← The Epstein Chronicles
The Epstein Chronicles
Mega Edition: Virginia Roberts Deposition in Edwards and Cassell v. Alan Dershowitz (Part 11-13) (4/11/26)
00:41:38
The videotaped deposition of Virginia Roberts Giuffre taken on January 16, 2016, in Fort Lauderdale sits at the center of the bitter legal war between Epstein survivors’ attorneys Bradley Edwards and Paul Cassell and Alan Dershowitz, who was accused...
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Virginia Roberts
What's up, everyone? And welcome to another episode of the Epstein Chronicles. In this episode, we're going to dive right back in to the Virginia Roberts deposition against Alan Dershowitz. Question. Ms. Roberts, we were talking earlier today about that Joinder motion, and I had given you a copy of this document. Do you still have it in front of you? Jane Doe number three and Jane Doe number four. Corrected motion. Answer this one, Macaulay. Yes. Yes. Turn please, to page four of that document, Macaulay. Hang on one second. I don't think I have a copy here of this for some reason. I know you gave me one. I got it. I'm sorry. Thank you, Borgia. Question in the first full paragraph. If you go six lines down. Let's start five lines down where it says the sentence begins. In addition to. Do you see where I'm reading? Yes. In addition to being a participant in the abuse of Jane Doe no. 3 and other minors, Dershowitz was an eyewitness to the sexual abuse of many other minors by Epstein and several of Epstein's Co conspirators. Do you see that? Yes. Now, where it says participant in the abuse of Jane Doe number three, you talked about your abuse and other minors? Answer yes. Participant yes. Question Participant in the abuse of other minors. Yes. Can you identify any of those minors? Answer. Specifically talking right now, I'm speaking about the girl on the airplane and in the limousine. Question how do you know the age of the girl on the airplane? Answer Like I said before, the they look young, but it's hard to depict exactly what age they are. Question Is it possible that neither one of them was a minor? Answer it's possible that they were, yes, Not a minor. But from what they look like to me, they did look young. Like I said, I can't tell you their ages because I didn't talk to them or ask them their ages. Question. Then it says Dershowitz was an eyewitness to the sexual abuse of. Of many other miners of Epstein and several of Epstein's co conspirators. Do you see that? Yes. Is that something that you personally know? Yes. Dershowitz was around a lot, and Epstein constantly had minors around with him. So to say that he personally knew about the abuse happening with the other miners. I mean, even before Dershowitz and I were personally together, he walked in one occasion in New York, he walked in the. On me providing oral sex to Jeffrey Epstein. I mean, I thought that was very awkward situation, somebody just knocking on the door, walking in, continuing to have a conversation while he's being serviced. So. And then as well, you know, there's, I mean, charades of it. Tons of young girls constantly around for the only sole purpose of having sex with those minors? Question how many times would anybody have to visit an Epstein property to. To be an eyewitness to the sexual abuse of many of the minors, in your opinion? I'm sorry, can you rephrase? I just don't understand what you mean. You say that Dershowitz was an eyewitness. Yes. But you never actually saw him as an eyewitness to the sexual abuse of many of the minors. Is that correct, McCauley? Objection. Answer yes, I did see him as an eyewitness, obviously on the plane and. And in the limousine. Question. But we don't know that those were minors one way or the other. Right Answer Right? Question that's your assumption. Correct Answer yes. McCauley Objection. Question. And you're speculating, right, McCauley? Objection. Special Master, you can answer. Macaulay. Sorry. Answer Yes. I mean, I. SCAROLA interjects Excuse me, I don't believe the witness finished her response. You interrupted her as she was still speaking. Question. So let's leave those two instances aside. Scrolla. May we ask her to please to finish her response? Mccawley, you can finish your answer if you had anything else to say. Special master, I thought you had finished. Do you have anything else to add? There were young girls, and there was constantly young girls that I know were minors around. I mean, only because they were two. Which way too young to even look like an 18 year old. Plus question. Okay, I'm not asking about other girls being around. I'm asking about professor Dershowitz being an eyewitness to sexual abuse with other minors. I'm asking you from the basis of your testimony that you know that he saw sexual abuse of other minors, what's the basis for your testimony, McAuley? Objection. Special Master, you can answer. The only thing that I can say to that is that there were minors around. And did Dershowitz know that Jeffrey Epstein was using these minors for sexual