1.9.24 Epstein documents

January 9, 2024 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Pursuant to the Court’s December 18, 2023, unsealing order, and following conferral with Defendant, Plaintiff files this set of documents ordered unsealed. This filing also excludes documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with Chambers), 107, and 110 (see ECF No. 1319), while the Court’s review of those documents is ongoing. This is the last set of documents to be filed pursuant to the Court’s December 18, 2023, order. Respectfully, /s/ Sigrid S. McCawley Sigrid S. McCawley cc: Counsel of Record (via ECF) Case 1:15-cv-07433-LAP Document 1335 Filed 01/09/24 Page 1 of 1 EXHIBIT 6 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 1 of 465 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 2 of 465 Page 2 1 2 APPEARANCES: 3 BOIES SCHILLER & FLEXNER, LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdatle, Florida, 33301 BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ, ESQUIRE EMMA ROSEN, PARALEGAL 7 8 FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN, P.L. Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 11 BY: BRAD EDWARDS, ESQUIRE 12 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE 20 21 Also Present: 22 James Christe, videographer 23 24 25 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 3 of 465 Page 3 1 2 THE VIDEOGRAPHER: We are now on 3 the record and recording. This begins 4 disk No. 1 in the deposition of 5 Ghislaine Maxwell in the matter of 6 Virginia Giuffre versus Ghislaine 7 Maxwell in the U.S. District Court for 8 the Southern District of New York. 9 Today is April 22, 2016 the time is 10 9:04 a.m.. This deposition is being 11 taken at 575 Lexington Avenue in New 12 York at the request of Sigrid McCawley 13 of Boies Schiller & Flexner. 14 The videographer is James Christe 15 and the court reporter is Leslie Fagin. 16 Will counsel state their appearance and 17 whom they represent and then court 18 reporter swear in Ms. Maxwell. 19 MS. McCAWLEY: My name is Sigrid 20 McCawley with my colleague Meredith 21 Schultz. We are with Boies Schiller & 22 Flexner. We represent Ms. Giuffre. 23 MR. EDWARDS: Brad Edwards. I also 24 represent Ms. Giuffre. 25 MR. CASSELL: Paul Cassell, I also Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 4 of 465 Page 4 1 G Maxwell - Confidential 2 represent Ms. Giuffre. 3 MR. PAGLIUCA: Jeff Pagliuca and 4 Laura Menninger on behalf of Ms. 5 Maxwell. 6 G H I S L A I N E M A X W E L L, called 7 as a witness, having been duly sworn by a 8 Notary Public, was examined and testified as 9 follows: 10 EXAMINATION BY 11 MS. McCAWLEY: 12 Q. Good morning. I'm going to explain 13 some of the rules that will happen with 14 respect to depositions. 15 Have you ever been deposed before? 16 A. I have not. 17 Q. What is going to happen here, we 18 have a court reporter and a videographer. 19 What they do is take down the words that we 20 say so when I ask you a question they will 21 record what you say in response to that. So 22 we have to be mindful that in order for them 23 to do their job we can't talk over each 24 other. 25 Another issue you have to be weary Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 5 of 465 Page 5 1 G Maxwell - Confidential 2 of is that in a response, you can't give a 3 nonverbal response, in other words, nodding a 4 yes or no, they need to hear verbal response 5 so they can record it on their transcript. 6 So that's important for you to remember as we 7 go through the day. If you forget, I will be 8 sure to remind you. 9 Is there anything that would 10 prevent you from giving truthful testimony 11 today? 12 A. There is not. 13 Q. You are not on any medications or 14 anything that would inhibit your ability to 15 remember or give truthful testimony? 16 A. I am not. 17 MR. PAGLIUCA: Could you identify 18 the assistant in the room. 19 MS. McCAWLEY: This is Emma Rosen 20 from our New York office. She is a 21 paralegal. 22 Q. Ms. Maxwell, can you please state 23 your address for the record? 24 A. Currently 25 Q. What is your date of birth? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 6 of 465 Page 6 1 G Maxwell - Confidential 2 A. 3 Q. When did you first recruit a female 4 to work for Mr. Epstein? 5 MR. PAGLIUCA: I object to the form 6 and foundation of the question. I 7 believe this is confidential 8 information. I ask anyone who is not 9 admitted in this case be excused from 10 the room, please. 11 MS. McCAWLEY: So the response to 12 that question would -- 13 MR. PAGLIUCA: The subject matter 14 of this question is confidential and I'm 15 designating it as confidential. 16 MS. McCAWLEY: I just want to make 17 that clear for the record. 18 MR. EDWARDS: So we don't delay the 19 deposition I will step out of the room 20 but I think it's important to lay the 21 record that -- 22 MR. PAGLIUCA: I'm sorry, you are 23 not admitted in this proceeding so you 24 are not entitled to make any record. If 25 Ms. McCawley wants to make a record she Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 7 of 465 Page 7 1 G Maxwell - Confidential 2 can. 3 MR. EDWARDS: I can make a record 4 right now. 5 MR. PAGLIUCA: Maybe we should get 6 the judge on the phone and talk about 7 it. 8 MR. EDWARDS: The record will be 9 short. This is the precise reason why 10 Ms. Giuffre wants me in this case and 11 I'm unable to effectively represent her 12 at this time because I am unable to have 13 access to the confidential information 14 which includes apparently the entire 15 deposition of Ms. Maxwell. But for the 16 sake of not further delaying this, I 17 will be outside the room. 18 MS. McCAWLEY: Thank you. 19 A. I would like to just -- wait for 20 him to leave. 21 Q. That's fine. 22 A. I would just like to clarify the 23 address. I'm in the process of selling the 24 house so while while I still receive mail 25 there, it's not my actual physical address. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 8 of 465 Page 8 1 G Maxwell - Confidential 2 It's in the process of being sold. It still 3 requires some final paperwork to be done, so 4 just for the purposes of clarity. 5 Q. Do you have a new address where you 6 will be living? 7 A. I do not. 8 Q. For the purpose of the record, if 9 there is something I ask you that you later 10 remember something else or need to correct 11 your testimony in some way, you can do that, 12 just let me know what it is and we will go 13 back to that question and can you clarify. 14 A. Of course. I just wanted to be 15 clear, there is still some paperwork pending 16 for final release, but it's in the process of 17 sale. But I don't have another address 18 currently, so whilst that should still be of 19 record that the mail could be forwarded 20 there, so for purposes of clarity I wanted to 21 be clear. 22 Q. I appreciate that. 23 So Ms. Maxwell, when did you first 24 recruit a female to work for Mr. Epstein? 25 MR. PAGLIUCA: Again. I object to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 9 of 465 Page 9 1 G Maxwell - Confidential 2 form and foundation of the question. 3 Q. You can answer the question. 4 A. First of all, can you please 5 clarify the question. I don't understand 6 what you mean by female, I don't understand 7 what you mean by recruit. Please be more 8 clear and specific about what you are 9 suggesting. 10 Q. Are you a female, is that the sex 11 that you are? 12 A. I am a female. 13 Q. That's what I'm referring to a 14 female and I'm asking you when you first, the 15 very first time you recruited a female to 16 work for Mr. Epstein? 17 A. Again, I don't understand what 18 female -- I am a 54 year old women. 19 Q. I'm not making it age, any age of a 20 female that you recruited to work for Mr. 21 Epstein? 22 A. Again, I was somebody who hired a 23 number of people to work for Mr. Epstein and 24 hiring is one of my functions. 25 Q. And when is the first time you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 10 of 465 Page 10 1 G Maxwell - Confidential 2 hired someone to work for Mr. Epstein, a 3 female? 4 A. As best as I can recollect, a woman 5 the age probably of about 40 or 50 was in 6 sometime in 1992. 7 Q. How long did you work for Mr. 8 Epstein? 9 A. I started working for him at some 10 point in 1992 and the nature of my work 11 relationship with him changed over time so 12 from around 2002, 2003, the work lessened 13 considerably. 14 Q. When did you -- 15 MR. PAGLIUCA: Can I interject for 16 a moment. If we are talking about 17 background -- 18 MS. McCAWLEY: I'm in the middle of 19 a question. Let me finish it and then 20 can you interject. 21 Q. When you say 2002 to 2003 that the 22 work lessened, when did you complete working 23 for Mr. Epstein; when was the last time you 24 were employed by him, the last date? 25 A. I believe I still was doing -- Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 11 of 465 Page 11 1 G Maxwell - Confidential 2 helping him in a very nominal way, maybe an 3 hour or two a year at sometime 2008 and 2009. 4 MR. PAGLIUCA: So if you are going 5 to be talking about general background, 6 I don't need to designate that as 7 confidential. So if you want to have 8 them come back in, that's fine. 9 I assumed by your first question 10 you were going into more sensitive 11 areas. I will leave it up to you, but 12 if this is general background it will 13 not be designated as confidential. 14 MS. McCAWLEY: I appreciate that. 15 I will jump back into my other 16 questions. 17 MR. PAGLIUCA: So we will keep it 18 as confidential. 19 Q. When you were first employed by him 20 in 1992, what were you hired to do? 21 A. First, I was consulting and what I 22 did was I helped with decorating houses and 23 in hiring staff to help run those houses. 24 Q. Did your duties change over the 25 course of 1992 to 2009? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 12 of 465 Page 12 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. My job entailed running the homes 5 that he had but much more importantly, most 6 of the houses had construction and so whilst 7 in 1992 there was no construction project, 8 there was construction projects that began 9 after that time and I was in charge not only 10 of hiring architects, I was also in charge of 11 all the filings or overseeing that, like a 12 general contractor would. 13 I also helped with hiring the 14 architects, hiring the builders, reviewing 15 the contracts for the builders, coordinating 16 the building projects, coordinating how the 17 projects would layout, the timing of the 18 projects and all the various materials that 19 they would require to run a very substantial 20 building project. That's the nature of the 21 job I was dealing with. 22 Q. How old was the youngest female you 23 ever hired to work for Jeffrey? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 13 of 465 Page 13 1 G Maxwell - Confidential 2 Q. You can answer. 3 A. I have not any idea exactly of the 4 youngest adult employee that I hired for 5 Jeffrey. 6 Q. When you say adult employee, did 7 you ever hire someone that was under the age 8 of 18? 9 A. Never. 10 Q. Did you ever bring someone who was 11 under -- invite someone under the age of 18 12 to Jeffrey's home, any of his homes? 13 MR. PAGLIUCA: Object to the form 14 foundation. 15 A. Can you repeat the question? 16 Q. Did you ever invite anybody who was 17 under the age of 18 to Jeffrey's homes? 18 MR. PAGLIUCA: Same objections. 19 A. I have a number of friends that 20 have children and friends of mine that have 21 kids and in the invitation of my friends and 22 their kids, I'm sure I may have invited some 23 of my friend's kids to come. 24 Q. Anybody that is not a friend of 25 yours. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 14 of 465 Page 14 1 G Maxwell - Confidential 2 Any female under the age of 18, did 3 you invite them to come to Jeffrey's home? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 A. Again, as I said, I am not aware of 7 inviting anybody other than friends of mine 8 who have children to the house. 9 Q. Did you invite Virginia Giuffre to 10 come to Jeffrey Epstein's home when she was 11 under the age of 18? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. Virginia Roberts held herself out 15 as a masseuse and invited herself to come and 16 give a massage. 17 Q. My question is, did you invite 18 Virginia Roberts when she was under the age 19 of 18 to come to Jeffrey Epstein's home? 20 MR. PAGLIUCA: Object to the form 21 and foundation. 22 A. Again, Virginia Roberts was a 23 masseuse -- 24 Q. I'm asking not asking if she was a 25 masseuse. I'm asking if you invited her to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 15 of 465 Page 15 1 G Maxwell - Confidential 2 come to Jeffrey Epstein's home? 3 A. Again, there would be no course to 4 have a conversation with Virginia unless she 5 held herself out to be a masseuse. 6 Q. I'm not asking that question. I'm 7 asking if you invited her to come to Jeffrey 8 Epstein's home when she was under the age of 9 18? 10 A. Again, I repeat, she was a masseuse 11 and in the form and as my job, I was to have 12 people who he wanted for various things 13 including massage. She came as a masseuse. 14 Q. So you invited her to his home to 15 come to give a massage, is that correct? 16 MR. PAGLIUCA: Object to the form 17 and foundation. Misstates the witness' 18 testimony. 19 A. Again, I did not invite Virginia 20 Roberts. She came as a masseuse. 21 Q. She who invited her to come as a 22 masseuse, she just showed up at the front 23 door? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 16 of 465 Page 16 1 G Maxwell - Confidential 2 A. Ms. Roberts held herself out -- 3 Q. I'm not asking how she held herself 4 out. I'm asking how she arrived at the home. 5 Did you meet her and invite her to come to 6 the home or how did she arrive there? 7 MR. PAGLIUCA: Object to the form 8 and foundation. 9 A. Ms. Roberts held her to be a 10 masseuse and her mother drove her to the 11 house. 12 Q. When did you first meet Virginia 13 Roberts? 14 A. I don't have a recollection of the 15 first meeting. 16 Q. Do you recall meeting her at 17 Mar-a-Lago? 18 A. Like I said, I don't have a 19 recollection of meeting Ms. Roberts. 20 Q. So you recall Ms. Roberts being 21 brought to the home by her mother, is that 22 your testimony? 23 A. That is my testimony. 24 Q. And that is the first time you met 25 her? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 17 of 465 Page 17 1 G Maxwell - Confidential 2 A. Like I said, I don't recall meeting 3 her the first time. I do remember her mother 4 bringing her to the house. 5 Q. Are you a member at Mar-a-Lago? 6 A. No. 7 Q. Have you visited Mar-a-Lago? 8 A. Yes. 9 Q. Did you visit Mar-a-Lago in the 10 year 2000? 11 A. I'm pretty sure I did. 12 Q. When Ms. Roberts arrived at the 13 home with her mother, what happened? 14 A. I spoke to her mother outside of 15 the house and she -- what I don't recall is 16 exactly what happened because I was talking 17 to her mother the entire she was in the 18 house. 19 Q. Did you introduce Ms. Roberts to 20 Jeffrey Epstein? 21 A. I don't recall how she actually met 22 Mr. Epstein. As I said, I spoke to her 23 mother the entire time outside the house. 24 Q. Did you walk Ms. Roberts up to the 25 upstairs location at the Palm Beach house to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 18 of 465 Page 18 1 G Maxwell - Confidential 2 meet Mr. Epstein? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 Q. You can answer. 6 A. I just explained. 7 A. I spent the entire time talking to 8 Virginia's mother outside the house so the 9 answer to the question is no. 10 Q. No, did you not walk her up and 11 introduce her to Mr. Epstein? 12 A. I just said no. 13 Q. Did you participate in a massage 14 this first time when she first came to the 15 home and you were speaking with her mother, 16 she was in the home, is that correct, you 17 brought her into the home? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 A. I will repeat again, I was standing 21 outside with her mother so very difficult for 22 me to do anything else at that time so no, I 23 did not take her upstairs. 24 Q. Did you participate -- 25 A. Virginia lied 100 percent about Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 19 of 465 Page 19 1 G Maxwell - Confidential 2 absolutely everything that took place in that 3 first meeting. She has lied repeatedly, 4 often and is just an awful fantasist. So 5 very difficult for anything to take place 6 that she repeated because I was with her 7 mother the entire time. 8 Q. So did you have -- did you give a 9 massage with Virginia Roberts and Mr. Epstein 10 during the first time Virginia Roberts was at 11 the West Palm Beach house? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 Q. Yes or no? 15 A. No. 16 Q. Have you ever given a massage with 17 Virginia Roberts in the room and Jeffrey 18 Epstein? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. No. 22 Q. Have you ever given Jeffrey Epstein 23 a massage? 24 MR. PAGLIUCA: Object to the form, 25 foundation. And I'm going to instruct Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 20 of 465 Page 20 1 G Maxwell - Confidential 2 you not to answer that question. I 3 don't have any problem with you asking 4 questions about what the subject matter 5 of this lawsuit is, which would be, as 6 you've termed it, sexual trafficking of 7 Ms. Roberts. 8 To the extent you are asking for 9 information relating to any consensual 10 adult interaction between my client and 11 Mr. Epstein, I'm going to instruct her 12 not to answer because it's not part of 13 this litigation and it is her private 14 confidential information, not subject to 15 this deposition. 16 MS. McCAWLEY: You can instruct her 17 not to answer. That is your right. But 18 I will bring her back for another 19 deposition because it is part of the 20 subject matter of this litigation so she 21 should be answering these questions. 22 This is civil litigation, deposition and 23 she should be responsible for answering 24 these questions. 25 MR. PAGLIUCA: I disagree and you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 21 of 465 Page 21 1 G Maxwell - Confidential 2 understand the bounds that I put on it. 3 MS. McCAWLEY: No, I don't. I will 4 continue to ask my questions and you can 5 continue to make your objections. 6 Q. Did you ever participate from the 7 time period of 1992 to 2009, did you ever 8 participate in a massage with Jeffrey Epstein 9 and another female? 10 MR. PAGLIUCA: Objection. Do not 11 answer that question. Again, to the 12 extent you are asking for some sort of 13 illegal activity as you've construed in 14 connection with this case I don't have 15 any problem with you asking that 16 question. To the extent these questions 17 involve consensual acts between adults, 18 frankly, they're none of your business 19 and I will instruct the witness not to 20 answer. 21 MS. McCAWLEY: This case involves 22 sexual trafficking, sexual abuse, 23 questions about her having interactions 24 with other females is relevant to this 25 case. She needs to answer these Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 22 of 465 Page 22 1 G Maxwell - Confidential 2 questions. 3 MR. PAGLIUCA: I'm instructing her 4 not to answer. 5 MS. McCAWLEY: Then we will be back 6 here again. 7 Q. Have you ever given a massage to 8 Mr. Epstein with a female that was under the 9 age of 18? 10 A. Can you repeat the question? 11 Q. Yes. Have you ever given a massage 12 to Mr. Epstein with a female that was under 13 the age of 18? 14 A. No. 15 Q. Have you ever observed Mr. Epstein 16 having a massage given by an individual, a 17 female, who was under the age of 18? 18 A. No. 19 Q. Have you ever observed females 20 under the age of 18 in the presence of 21 Jeffrey Epstein at his home? 22 MR. PAGLIUCA: Object to the form 23 and foundation. 24 A. Again, I have friends that have 25 children -- Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 23 of 465 Page 23 1 G Maxwell - Confidential 2 Q. I'm not talking about friends. I'm 3 talking about individuals -- 4 MR. PAGLIUCA: I'm going to object 5 to you interrupting the witness who was 6 answering your question. The question 7 was, have you ever seen anyone, female 8 under the age of 18 at the house and 9 that's the question she was answering. 10 If you want to strike that question and 11 ask another question, feel free, but let 12 the witness respond, please. 13 MS. McCAWLEY: I will do that. 14 Q. Have you ever observed a female 15 under the age of 18 at Jeffrey Epstein's home 16 that was not a friend, a child -- one of your 17 friend's children? 18 A. Again, I can't testify to that 19 because I have no idea what you are talking 20 about. 21 Q. You have no idea what I'm talking 22 about in the sense you never observed a 23 female under the age of 18 at Jeffrey 24 Epstein's home that was not one of your 25 friend's children, is that correct? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 24 of 465 Page 24 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. How would I possibly know how 5 someone is when they are at his house. You 6 are asking me to do that. I cannot possibly 7 testify to that. As far as I'm concerned, 8 everyone who came to his house was an adult 9 professional person. 10 Q. Are you familiar with the police 11 report that was issued in respect to the 12 investigation in this matter? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 Q. Are you familiar with the police 16 report that was used in this matter, the 17 investigation of Jeffrey Epstein, has been 18 produced as a document in this matter? 19 A. I have seen a police report. 20 (Maxwell Exhibit 1, police report, 21 marked for identification.) 22 Q. The police report that you have in 23 front of you, can you turn to page 28 of that 24 report, the numbers are on the top right-hand 25 corner. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 25 of 465 Page 25 1 G Maxwell - Confidential 2 You will see some redactions in 3 this report, Ms. Maxwell, the redacted 4 information is redacted because it reveals 5 the name of a minor, someone who is under the 6 age of 18. 7 On page 28, in the third paragraph, 8 about halfway down, it says, Roberts stated 9 she performed the massage naked. At the 10 conclusion of this massage, Epstein paid 11 RobSON $200 for the massage. He explained, I 12 know you are not comfortable put I will pay 13 you if you bring some girls. He told her the 14 younger the better. Robson stated once tried 15 to bring a 23 year old to Epstein and he 16 stated the female was too old. 17 Have you heard Mr. Epstein use the 18 phrase the younger the better? 19 A. I have no recollection of hearing 20 that. 21 Q. Have you used the phrase in talking 22 to Ms. Roberts and asking her to recruit 23 females for Mr. Epstein, the younger the 24 better? 25 MR. PAGLIUCA: Object to the form Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 26 of 465 Page 26 1 G Maxwell - Confidential 2 and foundation of the question. 3 A. First of all, can you break the 4 question apart. 5 Q. Have you used the phrase the 6 younger the better in speaking to Ms. Roberts 7 and asking her to recruit females for Jeffrey 8 Epstein? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 Q. You can answer. It's yes or no. 12 A. No, that's absolutely not true, on 13 the second part of your question, I have not 14 asked Virginia to recruit females and the 15 first part of your question, if you can 16 repeat that again, the question you asked. 17 Q. Will you read back the question. 18 (Record read.) 19 A. I believe I answered the later part 20 of the question. The first part of the 21 question, it's impossible for me to recall 22 events that took place 16 years ago but it 23 doesn't sound like something I would say. 24 Q. On page 28, that same paragraph, 25 Roberts was asked how many girls in total she Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 27 of 465 Page 27 1 G Maxwell - Confidential 2 brought to Epstein. Robson stated that she 3 can remember, Robson stated that she brought 4 and, it's redacted there, and the victim in 5 this case. 6 Let me ask my question, I have a 7 question pending right now. 8 Are you testifying that you are 9 unaware of any underage, under the age of 18, 10 females coming to Jeffrey Epstein's home to 11 perform massages? 12 MR. PAGLIUCA: Object to the form 13 foundation. 14 A. You need to straddle that question 15 in a different time period. When I was 16 there, at the time I was present, the people 17 that gave Jeffrey, men and women who gave 18 Jeffrey massages were adults over the age of 19 18. 20 Q. Never in your time at any of 21 Jeffrey Epstein's homes were you present when 22 a female under the age of 18 was there to 23 give Jeffrey Epstein a massage? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 28 of 465 Page 28 1 G Maxwell - Confidential 2 A. First of all, as I said when I was 3 present -- 4 Q. It is a yes or no. 5 A. No, it is not. 6 Q. You can answer the question in full 7 but please provide yes or no as an initial 8 matter. 9 A. I cannot answer yes or no, it's not 10 bounded by time. It's entirely possible I 11 could have been in a room or even in the 12 vicinity of Palm beach when somebody came and 13 I would not know. How would I know when 14 somebody was in the house. There is no way I 15 can know. 16 Q. Did you stay at Jeffrey Epstein's 17 home when you were in Palm Beach? 18 A. Most of the time. 19 Q. So how is it that you wouldn't know 20 if there was a female in the home under the 21 age of 18 if you were staying there? 22 A. Well, first of all, when I was 23 staying there, the house is actually quite 24 large and I have a very busy job and I had an 25 office with a door so the door would be shut Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 29 of 465 Page 29 1 G Maxwell - Confidential 2 and I would be working. I'm not responsible 3 for what Jeffrey does and I don't always pay 4 attention to what happens in the house. I'm 5 very busy. 6 Q. So you're testifying that you never 7 observed a female under the age of 18 at 8 Jeffrey Epstein's West Palm Beach home? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 A. I already answered that question, I 12 believe. 13 Q. You didn't answer my question. 14 A. I did. 15 Q. Did you observe a female under the 16 age of 18 at Jeffrey Epstein's home in Palm 17 Beach? 18 A. Like I said, I work, I don't sit 19 there and watch people coming in and out of 20 the house. I cannot possibly tell you if I'm 21 in the home that somebody was there that I 22 did not see, I cannot comment on it, I have 23 no idea. 24 Q. Did you observe females at Jeffrey 25 Epstein's home that were laying out topless Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 30 of 465 Page 30 1 G Maxwell - Confidential 2 in the back of the home, in other words 3 without a shirt on? 4 A. So that's just another of 5 Virginia's lies. So let's be clear, at the 6 time when I was there and present, frequently 7 at the house, it was unusual to see people 8 without their clothes on. 9 Q. When you say unusual, did you 10 observe people without their clothes at 11 Jeffrey Espstein's home? 12 A. Can I answer. Sometimes people in 13 the privacy of a house and swimming pool, I 14 have seen people from time to time take their 15 top off. I have seen people from time to 16 time do that. Very unusual. Naked people 17 around the people at any frequent period of 18 time, I have never seen. 19 Q. Were they under the age of 18? 20 A. As I was saying, people when I was 21 in the house, were of adult age, if they were 22 children, friends of my family or friends 23 that were there, they may well have been 24 because I have nieces and nephews under the 25 age of 18, I cannot testify to anybody else Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 31 of 465 Page 31 1 G Maxwell - Confidential 2 -- just another one of Virginia's many 3 fictitious lies and stories to make this a 4 salacious event to get interest and press. 5 It's absolute rubbish. 6 Q. Were you in charge of hiring 7 individuals to provide massages for Jeffrey 8 Epstein? 9 A. My job included hiring many people. 10 There were six homes. As I sit here, I hired 11 assistants, I hired architects, I hired 12 decorators, I hired cooks, I hired cleaners, 13 I hired gardeners, I hired pool people, I 14 hired pilots, I hired all sorts of people. 15 In the course and a very small part 16 of my job was from from time to time to find 17 adult professional massage therapists for 18 Jeffrey. 19 Q. When you say adult professional 20 massage therapists, where did you find these 21 massage therapists? 22 A. From time to time I would visit 23 professional spas, I would receive a massage 24 and if the massage was good I would ask that 25 man or woman if they did home visits. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 32 of 465 Page 32 1 G Maxwell - Confidential 2 Q. Did you ever hire a masseuse that 3 was under the age of 18? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 Q. Did you? 7 A. Again, I don't hire massage 8 therapists, so that was not my job. 9 Q. You just said you did, you just 10 said you hired massage therapists for Jeffrey 11 Epstein, I'm asking if you hired a massage 12 therapist who was under the age of 18? 13 A. Let me correct myself. When I 14 meant hire, I didn't mean hire in the way you 15 are doing it. What I say is that I went to 16 spas and I met people and if they did home 17 visits, Jeffrey would then, in fact, hire 18 them. I'm not responsible for hiring 19 someone. And they were not full-time, so 20 it's not a correct characterization. 21 Q. Did you ever, your term is meet, 22 did you ever meet a person that was under the 23 age of 18 that you -- that Jeffrey then hired 24 as a masseuse? 25 MR. PAGLIUCA: Object to the form Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 33 of 465 Page 33 1 G Maxwell - Confidential 2 and foundation. 3 A. First of all, Virginia Roberts who 4 you are referring to was a masseuse aged 17, 5 we all now know, so your story that you keep 6 pushing out to the press that she was a 15 7 year old -- you and I both know was a lie, 8 correct. 9 Q. You are not sentencing my question. 10 A. You and I both know that was a lie, 11 correct. 12 Q. You are not answering my question. 13 I'm asking you whether you ever met a female 14 under the age of 18 that Jeffrey then hired 15 as a masseuse? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. The only person I can talk about 19 who clearly was a massage age 17, a masseuse, 20 was Virginia. 21 Q. Did you meet her and then introduce 22 her to Jeffrey? 23 A. I don't know. I already testified 24 I don't recall meeting her. 25 (Maxwell Exhibit 2, email, marked Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 34 of 465 Page 34 1 G Maxwell - Confidential 2 for identification.) 3 Q. So I'm showing you a document that 4 we have marked as Maxwell Exhibit 2. It's a 5 document you produced in this matter labeled 6 confidential GM 00109. It's dated Sunday 7 June 12, 2011. It's from Jeffrey Epstein to 8 you. If you can turn to page 4 -- sorry, can 9 you turn to the first page, the cover page 10 initially which is 00109. If you look under 11 the time stamp it says, June 12, 2011 at 4:12 12 p.m., it says 13 Is that your email address? 14 A. It is. 15 Q. Under that it says, Thank you. I 16 have it now and I'm working on a letter, a 17 little, I will send the final version 18 tomorrow and what ever it is will be 19 factually accurate. 20 Do you see that on page 1? 21 A. I do. 22 Q. Then I would like you to turn to 23 page 4 please. The second paragraph down on 24 page 4, it states, After some thought, I 25 recall that I first met Ms. Roberts when she Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 35 of 465 Page 35 1 G Maxwell - Confidential 2 was working at a premier resort claiming to 3 be 18 years old and a professional masseuse? 4 MR. PAGLIUCA: What line are you 5 on, counsel. 6 MS. McCAWLEY: Second paragraph 7 down. 8 MR. PAGLIUCA: I got it. 9 Q. Is that a statement that you wrote? 10 A. It appears to be. 11 Q. So does that correct your testimony 12 that you did meet Ms. Roberts at Mar-a-Lago? 13 A. Again, this was written in, when 14 were you saying? 15 Q. 2011. 16 A. So by 2011, Ms. Roberts had already 17 perpetrated so many lies and stories it's 18 hard for me to accurately tell you today what 19 I remember back then. As I sit here today, 20 the testimony I give you today, I do not 21 recollect it. 22 Q. Do you have a reason to say that 23 this document that you wrote is incorrect? 24 A. It's in 2011, I can't possibly tell 25 you what I remember in 2011. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 36 of 465 Page 36 1 G Maxwell - Confidential 2 Q. Are you questioning that this 3 document is incorrect, this document -- this 4 email that you wrote? 5 A. I wrote an email. I was trying to 6 be accurate, so who knows, with all the 7 rubbish that you guys have put out in the 8 press that I read, maybe in the moment I 9 wrote it a memory came to me that I don't 10 know, but as I sit here today and the 11 testimony I gave you today is I don't 12 recollect it. 13 Q. Does this refresh your recollection 14 that you recalled meeting Ms. Roberts at 15 Mar-a-Lago? 16 A. It does not. 17 Q. So your testimony today is that you 18 don't remember meeting Ms. Roberts at 19 Mar-a-Lago? 20 A. I do not. 21 I just want to clarify, when you 22 read so much stuff and so much rubbish that 23 comes out from Virginia Roberts, you don't 24 know what's up and down, at the time I wrote 25 this I believe I had a memory but as I sit Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 37 of 465 Page 37 1 G Maxwell - Confidential 2 here today I do not. 3 Q. Ms. Maxwell, when did you first 4 meet ? 5 MR. PAGLIUCA: Object to the form 6 and foundation. 7 A. I have no idea when I met her. 8 Q. Do you know how old she was when 9 you met her? 10 A. I have no idea how old she was when 11 I met her. 12 Q. Is it possible she was 13 years old 13 when you first met her? 14 MR. PAGLIUCA: Object to the form 15 and foundation. 16 A. 21 Q. I understand 22 23 I'm asking if was 13 24 years old when you first met her? 25 A. I have no idea. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 38 of 465 Page 38 1 G Maxwell - Confidential 2 Q. Was she under 18 when you first met 3 her? 4 A. I have no idea how old she was when 5 I first met her. 6 Q. Did she look like a child when you 7 first met her? 8 A. I don't remember what she looked 9 like at the time she was in the house. 10 Q. How many years have you known her? 11 A. I can only recall the last time I 12 saw her. 13 Q. When was the first time you met 14 her? 15 A. Again, I just told you, I don't 16 recall the first time I met her. 17 Q. Did travel with you 18 on Jeffrey's planes? 19 A. I wouldn't remember if was on 20 the plane or not. 21 Q. Did you ever have sex with 22 23 A. No. 24 Q. Did you ever observe Jeffrey having 25 sex with ? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 39 of 465 Page 39 1 G Maxwell - Confidential 2 A. No. 3 Q. Were you aware that Jeffrey was 4 having sexual contact with when 5 she was 13 years old? 6 MR. PAGLIUCA: Object to the form 7 and foundation. 8 A. I would be very shocked and 9 surprised if that were true. 10 Q. Were you in the house when 11 was in the house in a private area 12 with Jeffrey Epstein? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 A. Can you repeat the question. 16 Q. Were you ever in the Palm Beach 17 house when Jeffrey Epstein was in the house 18 with ? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. I've already testified that I have 22 met her and that she was there 23 I don't understand what your 24 question is asking. 25 Q. So you have never seen Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 40 of 465 Page 40 1 G Maxwell - Confidential 2 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 Q. Is that your testimony? 6 A. I already said I don't recall all 7 the times I've seen her and I have no memory 8 of that. 9 Q. Have you ever seen in 10 the house with Jeffrey Epstein 11 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. I just told you I don't recall 15 seeing 16 Q. Were you ever involved in an orgy 17 with ? 18 A. No, absolutely not. 19 Q. Can you tell me, do you know an 20 individual by the name of Nadia Marcinkova? 21 A. I do. 22 Q. How did you meet Nadia Marcinkova? 23 A. At some point she was a friend of 24 Jeffrey's and I recall meeting her at some 25 point. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 41 of 465 Page 41 1 G Maxwell - Confidential 2 Q. Did you hire her? 3 A. First of all, I don't hire girls 4 like that, so let's be clear, I already 5 testified to that, and I have no idea what 6 you are referring to. 7 Q. When you say girls like that, what 8 do you mean? 9 A. I hire people who are professional 10 at the house. You are asking if I hired 11 somebody to do what, I don't know what you 12 are talking about. I hired people to work in 13 the homes. 14 Q. What was Nadia Marcinkova doing? 15 MR. PAGLIUCA: Object to the form 16 and foundation. 17 A. I have no idea what Nadia 18 Marcinkova was doing. I didn't hire her and 19 I don't know what you are referring to. 20 Q. You met Nadia Marcinkova? 21 A. I testified I did. 22 Q. Did she work for Jeffrey Epstein? 23 A. I have no idea what she did. 24 Q. Have you flown on planes with Nadia 25 Marcinkova? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 42 of 465 Page 42 1 G Maxwell - Confidential 2 A. I don't recollect. I don't know if 3 I did. 4 Q. How many times have you flown on 5 Jeffrey Epstein's planes? 6 A. Too many times. 7 Q. More than 300? 8 A. I really couldn't tell you how 9 many. 10 Q. More than 400? 11 A. Again, I said I cannot tell you how 12 many, a lot. 13 Q. How many times with Nadia 14 Marcinkova? 15 A. I already testified, I have no 16 idea. 17 Q. How old was Nadia Marcinkova when 18 she first became involved with Jeffrey? 19 A. I have no idea. 20 Q. Was she 14? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 A. I have no idea. 24 Q. Did she look like a child the first 25 time you met her? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 43 of 465 Page 43 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. Asked and answered. 4 Q. Did she look like a child the first 5 time you met Nadia Marcinkova? 6 A. I don't know what you mean if she 7 looked like a child. 8 Q. Did she look like she was under the 9 age of 18? 10 A. No. 11 Q. Did she look like she was under the 12 age of 16? 13 A. I just testified -- first of all, I 14 couldn't tell you how old she was, she didn't 15 like like a child, leave it at that. 16 Q. Did you know that she was a child? 17 MR. PAGLIUCA: Object to the form 18 and foundation. 19 A. I just answered I did not know how 20 old she was and she looked like an adult. 21 Q. In the times that you traveled with 22 her on Jeffrey Epstein's planes, did you ever 23 ask her how old she was? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Assumes facts not in Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 44 of 465 Page 44 1 G Maxwell - Confidential 2 evidence. The witness already testified 3 she doesn't remember. 4 Q. You can answer that question. 5 Did you ever ask her on the many 6 flights you were with her or the many times 7 you were with her at the house? 8 A. First of all, I don't know I was on 9 many flights with her, you are making stories 10 up again as usual. And secondly, if I was on 11 a flight with her, there would not be any 12 reason why I would ask her how old she was. 13 Q. You don't recollect having any 14 conversation with her about her age? 15 A. I already testified to that. 16 Q. Do you know what Nadia Marcinkova 17 was hired to do for Jeffrey? 18 A. I already testified I didn't know 19 she was hired and I don't know that she did 20 anything. I don't know how to answer that 21 question. 22 Q. Was Nadia Marcinkova at the house, 23 the Palm Beach house, when you were present 24 at that house? 25 MR. PAGLIUCA: Object to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 45 of 465 Page 45 1 G Maxwell - Confidential 2 foundation. 3 A. I have no recollection of her being 4 at the house at the same time as me. 5 Q. When did you first meet Nadia 6 Marcinkova? 7 A. I already told you I don't recall. 8 Q. Do you recall anything about Nadia 9 Marcinkova? 10 A. That she was tall and blond. 11 Q. Do you recall Nadia Marcinkova 12 interacting with other females at the house? 13 A. No, I do not. 14 Q. Did you arrange to get a visa for 15 Nadia Marcinkova to come into this country? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. Absolutely not. 19 Q. Did Jeffrey arrange for a visa for 20 Nadia Marcinkova? 21 MR. PAGLIUCA: You need to give me 22 a break so I can interpose an objection. 23 Object to the form and foundation. 24 Q. You can answer. 25 A. What was the question? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 46 of 465 Page 46 1 G Maxwell - Confidential 2 Q. Did Jeffrey arrange for a visa for 3 Nadia Marcinkova? 4 A. I don't know what Jeffrey did. I 5 cannot testify what Jeffrey did. 6 Q. Was Nadia involved in sex with 7 Jeffrey and other girls? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 Q. Girls under the age of 18? 11 MR. PAGLIUCA: Same objection. 12 A. I have no idea. 13 Q. Was Nadia involved with sex with 14 Jeffrey and girls over the age of 18? 15 MR. PAGLIUCA: Same objection. 16 A. I have no idea. 17 Q. Did Nadia recruit other girls for 18 sex with Jeffrey? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. I have no idea. 22 Q. Do you still talk to Nadia? 23 A. No. 24 Q. Is she a pilot? 25 A. I have no idea. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 47 of 465 Page 47 1 G Maxwell - Confidential 2 Q. Does she fly with Larry Veseski 3 (phonetic), one of Jeffrey's pilots? 4 A. I have no idea. 5 Q. Are you a pilot? 6 A. I am. 7 Q. Have you flown with Jeffrey Veseki? 8 A. I have. 9 Q. Have you flown with Nadia 10 Marcinkova? 11 A. What do you mean by flown? 12 Q. Have you been on planes with her? 13 A. I already testified I don't recall 14 having her on a plane with me. 15 Q. Do you know Sarah Kellen? 16 A. I do. 17 Q. When did you first meet her? 18 A. I don't recall exact dates. 19 Q. Did you meet her with the purpose 20 of hiring her to work for Jeffrey or having 21 Jeffrey hire her? 22 MR. PAGLIUCA: Object to the form 23 and foundation. 24 A. No. 25 Q. What was her relationship with Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 48 of 465 Page 48 1 G Maxwell - Confidential 2 Jeffrey? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 A. I don't know exactly the nature of 6 her relationship but she worked for him. 7 Q. What did she do? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 A. At the time she when was with him I 11 believe she traveled with him and helped with 12 his travel arrangements. 13 Q. Did she bring girls to the house to 14 give massages to Jeffrey? 15 MR. PAGLIUCA: Object to the form 16 and foundation. 17 A. I don't know what Sarah did. 18 Q. So you never observed Sarah 19 bringing girls to the home to give massages 20 to Jeffrey? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 A. I don't understand the question, 24 what did you mean bring? 25 Q. Did you ever observe Sarah Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 49 of 465 Page 49 1 G Maxwell - Confidential 2 inviting, bringing, walking anyone into the 3 home to give a massage for Jeffrey? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 A. I don't recollect anything like 7 that. 8 Q. Are you aware that Sarah Kellen was 9 a co-conspirator, named as a co-conspirator 10 in the case involving Jeffrey Epstein? 11 MR. PAGLIUCA: Object to the form 12 and foundation and also calls for a 13 legal conclusion. 14 MS. McCAWLEY I'm just asking if she 15 is aware of that. 16 A. I am aware. 17 Q. Who paid Sarah Kellen? 18 A. I have no idea. 19 Q. Did you ever arrange payment for 20 any of the employees at the home? 21 MR. PAGLIUCA: Object to the form. 22 A. What do you mean by arrange? 23 Q. Were you ever in charge or 24 responsible for paying individuals at the 25 home, that worked there? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 50 of 465 Page 50 1 G Maxwell - Confidential 2 A. People had salaries and they were 3 paid by the office. 4 Q. Did you ever pay any individual, 5 did you ever hand an individual cash for work 6 they performed? 7 MR. PAGLIUCA: Object to the form. 8 A. Can you be more specific about what 9 you are asking me. 10 Q. Did you ever hand any individual 11 who was working at the home cash as payment 12 for something that they performed at the 13 home? 14 MR. PAGLIUCA: Object to the form. 15 A. To the best of my recollection 16 there were very few times where I would leave 17 some cash for people for work performed. 18 Q. And what type of work was being 19 performed where you would be doing that? 20 A. If I left cash for the pool guy, I 21 would have left potentially some cash for the 22 gardener, potentially for exercise 23 instructors and sometimes for massage 24 therapy. 25 Q. How much were the massage Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 51 of 465 Page 51 1 G Maxwell - Confidential 2 therapists paid? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 A. They get paid between 100 and $200. 6 Q. Did it vary based on what sexual 7 acts they performed? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 A. No. It varied depending how much 11 time, some massage therapists charge more and 12 some charge less. 13 Q. Did the massage therapists that 14 were hired to come to the home perform sexual 15 acts for Jeffrey Epstein? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. What are you asking me? 19 Q. I'm asking if the massage 20 therapists -- 21 A. Are you asking me about underage 22 girls? 23 Q. I'm asking in general, did any of 24 the massage therapists in the home -- 25 A. Are you asking if they were paid Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 52 of 465 Page 52 1 G Maxwell - Confidential 2 for sexual acts. 3 Q. I'm asking if they performed sexual 4 acts? 5 MR. PAGLIUCA: Object to the form 6 and foundation. 7 Q. Did any of the massage therapists 8 who were at the home perform sexual acts for 9 Jeffrey Epstein? 10 A. I don't know what you mean by 11 sexual acts. 12 Q. Did any of the massage therapists 13 who were working at the home perform sexual 14 acts, including touching the breasts, 15 touching the vaginal area, being touched 16 while Jeffrey is masturbating, having 17 intercourse, any of those things? 18 MR. PAGLIUCA: Objection. Form and 19 foundation. 20 To the extent any of this is asking 21 for to your knowledge any consensual sex 22 act that may or may not have involved 23 you, I'm instructing you not to answer 24 the question. 25 Q. I'm not asking about consensual sex Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 53 of 465 Page 53 1 G Maxwell - Confidential 2 acts. I'm asking whether any of the massage 3 therapists performed sexual acts for Mr. 4 Epstein, as I have just described? 5 A. I have never seen anybody have 6 sexual intercourse with with Jeffrey, ever. 7 Q. I'm not asking about sexual 8 intercourse. I'm asking about any sexual 9 act, touching of the breast -- did you ever 10 see -- can you read back the question? 11 (Record read.) 12 A. I'm not addressing any questions 13 about consensual adult sex. If you want to 14 talk about what the subject matter, which is 15 defamation and lying, Virginia Roberts, that 16 you and Virginia Roberts are participating in 17 perpetrating her lies, I'm happy to address 18 those. I never saw any inappropriate 19 underage activities with Jeffrey ever. 20 Q. I'm not asking about underage. I'm 21 asking about whether any of the masseuses 22 that were at the home perform sexual acts for 23 Jeffrey Epstein? 24 A. I have just answered the question. 25 Q. No, you haven't. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 54 of 465 Page 54 1 G Maxwell - Confidential 2 A. I have. 3 Q. No, you haven't. 4 A. Yes, I have. 5 Q. You are refusing to answer the 6 question. 7 A. Let's move on. 8 Q. I'm in charge of the deposition. I 9 say when we move on and when we don't. 10 You are here to respond to my 11 questions. If you are refusing to answer the 12 court will bring you back for another 13 deposition to answer these questions. 14 Do you understand that? 15 MR. PAGLIUCA: You don't need to 16 threaten the witness. 17 MS. McCAWLEY: I'm not threatening 18 her. I'm making sure the record is 19 clear. 20 MR. PAGLIUCA: Certainly can you 21 apply to have someone come back and the 22 court may or may not have her come back 23 again. 24 Again, she is not answering 25 questions that relate to adult consent Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 55 of 465 Page 55 1 G Maxwell - Confidential 2 sex acts. Period. And that's the 3 instruction and we can take it up with 4 the court. 5 Q. Ms. Maxwell, are you aware of any 6 sexual acts with masseuses and Jeffrey 7 Epstein that were nonconsensual? 8 A. No. 9 Q. How do you know that? 10 A. All the time that I have been in 11 the house I have never seen, heard, nor 12 witnessed, nor have reported to me that any 13 activities took place, that people were in 14 distress, either reported to me by the staff 15 or anyone else. I base my answer based on 16 that. 17 Q. Are you familiar with a person by 18 the name of Annie Farmer? 19 A. I am. 20 Q. Has Annie Farmer given a statement 21 to police about you performing sexual acts on 22 her? 23 A. I have not heard that. 24 Q. Has Annie Farmer given a statement 25 to police about Jeffrey Epstein performing Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 56 of 465 Page 56 1 G Maxwell - Confidential 2 sexual acts on her? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 A. I have not heard that. 6 Q. How do you know Annie Farmer? 7 A. Annie Farmer had a sister and her 8 sister introduced Annie Farmer, I believe, to 9 Jeffrey. 10 Q. Was Annie Farmer under the age of 11 18? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. I don't recall how old Annie Farmer 15 was. 16 Q. Did she tell police that Jeffrey 17 Epstein assaulted her sexually? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 A. I never heard that. 21 Q. Did Sarah Kellen recruit or bring 22 girls to the home that were under the age of 23 18? 24 MR. PAGLIUCA: Object to the form 25 and foundation and I think this has been Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 57 of 465 Page 57 1 G Maxwell - Confidential 2 asked and answered already. 3 Q. You can answer the question. 4 A. I have no idea what Sarah Kellen 5 did. 6 Q. You never observed Sarah Kellen 7 with girls under the age of 18 at Jeffrey's 8 home? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 A. The answer is no, I have no idea. 12 Q. Do you know Glenn Dubin? 13 A. I do. 14 Q. What is your relationship with 15 Glenn Dubin? 16 MR. PAGLIUCA: Object to the form. 17 A. What do you mean what is my 18 relationship. 19 Q. Are you friendly with him, how do 20 you know him? 21 A. He is the husband of Eva Dubin. 22 Q. Is Eva Dubin one of your friends? 23 A. Yes. 24 Q. Did you ever send Virginia to 25 Glenn's condo at the Breakers to give him a Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 58 of 465 Page 58 1 G Maxwell - Confidential 2 massage? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. No. 6 Q. Did you ever instruct Virginia 7 Roberts to have sex with Glenn? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I have never instructed Virginia to 11 have sex with anybody ever. 12 Q. How old was Eva Anderson when she 13 met Jeffrey? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. I have no idea. 17 Q. What's she under the age of 18? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I just testified I have idea how 21 old she was. 22 Q. You testified she was your friend. 23 You don't know how old she was when she met 24 Jeffrey? 25 A. That happened sometime in the '70s, Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 59 of 465 Page 59 1 G Maxwell - Confidential 2 how would I know, or '80s. I have no idea. 3 Can you testify to what your friends did 30 4 years ago? 5 Q. You don't ask the questions here, 6 Ms. Maxwell. 7 What about Johanna Sjoberg, when 8 did you first meet Johanna? 9 A. I don't recall the exact date. 10 Q. Did you hire Johanna? 11 A. I don't hire people, she came to 12 work at the house to answer phones. 13 Q. Where did you meet her? 14 A. I just testified, I don't recall 15 exactly when I met her. 16 Q. Was one of your job 17 responsibilities to interview people that 18 would be then hired by Jeffrey? 19 A. That was one of my 20 responsibilities. 21 Q. Do you recall interviewing Johanna? 22 A. I don't recall the exact interview, 23 no. 24 Q. Do you know what tasks Johanna was 25 hired to performance? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 60 of 465 Page 60 1 G Maxwell - Confidential 2 A. She was tasked to answer 3 telephones. 4 Q. Did you ever ask her to rub 5 Jeffrey's feet? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I believe that I have read that, 9 but I don't have any memory of it. 10 Q. Did you ever tell Johanna that she 11 would get extra money if she provided Jeffrey 12 massages? 13 A. I was always happy to give career 14 advice to people and I think that becoming 15 somebody in the healthcare profession, either 16 exercise instructor or nutritionist or 17 professional massage therapist is an 18 excellent job opportunity. Hourly wages are 19 around 7, 8, $9 and as a professional 20 healthcare provider you can earn somewhere 21 between as we have established 100 to $200 22 and to be able to travel and have a job that 23 pays that is a wonderful job opportunity. So 24 in the context of advising people for 25 opportunities for work, it is possible that I Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 61 of 465 Page 61 1 G Maxwell - Confidential 2 would have said that she should explore that 3 as an option. 4 Q. Did you tell her she would get 5 extra money if she massaged Jeffrey? 6 A. I'm just saying, I cannot recall 7 the exact conversation. I give career advice 8 and I have done that. 9 Q. Did you ever have Johanna massage 10 you? 11 A. I did. 12 Q. How many times? 13 A. I don't recall how many times. 14 Q. Was there sex involved? 15 A. No. 16 Q. Did you ever instruct Johanna to 17 massage Glenn Dubin? 18 A. I don't believe -- I have no 19 recollection of it. 20 Q. Did you ever have sexual contact 21 with Johanna? 22 MR. PAGLIUCA: Object to the form 23 and foundation. You need to give me an 24 opportunity to get in between the 25 questions. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 62 of 465 Page 62 1 G Maxwell - Confidential 2 Anything that involves consensual 3 sex on your part, I'm instructing you 4 not to answer. 5 Q. Did you ever have sexual contact 6 with Johanna? 7 A. Again, she is an adult -- 8 Q. I'm asking you, did you ever have 9 sexual contact with Johanna? 10 A. I've just been instructed not to 11 answer. 12 Q. On what basis? 13 A. You have to ask my lawyer. 14 Q. Did you ever have sexual contact 15 with Johanna that was not consensual on 16 Johanna's part? 17 MR. PAGLIUCA: You can answer 18 nonconsensual. 19 A. I've never had nonconsensual sex 20 with anybody. 21 Q. Not Annie Farmer? 22 MR. PAGLIUCA: Objection. 23 A. I just testified I never had 24 nonconsensual sex with anybody ever, at any 25 time, at anyplace, at any time, with anybody. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 63 of 465 Page 63 1 G Maxwell - Confidential 2 Q. So if Johanna were to testify that 3 she did not consent to a sexual act that you 4 participated in -- 5 A. I just told you I have never ever 6 under any circumstances with anybody, at any 7 time, in anyplace, in any form had 8 nonconsensual relations with anybody. 9 Q. Did you introduce Johanna to Prince 10 Andrew? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I've, again, read that Johanna 14 claimed that she met or that she said she met 15 Prince Andrew. I don't know if I was the one 16 who made the introduction or not. 17 Q. Do you know a female by the name of 18 Emmy Taylor? 19 A. I do. 20 Q. How do you know her? 21 A. Emmy was my assistant. 22 Q. So she worked for you? 23 A. Yes. 24 Q. Did you hire her? 25 A. Again, Jeffrey hired people. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 64 of 465 Page 64 1 G Maxwell - Confidential 2 Q. Did you have sex with her? 3 MR. PAGLIUCA: This is the same 4 instruction about consensual or 5 nonconsensual. 6 Q. Was Emmy under the age of 18 when 7 you hired her? 8 A. No. I didn't hire her, as I said, 9 Jeffrey did. 10 Q. Did Emmy ever have sex with 11 Jeffrey? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. How would I know what somebody else 15 did. 16 Q. You weren't involved in the sex 17 between Jeffrey, Emmy and yourself? 18 A. We already -- 19 Q. Were you involved with sex between 20 Jeffrey, Emmy and yourself? 21 MR. PAGLIUCA: Everyone is talking 22 over each other. You heard the 23 question. 24 Again, you you know what the 25 instruction is. If there is any Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 65 of 465 Page 65 1 G Maxwell - Confidential 2 consensual issue involved, I instruct 3 you not to answer. 4 A. Moving on. 5 Q. So you are refusing to answer that 6 question? 7 A. I've been instructed by my lawyer. 8 Q. Did you ever have sex with Jeffrey, 9 Emmy, Virginia and yourself when Virginia was 10 underage? 11 A. Absolutely not. 12 MR. PAGLIUCA: We've been going for 13 about an hour. I would like to take a 14 five-minute break, please. 15 MS. McCAWLEY: I'm almost done. 16 MR. PAGLIUCA: You are not going to 17 allow a break. 18 MS. McCAWLEY: As soon as I get 19 through my line of questioning, which is 20 perfectly appropriate. 21 Q. Did Emmy Taylor travel with you and 22 Jeffrey to Europe? 23 A. I'm sure she did. 24 Q. What is she doing today? 25 A. I have no idea. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 66 of 465 Page 66 1 G Maxwell - Confidential 2 Q. Do you speak to her regularly now, 3 do you speak to her? 4 A. No. 5 Q. Do you know where she lives? 6 A. No. 7 Q. Do you know what country she lives 8 in? 9 A. No. 10 Q. Where is the last place you knew 11 that she lived? 12 A. Last place I knew for sure was in 13 Los Angeles. 14 Q. When did she stop working for you? 15 A. 2001, 2002. 16 Q. What tasks did she performance for 17 you? 18 A. She helped me with moving in and 19 out of houses, construction, she was a 20 general help, she helped with buying things 21 that needed to be purchased, if I needed her 22 to stand in for me during meetings, it was a 23 very wide ranging job. 24 Q. Did she ever bring females to 25 perform massages for Jeffrey? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 67 of 465 Page 67 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. What are you asking me? 5 Q. Did Emmy, was it ever Emmy's 6 responsibility to bring females to the house 7 for the purposes of massaging Jeffrey? 8 A. Emmy's job was to help me with the 9 houses and work in homes. It was not her job 10 to whatever you just said, bring masseuses. 11 Q. Did she do that? 12 A. I have no recollection. I have no 13 idea. 14 Q. Did you pay Emmy or did Jeffrey pay 15 her? 16 A. Jeffrey. 17 Q. Do you recall how much she was 18 paid? 19 A. I do not. 20 MS. McCAWLEY: I think we can take 21 a break now. 22 THE VIDEOGRAPHER: It's 10:02 and 23 we are off the record. 24 (Recess.) 25 THE VIDEOGRAPHER: It's now 10:18. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 68 of 465 Page 68 1 G Maxwell - Confidential 2 We are back on the record and starting 3 disk No. 2. 4 Q. Ms. Maxwell, I asked you about 5 Virginia Roberts earlier. 6 Can you describe what Virginia 7 Roberts' duties were when she was with Mr. 8 Epstein? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I believe that Virginia was a 12 masseuse. 13 Q. Was Virginia required to dress up 14 in any way for massages? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I have no idea. 18 Q. Did you provide Virginia with 19 outfits to wear for certain massages? 20 A. I have no idea what you are talking 21 about. 22 Q. For example, did you ever provide 23 Virginia with a school girl outfit to wear 24 for a massage? 25 A. I have no idea what you are talking Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 69 of 465 Page 69 1 G Maxwell - Confidential 2 about. 3 Q. So you didn't provide her with 4 that? 5 A. As I just testified, I have no idea 6 what you are talking about. 7 Q. I was trying to interpret whether 8 you didn't understand what a school girl 9 outfit was or you are saying that didn't 10 happen? 11 A. I clearly know what a school girl 12 outfit is. I have no recollection of 13 providing anybody with a school girl outfit. 14 Q. Did you have a set of outfits used 15 by the massage therapists that would include 16 things like a school girl outfit or a black 17 patent leather outfit or anything of that 18 nature? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. That would be just another one of 22 Virginia's lies. 23 Q. You didn't have anything like that? 24 A. I did not. 25 Q. Did you have a basket of sex toys Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 70 of 465 Page 70 1 G Maxwell - Confidential 2 that you kept in the Palm Beach house? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. First of all what do you mean. 6 Q. A laundry basket that contained sex 7 toys in it? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. Can you ask the question again? 11 Q. Did you have a laundry basket that 12 contained sex toys in it, in the Palm Beach 13 House? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 Q. Did you have a laundry basket of 17 sex toys in the Palm Beach house? 18 MR. PAGLIUCA: Same objection. 19 Q. You can answer. 20 A. I don't recollect anything about a 21 laundry basket of sex toys. 22 Q. Do you recollect having sex toys at 23 the Palm Beach house? 24 A. You have to define what are you 25 talking about. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 71 of 465 Page 71 1 G Maxwell - Confidential 2 Q. A sex toy meaning a vibrator of 3 some kind, sometimes they are called dildos, 4 of that nature, anything like that? 5 A. I don't recollect anything that 6 would formally be a dildo, anything like 7 that. 8 Q. How would you describe sex toys? 9 A. I wouldn't describe sex toys. 10 Q. Did you have anything that was of 11 an electronic nature that would be used 12 during sex? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I have no idea what you are 16 referring to. 17 (Maxwell Exhibit 3, transcript, 18 marked for identification.) 19 Q. Ms. Maxwell, I will show you what 20 we are marking as Maxwell Exhibit 3. 21 If you look at the cover you will 22 see it's a deposition transcript of Juan 23 Alessi, do you know who Juan Alessi is? 24 A. I do. 25 Q. Who is he? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 72 of 465 Page 72 1 G Maxwell - Confidential 2 A. He was somebody who Jeffrey hired 3 who worked at the house in Palm Beach. 4 Q. I would like to have you turn to 5 page, it should be page 76 of the actual 6 transcript? 7 MR. PAGLIUCA: We have two 8 transcripts. 9 Q. The mini version I think it is 10 there. 11 A. I don't have page 76. 12 Q. So in the miniscript portion here, 13 the beginning, there should be a page that 14 looks like this, it's got a 76 at the top in 15 the small square. Are you finding that, it's 16 not too far back, I don't believe, it says 17 page 19 the the bottom. 18 A. Okay. 19 Q. It's a miniscript like this. It 20 has four squares? 21 MS. MENNINGER: 109 or 19. 22 MS. McCAWLEY: 19. 23 MR. PAGLIUCA: The Bates label is 24 000109. 25 MS. McCAWLEY: Exactly. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 73 of 465 Page 73 1 G Maxwell - Confidential 2 Q. I will direct your attention to 3 page 76 in the deposition of Juan Alessi and 4 it says, Would you describe for me what kinds 5 of vibrators you found, question mark. The 6 answer is, I'm not familiar, not too familiar 7 with the names. They were big dildos, what 8 they call big rubber things like that, 9 indicating. 10 A. I can't find where you are looking. 11 Q. Page 76, right here. 12 A. I need to be able to read this. I 13 will not be answering anything I have not 14 read. You can read it out and then I will 15 read it. 16 Q. Where was I. And I used to go and 17 put on my gloves and pick them up and put 18 them in the sink, rinse it off and put it in 19 Ms. Maxwell's -- Ms. Maxwell had in her 20 closet -- she had like a laundry basket, one 21 of those laundry baskets that you put laundry 22 in, she had full of these toys and that was 23 -- that was me professionally leaving the 24 room ready for the bed when they come back to 25 the room again. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 74 of 465 Page 74 1 G Maxwell - Confidential 2 Does that refresh your recollection 3 that you had a laundry basket full of sex 4 toys? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. First I have to read this. 8 Q. Sure. 9 MS. McCAWLEY: I will stop the 10 clock while the witness is reading. 11 MR. PAGLIUCA: No. 12 MS. McCAWLEY: Yes, if she is going 13 to read the whole document, I will stop 14 the clock. 15 MR. PAGLIUCA: If you give her 16 documents to refresh her recollection, 17 we are on the clock here. 18 MS. McCAWLEY: Then we will take it 19 up with the judge. 20 MR. PAGLIUCA: Read whatever you 21 need to answer the question. 22 MS. McCAWLEY: I'm going to set the 23 document aside and I'm just go to ask 24 you a question, independent of the 25 document. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 75 of 465 Page 75 1 G Maxwell - Confidential 2 Q. Do you recall having a basket full 3 of sex toys? 4 A. I already told you I did not. 5 Q. We were talking a moment ago about 6 Ms. Roberts and her position as a masseuse, 7 do you know what she was paid for working as 8 a masseuse for Jeffrey Epstein? 9 A. I do not. 10 Q. Did you ever pay her? 11 A. I don't ever recall paying her. 12 Q. Do you know what happened during 13 the massage appointments with Jeffrey Epstein 14 and Virginia Roberts? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. No. 18 Q. Were you ever present to view a 19 massage between Jeffrey Epstein and Virginia 20 Roberts? 21 A. I don't recollect ever seeing 22 Virginia and Jeffrey in a massage situation. 23 Q. Do you ever recollect seeing them 24 in a sexual situation? 25 A. I never saw them in a sexual Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 76 of 465 Page 76 1 G Maxwell - Confidential 2 situation. 3 Q. Did you ever participate in sex 4 with Virginia Roberts and Jeffrey Epstein? 5 A. I never ever at any single time at 6 any point ever at all participated in 7 anything with Virginia and Jeffrey. And for 8 the record, she is an absolute total liar and 9 you all know she lied on multiple things and 10 that is just one other disgusting thing she 11 added. 12 Q. Did you help her obtain an 13 apartment in Palm Beach to live in? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 Q. Was that part of your 17 responsibilities for Jeffrey? 18 A. First of all, I didn't know she had 19 an apartment in Palm Beach. I only learned 20 that from the many times you guys have gone 21 to the press to sell stories, so no. 22 Q. Did you help her get a cell phone, 23 was that one of your responsibilities for 24 Jeffrey, to get her is a cell phone as part 25 of her masseuse obligations? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 77 of 465 Page 77 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I don't know what that means, 5 masseuse obligation, I don't know what you 6 are referring to. Would you like to ask the 7 question properly? 8 Q. I think it was proper. I will ask 9 it again. 10 Did you ever assist in getting 11 Virginia Roberts a cell phone to use during 12 the time that she worked for Jeffrey Epstein? 13 A. I have no recollection of doing 14 anything of that nature. 15 Q. Did you ever tell Virginia that you 16 wanted her to have a cell phone so that she 17 could be on call regularly? 18 A. I have no recollection of that 19 conversation. 20 Q. How often would Virginia come over 21 to the house in Palm Beach to give massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Ask the question again, please. 25 Q. How often did Virginia Roberts come Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 78 of 465 Page 78 1 G Maxwell - Confidential 2 over to the house in Palm Beach to give 3 massages? 4 A. It's important to understand that I 5 wasn't with Jeffrey all the time. In fact, I 6 was only in the house less than half the 7 time, so I cannot testify to when I wasn't in 8 the house how often she came when I wasn't 9 there. 10 What I can say is that I barely 11 would remember her, if not for all of this 12 rubbish, I probably wouldn't remember her at 13 all, except she did come from time to time 14 but I don't recollect her coming as often as 15 she portrayed herself. 16 Q. How many times a day on an average 17 day would Jeffrey Epstein get a massage? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. When I was at the house and when I 21 was there with him, he received a massage, on 22 average, about once a day. 23 Q. Just once? 24 A. Yes. 25 Q. Were there days when he received Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 79 of 465 Page 79 1 G Maxwell - Confidential 2 four or five? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. When I was present at the house, I 6 never saw something like that. 7 Q. Do you know if Virginia was 8 required to be on call at all times to come 9 to the house if Jeffrey wanted her there? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I have no idea of the arrangements 13 that Virginia made with Jeffrey. 14 Q. When Virginia was in New York, 15 would Virginia sleep at Jeffrey's mansion in 16 New York? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I don't recollect her being in New 20 York and I have no idea where she slept. 21 Q. You don't ever remember seeing 22 Virginia Roberts in New York? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I would barely recollect her at Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 80 of 465 Page 80 1 G Maxwell - Confidential 2 all, except for this story. 3 Q. Do you recall Virginia Roberts 4 calling you because she was having a medical 5 crisis and you and Jeffrey taking her to the 6 hospital? 7 A. I have heard this absurd story and 8 if any part of it were true I would remember 9 that. I do not. 10 Q. You don't remember taking her to 11 the hospital? 12 A. It's not that I don't remember it, 13 it didn't happen. 14 Q. How do you know it didn't happen? 15 A. That's the sort of memory you would 16 recall. 17 Q. Do you recall, you said you don't 18 remember her being at the New York mansion. 19 When you were in New York would you stay at 20 the New York mansion with Jeffrey? 21 A. I stayed from time to time. 22 Q. Do you recall Virginia being at the 23 New York mansion when Prince Andrew came to 24 visit? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 81 of 465 Page 81 1 G Maxwell - Confidential 2 form and foundation. 3 A. Like I told you, I don't recall her 4 being at the house at all. 5 Q. How many homes does Jeffrey have? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. When I was working for him, I think 9 he had six maybe. 10 Q. Would Virginia stay with him in 11 those homes? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I can only testify for when I was 15 present with him and I cannot say what she 16 did when I wasn't present with him. 17 Q. When you were present, would 18 Virginia stay in the homes with him? 19 A. I don't recall her staying in the 20 houses. 21 Q. Did you train Virginia on how to 22 recruit other girls for massages? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. No. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 82 of 465 Page 82 1 G Maxwell - Confidential 2 Q. Did you train Virginia on how to 3 recruit other girls to perform sexual 4 massages? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. No. And it's absurd and her entire 8 story is one giant tissue of lies and 9 furthermore, she herself has -- if she says 10 that, you have to ask her about what she did. 11 Q. Does Jeffrey like to have his 12 nipples pinched during sexual encounters? 13 MR. PAGLIUCA: Objection to form 14 and foundation. 15 A. I'm not referring to any advice on 16 my counsel. I'm not talking about any adult 17 sexual things when I was with him. 18 Q. When Jeffrey would have a massage, 19 would he request that the masseuse pinch his 20 nipples while he was having a massage? 21 A. I'm not talking about anything with 22 consensual adult situation. 23 Q. What about with underage -- 24 A. I am not aware of anything. 25 Q. You are not aware of Jeffrey Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 83 of 465 Page 83 1 G Maxwell - Confidential 2 Epstein ever having sex with an underage 3 minor and asking them to pinch his nipples? 4 A. I am not. 5 Q. So I'm going to direct you to, I 6 believe it's Maxwell Exhibit 1, the police 7 report. 8 Are you aware that over 30 under 9 age minors gave testimony to police that they 10 were engaged in sexual acts during, 11 quote-unquote, massages. 12 MR. PAGLIUCA: The witness needs to 13 find Exhibit 1. Exhibit 1 -- if you can 14 hand me that please. 15 Q. So now with respect to the police 16 report, are you aware that over 30 underage 17 girls, meaning under the age of 18 gave 18 reports to police that they were assaulted 19 sexually by Jeffrey Epstein during massages? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I read the police report. That's 23 all I can testify to. 24 Q. Are you aware of what is in the 25 police report? Are you aware that there were Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 84 of 465 Page 84 1 G Maxwell - Confidential 2 30 girls -- 3 A. I did not count the number of girls 4 and I did read the police report. I can only 5 testify to what I read. 6 Q. So you are aware that the police 7 report contains reports from 30 underage 8 girls? 9 A. I can't testify to what the girls 10 said. I can only testify to the fact that I 11 read a police report that stated that. 12 Q. Were you working for Jeffrey -- you 13 said you worked for him off an on until 2009, 14 is that correct? 15 A. I helped out from time to time. 16 Q. So you were working with him during 17 the time period when these underage girls 18 were visiting Jeffrey's home? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I was not -- what year, I need 22 years. 23 Q. How about let's say 2005? 24 A. I'm not sure I was at the house at 25 all in 2005, maybe one day, maybe. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 85 of 465 Page 85 1 G Maxwell - Confidential 2 Q. How about 2004? 3 A. I was present for his mother's -- 4 his mother died in 2004 so I was there for 5 his mother's death and the funeral and I was 6 at the house maybe a handful of days, again. 7 Q. I would like to direct you to, you 8 have it pulled together now, it's page 39, 9 Bates stamped Giuffre 00040? 10 A. Can you repeat that, please. 11 Q. Sure. 00040. 12 A. Yes. 13 Q. At the top of that document, about 14 three lines down, you see the redacted 15 portions where there is black so it blacks 16 out the name. 17 A. I see black redacted portions. 18 Q. That's a black redaction of the 19 name of the minor and there is -- I will 20 represent for the record that's what it is. 21 You can contest that but I'm not asking about 22 the name of the minor. 23 Five lines down, it says, She was 24 just 16 years of age. 25 Do you see that? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 86 of 465 Page 86 1 G Maxwell - Confidential 2 A. I have to read that, if you want me 3 to testify to some things. 4 Q. I'm asking if you see where it 5 says, She was just 16 years old. 6 A. No, I have to read it. 7 Q. It's five line downs on the first 8 paragraph. 9 A. I do see that. 10 Q. Then the next paragraph down, it 11 says, this is the next full paragraph, it 12 says, Epstein entered the room, introduced 13 himself, Epstein lay on the table and told 14 her to get comfortable, blank could not 15 remember if he was naked or if he entered the 16 room with a towel. Blank stated she provided 17 the massage wearing her panties. She 18 continued rubbing his thighs and feet. Blank 19 advised he turned over on his back and 20 continued to rub his legs with oil. Epstein 21 touched her breast and began to masturbate. 22 I asked if she knew what circumcised and 23 uncircumcised meant. She stated circumcised 24 is when the penis had no foreskin. 25 Then jumping down to the next Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 87 of 465 Page 87 1 G Maxwell - Confidential 2 paragraph, it says, Blank became upset, 3 crying hysterically and stated she was paid 4 and also instructed to have sex with Epstein 5 and Nadia Marcinkova by Epstein. 6 Do you see that there? 7 A. I do. 8 Q. Are you aware that there were 9 underage minors in the Palm Beach house that 10 were required to give sexual massages to 11 Jeffrey Epstein? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. This has been 14 asked and answered already. Now you are 15 just reading a document. 16 MS. McCAWLEY: I am allowed to take 17 this deposition. 18 A. I already testified -- 19 Q. Are you aware there were underage 20 girls, 30 of them, in this police report that 21 were assaulted by Jeffrey Epstein in the Palm 22 Beach house during the time you are working 23 there? 24 A. I am aware that Virginia has 25 lied repeatedly -- Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 88 of 465 Page 88 1 G Maxwell - Confidential 2 Q. I'm not asking about Virginia. I'm 3 asking if you are aware that there were over 4 30 underage girls who gave reports to police 5 officers during the time you worked for 6 Jeffrey Epstein. Are you aware of that? 7 MR. PAGLIUCA: Counsel, what is 8 your factual basis for asserting there 9 are 30 underaged people who gave 10 reports? 11 MS. McCAWLEY: I don't have to 12 answer that. 13 MR. PAGLIUCA: Are you representing 14 as an officer of the court that you have 15 personal knowledge that there are 30 16 people referenced in these police 17 reports? 18 MS. McCAWLEY: That's my 19 understanding, that there are 30 girls. 20 MR. PAGLIUCA: How is that your 21 understanding if these are redacted 22 reports? 23 MS. McCAWLEY: By reading through 24 the reports. 25 MR. PAGLIUCA: So you have personal Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 89 of 465 Page 89 1 G Maxwell - Confidential 2 knowledge there are 30 people -- 3 MS. McCAWLEY: Just like can you if 4 you read through -- I will not argue 5 with you counsel.. she can answer yes or 6 no. 7 Q. Are you aware there were over 30 8 individuals who were minors who gave reports 9 to police just like the one we just read that 10 they were sexually assaulted by Jeffrey 11 Epstein in the Palm Beach home during the 12 years that you were working with him? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. You can answer if 15 you have knowledge. 16 A. I already testified I was limited 17 in the house, a couple of days, there is no 18 way I knew. I have read these reports. I 19 cannot testify to 30. Given the experience 20 I've had with Virginia's lies, it's very hard 21 for me to testify about what I see. I can 22 tell from you my personal knowledge I did not 23 know what you are referring to. 24 Q. You did not know there were 25 underage girls in the home that were being Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 90 of 465 Page 90 1 G Maxwell - Confidential 2 assaulted by Jeffrey Epstein during the time 3 you were working there? 4 A. Based on the lies that I have 5 already been told, I cannot comment on any -- 6 Q. Are you saying these 30 girls are 7 lying when they gave these reports to police 8 officers? 9 A. I'm not testifying to their lies. 10 I'm testifying to Virginia's lies. 11 Q. I am not asking about Virginia's 12 lies. 13 A. I can only testify to Virginia's 14 lies. I can testify to having read these 15 reports. I cannot testify to anything else 16 about them. 17 Q. So your testimony is that during 18 the time you were working there, you did not 19 know that these minor children were being 20 abused in the home while you were there? 21 A. What I have already told you and I 22 will repeat, I was in the house very limited 23 times, very few times. I do not know what 24 you are referring to. I've read these 25 reports but based on the lies that Virginia Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 91 of 465 Page 91 1 G Maxwell - Confidential 2 has perpetrated, cannot tell you what is true 3 or factual or not. 4 Q. You said you were in the home a 5 very limited time, so average in the year for 6 example, 2004, how many times would you have 7 been in his Palm Beach home? 8 A. Very hard for me to state but very 9 little. 10 Q. How about his New York home? 11 A. Same. 12 Q. Were you his girlfriend in that 13 year, in 2004? 14 A. Define what you mean by girlfriend. 15 Q. Were you in a relationship with him 16 where you would consider yourself his 17 girlfriend? 18 A. No. 19 Q. Did you ever consider yourself his 20 girlfriend? 21 A. That's a tricky question. There 22 were times when I would have liked to think 23 of myself as his girlfriend. 24 Q. When would that have been? 25 A. Probably in the early '90s. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 92 of 465 Page 92 1 G Maxwell - Confidential 2 Q. In your responsibilities in working 3 for Jeffrey, would you book massages for him 4 on any given day so that he would have a 5 massage scheduled? Would you take a call for 6 example and book a massage for him? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 Q. You can answer. 10 A. Typically, that was not my 11 responsibility. He would either book the 12 massage himself or one of his other 13 assistants would do that. 14 Q. From time to time you had to do 15 that? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Like I said, typically it was 19 somebody else's responsibility. 20 Q. If you were unable to book a girl 21 for a massage on a given day, would that mean 22 that you were responsible for giving him a 23 sexual massage? 24 MR. PAGLIUCA: Objection to the 25 form and foundation and I instruct you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 93 of 465 Page 93 1 G Maxwell - Confidential 2 not to answer any questions about any of 3 your consensual adult sexual activity. 4 Q. So you are not going to answer that 5 question? 6 A. You just heard my counsel. 7 Q. Have you ever said to anybody that 8 recruiting other girls to perform sexual 9 massages for Jeffrey Epstein takes the 10 pressure off you? 11 MR. PAGLIUCA: Object to the form 12 and foundation. 13 A. Repeat the question and break it 14 out. 15 Q. Have you ever said to anybody that 16 you recruit girls -- 17 A. Stop right there. I never 18 recruited girls, let's stop there. Now 19 breakdown the question. 20 Q. Have you ever said to anybody -- 21 A. By girls, we are talking about 22 underage people -- you said girls, are you 23 talking about underage -- we are not talking 24 about consensual acts -- this is a defamation 25 suit. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 94 of 465 Page 94 1 G Maxwell - Confidential 2 Q. I'm asking the questions. I know 3 what this case is about. I'm trying to -- I 4 will ask you questions if you don't 5 understand the question I can break it down 6 for you. I'm happy to do that. 7 A. Break it down a lot please. 8 Q. I will do that. 9 The question is, have you ever said 10 to anybody that you recruit other girls -- 11 A. Why don't you stop there. 12 Q. Let me finish my question. 13 Have you ever said to anybody that 14 you recruit girls to take the pressure off 15 you, so you won't have to have sex with 16 Jeffrey, have you said that? 17 That's the question? 18 A. You don't ask me questions like 19 that. First of all, you are trying to trap 20 me, I will not be trapped. You are asking me 21 if I recruit, I told you no. Girls meaning 22 underage, I already said I don't do that with 23 underage people and as to ask me about a 24 specific conversation I had with language, we 25 talking about almost 17 years ago when this Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 95 of 465 Page 95 1 G Maxwell - Confidential 2 took place. I cannot testify to an actual 3 conversation or language that I used with 4 anybody at any time. 5 Q. Have you ever said to anybody that 6 you recruit other females over the age of 18 7 to take the pressure off you to having to 8 have sex with Jeffrey? 9 A. I totally resent and find it 10 disgusting that you use the word recruit. I 11 already told you I don't know what you are 12 saying about that and your implication is 13 repulsive. 14 Q. Answer my question. 15 A. I just did. 16 Q. Have you ever said to anybody that 17 you recruit females -- 18 A. I don't recruit anybody. 19 Q. That's an answer. So you never 20 said that? 21 A. I'm testifying that I cannot 22 testify to an actual language -- 23 Q. It's a yes or no. 24 A. I will not testify to an actual 25 statement made 17 years ago, so I cannot Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 96 of 465 Page 96 1 G Maxwell - Confidential 2 testify to actual language. 3 Q. So you won't testify to anything 4 I'm asking you 17 years ago about a statement 5 you made. How do you know it's 17 years ago? 6 A. We are talking about a time in 7 2000, right? 8 Q. Have you ever said that to anybody? 9 A. I'm 54 years old so you are asking 10 me in my entire life, what words are you 11 asking me in my entire life? 12 Q. Your entire life is limited by the 13 time you were with Jeffrey, this is the 14 question. 15 A. Let's time limit the question you 16 are asking me. 17 Q. So from, let's say, I think you 18 said you started with him in 1992, is that 19 correct, and finished with him in 2009. 20 So from 1992 to 2009 have you ever 21 said to anybody that you recruit other and we 22 will start with girls to take the pressure 23 off you to have sex with Jeffrey? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 97 of 465 Page 97 1 G Maxwell - Confidential 2 A. First of all I resent and despise 3 the world recruit. Would you like to define 4 what you mean by recruit and by girls, you 5 mean underage people. I never had to do 6 anything with underage people. So why don't 7 you reask the question in a way that I am 8 able to answer it. 9 Q. I'm asking if you ever said that to 10 anybody. So if you don't understand the word 11 recruit and you never used that word then the 12 answer to that question would be no. 13 A. I have no memory as I sit here 14 today having used that word. 15 Q. Did you ever meet an underage girl 16 in London to introduce her to Jeffrey to 17 provide him with a massage? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. Run that past me one more time. 21 Q. Did you ever meet an underage girl 22 in London to introduce her to Jeffrey to 23 perform a massage? 24 MR. PAGLIUCA: Same objection. 25 A. Are you asking me if I met anybody Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 98 of 465 Page 98 1 G Maxwell - Confidential 2 that was underage in London specifically to 3 provide a massage to Jeffrey, is that your 4 question? 5 Q. Yes. 6 A. No. 7 Q. Do you know who Alexander Dixon is? 8 A. I don't recall her right now. 9 Q. Do you know if -- strike that. 10 During the time that you were 11 working for Jeffrey, did you ever observe any 12 foreign females, so in other words, not from 13 the United States, that were brought to 14 Jeffrey's home to perform massages? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. Females, what age are we talking? 18 Q. Any age. 19 A. Can you repeat the question? 20 Q. During the time you were working 21 for Jeffrey, did you ever observe any foreign 22 females of any age that were at Jeffrey's 23 home to perform a massage? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 99 of 465 Page 99 1 G Maxwell - Confidential 2 A. Are you asking me if any foreigner, 3 not an American person, gave Jeffrey a 4 massage? 5 Q. Yes. 6 A. Well, as I sit here today, I can't 7 think of anyone who is foreign. Certainly -- 8 I just can't think of anybody right this 9 second. 10 Q. How about any foreign girls who 11 were under the age of 18? 12 A. I already testified to not knowing 13 anything about underage girls. 14 Q. Were there foreign girls who were 15 brought to Jeffrey's home by Jean Luc Brunel 16 for the purposes of providing massages? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I am not aware of Jean Luc bringing 20 girls. I have not no idea what you are 21 talking about. 22 Q. You have never been around foreign 23 girls who are under the age of 18 at 24 Jeffrey's homes? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 100 of 465 Page 100 1 G Maxwell - Confidential 2 form and foundation. 3 A. I already testified about not 4 knowing about underage girls. 5 Q. Did you provide any assistance with 6 obtaining visas for foreign girls that were 7 under the age of 18? 8 A. I've never participated in helping 9 people of any age to get visas. 10 Q. Did Jeffrey, was it Jeffrey's 11 preference to start a massage with sex? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I think you should ask that 15 question of Jeffrey. 16 Q. Do you know? 17 A. I don't believe that was his 18 preference. I think -- you have to 19 understand, a massage -- perhaps you are not 20 really familiar with what massage is. 21 Q. I am, I don't need a lecture on 22 massage. 23 A. I think you do. 24 MR. PAGLIUCA: No question pending. 25 She will ask you another question now. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 101 of 465 Page 101 1 G Maxwell - Confidential 2 A. Massage is for health benefits. 3 Q. When did you first meet Jeffrey? 4 A. Some point in 1991. 5 Q. And did Jeffrey know your father? 6 A. No. 7 Q. How were you introduced to Jeffrey? 8 A. Some friend introduced us. 9 Q. Can you describe your relationship 10 back in 1991, was it friendship or was it 11 girlfriend relationship or was it a work 12 relationship, what was your relationship in 13 1991? 14 A. It was just friendly. 15 Q. Then I believe you testified you 16 began working for him in 1992, is that 17 correct? 18 A. Yes. 19 Q. In 1992 I know you gave me the 20 description of the work that you were 21 performing for him, how much was he paying 22 you, do you remember? 23 A. I don't recall. 24 Q. Do you know for example in 2001 how 25 much he was paying you? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 102 of 465 Page 102 1 G Maxwell - Confidential 2 A. I don't recall. 3 Q. Did it change over the years or did 4 the payment remain the same? 5 A. I believe over the course of time 6 it increased a little bit. 7 Q. Was that the -- was that payment 8 the payment that -- was the payment made with 9 respect to the jobs, the work you were 10 performing for Jeffrey, was that your sole 11 income at that time? 12 MR. PAGLIUCA: I object to the 13 form. I'm also going to instruct you 14 not to answer about sources of -- your 15 personal sources of income outside of 16 Mr. Epstein at all. 17 MS. McCAWLEY: What's the basis for 18 that? 19 MR. PAGLIUCA: It's confidential, 20 it's not part of this lawsuit. 21 MS. McCAWLEY: We have a protective 22 order and it is part of this lawsuit 23 with respect to our damage claims. 24 MR. PAGLIUCA: It's not and, in 25 fact, you are not entitled to ask Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 103 of 465 Page 103 1 G Maxwell - Confidential 2 financial information of a defendant in 3 this kind of case, in a defamation case 4 unless and until there is a finding that 5 you are entitled to punitive damages. 6 That is clear in New York case law, both 7 state and Federal. 8 MS. McCAWLEY: We disagree on that 9 point and we will come back to that. 10 Q. From the source of payment from the 11 source of Jeffrey, from your work, can you 12 give me a range on that, do you know was it 13 over $100,000? 14 A. I just testified I don't recall. 15 Q. You don't don't know if it was 16 $500,000? 17 A. It was less than that. 18 Q. Somewhere between 100 and 500, 19 would that be fair to say? 20 A. I believe it was between 100 and 21 $200,000. 22 Q. Did Jeffrey during the time that 23 you were working for him purchase a town home 24 for you? 25 A. The subject of the townhouse is, I Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 104 of 465 Page 104 1 G Maxwell - Confidential 2 worked for it and I had a loan, we did loans. 3 Q. So a loan through Jeffrey? 4 A. I don't recall the exact 5 transaction. 6 Q. Did he purchase for you a 7 helicopter during the time you were working 8 for him? 9 A. It was his helicopter. 10 Q. When did you obtain your pilot 11 license? 12 A. I believe it was '98 or '99. 13 Q. Was that for both airplanes and 14 helicopters or just helicopters? 15 A. Just helicopters. 16 Q. Have you ever flown President 17 Clinton on your helicopter? 18 A. That is another one of Virginia's 19 lies. 20 Q. The question is have you ever done 21 that? 22 A. I have never flown President 23 Clinton at any time ever, in any helicopter, 24 in any place, any time, in any state, in any 25 country, at any time anywhere. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 105 of 465 Page 105 1 G Maxwell - Confidential 2 Q. Have you ever had dinner with 3 President Clinton at Jeffrey's home, at any 4 of Jeffrey's homes? 5 A. No, I don't believe so. 6 Q. Have you traveled on Jeffrey's 7 planes with President Clinton? 8 A. Yes, I have. 9 Q. Would that have been in 2002? 10 A. It's very hard for me to recollect 11 exact dates but that sounds about right. 12 Q. Was that during the time that 13 Virginia was working for Jeffrey? 14 A. I don't know that Virginia ever did 15 work for Jeffrey. I don't exactly know if 16 she testified to her so-called duties, we 17 know she is a serial liar so I can't testify 18 to what she did or didn't do. So I object to 19 that characterization of her. So repeat the 20 question, please. 21 Q. Can you read the question back? 22 (Record read.) 23 Q. You can answer the question. 24 A. What was the question again? 25 Q. When you were traveling on the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 106 of 465 Page 106 1 G Maxwell - Confidential 2 plane with President Clinton, was that during 3 the time, it was 2002, that you were on a 4 flight with Clinton, was that during the time 5 Virginia was working for Jeffrey? 6 MR. PAGLIUCA: Object to the form. 7 Misstates the witness' answer and if you 8 can answer the question, you can answer 9 it. 10 A. Well, like I said, I don't recall 11 exactly when I flew with him. I don't recall 12 when Virginia, we know what Virginia claims 13 when she left, so I can't answer the 14 question. I have no idea. 15 Q. Do you know Prince Andrew? 16 A. I do. 17 Q. How long have you known him? 18 A. A very long time. 19 Q. Since you were a child? 20 A. I really -- it's so long, it's 21 really a long time ago. I just don't recall. 22 Q. Do you remember how you first met 23 him? 24 A. No, I do not. 25 Q. Did you introduce him to Jeffrey? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 107 of 465 Page 107 1 G Maxwell - Confidential 2 A. That would be another of Virginia's 3 lies and the lies you perpetrate. I never 4 introduced Prince Andrew to Jeffrey Epstein 5 at any time ever, so just add that the to 6 long list of lies. 7 Q. Did Jeffrey know Prince Andrew? 8 A. Clearly he knew him. I think we 9 have that answer but how -- yeah. 10 Q. Do you know how Jeffery met Prince 11 Andrew? 12 A. I do not know Jeffrey met Prince 13 Andrew. What I do know is that I did not 14 introduce them. That is one of the many 15 lies. Are we tallying all the lies? 16 Q. Do you know when Jeffrey met Prince 17 Andrew? 18 A. I do not know when Jeffrey met 19 Prince Andrew. 20 Q. Did you ever introduce Prince 21 Andrew to any girls under the age of 18 who 22 were not friends of yours children? 23 A. I have not introduced Prince Andrew 24 to anyone that I am aware of other than 25 friends of mine who have kids under that age Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 108 of 465 Page 108 1 G Maxwell - Confidential 2 that he may have met socially through me. 3 Q. Did you ever introduce Prince 4 Andrew to Virginia in London? 5 A. I understand her story about London 6 but again, her tissue of lies is extremely 7 hard to pick apart what is true and what 8 isn't. Actually I wouldn't recollect her at 9 all but for her tissue stories about this 10 situation. 11 Q. So did you ever introduce Prince 12 Andrew to Virginia in London? 13 A. I have no recollection. 14 Q. Did Virginia ever stay at your home 15 in London, your town home? 16 A. I know she claims she did but if 17 you are asking me here today to remember 18 specifically, I cannot. 19 Q. Do you remember taking a trip with 20 Virginia to travel over to Europe, including 21 London? 22 A. So I have seen her reports and I 23 have seen the plane reports. I see she says 24 she was on that but again, I really have no 25 recollection of her. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 109 of 465 Page 109 1 G Maxwell - Confidential 2 Q. Did you know that she was 17 at the 3 time of that trip? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I have -- 7 Q. Did you know she was 17 at the time 8 of that trip? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I didn't even know she was on the 12 trip. 13 Q. Did you hold her passport for her 14 when she was traveling? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I have no recollection whatsoever 18 of her even being on the trip nor holding her 19 passport. 20 (Maxwell Exhibit 4, picture, marked 21 for identification.) 22 Q. I'm showing you what we marked as 23 Maxwell Exhibit 4. 24 Can you take a look at that picture 25 for me? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 110 of 465 Page 110 1 G Maxwell - Confidential 2 A. I've looked at it. 3 Q. Are you in that picture? 4 A. I am. 5 Q. Is that Prince Andrew in the 6 picture as well? 7 A. It is. 8 MR. PAGLIUCA: I don't believe this 9 has been produced to us in discovery by 10 you. 11 MS. McCAWLEY: The picture? 12 MR. PAGLIUCA: Yes. 13 MS. McCAWLEY: It has. 14 MS. MENNINGER: Is it the same 15 exact photograph. 16 MS. McCAWLEY: I believe so. We 17 will find one. The picture has been 18 produced a number of times. 19 MR. PAGLIUCA: I've seen different 20 iterations of this, I don't believe I 21 have ever seen this. 22 MS. McCAWLEY: We had them blow it 23 up on a page so she could see it. We 24 could use an article. 25 While you are looking for that, I Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 111 of 465 Page 111 1 G Maxwell - Confidential 2 will skip ahead. Hold that until we can 3 find one that has the Bates range on it. 4 Q. Do you recall Virginia being at 5 your London town home? 6 A. I do not. 7 Q. Do you recall going to dinner with 8 Prince Andrew, Jeffrey Epstein and Virginia 9 Roberts in London, at any time? 10 A. I do not. 11 Q. Do you recall going to a place 12 called Club Tramp with Prince Andrew, Jeffrey 13 Epstein and yourself and Virginia Roberts? 14 A. I would just like to state for the 15 record that Prince Andrew is a very famous 16 person, I know you are aware because you like 17 to use him so often in your press stories -- 18 please let me finish. Were he at Tramp, at 19 any time, that would be reported by the 20 press. I do not have any recollection of it 21 and I doubt it actually happened. 22 Q. You don't recall that. 23 Do you recall taking Virginia 24 shopping when you were in London to buy an 25 outfit to meet Prince Andrew? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 112 of 465 Page 112 1 G Maxwell - Confidential 2 A. No, I don't. 3 Q. Where in your town home -- we will 4 come back to that. 5 Do you have guest bedrooms in your 6 town home in London? 7 A. I do. 8 Q. How many? 9 A. Two. 10 Q. Did Prince Andrew ever visit 11 Jeffrey and you in New York? 12 A. Yes. 13 Q. Do you remember him visiting you 14 and Jeffrey in New York in the spring of 15 2001? 16 A. Again, I can't testify to any 17 specific dates. 18 Q. So you don't have a recollection of 19 that? 20 A. I have a recollection -- you've 21 asked me if I have a recollection of being in 22 New York but if you are asking for a date, I 23 cannot confirm that date. 24 Q. Do you remember Prince Andrew being 25 present in New York for a party where Johanna Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 113 of 465 Page 113 1 G Maxwell - Confidential 2 Sjoberg was also present? 3 A. I don't recollect. 4 Q. Do you recall ever giving Prince 5 Andrew a gift of a puppet that was in the 6 same -- that looked like him? 7 A. I never gave him a gift of a 8 puppet. 9 Q. Did Jeffrey ever give him a gift of 10 a puppet? 11 A. No, not that I am aware of. 12 Q. Have you ever given him any gifts? 13 MR. PAGLIUCA: Objection, 14 foundation. 15 A. I know Andrew -- 16 Q. Have you ever given him any gifts 17 that you remember when he came to Jeffrey's 18 home in New York? 19 A. I don't recall giving him any gifts 20 in New York. 21 (Maxwell Exhibit 5, picture, marked 22 for identification.) 23 Q. I think I directed you to page 24 0034. 25 Is that a picture that was taken at Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 114 of 465 Page 114 1 G Maxwell - Confidential 2 your London town home? 3 A. I have no idea what this picture 4 was taken. I know what she purports it to be 5 but I'm not going to say that I do. 6 Q. Do the surroundings look like your 7 London town home? 8 A. They are familiar. 9 Q. Do you know who took this picture? 10 A. I do not. 11 Q. Did Jeffrey Epstein take the 12 picture? 13 A. I just testified I don't know who 14 took the picture. 15 Q. So you don't know if Jeffery 16 Epstein took the picture? 17 A. When I tell you I don't know who 18 took the picture, it doesn't mean him -- I 19 don't know who took the picture. You can 20 come up with 50 names, I still do not know 21 who took the picture. 22 Q. Did you observe Prince Andrew go 23 into a room with Virginia alone in your town 24 home? 25 A. I cannot recall. As I have said, Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 115 of 465 Page 115 1 G Maxwell - Confidential 2 no. 3 Q. Did Prince Andrew ever tell you 4 that he had sex with Virginia Roberts? 5 A. He did not. 6 Q. Did Jeffrey Epstein ever tell you 7 that Prince Andrew had sex with Virginia 8 Roberts? 9 A. He did not. 10 Q. Did Prince Andrew ever visit -- let 11 me back up for a moment. We talked about 12 Jeffrey's homes, did Jeffrey have a home in 13 the U.S. Virgin islands called Little St. 14 James? 15 A. Yes. 16 Q. Did Prince Andrew ever visit that 17 island -- are you aware of Prince Andrew ever 18 visiting Jeffrey's island? 19 A. I am aware of that, yes. 20 Q. Do you know how many times he 21 visited? 22 A. I do not. 23 Q. Do you know if he visited when 24 Virginia was on the island? 25 A. I do not. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 116 of 465 Page 116 1 G Maxwell - Confidential 2 Q. Were you present on the island when 3 Prince Andrew visited? 4 A. Yes. 5 Q. How many times? 6 A. I can only remember once. 7 Q. Were there any girls under the age 8 of 18 on the island during that one visit 9 that you remember that were not family or 10 friends of or daughters of your friends? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. There were no girls on the island 14 at all. No girls, no women, other than the 15 staff who work at the house. Girls meaning, 16 I assume you are asking underage, but there 17 was nobody female outside of the cooks and 18 the cleaners. 19 Q. Did you, as part of your duties in 20 working for Jeffrey, ever arrange for 21 Virginia to have sex with John Luc Brunel? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Just for the record, I have never 25 at any time, at anyplace, in any moment ever Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 117 of 465 Page 117 1 G Maxwell - Confidential 2 asked Virginia Roberts or whatever she is 3 called now to have sex with anybody. 4 Q. Did you ever provide Virginia 5 Roberts with an outfit, an outfit of a sexual 6 nature to wear for Les Wexner? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I think we addressed the outfit 10 issue. 11 Q. I am asking you if you ever 12 provided her with an outfit of a sexual 13 nature to wear for Les Wexner? 14 A. Categorically no. You did get 15 that, I said categorically no 16 Q. Don't worry I'm paying attention. 17 A. You seemed very distracted in that 18 moment. 19 (Maxwell Exhibit 6, flight logs, 20 marked for identification.) 21 A. Do you mind if I take a break for 22 the bathroom. 23 Q. It's 11:08 and we are going to go 24 off the record now. 25 THE VIDEOGRAPHER: It's now 11:09. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 118 of 465 Page 118 1 G Maxwell - Confidential 2 We are off the record. 3 (Recess.) 4 THE VIDEOGRAPHER: It's now 11:26, 5 we are back on the record and starting 6 disk No. 3. 7 Q. Ms. Maxwell, I think I handed you 8 right before the break, did I hand you the 9 flight logs, they look like this. Did I mark 10 those yet, I thought I did. 11 A. I don't believe I have it. 12 Q. These admittedly are a little 13 difficult to read so what I'm going to 14 provide you with to assist is I have a chart 15 that has the airport codes, because it will 16 have, for example, just for the record 17 reflects that the first page of document 18 it will have a code in the from line 19 that says PBI, for example, to TEB so I a 20 chart that matches up, just in case you don't 21 understand what those letters mean, PBI 22 meaning Palm Beach, TEB meaning Teterboro, 23 which is New Jersey, but others are more 24 difficult but just for you to be able to 25 understand the logs, I will provide you with Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 119 of 465 Page 119 1 G Maxwell - Confidential 2 that. 3 MR. PAGLIUCA: So we are clear, if 4 the witness has personal knowledge of 5 what these are that's fine but I don't 6 know what these are and I don't expect 7 the witness to accept the representation 8 that they are what they are. 9 MS. McCAWLEY: If she can testify 10 to what city it is, she can state that 11 on the record. 12 MR. PAGLIUCA: If she knows what it 13 is, she knows what it is, we are not 14 putting any affirmatively on the record 15 until you ask your questions. 16 Q. So I'm going to ask you and I think 17 we flagged a few of the pages which may 18 direct us a little bit easier but I will do 19 it by Bates number which is at the bottom of 20 the document kind of at the side. 21 The first I will direct your 22 attention to is 23 A. Does it have a tab? 24 Q. It should. Let me make sure. 25 A. Yes it does. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 120 of 465 Page 120 1 G Maxwell - Confidential 2 Q. So I'm directing your attention to 3 the bottom, two lines up from the bottom, 4 there is a flight -- 5 MR. PAGLIUCA: Are you on 6 MS. McCAWLEY: 7 Q. So this flight is from, the one I'm 8 looking at, I think it's highlighted on your 9 copy. On the far corner on the date, it says 10 at the top and this would be the 11 and then the are the two I'm going to 12 direct your attention to. 13 Q. On that first one on the you 14 will see the column reading PBI in the from 15 column to TEB in the to column and you will 16 see some initials, you will see JE for 17 Jeffrey Epstein, GM for Ghislaine Maxwell, ET 18 for Emmy Taylor and then Virginia? 19 A. I have to object. 20 MR. PAGLIUCA: You don't get to 21 object. 22 Q. She is turning into a lawyer 23 already? 24 A. I would like to. 25 Q. Let me ask the question and if you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 121 of 465 Page 121 1 G Maxwell - Confidential 2 have an issue -- so with respect to this 3 flight, do you recall being on a flight in 4 the -- going from Palm Beach to 5 Teterboro? 6 A. No, I don't recall any specific 7 flight. 8 Q. Do you recall flying with Virginia 9 on a flight with Emmy Taylor and Jeffrey 10 Epstein at any time? 11 A. I don't. 12 Q. How often did you fly on a plane 13 with a 17 year old? 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. I have no idea what you are talking 17 about, other than friends of mine that had 18 kids. 19 Q. Did you regularly fly on Jeffrey's 20 plane with individuals who were under the age 21 of 18? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Can you repeat the question? 25 Q. Did you regularly fly on Jeffrey Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 122 of 465 Page 122 1 G Maxwell - Confidential 2 Epstein's planes with individuals who were 3 under the age of 18? 4 A. I regularly flew on Jeffrey 5 Epstein's airplane but I cannot testify as to 6 flying with people under the age. I don't 7 believe that I did. 8 Q. Why wouldn't you remember flying 9 with a 17 year old? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. How would I know, one, that she is 13 17, how would you know that, how do you know 14 I'm on the plane. 15 Q. Are you saying you are not on this 16 flight, so this is a Palm Beach to Teterboro. 17 This says the JE, GM ET and Virginia. The GM 18 you are saying is not you? 19 MR. PAGLIUCA: I object to the 20 form. You can answer the question if 21 you know. 22 A. How do you know the GM is me. 23 Q. Is it your testimony that on the 24 flight logs when it represents GM that it is 25 not you flying on the plane? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 123 of 465 Page 123 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. GM can stand for any level, it 5 could be Georgina, George. 6 Q. Are there any people that flew with 7 Jeffrey Epstein that had the initials GM? 8 A. I don't know. 9 Q. Do you recall flying with Jeffrey 10 Epstein on his plane over 300 times during 11 the period of 1999 to 2005? 12 A. I cannot testify to how many times 13 I was on his plane because that would just be 14 impossible. 15 Q. You were on his plane regularly, 16 would you say? 17 A. I already testified I was on his 18 plane regularly. 19 Q. Is it your testimony and I'm 20 referring now to the line that we were just 21 talking about that you were not on the flight 22 from Palm Beach to Teterboro that lists JE, 23 GM, ET and Virginia? 24 A. I am not testifying to that. I am 25 just saying that you cannot be sure that is Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 124 of 465 Page 124 1 G Maxwell - Confidential 2 me. 3 Q. So as you sit here today, you don't 4 believe you flew on that plane? 5 A. I'm not saying that. I'm just 6 saying you cannot be sure that's me. 7 Q. Do you have reason to doubt that 8 when it says GM on these flight logs that 9 that represents you? 10 A. I cannot testify to that. I'm just 11 saying it may not be me. 12 Q. In looking at the flight logs and 13 look up, let's move up a couple of lines. If 14 you start at the top, you are going to see 15 JE, , then JE, AP, , 16 JE, AP , JE, GM, JE, GM, JE, GM, 17 Ricardo Loretta, reposition, JE, GM, JE, GM 18 ET Kelly Spamm, JE, GM, Kelly Spamm, Tom 19 Pritzer, female, Marham Air Force 20 repositioning. JE, GM, ET, Kelly Spamm, JE, 21 GM, ET, Kelly Spamm, JE, GM, ET, Virginia, 22 JE, GM, AP, Virginia, repositioning and then 23 a certification. 24 So is it your testimony in looking 25 at that that you do not believe that the GM Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 125 of 465 Page 125 1 G Maxwell - Confidential 2 represents you? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I'm not saying that. I'm just 6 saying that you cannot -- I can't sit here 7 and tell you for sure GM is me and I cannot 8 testify remembering being on a flight at that 9 time. 10 Q. You don't remember being on any of 11 these flights with the initial GM? 12 A. I remember being on many flights. 13 I cannot testify that is a flight I am on. 14 Q. Let's go to the next page which is 15 going to be I want you to look at 16 line -- so the date is at the top, so it's 17 and if you go down, you will see 18 a line that says the and if you scroll 19 over you will see PBI to TIST, if you look at 20 the airport codes, TIST is going to be 21 representative for the U.S. Virgin Islands 22 and then you will see the list on the plane 23 JE, GM, ET and Virginia Roberts. 24 Do you recall flying from Palm 25 Beach to the U.S. Virgin Islands with Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 126 of 465 Page 126 1 G Maxwell - Confidential 2 Jeffrey, yourself, Emmy Taylor and Virginia 3 Roberts? 4 MR. PAGLIUCA: I object to the form 5 and just so the record is clear, we 6 don't agree with whatever your 7 characterizations are. The document 8 speaks for itself and she can answer 9 based on whatever her personal knowledge 10 is. 11 MS. McCAWLEY: I understand. 12 Q. Do you recall flying with those 13 individuals from Palm Beach to the U.S. 14 Virgin Islands? 15 A. I have no recollection of any 16 individual flight you are pointing out here. 17 You are talking about 2001, how many years 18 ago is that? 19 Q. I'm asking the questions. 20 A. I'm not being difficult. I'm just 21 asking, it's like 14, 15 years ago, it's 22 impossible, I'm sorry. 23 Q. So your testimony is you don't 24 recall flying on that flight with Virginia 25 Roberts? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 127 of 465 Page 127 1 G Maxwell - Confidential 2 A. I cannot testify to that flight. 3 Q. Let's look at the next flight which 4 is on the from the Virgin Islands back 5 to Palm Beach, JE, Jeffrey Epstein, Ghislaine 6 Maxwell, Emmy Taylor, Virginia Roberts, the 7 same individuals on the above flight. 8 A. It doesn't say my name, it has some 9 initials. 10 Q. I understand, the initials GM. 11 Do you recall flying on a plane, on 12 one of Jeffrey's planes from the Virgin 13 Islands to Palm Beach with Virginia Roberts? 14 A. I do not. 15 Q. Was there any other person that 16 flew with Jeffrey Epstein with frequency 17 during that time period in these logs that 18 have the initials GM? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I would have to look at all the 22 flight logs, I have no idea, I flew 23 frequently. 24 Q. Why don't you take a look at the 25 next three pages and see if that refreshes Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 128 of 465 Page 128 1 G Maxwell - Confidential 2 your recollection. 3 MR. PAGLIUCA: You are talking 4 about 5 MS. McCAWLEY: She can pick any 6 couple of pages, those have a lot of the 7 individuals on them so that is a good 8 sampling. 9 MR. PAGLIUCA: So pick any pages 10 you want. 11 Q. Does that refresh your recollection 12 at all as to whether GM represents you or 13 some other individual? 14 A. Again, I can't testify whether that 15 represents me or not, I don't see any other 16 GMs but you have to understand that even if 17 my name is on that record doesn't mean I was 18 on the flight. 19 Q. So are you contesting the accuracy 20 of the flight logs? In other words, you said 21 it doesn't represent you are on the flight so 22 is it your testimony just because a name is 23 listed doesn't mean they were actually on the 24 flight? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 129 of 465 Page 129 1 G Maxwell - Confidential 2 form and foundation. 3 A. I can't testify to what -- these 4 are records that were produced by Dave Rogers 5 is on here, so these aren't federally 6 mandated records, so I can't testify to what 7 he produced. 8 Q. I would like you to turn to page, 9 at the bottom, the Bates number is 10 And the month is . 11 A. Okay. 12 Q. If you go down to the number that 13 is that would be you're 14 going to see on that line an which is a 15 and then you 16 will see which is going to be, I'm going 17 to pronounce it incorrectly, 18 I'm sure I'm not pronouncing that 19 correctly. Then you will see in the list, 20 you will see JE, GM, SK, President Clinton, 21 Doug Band, it looks like -- 22 A. I believe it says male. 23 Q. Yes. Then I 24 believe. Is that GM on this page 25 representative of you? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 130 of 465 Page 130 1 G Maxwell - Confidential 2 A. Well, this would be a flight that I 3 would potentially remember with Bill Clinton 4 on it but I don't actually recall going to 5 Russia. 6 Q. Are those your initials, do you 7 recall being on the flight? 8 A. Those are my initials with 9 President Clinton, I don't recall this flight 10 either, but I would be more likely to if I 11 had a bit more time to study the timing of 12 this. 13 Q. Your testimony is you don't recall 14 flying with President Clinton from to 15 16 A. I don't recall the to 17 flight. I have definitely flown with 18 President Clinton. 19 Q. On that same page you will see 20 beneath there, beneath 22 you will see the 21 indication, same as above, same as above, 22 same as above in the column that originally 23 had the initials. 24 A. Uh-huh. 25 Q. And the names. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 131 of 465 Page 131 1 G Maxwell - Confidential 2 A. Uh-huh. 3 Q. Do you recall flying with President 4 Clinton from to 5 6 A. I do. 7 Q. So the GM that would be represented 8 in that column would be you? 9 A. I recall going to with the 10 president so that is likely to be me. 11 Q. You were on Jeffrey's plane for 12 that trip? 13 A. I believe I was. 14 Q. Do you know who 15 is? 16 A. I do not. 17 Q. I'm going back towards the front 18 which is going to be please. And 19 you're going to see -- 20 A. Hang on I'm not -- 21 Q. Take your time. 22 A. Okay. 23 Q. You are going to see in the date 24 column, you will see and then about 25 halfway down you will see and Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 132 of 465 Page 132 1 G Maxwell - Confidential 2 then you will see the which 3 is the column which is where I want you to 4 start looking at the log and there you're 5 going to see 11 A. Okay. 12 Q. If you look at the column, if you 13 go back up to the top on the if you look 14 at the column you will see JE, GM, ET, 15 Virginia Roberts and I believe it says 16 sorry I'm not reading that very 17 well. 18 Do you recall flying from, if you 19 see the dates, the 20 Do you recall a trip that went from 21 the United States to and to the places 22 I just mentioned where Virginia Roberts was 23 on the plane with you? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 133 of 465 Page 133 1 G Maxwell - Confidential 2 A. I already testified that I don't 3 recall Virginia on any of these flights. 4 Q. I would like to mark, as Maxwell 7, 5 I will put it at the top? 6 (Maxwell Exhibit 7, photo, marked 7 for identification.) 8 MR. PAGLIUCA: Has this document 9 been produced in discovery? 10 MS. McCAWLEY: Yes. 11 MR. PAGLIUCA: Do you have a Bates 12 number? 13 MS. McCAWLEY: This one doesn't. 14 Q. I'm going to ask you -- 15 MR. PAGLIUCA: I don't recall 16 seeing this document so I would like to 17 see a Bates number document before we 18 ask questions about it. 19 MS. McCAWLEY: Can you go look for 20 it and I will continue. We will set 21 that aside until we get a Bates number. 22 You may want to leave that log up and 23 set it to the side and we will bounce 24 back to that. 25 Q. Do you recall -- I think earlier Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 134 of 465 Page 134 1 G Maxwell - Confidential 2 you said you visited Jeffrey's island, I 3 think they called it St. Jeffrey or St. 4 James, the U.S. Virgin Island home. 5 A. St. James. 6 Q. Do you recall whether President 7 Clinton was ever on that island? 8 A. Categorically, definitively, 9 absolutely, without a shadow of a doubt, when 10 I was present or any other time that I am 11 aware of, was President Clinton ever on that 12 island, I do not believe he went to that 13 island ever ever, that is an absolute 14 fabrication and an absolute flat out lie. 15 Q. Was President Clinton or former 16 President Clinton ever at any of Jeffrey 17 Epstein's homes when you present, other than 18 the island I know you said that did not 19 happen, the home in either New York or Palm 20 Beach or New Mexico? 21 A. I do not believe at any time 22 President Clinton was at any of Jeffrey's 23 homes, I have absolutely no knowledge or 24 otherwise that he was ever there. 25 Q. You don't recall having dinner with Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 135 of 465 Page 135 1 G Maxwell - Confidential 2 him at any of those homes? 3 A. Again, Virginia is absolutely 4 totally lying. This is a subject of 5 defamation about Virginia and the lies she 6 has told and one of lies she told was that 7 President Clinton was on the island where I 8 was present. Absolutely 1000 percent that is 9 a flat out total fabrication and lie. 10 Q. You did fly on planes, Jeffrey 11 Epstein's planes with President Clinton, is 12 that correct? 13 A. I have flown, yes. 14 Q. Would it be fair to say that 15 President Clinton and Jeffrey are friends? 16 A. I wouldn't be able to characterize 17 it like that, no. 18 Q. Are they acquaintances? 19 A. I wouldn't categorize it. 20 Q. He just allowed him to use his 21 plane? 22 A. I couldn't categorize Jeffrey's 23 relationship. 24 Q. When you were on the plane with 25 Jeffrey and President Clinton, did you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 136 of 465 Page 136 1 G Maxwell - Confidential 2 observe Jeffrey and President Clinton 3 talking? 4 A. I'm sure they did. 5 Q. Did they seem friendly? 6 A. I don't recollect. 7 Q. Was Epstein one of the original 8 people that conceived the Clinton global 9 initiative? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 Q. Do you know? 13 A. I don't have -- I don't know what 14 you are talking about. 15 Q. You don't know what I'm talking 16 about. 17 Did you ever, not at one of houses, 18 but did you ever eat dinner with President 19 Clinton and Jeffrey Epstein? 20 A. Are you just talking in general 21 anywhere. 22 Q. In general? 23 A. I believe on a plane of this nature 24 we would have had a meal. 25 Q. But not outside of the travel on Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 137 of 465 Page 137 1 G Maxwell - Confidential 2 the flights? 3 A. I can't recollect having a meal 4 with them, but just so we are clear, the 5 allegations that Clinton had a meal on 6 Jeffrey's island is 100 percent false. 7 Q. But he may have had a meal on 8 Jeffrey's plane? 9 A. I'm sure he had a meal on Jeffrey's 10 plane. 11 Q. You do know how many times he flew 12 on Jeffrey's plane? 13 A. I don't. 14 Q. Do you know who Doug Band is? 15 A. I do. 16 Q. How do you know him? 17 A. He used to work or still works for 18 Bill Clinton. 19 Q. Did you ever have a relationship 20 with him? 21 A. We are talking about adult 22 consensual relationships, it's off the 23 record. 24 Q. I'm not asking what you did with 25 him, I'm asking if you ever had a Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 138 of 465 Page 138 1 G Maxwell - Confidential 2 relationship with him? 3 MR. PAGLIUCA: If you understand 4 the term relationship, certainly you can 5 answer that. 6 A. Define relationship. 7 Q. Somebody that you would have spent 8 time together, either seeing them in a 9 romantic relationship or -- 10 A. You need to be, what do you mean by 11 romantic. I was friends with Doug but you 12 are suggesting something more so I want to be 13 clear what you are actually asking me. 14 Q. You defined it. You said you were 15 friends with him. If that's what you were 16 that's all I need to know. 17 While you were on the trip with 18 President Clinton, do you recall where you 19 stayed at these locations, in other words, 20 would you leave the jet and stay overnight at 21 a hotel, do you have a recollection of this 22 trip? 23 A. I recollect the trip but if you're 24 asking me where we stayed, you can see it's a 25 very fast paced trip. It was very tiring and Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 139 of 465 Page 139 1 G Maxwell - Confidential 2 I don't recollect where we stayed. 3 Q. Do you recollect if you stayed at 4 the same place President Clinton stayed? In 5 other words, if you left the plane to go a 6 hotel did you all go together is your 7 recollection? 8 A. I honestly don't recollect, no. 9 Q. Part of this trip we were just 10 talking about, there is a flight that goes to 11 Thailand, do you remember being in Thailand? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. Are you asking me -- 15 Q. On the President Clinton trip. 16 A. Are you referencing something? 17 Q. The part that, let me make sure 18 I've got it here. The entry that would be 19 the Thailand, would be the one -- let me make 20 sure I'm correct. I have you on the wrong 21 page, it's actually the page before. It's 22 going to be And it's going to be the 23 entry on starting on and then 24 it goes down to where it has the same as 25 above, to -- I'm saying Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 140 of 465 Page 140 1 G Maxwell - Confidential 2 3 MR. PAGLIUCA: That's what the 4 document says. 5 Q. I'm not representing the date but 6 there it is. So the last leg of that where 7 it says same as above has, the second to 8 last, I'm sorry on the 10 Do you remember being in Thailand 11 with President Clinton? 12 A. I do. 13 Q. Do you remember what the purpose of 14 that trip was? 15 A. I don't. 16 Q. Do you know whether -- do you 17 recall, did you stay the night in Thailand? 18 A. I don't recall. 19 Q. Do you recall why you went to 20 Thailand? 21 A. I don't recall. 22 Q. Who is Andrea Mitrovich? 23 A. She I believe was a stewardess on 24 this flight. 25 Q. Did she perform any massages on the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 141 of 465 Page 141 1 G Maxwell - Confidential 2 flight? 3 A. I don't recollect any massages on 4 the flight. 5 Q. Do you know who is? 6 A. It doesn't -- no I don't know who 7 that is, I can't recall. 8 Q. This is not in color, it's a black 9 and white but it has the Bates label on it. 10 Should I take the sticker off the one that 11 has -- I don't know if you want to swap it. 12 MR. PAGLIUCA: Let the record 13 reflect I am replacing this on the black 14 and white copy of this exhibit with 15 16 Q. So, we were talking earlier, we 17 were looking at the flight logs and we were 18 talking about a trip and let me just get you 19 back to the page. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 142 of 465 Page 142 1 G Maxwell - Confidential 2 Q. Can I direct your attention to the 3 picture, please. 4 A. Of course. 5 Q. Can you tell me who is in this 6 picture, who is pictured here, and for the 7 court reporter's benefit, can you go from the 8 left of the picture to the right of the 9 picture, to the extent you can identify the 10 individuals? 11 A. Sure. I cannot identify the person 12 on the left, I cannot identify the person 13 next left. I can identify Jeffrey Epstein. 14 I cannot identify the next person to his 15 right and the next person in the picture is 16 myself. 17 Q. Is the individual all the way to 18 the left at the beginning of the picture, 19 does that resemble Emmy Taylor. You might 20 want to look at the color version if that 21 helps you at all, I know it's not the marked 22 one. I don't if that's easier to see, they 23 are both dark. 24 A. That does not look like Emmy Taylor 25 at all. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 143 of 465 Page 143 1 G Maxwell - Confidential 2 Q. Do you recall -- 3 MR. PAGLIUCA: Let's mark this then 4 as deposition Exhibit 8 since we are 5 referring to it and then you can give us 6 copies as well. 7 MS. MENNINGER: It's different 8 because it has other people in this 9 color photo. 10 (Maxwell Exhibit 8, photo, marked 11 for identification.) 12 Q. Do you recall who took this 13 photograph? 14 A. I do not. 15 Q. Do you recall this photograph being 16 taken by Virginia? 17 A. First of all, I don't know where we 18 are. 19 Q. So you don't recognize the 20 building? 21 A. I don't recognize the building and 22 I don't recognize -- the only two people I 23 recognize in the picture are Jeffrey and 24 myself. 25 Q. Does this like look a picture of a Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 144 of 465 Page 144 1 G Maxwell - Confidential 2 building that you would have seen when you 3 were on the trip in Europe? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't possibly answer that. 7 Q. Do you recall Virginia ever taking 8 pictures? 9 A. I barely recall Virginia, period. 10 Q. Do you recall her ever taking 11 pictures? 12 A. No, I don't. 13 Q. I'm going to direct your attention, 14 still within the flight logs to -- starting 15 on the next page from where you just were 16 which is going to be And the date at 17 the top says you will see and I'm 18 directing your attention down towards the 19 middle to the bottom where you will see the 20 numbers 21 A. Uh-huh. 22 Q. And we've got actually I'm going to 23 direct your attention to the one that starts 24 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 145 of 465 Page 145 1 G Maxwell - Confidential 2 and in the line, the remarks line you will 3 see JE, GM, AP, VR, BK, Marvin Minski and 4 5 MR. PAGLIUCA: Are you reading the 6 29th, is that what you're reading? 7 MS. McCAWLEY: I'm reading the 8 29th, yes. 9 Q. Below that you will see JE, GM, AP, 10 VR, and Marvin 11 Minski. 12 Do you see that? 13 A. I do. 14 Q. Do you recall a trip from Teterboro 15 to Santa Fe and Santa Fe back to Palm Beach 16 with these individuals? 17 A. I don't. 18 Q. Do you recall being on a plane with 19 and Virginia Roberts? 20 A. I don't. 21 Q. Do you recall ever witnessing any 22 sexual interaction on one of Jeffrey's planes 23 with any of these individuals? 24 A. I do not, absolutely not. 25 Q. Did Jeffrey have a fold out bed on Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 146 of 465 Page 146 1 G Maxwell - Confidential 2 one of his planes? 3 A. There was a bed on one of his 4 planes that folded out, yes. 5 Q. Do you recall whether with respect 6 to this being in Santa Fe, do you recall 7 whether you were there for some form of a 8 party? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I don't recall the trip at all and 12 this looks like a total work trip, not a 13 party trip. 14 Q. What would be the difference 15 between a work trip and a party trip? 16 A. Just that I would be on trips for 17 work and I believe that this looks like, AP 18 looks like it's one of the -- probably one of 19 the designers and the time would meet with a 20 trip to decorate the house, just the timing 21 of it. 22 Q. So would Virginia be brought on 23 trips that were for the purpose of work and 24 decorating the house? 25 A. Like I said, I never worked with Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 147 of 465 Page 147 1 G Maxwell - Confidential 2 her but you would have to ask Jeffrey what he 3 brought her on the trip for. 4 Q. But she would travel with him when 5 there was a work trip like this? 6 A. I can't -- I'm seeing that she is 7 on this flight but I have no idea what she is 8 doing, he invited her, it would not be my 9 job. 10 Q. What about , would she 11 regularly travel with Jeffrey on flights? 12 A. I have no idea, you would have to 13 look through the flight logs. I have no 14 idea. 15 Q. Your recollection is -- what is 16 your recollection, do you recollect 17 traveling often on flights with Jeffrey? 18 A. Absolutely not. No, not at all. I 19 don't recollect her actually on the flight at 20 all. 21 Q. I think you can set that aside for 22 the moment. 23 (Maxwell Exhibit 9, message pad 24 pages, marked for identification.) 25 Q. We will mark as Exhibit 9 these Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 148 of 465 Page 148 1 G Maxwell - Confidential 2 excerpts from -- we will identify what they 3 are but from the message pads. 4 Did you want to correct anything? 5 A. I want to make an addendum. 6 Would you mind rereading the last 7 question back to me? 8 (Record read.) 9 A. I also just want to say that at 10 this point I cannot recollect flying to 11 parties. Jeffrey went for work so -- was 12 this in Santa Fe, this flight as well. 13 Q. The flight we were looking at, yes 14 but it was to Santa Fe -- 15 A. I don't recall going to any parties 16 in Santa Fe at any time but certainly flying 17 to Santa Fe for a party seems highly 18 improbable. 19 Q. So I'm going to direct your 20 attention to the document that I set before 21 you which is Bates number and it 22 has different Bates numbers because it's a 23 smaller version of the larger production. 24 These are the pages I will be asking about. 25 In the time that you were working Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 149 of 465 Page 149 1 G Maxwell - Confidential 2 with Jeffrey in Palm Beach, do you recall a 3 process for taking, anybody at the house 4 taking messages when incoming phone calls 5 came in? 6 A. You are supposed to take a message 7 and receive the message and write the message 8 down. Who was the message was for, what time 9 it was taken and who took it and what the 10 message was, obviously. 11 Q. Does what's in front of you look 12 familiar with respect to the message pads 13 that you would have used at the house? 14 A. It is familiar. 15 Q. I'm going to direct your attention 16 to the second page of it? 17 MR. PAGLIUCA: These all have SAO 18 numbers on them or Bates ranges and I 19 don't see any of your Bates ranges on 20 these. I know you have produced message 21 pads but those have your Bates range 22 numbers on them and I'm wondering if 23 these are different documents. 24 MS. McCAWLEY: It's the same, just 25 ours have the Bates underneath them. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 150 of 465 Page 150 1 G Maxwell - Confidential 2 These were produced as part of the rule 3 26 discovery. We can get the additional 4 Bates if you want. 5 Q. The one I'm asking about first is 6 the . You can look at that and then 7 I will identify the Bates number referenced 8 in this case. 9 I want to direct your attention to 10 the top right-hand corner just so I have an 11 understanding of how these messages were 12 taken. So I see that it says at the top it 13 says in the for line it says Ms. Maxwell and 14 the date of 4/25/04 and then I see under the 15 M line it looks like Necole Hesse or 16 something like that, a phone number and a 17 message saying returning your call and on the 18 bottom it looks like Rushi. 19 Explain to me, is this -- does this 20 represent taking down a message for you 21 from Ms. Hesse, is that how these work? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. Go ahead. 24 Q. My question is, I'm trying to 25 understand how the messages were taken. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 151 of 465 Page 151 1 G Maxwell - Confidential 2 Looking at this message pad, where it says 3 signed can you tell me who was? 4 A. I cannot. 5 Q. You do not know. 6 Typically when these messages were 7 taken in your practice when you were there, 8 would the individual who took the message 9 write their name on the message? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I don't recollect, you can ask who 13 wrote it so you can find out who it was. 14 Q. Do you know who Necole Hesse is? 15 A. I don't. 16 Q. I'm going to direct your 17 attention -- do we have a Bates number for 18 that? 19 MR. EDWARDS: 20 Q. Giuffre for that one. 21 I will direct your attention to the 22 first page which has the on it. 23 A. Okay. 24 Q. Now at the top of that document, on 25 the right-hand side, the message that reads Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 152 of 465 Page 152 1 G Maxwell - Confidential 2 for JE, date 1/02/03, message Caroline Casey 3 and then it's signed GM. 4 Is that your signature? 5 A. That's not my handwriting. 6 Q. Would other people take a message, 7 how did this process work, is there someone 8 else in the house with the initials GM? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I cannot answer that. It's not my 12 handwriting. 13 Q. I'm trying to understand how this 14 gets there. If you took a message and didn't 15 write it down, would someone else record that 16 message for you? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. All I can tell you, this is not my 20 handwriting so I cannot -- I have no idea 21 what that is. 22 Q. Was the practice that, what was the 23 practice when someone answered the phone with 24 these message pads, what were they supposed 25 to do? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 153 of 465 Page 153 1 G Maxwell - Confidential 2 A. They were supposed to take a 3 message and the time and date and give the 4 message. 5 Q. Were they supposed to indicate who 6 took the message? 7 A. They were but it wasn't -- I don't 8 really recall the actual process. I can see 9 from here it looks like you were supposed to 10 but that's not my handwriting so I can't say 11 what that was. 12 Q. Do you know who Caroline Casey is? 13 A. No, I don't. 14 Q. Do you know whether Caroline Casey 15 was under the age of 18? 16 A. I just testified I couldn't 17 remember who she was so it would be difficult 18 to know how old she was. 19 Q. Do you know if she was coming to 20 the house to provide massages? 21 A. I don't remember who she is at all, 22 so no. 23 Q. And then I would like to direct 24 your attention to the message right 25 underneath it. Which says JE, , Amanda Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 154 of 465 Page 154 1 G Maxwell - Confidential 2 and has a phone number and the message says, 3 wants to know if she should bring her friend 4 tonight. 5 What is that message referring to? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I can't possibly know. 9 Q. Did individuals at the house take 10 messages for underage girls to come over and 11 bring friends for the purpose of providing 12 massages? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. How would I possibly know what you 16 are talking about. 17 Q. Did you record messages at the 18 house? 19 A. It's not my job. 20 Q. You did from time to time record 21 messages? 22 A. Hardly ever. 23 Q. But you did from time to time do 24 it? 25 A. I'm just saying I hardly ever took Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 155 of 465 Page 155 1 G Maxwell - Confidential 2 messages, very, very, very, very 3 infrequently. 4 Q. Do you know if Amanda brought her 5 friend over on that night? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. One, I don't know what this message 9 is, I don't know if I was in Palm Beach, I 10 don't know who Amanda is, I don't know who 11 is and I don't know what this message 12 is referring to. 13 Q. So on January 2nd of 2003, were you 14 in Palm Beach? 15 A. I don't know. 16 Q. Where would you have been other 17 than Palm Beach at the time? 18 A. I could have been anywhere. 19 Q. Where did you typically live? 20 A. What are you asking me? 21 Q. So for example, in 2003, where was 22 your primary residence, was it wherever 23 Jeffrey was living and staying or was it 24 independent of that? 25 A. What was the date again. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 156 of 465 Page 156 1 G Maxwell - Confidential 2 Q. In 2003? 3 A. The end of 2003? 4 Q. January, the beginning. 5 A. I don't know, I could have been 6 anywhere, Jeffrey and I were leading almost 7 separate lives by then. 8 Q. If you were at the house that day, 9 did you recall seeing anybody by the name of 10 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I don't know if I was at the house, 14 so I can't testify to that. 15 Q. Let's flip back to the next page, 16 the one we were on before the , the 17 message towards the bottom that says, for 18 Jeffrey, message of Ghislaine. And it says, 19 Would it be helpful to have and then redacted 20 come to Palm Beach today to stay here and 21 help train new staff with Ghislaine. Who 22 were you referring to in that message; do you 23 remember? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 157 of 465 Page 157 1 G Maxwell - Confidential 2 Q. The question is, do you recall this 3 message? 4 A. I do not recall this message. 5 Q. Do you recall training a female 6 under the age of 18 at Jeffrey's home? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I never trained a female under the 10 age of 18 at Jeffrey's home. 11 Q. Did you ever say it would be 12 helpful to have a female under the age of 18 13 come to Palm Beach today to stay here and 14 help train new staff with Ghislaine? 15 A. I never asked anyone under the age 16 of 18 come to help train new staff. 17 Q. I'm going to flip to the next page 18 which is . 19 A. By the way, that is not my 20 handwriting and it's not dated and I couldn't 21 possibly tell you who that is. 22 Did you hear that? 23 Q. You got your testimony on the 24 record. 25 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 158 of 465 Page 158 1 G Maxwell - Confidential 2 A. Yes. 3 MR. EDWARDS: Giuffre 4 Q. I'm going to direct your attention 5 to the top right-hand corner, for Mr. 6 Epstein, , message a phone 7 number and called. 8 Do you know who is? 9 A. I don't. 10 Q. Do you know that was 15 at 11 the time she left this message? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I don't know who is. 15 Q. And then I'm going to direct your 16 attention to the bottom left which is a 17 message JE message of Jean Luc and the 18 message says, He just did a good one, 18 19 years, she spoke to me and said I love 20 Jeffrey. 21 Was Jean Luc referring to sex with 22 an 18 year old in that message? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. How could I know what Jean Luc is Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 159 of 465 Page 159 1 G Maxwell - Confidential 2 referring to. 3 Q. Do you know if Jean Luc had sex 4 with an 18 year old that he referenced to 5 Jeffrey Epstein? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. How could I possibly know. 9 Q. Did Jeffrey Epstein or Jean Luc 10 ever tell you that Jean Luc had sex with an 11 18 year old? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I have no idea what you are talking 15 about. 16 Q. Did they ever tell you that? 17 A. I have no recollection of ever 18 hearing such a ridiculous thing. 19 Q. I will turn to the next page which 20 is SAO 2841? 21 MS. MENNINGER: Do you have the 22 Bates number? 23 Q. The bottom right-hand corner, Mr. 24 Epstein, the date Ms. Maxwell, it 25 says, it says, quote, is Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 160 of 465 Page 160 1 G Maxwell - Confidential 2 available on Tuesday, no one for tomorrow. 3 Is this a message you took? 4 A. It's not my handwriting and I don't 5 know who R is. 6 Q. So when it says Ms. Maxwell in the 7 line there, is that you calling for Mr. 8 Epstein? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I didn't write it, I don't know 12 when this message was taken. I don't even 13 know what it's referring to and I don't know 14 what my name is doing on that message pad. 15 Q. I know you said you only took them 16 a few times. Do you have a recollection of 17 taking messages of females who would call the 18 house to indicate whether or not they were 19 coming over? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Give me a date range. 23 Q. On 7/9/04. 24 A. How would I know if I'm in Palm 25 Beach, most likely not. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 161 of 465 Page 161 1 G Maxwell - Confidential 2 Q. I'm asking if you have a 3 recollection of taking messages for girls who 4 would call the house -- 5 A. Girls. 6 Q. Females, who would call the 7 house -- 8 A. Over the age of 18. 9 Q. is 15. 10 A. I don't know who is, so I 11 can't testify anything to 12 Q. Your name is on the message. 13 A. I didn't put it there and I don't 14 know what it's doing there. 15 Q. So your testimony is you didn't 16 take this message? 17 A. I obviously didn't take the 18 message, it's signed by somebody R, it's not 19 my handwriting. We don't know if I'm in Palm 20 Beach. 21 Q. Did you arrange for to have 22 his friend come over on Tuesday of 23 this week? 24 A. I don't know who is so it 25 would be hard for me to arrange anything with Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 162 of 465 Page 162 1 G Maxwell - Confidential 2 someone I don't know. 3 Q. Why is your name reflected on this 4 message pad? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I have no idea. You would have to 8 ask whoever took the message. 9 Q. Did you, in the course of your 10 work, regularly take messages for Jeffrey 11 Epstein? 12 A. I already testified I hardly ever 13 did. 14 Q. Would you, in the course of your 15 work, regularly set up appointments for 16 females to come over and give massages for 17 Jeffrey Epstein? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. Can you specify, females, you mean 21 adults over the age of 18. 22 Q. Did you regularly set up for 23 Jeffery adults over the age of 18 to come for 24 massages? 25 A. I didn't regularly do that, no. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 163 of 465 Page 163 1 G Maxwell - Confidential 2 Q. Would you take messages with 3 respect to females over the age of 18 to come 4 over for a massage? 5 A. I already testified I hardly ever 6 did take messages. 7 Q. But would you? 8 A. I already testified, I hardly 9 ever -- 10 Q. I know hardly ever, but did you? 11 A. Over the course of time it is 12 possible I may have taken a couple, I have no 13 recollection. I hardly ever did and I did so 14 irregularly that it would hard for me to 15 pinpoint. 16 Q. Did you ever take a message for a 17 female under the age of 18 to come over for a 18 massage or for any other reason to be with 19 Jeffrey Epstein? 20 MR. PAGLIUCA: Object to the form 21 and foundation. 22 A. I hardly ever took a message. I 23 have absolutely no way of knowing, maybe one 24 of my friends' daughters called to say they 25 were coming to visit me. I have never taken Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 164 of 465 Page 164 1 G Maxwell - Confidential 2 messages, I don't know about how I would 3 possibly know if somebody I spoke to, one or 4 two times I took a message is, how old they 5 would be but I have never taken a message 6 where I was aware of anything being under the 7 age of 18 and I probably took it so 8 infrequently, it would be impossible. 9 Q. Can you turn to it 10 should be the next page. 11 A. Uh-huh. 12 Q. Do you see at the top, it says, for 13 Mr. J. 11/8/04 and then the name is 14 redacted. It says, I have a female for him. 15 Why would a minor be calling 16 Jeffrey to say they have a female for him? 17 Do you know? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. First of all, I don't know that's a 21 minor, I don't know who took the message. 22 Q. I will represent to you these are 23 police reports and minor's names have to be 24 redacted for privacy purposes? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 165 of 465 Page 165 1 G Maxwell - Confidential 2 form and foundation. 3 Q. Do you know why a minor child would 4 be calling Jeffrey and leaving a message to 5 say, quote, I have a female for him? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I can't testify anything about this 9 message, I don't know anything about it. 10 Q. I'm going to direct your attention 11 to the next page If you look at 12 the bottom left, you are going to see a 13 message for Jeffrey, from , it 14 says she doesn't have a number and left a 15 message that she called. 16 Do you know who is? 17 A. I do not. 18 Q. Do you know that was 19 13 at the time she placed this call to 20 Jeffrey? 21 A. I don't know who is. 22 Q. Would Jeffrey regularly have 13 23 year olds call and leave messages? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 166 of 465 Page 166 1 G Maxwell - Confidential 2 A. How would I possibly, these were 3 messages taken when I was not at the house 4 and I have no idea who they are nor how old 5 they are nor anything. 6 Q. How do you know you weren't at the 7 house on this day? 8 A. I was hardly at the house in 2005. 9 Q. So you could have been there, you 10 just don't know? 11 A. In the five days I might have been 12 there in 2005, I suppose it's possible but 13 it's unlikely. 14 MR. PAGLIUCA: Do you know why this 15 isn't redacted if you are representing 16 all the names of people who are underage 17 have been redacted from these records. 18 MS. McCAWLEY: I think it was -- my 19 assumption is it was a miss by the 20 police department. 21 Q. I will direct your attention to 22 so you will skip a page and go back, 23 it's the final page in the message pads and 24 you will see on the top left for Jeffrey, on 25 6/1/2005 from Jean Luc Brunel with a phone Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 167 of 465 Page 167 1 G Maxwell - Confidential 2 number. It says, quote, He has a teacher for 3 you to teach you how to speak Russian. She 4 is two times eight years old. Not blond. 5 Lessons are free and you can have your first 6 today if you call. 7 Do you know whether Jean Luc Brunel 8 sent a Russian girl that was 16 years old 9 over to Jeffrey Epstein's home? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I do not know. 13 Q. Did you ever observe a Russian girl 14 that was 16 years old come to Jeffrey 15 Epstein's home? 16 A. I am not aware of any 16 year old 17 Russian girl that I can recall in Jeffrey 18 Epstein's home. 19 Q. Do you know whether Jeffrey Epstein 20 had sex with a 16 year old Russian girl? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I do not know. 24 THE VIDEOGRAPHER: It's 12:25. 25 This will be the end of disk 3, we are Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 168 of 465 Page 168 1 G Maxwell - Confidential 2 off the record. 3 (Recess.) 4 A F T E R N O O N S E S S I O N 5 (Time noted: 1:21 p.m.) 6 G H I S L A I N E M A X W E L L, 7 resumed and testified as follows: 8 EXAMINATION BY (Cont'd.) 9 MS. McCAWLEY: 10 THE VIDEOGRAPHER: It's now 1:21, 11 we're starting disk No. 4. We are back 12 on the record. 13 Q. Ms. Maxwell, before the break, we 14 were talking about and I think it's one of 15 the exhibits that's marked in front of you, 16 I'm not sure of the number, but the police 17 report that I showed you earlier today. 18 Now that you have knowledge of the 19 police report and the criminal investigation 20 with respect to Jeffrey Epstein, do you 21 believe that Jeffrey Epstein abused any minor 22 children? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Can you repeat the question please Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 169 of 465 Page 169 1 G Maxwell - Confidential 2 and break it down so it's more 3 understandable. 4 Q. Now that you have the police report 5 that I showed you this morning that you had 6 an opportunity to look at. 7 A. You gave it to me, I did not look 8 at it. 9 Q. The questions that I asked you 10 about the police report -- you are aware 11 there is a police report? 12 A. I am aware there is a police 13 report. 14 Q. You are aware there was a criminal 15 investigation of Jeffrey Epstein? 16 A. I am aware that there was that. 17 Q. Now that you are aware of those two 18 things and having talked to Jeffrey Epstein, 19 do you believe Jeffrey Epstein sexually 20 abused minors? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. Can you reask the second part of 24 that question please. 25 Q. Sure. The two documents we were Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 170 of 465 Page 170 1 G Maxwell - Confidential 2 talking about, the document and the 3 investigation, you said you are aware of and 4 after having talked to Jeffrey Epstein, do 5 you believe Jeffrey Epstein sexually abused 6 minors? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. What do you mean I talked to 10 Jeffrey, you need to break the question down 11 further. 12 Q. So you have the police report. 13 A. I do. 14 Q. And you are aware of the criminal 15 investigation? 16 A. I am. 17 Q. Let's take those two things. After 18 knowing those two things, do you believe that 19 Jeffrey Epstein abused minor children? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Can you explain what you mean by 23 the question actually. 24 Q. I think the question speaks for 25 itself. I will try again. I will say it one Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 171 of 465 Page 171 1 G Maxwell - Confidential 2 more time because I want you to be able to 3 understand it. 4 Knowing that you have the police 5 report here and knowing about the criminal 6 investigation, do you believe that Jeffrey 7 Epstein sexually abused minors? 8 MR. PAGLIUCA: Same objection. 9 A. I know what you put in front of me 10 and I know what I read. 11 Q. I'm asking what you believe, do you 12 believe Jeffrey Epstein sexually abused 13 minors? 14 A. I can only tell you what I read and 15 what you showed me. 16 Q. I'm asking what you believe, from 17 your own belief, do you believe that Jeffrey 18 Epstein abused minors? 19 A. I can only go from what I know 20 personally and what I know personally about 21 what Virginia's lies talked about. She is 22 the only person I know that actually claimed 23 that. And I can say with certitude that 24 everything Virginia said was a lie. 25 Q. You are aware Jeffrey Epstein was Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 172 of 465 Page 172 1 G Maxwell - Confidential 2 sentenced for sexual abuse, are you aware of 3 that? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 Q. Are you aware that Jeffrey Epstein 7 served time for sexual abuse of a minor? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I don't believe that's what he was 11 sentenced for, actually. 12 Q. So you don't know that Jeffrey 13 Epstein served time for sexually abusing a 14 minor? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I don't believe that's what he was 18 sentenced for. 19 Q. Do you know that Jeffrey Epstein 20 was convicted for procuring a minor for 21 prostitution? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. I don't know exactly what he was 25 convicted of. I don't know that he was Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 173 of 465 Page 173 1 G Maxwell - Confidential 2 convicted. I know he spent time in jail. 3 Q. Do you know that he spent time in 4 jail related to an issue with a minor child? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I did not know that. 8 Q. What did you think he was spending 9 time in jail for? 10 A. I only know he went to jail for -- 11 it was alleged that he hired -- had an 12 underage prostitute. 13 Q. So knowing that, do you believe 14 that Jeffrey Epstein sexually abused minors? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I can only tell you what he went to 18 jail for. 19 Q. I'm asking what you believe. I'm 20 not asking what he went to jail for. I'm 21 asking for your belief. 22 A. I cannot testify to what I believe. 23 I can only say what I have seen in the 24 reports and I know he went to jail. 25 Q. You can testify to what you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 174 of 465 Page 174 1 G Maxwell - Confidential 2 believe. Do you believe -- 3 A. I can only testify -- 4 Q. Let me finish the question so the 5 record is clear. 6 Do you believe Jeffrey Epstein 7 sexually abused minors? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 Q. You can answer. 11 A. I can only testify to what I know. 12 I know that Virginia is a liar and I know 13 what she testified is a lie. So I can only 14 testify to what I know to be a falsehood and 15 half those falsehoods are enormous and so I 16 can only categorically deny everything she 17 has said and that is the only thing I can 18 talk about because I have no knowledge of 19 anything else. 20 Q. I'm not asking about Virginia. I'm 21 asking whether you believe that Jeffrey 22 Epstein sexually abused minors? 23 A. Again, I repeat, I can only go on 24 what I know and what I know is a falsehood 25 based on what Virginia said. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 175 of 465 Page 175 1 G Maxwell - Confidential 2 Q. Do you believe Jeffrey Epstein 3 sexually abused minors? 4 A. Again, I repeat, Virginia is a liar 5 and based on Virginia's stories, that is 6 what -- she lied and I can only then talk 7 about what you've showed me in the police 8 reports and I know he went to jail. 9 Q. Do you believe that Jeffrey Epstein 10 sexually abused minors? I'm asking about 11 your belief. 12 A. Again, I just repeat, I can only 13 go -- my belief is Virginia is a liar. 14 Q. What is that belief? 15 A. She is an absolute liar and 16 everything she said is a lie and therefore, 17 everything that stems from that is a lie. 18 Q. So do you believe that Jeffrey 19 Epstein sexually abused minors? 20 A. Again -- can we move on from here? 21 Q. No. You are going to answer the 22 question. 23 A. I have already. 24 Q. No, you haven't. 25 A. I have. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 176 of 465 Page 176 1 G Maxwell - Confidential 2 Q. Do you believe Jeffrey Epstein 3 sexually abused minors? 4 A. Again, I repeat, the only person I 5 know who has talked about these things that I 6 have personal -- was personally present, was 7 Virginia and I can only talk to Virginia and 8 she is a liar. 9 Q. Setting aside Virginia. Take her 10 out of the picture. It's my question. 11 A. We are here today because of 12 Virginia and her lies because this is a 13 defamation suit. 14 Q. Setting aside Virginia, do you 15 believe Jeffrey Epstein sexually abused 16 minors? 17 A. I cannot set aside Virginia because 18 that's why we are here and this is the only 19 reason I am sitting here in this room and I 20 will not set her aside and I cannot comment 21 about anything else except her because she is 22 the only person I actually know about. 23 Q. Are you refusing to answer that 24 question? 25 A. I am not refusing the question. I Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 177 of 465 Page 177 1 G Maxwell - Confidential 2 can only testify about Virginia who is an 3 absolute total liar and you all know she is. 4 She lied about her age, you know she lied 5 about absolutely everything. So I can only 6 go on what I know as a liar and she is a 7 liar, an exaggerator, a fantasist and 8 absolutely true terrible person. 9 Q. I want you to listen very 10 carefully. I am asking you to set aside 11 Virginia. 12 A. I can't set aside Virginia. 13 Q. I am asking you to do that for 14 purposes of this question. 15 MR. PAGLIUCA: She doesn't have to. 16 MS. McCAWLEY: She can refuse to 17 answer the question. 18 A. I'm not refusing to answer the 19 question. 20 Q. You are refusing. 21 My question has nothing to do with 22 Virginia. Let me make the record here. My 23 question has nothing to do with Virginia. I 24 want it to be clear for the court. My 25 question has nothing to do with Virginia. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 178 of 465 Page 178 1 G Maxwell - Confidential 2 What I'm asking you is whether you 3 believe Jeffrey Epstein abused minors? 4 MR. PAGLIUCA: I object to the form 5 and you made your record, she answered 6 the question. A fair reading of her 7 answer is she doesn't have a belief 8 because she doesn't have any personal 9 knowledge. 10 MS. McCAWLEY: Now you are 11 testifying for the witness. Let her 12 answer the question. 13 MR. PAGLIUCA: It's a fair answer 14 to the question. 15 A. Again, I testified my only personal 16 knowledge concerns Virginia and everything 17 Virginia has said is an absolute lie, which 18 is why we are here in this room. If you are 19 asking me to testify about things I have no 20 knowledge of other than the police report 21 that you showed me, I am not in a position to 22 make a statement based on that because you 23 are asking me to speculate and I cannot 24 speculate. 25 Q. I'm asking you about your belief. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 179 of 465 Page 179 1 G Maxwell - Confidential 2 I'm not asking you to speculate at all. I'm 3 asking what you believe. 4 A. You are asking me to speculate and 5 I won't speculate. 6 Q. I'm not asking you to speculate. 7 I'm asking what you believe. 8 MR. PAGLIUCA: She answered the 9 question and we can move on. 10 MS. McCAWLEY: She hasn't answered 11 the question. 12 MR. PAGLIUCA: We are not going to 13 engage in this debate. She answered the 14 question. If you want to mark it and 15 move to compel an answer to the 16 question, have at it. Okay. 17 Q. Ms. Maxwell, is it your belief that 18 Jeffrey Epstein interacted sexually with 19 minors? 20 A. Again, you are asking me the same 21 type of question exactly but with different 22 language. Again, my only knowledge of 23 somebody who claims these things that I have 24 personal knowledge of is Virginia. Virginia 25 is an absolute liar and everything she has Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 180 of 465 Page 180 1 G Maxwell - Confidential 2 said is a lie. Therefore, based on those 3 lies I cannot speculate on what anybody else 4 did or didn't do because if Virginia is the 5 example of what that story is and everything 6 she said is false, so everything that leads 7 from that is false. 8 Q. So the 30 other minor children in 9 the police report are also telling lies about 10 being sexually abused during massages with 11 Mr. Epstein? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. Counsel, can you 14 show me in these police reports who the 15 30 minors are? 16 MS. McCAWLEY: I'm asking my 17 question. 18 MR. PAGLIUCA: You are making a 19 representation about numbers, you are 20 making a representation on the record 21 about what people said or didn't say. 22 We have no knowledge about that. These 23 are all redacted records so these are 24 bad questions. They don't lead to any 25 admissible evidence. It is only being Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 181 of 465 Page 181 1 G Maxwell - Confidential 2 propounded to the witness to harass her. 3 So we are done with these questions. 4 MS. McCAWLEY: Are you done? 5 MR. PAGLIUCA: Yes. 6 Q. My question is, are you aware that 7 Jeffrey Epstein was convicted of having 8 relations with a minor child? 9 MR. PAGLIUCA: She answered that 10 question already. 11 MS. McCAWLEY: I'm getting to my 12 next question. 13 MR. PAGLIUCA: Ask your next 14 question. Don't keep asking the same 15 question. 16 MS. McCAWLEY: You are now 17 shouting, I want the record to reflect 18 that you are interrupting the 19 deposition. I ask you to calm down, 20 take a deep breath and please let me ask 21 my questions. 22 MR. PAGLIUCA: Your behavior is 23 inappropriate. 24 Q. I will ask you again. 25 Do you believe that Jeffrey Epstein Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 182 of 465 Page 182 1 G Maxwell - Confidential 2 interacted sexually with minors? 3 A. Again, I go back to this, my only 4 actual knowledge is with Virginia and 5 Virginia is a liar, so I can only talk to 6 what Virginia's story and as I said before 7 and there are so many examples, I mean 8 thousands of examples of her lies, that that 9 is the only thing I can talk to. 10 Q. Based on that you do not believe 11 that Jeffrey Epstein sexually abused minors? 12 A. Again, as I said, I'm only talking 13 to what I know, I can only talk to Virginia. 14 Q. So is it your belief that Jeffrey 15 Epstein did not sexually abuse minors? 16 A. Again, I can only talk to what I 17 know and I know that Virginia is a liar and 18 that what she said is a lie. So I can only 19 testify to what she accused and you guys put 20 in the press for salacious purposes and 21 whatever terrible, inappropriate, unethical 22 and terrible reasons you chose to do that 23 about me and I can testify those are all 24 lies. 25 Q. Do you know whether Jeffrey Epstein Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 183 of 465 Page 183 1 G Maxwell - Confidential 2 sexually abused any minor children? 3 A. Again, I only know 1000 percent 4 that Virginia is a liar. I can only talk to 5 Virginia, her lies and your inappropriate, 6 unethical, really unattractive, terrible use 7 of her and the way that you have abused the 8 system, used the press for purposes that are 9 unethical, inappropriate and appalling. 10 Q. Do you believe that Jeffrey Epstein 11 used massages to lure minors to have sex with 12 him? 13 A. Again, that is Virginia's 14 testimony, which is a lie. 15 Q. But do you believe that? 16 A. Again, I refer back to Virginia. 17 Q. I'm asking whether you believe it 18 or not? 19 A. I can only go with what I know and 20 I know Virginia is a liar and therefore 21 that's a lie. 22 Q. So you don't believe that? 23 A. I said, I only know that Virginia 24 is lying. 25 Q. Are you aware that Jeffrey Epstein Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 184 of 465 Page 184 1 G Maxwell - Confidential 2 is a registered sex offender? 3 A. I am. 4 Q. Are you aware that Jeffrey Epstein 5 paid considerable amounts of money to settle 6 lawsuits with the minor children that he had 7 sexual contact with? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I have no knowledge of those 11 issues. 12 Q. Why did you continue to maintain 13 contact with Jeffrey Epstein after he pled 14 guilty? 15 A. I'm a very loyal person and Jeffrey 16 was very good to me when my father passed 17 away and I believe that you need to be a good 18 friend in people's hour of need and I felt 19 that it was a very thoughtful, nice thing for 20 me to do to help in very limited fashion 21 which was helping if he had any issue with 22 his homes, in terms of the staffing issues. 23 It was very, very minor but I felt it was 24 thoughtful in somebody's hour of need. 25 Q. Did he continue to pay you during Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 185 of 465 Page 185 1 G Maxwell - Confidential 2 that time period? 3 A. I was paid a little. 4 Q. You were paid? 5 A. Yes. 6 Q. When you say a little, what you did 7 mean by that? 8 A. I don't recall exactly the amount. 9 Q. So in 2009 when you left him, what 10 were you being paid? 11 A. I just told you, I don't recall. 12 Q. Were you being paid $100,000? 13 A. I just don't you I don't recall. 14 Q. Were you paid over a million 15 dollars? 16 A. I think I would remember over a 17 million dollars. 18 Q. So it was under a million dollars? 19 A. It was under a million dollars. 20 Q. Was it over $500,000? 21 A. I just told you, it was under 500, 22 it was an amount of money less than $500,000, 23 less than a million dollars and I did it out 24 of thoughtfulness and consideration for 25 somebody who was in trouble. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 186 of 465 Page 186 1 G Maxwell - Confidential 2 Q. Did you have an attorney to consult 3 with during the criminal investigation of 4 Jeffrey Epstein? 5 A. I don't believe I did. 6 Q. When did you learn that a search 7 warrant was executed for the Palm Beach 8 house? 9 A. I don't recall exactly. 10 Q. Were you present at the house in 11 advance of the search warrant being executed? 12 MR. PAGLIUCA: Object to the form 13 of the question. 14 A. I don't remember when the search 15 warrant was executed and I don't remember the 16 year that the search warrant was executed and 17 whenever that was, I already testified, I was 18 very, very infrequently at the house. So 19 highly unlikely but I was there a couple of 20 days, I just don't know which days it was in 21 relation to the police situation. 22 Q. Did you have a computer at the Palm 23 Beach home that was a computer that you would 24 use? 25 A. No. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 187 of 465 Page 187 1 G Maxwell - Confidential 2 Q. Was there a computer available for 3 use in the Palm Beach house? 4 A. Can you be more specific. 5 Q. Was there anywhere in the Palm 6 Beach house where there was a computer where 7 you said you worked for him and there were 8 other staff in the house, was there ever a 9 computer in the Palm Beach mansion that was 10 accessible by you or other staff? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I stopped being regularly at the 14 house sometime in 2003 so from 2003 to when 15 the police search was executed, I have no 16 memory of what there was or what there was 17 not. I can only testify for what was there 18 when I was present largely. 19 Q. So in 2003 when you were still 20 there, was there a computer that was 21 accessible to you or other staff at the 22 house? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. There was a desktop computer that Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 188 of 465 Page 188 1 G Maxwell - Confidential 2 people could use -- just like you would use 3 if you needed to go online to get something, 4 that people could use. 5 Q. Was that on a desk that you would 6 use in your work capacity when you were at 7 the house? 8 A. It was a desk, it was a room I was, 9 I didn't really use that computer. 10 Q. Were there images of naked girls 11 whether they be under the age of 18 or over 12 the age of 18 on that computer? 13 A. I have no recollection of any naked 14 people on that computer when I was there in 15 2003, we are talking. 16 Q. What about from say '99 to 2003? 17 A. No, I can't recollect any naked 18 pictures. 19 Q. Why were the computers removed from 20 the house before the search warrant was 21 executed? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. I have no knowledge of anything 25 like that. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 189 of 465 Page 189 1 G Maxwell - Confidential 2 Q. Do you know where the computers are 3 now? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I don't know what computers you are 7 talking of and I have no idea what you are 8 referencing. 9 Q. In 2003 you said there was a 10 computer in a room on a desk? 11 A. Right. 12 Q. Do you know where that computer is 13 now? 14 A. I do not. 15 Q. Did you take pictures of nude 16 females in any of Epstein's homes or in and 17 around the homes, out by the pool or anywhere 18 like, in the Palm Beach home, the New York 19 home, USVI home or the New Mexico home? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Can you repeat the question. 23 Q. Did you take pictures of nude woman 24 over 18 or under 18, females, in any of 25 Jeffrey Epstein's homes, inside or outside in Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 190 of 465 Page 190 1 G Maxwell - Confidential 2 or around the home? 3 A. I think we need to distinguish 4 between anyone under the age of 18 and over 5 the age of 18. 6 Q. We will start with, did you take 7 pictures of nude females in or around any of 8 Jeffrey's homes of women or females that were 9 under the age of 18? 10 A. No. 11 Q. Did you take pictures of nude 12 females -- 13 A. Nude you mean with no clothing on. 14 Q. Or half nude, with no top on, any 15 sort of nakedness to an individual. 16 In any of Jeffrey's homes, either 17 Palm Beach, New Mexico, USVI or New York 18 either outside by the pool, anywhere in or 19 around those homes of females over the age of 20 18? 21 A. So it is possible that I took 22 pictures of people that were somehow semi or 23 had some clothing on or no clothes on but at 24 no time were any of these pictures remotely 25 inappropriate. They were, you could see them Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 191 of 465 Page 191 1 G Maxwell - Confidential 2 in a mainstream magazine today, there would 3 be no inappropriateness, they would be 4 covered, concealed, you wouldn't see anything 5 at all. 6 The types of -- first, I took very 7 few and they were always by request, this was 8 a picture you could put on your -- gift to 9 your parent or to your grandparents to put on 10 their mantel piece . It would be a very 11 benign sort of attractive picture where you 12 wouldn't see anything. 13 Q. Who would request those pictures? 14 A. From time to time, people, men and 15 women would ask to have nice photographs of 16 them taken. 17 Q. And did Jeffrey Epstein request 18 those pictures? 19 A. I don't ever recall him asking me 20 to take pictures. 21 Q. Did you give him pictures of naked 22 females as a present? 23 A. I don't recall ever giving a 24 present of -- I don't know why a photograph 25 would constitute a gift. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 192 of 465 Page 192 1 G Maxwell - Confidential 2 Q. Not as a gift. 3 Do you recall ever giving Jeffrey 4 Epstein pictures that you've taken of these 5 individuals in a naked state? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. First of all, we've already 9 established that they are not naked state 10 photographs. 11 Q. A piece of them being naked as you 12 described. 13 A. I said they would be attractive as 14 you would see in mainstream magazines and 15 those pictures could be a picture of a hand 16 or a foot, they didn't necessarily 17 constitute -- I know where you are headed 18 with this and it's nowhere appropriate and 19 it's really unattractive. 20 Q. I'm not headed anywhere. I'm just 21 asking the questions. Did you give Jeffrey 22 Epstein any of these pictures that you took 23 of females in the state that you described? 24 A. I can't recall ever giving him 25 pictures but it is possible that I took Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 193 of 465 Page 193 1 G Maxwell - Confidential 2 pictures of people that would end up -- or a 3 friend of his that he would have -- not naked 4 or not inappropriate in any way, that he 5 might have somewhere in his house. 6 Q. Name for me all the individuals who 7 you took these pictures of? 8 A. It's entirely impossible for me to 9 name people. First of all, it was just -- it 10 would not be possible, I took thousands of 11 photos, not of people, I mostly take pictures 12 of landscapes and things. I have no 13 recollection specifically of people that I 14 took pictures of. 15 Q. So you can't remember, is it your 16 testimony you can't remember one person that 17 you took a picture of in either a naked or 18 semi naked state? 19 A. I seriously cannot recall. I just 20 don't recall. 21 Q. Did you take a picture of Virginia 22 Roberts either alone or with another 23 individual in a naked state? 24 A. I have never taken, I believe, any 25 pictures of two people in any type of Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 194 of 465 Page 194 1 G Maxwell - Confidential 2 situation, naked as you describe. 3 Q. Did you take a picture of Virginia 4 Roberts on her own without another individual 5 in it in a naked state? 6 A. I don't recall ever taking a 7 picture of Virginia -- naked, we are not 8 referring to someone with no clothing on at 9 all, we are referring to someone that could 10 be semi clad or could have a towel or we are 11 not referring to anything inappropriate. 12 Q. Was this a hobby of yours to take 13 pictures of the type that you are describing? 14 MR. PAGLIUCA: Object to the form. 15 A. I just testified, I didn't take 16 pictures of many people. My preference is 17 pictures for landscapes and for architectural 18 pieces. 19 Q. Where are those pictures today? 20 A. I have no idea. 21 Q. Do you have them in your home? 22 A. I do not. 23 Q. Do you have them on your computer? 24 A. I do not. 25 Q. What has Jeffrey Epstein told you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 195 of 465 Page 195 1 G Maxwell - Confidential 2 about the allegations related to the criminal 3 investigation that he was involved in? 4 A. I really can't say, not because I 5 don't want to say but I just think of what he 6 has said to me over the course of this time. 7 Q. Did he explain it to you and 8 explain what the charges were against him? 9 A. I never had a detailed conversation 10 with him, as I recall. 11 Q. Not detailed, just did he explain 12 anything that was happening to him? 13 A. I haven't spoken to him for so 14 long. I can't possibly testify to what 15 conversations I had with him over the course 16 of time. 17 Q. Did he talk to you about any of the 18 girls that were making allegations against 19 him other than Virginia? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. You are talking about the police 23 records again, all of that? 24 Q. Yes. 25 A. I have never had a conversation Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 196 of 465 Page 196 1 G Maxwell - Confidential 2 about those things. 3 Q. What has Jeffrey Epstein told you 4 about Virginia Roberts? 5 A. That she is a liar. 6 Q. What does he base that on? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. You would have to check with him. 10 I can tell you why I think she is a liar, I'm 11 happy to do that. 12 Q. Did he tell you he did not have 13 sexual relations with Virginia Roberts? 14 A. I can only testify what I know. 15 Q. I'm asking, has he told you that he 16 did not have sexual relations with Virginia 17 Roberts? 18 A. I can only tell you what I know 19 about Virginia Roberts, I cannot tell you 20 what he knows about Virginia Roberts. 21 Q. I'm asking, did he tell you that he 22 did not have sexual relations with Virginia 23 Roberts? 24 A. All he told me is she is a liar. 25 Q. That's all he said about Virginia Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 197 of 465 Page 197 1 G Maxwell - Confidential 2 Roberts? 3 A. We went through all the lies that 4 you have sold to the papers and sold in 5 general and we have analyzed her lies and 6 your lies and your inappropriate behavior in 7 detail. 8 Q. Did he ever say that he did not 9 have sexual relations with Virginia Roberts? 10 A. I just testified that we went 11 through all of her lies. 12 Q. I understand what you said. I'm 13 asking you a question. 14 Did he ever tell you that he never 15 had sex with Virginia Roberts? 16 A. I don't recall whether he ever -- I 17 don't know I ever had that question. We 18 focused on the lies she did say she had with 19 him as relates to me. I don't remember 20 asking him about his problems with her. I'm 21 interested in what she says about myself. 22 Q. Did you also talk about what things 23 that Virginia Roberts was saying that were 24 true? 25 A. There isn't anything that she said Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 198 of 465 Page 198 1 G Maxwell - Confidential 2 that was true. 3 Q. Nothing she said that you are aware 4 of is true? 5 A. I think she is correct when she 6 talks about what her name is. 7 Q. Anything else? 8 A. I'm sure there must be one or two 9 other details but they are so far and few 10 between, I would have to look in detail at 11 all of her allegations to pinpoint what 12 possibly could be true. 13 Q. Did you ever ask Jeffrey if he had 14 sex with minors? 15 A. I have never been asked that 16 question. 17 Q. You never asked him that question. 18 What analysis did Jeffrey do to 19 determine that the statements Virginia 20 Roberts were making were lies? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. Ask me again, please. 24 Q. What analysis did Jeffrey do to 25 determine that the statements that Virginia Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 199 of 465 Page 199 1 G Maxwell - Confidential 2 Roberts were making were lies? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. And to the extent 5 that any of this answer calls for any 6 privileged communication, I'm 7 instructing, with myself or another 8 lawyer representing you or in any common 9 interest agreement, I'm instructing you 10 not to answer. 11 MS. McCAWLEY: The court ruled she 12 is entitled and you had to produce 13 documents about communications with 14 Jeffrey, that's what I'm asking about. 15 I'm not asking about communications with 16 lawyers. 17 Q. I'm asking what analysis did 18 Jeffrey do to determine that the statements 19 that Virginia Roberts was making were lies, 20 if you know? 21 MR. PAGLIUCA: My objection is to 22 the extent she learned any of that 23 information as a result of either a 24 privileged communication from a lawyer, 25 one of her lawyers or a privileged Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 200 of 465 Page 200 1 G Maxwell - Confidential 2 communications subject to a joint 3 defense agreement or common interest 4 agreement, I'm telling her not to 5 answer. To the extent she has 6 information outside of those things, she 7 is permitted to answer. 8 Q. Do you understand? 9 So if it was a conversation with a 10 lawyer which I'm not asking about, I don't 11 want you to tell me about your conversations 12 with lawyers. 13 I want you to tell me whether 14 Jeffrey Epstein ever told you what he 15 analyzed in order to determine which of -- of 16 what Virginia were saying were lies? 17 A. I do not know what he did, no. 18 So you agree she is lying, Singrid. 19 Q. I do not agree with that and I'm 20 asking the questions. 21 A. You just said her lies. 22 Q. I'm repeating a statement you made. 23 Q. Are you saying it's an obvious lie 24 that Jeffrey Epstein engaged in sexual 25 conduct with Virginia while Virginia was Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 201 of 465 Page 201 1 G Maxwell - Confidential 2 underage? 3 A. I can only testify to what I saw 4 and what I was present for, so if you are 5 asking me what I saw then I am happy to 6 testify. I cannot testify to what somebody 7 else did or didn't do. 8 Q. Did you issue a statement to your 9 press agent, Ross Gow in 2015, stating that 10 Virginia Roberts' claims were, quote, obvious 11 lies? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 Q. You can answer. 15 A. You need to reask me the question. 16 Q. Sure. 17 Did you issue a press statement 18 through your press agent, Ross Gow, in 19 January of 2015, stating that Virginia 20 Roberts' claims were, quote, obvious lies? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. Can you ask it a different way, 24 please? 25 Q. I will ask it again and you can Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 202 of 465 Page 202 1 G Maxwell - Confidential 2 listen carefully. 3 Did you issue a press statement 4 through your press agent, Ross Gow, in 5 January of 2015, where you stated that 6 Virginia Roberts' claims were, quote, obvious 7 lies? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. So my lawyer, Philip Barden 11 instructed Ross Gow to issue a statement. 12 Q. Today, did you say that Virginia 13 lied about, quote, absolutely everything? 14 A. I said that there are some things 15 she may not have lied about. 16 Q. So are you saying it's an obvious 17 lie that Jeffrey Epstein engaged in sexual 18 contact with Virginia while Virginia was 19 underage? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Can you ask the question again, 23 please? 24 Q. Are you saying it's an obvious lie 25 that Jeffrey Epstein engaged in sexual Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 203 of 465 Page 203 1 G Maxwell - Confidential 2 conduct with Virginia while Virginia was 3 underage? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 Q. You can answer. 7 A. Try again, please. 8 Q. Are you saying that it's an obvious 9 lie that Jeffrey Epstein engaged in sexual 10 conduct with Virginia while Virginia was 11 underage? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. Again, I'm telling you, first of 15 all, it was a statement that was issued by my 16 lawyer and -- through my lawyer to Ross Gow. 17 Q. I understand that. I'm asking you, 18 are you saying that it's an obvious lie that 19 Jeffrey Epstein engaged in sexual conduct 20 with Virginia while Virginia was underage. 21 Is that a lie? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 Q. You can answer. 25 A. So I cannot testify to what Ross Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 204 of 465 Page 204 1 G Maxwell - Confidential 2 Gow and Philip Barden decided to put -- I can 3 testify to what Virginia's obvious lies are 4 as regards to me. I cannot make 5 representations about all the many lies she 6 may or may not have told about Jeffrey. 7 Q. So is Virginia lying when she says, 8 is it an obvious lie when she says that she 9 had sex with Jeffrey Epstein while she was 10 underage? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. Again, I'm testifying to what I 14 know to be true. I can only testify to all 15 the many lies she told about me. I cannot 16 testify to what lies she told about somebody 17 else. Given she told so many about me, one 18 can probably infer she is lying about 19 everything. 20 Q. So you think she is lying when she 21 said she had sex with Jeffrey Epstein when 22 she was underage? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Again, I can only talk about what I Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 205 of 465 Page 205 1 G Maxwell - Confidential 2 can positively say myself, not what somebody 3 else is going to represent. 4 Q. When you were saying that she was, 5 her claims of having sex with Jeffrey Epstein 6 were obvious lies, are you saying she is 7 lying about engaging in sexual conduct with 8 Jeffrey Epstein when she was underage? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 Q. You can answer. 12 A. Again, this was a statement that 13 was put out from my lawyer through my press 14 person in London. And I can only testify to 15 the obvious lies that she says about me. I 16 cannot make representations about lies she 17 says about someone else, but she lies so many 18 times about me, one can probably infer she is 19 lying about everything. 20 Q. So is she not lying when -- is she 21 telling the truth when she says she had sex 22 with Jeffrey Epstein when she was underage? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Again, I don't know how else to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 206 of 465 Page 206 1 G Maxwell - Confidential 2 tell you, I can only talk about what I know 3 to be true. What I know is her story about 4 how she claims that initial situation 5 happened is so egregiously false and such a 6 giant fat enormous, repulsive, disgusting, 7 inappropriate, vile lie, that that I can 8 testify to. 9 Q. Was she lying when she said she met 10 you at Mar-a-Lago? 11 A. Again I already testified I don't 12 recall meeting her at Mar-a-Lago. 13 Q. We showed you a document where you 14 said you met her at Mar-a-Lago when she was 15 17, is that correct? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. I think I already testified to 19 that. What I remembered based on all the 20 rubbish she has written and all the many 21 articles I have read, maybe in the moment 22 when I wrote that, have caused me to have 23 that but on reflection I don't recall it as I 24 sit here today. 25 Q. Are you saying that it was an Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 207 of 465 Page 207 1 G Maxwell - Confidential 2 obvious lie that you approached Virginia 3 while she was under age at Mar-a-Lago? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. First of all, we can all agree 7 here, all of you sitting here that the lies 8 that you perpetrated in the press that she 9 was 15 and we should all agree now that that 10 is fake, a lie that was perpetrated between 11 all of you to make the story more exciting, 12 can we agree on that? 13 Q. That is not my question. 14 A. Can we agree she was not the age 15 she said and you put that in the press, that 16 is obviously, manifestly, absolutely, totally 17 a lie. 18 MS. McCAWLEY: I am going to put on 19 the record, Ms. Maxwell very 20 inappropriately and very harshly pounded 21 our law firm table in an inappropriate 22 manner. I ask she take a deep breath, 23 and calm down. I know this is a 24 difficult position but physical assault 25 or threats is not appropriate, so no Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 208 of 465 Page 208 1 G Maxwell - Confidential 2 pounding, no stomping, no, that's not 3 appropriate,. 