Latest / The Vault: The Epstein Files / Mega Edition: The Virginia Roberts Deposition That Helped Expose Epstein And Maxwell (Part 1-3) (7/11/23)
Transcript
- 0:00Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
- 0:04In today's episode, we're going to begin our look at
- 0:08the Virginia Roberts deposition that was given on May third
- 0:13of two thousand and sixteen. And during this deposition, a
- 0:18lot of it was handled by Laura Meninger, who was
- 0:21the lawyer for Glen Maxwell at the time, so she's
- 0:24going to be asking the bulk of the question. However,
- 0:27she is also joined by Jeffrey Pagliuca, So if Jeffrey's
- 0:32asking a question, I'll say that it's Jeffrey who is
- 0:35asking the question. But besides that, it's going to be
- 0:39Laura Meninger doing all of the question asking, and then
- 0:42Virginia Roberts obviously will be answering the questions. So enough
- 0:47with the explaining and let's get to doing. Miss Meninger.
- 0:51Good morning, Miss Jeoffrey. Response, Good morning, Laura. Question by
- 0:56Laura Meninger. Can you please state your full name? Answer
- 1:00Virginia Lee Jeoffrey. And where do you live right now?
- 1:04Miss Jeoffrey redacted? Next question, All right, and who lives
- 1:09with you? Virginia responds my son, my other son, my daughter,
- 1:14my husband, and my in laws. Menager, When did you
- 1:17return to the US for this visit? Virginia? I believe
- 1:22it was around Thursday, the twenty ninth, I think, menager. Okay,
- 1:26And who traveled with you? Virginia myself? Yourself? Virginia responds yes.
- 1:34Manager says are you able to travel freely between the
- 1:37US and Australia? Virginia responds yes. Next question, are you married?
- 1:43Virginia's response yes, Next question to whom response redacted? Next question,
- 1:51all right, and did mister Joffrey travel with you back
- 1:54to the US? The answer no? Question all right? Have
- 1:59you taken medications in the last twenty four hours? Response?
- 2:04I have taken I have a cold, but I have
- 2:06taken non drowsy cold tablets and some day quill. Question
- 2:10all right? Anything else? Response no question? All right? And
- 2:16what is your current profession, Miss Jeoffrey? The response I'm
- 2:20a housewife? Question all right? And how long have you
- 2:24been a housewife? Response for the last ten years, since
- 2:29I've had kids? All right? And what was your profession
- 2:32in two thousand and four? Response? I was a housewife?
- 2:36Question alright? Any other professions? No? All right? You understand
- 2:41that you're under oath today? Response yes, and you understand
- 2:46that if you don't understand the question, you need to
- 2:49let me know that yes question and ask for clarification. Response,
- 2:56Uh huh question do you understand response yes question, you
- 3:01also understand I'm assuming that you have to say yes
- 3:05or no an answer to a question, or you have
- 3:08to make a verbal response and not just shake your
- 3:11head or something. Response, yes, question so the court reporter
- 3:17can get it you have been deposed before? Correct response
- 3:21yes question. Do you understand what it means to be
- 3:25under oath? Yes? What does it mean to you? Response
- 3:29to tell the truth, the whole truth and nothing but
- 3:32the truth? Question? All right? And what does the word
- 3:36truth mean to you? Response to be honest? Question? Is
- 3:40there more than one truth? Response? Is there more than? No?
- 3:45There's no more than one truth question. If you are
- 3:49confused by a question, you need to let me know
- 3:51so that I can clarify the question. Okay response okay. Question.
- 3:56For example, if I ask you the question where you
- 3:59sexually try to foreign presidents? Do you understand what that
- 4:02question means? Answer? Yes, question what does it mean? Answer?
- 4:07I was lent out for the purpose of sex to
- 4:09a foreign person president? All right? And what is the
- 4:13answer to that question? Answer yes. And if I asked
- 4:17if you had met any foreign presidents, do you understand
- 4:20what that question means? Answer yes? Question what is the
- 4:24answer to that question? Answer yes? Question all right? And
- 4:28if I ask you which foreign presidents have you met?
- 4:31Do you understand what the question means? Answer yes. What
- 4:35is the answer to that question? Answer? What is the
- 4:38name of the person? Question yes? Who are the foreign
- 4:41presidents that you have met? Answer? I honestly can't remember
- 4:44his name at this time. I'm a very visual person.
- 4:47So question all right, can you describe him? Then? Answer? Yes,
- 4:52he's Spanish. Question okay, answer tall, dark hair, question all right,
- 4:57anything else? Answer and he's got a foreign tongue accent.
- 5:02Question what age? Approximately? Age was I? Or was he? Question?
- 5:08Was he? I'd say in his forties? Question okay? And
- 5:12where did you meet him? Answer? I believe it was
- 5:14New Mexico. Question new Mexico? Answer possibly New Mexico. I'm sorry,
- 5:20it's really hard to go back and remember lots of
- 5:23different events with lots of different people. Question okay, and
- 5:27is that the only foreign president that you have met? Answer?
- 5:31I've met a lot of high powerful people, and I
- 5:34wasn't just introduced to them as who they were. It's
- 5:37only going back through photos in time to be able
- 5:40to realize who they are and what they are now.
- 5:43So it's hard for me to distinguish who I've actually
- 5:46met and when and where I've met them. Question, So,
- 5:50to your knowledge, you have only met one foreign president?
- 5:54Answer to my knowledge at this time? Yes. Question. And
- 5:58is there anything else that might change your knowledge at
- 6:00a different time? Answer? If I were to see more
- 6:03photos of other people. I mean, I've been able to
- 6:07distinguish the majority of the people I've been lent out to.
- 6:10But who's to say there's not more question? All right?
- 6:14And if I were to ask you the question of
- 6:17how many times you have had sex with redacted? Do
- 6:21you know what that question means? I believe so, all right?
- 6:25And what is the answer to that question? I believe
- 6:29I was with redacted? Ones question? Okay? I would like
- 6:33to ask you about your prior sworn statement. You understand
- 6:37that you're under oath correct yes, Okay, you've previously made
- 6:42statements under oath correct answer, yes question, and you've previously
- 6:47authorized pleadings to be filed on your behalf correct answer yes,
- 6:52question by various attorneys right answer yes, all right. Have
- 6:57you included in your sworn statement alligations about my client
- 7:01Gallage Maxwell? Answer yes. Question and did you review any
- 7:06of those prior to your sworn statements before appearing here today? Answer? Yes?