purposes? Yes, he did. How do you know that? How do I know that Dershowitz knew that? Yeah. How do you know that? How I know what he knew? Because he was around Jeffrey Epstein so many times that he would have to be blind to not know what Jeffrey Epstein was doing. So it's your guess as to what professor Dershowitz knew or didn't know, right? Argumentative. No, it's a fact. Did you see professor Dershowitz as a witness to the sexual abuse of anybody you know to have been a minor? Did you personally witness that, McCauley? Objection. With any other. I'm sorry? With any other minors? Did I see him with any other minors? Is that what you're asking me, Macaulay? Objection. Asked and answered. Special master, you can answer. Answer. Besides the two girls that I consider to be very young, but I don't know their ages, No, I have not seen him personally witness sexual abuse in that circumstance. Just the sheer fact that the girls were around and he knew the purpose for the girls being around. Question. What's the basis for your testimony that he knew the purpose for the girls being around Macaulay? Objection. You can answer. Answer. Because Jeffrey used these girls. He didn't have friends. They were 15, 16, 17, 18. Just to hang around with his friends. And like I said, you would have to be blind to not know what he was doing with these girls. I mean, he was arranging massages for other people that I did not witness myself for these girls, and they were minors. So for Dershowitz to be around on so many occasions and. And know that there's minors around. I mean, it's just common logical sense. Question. So you're making an assumption, right, McAuley? Objection. Special master. You can answer. Answer. You can call it an assumption, but like I said, you'd have to be blind to not know what's going on. Question. How many times did somebody have to come to Epstein's property for you to have the same assumption about that person Macaulay? Objection. Special master. You can answer. Answer. I would say the first time they came to the property, there is nude pictures everywhere. These are salacious acts of girls, young girls doing things to each other that would be considered child pornography. If you walked foot into Jeffrey Epstein's house and you went in there and you continued to be an acquaintance of his, then you would have known what was going on in there. Questions. So redacted was in your mind, you believe, a witness to the sexual abuse of minors, McCauley. Let her finish the witness. Thank you. McCauley, you can answer. I don't think redacted participated in anything. That would have to be another assumption. I never saw a witness redacted participate in those acts. But he was in the house of Jeffrey Epstein. I've heard he has been, but I haven't seen him myself, so I don't know. You've seen redacted with Jeffrey Epstein, right? Answer. At parties, Macaulay? Objection. Borgia. Question. So is it your assumption that she's a witness to sexual abuse of minors, Macaulay? Objection. Special master, you can answer. Answer. I don't know if redacted was at the house of Jeffrey Epstein. I know she was at parties with Jeffrey Epstein. So, no, I can't say. She's a witness. Question is redacted. A witness to the sexual abuse of minors McCauley. Objection. Answer. Yes, he would be a witness because he knew what my purpose there was for Jeffrey and he visited Jeffries Island. McCauley, please let her finish her answer. Answer. There's pictures of nude girls all around the house, at all of his houses. And it's something that Jeffrey wasn't shy about admitting to people. Question is redacted. A witness to the sexual abuse of minors, Macaulay. Objection. Answer. Not that I'm aware of. I mean, if you're going to say, why was I there with an older man, then I guess, yes, she would be. But do I believe that she took presence and anything like that? Absolutely not. I can't say. I'm not on grounds to say that. Question. Some people you'll assume and some people you won't. Macaulay. Objection. Answer. Some people, I would say, are closer to Jeffrey than others. Did I see redacted Hang around Jeffrey as as much as Alan Dershowitz. No, I didn't. But Alan Dershowitz was around all the time, so I would definitely say that he was a witness to it. Question is redacted. A witness to this abuse of those minors? Answer. You'd have to tell me who redacted is. Question is redacted. A witness to the sexual abuse of minors. Answer again. He wasn't around all the time. I only met him once, so I can't say that he is thereupon. VR defendants exhibit number seven was marked for identification. Question. Ms. Roberts, you have what's been marked as exhibit seven in front of you. Answer. Yes. Question. This is the Daily Mail article titled teenage girl recruited by pedophile. And it goes on. Do you see that? Answer yes. Question. Can you turn to page 3 of 31 of this printout? Do you have that Yes, I do. Question Right above the photograph there, it says, virginia disclosed that redacted. Were also guests of Epstein on the island. Do