4 A. Can we be clear, I didn't threaten 5 anybody. 6 MR. PAGLIUCA: Stop, you made your 7 record, there is no dent in the table. 8 I don't see any chips. Can we take a 9 break now. 10 MS. McCAWLEY: I think it's 11 appropriate to take a break. 12 THE VIDEOGRAPHER: It's 1:56 and we 13 are off the record. 14 (Recess.) 15 THE VIDEOGRAPHER: It's now 2:13, 16 we're starting disk No. 5 and we are 17 back on the record. 18 Q. Ms. Maxwell, how old was Virginia 19 Roberts when you met her in Mar-a-Lago? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I know today that she was 17 years 23 old. 24 Q. Are you saying that it's an obvious 25 lie that Virginia traveled on Jeffrey Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 209 of 465 Page 209 1 G Maxwell - Confidential 2 Epstein's airplanes? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 Q. You can answer. 6 A. Are you referring to my statement 7 where that says that? 8 Q. I'm referring to the language you 9 use in your statement that says, obvious 10 lies? 11 A. Can you read my entire statement? 12 Q. Sure, let me pass it out. 13 (Maxwell Exhibit 10, email,marked 14 for identification.) 15 Q. This is Bates GM 00068 and we will 16 mark it as -- what you have in front of you 17 is a statement at the top. This was produced 18 by your counsel, it is indicated Bates No. 19 GM 00068. At the top the date reflects 20 January 2, 2015 from, appears to be a Ross 21 subject line, is you and 22 then there is a number of individuals you can 23 see at the top that are copied on this that 24 is sent to and bcc'd on this statement. 25 The statement, there are two parts Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 210 of 465 Page 210 1 G Maxwell - Confidential 2 of it. There is an opening email that says, 3 please find an attached quotable statement on 4 behalf of Ms. Maxwell and there is more 5 language there and it's from Ross Gow and 6 then it says in the body of it, Jane Doe No. 7 3 or Jane Doe 3 is Virginia Roberts so not a 8 new individual. The allegations made by, and 9 it says Victoria but I believe that means 10 Virginia Roberts, against Ghislaine Maxwell 11 are not true. The original allegations are 12 not new and have been fully responded to and 13 shown to be untrue. And the next paragraph 14 says, Each time the story is retold, it 15 changes with new salacious details about 16 public figures and world leaders and now it 17 is alleged by Ms. Roberts that Al Dershowitz 18 is involved in having sexual relations with 19 her which he denies. Ms. Roberts claims are 20 obvious lies and should be treated as such 21 and not publicized as news as they are 22 defamatory. 23 The last paragraph states, 24 Ghislaine Maxwell's original response to the 25 lies and defamatory claims remains the same. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 211 of 465 Page 211 1 G Maxwell - Confidential 2 Maxwell strongly denies allegations of the -- 3 strongly denies allegations of an unsavory 4 nature which have appeared in the British 5 press and elsewhere and reserves her right to 6 seek redress at the repetition of such old 7 defamatory claims. 8 Are you saying that it's an obvious 9 lie that Virginia Roberts traveled on Jeffrey 10 Epstein's planes? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I'm saying what's an obvious lie 14 and I think we can all agree, you just had 15 the case tossed out by Alan Dershowitz. He 16 just got removed from the case because you 17 put him in a case that he wasn't supposed to 18 be in so what was said about him is not true. 19 Q. Are you saying that it's an obvious 20 lie that Virginia Roberts traveled on Jeffrey 21 Epstein's plane? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. You have given me plane records 25 that has her name on it but as I already Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 212 of 465 Page 212 1 G Maxwell - Confidential 2 testified those aren't federally mandated 3 things and I can see her name on it but 4 that's what I -- I told you I don't recall 5 her on any planes. 6 Q. Is is that one of Virginia's 7 obvious lies? 8 A. There are more obvious ones. 9 Q. Is that one of them? 10 A. I can't testify to her being on a 11 plane or not. 12 Q. So is that an obvious lie? 13 A. There are more obvious lies, like 14 Clinton. 15 Q. I understand there are more obvious 16 ones. I'm asking you, is the fact that she 17 said she traveled on Epstein's planes an 18 obvious lie? 19 A. I think we can probably say because 20 you see her name on a plane record and she 21 went from A to B, that would not be the 22 obvious lie that I would pick. 23 Q. What obvious lie were you picking 24 when you made this statement? 25 A. There are so many that I would be Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 213 of 465 Page 213 1 G Maxwell - Confidential 2 thrilled to go through all of them. 3 Q. Let's go through them. 4 What's the first one? 5 A. Her characterization of the first 6 meeting at Mar-a-Lago. 7 Q. What part of that was an obvious 8 lie? 9 A. The characterization that she said 10 that she said she was accosted. She looked 11 like, as best as I can recall, if I met her 12 in Mar-a-Lago as she claims, she worked at 13 Mar-a-Lago, she claims, and her statement she 14 worked at Mar-a-Lago, she would have been 15 dressed as all the spa people in Mar-a-Lago 16 would have been. It would have been 17 impossible to identify her as someone other 18 than someone who worked at a spa. She made 19 many claims, she has been a bathroom 20 attendant, front of house attendant, we don't 21 know what she was, so her obvious lies are 22 her contradictory of her own personal 23 statements within that. 24 Q. So what part of her statement 25 relating to Mar-a-Lago -- Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 214 of 465 Page 214 1 G Maxwell - Confidential 2 A. I'm carrying on. 3 Q. I'm sorry. I thought you were 4 done. 5 A. Please. Her statement also that 6 she was driven by her father to Palm Beach. 7 She was driven by her mother, as a matter of 8 fact. Her whole entire characterization of 9 the first meeting with Jeffrey, as I was 10 outside speaking to her mother. 11 Q. Let me stop you there, so we don't 12 get too far ahead. Let me make sure I 13 understand your testimony. 14 The first, in the first piece when 15 you were talking, I believe you said and 16 correct me if I'm wrong, that her 17 characterization of the first meeting at 18 Mar-a-Lago was an obvious lie. 19 What part of that meeting was an 20 obvious lie? 21 A. By her own testimony, all her 22 various many different descriptions of what 23 she was or wasn't or where she was or wasn't, 24 they have all changed. She was either front 25 of house or bathroom attendant. I don't know Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 215 of 465 Page 215 1 G Maxwell - Confidential 2 what she was, so just by her own words, one 3 doesn't know what's true and what isn't true. 4 Q. Are you saying what position she 5 said she was working in, is that what you are 6 considering the obvious lie? 7 A. I said inconsistency within her own 8 statement from everything, so in the 9 beginning it starts off with different 10 statements. 11 Q. Then I believe you said the second 12 piece was that she was driven by her father? 13 A. I said she was driven by her 14 mother. 15 Q. That's the obvious lie? 16 A. It's an obvious lie to me. 17 Q. You said why don't you state it in 18 your own words but the characterization of 19 how she was with Jeffrey, what about that is 20 an obvious lie? 21 A. I was standing outside talking to 22 her mother so the entire story is a 23 fabrication. 24 Q. Did she not have sex with Jeffrey 25 Epstein during that first massage? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 216 of 465 Page 216 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I was talking to her mother so... 5 Q. Do you know whether that's an 6 obvious lie, whether she had sex in that room 7 or not? 8 A. Her story about what happened -- 9 let's also be -- the story as first hit the 10 press was that somebody else led her to 11 Jeffrey's room, it was not me and then it 12 turned to being me so we have an obviously 13 important inconsistency, lie in my -- that's 14 how I would characterize a lie. It cannot be 15 me or somebody else, it can only be one or 16 the other. 17 Q. Who is the other person she said 18 took her to the room? 19 A. Why don't you ask her. 20 Q. I'm asking you. 21 A. How would I possibly know. 22 Q. You are saying that's a lie. 23 A. It was a lie in the papers, she 24 said it in the newspaper, it was in the 25 newspaper. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 217 of 465 Page 217 1 G Maxwell - Confidential 2 Q. How do you know she wasn't 3 identifying you? 4 A. She said somebody. 5 Q. How do you know that somebody 6 wasn't you? 7 A. Why did it suddenly become me, why 8 not say it was me and be done with it. 9 Q. So it's a lie because she 10 originally may not have named you and then 11 named you later? 12 A. It's obviously inconsistent to 13 somebody who wasn't me. 14 Q. How do you know it wasn't you? 15 A. I know it wasn't me because I was 16 talking to her mother. 17 Q. But she then named you, is what you 18 are saying? 19 A. That's an obvious lie. 20 Q. She named you? 21 A. It's an obvious lie because I 22 wasn't even in the house. 23 Q. Is it an obvious -- who did lead 24 her up to Jeffrey's room while you were 25 talking to her mother? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 218 of 465 Page 218 1 G Maxwell - Confidential 2 A. You would have to ask Virginia, I 3 don't know if she was led up to his room. 4 Q. You were standing with the mother, 5 is that correct? 6 A. That's correct. 7 Q. Who was working at the house that 8 day? 9 A. I believe John Alessi was. 10 A. Would John Alessi typically lead 11 someone up to the room where Jeffrey was 12 having a massage? 13 A. I don't know she was led up to the 14 room to have a massage. 15 Q. She would have found her way on her 16 own? 17 A. I would suggest that that entire 18 story never happened at all in any of its 19 form. 20 Q. If you stood outside with the 21 mother, what did you think happened inside 22 then? 23 A. I believe that somebody, it wasn't 24 me, John Alessi probably took her to meet 25 Jeffrey Epstein while he was working at his Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 219 of 465 Page 219 1 G Maxwell - Confidential 2 desk and they had a conversation. 3 Q. Did Jeffrey tell you that? 4 A. No but that would have been a 5 normal interaction. I don't believe for a 6 second -- I know her entire characterization 7 didn't happen because I was outside talking 8 to her mother the entire time. 9 Q. Why would she have come for a 10 massage and not given a massage? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. We are talking about her 14 characterization of the first time that she 15 came to the house. 16 Q. If I'm following you correctly, 17 you're saying she walked in and would have 18 gone to -- it's your assumption she would 19 have gone and talked to Jeffrey and left? 20 A. When I was working for Jeffrey, 21 typically he would meet someone before 22 getting a massage from them to see if he 23 wanted to have a massage from them, 24 typically. 25 Q. So he would not have someone come Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 220 of 465 Page 220 1 G Maxwell - Confidential 2 up to the room and start a massage? 3 A. He would not. 4 Q. So the young girls in the police 5 report who say they came over and were led up 6 to the room on the first day, would they be 7 wrong about that? 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. I can't comment what happened when 11 I was not at the house. I can only comment 12 when I was at the house. 13 Q. Was there ever a time where a woman 14 came to the house for the first time to give 15 a massage and Jeffrey had the massage that 16 day? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. Can we talk about adult 20 professional masseuses, please? 21 Q. I'm asking, whether adult or 22 underage? 23 A. I'm not interested in talking about 24 underage. I can only testify to what I know, 25 professional masseuses, adult, I cannot Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 221 of 465 Page 221 1 G Maxwell - Confidential 2 testify to anything else. 3 Q. Why can't you testify to an 4 underage girl that came over and was led up 5 to the room for a massage? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. The police records you are 9 referring to? 10 Q. You are saying that didn't happen. 11 You're saying I can only testify to adults 12 that came for an interview and were led up to 13 the room. Why can't you testify to whether 14 an underage girl was brought in for an 15 interview and led up -- 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 Q. Go ahead. 19 A. Can you reask the question. 20 Q. Why can't you testify as to an 21 underage girl who came over for an interview 22 and then was then led up to the room for the 23 massage? 24 A. You've mangled your entire 25 question. Can you please reask that in a way Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 222 of 465 Page 222 1 G Maxwell - Confidential 2 that I can answer it correctly? 3 Q. Why can you not testify as to 4 whether an underage girl, you said you can 5 testify as to females that were over the age 6 of 18, why can't you testify as to whether an 7 underage girl came over for an interview and 8 on the same day -- 9 A. I don't know what you mean by 10 interview. 11 Q. You just said that Jeffrey Epstein 12 interviewed, it was your word, interviewed 13 the masseuses before they gave massages, is 14 that correct? 15 A. The word interview is making me -- 16 I'm English, so you could have some 17 difficulty understanding the way I 18 communicate. 19 Q. I'm using your word. 20 A. Then I will reuse it a different 21 word. He would meet them because receiving a 22 massage is something you want to make sure 23 you are comfortable with the person and so 24 interview is not the correct word but you 25 would meet them to have a conversation with Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 223 of 465 Page 223 1 G Maxwell - Confidential 2 them to see if you want to have a massage 3 with that person. 4 Q. Did Jeffrey Epstein ever meet an 5 underaged girl and on the same day receive a 6 massage from that girl? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I can't possibly testify to what 10 happened after I was not at the house. 11 Q. If you are aware, at any time you 12 were at the house, did you ever see that? 13 MS. MENNINGER: Let her finish the 14 question. 15 A. I can only testify to people who 16 were adult professional masseuses who came to 17 the house. I cannot testify to something I'm 18 not party to and don't know about. I can 19 only testify to what I saw. So when 20 professional adult masseuse, male and/or 21 females would come to the house, typically 22 when I was there, typically he would meet 23 with them prior, to have a conversation with 24 them about their experience, whatever, to 25 decide whether it would then A, if he had Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 224 of 465 Page 224 1 G Maxwell - Confidential 2 time for a massage at that time or B, whether 3 he could have a massage at that moment. 4 Q. Was Virginia an adult when she came 5 over, was she over 18? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I think we established, as of 9 today, we are all aware, everyone in this 10 room that she was 17. 11 Q. So you have been present when a 12 minor was brought over for a massage for 13 Jeffrey? 14 A. Can I say, as you are able to have 15 a massage at 17, so she came as a masseuse. 16 Q. I'm not saying whether or not you 17 are able to. I'm saying you've been present 18 at Jeffrey's home when an underage minor has 19 come over to give him a massage? 20 A. That's just not how that works. 21 You are able to be a masseuse at 17 so she 22 came to give -- for a massage, at 17 you are 23 able to come and give a massage. 24 Q. I'm not asking whether she is able 25 to do it. I'm asking whether you were Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 225 of 465 Page 225 1 G Maxwell - Confidential 2 present at the home when a girl under the age 3 of 18 came over for the purposes of giving a 4 massage? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 Q. You can answer. 8 A. You can be a professional masseuse 9 at 17 in Florida, so as far as I am aware, a 10 professional masseuse showed up for a 11 massage. There is nothing inappropriate or 12 incorrect about that and your 13 mischaracterization of it, I think is 14 unfortunate. 15 Q. How many teenagers did he have that 16 were professional masseuses that worked in 17 his home? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 Q. How many? 21 A. First of all, I am not aware of 22 teenagers who worked in his home. 23 Q. You are aware of Virginia Roberts 24 and you've stated she was 17 and she worked 25 for him, correct? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 226 of 465 Page 226 1 G Maxwell - Confidential 2 A. No. I did not state that at all, 3 you are mischaracterizing my words and what I 4 said. 5 What I said was that we can all 6 agree and I think at this point there is not 7 one person in this room, however much you 8 would like her to be younger, to say she was 9 not 17 because that has been a very offensive 10 thing that you have all done. So she was 17. 11 At 17 you are allowed to be a professional 12 masseuse and as far as I'm concerned, she was 13 a professional masseuse. There is nothing 14 inappropriate or incorrect about her coming 15 at that time to give a massage. Her entire 16 characterization of her first time at the 17 house was to me an obvious lie, given it was 18 impossible for her entire story to take place 19 given I was speaking to her mother the entire 20 she was at the house. 21 Q. So it was impossible that day, that 22 first day she came and you were speaking to 23 the mother, for Virginia Roberts to have had 24 sex with Jeffrey Epstein during the time that 25 you were outside with her mother? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 227 of 465 Page 227 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. You, again, are completely 5 mischaracterizing. I can only testify to 6 what I heard obvious lies about me and her 7 obvious lies about me are that she, as you 8 put out to the papers and every other which 9 way, went upstairs with her, didn't happen. 10 So that to me is an absolute, obvious lie. I 11 also don't believe that her -- her 12 mischaracterization of the length of time she 13 was there because as I recall, she just met 14 with Jeffrey and then left with her mother. 15 That's my recollection. 16 Q. So you were standing outside the 17 entire time that Virginia was in the house, 18 is that correct? 19 A. That is correct. 20 Q. So can you testify as to whether or 21 not, do you know either from Jeffrey or any 22 other source whether or not Virginia Roberts 23 had sex with Jeffrey on that first day that 24 she was at the house? 25 A. We can categorically state, Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 228 of 465 Page 228 1 G Maxwell - Confidential 2 absolutely 1000 percent that she did not have 3 any type of sexual relations as described by 4 you in your court papers that took place 5 because those allegedly according to her lies 6 involved some aspect of me. 7 As I was standing outside with her 8 mother the entire time, her entire story is a 9 lie. Therefore, to ask me what she did or 10 didn't do during that time, I can only 11 testify to what she said about me, which was 12 1000 percent false. 13 Q. So let's not take the first time, 14 let's take the next time she comes. 15 A. No no, how can do you that, when 16 the basis of this entire horrible story that 17 you have put out is based on this first 18 appalling story that was written, repeated, 19 multiply by the press that lied about her 20 age, lied about the first time she came, lied 21 about and characterized the entire first 22 time. I have been so absolutely appalled by 23 her story and appalled by the entire 24 characterization of it and I apologize 25 sincerely for my banging at the table Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 229 of 465 Page 229 1 G Maxwell - Confidential 2 earlier, I hope you accept my apology. It's 3 borne out of years of feeling the pressure of 4 this entire lie that she has perpetrated from 5 our first time and whilst I recognize that 6 was -- I hope you forgive me sincerely 7 because it was just the length of time that 8 that terrible story has been told and retold 9 and rehashed when I know it to be 100 percent 10 false. 11 Q. So not the first time she came, but 12 the second time she came or the third time or 13 any time she came, did you ever participate 14 in a massage with her in Jeffrey Epstein's 15 room? 16 A. I have never participated at any 17 time with Virginia in a massage with Jeffrey. 18 Q. Have you ever participated at any 19 time with Virginia in any kind of sexual 20 contact or sexual touching with Jeffrey and 21 Virginia? 22 A. I have not. 23 Q. So we were going through the list 24 of obvious lies and you were talking about 25 the first time which I believe we have Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 230 of 465 Page 230 1 G Maxwell - Confidential 2 completed but you can add to that if you need 3 to. 4 What other obvious lies did 5 Virginia Roberts tell that you were referring 6 to in your statement? 7 A. Oh my goodness. Well, I think we 8 can totally cover the Clinton story, the 9 story that I flew him with Secret Service and 10 there was a dinner with other people and that 11 entire thing is 100 percent fictitious. I 12 have testified for the record and I'm happy 13 to do it again, that I have never flown Bill 14 Clinton, myself as a pilot in a helicopter at 15 any time, anyplace, at any time, to any part 16 of the world. 17 Q. What other obvious lies were you 18 referring to? 19 A. She was referring to Al Gore, she 20 is referring to a bunch of people. I don't 21 believe Al Gore ever came to the island at 22 any time ever. I don't even know Al Gore 23 actually. 24 Q. Just one moment, I want to hear all 25 of them, but when you say you don't believe Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 231 of 465 Page 231 1 G Maxwell - Confidential 2 Al Gore ever came to the island, do you know 3 whether Al Gore ever came to the island? 4 A. Al Gore never came to the island. 5 Q. How do you know that? 6 A. Jeffrey doesn't know him, I don't 7 know him and I think had Al Gore -- I don't 8 think -- had Al Gore gone to the island 9 during the period when I would have been 10 involved in organizing a trip, I would have 11 been aware of it. 12 Q. So go ahead, you had another one. 13 A. It would be easier if I could see, 14 do you mind if a take a reference at some of 15 these newspaper articles or you just want me 16 to go from memory. 17 Her entire characterization of what 18 took place in London at my house with Prince 19 Andrew. 20 Q. Was it an obvious lie that she was 21 at your house in London? 22 A. We can't really establish the 23 photograph and all that. I don't know if 24 that's true, if that's a real picture or not. 25 Q. So you dispute that you were Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 232 of 465 Page 232 1 G Maxwell - Confidential 2 actually photographed in your town home in 3 London -- 4 A. I don't recognize that picture. 5 I'm not sure if that's a real picture or not. 6 Q. And have you talked to Prince 7 Andrew about that picture? 8 A. We discussed Virginia's entire tail 9 and he asked me if he even knew her. 10 Q. So did Prince Andrew tell you that 11 he did not have sex with Virginia Roberts? 12 A. He doesn't even know who Virginia 13 Roberts is. 14 Q. Did he tell you that he didn't have 15 sex with her? 16 A. It would be difficult to have sex 17 with someone you don't know. 18 Q. He may not remember her? 19 A. I think the inference is he didn't 20 know who she was, he didn't have any 21 recollection of her whatsoever. 22 Q. Has Prince Andrew ever come to your 23 London town home? 24 A. Yes. Ever being the entire time I 25 owned my house, yes. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 233 of 465 Page 233 1 G Maxwell - Confidential 2 Can I go on on her obvious lies? 3 Q. If you have more. 4 A. I have -- her entire 5 characterization -- I took her shopping into 6 Burberry and bought her a very expensive 7 dress and if this photo were real and if this 8 is -- I would never -- the outfit doesn't 9 work at all so -- 10 Q. Do you not remember taking her 11 shopping or are you saying it's an obvious 12 lie, you know you did not take her shopping? 13 A. I did not take her shopping. I did 14 not by her a $5,000 handbag. 15 Q. Did Jeffrey by her a $5,000 16 handbag? 17 A. Her accusation was that I did. 18 Q. Do you know if Jeffrey bought her a 19 handbag during that trip to London? 20 A. I don't know what he did. She 21 accused me, I can't physically remember 22 buying a $5,000 not for her, not for anyone, 23 not for me. 24 Q. Did you ever go shopping with 25 Virginia? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 234 of 465 Page 234 1 G Maxwell - Confidential 2 A. I don't recall ever shopping with 3 Virginia. 4 Q. Did you have more to go over or did 5 you want me to ask my questions? 6 A. The entire characterization of what 7 took place in my house in London would have 8 been impossible. 9 Q. Can I ask, do you still have it, 10 the picture of the London town home with you 11 in it, Giuffre 00407. 12 As you are looking at this picture, 13 Ms. Maxwell, as I'm looking at it it's on the 14 right-hand side, there appears to be a 15 picture hanging on the wall, do you recall 16 that in your London town home? 17 A. It's a little difficult to see. 18 Q. Do you recall having a picture on 19 the wall there by the room where you're 20 standing? 21 A. I do have a picture. 22 Q. Do you recall on the left-hand side 23 having a railing that looks like that with 24 sort of a bubble wood top? 25 A. I do. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 235 of 465 Page 235 1 G Maxwell - Confidential 2 Q. So are you saying that it's an 3 obvious lie that Virginia's statement that 4 she had sex with Prince Andrew is an obvious 5 lie? 6 A. What I'm representing is that her 7 entire ludicrous and absurd story of what 8 took place in my house is an obvious lie. 9 Q. Including she had sex with Prince 10 Andrew? 11 A. She claimed things took place in my 12 bathroom in London. Her characterizations is 13 just not possible. 14 Q. So you're saying it's an obvious 15 lie -- that she was telling an obvious lie 16 when she said she had sex with Prince Andrew? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. The witness 19 answered the question. 20 A. I'm saying within the context of 21 all the stories she told, this particular 22 story -- back up, she claimed we went out at 23 night. I've already testified if -- Prince 24 Andrew is such a famous person, if he went to 25 a nightclub, it would have been reported by Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 236 of 465 Page 236 1 G Maxwell - Confidential 2 the press at that time. She characterized 3 that Prince Andrew drank alcohol. Prince 4 Andrew tea total. 5 She then characterized things took 6 place in my bathroom in the bathtub itself. 7 The tub is too small for any type of activity 8 whatsoever. 9 Q. Is Club Tramp the name of a London 10 club, is that a club you heard of? 11 A. It's not called Club Tramp, it's 12 called Tramp. 13 Q. That would be a club located in 14 London? 15 A. Yes. 16 Q. Are you saying that it was an 17 obvious lie when Virginia said that you made 18 her dress up in a school girl outfit? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I already testified that, first of 22 all, I don't know what you are taking about, 23 I already testified I didn't get her outfits 24 and all of that. 25 Q. Is it an obvious lie that Virginia Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 237 of 465 Page 237 1 G Maxwell - Confidential 2 was paid to go to give a massage to Glenn 3 Dubin at the Breakers? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I cannot testify to what Virginia 7 did outside of -- I can't testify to what she 8 did, who she gave massages to. 9 Q. So you don't know on that one? 10 A. Of course I don't know. 11 Q. Do you agree that it's 12 psychologically harmful to have sex with a 13 minor? 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. What are you asking me? 17 Q. I'm asking if is it psychologically 18 harmful for an adult to have sex with a 19 minor? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I don't know what you are asking. 23 This has nothing to do with Virginia Roberts. 24 Q. It does. 25 A. How does it? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 238 of 465 Page 238 1 G Maxwell - Confidential 2 Q. I ask the questions, you answer. 3 If you can't answer, you can say I don't 4 know. 5 But my question is, do you agree 6 that it's psychologically harmful to have sex 7 with a minor? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. Are you giving me a random question 11 and as not relates to this case and not 12 relates to anything. It's obviously not 13 something that you want to have happen. 14 Q. Do you agree that Jeffrey Epstein 15 has harmed many minors by having sex with 16 them? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I can't testify to what Jeffrey did 20 or didn't do. I have no knowledge of what 21 you are asking me. 22 Q. If Jeffrey had sex with minors, 23 would you agree that that could harm a minor? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 239 of 465 Page 239 1 G Maxwell - Confidential 2 A. Again, I am not testifying to what 3 Jeffrey did or did not do because I cannot. 4 Q. You don't know whether Jeffrey 5 Epstein ever had sex with a minor? 6 A. Again, I cannot testify to what 7 Jeffrey did or didn't do. I cannot. 8 Q. You never observed him having sex 9 with a minor? 10 A. I never observed Jeffrey having sex 11 with a minor. 12 Q. Do you agree that calling a sex 13 abuse victim a liar when she speaks about her 14 abuse can cause psychological harm? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. Can you repeat the question. 18 Q. Do you agree calling a sex abuse 19 victim when she speaks about her abuse can 20 cause psychological harm? 21 MR. PAGLIUCA: Objection to form 22 and foundation. 23 A. Say it again. 24 Q. Do you agree that calling a sexual 25 abuse victim a liar can cause psychological Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 240 of 465 Page 240 1 G Maxwell - Confidential 2 harm. 3 MR. PAGLIUCA: Object to the form 4 form and foundation. 5 A. I would like to say all the 6 terrible things Virginia Roberts said about 7 me is extremely harmful and you should turn 8 that around. All the lies she has said and 9 you have backed her on have been extremely 10 damaging to me. 11 So what I can testify to is that 12 somebody who has made these outrageous 13 allegations and who is a serious liar and 14 that I know for a fact is a liar, that I can 15 testify is damaging to me. 16 Q. Do you agree that calling a sexual 17 abuse victim a liar when she speaks out about 18 her abuse can cause psychological harm? 19 MR. PAGLIUCA: Are you asking a 20 hypothetical question? 21 MS. McCAWLEY: Yes. 22 A. You are asking me to speculate? 23 Q. I'm not asking you to speculate . 24 If somebody is a sexual abuse victim -- 25 A. I can't testify to what some random Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 241 of 465 Page 241 1 G Maxwell - Confidential 2 hypothetical person that you are asking me to 3 speculate on their mental state or health 4 versus speculative statement. I can't do 5 that, that's just not right. 6 Q. Do you agree that by calling 7 Virginia Roberts a liar when she was subject 8 to sexual abuse by Jeffrey Epstein can cause 9 psychological harm? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. Assumes facts not 12 in evidence. 13 A. I can only tell you about what I 14 know of Virginia's lies. She lied 15 repeatedly, often and I know for a fact she 16 is a liar so I can only testify to what I 17 know and the fact that she has lied about me 18 from the beginning to the end and repeatedly 19 causes me to question anything that she may 20 feel. 21 Q. Is it an obvious lie you had sex 22 toys in Jeffrey Epstein's Palm Beach house? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Can you repeat the question, Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 242 of 465 Page 242 1 G Maxwell - Confidential 2 please? 3 Q. Is it an obvious lie that you had 4 sex toys in Jeffrey Epstein's Palm Beach 5 house? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. Did Virginia say that? 9 Q. I'm asking you a question. 10 Is it an obvious lie that you had 11 sex toys in Jeffrey Epstein's house? 12 A. I don't recall any sex toys. 13 Q. If someone said had you sex toys, 14 would that be an obvious lie? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. Like I said -- can you be more 18 specific about the house or whatever, what 19 exactly you are referring to, what's a sex 20 toy? 21 Q. Yes. How would you define a sex 22 toy? 23 A. No. I need you to define a sex 24 toy, I don't have enough knowledge of sex 25 toys. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 243 of 465 Page 243 1 G Maxwell - Confidential 2 Q. I will define it based on the 3 dictionary's definition, which is an object 4 or device used to sexually stimulate or 5 enhance sexual pleasure. 6 A. What's your question, please? 7 Q. The question is, is it an obvious 8 lie that you had sex toys in Jeffrey 9 Epstein's Palm Beach house? 10 MR. PAGLIUCA: Same objection. 11 Q. You can answer. 12 A. Like I said, I do not have any 13 recollection of sex toys in Jeffrey's house. 14 Q. Is it a lie, is it an obvious lie 15 that you took pictures of nude girls? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. We already covered this. Girls we 19 are not referring to -- I can only testify to 20 taking pictures of adult people and I already 21 testified they are not nude, per se. That 22 every picture that I ever took and which they 23 were very limited, always by request, the 24 people would be covered or it would be a hand 25 or a foot. There was never any pictures that Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 244 of 465 Page 244 1 G Maxwell - Confidential 2 I took of people would only have been 3 mainstream type magazine type photos and any 4 photos I took could have been very happily 5 and expected to be displayed on your parents' 6 mantel piece or grandparents' mantel piece. 7 Q. Is it a lie that you approached 8 females to bring them to Jeffrey Epstein? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. Please ask the question, again. 12 Q. Sure. Is it a lie that you 13 approached females to bring them to Jeffrey 14 Epstein? 15 A. I don't know what you are asking 16 me. 17 Q. I'm asking you, if it's a lie that 18 you approached females to bring them to 19 Jeffrey Epstein? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. You are not asking me a good 23 question, sorry. 24 Q. You don't get to choose the 25 questions. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 245 of 465 Page 245 1 G Maxwell - Confidential 2 A. I would like to answer your 3 questions but you are not asking me a 4 question that I can answer. 5 Q. What about that is causing you 6 pause where you can't answer the question? 7 A. You are trying to trap me and 8 that's not fair, so I already testified that 9 I hire people across the board, so I would 10 hire architects, decorators, pool people, 11 exercise instructors, gardeners, cooks, 12 chefs, cleaning people. So I, in the course 13 of a very long time when I would hire people 14 I hired people to work for Jeffrey. So I'm 15 happy to testify to hiring people for every 16 possible conceivable proper job that you 17 could conceive of within the context of 18 Jeffrey's life and homes. 19 Q. Is it a lie that you approached 20 females to bring them to Jeffrey Epstein for 21 the purpose of performing massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Again, I have already testified 25 that part of the job that I had was to hire Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 246 of 465 Page 246 1 G Maxwell - Confidential 2 lots of different types of people. In terms 3 of whatever -- very small part of my job, 4 Jeffrey enjoyed getting massages. I think 5 that is something we can all agree in this 6 room and within the context of that, very 7 infrequently I would go to spas and myself 8 happily receive a professional nonsexual 9 massage from a man and/or from a woman and if 10 that massage was something that I thought was 11 something that was good, I would ask if that 12 man or woman would come back and does home 13 visits. If that person said that they did, 14 they would sometimes come, from time to time, 15 not always, come back to the house to perform 16 a nonsexual professional male or female 17 massage. 18 Q. Were any of the exercise 19 instructors you hired under the age of 18? 20 A. Again, I don't hire, we've already 21 established that I don't hire people. I 22 interview people to see if they are competent 23 in the job that they do and/or whether they 24 are someone who seemed that they can do home 25 visits. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 247 of 465 Page 247 1 G Maxwell - Confidential 2 At the point where I think that 3 there is somebody that has, can be either 4 whatever the job may be, pool, gardener, chef 5 and/or exercise instructor and I think they 6 could be good at whatever it is at whatever 7 skill that they had and they did a home visit 8 which would obviously be mandatory and Mr. 9 Epstein would meet with them and decide if he 10 wanted to have whatever skill it was that he 11 would do it and then he would then either 12 have them come back or hire them. 13 Q. Were there any exercise instructors 14 that worked at the home that were under the 15 age of 18? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Again, I keep coming back to this, 19 that the people that I employed or -- not the 20 right word, the people I would meet to come 21 and work at the house, under any guise 22 whatsoever, again, from any of the many 23 positions that I filled, were all over -- 24 were adults. 25 Q. When you say adults, over the age Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 248 of 465 Page 248 1 G Maxwell - Confidential 2 of 18? 3 A. I think we can establish what adult 4 would be. 5 Q. You never interviewed or I know you 6 don't want to use the word hired, whatever 7 your role was, you brought in an exercise 8 instructor that was under the age of 18 to 9 work at the house? 10 MR. PAGLIUCA: Object to the form 11 and foundation. 12 A. I have already testified that what 13 I was responsible for was to find people who 14 had competencies in whatever area I was 15 looking for. The competencies I was looking 16 for were professional and adult. 17 Q. So there was no exercise instructor 18 that worked at the Palm Beach house or the 19 New York house or the New Mexico house or the 20 USVI under the age of 18? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I can only testify to when I was at 24 the house. 25 Q. Yes. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 249 of 465 Page 249 1 G Maxwell - Confidential 2 A. I can only testify to the years 3 when I was present. 4 Q. Right. 5 A. And I can also only testify to 6 people I personally either met and/or worked 7 with and/or invited, to find the correct 8 word, I don't know what the correct word is, 9 to come to do exercise or whatever it was at 10 the house. 11 Of the people that I, male and/or 12 female that I brought were all appropriate 13 and age appropriate adults. 14 Q. Over the age of 18? 15 A. We've established them as an adult. 16 Q. You are saying appropriate adults, 17 so we are clear, you didn't hire or bring in 18 or know of any exercise instructors that were 19 under the age of 18 at any of those homes? 20 A. I am also testifying that when I 21 was present at the house and with the people 22 that I brought in, were all age appropriate 23 adults. 24 Q. How do you define age appropriate 25 adults, is that over the age of 18, can we Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 250 of 465 Page 250 1 G Maxwell - Confidential 2 agree to that? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 Q. Are they under the age of 18? 6 A. We already established that you can 7 be a masseuse in Florida at age 17. That 8 does not make it inappropriate. 9 A. I'm not saying appropriate or 10 inappropriate. I'm just asking if there were 11 any exercise instructors that were under the 12 age of 18. 13 A. I am not aware if anybody was but I 14 don't want to full out and say you oh she 15 said, we already established you can be a 17 16 year old masseuse and have it not be 17 something that is not appropriate. So when 18 you say that and then you go, well, you come 19 back and say something, now we can establish 20 that Virginia was 17 but you can be a 17 year 21 old legal masseuse, but I am not aware to 22 your point. 23 Q. Who were the other 17 year old 24 masseuses that you were aware of? 25 A. I am not aware of any. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 251 of 465 Page 251 1 G Maxwell - Confidential 2 Q. Were there any 16 year year old 3 masseuse that you are aware of? 4 A. I am not aware. 5 Q. Any 15? 6 A. I just want to be clear. The only 7 person that I am aware of who claims to have 8 been a -- we have to -- we established 9 Virginia now is 17, given she has changed her 10 age so many times. The only person that I am 11 aware of that was a masseuse at the time when 12 I was present in the house was Virginia. 13 Q. Is it an obvious lie that Jeffrey 14 Epstein had a sexual preference for underage 15 miners? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Can you ask the question again? 19 Q. It is it an obvious lie that 20 Jeffrey Epstein had a sexual preference for 21 underage minors? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Can you ask the question again? 25 Q. Is it an obvious lie that Jeffrey Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 252 of 465 Page 252 1 G Maxwell - Confidential 2 Epstein had a sexual preference for underage 3 minors? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 A. I cannot testify to what 7 Jeffrey's -- 8 Q. You don't know his preference? 9 A. You handed me a stack of papers 10 from the police reports and that's what I've 11 read but I have no knowledge, direct 12 knowledge, of what you are referencing. 13 Q. So you don't know, you don't know 14 in your own mind that Jeffrey Epstein had a 15 sexual preference for underage minors, is 16 that correct? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 Q. Is that correct? 20 A. Please ask the question again. 21 Q. You don't know in your own mind 22 that Jeffrey Epstein had a sexual preference 23 for underage minors? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. You have to pause, Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 253 of 465 Page 253 1 G Maxwell - Confidential 2 let me object, answer the question. 3 Listen to her question, pause, I object, 4 you answer. 5 Q. So you don't know in your own mind 6 that Jeffrey Epstein had a sexual preference 7 for underage minors? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 Q. You can answer. 11 A. I cannot tell you what Jeffrey's 12 story is. I'm not able to. 13 Q. Did Jeffrey Epstein have a scheme 14 to recruit underage girls to use them for 15 purposes of sexual massages? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Can you ask me again, please? 19 Q. Did Jeffrey Epstein have a scheme 20 to recruit underage girls to recruit them for 21 sexual massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Can you ask it a different way? 25 Q. Did Jeffrey Epstein have a scheme Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 254 of 465 Page 254 1 G Maxwell - Confidential 2 to recruit underage girls for sexual 3 massages? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 Q. If you know. 7 A. I don't know what you are talking 8 about. 9 Q. Is it an obvious lie that Virginia 10 Giuffre was a minor the first time she was 11 taken to Jeffrey Epstein's house? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. So we've already established that 15 Virginia was 17 and we have established that 16 her mother brought her to the house and that 17 she came as a masseuse, age 17, which is 18 legal in Florida. 19 Q. Would Jeffrey Epstein's assistants 20 arrange times for underage girls to come to 21 the house for sexual massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. What are you talking about? 25 Q. Sure. Would Jeffrey Epstein's Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 255 of 465 Page 255 1 G Maxwell - Confidential 2 assistants, I think earlier you mentioned, we 3 talked about Sarah Kellen who worked in the 4 role as an assistant or Nadia Marcinkova. 5 Would Jeffrey Epstein's assistants arrange 6 times for underage girls to come over the 7 house for sexual massages? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. Again, I read the police reports so 11 this is all happening according to the police 12 reports when I am no longer at the house so I 13 can't testify to what Jeffrey's assistants 14 did when this kind of activity as alleged in 15 the reports. 16 Q. So you don't know? 17 A. No. 18 Q. Would Jeffrey Epstein's assistants, 19 meaning Sarah Kellen, Nadia Marcinkova or any 20 other assistant that you are aware of from 21 the time you worked there take nude 22 photographs of underage girls? 23 MR. PAGLIUCA: Object to the form 24 and foundation. 25 A. During what period of time? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 256 of 465 Page 256 1 G Maxwell - Confidential 2 Q. During any period of time you 3 worked, did you observe that? 4 A. I did not observe any such 5 photographs. 6 Q. Are you aware if they took those 7 kinds of photos? 8 A. I am not aware. 9 MR. PAGLIUCA: Can we take a 10 five-minute break. 11 THE VIDEOGRAPHER: It's 2:58 and we 12 are off the record. 13 (Recess.) 14 THE VIDEOGRAPHER: It's now 3:10. 15 We're starting disk No. 6 and we are 16 back on the record. 17 Q. Ms. Maxwell, was it an obvious lie 18 when Virginia said she was sent to Thailand 19 by Epstein in September of 2002? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I have no knowledge of Virginia 23 being sent to Thailand. 24 But may I say something? 25 Q. There is not a question pending Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 257 of 465 Page 257 1 G Maxwell - Confidential 2 unless you want to clarify something. 3 Did you want to clarify that? 4 A. No, I just wanted to say something. 5 Q. Is it an obvious lie when Virginia 6 said she was given instructions to maintain 7 telephone contact with you while she was in 8 Thailand? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. Can you repeat the question? 12 Q. Is it an obvious lie when Virginia 13 said she was given instructions to maintain 14 telephone contact with you when she was in 15 Thailand? 16 MR. PAGLIUCA: Same objection. 17 A. I have no idea what instructions 18 Virginia was given, if any, when she went to 19 Thailand. 20 Q. So you know she went to Thailand? 21 A. I know she claimed she went to 22 Thailand from having read it but given that 23 she lied about everything it's hard to know 24 what is true and not true. 25 Q. Would it make any sense for her to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 258 of 465 Page 258 1 G Maxwell - Confidential 2 be in contact with you, would there be any 3 reason why she needed to be in contact with 4 you? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. When are we talking about? 8 Q. When she went to Thailand. 9 MR. PAGLIUCA: Same objection. 10 Q. In 2002, would there be any reason 11 for her to remain in contact with you? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. Can you ask the question again, 15 please? 16 Q. Would there be any reason for 17 Virginia to maintain contact with you in 2002 18 when she went to Thailand? 19 MR. PAGLIUCA: Same objection. 20 A. First of all, I didn't know that 21 she went to Thailand. I had had nothing to 22 do with her trip to go to Thailand and there 23 would absolutely no reason for her to be in 24 touch with me, whatsoever. 25 Q. Did you ever have a phone number Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 259 of 465 Page 259 1 G Maxwell - Confidential 2 that was 3 A. I did. 4 Q. Was that a cell phone number? 5 A. Yes. 6 Q. Is that your current cell phone 7 number? 8 A. Yes. 9 Q. I'm going to mark a couple of 10 things here? 11 (Maxwell Exhibit 11, photos, marked 12 for identification.) 13 THE WITNESS: Can I say something 14 now? 15 MR. PAGLIUCA: No. 16 THE WITNESS: Will you let me know 17 when I can? 18 MR. PAGLIUCA: When she asks you a 19 question: 20 Q. So we've marked this as Exhibit 11. 21 I'm showing you what's been marked as Exhibit 22 11 which is Giuffre 003191 and 003192. 23 Can you take a look at that 24 document for me. Is that number that you 25 just identified the as being Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 260 of 465 Page 260 1 G Maxwell - Confidential 2 your cell phone number, is that number on 3 this document? 4 A. It is. 5 Q. And do you know who authored this 6 document? 7 A. I do not. 8 Q. Who is JoJo? 9 A. I don't know who JoJo is on this 10 document because I don't know what this 11 document is. 12 Q. Do you know someone by the name of 13 JoJo? 14 A. I do know someone by the name of 15 JoJo. 16 Q. Would he know your phone number? 17 MR. PAGLIUCA: Object to the form. 18 A. I have to idea. 19 Q. Why would Virginia be instructed to 20 call Ms. Maxwell at your number on this form? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I don't know what this document is. 24 I don't know when it was done, I don't know 25 anything about it other than I can see it has Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 261 of 465 Page 261 1 G Maxwell - Confidential 2 my name and my number on it. 3 Q. So JoJo -- you said JoJo -- is he 4 employed by Mr. Epstein? 5 A. Again, it is not the only one JoJo 6 on the planet. 7 Q. I understand. 8 Do you know a JoJo that is employed 9 by Mr. Epstein? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. Can you ask me the question again? 13 Q. Do you know someone by the name of 14 JoJo that was employed by Mr. Epstein back in 15 2002? 16 A. I do know somebody who was employed 17 by Mr. Epstein known as JoJo. 18 Q. Do you recognize the other numbers 19 listed at the top of this document? 20 A. I do not. 21 Q. Would you have known JoJo's cell 22 number at that time in 2002? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I have no idea. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 262 of 465 Page 262 1 G Maxwell - Confidential 2 Q. Can I ask you to turn to the next 3 page, please. 4 Do you know who Nantimda Tharanese 5 is who is mentioned on this document? 6 A. I do not. 7 Q. If you look on the bottom lines of 8 the document, it says, Still in Thailand 9 during your stay, if she is, she will be 10 staying at the same hotel. 11 Do you recall ever giving Virginia 12 instructions to meet a girl in Thailand? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I have already testified that I 16 didn't even know that Virginia was going to 17 Thailand. 18 Q. So you didn't give her instructions 19 to meet a girl in Thailand? 20 A. Like I said, I didn't even know she 21 was going to Thailand. 22 Q. Do you know whether Jeffrey Epstein 23 would have given her instructions to meet a 24 girl in Thailand? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 263 of 465 Page 263 1 G Maxwell - Confidential 2 form and foundation. 3 A. I cannot possibly tell you what 4 Jeffrey did or didn't do. I wouldn't know. 5 Q. Do you know whether Jeffrey Epstein 6 paid for Virginia to go to Thailand? 7 A. Again, I wouldn't know if he did. 8 (Maxwell Exhibit 12, documents, 9 marked for identification) 10 Q. I'm going to direct -- you can take 11 a look at it and then I'm going to direct 12 your attention to a couple of pages. 13 MR. PAGLIUCA: So the record should 14 be clear, this exhibit which is 12 is 15 375, 6, 7, 8, 9, 80, 1, and then skips 16 to 919, 920, 921, 922, 923, 924, 925 and 17 926. 18 Q. So I'm going to direct your 19 attention to the first page, have you ever 20 traveled with Jeffrey Epstein where you've 21 received a document like this from Shoppers 22 Travel in your own independent travel. 23 Do you recognize this? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 264 of 465 Page 264 1 G Maxwell - Confidential 2 Q. The front form, the front page, do 3 you recognize this Shopper Travel form, have 4 you ever used them as a travel agent with 5 Jeffrey Epstein? 6 MR. PAGLIUCA: Same objection. 7 Q. You can answer. 8 A. I don't recognize this. 9 Q. Turning to the second page which is 10 the 00376, do you see at the top of that 11 document where it says Jeffrey Epstein, J. 12 Epstein 457 Madison Avenue 4th floor New York 13 New York. 14 Is that an address you are familiar 15 with that is Jeffrey Epstein's? 16 A. I am. 17 Q. Do you see below that, travel on 18 Singapore Airlines, and you are going to have 19 to go from New York JFK to Singapore Bangkok. 20 Do you see that? 21 MR. PAGLIUCA: What? 22 Q. The first entry is going to be on 23 September 27, New York. 24 MR. PAGLIUCA: I see it. 25 MS. McCAWLEY: I'm not talking to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 265 of 465 Page 265 1 G Maxwell - Confidential 2 you. I'm talking to the witness. 3 A. I see it. 4 Q. To Singapore Bangkok? 5 A. Singapore Bangkok I'm afraid are 6 not the same place. 7 Q. Singapore, then Bangkok: 8 Q. I'm going to turn you to page 9 Giuffre, it's a little further back 000919. 10 And do you see at the top where it says J. 11 Epstein, underneath, Royal Princess, change 12 mine? 13 A. I do. 14 Q. Does this refresh your recollection 15 that Virginia Roberts' trip to Thailand was 16 paid for by Jeffrey Epstein? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I can only testify to the piece of 20 paper you showed me that has that 21 information. I cannot testify from direct 22 memory. 23 Q. When Virginia was traveling to 24 Thailand, which the dates, again, I'm going 25 to refer you back to the first page so you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 266 of 465 Page 266 1 G Maxwell - Confidential 2 can see the dates. 3 MR. PAGLIUCA: Can you identify a 4 Bates number, please. 5 Q. which was at the top says, 6 I'm going to refer you, 7 at the same time, to the flight logs which 8 were marked, the thicker document that looks 9 like this with all the log entries on it. 10 I'm going to refer you to page -- 11 MR. PAGLIUCA: That's Exhibit No. 12 6, correct? I'm trying to keep the 13 record straight. 14 MS. McCAWLEY: I don't have Exhibit 15 numbers on mine. That's Giuffre 16 MR. PAGLIUCA: Hang on one second. 17 A. Can you repeat the number please. 18 Q. And if you will look on 19 that page at the entry, under 20 starting with the and then it runs 21 down to the, looks like the that first 22 entry has President Clinton, Kevin Spacey, 23 Chris Tucker, Jeffrey Epstein and the 24 initials GM. 25 Do you remember taking a trip with Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 267 of 465 Page 267 1 G Maxwell - Confidential 2 President Clinton during 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. Can you repeat the question, 6 please? 7 Q. Do you remember taking a trip with 8 President Clinton during 9 that's the it looks like, through the 10 11 A. I don't remember the dates. I 12 couldn't testify to when we actually did it 13 but I do remember the trip itself. 14 Q. So you were traveling with Jeffrey 15 Epstein and President Clinton at the same 16 time Virginia was headed to Thailand, is that 17 correct? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I don't know, is that right? 21 Q. If you look at on the 22 document that I gave you, the first document 23 and then you referred to, if you look in the 24 same as above lines, you will see the travel 25 group with President Clinton? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 268 of 465 Page 268 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Are you asking her 3 to compare the documents or are you 4 asking her what her personal knowledge 5 is. 6 MS. McCAWLEY: I'm asking if she can 7 look at the doubts and tell me if she 8 recalls that she traveling with 9 President Clinton at the same time this 10 document reflects Virginia was in 11 Thailand. 12 A. I can't testify to any dates. I 13 couldn't tell you. I can see a date and I 14 can see a date but I can't tell you that I 15 have a memory of the dates. I have a memory 16 of the trip, I don't have a memory of the 17 time. 18 Q. Who is ? 19 A. . 20 Q. What is her address? 21 A. I don't know. 22 Q. Does she live in the United States? 23 A. She does. 24 Q. In what state? 25 A. I believe in New Jersey somewhere. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 269 of 465 Page 269 1 G Maxwell - Confidential 2 Q. Do you have her phone number? 3 A. Not memorized. 4 Q. Do you have the ability to get her 5 phone number? 6 A. Of course. 7 Q. Has she ever asked -- has 8 ever asked other girls to come over to 9 see Jeffrey Epstein for the purpose of a 10 sexual massage? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. Can you ask the question again 14 please. 15 Q. Has ever asked girls to 16 come over to see Jeffrey Epstein for the 17 purpose of a sexual massage? 18 MR. PAGLIUCA: Object to form and 19 foundation. 20 A. Can you ask again, please? 21 Q. Has ever asked girls to 22 come over to see Jeffrey Epstein for the 23 purpose of sexual massage? 24 A. I have no personal knowledge. 25 Q. What does do for you? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 270 of 465 Page 270 1 G Maxwell - Confidential 2 A. She helps with my not-for-profit 3 ocean foundation and any other related 4 activities that I may have. 5 Q. Is she paid for by Jeffrey Epstein? 6 A. No. 7 Q. She is paid for by you? 8 A. Yes. 9 Q. When did you first meet 10 11 A. I don't recollect exactly, sometime 12 maybe 2002, 2003. 13 Q. How did you meet her? 14 A. I don't recollect exactly how we 15 met. 16 Q. Did Jeffrey introduce you to her? 17 A. I don't recollect how we met. 18 Q. Does she know Jeffrey Epstein? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. Can you ask again, please? 22 Q. Does know Jeffrey 23 Epstein? 24 A. What do you mean by know? 25 Q. Has she met her him before? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 271 of 465 Page 271 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I can't recollect a time when 5 -- I've seen with Jeffrey but -- 6 Q. You are not sure -- 7 A. I know they know either other. I 8 can't testify to a meeting between them. 9 Q. Do you know where in New Jersey she 10 lives? 11 A. No 12 Q. You don't know a city? 13 A. No. 14 Q. How long has she worked for you? 15 A. Sometime 2002, 2003. 16 Q. To the present? 17 A. Yeah. 18 Q. Why do you think that 19 might know Jeffrey? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Because you know, I know Jeffrey. 23 Q. Have you seen them together? 24 A. I already testified I have not seen 25 them together, to my recollection. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 272 of 465 Page 272 1 G Maxwell - Confidential 2 Q. Is it your testimony that 3 knows Jeffrey Epstein through the work 4 that she does for you? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I don't recollect, and I don't 8 recollect how I met and I can't testify 9 to what relationship is or is not with 10 Jeffrey. 11 Q. Have you ever talked to Jeffrey 12 about 13 A. I don't know what you mean. 14 Q. In any way, have you ever had a 15 conversation with Jeffrey about ? 16 A. In what context. 17 Q. In any context. Have you ever 18 talked to Jeffrey Epstein about ? 19 A. works for me so it's entirely 20 possible that in the course of conversations 21 since 2002, 2003 that a conversation in which 22 name would have come up is entirely 23 possible. 24 Q. I provided you with and I'm sorry, 25 I don't know all the numbers, but the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 273 of 465 Page 273 1 G Maxwell - Confidential 2 statement that was issued by Ross Gow that 3 should be a single page still in your stack 4 of exhibits there. 5 MR. PAGLIUCA: Exhibit 10. 6 Q. Did you authorize Ross Gow to issue 7 that statement on your behalf in January of 8 2015? 9 A. I already testified that that was 10 done by my lawyers. 11 Q. So did you authorize your lawyers 12 to issue a statement on your behalf through 13 Ross Gow in January of 2015? 14 A. It was determined that I had to 15 make a statement in the United Kingdom 16 because of the appalling lies and I just 17 thought of some new ones. 18 Virginia's statement that I 19 celebrated her 16 birthday with her. We can 20 all agree that that's entirely impossible. I 21 didn't meet her until she was 17 and other 22 lies she perpetrated that she had a diary and 23 we all know is a complete fake. That's not a 24 diary. It was just a book she was writing 25 that you helped sell to the press, as if it Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 274 of 465 Page 274 1 G Maxwell - Confidential 2 was a diary, when it was just a story that 3 she is writing of fiction, fictional story 4 for money. 5 Q. How did you arrive at the words 6 that were put in that statement? 7 MR. PAGLIUCA: I'm going to object 8 and instruct you to the extent this 9 calls for any privileged communications 10 between yourself and Mr. Barden or 11 another lawyer representing you, we're 12 asserting privilege. If you can answer 13 that without that, feel free to answer. 14 Q. So what your counsel is saying, and 15 I will exclude any privileged communications 16 you had with your lawyers. 17 The question is, how did you arrive 18 at the words that were put in that statement, 19 if you can tell me without disclosing 20 privileged communications? 21 A. I'm not sure that I can. 22 Q. Is the statement that you issued 23 true? 24 A. What do you mean by that? 25 Q. Is the statement that you issued, Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 275 of 465 Page 275 1 G Maxwell - Confidential 2 the statement that's in front of you, is it a 3 true statement? 4 A. As in that Virginia is a liar? 5 Q. The words you put in there, is that 6 true? 7 A. Of course they're true. 8 Q. When did you become aware that the 9 statement was being released? 10 A. I don't recollect exactly. 11 Q. What day it was? 12 A. No. 13 Q. I'm sorry. Did you identify, I 14 might not have caught it, did you identify 15 the name of the lawyer that you said you 16 retained for purposes of this statement? 17 A. I think Philip Barden. 18 Q. Did you pay that lawyer Philip 19 Barden? 20 A. Yes. 21 Q. Are you aware of any interstate or 22 international transportation of a woman aged 23 18 to 28 for the purposes of prostitution? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 276 of 465 Page 276 1 G Maxwell - Confidential 2 A. I'm not sure I even understand your 3 question. 4 Q. I will go slower. 5 Are you aware of any interstate, 6 meaning between states, or international, 7 meaning oversees transportation, of women 8 aged 18 to 28, for the purposes of 9 prostitution? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. Are you asking -- I'm still not 13 sure I understand the question. 14 Q. I will try to make it clearer. 15 I'm asking you if you are aware of 16 any interstate, meaning between states, or 17 international transportation, meaning by 18 flight or by car or by train, of women aged 19 18 to 28, their ages are between the ages of 20 18 and 28, for the purposes of prostitution? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. In the world I'm sure that that 24 happens, I read about it all the time. 25 Q. Not in the world. Are you aware of Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 277 of 465 Page 277 1 G Maxwell - Confidential 2 it, in your experience with Jeffrey Epstein, 3 of any interstate or international 4 transportation of women aged 18 to 28, for 5 the purposes of prostitution? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. So whilst I appreciate this might 9 not seem like a smart question, what do you 10 mean by prostitution, what are you asking me 11 exactly? 12 Q. That would be sex for hire, any 13 kind of sexual act that's paid for. 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. Who's paying, what are you asking 17 me. 18 Q. It can be paid for by anybody. 19 It's a sexual act that's paid for. 20 I'm asking if you are aware of any 21 interstate or international transportation of 22 women aged 18 to 28, for the purposes of 23 prostitution? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 278 of 465 Page 278 1 G Maxwell - Confidential 2 A. I have no idea what you are talking 3 about. 4 Q. So you are not aware of that? 5 A. No. 6 Q. Are you aware of any interstate or 7 international transportation of women, aged 8 18 to 28, for the purposes of having sex with 9 Epstein where they would receive compensation 10 of any type? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I don't know what you are referring 14 to. 15 Q. Do you want me to repeat the 16 question? 17 A. Sure, go ahead. 18 Q. Are you aware of any interstate or 19 international transportation of woman, aged 20 18 to 28, for the purpose of having sex with 21 Jeffrey Epstein where they would receive 22 compensation of any type? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. I am not aware of what you are Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 279 of 465 Page 279 1 G Maxwell - Confidential 2 talking about. 3 Q. Are you aware of any interstate or 4 international transportation of women, aged 5 18 to 28, for the purposes of providing a 6 massage for Jeffrey Epstein? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. So I you need to repeat that 10 question for me. 11 Q. Sure. 12 Are you aware of any interstate, 13 meaning between states, or international, 14 oversees, transportation of women, aged 18 to 15 28, for the purposes of providing massage for 16 Jeffrey Epstein? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I think we can agree he did travel 20 from time to time with a professional adult 21 masseuse. 22 Q. Are you aware of any interstate or 23 international transportation of women, aged 24 18 to 28, for the purposes of providing a 25 massage to any person other than Jeffrey Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 280 of 465 Page 280 1 G Maxwell - Confidential 2 Epstein? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. Again, I'm not aware of anybody 6 that, if you are asking for specifics to 7 someone else, I have no knowledge of that. 8 Q. So you are not aware of any 9 interstate or international transportation of 10 a woman aged 18 to 28 for the purposes of 11 providing a massage to any person other than 12 Jeffrey Epstein? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I don't recall what any single 16 person being on a plane for a massage with 17 someone else other than Jeffrey, for the sole 18 purpose, if that's the question, I don't have 19 any recollection of that. 20 Q. Earlier in your testimony, you 21 stated that Virginia Roberts was 17 at the 22 time you met her. 23 How do you know she was 17? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. And to the extent Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 281 of 465 Page 281 1 G Maxwell - Confidential 2 that calls for a privileged response, 3 I'm instructing you not to answer. 4 Q. How do you know Virginia Roberts 5 was 17 at the time you met her? 6 MR. PAGLIUCA: Again, if you 7 learned that information from your 8 lawyer, I'm instructing you not to 9 answer. 10 A. I will follow my counsel's advice. 11 Q. Are you able to answer that 12 question without telling me information you 13 learned from a lawyer? 14 A. I'm not. 15 Q. So you don't have independent 16 knowledge that Virginia, according to your 17 statement, was 17 at the time you met her? 18 A. Again, my lawyer has instructed me 19 not to answer. 20 Q. I'm asking you a different 21 question. Whether you have any independent 22 knowledge, outside your lawyers, that 23 Virginia was 17 at the time you met her? 24 A. Following the instructions of my 25 lawyers, I can only remember or testify to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 282 of 465 Page 282 1 G Maxwell - Confidential 2 what she -- 3 MR. PAGLIUCA: She is asking you a 4 different question. She is asking other 5 than what your lawyers have told you, do 6 you have any knowledge about her being 7 17, that's what she is asking. 8 A. I can't recollect where I got all 9 the information that I have that definitively 10 shows that. 11 Q. Earlier in your testimony, I 12 believe you said all of us would know that 13 Virginia was 17 at the time you met her. 14 How would we know that? 15 A. I think you know that by her own 16 dates, now that it was in 2000, so her entire 17 tail of me celebrating her 16th birthday is 18 clearly another giant falsehood. 19 Q. But she was 16 and 17 that year, 20 wasn't she? 21 A. Which year? 22 Q. You said it was 2000. 23 A. I think the information that I have 24 that indicates that definitively was 25 something that is privileged, so I can't Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 283 of 465 Page 283 1 G Maxwell - Confidential 2 share with you. 3 Q. So you have privileged information 4 that definitively tells you that she was 17 5 at the time you met her? 6 A. I believe I do. 7 Q. How would we know that? 8 A. What are you asking me? 9 Q. Earlier today you testified that we 10 would know that she was 17 at the time that 11 you met her. 12 How would we know that? 13 A. I imagine you have access to 14 exactly the same information that I do. 15 Q. What is that information? 16 A. Again, it's privileged, I can't 17 share it with you but you have been on this 18 case for, I don't know, much much longer than 19 I have and I imagine you have all the 20 information that I do. 21 Q. Do you know whether your lawyers 22 have produced documents from you that would 23 show the age that Virginia was at the time 24 that you met her? 25 MR. PAGLIUCA: To the extent that Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 284 of 465 Page 284 1 G Maxwell - Confidential 2 calls for a communication that you had 3 with one of your lawyers, I'm 4 instructing you not to answer that 5 question. 6 Q. I assume you, as part of the 7 discovery process, had to collect documents 8 that were relevant to this action, is that 9 correct? 10 A. I did. 11 Q. Did you collect documents that 12 would show that Virginia was 17 at the time 13 that you met her? 14 A. I think you have everything that 15 relates, that I had, contemporaneously per 16 what you asked for that I have that relates 17 to that. 18 Q. Did you have a document that 19 identified that Virginia was 17 at the time 20 that you met her? 21 A. You have all of the documents that 22 I had. 23 Q. I'm not asking what documents. I'm 24 asking, do you have a document that 25 identifies Virginia being 17 at the time you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 285 of 465 Page 285 1 G Maxwell - Confidential 2 met her? 3 A. You have every document that I 4 have. You have seen every document that I 5 have. 6 Q. That's not what I'm asking. 7 A. I don't recall every document that 8 I gave you, so I don't know. I would have to 9 look at every single document I gave you and 10 then review it but as I recall you have every 11 document that I have. 12 Q. What are you planning to show the 13 jury that will prove that Virginia was 17 14 when you met her? 15 A. Again that's privileged so I can't 16 share that with you. 17 Q. If you're showing the jury, it 18 wouldn't be privileged, so is there a 19 document you have produced in this matter 20 that shows that Virginia was 17 at the time 21 you met her? 22 MR. PAGLIUCA: She answered that 23 question already. She said she doesn't 24 know, she has given you everything. If 25 there is a decision -- assuming for the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 286 of 465 Page 286 1 G Maxwell - Confidential 2 moment there is such a document, just 3 hypothetically, and assuming for the 4 moment that it is going to get produced 5 somewhere, if it hasn't already been 6 produced, obviously that would involve a 7 waiver, a future waiver of the 8 privilege. I think that's the answer to 9 the question. 10 Q. Has the document been produced, do 11 you know? 12 A. You have everything that I have 13 given you, so if you can't -- if it's not in 14 those documents, I don't know what to tell 15 you. 16 Q. Your lawyers haven't withheld any 17 documents? 18 A. They are right here. You can ask 19 them. 20 Q. I'm asking you. 21 A. I don't know what -- they're 22 lawyers. 23 Q. When we were talking earlier about 24 Prince Andrew, I asked you whether you had 25 ever given him a gift of a puppet. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 287 of 465 Page 287 1 G Maxwell - Confidential 2 Did you ever, not as a gift, did 3 you ever see in the presence of Prince Andrew 4 a puppet? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. Can you be more direct, please? 8 Q. Sure. Were you ever in a room with 9 Prince Andrew where there was a puppet? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. Can you be more specific please and 13 can you bound it by time and be more 14 specific, whatever you are actually asking 15 me? 16 Q. Were you ever in a room with Prince 17 Andrew in New York in Jeffrey Epstein's home 18 where there was a puppet? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. What sort of puppet are you asking 22 me? 23 Q. Any kind of puppet? 24 A. You need to be more descriptive. I 25 don't know what you mean by puppet, there is Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 288 of 465 Page 288 1 G Maxwell - Confidential 2 hand puppets, all sorts of puppets. 3 Q. Is there any puppet you've ever 4 seen in Jeffrey Epstein's home in the 5 presence of Prince Andrew? 6 A. Again, puppet, you know, there is 7 lots of types of puppets. 8 Q. Any type of puppet. 9 A. If you want to give me a 10 description of the puppet, I would be perhaps 11 be able to say. 12 Q. Any type of puppet? 13 A. Can you be more detailed? 14 Q. Have you ever seen a puppet in 15 Jeffrey Epstein's home in the presence of 16 Prince Andrew? 17 A. My understanding of a puppet is a 18 small handheld item you have in a circus. I 19 have never seen that. 20 Q. Have you ever seen a puppet which 21 is defined as a movable model of a person or 22 animal that is used in entertainment and 23 typically moved either by strings or 24 controlled from above or by a hand inside it? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 289 of 465 Page 289 1 G Maxwell - Confidential 2 form and foundation. 3 A. I have not seen a puppet that fits 4 exactly that description. 5 Q. Have you seen any puppet that fits 6 any description? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. Can you reask the question, please? 10 Q. Yes. 11 Have you seen any puppet that fits 12 any description in the presence of Prince 13 Andrew in Jeffrey Epstein's home? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. I am not aware of any small 17 handheld puppet that was there. There was a 18 puppet -- not a puppet -- there was a -- I 19 don't know how would you describe it really, 20 I don't know how would you describe it. Not 21 a puppet, I don't know how you would describe 22 it. A caricature of Prince Andrew that was 23 in Jeffrey's home. 24 Q. Did you use that caricature to put 25 the hand of the caricature on Johanna Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 290 of 465 Page 290 1 G Maxwell - Confidential 2 Sjoberg's breast? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I don't recollect. I recollect the 6 puppet but I don't recollect anything around 7 the puppet. You characterized puppet, I 8 characterize it as, I don't know, as a 9 characterization of Andrew. 10 Q. Do you recollect asking Virginia 11 Roberts to sit on Prince Andrew's lap with 12 the caricature of Prince Andrew? 13 A. I do not recollect that. 14 Q. What do you remember about the 15 caricature of the Prince Andrew caricature 16 when you were in the presence of Prince 17 Andrew, Virginia Roberts and Johanna Sjoberg? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I don't recollect the story as told 21 by Johanna or Virginia. I don't even know 22 who -- I remember the caricature of Prince 23 Andrew and I remember Prince Andrew but I 24 don't recall anything else around the 25 caricature. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 291 of 465 Page 291 1 G Maxwell - Confidential 2 Q. Did you give it to him? 3 A. I did not. 4 Q. Who gave it to him? 5 A. I don't think it was given to him 6 at all. 7 Q. Did he bring it? 8 A. No. 9 Q. Was it something that was at the 10 house? 11 A. As best I recollect. 12 Q. Was it something that you saw at 13 the house in advance of Prince Andrew's 14 arrival? 15 A. Again, I don't real -- I recollect 16 the caricature, I recollect Prince Andrew, I 17 don't recollect much else around the 18 caricature. 19 Q. Was there a party going on in the 20 house at the time you recollect the 21 caricature? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. You have to be way more specific? 25 Q. Do you remember, you said you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 292 of 465 Page 292 1 G Maxwell - Confidential 2 recollect this caricature, you recollect 3 Prince Andrew being there. Do you recollect 4 a party going on at the time of that 5 interaction with Prince Andrew and the 6 caricature? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I don't recollect a party -- first 10 of all, they weren't really parties -- I 11 don't recollect a party -- I don't know what 12 you mean by party in the context of that 13 scenario. 14 Q. Who do you recollect being at the 15 home during the time Prince Andrew was there 16 with this caricature? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I only recollect myself with Prince 20 Andrew, I don't recollect anybody else. 21 Q. You don't recollect Jeffrey Epstein 22 being there? 23 A. Actually, no. 24 Q. You don't recollect Johanna Sjoberg 25 being there? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 293 of 465 Page 293 1 G Maxwell - Confidential 2 A. No. 3 Q. You don't recollect Virginia 4 Roberts being there? 5 A. No. 6 Q. It was just you and Prince Andrew? 7 A. I am not saying it was just me and 8 Prince Andrew, you are asking me do you 9 remember. I only remember Prince Andrew, I 10 remember Prince Andrew and the caricature but 11 I can't place the caricature and everybody 12 else in the same context, the same timeframe 13 you are asking me. 14 Q. Would Prince Andrew typically 15 travel with Secret Service or some sort of 16 security when he would come to visit you and 17 Jeffrey in New York? 18 A. Typically he would have somebody. 19 Q. Would they be in the house or 20 outside of the house? Would they usually 21 stay in the house or outside of the house, in 22 other words guarding the doors or would they 23 come inside? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 294 of 465 Page 294 1 G Maxwell - Confidential 2 A. Typically, there is no typical 3 because there is no standard procedure, so I 4 can't comment or testify to what secret 5 service would or wouldn't do. 6 Q. Do you remember them being in the 7 house? 8 A. Not specifically. 9 Do you mind if I take a bathroom 10 break. 11 THE VIDEOGRAPHER: It's now 3:51 12 and we are off the record. 13 (Recess.) 14 THE VIDEOGRAPHER: It's now 4:04. 15 We are back on the record and we're 16 starting disk No. 7. 17 Q. Ms. Maxwell, during what time 18 period, I know you said, I believe you said 19 you met Jeffrey in 1991, if I'm correct there 20 and you've known him through the present. 21 During what time period within 22 those years would you say your relationship 23 was the closest with Jeffrey? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 295 of 465 Page 295 1 G Maxwell - Confidential 2 A. What do you mean by close, sorry. 3 Q. I think earlier today you testified 4 that at some point in time you considered 5 yourself to be his girlfriend, is that the 6 closest you would say that your relationship 7 was with him and if so, what time period was 8 that? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I don't think I said I was his 12 girlfriend, I would like to think of myself 13 as maybe, I don't think I -- sometime in the 14 mid '90s. 15 Q. How close was your relationship? 16 A. We were very friendly. 17 Q. Without going into details, was 18 your relationship with him intimate? 19 A. Yes. 20 Q. When was the last time you had 21 contact with Jeffrey Epstein? 22 A. What do you mean by contact. 23 Q. Either a phone call or email or 24 anything of that nature? 25 A. As best as I can recollect when Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 296 of 465 Page 296 1 G Maxwell - Confidential 2 all -- sometime last year. 3 Q. So you haven't talked to him like, 4 for example, last week you didn't talk to 5 him? 6 A. I did not. 7 Q. How many times have you had either 8 direct or indirect, meaning, in the presence 9 of him or calling or emailing, contact with 10 Jeffrey Epstein from December 30, 2014 until 11 now? 12 A. I'm sorry, can you just -- 13 Q. Either in person or by phone or by 14 email, from December 30, 2014 until present. 15 A. I can't really characterize that 16 but not very much. There was a period when 17 in January when you filed your, whatever you 18 filed, where we spoke and then, since then 19 not much at all. 20 Q. Can you estimate how many emails 21 you would have sent Jeffrey from the period 22 of December 30, 2014 to the present? 23 A. Not very many at all. 24 Q. More than 20? 25 A. I really wouldn't be able to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 297 of 465 Page 297 1 G Maxwell - Confidential 2 characterize it because it wouldn't be that 3 many. I wouldn't know. 4 Q. More than 50? 5 A. It would be on the lesser side, not 6 on the more side. 7 Q. Can you give me a number? 8 A. I honestly couldn't. I would be 9 guessing. 10 Q. How many emails has Jeffrey sent 11 you from the period December 30, 2014 to the 12 present? 13 A. I would say less emails, even less 14 emails than I sent him. 15 Q. More than 20? 16 A. I would say on the lesser side. 17 Q. Less meaning 10? 18 A. I really can't recall, very little. 19 Q. When you spoke with Jeffrey in 20 January of 2015, what did he say to you? 21 A. I really couldn't remember exactly 22 what he said to me. 23 Q. Did you talk about Virginia 24 Roberts? 25 A. I'm sure we did but I couldn't Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 298 of 465 Page 298 1 G Maxwell - Confidential 2 recall the exact conversation. 3 Q. Does Jeffrey Epstein send you text 4 messages? 5 A. No. 6 Q. Do you send him text messages? 7 A. No. 8 Q. How many phone calls have you had 9 with Jeffrey Epstein since December 30, 2014? 10 A. Again, very few. 11 Q. More than five? 12 A. Probably as many as the few emails 13 that I would characterize, so just very few. 14 I mean a small number. 15 Q. Are you aware of any disagreement 16 between your views about Virginia Roberts and 17 Jeffrey's views about Virginia Roberts? 18 MR. PAGLIUCA: Object to the form 19 and foundation 20 A. I cannot speculate to his views. I 21 can only testify on my views. 22 Q. Earlier you went through the series 23 of lies. Have you talked to Jeffrey about 24 the lies and does he agree with you? 25 A. I have discussed some of the issues Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 299 of 465 Page 299 1 G Maxwell - Confidential 2 with him, I can't remember specifically which 3 ones. I just don't recall. I'm sorry. 4 Q. Do you recall him telling you that 5 he didn't agree with you on any of those? 6 A. I don't recall him saying that. 7 Q. Do you have a joint defense 8 agreement with Jeffrey Epstein? 9 A. I believe I do. 10 Q. Do you have a joint defense 11 agreement with Alan Dershowitz? 12 A. I don't believe I do. 13 Q. Earlier today in your testimony, 14 when I was asking you some questions, you 15 said that you couldn't answer but that 16 Jeffrey Epstein could answer that question. 17 Would Jeffrey Epstein be in a 18 position to confirm or deny some of the 19 obvious lies that we've discussed today? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I can't possibly testify to what 23 Jeffrey could or would say. I can't speak 24 for him. 25 Q. Would Jeffrey be able to confirm or Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 300 of 465 Page 300 1 G Maxwell - Confidential 2 deny whether he had sex with Virginia 3 Roberts? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't say what Jeffrey would say. 7 Q. Has he discussed that with you? 8 A. He has not. 9 Q. Would Jeffrey be able to confirm or 10 deny whether he had a sexual massage from 11 Virginia that first time she came to his 12 mansion in Palm Beach? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I cannot speak for what he would 16 say. I can only speak for what I would say. 17 So as I testified everything that she said 18 about that first meeting didn't happen so... 19 Q. Has he told that you everything 20 about that first meeting didn't happen? 21 A. I know it didn't happen because she 22 put me in that room. 23 Q. I understand you know. But has 24 Jeffrey said when you are talking about the 25 obvious lies, oh yeah, that never happened? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 301 of 465 Page 301 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I can't specifically recall that. 5 I don't know, but he has to agree with me 6 because it didn't happen. 7 Q. Can Jeffrey Epstein, would he be 8 able to confirm or deny whether he had sex 9 with underage girls? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I can't testify to what Jeffrey 13 would say. 14 Q. Can Jeffrey confirm or deny whether 15 Bill Clinton was on Jeffrey's island? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. I can't say what Jeffrey would say. 19 I can only say what I know to be true. 20 Q. Has Jeffrey talked to you about the 21 fact whether Bill Clinton was on his island? 22 A. As best as I can recollect, he said 23 he was not on the island. As best as I can 24 recollect. 25 Q. Can Jeffrey Epstein confirm whether Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 302 of 465 Page 302 1 G Maxwell - Confidential 2 he and Virginia Roberts were together in the 3 presence of Prince Andrew? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't speak to what Jeffrey would 7 say. 8 Q. Has he talked to about Virginia 9 Roberts' statement that she was in the 10 presence of Prince Andrew? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I have not discussed individual 14 presences with Virginia. That's not -- I'm 15 only concerned with what I know to be the 16 stuff about me. So my focus has always been 17 the lies and the obvious lies as something I 18 can personally attest to. I cannot possibly 19 talk for anything else. 20 Q. Has Jeffrey Epstein said to you 21 anything along the lines of Virginia is lying 22 when she says she met Prince Andrew? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Again, I'm not talking about what Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 303 of 465 Page 303 1 G Maxwell - Confidential 2 she says as regards to other people. I can 3 talk to things as regards to me. 4 Q. I'm asking if Jeffrey ever said 5 that to you? 6 A. I don't recollect specific 7 conversations along those things. 8 Q. You don't recollect him saying that 9 to you? 10 A. I don't recollect him saying to me 11 that Virginia didn't meet Prince Andrew. I'm 12 sure that wouldn't be a conversation that we 13 would have. It doesn't effect me whether -- 14 so I'm really only concerned about the lies 15 that were told as regards to me. 16 Q. Can Jeffrey Epstein confirm or deny 17 whether you sent Virginia to give Glenn Dubin 18 a massage? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I can't say what Jeffrey would say, 22 I can tell you I didn't. I can't tell you 23 what anybody else. 24 Q. Have you discussed with him 25 Virginia's allegation that she gave Glenn Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 304 of 465 Page 304 1 G Maxwell - Confidential 2 Dubin a massage? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I didn't know that she did say 6 that. 7 Q. Do you know whether Jeffrey Epstein 8 has ever sent anybody to Glenn Dubin to 9 perform a massage for him? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I couldn't possibly recollect 13 whether he did anything like that. 14 Q. Did you ever send anybody, not 15 Virginia, anybody else over to Glenn Dubin's 16 home for a massage? 17 A. Not to the best of my knowledge. 18 Q. Do you know one of Alexander 19 Dixon's friend by the name of Anuska 20 DiGeorgio? 21 A. I do recollect a person of that 22 name. 23 Q. How do you know her? 24 A. I don't recollect. 25 Q. Did you meet her through Jeffrey? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 305 of 465 Page 305 1 G Maxwell - Confidential 2 A. I don't recollect. 3 Q. Do you recall when you met her? 4 A. I do not recollect. 5 Q. How many times have you seen Anuska 6 DiGeorgio in your life? 7 A. The only reason I remember is 8 because it's an unusual name but I couldn't 9 tell you anything else. 10 Q. You didn't see her on a regular 11 basis, she wasn't one of your friends? 12 A. No. 13 Q. Was Anuska DiGeorgio a masseuse? 14 A. Not to my knowledge. 15 Q. Do you have knowledge of whether 16 she had a sexual relationship with Jeffrey 17 Epstein? 18 A. I have no knowledge of that. 19 Q. When was the last time you spoke 20 with her? 21 A. A very long -- I have no idea. 22 Q. Would it be years? 23 A. Yes. 24 Q. What do you remember about Anuska 25 DiGeorgio? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 306 of 465 Page 306 1 G Maxwell - Confidential 2 A. Nothing really. 3 Q. Do you remember what she looks 4 like? 5 A. I would just be speculating on how 6 I remember. I couldn't describe her. 7 Q. Do you recall traveling with her? 8 A. I don't. 9 Q. Did you ever go to her home? 10 A. I don't believe I did. 11 Q. Do you know where she lives? 12 A. I don't. 13 Q. Would you have met her through 14 Jeffrey Epstein? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I already testified I don't 18 recollect how I met her and I remember her 19 because her name is very unusual. 20 Q. So what's your -- what recollection 21 do you have of her, do you have a specific 22 recollection of meeting her somewhere, you 23 just don't know when that was or how do you 24 know that name Anuska DiGeorgio? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 307 of 465 Page 307 1 G Maxwell - Confidential 2 form and foundation. 3 A. I don't know why the name is -- I'm 4 sorry -- I can't -- I have no idea. I 5 recognize the name but that's it. 6 Q. Was Johanna Sjoberg a masseuse? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. What are you asking me, I'm sorry? 10 Q. When Johanna Sjoberg worked for 11 Jeffrey Epstein, did she perform massages? 12 A. I've testified that when Johanna 13 came originally, she came to answer 14 telephones. I believe at some point she 15 became a masseuse. I don't recollect when 16 and I personally had massages from Johanna. 17 Q. What did Johanna do for Jeffrey 18 Epstein, did she perform massages, anything 19 else? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. When she came she answered phones 23 and at some point, I believe, I don't have 24 any firm recollection, but I believe she went 25 to school and became a masseuse and I had Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 308 of 465 Page 308 1 G Maxwell - Confidential 2 massages from her. 3 Q. Did you ever have any sexual 4 interaction with her? 5 MR. PAGLIUCA: Object to the form 6 and foundation and I'm going to instruct 7 you if we're talking about any 8 consensual adult contact, you are not 9 allowed to answer the question. 10 Q. Did you have any sexual contact 11 with her in the presence of Jeffrey Epstein? 12 MR. PAGLIUCA: Same instruction. 13 Q. Did you have any sexual contact 14 with her in the presence of anybody other 15 than Jeffrey Epstein? 16 MR. PAGLIUCA: Same instruction. 17 Q. How many massages did you receive 18 from Johanna? 19 A. I really don't recall but a fair 20 amount. 21 Q. Did the massages involve sex? 22 MR. PAGLIUCA: I'm going to 23 instruct you not to answer. 24 Q. Have you ever engaged in sex with 25 any female? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 309 of 465 Page 309 1 G Maxwell - Confidential 2 MR. PAGLIUCA: I'm going to 3 instruct you not to answer. 4 MS. McCAWLEY: I want the record to 5 reflect that Ms. Maxwell's attorney is 6 directing her not to answer this series 7 of questions. 8 MR. PAGLIUCA: It definitely does. 9 Q. Were you responsible for 10 introducing Anuska to Jeffrey Epstein? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I already testified that I don't 14 really recall Anuska. 15 Q. Were you responsible for 16 introducing Johanna to Jeffrey Epstein? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. Again, I don't like the 20 characterization of introduction. Johanna 21 came to answer telephones. 22 Q. When did you -- were you the person 23 who brought or introduced or met Johanna for 24 purposes of bringing her to Jeffrey Epstein's 25 home? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 310 of 465 Page 310 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. That's not how I would characterize 5 that. 6 Q. How would you characterize it? 7 A. I have testified that I'm 8 responsible for finding professional people 9 to work in the homes, age appropriate adult 10 people, so from pool attendants, to 11 gardeners, to chefs, to housekeepers, to 12 butlers, to chauffeurs and one of the 13 functions was to be able to answer the 14 telephones and in the context of finding 15 someone to answer the telephones, I did look 16 to try to find appropriate people to answer 17 the phones. 18 Q. So did you find Johanna for 19 purposes of that role? 20 A. So in the course of looking for 21 somebody to answer phones at the house, 22 Johanna was one of the people who said that 23 she was willing to answer phones. 24 Q. Did you approach her at her school 25 campus? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 311 of 465 Page 311 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. I honestly don't recall how, in 5 that moment, how I met Johanna and how she 6 came to get the job but... 7 Q. Did you typically, in your work for 8 Jeffrey Epstein, would you typically go to 9 school campuses to try to find individuals to 10 work for Jeffrey Epstein? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I never -- what do you mean by 14 school? Let's characterize school. 15 Q. Any kind of school. 16 A. Obviously not. I never went to any 17 school with young people. Johanna, I believe 18 came from an adult university, as I would 19 know in England, so university, I went there 20 but I never went, as I best recollect, 21 anywhere else. 22 Q. Did you -- what university was it 23 that you went to? 24 A. I don't recall the university that 25 she went to right now. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 312 of 465 Page 312 1 G Maxwell - Confidential 2 Q. Would you visit more than one 3 university to try to find individuals to work 4 for Jeffrey Epstein? 5 A. As I recollect, I think that's, in 6 fact, the only university I went to. 7 Q. Did you go there more than once? 8 A. I think I went twice. 9 Q. Who else did you find from that 10 university, was there anybody other than 11 Johanna? 12 A. I don't recollect, I'm sorry. 13 Q. We are going to mark this as 14 Maxwell 13? 15 (Maxwell Exhibit 13, documents, 16 marked for identification.) 17 Q. Can you take a look at the document 18 I put in front of you, please. 19 Are you familiar with this 20 document? 21 A. I'm familiar with this actual 22 document. 23 Q. How was this document created? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 313 of 465 Page 313 1 G Maxwell - Confidential 2 A. I don't know how this document was 3 created. 4 Q. You were involved in the creation 5 of this document? 6 A. I think you can see from the date 7 that it's 2004, 2005, so no. 8 Q. You weren't involved in the 9 creation of this document. 10 Did you -- we talked earlier about 11 Mr. Epstein's house, I'm talking about the 12 Palm Beach house where you said there was a 13 computer on the desk, that employees had 14 access to -- people who worked for Jeffrey 15 Epstein may have had access to? 16 A. I think anybody could have had 17 access to that. 18 Q. Was that computer used, if you know 19 to keep a log of addresses and phone contact 20 information for Jeffrey Epstein? 21 A. Are we talking about when this 22 document was created. 23 Q. In general, was there, on that 24 computer during the time that you were 25 present with Jeffrey Epstein, was there a Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 314 of 465 Page 314 1 G Maxwell - Confidential 2 mechanism by which you kept electronic 3 information of names and addresses of 4 individuals that he knew? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I can't testify to what was on that 8 computer or not after I was gone. 9 Q. Not when you were gone, when you 10 were there. If Jeffrey wanted to call, for 11 example, say Les Wexner, would someone be 12 able to go to that computer to pull up the 13 address information and phone contact 14 information for that individual? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I couldn't possibly say. 18 Q. Did you ever have to keep track of 19 address or phone contact information for 20 Jeffrey Epstein? 21 A. That was not my job. 22 Q. Did you ever do it? 23 A. I am not responsible for keeping 24 his numbers so that wasn't my job at all. 25 Q. But did you ever do it? I know Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 315 of 465 Page 315 1 G Maxwell - Confidential 2 it's not your job but did you ever do it, did 3 you ever keep phone contact information for 4 him? 5 A. During the course of the time we 6 were together, if he gave me a telephone 7 number, I would give it to an assistant to 8 put in the computer, I could do that. 9 Q. Would he ask you for contact 10 information for different individuals, if he 11 wanted to contact someone? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. In the course of the long period of 15 time when I was there, it certainly would be 16 possible for him to ask me for a telephone 17 number and if I had the -- I wouldn't always 18 have it -- I'm sure it happened. 19 Q. Was there a hardcopy book in 20 addition to the computer, a hardcopy book 21 that you could look for numbers that were 22 relevant to Jeffrey Epstein's life and 23 something on the computer or was it just an 24 electronic version? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 316 of 465 Page 316 1 G Maxwell - Confidential 2 form and foundation. 3 Q. Was there a hard copy book as well 4 as something on the computer or was there 5 only electronic information on the phone 6 numbers? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I can only testify to what I know 10 obviously, and I believe that this is a copy 11 of a stolen document. I would love to know 12 how you guys got it. 13 Q. I'm asking during the time you 14 worked for Jeffrey Epstein, was there a 15 hardcopy document of any kind that kept phone 16 numbers for Jeffrey Epstein, if he needed to 17 contact someone? 18 A. The stolen document I have in front 19 of me that you have is what you are referring 20 to. 21 Q. So there was, during your time when 22 you were there, there was no other, you 23 mentioned there was information on a 24 computer. Was there any hardcopy document 25 that you could refer to to find someone's Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 317 of 465 Page 317 1 G Maxwell - Confidential 2 number? 3 A. You have the stolen document in 4 front of you. 5 Q. You had access to this when you 6 worked for Jeffrey Epstein? 7 A. This is, I believe, the book that 8 was stolen, that was the hardcopy of whatever 9 was there. 10 Q. So when you were working for 11 Jeffrey Epstein, you were able to access this 12 book? 13 A. This book -- if this is what this 14 is, I believe it was, this is the stolen 15 document from his house. 16 Q. And you were able to access it when 17 you worked for him? 18 A. It was a document that was printed 19 that you could, if you needed to, look for a 20 number. 21 Q. Do you know how this book was 22 created? 23 A. No. 24 Q. When you referred to it a moment 25 ago, to a stolen document, when Alfredo Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 318 of 465 Page 318 1 G Maxwell - Confidential 2 Rodriguez turned this document over to the 3 FBI, are you aware he described it as a 4 document that came from your computer? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I have no idea what he said or 8 didn't say, so if you want me to reference 9 something he said, you need to show it to me. 10 Q. Did you keep this document, an 11 electronic copy of it, on your personal 12 computer? 13 A. I don't recollect. 14 Q. If you had to update something, for 15 example, if there was a new number, a new 16 individual that Jeffrey had hired that you 17 were going to track, would you input that 18 information into this document on your 19 computer? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I've already testified that I'm not 23 responsible for updating and keeping these 24 records. 25 Q. Did you have this document on your Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 319 of 465 Page 319 1 G Maxwell - Confidential 2 computer, your personal computer? 3 A. I told you, I don't recollect 4 having this document on my computer. 5 Q. Do you know what computers this 6 document was on, if more than one? 7 A. I'm sorry, this is a long time ago 8 and I don't recall exactly how this was all 9 managed. 10 Q. If you didn't create this document, 11 do you know who did? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I don't. 15 Q. I'm going to direct your attention 16 to part of this document. It's towards the 17 back, it's going to be page 91 and it has 18 bates label Giuffre 001663. I'm going to 19 direct your attention to the section that 20 says, Massage Florida. 21 Did you input any of the names or 22 numbers under that section? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. So this document is produced in Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 320 of 465 Page 320 1 G Maxwell - Confidential 2 2004, 2005, so, no. 3 Q. But I'm sorry, correct me if I'm 4 misunderstanding your testimony, I thought 5 you said when you were working with Jeffrey, 6 that this document existed and it was 7 something you utilized? 8 A. I can't possibly tell you what 9 numbers were added or not added subsequent to 10 my departure. 11 Q. So you can't recall if you added 12 any of these numbers? 13 MR. PAGLIUCA: Objection to the 14 form and foundation, mischaracterizes 15 the witness' testimony. 16 Q. Are there any numbers on here or 17 names that you recognize that you would have 18 entered into this section? 19 A. I already testified that I'm not 20 responsible for inputting numbers and names 21 into this so I would not be able to tell you. 22 Q. Are there any names or numbers 23 under this section, Massage Florida, that you 24 would have provided to an assistant to input 25 into this document? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 321 of 465 Page 321 1 G Maxwell - Confidential 2 A. I can't possibly say. 3 Q. Do you see under Massage Florida, 4 about halfway down the first column, do you 5 see a number that says Johanna's cell? 6 MR. PAGLIUCA: What page? 7 Q. It's 91, Bates number 001663. 8 About halfway down, it says in the first 9 column, it says Johanna's cell. 10 Do you see that? 11 A. I do. 12 Q. Would you have provided after, I 13 know you didn't hire her, Jeffrey hired her 14 but after you brought her to Jeffrey, would 15 you have given her cell phone number to an 16 assistant to input into this document? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. I didn't bring her to Jeffrey, the 20 way you characterize and I would have no 21 knowledge of how this number ended up in this 22 book. 23 Q. I believe you, and I will try to 24 use your words so we are clear, you met 25 Johanna, is that correct? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 322 of 465 Page 322 1 G Maxwell - Confidential 2 A. Yes. 3 Q. And then she began working for 4 Jeffrey? 5 A. Yes. 6 Q. Would you have provided whomever 7 was in charge of keeping this updated with 8 Johanna's cell number so you would be able to 9 contact her if needed? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I don't know. It could have been a 13 number of different ways, it it could have 14 been Jeffrey who gave it to somebody. 15 Q. You just don't remember doing that? 16 A. I do not. 17 Q. Now, as you look -- I want you to 18 take a look at the Florida massage list, it's 19 three columns there. 20 Do you, as you look at those names 21 on the various columns, do you know the ages 22 of any of the girls in this list? 23 A. I don't know. One, I don't know 24 who all the people are on this list and I 25 certainly don't know the ages. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 323 of 465 Page 323 1 G Maxwell - Confidential 2 Q. Do you know what their 3 qualifications are? 4 A. I don't know who the people are in 5 general so of course I don't know what their 6 qualifications are. 7 Q. Do you know why Jeffrey has so many 8 masseuses listed in Florida in his book here? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. Again, this book was created post 12 my departure, so I couldn't explain why all 13 these people were here. 14 Q. When you were there, you said this 15 book existed? 16 A. Yes. 17 Q. So when you were there, were there 18 a number of masseuses listed under the 19 Florida massage? 20 MR. PAGLIUCA: Objection to the 21 form and foundation and 22 mischaracterization of the witness' 23 testimony. 24 Q. I'm asking you a question. 25 When you were there, were there a Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 324 of 465 Page 324 1 G Maxwell - Confidential 2 number of masseuses listed under the Florida 3 massage section? 4 A. When I was there, I would have, of 5 course there would have been some masseuses 6 listed but I could not tell you who or how 7 many and this -- I could not possibly because 8 I wouldn't remember. 9 Q. Do you know why Jeffrey would have 10 had so many names listed under his massage 11 Florida? 12 MR. PAGLIUCA: Objection to form 13 and foundation. 14 A. I can't testify to why Jeffrey has 15 so many. 16 Q. Did he use a different masseuse 17 every day? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 Q. You can answer. 21 A. When I was there he had a massage 22 roughly every day, one masseuse, and mostly 23 he would have them at random times, so it 24 would be difficult if you just only had one 25 person, man, woman, for an adult massage, to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 325 of 465 Page 325 1 G Maxwell - Confidential 2 come and be available for whatever time it 3 was. So he would have more than one person 4 that he could call for a massage because at 5 any given time the one that he called first 6 may not have been available. 7 Q. So would it typically be a 8 different person each day that would give him 9 a massage? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. It would be, when I was there, 13 based on availability. 14 Q. Would it surprise you to learn that 15 the Federal Government found that some of the 16 girls on this list under massage Florida were 17 under the age of 18? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I can't testify to what the 21 government found or did not find because I 22 would have no knowledge of it. 23 Q. I'm asking if you would be 24 surprised by that? 25 MR. PAGLIUCA: Form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 326 of 465 Page 326 1 G Maxwell - Confidential 2 A. I have knowledge of it. I can't 3 speculate. 4 Q. On the second column, towards the 5 bottom, there is the name, it's one up from 6 the bottom, there is the name Gwendolyn Beck, 7 do you know Gwendolyn Beck? 8 A. I do. 9 Q. Who is she? 10 A. She was a friend of Jeffrey's. 11 Q. Is she a masseuse? 12 A. She, I don't think she was a 13 masseuse, no. 14 Q. Why would be she listed under 15 Florida massages? 16 A. An input error. 17 Q. Is this list any individual that 18 would have sex with Jeffrey? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I wouldn't have any knowledge of 22 that. 23 Q. Do you know if Jeffrey had sex with 24 Gwendolyn Beck? 25 MR. PAGLIUCA: Object to the form Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 327 of 465 Page 327 1 G Maxwell - Confidential 2 and foundation. 3 A. First of all, I wouldn't have any 4 knowledge of that. 5 MS. McCAWLEY: We are going to take 6 a quick break. 7 THE VIDEOGRAPHER: It's now 4:39 8 and we are off the record. 9 (Recess.) 10 THE VIDEOGRAPHER: It's now 4:54 11 and we are as back on the record 12 starting disk number 8. 13 Q. Ms. Maxwell, we were talking 14 earlier about the journal and I believe you 15 said in 2004, 2005, you were no longer 16 working and responsible for that journal, is 17 that correct? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. What are we referring to, this 21 document right here? 22 Q. Yes. 23 A. I don't know who is the author of 24 this or I can't tell you what is in here 25 versus what would have been here when I was Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 328 of 465 Page 328 1 G Maxwell - Confidential 2 around. I can't testify to that. 3 Q. Were you around in 2004, 2005? 4 A. I already testified that I was 5 there when Jeffrey's mother passed away and 6 so you know, I did visit for her passing and 7 I believe I was there for a couple of days in 8 2005. 9 Q. So if an employee of Mr. Epstein in 10 2004 said that you were the employee's direct 11 supervisor, would that be incorrect? 12 MR. PAGLIUCA: Objection to form 13 and foundation. 14 A. What employee, what's the 15 circumstances and what is the story, I don't 16 know what you are asking me. 17 Q. If Alfredo Rodriguez said in 2004 18 when he was hired, you were his direct 19 supervisor, would that be true? 20 A. No. 21 Q. Were you in 2004 supervising Sarah 22 Kellen? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. I never supervised Sarah Kellen. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 329 of 465 Page 329 1 G Maxwell - Confidential 2 Q. Did Sarah Kellen take orders from 3 you? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. She worked for Jeffrey. 7 Q. If Alfredo Rodriguez said you had 8 knowledge of underage girls coming to 9 Jeffrey's home for the purpose of sex, would 10 you contend that that is truthful? 11 MR. PAGLIUCA: Objection to the 12 form and foundation of the question. 13 A. I have no idea what you are talking 14 about, I'm sorry. 15 Q. If Alfredo Rodriguez said that you 16 have knowledge of underage girls coming to 17 Jeffrey's home for the purpose of having 18 massages involving sex, would you say that 19 that statement is truthful? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I can't testify to what Alfredo 23 said or didn't say. 24 Q. I'm saying if Alfredo said that you 25 had knowledge that there were girls coming Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 330 of 465 Page 330 1 G Maxwell - Confidential 2 over to the house that were underage for the 3 purposes of sex, would that statement be 4 true? 5 MR. PAGLIUCA: Objection to form 6 and foundation. 7 A. I can't testify to what Alfredo 8 said or didn't say or what he thought. 9 Q. Did you have knowledge of underage 10 girls coming to Jeffrey Epstein's house for 11 the purpose of sex? 12 A. No. 13 Q. Earlier I believe you testified, 14 correct me if I'm wrong, that the document 15 that is in front of you, the thicker document 16 was a stolen document. 17 Do you know who stole that 18 document? 19 A. I have read that Alfredo stole the 20 document. 21 Q. And where have you read that? 22 A. I believe it was reported in the 23 press. 24 Q. Earlier we were talking about the 25 computers at Jeffrey Epstein's home. Did you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 331 of 465 Page 331 1 G Maxwell - Confidential 2 have a computer that was your computer 3 located in Jeffrey Epstein's home? 4 MR. PAGLIUCA: Objection to form 5 and foundation. 6 A. I've testified to the computer 7 already. Even when I was around, there was a 8 computer that people had access to. 9 Q. So is Alfredo Rodriguez telling the 10 truth when he says that he downloaded that 11 book from your computer? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I couldn't possibly tell you what 15 Alfredo did or didn't do or said or didn't 16 say. 17 Q. Was it on your computer? 18 A. I already testified I have no idea 19 where this document came from. 20 Q. Did you have a list of names of 21 individuals with contact information for 22 Jeffrey Epstein on your personal computer? 23 A. Again, that wasn't my computer. I 24 already said that was a computer that lots of 25 people would have, so I have no recollection Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 332 of 465 Page 332 1 G Maxwell - Confidential 2 of this document being on it, so I don't know 3 where this came from. 4 Q. I understand the computer at the 5 house that you're referencing. On a personal 6 computer of yours, did you have that 7 document? 8 A. I don't know where this document 9 came from, so I can't possibly say this 10 document was on any computer that I may have 11 had access to. 12 Q. On a personal computer of your own, 13 did you have lists of the phone numbers and 14 contact information relating to Jeffrey 15 Epstein? 16 A. Like everybody, I have an address 17 book but I can't possibly testify to where 18 this thing came from. 19 Q. Was it your address book or was it 20 addresses that related to Jeffrey Epstein? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I don't know what you're asking me. 24 Q. On your personal computer, the 25 address book you are referencing, was it your Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 333 of 465 Page 333 1 G Maxwell - Confidential 2 address book with individuals you knew or was 3 it an address book for your employer, Jeffrey 4 Epstein? 5 A. Jeffrey has his situation and I 6 have no -- this is Jeffrey's, it came from 7 his home, so I can't testify to anything 8 about this in that period of time. 9 Q. So you didn't have on your computer 10 a list of contact information for individuals 11 that was related to Jeffrey Epstein? 12 A. I don't recall exactly what I had 13 back in 2004 and 2005, so I can't say what I 14 had back then that relates to his addresses, 15 I can't recall. 16 Q. So is it possible that someone 17 could have downloaded from your personal 18 computer a list of names and address that 19 were affiliated with Jeffrey Epstein? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. This didn't come from any computer 23 of mine. 24 Q. But is it possible that someone 25 could have downloaded a list of names and Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 334 of 465 Page 334 1 G Maxwell - Confidential 2 addresses affiliated with Jeffrey Epstein 3 from your computer? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I already said, I didn't have a 7 computer there, so I don't know where this 8 came from, I have no idea. 9 Q. I'm going to read to you some 10 testimony from Alfredo Rodriguez's deposition 11 and it's on page 370 and I want to ask you a 12 question about it, if it's true or false? 13 MR. PAGLIUCA: I'm going to object 14 unless you show the witness the 15 document. 16 MS. McCAWLEY: I will pass it. We 17 are not going to mark it. We will skip 18 it. 19 Q. Did you ever tell Alfredo Rodriguez 20 that he better watch out and better keep his 21 mouth shut with respect to what occurred at 22 Mr. Epstein's home? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. It doesn't sound like anything I Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 335 of 465 Page 335 1 G Maxwell - Confidential 2 would say. 3 Q. Did you ever threaten Alfredo 4 Rodriguez in any way if he were to disclose 5 information he learned from his employment 6 with Jeffrey Epstein? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I'm happy to answer. No, I never 10 threatened him in any way. 11 Q. Were you concerned that he was 12 going to disclose that Jeffrey Epstein was 13 trafficking underage girls? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. First of all, there are so many 17 things wrong with that question, but I have 18 no knowledge of what you are talking about. 19 Q. Have you ever contacted or 20 instructed anyone to contact any witness in 21 this case for the purposes of threatening 22 them not to testify in this case? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I have never called anybody with Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 336 of 465 Page 336 1 G Maxwell - Confidential 2 reference to this case with any, anything you 3 just mentioned, I never threatened anyone. 4 Q. Have you ever directed anyone to 5 call any witnesses relevant to this case and 6 threaten them not to testify? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I never done such a thing. 10 Q. Did Jeffrey Epstein or you ever ask 11 any female, regardless of age, to carry 12 Jeffrey's baby for him? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 Q. Or anything along those lines? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Can you repeat the question, 19 please? 20 Q. Did you or Jeffrey Epstein ever ask 21 any female, regardless of age, to carry 22 Jeffrey Epstein's baby for him? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Are you asking -- Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 337 of 465 Page 337 1 G Maxwell - Confidential 2 Q. To become pregnant, did you or 3 Jeffrey Epstein ever ask any female to become 4 pregnant and carry Jeffrey Epstein's baby for 5 you or for Jeffrey? 6 MR. PAGLIUCA: Objection to form 7 and foundation. 8 A. You need to be very specific. I 9 have no idea what you are talking about. 10 That's completely rubbish. 11 Q. Did you or Jeffrey Epstein ask any 12 female to become pregnant and carry his baby 13 for either him or you? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. Go ahead. 16 A. I can't testify to anything Jeffrey 17 did or didn't do when I am not present, but I 18 have never asked anybody to carry a baby for 19 me. 20 Q. Or anything along those lines? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 Q. I want to make sure we are talking 24 about the same thing, not physically carry a 25 baby, I mean become pregnant with a baby? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 338 of 465 Page 338 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 Q. I want to make sure we are clear. 5 A. I don't know what you are asking. 6 Q. That's why I want to make sure we 7 are clear. 8 A. We are clear. I never asked 9 anybody to carry a baby for me. 10 Q. Do you know if Jeffrey ever asked 11 anybody to carry a baby for him? 12 A. I'm not going to characterize any 13 conversation Jeffrey had with somebody else. 14 Q. You are not aware of that, is that 15 your testimony? 16 A. I am testifying I never have and I 17 will not testify for anything for Jeffrey. 18 Q. Did you ever hear Jeffrey ask 19 anybody to carry a baby for him? 20 A. I don't recollect conversation 21 about Jeffrey and babies in any form. 22 Q. Did Jeffrey ever tell he wanted to 23 have a baby? 24 A. I don't recollect baby 25 conversations with Jeffrey. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 339 of 465 Page 339 1 G Maxwell - Confidential 2 Q. So he never told you he wanted to 3 have a baby? 4 A. I don't recollect any baby 5 conversations with him saying he wanted to 6 have a baby. 7 Q. Did you ever bring any females to 8 the Dubin's house that were not your friends' 9 children that were under the age of 18? 10 MR. PAGLIUCA: Objection to form 11 and foundation. 12 A. I have never, to my knowledge, 13 brought anybody under the age of 18 that's 14 not a friend of my family or my nieces or 15 nephews to the Dubin household. 16 Q. Earlier today you testified, I 17 believe, that with respect to your town home 18 Jeffrey paid for some of that and then gave 19 you a loan, is that correct? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I said, actually I think it was a 23 loan, I believe it was a loan. 24 Q. The whole thing? 25 A. As best as I can recollect. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 340 of 465 Page 340 1 G Maxwell - Confidential 2 Q. Did you pay that loan back? 3 A. I don't have any outstanding loans 4 with him. 5 Q. So you paid it back? 6 A. I don't have any outstanding loans 7 with him. 8 Q. That's not an answer to my 9 question. 10 Did you pay back Jeffrey for the 11 loans? 12 A. I have paid back any loans I had 13 with him. 14 Q. You have or haven't? 15 A. Have. 16 Q. Were there any other gifts that 17 Jeffrey gave you during the time period of 18 say 1999 to the present that were in excess 19 of $50,000? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. What's the question again? 23 Q. Did Jeffrey give you any gifts in 24 excess of amounts of $50,000, I'm not talking 25 about a scarf here or something Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 341 of 465 Page 341 1 G Maxwell - Confidential 2 insignificant, from 1999 to the present? 3 A. I can't recollect any gifts. 4 Q. Did he ever buy you a car? 5 A. I really don't recall, I can't 6 recall, it's a long time ago. 7 Q. You can't recall if Jeffrey Epstein 8 ever bought you a car? 9 A. I believe he did buy me a car, I 10 don't recall how much it cost. I don't 11 recall any of the financial details of that. 12 Q. Do you still have that car? 13 A. I don't. 14 Q. How long ago did you get rid of 15 that car? 16 A. I don't recall all the cars. There 17 was a car back -- there was -- I don't 18 recall, I'm sorry. 19 Q. He supplied you with several cars? 20 MR. PAGLIUCA: Object to the form 21 and the mischaracterization of the 22 testimony. 23 A. I don't recall details of the cars. 24 Q. Did he supply with you more than 25 one car? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 342 of 465 Page 342 1 G Maxwell - Confidential 2 A. Over the course of time, I've 3 driven many cars. 4 Q. That Jeffrey provided to you? 5 A. They were cars that could be driven 6 and I just don't recall them. 7 Q. Were they in your name? 8 A. I don't recall. 9 Q. You don't recall if Jeffrey Epstein 10 ever put a car in your name? 11 A. We are talking a long time ago, I 12 really don't recall. 13 Q. When is the last time you had a car 14 from Jeffrey Epstein that you used? 15 A. 2000, 2001, 2002. 16 Q. Do you recall what kind of a car 17 that was? 18 A. I don't recall, I'm sorry. 19 Q. Did Jeffrey Epstein purchase 20 anything else for you besides the townhouse 21 and cars that would be over the amount of 22 $50,000? 23 A. I didn't say that he did, I said I 24 had a loan. 25 Q. Besides the loan, I'm sorry, you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 343 of 465 Page 343 1 G Maxwell - Confidential 2 are right, you did say you had a loan and you 3 said you paid that back, correct? 4 A. That's my testimony. 5 Q. Anything else in excess of $50,000 6 that he would have purchased for you? 7 A. We are talking 2002, 2001, I don't 8 recall any gifts really. 9 Q. When is the last time Jeffrey 10 Epstein gave you a gift in excess of $50,000? 11 MR. PAGLIUCA: Assumes facts not in 12 evidence. Form and foundation. 13 Q. You're saying you don't remember 14 from 2001 and 2002. I'm asking when is the 15 last time you remember Jeffrey Epstein 16 purchasing a gift for you? 17 A. I don't recall gifts in excess of 18 $50,000, I barely recall gifts, I barely 19 recall a lot of this -- I'm sorry, I don't 20 recall. 21 Q. Is Jeffrey Epstein paying for your 22 legal fees in this case? 23 A. No. 24 Q. Is he paying for anything related 25 to this case? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 344 of 465 Page 344 1 G Maxwell - Confidential 2 A. No. 3 Q. Are you aware of any grand theft 4 police report relating to Virginia Roberts? 5 A. I believe I've read a report in the 6 press on that. 7 Q. Did you provide the press with a 8 report on a grand theft by Virginia Roberts? 9 A. I don't know how the press got that 10 story. 11 Q. Do you know if Virginia Roberts 12 committed a grand theft? 13 A. I only know what I read in the 14 press. 15 Q. Did you ever state to the press 16 that Virginia Roberts committed a grand 17 theft? 18 A. I've never had any conversation 19 directly with press. 20 Q. Did any of your representatives 21 ever inform the press that Virginia Roberts 22 committed a grand theft? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I have no way of knowing what my Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 345 of 465 Page 345 1 G Maxwell - Confidential 2 representatives said to press or didn't. 3 Q. Did they ever discuss with you the 4 fact that they were going to report that 5 Virginia Roberts participated in a grand 6 theft? 7 A. I don't know how, first of all, I 8 don't know how I know that. I believe I read 9 it in a press report so... 10 Q. I'm going to mark this as composite 11 exhibit, Maxwell 14 please? 12 (Maxwell Exhibit 14, email, marked 13 for identification.) 14 Q. I'm going to direct you to page GM 15 00109. At the top of that page you are going 16 to see an email address from Jeffrey Epstein 17 on Sunday June 12, 2011 to 18 19 A. Yes. 20 Q. The re line says, This is the 21 actual version they wanted me to send which I 22 changed but this is back from my U.K. 23 lawyers. 24 Do you see that? 25 A. Yes. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 346 of 465 Page 346 1 G Maxwell - Confidential 2 Q. If you go down further, you're 3 going to see halfway through the page, you 4 will see your email address the 5 and you will see a statement that says, Thank 6 you. I have it now. I'm working on the 7 letter a little. I will send final version 8 tomorrow and whatever is in it will be 9 factually accurate. 10 Beneath that you will see Philip 11 Barden who I believe you identified earlier 12 as one of your attorneys? 13 A. Uh-huh. 14 Q. And you will see a letter, starting 15 the text of a letter starting, I want you to 16 turn to the second page which is GM 00110. 17 About halfway through the page, it says you 18 will also presumably draw attention to the 19 fact that prior to filing her suit against 20 Mr. Epstein, Ms. Roberts fled the U.S. to 21 avoid being arrested for grand theft. Police 22 report available. 23 What grand theft were you referring 24 to there that Virginia Roberts committed? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 347 of 465 Page 347 1 G Maxwell - Confidential 2 form and foundation. 3 A. I don't know. However, I believe 4 she stole money from somewhere where she 5 worked. 6 Q. How do you know that was grand 7 theft? 8 A. I don't know how I know that. 9 Q. So you authorized a statement that 10 characterized that as grand theft without 11 knowing whether it was grand theft? 12 A. What month, what is the date of 13 this? 14 Q. The date of this is June 12, 2011? 15 A. So I'm afraid such a long time ago, 16 I'm not sure how, I really couldn't testify 17 as to how that language ended up in here. 18 Q. Do you have the police report? It 19 says police report available. Do you have 20 that document? 21 A. I don't have that document. 22 Q. Who does? 23 A. I have no idea. 24 Q. Would your lawyer Philip Barden 25 have that document? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 348 of 465 Page 348 1 G Maxwell - Confidential 2 A. I don't know who has this document. 3 Q. What's your basis in that statement 4 for saying Ms. Roberts fled the U.S.? 5 A. Again, you are asking me for a 6 statement that I made in 2011 and I can't say 7 what in 2011 exactly the basis of that 8 statement was. 9 Q. So you don't know whether or not 10 that statement is true? 11 A. This is in 2011 and it never went 12 out, so I'm not sure exactly. 13 Q. But you said in your email that you 14 were working to make it factually accurate, 15 is that correct? 16 A. That's what it says. 17 Q. I'm going to mark as Maxwell 15 a 18 document dated February 24, 2015? 19 (Maxwell Exhibit 15, email, marked 20 for identification.) 21 Q. This is an email from Ross Gow who 22 you've identified as your press agent on 23 February 24, 2015 to which I understand 24 to be your email address and Philip Barden. 25 The subject line says, VR cried rape. Prior Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 349 of 465 Page 349 1 G Maxwell - Confidential 2 case dismissed as prosecutors found her not 3 credible. The message says, Ghislaine, some 4 helpful leakage, dot dot dot. What is it you 5 were leaking to the press? 6 MR. PAGLIUCA: Objection, there is 7 no foundation that she leaked anything 8 and you know that. 9 Q. What was it that you were leaking 10 to the press in that statement? 11 A. Again, I don't think that's 12 referring to that, that's just referring to 13 the press getting hold of whatever story it 14 is. 15 Q. What was Ross Gow leaking to the 16 press? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. It doesn't say Ross was leaking 20 anything. It doesn't say that. 21 Q. The statement says, helpful 22 leakage, is that correct? 23 A. It says helpful leakage. That 24 doesn't mean he leaked anything. 25 Q. Did you leak to the press Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 350 of 465 Page 350 1 G Maxwell - Confidential 2 information to the press information about 3 the subject line, VR cried rape, prior case 4 dismissed as prosecutors found her not 5 credible? 6 A. I don't no idea what Ross is 7 referring to. I think he is referring to the 8 press held the story. I couldn't testify to 9 that. 10 Q. Did you leak to the press 11 information regarding the statement, VR cried 12 rape prior case dismissed as prosecutors 13 found her not credible, either through you or 14 through your press agents? 15 A. I think this is coming from the 16 daily mail. 17 Q. That is not my question, I'm asking 18 whether you or your press agent leaked that? 19 A. I have no knowledge, I have no 20 idea, I'm sorry. I can't -- I have no 21 recollection. I have no idea what she is 22 talking about. 23 Q. I'm going to mark this as 16? 24 (Maxwell Exhibit 16 email marked 25 for identification.) Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 351 of 465 Page 351 1 G Maxwell - Confidential 2 Q. This is an email addressed at the 3 top from Jeffrey Epstein on Monday, January 4 12, 2015 to which I understand to be 5 your email address. The email reads, You can 6 issue a reward to any of Virginia's friends, 7 aquaints, family, that come forward to help 8 prove her allegations are false. The 9 strongest is the Clinton dinner and the new 10 version of the Virgin Islands that Stven 11 Hawking practiced in an underage orgy. 12 Did you offer any rewards to 13 Virginia's family or friends to contradict 14 Virginia's story? 15 A. Absolutely not. 16 Q. Did Jeffrey Epstein offer any 17 rewards to any of Virginia's, as he suggests 18 here, friends, family or acquaintances to 19 contradict Virginia's story? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I have no idea what he did. 23 Q. Did he tell he was going to offer 24 rewards to Virginia's acquaintances, friends 25 and family to prove her allegations were Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 352 of 465 Page 352 1 G Maxwell - Confidential 2 false? 3 A. He did not. 4 Q. Do you know whether Jeffrey Epstein 5 paid Rebecca Boylen to give testimony about 6 Virginia Roberts? 7 A. I don't know who Rebecca Boylen is. 8 Q. So you don't know whether Jeffrey 9 Epstein paid her? 10 A. I don't know who Rebecca Boylen is. 11 Q. Have you ever contacted any of 12 Virginia's friends, acquaintances or family 13 regarding this case? 14 A. I don't know who Virginia's friends 15 or family are and I have not contacted 16 anybody related to her in any way, shape or 17 form. 18 Q. I will turn you, I believe it's the 19 thicker document which is Maxwell, I believe 20 it was 14, right there, the compilation 21 document to GM, at the bottom, GM 00071. You 22 actually may want to turn to the prior page 23 70 so you can see the email chain. At the 24 top of the page -- 25 MR. PAGLIUCA: I don't have a 00071 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 353 of 465 Page 353 1 G Maxwell - Confidential 2 on mine. 3 MS. McCAWLEY: It's the second page 4 in that document. 5 MR. PAGLIUCA: Okay. 6 Q. It's dated Friday March 11, 2011 7 from Maxwell to Jeffrey with the title, Daily 8 Mail and there is a forward from Ross Gow to 9 you and a number of other individuals, that's 10 on the cover page and as you scroll to the 11 second page, you are going to see that part 12 of the chain that I'm asking about and that 13 is the chain at the bottom which is dated 14 3/10/2011 from Brian Basham and it says we 15 think -- we should think about the letter to 16 the editor. School can be university. Age 17 of consent in Florida is complex. See below, 18 if you are 16 years old, a sexual 19 relationship with someone between 18 and 24 20 is legal in Florida. Two persons between 16 21 and 24, Florida statute 794.05. A person 24 22 years or of age or older who engages in 23 sexual activity with a person 16 or 17 years 24 of age commits a felony in the second degree. 25 So as soon as you turn 16 you are able to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 354 of 465 Page 354 1 G Maxwell - Confidential 2 have sexual relations and you can have sexual 3 relations with a minor under the age of 18 4 until your 24th birthday. 5 Why were you concerned with the age 6 of consent in Florida? 7 MR. PAGLIUCA: Objection to the 8 form and foundation of the question. 9 A. I wasn't concerned. I think this 10 was somebody sending me the statute for 11 informational purposes. 12 Q. Who is Brian Basham? 13 A. He is the person who, Ross Gow's 14 boss I believe, I don't know what the 15 relationship is. 16 Q. I didn't hear you? 17 A. I think he owns the agency, I'm not 18 sure exactly. 19 Q. Why would he be sending you 20 information addressing concerns about the age 21 of consent in Florida? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. I think he was just trying to be -- 25 telling me details that would happen, Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 355 of 465 Page 355 1 G Maxwell - Confidential 2 Virginia in '11 was claiming she was 15 and 3 we thought she was 17. I didn't know what 4 the statutes were in Florida and I think he 5 was just trying to be helpful so I would 6 know. 7 Q. Did you have a concern that you had 8 violated this statute in Florida? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. No. 12 Q. Did you have a concern that Jeffrey 13 Epstein had violated this statute in Florida? 14 A. I'm not concerned what happened 15 with Jeffrey. I'm only concerned what 16 happens with me. 17 Q. Why did you communicate with your 18 press agent about the sexual consent age in 19 Florida? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. It misstates her 22 testimony. 23 A. I wasn't concerned. I think he was 24 being helpful and stating what the statute 25 was. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 356 of 465 Page 356 1 G Maxwell - Confidential 2 Q. I'm going to turn you now in that 3 same stack the Bates number GM 00088. At the 4 top of the email you are going to see Jeffrey 5 Epstein, dated June 8, 2011, to you and it's 6 got a re line, Vanity Fair. If you go down 7 the chain you will see where it says under 8 your email, Do you have a problem with 9 anything I said. 10 Were you communicating with Jeffrey 11 to confirm what statements you could put in 12 any press releases you were given? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. Any interest I have is in accuracy. 16 Q. Were you confirming with Jeffrey 17 Epstein what information you could put in 18 press releases? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. Again, I'm only looking for 22 accuracy. 23 Q. Why would you ask him if he had a 24 problem with anything you were saying? 25 A. If there is anything I Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 357 of 465 Page 357 1 G Maxwell - Confidential 2 characterized that was not correct. 3 Q. That's not what you said. You 4 said, do you have a problem with anything I 5 said. 6 MR. PAGLIUCA: Objection to the 7 form and foundation. There is no 8 question pending. 9 MS. McCAWLEY: There is. 10 MR. PAGLIUCA: That's not a 11 question, it's a statement. 12 MS. McCAWLEY: Don't interrupt me. 13 Q. Di you say, do you have a problem 14 with anything I said? 15 A. That was asking in my parlance that 16 I wanted him to check it for accuracy. 17 Q. Did he tell you there was anything 18 inaccurate about the statement? 19 A. Again, I have to read the whole 20 thing to figure that out. 21 Q. Were you coordinating with Jeffrey 22 Epstein during this time period in 2011 23 regarding statements that you were issuing to 24 the press? 25 MR. PAGLIUCA: Did you withdraw the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 358 of 465 Page 358 1 G Maxwell - Confidential 2 last question. 3 MS. McCAWLEY: I'm not withdrawing 4 anything. I'm asking a question. 5 MR. PAGLIUCA: There was a question 6 pending. You didn't let the witness 7 answer the question, then you moved on 8 to another question so I'm asking for 9 clarification for the record now which 10 question are we answering. 11 MS. McCAWLEY: There is an answer. 12 The question was did he tell you 13 anything, there was anything in the 14 statement inaccurate about the statement 15 and she said again, I read the whole 16 thing -- 17 THE WITNESS: I would have to. 18 MS. McCAWLELY: -- I would have to 19 read the whole thing to figure that out. 20 MR. PAGLIUCA: Then she started 21 reading it and you asked another 22 question. 23 MS. McCAWLEY: That's the question. 24 MR. PAGLIUCA: I'm wondering if its 25 still pending. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 359 of 465 Page 359 1 G Maxwell - Confidential 2 MS. McCAWLEY: It was answered. 3 Q. Were you coordinating with Jeffrey 4 Epstein during the time period in 2011 5 regarding the statements you were issuing to 6 the press? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I only wanted to be accurate in any 10 factual statements that I made. 11 Q. You knew at that time that Jeffrey 12 Epstein had been convicted for sexual abuse 13 of a minor, is that correct? 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. He was sentenced I believe for 17 underage -- soliciting an underaged 18 prostitute. 19 Q. You knew that he was a registered 20 sex offender? 21 A. Yes. 22 Q. You were coordinating with him the 23 statement that you were going to be making to 24 the press to confirm whether they were 25 accurate in your words? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 360 of 465 Page 360 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I was not coordinating with 5 Jeffrey. He had details that I did not have. 6 I was not party to his case. I needed to 7 have information in order to be able to 8 respond so I was not coordinating with him. 9 I was merely asking for details that I could 10 have. 11 Q. Did Jeffrey write any of your press 12 statements for you? 13 A. No. 14 Q. He didn't draft any of them? 15 A. I have a lawyer who was working on 16 this and that was -- I asked, I believe as I 17 recollect asked him for information to make 18 sure I was being accurate in the 19 representations for whatever I was 20 discussing. 21 Q. Did Jeffrey provide you with any 22 drafts of statements to provide to the press? 23 A. I only recall drafts from my 24 lawyer. 25 Q. I will mark this as Maxwell 17. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 361 of 465 Page 361 1 G Maxwell - Confidential 2 (Maxwell Exhibit 17, email, marked 3 for identification.) 4 Q. This is an email from you on 5 January 10, 2015 to Philip Barden and Ross 6 Gow. The statement you had before you 7 earlier, that, if you can pull that in front 8 of you, the one page press release that you 9 gave. You might know from memory. 10 Was the press release that you 11 issued with the statement about Virginia 12 issued in or around January 2, 2015? 13 A. As best as I can recollect. 14 Q. I want to turn your attention to 15 the document I just handed you which is Bates 16 No. 001044, from you to Philip Barden and 17 Ross Gow. It says in the first sentence, I'm 18 out of my depth to understand defamation, 19 other legal hazards and I don't want to end 20 up in a lawsuit aimed at me from anyone, if I 21 can help it. Apparently, even saying 22 Virginia is a liar has hazards. 23 You knew at the time you called 24 Virginia a liar in early January of 2015 that 25 that was something that would result in a Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 362 of 465 Page 362 1 G Maxwell - Confidential 2 lawsuit, is that correct? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I have legal advice that I took. 6 Q. But you knew in early January by 7 making a statement calling Virginia a liar 8 that you were subjecting yourself to a legal 9 dispute with her? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I took legal advice as to what 13 should be said and not be said and the legal 14 advice that came from the United Kingdom 15 was -- 16 MR. PAGLIUCA: You are not allowed 17 to talk about any legal advice that you 18 got from anybody that's a lawyer. 19 A. Sorry. 20 Q. So is it correct without telling me 21 what you talked to your lawyers about that 22 you knew because this is dated January 10 23 that when you made this statement in early 24 January, January 2 of 2015 you knew that 25 calling Virginia a liar would subject you to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 363 of 465 Page 363 1 G Maxwell - Confidential 2 a legal action, isn't that correct? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. As to what you 5 knew -- whatever she knows would be 6 privileged. 7 MS. McCAWLEY: I'm asking if she 8 knows. I'm not asking her to tell me 9 about her privileged communications. 10 A. All I can say is I asked a question 11 and received legal advice. 12 (Maxwell Exhibit 18, email, marked 13 for identification.) 14 Q. This is an email dated January 15, 15 2015 from Jeffrey Epstein to you? 16 A. Uh-huh. 17 Q. It states in the first line, do you 18 want to come out and say she was the 19 girlfriend during the time? 20 MR. PAGLIUCA: Objection to the 21 form and foundation of the question and 22 actually the word is , there 23 is no vowel in there. 24 MS. McCAWLEY: I was just trying to 25 pronounce it. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 364 of 465 Page 364 1 G Maxwell - Confidential 2 Q. This email reads do you want 3 without a vowel, to come out and say 4 she was the girlfriend during the time. 5 Who was Jeffrey Epstein referring 6 to? 7 A. I believe he was referring to 8 . 9 Q. Why was he asking you if you wanted 10 to come out and say she was the 11 girlfriend? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. The way the press and you were 15 characterizing me is I was with Jeffrey 16 throughout this entire period of time and I 17 was not. 18 Q. Was with Jeffrey during this 19 period of time? 20 A. I believe she was. 21 Q. Did Jeffrey come out and tell the 22 press it was and not you that was with 23 him as he is proposing here? 24 A. I don't believe he did. 25 Q. Did you want him to do that? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 365 of 465 Page 365 1 G Maxwell - Confidential 2 A. No, I didn't ask him to do 3 anything. No. 4 Q. So do you know in January of 2015, 5 was his girlfriend? 6 A. 2015, I have no idea who was his 7 girlfriend in 2015. 8 Q. I'm sorry, you are correct. 9 In the period of 1999 to 2002, was 10 his girlfriend? 11 A. They spent a lot of time together. 12 Q. Did you talk to about going 13 to the press and saying that she was the 14 girlfriend and not you? 15 A. I have never spoken to 16 Q. Was offered any money to 17 make a statement that she was the girlfriend? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I have no idea. I have never 21 spoken to and I don't know anything -- 22 I have no idea. 23 (Maxwell Exhibit 19, email, marked 24 for identification.) 25 Q. That's an email from Jeffrey to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 366 of 465 Page 366 1 G Maxwell - Confidential 2 Maxwell dated January 25, 2015. 3 A. Uh-huh. 4 Q. I will direct your attention to the 5 bottom email which is from you on Saturday 6 January 24, 2015. It says, I would 7 appreciate it if would come out and 8 say she was your girlfriend. I think she was 9 from the end of '99 to 2002. 10 Does that refresh your recollection 11 that you asked Jeffrey to have come 12 out and say she was his girlfriend? 13 A. I'm sure I would loved anybody to 14 come out and say they were with Jeffrey 15 rather than me. 16 Q. Was that an accurate statement you 17 were asking to be made to the press? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. When is this? 21 Q. 2015. The statement is whether she 22 was the girlfriend from '99 to 2002. As the 23 email reads. 24 A. What is your question? 25 Q. My question is, was that an Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 367 of 465 Page 367 1 G Maxwell - Confidential 2 accurate statement you were going to be 3 giving to the press? 4 A. I didn't make the statement and 5 never came out, so it's completely 6 moot. 7 Q. My question is, was it an accurate 8 statement that was the girlfriend from 9 '99 to 2002 or were you just making that up 10 for purposes of deflecting press from you? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. As I said they spent a lot of time 14 together and... 15 Q. Were you also his girlfriend from 16 '99 to 2002? 17 A. I don't if I would have ever 18 characterized myself as his girlfriend, but 19 at that time, was with him as much if 20 not more than I was. 21 Q. I will mark this as Maxwell 20? 22 (Maxwell Exhibit 20, email, marked 23 for identification.) 24 Q. This is an email at the top, it's 25 Bates labled 001060. At the top is a chain Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 368 of 465 Page 368 1 G Maxwell - Confidential 2 from Jeffrey to you on January 11, 2015 and 3 if you look below, I'm going to start at the 4 bottom of that chain which is January 11 at 5 9:15 from Jeffrey and he wrote, Alan, do you 6 have an article coming out in Monday's paper. 7 If so, could you please forward us a copy. 8 Do you know what Alan Jeffrey was 9 referring to there? 10 A. I don't know. 11 Q. If you look up in the email chain 12 do you see an email address from Alan 13 Dershowitz responding to that letter? 14 A. I do. 15 Q. So that would be Alan Dershowitz 16 that Jeffrey was emailing at that time 17 according to this chain, correct? 18 A. It certainly looks like it. 19 Q. The email from Alan to Jeffrey is, 20 Nothing on Monday. I'm working on several 21 possible articles about unfairness in the 22 legal process that allows false charges to be 23 inserted into legal documents with no 24 opportunity to respond. 25 And do you see above that Jeffrey's Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 369 of 465 Page 369 1 G Maxwell - Confidential 2 email to you says, quote, Careful. 3 A. Is that to me or to Alan? 4 Q. Jeffrey to at the top. Why 5 was Jeffrey telling you to be careful? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I have no idea. 9 Q. What was he concerned about with 10 Alan Dershowitz's suggestion in the email 11 below? 12 MR. PAGLIUCA: Objection to form 13 and foundation. 14 A. I can't possibly know. 15 Q. Did you discuss with him why he 16 told you to be careful? 17 A. I had limited contact with him. I 18 don't recall where this goes in the chain, 19 why he was telling me to be careful, I have 20 no idea. 21 Q. Did you respond to this email? 22 A. If you don't have it, I didn't 23 respond. 24 Q. Did you ever delete emails during 25 the period of January of 2015? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 370 of 465 Page 370 1 G Maxwell - Confidential 2 A. I have every email that you asked 3 for in discovery, that I have I gave you. 4 Q. That's not my question. 5 Did you ever delete emails in 6 January of 2015? 7 A. I have not deleted anything that 8 you have asked me for in discovery. I have 9 given you everything that I have. 10 Q. That is not my question, my 11 question is, did you ever delete emails in 12 January of 2015? 13 A. In the normal course of my work, 14 there are emails from spam that I delete. 15 That is the type of email I've deleted. 16 Anything that is material to what you want, I 17 have not deleted. 18 Q. How do you know that? 19 A. Well, anybody that's to do with 20 Jeffrey or Alan or women or anything of which 21 I know you were interested in, of which I 22 have anything I would not have done because I 23 don't want to subject myself to... 24 Q. Have you had your computer 25 forensically copied for purposes of this Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 371 of 465 Page 371 1 G Maxwell - Confidential 2 litigation? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. Has someone made a copy of your 6 computer for purposes of this litigation. 7 A. No. 8 Q. Are you a citizen of the United 9 States? 10 A. I am. 11 Q. Are you also a citizen of England? 12 A. I am. 13 Q. Are you a citizen of any other 14 land? 15 A. TerraMar. 16 Q. That's the name of your charity 17 project that deals with oceans, is that 18 correct? 19 A. Yeah. I'm French as well. 20 Q. Has Jeffrey Epstein funded TerraMar 21 for you? 22 A. He did give some money to TerraMar, 23 yes. 24 Q. How much? 25 A. I believe it was $50,000. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 372 of 465 Page 372 1 G Maxwell - Confidential 2 Q. Earlier today, you said you were in 3 the process of resolving the sale of your 4 town home. Where do you intend to live once 5 your town home is sold? 6 A. That's a good question. I don't 7 have an answer for you yet. 8 Q. You don't have a present plan. Do 9 you intend to live in the United States? 10 A. I don't have a present plan. 11 Q. Are you living outside of your town 12 home right now or are you still there? 13 A. I'm just couch surfing. 14 Q. Has Jeffrey Epstein ever purchased 15 a company for you or put a company in your 16 name? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I have no recollection. 20 Q. Is there a Ghislaine Maxwell 21 corporation, for example? 22 A. No, not that I am aware of that has 23 anything to do with me. There may be with 24 one that someone else owns or started but not 25 one that is related to me. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 373 of 465 Page 373 1 G Maxwell - Confidential 2 MS. McCAWLEY: I'm going to take a 3 short break and make sure to keep it 4 short because I know you wanted to -- I 5 just want to wrap up what we have left. 6 THE VIDEOGRAPHER: It's now 5:49 we 7 are off the record. 8 (Recess.) 9 THE VIDEOGRAPHER: It's now 6:00 10 p.m. and we are back on the record. 11 Q. Ms. Maxwell, do you recall being 12 subpoenaed for a deposition back in 2009? 13 A. I do. 14 Q. Why did you avoid giving your 15 deposition in that case when you were 16 subpoenaed and had the opportunity to tell 17 your side of the story? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. That's not what happened. 21 Q. What happened? 22 A. As I best recall, I was subpoenaed 23 and a date was set for the subpoena and 24 everything was set and I believe it was with 25 Brad Edwards, correct me if I'm wrong, and Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 374 of 465 Page 374 1 G Maxwell - Confidential 2 Brad Edwards failed to show up for the 3 subpoena. 4 Q. So your testimony is Brad Edwards 5 did not show up for the deposition that had 6 been set? 7 A. Correct. 8 Q. Did you give any statement that 9 your mother was ill and, therefore, you 10 couldn't take your deposition and had to 11 leave the country indefinitely? 12 A. That's an entirely separate 13 situation. Brad Edwards was involved in the 14 Rothstein scandal which was a RICO, I 15 believe, you know, is when fake suits were 16 created in Jeffrey's case and Rothstein went 17 to jail for 50 years and Brad Edwards worked 18 for that firm. 19 Q. And Mr. Edwards worked for that 20 firm? 21 A. So when the subpoena came, Brad 22 Edwards was involved with Rothstein in the 23 case so when I was called for subpoena, then 24 and I had a subpoena, date and time set, Brad 25 Edwards went AWAL, meaning he failed to Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 375 of 465 Page 375 1 G Maxwell - Confidential 2 respond to calls and failed to get in touch 3 with my attorneys, even though a date and 4 time was set for the subpoena and so that's 5 what happened to that subpoena. It just 6 didn't happen. 7 Q. We may be talking about two 8 different cases so I will ask the question 9 again. 10 Was there ever a time where you 11 were subpoenaed to sit for a deposition that 12 you could not make it because you said that 13 your mother was ill? 14 A. So that is the same subpoena that 15 Brad Edwards failed to turn up for and then I 16 think five or six months passed between -- a 17 period of time, I can't characterize it 18 exactly, a period of time passed where then 19 he resurfaced and asked for a new subpoena to 20 be -- a new time to be set and because he had 21 contacted the press and done all sorts of 22 things that you guys are familiar with, I 23 believe, it was my lawyer suggested that I 24 should have some sort of protective order and 25 I believe between the time for when Brad Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 376 of 465 Page 376 1 G Maxwell - Confidential 2 Edwards resurfaced after the Rothstein story, 3 when the guy went to jail for 50 years for 4 creating fake cases in Jeffrey's and other 5 people's cases, in between the time when 6 there were -- trying to figure out the 7 protective situation for me, my mother was 8 sick, she is 89, she was 89 at that time so I 9 -- they -- we can all -- we all have parents, 10 so anyone, I don't know how old your parents 11 are but any parent or godparent, any 12 individual who is in the late 80s 90s, we can 13 understand has health issues so my mother's 14 health was deteriorating very rapidly at that 15 time and we had issues at home with who she 16 would talk to and how to manage her, her 17 healthcare situation and so I went home. 18 They were still arguing about the protective 19 order -- 20 Q. Is it your testimony that there was 21 not a date set for your deposition at the 22 time you left to go see your mother? 23 A. I don't believe so. 24 Q. Are you friends with the Clintons? 25 A. I am. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 377 of 465 Page 377 1 G Maxwell - Confidential 2 Q. Did you attend a wedding of Chelsea 3 Clinton a few weeks after the date was set, 4 let's say a few weeks after you left to go 5 see your mother who was ill? 6 A. I don't recall exactly when I left 7 but it was before, a few weeks before -- I 8 don't remember the exact timing of that, so 9 I'm sorry, can you repeat the question? 10 Q. Did you come back to the United 11 States to attend Chelsea Clinton's wedding? 12 A. I attended Chelsea Clinton's 13 wedding but I don't know if I came back 14 specifically for that or not. 15 Q. When we were looking at the flight 16 logs earlier, there was a flight where you 17 ended up in the naval base, I believe it was 18 in China, do you know how you got clearance 19 to land at that naval base? 20 A. I need to have a look at whatever 21 document. 22 Q. It's one of the flight logs, it was 23 on the flight with Clinton when we were 24 talking about you landed at a naval base. I 25 know you are a pilot, do you know what you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 378 of 465 Page 378 1 G Maxwell - Confidential 2 had to do to get clearance to land at that 3 naval base. 4 MR. PAGLIUCA: If you need to look 5 at something to answer the question, you 6 can. If you can't answer the question 7 without looking at something just 8 indicate such. 9 A. Regardless, I wouldn't have any 10 knowledge of that. 11 Q. Was Sarah Kellen traveling with you 12 on the flights you were on with Clinton? 13 A. I would have to look at a document. 14 I wouldn't know if she was on all of them or 15 not. I don't know. 16 Q. Do you recall her being on any of 17 them? 18 A. To the best of my recollection, I 19 think she was. I don't recollect exactly 20 what flight she was on or not. 21 Q. Sarah Kellen was one of the 22 co-conspirators, physically, in the 23 nonconstitution agreement, is that correct? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 379 of 465 Page 379 1 G Maxwell - Confidential 2 A. I have never seen the document but 3 my understanding, I believe, is that she was. 4 Q. Did you ever stay the night ever at 5 Les Wexner's house in Ohio, have you ever 6 stayed the night there? 7 A. In his home in Ohio? 8 Q. Yes. 9 A. I don't believe I did. 10 Q. Are you aware of anybody providing 11 Jeffrey with two 12 year old girls as a 12 birthday present? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. No. 16 Q. Are you aware of anybody ever 17 providing Jeffrey with French girls under the 18 age of 18 as a birthday present? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. No. 22 Q. Do you know whether Jean Luc Brunel 23 provided girls under the age of 18 to Jeffrey 24 for the purposes of sex? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 380 of 465 Page 380 1 G Maxwell - Confidential 2 form and foundation. 3 A. I am un -- the answer is no, I 4 don't know anything about that. 5 Q. Did you ever witness Jean Luc 6 Brunel bringing girls under the age of 18 to 7 any of Jeffrey residences? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I don't recollect Jean Luc coming 11 to the house with girls, period. 12 Q. Do you, when I say house, I'm 13 including the U.S. Virgin Island home. 14 Do you recollect Jean Luc Brunel 15 bringing foreign girls under the age of 18 to 16 the U.S. Virgin Island house? 17 A. I don't recollect anything like 18 that. 19 Q. Do you know how Jeffrey Epstein 20 made his money? 21 A. No. 22 Q. Was Les Wexner or is Les Wexner one 23 of his clients? 24 A. I have no idea. 25 Q. What do you know about the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 381 of 465 Page 381 1 G Maxwell - Confidential 2 relationship between Jeffrey Epstein and Les 3 Wexner? 4 A. Are you talking today? 5 Q. Yes, today. 6 A. I have no idea. 7 Q. Do they have a business 8 relationship? 9 A. I have no idea. 10 Q. Did they have a business 11 relationship during the time that you were 12 working for Jeffrey Epstein? 13 A. I believe in the '90s when I was 14 there they had a business relationship. 15 Q. Did they have any other kind of 16 relationship? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. The only relationship I am aware of 20 is the business relationship. 21 Q. Do you know why Les Wexner sold the 22 New York house or gave the New York house to 23 Jeffrey, if you know? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 382 of 465 Page 382 1 G Maxwell - Confidential 2 A. I know nothing about that 3 transaction. 4 Q. Can you list for me all the girls 5 that you have met and brought to Jeffrey 6 Epstein's house that were under the age of 7 18? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I could only recall my family 11 members that were there and I could not make 12 a list of anyone else because that list -- it 13 never happened that I can think of. 14 Q. I'm talking about the time you were 15 working for Jeffrey Epstein, can you list all 16 girls that you found for Jeffrey Epstein that 17 were under the age of 18 to come work for him 18 in any capacity? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I didn't find the girls. 22 Q. You choose the word. 23 MR. PAGLIUCA: If you have a 24 question ask it, you don't choose the 25 word. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 383 of 465 Page 383 1 G Maxwell - Confidential 2 Q. List all of the girls you met and 3 brought to Jeffrey Epstein's home for the 4 purposes of employment that were under the 5 age of 18? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I've already characterized my job 9 was to find people, adults, professional 10 people to do the jobs I listed before; pool 11 person, secretary, house person, chef, pilot, 12 architect. 13 Q. I'm asking about individuals under 14 the age of 18, not adult persons, people 15 under the age of 18. 16 A. I looked for people or tried to 17 find people to fill professional jobs in 18 professional situations. 19 Q. So Virginia Roberts was under the 20 age of 18, correct? 21 A. I think we've established that 22 Virginia was 17. 23 Q. Is she the -- sorry, go ahead. 24 Is she the only individual that you 25 met for purposes of hiring someone for Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 384 of 465 Page 384 1 G Maxwell - Confidential 2 Jeffrey that was under the age of 18? 3 MR. PAGLIUCA: Objection to form 4 and foundation. Mischaracterizes her 5 testimony. 6 A. I didn't hire people. 7 Q. I said met. 8 A. I interviewed people for jobs for 9 professional things and I am not aware of 10 anyone aside from now Virginia who clearly 11 was a masseuse aged 17 but that's, at least 12 that's how far we know that I can think of 13 that fulfilled any professional capacity for 14 Jeffrey. 15 Q. List all the people under the age 16 of 18 that you interacted with at any of 17 Jeffrey's properties? 18 A. I'm not aware of anybody that I 19 interacted with, other than obviously 20 Virginia who was 17 at this point? 21 (Maxwell Exhibit 21, email, marked 22 for identification.) 23 Q. I'm showing you what's been marked 24 as Maxwell 21, it's an email dated January 25 21, 2015 from Jeffrey to you. Is that, you Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 385 of 465 Page 385 1 G Maxwell - Confidential 2 can take a moment to take a look at it, is 3 that a statement that Jeffrey Epstein wrote 4 for you to be issued to the press? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. The question was? 8 Q. Is this a statement that Jeffrey 9 Epstein wrote for you to be issued to the 10 press? 11 MR. PAGLIUCA: Same objection. 12 A. Is there any other emails that you 13 have that surround this that would allow me 14 to know what -- does this have a context? 15 Q. These were produced by your counsel 16 so the to extent there are emails that 17 surround this, this is what we were given. 18 A. Okay. I don't know whether he 19 wrote this -- obviously he wrote this and 20 sent this to me. I don't know if this is 21 post a phone call we had, I can't recollect 22 exactly. 23 Q. Do you know if this was issued to 24 the press, this statement? 25 A. The only press statement that was Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 386 of 465 Page 386 1 G Maxwell - Confidential 2 issued is the one that you have. 3 Q. When the paragraph refers to you 4 being in a very long term committed 5 relationship with another man, who was that 6 other man? 7 MR. PAGLIUCA: You don't have to 8 answer the question. 9 MS. McCAWLEY: I'm asking the 10 identity of a witness in a statement she 11 is giving. 12 MR. PAGLIUCA: She didn't give the 13 statement. 14 MS. McCAWLEY: Jeffrey is writing 15 to her, I'm asking who is he is 16 referencing to a long term relationship. 17 You are going to refuse to let her 18 answer that question. 19 MR. PAGLIUCA: Yes. 20 MS. McCAWLEY: I would like to 21 state for the record he is refusing to 22 allow her to identify a potential 23 witness in this litigation. So we will 24 be back to get the answer to that 25 question. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 387 of 465 Page 387 1 G Maxwell - Confidential 2 Q. Do you recall when you were 3 traveling with Virginia Roberts that you 4 would be responsible for holding her 5 passport? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I already testified I don't recall 9 traveling with Virginia. 10 Q. Do you recall whether Jeffrey 11 Epstein when he was traveling with a minor, 12 someone under the age of 18, someone would 13 hold their passport? 14 MR. PAGLIUCA: Object to the form. 15 A. I couldn't testify to what Jeffrey 16 did or didn't do. 17 Q. You never observed him gathering a 18 minor's passport and holding it during one of 19 the trips you were on? 20 A. I don't have a recollection of 21 that. 22 Q. Are you familiar with a company 23 called Hyperion Air Inc.? 24 A. I am. 25 Q. Is that a company you are Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 388 of 465 Page 388 1 G Maxwell - Confidential 2 affiliated with? 3 A. No. 4 Q. Is that a company that Jeffrey 5 owns? 6 A. I knew it back in 2001, back when I 7 was working. I have no idea what that is 8 today. 9 Q. What about JEGE, are you familiar 10 with that company, JEGE Inc.? 11 A. I don't recall it. 12 Q. You don't recall? 13 A. It vaguely rings a bell. I don't 14 remember what it relates to. 15 Q. What about J Epstein Virgin Islands 16 Foundation, Inc. 17 Are you familiar with that company? 18 A. No. 19 Q. How did J Epstein & Company, Inc.? 20 A. Again, I don't recall his business 21 names and affiliations. 22 Q. How about NES LLC, are you familiar 23 with that name? 24 A. Again, I think that was one of his 25 businesses, but I don't recall. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 389 of 465 Page 389 1 G Maxwell - Confidential 2 Q. Do you know what that business did? 3 A. I don't. 4 Q. How about New York Strategy Group 5 Inc.? 6 A. I don't know. 7 Q. What about Ghislaine Maxwell 8 Company, are you familiar with that company? 9 A. I never heard of that. 10 Q. Is that a company you are on record 11 as being either a board member of or having a 12 position of authority in? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I've never heard of the business. 16 Q. What negative, unflattering, 17 private or potentially embarrassing 18 information does Jeffrey Epstein know about 19 you? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I imagine none. 23 Q. Does he know, does he have any 24 knowledge of any illegal activity that you've 25 conducted? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 390 of 465 Page 390 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. If you want to ask Jeffrey 5 questions about me, you would have to ask 6 him. 7 Q. Have you ever been involved in any 8 illegal activity in your lifetime? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I can't think of anything I have 12 done that is illegal. 13 Q. Have you ever been arrested? 14 A. I have a DUI in the U.K. a long 15 time ago. 16 Q. Is that the only arrest you have on 17 your record? 18 A. Yes. 19 Q. I will mark as Maxwell 22 this 20 email? 21 (Maxwell Exhibit 22, email, marked 22 for identification.) 23 Q. This is dated January 21, 2015. 24 It's from Jeffrey Epstein to you, forwarding 25 the Guardian and I would like you to look at Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 391 of 465 Page 391 1 G Maxwell - Confidential 2 the chain of emails so you understand the -- 3 have an appreciation for who is on this. 4 It's a three-page document. The bottom of 5 the email appears to be a message from, there 6 is a -- at the very bottom there is the 7 signature block for Ross Gow, who I 8 understand is your press agent and above that 9 there is a message from a John Swaine to Ross 10 Gow. 11 Do you see that? 12 A. Uh-huh. 13 Q. Do you know who John Swaine is? 14 A. I do not. 15 Q. Above that there is a message from 16 Ross Gow to Philip Barden and you and it 17 says, so this isn't getting better, latest 18 from our chums at the Guardian and above that 19 you will see on January 21 an email from you 20 where you wrote, See below. 21 And right above that chain you will 22 see Jeffrey Epstein to you on January 21 and 23 his statement to you is, This will now end 24 but I think a dismissive statement is okay. 25 What did he mean by his statement, Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 392 of 465 Page 392 1 G Maxwell - Confidential 2 This will now end? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I have no idea. 6 Q. Did you discuss with him what he 7 meant by the statement, This will now end? 8 A. I don't recall. 9 Q. Was he taking any action to ensure 10 that, quote, this will now end? 11 A. I have no idea. 12 (Maxwell Exhibit 23, email, marked 13 for identification.) 14 Q. This is an email from, if you look 15 at the chain at the top, you will see it's 16 from you to Jeffrey on January 27 and the 17 email at the bottom of the chain is from 18 Jeffrey to you on January 27. 19 He states, What happened to you and 20 your statement, question mark, question mark. 21 And you put at the top, I have not decided 22 what to do. 23 A. Uh-huh. 24 Q. Why was Jeffrey interested in you 25 making a statement to the press? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 393 of 465 Page 393 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I don't know that he was 5 interested. We made a statement and then I 6 was being advised to make an additional 7 statement and I never did. 8 Q. Was Jeffrey communicating with you 9 regularly on what additional statement you 10 might make? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. No, I've communicated with him very 14 little, as little as possible. 15 Q. Why did you feel you had to keep 16 him informed of statements you were making to 17 the press? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I didn't feel I had to. 21 Q. Then why you were communicating 22 with him about statements you were making to 23 the press? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 394 of 465 Page 394 1 G Maxwell - Confidential 2 A. Insofar as this is the case, it's 3 really all about Jeffrey, it's not a case 4 about me. 5 Q. In 2009, did you direct your 6 lawyer, either directly or indirectly, to 7 tell Brad Edwards that you were unavailable 8 to attend a deposition? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. And this is a 11 privileged communication as I understand 12 the question, what someone said or 13 didn't say to their lawyer. So don't 14 answer the question. 15 Q. Can you answer that question 16 without revealing a privileged communication? 17 A. Can you ask the question again? 18 Q. In 2009, did you direct your lawyer 19 to tell Brad Edwards that you were 20 unavailable to attend a deposition? 21 MR. PAGLIUCA: Same instruction. 22 Q. Did you make any statement in 2009 23 to anybody that you were unavailable to 24 attend a deposition? 25 A. My mother was sick and I don't Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 395 of 465 Page 395 1 G Maxwell - Confidential 2 recall exactly the sequence of events but 3 what sequence of events do exist are -- was 4 handled by my lawyers. 5 Q. What is your understanding of 6 Jeffrey Epstein's nonprosecution agreement? 7 A. I have no idea. 8 Q. Do you have an understanding of the 9 co-conspirators listed in the nonprosecution 10 agreement? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I have no knowledge of his 14 agreement, whatever that is. 15 Q. Do you know, you mentioned earlier 16 today that Sarah Kellen was one of the listed 17 co-conspirators. 18 Do you know who the other 19 co-conspirators are in the nonprosecution 20 agreement? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I do not know. 24 Q. What did Jeffrey Epstein tell you 25 about the nonprosecution agreement? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 396 of 465 Page 396 1 G Maxwell - Confidential 2 A. I don't think I've ever discussed 3 it with him. 4 Q. How did you come to learn that 5 Sarah Kellen was covered by the 6 nonprosecution agreement? 7 A. I believe I read it in the press. 8 Q. Did you have any discussions with 9 Sarah Kellen with about the nonprosecution 10 agreement? 11 A. I have not had any discussions with 12 Sarah. 13 Q. When is the last time you spoke to 14 Sarah Kellen? 15 A. Maybe 2005, 2006 maybe. 16 Q. And same with Nadia Marcinkova, 17 when is the last time you recall speaking 18 with Nadia Marcinkova? 19 A. Probably even more time before 20 that, maybe -- I've never had communications 21 really with Nadia. 22 Q. I'm sorry, I didn't hear that. 23 A. I never had communications with 24 her. 25 Q. You were working for Jeffrey at the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 397 of 465 Page 397 1 G Maxwell - Confidential 2 same time Nadia was also working for Jeffrey, 3 isn't that correct? 4 A. I didn't know what Nadia did for 5 Jeffrey so I didn't characterize what her 6 relationship or work or not was and I was 7 still helping him with his construction 8 projects and the like but I never crossed 9 paths with Nadia. 10 Q. What did you think Nadia was doing 11 for Jeffrey? 12 A. I have no idea what Nadia was doing 13 for Jeffrey. 14 Q. Did you observe Nadia at any of 15 Jeffrey's houses while you were there? 16 A. She was at the house on occasion. 17 Q. What would she be doing there? 18 A. I have no idea. 19 Q. Did you know if she lived at his 20 houses? 21 A. I have no idea. 22 Q. Did you ever go into a bedroom and 23 see her belongings at one of the houses? 24 A. Not that I recall, no. 25 Q. I'm going to mark this as Maxwell Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 398 of 465 Page 398 1 G Maxwell - Confidential 2 Exhibit 24? 3 (Maxwell Exhibit 24, email, marked 4 for identification.) 5 Q. You can see at the top of the first 6 page which is GM 0001, it's dated January 3, 7 2015 from you to the Duke of York. 8 Is that Prince Andrew who we 9 referred to today? 10 A. Yes. 11 Q. And can you tell me, it says, Have 12 some info. Call me when you have a moment. 13 What is redacted there? 14 A. I don't recall, I'm sorry. 15 Q. Do you know why there is a 16 redaction on this document? 17 A. You would have to confer with my 18 lawyers. 19 Q. What did you discuss on that call? 20 A. I don't have any specific knowledge 21 of that call. 22 Q. So the call is being made on 23 Saturday, January 3, 2015? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 399 of 465 Page 399 1 G Maxwell - Confidential 2 Q. The document states, it's Saturday 3 January 3, 2015. You issued your press 4 release on January 2, 2015. 5 Were you discussing with Prince 6 Andrew the subject of Virginia Roberts during 7 these calls? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I don't know if I spoke to him. 11 Q. I would like you to turn to GM 0002 12 and the bottom chain says Duke of York, 13 Saturday January 3, to re, and he says 14 let me know when we can talk. Got some 15 specific questions to ask you about Virginia 16 Roberts. 17 Do you recall having a conversation 18 with Prince Andrew about Virginia Roberts in 19 or around early January of 2015? 20 A. I don't know if we actually spoke. 21 Q. Did you ever speak to Prince Andrew 22 about Virginia Roberts after you issued your 23 statement on January 2, 2015? 24 A. I know that we did speak at some 25 point but I don't recollect when we spoke. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 400 of 465 Page 400 1 G Maxwell - Confidential 2 Q. What did you talk about? 3 A. Just what a liar she is. 4 Q. What did he say to you? 5 A. What a liar she is. 6 Q. Did he tell you why he thought she 7 was a liar? 8 A. I don't think he told me why she 9 was a liar. The substance of everything that 10 she said was a lie with regard to him. 11 Q. What did you say to him? 12 A. She is a liar. 13 Q. That was the whole conversation, it 14 was you said to him, she is a liar and he 15 said to you she say liar and did you discuss 16 any of the details about what those lies 17 were? 18 A. I don't recollect. 19 Q. Was that only one conversation you 20 had? 21 A. I don't recollect. I don't 22 recollect actually the conversation but other 23 than -- in detail other than we both said she 24 was a liar. 25 Q. Do you regularly communicate with Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 401 of 465 Page 401 1 G Maxwell - Confidential 2 Prince Andrew? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. What do you mean by regularly. 6 Q. Do you email with him once a month, 7 once every two months or text him or call 8 him? 9 A. No, we are not in that type of 10 regular touch. 11 Q. Do you travel with him regularly? 12 A. I don't know, I have traveled with 13 him. We have traveled together but regularly 14 is not a correct characterization. 15 Q. Do you travel with him more than 16 once a year? 17 A. There is no standard. There is no 18 set pattern. The answer to that was no. 19 Q. Have you ever observed him with any 20 underage, any women, female under the age of 21 18, interacting, that's not a child or a 22 family friend, interacting for the purposes 23 of a sexual relationship with that 24 individual? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 402 of 465 Page 402 1 G Maxwell - Confidential 2 form and foundation. 3 A. I've never seen Andrew interact in 4 any way of that nature. 5 Q. Have you ever gone to dinner with 6 him with any individual under the age of 18 7 that's not a family member or friend of yours 8 that is under the age of 18? 9 MR. PAGLIUCA: Objection to form 10 and foundation. 11 A. We've been to dinner all the time, 12 I am not not sure who is at dinner with us, I 13 can't testify to that. 14 Q. Has he ever brought a female under 15 the age 18 that's not a relative of his -- 16 A. He has children. 17 Q. I said not relatives. 18 A. I can't possibly testify to who he 19 comes to dinner with, I wouldn't recall. 20 Q. To your knowledge, has he ever had 21 a relationship with any female under the age 22 of 18 for purposes of a romantic relationship 23 to your knowledge? 24 A. I can't testify to Andrew's 25 relationship. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 403 of 465 Page 403 1 G Maxwell - Confidential 2 Q. You haven't observed that? 3 A. No. 4 Q. Have you talked to Prince Andrew 5 about coming to testify at trial in this 6 case? 7 A. No. 8 Q. When was the last time you 9 communicated with Leslie Wexner? 10 A. 1994, 1995. 11 Q. I believe earlier, did you say that 12 you -- when is the last time you've been to 13 his home in Ohio? 14 A. I said -- you asked me if I stayed 15 the night. 16 Q. I'm asking you a different 17 question. When is the last time you have 18 been to his home in Ohio? 19 A. Roughly the same time, in the 20 middle of the '90s sometime, mid '90s. 21 Q. Not in the years 2000 to 2002? 22 A. Mid '90s. 23 Q. Have you ever communicated with any 24 representative of Leslie Wexner? 25 MR. PAGLIUCA: Objection to the Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 404 of 465 Page 404 1 G Maxwell - Confidential 2 form and foundation. 3 A. I mean I've been to his -- in the 4 mid '90s, I would have communicated with 5 people who worked for him. 6 Q. Have you communicated with Leslie 7 Wexner about this case? 8 A. No. 9 Q. Have you ever seen a topless female 10 at any one of Jeffrey Epstein's properties? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. You've asked this 13 question, by the way, earlier on today. 14 A. Again, I testified that there are 15 people who from time to time in the privacy 16 of a swimming pool have maybe taken a bikini 17 top off or something but it's not common and 18 certainly when I was at the house I don't 19 really recollect seeing that kind of 20 activity. 21 Q. Have you ever smoked cigarettes? 22 A. Yes. 23 Q. Have you ever smoked cigarettes 24 with Virginia Roberts? 25 A. I don't recall smoking cigarettes Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 405 of 465 Page 405 1 G Maxwell - Confidential 2 with Virginia Roberts. 3 Q. I'm marking this as Maxwell 25. 4 (Maxwell Exhibit 25, email, marked 5 for identification.) 6 Q. I'm showing you what has been 7 marked as Maxwell 25. 8 This is an email dated January 11, 9 2015 at the top? 10 Do you see that that from Jeffrey 11 to you? 12 A. Uh-huh. 13 Q. And then below there is an email 14 from Philip Barden to you and cc'ing Ross Gow 15 on January 11, 2015. 16 Do you see that? 17 A. Uh-huh. 18 Q. It says, Dear Ghislaine, as you 19 know I have been working behind the scenes 20 and this article comes from that. It helps 21 but doesn't answer the VR claims. I will get 22 the criminal allegations out. This shows the 23 MOS will print truth, not just a VR voice 24 piece. We can only make the truth by making 25 a statement. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 406 of 465 Page 406 1 G Maxwell - Confidential 2 What did he mean when he said, I 3 will get the criminal allegations out, what 4 was he referring to? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I have no idea. 8 Q. Were there criminal allegations 9 about Virginia that either your lawyer or 10 press agent were leaking to the press? 11 MR. PAGLIUCA: Objection to form 12 and foundation. 13 A. I have no idea. 14 Q. Did you ask him what he meant when 15 he said, I will get the criminal allegations 16 out? 17 A. I don't recollect the conversation. 18 Q. Did you direct him to leak to the 19 press criminal allegations about Virginia 20 Roberts? 21 A. I already testified that I have no 22 knowledge of what you are asking me. 23 Q. Were you copied on this email, 24 correct? 25 A. I was. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 407 of 465 Page 407 1 G Maxwell - Confidential 2 Q. Did Jeffrey Epstein assist in 3 obtaining information about criminal 4 allegations relating to Virginia Roberts? 5 MR. PAGLIUCA: Objection to form 6 and foundation. 7 A. I have no recollection. 8 Q. Did Alan Dershowitz assist in 9 obtaining information regarding criminal 10 allegations of Virginia Roberts? 11 MR. PAGLIUCA: Objection to form 12 and foundation. 13 A. I have no knowledge of that. 14 Q. Did you ever discuss that with Alan 15 Dershowitz? 16 A. Discuss what? 17 Q. Criminal allegations about Virginia 18 Roberts. 19 A. I don't believe I have. 20 Q. Have you ever discussed allegations 21 relating to -- 22 Q. Do you know if Jeffrey Epstein had 23 any relationship with the U.S. government 24 either working for the CIA or the FBI in his 25 lifetime? Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 408 of 465 Page 408 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I have no knowledge of that. 5 Q. Do you know if Jeffrey Epstein has 6 any friends that are in the CIA or FBI? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I have no idea. 10 Q. Are you aware of an investigation 11 of Jeffrey Epstein in the early '80s relating 12 to the SEC? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I have no knowledge of that. 16 Q. Are you aware that Jeffrey Epstein 17 has told people that he worked for the 18 government to recover stolen funds? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I don't recall conversations about 22 that. 23 Q. Has he ever told that you he worked 24 for the U.S. government? 25 A. I don't recollect that. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 409 of 465 Page 409 1 G Maxwell - Confidential 2 Q. You don't recollect or has he never 3 told you that? 4 A. I have no knowledge, I don't 5 recollect him telling me he worked for the 6 government. 7 Q. Does Jeffrey Epstein have any 8 affiliation with the Israeli government? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I have no knowledge of that. 12 Q. Do you know if he ever performed 13 any work for the Israeli government? 14 A. I have no knowledge of that. 15 Q. Have you ever visited Israel with 16 Jeffrey Epstein? 17 A. I'm sorry, I don't recollect. 18 Q. You've seen the flight logs that I 19 provided you today. Are there, during the 20 time you worked for Jeffrey Epstein, were 21 there times that you flew on commercial 22 flights rather than Jeffrey Epstein's planes? 23 A. Yes. 24 Q. How often did that occur? 25 A. Decently. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 410 of 465 Page 410 1 G Maxwell - Confidential 2 Q. Were there other flights that you 3 recall flying on with Jeffrey Epstein that 4 were on flights that -- where Dave Rogers was 5 not the pilot? 6 A. Dave Rogers was not always the 7 pilot. 8 Q. How many planes did Jeffrey Epstein 9 have during the time you were with him? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. So you need to give me a date 13 range. 14 Q. During the time period of 1992 15 through when you left your employment which I 16 think you said was in 2009? 17 A. So in the '90s he had one plane and 18 at some point in the 2000s he had two planes 19 but I can't testify to anything past 2002, 20 2003, what happened to his planes after that. 21 Q. Do you know what travel agency, if 22 any, Jeffrey would use when he would send 23 someone, for example, you or one of his other 24 employees on a flight somewhere? Did he use 25 a particular travel agency to make those Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 411 of 465 Page 411 1 G Maxwell - Confidential 2 arrangements? 3 A. I don't recall. 4 Q. Were you ever responsible for 5 making those arrangements for other 6 individuals? 7 A. I don't recall making flight 8 arrangements. 9 Q. Was it a New York travel agent that 10 you would use for those arrangements? 11 A. Again, we are talking 16, 17, 18 12 years. I just don't recall anything to do 13 with travel agents. 14 Q. Would Jeffrey Epstein ever fly, for 15 example, Sarah Kellen on a commercial flight 16 to meet you in New Mexico? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I can't testify to that. 20 Q. Do you recall a trip where you met 21 Sarah Kellen in New Mexico? 22 A. No, I don't recall any specific 23 trip, no. 24 Q. Why would you be sent to New 25 Mexico, is there a reason why you would go Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 412 of 465 Page 412 1 G Maxwell - Confidential 2 there in the course of the work you were 3 doing for Jeffrey? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I was never sent. I had a job to 7 do and I would have to go to New Mexico for 8 work. 9 Q. Would Sarah Kellen assist in that 10 project? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. No. The project was largely 14 complete, largely complete by the end -- I 15 don't remember the dates exactly but it was 16 largely complete by the 1990s, 2000s. 17 Q. Do you know why Sarah Kellen would 18 be going to New Mexico to meet you? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I don't know. She worked for 22 Jeffrey. 23 MR. PAGLIUCA: I think we are out 24 of time, counsel. 25 THE VIDEOGRAPHER: It's true. Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 413 of 465 Page 413 1 G Maxwell - Confidential 2 MS. McCAWLEY: I will state for the 3 record there were questions today that 4 remain unanswered because the witness 5 has been instructed not to answer those 6 questions and we will be raising our 7 objections with the court to be able to 8 have those questions answered in the 9 near future. 10 MR. PAGLIUCA: So we are clear, we 11 are designating this entire deposition 12 as confidential under the protective 13 order. That would cover the paralegal 14 whose been present as well as the court 15 reporter and the videographer and all 16 the lawyers in the room. 17 THE VIDEOGRAPHER: This concludes 18 today's proceedings. We are off the 19 record at 6:43 p.m. 20 (Time noted: 6:43 p.m.) 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 414 of 465 Page 414 1 2 - - - 3 I N D E X 4 - - - 5 6 GHISLAINE MAXWELL PAGE 7 By Ms. McCawley 4 8 9 - - - 10 E X H I B I T S 11 - - - 12 MAXWELL EXHIBIT PAGE 13 Exhibit 1 police report 24 14 Exhibit 2 email 33 15 Exhibit 3 transcript 71 16 Exhibit 4 photo 109 17 Exhibit 5 photo 113 18 Exhibit 6 flight logs 117 19 Exhibit 7 photo 133 20 Exhibit 8 photo 143 21 Exhibit 9 message pad pages 147 22 Exhibit 10 email 209 23 Exhibit 11 photo 259 24 Exhibit 12 documents 263 25 Exhibit 13 documents 312 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 415 of 465 Page 415 1 2 MAXWELL EXHIBIT PAGE 3 Exhibit 14 email 345 4 Exhibit 15 email 348 5 Exhibit 16 email 348 6 Exhibit 17 email 361 7 Exhibit 18 email 363 8 Exhibit 19 email 365 9 Exhibit 20 email 367 10 Exhibit 21 email 384 11 Exhibit 22 email 390 12 Exhibit 23 email 392 13 Exhibit 24 email 398 14 Exhibit 25 email 405 15 16 17 18 19 20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 416 of 465 Page 416 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that the witness, 6 GHISLAINE MAXWELL, was duly sworn by me and 7 that the deposition is a true record of the 8 testimony given by the witness. 9 10 _______________________________ 11 Leslie Fagin, Registered Professional Reporter 12 Dated: April 22, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporter.) 20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 417 of 465 Page 417 1 2 ACKNOWLEDGMENT OF DEPONENT 3 I, , do hereby 4 certify that I have read the foregoing pages, and that the same is a correct transcription 5 of the answers given by me to the questions therein propounded, except for the 6 corrections or changes in form or substance, if any, noted in the attached Errata Sheet. 7 8 9 GHISLAINE MAXWELL DATE 10 11 Subscribed and sworn to before me this 12 day of , 2016. 13 My commission expires: 14 Notary Public 15 16 17 18 19 20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1335-1 Filed 01/09/24 Page 418 of 465 Page 418 1 2 - 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- - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 2 of 73 Confidential 2 (Pages 2 to 5) Page 2 1 2 APPEARANCES: 3 On Behalf of the Plaintiff: 4 BOIES SCHILLER & FLEXNER, LLP 333 Main Street 5 Armonk, New York 10504 BY: DAVID BOIES, ESQUIRE 6 BOIES SCHILLER & FLEXNER,LLP 7 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 8 BY: MEREDITH SCHULTZ, ESQUIRE SIGRID McCAWLEY, ESQUIRE 9 SANDRA PERKINS, PARALEGAL 10 FARMER JAFFE WEISSING EDWARDS FISTOS & 11 LEHRMAN, P.L. 425 N. Andrews Avenue 12 Fort Lauderdale, Florida 33301 BY: BRAD EDWARDS, ESQUIRE 13 14 PAUL G. CASSELL, ESQUIRE 383 South University Street 15 Salt Lake City, Utah 84112 16 J. STANLEY POTTINGER, PLLC 17 49 Twin Lakes Road South Salem, New York 10590 18 BY: STAN POTTINGER, ESQUIRE 19 On Behalf of Defendant: 20 HADDON MORGAN FOREMAN 21 Attorneys for Defendant 150 East 10th Avenue 22 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 23 LAURA A. MENNIGER, ESQUIRE 24 Also Present: 25 Page 3 1 2 THE VIDEOGRAPHER: This is DVD No. 3 1, Volume II, of the continued video 4 recorded deposition of Ghislaine Maxwell 5 in the matter Virginia Giuffre against 6 Ghislaine Maxwell, in the United States 7 District Court, Southern District of New 8 York. 9 This deposition is being held at 10 575 Lexington Avenue, New York, New 11 York, on July 22, 2016 at approximately 12 9:04 a.m. 13 My name is Rodolfo Duran. I am the 14 legal video specialist. The court 15 reporter is Leslie Fagin, and we are 16 both in association with Magna Legal 17 Services. 18 Will counsel please introduce 19 themselves. 20 MR. BOIES: This is David Boies, of 21 Boies, Schiller & Flexner, counsel for 22 plaintiff. 23 MS. SCHULTZ: Meredith Schultz, 24 from Boies Schiller & Flexner, counsel 25 for plaintiff. Page 4 1 2 MR. EDWARDS: Brad Edwards, also 3 representing the plaintiff, Virginia 4 Giuffre. 5 MR. POTTINGER: Stan Pottinger, 6 also representing the plaintiff. 7 MR. CASSELL: Paul Cassell, from 8 Salt Lake City, Utah, also representing 9 Ms. Giuffre. 10 MR. PAGLIUCA: Jeff Pagliuca and 11 Laura Menninger, on behalf of Ms. 12 Maxwell. 13 And Ms. McCawley has also entered 14 the room, and we have an assistant from 15 Boies Schiller from the Fort Lauderdale 16 office here today as well today. 17 THE VIDEOGRAPHER: Will the court 18 reporter please swear in the witness. 19 G H I S L A I N E M A X W E L L, 20 called as a witness, having been duly 21 sworn by a Notary Public, was 22 examined and testified as follows: 23 EXAMINATION BY 24 MR. BOIES: 25 Q. Good morning, Ms. Maxwell. Page 5 1 G. Maxwell - Confidential 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 3 of 73 Confidential 3 (Pages 6 to 9) Page 6 1 G. Maxwell - Confidential 2 3 Page 7 1 G. Maxwell - Confidential 2 3 Page 8 1 G. Maxwell - Confidential 2 22 MR. PAGLIUCA: Object to the form 23 and foundation. 24 MR. BOIES: Excuse me, counsel. 25 MR. PAGLIUCA: I'm objecting to Page 9 1 G. Maxwell - Confidential 2 form and foundation, and I have an 3 opportunity to do that. 4 MR. BOIES: Yes, you do, but you do 5 not have an opportunity to disrupt the 6 deposition. 7 MR. PAGLIUCA: Which I'm not. 8 MR. BOIES: The court will decide 9 that, as the court has decided the 10 issues before. 11 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 4 of 73 Confidential 4 (Pages 10 to 13) Page 10 1 G. Maxwell - Confidential 2 Page 11 1 G. Maxwell - Confidential 2 Page 12 1 G. Maxwell - Confidential 2 Page 13 1 G. Maxwell - Confidential 2 . 3 6 Q. You understand that you are under 7 oath, correct? 8 A. I do. 9 Q. And you understand that the oath 10 requires you to tell the truth, the whole 11 truth and nothing but the truth in response 12 to questions? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 Q. Do you? 16 A. I do understand that. 17 Q. Do you understand if you fail to do 18 that, that you could be prosecuted for 19 perjury? 20 MR. PAGLIUCA: Object to the form 21 and foundation. 22 A. I understood that is what happens 23 at these events. 24 Q. And do you understand that if you 25 say that you do not recall and in fact you do I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 5 of 73 Confidential 5 (Pages 14 to 17) Page 14 1 G. Maxwell - Confidential 2 recall, that would violate your oath? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 A. If I don't recall, I don't recall. 6 It's not a question of whether I'm violating 7 my oath or not. I don't know. Page 15 1 G. Maxwell - Confidential 2 Page 16 1 G. Maxwell - Confidential 2 23 Q. Were you ever on a plane with 24 Mr. Epstein when Mr. Epstein had sex with 25 anyone? Page 17 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. How would I know? 5 Q. Were you ever on a plane with 6 Mr. Epstein when, to your knowledge, 7 Mr. Epstein had sex with anyone? 8 A. Can you repeat the question? 9 Q. Were you ever on a plane with 10 Mr. Epstein when, to your knowledge, 11 Mr. Epstein had sex with anyone? 12 A. Not that I can recall. 13 Q. Were you ever on a plane with 14 Mr. Epstein when you saw Mr. Epstein having 15 sex with anyone? 16 A. Never. 17 Q. I want to be sure that the question 18 and answer is meeting. When you refer to 19 having sex with someone, what are you 20 referring to? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 A. Intercourse. 24 Q. And when you refer to intercourse, 25 what do you refer to? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 6 of 73 Confidential 6 (Pages 18 to 21) Page 18 1 G. Maxwell - Confidential 2 A. I think everyone here can 3 understand what intercourse is, is when you 4 have sex. I don't know how to say 5 intercourse any other way, having sex with 6 somebody. Perhaps you would like to define 7 it for me. 8 Q. I'm trying to get your definition 9 right now because you are the witness. When 10 you use the term intercourse, what are you 11 referring to? 12 A. I'm referring to a penis entering 13 someone's vagina. 14 Page 19 1 G. Maxwell - Confidential 2 Page 20 1 G. Maxwell - Confidential 2 11 MR. PAGLIUCA: I'm going to 12 instruct you not to answer, unless you 13 tie it to a specific individual related 14 to this case per the court's order. 15 MR. BOIES: I think the court's 16 order specifically permits this question 17 with respect to occasions related to 18 this case. If you instruct her not to 19 answer, all you're going to do is bring 20 her back. That's up to you. 21 MR. PAGLIUCA: It's up to you as 22 the questioner, Mr. Boies. Page 21 1 G. Maxwell - Confidential 2 6 You haven't tied your question to 7 time or individual or specific location. 8 And so unless you do that, we have an 9 open-ended question that would span from 10 the early '90s to 2000 or so, which 11 would not be tied to the key events, 12 individuals or locations of this case. 13 BY MR. BOIES: 14 Q. Let me ask you a couple more 15 questions. Then I think we probably ought to 16 call the court and get some guidance on this. 17 24 Q. Were you ever on Mr. Epstein's 25 plane when, to your knowledge, Mr. Epstein I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 7 of 73 Confidential 7 (Pages 22 to 25) Page 22 1 G. Maxwell - Confidential 2 had oral sex with anyone 3 A. No. 4 Page 23 1 G. Maxwell - Confidential 2 . 4 MR. BOIES: I will show you a 5 document we have marked for 6 identification as Maxwell Deposition 7 Exhibit 26. 8 (Maxwell Exhibit 26, List of names, 9 marked for identification, as of this 10 date.) 11 Q. I would like you to go down this 12 list and tell me which names, if any, you 13 recognize on this list. 14 A. Just in the way the list runs in 15 order, I recognize the names -- by recognize, 16 only stating that I know the name, I'm not 17 making any representations about these 18 people. 19 Q. I understand that, and I will come 20 back and ask you, but if you don't recognize 21 the name... 22 A. . Virginia Roberts. 23 And that's it on this list. Let me just 24 double-check. I recognize the name, not 25 because I know her, but just because of the Page 24 1 G. Maxwell - Confidential 2 court case on this list, one other person. 3 Q. Which one is that? 4 A. Haley Robson, because she has been 5 on the court papers. 6 Q. Haley who? 7 A. Robson. 8 The only two I know is and 9 Virginia, and one other name I recognize. 10 Q. So just to be clear, the only two 11 people listed on Maxwell Deposition Exhibit 12 26 that you know are 13 A. And Virginia Roberts, yes. 14 Q. And the only other person on -- 15 A. I don't know her, I recognize her 16 name. 17 Q. -- whose name you recognize is 18 Haley Robson, but you don't know her, never 19 met her? 20 A. I don't recall ever meeting her. 21 Q. Other than what you know from her 22 participation in this case, you don't know 23 anything about her, is that your testimony? 24 A. I don't even know -- I don't even 25 recognize what her participation is in this Page 25 1 G. Maxwell - Confidential 2 case. I just know I recognize her name, and 3 I can't recall right now what her involvement 4 is, but I recognize the name. 5 Q. Other than whatever her involvement 6 in this case may be or may not be? 7 A. Correct. 8 Q. Is it fair to say it is your 9 testimony that except for that, you have no 10 knowledge about her at all? 11 A. Correct. 12 Q. And other than , 13 Virginia Roberts and Haley Robson, you don't 14 know anything at all about any of the other 15 people listed here, is that your testimony? 16 A. I don't even know who they are. 17 You could put any names in front of me, I 18 wouldn't recognize them, I don't know them, I 19 don't even recognize the names. 20 Q. I think this is clear from your 21 last answer, but I want to be sure. It is 22 your testimony that other than 23 and Virginia Roberts, you never met any of 24 these people at any homes of Mr. Epstein, is 25 that your testimony? 1111 I - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 8 of 73 Confidential 8 (Pages 26 to 29) Page 26 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. I don't even know who they are, so 5 I wouldn't -- I have no clue who they are, I 6 don't know where they are, I don't know where 7 they come from, I don't recognize -- I only 8 pointed out Haley Robson because I recognize 9 the name from various documents I read. I 10 don't have any knowledge of any other person 11 on this list. I don't believe I've ever even 12 seen these names. I don't know who they are 13 at all. 14 I would not be able to identify a 15 single name on this list other than those 16 three that I have indicated to you. 17 Page 27 1 G. Maxwell - Confidential 2 5 Q. Did you provide massages to 6 Mr. Epstein? 7 A. No. 8 Q. What? 9 A. No. 10 Q. Were you ever present when anyone 11 provided a massage to Mr. Epstein? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. I have seen people give Mr. Epstein 15 massages. I have seen him on a massage 16 table. I have seen that. 17 Q. Have you seen someone other than 18 yourself give Mr. Epstein a massage at his 19 home in New York? 20 A. I can't recall seeing him in the 21 massage room in New York, no. 22 Q. I'm not asking whether you recall 23 seeing him in the massage room in New York. 24 I'm asking you whether you have ever seen 25 someone other than yourself give Mr. Epstein Page 28 1 G. Maxwell - Confidential 2 a massage at his home in New York, regardless 3 of where in the home it was? 4 A. No. 5 Q. Have you ever seen anyone give 6 Mr. Epstein a massage at his home in Palm 7 Beach? 8 A. I have. 9 Q. Have you ever seen anyone give 10 Mr. Epstein a massage in New Mexico? 11 A. No, I can't recall. 12 Q. Have you ever seen anyone give 13 Mr. Epstein a massage in the Virgin Islands? 14 A. I have. 15 Q. Have you ever seen anyone give 16 Mr. Epstein a massage in Paris? 17 A. No, I don't recall seeing that. 18 Q. Have you ever seen anyone give 19 Mr. Epstein a massage on an airplane? 20 A. No. 21 Q. Have you ever seen anyone give 22 Mr. Epstein a massage anywhere other than his 23 home in Palm Beach or in the Virgin Islands? 24 A. I'm sorry, can you just repeat the 25 question? Page 29 1 G. Maxwell - Confidential 2 Q. Have you ever seen anyone give 3 Mr. Epstein a massage anywhere other than in 4 his home in Palm Beach or in the Virgin 5 Islands? 6 A. No, I can't think of anyplace. 7 Q. Have you ever seen anyone give 8 Mr. Epstein a massage when Mr. Epstein was 9 not clothed? 10 A. Sorry, can you repeat the question? 11 Q. Have you ever seen anyone give 12 Mr. Epstein a massage when Mr. Epstein was 13 not clothed? 14 A. I think when Mr. Epstein received 15 massages, he never had clothes on. 16 Q. Who did you see give Mr. Epstein a 17 massage? 18 A. I can't recall the "whos" because I 19 don't really remember, but I have seen him 20 receive massages from professional adult 21 masseuses that I have seen him receive 22 massages. 23 Q. When you say professional adult 24 masseuses, what are you referring to? 25 A. I just want to be sure that we I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 9 of 73 Confidential 9 (Pages 30 to 33) Page 30 1 G. Maxwell - Confidential 2 understand that the times I have seen him 3 receive a massage it's been by somebody who 4 is an adult, clearly an older person. I 5 don't know if they're professional, but an 6 older person appearing to be a professional 7 masseuse. 8 Q. What led you to believe that the 9 person giving the massage was a professional 10 masseuse? 11 A. Because the massages that I 12 witnessed looked professional. I don't know 13 how to -- I'm defining it as opposed to the 14 ones from where people ask me inappropriate 15 questions, I couldn't answer, but these are 16 people who would be clothed giving a 17 professional massage, it appeared to be a 18 professional massage, as opposed to any other 19 type of massage. 20 Q. Have you ever had what you refer to 21 as a professional massage? 22 A. I have. 23 Q. Have you ever had what you refer to 24 as a professional massage in any of Mr. 25 Epstein's homes? Page 31 1 G. Maxwell - Confidential 2 A. I have. 3 Q. Did you ever have what you refer to 4 as a professional massage in Mr. Epstein's 5 home in New York? 6 A. I don't recall, but I think I have, 7 but I don't recall. I must have, but I don't 8 recall. 9 Q. Did you ever have what you refer to 10 as a professional massage in Mr. Epstein's 11 home in Palm Beach? 12 A. I did. 13 Q. Did you ever have what you refer to 14 as a professional massage in Mr. Epstein's 15 home in New Mexico? 16 A. I did. 17 Q. Did you ever have what you refer to 18 as a professional massage in Mr. Epstein's 19 home in Paris? 20 A. I did. 21 Q. Did you ever have what you refer to 22 as a professional massage in the Virgin 23 Islands? 24 A. I did. 25 Q. When you had what you referred to Page 32 1 G. Maxwell - Confidential 2 as professional massages, you were clothed or 3 unclothed? 4 A. Unclothed. 5 Q. Completely unclothed? 6 A. Typically when you receive a 7 massage you are not clothed, so I was 8 unclothed, as is the norm in a massage 9 situation. 10 Q. That is, you didn't have any 11 clothes on, is that the case? 12 A. Generally, what happens is you are 13 not wearing any clothes and you have a towel 14 or sheet that covers you while you are 15 receiving the massage, so I would be covered 16 always, but underneath the sheet or towel, I 17 would not be wearing any clothing. 18 Q. Are you saying that the massage was 19 through the sheet? 20 A. Well, in some instances, yes. 21 Q. It is your testimony that when you 22 received what you referred to as professional 23 massages, the masseuse didn't touch your 24 skin, only touched the sheet? 25 MR. PAGLIUCA: Object to the form Page 33 1 G. Maxwell - Confidential 2 and foundation. 3 A. I didn't say that. I said in some 4 instances, some massages are where you don't 5 touch the skin, so I have received massages 6 where I don't get touched, especially if it's 7 just pressure, so it's through a sheet, but I 8 have also received massages where you are 9 touched and the sheet is just there for 10 modesty. 11 Q. Have you ever received what you 12 referred to as a professional massage when 13 anyone else was in the room other than the 14 person that you are referring to as a 15 professional masseuse? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. Can you repeat the question, 19 please? 20 Q. Have you ever received a massage 21 when anyone was in the room other than the 22 person that you refer to as a professional 23 masseuse? 24 MR. PAGLIUCA: Same objection. 25 A. I am entirely possible that in the MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 10 of 73 Confidential 10 (Pages 34 to 37) Page 34 1 G. Maxwell - Confidential 2 course of receiving a massage someone would 3 come in and sit and chat to me while I was 4 getting a massage, a friend would come in. 5 That has happened. 6 Q. Do you recall that happening? 7 A. Not with specificity, I can't think 8 of it actually, but I know that I've had 9 friends come in and we've talked and as I got 10 a massage, that has happened. 11 Q. Have you ever received a massage 12 when Mr. Epstein was present? 13 A. He has entered the room and gave me 14 a message or asked me a question, that has 15 happened. 16 Q. Have you ever received a massage 17 when Mr. Epstein was in the room other than 18 just to come in to give you a message or ask 19 you a question? 20 MR. PAGLIUCA: Object to the form 21 and foundation. 22 A. Not that I recall. 23 Q. Did you ever participate in 24 arranging for anyone to give Mr. Epstein a 25 massage? Page 35 1 G. Maxwell - Confidential 2 A. Part of my duties and my job -- can 3 you repeat the question so I understand, and 4 I give you the right answer exactly. 5 Q. Did you ever participate in 6 arranging for anyone to give Mr. Epstein a 7 massage? 8 A. Part of my professional 9 responsibilities, I did, and I've testified 10 previously, go to spas and other professional 11 areas and received massages from people in 12 these places, and if I felt that person was 13 good or I had had a good massage, I had asked 14 if they do home visits. 15 In that capacity, I had, people did 16 come to the house in that capacity, that I 17 thought were good. 18 Q. Did you ever arrange for anyone to 19 give Mr. Epstein a massage or to come to his 20 home to give him a massage, other than 21 someone who had previously given you a 22 massage? 23 A. Sorry, can you repeat the question? 24 Q. Did you ever arrange for anyone to 25 give Mr. Epstein a massage or to come to his Page 36 1 G. Maxwell - Confidential 2 home to give him a massage, other than 3 someone who had previously given you a 4 massage? 5 A. No, I don't think so. No, I don't 6 think so. 7 Q. Is it your testimony that everyone 8 that you arranged to come to Mr. Epstein's 9 home to give Mr. Epstein a massage was 10 somebody you had already had a massage from? 11 A. No, that is not my testimony. I 12 don't recall -- there were definitely 13 instances where I had a massage and -- so 14 what you are asking me was if anyone came to 15 the house to give him a massage that I had 16 not had a massage from myself? 17 Q. It's a little different than that. 18 A. Okay. 19 Q. You've testified that you arranged 20 for some people to come to Mr. Epstein's home 21 to give him a massage, correct? 22 A. Yes. 23 Q. And at one point, I thought you had 24 testified that before you arranged to have 25 people come to give Mr. Epstein a massage, Page 37 1 G. Maxwell - Confidential 2 you had -- you didn't use the word tested 3 them out, but that you had previously gotten 4 them to give you a massage so that you could 5 see how good they were, is that fair to say? 6 A. If I thought they were -- if I 7 thought it was a good massage, yes, that is 8 my testimony. 9 Q. What I had thought, and what I'm 10 now asking you is that everyone who you 11 arranged to come to Mr. Epstein's home to 12 give him a massage was somebody who you had 13 already had a massage from, is that fair? 14 A. Typically, yes, but that wasn't 15 exclusively. So I know that friends of mine, 16 for instance, would have a masseuse or 17 masseur that they thought was very good, and 18 they said this is a very good person. 19 So it is possible, and I'm pretty 20 sure sometimes on recommendations of other 21 people, that without me having a massage from 22 them, that they may have come to the house. 23 So I could not testify that every single 24 person that came to the house I received a 25 massage from, because that would not be true. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 11 of 73 Confidential 11 (Pages 38 to 41) Page 38 1 G. Maxwell - Confidential 2 Q. Was every person who you arranged 3 to come to Mr. Epstein's house to give a 4 massage someone who either you had already 5 had a massage from or you had a friend who 6 recommended them as a good professional 7 masseuse? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 A. Typically, that is how that would 11 work. 12 Q. Was there ever anyone who you 13 arranged to come to Mr. Epstein's house to 14 give him a massage, someone who you had not 15 previously gotten a massage from yourself or 16 received a recommendation from one of your 17 friends that it was a good professional 18 masseuse? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. I cannot think of anyone that would 22 fit that category. 23 Q. You made a point in a previous 24 answer of referring to people as adult 25 masseuses. Do you recall that? Page 39 1 G. Maxwell - Confidential 2 A. I do. 3 Q. When you refer to someone as an 4 adult masseuse, what are you referring to? 5 A. I think everybody in this room is 6 an adult. 7 Q. I don't necessarily disagree with 8 that, but what I'm asking you, since I can't 9 carry all these people with me every time 10 somebody reads this transcript, is what do 11 you mean by an adult? 12 A. Well, I think an adult is somebody 13 who looks older and professional and is 14 someone who has lived some life and looks 15 like any one of us in this room do, some a 16 little older and some a little younger. 17 Q. You are aware that there are 18 assertions that Mr. Epstein had massages from 19 females under the age of 21? 20 A. I am aware of that. 21 Q. Insofar as you are aware, did 22 Mr. Epstein ever have a massage from anyone 23 under the age of 21? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Page 40 1 G. Maxwell - Confidential 2 A. I know what the allegations are, 3 and I am aware of those, but as to my actual 4 knowledge of somebody under the age of 21, I 5 can't say that I know, I can't think of 6 anybody. I know Virginia has obviously made 7 those claims and she was 17 when he met her, 8 but other than her, I cannot think of 9 anybody. 10 Q. Insofar as you are aware, did 11 Virginia ever give Mr. Epstein a massage? 12 A. I know she said she did and I 13 believe she may have, but I don't ever see 14 her giving him a massage, so I can't say. 15 Q. Leaving aside any information that 16 you have that has come from Virginia in the 17 last decade? 18 A. Right. 19 Q. Going back to the time when 20 Virginia was less than 21, at that period of 21 time, did you believe that Virginia was 22 giving Mr. Epstein massages? 23 A. I do think she was giving him 24 massages. 25 Q. Is it your testimony that the only Page 41 1 G. Maxwell - Confidential 2 female that you had any reason to believe was 3 under 21 who was giving Mr. Epstein massages 4 was Virginia? 5 MR. PAGLIUCA: Object to the form 6 and foundation. 7 A. First of all, I didn't know how old 8 Virginia was, so other than Virginia, so I 9 can't say, but other than -- I was not aware 10 of anybody else, no. 11 Q. You first met Virginia when? 12 A. I don't know. 13 Q. Approximately? 14 A. I believe it was in 2000, but now 15 I'm going off the knowledge that I have, not 16 from memory, so I met her the end of 2000 17 apparently. 18 Q. And when you met Virginia in 2000, 19 how old did you think she was? 20 MR. PAGLIUCA: Object to the form 21 and foundation. 22 A. I didn't think about how old she 23 was. I don't recall the actual meeting of 24 Virginia, so I can't say, but I think she was 25 at least, I thought she was a professional MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 12 of 73 Confidential 12 (Pages 42 to 45) Page 42 1 G. Maxwell - Confidential 2 masseuse as far as I can recall today, so 3 that would have made her, I thought that 4 would have made her, to work in a spa, I 5 didn't think about, and I, I thought she 6 appeared to be a professional masseuse. 7 Q. Remember questions a while ago 8 where you made a big point about people being 9 adult masseuses? 10 A. Right, yeah. 11 Q. When you met Virginia for the first 12 time -- 13 A. Right. 14 Q. -- did you think she was an adult 15 masseuse, as you use that term? 16 A. I don't recall actually meeting 17 Virginia at the time, and in fact, were it 18 not for this case, I'm not sure I would 19 recall her at all. 20 Q. But you do recall knowing Virginia? 21 A. I do, yes. 22 Q. You do recall knowing that Virginia 23 was giving Mr. Epstein massages, correct? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Page 43 1 G. Maxwell - Confidential 2 A. I believe she was, but I can't say 3 for sure. 4 Q. Why do you believe Virginia was 5 giving Mr. Epstein massages? 6 A. Today, because -- but back then. 7 Q. Back then? 8 A. Because at some point she would 9 have been going to the massage room to give 10 massages. 11 Q. Back then, in the period around 12 2000? 13 A. Right. 14 Q. You believed that Virginia was 15 giving Mr. Epstein massages, correct? 16 A. I believe I did, yes. 17 Q. At the time back in the period 18 around 2000 that you believe that Virginia 19 was giving Mr. Epstein massages, how old did 20 you think Virginia was at the time? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 A. I don't believe that I -- I don't 24 know what I thought at the time. It's a long 25 time ago and I just have no idea what I Page 44 1 G. Maxwell - Confidential 2 thought. I really don't recall her, so it's 3 hard for me to testify what I thought about 4 her age at the time. 5 Q. Was Virginia, in the period of 6 around 2000, the youngest person that, as you 7 understood it, was giving Mr. Epstein 8 massages? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 A. Again, I can't testify to her age, 12 but everybody else that I can recall seemed 13 to be again, like I would say, adults. 14 Q. You didn't think Virginia was an 15 adult, did you? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. Like I said, I don't recall her. I 19 don't recall thinking about -- my memory is 20 of adults giving Jeffrey massages, and as I 21 don't really remember Virginia around that 22 time, I don't know what I think. 23 Q. You do remember Virginia, about 24 that time back in the 2000s, giving 25 Mr. Epstein massages? Page 45 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. I barely remember her at all. 5 Q. Whether you barely remember her or 6 not, you do remember that back in the period 7 around 2000, Virginia was giving Mr. Epstein 8 massages, right? 9 MR. PAGLIUCA: Objection to form 10 and foundation. 11 A. Only in the most general terms. It 12 would be somebody who would give him a 13 massage, and that's it. 14 Q. During the period of time back in 15 the period around 2000, when you knew that 16 Virginia was somebody who would give 17 Mr. Epstein a massage, was she somebody who 18 you considered an adult? 19 MR. PAGLIUCA: Objection to form 20 and foundation. 21 A. I didn't consider her at all 22 because she is not somebody that I really 23 interacted with. 24 Q. It is your testimony that Virginia 25 was not somebody that you interacted with, is MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 13 of 73 Confidential 13 (Pages 46 to 49) Page 46 1 G. Maxwell - Confidential 2 that what you're saying? 3 A. I said I didn't really interact -- 4 it's not that I didn't interact with her at 5 all, but not enough for her to make a very 6 strong and lasting impression. 7 Q. Is it your testimony that you 8 interacted with Virginia, but you didn't 9 really interact with Virginia? 10 MR. PAGLIUCA: Objection to form 11 and foundation. 12 A. I don't understand what that 13 actually even means. 14 Q. You said that you interacted with 15 Virginia. Do you recall that? 16 A. In the most general terms, I do 17 recall her. 18 Q. And then you testified that you 19 didn't really interact with Virginia. Do you 20 recall saying that? 21 A. I consider this a real interaction. 22 I will not be forgetting this any time soon. 23 But the most casual of relationships, where 24 you say hello or to be nice or polite, or 25 offer someone a glass of water or something Page 47 1 G. Maxwell - Confidential 2 is what I would term a casual interaction. 3 It is not something that, from what are we 4 talking, 17, 18 years ago, something that 5 really sticks out in my mind. 6 Q. Is it your testimony that your only 7 relationship with Virginia was what you 8 referred to as a casual relationship where 9 you might say hello or offer a glass of water 10 to be polite? 11 MR. PAGLIUCA: Objection to form 12 and foundation. 13 A. Generally, yes, that's how I would 14 characterize. 15 MR. PAGLIUCA: We've been going for 16 about an hour. I would like to take a 17 break. 18 MR. BOIES: Certainly. 19 THE VIDEOGRAPHER: The time is 20 10:01 a.m., and we are going off the 21 record. 22 (Recess.) 23 THE VIDEOGRAPHER: The time is 24 10:10 a.m., and we are back on the 25 record. This also begins DVD No. 2. Page 48 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: We've been going for 3 about an hour this morning. I think 4 you're probably aware that Ms. Maxwell 5 was deposed for a full seven hours on a 6 prior occasion. In my view, the court's 7 order is limited and we shouldn't be 8 covering ground that we covered in the 9 prior deposition. 10 At some point, we are going to need 11 to call the court, if we go at this 12 pace, for instruction about length of 13 time here, because my view is that this 14 is not supposed to be a seven-hour 15 deposition, you are not supposed to be 16 covering old ground, and you should be 17 asking questions related to the, what I 18 characterize as the eight discreet areas 19 related to a, quote, sexual activity 20 which precedes all of the eight items in 21 the court's order of July 10th. 22 We spent a lot of time not talking 23 about those issues, and I suggest we get 24 to it or we get the court on the phone 25 for some guidance about timing here. Page 49 1 G. Maxwell - Confidential 2 MR. BOIES: I'm happy to get the 3 court on the phone any time you like. I 4 think the questions clearly relate to 5 sexual activity. 6 MR. PAGLIUCA: How old Virginia 7 Roberts was or not does not relate to 8 sexual activity. Her memory of how old 9 Virginia Roberts may or may not have 10 been does not relate to sexual activity, 11 and it was all asked and answered in the 12 prior deposition. 13 MR. BOIES: Your witness introduced 14 the subject, asserting that all of these 15 people were adults. I didn't ask 16 whether they were adults at that time. 17 I simply asked a general question that 18 was expressly covered by the judge's 19 order. Your client opened the door, 20 volunteered this and made it necessary 21 to do this. 22 I am happy to go to the court any 23 time you want, and I'm happy to go over 24 with the court some of these questions 25 and put it in context for the court with MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 14 of 73 Confidential 14 (Pages 50 to 53) Page 50 1 G. Maxwell - Confidential 2 respect to what the documentary evidence 3 is. I'm happy to do that any time you 4 want. 5 MR. PAGLIUCA: Let's get on with it 6 and ask some questions that are relevant 7 to what the court ordered here. 8 MR. BOIES: I am asking questions 9 that I think are clearly relevant. If 10 you don't think so, I invite you to take 11 it to the court. If not, then let me 12 get on with my questions. Any time that 13 I get to a point where you think you 14 want to stop the deposition and go to 15 the court, I am more than prepared to do 16 that. 17 BY MR. BOIES: 18 Q. Ms. Maxwell, during the break, did 19 you have conversations with anyone? 20 A. My lawyers. 21 Q. What did your lawyers say to you? 22 MR. PAGLIUCA: Don't answer that 23 question. 24 Q. What did you say to your lawyer? 25 MR. PAGLIUCA: Don't answer that Page 51 1 G. Maxwell - Confidential 2 question. 3 Q. Did you ask your lawyer for any 4 legal advice? 5 MR. PAGLIUCA: Don't answer that 6 question. 7 Q. Did your lawyer give you any legal 8 advice? 9 MR. PAGLIUCA: Don't answer that 10 question. 11 MR. BOIES: These are all yes or no 12 questions. 13 MR. PAGLIUCA: She is not answering 14 any of those questions, Mr. Boies. 15 Q. Did your lawyer give you advice as 16 to how to answer the questions I was asking? 17 MR. PAGLIUCA: Don't answer that 18 question. 19 Q. Did your lawyer tell you that you 20 were creating problems for yourself with some 21 of your answers? 22 MR. PAGLIUCA: Don't answer that 23 question. 24 Q. Did your lawyer suggest how you 25 might answer some of my questions? Page 52 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Don't answer that 3 question. 4 Q. Did you have conversations with 5 anyone other than your lawyer during the 6 break? 7 A. No. 8 Q. Did your lawyer tell you why he had 9 taken a break? 10 MR. PAGLIUCA: Don't answer that 11 question. 12 I don't think I did, by the way. 13 MR. BOIES: I'm happy to depose you 14 about it, if you want. 15 MR. PAGLIUCA: Sure. 16 MR. BOIES: I'm serious about that. 17 I'm happy to put you under oath right 18 now, and if you want to start talking 19 about what you did or did not do, I'm 20 happy to interrupt this deposition, put 21 you under oath and let you testify. 22 MR. PAGLIUCA: Ask a question. 23 MR. BOIES: I'm telling you. 24 Otherwise, I suggest you stop making 25 speeches. Page 53 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Why don't we both 3 stop making speeches. 4 BY MR. BOIES: 5 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 15 of 73 Confidential 15 (Pages 54 to 57) Page 54 1 G. Maxwell - Confidential 2 . Page 55 1 G. Maxwell - Confidential 2 Epstein's home in Palm Beach? 3 MR. PAGLIUCA: Objection to form 4 and foundation. 5 Page 56 1 G. Maxwell - Confidential 2 Page 57 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 16 of 73 Confidential 16 (Pages 58 to 61) Page 58 1 G. Maxwell - Confidential 2 21 MR. PAGLIUCA: Objection to form 22 and foundation. 23 Page 59 1 G. Maxwell - Confidential 2 Page 60 1 G. Maxwell - Confidential 2 Page 61 1 G. Maxwell - Confidential 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 17 of 73 Confidential 17 (Pages 62 to 65) Page 62 1 G. Maxwell - Confidential 2 Page 63 1 G. Maxwell - Confidential 2 Page 64 1 G. Maxwell - Confidential 2 Q. You were aware of how many people 3 gave Mr. Epstein massages? 4 MR. PAGLIUCA: Objection to form 5 and foundation. 6 A. I was not with him actually very 7 often. I was frequently -- we were 8 frequently not together, so I couldn't know 9 what he would be doing when I wasn't with 10 him. 11 But when we were together, the 12 behavior as described as alleged did not 13 happen, so he would have one massage a day, 14 that would be it. 15 Q. So insofar as you were aware and 16 when you were with Mr. Epstein, he only had 17 one massage a day? 18 A. Yeah. 19 Q. Other than Virginia Roberts, as you 20 understood it at the time, were any of the 21 people that gave Mr. Epstein massages women 22 who were under 21? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. I don't know what the ages were of Page 65 1 G. Maxwell - Confidential 2 the people who were giving him massages, but 3 I believe they were professional masseuses. 4 Q. I think you testified that you 5 believe that Virginia Roberts was a 6 professional masseuse, is that correct? 7 MR. PAGLIUCA: Objection to form 8 and foundation. 9 A. Based on how allegedly we met, 10 which was at a spa, I believe that when you 11 work at a spa, you are a professional. So 12 I'm basing my statement based on her working 13 as a professional massage person, at a 14 professional spa. 15 Q. When you met Ms. Roberts at the 16 spa, what spa was it? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. I don't recall the actual meeting, 20 but based on all the evidence and stories, it 21 was at Mar-a-Lago. 22 Q. You just testified that you met 23 Virginia Roberts at a spa. Do you recall 24 that? 25 MR. PAGLIUCA: Objection to form MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 18 of 73 Confidential 18 (Pages 66 to 69) Page 66 1 G. Maxwell - Confidential 2 and foundation. 3 A. I said I don't recall the actual 4 meeting, but based on the evidence that we 5 have been produced, and I now believe it was 6 at Mar-a-Lago that that meeting may have 7 taken place. 8 Q. When you met Virginia Roberts, did 9 you understand that she was at that time a 10 professional masseuse? 11 MR. PAGLIUCA: Objection to form 12 and foundation. 13 A. I don't recall the actual first 14 meeting, I don't know. 15 Q. Whether or not you recall the 16 actual first meeting, was it your 17 understanding that Virginia Roberts was a 18 professional masseuse? 19 MR. PAGLIUCA: Objection to form 20 and foundation. 21 A. I had no idea at the time, but I 22 believe she was working at a spa, and based 23 on what I believe today, she was a masseuse 24 at Mar-a-Lago. 25 Q. When you say based on what you Page 67 1 G. Maxwell - Confidential 2 believe today, you believe she was a masseuse 3 at Mar-a-Lago, what is it that you've learned 4 that leads you to believe she was a masseuse 5 at Mar-a-Lago? 6 A. She worked at the spa, and that's 7 all I know, that she was 17 and that she held 8 herself out to be a masseuse. 9 Q. She told you she was a masseuse? 10 A. I don't know if she told me at the 11 time she was a masseuse. I believe today she 12 was a masseuse working at Mar-a-Lago and she 13 was 17 years old. 14 Q. You said she held herself out as a 15 masseuse. Do you recall that? 16 A. I just said it. The problem is I 17 don't recall with specificity. I don't 18 recall the actual meeting, so events in my 19 mind are conflated with all of her stories, 20 all of the lies that have been told. 21 So, today, I believe that she was a 22 17-year-old masseuse at Mar-a-Lago. 23 Q. Did she ever tell you that she was 24 a masseuse at Mar-a-Lago? 25 A. I don't recall specific Page 68 1 G. Maxwell - Confidential 2 conversations with Virginia. Like I said, I 3 would actually barely remember her at all 4 were it not for this case. 5 Q. Why, then, do you believe she was a 6 masseuse at Mar-a-Lago? 7 A. Based on having met her at 8 Mar-a-Lago. I don't know why else she would 9 be at the house. 10 Q. At what house? 11 A. Why would she come to Jeffrey's 12 house if she was not a masseuse at 13 Mar-a-Lago, why else would she come. 14 Q. Did you ask her to come to 15 Jeffrey's house? 16 A. I don't recall the first meeting or 17 how it went down that she came to give 18 Jeffrey a massage or whatever she came to do. 19 All I remember as I testified in my first 20 deposition is that her mother came and that 21 we sat outside and I talked to her mother, 22 and that she went in and met Jeffrey and then 23 she left. And then subsequent to that, I 24 understand she gave him massages. 25 Q. My question was a simple yes or no Page 69 1 G. Maxwell - Confidential 2 question. Did you ask her to come to 3 Jeffrey's house? 4 A. I can't recall exactly the meeting. 5 Q. In response, I got a paragraph that 6 makes a number of assertions that I'm now 7 going to have to follow-up. I'm prepared to 8 do that, but in light of your counsel's 9 desire to move the deposition along, I won't 10 have to follow-up things that you volunteer 11 if you don't volunteer them. 12 So if you will focus on my 13 question, and if it is simply a yes or no 14 answer and you give a yes or no answer, that 15 will shorten the deposition. If you want to 16 say other things, I'm not going to try to 17 stop you, but I am going to follow-up on what 18 you say. 19 My question now is simply, do you 20 recall, one way or the other, as you sit here 21 now, whether you asked Virginia Roberts to 22 come to Mr. Epstein's house? 23 A. I do not. 24 Q. Do you recall, as you sit here now, 25 one way or another, whether Virginia Roberts MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 19 of 73 Confidential 19 (Pages 70 to 73) Page 70 1 G. Maxwell - Confidential 2 was a masseuse, a towel girl, a maintenance 3 person or any other type employee at 4 Mar-a-Lago? 5 A. I do not. 6 Q. Did Mr. Epstein ever ask you to 7 attempt to obtain or secure people to give 8 him massages that were not professional 9 masseuses? 10 A. No. 11 Q. Do you remember somebody by the 12 name of Tony Figueroa? 13 A. I don't believe I ever met him. 14 Q. You don't believe you ever met him? 15 A. No. 16 Q. Do you remember anyone other than 17 yourself who secured or obtained people to 18 give Mr. Epstein massages? 19 MR. PAGLIUCA: Objection to form 20 and foundation. 21 A. Can you ask the question again, 22 please? 23 Q. Do you remember anyone other than 24 yourself who secured or obtained people to 25 give Mr. Epstein massages? Page 71 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. I believe Jeffrey did get massages 5 from other people who were recommendations 6 from other people for massages that had 7 nothing to do with me. 8 Q. Do you know who? 9 A. I only know what I read. Virginia 10 gave people. 11 Q. Other than what Virginia had said 12 in the last 10 years, were you aware of 13 anyone who was obtaining people to give 14 Mr. Epstein massages other than yourself? 15 A. I'm not -- I don't know what other 16 people do. I know that other people 17 recommended massages to him, but I can't 18 testify to what other people do for him or 19 did for him. 20 Q. Back in the 1990s and the 2000s, 21 did you see women under the age of 21 at 22 Mr. Epstein's houses? 23 MR. PAGLIUCA: This has been asked 24 and answered in her prior deposition. 25 Do you understand that? It's been Page 72 1 G. Maxwell - Confidential 2 covered extensively. 3 MR. BOIES: I understand what the 4 prior deposition -- 5 A. Other than friends of my family and 6 friends of other people's people, and the 7 people that I've identified, I am aware that 8 Jeffrey had friends that came over that 9 brought their kids with them from time to 10 time. 11 Q. These kids that you refer to, they 12 didn't give Mr. Epstein massages, did they? 13 MR. PAGLIUCA: Mr. Boies, this has 14 been asked and answered already. 15 MR. BOIES: I don't think that 16 particular question was asked and 17 answered, but whether it was asked and 18 answered or not, you can instruct not to 19 answer and then we will move on. I 20 think we take much more time with your 21 interjections than we would if you 22 simply let the witness answer the 23 question. 24 MR. PAGLIUCA: Well, we do, but 25 then we go down this road where you keep Page 73 1 G. Maxwell - Confidential 2 asking these questions that have already 3 been asked and answered. 4 So the witness can answer the 5 question, but let's stick to the topic 6 here. 7 MR. BOIES: If you want to instruct 8 her not to answer, instruct her not to 9 answer. You are not going to convince 10 me with speeches. 11 A. What is the question, please? 12 Q. You referred to friends of 13 Mr. Epstein bringing their kids with them 14 when they came over? 15 A. Yes. 16 Q. Those kids, as you described, did 17 not give Mr. Epstein massages, correct? 18 A. I don't believe so. 19 Q. Limiting the people that we're 20 talking about just to people who gave 21 Mr. Epstein massages or who were brought to 22 the home to give Mr. Epstein massages, were 23 there people other than you who were 24 responsible for bringing those people to Mr. 25 Epstein's house? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 20 of 73 Confidential 20 (Pages 74 to 77) Page 74 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. I have no idea. 5 Q. Do you know Joanna Sieberg, 6 S-I-E-B-E-R-G? 7 A. No. 8 MR. PAGLIUCA: Showberg (sic)? 9 MR. BOIES: Yes. 10 MR. PAGLIUCA: You said Sieberg. 11 A. I do know Johanna Sieberg. 12 Q. Did Joanna ever give Mr. Epstein a 13 massage? 14 A. I believe she did. 15 Q. Did she ever give you a massage? 16 A. She did. 17 Q. Was she what you referred to as a 18 professional masseuse? 19 A. I would. 20 Q. Had she ever worked in a spa? 21 A. I don't know if she worked in a 22 spa. 23 Q. Had she ever, prior to giving you 24 and Mr. Epstein massages, had she ever given 25 massages to other people? Page 75 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. I have no idea, I don't know. 5 Q. Prior to the time that Joanna gave 6 you and Mr. Epstein massages, had she been a 7 professional masseuse? 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. I believe she went to massage 11 school and became a professional masseuse. 12 Q. Did she go to massage school before 13 or after you met her? 14 A. I believe after. 15 Q. Who paid for her massage school? 16 A. I have no idea. 17 Q. Who arranged for her to go to 18 massage school? 19 A. I have no idea. 20 Q. Did she ever give Mr. Epstein a 21 massage before she went to massage school? 22 A. I have no idea. 23 Q. Did she ever give you a massage 24 before she went to massage school? 25 A. I have no idea. Page 76 1 G. Maxwell - Confidential 2 Q. Where did she go to massage school? 3 A. I don't know. 4 Q. When did she go to massage school? 5 A. I don't know. 6 Q. Did she tell you she went to 7 massage school? 8 A. I don't recall. 9 Q. Did someone else tell you she went 10 to massage school? 11 A. I don't recall. It's my belief she 12 went to massage school and became a 13 professional masseuse at some point. 14 Q. What is your belief based on? 15 A. I don't know why, it's just 16 something, I must have had a conversation 17 with her, I think, about it, but I don't 18 recall specifically the conversation. Just 19 in general terms, that's what I believe. 20 Q. Is it your testimony that she told 21 you in general terms in a conversation that 22 she had gone to massage school? 23 A. I don't recall a specific 24 conversation, but that is my general 25 impression. Page 77 1 G. Maxwell - Confidential 2 Q. Do you know how long she was in 3 massage school? 4 A. I don't. 5 Q. Did Mr. Epstein ask her to go to 6 massage school? 7 A. I don't know. 8 Q. How old was Johanna when she gave 9 you a massage? 10 A. Mid 20s, I believe. 11 Q. And was the timeframe in which she 12 gave Mr. Epstein a massage the same timeframe 13 she gave you a massage? 14 A. I really don't recall. I can only 15 recall her giving me massages. I know she 16 gave Mr. Epstein massages, but I don't recall 17 them. I know she gave me them, I know she 18 gave me massages. 19 Q. How old was she when she gave 20 Mr. Epstein massages? 21 A. I met her, I believe, when she was 22 in her mid 20.s, it would have been in her 23 mid 20s. 24 Q. Did Mr. Epstein, insofar as you 25 believe, engage in sexual activities with MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 21 of 73 Confidential 21 (Pages 78 to 81) Page 78 1 G. Maxwell - Confidential 2 Johanna? 3 A. I would not know. I would say no. 4 Q. Did you engage in sexual activities 5 with Johanna? 6 A. No. 7 Q. Do you know how Johanna came to 8 know Mr. Epstein? 9 A. I met her at her university and she 10 came to answer phones. 11 Q. When you say she came to answer 12 phones, where? 13 A. In Palm Beach. 14 Q. At Mr. Epstein's home in Palm 15 Beach? 16 A. Yes. 17 Q. So is it fair to say that Johanna 18 was initially hired to answer telephones, 19 according to your testimony? 20 MR. PAGLIUCA: This has already 21 been testified to Mr. Boies. We are 22 repeating testimony now. 23 MR. BOIES: I think in the context 24 of the witness' answers, these are fair 25 questions. Page 79 1 G. Maxwell - Confidential 2 Now, I've asked you before, if you 3 want to instruct her not to answer, if 4 you want to go to the judge, we are 5 happy to do that, but I would suggest, 6 in the interest of moving it along, that 7 you stop these speeches. 8 MR. PAGLIUCA: You are not moving 9 it along is the problem, so maybe we 10 should call the court and get some 11 direction here, because I am not going 12 to sit here and rehash the testimony we 13 already gave. 14 MR. BOIES: That's fine. 15 THE VIDEOGRAPHER: The time is 16 10:51 a.m. and we are going off the 17 record. 18 (Whereupon, an off-the-record 19 discussion was held.) 20 THE VIDEOGRAPHER: The time is 21 10:56 a.m. and we are going back on the 22 record. This begins DVD No. 3. 23 MR. BOIES: We have just had a call 24 with Judge Sweet's chambers, Judge Sweet 25 is not available and his chambers Page 80 1 G. Maxwell - Confidential 2 instructed that the right way to do it 3 was to bring any issue to him after the 4 conclusion of the deposition. 5 The question that has been raised 6 is whether we should interrupt the 7 deposition now and seek guidance of the 8 court before continuing the deposition. 9 My view is that the deposition 10 needs to continue, and the counsel for 11 the defendant can instruct not to answer 12 and any questions that are instructed 13 not to answer can be brought to the 14 court, but I would not consent to 15 terminating the deposition at this 16 point. 17 MR. PAGLIUCA: I don't know if it's 18 a matter of consent or not. If I move 19 for a protective order, the deposition 20 is over and we can go litigate it in 21 front of Judge Sweet. We are here and 22 I'd like to complete this deposition 23 because this case needs to move along, 24 and quite frankly, I don't want to spend 25 money coming back here to do this again Page 81 1 G. Maxwell - Confidential 2 or argue this in front of Judge Sweet. 3 But I will simply start referring 4 you back to the transcript and 5 instructing the witness not to answer 6 when I think we are getting into some 7 things that have been asked and answered 8 already. 9 MR. BOIES: Exactly the procedure 10 that I have proposed from the beginning. 11 If you think a question is out of 12 bounds, instruct not to answer and we 13 will then let the judge decide it. 14 BY MR. BOIES: 15 Q. How did it happen, Ms. Maxwell, 16 that Johanna, who had been hired to answer 17 the phones, ended up giving massages to you 18 and Mr. Epstein? 19 MR. PAGLIUCA: I'm going to 20 instruct you not to answer the question. 21 This has been previously, the subject of 22 your former deposition, it doesn't fall 23 into any of the categories ordered by 24 the court, and so you don't need to 25 answer that. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 22 of 73 Confidential 22 (Pages 82 to 85) Page 82 1 G. Maxwell - Confidential 2 Q. Was Johanna paid for the massages 3 that she gave you? 4 A. I didn't pay her, so I believe she 5 was paid. 6 Q. Who paid her? 7 A. I don't know who paid her. 8 MR. PAGLIUCA: Again, you've 9 already answered that there was no 10 sexual activity between yourself and 11 Mr. Epstein related to these massages. 12 That's record testimony today. That's 13 within the scope of the court's order. 14 The rest of this is outside the scope of 15 the court's order, and I instruct you 16 not to answer. 17 MR. BOIES: You are taking the 18 position that as long as she said says 19 that a massage did not involve sexual 20 activity, we cannot ask about massages. 21 That's your view? 22 MR. PAGLIUCA: On this particular 23 questioning, yes. 24 BY MR. BOIES: 25 Q. Did Mr. Epstein pay Johanna for the Page 83 1 G. Maxwell - Confidential 2 massages that she gave Mr. Epstein? 3 MR. PAGLIUCA: You just asked this 4 question, and I told her not to answer. 5 I will tell her not to answer again for 6 the same reasons. 7 Q. Do you know how much Mr. Epstein 8 paid Johanna to give massages? 9 MR. PAGLIUCA: Same instruction to 10 the witness. Why do you believe this is 11 within the scope of the court's order? 12 MR. BOIES: Because of the court's 13 reference to massages, and because I 14 think how much a girl who was hired to 15 answer the phone was paid to give a 16 "massage" goes to whether there actually 17 was or was not sexual activity involved. 18 MR. PAGLIUCA: The witness has 19 testified there wasn't. 20 MR. BOIES: Perhaps it will 21 surprise you, I think it should not, 22 that I do not believe in my deposition I 23 need to simply accept her 24 characterization without 25 cross-examination. Now, that's Page 84 1 G. Maxwell - Confidential 2 something the judge can decide, but a 3 question as to how much this young girl 4 was being paid for a "massage", I think 5 goes directly to the issue of sexual 6 activity. 7 MR. PAGLIUCA: Here is the problem, 8 Mr. Boies, at the first deposition, 9 there were very limited instructions not 10 to answer and the witness was not told 11 not to answer questions about how much 12 people were paid or not paid or any of 13 those subject matters. The witness was 14 only instructed not to answer about 15 sexual activity concerning adults in the 16 home. 17 None of this came up during the 18 deposition, and you just don't get a 19 chance to redo the deposition because 20 you feel like you want to. 21 So the judge's order is in the 22 context of the instructions to the 23 witness not to answer in the first 24 deposition, which is simply sexual 25 activity involving adults, which was the Page 85 1 G. Maxwell - Confidential 2 only area that the witness was precluded 3 from talking about in the first 4 deposition. So that's where we're at. 5 MR. BOIES: I think that directly 6 misreads the judge's order, including 7 where it says: Defendant is ordered to 8 answer questions relating to defendant's 9 own sexual activity with or involving 10 Jeffrey Epstein, with or involving 11 plaintiff, with or involving underage 12 females, involving or including massage 13 with individuals defendant knew to be or 14 believed might become known to Epstein. 15 MR. PAGLIUCA: All of it is 16 preceded by the word sexual activity. 17 MR. BOIES: I think your point of 18 view is an interesting one, but we will 19 see what the judge rules on it. 20 BY MR. BOIES: 21 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 23 of 73 Confidential 23 (Pages 86 to 89) Page 86 1 G. Maxwell - Confidential 2 and foundation. 3 A. 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. I don't know. 11 Q. Did any of them give you massages? 12 A. No. 13 Q. 17 MR. PAGLIUCA: Objection to form 18 and foundation. Asked and answered. 19 A. No. 20 Q. Were they ever in the Virgin 21 Islands? 22 MR. PAGLIUCA: Objection to form 23 and foundation. 24 A. No. 25 Page 87 1 G. Maxwell - Confidential 2 24 MR. PAGLIUCA: Objection to form 25 and foundation. Page 88 1 G. Maxwell - Confidential 2 Page 89 1 G. Maxwell - Confidential 2 I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 24 of 73 Confidential 24 (Pages 90 to 93) Page 90 1 G. Maxwell - Confidential 2 Page 91 1 G. Maxwell - Confidential 2 it to something in the case. 3 MR. BOIES: I think it's tied, but 4 if you instruct her not to answer, it 5 goes into the -- 6 MR. PAGLIUCA: Meat grinder. 7 BY MR. BOIES: 8 Q. . 14 A. Can you repeat the question? 15 Q. 20 MR. PAGLIUCA: Same objection. 21 A. No. 22 Q. Page 92 1 G. Maxwell - Confidential 2 Page 93 1 G. Maxwell - Confidential 2 3 25 Q. Do you know the reporter by the MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 25 of 73 Confidential 25 (Pages 94 to 97) Page 94 1 G. Maxwell - Confidential 2 name of Vicky Hart -- Vicky Ward? 3 A. I do. 4 MR. BOIES: Let me show you a 5 document that has been marked for 6 identification as Maxwell Deposition 7 Exhibit 27. 8 (Maxwell Exhibit 27, Article, 9 marked for identification, as of this 10 date.) 11 MR. PAGLIUCA: I'm going to need a 12 moment to review this, counsel. 13 MR. BOIES: Sure. Let me know when 14 you are finished. 15 MR. PAGLIUCA: I will. 16 Okay. 17 BY MR. BOIES: 18 Q. Did you see this article prior to 19 the time I'm showing it to you? 20 A. No. 21 Q. This is the first time you have 22 seen this article? 23 A. Yes. 24 Q. When did you first meet Vicky Ward? 25 MR. PAGLIUCA: You are not Page 95 1 G. Maxwell - Confidential 2 answering those questions. That has 3 nothing to do with what we're here for 4 today. We will take that up with the 5 judge, if we need to. 6 Q. Let me direct your attention to a 7 portion of this article. Did Vicky Ward ever 8 talk to you about women that she believed 9 Mr. Epstein had had sex with? 10 MR. PAGLIUCA: Don't answer that 11 question. We will take that up with the 12 judge. 13 MR. BOIES: Okay. 14 Q. Did Ms. Ward ever mention to you a 15 Maria Farmer? 16 A. She did. 17 Q. Did Ms. Ward ever mention to you an 18 Annie Farmer? 19 A. She did. 20 Q. When did Ms. Ward mention Maria 21 Farmer to you? 22 A. She called me and asked me, I don't 23 know if she mentioned -- I want to take that 24 back. I don't know if she mentioned Maria 25 Farmer. I think she just mentioned Annie Page 96 1 G. Maxwell - Confidential 2 Farmer. 3 Q. Who was Annie Farmer? 4 A. Annie Farmer was Maria Farmer's 5 sister. 6 Q. Annie Farmer was Maria Farmer's 7 sister? 8 A. Uh-huh. 9 Q. Who was Maria Farmer? 10 A. Maria Farmer was a girl that 11 Jeffrey, I believe, helped. She was an 12 artist, I believe. 13 Q. Did you know Maria Farmer? 14 A. I did. 15 Q. When did you first meet Maria 16 Farmer? 17 A. I don't recall. 18 Q. Did you see Maria Farmer at 19 Mr. Epstein's house in Palm Beach? 20 A. No, I don't think so. 21 Q. Where did you see Maria Farmer? 22 A. I believe I met her in New York at 23 some point. 24 Q. Did you see Maria Farmer at 25 Mr. Epstein's house in New York? Page 97 1 G. Maxwell - Confidential 2 A. I don't recall meeting her there, 3 but -- I may have, but I don't recall. 4 Q. Did you ever meet Annie Farmer? 5 A. I did. 6 Q. Where did you meet Annie Farmer? 7 A. She was in New Mexico. 8 Q. At Mr. Epstein's property in New 9 Mexico? 10 A. Yes. 11 Q. And did Mr. Epstein ever have sex 12 with Annie Farmer? 13 A. I have no idea. 14 Q. Did Mr. Epstein ever engage in 15 sexual activities with Annie Farmer? 16 A. I have no idea. 17 Q. Did Mr. Epstein ever engage in 18 sexual activities with Maria Farmer? 19 A. I don't know, I don't think so. 20 Q. Did Maria Farmer ever work for 21 Mr. Epstein? 22 A. I don't know. 23 Q. Did Maria Farmer ever visit you at 24 your apartment? 25 A. I don't recall her ever coming. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 26 of 73 Confidential 26 (Pages 98 to 101) Page 98 1 G. Maxwell - Confidential 2 Q. Did you ever fly on Mr. Epstein's 3 plane with Maria Farmer? 4 A. I don't remember. 5 Q. Did you ever fly on Mr. Epstein's 6 plane with Annie Farmer? 7 A. I don't think so. 8 Q. Did Maria Farmer ever give 9 Mr. Epstein a massage? 10 A. I don't -- I have no idea. 11 Q. Did Vicky Ward tell you that she 12 had interviewed Maria Farmer? 13 A. I don't recall. 14 Q. What did Vicky Ward tell you about 15 Maria Farmer when she talked to you? 16 MR. PAGLIUCA: You don't have to 17 answer that. That has nothing to do 18 with the court's order and why we are 19 here. 20 Q. Did Vicky Ward tell you she 21 interviewed with Maria Farmer, and Maria 22 Farmer had said that Mr. Epstein had engaged 23 in sexual activities with her? 24 A. She never said that. 25 Q. Excuse me? Page 99 1 G. Maxwell - Confidential 2 A. I don't recall ever hearing such a 3 thing. 4 Q. You know Mr. Les Wexner, correct? 5 A. I do. 6 Q. Do you know whether or not Maria 7 Farmer was ever at Mr. Wexner's property in 8 9 MR. PAGLIUCA: Can you tell me how 10 that relates to this order, counselor? 11 MR. BOIES: Yes, I think it goes 12 directly to the sexual activity related 13 to Maria Farmer and what Mr. Epstein was 14 doing with Maria Farmer. 15 Again, you can instruct not to 16 answer. 17 MR. PAGLIUCA: I'm trying to 18 understand why you are asking these 19 questions before I -- 20 MR. BOIES: I'm asking these 21 questions because these are people who 22 not only have been publicly written 23 about in terms of the sexual activity 24 that they were put into in connection 25 with Mr. Epstein, but the person who Page 100 1 G. Maxwell - Confidential 2 wrote about them is somebody who talked 3 to this witness about it, and I think 4 that this is more than easily understood 5 cross-examination. 6 MR. PAGLIUCA: Your question was, 7 do you know whether or not Maria Farmer 8 was ever at Mr. Wexner's property in 9 Ohio. 10 MR. BOIES: Yes. And if you let 11 her answer, you will see where it leads. 12 If you won't let her answer, the judge 13 is going to determine it. And I just 14 suggest to you that you stop these 15 speeches and stop debating, because you 16 are not going to convince me not to 17 follow-up on these questions. If you 18 can convince the court to truncate the 19 deposition, that's your right, but all 20 you're doing is dragging this deposition 21 out. 22 MR. PAGLIUCA: You have the 23 opportunity to give me a good faith 24 basis why you are asking these 25 questions. Page 101 1 G. Maxwell - Confidential 2 MR. BOIES: I have given you a good 3 faith basis. 4 MR. PAGLIUCA: You haven't. 5 MR. BOIES: Then instruct not to 6 answer. 7 MR. PAGLIUCA: I am giving you the 8 opportunity to say why you are asking 9 the question, and why I'm telling her 10 not to answer and I am entitled to know 11 that. 12 MR. BOIES: You are not entitled to 13 know why I'm asking the question. You 14 are only entitled to know that it 15 relates to the subject matter that I am 16 entitled to inquire about, and I don't 17 think the judge is going to think that, 18 you know, where Mr. Epstein shipped 19 Maria Farmer off to is outside the scope 20 of what I'm entitled to inquire about. 21 THE WITNESS: Can we take a break? 22 MR. BOIES: Only if you commit not 23 to talk to your counsel during the 24 break. 25 THE WITNESS: That's ludicrous. 1111 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 27 of 73 Confidential 27 (Pages 102 to 105) Page 102 1 G. Maxwell - Confidential 2 MR. BOIES: You want a break to 3 talk to your counsel, right? 4 THE WITNESS: I want to use the 5 bathroom. 6 MR. BOIES: You want to talk to 7 your counsel, right? 8 THE WITNESS: I talk to my counsel 9 all the time. 10 MR. BOIES: I don't want you 11 talking to your counsel while I'm in the 12 middle of this examination. 13 MR. PAGLIUCA: I'm going to talk to 14 her, so are we going to sit here and go 15 for the rest of the day until we're 16 done? 17 MR. BOIES: No, but I'm going to go 18 through the rest of this line of 19 questioning, unless you take her and 20 walk out and then, I'm going to protest 21 that to the judge. 22 MR. PAGLIUCA: He is refusing a 23 bathroom break to you right now. 24 MR. BOIES: No, I'm not. I'm happy 25 to have her take a bathroom break as Page 103 1 G. Maxwell - Confidential 2 long as she doesn't use it as an excuse 3 to get coached by her lawyer. 4 THE WITNESS: For the record, I 5 want to object strongly to that. 6 MR. PAGLIUCA: You don't talk now. 7 Do you want to go to the bathroom? 8 THE WITNESS: Yes. 9 MR. PAGLIUCA: How about if I stay 10 here, Mr. Boies, will that work for you? 11 MR. BOIES: Absolutely. 12 THE VIDEOGRAPHER: The time is 13 11:31, and we are going off the record. 14 (Recess.) 15 THE VIDEOGRAPHER: The time is 16 11:34 a.m. and we are back on the 17 record. This also begins DVD No. 4. 18 BY MR. BOIES: 19 Q. Let me approach it this way. If 20 you turn to page 5 of 7 of the exhibit that 21 is Vicky Ward's Daily Beast article. And if 22 you look at the third paragraph where Ms. 23 Ward writes: What I had "on the girls" were 24 some remarkably brave first-person accounts. 25 Three on-the-record stories from the family, Page 104 1 G. Maxwell - Confidential 2 a mother and her daughters who came from 3 Phoenix. The oldest daughter, an artist, 4 whose character was vouchsafed to me by 5 several sources, including the artist, Eric 6 Fischl, had told me weeping as she sat in my 7 living room, of how Epstein had attempted to 8 seduce both her and separately and her 9 younger sister, then only 16." 10 Did Ms. Ward tell you that? 11 A. No. 12 Q. Did Ms. Ward tell you that her 13 information was that Mr. Epstein had 14 attempted to seduce both Maria and Annie 15 Farmer? 16 A. No. 17 Q. Did you and Mr. Epstein visit Maria 18 Farmer in Ohio? 19 A. I don't know I would characterize 20 the word visit with Mr. Epstein. We went for 21 business in Ohio because he worked with 22 Mr. Wexner, and I accompanied him on a few 23 visits. 24 Q. Did you and Mr. Epstein go to Ohio, 25 and while you were in Ohio, see Maria Farmer? Page 105 1 G. Maxwell - Confidential 2 A. I believe actually that she was -- 3 stayed at his house there, so I would have 4 seen her at the house. I believe I do recall 5 seeing her at the house, actually. 6 Q. When you say she stayed at the 7 house, you are referring to Maria Farmer? 8 A. Yeah, I think Maria Farmer was 9 painting or something in Ohio, and he let her 10 stay at a place that he had. 11 Q. When you say "he" let her stay, you 12 are talking about Les Wexner? 13 A. No, I'm talking about Jeffrey 14 Epstein. 15 Q. So when you saw Maria Farmer in 16 Ohio, it was your understanding that she was 17 staying at property that Mr. Epstein had in 18 Ohio, is that correct? 19 A. I don't know if it was his property 20 or he rented it, I don't know what the nature 21 was. It was a property that he had that she 22 stayed at. 23 Q. Maria Farmer was staying in Ohio at 24 some property, and you don't know whose 25 property it was, is that fair? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 28 of 73 Confidential 28 (Pages 106 to 109) Page 106 1 G. Maxwell - Confidential 2 A. I don't know what -- I don't know 3 who owned -- I don't know anything about the 4 ownership of the property or how Jeffrey had 5 it or why he stayed there, I don't know. 6 Q. Was it clear to you that Jeffrey 7 had arranged for Maria Farmer to stay at 8 wherever she was staying in Ohio? 9 MR. PAGLIUCA: Objection to form 10 and foundation. 11 A. I have no idea what the arrangement 12 was between Maria Farmer and Jeffrey. 13 Q. When you referred to the property 14 where Maria Farmer was staying, you said you 15 didn't know how Jeffrey had it? 16 A. What's your question? 17 Q. Was it your understanding that 18 Jeffrey did have that property that she was 19 staying at in some capacity or another, 20 either owning it or leasing it or having been 21 given it by a friend? 22 MR. PAGLIUCA: Objection to form 23 and foundation. 24 A. I have no idea. 25 Q. Where was this property that you Page 107 1 G. Maxwell - Confidential 2 and Mr. Epstein visited Maria Farmer at in 3 Ohio? 4 MR. PAGLIUCA: Objection to form 5 and foundation. 6 A. It was in Columbus. 7 Q. Was it a house or an apartment? 8 A. It was a house. 9 Q. When you and Mr. Epstein visited 10 Maria Farmer at this house in Columbus, was 11 anyone else in the house? 12 A. I never visited Maria Farmer at the 13 house. 14 Q. Did you see Maria Farmer in Ohio? 15 A. I recall seeing her, but I didn't 16 visit. I didn't go to Ohio to see Maria 17 Farmer. 18 Q. When you went to Ohio, did you see 19 Maria Farmer? 20 A. I recall seeing Maria Farmer in 21 Ohio. 22 Q. Where did you see her? 23 A. I recall seeing her at this house 24 that Jeffrey stayed at. 25 Q. Maria Farmer was staying in the Page 108 1 G. Maxwell - Confidential 2 house in Columbus, Ohio, correct? 3 A. I don't know the arrangement that 4 Maria Farmer had with Jeffrey. I believe she 5 was painting there, but I was never aware of 6 the arrangement. I know that I saw her in 7 Ohio at a house. 8 Q. When you were with Maria Farmer at 9 this house in Columbus, Ohio, Mr. Epstein was 10 with you, correct? 11 A. I went to Ohio with him on 12 business, and we were at a house that he 13 could stay at and I stayed at, and I recall 14 Maria Farmer being at this house. That is 15 what I recall. 16 Q. When you went to Ohio with 17 Mr. Epstein, did you see Maria Farmer on more 18 than one occasion? 19 A. I don't recall. 20 Q. You saw Maria Farmer in Ohio with 21 Mr. Epstein on at least one occasion, 22 correct? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. I recall seeing her in Ohio, but I Page 109 1 G. Maxwell - Confidential 2 couldn't tell you how many times I saw her. 3 For sure once, because I have a recollection 4 of seeing her once. 5 Q. And the house in which you and 6 Mr. Epstein and Maria Farmer were in 7 Columbus, Ohio, was that a house that you and 8 Mr. Epstein were staying in overnight? 9 A. I stayed overnight there. 10 Q. Was Maria Farmer staying there 11 overnight? 12 A. I don't recall. 13 Q. How many nights did you and 14 Mr. Epstein stay in this house in Columbus? 15 A. I don't recall. 16 Q. Was it more than one? 17 A. I don't recall. 18 Q. The night or nights that you and 19 Mr. Epstein stayed at this house in Columbus, 20 was Maria Farmer there? 21 A. I don't recall. 22 Q. When you saw Maria Farmer in Ohio, 23 did you talk to her? 24 A. I'm assuming I must have said 25 hello, so yes. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 29 of 73 Confidential 29 (Pages 110 to 113) Page 110 1 G. Maxwell - Confidential 2 Q. Other than assuming you may have 3 said hello, did you have any conversations 4 with her? 5 A. Not that I recall. 6 Q. Did Maria Farmer complain to you or 7 Mr. Epstein about anything? 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. I don't know what she would have 11 done if she complained to Jeffrey about 12 anything, but she didn't complain to me, as 13 far as I recall. 14 Q. As far as you know, she didn't 15 complain to Mr. Epstein,, is that correct? 16 A. I have no knowledge of what she did 17 or didn't do in that regard. 18 Q. Did she call the police or threaten 19 to call the police because of anything that 20 either you or Mr. Epstein did? 21 MR. PAGLIUCA: Objection to form 22 and foundation. 23 A. I never ever heard that. 24 Q. Ms. Ward didn't tell you, is your 25 testimony? Page 111 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. My testimony is I never heard that, 5 period. 6 Q. That includes, I assume, that you 7 never heard that from Ms. Ward, that's your 8 testimony? 9 MR. PAGLIUCA: Objection to form 10 and foundation. 11 A. I think you can safely say if 12 you've never heard it at all, it would 13 encompass anybody at all. It means you never 14 heard it, period. 15 Q. Did you ever see Annie Farmer in 16 Ohio? 17 A. Not that I recall. 18 Q. Where did you last see Annie 19 Farmer? 20 A. I only recall seeing her at the 21 ranch. 22 Q. In New Mexico? 23 A. Yeah. 24 Q. Other than seeing Annie Farmer at 25 Mr. Epstein's place in New Mexico, did you Page 112 1 G. Maxwell - Confidential 2 ever see Annie Farmer? 3 A. I don't recall ever seeing her. 4 Q. Did Annie Farmer ever engage in any 5 sexual activity with you? 6 A. No. 7 Q. Did Annie Farmer ever engage in any 8 sexual activity with Mr. Epstein? 9 A. I wouldn't know. I would assume 10 not, but I don't know. 11 Q. Do you have any reason to believe 12 that Mr. Epstein engaged in any sexual 13 activity with Annie Farmer? 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. I wouldn't know. 17 Q. Did you ever give a massage to 18 anyone other than Mr. Epstein at any of Mr. 19 Epstein's properties? 20 A. First of all, I never said I gave 21 Mr. Epstein a massage. 22 Q. I will ask that question if you 23 want, but I was focusing on people other than 24 Mr. Epstein right now. 25 A. I don't give massages. Page 113 1 G. Maxwell - Confidential 2 Q. Let's just tie that down. It is 3 your testimony that you've never given 4 anybody a massage? 5 A. I have not given anyone a massage. 6 Q. You never gave Mr. Epstein a 7 massage, is that your testimony? 8 A. That is my testimony. 9 Q. You never gave Annie Farmer a 10 massage is your testimony? 11 A. I never gave Annie Farmer a 12 massage. 13 Q. Did you, or to your knowledge, 14 Mr. Epstein pay for Annie Farmer to go to 15 Thailand? 16 MR. PAGLIUCA: Objection to form 17 and foundation. 18 A. I am not aware. 19 Q. Do you know whether Annie Farmer 20 went to Thailand? 21 A. I have no knowledge of anything 22 like that. 23 Q. Did you ever give anyone 24 instructions as to how to give a massage? 25 MR. PAGLIUCA: Objection to form MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 30 of 73 Confidential 30 (Pages 114 to 117) Page 114 1 G. Maxwell - Confidential 2 and foundation. 3 A. No. With a clarification, I do -- 4 I have very -- how to massage feet, pressure 5 points on a foot and pressure points on a 6 hand. 7 Q. Is what you're saying is that you 8 gave people instructions as to how to massage 9 feet and hands? 10 A. I have never given any 11 instructions. I have shown where pressure 12 points are on a hand and on a foot, but I 13 have never given instructions on how to do 14 it. I have demonstrated where a pressure 15 point on a hand and a foot is. 16 Q. Did you do that demonstration with 17 people who were giving or were planning to 18 give Mr. Epstein massages? 19 MR. PAGLIUCA: Objection to form 20 and foundation. 21 A. No, just in general, something 22 that I know how to do, so it would be just as 23 a general thing I have done. 24 Q. When you talk about general thing 25 you have done, is to tell people where the Page 115 1 G. Maxwell - Confidential 2 pressure points are on hands and feet? 3 A. Yes. 4 Q. Did you ever use that knowledge to 5 try to show someone who was giving or was 6 planning to give Mr. Epstein a massage how to 7 do it? 8 MR. PAGLIUCA: Objection to form 9 and foundation. Asked and answered. 10 A. I am not aware of ever having done 11 that, but I am aware of having shown people 12 that there is a pressure point on the hand 13 and foot. I have no specific knowledge of 14 who. Just in general, I have done it. 15 Q. Did you show people pressure points 16 on hands and feet in Mr. Epstein's house in 17 Palm Beach? 18 A. I don't recall with specificity 19 where. I just know I do it because it's just 20 something that I happen to know, it helps 21 people, something I know. 22 Q. What I'm trying to be sure that I 23 have your testimony on is whether at any of 24 Mr. Epstein's properties, whether you call it 25 instructions or not, told people or showed Page 116 1 G. Maxwell - Confidential 2 people how to give massage. Did you do that? 3 A. I have not done that. 4 Q. Did you ever tell or show people 5 how to give Mr. Epstein a massage? 6 A. No. 7 Q. Did you ever tell or show people at 8 Mr. Epstein's properties how to give 9 massages? 10 A. No. 11 Q. Did you at any time, at any of 12 Mr. Epstein's properties, tell or show anyone 13 how to give massages or how Mr. Epstein liked 14 massages? 15 MR. PAGLIUCA: Objection to form 16 and foundation. 17 A. No. I think Mr. Epstein is 18 perfectly capable -- 19 MR. PAGLIUCA: There is no question 20 pending. 21 Q. Did Mr. Epstein, in your presence, 22 ever tell or show anyone how he liked 23 massages? 24 A. I don't recall. 25 Q. Did Mr. Epstein ever tell you how Page 117 1 G. Maxwell - Confidential 2 he liked or didn't like massages given by any 3 particular person? 4 A. I can't recall. 5 Q. In other words, did he ever praise 6 to you or compliment to you some massage that 7 he had gotten or some person who had given 8 him a massage? 9 A. I'm sure in the course of time he 10 did, but I can't recall. 11 Q. Did he ever complain to you or 12 criticize the massage that anyone gave him? 13 A. Again, I don't recall. 14 Q. You know Sarah Kellen or Sarah 15 Kellen Vickers, correct? 16 A. I do. 17 Q. Did Mr. Epstein, insofar as you 18 have any reason to believe, ever engage in 19 sexual activities with her? 20 A. I have no knowledge. 21 Q. Did you ever engage in sexual 22 activities with Sarah Kellen Vickers? 23 A. No. 24 Q. Have you had any conversations with 25 Sarah Kellen Vickers about Mr. Epstein's MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 31 of 73 Confidential 31 (Pages 118 to 121) Page 118 1 G. Maxwell - Confidential 2 massages or sexual activities? 3 MR. PAGLIUCA: Objection to form 4 and foundation. 5 A. No. 6 Q. When was the last time you had any 7 communications with Sarah Kellen Vickers? 8 A. A long time ago. So long, I don't 9 recall. 10 Q. Were you aware that Sarah Kellen 11 Vickers was noticed for a deposition in this 12 case? 13 A. I believe I did know that, yes. 14 Q. Did you have any conversations with 15 anyone as to whether or not Sarah Kellen 16 Vickers would or should show up for that 17 deposition? 18 MR. PAGLIUCA: Wait a minute, what 19 does that have to do with the court's 20 order. Don't answer that question. 21 Just don't answer it. This is silly. 22 MR. BOIES: I actually think it is 23 far from silly. I think it goes to an 24 obstruction of justice situation that I 25 think you would be well advised to allow Page 119 1 G. Maxwell - Confidential 2 your client to answer the question on. 3 MR. PAGLIUCA: Do you have a good 4 faith basis to suggest that she 5 suggested that Ms. Kellen not show up at 6 her deposition yesterday? 7 MR. BOIES: I don't know whether it 8 was you, I don't know whether it was 9 her, I don't know who did it. What I do 10 know is that she didn't show up, and I 11 think the evidence will be quite clear 12 that your client's testimony about the 13 extent of her relationship with Sarah 14 Kellen Vickers is not accurate. 15 And in that context, I think the 16 circumstances under which it turns out 17 that she doesn't show up is entirely 18 appropriate for examination, but that is 19 something that I'm happy to talk to the 20 judge about. 21 MR. PAGLIUCA: Sure. And I hope 22 that you give him some good faith basis 23 for the assertions that you are making 24 here today, which are wholly improper. 25 MR. BOIES: I don't think they are Page 120 1 G. Maxwell - Confidential 2 at all improper. I am not making any 3 assertions. I'm simply asking 4 questions. I'm trying to find out what 5 the facts are. 6 MR. PAGLIUCA: No, you are not. 7 MR. BOIES: Yes, I am. You are 8 trying to keep the facts from coming 9 out. 10 MR. PAGLIUCA: No, I'm not. I'm 11 trying to keep this orderly and not 12 abusive as to where it is going. 13 MR. BOIES: This is so far from 14 abusive. 15 MR. PAGLIUCA: I think we should 16 take a lunch break, given it is noon. 17 MR. BOIES: We will do it in a half 18 hour, I want to finish this line of 19 questioning. I will guarantee we are 20 out by 12:30. 21 BY MR. BOIES: 22 Q. Let me ask you about a few other 23 people. 24 Nadia Marcinkova, do you know her? 25 A. I do. Page 121 1 G. Maxwell - Confidential 2 Q. Is she anyone with whom Mr. Epstein 3 had sex? 4 MR. PAGLIUCA: Objection to form 5 and foundation. 6 A. I have no idea. 7 Q. Is she anyone with whom Mr. Epstein 8 engaged in sexual activities? 9 MR. PAGLIUCA: Objection to form 10 and foundation. 11 A. I have no personal knowledge. 12 Q. When you say you have no personal 13 knowledge, what do you mean by personal 14 knowledge? 15 A. I mean that I've read the police 16 reports, so that's the only knowledge I have 17 of what Nadia or anybody else has with 18 Jeffrey. I have no way of knowing whether 19 they did or not. Personal knowledge means 20 did I know myself. 21 Q. After you saw the police reports 22 about Mr. Epstein's relations with Nadia 23 Marcinkova, did you ever talk to Mr. Epstein 24 about whether or not that police report was 25 or was not accurate? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 32 of 73 Confidential 32 (Pages 122 to 125) Page 122 1 G. Maxwell - Confidential 2 A. I have not. 3 Q. You did communicate with 4 Mr. Epstein after you saw that police report, 5 correct? 6 MR. PAGLIUCA: Objection to form 7 and foundation. 8 A. I don't know that's true. 9 Q. When did you see the police report? 10 MR. PAGLIUCA: If this involves 11 communications with me, I'm going to 12 instruct you not to answer the 13 questions. 14 Q. Is it your testimony that the only 15 time you saw the police reports was when it 16 was shown to you by your counsel? 17 A. That's the only time I recollect. 18 Q. What? 19 A. That's the only time I remember 20 seeing it. 21 Q. When did your counsel show you the 22 police report? 23 MR. PAGLIUCA: If you remember, you 24 can answer that question. 25 A. I don't know. I guess recently, Page 123 1 G. Maxwell - Confidential 2 but I don't recall. 3 Q. In the last 30 days? 4 A. I really don't remember when I saw 5 it. 6 Q. Was the first time that you saw the 7 police report sometime this calendar year 8 2016? 9 A. I don't remember when I've seen 10 them. It's in the course of this latest 11 lies. 12 Q. What do you mean, in the course of 13 this latest lies? 14 A. In the course of this defamation 15 suit. 16 Q. And you may not be able to answer 17 this, but if you can, I just want to know. 18 When you saw the police report in the course 19 of this defamation suit, was it this calendar 20 year, that is 2016, sometime? 21 A. I don't know, I'm sorry, I have no 22 memory. 23 Q. When is the last time you had a 24 conversation or communication with 25 Mr. Epstein? Page 124 1 G. Maxwell - Confidential 2 A. A very long time ago. 3 Q. How long? 4 A. I think two years ago, something 5 like that. 6 Q. Before this defamation lawsuit? 7 A. Excuse me? 8 Q. Before this defamation lawsuit? 9 A. You are asking if I communicated 10 with him before the defamation? What are you 11 asking me? 12 Q. Have you communicated with 13 Mr. Epstein since this defamation lawsuit was 14 filed? 15 A. I don't believe I have. I haven't 16 spoken to him -- no, I don't think so. I 17 don't remember when it was filed, no, I don't 18 think so. 19 Q. By communication, I don't mean just 20 speaking to him. I mean writing him a 21 letter, email, communicated in any way? 22 A. No. 23 Q. When you say no, does that mean you 24 have not communicated with Mr. Epstein in any 25 way since this lawsuit was filed? Page 125 1 G. Maxwell - Confidential 2 A. I don't recall any communications 3 with him since this lawsuit has been filed. 4 Q. Did you ever discuss Sarah Kellen 5 Vickers with Mr. Epstein? 6 MR. PAGLIUCA: Objection to form 7 and foundation. 8 A. I would have had conversations with 9 him in general terms. Obviously I talked 10 about her with him but not in any context of 11 this situation. Just I will have talked to 12 him about her. 13 Q. When was the last time you talked 14 to Mr. Epstein about Sarah Kellen Vickers? 15 A. Probably in 2003, 2002. 16 Q. What was the subject matter of that 17 conversation? 18 A. I have no idea. 19 Q. Did it have anything to do with 20 Mr. Epstein's relationship with Sarah Kellen 21 Vickers? 22 A. No, I have no idea. It would have 23 nothing to do with anything other than a 24 work-related issue. 25 Q. Did Sarah Kellen Vickers work for MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 33 of 73 Confidential 33 (Pages 126 to 129) Page 126 1 G. Maxwell - Confidential 2 Mr. Epstein? 3 A. I believe she did. 4 Q. Was she working for Mr. Epstein in 5 2003? 6 A. I believe she was. 7 Q. What was her job? 8 A. I don't exactly know what her job, 9 her responsibilities were. 10 Q. Do you know any of job 11 responsibilities? 12 A. I believe she traveled with him and 13 help managed the houses and run the staff and 14 whatever else he asked her to do. She worked 15 for Mr. Epstein, so you would have to ask 16 him. 17 Q. Was it your understanding that 18 Sarah Kellen Vickers at some point had had a 19 sexual or romantic relationship with 20 Mr. Epstein? 21 A. I have no knowledge of that. 22 Q. Let me go back to Nadia Marcinkova. 23 Did you know, yourself, Nadia Marcinkova? 24 A. I met her. 25 Q. Where did you meet her? Page 127 1 G. Maxwell - Confidential 2 A. I don't recall where I met her, I 3 just don't. 4 Q. Did you meet her at one of 5 Mr. Epstein's properties? 6 A. It's possible, but I don't recall 7 where I met her. 8 Q. Did you ever see Nadia at any of 9 Mr. Epstein's properties? 10 A. I believe that -- I believe on the 11 island, I recall, maybe. 12 Q. Virgin Islands? 13 A. Virgin Islands. 14 Q. Did Nadia work for Mr. Epstein? 15 A. I don't know. 16 Q. Did Nadia travel with Mr. Epstein? 17 A. I don't know. If she was on the 18 island, then presumably she did. I don't 19 recall. 20 Q. Did you ever see Nadia Marcinkova 21 at any of Mr. Epstein's properties other than 22 in the Virgin Islands? 23 A. Not that I recall. 24 Q. Leaving aside anything that you 25 have learned since this defamation suit Page 128 1 G. Maxwell - Confidential 2 started, did you have any reason to believe 3 that Mr. Epstein had engaged in sexual 4 activities with Nadia Marcinkova? 5 MR. PAGLIUCA: Objection to form 6 and foundation. 7 A. I don't -- I have no idea. It 8 wouldn't be something I think about. 9 Q. I'm sorry, say that again? 10 A. I would have no idea. 11 Q. Did Nadia Marcinkova, insofar as 12 you were aware, ever give Mr. Epstein a 13 massage? 14 A. I have no idea. 15 Q. Did you ever see her go into the 16 massage room? 17 A. Not that I recall, no. 18 Q. Did you ever tell Nadia Marcinkova 19 that Mr. Epstein wanted her in the massage 20 room? 21 A. No. 22 Q. Did you ever have any discussions 23 with Mr. Epstein about Nadia Marcinkova? 24 A. None. 25 Q. Did you ever have any discussions Page 129 1 G. Maxwell - Confidential 2 with Nadia Marcinkova about Mr. Epstein? 3 A. None. 4 Q. Do you know how much money, if any, 5 Mr. Epstein paid Nadia Marcinkova? 6 A. I have no idea, no, I have no idea. 7 Q. Do you know whether Mr. Epstein 8 paid Nadia Marcinkova, even if you don't know 9 the amount? 10 A. No, I would not know that. 11 Actually, I don't, I don't recall any 12 conversation -- 13 MR. PAGLIUCA: There is no question 14 pending. 15 Q. Do you know who Alfredo Rodriguez 16 is? 17 A. Yes. 18 Q. Would you identify him for the 19 record? 20 A. He is dead. 21 Q. Before he died? 22 A. He was a butler. 23 Q. A butler for whom? 24 A. Mr. Epstein in Palm Beach. 25 Q. And was he a butler for Mr. Epstein MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 34 of 73 Confidential 34 (Pages 130 to 133) Page 130 1 G. Maxwell - Confidential 2 in Palm Beach in the 1990s and 2000s? 3 A. I don't believe so. 4 Q. When did he become a butler for 5 Mr. Epstein? 6 A. I believe late -- middle of 2000s. 7 2004, 2005, something like that. 8 Q. When he became a butler for 9 Mr. Epstein, did he work for Mr. Epstein in 10 Palm Beach? 11 A. I believe he did. 12 Q. And did you see Mr. Rodriguez at 13 Mr. Epstein's Palm Beach residence while Mr. 14 Rodriguez was working as a butler for 15 Mr. Epstein? 16 A. I was not in Palm Beach when he was 17 working for Mr. Epstein. 18 Q. I think you answered the question, 19 but I want to be absolutely certain. Is it 20 your testimony that you never saw 21 Mr. Rodriguez at Mr. Epstein's Palm Beach 22 residence? 23 A. That is not my testimony. 24 Q. Did you ever see Mr. Rodriguez at 25 Mr. Epstein's Palm Beach residence? Page 131 1 G. Maxwell - Confidential 2 A. I'm sure I did because I would have 3 seen him. I'm sure I did see him but -- yes, 4 I would have seen him. 5 Q. When did you see Mr. Rodriguez at 6 Mr. Epstein's Palm Beach residence? 7 A. If I'm right and I could -- the 8 dates are a bit off, Mr. Epstein's mother 9 died, I think Mr. Rodriguez was working for 10 Mr. Epstein at that time, and I helped with 11 the funeral arrangements and I would have 12 seen him at that point. 13 Q. Other than the one occasion when 14 Mr. Epstein's mother died, we can figure out 15 what the date of that was -- 16 A. I don't have all the dates in my 17 head. 18 Q. Other than the one occasion when 19 Mr. Epstein's mother died, did you ever see 20 Mr. Rodriguez? 21 A. In that period of time when I went 22 very infrequently to Palm Beach, I don't know 23 how many times, maybe once or twice and had 24 he been at the house, I would have seen him, 25 so there would have been very few times. Page 132 1 G. Maxwell - Confidential 2 Q. Did you see Mr. Rodriguez at Mr. 3 Epstein's Palm Beach residence in 2005? 4 A. I don't recall going to the house 5 in 2005, but if I was there and he was 6 working, I would have seen him. 7 Q. Do you recall, as you sit here now, 8 one way or another, whether you were at Mr. 9 Epstein's Palm Beach residence in 2005? 10 A. I don't recall going to the house 11 in 2005, but if I did go, I would have seen 12 him. And if I did go, it would have been 13 once, maybe, I maybe went to the house in 14 2005, I don't recall. 15 Q. If you went to the house in 2005, 16 is it your testimony it would have only been 17 once? 18 A. Sounds about right, maybe twice. I 19 was not in Palm Beach in 2005. 20 Q. For you to have been at Mr. 21 Epstein's house in Palm Beach, you would have 22 had to have been in Palm Beach, right? 23 A. I would have had to have been in 24 Palm Beach to be at his house in Palm Beach, 25 of course. Page 133 1 G. Maxwell - Confidential 2 Q. So when you say you were not in 3 Palm Beach in 2005, does that mean it is your 4 testimony you were not at Mr. Epstein's house 5 in Palm Beach in 2005? 6 A. I don't recall being at Mr. 7 Epstein's house in 2005, I don't really 8 recall being in Palm Beach in 2005, and if I 9 was in Palm Beach in 2005, I may not have 10 stayed at his house. 11 Q. Is it your testimony that the most 12 you would have been at Mr. Epstein's house in 13 Palm Beach in 2005 was once or twice, if 14 that? 15 A. To the best of my recollection, 16 that sounds about right. But I really don't 17 recall, 2005 is a long time ago, I just don't 18 recall. 19 Q. You were continuing to work for 20 Mr. Epstein in 2005? 21 A. I was helping out in just very 22 specific areas of staffing of the houses and 23 some architectural details and decorating. 24 Q. You were getting paid? 25 MR. PAGLIUCA: We've gone over MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 35 of 73 Confidential 35 (Pages 134 to 137) Page 134 1 G. Maxwell - Confidential 2 this. You don't need to testify about 3 this again. We will take it up with the 4 judge, if we need to. I let this go on 5 for 15 minutes about Palm Beach. 6 MR. BOIES: I ask the question, you 7 give the instruction, the judge decides. 8 Q. In 2005, were you assisting in the 9 arranging of massages for Mr. Epstein? 10 A. No. 11 Q. Not at all is your testimony? 12 A. Correct. 13 MR. BOIES: This is a good time to 14 take a lunch break. 15 MR. PAGLIUCA: Okay. I don't 16 intend on being here all day, so if you 17 have some important questions you want 18 to ask, you may want to get to those. 19 MR. BOIES: You can walk out any 20 time you want. 21 MR. PAGLIUCA: We are getting 22 close. 23 MR. BOIES: The judge will decide 24 whether that's appropriate or not. 25 MR. PAGLIUCA: We are getting Page 135 1 G. Maxwell - Confidential 2 close. 3 THE VIDEOGRAPHER: It's 12:15 p.m. 4 and we are going off the record. 5 (Whereupon, a luncheon recess was 6 taken at 12:15 p.m.) 7 8 * * * 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 136 1 G. Maxwell - Confidential 2 A F T E R N O O N S E S S I O N 3 (Time noted: 1:16 p.m.) 4 5 G H I S L A I N E M A X W E L L, 6 resumed and testified as follows: 7 8 THE VIDEOGRAPHER: The time is 1:16 9 p.m., and we are back on the record. 10 This also begins DVD No. 5. 11 MR. PAGLIUCA: One housekeeping 12 matter before you get started. The 13 original deposition was as confidential 14 and we would designate this continued 15 deposition as confidential as well. 16 MR. BOIES: Okay. 17 Let me ask you to look at a 18 document that has been marked as Maxwell 19 Deposition Exhibit 28. This is another 20 list of names. 21 (Maxwell Exhibit 28, List of names, 22 marked for identification, as of this 23 date.) 24 Q. What I would ask you to do is to 25 identify the names that are here that you do Page 137 1 G. Maxwell - Confidential 2 not recognize. That is, I think you will 3 recognize most of the names -- 4 MR. POTTINGER: Excuse me one 5 second. 6 Q. What I was saying was that I would 7 like you to look at the names here and tell 8 me which names you do not recognize. 9 A. I pretty much recognize these 10 names. I don't know everybody very well, but 11 I recognize the names. 12 Q. You know who they are? 13 A. I don't know if I know who they 14 are. I recognize the names. 15 Q. Are most of the people on this list 16 people that you've met before? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. I believe I've met pretty much 20 everybody on this list. 21 Q. Who on the list have you not met? 22 A. I think I met them all. 23 Q. Now, were all of these people 24 people that at one time or another you were 25 with with Mr. Epstein? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 36 of 73 Confidential 36 (Pages 138 to 141) Page 138 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. I believe so. 5 Q. Were any of these people on the 6 list, obviously leaving aside Mr. Epstein 7 himself, people who, to your knowledge, 8 received massages at one or more of Mr. 9 Epstein's properties? 10 MR. PAGLIUCA: Objection to form 11 and foundation. 12 A. I couldn't say. 13 Q. Are there any people on this list 14 who you have reason to believe received 15 massages at one or more of Mr. Epstein's 16 properties? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. I couldn't say. 20 Q. Just to be clear, my most recent 21 question is whether any of the people on this 22 list are people who you have reason to 23 believe received massages at one of Mr. 24 Epstein's properties? 25 MR. PAGLIUCA: Same objection. Page 139 1 G. Maxwell - Confidential 2 A. I couldn't say. 3 Q. Why can't you say? 4 A. Because I just don't know. 5 Q. Well, you know whether you have a 6 reason to believe, correct? 7 MR. PAGLIUCA: Objection to form 8 and foundation. 9 A. These are events that took place 17 10 years ago, and I really do not know. It is 11 possible that people on that list got a 12 massage, it's also possible they didn't. I 13 really don't know, leaving aside, of course, 14 Mr. Epstein himself. 15 Q. Yes. 16 MR. PAGLIUCA: One second, I'm 17 getting text messages. 18 22 Q. Are there any names on this list 23 that you have reason to believe Mr. Epstein 24 engaged in sexual activities with? 25 MR. PAGLIUCA: Objection to form Page 140 1 G. Maxwell - Confidential 2 and foundation. 3 A. Eva Anderson was his girlfriend. 4 Q. I am sorry? 5 A. Eva Anderson was his girlfriend. 6 Q. When was Eva Anderson Mr. Epstein's 7 girlfriend? 8 A. I don't know the dates, but I 9 believe in the '80s. 10 Q. In the 1980s? 11 A. Yeah, and part of the 1990s, I 12 believe. So I don't know when they started 13 and when they ended. They were in a 14 long-term relationship. 15 Q. Was Mr. Epstein engaged in sexual 16 activities with Eva Anderson during the 17 period of time that you were involved with 18 Mr. Epstein? 19 A. I wouldn't know. 20 Q. How old was Eva Anderson when she 21 was first involved with Mr. Epstein? 22 A. I don't know. 23 Q. How old was Eva Anderson when you 24 first met her? 25 A. I don't recall. Page 141 1 G. Maxwell - Confidential 2 Q. Did any of the people on this list, 3 other than Mr. Epstein himself, and the list 4 is Exhibit 28, ever ask you to arrange a 5 massage? 6 MR. PAGLIUCA: Objection to form 7 and foundation. 8 A. Not that I recall. 9 Q. Did you arrange a massage for any 10 of the people on this list other than 11 Mr. Epstein? 12 A. Not that I recall. 13 Q. Were any of the people on this 14 list, other than Mr. Epstein, given a massage 15 at any of Mr. Epstein's residences? 16 MR. PAGLIUCA: Objection to form 17 and foundation. Asked and answered. 18 A. I wouldn't know. 19 Q. Did any of the people on this list, 20 other than Mr. Epstein, engage in sexual 21 activities with anyone at Mr. Epstein's 22 properties? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. I wouldn't know. I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 37 of 73 Confidential 37 (Pages 142 to 145) Page 142 1 G. Maxwell - Confidential 2 Q. When you say I wouldn't know, I 3 take it you mean to include that you 4 testified that you do not know, is that 5 correct? 6 MR. PAGLIUCA: Objection to form 7 and foundation. 8 A. I would have no knowledge. I have 9 no knowledge of what you are asking me. 10 Q. Did you ever have conversations 11 with anyone that were intended to convince 12 them to engage in sexual activities with 13 Mr. Epstein? 14 MR. PAGLIUCA: Objection to form 15 and foundation. This has been asked and 16 answered in her previous deposition, by 17 the way. 18 A. No. 19 Q. Did you ever tell anyone that 20 Mr. Epstein was a scout for Victoria's 21 Secret? 22 A. I don't recall saying that. 23 Q. Did you ever tell anyone that 24 Mr. Epstein could get them a job with 25 Victoria's Secret? Page 143 1 G. Maxwell - Confidential 2 A. I don't recall saying that. 3 Q. Do you deny saying that, or do you 4 simply say you don't recall, one way or 5 another, whether you said it? 6 MR. PAGLIUCA: This is outside the 7 court's order, so I will tell you not to 8 answer this, and we will take it up with 9 the judge. 10 Page 144 1 G. Maxwell - Confidential 2 Page 145 1 G. Maxwell - Confidential 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 38 of 73 Confidential 38 (Pages 146 to 149) Page 146 1 G. Maxwell - Confidential 2 Page 147 1 G. Maxwell - Confidential 2 Page 148 1 G. Maxwell - Confidential 2 Page 149 1 G. Maxwell - Confidential 2 15 Q. Was there anything that occurred 16 that led you to conclude that you didn't want 17 to be there anymore? 18 A. I ceased to be happy in the job and 19 I ceased to be happy spending time with 20 Mr. Epstein. 21 Q. Was there anything that happened 22 that you can identify that caused you to 23 cease to be happy spending time with 24 Mr. Epstein? 25 A. He became more difficult to work MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 39 of 73 Confidential 39 (Pages 150 to 153) Page 150 1 G. Maxwell - Confidential 2 with. 3 Q. Was there any particular aspect of 4 that that you can identify now? 5 A. Just general. Just doesn't work. 6 Q. Let me focus on Mr. Brunel. Now, 7 you testified that you have no reason to 8 believe that Mr. Brunel engaged in sexual 9 activities with anyone at any of Mr. 10 Epstein's residences, is that correct? 11 A. I would have no knowledge of that. 12 Q. Did you ever see Mr. Brunel engage 13 in sexual activities with anyone? 14 A. I did not. 15 Q. Did you ever see Mr. Brunel taking 16 photographs of people engaged in sexual 17 activities? 18 A. I did not. 19 Q. I apologize for getting into 20 something that is kind of an intimate area, 21 but I need to establish this, in part because 22 it relates to patterns of conduct, and I need 23 to ask you some questions about your sexual 24 activities with Mr. Epstein. 25 A. Okay. Page 151 1 G. Maxwell - Confidential 2 Page 152 1 G. Maxwell - Confidential 2 7 Q. Did you ever have conversations 8 with anyone who was engaged in sexual 9 activities with Mr. Epstein about those 10 sexual activities? 11 MR. PAGLIUCA: Objection to form 12 and foundation. 13 A. I never had those conversations. 14 Q. So would it be your testimony that 15 you never had any conversations about Mr. 16 Epstein's sexual activities with Nadia 17 Marcinkova? 18 A. I have never talked about sex with 19 Nadia at any point. I have hardly ever 20 spoken to her. 21 Q. Would your testimony be the same 22 with respect to Sarah Kellen Vickers? 23 A. That would be true, correct, I have 24 not. 25 Q. And Virginia Roberts? Page 153 1 G. Maxwell - Confidential 2 A. Of course not. 3 Q. Were there any young men that, to 4 your knowledge, would bring women over to 5 Mr. Epstein's residences to perform services 6 for Mr. Epstein? 7 MR. PAGLIUCA: Objection to form 8 and foundation. 9 A. Can you repeat the question, 10 please? 11 Q. Were there any young men that, to 12 your knowledge, would bring women over to 13 Mr. Epstein's residences to perform services 14 for Mr. Epstein? 15 A. I have no idea what you are talking 16 about, I'm sorry. 17 Q. I'm talking about whether there 18 were any young men that brought women over to 19 Mr. Epstein's residence to perform services? 20 A. I can't think of a single man in 21 that context that I've ever met. 22 Q. You testified earlier that you did 23 not recall ever meeting Tony Figueroa, is 24 that correct? 25 A. I don't believe I ever have. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 40 of 73 Confidential 40 (Pages 154 to 157) Page 154 1 G. Maxwell - Confidential 2 Q. Insofar as you were aware, did 3 Virginia Roberts ever have a male friend that 4 visited her at the Epstein residences? 5 A. I don't recall ever seeing a man 6 with Virginia. I believe she had a fiance 7 that I was aware of, I think, but that's all. 8 Q. When were you aware that Virginia 9 Roberts had a fiance? 10 A. I can't say I became aware from 11 reading all this stuff, or I was aware of it 12 at the time. I don't know. 13 Q. Did you ever meet Virginia Roberts' 14 fiance? 15 A. I don't think I ever did. I don't 16 recall meeting any men with Virginia. 17 Q. Do you know , 18 19 A. I never heard that name before. 20 Q. Have you ever heard the name of 21 Carolyn Andriamo, A-N-D-R-I-A-M-O? 22 A. I don't recollect that name at all. 23 MR. PAGLIUCA: Mr. Boies, those 24 names are on Exhibit 26, which we have 25 already gone over and she said she Page 155 1 G. Maxwell - Confidential 2 didn't recognize those people, so now we 3 are just repeating things that we went 4 over. 5 MR. BOIES: I am in the context of 6 seeing if I can refresh her 7 recollection, because these are women 8 that Mr. Figueroa, who she also does not 9 recall, brought over to Mr. Epstein's 10 residences, and I also want to make a 11 very clear record of what her testimony 12 is and is not right now. 13 Again, you can instruct her not to 14 answer if you wish. 15 MR. PAGLIUCA: I'm trying to get to 16 nonrepetitive questions here. You 17 basically asked the same question three 18 times. Then we get a pile of notes that 19 get pushed up to you, you read those. 20 Then you ask those three times, and then 21 we go to another question. So it's 22 taking an inordinately long amount of 23 time and it shouldn't. 24 MR. BOIES: I think that is a 25 demonstrably inaccurate statement of Page 156 1 G. Maxwell - Confidential 2 what has been going on, and I 3 attribute -- maybe I shouldn't attribute 4 it at all. 5 But if you want to instruct not to 6 answer, instruct not to answer. If you 7 don't, again, all I will do is request 8 that you cease your comments. I can't 9 do that. All I can do is seek sanctions 10 afterwards. 11 BY MR. BOIES: 12 Q. Ms. Maxwell. 13 A. Mr. Boies. 14 Q. What? 15 A. I'm replying. You said Ms. 16 Maxwell, I said Mr. Boies. 17 Q. Do you have a question? 18 A. No. 19 Q. I have a question. 20 A. I'm sure you do. 21 Q. During the time that you were in 22 the property or at the property that 23 Mr. Epstein has in the Virgin Islands, were 24 you aware of Mr. Epstein getting any 25 massages? Page 157 1 G. Maxwell - Confidential 2 A. He did receive massages at the 3 Virgin Islands property. 4 Q. From whom did he receive massages 5 at the Virgin Islands? 6 A. There is a professional masseuse 7 and masseur that came from St. Thomas. 8 Q. This was somebody who came over 9 from St. Thomas for the day to give massages 10 and then left, or was that person a resident? 11 A. I believe, from memory, they came 12 over, gave a massage and left. 13 Q. And who arranged for this person to 14 come over from St. Thomas? 15 A. Probably the staff at the island. 16 Q. But you don't know? 17 A. The staff of the island would have 18 made those arrangements. 19 Q. Who at the staff? 20 A. Whoever would have been running the 21 island at that period of time. 22 Q. Do you know who that was? 23 A. I'm sorry, in this moment I can't 24 think of the names of the people who worked 25 on the island. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 41 of 73 Confidential 41 (Pages 158 to 161) Page 158 1 G. Maxwell - Confidential 2 Q. Did you ever arrange for anyone to 3 give Mr. Epstein a massage at his Virgin 4 Island property? 5 A. I don't recall if I ever made a 6 call to the massage people in St. Thomas. I 7 don't recall. 8 Q. Did Mr. Epstein ever receive 9 massages at his Virgin Island property from 10 people that he had brought with him on his 11 plane from the United States? 12 MR. PAGLIUCA: Objection to form 13 and foundation. 14 A. I don't know. 15 Q. Did you ever participate in 16 arranging for a massage for Mr. Epstein by 17 someone who had been brought to the island on 18 Mr. Epstein's plane? 19 A. My memory of the massages on the 20 island were from people who came from St. 21 Thomas. 22 Q. Does that mean that you never 23 participated in arranging for a massage for 24 Mr. Epstein at his Virgin Island property to 25 be given by someone who had been brought to Page 159 1 G. Maxwell - Confidential 2 the island on Mr. Epstein's plane? 3 MR. PAGLIUCA: Objection to form 4 and foundation. 5 A. I don't recall, I have no idea. 6 Q. Mr. Epstein did bring women to his 7 Virgin Island property on his plane from time 8 to time, right? 9 MR. PAGLIUCA: Objection to form 10 and foundation. 11 A. People came to the island who were 12 his guests. 13 Q. And some of those guests, as you 14 described it, were women, right? 15 A. Indeed. 16 Q. Did you ever participate in 17 arranging for any of the women that came to 18 Mr. Epstein's Virgin Island property to 19 provide Mr. Epstein with a massage? 20 A. No. 21 Q. Where on the Virgin Island property 22 did Mr. Epstein have his massages? 23 A. I believe from memory he had them 24 in the master cabana. 25 Q. In what? Page 160 1 G. Maxwell - Confidential 2 A. It was a cabana, and also he had a 3 beach place, a place on the beach where from 4 time to time he would... 5 Q. Did you ever see Mr. Epstein being 6 given a massage in the beach area where he 7 from time to time had massages? 8 A. I don't have any recollection of a 9 specific memory, but it was just on the 10 beach, so there wouldn't be any privacy, he 11 would just be getting a massage. 12 Q. That would be visible to people who 13 are on the beach, correct? 14 A. It would be, yes. 15 Q. Did you, at any time when you were 16 there, see Mr. Epstein being given a massage 17 in this beach area other than by a 18 professional masseuse brought to the island 19 from St. Thomas? 20 A. I don't have any memory of -- I 21 don't have a specific memory of seeing him 22 get a massage on the beach. I just have an 23 image of a massage on the beach, so I don't 24 know who, I have no memory of it. 25 Q. Whether or not you have a specific Page 161 1 G. Maxwell - Confidential 2 memory of it, do you have a general memory 3 that from time to time Mr. Epstein got 4 massages down in the beach area? 5 A. I have a general memory, I do. 6 Q. Do you have a general memory that 7 from time to time those massages were given 8 to Mr. Epstein by people other than a 9 professional masseuse brought to the island 10 from St. Thomas? 11 MR. PAGLIUCA: Objection to form 12 and foundation. 13 A. I have no idea who would be giving 14 him a massage in that general memory of mine, 15 so I can't say. The massages that I recall 16 were from people from St. Thomas, and that's 17 what I recall. 18 Q. Did anyone ever complain to you 19 that Mr. Epstein had demanded sex of them? 20 MR. PAGLIUCA: Objection to form 21 and foundation. 22 A. Is that a question? 23 Q. Yes. 24 A. Never. 25 Q. Do you know somebody named Reynaldo MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 42 of 73 Confidential 42 (Pages 162 to 165) Page 162 1 G. Maxwell - Confidential 2 Rizzo? 3 A. I do not. 4 Q. Who is he? 5 A. I don't know him -- I know who he 6 is now, but he worked, I believe, for Eva and 7 Glenn, but prior to -- 8 Q. Eva and Glenn Dubin? 9 A. Yeah. 10 Q. It's your testimony you never met 11 Mr. Rizzo? 12 A. I don't recall ever meeting him. 13 Q. Do you remember being at the 14 Dubins' residence with Mr. Rizzo and with a 15 16 A. I do not. 17 Q. Do you ever remember a 18 during 19 the period of time that you were with 20 Mr. Epstein? 21 A. I do not. 22 Q. Was there ever a time when you were 23 at the Dubin residence with a girl under the 24 age of 21 who had been with Mr. Epstein? 25 MR. PAGLIUCA: Objection to form Page 163 1 G. Maxwell - Confidential 2 and foundation. 3 A. Can you repeat the question, 4 please? 5 Q. Sure. 6 You remember from time to time 7 being at the Dubin residence, correct? 8 A. I do. 9 Q. And I think you testified that you 10 don't remember whether Mr. Rizzo was present 11 on any of those occasions, although he might 12 have been, correct? 13 A. If Mr. Rizzo was standing right 14 here in front of me, I wouldn't know who he 15 is. 16 Q. Does that mean you are saying that 17 you never met him or simply that you don't 18 remember him? 19 A. I don't know if I ever met him, but 20 if I saw him in a picture, maybe I would 21 recognize it, but I don't believe I'd 22 remember him. 23 Q. Did you ever go to the Dubin 24 residence with some woman who had previously 25 been with Mr. Epstein? Page 164 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. No, no. 5 Q. Let me see if I can possibly 6 refresh your recollection. Do you recall 7 being at the Dubin residence with 8 that was crying and very 9 distraught? 10 A. I have never seen that. 11 Q. Did you ever take the passport of 12 any person who had told you that Mr. Epstein 13 had demanded sex of them? 14 A. No. 15 Q. Were you ever at any residence of 16 Mr. Epstein's when Alan Dershowitz was 17 present? 18 A. I'm sure I was. 19 Q. Were you at Mr. Epstein's Palm 20 Beach residence when Mr. Dershowitz was 21 present? 22 A. I may have been. It's possible. 23 Q. Were you at Mr. Epstein's New 24 Mexico property when Mr. Dershowitz was 25 present? Page 165 1 G. Maxwell - Confidential 2 A. I don't have any memory of that, 3 but it's possible. I just don't recall it. 4 Q. Were you at Mr. Epstein's Virgin 5 Islands property when Mr. Dershowitz was 6 present? 7 A. That I do recall, yes. 8 Q. Were you at Mr. Epstein's New York 9 property when Mr. Dershowitz was present? 10 A. Again, it's possible, but I don't 11 have a memory of it. 12 Q. How many times do you recall being 13 at Mr. Epstein's Virgin Island property when 14 Mr. Dershowitz was also present? 15 A. I only recall once. 16 Q. When was that? 17 A. I don't recall the date. 18 Q. Who else was present on that time? 19 A. I believe his wife and his 20 daughter. 21 Q. Anyone else? 22 A. I don't recall anyone else. 23 Q. Anyone else on the whole island. I 24 don't just mean with him. I mean did 25 Mr. Epstein have other guests with him at - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 43 of 73 Confidential 43 (Pages 166 to 169) Page 166 1 G. Maxwell - Confidential 2 that time? 3 A. I don't recall anybody else. 4 Q. How did you arrive there? 5 A. I don't know. 6 Q. Did you come with Mr. Epstein? 7 A. I don't know, I'm sorry. 8 Q. How did Mr. Dershowitz arrive 9 there? 10 A. Again, I don't know. 11 Q. Did he come with Mr. Epstein? 12 A. I don't know. 13 Q. Other than that one time that you 14 say you were at the Virgin Island property 15 with Mr. Dershowitz, had you ever met 16 Mr. Dershowitz in Mr. Epstein's presence? 17 MR. PAGLIUCA: This is outside of 18 the court's order. I will tell you not 19 to answer that question. 20 THE WITNESS: Okay. 21 Q. Did Mr. Dershowitz ever receive a 22 massage at any of Mr. Epstein's properties? 23 A. I don't recall. 24 Q. Did you ever have any conversations 25 with Mr. Dershowitz? Page 167 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: You don't have to 3 answer that question. About what, 4 anything? 5 Q. Did you ever have any conversations 6 with Mr. Dershowitz at Mr. Epstein's 7 properties? 8 A. I did, about metal detecting. 9 Q. Anything else? 10 A. I only recall metal detecting. 11 Q. Where did that conversation take 12 place? 13 A. As I was metal detecting. 14 Q. I said where? 15 A. On the island. 16 Q. That's the only conversation that 17 you recall, is that your testimony? 18 A. Yes, that is my testimony. 19 Q. Do you recall ever seeing 20 Mr. Dershowitz at any of Mr. Epstein's 21 residences other than the Virgin Island 22 property? 23 A. That's the only specific memory I 24 have of the conversation that I recall 25 because it was something special. Page 168 1 G. Maxwell - Confidential 2 Q. I'm not now asking you about a 3 conversation. 4 A. What are you asking me? Sorry. 5 Q. Do you recall ever seeing 6 Mr. Dershowitz at any of Mr. Epstein's 7 residences other than the Virgin Island 8 property? 9 A. I don't have any specific 10 recollection. 11 Q. Do you have a general recollection? 12 A. I have a general recollection that 13 I have seen him, but I just don't have any 14 other memory of it. I know I met him. I 15 just don't recall where or when, except for 16 that singular event on the island. 17 Q. When you say you have a general 18 recollection that you have seen him, do you 19 mean you have a general recollection that you 20 have seen him at Mr. Epstein's properties 21 other than the Virgin Islands? 22 A. It's just a general recollection, 23 but I have no specific memory of seeing him. 24 Q. All I'm trying to do is find out 25 whether your general recollection is a Page 169 1 G. Maxwell - Confidential 2 general recollection of having seen him 3 someplace in the world or whether you have a 4 general recollection of having seen him at 5 Mr. Epstein's properties? 6 A. I'm sorry, I really can't answer. 7 I just don't know. The only memory I have of 8 him is on the island, and I don't have any 9 additional memory of him anywhere else. 10 Q. I mentioned a woman by the name of 11 Caroline before. Are you familiar with a 12 Caroline Casey? And I don't mean to imply 13 they are the same people. 14 A. Is this on any of these lists that 15 you gave me? 16 Q. It could have been on the first 17 list. I don't think so. 18 A. Is it on this list? 19 Q. It's not on the second list. 20 A. So what's your question? 21 Q. Are you familiar with a woman named 22 Caroline Casey? 23 A. I'm familiar with the name, yes. 24 Q. Who is that person? 25 A. I don't recall who she is. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 44 of 73 Confidential 44 (Pages 170 to 173) Page 170 1 G. Maxwell - Confidential 2 Q. What is Caroline Casey's connection 3 to Mr. Epstein? 4 A. I don't know. 5 Q. Did you ever speak to Caroline 6 Casey? 7 A. I don't recall. I know her name, 8 and that's all I can -- I don't recall a 9 conversation with her. I don't recall who 10 she is at this point. 11 Q. Was Caroline Casey someone who 12 provided massages for Mr. Epstein? 13 A. I don't believe so. 14 Q. Did Caroline Casey perform any 15 services for Mr. Epstein? 16 MR. PAGLIUCA: Objection to form 17 and foundation. 18 A. I have no idea, I'm sorry. 19 Q. When did you first become aware of 20 charges that Mr. Epstein was having sex with 21 a significant number of people at his 22 residences? 23 MR. PAGLIUCA: You don't have to 24 answer that question. It's outside of 25 the court's order. Page 171 1 G. Maxwell - Confidential 2 Q. You have testified that you were 3 only aware of a few people that Mr. Epstein 4 had sex with or engaged in sexual activities 5 with at his residences, correct? 6 MR. PAGLIUCA: Objection to form 7 and foundation. 8 A. I didn't say that. 9 Q. How many people are you aware of 10 that Mr. Epstein engaged in sexual activities 11 with at his residences? 12 A. I'm not aware. 13 Q. You are aware of some? 14 A. Well, the ones that we've 15 discussed, but that's all I'm aware of. 16 Q. That's my question. 17 A. Then I can concur, yes. 18 Q. Let's be clear. You have 19 identified three people. 20 Page 172 1 G. Maxwell - Confidential 2 8 A. Are you giving me a timeframe here, 9 because it's been a long time. I'm assuming 10 he is having sexual relations today. You 11 have to bind it to some time. 12 Q. You don't know who he is having 13 sexual relationships with today, do you? 14 A. No. 15 Q. So you can only tell me who 16 Mr. Epstein was having sexual relationships 17 with at a time when you knew about it, 18 correct? 19 A. I have no knowledge of him actually 20 having sex with anybody else outside of what 21 we have identified, 22 . 23 Q. Now, there came a time when you 24 learned that people were asserting that he 25 had had sexual activities with a lot more Page 173 1 G. Maxwell - Confidential 2 than those three people at his residences, 3 correct? During the period of time that you 4 were involved with Mr. Epstein, correct? 5 A. Like everybody else, like the rest 6 of the world, when it was announced in the 7 papers. 8 Q. Yes. 9 And that was during 2005? 10 A. Whenever it was. 11 Q. At that point, did you do anything 12 to try to find out whether those assertions 13 were or were not accurate? 14 MR. PAGLIUCA: You don't have to 15 answer that. That's outside the court's 16 order. 17 Q. When you heard that there were 18 assertions that Mr. Epstein had engaged in 19 sexual activities with people who you had met 20 at Mr. Epstein's residences, did you do 21 anything to determine whether those 22 assertions were or were not accurate? 23 MR. PAGLIUCA: Objection to form 24 and foundation, and you don't have to 25 answer that question. It's outside the MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 45 of 73 Confidential 45 (Pages 174 to 177) Page 174 1 G. Maxwell - Confidential 2 court's order. 3 Q. In terms of preparing for this 4 deposition, what documents did you review? 5 MR. PAGLIUCA: To the extent I 6 provided you with any documents to 7 review, I will tell you that's both -- 8 it's privileged and I instruct you not 9 to answer. 10 Q. Did your lawyer provide you with 11 any documents to review in preparation for 12 this deposition that refreshed your 13 recollection about any of the events that 14 occurred? 15 MR. PAGLIUCA: You can answer that 16 question. 17 A. No. 18 Q. How many documents did your lawyer 19 provide you with? 20 MR. PAGLIUCA: You can answer. 21 A. One, I believe. 22 Q. One document. Was that a document 23 that had been prepared by your attorney, or 24 was it a document from the past? 25 MR. PAGLIUCA: I will tell you not Page 175 1 G. Maxwell - Confidential 2 to answer that question. 3 Q. Was the document that your attorney 4 showed you a document that you had ever seen 5 before? 6 MR. PAGLIUCA: Again, don't answer 7 questions about what I showed you or 8 didn't show you. 9 She already testified that nothing 10 refreshed her recollection. 11 MR. BOIES: I don't have to accept 12 that answer. I can ask these questions, 13 and I think these are clearly not 14 privileged questions. 15 Q. Do you know a 16 A. I do. 17 Q. Who is 18 A. She was a friend of Jeffrey's. 19 Q. Was someone with whom 20 Mr. Epstein engaged in sexual activities? 21 MR. PAGLIUCA: Objection to form 22 and foundation. 23 A. I don't know. 24 Q. Did you ever have any reason to 25 believe that Mr. Epstein was engaged in Page 176 1 G. Maxwell - Confidential 2 sexual activities with 3 MR. PAGLIUCA: Objection to form 4 and foundation. 5 A. I didn't have any reason -- I had 6 no idea whether they were or weren't. 7 Q. Were you with Mr. Epstein in 2005 8 when the Palm Beach police launched their 9 investigation? 10 MR. PAGLIUCA: You don't have to 11 answer the question. That's outside the 12 court's order. 13 Q. When the Palm Beach police launched 14 their investigation in 2005, did you make any 15 effort to retain records of the women who had 16 been present at Mr. Epstein's residences in 17 the prior period? 18 MR. PAGLIUCA: Don't answer that 19 question. It's outside the court's 20 order. 21 Q. When the Palm Beach police launched 22 their investigation in 2005, were you aware 23 of any effort to destroy records of women who 24 had been present at Mr. Epstein's residences 25 in the prior period? Page 177 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Don't answer that 3 question. It's outside the court's 4 order. 5 Q. In 2005, were you aware of any 6 effort to destroy records of messages you had 7 taken of women who had called Mr. Epstein in 8 the prior period? 9 MR. PAGLIUCA: Don't answer that 10 question. It's outside the court's 11 order. 12 MR. BOIES: I said I would give you 13 a break every hour. It's been an hour. 14 MR. PAGLIUCA: Do you want a break 15 or do you want to keep going? 16 THE WITNESS: Keep going. 17 MR. BOIES: What I told you before, 18 you asked for a break every hour. I am 19 happy to give you a break at a fixed 20 time. What I'm not happy to do is 21 interrupt a chain of examination. 22 So if you want a break now, we will 23 take a break now. If you don't want a 24 break now, we will not break for another 25 hour. - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 46 of 73 Confidential 46 (Pages 178 to 181) Page 178 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Is there a rule that 3 you can point me to that mandates that 4 you get to control the time and place of 5 breaks? 6 MR. BOIES: No. We will take a 7 break now, because if what you are going 8 to do is say, you said at the very 9 beginning of this thing that you wanted 10 to have a rule that every hour we took a 11 break, and I said that was fine with me, 12 but I just didn't want you taking a 13 break, particularly since you reserve 14 the right to talk to your client during 15 breaks, in the middle of an examination. 16 Now you are saying let's continue 17 for a while but I am not agreeing to 18 continue for the next hour. We will 19 take a break, and we will come back and 20 we will go from there. 21 MR. PAGLIUCA: We will take a break 22 at your request now, and then if I want 23 to take a break, we will take another 24 break. 25 MR. BOIES: If you take a break to Page 179 1 G. Maxwell - Confidential 2 talk to your witness, I guarantee you 3 there will be a motion for sanctions. I 4 think what you're doing with this 5 witness is inappropriate. I think your 6 instructions not to answer, 7 conversations that you had with her 8 while she is under oath and under 9 examination is inappropriate. 10 THE VIDEOGRAPHER: It's 2:18 p.m., 11 and we are off the record. 12 (Recess.) 13 THE VIDEOGRAPHER: The time is 2:28 14 p.m. This also begins DVD No. 6. 15 BY MR. BOIES: 16 Q. Let me hand you a document that has 17 been previously marked as Maxwell Exhibit 13. 18 And I would like you to turn to page 91 of 19 that exhibit. And you see the heading that 20 says, "Massage-Florida"? 21 A. Actually, I don't -- yes, I do, 22 sorry. 23 Q. Then you see a list of telephone 24 numbers with names? 25 A. I do. Page 180 1 G. Maxwell - Confidential 2 Q. I would like to go down those names 3 and see if any of those people are people 4 that you recognize. However you think is 5 best, we can go name by name, or you can tell 6 me which ones you recognize and which ones 7 you don't. 8 A. I recognize Sherrie. I recognize 9 Allison Chambers. Caroline Casey. These are 10 names that ring bells, nothing else. 11 Dara. I recognize the name. 12 Q. Where is Dara? 13 A. Dara Preece. I just recognize 14 these names. It doesn't mean anything else. 15 I'm just recognizing names. 16 Gwendolyn Beck. 17 Let me do it again and make sure I 18 didn't miss anyone. That's it. 19 Q. Now, with respect to the people 20 that you say you recognized the names of, 21 Sherrie Lynch, Allison chambers, Caroline 22 Casey, Dara Preece and Gwendolyn Beck, were 23 any of those people, people who provided 24 massages to Mr. Epstein? 25 MR. PAGLIUCA: Objection to form Page 181 1 G. Maxwell - Confidential 2 and foundation. 3 A. Sorry, I guess. I believe Sherrie 4 did, and I believe -- I think that's it that 5 I know of, I think. 6 Q. Now, just going down the names of 7 people that you did not recognize, I take it 8 you are not aware or recognize the name 9 first name? 10 A. It was just a first name. I can't 11 think of a at this point. 12 Q. The same thing is true for 13 A. I don't recognize 14 Q. And 15 A. I don't recognize 16 Q. And Joanne? 17 A. Is that Johanna? Where is that? 18 That's Johanna, I'm sorry, I missed her. 19 That would probably be Johanna Sieberg. 20 I think might have been a 21 masseuse as well. There is a in the 22 back of my head. 23 Q. Amy Birse? 24 A. I don't know who that is. 25 Q. What about Melissa Hanes? 1111 1111 1111 -- - 1111 1111 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 47 of 73 Confidential 47 (Pages 182 to 185) Page 182 1 G. Maxwell - Confidential 2 A. No. 3 Q. What about 4 A. No. 5 Q. 6 A. No. 7 Q. 8 A. I didn't think I know a 9 period. 10 Q. 11 A. No. 12 Q. Is that Virginie? 13 A. I don't know what that is. 14 Q. Then there is a or 15 Do you see that? 16 A. I don't see that. 17 Q. It's right after Virginia, which is 18 right after 19 A. I see it. I don't know who that 20 is. 21 Q. How about 22 A. No idea. 23 Q. There is someone here and 24 described as a redhead? 25 A. I don't know who that is. Page 183 1 G. Maxwell - Confidential 2 Q. Melanie? 3 A. No. 4 Q. And there is a Melanie Haynes? 5 A. I don't know. 6 Q. 7 A. No idea. 8 Q. Then there is Caroline Andriano? 9 A. That's a name that keeps coming up. 10 I recognize the name, but I don't know her in 11 particular. 12 Q. What about Dominique Kelly? 13 A. I have no idea who that is. 14 Q. Mary Southwell? 15 A. No idea. 16 Q. Somebody that's listed as 17 , Virginia's friend? 18 A. No. 19 Q. Diane Cahill, do you know who that 20 is? 21 A. No. 22 Q. How about Tony's friend? 23 A. No. 24 Q. Do you know who Tony is? 25 A. No. Page 184 1 G. Maxwell - Confidential 2 Q. Next one is -- 3 A. Tony is Virginia's guy that you 4 asked me about. I don't know Tony. 5 Q. I asked you about a Tony Figueroa. 6 A. Right, I don't know him, so I'm 7 guessing, I don't know him. 8 Q. 9 A. No. 10 Q. 11 A. No. 12 Q. 13 A. I don't know who these people are. 14 Q. Was there a list that was kept of 15 women or girls who provided massages? 16 MR. PAGLIUCA: This has been 17 previously deposed on. This is not part 18 of the court's order, I will tell her 19 not to answer. 20 MR. BOIES: You are going to tell 21 her not to answer a question that says 22 was there a list of women or girls who 23 provided massages? 24 MR. PAGLIUCA: She has been 25 previously deposed on this subject. Page 185 1 G. Maxwell - Confidential 2 MR. BOIES: I think this is 3 squarely in the court's order, but if 4 you instruct her not to answer, you 5 instruct her not to answer. 6 MR. PAGLIUCA: We'll find out. 7 BY MR. BOIES: 8 Q. I take it you don't know the ages 9 of any of these people? 10 A. The ones that I did recognize were 11 roughly my age. The ones I don't know, I 12 wouldn't have a clue. 13 Q. Did you, or insofar as you are 14 aware anyone, maintain a list of females that 15 provided massage services to Mr. Epstein at 16 his residences? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 You can answer if you can. 20 A. I don't know anything about a list. 21 Q. Let me go back to Exhibit 28. I 22 want to go down this list, excluding 23 Mr. Epstein himself, and just ask you a 24 series of the same essential questions about 25 each one. - 1111 1111 - - - - - 1111 1111 - - - 1111 - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 48 of 73 Confidential 48 (Pages 186 to 189) Page 186 1 G. Maxwell - Confidential 2 Tila Davies, which of Mr. Epstein's 3 residences did you see Tila Davis at? 4 A. I don't have a memory of Tila, 5 where I would have seen her. 6 Q. Did you see her at some residence 7 or property? 8 A. I did. 9 Q. Of Mr. Epstein? 10 A. I did. 11 Q. You just can't remember which ones, 12 is that fair? 13 A. Yes, that's fair. 14 Q. Tiffany Gramza, which residences of 15 Mr. Epstein did you see Tiffany at? 16 A. I don't actually recall meeting 17 Tiffany, so I can't recall. 18 Q. So Tiffany Gramza may be somebody 19 who you never met, is that your testimony? 20 A. No, I'm not saying that. I just 21 don't recall her really at all. I'm sorry, I 22 don't recall. 23 Q. Did you see Tiffany at some 24 residence or property of Mr. Epstein? 25 A. I don't recall. Page 187 1 G. Maxwell - Confidential 2 Q. Clara Hazel, what properties of 3 Mr. Epstein did you see Clare Hazel at? 4 A. Palm Beach, and I believe New 5 Mexico and New York. 6 Q. And Melinda Luntz? 7 A. Palm Beach, I believe. 8 Q. And what was Melinda Luntz doing at 9 Palm Beach when you saw her? 10 A. If I remember correctly, she was a 11 real estate broker. 12 Q. Did you see Melinda Luntz at 13 Mr. Epstein's Virgin Island property? 14 A. I don't recall. 15 Q. When you saw Clare Hazel in Palm 16 Beach and New Mexico and New York, what was 17 she doing? 18 A. I don't know. 19 Q. Do you know why she was there? 20 A. I think she was just a friend. 21 Q. A friend of Mr. Epstein's? 22 A. Yeah. 23 Q. Alexia Wallaert, what Epstein 24 properties did you see her at? 25 MR. PAGLIUCA: I will now tell you Page 188 1 G. Maxwell - Confidential 2 not to answer these questions anymore. 3 These do not appear -- I let this go on, 4 they don't appear to be tied to the 5 court's order as relating to sex or 6 massages or anything that's contained in 7 the order. This is just simply what was 8 somebody doing at some property at some 9 point in time. So don't answer these 10 questions. 11 Q. It is your assertion that, leaving 12 Mr. Epstein aside, none of the people on this 13 list engaged in sexual activities with either 14 you or Mr. Epstein, correct? 15 MR. PAGLIUCA: Objection to form 16 and foundation. 17 A. I can only testify to myself. I 18 cannot testify to Mr. Epstein. 19 Q. With respect to Mr. Epstein, do you 20 know, one way or another, whether any of 21 these people engaged in sexual activities? 22 A. With respect to Mr. Epstein, how 23 would I know that? 24 Q. The answer is lots of ways, but all 25 I can do is ask you whether you know it or Page 189 1 G. Maxwell - Confidential 2 not. 3 A. I don't. 4 Q. Do you have any reason to believe 5 -- because I don't want to get stuck on your 6 concept of personal knowledge -- do you have 7 any reason to believe that any of the people 8 on this list had sexual activities with 9 Mr. Epstein? 10 A. I do not. 11 Q. Do you have any reason to believe 12 that any of these people had massages at any 13 Epstein property? 14 A. I have no idea. It's entirely 15 possible, but I have no idea. 16 Q. Do you have any reason to believe 17 that any of the people on this list, other 18 than Mr. Epstein himself, engaged in sexual 19 activities with anyone on Mr. Epstein's 20 properties? 21 A. I have no reason to believe that. 22 Q. Let me go to the Dubin residence. 23 I asked you some questions about the Dubin 24 residence earlier and about a possible visit 25 to that residence of a . Do you MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 49 of 73 Confidential 49 (Pages 190 to 193) Page 190 1 G. Maxwell - Confidential 2 recall that subject generally? 3 A. I recall you asking me a question 4 about it, yes, I do. 5 Q. Let me ask about another time at 6 the Dubin residence. Were you ever at the 7 Dubin residence with people who worked at the 8 Epstein residence? 9 MR. PAGLIUCA: Objection to form 10 and foundation. 11 A. No. 12 Q. Were you ever at the Dubin 13 residence when there were a number of females 14 under the age of 21 dancing? 15 A. Excuse me? 16 Q. Were you ever at the Dubin 17 residence when there were a number of females 18 under the age of 21 dancing? 19 A. The only people I have seen dancing 20 at any Dubin residence are 21 Q. Just those , no other 22 ? 23 A. No other 24 Q. Were you ever at the Dubin 25 residence when females who you had seen at Page 191 1 G. Maxwell - Confidential 2 the residences of Mr. Epstein, leaving aside 3 were present and dancing? 4 A. Can you ask me the question again? 5 Q. Sure. I'm focusing on the Dubin 6 residence, and I'm focusing on children other 7 than 8 A. I'm there. 9 Q. I'm asking whether you were ever at 10 the Dubin residence where there were females 11 other than who were 12 dancing. 13 A. I've never witnessed -- 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. Other than , who I have 17 certainly seen dancing, I don't recall any 18 dancing at Eva and Glenn's residences by any 19 other people. 20 MR. BOIES: I think pending 21 resolution of the instructions not to 22 answer, I don't have any further 23 questions at this time. If you give me 24 a minute, just to check. 25 Thank you very much. Page 192 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: I want to make a 3 record here before we are done. I do 4 get a chance to speak. Are we going off 5 the record now? 6 MR. BOIES: You want to talk on the 7 record? 8 MR. PAGLIUCA: Yes, is that okay 9 with you? 10 MR. BOIES: You want to ask her 11 questions? 12 MR. PAGLIUCA: No. I want to make 13 a record of your closing of the 14 deposition. 15 MR. BOIES: I don't know how you 16 can make a record of my closing the 17 deposition, but if you want to take up 18 the time and the transcript space to 19 talk as opposed to writing a letter or 20 filing a motion, go for it. 21 MR. PAGLIUCA: To the extent you 22 have questions that are within the 23 court's order that you haven't asked, 24 that I haven't objected to, meaning no 25 other questions, this deposition is Page 193 1 G. Maxwell - Confidential 2 closed. 3 If there are questions that I have 4 instructed the witness not to answer and 5 it later turns out the judge disagrees 6 with my characterization, we will be 7 back to revisit it, but we are done as 8 far as I'm concerned. 9 MR. BOIES: The deposition is not 10 closed. There are a number of 11 instructions not to answer. I think it 12 is a fair point that if the court were 13 to conclude that none of the questions 14 that have been instructed need to be 15 answered, we're not going to be 16 continuing the deposition, barring some 17 additional information coming to light. 18 MR. PAGLIUCA: I think we agree 19 then. 20 THE VIDEOGRAPHER: The time is 2:51 21 p.m., and we are going off the record. 22 (Time noted: 2:51 p.m.) 23 24 25 - - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 50 of 73 Confidential 50 (Pages 194 to 197) Page 194 1 2 - - - 3 I N D E X 4 - - - 5 6 GHISLAINE MAXWELL PAGE 7 By Mr. Boies 4 8 9 - - - 10 E X H I B I T S 11 - - - 12 EXHIBIT PAGE 13 Exhibit 26 List of names 23 14 Exhibit 27 Article 94 15 Exhibit 28 List of names 135 16 17 18 19 20 21 22 23 24 25 Page 195 1 2 - - - 3 DEPOSITION SUPPORT INDEX 4 - - - 5 Direction to Witness Not to Answer 6 Page Line Page Line Page Line 7 50 22 50 25 51 5 8 51 9 51 17 51 22 9 52 2 81 17 82 6 10 82 25 83 7 94 21 11 95 6 98 12 118 11 12 142 6 142 13 165 16 13 165 25 169 22 172 13 14 172 22 173 4 173 24 15 174 5 175 9 175 17 16 175 25 176 8 183 14 17 186 23 18 - - - 19 Request for Production of Documents 20 Page Line Page Line Page Line 21 None 22 - - - 23 Stipulations 24 Page Line Page Line Page Line 25 None Page 196 1 2 - - - 3 Questions Marked 4 Page Line Page Line Page Line 5 None 6 - - - 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 197 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that GHISLAINE 6 MAXWELL, was duly sworn by me and that the 7 deposition is a true record of the testimony 8 given by the witness. 9 10 _______________________________ 11 Leslie Fagin, Registered Professional Reporter 12 Dated: July 22, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporter.) 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 51 of 73 Confidential 51 (Pages 198 to 199) Page 198 1 2 ACKNOWLEDGMENT OF DEPONENT 3 4 5 I, , do hereby 6 certify that I have read the foregoing pages, 7 and that the same is a correct transcription 8 of the answers given by me to the questions 9 therein propounded, except for the 10 corrections or changes in form or substance, 11 if any, noted in the attached Errata Sheet. 12 13 14 15 16 GHISLAINE MAXWELL DATE 17 18 19 20 Subscribed and sworn to before me this 21 day of , 2016. 22 My commission expires: 23 Notary Public 24 25 Page 199 1 2 - - - - - - E R R A T A 3 - - - - - - PAGE LINE CHANGE 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 52 of 73 Confidential Page 1 A MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 53 of 73 Confidential Page 2 B MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 54 of 73 Confidential Page 3 C MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 55 of 73 Confidential Page 4 D MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 56 of 73 Confidential Page 5 E MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 57 of 73 Confidential Page 6 F MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 58 of 73 Confidential Page 7 G MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 59 of 73 Confidential Page 8 H MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 60 of 73 Confidential Page 9 I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 61 of 73 Confidential Page 10 J K L MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 62 of 73 Confidential Page 11 M MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 63 of 73 Confidential Page 12 N MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 64 of 73 Confidential Page 13 O P MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 65 of 73 Confidential Page 14 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 66 of 73 Confidential Page 15 Q R MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 67 of 73 Confidential Page 16 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 68 of 73 Confidential Page 17 S MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 69 of 73 Confidential Page 18 T MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 70 of 73 Confidential Page 19 58:25 76:20 78:19 U MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 71 of 73 Confidential Page 20 V W MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 72 of 73 Confidential Page 21 X Y Z 0 1 2 3 4 5 6 7 8 9 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-2 Filed 01/09/24 Page 73 of 73 Exhibit G Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 1 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 1 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, -vs- CONFIDENTIAL ALAN M. DERSHOWITZ, Defendant. ____________________________________/ VIDEOTAPED DEPOSITION OF VIRGINIA ROBERTS GIUFFRE Saturday, January 16, 2016 9:07 a.m. - 2:48 p.m. 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, Florida 33301 Reported By: Deborah A. Harris, Court Reporter Notary Public, State of Florida Phone - 305.651.0706 Job No. JO277789 Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 2 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 2 APPEARANCES: On behalf of the Plaintiffs: Jack Scarola, Esquire SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 (561) 686-6300 On behalf of the Deponent: Sigrid McCawley, Esquire BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, Florida 33301 (954) 356-0011 On behalf of the Defendant: Mary Borja, Esquire WILEY REIN, LLP 1776 K Street NW Washington, DC 20006 (202) 719-7000 On behalf of the Defendant: Richard Simpson, Esquire WILEY REIN, LLP 1776 K Street NW Washington, DC 20006 (202) 719-7000 On behalf of the Defendant: Thomas E. Scott, Esquire COLE, SCOTT & KISSANE, P.A. 9150 South Dadeland Boulevard, 14th Floor Miami, Florida 33156 (305) 350-5300 On behalf of the Defendant: Kenneth A. Sweder, Esquire SWEDER & ROSS, LLP 131 Oliver Street. Boston, Massachusetts 02110 (617) 646-4466 Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 3 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 3 ALSO PRESENT Edward J. Pozzuoli, Special Master Robert Pacheco, Videographer Ryan Kick, Videographer Bradley J. Edwards Paul G. Cassell Alan M. Dershowitz Brittany N. Henderson, Esq. Meridith Schultz, Esquire --- INDEX WITNESS DIRECT CROSS REDIRECT RECROSS Virginia Roberts Giuffre By Ms. Borja 5 By Mr. Scarola 201 By Ms. Borja 204 --- EXHIBITS DEFENDANT VR EXHIBITS FOR ID 1 - Notice. 6 2 - Disclosure list. 26 3 - Order. 59 4 - E-mail. 92 5 - Photo (Confidential) 100 6 - Article. 124 7 - Daily Mail. 155 8 - Daily Mail. 168 9 - Declaration. 170 10- FBI doc. 187 REPORTER'S NOTE: Exhibit 5 marked confidential, sealed, and retained by the Special Master. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 4 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 4 Deposition taken before Deborah A. Harris, Florida Professional Court Reporter and Notary Public in and for the State of Florida at Large, in the above cause. --- THE VIDEOGRAPHER: We are now on video record. This is disk number one in the videotaped deposition of Virginia Roberts in the matter of Bradley J. Edwards and Paul G. Cassell, Plaintiff versus Alan M. Dershowitz, Defendant. The deposition is being held at the Law Office of Boies, Schiller & Flexner located at 401 East Las Olas Boulevard, Suite 1200. Fort Lauderdale, Florida 33301. Today's date is January 16th, 2016. The time is 9:07 a.m. My name is Robert Pacheco, I am the videographer. The court reporter is Deborah Harris, both from Esquire Deposition Solutions. Would counsel please introduce yourselves and your affiliation and the witness will be sworn in. MS. MCCAWLEY: My name is Sigrid McCawley. I'm with the Law Firm of Boies, Schiller & Flexner. I'm here with my colleague, Meridith Schultz and we represent non-party Virginia Roberts Giuffre. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 5 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 5 MR. SCAROLA: Jack Scarola, counsel on behalf of Bradley Edwards and Paul Cassell. Mr. Edwards and Mr. Cassell are also present. MS. HENDERSON: Brittany Henderson also on behalf of the Plaintiff. MS. BORJA: Mary Borja for Defendant, Alan Dershowitz. MR. SCOTT: Thomas Scott for the Defendant. MR. SIMPSON: Richard Simpson on behalf of Professor Dershowitz. MR. SWEDER: Ken Sweder of Sweder and Ross on behalf of Professor Dershowitz. SPECIAL MASTER: Ed Pozzuoli, Special Master. --- Thereupon, VIRGINIA ROBERTS GIUFFRE, having been first duly sworn or affirmed, was examined and testified as follows: THE WITNESS: Yes, I do. DIRECT EXAMINATION BY MS. BORJA: Q. We have noticed this examination for you as Virginia Roberts. I understand you have a different married last name? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 6 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 6 A. Yes. Q. Could you pronounce that for me? A. Giuffre. Q. Giuffre. If I from time to time call you Ms. Roberts, would that be okay with you today? A. Absolutely. (Thereupon, Defendant's VR Exhibit No. 1, was Marked for Identification.) BY MS. BORJA: Q. I'm going to hand you a document that's been marked as VR Exhibit Number 1, which is a notice of taking video duces tecum. Ms. Roberts, are you appearing here today pursuant to this notice of video deposition duces tecum? A. Yes. Q. And you've seen this document before today? A. No. Q. Did you bring any documents with you today pursuant to the duces tecum? A. No. Q. Were you asked to bring any documents with you today? A. No. Q. You understand that you're under oath today and that your testimony is being taken down by the court Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 7 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 7 reporter, correct? A. Yes. Q. And today's testimony is the same as if you were testifying before a judge and a jury. Do you understand that? A. Yes. Q. It's important that you allow me to finish my question and I'll allow you to finish your answer because the court reporter is very good, but she can only type one of us talking at a time. Is that okay? A. Yes. Q. It's also important that all of your answers be verbal since nodding your head or shaking your head if you mean yes or no, you should give it a verbal response. Is that agreeable? A. Yes. Q. What is your current home address? MS. MCCAWLEY: We're going to object on the record. You're welcome to notice anything to my law office for Virginia. She's had some safety issues with respect to her location so we're not going to be putting that on the record. MS. BORJA: That's fine. You're going to accept service for her for all purposes in this action? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 8 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 8 MS. MCCAWLEY: Yes. MS. BORJA: That's fine. Thank you. MS. MCCAWLEY: Yes. If you need to serve her with anything. BY MS. BORJA: Q. Ms. Roberts, are you taking medication that would effect in any way your ability to testify? A. No. Q. Were you involved in collecting documents for production in this case? A. I don't understand. Q. I'll get back to that in a little bit. Are you aware of the action that your attorneys, Brad Edwards and Paul Cassell, filed against the government? A. Yes. Q. If I call that the Federal action or the CVRA action, will you understand the action that I'm referring to? A. Yes. Q. And you sought to join that action, correct? A. Yes. Q. And you understand that you were Jane Doe #3 named in the motion for joinder, right? A. Yes. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 9 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 9 Q. I'm going to show you, I'm not going to mark it as an exhibit, a copy of Jane Doe #3 and Jane Doe #4 corrected motion pursuant to Rule 21 for joinder and action. Do you have that in front of you right now? A. Yes. Q. And this was entered as Document 280 in the docket for purposes of identification in our record here today. Did you review this document before it was filed? A. Not this specific document, no. Q. Were you aware that this joinder motion was being filed in the CVRA action? A. I knew there was an action for the CVRA for me to be joined, yes. Q. And you're aware, are you not, that there are allegations that you were sexually trafficked being made in that action, correct? A. I'm aware that there are allegations that I was trafficked. Q. If you turn to page 4 of this document the numbers are on the bottom of the page. In that first full paragraph in the third line down it says, Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions when she was a minor? MS. MCCAWLEY: Feel free to look at the entire page. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 10 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 10 MR. SCAROLA: It is a minor discrepancy, but I think you read it as when she was a minor and it's while she was a minor. BY MS. BORJA: Q. While she was a minor. Do you see where I'm reading starting in the third line? A. Yes. Q. Is that allegation true? A. Yes. Q. If you go to page 6 of the document, do you see the paragraph that's starts, Epstein also trafficked? A. Yes. Q. Is says Epstein also trafficked Jane Doe #3 for sexual purposes to many other powerful men including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known prime minister and other world leaders. Do you see that? A. Yes. Q. Is that allegation true? A. Yes. Q. The reference there to foreign presidents, do you see that? A. Yes. Q. You were sexually trafficked to foreign presidents? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 11 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 11 A. No. Q. So that's not true, you were not sexually trafficked to foreign presidents? A. I don't know what foreign president you're talking about. Q. Have you ever been sexually trafficked to any foreign president? MS. MCCAWLEY: I'm going to allow you to ask that question, but with respect to specific identification of an individual we're not going to do that. At this point she has. MS. BORJA: Counsel, your objection has been made. No speaking objections, please. Let's move on. MS. MCCAWLEY: I can make my record, and my record is she's not going to be speaking with respect to individuals' names that are named in generalities in this document. SPECIAL MASTER: Objection overruled. You can answer. A. I understand well-known prime ministers and other world leaders; as far as foreign presidents, I'm not too sure, I don't know. Q. Have you ever met any foreign presidents? A. Foreign presidents as in overseas? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 12 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 12 Q. Sure, okay, overseas. A. No. Q. Have you ever met any foreign presidents from countries not overseas such as Canada or Mexico? A. No. Q. So you were not sexually trafficked to any foreign presidents; is that correct? A. As far as I know right now, yes. Q. It's correct that you were not sexually trafficked to them, right? A. You've asked me this three times and I'm telling you. Q. Okay. A well-known prime minister. Were you sexually trafficked to a well-known prime minister? A. Yes. Q. Who was that? MS. MCCAWLEY: I'm going to object to this line of questioning. This has to do with safety concerns for her. MS. BORJA: Counsel, this is under seal. You can answer. MS. MCCAWLEY: No, she's not going to answer. SPECIAL MASTER: Hang on one second. MS. MCCAWLEY: Let me make my objection. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 13 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 13 SPECIAL MASTER: Make your objection. MS. MCCAWLEY: Regardless of it being under seal, we've seen that in this case the client that you represent has violated confidentiality orders regularly so we have no sense of security with a sense that this is a confidential record at this point. We are doing that under the Court's order. With respect to naming individuals who can harm a victim of sexual trafficking, she's a non-party in this action, not a plaintiff. She is not going to be revealing any names today of an individual who is going to harm her physically, period. If we have to go to Judge Lynch on that we will, I'm happy to do that, but she's not going to be naming individuals where there's a threat to her safety. SPECIAL MASTER: Response. MS. BORJA: It is under seal. I'm shocked that counsel would suggest that a prime minister is threatening the physical safety of this witness. There's no foundation for that. The suggestion that a foreign minister is going to physically harm has no evidence in this case, and it's being to be under seal. Let's get the evidence out while the Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 14 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 14 witness is here. As you pointed out, she's a non-party. Let's make our record and move on. MS. MCCAWLEY: You may be shocked by that but -- SPECIAL MASTER: Hang on one second. The reason why I'm here is so we don't have the back and forth. MS. MCCAWLEY: Sure. SPECIAL MASTER: I'm going to rule on the objection. Your objection at this point is overruled. You can answer. And I want to admonish everybody here that this is confidential and the protection of this witness is of paramount importance under the Confidentiality Order. So Ms. Roberts, you can answer the question that's been asked. MS. MCCAWLEY: At this point we're going to need to take a break because I'm not going to allow her to answer a question that's going to threaten her physical safety. So we can take a break on that. THE WITNESS: If I can just say, I personally know that this is not a good person to talk about and I'm not going to, point blank, I'm not going to say his name. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 15 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 15 SPECIAL MASTER: Okay. I can't twist her arm and force her so we'll deal with it. BY MS. BORJA: Q. Okay. Other world leaders, what other world leaders were you sexually trafficked to? MS. MCCAWLEY: We have the same objection. SPECIAL MASTER: And I would have the same ruling based upon the arguments. MS. MCCAWLEY: Let me just make my record. To the extent that there's a name of an individual that you can reveal that you do not feel would harm your physical safety, you're welcome to reveal them. Anybody else, you don't have to reveal at this time and we'll take that to Judge Lynch. A. Okay. Prince Andrew for one. Q. Other than Prince Andrew? A. There is another individual that I honestly do not know his name. Q. What country is he from? A. I'm not too sure, he spoke in a foreign -- he did speak foreign tongue, he spoke English as well, but I'm not too sure where he was from. Q. How do you know he is world leader? A. I was introduced to him as a prince. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 16 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 16 Q. Okay. Did he have security with him? A. I'm sure he did somewhere around, but not when I was with him. Q. Did you see security? A. No. Q. Did you -- where were you when you met him? A. On this occasion the South of France. Q. Are there witnesses to you being sexually trafficked to this prince? A. Yes. Q. Name them. A. Jeffrey Epstein, Ghislaine Maxwell. Q. Anyone else? A. There was a whole bunch of people in the room so of course. Q. Was this an orgy? A. No. Q. Who else was in the room? A. I can't name them all, there was a lot. Q. Name as many as you can name? A. I don't know their names. I can't name their names. Q. They were present during sexual activity? A. They were present before the sexual activity and then I went to have sexual activity with him Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 17 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 17 alone. Q. So he's the only witness to your sexual activity, the prince? A. On the instruction of Epstein and Ghislaine, yes. Q. Where in the South of France were you? A. I don't know. Q. Were you on a boat, were you in a house? A. We were at a like a cabana, not cabana, like a resort, but it was a big party. Q. Who was throwing the party? A. I don't know. I was just brought there. Q. You also refer to powerful business executives. What powerful business executives were you sexually trafficked to? MS. MCCAWLEY: Again, to the extent you can reveal somebody without a safety concern you're welcome to do that. SPECIAL MASTER: Well, again -- MS. MCCAWLEY: Right. I understand. SPECIAL MASTER: Same objection, same ruling. A. George Mitchell. Q. When were you sexually trafficked to George Mitchell? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 18 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 18 A. I am unable to give you times since we are going back a very long time ago. Q. Tell me the best that you can remember? A. Roughly when I was 17. Q. Where were you? A. New Mexico and New York. Q. Are there witnesses to this? A. Not to the actual event itself. Q. What other powerful business executives were you sexually trafficked to? A. Bill Richardson. Q. Are there witnesses? A. Besides Epstein instructing me to do so, no. Q. What other powerful business executives that you were sexually trafficked to? A. Yes, I know what you're saying. MS. MCCAWLEY: Take your time. Take a deep breath. A. Jean Luc Brunel. Q. Who else? MS. MCCAWLEY: To the extent you recall. A. I'm just trying to think. This is all very confronting for me. So at the same token I'm just trying to recollect everybody. The Dubins, Glen Dubin. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 19 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 19 Q. You said the Dubins, were you sexually trafficked to more than one Dubin? A. No. Q. Just to Glen? A. Just to Glen. Q. Is he the powerful business executive who's pregnant wife was asleep in the next room. A. Yes. Q. What other powerful business executives were you sexually trafficked to? A. None that I can remember off the top of my head. Q. Was Les Wexner one of the powerful business executives that you were trafficked to? A. Yes. Q. So you can remember others. Who else is there? MS. MCCAWLEY: I'm going to object to that. That's inappropriate. She gave you everyone she could remember at the time when you mentioned a name. SPECIAL MASTER: Okay. Okay. Please move on without -- MS. BORJA: There's a question pending. A. I said yes. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 20 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 20 Q. What other powerful business executives? A. Wasn't that just objected? MS. MCCAWLEY: You can answer. SPECIAL MASTER: You can answer. A. I can't remember off the top of my head, I'm sorry. Q. You also referred to prominent American politicians. What prominent American politicians other than the ones we've already named were you sexually trafficked to? A. The ones I just told you about, Bill Richardson and . Q. How many times were you trafficked to Bill Richardson? A. I don't know, over two times. Q. How old were you? A. Approximately 17, 18. Q. Are you sure you were underage during one of those incidents? A. I can't be 100 percent sure of anything. It's not like I recorded the dates. I'm just giving you an approximation. Q. How many times were you sexually trafficked to ? A. Twice that I can recall. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 21 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 21 Q. Were you underage during either of those? A. I believe so. Q. Both of them? A. I can't be 100 perfect sure. Q. When you were sexually trafficked to the prince were you underage? A. Not by England's standards. Q. You weren't in England, were you, you were in the South of France? MS. MCCAWLEY: Which prince? You need to clarify. A. Foreign prince, sorry. I believe I would have been 17. I don't know what their age -- MS. MCCAWLEY: You don't have to know. You don't have to know anything legal. Just answer the question the best you can. BY MS. BORJA: Q. So how old were you when you were sexually trafficked to Mr. Dubin? A. I don't know. Q. What is your best guess? A. I'm not going to speculate. Q. How many times did you have sex with Mr. Dubin? A. Once. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 22 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 22 Q. How many times did you have sex with Les Wexner? A. Multiple. Q. What's the approximate range of number, more than three? A. More than three. Q. More than five? A. Possibly. Q. More than ten? A. No. Q. Did Mr. Wexner ask you to wear any particular clothing during your sexual trafficking? MS. MCCAWLEY: Again, I'm going to object to this line of questioning. To the extent that you revealed something to me in work product circumstance or attorney-client privilege, I don't want you revealing that. This case is about the defamation between Paul Cassell and Brad Edwards and Mr. Dershowitz. It's not about the individuals other than Mr. Dershowitz who is the individual here who the judge said we're here to talk about the issues in this case, not the litany of other individuals. MS. BORJA: Counsel, we have limited time. SPECIAL MASTER: Hang on one second. I'm Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 23 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 23 going to deny the objection. You can answer the question. I'm going to give some latitude on this, but counsel, please understand it's some latitude. So you can answer the question. MS. BORJA: And Special Magistrate, I would also ask for an instruction, we have limited time here and speaking objections are inappropriate and unnecessary for your ruling. MS. MCCAWLEY: I'm allowed to make my record. SPECIAL MASTER: Counsel, she needs to make the record, however, the four hours in my mind is not a hard and fast four hours based upon how we proceed in this deposition. So I'll take that into consideration as we approach the four hours. A. Yes, I wore lingerie for him. Q. At his request? A. It wasn't his request, it was Ghislaine who set it up for me. Q. And did she specify baby doll lingerie to be worn? A. All different types of lingerie. Q. Was it specifically Victoria Secret lingerie? A. I didn't write the brand. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 24 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 24 Q. Have you alleged that you were required to wear Victoria Secret lingerie for Les Wexner? A. No. MS. MCCAWLEY: Alleged in what context? BY MS. BORJA: Q. She's already answered. Now, other than the people you've already named for me today, were you sexually trafficked to anyone else during your period between 1999 and 2002? A. Yes. Q. Who else? MS. MCCAWLEY: To the extent you can recall. SPECIAL MASTER: Counsel, let her think it through. A. Alan Dershowitz, Jean Brunel, the obvious people that I've already stated. , Jeffrey Epstein obviously, Ghislaine Maxwell, you know, there's people that I just -- I honestly can't think of everybody right now. I do feel like I am under a lot of pressure to answer the questions and I'm doing the best that I can honestly. Q. Were you sexually trafficked to Marvin Minsky? A. Yes. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 25 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 25 Q. Were you sexually trafficked to a man last name ? A. Who? Q. , if the name doesn't ring a bell, just tell me? A. No. Q. How many times were sexually trafficked to Marvin Minsky? A. Once. Q. How old were you? A. I don't know. Q. You're sure it was one time, correct? A. I'm not sure of anything. There was a lot of people that Jeffrey sent me to and it was a long time ago. I can't be a thousand percent correct on that. Q. Who is Marvin Minsky? A. He is an older gentleman. Q. Do you know what's does for a living? A. I think he's a scientist, but I don't want to 100 percent say. Q. Who is ? A. I think he's a r. Q. Do you know where? A. Possibly , I think, or maybe . I'm not too sure. I'm just speculating. - - - - Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 26 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 26 Q. Where did you meet ? A. , at the islands. Q. And when you say the islands, do you mean Jeffrey Epstein's estate? A. Yes. Q. And where did you meet Marvin Minsky? A. Marvin Minsky was at the islands as well. Q. Did you ever meet him anywhere else? A. Yes. Q. Did you have sex with him in other locations? A. No. Q. Did you ever fly in a plane with him? A. No. Q. Did you ever have sex is Larry Summers? A. No, not that I know of. The name does not ring a bell. You have to understand that there were a lot of gentlemen that I was lent out to by Jeffrey Epstein. So it is very hard for me to remember all of their names and who they were and what they did. (Thereupon, Defendant's VR Exhibit No. 2, was Marked for Identification.) BY MS. BORJA: Q. Ms. Roberts, when you refer to , did you mean ? - Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 27 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 27 A. No. Q. Have you ever met a ? A. Possibly. Q. Do you know one way or the other? A. Do I know? Q. You said possibly? A. I was introduced lots of political scientific, academic, so there is a possibility I could have met him. Q. Did you ever have sex with ? A. No. Q. Were you ever sexually trafficked to Nathan Nervelt? A. No, not that I know of. Q. I'm handing you a document that's been marked as VR Exhibit 2, which is Plaintiff, Virginia L. Giuffre's, I apologize, disclosure pursuant to Federal Rule of Civil Procedure 26. This is a document that was entered in your lawsuit against Ghislaine Maxwell in the Southern District of New York. Have you ever seen this document before? A. No. Q. If you take a look, there's a list of witnesses starting at page 1 and continues on? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 28 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 28 A. Yes. Q. I'm wondering whether this list might help you. Can you look at the names on this list and tell me who from these names you were sexually trafficked to? A. Number 7, Gwendolyn Beck. I wasn't trafficked to her. She was just a part of some of the trafficking. Q. Hold on. What part did she have in the trafficking? A. She was involved in some of the orgies. Q. So she was a sexual participant in the orgies? A. Yes. Q. That you were a participant in as well? A. Yes. Q. Were these orgies that Ms. Beck was involved in with any of the individuals that you have named so far today? A. Not that I can remember right now. Q. Do you know what gentlemen were involved in the orgies with you and Ms. Beck? A. As far as I can recall Jeffrey Epstein. Q. Okay. A. Number 9, , Sophie Biddle does ring a bell, but I don't want to 100 percent say that. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 29 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 29 Q. Ring a bell in terms of what? A. The name rings a bell. I mean, you have to understand there was a lot, a lot, a lot of girls around to remember all of their names. Q. My question is, was Sophie Biddle a participant in sexual activities with you? A. I don't know and I'm not going to speculate. Q. I'm not asking you to speculate. I'm asking you under oath today was she a participant, as far as you can recall today, in sexual activities -- MS. MCCAWLEY: Objection, asked and answered. Sorry, I didn't mean to interrupt. BY MS. BORJA: Q. -- with you? A. I'm telling you under oath that I'm not sure about Sophie Biddle being in sexual orgies with me but the name does ring a bell. Q. And A. Yes, she was involved, but I'm not going to speak about her. She has the right to her own privacy. She's been hurt, she's a victim, so I'm not going there. Q. Did she participate in any of the sexual activities with others that you've named today? A. Yes. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 30 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 30 Q. With whom? A. I'm not answering that. MS. MCCAWLEY: We're going to object. To the extent that you're concerned about the safety of one of these individuals, we're not going to testify. We can go to the judge and we can come back if he says you have to testimony regarding that but -- MS. BORJA: We already have the names of the gentlemen. SPECIAL MASTER: Hang on one second. For purposes of the record, have you made your record? MS. MCCAWLEY: Well, let's make a record. So was underage at the time this occurred so she, herself, is a victim. So to the extent that, you know, if you want to bring her counsel in and have them present during something like this, that's fine, but this witness who is a non-party to this litigation who's a victim herself doesn't have to speak about other under-aged victims. SPECIAL MASTER: Counsel? MS. BORJA: I'm entitled to know the names of witnesses who can either verify or discredit the allegations. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 31 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 31 MS. MCCAWLEY: She's given you the name. SPECIAL MASTER: Counsel, let her make her record. MS. BORJA: As to specific individuals, and I do not want to bring up her name with individuals with whom she's not alleged to have had sexual activity, that would be unfair to this witness; but what would be fair to my client who is being sued in this case is to be able to check the allegations with a neutral third party, and if this is a witness -- MS. MCCAWLEY: Why don't you ask her if that's somebody who was involved with your client, which is what we're here on today, Alan Dershowitz, not all of these other individuals. SPECIAL MASTER: Okay. All right. Have you made your record? MS. BORJA: Yes. SPECIAL MASTER: I'm going to overrule the objection. I understand that you're going to instruct the witness not to answer, right? MS. MCCAWLEY: Yes. SPECIAL MASTER: So that will have to be dealt with in front of Judge Lynch for a subsequent time because I do think that it's Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 32 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 32 incumbent upon, especially on this question, it's incumbent upon you to lay the predicate as to why you're instructing the witness not to answer. MS. MCCAWLEY: And I believe I have. SPECIAL MASTER: I understand. We're not here to do that. So I'm going to, for purposes of the record, I'm going to overrule your objection. And now make your instruction so we have a clean record to deal with. MS. MCCAWLEY: Sure. With respect to because she was an underaged victim at the time, I'm instructing you not to answer questions with respect to her other than identifying her as being one of the victims involved. BY MS. BORJA: Q. Are you going to follow your counsel's instructions? A. Absolutely. Q. And you understand that we're going to reserve the right to bring you back for another deposition in the event that the judge overrules your counsel's objections. Do you still want to keep abiding by those? A. Go for it. Q. I'm sorry? - - Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 33 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 33 SPECIAL MASTER: Yes. Yes. A. No problem. Q. We were looking at the list of names and you were going through to see if they refresh your recollection as to the names of individuals to whom you were sexually trafficked? A. On page 3, number 11, . Q. Who is ? A. I think she also goes underneath the name Kelly Spamm, if it's the same woman that I'm thinking of and she was one of Jeffrey's, I would like to say, co-conspirators. She had sex with underaged girls and myself. Number 12, Jean Luc Brunel. He was not only a witness, but also another co-conspirator. Again, number 13, sounds familiar, but I'm not going to attempt to put her out of place and I'm not too sure. Q. Do you know who the names of the others are, Valdson Cotrin or Chauntae Davies, do you know who they are? A. Chauntae Davies I think I have heard of as another victim, but I don't recall meeting her. Q. Do you know who Valdson Cotrin is? A. No. Q. Okay. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 34 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 34 A. Number 19, Alan Dershowitz; number 22 Eva Anderson Dubin; number 23, Glen Dubin. Q. Before you move on, were you sexually trafficked to Eva Anderson Dubin? MS. MCCAWLEY: This has been asked and answered. SPECIAL MASTER: No, it has not. Overruled. A. No, I was not trafficked to Eva. Number 24, number 25, I believe are . Q. Let my ask you this, were you sexually trafficked to ? A. No. MS. MCCAWLEY: With a question pending, I think she's lost the question, Counsel. Ask the question. MS. BORJA: Okay, counsel, I'll ask the question. MS. MCCAWLEY: Thank you. BY MS. BORJA: Q. The question is, when you look at this list of names does it refresh your recollection as to who you were sexually trafficked to? A. Some of the people that I mentioned, yes. Q. Okay. So, let's continue reviewing the Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 35 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 35 list. I'm looking for the names of the people that you allege you were sexually trafficked to? A. Okay. Number 26, Prince Andrew; number 27, Jeffrey Epstein; number 43, Shelly Harrison, she was an older woman who participated. Q. Participated in what? A. In sexual acts. Q. With whom? A. With Jeffrey Epstein. Q. How do you know that? A. I was there with her. Q. Okay, who else was there? A. Ghislaine Maxwell, Emmy Tayler. Q. Anyone else? A. No. Did I say Sheridan, number 38? Q. No. A. Okay, Sheridan is another one. Q. Is another what? A. Another older woman that was a part of the sexual endeavors. Q. With whom? A. Ghislaine, Jeffrey and me. Q. Anyone else? A. Number 46. Q. I'm sorry, I'm still talking about Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 36 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 36 Sheridan. When you said involved, you said involved with sexual activity with Ghislaine, Jeffrey and yourself. Was there anybody else involved? A. Not that I can remember. Q. Was this a single incident? A. No. Q. Okay. A. Number 46, Sarah Kensington, formerly known as Sarah Kellen, she was involved with, very heavily involved with lots of incidents of sex. Q. With yourself? A. With myself. Q. And who else? MS. MCCAWLEY: To the extent you can answer. If it's multiple incidents you can take them one at a time. A. It was multiple incidents so it's going to be nearly impossible for me to remember every one. But obviously Jeffrey Epstein, Ghislaine Maxwell, Les Wexner, Brunel, Jean Luc Brunel. I'm sure there's more, but I just can't remember off the top of my head. Q. How do know that she had sex with Les Wexner? A. I was there. Q. How do you know she had sex with Jean Luc Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 37 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 37 Brunel? A. I again was there. Q. How many times did you and Les Wexner and Sarah Kellen have sex together? A. Once that I can remember. Q. Where were you? A. New Mexico. Q. Are there other witnesses? A. Number 48, , I can't pronounce her last name. Q. ? A. , yes. Q. Anyone else? A. Number 50, MS. MCCAWLEY: I'm sorry, I think she's moving on with the list. Are you still talking about the incident? BY MS. BORJA: Q. I understand was a witness to your sexual activities with Les Wexner in Mexico, is that not what you meant? A. Yes. Q. She was a witness? A. Yes. Q. Was a witness? - Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 38 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 38 A. No, I'm sorry. I was moving on with the list. Q. What is the sexual incident involving A. Palm Beach and the Caribbean with Jeffrey, myself, possibly Sarah Kellen if I remember correctly, there was another girl, I'm pretty sure it was Sarah. Q. Were you sexually trafficked to anybody else on the list? A. I'll continue with the list here. Nadia Marcinkova I was not sent to her, but she was a part of it with Jeff Epstein, Marvin Minsky, Tom Pritzker. Q. Who is Tom Pritzker? A. He, I don't know exactly what he does, but I think he's some kind of academic. Q. Did you have sex with him? A. Yes. Q. How many times? A. Off the top of my head, just once. Q. Where were you? A. I believe Tom was at Mexico. Q. Approximately how old were you? A. Again, I don't know. Q. Are there any other witnesses? A. Not that I can remember. I mean, besides Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 39 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 39 Jeffrey asking me to give him a massage which involved sexual acts, I don't remember. Joanna Sjoberg was another victim of Jeffrey Epstein who witnessed sexual acts. Q. Witnessed sexual acts between you and somebody else? A. She is another victim that I would like to say that I wouldn't like to mention the stuff that happened to her. She's very sensitive about this stuff. Q. That's fine, but I'm wondering if she's a witness to sexual acts that you allege were between you and somebody else? A. Other than Epstein, no. I mean, she did see the meeting with Prince Andrew, but she did not witness the act with him. Q. Okay. A. Kelly Spamm is, I believe that be which is number 81, and I've already explained that one. Number 85, Emmy Taylor, she witnessed many acts of sexual abuse by Ghislaine Maxwell, Jeffrey Epstein. Number 92, Larry Visosky is the pilot. I don't believe he witnessed anything, but he was flying during some of the times that sexual abuse encountered. Q. Do you know why Les Wexner is not on this - - Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 40 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 40 list? A. I haven't seen this list before, so, no. MS. MCCAWLEY: This is a good time to take a break. MS. BORJA: The time is now 9:45. THE VIDEOGRAPHER: Going off video record 9:49 a.m. (A recess was taken.) THE VIDEOGRAPHER: We are now back on video record 10:01 a.m. MS. MCCAWLEY: Did you mark this? MR. SCAROLA: Yes. MS. MCCAWLEY: That's 2. BY MS. BORJA: Q. Ms. Roberts, did you have an opportunity to talk to anybody other than Ms. McCawley during the break? A. Yes, I spoke with my good friends over there. Q. Who are? A. Brittany Henderson and -- MS. MCCAWLEY: Meridith. BY MS. BORJA: Q. Anyone else? A. Brad Edwards. I'm sorry, I forget he came in. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 41 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 41 Q. Now, do you have knowledge of Professor Dershowitz having sex with any minor girls other than, you claim, yourself? A. Yes, I don't know their names. Q. How do you know that? A. I witnessed it. Q. Where were you? A. On an airplane. Q. How many girls? A. One. Q. Describe her? A. Blond, young. Q. Anything else? A. No. Q. Where were you going on this plane? A. You know, it's hard for me to remember the exact destination. I was flying around a lot from the times I was with Jeffrey, but I believe it was to Massachusetts, if my memory is correct. Q. Why were you flying to Massachusetts? A. Again, I don't want to -- I don't know. I just flew wherever Jeffrey wanted fly to. Q. Did you stay in a hotel in Massachusetts? A. No, we flew in and flew out the same day. Q. Who else was on the plane? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 42 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 42 A. Epstein. Q. Where were you coming from? A. I believe it was New York, but again, I don't want to 100 percent say, like I said we were constantly flying. Q. Was it winter time, was it summer time? What do you recall about when it was? A. It wasn't snowing so I'm not too sure. This is going back a long time ago. I don't know the date. Q. What's your best recollection of how you were dressed? A. I don't know what I was wearing. Q. Did you have a sweater? A. I don't know what I was wearing. Q. Were you over 18? A. I don't know, I'm sorry. Q. You might have been? A. I could have been. I could have been under 18, over 18. Q. The other girl, she could have been over 18? A. She could have been, she could have not been. Jeffrey liked having a lot of young girls around him. I'm not too sure. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 43 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 43 Q. You don't know one way or the other whether the girl was a minor? A. I didn't ask her the age. Q. Other than the girl you're not sure whether she was a minor, are there any girls you are sure were a minor who you think had sex with Professor Dershowitz? A. Not that I know of. Q. So would it be correct that you actually don't know one way or the other whether Professor Dershowitz had sex with any minors other than you claim yourself? MS. MCCAWLEY: Objection. You can answer. A. Yeah, I don't know. It would hard to say. Jeffrey, like I said, had lots of young girls around all the time and some of them were very young and some of them were on the cusp of 18, 19. So it's very hard to speculate how old exactly she was. Q. So you don't know? A. I don't know. Q. Other than yourself, Jeffrey, Professor Dershowitz and this other woman of unknown age, was anybody else on the plane besides the pilot? A. Pilot. Q. That's it? A. Yes. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 44 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 44 Q. Putting aside ages, whether they were minors or not, other than this one girl you say had sex with Professor Dershowitz on a plane, are you aware of any other girls with whom you believe Professor Dershowitz had sex? A. Professor Dershowitz was around a lot and there was always young girls around a lot and I physically did not see him with any other girls besides the ones that we're talking about right now and myself, but no, I'm not too sure. Q. You don't know of any, correct? A. Not that I physically witnessed. Q. How tall is Professor Dershowitz? A. I don't know. Q. Is he closer to 5'5" or 6"? A. Goodness, 5'5", 5'6", 5'7", he's not 6". Q. Does he have any distinguishing characteristics? A. Like are you asking me skin color? Q. Any distinguishing physical characteristics, whatever that might mean to you? A. He's older, he's -- I don't know what you mean. Like does he have a mole in a specific place, is that what you're asking me? Q. Anything that might occur to you? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 45 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 45 A. No, not that I know of. Q. Did you know who he was before you met him the first time? A. No. Q. Now, one of the places that you say you had sex with Professor Dershowitz was in New Mexico, correct? A. Yes. Q. When was that? A. Again, it's hard for me to place exact times and dates, but it wasn't snowing and it wasn't hot. So it could have been fall or spring. One thing that I do remember was Jeffrey was having his pool area painted and the massage room was just off the pool area. Q. What else do you remember? A. I remember the smell of paint. I remember later that evening there was a dinner party of a whole bunch of academic scientists, I guess, I'm not too sure. We weren't really allowed to have and make conversation with the people around us. Q. How many people were at this dinner party? A. I don't know the exact number, but over fifteen. Q. Anybody that you recall, anybody famous? A. No, nobody famous that I recall, I'm just showing that they are distinguished in their own way, but Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 46 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 46 besides Alan Dershowitz, Jeffrey Epstein, Ghislaine Maxwell, Emmy Tayler, the house staff. Q. Now, you said there was a dinner party with scientists and academics? A. Yes. Q. Were any of the scientists and academics that we talked about early today at that party? A. Not that I remember. They could have been, but I was not there for anyone else. Q. How did you get there? A. By airplane, Jeffrey. Q. You flew privately for that event? A. Yes. Q. How did you leave? A. Privately. Q. How long were you there? A. Maybe anywhere between three days and a week. Q. So at least three days? A. At least three days. Q. Who else was on the plane with you? A. Jeffrey Epstein, Emmy Tayler, Ghislaine, myself, the pilots, possibly, Adam Perrylang, I can't remember. He was on the plane sometimes and sometimes not, so. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 47 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 47 Q. Can you spell Adam's last name? MS. MCCAWLEY: If you know. A. Off the top of my head, P-E-R-R-Y-L-A-N-G. Q. Who is Adam Perrylang? A. A chef. Q. Was Professor Dershowitz on the plane? A. No. Q. How did you know -- well, was this the first time you had met Professor Dershowitz? A. No. Q. How many times had you met him before this event? A. Dershowitz was around a lot. So I mean, I couldn't count how many times I've met him. Q. What's your best recollection? A. Are you asking me to guess? Q. I'm asking for your best recollection? A. I couldn't give you a number. I'm not too sure. He was around a lot. Q. When you say he was around, what do you mean by that? A. He obviously did a lot of work with Jeffrey. I'm not too sure what that work was. Q. Did you ever talk to him? A. I was introduced to him. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 48 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 48 Q. When were you first introduced to him? A. I believe the first time I was introduced to him would have been in New York. Q. Putting aside that first introduction, did you ever have a conversation with Professor Dershowitz? A. Besides formalities, no? Q. Did Professor Dershowitz tell you why he was in New Mexico? A. No. I'm assuming there for the conference or the get together, the politicians get together, not politicians, sorry, academic get together. Q. How did you know this was an academic get together? A. Because they were talking about, most of the things, I can't really understand, just scientific stuff. Q. Were you there for that portion of the evening? A. Yes. I ate dinner at the table. Q. Was there anything other than the dinner that was going on during this three-day to one week stay in New Mexico? A. Generally they're always was. I mean, I would do horseback riding, I would go for walks. If you're asking if there was another event, no, but that Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 49 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 49 was one of Jeffrey's places he liked to stay. Q. Where did Professor Dershowitz stay? A. Upstairs in the room. Q. How long did he stay? A. I'm not too sure. Q. What's your best recollection? A. I only remember seeing him there for a day? Q. And you didn't see him -- was this dinner party at the end of the your trip there? A. The first day. Q. So then after the first day you didn't see Professor Dershowitz again? A. I didn't see anyone else except for obviously Epstein, Maxwell, Tayler, the house staff. Q. How many people other than Professor Dershowitz stayed at the ranch during this trip? A. Nobody else stayed except for the people I just mentioned. Q. I'm sorry, I thought that Professor Dershowitz spent the night? A. He could have spent the night, but I'm saying I didn't see him the next day. I don't know if he left that day or I don't know if he stayed the night, but all the rooms were upstairs. If he would have stayed, he would have stayed upstairs. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 50 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 50 Q. So you don't know one way or the other whether he did stay? A. No, I don't know whether he did stay. Q. What year was this? A. I don't know. I was with Jeffrey from 1999 until 2002. So it's a broad spectrum of trying to remember times and dates. Q. You definitely remember this dinner party, right? A. Yes. Q. You remember that there were 15 or so academics and scientists, right? A. Yes. Q. And you remember that you had sex with Professor Dershowitz, right? A. Yes. Q. You remember everybody left after that dinner party, right? A. Yes. Q. So what would help you fix this in your mind, had you already met Prince Andrew before this dinner party? A. You know, I don't think so, but I don't think so. Q. Why do you say that? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 51 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 51 A. Because Prince Andrew happened when I was 17, you know. I can't 100 percent say if it happened before or after and me trying to pin point that down just wouldn't work. Q. Did you tell anybody about having sex with Professor Dershowitz? A. Besides Epstein? Q. So you told Epstein? A. Yes, Epstein. Q. Did you tell anybody else? A. Maxwell. Q. Anyone else? A. I told my boyfriend at the time that I had met him. Q. Who was your boyfriend at the time? A. Tony Figueroa. Q. You didn't say anything else other than you had met Professor Dershowitz? A. I told him I was very upset from one of the things I had to do but he didn't fully comprehend what I was talking about. Q. Did you tell anybody else? MR. SCAROLA: Excuse me, can you set a time frame? BY MS. BORJA: Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 52 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 52 Q. At any time in your entire life? A. Oh, at any time? MR. SCAROLA: Are we excluding attorney/client privileged communications? BY MS. BORJA: Q. Other than your attorneys, did you tell anybody else? A. Yes, I told my best friend, Rebecca Boylan, my husband, Robert Giuffre, my mother, I think that's about it. Q. When did you tell your mother? A. Within the last couple of years. Q. What did you tell her? A. I didn't go into details with her. I just said that he's one of the people that abused me. Q. Did you say anything else to your mother about Professor Dershowitz other than generally he abused you? MS. MCCAWLEY: Objection, asked and answered. SPECIAL MASTER: You can answer. A. No, just I mean, obviously characterization about who he is and what he is, but I didn't go into details with her, if that's what you're asking. Q. What did you tell Rebecca? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 53 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 53 A. That he was one of my abusers. Q. Did you say anything else? A. About Dershowitz? Q. Yes. A. In regards to what? Q. Did you say anything else about Professor Dershowitz to Rebecca? A. I need a little more specifics. Did I tell her about the details? Q. Anything else about Professor Dershowitz, anything? I'm not excluding or narrowing it in any way? MS. MCCAWLEY: Objection. To the extent you can answer that. A. I told her who he was, I told her -- I might have told her specifics I'm not too sure. I can't recall. We're going back make over a year ago. Q. When did you have -- how many conversations did you have with Rebecca about Professor Dershowitz? A. It wouldn't be like full blown conversations like long talks about it. It would be more from girlfriend to girlfriend, just, you know, this is what's happening in my life. You know, these are one of the people that abused me. These are one of the people that I'd like to get brought to justice for it. She would ask me questions like, what happened? I explained Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 54 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 54 to her what's going on. I don't know how many times I've had conversations with her. Q. About Professor Dershowitz? A. About Professor Dershowitz. Q. Is Rebecca a truthful person? A. I used to think she was. Q. You don't think that now? A. No. Q. Have you had a falling out with Rebecca? A. Yes. Q. Have you called Rebecca and told her not to talk to Professor Dershowitz? A. Not in that way. I told her, I can't believe that you are talking to somebody, in my own words, a pedophile. Q. Did you tell her not to talk to anyone else about Professor Dershowitz? A. Did I tell her not to talk to anybody else about Professor Dershowitz, like talking about her husband? Q. Did you tell Rebecca not to talk to anybody about Professor Dershowitz? A. Did I tell Rebecca not to talk -- MS. MCCAWLEY: Objection, to the extent you didn't understand the question you can ask for it Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 55 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 55 to be re-asked. A. Can you -- I don't understand what you're asking. Q. Why did you think that Rebecca was a truthful person in the past? A. I've known her since I was a kid and I love her like a sister. Q. In your experience in knowing her since you were a kid you found her to be truthful? A. Yes, I have. Q. When did you first tell Tony Figueroa about Professor Dershowitz? A. I believe I was on the island, Jeffrey's island. Q. What's your best estimate of when this was? A. I don't know. It's always hot in the Caribbean so I can't pin point a season. Q. Did you tell Rebecca that Professor Dershowitz, in your words, was a pedophile? A. Yes, I did. Q. Did you tell anybody else that? MS. MCCAWLEY: Outside of the comments to the lawyer. BY MS. BORJA: Q. Other than your lawyers? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 56 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 56 A. The people that I've told you, my mom, my husband, as you said Rebecca, Michael, her husband might have been present on some of those conversations, but I'm not too sure if he was. Just my lawyers. Q. Did you ever tell the press that you had had sex with Professor Dershowitz? MS. MCCAWLEY: Objection. Any questions regarding the press were already quashed by the judge and we have an order standing on that so there will be no questions regarding the press. MS. BORJA: There is no such order from the Court. MS. MCCAWLEY: There is and I'll be happy to pass it out. SPECIAL MASTER: Can you please share? MS. MCCAWLEY: They issued a subpoena duces tecum and he quashed certain discovery requests and that's included, any discovery relating to press. Here is a chart that has the request for the ones that should be quashed. SPECIAL MASTER: I've read this. I've read -- MS. MCCAWLEY: Those that have the numbers he quashed. He quashed certain categories of discovery. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 57 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 57 MS. BORJA: Can I be heard? SPECIAL MASTER: Are you finished making your objection? MS. MCCAWLEY: I just want to be clear that there are certain categories of discovery that he quashed in response to my motion to quash this deposition, and he narrowed out categories that were not subject to discovery in this case for this non-party witnesses. SPECIAL MASTER: Okay. And I'm looking at both the order and a chart that was provided by MS. MCCAWLEY? MS. BORJA: That's a duces tecum. The judge ruled on the production of documents. The judge did not narrow the scope of testimony of a fact witness in that way. She was not required to produce certain documents. We're certainly entitled to check the veracity of the witnesses' testimony. SPECIAL MASTER: I'm going to overrule the objection. You can answer. MS. MCCAWLEY: Can we take a break? MS. BORJA: There's a question pending. You cannot take a break while there is a question pending. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 58 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 58 MS. MCCAWLEY: We are going to take a break because this is a judge's order and we're going to determine whether we need to call Judge Lynch at this time to deal with this order. So we are going to take a break at this time. MS. BORJA: I object to taking a break while there's a question pending. SPECIAL MASTER: Well, I'm going to let her take a break so she can make her record. I need to allow her to protect it. MS. BORJA: Can you put the time on the record? THE VIDEOGRAPHER: Going off video record. 10:23 a.m. (A recess was taken.) THE VIDEOGRAPHER: We are now back on video record 10:30 a.m. SPECIAL MASTER: There was a question pending. THE WITNESS: Would you like that to be answered now? MS. MCCAWLEY: Really quickly I want to make my record in advance of her answering that. We believe that the questions, this line of questioning is in violation of Judge Lynch's order Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 59 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 59 where he struck certain requests relating to the subpoena, and we have a standing objection to that that we'll take up with Judge Lynch, but at this time we'll allow her to answer the question subject to our ability to strike that testimony as a result of it being non-applicable here because of his prior ruling. SPECIAL MASTER: So you understand my ruling, I've reviewed, I've had an opportunity to review both the original objections made, the series of objections made to the duces tecum, the order, as well as the chart that was provided by Ms. McCawley with respect to what was stricken on the subpoena, and for the purposes of the record we'll go ahead and have this marked so we can preserve the record as to what I'm referring to, my ruling. MS. BORJA: We can make them a compellation Exhibit VR 3. (Thereupon, Defendant's VR Exhibit No. 3, was Marked for Identification.) SPECIAL MASTER: My ruling stands, and I don't have an issue with you having a continuing objection, but the witness now can answer. MS. MCCAWLEY: Do you want the question Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 60 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 60 read back to you? THE WITNESS: No. Should I just go ahead and say it? SPECIAL MASTER: Go ahead and read back the question? (Last question read back by the court reporter.) SPECIAL MASTER: Subject to the continuing objection, you can now answer. A. I thought the question was if I ever called him a pedophile to the press. Wasn't that the question? SPECIAL MASTER: No. A. I did point him out to a journalist as one of my abusers. Q. What journalist? A. Sharon Churcher. Q. When did you do that? A. I believe it was 2011. Q. What did you tell Ms. Churcher? A. I just pointed him out. Q. What do you mean? A. I was given a picture to look at and he asked me which ones that I recognized as abusers and Alan Dershowitz was one of those. Q. How many pictures did you look at? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 61 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 61 A. I'm not too sure. Q. What's your best recollection? A. Over 40. Q. Did you pick out anybody else as one of your abusers? A. Yes. Q. Who was that? A. Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, Glen Dubin, Prince Andrew, I believe, that's all I can remember for now. Q. Was one of the pictures of Les Wexner? A. Possibly, yes. Q. Was one of the pictures Richardson, Bill Richardson? A. Again, possibly, yes. Probably, I'm not committing 100 percent to that, I can't remember exactly who she showed, but if they were there I would have pointed to them. Q. Was one of the pictures of ? A. Again, possibly yes. If they were there I would have pointed them out. Q. Where did these pictures come from, do you know? A. No. Q. Were the people that were in photos that Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 62 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 62 you did not identify as individuals to whom you had been sexually trafficked? MS. MCCAWLEY: Objection. You can answer. A. Yes. Q. Tell me everything you can recall telling Sharon Churcher about being sexual trafficked to Alan Dershowitz when you met with her in 2011? MS. MCCAWLEY: Objection. I just want to be clear that I have a standing objection to this line of questioning. SPECIAL MASTER: So noted. You can answer. A. I just identified him. I don't think we actually got into any kind of details. It was going through a book of people kind of like the FBI does and pointing out. She was more interested in Prince Andrew. Q. You met with Ms. Churcher for about a week; is that correct? A. Yes. Q. During the course of that week did you give Ms. Churcher any documents? A. Yes, I had given her some pages out of a booklet that I had wrote concerning Prince Andrew. Q. What is this booklet that you wrote? A. She contacted me and asked me to recall the times that I was with Prince Andrew and I wrote them down Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 63 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 63 and I gave them to her. Q. When did Ms. Churcher first contact you? A. It would have been 2011. Q. What did she say when she first contacted you? A. She introduced herself. She asked me if I was a victim of Jeffrey Epstein. She was interested in how he got away with so many counts of abusing minors, and seeing that I was one of the minors she wanted to talk about that; and when she came over or before she came over she asked me about some of the people I had been with. I had said, well, I've got a picture of myself with Prince Andrew and she was very interested and she came over and wrote the article. Q. Now, the picture that you had of Prince Andrew, that's an original photo that you developed, correct? A. Yes. Q. Do you still have the original? A. It's been passed around a lot. I'm not too sure if mine is the original or not anymore. Q. The photographs of you in New Mexico in the snow wearing your red jacket were those taken on your camera? A. Yes, my camera. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 64 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 64 Q. Do you have the originals? A. Again, between the FBI and giving them to my lawyers and Sharon Churcher, the circulation, I'm not too sure if I have the originals. I know I have copies. So I'm not too sure if they're the originals. Q. The booklet that you gave pages from to Ms. Churcher where is that booklet? A. Burned. Q. When did you burn it? A. In, I think it was 2013. Me and my husband had a bonfire. Q. What did you put in the bonfire? A. Any kind of memories that I had written down about all the stuff going on. Q. Had you written anything about Professor Dershowitz? A. He could have been there, yes. Q. And you burned that? A. I wanted to burn my memories. I wanted to get rid of it. It was very painful stuff. Q. Other than what you had written down did you burn anything else? I don't mean the wood, when you talk about burning your memories, what were you burning? A. I was burning like memories, thoughts, dreams that I had, just everything that was kind of Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 65 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 65 affiliated with the abuse I endured, and there was a lot of it in there. My husband is pretty spiritual so he said the best thing to do would be burn them. Q. Is there anything you decided to keep and not burn? A. Just the photographs. Q. Anything else that you can think of? A. Photographs, that's it. Q. Approximately when in 2013 was this bonfire? A. I don't know what month it was. Q. Did you do it outside? A. Yeah, it was outside. I wasn't going to do it in my living room. Q. Did it feel good to be close to the fire because it was cold out or was it a summertime bonfire? A. I believe I had just bought my house in Titusville, Florida. I bought my house in, I think, I either got it October or November of 2013. It would have been around probably November. Q. Why did you decide to keep the photos? A. They're evidence. Q. Do you have any photographs of yourselves with Professor Dershowitz? A. No. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 66 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 66 Q. Do you have any photographs of yourself at any of the locations at the times that you allege Professor Dershowitz was there? A. Like there's not photographs of Dershowitz. Q. Showing that you were at the locations at the time that you say Professor Dershowitz was there regardless of whether or not he was in the photograph? A. I'm not too sure, I mean, it could have been the same week. I always carried around cameras so I took lots of pictures of everything. It could have been the same week, but he was definitely not in the photographs. Q. After you gave Ms. Churcher the pages from that booklet did she give you a copy of those back? A. I don't think so. Not that I remember. Q. You gave her the original pages? A. Yes. Q. Are those the same pages that showed up in Radar Online? A. Yes. Q. How did they get them? A. Not by me. Q. Did you get paid for them? A. No, not for those. Q. You got paid for Ms. Churcher's interview? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 67 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 67 MS. MCCAWLEY: Again, I just want to make sure that I have a standing objection to all of the testimony relating to the media. A. Specifically I got paid for the picture. Q. The picture of yourself with Prince Andrew? A. Yes. Q. Was there a contract? A. I believe so. Q. Who negotiated that? A. Just Sharon and myself maybe the place that she works, I'm not too sure. Q. You told the FBI that you got $160,000 for that, is that right? A. Yes. Q. And is that a correct statement? A. It was 140 and then for the articles $10,000, and then $10,000. Q. So how does the picture fit into that? A. What do you mean? Q. You said it was 160 for the photo? A. No, 140 for the -- Q. For the article? A. Well, for the photograph and articles and then for the other articles, I don't think she just printed one article, I think she printed like three Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 68 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 68 articles if I recall correctly, but for the other one it was $10,000 and then $10,000. Q. Were you paid for any other media interviews? A. No. SPECIAL MASTER: There is a standing objection to all this. MS. MCCAWLEY: Yes. BY MS. BORJA: Q. Did Ms. Churcher give you any documents? I know she showed you pictures, did she give you anything? A. No. Q. Did Ms. Churcher tell you anything about Professor Dershowitz? A. No. Q. Other than you've named your mother, your boyfriend, Mr. Figueroa? A. Yes. Q. Your friend Rebecca and Sharon Churcher? A. And my husband. Q. Your husband, and putting aside your lawyers, did you tell anyone else that you were sexually trafficked to Professor Dershowitz? A. The FBI. Q. What did you tell the FBI? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 69 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 69 A. I just remember -- my memory recalls they did show me a photograph of everybody, if he was in those photographs I would have pointed him out. I'm just saying I could have possibly pointed him out in the pictures. Q. But do you recall doing that? A. I just know there was a lot of pictures and if he was in there I would have pointed him out to them. Q. Do you recall having any discussions with the FBI about Professor Dershowitz? A. I had discussions about a lot of people with him and I specifically don't remember if it was just -- if Alan was included in those, but if he was I would have told them what I know. Q. Did you talk to the FBI more than once about Professor Dershowitz? MS. MCCAWLEY: Objection, mischaracterizes the testimony. SPECIAL MASTER: You can answer. THE WITNESS: Does that mean go ahead? SPECIAL MASTER: Yes. A. I only met with the FBI one time, so no. Q. When you say that if you've been shown a picture you would have identified Professor Dershowitz you're talking about an in-person meeting in April 2011? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 70 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 70 A. I don't recall if it was April, but yes, I think it was 2011. Q. Shortly after the article in the Daily Mail came out? A. I think after about two weeks. Q. What else did you tell the FBI about being sexually trafficked? A. I've told them everything that I could remember at the time from the period of the years I was with Jeffrey Epstein. Q. Did you tell them about a prominent prime minister? A. Yes. Q. Did you tell them about heads of state? A. I'm not too sure what a head of a state is. Q. Did you tell them about prominent politicians? A. Yes. Q. Did you name them? A. Yes. Q. Did you tell the FBI about prominent business people? A. Yes. Q. Did you name them? A. Yes. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 71 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 71 Q. What were the names of the politicians that you gave to the FBI? A. The same names I've given to you. Q. What were the names? You gave the FBI the name Bill Richardson? A. Yes. Q. And you gave the FBI the name ? A. Yes. Q. Which prominent businessmen names did you give the FBI? A. Glen Dubin, I mean, we're going back over a list that's very hard to continually go over, but Jean Luc Brunel, Glen Dubin. I'm trying to remember, but I'm having a blockage. I'm sorry. Q. Did you name Les Wexner to the FBI? A. Yes. Q. Did you name any academicians specifically that you recall? A. I named . I mean, anyone that they would have pointed out to me and asked me I would have told them truthfully who I was with and what happened. I can't remember exactly who they showed me, I can't remember exactly who I told them about, but if they were there I would have told them. - Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 72 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 72 Q. Did the FBI ask you about Bill Clinton or Al Gore? A. I do believe they did ask me about Bill Clinton, but I cannot remember the exact conversation we had about him. Q. I understand you were not sexual trafficked to Bill Clinton; is that correct? A. Correct. Q. Did Sharon Churcher ask you about Bill Clinton or Al Gore? A. I believe they did. Q. How many times did you meet Bill Clinton? A. Twice. Q. How many times did you meet Al Gore? A. Once. Q. You're meeting with Bill Clinton what was the first one? A. I don't know the exact date. I know it was towards the end of my period with Jeffrey. I'm sorry, I can't give you a date. Q. The end of your period with Jeffrey is September 2002, correct? A. That was, yeah, when I left. Q. That's the first time you meet Bill Clinton, towards the end of that period? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 73 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 73 A. No, it wasn't September. I'm not saying it was September. I'm saying it was around that period. If I was going to place times around something it would be towards the end of that. Q. Where were you the first time you met Bill Clinton? A. On Little Saint Jeff's, which is the island. Q. Little Saint James? A. He used to call it Little Saint Jeff's, sorry. Q. Meeting Bill Clinton? A. Generally or specifically about his personality? Q. Where were you on the island when you met him? A. We had a dinner together. Q. Who was at that dinner? A. Ghislaine, Emmy Tailer, Jeffrey Epstein, myself and two girls that I do not know who they are. Q. This is the meeting with Bill Clinton that's been described in press articles; is that correct? MS. MCCAWLEY: Objection. Go ahead. You can answer. SPECIAL MASTER: You can answer. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 74 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 74 A. Sorry. Confusing legal stuff. Yes, I believe it has been circulated. Q. You had a second meeting with Bill Clinton? A. Yes. Q. When was that? A. I believe very close together, within weeks if not months. Q. Where was it? A. Little Saint Jeff's. Q. What were the circumstances of your second meeting with Bill Clinton? A. Very similar, I mean, there was a dinner, lots of laughing, lots of joking, it was just a dinner and then I didn't have to do anything with Bill Clinton, he was never sexually involved with me. I've never witnessed him sexually involved with anybody else. Jeffrey asked me for a massage after dinner and I went off to Jeffrey's cabana. Q. Who was at that dinner? A. Ghislaine, Jeffrey Epstein, myself, Clinton, I believe there were -- there were some other guys, they were down by the beach. I'm not too sure who they were. I assume they were security of some sort. They weren't there at the dinner. There were two girls. Q. So each time you had dinner with Bill Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 75 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 75 Clinton there were two girls; is that correct? A. From my recollection, yes, only two. Q. And describe the two girls at the first dinner? A. Young, beautiful like every girl that's generally around Jeffrey. Q. Are you able to identify them? A. Possibly if I was shown pictures, but I don't know their names. You need to understand, when I was with Jeffrey we were specifically told not to make friends, not to talk other than small talk. But we weren't like, hi, my name is Susan and I'm 15 or 19. We weren't like that. Q. Was there any security at this first dinner? A. Not at the table, but they always stayed around the beach. Q. Who were the two girls at the second dinner? A. It sounds funny, but I thought that they were sisters they looked so much alike. They had -- they were beautiful, they were youngish. I don't know exactly their age, but they were -- I don't know, it's hard to say, anywhere between 17 and 21, but I don't know their names. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 76 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 76 Q. Was it the first dinner that Ghislaine Maxwell flew the helicopter with Bill Clinton to the island? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer if you know. A. I was only told that. I'm not too sure if she actually did or not. I never witnessed Ghislaine flying him, but she said she did. Q. And did you hear Bill say that she was a good pilot? A. I remember her saying he thought she was a good pilot but I never witnessed it myself. Q. So it's possible she wasn't flying Bill Clinton in a black helicopter, that could be false? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. To my knowledge Ghislaine and Jeffrey talk a lot, they say things that are sometimes hard to believe. Some are actually true, so I don't know. Q. The second dinner, how did Bill Clinton get there? A. Either by boat or by helicopter. There's only two ways to the island. Q. So you don't know? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 77 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 77 A. No. Q. Tell me the circumstances of meeting Al Gore? A. It's a little hazy at where that took place. I mean, we are going back a long time ago, but I do remember one thing about him, I thought he was a wonderful guy who loved his wife and they spent the entire time like there was nothing else around them, it was just those two. It was a dinner table, a long dinner table with people around, but they were just lovely, just watching them as a couple. I remember thinking, you know, he's somebody that I would definitely vote for. He's just somebody that loves his wife that much. Q. What was the purpose of this dinner? A. As usual I'm not told these kind of things. I'm just kind of there to sit down and look pretty and keep my mouth shut. Q. Who else was there? A. I'm not too sure. Q. This was on the island, right? A. It could have been the island, but I could be mistaken if it was the island. It could have been New York. I'm not going to commit myself to saying it was definitely the island. My memory is still hazy when it Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 78 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 78 comes to locations or places. We were traveling everywhere a lot. Q. And I understand that at some point you were using Xanax, correct? A. Correct. Q. At some point you were up to eight Xanax a day, correct? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. I was suffering a lot mentally coping with what was happening and when I took Xanax it helped me forget a lot of things that I didn't want to think about for that day and it did help. Q. At some point you were using eight Xanax a day as part of your -- A. To start with I was only taking one or two, but yes, it did get up to eight in the end. Q. Did it affect your ability to recall certain events? A. I would say any drug is going to do that to you. So, yes, you know, but I can tell you a thousand percent that just because I might not remember a location or a time doesn't mean I don't know a thousand percent the people that I was with or the people that abused me. Q. You told the FBI that it affected your Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 79 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 79 ability to recall certain events, correct? A. Yes. MS. MCCAWLEY: Objection. Give me a chance to object. BY MS. BORJA: Q. Do you know approximately when you were up to eight Xanax a day? A. Towards the end. Q. What does that mean to you? A. Probably from 19 onwards or no, sorry, 18 onwards. Q. Were you using any other medications or drugs in order to address your pain and suffering? A. I did smoke marijuana and sometimes at parties I would use Ecstasy. Q. Anything else? A. No. Q. How often were you smoking marijuana? A. Considering I was with Jeffrey most of the time, not then, but whenever I went back to Palm Beach to see my boyfriend. Maybe once a week out of a month. Q. How often were you using Ecstasy? A. At parties. I don't know. I mean, it wasn't a regular basis, it was because if I was at a party with a whole bunch of kids. If it was there, I Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 80 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 80 would take it. Q. Did you use it during times what you were being sexual trafficked? A. No. Q. How often were these parties when you were taking it? A. How often were the parties? It varies, it could be -- like are we talking about yearly basis, because it wasn't every month. Q. Okay. During the time frame 1999 to 2002? A. Probably about fifteen parties. That's a rough estimate. No way is that a certain number. Q. Other than the marijuana, the Ecstasy, and the Xanax were there any other medications, or alcohol that you were using? A. Oh, alcohol, yes. I was drinking alcohol at the parties. Q. Did you drink alcohol outside of parties? A. Sometimes. Q. At the dinners? A. Sometimes. Q. Anything else? A. No. Q. Did you -- you mentioned that you were about one week in your apartment with Mr. Figueroa. Was Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 81 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 81 that a consist arrangement through the period? A. No, no, I'm just roughly saying that, you know, if I was home with Tony, at my apartment with Tony and it was for a week, that would be how long I smoked marijuana for. I wasn't saying specifically I was there for a week. It could have been three days, it could have been five days, it could have been seven days, I'm not too sure. Q. Between 1999 and 2002 how many places did you live? A. Like my own or like Jeffrey's residences? Q. Putting aside when you were staying at a home, one of the mansions that Mr. Epstein owned, how many places did you live? A. Just one. Q. That was an apartment building? A. Actually, let me correct that. At first I lived at my parents house and then I got an apartment. Q. You lived at that apartment the entire period between 1999 and 2002? MS. MCCAWLEY: Objection. Go ahead. A. Besides my parent's house, yes, that's the only place I lived. Q. During what period did Mr. Figueroa live with you? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 82 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 82 A. On and off, but from, I don't know when our relationship actually started. I think I was with Jeffrey before. Yes, I was with Jeffrey already. Q. So on and off between 1999 and 2002? A. Yes. Q. Is Mr. Figueroa a truthful person? A. I believe so. Q. Why did you say -- what's the basis for your statement earlier that you didn't think Mr. Figueroa understood what you were telling him about Professor Dershowitz? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. He was my boyfriend and I didn't really get into too much details with him. Q. But you specifically named Professor Dershowitz as one of your abusers? A. Yes. Q. Did you name other abusers to Mr. Figueroa? A. Yes. Q. Who did you tell him was sexually abusing you? MS. MCCAWLEY: Objection. Mischaracterized the testimony. SPECIAL MASTER: You can answer if you can. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 83 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 83 A. The same people that I've named to you. He wouldn't have understood some of the names, he wouldn't have known who they were, but anyone prominent such Prince Andrew, he would have recognized that. But generally I would call him every day when I was with Jeffrey and tell him what happened. Q. You would say the names of the people you had sex with? A. Sometimes, I mean, you know, sometimes I would just say I've had a really hard day, that is what I've had to do and we wouldn't get into names. Sometimes I would. Q. Tell me about the first time you met Professor Dershowitz? A. Are we talking sexually or just introduced. Q. The very first time you ever met Professor Dershowitz? A. I believe it was in New York in Jeffrey's office. Q. What were the circumstances of you being there? A. To please Jeffrey. Q. What were the circumstances of Professor Dershowitz being there? A. No idea, I never asked about the business. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 84 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 84 Q. Who else was there? A. House staff, Ghislaine, Emmy. Q. In this office with yourself Professor Dershowitz and Jeffrey Epstein? A. I don't know exactly who was in there. I'm just saying who was at the house. I'm not too sure who was in the office. I remember being introduced to him in Jeffrey's office, and no, I cannot recall anyone else being there. Q. What office is there? A. In his mansion in New York. Q. Can you tell me where that office is? A. Up a flight of stairs to your left. Q. How long was this meeting? A. Short, brief. I was already in there with Jeffrey when Dershowitz walked in and I was introduced. Q. How long was this meeting? MS. MCCAWLEY: Objection, asked and answered. SPECIAL MASTER: You can answer if you can. A. Ten, fifteen minutes. Q. When was the next time that you met Professor Dershowitz? A. This is very hard for me to remember. Like I said, he was around a lot so I've seen him in Palm Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 85 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 85 Beach, I've seen him in New York. So I mean, if we're going to pin point how many times I've seen him or the next time I saw him after that I don't know. Q. Then tell me -- let's do it this way, what was the most recent time that you recall having sex with Professor Dershowitz? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. The first time I recall having sex with Professor Dershowitz was in New York. Q. My question was, the most recent time now. What's the most current, most recent memory of having sex with Professor Dershowitz? MS. MCCAWLEY: Objection. Just so I'm clear, you're going backward? MS. BORJA: Correct. MS. MCCAWLEY: The last time. A. The last time that I remember having sex with him? Okay. I believe it was on an airplane. Q. Where were you going? A. On, I believe it was Massachusetts. I don't know. It's very hard for me to remember exactly where we were going, what were the circumstances. Q. So that's the time you testified about earlier? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 86 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 86 A. Yes, ma'am. Q. What was the time prior to that? A. You know chronologically it's impossible for me to place these in order. I can tell you about events, but if we're going to say chronologically, correct, it would be impossible. Q. Well, you say there was six times, right, you were very specific about that? MS. MCCAWLEY: Objection. SPECIAL MASTER: Let her get her question out. Go ahead. BY MS. BORJA: Q. You're very specific about that, right? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. I am specific about the fact that I know I have been with Alan Dershowitz at least six times, if not more. Q. So let's talk about what you know about those six times. Let's start with, you can pick any one other than the flight that we've talked about? A. Okay. New York. Q. Okay. Let's start with New York? A. I was upstairs in Jeffrey's room with Jeffrey. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 87 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 87 Q. When you say Jeffrey's room, do you mean his bedroom? A. Yes. Q. Okay. A. There's a shower in the middle of that room and I had just finished having a shower with Jeffrey. Jeffrey got out of the shower, got dressed and left the room. He was wearing sweat pants if I recall and while I'm undressed and drying myself off and drying my hair Dershowitz entered the room and there was some red velvet chair that I remember -- I don't know, is there a certain language you want me to use to describe these events? Q. No. MS. MCCAWLEY: Just use whatever you're comfortable with, that's fine. A. We had sexual intercourse on the chair while I was bent over. Q. How long did that last? A. Less than ten minutes. Q. Did you speak to the Professor? A. Just formalities, but at this time Jeffrey had before trained me to do what he wanted me to do. Q. When you say just formalities, what do you mean? A. Hi, nice to see you again, how are you? I Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 88 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 88 mean, that could have not been exactly what was said, but those are generalities of what was said. Q. Who else was in the house at this time? A. Epstein for a fact. I'm not too sure about Ghislaine and Emmy, they could have been. Definitely house staff. Q. Who? A. Joe Joe and there was another Philippine lady, I'm not too sure. Q. How often were you sexual trafficked in Jeffrey Epstein's private bedroom? MS. MCCAWLEY: Objection. Which bedroom are you talking about? BY MS. BORJA: Q. The same bedroom in New York that you were talking about? A. That's actually the only time besides with Jeffrey. I mean, Jeffrey countless, but there was no other men brought to Jeffrey's room. Q. Who brought Professor Dershowitz to this room? A. I have no idea, I'm assuming Epstein. Q. Help me figure this out. Epstein had just left the room? A. Epstein exits the room, Dershowitz walks Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 89 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 89 in. Q. Same door? A. Same door. Q. How long before Jeffrey exiting and Professor Dershowitz walking in? A. Minutes, not even, approximately 60 seconds. Q. Ten minutes later once the sex encounter ends, what happens next? A. He pulled up his pants and I put my towel back on. I went upstairs to my room -- my room was downstairs, had another shower, I got dressed. I don't remember the rest of the day from there. Q. Did you see Professor Dershowitz in the house again that day? A. On that day? Q. Right. A. Possibly, I mean, I don't remember. I just remember that event very clearly. Q. So it was unusual that somebody other than Jeffrey to whom you would be sexual trafficked would walk into Jeffrey's bedroom, is that fair? A. Yes. Q. Did you ask anybody how that came to be? A. No, it was expected of me. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 90 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 90 Q. Did you talk to Jeffrey about it? A. Yes. Q. What did you tell Jeffrey? A. Jeffrey asked me if he enjoyed it, I said yes. Q. So the act was consummated? MS. MCCAWLEY: Objection. A. What does consummated mean? MS. MCCAWLEY: If you don't know you don't answer. SPECIAL MASTER: Rephrase that. BY MS. BORJA: Q. What do you mean by your testimony that Professor Dershowitz enjoyed it? MS. MCCAWLEY: Objection. Mischaracterizes the testimony. SPECIAL MASTER: You can answer if you can. A. I don't even understand. What do you mean, did he enjoy it? MS. MCCAWLEY: Take a deep breath. She can re-ask the question. A. He enjoyed it, yes. From what it looked like, my God, yes, he enjoyed it. Q. Why do you say that? MS. MCCAWLEY: Take a deep breath. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 91 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 91 A. He ejaculated. He was happy. Q. Tell me about the next incident that you can recall of the sex? MS. MCCAWLEY: Do you want to take a break? THE WITNESS: Yes, absolutely. SPECIAL MASTER: Let's take a break, five minutes. THE VIDEOGRAPHER: Going off video record, 11:11 a.m. (A recess was taken.) THE VIDEOGRAPHER: We are now back on video record 11:31 a.m., disk number 2. BY MS. BORJA: Q. Is there anything else that you can recall that would help you to place the time frame of this sexual encounter of Professor Dershowitz in New York? A. No, not that I can remember. Q. Do you recall whether it was before or after the first time you met Prince Andrew? A. Before. Q. About how long before do you think? A. I don't know. It was fairly early on in my relationship with Jeffrey that I first met him, but it was after my training so I'm not too sure. Q. And your training was about nine months, is Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 92 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 92 that fair? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. No, my training wasn't about nine months. MR. SIMPSON: Can you ask her to speak up just a little bit? I'm having a hard time hearing. MS. MCCAWLEY: Okay. We'll do our best, but she got sick during the break. Let's just be happy that we're here and we're getting this. SPECIAL MASTER: Let's move on. Let's move on, please. (Thereupon, VR Defendant's Exhibit No. 4, was Marked for Identification.) BY MS. BORJA: Q. Ms. Roberts, I've handed you a document that's been marked as VR 4 which is dated April 7th, 2011 and it reflects on the top, participant Jack Scarola, Brad Edwards, Virginia Roberts, and the document has a bates number non-party VR 178 through 200. Do you have that? A. Yes, I do. Q. Have you seen this document before? A. Yes, I have. Q. Did you see a draft of this document before Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 93 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 93 this version? A. I'm sorry, I don't understand what you mean. Q. Have you seen more than one version of this transcript of the telephone conference? A. Not that I'm aware of. Q. Do you recall receiving a draft and making any edits to it? A. Not that I'm aware of. There's a lot of documents that I've gone through so it's a possibility. Q. You say you've seen it before, correct? A. Yes. Q. When did you first see it? A. I don't know the first time I saw it. I remember seeing it recently, but I don't remember the first time I saw it. Q. Did you see it shortly after your telephone conversation with Jack Scarola and Brad Edwards? MS. MCCAWLEY: Objection. Can we have a time frame on this document, please? SPECIAL MASTER: Could you please recite a time frame? BY MS. BORJA: Q. You had a telephone conversation with Jack Scarola and Brad Edwards in April 2011, do you recall Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 94 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 94 that? A. I recall the telephone conversation, yes. Q. And after you had that telephone conversation did you see a transcript of the conversation? A. I don't know. I don't remember. Q. Have you actually read this document? A. Yes, I have. Q. Is the document accurate to the best of your knowledge? A. Yes, I mean, there's a couple small things like my middle name is not Louise, I wasn't living in Australia for 19 years, but for the most part everything else is pretty correct. Q. If you turn to page 10 of 23? MS. MCCAWLEY: They're numbered at the top, at the very top in the corner. You see there? A. Yes. Q. Do you have that page? A. Yes, I do. Q. About halfway down the page Mr. Scarola asked you, okay, and how long after you first met Jeffrey did he first ask you to provide services for one of his friends? You answered, about nine months I think it was. It wasn't a full year, it wasn't six months, it was Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 95 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 95 between six months and a year which is why I'm saying nine months. Do you see where I am reading? A. Yes, I do. Q. Is that truthful and accurate? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. It's as close to what I can remember, but I hadn't given it much thought at that time, but it's close. Q. Well, within 60 days of this telephone call you had met with Ms. Churcher, right? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. Within 60 days? We are talking about before the telephone call or after the telephone call? Q. You met with Ms. Churcher before the publication of the Daily Mail article in March 2011, right? A. Right. MS. MCCAWLEY: Objection. BY MS. BORJA: Q. And you met with her for about a week, right? MS. MCCAWLEY: Objection. I have an objection to all line of questioning relating to Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 96 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 96 the media. SPECIAL MASTER: I understand. Proceed. You can answer. A. Yes, and that was her, must have been March if that's the date she called. Q. And during the week that you met with Ms. Churcher she showed you photos of people, correct? A. Yes. Q. And you thought about whether they were abusers, correct? MS. MCCAWLEY: Objection. BY MS. BORJA: Q. And she talked to you -- MS. MCCAWLEY: Sorry, let me have my objection. If you can pause for a moment. Go ahead. SPECIAL MASTER: You can answer. You did answer. Move forward. BY MS. BORJA: Q. And she talked to you about your time with Jeffrey Epstein and being sexually trafficked; is that correct? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. Yes. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 97 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 97 Q. And then an article came out about it, right? MS. MCCAWLEY: Objection. A. Yes. Q. And people called you about that article, correct? MS. MCCAWLEY: Objection. A. Yes. Q. And so you had a meeting for a week, you looked at pictures, you talked to Ms. Churcher, an article came out, you talked to people, and this is happening right around February, March 2011, correct? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. Yes. Q. And now April 7th you have a telephone call with Mr. Scarola and Mr. Edwards, correct? A. Yes. Q. So you had had time with Ms. Churcher, with your friend calling, with the article to think about these activities, correct? A. Yes. MS. MCCAWLEY: Objection. BY MS. BORJA: Q. And your best recollection in April of 2011 Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 98 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 98 was that about nine months, it wasn't a full year, it wasn't six months, but between six months and a year, which is why I'm saying nine months. That it was your best recollection as to the time frame at that point after you first met Jeffrey when he asked you to provide services for one of his friends. Is that fair? MS. MCCAWLEY: Objection. A. As you can see in that answer I'm not even sure. It wasn't six months, but between six months and a year which is why I'm saying nine months. It was an assumption. Q. Was it your recollection at the time? MS. MCCAWLEY: Objection. A. It was my best assumption. It could have been three months for all I know, it could have been six months for all I know, but it's an assumption. Q. It could have been a year for all you know, then, right? MS. MCCAWLEY: Objection. A. No. Q. Why is three months fair and twelve months not fair? A. Because it wasn't that long. Q. But has your memory improved since 2011? MS. MCCAWLEY: Objection, argumentative. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 99 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 99 Go ahead. A. Going through everything that I have gone through over and over and over again, yes, it has. Q. So is your memory improving over time about the events? A. It's not improving. MS. MCCAWLEY: Objection, sorry, let me just -- objection, argumentative. SPECIAL MASTER: You can answer. A. It's not that it's improving over time, but the more that I talk about it, the more I am able to remember stuff. Q. Are there things that you remember now that you didn't tell Ms. Churcher in your interview? A. Definitely a possibility. Q. You don't know one way or the other? A. She didn't ask me everything and I didn't tell her everything. Q. Why did she call you, do you know? A. I think I've answered this previously, haven't I? SPECIAL MASTER: You can answer it again. MS. MCCAWLEY: You can answer it to the extent you can recall. A. She called me because she was interested in Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 100 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 100 the Jeffrey Epstein saga, so to speak. Q. Did Ms. Churcher tell you she had talked to anybody else before she talked to you? A. Like in order to get my number or? Q. No, about the same subject matter that she was asking you about? A. I'm not aware of her conversations with other people. Q. I'm asking you what she told you. Did she tell you she had talked to other people? MS. MCCAWLEY: Objection, asked and answered. A. I'm thinking. I can't recall a specific person that she said, but I'm sure she did talk to other people about this. I know she talked to the Daily Mail to see if we could run the story. Q. After you gave the telephone interview to Mr. Scarola did you call him and say anything that you told him was wrong, incorrect I should say, from your telephone conversation? A. No, not that I can remember, no. (Thereupon, VR Defendant's Exhibit No. 5 was Marked for Identification.) MS. MCCAWLEY: I'm going to object to this. This has pictures of Virginia's children on this Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 101 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 101 and we have safety concerns here. We're not going to be putting this in the record, and I think any line of questioning regarding her kids or identification with respect to them is absolutely inappropriate. She's a non-party witness, she's a sexual abuse victim, and injecting her children into this is inappropriate. MS. BORJA: I'm still going to mark this as an exhibit. This is under seal and if you want to take other steps after this that's up to you. THE WITNESS: What do my children -- MS. MCCAWLEY: Hang on, take a deep breath. It's okay. We'll handle it. SPECIAL MASTER: So explain to me why? MS. BORJA: I asked haven't any questions yet. SPECIAL MASTER: Well, explain to me about the exhibit. You can mark it, but we're going to keep it. I'm going to tell you what, other than after the lawyers see that, let's put the copies here and we're going to hold those separately and apart from the rest of the exhibits because I tend to agree with Ms. McCawley's concern on this. So proceed with the question on that grounds. BY MS. BORJA: Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 102 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 102 Q. Ms. Giuffre, the document that's been marked as VR Exhibit 5 is a compellation exhibit with two pages from a Facebook profile. Do you have that? A. Yes, I do. Q. Is this a Facebook profile that you created? A. Yes, it is. Q. Did you input pictures into it? A. I sure did. Q. Is page 1 an accurate depiction of your Facebook profile? A. Yes. Q. And the second page of this exhibit, it says Virginia Giuffre, November 11, 2013. Do you see that? A. Where am I looking at? Q. At the top under the name Virginia Giuffre, it says November 11, 2013. Do you see that? A. Yes, I see that. Q. And is this an entry that you made into your Facebook account? A. Yes. Q. You posted the picture? A. Yes. Q. Do you know below the first entry under the Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 103 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 103 photos says high buddies, we'd love to hear from our pen pals across the sea. Our new address is, and it states an address there and goes on. Do you see where I'm reading? A. Yes. Q. Did you make that entry into your Facebook profile? A. Yes. Q. And is this a true and accurate depiction of that entry that you made? A. Yes. SPECIAL MASTER: Is that it? MS. MCCAWLEY: I'm going to ask to the extent that the exhibit gets used at all that every picture of her children is redacted. If you want to leave the date, that's fine. THE WITNESS: Can I also ask why -- SPECIAL MASTER: Hold on one second. MS. MCCAWLEY: It's okay. SPECIAL MASTER: Do you have an objection to the redaction of the children? MS. BORJA: I do in this regard, and I would like to make my objection on the record without the witness present. SPECIAL MASTER: Without the witness Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 104 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 104 present? MS. BORJA: Correct. SPECIAL MASTER: All right. Let's hold that because I don't want to lose this. We'll go back to that on the next break. When the witness takes a break we'll go ahead and put that on the record, but in the meantime let's go ahead and put the exhibit -- you hold yours and we'll hold the rest of them there. MS. BORJA: There's several copies here. SPECIAL MASTER: Put them there. Ms. McCawley, as a officer of the Court will you take those exhibits and then on a break put them in an envelope and mark them and I'll seal them right away so this way you can take provisions on that. MS. MCCAWLEY: Okay. SPECIAL MASTER: Thank you. And then we can go ahead at the next break you can make your objection at that point. Go ahead, proceed. BY MS. BORJA: Q. Ms. Roberts, we've been talking about when you claimed you were sexually trafficked to Professor Dershowitz and you talk about three of the incidents that are reflected in the joinder motion. Let's go through the other three. Pick any of them? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 105 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 105 A. Which ones have I told you about so far? Q. You had mentioned on a plane, New York, and New Mexico? A. Okay. Let's to go Palm Beach. Q. When was this? A. I don't have a significant date for you. Q. Was it before or after you met Prince Andrew? A. Before. Q. How do you know that? A. Because I hadn't met Prince Andrew at that time. Q. What do you recall about -- that helps you place the time of this meeting in Palm Beach? A. It's Florida, it's sunny, it's always hot. I have no idea. Q. Do you have any idea when it was? A. No idea. Q. How do you know it's before you met Prince Andrew? A. I hadn't met Prince Andrew by then. I don't know how else you want me to answer that. Q. Well, if you have no idea when it is? A. I'm telling you. MS. MCCAWLEY: Objection, argumentative. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 106 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 106 SPECIAL MASTER: Let her get a question out. Let her get a question out then you can object. BY MS. BORJA: Q. What markers are you using to identify for yourself it was before -- let's say you met Prince Andrew in March 2001 how are you able to know that this event in Palm Beach was before March 2, 2011? MS. MCCAWLEY: Objection, assumes facts not in evidence. You can answer. SPECIAL MASTER: You can answer. A. I recall meeting Prince Andrew and it was a very significant event and I can tell you it was before I met Prince Andrew. Q. How many times after you met Prince Andrew were you sexually trafficked to Professor Dershowitz? A. I don't know. Q. Were there any? A. I cannot chronologically give you the answer to that, I'm sorry. There is no way for me to do that. You know, could there have been times after Prince Andrew that I was with Dershowitz absolutely, but do I know for a fact no, I don't. Q. Is that true for all six? A. Yes, that's true for all six, I don't know. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 107 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 107 Q. Who else was there in Palm Beach? A. Same people, Jeffrey, Ghislaine, Juan Alessi, he's the butler. I'm trying to remember if Emmy Tayler was there. I'm pretty sure she would have been. She was always with Ghislaine. No one else significant that I can remember. Q. So that's four instances. What are the other two? A. So I've given you Palm Beach, New Mexico, there's the U.S. Virgin Islands, Little Saint Jeff's. Q. Who else was there? A. Jeffrey Epstein, Ghislaine Maxwell, I possibly want to say Adam Perrylang was there as the chef, Miles Caffe, I think that's it. I mean there's a possibility that there could have been another girl there, but I can't remember. Q. Who is Miles? A. He's like a house staff. Q. What's your best recollection as to the time of year this was? A. Well, like Florida the Caribbean is very hot all year round so it's hard to depict what time of year it was. Q. I understand it's hard. What's your best recollection as you sit here today under oath? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 108 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 108 A. That's what I'm trying to tell you is I don't know. I don't know because it doesn't get cold in the USVI so there's no way to really tell you it was winter or fall or spring or summer because it's always hot. Q. Where did you go next after that trip? A. I don't know. Q. How long was Professor Dershowitz down there? A. I think he was there from, just from any recollection two days. Q. Where did he stay? A. In one of the villas. He would have had to. Q. Where did you stay? A. In another one of the separate rooms. Q. When you were in Palm Beach, the time that you mentioned previously, how long was Professor Dershowitz there? A. I don't know. I had my own apartment in Palm Beach. I was called in for him. Q. How do you know you were called in for him? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. I normally got phone calls when I was in Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 109 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 109 Palm Beach when I was at my apartment to come in to give someone a massage. Q. Did any guests get massages that were not sexual in nature? A. Not that I was aware of. All the massages I gave were of a sexual nature except for Eva Anderson, sorry. I'm sorry, Eva Dubin, sorry. Q. Did you ever see any male masseuses? A. Once when I was at the island. He was there helping me train. Q. Were that massages and that masseuse sexual in nature? A. No, but it was a training. Not that kind of training, actual massage training. Q. Were there ever any masseuses over the age of 25? A. Yes, I think her name is Sheridan. Q. Were there ever any over the age of 30? A. The male one that we just talked about is over 30. Q. Can you recall any others? A. No. Q. Do you know one way or the other whether there were any other masseuses over the age of 30? A. Do I know of any other masseuses over the Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 110 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 110 age of 30? Q. That were providing massages to Jeffrey Epstein? A. Just the male that was teaching me on the USVI and Sheridan, but she was also involved in sexual acts. She wasn't over the age of -- she could have been around 30, but she would have been over 30. Q. Did you keep a list of the masseuses who came to Epstein's properties? A. No. Q. Did some of them come only once? A. Uh-huh. Q. Are there some that came when you weren't there? A. I wasn't there, how am I to know. Q. You don't know if any came as a masseuse while you were not at Jeffrey Epstein's property? MS. MCCAWLEY: Objection, asked and answered. A. I wasn't there so I couldn't have. Q. What's the sixth incident that you say happened where you were sexually trafficked to Professor Dershowitz? A. We've talked about New York, we talked about Palm Beach, New Mexico, U.S. Virgin Islands, talked Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 111 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 111 about we took the airplane? Q. Yes. A. There was an instance in a car, but it was more -- it wasn't intercourse, it was more -- MS. MCCAWLEY: Use a term you're comfortable with. A. More oral is the good term to use, oral sex. Q. Where were you? Where was his car, what city, what state, what jurisdiction? Where were you? A. This was in Massachusetts. It was a black limousine. Q. Who else was in the car other than yourself and Professor Dershowitz? A. Jeffrey Epstein and another young girl. Q. How many people participated in the sexual activity in the car? A. Including myself? Q. Uh-huh. A. Four. Q. Where was everybody in the car? A. Sitting down. Q. Were people -- was this a town car, was this a limousine? A. Like a long limousine. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 112 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 112 Q. Where was the car going? A. To Mr. Dershowitz' house. Q. Where was it coming from? A. An airport. Q. When was this? A. I don't know. Q. What's your best recollection? A. It wasn't snowing. It wasn't hot. So I would like to say -- I'm trying to think of the trees around, but I don't know, maybe spring. Q. Why were you going to Professor Dershowitz' house? A. Jeffrey and him were doing some business. They were doing something at his house. Nothing sexual happened at his house. Q. Did you go in Professor Dershowitz' house? A. Yes, I did. Q. How long were you there? A. Not even twenty minutes, half an hour. Q. What did you do while you were in the house? A. I sat in, I don't know, a foyer with another girl and Jeffrey and Dershowitz went to a different part of the house. There was a desk there and we just sat, not sat, stood in the foyer. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 113 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 113 Q. Who was this other girl? A. I don't know who she is. Q. Had you ever met her before? A. No. Q. When you were coming from the airport had you flown in? A. Yes, me and Jeffrey and the girl had flown in, Dershowitz had not. Q. How did he get into the limousine? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. BY MS. BORJA: Q. Where did he get into the limousine? A. At the airport. Q. He was not on a flight with Mr. Epstein? A. Not on this occasion. Q. Did you tell anybody about this incident in the car? A. Like anybody that I know personally? Q. Anybody in the world? MS. MCCAWLEY: Objection to the extent you relayed something to your lawyer. You can say that you told your lawyers but you can't discuss what you said. SPECIAL MASTER: Other than -- Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 114 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 114 A. No, I told my lawyers. Q. Did you tell anybody about it closer in time to the event? A. Like my boyfriend or something like that, no. Q. After you left Professor Dershowitz's house where did you go? A. Back to the airport. Q. Where did you fly in from? A. I believe it was New York. Q. When you went back to the airport where did you go? A. I believe, see, that's the hard thing. I want to say either New York or Palm Beach. I'm no 100 percent sure. Q. So I understand the time frame, did you fly in on a private jet or commercial? A. Private. Q. You flew out again on private? A. Yes. Q. So the time frame is that you and Jeffrey were on the plane? MS. MCCAWLEY: Objection. A. Yes. MS. MCCAWLEY: Objection, mischaracterizes Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 115 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 115 the testimony. Go ahead. A. Yes, me and Jeffrey were on the plane together. Q. And the girl was on the plane? A. Yes. Q. Anybody else? A. The pilots. Q. So the three of you took the flight, correct? A. Yes. Q. And you flew into an airport in Massachusetts? A. Yes. Q. Then you took a limousine to the Professor's house and you were there for about ten minutes, is that right? MS. MCCAWLEY: Objection. Go ahead. A. About 20, 25 minutes. I didn't look at my watch. Q. A very brief period of time? A. Very brief. Q. And then you went back to the airport and you flew out? A. Yes. Q. And you flew back either to New York or to Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 116 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 116 Palm Beach? A. It could have yeah, it could have been either-or, I'm not too sure. Q. But one or the other? A. Yes. Q. When you flew back out was anybody else on the plane other than yourself, Jeffrey, and this girl? A. Actually the girl stayed behind, it was just Jeffrey and I that went back. Q. Did the girl leave in the limousine with you and Jeffrey back to the airport? A. No. Q. She was left at Professor Dershowitz's house? A. She stayed there. Q. Do you know why she was staying there? A. I don't ask questions. Q. Did you talk to her when you were in the foyer with her? A. Like I said, we basically just have not real conversations, not girlfriends sitting down talking to each other just, I don't know, brief conversation. Q. Did Mr. Epstein arrange for the limousine or did somebody else? A. Maybe one of his assistants. Jeffrey Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 117 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 117 rarely arranged everything himself, usually had somebody else do it for him. Q. And was there anybody else in Professor Dershowitz' house other than the people that you've mentioned, Jeffrey, the girl, and yourself? A. I didn't see anybody. Q. Was this in the morning, at night, what time was this? A. After noonish, like after the noon period. It wasn't dark. Q. Did you have anything to eat for lunch? A. Not that I remember. I mean, I'm sure we did. We didn't go out to lunch. We didn't stop at any restaurant or anything like that. Q. Other than Professor Dershowitz' house did you stop anywhere during this trip? A. No. Q. Was this during a weekday or a weekend? A. No idea. Q. Were you able to see the driver while you were in the car? A. No, there was a black, like a window. Q. Was it closed the entire time? A. That I can remember, yes. Q. Did you ever fly commercially to any of the Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 118 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 118 locations when you claim you were sexually trafficked to Professor Dershowitz? A. I did used to have to fly commercially to go service the men that Jeffrey sent me to, but I don't remember having to fly commercially for Alan Dershowitz. Q. Now, other than your conversation with Ms. Churcher before the first Daily Mail article came out, did you talk to her again about where you mentioned Alan Dershowitz? A. Before I spoke to her? Q. No, since that article came out? A. Have I talked to her again about Alan Dershowitz? Q. Correct? MS. MCCAWLEY: I object to this line of questioning. I think I have a standing objection, just to make that clear. A. Yes, I think we actually have. I think she read the recent, well, not so recent, about a year ago the statements made in the press and she called me up and I told her that I was not allowed to discuss it. Q. What did she say to you? A. She was just asking me about the ongoing proceedings and I said I don't think I'm able to comment. I don't think it's a wise thing to do, especially her Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 119 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 119 being a journalist. Q. Have you ever e-mailed with Sharon Churcher? A. Yes, I have. Q. How many times? A. I don't know, a lot. Q. What does a lot mean to you? A. Over twenty. Q. When was the last time you e-mailed with her? A. Probably in 2015. Q. Do you know approximately how many times you e-mailed with her in 2015? A. Maybe about five. Q. Before 2015 was there a long gap in your e-mail? A. Yes, there was a long gap. Q. Did you e-mail with her around the time leading up to the meeting that you had before the first Daily Mail article? A. I think that was actually phone conversations, not e-mails. Q. After you met with her the first time did you then e-mail with her? A. Yes, then we e-mailed. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 120 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 120 Q. About how many times, putting aside the five or so in 2015? A. About anywhere between ten to fifteen. I'm not too sure of the exact number but -- Q. Were you e-mailing with her while you were living in Australia? A. Uh-huh. Q. And were you e-mailings with her while you were living back in the United States? A. Uh-huh. Q. Yes? A. Yes, sorry. Q. Have you e-mailed with any other press regarding Alan Dershowitz? A. No. Q. Actually did your e-mails with Ms. Churcher refer to Alan Dershowitz? A. No. Q. Did your e-mails with Ms. Churcher specifically identify any alleged sexual abuser other than Mr. Epstein? A. Prince Andrew, that's it. Q. Had you had any e-mails with anybody about Alan Dershowitz? MS. MCCAWLEY: I'm going to object to the Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 121 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 121 extent that this reveals anything that you have e-mailed with your lawyer. You don't have to testify to that. A. Besides with my lawyers, no. Q. Did you ever e-mail Rebecca about Professor Dershowitz? A. I am pretty sure we had phone conversation, actually no, face to face conversations about him and maybe some comments over the phone, but I do not recall sending her any e-mails regarding Alan Dershowitz except for the text messages I sent to her after I learned she was talking to him and I said, I don't believe you're talking to a pedophile. Other than that, no. Q. How many text messages did you send to her? A. What, from the time I've known her? Q. No, regarding Professor Dershowitz? A. Max, well, I mean the first one I sent to her was about him and then, you know, the other ones were quite simple like, you know, you've got two precious daughters, you know. I don't know if he was actually named in any of those to be honest. I think I referred to him as the pedophile or a pedophile, but I mean I would say max three. Q. Have you left her voice mail messages about Professor Dershowitz? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 122 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 122 A. I have called her. Well, first she answered and then I said, please tell me it's not true that you're actually doing this and then she hung up and, yes, I have called her back and I have left her voice mails, nothing abusive just, Becky, what are you doing you know. Q. You know what? A. What are you doing, you know, like that's what I said to her. That's how I talk, our lingo. Not you know what, like anything, but what are you doing, you know. Q. Did you give her any context or is that the entire message that you would have left? A. I don't know the entire message I would have left, but like I said, it would not be abusive. Q. Now, I think that you mentioned in, was it Palm Beach, Juan Alessi? A. Yes. Q. He was on the house staff? A. Yes, he was a butler. Q. What was the name of the fellow? A. Joe Joe. Q. What's Joe Joe's last name? A. I have no idea. Q. Have you ever met Alfredo Rodriguez? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 123 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 123 A. I don't know. I mean, you have to understand there's lots of house staff at all of his residences. It's possible I did come across them, but I'm not too sure. Q. But you don't have any specific recollection ever meeting him, do you? MS. MCCAWLEY: Objection. A. No. SPECIAL MASTER: You can answer. You answered. Go ahead. THE WITNESS: Sorry. SPECIAL MASTER: It's all right. BY MS. BORJA: Q. What did you do with the your e-mails with Ms. Churcher? A. What do you mean, what did I do with them? Did I print them out? Q. Did you keep them in your inbox, your sent box? A. Yes, they would be in my in box. I mean, after so long, I mean, I had to not just delete hers, but delete a lot of files from my inbox, it was getting too full. I still have e-mails of hers in my inbox. Q. Do you still have the text messages you sent to Rebecca? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 124 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 124 A. No, I've gone through phones and that's not because of on purpose. My kids literally break every phone that I get. Q. So when was the last time that you texted Rebecca? A. When I found out that she was talking to Dershowitz. Q. What's that time frame? A. I have no idea. I think it was June of last year, June 2015, but that's not what I messaged her. I only messaged her recently when I found out, which I think was during Dershowitz' first deposition when he said that he had been talking about Rebecca. Q. And then you've switched phones since then? A. Yes, I have a new phone, but I have those messages that I sent to her on my new phone. (Thereupon, VR Defendant's Exhibit No. 6, was Marked for Identification.) BY MS. BORJA: Q. Ms. Giuffre, I've handed you a document that's been marked VR Exhibit 6, which is a 13 page document copy of an article from Radar Online. Do you have that? A. Yes, I do. Q. Is this the Radar Online article that you Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 125 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 125 referred to earlier in your testimony today with the ripped out pages from your booklet? A. Yes. Q. Do you have any understanding of how Radar Online got these pages? MS. MCCAWLEY: Objection. A. No, not at all. Q. After these were public on Radar Online did you contact that publication? A. No. Maybe I should have, but I didn't think of it. Q. Are the excerpts here things that you wrote in your handwriting? A. Yes. Q. These are the pages that you gave Ms. Churcher, correct? A. Uh-huh, yes. Q. Are there any pages that you gave Ms. Churcher that are not reflected in the article? A. I mean, can you give me a minute to look at all of them? Q. You don't have to read the comments. I'm not going to ask you about them. A. It looks like there's a little bit of excerpts taken out of the pages I gave to her. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 126 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 126 Q. Were there any additional pages that you gave to her that's not printed into this article? A. Yes, that's what I'm saying. I mean, from what I can tell it's like they've taken excerpts out of the pages I gave to her and kind of pieced them together; but if you read them closely it doesn't look like every single one matches the next. Q. What was your purpose in writing those pages? MS. MCCAWLEY: Objection. You can answer. A. You know, at that time I was very let down by the United States government for not prosecuting Jeffrey Epstein in what I think that he deserved and what all his victims deserved to get from what he's done to us. So to me this was my way of telling a small piece of my story to see, you know, what we could do to re-open the case to get more knowledge about Jeffrey Epstein and what he's made, not just me, but a lot of other victims have to go through. Q. About how much time had elapsed between the time when you met Prince Andrew and the time that you wrote the booklet? A. Oh, many years, many years. All three of my kids had been born by then so we're talking, sorry, I am horrible at math, roughly about ten years. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 127 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 127 Q. In terms of your meeting with Prince Andrew when you went to Club Tramp, the excerpts in here said the two of you had grabbed a couple of alcoholic cocktails. Do you see that? A. Is that in the first page? Q. This is at page 3 of 13. The beginning of the text gets blocked out by the advertisement, but it refers generally to Club Tramp where you had grabbed them both an alcoholic cocktail, she wrote in the diary obtained by Radar? A. I do read that. Q. How long were you at the bar with Prince Andrew or at Club Tramp I should say? A. I would say over an hour but not two. Q. Did you have more than one drink? A. I believe I had two drinks. I'm not too sure if -- I assumed that Andrew was drinking alcohol as well, but I'm not too sure if it was. He ordered the drinks, and he ordered alcohol for me. So I only assumed that he was drinking it as well, but yes. Q. So he went up to the bar and ordered them and brought them back? A. Yes. Q. And you can't say what he ordered at the bar? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 128 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 128 A. I know they were both clear drinks. I don't know exactly what mine was, but it was clear and was alcohol. I didn't have a sip of his so I don't know what it was. Q. Did you take Ecstasy at this club? A. No. Q. And on two drinks -- did Prince Andrew have more than two drinks? A. I know I had two drinks. I don't know how many he had. I'm not too sure. Q. Okay. After these were public did you ever ask for these pages back? A. As far as I knew they were properties of Sharons. I think I had a rough conversation with her about it because I didn't know that these were going to get public at any time. These were more from between me and her. It really shocked me to see these in the public. So I honestly didn't think there was anything that you could do about it, it was already out there. Thinking about it today, you're right, I should have gone to Radar Online and found out why and who and how. Q. I don't mean to mislead you, Sharon's name is at the end of the article? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 129 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 129 A. Well, then -- I mean, that's obvious without even reading that. I mean, she's the only one who had it. So she's the only one who could have given it to them. Q. Why did you think it was her property? A. Because everything that I had given her was her property. Q. Why is that? MS. MCCAWLEY: Objection, asked and answered. A. I mean, well -- SPECIAL MASTER: You can answer. MS. MCCAWLEY: It's fine, if you know. Say what you know. A. Because everything that -- she told me everything that I gave her. So the story was her property, the papers that I gave her were her property. The photographs that they took of me like on the beach and I think there was a pictures of me on the bridge. Maybe there's a couple of other pictures, those are her property as well. Q. Was that spelled out in the contract? A. I don't know. It probably was. It was a long contract. I didn't have lawyers read it over for me so I'm not too sure. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 130 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 130 Q. Did you keep a copy of that? A. No. Q. What did you do with it? A. When I moved from Australia I had a bunch of paperwork I just kind of threw out, I didn't bring everything with me. Q. Why did you choose to move back to the United States at that time? A. I mean, there's a couple good reasons why I moved back. You know, first and foremost I haven't seen my family in a long time; and secondly, I wanted to see something happen with the -- I was trying to join the CVRA case so I was hoping by moving back I would see that progress. Q. What's the date that you moved back? A. As far as the picture that you just showed me of the house that's November. I think it only took me about two weeks -- actually I can tell you the exact date, it was on my anniversary, October 16th, 2013. MS. MCCAWLEY: Do you need a break or are you okay? THE WITNESS: I'm okay. BY MS. BORJA: Q. Other than the meeting that you talked about with the FBI in 2011 shortly after the first Daily Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 131 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 131 Mail article came out, have you talked to any other law enforcement about Jeffrey Epstein? MS. MCCAWLEY: I'm going to object to the extent that it's an investigational privilege. If there's an ongoing investigation to extent it was the FBI or something that happened previously you can discuss that. SPECIAL MASTER: You can answer. A. Okay. Honestly I'm trying to think, FBI -- I'm trying to remember when I talked to Maria Vilafana. I'm just going to say I'm not to sure. I don't want to answer incorrectly. Q. Have you ever given an affidavit to law enforcement? A. An affidavit? Q. Something that you signed? A. Yes, I know what it is. I'm just trying to think. I'm not questioning you, but would the FBI have an affidavit? I don't know. I would have signed something for them. MS. MCCAWLEY: Just answer what you know. BY MS. BORJA: Q. When was the first time that you told Brad Edwards that you had been sexually abused by Professor Dershowitz? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 132 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 132 MS. MCCAWLEY: And again, no attorney/client privileged discussions, you can give the date. A. I don't know the date. MS. MCCAWLEY: Or time frame. A. It would have been, I think, on -- this is not attorney/client privilege? SPECIAL MASTER: Just the time frame. MS. MCCAWLEY: As long as you don't describe it. Just the time frame. SPECIAL MASTER: You can't describe the conversation but you can describe the time frame. A. That's a difficult answer because there -- MS. MCCAWLEY: I don't want you to go into considerations. Think about it in your mind. So don't talk about what you were discussing, but if you can come up with a date in your mind or a time period then you can say that. A. Let's just say the first time I mentioned Alan Dershowitz I think was in 2011. Q. Did you say -- when was the first time, not that you mentioned Alan Dershowitz but that you identified him as a sexual abuser? A. The first time I went into detail about it would have been I think in 2013, maybe early 2014. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 133 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 133 Q. Were you living in the U.S.? A. Yes. Don't quote me 100 percent, it could have been before then. I'm just trying to remember back. Q. When was the first time, just the date, that you ever told Paul Cassell that you were sexually abused by Alan Dershowitz? SPECIAL MASTER: Just the date. A. It would have early 2013, 2014, same as Brad. Q. Now, in the document that we previously marked, the transcript of your conversation with Mr. Scarola, I'm not going to ask you to read it, I'm just asking you generally, you had said that Brad Edwards had contacted you because he was being sued -- he was in a lawsuit with Mr. Epstein. Do you recall that? MS. MCCAWLEY: Objection. You can answer. Sorry. THE WITNESS: You're confusing me. MS. MCCAWLEY: It's part of it. I'm sorry. A. Yes, I do remember that. Q. Do you know when that was? A. Possibly April 7, 2011. I don't know if that's the same conversation or it was before that or after that, but I believe the first time me and Brad ever talked was around that date. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 134 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 134 Q. He called you, right? You didn't call him out of the blue, he called you out of the blue? A. No, I might have called him, I think. I might have. I can't honestly remember, but Sharon Churcher knew how much I wanted to see this case open up and get resolved which is why I talked to the FBI. So I can't remember if she introduced me to Brad. I think that's how that went. Q. Did Sharon Churcher know about Mr. Edwards' litigation with Mr. Epstein? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer if you know. MS. MCCAWLEY: You can answer. A. I don't know what she knew about him, but she told me he was a really good lawyer who was doing pro bono work for other victims of Epstein and that if I wanted talk to somebody, he would be a good person to talk to. Q. That was in the -- A. Same time period. Q. 2011? A. Yes. Q. Okay. So in 2011 he was going to help you? A. At that stage we hadn't established Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 135 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 135 anything. It was just kind of like, hi, who are you, this is me, who are you, so on so forth. Q. You wanted to identify yourself as a victim of Jeffrey Epstein? A. Absolutely. MS. MCCAWLEY: Do you need a break? THE WITNESS: No. BY MS. BORJA: Q. Now, in your -- that transcript towards the end Mr. Scarola asks you certain names? SPECIAL MASTER: What page are you referring to? BY MS. BORJA: Q. At page 22 of 23? A. Yes. Q. If you go down about halfway, two-thirds of the way down the page, it says -- so I'll just name a name and you tell me yes if they told the truth. I think they have relevant information, or no, I don't think they would or I don't know whether they would or not. Okay, you understand? MS. MCCAWLEY: I don't see where you are. MR. SCAROLA: Just below the middle of the page. MS. MCCAWLEY: Here we go. I see it, I'm Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 136 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 136 sorry. BY MS. BORJA: Q. You see where I am reading? A. Uh-huh. Q. And then you say yes, and then Mr. Scarola says, okay, Les Wexner, do you see that? A. Yes. Q. And you said I think he has relevant information, but I don't think he'll tell you the truth. Do you see that? A. Yes. Q. Why did you think he wouldn't tell the truth? A. Because he did things that were wrong. Q. What do you mean by that? A. He participated in sex with minors. Q. Did you tell Rebecca that Les Wexner had participated in sex with minors? A. Yes, I did. Q. Did you talk to Rebecca about efforts to obtain any sort of the remedy or relief or damages or other way to bring Mr. Wexner to justice? A. I did talk to her about the ongoing proceedings that I wanted to bring against Mr. Wexner. Q. What did you tell her? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 137 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 137 A. I told her the details about what happened between Wexner and I and, you know, I said I hope we can get him in some way. I mean, I've heard the statements about the 50 billion or whatever that was, completely incorrect and I honestly do not know where she pulled that rabbit out of, that's absorb. I don't know her to be an untruthful person, but what her statements were are a thousand percentage untrue. MS. BORJA: Can you read back the answer? I can read your notes. BY MS. BORJA: Q. When you said I hope we can get him in some way, what did you mean by that? A. I hoped that my lawyers would prevail in fighting him in court, you know. I don't know what I'm allowed to talk about. MS. MCCAWLEY: You're not allowed to discuss anything that we've talked about in a confidential nature. A. There was never any monetary value ever discussed. Q. So you wanted to go off Wexner? SPECIAL MASTER: Outside of -- MS. MCCAWLEY: If you're talking about the conversation with Rebecca. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 138 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 138 SPECIAL MASTER: You're excluding discussions with your lawyers. MS. MCCAWLEY: If you're talking about the conversations with Rebecca that time but don't talk about anything you talked to us about. A. No, with Rebecca there was no monetary value ever discussed. Q. But you said you wanted to go after him in court? A. Yes. Q. What did you want to have happen? A. I wanted to see him come forward. I wanted justice to happen. Q. What does that mean? A. I wanted him to own up for his wrongs. Q. Did you go to the government and say prosecute him? MS. MCCAWLEY: Objection. To the extent that it reveals any current ongoing investigation you can't discuss that. SPECIAL MASTER: Anything that you had discussions with your lawyers and they provided on your behalf, that's not to be discussed. Do you understand that. A. Did I tell Rebecca that I'm going to the Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 139 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 139 government? SPECIAL MASTER: We're talking about Rebecca. A. No, I never went to Rebecca and told her we're going to the government. What did the government have to do with this anyways? Q. Did you want to have Mr. Wexner or anybody else pay amounts to your charity? A. No. Q. Why not? You didn't want any money for your charity? A. Of course I want money for my charity. I'd love to see -- my charity is my vision, to be able to help other victims out there suffering through what I suffered through. Of course that would be a dream come true, but did I say that money is going to be put into that by some unimaginable source, no. Q. Has the charity distributed any funds to victims? A. Not as yet. We haven't been able to go out and publish, not publish, what's the word I'm looking for? We haven't been able to make it proactive the way I want to make it proactive like go on TV and talk about it. You know what I mean? It's there, it's set up, it's wonderful. It's got a list of numbers and names of Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 140 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 140 places you can to go to for help. Right now it's just a map of every place in the United States that I've called personally to be able to get out of the situation that you're in if you're a victim of abuse or sexually trafficked. There's no money to give to victims. Q. There's no funds currently in the charity? A. No, besides what keeps it afloat in the bank, which is probably $150 or something. Q. Are the officers paid? A. The who? Q. The officers of the charity? A. No, no one is paid. Q. Has anybody applied to the charity or funds? A. No, like has a victim called up and said, can we get some money? Is that what you're asking? No. Q. That's one way? A. No. Q. Nobody has contacted the charity on line? A. No, we have had nice people call up and tell us about their story and, you know, thank me for coming forward and being brave. We have had that, but we have had nobody ask for money, we've just had nice fan mail. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 141 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 141 SPECIAL MASTER: Now is good time to take a five-minute break. MS. MCCAWLEY: Sure, I was going to let you know, too, in the effort to conserve time I did get lunch brought in for everybody. I'm not sure how many things are open since this is a Saturday. I don't know when you're hungry. It's your deposition, unless you're ready to eat, but whenever that is, I think she set it up maybe in one of the rooms so we can sign them out. SPECIAL MASTER: Thank you. THE VIDEOGRAPHER: Going off -- SPECIAL MASTER: The witness is excused. Go ahead and step out. MS. MCCAWLEY: Meridith, why don't you take her. (Witness leaves the conference room.) SPECIAL MASTER: Housekeeping. You wanted to put your objection on the record outside of the witness. Go ahead. Now would be the appropriate time. MS. BORJA: The witness has testified that she's afraid for her life. Her counsel has instructed her not to provide names because of fears of physical retribution. At the same time Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 142 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 142 the witness has posted on Facebook in a way that's publically available not only the photo of her house, the exact street address. She posted her children up on Facebook. I didn't inject those children into this case, I don't plan to, but there's no basis when a witness has made a Facebook page profile available to the world to say that I'm supposed to collect copies of something that's on the Internet and seal them. That's not my obligation and I think that is inappropriate, and this is something that the witness has put out there that is inconsistent with the testimony. MS. MCCAWLEY: I want to make clear, the date on that is November of 2013. She has received threats to her safety since that date. So it is inappropriate to put her address on the record or anything with respect to her children. MS. BORJA: I did not read her address into the record. MR. SCAROLA: May I make a suggestion? I understand the point that is attempted to be made with regard to the relevancy of these matters, and the relevancy is the suggestion that posting pictures of her children and her address would Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 143 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 143 tend to contradict assertions that she is in fear. Well, to the extent that that is a relevant argument it is established by reference to the fact that pictures of her children and her address were posted on the Internet in a specific date, there's no reason for either the pictures themselves or the address to be part of any record. So we would join in the objection that as a matter of privacy those things be excluded from the public record, although referenced to the fact of the posting is fair game from our perspective. MS. BORJA: Then I'm going to go in, I'm going to need to re-examine the witness because I avoided any mention of her children based on her counsel's objections, and I will ask her on the record that she has posted pictures of her own children. I didn't ask her that. MR. SCAROLA: We'll stipulate to the fact I think that she said those are her children. We'll stipulate to the fact that there are photographs of her children. MS. BORJA: That she posted. MR. SCAROLA: That she posted. MS. MCCAWLEY: On that date. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 144 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 144 MR. SCAROLA: On that date in 2013 and that her address appears on the document posted in 2013. SPECIAL MASTER: Does that stipulation satisfy you? MR. SCOTT: We'll consider it over lunch. We'll talk. MR. SCAROLA: Over lunch. When we take the break we'll talk to the client. SPECIAL MASTER: I'm not excluding the documents, should be aware. What I want to do, though, is take extra precaution to protect the document from being disclosed in any form, which is why we've collected all of the copies. I will put you in charge of them, Sigrid, and what we'll do -- and with respect to your relevancy argument or any other argument that you wish to make on that it appears it's going to go in front of Judge Lynch. That document is going to be available to you. If he's going to treat it in the manner in which he treats it and gives it whatever weight. I'm not excluding that, but what I do want to do is take the extra precaution of protecting the witnesses' privacy. MS. BORJA: That's fine, but to be clear my Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 145 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 145 objection is not relevance. My basis for arguing this is not relevancy. It goes to the credibility of the witness. SPECIAL MASTER: I'm aware. I will share this, if you need to ask additional questions beyond the stipulation, then I think we can go down that road and let you ask the questions and we'll see if there's an objection with respect to those, but I'm going to give you that opportunity if you choose to take it. Fair enough? MS. BORJA: Yes. SPECIAL MASTER: Let's break for five minutes. Let's be back here, it is, by my watch it is now what, 20 to 1. Let's be back here at quarter to one. MS. MCCAWLEY: Can we have a time check on how much time we've spent? THE VIDEOGRAPHER: Two hours and 59 minutes exactly. SPECIAL MASTER: It's 20 to 1. Let's be back ready to begin the deposition again at 1:00 o'clock. (Lunch recess was taken.) THE VIDEOGRAPHER: We are now back on video record, 1:16 p.m. disk number 3. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 146 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 146 BY MS. BORJA: Q. Mr. Giuffre, we were talking earlier today about that joinder motion and I had given you a copy of this document, do you still have to in front of you, Jane Doe #3 and Jane Doe #4 corrected motion? A. This one? MS. MCCAWLEY: Yes. A. Yes. Q. Turn, please, to page 4 of that document. MS. MCCAWLEY: 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. BY MS. BORJA: Q. 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? A. Yes. Q. In addition to being a participate in the abuse of Jane Doe #3 and other minors Dershowitz was an eye witness to the sexual abuse of many other minors by Epstein and several of Epstein's co-conspirators. Do you see that? A. Yes. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 147 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 147 Q. Now, where it says participant in the abuse of Jane Doe #3, you talked about your abuse and other minors? A. I'm sorry, I don't see -- yes, participant, yes. Q. Participant in the abuse of other minors? A. Yes. Q. Can you identify any of those minors? A. Specifically talking right now I'm speaking about the girl on the airplane and in the limousine. Q. How do you know the age of the girl on the airplane? A. Like I said before they looked young but it's hard to depict exactly what age they are. Q. It's possible that neither one of them was a minor? A. It's possible that they were, yes, not a minor, but from what they looked like to me they did look young. Like I said, I can't tell you their ages because I didn't talk to them and ask them their ages. Q. Then it says Dershowitz was an eye witness to the sexual abuse of many other minors of Epstein and several of Epstein's co-conspirators, do you see that? A. Yes. Q. Is that something that you personally know? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 148 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 148 A. 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 minors, I mean, even before Dershowitz and I were personally together, he walked in on -- one occasion in New York he walked in on me providing oral sex to Jeffrey Epstein and, I mean, I thought that was a 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, tons of young girls constantly around for the only sole purpose of having sex with those minors. Q. How many times would anybody have to visit an Epstein property to be an eye witness to the sexual abuse of many of the minors in your opinion? A. I'm sorry, can you rephrase? I just don't understand what you mean. Q. You say that Dershowitz was on eye witness? A. Yes. Q. But you never actually saw him as an eye witness to the sexual abuse of many of the minors; is that correct? MS. MCCAWLEY: Objection. A. Yes, I did see him as an eye witness Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 149 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 149 obviously on the plane and in the limousine. Q. But we don't know those were minors one way or the other, right? A. Right. Q. That's your assumption, correct? A. Yes. MS. MCCAWLEY: Objection. Q. And you're speculating, right? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. MS. MCCAWLEY: Sorry. A. Yes. I mean I -- MR. SCAROLA: Excuse me, I don't believe the witness finished her response. You interrupted her as she was still speaking. BY MS. BORJA: Q. So let's leave those two instances aside? MR. SCAROLA: May we ask her to please to finish her response. MS. 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? A. They were young girls and there was constantly young girls that I know were minors around, I Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 150 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 150 mean, only because they were too, way too young to even look like an 18 year old plus. Q. Okay. I'm not asking about other girls being around. I'm asking about Professor Dershowitz being an eye witness 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? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. The only thing 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. Q. How do you know that? A. How do I know that Dershowitz knew that? MS. MCCAWLEY: Objection. BY MS. BORJA: Q. Yes, how do you know what he knew? A. How do I know what he knew, because he was around Jeffrey Epstein so many times that you would have to be blind to not know what Jeffrey Epstein was doing. Q. So it's your guess as to what Professor Dershowitz knew or didn't know, right? MS. MCCAWLEY: Objection, argumentative. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 151 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 151 A. No, it's a fact. Q. 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? MS. MCCAWLEY: Objection. A. 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? MS. MCCAWLEY: Objection, asked and answered. SPECIAL MASTER: You can answer. A. Besides the two girls that I considered to be very young, but I don't know their ages, no, I have not seem 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. Q. What's the basis for your testimony that he knew the purpose for the girls being around? MS. MCCAWLEY: Objection. You can answer. SPECIAL MASTER: You can answer. A. Because Jeffrey used these girls -- he didn't have friends that were 15, 16, 17, 18 just to hang around with as friends. And like I said, you would have to be a blind person to not know what he was doing with Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 152 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 152 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 know that there's minors around, I mean, it's just common logical sense. Q. So you're making an assumption, right? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. You can call it an assumption, but like I said you'd have to be blind to not know what's going on. Q. How many times did somebody to have to come to an Epstein property for you to have the same assumption about that person? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. I would say the first time they came to that 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 to know what was going on there. Q. So Donald Trump was in your mind you believe a witness to the sexual abuse of minors? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 153 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 153 MS. MCCAWLEY: Let her finish. Objection. That mischaracterizes testimony. THE WITNESS: Thank you. SPECIAL MASTER: You can answer. MS. MCCAWLEY: You can answer. A. I don't think Donald Trump participated in anything. That would have to be another assumption. I never saw or witnessed Donald Trump participate in those acts, but was he in the house of Jeffrey Epstein. I've heard he has been, but I haven't seen him myself so I don't know. Q. You've seen Heidi Klum with Jeffrey Epstein, correct? A. At parties. MS. MCCAWLEY: Objection. BY MS. BORJA: Q. So is it your assumption that she's a witness to sexual abuse of minors? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. I don't know if Heidi Klum 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. Q. Is Bill Clinton a witness to the sexual abuse of minors? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 154 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 154 MS. MCCAWLEY: Objection. You can answer. SPECIAL MASTER: You can answer. MS. MCCAWLEY: Just what you know. A. Yes, he would be a witness because he knew what my purpose there was for Jeffrey and he visited Jeffrey's island. MS. MCCAWLEY: Shhh please. Let her finish her answer. A. There's pictures of nude girls all around the house at all of his houses and it's something that Jeffrey Epstein wasn't shy about admitting to people. Q. Is Tipper Gore a witness to the sexual abuse of minors? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. A. 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 in anything like that, absolutely not. I can't say. I'm not on grounds to say that. Q. Some people you'll assume and some people you won't? MS. MCCAWLEY: Objection. A. Some people I would say are closer to Jeffrey than others. Did I see Tipper hang around Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 155 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 155 Jeffrey as much as Alan Dershowitz, no, I didn't. But Alan Dershowitz was around all the time so I would definitely say he was a witness to it. Q. Is Larry Summers a witness to the abuse of those minors? A. You'd have to tell me who Larry Summers is. Q. Is Al Gore a witness to the sexual abuse of minors? A. Again, he wasn't around all the time. I only met him once so I can't say that he is. (Thereupon, VR Defendant's Exhibit No. 7, was Marked for Identification.) BY MS. BORJA: Q. Ms. Giuffre, you have what's been marked as VR Exhibit 7 in front of you? A. Yes. Q. This is the Daily Mail article titled teenage girl recruited by pedophile, and it goes on. Do you see that? A. Yes. Q. Can you turn to page 3 of 31 of this printout. Do you have that? A. Yes. I do. Q. Right above the photograph there it says, Virginia disclosed that Mr. Clinton's Vice-President, Al Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 156 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 156 Gore and his wife Tipper were also guests of Epstein on the island. Do you see that? A. Yes, I do. Q. Is that true statement in the article? A. It is a true statement that I did meet Al Gore and his wife, but I cannot 100 percent lock down that it was at the island, it could have been New York. Q. Did you tell Ms. Churcher that it was on the island? A. I did tell Ms. Churcher that I thought it was on the island and this is how it was printed out. Q. Is Kevin Spacey a witness to the sexual abuse of minors? A. I don't know Kevin Spacey so I can't say that he is or isn't. Q. Do you know who he is? A. I know who he is. Q. Do you know how often, if ever, he was at any Epstein property? A. I was never there as an eye witness to see that. Q. Now, you refer to nude pictures a second ago. Do you recall that? A. Yes. Q. Where in the -- start with the Little Saint Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 157 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 157 James island, where in that property were there nude pictures? A. So there was nude pictures in -- 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? Q. You can just describe it as best you can? A. 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 TV, couches and everything like that in there. There is nude photographs all over that room. There is nude photographs in -- adjacent to the right-hand side is Ghislaine Maxwell's office, there's nude photographs in there. Away from the main house in Jeffrey Epstein's private bedroom there are nude photographs in there. Q. In these locations where there's nude photographs is that where Epstein guests go typically? MS. MCCAWLEY: Objection. Are you referring this one house or all the houses? BY MS. BORJA: Q. That's what we're talking about? A. The main house? MS. MCCAWLEY: Right. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 158 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 158 A. 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. Q. So did guests of Jeffrey Epstein typically see those nude photographs to the best of your understanding? A. To the best of my understanding, yes. Q. Where were there nude photographs in the Palm Beach house? A. 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 in 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 old girlfriends or models or Naomi Campbell or whatever the case is; but among all of those photographs would be nude photographs. Q. And this is, when you say, was it the front room or front table? A. Like as soon as you walked through the front door of the mansion the first thing that you see is Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 159 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 159 is that hallway table, on that hallway table is there. Q. And that front door that you were referring to is the one that guests walk in? A. Yes, and also upstairs in Jeffrey's massage room there is a hidden room where nude photographs from the floor to the ceiling all over, right, so there's not one piece of white showing. Q. Let me ask you about that? A. And then there's boxes and boxes and boxes of nude photographs. Q. You say this is a hidden room, what do you mean by that? A. 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 message table in the middle, and to your, I'm bad at 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. Q. Is this a place where guests typically when? A. If you were having a massage, yes. Q. Did all guests get massages in this hidden room? A. I can't say that all guests did. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 160 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 160 Q. Is that where Professor Dershowitz' massage was? A. Yes. Q. Where were there nude photographs in New York? A. 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 forget another place. MS. MCCAWLEY: Yes, you're allowed to finish your answer. A. Back to Palm Beach there was -- so you walk into the front door and I told you about that 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 that 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. Q. And these are all locations where guests would be? A. Yes. Q. And it was frequent that guests would have Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 161 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 161 the opportunity to see these as they were going through the house? A. Yes, if you walked through Jeffrey's house there is not a chance that you could not see nude photographs. Q. Were the photographs ever changed or taken down when guests were there? A. No. Like I said, he was not ashamed. Q. Were there also nude photographs in New Mexico? A. 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 to 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 can remember seeing them around the New Mexico house. Q. Did guests go by Jeffrey's bedside table? A. Sometimes if there was -- something was happening. Q. If you were just a visitor for a dinner party for example? A. No, if you were there for a dinner party you wouldn't go into his bedroom. Q. If you were just a guest for a dinner party Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 162 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 162 in New Mexico would you see nude photographs in getting to the dining room? A. No. I don't think we finished New York, did we? Q. You tell me? A. 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 to New York? MS. MCCAWLEY: Finish your answer. Yes. A. 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 and that had a huge photograph of me and another girl, I mean huge as in bigger than that wall cabinet. There's a painting of both of us doing salacious acts together. Q. Salacious acts? A. Sexual acts, you know what I'm saying? MR. SCAROLA: 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. BY MS. BORJA: Q. Now, the Dubins, they visited Jeffrey Epstein's property, correct? A. Yes. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 163 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 163 MS. MCCAWLEY: Objection. BY MS. BORJA: Q. ? A. Yes, . Q. And the children would see these nude photographs in the property? A. Yes. Q. And both the parents would? A. Yes. Q. Were there other children that saw these nude photographs? A. I mean, if you're talking about minors, then yes. Q. When you saw Alan Dershowitz visiting Jeffrey Epstein's properties did you ever see his wife ? A. No. Q. Did you ever see his grandchildren? A. No. Q. Do you know whether they were there or not? A. I don't know if they were there, but I did not see them. Q. Now is somebody who was at Jeffrey Epstein's properties, correct, at least at one, - Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 164 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 164 right? A. Yes. Q. Which property was that? MS. MCCAWLEY: It's previously -- she's a childhood victim. We're objecting to a line of testimony regarding details about sexual encounters with . 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. A. I'm just looking out for her. She was a victim. Yes, she was at all of his residences. Q. Did her mother ever come to visit any of these residences? A. I never met her mother. Q. Do you know whether her mother did? A. I don't know. Q. You never met A. No. Q. How much were you paid for messages? MS. MCCAWLEY: 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 Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 165 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 165 made a ruling that she did not have to go through a remuneration of funds as a result of the activities she was forced to participate in. That's the request. SPECIAL MASTER: Let me take a look at this. MS. MCCAWLEY: Sure. That was question 20 and he quashed that. MS. BORJA: Can you tell me which duces tecum request you're saying this is? MS. MCCAWLEY: I believe it's request 20. All documents showing any payments or remuneration of any kind made by Epstein or his agents or associates to you from June 1999 to December 31, 2002. BY MS. BORJA: Q. I'll ask another question. You've made statements that you were paid $200 a massage, correct? MS. MCCAWLEY: Objection. Same objection. He did not make her produce documents or have any testimony regarding the payments she received. SPECIAL MASTER: Do you have a statement particularly you're referring to? BY MS. BORJA: Q. You were paid for sexual services by Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 166 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 166 Jeffrey Epstein, right? A. Yes. Q. Did you pay taxes on those? A. No. Q. Why not? A. It was cash payment. Q. You were a waitress at the Roadside Grill, right? A. Yes, for a very short time. Q. Did you pay taxes on that? A. Not that I know of. No, I don't think I've ever paid taxes in the U.S. Q. And you haven't paid taxes since you returned? A. I haven't worked here since I returned. Q. When you got the $160,000 for the media deal you didn't pay taxes on that? MS. MCCAWLEY: Objection. Go ahead. A. I did pay taxes on that in Australia. Q. But not in the U.S.? A. It was given to me in Australian money so I paid for it in Australian taxes. Q. When you worked at Mar-a-Lago did you pay taxes? A. No, I was only there a very short period of Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 167 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 167 time. Max maybe pulled in two paychecks, so no. I think as a young age I think there's an exemption 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. Q. What was the last grade that you completed in school? A. I believe it was the ninth grade. Q. Did you ever complete your GED? A. I attempted to complete my GED, but I never did. Q. And over what period of time did you receive payment for any sexual acts? MS. MCCAWLEY: Same objection that I had before. SPECIAL MASTER: You can answer. A. From 1999 to 2002. Q. Until when in 2002, until you left? A. 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 just living expenses. Q. How long were you in Thailand? A. 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 Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 168 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 168 husband we went on a honeymoon. I think I came to Australia, I think it was November. MS. BORJA: 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's Exhibit No. 8, was Marked for Identification.) BY MS. BORJA: Q. I'm going to read to you, I'll hand it to you in a second, read to you the document that is marked as VR Exhibit Number 8 and it says, at page 3 of 29, "Epstein, a Wall Street money manager who once counted Bill Clinton and Donald Trump amongst his friends, became the subject of an undercover investigation in 2005 after the stepmother of a 14-year old girl claims she was paid $200, 125 pounds sterling to give an erotic massage." Do you see that? A. What paragraph is that on? Q. Top of the page. A. However, he avoided trial. Yes. Yes, I do. MS. MCCAWLEY: So I'm objecting as to any testimony regarding payments to you if it's a payment to someone else. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 169 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 169 SPECIAL MASTER: Right now the only question pending is do you see that paragraph? BY MS. BORJA: Q. Was that a standard payment for massages by Jeffrey Epstein? MS. MCCAWLEY: You can answer that. A. Yes, it is. Q. What's the basis for your testimony in that regard? A. It was the basis for my testimony? Q. How do you know that's a standard payment? A. That's -- are you trying to trick me into another question? MS. MCCAWLEY: 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. MS. BORJA: Counsel, speaking objections are not appropriate. MS. MCCAWLEY: I'm making my 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 Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 170 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 170 question. A. So can you repeat that question for me? SPECIAL MASTER: Go ahead and repeat it off the record so we get the exact wording. (Last question read back by the court reporter.) A. Yes, I do. Q. What's the basis for that statement? A. That's what we were given. Q. Who is we? A. Any of the girls that had to service Jeffrey. I'll speak for myself alone. Q. That's per massage? A. Yes. (Thereupon, VR Defendant's Exhibit No. 9, was Marked for Identification.) BY MS. BORJA: Q. Ms. Giuffre, I have handed you document a that's been marked as VR Exhibit 9, which is a declaration of Virginia Giuffre? A. Yes. Q. You've seen this document before? A. I've seen a lot of documents, but yes I have seen this. Q. On page 6, please. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 171 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 171 MS. MCCAWLEY: Is there a copy for me? MS. BORJA: Do you have one? MR. SCAROLA: No. Thank you. Page 6 is that where we are? BY MS. BORJA: Q. Yes, 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? A. Yes. Q. And that's the same event that you testified earlier where you testified that Professor Dershowitz walked into Jeffrey Epstein's private bedroom? A. Yes. Q. And we talked about the six instances earlier today and I believe you've indicated that they were at six different locations, correct? A. At least, yes. Q. Are there any other instances that you recall? A. Not off the top of my head. Q. Think about it. I want your best testimony today before we leave? A. All I can remember right now at this time is these approximately six times. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 172 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 172 Q. Why didn't you mention the limousine in your affidavit? MS. MCCAWLEY: Objection. To the extent that this pertains to a conversation you had with your lawyers she can't reveal that, anything else you can reveal. SPECIAL MASTER: You can answer. MS. MCCAWLEY: If you can answer without talking about what you discussed with your lawyers. A. At that time I wasn't asked about it and it came to me while thinking about it later on. Q. When did it first come to you? A. 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 to 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 had gotten away with it infuriated me so then I wanted to do something about it 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, the more I would remember certain occasions. Q. But you didn't remember the limousine as of Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 173 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 173 the time of this affidavit? MS. MCCAWLEY: Objection. SPECIAL MASTER: You can answer. MS. MCCAWLEY: You can answer. A. Apparently not. Q. Have you ever told anybody about having sex in the limousine with Alan Dershowitz? MS. MCCAWLEY: Outside of your lawyers. A. Outside of my lawyers, no. Q. Did you ever tell your lawyers? MS. MCCAWLEY: Objection. I'm not going to have her testify as to what she told the lawyers. SPECIAL MASTER: We're not going to allow that. BY MS. BORJA: Q. It's your privilege, the attorney/client privilege. MS. MCCAWLEY: She's not waiving her privilege. MS. BORJA: Counsel, can I make my record? SPECIAL MASTER: You've said -- go ahead and make your record. BY MS. BORJA: Q. You hold the privilege, you're the decider. The attorney/client privilege belongs to you. If you Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 174 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 174 would like to waive it you have that opportunity to do it? A. I decide not to waive my privilege at this time. Thank you. MR. SCAROLA: She would really like to be able to give you the answer to that question. MS. BORJA: Counsel, I would appreciate -- MR. SCAROLA: All right. I couldn't resist. MS. BORJA: 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. MR. SCAROLA: I absolutely agree with you. It is not a joke. SPECIAL MASTER: Let's move on. I understand. Let's move on. BY MS. BORJA: Q. Did you ever tell anybody other than your lawyers ever about your allegation that you had sex in the limousine? A. I've spoken with my husband about the times and experiences that I had with Dershowitz. Q. Including the limousine? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 175 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 175 A. Including all of the times that I can remember that I've told him. I mean, he's my best friend so. Q. This affidavit was signed November 20th, 2015. So around this past Thanksgiving. So you first remembered it since Thanksgiving? A. Yes. Q. So, since Thanksgiving have you had conversations with anybody about the allegation? A. 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. Q. How long did that sexual activity in the limousine take place? A. Not long. Q. What happened? A. You want a description? Q. I would like to know what happened in that limousine that is the abuse that you're alleging happened? A. Jeffrey instigated it, the men pulled out their, the wording for this is just anatomy. They pulled out their anatomy, their genitals and we were told to perform oral sex on them. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 176 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 176 Q. There was no discussion between the gentlemen beforehand that you heard? A. You know, I don't know the exact terms that they used during that time, but Jeffrey insinuated it and Alan agreed to it, so yes. Q. The time on the plane where you allege that you and another female participated in sexual activity, was that at the same time? MS. MCCAWLEY: Objection. A. What, the girl and me and Jeffrey and Dershowitz, was that like all together? Q. Tell me what happened on the plane? A. It went from -- MS. MCCAWLEY: Just use the best terms you can. Take your time. A. Sorry, it wasn't from giving foot massages, which is a normal thing 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 messages to oral sex to intercourse. Q. So who was involved, I mean, you were sexually involved with Professor Dershowitz, correct? A. Yes. It was kind of -- to be honest it Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 177 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 177 was -- MS. MCCAWLEY: Use a term that you can use. A. It was a little bit of 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 swapped within, I would say seconds, like 60 seconds to a minute we were told, you know, 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. Q. The foot messages, who gave who foot messages? A. I believe I was giving Jeffrey a foot massage and the other young lady was giving Dershowitz a foot message? Q. Anything else happen during that flight? A. After the sexual experiences, which is what I had been trained to do anyway, which was not out of the ordinary, I went to the back of the plane, got washcloths and proceeded to clean Jeffrey and Dershowitz up with a warm washcloth. Q. During this activity were condoms used? A. No. Q. Were condoms ever used with Professor Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 178 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 178 Dershowitz? A. No, and they weren't used with any other people as well. Q. Were the other people that you were sexual trafficked to? A. No. Q. Did you ever ask to use a condom? A. No, I mean, Jeffrey had us tested quite regularly so we knew we were clean. Q. You've never had a sexually transmitted disease? A. No. Q. Where would you get tested? A. At a doctors. To be specific a gynecologist. Q. Who was your doctor? A. A gynecologist in Palm Beach. Q. Who is that? A. I have no idea. Q. Were you ever hospitalized during 1999 to 2002? A. Yes. Q. For what? MS. MCCAWLEY: I object to the extent that this gets into private medical discussions. I Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 179 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 179 don't think she has to do that in this deposition. SPECIAL MASTER: Please answer the question. A. 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. Her question was -- A. Yes, I was medically brought to a hospital. Q. For mental health or physical health? A. Physical. Q. It didn't have anything to do with a sexually transmitted disease; is that correct? A. No, it wasn't a sexually transmitted disease. Q. Do you know which hospital you were treated at? A. No, but I know it was in New York. Q. 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? A. 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. Q. Were you given any medication as a result Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 180 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 180 of -- A. Yes. Q. What were you given? A. I don't know. I mean, I'm a young kid, I didn't know the medications or the terminology or anything. I think it was some kind of antibiotic. Q. You weren't given some sort of pain reliever? A. Yes, I was given pain relief at the hospital. I think I left the hospital with the antibiotics. Q. Do you have a book agent? A. What's a book agent? MS. MCCAWLEY: Objection. BY MS. BORJA: Q. Somebody to help you negotiate a book or media contract? MS. MCCAWLEY: Objection. This is again one of the requests that Judge Lynch quashed relating to their inquiry and their subpoena as to communications with -- it's actually two of them. He quashed 9, communications with media; he quashed 17, communications relating to potential book deals, et cetera. It's absolutely relevant as to whether or Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 181 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 181 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? MS. BORJA: 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. MS. MCCAWLEY: 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 those items. SPECIAL MASTER: And your question is whether she has a book agent? That's the question? MS. BORJA: Right. SPECIAL MASTER: I think you can answer that question. A. Well, I don't have a book deal, but I have Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 182 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 182 looked into getting a book agent. SPECIAL MASTER: Do you have a book agent is the question? A. Not at this time, no. I did at one time. Q. When did you have one? A. Book in 2012, maybe the end of 2011. Q. Who was that? MS. MCCAWLEY: Again, I object to all this testimony. We had a motion to quash on this. We won that 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. A. His name is Gerad? Q. Who does he work for? A. 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 about him. 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. Q. Did you tell him about Professor Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 183 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 183 Dershowitz? A. No. Q. Why not? A. Because we didn't even talk in lengthy discussion about that. We mostly talked about -- if I were going to have -- I can't say that. I mean, it's mostly about the sickening discussions, I mean, sickening ordeal that Epstein got away with so many counts of maliciously hurting minors and got away with it. That's more my idea if I was going to ever write a book. Q. Do you have any agreement or understanding with Boise, Schiller regarding what would happen if you did receive any monetary amounts from Mr. Wexner? MS. MCCAWLEY: 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 have to respond to any of that. SPECIAL MASTER: I'm going to grant that motion. BY MS. BORJA: Q. Did you receive a payment of 10 or $15,000 after you claim that you had sex with Prince Andrew? MS. MCCAWLEY: Objection, it gets into the remuneration of which has already been quashed in one of the questions. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 184 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 184 MR. SCAROLA: I also don't understand the scope of the question. From whom, for what, did she ever get 10 or $15,000 in the last years unrelated to this case? The objection is overbroad, vague, confusing. SPECIAL MASTER: Put a time frame on it counsel and then I'll see. Put a time frame. BY MS. BORJA: Q. 2011 were you paid 10 to $15,000 by or on behalf of Jeffrey Epstein for having sex with Prince Andrew? A. 2011. Q. I'm sorry 2001? A. Is that granted? SPECIAL MASTER: I didn't make a determination yet. MS. MCCAWLEY: Same objection. THE WITNESS: Sorry. SPECIAL MASTER: I'm going to allow the question. I'm going to overrule the objection. You can answer if you know. A. Yes, I did receive $15,000. I don't know what equivalent that is to pounds. I received it in American dollars. COURT REPORTER: Repeat that again. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 185 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 185 A. I did receive $15,000. I do not know the equivalent to what that is in pounds. Q. And you didn't pay taxes on that? A. No. Q. When did you first retain Paul Cassell as your counsel? MS. MCCAWLEY: You can give the date but can't get into discussions you had with Mr. Cassell. SPECIAL MASTER: That's the question. A. I don't know the exact date, I'm sorry. Q. What's your best estimate? A. Well, I started talking to Brad in the fall in 2011, but I never met them personally until 2013 I think. So I don't know when I officially became their client. Q. When do you consider that you became their client, was it when you first met them? A. Personally, like face to face? Q. I'm asking you that question? I'm not suggesting that's the answer. A. No, that's why I'm asking you. When I talked to them on the phone or met them face to face? Q. Do you consider when you met them face to face as being the first time that you engaged them or Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 186 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 186 some other time? A. I believe when we first met face to face is when I became their client, I think that's right. Q. When did you first meet Brad Edwards face to face? A. The same time I met Paul. I think it's 2013. Q. Whenever it was that's when you engaged him to be your lawyer in your mind? A. 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. Q. But your understanding is when you met them you wanted them to represent you? A. Oh yeah, I wanted them to represent me from 2011. I just wanted to be a part of the CVRA case. I wanted my story to be heard and I wanted to help other victims out there, so yes. MR. SCAROLA: 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? THE VIDEOGRAPHER: Seven. MR. SCAROLA: Seven minutes left. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 187 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 187 MS. BORJA: You did not cross notice this so if counsel wants to give you time that would be up to counsel. MR. SCAROLA: I don't know that it's necessary for me to cross-notice the depo. SPECIAL MASTER: Hang on one second. We have seven minutes, let's spend it wisely. Counsel is not finished with her examination. So she is entitled to complete her examination before handing it off. MS. MCCAWLEY: I'm comfortable allowing her four hours and then if you have questions we can deal with that. (Thereupon, VR Defendant's Exhibit No. 10 was Marked for Identification.) BY MS. BORJA: Q. Ms. Giuffre, I've handed you a document that's been marked as VR 10 which is a Federal Bureau of Investigation document consisting of 12 pages. Do you have that? A. Yes, I do. Q. Have you seen that before today? A. Yes, I have. Q. When did you first see this? A. I'm not too sure if the FBI gave me a copy Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 188 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 188 of it. I think it's a possibility that they did, otherwise I would have seen it from my lawyers. Q. If the FBI gave you a copy of it what would you have done with it? A. Probably put it in a big file in the back of my closet. Q. Do you keep a big file in the back of your closet with your personal papers? A. You should see my filing system, it's quite horrible. Q. Do you have -- actually let's turn to page 10 of 12? MS. MCCAWLEY: Numbered at the top, the very corner. A. Okay. Q. It says Giuffre recalled meeting, and then it's redacted. Giuffre was using Xanax, heavily at the time. Her recollection was not clear. She remembered that there were many models on the island that did not speak English along with a modeling person who had an unknown accent. Do you see that? A. Yes. Q. Do you know what incident this is referring to. A. With all the blanks there, that's not a Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 189 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 189 unusual thing because there was lots of models there. Q. Do you remember telling the FBI that you couldn't remember an incident because you were using Xanax heavily at the time and your recollection was not clear? A. No, I remember telling them that I used Xanax so of course things are going to be foggy, but some things severely stick out, you just can't remember no matter how much Xanax or anything else you take. MR. SCAROLA: Could you read that last response back again, please? MS. BORJA: During you deposition you can read back. MR. SCAROLA: No, I would like -- I'm not sure that I heard it correctly. If I could hear it back now please? MS. BORJA: No, you can read it on cross examination. I'm moving on. SPECIAL MASTER: Hold on a second. Read it back so we can move on. MR. SCAROLA: Thank you. (Last answer was read back by the court reporter.) MR. SCAROLA: Thank you. SPECIAL MASTER: Counsel? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 190 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 190 BY MS. BORJA: Q. When we started today I asked you about the subpoena duces tecum that's been marked in this case do you have that? A. I don't know of the subpoena. MS. MCCAWLEY: It's going to be one of the exhibits here. SPECIAL MASTER: Are you talking about the actual notice? MS. BORJA: I'm asking about the actual notice. MS. MCCAWLEY: I don't think that was marked. I'm sorry, there is a schedule A attached to the notice you marked. If you flip this page on the notice. SPECIAL MASTER: VR 1, there's a schedule attached to VR 1. MS. MCCAWLEY: You can use mine. A. Which page would you like me to look at? Q. Let's start with schedule A, number 1. Have you seen this document before? A. No, other than maybe you showing it to me today. It's in my pile. It's not in my pile, is it? I don't know. I haven't seen it. Q. Did you collect documents to give to Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 191 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 191 Professor Dershowitz as a part of this action? A. Did I collect documents to give to Dershowitz? Q. Correct? A. Why would I do -- no. Q. Do you have -- did you ever check to see if you have any original photographs in your possession? A. Unfortunately, I don't have lots of photographs because I left a lot of things behind in America when I moved to Australia. Q. Ms. Roberts, my questions is -- A. No, I don't have any in my hand or possession. Q. Did you look for any? A. I've seen the photos that I have and no, I don't see any of Alan Dershowitz in there. Q. My question was, were you looking for any original photographs to produce to Professor Dershowitz in this case, did you look? A. No. MS. MCCAWLEY: Other than what your lawyers have done for you I think is what she's asking. You made a production in this case and I think she may have been asking you questions about that. SPECIAL MASTER: Counsel, she's asking a Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 192 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 192 specific question of the witness. A. I'm sorry, that's my fault, I didn't understand the question. But no, I was not looking for photographs for Dershowitz. Q. Do you have any notes of any sort pertaining to Professor Dershowitz? A. I've got lots of affidavits. I don't know what these things are called, documents. Yes, I do have lots of those. Q. Do you have any drafts of those before they're final and you sign them? A. No, I've got final -- I've got stuff like this, declarations signed on the back. Q. You get a declaration at some point, right? A. Yes. Q. And it's not signed, correct? A. I sign it and my lawyers print it out for me. Q. Do you make any changes? A. Not unless there needs to be changes, but my lawyers do a great job of recording everything that I say. Q. But you've never made revisions, correct? A. Not that I'm aware of. Q. Have you made any notes, personal notes on Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 193 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 193 scraps of paper or notepads, the booklet pertaining to -- other than the ones that you gave, the pages that you gave to Ms. Churcher? A. I didn't give anything to Ms. Churcher about Alan Dershowitz, but when I'm going through, you know, my affidavits and stuff like that, if I do get a memory that sticks out, yes, I will write it down, you know, and think about it, but I don't have, you know, notes per se that have Dershowitz written all over it, no. Q. But when you think of something you write it down to help you with your memory? A. Yes. Q. What do you do with those documents? A. I'm a visual person so generally I just write them down and then I forget about it. It's not like -- I don't hold on to everything basically if that's what you're asking me. Q. Does any of it go to the file in the back of the closet? A. No, these do though. These are always back there, but, no. Q. Did you ever look to see if you had any notes that related to any times that you met Professor Dershowitz? Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 194 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 194 A. Besides what's in these? Q. Did you ever look to see if you had any personal notes in your writing that pertain to Professor Dershowitz? A. Like from my old journal, the one that I burned? Q. From anywhere. Did you ever make an effort to look? A. Dershowitz could have been in my journal, he could have been. We're talking about an 85 page, if not more, you know, things that I had written to get my story out of my head and into pages; and yes, Dershowitz could have been in there, but that's up in the clouds now, bonfire. Q. That's what you call your journals, what you burned, right? A. Yes. Q. And you wrote that journal in order to collect your thoughts? A. To get everything out of here and on to paper. Q. Have you made any other notes, though, since then to help you when you think of things? A. Yes, sometimes like I said, sometimes when I read my affidavits and stuff like that, you know, and I Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 195 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 195 think of something else like a description of something that I forget about, you know what I mean, then yeah, I'll go back and I'll write it in the journal, you know, for instance, you know, what another girl would have looked like. Even though I can't identify her name or her age or anything like that, but I do remember like flashes of blonde, little things like that, but nothing -- I don't have any more journals. Q. But those notes, they help your memory? A. Sometimes. I'm a very visual person. Q. And they help you with your affidavits? A. No, they don't help me with my affidavits, my affidavits are already done, I just go back and it helps my memory. It helps me bring stuff out. Q. What do you do with those notes? A. Nothing, literally nothing. They're in a notebook that if I need to write it down. I have a dream notebook as well where I'll just write down my dreams and stuff. I do nothing, no one is seeing it. Q. You read it? You keep it? A. Yeah, I keep it. Q. Okay. Have you gone back and read that recently? A. No. Q. Okay. You continue to make entries into Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 196 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 196 it? A. Not so much about Dershowitz. It's mostly like feelings, dreams, you know, past things that I've gone through. Like I said, not so much pertaining to Dershowitz himself. Q. And that's separate from your dream book? A. No, it's all in one. Q. Is it a spiral bound notebook? A. Yes, it's just a cheap, like, actually it's in my kid's closet. Q. At this point in time are you angry with Mr. Epstein? A. Furious. Q. Are you angry with Professor Dershowitz? A. Absolutely. Q. Are you angry with famous politicians? A. I'm angry with anybody who has it in their mind that they can hurt and abuse a minor child and continue to lie about getting away with it and that what they've done is okay and they can continue to harass victims, yes, I'm furious. Q. Are you angry with Professor Dershowitz for his role in representing Jeffrey Epstein in the criminal action? A. Do I think he played a big part getting him Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 197 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 197 off, absolutely. So many other lawyers of his, I'm angry with them, too. Q. Do you know what role Professor Dershowitz played in the criminal prosecution of Jeffrey Epstein? A. No, by the time all the plea bargains and everything had happened I was just a notified victim. I didn't know, you know, hey, ex's said this and now this is going to be done. I was already way past that point and, hey, sorry, this is what you got to deal with. Q. And you don't know personally what role he had in the non-prosecution agreements with Mr. Epstein, is that fair? A. That's fair. I know he played a part in it, I know he was one of his lawyers. Q. What part do you know he played in it? MS. MCCAWLEY: Objection, asked and answered. SPECIAL MASTER: You can answer. MR. SCAROLA: Except to the extent that the information is derived from attorney/client privileged communications. SPECIAL MASTER: Agreed. THE WITNESS: What does that mean? SPECIAL MASTER: Outside of what your lawyers discussed if you can answer that question. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 198 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 198 A. I knew he was his lawyer from what I've been told. Q. But you don't know anything specific regarding the non-prosecution agreements, correct? A. No. MS. MCCAWLEY: Can we have a time check. THE VIDEOGRAPHER: Four hours and seven minutes. MS. MCCAWLEY: We're going to wrap this up. We've indulged -- SPECIAL MASTER: How much further do you have in this line? MS. BORJA: In this line? Nothing, but I do have a lot more questions. SPECIAL MASTER: I'm sure that you do. Okay. I think it's a good place for us to break because I think we've satisfied what I see as the Court's order, four minutes -- four hours and you've gone a little bit over, but that's actually the running time, correct? THE VIDEOGRAPHER: Yes. SPECIAL MASTER: Based upon the Court's order I think the deposition is concluded. MS. MCCAWLEY: We're going to allow it be -- because I didn't interfere with her four hours, Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 199 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 199 so I allowed that to happen. MR. SCOTT: We object to that. The Court's order said four hours. The Court's order provided for us to have the four hours and now all of a sudden by agreement of the plaintiff's attorney and the witnesses' lawyer without ever requesting it from the judge, we're now going to agree to extent the period? SPECIAL MASTER: Mr. Scarola? MR. SCAROLA: The Court's order provided for a four-hour deposition. I requested an opportunity to have some time within that four hours and we've allowed opposing counsel to use more than the four-hour time. I have probably five minutes worth of questioning and I would like an opportunity to be able to ask those questions. MR. SCOTT: We oppose that and if he does then we want to re-direct. SPECIAL MASTER: That was exactly the point. So just understand that if I do grant the extra time to Mr. Scarola of five minutes or not that they're going to get an opportunity to discuss the topics that he raises and we're going to sit here for however how long they're satisfied with those questions in the topic areas that he Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 200 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 200 raises. Do you understand that? MS. MCCAWLEY: I do. So let's take a break. It's a moment to take a break and I'll discuss with these folks and we'll come back. THE VIDEOGRAPHER: Going off video record 2:25 p.m. (A recess was taken.) THE VIDEOGRAPHER: We're now back on video record 2:32 p.m. SPECIAL MASTER: Just for the record, Mr. Dershowitz through counsel examined the witness for four hours and seven minutes and there was a request and it appears to be in agreement to allow. MR. SCOTT: No agreement. SPECIAL MASTER: Hang on one second. Hang on. Between Mr. Scarola and Ms. McCawley, to allow Mr. Scarola a couple questions on examination on cross and then my ruling is going to be as follows: You can go ahead and ask whatever questions you want, Mr. Scarola, at which time I will give opportunity for re-direct based upon the topics that you've raised. MR. SCAROLA: With the understanding that re-direct is going to be limited to the area of Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 201 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 201 inquiry that I am about to conduct. I am about to conduct an inquiry. SPECIAL MASTER: That is the understanding. My understanding of my ruling, I know that Mr. Dershowitz' team has objected to that. I also understand that there might be -- this is no impact or their right or anybody else's right to go back to Judge Lynch and ask for more time from this witness based upon my ruling or my reading of the original order. MS. MCCAWLEY: And there's also the motion to strike the testimony that you allowed over the ruling. SPECIAL MASTER: And there's a series of those things that might need to be cleaned up in a subsequent sitting. MR. SCOTT: It's my understanding this is going to be limited to five minutes or less; is that correct? MR. SCAROLA: That's what I anticipate. MR. SCOTT: Over our objection, okay. SPECIAL MASTER: Let's rock and roll. CROSS-EXAMINATION BY MR. SCAROLA: Q. Virginia, has Brad Edwards ever pressured Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 202 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 202 you or encouraged you in any way whatsoever at any time and under any circumstances to provide false information about Alan Dershowitz? A. Never. Q. Has Brad Edwards ever pressured you or encouraged you in any way or under any circumstances at any time to provide false information about Jeffrey Epstein? A. Never. Q. Has he ever pressured you or encouraged you at any time or in any way, under any circumstances to provide false information about anyone or anything? A. Never. Q. Has Paul Cassell ever pressured you or encouraged you in any way, at any time, under any circumstances to provide false information about Alan Dershowitz? A. Never. Q. Has he ever pressured or encouraged you in any way at any time, under any circumstances to provide false information about Jeffrey Epstein? A. Never. MS. BORJA: Objection. I couldn't follow who he was. BY MR. SCAROLA: Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 203 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 203 Q. Mr. Cassell, Professor Cassell? You understood that I was asking you that question about Professor Cassell, right? A. And he's never pressured me or encouraged me in any way to talk -- MS. MCCAWLEY: I don't want you to go into discussions with them if you're saying something didn't happen -- SPECIAL MASTER: Just -- MS. MCCAWLEY: I'm preserving privilege. I just want to make sure if something didn't happen she can say that. BY MR. SCAROLA: Q. Has Professor Cassell ever pressured you or encouraged you in any way to provide false information about anyone or anything at any time? A. Never. Q. Apart from any efforts made by Jeffrey Epstein or agents on behalf of Jeffrey Epstein to silence you or to have you refrain from providing true and accurate information about the interactions that you had with Jeffrey Epstein and others to whom you were trafficked by Jeffrey Epstein, has anyone apart from that circumstance pressured you or encouraged you to provide false information about any of the topics that were Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 204 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 204 covered during the course of your examination? MS. BORJA: Objection. Objection to the form. Leading, assumes facts not in evidence, compound, misleading. SPECIAL MASTER: Your form objection will be reserved. You can answer. A. No. MR. SCAROLA: Thank you. I don't have any further questions. MR. SCOTT: Judge, excuse me, none of this was covered on direct examination so we move to exclude and strike the entire testimony because none of this was covered on our direct. But we would like to request a two-minute recess because these are completely new areas. SPECIAL MASTER: I'll grand your two-minute recess. THE VIDEOGRAPHER: Going off video record 2:37 p.m. (A recess was taken.) THE VIDEOGRAPHER: We are now back on video record 2:41 p.m. MR. SCAROLA: Could we have a reading how much time is used in my examination. SPECIAL MASTER: That's going to be Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 205 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 205 irrelevant at this point, but you can ask. THE VIDEOGRAPHER: It's going to be about eight minutes, seven minutes of change. MR. SCAROLA: Hard for me to believe that but if the counter says what the counter says. SPECIAL MASTER: The overtime got three minutes, let's go. REDIRECT EXAMINATION BY MS. BORJA: Q. Before you were scheduled here under oath today by Mr. Scarola, did you talk to him in the break before that? MS. MCCAWLEY: Objection to the extent you discussed privileged information with your lawyers you don't have to reveal. BY MS. BORJA: Q. I'm asking what she talked about with Mr. Scott? MS. MCCAWLEY: She's in a joint defense agreement with Mr. Scarola. BY MS. BORJA: Q. Are you in a joint defense agreement with Mr. Scarola? MR. SCAROLA: I will tell you that there is a joint defense, a common interest privilege Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 206 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 206 agreement between the witness and my clients, yes. SPECIAL MASTER: Are you asserting that privilege then? MR. SCAROLA: Yes, we are asserting that privilege and instructing the witness not to answer on the basis of the privilege that exists for Bradley Edwards and Professor Cassell. SPECIAL MASTER: So with that I'm going to grant the motion similar to what I did the other day when Mr. Dershowitz was testifying and under the reservation that that can be dealt with later in front of the judge or in front of me, whichever you choose. BY MS. BORJA: Q. Now, I understand from your testimony that Mr. Edwards did not pressure you to give false information about this matter, is that fair? A. That's fair. Q. Tell me everything that Mr. Edwards told you about this matter? MS. MCCAWLEY: Objection, that's privileged and she has not waived any privilege. She's not here testifying as to what she discussed with her lawyers. SPECIAL MASTER: You know, it's an Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 207 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 207 interesting point. I'm going to grant your motion for privilege, but I'm going to suggest to you that there might be a strong argument to be made that those questions opened some of the door. I'm going to let the judge decide that. But you can go ahead, ask the questions, we'll put it on the record for later determination, and it's going to force, to be blunt, this among other things may force the witness to come back and complete the deposition. Just let's be aware of that. MS. BORJA: And I can't make a proffer to all of my questions because some of them will depend on this witness' answers. SPECIAL MASTER: I'm aware of that. MS. BORJA: I want the record to be clear that although I'm being asked for a proffer, I'm constrained based on my inability to follow up. SPECIAL MASTER: I understand that, but I'm sure that you have a couple questions that you'd like to proffer to give the record an idea of where you might have gone without restraint to what the answer might be and then a subsequent question might lead from the answer, I understand that. BY MS. BORJA: Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 208 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 208 Q. Did Mr. Edwards ever suggest to you anything regarding Professor Dershowitz? MS. MCCAWLEY: Objection. Hang on, I'm objecting. She's making a proffer and I need to make my objection on the record. Do not answer. Objection, attorney/client privilege. SPECIAL MASTER: So I'm going to grant within the reservation it be brought back later. BY MS. BORJA: Q. Did Paul Cassell ever tell you anything about the topics that were covered in today's deposition? MS. MCCAWLEY: Objection, attorney/client privilege. SPECIAL MASTER: Same ruling. BY MS. BORJA: Q. Did anyone from Boise, Schiller ever tell you anything about the topics that were covered in today's deposition? MS. MCCAWLEY: Objection, privileged work product. SPECIAL MASTER: Same ruling. BY MS. BORJA: Q. Did Mr. Scarola ever tell you anything about the topics that were covered in today's deposition? MS. MCCAWLEY: Objection, attorney/client Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 209 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 209 privilege. SPECIAL MASTER: Same ruling. BY MS. BORJA: Q. Did the group that is Mr. Edwards, Mr. Cassell, Boise, Schiller, whether it's Ms. McCawley, or others or Jack Scarola ever tell you anything about Professor Dershowitz at all? MS. MCCAWLEY: Objection, privileged information. SPECIAL MASTER: To the extent it's privileged I'll grant the motion. MS. MCCAWLEY: If you can answer that. SPECIAL MASTER: To the extent it's privileged I'll grant the motion under the same reservation. MS. MCCAWLEY: The question is, do you have any non-privileged information? You want to re-ask question. A. I don't have any non-privileged information. Q. Did they ever tell you anything before you retained them as counsel? A. No. Q. Did Mr. Edwards, Mr. Cassell, Boise, Schiller firm or Mr. SCAROLA ever tell you anything about Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 210 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 210 the circumstances of your sexual traffic, alleged sexual trafficking to other individuals such as foreign presidents? MS. MCCAWLEY: Objection. That would be privileged. SPECIAL MASTER: Same ruling. BY MS. BORJA: Q. Did the group that includes Mr. Edwards, Mr. Cassell, Boise Schiller, Mr. Scarola ever tell you anything with regard to any allegations of sexual abuse by Professor Dershowitz of other minors? MS. MCCAWLEY: Objection. It would be privileged. SPECIAL MASTER: I'm going to grand the same thing. Let me share with you in order to -- I do think it's unfair to have them proffer virtually every question possible because it would depend upon the potential answer. MS. MCCAWLEY: I understand. SPECIAL MASTER: If the ruling comes down that this area of inquiry for whatever reason, waive of privilege or for whatever reason is allowed to be pursued then I'm going to provide Mr. Dershowitz and his team wide latitude to follow up on the questions should we re-set and Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 211 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 211 re-visit this. MS. MCCAWLEY: I understand. MR. SCAROLA: And we'll agree that the questions that have been asked adequately -- MR. SCOTT: That's what I wanted -- MR. SCAROLA: Yes, adequately establish a record for presentation to the Court. MR. SCOTT: As long as Mr. Scarola and you agree, also, counsel? MS. MCCAWLEY: Do I agree that they adequately established a record as to what you ruled that can be presented here, yes. MR. SCOTT: Okay. So with that I think we're done. MS. BORJA: We just need to confirm that the witness is going to following the instructions of her counsel; is that correct? THE WITNESS: Yes. MR. SCOTT: Thank you, Mr. Scarola. SPECIAL MASTER: That short circuits it, I appreciate it. We're concluded. MS. BORJA: Unless I'm allowed to conduct a cross examination about the pressure that her lawyers gave her and the circumstances of that pressure and what they told her. Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 212 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 CONFIDENTIAL 212 SPECIAL MASTER: Well, obviously that would be subject to the area we just -- MS. BORJA: Then if that's -- SPECIAL MASTER: Anything else? MS. BORJA: No. I just want the record to be clear that we've been precluded about cross examination about the exact scope of the examination from Mr. Scarola regarding pressure. SPECIAL MASTER: Based upon what Mr. Scarola just agreed to and counsel just agreed to, I think that we have, and I think my rulings are also clear on the issue. MR. SCOTT: I think we're done. COURT REPORTER: Do you need this ordered? MS. BORJA: Yes. COURT REPORTER: Mr. Scarola, do you need a copy of this? MR. SCAROLA: Yes. THE VIDEOGRAPHER: That concludes the videotaped deposition. The time is 2:48 p.m. (Thereupon, the deposition was concluded at 2:48 p.m.) Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 213 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 213 CERTIFICATE OF OATH STATE OF FLORIDA, COUNTY OF DADE, I, Deborah A. Harris, the undersigned authority and Notary Public certify that VIRGINIA ROBERTS GIUFFRE personally appeared before me and was duly sworn on the 16th day of January, 2016. Sworn to before me this 20th day of January, 2016. _______________________________ Deborah A. Harris, Court Reporter Notary Public - State of Florida My Commission No. FF 246867 My Commission Expires: October 31, 2019 Job No. JO277789 Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 214 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 214 REPORTER'S CERTIFICATE I, Deborah A. Harris, Florida Professional Court Reporter and Notary Public in and for the State of Florida at Large, do hereby certify that I was authorized to and did report said deposition in stenotype; and that the foregoing pages 1 through 216 are a true and correct transcription of my shorthand notes of said deposition. I further certify that said deposition was taken at the time and place hereinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out. I further certify that I am not an attorney or counsel of any of the parties, nor am I a relative or employee of any attorney or counsel of party connected with the action, nor am I financially interested in the action. The foregoing certification of this transcript does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter. DATED this 20th day of January, 2016. ________________________________ Deborah A. Harris, Court Reporter Job No. JO277789 Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 215 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 215 DEPOSITION ERRATA SHEET Assignment no: JO277789 Bradley J. Edwards and Paul G. Cassell vs. Alan M. Dershowitz ** DECLARATION UNDER PENALTY OF PERJURY I declare under penalty of perjury that I have read the entire transcript of my videotaped deposition taken in the captioned matter or the same has been read to me, and the same is true and accurate, save and except for changes and/or corrections, if any, as indicated by me on the DEPOSITION ERRATA SHEET hereof, with the understanding that I offer these changes as if still under oath. Signed on the ______ day of ____________, 20___. ___________________________________ VIRGINIA ROBERTS GIUFFRE Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 216 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 216 DEPOSITION ERRATA SHEET Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: _________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ SIGNATURE:_______________________DATE:___________ VIRGINIA ROBERTS GIUFFRE Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 217 of 223 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 217 DEPOSITION ERRATA SHEET Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ Page No.____Line No._____Change to: _________________________________________________________ Reason for change: __________________________________ SIGNATURE:_______________________DATE:______________ VIRGINIA ROBERTS GIUFFRE Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 218 of 223 BO I E S, S CH I LL E R & FL E X N E R LL P 401 EAST LAS OLAS BOULEVARD • SUITE 1200 • FORT LAUDERDALE FL 3330 - 22 I • PH 954 356 001 • FAX 954 356 0022 CONFIDENTIAL/SEALED DEPOSITION SPECIAL TREATI\IENT REQUIRED February l 0, 2016 VIA E-MAIL & FEDERAL EXPRESS Esquire Solutions PRODUCTION DEPARTMENT l 01 Marietta Street Atlanta, Georgia 30303 errata@esguiresolutions.com Sigrid S. McCawley, Esq. E-mail: smccawley(cv,bsntp.com Re: Confidential/Sealed Deposition Transcript, Job No. J02777789 (Errata changes to be treated in same manner). To Whom It May Concern: Attached please find the errata changes for the Videotaped Deposition of Virginia Roberts Giuffre taken January 16, 2016. This transcript has been designated as Confidential and has been sealed by the Court. Please ensure that all materiaJs including transcript, errata changes and video tape are treated accordingly. lf you have any questions regarding the errata changes or treatment of confidential/sealed materials, please do not hesitate to contact me at (954) 356-0011. SSM:sp Enclosures Sincerely, WWW BSFLLP.COM Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 219 of 223 Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Joh N o. J0277789 1 3 Ass i g nment no: J0277789 'i VS. 6 Alan M. D~rshowitz l s OEClARATTON U~OrR rrNAlTY or P~RJURY C) 10 r declare under penalty of perjury that I 17 deposition t~ken in rhe captioned matt~r or ~he same has l 1 b c {-) n r e ii: d t o r., e . 2. n d t r1 t2 s a tn €! i s t r u c .:i n d a c c u r il Tc , s a v e 14 and cx<{'.P1, for <_h;J,ngc·, ~nd/or· corn~<L1ons , if any. a~ ]5 indi(Jtert by ~eon the DFPOSITTON ERRATA SHEET hereof, 17 st i 11 undc r· CM th. 1 8 19 20 20 ]Li . ~, i qned on the • I J l. d.i.v of Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 220 of 223 Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. J0277789 DEPOSITION ERRATA SHEET Page No. 6 L1 r:e No. 17 f'hane:e to: "Yes. 1 signed the subpoena cluc,·s 1c c1101." Rec\s011 for ch:\ng~' : D id not it1 1t.ally 1·cco1u117.c th : dui.:umcnL r age J\:o. 6 Line "No. ::,o Chan!!c to: .. No. i\Iy lawyers wor kc-cl with me to cc,llcd documents and my undcrsfa ndin~ is tha l we !u rned I hose documents o,·cr to Dcn1howilL's counsel prio r lo the tlcposition.'' Reason tor change: Clarification of .inswcr Page No. 9 Lrnc No. q Chan12.e to: "\\·s." Rrnson for change: Diel nol initiall) rn:ogni1c: tl1c doc111111.:11r. Page No. I I Reason for change: Mi·rnmkrsloou th1: question Line l\os . ..J-5 C'lia11g_l'_JQ: •' J'm con fused. I d on'I know wh a t f'orl'ign prcsitknt yo 11 ' r l' talking :.ihout." Rca!->Oll for change : M isundcrstood the question Page No. 11 Lin,.; No. n ChangL· to: '·( undl·rstnnd wt•ll-1.nown prillll' minisfl>rs and olhcr " orld leade rs; as frir a.s foreign p rcsidcnls, T believe so." Rcnson for clrnngc-. !vli~u11<kr:-:ood tb.: q11.:!'t i~JJ1 Png.e No. I:.: Linc 1'1 0 . :.: Ch211!!c 10: ·' Yes, assumin g South Amc,·ica is con~itlcn•d o,·crscas.'' Reason for change: Misundt·rstood the quc-stion Page No. I :2 L ine No. 8 Ch,muc to: "As fa r as I know right now, ~·es, I w:1s. " Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 221 of 223 Confidential/Sealed Transcript Pursmml to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. J0277789 Reason for ckmg.e: i'vlisllnd..:rstood th<: q11csliP11 --------· .......... --------------------------------.. -----------------------------. -------------------------------------- Page 1\'o. 38 l.;11..:No. 11 Chani:!e to: '·I'll eo11ti11ul' wi01 the li~t hen•. i\':idia iVIarcinko\'a I was not S('n l to her, but she was part ofit with Jeff Ep:-.tcin. Others on the list include '\1.arvi11 Minsk,· and Tom Pritzker." • Rcuson for r.:!ian~e: C lnri lir.:a:ion of :1nswa ----------------------------------------------. --------------... ........... ·-----------------------------. --------------- Pag..: 38 Linc 19 Clrn1w.e to: ''Off the top of 111y hc,HI, once, bu t ii could ha\'r UC('ll morc." Rensen for change: C'l<1ri fication ofanswi:r ----------------· ---------------------------------.. -............. _.,.._ ----------------------------------------------------- l':1ge No. 38 l.i111.: No. 2! Change to: ''l bdicYc Tom was at Mexico. I may haYc also hcrn with him in other places.•· Reason for change: Clari!ic,11ion 01· a:1:--,., i.:r ---------------........... ·-----------------------------.... ---------------------------------------·-------.......... --------- Li::c No. 8 Cha1;:·!e 10: "On an airplane nnd inn limo.•· Pnge No. -1 l Li11i.: Nn. 10 ChanQ.c to: "One. c<1ch time:.'' Rcaso:: fo1· change: Clari !iui: iu11 of ;i1h11 er -......................... ---------------------------------------.... ------------------------........ ----.. -------------------------- Page No. 41 Linc No. 12 Chang<.' to: "Ou airplane, blond, young.'' Rc:ason ~<)r change: Clari ficaiion of n11S1~e1 ----------------------------------------,.._ ......... _ ... __ ,..,.. ____ ------------------------------------- ------------------- Pngc No. 98 I ,inc '\Jo. 16 Chani!C to: "As you can see in th:it :inswer I'm not c,·cn sure. II wasn't six months, but between six months and :1 yearn hich is why l'm sayi ng niue months. It was an assu m p1io11, Tr cou Id ha,·e hecn six "eeks." Reason ror cha11gc: Clarification ot' a11swc1· -------------------------------------------------------------------------------------------------------------......... Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 222 of 223 Confidential/Sealed Transcript Pursuant to Court Order Videotaped Deposition of Virginia Roberts Giuffre (January 16, 2016) Job No. J0277789 Change to: " ;"fo, olhcr than maybe you showing ii to me today. It's in my pile. It's no! in my pile, is it'? I don·t know. f haven ' t seen it. J was ~en c:d wilh the subpoena, :rnd I signed for· it, and [ rc\·icwt•cl it .tt that time:." Re:ison fo:· chi:nge: Clmitic11tio11 of' ans\\'c:· ___ .,.. __________ ,...., .... ----------------------------------------------·-·----------------------------------------------- Page 191 Linc 5 Change to: "\Vhy would J do - nu. f uid collcc1 tl oc11mc111s and g:1vc them rn my lawyers in response to this subpoena. And my unclcn;tandi11g i~ thost· documcn ls were producNL" Reason for change: /\ 1 is•.111dcrsi0od the question Page 19 I Linc ~o Change to: ''Yes, bu t I did not han• an~ pictu re~ of mysclf'·11 it h Profr~scir Dcrshowitz." Rc11son fu1· change· r-..lisunc!e,·stoocJ th<.: question Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 223 of 223 COMPOSITE EXHIBIT 1 (Filed Under Seal) Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 1 of 106 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 2 of 106 2 (Pages 2 to 5) Page 2 1 2 APPEARANCES: 3 BOIES SCHILLER & FLEXNER, LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdatle, Florida, 33301 BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ, ESQUIRE EMMA ROSEN, PARALEGAL 7 8 FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN, P.L. Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 11 BY: BRAD EDWARDS, ESQUIRE 12 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE 20 21 Also Present: 22 James Christe, videographer 23 24 25 Page 3 1 2 THE VIDEOGRAPHER: We are now on 3 the record and recording. This begins 4 disk No. 1 in the deposition of 5 Ghislaine Maxwell in the matter of 6 Virginia Giuffre versus Ghislaine 7 Maxwell in the U.S. District Court for 8 the Southern District of New York. 9 Today is April 22, 2016 the time is 10 9:04 a.m.. This deposition is being 11 taken at 575 Lexington Avenue in New 12 York at the request of Sigrid McCawley 13 of Boies Schiller & Flexner. 14 The videographer is James Christe 15 and the court reporter is Leslie Fagin. 16 Will counsel state their appearance and 17 whom they represent and then court 18 reporter swear in Ms. Maxwell. 19 MS. McCAWLEY: My name is Sigrid 20 McCawley with my colleague Meredith 21 Schultz. We are with Boies Schiller & 22 Flexner. We represent Ms. Giuffre. 23 MR. EDWARDS: Brad Edwards. I also 24 represent Ms. Giuffre. 25 MR. CASSELL: Paul Cassell, I also Page 4 1 G Maxwell - Confidential 2 represent Ms. Giuffre. 3 MR. PAGLIUCA: Jeff Pagliuca and 4 Laura Menninger on behalf of Ms. 5 Maxwell. 6 G H I S L A I N E M A X W E L L, called 7 as a witness, having been duly sworn by a 8 Notary Public, was examined and testified as 9 follows: 10 EXAMINATION BY 11 MS. McCAWLEY: 12 Q. Good morning. I'm going to explain 13 some of the rules that will happen with 14 respect to depositions. 15 Have you ever been deposed before? 16 A. I have not. 17 Q. What is going to happen here, we 18 have a court reporter and a videographer. 19 What they do is take down the words that we 20 say so when I ask you a question they will 21 record what you say in response to that. So 22 we have to be mindful that in order for them 23 to do their job we can't talk over each 24 other. 25 Another issue you have to be weary Page 5 1 G Maxwell - Confidential 2 of is that in a response, you can't give a 3 nonverbal response, in other words, nodding a 4 yes or no, they need to hear verbal response 5 so they can record it on their transcript. 6 So that's important for you to remember as we 7 go through the day. If you forget, I will be 8 sure to remind you. 9 Is there anything that would 10 prevent you from giving truthful testimony 11 today? 12 A. There is not. 13 Q. You are not on any medications or 14 anything that would inhibit your ability to 15 remember or give truthful testimony? 16 A. I am not. 17 MR. PAGLIUCA: Could you identify 18 the assistant in the room. 19 MS. McCAWLEY: This is Emma Rosen 20 from our New York office. She is a 21 paralegal. 22 Q. Ms. Maxwell, can you please state 23 your address for the record? 24 A. Currently 25 Q. What is your date of birth? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 3 of 106 3 (Pages 6 to 9) Page 6 1 G Maxwell - Confidential 2 A. 3 Q. When did you first recruit a female 4 to work for Mr. Epstein? 5 MR. PAGLIUCA: I object to the form 6 and foundation of the question. I 7 believe this is confidential 8 information. I ask anyone who is not 9 admitted in this case be excused from 10 the room, please. 11 MS. McCAWLEY: So the response to 12 that question would -- 13 MR. PAGLIUCA: The subject matter 14 of this question is confidential and I'm 15 designating it as confidential. 16 MS. McCAWLEY: I just want to make 17 that clear for the record. 18 MR. EDWARDS: So we don't delay the 19 deposition I will step out of the room 20 but I think it's important to lay the 21 record that -- 22 MR. PAGLIUCA: I'm sorry, you are 23 not admitted in this proceeding so you 24 are not entitled to make any record. If 25 Ms. McCawley wants to make a record she Page 7 1 G Maxwell - Confidential 2 can. 3 MR. EDWARDS: I can make a record 4 right now. 5 MR. PAGLIUCA: Maybe we should get 6 the judge on the phone and talk about 7 it. 8 MR. EDWARDS: The record will be 9 short. This is the precise reason why 10 Ms. Giuffre wants me in this case and 11 I'm unable to effectively represent her 12 at this time because I am unable to have 13 access to the confidential information 14 which includes apparently the entire 15 deposition of Ms. Maxwell. But for the 16 sake of not further delaying this, I 17 will be outside the room. 18 MS. McCAWLEY: Thank you. 19 A. I would like to just -- wait for 20 him to leave. 21 Q. That's fine. 22 A. I would just like to clarify the 23 address. I'm in the process of selling the 24 house so while while I still receive mail 25 there, it's not my actual physical address. Page 8 1 G Maxwell - Confidential 2 It's in the process of being sold. It still 3 requires some final paperwork to be done, so 4 just for the purposes of clarity. 5 Q. Do you have a new address where you 6 will be living? 7 A. I do not. 8 Q. For the purpose of the record, if 9 there is something I ask you that you later 10 remember something else or need to correct 11 your testimony in some way, you can do that, 12 just let me know what it is and we will go 13 back to that question and can you clarify. 14 A. Of course. I just wanted to be 15 clear, there is still some paperwork pending 16 for final release, but it's in the process of 17 sale. But I don't have another address 18 currently, so whilst that should still be of 19 record that the mail could be forwarded 20 there, so for purposes of clarity I wanted to 21 be clear. 22 Q. I appreciate that. 23 So Ms. Maxwell, when did you first 24 recruit a female to work for Mr. Epstein? 25 MR. PAGLIUCA: Again. I object to Page 9 1 G Maxwell - Confidential 2 form and foundation of the question. 3 Q. You can answer the question. 4 A. First of all, can you please 5 clarify the question. I don't understand 6 what you mean by female, I don't understand 7 what you mean by recruit. Please be more 8 clear and specific about what you are 9 suggesting. 10 Q. Are you a female, is that the sex 11 that you are? 12 A. I am a female. 13 Q. That's what I'm referring to a 14 female and I'm asking you when you first, the 15 very first time you recruited a female to 16 work for Mr. Epstein? 17 A. Again, I don't understand what 18 female -- I am a 54 year old women. 19 Q. I'm not making it age, any age of a 20 female that you recruited to work for Mr. 21 Epstein? 22 A. Again, I was somebody who hired a 23 number of people to work for Mr. Epstein and 24 hiring is one of my functions. 25 Q. And when is the first time you MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 4 of 106 4 (Pages 10 to 13) Page 10 1 G Maxwell - Confidential 2 hired someone to work for Mr. Epstein, a 3 female? 4 A. As best as I can recollect, a woman 5 the age probably of about 40 or 50 was in 6 sometime in 1992. 7 Q. How long did you work for Mr. 8 Epstein? 9 A. I started working for him at some 10 point in 1992 and the nature of my work 11 relationship with him changed over time so 12 from around 2002, 2003, the work lessened 13 considerably. 14 Q. When did you -- 15 MR. PAGLIUCA: Can I interject for 16 a moment. If we are talking about 17 background -- 18 MS. McCAWLEY: I'm in the middle of 19 a question. Let me finish it and then 20 can you interject. 21 Q. When you say 2002 to 2003 that the 22 work lessened, when did you complete working 23 for Mr. Epstein; when was the last time you 24 were employed by him, the last date? 25 A. I believe I still was doing -- Page 11 1 G Maxwell - Confidential 2 helping him in a very nominal way, maybe an 3 hour or two a year at sometime 2008 and 2009. 4 MR. PAGLIUCA: So if you are going 5 to be talking about general background, 6 I don't need to designate that as 7 confidential. So if you want to have 8 them come back in, that's fine. 9 I assumed by your first question 10 you were going into more sensitive 11 areas. I will leave it up to you, but 12 if this is general background it will 13 not be designated as confidential. 14 MS. McCAWLEY: I appreciate that. 15 I will jump back into my other 16 questions. 17 MR. PAGLIUCA: So we will keep it 18 as confidential. 19 Q. When you were first employed by him 20 in 1992, what were you hired to do? 21 A. First, I was consulting and what I 22 did was I helped with decorating houses and 23 in hiring staff to help run those houses. 24 Q. Did your duties change over the 25 course of 1992 to 2009? Page 12 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. My job entailed running the homes 5 that he had but much more importantly, most 6 of the houses had construction and so whilst 7 in 1992 there was no construction project, 8 there was construction projects that began 9 after that time and I was in charge not only 10 of hiring architects, I was also in charge of 11 all the filings or overseeing that, like a 12 general contractor would. 13 I also helped with hiring the 14 architects, hiring the builders, reviewing 15 the contracts for the builders, coordinating 16 the building projects, coordinating how the 17 projects would layout, the timing of the 18 projects and all the various materials that 19 they would require to run a very substantial 20 building project. That's the nature of the 21 job I was dealing with. 22 Q. How old was the youngest female you 23 ever hired to work for Jeffrey? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Page 13 1 G Maxwell - Confidential 2 Q. You can answer. 3 A. I have not any idea exactly of the 4 youngest adult employee that I hired for 5 Jeffrey. 6 Q. When you say adult employee, did 7 you ever hire someone that was under the age 8 of 18? 9 A. Never. 10 Q. Did you ever bring someone who was 11 under -- invite someone under the age of 18 12 to Jeffrey's home, any of his homes? 13 MR. PAGLIUCA: Object to the form 14 foundation. 15 A. Can you repeat the question? 16 Q. Did you ever invite anybody who was 17 under the age of 18 to Jeffrey's homes? 18 MR. PAGLIUCA: Same objections. 19 A. I have a number of friends that 20 have children and friends of mine that have 21 kids and in the invitation of my friends and 22 their kids, I'm sure I may have invited some 23 of my friend's kids to come. 24 Q. Anybody that is not a friend of 25 yours. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 5 of 106 5 (Pages 14 to 17) Page 14 1 G Maxwell - Confidential 2 Any female under the age of 18, did 3 you invite them to come to Jeffrey's home? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 A. Again, as I said, I am not aware of 7 inviting anybody other than friends of mine 8 who have children to the house. 9 Q. Did you invite Virginia Giuffre to 10 come to Jeffrey Epstein's home when she was 11 under the age of 18? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. Virginia Roberts held herself out 15 as a masseuse and invited herself to come and 16 give a massage. 17 Q. My question is, did you invite 18 Virginia Roberts when she was under the age 19 of 18 to come to Jeffrey Epstein's home? 20 MR. PAGLIUCA: Object to the form 21 and foundation. 22 A. Again, Virginia Roberts was a 23 masseuse -- 24 Q. I'm asking not asking if she was a 25 masseuse. I'm asking if you invited her to Page 15 1 G Maxwell - Confidential 2 come to Jeffrey Epstein's home? 3 A. Again, there would be no course to 4 have a conversation with Virginia unless she 5 held herself out to be a masseuse. 6 Q. I'm not asking that question. I'm 7 asking if you invited her to come to Jeffrey 8 Epstein's home when she was under the age of 9 18? 10 A. Again, I repeat, she was a masseuse 11 and in the form and as my job, I was to have 12 people who he wanted for various things 13 including massage. She came as a masseuse. 14 Q. So you invited her to his home to 15 come to give a massage, is that correct? 16 MR. PAGLIUCA: Object to the form 17 and foundation. Misstates the witness' 18 testimony. 19 A. Again, I did not invite Virginia 20 Roberts. She came as a masseuse. 21 Q. She who invited her to come as a 22 masseuse, she just showed up at the front 23 door? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Page 16 1 G Maxwell - Confidential 2 A. Ms. Roberts held herself out -- 3 Q. I'm not asking how she held herself 4 out. I'm asking how she arrived at the home. 5 Did you meet her and invite her to come to 6 the home or how did she arrive there? 7 MR. PAGLIUCA: Object to the form 8 and foundation. 9 A. Ms. Roberts held her to be a 10 masseuse and her mother drove her to the 11 house. 12 Q. When did you first meet Virginia 13 Roberts? 14 A. I don't have a recollection of the 15 first meeting. 16 Q. Do you recall meeting her at 17 Mar-a-Lago? 18 A. Like I said, I don't have a 19 recollection of meeting Ms. Roberts. 20 Q. So you recall Ms. Roberts being 21 brought to the home by her mother, is that 22 your testimony? 23 A. That is my testimony. 24 Q. And that is the first time you met 25 her? Page 17 1 G Maxwell - Confidential 2 A. Like I said, I don't recall meeting 3 her the first time. I do remember her mother 4 bringing her to the house. 5 Q. Are you a member at Mar-a-Lago? 6 A. No. 7 Q. Have you visited Mar-a-Lago? 8 A. Yes. 9 Q. Did you visit Mar-a-Lago in the 10 year 2000? 11 A. I'm pretty sure I did. 12 Q. When Ms. Roberts arrived at the 13 home with her mother, what happened? 14 A. I spoke to her mother outside of 15 the house and she -- what I don't recall is 16 exactly what happened because I was talking 17 to her mother the entire she was in the 18 house. 19 Q. Did you introduce Ms. Roberts to 20 Jeffrey Epstein? 21 A. I don't recall how she actually met 22 Mr. Epstein. As I said, I spoke to her 23 mother the entire time outside the house. 24 Q. Did you walk Ms. Roberts up to the 25 upstairs location at the Palm Beach house to MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 6 of 106 6 (Pages 18 to 21) Page 18 1 G Maxwell - Confidential 2 meet Mr. Epstein? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 Q. You can answer. 6 A. I just explained. 7 A. I spent the entire time talking to 8 Virginia's mother outside the house so the 9 answer to the question is no. 10 Q. No, did you not walk her up and 11 introduce her to Mr. Epstein? 12 A. I just said no. 13 Q. Did you participate in a massage 14 this first time when she first came to the 15 home and you were speaking with her mother, 16 she was in the home, is that correct, you 17 brought her into the home? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 A. I will repeat again, I was standing 21 outside with her mother so very difficult for 22 me to do anything else at that time so no, I 23 did not take her upstairs. 24 Q. Did you participate -- 25 A. Virginia lied 100 percent about Page 19 1 G Maxwell - Confidential 2 absolutely everything that took place in that 3 first meeting. She has lied repeatedly, 4 often and is just an awful fantasist. So 5 very difficult for anything to take place 6 that she repeated because I was with her 7 mother the entire time. 8 Q. So did you have -- did you give a 9 massage with Virginia Roberts and Mr. Epstein 10 during the first time Virginia Roberts was at 11 the West Palm Beach house? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 Q. Yes or no? 15 A. No. 16 Q. Have you ever given a massage with 17 Virginia Roberts in the room and Jeffrey 18 Epstein? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. No. 22 Q. Have you ever given Jeffrey Epstein 23 a massage? 24 MR. PAGLIUCA: Object to the form, 25 foundation. And I'm going to instruct Page 20 1 G Maxwell - Confidential 2 you not to answer that question. I 3 don't have any problem with you asking 4 questions about what the subject matter 5 of this lawsuit is, which would be, as 6 you've termed it, sexual trafficking of 7 Ms. Roberts. 8 To the extent you are asking for 9 information relating to any consensual 10 adult interaction between my client and 11 Mr. Epstein, I'm going to instruct her 12 not to answer because it's not part of 13 this litigation and it is her private 14 confidential information, not subject to 15 this deposition. 16 MS. McCAWLEY: You can instruct her 17 not to answer. That is your right. But 18 I will bring her back for another 19 deposition because it is part of the 20 subject matter of this litigation so she 21 should be answering these questions. 22 This is civil litigation, deposition and 23 she should be responsible for answering 24 these questions. 25 MR. PAGLIUCA: I disagree and you Page 21 1 G Maxwell - Confidential 2 understand the bounds that I put on it. 3 MS. McCAWLEY: No, I don't. I will 4 continue to ask my questions and you can 5 continue to make your objections. 6 Q. Did you ever participate from the 7 time period of 1992 to 2009, did you ever 8 participate in a massage with Jeffrey Epstein 9 and another female? 10 MR. PAGLIUCA: Objection. Do not 11 answer that question. Again, to the 12 extent you are asking for some sort of 13 illegal activity as you've construed in 14 connection with this case I don't have 15 any problem with you asking that 16 question. To the extent these questions 17 involve consensual acts between adults, 18 frankly, they're none of your business 19 and I will instruct the witness not to 20 answer. 21 MS. McCAWLEY: This case involves 22 sexual trafficking, sexual abuse, 23 questions about her having interactions 24 with other females is relevant to this 25 case. She needs to answer these MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 7 of 106 7 (Pages 22 to 25) Page 22 1 G Maxwell - Confidential 2 questions. 3 MR. PAGLIUCA: I'm instructing her 4 not to answer. 5 MS. McCAWLEY: Then we will be back 6 here again. 7 Q. Have you ever given a massage to 8 Mr. Epstein with a female that was under the 9 age of 18? 10 A. Can you repeat the question? 11 Q. Yes. Have you ever given a massage 12 to Mr. Epstein with a female that was under 13 the age of 18? 14 A. No. 15 Q. Have you ever observed Mr. Epstein 16 having a massage given by an individual, a 17 female, who was under the age of 18? 18 A. No. 19 Q. Have you ever observed females 20 under the age of 18 in the presence of 21 Jeffrey Epstein at his home? 22 MR. PAGLIUCA: Object to the form 23 and foundation. 24 A. Again, I have friends that have 25 children -- Page 23 1 G Maxwell - Confidential 2 Q. I'm not talking about friends. I'm 3 talking about individuals -- 4 MR. PAGLIUCA: I'm going to object 5 to you interrupting the witness who was 6 answering your question. The question 7 was, have you ever seen anyone, female 8 under the age of 18 at the house and 9 that's the question she was answering. 10 If you want to strike that question and 11 ask another question, feel free, but let 12 the witness respond, please. 13 MS. McCAWLEY: I will do that. 14 Q. Have you ever observed a female 15 under the age of 18 at Jeffrey Epstein's home 16 that was not a friend, a child -- one of your 17 friend's children? 18 A. Again, I can't testify to that 19 because I have no idea what you are talking 20 about. 21 Q. You have no idea what I'm talking 22 about in the sense you never observed a 23 female under the age of 18 at Jeffrey 24 Epstein's home that was not one of your 25 friend's children, is that correct? Page 24 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. How would I possibly know how 5 someone is when they are at his house. You 6 are asking me to do that. I cannot possibly 7 testify to that. As far as I'm concerned, 8 everyone who came to his house was an adult 9 professional person. 10 Q. Are you familiar with the police 11 report that was issued in respect to the 12 investigation in this matter? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 Q. Are you familiar with the police 16 report that was used in this matter, the 17 investigation of Jeffrey Epstein, has been 18 produced as a document in this matter? 19 A. I have seen a police report. 20 (Maxwell Exhibit 1, police report, 21 marked for identification.) 22 Q. The police report that you have in 23 front of you, can you turn to page 28 of that 24 report, the numbers are on the top right-hand 25 corner. Page 25 1 G Maxwell - Confidential 2 You will see some redactions in 3 this report, Ms. Maxwell, the redacted 4 information is redacted because it reveals 5 the name of a minor, someone who is under the 6 age of 18. 7 On page 28, in the third paragraph, 8 about halfway down, it says, Roberts stated 9 she performed the massage naked. At the 10 conclusion of this massage, Epstein paid 11 RobSON $200 for the massage. He explained, I 12 know you are not comfortable put I will pay 13 you if you bring some girls. He told her the 14 younger the better. Robson stated once tried 15 to bring a 23 year old to Epstein and he 16 stated the female was too old. 17 Have you heard Mr. Epstein use the 18 phrase the younger the better? 19 A. I have no recollection of hearing 20 that. 21 Q. Have you used the phrase in talking 22 to Ms. Roberts and asking her to recruit 23 females for Mr. Epstein, the younger the 24 better? 25 MR. PAGLIUCA: Object to the form MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 8 of 106 8 (Pages 26 to 29) Page 26 1 G Maxwell - Confidential 2 and foundation of the question. 3 A. First of all, can you break the 4 question apart. 5 Q. Have you used the phrase the 6 younger the better in speaking to Ms. Roberts 7 and asking her to recruit females for Jeffrey 8 Epstein? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 Q. You can answer. It's yes or no. 12 A. No, that's absolutely not true, on 13 the second part of your question, I have not 14 asked Virginia to recruit females and the 15 first part of your question, if you can 16 repeat that again, the question you asked. 17 Q. Will you read back the question. 18 (Record read.) 19 A. I believe I answered the later part 20 of the question. The first part of the 21 question, it's impossible for me to recall 22 events that took place 16 years ago but it 23 doesn't sound like something I would say. 24 Q. On page 28, that same paragraph, 25 Roberts was asked how many girls in total she Page 27 1 G Maxwell - Confidential 2 brought to Epstein. Robson stated that she 3 can remember, Robson stated that she brought 4 and, it's redacted there, and the victim in 5 this case. 6 Let me ask my question, I have a 7 question pending right now. 8 Are you testifying that you are 9 unaware of any underage, under the age of 18, 10 females coming to Jeffrey Epstein's home to 11 perform massages? 12 MR. PAGLIUCA: Object to the form 13 foundation. 14 A. You need to straddle that question 15 in a different time period. When I was 16 there, at the time I was present, the people 17 that gave Jeffrey, men and women who gave 18 Jeffrey massages were adults over the age of 19 18. 20 Q. Never in your time at any of 21 Jeffrey Epstein's homes were you present when 22 a female under the age of 18 was there to 23 give Jeffrey Epstein a massage? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Page 28 1 G Maxwell - Confidential 2 A. First of all, as I said when I was 3 present -- 4 Q. It is a yes or no. 5 A. No, it is not. 6 Q. You can answer the question in full 7 but please provide yes or no as an initial 8 matter. 9 A. I cannot answer yes or no, it's not 10 bounded by time. It's entirely possible I 11 could have been in a room or even in the 12 vicinity of Palm beach when somebody came and 13 I would not know. How would I know when 14 somebody was in the house. There is no way I 15 can know. 16 Q. Did you stay at Jeffrey Epstein's 17 home when you were in Palm Beach? 18 A. Most of the time. 19 Q. So how is it that you wouldn't know 20 if there was a female in the home under the 21 age of 18 if you were staying there? 22 A. Well, first of all, when I was 23 staying there, the house is actually quite 24 large and I have a very busy job and I had an 25 office with a door so the door would be shut Page 29 1 G Maxwell - Confidential 2 and I would be working. I'm not responsible 3 for what Jeffrey does and I don't always pay 4 attention to what happens in the house. I'm 5 very busy. 6 Q. So you're testifying that you never 7 observed a female under the age of 18 at 8 Jeffrey Epstein's West Palm Beach home? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 A. I already answered that question, I 12 believe. 13 Q. You didn't answer my question. 14 A. I did. 15 Q. Did you observe a female under the 16 age of 18 at Jeffrey Epstein's home in Palm 17 Beach? 18 A. Like I said, I work, I don't sit 19 there and watch people coming in and out of 20 the house. I cannot possibly tell you if I'm 21 in the home that somebody was there that I 22 did not see, I cannot comment on it, I have 23 no idea. 24 Q. Did you observe females at Jeffrey 25 Epstein's home that were laying out topless MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 9 of 106 9 (Pages 30 to 33) Page 30 1 G Maxwell - Confidential 2 in the back of the home, in other words 3 without a shirt on? 4 A. So that's just another of 5 Virginia's lies. So let's be clear, at the 6 time when I was there and present, frequently 7 at the house, it was unusual to see people 8 without their clothes on. 9 Q. When you say unusual, did you 10 observe people without their clothes at 11 Jeffrey Espstein's home? 12 A. Can I answer. Sometimes people in 13 the privacy of a house and swimming pool, I 14 have seen people from time to time take their 15 top off. I have seen people from time to 16 time do that. Very unusual. Naked people 17 around the people at any frequent period of 18 time, I have never seen. 19 Q. Were they under the age of 18? 20 A. As I was saying, people when I was 21 in the house, were of adult age, if they were 22 children, friends of my family or friends 23 that were there, they may well have been 24 because I have nieces and nephews under the 25 age of 18, I cannot testify to anybody else Page 31 1 G Maxwell - Confidential 2 -- just another one of Virginia's many 3 fictitious lies and stories to make this a 4 salacious event to get interest and press. 5 It's absolute rubbish. 6 Q. Were you in charge of hiring 7 individuals to provide massages for Jeffrey 8 Epstein? 9 A. My job included hiring many people. 10 There were six homes. As I sit here, I hired 11 assistants, I hired architects, I hired 12 decorators, I hired cooks, I hired cleaners, 13 I hired gardeners, I hired pool people, I 14 hired pilots, I hired all sorts of people. 15 In the course and a very small part 16 of my job was from from time to time to find 17 adult professional massage therapists for 18 Jeffrey. 19 Q. When you say adult professional 20 massage therapists, where did you find these 21 massage therapists? 22 A. From time to time I would visit 23 professional spas, I would receive a massage 24 and if the massage was good I would ask that 25 man or woman if they did home visits. Page 32 1 G Maxwell - Confidential 2 Q. Did you ever hire a masseuse that 3 was under the age of 18? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 Q. Did you? 7 A. Again, I don't hire massage 8 therapists, so that was not my job. 9 Q. You just said you did, you just 10 said you hired massage therapists for Jeffrey 11 Epstein, I'm asking if you hired a massage 12 therapist who was under the age of 18? 13 A. Let me correct myself. When I 14 meant hire, I didn't mean hire in the way you 15 are doing it. What I say is that I went to 16 spas and I met people and if they did home 17 visits, Jeffrey would then, in fact, hire 18 them. I'm not responsible for hiring 19 someone. And they were not full-time, so 20 it's not a correct characterization. 21 Q. Did you ever, your term is meet, 22 did you ever meet a person that was under the 23 age of 18 that you -- that Jeffrey then hired 24 as a masseuse? 25 MR. PAGLIUCA: Object to the form Page 33 1 G Maxwell - Confidential 2 and foundation. 3 A. First of all, Virginia Roberts who 4 you are referring to was a masseuse aged 17, 5 we all now know, so your story that you keep 6 pushing out to the press that she was a 15 7 year old -- you and I both know was a lie, 8 correct. 9 Q. You are not sentencing my question. 10 A. You and I both know that was a lie, 11 correct. 12 Q. You are not answering my question. 13 I'm asking you whether you ever met a female 14 under the age of 18 that Jeffrey then hired 15 as a masseuse? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. The only person I can talk about 19 who clearly was a massage age 17, a masseuse, 20 was Virginia. 21 Q. Did you meet her and then introduce 22 her to Jeffrey? 23 A. I don't know. I already testified 24 I don't recall meeting her. 25 (Maxwell Exhibit 2, email, marked MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 10 of 106 10 (Pages 34 to 37) Page 34 1 G Maxwell - Confidential 2 for identification.) 3 Q. So I'm showing you a document that 4 we have marked as Maxwell Exhibit 2. It's a 5 document you produced in this matter labeled 6 confidential GM 00109. It's dated Sunday 7 June 12, 2011. It's from Jeffrey Epstein to 8 you. If you can turn to page 4 -- sorry, can 9 you turn to the first page, the cover page 10 initially which is 00109. If you look under 11 the time stamp it says, June 12, 2011 at 4:12 12 p.m., it says 13 Is that your email address? 14 A. It is. 15 Q. Under that it says, Thank you. I 16 have it now and I'm working on a letter, a 17 little, I will send the final version 18 tomorrow and what ever it is will be 19 factually accurate. 20 Do you see that on page 1? 21 A. I do. 22 Q. Then I would like you to turn to 23 page 4 please. The second paragraph down on 24 page 4, it states, After some thought, I 25 recall that I first met Ms. Roberts when she Page 35 1 G Maxwell - Confidential 2 was working at a premier resort claiming to 3 be 18 years old and a professional masseuse? 4 MR. PAGLIUCA: What line are you 5 on, counsel. 6 MS. McCAWLEY: Second paragraph 7 down. 8 MR. PAGLIUCA: I got it. 9 Q. Is that a statement that you wrote? 10 A. It appears to be. 11 Q. So does that correct your testimony 12 that you did meet Ms. Roberts at Mar-a-Lago? 13 A. Again, this was written in, when 14 were you saying? 15 Q. 2011. 16 A. So by 2011, Ms. Roberts had already 17 perpetrated so many lies and stories it's 18 hard for me to accurately tell you today what 19 I remember back then. As I sit here today, 20 the testimony I give you today, I do not 21 recollect it. 22 Q. Do you have a reason to say that 23 this document that you wrote is incorrect? 24 A. It's in 2011, I can't possibly tell 25 you what I remember in 2011. Page 36 1 G Maxwell - Confidential 2 Q. Are you questioning that this 3 document is incorrect, this document -- this 4 email that you wrote? 5 A. I wrote an email. I was trying to 6 be accurate, so who knows, with all the 7 rubbish that you guys have put out in the 8 press that I read, maybe in the moment I 9 wrote it a memory came to me that I don't 10 know, but as I sit here today and the 11 testimony I gave you today is I don't 12 recollect it. 13 Q. Does this refresh your recollection 14 that you recalled meeting Ms. Roberts at 15 Mar-a-Lago? 16 A. It does not. 17 Q. So your testimony today is that you 18 don't remember meeting Ms. Roberts at 19 Mar-a-Lago? 20 A. I do not. 21 I just want to clarify, when you 22 read so much stuff and so much rubbish that 23 comes out from Virginia Roberts, you don't 24 know what's up and down, at the time I wrote 25 this I believe I had a memory but as I sit Page 37 1 G Maxwell - Confidential 2 here today I do not. 3 Q. Ms. Maxwell, when did you first 4 meet 5 MR. PAGLIUCA: Object to the form 6 and foundation. 7 A. I have no idea when I met her. 8 Q. Do you know how old she was when 9 you met her? 10 A. I have no idea how old she was when 11 I met her. 12 Q. Is it possible she was 13 years old 13 when you first met her? 14 MR. PAGLIUCA: Object to the form 15 and foundation. 16 A. was Jeffrey's friend 17 and 21 Q. I understand 22 23 I'm asking if was 13 24 years old when you first met her? 25 A. I have no idea. I - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 11 of 106 11 (Pages 38 to 41) Page 38 1 G Maxwell - Confidential 2 Q. Was she under 18 when you first met 3 her? 4 A. I have no idea how old she was when 5 I first met her. 6 Q. Did she look like a child when you 7 first met her? 8 A. I don't remember what she looked 9 like at the time she was in the house. 10 Q. How many years have you known her? 11 A. I can only recall the last time I 12 saw her. 13 Q. When was the first time you met 14 her? 15 A. Again, I just told you, I don't 16 recall the first time I met her. 17 Q. Did travel with you 18 on Jeffrey's planes? 19 A. I wouldn't remember if was on 20 the plane or not. 21 Q. Did you ever have sex with 22 23 A. No. 24 Q. Did you ever observe Jeffrey having 25 sex with Page 39 1 G Maxwell - Confidential 2 A. No. 3 Q. Were you aware that Jeffrey was 4 having sexual contact with when 5 she was 13 years old? 6 MR. PAGLIUCA: Object to the form 7 and foundation. 8 A. I would be very shocked and 9 surprised if that were true. 10 Q. Were you in the house when 11 was in the house in a private area 12 with Jeffrey Epstein? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 A. Can you repeat the question. 16 Q. Were you ever in the Palm Beach 17 house when Jeffrey Epstein was in the house 18 with 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. I've already testified that I have 22 met her and that she was there 23 I don't understand what your 24 question is asking. 25 Q. So you have never seen Page 40 1 G Maxwell - Confidential 2 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 Q. Is that your testimony? 6 A. I already said I don't recall all 7 the times I've seen her and I have no memory 8 of that. 9 Q. Have you ever seen in 10 the house with Jeffrey Epstein 11 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. I just told you I don't recall 15 seeing 16 Q. Were you ever involved in an orgy 17 with 18 A. No, absolutely not. 19 Q. Can you tell me, do you know an 20 individual by the name of Nadia Marcinkova? 21 A. I do. 22 Q. How did you meet Nadia Marcinkova? 23 A. At some point she was a friend of 24 Jeffrey's and I recall meeting her at some 25 point. Page 41 1 G Maxwell - Confidential 2 Q. Did you hire her? 3 A. First of all, I don't hire girls 4 like that, so let's be clear, I already 5 testified to that, and I have no idea what 6 you are referring to. 7 Q. When you say girls like that, what 8 do you mean? 9 A. I hire people who are professional 10 at the house. You are asking if I hired 11 somebody to do what, I don't know what you 12 are talking about. I hired people to work in 13 the homes. 14 Q. What was Nadia Marcinkova doing? 15 MR. PAGLIUCA: Object to the form 16 and foundation. 17 A. I have no idea what Nadia 18 Marcinkova was doing. I didn't hire her and 19 I don't know what you are referring to. 20 Q. You met Nadia Marcinkova? 21 A. I testified I did. 22 Q. Did she work for Jeffrey Epstein? 23 A. I have no idea what she did. 24 Q. Have you flown on planes with Nadia 25 Marcinkova? - - - - - Ill - - - -----+---------! - Ill - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 12 of 106 12 (Pages 42 to 45) Page 42 1 G Maxwell - Confidential 2 A. I don't recollect. I don't know if 3 I did. 4 Q. How many times have you flown on 5 Jeffrey Epstein's planes? 6 A. Too many times. 7 Q. More than 300? 8 A. I really couldn't tell you how 9 many. 10 Q. More than 400? 11 A. Again, I said I cannot tell you how 12 many, a lot. 13 Q. How many times with Nadia 14 Marcinkova? 15 A. I already testified, I have no 16 idea. 17 Q. How old was Nadia Marcinkova when 18 she first became involved with Jeffrey? 19 A. I have no idea. 20 Q. Was she 14? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 A. I have no idea. 24 Q. Did she look like a child the first 25 time you met her? Page 43 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. Asked and answered. 4 Q. Did she look like a child the first 5 time you met Nadia Marcinkova? 6 A. I don't know what you mean if she 7 looked like a child. 8 Q. Did she look like she was under the 9 age of 18? 10 A. No. 11 Q. Did she look like she was under the 12 age of 16? 13 A. I just testified -- first of all, I 14 couldn't tell you how old she was, she didn't 15 like like a child, leave it at that. 16 Q. Did you know that she was a child? 17 MR. PAGLIUCA: Object to the form 18 and foundation. 19 A. I just answered I did not know how 20 old she was and she looked like an adult. 21 Q. In the times that you traveled with 22 her on Jeffrey Epstein's planes, did you ever 23 ask her how old she was? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Assumes facts not in Page 44 1 G Maxwell - Confidential 2 evidence. The witness already testified 3 she doesn't remember. 4 Q. You can answer that question. 5 Did you ever ask her on the many 6 flights you were with her or the many times 7 you were with her at the house? 8 A. First of all, I don't know I was on 9 many flights with her, you are making stories 10 up again as usual. And secondly, if I was on 11 a flight with her, there would not be any 12 reason why I would ask her how old she was. 13 Q. You don't recollect having any 14 conversation with her about her age? 15 A. I already testified to that. 16 Q. Do you know what Nadia Marcinkova 17 was hired to do for Jeffrey? 18 A. I already testified I didn't know 19 she was hired and I don't know that she did 20 anything. I don't know how to answer that 21 question. 22 Q. Was Nadia Marcinkova at the house, 23 the Palm Beach house, when you were present 24 at that house? 25 MR. PAGLIUCA: Object to the Page 45 1 G Maxwell - Confidential 2 foundation. 3 A. I have no recollection of her being 4 at the house at the same time as me. 5 Q. When did you first meet Nadia 6 Marcinkova? 7 A. I already told you I don't recall. 8 Q. Do you recall anything about Nadia 9 Marcinkova? 10 A. That she was tall and blond. 11 Q. Do you recall Nadia Marcinkova 12 interacting with other females at the house? 13 A. No, I do not. 14 Q. Did you arrange to get a visa for 15 Nadia Marcinkova to come into this country? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. Absolutely not. 19 Q. Did Jeffrey arrange for a visa for 20 Nadia Marcinkova? 21 MR. PAGLIUCA: You need to give me 22 a break so I can interpose an objection. 23 Object to the form and foundation. 24 Q. You can answer. 25 A. What was the question? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 13 of 106 13 (Pages 46 to 49) Page 46 1 G Maxwell - Confidential 2 Q. Did Jeffrey arrange for a visa for 3 Nadia Marcinkova? 4 A. I don't know what Jeffrey did. I 5 cannot testify what Jeffrey did. 6 Q. Was Nadia involved in sex with 7 Jeffrey and other girls? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 Q. Girls under the age of 18? 11 MR. PAGLIUCA: Same objection. 12 A. I have no idea. 13 Q. Was Nadia involved with sex with 14 Jeffrey and girls over the age of 18? 15 MR. PAGLIUCA: Same objection. 16 A. I have no idea. 17 Q. Did Nadia recruit other girls for 18 sex with Jeffrey? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. I have no idea. 22 Q. Do you still talk to Nadia? 23 A. No. 24 Q. Is she a pilot? 25 A. I have no idea. Page 47 1 G Maxwell - Confidential 2 Q. Does she fly with Larry Veseski 3 (phonetic), one of Jeffrey's pilots? 4 A. I have no idea. 5 Q. Are you a pilot? 6 A. I am. 7 Q. Have you flown with Jeffrey Veseki? 8 A. I have. 9 Q. Have you flown with Nadia 10 Marcinkova? 11 A. What do you mean by flown? 12 Q. Have you been on planes with her? 13 A. I already testified I don't recall 14 having her on a plane with me. 15 Q. Do you know Sarah Kellen? 16 A. I do. 17 Q. When did you first meet her? 18 A. I don't recall exact dates. 19 Q. Did you meet her with the purpose 20 of hiring her to work for Jeffrey or having 21 Jeffrey hire her? 22 MR. PAGLIUCA: Object to the form 23 and foundation. 24 A. No. 25 Q. What was her relationship with Page 48 1 G Maxwell - Confidential 2 Jeffrey? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 A. I don't know exactly the nature of 6 her relationship but she worked for him. 7 Q. What did she do? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 A. At the time she when was with him I 11 believe she traveled with him and helped with 12 his travel arrangements. 13 Q. Did she bring girls to the house to 14 give massages to Jeffrey? 15 MR. PAGLIUCA: Object to the form 16 and foundation. 17 A. I don't know what Sarah did. 18 Q. So you never observed Sarah 19 bringing girls to the home to give massages 20 to Jeffrey? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 A. I don't understand the question, 24 what did you mean bring? 25 Q. Did you ever observe Sarah Page 49 1 G Maxwell - Confidential 2 inviting, bringing, walking anyone into the 3 home to give a massage for Jeffrey? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 A. I don't recollect anything like 7 that. 8 Q. Are you aware that Sarah Kellen was 9 a co-conspirator, named as a co-conspirator 10 in the case involving Jeffrey Epstein? 11 MR. PAGLIUCA: Object to the form 12 and foundation and also calls for a 13 legal conclusion. 14 MS. McCAWLEY I'm just asking if she 15 is aware of that. 16 A. I am aware. 17 Q. Who paid Sarah Kellen? 18 A. I have no idea. 19 Q. Did you ever arrange payment for 20 any of the employees at the home? 21 MR. PAGLIUCA: Object to the form. 22 A. What do you mean by arrange? 23 Q. Were you ever in charge or 24 responsible for paying individuals at the 25 home, that worked there? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 14 of 106 14 (Pages 50 to 53) Page 50 1 G Maxwell - Confidential 2 A. People had salaries and they were 3 paid by the office. 4 Q. Did you ever pay any individual, 5 did you ever hand an individual cash for work 6 they performed? 7 MR. PAGLIUCA: Object to the form. 8 A. Can you be more specific about what 9 you are asking me. 10 Q. Did you ever hand any individual 11 who was working at the home cash as payment 12 for something that they performed at the 13 home? 14 MR. PAGLIUCA: Object to the form. 15 A. To the best of my recollection 16 there were very few times where I would leave 17 some cash for people for work performed. 18 Q. And what type of work was being 19 performed where you would be doing that? 20 A. If I left cash for the pool guy, I 21 would have left potentially some cash for the 22 gardener, potentially for exercise 23 instructors and sometimes for massage 24 therapy. 25 Q. How much were the massage Page 51 1 G Maxwell - Confidential 2 therapists paid? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 A. They get paid between 100 and $200. 6 Q. Did it vary based on what sexual 7 acts they performed? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 A. No. It varied depending how much 11 time, some massage therapists charge more and 12 some charge less. 13 Q. Did the massage therapists that 14 were hired to come to the home perform sexual 15 acts for Jeffrey Epstein? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. What are you asking me? 19 Q. I'm asking if the massage 20 therapists -- 21 A. Are you asking me about underage 22 girls? 23 Q. I'm asking in general, did any of 24 the massage therapists in the home -- 25 A. Are you asking if they were paid Page 52 1 G Maxwell - Confidential 2 for sexual acts. 3 Q. I'm asking if they performed sexual 4 acts? 5 MR. PAGLIUCA: Object to the form 6 and foundation. 7 Q. Did any of the massage therapists 8 who were at the home perform sexual acts for 9 Jeffrey Epstein? 10 A. I don't know what you mean by 11 sexual acts. 12 Q. Did any of the massage therapists 13 who were working at the home perform sexual 14 acts, including touching the breasts, 15 touching the vaginal area, being touched 16 while Jeffrey is masturbating, having 17 intercourse, any of those things? 18 MR. PAGLIUCA: Objection. Form and 19 foundation. 20 To the extent any of this is asking 21 for to your knowledge any consensual sex 22 act that may or may not have involved 23 you, I'm instructing you not to answer 24 the question. 25 Q. I'm not asking about consensual sex Page 53 1 G Maxwell - Confidential 2 acts. I'm asking whether any of the massage 3 therapists performed sexual acts for Mr. 4 Epstein, as I have just described? 5 A. I have never seen anybody have 6 sexual intercourse with with Jeffrey, ever. 7 Q. I'm not asking about sexual 8 intercourse. I'm asking about any sexual 9 act, touching of the breast -- did you ever 10 see -- can you read back the question? 11 (Record read.) 12 A. I'm not addressing any questions 13 about consensual adult sex. If you want to 14 talk about what the subject matter, which is 15 defamation and lying, Virginia Roberts, that 16 you and Virginia Roberts are participating in 17 perpetrating her lies, I'm happy to address 18 those. I never saw any inappropriate 19 underage activities with Jeffrey ever. 20 Q. I'm not asking about underage. I'm 21 asking about whether any of the masseuses 22 that were at the home perform sexual acts for 23 Jeffrey Epstein? 24 A. I have just answered the question. 25 Q. No, you haven't. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 15 of 106 15 (Pages 54 to 57) Page 54 1 G Maxwell - Confidential 2 A. I have. 3 Q. No, you haven't. 4 A. Yes, I have. 5 Q. You are refusing to answer the 6 question. 7 A. Let's move on. 8 Q. I'm in charge of the deposition. I 9 say when we move on and when we don't. 10 You are here to respond to my 11 questions. If you are refusing to answer the 12 court will bring you back for another 13 deposition to answer these questions. 14 Do you understand that? 15 MR. PAGLIUCA: You don't need to 16 threaten the witness. 17 MS. McCAWLEY: I'm not threatening 18 her. I'm making sure the record is 19 clear. 20 MR. PAGLIUCA: Certainly can you 21 apply to have someone come back and the 22 court may or may not have her come back 23 again. 24 Again, she is not answering 25 questions that relate to adult consent Page 55 1 G Maxwell - Confidential 2 sex acts. Period. And that's the 3 instruction and we can take it up with 4 the court. 5 Q. Ms. Maxwell, are you aware of any 6 sexual acts with masseuses and Jeffrey 7 Epstein that were nonconsensual? 8 A. No. 9 Q. How do you know that? 10 A. All the time that I have been in 11 the house I have never seen, heard, nor 12 witnessed, nor have reported to me that any 13 activities took place, that people were in 14 distress, either reported to me by the staff 15 or anyone else. I base my answer based on 16 that. 17 Q. Are you familiar with a person by 18 the name of Annie Farmer? 19 A. I am. 20 Q. Has Annie Farmer given a statement 21 to police about you performing sexual acts on 22 her? 23 A. I have not heard that. 24 Q. Has Annie Farmer given a statement 25 to police about Jeffrey Epstein performing Page 56 1 G Maxwell - Confidential 2 sexual acts on her? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 A. I have not heard that. 6 Q. How do you know Annie Farmer? 7 A. Annie Farmer had a sister and her 8 sister introduced Annie Farmer, I believe, to 9 Jeffrey. 10 Q. Was Annie Farmer under the age of 11 18? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. I don't recall how old Annie Farmer 15 was. 16 Q. Did she tell police that Jeffrey 17 Epstein assaulted her sexually? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 A. I never heard that. 21 Q. Did Sarah Kellen recruit or bring 22 girls to the home that were under the age of 23 18? 24 MR. PAGLIUCA: Object to the form 25 and foundation and I think this has been Page 57 1 G Maxwell - Confidential 2 asked and answered already. 3 Q. You can answer the question. 4 A. I have no idea what Sarah Kellen 5 did. 6 Q. You never observed Sarah Kellen 7 with girls under the age of 18 at Jeffrey's 8 home? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 A. The answer is no, I have no idea. 12 Q. Do you know Glenn Dubin? 13 A. I do. 14 Q. What is your relationship with 15 Glenn Dubin? 16 MR. PAGLIUCA: Object to the form. 17 A. What do you mean what is my 18 relationship. 19 Q. Are you friendly with him, how do 20 you know him? 21 A. He is the husband of Eva Dubin. 22 Q. Is Eva Dubin one of your friends? 23 A. Yes. 24 Q. Did you ever send Virginia to 25 Glenn's condo at the Breakers to give him a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 16 of 106 16 (Pages 58 to 61) Page 58 1 G Maxwell - Confidential 2 massage? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. No. 6 Q. Did you ever instruct Virginia 7 Roberts to have sex with Glenn? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I have never instructed Virginia to 11 have sex with anybody ever. 12 Q. How old was Eva Anderson when she 13 met Jeffrey? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. I have no idea. 17 Q. What's she under the age of 18? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I just testified I have idea how 21 old she was. 22 Q. You testified she was your friend. 23 You don't know how old she was when she met 24 Jeffrey? 25 A. That happened sometime in the '70s, Page 59 1 G Maxwell - Confidential 2 how would I know, or '80s. I have no idea. 3 Can you testify to what your friends did 30 4 years ago? 5 Q. You don't ask the questions here, 6 Ms. Maxwell. 7 What about Johanna Sjoberg, when 8 did you first meet Johanna? 9 A. I don't recall the exact date. 10 Q. Did you hire Johanna? 11 A. I don't hire people, she came to 12 work at the house to answer phones. 13 Q. Where did you meet her? 14 A. I just testified, I don't recall 15 exactly when I met her. 16 Q. Was one of your job 17 responsibilities to interview people that 18 would be then hired by Jeffrey? 19 A. That was one of my 20 responsibilities. 21 Q. Do you recall interviewing Johanna? 22 A. I don't recall the exact interview, 23 no. 24 Q. Do you know what tasks Johanna was 25 hired to performance? Page 60 1 G Maxwell - Confidential 2 A. She was tasked to answer 3 telephones. 4 Q. Did you ever ask her to rub 5 Jeffrey's feet? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I believe that I have read that, 9 but I don't have any memory of it. 10 Q. Did you ever tell Johanna that she 11 would get extra money if she provided Jeffrey 12 massages? 13 A. I was always happy to give career 14 advice to people and I think that becoming 15 somebody in the healthcare profession, either 16 exercise instructor or nutritionist or 17 professional massage therapist is an 18 excellent job opportunity. Hourly wages are 19 around 7, 8, $9 and as a professional 20 healthcare provider you can earn somewhere 21 between as we have established 100 to $200 22 and to be able to travel and have a job that 23 pays that is a wonderful job opportunity. So 24 in the context of advising people for 25 opportunities for work, it is possible that I Page 61 1 G Maxwell - Confidential 2 would have said that she should explore that 3 as an option. 4 Q. Did you tell her she would get 5 extra money if she massaged Jeffrey? 6 A. I'm just saying, I cannot recall 7 the exact conversation. I give career advice 8 and I have done that. 9 Q. Did you ever have Johanna massage 10 you? 11 A. I did. 12 Q. How many times? 13 A. I don't recall how many times. 14 Q. Was there sex involved? 15 A. No. 16 Q. Did you ever instruct Johanna to 17 massage Glenn Dubin? 18 A. I don't believe -- I have no 19 recollection of it. 20 Q. Did you ever have sexual contact 21 with Johanna? 22 MR. PAGLIUCA: Object to the form 23 and foundation. You need to give me an 24 opportunity to get in between the 25 questions. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 17 of 106 17 (Pages 62 to 65) Page 62 1 G Maxwell - Confidential 2 Anything that involves consensual 3 sex on your part, I'm instructing you 4 not to answer. 5 Q. Did you ever have sexual contact 6 with Johanna? 7 A. Again, she is an adult -- 8 Q. I'm asking you, did you ever have 9 sexual contact with Johanna? 10 A. I've just been instructed not to 11 answer. 12 Q. On what basis? 13 A. You have to ask my lawyer. 14 Q. Did you ever have sexual contact 15 with Johanna that was not consensual on 16 Johanna's part? 17 MR. PAGLIUCA: You can answer 18 nonconsensual. 19 A. I've never had nonconsensual sex 20 with anybody. 21 Q. Not Annie Farmer? 22 MR. PAGLIUCA: Objection. 23 A. I just testified I never had 24 nonconsensual sex with anybody ever, at any 25 time, at anyplace, at any time, with anybody. Page 63 1 G Maxwell - Confidential 2 Q. So if Johanna were to testify that 3 she did not consent to a sexual act that you 4 participated in -- 5 A. I just told you I have never ever 6 under any circumstances with anybody, at any 7 time, in anyplace, in any form had 8 nonconsensual relations with anybody. 9 Q. Did you introduce Johanna to Prince 10 Andrew? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I've, again, read that Johanna 14 claimed that she met or that she said she met 15 Prince Andrew. I don't know if I was the one 16 who made the introduction or not. 17 Q. Do you know a female by the name of 18 Emmy Taylor? 19 A. I do. 20 Q. How do you know her? 21 A. Emmy was my assistant. 22 Q. So she worked for you? 23 A. Yes. 24 Q. Did you hire her? 25 A. Again, Jeffrey hired people. Page 64 1 G Maxwell - Confidential 2 Q. Did you have sex with her? 3 MR. PAGLIUCA: This is the same 4 instruction about consensual or 5 nonconsensual. 6 Q. Was Emmy under the age of 18 when 7 you hired her? 8 A. No. I didn't hire her, as I said, 9 Jeffrey did. 10 Q. Did Emmy ever have sex with 11 Jeffrey? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. How would I know what somebody else 15 did. 16 Q. You weren't involved in the sex 17 between Jeffrey, Emmy and yourself? 18 A. We already -- 19 Q. Were you involved with sex between 20 Jeffrey, Emmy and yourself? 21 MR. PAGLIUCA: Everyone is talking 22 over each other. You heard the 23 question. 24 Again, you you know what the 25 instruction is. If there is any Page 65 1 G Maxwell - Confidential 2 consensual issue involved, I instruct 3 you not to answer. 4 A. Moving on. 5 Q. So you are refusing to answer that 6 question? 7 A. I've been instructed by my lawyer. 8 Q. Did you ever have sex with Jeffrey, 9 Emmy, Virginia and yourself when Virginia was 10 underage? 11 A. Absolutely not. 12 MR. PAGLIUCA: We've been going for 13 about an hour. I would like to take a 14 five-minute break, please. 15 MS. McCAWLEY: I'm almost done. 16 MR. PAGLIUCA: You are not going to 17 allow a break. 18 MS. McCAWLEY: As soon as I get 19 through my line of questioning, which is 20 perfectly appropriate. 21 Q. Did Emmy Taylor travel with you and 22 Jeffrey to Europe? 23 A. I'm sure she did. 24 Q. What is she doing today? 25 A. I have no idea. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 18 of 106 18 (Pages 66 to 69) Page 66 1 G Maxwell - Confidential 2 Q. Do you speak to her regularly now, 3 do you speak to her? 4 A. No. 5 Q. Do you know where she lives? 6 A. No. 7 Q. Do you know what country she lives 8 in? 9 A. No. 10 Q. Where is the last place you knew 11 that she lived? 12 A. Last place I knew for sure was in 13 Los Angeles. 14 Q. When did she stop working for you? 15 A. 2001, 2002. 16 Q. What tasks did she performance for 17 you? 18 A. She helped me with moving in and 19 out of houses, construction, she was a 20 general help, she helped with buying things 21 that needed to be purchased, if I needed her 22 to stand in for me during meetings, it was a 23 very wide ranging job. 24 Q. Did she ever bring females to 25 perform massages for Jeffrey? Page 67 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. What are you asking me? 5 Q. Did Emmy, was it ever Emmy's 6 responsibility to bring females to the house 7 for the purposes of massaging Jeffrey? 8 A. Emmy's job was to help me with the 9 houses and work in homes. It was not her job 10 to whatever you just said, bring masseuses. 11 Q. Did she do that? 12 A. I have no recollection. I have no 13 idea. 14 Q. Did you pay Emmy or did Jeffrey pay 15 her? 16 A. Jeffrey. 17 Q. Do you recall how much she was 18 paid? 19 A. I do not. 20 MS. McCAWLEY: I think we can take 21 a break now. 22 THE VIDEOGRAPHER: It's 10:02 and 23 we are off the record. 24 (Recess.) 25 THE VIDEOGRAPHER: It's now 10:18. Page 68 1 G Maxwell - Confidential 2 We are back on the record and starting 3 disk No. 2. 4 Q. Ms. Maxwell, I asked you about 5 Virginia Roberts earlier. 6 Can you describe what Virginia 7 Roberts' duties were when she was with Mr. 8 Epstein? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I believe that Virginia was a 12 masseuse. 13 Q. Was Virginia required to dress up 14 in any way for massages? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I have no idea. 18 Q. Did you provide Virginia with 19 outfits to wear for certain massages? 20 A. I have no idea what you are talking 21 about. 22 Q. For example, did you ever provide 23 Virginia with a school girl outfit to wear 24 for a massage? 25 A. I have no idea what you are talking Page 69 1 G Maxwell - Confidential 2 about. 3 Q. So you didn't provide her with 4 that? 5 A. As I just testified, I have no idea 6 what you are talking about. 7 Q. I was trying to interpret whether 8 you didn't understand what a school girl 9 outfit was or you are saying that didn't 10 happen? 11 A. I clearly know what a school girl 12 outfit is. I have no recollection of 13 providing anybody with a school girl outfit. 14 Q. Did you have a set of outfits used 15 by the massage therapists that would include 16 things like a school girl outfit or a black 17 patent leather outfit or anything of that 18 nature? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. That would be just another one of 22 Virginia's lies. 23 Q. You didn't have anything like that? 24 A. I did not. 25 Q. Did you have a basket of sex toys MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 19 of 106 19 (Pages 70 to 73) Page 70 1 G Maxwell - Confidential 2 that you kept in the Palm Beach house? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. First of all what do you mean. 6 Q. A laundry basket that contained sex 7 toys in it? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. Can you ask the question again? 11 Q. Did you have a laundry basket that 12 contained sex toys in it, in the Palm Beach 13 House? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 Q. Did you have a laundry basket of 17 sex toys in the Palm Beach house? 18 MR. PAGLIUCA: Same objection. 19 Q. You can answer. 20 A. I don't recollect anything about a 21 laundry basket of sex toys. 22 Q. Do you recollect having sex toys at 23 the Palm Beach house? 24 A. You have to define what are you 25 talking about. Page 71 1 G Maxwell - Confidential 2 Q. A sex toy meaning a vibrator of 3 some kind, sometimes they are called dildos, 4 of that nature, anything like that? 5 A. I don't recollect anything that 6 would formally be a dildo, anything like 7 that. 8 Q. How would you describe sex toys? 9 A. I wouldn't describe sex toys. 10 Q. Did you have anything that was of 11 an electronic nature that would be used 12 during sex? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I have no idea what you are 16 referring to. 17 (Maxwell Exhibit 3, transcript, 18 marked for identification.) 19 Q. Ms. Maxwell, I will show you what 20 we are marking as Maxwell Exhibit 3. 21 If you look at the cover you will 22 see it's a deposition transcript of Juan 23 Alessi, do you know who Juan Alessi is? 24 A. I do. 25 Q. Who is he? Page 72 1 G Maxwell - Confidential 2 A. He was somebody who Jeffrey hired 3 who worked at the house in Palm Beach. 4 Q. I would like to have you turn to 5 page, it should be page 76 of the actual 6 transcript? 7 MR. PAGLIUCA: We have two 8 transcripts. 9 Q. The mini version I think it is 10 there. 11 A. I don't have page 76. 12 Q. So in the miniscript portion here, 13 the beginning, there should be a page that 14 looks like this, it's got a 76 at the top in 15 the small square. Are you finding that, it's 16 not too far back, I don't believe, it says 17 page 19 the the bottom. 18 A. Okay. 19 Q. It's a miniscript like this. It 20 has four squares? 21 MS. MENNINGER: 109 or 19. 22 MS. McCAWLEY: 19. 23 MR. PAGLIUCA: The Bates label is 24 000109. 25 MS. McCAWLEY: Exactly. Page 73 1 G Maxwell - Confidential 2 Q. I will direct your attention to 3 page 76 in the deposition of Juan Alessi and 4 it says, Would you describe for me what kinds 5 of vibrators you found, question mark. The 6 answer is, I'm not familiar, not too familiar 7 with the names. They were big dildos, what 8 they call big rubber things like that, 9 indicating. 10 A. I can't find where you are looking. 11 Q. Page 76, right here. 12 A. I need to be able to read this. I 13 will not be answering anything I have not 14 read. You can read it out and then I will 15 read it. 16 Q. Where was I. And I used to go and 17 put on my gloves and pick them up and put 18 them in the sink, rinse it off and put it in 19 Ms. Maxwell's -- Ms. Maxwell had in her 20 closet -- she had like a laundry basket, one 21 of those laundry baskets that you put laundry 22 in, she had full of these toys and that was 23 -- that was me professionally leaving the 24 room ready for the bed when they come back to 25 the room again. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 20 of 106 20 (Pages 74 to 77) Page 74 1 G Maxwell - Confidential 2 Does that refresh your recollection 3 that you had a laundry basket full of sex 4 toys? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. First I have to read this. 8 Q. Sure. 9 MS. McCAWLEY: I will stop the 10 clock while the witness is reading. 11 MR. PAGLIUCA: No. 12 MS. McCAWLEY: Yes, if she is going 13 to read the whole document, I will stop 14 the clock. 15 MR. PAGLIUCA: If you give her 16 documents to refresh her recollection, 17 we are on the clock here. 18 MS. McCAWLEY: Then we will take it 19 up with the judge. 20 MR. PAGLIUCA: Read whatever you 21 need to answer the question. 22 MS. McCAWLEY: I'm going to set the 23 document aside and I'm just go to ask 24 you a question, independent of the 25 document. Page 75 1 G Maxwell - Confidential 2 Q. Do you recall having a basket full 3 of sex toys? 4 A. I already told you I did not. 5 Q. We were talking a moment ago about 6 Ms. Roberts and her position as a masseuse, 7 do you know what she was paid for working as 8 a masseuse for Jeffrey Epstein? 9 A. I do not. 10 Q. Did you ever pay her? 11 A. I don't ever recall paying her. 12 Q. Do you know what happened during 13 the massage appointments with Jeffrey Epstein 14 and Virginia Roberts? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. No. 18 Q. Were you ever present to view a 19 massage between Jeffrey Epstein and Virginia 20 Roberts? 21 A. I don't recollect ever seeing 22 Virginia and Jeffrey in a massage situation. 23 Q. Do you ever recollect seeing them 24 in a sexual situation? 25 A. I never saw them in a sexual Page 76 1 G Maxwell - Confidential 2 situation. 3 Q. Did you ever participate in sex 4 with Virginia Roberts and Jeffrey Epstein? 5 A. I never ever at any single time at 6 any point ever at all participated in 7 anything with Virginia and Jeffrey. And for 8 the record, she is an absolute total liar and 9 you all know she lied on multiple things and 10 that is just one other disgusting thing she 11 added. 12 Q. Did you help her obtain an 13 apartment in Palm Beach to live in? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 Q. Was that part of your 17 responsibilities for Jeffrey? 18 A. First of all, I didn't know she had 19 an apartment in Palm Beach. I only learned 20 that from the many times you guys have gone 21 to the press to sell stories, so no. 22 Q. Did you help her get a cell phone, 23 was that one of your responsibilities for 24 Jeffrey, to get her is a cell phone as part 25 of her masseuse obligations? Page 77 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I don't know what that means, 5 masseuse obligation, I don't know what you 6 are referring to. Would you like to ask the 7 question properly? 8 Q. I think it was proper. I will ask 9 it again. 10 Did you ever assist in getting 11 Virginia Roberts a cell phone to use during 12 the time that she worked for Jeffrey Epstein? 13 A. I have no recollection of doing 14 anything of that nature. 15 Q. Did you ever tell Virginia that you 16 wanted her to have a cell phone so that she 17 could be on call regularly? 18 A. I have no recollection of that 19 conversation. 20 Q. How often would Virginia come over 21 to the house in Palm Beach to give massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Ask the question again, please. 25 Q. How often did Virginia Roberts come MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 21 of 106 21 (Pages 78 to 81) Page 78 1 G Maxwell - Confidential 2 over to the house in Palm Beach to give 3 massages? 4 A. It's important to understand that I 5 wasn't with Jeffrey all the time. In fact, I 6 was only in the house less than half the 7 time, so I cannot testify to when I wasn't in 8 the house how often she came when I wasn't 9 there. 10 What I can say is that I barely 11 would remember her, if not for all of this 12 rubbish, I probably wouldn't remember her at 13 all, except she did come from time to time 14 but I don't recollect her coming as often as 15 she portrayed herself. 16 Q. How many times a day on an average 17 day would Jeffrey Epstein get a massage? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. When I was at the house and when I 21 was there with him, he received a massage, on 22 average, about once a day. 23 Q. Just once? 24 A. Yes. 25 Q. Were there days when he received Page 79 1 G Maxwell - Confidential 2 four or five? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. When I was present at the house, I 6 never saw something like that. 7 Q. Do you know if Virginia was 8 required to be on call at all times to come 9 to the house if Jeffrey wanted her there? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I have no idea of the arrangements 13 that Virginia made with Jeffrey. 14 Q. When Virginia was in New York, 15 would Virginia sleep at Jeffrey's mansion in 16 New York? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I don't recollect her being in New 20 York and I have no idea where she slept. 21 Q. You don't ever remember seeing 22 Virginia Roberts in New York? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I would barely recollect her at Page 80 1 G Maxwell - Confidential 2 all, except for this story. 3 Q. Do you recall Virginia Roberts 4 calling you because she was having a medical 5 crisis and you and Jeffrey taking her to the 6 hospital? 7 A. I have heard this absurd story and 8 if any part of it were true I would remember 9 that. I do not. 10 Q. You don't remember taking her to 11 the hospital? 12 A. It's not that I don't remember it, 13 it didn't happen. 14 Q. How do you know it didn't happen? 15 A. That's the sort of memory you would 16 recall. 17 Q. Do you recall, you said you don't 18 remember her being at the New York mansion. 19 When you were in New York would you stay at 20 the New York mansion with Jeffrey? 21 A. I stayed from time to time. 22 Q. Do you recall Virginia being at the 23 New York mansion when Prince Andrew came to 24 visit? 25 MR. PAGLIUCA: Objection to the Page 81 1 G Maxwell - Confidential 2 form and foundation. 3 A. Like I told you, I don't recall her 4 being at the house at all. 5 Q. How many homes does Jeffrey have? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. When I was working for him, I think 9 he had six maybe. 10 Q. Would Virginia stay with him in 11 those homes? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I can only testify for when I was 15 present with him and I cannot say what she 16 did when I wasn't present with him. 17 Q. When you were present, would 18 Virginia stay in the homes with him? 19 A. I don't recall her staying in the 20 houses. 21 Q. Did you train Virginia on how to 22 recruit other girls for massages? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. No. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 22 of 106 22 (Pages 82 to 85) Page 82 1 G Maxwell - Confidential 2 Q. Did you train Virginia on how to 3 recruit other girls to perform sexual 4 massages? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. No. And it's absurd and her entire 8 story is one giant tissue of lies and 9 furthermore, she herself has -- if she says 10 that, you have to ask her about what she did. 11 Q. Does Jeffrey like to have his 12 nipples pinched during sexual encounters? 13 MR. PAGLIUCA: Objection to form 14 and foundation. 15 A. I'm not referring to any advice on 16 my counsel. I'm not talking about any adult 17 sexual things when I was with him. 18 Q. When Jeffrey would have a massage, 19 would he request that the masseuse pinch his 20 nipples while he was having a massage? 21 A. I'm not talking about anything with 22 consensual adult situation. 23 Q. What about with underage -- 24 A. I am not aware of anything. 25 Q. You are not aware of Jeffrey Page 83 1 G Maxwell - Confidential 2 Epstein ever having sex with an underage 3 minor and asking them to pinch his nipples? 4 A. I am not. 5 Q. So I'm going to direct you to, I 6 believe it's Maxwell Exhibit 1, the police 7 report. 8 Are you aware that over 30 under 9 age minors gave testimony to police that they 10 were engaged in sexual acts during, 11 quote-unquote, massages. 12 MR. PAGLIUCA: The witness needs to 13 find Exhibit 1. Exhibit 1 -- if you can 14 hand me that please. 15 Q. So now with respect to the police 16 report, are you aware that over 30 underage 17 girls, meaning under the age of 18 gave 18 reports to police that they were assaulted 19 sexually by Jeffrey Epstein during massages? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I read the police report. That's 23 all I can testify to. 24 Q. Are you aware of what is in the 25 police report? Are you aware that there were Page 84 1 G Maxwell - Confidential 2 30 girls -- 3 A. I did not count the number of girls 4 and I did read the police report. I can only 5 testify to what I read. 6 Q. So you are aware that the police 7 report contains reports from 30 underage 8 girls? 9 A. I can't testify to what the girls 10 said. I can only testify to the fact that I 11 read a police report that stated that. 12 Q. Were you working for Jeffrey -- you 13 said you worked for him off an on until 2009, 14 is that correct? 15 A. I helped out from time to time. 16 Q. So you were working with him during 17 the time period when these underage girls 18 were visiting Jeffrey's home? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I was not -- what year, I need 22 years. 23 Q. How about let's say 2005? 24 A. I'm not sure I was at the house at 25 all in 2005, maybe one day, maybe. Page 85 1 G Maxwell - Confidential 2 Q. How about 2004? 3 A. I was present for his mother's -- 4 his mother died in 2004 so I was there for 5 his mother's death and the funeral and I was 6 at the house maybe a handful of days, again. 7 Q. I would like to direct you to, you 8 have it pulled together now, it's page 39, 9 Bates stamped Giuffre 00040? 10 A. Can you repeat that, please. 11 Q. Sure. 00040. 12 A. Yes. 13 Q. At the top of that document, about 14 three lines down, you see the redacted 15 portions where there is black so it blacks 16 out the name. 17 A. I see black redacted portions. 18 Q. That's a black redaction of the 19 name of the minor and there is -- I will 20 represent for the record that's what it is. 21 You can contest that but I'm not asking about 22 the name of the minor. 23 Five lines down, it says, She was 24 just 16 years of age. 25 Do you see that? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 23 of 106 23 (Pages 86 to 89) Page 86 1 G Maxwell - Confidential 2 A. I have to read that, if you want me 3 to testify to some things. 4 Q. I'm asking if you see where it 5 says, She was just 16 years old. 6 A. No, I have to read it. 7 Q. It's five line downs on the first 8 paragraph. 9 A. I do see that. 10 Q. Then the next paragraph down, it 11 says, this is the next full paragraph, it 12 says, Epstein entered the room, introduced 13 himself, Epstein lay on the table and told 14 her to get comfortable, blank could not 15 remember if he was naked or if he entered the 16 room with a towel. Blank stated she provided 17 the massage wearing her panties. She 18 continued rubbing his thighs and feet. Blank 19 advised he turned over on his back and 20 continued to rub his legs with oil. Epstein 21 touched her breast and began to masturbate. 22 I asked if she knew what circumcised and 23 uncircumcised meant. She stated circumcised 24 is when the penis had no foreskin. 25 Then jumping down to the next Page 87 1 G Maxwell - Confidential 2 paragraph, it says, Blank became upset, 3 crying hysterically and stated she was paid 4 and also instructed to have sex with Epstein 5 and Nadia Marcinkova by Epstein. 6 Do you see that there? 7 A. I do. 8 Q. Are you aware that there were 9 underage minors in the Palm Beach house that 10 were required to give sexual massages to 11 Jeffrey Epstein? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. This has been 14 asked and answered already. Now you are 15 just reading a document. 16 MS. McCAWLEY: I am allowed to take 17 this deposition. 18 A. I already testified -- 19 Q. Are you aware there were underage 20 girls, 30 of them, in this police report that 21 were assaulted by Jeffrey Epstein in the Palm 22 Beach house during the time you are working 23 there? 24 A. I am aware that Virginia has 25 lied repeatedly -- Page 88 1 G Maxwell - Confidential 2 Q. I'm not asking about Virginia. I'm 3 asking if you are aware that there were over 4 30 underage girls who gave reports to police 5 officers during the time you worked for 6 Jeffrey Epstein. Are you aware of that? 7 MR. PAGLIUCA: Counsel, what is 8 your factual basis for asserting there 9 are 30 underaged people who gave 10 reports? 11 MS. McCAWLEY: I don't have to 12 answer that. 13 MR. PAGLIUCA: Are you representing 14 as an officer of the court that you have 15 personal knowledge that there are 30 16 people referenced in these police 17 reports? 18 MS. McCAWLEY: That's my 19 understanding, that there are 30 girls. 20 MR. PAGLIUCA: How is that your 21 understanding if these are redacted 22 reports? 23 MS. McCAWLEY: By reading through 24 the reports. 25 MR. PAGLIUCA: So you have personal Page 89 1 G Maxwell - Confidential 2 knowledge there are 30 people -- 3 MS. McCAWLEY: Just like can you if 4 you read through -- I will not argue 5 with you counsel.. she can answer yes or 6 no. 7 Q. Are you aware there were over 30 8 individuals who were minors who gave reports 9 to police just like the one we just read that 10 they were sexually assaulted by Jeffrey 11 Epstein in the Palm Beach home during the 12 years that you were working with him? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. You can answer if 15 you have knowledge. 16 A. I already testified I was limited 17 in the house, a couple of days, there is no 18 way I knew. I have read these reports. I 19 cannot testify to 30. Given the experience 20 I've had with Virginia's lies, it's very hard 21 for me to testify about what I see. I can 22 tell from you my personal knowledge I did not 23 know what you are referring to. 24 Q. You did not know there were 25 underage girls in the home that were being MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 24 of 106 24 (Pages 90 to 93) Page 90 1 G Maxwell - Confidential 2 assaulted by Jeffrey Epstein during the time 3 you were working there? 4 A. Based on the lies that I have 5 already been told, I cannot comment on any -- 6 Q. Are you saying these 30 girls are 7 lying when they gave these reports to police 8 officers? 9 A. I'm not testifying to their lies. 10 I'm testifying to Virginia's lies. 11 Q. I am not asking about Virginia's 12 lies. 13 A. I can only testify to Virginia's 14 lies. I can testify to having read these 15 reports. I cannot testify to anything else 16 about them. 17 Q. So your testimony is that during 18 the time you were working there, you did not 19 know that these minor children were being 20 abused in the home while you were there? 21 A. What I have already told you and I 22 will repeat, I was in the house very limited 23 times, very few times. I do not know what 24 you are referring to. I've read these 25 reports but based on the lies that Virginia Page 91 1 G Maxwell - Confidential 2 has perpetrated, cannot tell you what is true 3 or factual or not. 4 Q. You said you were in the home a 5 very limited time, so average in the year for 6 example, 2004, how many times would you have 7 been in his Palm Beach home? 8 A. Very hard for me to state but very 9 little. 10 Q. How about his New York home? 11 A. Same. 12 Q. Were you his girlfriend in that 13 year, in 2004? 14 A. Define what you mean by girlfriend. 15 Q. Were you in a relationship with him 16 where you would consider yourself his 17 girlfriend? 18 A. No. 19 Q. Did you ever consider yourself his 20 girlfriend? 21 A. That's a tricky question. There 22 were times when I would have liked to think 23 of myself as his girlfriend. 24 Q. When would that have been? 25 A. Probably in the early '90s. Page 92 1 G Maxwell - Confidential 2 Q. In your responsibilities in working 3 for Jeffrey, would you book massages for him 4 on any given day so that he would have a 5 massage scheduled? Would you take a call for 6 example and book a massage for him? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 Q. You can answer. 10 A. Typically, that was not my 11 responsibility. He would either book the 12 massage himself or one of his other 13 assistants would do that. 14 Q. From time to time you had to do 15 that? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Like I said, typically it was 19 somebody else's responsibility. 20 Q. If you were unable to book a girl 21 for a massage on a given day, would that mean 22 that you were responsible for giving him a 23 sexual massage? 24 MR. PAGLIUCA: Objection to the 25 form and foundation and I instruct you Page 93 1 G Maxwell - Confidential 2 not to answer any questions about any of 3 your consensual adult sexual activity. 4 Q. So you are not going to answer that 5 question? 6 A. You just heard my counsel. 7 Q. Have you ever said to anybody that 8 recruiting other girls to perform sexual 9 massages for Jeffrey Epstein takes the 10 pressure off you? 11 MR. PAGLIUCA: Object to the form 12 and foundation. 13 A. Repeat the question and break it 14 out. 15 Q. Have you ever said to anybody that 16 you recruit girls -- 17 A. Stop right there. I never 18 recruited girls, let's stop there. Now 19 breakdown the question. 20 Q. Have you ever said to anybody -- 21 A. By girls, we are talking about 22 underage people -- you said girls, are you 23 talking about underage -- we are not talking 24 about consensual acts -- this is a defamation 25 suit. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 25 of 106 25 (Pages 94 to 97) Page 94 1 G Maxwell - Confidential 2 Q. I'm asking the questions. I know 3 what this case is about. I'm trying to -- I 4 will ask you questions if you don't 5 understand the question I can break it down 6 for you. I'm happy to do that. 7 A. Break it down a lot please. 8 Q. I will do that. 9 The question is, have you ever said 10 to anybody that you recruit other girls -- 11 A. Why don't you stop there. 12 Q. Let me finish my question. 13 Have you ever said to anybody that 14 you recruit girls to take the pressure off 15 you, so you won't have to have sex with 16 Jeffrey, have you said that? 17 That's the question? 18 A. You don't ask me questions like 19 that. First of all, you are trying to trap 20 me, I will not be trapped. You are asking me 21 if I recruit, I told you no. Girls meaning 22 underage, I already said I don't do that with 23 underage people and as to ask me about a 24 specific conversation I had with language, we 25 talking about almost 17 years ago when this Page 95 1 G Maxwell - Confidential 2 took place. I cannot testify to an actual 3 conversation or language that I used with 4 anybody at any time. 5 Q. Have you ever said to anybody that 6 you recruit other females over the age of 18 7 to take the pressure off you to having to 8 have sex with Jeffrey? 9 A. I totally resent and find it 10 disgusting that you use the word recruit. I 11 already told you I don't know what you are 12 saying about that and your implication is 13 repulsive. 14 Q. Answer my question. 15 A. I just did. 16 Q. Have you ever said to anybody that 17 you recruit females -- 18 A. I don't recruit anybody. 19 Q. That's an answer. So you never 20 said that? 21 A. I'm testifying that I cannot 22 testify to an actual language -- 23 Q. It's a yes or no. 24 A. I will not testify to an actual 25 statement made 17 years ago, so I cannot Page 96 1 G Maxwell - Confidential 2 testify to actual language. 3 Q. So you won't testify to anything 4 I'm asking you 17 years ago about a statement 5 you made. How do you know it's 17 years ago? 6 A. We are talking about a time in 7 2000, right? 8 Q. Have you ever said that to anybody? 9 A. I'm 54 years old so you are asking 10 me in my entire life, what words are you 11 asking me in my entire life? 12 Q. Your entire life is limited by the 13 time you were with Jeffrey, this is the 14 question. 15 A. Let's time limit the question you 16 are asking me. 17 Q. So from, let's say, I think you 18 said you started with him in 1992, is that 19 correct, and finished with him in 2009. 20 So from 1992 to 2009 have you ever 21 said to anybody that you recruit other and we 22 will start with girls to take the pressure 23 off you to have sex with Jeffrey? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 97 1 G Maxwell - Confidential 2 A. First of all I resent and despise 3 the world recruit. Would you like to define 4 what you mean by recruit and by girls, you 5 mean underage people. I never had to do 6 anything with underage people. So why don't 7 you reask the question in a way that I am 8 able to answer it. 9 Q. I'm asking if you ever said that to 10 anybody. So if you don't understand the word 11 recruit and you never used that word then the 12 answer to that question would be no. 13 A. I have no memory as I sit here 14 today having used that word. 15 Q. Did you ever meet an underage girl 16 in London to introduce her to Jeffrey to 17 provide him with a massage? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. Run that past me one more time. 21 Q. Did you ever meet an underage girl 22 in London to introduce her to Jeffrey to 23 perform a massage? 24 MR. PAGLIUCA: Same objection. 25 A. Are you asking me if I met anybody MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 26 of 106 26 (Pages 98 to 101) Page 98 1 G Maxwell - Confidential 2 that was underage in London specifically to 3 provide a massage to Jeffrey, is that your 4 question? 5 Q. Yes. 6 A. No. 7 Q. Do you know who Alexander Dixon is? 8 A. I don't recall her right now. 9 Q. Do you know if -- strike that. 10 During the time that you were 11 working for Jeffrey, did you ever observe any 12 foreign females, so in other words, not from 13 the United States, that were brought to 14 Jeffrey's home to perform massages? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. Females, what age are we talking? 18 Q. Any age. 19 A. Can you repeat the question? 20 Q. During the time you were working 21 for Jeffrey, did you ever observe any foreign 22 females of any age that were at Jeffrey's 23 home to perform a massage? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 99 1 G Maxwell - Confidential 2 A. Are you asking me if any foreigner, 3 not an American person, gave Jeffrey a 4 massage? 5 Q. Yes. 6 A. Well, as I sit here today, I can't 7 think of anyone who is foreign. Certainly -- 8 I just can't think of anybody right this 9 second. 10 Q. How about any foreign girls who 11 were under the age of 18? 12 A. I already testified to not knowing 13 anything about underage girls. 14 Q. Were there foreign girls who were 15 brought to Jeffrey's home by Jean Luc Brunel 16 for the purposes of providing massages? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I am not aware of Jean Luc bringing 20 girls. I have not no idea what you are 21 talking about. 22 Q. You have never been around foreign 23 girls who are under the age of 18 at 24 Jeffrey's homes? 25 MR. PAGLIUCA: Objection to the Page 100 1 G Maxwell - Confidential 2 form and foundation. 3 A. I already testified about not 4 knowing about underage girls. 5 Q. Did you provide any assistance with 6 obtaining visas for foreign girls that were 7 under the age of 18? 8 A. I've never participated in helping 9 people of any age to get visas. 10 Q. Did Jeffrey, was it Jeffrey's 11 preference to start a massage with sex? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I think you should ask that 15 question of Jeffrey. 16 Q. Do you know? 17 A. I don't believe that was his 18 preference. I think -- you have to 19 understand, a massage -- perhaps you are not 20 really familiar with what massage is. 21 Q. I am, I don't need a lecture on 22 massage. 23 A. I think you do. 24 MR. PAGLIUCA: No question pending. 25 She will ask you another question now. Page 101 1 G Maxwell - Confidential 2 A. Massage is for health benefits. 3 Q. When did you first meet Jeffrey? 4 A. Some point in 1991. 5 Q. And did Jeffrey know your father? 6 A. No. 7 Q. How were you introduced to Jeffrey? 8 A. Some friend introduced us. 9 Q. Can you describe your relationship 10 back in 1991, was it friendship or was it 11 girlfriend relationship or was it a work 12 relationship, what was your relationship in 13 1991? 14 A. It was just friendly. 15 Q. Then I believe you testified you 16 began working for him in 1992, is that 17 correct? 18 A. Yes. 19 Q. In 1992 I know you gave me the 20 description of the work that you were 21 performing for him, how much was he paying 22 you, do you remember? 23 A. I don't recall. 24 Q. Do you know for example in 2001 how 25 much he was paying you? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 27 of 106 27 (Pages 102 to 105) Page 102 1 G Maxwell - Confidential 2 A. I don't recall. 3 Q. Did it change over the years or did 4 the payment remain the same? 5 A. I believe over the course of time 6 it increased a little bit. 7 Q. Was that the -- was that payment 8 the payment that -- was the payment made with 9 respect to the jobs, the work you were 10 performing for Jeffrey, was that your sole 11 income at that time? 12 MR. PAGLIUCA: I object to the 13 form. I'm also going to instruct you 14 not to answer about sources of -- your 15 personal sources of income outside of 16 Mr. Epstein at all. 17 MS. McCAWLEY: What's the basis for 18 that? 19 MR. PAGLIUCA: It's confidential, 20 it's not part of this lawsuit. 21 MS. McCAWLEY: We have a protective 22 order and it is part of this lawsuit 23 with respect to our damage claims. 24 MR. PAGLIUCA: It's not and, in 25 fact, you are not entitled to ask Page 103 1 G Maxwell - Confidential 2 financial information of a defendant in 3 this kind of case, in a defamation case 4 unless and until there is a finding that 5 you are entitled to punitive damages. 6 That is clear in New York case law, both 7 state and Federal. 8 MS. McCAWLEY: We disagree on that 9 point and we will come back to that. 10 Q. From the source of payment from the 11 source of Jeffrey, from your work, can you 12 give me a range on that, do you know was it 13 over $100,000? 14 A. I just testified I don't recall. 15 Q. You don't don't know if it was 16 $500,000? 17 A. It was less than that. 18 Q. Somewhere between 100 and 500, 19 would that be fair to say? 20 A. I believe it was between 100 and 21 $200,000. 22 Q. Did Jeffrey during the time that 23 you were working for him purchase a town home 24 for you? 25 A. The subject of the townhouse is, I Page 104 1 G Maxwell - Confidential 2 worked for it and I had a loan, we did loans. 3 Q. So a loan through Jeffrey? 4 A. I don't recall the exact 5 transaction. 6 Q. Did he purchase for you a 7 helicopter during the time you were working 8 for him? 9 A. It was his helicopter. 10 Q. When did you obtain your pilot 11 license? 12 A. I believe it was '98 or '99. 13 Q. Was that for both airplanes and 14 helicopters or just helicopters? 15 A. Just helicopters. 16 Q. Have you ever flown President 17 Clinton on your helicopter? 18 A. That is another one of Virginia's 19 lies. 20 Q. The question is have you ever done 21 that? 22 A. I have never flown President 23 Clinton at any time ever, in any helicopter, 24 in any place, any time, in any state, in any 25 country, at any time anywhere. Page 105 1 G Maxwell - Confidential 2 Q. Have you ever had dinner with 3 President Clinton at Jeffrey's home, at any 4 of Jeffrey's homes? 5 A. No, I don't believe so. 6 Q. Have you traveled on Jeffrey's 7 planes with President Clinton? 8 A. Yes, I have. 9 Q. Would that have been in 2002? 10 A. It's very hard for me to recollect 11 exact dates but that sounds about right. 12 Q. Was that during the time that 13 Virginia was working for Jeffrey? 14 A. I don't know that Virginia ever did 15 work for Jeffrey. I don't exactly know if 16 she testified to her so-called duties, we 17 know she is a serial liar so I can't testify 18 to what she did or didn't do. So I object to 19 that characterization of her. So repeat the 20 question, please. 21 Q. Can you read the question back? 22 (Record read.) 23 Q. You can answer the question. 24 A. What was the question again? 25 Q. When you were traveling on the MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 28 of 106 28 (Pages 106 to 109) Page 106 1 G Maxwell - Confidential 2 plane with President Clinton, was that during 3 the time, it was 2002, that you were on a 4 flight with Clinton, was that during the time 5 Virginia was working for Jeffrey? 6 MR. PAGLIUCA: Object to the form. 7 Misstates the witness' answer and if you 8 can answer the question, you can answer 9 it. 10 A. Well, like I said, I don't recall 11 exactly when I flew with him. I don't recall 12 when Virginia, we know what Virginia claims 13 when she left, so I can't answer the 14 question. I have no idea. 15 Q. Do you know Prince Andrew? 16 A. I do. 17 Q. How long have you known him? 18 A. A very long time. 19 Q. Since you were a child? 20 A. I really -- it's so long, it's 21 really a long time ago. I just don't recall. 22 Q. Do you remember how you first met 23 him? 24 A. No, I do not. 25 Q. Did you introduce him to Jeffrey? Page 107 1 G Maxwell - Confidential 2 A. That would be another of Virginia's 3 lies and the lies you perpetrate. I never 4 introduced Prince Andrew to Jeffrey Epstein 5 at any time ever, so just add that the to 6 long list of lies. 7 Q. Did Jeffrey know Prince Andrew? 8 A. Clearly he knew him. I think we 9 have that answer but how -- yeah. 10 Q. Do you know how Jeffery met Prince 11 Andrew? 12 A. I do not know Jeffrey met Prince 13 Andrew. What I do know is that I did not 14 introduce them. That is one of the many 15 lies. Are we tallying all the lies? 16 Q. Do you know when Jeffrey met Prince 17 Andrew? 18 A. I do not know when Jeffrey met 19 Prince Andrew. 20 Q. Did you ever introduce Prince 21 Andrew to any girls under the age of 18 who 22 were not friends of yours children? 23 A. I have not introduced Prince Andrew 24 to anyone that I am aware of other than 25 friends of mine who have kids under that age Page 108 1 G Maxwell - Confidential 2 that he may have met socially through me. 3 Q. Did you ever introduce Prince 4 Andrew to Virginia in London? 5 A. I understand her story about London 6 but again, her tissue of lies is extremely 7 hard to pick apart what is true and what 8 isn't. Actually I wouldn't recollect her at 9 all but for her tissue stories about this 10 situation. 11 Q. So did you ever introduce Prince 12 Andrew to Virginia in London? 13 A. I have no recollection. 14 Q. Did Virginia ever stay at your home 15 in London, your town home? 16 A. I know she claims she did but if 17 you are asking me here today to remember 18 specifically, I cannot. 19 Q. Do you remember taking a trip with 20 Virginia to travel over to Europe, including 21 London? 22 A. So I have seen her reports and I 23 have seen the plane reports. I see she says 24 she was on that but again, I really have no 25 recollection of her. Page 109 1 G Maxwell - Confidential 2 Q. Did you know that she was 17 at the 3 time of that trip? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I have -- 7 Q. Did you know she was 17 at the time 8 of that trip? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I didn't even know she was on the 12 trip. 13 Q. Did you hold her passport for her 14 when she was traveling? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I have no recollection whatsoever 18 of her even being on the trip nor holding her 19 passport. 20 (Maxwell Exhibit 4, picture, marked 21 for identification.) 22 Q. I'm showing you what we marked as 23 Maxwell Exhibit 4. 24 Can you take a look at that picture 25 for me? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 29 of 106 29 (Pages 110 to 113) Page 110 1 G Maxwell - Confidential 2 A. I've looked at it. 3 Q. Are you in that picture? 4 A. I am. 5 Q. Is that Prince Andrew in the 6 picture as well? 7 A. It is. 8 MR. PAGLIUCA: I don't believe this 9 has been produced to us in discovery by 10 you. 11 MS. McCAWLEY: The picture? 12 MR. PAGLIUCA: Yes. 13 MS. McCAWLEY: It has. 14 MS. MENNINGER: Is it the same 15 exact photograph. 16 MS. McCAWLEY: I believe so. We 17 will find one. The picture has been 18 produced a number of times. 19 MR. PAGLIUCA: I've seen different 20 iterations of this, I don't believe I 21 have ever seen this. 22 MS. McCAWLEY: We had them blow it 23 up on a page so she could see it. We 24 could use an article. 25 While you are looking for that, I Page 111 1 G Maxwell - Confidential 2 will skip ahead. Hold that until we can 3 find one that has the Bates range on it. 4 Q. Do you recall Virginia being at 5 your London town home? 6 A. I do not. 7 Q. Do you recall going to dinner with 8 Prince Andrew, Jeffrey Epstein and Virginia 9 Roberts in London, at any time? 10 A. I do not. 11 Q. Do you recall going to a place 12 called Club Tramp with Prince Andrew, Jeffrey 13 Epstein and yourself and Virginia Roberts? 14 A. I would just like to state for the 15 record that Prince Andrew is a very famous 16 person, I know you are aware because you like 17 to use him so often in your press stories -- 18 please let me finish. Were he at Tramp, at 19 any time, that would be reported by the 20 press. I do not have any recollection of it 21 and I doubt it actually happened. 22 Q. You don't recall that. 23 Do you recall taking Virginia 24 shopping when you were in London to buy an 25 outfit to meet Prince Andrew? Page 112 1 G Maxwell - Confidential 2 A. No, I don't. 3 Q. Where in your town home -- we will 4 come back to that. 5 Do you have guest bedrooms in your 6 town home in London? 7 A. I do. 8 Q. How many? 9 A. Two. 10 Q. Did Prince Andrew ever visit 11 Jeffrey and you in New York? 12 A. Yes. 13 Q. Do you remember him visiting you 14 and Jeffrey in New York in the spring of 15 2001? 16 A. Again, I can't testify to any 17 specific dates. 18 Q. So you don't have a recollection of 19 that? 20 A. I have a recollection -- you've 21 asked me if I have a recollection of being in 22 New York but if you are asking for a date, I 23 cannot confirm that date. 24 Q. Do you remember Prince Andrew being 25 present in New York for a party where Johanna Page 113 1 G Maxwell - Confidential 2 Sjoberg was also present? 3 A. I don't recollect. 4 Q. Do you recall ever giving Prince 5 Andrew a gift of a puppet that was in the 6 same -- that looked like him? 7 A. I never gave him a gift of a 8 puppet. 9 Q. Did Jeffrey ever give him a gift of 10 a puppet? 11 A. No, not that I am aware of. 12 Q. Have you ever given him any gifts? 13 MR. PAGLIUCA: Objection, 14 foundation. 15 A. I know Andrew -- 16 Q. Have you ever given him any gifts 17 that you remember when he came to Jeffrey's 18 home in New York? 19 A. I don't recall giving him any gifts 20 in New York. 21 (Maxwell Exhibit 5, picture, marked 22 for identification.) 23 Q. I think I directed you to page 24 0034. 25 Is that a picture that was taken at MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 30 of 106 30 (Pages 114 to 117) Page 114 1 G Maxwell - Confidential 2 your London town home? 3 A. I have no idea what this picture 4 was taken. I know what she purports it to be 5 but I'm not going to say that I do. 6 Q. Do the surroundings look like your 7 London town home? 8 A. They are familiar. 9 Q. Do you know who took this picture? 10 A. I do not. 11 Q. Did Jeffrey Epstein take the 12 picture? 13 A. I just testified I don't know who 14 took the picture. 15 Q. So you don't know if Jeffery 16 Epstein took the picture? 17 A. When I tell you I don't know who 18 took the picture, it doesn't mean him -- I 19 don't know who took the picture. You can 20 come up with 50 names, I still do not know 21 who took the picture. 22 Q. Did you observe Prince Andrew go 23 into a room with Virginia alone in your town 24 home? 25 A. I cannot recall. As I have said, Page 115 1 G Maxwell - Confidential 2 no. 3 Q. Did Prince Andrew ever tell you 4 that he had sex with Virginia Roberts? 5 A. He did not. 6 Q. Did Jeffrey Epstein ever tell you 7 that Prince Andrew had sex with Virginia 8 Roberts? 9 A. He did not. 10 Q. Did Prince Andrew ever visit -- let 11 me back up for a moment. We talked about 12 Jeffrey's homes, did Jeffrey have a home in 13 the U.S. Virgin islands called Little St. 14 James? 15 A. Yes. 16 Q. Did Prince Andrew ever visit that 17 island -- are you aware of Prince Andrew ever 18 visiting Jeffrey's island? 19 A. I am aware of that, yes. 20 Q. Do you know how many times he 21 visited? 22 A. I do not. 23 Q. Do you know if he visited when 24 Virginia was on the island? 25 A. I do not. Page 116 1 G Maxwell - Confidential 2 Q. Were you present on the island when 3 Prince Andrew visited? 4 A. Yes. 5 Q. How many times? 6 A. I can only remember once. 7 Q. Were there any girls under the age 8 of 18 on the island during that one visit 9 that you remember that were not family or 10 friends of or daughters of your friends? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. There were no girls on the island 14 at all. No girls, no women, other than the 15 staff who work at the house. Girls meaning, 16 I assume you are asking underage, but there 17 was nobody female outside of the cooks and 18 the cleaners. 19 Q. Did you, as part of your duties in 20 working for Jeffrey, ever arrange for 21 Virginia to have sex with John Luc Brunel? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Just for the record, I have never 25 at any time, at anyplace, in any moment ever Page 117 1 G Maxwell - Confidential 2 asked Virginia Roberts or whatever she is 3 called now to have sex with anybody. 4 Q. Did you ever provide Virginia 5 Roberts with an outfit, an outfit of a sexual 6 nature to wear for Les Wexner? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I think we addressed the outfit 10 issue. 11 Q. I am asking you if you ever 12 provided her with an outfit of a sexual 13 nature to wear for Les Wexner? 14 A. Categorically no. You did get 15 that, I said categorically no 16 Q. Don't worry I'm paying attention. 17 A. You seemed very distracted in that 18 moment. 19 (Maxwell Exhibit 6, flight logs, 20 marked for identification.) 21 A. Do you mind if I take a break for 22 the bathroom. 23 Q. It's 11:08 and we are going to go 24 off the record now. 25 THE VIDEOGRAPHER: It's now 11:09. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 31 of 106 31 (Pages 118 to 121) Page 118 1 G Maxwell - Confidential 2 We are off the record. 3 (Recess.) 4 THE VIDEOGRAPHER: It's now 11:26, 5 we are back on the record and starting 6 disk No. 3. 7 Q. Ms. Maxwell, I think I handed you 8 right before the break, did I hand you the 9 flight logs, they look like this. Did I mark 10 those yet, I thought I did. 11 A. I don't believe I have it. 12 Q. These admittedly are a little 13 difficult to read so what I'm going to 14 provide you with to assist is I have a chart 15 that has the airport codes, because it will 16 have, for example, just for the record 17 reflects that the first page of document 18 it will have a code in the from line 19 that says PBI, for example, to TEB so I a 20 chart that matches up, just in case you don't 21 understand what those letters mean, PBI 22 meaning Palm Beach, TEB meaning Teterboro, 23 which is New Jersey, but others are more 24 difficult but just for you to be able to 25 understand the logs, I will provide you with Page 119 1 G Maxwell - Confidential 2 that. 3 MR. PAGLIUCA: So we are clear, if 4 the witness has personal knowledge of 5 what these are that's fine but I don't 6 know what these are and I don't expect 7 the witness to accept the representation 8 that they are what they are. 9 MS. McCAWLEY: If she can testify 10 to what city it is, she can state that 11 on the record. 12 MR. PAGLIUCA: If she knows what it 13 is, she knows what it is, we are not 14 putting any affirmatively on the record 15 until you ask your questions. 16 Q. So I'm going to ask you and I think 17 we flagged a few of the pages which may 18 direct us a little bit easier but I will do 19 it by Bates number which is at the bottom of 20 the document kind of at the side. 21 The first I will direct your 22 attention to is 23 A. Does it have a tab? 24 Q. It should. Let me make sure. 25 A. Yes it does. Page 120 1 G Maxwell - Confidential 2 Q. So I'm directing your attention to 3 the bottom, two lines up from the bottom, 4 there is a flight -- 5 MR. PAGLIUCA: Are you on 6 MS. McCAWLEY: 7 Q. So this flight is from, the one I'm 8 looking at, I think it's highlighted on your 9 copy. On the far corner on the date, it says 10 at the top and this would be the 11 and then the are the two I'm going to 12 direct your attention to. 13 Q. On that first one on the you 14 will see the column reading PBI in the from 15 column to TEB in the to column and you will 16 see some initials, you will see JE for 17 Jeffrey Epstein, GM for Ghislaine Maxwell, ET 18 for Emmy Taylor and then Virginia? 19 A. I have to object. 20 MR. PAGLIUCA: You don't get to 21 object. 22 Q. She is turning into a lawyer 23 already? 24 A. I would like to. 25 Q. Let me ask the question and if you Page 121 1 G Maxwell - Confidential 2 have an issue -- so with respect to this 3 flight, do you recall being on a flight in 4 the -- going from Palm Beach to 5 Teterboro? 6 A. No, I don't recall any specific 7 flight. 8 Q. Do you recall flying with Virginia 9 on a flight with Emmy Taylor and Jeffrey 10 Epstein at any time? 11 A. I don't. 12 Q. How often did you fly on a plane 13 with a 17 year old? 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. I have no idea what you are talking 17 about, other than friends of mine that had 18 kids. 19 Q. Did you regularly fly on Jeffrey's 20 plane with individuals who were under the age 21 of 18? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Can you repeat the question? 25 Q. Did you regularly fly on Jeffrey 1111 - • ■ - . . • MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 32 of 106 32 (Pages 122 to 125) Page 122 1 G Maxwell - Confidential 2 Epstein's planes with individuals who were 3 under the age of 18? 4 A. I regularly flew on Jeffrey 5 Epstein's airplane but I cannot testify as to 6 flying with people under the age. I don't 7 believe that I did. 8 Q. Why wouldn't you remember flying 9 with a 17 year old? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. How would I know, one, that she is 13 17, how would you know that, how do you know 14 I'm on the plane. 15 Q. Are you saying you are not on this 16 flight, so this is a Palm Beach to Teterboro. 17 This says the JE, GM ET and Virginia. The GM 18 you are saying is not you? 19 MR. PAGLIUCA: I object to the 20 form. You can answer the question if 21 you know. 22 A. How do you know the GM is me. 23 Q. Is it your testimony that on the 24 flight logs when it represents GM that it is 25 not you flying on the plane? Page 123 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. GM can stand for any level, it 5 could be Georgina, George. 6 Q. Are there any people that flew with 7 Jeffrey Epstein that had the initials GM? 8 A. I don't know. 9 Q. Do you recall flying with Jeffrey 10 Epstein on his plane over 300 times during 11 the period of 1999 to 2005? 12 A. I cannot testify to how many times 13 I was on his plane because that would just be 14 impossible. 15 Q. You were on his plane regularly, 16 would you say? 17 A. I already testified I was on his 18 plane regularly. 19 Q. Is it your testimony and I'm 20 referring now to the line that we were just 21 talking about that you were not on the flight 22 from Palm Beach to Teterboro that lists JE, 23 GM, ET and Virginia? 24 A. I am not testifying to that. I am 25 just saying that you cannot be sure that is Page 124 1 G Maxwell - Confidential 2 me. 3 Q. So as you sit here today, you don't 4 believe you flew on that plane? 5 A. I'm not saying that. I'm just 6 saying you cannot be sure that's me. 7 Q. Do you have reason to doubt that 8 when it says GM on these flight logs that 9 that represents you? 10 A. I cannot testify to that. I'm just 11 saying it may not be me. 12 Q. In looking at the flight logs and 13 look up, let's move up a couple of lines. If 14 you start at the top, you are going to see 15 JE, , then JE, AP, , 16 JE, AP JE, GM, JE, GM, JE, GM, 17 Ricardo Loretta, reposition, JE, GM, JE, GM 18 ET Kelly Spamm, JE, GM, Kelly Spamm, Tom 19 Pritzer, female, Marham Air Force 20 repositioning. JE, GM, ET, Kelly Spamm, JE, 21 GM, ET, Kelly Spamm, JE, GM, ET, Virginia, 22 JE, GM, AP, Virginia, repositioning and then 23 a certification. 24 So is it your testimony in looking 25 at that that you do not believe that the GM Page 125 1 G Maxwell - Confidential 2 represents you? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I'm not saying that. I'm just 6 saying that you cannot -- I can't sit here 7 and tell you for sure GM is me and I cannot 8 testify remembering being on a flight at that 9 time. 10 Q. You don't remember being on any of 11 these flights with the initial GM? 12 A. I remember being on many flights. 13 I cannot testify that is a flight I am on. 14 Q. Let's go to the next page which is 15 going to be I want you to look at 16 line -- so the date is at the top, so it's 17 and if you go down, you will see 18 a line that says the and if you scroll 19 over you will see PBI to TIST, if you look at 20 the airport codes, TIST is going to be 21 representative for the U.S. Virgin Islands 22 and then you will see the list on the plane 23 JE, GM, ET and Virginia Roberts. 24 Do you recall flying from Palm 25 Beach to the U.S. Virgin Islands with 1111 -- MAGNA9 LEGAL SERVICES - Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 33 of 106 33 (Pages 126 to 129) Page 126 1 G Maxwell - Confidential 2 Jeffrey, yourself, Emmy Taylor and Virginia 3 Roberts? 4 MR. PAGLIUCA: I object to the form 5 and just so the record is clear, we 6 don't agree with whatever your 7 characterizations are. The document 8 speaks for itself and she can answer 9 based on whatever her personal knowledge 10 is. 11 MS. McCAWLEY: I understand. 12 Q. Do you recall flying with those 13 individuals from Palm Beach to the U.S. 14 Virgin Islands? 15 A. I have no recollection of any 16 individual flight you are pointing out here. 17 You are talking about 2001, how many years 18 ago is that? 19 Q. I'm asking the questions. 20 A. I'm not being difficult. I'm just 21 asking, it's like 14, 15 years ago, it's 22 impossible, I'm sorry. 23 Q. So your testimony is you don't 24 recall flying on that flight with Virginia 25 Roberts? Page 127 1 G Maxwell - Confidential 2 A. I cannot testify to that flight. 3 Q. Let's look at the next flight which 4 is on the from the Virgin Islands back 5 to Palm Beach, JE, Jeffrey Epstein, Ghislaine 6 Maxwell, Emmy Taylor, Virginia Roberts, the 7 same individuals on the above flight. 8 A. It doesn't say my name, it has some 9 initials. 10 Q. I understand, the initials GM. 11 Do you recall flying on a plane, on 12 one of Jeffrey's planes from the Virgin 13 Islands to Palm Beach with Virginia Roberts? 14 A. I do not. 15 Q. Was there any other person that 16 flew with Jeffrey Epstein with frequency 17 during that time period in these logs that 18 have the initials GM? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I would have to look at all the 22 flight logs, I have no idea, I flew 23 frequently. 24 Q. Why don't you take a look at the 25 next three pages and see if that refreshes Page 128 1 G Maxwell - Confidential 2 your recollection. 3 MR. PAGLIUCA: You are talking 4 about 5 MS. McCAWLEY: She can pick any 6 couple of pages, those have a lot of the 7 individuals on them so that is a good 8 sampling. 9 MR. PAGLIUCA: So pick any pages 10 you want. 11 Q. Does that refresh your recollection 12 at all as to whether GM represents you or 13 some other individual? 14 A. Again, I can't testify whether that 15 represents me or not, I don't see any other 16 GMs but you have to understand that even if 17 my name is on that record doesn't mean I was 18 on the flight. 19 Q. So are you contesting the accuracy 20 of the flight logs? In other words, you said 21 it doesn't represent you are on the flight so 22 is it your testimony just because a name is 23 listed doesn't mean they were actually on the 24 flight? 25 MR. PAGLIUCA: Objection to the Page 129 1 G Maxwell - Confidential 2 form and foundation. 3 A. I can't testify to what -- these 4 are records that were produced by Dave Rogers 5 is on here, so these aren't federally 6 mandated records, so I can't testify to what 7 he produced. 8 Q. I would like you to turn to page, 9 at the bottom, the Bates number is 10 And the month is 11 A. Okay. 12 Q. If you go down to the number that 13 is that would be , you're 14 going to see on that line an which is a 15 and then you 16 will see which is going to be, I'm going 17 to pronounce it incorrectly, 18 I'm sure I'm not pronouncing that 19 correctly. Then you will see in the list, 20 you will see JE, GM, SK, President Clinton, 21 Doug Band, it looks like -- 22 A. I believe it says male. 23 Q. Yes. Then I 24 believe. Is that GM on this page 25 representative of you? • • -- ■ - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 34 of 106 34 (Pages 130 to 133) Page 130 1 G Maxwell - Confidential 2 A. Well, this would be a flight that I 3 would potentially remember with Bill Clinton 4 on it but I don't actually recall going to 5 Russia. 6 Q. Are those your initials, do you 7 recall being on the flight? 8 A. Those are my initials with 9 President Clinton, I don't recall this flight 10 either, but I would be more likely to if I 11 had a bit more time to study the timing of 12 this. 13 Q. Your testimony is you don't recall 14 flying with President Clinton from to 15 16 A. I don't recall the to 17 flight. I have definitely flown with 18 President Clinton. 19 Q. On that same page you will see 20 beneath there, beneath 22 you will see the 21 indication, same as above, same as above, 22 same as above in the column that originally 23 had the initials. 24 A. Uh-huh. 25 Q. And the names. Page 131 1 G Maxwell - Confidential 2 A. Uh-huh. 3 Q. Do you recall flying with President 4 Clinton from to 5 6 A. I do. 7 Q. So the GM that would be represented 8 in that column would be you? 9 A. I recall going to with the 10 president so that is likely to be me. 11 Q. You were on Jeffrey's plane for 12 that trip? 13 A. I believe I was. 14 Q. Do you know who 15 is? 16 A. I do not. 17 Q. I'm going back towards the front 18 which is going to be please. And 19 you're going to see -- 20 A. Hang on I'm not -- 21 Q. Take your time. 22 A. Okay. 23 Q. You are going to see in the date 24 column, you will see and then about 25 halfway down you will see and Page 132 1 G Maxwell - Confidential 2 then you will see the which 3 is the column which is where I want you to 4 start looking at the log and there you're 5 going to see 11 A. Okay. 12 Q. If you look at the column, if you 13 go back up to the top on the if you look 14 at the column you will see JE, GM, ET, 15 Virginia Roberts and I believe it says 16 sorry I'm not reading that very 17 well. 18 Do you recall flying from, if you 19 see the dates, the and 20 Do you recall a trip that went from 21 the United States to Canada and to the places 22 I just mentioned where Virginia Roberts was 23 on the plane with you? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 133 1 G Maxwell - Confidential 2 A. I already testified that I don't 3 recall Virginia on any of these flights. 4 Q. I would like to mark, as Maxwell 7, 5 I will put it at the top? 6 (Maxwell Exhibit 7, photo, marked 7 for identification.) 8 MR. PAGLIUCA: Has this document 9 been produced in discovery? 10 MS. McCAWLEY: Yes. 11 MR. PAGLIUCA: Do you have a Bates 12 number? 13 MS. McCAWLEY: This one doesn't. 14 Q. I'm going to ask you -- 15 MR. PAGLIUCA: I don't recall 16 seeing this document so I would like to 17 see a Bates number document before we 18 ask questions about it. 19 MS. McCAWLEY: Can you go look for 20 it and I will continue. We will set 21 that aside until we get a Bates number. 22 You may want to leave that log up and 23 set it to the side and we will bounce 24 back to that. 25 Q. Do you recall -- I think earlier - - -- - ■ - - - - - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 35 of 106 35 (Pages 134 to 137) Page 134 1 G Maxwell - Confidential 2 you said you visited Jeffrey's island, I 3 think they called it St. Jeffrey or St. 4 James, the U.S. Virgin Island home. 5 A. St. James. 6 Q. Do you recall whether President 7 Clinton was ever on that island? 8 A. Categorically, definitively, 9 absolutely, without a shadow of a doubt, when 10 I was present or any other time that I am 11 aware of, was President Clinton ever on that 12 island, I do not believe he went to that 13 island ever ever, that is an absolute 14 fabrication and an absolute flat out lie. 15 Q. Was President Clinton or former 16 President Clinton ever at any of Jeffrey 17 Epstein's homes when you present, other than 18 the island I know you said that did not 19 happen, the home in either New York or Palm 20 Beach or New Mexico? 21 A. I do not believe at any time 22 President Clinton was at any of Jeffrey's 23 homes, I have absolutely no knowledge or 24 otherwise that he was ever there. 25 Q. You don't recall having dinner with Page 135 1 G Maxwell - Confidential 2 him at any of those homes? 3 A. Again, Virginia is absolutely 4 totally lying. This is a subject of 5 defamation about Virginia and the lies she 6 has told and one of lies she told was that 7 President Clinton was on the island where I 8 was present. Absolutely 1000 percent that is 9 a flat out total fabrication and lie. 10 Q. You did fly on planes, Jeffrey 11 Epstein's planes with President Clinton, is 12 that correct? 13 A. I have flown, yes. 14 Q. Would it be fair to say that 15 President Clinton and Jeffrey are friends? 16 A. I wouldn't be able to characterize 17 it like that, no. 18 Q. Are they acquaintances? 19 A. I wouldn't categorize it. 20 Q. He just allowed him to use his 21 plane? 22 A. I couldn't categorize Jeffrey's 23 relationship. 24 Q. When you were on the plane with 25 Jeffrey and President Clinton, did you Page 136 1 G Maxwell - Confidential 2 observe Jeffrey and President Clinton 3 talking? 4 A. I'm sure they did. 5 Q. Did they seem friendly? 6 A. I don't recollect. 7 Q. Was Epstein one of the original 8 people that conceived the Clinton global 9 initiative? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 Q. Do you know? 13 A. I don't have -- I don't know what 14 you are talking about. 15 Q. You don't know what I'm talking 16 about. 17 Did you ever, not at one of houses, 18 but did you ever eat dinner with President 19 Clinton and Jeffrey Epstein? 20 A. Are you just talking in general 21 anywhere. 22 Q. In general? 23 A. I believe on a plane of this nature 24 we would have had a meal. 25 Q. But not outside of the travel on Page 137 1 G Maxwell - Confidential 2 the flights? 3 A. I can't recollect having a meal 4 with them, but just so we are clear, the 5 allegations that Clinton had a meal on 6 Jeffrey's island is 100 percent false. 7 Q. But he may have had a meal on 8 Jeffrey's plane? 9 A. I'm sure he had a meal on Jeffrey's 10 plane. 11 Q. You do know how many times he flew 12 on Jeffrey's plane? 13 A. I don't. 14 Q. Do you know who Doug Band is? 15 A. I do. 16 Q. How do you know him? 17 A. He used to work or still works for 18 Bill Clinton. 19 Q. Did you ever have a relationship 20 with him? 21 A. We are talking about adult 22 consensual relationships, it's off the 23 record. 24 Q. I'm not asking what you did with 25 him, I'm asking if you ever had a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 36 of 106 36 (Pages 138 to 141) Page 138 1 G Maxwell - Confidential 2 relationship with him? 3 MR. PAGLIUCA: If you understand 4 the term relationship, certainly you can 5 answer that. 6 A. Define relationship. 7 Q. Somebody that you would have spent 8 time together, either seeing them in a 9 romantic relationship or -- 10 A. You need to be, what do you mean by 11 romantic. I was friends with Doug but you 12 are suggesting something more so I want to be 13 clear what you are actually asking me. 14 Q. You defined it. You said you were 15 friends with him. If that's what you were 16 that's all I need to know. 17 While you were on the trip with 18 President Clinton, do you recall where you 19 stayed at these locations, in other words, 20 would you leave the jet and stay overnight at 21 a hotel, do you have a recollection of this 22 trip? 23 A. I recollect the trip but if you're 24 asking me where we stayed, you can see it's a 25 very fast paced trip. It was very tiring and Page 139 1 G Maxwell - Confidential 2 I don't recollect where we stayed. 3 Q. Do you recollect if you stayed at 4 the same place President Clinton stayed? In 5 other words, if you left the plane to go a 6 hotel did you all go together is your 7 recollection? 8 A. I honestly don't recollect, no. 9 Q. Part of this trip we were just 10 talking about, there is a flight that goes to 11 Thailand, do you remember being in Thailand? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. Are you asking me -- 15 Q. On the President Clinton trip. 16 A. Are you referencing something? 17 Q. The part that, let me make sure 18 I've got it here. The entry that would be 19 the Thailand, would be the one -- let me make 20 sure I'm correct. I have you on the wrong 21 page, it's actually the page before. It's 22 going to be And it's going to be the 23 entry on starting on and then 24 it goes down to where it has the same as 25 above, to -- I'm saying Page 140 1 G Maxwell - Confidential 2 3 MR. PAGLIUCA: That's what the 4 document says. 5 Q. I'm not representing the date but 6 there it is. So the last leg of that where 7 it says same as above has, the second to 8 last, I'm sorry on the 2 10 Do you remember being in Thailand 11 with President Clinton? 12 A. I do. 13 Q. Do you remember what the purpose of 14 that trip was? 15 A. I don't. 16 Q. Do you know whether -- do you 17 recall, did you stay the night in Thailand? 18 A. I don't recall. 19 Q. Do you recall why you went to 20 Thailand? 21 A. I don't recall. 22 Q. Who is Andrea Mitrovich? 23 A. She I believe was a stewardess on 24 this flight. 25 Q. Did she perform any massages on the Page 141 1 G Maxwell - Confidential 2 flight? 3 A. I don't recollect any massages on 4 the flight. 5 Q. Do you know who is? 6 A. It doesn't -- no I don't know who 7 that is, I can't recall. 8 Q. This is not in color, it's a black 9 and white but it has the Bates label on it. 10 Should I take the sticker off the one that 11 has -- I don't know if you want to swap it. 12 MR. PAGLIUCA: Let the record 13 reflect I am replacing this on the black 14 and white copy of this exhibit with 15 16 Q. So, we were talking earlier, we 17 were looking at the flight logs and we were 18 talking about a trip and let me just get you 19 back to the page. I - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 37 of 106 37 (Pages 142 to 145) Page 142 1 G Maxwell - Confidential 2 Q. Can I direct your attention to the 3 picture, please. 4 A. Of course. 5 Q. Can you tell me who is in this 6 picture, who is pictured here, and for the 7 court reporter's benefit, can you go from the 8 left of the picture to the right of the 9 picture, to the extent you can identify the 10 individuals? 11 A. Sure. I cannot identify the person 12 on the left, I cannot identify the person 13 next left. I can identify Jeffrey Epstein. 14 I cannot identify the next person to his 15 right and the next person in the picture is 16 myself. 17 Q. Is the individual all the way to 18 the left at the beginning of the picture, 19 does that resemble Emmy Taylor. You might 20 want to look at the color version if that 21 helps you at all, I know it's not the marked 22 one. I don't if that's easier to see, they 23 are both dark. 24 A. That does not look like Emmy Taylor 25 at all. Page 143 1 G Maxwell - Confidential 2 Q. Do you recall -- 3 MR. PAGLIUCA: Let's mark this then 4 as deposition Exhibit 8 since we are 5 referring to it and then you can give us 6 copies as well. 7 MS. MENNINGER: It's different 8 because it has other people in this 9 color photo. 10 (Maxwell Exhibit 8, photo, marked 11 for identification.) 12 Q. Do you recall who took this 13 photograph? 14 A. I do not. 15 Q. Do you recall this photograph being 16 taken by Virginia? 17 A. First of all, I don't know where we 18 are. 19 Q. So you don't recognize the 20 building? 21 A. I don't recognize the building and 22 I don't recognize -- the only two people I 23 recognize in the picture are Jeffrey and 24 myself. 25 Q. Does this like look a picture of a Page 144 1 G Maxwell - Confidential 2 building that you would have seen when you 3 were on the trip in Europe? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't possibly answer that. 7 Q. Do you recall Virginia ever taking 8 pictures? 9 A. I barely recall Virginia, period. 10 Q. Do you recall her ever taking 11 pictures? 12 A. No, I don't. 13 Q. I'm going to direct your attention, 14 still within the flight logs to -- starting 15 on the next page from where you just were 16 which is going to be And the date at 17 the top says you will see and I'm 18 directing your attention down towards the 19 middle to the bottom where you will see the 20 numbers 21 A. Uh-huh. 22 Q. And we've got actually I'm going to 23 direct your attention to the one that starts 24 Page 145 1 G Maxwell - Confidential 2 and in the line, the remarks line you will 3 see JE, GM, AP, VR, BK, Marvin Minski and 4 5 MR. PAGLIUCA: Are you reading the 6 29th, is that what you're reading? 7 MS. McCAWLEY: I'm reading the 8 29th, yes. 9 Q. Below that you will see JE, GM, AP, 10 VR, and Marvin 11 Minski. 12 Do you see that? 13 A. I do. 14 Q. Do you recall a trip from Teterboro 15 to Santa Fe and Santa Fe back to Palm Beach 16 with these individuals? 17 A. I don't. 18 Q. Do you recall being on a plane with 19 and Virginia Roberts? 20 A. I don't. 21 Q. Do you recall ever witnessing any 22 sexual interaction on one of Jeffrey's planes 23 with any of these individuals? 24 A. I do not, absolutely not. 25 Q. Did Jeffrey have a fold out bed on --- MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 38 of 106 38 (Pages 146 to 149) Page 146 1 G Maxwell - Confidential 2 one of his planes? 3 A. There was a bed on one of his 4 planes that folded out, yes. 5 Q. Do you recall whether with respect 6 to this being in Santa Fe, do you recall 7 whether you were there for some form of a 8 party? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I don't recall the trip at all and 12 this looks like a total work trip, not a 13 party trip. 14 Q. What would be the difference 15 between a work trip and a party trip? 16 A. Just that I would be on trips for 17 work and I believe that this looks like, AP 18 looks like it's one of the -- probably one of 19 the designers and the time would meet with a 20 trip to decorate the house, just the timing 21 of it. 22 Q. So would Virginia be brought on 23 trips that were for the purpose of work and 24 decorating the house? 25 A. Like I said, I never worked with Page 147 1 G Maxwell - Confidential 2 her but you would have to ask Jeffrey what he 3 brought her on the trip for. 4 Q. But she would travel with him when 5 there was a work trip like this? 6 A. I can't -- I'm seeing that she is 7 on this flight but I have no idea what she is 8 doing, he invited her, it would not be my 9 job. 10 Q. What about would she 11 regularly travel with Jeffrey on flights? 12 A. I have no idea, you would have to 13 look through the flight logs. I have no 14 idea. 15 Q. Your recollection is -- what is 16 your recollection, do you recollect 17 traveling often on flights with Jeffrey? 18 A. Absolutely not. No, not at all. I 19 don't recollect her actually on the flight at 20 all. 21 Q. I think you can set that aside for 22 the moment. 23 (Maxwell Exhibit 9, message pad 24 pages, marked for identification.) 25 Q. We will mark as Exhibit 9 these Page 148 1 G Maxwell - Confidential 2 excerpts from -- we will identify what they 3 are but from the message pads. 4 Did you want to correct anything? 5 A. I want to make an addendum. 6 Would you mind rereading the last 7 question back to me? 8 (Record read.) 9 A. I also just want to say that at 10 this point I cannot recollect flying to 11 parties. Jeffrey went for work so -- was 12 this in Santa Fe, this flight as well. 13 Q. The flight we were looking at, yes 14 but it was to Santa Fe -- 15 A. I don't recall going to any parties 16 in Santa Fe at any time but certainly flying 17 to Santa Fe for a party seems highly 18 improbable. 19 Q. So I'm going to direct your 20 attention to the document that I set before 21 you which is Bates number and it 22 has different Bates numbers because it's a 23 smaller version of the larger production. 24 These are the pages I will be asking about. 25 In the time that you were working Page 149 1 G Maxwell - Confidential 2 with Jeffrey in Palm Beach, do you recall a 3 process for taking, anybody at the house 4 taking messages when incoming phone calls 5 came in? 6 A. You are supposed to take a message 7 and receive the message and write the message 8 down. Who was the message was for, what time 9 it was taken and who took it and what the 10 message was, obviously. 11 Q. Does what's in front of you look 12 familiar with respect to the message pads 13 that you would have used at the house? 14 A. It is familiar. 15 Q. I'm going to direct your attention 16 to the second page of it? 17 MR. PAGLIUCA: These all have SAO 18 numbers on them or Bates ranges and I 19 don't see any of your Bates ranges on 20 these. I know you have produced message 21 pads but those have your Bates range 22 numbers on them and I'm wondering if 23 these are different documents. 24 MS. McCAWLEY: It's the same, just 25 ours have the Bates underneath them. - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 39 of 106 39 (Pages 150 to 153) Page 150 1 G Maxwell - Confidential 2 These were produced as part of the rule 3 26 discovery. We can get the additional 4 Bates if you want. 5 Q. The one I'm asking about first is 6 the You can look at that and then 7 I will identify the Bates number referenced 8 in this case. 9 I want to direct your attention to 10 the top right-hand corner just so I have an 11 understanding of how these messages were 12 taken. So I see that it says at the top it 13 says in the for line it says Ms. Maxwell and 14 the date of 4/25/04 and then I see under the 15 M line it looks like Necole Hesse or 16 something like that, a phone number and a 17 message saying returning your call and on the 18 bottom it looks like 19 Explain to me, is this -- does this 20 represent Rushi taking down a message for you 21 from Ms. Hesse, is that how these work? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. Go ahead. 24 Q. My question is, I'm trying to 25 understand how the messages were taken. Page 151 1 G Maxwell - Confidential 2 Looking at this message pad, where it says 3 signed can you tell me who was? 4 A. I cannot. 5 Q. You do not know. 6 Typically when these messages were 7 taken in your practice when you were there, 8 would the individual who took the message 9 write their name on the message? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I don't recollect, you can ask who 13 wrote it so you can find out who it was. 14 Q. Do you know who Necole Hesse is? 15 A. I don't. 16 Q. I'm going to direct your 17 attention -- do we have a Bates number for 18 that? 19 MR. EDWARDS: 20 Q. Giuffre for that one. 21 I will direct your attention to the 22 first page which has the on it. 23 A. Okay. 24 Q. Now at the top of that document, on 25 the right-hand side, the message that reads Page 152 1 G Maxwell - Confidential 2 for JE, date 1/02/03, message Caroline Casey 3 and then it's signed GM. 4 Is that your signature? 5 A. That's not my handwriting. 6 Q. Would other people take a message, 7 how did this process work, is there someone 8 else in the house with the initials GM? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I cannot answer that. It's not my 12 handwriting. 13 Q. I'm trying to understand how this 14 gets there. If you took a message and didn't 15 write it down, would someone else record that 16 message for you? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. All I can tell you, this is not my 20 handwriting so I cannot -- I have no idea 21 what that is. 22 Q. Was the practice that, what was the 23 practice when someone answered the phone with 24 these message pads, what were they supposed 25 to do? Page 153 1 G Maxwell - Confidential 2 A. They were supposed to take a 3 message and the time and date and give the 4 message. 5 Q. Were they supposed to indicate who 6 took the message? 7 A. They were but it wasn't -- I don't 8 really recall the actual process. I can see 9 from here it looks like you were supposed to 10 but that's not my handwriting so I can't say 11 what that was. 12 Q. Do you know who Caroline Casey is? 13 A. No, I don't. 14 Q. Do you know whether Caroline Casey 15 was under the age of 18? 16 A. I just testified I couldn't 17 remember who she was so it would be difficult 18 to know how old she was. 19 Q. Do you know if she was coming to 20 the house to provide massages? 21 A. I don't remember who she is at all, 22 so no. 23 Q. And then I would like to direct 24 your attention to the message right 25 underneath it. Which says JE, Amanda - 1111 - - -- - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 40 of 106 40 (Pages 154 to 157) Page 154 1 G Maxwell - Confidential 2 and has a phone number and the message says, 3 wants to know if she should bring her friend 4 tonight. 5 What is that message referring to? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I can't possibly know. 9 Q. Did individuals at the house take 10 messages for underage girls to come over and 11 bring friends for the purpose of providing 12 massages? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. How would I possibly know what you 16 are talking about. 17 Q. Did you record messages at the 18 house? 19 A. It's not my job. 20 Q. You did from time to time record 21 messages? 22 A. Hardly ever. 23 Q. But you did from time to time do 24 it? 25 A. I'm just saying I hardly ever took Page 155 1 G Maxwell - Confidential 2 messages, very, very, very, very 3 infrequently. 4 Q. Do you know if Amanda brought her 5 friend over on that night? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. One, I don't know what this message 9 is, I don't know if I was in Palm Beach, I 10 don't know who Amanda is, I don't know who 11 is and I don't know what this message 12 is referring to. 13 Q. So on January 2nd of 2003, were you 14 in Palm Beach? 15 A. I don't know. 16 Q. Where would you have been other 17 than Palm Beach at the time? 18 A. I could have been anywhere. 19 Q. Where did you typically live? 20 A. What are you asking me? 21 Q. So for example, in 2003, where was 22 your primary residence, was it wherever 23 Jeffrey was living and staying or was it 24 independent of that? 25 A. What was the date again. Page 156 1 G Maxwell - Confidential 2 Q. In 2003? 3 A. The end of 2003? 4 Q. January, the beginning. 5 A. I don't know, I could have been 6 anywhere, Jeffrey and I were leading almost 7 separate lives by then. 8 Q. If you were at the house that day, 9 did you recall seeing anybody by the name of 10 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I don't know if I was at the house, 14 so I can't testify to that. 15 Q. Let's flip back to the next page, 16 the one we were on before the the 17 message towards the bottom that says, for 18 Jeffrey, message of Ghislaine. And it says, 19 Would it be helpful to have and then redacted 20 come to Palm Beach today to stay here and 21 help train new staff with Ghislaine. Who 22 were you referring to in that message; do you 23 remember? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 157 1 G Maxwell - Confidential 2 Q. The question is, do you recall this 3 message? 4 A. I do not recall this message. 5 Q. Do you recall training a female 6 under the age of 18 at Jeffrey's home? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I never trained a female under the 10 age of 18 at Jeffrey's home. 11 Q. Did you ever say it would be 12 helpful to have a female under the age of 18 13 come to Palm Beach today to stay here and 14 help train new staff with Ghislaine? 15 A. I never asked anyone under the age 16 of 18 come to help train new staff. 17 Q. I'm going to flip to the next page 18 which is . 19 A. By the way, that is not my 20 handwriting and it's not dated and I couldn't 21 possibly tell you who that is. 22 Did you hear that? 23 Q. You got your testimony on the 24 record. 25 2832. Ill - - - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 41 of 106 41 (Pages 158 to 161) Page 158 1 G Maxwell - Confidential 2 A. Yes. 3 MR. EDWARDS: Giuffre 4 Q. I'm going to direct your attention 5 to the top right-hand corner, for Mr. 6 Epstein, message a phone 7 number and called. 8 Do you know who is? 9 A. I don't. 10 Q. Do you know that was 15 at 11 the time she left this message? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I don't know who is. 15 Q. And then I'm going to direct your 16 attention to the bottom left which is a 17 message JE message of Jean Luc and the 18 message says, He just did a good one, 18 19 years, she spoke to me and said I love 20 Jeffrey. 21 Was Jean Luc referring to sex with 22 an 18 year old in that message? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. How could I know what Jean Luc is Page 159 1 G Maxwell - Confidential 2 referring to. 3 Q. Do you know if Jean Luc had sex 4 with an 18 year old that he referenced to 5 Jeffrey Epstein? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. How could I possibly know. 9 Q. Did Jeffrey Epstein or Jean Luc 10 ever tell you that Jean Luc had sex with an 11 18 year old? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I have no idea what you are talking 15 about. 16 Q. Did they ever tell you that? 17 A. I have no recollection of ever 18 hearing such a ridiculous thing. 19 Q. I will turn to the next page which 20 is SAO 2841? 21 MS. MENNINGER: Do you have the 22 Bates number? 23 Q. The bottom right-hand corner, Mr. 24 Epstein, the date Ms. Maxwell, it 25 says, it says, quote, is Page 160 1 G Maxwell - Confidential 2 available on Tuesday, no one for tomorrow. 3 Is this a message you took? 4 A. It's not my handwriting and I don't 5 know who R is. 6 Q. So when it says Ms. Maxwell in the 7 line there, is that you calling for Mr. 8 Epstein? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I didn't write it, I don't know 12 when this message was taken. I don't even 13 know what it's referring to and I don't know 14 what my name is doing on that message pad. 15 Q. I know you said you only took them 16 a few times. Do you have a recollection of 17 taking messages of females who would call the 18 house to indicate whether or not they were 19 coming over? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Give me a date range. 23 Q. On 7/9/04. 24 A. How would I know if I'm in Palm 25 Beach, most likely not. Page 161 1 G Maxwell - Confidential 2 Q. I'm asking if you have a 3 recollection of taking messages for girls who 4 would call the house -- 5 A. Girls. 6 Q. Females, who would call the 7 house -- 8 A. Over the age of 18. 9 Q. is 15. 10 A. I don't know who is, so I 11 can't testify anything to 12 Q. Your name is on the message. 13 A. I didn't put it there and I don't 14 know what it's doing there. 15 Q. So your testimony is you didn't 16 take this message? 17 A. I obviously didn't take the 18 message, it's signed by somebody R, it's not 19 my handwriting. We don't know if I'm in Palm 20 Beach. 21 Q. Did you arrange for to have 22 his friend come over on Tuesday of 23 this week? 24 A. I don't know who is so it 25 would be hard for me to arrange anything with - - - - - - 1111 - 1111 ~ _ _._ ____ 1111 __ ____. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 42 of 106 42 (Pages 162 to 165) Page 162 1 G Maxwell - Confidential 2 someone I don't know. 3 Q. Why is your name reflected on this 4 message pad? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I have no idea. You would have to 8 ask whoever took the message. 9 Q. Did you, in the course of your 10 work, regularly take messages for Jeffrey 11 Epstein? 12 A. I already testified I hardly ever 13 did. 14 Q. Would you, in the course of your 15 work, regularly set up appointments for 16 females to come over and give massages for 17 Jeffrey Epstein? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. Can you specify, females, you mean 21 adults over the age of 18. 22 Q. Did you regularly set up for 23 Jeffery adults over the age of 18 to come for 24 massages? 25 A. I didn't regularly do that, no. Page 163 1 G Maxwell - Confidential 2 Q. Would you take messages with 3 respect to females over the age of 18 to come 4 over for a massage? 5 A. I already testified I hardly ever 6 did take messages. 7 Q. But would you? 8 A. I already testified, I hardly 9 ever -- 10 Q. I know hardly ever, but did you? 11 A. Over the course of time it is 12 possible I may have taken a couple, I have no 13 recollection. I hardly ever did and I did so 14 irregularly that it would hard for me to 15 pinpoint. 16 Q. Did you ever take a message for a 17 female under the age of 18 to come over for a 18 massage or for any other reason to be with 19 Jeffrey Epstein? 20 MR. PAGLIUCA: Object to the form 21 and foundation. 22 A. I hardly ever took a message. I 23 have absolutely no way of knowing, maybe one 24 of my friends' daughters called to say they 25 were coming to visit me. I have never taken Page 164 1 G Maxwell - Confidential 2 messages, I don't know about how I would 3 possibly know if somebody I spoke to, one or 4 two times I took a message is, how old they 5 would be but I have never taken a message 6 where I was aware of anything being under the 7 age of 18 and I probably took it so 8 infrequently, it would be impossible. 9 Q. Can you turn to it 10 should be the next page. 11 A. Uh-huh. 12 Q. Do you see at the top, it says, for 13 Mr. J. 11/8/04 and then the name is 14 redacted. It says, I have a female for him. 15 Why would a minor be calling 16 Jeffrey to say they have a female for him? 17 Do you know? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. First of all, I don't know that's a 21 minor, I don't know who took the message. 22 Q. I will represent to you these are 23 police reports and minor's names have to be 24 redacted for privacy purposes? 25 MR. PAGLIUCA: Objection to the Page 165 1 G Maxwell - Confidential 2 form and foundation. 3 Q. Do you know why a minor child would 4 be calling Jeffrey and leaving a message to 5 say, quote, I have a female for him? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I can't testify anything about this 9 message, I don't know anything about it. 10 Q. I'm going to direct your attention 11 to the next page If you look at 12 the bottom left, you are going to see a 13 message for Jeffrey, from it 14 says she doesn't have a number and left a 15 message that she called. 16 Do you know who is? 17 A. I do not. 18 Q. Do you know that was 19 13 at the time she placed this call to 20 Jeffrey? 21 A. I don't know who is. 22 Q. Would Jeffrey regularly have 13 23 year olds call and leave messages? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 43 of 106 43 (Pages 166 to 169) Page 166 1 G Maxwell - Confidential 2 A. How would I possibly, these were 3 messages taken when I was not at the house 4 and I have no idea who they are nor how old 5 they are nor anything. 6 Q. How do you know you weren't at the 7 house on this day? 8 A. I was hardly at the house in 2005. 9 Q. So you could have been there, you 10 just don't know? 11 A. In the five days I might have been 12 there in 2005, I suppose it's possible but 13 it's unlikely. 14 MR. PAGLIUCA: Do you know why this 15 isn't redacted if you are representing 16 all the names of people who are underage 17 have been redacted from these records. 18 MS. McCAWLEY: I think it was -- my 19 assumption is it was a miss by the 20 police department. 21 Q. I will direct your attention to 22 so you will skip a page and go back, 23 it's the final page in the message pads and 24 you will see on the top left for Jeffrey, on 25 6/1/2005 from Jean Luc Brunel with a phone Page 167 1 G Maxwell - Confidential 2 number. It says, quote, He has a teacher for 3 you to teach you how to speak Russian. She 4 is two times eight years old. Not blond. 5 Lessons are free and you can have your first 6 today if you call. 7 Do you know whether Jean Luc Brunel 8 sent a Russian girl that was 16 years old 9 over to Jeffrey Epstein's home? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I do not know. 13 Q. Did you ever observe a Russian girl 14 that was 16 years old come to Jeffrey 15 Epstein's home? 16 A. I am not aware of any 16 year old 17 Russian girl that I can recall in Jeffrey 18 Epstein's home. 19 Q. Do you know whether Jeffrey Epstein 20 had sex with a 16 year old Russian girl? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I do not know. 24 THE VIDEOGRAPHER: It's 12:25. 25 This will be the end of disk 3, we are Page 168 1 G Maxwell - Confidential 2 off the record. 3 (Recess.) 4 A F T E R N O O N S E S S I O N 5 (Time noted: 1:21 p.m.) 6 G H I S L A I N E M A X W E L L, 7 resumed and testified as follows: 8 EXAMINATION BY (Cont'd.) 9 MS. McCAWLEY: 10 THE VIDEOGRAPHER: It's now 1:21, 11 we're starting disk No. 4. We are back 12 on the record. 13 Q. Ms. Maxwell, before the break, we 14 were talking about and I think it's one of 15 the exhibits that's marked in front of you, 16 I'm not sure of the number, but the police 17 report that I showed you earlier today. 18 Now that you have knowledge of the 19 police report and the criminal investigation 20 with respect to Jeffrey Epstein, do you 21 believe that Jeffrey Epstein abused any minor 22 children? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Can you repeat the question please Page 169 1 G Maxwell - Confidential 2 and break it down so it's more 3 understandable. 4 Q. Now that you have the police report 5 that I showed you this morning that you had 6 an opportunity to look at. 7 A. You gave it to me, I did not look 8 at it. 9 Q. The questions that I asked you 10 about the police report -- you are aware 11 there is a police report? 12 A. I am aware there is a police 13 report. 14 Q. You are aware there was a criminal 15 investigation of Jeffrey Epstein? 16 A. I am aware that there was that. 17 Q. Now that you are aware of those two 18 things and having talked to Jeffrey Epstein, 19 do you believe Jeffrey Epstein sexually 20 abused minors? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. Can you reask the second part of 24 that question please. 25 Q. Sure. The two documents we were - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 44 of 106 44 (Pages 170 to 173) Page 170 1 G Maxwell - Confidential 2 talking about, the document and the 3 investigation, you said you are aware of and 4 after having talked to Jeffrey Epstein, do 5 you believe Jeffrey Epstein sexually abused 6 minors? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. What do you mean I talked to 10 Jeffrey, you need to break the question down 11 further. 12 Q. So you have the police report. 13 A. I do. 14 Q. And you are aware of the criminal 15 investigation? 16 A. I am. 17 Q. Let's take those two things. After 18 knowing those two things, do you believe that 19 Jeffrey Epstein abused minor children? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Can you explain what you mean by 23 the question actually. 24 Q. I think the question speaks for 25 itself. I will try again. I will say it one Page 171 1 G Maxwell - Confidential 2 more time because I want you to be able to 3 understand it. 4 Knowing that you have the police 5 report here and knowing about the criminal 6 investigation, do you believe that Jeffrey 7 Epstein sexually abused minors? 8 MR. PAGLIUCA: Same objection. 9 A. I know what you put in front of me 10 and I know what I read. 11 Q. I'm asking what you believe, do you 12 believe Jeffrey Epstein sexually abused 13 minors? 14 A. I can only tell you what I read and 15 what you showed me. 16 Q. I'm asking what you believe, from 17 your own belief, do you believe that Jeffrey 18 Epstein abused minors? 19 A. I can only go from what I know 20 personally and what I know personally about 21 what Virginia's lies talked about. She is 22 the only person I know that actually claimed 23 that. And I can say with certitude that 24 everything Virginia said was a lie. 25 Q. You are aware Jeffrey Epstein was Page 172 1 G Maxwell - Confidential 2 sentenced for sexual abuse, are you aware of 3 that? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 Q. Are you aware that Jeffrey Epstein 7 served time for sexual abuse of a minor? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I don't believe that's what he was 11 sentenced for, actually. 12 Q. So you don't know that Jeffrey 13 Epstein served time for sexually abusing a 14 minor? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I don't believe that's what he was 18 sentenced for. 19 Q. Do you know that Jeffrey Epstein 20 was convicted for procuring a minor for 21 prostitution? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. I don't know exactly what he was 25 convicted of. I don't know that he was Page 173 1 G Maxwell - Confidential 2 convicted. I know he spent time in jail. 3 Q. Do you know that he spent time in 4 jail related to an issue with a minor child? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I did not know that. 8 Q. What did you think he was spending 9 time in jail for? 10 A. I only know he went to jail for -- 11 it was alleged that he hired -- had an 12 underage prostitute. 13 Q. So knowing that, do you believe 14 that Jeffrey Epstein sexually abused minors? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I can only tell you what he went to 18 jail for. 19 Q. I'm asking what you believe. I'm 20 not asking what he went to jail for. I'm 21 asking for your belief. 22 A. I cannot testify to what I believe. 23 I can only say what I have seen in the 24 reports and I know he went to jail. 25 Q. You can testify to what you MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 45 of 106 45 (Pages 174 to 177) Page 174 1 G Maxwell - Confidential 2 believe. Do you believe -- 3 A. I can only testify -- 4 Q. Let me finish the question so the 5 record is clear. 6 Do you believe Jeffrey Epstein 7 sexually abused minors? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 Q. You can answer. 11 A. I can only testify to what I know. 12 I know that Virginia is a liar and I know 13 what she testified is a lie. So I can only 14 testify to what I know to be a falsehood and 15 half those falsehoods are enormous and so I 16 can only categorically deny everything she 17 has said and that is the only thing I can 18 talk about because I have no knowledge of 19 anything else. 20 Q. I'm not asking about Virginia. I'm 21 asking whether you believe that Jeffrey 22 Epstein sexually abused minors? 23 A. Again, I repeat, I can only go on 24 what I know and what I know is a falsehood 25 based on what Virginia said. Page 175 1 G Maxwell - Confidential 2 Q. Do you believe Jeffrey Epstein 3 sexually abused minors? 4 A. Again, I repeat, Virginia is a liar 5 and based on Virginia's stories, that is 6 what -- she lied and I can only then talk 7 about what you've showed me in the police 8 reports and I know he went to jail. 9 Q. Do you believe that Jeffrey Epstein 10 sexually abused minors? I'm asking about 11 your belief. 12 A. Again, I just repeat, I can only 13 go -- my belief is Virginia is a liar. 14 Q. What is that belief? 15 A. She is an absolute liar and 16 everything she said is a lie and therefore, 17 everything that stems from that is a lie. 18 Q. So do you believe that Jeffrey 19 Epstein sexually abused minors? 20 A. Again -- can we move on from here? 21 Q. No. You are going to answer the 22 question. 23 A. I have already. 24 Q. No, you haven't. 25 A. I have. Page 176 1 G Maxwell - Confidential 2 Q. Do you believe Jeffrey Epstein 3 sexually abused minors? 4 A. Again, I repeat, the only person I 5 know who has talked about these things that I 6 have personal -- was personally present, was 7 Virginia and I can only talk to Virginia and 8 she is a liar. 9 Q. Setting aside Virginia. Take her 10 out of the picture. It's my question. 11 A. We are here today because of 12 Virginia and her lies because this is a 13 defamation suit. 14 Q. Setting aside Virginia, do you 15 believe Jeffrey Epstein sexually abused 16 minors? 17 A. I cannot set aside Virginia because 18 that's why we are here and this is the only 19 reason I am sitting here in this room and I 20 will not set her aside and I cannot comment 21 about anything else except her because she is 22 the only person I actually know about. 23 Q. Are you refusing to answer that 24 question? 25 A. I am not refusing the question. I Page 177 1 G Maxwell - Confidential 2 can only testify about Virginia who is an 3 absolute total liar and you all know she is. 4 She lied about her age, you know she lied 5 about absolutely everything. So I can only 6 go on what I know as a liar and she is a 7 liar, an exaggerator, a fantasist and 8 absolutely true terrible person. 9 Q. I want you to listen very 10 carefully. I am asking you to set aside 11 Virginia. 12 A. I can't set aside Virginia. 13 Q. I am asking you to do that for 14 purposes of this question. 15 MR. PAGLIUCA: She doesn't have to. 16 MS. McCAWLEY: She can refuse to 17 answer the question. 18 A. I'm not refusing to answer the 19 question. 20 Q. You are refusing. 21 My question has nothing to do with 22 Virginia. Let me make the record here. My 23 question has nothing to do with Virginia. I 24 want it to be clear for the court. My 25 question has nothing to do with Virginia. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 46 of 106 46 (Pages 178 to 181) Page 178 1 G Maxwell - Confidential 2 What I'm asking you is whether you 3 believe Jeffrey Epstein abused minors? 4 MR. PAGLIUCA: I object to the form 5 and you made your record, she answered 6 the question. A fair reading of her 7 answer is she doesn't have a belief 8 because she doesn't have any personal 9 knowledge. 10 MS. McCAWLEY: Now you are 11 testifying for the witness. Let her 12 answer the question. 13 MR. PAGLIUCA: It's a fair answer 14 to the question. 15 A. Again, I testified my only personal 16 knowledge concerns Virginia and everything 17 Virginia has said is an absolute lie, which 18 is why we are here in this room. If you are 19 asking me to testify about things I have no 20 knowledge of other than the police report 21 that you showed me, I am not in a position to 22 make a statement based on that because you 23 are asking me to speculate and I cannot 24 speculate. 25 Q. I'm asking you about your belief. Page 179 1 G Maxwell - Confidential 2 I'm not asking you to speculate at all. I'm 3 asking what you believe. 4 A. You are asking me to speculate and 5 I won't speculate. 6 Q. I'm not asking you to speculate. 7 I'm asking what you believe. 8 MR. PAGLIUCA: She answered the 9 question and we can move on. 10 MS. McCAWLEY: She hasn't answered 11 the question. 12 MR. PAGLIUCA: We are not going to 13 engage in this debate. She answered the 14 question. If you want to mark it and 15 move to compel an answer to the 16 question, have at it. Okay. 17 Q. Ms. Maxwell, is it your belief that 18 Jeffrey Epstein interacted sexually with 19 minors? 20 A. Again, you are asking me the same 21 type of question exactly but with different 22 language. Again, my only knowledge of 23 somebody who claims these things that I have 24 personal knowledge of is Virginia. Virginia 25 is an absolute liar and everything she has Page 180 1 G Maxwell - Confidential 2 said is a lie. Therefore, based on those 3 lies I cannot speculate on what anybody else 4 did or didn't do because if Virginia is the 5 example of what that story is and everything 6 she said is false, so everything that leads 7 from that is false. 8 Q. So the 30 other minor children in 9 the police report are also telling lies about 10 being sexually abused during massages with 11 Mr. Epstein? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. Counsel, can you 14 show me in these police reports who the 15 30 minors are? 16 MS. McCAWLEY: I'm asking my 17 question. 18 MR. PAGLIUCA: You are making a 19 representation about numbers, you are 20 making a representation on the record 21 about what people said or didn't say. 22 We have no knowledge about that. These 23 are all redacted records so these are 24 bad questions. They don't lead to any 25 admissible evidence. It is only being Page 181 1 G Maxwell - Confidential 2 propounded to the witness to harass her. 3 So we are done with these questions. 4 MS. McCAWLEY: Are you done? 5 MR. PAGLIUCA: Yes. 6 Q. My question is, are you aware that 7 Jeffrey Epstein was convicted of having 8 relations with a minor child? 9 MR. PAGLIUCA: She answered that 10 question already. 11 MS. McCAWLEY: I'm getting to my 12 next question. 13 MR. PAGLIUCA: Ask your next 14 question. Don't keep asking the same 15 question. 16 MS. McCAWLEY: You are now 17 shouting, I want the record to reflect 18 that you are interrupting the 19 deposition. I ask you to calm down, 20 take a deep breath and please let me ask 21 my questions. 22 MR. PAGLIUCA: Your behavior is 23 inappropriate. 24 Q. I will ask you again. 25 Do you believe that Jeffrey Epstein MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 47 of 106 47 (Pages 182 to 185) Page 182 1 G Maxwell - Confidential 2 interacted sexually with minors? 3 A. Again, I go back to this, my only 4 actual knowledge is with Virginia and 5 Virginia is a liar, so I can only talk to 6 what Virginia's story and as I said before 7 and there are so many examples, I mean 8 thousands of examples of her lies, that that 9 is the only thing I can talk to. 10 Q. Based on that you do not believe 11 that Jeffrey Epstein sexually abused minors? 12 A. Again, as I said, I'm only talking 13 to what I know, I can only talk to Virginia. 14 Q. So is it your belief that Jeffrey 15 Epstein did not sexually abuse minors? 16 A. Again, I can only talk to what I 17 know and I know that Virginia is a liar and 18 that what she said is a lie. So I can only 19 testify to what she accused and you guys put 20 in the press for salacious purposes and 21 whatever terrible, inappropriate, unethical 22 and terrible reasons you chose to do that 23 about me and I can testify those are all 24 lies. 25 Q. Do you know whether Jeffrey Epstein Page 183 1 G Maxwell - Confidential 2 sexually abused any minor children? 3 A. Again, I only know 1000 percent 4 that Virginia is a liar. I can only talk to 5 Virginia, her lies and your inappropriate, 6 unethical, really unattractive, terrible use 7 of her and the way that you have abused the 8 system, used the press for purposes that are 9 unethical, inappropriate and appalling. 10 Q. Do you believe that Jeffrey Epstein 11 used massages to lure minors to have sex with 12 him? 13 A. Again, that is Virginia's 14 testimony, which is a lie. 15 Q. But do you believe that? 16 A. Again, I refer back to Virginia. 17 Q. I'm asking whether you believe it 18 or not? 19 A. I can only go with what I know and 20 I know Virginia is a liar and therefore 21 that's a lie. 22 Q. So you don't believe that? 23 A. I said, I only know that Virginia 24 is lying. 25 Q. Are you aware that Jeffrey Epstein Page 184 1 G Maxwell - Confidential 2 is a registered sex offender? 3 A. I am. 4 Q. Are you aware that Jeffrey Epstein 5 paid considerable amounts of money to settle 6 lawsuits with the minor children that he had 7 sexual contact with? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I have no knowledge of those 11 issues. 12 Q. Why did you continue to maintain 13 contact with Jeffrey Epstein after he pled 14 guilty? 15 A. I'm a very loyal person and Jeffrey 16 was very good to me when my father passed 17 away and I believe that you need to be a good 18 friend in people's hour of need and I felt 19 that it was a very thoughtful, nice thing for 20 me to do to help in very limited fashion 21 which was helping if he had any issue with 22 his homes, in terms of the staffing issues. 23 It was very, very minor but I felt it was 24 thoughtful in somebody's hour of need. 25 Q. Did he continue to pay you during Page 185 1 G Maxwell - Confidential 2 that time period? 3 A. I was paid a little. 4 Q. You were paid? 5 A. Yes. 6 Q. When you say a little, what you did 7 mean by that? 8 A. I don't recall exactly the amount. 9 Q. So in 2009 when you left him, what 10 were you being paid? 11 A. I just told you, I don't recall. 12 Q. Were you being paid $100,000? 13 A. I just don't you I don't recall. 14 Q. Were you paid over a million 15 dollars? 16 A. I think I would remember over a 17 million dollars. 18 Q. So it was under a million dollars? 19 A. It was under a million dollars. 20 Q. Was it over $500,000? 21 A. I just told you, it was under 500, 22 it was an amount of money less than $500,000, 23 less than a million dollars and I did it out 24 of thoughtfulness and consideration for 25 somebody who was in trouble. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 48 of 106 48 (Pages 186 to 189) Page 186 1 G Maxwell - Confidential 2 Q. Did you have an attorney to consult 3 with during the criminal investigation of 4 Jeffrey Epstein? 5 A. I don't believe I did. 6 Q. When did you learn that a search 7 warrant was executed for the Palm Beach 8 house? 9 A. I don't recall exactly. 10 Q. Were you present at the house in 11 advance of the search warrant being executed? 12 MR. PAGLIUCA: Object to the form 13 of the question. 14 A. I don't remember when the search 15 warrant was executed and I don't remember the 16 year that the search warrant was executed and 17 whenever that was, I already testified, I was 18 very, very infrequently at the house. So 19 highly unlikely but I was there a couple of 20 days, I just don't know which days it was in 21 relation to the police situation. 22 Q. Did you have a computer at the Palm 23 Beach home that was a computer that you would 24 use? 25 A. No. Page 187 1 G Maxwell - Confidential 2 Q. Was there a computer available for 3 use in the Palm Beach house? 4 A. Can you be more specific. 5 Q. Was there anywhere in the Palm 6 Beach house where there was a computer where 7 you said you worked for him and there were 8 other staff in the house, was there ever a 9 computer in the Palm Beach mansion that was 10 accessible by you or other staff? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I stopped being regularly at the 14 house sometime in 2003 so from 2003 to when 15 the police search was executed, I have no 16 memory of what there was or what there was 17 not. I can only testify for what was there 18 when I was present largely. 19 Q. So in 2003 when you were still 20 there, was there a computer that was 21 accessible to you or other staff at the 22 house? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. There was a desktop computer that Page 188 1 G Maxwell - Confidential 2 people could use -- just like you would use 3 if you needed to go online to get something, 4 that people could use. 5 Q. Was that on a desk that you would 6 use in your work capacity when you were at 7 the house? 8 A. It was a desk, it was a room I was, 9 I didn't really use that computer. 10 Q. Were there images of naked girls 11 whether they be under the age of 18 or over 12 the age of 18 on that computer? 13 A. I have no recollection of any naked 14 people on that computer when I was there in 15 2003, we are talking. 16 Q. What about from say '99 to 2003? 17 A. No, I can't recollect any naked 18 pictures. 19 Q. Why were the computers removed from 20 the house before the search warrant was 21 executed? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. I have no knowledge of anything 25 like that. Page 189 1 G Maxwell - Confidential 2 Q. Do you know where the computers are 3 now? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I don't know what computers you are 7 talking of and I have no idea what you are 8 referencing. 9 Q. In 2003 you said there was a 10 computer in a room on a desk? 11 A. Right. 12 Q. Do you know where that computer is 13 now? 14 A. I do not. 15 Q. Did you take pictures of nude 16 females in any of Epstein's homes or in and 17 around the homes, out by the pool or anywhere 18 like, in the Palm Beach home, the New York 19 home, USVI home or the New Mexico home? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Can you repeat the question. 23 Q. Did you take pictures of nude woman 24 over 18 or under 18, females, in any of 25 Jeffrey Epstein's homes, inside or outside in MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 49 of 106 49 (Pages 190 to 193) Page 190 1 G Maxwell - Confidential 2 or around the home? 3 A. I think we need to distinguish 4 between anyone under the age of 18 and over 5 the age of 18. 6 Q. We will start with, did you take 7 pictures of nude females in or around any of 8 Jeffrey's homes of women or females that were 9 under the age of 18? 10 A. No. 11 Q. Did you take pictures of nude 12 females -- 13 A. Nude you mean with no clothing on. 14 Q. Or half nude, with no top on, any 15 sort of nakedness to an individual. 16 In any of Jeffrey's homes, either 17 Palm Beach, New Mexico, USVI or New York 18 either outside by the pool, anywhere in or 19 around those homes of females over the age of 20 18? 21 A. So it is possible that I took 22 pictures of people that were somehow semi or 23 had some clothing on or no clothes on but at 24 no time were any of these pictures remotely 25 inappropriate. They were, you could see them Page 191 1 G Maxwell - Confidential 2 in a mainstream magazine today, there would 3 be no inappropriateness, they would be 4 covered, concealed, you wouldn't see anything 5 at all. 6 The types of -- first, I took very 7 few and they were always by request, this was 8 a picture you could put on your -- gift to 9 your parent or to your grandparents to put on 10 their mantel piece . It would be a very 11 benign sort of attractive picture where you 12 wouldn't see anything. 13 Q. Who would request those pictures? 14 A. From time to time, people, men and 15 women would ask to have nice photographs of 16 them taken. 17 Q. And did Jeffrey Epstein request 18 those pictures? 19 A. I don't ever recall him asking me 20 to take pictures. 21 Q. Did you give him pictures of naked 22 females as a present? 23 A. I don't recall ever giving a 24 present of -- I don't know why a photograph 25 would constitute a gift. Page 192 1 G Maxwell - Confidential 2 Q. Not as a gift. 3 Do you recall ever giving Jeffrey 4 Epstein pictures that you've taken of these 5 individuals in a naked state? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. First of all, we've already 9 established that they are not naked state 10 photographs. 11 Q. A piece of them being naked as you 12 described. 13 A. I said they would be attractive as 14 you would see in mainstream magazines and 15 those pictures could be a picture of a hand 16 or a foot, they didn't necessarily 17 constitute -- I know where you are headed 18 with this and it's nowhere appropriate and 19 it's really unattractive. 20 Q. I'm not headed anywhere. I'm just 21 asking the questions. Did you give Jeffrey 22 Epstein any of these pictures that you took 23 of females in the state that you described? 24 A. I can't recall ever giving him 25 pictures but it is possible that I took Page 193 1 G Maxwell - Confidential 2 pictures of people that would end up -- or a 3 friend of his that he would have -- not naked 4 or not inappropriate in any way, that he 5 might have somewhere in his house. 6 Q. Name for me all the individuals who 7 you took these pictures of? 8 A. It's entirely impossible for me to 9 name people. First of all, it was just -- it 10 would not be possible, I took thousands of 11 photos, not of people, I mostly take pictures 12 of landscapes and things. I have no 13 recollection specifically of people that I 14 took pictures of. 15 Q. So you can't remember, is it your 16 testimony you can't remember one person that 17 you took a picture of in either a naked or 18 semi naked state? 19 A. I seriously cannot recall. I just 20 don't recall. 21 Q. Did you take a picture of Virginia 22 Roberts either alone or with another 23 individual in a naked state? 24 A. I have never taken, I believe, any 25 pictures of two people in any type of MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 50 of 106 50 (Pages 194 to 197) Page 194 1 G Maxwell - Confidential 2 situation, naked as you describe. 3 Q. Did you take a picture of Virginia 4 Roberts on her own without another individual 5 in it in a naked state? 6 A. I don't recall ever taking a 7 picture of Virginia -- naked, we are not 8 referring to someone with no clothing on at 9 all, we are referring to someone that could 10 be semi clad or could have a towel or we are 11 not referring to anything inappropriate. 12 Q. Was this a hobby of yours to take 13 pictures of the type that you are describing? 14 MR. PAGLIUCA: Object to the form. 15 A. I just testified, I didn't take 16 pictures of many people. My preference is 17 pictures for landscapes and for architectural 18 pieces. 19 Q. Where are those pictures today? 20 A. I have no idea. 21 Q. Do you have them in your home? 22 A. I do not. 23 Q. Do you have them on your computer? 24 A. I do not. 25 Q. What has Jeffrey Epstein told you Page 195 1 G Maxwell - Confidential 2 about the allegations related to the criminal 3 investigation that he was involved in? 4 A. I really can't say, not because I 5 don't want to say but I just think of what he 6 has said to me over the course of this time. 7 Q. Did he explain it to you and 8 explain what the charges were against him? 9 A. I never had a detailed conversation 10 with him, as I recall. 11 Q. Not detailed, just did he explain 12 anything that was happening to him? 13 A. I haven't spoken to him for so 14 long. I can't possibly testify to what 15 conversations I had with him over the course 16 of time. 17 Q. Did he talk to you about any of the 18 girls that were making allegations against 19 him other than Virginia? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. You are talking about the police 23 records again, all of that? 24 Q. Yes. 25 A. I have never had a conversation Page 196 1 G Maxwell - Confidential 2 about those things. 3 Q. What has Jeffrey Epstein told you 4 about Virginia Roberts? 5 A. That she is a liar. 6 Q. What does he base that on? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. You would have to check with him. 10 I can tell you why I think she is a liar, I'm 11 happy to do that. 12 Q. Did he tell you he did not have 13 sexual relations with Virginia Roberts? 14 A. I can only testify what I know. 15 Q. I'm asking, has he told you that he 16 did not have sexual relations with Virginia 17 Roberts? 18 A. I can only tell you what I know 19 about Virginia Roberts, I cannot tell you 20 what he knows about Virginia Roberts. 21 Q. I'm asking, did he tell you that he 22 did not have sexual relations with Virginia 23 Roberts? 24 A. All he told me is she is a liar. 25 Q. That's all he said about Virginia Page 197 1 G Maxwell - Confidential 2 Roberts? 3 A. We went through all the lies that 4 you have sold to the papers and sold in 5 general and we have analyzed her lies and 6 your lies and your inappropriate behavior in 7 detail. 8 Q. Did he ever say that he did not 9 have sexual relations with Virginia Roberts? 10 A. I just testified that we went 11 through all of her lies. 12 Q. I understand what you said. I'm 13 asking you a question. 14 Did he ever tell you that he never 15 had sex with Virginia Roberts? 16 A. I don't recall whether he ever -- I 17 don't know I ever had that question. We 18 focused on the lies she did say she had with 19 him as relates to me. I don't remember 20 asking him about his problems with her. I'm 21 interested in what she says about myself. 22 Q. Did you also talk about what things 23 that Virginia Roberts was saying that were 24 true? 25 A. There isn't anything that she said MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 51 of 106 51 (Pages 198 to 201) Page 198 1 G Maxwell - Confidential 2 that was true. 3 Q. Nothing she said that you are aware 4 of is true? 5 A. I think she is correct when she 6 talks about what her name is. 7 Q. Anything else? 8 A. I'm sure there must be one or two 9 other details but they are so far and few 10 between, I would have to look in detail at 11 all of her allegations to pinpoint what 12 possibly could be true. 13 Q. Did you ever ask Jeffrey if he had 14 sex with minors? 15 A. I have never been asked that 16 question. 17 Q. You never asked him that question. 18 What analysis did Jeffrey do to 19 determine that the statements Virginia 20 Roberts were making were lies? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. Ask me again, please. 24 Q. What analysis did Jeffrey do to 25 determine that the statements that Virginia Page 199 1 G Maxwell - Confidential 2 Roberts were making were lies? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. And to the extent 5 that any of this answer calls for any 6 privileged communication, I'm 7 instructing, with myself or another 8 lawyer representing you or in any common 9 interest agreement, I'm instructing you 10 not to answer. 11 MS. McCAWLEY: The court ruled she 12 is entitled and you had to produce 13 documents about communications with 14 Jeffrey, that's what I'm asking about. 15 I'm not asking about communications with 16 lawyers. 17 Q. I'm asking what analysis did 18 Jeffrey do to determine that the statements 19 that Virginia Roberts was making were lies, 20 if you know? 21 MR. PAGLIUCA: My objection is to 22 the extent she learned any of that 23 information as a result of either a 24 privileged communication from a lawyer, 25 one of her lawyers or a privileged Page 200 1 G Maxwell - Confidential 2 communications subject to a joint 3 defense agreement or common interest 4 agreement, I'm telling her not to 5 answer. To the extent she has 6 information outside of those things, she 7 is permitted to answer. 8 Q. Do you understand? 9 So if it was a conversation with a 10 lawyer which I'm not asking about, I don't 11 want you to tell me about your conversations 12 with lawyers. 13 I want you to tell me whether 14 Jeffrey Epstein ever told you what he 15 analyzed in order to determine which of -- of 16 what Virginia were saying were lies? 17 A. I do not know what he did, no. 18 So you agree she is lying, Singrid. 19 Q. I do not agree with that and I'm 20 asking the questions. 21 A. You just said her lies. 22 Q. I'm repeating a statement you made. 23 Q. Are you saying it's an obvious lie 24 that Jeffrey Epstein engaged in sexual 25 conduct with Virginia while Virginia was Page 201 1 G Maxwell - Confidential 2 underage? 3 A. I can only testify to what I saw 4 and what I was present for, so if you are 5 asking me what I saw then I am happy to 6 testify. I cannot testify to what somebody 7 else did or didn't do. 8 Q. Did you issue a statement to your 9 press agent, Ross Gow in 2015, stating that 10 Virginia Roberts' claims were, quote, obvious 11 lies? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 Q. You can answer. 15 A. You need to reask me the question. 16 Q. Sure. 17 Did you issue a press statement 18 through your press agent, Ross Gow, in 19 January of 2015, stating that Virginia 20 Roberts' claims were, quote, obvious lies? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. Can you ask it a different way, 24 please? 25 Q. I will ask it again and you can MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 52 of 106 52 (Pages 202 to 205) Page 202 1 G Maxwell - Confidential 2 listen carefully. 3 Did you issue a press statement 4 through your press agent, Ross Gow, in 5 January of 2015, where you stated that 6 Virginia Roberts' claims were, quote, obvious 7 lies? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. So my lawyer, Philip Barden 11 instructed Ross Gow to issue a statement. 12 Q. Today, did you say that Virginia 13 lied about, quote, absolutely everything? 14 A. I said that there are some things 15 she may not have lied about. 16 Q. So are you saying it's an obvious 17 lie that Jeffrey Epstein engaged in sexual 18 contact with Virginia while Virginia was 19 underage? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Can you ask the question again, 23 please? 24 Q. Are you saying it's an obvious lie 25 that Jeffrey Epstein engaged in sexual Page 203 1 G Maxwell - Confidential 2 conduct with Virginia while Virginia was 3 underage? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 Q. You can answer. 7 A. Try again, please. 8 Q. Are you saying that it's an obvious 9 lie that Jeffrey Epstein engaged in sexual 10 conduct with Virginia while Virginia was 11 underage? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. Again, I'm telling you, first of 15 all, it was a statement that was issued by my 16 lawyer and -- through my lawyer to Ross Gow. 17 Q. I understand that. I'm asking you, 18 are you saying that it's an obvious lie that 19 Jeffrey Epstein engaged in sexual conduct 20 with Virginia while Virginia was underage. 21 Is that a lie? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 Q. You can answer. 25 A. So I cannot testify to what Ross Page 204 1 G Maxwell - Confidential 2 Gow and Philip Barden decided to put -- I can 3 testify to what Virginia's obvious lies are 4 as regards to me. I cannot make 5 representations about all the many lies she 6 may or may not have told about Jeffrey. 7 Q. So is Virginia lying when she says, 8 is it an obvious lie when she says that she 9 had sex with Jeffrey Epstein while she was 10 underage? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. Again, I'm testifying to what I 14 know to be true. I can only testify to all 15 the many lies she told about me. I cannot 16 testify to what lies she told about somebody 17 else. Given she told so many about me, one 18 can probably infer she is lying about 19 everything. 20 Q. So you think she is lying when she 21 said she had sex with Jeffrey Epstein when 22 she was underage? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Again, I can only talk about what I Page 205 1 G Maxwell - Confidential 2 can positively say myself, not what somebody 3 else is going to represent. 4 Q. When you were saying that she was, 5 her claims of having sex with Jeffrey Epstein 6 were obvious lies, are you saying she is 7 lying about engaging in sexual conduct with 8 Jeffrey Epstein when she was underage? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 Q. You can answer. 12 A. Again, this was a statement that 13 was put out from my lawyer through my press 14 person in London. And I can only testify to 15 the obvious lies that she says about me. I 16 cannot make representations about lies she 17 says about someone else, but she lies so many 18 times about me, one can probably infer she is 19 lying about everything. 20 Q. So is she not lying when -- is she 21 telling the truth when she says she had sex 22 with Jeffrey Epstein when she was underage? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Again, I don't know how else to MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 53 of 106 53 (Pages 206 to 209) Page 206 1 G Maxwell - Confidential 2 tell you, I can only talk about what I know 3 to be true. What I know is her story about 4 how she claims that initial situation 5 happened is so egregiously false and such a 6 giant fat enormous, repulsive, disgusting, 7 inappropriate, vile lie, that that I can 8 testify to. 9 Q. Was she lying when she said she met 10 you at Mar-a-Lago? 11 A. Again I already testified I don't 12 recall meeting her at Mar-a-Lago. 13 Q. We showed you a document where you 14 said you met her at Mar-a-Lago when she was 15 17, is that correct? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. I think I already testified to 19 that. What I remembered based on all the 20 rubbish she has written and all the many 21 articles I have read, maybe in the moment 22 when I wrote that, have caused me to have 23 that but on reflection I don't recall it as I 24 sit here today. 25 Q. Are you saying that it was an Page 207 1 G Maxwell - Confidential 2 obvious lie that you approached Virginia 3 while she was under age at Mar-a-Lago? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. First of all, we can all agree 7 here, all of you sitting here that the lies 8 that you perpetrated in the press that she 9 was 15 and we should all agree now that that 10 is fake, a lie that was perpetrated between 11 all of you to make the story more exciting, 12 can we agree on that? 13 Q. That is not my question. 14 A. Can we agree she was not the age 15 she said and you put that in the press, that 16 is obviously, manifestly, absolutely, totally 17 a lie. 18 MS. McCAWLEY: I am going to put on 19 the record, Ms. Maxwell very 20 inappropriately and very harshly pounded 21 our law firm table in an inappropriate 22 manner. I ask she take a deep breath, 23 and calm down. I know this is a 24 difficult position but physical assault 25 or threats is not appropriate, so no Page 208 1 G Maxwell - Confidential 2 pounding, no stomping, no, that's not 3 appropriate,. 4 A. Can we be clear, I didn't threaten 5 anybody. 6 MR. PAGLIUCA: Stop, you made your 7 record, there is no dent in the table. 8 I don't see any chips. Can we take a 9 break now. 10 MS. McCAWLEY: I think it's 11 appropriate to take a break. 12 THE VIDEOGRAPHER: It's 1:56 and we 13 are off the record. 14 (Recess.) 15 THE VIDEOGRAPHER: It's now 2:13, 16 we're starting disk No. 5 and we are 17 back on the record. 18 Q. Ms. Maxwell, how old was Virginia 19 Roberts when you met her in Mar-a-Lago? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I know today that she was 17 years 23 old. 24 Q. Are you saying that it's an obvious 25 lie that Virginia traveled on Jeffrey Page 209 1 G Maxwell - Confidential 2 Epstein's airplanes? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 Q. You can answer. 6 A. Are you referring to my statement 7 where that says that? 8 Q. I'm referring to the language you 9 use in your statement that says, obvious 10 lies? 11 A. Can you read my entire statement? 12 Q. Sure, let me pass it out. 13 (Maxwell Exhibit 10, email,marked 14 for identification.) 15 Q. This is Bates GM 00068 and we will 16 mark it as -- what you have in front of you 17 is a statement at the top. This was produced 18 by your counsel, it is indicated Bates No. 19 GM 00068. At the top the date reflects 20 January 2, 2015 from, appears to be a Ross 21 subject line, is you and 22 then there is a number of individuals you can 23 see at the top that are copied on this that 24 is sent to and bcc'd on this statement. 25 The statement, there are two parts I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 54 of 106 54 (Pages 210 to 213) Page 210 1 G Maxwell - Confidential 2 of it. There is an opening email that says, 3 please find an attached quotable statement on 4 behalf of Ms. Maxwell and there is more 5 language there and it's from Ross Gow and 6 then it says in the body of it, Jane Doe No. 7 3 or Jane Doe 3 is Virginia Roberts so not a 8 new individual. The allegations made by, and 9 it says Victoria but I believe that means 10 Virginia Roberts, against Ghislaine Maxwell 11 are not true. The original allegations are 12 not new and have been fully responded to and 13 shown to be untrue. And the next paragraph 14 says, Each time the story is retold, it 15 changes with new salacious details about 16 public figures and world leaders and now it 17 is alleged by Ms. Roberts that Al Dershowitz 18 is involved in having sexual relations with 19 her which he denies. Ms. Roberts claims are 20 obvious lies and should be treated as such 21 and not publicized as news as they are 22 defamatory. 23 The last paragraph states, 24 Ghislaine Maxwell's original response to the 25 lies and defamatory claims remains the same. Page 211 1 G Maxwell - Confidential 2 Maxwell strongly denies allegations of the -- 3 strongly denies allegations of an unsavory 4 nature which have appeared in the British 5 press and elsewhere and reserves her right to 6 seek redress at the repetition of such old 7 defamatory claims. 8 Are you saying that it's an obvious 9 lie that Virginia Roberts traveled on Jeffrey 10 Epstein's planes? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I'm saying what's an obvious lie 14 and I think we can all agree, you just had 15 the case tossed out by Alan Dershowitz. He 16 just got removed from the case because you 17 put him in a case that he wasn't supposed to 18 be in so what was said about him is not true. 19 Q. Are you saying that it's an obvious 20 lie that Virginia Roberts traveled on Jeffrey 21 Epstein's plane? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. You have given me plane records 25 that has her name on it but as I already Page 212 1 G Maxwell - Confidential 2 testified those aren't federally mandated 3 things and I can see her name on it but 4 that's what I -- I told you I don't recall 5 her on any planes. 6 Q. Is is that one of Virginia's 7 obvious lies? 8 A. There are more obvious ones. 9 Q. Is that one of them? 10 A. I can't testify to her being on a 11 plane or not. 12 Q. So is that an obvious lie? 13 A. There are more obvious lies, like 14 Clinton. 15 Q. I understand there are more obvious 16 ones. I'm asking you, is the fact that she 17 said she traveled on Epstein's planes an 18 obvious lie? 19 A. I think we can probably say because 20 you see her name on a plane record and she 21 went from A to B, that would not be the 22 obvious lie that I would pick. 23 Q. What obvious lie were you picking 24 when you made this statement? 25 A. There are so many that I would be Page 213 1 G Maxwell - Confidential 2 thrilled to go through all of them. 3 Q. Let's go through them. 4 What's the first one? 5 A. Her characterization of the first 6 meeting at Mar-a-Lago. 7 Q. What part of that was an obvious 8 lie? 9 A. The characterization that she said 10 that she said she was accosted. She looked 11 like, as best as I can recall, if I met her 12 in Mar-a-Lago as she claims, she worked at 13 Mar-a-Lago, she claims, and her statement she 14 worked at Mar-a-Lago, she would have been 15 dressed as all the spa people in Mar-a-Lago 16 would have been. It would have been 17 impossible to identify her as someone other 18 than someone who worked at a spa. She made 19 many claims, she has been a bathroom 20 attendant, front of house attendant, we don't 21 know what she was, so her obvious lies are 22 her contradictory of her own personal 23 statements within that. 24 Q. So what part of her statement 25 relating to Mar-a-Lago -- MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 55 of 106 55 (Pages 214 to 217) Page 214 1 G Maxwell - Confidential 2 A. I'm carrying on. 3 Q. I'm sorry. I thought you were 4 done. 5 A. Please. Her statement also that 6 she was driven by her father to Palm Beach. 7 She was driven by her mother, as a matter of 8 fact. Her whole entire characterization of 9 the first meeting with Jeffrey, as I was 10 outside speaking to her mother. 11 Q. Let me stop you there, so we don't 12 get too far ahead. Let me make sure I 13 understand your testimony. 14 The first, in the first piece when 15 you were talking, I believe you said and 16 correct me if I'm wrong, that her 17 characterization of the first meeting at 18 Mar-a-Lago was an obvious lie. 19 What part of that meeting was an 20 obvious lie? 21 A. By her own testimony, all her 22 various many different descriptions of what 23 she was or wasn't or where she was or wasn't, 24 they have all changed. She was either front 25 of house or bathroom attendant. I don't know Page 215 1 G Maxwell - Confidential 2 what she was, so just by her own words, one 3 doesn't know what's true and what isn't true. 4 Q. Are you saying what position she 5 said she was working in, is that what you are 6 considering the obvious lie? 7 A. I said inconsistency within her own 8 statement from everything, so in the 9 beginning it starts off with different 10 statements. 11 Q. Then I believe you said the second 12 piece was that she was driven by her father? 13 A. I said she was driven by her 14 mother. 15 Q. That's the obvious lie? 16 A. It's an obvious lie to me. 17 Q. You said why don't you state it in 18 your own words but the characterization of 19 how she was with Jeffrey, what about that is 20 an obvious lie? 21 A. I was standing outside talking to 22 her mother so the entire story is a 23 fabrication. 24 Q. Did she not have sex with Jeffrey 25 Epstein during that first massage? Page 216 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I was talking to her mother so... 5 Q. Do you know whether that's an 6 obvious lie, whether she had sex in that room 7 or not? 8 A. Her story about what happened -- 9 let's also be -- the story as first hit the 10 press was that somebody else led her to 11 Jeffrey's room, it was not me and then it 12 turned to being me so we have an obviously 13 important inconsistency, lie in my -- that's 14 how I would characterize a lie. It cannot be 15 me or somebody else, it can only be one or 16 the other. 17 Q. Who is the other person she said 18 took her to the room? 19 A. Why don't you ask her. 20 Q. I'm asking you. 21 A. How would I possibly know. 22 Q. You are saying that's a lie. 23 A. It was a lie in the papers, she 24 said it in the newspaper, it was in the 25 newspaper. Page 217 1 G Maxwell - Confidential 2 Q. How do you know she wasn't 3 identifying you? 4 A. She said somebody. 5 Q. How do you know that somebody 6 wasn't you? 7 A. Why did it suddenly become me, why 8 not say it was me and be done with it. 9 Q. So it's a lie because she 10 originally may not have named you and then 11 named you later? 12 A. It's obviously inconsistent to 13 somebody who wasn't me. 14 Q. How do you know it wasn't you? 15 A. I know it wasn't me because I was 16 talking to her mother. 17 Q. But she then named you, is what you 18 are saying? 19 A. That's an obvious lie. 20 Q. She named you? 21 A. It's an obvious lie because I 22 wasn't even in the house. 23 Q. Is it an obvious -- who did lead 24 her up to Jeffrey's room while you were 25 talking to her mother? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 56 of 106 56 (Pages 218 to 221) Page 218 1 G Maxwell - Confidential 2 A. You would have to ask Virginia, I 3 don't know if she was led up to his room. 4 Q. You were standing with the mother, 5 is that correct? 6 A. That's correct. 7 Q. Who was working at the house that 8 day? 9 A. I believe John Alessi was. 10 A. Would John Alessi typically lead 11 someone up to the room where Jeffrey was 12 having a massage? 13 A. I don't know she was led up to the 14 room to have a massage. 15 Q. She would have found her way on her 16 own? 17 A. I would suggest that that entire 18 story never happened at all in any of its 19 form. 20 Q. If you stood outside with the 21 mother, what did you think happened inside 22 then? 23 A. I believe that somebody, it wasn't 24 me, John Alessi probably took her to meet 25 Jeffrey Epstein while he was working at his Page 219 1 G Maxwell - Confidential 2 desk and they had a conversation. 3 Q. Did Jeffrey tell you that? 4 A. No but that would have been a 5 normal interaction. I don't believe for a 6 second -- I know her entire characterization 7 didn't happen because I was outside talking 8 to her mother the entire time. 9 Q. Why would she have come for a 10 massage and not given a massage? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. We are talking about her 14 characterization of the first time that she 15 came to the house. 16 Q. If I'm following you correctly, 17 you're saying she walked in and would have 18 gone to -- it's your assumption she would 19 have gone and talked to Jeffrey and left? 20 A. When I was working for Jeffrey, 21 typically he would meet someone before 22 getting a massage from them to see if he 23 wanted to have a massage from them, 24 typically. 25 Q. So he would not have someone come Page 220 1 G Maxwell - Confidential 2 up to the room and start a massage? 3 A. He would not. 4 Q. So the young girls in the police 5 report who say they came over and were led up 6 to the room on the first day, would they be 7 wrong about that? 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. I can't comment what happened when 11 I was not at the house. I can only comment 12 when I was at the house. 13 Q. Was there ever a time where a woman 14 came to the house for the first time to give 15 a massage and Jeffrey had the massage that 16 day? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. Can we talk about adult 20 professional masseuses, please? 21 Q. I'm asking, whether adult or 22 underage? 23 A. I'm not interested in talking about 24 underage. I can only testify to what I know, 25 professional masseuses, adult, I cannot Page 221 1 G Maxwell - Confidential 2 testify to anything else. 3 Q. Why can't you testify to an 4 underage girl that came over and was led up 5 to the room for a massage? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. The police records you are 9 referring to? 10 Q. You are saying that didn't happen. 11 You're saying I can only testify to adults 12 that came for an interview and were led up to 13 the room. Why can't you testify to whether 14 an underage girl was brought in for an 15 interview and led up -- 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 Q. Go ahead. 19 A. Can you reask the question. 20 Q. Why can't you testify as to an 21 underage girl who came over for an interview 22 and then was then led up to the room for the 23 massage? 24 A. You've mangled your entire 25 question. Can you please reask that in a way MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 57 of 106 57 (Pages 222 to 225) Page 222 1 G Maxwell - Confidential 2 that I can answer it correctly? 3 Q. Why can you not testify as to 4 whether an underage girl, you said you can 5 testify as to females that were over the age 6 of 18, why can't you testify as to whether an 7 underage girl came over for an interview and 8 on the same day -- 9 A. I don't know what you mean by 10 interview. 11 Q. You just said that Jeffrey Epstein 12 interviewed, it was your word, interviewed 13 the masseuses before they gave massages, is 14 that correct? 15 A. The word interview is making me -- 16 I'm English, so you could have some 17 difficulty understanding the way I 18 communicate. 19 Q. I'm using your word. 20 A. Then I will reuse it a different 21 word. He would meet them because receiving a 22 massage is something you want to make sure 23 you are comfortable with the person and so 24 interview is not the correct word but you 25 would meet them to have a conversation with Page 223 1 G Maxwell - Confidential 2 them to see if you want to have a massage 3 with that person. 4 Q. Did Jeffrey Epstein ever meet an 5 underaged girl and on the same day receive a 6 massage from that girl? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I can't possibly testify to what 10 happened after I was not at the house. 11 Q. If you are aware, at any time you 12 were at the house, did you ever see that? 13 MS. MENNINGER: Let her finish the 14 question. 15 A. I can only testify to people who 16 were adult professional masseuses who came to 17 the house. I cannot testify to something I'm 18 not party to and don't know about. I can 19 only testify to what I saw. So when 20 professional adult masseuse, male and/or 21 females would come to the house, typically 22 when I was there, typically he would meet 23 with them prior, to have a conversation with 24 them about their experience, whatever, to 25 decide whether it would then A, if he had Page 224 1 G Maxwell - Confidential 2 time for a massage at that time or B, whether 3 he could have a massage at that moment. 4 Q. Was Virginia an adult when she came 5 over, was she over 18? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I think we established, as of 9 today, we are all aware, everyone in this 10 room that she was 17. 11 Q. So you have been present when a 12 minor was brought over for a massage for 13 Jeffrey? 14 A. Can I say, as you are able to have 15 a massage at 17, so she came as a masseuse. 16 Q. I'm not saying whether or not you 17 are able to. I'm saying you've been present 18 at Jeffrey's home when an underage minor has 19 come over to give him a massage? 20 A. That's just not how that works. 21 You are able to be a masseuse at 17 so she 22 came to give -- for a massage, at 17 you are 23 able to come and give a massage. 24 Q. I'm not asking whether she is able 25 to do it. I'm asking whether you were Page 225 1 G Maxwell - Confidential 2 present at the home when a girl under the age 3 of 18 came over for the purposes of giving a 4 massage? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 Q. You can answer. 8 A. You can be a professional masseuse 9 at 17 in Florida, so as far as I am aware, a 10 professional masseuse showed up for a 11 massage. There is nothing inappropriate or 12 incorrect about that and your 13 mischaracterization of it, I think is 14 unfortunate. 15 Q. How many teenagers did he have that 16 were professional masseuses that worked in 17 his home? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 Q. How many? 21 A. First of all, I am not aware of 22 teenagers who worked in his home. 23 Q. You are aware of Virginia Roberts 24 and you've stated she was 17 and she worked 25 for him, correct? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 58 of 106 58 (Pages 226 to 229) Page 226 1 G Maxwell - Confidential 2 A. No. I did not state that at all, 3 you are mischaracterizing my words and what I 4 said. 5 What I said was that we can all 6 agree and I think at this point there is not 7 one person in this room, however much you 8 would like her to be younger, to say she was 9 not 17 because that has been a very offensive 10 thing that you have all done. So she was 17. 11 At 17 you are allowed to be a professional 12 masseuse and as far as I'm concerned, she was 13 a professional masseuse. There is nothing 14 inappropriate or incorrect about her coming 15 at that time to give a massage. Her entire 16 characterization of her first time at the 17 house was to me an obvious lie, given it was 18 impossible for her entire story to take place 19 given I was speaking to her mother the entire 20 she was at the house. 21 Q. So it was impossible that day, that 22 first day she came and you were speaking to 23 the mother, for Virginia Roberts to have had 24 sex with Jeffrey Epstein during the time that 25 you were outside with her mother? Page 227 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. You, again, are completely 5 mischaracterizing. I can only testify to 6 what I heard obvious lies about me and her 7 obvious lies about me are that she, as you 8 put out to the papers and every other which 9 way, went upstairs with her, didn't happen. 10 So that to me is an absolute, obvious lie. I 11 also don't believe that her -- her 12 mischaracterization of the length of time she 13 was there because as I recall, she just met 14 with Jeffrey and then left with her mother. 15 That's my recollection. 16 Q. So you were standing outside the 17 entire time that Virginia was in the house, 18 is that correct? 19 A. That is correct. 20 Q. So can you testify as to whether or 21 not, do you know either from Jeffrey or any 22 other source whether or not Virginia Roberts 23 had sex with Jeffrey on that first day that 24 she was at the house? 25 A. We can categorically state, Page 228 1 G Maxwell - Confidential 2 absolutely 1000 percent that she did not have 3 any type of sexual relations as described by 4 you in your court papers that took place 5 because those allegedly according to her lies 6 involved some aspect of me. 7 As I was standing outside with her 8 mother the entire time, her entire story is a 9 lie. Therefore, to ask me what she did or 10 didn't do during that time, I can only 11 testify to what she said about me, which was 12 1000 percent false. 13 Q. So let's not take the first time, 14 let's take the next time she comes. 15 A. No no, how can do you that, when 16 the basis of this entire horrible story that 17 you have put out is based on this first 18 appalling story that was written, repeated, 19 multiply by the press that lied about her 20 age, lied about the first time she came, lied 21 about and characterized the entire first 22 time. I have been so absolutely appalled by 23 her story and appalled by the entire 24 characterization of it and I apologize 25 sincerely for my banging at the table Page 229 1 G Maxwell - Confidential 2 earlier, I hope you accept my apology. It's 3 borne out of years of feeling the pressure of 4 this entire lie that she has perpetrated from 5 our first time and whilst I recognize that 6 was -- I hope you forgive me sincerely 7 because it was just the length of time that 8 that terrible story has been told and retold 9 and rehashed when I know it to be 100 percent 10 false. 11 Q. So not the first time she came, but 12 the second time she came or the third time or 13 any time she came, did you ever participate 14 in a massage with her in Jeffrey Epstein's 15 room? 16 A. I have never participated at any 17 time with Virginia in a massage with Jeffrey. 18 Q. Have you ever participated at any 19 time with Virginia in any kind of sexual 20 contact or sexual touching with Jeffrey and 21 Virginia? 22 A. I have not. 23 Q. So we were going through the list 24 of obvious lies and you were talking about 25 the first time which I believe we have MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 59 of 106 59 (Pages 230 to 233) Page 230 1 G Maxwell - Confidential 2 completed but you can add to that if you need 3 to. 4 What other obvious lies did 5 Virginia Roberts tell that you were referring 6 to in your statement? 7 A. Oh my goodness. Well, I think we 8 can totally cover the Clinton story, the 9 story that I flew him with Secret Service and 10 there was a dinner with other people and that 11 entire thing is 100 percent fictitious. I 12 have testified for the record and I'm happy 13 to do it again, that I have never flown Bill 14 Clinton, myself as a pilot in a helicopter at 15 any time, anyplace, at any time, to any part 16 of the world. 17 Q. What other obvious lies were you 18 referring to? 19 A. She was referring to Al Gore, she 20 is referring to a bunch of people. I don't 21 believe Al Gore ever came to the island at 22 any time ever. I don't even know Al Gore 23 actually. 24 Q. Just one moment, I want to hear all 25 of them, but when you say you don't believe Page 231 1 G Maxwell - Confidential 2 Al Gore ever came to the island, do you know 3 whether Al Gore ever came to the island? 4 A. Al Gore never came to the island. 5 Q. How do you know that? 6 A. Jeffrey doesn't know him, I don't 7 know him and I think had Al Gore -- I don't 8 think -- had Al Gore gone to the island 9 during the period when I would have been 10 involved in organizing a trip, I would have 11 been aware of it. 12 Q. So go ahead, you had another one. 13 A. It would be easier if I could see, 14 do you mind if a take a reference at some of 15 these newspaper articles or you just want me 16 to go from memory. 17 Her entire characterization of what 18 took place in London at my house with Prince 19 Andrew. 20 Q. Was it an obvious lie that she was 21 at your house in London? 22 A. We can't really establish the 23 photograph and all that. I don't know if 24 that's true, if that's a real picture or not. 25 Q. So you dispute that you were Page 232 1 G Maxwell - Confidential 2 actually photographed in your town home in 3 London -- 4 A. I don't recognize that picture. 5 I'm not sure if that's a real picture or not. 6 Q. And have you talked to Prince 7 Andrew about that picture? 8 A. We discussed Virginia's entire tail 9 and he asked me if he even knew her. 10 Q. So did Prince Andrew tell you that 11 he did not have sex with Virginia Roberts? 12 A. He doesn't even know who Virginia 13 Roberts is. 14 Q. Did he tell you that he didn't have 15 sex with her? 16 A. It would be difficult to have sex 17 with someone you don't know. 18 Q. He may not remember her? 19 A. I think the inference is he didn't 20 know who she was, he didn't have any 21 recollection of her whatsoever. 22 Q. Has Prince Andrew ever come to your 23 London town home? 24 A. Yes. Ever being the entire time I 25 owned my house, yes. Page 233 1 G Maxwell - Confidential 2 Can I go on on her obvious lies? 3 Q. If you have more. 4 A. I have -- her entire 5 characterization -- I took her shopping into 6 Burberry and bought her a very expensive 7 dress and if this photo were real and if this 8 is -- I would never -- the outfit doesn't 9 work at all so -- 10 Q. Do you not remember taking her 11 shopping or are you saying it's an obvious 12 lie, you know you did not take her shopping? 13 A. I did not take her shopping. I did 14 not by her a $5,000 handbag. 15 Q. Did Jeffrey by her a $5,000 16 handbag? 17 A. Her accusation was that I did. 18 Q. Do you know if Jeffrey bought her a 19 handbag during that trip to London? 20 A. I don't know what he did. She 21 accused me, I can't physically remember 22 buying a $5,000 not for her, not for anyone, 23 not for me. 24 Q. Did you ever go shopping with 25 Virginia? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 60 of 106 60 (Pages 234 to 237) Page 234 1 G Maxwell - Confidential 2 A. I don't recall ever shopping with 3 Virginia. 4 Q. Did you have more to go over or did 5 you want me to ask my questions? 6 A. The entire characterization of what 7 took place in my house in London would have 8 been impossible. 9 Q. Can I ask, do you still have it, 10 the picture of the London town home with you 11 in it, Giuffre 00407. 12 As you are looking at this picture, 13 Ms. Maxwell, as I'm looking at it it's on the 14 right-hand side, there appears to be a 15 picture hanging on the wall, do you recall 16 that in your London town home? 17 A. It's a little difficult to see. 18 Q. Do you recall having a picture on 19 the wall there by the room where you're 20 standing? 21 A. I do have a picture. 22 Q. Do you recall on the left-hand side 23 having a railing that looks like that with 24 sort of a bubble wood top? 25 A. I do. Page 235 1 G Maxwell - Confidential 2 Q. So are you saying that it's an 3 obvious lie that Virginia's statement that 4 she had sex with Prince Andrew is an obvious 5 lie? 6 A. What I'm representing is that her 7 entire ludicrous and absurd story of what 8 took place in my house is an obvious lie. 9 Q. Including she had sex with Prince 10 Andrew? 11 A. She claimed things took place in my 12 bathroom in London. Her characterizations is 13 just not possible. 14 Q. So you're saying it's an obvious 15 lie -- that she was telling an obvious lie 16 when she said she had sex with Prince Andrew? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. The witness 19 answered the question. 20 A. I'm saying within the context of 21 all the stories she told, this particular 22 story -- back up, she claimed we went out at 23 night. I've already testified if -- Prince 24 Andrew is such a famous person, if he went to 25 a nightclub, it would have been reported by Page 236 1 G Maxwell - Confidential 2 the press at that time. She characterized 3 that Prince Andrew drank alcohol. Prince 4 Andrew tea total. 5 She then characterized things took 6 place in my bathroom in the bathtub itself. 7 The tub is too small for any type of activity 8 whatsoever. 9 Q. Is Club Tramp the name of a London 10 club, is that a club you heard of? 11 A. It's not called Club Tramp, it's 12 called Tramp. 13 Q. That would be a club located in 14 London? 15 A. Yes. 16 Q. Are you saying that it was an 17 obvious lie when Virginia said that you made 18 her dress up in a school girl outfit? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I already testified that, first of 22 all, I don't know what you are taking about, 23 I already testified I didn't get her outfits 24 and all of that. 25 Q. Is it an obvious lie that Virginia Page 237 1 G Maxwell - Confidential 2 was paid to go to give a massage to Glenn 3 Dubin at the Breakers? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I cannot testify to what Virginia 7 did outside of -- I can't testify to what she 8 did, who she gave massages to. 9 Q. So you don't know on that one? 10 A. Of course I don't know. 11 Q. Do you agree that it's 12 psychologically harmful to have sex with a 13 minor? 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. What are you asking me? 17 Q. I'm asking if is it psychologically 18 harmful for an adult to have sex with a 19 minor? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I don't know what you are asking. 23 This has nothing to do with Virginia Roberts. 24 Q. It does. 25 A. How does it? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 61 of 106 61 (Pages 238 to 241) Page 238 1 G Maxwell - Confidential 2 Q. I ask the questions, you answer. 3 If you can't answer, you can say I don't 4 know. 5 But my question is, do you agree 6 that it's psychologically harmful to have sex 7 with a minor? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. Are you giving me a random question 11 and as not relates to this case and not 12 relates to anything. It's obviously not 13 something that you want to have happen. 14 Q. Do you agree that Jeffrey Epstein 15 has harmed many minors by having sex with 16 them? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I can't testify to what Jeffrey did 20 or didn't do. I have no knowledge of what 21 you are asking me. 22 Q. If Jeffrey had sex with minors, 23 would you agree that that could harm a minor? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Page 239 1 G Maxwell - Confidential 2 A. Again, I am not testifying to what 3 Jeffrey did or did not do because I cannot. 4 Q. You don't know whether Jeffrey 5 Epstein ever had sex with a minor? 6 A. Again, I cannot testify to what 7 Jeffrey did or didn't do. I cannot. 8 Q. You never observed him having sex 9 with a minor? 10 A. I never observed Jeffrey having sex 11 with a minor. 12 Q. Do you agree that calling a sex 13 abuse victim a liar when she speaks about her 14 abuse can cause psychological harm? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. Can you repeat the question. 18 Q. Do you agree calling a sex abuse 19 victim when she speaks about her abuse can 20 cause psychological harm? 21 MR. PAGLIUCA: Objection to form 22 and foundation. 23 A. Say it again. 24 Q. Do you agree that calling a sexual 25 abuse victim a liar can cause psychological Page 240 1 G Maxwell - Confidential 2 harm. 3 MR. PAGLIUCA: Object to the form 4 form and foundation. 5 A. I would like to say all the 6 terrible things Virginia Roberts said about 7 me is extremely harmful and you should turn 8 that around. All the lies she has said and 9 you have backed her on have been extremely 10 damaging to me. 11 So what I can testify to is that 12 somebody who has made these outrageous 13 allegations and who is a serious liar and 14 that I know for a fact is a liar, that I can 15 testify is damaging to me. 16 Q. Do you agree that calling a sexual 17 abuse victim a liar when she speaks out about 18 her abuse can cause psychological harm? 19 MR. PAGLIUCA: Are you asking a 20 hypothetical question? 21 MS. McCAWLEY: Yes. 22 A. You are asking me to speculate? 23 Q. I'm not asking you to speculate . 24 If somebody is a sexual abuse victim -- 25 A. I can't testify to what some random Page 241 1 G Maxwell - Confidential 2 hypothetical person that you are asking me to 3 speculate on their mental state or health 4 versus speculative statement. I can't do 5 that, that's just not right. 6 Q. Do you agree that by calling 7 Virginia Roberts a liar when she was subject 8 to sexual abuse by Jeffrey Epstein can cause 9 psychological harm? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. Assumes facts not 12 in evidence. 13 A. I can only tell you about what I 14 know of Virginia's lies. She lied 15 repeatedly, often and I know for a fact she 16 is a liar so I can only testify to what I 17 know and the fact that she has lied about me 18 from the beginning to the end and repeatedly 19 causes me to question anything that she may 20 feel. 21 Q. Is it an obvious lie you had sex 22 toys in Jeffrey Epstein's Palm Beach house? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Can you repeat the question, MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 62 of 106 62 (Pages 242 to 245) Page 242 1 G Maxwell - Confidential 2 please? 3 Q. Is it an obvious lie that you had 4 sex toys in Jeffrey Epstein's Palm Beach 5 house? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. Did Virginia say that? 9 Q. I'm asking you a question. 10 Is it an obvious lie that you had 11 sex toys in Jeffrey Epstein's house? 12 A. I don't recall any sex toys. 13 Q. If someone said had you sex toys, 14 would that be an obvious lie? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. Like I said -- can you be more 18 specific about the house or whatever, what 19 exactly you are referring to, what's a sex 20 toy? 21 Q. Yes. How would you define a sex 22 toy? 23 A. No. I need you to define a sex 24 toy, I don't have enough knowledge of sex 25 toys. Page 243 1 G Maxwell - Confidential 2 Q. I will define it based on the 3 dictionary's definition, which is an object 4 or device used to sexually stimulate or 5 enhance sexual pleasure. 6 A. What's your question, please? 7 Q. The question is, is it an obvious 8 lie that you had sex toys in Jeffrey 9 Epstein's Palm Beach house? 10 MR. PAGLIUCA: Same objection. 11 Q. You can answer. 12 A. Like I said, I do not have any 13 recollection of sex toys in Jeffrey's house. 14 Q. Is it a lie, is it an obvious lie 15 that you took pictures of nude girls? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. We already covered this. Girls we 19 are not referring to -- I can only testify to 20 taking pictures of adult people and I already 21 testified they are not nude, per se. That 22 every picture that I ever took and which they 23 were very limited, always by request, the 24 people would be covered or it would be a hand 25 or a foot. There was never any pictures that Page 244 1 G Maxwell - Confidential 2 I took of people would only have been 3 mainstream type magazine type photos and any 4 photos I took could have been very happily 5 and expected to be displayed on your parents' 6 mantel piece or grandparents' mantel piece. 7 Q. Is it a lie that you approached 8 females to bring them to Jeffrey Epstein? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. Please ask the question, again. 12 Q. Sure. Is it a lie that you 13 approached females to bring them to Jeffrey 14 Epstein? 15 A. I don't know what you are asking 16 me. 17 Q. I'm asking you, if it's a lie that 18 you approached females to bring them to 19 Jeffrey Epstein? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. You are not asking me a good 23 question, sorry. 24 Q. You don't get to choose the 25 questions. Page 245 1 G Maxwell - Confidential 2 A. I would like to answer your 3 questions but you are not asking me a 4 question that I can answer. 5 Q. What about that is causing you 6 pause where you can't answer the question? 7 A. You are trying to trap me and 8 that's not fair, so I already testified that 9 I hire people across the board, so I would 10 hire architects, decorators, pool people, 11 exercise instructors, gardeners, cooks, 12 chefs, cleaning people. So I, in the course 13 of a very long time when I would hire people 14 I hired people to work for Jeffrey. So I'm 15 happy to testify to hiring people for every 16 possible conceivable proper job that you 17 could conceive of within the context of 18 Jeffrey's life and homes. 19 Q. Is it a lie that you approached 20 females to bring them to Jeffrey Epstein for 21 the purpose of performing massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Again, I have already testified 25 that part of the job that I had was to hire MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 63 of 106 63 (Pages 246 to 249) Page 246 1 G Maxwell - Confidential 2 lots of different types of people. In terms 3 of whatever -- very small part of my job, 4 Jeffrey enjoyed getting massages. I think 5 that is something we can all agree in this 6 room and within the context of that, very 7 infrequently I would go to spas and myself 8 happily receive a professional nonsexual 9 massage from a man and/or from a woman and if 10 that massage was something that I thought was 11 something that was good, I would ask if that 12 man or woman would come back and does home 13 visits. If that person said that they did, 14 they would sometimes come, from time to time, 15 not always, come back to the house to perform 16 a nonsexual professional male or female 17 massage. 18 Q. Were any of the exercise 19 instructors you hired under the age of 18? 20 A. Again, I don't hire, we've already 21 established that I don't hire people. I 22 interview people to see if they are competent 23 in the job that they do and/or whether they 24 are someone who seemed that they can do home 25 visits. Page 247 1 G Maxwell - Confidential 2 At the point where I think that 3 there is somebody that has, can be either 4 whatever the job may be, pool, gardener, chef 5 and/or exercise instructor and I think they 6 could be good at whatever it is at whatever 7 skill that they had and they did a home visit 8 which would obviously be mandatory and Mr. 9 Epstein would meet with them and decide if he 10 wanted to have whatever skill it was that he 11 would do it and then he would then either 12 have them come back or hire them. 13 Q. Were there any exercise instructors 14 that worked at the home that were under the 15 age of 18? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Again, I keep coming back to this, 19 that the people that I employed or -- not the 20 right word, the people I would meet to come 21 and work at the house, under any guise 22 whatsoever, again, from any of the many 23 positions that I filled, were all over -- 24 were adults. 25 Q. When you say adults, over the age Page 248 1 G Maxwell - Confidential 2 of 18? 3 A. I think we can establish what adult 4 would be. 5 Q. You never interviewed or I know you 6 don't want to use the word hired, whatever 7 your role was, you brought in an exercise 8 instructor that was under the age of 18 to 9 work at the house? 10 MR. PAGLIUCA: Object to the form 11 and foundation. 12 A. I have already testified that what 13 I was responsible for was to find people who 14 had competencies in whatever area I was 15 looking for. The competencies I was looking 16 for were professional and adult. 17 Q. So there was no exercise instructor 18 that worked at the Palm Beach house or the 19 New York house or the New Mexico house or the 20 USVI under the age of 18? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I can only testify to when I was at 24 the house. 25 Q. Yes. Page 249 1 G Maxwell - Confidential 2 A. I can only testify to the years 3 when I was present. 4 Q. Right. 5 A. And I can also only testify to 6 people I personally either met and/or worked 7 with and/or invited, to find the correct 8 word, I don't know what the correct word is, 9 to come to do exercise or whatever it was at 10 the house. 11 Of the people that I, male and/or 12 female that I brought were all appropriate 13 and age appropriate adults. 14 Q. Over the age of 18? 15 A. We've established them as an adult. 16 Q. You are saying appropriate adults, 17 so we are clear, you didn't hire or bring in 18 or know of any exercise instructors that were 19 under the age of 18 at any of those homes? 20 A. I am also testifying that when I 21 was present at the house and with the people 22 that I brought in, were all age appropriate 23 adults. 24 Q. How do you define age appropriate 25 adults, is that over the age of 18, can we MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 64 of 106 64 (Pages 250 to 253) Page 250 1 G Maxwell - Confidential 2 agree to that? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 Q. Are they under the age of 18? 6 A. We already established that you can 7 be a masseuse in Florida at age 17. That 8 does not make it inappropriate. 9 A. I'm not saying appropriate or 10 inappropriate. I'm just asking if there were 11 any exercise instructors that were under the 12 age of 18. 13 A. I am not aware if anybody was but I 14 don't want to full out and say you oh she 15 said, we already established you can be a 17 16 year old masseuse and have it not be 17 something that is not appropriate. So when 18 you say that and then you go, well, you come 19 back and say something, now we can establish 20 that Virginia was 17 but you can be a 17 year 21 old legal masseuse, but I am not aware to 22 your point. 23 Q. Who were the other 17 year old 24 masseuses that you were aware of? 25 A. I am not aware of any. Page 251 1 G Maxwell - Confidential 2 Q. Were there any 16 year year old 3 masseuse that you are aware of? 4 A. I am not aware. 5 Q. Any 15? 6 A. I just want to be clear. The only 7 person that I am aware of who claims to have 8 been a -- we have to -- we established 9 Virginia now is 17, given she has changed her 10 age so many times. The only person that I am 11 aware of that was a masseuse at the time when 12 I was present in the house was Virginia. 13 Q. Is it an obvious lie that Jeffrey 14 Epstein had a sexual preference for underage 15 miners? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Can you ask the question again? 19 Q. It is it an obvious lie that 20 Jeffrey Epstein had a sexual preference for 21 underage minors? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Can you ask the question again? 25 Q. Is it an obvious lie that Jeffrey Page 252 1 G Maxwell - Confidential 2 Epstein had a sexual preference for underage 3 minors? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 A. I cannot testify to what 7 Jeffrey's -- 8 Q. You don't know his preference? 9 A. You handed me a stack of papers 10 from the police reports and that's what I've 11 read but I have no knowledge, direct 12 knowledge, of what you are referencing. 13 Q. So you don't know, you don't know 14 in your own mind that Jeffrey Epstein had a 15 sexual preference for underage minors, is 16 that correct? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 Q. Is that correct? 20 A. Please ask the question again. 21 Q. You don't know in your own mind 22 that Jeffrey Epstein had a sexual preference 23 for underage minors? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. You have to pause, Page 253 1 G Maxwell - Confidential 2 let me object, answer the question. 3 Listen to her question, pause, I object, 4 you answer. 5 Q. So you don't know in your own mind 6 that Jeffrey Epstein had a sexual preference 7 for underage minors? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 Q. You can answer. 11 A. I cannot tell you what Jeffrey's 12 story is. I'm not able to. 13 Q. Did Jeffrey Epstein have a scheme 14 to recruit underage girls to use them for 15 purposes of sexual massages? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Can you ask me again, please? 19 Q. Did Jeffrey Epstein have a scheme 20 to recruit underage girls to recruit them for 21 sexual massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Can you ask it a different way? 25 Q. Did Jeffrey Epstein have a scheme MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 65 of 106 65 (Pages 254 to 257) Page 254 1 G Maxwell - Confidential 2 to recruit underage girls for sexual 3 massages? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 Q. If you know. 7 A. I don't know what you are talking 8 about. 9 Q. Is it an obvious lie that Virginia 10 Giuffre was a minor the first time she was 11 taken to Jeffrey Epstein's house? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. So we've already established that 15 Virginia was 17 and we have established that 16 her mother brought her to the house and that 17 she came as a masseuse, age 17, which is 18 legal in Florida. 19 Q. Would Jeffrey Epstein's assistants 20 arrange times for underage girls to come to 21 the house for sexual massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. What are you talking about? 25 Q. Sure. Would Jeffrey Epstein's Page 255 1 G Maxwell - Confidential 2 assistants, I think earlier you mentioned, we 3 talked about Sarah Kellen who worked in the 4 role as an assistant or Nadia Marcinkova. 5 Would Jeffrey Epstein's assistants arrange 6 times for underage girls to come over the 7 house for sexual massages? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. Again, I read the police reports so 11 this is all happening according to the police 12 reports when I am no longer at the house so I 13 can't testify to what Jeffrey's assistants 14 did when this kind of activity as alleged in 15 the reports. 16 Q. So you don't know? 17 A. No. 18 Q. Would Jeffrey Epstein's assistants, 19 meaning Sarah Kellen, Nadia Marcinkova or any 20 other assistant that you are aware of from 21 the time you worked there take nude 22 photographs of underage girls? 23 MR. PAGLIUCA: Object to the form 24 and foundation. 25 A. During what period of time? Page 256 1 G Maxwell - Confidential 2 Q. During any period of time you 3 worked, did you observe that? 4 A. I did not observe any such 5 photographs. 6 Q. Are you aware if they took those 7 kinds of photos? 8 A. I am not aware. 9 MR. PAGLIUCA: Can we take a 10 five-minute break. 11 THE VIDEOGRAPHER: It's 2:58 and we 12 are off the record. 13 (Recess.) 14 THE VIDEOGRAPHER: It's now 3:10. 15 We're starting disk No. 6 and we are 16 back on the record. 17 Q. Ms. Maxwell, was it an obvious lie 18 when Virginia said she was sent to Thailand 19 by Epstein in September of 2002? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I have no knowledge of Virginia 23 being sent to Thailand. 24 But may I say something? 25 Q. There is not a question pending Page 257 1 G Maxwell - Confidential 2 unless you want to clarify something. 3 Did you want to clarify that? 4 A. No, I just wanted to say something. 5 Q. Is it an obvious lie when Virginia 6 said she was given instructions to maintain 7 telephone contact with you while she was in 8 Thailand? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. Can you repeat the question? 12 Q. Is it an obvious lie when Virginia 13 said she was given instructions to maintain 14 telephone contact with you when she was in 15 Thailand? 16 MR. PAGLIUCA: Same objection. 17 A. I have no idea what instructions 18 Virginia was given, if any, when she went to 19 Thailand. 20 Q. So you know she went to Thailand? 21 A. I know she claimed she went to 22 Thailand from having read it but given that 23 she lied about everything it's hard to know 24 what is true and not true. 25 Q. Would it make any sense for her to MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 66 of 106 66 (Pages 258 to 261) Page 258 1 G Maxwell - Confidential 2 be in contact with you, would there be any 3 reason why she needed to be in contact with 4 you? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. When are we talking about? 8 Q. When she went to Thailand. 9 MR. PAGLIUCA: Same objection. 10 Q. In 2002, would there be any reason 11 for her to remain in contact with you? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. Can you ask the question again, 15 please? 16 Q. Would there be any reason for 17 Virginia to maintain contact with you in 2002 18 when she went to Thailand? 19 MR. PAGLIUCA: Same objection. 20 A. First of all, I didn't know that 21 she went to Thailand. I had had nothing to 22 do with her trip to go to Thailand and there 23 would absolutely no reason for her to be in 24 touch with me, whatsoever. 25 Q. Did you ever have a phone number Page 259 1 G Maxwell - Confidential 2 that was ? 3 A. I did. 4 Q. Was that a cell phone number? 5 A. Yes. 6 Q. Is that your current cell phone 7 number? 8 A. Yes. 9 Q. I'm going to mark a couple of 10 things here? 11 (Maxwell Exhibit 11, photos, marked 12 for identification.) 13 THE WITNESS: Can I say something 14 now? 15 MR. PAGLIUCA: No. 16 THE WITNESS: Will you let me know 17 when I can? 18 MR. PAGLIUCA: When she asks you a 19 question: 20 Q. So we've marked this as Exhibit 11. 21 I'm showing you what's been marked as Exhibit 22 11 which is Giuffre 003191 and 003192. 23 Can you take a look at that 24 document for me. Is that number that you 25 just identified the as being Page 260 1 G Maxwell - Confidential 2 your cell phone number, is that number on 3 this document? 4 A. It is. 5 Q. And do you know who authored this 6 document? 7 A. I do not. 8 Q. Who is JoJo? 9 A. I don't know who JoJo is on this 10 document because I don't know what this 11 document is. 12 Q. Do you know someone by the name of 13 JoJo? 14 A. I do know someone by the name of 15 JoJo. 16 Q. Would he know your phone number? 17 MR. PAGLIUCA: Object to the form. 18 A. I have to idea. 19 Q. Why would Virginia be instructed to 20 call Ms. Maxwell at your number on this form? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I don't know what this document is. 24 I don't know when it was done, I don't know 25 anything about it other than I can see it has Page 261 1 G Maxwell - Confidential 2 my name and my number on it. 3 Q. So JoJo -- you said JoJo -- is he 4 employed by Mr. Epstein? 5 A. Again, it is not the only one JoJo 6 on the planet. 7 Q. I understand. 8 Do you know a JoJo that is employed 9 by Mr. Epstein? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. Can you ask me the question again? 13 Q. Do you know someone by the name of 14 JoJo that was employed by Mr. Epstein back in 15 2002? 16 A. I do know somebody who was employed 17 by Mr. Epstein known as JoJo. 18 Q. Do you recognize the other numbers 19 listed at the top of this document? 20 A. I do not. 21 Q. Would you have known JoJo's cell 22 number at that time in 2002? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I have no idea. - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 67 of 106 67 (Pages 262 to 265) Page 262 1 G Maxwell - Confidential 2 Q. Can I ask you to turn to the next 3 page, please. 4 Do you know who Nantimda Tharanese 5 is who is mentioned on this document? 6 A. I do not. 7 Q. If you look on the bottom lines of 8 the document, it says, Still in Thailand 9 during your stay, if she is, she will be 10 staying at the same hotel. 11 Do you recall ever giving Virginia 12 instructions to meet a girl in Thailand? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I have already testified that I 16 didn't even know that Virginia was going to 17 Thailand. 18 Q. So you didn't give her instructions 19 to meet a girl in Thailand? 20 A. Like I said, I didn't even know she 21 was going to Thailand. 22 Q. Do you know whether Jeffrey Epstein 23 would have given her instructions to meet a 24 girl in Thailand? 25 MR. PAGLIUCA: Objection to the Page 263 1 G Maxwell - Confidential 2 form and foundation. 3 A. I cannot possibly tell you what 4 Jeffrey did or didn't do. I wouldn't know. 5 Q. Do you know whether Jeffrey Epstein 6 paid for Virginia to go to Thailand? 7 A. Again, I wouldn't know if he did. 8 (Maxwell Exhibit 12, documents, 9 marked for identification) 10 Q. I'm going to direct -- you can take 11 a look at it and then I'm going to direct 12 your attention to a couple of pages. 13 MR. PAGLIUCA: So the record should 14 be clear, this exhibit which is 12 is 15 375, 6, 7, 8, 9, 80, 1, and then skips 16 to 919, 920, 921, 922, 923, 924, 925 and 17 926. 18 Q. So I'm going to direct your 19 attention to the first page, have you ever 20 traveled with Jeffrey Epstein where you've 21 received a document like this from Shoppers 22 Travel in your own independent travel. 23 Do you recognize this? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 264 1 G Maxwell - Confidential 2 Q. The front form, the front page, do 3 you recognize this Shopper Travel form, have 4 you ever used them as a travel agent with 5 Jeffrey Epstein? 6 MR. PAGLIUCA: Same objection. 7 Q. You can answer. 8 A. I don't recognize this. 9 Q. Turning to the second page which is 10 the 00376, do you see at the top of that 11 document where it says Jeffrey Epstein, J. 12 Epstein 457 Madison Avenue 4th floor New York 13 New York. 14 Is that an address you are familiar 15 with that is Jeffrey Epstein's? 16 A. I am. 17 Q. Do you see below that, travel on 18 Singapore Airlines, and you are going to have 19 to go from New York JFK to Singapore Bangkok. 20 Do you see that? 21 MR. PAGLIUCA: What? 22 Q. The first entry is going to be on 23 September 27, New York. 24 MR. PAGLIUCA: I see it. 25 MS. McCAWLEY: I'm not talking to Page 265 1 G Maxwell - Confidential 2 you. I'm talking to the witness. 3 A. I see it. 4 Q. To Singapore Bangkok? 5 A. Singapore Bangkok I'm afraid are 6 not the same place. 7 Q. Singapore, then Bangkok: 8 Q. I'm going to turn you to page 9 Giuffre, it's a little further back 000919. 10 And do you see at the top where it says J. 11 Epstein, underneath, Royal Princess, change 12 mine? 13 A. I do. 14 Q. Does this refresh your recollection 15 that Virginia Roberts' trip to Thailand was 16 paid for by Jeffrey Epstein? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I can only testify to the piece of 20 paper you showed me that has that 21 information. I cannot testify from direct 22 memory. 23 Q. When Virginia was traveling to 24 Thailand, which the dates, again, I'm going 25 to refer you back to the first page so you MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 68 of 106 68 (Pages 266 to 269) Page 266 1 G Maxwell - Confidential 2 can see the dates. 3 MR. PAGLIUCA: Can you identify a 4 Bates number, please. 5 Q. which was at the top says, 6 I'm going to refer you, 7 at the same time, to the flight logs which 8 were marked, the thicker document that looks 9 like this with all the log entries on it. 10 I'm going to refer you to page -- 11 MR. PAGLIUCA: That's Exhibit No. 12 6, correct? I'm trying to keep the 13 record straight. 14 MS. McCAWLEY: I don't have Exhibit 15 numbers on mine. That's Giuffre 16 MR. PAGLIUCA: Hang on one second. 17 A. Can you repeat the number please. 18 Q. And if you will look on 19 that page at the entry, under 20 starting with the and then it runs 21 down to the, looks like the that first 22 entry has President Clinton, Kevin Spacey, 23 Chris Tucker, Jeffrey Epstein and the 24 initials GM. 25 Do you remember taking a trip with Page 267 1 G Maxwell - Confidential 2 President Clinton during 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. Can you repeat the question, 6 please? 7 Q. Do you remember taking a trip with 8 President Clinton during 9 that's the it looks like, through the 10 11 A. I don't remember the dates. I 12 couldn't testify to when we actually did it 13 but I do remember the trip itself. 14 Q. So you were traveling with Jeffrey 15 Epstein and President Clinton at the same 16 time Virginia was headed to Thailand, is that 17 correct? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I don't know, is that right? 21 Q. If you look at on the 22 document that I gave you, the first document 23 and then you referred to, if you look in the 24 same as above lines, you will see the travel 25 group with President Clinton? Page 268 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Are you asking her 3 to compare the documents or are you 4 asking her what her personal knowledge 5 is. 6 MS. McCAWLEY: I'm asking if she can 7 look at the doubts and tell me if she 8 recalls that she traveling with 9 President Clinton at the same time this 10 document reflects Virginia was in 11 Thailand. 12 A. I can't testify to any dates. I 13 couldn't tell you. I can see a date and I 14 can see a date but I can't tell you that I 15 have a memory of the dates. I have a memory 16 of the trip, I don't have a memory of the 17 time. 18 Q. Who is ? 19 A. 20 Q. What is her address? 21 A. I don't know. 22 Q. Does she live in the United States? 23 A. She does. 24 Q. In what state? 25 A. I believe in New Jersey somewhere. Page 269 1 G Maxwell - Confidential 2 Q. Do you have her phone number? 3 A. Not memorized. 4 Q. Do you have the ability to get her 5 phone number? 6 A. Of course. 7 Q. Has she ever asked -- has 8 ever asked other girls to come over to 9 see Jeffrey Epstein for the purpose of a 10 sexual massage? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. Can you ask the question again 14 please. 15 Q. Has ever asked girls to 16 come over to see Jeffrey Epstein for the 17 purpose of a sexual massage? 18 MR. PAGLIUCA: Object to form and 19 foundation. 20 A. Can you ask again, please? 21 Q. Has ever asked girls to 22 come over to see Jeffrey Epstein for the 23 purpose of sexual massage? 24 A. I have no personal knowledge. 25 Q. What does do for you? - - -- - ■- - - - MAGNA9 LEGAL SERVICES - - - Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 69 of 106 69 (Pages 270 to 273) Page 270 1 G Maxwell - Confidential 2 A. She helps with my not-for-profit 3 ocean foundation and any other related 4 activities that I may have. 5 Q. Is she paid for by Jeffrey Epstein? 6 A. No. 7 Q. She is paid for by you? 8 A. Yes. 9 Q. When did you first meet 10 11 A. I don't recollect exactly, sometime 12 maybe 2002, 2003. 13 Q. How did you meet her? 14 A. I don't recollect exactly how we 15 met. 16 Q. Did Jeffrey introduce you to her? 17 A. I don't recollect how we met. 18 Q. Does she know Jeffrey Epstein? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. Can you ask again, please? 22 Q. Does know Jeffrey 23 Epstein? 24 A. What do you mean by know? 25 Q. Has she met her him before? Page 271 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I can't recollect a time when 5 -- I've seen with Jeffrey but -- 6 Q. You are not sure -- 7 A. I know they know either other. I 8 can't testify to a meeting between them. 9 Q. Do you know where in New Jersey she 10 lives? 11 A. No 12 Q. You don't know a city? 13 A. No. 14 Q. How long has she worked for you? 15 A. Sometime 2002, 2003. 16 Q. To the present? 17 A. Yeah. 18 Q. Why do you think that 19 might know Jeffrey? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Because you know, I know Jeffrey. 23 Q. Have you seen them together? 24 A. I already testified I have not seen 25 them together, to my recollection. Page 272 1 G Maxwell - Confidential 2 Q. Is it your testimony that 3 knows Jeffrey Epstein through the work 4 that she does for you? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I don't recollect, and I don't 8 recollect how I met and I can't testify 9 to what relationship is or is not with 10 Jeffrey. 11 Q. Have you ever talked to Jeffrey 12 about 13 A. I don't know what you mean. 14 Q. In any way, have you ever had a 15 conversation with Jeffrey about 16 A. In what context. 17 Q. In any context. Have you ever 18 talked to Jeffrey Epstein about ? 19 A. works for me so it's entirely 20 possible that in the course of conversations 21 since 2002, 2003 that a conversation in which 22 name would have come up is entirely 23 possible. 24 Q. I provided you with and I'm sorry, 25 I don't know all the numbers, but the Page 273 1 G Maxwell - Confidential 2 statement that was issued by Ross Gow that 3 should be a single page still in your stack 4 of exhibits there. 5 MR. PAGLIUCA: Exhibit 10. 6 Q. Did you authorize Ross Gow to issue 7 that statement on your behalf in January of 8 2015? 9 A. I already testified that that was 10 done by my lawyers. 11 Q. So did you authorize your lawyers 12 to issue a statement on your behalf through 13 Ross Gow in January of 2015? 14 A. It was determined that I had to 15 make a statement in the United Kingdom 16 because of the appalling lies and I just 17 thought of some new ones. 18 Virginia's statement that I 19 celebrated her 16 birthday with her. We can 20 all agree that that's entirely impossible. I 21 didn't meet her until she was 17 and other 22 lies she perpetrated that she had a diary and 23 we all know is a complete fake. That's not a 24 diary. It was just a book she was writing 25 that you helped sell to the press, as if it - - - ~ - - 1111 - - - - ~ - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 70 of 106 70 (Pages 274 to 277) Page 274 1 G Maxwell - Confidential 2 was a diary, when it was just a story that 3 she is writing of fiction, fictional story 4 for money. 5 Q. How did you arrive at the words 6 that were put in that statement? 7 MR. PAGLIUCA: I'm going to object 8 and instruct you to the extent this 9 calls for any privileged communications 10 between yourself and Mr. Barden or 11 another lawyer representing you, we're 12 asserting privilege. If you can answer 13 that without that, feel free to answer. 14 Q. So what your counsel is saying, and 15 I will exclude any privileged communications 16 you had with your lawyers. 17 The question is, how did you arrive 18 at the words that were put in that statement, 19 if you can tell me without disclosing 20 privileged communications? 21 A. I'm not sure that I can. 22 Q. Is the statement that you issued 23 true? 24 A. What do you mean by that? 25 Q. Is the statement that you issued, Page 275 1 G Maxwell - Confidential 2 the statement that's in front of you, is it a 3 true statement? 4 A. As in that Virginia is a liar? 5 Q. The words you put in there, is that 6 true? 7 A. Of course they're true. 8 Q. When did you become aware that the 9 statement was being released? 10 A. I don't recollect exactly. 11 Q. What day it was? 12 A. No. 13 Q. I'm sorry. Did you identify, I 14 might not have caught it, did you identify 15 the name of the lawyer that you said you 16 retained for purposes of this statement? 17 A. I think Philip Barden. 18 Q. Did you pay that lawyer Philip 19 Barden? 20 A. Yes. 21 Q. Are you aware of any interstate or 22 international transportation of a woman aged 23 18 to 28 for the purposes of prostitution? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 276 1 G Maxwell - Confidential 2 A. I'm not sure I even understand your 3 question. 4 Q. I will go slower. 5 Are you aware of any interstate, 6 meaning between states, or international, 7 meaning oversees transportation, of women 8 aged 18 to 28, for the purposes of 9 prostitution? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. Are you asking -- I'm still not 13 sure I understand the question. 14 Q. I will try to make it clearer. 15 I'm asking you if you are aware of 16 any interstate, meaning between states, or 17 international transportation, meaning by 18 flight or by car or by train, of women aged 19 18 to 28, their ages are between the ages of 20 18 and 28, for the purposes of prostitution? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. In the world I'm sure that that 24 happens, I read about it all the time. 25 Q. Not in the world. Are you aware of Page 277 1 G Maxwell - Confidential 2 it, in your experience with Jeffrey Epstein, 3 of any interstate or international 4 transportation of women aged 18 to 28, for 5 the purposes of prostitution? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. So whilst I appreciate this might 9 not seem like a smart question, what do you 10 mean by prostitution, what are you asking me 11 exactly? 12 Q. That would be sex for hire, any 13 kind of sexual act that's paid for. 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. Who's paying, what are you asking 17 me. 18 Q. It can be paid for by anybody. 19 It's a sexual act that's paid for. 20 I'm asking if you are aware of any 21 interstate or international transportation of 22 women aged 18 to 28, for the purposes of 23 prostitution? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 71 of 106 71 (Pages 278 to 281) Page 278 1 G Maxwell - Confidential 2 A. I have no idea what you are talking 3 about. 4 Q. So you are not aware of that? 5 A. No. 6 Q. Are you aware of any interstate or 7 international transportation of women, aged 8 18 to 28, for the purposes of having sex with 9 Epstein where they would receive compensation 10 of any type? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I don't know what you are referring 14 to. 15 Q. Do you want me to repeat the 16 question? 17 A. Sure, go ahead. 18 Q. Are you aware of any interstate or 19 international transportation of woman, aged 20 18 to 28, for the purpose of having sex with 21 Jeffrey Epstein where they would receive 22 compensation of any type? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. I am not aware of what you are Page 279 1 G Maxwell - Confidential 2 talking about. 3 Q. Are you aware of any interstate or 4 international transportation of women, aged 5 18 to 28, for the purposes of providing a 6 massage for Jeffrey Epstein? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. So I you need to repeat that 10 question for me. 11 Q. Sure. 12 Are you aware of any interstate, 13 meaning between states, or international, 14 oversees, transportation of women, aged 18 to 15 28, for the purposes of providing massage for 16 Jeffrey Epstein? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I think we can agree he did travel 20 from time to time with a professional adult 21 masseuse. 22 Q. Are you aware of any interstate or 23 international transportation of women, aged 24 18 to 28, for the purposes of providing a 25 massage to any person other than Jeffrey Page 280 1 G Maxwell - Confidential 2 Epstein? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. Again, I'm not aware of anybody 6 that, if you are asking for specifics to 7 someone else, I have no knowledge of that. 8 Q. So you are not aware of any 9 interstate or international transportation of 10 a woman aged 18 to 28 for the purposes of 11 providing a massage to any person other than 12 Jeffrey Epstein? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I don't recall what any single 16 person being on a plane for a massage with 17 someone else other than Jeffrey, for the sole 18 purpose, if that's the question, I don't have 19 any recollection of that. 20 Q. Earlier in your testimony, you 21 stated that Virginia Roberts was 17 at the 22 time you met her. 23 How do you know she was 17? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. And to the extent Page 281 1 G Maxwell - Confidential 2 that calls for a privileged response, 3 I'm instructing you not to answer. 4 Q. How do you know Virginia Roberts 5 was 17 at the time you met her? 6 MR. PAGLIUCA: Again, if you 7 learned that information from your 8 lawyer, I'm instructing you not to 9 answer. 10 A. I will follow my counsel's advice. 11 Q. Are you able to answer that 12 question without telling me information you 13 learned from a lawyer? 14 A. I'm not. 15 Q. So you don't have independent 16 knowledge that Virginia, according to your 17 statement, was 17 at the time you met her? 18 A. Again, my lawyer has instructed me 19 not to answer. 20 Q. I'm asking you a different 21 question. Whether you have any independent 22 knowledge, outside your lawyers, that 23 Virginia was 17 at the time you met her? 24 A. Following the instructions of my 25 lawyers, I can only remember or testify to MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 72 of 106 72 (Pages 282 to 285) Page 282 1 G Maxwell - Confidential 2 what she -- 3 MR. PAGLIUCA: She is asking you a 4 different question. She is asking other 5 than what your lawyers have told you, do 6 you have any knowledge about her being 7 17, that's what she is asking. 8 A. I can't recollect where I got all 9 the information that I have that definitively 10 shows that. 11 Q. Earlier in your testimony, I 12 believe you said all of us would know that 13 Virginia was 17 at the time you met her. 14 How would we know that? 15 A. I think you know that by her own 16 dates, now that it was in 2000, so her entire 17 tail of me celebrating her 16th birthday is 18 clearly another giant falsehood. 19 Q. But she was 16 and 17 that year, 20 wasn't she? 21 A. Which year? 22 Q. You said it was 2000. 23 A. I think the information that I have 24 that indicates that definitively was 25 something that is privileged, so I can't Page 283 1 G Maxwell - Confidential 2 share with you. 3 Q. So you have privileged information 4 that definitively tells you that she was 17 5 at the time you met her? 6 A. I believe I do. 7 Q. How would we know that? 8 A. What are you asking me? 9 Q. Earlier today you testified that we 10 would know that she was 17 at the time that 11 you met her. 12 How would we know that? 13 A. I imagine you have access to 14 exactly the same information that I do. 15 Q. What is that information? 16 A. Again, it's privileged, I can't 17 share it with you but you have been on this 18 case for, I don't know, much much longer than 19 I have and I imagine you have all the 20 information that I do. 21 Q. Do you know whether your lawyers 22 have produced documents from you that would 23 show the age that Virginia was at the time 24 that you met her? 25 MR. PAGLIUCA: To the extent that Page 284 1 G Maxwell - Confidential 2 calls for a communication that you had 3 with one of your lawyers, I'm 4 instructing you not to answer that 5 question. 6 Q. I assume you, as part of the 7 discovery process, had to collect documents 8 that were relevant to this action, is that 9 correct? 10 A. I did. 11 Q. Did you collect documents that 12 would show that Virginia was 17 at the time 13 that you met her? 14 A. I think you have everything that 15 relates, that I had, contemporaneously per 16 what you asked for that I have that relates 17 to that. 18 Q. Did you have a document that 19 identified that Virginia was 17 at the time 20 that you met her? 21 A. You have all of the documents that 22 I had. 23 Q. I'm not asking what documents. I'm 24 asking, do you have a document that 25 identifies Virginia being 17 at the time you Page 285 1 G Maxwell - Confidential 2 met her? 3 A. You have every document that I 4 have. You have seen every document that I 5 have. 6 Q. That's not what I'm asking. 7 A. I don't recall every document that 8 I gave you, so I don't know. I would have to 9 look at every single document I gave you and 10 then review it but as I recall you have every 11 document that I have. 12 Q. What are you planning to show the 13 jury that will prove that Virginia was 17 14 when you met her? 15 A. Again that's privileged so I can't 16 share that with you. 17 Q. If you're showing the jury, it 18 wouldn't be privileged, so is there a 19 document you have produced in this matter 20 that shows that Virginia was 17 at the time 21 you met her? 22 MR. PAGLIUCA: She answered that 23 question already. She said she doesn't 24 know, she has given you everything. If 25 there is a decision -- assuming for the MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 73 of 106 73 (Pages 286 to 289) Page 286 1 G Maxwell - Confidential 2 moment there is such a document, just 3 hypothetically, and assuming for the 4 moment that it is going to get produced 5 somewhere, if it hasn't already been 6 produced, obviously that would involve a 7 waiver, a future waiver of the 8 privilege. I think that's the answer to 9 the question. 10 Q. Has the document been produced, do 11 you know? 12 A. You have everything that I have 13 given you, so if you can't -- if it's not in 14 those documents, I don't know what to tell 15 you. 16 Q. Your lawyers haven't withheld any 17 documents? 18 A. They are right here. You can ask 19 them. 20 Q. I'm asking you. 21 A. I don't know what -- they're 22 lawyers. 23 Q. When we were talking earlier about 24 Prince Andrew, I asked you whether you had 25 ever given him a gift of a puppet. Page 287 1 G Maxwell - Confidential 2 Did you ever, not as a gift, did 3 you ever see in the presence of Prince Andrew 4 a puppet? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. Can you be more direct, please? 8 Q. Sure. Were you ever in a room with 9 Prince Andrew where there was a puppet? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. Can you be more specific please and 13 can you bound it by time and be more 14 specific, whatever you are actually asking 15 me? 16 Q. Were you ever in a room with Prince 17 Andrew in New York in Jeffrey Epstein's home 18 where there was a puppet? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. What sort of puppet are you asking 22 me? 23 Q. Any kind of puppet? 24 A. You need to be more descriptive. I 25 don't know what you mean by puppet, there is Page 288 1 G Maxwell - Confidential 2 hand puppets, all sorts of puppets. 3 Q. Is there any puppet you've ever 4 seen in Jeffrey Epstein's home in the 5 presence of Prince Andrew? 6 A. Again, puppet, you know, there is 7 lots of types of puppets. 8 Q. Any type of puppet. 9 A. If you want to give me a 10 description of the puppet, I would be perhaps 11 be able to say. 12 Q. Any type of puppet? 13 A. Can you be more detailed? 14 Q. Have you ever seen a puppet in 15 Jeffrey Epstein's home in the presence of 16 Prince Andrew? 17 A. My understanding of a puppet is a 18 small handheld item you have in a circus. I 19 have never seen that. 20 Q. Have you ever seen a puppet which 21 is defined as a movable model of a person or 22 animal that is used in entertainment and 23 typically moved either by strings or 24 controlled from above or by a hand inside it? 25 MR. PAGLIUCA: Objection to the Page 289 1 G Maxwell - Confidential 2 form and foundation. 3 A. I have not seen a puppet that fits 4 exactly that description. 5 Q. Have you seen any puppet that fits 6 any description? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. Can you reask the question, please? 10 Q. Yes. 11 Have you seen any puppet that fits 12 any description in the presence of Prince 13 Andrew in Jeffrey Epstein's home? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. I am not aware of any small 17 handheld puppet that was there. There was a 18 puppet -- not a puppet -- there was a -- I 19 don't know how would you describe it really, 20 I don't know how would you describe it. Not 21 a puppet, I don't know how you would describe 22 it. A caricature of Prince Andrew that was 23 in Jeffrey's home. 24 Q. Did you use that caricature to put 25 the hand of the caricature on Johanna MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 74 of 106 74 (Pages 290 to 293) Page 290 1 G Maxwell - Confidential 2 Sjoberg's breast? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I don't recollect. I recollect the 6 puppet but I don't recollect anything around 7 the puppet. You characterized puppet, I 8 characterize it as, I don't know, as a 9 characterization of Andrew. 10 Q. Do you recollect asking Virginia 11 Roberts to sit on Prince Andrew's lap with 12 the caricature of Prince Andrew? 13 A. I do not recollect that. 14 Q. What do you remember about the 15 caricature of the Prince Andrew caricature 16 when you were in the presence of Prince 17 Andrew, Virginia Roberts and Johanna Sjoberg? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I don't recollect the story as told 21 by Johanna or Virginia. I don't even know 22 who -- I remember the caricature of Prince 23 Andrew and I remember Prince Andrew but I 24 don't recall anything else around the 25 caricature. Page 291 1 G Maxwell - Confidential 2 Q. Did you give it to him? 3 A. I did not. 4 Q. Who gave it to him? 5 A. I don't think it was given to him 6 at all. 7 Q. Did he bring it? 8 A. No. 9 Q. Was it something that was at the 10 house? 11 A. As best I recollect. 12 Q. Was it something that you saw at 13 the house in advance of Prince Andrew's 14 arrival? 15 A. Again, I don't real -- I recollect 16 the caricature, I recollect Prince Andrew, I 17 don't recollect much else around the 18 caricature. 19 Q. Was there a party going on in the 20 house at the time you recollect the 21 caricature? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. You have to be way more specific? 25 Q. Do you remember, you said you Page 292 1 G Maxwell - Confidential 2 recollect this caricature, you recollect 3 Prince Andrew being there. Do you recollect 4 a party going on at the time of that 5 interaction with Prince Andrew and the 6 caricature? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I don't recollect a party -- first 10 of all, they weren't really parties -- I 11 don't recollect a party -- I don't know what 12 you mean by party in the context of that 13 scenario. 14 Q. Who do you recollect being at the 15 home during the time Prince Andrew was there 16 with this caricature? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I only recollect myself with Prince 20 Andrew, I don't recollect anybody else. 21 Q. You don't recollect Jeffrey Epstein 22 being there? 23 A. Actually, no. 24 Q. You don't recollect Johanna Sjoberg 25 being there? Page 293 1 G Maxwell - Confidential 2 A. No. 3 Q. You don't recollect Virginia 4 Roberts being there? 5 A. No. 6 Q. It was just you and Prince Andrew? 7 A. I am not saying it was just me and 8 Prince Andrew, you are asking me do you 9 remember. I only remember Prince Andrew, I 10 remember Prince Andrew and the caricature but 11 I can't place the caricature and everybody 12 else in the same context, the same timeframe 13 you are asking me. 14 Q. Would Prince Andrew typically 15 travel with Secret Service or some sort of 16 security when he would come to visit you and 17 Jeffrey in New York? 18 A. Typically he would have somebody. 19 Q. Would they be in the house or 20 outside of the house? Would they usually 21 stay in the house or outside of the house, in 22 other words guarding the doors or would they 23 come inside? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 75 of 106 75 (Pages 294 to 297) Page 294 1 G Maxwell - Confidential 2 A. Typically, there is no typical 3 because there is no standard procedure, so I 4 can't comment or testify to what secret 5 service would or wouldn't do. 6 Q. Do you remember them being in the 7 house? 8 A. Not specifically. 9 Do you mind if I take a bathroom 10 break. 11 THE VIDEOGRAPHER: It's now 3:51 12 and we are off the record. 13 (Recess.) 14 THE VIDEOGRAPHER: It's now 4:04. 15 We are back on the record and we're 16 starting disk No. 7. 17 Q. Ms. Maxwell, during what time 18 period, I know you said, I believe you said 19 you met Jeffrey in 1991, if I'm correct there 20 and you've known him through the present. 21 During what time period within 22 those years would you say your relationship 23 was the closest with Jeffrey? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 295 1 G Maxwell - Confidential 2 A. What do you mean by close, sorry. 3 Q. I think earlier today you testified 4 that at some point in time you considered 5 yourself to be his girlfriend, is that the 6 closest you would say that your relationship 7 was with him and if so, what time period was 8 that? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I don't think I said I was his 12 girlfriend, I would like to think of myself 13 as maybe, I don't think I -- sometime in the 14 mid '90s. 15 Q. How close was your relationship? 16 A. We were very friendly. 17 Q. Without going into details, was 18 your relationship with him intimate? 19 A. Yes. 20 Q. When was the last time you had 21 contact with Jeffrey Epstein? 22 A. What do you mean by contact. 23 Q. Either a phone call or email or 24 anything of that nature? 25 A. As best as I can recollect when Page 296 1 G Maxwell - Confidential 2 all -- sometime last year. 3 Q. So you haven't talked to him like, 4 for example, last week you didn't talk to 5 him? 6 A. I did not. 7 Q. How many times have you had either 8 direct or indirect, meaning, in the presence 9 of him or calling or emailing, contact with 10 Jeffrey Epstein from December 30, 2014 until 11 now? 12 A. I'm sorry, can you just -- 13 Q. Either in person or by phone or by 14 email, from December 30, 2014 until present. 15 A. I can't really characterize that 16 but not very much. There was a period when 17 in January when you filed your, whatever you 18 filed, where we spoke and then, since then 19 not much at all. 20 Q. Can you estimate how many emails 21 you would have sent Jeffrey from the period 22 of December 30, 2014 to the present? 23 A. Not very many at all. 24 Q. More than 20? 25 A. I really wouldn't be able to Page 297 1 G Maxwell - Confidential 2 characterize it because it wouldn't be that 3 many. I wouldn't know. 4 Q. More than 50? 5 A. It would be on the lesser side, not 6 on the more side. 7 Q. Can you give me a number? 8 A. I honestly couldn't. I would be 9 guessing. 10 Q. How many emails has Jeffrey sent 11 you from the period December 30, 2014 to the 12 present? 13 A. I would say less emails, even less 14 emails than I sent him. 15 Q. More than 20? 16 A. I would say on the lesser side. 17 Q. Less meaning 10? 18 A. I really can't recall, very little. 19 Q. When you spoke with Jeffrey in 20 January of 2015, what did he say to you? 21 A. I really couldn't remember exactly 22 what he said to me. 23 Q. Did you talk about Virginia 24 Roberts? 25 A. I'm sure we did but I couldn't MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 76 of 106 76 (Pages 298 to 301) Page 298 1 G Maxwell - Confidential 2 recall the exact conversation. 3 Q. Does Jeffrey Epstein send you text 4 messages? 5 A. No. 6 Q. Do you send him text messages? 7 A. No. 8 Q. How many phone calls have you had 9 with Jeffrey Epstein since December 30, 2014? 10 A. Again, very few. 11 Q. More than five? 12 A. Probably as many as the few emails 13 that I would characterize, so just very few. 14 I mean a small number. 15 Q. Are you aware of any disagreement 16 between your views about Virginia Roberts and 17 Jeffrey's views about Virginia Roberts? 18 MR. PAGLIUCA: Object to the form 19 and foundation 20 A. I cannot speculate to his views. I 21 can only testify on my views. 22 Q. Earlier you went through the series 23 of lies. Have you talked to Jeffrey about 24 the lies and does he agree with you? 25 A. I have discussed some of the issues Page 299 1 G Maxwell - Confidential 2 with him, I can't remember specifically which 3 ones. I just don't recall. I'm sorry. 4 Q. Do you recall him telling you that 5 he didn't agree with you on any of those? 6 A. I don't recall him saying that. 7 Q. Do you have a joint defense 8 agreement with Jeffrey Epstein? 9 A. I believe I do. 10 Q. Do you have a joint defense 11 agreement with Alan Dershowitz? 12 A. I don't believe I do. 13 Q. Earlier today in your testimony, 14 when I was asking you some questions, you 15 said that you couldn't answer but that 16 Jeffrey Epstein could answer that question. 17 Would Jeffrey Epstein be in a 18 position to confirm or deny some of the 19 obvious lies that we've discussed today? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I can't possibly testify to what 23 Jeffrey could or would say. I can't speak 24 for him. 25 Q. Would Jeffrey be able to confirm or Page 300 1 G Maxwell - Confidential 2 deny whether he had sex with Virginia 3 Roberts? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't say what Jeffrey would say. 7 Q. Has he discussed that with you? 8 A. He has not. 9 Q. Would Jeffrey be able to confirm or 10 deny whether he had a sexual massage from 11 Virginia that first time she came to his 12 mansion in Palm Beach? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I cannot speak for what he would 16 say. I can only speak for what I would say. 17 So as I testified everything that she said 18 about that first meeting didn't happen so... 19 Q. Has he told that you everything 20 about that first meeting didn't happen? 21 A. I know it didn't happen because she 22 put me in that room. 23 Q. I understand you know. But has 24 Jeffrey said when you are talking about the 25 obvious lies, oh yeah, that never happened? Page 301 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I can't specifically recall that. 5 I don't know, but he has to agree with me 6 because it didn't happen. 7 Q. Can Jeffrey Epstein, would he be 8 able to confirm or deny whether he had sex 9 with underage girls? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I can't testify to what Jeffrey 13 would say. 14 Q. Can Jeffrey confirm or deny whether 15 Bill Clinton was on Jeffrey's island? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. I can't say what Jeffrey would say. 19 I can only say what I know to be true. 20 Q. Has Jeffrey talked to you about the 21 fact whether Bill Clinton was on his island? 22 A. As best as I can recollect, he said 23 he was not on the island. As best as I can 24 recollect. 25 Q. Can Jeffrey Epstein confirm whether MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 77 of 106 77 (Pages 302 to 305) Page 302 1 G Maxwell - Confidential 2 he and Virginia Roberts were together in the 3 presence of Prince Andrew? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't speak to what Jeffrey would 7 say. 8 Q. Has he talked to about Virginia 9 Roberts' statement that she was in the 10 presence of Prince Andrew? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I have not discussed individual 14 presences with Virginia. That's not -- I'm 15 only concerned with what I know to be the 16 stuff about me. So my focus has always been 17 the lies and the obvious lies as something I 18 can personally attest to. I cannot possibly 19 talk for anything else. 20 Q. Has Jeffrey Epstein said to you 21 anything along the lines of Virginia is lying 22 when she says she met Prince Andrew? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Again, I'm not talking about what Page 303 1 G Maxwell - Confidential 2 she says as regards to other people. I can 3 talk to things as regards to me. 4 Q. I'm asking if Jeffrey ever said 5 that to you? 6 A. I don't recollect specific 7 conversations along those things. 8 Q. You don't recollect him saying that 9 to you? 10 A. I don't recollect him saying to me 11 that Virginia didn't meet Prince Andrew. I'm 12 sure that wouldn't be a conversation that we 13 would have. It doesn't effect me whether -- 14 so I'm really only concerned about the lies 15 that were told as regards to me. 16 Q. Can Jeffrey Epstein confirm or deny 17 whether you sent Virginia to give Glenn Dubin 18 a massage? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I can't say what Jeffrey would say, 22 I can tell you I didn't. I can't tell you 23 what anybody else. 24 Q. Have you discussed with him 25 Virginia's allegation that she gave Glenn Page 304 1 G Maxwell - Confidential 2 Dubin a massage? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I didn't know that she did say 6 that. 7 Q. Do you know whether Jeffrey Epstein 8 has ever sent anybody to Glenn Dubin to 9 perform a massage for him? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I couldn't possibly recollect 13 whether he did anything like that. 14 Q. Did you ever send anybody, not 15 Virginia, anybody else over to Glenn Dubin's 16 home for a massage? 17 A. Not to the best of my knowledge. 18 Q. Do you know one of Alexander 19 Dixon's friend by the name of Anuska 20 DiGeorgio? 21 A. I do recollect a person of that 22 name. 23 Q. How do you know her? 24 A. I don't recollect. 25 Q. Did you meet her through Jeffrey? Page 305 1 G Maxwell - Confidential 2 A. I don't recollect. 3 Q. Do you recall when you met her? 4 A. I do not recollect. 5 Q. How many times have you seen Anuska 6 DiGeorgio in your life? 7 A. The only reason I remember is 8 because it's an unusual name but I couldn't 9 tell you anything else. 10 Q. You didn't see her on a regular 11 basis, she wasn't one of your friends? 12 A. No. 13 Q. Was Anuska DiGeorgio a masseuse? 14 A. Not to my knowledge. 15 Q. Do you have knowledge of whether 16 she had a sexual relationship with Jeffrey 17 Epstein? 18 A. I have no knowledge of that. 19 Q. When was the last time you spoke 20 with her? 21 A. A very long -- I have no idea. 22 Q. Would it be years? 23 A. Yes. 24 Q. What do you remember about Anuska 25 DiGeorgio? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 78 of 106 78 (Pages 306 to 309) Page 306 1 G Maxwell - Confidential 2 A. Nothing really. 3 Q. Do you remember what she looks 4 like? 5 A. I would just be speculating on how 6 I remember. I couldn't describe her. 7 Q. Do you recall traveling with her? 8 A. I don't. 9 Q. Did you ever go to her home? 10 A. I don't believe I did. 11 Q. Do you know where she lives? 12 A. I don't. 13 Q. Would you have met her through 14 Jeffrey Epstein? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I already testified I don't 18 recollect how I met her and I remember her 19 because her name is very unusual. 20 Q. So what's your -- what recollection 21 do you have of her, do you have a specific 22 recollection of meeting her somewhere, you 23 just don't know when that was or how do you 24 know that name Anuska DiGeorgio? 25 MR. PAGLIUCA: Objection to the Page 307 1 G Maxwell - Confidential 2 form and foundation. 3 A. I don't know why the name is -- I'm 4 sorry -- I can't -- I have no idea. I 5 recognize the name but that's it. 6 Q. Was Johanna Sjoberg a masseuse? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. What are you asking me, I'm sorry? 10 Q. When Johanna Sjoberg worked for 11 Jeffrey Epstein, did she perform massages? 12 A. I've testified that when Johanna 13 came originally, she came to answer 14 telephones. I believe at some point she 15 became a masseuse. I don't recollect when 16 and I personally had massages from Johanna. 17 Q. What did Johanna do for Jeffrey 18 Epstein, did she perform massages, anything 19 else? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. When she came she answered phones 23 and at some point, I believe, I don't have 24 any firm recollection, but I believe she went 25 to school and became a masseuse and I had Page 308 1 G Maxwell - Confidential 2 massages from her. 3 Q. Did you ever have any sexual 4 interaction with her? 5 MR. PAGLIUCA: Object to the form 6 and foundation and I'm going to instruct 7 you if we're talking about any 8 consensual adult contact, you are not 9 allowed to answer the question. 10 Q. Did you have any sexual contact 11 with her in the presence of Jeffrey Epstein? 12 MR. PAGLIUCA: Same instruction. 13 Q. Did you have any sexual contact 14 with her in the presence of anybody other 15 than Jeffrey Epstein? 16 MR. PAGLIUCA: Same instruction. 17 Q. How many massages did you receive 18 from Johanna? 19 A. I really don't recall but a fair 20 amount. 21 Q. Did the massages involve sex? 22 MR. PAGLIUCA: I'm going to 23 instruct you not to answer. 24 Q. Have you ever engaged in sex with 25 any female? Page 309 1 G Maxwell - Confidential 2 MR. PAGLIUCA: I'm going to 3 instruct you not to answer. 4 MS. McCAWLEY: I want the record to 5 reflect that Ms. Maxwell's attorney is 6 directing her not to answer this series 7 of questions. 8 MR. PAGLIUCA: It definitely does. 9 Q. Were you responsible for 10 introducing Anuska to Jeffrey Epstein? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I already testified that I don't 14 really recall Anuska. 15 Q. Were you responsible for 16 introducing Johanna to Jeffrey Epstein? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. Again, I don't like the 20 characterization of introduction. Johanna 21 came to answer telephones. 22 Q. When did you -- were you the person 23 who brought or introduced or met Johanna for 24 purposes of bringing her to Jeffrey Epstein's 25 home? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 79 of 106 79 (Pages 310 to 313) Page 310 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. That's not how I would characterize 5 that. 6 Q. How would you characterize it? 7 A. I have testified that I'm 8 responsible for finding professional people 9 to work in the homes, age appropriate adult 10 people, so from pool attendants, to 11 gardeners, to chefs, to housekeepers, to 12 butlers, to chauffeurs and one of the 13 functions was to be able to answer the 14 telephones and in the context of finding 15 someone to answer the telephones, I did look 16 to try to find appropriate people to answer 17 the phones. 18 Q. So did you find Johanna for 19 purposes of that role? 20 A. So in the course of looking for 21 somebody to answer phones at the house, 22 Johanna was one of the people who said that 23 she was willing to answer phones. 24 Q. Did you approach her at her school 25 campus? Page 311 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. I honestly don't recall how, in 5 that moment, how I met Johanna and how she 6 came to get the job but... 7 Q. Did you typically, in your work for 8 Jeffrey Epstein, would you typically go to 9 school campuses to try to find individuals to 10 work for Jeffrey Epstein? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I never -- what do you mean by 14 school? Let's characterize school. 15 Q. Any kind of school. 16 A. Obviously not. I never went to any 17 school with young people. Johanna, I believe 18 came from an adult university, as I would 19 know in England, so university, I went there 20 but I never went, as I best recollect, 21 anywhere else. 22 Q. Did you -- what university was it 23 that you went to? 24 A. I don't recall the university that 25 she went to right now. Page 312 1 G Maxwell - Confidential 2 Q. Would you visit more than one 3 university to try to find individuals to work 4 for Jeffrey Epstein? 5 A. As I recollect, I think that's, in 6 fact, the only university I went to. 7 Q. Did you go there more than once? 8 A. I think I went twice. 9 Q. Who else did you find from that 10 university, was there anybody other than 11 Johanna? 12 A. I don't recollect, I'm sorry. 13 Q. We are going to mark this as 14 Maxwell 13? 15 (Maxwell Exhibit 13, documents, 16 marked for identification.) 17 Q. Can you take a look at the document 18 I put in front of you, please. 19 Are you familiar with this 20 document? 21 A. I'm familiar with this actual 22 document. 23 Q. How was this document created? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 313 1 G Maxwell - Confidential 2 A. I don't know how this document was 3 created. 4 Q. You were involved in the creation 5 of this document? 6 A. I think you can see from the date 7 that it's 2004, 2005, so no. 8 Q. You weren't involved in the 9 creation of this document. 10 Did you -- we talked earlier about 11 Mr. Epstein's house, I'm talking about the 12 Palm Beach house where you said there was a 13 computer on the desk, that employees had 14 access to -- people who worked for Jeffrey 15 Epstein may have had access to? 16 A. I think anybody could have had 17 access to that. 18 Q. Was that computer used, if you know 19 to keep a log of addresses and phone contact 20 information for Jeffrey Epstein? 21 A. Are we talking about when this 22 document was created. 23 Q. In general, was there, on that 24 computer during the time that you were 25 present with Jeffrey Epstein, was there a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 80 of 106 80 (Pages 314 to 317) Page 314 1 G Maxwell - Confidential 2 mechanism by which you kept electronic 3 information of names and addresses of 4 individuals that he knew? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I can't testify to what was on that 8 computer or not after I was gone. 9 Q. Not when you were gone, when you 10 were there. If Jeffrey wanted to call, for 11 example, say Les Wexner, would someone be 12 able to go to that computer to pull up the 13 address information and phone contact 14 information for that individual? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I couldn't possibly say. 18 Q. Did you ever have to keep track of 19 address or phone contact information for 20 Jeffrey Epstein? 21 A. That was not my job. 22 Q. Did you ever do it? 23 A. I am not responsible for keeping 24 his numbers so that wasn't my job at all. 25 Q. But did you ever do it? I know Page 315 1 G Maxwell - Confidential 2 it's not your job but did you ever do it, did 3 you ever keep phone contact information for 4 him? 5 A. During the course of the time we 6 were together, if he gave me a telephone 7 number, I would give it to an assistant to 8 put in the computer, I could do that. 9 Q. Would he ask you for contact 10 information for different individuals, if he 11 wanted to contact someone? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. In the course of the long period of 15 time when I was there, it certainly would be 16 possible for him to ask me for a telephone 17 number and if I had the -- I wouldn't always 18 have it -- I'm sure it happened. 19 Q. Was there a hardcopy book in 20 addition to the computer, a hardcopy book 21 that you could look for numbers that were 22 relevant to Jeffrey Epstein's life and 23 something on the computer or was it just an 24 electronic version? 25 MR. PAGLIUCA: Objection to the Page 316 1 G Maxwell - Confidential 2 form and foundation. 3 Q. Was there a hard copy book as well 4 as something on the computer or was there 5 only electronic information on the phone 6 numbers? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I can only testify to what I know 10 obviously, and I believe that this is a copy 11 of a stolen document. I would love to know 12 how you guys got it. 13 Q. I'm asking during the time you 14 worked for Jeffrey Epstein, was there a 15 hardcopy document of any kind that kept phone 16 numbers for Jeffrey Epstein, if he needed to 17 contact someone? 18 A. The stolen document I have in front 19 of me that you have is what you are referring 20 to. 21 Q. So there was, during your time when 22 you were there, there was no other, you 23 mentioned there was information on a 24 computer. Was there any hardcopy document 25 that you could refer to to find someone's Page 317 1 G Maxwell - Confidential 2 number? 3 A. You have the stolen document in 4 front of you. 5 Q. You had access to this when you 6 worked for Jeffrey Epstein? 7 A. This is, I believe, the book that 8 was stolen, that was the hardcopy of whatever 9 was there. 10 Q. So when you were working for 11 Jeffrey Epstein, you were able to access this 12 book? 13 A. This book -- if this is what this 14 is, I believe it was, this is the stolen 15 document from his house. 16 Q. And you were able to access it when 17 you worked for him? 18 A. It was a document that was printed 19 that you could, if you needed to, look for a 20 number. 21 Q. Do you know how this book was 22 created? 23 A. No. 24 Q. When you referred to it a moment 25 ago, to a stolen document, when Alfredo MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 81 of 106 81 (Pages 318 to 321) Page 318 1 G Maxwell - Confidential 2 Rodriguez turned this document over to the 3 FBI, are you aware he described it as a 4 document that came from your computer? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I have no idea what he said or 8 didn't say, so if you want me to reference 9 something he said, you need to show it to me. 10 Q. Did you keep this document, an 11 electronic copy of it, on your personal 12 computer? 13 A. I don't recollect. 14 Q. If you had to update something, for 15 example, if there was a new number, a new 16 individual that Jeffrey had hired that you 17 were going to track, would you input that 18 information into this document on your 19 computer? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I've already testified that I'm not 23 responsible for updating and keeping these 24 records. 25 Q. Did you have this document on your Page 319 1 G Maxwell - Confidential 2 computer, your personal computer? 3 A. I told you, I don't recollect 4 having this document on my computer. 5 Q. Do you know what computers this 6 document was on, if more than one? 7 A. I'm sorry, this is a long time ago 8 and I don't recall exactly how this was all 9 managed. 10 Q. If you didn't create this document, 11 do you know who did? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I don't. 15 Q. I'm going to direct your attention 16 to part of this document. It's towards the 17 back, it's going to be page 91 and it has 18 bates label Giuffre 001663. I'm going to 19 direct your attention to the section that 20 says, Massage Florida. 21 Did you input any of the names or 22 numbers under that section? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. So this document is produced in Page 320 1 G Maxwell - Confidential 2 2004, 2005, so, no. 3 Q. But I'm sorry, correct me if I'm 4 misunderstanding your testimony, I thought 5 you said when you were working with Jeffrey, 6 that this document existed and it was 7 something you utilized? 8 A. I can't possibly tell you what 9 numbers were added or not added subsequent to 10 my departure. 11 Q. So you can't recall if you added 12 any of these numbers? 13 MR. PAGLIUCA: Objection to the 14 form and foundation, mischaracterizes 15 the witness' testimony. 16 Q. Are there any numbers on here or 17 names that you recognize that you would have 18 entered into this section? 19 A. I already testified that I'm not 20 responsible for inputting numbers and names 21 into this so I would not be able to tell you. 22 Q. Are there any names or numbers 23 under this section, Massage Florida, that you 24 would have provided to an assistant to input 25 into this document? Page 321 1 G Maxwell - Confidential 2 A. I can't possibly say. 3 Q. Do you see under Massage Florida, 4 about halfway down the first column, do you 5 see a number that says Johanna's cell? 6 MR. PAGLIUCA: What page? 7 Q. It's 91, Bates number 001663. 8 About halfway down, it says in the first 9 column, it says Johanna's cell. 10 Do you see that? 11 A. I do. 12 Q. Would you have provided after, I 13 know you didn't hire her, Jeffrey hired her 14 but after you brought her to Jeffrey, would 15 you have given her cell phone number to an 16 assistant to input into this document? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. I didn't bring her to Jeffrey, the 20 way you characterize and I would have no 21 knowledge of how this number ended up in this 22 book. 23 Q. I believe you, and I will try to 24 use your words so we are clear, you met 25 Johanna, is that correct? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 82 of 106 82 (Pages 322 to 325) Page 322 1 G Maxwell - Confidential 2 A. Yes. 3 Q. And then she began working for 4 Jeffrey? 5 A. Yes. 6 Q. Would you have provided whomever 7 was in charge of keeping this updated with 8 Johanna's cell number so you would be able to 9 contact her if needed? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I don't know. It could have been a 13 number of different ways, it it could have 14 been Jeffrey who gave it to somebody. 15 Q. You just don't remember doing that? 16 A. I do not. 17 Q. Now, as you look -- I want you to 18 take a look at the Florida massage list, it's 19 three columns there. 20 Do you, as you look at those names 21 on the various columns, do you know the ages 22 of any of the girls in this list? 23 A. I don't know. One, I don't know 24 who all the people are on this list and I 25 certainly don't know the ages. Page 323 1 G Maxwell - Confidential 2 Q. Do you know what their 3 qualifications are? 4 A. I don't know who the people are in 5 general so of course I don't know what their 6 qualifications are. 7 Q. Do you know why Jeffrey has so many 8 masseuses listed in Florida in his book here? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. Again, this book was created post 12 my departure, so I couldn't explain why all 13 these people were here. 14 Q. When you were there, you said this 15 book existed? 16 A. Yes. 17 Q. So when you were there, were there 18 a number of masseuses listed under the 19 Florida massage? 20 MR. PAGLIUCA: Objection to the 21 form and foundation and 22 mischaracterization of the witness' 23 testimony. 24 Q. I'm asking you a question. 25 When you were there, were there a Page 324 1 G Maxwell - Confidential 2 number of masseuses listed under the Florida 3 massage section? 4 A. When I was there, I would have, of 5 course there would have been some masseuses 6 listed but I could not tell you who or how 7 many and this -- I could not possibly because 8 I wouldn't remember. 9 Q. Do you know why Jeffrey would have 10 had so many names listed under his massage 11 Florida? 12 MR. PAGLIUCA: Objection to form 13 and foundation. 14 A. I can't testify to why Jeffrey has 15 so many. 16 Q. Did he use a different masseuse 17 every day? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 Q. You can answer. 21 A. When I was there he had a massage 22 roughly every day, one masseuse, and mostly 23 he would have them at random times, so it 24 would be difficult if you just only had one 25 person, man, woman, for an adult massage, to Page 325 1 G Maxwell - Confidential 2 come and be available for whatever time it 3 was. So he would have more than one person 4 that he could call for a massage because at 5 any given time the one that he called first 6 may not have been available. 7 Q. So would it typically be a 8 different person each day that would give him 9 a massage? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. It would be, when I was there, 13 based on availability. 14 Q. Would it surprise you to learn that 15 the Federal Government found that some of the 16 girls on this list under massage Florida were 17 under the age of 18? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I can't testify to what the 21 government found or did not find because I 22 would have no knowledge of it. 23 Q. I'm asking if you would be 24 surprised by that? 25 MR. PAGLIUCA: Form and foundation. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 83 of 106 83 (Pages 326 to 329) Page 326 1 G Maxwell - Confidential 2 A. I have knowledge of it. I can't 3 speculate. 4 Q. On the second column, towards the 5 bottom, there is the name, it's one up from 6 the bottom, there is the name Gwendolyn Beck, 7 do you know Gwendolyn Beck? 8 A. I do. 9 Q. Who is she? 10 A. She was a friend of Jeffrey's. 11 Q. Is she a masseuse? 12 A. She, I don't think she was a 13 masseuse, no. 14 Q. Why would be she listed under 15 Florida massages? 16 A. An input error. 17 Q. Is this list any individual that 18 would have sex with Jeffrey? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I wouldn't have any knowledge of 22 that. 23 Q. Do you know if Jeffrey had sex with 24 Gwendolyn Beck? 25 MR. PAGLIUCA: Object to the form Page 327 1 G Maxwell - Confidential 2 and foundation. 3 A. First of all, I wouldn't have any 4 knowledge of that. 5 MS. McCAWLEY: We are going to take 6 a quick break. 7 THE VIDEOGRAPHER: It's now 4:39 8 and we are off the record. 9 (Recess.) 10 THE VIDEOGRAPHER: It's now 4:54 11 and we are as back on the record 12 starting disk number 8. 13 Q. Ms. Maxwell, we were talking 14 earlier about the journal and I believe you 15 said in 2004, 2005, you were no longer 16 working and responsible for that journal, is 17 that correct? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. What are we referring to, this 21 document right here? 22 Q. Yes. 23 A. I don't know who is the author of 24 this or I can't tell you what is in here 25 versus what would have been here when I was Page 328 1 G Maxwell - Confidential 2 around. I can't testify to that. 3 Q. Were you around in 2004, 2005? 4 A. I already testified that I was 5 there when Jeffrey's mother passed away and 6 so you know, I did visit for her passing and 7 I believe I was there for a couple of days in 8 2005. 9 Q. So if an employee of Mr. Epstein in 10 2004 said that you were the employee's direct 11 supervisor, would that be incorrect? 12 MR. PAGLIUCA: Objection to form 13 and foundation. 14 A. What employee, what's the 15 circumstances and what is the story, I don't 16 know what you are asking me. 17 Q. If Alfredo Rodriguez said in 2004 18 when he was hired, you were his direct 19 supervisor, would that be true? 20 A. No. 21 Q. Were you in 2004 supervising Sarah 22 Kellen? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. I never supervised Sarah Kellen. Page 329 1 G Maxwell - Confidential 2 Q. Did Sarah Kellen take orders from 3 you? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. She worked for Jeffrey. 7 Q. If Alfredo Rodriguez said you had 8 knowledge of underage girls coming to 9 Jeffrey's home for the purpose of sex, would 10 you contend that that is truthful? 11 MR. PAGLIUCA: Objection to the 12 form and foundation of the question. 13 A. I have no idea what you are talking 14 about, I'm sorry. 15 Q. If Alfredo Rodriguez said that you 16 have knowledge of underage girls coming to 17 Jeffrey's home for the purpose of having 18 massages involving sex, would you say that 19 that statement is truthful? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I can't testify to what Alfredo 23 said or didn't say. 24 Q. I'm saying if Alfredo said that you 25 had knowledge that there were girls coming MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 84 of 106 84 (Pages 330 to 333) Page 330 1 G Maxwell - Confidential 2 over to the house that were underage for the 3 purposes of sex, would that statement be 4 true? 5 MR. PAGLIUCA: Objection to form 6 and foundation. 7 A. I can't testify to what Alfredo 8 said or didn't say or what he thought. 9 Q. Did you have knowledge of underage 10 girls coming to Jeffrey Epstein's house for 11 the purpose of sex? 12 A. No. 13 Q. Earlier I believe you testified, 14 correct me if I'm wrong, that the document 15 that is in front of you, the thicker document 16 was a stolen document. 17 Do you know who stole that 18 document? 19 A. I have read that Alfredo stole the 20 document. 21 Q. And where have you read that? 22 A. I believe it was reported in the 23 press. 24 Q. Earlier we were talking about the 25 computers at Jeffrey Epstein's home. Did you Page 331 1 G Maxwell - Confidential 2 have a computer that was your computer 3 located in Jeffrey Epstein's home? 4 MR. PAGLIUCA: Objection to form 5 and foundation. 6 A. I've testified to the computer 7 already. Even when I was around, there was a 8 computer that people had access to. 9 Q. So is Alfredo Rodriguez telling the 10 truth when he says that he downloaded that 11 book from your computer? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I couldn't possibly tell you what 15 Alfredo did or didn't do or said or didn't 16 say. 17 Q. Was it on your computer? 18 A. I already testified I have no idea 19 where this document came from. 20 Q. Did you have a list of names of 21 individuals with contact information for 22 Jeffrey Epstein on your personal computer? 23 A. Again, that wasn't my computer. I 24 already said that was a computer that lots of 25 people would have, so I have no recollection Page 332 1 G Maxwell - Confidential 2 of this document being on it, so I don't know 3 where this came from. 4 Q. I understand the computer at the 5 house that you're referencing. On a personal 6 computer of yours, did you have that 7 document? 8 A. I don't know where this document 9 came from, so I can't possibly say this 10 document was on any computer that I may have 11 had access to. 12 Q. On a personal computer of your own, 13 did you have lists of the phone numbers and 14 contact information relating to Jeffrey 15 Epstein? 16 A. Like everybody, I have an address 17 book but I can't possibly testify to where 18 this thing came from. 19 Q. Was it your address book or was it 20 addresses that related to Jeffrey Epstein? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I don't know what you're asking me. 24 Q. On your personal computer, the 25 address book you are referencing, was it your Page 333 1 G Maxwell - Confidential 2 address book with individuals you knew or was 3 it an address book for your employer, Jeffrey 4 Epstein? 5 A. Jeffrey has his situation and I 6 have no -- this is Jeffrey's, it came from 7 his home, so I can't testify to anything 8 about this in that period of time. 9 Q. So you didn't have on your computer 10 a list of contact information for individuals 11 that was related to Jeffrey Epstein? 12 A. I don't recall exactly what I had 13 back in 2004 and 2005, so I can't say what I 14 had back then that relates to his addresses, 15 I can't recall. 16 Q. So is it possible that someone 17 could have downloaded from your personal 18 computer a list of names and address that 19 were affiliated with Jeffrey Epstein? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. This didn't come from any computer 23 of mine. 24 Q. But is it possible that someone 25 could have downloaded a list of names and MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 85 of 106 85 (Pages 334 to 337) Page 334 1 G Maxwell - Confidential 2 addresses affiliated with Jeffrey Epstein 3 from your computer? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I already said, I didn't have a 7 computer there, so I don't know where this 8 came from, I have no idea. 9 Q. I'm going to read to you some 10 testimony from Alfredo Rodriguez's deposition 11 and it's on page 370 and I want to ask you a 12 question about it, if it's true or false? 13 MR. PAGLIUCA: I'm going to object 14 unless you show the witness the 15 document. 16 MS. McCAWLEY: I will pass it. We 17 are not going to mark it. We will skip 18 it. 19 Q. Did you ever tell Alfredo Rodriguez 20 that he better watch out and better keep his 21 mouth shut with respect to what occurred at 22 Mr. Epstein's home? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. It doesn't sound like anything I Page 335 1 G Maxwell - Confidential 2 would say. 3 Q. Did you ever threaten Alfredo 4 Rodriguez in any way if he were to disclose 5 information he learned from his employment 6 with Jeffrey Epstein? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I'm happy to answer. No, I never 10 threatened him in any way. 11 Q. Were you concerned that he was 12 going to disclose that Jeffrey Epstein was 13 trafficking underage girls? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. First of all, there are so many 17 things wrong with that question, but I have 18 no knowledge of what you are talking about. 19 Q. Have you ever contacted or 20 instructed anyone to contact any witness in 21 this case for the purposes of threatening 22 them not to testify in this case? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I have never called anybody with Page 336 1 G Maxwell - Confidential 2 reference to this case with any, anything you 3 just mentioned, I never threatened anyone. 4 Q. Have you ever directed anyone to 5 call any witnesses relevant to this case and 6 threaten them not to testify? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I never done such a thing. 10 Q. Did Jeffrey Epstein or you ever ask 11 any female, regardless of age, to carry 12 Jeffrey's baby for him? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 Q. Or anything along those lines? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Can you repeat the question, 19 please? 20 Q. Did you or Jeffrey Epstein ever ask 21 any female, regardless of age, to carry 22 Jeffrey Epstein's baby for him? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Are you asking -- Page 337 1 G Maxwell - Confidential 2 Q. To become pregnant, did you or 3 Jeffrey Epstein ever ask any female to become 4 pregnant and carry Jeffrey Epstein's baby for 5 you or for Jeffrey? 6 MR. PAGLIUCA: Objection to form 7 and foundation. 8 A. You need to be very specific. I 9 have no idea what you are talking about. 10 That's completely rubbish. 11 Q. Did you or Jeffrey Epstein ask any 12 female to become pregnant and carry his baby 13 for either him or you? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. Go ahead. 16 A. I can't testify to anything Jeffrey 17 did or didn't do when I am not present, but I 18 have never asked anybody to carry a baby for 19 me. 20 Q. Or anything along those lines? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 Q. I want to make sure we are talking 24 about the same thing, not physically carry a 25 baby, I mean become pregnant with a baby? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 86 of 106 86 (Pages 338 to 341) Page 338 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 Q. I want to make sure we are clear. 5 A. I don't know what you are asking. 6 Q. That's why I want to make sure we 7 are clear. 8 A. We are clear. I never asked 9 anybody to carry a baby for me. 10 Q. Do you know if Jeffrey ever asked 11 anybody to carry a baby for him? 12 A. I'm not going to characterize any 13 conversation Jeffrey had with somebody else. 14 Q. You are not aware of that, is that 15 your testimony? 16 A. I am testifying I never have and I 17 will not testify for anything for Jeffrey. 18 Q. Did you ever hear Jeffrey ask 19 anybody to carry a baby for him? 20 A. I don't recollect conversation 21 about Jeffrey and babies in any form. 22 Q. Did Jeffrey ever tell he wanted to 23 have a baby? 24 A. I don't recollect baby 25 conversations with Jeffrey. Page 339 1 G Maxwell - Confidential 2 Q. So he never told you he wanted to 3 have a baby? 4 A. I don't recollect any baby 5 conversations with him saying he wanted to 6 have a baby. 7 Q. Did you ever bring any females to 8 the Dubin's house that were not your friends' 9 children that were under the age of 18? 10 MR. PAGLIUCA: Objection to form 11 and foundation. 12 A. I have never, to my knowledge, 13 brought anybody under the age of 18 that's 14 not a friend of my family or my nieces or 15 nephews to the Dubin household. 16 Q. Earlier today you testified, I 17 believe, that with respect to your town home 18 Jeffrey paid for some of that and then gave 19 you a loan, is that correct? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I said, actually I think it was a 23 loan, I believe it was a loan. 24 Q. The whole thing? 25 A. As best as I can recollect. Page 340 1 G Maxwell - Confidential 2 Q. Did you pay that loan back? 3 A. I don't have any outstanding loans 4 with him. 5 Q. So you paid it back? 6 A. I don't have any outstanding loans 7 with him. 8 Q. That's not an answer to my 9 question. 10 Did you pay back Jeffrey for the 11 loans? 12 A. I have paid back any loans I had 13 with him. 14 Q. You have or haven't? 15 A. Have. 16 Q. Were there any other gifts that 17 Jeffrey gave you during the time period of 18 say 1999 to the present that were in excess 19 of $50,000? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. What's the question again? 23 Q. Did Jeffrey give you any gifts in 24 excess of amounts of $50,000, I'm not talking 25 about a scarf here or something Page 341 1 G Maxwell - Confidential 2 insignificant, from 1999 to the present? 3 A. I can't recollect any gifts. 4 Q. Did he ever buy you a car? 5 A. I really don't recall, I can't 6 recall, it's a long time ago. 7 Q. You can't recall if Jeffrey Epstein 8 ever bought you a car? 9 A. I believe he did buy me a car, I 10 don't recall how much it cost. I don't 11 recall any of the financial details of that. 12 Q. Do you still have that car? 13 A. I don't. 14 Q. How long ago did you get rid of 15 that car? 16 A. I don't recall all the cars. There 17 was a car back -- there was -- I don't 18 recall, I'm sorry. 19 Q. He supplied you with several cars? 20 MR. PAGLIUCA: Object to the form 21 and the mischaracterization of the 22 testimony. 23 A. I don't recall details of the cars. 24 Q. Did he supply with you more than 25 one car? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 87 of 106 87 (Pages 342 to 345) Page 342 1 G Maxwell - Confidential 2 A. Over the course of time, I've 3 driven many cars. 4 Q. That Jeffrey provided to you? 5 A. They were cars that could be driven 6 and I just don't recall them. 7 Q. Were they in your name? 8 A. I don't recall. 9 Q. You don't recall if Jeffrey Epstein 10 ever put a car in your name? 11 A. We are talking a long time ago, I 12 really don't recall. 13 Q. When is the last time you had a car 14 from Jeffrey Epstein that you used? 15 A. 2000, 2001, 2002. 16 Q. Do you recall what kind of a car 17 that was? 18 A. I don't recall, I'm sorry. 19 Q. Did Jeffrey Epstein purchase 20 anything else for you besides the townhouse 21 and cars that would be over the amount of 22 $50,000? 23 A. I didn't say that he did, I said I 24 had a loan. 25 Q. Besides the loan, I'm sorry, you Page 343 1 G Maxwell - Confidential 2 are right, you did say you had a loan and you 3 said you paid that back, correct? 4 A. That's my testimony. 5 Q. Anything else in excess of $50,000 6 that he would have purchased for you? 7 A. We are talking 2002, 2001, I don't 8 recall any gifts really. 9 Q. When is the last time Jeffrey 10 Epstein gave you a gift in excess of $50,000? 11 MR. PAGLIUCA: Assumes facts not in 12 evidence. Form and foundation. 13 Q. You're saying you don't remember 14 from 2001 and 2002. I'm asking when is the 15 last time you remember Jeffrey Epstein 16 purchasing a gift for you? 17 A. I don't recall gifts in excess of 18 $50,000, I barely recall gifts, I barely 19 recall a lot of this -- I'm sorry, I don't 20 recall. 21 Q. Is Jeffrey Epstein paying for your 22 legal fees in this case? 23 A. No. 24 Q. Is he paying for anything related 25 to this case? Page 344 1 G Maxwell - Confidential 2 A. No. 3 Q. Are you aware of any grand theft 4 police report relating to Virginia Roberts? 5 A. I believe I've read a report in the 6 press on that. 7 Q. Did you provide the press with a 8 report on a grand theft by Virginia Roberts? 9 A. I don't know how the press got that 10 story. 11 Q. Do you know if Virginia Roberts 12 committed a grand theft? 13 A. I only know what I read in the 14 press. 15 Q. Did you ever state to the press 16 that Virginia Roberts committed a grand 17 theft? 18 A. I've never had any conversation 19 directly with press. 20 Q. Did any of your representatives 21 ever inform the press that Virginia Roberts 22 committed a grand theft? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I have no way of knowing what my Page 345 1 G Maxwell - Confidential 2 representatives said to press or didn't. 3 Q. Did they ever discuss with you the 4 fact that they were going to report that 5 Virginia Roberts participated in a grand 6 theft? 7 A. I don't know how, first of all, I 8 don't know how I know that. I believe I read 9 it in a press report so... 10 Q. I'm going to mark this as composite 11 exhibit, Maxwell 14 please? 12 (Maxwell Exhibit 14, email, marked 13 for identification.) 14 Q. I'm going to direct you to page GM 15 00109. At the top of that page you are going 16 to see an email address from Jeffrey Epstein 17 on Sunday June 12, 2011 to 18 19 A. Yes. 20 Q. The re line says, This is the 21 actual version they wanted me to send which I 22 changed but this is back from my U.K. 23 lawyers. 24 Do you see that? 25 A. Yes. - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 88 of 106 88 (Pages 346 to 349) Page 346 1 G Maxwell - Confidential 2 Q. If you go down further, you're 3 going to see halfway through the page, you 4 will see your email address the 5 and you will see a statement that says, Thank 6 you. I have it now. I'm working on the 7 letter a little. I will send final version 8 tomorrow and whatever is in it will be 9 factually accurate. 10 Beneath that you will see Philip 11 Barden who I believe you identified earlier 12 as one of your attorneys? 13 A. Uh-huh. 14 Q. And you will see a letter, starting 15 the text of a letter starting, I want you to 16 turn to the second page which is GM 00110. 17 About halfway through the page, it says you 18 will also presumably draw attention to the 19 fact that prior to filing her suit against 20 Mr. Epstein, Ms. Roberts fled the U.S. to 21 avoid being arrested for grand theft. Police 22 report available. 23 What grand theft were you referring 24 to there that Virginia Roberts committed? 25 MR. PAGLIUCA: Objection to the Page 347 1 G Maxwell - Confidential 2 form and foundation. 3 A. I don't know. However, I believe 4 she stole money from somewhere where she 5 worked. 6 Q. How do you know that was grand 7 theft? 8 A. I don't know how I know that. 9 Q. So you authorized a statement that 10 characterized that as grand theft without 11 knowing whether it was grand theft? 12 A. What month, what is the date of 13 this? 14 Q. The date of this is June 12, 2011? 15 A. So I'm afraid such a long time ago, 16 I'm not sure how, I really couldn't testify 17 as to how that language ended up in here. 18 Q. Do you have the police report? It 19 says police report available. Do you have 20 that document? 21 A. I don't have that document. 22 Q. Who does? 23 A. I have no idea. 24 Q. Would your lawyer Philip Barden 25 have that document? Page 348 1 G Maxwell - Confidential 2 A. I don't know who has this document. 3 Q. What's your basis in that statement 4 for saying Ms. Roberts fled the U.S.? 5 A. Again, you are asking me for a 6 statement that I made in 2011 and I can't say 7 what in 2011 exactly the basis of that 8 statement was. 9 Q. So you don't know whether or not 10 that statement is true? 11 A. This is in 2011 and it never went 12 out, so I'm not sure exactly. 13 Q. But you said in your email that you 14 were working to make it factually accurate, 15 is that correct? 16 A. That's what it says. 17 Q. I'm going to mark as Maxwell 15 a 18 document dated February 24, 2015? 19 (Maxwell Exhibit 15, email, marked 20 for identification.) 21 Q. This is an email from Ross Gow who 22 you've identified as your press agent on 23 February 24, 2015 to which I understand 24 to be your email address and Philip Barden. 25 The subject line says, VR cried rape. Prior Page 349 1 G Maxwell - Confidential 2 case dismissed as prosecutors found her not 3 credible. The message says, Ghislaine, some 4 helpful leakage, dot dot dot. What is it you 5 were leaking to the press? 6 MR. PAGLIUCA: Objection, there is 7 no foundation that she leaked anything 8 and you know that. 9 Q. What was it that you were leaking 10 to the press in that statement? 11 A. Again, I don't think that's 12 referring to that, that's just referring to 13 the press getting hold of whatever story it 14 is. 15 Q. What was Ross Gow leaking to the 16 press? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. It doesn't say Ross was leaking 20 anything. It doesn't say that. 21 Q. The statement says, helpful 22 leakage, is that correct? 23 A. It says helpful leakage. That 24 doesn't mean he leaked anything. 25 Q. Did you leak to the press 1111 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 89 of 106 89 (Pages 350 to 353) Page 350 1 G Maxwell - Confidential 2 information to the press information about 3 the subject line, VR cried rape, prior case 4 dismissed as prosecutors found her not 5 credible? 6 A. I don't no idea what Ross is 7 referring to. I think he is referring to the 8 press held the story. I couldn't testify to 9 that. 10 Q. Did you leak to the press 11 information regarding the statement, VR cried 12 rape prior case dismissed as prosecutors 13 found her not credible, either through you or 14 through your press agents? 15 A. I think this is coming from the 16 daily mail. 17 Q. That is not my question, I'm asking 18 whether you or your press agent leaked that? 19 A. I have no knowledge, I have no 20 idea, I'm sorry. I can't -- I have no 21 recollection. I have no idea what she is 22 talking about. 23 Q. I'm going to mark this as 16? 24 (Maxwell Exhibit 16 email marked 25 for identification.) Page 351 1 G Maxwell - Confidential 2 Q. This is an email addressed at the 3 top from Jeffrey Epstein on Monday, January 4 12, 2015 to which I understand to be 5 your email address. The email reads, You can 6 issue a reward to any of Virginia's friends, 7 aquaints, family, that come forward to help 8 prove her allegations are false. The 9 strongest is the Clinton dinner and the new 10 version of the Virgin Islands that Stven 11 Hawking practiced in an underage orgy. 12 Did you offer any rewards to 13 Virginia's family or friends to contradict 14 Virginia's story? 15 A. Absolutely not. 16 Q. Did Jeffrey Epstein offer any 17 rewards to any of Virginia's, as he suggests 18 here, friends, family or acquaintances to 19 contradict Virginia's story? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I have no idea what he did. 23 Q. Did he tell he was going to offer 24 rewards to Virginia's acquaintances, friends 25 and family to prove her allegations were Page 352 1 G Maxwell - Confidential 2 false? 3 A. He did not. 4 Q. Do you know whether Jeffrey Epstein 5 paid Rebecca Boylen to give testimony about 6 Virginia Roberts? 7 A. I don't know who Rebecca Boylen is. 8 Q. So you don't know whether Jeffrey 9 Epstein paid her? 10 A. I don't know who Rebecca Boylen is. 11 Q. Have you ever contacted any of 12 Virginia's friends, acquaintances or family 13 regarding this case? 14 A. I don't know who Virginia's friends 15 or family are and I have not contacted 16 anybody related to her in any way, shape or 17 form. 18 Q. I will turn you, I believe it's the 19 thicker document which is Maxwell, I believe 20 it was 14, right there, the compilation 21 document to GM, at the bottom, GM 00071. You 22 actually may want to turn to the prior page 23 70 so you can see the email chain. At the 24 top of the page -- 25 MR. PAGLIUCA: I don't have a 00071 Page 353 1 G Maxwell - Confidential 2 on mine. 3 MS. McCAWLEY: It's the second page 4 in that document. 5 MR. PAGLIUCA: Okay. 6 Q. It's dated Friday March 11, 2011 7 from Maxwell to Jeffrey with the title, Daily 8 Mail and there is a forward from Ross Gow to 9 you and a number of other individuals, that's 10 on the cover page and as you scroll to the 11 second page, you are going to see that part 12 of the chain that I'm asking about and that 13 is the chain at the bottom which is dated 14 3/10/2011 from Brian Basham and it says we 15 think -- we should think about the letter to 16 the editor. School can be university. Age 17 of consent in Florida is complex. See below, 18 if you are 16 years old, a sexual 19 relationship with someone between 18 and 24 20 is legal in Florida. Two persons between 16 21 and 24, Florida statute 794.05. A person 24 22 years or of age or older who engages in 23 sexual activity with a person 16 or 17 years 24 of age commits a felony in the second degree. 25 So as soon as you turn 16 you are able to - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 90 of 106 90 (Pages 354 to 357) Page 354 1 G Maxwell - Confidential 2 have sexual relations and you can have sexual 3 relations with a minor under the age of 18 4 until your 24th birthday. 5 Why were you concerned with the age 6 of consent in Florida? 7 MR. PAGLIUCA: Objection to the 8 form and foundation of the question. 9 A. I wasn't concerned. I think this 10 was somebody sending me the statute for 11 informational purposes. 12 Q. Who is Brian Basham? 13 A. He is the person who, Ross Gow's 14 boss I believe, I don't know what the 15 relationship is. 16 Q. I didn't hear you? 17 A. I think he owns the agency, I'm not 18 sure exactly. 19 Q. Why would he be sending you 20 information addressing concerns about the age 21 of consent in Florida? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. I think he was just trying to be -- 25 telling me details that would happen, Page 355 1 G Maxwell - Confidential 2 Virginia in '11 was claiming she was 15 and 3 we thought she was 17. I didn't know what 4 the statutes were in Florida and I think he 5 was just trying to be helpful so I would 6 know. 7 Q. Did you have a concern that you had 8 violated this statute in Florida? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. No. 12 Q. Did you have a concern that Jeffrey 13 Epstein had violated this statute in Florida? 14 A. I'm not concerned what happened 15 with Jeffrey. I'm only concerned what 16 happens with me. 17 Q. Why did you communicate with your 18 press agent about the sexual consent age in 19 Florida? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. It misstates her 22 testimony. 23 A. I wasn't concerned. I think he was 24 being helpful and stating what the statute 25 was. Page 356 1 G Maxwell - Confidential 2 Q. I'm going to turn you now in that 3 same stack the Bates number GM 00088. At the 4 top of the email you are going to see Jeffrey 5 Epstein, dated June 8, 2011, to you and it's 6 got a re line, Vanity Fair. If you go down 7 the chain you will see where it says under 8 your email, Do you have a problem with 9 anything I said. 10 Were you communicating with Jeffrey 11 to confirm what statements you could put in 12 any press releases you were given? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. Any interest I have is in accuracy. 16 Q. Were you confirming with Jeffrey 17 Epstein what information you could put in 18 press releases? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. Again, I'm only looking for 22 accuracy. 23 Q. Why would you ask him if he had a 24 problem with anything you were saying? 25 A. If there is anything I Page 357 1 G Maxwell - Confidential 2 characterized that was not correct. 3 Q. That's not what you said. You 4 said, do you have a problem with anything I 5 said. 6 MR. PAGLIUCA: Objection to the 7 form and foundation. There is no 8 question pending. 9 MS. McCAWLEY: There is. 10 MR. PAGLIUCA: That's not a 11 question, it's a statement. 12 MS. McCAWLEY: Don't interrupt me. 13 Q. Di you say, do you have a problem 14 with anything I said? 15 A. That was asking in my parlance that 16 I wanted him to check it for accuracy. 17 Q. Did he tell you there was anything 18 inaccurate about the statement? 19 A. Again, I have to read the whole 20 thing to figure that out. 21 Q. Were you coordinating with Jeffrey 22 Epstein during this time period in 2011 23 regarding statements that you were issuing to 24 the press? 25 MR. PAGLIUCA: Did you withdraw the MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 91 of 106 91 (Pages 358 to 361) Page 358 1 G Maxwell - Confidential 2 last question. 3 MS. McCAWLEY: I'm not withdrawing 4 anything. I'm asking a question. 5 MR. PAGLIUCA: There was a question 6 pending. You didn't let the witness 7 answer the question, then you moved on 8 to another question so I'm asking for 9 clarification for the record now which 10 question are we answering. 11 MS. McCAWLEY: There is an answer. 12 The question was did he tell you 13 anything, there was anything in the 14 statement inaccurate about the statement 15 and she said again, I read the whole 16 thing -- 17 THE WITNESS: I would have to. 18 MS. McCAWLELY: -- I would have to 19 read the whole thing to figure that out. 20 MR. PAGLIUCA: Then she started 21 reading it and you asked another 22 question. 23 MS. McCAWLEY: That's the question. 24 MR. PAGLIUCA: I'm wondering if its 25 still pending. Page 359 1 G Maxwell - Confidential 2 MS. McCAWLEY: It was answered. 3 Q. Were you coordinating with Jeffrey 4 Epstein during the time period in 2011 5 regarding the statements you were issuing to 6 the press? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I only wanted to be accurate in any 10 factual statements that I made. 11 Q. You knew at that time that Jeffrey 12 Epstein had been convicted for sexual abuse 13 of a minor, is that correct? 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. He was sentenced I believe for 17 underage -- soliciting an underaged 18 prostitute. 19 Q. You knew that he was a registered 20 sex offender? 21 A. Yes. 22 Q. You were coordinating with him the 23 statement that you were going to be making to 24 the press to confirm whether they were 25 accurate in your words? Page 360 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I was not coordinating with 5 Jeffrey. He had details that I did not have. 6 I was not party to his case. I needed to 7 have information in order to be able to 8 respond so I was not coordinating with him. 9 I was merely asking for details that I could 10 have. 11 Q. Did Jeffrey write any of your press 12 statements for you? 13 A. No. 14 Q. He didn't draft any of them? 15 A. I have a lawyer who was working on 16 this and that was -- I asked, I believe as I 17 recollect asked him for information to make 18 sure I was being accurate in the 19 representations for whatever I was 20 discussing. 21 Q. Did Jeffrey provide you with any 22 drafts of statements to provide to the press? 23 A. I only recall drafts from my 24 lawyer. 25 Q. I will mark this as Maxwell 17. Page 361 1 G Maxwell - Confidential 2 (Maxwell Exhibit 17, email, marked 3 for identification.) 4 Q. This is an email from you on 5 January 10, 2015 to Philip Barden and Ross 6 Gow. The statement you had before you 7 earlier, that, if you can pull that in front 8 of you, the one page press release that you 9 gave. You might know from memory. 10 Was the press release that you 11 issued with the statement about Virginia 12 issued in or around January 2, 2015? 13 A. As best as I can recollect. 14 Q. I want to turn your attention to 15 the document I just handed you which is Bates 16 No. 001044, from you to Philip Barden and 17 Ross Gow. It says in the first sentence, I'm 18 out of my depth to understand defamation, 19 other legal hazards and I don't want to end 20 up in a lawsuit aimed at me from anyone, if I 21 can help it. Apparently, even saying 22 Virginia is a liar has hazards. 23 You knew at the time you called 24 Virginia a liar in early January of 2015 that 25 that was something that would result in a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 92 of 106 92 (Pages 362 to 365) Page 362 1 G Maxwell - Confidential 2 lawsuit, is that correct? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I have legal advice that I took. 6 Q. But you knew in early January by 7 making a statement calling Virginia a liar 8 that you were subjecting yourself to a legal 9 dispute with her? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I took legal advice as to what 13 should be said and not be said and the legal 14 advice that came from the United Kingdom 15 was -- 16 MR. PAGLIUCA: You are not allowed 17 to talk about any legal advice that you 18 got from anybody that's a lawyer. 19 A. Sorry. 20 Q. So is it correct without telling me 21 what you talked to your lawyers about that 22 you knew because this is dated January 10 23 that when you made this statement in early 24 January, January 2 of 2015 you knew that 25 calling Virginia a liar would subject you to Page 363 1 G Maxwell - Confidential 2 a legal action, isn't that correct? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. As to what you 5 knew -- whatever she knows would be 6 privileged. 7 MS. McCAWLEY: I'm asking if she 8 knows. I'm not asking her to tell me 9 about her privileged communications. 10 A. All I can say is I asked a question 11 and received legal advice. 12 (Maxwell Exhibit 18, email, marked 13 for identification.) 14 Q. This is an email dated January 15, 15 2015 from Jeffrey Epstein to you? 16 A. Uh-huh. 17 Q. It states in the first line, do you 18 want to come out and say she was the 19 girlfriend during the time? 20 MR. PAGLIUCA: Objection to the 21 form and foundation of the question and 22 actually the word is , there 23 is no vowel in there. 24 MS. McCAWLEY: I was just trying to 25 pronounce it. Page 364 1 G Maxwell - Confidential 2 Q. This email reads do you want 3 without a vowel, to come out and say 4 she was the girlfriend during the time. 5 Who was Jeffrey Epstein referring 6 to? 7 A. I believe he was referring to 8 9 Q. Why was he asking you if you wanted 10 to come out and say she was the 11 girlfriend? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. The way the press and you were 15 characterizing me is I was with Jeffrey 16 throughout this entire period of time and I 17 was not. 18 Q. Was with Jeffrey during this 19 period of time? 20 A. I believe she was. 21 Q. Did Jeffrey come out and tell the 22 press it was and not you that was with 23 him as he is proposing here? 24 A. I don't believe he did. 25 Q. Did you want him to do that? Page 365 1 G Maxwell - Confidential 2 A. No, I didn't ask him to do 3 anything. No. 4 Q. So do you know in January of 2015, 5 was his girlfriend? 6 A. 2015, I have no idea who was his 7 girlfriend in 2015. 8 Q. I'm sorry, you are correct. 9 In the period of 1999 to 2002, was 10 his girlfriend? 11 A. They spent a lot of time together. 12 Q. Did you talk to about going 13 to the press and saying that she was the 14 girlfriend and not you? 15 A. I have never spoken to 16 Q. Was offered any money to 17 make a statement that she was the girlfriend? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I have no idea. I have never 21 spoken to and I don't know anything -- 22 I have no idea. 23 (Maxwell Exhibit 19, email, marked 24 for identification.) 25 Q. That's an email from Jeffrey to - - - - - - - - - - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 93 of 106 93 (Pages 366 to 369) Page 366 1 G Maxwell - Confidential 2 Maxwell dated January 25, 2015. 3 A. Uh-huh. 4 Q. I will direct your attention to the 5 bottom email which is from you on Saturday 6 January 24, 2015. It says, I would 7 appreciate it if would come out and 8 say she was your girlfriend. I think she was 9 from the end of '99 to 2002. 10 Does that refresh your recollection 11 that you asked Jeffrey to have come 12 out and say she was his girlfriend? 13 A. I'm sure I would loved anybody to 14 come out and say they were with Jeffrey 15 rather than me. 16 Q. Was that an accurate statement you 17 were asking to be made to the press? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. When is this? 21 Q. 2015. The statement is whether she 22 was the girlfriend from '99 to 2002. As the 23 email reads. 24 A. What is your question? 25 Q. My question is, was that an Page 367 1 G Maxwell - Confidential 2 accurate statement you were going to be 3 giving to the press? 4 A. I didn't make the statement and 5 never came out, so it's completely 6 moot. 7 Q. My question is, was it an accurate 8 statement that was the girlfriend from 9 '99 to 2002 or were you just making that up 10 for purposes of deflecting press from you? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. As I said they spent a lot of time 14 together and... 15 Q. Were you also his girlfriend from 16 '99 to 2002? 17 A. I don't if I would have ever 18 characterized myself as his girlfriend, but 19 at that time, was with him as much if 20 not more than I was. 21 Q. I will mark this as Maxwell 20? 22 (Maxwell Exhibit 20, email, marked 23 for identification.) 24 Q. This is an email at the top, it's 25 Bates labled 001060. At the top is a chain Page 368 1 G Maxwell - Confidential 2 from Jeffrey to you on January 11, 2015 and 3 if you look below, I'm going to start at the 4 bottom of that chain which is January 11 at 5 9:15 from Jeffrey and he wrote, Alan, do you 6 have an article coming out in Monday's paper. 7 If so, could you please forward us a copy. 8 Do you know what Alan Jeffrey was 9 referring to there? 10 A. I don't know. 11 Q. If you look up in the email chain 12 do you see an email address from Alan 13 Dershowitz responding to that letter? 14 A. I do. 15 Q. So that would be Alan Dershowitz 16 that Jeffrey was emailing at that time 17 according to this chain, correct? 18 A. It certainly looks like it. 19 Q. The email from Alan to Jeffrey is, 20 Nothing on Monday. I'm working on several 21 possible articles about unfairness in the 22 legal process that allows false charges to be 23 inserted into legal documents with no 24 opportunity to respond. 25 And do you see above that Jeffrey's Page 369 1 G Maxwell - Confidential 2 email to you says, quote, Careful. 3 A. Is that to me or to Alan? 4 Q. Jeffrey to at the top. Why 5 was Jeffrey telling you to be careful? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I have no idea. 9 Q. What was he concerned about with 10 Alan Dershowitz's suggestion in the email 11 below? 12 MR. PAGLIUCA: Objection to form 13 and foundation. 14 A. I can't possibly know. 15 Q. Did you discuss with him why he 16 told you to be careful? 17 A. I had limited contact with him. I 18 don't recall where this goes in the chain, 19 why he was telling me to be careful, I have 20 no idea. 21 Q. Did you respond to this email? 22 A. If you don't have it, I didn't 23 respond. 24 Q. Did you ever delete emails during 25 the period of January of 2015? - - - - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 94 of 106 94 (Pages 370 to 373) Page 370 1 G Maxwell - Confidential 2 A. I have every email that you asked 3 for in discovery, that I have I gave you. 4 Q. That's not my question. 5 Did you ever delete emails in 6 January of 2015? 7 A. I have not deleted anything that 8 you have asked me for in discovery. I have 9 given you everything that I have. 10 Q. That is not my question, my 11 question is, did you ever delete emails in 12 January of 2015? 13 A. In the normal course of my work, 14 there are emails from spam that I delete. 15 That is the type of email I've deleted. 16 Anything that is material to what you want, I 17 have not deleted. 18 Q. How do you know that? 19 A. Well, anybody that's to do with 20 Jeffrey or Alan or women or anything of which 21 I know you were interested in, of which I 22 have anything I would not have done because I 23 don't want to subject myself to... 24 Q. Have you had your computer 25 forensically copied for purposes of this Page 371 1 G Maxwell - Confidential 2 litigation? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. Has someone made a copy of your 6 computer for purposes of this litigation. 7 A. No. 8 Q. Are you a citizen of the United 9 States? 10 A. I am. 11 Q. Are you also a citizen of England? 12 A. I am. 13 Q. Are you a citizen of any other 14 land? 15 A. TerraMar. 16 Q. That's the name of your charity 17 project that deals with oceans, is that 18 correct? 19 A. Yeah. I'm French as well. 20 Q. Has Jeffrey Epstein funded TerraMar 21 for you? 22 A. He did give some money to TerraMar, 23 yes. 24 Q. How much? 25 A. I believe it was $50,000. Page 372 1 G Maxwell - Confidential 2 Q. Earlier today, you said you were in 3 the process of resolving the sale of your 4 town home. Where do you intend to live once 5 your town home is sold? 6 A. That's a good question. I don't 7 have an answer for you yet. 8 Q. You don't have a present plan. Do 9 you intend to live in the United States? 10 A. I don't have a present plan. 11 Q. Are you living outside of your town 12 home right now or are you still there? 13 A. I'm just couch surfing. 14 Q. Has Jeffrey Epstein ever purchased 15 a company for you or put a company in your 16 name? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I have no recollection. 20 Q. Is there a Ghislaine Maxwell 21 corporation, for example? 22 A. No, not that I am aware of that has 23 anything to do with me. There may be with 24 one that someone else owns or started but not 25 one that is related to me. Page 373 1 G Maxwell - Confidential 2 MS. McCAWLEY: I'm going to take a 3 short break and make sure to keep it 4 short because I know you wanted to -- I 5 just want to wrap up what we have left. 6 THE VIDEOGRAPHER: It's now 5:49 we 7 are off the record. 8 (Recess.) 9 THE VIDEOGRAPHER: It's now 6:00 10 p.m. and we are back on the record. 11 Q. Ms. Maxwell, do you recall being 12 subpoenaed for a deposition back in 2009? 13 A. I do. 14 Q. Why did you avoid giving your 15 deposition in that case when you were 16 subpoenaed and had the opportunity to tell 17 your side of the story? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. That's not what happened. 21 Q. What happened? 22 A. As I best recall, I was subpoenaed 23 and a date was set for the subpoena and 24 everything was set and I believe it was with 25 Brad Edwards, correct me if I'm wrong, and MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 95 of 106 95 (Pages 374 to 377) Page 374 1 G Maxwell - Confidential 2 Brad Edwards failed to show up for the 3 subpoena. 4 Q. So your testimony is Brad Edwards 5 did not show up for the deposition that had 6 been set? 7 A. Correct. 8 Q. Did you give any statement that 9 your mother was ill and, therefore, you 10 couldn't take your deposition and had to 11 leave the country indefinitely? 12 A. That's an entirely separate 13 situation. Brad Edwards was involved in the 14 Rothstein scandal which was a RICO, I 15 believe, you know, is when fake suits were 16 created in Jeffrey's case and Rothstein went 17 to jail for 50 years and Brad Edwards worked 18 for that firm. 19 Q. And Mr. Edwards worked for that 20 firm? 21 A. So when the subpoena came, Brad 22 Edwards was involved with Rothstein in the 23 case so when I was called for subpoena, then 24 and I had a subpoena, date and time set, Brad 25 Edwards went AWAL, meaning he failed to Page 375 1 G Maxwell - Confidential 2 respond to calls and failed to get in touch 3 with my attorneys, even though a date and 4 time was set for the subpoena and so that's 5 what happened to that subpoena. It just 6 didn't happen. 7 Q. We may be talking about two 8 different cases so I will ask the question 9 again. 10 Was there ever a time where you 11 were subpoenaed to sit for a deposition that 12 you could not make it because you said that 13 your mother was ill? 14 A. So that is the same subpoena that 15 Brad Edwards failed to turn up for and then I 16 think five or six months passed between -- a 17 period of time, I can't characterize it 18 exactly, a period of time passed where then 19 he resurfaced and asked for a new subpoena to 20 be -- a new time to be set and because he had 21 contacted the press and done all sorts of 22 things that you guys are familiar with, I 23 believe, it was my lawyer suggested that I 24 should have some sort of protective order and 25 I believe between the time for when Brad Page 376 1 G Maxwell - Confidential 2 Edwards resurfaced after the Rothstein story, 3 when the guy went to jail for 50 years for 4 creating fake cases in Jeffrey's and other 5 people's cases, in between the time when 6 there were -- trying to figure out the 7 protective situation for me, my mother was 8 sick, she is 89, she was 89 at that time so I 9 -- they -- we can all -- we all have parents, 10 so anyone, I don't know how old your parents 11 are but any parent or godparent, any 12 individual who is in the late 80s 90s, we can 13 understand has health issues so my mother's 14 health was deteriorating very rapidly at that 15 time and we had issues at home with who she 16 would talk to and how to manage her, her 17 healthcare situation and so I went home. 18 They were still arguing about the protective 19 order -- 20 Q. Is it your testimony that there was 21 not a date set for your deposition at the 22 time you left to go see your mother? 23 A. I don't believe so. 24 Q. Are you friends with the Clintons? 25 A. I am. Page 377 1 G Maxwell - Confidential 2 Q. Did you attend a wedding of Chelsea 3 Clinton a few weeks after the date was set, 4 let's say a few weeks after you left to go 5 see your mother who was ill? 6 A. I don't recall exactly when I left 7 but it was before, a few weeks before -- I 8 don't remember the exact timing of that, so 9 I'm sorry, can you repeat the question? 10 Q. Did you come back to the United 11 States to attend Chelsea Clinton's wedding? 12 A. I attended Chelsea Clinton's 13 wedding but I don't know if I came back 14 specifically for that or not. 15 Q. When we were looking at the flight 16 logs earlier, there was a flight where you 17 ended up in the naval base, I believe it was 18 in China, do you know how you got clearance 19 to land at that naval base? 20 A. I need to have a look at whatever 21 document. 22 Q. It's one of the flight logs, it was 23 on the flight with Clinton when we were 24 talking about you landed at a naval base. I 25 know you are a pilot, do you know what you MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 96 of 106 96 (Pages 378 to 381) Page 378 1 G Maxwell - Confidential 2 had to do to get clearance to land at that 3 naval base. 4 MR. PAGLIUCA: If you need to look 5 at something to answer the question, you 6 can. If you can't answer the question 7 without looking at something just 8 indicate such. 9 A. Regardless, I wouldn't have any 10 knowledge of that. 11 Q. Was Sarah Kellen traveling with you 12 on the flights you were on with Clinton? 13 A. I would have to look at a document. 14 I wouldn't know if she was on all of them or 15 not. I don't know. 16 Q. Do you recall her being on any of 17 them? 18 A. To the best of my recollection, I 19 think she was. I don't recollect exactly 20 what flight she was on or not. 21 Q. Sarah Kellen was one of the 22 co-conspirators, physically, in the 23 nonconstitution agreement, is that correct? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 379 1 G Maxwell - Confidential 2 A. I have never seen the document but 3 my understanding, I believe, is that she was. 4 Q. Did you ever stay the night ever at 5 Les Wexner's house in Ohio, have you ever 6 stayed the night there? 7 A. In his home in Ohio? 8 Q. Yes. 9 A. I don't believe I did. 10 Q. Are you aware of anybody providing 11 Jeffrey with two 12 year old girls as a 12 birthday present? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. No. 16 Q. Are you aware of anybody ever 17 providing Jeffrey with French girls under the 18 age of 18 as a birthday present? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. No. 22 Q. Do you know whether Jean Luc Brunel 23 provided girls under the age of 18 to Jeffrey 24 for the purposes of sex? 25 MR. PAGLIUCA: Objection to the Page 380 1 G Maxwell - Confidential 2 form and foundation. 3 A. I am un -- the answer is no, I 4 don't know anything about that. 5 Q. Did you ever witness Jean Luc 6 Brunel bringing girls under the age of 18 to 7 any of Jeffrey residences? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I don't recollect Jean Luc coming 11 to the house with girls, period. 12 Q. Do you, when I say house, I'm 13 including the U.S. Virgin Island home. 14 Do you recollect Jean Luc Brunel 15 bringing foreign girls under the age of 18 to 16 the U.S. Virgin Island house? 17 A. I don't recollect anything like 18 that. 19 Q. Do you know how Jeffrey Epstein 20 made his money? 21 A. No. 22 Q. Was Les Wexner or is Les Wexner one 23 of his clients? 24 A. I have no idea. 25 Q. What do you know about the Page 381 1 G Maxwell - Confidential 2 relationship between Jeffrey Epstein and Les 3 Wexner? 4 A. Are you talking today? 5 Q. Yes, today. 6 A. I have no idea. 7 Q. Do they have a business 8 relationship? 9 A. I have no idea. 10 Q. Did they have a business 11 relationship during the time that you were 12 working for Jeffrey Epstein? 13 A. I believe in the '90s when I was 14 there they had a business relationship. 15 Q. Did they have any other kind of 16 relationship? 17 MR. PAGLIUCA: Objection to form 18 and foundation. 19 A. The only relationship I am aware of 20 is the business relationship. 21 Q. Do you know why Les Wexner sold the 22 New York house or gave the New York house to 23 Jeffrey, if you know? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 97 of 106 97 (Pages 382 to 385) Page 382 1 G Maxwell - Confidential 2 A. I know nothing about that 3 transaction. 4 Q. Can you list for me all the girls 5 that you have met and brought to Jeffrey 6 Epstein's house that were under the age of 7 18? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I could only recall my family 11 members that were there and I could not make 12 a list of anyone else because that list -- it 13 never happened that I can think of. 14 Q. I'm talking about the time you were 15 working for Jeffrey Epstein, can you list all 16 girls that you found for Jeffrey Epstein that 17 were under the age of 18 to come work for him 18 in any capacity? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I didn't find the girls. 22 Q. You choose the word. 23 MR. PAGLIUCA: If you have a 24 question ask it, you don't choose the 25 word. Page 383 1 G Maxwell - Confidential 2 Q. List all of the girls you met and 3 brought to Jeffrey Epstein's home for the 4 purposes of employment that were under the 5 age of 18? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I've already characterized my job 9 was to find people, adults, professional 10 people to do the jobs I listed before; pool 11 person, secretary, house person, chef, pilot, 12 architect. 13 Q. I'm asking about individuals under 14 the age of 18, not adult persons, people 15 under the age of 18. 16 A. I looked for people or tried to 17 find people to fill professional jobs in 18 professional situations. 19 Q. So Virginia Roberts was under the 20 age of 18, correct? 21 A. I think we've established that 22 Virginia was 17. 23 Q. Is she the -- sorry, go ahead. 24 Is she the only individual that you 25 met for purposes of hiring someone for Page 384 1 G Maxwell - Confidential 2 Jeffrey that was under the age of 18? 3 MR. PAGLIUCA: Objection to form 4 and foundation. Mischaracterizes her 5 testimony. 6 A. I didn't hire people. 7 Q. I said met. 8 A. I interviewed people for jobs for 9 professional things and I am not aware of 10 anyone aside from now Virginia who clearly 11 was a masseuse aged 17 but that's, at least 12 that's how far we know that I can think of 13 that fulfilled any professional capacity for 14 Jeffrey. 15 Q. List all the people under the age 16 of 18 that you interacted with at any of 17 Jeffrey's properties? 18 A. I'm not aware of anybody that I 19 interacted with, other than obviously 20 Virginia who was 17 at this point? 21 (Maxwell Exhibit 21, email, marked 22 for identification.) 23 Q. I'm showing you what's been marked 24 as Maxwell 21, it's an email dated January 25 21, 2015 from Jeffrey to you. Is that, you Page 385 1 G Maxwell - Confidential 2 can take a moment to take a look at it, is 3 that a statement that Jeffrey Epstein wrote 4 for you to be issued to the press? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. The question was? 8 Q. Is this a statement that Jeffrey 9 Epstein wrote for you to be issued to the 10 press? 11 MR. PAGLIUCA: Same objection. 12 A. Is there any other emails that you 13 have that surround this that would allow me 14 to know what -- does this have a context? 15 Q. These were produced by your counsel 16 so the to extent there are emails that 17 surround this, this is what we were given. 18 A. Okay. I don't know whether he 19 wrote this -- obviously he wrote this and 20 sent this to me. I don't know if this is 21 post a phone call we had, I can't recollect 22 exactly. 23 Q. Do you know if this was issued to 24 the press, this statement? 25 A. The only press statement that was MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 98 of 106 98 (Pages 386 to 389) Page 386 1 G Maxwell - Confidential 2 issued is the one that you have. 3 Q. When the paragraph refers to you 4 being in a very long term committed 5 relationship with another man, who was that 6 other man? 7 MR. PAGLIUCA: You don't have to 8 answer the question. 9 MS. McCAWLEY: I'm asking the 10 identity of a witness in a statement she 11 is giving. 12 MR. PAGLIUCA: She didn't give the 13 statement. 14 MS. McCAWLEY: Jeffrey is writing 15 to her, I'm asking who is he is 16 referencing to a long term relationship. 17 You are going to refuse to let her 18 answer that question. 19 MR. PAGLIUCA: Yes. 20 MS. McCAWLEY: I would like to 21 state for the record he is refusing to 22 allow her to identify a potential 23 witness in this litigation. So we will 24 be back to get the answer to that 25 question. Page 387 1 G Maxwell - Confidential 2 Q. Do you recall when you were 3 traveling with Virginia Roberts that you 4 would be responsible for holding her 5 passport? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I already testified I don't recall 9 traveling with Virginia. 10 Q. Do you recall whether Jeffrey 11 Epstein when he was traveling with a minor, 12 someone under the age of 18, someone would 13 hold their passport? 14 MR. PAGLIUCA: Object to the form. 15 A. I couldn't testify to what Jeffrey 16 did or didn't do. 17 Q. You never observed him gathering a 18 minor's passport and holding it during one of 19 the trips you were on? 20 A. I don't have a recollection of 21 that. 22 Q. Are you familiar with a company 23 called Hyperion Air Inc.? 24 A. I am. 25 Q. Is that a company you are Page 388 1 G Maxwell - Confidential 2 affiliated with? 3 A. No. 4 Q. Is that a company that Jeffrey 5 owns? 6 A. I knew it back in 2001, back when I 7 was working. I have no idea what that is 8 today. 9 Q. What about JEGE, are you familiar 10 with that company, JEGE Inc.? 11 A. I don't recall it. 12 Q. You don't recall? 13 A. It vaguely rings a bell. I don't 14 remember what it relates to. 15 Q. What about J Epstein Virgin Islands 16 Foundation, Inc. 17 Are you familiar with that company? 18 A. No. 19 Q. How did J Epstein & Company, Inc.? 20 A. Again, I don't recall his business 21 names and affiliations. 22 Q. How about NES LLC, are you familiar 23 with that name? 24 A. Again, I think that was one of his 25 businesses, but I don't recall. Page 389 1 G Maxwell - Confidential 2 Q. Do you know what that business did? 3 A. I don't. 4 Q. How about New York Strategy Group 5 Inc.? 6 A. I don't know. 7 Q. What about Ghislaine Maxwell 8 Company, are you familiar with that company? 9 A. I never heard of that. 10 Q. Is that a company you are on record 11 as being either a board member of or having a 12 position of authority in? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I've never heard of the business. 16 Q. What negative, unflattering, 17 private or potentially embarrassing 18 information does Jeffrey Epstein know about 19 you? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I imagine none. 23 Q. Does he know, does he have any 24 knowledge of any illegal activity that you've 25 conducted? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 99 of 106 99 (Pages 390 to 393) Page 390 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. If you want to ask Jeffrey 5 questions about me, you would have to ask 6 him. 7 Q. Have you ever been involved in any 8 illegal activity in your lifetime? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I can't think of anything I have 12 done that is illegal. 13 Q. Have you ever been arrested? 14 A. I have a DUI in the U.K. a long 15 time ago. 16 Q. Is that the only arrest you have on 17 your record? 18 A. Yes. 19 Q. I will mark as Maxwell 22 this 20 email? 21 (Maxwell Exhibit 22, email, marked 22 for identification.) 23 Q. This is dated January 21, 2015. 24 It's from Jeffrey Epstein to you, forwarding 25 the Guardian and I would like you to look at Page 391 1 G Maxwell - Confidential 2 the chain of emails so you understand the -- 3 have an appreciation for who is on this. 4 It's a three-page document. The bottom of 5 the email appears to be a message from, there 6 is a -- at the very bottom there is the 7 signature block for Ross Gow, who I 8 understand is your press agent and above that 9 there is a message from a John Swaine to Ross 10 Gow. 11 Do you see that? 12 A. Uh-huh. 13 Q. Do you know who John Swaine is? 14 A. I do not. 15 Q. Above that there is a message from 16 Ross Gow to Philip Barden and you and it 17 says, so this isn't getting better, latest 18 from our chums at the Guardian and above that 19 you will see on January 21 an email from you 20 where you wrote, See below. 21 And right above that chain you will 22 see Jeffrey Epstein to you on January 21 and 23 his statement to you is, This will now end 24 but I think a dismissive statement is okay. 25 What did he mean by his statement, Page 392 1 G Maxwell - Confidential 2 This will now end? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. I have no idea. 6 Q. Did you discuss with him what he 7 meant by the statement, This will now end? 8 A. I don't recall. 9 Q. Was he taking any action to ensure 10 that, quote, this will now end? 11 A. I have no idea. 12 (Maxwell Exhibit 23, email, marked 13 for identification.) 14 Q. This is an email from, if you look 15 at the chain at the top, you will see it's 16 from you to Jeffrey on January 27 and the 17 email at the bottom of the chain is from 18 Jeffrey to you on January 27. 19 He states, What happened to you and 20 your statement, question mark, question mark. 21 And you put at the top, I have not decided 22 what to do. 23 A. Uh-huh. 24 Q. Why was Jeffrey interested in you 25 making a statement to the press? Page 393 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I don't know that he was 5 interested. We made a statement and then I 6 was being advised to make an additional 7 statement and I never did. 8 Q. Was Jeffrey communicating with you 9 regularly on what additional statement you 10 might make? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. No, I've communicated with him very 14 little, as little as possible. 15 Q. Why did you feel you had to keep 16 him informed of statements you were making to 17 the press? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I didn't feel I had to. 21 Q. Then why you were communicating 22 with him about statements you were making to 23 the press? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 100 of 106 100 (Pages 394 to 397) Page 394 1 G Maxwell - Confidential 2 A. Insofar as this is the case, it's 3 really all about Jeffrey, it's not a case 4 about me. 5 Q. In 2009, did you direct your 6 lawyer, either directly or indirectly, to 7 tell Brad Edwards that you were unavailable 8 to attend a deposition? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. And this is a 11 privileged communication as I understand 12 the question, what someone said or 13 didn't say to their lawyer. So don't 14 answer the question. 15 Q. Can you answer that question 16 without revealing a privileged communication? 17 A. Can you ask the question again? 18 Q. In 2009, did you direct your lawyer 19 to tell Brad Edwards that you were 20 unavailable to attend a deposition? 21 MR. PAGLIUCA: Same instruction. 22 Q. Did you make any statement in 2009 23 to anybody that you were unavailable to 24 attend a deposition? 25 A. My mother was sick and I don't Page 395 1 G Maxwell - Confidential 2 recall exactly the sequence of events but 3 what sequence of events do exist are -- was 4 handled by my lawyers. 5 Q. What is your understanding of 6 Jeffrey Epstein's nonprosecution agreement? 7 A. I have no idea. 8 Q. Do you have an understanding of the 9 co-conspirators listed in the nonprosecution 10 agreement? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I have no knowledge of his 14 agreement, whatever that is. 15 Q. Do you know, you mentioned earlier 16 today that Sarah Kellen was one of the listed 17 co-conspirators. 18 Do you know who the other 19 co-conspirators are in the nonprosecution 20 agreement? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I do not know. 24 Q. What did Jeffrey Epstein tell you 25 about the nonprosecution agreement? Page 396 1 G Maxwell - Confidential 2 A. I don't think I've ever discussed 3 it with him. 4 Q. How did you come to learn that 5 Sarah Kellen was covered by the 6 nonprosecution agreement? 7 A. I believe I read it in the press. 8 Q. Did you have any discussions with 9 Sarah Kellen with about the nonprosecution 10 agreement? 11 A. I have not had any discussions with 12 Sarah. 13 Q. When is the last time you spoke to 14 Sarah Kellen? 15 A. Maybe 2005, 2006 maybe. 16 Q. And same with Nadia Marcinkova, 17 when is the last time you recall speaking 18 with Nadia Marcinkova? 19 A. Probably even more time before 20 that, maybe -- I've never had communications 21 really with Nadia. 22 Q. I'm sorry, I didn't hear that. 23 A. I never had communications with 24 her. 25 Q. You were working for Jeffrey at the Page 397 1 G Maxwell - Confidential 2 same time Nadia was also working for Jeffrey, 3 isn't that correct? 4 A. I didn't know what Nadia did for 5 Jeffrey so I didn't characterize what her 6 relationship or work or not was and I was 7 still helping him with his construction 8 projects and the like but I never crossed 9 paths with Nadia. 10 Q. What did you think Nadia was doing 11 for Jeffrey? 12 A. I have no idea what Nadia was doing 13 for Jeffrey. 14 Q. Did you observe Nadia at any of 15 Jeffrey's houses while you were there? 16 A. She was at the house on occasion. 17 Q. What would she be doing there? 18 A. I have no idea. 19 Q. Did you know if she lived at his 20 houses? 21 A. I have no idea. 22 Q. Did you ever go into a bedroom and 23 see her belongings at one of the houses? 24 A. Not that I recall, no. 25 Q. I'm going to mark this as Maxwell MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 101 of 106 101 (Pages 398 to 401) Page 398 1 G Maxwell - Confidential 2 Exhibit 24? 3 (Maxwell Exhibit 24, email, marked 4 for identification.) 5 Q. You can see at the top of the first 6 page which is GM 0001, it's dated January 3, 7 2015 from you to the Duke of York. 8 Is that Prince Andrew who we 9 referred to today? 10 A. Yes. 11 Q. And can you tell me, it says, Have 12 some info. Call me when you have a moment. 13 What is redacted there? 14 A. I don't recall, I'm sorry. 15 Q. Do you know why there is a 16 redaction on this document? 17 A. You would have to confer with my 18 lawyers. 19 Q. What did you discuss on that call? 20 A. I don't have any specific knowledge 21 of that call. 22 Q. So the call is being made on 23 Saturday, January 3, 2015? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 399 1 G Maxwell - Confidential 2 Q. The document states, it's Saturday 3 January 3, 2015. You issued your press 4 release on January 2, 2015. 5 Were you discussing with Prince 6 Andrew the subject of Virginia Roberts during 7 these calls? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I don't know if I spoke to him. 11 Q. I would like you to turn to GM 0002 12 and the bottom chain says Duke of York, 13 Saturday January 3, to re, and he says 14 let me know when we can talk. Got some 15 specific questions to ask you about Virginia 16 Roberts. 17 Do you recall having a conversation 18 with Prince Andrew about Virginia Roberts in 19 or around early January of 2015? 20 A. I don't know if we actually spoke. 21 Q. Did you ever speak to Prince Andrew 22 about Virginia Roberts after you issued your 23 statement on January 2, 2015? 24 A. I know that we did speak at some 25 point but I don't recollect when we spoke. Page 400 1 G Maxwell - Confidential 2 Q. What did you talk about? 3 A. Just what a liar she is. 4 Q. What did he say to you? 5 A. What a liar she is. 6 Q. Did he tell you why he thought she 7 was a liar? 8 A. I don't think he told me why she 9 was a liar. The substance of everything that 10 she said was a lie with regard to him. 11 Q. What did you say to him? 12 A. She is a liar. 13 Q. That was the whole conversation, it 14 was you said to him, she is a liar and he 15 said to you she say liar and did you discuss 16 any of the details about what those lies 17 were? 18 A. I don't recollect. 19 Q. Was that only one conversation you 20 had? 21 A. I don't recollect. I don't 22 recollect actually the conversation but other 23 than -- in detail other than we both said she 24 was a liar. 25 Q. Do you regularly communicate with Page 401 1 G Maxwell - Confidential 2 Prince Andrew? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. What do you mean by regularly. 6 Q. Do you email with him once a month, 7 once every two months or text him or call 8 him? 9 A. No, we are not in that type of 10 regular touch. 11 Q. Do you travel with him regularly? 12 A. I don't know, I have traveled with 13 him. We have traveled together but regularly 14 is not a correct characterization. 15 Q. Do you travel with him more than 16 once a year? 17 A. There is no standard. There is no 18 set pattern. The answer to that was no. 19 Q. Have you ever observed him with any 20 underage, any women, female under the age of 21 18, interacting, that's not a child or a 22 family friend, interacting for the purposes 23 of a sexual relationship with that 24 individual? 25 MR. PAGLIUCA: Objection to the 1111 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 102 of 106 102 (Pages 402 to 405) Page 402 1 G Maxwell - Confidential 2 form and foundation. 3 A. I've never seen Andrew interact in 4 any way of that nature. 5 Q. Have you ever gone to dinner with 6 him with any individual under the age of 18 7 that's not a family member or friend of yours 8 that is under the age of 18? 9 MR. PAGLIUCA: Objection to form 10 and foundation. 11 A. We've been to dinner all the time, 12 I am not not sure who is at dinner with us, I 13 can't testify to that. 14 Q. Has he ever brought a female under 15 the age 18 that's not a relative of his -- 16 A. He has children. 17 Q. I said not relatives. 18 A. I can't possibly testify to who he 19 comes to dinner with, I wouldn't recall. 20 Q. To your knowledge, has he ever had 21 a relationship with any female under the age 22 of 18 for purposes of a romantic relationship 23 to your knowledge? 24 A. I can't testify to Andrew's 25 relationship. Page 403 1 G Maxwell - Confidential 2 Q. You haven't observed that? 3 A. No. 4 Q. Have you talked to Prince Andrew 5 about coming to testify at trial in this 6 case? 7 A. No. 8 Q. When was the last time you 9 communicated with Leslie Wexner? 10 A. 1994, 1995. 11 Q. I believe earlier, did you say that 12 you -- when is the last time you've been to 13 his home in Ohio? 14 A. I said -- you asked me if I stayed 15 the night. 16 Q. I'm asking you a different 17 question. When is the last time you have 18 been to his home in Ohio? 19 A. Roughly the same time, in the 20 middle of the '90s sometime, mid '90s. 21 Q. Not in the years 2000 to 2002? 22 A. Mid '90s. 23 Q. Have you ever communicated with any 24 representative of Leslie Wexner? 25 MR. PAGLIUCA: Objection to the Page 404 1 G Maxwell - Confidential 2 form and foundation. 3 A. I mean I've been to his -- in the 4 mid '90s, I would have communicated with 5 people who worked for him. 6 Q. Have you communicated with Leslie 7 Wexner about this case? 8 A. No. 9 Q. Have you ever seen a topless female 10 at any one of Jeffrey Epstein's properties? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. You've asked this 13 question, by the way, earlier on today. 14 A. Again, I testified that there are 15 people who from time to time in the privacy 16 of a swimming pool have maybe taken a bikini 17 top off or something but it's not common and 18 certainly when I was at the house I don't 19 really recollect seeing that kind of 20 activity. 21 Q. Have you ever smoked cigarettes? 22 A. Yes. 23 Q. Have you ever smoked cigarettes 24 with Virginia Roberts? 25 A. I don't recall smoking cigarettes Page 405 1 G Maxwell - Confidential 2 with Virginia Roberts. 3 Q. I'm marking this as Maxwell 25. 4 (Maxwell Exhibit 25, email, marked 5 for identification.) 6 Q. I'm showing you what has been 7 marked as Maxwell 25. 8 This is an email dated January 11, 9 2015 at the top? 10 Do you see that that from Jeffrey 11 to you? 12 A. Uh-huh. 13 Q. And then below there is an email 14 from Philip Barden to you and cc'ing Ross Gow 15 on January 11, 2015. 16 Do you see that? 17 A. Uh-huh. 18 Q. It says, Dear Ghislaine, as you 19 know I have been working behind the scenes 20 and this article comes from that. It helps 21 but doesn't answer the VR claims. I will get 22 the criminal allegations out. This shows the 23 MOS will print truth, not just a VR voice 24 piece. We can only make the truth by making 25 a statement. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 103 of 106 103 (Pages 406 to 409) Page 406 1 G Maxwell - Confidential 2 What did he mean when he said, I 3 will get the criminal allegations out, what 4 was he referring to? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I have no idea. 8 Q. Were there criminal allegations 9 about Virginia that either your lawyer or 10 press agent were leaking to the press? 11 MR. PAGLIUCA: Objection to form 12 and foundation. 13 A. I have no idea. 14 Q. Did you ask him what he meant when 15 he said, I will get the criminal allegations 16 out? 17 A. I don't recollect the conversation. 18 Q. Did you direct him to leak to the 19 press criminal allegations about Virginia 20 Roberts? 21 A. I already testified that I have no 22 knowledge of what you are asking me. 23 Q. Were you copied on this email, 24 correct? 25 A. I was. Page 407 1 G Maxwell - Confidential 2 Q. Did Jeffrey Epstein assist in 3 obtaining information about criminal 4 allegations relating to Virginia Roberts? 5 MR. PAGLIUCA: Objection to form 6 and foundation. 7 A. I have no recollection. 8 Q. Did Alan Dershowitz assist in 9 obtaining information regarding criminal 10 allegations of Virginia Roberts? 11 MR. PAGLIUCA: Objection to form 12 and foundation. 13 A. I have no knowledge of that. 14 Q. Did you ever discuss that with Alan 15 Dershowitz? 16 A. Discuss what? 17 Q. Criminal allegations about Virginia 18 Roberts. 19 A. I don't believe I have. 20 Q. Have you ever discussed allegations 21 relating to -- 22 Q. Do you know if Jeffrey Epstein had 23 any relationship with the U.S. government 24 either working for the CIA or the FBI in his 25 lifetime? Page 408 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I have no knowledge of that. 5 Q. Do you know if Jeffrey Epstein has 6 any friends that are in the CIA or FBI? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I have no idea. 10 Q. Are you aware of an investigation 11 of Jeffrey Epstein in the early '80s relating 12 to the SEC? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I have no knowledge of that. 16 Q. Are you aware that Jeffrey Epstein 17 has told people that he worked for the 18 government to recover stolen funds? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I don't recall conversations about 22 that. 23 Q. Has he ever told that you he worked 24 for the U.S. government? 25 A. I don't recollect that. Page 409 1 G Maxwell - Confidential 2 Q. You don't recollect or has he never 3 told you that? 4 A. I have no knowledge, I don't 5 recollect him telling me he worked for the 6 government. 7 Q. Does Jeffrey Epstein have any 8 affiliation with the Israeli government? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I have no knowledge of that. 12 Q. Do you know if he ever performed 13 any work for the Israeli government? 14 A. I have no knowledge of that. 15 Q. Have you ever visited Israel with 16 Jeffrey Epstein? 17 A. I'm sorry, I don't recollect. 18 Q. You've seen the flight logs that I 19 provided you today. Are there, during the 20 time you worked for Jeffrey Epstein, were 21 there times that you flew on commercial 22 flights rather than Jeffrey Epstein's planes? 23 A. Yes. 24 Q. How often did that occur? 25 A. Decently. MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 104 of 106 104 (Pages 410 to 413) Page 410 1 G Maxwell - Confidential 2 Q. Were there other flights that you 3 recall flying on with Jeffrey Epstein that 4 were on flights that -- where Dave Rogers was 5 not the pilot? 6 A. Dave Rogers was not always the 7 pilot. 8 Q. How many planes did Jeffrey Epstein 9 have during the time you were with him? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. So you need to give me a date 13 range. 14 Q. During the time period of 1992 15 through when you left your employment which I 16 think you said was in 2009? 17 A. So in the '90s he had one plane and 18 at some point in the 2000s he had two planes 19 but I can't testify to anything past 2002, 20 2003, what happened to his planes after that. 21 Q. Do you know what travel agency, if 22 any, Jeffrey would use when he would send 23 someone, for example, you or one of his other 24 employees on a flight somewhere? Did he use 25 a particular travel agency to make those Page 411 1 G Maxwell - Confidential 2 arrangements? 3 A. I don't recall. 4 Q. Were you ever responsible for 5 making those arrangements for other 6 individuals? 7 A. I don't recall making flight 8 arrangements. 9 Q. Was it a New York travel agent that 10 you would use for those arrangements? 11 A. Again, we are talking 16, 17, 18 12 years. I just don't recall anything to do 13 with travel agents. 14 Q. Would Jeffrey Epstein ever fly, for 15 example, Sarah Kellen on a commercial flight 16 to meet you in New Mexico? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I can't testify to that. 20 Q. Do you recall a trip where you met 21 Sarah Kellen in New Mexico? 22 A. No, I don't recall any specific 23 trip, no. 24 Q. Why would you be sent to New 25 Mexico, is there a reason why you would go Page 412 1 G Maxwell - Confidential 2 there in the course of the work you were 3 doing for Jeffrey? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I was never sent. I had a job to 7 do and I would have to go to New Mexico for 8 work. 9 Q. Would Sarah Kellen assist in that 10 project? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. No. The project was largely 14 complete, largely complete by the end -- I 15 don't remember the dates exactly but it was 16 largely complete by the 1990s, 2000s. 17 Q. Do you know why Sarah Kellen would 18 be going to New Mexico to meet you? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I don't know. She worked for 22 Jeffrey. 23 MR. PAGLIUCA: I think we are out 24 of time, counsel. 25 THE VIDEOGRAPHER: It's true. Page 413 1 G Maxwell - Confidential 2 MS. McCAWLEY: I will state for the 3 record there were questions today that 4 remain unanswered because the witness 5 has been instructed not to answer those 6 questions and we will be raising our 7 objections with the court to be able to 8 have those questions answered in the 9 near future. 10 MR. PAGLIUCA: So we are clear, we 11 are designating this entire deposition 12 as confidential under the protective 13 order. That would cover the paralegal 14 whose been present as well as the court 15 reporter and the videographer and all 16 the lawyers in the room. 17 THE VIDEOGRAPHER: This concludes 18 today's proceedings. We are off the 19 record at 6:43 p.m. 20 (Time noted: 6:43 p.m.) 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 105 of 106 105 (Pages 414 to 417) Page 414 1 2 - - - 3 I N D E X 4 - - - 5 6 GHISLAINE MAXWELL PAGE 7 By Ms. McCawley 4 8 9 - - - 10 E X H I B I T S 11 - - - 12 MAXWELL EXHIBIT PAGE 13 Exhibit 1 police report 24 14 Exhibit 2 email 33 15 Exhibit 3 transcript 71 16 Exhibit 4 photo 109 17 Exhibit 5 photo 113 18 Exhibit 6 flight logs 117 19 Exhibit 7 photo 133 20 Exhibit 8 photo 143 21 Exhibit 9 message pad pages 147 22 Exhibit 10 email 209 23 Exhibit 11 photo 259 24 Exhibit 12 documents 263 25 Exhibit 13 documents 312 Page 415 1 2 MAXWELL EXHIBIT PAGE 3 Exhibit 14 email 345 4 Exhibit 15 email 348 5 Exhibit 16 email 348 6 Exhibit 17 email 361 7 Exhibit 18 email 363 8 Exhibit 19 email 365 9 Exhibit 20 email 367 10 Exhibit 21 email 384 11 Exhibit 22 email 390 12 Exhibit 23 email 392 13 Exhibit 24 email 398 14 Exhibit 25 email 405 15 16 17 18 19 20 21 22 23 24 25 Page 416 1 2 CERTIFICATE 3 4 5 I HEREBY CERTIFY that the witness, 6 GHISLAINE MAXWELL, was duly sworn by me and 7 that the deposition is a true record of the 8 testimony given by the witness. 9 10 _______________________________ 11 Leslie Fagin, Registered Professional Reporter 12 Dated: April 22, 2016 13 14 15 (The foregoing certification of 16 this transcript does not apply to any 17 reproduction of the same by any means, unless 18 under the direct control and/or supervision 19 of the certifying reporter.) 20 21 22 23 24 25 Page 417 1 2 ACKNOWLEDGMENT OF DEPONENT 3 I, , do hereby 4 certify that I have read the foregoing pages, and that the same is a correct transcription 5 of the answers given by me to the questions therein propounded, except for the 6 corrections or changes in form or substance, if any, noted in the attached Errata Sheet. 7 8 9 GHISLAINE MAXWELL DATE 10 11 Subscribed and sworn to before me this 12 day of , 2016. 13 My commission expires: 14 Notary Public 15 16 17 18 19 20 21 22 23 24 25 (~r- a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-4 Filed 01/09/24 Page 106 of 106 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ REPLY IN SUPPORT OF PLAINTIFF’S MOTION FOR PROTECTIVE ORDER AND TO DIRECT THE DEFENDANT TO DISCLOSE ALL INDIVIDUALS TO WHOM DEFENDANT HAS DISSIMINATED CONFIDENTIAL INFORMATION (DE 335) Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) BOIES, SCHILLER & FLEXNER LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 1 of 12 1 Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Reply in Support of her Motion for Protective Order and Motion for the Court to Direct Defendant to Disclose All Individuals to whom Defendant has Disseminated Confidential Information (DE 335). I. INTRODUCTION “The nature of this case concerns highly personal and sensitive information from both parties. In this action, both parties have sought and will seek confidential information in the course of discovery from the other party and from non-party witnesses. Release of such confidential information outside of the litigation could expose the parties to ‘annoyance, embarrassment, [and] oppression and result in significant injury to one or more of the parties’ business or privacy interests.” - Defendant, Ghislaine Maxwell, March 2, 20161 Less than six months after representing to this Court that this case involves “highly personal and sensitive information” warranting a broad protective order, Defendant now wants to publicize police reports concerning Ms. Giuffre - most of them from when she was a child, some of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s confidentiality designation is without merit, and it is for improper purposes. Therefore, it should be denied. Ms. Giuffre moved to maintain her confidentiality of highly sensitive documents. They are police reports involving Ms. Giuffre, including two police reports describing Ms. Giuffre as a fourteen-year-old victim of rape. Other police reports show her to be the victim of other crimes, including domestic violence. Defendant should not be allowed to make these police reports public, nor disseminate them to third parties. Defendant’s Response brief is devoid of any argument to allow her to make these documents public, and completely devoid of any case law. 1 DE 38 at 1. - Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 2 of 12 2 Instead, Defendant mischaracterizes the police reports at issue. For example, in her “Factual Background,” what Defendant characterizes as a “simulated sex act” for which Ms. Giuffre “cried rape,” actually is a police report as follows: “I then had [REDACTED] get off of [REDACTED]. I observed that [REDACTED] was very intoxicated, and she was unable to stand on her legs. She was unable to crawl . . .Based on [REDACTED] intoxicated condition, a [sic] ambulance was called to transport her to [REDACTED] to check on her condition. I then met with [REDACTED] and his mother. I advised [REDACTED] of his Miranda rights . . . Upon arrival, at the E.R., I met with [REDACTED] who stated that while enroute to the E.R. she was conducting a head to toe evaluation when the patient stated that she had to urinate. [REDACTED] was assisting [REDACTED] remove her panties when she noticed grass and twig particles in the crotch area of [REDACTED] panties as well as a small amount of blood, an unknown clear substance, and a substance which appeared to be semen. She also saw abrasions on [REDACTED] buttocks. ” See GM 00790-801. To be clear, Defendant will be able to use this report in these proceedings – if she can prove it relevant and otherwise admissible. Indeed, under the protective order, she is permitted to share it with witnesses. Thus, the confidentiality designation made by Ms. Giuffre merely prevent Defendant from running to the press with these reports, which is, of course, what she seeks to do.2 As is in some of her other briefs, Defendant fails to cite a single case supporting her position. Nor does she respond in any way to the case law advanced by Ms. Giuffre in the instant motion. Instead, Defendant says that the police report documenting Ms. Giuffre’s rape while a minor has her name redacted. Of course, such a redaction does Ms. Giuffre little good when Defendant and her cohorts distribute it to the press - the identity of the victim in the police report will presumably be supplied by Defendant. Indeed, Defendant and/or her joint defense partners have already made it known to the media that this very police report concerns Ms. Giuffre, see 2 This plan was admitted by her joint defense partner, Alan Dershowitz, in his baseless Motion to Intervene (DE 362). - Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 3 of 12 3 Defendant’s brief at p. 5, which is why Ms. Giuffre’s counsel had to respond to the media inquiry about it in the first place. A redacted name does nothing to protect Ms. Giuffre’s identity when Defendant is the one leaking the report to the press. Since Ms. Giuffre filed her motion for a Protective Order, Defendant’s joint defense partner, Alan Dershowitz, has also made distorted representations to the Court and asks, without standing, for this Court to strip away designations made under its order so that he, too, can take confidential litigation materials to the press.3 As the adverse testimonial evidence piles up against Defendant,4 it appears she and Dershowitz are planning another media blitz in an attempt to discredit and defame Ms. Giuffre. The Court is aware that a mountain of testimonial evidence, from multiple witnesses, firmly establishes Defendant operated as convicted pedophile Jeffrey Epstein’s procurer of underage girls. The Court is also aware that, as things stand today, all of this testimony is under 3 Id. Ms. Giuffre will be filing an opposition to Dershowitz’s motion to intervene shortly. 4 See McCawley Decl. at Composite Exhibit 1, Figueroa June 24, 2016 Dep. Tr. Vol. 1 at 96-97 and 103 (Figueroa testified that Plaintiff told him about threesomes with Defendant and Epstein which included the use of strap-ons); and Vol. 2 at 200 (Figueroa testified that Defendant called him inquiring if he had found any other girls for Epstein); Johanna Sjoberg’s May 18, 2016 Dep. Tr. at 8-9, 13, 33-35, 142-143(testifying that Defendant recruited her for sex with Epstein under the guise of answering phones, a job that lasted one day, because her second day Defendant asked her to start giving massages, and it soon made it clear that Sjoberg’s purpose was to bring Epstein to orgasm so Defendant didn’t have to all of the time); Rinaldo Rizzo’s June 10, 2016 Dep. Tr. at 52-60 (Defendant’s friend’s house manager, through tears, described how Defendant tried to force a 15 year old Swedish girl to have sex with Epstein through threats and stealing her passport); Juan Alessi’s June 1, 2016 Dep. Tr. at 28, 52-54 (Epstein’s house manager, testified that Defendant was one of the people who procured the over 100 girls he witnessed visit Epstein, and that he had to clean Defendant’s sex toys); Lynn Miller’s May 24, 2016 Dep. Tr. at 115 (testified that Defendant became Ms. Giuffre’s “new momma”); Detective Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30 (the detective who led the investigation of Epstein, testified that Defendant procured underage girls for Epstein); David Rodgers’ June 3, 2016 Dep. Tr. at 18, 34- 36; see also Exhibit 2 Excerpted Rodgers Dep. Ex. 1 at flight #s 1433-1434, 1444-1446, 1464- 1470, 1478-1480, 1490-1491, 1506, 1525-1526, 1528, 1570 and 1589 (Epstein’s pilot testified that the passenger listed on his flight log bearing the initials – GM – was in fact Ghislaine Maxwell and Rodgers was the pilot on at least 23 of the flights in which Defendant flew with Plaintiff), etc. Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 4 of 12 4 this Court’s Protective Order, and cannot be disclosed to the public. For instance, Ms. Sjoberg’s testimony of how Defendant lured her from her school to have sex with Epstein under the guise of answering phones cannot be given to the media5 . Similarly, Mr. Rizzo’s testimony about how Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein cannot be given to the media.6 Likewise Mr. Alessi’s testimony about how Defendant brought girls over for Epstein is also under a confidentiality order.7 So too with Mr. Figueroa’s testimony about how Defendant would call him to bring over underage girls and how Defendant and Epstein would have threesomes with Ms. Giuffre.8 Defendant’s own admission of how she and Epstein had threesomes with multiple different girls whose names she can’t even remember9 also has been designated as confidential.10 Ms. Giuffre has never sought to challenge Defendant’s sweeping confidentiality designations, which Defendant has freely employed to hide the voluminous incriminating evidence in this case. Defendant, on the other hand, appears to operating from different premises. Knowing that the documentary and testimonial evidence in this case are fatal to all her purported defenses, Defendant appears to be planning a preemptive and one-sided media strike to try to discredit Ms. Giuffre.11 Indeed, a recent brief before this Court makes clear that Defendant 5 Id. 6 Id. 7 Id. 8 Id. 9 See McCawley Dec. at Exhibit 3, Maxwell Dep. Tr. at 59:3-17 (July 22, 2016). 10 Interestingly despite that admission, Defendant has the gall to publically call Ms. Giuffre, a longtime-married, mother of three, a “sexually permissive woman.” 11 Tellingly, nowhere in her brief does Defendant mention to the court why she wants to make these documents public. Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 5 of 12 5 is not acting alone in this effort, but is teaming up with Alan Dershowitz12 to ask this Court to release additional documents (but, naturally, none of the condemning documents Defendant has marked confidential). Part of Defendant’s frantic attempt to discredit Ms. Giuffre is to publicly reveal that she was sexually assaulted as a 14 year old, yet announce to the world that she “cried rape,”13 and to humiliate her family (including three minor children) by publicizing she was the victim of domestic abuse in 2015. As the Court saw during its in camera review, Defendant and Mr. Gow previously exchanged emails about how to leak information to the press to discredit Ms. Giuffre by saying that she “cried rape” when she was 14 (GM_00577): Defendant has been liberal with her own confidentiality designations. In fact, Defendant has even requested that significant parts of this Court’s Orders be treated as “confidential.” For example, when this Court issued its June 20, 2016, Order directing Defendant to turn over documents that she improperly claimed as “privileged,” Defendant redacted the public version of the Order to erase all reference to her extensive communications with her boyfriend, convicted pedophile Jeffrey Epstein. While seeking to publicize confidential information about Ms. Giuffre, Defendant apparently does not want the world not know that she continues to maintain 12 Defendant has even filed an Affidavit from Dershowitz’s attorney which states that there is a common interest between them. Curiously, the name of Dershowitz’s attorney, as is the name of Dershowitz himself, is redacted in the public version of these briefs. See (DE 387). 13 As the Court saw during its in camera review, Defendant and Mr. Gow exchanged emails about how to discredit her by saying that she “cried rape” when she was 14. From: Sent: To: Subject: Ghislaine Some helpful leakage ... Ross Gow Tuesday, February 24, 2015 3:36 AM G Max; Philip Barden VR cried rape - prior case dismissed as pmsecutors found her 'not credible' Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 6 of 12 6 her close relationship with Jeffrey Epstein and plotted with him to defame Ms. Giuffre. Defendant has also chosen to designate as confidential the fact that she has a DUI conviction,14 so that her own criminal activity for which she has been convicted is not in the media. II. DISCUSSION Ms. Giuffre has not challenged any of Defendant’s self-serving confidentiality designations - designations that do not protect legitimate interests (such as trademark or copyright information) but rather conceal shameful aspects of Defendant’s life, including all the testimony regarding the specifics on just how she recruited underage girls for sex with convicted pedophile Jeffrey Epstein But now Defendant challenges Ms. Giuffre’s designation of a police report involving rape as confidential. The Court should not countenance the one-sided attempt at gamesmanship by Defendant (and Dershowitz), who use confidentiality designations as a shield to block release of information about Epstein’s sex trafficking while attempting to strike down Ms. Giuffre designations about such things as being sexually assaulted while a child. Given the extremity of the position she is staking out, it is unsurprising that Defendant’s entire brief cites no case law, and presents no argument to refute Ms. Giuffre’s case law. The material Defendant seeks to send to the press is exactly the type of information that Protective Orders are meant to protect, and this Court should deem these documents as confidential. A. The Court can Order that these Documents be Made Confidential Either Under the Existing Protective Order or Independent of the Protective Order Ms. Giuffre explained in detail why her application to the Court is timely filed under the Protective Order [DE 62], and will not burden the Court with a recitation of such details and arguments. The simple fact remains that these materials should remain confidential, and 14 See McCawley Dec. at Exhibit 4, Maxwell Dep. Tr. at 390:13-15 (April 22, 2016). • Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 7 of 12 7 Defendant cannot articulate one legitimate purpose for making them public. Accordingly, they should remain confidential under the existing protective order. In addition, even if the Court were to find, for some reason, that the motion is untimely under the Protective Order, or that these documents do not come within the ambit of the existing protective Order, this Court still clearly has the inherent power to determine that these documents are confidential and should be kept under seal. Rule 26(c) of the Federal Rules of Civil Procedure permits a district court to “make any order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense” upon a showing of good cause. In her moving brief, Ms. Giuffre has established “good cause” for these documents to remain and/or be deemed confidential by the Court. Therefore, the Court should grant the instant motion independent of the language of the Protective Order (drafted by Defendant). As this Court will remember, the Court twice allowed the parties to make suggested redactions to the public versions of its Orders (see, e.g., DE 135). While the redactions were agreed upon by the parties, they were solely at Defendant’s request. This is a case concerning sex abuse of minors, brought by a minor victim of sex abuse. If any civil case cries out for protective treatment, it is this one. As the Defendant explained to this Court back in March of 2016, the materials in this case, and the materials at issue in the instant motion, are sensitive in nature, and therefore fall squarely into the categories of material over which courts routinely grant protection. C.F. Strategic Growth Intern., Inc. v. Remote MDX, Inc., 2007 WL 3341522, at *3 (S.D.N.Y., Nov. 9, 2007) (Sweet, J.) (“To the extent that RMDX is concerned about the sensitive nature of the - Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 8 of 12 8 redacted information, those concerns should be allayed by the September 13, 2007 Stipulated Protective Order”). In this case, unlike Maxwell who has refused to produce documents, Ms. Giuffre has produced a number of documents including turning over personal, embarrassing documents that bear no relation to the claim at issue in this case. Indeed, Defendant has procured other documents with the same issues, including those documenting her being raped as a 14 year old and being beaten by her husband, the father of her three minor children. These are the types of documents for which confidentiality treatment during pre-trial proceedings is appropriate. B. Defendant’s Challenge of these Materials (and her Joint Defense Partner’s Challenge of Other Materials) Frustrate this Court’s Ability to Resolve the Claim at Issue, and is a Waste of Judicial Economy Defendant and her joint defense partner, Dershowitz, for no apparent reason than their media smear campaign, are now tying-up this Court’s docket, asking the Court to engage in a document-by-document determination of confidentiality of the discovery in this case. This is a waste of judicial resources, as it in no way furthers the resolution of the claim before this court. Cf. In re Terrorist Attacks on September 11, 2001, 454 F.Supp.2d 220, 223 (S.D.N.Y.2006) (“document-by-document confidentiality determinations . . . would impose an enormous burden upon the Court and severely hinder its progress toward resolution of pretrial matters”). Moreover, should Defendant and her joint defense partner prevail in these baseless efforts, Ms. Giuffre would be forced to apply to the Court to lift the confidentiality designations from parallel discovery materials in this case that refute what Defendant and her proxies say in the media (materials that are present in abundance in this case). None of this motion practice aids in the resolution of the claim before this Court, but would merely frustrate that resolution. Accordingly, the Court should grant Ms. Giuffre’s motion. Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 9 of 12 9 C. Details Concerning Ms. Giuffre’s Rape as a 14 Year Old Are Only in The Public Realm Because, Upon Information and Belief, Defendant and/or Her Joint Defense Partners Previously Fed Them to The Media Defendant incorporated into her Response brief the media inquiry about Ms. Giuffre’s sexual assault and Sigrid McCawley’s response made on Ms. Giuffre’s behalf. This exchange illustrates exactly why Ms. Giuffre’s motion should be granted. The Court has seen the email from Ross Gow, Defendant’s public relations agent, informing her of the strategy of leaking the information to the press for the purpose of discrediting Ms. Giuffre by falsely claiming that she “cried rape” as a 14 year old.15 Unsurprisingly, the media was then tipped off to Defendant’s false and twisted version of the events, to which Ms. McCawley made a response. The Court has seen Defendant’s play book in action. Significantly, there is not a single word in Defendant’s brief refuting the fact that she challenges this confidentiality designation for improper purposes. III. CONCLUSION Ms. Giuffre was a child victim of sexual abuse, which is undisputed. Upon Defendant’s own motion, this Court entered a Protective Order in this matter. Ms. Giuffre has shown good cause for confidentiality of the materials at issue. Therefore, the Court should hold that these materials are confidential. This Court should also direct Defendant to disclose all the individuals to whom she has already disseminated the material at issue, and direct the Defendant to recall such material forthwith. DATED: August 23, 2016. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Meredith Schultz Sigrid McCawley (Pro Hac Vice) 15 See GM_00577, above. Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 10 of 12 10 Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-520216 16 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 11 of 12 11 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 23, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: lmenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Meredith Schultz Meredith Schultz Case 1:15-cv-07433-LAP Document 1335-5 Filed 01/09/24 Page 12 of 12 EXHIBIT 1 (FILE UNDER SEAL) Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 1 of 469 Highly Confidential Page 1 HIGHLY CONFIDENTIAL AEO UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -----------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. Case No: 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. -----------------------------x HIGHLY CONFIDENTIAL DEPOSITION OF SARAH RANSOME NEW YORK, NEW YORK Friday, February 17, 2017 Reported by: JEREMY RICHMAN JOB NO: 300491 MAGNA LEGAL SERVICES 320 West 37th Street, 12th Floor New York, New York 10018 (866) 624-6221 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 2 of 469 Highly Confidential Page 2 1 HIGHLY CONFIDENTIAL AEO 2 3 4 February 17, 2017 5 9:00 a.m. 6 7 DEPOSITION of SARAH RANSOME, held 8 at the offices of Boies, Schiller & Flexner, 9 575 Lexington Avenue, New York, New York, 10 before JEREMY RICHMAN, a Shorthand Reporter and 11 Notary Public of the State of New York. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 3 of 469 Highly Confidential Page 3 1 HIGHLY CONFIDENTIAL AEO 2 APPEARANCES: 3 4 BOIES, SCHILLER & FLEXNER, LLP 5 Attorneys for plaintiff 6 401 East Las Olas Boulevard, Suite 1200 7 Fort Lauderdale, FL 33301-2211 8 BY: SIGRID STONE MCCAWLEY, ESQ. 9 (smccawley@bsfllp.com) 10 11 12 HADDON, MORGAN AND FOREMAN, P.C 13 Attorneys for Defendant 14 150 East 10th Avenue 15 Denver, CO 80230 16 BY: LAURA A. MENNINGER, ESQ. 17 JEFFREY S. PAGLIUCA, ESQ. 18 (lmenninger@hmflaw.com) 19 (jpagliuca@hmflaw.com) 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 4 of 469 Highly Confidential Page 4 1 HIGHLY CONFIDENTIAL AEO 2 APPEARANCES (Continued): 3 4 J. STANLEY POTTINGER, PLLC 5 Attorneys for the witness 6 49 Twin Lakes Road, Suite 100 7 South Salem, NY 10590 8 BY: J. STANLEY POTTINGER, ESQ. 9 (stanpottinger@aol.com) 10 11 12 M I N T Z & G O L D , L L P 13 A t t o r n e y s f o r t h e w i t n e s s 14 6 0 0 T h i r d A v e n u e 15 N e w Y o r k , N Y 1 0 0 1 6 16 B Y : P E T E R G U I R G U I S , E S Q . 17 ( g u i r g u i s @ m i n t z a n d g o l d . c o m ) 18 19 20 A L S O P R E S E N T : 21 G H I S L A I N E M A X W E L L , v i a t e l e c o n f e r e n c e 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 5 of 469 Highly Confidential Page 5 1 HIGHLY CONFIDENTIAL AEO 2 IT IS HEREBY STIPULATED AND AGREED 3 by and between the attorneys for the respective 4 parties herein, that filing and sealing be and 5 the same are hereby waived. 6 IT IS FURTHER STIPULATED AND AGREED 7 that all objections, except as to form of the 8 question, shall be reserved to the time of the 9 trial. 10 IT IS FURTHER STIPULATED AND AGREED 11 that the within deposition may be sworn to and 12 signed before any officer authorized to 13 administer an oath, with the same force and 14 effect as if signed and sworn to before the 15 Court. 16 17 18 19 20 - oOo - 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 6 of 469 Highly Confidential Page 6 1 HIGHLY CONFIDENTIAL AEO 2 MS. MENNINGER: If we could 3 have counsel enter their 4 appearances for the record, 5 please. 6 MR. GUIRGUIS: Sure. My 7 name is Peter Guirguis. I'm 8 appearing on behalf of the 9 witness today. 10 M S . M C C A W L E Y : S i g r i d 11 M c C a w l e y o n b e h a l f o f V i r g i n i a 12 G i u f f r e , t h e p l a i n t i f f i n t h e 13 a c t i o n . 14 M R . P O T T I N G E R : S t a n 15 P o t t i n g e r o n b e h a l f o f t h e 16 w i t n e s s . 17 M S . M E N N I N G E R : L a u r a 18 M e n n i n g e r a n d J e f f r e y P a g l i u c a o n 19 b e h a l f o f M s . M a x w e l l , w h o i s 20 a p p e a r i n g b y t e l e p h o n e . 21 S A R A H R A N S O M E , h a v i n g b e e n 22 c a l l e d a s a w i t n e s s , h a v i n g f i r s t 23 b e e n d u l y s w o r n b y a N o t a r y 24 P u b l i c ( J e r e m y R i c h m a n ) o f t h e 25 S t a t e o f N e w Y o r k , w a s e x a m i n e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 7 of 469 Highly Confidential Page 7 1 HIGHLY CONFIDENTIAL AEO 2 and testified as follows: 3 EXAMINATION BY 4 MS. MENNINGER: 5 Q. Good morning, Ms. Ransome. 6 A. Good morning. 7 Q. Can you please give us your 8 full name. 9 A. Sarah Emma Ashley Ransome. 10 Q . A n d w h a t i s y o u r b i r t h d a t e ? 11 A . 1 3 t h o f t h e 8 t h , 1 9 8 4 . 12 Q . A n d w h a t i s y o u r c u r r e n t 13 a d d r e s s ? 14 M R . G U I R G U I S : I ' m g o i n g t o 15 o b j e c t t o c u r r e n t a d d r e s s . 16 Q . Y o u c a n a n s w e r . 17 M R . G U I R G U I S : Y o u c a n g i v e 18 y o u r l a s t p e r m a n e n t a d d r e s s . 19 A . I t w a s C a r r e r d e C a n u d a . 20 ( A n o f f - t h e - r e c o r d 21 d i s c u s s i o n w a s h e l d . ) 22 A . T h a t ' s B a r c e l o n a , a n d I 23 c a n ' t r e m e m b e r t h e p o s t c o d e . 24 Q . A n d w h a t d o e s t h a t m e a n , 25 t h a t ' s y o u r l a s t p e r m a n e n t a d d r e s s ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 8 of 469 Highly Confidential Page 8 1 HIGHLY CONFIDENTIAL AEO 2 A. I reside there. 3 Q. Do you rent an apartment? 4 A. My partner does. 5 Q. Who is your partner? 6 MR. GUIRGUIS: Objection. 7 Q. Who is your partner? 8 THE WITNESS: Do I have to 9 answer that? 10 M R . G U I R G U I S : Y e s . 11 A . P e t e r C o u l t h a r d . 12 Q . I ' m s o r r y ? 13 A . P e t e r C o u l t h a r d . 14 Q . H o w d o y o u s p e l l t h a t l a s t 15 n a m e ? 16 A . C - O - U - L - T - H - A - R - D . 17 Q . A n d h o w l o n g h a s P e t e r b e e n 18 y o u r p a r t n e r ? 19 M R . G U I R G U I S : I ' m g o i n g t o 20 o b j e c t . I ' m n o t s u r e w h a t t h e 21 r e l e v a n c e o f t h i s i s o r w h e r e 22 y o u ' r e g o i n g w i t h t h i s . 23 Q . H o w l o n g h a s P e t e r b e e n y o u r 24 p a r t n e r ? 25 T H E W I T N E S S : S o r r y , c a n I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 9 of 469 Highly Confidential Page 9 1 HIGHLY CONFIDENTIAL AEO 2 just ask a question? I would 3 like to just clarify. When you 4 say objection, does that mean I 5 actually have to answer the 6 question? Because that's 7 irrelevant. 8 MR. GUIRGUIS: Right. 9 Unless I'm telling you not to 10 a n s w e r , y o u n e e d t o a n s w e r . 11 T H E W I T N E S S : S o I d o n ' t 12 n e e d t o a n s w e r ? 13 M R . G U I R G U I S : N o , y o u d o 14 n e e d t o a n s w e r t h i s . 15 A . O k a y . W e ' v e b e e n t o g e t h e r 16 a l m o s t a y e a r . 17 Q . A n d w h a t i s y o u r c u r r e n t 18 o c c u p a t i o n ? 19 A . I ' m a w r i t e r . 20 Q . A n d w h a t d o y o u w r i t e ? 21 A . J u s t s t u f f , y o u k n o w ? J u s t 22 a b o u t f a c t u a l s t u f f . Y o u k n o w , j u s t a 23 b i t o f t h i s , b i t o f t h a t . 24 Q . H a v e y o u b e e n p a i d f o r a n y 25 o f y o u r w r i t i n g ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 10 of 469 Highly Confidential Page 10 1 HIGHLY CONFIDENTIAL AEO 2 A. No. It's more of a hobby, 3 really. 4 Q. Are you employed? 5 A. Nope. 6 Q. Do you have any source of 7 income? 8 A. My partner -- 9 MR. GUIRGUIS: I'm going to 10 o b j e c t t o t h a t . I n c o m e i s o u t . 11 Y o u d o n ' t h a v e t o a n s w e r 12 t h a t . 13 Q . D o y o u h a v e a n y s o u r c e o f 14 i n c o m e ? 15 M R . G U I R G U I S : I j u s t 16 o b j e c t e d t o t h a t . Y o u d o n ' t h a v e 17 t o a n s w e r . 18 M S . M E N N I N G E R : I s t h e r e a 19 p r i v i l e g e y o u ' r e a s s e r t i n g ? 20 M R . G U I R G U I S : I ' m n o t s u r e 21 w h a t t h e r e l e v a n c e i s , a n d I ' m 22 n o t g o i n g t o a l l o w - - 23 M S . M E N N I N G E R : D o y o u 24 b e l i e v e t h a t r e l e v a n c e i s a 25 p r o p e r o b j e c t i o n d u r i n g a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 11 of 469 Highly Confidential Page 11 1 HIGHLY CONFIDENTIAL AEO 2 deposition? 3 MR. GUIRGUIS: I believe 4 that if you go far afield with 5 this witness, that the judge is 6 not going to appreciate it, and 7 that I'm not going to just sit 8 here and be a potted plant and 9 allow her to answer any questions 10 o n a n y s u b j e c t t h a t y o u s e e f i t . 11 M S . M E N N I N G E R : O n 12 r e l e v a n c e ? Y o u ' r e i n s t r u c t i n g 13 h e r n o t t o a n s w e r o n a r e l e v a n c e 14 o b j e c t i o n ? I s t h a t w h a t y o u ' r e 15 s a y i n g ? 16 M R . G U I R G U I S : I j u s t 17 o b j e c t e d . 18 M S . M C C A W L E Y : I ' m g o i n g t o 19 o b j e c t o n b e h a l f o f t h e 20 p l a i n t i f f , V i r g i n i a G i u f f r e , t o 21 t h e e x t e n t t h a t y o u ' r e r e q u e s t i n g 22 f r o m a n o n p a r t y f i n a n c i a l 23 i n f o r m a t i o n , w h i c h i s n o t a l l o w e d 24 u n d e r N e w Y o r k l a w . 25 M S . M E N N I N G E R : I h a v e a s k e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 12 of 469 Highly Confidential Page 12 1 HIGHLY CONFIDENTIAL AEO 2 her whether she has any source of 3 income, and you're going to 4 object -- 5 MS. MCCAWLEY: Yes. 6 MS. MENNINGER: -- and 7 instruct her not to answer as 8 well? 9 MS. MCCAWLEY: I'm not 10 i n s t r u c t i n g h e r n o t t o a n s w e r . 11 I ' m j u s t m a k i n g a r e c o r d . 12 M R . G U I R G U I S : I t ' s 13 f i n a n c i a l i n f o r m a t i o n - - 14 M S . M E N N I N G E R : A n d w h e t h e r 15 s h e h a s a f i n a n c i a l m o t i v e i s 16 r e l e v a n t . 17 Q . S o I ' m g o i n g t o a s k y o u a 18 l a s t t i m e : D o y o u h a v e a n y s o u r c e o f 19 i n c o m e ? 20 M R . G U I R G U I S : I ' m g o i n g t o 21 i n s t r u c t y o u a g a i n n o t t o a n s w e r . 22 Q . H a s a n y o f y o u r w r i t i n g b e e n 23 p u b l i s h e d b y a n y o n e ? 24 A . N o . 25 Q . H a v e y o u s o u g h t t o h a v e y o u r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 13 of 469 Highly Confidential Page 13 1 HIGHLY CONFIDENTIAL AEO 2 writing published by anyone? 3 A. No. 4 Q. What is your partner's 5 occupation? 6 MR. GUIRGUIS: Objection. 7 MS. MCCAWLEY: Objection. 8 MR. GUIRGUIS: I'm going to 9 object, yeah. Same objection. 10 M S . M E N N I N G E R : I f y o u a r e 11 g o i n g t o i n s t r u c t t h e w i t n e s s n o t 12 t o a n s w e r , p l e a s e s a y t h a t 13 c o n t e m p o r a n e o u s w i t h y o u r 14 o b j e c t i o n , b e c a u s e t h e r e a r e t w o 15 d i f f e r e n t t h i n g s : T h e r e a r e 16 o b j e c t i o n s a n d i n s t r u c t i o n s n o t 17 t o a n s w e r . 18 S o a r e y o u i n s t r u c t i n g h e r 19 n o t t o a n s w e r w h a t h e r p a r t n e r ' s 20 o c c u p a t i o n i s ? 21 M R . G U I R G U I S : R i g h t . S a m e 22 o b j e c t i o n . I ' m i n s t r u c t i n g t h e 23 w i t n e s s n o t t o a n s w e r o n t h e 24 b a s i s o f b o t h r e l e v a n c e a n d 25 b e c a u s e s h e i s a t h i r d - p a r t y n o n - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 14 of 469 Highly Confidential Page 14 1 HIGHLY CONFIDENTIAL AEO 2 -- I'm sorry -- nonparty witness 3 who you are asking for financial 4 information about -- 5 MS. MENNINGER: No, I asked 6 for an occupation. 7 MS. MCCAWLEY: I'm going to 8 object. That relates directly to 9 financial information, so it's 10 c o v e r e d b y N e w Y o r k l a w w i t h 11 r e s p e c t t o n o n p a r t y w i t n e s s e s . 12 Q . W h a t a r e t h e n a m e s o f y o u r 13 p a r e n t s ? 14 A . E l i z a b e t h S h a w a n d M a r k 15 R a n s o m e . 16 Q . H o w d o y o u s p e l l S h a w ? 17 A . S - H - A - W . 18 Q . A n d w h e r e d o y o u r p a r e n t s 19 l i v e ? 20 A . I ' m n o t c o m f o r t a b l e g i v i n g 21 m y m o t h e r ' s a n d m y f a t h e r ' s a d d r e s s t o 22 y o u . 23 M S . M E N N I N G E R : A r e y o u 24 i n s t r u c t i n g h e r n o t t o a n s w e r ? 25 M S . M C C A W L E Y : D o y o u w a n t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 15 of 469 Highly Confidential Page 15 1 HIGHLY CONFIDENTIAL AEO 2 to confer? 3 MR. GUIRGUIS: Give me a 4 moment on this. 5 THE WITNESS: We're really 6 well organized. 7 (Time noted: 9:21 a.m.) 8 (Recess.) 9 (Time noted: 9:23 a.m.) 10 Q . M s . R a n s o m e , t h e r e w a s a 11 q u e s t i o n p e n d i n g w h e n y o u t o o k a b r e a k 12 w i t h y o u r l a w y e r s . C a n y o u p l e a s e 13 a n s w e r t h e q u e s t i o n . 14 M R . G U I R G U I S : I ' m 15 i n s t r u c t i n g t h e w i t n e s s n o t t o 16 a n s w e r q u e s t i o n s r e g a r d i n g 17 c u r r e n t i n f o r m a t i o n a b o u t h e r o w n 18 l o c a t i o n , h e r f a m i l y ' s l o c a t i o n , 19 t h i n g s o f t h a t n a t u r e . 20 T h e w i t n e s s h a s e x p r e s s e d t o 21 m e f e a r s o f h a r a s s m e n t a n d t h e 22 b e l i e f t h a t s h e ' s b e i n g f o l l o w e d , 23 a n d m y u n d e r s t a n d i n g i s t h a t 24 t h e r e a r e o t h e r w i t n e s s e s t h a t 25 h a v e h a d s i m i l a r f e a r s a n d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 16 of 469 Highly Confidential Page 16 1 HIGHLY CONFIDENTIAL AEO 2 concerns. 3 And unless you make some 4 sort of proffer of the actual 5 relevance of her parents' 6 addresses, wherever those are, 7 I'm not going to have her answer. 8 MS. MENNINGER: Okay. Where 9 does that understanding come 10 f r o m , p l e a s e , M r . G u i r g u i s ? 11 M r . G u i r g u i s , w h e r e d o e s 12 y o u r u n d e r s t a n d i n g c o m e f r o m ? 13 Y o u j u s t m a d e a f a c t u a l 14 r e p r e s e n t a t i o n . I w o u l d l i k e t o 15 k n o w w h e r e y o u r u n d e r s t a n d i n g 16 c o m e s f r o m . 17 M R . G U I R G U I S : Y e a h , I ' m n o t 18 b e i n g d e p o s e d . I ' m n o t g o i n g t o 19 a n s w e r y o u r q u e s t i o n s . 20 M S . M E N N I N G E R : A l l r i g h t . 21 Q . M s . R a n s o m e , d i d y o u a g r e e 22 t o b e a w i t n e s s i n t h e c a s e o f G i u f f r e 23 v e r s u s M a x w e l l ? 24 A . Y e s . 