- 7:13Question and which ones did you review? Answer? I'd have
- 7:16to see which ones you're specifically talking about. There is
- 7:19quite a lot of statements that I've made. Question right?
- 7:23And which ones do you recall having reviewed before you
- 7:26attended this deposition today? I reviewed my affid David. I'm
- 7:31not a lawyer, so I really don't know legal terms
- 7:34to half of the you know, legal jargon of statements
- 7:37which they are. If you showed me, I'd be able
- 7:39to tell you if I've seen it or not. Question okay,
- 7:43So to your knowledge, can you identify any sworn statement
- 7:46you're reviewed before attending the deposition today? Answer? Could I
- 7:50name what the statement is? Question right? Answer the actual
- 7:54piece of paper that has the title at the top.
- 7:57Question right answer, No, I don't. Question can you describe
- 8:02it in any other fashion? Response? I don't understand. I'm sorry.
- 8:07Question that's all right. You have to tell me if
- 8:10you don't, do you have any other reason to believe
- 8:12that any of your previous sworn statements that you have
- 8:15made or not true. Answer no, Now we have an
- 8:19objection here to by Brad Edwards. I must object and
- 8:23ask that if we're going to ask the witness questions
- 8:25about any of her statements in whole or in part,
- 8:28that the witness be allowed to see this statement, review
- 8:31the statement, and then answer your questions. Question by mismanager,
- 8:36you may answer the question answer can you re ask
- 8:40the question? I'm sorry? Question? Do you have any reason
- 8:44to believe that any of your prior sworn statements are untrue? Answer?
- 8:49I have no reason to believe that my prior statements
- 8:51are untrue. Question has anyone told you to say something
- 8:56that was not true in connection with this case? Answer? No, ma'am.
- 9:01Question all right. I'd like to start with a lawsuit
- 9:04that you filed under the caption Jane Doe versus Jeffrey Epstein.
- 9:08Do you recall the lawsuit? Answer? I believe so. I'm
- 9:13going to show you an exhibit what we are marking
- 9:16as defendants, Exhibit number one. Brad Edwards chimes in again,
- 9:20can I see that for a second. I'd just like
- 9:22to make an objection on the record for the misidentification
- 9:26of this document. While there was a lawsuit filed under
- 9:29the style of Jane Doe versus Jeffrey Epstein, Jane Doe
- 9:33was not Virginia Jeoffrey, and the lawsuit that's now being
- 9:37handed to this witness is Jane Doe one oh two
- 9:40versus Jeffrey Epstein. Is that the document that we're talking about, Mismninger, Counsel,
- 9:46if you have an objection, you should state the basis
- 9:49for your objection in a non leading, non suggestive manner.
- 9:53If you have any other record to make, you can
- 9:55do so in a pleading filed with the court. Mister Edwards, Sure,
- 10:00my objection is you've misrepresented what you've handed the witness.
- 10:04I want to make sure that the witness is holding
- 10:06what you actually want her to be holding, as opposed
- 10:09to the lawsuit you said that you were going to hander.
- 10:12That's it, Miss manager Counsel. I will ask the witness
- 10:16questions about the document. I did not ask you any
- 10:19questions about the document. The questioning now turns back to
- 10:23Virginia Roberts question. Miss Joffrey, could you please take a
- 10:27look at what we have marked as defendants Exhibit number one.
- 10:31Do you recognize that document, Miss Joffrey. Answer I believe so, Yes,
- 10:35I do. Question and do you see that council on
- 10:39the last page I'm sorry, not the last page, but
- 10:42the third page. From the last page are mister Josephsberg
- 10:46and mister Essel from Podthurst or Sek Answer yes, question
- 10:51were those your lawyers? Answer? Yes they were? Question and
- 10:56did you authorize them to file Jane Doe one h
- 10:59two versus Epstein on your behalf? Answer? Yes, I did.
- 11:03Question and is that this complaint that's been marked as
- 11:07defendants exhibit number one? Answer? I believe so. Question in
- 11:12that document? If I could ask you to turn the page, well,
- 11:15I'll turn to page nine and paragraph twenty three. Answer
- 11:20would you like me to read it? Manager responds no,
- 11:25I'm just did you find it? Answer? I can see
- 11:28paragraph twenty three? Question, Okay, do you see that there
- 11:32are other allegations about miss Maxwell contained in that complaint? Answer? Yes,
- 11:36I do. Question all right? And do you understand that
- 11:41to be Glen Maxwell my client? Answer yes, question all right?
- 11:46And Miss Maxwell was not sued as part of this case? Correct?
- 11:51Brad Edwards chimes in object to the form the opponent,
- 11:55does that mean I can answer, mister Edwards, Sure you
- 11:58can answer, Laura man right. Brad Edwards responds, if you
- 12:03understand the question, answer it and to that Virginia response, yes,
- 12:08Miss Maxwell, sorry, repeat the question. The question is then
- 12:12repeated by miss Manager. Was miss Maxwell's suit in this
- 12:16the answer? No, she wasn't. Question in this case that's
- 12:19represented by defendants Exhibit number one. No she wasn't. I'm
- 12:25sorry for interrupting you, but no, she was not sued
- 12:28at this time. No question, and why not? Brad Edwards
- 12:32once again chimes in, I'd object and ask the witness
- 12:35not to answer that question because that would be privileged
- 12:38attorney client privileged information that was between miss Joffrey and
- 12:43Podhurst or SEC firm at the time. So I'm instructing
- 12:46you not to answer, Miss Meninger. All right, Miss Jeoffrey,
- 12:51did you make a decision yourself whether or not to
- 12:53assume Miss Maxwell as part of the lawsuit against Jane
- 12:57Doe one h two versus Jeffrey Epstein. Response, I think
- 13:02I've been advised not to answer that question. Next question,
- 13:06This is a different question, Virginia, Oh, okay, question, So
- 13:11your counsel can assert a privilege but that question did
- 13:14not call for privileged information. Brad Edwards tries to interject,
- 13:18but Menager stops him in his tracks. I'm asking about
- 13:22what you decided to do, whether you decided to ssue
- 13:25Miss Maxwell or not. At the same time, Jane Doe
- 13:28one h two versus Epstein was filed. Edwards again chimes in,
- 13:33and I disagree, and I object to this invading the
- 13:37attorney client privilege, and I am instructing you not to answer.