you see that? Yes, I do. Is that a true statement in the article? Is it a true statement that I did meet Redacted. But I cannot 100% lock down that it was at the island. It could have been New York. Did you tell Ms. Churcher that it was on the island? I did tell Ms. Churcher that I thought it was on the island and this is how it was printed out. Question. Is redacted. A witness to the sexual abuse of minors. Answer. I don't know. So I can't say that he is or he isn't. Question. Do you know who he is? Answer. I know who he is. Question. Do you know how often, if ever, he was at Epstein's property? Answer. I was never there as an eyewitness to see that. Now, you refer to nude pictures a second ago. Do you recall that? Answer yes. Question. Start in the little St. James Island. Where in that property were there nude pictures? Answer. So there was nude pictures? I don't know how to explain it. You've got a main house? I don't know. Have you seen pictures of the island? Question. Can you just describe it as best you can? Answer. Well, in the main house, not attached to Jeffrey's room, there's a. I don't know if you want to call it an entertaining room. It looks like a living room, but it's bigger than that. It has couches, a TV and everything. Like that in there. There's nude photographs all over that room. There's nude photographs. Adjacent to the right hand side is Glenn Maxwell's office. There's nude photographs in there. Away from the house, in Jeffrey Epstein's private bedroom. There are nude photographs in there.
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Virginia Roberts
Question in these locations where there is nude photographs, is that where Epstein's guests typically go? Macaulay? Objection. Are you referring this one house or to all the houses? Question that's what we're talking about. Answer. The main house. Macaulay, Right? Answer Right outside the main house is the main dining table. So in order for you to get to the dining table, I mean, you could walk from outside. But considering if you're coming from inside to outside, yes, you would have to cross those. Question so did guests of Jeffrey Epstein typically see those nude photographs to the best of your understanding? Answer to the best of my understanding, yes. Question where were those nude photographs in the Palm beach house? Answer as soon as you walked into the front door, there was a large hallway table. And I would assume, my assumption is there is at least 50 photographs on that table, some with nude photographs, some with girls and raunchy. Forgive me, when I say raunchy, I mean lingerie photos mixed in with Jeffrey and some of the privileged people he's met, such as, you know, I don't know, like his old girlfriend or a model or redacted or whatever the case is. But among all those photographs would be nude photographs. Question and when you say, was it in the front room or the front table? Answer. Like I said, as soon as you walk through the front door of the mansion, the first thing you see is the hallway table. On that hallway table, is there. Question. And the front door that you're referring to, is that the one the guests walk in? Answer yes. And also upstairs to Jeffrey's massage room, there's a Hidden room where nude photographs from the floor to the ceiling, all. All over. Right. So there's not one place of white showing. Question. Let me ask you about that. Answer. And then there's boxes and boxes and boxes of nude photographs. Question. You say this is a hidden room. What do you mean by that? Answer. It's not a room that you could just walk in and see. It's something that Jeffrey would show you. So in the massage room, you've got the shower, the steam shower, the massage table in the middle and to your bed, or my bad, left and right. If I was facing this way, it would be my left. It's like a closet, top to bottom, with nude photographs. Is this a place that the guests typically went if you're having a massage? Yes. Did all guests get massages in this hidden room? I can't say that all guests did. Is that where Professor Dershowitz massage was? Answer yes. All right, we're going to wrap up right here. And in the next episode dealing with the topic, we're going to pick up where we left off. All of the information that goes with this episode can be found in the description box. What's up, everyone? And welcome to another episode of the Epstein Chronicles. In this episode, we're going to pick up where we left off with the Virginia Roberts deposition against Alan Dershowitz. Question where were the nude photographs in New York? Answer. In New York. So you would have to go upstairs, make a left into Jeffrey's office, All over the table. Sorry, can I go back to Palm Beach? I forgot another place. Macaulay. Yeah, you're allowed to finish your answer, Virginia. Back to Palm Beach. There was. So you walk into the front door and I told you about the table. And again, I'm bad at left and right. But if I'm facing the door this way, you make a right. And there's Jeffrey's desk and then Ghislaine's