25 Q . D i d y o u v o l u n t a r i l y a g r e e t o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 17 of 469 Highly Confidential Page 17 1 HIGHLY CONFIDENTIAL AEO 2 do that? 3 A. Yes. 4 Q. Were you promised anything 5 in exchange for your testimony in the 6 Giuffre versus Maxwell case? 7 A. No. 8 Q. Were you provided legal 9 counsel? 10 A . S o r r y , d o e s t h a t m e a n - - 11 M S . M C C A W L E Y : Y o u h a v e a 12 l a w y e r , y e s ? 13 M R . G U I R G U I S : Y e s . 14 A . Y e s . 15 Q . O k a y . H o w m a n y l a w y e r s d o 16 y o u h a v e n o w ? 17 A . T h r e e . 18 M S . M E N N I N G E R : I w o u l d l i k e 19 t h e r e c o r d t o r e f l e c t t h a t 20 w i t n e s s i s c h e c k i n g w i t h t h e 21 l a w y e r s t o g e t a n s w e r s t o t h e s e 22 q u e s t i o n s . 23 M R . P O T T I N G E R : W a i t , w a i t , 24 w a i t . O b j e c t i o n . 25 M R . G U I R G U I S : T h e r e i s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 18 of 469 Highly Confidential Page 18 1 HIGHLY CONFIDENTIAL AEO 2 absolutely no exchange. No words 3 were spoken by -- 4 MS. MENNINGER: 5 Mr. Pottinger, did you put up a 6 number of fingers? 7 Did you put up a number of 8 fingers, Mr. Pottinger? 9 MR. POTTINGER: You said, 10 I ' m g o i n g t o o b j e c t b e c a u s e t h e 11 w i t n e s s i s a n s w e r i n g t h e s e 12 q u e s t i o n s , i n t h e p l u r a l . 13 M S . M E N N I N G E R : M m - h m m . 14 M R . P O T T I N G E R : T h a t i s 15 i n a c c u r a t e . W h e n s h e l o o k e d a t 16 m e t o a s k h o w m a n y l a w y e r s s h e 17 h a d , I s a i d t h r e e w i t h t h r e e 18 f i n g e r s . T h a t i s a s i n g l e 19 r e q u e s t o n h e r p a r t a n d a s i n g l e 20 a n s w e r , n o t m u l t i p l e . 21 M S . M E N N I N G E R : N o . S h e h a s 22 l o o k e d t o h e r l a w y e r s f o r 23 p r e v i o u s a n s w e r s . 24 W e ' l l j u s t m a k e a r e c o r d a s 25 w e g o a l o n g . T h a n k y o u . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 19 of 469 Highly Confidential Page 19 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: You could 3 have had a videotape here so that 4 we would have a record of that, 5 because I think your verbal 6 record is inaccurate, so... 7 MR. POTTINGER: And, in 8 fact, she -- this is Mr. 9 Pottinger speaking. 10 A n d , i n f a c t , s h e h a s n o t 11 l o o k e d a t m e d u r i n g t h i s 12 d e p o s i t i o n e x c e p t o n e t i m e , w h i c h 13 w a s f o r w h a t I t o o k t o b e a 14 r e q u e s t t o k n o w h o w m a n y l a w y e r s 15 s h e h a s . 16 M S . M E N N I N G E R : S o a r e y o u 17 b e i n g d e p o s e d , M r . P o t t i n g e r ? 18 M R . P O T T I N G E R : I a m n o t . 19 Q . M s . R a n s o m e , h o w m a n y 20 l a w y e r s d o y o u t h i n k y o u h a v e ? 21 A . T h r e e . 22 Q . C a n y o u p l e a s e n a m e t h e m ? 23 A . P e t e r , S i g r i d a n d S t a n . 24 Q . I s M r . B r a d l e y E d w a r d s 25 r e p r e s e n t i n g y o u ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 20 of 469 Highly Confidential Page 20 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. Is Mr. Paul Cassell 4 representing you? 5 A. No. 6 Q. Is Mr. David Boies 7 representing you? 8 A. Yes. 9 MS. MCCAWLEY: I just want 10 t o b e c l e a r f o r t h e r e c o r d i f 11 y o u ' r e t a l k i n g a b o u t r e p r e s e n t i n g 12 g e n e r a l l y o r y o u ' r e t a l k i n g a b o u t 13 a p a r t i c u l a r m a t t e r . B e c a u s e w e 14 h a v e a c o u p l e m a t t e r s . 15 M S . M E N N I N G E R : I ' m a s k i n g 16 q u e s t i o n s h e r e . 17 M S . M C C A W L E Y : N o , I 18 u n d e r s t a n d t h a t y o u h a v e t o m a k e 19 t h e r e c o r d c l e a r - - 20 M S . M E N N I N G E R : M s . 21 M c C a w l e y , i f y o u w a n t t o a s k h e r 22 q u e s t i o n s l a t e r , y o u a r e m o r e 23 t h a n w e l c o m e t o d o s o . I a m 24 g o i n g t o a s k q u e s t i o n s o f t h e 25 w i t n e s s I a m d e p o s i n g . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 21 of 469 Highly Confidential Page 21 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: Well, we want 3 the record to be clear that there 4 are more than one action -- 5 MS. MENNINGER: You can ask 6 questions when you're doing your 7 questioning. I'm doing my 8 questioning now, and so I will 9 ask the questions. 10 M S . M C C A W L E Y : I ' m g o i n g t o 11 o b j e c t . T h e r e c o r d s h o u l d b e 12 c l e a r t h e r e i s m o r e t h a n o n e 13 a c t i o n p e n d i n g h e r e . S h e i s 14 r e p r e s e n t e d h e r e a s a n o n p a r t y 15 w i t n e s s , a n d s h e a l s o h a s h e r o w n 16 a c t i o n p e n d i n g . 17 M R . P A G L I U C A : T h a n k y o u f o r 18 t h a t s p e a k i n g o b j e c t i o n , M s . 19 M c C a w l e y , a n d c o m m u n i c a t i n g t h a t 20 i n f o r m a t i o n t o t h e w i t n e s s , w h i c h 21 y o u k n o w i s t o t a l l y i m p r o p e r . 22 M S . M C C A W L E Y : N o w , t h a t ' s 23 t w o p e o p l e o b j e c t i n g r i g h t n o w . 24 I s i t g o i n g t o b e L a u r a t a k i n g 25 t h i s d e p o s i t i o n o r y o u , J e f f ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 22 of 469 Highly Confidential Page 22 1 HIGHLY CONFIDENTIAL AEO 2 You guys have done this to me 3 before, and it's not a position 4 where you're allowed to object 5 and she's allowed to object. You 6 guys pulled that at the last 7 deposition, so please do not do 8 this here. 9 MR. PAGLIUCA: I was just 10 t h a n k i n g y o u . 11 Q . A l l r i g h t . S o t h e n u m b e r o f 12 l a w y e r s w e ' r e u p t o s o f a r i s 13 M r . G u i r g u i s , M s . M c C a w l e y , 14 M r . P o t t i n g e r , M r . E d w a r d s , M r . B o i e s . 15 T h a t ' s f i v e , c o r r e c t ? 16 A . C a n I j u s t a s k y o u a 17 q u e s t i o n ? 18 Q . N o , y o u c a n n o t . 19 A . O k a y . 20 Q . A r e t h o s e f i v e l a w y e r s t h a t 21 a r e r e p r e s e n t i n g y o u ? 22 M R . G U I R G U I S : O b j e c t i o n . 23 Q . Y e s o r n o ? 24 A . Y e s . 25 Q . A l l r i g h t . A n y o n e e l s e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 23 of 469 Highly Confidential Page 23 1 HIGHLY CONFIDENTIAL AEO 2 representing you? 3 A. No. 4 Q. Ms. Schultz? Is 5 Ms. Meredith Schultz representing you? 6 A. No. 7 Q. How much are you paying for 8 any of those lawyers? 9 A. It's on a pro-bono basis. 10 Q . D o y o u k n o w w h a t e a c h o f 11 t h o s e l a w y e r s ' n o r m a l h o u r l y r a t e s 12 a r e ? 13 A . N o . 14 Q . D o y o u k n o w h o w m a n y h o u r s 15 y o u h a v e s p e n t w i t h y o u r a t t o r n e y s ? 16 A . N o . 17 M R . G U I R G U I S : O b j e c t i o n . 18 Q . H o w m a n y h o u r s h a v e y o u 19 s p e n t w i t h M r . G u i r g u i s ? 20 M R . G U I R G U I S : O b j e c t i o n . 21 Q . W i t h o u t c o m m u n i c a t i n g t o m e 22 a n y i n f o r m a t i o n y o u a n d h e h a v e 23 s h a r e d . 24 A . A f e w , m a y b e . 25 Q . H o w m a n y ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 24 of 469 Highly Confidential Page 24 1 HIGHLY CONFIDENTIAL AEO 2 A. About 11 hours in total. 3 Q. When is the first time that 4 you met Mr. Guirguis? 5 MR. GUIRGUIS: Objection. 6 MS. MCCAWLEY: You can 7 answer. 8 MR. GUIRGUIS: You can 9 answer. 10 A . Y e s t e r d a y . 11 Q . Y o u m e t M r . G u i r g u i s 12 y e s t e r d a y ? W a s t h a t y o u r a n s w e r ? 13 A . Y e s . 14 Q . A n d w h o i s p a y i n g f o r 15 M r . G u i r g u i s ' s f e e s , i f y o u k n o w ? 16 A . I h a v e a p r o - b o n o 17 a r r a n g e m e n t . 18 Q . D o y o u k n o w i f h e ' s 19 r e c e i v i n g m o n e y f r o m a n y o n e e l s e i n 20 e x c h a n g e f o r r e p r e s e n t i n g y o u ? 21 A . N o . 22 Q . N o , y o u d o n ' t k n o w , o r n o , 23 h e i s n o t ? 24 A . I d o n ' t k n o w . 25 Q . H o w m a n y h o u r s h a v e y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 25 of 469 Highly Confidential Page 25 1 HIGHLY CONFIDENTIAL AEO 2 spent with Ms. McCawley? 3 A. Can I just clarify that 4 question? Does that mean on the 5 phone? Like what are you referring 6 to, in person or -- 7 Q. Either one. How many hours, 8 how much time have you spent with 9 Ms. McCawley in person? 10 A . I m e t w i t h M s . M c C a w l e y f o r 11 t h e f i r s t t i m e i n p e r s o n y e s t e r d a y , 12 b u t I ' v e s p e n t - - y e a h , w e ' v e b e e n - - 13 M s . M c C a w l e y w a s t h e f i r s t p e r s o n I 14 a c t u a l l y s p o k e t o . 15 Q . A n d h o w m a n y h o u r s h a v e y o u 16 s p e n t w i t h h e r o n t h e p h o n e ? 17 A . M a n y , m a n y h o u r s . 18 Q . A p p r o x i m a t e l y h o w m a n y ? 19 A . I d o n ' t k n o w . 20 Q . F i v e ? 21 M R . G U I R G U I S : O b j e c t i o n . 22 A . M o r e t h a n f i v e . 23 Q . T e n ? 24 M R . G U I R G U I S : O b j e c t i o n . 25 Q . T e n ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 26 of 469 Highly Confidential Page 26 1 HIGHLY CONFIDENTIAL AEO 2 A. Well, 10, 15. She's been 3 with me the whole way since when I 4 came forward, so she's been a very 5 prominent person. 6 Q. And when did you first speak 7 with her on the phone? 8 A. I think it was -- 9 Q. Without telling me what you 10 s a i d . 11 A . I t h i n k i t w a s N o v e m b e r . 12 Q . N o v e m b e r w h a t ? 13 A . I c a n ' t r e m e m b e r t h e d a t e . 14 Q . E a r l y N o v e m b e r ? L a t e 15 N o v e m b e r ? 16 M R . G U I R G U I S : O b j e c t i o n . 17 A . I c a n ' t r e m e m b e r . 18 Q . W a s s h e s p e a k i n g t o y o u o n 19 y o u r c e l l p h o n e o r a l a n d l i n e ? 20 A . C e l l p h o n e . 21 Q . A m o b i l e n u m b e r o r a 22 l a n d l i n e ? 23 A . A c e l l p h o n e . 24 Q . O k a y . A n d w h a t ' s t h a t c e l l 25 p h o n e n u m b e r ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 27 of 469 Highly Confidential Page 27 1 HIGHLY CONFIDENTIAL AEO 2 A. I don't have it anymore. 3 Q. That's okay. What's the 4 cell phone number? 5 A. I actually don't know. I 6 can't remember my cell phone number. 7 I don't have anything with me, so I 8 can't remember that number offhand. 9 Q. How long did you have that 10 c e l l p h o n e ? 11 A . A b o u t e i g h t m o n t h s . 12 Q . W h a t h a p p e n e d t o i t ? 13 A . I g o t r i d o f i t . 14 Q . W h y ? 15 A . B e c a u s e I f e a r f o r m y l i f e 16 b e c a u s e o f J e f f r e y E p s t e i n a n d 17 G h i s l a i n e M a x w e l l . 18 Q . W h a t d i d y o u d o w i t h i t ? 19 A . I s o l d i t . 20 Q . W h e n ? 21 A . N o v e m b e r . 22 Q . B e f o r e o r a f t e r y o u f i r s t 23 s p o k e w i t h M s . M c C a w l e y ? 24 A . B e f o r e . 25 Q . S o t h e n h o w d i d y o u s p e a k MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 28 of 469 Highly Confidential Page 28 1 HIGHLY CONFIDENTIAL AEO 2 with Ms. McCawley over the phone? 3 A. On my partner's cell phone. 4 Q. What's his cell phone 5 number? 6 MS. MCCAWLEY: Objection. 7 What's the relevance of her 8 partner's cell phone? 9 Again, this is irrelevant. 10 I t ' s h a r a s s i n g . I t ' s - - y o u ' r e 11 s e e k i n g i n f o r m a t i o n t o b e a b l e 12 t o - - t h e w i t n e s s h a s a l r e a d y 13 e x p r e s s e d f e a r a b o u t h e r - - 14 p e o p l e c u r r e n t l y g o i n g a f t e r h e r . 15 S o w e w o u l d o b j e c t t o t h a t 16 i n t i m i d a t i o n o f a n o n p a r t y 17 w i t n e s s . 18 Q . W h a t i s y o u r p a r t n e r ' s c e l l 19 p h o n e n u m b e r ? 20 M R . G U I R G U I S : I ' m d i r e c t i n g 21 t h e w i t n e s s n o t t o a n s w e r . 22 Q . H o w m a n y h o u r s h a v e y o u 23 s p e n t s p e a k i n g w i t h M r . P o t t i n g e r ? 24 A . I ' v e b e e n s p e a k i n g t o 25 M r . P o t t i n g e r f r o m N o v e m b e r . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 29 of 469 Highly Confidential Page 29 1 HIGHLY CONFIDENTIAL AEO 2 Q. When in November? 3 A. I can't remember. 4 Q. On your same cell phone that 5 you got rid of? 6 A. No, on my partner's cell 7 phone. 8 Q. And when did you first meet 9 Mr. Pottinger in person? 10 A . I t w a s i n t h e b e g i n n i n g o f 11 J a n u a r y . 12 Q . A n d w h e r e w a s t h a t m e e t i n g ? 13 A . B a r c e l o n a . 14 Q . W h e r e i n B a r c e l o n a ? 15 A . B a r c e l o n a . I t ' s B a r c e l o n a . 16 W e m e e t - - I c a n ' t r e m e m b e r t h e a r e a . 17 Q . I n a r e s t a u r a n t ? I n a 18 h o t e l ? I n a n o f f i c e ? 19 A . I n a h o t e l . 20 Q . A n d h o w l o n g d i d y o u s p e n d 21 w i t h M r . P o t t i n g e r o n t h a t o c c a s i o n ? 22 A . T w o d a y s . 23 Q . H o w m a n y h o u r s o v e r t h e t w o 24 d a y s ? 25 A . G o s h , a b o u t 1 6 . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 30 of 469 Highly Confidential Page 30 1 HIGHLY CONFIDENTIAL AEO 2 Q. How many hours did you spend 3 with Mr. Edwards? 4 MS. MCCAWLEY: Objection. 5 A. The same amount. 6 Q. He was with Mr. Pottinger? 7 A. Yeah, yes. 8 Q. And Mr. Boies, how much time 9 have you spent with Mr. Boies? 10 A . I h a v e n ' t s p e n t a n y t i m e 11 w i t h h i m y e t . 12 Q . H a v e y o u m e t h i m ? 13 A . N o . 14 Q . H a v e y o u s p o k e n t o h i m o n 15 t h e p h o n e ? 16 A . N o . 17 Q . A n d y o u h a v e n o t p a i d a n y 18 m o n e y f o r a n y o f t h o s e l a w y e r s ' t i m e , 19 c o r r e c t ? 20 A . Y e s . 21 Q . I n a d d i t i o n t o y o u r f r e e 22 l e g a l c o u n s e l , w e r e y o u g i v e n a n y t h i n g 23 e l s e i n e x c h a n g e f o r y o u r a g r e e m e n t t o 24 b e a w i t n e s s i n t h i s c a s e ? 25 M R . G U I R G U I S : O b j e c t i o n . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 31 of 469 Highly Confidential Page 31 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Did you fly over here? 4 A. Yes. 5 Q. From Barcelona? 6 A. Yes. 7 Q. Did you pay for the plane 8 ticket? 9 A. Yes. 10 Q . H o w m u c h w a s t h e p l a n e 11 t i c k e t ? 12 A . I t w a s - - I t h i n k i t w a s 13 1 , 0 0 0 - - i t w a s 1 , 0 0 0 - - I c a n ' t 14 r e m e m b e r t h e e x a c t t o t a l . 15 Q . H a s a n y o n e a g r e e d t o 16 r e i m b u r s e y o u f o r t h a t ? 17 A . N o . 18 Q . A n d y o u ' r e s t a y i n g w h e r e 19 w h i l e y o u ' r e h e r e ? 20 M R . G U I R G U I S : O b j e c t i o n . 21 A n d d i r e c t y o u n o t t o a n s w e r 22 t h a t . 23 Q . A r e y o u s t a y i n g i n a h o t e l 24 w h i l e y o u ' r e h e r e ? 25 M R . G U I R G U I S : Y o u c a n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 32 of 469 Highly Confidential Page 32 1 HIGHLY CONFIDENTIAL AEO 2 answer that. 3 A. Yeah. 4 Q. Are you paying for that? 5 MR. GUIRGUIS: Objection. 6 I'm directing you not to 7 answer. 8 MS. MCCAWLEY: You can 9 answer. 10 M R . G U I R G U I S : I t h i n k y o u 11 c a n a n s w e r . 12 M S . M C C A W L E Y : Y e a h , I t h i n k 13 y o u c a n a n s w e r . 14 M R . G U I R G U I S : T h a t ' s f i n e . 15 I a g r e e . 16 M S . M C C A W L E Y : Y o u ' r e a 17 n o n p a r t y w i t n e s s . Y o u c a n a n s w e r 18 t h a t q u e s t i o n . 19 M S . M E N N I N G E R : W h o i s - - 20 M S . M C C A W L E Y : I a m 21 r e p r e s e n t i n g V i r g i n i a . H e i s 22 r e p r e s e n t i n g t h e w i t n e s s . 23 M S . M E N N I N G E R : W e l l , y o u ' r e 24 r e p r e s e n t i n g t h e w i t n e s s a s w e l l , 25 r i g h t ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 33 of 469 Highly Confidential Page 33 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: I'm not. 3 MS. MENNINGER: Well, did 4 you just tell her she can answer 5 a question? 6 MS. MCCAWLEY: I did. 7 Q. Are you paying for the 8 hotel? 9 A. No. 10 Q . W h o ' s p a y i n g f o r t h e h o t e l ? 11 A . I t ' s o n e x p e n s e s , I t h i n k , 12 o f a w i t n e s s . I t ' s e x p e n s e s f r o m - - 13 y e a h , I d o n ' t k n o w , a c t u a l l y . 14 Q . Y o u d o n ' t k n o w w h o i s p a y i n g 15 f o r y o u r h o t e l ? 16 A . N o . 17 Q . I t ' s n o t y o u ? 18 A . N o . 19 Q . A n d h o w m u c h p e r n i g h t i s 20 y o u r h o t e l ? 21 A . I h a v e n o i d e a . 22 Q . H o w l o n g a r e y o u s t a y i n g 23 h e r e o n t h i s t r i p ? 24 A . J u s t f o r t h e d e p o s i t i o n . 25 Q . O k a y . W h e n d i d y o u a r r i v e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 34 of 469 Highly Confidential Page 34 1 HIGHLY CONFIDENTIAL AEO 2 A. It was Tuesday, late Tuesday 3 night. 4 Q. And when are you leaving? 5 A. Tomorrow evening. 6 Q. In addition to your legal 7 counsel and your hotel, is there 8 anything else you've been given in 9 exchange for your -- 10 A . N o . 11 Q . - - t o b e a w i t n e s s i n t h i s 12 c a s e ? 13 Y o u h a v e t o w a i t f o r m e t o 14 f i n i s h m y q u e s t i o n b e f o r e y o u a n s w e r . 15 A . S o r r y . 16 Q . H a v e y o u b e e n g i v e n a n y t h i n g 17 e l s e ? 18 A . N o . 19 Q . H a v e y o u b e e n p r o m i s e d 20 a n y t h i n g e l s e ? 21 A . N o . 22 Q . H a v e y o u b e e n p r o m i s e d t h a t 23 y o u w o u l d h a v e c o u n s e l t o h e l p y o u 24 b r i n g a l a w s u i t a g a i n s t a n u m b e r o f 25 p e o p l e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 35 of 469 Highly Confidential Page 35 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: Objection. 3 To the extent this gets into 4 attorney/client privileged 5 information, you're not allowed 6 to answer. 7 Q. Have your lawyers agreed to 8 bring a lawsuit on your behalf against 9 a number of people? 10 A . Y e s . 11 Q . A n d a r e y o u p a y i n g f o r t h a t 12 c o u n s e l ? 13 A . N o . 14 Q . H a v e y o u r e a c h e d a n y 15 a g r e e m e n t a b o u t a c o n t i n g e n c y f e e f o r 16 t h a t c a s e ? 17 A . C a n y o u e x p l a i n w h a t 18 c o n t i n g e n c y m e a n s ? S o r r y . 19 Q . D o y o u e x p e c t t o r e c e i v e 20 m o n e y a s a r e s u l t o f t h a t l a w s u i t ? 21 A . O h , n o . N o . 22 Q . Y o u ' r e n o t a s k i n g t o r e c e i v e 23 a n y m o n e y a s a r e s u l t o f t h a t l a w s u i t ? 24 A . N o . N o . 25 Q . A l l r i g h t . S o h a v e y o u h a d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 36 of 469 Highly Confidential Page 36 1 HIGHLY CONFIDENTIAL AEO 2 any agreements regarding writing a 3 book -- 4 A. No. 5 Q. -- about your experience? 6 You have to wait for me to 7 finish my question. 8 Have you had any agreements 9 with your lawyers about media rights 10 i n a n y f o r m ? 11 M R . G U I R G U I S : O b j e c t i o n t o 12 t h e e x t e n t t h a t y o u ' r e a s k i n g 13 a b o u t c o m m u n i c a t i o n s w i t h t h e 14 a t t o r n e y s . 15 M S . M E N N I N G E R : I ' m a s k i n g 16 a b o u t h e r a r r a n g e m e n t w i t h h e r 17 a t t o r n e y s , w h i c h i s n o t 18 p r i v i l e g e d . 19 A . C a n y o u p l e a s e r e p e a t t h e 20 q u e s t i o n . 21 Q . H a v e y o u r e a c h e d a n y 22 a g r e e m e n t w i t h y o u r a t t o r n e y s 23 r e g a r d i n g m e d i a r i g h t s f o r y o u r s t o r y ? 24 A . N o . 25 Q . H a v e y o u t a l k e d t o a n y o n e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 37 of 469 Highly Confidential Page 37 1 HIGHLY CONFIDENTIAL AEO 2 about publishing anything relating to 3 your story? 4 A. Can you repeat the question, 5 please. 6 MS. MENNINGER: Can you read 7 it back. 8 (Requested portion of the 9 record was read back.) 10 A . Y e s , I h a v e . 11 Q . W h o h a v e s p o k e n t o ? 12 A . T h e N e w Y o r k P o s t . 13 Q . W h o a t t h e N e w Y o r k P o s t ? 14 A . M a u r e e n C a l l a h a n . 15 Q . A n d w h e n d i d y o u s p e a k w i t h 16 h e r ? 17 A . I t h i n k i t w a s l a t e r 18 O c t o b e r . 19 Q . H a v e y o u s p o k e n w i t h h e r 20 s i n c e ? 21 A . N o . 22 Q . A n d h o w l o n g d i d y o u s p e a k 23 t o h e r ? 24 A . I s p o k e t o h e r f o r , g o s h , 25 a b o u t 3 0 m i n u t e s o n t h e p h o n e o n c e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 38 of 469 Highly Confidential Page 38 1 HIGHLY CONFIDENTIAL AEO 2 Q. And what was -- what did you 3 tell her in your phone call? 4 A. I told her what Jeffrey 5 Epstein and Ghislaine Maxwell did to 6 me and the other girls. 7 Q. Did she give you any money 8 in exchange for that interview? 9 A. No. 10 Q . D i d s h e p u b l i s h a n y t h i n g 11 r e l a t e d t o t h a t i n t e r v i e w ? 12 A . N o . 13 Q . H o w d i d y o u g e t i n t o u c h 14 w i t h M s . C a l l a h a n ? 15 A . I e m a i l e d a f t e r I r e a d a n 16 a r t i c l e t h a t s h e h a d w r i t t e n a b o u t 17 J e f f r e y E p s t e i n , a n d t h e l a s t s e n t e n c e 18 w a s - - i t w a s o n t h e 1 6 t h o f O c t o b e r , 19 a n d o n e o f t h e l a s t s e n t e n c e s I 20 r e m e m b e r w a s , w i l l w e e v e r k n o w t h e 21 t r u e e x t e n t o f J e f f r e y E p s t e i n ' s 22 v i c t i m s . A n d I w r o t e h e r a f t e r t h a t 23 b e c a u s e , w e l l , i t s t i l l c o n t i n u e s , 24 d o e s n ' t i t . 25 Q . W h e r e i s t h e e m a i l t h a t y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 39 of 469 Highly Confidential Page 39 1 HIGHLY CONFIDENTIAL AEO 2 wrote her? 3 A. It's on a -- it's on my 4 computer. 5 Q. Okay. In your Yahoo 6 account? 7 A. Yes. 8 Q. Did you have any agreement 9 with her to have any additional 10 c o n v e r s a t i o n ? 11 A . Y e s . 12 Q . A n d w h a t w a s t h a t a g r e e m e n t ? 13 A . I t w a s n ' t a n a g r e e m e n t p e r 14 s u c h . W h a t a c t u a l l y h a p p e n e d w a s I 15 c a m e f o r w a r d . A s s o o n a s I c a m e 16 f o r w a r d , t h e r e w a s - - w h e r e I l i v e i n 17 B a r c e l o n a , t h e r e ' s q u i t e a l o t - - i t ' s 18 q u i t e b u s y t r a f f i c w i t h p e o p l e . 19 I c a m e f o r w a r d t o M a u r e e n 20 C a l l a h a n . I w a n t e d t o t e l l m y s t o r y , 21 a n d I w a n t t o r u n a c a m p a i g n i n w h i c h 22 a l l t h e g i r l s t h a t h a v e b e e n a b u s e d b y 23 G h i s l a i n e a n d J e f f r e y c a n c o m e 24 f o r w a r d . A n d I w a n t e d t o r u n a 25 c a m p a i g n w i t h t h e N e w Y o r k P o s t t o g e t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 40 of 469 Highly Confidential Page 40 1 HIGHLY CONFIDENTIAL AEO 2 these girls to have the courage to 3 come forward, because I know a lot of 4 them are frightened like myself. 5 The email correspondence I 6 had with Maureen Callahan, she was 7 going away or something and she was 8 going to write a piece in the New York 9 Post about my story. During that time 10 i t w a s t h e e l e c t i o n s , s o t h e r e w a s a 11 l o t m o r e o t h e r t h i n g s g o i n g o n . 12 T h e r e w e r e t w o p e o p l e 13 f o l l o w i n g m e a f t e r I c a m e f o r w a r d t o 14 M a u r e e n C a l l a h a n . I w e n t t o - - I 15 w a l k e d d o w n s t a i r s . I w a l k e d a r o u n d - - 16 I h a v e a u s u a l r o u t i n e t h a t I d o . I n 17 t h e m o r n i n g I w e n t o u t , I s a w t h e s a m e 18 t w o p e o p l e . L a t e r o n t h a t a f t e r n o o n , 19 I s a w t h e s a m e t w o p e o p l e a g a i n . I 20 w a s f r i g h t e n e d . I ' m f r i g h t e n e d f o r m y 21 l i f e , a b s o l u t e l y f r i g h t e n e d . S o t h e r e 22 y o u g o . 23 S o t h a t ' s w h a t I w a s - - 24 c o m m u n i c a t i o n s t o p p e d b e t w e e n M a u r e e n 25 C a l l a h a n a n d I . I g o t r e a l l y a n g r y MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 41 of 469 Highly Confidential Page 41 1 HIGHLY CONFIDENTIAL AEO 2 with Maureen because she had obviously 3 told someone. Being the New York 4 Post, so, you know. 5 Q. So you had an email to 6 Ms. Callahan and an email back from 7 her? 8 A. Yes. 9 Q. More than one? 10 A . Y e s . 11 Q . H o w m a n y ? 12 A . I c a n ' t r e m e m b e r . 13 Q . M o r e t h a n t e n o r l e s s t h a n 14 t e n ? 15 A . L e s s t h a n t e n . 16 Q . A n d y o u h a d o n e p h o n e c a l l 17 w i t h h e r o r m o r e t h a n o n e ? 18 A . J u s t o n e . 19 Q . A n d i t l a s t e d a b o u t 3 0 20 m i n u t e s ? 21 A . A b o u t t h a t . 22 Q . A n d w a s t h a t a l s o o n t h e 23 c e l l p h o n e t h a t y o u g o t r i d o f ? 24 A . T h a t w a s o n m y p a r t n e r ' s 25 c e l l p h o n e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 42 of 469 Highly Confidential Page 42 1 HIGHLY CONFIDENTIAL AEO 2 Q. And what had you read in the 3 press that caused you to get in touch 4 with Ms. Callahan? 5 MS. MCCAWLEY: Objection to 6 form. Go ahead. 7 A. You can read the article 8 yourself. It's on the 16th of 9 October, there's an article in the New 10 Y o r k P o s t w r i t t e n b y M a u r e e n C a l l a h a n . 11 Y o u c a n r e a d i t . A n d t h a t ' s w h a t 12 i n s p i r e d m e t o c o m e f o r w a r d . 13 Q . W h a t d o y o u r e c a l l a b o u t 14 t h a t a r t i c l e ? 15 A . O h , I c a n ' t r e m e m b e r . T h e 16 o n e t h i n g I d o r e m e m b e r i s t h e l a s t 17 s e n t e n c e o f t h e a r t i c l e , w h i c h h a s 18 s t u c k w i t h m e a n d q u i t e p r o m i n e n t , a n d 19 t h a t i s , w i l l w e e v e r k n o w t h e t r u e 20 e x t e n t o f J e f f r e y E p s t e i n ' s v i c t i m s . 21 Q . D o y o u r e c a l l a n y t h i n g e l s e 22 a b o u t t h e a r t i c l e ? 23 A . I t ' s j u s t t h e s a m e . W h e n I 24 r e a d t h e a r t i c l e , t h e s t u f f t h a t I h a d 25 e x p e r i e n c e d m y s e l f w i t h J e f f r e y , i t ' s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 43 of 469 Highly Confidential Page 43 1 HIGHLY CONFIDENTIAL AEO 2 just same old stuff, just continuing. 3 I thought he had stopped abusing 4 girls. 5 Q. What do you recall reading a 6 article that Jeffrey Epstein was 7 doing? 8 A. I can't remember. 9 Q. Anything at all? 10 A . Y o u c a n r e a d t h e a r t i c l e . I 11 c a n ' t r e m e m b e r . 12 Q . T h e q u e s t i o n i s w h a t y o u 13 r e m e m b e r . 14 A . I c a n ' t r e m e m b e r . 15 Q . Y o u r e m e m b e r n o t h i n g e l s e 16 a b o u t t h e a r t i c l e - - 17 M S . M C C A W L E Y : A s k e d a n d 18 a n s w e r e d o b j e c t i o n . 19 Q . - - e x c e p t i t w a s r e l a t e d t o 20 J e f f r e y E p s t e i n a n d i t e n d e d w i t h t h e 21 s e n t e n c e t h a t y o u ' v e d e s c r i b e d ? 22 M S . M C C A W L E Y : O b j e c t i o n , 23 a s k e d a n d a n s w e r e d . 24 A . Y e s . 25 Q . W h a t d o y o u k n o w a b o u t o t h e r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 44 of 469 Highly Confidential Page 44 1 HIGHLY CONFIDENTIAL AEO 2 girls being frightened? 3 A. I know that the girls on the 4 island and in New York during my time 5 with Jeffrey and Ghislaine, that they 6 were frightened. 7 Q. Okay. What are the names of 8 those girls? 9 A. Natalya Malyshev. 10 - - I d o n ' t k n o w h e r s u r n a m e . I c a n ' t 11 r e m e m b e r h e r s u r n a m e . 12 Q . H o w d o y o u s p e l l t h e f i r s t 13 n a m e ? 14 A . - - I ' m j u s t t a k i n g a 15 g u e s s , , I ' m g u e s s i n g , I 16 t h i n k . 17 M R . G U I R G U I S : I ' m g o i n g t o 18 r e m i n d t h e w i t n e s s I t o l d h e r n o t 19 t o s p e c u l a t e , b u t t h a t ' s o k a y . 20 Q . I n a d d i t i o n t o N a t a l y a 21 M a l y s h e v a n d , w h a t a r e t h e 22 n a m e s o f t h e o t h e r g i r l s w h o y o u 23 b e l i e v e a r e f r i g h t e n e d ? 24 A . J e n n i f e r . T h e r e w e r e a 25 c o u p l e o t h e r g i r l s I m e t d u r i n g m y - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 45 of 469 Highly Confidential Page 45 1 HIGHLY CONFIDENTIAL AEO 2 time with Ghislaine and Jeffrey that 3 were frightened. 4 Q. What were the names of the 5 girls that you met that were 6 frightened? 7 A. There was Jennifer, , 8 Natalya Malyshev. And there were two 9 other girls, I can't remember their 10 n a m e s . 11 Q . O k a y . P l e a s e d e s c r i b e t h e m . 12 A . T h e - - d e s c r i b e a l l t h e 13 g i r l s o r - - 14 Q . N o . W e ' r e t a l k i n g a b o u t t h e 15 g i r l s t h a t y o u m e t o n t h e i s l a n d t h a t 16 y o u d e s c r i b e d a s f r i g h t e n e d . 17 A . O k a y . O n t h e i s l a n d - - 18 M R . G U I R G U I S : O b j e c t i o n . 19 Y o u s e e m t o b e s u g g e s t i n g t h a t 20 a l l t h o s e g i r l s a r e f r o m t h e 21 i s l a n d . I ' m n o t s u r e t h a t ' s t h e 22 t e s t i m o n y . 23 Q . A l l r i g h t . Y o u s a i d g i r l s 24 o n t h e i s l a n d a n d i n N e w Y o r k w h o a r e 25 f r i g h t e n e d . I a s k e d y o u f o r t h e i r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 46 of 469 Highly Confidential Page 46 1 HIGHLY CONFIDENTIAL AEO 2 names. 3 You gave me three, correct? 4 A. Yes. 5 Q. You said there were two 6 others, correct? 7 A. Mm-hmm. 8 Q. What did those two other 9 girls look like? 10 A . I c a n ' t r e a l l y r e m e m b e r . 11 O n e h a d b l o n d e h a i r ; l o n g , b l o n d e 12 h a i r . 13 Q . A n y t h i n g e l s e a b o u t t h a t ? 14 A . I c a n ' t r e m e m b e r . 15 Q . T h e o t h e r g i r l , c a n y o u 16 r e m e m b e r h e r h a i r c o l o r ? 17 A . N o , I c a n ' t r e m e m b e r . 18 Q . D o y o u k n o w t h e h e i g h t o f 19 e i t h e r o n e o f t h e m ? 20 A . N o , I c a n ' t r e m e m b e r . 21 Q . D o y o u h a v e a p h o t o g r a p h o f 22 e i t h e r o n e o f t h e m ? 23 A . N o . 24 Q . A n d w h e r e d i d y o u m e e t t h e s e 25 t w o o t h e r g i r l s ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 47 of 469 Highly Confidential Page 47 1 HIGHLY CONFIDENTIAL AEO 2 A. In New York. 3 Q. Where in New York? 4 A. I can't remember. 5 Q. You don't know the location 6 at all? 7 A. No. It was ten years ago. 8 Q. Was it in a home or in a 9 commercial setting? 10 A . I m e t g i r l s c o m m e r c i a l l y a n d 11 i n h o m e s e t t i n g s . 12 Q . W h e r e d i d y o u m e e t t h e s e t w o 13 o t h e r g i r l s y o u d e s c r i b e d a s b e i n g 14 f r i g h t e n e d ? 15 A . I c a n ' t r e m e m b e r . 16 Q . W h a t i s J e n n i f e r ' s l a s t 17 n a m e ? 18 A . I d o n ' t k n o w . 19 Q . W h a t d o e s J e n n i f e r l o o k 20 l i k e ? 21 A . S h e ' s g o t l o n g , b l o n d e h a i r . 22 Q . H o w l o n g ? 23 A . L o n g , l o n g h a i r . 24 Q . L o n g e r t h a n y o u r h a i r n o w ? 25 A . I t h i n k s o . I t h i n k i t w a s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 48 of 469 Highly Confidential Page 48 1 HIGHLY CONFIDENTIAL AEO 2 longer. 3 Q. So middle of her back? 4 A. I can't -- I can't remember 5 on how long her hair is. 6 Q. Where did you meet Jennifer? 7 A. I met Jennifer first in New 8 York. 9 Q. Where in New York? 10 A . I c a n ' t r e m e m b e r . 11 Q . A n y w h e r e i n N e w Y o r k ? Y o u 12 c a n ' t r e m e m b e r a t a l l ? 13 A . I c a n ' t r e m e m b e r t h e 14 l o c a t i o n . 15 Q . W a s i t a t M r . E p s t e i n ' s 16 h o m e ? 17 M R . G U I R G U I S : O b j e c t i o n . 18 Y o u h a v e a s k e d h e r n o w a l m o s t 2 0 19 q u e s t i o n s a b o u t w h e r e s h e m e t 20 t h e s e g i r l s , a n d s h e h a s 21 c o n s i s t e n t l y s a i d t h a t s h e d o e s 22 n o t r e m e m b e r . 23 Q . W a s i t i n M r . E p s t e i n ' s 24 h o m e ? 25 A . N o . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 49 of 469 Highly Confidential Page 49 1 HIGHLY CONFIDENTIAL AEO 2 Q. Was it at a club? 3 MR. GUIRGUIS: Are we going 4 to spend seven hours with her 5 saying I can't remember where she 6 met these two girls? 7 Q. Was it at a club? 8 A. One was at a club. 9 Q. Which one? 10 A . N a t a l y a M a l y s h e v . 11 Q . W h e r e d i d y o u m e e t ? 12 A . I f i r s t m e t o n t h e 13 i s l a n d . 14 Q . D i d y o u m e e t h e r a s e c o n d 15 t i m e ? 16 A . Y e s . 17 Q . W h e r e d i d y o u m e e t h e r t h e 18 s e c o n d t i m e ? 19 A . I c a n ' t r e m e m b e r . 20 Q . S t a t e ? 21 A . C a n ' t r e m e m b e r . 22 Q . C o u n t r y ? 23 A . W e l l , U . S . 24 T H E W I T N E S S : S o r r y , c a n I 25 h a v e a b r e a k ? I a c t u a l l y n e e d t o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 50 of 469 Highly Confidential Page 50 1 HIGHLY CONFIDENTIAL AEO 2 go to the bathroom. Sorry. 3 MS. MENNINGER: Yes, I don't 4 think I have a question pending. 5 We'll go off the record now. 6 (Time noted: 9:52 a.m.) 7 (Recess.) 8 (Time noted: 10:07 a.m.) 9 Q. So I want to return to your 10 c o n v e r s a t i o n s w i t h M s . C a l l a h a n , 11 c o n v e r s a t i o n w i t h M s . C a l l a h a n . 12 D i d y o u h a v e a n y f u r t h e r 13 c o m m u n i c a t i o n s w i t h h e r a f t e r t h e 14 p h o n e c a l l y o u d e s c r i b e d ? 15 A . T h e r e w e r e , I t h i n k , a f e w 16 e m a i l s e x c h a n g e d , b u t n o t h i n g e v e r 17 c a m e a b o u t i t . 18 Q . A n d , a g a i n , t h o s e a r e e m a i l s 19 f r o m y o u r Y a h o o a c c o u n t ? 20 A . Y e s . 21 Q . D i d y o u a s k M s . C a l l a h a n f o r 22 c o m p e n s a t i o n i n e x c h a n g e f o r y o u r 23 s t o r y ? 24 M S . M C C A W L E Y : O b j e c t i o n , 25 a s k e d a n d a n s w e r e d . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 51 of 469 Highly Confidential Page 51 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Had you seen any other 4 stories in the press about Jeffrey 5 Epstein? 6 A. Through the last ten years, 7 I've seen a few articles written about 8 Jeffrey Epstein. 9 Q. What do you recall about 10 t h o s e a r t i c l e s ? 11 A . T h e w a y h e u s e d t o a b u s e 12 g i r l s . B a s i c a l l y a r t i c l e s w r i t t e n 13 v e r y s i m i l a r t o m y o w n s t o r y - - w e l l , 14 i d e n t i c a l , s o . . . 15 Q . A n d h a v e y o u w r i t t e n d o w n 16 y o u r s t o r y ? 17 A . N o . 18 Q . N o w h e r e ? 19 A . N o . 20 Q . D i d y o u s e e a n y a r t i c l e s 21 a b o u t V i r g i n i a R o b e r t s ? 22 A . Y e s . 23 Q . W h i c h a r t i c l e s d i d y o u s e e 24 a b o u t V i r g i n i a R o b e r t s ? 25 A . I c a n ' t r e m e m b e r . I t w a s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 52 of 469 Highly Confidential Page 52 1 HIGHLY CONFIDENTIAL AEO 2 quite some time ago. 3 Q. What do you recall about it? 4 A. She came forward and I 5 was -- it was a few years ago that she 6 came forward, and her story was 7 exactly the same as mine. 8 I can't remember 9 specifically what article I read, but 10 e v e r y s i n g l e a r t i c l e I d i d r e a d d u r i n g 11 t h e d u r a t i o n o f t h a t t i m e , s h e 12 e x p e r i e n c e d t h e s a m e t h i n g I d i d . 13 S o i t w a s m o r e o r l e s s t h e 14 s a m e c o n t e x t a n d i t ' s t h e s a m e s t o r y 15 i n a l l a r t i c l e s , r e a l l y . 16 Q . S o y o u w e r e r e a d i n g t h e s e 17 a r t i c l e s o v e r t h e c o u r s e o f a p e r i o d 18 o f t e n y e a r s , y o u t h i n k ? 19 A . Y e a h . I d i d n ' t p a y m u c h 20 a t t e n t i o n t o i t b e c a u s e I ' v e s p e n t t h e 21 l a s t t e n y e a r s t r y i n g t o g e t o v e r t h a t 22 e x p e r i e n c e , a n d I ' v e b e e n f r i g h t e n e d 23 t o c o m e f o r w a r d . 24 Q . A n d w h e n y o u r e a d t h e 25 a r t i c l e s , y o u n o t i c e d t h a t t h e r e w e r e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 53 of 469 Highly Confidential Page 53 1 HIGHLY CONFIDENTIAL AEO 2 details that you thought were similar 3 to your experience? 4 MS. MCCAWLEY: Objection. 5 A. They were details that were 6 exactly the same as what I had 7 experienced. 8 Q. Do you know whether anyone 9 else had brought lawsuits against 10 M r . E p s t e i n ? 11 A . N o . 12 Q . D i d y o u s a v e a n y o f t h e s e 13 a r t i c l e s t h a t y o u r e a d ? 14 A . S o r r y , c a n y o u r e p e a t t h a t . 15 Q . D i d y o u s a v e a n y o f t h e 16 a r t i c l e s t h a t y o u r e a d ? 17 A . N o . 18 Q . W h e r e d i d y o u g r o w u p ? 19 A . I g r e w u p i n S o u t h A f r i c a . 20 I t h e n f i n i s h e d s c h o o l i n S c o t l a n d . 21 Q . W h e n d i d y o u m o v e t o 22 S c o t l a n d ? H o w o l d w e r e y o u ? 23 A . I w a s 1 4 . 24 Q . D i d y o u r f a m i l y m o v e t o 25 S c o t l a n d o r j u s t y o u ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 54 of 469 Highly Confidential Page 54 1 HIGHLY CONFIDENTIAL AEO 2 A. Just myself. 3 Q. Are you a South African 4 citizen? 5 A. Yes. 6 Q. Do you have a South African 7 passport? 8 A. Well, yeah. It was stolen. 9 I'm reapplying for a new one. I have 10 t o r e n e w m y S o u t h A f r i c a n p a s s p o r t . 11 I t w a s s t o l e n . S o u t h A f r i c a f o r y o u . 12 Q . S o w h e n d i d y o u g e t t h a t 13 S o u t h A f r i c a n p a s s p o r t ? 14 A . I c a n ' t r e m e m b e r . I ' v e h a d 15 a S o u t h A f r i c a n p a s s p o r t m y w h o l e 16 l i f e , s o . . . 17 Q . A n d w h e n w a s i t s t o l e n ? 18 A . I t h i n k i t w a s 2 0 1 4 , 2 0 1 5 . 19 Q . S o y o u w e r e b o r n i n S o u t h 20 A f r i c a , y o u ' r e a S o u t h A f r i c a n 21 c i t i z e n , a n d y o u h a d a S o u t h A f r i c a n 22 p a s s p o r t y o u r w h o l e l i f e . 23 H a v e I g o t t h a t r i g h t ? 24 A . M m - h m m . 25 Q . Y e s o r n o ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 55 of 469 Highly Confidential Page 55 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection to 3 form. 4 You can answer. 5 A. Yes. 6 Q. Did you also have a British 7 passport? 8 A. Yes. 9 Q. How did that come about? 10 A . M y m o m ' s s i d e o f t h e f a m i l y 11 i s B r i t i s h . 12 Q . A n d w h e n d i d y o u g e t a 13 B r i t i s h p a s s p o r t ? 14 A . I t h i n k w h e n I w a s a b o u t 15 f i v e . 16 Q . D o y o u h a v e a d u a l 17 c i t i z e n s h i p ? 18 A . Y e s . 19 Q . A n d d o y o u t r a v e l u s i n g b o t h 20 p a s s p o r t s ? 21 A . I t ' s r e a l l y c o m p l i c a t e d . I 22 o n l y u s e m y S o u t h A f r i c a n p a s s p o r t 23 w h e n I e n t e r i n t o S o u t h A f r i c a . S o 24 t h a t ' s t h e o n l y t i m e I u s e m y S o u t h 25 A f r i c a n p a s s p o r t , t h e n . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 56 of 469 Highly Confidential Page 56 1 HIGHLY CONFIDENTIAL AEO 2 Other than that, I use my 3 British passport for all other 4 transportation. Because South Africa 5 you need, like, a visa; it's really 6 complicated. So I'm lucky I've got a 7 British passport. 8 Q. It's easier to travel on a 9 British passport than a South African 10 p a s s p o r t ? 11 A . Y e a h , a l o t e a s i e r . A l o t 12 e a s i e r . 13 Q . A l l r i g h t . D i d y o u h a v e a n y 14 s i b l i n g s g r o w i n g u p ? 15 A . Y e s . 16 Q . H o w m a n y ? 17 A . I ' v e g o t o n e r e a l o l d e r 18 b r o t h e r a n d t h e n I ' v e g o t a h a l f 19 y o u n g e r b r o t h e r a n d a h a l f y o u n g e r 20 s i s t e r . 21 Q . D i d y o u a l l g r o w u p i n t h e 22 s a m e h o m e ? 23 A . N o . 24 Q . W h o d i d y o u g r o w u p i n t h e 25 s a m e h o m e w i t h ? I d o n ' t n e e d t h e i r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 57 of 469 Highly Confidential Page 57 1 HIGHLY CONFIDENTIAL AEO 2 names, but just the people you just 3 described. 4 MR. GUIRGUIS: Objection. 5 You can answer. 6 A. I grew up with my mom and my 7 stepdad, and my brother was just 8 entering boarding school. 9 And then I lived with my 10 a u n t i e a n d u n c l e i n S c o t l a n d . 11 Q . A n d c o u s i n s ? 12 A . Y e a h , a n d c o u s i n s . O n e 13 c o u s i n . 14 Q . A n d h o w l o n g d i d y o u a t t e n d 15 s c h o o l i n S c o t l a n d ? 16 A . A b o u t t h r e e y e a r s . 17 Q . D i d y o u g r a d u a t e ? 18 A . Y e p , y e s . 19 Q . I s t h a t t h e e q u i v a l e n t o f 20 o u r h i g h s c h o o l ? 21 A . Y e a h , i t i s . 22 Q . D i d y o u g o t o c o l l e g e ? 23 A . I w e n t t o u n i v e r s i t y t o 24 s t u d y p s y c h o l o g y a n d s o c i o l o g y . 25 Q . W h e r e d i d y o u g o ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 58 of 469 Highly Confidential Page 58 1 HIGHLY CONFIDENTIAL AEO 2 A. Queen Margaret University in 3 Edinburgh. 4 Q. Did you graduate? 5 A. No, I didn't. 6 Q. Did you go to that college 7 immediately after graduating from high 8 school? 9 A. No. 10 Q . W h e n d i d y o u g o t o t h a t 11 c o l l e g e ? 12 A . 2 0 0 4 . 13 Q . A n d h o w l o n g d i d y o u s t a y a t 14 Q u e e n M a r g a r e t c o l l e g e ? 15 A . A y e a r a n d a h a l f . 16 Q . W h y d i d y o u l e a v e c o l l e g e ? 17 A . I c h o s e t h e w r o n g c o u r s e . I 18 d i d n ' t - - I d i d n ' t r e a l l y a g r e e w i t h 19 w h a t I w a s b e i n g t a u g h t i n s o c i o l o g y , 20 s o I q u i t . 21 Q . D u r i n g t h e t i m e y o u w e r e i n 22 c o l l e g e , d i d y o u w o r k ? 23 A . Y e s . 24 Q . W h e r e d i d y o u w o r k ? 25 A . I w a s a w a i t r e s s a t a b a r . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 59 of 469 Highly Confidential Page 59 1 HIGHLY CONFIDENTIAL AEO 2 Q. Anything else? 3 A. No. 4 Q. Have you ever been married? 5 A. No. 6 Q. Have you ever been engaged? 7 A. Yes. 8 Q. To whom? 9 A. Peter Coulthard. 10 Q . Y o u r c u r r e n t p a r t n e r ? 11 A . Y e s . 12 Q . A n y o n e e l s e ? 13 A . Y e s , I h a v e . 14 Q . W h o e l s e h a v e y o u b e e n 15 e n g a g e d t o ? 16 M S . M C C A W L E Y : O b j e c t i o n . 17 M R . G U I R G U I S : O b j e c t i o n . 18 A . I d o n ' t r e a l l y s e e t h e 19 r e l e v a n c e i n t h a t . 20 Q . W h o e l s e h a v e y o u b e e n 21 e n g a g e d t o ? 22 A . A n d r e w R a l p h . 23 Q . W a s h e l i s t e d i n y o u r 24 p a s s p o r t ? 25 A . Y e s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 60 of 469 Highly Confidential Page 60 1 HIGHLY CONFIDENTIAL AEO 2 Q. Anyone else? 3 A. Listed on my passport? 4 Sorry. 5 Q. Have you been engaged to 6 anyone else? 7 A. Oh, sorry. I've got a 8 really bad train... No. 9 Q. During what period of time 10 w e r e y o u e n g a g e d t o A n d r e w R o l p h ? 11 A . I c a n ' t r e m e m b e r . 12 Q . W a s i t b e f o r e 2 0 0 6 o r a f t e r ? 13 A . A f t e r . 14 Q . H o w l o n g a f t e r ? 15 A . T h r e e y e a r s . 16 Q . D i d y o u k n o w M r . R o l p h 17 d u r i n g 2 0 0 6 ? 18 A . I t ' s R a l p h , s o r r y . 19 R - A - L - P - H . 20 V a g u e l y , v a g u e l y . W e l o s t 21 c o n t a c t . 22 Q . W h e n d i d y o u l o s e c o n t a c t ? 23 A . I n 2 0 0 6 . 24 Q . A n d w h e n d i d y o u r e e s t a b l i s h 25 c o n t a c t ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 61 of 469 Highly Confidential Page 61 1 HIGHLY CONFIDENTIAL AEO 2 A. 2008. 3 Q. Do you go by any other 4 names? 5 A. No. 6 Q. Do you go by SarahEmmaAshley 7 online? 8 A. I don't think so. I don't 9 know. 10 Q . O n T w i t t e r ? 11 A . I d o n ' t h a v e a n y s o c i a l 12 m e d i a p l a t f o r m s , s o I c a n ' t r e m e m b e r . 13 Q . H a v e y o u e v e r g o n e b y 14 S a r a h E m m a A s h l e y , a l l o n e w o r d , o n 15 T w i t t e r ? 16 A . I c a n ' t r e m e m b e r . 17 Q . D o y o u h a v e a n y t a t t o o s ? 18 A . Y e s . 19 Q . W h e r e ? 20 A . O n e h e r e . 21 Q . I n d i c a t i n g o n y o u r a r m ? 22 A . I n d i c a t i n g o n m y a r m , s o r r y . 23 N o c a m e r a . 24 Y e s , I h a v e o n e , t w o , t h r e e 25 f o u r . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 62 of 469 Highly Confidential Page 62 1 HIGHLY CONFIDENTIAL AEO 2 Q. Where is the second one? 3 A. I've got four. 4 Q. All right. Just tell me 5 where they are. 6 A. One is on my arm, one is on 7 my right hip, one's on my upper bikini 8 line on my right inner thigh, and I've 9 got one on my left side on my rib 10 c a g e . 11 Q . O k a y . H a v e y o u h a d t h e m f o r 12 a l o n g t i m e ? 13 A . I ' v e h a d - - h a n g o n . T w o I 14 h a v e h a d f o r a l o n g t i m e . 15 Q . W h i c h o n e s a r e t h e y ? 16 A . T h e s c o r p i o n o n m y r i g h t h i p 17 a n d m y L e o s y m b o l o n m y b i k i n i l i n e . 18 Q . H a v e y o u e v e r o b t a i n e d a 19 c o l l e g e d e g r e e ? 20 A . N o . 21 Q . H a v e y o u e v e r g o n e b a c k t o 22 c o l l e g e ? 23 A . I h a v e t r i e d t o . I w a n t e d 24 t o . 25 Q . W h e n d i d y o u d o t h a t ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 63 of 469 Highly Confidential Page 63 1 HIGHLY CONFIDENTIAL AEO 2 A. When I moved to New York. 3 Q. In 2006? 4 A. Correct. 5 Q. Any other time? 6 A. Well, recent. I mean, I'm 7 going back to university next year, so 8 I'm currently relooking at colleges. 9 I'm going back to do my psychology 10 d e g r e e . 11 Q . W h e r e ? 12 A . I h a v e n ' t d e c i d e d y e t 13 b e c a u s e I ' m l o o k i n g f o r a n o p e n d e g r e e 14 - - w e l l , s o r r y , h o m e l e a r n i n g , s o I 15 h a v e n ' t f o u n d s o m e w h e r e y e t . B u t I ' m 16 c u r r e n t l y g o i n g - - w e l l , m y a i m i s t o 17 g o b a c k t o u n i v e r s i t y a n d g e t 18 q u a l i f i e d . 19 Q . B e t w e e n 2 0 0 6 a n d t o d a y , h a v e 20 y o u a p p l i e d t o a n y o t h e r c o l l e g e s ? 21 A . N o . 22 O h , y e s . S o r r y , c a n y o u 23 r e p e a t t h e q u e s t i o n ? S o r r y . 24 M S . M E N N I N G E R : H e c a n r e a d 25 i t b a c k . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 64 of 469 Highly Confidential Page 64 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. Yes. 3 Q. Okay. When did you apply to 4 colleges between 2006 and today? 5 A. It was 2006. 6 Q. Is that FIT? 7 A. That's correct. 8 Q. Anywhere else? 9 A. No. 10 Q . O t h e r t h a n w o r k i n g a s a 11 w a i t r e s s a t a b a r d u r i n g c o l l e g e i n 12 2 0 0 4 - 2 0 0 5 , w h a t o t h e r e m p l o y m e n t h a v e 13 y o u h a d ? 14 A . I h a v e w o r k e d i n 15 h o s p i t a l i t y . I ' v e w o r k e d i n 16 s u p e r y a c h t i n g , t h o s e w e a l t h y p e o p l e 17 t h a t h a v e s u p e r y a c h t s . I u s e d t o w o r k 18 f o r t h e m . I h a v e d o n e m o d e l i n g . A n d 19 I c a n ' t r e m e m b e r a n y . . . 20 Q . D i d y o u h a v e a m o d e l i n g 21 a g e n t ? 22 A . I d i d i n S c o t l a n d . 23 Q . I n c o l l e g e ? 24 A . M m - h m m , t h a t ' s c o r r e c t . 25 Q . A n y o t h e r t i m e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 65 of 469 Highly Confidential Page 65 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. And what type of modeling 4 was that? 5 A. Just commercial. 6 Q. Print? 7 A. Yep. 8 Q. Runway? 9 A. Yep. 10 Q . T V o r a d s ? 11 A . N o . 12 Q . A n d a l l i n S c o t l a n d ? 13 A . N o . 14 Q . W h e r e e l s e d i d y o u m o d e l ? 15 A . N e w Y o r k . 16 Q . A n y w h e r e e l s e ? 17 A . N o . 18 Q . L o n d o n ? 19 A . O h , y e a h , I d i d , s o r r y . I 20 d i d d o m o d e l i n g , a b i t o f m o d e l i n g i n 21 L o n d o n . 22 Q . A l l r i g h t . W h e n d i d y o u d o 23 m o d e l i n g i n N e w Y o r k ? 24 A . D u r i n g - - w h e n I f i r s t 25 a r r i v e d i n N e w Y o r k i n 2 0 0 6 . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 66 of 469 Highly Confidential Page 66 1 HIGHLY CONFIDENTIAL AEO 2 Q. How much money did you make 3 as a model? 4 MR. GUIRGUIS: Objection. 5 A. I can't remember. 6 Q. When did you work in 7 superyachting? 8 A. I can't remember. About 9 2011. About 2011. 10 Q . A n d w h e n d i d y o u w o r k i n 11 h o s p i t a l i t y ? 12 A . I ' v e w o r k e d i n h o s p i t a l i t y 13 m y w h o l e l i f e . I ' v e w o r k e d i n - - I 14 m e a n , h o s p i t a l i t y , I ' v e e i t h e r d o n e 15 b a r w o r k , w a i t r e s s i n g , s u p e r y a c h t i n g , 16 y e a h . 17 Q . S o o n a n d o f f ? 18 A . Y e a h , o n a n d o f f . 19 Q . A n d s i n c e y o u w e r e a n a d u l t ? 20 A . A n d s i n c e I w a s a n a d u l t , I 21 w o r k e d i n c o r p o r a t e j o b s a s w e l l . 22 Q . W h e r e d i d y o u w o r k i n 23 c o r p o r a t e j o b s ? 24 A . I n S o u t h A f r i c a . 25 Q . A n d j u s t s o I u n d e r s t a n d , MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 67 of 469 Highly Confidential Page 67 1 HIGHLY CONFIDENTIAL AEO 2 you lived in Scotland from the ages of 3 14 to 22? 4 A. That's correct. 5 Q. And then where did you move? 6 A. To New York. 7 Q. And how long did you live in 8 New York? 9 A. About seven, eight months. 10 Q . A n d w h e r e d i d y o u m o v e ? 11 A . B a c k i n L o n d o n . 12 Q . A n d h o w l o n g d i d y o u l i v e i n 13 L o n d o n ? 14 A . W e l l , I l i v e d i n t h e U K . 15 B e c a u s e I m o v e d a r o u n d a f e w t i m e s , s o 16 I d i d n ' t j u s t s p e c i f i c a l l y l i v e i n 17 L o n d o n . B u t I w a s i n t h e U K a b o u t 18 2 0 1 2 . 19 Q . A n d t h e n w h e r e d i d y o u m o v e ? 20 A . I t h e n w e n t i n t o t h e 21 s u p e r y a c h t i n g i n d u s t r y , s o I d i d n ' t - - 22 I l i v e d o n a b o a t i n I t a l y a n d s o u t h 23 o f F r a n c e . 24 Q . D i d y o u w o r k f o r a c o m p a n y ? 25 A . I w o r k e d f o r a p r i v a t e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 68 of 469 Highly Confidential Page 68 1 HIGHLY CONFIDENTIAL AEO 2 owner. 3 Q. On one yacht? 4 A. On multiple yachts. 5 Q. And what was your job? 6 A. Stewardess -- stewardess, 7 and then I was a deckhand. 8 Q. With wine? 9 A. Sorry? 10 Q . W h a t ' s a d e c a n t ? 11 A . A d e c k h a n d . 12 M S . M C C A W L E Y : D - E - C - K . 13 T H E W I T N E S S : S o r r y . 14 M S . M E N N I N G E R : O h , 15 d e c k h a n d . I t h o u g h t y o u w e r e 16 d e c a n t i n g w i n e . I t ' s a p r e t t y 17 g o o d j o b . 18 Q . W h o i s t h e o w n e r o f t h e 19 s h i p ? 20 A . I ' m n o t a l l o w e d t o s p e c i f y . 21 Q . D o y o u h a v e a 22 c o n f i d e n t i a l i t y a g r e e m e n t ? 23 A . I d i d s i g n a c o n f i d e n t i a l i t y 24 a g r e e m e n t w h e n I s t a r t e d e m p l o y m e n t . 25 Q . A n d h o w l o n g w e r e y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 69 of 469 Highly Confidential Page 69 1 HIGHLY CONFIDENTIAL AEO 2 employed in superyachting? 3 A. Two and a half years. 4 Q. Okay. And what did you do 5 after that? 6 A. I moved back to Cape Town. 7 Q. So that was in 2014? 8 A. I can't remember the 9 specific dates or year. 10 Q . B e t w e e n 2 0 1 4 a n d 2 0 1 6 ? 11 A . I ' v e m o v e d 4 7 t i m e s , s o I 12 c a n ' t r e m e m b e r . 13 Q . Y o u c a n ' t r e m e m b e r w h a t y e a r 14 y o u m o v e d b a c k t o C a p e T o w n ? 15 A . N o . 16 Q . O k a y . A n d w h o d i d y o u l i v e 17 w i t h w h e n y o u m o v e d b a c k t o C a p e T o w n ? 18 A . M y s e l f . 19 Q . A n d h o w l o n g d i d y o u l i v e 20 t h e r e ? 21 A . F o u r y e a r s . 22 Q . A n d y o u , w h e n d i d y o u m o v e 23 a f t e r t h a t ? 24 A . D e c e m b e r . Y e a h , i t w a s 25 D e c e m b e r 2 0 1 5 . S o r r y . I t w a s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 70 of 469 Highly Confidential Page 70 1 HIGHLY CONFIDENTIAL AEO 2 December 2015. 3 Q. Where did you move? 4 A. I moved from Cape Town to 5 London. 6 Q. And how long did you live 7 there? 8 A. Three months. 9 Q. And then where did you move? 10 A . B a r c e l o n a . 11 Q . S o i n M a r c h 2 0 1 6 ? 12 A . S o r r y , n o , j u s t h a n g o n . 13 S o r r y . I m o v e d t o B a r c e l o n a a r o u n d 14 J u n e , J u n e l a s t y e a r . 15 Q . 2 0 1 6 J u n e ? 16 A . Y e a h . 17 Q . Y o u m o v e d t o B a r c e l o n a ? 18 A . Y e a h . 19 Q . W h e n y o u c a m e t o t h e U . S . , 20 y o u s a i d t h a t w a s i n 2 0 0 6 ? 21 A . C o r r e c t . 22 Q . A n d w h o d i d y o u c o m e w i t h ? 23 A . M y s e l f . 24 Q . A n d w h o p a i d f o r y o u r p l a n e 25 t i c k e t ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 71 of 469 Highly Confidential Page 71 1 HIGHLY CONFIDENTIAL AEO 2 A. Myself. 3 Q. Why did you come? 4 A. I wanted to advance my 5 career. 6 Q. What year? 7 A. I wanted to go to FIT 8 university. 9 Q. Did you have a student visa 10 w h e n y o u c a m e i n 2 0 0 6 ? 11 A . N o . 12 Q . H a d y o u a p p l i e d t o F I T w h e n 13 y o u c a m e t o N e w Y o r k i n 2 0 0 6 ? 14 A . N o . 15 Q . D i d y o u h a v e a j o b w h e n y o u 16 c a m e h e r e i n 2 0 0 6 ? 17 A . N o . 18 Q . W h e r e d i d y o u s t a y w h e n y o u 19 g o t h e r e i n 2 0 0 6 ? 20 A . T h e U p p e r E a s t S i d e . 21 Q . W i t h w h o m ? 22 A . I t w a s j u s t a h o u s e m a t e , 23 h o u s e . 24 Q . W h a t w a s t h a t p e r s o n ' s n a m e ? 25 A . C h r i s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 72 of 469 Highly Confidential Page 72 1 HIGHLY CONFIDENTIAL AEO 2 Q. How do you spell Chris? 3 A. C-H-R-I-S. 4 Q. And what's the last name of 5 Chris? 6 A. I can't remember. 7 Q. Male or female? 8 A. Male. 9 Q. How old? 10 A . I t h i n k h e w a s i n h i s 4 0 s . 11 Q . A n d h o w d i d y o u m e e t C h r i s ? 12 A . I m e t C h r i s j u s t v i a - - I 13 m e t h i m w h e n - - w h y c a n ' t I r e m e m b e r ? 14 I t h i n k , y e a h , I w a s l o o k i n g f o r a n 15 a p a r t m e n t w h e n I g o t h e r e s o i t w a s 16 j u s t a - - l i k e , w e j u s t k i n d o f m e t o n 17 t h e U p p e r E a s t S i d e a n d , y e a h , I s a i d 18 I w a s l o o k i n g f o r s o m e w h e r e t o s t a y . 19 Q . D i d y o u p a y r e n t ? 20 A . Y e s . 21 Q . H o w m u c h d i d y o u p a y ? 22 A . I c a n ' t r e m e m b e r . 23 Q . A t h o u s a n d d o l l a r s ? 24 M R . G U I R G U I S : O b j e c t i o n . 25 A . I t h i n k i t w a s l e s s t h a n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 73 of 469 Highly Confidential Page 73 1 HIGHLY CONFIDENTIAL AEO 2 that. 3 Q. Did you have your own 4 bedroom? 5 A. No. 6 Q. Was Chris the only other 7 occupant? 8 A. There was another guy. 9 Q. Did you share a bed with 10 a n y o n e a t t h a t h o u s e ? 11 A . W i t h C h r i s . 12 Q . W e r e y o u i n a r e l a t i o n s h i p 13 w i t h C h r i s ? 14 A . N o . 15 Q . Y o u s l e p t i n a b e d w i t h 16 C h r i s i n t h e a p a r t m e n t o n t h e U p p e r 17 E a s t S i d e ? 18 A . T h a t ' s c o r r e c t . 19 Q . W h a t w a s t h e a d d r e s s o f t h a t 20 a p a r t m e n t ? 21 A . I c a n ' t r e m e m b e r . 22 Q . D o y o u h a v e a n y w a y o f 23 r e a c h i n g C h r i s n o w ? 24 A . N o , n o , I d o n ' t . 25 Q . D o y o u k n o w a p p r o x i m a t e l y MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 74 of 469 Highly Confidential Page 74 1 HIGHLY CONFIDENTIAL AEO 2 where in New York it was besides the 3 Upper East Side? 4 A. I just remember it being in 5 the Upper East Side. I can't remember 6 the exact location. 7 Q. Any of the cross-streets? 8 A. I went there the other day, 9 and it looks -- it looks familiar. I 10 c a n ' t - - I c a n ' t r e m e m b e r 11 s p e c i f i c a l l y . 12 Q . Y o u w e n t t o t h e a p a r t m e n t 13 t h e o t h e r d a y ? 14 A . N o , I d i d n ' t g o t o t h e 15 a p a r t m e n t t h e o t h e r d a y . I w e n t t o 16 t h e U p p e r E a s t S i d e y e s t e r d a y - - t h e 17 o t h e r d a y , s o r r y . B u t I c a n ' t 18 r e m e m b e r w h e r e t h e a p a r t m e n t w a s , n o . 19 Q . W a s i t a w a l k u p o r a d o o r m a n 20 o r e l e v a t o r k i n d o f b u i l d i n g ? 21 A . I t w a s a n e l e v a t o r b u i l d i n g . 22 Q . W a s t h e r e a d o o r m a n ? 23 A . N o . 24 Q . W h a t f l o o r w e r e y o u o n ? 25 A . I c a n ' t r e m e m b e r . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 75 of 469 Highly Confidential Page 75 1 HIGHLY CONFIDENTIAL AEO 2 Q. And you don't remember how 3 you met Chris? 4 MR. GUIRGUIS: Objection. 5 A. I met loads of people during 6 that time. I can't specifically 7 remember how I met every individual. 8 Q. And in the same house, there 9 was Chris and another guy? 10 A . T h a t ' s c o r r e c t . 11 M S . M C C A W L E Y : O b j e c t i o n , 12 m i s s t a t e s - - 13 Q . D o y o u r e m e m b e r t h e o t h e r 14 g u y ' s n a m e ? 15 A . I c a n ' t r e m e m b e r . 16 Q . H o w l o n g d i d y o u l i v e w i t h 17 C h r i s a n d t h e o t h e r g u y ? 18 A . F o r a - - I t h i n k i t w a s a 19 c o u p l e m o n t h s u n t i l I m o v e d . 20 Q . A n d w h e r e d i d y o u m o v e ? 21 A . T o J e f f r e y E p s t e i n ' s 22 a p a r t m e n t . 23 Q . W h a t w a s t h e a d d r e s s t o 24 t h a t ? 25 A . I t h i n k i t w a s 2 0 0 0 - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 76 of 469 Highly Confidential Page 76 1 HIGHLY CONFIDENTIAL AEO 2 sorry -- 205 East. It was Midtown 3 somewhere. 4 Q. I'm sorry, what? 5 A. It was sort of Midtown. I'm 6 not familiar with New York because I 7 haven't been here and I don't live 8 here. It was kind of Midtown, his 9 apartment. 10 Q . O k a y . 11 A . I f I r e c a l l , y e a h . 12 Q . S o i t ' s 2 0 5 E a s t s o m e t h i n g ? 13 A . I t ' s E a s t - - i t ' s E a s t 14 s o m e t h i n g . I t w a s t h e s a m e - - i t w a s 15 t h e s a m e a p a r t m e n t b u i l d i n g t h a t N a d i a 16 l i v e d i n , b e c a u s e w e l i v e d i n t h e s a m e 17 b u i l d i n g . 18 Q . D i d y o u l i v e i n t h e s a m e 19 a p a r t m e n t ? 20 A . N o . 21 Q . D i d y o u h a v e y o u r o w n 22 a p a r t m e n t ? 23 A . Y e s . 24 Q . H o w b i g w a s t h e a p a r t m e n t ? 25 A . I t w a s m a s s i v e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 77 of 469 Highly Confidential Page 77 1 HIGHLY CONFIDENTIAL AEO 2 Q. How many bedrooms did it 3 have? 4 A. I can't remember. I can't 5 remember. I can't -- 6 Q. Two or seven? 7 A. I just -- I remember just 8 the -- like, the living room, and it 9 was very spacious. 10 Q . C a n y o u d r a w a p i c t u r e o f 11 t h e l a y o u t o f i t ? 12 A . I w o u l d n ' t r e m e m b e r t h e 13 l a y o u t . T h e r e w a s - - I r e m e m b e r l i k e 14 a p a l e b l u e d e c o r . 15 Q . A n d n o o n e e l s e l i v e d t h e r e 16 w i t h y o u ? 17 A . N o . 18 Q . A n d y o u d o n ' t k n o w h o w m a n y 19 b e d r o o m s ? 20 A . I c a n ' t r e m e m b e r h o w m a n y 21 b e d r o o m s t h e r e w e r e . 22 Q . W a s t h e r e a d o o r m a n ? 23 A . O h , I c a n ' t r e m e m b e r . 24 Q . W a s i t a w a l k u p o r e l e v a t o r ? 25 A . E l e v a t o r . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 78 of 469 Highly Confidential Page 78 1 HIGHLY CONFIDENTIAL AEO 2 Q. What floor were you on? 3 A. I can't remember. 4 Q. Approximately when did you 5 move into this apartment? 6 A. It was not long after I 7 moved in with Chris. About two 8 months, I think. About two months, I 9 think, roughly. 10 Q . S o y o u l i v e d w i t h C h r i s f o r 11 a b o u t t w o m o n t h s a n d t h e n y o u m o v e d 12 i n t o t h i s o t h e r a p a r t m e n t ? 13 A . T h a t ' s c o r r e c t . 14 Q . A n d h o w m u c h w e r e y o u p a y i n g 15 f o r t h i s n e w a p a r t m e n t ? 16 A . O h , i t w a s J e f f r e y ' s . I 17 d i d n ' t p a y a s i n g l e t h i n g . 18 Q . A n d w h o e l s e l i v e d i n t h e 19 a p a r t m e n t b u i l d i n g ? 20 A . Q u i t e a - - g o s h . A f e w , 21 a c t u a l l y . I r e c a l l N a d i a . 22 Q . D o y o u k n o w N a d i a ' s l a s t 23 n a m e ? 24 A . I c a n ' t r e m e m b e r h e r l a s t 25 n a m e , N a d i a ' s l a s t n a m e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 79 of 469 Highly Confidential Page 79 1 HIGHLY CONFIDENTIAL AEO 2 Q. Okay. Who else? 3 A. There were a few other 4 girls. I can't remember their names. 5 Q. None of them? 6 A. No. It was a long time ago. 7 Q. What did they look like, 8 these other names you can't remember? 9 A. I can't remember. There 10 w e r e s o m a n y . T h e r e w e r e s o m a n y 11 g i r l s , a c o n s t a n t i n f l u x o f g i r l s . 12 Q . H o w m a n y ? 13 M S . M C C A W L E Y : O b j e c t i o n . 14 A . I c a n ' t r e m e m b e r . 15 Q . 5 0 ? 16 M R . G U I R G U I S : O b j e c t i o n . 17 A . I c a n ' t r e m e m b e r . 18 Q . A h u n d r e d ? 19 M R . G U I R G U I S : O b j e c t i o n . 20 A . I c a n ' t r e m e m b e r . 21 Q . C a n y o u s a y i f i t w a s m o r e 22 t h a n a t h o u s a n d o r l e s s ? 23 M R . G U I R G U I S : O b j e c t i o n . 24 A . I c a n ' t r e m e m b e r . 25 Q . Y o u c a n ' t r e m e m b e r i f i t w a s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 80 of 469 Highly Confidential Page 80 1 HIGHLY CONFIDENTIAL AEO 2 more than a thousand? 3 A. I can't remember. 4 MR. GUIRGUIS: Objection. 5 MS. MCCAWLEY: Objection. 6 This is harassing. 7 MR. GUIRGUIS: Objection. 8 We're crossing a line here. 9 MS. MENNINGER: Okay. I'm 10 a s k i n g i f s h e c a n r e m e m b e r i f i t 11 w a s m o r e t h a n a t h o u s a n d o r l e s s . 12 M S . M C C A W L E Y : B u t y o u 13 h a v e n ' t d e f i n e d i t . Y o u ' r e n o t 14 s a y i n g w h e r e . I n t h e a p a r t m e n t ? 15 I n g e n e r a l w h e n s h e m e t w i t h 16 J e f f r e y ? I m e a n - - 17 M S . M E N N I N G E R : I ' m a s k i n g 18 h e r - - s h e s a i d t h e r e w e r e s o 19 m a n y w o m e n t h a t w e r e i n f l u x i n 20 t h e a p a r t m e n t , a n d I ' m a s k i n g h o w 21 m a n y . 22 M S . M C C A W L E Y : S h e d i d n ' t 23 s a y i n t h e a p a r t m e n t . G o b a c k 24 a n d l o o k a t t h e t e s t i m o n y . 25 T H E W I T N E S S : I n t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 81 of 469 Highly Confidential Page 81 1 HIGHLY CONFIDENTIAL AEO 2 building. 3 Q. Right. In the building. 4 How many females did you meet in the 5 building? 6 MR. GUIRGUIS: Objection. 7 A. I can't remember. 8 Q. And can you say it was more 9 or less than one thousand? 10 M R . G U I R G U I S : O b j e c t i o n . 11 A . I t w a s l e s s t h a n a t h o u s a n d 12 g i r l s . 13 Q . W a s i t l e s s t h a n a h u n d r e d ? 14 A . Y e s , i t w a s l e s s t h a n a 15 h u n d r e d . 16 Q . W a s i t l e s s t h a n 5 0 ? 17 A . I c a n ' t r e m e m b e r . 18 Q . A p a r t f r o m N a d i a , c a n y o u 19 n a m e a n y o t h e r o n e o f t h e f e m a l e s t h a t 20 y o u m e t i n t h e a p a r t m e n t b u i l d i n g ? 21 M R . G U I R G U I S : O b j e c t i o n . 22 A . I c a n ' t r e m e m b e r . 23 Q . C a n y o u d e s c r i b e a n y o f 24 t h e m ? 25 M R . G U I R G U I S : O b j e c t i o n . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 82 of 469 Highly Confidential Page 82 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember. 3 Q. Did you do any employment 4 while you were here in the U.S. in the 5 fall of 2006? 6 MR. GUIRGUIS: Objection. 7 A. I did freelance modeling. 8 Q. Who did you do that for? 9 A. Various photographers. 10 Q . D o y o u h a v e t h o s e 11 p h o t o g r a p h s s t i l l ? 12 A . N o . 13 Q . D o y o u h a v e a p o r t f o l i o ? 14 A . I u s e d t o h a v e o n e . 15 Q . D o y o u c u r r e n t l y h a v e a 16 m o d e l i n g p o r t f o l i o ? 17 A . N o . 18 Q . D o y o u h a v e a n y o f y o u r 19 m o d e l i n g p h o t o s ? 20 M S . M C C A W L E Y : O b j e c t i o n , 21 a s k e d a n d a n s w e r e d . 22 A . Y e a h , I g o t a c o u p l e . 23 Q . W h e r e a r e t h e y ? 24 A . A t h o m e . 25 Q . I n B a r c e l o n a ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 83 of 469 Highly Confidential Page 83 1 HIGHLY CONFIDENTIAL AEO 2 A. That's correct. 3 Q. Are they on a computer? 4 A. No. 5 Q. When you came to the U.S. in 6 the fall of 2006, was there a limit on 7 how long you could stay here? 8 MR. GUIRGUIS: Objection. 9 A. Yes, there was. 10 Q . W h a t w a s t h a t ? 11 A . I t w a s a t h r e e - m o n t h t o u r i s t 12 v i s a . 13 Q . W e r e y o u p e r m i t t e d t o b e 14 e m p l o y e d w h i l e y o u w e r e h e r e o n a 15 t o u r i s t v i s a ? 16 M R . G U I R G U I S : O b j e c t i o n . 17 H o l d o n a s e c o n d . 18 M S . M E N N I N G E R : I d o n ' t k n o w 19 w h a t k i n d o f v i s a s h e w a s o n . 20 I ' m j u s t a s k i n g t h e q u e s t i o n . 21 M R . G U I R G U I S : I d o n ' t - - I 22 d o n ' t k n o w w h y h e r v i s a s t a t u s i s 23 r e l e v a n t o r w h y w e ' r e g o i n g t o 24 g e t i n t o t h i n g s t h a t M r . T r u m p 25 m i g h t b e i n t e r e s t e d i n , s o I ' m MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 84 of 469 Highly Confidential Page 84 1 HIGHLY CONFIDENTIAL AEO 2 not going to have her sit here 3 and testify about whether she was 4 complying with immigration law or 5 not. 6 MS. MENNINGER: Is she 7 taking the Fifth Amendment? 8 MR. GUIRGUIS: I'm just not 9 sure that you need to ask the 10 q u e s t i o n . 11 M S . M E N N I N G E R : W e l l , I d i d 12 a s k t h e q u e s t i o n . I w a n t t o k n o w 13 i f s h e w a s p e r m i t t e d , o n t h e t y p e 14 o f v i s a s h e c a m e i n o n t h e f a l l 15 o f 2 0 0 6 , t o e n g a g e i n p a i d 16 e m p l o y m e n t . 17 M R . G U I R G U I S : O k a y . N o w 18 t h a t I h e a r t h e q u e s t i o n , y o u c a n 19 a n s w e r i t i f y o u k n o w t h e a n s w e r . 20 A . N o . 21 Q . N o , y o u w e r e n o t p e r m i t t e d 22 t o d o p a i d e m p l o y m e n t , c o r r e c t ? 23 A . T h a t ' s c o r r e c t . 24 Q . Y o u d i d p a i d e m p l o y m e n t 25 w h i l e y o u w e r e h e r e o n t h e t o u r i s t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 85 of 469 Highly Confidential Page 85 1 HIGHLY CONFIDENTIAL AEO 2 visa, correct? 3 A. I wouldn't quite say -- I 4 kind of -- I wasn't that great at it, 5 so I didn't make a lot of money doing 6 modeling. I was too fat, apparently. 7 So I wouldn't say I milked the bank 8 there. 9 (An off-the-record 10 d i s c u s s i o n w a s h e l d . ) 11 A . M i l k e d t h e b a n k w i t h m y 12 m o d e l i n g - - a m a z i n g m o d e l i n g c a r e e r . 13 Q . S o y o u c a m e o v e r i n o r d e r t o 14 f u r t h e r y o u r e d u c a t i o n , I t h i n k y o u 15 t e s t i f i e d t o e a r l i e r , c o r r e c t ? 16 A . T h a t ' s c o r r e c t . 17 Q . S o w h i l e y o u w e r e h e r e 18 d u r i n g t h o s e t h r e e m o n t h s - - w a s i t 19 t h r e e m o n t h s y o u s a i d , a t f i r s t , o n 20 t h e t o u r i s t v i s a ? C o r r e c t ? 21 A . Y e s , y e a h . 22 Q . W h e n y o u w e r e h e r e t h o s e 23 f i r s t t h r e e m o n t h s , w h a t d i d y o u d o t o 24 f u r t h e r y o u r e d u c a t i o n ? 25 A . I s t a r t e d l o o k i n g a t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 86 of 469 Highly Confidential Page 86 1 HIGHLY CONFIDENTIAL AEO 2 universities or colleges, researching 3 what was the right one for me to go 4 to. 5 By that stage, I -- I've 6 always been interested in the fashion 7 industry, designing, clothes 8 designing. And New York was -- well, 9 this is the place to be for it. 10 S o , y e a h , I d i d q u i t e a l o t 11 o f r e s e a r c h o n w h i c h u n i v e r s i t y , w h a t 12 k i n d o f p e o p l e w e r e t h e r e a n d 13 e t c e t e r a , s o . . . 14 Q . H o w w e r e y o u s u p p o r t i n g 15 y o u r s e l f w h i l e y o u w e r e l i v i n g i n N e w 16 Y o r k d u r i n g t h e t h r e e - m o n t h p e r i o d 17 a f t e r y o u i n i t i a l l y a r r i v e d ? 18 A . I h a d s o m e s a v i n g s . 19 Q . W a s y o u r f a m i l y p r o v i d i n g 20 y o u a n y m o n e y ? 21 A . N o . 22 Q . A p a r t f r o m y o u r s a v i n g s , w a s 23 t h e r e a n y o t h e r s o u r c e o f i n c o m e 24 d u r i n g O c t o b e r o r s o o f 2 0 0 6 ? 25 A . I d i d t h e o c c a s i o n a l , I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 87 of 469 Highly Confidential Page 87 1 HIGHLY CONFIDENTIAL AEO 2 guess, job where I was called to 3 entertain or spend time with people, 4 but that was about it. 5 Q. What does that mean? 6 A. Well, I don't really like to 7 use the word per se, because you guys 8 kind of, in your legal minds, have it 9 in a box of what you think it is. 10 B u t , l i k e , o n c e o r t w i c e , I 11 w a s p a i d t o s p e n d d i n n e r w i t h a 12 g e n t l e m a n d u r i n g t h a t t i m e . 13 Q . A n d h o w d i d y o u m e e t t h e 14 g e n t l e m a n ? 15 A . I t w a s t h r o u g h a n a g e n c y . 16 Q . W h a t w a s t h e n a m e o f t h e 17 a g e n c y ? 18 A . I c a n ' t r e m e m b e r . 19 Q . D o y o u k n o w w h e r e i t w a s 20 l o c a t e d ? 21 A . N o . 22 Q . D o y o u k n o w h o w m u c h y o u 23 w e r e p a i d t o s p e n d d i n n e r t i m e w i t h a 24 g e n t l e m a n ? 25 A . I t d e p e n d e d h o w l o n g t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 88 of 469 Highly Confidential Page 88 1 HIGHLY CONFIDENTIAL AEO 2 dinner was for. 3 Q. And what was the most that 4 you recall making for spending dinner 5 with a gentleman? 6 A. $1,500. 7 Q. Did you engage in any sexual 8 relations with the gentleman? 9 A. One, yeah, once or twice, 10 b u t i t w a s o n m y o w n a c c o r d . I t w a s 11 a f t e r t h a t t i m e p e r i o d h a d f i n i s h e d . 12 Q . W h a t t i m e p e r i o d ? 13 A . M y a p p o i n t m e n t , m y d i n n e r 14 w i t h t h e m . 15 Q . O k a y . 16 A . H e j u s t h a p p e n e d t o b e 17 r e a l l y g o o d l o o k i n g . 18 M R . G U I R G U I S : I t ' s b e e n 19 a b o u t a n h o u r . M a y b e w e c a n t a k e 20 f i v e m i n u t e s , s t r e t c h . 21 M S . M E N N I N G E R : S u r e . 22 ( T i m e n o t e d : 1 0 : 4 7 a . m . ) 23 ( R e c e s s . ) 24 ( T i m e n o t e d : 1 1 : 0 5 a . m . ) 25 Q . A p p r o x i m a t e l y h o w m a n y t i m e s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 89 of 469 Highly Confidential Page 89 1 HIGHLY CONFIDENTIAL AEO 2 do you recall being paid to spend 3 dinner with a gentleman in New York 4 when you were living here in late 5 2006? 6 A. I can't remember. 7 Q. Ten times? 8 MR. GUIRGUIS: Objection. 9 A. It could be, it wasn't -- 10 y e a h , i t c o u l d b e t h a t . I t w a s n ' t 11 r e a l l y . . . 12 Q . A p a r t f r o m t h a t i n c o m e , d i d 13 y o u h a v e a n y o t h e r s o u r c e s o f i n c o m e ? 14 M R . G U I R G U I S : I ' m s o r r y . 15 O f f t h e r e c o r d f o r a s e c o n d . 16 ( A n o f f - t h e - r e c o r d 17 d i s c u s s i o n w a s h e l d . ) 18 M S . M E N N I N G E R : I t h i n k 19 t h e r e ' s a q u e s t i o n p e n d i n g . 20 ( R e q u e s t e d p o r t i o n o f t h e 21 r e c o r d w a s r e a d b a c k . ) 22 A . Y e s , I d i d , y e s . 23 Q . W h a t w e r e t h e o t h e r s o u r c e s ? 24 A . J e f f r e y E p s t e i n . 25 Q . A n y o t h e r s o u r c e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 90 of 469 Highly Confidential Page 90 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Who introduced you to 4 Jeffrey Epstein? 5 A. Natalya Malyshev. 6 Q. And how did you meet Natalya 7 Malyshev? 8 A. I met her in a nightclub. 9 Q. Do you know which nightclub? 10 A . I c a n ' t r e m e m b e r t h e e x a c t 11 n a m e . I t w a s a r o c k c l u b . T h e o w n e r 12 o f t h e c l u b , h i s n a m e i s . Y e a h , 13 h i s n a m e - - i t ' s q u i t e a w e l l - k n o w n 14 c l u b . I f y o u G o o g l e t h e n a m e , 15 y o u ' l l f i n d t h e n a m e . t h e 16 n i g h t c l u b o w n e r ; h e ' s q u i t e f a m o u s i n 17 N e w Y o r k . 18 Q . D o y o u k n o w w h e r e i n N e w 19 Y o r k t h e c l u b i s l o c a t e d ? 20 A . I c a n ' t r e m e m b e r . I d o n ' t 21 k n o w t h e e x a c t l o c a t i o n . 22 Q . W e r e y o u t h e r e s o c i a l l y o r 23 w e r e y o u w o r k i n g ? 24 A . S o c i a l l y . 25 Q . A n d w e r e y o u w i t h a n y o n e ? - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 91 of 469 Highly Confidential Page 91 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection. 3 A. I can't remember. I would 4 have been with an acquaintance or 5 something, but I can't remember who I 6 was with. 7 Q. Were you able to make some 8 friends with people here in New York 9 when you moved here? 10 A . Y e s . N a t a l y a , J e n n i f e r , 11 , a g i r l n a m e d P a m . P a m . 12 T h e r e w e r e a f e w o t h e r - - I c a n ' t 13 r e m e m b e r t h e i r - - t h e y w e r e n ' t c l o s e 14 f r i e n d s , t h e y w e r e j u s t a c q u a i n t a n c e s . 15 Y o u d o n ' t r e a l l y m a k e f r i e n d s i n N e w 16 Y o r k . 17 Q . T e l l m e a b o u t y o u r m e e t i n g 18 o f N a t a l y a . 19 A . S h e w a s a v e r y a t t r a c t i v e 20 g i r l , R u s s i a n . I t h i n k R u s s i a n . V e r y 21 f r i e n d l y , v e r y b e a u t i f u l g i r l , v e r y - - 22 w e c l i c k e d i m m e d i a t e l y . 23 Y e a h . S h e a p p r o a c h e d m e . I 24 w a s n ' t - - y e a h , I d i d n ' t g o o u t o f m y 25 w a y t o m e e t a n y f r i e n d s i n a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 92 of 469 Highly Confidential Page 92 1 HIGHLY CONFIDENTIAL AEO 2 nightclub, so -- especially girls. 3 Q. What do you mean, she 4 approached you? 5 A. So when I go to a club, I 6 don't really speak to girls. I speak 7 to guys. So Natalya approached me and 8 came on to me. 9 Q. Where were you? 10 A . I n t h e n i g h t c l u b . 11 Q . W h e r e i n t h e n i g h t c l u b ? 12 A . I c a n ' t - - I c a n ' t r e m e m b e r 13 t h e e x a c t l o c a t i o n . 14 Q . W e r e y o u a t t h e b a r a r e a ? 15 O n t h e d a n c e f l o o r ? I n t h e b a t h r o o m ? 16 A . I w o u l d s a y s h e p r e t t y m u c h 17 h i t o n m e e v e r y w h e r e i n t h e c l u b . 18 Q . W a s t h e r e a d a n c e f l o o r ? 19 A . Y e s , t h e r e w a s . 20 Q . W a s i t a o n e f l o o r c l u b o r 21 t w o f l o o r s ? 22 A . I c a n ' t r e m e m b e r h o w m a n y 23 f l o o r s . 24 Q . A n d w h a t d i d s h e d o t o h i t 25 o n y o u ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 93 of 469 Highly Confidential Page 93 1 HIGHLY CONFIDENTIAL AEO 2 A. She befriended me, she -- 3 yeah, she kissed me. 4 Q. Where did she kiss you? 5 A. On the mouth. 6 Q. Anywhere else? 7 A. Can -- is that in general or 8 at that -- 9 Q. I'm just talking about the 10 f i r s t t i m e y o u m e t . 11 A . T h e f i r s t t i m e w e m e t ? 12 Q . R i g h t . 13 A . I c a n ' t r e m e m b e r i f w e h a d 14 s e x t h e f i r s t n i g h t w e m e t , b u t w e 15 d e f i n i t e l y w e r e i n t i m a t e t h e f i r s t 16 t i m e w e m e t . B u t I c a n ' t r e m e m b e r i f 17 w e h a d h a d s e x o n t h a t f i r s t n i g h t . 18 Q . O k a y . W a s t h a t c o n s e n s u a l 19 s e x ? 20 A . Y e s , i t w a s w i t h N a t a l y , 21 N a t a l y a . 22 Q . A n d w h e r e d i d y o u h a v e 23 c o n s e n s u a l s e x w i t h N a t a l y a ? 24 A . I n t h e c l u b t h e f i r s t t i m e . 25 Q . W h e r e i n t h e c l u b ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 94 of 469 Highly Confidential Page 94 1 HIGHLY CONFIDENTIAL AEO 2 A. In the owner's office. 3 Q. Was the owner present? 4 A. Yes, the owner was present. 5 Q. ? 6 A. Is that -- I don't know his 7 surname, so -- is it -- -- I can 8 give you a description of if you 9 want. 10 Q . S u r e . 11 A . G r a y i s h h a i r , d a r k e y e s . 12 L o o k s a b i t l i k e t h e d e v i l , g o t a 13 l i t t l e g o a t e e . G o t k i n d o f l i k e o l i v y 14 s k i n . I ' v e g o t a p h o t o o f m y s e l f a n d 15 , s o . . . 16 Q . O k a y . S o y o u a n d N a t a l y a 17 a n d h a d c o n s e n s u a l s e x i n ' s 18 o f f i c e ? 19 M R . G U I R G U I S : O b j e c t i o n . 20 M S . M C C A W L E Y : O b j e c t i o n . 21 Q . I s t h a t r i g h t ? 22 A . T h a t ' s c o r r e c t . 23 Q . D i d I g e t t h a t w r o n g i n a n y 24 w a y ? 25 M R . G U I R G U I S : H e r e ' s t h e - - - - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 95 of 469 Highly Confidential Page 95 1 HIGHLY CONFIDENTIAL AEO 2 question. 3 A. Yeah, that's correct. 4 Q. Was anyone else present? 5 A. No. 6 Q. Did you have any alcohol 7 that night? 8 A. I did. 9 Q. How much? 10 A . N o t e n o u g h t o f o r g e t o r 11 b l a c k o u t , s o n o t m u c h . I w a s a b l e t o 12 m a k e d e c i s i o n s . 13 Q . D o y o u r e c a l l w h a t y o u w e r e 14 w e a r i n g ? 15 A . N o , I d o n ' t . 16 Q . D i d y o u h a v e a n y c o c a i n e 17 t h a t n i g h t ? 18 A . I d o n ' t r e m e m b e r . 19 Q . D i d y o u u s e c o c a i n e d u r i n g 20 t h e f a l l o f 2 0 0 6 ? 21 A . Y e s , I d i d . 22 Q . A n d w h e r e d i d y o u g e t t h a t 23 c o c a i n e ? 24 A . F r o m a n d N a t a l y a . 25 Q . A n y w h e r e e l s e ? - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 96 of 469 Highly Confidential Page 96 1 HIGHLY CONFIDENTIAL AEO 2 A. From 's best friend, a 3 guy named Peter Lambrakis. I don't 4 know how to spell that. 5 Q. Anywhere else? 6 A. No. 7 Q. Did you pay for any of the 8 cocaine? 9 A. No. 10 Q . D i d y o u u s e a n y o t h e r 11 c o n t r o l l e d s u b s t a n c e s i n t h e f a l l o f 12 2 0 0 6 ? 13 A . N o . 14 Q . D i d y o u t a k e a n y 15 p r e s c r i p t i o n s i n t h e f a l l o f 2 0 0 6 ? 16 A . I d i d . 17 Q . W h a t d i d y o u t a k e ? 18 A . J e f f r e y ' s p s y c h i a t r i s t 19 p r e s c r i b e d m e l i t h i u m , R i t a l i n , a n d 20 t h e r e w a s a b i p o l a r d e s c r i p t i o n d r u g 21 t h a t w a s a l s o p r e s c r i b e d t o m e b y 22 J e f f r e y E p s t e i n ' s p s y c h i a t r i s t . I 23 c a n ' t r e m e m b e r t h e e x a c t n a m e o f t h a t 24 b i p o l a r d r u g . B u t I w a s s t a r t e d o f f 25 w i t h l i t h i u m a n d R i t a l i n . - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 97 of 469 Highly Confidential Page 97 1 HIGHLY CONFIDENTIAL AEO 2 Q. Okay. What was the name of 3 the psychiatrist? 4 A. I can't remember her name. 5 Q. It was a woman? 6 A. It was a woman. 7 Q. And where was she located? 8 A. I can't -- I can't remember 9 the exact location of her office. 10 Q . C a n y o u d e s c r i b e t h e o f f i c e 11 i n a n y w a y ? 12 A . I c a n ' t r e m e m b e r . 13 Q . D i d a n y o n e g o w i t h y o u ? 14 A . N o , I w e n t o n m y o w n . 15 Q . W h e r e d i d y o u g o t o g e t y o u r 16 p r e s c r i p t i o n s f i l l e d ? 17 A . A p h a r m a c y n e a r J e f f r e y 18 E p s t e i n ' s a p a r t m e n t t h a t I w a s l i v i n g 19 i n a t t h e t i m e . I t h i n k i t w a s a 20 D u a n e R e a d e . 21 Q . W e r e t h e y i n y o u r n a m e ? 22 A . Y e s , t h e y w e r e . 23 Q . W e r e y o u t a k i n g t h e s e i n t h e 24 f a l l o f 2 0 0 6 o r i n 2 0 0 7 o r b o t h ? 25 A . J e f f r e y f i r s t p u t m e i n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 98 of 469 Highly Confidential Page 98 1 HIGHLY CONFIDENTIAL AEO 2 touch with his psychiatrist, it was 3 before -- it was -- yeah, it was well 4 before December, so it was the fall 5 of -- fall/winter, going into winter 6 2006. 7 Q. Do you recall what month you 8 came to the U.S.? 9 A. It was September 2006. 10 Q . D i d y o u l e a v e a n d c o m e b a c k 11 i n O c t o b e r ? 12 A . I t h i n k I m a y h a v e . I m a y 13 h a v e m a d e a t r i p t o L o n d o n o r l i k e a 14 q u i c k , b r i e f t r i p . 15 Q . W h o p a i d f o r t h a t ? 16 A . I c a n ' t r e m e m b e r . 17 Q . W h y d i d y o u g o b a c k ? 18 A . I a c t u a l l y c a n ' t e v e n 19 r e m e m b e r w h y I w e n t b a c k . 20 Q . S o y o u t h i n k y o u c a m e i n 21 S e p t e m b e r ? 22 A . I k n o w I c a m e i n S e p t e m b e r . 23 Q . A n d y o u s a i d y o u c o u l d s t a y 24 f o r t h r e e m o n t h s ? 25 A . A n d t h e n I l e f t t h e c o u n t r y MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 99 of 469 Highly Confidential Page 99 1 HIGHLY CONFIDENTIAL AEO 2 briefly for a day and then I came back 3 in again. 4 Q. When did you do that? 5 A. So if you look at my 6 passport when I entered -- you've got 7 my passport. So I arrived on the 1st, 8 I think, of September, and then it was 9 just before the three months were up, 10 a n d t h e n I l e f t . 11 I t h i n k t h a t w a s t h e t r i p 12 t h a t I m a d e t o L o n d o n i n - - O c t o b e r , 13 N o v e m b e r - - O c t o b e r , N o v e m b e r - - y e a h , 14 s o I w a s - - I l e f t b e f o r e t h e d u e t i m e 15 t h a t m y t o u r i s t v i s a w a s u p , a n d I 16 s p e n t a s u m m e r a n d c a m e b a c k . 17 Q . W h e r e d i d y o u g o ? 18 A . I t h i n k i t w a s L o n d o n . I 19 w e n t t o - - I w e n t t o L o n d o n . A n d t h e n 20 J e f f r e y p a i d f o r a f l i g h t f o r m e t o 21 v i s i t m y f a m i l y i n S o u t h A f r i c a i n 22 F e b r u a r y . 23 Q . O k a y . S o t h e r e ' s t w o t r i p s 24 t o L o n d o n w e ' r e t a l k i n g a b o u t ? 25 T h e r e ' s o n e y o u w e n t a n d y o u c a m e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 100 of 469 Highly Confidential Page 100 1 HIGHLY CONFIDENTIAL AEO 2 right back? 3 A. I only recall one trip to 4 London. I didn't really kind of 5 catalog every trip I made. I did a 6 lot of traveling during my time in the 7 U.S., so... 8 Q. Had you traveled a lot 9 before you came to the U.S.? 10 A . Y e a h . I s p e n t m y w h o l e l i f e 11 t r a v e l i n g . 12 Q . H o w w e r e y o u a b l e d o t h a t ? 13 A . T h r o u g h s a v i n g s , t h r o u g h 14 w a i t r e s s i n g j o b s , t h a t k i n d o f t h i n g . 15 Q . D i d y o u r f a m i l y e v e r p a y f o r 16 y o u t o g o o n t r i p s ? 17 A . N o . 18 Q . N e v e r ? 19 A . N o . 20 Q . D o e s y o u r f a m i l y t r a v e l ? 21 A . Y e a h , t h e y t r a v e l . T h e y g o 22 o n h o l i d a y s o v e r s e a s . T h e y g o o n 23 h o l i d a y s . 24 Q . S o y o u s a i d y o u g o t a 25 p a s s p o r t y o u r w h o l e l i f e , I t h i n k y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 101 of 469 Highly Confidential Page 101 1 HIGHLY CONFIDENTIAL AEO 2 said, right? 3 A. Well, I can't remember the 4 specific date when -- I was like from 5 3 to 5 when I got my passport. I 6 didn't arrange my passport at 3 years 7 old; my mom kind of did that. 8 So I've always grown up with 9 a British and South African passport. 10 I h a d d u a l n a t i o n a l i t y r i g h t f r o m t h e 11 g e t - g o . 12 Q . R i g h t . S o w h e n y o u w e r e a 13 c h i l d , d i d y o u t r a v e l i n t e r n a t i o n a l l y ? 14 A . Y e a h , I d i d , t o v i s i t m y 15 f a m i l y i n S c o t l a n d . 16 Q . A n d a p a r t f r o m t h e U K a n d 17 S o u t h A f r i c a , d i d y o u g o a n y w h e r e a s a 18 c h i l d ? 19 A . W e w e n t o n h o l i d a y s a n d 20 A f r i c a . M a y b e I w e n t t o S c o t l a n d t o 21 v i s i t m y f a m i l y , y e a h , p o s s i b l y . I 22 d o n ' t r e m e m b e r . 23 Q . O k a y . 24 A . T h e y w e r e n ' t p h o t o - h a p p y i n 25 m y f a m i l y . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 102 of 469 Highly Confidential Page 102 1 HIGHLY CONFIDENTIAL AEO 2 Q. They were what? 3 A. They weren't photo-happy, 4 so... 5 Q. So back in the fall 2006, 6 you were here for three months and 7 then you left -- 8 A. Yeah. I didn't want to go 9 over my visa and get in trouble, and I 10 w a s n ' t m a k i n g m u c h m o n e y a n y w a y . A n d 11 J e f f r e y w a s w i t h F I T , s o h e w a s g o i n g 12 t o o r g a n i z e m e a v i s a s o I c o u l d s t a y . 13 S o I d i d n ' t d o a n y t h i n g 14 w r o n g o r i l l e g a l w i t h m y v i s a , j u s t t o 15 c l a r i f y . 16 Q . I u n d e r s t a n d . I ' m j u s t 17 t r y i n g t o g e t t h e t i m i n g o f w h e n y o u 18 w e r e h e r e a n d t h e n y o u l e f t a n d t h e n 19 y o u c a m e b a c k ; i s t h a t r i g h t ? 20 A . S o t h e d u r a t i o n t h a t I w a s 21 h e r e , I a r r i v e d i n S e p t e m b e r a n d I 22 l e f t - - I t h i n k i t w a s t h e 1 s t o f M a y . 23 S o d u r i n g t h a t t i m e , t h e r e 24 w a s a t r i p t h a t I m a d e t o S o u t h A f r i c a 25 t o v i s i t m y f a m i l y a n d t h e r e w a s a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 103 of 469 Highly Confidential Page 103 1 HIGHLY CONFIDENTIAL AEO 2 trip to London. I don't recall -- I 3 don't remember any other trips that I 4 made during that duration of time, 5 away from Jeffrey and Ghislaine, if 6 you understand, on my independent own. 7 Q. Right. So if you came in 8 September and you could stay for three 9 months -- 10 A . M m - h m m . 11 Q . S o y o u l e f t i n D e c e m b e r ? 12 M S . M C C A W L E Y : O b j e c t i o n , 13 a s k e d a n d a n s w e r e d . 14 A . S e p t e m b e r , O c t o b e r , 15 N o v e m b e r . Y e a h , I d i d - - I d i d m a k e a 16 t r i p t o - - I d o n ' t r e c a l l t h e s p e c i f i c 17 d a t e s , b u t I d i d m a k e a t r i p t o L o n d o n 18 a n d I d i d m a k e a t r i p t o S o u t h A f r i c a 19 i n F e b r u a r y . S o I d o n ' t . . . 20 Q . D i d y o u g o f r o m L o n d o n t o 21 S o u t h A f r i c a ? 22 A . I d o n ' t r e m e m b e r t h e e x a c t 23 t r i p i t i n e r a r y . B u t , y e a h , I f l e w t o 24 S o u t h A f r i c a o n a p l a n e . 25 Q . F r o m L o n d o n ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 104 of 469 Highly Confidential Page 104 1 HIGHLY CONFIDENTIAL AEO 2 A. From New York. 3 Q. Okay. So you recall having 4 been on two trips independently 5 between September 2006 and May 2007, 6 right? One to London and one to South 7 Africa? 8 A. Yeah, that's correct. 9 Q. And the one to London, you 10 r e c a l l b e i n g a b r i e f t r i p t o t h e n 11 a l l o w y o u t o s t a y i n t h e c o u n t r y 12 l o n g e r ? 13 A . I d o n ' t r e m e m b e r w h y I w e n t . 14 I d o n ' t e v e n r e m e m b e r t h e t r i p , o k a y ? 15 I r e a l l y d o n ' t r e c a l l . I p r o b a b l y 16 v i s i t e d m y m o m o r - - o r w h a t e v e r . I 17 j u s t k n o w t h a t I m a d e t w o t r i p s d u r i n g 18 t h a t d u r a t i o n a n d I k n o w t h a t I d i d 19 n o t o v e r g o t h e t h r e e - m o n t h t h i n g . S o 20 I m a d e t h o s e f o r t h o s e s p e c i f i c 21 r e a s o n s . 22 Q . O k a y . 23 A . B u t t h o s e - - I j u s t w a n t e d 24 t o m a k e c l e a r t h a t t h o s e w e r e t h e o n l y 25 t w o t r i p s I m a d e i n d e p e n d e n t l y w i t h o u t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 105 of 469 Highly Confidential Page 105 1 HIGHLY CONFIDENTIAL AEO 2 Jeffrey aiding, and I would like to 3 make that clear. I made multiple 4 trips with Jeffrey, so independently I 5 did those two. 6 Q. Were any of your trips with 7 Jeffrey international? 8 A. No. 9 Q. Can you tell me when in your 10 s t a y i n t h e U . S . y o u i n i t i a l l y m e t 11 N a t a l y a ? 12 A . I t w a s p r e t t y s o o n a f t e r I 13 a r r i v e d . I c a n ' t r e m e m b e r t h e e x a c t 14 t i m e f r a m e . I t h i n k i t w a s a b o u t 15 m a y b e t w o , t h r e e w e e k s a f t e r I 16 a r r i v e d . 17 Q . W e r e y o u l i v i n g a t C h r i s ' s ? 18 A . Y e s . 19 Q . D i d y o u c o n s i d e r y o u r s e l f i n 20 a r e l a t i o n s h i p w i t h N a t a l y a ? 21 A . N o , w e w e r e j u s t h a v i n g f u n . 22 A n d s h e w a s - - s h e w a s r e a l l y 23 f r i e n d l y , a n d I d i d n ' t k n o w a n y o n e i n 24 N e w Y o r k , s o - - a n d , y o u k n o w , I 25 w a n t e d t o m a k e f r i e n d s . S h e w a s a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 106 of 469 Highly Confidential Page 106 1 HIGHLY CONFIDENTIAL AEO 2 girl and was just very friendly, 3 pretty. 4 Q. Was she also involved in the 5 fashion industry at all? 6 A. I don't recall. I just 7 recall her working for Jeffrey. 8 Q. What did you observe her 9 doing for Jeffrey? 10 A . T h e e x a c t s a m e t h i n g s h e d i d 11 w i t h m e . S h e r e c r u i t e d m e a n d w a s 12 p a i d f o r i t . 13 Q . O k a y . D i d y o u s e e h e r g e t 14 p a i d ? 15 A . N o . 16 Q . H o w d o y o u k n o w s h e g o t 17 p a i d ? 18 A . T h e g i r l s t o l d m e . 19 Q . W h o w e r e t h e g i r l s ? 20 A . I c a n ' t r e m e m b e r t h e i r 21 n a m e s . 22 Q . O k a y . S o t h e g i r l s t o l d 23 y o u ' r e t h a t N a t a l y a g o t p a i d b y 24 J e f f r e y ? 25 A . T h a t ' s c o r r e c t . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 107 of 469 Highly Confidential Page 107 1 HIGHLY CONFIDENTIAL AEO 2 Q. So what did you see Natalya 3 do for Jeffrey? 4 A. Well, she recruited me. I 5 think she recruited other girls for 6 Jeffrey. 7 Q. Did you see her do that? 8 A. No, but I met some of the 9 other girls that had been introduced 10 t o J e f f r e y a n d G h i s l a i n e v i a N a t a l y a . 11 Q . G o t i t . 12 S o y o u w e r e r e c r u i t e d b y 13 N a t a l y a , c o r r e c t ? Y e s o r n o . 14 A . Y e s . 15 Q . A n d y o u m e t o t h e r g i r l s w h o 16 k n e w N a t a l y a a n d J e f f r e y , c o r r e c t ? 17 A . W e l l , a l l t h e g i r l s k n e w 18 e a c h o t h e r , r e a l l y . A l l t h e g i r l s 19 k i n d o f . . . 20 Q . A r e t h e s e t h e s a m e g i r l s 21 t h a t a r e i n t h e a p a r t m e n t b u i l d i n g o r 22 a d i f f e r e n t s e t o f g i r l s ? 23 A . D i f f e r e n t s e t o f g i r l s . 24 Q . O k a y . 25 A . Y o u k n o w , t h e r e w a s a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 108 of 469 Highly Confidential Page 108 1 HIGHLY CONFIDENTIAL AEO 2 constant flow of women, girls. 3 Q. So where did you see these 4 other girls? 5 A. In Manhattan, with Jeffrey, 6 a few social occasions that we went 7 on, the island. On the plane, Jeffrey 8 Epstein's plane. I met girls 9 everywhere -- every time I went with 10 J e f f r e y . W e l l , n o t e v e r y t i m e , b u t h e 11 w a s a l w a y s s u r r o u n d e d b y n e w g i r l s . I 12 c o u l d n ' t k e e p u p w i t h t h e n a m e s , t o b e 13 h o n e s t . T h a t ' s w h y I c a n ' t r e m e m b e r 14 a n y o f t h e m . 15 Q . G e t t i n g b a c k t o N a t a l y a , y o u 16 m e t h e r a t t h e n i g h t c l u b ? 17 A . M m - h m m . 18 Q . D i d s h e w o r k a s a m o d e l a t 19 a l l ? 20 A . I w a s n ' t q u i t e c l e a r w h a t 21 s h e a c t u a l l y d i d , t o b e h o n e s t . I 22 h a v e a b s o l u t e l y n o i d e a . 23 Q . D o y o u k n o w w h e r e s h e l i v e d ? 24 A . N o , I d i d n ' t . I d o n ' t k n o w 25 w h e r e s h e l i v e s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 109 of 469 Highly Confidential Page 109 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you ever go to her 3 apartment? 4 A. No. 5 Q. When is the last time you 6 talked to her? 7 A. I haven't -- I think before 8 I left New York. 9 Q. Did you have a cell phone 10 w h e n y o u w e r e i n N e w Y o r k ? 11 A . Y e s , I d i d . 12 Q . D o y o u r e c a l l w h o y o u r c e l l 13 p h o n e p r o v i d e r w a s ? 14 A . I d o n ' t r e m e m b e r . 15 Q . D o y o u k n o w y o u r c e l l p h o n e 16 n u m b e r ? 17 A . N o , I h a v e n o i d e a . 18 Q . W h e n y o u w e r e l i v i n g i n N e w 19 Y o r k , w e r e y o u r p a r e n t s l i v i n g i n 20 S o u t h A f r i c a ? 21 A . M y d a d w a s l i v i n g i n S o u t h 22 A f r i c a , m y m o m w a s i n t h e U K . 23 Q . C a n y o u t e l l m e a b o u t y o u r 24 f i r s t c o n v e r s a t i o n w i t h N a t a l y a ? 25 A . I c a n ' t r e m e m b e r m y f i r s t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 110 of 469 Highly Confidential Page 110 1 HIGHLY CONFIDENTIAL AEO 2 conversation with her. 3 Q. Can you remember any 4 conversation with her? 5 A. Yeah, I can. I can remember 6 chatting. She was my friend. I mean, 7 we spoke about everything. We spoke 8 about life with Jeffrey, we spoke 9 about Ghislaine, we spoke about the 10 o t h e r g i r l s , w e s p o k e a b o u t J e n . J e n 11 w a s a r e a l l y n i c e g i r l a s w e l l . L i k e , 12 w e o f t e n g o t c o f f e e w i t h e a c h o t h e r , 13 l u n c h e s , d i n n e r s . 14 Q . O k a y . D o y o u r e m e m b e r a n y 15 s p e c i f i c s o f y o u r c o n v e r s a t i o n s ? 16 M S . M C C A W L E Y : O b j e c t i o n , 17 a s k e d a n d a n s w e r e d . 18 A . W e s p o k e v e r y f r e q u e n t l y 19 a b o u t t h e f a c e s J e f f r e y u s e d t o p u l l 20 w h e n h e u s e d t o m a s t u r b a t e o v e r t h e 21 g i r l s , w h i c h w a s q u i t e f u n n y . 22 W e s p o k e a b o u t G h i s l a i n e 23 q u i t e a l o t a n d w h a t a m o n s t e r s h e 24 w a s . S h e ' s r e a l l y n o t a n i c e p e r s o n , 25 s o - - y e a h , I m e a n , w e s p o k e a b o u t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 111 of 469 Highly Confidential Page 111 1 HIGHLY CONFIDENTIAL AEO 2 them a lot, actually. 3 Q. Okay. So you spoke about 4 the faces Jeffrey made when he 5 masturbates over the girls? 6 A. And the way he spits on his 7 hand when he masturbates. It's really 8 gross. It's quite funny. 9 Q. Any other conversations with 10 N a t a l y a t h a t y o u r e m e m b e r ? 11 A . I r e m e m b e r I d i d n ' t r e a l l y 12 g e t o n w i t h G h i s l a i n e . A s I s a i d , 13 s h e ' s - - i n m y o p i n i o n , s h e ' s n o t a 14 n i c e p e r s o n . I d i d n ' t r e a l l y g e t h e r . 15 A n d J e f f r e y E p s t e i n p r o m i s e d 16 m e a - - g o i n g t o F I T . S o w e 17 f r e q u e n t l y s p o k e a b o u t j u s t e v e r y d a y 18 t h i n g s , y o u k n o w . 19 N a t a l y a a n d I - - N a t a l y a 20 r e a l l y - - J e f f r e y E p s t e i n a n d I o n c e 21 h a d a f i g h t a n d N a t a l y a p a t c h e d t h i n g s 22 u p b e t w e e n u s , b e c a u s e I d i d n ' t w a n t 23 t o s p e a k t o J e f f r e y a n y m o r e . 24 I o f t e n s p o k e t o N a t a l y a 25 a b o u t w h y G h i s l a i n e d i d n ' t l i k e m e a n d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 112 of 469 Highly Confidential Page 112 1 HIGHLY CONFIDENTIAL AEO 2 why the other girls didn't like me: 3 Nadia didn't like me, Ghislaine didn't 4 like me, Sarah Kellen definitely 5 didn't like me. Yeah, that kind of 6 stuff. 7 Q. How is it that you came to 8 meet Jeffrey Epstein? 9 A. Through Natalya. 10 Q . T e l l m e a b o u t t h a t . 11 A . I f i r s t m e t J e f f r e y - - 12 N a t a l y a i n t r o d u c e d m e t o J e f f r e y . S h e 13 k i n d o f d e s c r i b e d h i m t o m e . S h e k n e w 14 I w a n t e d t o g o b a c k t o s c h o o l t o g e t a 15 d e g r e e , a n d I w a s r e a l l y b a t t l i n g 16 f i n a n c i a l l y b e c a u s e a t t h a t t i m e I 17 w a s n ' t r e a l l y m o d e l i n g m a t e r i a l . 18 S o , y e a h , s h e t o l d m e a b o u t 19 t h i s g u y w h o w a s r e a l l y w e a l t h y , a 20 p h i l a n t h r o p i s t , y o u k n o w , r e a l l y 21 e n j o y e d - - y o u k n o w , h e r e a l l y c a r e s 22 a b o u t p e o p l e a n d h e r e a l l y w a n t s t o 23 h e l p t h e m , a n d h e w a s a r e a l l y g o o d , 24 d e c e n t g u y . 25 T h e n w e - - h e w a s h e l p i n g MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 113 of 469 Highly Confidential Page 113 1 HIGHLY CONFIDENTIAL AEO 2 her at that time, as well as Jen and 3 other girls. 4 Q. That's what she told you? 5 A. Yes. 6 Q. Where were you when Natalya 7 was describing Jeffrey? 8 A. I can't remember the 9 location, but -- I mean, she first 10 d e s c r i b e d J e f f r e y - - I t h i n k i t w a s 11 t h e s e c o n d t i m e w e m e t , b e c a u s e I h a d 12 d i s c u s s e d w i t h h e r t h a t I w a s 13 s t r u g g l i n g f i n a n c i a l l y b e c a u s e m y 14 m o d e l i n g c a r e e r h a d n ' t r e a l l y t a k e n 15 o f f a s I h a d h o p e d , s o I w a s - - y e a h , 16 s h e w a n t e d t o h e l p . 17 Q . A n d y o u d o n ' t r e m e m b e r w h e r e 18 y o u h a d t h i s c o n v e r s a t i o n ? 19 A . N o , n o t s p e c i f i c a l l y t h e 20 e x a c t l o c a t i o n . 21 Q . W a s i t i n p e r s o n o r o v e r t h e 22 p h o n e ? 23 A . I t w a s i n p e r s o n . 24 Q . W a s a n y b o d y e l s e t h e r e ? 25 A . I t h i n k c o u l d h a v e b e e n - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 114 of 469 Highly Confidential Page 114 1 HIGHLY CONFIDENTIAL AEO 2 there, Peter Lambrakis could have been 3 there, a few other people could have 4 been there. Various people. She was 5 quite open about it. 6 Q. And do you know when this 7 was in the fall of 2006? 8 A. It was very close to after I 9 had first arrived, so it was quite 10 s o o n a f t e r I a r r i v e d . I d o n ' t k n o w 11 s p e c i f i c a l l y i f i t w a s t h r e e w e e k s o r 12 t w o w e e k s , b u t i t w a s q u i t e s o o n a f t e r 13 I f i r s t g o t t o . . . 14 Q . O k a y . S o d i d y o u m e e t 15 J e f f r e y ? D i d y o u a g r e e t o m e e t 16 J e f f r e y ? W h a t h a p p e n e d n e x t ? 17 M R . G U I R G U I S : O b j e c t i o n t o 18 f o r m . 19 Q . W h a t h a p p e n e d n e x t ? 20 M R . G U I R G U I S : O b j e c t i o n t o 21 t h a t o n e t o o . 22 A . I a g r e e d t o - - y e a h , I m e t 23 J e f f r e y . 24 Q . H o w ? 25 A . W e w e n t t o - - t h e f i r s t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 115 of 469 Highly Confidential Page 115 1 HIGHLY CONFIDENTIAL AEO 2 meeting I had with Jeffrey was at the 3 cinema. There were about ten other 4 girls with him. 5 Q. How did that meeting get 6 arranged? 7 A. Natalya arranged it, and 8 said she had spoken to Jeffrey and 9 Jeffrey wanted to meet me. 10 Q . A n d w h a t m o v i e d i d y o u s e e ? 11 A . I c a n ' t r e m e m b e r w h a t m o v i e 12 i t w a s . 13 Q . D i d y o u s i t w i t h h i m ? 14 A . Y e s , I d i d . 15 Q . N e x t t o h i m ? 16 A . I c a n ' t r e m e m b e r i f i t w a s 17 n e x t t o h i m , b u t I w a s c l o s e b y h i m . 18 Q . Y o u , N a t a l y a , t e n o t h e r 19 g i r l s a n d J e f f r e y ? 20 A . I d o n ' t k n o w i f i t w a s 21 e x a c t l y t e n , b u t t h e r e w e r e - - t h e r e 22 w e r e m a n y o t h e r g i r l s t h e r e . T h e r e 23 w a s l i k e a b i g g r o u p o f u s . 24 Q . A n d w h e r e w a s t h e t h e a t e r ? 25 A . I c a n ' t r e m e m b e r t h e e x a c t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 116 of 469 Highly Confidential Page 116 1 HIGHLY CONFIDENTIAL AEO 2 location, but it was quite a 3 prominent -- it was a big cinema. It 4 was like a huge -- like one of your 5 main cinemas. Somewhere -- is there a 6 cinema on Lexington, maybe? 7 I don't know. Sorry. 8 Navigation isn't in my strong points. 9 I'm going to stop speculating. I'm 10 s o r r y , o k a y ? I s a i d i t f o r y o u . I 11 d o n ' t k n o w . 12 Q . I t w a s s o m e w h e r e i n N e w 13 Y o r k ? 14 A . I t w a s i n N e w Y o r k . 15 Q . A n d y o u w e n t w i t h N a t a l y a ? 16 A . Y e s . 17 Q . H o w d i d y o u g o ? 18 A . B y c a b . 19 Q . F r o m y o u r a p a r t m e n t w i t h 20 C h r i s ? 21 A . Y e s . 22 Q . A n d t e l l m e a b o u t y o u r 23 e x p e r i e n c e a t t h e c i n e m a ? 24 A . I b o u g h t p o p c o r n a n d s w e e t s 25 a n d j u i c e , a n d I h a d a n a w e s o m e t i m e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 117 of 469 Highly Confidential Page 117 1 HIGHLY CONFIDENTIAL AEO 2 watching the movie with a bunch of new 3 people. 4 Q. And you do not remember the 5 name of the movie? 6 MR. GUIRGUIS: Objection. 7 A. No. 8 Q. And what happened after the 9 movie was over? 10 M R . G U I R G U I S : O b j e c t i o n . 11 A . I g o t i n a t a x i . 12 Q . A n d ? 13 M R . G U I R G U I S : O b j e c t i o n . 14 M S . M E N N I N G E R : W h a t ' s t h e 15 o b j e c t i o n ? 16 M R . G U I R G U I S : T h e q u e s t i o n 17 a n d , o b j e c t i o n t o f o r m . T h a t ' s a 18 g o o d o b j e c t i o n . 19 A . I w e n t h o m e . 20 Q . W h e n w a s t h e n e x t t i m e y o u 21 m e t J e f f r e y ? 22 A . I c a n ' t r e m e m b e r s p e c i f i c - - 23 I c a n ' t r e m e m b e r - - I t h i n k I m e t 24 h i m - - a g a i n , I ' m n o t t r y i n g t o 25 s p e c u l a t e . I t h i n k I m e t h i m i n N e w MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 118 of 469 Highly Confidential Page 118 1 HIGHLY CONFIDENTIAL AEO 2 York again. I can't remember that 3 meeting. I then met him again on his 4 private plane. 5 Q. So you believe the third 6 time you met him was on the private 7 plane? 8 A. That's correct. 9 Q. And do you remember anything 10 a b o u t t h e s e c o n d t i m e y o u m e t h i m ? 11 A . N o , I c a n ' t r e m e m b e r . 12 Q . A n d d o y o u k n o w h o w l o n g 13 a f t e r t h e f i r s t t i m e y o u m e t h i m t h e 14 s e c o n d t i m e w a s ? 15 A . P r e t t y s o o n a f t e r . 16 Q . W h a t d o e s t h a t m e a n t o y o u ? 17 A . C o u p l e d a y s . 18 Q . W h e r e d i d y o u m e e t h i m t h a t 19 s e c o n d t i m e ? 20 A . I n N e w Y o r k . 21 Q . W h e r e ? 22 A . I c a n ' t r e m e m b e r . 23 Q . A t h i s h o u s e ? 24 A . N o , i t w a s n ' t a t h i s h o u s e . 25 Q . W a s a n y o n e e l s e t h e r e t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 119 of 469 Highly Confidential Page 119 1 HIGHLY CONFIDENTIAL AEO 2 second time you met him? 3 A. Natalya. 4 Q. Anyone else? 5 A. No, not that I recall. 6 Q. Anything memorable about 7 that event? 8 A. Nothing, nothing memorable. 9 Q. Anything sexual happen at 10 t h e s e c o n d m e e t i n g ? 11 A . N o . 12 Q . A t t h e f i r s t m e e t i n g ? 13 A . N o . 14 Q . H o w d i d t h e f l i g h t m e e t i n g 15 b e c o m e a r r a n g e d , i f y o u k n o w ? 16 A . S o i t w a s p r e t t y a 17 l a s t - m i n u t e t h i n g . N a t a l y a p h o n e d m e 18 u p a n d s a i d t h a t J e f f r e y E p s t e i n w o u l d 19 v e r y m u c h l i k e t o h a v e m e g o t o h i s 20 i s l a n d . I t w a s g o i n g t o b e s o m u c h 21 f u n , i t w a s g o i n g t o b e a g i r l s ' w e e k , 22 t h e r e w e r e l o t s o f o t h e r g i r l s g o i n g , 23 w e w e r e g o i n g t o h a v e s o m u c h f u n , 24 e t c e t e r a , e t c e t e r a , e t c e t e r a . 25 Q . A n d w h a t d i d y o u d o ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 120 of 469 Highly Confidential Page 120 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection. 3 A. I went on the -- I went with 4 them to the island. 5 Q. Where was the plane located? 6 A. I can't remember the exact 7 airport. I think it was either Newark 8 or JFK. 9 Q. Did you fly commercially or 10 p r i v a t e ? 11 A . P r i v a t e . 12 Q . W a s i t J e f f r e y ' s p l a n e ? 13 A . Y e s . 14 Q . W h o e l s e w a s o n t h e p l a n e ? 15 A . N a d i a , N a t a l y a - - I w o u l d 16 l i k e t o s a y J e n , b u t I c a n ' t r e m e m b e r 17 h e r s p e c i f i c a l l y b e i n g t h e r e o n t h e 18 f i r s t t r i p , s o . . . N a t a l y a a n d N a d i a 19 w e r e d e f i n i t e l y t h e r e . 20 Q . H a d y o u m e t N a d i a b e f o r e ? 21 A . N o . 22 Q . A n d y o u d o n ' t r e m e m b e r 23 a n y o n e e l s e ? 24 A . N o , i t w a s - - I m e a n , t h e r e 25 w e r e a l w a y s n e w p e o p l e a r o u n d J e f f r e y MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 121 of 469 Highly Confidential Page 121 1 HIGHLY CONFIDENTIAL AEO 2 and Ghislaine, so I don't really -- 3 Q. Well, you just said and 4 Ghislaine. Was Ghislaine there? 5 A. No, not the first time. 6 Q. And do you recall what month 7 this was? 8 A. I can't remember what month 9 it was. 10 Q . I t w a s s o m e t i m e d u r i n g y o u r 11 f i r s t t h r e e - m o n t h p e r i o d ? 12 A . Y e a h , i t w a s w i t h i n t h a t 13 f i r s t t h r e e m o n t h s . 14 Q . S o s o m e t i m e b e t w e e n 15 S e p t e m b e r a n d D e c e m b e r ? 16 A . T h a t ' s c o r r e c t . 17 Q . A n d d i d y o u h a v e a c a m e r a 18 w i t h y o u w h e n y o u w e n t ? 19 A . I d i d . 20 Q . D i d y o u t a k e p i c t u r e s ? 21 A . I t o o k a c o u p l e . 22 Q . D e s c r i b e f o r m e w h a t 23 h a p p e n e d o n t h e p l a n e r i d e ? 24 A . N a d i a w a l k e d i n , s a t d o w n i n 25 f r o n t o f m e , N a t a l y . W e a l l b u c k l e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 122 of 469 Highly Confidential Page 122 1 HIGHLY CONFIDENTIAL AEO 2 up, we took off. 3 The rest of the passengers 4 in the -- I think it's towards the 5 front of the plane where all the seats 6 are -- we all -- all the guests 7 were -- fell asleep. I pretended to 8 be asleep. 9 Jeffrey then went -- Jeffrey 10 w e n t t o h i s - - w a s i n h i s b e d o n t h e 11 p l a n e , h a v i n g o p e n s e x w i t h N a d i a f o r 12 e v e r y o n e t o s e e , o n d i s p l a y . 13 Q . D i d y o u p a r t i c i p a t e i n t h a t 14 s e x a t a l l ? 15 A . N o , I d i d n ' t . 16 Q . D i d a n y o n e a s k y o u t o ? 17 A . N o . 18 Q . D i d y o u a n d N a t a l y a h a v e a n y 19 s e x u a l r e l a t i o n s h i p o n t h a t p l a n e , t h e 20 f i r s t p l a n e r i d e ? 21 A . N o . 22 Q . W e r e y o u s t i l l h a v i n g a n 23 o c c a s i o n a l s e x u a l r e l a t i o n s h i p w i t h 24 N a t a l y a a t t h a t t i m e ? 25 M S . M C C A W L E Y : O b j e c t i o n . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 123 of 469 Highly Confidential Page 123 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember. 3 Q. What types of sexual 4 relationship did Jeffrey and Nadia 5 have on the plane in your presence? 6 A. Well, Nadia was straddling 7 Jeffrey for quite some time. I 8 watched them both ejaculate with each 9 other. They were having quite a good 10 t i m e t o g e t h e r . 11 Q . H o w l o n g w a s t h e p l a n e r i d e ? 12 A . G o s h , a f e w h o u r s . F e w 13 h o u r s . 14 Q . D i d y o u s a y a n y t h i n g ? 15 A . N o . I w a s a g u e s t . I 16 t h o u g h t i t w o u l d b e q u i t e 17 i n a p p r o p r i a t e . 18 Q . A l l r i g h t . C a n i f I a s k y o u 19 i f y o u c o u l d j u s t d r a w a l a y o u t o f t h e 20 p l a n e ? 21 I ' m g o i n g t o r e a c h o v e r ? 22 J u s t k i n d o f d e s c r i b e w h e r e 23 e v e r y o n e w a s s i t t i n g a n d t h e b e d a r e a . 24 A . I d o n ' t r e m e m b e r i f i t w a s 25 t h e b a c k o r f r o n t . T h e f r o n t o f t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 124 of 469 Highly Confidential Page 124 1 HIGHLY CONFIDENTIAL AEO 2 plane, I think there was a round -- 3 there was, like, a round bed at the 4 back of the plane. 5 There was seating. Pilots 6 are there. Nadia walked in with her 7 Louis Vuitton handbag. She sat there 8 in front of me at the side of the 9 plane. So there was seating here. 10 Q . C a n y o u j u s t w r i t e N a d i a 11 n e x t t o t h a t - - 12 A . O k a y . 13 Q . - - s o I w i l l r e m e m b e r l a t e r . 14 A . N a d i a s a t t h e r e w h e n s h e 15 f i r s t w a l k e d i n . A n d I r e m e m b e r h e r 16 s p e c i f i c a l l y w i t h a L o u i s V u i t t o n 17 h a n d b a g t h a t s h e h a d , a b l a c k o n e . 18 Q . O k a y . A n d w h e r e w e r e y o u 19 s i t t i n g ? 20 A . I w a s s i t t i n g o p p o s i t e h e r . 21 A n d t h e n I t h i n k w e c h a n g e d p o s i t i o n s 22 o r t h e r e w a s - - I j u s t r e m e m b e r a t t h e 23 f r o n t , t h e r e w a s s e a t i n g h e r e , o k a y . 24 Q . W e l l , w h e r e w a s N a t a l y a 25 s i t t i n g ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 125 of 469 Highly Confidential Page 125 1 HIGHLY CONFIDENTIAL AEO 2 A. I don't remember where she 3 was sitting. 4 Q. Can you just put where the 5 other seats were, if you don't 6 remember who was in them? 7 A. I remember there was seating 8 here. I think there was -- I'm 9 speculating here, but I can't remember 10 i f t h e y w e r e s i t t i n g o n t h e - - o n t h e 11 o t h e r s i d e o f t h e p l a n e . I c a n ' t - - I 12 j u s t r e m e m b e r t h a t I s a t o n a s e a t i n 13 t h e f r o n t o f t h e p l a n e a n d t h e r e w e r e 14 p e o p l e o p p o s i t e m e . 15 Q . W h e n y o u s a y o p p o s i t e , d o 16 y o u m e a n i n f r o n t a n d b a c k o f y o u o r 17 a r e y o u s a y i n g t o y o u r s i d e s ? 18 A . I n f r o n t o f m e . 19 Q . O k a y . 20 A . S o i t ' s l i k e a s e a t i n g - - 21 Q . I s i t o n e s e a t i n a r o w ? 22 A . I c a n ' t r e m e m b e r t h e 23 s p e c i f i c l a y o u t o f t h e s e a t i n g o n t h e 24 a i r c r a f t , b u t I k n o w t h a t t h e r e ' s a 25 b i g , f a t , r o u n d o p e n - - t h e r e ' s a b e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 126 of 469 Highly Confidential Page 126 1 HIGHLY CONFIDENTIAL AEO 2 on the back of the plane -- 3 Q. Okay. 4 A. -- which there's no door, so 5 you can quite easily have sex and show 6 the whole plane. Which is how it's 7 designed, I'm guessing. 8 Q. Okay. 9 A. Because there's no privacy 10 a r o u n d t h e b e d . 11 Q . I u n d e r s t a n d . 12 C a n y o u j u s t d r a w w h e r e t h e 13 o t h e r s e a t s a r e , t h o u g h ? 14 M S . M C C A W L E Y : O b j e c t i o n , 15 a s k e d a n d a n s w e r e d . 16 A . I d o n ' t r e m e m b e r w h e r e t h e 17 o t h e r s e a t s a r e . I r e m e m b e r m e 18 s i t t i n g i n a s p e c i f i c a i r p l a n e s e a t a t 19 t h e b e g i n n i n g , y o u k n o w , a t t h e f r o n t 20 o f t h e p l a n e . I d o n ' t r e m e m b e r t h e 21 d e c o r o f t h e p l a n e . I r e m e m b e r t h e r e 22 w a s a b e d . I t w a s o p e n , i t w a s o p e n 23 p l a n . 24 Q . W e r e t h e r e b a t h r o o m s o n t h e 25 p l a n e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 127 of 469 Highly Confidential Page 127 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. Where were they? 4 A. I can't remember where the 5 bathrooms were located on the 6 aircraft. 7 Q. Do you know what kind of 8 plane it was? 9 A. It was a nice, big plane. 10 Y e a h , i t w a s a p l a n e . A p l a n e . 11 Q . H a d y o u b e e n o n a p r i v a t e 12 p l a n e b e f o r e ? 13 A . N o . 14 Q . D o y o u k n o w h o w m a n y p e o p l e 15 i t c a r r i e d ? 16 A . I j u s t k n o w i t ' s a p l a n e . 17 M S . M E N N I N G E R : C a n w e m a r k 18 t h a t . C a n y o u m a r k t h a t a s 19 D e f e n d a n t ' s E x h i b i t 1 . 20 M R . G U I R G U I S : H a v e y o u s e e n 21 i t b e f o r e y o u w a n t t o m a r k i t ? 22 T H E W I T N E S S : I t ' s r e a l l y 23 b a d . D o y o u w a n t m e t o r e d r a w 24 t h a t ? I t ' s r e a l l y e m b a r r a s s i n g . 25 I ' m n o t a n a r t i s t o r a n y t h i n g . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 128 of 469 Highly Confidential Page 128 1 HIGHLY CONFIDENTIAL AEO 2 It's really bad. 3 MR. GUIRGUIS: Just hand it 4 over. 5 (Defendant's Exhibit 1, 6 hand-drawn picture marked for 7 identification.) 8 Q. Was there a kitchen on the 9 plane that you recall? 10 A . I c a n ' t r e m e m b e r a n y , n o . 11 Q . W a s t h e r e a n o f f i c e a r e a ? 12 A . I c a n ' t r e m e m b e r t h e l a y o u t 13 o f t h e p l a n e . I r e m e m b e r t h e b e d . 14 T h e o n l y t h i n g I r e m e m b e r i s t h e 15 o p e n - p l a n b e d w h e r e I w a t c h e d N a d i a 16 a n d J e f f r e y h a v e s e x . 17 Q . A p a r t f r o m t h e L o u i s V u i t t o n 18 b a g , d o y o u r e m e m b e r w h a t N a d i a w a s 19 w e a r i n g ? 20 A . I j u s t r e m e m b e r s h e h a d a 21 b l a c k L o u i s V u i t t o n h a n d b a g . A n d I 22 d o n ' t r e m e m b e r w h a t s h e w a s w e a r i n g , 23 n o . B u t I r e m e m b e r t h e b l a c k h a n d b a g 24 b e c a u s e I l i k e d i t s o m u c h , I b o u g h t 25 t h e r e d - c o l o r e d v e r s i o n a f e w y e a r s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 129 of 469 Highly Confidential Page 129 1 HIGHLY CONFIDENTIAL AEO 2 later. It was really nice. 3 Q. How long did you stay on the 4 island during this first trip? 5 A. A few days. 6 Q. Was it a week or two days? 7 A. I can't remember. 8 Q. Apart from Nadia, Natalya, 9 Jeffrey and yourself, is there anyone 10 e l s e y o u r e c a l l b e i n g o n t h a t f i r s t 11 t r i p ? 12 M R . G U I R G U I S : O b j e c t i o n . 13 A . O n t h a t p a r t i c u l a r f i r s t 14 t r i p , I c a n ' t r e m e m b e r . I j u s t 15 r e m e m b e r N a d i a , N a t a l y a , J e f f r e y , 16 m y s e l f o n t h e f i r s t t r i p . 17 Q . W h e n y o u g o t t o t h e i s l a n d , 18 w a s t h e r e a n y o n e t h e r e ? 19 A . Y e s . T h e r e w a s a l o v e l y 20 c o u p l e f r o m Z i m b a b w e , s o m e w h e r e i n 21 A f r i c a . I t h i n k t h e y w e r e e i t h e r 22 S o u t h A f r i c a n o r f r o m Z i m b a b w e , b u t 23 t h e y w a s a l o v e l y m i d d l e - a g e c o u p l e . 24 C h e f , l i k e s t a f f , r e a l l y n i c e s t a f f o n 25 t h e i s l a n d . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 130 of 469 Highly Confidential Page 130 1 HIGHLY CONFIDENTIAL AEO 2 Q. Any other guests? 3 A. No, not that first trip. 4 Q. Did you engage in any sexual 5 acts with Jeffrey Epstein on your 6 first trip? 7 A. Yes. 8 Q. What happened? 9 MR. GUIRGUIS: Objection. 10 A . I t w a s - - I h a d t o g i v e h i m 11 a m a s s a g e i n h i s b e d r o o m . 12 Q . A n d h o w d i d t h a t c o m e a b o u t ? 13 A . S o t h e e n t i r e b a s i c s w e r e 14 e x p l a i n e d t o m e , t h e r e ' s t h i s w e a l t h y 15 d u d e , t h i s p h i l a n t h r o p i s t , l o v e s 16 w o m e n , l o v e s g e t t i n g m a s s a g e s . A n d 17 t h i s w a s a n i c e w a y t o m a k e e x t r a 18 c a s h , w h i c h i s g r e a t . 19 I g o t t o t h e i s l a n d - - o h , I 20 w a s m a d e t o m a s s a g e J e f f r e y o n t h e 21 p l a n e . S o r r y . T h a t ' s w h e r e I g a v e m y 22 f i r s t m a s s a g e t o J e f f r e y . 23 S o m y f i r s t m a s s a g e s t a r t e d 24 w i t h h i m o n t h e p l a n e , w i t h h i s f e e t 25 a n d h i s h a n d s . A n d o n t h a t t r i p I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 131 of 469 Highly Confidential Page 131 1 HIGHLY CONFIDENTIAL AEO 2 was -- I had to give him other 3 massages, like legs, arms, feet, 4 hands, head, shoulders. And it wasn't 5 straight away, but they got more 6 sexual. Then I was called to his 7 bedroom. 8 Q. Okay. I just want to make 9 sure we're talking about the same time 10 f r a m e . 11 T h e r e w a s a m a s s a g e y o u g a v e 12 o n t h e p l a n e o n t h e w a y d o w n t h e r e ? 13 A . Y e s . 14 Q . T h a t w a s n o t s e x u a l ? 15 A . T h a t w a s n o t s e x u a l , n o . 16 Q . W a s t h a t b e f o r e o r a f t e r h e 17 w a s h a v i n g s e x w i t h N a d i a i n t h e o p e n 18 b e d i n t h e p l a n e a r e a ? 19 A . I t w a s b e f o r e . I t w a s 20 b e f o r e t h e y h a d s e x , b e c a u s e w e a l l 21 f e l l a s l e e p . 22 Q . O k a y . A n d t h e n h o w d i d t h e 23 m a s s a g e c o m e a b o u t ? 24 A . O n t h e i s l a n d o r - - 25 Q . N o , o n t h e p l a n e . J u s t o n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 132 of 469 Highly Confidential Page 132 1 HIGHLY CONFIDENTIAL AEO 2 the plane. 3 A. Jeffrey asked me to massage 4 him. 5 Q. So you were asleep and 6 Jeffrey woke you up? 7 MS. MCCAWLEY: Objection. 8 A. When we first got on the 9 plane, we sat down. You know, like 10 w h e n y o u f i r s t g e t o n a n a i r p l a n e , y o u 11 s e t t l e i n a n d c h a t , c h a t , c h a t . A n d I 12 m a s s a g e d h i m , a n d t h e n i t w a s a f t e r 13 t h a t w e f i n d o f a l l f e l l a s l e e p . A n d 14 t h e n I w o k e u p a n d I s a w J e f f r e y a n d 15 N a d i a . 16 Q . O k a y . 17 A . S o i n t h a t e f f e c t , I w a s 18 p r o b a b l y s i t t i n g - - I w a s f a c i n g t h e 19 b e d . 20 Q . Y o u w e r e r e a r - f a c i n g ? 21 A . Y e a h . 22 Q . C a n I j u s t h a n d y o u b a c k 23 D e f e n d a n t ' s E x h i b i t 1 . I s i t s t i l l , 24 i n y o u r r e c o l l e c t i o n , t h e s a m e p l a c e ? 25 A . Y e a h . W e s w i t c h e d s e a t s a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 133 of 469 Highly Confidential Page 133 1 HIGHLY CONFIDENTIAL AEO 2 few times. 3 Q. So where was Jeffrey when 4 you gave him the massage on the 5 airplane? 6 A. He was -- he was seated at 7 the front. 8 Q. In front of where you were? 9 A. We weren't really all seated 10 t h r o u g h o u t t h e e n t i r e d u r a t i o n o f t h e 11 f l i g h t . S o a s s o o n a s t h e f l i g h t t o o k 12 u p , w e t o o k o u r s e a t b e l t s o f f a n d 13 k i n d o f m o v e d a r o u n d f r e e l y , b e c a u s e 14 i t ' s n o t a c o m m e r c i a l f l i g h t . Y o u c a n 15 d o t h a t o n p r i v a t e p l a n e s . S o w e 16 w e r e n ' t i n o u r s e a t s t h e w h o l e t i m e . 17 T h e r e w a s a l o t o f m o v i n g a r o u n d . 18 Q . O k a y . C a n y o u j u s t d r a w o n 19 D e f e n d a n t ' s E x h i b i t 1 w h e r e h e w a s 20 w h e n y o u g a v e h i m t h e m a s s a g e ? 21 A . I c a n ' t r e m e m b e r w h e r e 22 s p e c i f i c a l l y o n w h a t s e a t o r w h e r e I 23 w a s f a c i n g t h a t I g a v e J e f f r e y h i s 24 m a s s a g e , s o I ' m n o t c o m f o r t a b l e 25 p u t t i n g s o m e t h i n g b e c a u s e t h a t ' s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 134 of 469 Highly Confidential Page 134 1 HIGHLY CONFIDENTIAL AEO 2 speculating. 3 Q. Do you have a general area 4 at all? Was it in the front area? 5 A. The general area -- the 6 general area here is at the front of 7 the plane, and then the bed at the 8 back of the plane. 9 Q. So which of those two 10 g e n e r a l a r e a s w a s t h e m a s s a g e ? 11 A . S o t h e m a s s a g e w a s a t t h e 12 f r o n t , b e c a u s e I d i d n ' t g i v e h i m i t o n 13 t h e b e d ; i t w a s i n t h e f r o n t o f t h e 14 p l a n e . I d o n ' t r e m e m b e r w h a t s p e c i f i c 15 s e a t p l a n I g a v e h i m a m a s s a g e . 16 Q . W a s h e w e a r i n g c l o t h e s ? 17 A . Y e s . 18 Q . D u r i n g t h e w h o l e m a s s a g e ? 19 A . D u r i n g t h e w h o l e m a s s a g e , 20 y e s . 21 Q . W h a t w a s h e w e a r i n g ? 22 A . I d o n ' t r e m e m b e r . 23 Q . D i d h e h a v e o n s h o e s ? 24 A . Y e s , h e h a d o n s h o e s w h e n h e 25 w a l k e d o n t o t h e p l a n e . B u t t h e n h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 135 of 469 Highly Confidential Page 135 1 HIGHLY CONFIDENTIAL AEO 2 took his shoes off to have the 3 massage. 4 Q. And do you recall what he 5 said when he asked you to give him a 6 massage? 7 A. Yes. He asked me to massage 8 his feet and massage him. 9 Q. Were you surprised by that 10 r e q u e s t ? 11 A . N o . 12 Q . W h y n o t ? 13 A . B e c a u s e N a t a l y a t o l d m e t h a t 14 h e l i k e d g e t t i n g m a s s a g e s f r o m g i r l s 15 a n d t h a t h e p a i d f o r t h e m . 16 Q . D i d h e p a y y o u f o r t h a t 17 m a s s a g e o n t h e p l a n e ? 18 A . N o . 19 Q . D i d y o u e x p e c t h i m t o ? 20 A . W e l l i t w a s a - - i t w a s t h e 21 b e g i n n i n g o f t h e t r i p , s o I ' m h a r d l y 22 g o i n g t o g o , I d o n ' t r e a l l y k n o w y o u . 23 C a n y o u p l e a s e p a y m e . I t ' s n o t 24 s o m e t h i n g y o u r e a l l y d i s c u s s , I d o n ' t 25 t h i n k . I t ' s n o t r e a l l y a p p r o p r i a t e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 136 of 469 Highly Confidential Page 136 1 HIGHLY CONFIDENTIAL AEO 2 It's not very businesslike. 3 Q. And you were clothed during 4 the massage on the plane? 5 A. Yes. 6 Q. Where was the second 7 massage? 8 A. On his island. 9 Q. Where on the island? 10 A . S o t h e s e c o n d t i m e I 11 m a s s a g e d h i m w a s p r o b a b l y o n - - i t 12 w a s - - I w a s t h e n a s k e d t o m a s s a g e h i m 13 a g a i n l a t e r t h a t d a y , t o m a s s a g e h i m 14 a g a i n i n t h e o p e n - p l a n n e d s e a t i n g a r e a 15 o n t h e i s l a n d . 16 Q . W h o a s k e d y o u t o d o t h a t ? 17 A . S a r a h K e l l e n . 18 Q . S o S a r a h K e l l e n w a s o n t h e 19 i s l a n d ? 20 A . Y e s . 21 Q . D i d s h e t r a v e l w i t h y o u ? 22 A . N o t a l l - - I c a n ' t r e m e m b e r 23 s p e c i f i c a l l y w h o t r a v e l i n g - - I c a n ' t 24 s a y t h a t I a h u n d r e d p e r c e n t r e m e m b e r 25 h e r t h e r e o n t h a t f i r s t f l i g h t . I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 137 of 469 Highly Confidential Page 137 1 HIGHLY CONFIDENTIAL AEO 2 don't -- I can't visually see her 3 there. But I know that she traveled 4 with us pretty much every time with 5 Jeffrey. She traveled everywhere with 6 Jeffrey. 7 Q. How many times did you go to 8 the island? 9 A. Several. 10 Q . H o w m a n y ? 11 A . S e v e r a l . S e v e r a l t i m e s . 12 T h e r e w e r e m u l t i p l e o c c a s i o n s t h a t I 13 w e n t t o t h e i s l a n d . 14 Q . T h r e e t i m e s ? 15 A . S e v e r a l . S e v e r a l . I c a n ' t 16 r e m e m b e r h o w m a n y t i m e s s p e c i f i c a l l y . 17 Q . I u n d e r s t a n d y o u d o n ' t h a v e 18 a s p e c i f i c a n s w e r . 19 A . Y e a h . 20 Q . D o y o u b e l i e v e i t w a s m o r e 21 t h a n t e n t i m e s ? 22 A . I d o n ' t t h i n k i t w a s a s m u c h 23 a s t e n t i m e s , n o . M a y b e a l i t t l e b i t 24 l e s s , b u t n o t t h a t m a n y . 25 Q . D o y o u k n o w h o w m a n y t i m e s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 138 of 469 Highly Confidential Page 138 1 HIGHLY CONFIDENTIAL AEO 2 you went on the private plane versus a 3 commercial plane? 4 A. I flew both, so I can't 5 remember how many times I did 6 commercial, how many times I did 7 private. I mean, it was -- I know 8 that I did fly commercially at some 9 times when the plane wasn't available. 10 Q . A n d t h e t o t a l n u m b e r o f 11 t r i p s t o t h e i s l a n d y o u t h i n k w a s l e s s 12 t h a n t e n t i m e s ? 13 M R . G U I R G U I S : O b j e c t i o n . 14 A . T h e r e w a s s e v e r a l t i m e s . 15 I ' m n o t s u r e i f i t w a s m o r e t h a n t e n . 16 I d o n ' t k n o w t h e a c c u r a t e n u m b e r . I t 17 w a s s e v e r a l t i m e s . 18 Q . D i d y o u g o t h r o u g h a n y t y p e 19 o f p a s s p o r t c o n t r o l w h e n y o u w e n t t o 20 t h e i s l a n d a t a l l ? 21 A . N o , t h e y d i d n ' t c h e c k 22 p a s s p o r t s . 23 Q . H o w d i d y o u g e t f r o m w h e r e 24 t h e p l a n e l a n d e d t o t h e i s l a n d ? 25 A . J e f f r e y ' s s p e e d b o a t . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 139 of 469 Highly Confidential Page 139 1 HIGHLY CONFIDENTIAL AEO 2 Q. Was that the only method? 3 A. Also a helicopter. 4 Q. Who flew the helicopter? 5 A. I don't -- a guy. 6 Q. Was he cute? 7 MR. GUIRGUIS: Objection. 8 A. I don't remember. 9 MR. GUIRGUIS: Objection, 10 a n d I d i r e c t t h e w i t n e s s n o t t o 11 a n s w e r . 12 M S . M E N N I N G E R : I ' m l e a r n i n g 13 a b o u t s u p e r y a c h t i n g . I t h o u g h t I 14 w o u l d f i n d o u t a b o u t t h e 15 h e l i c o p t e r . 16 M R . G U I R G U I S : I t h o u g h t y o u 17 w e r e g o i n g t o a s k i f h e w a s 18 t a l l e r t h a n 6 f e e t o r l e s s t h a n 6 19 f e e t . I t h o u g h t t h a t w a s t h e 20 n e x t s e r i e s o f q u e s t i o n s . 21 Q . S o y o u s a i d t h e s e c o n d 22 m a s s a g e y o u g a v e J e f f r e y w a s o n t h e 23 i s l a n d t h e s a m e d a y y o u f l e w d o w n 24 t h e r e t h e f i r s t t i m e ? 25 A . Y e s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 140 of 469 Highly Confidential Page 140 1 HIGHLY CONFIDENTIAL AEO 2 Q. And it was in the open-plan 3 area? 4 A. Yes. 5 Q. And you recall Sarah Kellen 6 being the one to ask you to give the 7 message? 8 A. We were all sitting there 9 socially. Jeffrey asked me. And that 10 w a s n ' t a s e x u a l m a s s a g e i n t h e s e a t i n g 11 a r e a o n t h e i s l a n d , t h e s e c o n d 12 m a s s a g e . H e w a s s t i l l t r a i n i n g m e t o 13 m a s s a g e , s o m y s t a n d a r d s w e r e n ' t q u i t e 14 h i g h e n o u g h . 15 Q . H o w d i d h e t r a i n y o u t o 16 m a s s a g e h i m ? 17 A . H e l e t t h e g i r l s m a s s a g e m e 18 i n f r o n t o f h i m . H e s h o w e d m e h o w 19 t o - - b e c a u s e h i s b o d y ' s f u l l o f 20 k n o t s , s o - - a n d h e l i k e s h i s m a s s a g e 21 r e a l l y h a r d . S o w h e n y o u r e a l l y p u s h 22 o n t h o s e k n o t s t h a t h e h a s , y o u h a v e 23 t o b e q u i t e f i r m w i t h h i m . 24 Q . S o h e t o l d y o u w h a t h e 25 l i k e d ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 141 of 469 Highly Confidential Page 141 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes, yeah. And some of the 3 other girls -- sorry. Natalya showed 4 me how he like his massages. 5 Q. Was he clothed during the 6 second massage? 7 A. Yes. 8 Q. Were you clothed? 9 A. Yes. 10 Q . D i d a n y s e x u a l c o n t a c t o c c u r 11 o n t h e s e c o n d m a s s a g e ? 12 A . N o . 13 Q . W h e n d o y o u r e c a l l t h e r e 14 b e i n g a t h i r d m a s s a g e ? 15 A . T h e n e x t d a y . 16 Q . A n d w h a t h a p p e n e d t h a t g a v e 17 r i s e t o t h e t h i r d m a s s a g e ? 18 A . I w a s c a l l e d t o J e f f r e y ' s 19 b e d r o o m t o m a s s a g e h i m . 20 Q . W h o c a l l e d y o u ? 21 A . I ' m - - I d o n ' t w a n t t o 22 s p e c u l a t e , s o I c a n ' t r e m e m b e r 23 s p e c i f i c a l l y w h o c a l l e d m e . 24 Q . O k a y . S o s o m e t h i r d p e r s o n 25 y o u d o n ' t r e c a l l - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 142 of 469 Highly Confidential Page 142 1 HIGHLY CONFIDENTIAL AEO 2 A. It was a female. It was 3 either Sarah Kellen or Natalya, so I 4 can't remember which of the two that 5 called me, because they called me many 6 times during the duration of my trip. 7 Q. So when you say called me, 8 what does that mean? 9 A. They come up to me and say, 10 p l e a s e g o t o J e f f r e y ' s b e d r o o m a n d 11 m a s s a g e J e f f r e y . H e i s w a i t i n g f o r 12 y o u . 13 Q . W h a t t i m e o f d a y w a s i t ? 14 A . I t h i n k i t w a s - - I c a n ' t 15 r e m e m b e r w h a t s p e c i f i c t i m e o f d a y i t 16 w a s . 17 Q . C a n y o u k i n d o f d e s c r i b e t h e 18 i s l a n d f o r m e . W e r e t h e r e m o r e t h a n 19 o n e b u i l d i n g o n i t ? 20 A . Y e a h , t h e r e w e r e m u l t i p l e 21 b u i l d i n g s . Y o u h a d t h e m a i n h o u s e . 22 Y o u h a d c e r t a i n a c c o m m o d a t i o n a r e a s 23 w h e r e t h e g i r l s s i t . 24 T h e r e w e r e v a r i o u s b u i l d i n g s 25 a r o u n d t h e i s l a n d w h e r e h e u s e d t o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 143 of 469 Highly Confidential Page 143 1 HIGHLY CONFIDENTIAL AEO 2 have all -- him and his other guests, 3 like beds and beds, like little 4 shelter things where him and his 5 guests used to have sex with the 6 girls, like beds set up for instant 7 sexual entertainment. So -- 8 Q. On a beach area? 9 A. All over the island. All 10 o v e r t h e i s l a n d . S o i f y o u g o o n o n e 11 o f h i s q u a d b i k e s a n d d o a t o u r o f h i s 12 i s l a n d , w h i c h I ' m s u r e y o u g u y s h a v e 13 d o n e , y o u w i l l s e e m u l t i p l e b u i l d i n g s 14 a r o u n d t h e i s l a n d . 15 Q . A n d w h e r e w e r e y o u s t a y i n g 16 d u r i n g t h i s f i r s t t r i p ? 17 A . I w a s s t a y i n g i n o n e o f t h e 18 g u e s t h o u s e s t h a t N a t a l y a - - t h e m a i n 19 g u e s t h o u s e t h a t a l l t h e g i r l s s h a r e d . 20 Q . W e r e y o u s t a y i n g i n y o u r o w n 21 r o o m ? 22 A . N o . 23 Q . W h o w e r e y o u s h a r i n g a r o o m 24 w i t h ? 25 A . N a t a l y a . I t h i n k N a d i a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 144 of 469 Highly Confidential Page 144 1 HIGHLY CONFIDENTIAL AEO 2 slept in the bungalow; she didn't stay 3 there per se. She was explained to be 4 Jeffrey Epstein's girlfriend at the 5 time. 6 Q. When you were asked to give 7 Jeffrey a massage on the third 8 occasion by a female, do you recall 9 what words were used? 10 A . I c a n ' t r e m e m b e r t h e e x a c t 11 w o r d s , n o . B u t I w a s - - i t w a s 12 g e n e r a l l y - - i t w a s , c a n y o u p l e a s e g o 13 a n d g i v e J e f f r e y - - i t ' s k i n d o f l i k e 14 y o u r t u r n t y p e o f t h i n g . 15 Q . D i d y o u k n o w w h e r e h i s 16 b e d r o o m w a s ? 17 A . I w a s s h o w n t o h i s b e d r o o m . 18 Q . W h o s h o w e d y o u t o h i s 19 b e d r o o m ? 20 A . I c a n ' t r e m e m b e r w h o s h o w e d 21 m e t o h i s b e d r o o m . 22 Q . A l l r i g h t . T e l l m e w h a t 23 h a p p e n e d d u r i n g t h e t h i r d m a s s a g e ? 24 A . S o I w e n t i n t o J e f f r e y 25 E p s t e i n ' s b e d r o o m . H i s b e d r o o m i s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 145 of 469 Highly Confidential Page 145 1 HIGHLY CONFIDENTIAL AEO 2 ice-cold; it's always ice-cold. He 3 likes his bedrooms very well air 4 conditioned. 5 There was a massage table 6 laid out in his bedroom. He asked me 7 to undress and that he wanted to give 8 me a massage, and he asked me to lay 9 on the table. He then started 10 t o u c h i n g m y b o d y . 11 I w a s - - I w a s - - i t d i d n ' t 12 s t a r t o f f a s a s e x u a l m a s s a g e ; i t w a s 13 j u s t - - y o u k n o w , i t w a s j u s t d o i n g a 14 n o r m a l m a s s a g e , a n d t h e n h e s t a r t e d t o 15 t o u c h m e . H e t o u c h e d m y v a g i n a l 16 r e g i o n a n d h e t o u c h e d m e a l l o v e r . 17 Q . W e r e y o u d r a p e d w i t h a 18 t o w e l ? 19 A . N o . 20 Q . F o r n o p a r t o f t h e m a s s a g e ? 21 A . F o r t h e - - I c a n ' t r e m e m b e r . 22 Q . W a s a n y o n e e l s e p r e s e n t i n 23 t h e r o o m ? 24 A . N o . 25 Q . A n d a f t e r h e s t a r t e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 146 of 469 Highly Confidential Page 146 1 HIGHLY CONFIDENTIAL AEO 2 touching you while you were on the 3 table, did you give him a massage? 4 A. I can't remember the 5 specific sequence of events, but I 6 remember the third massage, it wasn't 7 for Jeffrey; it was for me. He 8 performed the massage on me. 9 Q. Did you tell him to stop? 10 A . N o , I d i d n ' t . 11 Q . D i d y o u h a v e a n y s e x u a l 12 c o n t a c t w i t h h i m ? 13 A . N o , h e j u s t t o u c h e d m e . A n d 14 h e w a s t o u c h i n g h i m s e l f t o o , s o . . . 15 Q . D i d y o u h a v e a n o r g a s m ? 16 A . I d i d h a v e a n o r g a s m . H e 17 u s e d a s p e c i f i c v i b r a t o r o n m e , w h i c h 18 i t w a s q u i t e h a r d n o t t o . 19 Q . C a n y o u d e s c r i b e i t ? 20 A . Y e a h . I t ' s q u i t e b i g . I t ' s 21 n o t a n a c t u a l v i b r a t o r . I t ' s r e a l l y 22 g o o d ; y o u s h o u l d g e t o n e i f y o u d o n ' t . 23 T H E W I T N E S S : S o r r y . I ' m 24 a l l o w e d t o t a l k . O k a y . S o r r y . 25 A . I t ' s - - I ' l l - - c a n I d r a w MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 147 of 469 Highly Confidential Page 147 1 HIGHLY CONFIDENTIAL AEO 2 it? Can I draw it? I'll draw you the 3 exact -- I can actually get you -- I 4 actually own one, so I can get you a 5 photo of it, you know. It's also in 6 the pictures in the dentist chair, in 7 one of the photos, so... 8 It's like this. 9 THE WITNESS: I'm sorry. 10 M R . G U I R G U I S : Y o u ' r e f i n e . 11 M S . M C C A W L E Y : Y o u ' r e f i n e . 12 A . S o i t ' s a c t u a l l y a m a s s a g e r 13 f o r s h o u l d e r s . I t ' s g o t a l o n g b a s e . 14 I t ' s g o t q u i t e a - - i t ' s g o t l i k e a 15 r u b b e r w h i t e h e a d . 16 A n d , y e a h , i t w a s r e a l l y - - 17 i t ' s n o t - - i t ' s n o t u s e d f o r s e x u a l 18 p u r p o s e s . 19 Q . I t ' s n o t ? 20 A . N o , t h a t ' s w h a t I ' m s a y i n g . 21 I t ' s n o t a v i b r a t o r . 22 Q . O k a y . 23 A . I t w a s a c t u a l l y q u i t e 24 p a i n f u l f o r m e - - 25 Q . O k a y . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 148 of 469 Highly Confidential Page 148 1 HIGHLY CONFIDENTIAL AEO 2 A. -- actually. 3 Q. Okay. Did you tell him to 4 stop? 5 A. I told him to stop when 6 he -- because he pressed the vibrator 7 head on my clitoris and it was 8 incredibly painful. It hurt me. 9 That's a very sensitive area, and the 10 s t r e n g t h o f t h i s s p e c i f i c d e v i c e h e 11 u s e d i s - - i t ' s n o t r e a l l y m e a n t f o r 12 t h a t . 13 Q . R i g h t . D i d h e s t o p w h e n y o u 14 s a i d s t o p ? 15 A . N o . 16 Q . A n d h o w l o n g d i d t h i s 17 m a s s a g e - - 18 A . U n t i l - - u n t i l I o r g a s m e d . 19 Q . A n d t h e n w h a t h a p p e n e d ? 20 A . H e j u s t s t o p p e d . A n d I g o t 21 d r e s s e d a n d I l e f t . 22 Q . W a s t h e r e a n y d i s c u s s i o n ? 23 A . N o . 24 Q . D i d h e g i v e y o u a n y m o n e y ? 25 A . N o . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 149 of 469 Highly Confidential Page 149 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Can we stop 3 for a moment? The witness is 4 crying. I think maybe we should 5 take a moment, have a moment. 6 MS. MENNINGER: Okay. Mark 7 that as Defendant's Exhibit 2, 8 and then we'll take a break for 9 ten minutes. 10 ( D e f e n d a n t ' s E x h i b i t 2 , 11 h a n d - d r a w n p i c t u r e , w a s m a r k e d 12 f o r i d e n t i f i c a t i o n . ) 13 ( T i m e n o t e d : 1 2 : 0 7 p . m . ) 14 ( R e c e s s . ) 15 ( T i m e n o t e d : 1 2 : 1 9 p . m . ) 16 Q . S o y o u j u s t d e s c r i b e d f o r 17 u s , I t h i n k , w h a t y o u r e c a l l b e i n g t h e 18 t h i r d m a s s a g e w i t h J e f f r e y ? 19 A . Y e a h . 20 Q . D o y o u r e c a l l t h e n e x t o n e 21 a f t e r t h a t ? 22 A . I t w a s - - i t w a s b a s i c a l l y 23 t h e s a m e . I w a s c a l l e d t o g i v e 24 J e f f r e y m a s s a g e s . 25 Q . D u r i n g t h a t f i r s t t r i p t o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 150 of 469 Highly Confidential Page 150 1 HIGHLY CONFIDENTIAL AEO 2 the island? 3 A. During the first trip, yeah. 4 Q. Can you approximate how many 5 massages you gave to him during that 6 first trip? 7 A. I would give him up to maybe 8 two a day. The other girls, they had 9 to also give him massages during that 10 t r i p . 11 Q . A n d y o u d o n ' t r e m e m b e r h o w 12 m a n y d a y s t h a t t r i p w a s ? 13 A . N o , n o t s p e c i f i c a l l y h o w 14 m a n y . I t w a s a f e w d a y s . I t w a s a 15 f e w d a y s . 16 Q . A t s o m e p o i n t d i d t h e 17 m a s s a g e s b e c o m e d i f f e r e n t t h a n t h e o n e 18 y o u j u s t d e s c r i b e d a s t h e t h i r d 19 m a s s a g e ? 20 A . I t w a s e i t h e r J e f f r e y l y i n g 21 o n t h e m a s s a g e - - m e m a s s a g i n g h i m a n d 22 i t t u r n i n g s e x u a l o r v i c e v e r s a . 23 P r e t t y m u c h f r o m t h e t h i r d s e x u a l 24 m a s s a g e I h a d w i t h J e f f r e y , a l l o t h e r 25 m a s s a g e s w e r e s e x u a l . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 151 of 469 Highly Confidential Page 151 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you recall who was on the 3 flight home from the first trip? 4 A. I don't recall who was on 5 the flight home. I think it was all 6 the people that were on the first 7 flight there. 8 Q. Did you receive any 9 compensation from Jeffrey during that 10 f i r s t t r i p ? 11 A . I r e c e i v e d l i k e $ 3 0 0 o r 12 s o m e t h i n g . N o t a l o t . 13 Q . W h e n d i d y o u g e t t h a t ? 14 A . A t t h e e n d o f t h e t r i p . 15 Q . H o w w a s i t g i v e n t o y o u ? 16 A . I n c a s h . 17 Q . B y w h o m ? 18 A . T h a t s p e c i f i c t i m e i t w a s 19 J e f f r e y . 20 Q . W h e r e w e r e y o u w h e n h e g a v e 21 t h a t y o u m o n e y ? 22 A . I c a n ' t r e c a l l w h e r e I w a s 23 w h e n h e g a v e m e t h e c a s h . 24 Q . D i d - - w e r e y o u s t i l l w i t h 25 t h e o t h e r f e m a l e s t h a t h a d b e e n o n t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 152 of 469 Highly Confidential Page 152 1 HIGHLY CONFIDENTIAL AEO 2 plane? 3 A. When he gave me the cash? 4 Q. Yes. 5 A. I can't recall. I don't 6 remember if someone was with me. But 7 we all knew that we were going to get 8 cash. 9 Q. Did you see him give cash to 10 a n y o n e e l s e ? 11 A . I s a w h i m g i v e c a s h t o 12 N a t a l y a . 13 Q . H o w m u c h d i d h e g i v e h e r , i f 14 y o u k n o w ? 15 A . I d o n ' t k n o w . 16 Q . D i d y o u s e e N a t a l y a h a v i n g 17 a n y t y p e o f s e x u a l r e l a t i o n s w i t h 18 J e f f r e y d u r i n g t h e t r i p ? 19 A . Y e s , I d i d . 20 Q . W h e n d i d y o u s e e t h a t ? 21 A . I d i d n ' t s e e i t i n t h e 22 b e d r o o m , b u t w e w e r e c a l l e d o n , l i k e , 23 a r o t a t i o n v i s i t f o r J e f f r e y 24 t h r o u g h o u t t h e d a y a n d e v e n i n g . 25 Q . W h e n d i d y o u s e e N a t a l y a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 153 of 469 Highly Confidential Page 153 1 HIGHLY CONFIDENTIAL AEO 2 having some type of sexual 3 relationship with Jeffrey on the 4 island during the first trip? 5 A. I didn't see her perform 6 sexual acts on Jeffrey. 7 Q. Did anyone see you 8 performing sexual acts on Jeffrey 9 during the first trip to the island? 10 A . N o . 11 Q . D i d y o u t e l l a n y o f t h e s e 12 o t h e r w o m e n a b o u t w h a t w a s g o i n g o n 13 d u r i n g y o u r m a s s a g e s w i t h J e f f r e y ? 14 A . Y e s . 15 Q . W h o d i d y o u t e l l ? 16 A . A l l t h e g i r l s t h a t w e r e 17 t h e r e . 18 Q . A n d , a g a i n , t h a t i s N a t a l y a , 19 N a d i a a n d J e n ? 20 M R . G U I R G U I S : O b j e c t i o n . 21 Q . D o y o u r e m e m b e r ? 22 A . I c a n ' t s a y s p e c i f i c a l l y i f 23 J e n w a s t h e r e . I c a n ' t r e m e m b e r J e n 24 b e i n g t h e r e , s o I d o n ' t l i k e t o b r i n g 25 J e n i n t o t h e f i r s t t r i p . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 154 of 469 Highly Confidential Page 154 1 HIGHLY CONFIDENTIAL AEO 2 I saw her multiple times on 3 the island, but I can't specifically 4 place her there on the first trip. I 5 just remember the key people that were 6 there because they were the most vivid 7 in my memory. 8 Q. Do you know if you took any 9 pictures during that first trip? 10 A . I d o n ' t t h i n k d u r i n g t h a t 11 f i r s t t r i p , n o . W e w e r e n ' t a c t u a l l y 12 a l l o w e d t o b r i n g a n y e l e c t r o n i c 13 d e v i c e s w i t h u s . 14 Q . H o w d i d y o u l e a r n t h a t r u l e ? 15 A . N a t a l y a t o l d m e a n d t h e 16 o t h e r g i r l s t o l d m e . 17 Q . W h o a r e t h e o t h e r g i r l s ? 18 A . J e n . 19 Q . D i d y o u t a k e a c a m e r a t o t h e 20 i s l a n d ? 21 A . N o t t h e f i r s t t i m e , n o . 22 Q . D i d y o u h a v e a d i g i t a l 23 c a m e r a a t t h e t i m e ? 24 A . Y e s , I d i d . 25 Q . W h a t k i n d ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 155 of 469 Highly Confidential Page 155 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember. 3 Q. Did you have a phone with a 4 camera on it? 5 A. I had a BlackBerry, yes, 6 which you could take photos on. 7 Q. All right. Do you recall 8 there being any sexual acts performed 9 on the plane on the ride home during 10 t h e f i r s t t r i p ? 11 A . N o . 12 Q . O k a y . D o y o u r e c a l l g o i n g 13 d o w n a s e c o n d t i m e ? 14 A . T o t h e i s l a n d ? 15 Q . Y e s . 16 A . Y e s . 17 Q . W h e n d i d t h a t h a p p e n ? 18 A . S h o r t l y . I c a n ' t r e m e m b e r 19 s p e c i f i c a l l y w h e n i t w a s , b u t i t 20 w a s n ' t o n - - I d o n ' t k n o w t h e t i m e 21 l e n g t h . I s a w J e f f r e y a n d G h i s l a i n e 22 a n d t h e c r o w d q u i t e a l o t i n N e w Y o r k 23 a s w e l l , s o i t ' s n o t c l e a r t o m e w h e n 24 t h e s e c o n d t r i p w a s . 25 Q . W h e n w a s t h e f i r s t t i m e y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 156 of 469 Highly Confidential Page 156 1 HIGHLY CONFIDENTIAL AEO 2 met Ghislaine? 3 A. I'd been to the island a 4 couple times before, and then I met 5 Ghislaine on the island. 6 Q. Tell me about your meeting 7 with her? 8 A. I remember being told by 9 everyone before she arrived who she 10 w a s . A n d I w a s p r e t t y m u c h t o l d t h e 11 t y p e o f p e r s o n s h e w a s a n d t h a t I h a d 12 t o d o e v e r y t h i n g s h e t o l d m e t o d o . 13 Q . W h o t o l d t h a t y o u ? 14 A . N a d i a , S a r a h K e l l e n , 15 N a t a l y a , J e n . E v e r y s i n g l e g i r l t h a t 16 I c a m e i n c o m m u n i c a t i o n w i t h t o l d m e 17 t h a t . 18 Q . A n d w h a t t y p e o f p e r s o n d i d 19 t h e y t e l l y o u t h a t s h e w a s ? 20 A . S h e ' s i n c r e d i b l y 21 i n t i m i d a t i n g . S h e ' s n o t s o m e o n e y o u 22 w a n t t o b e s t u c k i n a n a l l e y a t n i g h t , 23 p u t i t t h a t w a y . S h e ' s a v e r y 24 d a n g e r o u s c h a r a c t e r a n d h a s 25 c o n n e c t i o n s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 157 of 469 Highly Confidential Page 157 1 HIGHLY CONFIDENTIAL AEO 2 Q. And that was communicated to 3 you by this group of females: Nadia, 4 Sarah, Natalya and Jen? 5 A. Yes. 6 Q. Anyone else? 7 A. I mean, it was a general 8 conversation amongst the girls about 9 Ghislaine, so there were other girls 10 a l l t h e t i m e . S o d u r i n g t h e d u r a t i o n 11 o f m y s t a y - - s o p r e t t y m u c h f r o m 12 m y - - w h e n I f i r s t a r r i v e d i n N e w 13 Y o r k , m y e n t i r e t i m e w a s s p e n t w i t h 14 J e f f r e y a n d G h i s l a i n e a n d t h a t c r o w d . 15 S o , y e a h , i t w a s - - t h a t ' s 16 a b o u t e v e r y t h i n g . 17 Q . O k a y . S o y o u m e t - - 18 A . I m e t a l o t o f g i r l s w h o w e 19 a l l h a d t h e s a m e o p i n i o n o f G h i s l a i n e ; 20 w e w e r e a l l f r i g h t e n e d o f h e r . S h e 21 h a d a v e r y o d d r e l a t i o n s h i p w i t h 22 J e f f r e y a n d - - y e a h , s h e ' s n o t a 23 n i c e - - I ' m s o r r y , I k n o w s h e ' s y o u r 24 c l i e n t , b u t s h e ' s n o t - - s h e ' s n o t a 25 f r i e n d l y , w a r m p e r s o n . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 158 of 469 Highly Confidential Page 158 1 HIGHLY CONFIDENTIAL AEO 2 I liked her dog, though, her 3 Yorkshire Terrier. Her dog was nice. 4 Q. You recall meeting her for 5 the first time on the island? 6 A. Yeah. She flew in by 7 helicopter. 8 Q. And that was after you were 9 on the island a couple of times? 10 A . Y e a h . 11 Q . D i d s h e f l y t h e h e l i c o p t e r ? 12 A . I c a n ' t r e m e m b e r i f s h e f l e w 13 i t o r n o t . I j u s t r e m e m b e r h e r 14 g e t t i n g o u t - - l i k e g e t t i n g o u t o f 15 a - - a n d g o i n g G h i s l a i n e , a n d I w a s 16 l i k e - - I w a s q u i t e f r i g h t e n e d w h e n 17 s h e a r r i v e d , s o . . . 18 Q . W a s s h e a l o n e o r w i t h 19 s o m e o n e ? 20 A . I c a n ' t r e m e m b e r i f s h e w a s 21 w i t h s o m e o n e . I j u s t r e m e m b e r t h e 22 f i r s t t i m e I s a w h e r , I w a s l i k e , i s 23 t h a t i t ? S h e d i d n ' t l o o k t h a t s c a r y 24 w h e n I f i r s t m e t h e r . L o o k s a r e 25 d e c e i v i n g . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 159 of 469 Highly Confidential Page 159 1 HIGHLY CONFIDENTIAL AEO 2 Q. So the first time you saw 3 her, she was getting off of a 4 helicopter? 5 A. Yeah. 6 Q. And you don't recall if she 7 flew the helicopter? 8 A. I don't recall if she flew 9 it herself or if there was a pilot 10 t h e r e . I j u s t r e m e m b e r s h e a r r i v e d o n 11 a h e l i c o p t e r . 12 Q . W h a t ' s t h e n e x t t h i n g y o u 13 r e m e m b e r a b o u t y o u r i n t e r a c t i o n s w i t h 14 h e r p e r s o n a l l y ? 15 A . S h e s t a y e d o n t h e i s l a n d a 16 f e w d a y s , a n d I d i d n ' t h a v e a l o t o f 17 i n t e r a c t i o n w i t h h e r . I a v o i d e d h e r , 18 t o b e h o n e s t . 19 Q . D i d y o u t a k e p i c t u r e s o f 20 h e r ? 21 A . N o . W e w e r e n ' t a l l o w e d a n y 22 d i g i t a l c a m e r a s o n t h e i s l a n d . 23 Q . H a v e y o u e v e r t a k e n a 24 p i c t u r e o f h e r ? 25 A . N o . I d i d n ' t r e a l l y f e e l MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 160 of 469 Highly Confidential Page 160 1 HIGHLY CONFIDENTIAL AEO 2 the need to take pictures of Ghislaine 3 for my photo album. 4 Q. Apart from staying away from 5 her and not having a lot of 6 interactions, do you recall anything 7 else about your first interaction with 8 her on the island? 9 A. Yeah. She was incredibly 10 u n p l e a s a n t t o m e . S h e w a s n ' t f r i e n d l y 11 o r w a r m . 12 Q . W h a t d i d s h e s a y o r d o ? 13 A . S h e w a s v e r y d i s m i s s i v e . 14 J u s t a n o t h e r g i r l , r e a l l y . 15 Q . D i d y o u e v e r g i v e h e r a 16 m a s s a g e ? 17 A . N o . 18 Q . D i d s h e e v e r g i v e y o u a 19 m a s s a g e ? 20 A . S h e m a s s a g e d m e o n c e o r 21 t w i c e , b u t i t w a s t o - - i t w a s t o 22 r e f i n e m y t e c h n i q u e f o r J e f f r e y . 23 Q . T h i s w a s o n t h e f i r s t t i m e 24 y o u m e t h e r ? 25 A . Y e a h , d u r i n g t h a t t r i p MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 161 of 469 Highly Confidential Page 161 1 HIGHLY CONFIDENTIAL AEO 2 she -- because Jeffrey, again, he's 3 quite specific on how he likes his 4 massages and, yeah, I'm not -- that's 5 not my forte, massages. 6 Q. How did it come about that 7 she was helping you to refine your 8 massage techniques? 9 A. We were just sitting in the 10 m a i n a r e a b y t h e b i g h o u s e . T h a t ' s 11 w h e r e w e c h i l l e d o u t . T h e r e ' s a t a b l e 12 t h e r e a s w e l l . 13 A n d , y e a h , w e w e r e j u s t 14 s i t t i n g o n t h e s o f a s , a n d I t h i n k - - I 15 c a n ' t r e m e m b e r i f I w a s g i v i n g J e f f r e y 16 a m a s s a g e , b u t w e w e r e a l l s i t t i n g 17 t o g e t h e r , a n d I t h i n k h e w a s g e t t i n g 18 m a s s a g e d b y o n e g i r l a n d w e w e r e k i n d 19 o f t a k i n g i t i n t u r n s . 20 Q . W a s i t s e x u a l ? 21 A . N o , i t w a s n ' t s e x u a l . B u t 22 G h i s l a i n e w a s t h e r e , a n d I w a s n ' t 23 d o i n g i t p r o p e r l y a n d s h e s h o w e d m e 24 h o w t o m a s s a g e h i m a n d h o w h e l i k e d 25 i t . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 162 of 469 Highly Confidential Page 162 1 HIGHLY CONFIDENTIAL AEO 2 Q. What part of his body did 3 she show you how to massage? 4 A. His feet, his hands. 5 Q. Did she say anything to you? 6 A. I can't remember 7 specifically what she said to me. She 8 said a lot of things to me. 9 Q. Okay. Well, tell me what 10 y o u r e m e m b e r s h e s a i d t o y o u . 11 M R . G U I R G U I S : O b j e c t i o n . 12 W h e n ? W h e r e ? W h a t ? W h a t a r e w e 13 t a l k i n g a b o u t ? 14 A . I c a n ' t r e m e m b e r 15 s p e c i f i c a l l y w h a t s h e s a i d t o m e . A l l 16 I k n o w i s t h a t s h e w a s n ' t - - s h e 17 w a s n ' t a p a r t i c u l a r l y n i c e p e r s o n , t o 18 m e o r a n y b o d y . S o v e r y d i c t o r i a l 19 [ s i c ] . 20 Q . U n l i m i t e d b y t i m e o r 21 a n y t h i n g , d o y o u r e c a l l a n y t h i n g 22 G h i s l a i n e s a i d t o y o u ? 23 M R . G U I R G U I S : O b j e c t i o n . 24 Y o u ' r e a s k i n g h e r - - 25 A . I t w a s h o w t o m a s s a g e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 163 of 469 Highly Confidential Page 163 1 HIGHLY CONFIDENTIAL AEO 2 Jeffrey. 3 I remember speaking to her 4 quite a lot about my FIT application. 5 I remember speaking to 6 Ghislaine about my psychiatrist, about 7 my weight. My weight was a big issue. 8 And, in fact, everything was an issue 9 with Ghislaine. 10 Q . D u r i n g t h i s f i r s t t i m e y o u 11 m e t h e r , o t h e r t h a n d i s c u s s i n g 12 m a s s a g e s , d i d t h o s e o t h e r t o p i c s c o m e 13 u p ? 14 A . I c a n ' t r e m e m b e r t h e f i r s t 15 e n c o u n t e r w i t h G h i s l a i n e , b u t i t w a s 16 p r e t t y s o o n a f t e r . E v e r y t h i n g 17 s n o w b a l l e d q u i t e q u i c k l y . 18 Q . W e l l , y o u s a w h e r g e t t i n g 19 o f f t h e h e l i c o p t e r , c o r r e c t ? 20 A . Y e a h . 21 Q . A n d y o u s a w h e r o n t h e 22 i s l a n d f o r a c o u p l e d a y s t h a t t i m e , 23 y o u s a i d , c o r r e c t ? 24 A . Y e a h . 25 Q . S o d u r i n g t h a t t i m e y o u s a w MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 164 of 469 Highly Confidential Page 164 1 HIGHLY CONFIDENTIAL AEO 2 her over a couple days, do you 3 remember any other discussions you had 4 with her apart from this massage? 5 A. We spoke about why I was 6 there, New York. I mean, we -- you 7 know, she got to know me. She asked 8 me a lot of questions about my family 9 life, my -- I mean, she questioned me 10 a l o t o n m y p e r s o n a l l i f e . 11 Q . W a s a n y o n e e l s e p r e s e n t w h e n 12 y o u w e r e h a v i n g t h e s e d i s c u s s i o n s w i t h 13 G h i s l a i n e ? 14 A . Y e s , e v e r y o n e . E v e r y o n e 15 t h a t w a s - - S a r a h K e l l e n , J e f f r e y , 16 N a t a l y a . 17 Q . W a s t h e r e a n y o n e d i f f e r e n t 18 o n t h i s t r i p ? 19 A . N a d i a a s w e l l . N a d i a w a s 20 t h e r e . 21 Q . A n y o n e e l s e o n t h i s t r i p ? 22 A . I c a n ' t r e m e m b e r . 23 Q . W a s J e a n L u c B r u n e l t h e r e ? 24 A . N o t t h e f i r s t t i m e I m e t 25 G h i s l a i n e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 165 of 469 Highly Confidential Page 165 1 HIGHLY CONFIDENTIAL AEO 2 Q. Was anyone else there? 3 A. I can't remember. 4 Q. Anything that would refresh 5 your memory? 6 A. If you could give me the 7 plane logs or something, or names or 8 photos. Ten years, as I said, is an 9 incredibly long time. I don't 10 r e m e m b e r w h o - - I m e a n , i t w a s s u c h a 11 l o n g t i m e f o r m e . 12 I c a m e t o N e w Y o r k , m y 13 i n t e n t i o n w a s t o m e e t m a n y p e o p l e , 14 m a k e n e w f r i e n d s , m a k e a n e w l i f e f o r 15 m y s e l f . S o I d i d n ' t r e a l l y - - I d o n ' t 16 r e m e m b e r n a m e s s p e c i f i c a l l y . 17 Q . D o y o u r e m e m b e r a n y 18 d e s c r i p t i o n s o f o t h e r p e o p l e w h o w e r e 19 o n t h e i s l a n d t h e f i r s t t i m e y o u m e t 20 G h i s l a i n e ? 21 A . T h e y w e r e a l l b e a u t i f u l 22 p e o p l e . I j u s t r e m e m b e r b e i n g 23 s u r r o u n d e d b y b e a u t i f u l y o u n g p e o p l e . 24 T h e y w e r e a l w a y s g i r l s . T h e r e w e r e 25 a l w a y s g i r l s . Y o u k n o w , g i r l s d i d n ' t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 166 of 469 Highly Confidential Page 166 1 HIGHLY CONFIDENTIAL AEO 2 even have time to kind of remember 3 girls' names because there was always 4 people leaving the island, popping in, 5 flying in. So there was a constant 6 flux of people coming in, popping in 7 visiting Jeffrey and Ghislaine. 8 Q. So the first time you met 9 Ghislaine, you saw her get off a 10 h e l i c o p t e r . S h e w a s o n t h e i s l a n d f o r 11 a c o u p l e d a y s . 12 A n y o t h e r f e m a l e s y o u 13 r e m e m b e r b e i n g t h e r e o n t h a t o c c a s i o n ? 14 M S . M C C A W L E Y : O b j e c t i o n , 15 a s k e d a n d a n s w e r e d . 16 A . S a r a h K e l l e n , N a d i a , 17 N a t a l y a , a n d I c a n ' t r e m e m b e r a n y 18 o t h e r s . 19 Q . C a n y o u r e m e m b e r a n y 20 d e s c r i p t i o n s o f o t h e r p e o p l e w h o w e r e 21 t h e r e o n t h a t o c c a s i o n ? 22 M R . G U I R G U I S : O b j e c t i o n , 23 a s k e d a n d a n s w e r e d . 24 A . T h e y w e r e j u s t p r e t t y . T h e y 25 w e r e j u s t b e a u t i f u l . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 167 of 469 Highly Confidential Page 167 1 HIGHLY CONFIDENTIAL AEO 2 Q. Hair color? 3 MR. GUIRGUIS: Objection. 4 A. Normal. 5 Q. Height? 6 A. I don't recall height. 7 Q. Any other physical 8 characteristics at all? 9 MR. GUIRGUIS: Objection. 10 A . J u s t t h a t t h e y w e r e 11 e x t r e m e l y b e a u t i f u l . I ' v e n e v e r s e e n 12 g i r l s l i k e t h i s . 13 Q . W e l l , y o u h a d b e e n a m o d e l 14 i n L o n d o n , r i g h t ? 15 A . Y e a h , I h a v e , b u t , y o u k n o w , 16 J e f f r e y E p s t e i n , h e a c q u i r e d t h e 17 e l i t e , d i d n ' t h e , y o u k n o w , h i m a n d 18 G h i s l a i n e . S o t h e y w e r e p r e t t y m u c h 19 t h e c r è m e d e l a c r è m e o f t h e c r o p , I 20 w o u l d s a y , t h e g i r l s t h a t w e r e a r o u n d 21 h i m . 22 Q . O n t h i s f i r s t o c c a s i o n w h e n 23 y o u m e t G h i s l a i n e a n d t h e r e w e r e 24 b e a u t i f u l g i r l s , w h o y o u d o n ' t r e c a l l 25 w h a t t h e y l o o k l i k e ; y o u r e c a l l t h e y MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 168 of 469 Highly Confidential Page 168 1 HIGHLY CONFIDENTIAL AEO 2 were beautiful? 3 A. Yeah, there were beautiful 4 people constantly surrounded by 5 Jeffrey Epstein and Ghislaine. They 6 were only surrounded by beautiful 7 people, beautiful girls. 8 Q. But apart from that, you 9 don't have any other specifics? 10 A . I d o n ' t r e c a l l t h e 11 a p p e a r a n c e o f t h e o t h e r g i r l s . I 12 d o n ' t - - a s I w i l l s a y a g a i n , t h e r e 13 w a s a c o n s t a n t s t r e a m o f p e o p l e c o m i n g 14 i n , g o i n g o f f t h e i s l a n d , p o p p i n g i n , 15 p o p p i n g o u t , g i r l s f l y i n g i n , g i r l s 16 f l y i n g o u t . T h e r e w e r e g i r l s o n t h e 17 i s l a n d t h a t w e r e t h e r e s h o r t e r t i m e 18 f r a m e s t h a n m e a n d f l e w o u t . 19 I d i d n ' t r e a l l y - - I h u n g 20 o u t w i t h m y c r e w : N a t a l y a , J e n . T h e y 21 w e r e - - t h e y w e r e m y f r i e n d s . I 22 t h o u g h t t h e y w e r e m y f r i e n d s . S o I 23 d i d n ' t r e a l l y c o z y u p t o a n y o f t h e 24 o t h e r g i r l s . 25 I t ' s l i k e h i g h s c h o o l , y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 169 of 469 Highly Confidential Page 169 1 HIGHLY CONFIDENTIAL AEO 2 know, you're not friends with 3 everybody. You ask me who -- everyone 4 I went to school with, I don't 5 remember. I don't have a clue. I 6 don't know who they are. 7 Q. Do you have a best friend 8 from school? 9 MR. GUIRGUIS: Objection. 10 A . S e v e r a l . S e v e r a l . I m e a n , 11 w h o h a s a n y b e s t f r i e n d a t s c h o o l ? 12 S c h o o l ' s s c h o o l . W e d o n ' t m a k e b e s t 13 f r i e n d s a t s c h o o l . 14 Q . W h o i s P u m l a ? 15 A . S h e w a s a n a c q u a i n t a n c e t h a t 16 I m e t i n N e w Y o r k . 17 Q . W h e r e d i d y o u m e e t h e r ? 18 A . I t h i n k I m e t h e r a t a b a r 19 o r s o m e t h i n g . 20 Q . W a s s h e a f r i e n d o f y o u r s 21 d u r i n g t h i s t i m e p e r i o d ? 22 A . S h e w a s a n a c q u a i n t a n c e . I 23 w o u l d s a y f r i e n d i s - - y e a h , I 24 w o u l d n ' t s a y f r i e n d . I ' d s a y 25 a c q u a i n t a n c e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 170 of 469 Highly Confidential Page 170 1 HIGHLY CONFIDENTIAL AEO 2 Q. So on this occasion where 3 you met Ghislaine on the island and 4 you spoke to her about massage, did 5 you ever have any other sexual-type 6 interactions with her? 7 MS. MCCAWLEY: I didn't hear 8 the end of that. Did you say 9 "him"? 10 Q . S e x u a l - t y p e i n t e r a c t i o n s 11 w i t h h e r ? 12 A . W i t h h e r ? 13 Q . G h i s l a i n e ? 14 A . N o . 15 Q . A n d d o y o u r e c a l l i f s h e 16 f l e w w i t h y o u b a c k o n t h e p l a n e ? 17 A . I c a n ' t r e m e m b e r . 18 Q . W h a t ' s t h e n e x t t i m e y o u 19 w e n t t o t h e i s l a n d ? 20 A . A g a i n , I d o n ' t r e m e m b e r 21 s p e c i f i c a l l y . I w e n t v a r i o u s s e v e r a l 22 t i m e s d u r i n g t h e d u r a t i o n . S o I 23 r e m e m b e r t h e r e w a s a - - i t w a s s e v e r a l 24 t i m e s . I c a n ' t r e m e m b e r t h e n e x t t i m e 25 I w e n t t o t h e i s l a n d . I m e a n , i t ' s . . . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 171 of 469 Highly Confidential Page 171 1 HIGHLY CONFIDENTIAL AEO 2 Q. Was it before you went back 3 to South Africa to visit? 4 A. Yes. 5 Q. All the visits to the island 6 were before that? 7 MS. MCCAWLEY: Objection. 8 A. Yeah. 9 Q. What's the next time you 10 r e m e m b e r m e e t i n g G h i s l a i n e ? 11 A . I m e t h e r a t t h e o f f i c e i n 12 N e w Y o r k . 13 Q . W h a t ' s t h e o f f i c e ? 14 A . J e f f r e y ' s o f f i c e , m a i n 15 o f f i c e . 16 Q . W h e r e i s t h a t ? 17 A . I d o n ' t r e m e m b e r t h e 18 l o c a t i o n . I t ' s c e n t r a l . I t ' s g o t a 19 c o u r t y a r d . L i k e w h e n y o u w a l k i n , 20 t h e r e ' s l i k e a c o u r t y a r d . 21 Q . W h a t w e r e y o u d o i n g a t 22 J e f f r e y ' s o f f i c e i n N e w Y o r k ? 23 A . W e w e r e p r e p a r i n g f o r m y 24 c o l l e g e a p p l i c a t i o n . J e f f r e y o f t e n 25 w a n t e d t o s e e j u s t h o w I w a s d o i n g , s o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 172 of 469 Highly Confidential Page 172 1 HIGHLY CONFIDENTIAL AEO 2 I had to regularly pop in to see him 3 and Ghislaine. And Ghislaine would 4 often check how I was doing and blah, 5 blah, blah, etcetera. 6 Q. What were you doing to 7 prepare for your college application? 8 A. I had to write an essay. 9 Q. When did you -- 10 A . A l s o , I h a d t o d o - - l i k e , 11 y o u k n o w h o w y o u a p p l y f o r c o l l e g e 12 a p p l i c a t i o n s ; y o u ' v e g o t y o u r 13 a p p l i c a t i o n f o r m s a n d s u c h . S o i t w a s 14 m o r e a d m i n . 15 Q . A n d y o u w e r e g o i n g t o 16 J e f f r e y ' s o f f i c e t o w o r k o n y o u r 17 f o r m s ? 18 A . Y e s . A n d t o j u s t s a y h i . I 19 w a s - - w e l l , I n e v e r w e n t o n m y o w n 20 a c c o r d . I w a s e i t h e r i n v i t e d o r t o l d 21 t o b e t h e r e b y e i t h e r G h i s l a i n e o r 22 J e f f r e y . I a l s o w e n t t o t h e o f f i c e s 23 o n a n u m b e r o f o c c a s i o n s f o r p r i v a t e 24 l e g a l m a t t e r . 25 Q . W h a t ' s t h e p r i v a t e l e g a l MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 173 of 469 Highly Confidential Page 173 1 HIGHLY CONFIDENTIAL AEO 2 matter? 3 MR. GUIRGUIS: Objection. 4 I'm going to direct you not to 5 answer if it's unrelated to this 6 case. 7 Q. Was there an attorney 8 present? 9 A. Yes. 10 Q . W h a t w a s t h e n a m e o f t h e 11 a t t o r n e y w h o w a s p r e s e n t ? 12 A . A l a n D e r s h o w i t z . 13 Q . S o I w a s a s k i n g a b o u t t h e 14 s e c o n d t i m e y o u m e t G h i s l a i n e . I t w a s 15 a t J e f f r e y ' s o f f i c e i n N e w Y o r k ? 16 A . Y e s . 17 Q . H o w d i d y o u c o m e t o b e i n 18 J e f f r e y ' s o f f i c e i n N e w Y o r k w h e r e y o u 19 m e t G h i s l a i n e t h e s e c o n d t i m e ? 20 A . I w a s t o l d t o b e t h e r e . 21 Q . W h o t o l d y o u t o b e t h e r e ? 22 A . I t h i n k i t w a s G h i s l a i n e . 23 Q . H o w d i d G h i s l a i n e t e l l y o u 24 t o b e t h e r e ? 25 A . I c a n ' t r e m e m b e r i f i t w a s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 174 of 469 Highly Confidential Page 174 1 HIGHLY CONFIDENTIAL AEO 2 via telephone call. I can't remember 3 the exact communication that she used. 4 But I was told to regularly be there 5 when they wanted me there, and just 6 grabbed a taxi and arrived at the 7 office. 8 Q. Well, I'm asking you about 9 the second time. 10 S o y o u m e t h e r o n t h e 11 i s l a n d , a n d t h e n e x t t h i n g y o u k n o w , 12 y o u h a v e a c o m m u n i c a t i o n f r o m h e r i n 13 N e w Y o r k ? 14 A . W e l l , s h e w a s a l w a y s w i t h 15 J e f f r e y i n h i s o f f i c e , s o i t ' s l i k e - - 16 o k a y , s o l e t m e e x p l a i n i t . 17 S o y o u g o t o a n o f f i c e a n d 18 y o u s e e J e f f r e y ' s o f f i c e t h e r e a n d 19 G h i s l a i n e - - G h i s l a i n e w a s a l w a y s a t 20 J e f f r e y ' s o f f i c e , s o I t h i n k s h e h a d 21 h e r o w n o f f i c e t h e r e . 22 S o w h e n y o u w a l k i n a n d 23 y o u ' v e m e t p e o p l e b e f o r e , y o u k i n d o f 24 s a y h i t o e v e r y o n e . Y o u k n o w , y o u 25 h a v e a l i t t l e c h i t c h a t . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 175 of 469 Highly Confidential Page 175 1 HIGHLY CONFIDENTIAL AEO 2 Do you understand? You 3 don't -- you don't -- you know, I 4 chatted with Ghislaine, I chatted with 5 Jeffrey. It was a busy office. I 6 can't remember specifically what was 7 said. It was just a check-in, kind 8 of. 9 Q. So you were going there to 10 w o r k o n y o u r c o l l e g e a p p l i c a t i o n , a n d 11 y o u h a p p e n e d t o s e e G h i s l a i n e i n t h e 12 o f f i c e s ? 13 M S . M C C A W L E Y : O b j e c t i o n . 14 A . S h e - - y o u k n o w , s h e 15 p a r t i c i p a t e d i n t h e - - y o u k n o w , a 16 l o t . S h e w a s i n t e r e s t e d i n m e . I 17 w a s - - y o u k n o w , s h e i n t e r a c t e d w i t h 18 m e . 19 Q . I k n o w . I ' m t r y i n g t o 20 u n d e r s t a n d w h e n y o u d i d t h i s . W h e n 21 w a s i t ? 22 A . I t w a s t h e s e c o n d t i m e , t h e 23 f i r s t t i m e I w e n t t o t h e o f f i c e . 24 Q . T h e f i r s t t i m e y o u w e n t t o 25 t h e o f f i c e , t h e s e c o n d t i m e y o u m e t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 176 of 469 Highly Confidential Page 176 1 HIGHLY CONFIDENTIAL AEO 2 Ghislaine? 3 A. Yes. 4 Q. And when was it relative to 5 the first time you met Ghislaine? 6 A. I can't remember if it was a 7 couple of weeks later. I don't 8 remember the exact time frame of how 9 many days or weeks there was between 10 t h e f i r s t t r i p a n d t h e - - w h e n I w e n t 11 i n t o t h e o f f i c e . 12 Q . B u t y o u d o r e c a l l g o i n g i n t o 13 t h e o f f i c e t o w o r k o n y o u r c o l l e g e 14 a p p l i c a t i o n ? 15 M S . M C C A W L E Y : O b j e c t i o n . 16 A . Y e s . W e l l , I w e n t i n a 17 n u m b e r o f t i m e s t o t h e o f f i c e . S o , 18 l i k e , w e r e g u l a r l y h a d t o r e p o r t t o 19 J e f f r e y i n t h e o f f i c e . I t w a s a - - w e 20 w e r e c a l l e d a l l t h e t i m e t h e r e . 21 Q . W h a t d o y o u m e a n , y o u h a d t o 22 r e p o r t t h e r e ? 23 A . W e l l , J e f f r e y l i k e d t o c h e c k 24 i n w i t h a l l o f u s . 25 Q . H o w w a s i t c o m m u n i c a t e d t o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 177 of 469 Highly Confidential Page 177 1 HIGHLY CONFIDENTIAL AEO 2 you that you needed to report to the 3 office? 4 A. Jeffrey. I was just told to 5 be there; I had to be there. 6 Q. Who told that you? 7 A. Jeffrey and Ghislaine. 8 Q. Anyone else? 9 A. Sarah Kellen and Lesley 10 G r o f f . 11 Q . H o w d i d t h e y c o m m u n i c a t e i t 12 t o y o u ? 13 A . B y t e l e p h o n i c c a l l . 14 Q . T o y o u r c e l l p h o n e ? 15 A . A n d B l a c k B e r r y , w h i c h t h e y 16 p r o v i d e d m e . 17 Q . S o y o u d i d n o t h a v e a 18 B l a c k B e r r y b e f o r e y o u m e t J e f f r e y ? 19 A . N o . 20 Q . T h e n y o u g o t a B l a c k B e r r y 21 w h e n y o u w e r e - - 22 A . T h a t ' s c o r r e c t . 23 Q . - - a c q u a i n t e d w i t h h i m . 24 A n d w h a t h a p p e n e d w i t h t h e 25 p h o n e y o u h a d b e f o r e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 178 of 469 Highly Confidential Page 178 1 HIGHLY CONFIDENTIAL AEO 2 A. It's got lost through 3 translation. I have moved several 4 times through the years, so... 5 Q. So you got messages or phone 6 calls? 7 A. BBMs, phone calls, text 8 messages. 9 All the emails that they 10 s e n t m e , I t h i n k y o u g u y s h a v e . T h e r e 11 w a s n ' t a l o t o f e m a i l c o r r e s p o n d e n c e . 12 T h e m a j o r i t y o f i t w a s d o n e b y p h o n e 13 c a l l . 14 Q . D i d y o u h a v e a n y e m a i l s w i t h 15 G h i s l a i n e ? 16 A . N o , n o e m a i l c o r r e s p o n d e n c e 17 w i t h G h i s l a i n e . 18 Q . D i d y o u h a v e h e r p h o n e 19 n u m b e r ? 20 A . I d i d a t t h e t i m e , y e a h . 21 Q . D o y o u r e m e m b e r w h a t i t w a s ? 22 A . N o . 23 Q . D o y o u r e m e m b e r w h a t y o u r 24 n u m b e r w a s ? 25 A . N o . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 179 of 469 Highly Confidential Page 179 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection, 3 asked and answered. 4 Q. Tell me about any 5 conversations you had with Ghislaine 6 that involved FIT. 7 MR. GUIRGUIS: Objection, 8 form. 9 A. I can't remember the 10 s p e c i f i c c o n v e r s a t i o n . T h e r e w e r e 11 m a n y c o n v e r s a t i o n s . I w a s j u s t 12 a p p l y i n g - - d o i n g a n a p p l i c a t i o n f o r m . 13 A n d t h e y w e r e t r y i n g t o g e t m e i n . 14 T h e y - - y e a h , I c a n ' t r e m e m b e r t h e 15 e x a c t - - I t h i n k G h i s l a i n e a l s o k n e w 16 p e o p l e t h e r e , s o t h e y w e r e b a s i c a l l y 17 t r y i n g t o g e t m e i n t o F I T . 18 Q . W e l l , t e l l m e w h a t y o u 19 r e c a l l G h i s l a i n e s a y i n g v e r s u s t h e y ? 20 A . I c a n ' t r e m e m b e r 21 s p e c i f i c a l l y t h e c o n v e r s a t i o n , s o I 22 w o u l d n o t l i k e t o s p e c u l a t e . B u t I 23 w i l l g i v e y o u t h e o v e r a l l c o n v e r s a t i o n 24 w a s r e g a r d i n g m y F I T a p p l i c a t i o n , b u t 25 I c a n n o t r e m e m b e r t h e s p e c i f i c c o n t e n t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 180 of 469 Highly Confidential Page 180 1 HIGHLY CONFIDENTIAL AEO 2 or the specific words used. 3 But it was surrounding my 4 FIT application and an essay I had to 5 write, and they both proofread my FIT 6 application as well. 7 Q. And did they both read your 8 essay? 9 A. Yes, they did. 10 Q . W h e n d i d y o u w r i t e t h a t 11 e s s a y ? 12 A . I c a n ' t r e m e m b e r . 13 Q . B e f o r e y o u w e n t t o S o u t h 14 A f r i c a ? 15 A . Y e s . 16 Q . D o y o u k n o w w h a t t h e 17 a p p l i c a t i o n d e a d l i n e w a s ? 18 A . I d o n ' t k n o w . I d o n ' t k n o w . 19 I c a n ' t r e m e m b e r . 20 Q . W h e n d i d y o u m e e t A l a n 21 D e r s h o w i t z ? 22 A . I d o n ' t r e m e m b e r t h e 23 s p e c i f i c d a t e . I t w a s a f e w m o n t h s 24 a f t e r I h a d b e e n h e r e i n N e w Y o r k . 25 Q . W a s i t a f t e r y o u h a d g o n e t o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 181 of 469 Highly Confidential Page 181 1 HIGHLY CONFIDENTIAL AEO 2 the island? 3 A. Yes. 4 Q. Do you know what time of 5 year? 6 A. I mean, I think it was 7 before winter. 8 Q. Well, you were here in the 9 fall. 10 A . Y e a h . 11 Q . A n d y o u l e f t i n t h e w i n t e r ? 12 A . Y e a h . I l e f t i n M a y . 13 Q . S o d i d y o u m e e t h i m b e f o r e 14 y o u w e n t t o S o u t h A f r i c a ? 15 A . Y e s . 16 Q . W e l l , l e t ' s b e c l e a r . Y o u 17 w e r e h e r e u n t i l y o u w e n t t o S o u t h 18 A f r i c a , a n d y o u l e f t f o r a w h i l e a n d 19 t h e n y o u c a m e b a c k , r i g h t ? 20 A . M m - h m m . 21 Q . H o w l o n g w e r e y o u g o n e ? 22 A . I t h i n k a b o u t t h r e e - - a b o u t 23 t h r e e w e e k s . 24 Q . S o y o u m e t h i m b e f o r e y o u 25 w e n t t o S o u t h A f r i c a ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 182 of 469 Highly Confidential Page 182 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. And tell me about when you 4 met Alan. 5 A. I first met Alan at the 6 offices. 7 Q. And tell me what happened. 8 A. I can't really tell you what 9 happened, because it's about a legal 10 m a t t e r . 11 Q . W a s h e y o u r l a w y e r ? 12 A . H e w a s g o i n g t o b e a s s i g n e d 13 t o b e m y l a w y e r . 14 Q . A s s i g n e d t o b e y o u r l a w y e r ? 15 A . T h r o u g h J e f f r e y ' s 16 i n s t r u c t i o n . 17 Q . O k a y . W a s h e y o u r l a w y e r ? 18 M S . M C C A W L E Y : O b j e c t i o n , 19 a s k e d a n d a n s w e r e d . 20 M S . M E N N I N G E R : I d o n ' t k n o w 21 i f t h e r e ' s a p r i v i l e g e . 22 M R . G U I R G U I S : T h e r e ' s a 23 p r i v i l e g e w h e t h e r h e w a s r e t a i n e d 24 o r n o t , r i g h t ? I m e a n , i f y o u ' r e 25 a t a c o c k t a i l p a r t y a n d y o u s p e a k MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 183 of 469 Highly Confidential Page 183 1 HIGHLY CONFIDENTIAL AEO 2 to a lawyer, you know that 3 conversation is privileged. 4 So... 5 MS. MENNINGER: Well, I 6 don't, actually. 7 MR. GUIRGUIS: You're free 8 to research it. 9 MS. MENNINGER: I will ask 10 q u e s t i o n s , t h e n , t o t r y t o 11 e s t a b l i s h w h e t h e r o r n o t t h e r e ' s 12 a g o o d - f a i t h b a s i s . 13 Q . D i d y o u a p p r o a c h A l a n 14 D e r s h o w i t z f o r t h e p u r p o s e o f s e e k i n g 15 l e g a l a d v i c e ? 16 A . I w a s i n t r o d u c e d t o A l a n . 17 Q . B y w h o m ? 18 A . J e f f r e y E p s t e i n . 19 Q . O n w h a t d a y ? 20 A . I d o n ' t r e c a l l w h a t d a y . 21 Q . W a s i t r e l a t e d t o s o m e e v e n t 22 t h a t h a d o c c u r r e d j u s t b e f o r e t h a t ? 23 A . Y e s , t h a t ' s c o r r e c t . 24 Q . W e r e y o u i n t o u c h w i t h a n y 25 l a w e n f o r c e m e n t a u t h o r i t i e s ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 184 of 469 Highly Confidential Page 184 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Hmm? 4 A. No. 5 Q. Was Jeffrey Epstein in the 6 room when you were speaking with Alan 7 Dershowitz? 8 A. Yes. 9 Q. Did Jeffrey Epstein overhear 10 y o u r c o n v e r s a t i o n w i t h A l a n 11 D e r s h o w i t z ? 12 A . Y e s . 13 Q . W h a t d i d y o u t a l k a b o u t w i t h 14 A l a n D e r s h o w i t z ? 15 M R . G U I R G U I S : O b j e c t i o n . 16 A . I t - - 17 M R . G U I R G U I S : O b j e c t i o n . I 18 d i r e c t t h e w i t n e s s n o t t o a n s w e r . 19 M S . M E N N I N G E R : A t h i r d 20 p a r t y w a s i n t h e r o o m ; y o u ' v e 21 h e a r d t h a t , C o u n s e l . A n d y o u 22 k n o w t h a t m e a n s t h a t ' s a w a i v e r . 23 M S . M C C A W L E Y : N o . I m e a n , 24 t h e y w o u l d h a v e b e e n i n v o l v e d - - 25 w e d o n ' t k n o w w h a t t h e s i t u a t i o n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 185 of 469 Highly Confidential Page 185 1 HIGHLY CONFIDENTIAL AEO 2 is. They could have been 3 involved together. There could 4 be a number of reasons why 5 Jeffrey had some sort of common 6 interest with her with that. 7 Q. Did you sign a common 8 interest agreement with Jeffrey? 9 MR. GUIRGUIS: Objection. 10 D o n o t a n s w e r . 11 M S . M E N N I N G E R : W h e t h e r s h e 12 h a d a c o m m o n i n t e r e s t a g r e e m e n t 13 w i t h J e f f r e y , y o u ' r e i n s t r u c t i n g 14 h e r n o t t o a n s w e r ; i s t h a t r i g h t , 15 C o u n s e l ? 16 M R . G U I R G U I S : D o y o u h a v e 17 r e a l t i m e i n f r o n t o f y o u , 18 C o u n s e l ? 19 M S . M E N N I N G E R : I d o n ' t . 20 M R . G U I R G U I S : Y o u d o n ' t ? 21 Y o u c a n b o r r o w m i n e . 22 M S . M E N N I N G E R : I d o n ' t w a n t 23 i t . T h a n k y o u . 24 M R . G U I R G U I S : O k a y . 25 Q . A n y o n e e l s e i n t h e r o o m w h e n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 186 of 469 Highly Confidential Page 186 1 HIGHLY CONFIDENTIAL AEO 2 you spoke with Mr. Dershowitz? 3 A. No. 4 Q. Describe Mr. Dershowitz for 5 me. 6 A. He -- old age; white, pasty 7 skin; not very attractive. Wears 8 glasses. Bit of an ugly man, really. 9 Q. Did he have any facial hair? 10 A . I c a n ' t r e c a l l a t t h a t t i m e , 11 n o . 12 Q . M u s t a c h e ? 13 A . I c a n ' t r e m e m b e r . 14 Q . B e a r d ? 15 A . I c a n ' t r e m e m b e r . 16 Q . Y o u c a n ' t r e m e m b e r i f h e h a d 17 a m u s t a c h e o r a b e a r d ? 18 M R . G U I R G U I S : O b j e c t i o n , 19 a s k e d a n d a n s w e r e d . 20 M S . M C C A W L E Y : O b j e c t i o n . 21 A . I d o n ' t r e c a l l s e e i n g a 22 m a s s a g e - - s o r r y , a m u s t a c h e o n A l a n 23 D e r s h o w i t z . I d o n ' t r e c a l l a m a s s i v e 24 a m o u n t o f f a c i a l h a i r . I r e c a l l A l a n 25 D e r s h o w i t z . W h e t h e r h e h a d s t u b b l e o r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 187 of 469 Highly Confidential Page 187 1 HIGHLY CONFIDENTIAL AEO 2 not, I'm -- yeah, it's -- he didn't 3 have a beard, I don't think. 4 Q. All right. Did you sign an 5 affidavit that you submitted in this 6 case? 7 A. Yes. 8 Q. Did you make the allegation 9 in your declaration that you had a 10 s e x u a l r e l a t i o n s h i p w i t h A l a n 11 D e r s h o w i t z ? 12 A . Y e s , I a b s o l u t e l y d i d . 13 Q . W h e n d i d y o u h a v e s e x w i t h 14 A l a n D e r s h o w i t z ? 15 A . I c a n ' t r e m e m b e r t h e e x a c t 16 t i m e , b u t i t w a s i n J e f f r e y ' s N e w Y o r k 17 a p a r t m e n t . 18 Q . W h e r e i n t h e a p a r t m e n t ? 19 A . I t w a s i n a b a t h r o o m . I 20 c a n ' t r e m e m b e r . 21 Q . W a s i t b e f o r e o r a f t e r y o u 22 h a d t h i s c o n v e r s a t i o n t h a t y o u w o n ' t 23 d e s c r i b e ? 24 A . I t w a s a f t e r . 25 Q . S o d o y o u r e c a l l w h a t m o n t h MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 188 of 469 Highly Confidential Page 188 1 HIGHLY CONFIDENTIAL AEO 2 that was? Before you went to South 3 Africa or after you went to South 4 Africa? 5 A. I can't remember. 6 Q. How long did you speak to 7 Alan Dershowitz during your first 8 meeting with him? 9 A. Until I was finished 10 e x p l a i n i n g w h a t m y l e g a l m a t t e r w a s . 11 Q . D i d h e b e l i e v e y o u t o b e - - 12 d i d h e b e l i e v e t h a t h e w a s y o u r l a w y e r 13 d u r i n g t h a t c o n v e r s a t i o n ? 14 M R . G U I R G U I S : O b j e c t i o n . 15 M S . M C C A W L E Y : O b j e c t i o n . 16 M R . P O T T I N G E R : P l e a s e . 17 M R . P A G L I U C A : A l l r i g h t , 18 g u y s . Y o u k n o w , l e t ' s j u s t d o 19 t h e d e p o s i t i o n h e r e w i t h o u t t h e 20 c h o r u s o v e r t h e r e . 21 M R . G U I R G U I S : A n d w i t h o u t 22 t h e s p e e c h e s a s w e l l . 23 W e a g r e e , l e t ' s c a r r y o n 24 w i t h o u t a s k i n g r i d i c u l o u s 25 q u e s t i o n s a b o u t w h a t o t h e r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 189 of 469 Highly Confidential Page 189 1 HIGHLY CONFIDENTIAL AEO 2 people's mental state was. I 3 think that's a good idea. Let's 4 carry on. 5 Counsel? 6 Q. Did you ever sign a fee 7 agreement with Alan Dershowitz? 8 A. No. 9 Q. Did you ever appear in court 10 w i t h A l a n D e r s h o w i t z ? 11 A . N o . 12 Q . D i d y o u e v e r a p p e a r i n c o u r t 13 y o u r s e l f ? 14 A . N o . 15 Q . D i d y o u e v e r h a v e a n y 16 c o n t a c t w i t h a n y l a w e n f o r c e m e n t 17 o f f i c e r s w h i l e y o u w e r e i n N e w Y o r k ? 18 A . N o . 19 Q . A n y p o l i c e ? 20 A . N o . 21 Q . A f t e r y o u l e f t t h a t m e e t i n g 22 w i t h A l a n D e r s h o w i t z , w h e n d i d y o u s e e 23 h i m n e x t ? 24 A . I c a n ' t r e m e m b e r . I t h i n k 25 i t w a s a t d i n n e r . T h e r e w a s a d i n n e r , MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 190 of 469 Highly Confidential Page 190 1 HIGHLY CONFIDENTIAL AEO 2 yeah. 3 Q. And do you know whether the 4 dinner was before or after you went to 5 South Africa? 6 A. I can't remember the 7 specific time period, so I don't 8 remember if it was before or after. 9 But it was -- 10 Q . W h e r e w a s t h e d i n n e r ? 11 A . I t w a s i n a r e s t a u r a n t i n 12 N e w Y o r k . 13 Q . W h a t r e s t a u r a n t ? 14 A . I c a n ' t r e m e m b e r . 15 Q . W h o e l s e w a s t h e r e ? 16 A . I r e m e m b e r A l a n , J e f f r e y , 17 m y s e l f . A n d I c a n ' t r e m e m b e r i f 18 o t h e r s - - i f t h e r e w e r e o t h e r p e o p l e 19 t h e r e . 20 Q . W h a t t y p e o f r e s t a u r a n t w a s 21 i t ? 22 A . I t w a s a n i c e r e s t a u r a n t . 23 Q . D o y o u r e m e m b e r t h e t y p e o f 24 c u i s i n e ? 25 A . N o . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 191 of 469 Highly Confidential Page 191 1 HIGHLY CONFIDENTIAL AEO 2 Q. When was the next time -- 3 what do you remember discussing that 4 dinner? 5 A. The legal matter I had. 6 Q. Did you consider him to be 7 your lawyer at that dinner? 8 A. Yes, I did. 9 Q. What's the next time that 10 y o u s a w A l a n D e r s h o w i t z ? 11 A . A t J e f f r e y ' s N e w Y o r k 12 m a n s i o n . 13 Q . W h e n w a s t h a t ? 14 A . I t w a s a f t e r t h e s e c o n d t i m e 15 I h a d m e t A l a n . 16 Q . H a d y o u b e e n t o S o u t h 17 A f r i c a ? 18 A . I c a n ' t r e m e m b e r . 19 Q . T e l l m e w h a t h a p p e n e d d u r i n g 20 t h a t e n c o u n t e r . 21 A . I w a l k e d i n t h e r o o m - - I 22 w a l k e d i n t h e h o u s e . J e f f r e y a n d 23 N a d i a a n d A l a n w e r e t h e r e . 24 Q . W h a t h a p p e n e d a f t e r y o u 25 w a l k e d i n t h e h o u s e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 192 of 469 Highly Confidential Page 192 1 HIGHLY CONFIDENTIAL AEO 2 A. I -- it was really strange, 3 because Nadia didn't like me. And so 4 when I arrived, we had -- I think -- I 5 can't remember if I had, like, water 6 or whatever. 7 Nadia took me upstairs. I 8 remember there was a room. I didn't 9 quite understand what was going on at 10 t h e t i m e . I k n e w o b v i o u s l y s o m e t h i n g 11 w a s g o i n g o n , b e c a u s e I n e v e r m e t 12 N a d i a s o c i a l l y . 13 S o N a d i a s t a r t e d u n d r e s s i n g 14 m e i n t h e r o o m . S h e s t a r t e d 15 u n d r e s s i n g m e b y t h e b e d . W e g o t o n 16 t h e b e d . I k i n d o f k n e w w h a t w a s 17 g o i n g o n f r o m t h a t . T h e g i r l s w e r e 18 o f t e n f o r c e d t o h a v e s e x w i t h e a c h 19 o t h e r f o r J e f f r e y ' s p l e a s u r e , s o i t 20 w a s j u s t a n o t h e r o c c a s i o n , I g u e s s . 21 J e f f r e y t h e n w a l k e d i n t h e 22 r o o m . H e s t a r t e d m a s t u r b a t i n g u n d e r 23 h i s c l o t h e s . H e p u t h i s h a n d i n h i s 24 t r o u s e r s . A f e w m i n u t e s l a t e r A l a n 25 w a l k e d i n t h e r o o m . H e s t a r t e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 193 of 469 Highly Confidential Page 193 1 HIGHLY CONFIDENTIAL AEO 2 undressing, he got on the bed with 3 Nadia and myself, and we basically had 4 a three-way sexual interaction. 5 Q. Was Alan fully unclothed? 6 A. During -- when? At what 7 specific -- he walked in with clothes. 8 Q. And he got fully undressed? 9 A. Yes. 10 Q . S o y o u s a w h i s e n t i r e n a k e d 11 b o d y ? 12 A . Y e s . 13 Q . D i d y o u n o t i c e a n y t h i n g 14 s p e c i f i c a b o u t h i s b o d y ? 15 A . N o t t h a t I r e c a l l . I m e a n 16 - - y e a h , n o t t h a t I - - I c a n ' t r e a l l y 17 r e m e m b e r . I t w a s q u i t e a - - i t w a s 18 a - - i t w a s n ' t a p l e a s a n t e x p e r i e n c e . 19 Q . W h a t d i d y o u d o w i t h A l a n ? 20 A . I g a v e h i m o r a l s e x , 21 m a s t u r b a t e d h i m . 22 Q . A n y t h i n g e l s e ? 23 A . H e d i d t h e s a m e w i t h N a d i a . 24 H e p e r f o r m e d t h e s a m e o n m e . 25 Q . D i d h e e j a c u l a t e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 194 of 469 Highly Confidential Page 194 1 HIGHLY CONFIDENTIAL AEO 2 A. He did, yeah. 3 Q. In your mouth? 4 A. No. 5 Q. Did you have intercourse 6 with him? 7 A. No, not penetration, no. 8 Q. Did you see him ejaculate 9 more than once? 10 A . N o , I d i d n ' t s e e h i m 11 e j a c u l a t e m o r e t h a n o n c e . 12 Q . Y o u d i d n ' t n o t i c e a n y s c a r s ? 13 M S . M C C A W L E Y : O b j e c t i o n . 14 A . I d o n ' t r e c a l l s p e c i f i c 15 m a r k i n g s o n e v e r y m a n I ' v e b e e n w i t h 16 b o d y . S o i t ' s n o t s o m e t h i n g - - I 17 w a s n ' t r a v i s h i n g A l a n ' s b o d y . I w a s 18 t r y i n g t o c l o s e m y e y e s a n d j u s t g e t 19 i t d o n e s o I c o u l d g o h o m e a n d w a t c h 20 T V , r e a l l y . S o I w a s n ' t r e a l l y a w a r e . 21 I d i d n ' t r e a l l y l i k e k i n d o f 22 g o , w o o , h i s b o d y . I d o n ' t - - I d o n ' t 23 r e c a l l h i s b o d y a t a l l . L i k e , I d o n ' t 24 m a k e a m e n t a l n o t e o f e v e r y m a n ' s b o d y 25 I ' v e s l e p t w i t h . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 195 of 469 Highly Confidential Page 195 1 HIGHLY CONFIDENTIAL AEO 2 Q. Other than Jeffrey, is that 3 the first time you had sex with 4 another man in his home or on his 5 property? 6 A. Sorry, can you just repeat 7 the question. 8 MR. GUIRGUIS: Or rephrase 9 it. 10 T H E W I T N E S S : I ' l l j u s t r e a d 11 i t . 12 M R . G U I R G U I S : I f y o u 13 u n d e r s t a n d i t . 14 A . Y e a h , h e w a s t h e o n l y 15 p e r s o n , A l a n D e r s h o w i t z . 16 Q . D i d y o u h a v e s e x w i t h h i m 17 m o r e t h a n o n c e ? 18 A . N o . 19 Q . A t t h e o c c a s i o n y o u j u s t 20 d e s c r i b e d , d i d h e h a v e a n e r e c t i o n ? 21 A . I t w a s - - i t w a s - - i t 22 w a s n ' t p a r t i c u l a r l y h a r d . I t w a s 23 p r e t t y d i s a p p o i n t i n g . 24 Q . A n d w h e r e d i d h e e j a c u l a t e ? 25 A . I h a d g i v e n h i m o r a l s e x MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 196 of 469 Highly Confidential Page 196 1 HIGHLY CONFIDENTIAL AEO 2 and, well, he ejaculated -- he 3 ejaculated. I mean, there's only so 4 many places a man can ejaculate. He 5 didn't ejaculate on me. 6 He didn't ejaculate in my 7 mouth. I gave him oral and I 8 masturbated him and finished him off. 9 He ejaculated over himself, me. 10 J u s t - - t h e r e w a s n ' t a l o t o f 11 e j a c u l a t i o n . I d o n ' t r e m e m b e r a l o t 12 o f s p e r m . I d i d n ' t s e e m a s s i v e 13 a m o u n t s o f s e m e n . B u t I j u s t r e m e m b e r 14 h i m e j a c u l a t i n g , b u t i t w a s n ' t i n m y 15 m o u t h . 16 Q . A n d i n t e r m s o f t i m e f r a m e , 17 t h e b e s t y o u c a n s a y i s t h i s i s a f t e r 18 y o u h a d b e e n t o t h e i s l a n d a f e w 19 t i m e s ? 20 A . T h a t ' s c o r r e c t . 21 Q . A n d y o u d o n ' t r e m e m b e r i f i t 22 w a s b e f o r e o r a f t e r y o u w e n t t o S o u t h 23 A f r i c a ? 24 A . I c a n ' t r e m e m b e r 25 s p e c i f i c a l l y , n o . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 197 of 469 Highly Confidential Page 197 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you see Alan Dershowitz 3 again after that one occasion? 4 A. No. 5 Q. So you saw him at the 6 office, you say saw him at dinner, and 7 you saw him that one time in the 8 bedroom at Jeffrey's house? 9 A. That's correct. 10 M S . M E N N I N G E R : I t ' s 1 : 0 0 . 11 I t h i n k w e s h o u l d t a k e a s m a l l 12 l u n c h b r e a k . 13 ( T i m e n o t e d : 1 : 0 1 p . m . ) 14 ( L u n c h e o n r e c e s s . ) 15 16 17 18 19 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 198 of 469 Highly Confidential Page 198 1 HIGHLY CONFIDENTIAL AEO 2 A F T E R N O O N S E S S I O N 3 (Time noted: 1:54 p.m.) 4 MR. GUIRGUIS: Counsel, 5 before you commence with your 6 questioning, I think there's one 7 issue from this morning that the 8 witness wants to correct herself 9 on, so just let her do that now. 10 T H E W I T N E S S : I s a i d e a r l i e r 11 t h a t I w o u l d j u s t l i k e t o c o r r e c t 12 t h a t m y l a w y e r s a r e p a y i n g f o r - - 13 t h e y a r e c o v e r i n g m y h o t e l 14 e x p e n s e . 