- 13:42Ms Menninger. Can you answer that question without revealing any
- 13:45attorney client communication whether you made a decision to file
- 13:49a lawsuit or not. Virginia, I'm going to have to
- 13:52listen to my attorney and not answer the question. Question
- 13:56all right, I would like to show you some documents
- 13:58that were filed in what we'll call the CVRA case,
- 14:03the Crime Victims Rights Act case. Do you know what
- 14:06I mean by that reference, Virginia, I'm familiar with that. Okay.
- 14:11I'm going to start with one, Honor about December thirtieth,
- 14:14twenty fourteen. We will mark it as defendants Exhibit two.
- 14:19Exhibit too marked Brad Edwards, thank you, manager. All right,
- 14:23Miss Joffrey, do you recognize defendants exhibit two. Response, Yes,
- 14:29and what do you understand it to be? Response? I
- 14:32believe this is when I was hoping to join the
- 14:35CVRA case. Question all right, and do you know when
- 14:39this document was filed? And actually, just to be clear
- 14:43about halfway, there's actually a second document that was filed.
- 14:47So this is a composite exhibit. Let me be very clear.
- 14:51So after page fourteen I'm sorry, thirteen, there's a second
- 14:55document that is styled Jane Do three and Jane Doe
- 14:58four's correct emotion pursue and to rule twenty one for
- 15:02joinder in action. Do you see that response? Did you
- 15:06say page fourteen? Question? It's on page fourteen of this document.
- 15:11Do you see that response? I do? Question? And so
- 15:15this composite exhibit too has both a motion and the
- 15:19correct emotion. Do you see that? Answer? Yes? Question? And
- 15:23where both of these pleadings authorized by you to be filed? Answer? Yes. Question.
- 15:29In other words, you wanted to join CVRA action in
- 15:33or about December thirtieth, twenty fourteen. Correct answer. I'm not
- 15:38aware of the exact dates. There's no dates on this,
- 15:41but I did try to join that motion. Yes. Question,
- 15:44all right, If you can look at the top of
- 15:46the line of the document. Answer yes. Question does it
- 15:50say entered on FLSD? Answer? Oh, it does too. I'm sorry. Yes.
- 15:56Question that's all right. So does that refresh your memory
- 15:59as to at when you first sought to join the
- 16:02CVRA action? Answer yes, question December thirtieth, twenty fourteen. Correct, yes,
- 16:09and the corrected motion was filed a few days later.
- 16:11Correct yes, correct. Question if I could turn to defendant's
- 16:17exhibit three, which was January twenty first Exhibit three marked
- 16:21mister Edwards, thank you. Question missmanager, do you recognize this document?
- 16:27Virginia responds yes, I do. What do you understand this
- 16:30document to be? Virginia, It's a rough background of the
- 16:34years that I was abused by Glaine and Jeffrey. Question
- 16:38all right, and this is something I believe that you
- 16:41on page fifteen signed? Is that true? Answer? Just let
- 16:45me have a look. Question sure. Answer. I think I'm
- 16:48actually missing page fifteen. Oh here we go. Question, Sorry,
- 16:52I'm looking at the numbers on the top right. I apologize.
- 16:56I believe there was some cover page or something that
- 16:59was excluded. Brad Edwards chimes in, and just for the record,
- 17:03I'm going to object to the relevance of this document.
- 17:06I'm going to allow the witness to answer the question,
- 17:08but I want my objection on the record. Mismanager, Okay,
- 17:12simple objection relevance. Are we talking about this page? Question
- 17:17by mismanager? Yes, the one with the black box. Yes.
- 17:21Do you believe that you have contained your signature? Answer? Yes?
- 17:26Question all right? And you executed that on January nineteenth,
- 17:31twenty fifteen. At the very top of the page it
- 17:34says January twenty first, twenty fifteen. Question the data was filed?
- 17:40Is there a date just above this signature block? Answer? Oh? Yes, sorry,
- 17:43there it is. Question and what date? What date was that? Answer?
- 17:48The nineteenth of January twenty fifteen? Okay, And this document
- 17:53is something that you believe contains the truth correct Virginia,
- 17:58to the best of my knowledge at the time, Yes,
- 18:01all right. Did something change between the time then and
- 18:04today that makes you believe that it's not all accurate? Answer? Well,
- 18:09as you can see in line four on page one,
- 18:12I wasn't aware of my dates. I was just doing
- 18:14the best to guesstimate when I actually met them. Since then,
- 18:18I've been able to find out that through my Mara
- 18:21Alago records that it was actually the summer of two thousand,
- 18:24not the summer of nineteen ninety nine. Manager. Oh, I'm sorry.
- 18:29Are you back on page twelve, Virginia, I'm on the
- 18:32first page, manager, okay, And you're talking about line four, yes,
- 18:38line four Manager, paragraph four or line four Virginia, Oh, sorry,
- 18:43number four? The paragraph number four? Question? Okay? And what
- 18:48part of the paragraph four do you believe to be untrue?
- 18:52And approximately? But right there Brad Edwards steps in and
- 18:56he objects to the form. But you can answer, Virginia.
- 19:01In approximately nineteen ninety nine, when I was fifteen years old,
- 19:04I met Glan Maxwell. Question by Menager, Okay, answer, I
- 19:09now know that it was two thousand, that I was
- 19:11sixteen years old when I met Glan Maxwell. Question. So,
- 19:16when you signed this document under penalty of perjury stating
- 19:19that it was true, you no longer believe that it
- 19:21to be true, Virginia. It was an honest mistake. We
- 19:25had no idea, had a pinpoint, without any kind of
- 19:28records or dates or anything like that. I was just
- 19:30going back chronologically through time and that's the best time
- 19:34that I thought it was. And now I know the facts,
- 19:37So it's good to know question. So you now believe
- 19:41that a document you filed under oath is no longer true?
