Answer Deposition Questions Filed Under Seal.

3. Attached hereto as Exhibit 1, is a true and correct copy of page 21 of Defendant

Maxwell's April 22, 2016 Deposition transcript.

Defendant Maxwell's April 22, 2016 Deposition transcript.

Defendant Maxwell's April 22, 2016 Deposition transcript.

7. Attached hereto as Exhibit 5, is a true and correct copy of page 82 of Defendant

Maxwell's April 22, 2016 Deposition transcript.

9. Attached hereto as Exhibit 7, is a true and correct copy of page 51 of Defendant

Maxwell's April 22, 2016 Deposition transcript.

Dated: May 5, 2016.

BOIES, SCHILLER & FLEXNER LLP

Electronic Filing generated by CM/ECF .

Laura A. Menninger, Esq.

UNITED STATES DISTRICT COURT

DECLARATION OF JEFFREY S. PAGLIUCA IN SUPPORT OF DEFENDANT’S

I, Jeffrey S. Pagliuca, declare as follows:

1. I am an attorney at law duly licensed in the State of Colorado and admitted to

in support of Maxwell’s Combined Response to Plaintiff’s Motion to Compel Defendant to

2. Attached as Exhibit A is a true and correct copy of composite pages from

Defendant’s April 22 ,2016 Deposition Transcript.

May 10, 2016 in Denver, Colorado.

By: /s/ Jeffrey S. Pagliuca

I certify that on May 10, 2016, I electronically served this DECLARATION OF

Sigrid S. McCawley Paul G. Cassell

United States District Court

Plaintiff, Case No.: 15-cv-07433-RWS

DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF

2015 Order granting my Application to Appear Pro Hac Vice.

2. I respectfully submit this Declaration in support of Plaintiff’s Reply in Support of

April 22, 2016 Deposition Transcript of Ghislaine Maxwell.

Logs of Jeffrey Epstein’s private planes and summary charts.

July 29, 2009 Deposition Transcript of Alfredo Rodriguez.

Alessi’s November 21, 2005 Sworn Statement.

September 8, 2009 Deposition Transcript of Juan Alessi.

August 7, 2009 Deposition Transcript of Alfredo Rodriguez.

/s/ Sigrid S. McCawley_________

Dated: May 11, 2016.

BOIES, SCHILLER & FLEXNER LLP

By: /s/ Sigrid McCawley________________

Bradley J. Edwards (Pro Hac Vice)

Paul G. Cassell (Pro Hac Vice)

Notices of Electronic Filing generated by CM/ECF.

Laura A. Menninger, Esq.

/s/ Sigrid S. McCawley

UNITED STATES DISTRICT COURT

MOTION TO COMPEL ALL ATTORNEY-CLIENT COMMUNICATIONS AND

TABLE OF AUTHORITIES ....................................................................................................... ii

CERTIFICATE OF CONFERRAL ............................................................................................ 1

BACKGROUND FACTS RELEVANT TO DISPUTE ................................................................. 2

1. Correspondence re: Jane Doe #1 and Jane Doe #2 v. United States.................................... 2

a. The Attorney-Client Privilege .............................................................................................. 7

a. Plaintiff’s Waiver of the Attorney-Client Privilege ........................................................... 10

III. There is No Privilege as to Communications with Scarola ............................................ 22

a. There is no Attorney-Client Relationship .......................................................................... 22