desk. And all over their desks were nude photographs. All over the computer. Like, you know, the screen pages that you get pop up nude photographs on this as well. So I just wanted to mention those. And outside the cabana. Sounds horrible. Outside by the cabana, by the pool, there's more nude photographs. Question. And these are all locations where guests would be. Answer. Yes. Question. And it was frequent that guests would have had the opportunity to see these as they were going through the house. Answer. Yes. If you walk through Jeffrey's house, there is not a chance that you could not see nude photographs. Question. Were the photographs ever changed or taken down when Guests were there? Answer no. Like I said, he was not ashamed. Question. Were there also nude photographs in New Mexico? Answer yes, but more in his. Like, I guess you would call it an office. It's not like Florida where you just walk in and you see it right there. It was more. You'd have to go into his office to see them. I'm just trying to recollect. There was some by his bedside table. And I honestly think that's all I remember seeing them around the New Mexico house. Question. Did guests go by Jeffrey's bedside table? Answer Sometimes. If there was something was happening. If you were just a visitor for a dinner party, for example. Answer no. If you were there for a dinner party, you wouldn't go into his bedroom. Question. If you were just a guest for a dinner party in New Mexico, would you see nude photographs in getting to the dining room? No. I don't think we finished New York. Did we? Answer. You tell me. I don't think we did. I think I skipped from telling you about New York and went back to Palm Beach. So should I touch back on New York? McAuley, finish your answer. Yes. Answer. New York. So there was pictures on his desk in the office and around that room. And then there's this room that I refer to as the dungeon that had a huge photograph of me and another girl. I mean, huge, as in bigger than the wall cabinet. There's a painting of both of us doing salacious acts together. Question. Salacious acts? Answer. Sexual acts. You know what I'm saying? Mr. Scrolla, could I request that the camera pan to above Virginia so as to show the wall cabinet and then come back down, if you would, please? Thank you, Ms. Borgia. Question now, the Dubens, they visited Jeffrey Epstein's property, correct? Answer yes. Borgia. Question Redacted. Answer Yes. Redacted. Question. And the children would see these nude photographs in the property? Answer yes. Question. And both parents would Answer yes. Question. Were there other children that saw these nude photographs? Answer. I mean, if you're talking about minors, then yes. Question. When you saw Alan Dershowitz visiting Jeffrey Epstein's properties, did you ever see his wife? Redacted. Answer no. Question. Did you ever see his grandchildren? Answer no. Question. Do you know whether they were there or not? Answer. I don't know if they were there, but I did not see them. Question. Now redacted. Is somebody that was at Jeffrey Epstein's property correct? At least at 1? Answer yes. Question. Which property was that? Macaulay. It's previously. She's a childhood victim. We're objecting to a line of testimony regarding details about sexual encounters with. Redacted. If you know if she was in a location, you can state that, but you don't have to give details. Special Master, she's asking only the location at this point. Answer by Virginia. I'm just looking out for. She was a victim. Yes, she was. At all of his residences. Question. Did her mother ever come visit any of the residences? Answer. I never met her mother. Question. Do you know whether her mother died or whether her mother did. Excuse me. Answer. I don't know. Question. You ever. You never met? No. Question. How much were you paid for the massages? I'm going to. Just give me a moment. This is one of the areas that Judge lynch quashed discovery on. I know you've made a ruling on that, but I want to make my record. He made a ruling that she did not have to go through a renumeration of funds as a result of the activities she was forced to participate in. That's not the request. Special Master, Let me take a look at this. McCauley. Sure. That was question 20, and he quashed that. Ms. Borgia, can you tell me which TUM request you're saying this in? McAuley? I believe it's request 20. All documents showing any payments of any kind made by Epstein or his agents or associates to you from June 1999 to December 31, 2002. Ms. Borgia, I'll ask another question. You've made statements that you were paid $200amassage, correct? McCauley? Objection. Same. Objection. He did not make or produce documents or have any testimony regarding the payments that she received. Special Master, do you have a statement particularly you're referring to? Ms. Borgia, you were paid for sexual services by Jeffrey Epstein, right? Yes. Did you pay taxes on those? Answer. No. Question. Why not? Answer. It was a cash payment. Question. You were a waitress