- 19:45Edwards again, Objects object to form Virginia, I wouldn't say
- 19:49that it wasn't true. I was just unaware of the
- 19:52times and the dates. Menager again, is there more than
- 19:56one truth? Miss Roberts answer, no, there's no more than
- 20:00one truth. Question all right, So a document in which
- 20:04you swore that you were fifteen years old when you
- 20:06met Glaine Maxwell is an untrue statement? Correct Edwards objects
- 20:11again to the form Virginia. It's not that it's an
- 20:14untrue statement. It was a mistake. So it wasn't intentionally
- 20:17trying to say something that wasn't true. It was to
- 20:20the best knowledge that I thought it was nineteen ninety nine,
- 20:23and when I got my records from mar A Lago,
- 20:26I was able to find out that it was two thousand,
- 20:29and this was entered before I found out the actual
- 20:32dates that I did work at mar A Lago. Manager. Okay,
- 20:36so a document that you filed under oath, Virginia, Uh huh, Manager,
- 20:41is now you believe to be untrue? Not? Correct Edwards again,
- 20:46Objects asked an answered, Manager, you may answer, Edwards answer again, Virginia. Again,
- 20:53I wouldn't say it's untrue. Untrue would mean that I
- 20:56would have lied, and I didn't lie. This was my
- 20:59best knowledge at the time, and I did my very
- 21:01best to try to pinpoint time periods going back such
- 21:04a long time ago. It wasn't until I found the
- 21:07facts that I worked at mar A Lago at two
- 21:10thousand that I was able to figure that out, Menager.
- 21:14And approximately when did you learn those facts about the
- 21:17dates you worked at mar A Lago, Virginia. I would
- 21:20say it was about mid twenty fifteen, Menager. Mid twenty
- 21:25fifteen is the first time you became aware of the dates, Virginia.
- 21:29I don't know the exact Menager interrupts her. If you
- 21:32could just let me finish, Virginia apologizes, I'm sorry, Menager,
- 21:36that's all right. Approximately mid twenty fifteen when you learn
- 21:40the true dates that you had worked at mar A Lago, Virginia.
- 21:44That's correct. Sorry, And based on the fact that you
- 21:47learned you had worked at mar A Lago in two thousand,
- 21:50you became aware in mid twenty fifteen, Virginia, Uh huh,
- 21:55question that you had met miss Maxwell in two thousand, correct,
- 21:59answered sure, that's again cut off by Bradley Edwards objective form.
- 22:05Virginia then answers, that's correct. All right. We're gonna wrap
- 22:08up with the first episode here and in the next
- 22:11episode we're gonna pick up with part two. All of
- 22:15the information that goes with this episode can be found
- 22:18in the description box. What's up, everyone, and welcome back
- 22:22to the Epstein Chronicles. In this episode, we're gonna pick
- 22:26up where we left off with the Virginia Roberts deposition.
- 22:30So let's just dive right back in. Menainger, okay, and
- 22:35who provided you those mar a Lago records in approximately
- 22:39mid twenty fifteen. Edwards once again objects. I'm going to
- 22:44object and to the extent that this invades the attorney
- 22:48client privilege. If it was your attorneys that you spoke
- 22:51to and learn this information or receive this information from,
- 22:55then you're instructed not to answer. Virginia, I cannot answer
- 22:59the question, menager, did you yourself look at records in
- 23:05the middle of twenty fifteen, regardless of who showed them
- 23:08to you? Mister Edwards objection, and to the extent that
- 23:12they were showed to you or shared by any of
- 23:14your lawyers you're instructed not to answer the question. It
- 23:18invades the attorney client privilege. Menager again asked, did you
- 23:22look at the mar A Lago records in the middle
- 23:24of twenty fifteen yourself? Edwards, She's not answering the question, Menager.
- 23:29On what grounds is she not answering the question? Edwards?
- 23:33I just told you it invades the attorney client privilege.
- 23:36If she learned, I will instruct her. If she learned
- 23:39by some other way than by her attorneys sharing the
- 23:42information with her, then she can answer the question. Menager,
- 23:46I'm asking you not to tell me whether your attorney
- 23:49showed you the record. I'm asking you not to tell
- 23:52me the source of the record. I'm asking you if
- 23:55you personally in the middle of twenty fifteen looked at
- 23:58mar A Lago's records, Mister Edwards, same objection, same instruction. Manager.
- 24:04I'm going to show you an exhibit filed on oh
- 24:07I believe on or about February sixth of twenty fifteen, defendants,
- 24:12Exhibit number four, Exhibit four marked Brad Edwards. Thank you, manager,
- 24:18and drawing your attention to the heading that says entered
- 24:21on the docket February sixth, twenty fifteen. Do you see that?
- 24:25Answer yes, question all right? And declaration of Jane Doe three.
- 24:29Do you see that on the first page? Answer yes.
- 24:33Question and it's the CVR case, correct, Jane do one
- 24:37and Jane Do two versus the United States of America.
- 24:41Answer yes, Manager, all right. And do you recognize this
- 24:45document Virginia? Yes? And what do you understand this document
- 24:49to be Virginia answers. I believe it's more reason to
- 24:53why I should have been added to the CVR case.
- 24:57Edwards objects objection to the relevance Council. Manager, okay. And
- 25:02again if you look to the last page of the document,
- 25:05paragraph sixty seven. Answer the last page, manager, Yes, the
- 25:09very last page, Virginia sixty seven. Yes, question all right.
- 25:15It says in paragraph sixty seven, I declare under a
- 25:18penalty of perjury that the foregoing is true and correct.
- 25:22Answer yes, And it was executed honor about the fifth
- 25:26day of February twenty fifteen. Correct. It's a bit smudge,
- 25:31but it kind of looks like a five. Question all right.
- 25:34And then there's a signature block that's redacted that says
- 25:38Jane do three correct answer correct. Manager. Do you believe
- 25:43that you signed this document and it was later covered
- 25:46up by that block. Answer yes, question all right? And again,
- 25:51is there anything in this document that you believe today
- 25:54to not be true? Mister Edwards, I just ask you
- 25:57that you read through the entire document and a k
- 26:00the question, miss Manager, have you seen this document before?
- 26:04Miss Joffrey. Response, I'm sure I have, but it's always
- 26:09good to refresh your memory just looking over something. Manager
- 26:12all right. She pauses. Then Virginia answers, thank you for
- 26:16giving me time to read it over. Manager certainly, so
- 26:20have you had a chance to read it over now?
- 26:23Answer yes, all right? And what parts of this document
- 26:26sworn by you under penalty of perjury are not true?
- 26:30Answer again, the only thing I see that is a
- 26:33mistake that I made is I first met Epstein when
- 26:36I was fifteen years old. Question okay, and that's in
- 26:39paragraph five. Answer that's in paragraph five on the first page.