at the Roadside Grill, right? Answer. Yes, for a short time. Answer. Did you pay taxes on that? Answer. Not that I know of. No. I don't think I've ever paid taxes in the U.S. question. And you haven't paid taxes since you returned? Answer. I haven't worked here since I returned. When you got the 160,000 for the media deal, you didn't pay taxes on that, McCauley? Objection. Go ahead. I did pay taxes on that in Australia, but not in the US it was given to me in Australian money, so I paid for it in Australian taxes. When you worked at Mar a Lago, did you pay taxes? No. I was only there for a very short period of time, max. Maybe pulled in two paychecks. So no, I think at a young age. I think there's an example. If you're 15 or something like that, you don't have to pay tax. That's what I heard. I'm not too sure if that's correct or not. But no, I didn't pay tax on it. Question what was the last grade that you completed in school? Answer I believe it was the 9th grade. Question, did you ever complete your GED? Answer I attempted to complete my GED but I never did. And over what period of time did you receive payment for any sexual acts? McCauley. Same objection that I had before. Special Master, you can answer. Answer. From 99 to 2002 until when? In 2002. Until you left? Yeah. Even after I left, Jeffrey sent me money in Thailand Western Union just to help pay for my school that I was being sent to and my living expenses. Question how long were you in Thailand? Answer. I believe I was there from September. I can't remember the exact date in September, but let's just say early September. And then after I married my husband, we went on a honeymoon. I think I came to Australia. I think it was November. Borgia, I don't want to take a lot of time. I don't know why I'm not putting my hands on this document right now. I'll just have it marked and give you the original thereupon. VR defendant exhibit number eight was was marked for identification. Ms. Borgia, I'm going to read you. I'll hand it to you in a second. Read you the document that's marked as VR exhibit number eight and it says at page three of 29 Epstein, Wall Street's money manager, who once counted, redacted and redacted amongst his friends became the subject of an undercover investigation in 2005 after the stepmother of a 14 year old girl claim she was paid 200125 pounds sterling to give an erotic massage. Do you see that? Answer. What paragraph is that on? Question. Top of the page. Answer. However, he avoided trial. Yeah, yeah I do, Macaulay. So I'm objecting as to any testimony regarding payment to you if it's a payment to someone else. Special Master. Right now the only question pending is do you see that paragraph? Ms. Borgia? Was that a standard payment for massages by Jeffrey Epstein McAuley? You can answer that. Yes, it is. What's the basis for your testimony in that regard? It was the basis for my Testimony. How do you know that's a standard payment? Are you trying to trick me into another question? I have an objection to this line of questioning. I mean, I do. I have an objection based on a quash. If the article references a payment and you're familiar with that payment. Borgia. Council speaking. Objections are not appropriate. McCauley. I'm making an objection for the record. Special Master. Hang on. Finish making your objection. Try not to instruct the witness during the objection. Okay, you can answer the question. Answer. So you can repeat that question for me. So, Special Master, go ahead and repeat it off the record so we get the exact wording. Answer Yes, I do. Question. What's the basis for that statement? Answer. That's what we were given. Question who is we? Answer. Any of the girls that had to serve as Jeffrey. I'll speak for myself alone. Question. That's per massage. Answer yes. Exhibit number nine was marked for identification. Borgia. Ms. Roberts, I have handed you the document that's been marked as VR Exhibit 9, which is a declaration of Virginia Roberts. Answer. Yes. You've seen this document before? I've seen a lot of documents, but yes, I have seen this. Question. Page six, please, Macaulay. Is there a copy for me, Borgia? Do you have one? Scroll. No. Thank you. Page six. Is that where we are, Borgia? Yeah. Paragraph 20. You say here in your affidavit. Dershowitz was so comfortable with the sex that was going on that on one occasion he observed me in sexual activity with Epstein. Do you see that? Answer. Yes. Question. And that's the same event that you testified earlier, where you testified that Professor Dershowitz walked into Jeffrey Epstein's private bedroom. Answer yes. Question. And we talked about the six instances earlier today. And? And I believe you've indicated that they were at six different locations. Correct? Answer. At least yes. Question Are there any other instances that you recall? Answer. Not off the top of my head. Question. Think about it. I want your best testimony today before we leave. Answer. All I can remember right now at this time is these approximately six times. Question. Why didn't you mention the limousine in your affidavit, Macaulay? Objection. To the extent that this pertains to a conversation you had with your lawyers, she can't reveal that. Anything else she can reveal. Special Master. You can answer. Macaulay, if you can answer without talking about what you discussed with your lawyers. Answer. At the time, I wasn't asked about it. And it came to me while thinking about it later on. Question. When did it first come to you? Answer. I Don't know the exact date or time. Like I said to you earlier, it's. Trust me, this is not stuff you want to remember. This is stuff you want to try and throw away in the back of the garbage can in your head. And it took me a long time to be able to do that and move on with my life. And when Jeffrey got away with everything that he gotten away with, it infuriated me. So then I wanted to do something about it. In which is why I started thinking about the things more and more and more. And sometimes the more and more and more I thought about it, I. The more I would remember certain occasions. Question. But you didn't remember the limousine as the time of the affidavit? McAuley. Objection. Special Master, you can answer. Macaulay, you can answer. Answer. Apparently not. Question. Have you ever told anybody about having sex in the limousine with Alan Dershowitz? McAuley. Outside of your lawyers? Answer. Outside of my lawyers, no. Question. Did. Did you ever tell your lawyers, McCauley? Objection. I'm not going to have her testify as to what she told her lawyers. Special master, we're not going to allow that. Ms. Borgia, is your privilege, the attorney client privilege? McCauley. She's not waiving her privilege. Counsel, can I make a record? Special, you've said go ahead and make your record. You hold the privilege. You. You're the decider. The attorney client privilege belongs to you. If you would like to waive it, you have the opportunity to do it. I decide not to waive my privilege at this time. Thank you. She would really like to be able to give you the answer to that question. Borgia council, I would appreciate. All right. I couldn't resist. This is not a game. This is not a joke to the witness or to the attorneys who are here for the correct purposes. So please don't make this a joke today. Special master, let's move on. Scarola, I absolutely agree with you. It is not a joke. Special master, let's move on. I understand. Let's move on. All right, we're gonna wrap up right here. And in the next episode dealing with the topic, we're gonna pick up where we left off. All of the information that goes with this episode can be found in. In the description box. What's up, everyone? And welcome to another episode of the Epstein Chronicles. In this episode, we're picking up where we left off with the Virginia Roberts deposition against Alan Dershowitz. Borgia, Question. Did you ever tell anybody other than your lawyers ever about your allegation that you had sex in the limousine? Answer. I've spoken with my husband a. About the times and experiences that I had with Dershowitz. Question. Including the limousine? Answer. Including all the times that I can remember that I've told him. I mean, he's my best friend, so. Question. So this affidavit was signed November 20, 2015, so around this past Thanksgiving. So you first remembered it since Thanksgiving? Answer. Yes. Question. So since Thanksgiving, have you had conversations with anybody about the allegation? Answer. Other than my lawyers, no. I mean, the only other person that would know anything about this would be my husband. But I mean, it's only because recently we've just been dealing with a lot of this. Question. How long did that sexual activity in the limousine take place? Answer. Not long. Question. What happened? Answer. You want a description? Answer. I would like to know what happened. And in that limousine, that is the abuse that you're alleging happened? Answer. Jeffrey instigated it. The men pulled out there. The wording for this is just anatomy. They pulled out their anatomy, their genitals, and we were told to perform oral sex on them. Question. There was no discussion between the gentleman beforehand that you heard? Answer. You know, I don't know the exact terms that they used during the time, but Jeffrey insinuated it and Allen agreed to it. So, yes. Question. The time on the plane where you allege that you and another female participated in sexual activity, was that at the same time, Macaulay? Objection. Answer. What the girl and me and Jeffrey and Dershowitz, was that, like, altogether? Question. Tell me what happened on the plane? Answer. It went from Macaulay. Just use your best terms. You can take your time. Virginia. Sorry. It wasn't from giving foot massages, which is a normal thing to do, that we would do on the plane to Jeffrey again insinuating, you know, we should. Him and Alan, we should kind of do this. I don't know their exact wording, so I'm not going to put words in their mouth, but it went from foot massages to oral sex to