- 26:45Question all right? And everything else you believe to be true? Answer? Yes,
- 26:50question okay. If I could now turn to what I'll
- 26:53mark as defendants Exhibit number five. Virginia response, thank you Edwards,
- 26:59Thank you Manager. I think I have one more McAuley,
- 27:04It's okay, if you don't, Manager, I don't think I
- 27:07have all of them. Manager, all right, Do you recognize
- 27:10defendants exhibit number five? Answer yes? What is the title
- 27:15of that document? Answer the declaration of Virginia Jeoffrey and
- 27:20that's you correct? Yes? And do you recognize which case
- 27:23this declaration was filed in? Answer yes, Bradley Edwards and
- 27:27Paul Cassel plaintiff versus redacted? Question all right? And what
- 27:32do you understand mister Edwards and mister Cassell to be
- 27:35answer and mister Edwards is my lawyer sitting next to me?
- 27:38Question all right? And mister Castle is another one of
- 27:42my lawyers. All right, and they are in the lawsuit
- 27:45against redacted? Is that you're understanding? It's your understanding. You
- 27:49don't have to look to your lawyer. If you understand,
- 27:52you don't have to Virginia. No, I just don't know
- 27:55if I'm allowed, Menager. That's all right, Virginia to say
- 27:59a certain things about that. But yes, I believe they
- 28:02were in a lawsuit. Question okay, and that's against redacted? Right?
- 28:08Answer correct Edwards once again objects to form here. I
- 28:12object to the relevance of the document, Menager, all right,
- 28:16Ms Joffrey again, if you could turn to the last
- 28:19page of this document, and do you see a signature
- 28:22on that page? Answer? I do. Question whose signature is that? Virginia? Response?
- 28:27That is mine? Question? And approximately when did you sign
- 28:31that document? Answer? Executed this twentieth day of November twenty fifteen.
- 28:37Question all right, so you sign that on November twentieth,
- 28:40twenty fifteen. Answer correct question, all right, and that was
- 28:45under penalty of perjury? Correct correct question? All right? If
- 28:50I could now turn to what will mark as defendants
- 28:53Exhibit number six Edwards, Thank you, McCauley, Thank you. Manager.
- 28:58Do you recognize this dot? Rum ms? Joffrey. Virginia responds,
- 29:02I do. Question all right, what do you believe this
- 29:05document to be Virginia? I believe this is when I
- 29:08spoke to the FBI. Okay, And do you remember about
- 29:12when you spoke to the FBI. It says the date
- 29:16of entry July fifth, twenty thirteen. Menager, do you believe
- 29:21that you spoke to the FBI in twenty thirteen? Answer?
- 29:25I thought it was twenty and eleven when I talked
- 29:27to them. Question, Okay, I'm going to direct your attention
- 29:31to the bottom of that page the first page. Do
- 29:35you see that answer yes, question the last few lines
- 29:38there have another day answer oh, yes, investigation of yes.
- 29:43Question all right, answer so that makes sense? Okay? Question
- 29:48by Menager. Okay, what do you understand that to be
- 29:51and if it refreshes your recollection about when you spoke
- 29:54to the FBI, just let us know. Answer yeah. March seventeenth,
- 29:59twenty eleven. That sounds more right than twenty thirteen. Meninger
- 30:04again asked a question okay, and where did you speak
- 30:07to them Virginia. Response? I believe this was in the
- 30:11office of the Consulate, the American Consulate in Sydney. Question Sydney, Australia.
- 30:16Answer Sydney, Australia. Question okay, and you were there in
- 30:21person with these FBI agents answer correct question and they
- 30:26were taking notes when they spoke to you? Answer yes?
- 30:29Were they recording the interview? To your knowledge? Answer? I
- 30:33believe they were. Question Okay, have you had a chance
- 30:37to review this report? And I will make note for
- 30:39the record that there are obviously many places that are
- 30:42blacked out? Answer yeah, question or white out? Is that fair? Answer? Yes?
- 30:49Question all right? Have you had a chance to review
- 30:52this one with whited out portions of it before today?
- 30:56Answer yes. Question all right, And you understood when you
- 31:00were speaking to the FBI that they were federal agents
- 31:03correct answer yes, and that you were supposed to tell
- 31:06them the truth? Correct absolutely. Question and do you believe
- 31:11that you did, in fact tell them the truth? Answer
- 31:14to the best of my knowledge. Again, when it comes
- 31:17to dates and times, I was obviously off, but everything
- 31:20else is absolutely one hundred percent true. Question okay, and
- 31:25you have reviewed any Have you at any time reviewed
- 31:29this document without any portions wipe it out? Answer? I
- 31:32don't believe I've seen this document without the portions. Okay,
- 31:36So you don't know, for example, what's behind those other
- 31:39than what you recall? Answer no, question, having told the
- 31:43FBI at the time, correct answer, that is correct. Question Okay,
- 31:48I'm going to show you a new document. Virginia responds, okay, Manager,
- 31:54you can just put that to the side, defendants Exhibit
- 31:56number seven Manager All right, Edwards, thank you, manager, And
- 32:01do you recognize this document? Virginia then replies yes, manager,
- 32:06And what do you understand it to be? Well, this
- 32:09was the phone conversation that I had between Jack Scarrola
- 32:13and Brad Edwards. Manager. Okay. And then the last, the
- 32:19last document, I hope is manager, the big one Manager?
- 32:23All right, do you recognize I'm going to I'm sorry
- 32:27if I didn't say it already. This is defendant's Exhibit
- 32:30number eight. Do you recognize this document, Virginia, Yes, I do.
- 32:34Question what is this document? Answer? This is a manuscript
- 32:39that I was writing, I believe, back in twenty eleven,
- 32:42regarding some of my life story. And just to make
- 32:45it known, this is based on true events. But I
- 32:48wouldn't say fictional, but just based on true events. Not
- 32:52everything in it is not everything is in there, and
- 32:55not everything is you know, correct. So there's a few
- 32:58mistakes in there, okay, So off the top of your head,
- 33:02do you recall any mistakes that are in there now?
- 33:04Without reading the one hundred and forty page document, mister Edwards,
- 33:09We're going to be here a long time. Answer? Yeah,
- 33:12we could be here a very long time. I mean,
- 33:14I'd like to say a majority of it is correct.
- 33:18Some names have been changed in order to protect other people.