intercourse. Question. So who was involved? I mean, you were sexually involved with professor Dershowitz, correct? Yes, it was kind of, to be honest. It was. Use a term that you can use. It was a little bit of a mix and match. It sounds horrible. So at first I went down. Oh, God, I can't believe I'm saying this. At first I gave oral sex to Epstein, and the other girl gave oral sex to Dershowitz. And then we swap within, I would say, seconds, like 60 seconds to a minute, we Were told, you know, the. They wanted us to get on top. So we mounted them and we straddled them and we performed intercourse on a bed in the airplane. Question the foot massages. Who gave who foot massages? Answer I believe I was giving Jeffrey a foot massage and the other young lady was giving Dershowitz a foot massage. Question Anything else happened during that flight? Answer after the sexual experiences, which is what I had been trained to do anyway, which was not out of the ordinary, I went back to the back of the plane, got washcloths, and proceeded to clean Jeffrey and Dershowitz up with a warm washcloth. Question during this activity, were condoms used? Answer no. Question Were condoms ever used with Professor Dershowitz? Answer no. They weren't used with any other people as well. Question Were the other people that you were sexually trafficked to? Answer no. Question. Did you ever ask to use a condom? No. I mean, Jeffrey had us tested quite regularly, so we knew we were clean. You've never had any sexually transmitted diseases? No. Question where would you get tested? At a doctor. To be specific, a gynecologist. Question who is your doctor? Answer, A gynecologist in Palm Beach. Question who is that? Answer, I have no idea. Were you ever hospitalized during 99 to 92? Answer yes. Question for what? Macaulay? I object to the extent that this gets into private medical discussions. I don't think that she has to do that in this deposition. Special Master, please answer the question. Answer. To this day, I'm actually confused about the whole situation. If you want me to get into detail about it. Special Master, listen to her question. Answer Yes, I was medically brought to a hospital. Question. For mental health or physical health? Answer physical. Question it didn't have anything to do with a sexually transmitted disease. Is that correct? Answer no, it wasn't a sexually transmitted disease. Question do you know which hospital you were treated at? Answer no, but I know it was in New York. Question Were you admitted into the hospital to stay, or was it you went to the emergency room and they let you out the same day after? Answer I was admitted to the emergency room, and I think I stayed two days. It could be more, it could be less. I know they heavily sedated me. I'm not too sure. Question Were you given any medication as a result? Answer yes. Question what were you given? Answer I don't know. I mean, I'm a young kid. I didn't know the medication or the terminology or anything. I think it was some kind of antibiotic. Question. You weren't given any sort of pain reliever. Answer, yeah, I was given pain relief at the hospital. I think I left the hospital with the antibiotics. Question do you have a book agent? Answer, what's a book agent, McCauley? Objection. Borgia. Somebody to help you negotiate a book or a media contract. Objection by McCauley. This is again one of the requests that Judge lynch quash relating to their inquiry and their subpoena as to communications with. It's actually two of them. He quashed nine communications with media. He quashed 17 communications relating to potential book deals, etc. It's absolutely relevant as to whether or not Professor Cassell and Mr. Edwards were defamed by Professor Dershowitz is what this case is about. It's not about any media inquiries or any book deals or anything of that nature. Special Master. And your position? Borgia. This is a discovery deposition. This may lead to discovery of admissible evidence. And I understand that this witness doesn't want to provide this information, but we can pursue it from third parties. And blocking us in this way is inappropriate. I simply asked for the name of an Agent McCauley. So they lost in front of Judge lynch and now they're trying to win here. I mean, it's totally inappropriate. He ruled in our favor. I have a motion to quash and she shouldn't have to be forced to testify as to these items. Special Master. And your question is whether she has a book agent. That's the question. Borja. Right? Special Master. I think you can answer that question. Answer, well, I don't have a book deal, but I have looked into getting a book agent. Special Master, do you have a book agent? Is the question. Answer not at this time, no. I did at one time. Question when did you have one? Answer back in 2012, maybe the end of 2011. Question who was that? McCauley. Again, I object to all of this testimony. We had a motion to quash on this. We won the motion to quash for the reasons we argued in court in front of Judge lynch. And the testimony