- 33:21Question Manager, protect their privacy? Answer? Protect their privacy? Yeah,
- 33:26I would say, just not getting them involved. If this
- 33:29were to Averrago public. Question, Well, again, without reading the
- 33:33whole manuscript. Virginia reading it. Yeah, but I'm trying to
- 33:37see if I can see something in here. Manager, Let
- 33:41me narrow my question and maybe that will help answer. Okay, question,
- 33:46is there anything Well? First of all, did you author
- 33:49that entire manuscript? Answer? Yes, I did. Question did anyone
- 33:54else author part of the manuscript? Answer? Do you mean
- 33:57anyone else write this with me? Question? Right? Answer? No,
- 34:02So that's all you're writing, Virginia, this is my writing manager. Okay,
- 34:07to the best of your recollection as you sit here
- 34:10right now, is there anything in that manuscript about Gallaine
- 34:13Maxwell that is untrue? Answer? I don't believe so. Like
- 34:17I said before, there's a lot of stuff that I
- 34:19actually have left out of her question. Uh huh. Answer,
- 34:24So there is a lot more information I could put
- 34:27in there, But as far as glain Maxwell goes, I
- 34:29would like to say that there is ninety nine point
- 34:31nine percent of it would be to the correct knowledge. Manager,
- 34:35All right, anything else that you I understand you're doing
- 34:38this for memory? Is there anything else that you recall
- 34:41as you're sitting here today about Gallainne Maxwell that is
- 34:44contained in the manuscript that is not true? Virginia. You know,
- 34:49I haven't read this in a very long time. I
- 34:51don't believe that there's anything in here about Gallainne Maxwell.
- 34:54That's not true, mister Edwards. I just ask counsel if
- 34:58you have anything specific to show about Klainne Maxwell. Menager,
- 35:02I'll ask questions, Edwards. Well, i'll have her look at it, Menager.
- 35:07I'll ask questions. Mister Edwards. I know, but I want
- 35:11the record clear that if she hasn't read it in
- 35:13a long time, she Menager, it erupts. She made the
- 35:17record very clear. Thank you. She doesn't need you to
- 35:19make a record, Edwards. I'm not making records, but you're
- 35:23making this last longer. There's no need for this. This
- 35:26doesn't have to be an unpleasant process. I want her
- 35:29to help you. Menager. I don't find it unpleasant. I'm
- 35:33sorry if you do, mister Edwards. Okay, well, then I
- 35:37object to that last series of questions to the extent
- 35:39that she was unable to look at what you wanted
- 35:42her to look at. Menager. I would like to turn
- 35:45to the next document filed on March sixteenth of this year,
- 35:48or actually, let me rephrase that. A document dated March sixteenth,
- 35:52of this year, which we will mark as defendants Exhibit
- 35:55number nine. All right, folks, we're gonna wrap up well
- 35:58part two right here, and the next episode we're gonna
- 36:01pick up where we left off. All of the information
- 36:04that goes with this episode can be found in the
- 36:08description box. What's up, everyone, and welcome back to the
- 36:11Epstein Chronicles. This episode, we're gonna pick up where we
- 36:15left off with the Virginia Roberts deposition, So let's get
- 36:21back to it. Ms Meninger, do you recognize this document,
- 36:25Miss Joffrey Virginia, Yes, I do, all right? And what
- 36:29is your understanding of what this document represents? Based upon
- 36:35the title, it is plaintiff's response and objections to defendant's
- 36:39first set of discovery requests. A plaintiff question and are
- 36:43you the plaintiff? Answer? I am the plaintiff, yes, question
- 36:47all right. So it's your response to Miss Maxwell's discovery request.
- 36:51Correct answer, correct manager, all right? And if you look
- 36:56at the last page, or I'm sorry it would be
- 36:59the second plat page, you might see signatures of your attorney.
- 37:03Correct answer, I see printed names, question printed electronic signature answer. Okay, Manager,
- 37:11will have a little s in front of it. Virginia,
- 37:14all right, manager, do you see that? Virginia. I can
- 37:18see there, Yeah, the printed names, So if it's electronic signature,
- 37:22then yes, manager, all right, and the date on that
- 37:26is March sixteenth of twenty sixteen. Virginia responds, correct, manager,
- 37:32all right, So, without revealing the content of your conversations,
- 37:35you assisted in preparing responses to discovery requests. Correct answer, yes, Manager,
- 37:42all right. I'm going to show you a subsequent one,
- 37:45mark defendants Exhibit ten and dated March twenty second Exhibit
- 37:49ten marked question by miss manager. If you can take
- 37:53a look at that answer, Thank you, manager. And while
- 37:56we're at it, I'm going to give you defendants exhibit
- 37:59number eleven so you can look at them together. Miss
- 38:03manager all right. Virginia response, thank you. Manager. All right.
- 38:07So looking at defendants Exhibit ten, do you recognize that document?
- 38:12Virginia response a plaintiff supplemental response and objections to Defendant's
- 38:17first set of discovery requests to Plaintiff. I've seen a
- 38:20lot of documents and they all look the same. But
- 38:23I'm sure I've seen it, all right, And looking again
- 38:26at the last page or I'm sorry this time it
- 38:29will be the third to last page. Manager, do you
- 38:34see your attorneys signature and the date March twenty second,
- 38:37twenty sixteen, correct answer, I do, question, all right? And
- 38:42then looking at defendants Exhibit eleven, that's your declaration correct answer, Yes,
- 38:47it is. Question and declaring under penalty of perjury as
- 38:52of March twenty second, twenty sixteen. That the supplemental response
- 38:56and objections are true and correct. Right answer correct, Manager,
- 39:01And you that's your signature. Virginia responds, that's mine, Manager,
- 39:06and you are swearing under penalty of perjury that defendants
- 39:10Exhibit ten is true and correct. Virginia responds yes, Manager,
- 39:15as of March twenty second, twenty sixteen. Right, Virginia, yes,
- 39:21all right? And then one more on that defendants Exhibit twelve. Manager,
- 39:26do you recognize this document? Virginia responds yes, okay, and
- 39:31what is this document? Answer Plaintiff's second amended Supplemental Response
- 39:36and Objections to Defendants first set of discovery requests to
- 39:40plaintiff Manager, all right, and again turning to the very
- 39:44rear section, I think you'll see your attorney signatures again
- 39:48and the date of April twenty ninth, twenty sixteen, Virginia,
- 39:53I do see that, okay, all right? And again you
- 39:56authorize this document to be file, correct, Virginia. Correct, Manager,
- 40:01and the statements contained therein are true to the best
- 40:04of your knowledge, correct, Virginia. Correct, And that's April twenty ninth,
- 40:10is just a few days ago, correct, Virginia. Once again, yes,
- 40:14all right? Do you review this April twenty ninth document
- 40:17before it was filed or served? Virginia? Like I said,
- 40:21I've seen a lot of documents and they all look alike,
- 40:24but I'm sure I've seen this one, Menager. Okay. And
- 40:27if it's something that was served last Friday, does that
- 40:30refresh your recollection that you reviewed it before it was
- 40:34served on April twenty ninth, twenty sixteen, Virginia. I believe
- 40:39I have seen this, Manager, and you were here in
- 40:43the US last Friday, Virginia. Yes, Manager, so you saw
- 40:48it in person? Correct? Yes, I was looking at a
- 40:51lot of documents on Friday. Manager, Okay, Virginia responds, I
- 40:55believe this definitely could be the one that I looked at, Menager.
- 40:59All right, if I could direct your attention to let
- 41:02me see in that document. Edwards objects again Exhibit twelve,
- 41:07manager responds, uh huh, defendants Exhibit number twelve. Manager to page. Sorry,
- 41:13you're not the only one who's seen a lot of documents. Well,
- 41:17without asking you to look at the page, can you
- 41:19tell me what you're between nineteen ninety six and well
- 41:23in nineteen ninety six to two thousand and two. What
- 41:26was the first job that you held? Answer? I believe
- 41:29the first job that I held was in the year
- 41:31two thousand and that was at mar A Lago. Question okay,
- 41:36and that's the first job you held as a teenager
- 41:38or at any point that you can recall. Answer that
- 41:42I recall. Question all right, did you ever work at
- 41:45Taco Bell? Answer? My ex boyfriend used to work there,
- 41:49and I would help him out. I was never really
- 41:51I don't think I was employed there. He was my boyfriend,
- 41:54so I stayed there with him all the time. Question
- 41:57what was his name? Answer? I called him redacted, but
- 42:01I think his real name was redacted. Question okay, so
- 42:05he was employed there, but you were not employed there. Answer?
- 42:09I used to go there to help him out. Question
- 42:11did you have a uniform? Answer? I would have to
- 42:14wear a shirt when I was there. Yes, he was
- 42:17the manager. So question oh a Taco Bell shirt. Answer, yes, okay,
- 42:22did you get a paycheck from them? I believe redacted
- 42:25paid me. How did he pay you? Answer with a check?
- 42:28Manager then responds written from Taco Bell. Virginia, you know,
- 42:33I don't know. Sorry, I just remember he asked me
- 42:35to come in and help him out, and that I
- 42:38really don't consider myself an employee there. But question, just
- 42:42wearing the shirt and getting a paycheck didn't cause you
- 42:45to think that you were an employee? Answer Virginia, Well,
- 42:49mister Edwards then objects to the form mischaracterizes her testimony. Virginia, Yeah,
- 42:55I know. I mean it was my boyfriend. I was
- 42:57helping him out, so that's the way I looked at it.
- 43:00Question by mismanager. Is there any other place that you
- 43:04wore a uniform and got a check from in the
- 43:06years from nineteen ninety six to two thousand? Answer? I
- 43:10did work at publics as a bad girl, but that
- 43:13was only for a couple of weeks. I think. Manager.
- 43:16Which Publix was it? Answer? I believe it was in Locksahatchie. Okay,
- 43:22so do you remember the street? Virginia? No, Manager, all right?
- 43:27Anywhere else you wore a uniform and got a paycheck. Answer,
- 43:31I volunteered at a bird aviary. Question what was the
- 43:35name of that? Answer? I don't know the name of it,
- 43:37but it was I'm an animal lover. So question okay,
- 43:41answer it's something I enjoyed doing. Question by manager, Okay,
- 43:46did you get a check from them? Answer? I volunteered.
- 43:49I think they eventually put me on some kinds of payroll.
- 43:51I don't think it was much though. Question okay, so
- 43:55that year you were helping out in Taco Bell wearing
- 43:58a uniform and getting a check. Virginia, I have no
- 44:01idea when it comes to years. Question was it before
- 44:05or after mar A Lago? Virginia before mar A Lago?
- 44:09Question okay, and how mar A Lago was my first
- 44:12real job, so Virginia interjects. Meninger goes on to say
- 44:17what's that. Then Virginia responds, mar A Lago was my
- 44:20first real job, menager, what do you mean by real job? Virginia, like,
- 44:26you know, fully employed, sit down for an interview and
- 44:29you know. Question okay, so Taco Bell? Was Taco Bell
- 44:33the first place you got a paycheck from? To this,
- 44:35mister Edwards objects again Virginia, I don't know to be honest.
- 44:40Question by miss Meninger. And in what order did Taco Bell,
- 44:44Publics and mar A Lago go and the Aviary? Sorry? Oh,
- 44:48I would have to guess. Do you want me to guess? Question? Sure, Virginia.
- 44:53I would say Publics, and then I think that's when
- 44:56I helped my boyfriend out at Taco Bell, and then
- 44:58I think it was the av Question and where was
- 45:03the Taco Bell? Answer? I was living in Fort Law.
- 45:06I think it was Fort Lauderdale. Don't quote me on that,
- 45:09but somewhere in Florida, Broward County something like that. Question
- 45:13And who were you living with at this time? Answer Michael?
- 45:17His name is James, but Michael. Question So you were
- 45:20living with Michael when you worked at Taco Bell? Right answer, yes,
- 45:24I was living with them. Question and when you worked
- 45:27with Michael when you worked at Publics? Correct? No question? Okay,
- 45:32So Publics came after Taco Bell or before? Virginia, I
- 45:37think it came, like I said, don't quote me on it,
- 45:40but I think Publics came before it. Menager? And who
- 45:43are you living with when you worked at Publics? Answer
- 45:46by Virginia my mom and my dad? Menager? And who
- 45:50were you living with when you worked at the aviary,
- 45:53answer my mom and my dad. Question anywhere else that
- 45:57you got a paycheck from before two thousand, Virginia, No,
- 46:01not that I can think of. Question okay, anywhere else
- 46:05you wore a uniform answer besides Marrow Lago. Yeah, that's it.