is not appropriate. Special Master, you can answer the question if you know the person's name. Answer, his name is Gerard. Answer, who does he work for? Answer, I don't know the name of his company. He was just a small time guy. He worked with rappers before. That's about all I know. I don't know if we even actually signed anything saying he was my agent. He said he was interested. He read the stuff by Sharon Churcher. I think he was going to represent me if a book ever came out or if a book deal ever happened and nothing ever happened, so he's not representing me. Question the did you ever tell him about Professor Dershowitz? Answer no. Question. Why not? Answer because we didn't even talk in lengthy discussion about that. We mostly talked about if we were going. I mean, it's mostly about the sickening discussions. The ordeal that Epstein got away with. So many counts of maliciously hurting minors and he got away with it. That's more my idea of where I was going if I ever write a book. Question do you have an agreement or understanding with boys Shiller regarding what would happen if you did receive the monetary amount from redacted McCauley? I'm going to object to this. This gets into the relationship that she has with our firm and that's attorney client privilege. You don't answer to respond or need to respond to any of that. Special Master. I'm going to grant that motion. Borgia, did you receive a payment of 10 or 15,000 after you claim that you had sex with redacted McCauley? Objection. It gets into one of the quash motions in one of the questions. Mr. Scrolla. Also I don't understand the scope of the question. From whom for what did she ever get 10,000 or 15,000 in the last years? Unrelated to this case? The objection is over. Broad, vague and confusing. Special Master. Put a time frame on a council and then I'll see. Question 2011. You were paid 10,000 to 15,000 by or on behalf of Jeffrey Epstein for having sex with redacted. Answer 2011 question I'm sorry, 2001 answer. Is that granted? Special Master. I didn't make a determination yet. McCauley. Same objection. Virginia. Sorry. Special Master, I'm going to allow the question. I'm going to overrule the objection. You can answer if you know. Yeah, I received 15,000. I don't know what the equivalent is to that in pounds. I received it in American dollars. I did receive 15,000. I do not know the equivalent to what that is in pounds. And you didn't pay taxes on that? No. When did you first retain Paul Cassell as your counsel? McCauley, you can give the date, but you can't get into discussion you had with Mr. Cassell. Special master. That's the question. Answer I don't know the exact date. I'm sorry. Question what's your best estimate? Answer Well, I started talking to Brad in the fall of 2011, but I never met him personally. Until 2013, I think. So I don't know When I officially became their client. Question when do you consider that you became their client? Was it when you first met them? Answer. Personally, like face to face? Question I'm asking you the questions. I'm not suggesting that's the answer. Answer no, that's why I'm asking you when I talk to them on the phone or met them face to face. Question do you consider when you met them face to face as being the first time that you engage them or some other time? Answer I believe when we first met face to face is when I became their client. I think that's right. Question when did you first meet Brad Edwards face to face? Answer the same time that I met Paul. I think it's 2013. Question whenever it was, that's when you engaged him to be your lawyer in your mind? Answer well, in my mind it could have been 2011 when we started talking. I don't officially know. I really just trying to answer you honestly, if possible. Question. But your understanding is when you met them, you wanted them to represent you? Answer oh yeah, I wanted them to represent me from 2011. I just wanted to be part of the CVRA case. I wanted my story to be heard and I wanted to help other victims out there. So, yeah, Scrolla. I'm going to observe that. I think There are about 15 minutes left on the four hour allocation and I would like some time for examination of the witness. Special Master, there's actually how much? Seven. Scrolla. Seven minutes left. Did not cross notice this. So if council wants to give you time, that would be up to council. I don't know that it's necessary for me to cross notice the depot. Special Master, hang on one second. We have seven minutes. Let's spend it wisely. Counsel is not finished with her examination, so she's entitled to complete her examination. But before handing it off, Macaulay, I'm comfortable allowing her four hours. And then if you have some questions, we can deal with that. All right, folks, we're going to wrap up right here and as you can see, we're getting right down to the finish line. And in another couple episodes, we'll be crossing that finish line. But until then, all of the information that goes with this episode can be found in the description box.