- 46:09Question okay. So how long was it before working at
- 46:13any of those three places? And the time that you
- 46:15worked at mar A Lago, Virginia applies. I have no idea,
- 46:19I'm sorry, manager interrupts. Years months, Virginia. Oh, we're going
- 46:25back chronologically. I was trying to get my ged and
- 46:28I was a summer break, and that's when I started
- 46:31working for mar A Lago. So that mar A Lago
- 46:34we know now is the year two thousand. So I
- 46:37would have to say a month question by manager. Months?
- 46:42And what was the job you believe you had immediately
- 46:46prior to mar A Lago, Virginia. If I were correct,
- 46:49it would be the aviary that I volunteered at. Question Okay.
- 46:53And you believe you were living with your parents at
- 46:55the time that you worked at the aviary, Virginia. Yesestion
- 47:00by manager, okay, and not living with redacted Virginia redacted
- 47:04might have been living with me and my parents. Question. Okay,
- 47:08so you recall redacted was living with you and your
- 47:10parents at the time you worked at the aviary. Virginia
- 47:14starts to answer, and Sigaret McAuley here objects objection mischaracterizes testimony. Manager,
- 47:23and was redacted living with you and your parents at
- 47:27the time you started at mar A Lago? Virginia responds yes, manager,
- 47:33And what address was redacted living with you and your
- 47:36parents at at the time you started at marri A Lago?
- 47:40Answer my parents address, whatever address you were living at
- 47:45at the time you started at mar A Lago, Virginia redacted. Lochsahachie, Florida,
- 47:51thirty three, four seventy Question, how is it that you
- 47:55came to work at mar A Lago, Virginia. My dad's
- 47:59a maintenance manager or supervisor. I don't know what you
- 48:02call it, but he worked in the maintenance department, mostly
- 48:05on tennis courts, working on the air conditioning, helping set
- 48:08up for functions, and he got me a summer job there. Manager. Okay,
- 48:13and you said you were on a break Virginia. Yes, manager,
- 48:18what were you on a break from? Virginia? I think
- 48:21like this is going back so long now. But I
- 48:23was attempting to get my GED and summer came, so
- 48:27school stops during the summertime here in America, and I
- 48:30got a summer job. Question all right, And where were
- 48:34you in school, Virginia. I don't actually know the name
- 48:37of the place. It's called. Yeah, I know manager, a
- 48:41GED place, Virginia. Yeah, it was like I was previously
- 48:45in Royal Palm Beach High School. But I mean, because
- 48:48of a lot of circumstances that I had been subjected to,
- 48:51I decided I wanted to get my GED. Manager. Okay,
- 48:56so you were going to an actual school to get
- 48:58your GED, that's what you're saying, Virginia responds yes, manager,
- 49:03And that school, whatever it was that you were getting
- 49:06your GED, was not Palm Beach High School, right answer, no, Manager,
- 49:12and it whatever the school was where you were getting
- 49:14your GED took a summer break, Virginia. I believe so.
- 49:18And that was in two thousand, Menager ass now that
- 49:21we know the dates. Yes, came the reply from Virginia.
- 49:25And that's when your dad helped you get a quote
- 49:28unquote summer job. Answer yes, question, all right, And that
- 49:33summer job was at mar A Lago. Virginia answers yes, Manager, Okay,
- 49:39Now tell me how you sort of came into mar
- 49:41aw Lago for the first time. He asked you to come,
- 49:43they called you. What happened, Virginia. My dad was very
- 49:48like there, so I think he talked to some people
- 49:50who were in HR and then they said for me
- 49:53to come for an interview question uh huh, Virginia, to
- 49:57be interviewed for a locker room assistant says, uh huh, Virginia.
- 50:02They liked me. I had to go through a series
- 50:04of drug tests, polygraph tests. I mean, it was a
- 50:07very extensive regiment to get the job there. Manager, Yeah, Virginia.
- 50:12And then when all those came back good, I started
- 50:14the job. Manager. So how long do you think it
- 50:17took for you to go through that extensive series of
- 50:20drug tests and polygraph tests? Virginia. I did them both
- 50:24the same day, Manager, Okay, when was the interview? Was
- 50:28it on the same day a different day, Virginia. I
- 50:31believe it was a few days beforehand. Manager. Okay, do
- 50:34you remember who you interviewed with, Virginia. No. Manager, do
- 50:39you remember the title of the job for which you
- 50:42were interviewing. Virginia responds, locker room attendant. Manager. Locker room
- 50:49attendant was the name, Virginia of the position manager? Yes,
- 50:53Virginia responds, yes, manager. And then did they give you training,
- 50:58Virginia non? Did they show you how to work the lockers? Virginia, Well,
- 51:03I mean there was a girl who already worked there
- 51:06at the front desk. I think she helped make appointments
- 51:08and greeted people, and then she just told me my
- 51:11duties in the locker room were to, you know, make tea.
- 51:14I had never made tea before, so that was that
- 51:17was fun, learn how to make tea. Clean up after
- 51:19the ladies who had been in the locker room, make
- 51:21sure the bathrooms were kept nice and tidy. You foled
- 51:24the toilet paper into a little triangle every time you
- 51:27went to the toilet, clean up the sink area. It
- 51:30was a very crazy job. Menainger, do you remember the
- 51:33names of any of your coworkers who work with you
- 51:35at mar A Lago, Virginia answers. I believe the head
- 51:39of the spy area was Adriana or Adrian I can't
- 51:42remember exactly, Okay, And the girl who trained me, I
- 51:46have a very clear picture of her face, but I
- 51:48can't remember her name. Question, all right, what did she
- 51:51look like? Answer? She had blonde hair, probably to her
- 51:54shoulders and it was curly Menager, And how old was she? Virginia?
- 52:00Your response, I'd say in her twenties. Manager, all right,
- 52:03did they check your identification when you went in for
- 52:06your job interview or your Virginia answers. It was very extensive.
- 52:10I'm sure they would have had to check and make
- 52:12sure that I was who I was. Manager, and so
- 52:16you had a driver's license, right, Virginia, I believe so.
- 52:20And Manager, all right, and let's see. Did you move
- 52:23to a different position while you were there or did
- 52:25you always stay in the locker room? Virginia, I wasn't
- 52:28there very long, so I just Manager interrupts just one second.
- 52:32Did you always stay as a locker room attendant? Virginia responds, yes, Manager, Okay,
- 52:38I just need to finish my question for the court reporter.
- 52:41All right, folks, we're going to wrap up there, and
- 52:43in the next episode, we're going to keep it rolling
- 52:46with this explosive deposition. All of the information that goes
- 52:50with this episode can be found in the description box.