15 M S . M E N N I N G E R : T h a n k y o u 16 f o r t h a t c l a r i f i c a t i o n . 17 T H E W I T N E S S : A n d - - 18 M R . G U I R G U I S : G o a h e a d . 19 T H E W I T N E S S : A n d m y f l i g h t . 20 M S . M E N N I N G E R : T h a n k y o u . 21 S A R A H R A N S O M E , R E S U M E D , 22 h a v i n g b e e n p r e v i o u s l y a n d d u l y 23 s w o r n , w a s e x a m i n e d a n d t e s t i f i e d 24 f u r t h e r , a s f o l l o w s : 25 C O N T I N U E D E X A M I N A T I O N MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 199 of 469 Highly Confidential Page 199 1 HIGHLY CONFIDENTIAL AEO 2 BY MS. MENNINGER: 3 Q. Going back to your first 4 conversation with Alan Dershowitz, at 5 any point in that conversation, had 6 Mr. Dershowitz agreed to act as your 7 lawyer? 8 A. Yes. 9 Q. Did he do anything in terms 10 o f c o n t a c t i n g a n y o n e o n y o u r b e h a l f ? 11 M R . G U I R G U I S : O b j e c t i o n . 12 D o n o t a n s w e r . 13 Q . W h a t w a s t h e s p e c i f i c l e g a l 14 m a t t e r t h a t y o u w e r e s e e k i n g 15 r e p r e s e n t a t i o n f o r ? 16 M S . M C C A W L E Y : O b j e c t i o n . 17 M R . G U I R G U I S : O b j e c t i o n . 18 D o n o t a n s w e r . 19 Q . W h a t d i d y o u u n d e r s t a n d t h e 20 p u r p o s e o f J e f f r e y E p s t e i n b e i n g i n 21 t h e r o o m f o r d u r i n g t h a t c o n v e r s a t i o n ? 22 A . J e f f r e y w a s t h e r e t o s u p p o r t 23 m e a n d J e f f r e y w a s l o o k i n g a f t e r m e . 24 Q . W h e n y o u e n g a g e d i n s e x u a l 25 c o n d u c t w i t h A l a n D e r s h o w i t z , d i d y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 200 of 469 Highly Confidential Page 200 1 HIGHLY CONFIDENTIAL AEO 2 see any evidence on his body of his 3 surgical procedure? 4 A. I don't recall seeing 5 anything. I can't remember. 6 Q. Did you see any bandages? 7 A. I can't remember. 8 Q. Did you see him bleed 9 through his penis? 10 A . N o t t h a t I r e c a l l . 11 Q . D o y o u r e c a l l s e e i n g 12 M r . D e r s h o w i t z b l e e d t h r o u g h h i s 13 p e n i s ? 14 M S . M C C A W L E Y : O b j e c t i o n , 15 a s k e d a n d a n s w e r e d . 16 A . N o t t h a t I r e c a l l . 17 Q . W h e n y o u w e r e o n t h e i s l a n d , 18 s o m e t i m e l e s s t h a n t e n t i m e s , y o u 19 t h i n k , d i d y o u e v e r u s e a n y d r u g s ? 20 A . N o . 21 Q . D i d y o u u s e c o c a i n e ? 22 A . N o . 23 Q . D i d y o u e v e r g e t t h r o w n o f f 24 t h e i s l a n d f o r u s i n g c o c a i n e ? 25 A . N o . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 201 of 469 Highly Confidential Page 201 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you drink alcohol? 3 A. No. 4 Q. None? 5 A. During on the island, 6 whenever I was around Jeffrey, 7 absolutely not. 8 Q. Other than going to the 9 island, did you travel with Jeffrey 10 a n y w h e r e e l s e ? 11 A . N o . 12 Q . D i d y o u e v e r t r a v e l a n y w h e r e 13 w i t h G h i s l a i n e M a x w e l l ? 14 A . N o . 15 Q . D i d y o u e v e r f l y o n a n 16 a i r p l a n e w i t h G h i s l a i n e M a x w e l l ? 17 A . I d o n ' t - - I d o n ' t r e m e m b e r . 18 Q . Y o u d o n ' t r e m e m b e r a n y t i m e 19 y o u f l e w o n a p l a n e w i t h G h i s l a i n e 20 M a x w e l l ? 21 A . N o , I d o n ' t r e m e m b e r . T h e r e 22 w e r e a l w a y s m a n y p e o p l e o n t h e p l a n e . 23 Q . W h e n y o u r e f e r t o t h e p l a n e , 24 y o u ' r e r e f e r r i n g t o a p r i v a t e p l a n e ? 25 A . J e f f r e y ' s p l a n e , y e s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 202 of 469 Highly Confidential Page 202 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you travel on more than 3 one plane of Jeffrey's? 4 A. Not that I -- no, I don't 5 remember. I don't remember. 6 Q. Can you visualize in your 7 head any other layout of a different 8 type of plane than the one you drew in 9 Defendant's Exhibit 1? 10 A . N o . 11 Q . W h y d i d y o u g o t o S o u t h 12 A f r i c a i n e a r l y 2 0 0 7 ? 13 A . T o v i s i t m y f a m i l y . 14 Q . A n d w h i c h f a m i l y m e m b e r s d i d 15 y o u v i s i t ? 16 A . M y f a t h e r a n d m y s t e p m o t h e r . 17 Q . A n y o n e e l s e ? 18 A . N o . 19 Q . A n y s i b l i n g s ? 20 A . M y y o u n g e r b r o t h e r a n d 21 s i s t e r l i v e d w i t h m y p a r e n t s ; m y d a d 22 a n d m y s t e p m o m a n d t h e i r t w o y o u n g e r 23 c h i l d r e n . 24 Q . D i d y o u s e e a n y s c h o o l 25 f r i e n d s t h e r e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 203 of 469 Highly Confidential Page 203 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Who paid for your plane 4 ticket to go to South Africa? 5 A. Jeffrey did. 6 Q. How did that come about? 7 A. I wanted to see my family, 8 and he funded the plane ticket because 9 he was funding everything else at that 10 t i m e . 11 Q . W h a t e l s e w a s h e f u n d i n g a t 12 t h a t t i m e ? 13 A . A c c o m m o d a t i o n , t r a v e l , 14 t a x i s , f o o d , m y p r e s c r i p t i o n t h a t I 15 h a d t o p a y f o r , f o r t h e p r e s c r i p t i o n 16 t h a t - - p r e s c r i p t i o n d r u g s . 17 Q . H a d y o u t a k e n a n y 18 p r e s c r i p t i o n s f o r m e n t a l h e a l t h 19 d i s o r d e r s b e f o r e O c t o b e r 2 0 0 6 ? 20 A . N o . 21 Q . H a v e y o u t a k e n a n y s i n c e M a y 22 o f 2 0 0 7 ? 23 A . Y e s , I h a v e . 24 Q . W h i c h o n e s ? 25 A . P a r o x e t i n e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 204 of 469 Highly Confidential Page 204 1 HIGHLY CONFIDENTIAL AEO 2 Q. Anything else? 3 MS. MCCAWLEY: I'm going to 4 object. There's no time frame on 5 this. You're talking about one 6 year? All the years from 2007 to 7 2015? Which I would say is 8 inappropriate for a nonparty 9 witness to talk about her -- if 10 y o u ' r e t a l k i n g g e n e r a l l y a b o u t 11 p r e s c r i p t i o n s . 12 Q . A r e y o u o n a n y m e d i c a t i o n s 13 r i g h t n o w ? 14 A . Y e s , I a m . 15 M S . M C C A W L E Y : O b j e c t i o n . 16 Q . W h a t a r e y o u o n r i g h t n o w ? 17 A . P a r o x e t i n e . 18 Q . W h a t ' s t h a t f o r ? 19 A . I t ' s f o r p o s t t r a u m a t i c 20 s t r e s s a n d a n x i e t y . P a r o x e t i n e , a b o u t 21 a y e a r , a y e a r n o w . 22 Q . W a s i t p r e s c r i b e d t o y o u 23 b e f o r e y o u m o v e d t o B a r c e l o n a ? 24 A . Y e s , i t w a s . 25 Q . W h o p r e s c r i b e d i t t o y o u ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 205 of 469 Highly Confidential Page 205 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection. 3 You don't have to answer 4 that. 5 MS. MENNINGER: On what 6 grounds, Counsel? 7 MR. GUIRGUIS: I don't know 8 what period you're talking about. 9 I don't know what doctor you're 10 t a l k i n g a b o u t . I d o n ' t k n o w w h y 11 a n y o f t h i s i s r e l e v a n t . T h a t ' s 12 w h y I ' m o b j e c t i n g . 13 M S . M E N N I N G E R : S o y o u ' r e 14 o b j e c t i n g o n r e l e v a n c e g r o u n d s ? 15 M R . G U I R G U I S : I ' m o b j e c t i n g 16 f o r r e l e v a n c e , a n d a l s o f o r t h e 17 s a m e r e a s o n s t h a t w e r e j u s t 18 e x p l a i n e d b y c o u n s e l f o r 19 p l a i n t i f f , w h i c h i s t h a t t h i s i s 20 a n o n p a r t y w i t n e s s a n d y o u ' r e n o t 21 e v e n p r o f f e r i n g a r e a s o n w h y 22 y o u ' r e a s k i n g t h e q u e s t i o n . 23 S o , y e s , I ' m n o t g o i n g t o 24 l e t t h i s g o t o t a l l y f a r a f i e l d 25 w i t h o u t o b j e c t i o n . I f y o u ' d l i k e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 206 of 469 Highly Confidential Page 206 1 HIGHLY CONFIDENTIAL AEO 2 to proffer a reason, we can talk 3 about it. 4 Q. You've been taking 5 paroxetine for approximately a year? 6 A. Mm-hmm. 7 Q. Did you take any medications 8 between 2007 and 2016 for any mental 9 health disorders? 10 A . Y e s , I d i d . 11 Q . W h a t w e r e t h e y ? 12 A . W h e n I m o v e d b a c k t o t h e U K , 13 i t w a s t h e s a m e p r e s c r i p t i o n d r u g s 14 t h a t J e f f r e y ' s p s y c h i a t r i s t h a d 15 p r e s c r i b e d m e . I c o n t i n u e d o n w i t h m y 16 m e d i c a t i o n e v e n t h o u g h I w a s w r o n g l y 17 d i a g n o s e d . I d i d n ' t k n o w I h a d b e e n 18 w r o n g l y d i a g n o s e d . 19 Q . W h e n d i d y o u l e a r n y o u h a d 20 b e e n w r o n g f u l l y d i a g n o s e d ? 21 A . W h e n I w e n t t o a r e a l 22 d o c t o r . 23 Q . W h e n w a s t h a t ? 24 A . I s a w a p s y c h o l o g i s t a f t e r 25 2 0 0 8 , a n d t h e y t o l d m e t h a t t h e d r u g s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 207 of 469 Highly Confidential Page 207 1 HIGHLY CONFIDENTIAL AEO 2 I had been prescribed were incorrect. 3 Q. Those are the ones you 4 mentioned earlier in your testimony? 5 A. Yeah. I had to stop and 6 change medication, because I was first 7 started on lithium. The lithium made 8 me put on weight at quite a rapid 9 rate, so I was put on so many 10 d i f f e r e n t t y p e s o f m e d i c a t i o n b e c a u s e 11 I d i d n ' t - - n o t e v e r y o n e a g r e e s w i t h 12 y o u . W e i g h t w a s a m a s s i v e i s s u e f o r 13 G h i s l a i n e a n d J e f f r e y , s o t h e l i t h i u m 14 j u s t d i d n ' t w o r k f o r m e . I m e a n , I 15 p u t o n w e i g h t q u i t e q u i c k l y . 16 Q . W h a t d i d G h i s l a i n e M a x w e l l 17 s a y t o y o u a b o u t w e i g h t ? 18 A . W e l l , w h a t d i d s h e n o t s a y ? 19 S h e b u l l i e d m e m a s s i v e l y a b o u t m y 20 w e i g h t . 21 Q . W h a t d i d s e e s a y ? 22 A . I w a s t o l d t h a t I w o u l d l o s e 23 J e f f r e y ' s f i n a n c i n g i f I d i d n ' t l o s e 24 w e i g h t , a n d I w o u l d n o t - - t h e y w o u l d 25 n o t h e l p m e g e t i n t o F I T . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 208 of 469 Highly Confidential Page 208 1 HIGHLY CONFIDENTIAL AEO 2 Q. Who were you told that by? 3 A. Ghislaine and Jeffrey. 4 Q. In the same conversation? 5 A. Various conversations. 6 Q. Tell me your conversations 7 with Ghislaine. When did she say that 8 to you? 9 A. On the island. 10 Q . B e f o r e y o u w e n t t o S o u t h 11 A f r i c a ? 12 A . Y e s . 13 Q . A n d w a s t h a t i n p e r s o n ? 14 A . Y e s . 15 Q . W h o e l s e w a s p r e s e n t ? 16 A . S a r a h K e l l e n , N a d i a , a g i r l 17 n a m e d a n d a g i r l n a m e d . 18 S o r r y , I j u s t r e m e m b e r e d a n a m e . A 19 g i r l n a m e d a n d a g i r l n a m e d 20 . 21 Q . S o t h e y w e r e a l l p r e s e n t 22 w h e n y o u h a d a d i s c u s s i o n w i t h 23 G h i s l a i n e a b o u t y o u r w e i g h t o n t h e 24 i s l a n d ? 25 A . Y e s . - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 209 of 469 Highly Confidential Page 209 1 HIGHLY CONFIDENTIAL AEO 2 Q. And what did Ghislaine say 3 to you about your weight when you were 4 on the island in front of all these 5 people? 6 A. I can't remember the 7 specific conversation, how it went. 8 We got into an argument about my 9 weight, quite a heated argument. 10 Q . W h a t d o y o u r e c a l l a b o u t t h e 11 a r g u m e n t ? 12 A . I r e c a l l i t g o t s o h e a t e d 13 t h a t I r a n o f f a n d t r i e d t o s w i m o f f 14 t h e i s l a n d . I w a n t e d t o g e t a s f a r 15 a w a y f r o m J e f f r e y a n d G h i s l a i n e a s 16 p o s s i b l e . 17 Q . O k a y . A n d t h e n w h a t 18 h a p p e n e d ? 19 A . I l e f t t h e m a i n h o u s e . I 20 t o o k - - t h e r e ' s l i k e a b u g g y t h i n g . 21 I t w a s e v e n i n g . I d r o v e t o a 22 p a r t i c u l a r s p o t o n t h e i s l a n d . I t w a s 23 - - s o J e f f r e y ' s i s l a n d i s q u i t e r o c k y 24 a r o u n d t h e e d g e s , s o - - a n d i t ' s n o t 25 r e a l l y - - y o u c a n ' t j u s t g o i n t o t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 210 of 469 Highly Confidential Page 210 1 HIGHLY CONFIDENTIAL AEO 2 water. It was quite steep. And, 3 well, I didn't really know how to swim 4 away. I didn't know how to escape. 5 But I wanted to, at that precise 6 moment, get as far as away from him as 7 possible. 8 Q. So you had a heated argument 9 about your weight with Ghislaine? 10 A . G h i s l a i n e a n d J e f f r e y . 11 Q . T h e y w e r e b o t h t h e r e ? 12 A . Y e s . 13 Q . A n d d o y o u r e m e m b e r a n y t h i n g 14 t h a t w a s s a i d d u r i n g t h a t a r g u m e n t ? 15 A . I t w a s b a s i c a l l y a n 16 u l t i m a t u m t h a t I e i t h e r l o s e w e i g h t 17 o r - - o r t h a t ' s i t . 18 T H E W I T N E S S : S o r r y , c a n I 19 - - s o r r y . I n e e d t o g e t a 20 h e a d a c h e t a b l e t , i f y o u d o n ' t 21 m i n d . 22 M S . M E N N I N G E R : G o o f f t h e 23 r e c o r d f o r a s e c o n d . 24 ( A n o f f - t h e - r e c o r d 25 d i s c u s s i o n w a s h e l d . ) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 211 of 469 Highly Confidential Page 211 1 HIGHLY CONFIDENTIAL AEO 2 MS. MENNINGER: Go back on. 3 Q. You were given an ultimatum 4 to lose weight or what? 5 A. They wouldn't help me to get 6 into FIT, and that my time with 7 Jeffrey would be -- would end. 8 Q. Who said what? 9 A. Well, they both -- they both 10 s a i d i t i n s o m a n y w o r d s . I c a n ' t 11 r e m e m b e r t h e e x a c t c o n v e r s a t i o n . I 12 r e m e m b e r i t b e i n g h e a t e d . I r e m e m b e r 13 t h e m g i v i n g m e t h e u l t i m a t u m . I t h i n k 14 a f e w c u r s e w o r d s w e r e s h a r e d . I 15 c a n ' t - - i t w a s a v e r y h e a t e d 16 c o n v e r s a t i o n . I c a n ' t r e m e m b e r t h e 17 e x a c t w o r d s . 18 Q . W a s N a t a l y a t h e r e ? 19 A . N o , I d o n ' t r e c a l l h e r b e i n g 20 t h e r e . 21 Q . W e r e y o u t a k i n g t h e 22 m e d i c a t i o n s t h a t y o u t a l k e d a b o u t 23 e a r l i e r d u r i n g t h i s t i m e p e r i o d ? 24 A . Y e s . 25 Q . H a d y o u p u t o n w e i g h t s i n c e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 212 of 469 Highly Confidential Page 212 1 HIGHLY CONFIDENTIAL AEO 2 taking those medications? 3 A. Yes, I had. And I had also 4 put on weight because I wasn't allowed 5 to smoke any cigarettes at all, with 6 Jeffrey on the island or anywhere near 7 Jeffrey. Jeffrey wasn't allowed to 8 know that we smoked. 9 So I put on also a lot of 10 w e i g h t a s w e l l , i n c o n j u n c t i o n w i t h 11 t h e l i t h i u m . S o y e a h . 12 Q . H o w d i d t h e t o p i c o f y o u r 13 w e i g h t c o m e u p ? 14 A . W e l l , I w a s n ' t a s s k i n n y a s 15 t h e o t h e r g i r l s , a n d J e f f r e y l i k e d h i s 16 g i r l s v e r y t h i n . 17 Q . W e r e y o u i n t e r e s t e d i n 18 m o d e l i n g a t t h a t p o i n t i n t i m e ? 19 A . I w a s d o i n g f r e e l a n c e 20 m o d e l i n g a t t h e t i m e , b u t I m e a n , I 21 w a s n ' t e x a c t l y g o i n g t o b e a K a t e 22 M o s s . A n d t h e m o d e l i n g a g e n c y t h o u g h t 23 I w a s n ' t p e t i t e e n o u g h f o r t h e m 24 e i t h e r . 25 I w o u l d l i k e t o c l a r i f y I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 213 of 469 Highly Confidential Page 213 1 HIGHLY CONFIDENTIAL AEO 2 wasn't actually fat; I was normal 3 weight, by the way, just to make that 4 clear. I am 64, 65 kilograms at that 5 time. 6 Q. Why did you understand that 7 Jeffrey and Ghislaine wanted you to 8 lose weight? 9 A. I was one of the girls that 10 J e f f r e y h a d s e x u a l e n c o u n t e r s w i t h 11 r e g u l a r l y . H e l i k e d h i s g i r l s t h i n . 12 Q . D i d y o u a s k J e f f r e y t o h e l p 13 y o u b e c o m e a m o d e l ? 14 A . N o . I w a n t e d t o g e t a 15 d e g r e e a n d a n e d u c a t i o n . 16 Q . S o y o u w e r e n o t a t t e m p t i n g 17 t o b e c o m e a m o d e l a t t h a t p o i n t i n 18 t i m e ? 19 A . N o . I w a n t e d t o g e t a n 20 e d u c a t i o n a s o p p o s e d t o b e i n g a m o d e l . 21 Q . D i d y o u t a l k t o J e a n L u c 22 B r u n e l a b o u t b e c o m i n g a m o d e l ? 23 A . I - - a s I w a s f r e e l a n c i n g 24 d u r i n g t h a t t i m e , o r t r y i n g t o g e t 25 f r e e l a n c i n g w o r k , J e f f r e y k e p t u s o n a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 214 of 469 Highly Confidential Page 214 1 HIGHLY CONFIDENTIAL AEO 2 little string with his massage 3 payments, so I wanted to earn a 4 separate income while I was doing my 5 education to fund my living expenses. 6 So, you know, I wanted to potentially 7 increase my jobs. 8 But no, my job was not to be 9 a high-fashion model. I wanted to get 10 m y d e g r e e , g e t m y e d u c a t i o n a n d w o r k 11 i n t h e f a s h i o n i n d u s t r y . 12 Q . Y o u h a d w o r k e d a s a m o d e l 13 d u r i n g c o l l e g e e a r l i e r , c o r r e c t ? 14 A . Y e s . 15 Q . A n d y o u s a v e d u p m o n e y f r o m 16 t h a t j o b , c o r r e c t ? 17 A . Y e s . 18 Q . A n d y o u h a d u s e d t h a t m o n e y 19 t o f l y t o N e w Y o r k a t s o m e p o i n t , 20 c o r r e c t ? 21 A . Y e s . 22 Q . A n d w h a t y o u ' r e s a y i n g n o w 23 i s y o u w o u l d a l s o p o t e n t i a l l y d o 24 m o d e l i n g w h i l e y o u w e r e s t u d y i n g i n 25 t h e f u t u r e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 215 of 469 Highly Confidential Page 215 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection. 3 That's not at all what she's 4 saying. 5 A. As in future, as in would I 6 do modeling now? 7 Q. No. I'll rephrase the 8 question. 9 A. Please. 10 M S . M E N N I N G E R : L e t ' s t a k e a 11 b r e a k , g o o f f t h e r e c o r d . A n d 12 w h e n y o u f i n i s h t h e s a l a d , w e ' l l 13 p r o c e e d . 14 ( T i m e n o t e d : 2 : 1 4 p . m . ) 15 ( R e c e s s . ) 16 ( T i m e n o t e d : 2 : 1 5 p . m . ) 17 M S . M E N N I N G E R : G o b a c k o n 18 t h e r e c o r d . 19 Q . A t t h e t i m e y o u w e r e h a v i n g 20 a d i s c u s s i o n w i t h J e f f r e y a n d 21 G h i s l a i n e a b o u t y o u r w e i g h t w h e n y o u 22 w e r e o n t h e i s l a n d , d i d y o u h a v e a n y 23 i n t e n t i o n o f b e i n g a m o d e l a t t h a t 24 t i m e ? 25 A . I w a s a f r e e l a n c e m o d e l . I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 216 of 469 Highly Confidential Page 216 1 HIGHLY CONFIDENTIAL AEO 2 wanted to increase my workload to help 3 fund my living expenses. So it was 4 not my intention to be a full-time 5 model, because I quite clearly applied 6 to a college to get an education that 7 I was promised by Jeffrey Epstein. 8 Q. Between January of 2007 and 9 today, have you worked as a model? 10 A . N o . 11 Q . W h e n y o u l e f t f o r S o u t h 12 A f r i c a , d i d y o u h a v e a t i c k e t t o 13 r e t u r n t o t h e U . S . ? 14 A . A t t h a t t i m e , a r e t u r n 15 t i c k e t h a d n ' t b e e n b o o k e d b y J e f f r e y 16 y e t . 17 Q . Y o u t r a v e l e d t o S o u t h A f r i c a 18 t o v i s i t y o u r f a m i l y w i t h o u t a r e t u r n 19 t i c k e t ? 20 A . Y e s . 21 Q . D i d a n y o n e t r a v e l w i t h y o u 22 t o S o u t h A f r i c a ? 23 A . N o . 24 Q . Y o u r m o t h e r w a s n o t i n S o u t h 25 A f r i c a w h e n y o u w e n t t o S o u t h A f r i c a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 217 of 469 Highly Confidential Page 217 1 HIGHLY CONFIDENTIAL AEO 2 on that occasion in 2007, correct? 3 A. Correct. 4 Q. What did you do while you 5 were in South Africa in February of 6 2007? 7 A. Spend time with my family. 8 Q. Anything else? 9 A. I spent time with my family, 10 t h a t ' s - - t h a t ' s i t . 11 Q . D i d y o u v i s i t a n y m o d e l i n g 12 a g e n c i e s ? 13 A . Y e s , I d i d v i s i t s o m e 14 m o d e l i n g a g e n c i e s . 15 Q . W h i c h m o d e l i n g a g e n c i e s d i d 16 y o u v i s i t ? 17 A . I c a n ' t r e m e m b e r t h e e x a c t 18 n a m e s . T h e m o d e l i n g a g e n c i e s w e r e o n 19 L o n g S t r e e t i n C a p e T o w n . I v i s i t e d 20 s e v e r a l m o d e l i n g a g e n c i e s o n L o n g 21 S t r e e t , a n d B r e e S t r e e t a s w e l l . B r e e 22 S t r e e t a n d L o n g S t r e e t a n d a f e w 23 o t h e r s i n c e n t r a l C a p e T o w n . S o I 24 v i s i t e d a f e w , a c t u a l l y . 25 Q . H a d y o u w o r k e d w i t h a n y o f MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 218 of 469 Highly Confidential Page 218 1 HIGHLY CONFIDENTIAL AEO 2 those modeling agencies in the past? 3 A. No. 4 Q. Did you have any connections 5 with any of those modeling agencies? 6 A. No. 7 Q. Did you have an agent at 8 that time? 9 A. No. 10 Q . W h a t d i d y o u d o w h e n y o u 11 v i s i t e d t h e m o d e l i n g a g e n c i e s i n C a p e 12 T o w n i n F e b r u a r y o f 2 0 0 7 ? 13 A . I w a s r e q u e s t e d t o l o o k f o r 14 a P A f o r M r . E p s t e i n . 15 Q . W h a t d o e s t h a t m e a n ? 16 A . I t m e a n s t h a t h e t o l d m e h e 17 w o u l d p a y m e a c e r t a i n a m o u n t o f m o n e y 18 t o f i n d h i m a P A i n S o u t h A f r i c a . 19 Q . W h a t d o y o u u n d e r s t a n d t h e 20 i n i t i a l s P A t o s t a n d f o r ? 21 A . P e r s o n a l a s s i s t a n t . 22 Q . W h a t a r e t h e j o b 23 r e s p o n s i b i l i t i e s o f a p e r s o n a l 24 a s s i s t a n t ? 25 A . T o b o o k f l i g h t s , t y p e , d o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 219 of 469 Highly Confidential Page 219 1 HIGHLY CONFIDENTIAL AEO 2 faxes. Basically a PA is your -- a 3 CEO's right-hand man of, you know, 4 company's -- anything business-wise. 5 They do everything, really, for that 6 person. 7 Q. When did Jeffrey ask you to 8 find him a PA while in South Africa? 9 A. Before I went. 10 Q . D i d y o u a g r e e t o d o t h a t ? 11 A . Y e s . 12 Q . A n d y o u d i d g o t o t h e 13 m o d e l i n g a g e n c i e s ? 14 A . I t o l d J e f f r e y I d i d , b u t I 15 a c t u a l l y - - I w e n t t o a c o u p l e a n d 16 t h e n I j u s t - - i t w a s n ' t r i g h t . M y 17 g u t i n s t i n c t w a s - - y e a h . 18 Q . W h a t h a p p e n e d w h e n y o u w e n t 19 i n s i d e t h e m o d e l i n g a g e n c i e s i n C a p e 20 T o w n ? 21 A . I w a s h u m i l i a t e d . I w a s 22 c o m p l e t e l y e m b a r r a s s e d . I c o u l d n ' t 23 e v e n a s k t h e m w h a t J e f f r e y w a s 24 w a n t i n g . I m e a n , i t w a s s o a b s o l u t e l y 25 r i d i c u l o u s , h i s r e q u e s t o f m e f i n d i n g MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 220 of 469 Highly Confidential Page 220 1 HIGHLY CONFIDENTIAL AEO 2 him a PA. 3 Q. So what happened? 4 A. So I -- I asked if they had 5 any girls that would want to travel; 6 they would be put up in accommodation 7 and they would be a PA. 8 And when I actually spoke to 9 the modeling agencies, they actually 10 l a u g h e d a t m e , b e c a u s e i t w a s q u i t e 11 r i d i c u l o u s t h a t a y o u n g 2 2 - y e a r - o l d 12 w a s a s k i n g a m o d e l i n g a g e n c i e s f o r a 13 1 8 - y e a r - o l d P A f o r a m u l t i - b i l l i o n a i r e 14 w h o h a d s e v e r a l a l r e a d y . 15 Q . S o y o u r e c a l l a c o n v e r s a t i o n 16 w h e r e t h e p e r s o n y o u w e r e s p e a k i n g t o 17 s t a r t e d l a u g h i n g ? 18 A . Y e s . 19 Q . W h a t t y p e o f p e r s o n w e r e y o u 20 d e s c r i b i n g t h a t y o u w e r e l o o k i n g f o r ? 21 A . T h e s a m e s p e c i f i c a t i o n s t h a t 22 J e f f r e y t o l d m e : S h e h a d t o b e 1 8 , 23 t h i n , v e r y y o u n g l o o k i n g , p r e t t y . 24 Q . A n y t h i n g e l s e ? 25 A . W e l l , b r i g h t a n d a b l e t o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 221 of 469 Highly Confidential Page 221 1 HIGHLY CONFIDENTIAL AEO 2 type. 3 Q. Did you go on a diet while 4 you were in South Africa? 5 A. I was forced to go on a 6 diet. 7 Q. Tell me what you mean by 8 forced to go on a diet. 9 A. After that incident on the 10 i s l a n d i n - - i t w a s D e c e m b e r , w h e n 11 G h i s l a i n e b r o u g h t m e b a c k t o t h e m a i n 12 h o u s e a f t e r s h e - - s h e s e n t a s e a r c h 13 p a r t y . S h e l e d a s e a r c h p a r t y t o f i n d 14 m e o n t h e i s l a n d a n d b r i n g m e b a c k . 15 Q . G h i s l a i n e l e d a s e a r c h 16 p a r t y ? 17 A . Y e a h , y e a h , y e a h . S h e g o t 18 e v e r y o n e t o g e t h e r a n d t h e y a l l w e n t 19 l o o k i n g f o r m e w h e n I d i s a p p e a r e d . 20 Q . W h o w e n t l o o k i n g f o r y o u ? 21 A . J e a n L u c , J e f f r e y , t h e 22 g i r l s , G h i s l a i n e . 23 Q . W h i c h g i r l s ? 24 A . a n d t h e g i r l 25 n a m e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 222 of 469 Highly Confidential Page 222 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did Jeffrey go searching for 3 you? 4 A. Yes. 5 Q. How do you know that? 6 A. I was told. 7 Q. About whom? 8 A. By and the other 9 girl. 10 Q . W h e r e w e r e y o u l o c a t e d ? 11 A . O n t h e i s l a n d . 12 Q . W h e r e o n t h e i s l a n d ? 13 A . A c o r n e r o f t h e i s l a n d . 14 Q . O n t h e w a t e r ? 15 A . N o . I t w a s q u i t e a l o n g 16 d r o p o f f t h e - - i t w a s l i k e a 17 c l i f f - t y p e - - I w a s n ' t a b l e t o j u m p o r 18 g e t i n t h e w a t e r . 19 Q . Y o u r i n t e n t w a s t o s w i m o f f 20 t h e i s l a n d , b u t y o u d i d n ' t m a k e i t 21 i n t o t h e w a t e r ? 22 A . N o , b e c a u s e I w o u l d h a v e 23 k i l l e d m y s e l f , s o i t w a s n ' t s a f e . 24 Q . S o w h o l o c a t e d y o u o n t h i s 25 c o r n e r o f t h e i s l a n d ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 223 of 469 Highly Confidential Page 223 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember who got to 3 me first. I remember the -- I can't 4 remember who found me first. 5 Q. Do you remember anyone who 6 found you? 7 A. Yes, I was definitely found 8 because I didn't have enough time to 9 find a different location on the 10 i s l a n d s o I c o u l d g e t o f f a n d s w i m 11 a w a y f r o m J e f f r e y a n d G h i s l a i n e . 12 Q . O n c e t h e y f o u n d y o u , w h a t 13 h a p p e n e d ? 14 A . I w a s b r o u g h t b a c k t o t h e 15 m a i n h o u s e . 16 Q . H o w w e r e y o u b r o u g h t b a c k ? 17 A . T h e s a m e w a y t h a t I g o t 18 t h e r e , o n t h e , l i k e , b e a c h b u g g y , 19 b l a c k 4 - b y - 4 , n o t - - w h a t a r e t h e y . 20 Q u a d t h i n g s . 21 M S . M C C A W L E Y : Q u a d b i k e s ? 22 A . Q u a d b i k e s , y e a h . 23 Q . D i d y o u b i k e b a c k ? 24 A . Y e s . 25 Q . A c c o m p a n i e d b y s o m e p e o p l e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 224 of 469 Highly Confidential Page 224 1 HIGHLY CONFIDENTIAL AEO 2 A. I was accompanied back, yes. 3 Q. By whom? 4 A. I can't remember 5 specifically who it was. 6 Q. Okay. And once you got 7 back, what happened? 8 A. They tried to calm me down. 9 Q. And then what happened? 10 A . F r o m t h a t e v e n i n g o n w a r d s , I 11 w a s - - J e f f r e y p u t m e o n t h e A t k i n s 12 D i e t . 13 Q . D i d y o u c a l m d o w n ? 14 A . Y e s , I d i d . 15 Q . D i d y o u t a k e s o m e m o r e 16 m e d i c a t i o n s ? 17 A . N o . W h e n y o u ' r e o n 18 p r e s c r i p t i o n d r u g s , y o u o n l y t a k e t h e m 19 a t a s p e c i f i c r e q u i r e d t i m e . 20 G e n e r a l l y y o u d o n ' t t a k e m o r e t h a n 21 y o u r p r e s c r i p t i o n w h e n y o u ' r e o n 22 p r e s c r i p t i o n d r u g s , s o y o u d o n ' t k i n d 23 o f j u s t t h r o w t a b l e t s i n y o u r m o u t h . 24 Y o u k i n d o f j u s t t a k e t h e m i n t h e 25 m o r n i n g o r - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 225 of 469 Highly Confidential Page 225 1 HIGHLY CONFIDENTIAL AEO 2 Q. I asked a bad question. 3 A. Yeah. 4 Q. You said earlier that the 5 prescriptions were causing you to gain 6 weight, I thought you said. 7 A. Yes. 8 Q. And then you just said you 9 were put on a diet after this event, 10 c o r r e c t ? 11 A . Y e s . 12 Q . A n d w h a t d o y o u m e a n b y y o u 13 w e r e p u t o n a d i e t ? 14 A . J e f f r e y s a i d , y o u e i t h e r g o 15 o n t h e A t k i n s D i e t , o r I c a n g o . 16 Q . G o m e a n i n g o f f t h e i s l a n d ? 17 A . A s i n , d o n ' t c a l l m e b a c k , 18 S a r a h . 19 Q . H e r e ' s t h e q u e s t i o n : D i d 20 y o u d i s c o n t i n u e t h e m e d i c a t i o n s a t t h e 21 s a m e t i m e y o u w e n t o n t h e A t k i n s D i e t ? 22 A . N o . 23 Q . A n d h o w l o n g w e r e y o u o n t h e 24 A t k i n s D i e t ? 25 A . L o n g e n o u g h f o r m y k i d n e y s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 226 of 469 Highly Confidential Page 226 1 HIGHLY CONFIDENTIAL AEO 2 to be incredibly painful and for me to 3 no longer continue on the diet because 4 it was unsafe to do so. 5 Q. Did you seek medical help 6 for that pain? 7 A. I just took painkillers. 8 Q. What painkillers did you 9 take? 10 A . I c a n ' t r e m e m b e r w h a t 11 p a i n k i l l e r s . 12 Q . P r e s c r i p t i o n o r 13 o v e r - t h e - c o u n t e r ? 14 A . O v e r - t h e - c o u n t e r . 15 Q . W e r e y o u o n t h e d i e t f o r 16 m o r e t h a n a w e e k ? 17 A . Y e s , I w a s . 18 Q . M o r e t h a n a m o n t h ? 19 A . Y e s . 20 Q . M o r e t h a n t w o m o n t h s ? 21 A . I c a n ' t r e m e m b e r . 22 Q . W e r e y o u o n t h e d i e t t h e 23 w h o l e t i m e y o u w e r e i n S o u t h A f r i c a ? 24 A . Y e s . 25 Q . D i d y o u c o n t i n u e o n t h e d i e t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 227 of 469 Highly Confidential Page 227 1 HIGHLY CONFIDENTIAL AEO 2 after you returned? 3 A. Yes. 4 Q. What was the lowest weight 5 that you reached during that period of 6 time on the diet? 7 A. 56 kilograms. 8 Q. Had you ever weighed 9 56 kilograms in your adult life -- 10 A . N o . 11 Q . - - p r e v i o u s l y ? 12 A . N o . 13 Q . H a v e y o u s i n c e ? 14 A . N o . 15 Q . D i d y o u s p e a k t o J e f f r e y 16 a g a i n a b o u t t h a t d i e t ? 17 A . M u l t i p l e t i m e s . 18 Q . W h a t d i d y o u s a y ? 19 A . I c o m p l a i n e d f r e q u e n t l y 20 a b o u t t h e d i e t t h a t h e h a d p u t m e o n , 21 b e c a u s e i t w a s s e r i o u s l y a f f e c t i n g m y 22 p h y s i c a l h e a l t h a s w e l l a s m y m e n t a l 23 h e a l t h . Y e a h , i t ' s a p r e t t y h e c t i c 24 d i e t . 25 Q . T h e t i m e y o u w e r e o n t h i s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 228 of 469 Highly Confidential Page 228 1 HIGHLY CONFIDENTIAL AEO 2 diet, did you have a boyfriend? 3 A. Oh, yeah. Yes. 4 Q. Who was your boyfriend at 5 the time? 6 A. Adam. 7 Q. Ralph? 8 A. That's Andy Ralph. This is 9 Adam. 10 Q . W h a t ' s A d a m ' s l a s t n a m e ? 11 A . I t h i n k i t ' s C a s t e l l a n i . 12 Q . W h e r e d i d h e l i v e ? 13 A . I n t h e U p p e r E a s t S i d e . 14 Q . D i d y o u t a l k t o A d a m a b o u t 15 y o u r d i e t ? 16 A . Y e s . 17 Q . W e r e y o u l i v i n g w i t h A d a m ? 18 A . N o t a t - - n o t w h e n I w a s i n 19 S o u t h A f r i c a . 20 Q . W h e n y o u r e t u r n e d f r o m S o u t h 21 A f r i c a , d i d y o u m o v e i n w i t h A d a m ? 22 A . Y e s , I d i d , t o g e t a w a y f r o m 23 J e f f r e y . 24 Q . A n d w h e r e o n t h e U p p e r E a s t 25 S i d e d i d A d a m l i v e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 229 of 469 Highly Confidential Page 229 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember. 3 Q. Walkup or elevator building? 4 A. Elevator. 5 Q. How big was that apartment? 6 A. It's relatively small. 7 Q. More than one bedroom? 8 A. No, it was just one bedroom. 9 It was a small, tiny apartment. 10 Q . A n d w h a t d i d A d a m d o f o r a 11 l i v i n g ? 12 A . H e w a s a b a n k e r . 13 Q . W h e r e d i d h e w o r k ? 14 A . H e w o r k e d a t - - I c a n ' t 15 r e m e m b e r w h e r e h e w o r k e d . 16 Q . H o w d i d y o u m e e t A d a m ? 17 A . A t a d e l i c a t e s s e n , w h e n I 18 w a s b u y i n g f o o d . 19 Q . H a d y o u s t a r t e d d a t i n g h i m 20 b e f o r e y o u w e n t t o S o u t h A f r i c a ? 21 A . I t h i n k w e h a d g o n e o n a 22 c o u p l e d a t e s o r s o m e t h i n g . 23 Q . W h e r e h a d y o u g o n e o n y o u r 24 d a t e s ? 25 A . I c a n ' t r e m e m b e r . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 230 of 469 Highly Confidential Page 230 1 HIGHLY CONFIDENTIAL AEO 2 Q. When you were in South 3 Africa, did you have contact with 4 Adam? 5 A. Once or twice, like three 6 times. Well, we were sort of seeing 7 each other, so I don't know how many 8 phone times I spoke to him in a month. 9 Yeah, a few times I spoke to Adam. 10 Q . W h e n y o u s p o k e t o h i m , d i d 11 h e a s k y o u t o m o v e i n w i t h h i m w h e n 12 y o u r e t u r n e d ? 13 A . I w o u l d n ' t r e a l l y s a y t h a t . 14 I w o u l d n ' t r e a l l y s a y h e a s k e d m e t o 15 m o v e i n . 16 Q . O k a y . W h a t w o u l d y o u s a y ? 17 A . I a s k e d h i m f o r m e t o m o v e 18 i n w i t h h i m . 19 Q . O k a y . W h i l e y o u w e r e i n 20 S o u t h A f r i c a , d i d y o u r e c e i v e a n y 21 p h o n e c a l l s f r o m J e f f r e y ? 22 A . Y e s . 23 Q . D i d y o u w a n t J e f f r e y t o c a l l 24 y o u t h e r e ? 25 A . Y e s . H e w a s h e l p i n g m e g e t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 231 of 469 Highly Confidential Page 231 1 HIGHLY CONFIDENTIAL AEO 2 into FIT. 3 Q. Any other reason for you to 4 have communications while you were in 5 South Africa? 6 A. I was living in his 7 apartment. 8 Q. In South Africa? 9 A. In New York. 10 Q . S o y o u w a n t e d t o h a v e 11 c o m m u n i c a t i o n s w i t h J e f f r e y w h i l e y o u 12 w e r e i n S o u t h A f r i c a b e c a u s e y o u w e r e 13 l i v i n g i n h i s a p a r t m e n t i n N e w Y o r k ? 14 M S . M C C A W L E Y : O b j e c t i o n . 15 A . A n d h e w a s g o i n g t o - - h e 16 p r o m i s e d t h a t h e w o u l d p a y f o r m y 17 e d u c a t i o n . A n d I w a s s t a y i n g i n h i s 18 a p a r t m e n t a n d h e w a s f u n d i n g m y l i f e , 19 s o o f c o u r s e I w o u l d w a n t h i m t o 20 c o n t a c t m e . 21 A n d , a l s o , h e w a s s t i l l - - 22 h e t o l d m e h e w o u l d p a y f o r m y r e t u r n 23 t i c k e t . S o , y e a h , o f c o u r s e I w a n t e d 24 h i m t o c o n t a c t m e . 25 ( A n o f f - t h e - r e c o r d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 232 of 469 Highly Confidential Page 232 1 HIGHLY CONFIDENTIAL AEO 2 discussion was held.) 3 Q. Did you have an intention 4 while you were in South Africa to go 5 to Miami upon your return? 6 A. I think there was a vague 7 conversation about it, but I had no 8 real intention of going to Miami. I 9 had a conversation with Natalya about 10 i t . 11 Q . W h a t , i f a n y t h i n g , w e r e y o u 12 g o i n g t o d o i n M i a m i ? 13 A . I c a n ' t r e m e m b e r . 14 Q . D i d y o u h a v e a j o b l i n e d u p 15 i n M i a m i ? 16 A . I c a n ' t r e m e m b e r . 17 Q . A n i n t e r n s h i p ? 18 A . I t w a s s o m e t h i n g t o d o w i t h 19 J e f f r e y , t h a t J e f f r e y , N a t a l y a a n d - - 20 i t w o u l d h a v e - - i t w o u l d h a v e - - i t 21 w a s t h r o u g h J e f f r e y , s o m e t h i n g w i t h 22 M i a m i . I c a n ' t r e m e m b e r w h a t i t w a s 23 f o r o r - - I d o n ' t r e m e m b e r . I t 24 d i d n ' t - - i t w a s j u s t a c o n v e r s a t i o n 25 a b o u t M i a m i . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 233 of 469 Highly Confidential Page 233 1 HIGHLY CONFIDENTIAL AEO 2 Q. So not a real firm plan to 3 go to Miami? 4 A. No, no. 5 Q. Were you disappointed when 6 you didn't go to Miami? 7 A. No, no, not at all. 8 Q. And you weren't planning to 9 be a model in Miami, for example? 10 A . N o . 11 Q . Y o u s a i d t h a t J e f f r e y h a d 12 a g r e e d t o p a y f o r y o u r e d u c a t i o n ? 13 A . Y e s . 14 Q . D i d y o u a p p l y t o a n y o t h e r 15 s c h o o l b e s i d e s F I T ? 16 A . N o . 17 Q . D o y o u k n o w w h e t h e r y o u m e t 18 t h e q u a l i f i c a t i o n s t o g e t i n t o F I T ? 19 M R . G U I R G U I S : O b j e c t i o n , 20 f o r m . 21 A . Y e s . 22 M R . G U I R G U I S : 23 C o m p r e h e n s i b i l i t y . 24 M S . M E N N I N G E R : S h e s e e m e d 25 t o u n d e r s t a n d i t j u s t f i n e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 234 of 469 Highly Confidential Page 234 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: I don't know 3 if she did, but fine. 4 Q. Do you know how much FIT was 5 supposed to cost per year? 6 A. No. 7 Q. Did you believe it to be 8 expensive? 9 A. All schools are expensive. 10 Q . Y o u h a d p r e v i o u s l y a t t e n d e d 11 Q u e e n M a r g a r e t C o l l e g e ; i s t h a t r i g h t ? 12 A . Q u e e n M a r g a r e t U n i v e r s i t y . 13 Q . M y a p o l o g i e s . 14 H o w m u c h d i d Q u e e n M a r g a r e t 15 U n i v e r s i t y c o s t ? 16 A . I c a n ' t r e m e m b e r . 17 Q . D i d y o u a p p l y f o r a n y 18 f i n a n c i a l a i d f o r F I T ? 19 A . N o . J e f f r e y w a s c o v e r i n g 20 F I T . 21 Q . T h a t ' s w h a t J e f f r e y t o l d 22 y o u ? 23 A . M u l t i p l e , m u l t i p l e t i m e s . 24 Q . D i d G h i s l a i n e M a x w e l l s a y 25 a n y t h i n g t o y o u w i t h r e g a r d s t o F I T ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 235 of 469 Highly Confidential Page 235 1 HIGHLY CONFIDENTIAL AEO 2 A. It was various 3 conversations. It was known among 4 everyone that I was going to FIT, and 5 Jeffrey -- everyone knew he was 6 helping me to get into FIT. It was 7 common knowledge. 8 Q. You described earlier that 9 Ghislaine was helping review your 10 a p p l i c a t i o n a n d y o u r e s s a y . 11 W a s t h e r e s o m e t h i n g e l s e 12 t h a t s h e w a s d o i n g t o h e l p y o u ? 13 A . W e l l , s h e s a i d s h e w o u l d , 14 b u t w h e t h e r s h e d i d , I h a v e n o i d e a . 15 S h e s a i d s h e w o u l d . W h e t h e r s h e m a d e 16 c a l l s , I d o u b t , b e c a u s e I d i d n ' t e n d 17 u p a t F I T . S o . . . 18 Q . D i d y o u g e t a c c e p t e d t h e r e ? 19 A . I n e v e r h e a r d f r o m a n y o n e a t 20 F I T . 21 Q . Y o u n e v e r g o t a r e s p o n s e ? 22 A . N o . 23 Q . D i d y o u h a v e a n e m a i l 24 a d d r e s s a t t h a t t i m e ? 25 A . Y e s , I d i d . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 236 of 469 Highly Confidential Page 236 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you have a copy of your 3 FIT application? 4 A. I think it's somewhere. I 5 think it's in the email. 6 Q. There's an essay and then 7 there's an application, correct? 8 A. Yes, that's correct. I can 9 find the essay if you want. 10 M R . G U I R G U I S : I t h i n k w e ' v e 11 a l r e a d y p r o d u c e d t h a t e s s a y . 12 Q . W h i l e y o u w e r e i n S o u t h 13 A f r i c a , d i d y o u h a v e a n y p h o n e 14 c o n v e r s a t i o n w i t h G h i s l a i n e ? 15 A . Y e s . 16 Q . W h e n w a s t h a t ? 17 A . T h r o u g h v a r i o u s t i m e s 18 t h r o u g h o u t m y s t a y i n S o u t h A f r i c a . 19 Q . W h a t p h o n e w e r e y o u u s i n g 20 w h i l e y o u w e r e i n S o u t h A f r i c a ? 21 A . I h a d t h e B l a c k B e r r y t h a t 22 t h e y h a d g i v e n m e , a n d t h e y a l s o 23 p h o n e d m y p a r e n t s ' l a n d l i n e a s w e l l . 24 Q . W h o i s t h e y ? 25 A . J e f f r e y , G h i s l a i n e a n d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 237 of 469 Highly Confidential Page 237 1 HIGHLY CONFIDENTIAL AEO 2 Lesley Groff. 3 Q. Did Ghislaine speak to your 4 parents? 5 A. Yes. 6 Q. Who did she speak to? 7 A. I can't remember if she 8 spoke -- I can't remember, actually. 9 I can't remember who she spoke to. 10 Q . H o w d o y o u k n o w t h a t s h e 11 s p o k e t o y o u r p a r e n t s ? 12 A . B e c a u s e I r e m e m b e r i t b e i n g 13 a h u g e t h i n g , a n d m y f a m i l y - - b e c a u s e 14 t h e y c o u l d n ' t q u i t e u n d e r s t a n d w h a t 15 J e f f r e y a n d G h i s l a i n e w e r e d o i n g 16 p a y i n g f o r t h e i r d a u g h t e r ' s e d u c a t i o n , 17 a n d t h e y o b v i o u s l y t h o u g h t - - 18 s u s p e c t e d s o m e t h i n g w a s g o i n g o n . 19 Q . S o h o w d o y o u k n o w t h a t 20 s o m e o n e s p o k e t o y o u r p a r e n t s ? 21 A . B e c a u s e m y p a r e n t s a n d I 22 f o u g h t a b o u t i t . 23 Q . D i d y o u r p a r e n t s t e l l y o u 24 t h a t t h e y s p o k e t o G h i s l a i n e ? 25 A . I - - I c a n ' t r e m e m b e r . I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 238 of 469 Highly Confidential Page 238 1 HIGHLY CONFIDENTIAL AEO 2 remember having a huge row with my 3 family because they had spoken to -- 4 so there were multiple phone calls 5 during the duration of that month, 6 okay. There's not a specific call. 7 There were multiple calls. 8 There were multiple emails. 9 I produced emails during that time 10 f r a m e , b a c k - a n d - f o r t h e m a i l s b e t w e e n 11 L e s l e y G r o f f a n d m y s e l f . S o t h e y 12 w e r e - - t h e y c o n t a c t e d m e r e g u l a r l y . 13 G h i s l a i n e , L e s l e y G r o f f a n d J e f f r e y 14 E p s t e i n p h o n e d m e a f e w t i m e s . 15 Q . D i d y o u r p a r e n t s t e l l y o u 16 t h a t t h e y s p o k e t o G h i s l a i n e ? 17 A . I k n e w w i t h m y o w n - - t h a t 18 t h e y h a d s p o k e n t o G h i s l a i n e . 19 Q . H o w d i d y o u k n o w t h a t ? 20 A . B e c a u s e I k n o w t h a t t h e y h a d 21 s p o k e n . T h e y t o l d m e t h a t t h e y h a d 22 s p o k e n . I k n o w s h e m a d e c o m m u n i c a t i o n 23 w i t h m y f a m i l y . 24 Q . Y o u r f a m i l y t o l d y o u t h a t 25 t h e y h a d s p o k e n t o G h i s l a i n e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 239 of 469 Highly Confidential Page 239 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Objection, 3 asked and answered. 4 A. Yes. 5 Q. Who in your family told that 6 you they had spoken to Ghislaine? 7 A. I can't remember whether it 8 was my stepmother or my father. I 9 cannot remember which one it was. 10 Q . W h a t d i d y o u r s t e p m o t h e r o r 11 f a t h e r t e l l y o u t h e y h a d d i s c u s s e d 12 w i t h G h i s l a i n e ? 13 A . T h a t s h e h a d r e a s s u r e d t h e m 14 t h a t m y e d u c a t i o n w o u l d b e p a i d f o r 15 a n d - - b a s i c a l l y t h a t . Y o u k n o w , t h e y 16 s p e n t a l o t o f t i m e a n d e f f o r t 17 r e a s s u r i n g m y f a m i l y t h e y w e r e n ' t 18 a b u s i n g m e , w h i c h t h e y w e r e , a n d t h a t 19 t h e y w e r e n ' t g o i n g t o t r a f f i c m e , 20 w h i c h t h e y w e r e . 21 S o t h e r e y o u g o . I h a d t o 22 l i e t o m y f a m i l y . 23 Q . W h a t i s y o u r s t e p m o t h e r ' s 24 n a m e ? 25 A . L i n d a R a n s o m e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 240 of 469 Highly Confidential Page 240 1 HIGHLY CONFIDENTIAL AEO 2 Q. And do you have an email 3 address or phone number for her? 4 A. No, I don't. 5 MR. GUIRGUIS: Objection. 6 No current information. Same 7 objection as at the outset of 8 deposition. 9 MS. MENNINGER: Are you 10 i n s t r u c t i n g h e r n o t t o a n s w e r ? 11 M R . G U I R G U I S : I a m 12 i n s t r u c t i n g h e r n o t t o a n s w e r . 13 Q . W h e r e d o e s L i n d a - - 14 M R . G U I R G U I S : A n d I ' m a g a i n 15 o f f e r i n g y o u t o t h e o p p o r t u n i t y 16 t o p r o f f e r a r e a s o n f o r t h e s e 17 q u e s t i o n s . A n d I - - 18 M S . M E N N I N G E R : I ' l l t e l l 19 y o u . Y o u r c l i e n t h a s s i g n e d a n 20 a f f i d a v i t a n d a c o m p l a i n t 21 d i s c u s s i n g t h i s c o n v e r s a t i o n , a n d 22 I ' m a s k i n g f o r c o n t a c t 23 i n f o r m a t i o n f o r a w i t n e s s t o t h e 24 c o n v e r s a t i o n , t h e p e r s o n w h o 25 a c t u a l l y s u p p o s e d l y h a d a p h o n e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 241 of 469 Highly Confidential Page 241 1 HIGHLY CONFIDENTIAL AEO 2 conversation with my client. And 3 you're telling me I can't follow 4 up with those witnesses. 5 Q. So please tell me how to 6 reach your stepmother, Linda Ransome. 7 A. I'm not going to offer you 8 my family's address details. 9 MR. GUIRGUIS: You don't 10 h a v e t o a n s w e r . 11 G o o n . 12 M S . M E N N I N G E R : Y o u m a y c o m e 13 b a c k a n d a n s w e r i t a n o t h e r d a y , 14 b u t . . . 15 Q . W h e r e d o e s L i n d a R a n s o m e 16 l i v e ? 17 A . S h e l i v e s i n C a p e T o w n . 18 Q . W h e r e i n C a p e T o w n ? 19 A . I d o n ' t k n o w . 20 Q . H a v e y o u b e e n i n t o u c h w i t h 21 h e r ? 22 A . N o t r e c e n t l y , n o . 23 Q . W h e n i s t h e l a s t t i m e y o u 24 c o m m u n i c a t e d w i t h h e r ? 25 A . A w h i l e b a c k . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 242 of 469 Highly Confidential Page 242 1 HIGHLY CONFIDENTIAL AEO 2 Q. More than a year? 3 A. Less than a year. 4 Q. Is she still married to your 5 father? 6 A. I presume so. 7 Q. Have you talked to him in 8 the same period of time? 9 A. No. 10 Q . W h y h a v e n ' t y o u t a l k e d t o 11 y o u r f a m i l y i n m o r e t h a n a y e a r ? 12 M S . M C C A W L E Y : O b j e c t i o n . 13 T h i s i s g e t t i n g i n t o h e r c u r r e n t 14 r e l a t i o n s h i p s , w h i c h i s n o t 15 r e l e v a n t t o t h e c a s e a n d a l s o c a n 16 b e u s e d f o r h a r a s s m e n t . 17 Q . W h y h a v e n ' t y o u t a l k e d t o 18 y o u r f a m i l y i n a y e a r ? 19 A . B e c a u s e I c a m e f o r w a r d . 20 Q . W h e n d i d y o u c o m e f o r w a r d ? 21 A . O c t o b e r , a r o u n d O c t o b e r . 22 Q . H a v e y o u s p o k e n t o y o u r 23 f a m i l y s i n c e O c t o b e r ? 24 A . N o . 25 Q . W h e n w a s t h e l a s t t i m e y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 243 of 469 Highly Confidential Page 243 1 HIGHLY CONFIDENTIAL AEO 2 spoke to your father or stepmother 3 before October? 4 A. September. 5 Q. And did you tell them not to 6 contact you or did they tell you not 7 to contact them? 8 A. Well, I didn't -- I 9 basically said to them, either accept 10 m e f o r w h o I a m o r w e n e e d t o s t o p 11 t h i s r e l a t i o n s h i p . 12 Q . W h a t d i d y o u m e a n b y a c c e p t 13 y o u a s y o u a r e ? 14 A . I ' v e m a d e a l o t o f p o o r 15 c h o i c e s , p a r t i c u l a r l y J e f f r e y , b e i n g 16 i n v o l v e d w i t h J e f f r e y E p s t e i n . A n d 17 t h e y f e e l I ' v e c o m e a l o n g w a y f r o m 18 t h a t t i m e , a n d t h e y t h o u g h t t h a t t h e y 19 d i d n ' t w a n t m e g o i n g b a c k t o a t i m e 20 t h a t w a s v e r y t r a u m a t i c f o r m e . 21 Q . D i d t h e y t e l l y o u t h e y w o u l d 22 n o t b e i n t o u c h w i t h y o u g o i n g 23 f o r w a r d ? 24 A . I d i d n ' t g i v e t h e m t h a t 25 o p t i o n f o r t h e m t o t e l l m e t h a t . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 244 of 469 Highly Confidential Page 244 1 HIGHLY CONFIDENTIAL AEO 2 Q. So your not having a 3 conversation with your father and 4 stepmother in a year is because of 5 your choice to come forward? 6 A. That's correct. 7 Q. What about your mother? 8 MR. GUIRGUIS: Objection to 9 form. 10 A . W h a t a b o u t m y m o t h e r ? 11 Q . H a v e y o u h a d c o n t a c t w i t h 12 h e r i n a y e a r ? 13 A . Y e s . 14 Q . W h e n w a s t h e l a s t t i m e y o u 15 h a d c o n t a c t w i t h y o u r m o t h e r ? 16 A . L a s t w e e k . 17 Q . W h e n y o u r e t u r n e d t o N e w 18 Y o r k a n d m o v e d i n w i t h A d a m , d i d y o u 19 t a l k t o A d a m a b o u t J e f f r e y E p s t e i n ? 20 A . Y e s . 21 Q . W h a t d i d y o u t e l l A d a m ? 22 A . I t o l d h i m t h a t I w a s 23 f r i g h t e n e d . 24 H e w a s i n c r e d i b l y c o n c e r n e d 25 a b o u t m y w e i g h t l o s s a n d a b o u t t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 245 of 469 Highly Confidential Page 245 1 HIGHLY CONFIDENTIAL AEO 2 weight goal that Jeffrey and Ghislaine 3 set for me, which was 52 kilograms. 4 He was scared for me, actually. 5 Q. To your knowledge, did he 6 contact anyone about it? 7 A. Not to my knowledge. 8 Q. What did he do about his 9 concern, to your knowledge? 10 A . I b e g g e d h i m i f I c o u l d l i v e 11 w i t h h i m , a n d h e a g r e e d . 12 Q . H o w l o n g d i d y o u l i v e w i t h 13 h i m ? 14 A . I t w a s n ' t r e a l l y l o n g , 15 b e c a u s e I m o v e d i n w i t h h i m a f t e r 16 S o u t h A f r i c a . S o a b o u t a m o n t h o r 17 s o m e t h i n g . 18 Q . F r o m t h e t i m e y o u r e t u r n e d 19 f r o m S o u t h A f r i c a t o w h e n y o u r e t u r n e d 20 t o S o u t h A f r i c a ? 21 A . O h . Y e a h , n o , w e o n l y k i n d 22 o f w e n t - - w e o n l y d a t e d f o r b r i e f l y . 23 I t w a s n ' t a s e r i o u s r e l a t i o n s h i p . 24 Y e a h . S o w h e n I m o v e d t o N e w Y o r k - - 25 s o r r y , b a c k t o L o n d o n , k i n d o f o u r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 246 of 469 Highly Confidential Page 246 1 HIGHLY CONFIDENTIAL AEO 2 relationship couldn't really go 3 anywhere, I guess. 4 Q. The long distance? 5 A. Yeah, long distance doesn't 6 really work, so... 7 Q. So about the time you moved 8 back to London is when you and he 9 broke up? 10 A . T h a t ' s c o r r e c t . 11 Q . H a v e y o u h a d c o n t a c t w i t h 12 h i m s i n c e t h e n ? 13 A . I h a d c o n t a c t w i t h h i m a g a i n 14 i n 2 0 0 8 . 15 Q . D i d y o u c o m e b a c k t o t h e 16 U . S . t h e n ? 17 A . N o . 18 Q . Y o u d i d n o t c o m e b a c k t o t h e 19 U . S . i n 2 0 0 8 ? 20 A . O h , I d i d , s o r r y , f o r a 21 b u s i n e s s t r i p . I w e n t - - I d i d a 22 t o u r , y e a h , f r o m - - I t h i n k i t w a s 23 A t l a n t i c t o A t l a n t a t o S a n F r a n c i s c o . 24 Q . W i t h w h i c h b u s i n e s s ? 25 A . B e l f a i r s I n t e r n a t i o n a l . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 247 of 469 Highly Confidential Page 247 1 HIGHLY CONFIDENTIAL AEO 2 It's a private company at that time 3 that did private planes, the interiors 4 of private planes. 5 (An off-the-record 6 discussion was held.) 7 Q. One more time. Can you 8 spell that? 9 A. Sorry. B-A-R- -- sorry, B￾10 - - s o r r y . I t ' s g e t t i n g s o b a d . I ' m , 11 l i k e , r e a l l y b a d a t s p e l l i n g . I t ' s 12 B - E - L - F - A - I - R - S , B e l f a i r s 13 I n t e r n a t i o n a l . 14 Q . Y o u w e r e w o r k i n g w i t h t h e m 15 i n 2 0 0 8 ? 16 A . B r i e f l y . 17 Q . A n d y o u c a m e f o r a b u s i n e s s 18 t r i p ? 19 A . Y e s . 20 Q . A n d h o w l o n g w e r e y o u i n t h e 21 U . S . o n t h a t o c c a s i o n ? 22 A . G o s h , I c a n ' t r e m e m b e r . I t 23 w a s l i k e a w e e k . 24 Q . A n d w h o d i d y o u c o m e w i t h ? 25 A . M y m a n a g e r o f b u s i n e s s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 248 of 469 Highly Confidential Page 248 1 HIGHLY CONFIDENTIAL AEO 2 Q. What was that person's name? 3 A. David. 4 Q. What's the last name? 5 A. I can't remember the last 6 name. 7 Q. So you came back to the U.S. 8 in 2008, but you did not have contact 9 with Adam on that trip? 10 A . N o . 11 Q . W h e n d i d y o u h a v e c o n t a c t 12 w i t h A d a m i n 2 0 0 8 ? 13 A . H e m o v e d t o L o n d o n i n 2 0 0 8 . 14 Q . D i d y o u s e e h i m i n L o n d o n ? 15 A . Y e s , I d i d . 16 Q . W h e r e d i d y o u s e e h i m ? 17 A . H e c a m e t o s t a y w i t h m e i n 18 L o n d o n . 19 Q . D i d y o u r e s u m e y o u r 20 r e l a t i o n s h i p ? 21 A . B r i e f l y . 22 Q . I s t h a t t h e l a s t t i m e y o u ' v e 23 h a d c o n t a c t w i t h h i m ? 24 A . Y e s . 25 Q . W a s t h a t a b o u t t h e t i m e y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 249 of 469 Highly Confidential Page 249 1 HIGHLY CONFIDENTIAL AEO 2 became engaged to -- 3 A. Andy. 4 Q. -- Andy? 5 A. Andy and I got together at 6 the end of 2008. We didn't meet and 7 then get engaged immediately. It was 8 like we dated and then got engaged. 9 Q. Understood. 10 I n a d d i t i o n t o d i s c u s s i n g 11 J e f f r e y w i t h A d a m , i s t h e r e s o m e o n e 12 e l s e y o u d i s c u s s e d J e f f r e y w i t h i n 13 y o u r l i f e i n 2 0 0 6 o r 2 0 0 7 ? 14 A . W e l l , I d i s c u s s e d i t w i t h 15 e v e r y o n e I k n e w . I t ' s q u i t e a n a m a z - 16 - - h e ' s a n a m a z i n g m a n . Y e a h , 17 e v e r y o n e I k n e w k n e w t h a t I w a s 18 i n v o l v e d w i t h J e f f r e y E p s t e i n . 19 E v e r y o n e t h a t I m e t i n N e w Y o r k k n e w 20 t h a t I w a s a f f i l i a t e d w i t h J e f f r e y 21 E p s t e i n a n d G h i s l a i n e M a x w e l l . 22 Q . M o r e s p e c i f i c a l l y , w h o d i d 23 y o u t e l l t h a t y o u h a d c o n c e r n s a b o u t 24 y o u r r e l a t i o n s h i p w i t h J e f f r e y ? 25 A . M y f r i e n d P a m . A n d t h e r e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 250 of 469 Highly Confidential Page 250 1 HIGHLY CONFIDENTIAL AEO 2 were a few other friends I had at the 3 time, but I don't remember their 4 names. 5 Q. Did you discuss it with 6 Pumla? 7 A. Yes. 8 Q. What did you tell Pumla? 9 A. Everything that Jeffrey did 10 t o m e . I t o l d h e r e v e r y s i n g l e d e t a i l 11 o n h o w h e a b u s e d m e . 12 Q . H o w d i d J e f f r e y a b u s e y o u ? 13 A . T h e r e w e r e t i m e s t h a t I w a s 14 - - I m e a n , l o o k , I w a s i n t i m i d a t e d . I 15 w a s f r i g h t e n e d o f J e f f r e y , o k a y . I 16 w a n t e d t o g o t o F I T , g e t a n e d u c a t i o n . 17 B u t i f I d i d n ' t c o m p l y w i t h J e f f r e y ' s 18 r e q u e s t s , I w a s s c a r e d . O k a y ? 19 S o h o w d i d h e a b u s e m e ? 20 W h e n h e h a d m e o n , l i k e , t h e m a s s a g e 21 t a b l e , I h a d n o o p t i o n . S o h o w d i d h e 22 a b u s e m e ? B y p u t t i n g a v i b r a t o r a n d 23 p u s h i n g i t d o w n o n m y c l i t o r i s f o r t e n 24 m i n u t e s , t h a t ' s a b u s e . T h a t w a s n o t 25 p l e a s u r a b l e ; t h a t w a s e x c e p t i o n a l l y MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 251 of 469 Highly Confidential Page 251 1 HIGHLY CONFIDENTIAL AEO 2 painful. He hurt me physically and he 3 abused me mentally, both. 4 Q. How did he abuse you 5 mentally? 6 A. Jeez. Well, I think the 7 fact that -- A, physical abuse always 8 leads to mental abuse. It's a fact. 9 So you can't physically abuse someone 10 a n d t h e y c a n ' t b e m e n t a l l y , b e c a u s e 11 t h e y w i l l - - w i t h o u t a d o u b t , I ' m s u r e 12 m y s e l f a n d a l l t h e o t h e r g i r l s w i l l 13 h a v e s u f f e r e d s o m e f o r m o f 14 p o s t t r a u m a t i c s t r e s s . 15 S o i n t e r m s o f h o w d i d h e 16 m e n t a l l y a b u s e m e ? H e b u l l i e d m e . H e 17 w e n t o n a b o u t m y w e i g h t . H e 18 i n t i m i d a t e d m e . H e p r o m i s e d m e t h i n g s 19 h e d i d n ' t d e l i v e r . I m e a n , I c o u l d g o 20 o n . S o . . . 21 Q . W h a t t h i n g s d i d h e p r o m i s e 22 y o u t h a t h e d i d n ' t d e l i v e r ? 23 A . A n e d u c a t i o n . 24 Q . A n d w h a t d o y o u k n o w a b o u t 25 w h a t h e d i d o r d i d n ' t d o t o g e t y o u a n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 252 of 469 Highly Confidential Page 252 1 HIGHLY CONFIDENTIAL AEO 2 education? 3 A. Well, I didn't go to FIT, so 4 I presume not very much. 5 Q. Do you know why you didn't 6 get into FIT? 7 A. No, no. It just didn't ever 8 materialize. 9 Q. Did you ever contact FIT to 10 f i n d o u t ? 11 A . D u r i n g t h a t t i m e , J e f f r e y 12 h a d i t i n h a n d . I d i d n ' t t h i n k I 13 n e e d e d t o c o n t a c t a n y b o d y a t F I T . I 14 m e a n , J e f f r e y - - i t w a s J e f f r e y ' s 15 c o n t a c t i n t h e f i r s t p l a c e t h a t h e w a s 16 c o n t a c t i n g . S o I d i d n ' t c o n t a c t 17 a n y o n e a t F I T . 18 Q . Y o u d i d n ' t c o n t a c t t h e m a t 19 a l l ? 20 A . W e l l , n o , b e c a u s e J e f f r e y 21 s a i d t h a t h e w a s g o i n g t o d o t h a t f o r 22 m e t o g e t m e i n t o F I T . 23 Q . A n d h o w d i d y o u e v e r c o n f i r m 24 o r d e n y t h a t y o u w e r e n ' t a d m i t t e d t o 25 F I T ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 253 of 469 Highly Confidential Page 253 1 HIGHLY CONFIDENTIAL AEO 2 A. I was never told. I was 3 never given a letter. I didn't have 4 anyone phone me. I didn't have the 5 contact that Jeffrey had been speaking 6 to about getting me in. She didn't 7 contact me. So I'm presuming as an 8 educated woman it was all hearsay, 9 because nothing ever materialized from 10 t h a t . 11 Q . D i d F I T h a v e y o u r a d d r e s s a t 12 A d a m ' s ? 13 A . N o t t h a t I r e c a l l . 14 Q . D i d y o u g i v e J e f f r e y y o u r 15 a d d r e s s a t A d a m ' s ? 16 A . Y e s , J e f f r e y k n e w w h e r e I 17 l i v e d . 18 Q . I u n d e r s t o o d y o u w e r e g o i n g 19 t o l i v e w i t h A d a m i n o r d e r t o g e t a w a y 20 f r o m J e f f r e y . 21 A . S o w h e n - - s o b a s i c a l l y w h e n 22 y o u l i v e i n s o m e o n e ' s a p a r t m e n t , i t ' s 23 a f o r m o f c o n t r o l . S o w h e n y o u d o n ' t 24 c o m p l y w i t h t h e i r i n s t r u c t i o n s a l l t h e 25 t i m e , h u n d r e d p e r c e n t , i t ' s l i k e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 254 of 469 Highly Confidential Page 254 1 HIGHLY CONFIDENTIAL AEO 2 leverage for them to control you. 3 I don't like being 4 controlled by people, especially by 5 someone like Jeffrey Epstein and 6 Ghislaine Maxwell. 7 So Jeffrey Epstein, he knew 8 where I was all the time, so... 9 Q. Did Jeffrey come to Adam's 10 a p a r t m e n t ? 11 A . H e c a m e a r o u n d t h e U p p e r 12 E a s t S i d e n e a r t h e a p a r t m e n t , y e s , h e 13 d i d . T h e r e w a s a n o c c a s i o n t h a t 14 J e f f r e y E p s t e i n p i c k e d m e u p w h e n I 15 d i d n ' t g o t o t h e m a n s i o n . 16 Q . P i c k e d y o u u p w h e r e ? 17 A . I c a n ' t r e m e m b e r t h e 18 l o c a t i o n . 19 Q . J e f f r e y l i v e d o n t h e U p p e r 20 E a s t S i d e ? 21 A . I c a n ' t r e m e m b e r w h e r e 22 J e f f r e y - - h i s e x a c t l o c a t i o n i s . I 23 m e a n , i t ' s a n i c e - - I t h i n k i t ' s n e a r 24 5 t h . I t ' s n e a r 5 t h A v e n u e . 25 Q . W a s i t o n t h e U p p e r E a s t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 255 of 469 Highly Confidential Page 255 1 HIGHLY CONFIDENTIAL AEO 2 Side? 3 A. I think. I don't think it 4 was on the West Side. So hang on. So 5 5th Avenue is there. Is the West Side 6 that side? 7 I don't know -- sorry. I'm 8 really -- I'm a tourister, so I don't 9 know. I don't know where Jeffrey -- I 10 k n o w t h a t h e ' s g o t - - i t w a s n e a r 5 t h 11 A v e n u e . T h a t ' s w h e r e I k n o w h i s 12 a p a r t m e n t w a s . 13 I ' m n o t a N e w Y o r k e r , s o . . . 14 Q . D o y o u r e c a l l a n o c c a s i o n 15 w h i l e y o u w e r e l i v i n g w i t h A d a m t h a t 16 J e f f r e y c a m e a n d p i c k e d y o u u p ? 17 A . Y e s . 18 Q . S o m e w h e r e o n t h e U p p e r E a s t 19 S i d e ? 20 A . Y e s . 21 Q . Y o u d o n ' t k n o w w h e r e ? 22 A . N o , I d o n ' t k n o w t h e 23 s p e c i f i c s t r e e t , n a m e o r p a v e m e n t t h a t 24 I w a s s t a n d i n g o n , n o , I d o n ' t . 25 Q . W h e r e d i d y o u g o w i t h MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 256 of 469 Highly Confidential Page 256 1 HIGHLY CONFIDENTIAL AEO 2 Jeffrey when he picked you up on the 3 Upper East Side? 4 A. I got in his car and went 5 back to his mansion. 6 Q. What kind of car was it? 7 A. It was a -- I can't remember 8 what car it was. 9 Q. Who was driving the car? 10 A . H e w a s n ' t d r i v i n g . I c a n ' t 11 r e m e m b e r w h o w a s d r i v i n g . 12 Q . W a s a n y o n e e l s e i n t h e c a r ? 13 A . S o m e o n e w a s d r i v i n g t h e c a r . 14 Q . A n y o n e e l s e ? 15 A . I c a n ' t r e m e m b e r a n y o n e 16 e l s e . 17 Q . W h a t w a s t h e p u r p o s e o f y o u r 18 g o i n g b a c k t o t h e m a n s i o n o n t h a t 19 o c c a s i o n ? 20 A . I d o n ' t k n o w . Y o u ' r e g o i n g 21 t o h a v e t o a s k J e f f r e y . 22 Q . W h y d i d y o u g e t i n t h e c a r ? 23 A . B e c a u s e I w a s f r i g h t e n e d . 24 Q . W h a t w e r e y o u f r i g h t e n e d o f ? 25 A . T h e f a c t t h a t h e h a d f o u n d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 257 of 469 Highly Confidential Page 257 1 HIGHLY CONFIDENTIAL AEO 2 me and wasn't supposed to know where I 3 was. So I was incredibly intimidated 4 that he drove up beside me and knew 5 where I was. 6 Q. You were somewhere out on 7 the street visible and he found you? 8 A. No. I was supposed to meet 9 Jeffrey. I was instructed to meet 10 J e f f r e y . I f a i l e d t o t u r n u p t o m e e t 11 J e f f r e y a n d J e f f r e y f o u n d m e . 12 Q . W h o i n s t r u c t e d y o u t o m e e t 13 J e f f r e y ? 14 A . I t w a s o n e o f t h e g i r l s . I t 15 w a s e i t h e r S a r a h K e l l e n o r L e s l e y 16 G r o f f . 17 Q . H o w d i d t h e y i n s t r u c t y o u t o 18 m e e t J e f f r e y ? 19 A . V i a t h e B l a c k B e r r y t h e y g a v e 20 m e . 21 Q . Y o u k e p t t h e B l a c k B e r r y 22 a f t e r y o u r e t u r n e d f r o m S o u t h A f r i c a ? 23 A . Y e s , I d i d . 24 Q . W h i l e y o u w e r e l i v i n g w i t h 25 A d a m ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 258 of 469 Highly Confidential Page 258 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. Why did you keep the 4 BlackBerry after you were living with 5 Adam? 6 A. Because Jeffrey and I were 7 still in contact. 8 Q. What were you in contact 9 about? The FIT application? 10 A . H e w a s t r y i n g t o g e t m e a 11 v i s a , a n d h e - - h e d e v i s e d a w a y o f m e 12 g e t t i n g - - I d o n ' t k n o w w h a t y o u c a l l 13 i t , s o r r y - - a n a p p r e n t i c e s h i p , a n 14 i n t e r n s h i p w i t h a c o s m e t i c c o m p a n y . 15 Y e a h , a c o s m e t i c a g e n c y , d o c t o r ' s 16 m e d i c a l f a c i l i t y . 17 Q . W h e n y o u c a m e b a c k f r o m 18 S o u t h A f r i c a i n F e b r u a r y o f 2 0 0 7 , d i d 19 y o u h a v e a t o u r i s t v i s a ? 20 A . Y e a h , y e s . 21 Q . S o J e f f r e y w a s t r y i n g t o 22 h e l p y o u g e t a j o b s o y o u c o u l d g e t a 23 d i f f e r e n t k i n d o f v i s a ? 24 A . Y e a h . W e l l , y o u c a n ' t l i v e 25 i n N e w Y o r k o n a t o u r i s t v i s a . I t ' s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 259 of 469 Highly Confidential Page 259 1 HIGHLY CONFIDENTIAL AEO 2 three months, so -- so I don't know 3 what it's like anymore, the laws. But 4 back then, if you wanted to tour 5 America, you would go and fill -- I 6 think it was 90 days, but then you 7 would have to leave. You couldn't 8 stay. 9 And Jeffrey was trying to 10 g e t m e a - - i t ' s d i f f i c u l t , n o t 11 b e i n g - - i t ' s d i f f i c u l t a c t u a l l y g o i n g 12 t o u n i v e r s i t y h e r e i f y o u d o n ' t h a v e a 13 B r i t i s h - - I d o n ' t k n o w t h e s y s t e m . I 14 j u s t d i d n ' t h a v e a v i s a I c o u l d g o t o 15 F I T . 16 A n d t h i s f r i e n d o f h i s t h a t 17 o w n e d a c o s m e t i c s u r g e r y , h e h a d 18 o r g a n i z e d t h a t I w o u l d g o i n a n d d o a n 19 i n t e r n s h i p , a n d t h a t w a y w o u l d b e a 20 l e g i t i m a t e w a y t o - - f o r m e t o g e t a 21 v i s a , f o r m e t o s t a y a n d c o n t i n u e i n 22 F I T . I f t h a t m a k e s s e n s e . 23 Q . W h a t w a s t h e n a m e o f t h a t 24 f r i e n d ? 25 M R . G U I R G U I S : D o y o u n e e d a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 260 of 469 Highly Confidential Page 260 1 HIGHLY CONFIDENTIAL AEO 2 break? 3 THE WITNESS: I do, sorry. 4 Do you mind? 5 MS. MENNINGER: There was a 6 question pending. 7 MR. GUIRGUIS: She has a 8 question pending. You can answer 9 that, then. Go ahead. 10 W h a t w a s t h e n a m e o f t h a t 11 f r i e n d ? 12 T H E W I T N E S S : I d o n ' t k n o w . 13 I t w a s a m a n . 14 Q . D i d y o u e n d u p w o r k i n g i n 15 t h a t i n t e r n s h i p ? 16 A . N o . 17 Q . D i d y o u e v e r m e e t w i t h t h a t 18 m a n ? 19 A . Y e s . 20 Q . W h y d i d n ' t y o u e n d u p 21 w o r k i n g i n t h a t i n t e r n s h i p w i t h t h a t 22 m a n ? 23 A . I w a n t e d t o r e t u r n h o m e . 24 M R . G U I R G U I S : C a n w e t a k e 25 t h a t b r e a k ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 261 of 469 Highly Confidential Page 261 1 HIGHLY CONFIDENTIAL AEO 2 MS. MENNINGER: Yes. 3 (Time noted: 3:04 p.m.) 4 (Recess.) 5 (Time noted: 3:20 p.m.) 6 MS. MENNINGER: Going back 7 on the record. 8 MR. GUIRGUIS: Before you 9 proceed with your questions, 10 C o u n s e l , I r a i s e d a n o b j e c t i o n t o 11 p r o v i d i n g L i n d a R a n s o m e ' s e m a i l 12 a d d r e s s b e f o r e . T h e n y o u 13 p r o f f e r e d a r e a s o n f o r i t . 14 I a c c e p t y o u r p r o f f e r a n d I 15 w i l l p r o v i d e y o u t h a t e m a i l 16 a d d r e s s n o w , o r h a v e t h e w i t n e s s 17 d o i t . 18 M S . M E N N I N G E R : O k a y . 19 T H E W I T N E S S : I t ' s 20 21 ( A n o f f - t h e - r e c o r d 22 d i s c u s s i o n w a s h e l d . ) 23 M R . G U I R G U I S : A n d l e t t h e 24 r e c o r d r e f l e c t s h e ' s t a k i n g i t 25 d o w n f r o m a G o o g l e s e a r c h o n t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 262 of 469 Highly Confidential Page 262 1 HIGHLY CONFIDENTIAL AEO 2 web. She believes that's right. 3 Q. What is your father's email 4 address? 5 A. I don't remember it offhand. 6 MS. MENNINGER: Can you mark 7 this. 8 (Defendant's Exhibit 3, 9 affidavit, was marked for 10 i d e n t i f i c a t i o n . ) 11 Q . D o y o u r e c o g n i z e t h e 12 d o c u m e n t w e m a r k e d a s D e f e n d a n t ' s 13 E x h i b i t 3 ? 14 A . Y e s . 15 Q . W h a t i s i t ? 16 A . M y a f f i d a v i t . 17 Q . W h o w r o t e t h i s a f f i d a v i t ? 18 A . W e l l , I - - I - - I d i d n ' t 19 t y p e i t u p , b u t I g a v e t h e a f f i d a v i t . 20 Q . S o y o u s p o k e w o r d s t o 21 s o m e o n e e l s e a n d t h e y t y p e d i t ? 22 A . Y e s . 23 Q . W h o w a s t h a t p e r s o n ? 24 A . I d o n ' t k n o w . 25 Q . W h o w a s t h e p e r s o n y o u g a v e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 263 of 469 Highly Confidential Page 263 1 HIGHLY CONFIDENTIAL AEO 2 words to? 3 MR. GUIRGUIS: Was it an 4 attorney? 5 THE WITNESS: Yes. 6 MR. GUIRGUIS: Okay. 7 Q. Which attorney? 8 MR. GUIRGUIS: I think I'm 9 going to object to that. I don't 10 k n o w t h a t i t m a t t e r s w h i c h 11 a t t o r n e y o r w h i c h a t t o r n e y 12 p r o v i d e d t h e w o r k o r d i d s p e c i f i c 13 t a s k s . I t h i n k t h a t ' s 14 p r i v i l e g e d . 15 Q . D i d y o u c o m m u n i c a t e t h e s e 16 w o r d s t o a a t t o r n e y w i t h t h e i n t e n t 17 t h a t t h e y w o u l d p u t i t i n t o a n 18 a f f i d a v i t t h a t y o u w o u l d s h a r e 19 p u b l i c l y ? 20 A . I d o n ' t k n o w t h a t t h e 21 a f f i d a v i t i s p u b l i c , b u t t o s h a r e 22 w i t h - - w i t h y o u g u y s . 23 Q . W i t h a t h i r d p a r t y ? 24 A . Y e a h , w i t h a t h i r d p a r t y . 25 Q . A n d y o u k n e w t h a t a t t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 264 of 469 Highly Confidential Page 264 1 HIGHLY CONFIDENTIAL AEO 2 time you were giving the words to the 3 person to type up? 4 A. Yeah, to give to you guys. 5 Q. So who was the person that 6 you were speaking to that took down 7 the words for your affidavit? 8 A. Sorry. It was Stan and 9 Brad. 10 Q . A n d w h e n d i d y o u h a v e t h a t 11 c o n v e r s a t i o n w i t h t h e m ? 12 A . I t h i n k i t w a s e i t h e r - - I 13 t h i n k i t w a s i n J a n u a r y . 14 Q . L a s t m o n t h ? 15 A . O h , G o d . L a s t m o n t h . Y e a h , 16 l a s t m o n t h . 17 Q . I n p e r s o n ? 18 A . I n p e r s o n . 19 Q . D i d t h e y g i v e y o u m u l t i p l e 20 d r a f t s o f t h i s d o c u m e n t ? 21 A . I w o u l d n ' t s a y m u l t i p l e , b u t 22 I m a d e s u r e t h a t i t w a s a c c u r a t e . 23 Q . D i d y o u m a k e a n y c h a n g e s t o 24 t h e d o c u m e n t y o u w e r e o r i g i n a l l y 25 p r e s e n t e d w i t h ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 265 of 469 Highly Confidential Page 265 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. The first document that you 4 were presented with, is that the one 5 that you signed? 6 A. Yes. 7 Q. And nothing was changed 8 after you reviewed it? 9 A. No. 10 Q . I s t h a t y o u r s i g n a t u r e o n 11 t h e s e c o n d p a g e ? 12 A . Y e s , t h a t i s m y s i g n a t u r e . 13 Q . A n d t h e l a s t p a g e , i s t h a t 14 t h e o f f i c i a l i n S p a i n w h o w i t n e s s e d 15 y o u r s i g n a t u r e ? 16 A . Y e s . 17 Q . D i d y o u s i g n p a g e 2 i n f r o n t 18 o f t h e p e r s o n i n d i c a t e d o n p a g e 3 ? 19 A . Y e s . 20 Q . D i d y o u p r e s e n t t h a t p e r s o n 21 w i t h s o m e f o r m o f i d e n t i f i c a t i o n ? 22 A . Y e s . 23 Q . W h a t f o r m o f i d e n t i f i c a t i o n 24 d i d y o u p r e s e n t ? 25 A . M y p a s s p o r t . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 266 of 469 Highly Confidential Page 266 1 HIGHLY CONFIDENTIAL AEO 2 Q. Which passport? 3 A. My British passport. 4 Q. Is that a current British 5 passport? 6 A. Yes. 7 Q. Did you have a British 8 passport that expired in 2014? 9 A. Yeah, I can't remember when 10 i t e x p i r e d , b u t I t h i n k y o u g u y s h a v e 11 a c o p y a s w e l l o f m y p a s s p o r t . I 12 d o n ' t r e m e m b e r t h e e x a c t d a t e t h a t i t 13 e x p i r e d . 14 Q . N o t t h e S o u t h A f r i c a n 15 p a s s p o r t t h a t w a s s t o l e n ? 16 A . T h e S o u t h A f r i c a n p a s s p o r t 17 i s c o m p l e t e l y i r r e l e v a n t . Y o u c a n ' t 18 t r a v e l o n a S o u t h A f r i c a n p a s s p o r t . 19 I t ' s - - y o u c a n ' t g o i n t o a n y o t h e r 20 c o u n t r y b a r S o u t h A f r i c a , o t h e r t h a n 21 S o u t h A f r i c a , o n a p a s s p o r t . S o I ' v e 22 h a r d l y u s e d m y S o u t h A f r i c a n p a s s p o r t 23 a t a l l . 24 Q . I ' m j u s t a s k i n g w h i c h 25 p a s s p o r t y o u s h o w e d t o t h e p e r s o n o n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 267 of 469 Highly Confidential Page 267 1 HIGHLY CONFIDENTIAL AEO 2 page 3. 3 A. Sorry. My British passport. 4 Q. And it's a British passport 5 that's current? 6 A. Yes. 7 MR. GUIRGUIS: Asked and 8 answered. 9 MS. MENNINGER: Just a bit 10 o f a d e t o u r . 11 Q . C a n I h a v e y o u t a k e a l o o k 12 a t p a r a g r a p h 1 ? 13 A . Y e p . 14 Q . I s p a r a g r a p h 1 t r u e ? 15 A . " I a m c u r r e n t l y o v e r t h e a g e 16 o f 1 8 , " p a r a g r a p h 1 , y e s . 17 Q . A n d y o u p r e s e n t l y r e s i d e i n 18 S p a i n ? 19 A . Y e s . 20 Q . P a r a g r a p h 2 , y o u s t a t e , " I n 21 t h e s u m m e r o f 2 0 0 6 , w h e n I w a s 22 2 2 y e a r s o l d a n d l i v i n g i n N e w Y o r k , I 23 w a s i n t r o d u c e d t o J e f f r e y E p s t e i n b y a 24 g i r l I h a d m e t n a m e d N a t a l y a 25 M a l y s h e v . " MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 268 of 469 Highly Confidential Page 268 1 HIGHLY CONFIDENTIAL AEO 2 Is that true? 3 A. Yes. 4 Q. Was it the summer of 2006 5 when you met Natalya? 6 A. Okay, well, it was summer. 7 End of summer going into fall. 8 Q. So when was it, do you 9 think? 10 A . I t w a s f a l l o f 2 0 0 6 . I t w a s 11 j u s t a f t e r t h e s u m m e r . 12 Q . S o i t w a s t h e f a l l o f 2 0 0 6 13 w h e n y o u m e t N a t a l y a ? 14 A . W e l l , i t w a s t h e e n d o f t h e 15 s u m m e r , s o I d o n ' t k n o w - - f a l l o r i n 16 t h e s u m m e r o r - - i t w a s e n d o f s u m m e r , 17 f a l l . 18 Q . S o m e t i m e a f t e r y o u c a m e i n t o 19 t h e U . S . ? 20 A . Y e s , y e a h . 21 Q . A n d d o y o u k n o w w h e n i n t h e 22 f a l l o f 2 0 0 6 y o u m e t N a t a l y a ? 23 A . W h a t , y o u m e a n t h e e n d o f 24 s u m m e r / f a l l s l a s h - - i f y o u r e a l l y 25 w a n t t o g o - - c a n y o u d e f i n e , l i k e , MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 269 of 469 Highly Confidential Page 269 1 HIGHLY CONFIDENTIAL AEO 2 geography lessons? Should we do 3 geography lessons? 4 MS. MCCAWLEY: All right. 5 Hang on a second. 6 A. Maybe summer? Fall? 7 Winter? What are your dates here in 8 New York? 9 MR. POTTINGER: Can we get 10 t h i s c l e a r ? 11 M R . P A G L I U C A : W o u l d y o u 12 j u s t s t o p i t ? 13 M R . P O T T I N G E R : D o y o u m i n d ? 14 D o y o u m i n d ? 15 M R . P A G L I U C A : I m i n d y o u 16 t a l k i n g . 17 M R . P O T T I N G E R : D o y o u m i n d ? 18 M S . M E N N I N G E R : I f y o u w a n t 19 t o e n t e r a n o b j e c t i o n , p l e a s e d o 20 s o . 21 M R . P O T T I N G E R : I o b j e c t . 22 M S . M E N N I N G E R : W h a t i s t h e 23 b a s i s o f y o u r o b j e c t i o n , M r . 24 P o t t i n g e r ? 25 M R . P O T T I N G E R : D e f i n e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 270 of 469 Highly Confidential Page 270 1 HIGHLY CONFIDENTIAL AEO 2 summer or fall. 3 MS. MENNINGER: I will do 4 whatever I want during my 5 deposition. 6 MR. POTTINGER: Define -- 7 define summer or fall. 8 MS. MENNINGER: I don't have 9 to define anything. 10 M R . P O T T I N G E R : D e f i n e 11 s u m m e r o r f a l l f o r t h e c l i e n t - - 12 M S . M E N N I N G E R : A l l r i g h t . 13 M R . P O T T I N G E R : - - a n d t h e n 14 w e w i l l a n s w e r t h e - - s h e w i l l b e 15 a b l e t o a n s w e r t h e q u e s t i o n . 16 M S . M E N N I N G E R : I ' m g o i n g 17 o f f t h e r e c o r d u n t i l y o u c a l m 18 d o w n . 19 L e t ' s g o o f f t h e r e c o r d . 20 ( T i m e n o t e d : 3 : 2 8 p . m . ) 21 ( R e c e s s . ) 22 ( T i m e n o t e d : 3 : 3 0 p . m . ) 23 M S . M E N N I N G E R : G o b a c k o n 24 t h e r e c o r d . 25 Q . A p p r o x i m a t e l y w h a t m o n t h a n d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 271 of 469 Highly Confidential Page 271 1 HIGHLY CONFIDENTIAL AEO 2 day did you meet Natalya Malyshev? 3 A. As I said earlier, I can't 4 remember what day, but it was end of 5 summer/fall in the United States. I 6 can't remember what specific date or 7 time that was. 8 Q. What month? Any idea? 9 A. It was September. 10 Q . W h e n d i d y o u m e e t J e f f r e y 11 E p s t e i n ? 12 A . S h o r t l y a f t e r I m e t N a t a l y a . 13 Q . W a s t h a t a l s o i n S e p t e m b e r ? 14 A . I g u e s s s o . I d o n ' t k n o w 15 t h e e x a c t d a t e I a r r i v e d , s o i f 16 s o m e o n e c a n p r o v i d e m e w i t h m y 17 p a s s p o r t s o I c a n s e e m y e n t r y d a t e , 18 m a y b e t h a t w o u l d h e l p . 19 S o I m e t N a t a l y a - - i f y o u 20 l o o k a t t h e d a t e t h a t I a r r i v e d i n N e w 21 Y o r k o n m y p a s s p o r t , I t h i n k i t ' s v e r y 22 c l e a r w h e n I a r r i v e d . Y o u ' v e g o t t h e 23 e v i d e n c e , I ' m s u r e . 24 S o t w o w e e k s a f t e r t h e d a t e 25 t h a t i s o n m y p a s s p o r t t h a t I a r r i v e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 272 of 469 Highly Confidential Page 272 1 HIGHLY CONFIDENTIAL AEO 2 in, I met Natalya. Very soon after I 3 met Natalya, I was introduced to 4 Jeffrey Epstein. It was in and around 5 September. I can't specifically 6 remember the date, time, season, 7 whatever. 8 Q. Did you show your passport 9 to Mr. Pottinger and Mr. Edwards when 10 y o u w e r e s t a n d i n g t h e r e a t t h e 11 c o n s u l a t e h a v i n g t h e a f f i d a v i t 12 n o t a r i z e d ? 13 A . I s h o w e d m y c u r r e n t p a s s p o r t 14 w h e n I h a d t h i s s i g n e d . 15 Q . N o t t h e p a s s p o r t t h a t 16 c o n t a i n e d d a t e s f r o m 2 0 0 6 ? 17 A . M y c u r r e n t v a l i d p a s s p o r t . 18 Y o u c a n o n l y s h o w a v a l i d p a s s p o r t . 19 Q . F a i r e n o u g h . 20 S o y o u b e l i e v e t h a t y o u r 21 l a w y e r s h a v e p r o d u c e d y o u r c u r r e n t 22 v a l i d p a s s p o r t t o m e ? 23 A . N o - - 24 M S . M C C A W L E Y : O b j e c t i o n . 25 A . - - t h e y h a v e n o t p r o d u c e d m y MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 273 of 469 Highly Confidential Page 273 1 HIGHLY CONFIDENTIAL AEO 2 current passport. They produced have 3 my passport during that time frame, 4 which clearly shows that -- when I 5 entered the United States. 6 Q. So when your lawyers wrote, 7 "A copy of nonparty Sarah Ransome's 8 current passport is attached hereto as 9 RANSOME 157 to 168, which should be 10 t r e a t e d a s c o n f i d e n t i a l p u r s u a n t t o 11 t h e p a r t y ' s p r o t e c t i v e o r d e r , " d o y o u 12 b e l i e v e t h a t t o b e a n a c c u r a t e 13 s t a t e m e n t ? 14 M S . M C C A W L E Y : O b j e c t i o n . 15 Y o u ' r e a s k i n g h e r l e g a l 16 i n f o r m a t i o n t h a t s h e ' s n o t p r i v y 17 t o . 18 M S . M E N N I N G E R : T h e r e w a s 19 n o t h i n g l e g a l a b o u t t h a t c o m m e n t . 20 A . S o r r y . T h a t m a k e s n o s e n s e 21 t o m e , p l e a s e . C a n y o u r e p e a t t h e 22 q u e s t i o n . 23 Q . I ' l l d o i t t h i s w a y . 24 M S . M E N N I N G E R : D e f e n d a n t ' s 25 E x h i b i t 4 . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 274 of 469 Highly Confidential Page 274 1 HIGHLY CONFIDENTIAL AEO 2 (Defendant's Exhibit 4, 3 RANSOME_000168, was marked for 4 identification.) 5 Q. Take a look at Defendant's 6 Exhibit 4. 7 A. Okay. 8 Q. Just take a look at it. Do 9 you recognize it? 10 A . Y e a h , t h i s i s m y p a s s p o r t . 11 Q . D o y o u k n o w w h i c h p a s s p o r t 12 t h i s i s ? 13 A . T h i s i s m y o l d p a s s p o r t . 14 Q . S o i t ' s n o t y o u r c u r r e n t 15 p a s s p o r t , c o r r e c t ? 16 A . N o , i t ' s n o t m y c u r r e n t 17 p a s s p o r t , b e c a u s e i t e x p i r e d o n - - 18 l e t ' s h a v e a l o o k h e r e - - 19 Q . C a n y o u t u r n t o t h e 20 s e c o n d - t o - l a s t p a g e . S o r r y . 21 A . Y e s , h e r e w e g o . 22 Q . D o e s t h a t h a v e a B a t e s 23 n u m b e r ? I n o t h e r w o r d s , y o u r n a m e , 24 R A N S O M E , w i t h a n u n d e r s c o r e a n d t h e n 25 p a g e n u m b e r s a f t e r t h a t , t h a t w e r e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 275 of 469 Highly Confidential Page 275 1 HIGHLY CONFIDENTIAL AEO 2 placed there by your attorneys. 3 A. Hmm, sorry. I don't 4 understand. 5 Q. Do you see at the bottom of 6 that page, your name, RANSOME_000158? 7 A. Yes. 8 Q. All right. And that's on a 9 document that is an expired passport? 10 A . Y e s . 11 Q . T h i s i s n o t y o u r c u r r e n t 12 p a s s p o r t ? 13 M R . G U I R G U I S : O b j e c t i o n , 14 a s k e d a n d a n s w e r e d . 15 A . N o . 16 Q . Y o u h a v e a n o t h e r p a s s p o r t 17 t h a t ' s n o t t h i s p a s s p o r t t h a t ' s 18 c u r r e n t l y i n e f f e c t ? 19 M R . G U I R G U I S : O b j e c t i o n , 20 a s k e d a n d a n s w e r e d . 21 Q . C o r r e c t ? 22 A . Y e s . 23 Q . I f I c o u l d a l s o h a v e y o u 24 t a k e a l o o k a t - - a n d I ' l l h a v e t o 25 s h o w , i f y o u c a n s e e , t h e r e a r e t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 276 of 469 Highly Confidential Page 276 1 HIGHLY CONFIDENTIAL AEO 2 passport page numbers -- 3 A. Mm-hmm. 4 Q. -- that show up on a 5 passport. 6 A. Yeah. 7 Q. And these have been put in 8 some order. 9 A. Mm-hmm, the order of my 10 p a s s p o r t , y e s . 11 Q . R i g h t . T h a t ' s n o t h o w t h e y 12 w e r e p r o d u c e d , b u t t h a t ' s t h e o r d e r 13 t h e y ' r e i n n o w . 14 A . O k a y . 15 Q . I f w e c o u l d h a v e y o u t u r n t o 16 R A N S O M E 1 6 2 , w h i c h i s p a g e 1 6 o f y o u r 17 p a s s p o r t . 18 M R . G U I R G U I S : I s t h a t t h e 19 f r o n t - - s o r r y , 1 6 2 . 20 M S . M E N N I N G E R : T h e y ' r e n o t 21 i n B a t e s o r d e r . T h e y ' r e p u t i n 22 t h e o r d e r o f t h e p a s s p o r t . 23 T H E W I T N E S S : O h , y e a h . 24 M m - h m m . 25 M S . M E N N I N G E R : I t ' s p a g e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 277 of 469 Highly Confidential Page 277 1 HIGHLY CONFIDENTIAL AEO 2 16. 3 Q. Do you see on that page a 4 stamp from the Department of Homeland 5 Security of the U.S., dated 6 October 19, 2006? 7 A. Mm-hmm. 8 Q. Does that indicate to you 9 that you were admitted to visit the 10 U . S . o n O c t o b e r 1 9 t h o f 2 0 0 6 ? 11 A . Y e s , i t d o e s . 12 Q . D o y o u b e l i e v e O c t o b e r 1 9 t h 13 i s d u r i n g t h e s u m m e r i n t h e U . S . ? 14 A . N o . I d o n ' t s e e t h e 15 r e l e v a n c e . 16 Q . W h a t s e a s o n d o y o u t h i n k 17 O c t o b e r 1 9 t h i s i n t h e U . S . ? 18 A . O k a y . W e l l , c o n s i d e r i n g I 19 a r r i v e d i n S e p t e m b e r , O c t o b e r ' s i n 20 w i n t e r . B u t I a r r i v e d i n S e p t e m b e r . 21 Q . O k a y . W e l l , d o y o u b e l i e v e 22 t h a t y o u d i d n o t e n t e r t h e U . S . o n 23 O c t o b e r 1 9 t h , 2 0 0 6 ? 24 A . W e l l , i t ' s s t a m p e d . 25 Q . D o e s i t s a y " a d m i t t e d " ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 278 of 469 Highly Confidential Page 278 1 HIGHLY CONFIDENTIAL AEO 2 A. "Admitted," yes. 3 Q. Does it say "October 19, 4 2006"? 5 A. Yes. 6 Q. Does it say "Department of 7 Homeland Security, U.S. Customs and 8 Border Patrol"? 9 A. Yes. 10 Q . S o y o u d o o r d o n o t b e l i e v e 11 y o u w e r e a d m i t t e d t o t h e U n i t e d S t a t e s 12 o n O c t o b e r 1 9 , 2 0 0 6 ? 13 A . I f l e w i n a n d h a d m y 14 p a s s p o r t s t a m p e d a f t e r I w e n t o n m y 15 t r i p t o L o n d o n i n t h e U K . 16 E v e r y t i m e y o u g o i n t o a - - 17 a s y o u a l l k n o w , u s i n g y o u r p a s s p o r t , 18 e v e r y t i m e y o u g o i n t o a n e w c o u n t r y , 19 i f y o u d o n ' t h a v e t h e i r p a s s p o r t , y o u 20 g e t a s t a m p . S o i f y o u g o i n s e v e r a l 21 t i m e s , e v e r y t i m e y o u g o i n t o t h a t n e w 22 c o u n t r y , i t g e t s s t a m p e d . 23 Q . S o y o u t h i n k y o u w e n t o n a 24 t r i p i n O c t o b e r a n d c a m e b a c k t o t h e 25 U . S . o n O c t o b e r 1 9 t h ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 279 of 469 Highly Confidential Page 279 1 HIGHLY CONFIDENTIAL AEO 2 A. I obviously went -- I 3 arrived in New York a day on the 19th 4 of October. 5 Q. Where were you coming from 6 on October 19th? 7 A. I can't remember. 8 Q. You have no idea? 9 A. I think it was London. I 10 m a d e a t r i p t o L o n d o n . 11 Q . A n d h o w l o n g w e r e y o u i n 12 L o n d o n i n O c t o b e r ? 13 A . I c a n ' t r e m e m b e r . 14 Q . A w e e k ? 15 A . I c a n ' t r e m e m b e r . 16 Q . W h o p a i d f o r t h a t t i c k e t ? 17 A . M y s e l f . 18 Q . D i d y o u g o w i t h a n y o n e ? 19 A . N o . 20 Q . D i d y o u h a v e a n e w 9 0 d a y s 21 t h a t b e g a n o n O c t o b e r 1 9 t h ? 22 A . Y e s . I t a u t o m a t i c a l l y 23 s t a r t s e v e r y t i m e y o u e n t e r . 24 Q . S o i n o r d e r t o b e c o m p l i a n t 25 w i t h t h a t v i s a , y o u n e e d e d t o l e a v e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 280 of 469 Highly Confidential Page 280 1 HIGHLY CONFIDENTIAL AEO 2 within 90 days of October 19th? 3 A. That's correct. 4 Q. Do you know which airline 5 you flew to London in 2006? 6 A. I can't remember. 7 Q. Do you know which class of 8 service you flew? 9 A. I can't remember. 10 Q . W h e r e i s y o u r c u r r e n t 11 p a s s p o r t r i g h t n o w ? 12 A . I t i s i n m y h o t e l r o o m . 13 H e r e , i n - - i t ' s i n m y h o t e l r o o m . 14 Q . G o t i t . 15 D i d N a t a l y a f l y w i t h y o u t o 16 L o n d o n ? 17 A . N o . 18 Q . D i d J e f f r e y p a y f o r y o u t o 19 g o t o L o n d o n ? 20 A . I c a n ' t r e m e m b e r . 21 Q . D o y o u k n o w w h e t h e r y o u h a d 22 m e t J e f f r e y b e f o r e y o u w e n t t o L o n d o n 23 i n O c t o b e r o f 2 0 0 6 ? 24 A . I h a d m e t J e f f r e y b y t h e n . 25 Q . D o y o u h a v e a n y e m a i l s o r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 281 of 469 Highly Confidential Page 281 1 HIGHLY CONFIDENTIAL AEO 2 anything reflecting your travel plans 3 on that trip? 4 A. Oh, I think there was a 5 plane, I think there was a plane 6 booking or something. 7 Q. For that trip to London in 8 October of 2006? 9 A. I think so. I would have to 10 d o u b l e c h e c k . 11 Q . W h e r e w o u l d y o u c h e c k ? 12 A . W e l l , I ' m t r y i n g t o g o a n d 13 f i n d i t i n m y e m a i l , m y o l d e m a i l 14 a c c o u n t , w h e r e a l l o f m y o t h e r e m a i l s 15 e x c h a n g e d b e t w e e n S a r a h K e l l e n a n d 16 L e s l e y G r o f f a r e . 17 Q . D o y o u h a v e a n y f r e q u e n t 18 f l y e r a c c o u n t s ? 19 A . N o . 20 Q . D i d y o u r f i r s t t r i p t o t h e 21 p r i v a t e i s l a n d i n t h e U . S . V i r g i n 22 I s l a n d s b e f o r e o r a f t e r y o u w e n t t o 23 L o n d o n a n d r e t u r n e d ? 24 A . W h a t w a s t h e d a t e i n O c t o b e r 25 a g a i n ? 1 9 t h . I c a n ' t r e m e m b e r . I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 282 of 469 Highly Confidential Page 282 1 HIGHLY CONFIDENTIAL AEO 2 mean, I said earlier I can't remember 3 the first time. 4 Q. In the next sentence you 5 say, "After that first trip, I 6 traveled to the island several more 7 times, usually on one of Jeffrey's 8 private airplanes, and always at his 9 direction." 10 W h a t d o y o u m e a n b y " a l w a y s 11 a t h i s d i r e c t i o n " ? 12 A . W e l l , I w a s n ' t g o i n g t o g o 13 t h e r e o n m y o w n , s o I w o u l d h a v e t o b e 14 i n v i t e d f i r s t . I d i d n ' t w a n t t o j u s t 15 g o c h i l l o n m y o w n . I t w a s J e f f r e y ' s 16 h o u s e , s o h e h a d t o p h o n e m e a n d 17 i n v i t e m e b e f o r e I d e c i d e d I w a n t e d t o 18 g o t o h i s i s l a n d . 19 Q . S o h e p h o n e d y o u , h e i n v i t e d 20 y o u , a n d y o u d e c i d e d y o u w a n t e d t o g o 21 t o h i s i s l a n d . 22 A . N o , I h a d t o g o t o h i s 23 i s l a n d . 24 Q . W h y d i d y o u h a v e t o g o t o 25 h i s i s l a n d ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 283 of 469 Highly Confidential Page 283 1 HIGHLY CONFIDENTIAL AEO 2 A. Because I was frightened of 3 him. 4 Q. Did Jeffrey ever hit you? 5 A. No, he didn't. 6 Q. Did you ever see Jeffrey 7 with a weapon? 8 A. No. 9 Q. Have you reviewed any flight 10 l o g s ? 11 A . N o , n o t t h a t I r e c a l l . 12 Q . Y o u ' v e n e v e r s e e n a f l i g h t 13 l o g ? 14 A . I ' v e s e e n o n e w h i c h s h o w e d 15 m y n a m e . 16 Q . W h e n d i d y o u f i r s t b e c o m e 17 f r i g h t e n e d o f J e f f r e y E p s t e i n ? 18 A . D u r i n g m y t i m e w i t h h i m i n 19 N e w Y o r k . 20 Q . W h a t p e r i o d o f t i m e ? 21 A . P r e t t y m u c h s o o n a f t e r I m e t 22 h i m , a c t u a l l y , a n d h e f o r c e d t h e 23 v i b r a t o r o n m y v a g i n a f o r a n e x t e n d e d 24 p e r i o d o f t i m e , w h i c h c o n s i d e r a b l y 25 h u r t m y l a d y r e g i o n , a c t u a l l y . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 284 of 469 Highly Confidential Page 284 1 HIGHLY CONFIDENTIAL AEO 2 Q. That's when you became 3 frightened of him? 4 A. Yes, absolutely. 5 Q. You've seen a flight log 6 with your name on one flight? 7 A. Yes, I have. 8 Q. When did you see that? 9 A. I saw it in January, and it 10 w a s t o c o n f i r m t h a t - - 11 M R . G U I R G U I S : I ' m g o i n g t o 12 o b j e c t . H o l d o n . 13 I s t h i s - - i f t h i s i s a 14 c o m m u n i c a t i o n w i t h c o u n s e l , y o u 15 s h o u l d u n d e r s t a n d , a n y t i m e s h e 16 a s k s y o u a q u e s t i o n , i f t h e 17 a n s w e r i s i t w a s w i t h c o u n s e l , 18 t h e n y o u d o n ' t a n s w e r . 19 W a s t h i s w i t h c o u n s e l ? 20 T H E W I T N E S S : Y e s . 21 M R . G U I R G U I S : D o n ' t a n s w e r . 22 M S . M E N N I N G E R : S e e i n g a 23 d o c u m e n t w h e n y o u ' r e w i t h c o u n s e l 24 i s p r i v i l e g e d ? 25 M R . G U I R G U I S : I d o n ' t k n o w MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 285 of 469 Highly Confidential Page 285 1 HIGHLY CONFIDENTIAL AEO 2 what your next question is going 3 to be, so... 4 MS. MENNINGER: I asked her 5 when she saw the flight logs. 6 And she said in January, correct? 7 MR. GUIRGUIS: Right. And 8 then she was about to continue 9 the answer. I'm fine with the I 10 s a w i t i n J a n u a r y . T h a t ' s w h y I 11 d i d n ' t o b j e c t w h e n y o u a s k e d t h e 12 q u e s t i o n . 13 I ' m o b j e c t i n g t o h e r 14 c o n t i n u i n g a n d c a u t i o n t h e 15 w i t n e s s n o t t o w a i v e h e r 16 a t t o r n e y / c l i e n t p r i v i l e g e . 17 Q . D o n ' t t e l l m e a n y t h i n g t h a t 18 y o u r l a w y e r s a i d t o y o u . 19 Y o u r e v i e w e d t h e f l i g h t l o g 20 i n J a n u a r y ? 21 A . I r e v i e w e d o n e f l i g h t l o g , 22 w h i c h c o n f i r m e d t h a t I w a s t h e r e . 23 Q . W h a t o t h e r d o c u m e n t s d i d y o u 24 r e v i e w ? 25 A . N o o t h e r d o c u m e n t s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 286 of 469 Highly Confidential Page 286 1 HIGHLY CONFIDENTIAL AEO 2 Q. In addition to Jeffrey and 3 Nadia, what other girls did you have 4 sexual relations with on the island? 5 A. I can't remember their 6 names. 7 Q. Can you remember any of 8 their names? 9 A. There were a few. 10 Q . C a n y o u r e m e m b e r a n y o f 11 t h e i r n a m e s ? 12 A . , J e n - - s o r r y , I 13 m i s u n d e r s t o o d y o u r q u e s t i o n . I d i d n ' t 14 h a v e s e x u a l r e l a t i o n s w i t h . 15 S o r r y , I m i s u n d e r s t o o d y o u . 16 I t w a s J e n , N a t a l y a a n d 17 N a d i a . A n d t h e r e w e r e a c o u p l e 18 o t h e r s , I d o n ' t r e m e m b e r t h e i r n a m e s . 19 Q . W h a t a r e o t h e r g u e s t s d i d 20 y o u h a v e s e x u a l r e l a t i o n s w i t h o n t h e 21 i s l a n d ? 22 A . I t w a s o n l y t h o s e o n e s . 23 Q . D o y o u k n o w t h e a g e s o f a n y 24 o f t h e i n d i v i d u a l s y o u h a d s e x u a l 25 r e l a t i o n s w i t h o n t h e i s l a n d ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 287 of 469 Highly Confidential Page 287 1 HIGHLY CONFIDENTIAL AEO 2 A. They were 18, I assumed. 3 Natalya was around my age, was my age. 4 Q. In the next paragraph, you 5 refer to meeting Ghislaine Maxwell on 6 one of your visits to the island, 7 correct? 8 A. Correct. 9 Q. You said, "Watching her 10 i n t e r a c t w i t h t h e o t h e r g i r l s o n t h e 11 i s l a n d , i t b e c a m e c l e a r t o m e t h a t s h e 12 r e c r u i t e d a l l o r m a n y o f t h e m t o t h e 13 i s l a n d . " 14 W h a t d o y o u m e a n t h a t ? 15 A . T h a t s h e r e c r u i t e d a l o t o f 16 t h e g i r l s . 17 Q . W h a t d i d y o u s e e ? 18 A . I s a w h o w s h e i n t e r a c t e d 19 w i t h a l l t h e g i r l s . Y o u k n o w , i f y o u 20 w a l k i n t o a n y - - I m e a n , c o m m o n 21 s e n s e w i s e , i f y o u w a l k i n t o a f i r m , 22 y o u k i n d o f k n o w w h o t h e b o s s i s . 23 Y o u k n o w , a l l t h e g i r l s k i n d 24 o f r e p o r t e d t o G h i s l a i n e . G h i s l a i n e 25 w a s l i k e t h e m a m a b e a r , i f y o u k n o w MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 288 of 469 Highly Confidential Page 288 1 HIGHLY CONFIDENTIAL AEO 2 what I mean. She called the shots; we 3 had to listen to Ghislaine. 4 And Ghislaine was Jeffrey's 5 right-hand woman, so, you know, 6 whatever Jeffrey wanted went through 7 Ghislaine and then filtered through. 8 Q. What did any girl report to 9 Ghislaine in your presence? 10 M R . G U I R G U I S : O b j e c t i o n . 11 I ' m n o t s u r e t h a t ' s - - j u s t 12 o b j e c t i o n t o f o r m . 13 Q . Y o u s a i d t h a t t h e g i r l s 14 r e p o r t e d t o G h i s l a i n e . W h a t d i d y o u 15 s e e o r h e a r t h a t c a u s e d y o u t o s a y 16 t h a t ? 17 A . W e l l , i t ' s p r e t t y o b v i o u s . 18 I m e a n , G h i s l a i n e c a l l e d t h e s h o t s . 19 S o , f o r e x a m p l e , w h e n - - I 20 c a n ' t r e m e m b e r s p e c i f i c s , b u t N a t a l y a , 21 I t h i n k , h a d a n i s s u e . A n d s h e h a d t o 22 s p e a k t o G h i s l a i n e i f t h e r e w a s e v e r 23 a n i s s u e . 24 Q . W h a t i s s u e ? 25 A . I c a n ' t r e m e m b e r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 289 of 469 Highly Confidential Page 289 1 HIGHLY CONFIDENTIAL AEO 2 specifically. We always have issues. 3 Girls have issues. We have period 4 pains, we've got headaches. 5 You know, we had to look a 6 certain way for Jeffrey. So if we put 7 on a little bit of weight or, for 8 example, if my hairstyle was wrong -- 9 Jeffrey liked girls to look a certain 10 w a y . 11 S o , f o r e x a m p l e , t h e r e w a s 12 o n e o c c a s i o n w h e r e J e f f r e y d i d n ' t l i k e 13 m y h a i r a n d G h i s l a i n e t o l d m e t o 14 c h a n g e i t . 15 S o t h e r e w a s - - e v e r y o n e w a s 16 a f r a i d o f G h i s l a i n e . A l l t h e g i r l s 17 w e r e a f r a i d o f h e r , s o e v e r y o n e - - 18 S a r a h K e l l e n r e p o r t e d t o h e r . L e s l e y 19 G r o f f r e p o r t e d t o h e r . I d o n ' t k n o w 20 h o w t o t e l l y o u . 21 S o w h e n I s a y r e p o r t i n g , I 22 w i t n e s s e d w i t h m y o w n t w o e y e s S a r a h 23 K e l l e n r e p o r t i n g t o G h i s l a i n e i n f r o n t 24 o f m e , b u t I c a n ' t r e m e m b e r s p e c i f i c s . 25 T h e y w e r e t a l k i n g a b o u t g i r l s . I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 290 of 469 Highly Confidential Page 290 1 HIGHLY CONFIDENTIAL AEO 2 can't remember the specific 3 conversation. But every single person 4 100 percent, 200 percent reported to 5 Ghislaine. 100 percent. 6 Q. Okay. Great. I appreciate 7 your certainty. 8 A. Absolutely. 9 Q. So we have Sarah Kellen 10 h a v i n g a d i s c u s s i o n w i t h G h i s l a i n e 11 a b o u t g i r l s . W h a t o t h e r d i s c u s s i o n s 12 d i d y o u o v e r h e a r ? 13 A . T h e r e w e r e v a r i o u s 14 d i s c u s s i o n s . W e w e r e a l w a y s t a l k i n g 15 a b o u t g i r l s . T h e r e w a s a c o n s t a n t 16 i n f l u x o f g i r l s . T h e r e w e r e s o m a n y 17 g i r l s . T h e r e w e r e g i r l s i n M i a m i . 18 T h e r e w e r e g u e s t s c o m i n g . T h e r e 19 w e r e - - 20 I t ' s l i k e , I ' m s u r e i f y o u 21 g o i n t o a h o o k e r ' s b r o t h e l a n d s e e h o w 22 t h e y r u n t h e i r b u s i n e s s , I m e a n , i t ' s 23 j u s t g e n e r a l c o n v e r s a t i o n a b o u t w h o ' s 24 g o i n g t o h a v e s e x w i t h w h o a n d , y o u 25 k n o w - - w h a t d o y o u t a l k a b o u t w h e n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 291 of 469 Highly Confidential Page 291 1 HIGHLY CONFIDENTIAL AEO 2 all do you is have sex every day on 3 rotation? I mean, what is there to 4 talk about? 5 Q. You were in Miami? When did 6 you go to Miami? 7 MR. GUIRGUIS: Objection. 8 MS. MCCAWLEY: Objection. 9 A. No, I didn't go to Miami. I 10 d i d n ' t s a y t h a t . 11 Q . A p a r t f r o m g e n e r a l 12 c o n v e r s a t i o n , d o y o u r e c a l l a n y 13 s p e c i f i c s o f a n y f e m a l e r e p o r t i n g t o 14 G h i s l a i n e ? 15 A . Y e s , I s a w . A n d w i t h m y o w n 16 e y e s , I s a w h o w G h i s l a i n e a n d L e s l e y 17 G r o f f a n d t h e o t h e r g i r l s r e p o r t e d t o 18 t h e m . 19 I f y o u w o u l d l i k e m e t o 20 r e p o r t s p e c i f i c c o n v e r s a t i o n s , I 21 c a n ' t . B u t i n m y b e i n g a n a d u l t a n d 22 h a v i n g c o m m o n s e n s e a n d a s e n s i b l e 23 h e a d o n m y s h o u l d e r s , y o u c a n q u i t e 24 q u i c k l y w o r k o u t w h o i s t h e m a n a g e m e n t 25 t h e r e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 292 of 469 Highly Confidential Page 292 1 HIGHLY CONFIDENTIAL AEO 2 And we were told by Jeffrey 3 Epstein to listen to Ghislaine. So 4 Ghislaine was the main right-hand 5 woman of Jeffrey Epstein. We were 6 told by Jeffrey Epstein to listen to 7 Ghislaine. 8 Q. When did Jeffrey Epstein 9 tell you that? 10 A . I c a n ' t r e m e m b e r t h e e x a c t 11 t i m e , d a t e o r w h e r e I w a s s t a n d i n g , o n 12 w h i c h p a v e m e n t o r c r a c k . B u t i t w a s 13 a r o u n d t h e t i m e t h a t I m e t G h i s l a i n e . 14 Q . W h i c h w a s o n t h e i s l a n d ? 15 A . I c a n ' t r e m e m b e r w h a t d a t e , 16 t i m e , p a v e m e n t , w h e r e I w a s s t a n d i n g . 17 B u t I w a s t o l d d u r i n g a r o u n d t h e t i m e 18 I m e t G h i s l a i n e t h a t I h a d t o l i s t e n 19 t o G h i s l a i n e . 20 Q . B y J e f f r e y ? 21 A . B y J e f f r e y . A n d e v e r y 22 s i n g l e o t h e r g i r l t h a t I ' v e e v e r m e t 23 w i t h J e f f r e y . 24 Q . A n d w e k n o w t h r e e n a m e s , b u t 25 t h a t ' s i t ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 293 of 469 Highly Confidential Page 293 1 HIGHLY CONFIDENTIAL AEO 2 A. Those are three names that I 3 remember, but I met -- I met lots of 4 girls. Lots. 5 Q. Okay. 6 A. Yeah. 7 Q. What activities was 8 Ghislaine Maxwell in charge of? 9 A. In terms of -- can you 10 e x p l a i n a c t i v i t i e s , p l e a s e ? 11 Q . I ' m a c t u a l l y j u s t l o o k i n g a t 12 y o u r a f f i d a v i t o n p a r a g r a p h 3 , s o w h y 13 d o n ' t y o u t a k e a l o o k a t t h a t . 14 A . A c t i v i t i e s . A c t i v i t i e s . S o 15 w h e n w e h a d t o g o t o t h e i s l a n d , w h e n 16 w e h a d t o g o s e e J e f f r e y i n N e w Y o r k , 17 w h e n w e h a d t o g o t o h i s m a n s i o n . 18 Y o u k n o w , w e s a w J e f f r e y 19 p r e t t y r e g u l a r l y . I w a s o n r o t a t i o n 20 p r e t t y m u c h e v e r y d a y , s o - - a m o n g s t 21 o t h e r g i r l s . 22 S o G h i s l a i n e a l s o c a l l e d 23 m e - - s h e a l s o c a l l e d t h e o t h e r 24 g i r l s - - w h e n J e f f r e y w a n t e d h i s 25 m a s s a g e . S o t h e r e w a s a n o c c a s i o n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 294 of 469 Highly Confidential Page 294 1 HIGHLY CONFIDENTIAL AEO 2 that I didn't want to go, and she got 3 angry with me because I didn't want to 4 give Jeffrey a massage. 5 Q. When was that? 6 A. It was on one of my -- one 7 of my stays on the island. I can't 8 remember what specific date or what 9 specific time. 10 Q . H o w m a n y t i m e s w e r e y o u o n 11 t h e i s l a n d w i t h G h i s l a i n e ? 12 A . I c a n ' t r e m e m b e r 13 s p e c i f i c a l l y . 14 Q . M o r e t h a n o n c e ? 15 A . Y e a h . 16 Q . M o r e t h a n t w i c e ? 17 A . I c a n ' t r e m e m b e r . I a l s o 18 s a w h e r i n N e w Y o r k q u i t e a l o t , s o - - 19 I m e a n , t h i s i s n ' t j u s t b a s e d o n t h e 20 i s l a n d . I s p e n t j u s t a s m u c h t i m e 21 w i t h J e f f r e y a n d G h i s l a i n e i n N e w 22 Y o r k , s o w e c a n ' t j u s t c o n c e n t r a t e o n 23 t h e i s l a n d , p l e a s e . 24 Q . D i d y o u b e l i e v e G h i s l a i n e 25 w a s l i v i n g i n N e w Y o r k i n J a n u a r y o f MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 295 of 469 Highly Confidential Page 295 1 HIGHLY CONFIDENTIAL AEO 2 2007? 3 A. I don't know where the hell 4 Ghislaine lived, to be honest. 5 Q. But you saw her regularly in 6 January of 2007? 7 MR. GUIRGUIS: Objection. 8 MS. MCCAWLEY: Objection. 9 A. Regularly, what's regularly? 10 I s a w h e r a f e w t i m e s . I d o n ' t k n o w 11 w h e r e s h e w a s l i v i n g . I t r i e d t o 12 a c t u a l l y n o t s p e n d - - w e l l , I t r i e d t o 13 s p e n d a s l i t t l e t i m e w i t h h e r a s 14 p o s s i b l e b e c a u s e e v e r y t i m e I s a w h e r 15 o n t h e i s l a n d , s h e w o u l d c a l l m e t o 16 g i v e J e f f r e y a m a s s a g e , s o . . . 17 Q . Y o u s a w h e r m o r e t h a n o n c e 18 o n t h e i s l a n d a n d y o u s a w h e r a f e w 19 t i m e s i n N e w Y o r k . D i d y o u s e e h e r 20 a n y w h e r e e l s e ? 21 M R . G U I R G U I S : O b j e c t i o n . 22 M S . M C C A W L E Y : O b j e c t i o n , 23 m i s c h a r a c t e r i z e s t e s t i m o n y . 24 A . N o . 25 Q . I n N e w Y o r k , y o u s a w h e r a t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 296 of 469 Highly Confidential Page 296 1 HIGHLY CONFIDENTIAL AEO 2 Jeffrey's office. Did you see her 3 anywhere else in New York? 4 A. I can't remember. I saw 5 them, I spent a lot of time with them, 6 so... 7 Q. How much time did you spend 8 with Ghislaine? 9 A. Enough. 10 M R . G U I R G U I S : O b j e c t i o n . 11 T h a t ' s v a g u e . 12 A . E n o u g h t i m e . I m e a n , h o w 13 l o n g i s a p i e c e o f s t r i n g ? I w a s h e r e 14 f o r a c e r t a i n a m o u n t o f t i m e , a n d i n 15 t h a t t i m e , t h e m a j o r i t y o f t h e t i m e I 16 s p e n t w i t h J e f f r e y E p s t e i n b e i n g 17 i n v o l v e d w i t h h i s p e d o p h i l i n g - - I 18 m e a n , h o w m u c h t i m e h a v e y o u s p e n t 19 w i t h h i m ? I d o n ' t k n o w . I t w a s n ' t a 20 l o t o f t i m e , b e c a u s e I c o u l d n ' t s t a n d 21 t h e w o m a n a n d s h e w a s a b u l l y a n d n o 22 o n e l i k e d h e r , s o n o o n e r e a l l y w e n t 23 o u t o f t h e i r w a y t o s p e n d t i m e w i t h 24 h e r . 25 S o I d i d n ' t s p e n d a l o t o f MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 297 of 469 Highly Confidential Page 297 1 HIGHLY CONFIDENTIAL AEO 2 time with her because she's a 3 particularly unpleasant person. And 4 when I did spend time with her, it was 5 either directing me to massage Jeffrey 6 or her showing me how to massage 7 Jeffrey, or I spent a lot of time with 8 her on the island. 9 Yeah, so how much time did I 10 s p e n d w i t h G h i s l a i n e i n t o t a l o f 11 h o u r s ? I c a n ' t r e c a l l b e c a u s e i t w a s 12 t e n y e a r s a g o . I m e a n , h o w m a n y h o u r s 13 d i d I s p e n d w i t h J e f f r e y ? I m e a n , 14 w h a t a s i l l y q u e s t i o n . 15 Q . H o w m a n y d a y s d i d y o u s e e 16 G h i s l a i n e ? 17 A . D o n ' t k n o w . 18 Q . L e s s t h a n t e n o r m o r e t h a n 19 t e n ? 20 A . I c a n ' t r e m e m b e r . 21 Q . L e s s t h a n f i v e o r m o r e t h a n 22 f i v e ? 23 A . C a n ' t r e m e m b e r . 24 Q . Y o u i n d i c a t e t h a t m a n y g i r l s 25 y o u s a w a p p e a r e d t o b e y o u n g MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 298 of 469 Highly Confidential Page 298 1 HIGHLY CONFIDENTIAL AEO 2 teenagers. Where did you see young 3 teenagers? 4 A. It says they appeared to be 5 teenagers. All the girls I saw looked 6 young. 7 Q. Okay. Where did you see 8 girls who appeared to be young 9 teenagers? 10 A . O n t h e i s l a n d a n d i n N e w 11 Y o r k . 12 Q . D e s c r i b e f o r m e a y o u n g 13 t e e n a g e r t h a t y o u s a w . 14 M R . G U I R G U I S : O b j e c t i o n , 15 m i s c h a r a c t e r i z e s t e s t i m o n y . 16 A . S o I n e v e r s a i d I s a w a 17 t e e n a g e r . T h e y a p p e a r e d t o l o o k l i k e 18 t e e n a g e r s , o k a y ? w a s - - I t r y 19 t o l o o k a t . I d o n ' t k n o w h o w 20 o l d i s , b u t s h e l o o k e d y o u n g . 21 A n d I ' m s u r e y o u c a n a g r e e , a s a m o m , 22 i n t h e p h o t o s , t h a t s h e l o o k s p r e t t y 23 y o u n g f o r a n o l d m a n t o b e b o n k i n g . 24 S o s h e l o o k s r e a l l y y o u n g . S h e l o o k s 25 y o u n g e r t h a n m e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 299 of 469 Highly Confidential Page 299 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you see her bonk 3 someone? 4 A. No, but she told me. She 5 told me and Nadia that they abused her 6 on the island. 7 Q. Nadia said they abused who 8 on the island? 9 MR. GUIRGUIS: Objection, 10 m i s c h a r a c t e r i z e s t e s t i m o n y . 11 T h a t ' s n o t w h a t s h e s a i d . 12 A . s a i d t h a t J e f f r e y 13 a n d N a d i a h a d a b u s e d h e r . 14 Q . O k a y . A n d d o y o u h a v e a n y 15 w a y t o r e a c h ? 16 A . I h a v e n ' t s p o k e n t o h e r . I 17 d o n ' t - - I j u s t k n o w h e r f i r s t n a m e . 18 Q . Y o u s a i d y o u r e c a l l s e e i n g 19 " a p a r t i c u l a r l y y o u n g , t h i n g i r l w h o 20 l o o k e d w e l l u n d e r 1 8 , " a n d y o u r e c a l l 21 a s k i n g h e r h e r a g e . 22 W h e n d i d y o u s e e t h i s 23 p a r t i c u l a r l y y o u n g , t h i n g i r l w h o 24 l o o k e d w e l l u n d e r 1 8 a n d y o u r e c a l l 25 a s k i n g h e r a g e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 300 of 469 Highly Confidential Page 300 1 HIGHLY CONFIDENTIAL AEO 2 A. It was on the trips. I 3 think you've got the photos. 4 is in the photos. So it was that trip 5 in December. 6 Q. Did you take a photo of the 7 young, thin girl who looked well under 8 18? 9 A. I think I did take a photo 10 o f h e r . I d o n ' t h a v e a n y m o r e p h o t o s 11 o f h e r o f m y o w n . 12 W e l l , I h a v e p h o t o s o f h e r . 13 Y o u ' v e g o t t h e p h o t o s . 14 Q . S o t h e p e r s o n - - 15 A . I ' v e g i v e n y o u a l l t h e 16 p h o t o s t h a t I h a v e . 17 Q . T h e p e r s o n t h a t y o u w r o t e 18 h e r e w a s " a p a r t i c u l a r l y y o u n g , t h i n 19 g i r l w h o l o o k e d w e l l u n d e r 1 8 " i s 20 r e f l e c t e d i n p h o t o g r a p h s y o u ' v e 21 p r o d u c e d i n t h i s c a s e ? 22 A . T h a t ' s c o r r e c t . 23 Q . A n d d o y o u k n o w h e r n a m e ? 24 A . S o r r y , c a n y o u j u s t r e p e a t 25 t h a t ? D i d n ' t I j u s t a n s w e r t h i s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 301 of 469 Highly Confidential Page 301 1 HIGHLY CONFIDENTIAL AEO 2 question? 3 Yeah, that's who I 4 was particularly concerned about, 5 about her age, in the photos that I 6 have supplied with -- you with, with 7 me in them with . 8 Q. So in your affidavit in 9 paragraph 3 where you talk about "a 10 p a r t i c u l a r l y y o u n g , t h i n g i r l w h o 11 l o o k e d w e l l u n d e r 1 8 , " y o u a r e 12 r e f e r r i n g t o ? 13 A . Y e s . 14 Q . A n d y o u s a i d y o u l a t e r 15 l e a r n e d s h e w a s a 16 A . T h a t ' s c o r r e c t . 17 Q . H o w d i d y o u l e a r n s h e w a s a 18 19 A . B e c a u s e s h e t o l d m e . A n d 20 s h e t o l d m e J e f f r e y E p s t e i n w a s 21 f u n d i n g h e r 22 Q . A n d w h e r e w a s h e r 23 24 A . I d o n ' t k n o w . 25 Q . W h e n d i d s h e t e l l y o u t h i s ? - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 302 of 469 Highly Confidential Page 302 1 HIGHLY CONFIDENTIAL AEO 2 A. During that December trip. 3 Q. Was that the only trip you 4 took with her? 5 A. I can't -- I can't remember. 6 I think there was another trip, but I 7 can't remember. 8 Q. Did you ever see her name on 9 a flight log? 10 A . N o . 11 Q . W a s s h e o n t h e p l a n e w i t h 12 y o u ? 13 A . I c a n ' t - - I c a n ' t r e m e m b e r . 14 I c a n ' t r e m e m b e r . Y e a h , I j u s t 15 r e m e m b e r o n t h e i s l a n d . 16 Q . O t h e r t h a n h e r t e l l i n g y o u 17 s h e w a s a d i d s h e t e l l y o u 18 a n y t h i n g e l s e a b o u t h e r s e l f ? 19 A . Y e a h , y o u k n o w , I t h i n k s h e 20 c a m e f r o m q u i t e a t o u g h b a c k g r o u n d . 21 Q . W h a t d i d s h e s a y ? 22 A . W e l l , I c a n ' t r e m e m b e r t h e 23 s p e c i f i c s , b u t I r e m e m b e r t h a t - - I 24 d o n ' t k n o w i f s h e h a d i s s u e s w i t h h e r 25 p a r e n t s - - I d o n ' t k n o w . S h e w a s a MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 303 of 469 Highly Confidential Page 303 1 HIGHLY CONFIDENTIAL AEO 2 bit of a -- you know, she was a -- I 3 was worried about her. 4 Q. What did she say to cause 5 you to be worried about her? 6 A. Well, I first met her -- she 7 was new to Jeffrey Epstein's list of 8 girls in December. And when I first 9 met her, she was a really bubbly girl 10 a n d - - I m e a n , s h e w a s y o u n g . S h e w a s 11 i n e x p e r i e n c e d . S h e - - s h e w a s f r a i l . 12 A n d s h e c h a n g e d q u i t e q u i c k l y a f t e r 13 t h a t f i r s t t r i p . 14 Q . H o w m a n y t r i p s d i d y o u t a k e 15 w i t h h e r ? 16 A . I t h i n k i t w a s m o r e t h a n 17 o n e . I c a n ' t r e m e m b e r . I s a w h e r a 18 l o t . 19 Q . W h e r e d i d y o u s e e h e r ? 20 A . O h , i t w a s e i t h e r N e w Y o r k 21 o r t h e i s l a n d . I m e a n , I c a n ' t 22 r e m e m b e r . 23 Q . I n N e w Y o r k , w h e r e d i d y o u 24 s e e h e r ? 25 A . I t h i n k w e m e t - - l i k e w e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 304 of 469 Highly Confidential Page 304 1 HIGHLY CONFIDENTIAL AEO 2 all met a couple times in New York. 3 We all kind of knew each other. 4 Q. Did you ever see her 5 A. No. 6 Q. Did she live in an apartment 7 that you went to? 8 A. I can't remember about her 9 living arrangements. 10 Q . D o y o u k n o w w h e r e h e r 11 w a s ? 12 A . N o . 13 Q . W h e n d i d y o u a s k t o s e e h e r 14 p a s s p o r t ? 15 A . W h e n w e s h o r t l y a r r i v e d t o 16 t h e V i r g i n I s l a n d s , s h e l o o k e d 17 p a r t i c u l a r l y y o u n g . A n d y o u k n o w w h a t 18 g i r l s a r e l i k e w i t h p a s s p o r t - - w i t h 19 p a s s p o r t p i c t u r e s . T h e y d o n ' t - - t h e y 20 g e t e m b a r r a s s e d a b o u t t h e i r p a s s p o r t 21 p i c t u r e s . 22 A n d s h e w a s q u i t e c a g e y 23 a b o u t h e r p a s s p o r t , s o s h e d i d n ' t s h o w 24 m e . I d o n ' t k n o w w h e t h e r t h a t - - I 25 d o n ' t k n o w . S h e j u s t d i d n ' t s h o w m e . - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 305 of 469 Highly Confidential Page 305 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did she say why she wasn't 3 showing it to you? 4 A. She said it was because she 5 was embarrassed about the picture. 6 Q. Were you living in the same 7 room with her on the island? 8 A. Yeah, we stayed in the same 9 room. 10 Q . D i d y o u e v e r a t t e m p t t o l o o k 11 a t h e r p a s s p o r t w h e n s h e w a s n ' t t h e r e ? 12 A . N o . 13 Q . D i d y o u e v e r c a l l a n y 14 a u t h o r i t i e s a b o u t h a v i n g s e e n t h i s 15 y o u n g , t h i n g i r l w h o l o o k e d w e l l u n d e r 16 1 8 ? 17 A . N o . 18 Q . I n t h e f o u r t h p a r a g r a p h , y o u 19 d e s c r i b e d b e i n g l e n t o u t t o J e f f r e y ' s 20 f r i e n d s i n N e w Y o r k . 21 W h i c h f r i e n d s o f J e f f r e y ' s 22 w e r e y o u l e n t o u t t o t o h a v e s e x ? 23 A . A l a n D e r s h o w i t z . 24 Q . W h o e l s e ? 25 A . N a d i a . A l l t h e g i r l s t h a t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 306 of 469 Highly Confidential Page 306 1 HIGHLY CONFIDENTIAL AEO 2 were involved, really. I had to have 3 sex with them, so... 4 Q. Well, what do you mean by 5 lent out? 6 A. Lent out as in -- so I was 7 one of the girls that regularly -- 8 that Jeffrey regularly asked to see 9 sexually. 10 A n d w h a t m y d e s c r i p t i o n w a s 11 o f b e i n g l e n t o u t i s w h e n - - i t ' s 12 a l m o s t l i k e J e f f r e y ' s q u i t e p o s s e s s i v e 13 o f h i s g i r l s . H e ' s - - y o u k n o w , h e 14 l e n d s t h e m o u t . 15 H e s a m p l e s t h e g i r l s , h e h a s 16 f r i e n d s c o m e o v e r t o N e w Y o r k o r t h e 17 i s l a n d a n d t h e y - - t h e y g e t t o s e e w h o 18 a l l t h e g i r l s a r e a r o u n d J e f f r e y , a n d 19 t h e y g e t t o p i c k o n e w h i c h t h e y w a n t 20 t o b e w i t h . 21 Q . S o y o u w e r e w i t h J e f f r e y a n d 22 a n u m b e r o f o t h e r f e m a l e s i n N e w Y o r k 23 w h e n a p e r s o n , a f r i e n d w o u l d c o m e i n , 24 A l a n D e r s h o w i t z w o u l d c o m e i n a n d l o o k 25 a t a l l o f t h e g i r l s a n d c h o o s e o n e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 307 of 469 Highly Confidential Page 307 1 HIGHLY CONFIDENTIAL AEO 2 MS. MCCAWLEY: Objection. 3 MR. GUIRGUIS: Objection, 4 mischaracterizes testimony. 5 MS. MENNINGER: I'm asking a 6 question. 7 MR. GUIRGUIS: I'm objecting 8 to your question. 9 A. So let me give you a 10 s p e c i f i c e x a m p l e o f t h a t . S o , f o r 11 e x a m p l e , t h e r e w a s a n o c c a s i o n w h e r e I 12 a n d s o m e o f t h e o t h e r g i r l s w e r e o n 13 t h e i s l a n d . S o a s p e c i f i c o c c a s i o n 14 w a s w h e n S e r g e y - - I d o n ' t k n o w h i s 15 s u r n a m e , b u t h e o w n s G o o g l e o r 16 w h a t e v e r , a n d h e c a m e w i t h h i s 17 f i a n c é e . 18 S o , y o u k n o w , y o u g o t a 19 t a b l e w i t h J e f f r e y E p s t e i n o f l o t s o f 20 w o m e n - - g i r l s , w o m e n , w h a t e v e r - - 21 b e a u t i f u l g i r l s , a n d y o u ' v e g o t 22 f r i e n d s j o i n i n g h i m . A n d f r i e n d s 23 p o p p e d o v e r a l l t h e t i m e . 24 S o I h a d o t h e r - - t h e r e w e r e 25 o t h e r m a l e s t h a t v i s i t e d J e f f r e y o n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 308 of 469 Highly Confidential Page 308 1 HIGHLY CONFIDENTIAL AEO 2 the island. I don't know who they 3 are. I can't remember their names. 4 But, yeah. I mean, he 5 didn't -- he didn't line them up and 6 go, hey, boys, pick which vagina you 7 want. He didn't do it that blatantly. 8 But they had spent time with 9 the girls during a lunch on the 10 i s l a n d - - y e a h , I m e a n , t h e y - - h i s 11 f r i e n d s w o u l d s p e n d t i m e w i t h u s . 12 Q . O k a y . I n p a r a g r a p h 4 , w h e r e 13 y o u s a y , " A t h i s t o w n h o u s e , I w a s a l s o 14 l e n t o u t b y h i m t o h i s f r i e n d s a n d 15 a s s o c i a t e s t o h a v e s e x . " 16 W h a t d o y o u m e a n b y t h a t 17 s e n t e n c e ? 18 A . W e l l , I m e a n , i t ' s q u i t e 19 o b v i o u s w i t h t h e i n c i d e n t s - - w e l l , 20 t h e i n c i d e n t t h a t h a p p e n e d w i t h A l a n . 21 S o I w o u l d c l a s s i f y t h a t a s b e i n g l e n t 22 o u t . I d i d n ' t w i l l i n g l y g o , h e y , 23 A l a n , l e t ' s h a v e s o m e f u n , b e c a u s e n o 24 o n e o n t h e p l a n e t w o u l d s a y t h a t t o 25 A l a n . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 309 of 469 Highly Confidential Page 309 1 HIGHLY CONFIDENTIAL AEO 2 Q. So you say "lent out by him 3 to his friends and associates." 4 Who are the friends and 5 associates that you were lent out to? 6 MR. GUIRGUIS: Objection, 7 asked and answered. 8 A. Alan Dershowitz and Nadia. 9 The girls that I mentioned. There 10 w e r e o t h e r g i r l s t h a t I h a d s e x u a l 11 i n t e r c o u r s e w i t h , b u t I c a n ' t r e m e m b e r 12 t h e i r n a m e s . 13 Q . W e r e t h e r e a n y o t h e r m e n ? 14 A . N o , t h e r e w e r e n ' t a n y o t h e r 15 m e n . 16 Q . P r i n c e A n d r e w ? 17 A . N o . 18 Q . ? 19 A . N o , n o , I d o n ' t k n o w t h a t . 20 Q . B i l l R i c h a r d s o n ? Y e s ? N o ? 21 A . N o . T h a t I w o u l d b e l e n t 22 o u t t o h a v e s e x w i t h ? 23 Q . Y e s . 24 A . N o , n o . 25 Q . T o m P r i t z k e r ? - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 310 of 469 Highly Confidential Page 310 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Marvin Minsky? 4 A. No. 5 Q. Were you paid money after 6 you had sex with Alan Dershowitz? 7 A. No. 8 Q. Were you paid money after 9 you had sex with Nadia? 10 A . N o . 11 Q . W e r e y o u p a i d m o n e y a f t e r 12 y o u h a d s e x w i t h N a t a l y a ? 13 A . N o . 14 Q . W e r e y o u p a i d m o n e y a f t e r 15 y o u h a d s e x w i t h a n y o f t h e o t h e r 16 g i r l s - - 17 A . N o . 18 Q . - - o f n a m e s y o u c a n ' t 19 r e m e m b e r ? 20 A . I w a s o n l y e v e r p a i d t o - - 21 w h e n I h a d s e x w i t h J e f f r e y h i m s e l f . 22 Q . I n t h e c o u r s e o f m a s s a g e ? 23 A . Y e s . 24 Q . D i d y o u e v e r h a v e s e x w i t h 25 J e f f r e y n o t i n a m a s s a g e c o n t e x t ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 311 of 469 Highly Confidential Page 311 1 HIGHLY CONFIDENTIAL AEO 2 A. Yeah, we -- yeah. He was 3 really intimate all the time. We 4 had -- multiple times. I can't tell 5 you how many times I've slept with 6 Jeffrey. I mean, we were on rotation. 7 Every single day, it was -- sometimes 8 twice a day I was called. 9 You know, Ghislaine, Sarah 10 K e l l e n - - y o u k n o w , i t w a s - - y e a h . I 11 m e a n , h o w - - w e w e r e o n r o t a t i o n 12 p r e t t y m u c h t h e w h o l e t i m e I w a s h e r e . 13 Q . A n d w h e n y o u s a y y o u w e r e o n 14 r o t a t i o n , y o u m e a n y o u w e r e h a v i n g s e x 15 w i t h J e f f r e y m u l t i p l e t i m e s p e r d a y ? 16 A . N o . A s i n w h e n I w a s 17 f i n i s h e d , a n o t h e r g i r l w a s c a l l e d b y 18 G h i s l a i n e . A n d w h e n t h e y h a d 19 f i n i s h e d , a n o t h e r g i r l w a s c a l l e d . 20 Q . H o w d o y o u k n o w t h a t a n o t h e r 21 g i r l w a s c a l l e d b y G h i s l a i n e ? 22 A . B e c a u s e I w a s t h e r e , a n d I 23 s a w i t a n d h e a r d i t w i t h a l l m y 24 s e n s e s . I s a w G h i s l a i n e c a l l a n o t h e r 25 g i r l , a n d s h e c a l l e d m e h e r s e l f , t o g o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 312 of 469 Highly Confidential Page 312 1 HIGHLY CONFIDENTIAL AEO 2 give Jeffrey Epstein a sexual massage. 3 Q. What do you mean by call? I 4 guess I'm thinking like telephone. 5 That may be my -- 6 A. No. As in going up to the 7 person and going, Jeffrey wants to see 8 you in his bedroom, which meant it's 9 your turn to be abused. That kind of 10 t h i n g . 11 Q . A n d t h i s i s o n t h e i s l a n d ? 12 A . T h i s i s o n t h e i s l a n d . 13 Q . Y o u h e a r d - - a s s o o n a s y o u 14 w e r e d o n e w i t h J e f f r e y , y o u h e a r d 15 G h i s l a i n e g o u p t o a n o t h e r g i r l a n d 16 s a y , i t ' s y o u r t u r n w i t h J e f f r e y ? 17 A . S o e v e r y s i n g l e d a y , I 18 m e a n - - s o I d o n ' t k n o w h o w q u i c k l y 19 J e f f r e y ' s s p e r m b a n k f i l l s u p . I 20 m e a n , I k n o w g u y s c a n n o r m a l l y c u m 21 o n c e o r t w i c e a d a y , b u t J e f f r e y ' s n o t 22 a n o r m a l p e r s o n . 23 S o , I m e a n , o u r r o t a t i o n 24 c h a n g e d e v e r y d a y t h a t s p e c i f i c t r i p 25 w e h a d i n D e c e m b e r . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 313 of 469 Highly Confidential Page 313 1 HIGHLY CONFIDENTIAL AEO 2 So, for example, I would be 3 called. Maybe a couple hours when 4 Jeffrey had a little, you know, break, 5 another girl was called, . 6 Then another girl was called. Every 7 single day. 8 We tried to hide on 9 different -- like, so we wouldn't have 10 t o g e t c a l l e d . W e ' d g e n e r a l l y h a v e t o 11 s i t i n t h e m a i n a r e a . T h e r e w a s l i k e 12 a b i g p o o l , t h e m a i n s e a t i n g a r e a . 13 T h e r e w a s a b i g t a b l e . W e ' d s i t t h e r e 14 a n d d o k i n d o f a r t o n t h e t a b l e , a n d 15 w e a l w a y s h a d t o b e a r o u n d . W e 16 w e r e n ' t a l l o w e d t o g o v e r y f a r o n t h e 17 i s l a n d . 18 W e a l w a y s h a d t o r e p o r t t o 19 G h i s l a i n e a n d J e f f r e y a n d t e l l t h e m i f 20 w e w e r e g o i n g d o w n t o t h e b e a c h t o 21 s w i m b e c a u s e t h e y h a d a n i n f l a t a b l e 22 t r a m p o l i n e . S o t h e y - - I m e a n , w e 23 a l w a y s h a d t o t e l l G h i s l a i n e a n d 24 J e f f r e y w h e r e w e w e r e a t a l l t i m e s . 25 Q . O n t h e i s l a n d ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 314 of 469 Highly Confidential Page 314 1 HIGHLY CONFIDENTIAL AEO 2 A. On the island, yeah. 3 Q. In New York -- strike that. 4 How many times a day, to 5 your knowledge, did Jeffrey Epstein 6 have sex? 7 A. To my knowledge, from what I 8 saw and what I've witnessed -- I don't 9 know what he did when I wasn't 10 t h e r e - - u p t o a b o u t t h r e e , f o u r t i m e s 11 a d a y . 12 Q . S o y o u h a d s e x w i t h h i m 13 t h r e e o r f o u r t i m e s a d a y ? 14 M S . M C C A W L E Y : O b j e c t i o n . 15 A . N o . 16 Q . I ' m s o r r y . Y o u s a i d t o y o u r 17 k n o w l e d g e , w h a t y o u w i t n e s s e d . I ' m 18 t r y i n g t o u n d e r s t a n d w h a t y o u m e a n . 19 A . S o a s s o o n a s I s l e p t w i t h 20 J e f f r e y , a c e r t a i n t i m e w o u l d g o b y . 21 H e m a y b e h a d a c o f f e e . A n d t h e n t h e r e 22 w a s a s p e c i f i c o c c a s i o n w h e r e t h e n 23 w a s c a l l e d t o g o a n d d o t h a t 24 f o r J e f f r e y . 25 Q . A n d y o u w e r e n o t i n t h e r o o m MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 315 of 469 Highly Confidential Page 315 1 HIGHLY CONFIDENTIAL AEO 2 when was with Jeffrey? 3 A. No, but I was certainly 4 there afterwards, because she was 5 forced to have sex with Nadia and 6 Jeffrey Epstein. 7 Q. That happened? 8 A. Yes. And she had never had 9 a female experience before and she was 10 v e r y u p s e t , v e r y u p s e t . 11 Q . S o y o u d i d n ' t p e r s o n a l l y s e e 12 i t , b u t y o u t a l k e d t o a n d s a w 13 h e r a f t e r w a r d s ? 14 A . W e l l , I d o n ' t t h i n k t h e 15 g i r l s , w h e n t h e y w e r e c a l l e d , w e r e 16 m a k i n g c u p s o f t e a w i t h J e f f r e y i n h i s 17 r o o m . S o - - a n d w h e n a g i r l c o m e s o u t 18 c r y i n g a n d I k n o w t h a t I ' v e b e e n 19 s e x u a l l y a b u s e d , i t ' s q u i t e s a f e t o 20 a s s u m e . 21 A n d w h e n t h a t g i r l t e l l s y o u 22 s h e ' s b e i n g f o r c e d t o h a v e s e x w i t h 23 J e f f r e y E p s t e i n a n d N a d i a , y o u k n o w , 24 i t ' s t h e r e , i s n ' t i t . 25 Q . S o s h e t o l d y o u ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 316 of 469 Highly Confidential Page 316 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes, she told me. And with 3 my own intelligence, in my -- you 4 know, I can see with my own senses. I 5 can hear things, see things. It's 6 quite obvious what was going on. 7 MS. MENNINGER: I need a 8 small break. 9 (Time noted: 4:17 p.m.) 10 ( R e c e s s . ) 11 ( T i m e n o t e d : 4 : 2 8 p . m . ) 12 Q . O n D e f e n d a n t ' s E x h i b i t 3 i n 13 t h e l a s t p a r a g r a p h , y o u d e s c r i b e 14 h a v i n g h a d s e x w i t h A l a n D e r s h o w i t z , 15 c o r r e c t ? 16 A . C o r r e c t . 17 Q . Y o u s a y i n t h e l a s t s e n t e n c e 18 t h a t y o u r e c a l l " s p e c i f i c k e y d e t a i l s 19 o f h i s p e r s o n . " 20 W h a t s p e c i f i c k e y d e t a i l s o f 21 h i s p e r s o n d o y o u r e c a l l ? 22 A . Y o u k n o w , I r e c a l l h i s 23 a p p e a r a n c e . Y o u k n o w , I ' d m e t h i m , 24 y o u k n o w , t w i c e b e f o r e h a n d . S o i n 25 t e r m s o f s p e c i f i c k e y d e t a i l s , I c a n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 317 of 469 Highly Confidential Page 317 1 HIGHLY CONFIDENTIAL AEO 2 describe how he looked. 3 Q. How did he look? 4 A. He was, as I've explained -- 5 described earlier, quite -- quite an 6 elderly man, wore glasses, quite 7 pasty, pasty-skinned. Not well, I 8 assumed, not at all well. He wasn't 9 well, W-E-L-L. Like, he wasn't a -- 10 h e w a s n ' t - - h e w a s n ' t a h e a l t h y 11 p e r s o n . 12 Q . A n d d o y o u r e c a l l w h e t h e r h e 13 h a d a m u s t a c h e ? 14 A . I c a n ' t - - I c a n ' t r e c a l l i f 15 h e h a d a m u s t a c h e , n o . 16 Q . W h i c h o f t h o s e t h a t y o u j u s t 17 d e s c r i b e d a r e t h e k e y d e t a i l s y o u a r e 18 r e f e r r i n g t o i n p a r a g r a p h 4 ? 19 M S . M C C A W L E Y : O b j e c t i o n , 20 a s k e d a n d a n s w e r e d . 21 A . A s I ' v e d e s c r i b e d . I 22 m e a n . . . 23 Q . P a s t y s k i n ? 24 A . P a s t y s k i n , w r i n k l y . I 25 d i d n ' t - - I t r i e d t o p a y a s l i t t l e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 318 of 469 Highly Confidential Page 318 1 HIGHLY CONFIDENTIAL AEO 2 attention to him as possible. During 3 that session, I was completely 4 overwhelmed. I -- it completely took 5 me by surprise, that incident, and I 6 was exceptionally upset by what was 7 going on because I felt that I had 8 been coerced beforehand, that it had 9 been prior arranged to me arriving 10 t h e r e . 11 Q . C a n y o u d e s c r i b e a n y o t h e r 12 s p e c i f i c k e y d e t a i l o f h i s p e r s o n t h a t 13 y o u h a v e n ' t a l r e a d y m e n t i o n e d ? 14 A . I c a n ' t r e m e m b e r s p e c i f i c 15 o n e s . I t w a s - - I j u s t t r i e d t o j u s t 16 g e t i t d o n e a s s o o n a s p o s s i b l e t o g e t 17 o u t o f t h e r e . I c o u l d n ' t w a i t t o g e t 18 o u t o f t h e r e q u i c k e n o u g h , t o b e 19 h o n e s t . 20 Q . D i d y o u t e l l y o u r a t t o r n e y s , 21 I r e c a l l s p e c i f i c k e y d e t a i l s o f t h i s 22 p e r s o n ? 23 A . I t h i n k I ' v e j u s t d e s c r i b e d 24 t h a t k e y d e t a i l s o f t h i s p e r s o n . 25 Q . D i d y o u s a y t h o s e w o r d s t o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 319 of 469 Highly Confidential Page 319 1 HIGHLY CONFIDENTIAL AEO 2 your attorneys when you drafted this? 3 MR. GUIRGUIS: Objection, 4 asked and answered. 5 MS. MCCAWLEY: Objection. 6 A. I do recall specific 7 details, which I've given. 8 Q. And they're the ones you've 9 already given? 10 A . I d o n ' t - - a s I s p e c i f i e d , 11 t h i s w a s a c o e r c e d e v e n t t h a t t o o k 12 p l a c e . I w a s e x t r e m e l y u p s e t . I d i d 13 n o t w a n t t o h a v e s e x u a l i n t e r c o u r s e 14 w i t h A l a n . 15 I d i d n o t - - I d o n ' t - - I 16 d o n ' t r e m e m b e r s p e c i f i c - - I d o n ' t 17 r e m e m b e r s p e c i f i c t h i n g s . I r e m e m b e r 18 N a d i a - - m e p a y i n g p a r t i c u l a r 19 a t t e n t i o n t o N a d i a b e c a u s e I d i d n ' t 20 w a n t A l a n t o u c h i n g m e , s o i t w a s - - a s 21 I s a i d , i t w a s a t r a u m a t i c e x p e r i e n c e . 22 I d o n ' t r e m e m b e r t h e f i n e r 23 d e t a i l s o f A l a n D e r s h o w i t z ' s p r i v a t e 24 p a r t s o r a n y o t h e r t h i n g . I t r i e d t o 25 s p e n d a s l i t t l e t i m e a s p o s s i b l e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 320 of 469 Highly Confidential Page 320 1 HIGHLY CONFIDENTIAL AEO 2 touching Alan, as I'm sure you can 3 imagine. 4 Q. How was it coerced? 5 A. It was coerced in the sense 6 that when I arrived there, Alan 7 Dershowitz was there and Nadia was 8 there. It was quite clear to me what 9 their intention was after me arriving 10 t h e r e . 11 Q . T h e r e b e i n g w h e r e ? 12 A . J e f f r e y ' s N e w Y o r k 13 a p a r t m e n t . 14 Q . W h e n y o u a r r i v e d a t 15 J e f f r e y ' s N e w Y o r k a p a r t m e n t , A l a n w a s 16 a l r e a d y t h e r e ? 17 A . Y e s . 18 Q . A n d N a d i a w a s a l r e a d y t h e r e ? 19 A . Y e s . 20 Q . W h a t w e r e t h e s p e c i f i c k e y 21 d e t a i l s o f t h e s e x a c t s t h a t y o u c a n 22 r e m e m b e r t h a t y o u h a v e n o t a l r e a d y 23 d e s c r i b e d ? 24 A . T h e r e w a s c u n n i l i n g u s 25 i n v o l v e d , m a s t u r b a t i o n . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 321 of 469 Highly Confidential Page 321 1 HIGHLY CONFIDENTIAL AEO 2 Q. Who performed cunnilingus on 3 who? 4 A. We all performed cunnilingus 5 on each other. 6 Q. So did anyone perform 7 cunnilingus on Mr. Dershowitz? 8 A. Is that the same as girls 9 and boys? Yeah, same definition. 10 Q . D i d y o u p e r f o r m c u n n i l i n g u s 11 o n N a d i a ? 12 A . Y e s . 13 Q . D i d s h e p e r f o r m i t o n y o u ? 14 A . Y e s . 15 Q . D i d M r . D e r s h o w i t z p e r f o r m 16 i t o n y o u ? 17 A . Y e s . 18 Q . D i d h e p e r f o r m i t o n N a d i a ? 19 A . Y e s . 20 Q . A n d a n y o t h e r s p e c i f i c k e y 21 d e t a i l s o f t h e s e x a c t s y o u c a n 22 d e s c r i b e ? 23 A . T h e r e w a s a l o t o f t o u c h i n g , 24 f o n d l i n g , y e a h . 25 Q . W h e n y o u s a y P r o f e s s o r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 322 of 469 Highly Confidential Page 322 1 HIGHLY CONFIDENTIAL AEO 2 Dershowitz's name, you say Dershovitz 3 with a V, phonetically, correct? 4 A. I'm slightly dyslexic and 5 I'm terrible with names. So it's 6 known that I've always struggled with 7 pronunciations, especially because of 8 my accent as well. 9 Q. Do you believe you were 10 i n t r o d u c e d t o h i m a s D e r s h o v i t z w i t h a 11 V ? 12 A . I w a s i n t r o d u c e d t o h i m a s 13 A l a n . 14 Q . D i d y o u e v e r h e a r a n y o n e s a y 15 h i s l a s t n a m e ? 16 A . Y e s . 17 Q . D i d y o u h e a r t h o s e p e o p l e 18 s a y i t w i t h a V ? 19 A . I c a n ' t r e c a l l t h e e x a c t 20 p r o n u n c i a t i o n o f t h e t o n g u e , b u t t h e 21 w a y m y e a r s h e a r w o r d s - - p e r h a p s y o u 22 c a n c o n t a c t m y u n i v e r s i t y . I d o n ' t - - 23 I h a v e d i f f i c u l t y w i t h n a m e s a n d I ' m 24 s l i g h t l y d y s l e x i c , s o . . . 25 M S . M E N N I N G E R : O k a y . C a n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 323 of 469 Highly Confidential Page 323 1 HIGHLY CONFIDENTIAL AEO 2 you mark this as Defendant's 3 Exhibit 5. 4 (Defendant's Exhibit 5, jury 5 trial demand, was marked for 6 identification.) 7 MS. MCCAWLEY: Because I 8 forget earlier, just for the 9 record, the plaintiff in the case 10 i s g o i n g t o m a r k t h e d e p o s i t i o n 11 a s c o n f i d e n t i a l . 12 M S . M E N N I N G E R : Y e s . I 13 d i s c u s s e d i t w i t h t h e c o u r t 14 r e p o r t e r , a n d I t h i n k h e a l r e a d y 15 h a s , b u t i f n o t , h e w i l l d o i t . 16 M S . M C C A W L E Y : O k a y . 17 Q . C a n y o u t a k e a l o o k a t 18 D e f e n d a n t ' s E x h i b i t 5 . 19 A . Y e s . 20 Q . H a v e y o u s e e n t h i s d o c u m e n t 21 b e f o r e ? 22 A . Y e s . 23 Q . D i d y o u r e v i e w i t b e f o r e i t 24 w a s f i l e d ? 25 A . Y e s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 324 of 469 Highly Confidential Page 324 1 HIGHLY CONFIDENTIAL AEO 2 Q. What do you understand this 3 document to be? 4 A. This is a complaint against 5 Jeffrey Epstein. 6 Q. Anyone else? 7 A. Ghislaine Maxwell, Sarah 8 Kellen, Lesley Groff, Natalya 9 Malyshev. 10 Q . A n d t h i s i s a c o m p l a i n t t h a t 11 y o u a u t h o r i z e d b e f i l e d o n y o u r 12 b e h a l f ? 13 A . T h a t ' s c o r r e c t . 14 Q . A n d a t t h e e n d o f t h i s 15 c o m p l a i n t , y o u a s k f o r m o n e y t o b e 16 a w a r d e d t o y o u , c o r r e c t ? 17 A . C a n y o u r e f e r m e t o t h e 18 s p e c i f i c p a g e , p l e a s e ? 19 Q . W e l l , d o y o u u n d e r s t a n d t h a t 20 y o u a r e a s k i n g f o r m o n e y t o b e a w a r d e d 21 t o y o u ? 22 A . C a n y o u t e l l m e w h i c h p a g e 23 t h a t ' s o n , p l e a s e . 24 Q . I ' m j u s t a s k i n g y o u r 25 u n d e r s t a n d i n g . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 325 of 469 Highly Confidential Page 325 1 HIGHLY CONFIDENTIAL AEO 2 A. Nothing's been promised to 3 me about money. 4 Q. Were you seeking money when 5 you authorized this complaint to be 6 filed on your behalf? 7 A. No. I just wanted a 8 pedophile behind bars, really, and for 9 him to stop abusing young girls. 10 S e e i n g a s I ' m g o i n g t o b e a 11 p a r e n t m y s e l f , I c a n ' t r e a l l y l i v e 12 w i t h m y s e l f , k n o w i n g t h a t t h e r e ' s a 13 p e d o p h i l e w i t h m y k i d s o n t h e p l a n e t . 14 S o a s a r e s p o n s i b l e h u m a n b e i n g , I 15 t h o u g h t t h a t I w o u l d c o m e f o r w a r d . 16 Q . S o y o u r h o p e i n f i l i n g t h i s 17 l a w s u i t w a s n o t t o r e c o v e r a n y m o n e y ? 18 A . N o . I w a n t J e f f e r y a n d 19 G h i s l a i n e a n d a l l o f t h e s e p e o p l e 20 b e h i n d b a r s s o I c a n t h e n v i s i t t h e m 21 i n j a i l . 22 Q . I n p a r a g r a p h 3 6 o f t h i s , 23 w h i c h i s o n p a g e 1 1 , c a n I h a v e y o u 24 r e v i e w t h a t p a r a g r a p h . 25 A . Y e p . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 326 of 469 Highly Confidential Page 326 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you know what that 3 paragraph refers to? 4 A. Yes, I do. 5 Q. What is the basis for your 6 statement that "Defendant Malyshev 7 reported to Defendants Kellen, Groff 8 and Maxwell, and was paid for her 9 recruitment of young females, 10 i n c l u d i n g t h e r e c r u i t m e n t o f 11 p l a i n t i f f " ? 12 A . S h e t o l d m e f a c e t o f a c e , i n 13 p e r s o n , t h a t s h e w a s p a i d b y J e f f r e y . 14 A n d J e f f r e y a l s o o f f e r e d t o 15 p a y m e $ 5 , 0 0 0 t o f i n d h i m a n e w 16 1 8 - y e a r - o l d m o d e l P A t o h e l p h i m w i t h 17 h i s m u l t i - b i l l i o n a i r e c o r p o r a t i o n , 18 b e c a u s e s h e ' s t h a t q u a l i f i e d . 19 Q . S o w h e n y o u s a y r e c r u i t m e n t 20 o f y o u n g f e m a l e s , y o u ' r e r e f e r r i n g t o 21 p e o p l e w h o a r e 1 8 ? 22 A . Y e s . 23 Q . A n d a t t h e t i m e y o u w e r e i n 24 t o u c h w i t h M s . M a l y s h e v , y o u w e r e 2 2 , 25 c o r r e c t ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 327 of 469 Highly Confidential Page 327 1 HIGHLY CONFIDENTIAL AEO 2 A. That's correct. 3 Q. Apart from what Ms. Malyshev 4 told you, do you have any other basis 5 for knowing that Malyshev reported to 6 Kellen, Groff and Maxwell and was paid 7 for her recruitment of young females, 8 including you? 9 A. What she told me. 10 Q . A p a r t f r o m w h a t s h e t o l d 11 y o u , d o y o u h a v e a n y o t h e r b a s i s f o r 12 t h a t ? 13 A . W e l l , I s a w i t w i t h m y o w n 14 e y e s . I w a s a w i t n e s s . 15 Q . W h a t d i d y o u w i t n e s s ? 16 A . I w i t n e s s e d t h e s a m e t h i n g 17 a l l t h e o t h e r g i r l s d i d , t h e s a m e 18 t h i n g I h a d t o d o , w a s g o a n d r e p o r t 19 t o S a r a h K e l l e n , L e s l e y G r o f f a n d 20 G h i s l a i n e . 21 G h i s l a i n e w a s t h e m a i n l a d y . 22 S a r a h K e l l e n a n d L e s l e y G r o f f d i d a l l 23 t h e a d m i n , l i k e b o o k i n g f l i g h t s , l i k e 24 w h a t a n o r m a l P A d o e s . 25 D o y o u u n d e r s t a n d ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 328 of 469 Highly Confidential Page 328 1 HIGHLY CONFIDENTIAL AEO 2 Q. Well, did you get paid for 3 recruitment of young females? 4 A. Jeffrey Epstein told me that 5 he would give me money to find him a 6 PA for him in South Africa. 7 Q. You did not find a PA, 8 correct? 9 A. Absolutely not. 10 Q . A n d y o u d i d n o t g e t p a i d f o r 11 r e c r u i t m e n t o f y o u n g f e m a l e s , c o r r e c t ? 12 A . A b s o l u t e l y n o t . 13 Q . Y o u s a y i n p a r a g r a p h 3 7 t h a t 14 y o u w e r e i n t r o d u c e d t o E p s t e i n b y 15 M a l y s h e v , c o r r e c t ? 16 A . C o r r e c t . 17 Q . A n d E p s t e i n c o n f i r m e d t o y o u 18 t h a t h e w o u l d u s e h i s w e a l t h a n d 19 i n f l u e n c e t o h a v e y o u a d m i t t e d i n t o 20 F I T , c o r r e c t ? 21 A . T h a t ' s c o r r e c t . 22 Q . W h a t d i d E p s t e i n s a y t o y o u 23 t o c o n f i r m t h a t ? H e s a i d , I w i l l u s e 24 m y w e a l t h a n d i n f l u e n c e t o h a v e y o u 25 a d m i t t e d , o r s o m e o t h e r w o r d s ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 329 of 469 Highly Confidential Page 329 1 HIGHLY CONFIDENTIAL AEO 2 A. I can't remember the exact 3 conversation, but from the very 4 beginning Jeffrey and Ghislaine knew 5 what my intentions were and why I 6 wanted to stay in New York, which was 7 to get a degree. 8 Q. Did Epstein say something to 9 you about a similar institute of 10 h i g h e r l e a r n i n g o f f e r i n g a c u r r i c u l u m 11 o f f a s h i o n i n d u s t r y t r a i n i n g ? 12 A . N o . I w a s p r e t t y a d a m a n t 13 t h a t I w a n t e d t o g o t o F I T . I t ' s o n e 14 o f t h e b e s t f a s h i o n s c h o o l s , s o . . . 15 Q . I n p a r a g r a p h 3 8 , y o u s a y 16 M a x w e l l t o l d y o u t h a t y o u w o u l d " n e e d 17 t o p r o v i d e E p s t e i n w i t h b o d y m a s s a g e s 18 i n o r d e r t o r e a p t h e b e n e f i t s o f h i s 19 a n d h e r c o n n e c t i o n s . " 20 W h a t d i d M s . M a x w e l l s a y t o 21 y o u i n r e g a r d s t o g i v i n g b o d y m a s s a g e s 22 i n o r d e r t o r e a p b e n e f i t s o f h e r 23 c o n n e c t i o n s ? 24 A . W e l l , t h e f a c t t h a t s h e t o l d 25 m e I h a d t o w e i g h 5 2 k i l o g r a m s i n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 330 of 469 Highly Confidential Page 330 1 HIGHLY CONFIDENTIAL AEO 2 order for them to pay for my 3 education, that was pretty -- that was 4 one of the conversations that she had 5 with me. 6 Q. Does that have something to 7 do with body massages? 8 A. Can you repeat -- let me 9 read the question again. 10 S o I w o u l d j u s t l i k e t o 11 c l a r i f y , b o d y m a s s a g e s m e a n t s e x , 12 o k a y ? T h a t ' s l i k e a k e y w o r d f o r s e x . 13 S o a s s o o n a s y o u s t o p h a v i n g s e x w i t h 14 J e f f r e y a n d h i s f r i e n d s a n d h i s g i r l s , 15 y o u ' r e o u t , b e c a u s e o t h e r w i s e t h e r e ' s 16 n o r e a s o n f o r y o u t o b e a s s o c i a t e d 17 w i t h J e f f r e y , b e c a u s e y o u ' r e j u s t 18 t h e r e t o h a v e s e x w i t h h i m , s o . . . 19 Q . C a n I d i r e c t y o u r a t t e n t i o n 20 t o t h e f i r s t s e n t e n c e i n p a r a g r a p h 3 8 , 21 a n d c a n y o u j u s t e x p l a i n t o m e w h e n 22 t h a t c o n v e r s a t i o n t o o k p l a c e . 23 M R . G U I R G U I S : O b j e c t i o n , 24 f o r m . 25 A . F i r s t t i m e I m e t G h i s l a i n e , MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 331 of 469 Highly Confidential Page 331 1 HIGHLY CONFIDENTIAL AEO 2 from the very first beginning. 3 Q. What did Ghislaine say to 4 you? 5 A. I can't remember the 6 specific conversation. But the fact 7 that she helped me refine my massage 8 skills to satisfy Jeffrey, I think 9 it's pretty self-explanatory. 10 Q . T h e o n e y o u d e s c r i b e d 11 e a r l i e r ? 12 A . T h e o n e I d e s c r i b e d e a r l i e r . 13 Q . O k a y . I n t h e s e c o n d 14 s e n t e n c e , w h e r e i t s a y s , " M a x w e l l a n d 15 E p s t e i n a l s o t h r e a t e n e d p l a i n t i f f t h a t 16 w h i l e t h e y h a d t h e a b i l i t y t o a d v a n c e 17 h e r e d u c a t i o n a n d c a r e e r , t h e y a l s o 18 h a d t h e a b i l i t y t o m a k e s u r e t h a t s h e 19 w o u l d o b t a i n n o f o r m a l e d u c a t i o n o r 20 m o d e l i n g a g e n c y c o n t r a c t s i f s h e 21 f a i l e d t o p r o v i d e t h e s e x u a l f a v o r s 22 d e s i r e d b y d e f e n d a n t E p s t e i n o r a b i d e 23 b y t h e i n s t r u c t i o n s g i v e n h e r b y 24 d e f e n d a n t s E p s t e i n a n d M a x w e l l . " 25 A . M m - h m m . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 332 of 469 Highly Confidential Page 332 1 HIGHLY CONFIDENTIAL AEO 2 Q. What did Ms. Maxwell say to 3 you that gave rise to this particular 4 statement? 5 A. Well, the fact that she used 6 to personally call me herself to give 7 Jeffrey sexual massages. Not body 8 massages; sexual massages. It should 9 be rephrased. 10 I m e a n , i t w a s p r e t t y 11 o b v i o u s . I m e a n , t h e w h o l e w e i g h t 12 t h i n g . I t r i e d t o s w i m o f f t h e 13 i s l a n d . I t r i e d t o e s c a p e f r o m a n 14 i s l a n d d u r i n g t h e e v e n i n g t o t r y a n d 15 e s c a p e f r o m h e r b e c a u s e i f I d i d n ' t 16 l o s e w e i g h t , t h e y w o u l d c u t m e o u t o f 17 t h e i r - - f i n a n c i a l l y o f f . I w o u l d 18 l o s e t h e p l a c e t h a t I w a s s t a y i n g a t . 19 I w o u l d l o s e m y e d u c a t i o n . Y o u n a m e 20 i t . 21 T h e y b u l l i e d m e w i t h 22 e v e r y t h i n g , j u s t l i k e t h e y d i d w i t h 23 t h e o t h e r g i r l s . 24 Q . I n p a r a g r a p h 3 8 , y o u s a y , 25 " M a x w e l l a n d E p s t e i n a l s o t h r e a t e n e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 333 of 469 Highly Confidential Page 333 1 HIGHLY CONFIDENTIAL AEO 2 plaintiff." 3 What was the threat that was 4 made to you by Maxwell? 5 MS. MCCAWLEY: Objection, 6 asked and answered. 7 A. The fact that I would lose 8 everything that they promised me. 9 They -- they were really naughty. You 10 k n o w , t h e y t o o k g i r l s f r o m v e r y 11 u n d e r p r i v i l e g e d f a m i l i e s . T h e y g a v e 12 t h e m a c c o m m o d a t i o n , t h e y g a v e t h e m 13 f o o d , g a v e t h e m m o n e y f o r 14 t r a n s p o r t a t i o n , y o u k n o w , p r i v a t e 15 p l a n e s , e t c e t e r a , e t c e t e r a . 16 S o i f I d i d n ' t h a v e s e x w i t h 17 J e f f r e y , I w o u l d b e h o m e l e s s a n d 18 s t a r v i n g i n N e w Y o r k , s o - - a n d m y 19 d r e a m o f g e t t i n g a f u l l - t i m e e d u c a t i o n 20 a t o n e o f t h e t o p f a s h i o n i n s t i t u t e s 21 i n t h e w o r l d w o u l d b e d i m i n i s h e d . 22 A n d t h a t ' s w h a t h e h e l d o v e r 23 m y h e a d , e x a c t l y l i k e h e d i d w i t h 24 a n d t h e o t h e r g i r l s . H e w a s 25 p a y i n g f o r a l l o f t h e i r e d u c a t i o n s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 334 of 469 Highly Confidential Page 334 1 HIGHLY CONFIDENTIAL AEO 2 Q. How do you know that? 3 A. Because they were telling 4 me. It was common knowledge amongst 5 all the girls. No other girl would be 6 there willingly just to have sex with 7 Jeffrey. 8 Q. In paragraph 40, you say, 9 "Maxwell instructed plaintiff how to 10 m a s s a g e E p s t e i n u s i n g t h e t e c h n i q u e s 11 t h a t h e p r e f e r r e d . " 12 A . C o r r e c t . 13 Q . I s t h a t t h e a c c i d e n t y o u 14 d e s c r i b e d e a r l i e r o n t h e i s l a n d ? 15 A . T h e r e w e r e m a n y t i m e s t h a t 16 s h e g a v e m e m a s s a g e t e c h n i q u e s t o h e l p 17 r e f i n e m y t e c h n i q u e s . J e f f r e y E p s t e i n 18 w a s a l l a b o u t m a s s a g e s a n d t h e 19 t e c h n i q u e s . H e l i k e d a s m a n y g i r l s 20 t o u c h i n g h i m a s p o s s i b l e a l l t h e t i m e . 21 S o t h e r e w a s m o r e t h a n o n e 22 o c c a s i o n t h a t G h i s l a i n e s h o w e d m e h o w 23 t o m a s s a g e h i m . I t c o u l d h a v e b e e n o n 24 t h a t s p e c i f i c t r i p o r t h e o t h e r o n e . 25 I ' m n o t q u i t e s u r e d a y , MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 335 of 469 Highly Confidential Page 335 1 HIGHLY CONFIDENTIAL AEO 2 time, what seat I was sitting in, what 3 color the seat it is, but she on more 4 than one occasion showed me how to 5 massage Jeffrey and how to get out the 6 extreme knots in his body. Because 7 everyone knows about his knots and how 8 he likes them to pop and, yeah, the 9 specific techniques that he likes. 10 Q . T h e n e x t s e n t e n c e r e a d s , 11 " D u r i n g p l a i n t i f f ' s f i r s t m a s s a g e , 12 d e f e n d a n t E p s t e i n c o n v e r t e d i t i n t o a 13 s e x u a l a c t . . . " a n d i t g o e s o n . 14 Y o u r f i r s t m a s s a g e t h a t 15 d e f e n d a n t E p s t e i n c o n v e r t e d i n t o a 16 s e x u a l a c t w a s p r i o r t o y o u m e e t i n g 17 M s . M a x w e l l , c o r r e c t ? 18 A . Y e s . 19 M S . M E N N I N G E R : I ' m g o i n g t o 20 s h o w y o u D e f e n d a n t ' s E x h i b i t 6 , 21 w h i c h a r e s o m e p h o t o g r a p h s . 22 ( D e f e n d a n t ' s E x h i b i t 6 , 23 B a t e s s t a m p e d R a n s o m e _ 0 0 0 0 1 7 , w a s 24 m a r k e d f o r i d e n t i f i c a t i o n . ) 25 Q . D o y o u r e c o g n i z e t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 336 of 469 Highly Confidential Page 336 1 HIGHLY CONFIDENTIAL AEO 2 photographs contained in Defendant's 3 Exhibit 6? 4 A. Yes, I do. 5 Q. What are they? 6 A. They are photos of Jeffrey's 7 island and the trip in December. 8 Q. Who took those photos? 9 A. Jean Luc took these specific 10 p h o t o s . 11 Q . A n d w h e n y o u w e r e a s k e d t o 12 p r o v i d e t h e s e t o u s , w h e r e d i d y o u 13 l o c a t e t h e m ? 14 A . I h a d a d i s k t h a t J e a n L u c 15 h a d g i v e n m e a s a p r e s e n t a n d m e m e n t o 16 o f t h a t h o l i d a y . 17 Q . W h e r e i s t h a t d i s k n o w ? 18 A . I n S p a i n . 19 Q . D o y o u s e e i n t h e c o r n e r 20 t h e r e a r e s o m e l i t t l e n u m b e r s w i t h 21 y o u r l a s t n a m e a n d t h e n s o m e - - 22 A . O h , y e a h , o k a y . 23 Q . I ' m o n l y s h o w i n g y o u t h a t s o 24 w e c a n t o g e t h e r g o t h r o u g h t o s o m e . 25 A . O k a y . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 337 of 469 Highly Confidential Page 337 1 HIGHLY CONFIDENTIAL AEO 2 Q. So if I could ask you to 3 turn to -- well, the first ones 4 show -- 5 A. Sergey, the guy who owns 6 Google, is kitesurfing. 7 Q. Got it. 8 A. Yeah, that's Sergey. 9 Q. How do you know that that's 10 S e r g e y ? 11 A . B e c a u s e h e c a m e f o r l u n c h 12 t h a t d a y a n d S e r g e y - - S e r g e y , h i , I ' m 13 S e r g e y . 14 H i , S e r g e y . 15 Q . D i d y o u h a v e a n y s e x u a l 16 r e l a t i o n s w i t h S e r g e y ? 17 A . N o . 18 Q . I f y o u c o u l d t u r n t o t h e o n e 19 t h a t s a y s R A N S O M E 2 2 i n t h e c o r n e r . 20 I t ' s a b o u t f i v e o r s i x p a g e s b a c k . 21 A . Y e s . 22 Q . W h o i s t h a t i n t h e 23 p h o t o g r a p h ? 24 A . J e a n L u c . 25 Q . A n d w h o i s t h e o t h e r p e r s o n ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 338 of 469 Highly Confidential Page 338 1 HIGHLY CONFIDENTIAL AEO 2 A. That's me. 3 Q. And when was this photograph 4 taken? 5 A. This was taken during the 6 December trip. 7 Q. Was there only one trip in 8 December? 9 A. From what I recall, yeah. 10 Q . W a s t h a t t h e f i r s t t r i p t h a t 11 y o u h a d t a k e n ? 12 A . N o . 13 Q . W h e n w a s t h e f i r s t t r i p y o u 14 h a d t a k e n ? 15 A . I a n s w e r e d t h a t p r e v i o u s l y , 16 w h i c h w a s n o t s o l o n g a f t e r I m e t 17 J e f f r e y E p s t e i n f o r t h e f i r s t t i m e . 18 S o I h a d b e e n t h e r e v a r i o u s t i m e s 19 b e f o r e t h e s e w e r e t a k e n . 20 Q . D o y o u k n o w h o w m a n y ? 21 A . L i k e I s a i d e a r l i e r , 22 s e v e r a l . I m e a n , I . . . 23 Q . A n d c a n y o u t u r n t o R A N S O M E 24 2 4 ? 25 A . M m - h m m . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 339 of 469 Highly Confidential Page 339 1 HIGHLY CONFIDENTIAL AEO 2 Q. Who is that? 3 A. That's the wonderful Sarah 4 Kellen. 5 Q. Did you take these 6 photographs? 7 A. Jean Luc took these ones. 8 Q. All of them? 9 A. There were -- I had other 10 p h o t o s a s w e l l . 11 Q . T h a t c a m e l a t e r , a s e p a r a t e 12 b a t c h ? 13 A . Y e a h , t h o s e a r e t h e h a r d 14 c o p i e s . 15 M S . M E N N I N G E R : I w i l l m a r k 16 i t n o w , t h e s e c o n d b a t c h , 17 D e f e n d a n t ' s E x h i b i t 7 . 18 ( D e f e n d a n t ' s E x h i b i t 7 , 19 B a t e s s t a m p e d R a n s o m e _ 0 0 0 2 0 4 , w a s 20 m a r k e d f o r i d e n t i f i c a t i o n . ) 21 M S . M E N N I N G E R : I a p o l o g i z e , 22 C o u n s e l . W e j u s t g o t t h e s e l a s t 23 n i g h t , s o I o n l y h a v e o n e c o p y 24 f o r t h e w i t n e s s . 25 M R . G U I R G U I S : T h a t ' s f i n e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 340 of 469 Highly Confidential Page 340 1 HIGHLY CONFIDENTIAL AEO 2 Q. So is Defendant's Exhibit 7 3 the second batch that you were 4 referring to? 5 A. Yes. 6 Q. Okay. So I'm just trying to 7 help be clear. 8 Defendant's Exhibit 6, you 9 believe were all given to you by Jean 10 L u c o n a d i s k ? 11 A . W e l l , t h e r e ' s a l o t o f 12 p h o t o s h e r e . S o I t o o k s o m e , I h a d 13 s o m e h a r d c o p i e s , a n d t h e y ' r e a l l 14 a c t u a l l y a l l t o g e t h e r , s o . . . 15 Q . O k a y , t h a t ' s f i n e . 16 A . Y e a h . I d o n ' t w a n t t o b e 17 u n c l e a r o n w h i c h e x h i b i t i s w h i c h . 18 T h e r e ' s h u n d r e d s h e r e . 19 Q . S o t h e p h o t o g r a p h s o f S a r a h 20 K e l l e n , y o u ' r e s a y i n g w e r e t a k e n b y 21 J e a n L u c , t h a t w e w e r e l o o k i n g a t i n 22 R A N S O M E 2 4 ? 23 A . W e l l , I c a n r e c h e c k t h e d i s k 24 a n d t h e n I c a n a c t u a l l y t e l l y o u 25 e x a c t l y w h i c h o n e s h e t o o k , b u t I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 341 of 469 Highly Confidential Page 341 1 HIGHLY CONFIDENTIAL AEO 2 can't recall every single photo on 3 Jean Luc's disk. But there were 4 multiple photos that were produced 5 from myself as well. 6 Q. Okay. I will just ask you 7 about a few. 8 A. Okay. 9 Q. RANSOME 24 is one that you 10 s a i d w a s - - o f S a r a h K e l l e n , w a s o n e 11 y o u s a i d y o u t h o u g h t J e a n L u c h a d 12 t a k e n ? 13 A . Y e s . 14 Q . I f y o u c o u l d t u r n t o R A N S O M E 15 4 0 . A n d t h e s e a r e i n o r d e r , s o 16 h o p e f u l l y t h a t w i l l b e e a s y . 17 A . O k a y . M m - h m m . 18 Q . W h o i s r e p r e s e n t e d i n t h i s 19 p h o t o g r a p h ? 20 A . T h a t ' s 21 Q . A n d w h e r e i s i n t h i s 22 p h o t o g r a p h , i f y o u k n o w ? 23 A . T h i s i s b y t h e b e a c h . 24 T h e r e ' s l i k e - - t h e r e ' s l i k e a s m a l l 25 b e a c h , l i k e t h e r e ' s a b e a c h h o u s e o n - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 342 of 469 Highly Confidential Page 342 1 HIGHLY CONFIDENTIAL AEO 2 the beachfront. 3 Q. Do you know who took this 4 photograph? 5 A. I can't remember. 6 Q. Okay. Turning a couple more 7 pages to RANSOME 42, who is that? 8 A. That's me. 9 Q. Are you smoking? 10 A . I a m . A n d t h a t w a s a f t e r 11 t h e a r g u m e n t t h a t I h a d w i t h J e f f r e y 12 a b o u t m e b e i n g o n l i t h i u m a n d m e n o t 13 b e i n g a b l e t o s m o k e . A n d t h a t w a s t h e 14 r e a s o n I w a s r e a l l y u p s e t , t h a t I 15 c o u l d n ' t s m o k e a n d t h a t I w a s b e i n g 16 p u t o n a s t u p i d d i e t . 17 S o J e f f r e y - - y e a h , J e f f r e y 18 s a i d i t w a s o k a y f o r m e t o s m o k e . I 19 w a s n ' t a l l o w e d t o s m o k e i n f r o n t o f 20 h i m . T h a t w a s t h e r u l e . 21 Q . D o y o u k n o w w h o t o o k t h i s 22 p h o t o g r a p h ? 23 A . I d o n ' t r e m e m b e r w h o t o o k 24 t h a t p h o t o g r a p h . 25 Q . I s i t o n t h e s a m e t r i p i n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 343 of 469 Highly Confidential Page 343 1 HIGHLY CONFIDENTIAL AEO 2 December? 3 A. Yes. 4 Q. Turning the next page, is 5 that also you and Jean Luc? 6 A. That's correct. 7 Q. Do you know who took this 8 photograph? 9 A. I can't remember. 10 Q . W a s i t a l s o i n t h e s a m e t i m e 11 f r a m e w h e n y o u w e r e u p s e t ? 12 A . I t w a s t h a t s a m e D e c e m b e r 13 t r i p , y e s . 14 M S . M E N N I N G E R : W e c a n g o 15 o f f t h e r e c o r d f o r j u s t a m i n u t e . 16 I t h i n k w e ' r e s w a p p i n g o u t 17 c o u n s e l . 18 ( M s . M c C a w l e y l e f t t h e 19 h e a r i n g a n d M s . S y e d e n t e r e d . ) 20 ( T i m e n o t e d : 4 : 5 6 p . m . ) 21 ( R e c e s s . ) 22 ( T i m e n o t e d : 4 : 5 6 p . m . ) 23 Q . L o o k i n g a t R A N S O M E 4 4 , 24 y o u ' r e s a y i n g i t ' s i n t h e s a m e t i m e 25 p e r i o d ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 344 of 469 Highly Confidential Page 344 1 HIGHLY CONFIDENTIAL AEO 2 A. Yeah. 3 Q. And also true of 45? 4 A. Yes. 5 Q. And 47? 6 A. Yes. It was the same 7 holiday, the same trip. 8 Q. And do you know who took 9 these photographs? 10 A . I d o n ' t r e m e m b e r . 11 Q . I s t h a t a l s o t r u e f o r 4 8 , 12 4 9 , 5 0 , 5 1 , 5 2 ? 13 A . I d o n ' t r e m e m b e r w h o t o o k 14 t h o s e p h o t o s . 15 Q . O k a y . C a n y o u t e l l f r o m 5 2 16 w h e r e y o u w e r e s i t u a t e d o n t h e i s l a n d ? 17 A . I t w a s o n t h e b e a c h . 18 Q . 5 3 , c a n y o u t e l l m e w h o t h a t 19 i s ? 20 A . T h a t ' s 21 Q . 5 4 a n d 5 5 , a l s o 22 A . T h a t ' s c o r r e c t . 23 Q . 6 9 , w h o i s t h a t ? 24 A . T h a t ' s J e f f r e y E p s t e i n . 25 Q . D o y o u k n o w w h o t o o k t h i s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 345 of 469 Highly Confidential Page 345 1 HIGHLY CONFIDENTIAL AEO 2 photograph? 3 A. I can't remember who took 4 this photograph. 5 Q. 71, is that you? 6 A. That's correct. 7 Q. Were you posing for the 8 photograph? 9 A. Most people pose for 10 p h o t o g r a p h s , e v e r y p h o t o g r a p h . S o I 11 p r e s u m e I w a s p o s i n g . 12 Q . D o y o u k n o w w h a t J e a n L u c ' s 13 l i n e o f w o r k i s ? 14 A . I t h i n k h e ' s w i t h m o d e l i n g 15 o r s o m e t h i n g , l i k e a m o d e l i n g a g e n t . 16 Q . D o y o u k n o w w h e r e h e ' s 17 b a s e d ? 18 A . I h a v e n o i d e a w h e r e h e ' s 19 b a s e d . 20 Q . D i d y o u m e e t h i m m o r e t h a n 21 o n c e ? 22 A . I c a n ' t r e m e m b e r i f I m e t 23 h i m m o r e t h a n o n c e . 24 Q . D i d y o u h a v e s e x u a l c o n t a c t 25 w i t h h i m ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 346 of 469 Highly Confidential Page 346 1 HIGHLY CONFIDENTIAL AEO 2 A. No. 3 Q. Did you give him a massage? 4 A. No. 5 Q. Sorry. Going back a little 6 bit further to RANSOME 121. 7 A. Mm-hmm. 8 Q. Who is in that photograph? 9 A. That's Nadia and 10 Q . O k a y . S o N a d i a ' s o n t h e 11 l e f t ? 12 A . T h a t ' s c o r r e c t . 13 Q . A n d o n t h e r i g h t ? 14 A . T h a t ' s c o r r e c t . 15 Q . D o y o u k n o w w h a t t h e y ' r e 16 d o i n g ? 17 A . I w o u l d l o v e t o k n o w w h a t 18 t h e y ' r e d o i n g m y s e l f , p e r s o n a l l y . 19 Q . D i d y o u t a k e t h i s 20 p h o t o g r a p h ? 21 A . I c a n ' t r e m e m b e r . 22 Q . T u r n i n g t o 1 2 3 , d o y o u k n o w 23 w h a t i s h a p p e n i n g i n t h a t p h o t o g r a p h ? 24 A . I t h i n k w e w e r e j u s t p l a y i n g 25 a r o u n d . I d o n ' t t h i n k i t w a s s e r i o u s , MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 347 of 469 Highly Confidential Page 347 1 HIGHLY CONFIDENTIAL AEO 2 you know. 3 Q. Okay. 4 A. Just to make that clear. 5 Q. Can I have you look at 126. 6 A. Yeah. 7 Q. Who is in that photograph? 8 A. That's and 9 Q. And is in the 10 b a c k g r o u n d ? 11 A . T h a t ' s c o r r e c t . 12 Q . O n 1 2 7 - - 13 A . M m - h m m . 14 Q . - - w h o i s i n t h a t 15 p h o t o g r a p h ? 16 A . T o t h e r i g h t - - s o r r y , t o 17 t h e l e f t i t ' s m y s e l f , , N a d i a 18 a n d t h e n . 19 Q . I s t h i s o n t h e s a m e D e c e m b e r 20 t r i p ? 21 A . T h a t ' s c o r r e c t . 22 Q . W h e n d i d J e a n L u c g i v e y o u 23 t h e d i s k ? 24 A . I c a n ' t r e m e m b e r w h e n h e 25 g a v e m e t h e d i s k . - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 348 of 469 Highly Confidential Page 348 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you know if these 3 photographs are ones that he took? 4 A. They were photos that were 5 taken during our holiday together, and 6 they were given to me as a memento, as 7 a present from John Luc. 8 Q. In person? 9 A. I can't remember. 10 Q . D o y o u r e c a l l t h e t o r t o i s e ? 11 A . I c a n ' t r e m e m b e r t h e 12 t o r t o i s e . 13 Q . A p a r t f r o m , 14 N a d i a a n d y o u r s e l f a n d J e a n L u c , d o 15 y o u r e m e m b e r a n y o n e e l s e b e i n g o n t h i s 16 p a r t i c u l a r t r i p ? 17 A . T h e r e w e r e - - t h e r e w e r e 18 q u i t e a f e w p e o p l e t h a t v i s i t e d t h e 19 i s l a n d . I d o n ' t r e m e m b e r t h e i r n a m e s . 20 Q . C a n I h a v e y o u l o o k a t 1 3 8 . 21 A . M m - h m m , y e a h . 22 Q . D o y o u k n o w w h o t o o k t h a t 23 p h o t o g r a p h ? 24 A . I d o n ' t k n o w w h o t o o k t h a t 25 p h o t o g r a p h . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 349 of 469 Highly Confidential Page 349 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you know when it was 3 taken? 4 A. It was taken that December 5 trip that I took with Ghislaine and 6 Jeffrey. 7 Q. How do you know that? 8 A. Because I remember what she 9 was wearing. And I was there. I was 10 t h e r e i n p e r s o n . L i k e , I w a s t h e r e . 11 Q . S o y o u s a w h e r o n t h e i s l a n d 12 w e a r i n g t h o s e c l o t h e s ? 13 A . I s a w h e r o n t h e i s l a n d 14 w e a r i n g t h o s e c l o t h e s . 15 Q . D i d y o u s e e h e r s i t t i n g i n 16 t h i s p o s i t i o n w h i l e o n t h e i s l a n d ? 17 A . I s a w h e r w i t h m y o w n e y e s 18 s i t t i n g i n t h i s p o s i t i o n . I w a s 19 p r o b a b l y s i t t i n g n e x t t o h e r . 20 Q . B u t y o u d o n ' t k n o w i f y o u 21 t o o k t h e p h o t o g r a p h o r s o m e o n e e l s e ? 22 A . Y o u k n o w w h a t ? P h o t o s a r e 23 p h o t o s . I d o n ' t r e m e m b e r i f I t o o k 24 t h e p h o t o o r i f s o m e o n e e l s e t o o k t h e 25 p h o t o . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 350 of 469 Highly Confidential Page 350 1 HIGHLY CONFIDENTIAL AEO 2 All I remember is I was with 3 Ghislaine on this trip. I was 4 probably sitting next to her in this 5 photo. I don't know who -- which 6 specific girl took the photo. 7 Q. Do you know if it was a girl 8 who took the photo? 9 A. I have no idea who took the 10 p h o t o . I j u s t r e m e m b e r s i t t i n g t h e r e 11 a n d r e m e m b e r b e i n g n e x t t o G h i s l a i n e 12 w h i l e s h e w a s w e a r i n g t h a t o u t f i t . I 13 w a s t h e r e d u r i n g t h a t t i m e f r a m e . 14 Q . R A N S O M E 1 3 9 , w h o i s t h a t , i f 15 y o u k n o w ? 16 A . T h a t i s S a r a h K e l l e n a f t e r 17 s h e h a d a s h o w e r , a n d s h e ' s i n 18 V i c t o r i a ' s S e c r e t p a j a m a s t h a t w e r e 19 s u p p l i e d t o u s . 20 Q . T h e y w e r e s u p p l i e d t o y o u ? 21 A . Y e s . A l l o f t h e o u t f i t s - - 22 t h e r e w e r e c l o t h e s t h a t w e r e p r o v i d e d 23 o n t h e i s l a n d b y J e f f r e y E p s t e i n , 24 w h i c h w e r e a l l V i c t o r i a ' s S e c r e t 25 c l o t h i n g : b i k i n i s , n i g h t w e a r . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 351 of 469 Highly Confidential Page 351 1 HIGHLY CONFIDENTIAL AEO 2 Q. You're talking about the 3 flannel pajamas? 4 A. Yes. 5 Q. Page 140, do you know who 6 took this photograph? 7 A. I don't remember taking this 8 photo, but I remember that very well 9 because we are doing mosaic on that 10 t a b l e . W e w e r e b u s y d o i n g a f i s h . S o 11 t h a t ' s w h a t a l l t h e s e a r e a p p a r a t u s 12 a r e . W e w e r e d o i n g m o s a i c s . 13 S o I d o n ' t r e m e m b e r i f I 14 t o o k t h a t p h o t o , b u t I r e m e m b e r I w a s 15 t h e r e , b e c a u s e w e w e r e a l l d o i n g 16 m o s a i c s . 17 Q . 1 4 2 ? 18 A . M m - h m m . 19 Q . D o y o u r e m e m b e r w h o t o o k 20 t h a t p h o t o g r a p h ? 21 A . I c a n ' t r e m e m b e r - - o h , t h e 22 B l a c k B e r r y . I c a n ' t r e m e m b e r w h o t o o k 23 a l l t h e p h o t o s w h e n I w a s t h e r e . Y o u 24 c a n s e e t h e m o s a i c s t h a t w e w e r e d o i n g 25 t o g e t h e r . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 352 of 469 Highly Confidential Page 352 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you still have that 3 mosaic? 4 A. No. It was on the big table 5 that she's sitting at, the large 6 table. So we actually stuck the 7 mosaic on the table. 8 Q. 143, do you know who took 9 that? 10 A . N o . W e w e r e a l l t h e r e 11 t o g e t h e r . 12 Q . G o i n g t h r o u g h t h e r e s t , d o 13 y o u s e e a n y t h a t y o u k n o w w h o t o o k t h e 14 p h o t o ? 15 A . N o . 16 M R . G U I R G U I S : T a k e y o u r 17 t i m e a n d l o o k a t e a c h o n e m . 18 D o n ' t j u s t - - t a k e y o u r t i m e . 19 C a n w e t a k e a b r e a k f o r j u s t 20 a m i n u t e . 21 ( T i m e n o t e d : 5 : 0 6 p . m . ) 22 ( R e c e s s . ) 23 ( T i m e n o t e d : 5 : 1 5 p . m . ) 24 Q . D i d y o u h a v e a c h a n c e t o 25 l o o k t h r o u g h t h e r e s t o f t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 353 of 469 Highly Confidential Page 353 1 HIGHLY CONFIDENTIAL AEO 2 photographs in Defendant's Exhibit 6? 3 A. No, because I took a break, 4 so I will continue now. 5 Q. Sure. 6 A. I can't remember who took 7 these photos. It was during all the 8 same trip. 9 Q. It was what? 10 A . I t w a s d u r i n g t h a t s a m e 11 t r i p . 12 Q . C a n I h a v e y o u t a k e a l o o k 13 a t R A N S O M E 1 5 4 . I t ' s o n e o f t h e l a s t 14 f e w o f t h a t e x h i b i t . 15 A . Y e s . 16 Q . D o y o u k n o w w h e r e t h a t 17 p h o t o g r a p h w a s t a k e n ? 18 A . I c a n ' t r e m e m b e r . 19 Q . D o y o u k n o w i f y o u w e r e 20 t h e r e ? 21 A . I c a n ' t r e m e m b e r . 22 Q . D o e s i t a p p e a r t o b e i n s i d e 23 o f a s h o p ? 24 A . I t a p p e a r s t h a t w a y . 25 Q . D o y o u r e c a l l g o i n g t o a n y MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 354 of 469 Highly Confidential Page 354 1 HIGHLY CONFIDENTIAL AEO 2 shops on that trip? 3 A. I went everywhere with 4 Jeffrey, so... 5 Q. Did that include shops? 6 A. Yes. 7 Q. Do you recall this shop? 8 A. There were many shops that I 9 visited. I can't recall this specific 10 s h o p . 11 Q . D o y o u k n o w w h o t h e 12 g e n t l e m a n i s ? 13 A . I c a n ' t r e m e m b e r h i s n a m e . 14 Q . A n d b y g e n t l e m a n , I m e a n t h e 15 p e r s o n o n t h e l e f t . 16 A . T h a n k y o u f o r c l a r i f y i n g 17 t h a t . 18 N o , I d o n ' t r e c a l l . I d o n ' t 19 k n o w w h o t h i s J e f f r e y - - J e f f r e y ' s o n 20 t h e r i g h t . I d o n ' t k n o w t h e n a m e , I 21 c a n ' t r e m e m b e r t h e n a m e o f t h i s g u y . 22 Q . W e a r i n g a b e l t ? 23 A . T r y i n g o n a b e l t , y e a h . 24 Q . O k a y . T u r n i n g t o 25 D e f e n d a n t ' s E x h i b i t 7 . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 355 of 469 Highly Confidential Page 355 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes. 3 Q. Do you recognize these 4 photographs? 5 A. I remember this photograph, 6 the first one, very well. 7 Q. What is it? 8 A. It's a box -- it's a box of 9 condoms that were placed around the 10 i s l a n d f o r t h e g u e s t s t o u s e a t t h e i r 11 l e i s u r e . 12 Q . W h e r e o n t h e i s l a n d w a s t h i s 13 o n e ? 14 A . I c a n ' t r e m e m b e r . 15 Q . D i d y o u t a k e t h e p h o t o g r a p h ? 16 A . I c a n ' t r e m e m b e r . 17 Q . D o y o u h a v e t h i s p h o t o g r a p h 18 a t y o u r h o u s e n o w ? 19 A . I ' l l h a v e t o r e c h e c k . I 20 c a n ' t r e m e m b e r w h e r e t h i s p h o t o c a m e 21 f r o m , i f i t w a s e i t h e r o n t h e d i s k o r 22 b y m y s e l f . B u t i t w a s - - I r e c o g n i z e 23 t h e b o x . T h e r e w e r e b o x e s l i k e t h i s 24 p u t e v e r y w h e r e . 25 Q . D i d y o u h a v e a n y p h o t o g r a p h s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 356 of 469 Highly Confidential Page 356 1 HIGHLY CONFIDENTIAL AEO 2 contained on your computer? 3 A. No. 4 Q. Where were photographs that 5 you gathered together to produce? 6 A. You've got them all there. 7 I just need to -- all the photos that 8 I have, you guys have. So I don't 9 know. 10 Q . W h e r e w e r e t h e y ? W h e r e d i d 11 y o u f i n d t h e m ? 12 A . M y p h o t o s ? 13 Q . Y e s . 14 A . I n m y s t o r a g e . 15 Q . W h e r e i s t h a t ? 16 A . I t w a s i n E n g l a n d . I t w a s 17 i n m y p r i v a t e b o x w h e r e I k e e p a l l m y 18 p h o t o s f r o m , y o u k n o w , w h e n I w a s a 19 b a b y t o n o w , s o . . . 20 Q . I s t h a t w i t h y o u r m o t h e r ? 21 A . N o , t h a t w a s n ' t w i t h m y 22 m o t h e r . 23 Q . W h e r e i s t h e s t o r a g e i n 24 L o n d o n ? 25 A . T h e s t o r a g e w a s i n R a m s g a t e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 357 of 469 Highly Confidential Page 357 1 HIGHLY CONFIDENTIAL AEO 2 Q. And where did it go? 3 A. It's now in my current 4 residency in Spain. 5 Q. When you gathered the photos 6 together and gave them to your lawyer 7 to give to us, did you gather them in 8 Spain or in London? 9 A. My stuff was in London and I 10 m o v e d t o B a r c e l o n a . I w a s c u r r e n t l y 11 s t a y i n g i n B a r c e l o n a w i t h P e t e r , a n d 12 w e w e r e j u s t g o i n g t o c o m m u t e b e t w e e n 13 S t . A l b a n s a n d B a r c e l o n a . 14 W h e n I c a m e f o r w a r d , I k n e w 15 t h a t I h a d p h o t o s t h a t I h a d t a k e n a n d 16 I k n e w t h a t I h a d m a t e r i a l s . 17 A t t h a t s a m e t i m e i s - - 18 d u r i n g t h a t s a m e t i m e , I c o n t a c t e d 19 M a u r e e n C a l l a h a n . W h e n I c o n t a c t e d 20 M a u r e e n C a l l a h a n , t h e r e w e r e p e o p l e 21 t h a t w e r e f o l l o w i n g m e i n B a r c e l o n a , 22 a n d I g o t s c a r e d . 23 I t h e n c o n t a c t e d m y e s t a t e 24 a g e n t . I g o t m y e n t i r e f l a t p a c k e d u p 25 i n S t . A l b a n s a n d m o v e d t o S p a i n . I MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 358 of 469 Highly Confidential Page 358 1 HIGHLY CONFIDENTIAL AEO 2 was too frightened to actually fly 3 back myself and pack, so I stayed in 4 Barcelona and a company packed my 5 things for me and brought them to me. 6 Q. Okay. So they were in St. 7 Albans. You had them all packed up 8 and sent to you in Barcelona, where 9 you relocated? 10 A . T h a t ' s c o r r e c t . 11 Q . W h e n y o u w e r e i n t e r a c t i n g 12 w i t h M s . C a l l a h a n , d i d y o u s e n d h e r 13 a n y p h o t o g r a p h s ? 14 A . S o r r y , s o r r y . W h o i s 15 M s . C a l l a h a n ? S o r r y . I ' m j u s t r e a l l y 16 t i r e d . I ' m r e a l l y b a d w i t h n a m e s . 17 C a l l a h a n f i r s t n a m e , p l e a s e . 18 Q . D o y o u k n o w w h o M s . C a l l a h a n 19 i s ? 20 A . I t ' s r e a l l y l a t e , I ' v e h a d a 21 r e a l l y l o n g d a y , a n d I ' v e s a i d 22 n u m e r o u s t i m e s t h r o u g h o u t t h e d a y t h a t 23 I a m s l i g h t l y d y s l e x i c a n d I h a v e 24 d i f f i c u l t y w i t h n a m e s . 25 C a n y o u j u s t t e l l m e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 359 of 469 Highly Confidential Page 359 1 HIGHLY CONFIDENTIAL AEO 2 Ms. Callahan's first name so I can 3 answer the question, please. 4 Q. Is Ms. Callahan the name of 5 the individual that you said worked 6 for the New York Post? 7 A. Oh, sorry. Maureen 8 Callahan, yes. 9 Q. Did you send Ms. Callahan 10 a n y p h o t o g r a p h s ? 11 A . N o t o f t h i s , n o . N o t o f 12 t h i s . 13 Q . D i d y o u s e n d h e r p h o t o g r a p h s 14 o f s o m e t h i n g e l s e ? 15 A . I d i d . I s e n t h e r a p h o t o 16 o f m y e x - b o y f r i e n d a n d m y s e l f . 17 Q . W h o w a s y o u r e x - b o y f r i e n d ? 18 A . 19 Q . W h o i s t h a t ? 20 A . s e r f 21 s e r f . 22 23 24 Q . A n d w h e n w a s h e y o u r 25 b o y f r i e n d ? - MAGNA9 LEGAL SERVICES ■■■ - ■ Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 360 of 469 Highly Confidential Page 360 1 HIGHLY CONFIDENTIAL AEO 2 A. In Edinburgh, before I moved 3 to New York. 4 Q. Why did you send 5 Ms. Callahan a photograph of yourself 6 and your boyfriend? 7 A. Because I wanted to show her 8 I was telling the truth about 9 everything. I didn't want to send a 10 j o u r n a l i s t a n y t h i n g r e g a r d i n g J e f f r e y 11 E p s t e i n b e c a u s e I - - I - - w e l l , I s e n t 12 h e r a p i c t u r e o f a n d I 13 t o s h o w t h a t I w a s t e l l i n g m y s t o r y , 14 t h a t m y s t o r y w a s s t r a i g h t f r o m t h e 15 b e g i n n i n g , t h a t I k n o w t h e p e o p l e I 16 m e n t i o n e d , e t c e t e r a . S o . . . 17 Q . S o f i g u r e d i n t o t h e 18 s t o r y t h a t y o u h a d r e l a y e d t o 19 M s . C a l l a h a n ? 20 A . Y e s , b e c a u s e a n d I 21 h a d a b r e a k u p , a n d t h a t w a s o n e o f t h e 22 r e a s o n s I m o v e d t o N e w Y o r k . 23 Q . H a v e y o u h a d c o n t a c t w i t h 24 s i n c e t h e n ? 25 A . T h r o u g h o u t t h e y e a r s o n a n d - - - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 361 of 469 Highly Confidential Page 361 1 HIGHLY CONFIDENTIAL AEO 2 off, but, no, I don't have any contact 3 with him now. 4 Q. Apart from the photograph 5 with yourself and did you send 6 Ms. Callahan any other documents or 7 photographs? 8 A. I can't remember. 9 Q. Did you have contact with 10 a n y o t h e r m e d i a p e r s o n ? 11 A . I c a n ' t r e m e m b e r . 12 Q . D i d y o u m e e t w i t h a n y o n e 13 f r o m t h e D a i l y M a i l ? 14 A . N o . 15 Q . F r o m t h e M i r r o r ? 16 A . N o . 17 Q . D i d y o u s p e a k t o a n y o n e f r o m 18 t h e D a i l y M a i l ? 19 A . N o . 20 Q . A n y o n e f r o m t h e M i r r o r ? 21 A . N o . 22 Q . T h e I n d e p e n d e n t ? 23 A . N o . 24 Q . T h e G u a r d i a n ? 25 A . N o . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 362 of 469 Highly Confidential Page 362 1 HIGHLY CONFIDENTIAL AEO 2 Q. When you got these boxes of 3 items from St. Albans and you looked 4 at them while you were in Barcelona; 5 is that right? 6 A. I -- 7 MR. GUIRGUIS: Objection. 8 A. I looked at them -- I 9 vaguely went through the photos in St. 10 A l b a n s . I k n e w w h a t w a s t h e r e . Y e a h , 11 I - - t h e y w e r e t h e r e , s o I s a w t h e m . 12 I w e n t t h r o u g h m y p h o t o s , l i k e a l l m y 13 m e m o r a b i l i a t h a t h a d b e e n i n s t o r a g e . 14 B u t t h a t ' s a b o u t i t . 15 Q . A n d y o u s e l e c t e d p h o t o g r a p h s 16 t o s e n d t o y o u r l a w y e r s t o g i v e t o u s , 17 c o r r e c t ? 18 A . I w a s a s k e d t o - - w e l l I 19 j u s t p r o v i d e d e v e r y - - a l l t h e 20 e v i d e n c e t h a t I h a d . 21 Q . W h e n d i d d o y o u t h a t ? 22 M R . G U I R G U I S : I ' m g o i n g t o 23 o b j e c t . I f y o u ' r e t a l k i n g a b o u t 24 a c o m m u n i c a t i o n b e t w e e n c l i e n t 25 a n d c o u n s e l - - i s t h a t w h a t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 363 of 469 Highly Confidential Page 363 1 HIGHLY CONFIDENTIAL AEO 2 you're asking for? 3 MS. MENNINGER: No. I'm 4 asking when did you provide all 5 of your evidence, which is what 6 she said that she had. 7 MR. GUIRGUIS: The photos -- 8 you mean when she provided them 9 to her counsel? 10 M S . M E N N I N G E R : Y e s . 11 Q . W h e n d i d y o u p r o v i d e t h e m t o 12 y o u r c o u n s e l ? 13 M R . G U I R G U I S : O b j e c t i o n . 14 D o n o t a n s w e r . 15 Q . D i d y o u r e c e i v e a s u b p o e n a 16 i n t h i s c a s e ? 17 A . I d o n ' t k n o w w h a t a s u b p o e n a 18 i s . 19 M S . M E N N I N G E R : L e t ' s m a r k 20 D e f e n d a n t ' s E x h i b i t 8 . 21 ( D e f e n d a n t ' s E x h i b i t 8 , 22 N o t i c e o f S e r v i c e o f R u l e 4 5 23 S u b p o e n a a n d N o t i c e o f D e p o s i t i o n 24 o f S a r a h R a n s o m e , w a s m a r k e d f o r 25 i d e n t i f i c a t i o n . ) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 364 of 469 Highly Confidential Page 364 1 HIGHLY CONFIDENTIAL AEO 2 Q. Have you seen this document 3 before? 4 A. Let me just have a look, 5 okay. I don't remember. 6 Q. Have you ever seen this 7 document before? 8 MR. GUIRGUIS: Objection, 9 asked and answered. 10 M S . M E N N I N G E R : I ' m s o r r y . 11 I d i d n ' t h e a r a n a n s w e r . 12 A . I ' v e s e e n v a r i o u s p a p e r s . I 13 r e m e m b e r s p e c i f i c a l l y s e e i n g t h e 14 d e p o s i t i o n s . T h e r e ' s b e e n m i l l i o n s o f 15 d o c u m e n t s . I c a n ' t r e m e m b e r w h i c h 16 s p e c i f i c d o c u m e n t s I ' v e s e e n . 17 Q . O k a y . I f I c o u l d h a v e y o u 18 t u r n t o t h e l a s t t h r e e p a g e s , w h e r e i t 19 s a y s " D o c u m e n t s t o b e P r o d u c e d . " 20 A . M m - h m m . 21 Q . H a v e y o u s e e n t h a t l i s t 22 b e f o r e ? 23 A . Y e s , I h a v e . 24 Q . D i d y o u c o n d u c t a s e a r c h o f 25 y o u r r e c o r d s t o p r o d u c e d o c u m e n t s ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 365 of 469 Highly Confidential Page 365 1 HIGHLY CONFIDENTIAL AEO 2 A. Yes, I believe that I 3 produced every single document I can. 4 Q. After looking at this list, 5 did you go back and look through your 6 photographs in Barcelona? 7 A. As I said, I looked at 8 everything I had during that time 9 frame and I produced everything I can 10 d u r i n g t h a t t i m e f r a m e t h a t I w a s w i t h 11 J e f f r e y . 12 Q . J u s t t e l l m e w h a t y o u d i d i n 13 o r d e r t o m a k e s u r e y o u h a d p r o d u c e d 14 e v e r y t h i n g t h a t w a s c a l l e d f o r i n t h i s 15 l i s t . 16 A . O k a y . S o I w e n t t h r o u g h a 17 b o x o f a b o u t o v e r 5 , 0 0 0 p h o t o s t h a t I 18 h a d , a n d I w e n t t h r o u g h e v e r y s i n g l e 19 p h o t o , e v e r y s i n g l e d i s k , e v e r y t h i n g 20 t h a t I h a d . 21 I w e n t t h r o u g h a l l m y 22 e m a i l s . 23 I t r i e d t o l o o k f o r t h e 24 B l a c k B e r r y s i m c a r d , w h i c h I h a d h o p e d 25 t h a t I h a d k e p t , w h i c h h a d a l l MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 366 of 469 Highly Confidential Page 366 1 HIGHLY CONFIDENTIAL AEO 2 Ghislaine's messages on and Jeffrey's 3 and Lesley's, and stupidly I misplaced 4 that, which is really annoying. 5 But I myself, you know, 6 considering my objective is to get 7 these people and get justice for the 8 abuse that Ghislaine caused me -- and 9 Jeffrey -- I have given as sufficient 10 e v i d e n c e t h a t I h a v e . 11 Q . D i d y o u l o o k f o r a l l 12 p h o t o g r a p h s t a k e n b y y o u o r c o n t a i n i n g 13 a n y i m a g e o f y o u a t o r n e a r a n y h o m e , 14 b u s i n e s s , p r i v a t e v e h i c l e o r a n y o t h e r 15 p r o p e r t y o w n e d o r c o n t r o l l e d b y 16 J e f f r e y E p s t e i n , a s i n d i c a t e d i n 17 p a r a g r a p h 7 ? 18 A . Y e s . 19 Q . L i k e w i s e i n p a r a g r a p h 8 , d i d 20 y o u l o o k f o r a n y p h o t o g r a p h s t h a t 21 d e p i c t a n y h o m e , b u s i n e s s , p r i v a t e 22 v e h i c l e o r a n y o t h e r p r o p e r t y o w n e d o r 23 c o n t r o l l e d b y J e f f r e y E p s t e i n ? 24 A . Y e s . 25 Q . A n d y o u d i d t h a t a f t e r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 367 of 469 Highly Confidential Page 367 1 HIGHLY CONFIDENTIAL AEO 2 reviewing this list of documents? 3 A. Yeah, I mean, I received the 4 list and I've complied with 5 everything. I have given absolutely 6 everything that I can to you guys. 7 Q. Have you given all of your 8 passports, travel visas or permissions 9 to live, work or study in other 10 c o u n t r y ? 11 A . I h a v e n ' t g i v e n m y c u r r e n t 12 p a s s p o r t s , b u t I ' v e g i v e n e v e r y t h i n g 13 t h a t I h a v e ; d o c u m e n t s , p a s s p o r t s t h a t 14 I h a d d u r i n g , c o m m e r c i a l p l a n e 15 t i c k e t s . 16 Q . D o y o u h a v e a n y v i s a s ? 17 A . I h a v e a v i s a c o m i n g h e r e , 18 b u t t h a t ' s t h e o n l y v i s a t h a t I h a v e . 19 Q . D o y o u h a v e a n y v i s a 20 a p p l i c a t i o n s ? 21 A . N o . 22 Q . D o y o u h a v e a n y o t h e r p l a n e 23 t i c k e t s o r b o a r d i n g p a s s e s f o r t h e 24 p e r i o d 2 0 0 6 t o 2 0 0 7 ? 25 A . N o . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 368 of 469 Highly Confidential Page 368 1 HIGHLY CONFIDENTIAL AEO 2 Q. Turning back to Defendant's 3 Exhibit 7, these photographs, do you 4 know what the second photograph 5 represents? 6 A. Yes, that's me playing with 7 Ghislaine's dog, a Yorkshire Terrier. 8 Q. Where are you in this 9 picture? 10 A . I w a s i n t h e g i r l s ' b e d r o o m 11 w h e r e w e a l l s l e p t , a n d I w a s o n m y 12 b e d p l a y i n g w i t h G h i s l a i n e ' s d o g . 13 Q . W h e n w a s t h i s p h o t o g r a p h 14 t a k e n ? 15 A . I c a n ' t r e m e m b e r . 16 Q . W a s i t t h e s a m e t r i p a s 17 D e f e n d a n t ' s E x h i b i t 6 ? 18 A . I c a n ' t r e m e m b e r . 19 Q . O k a y . D o y o u k n o w w h o t o o k 20 t h e p h o t o g r a p h i n 2 0 5 ? 21 A . I c a n ' t r e m e m b e r . 22 Q . 2 0 6 ? 23 M R . G U I R G U I S : O b j e c t i o n t o 24 f o r m . 25 A . I c a n ' t r e m e m b e r . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 369 of 469 Highly Confidential Page 369 1 HIGHLY CONFIDENTIAL AEO 2 Q. 207? 3 MR. GUIRGUIS: Objection to 4 form. 5 A. Can't remember. 6 Q. Who is depicted in 208? 7 A. 8 Q. And? 9 A. Oh, and me. That's me. 10 Q . A n d 2 0 9 ? 11 A . S o r r y . T h a t ' s m e , 12 J e a n L u c , a n d o n e o f J e f f r e y ' s s t a f f 13 m e m b e r s i n t h e b a c k g r o u n d . 14 Q . T u r n i n g t o 2 1 3 , i s t h a t y o u ? 15 A . Y e s , t h a t ' s m e . 16 Q . A n d w h e r e a r e y o u l o c a t e d ? 17 A . I ' m t r y i n g t o r e m e m b e r 18 s p e c i f i c a l l y w h e r e t h a t i s o n t h e 19 i s l a n d . I t h i n k i t ' s n e a r t h e m a i n 20 h o u s e , t h e r e w a s a - - y e a h , t h e r e w a s 21 a f o u n t a i n n e a r t h e m a i n h o u s e . 22 Q . D o y o u k n o w w h e t h e r y o u t o o k 23 t h i s ? 24 A . I d o n ' t r e m e m b e r . 25 Q . D o y o u k n o w w h e t h e r y o u h a d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 370 of 469 Highly Confidential Page 370 1 HIGHLY CONFIDENTIAL AEO 2 this photograph on the disk? 3 A. I think these were one of my 4 photos. 5 Q. Was it in hard copy, like an 6 actual print? 7 A. I can't remember. I have to 8 double check if there are more copies. 9 But I think -- yeah, I'm pretty sure 10 t h i s i s a h a r d c o p y . 11 Q . D o e s i t h a v e a b a c k , l i k e 12 w h e n i t w a s d e v e l o p e d o r p r i n t e d ? 13 A . I c a n c h e c k . 14 Q . I s i t b a c k i n B a r c e l o n a ? 15 A . N o . 16 Q . W h e r e a r e t h e s e p h o t o g r a p h s ? 17 A . I h a v e g i v e n a l l t h e 18 p h o t o g r a p h s t o m y l a w y e r s . 19 Q . O k a y . H o w d i d y o u d o t h a t ? 20 B y h a n d i n g t h e m o v e r i n p e r s o n ? 21 S e n d i n g t h e m b y m a i l ? 22 A . H a n d i n g t h e m o v e r i n p e r s o n . 23 Q . W a s t h i s s o m e t y p e o f p h o t o 24 s h o o t r e p r e s e n t e d i n R A N S O M E 2 1 4 , 2 1 5 , 25 2 1 6 ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 371 of 469 Highly Confidential Page 371 1 HIGHLY CONFIDENTIAL AEO 2 A. Sorry. 214, this is not a 3 photo shoot. We were just messing 4 around on the island. 5 Q. Do you know who you were 6 messing around with? 7 A. We were all having fun 8 together. 9 Q. Were there photographs of 10 o t h e r p e o p l e t a k e n a r o u n d t h e s a m e 11 t i m e t h a t y o u h a v e ? 12 A . I h a v e g i v e n a l l t h e p h o t o s 13 t h a t I h a v e . 14 Q . I n o t h e r w o r d s , i f y o u w e r e 15 m e s s i n g a r o u n d w i t h a t t h i s 16 t i m e a n d t h e r e ' s a p h o t o o f 17 t h a t y o u h a v e , d i d y o u p r o v i d e t h a t ? 18 A . I p r o v i d e d e v e r y s i n g l e 19 p h o t o g r a p h t h a t I h a v e . 20 Q . A n d 2 1 8 , w a s t h a t a p h o t o 21 s h o o t ? 22 A . T h a t w a s m e w h e n I w a s 23 n a k e d , a c t u a l l y , a n d I h a d a t o w e l 24 a r o u n d m e . S o I t h i n k I j u s t h a d a 25 m a s s a g e b y J e f f r e y , b e c a u s e I w a s - - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 372 of 469 Highly Confidential Page 372 1 HIGHLY CONFIDENTIAL AEO 2 naked underneath the towel. 3 Q. Also 219 and 220? 4 A. Yep. 5 Q. Those were just after a 6 massage? 7 A. Yeah. You can tell I look 8 really, really happy to be out of 9 there, so... 10 Q . D o y o u k n o w w h i c h t r i p t h a t 11 w a s o n ? 12 A . I c a n ' t r e m e m b e r w h i c h t r i p . 13 Q . A n d p a g e R A N S O M E 2 2 1 , w h o i s 14 i n t h a t p h o t o g r a p h ? 15 A . M y s e l f , a n d J e a n L u c , 16 a n d a s t a f f m e m b e r i n t h e b a c k g r o u n d . 17 Q . D o y o u k n o w w h a t ' s h a p p e n i n g 18 i n 2 2 3 ? 19 A . O h , n o . Y e s . S o J e f f r e y 20 p r o v i d e d c o s m e t i c s f o r a l l t h e g i r l s . 21 W e h a d t o l o o k o u r b e s t . S o t h a t w a s 22 a C r è m e d e l a M e r f a c i a l m a s k t h a t h e 23 r e g u l a r l y g a v e t o t h e g i r l s s o t h e i r 24 s k i n w a s n i c e . W e h a d t o p - l i n e 25 c o s m e t i c s i n o u r b a t h r o o m t o u s e a t - MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 373 of 469 Highly Confidential Page 373 1 HIGHLY CONFIDENTIAL AEO 2 our disposal. 3 Q. So in 223 and 224 you're 4 doing a facial mask? 5 A. I'm attempting to do a 6 facial. It's not going that well. 7 Q. And going to 229, do you 8 know where that was taken? 9 A. That was on Jeffrey's 10 s p e e d b o a t t o - - g o i n g t o t h e i s l a n d . 11 Q . D o y o u k n o w w h e n ? 12 A . I d o n ' t r e c a l l w h i c h d a t e 13 t h a t w a s . 14 Q . D i d y o u h a v e a n y c o n t a c t 15 w i t h t h e m a i l o n S u n d a y ? 16 M R . G U I R G U I S : O b j e c t i o n . 17 H u h ? 18 Q . D i d y o u e v e r h a v e a n y 19 c o n t a c t w i t h t h e m a i l o n S u n d a y ? 20 A . N o . 21 M R . G U I R G U I S : Y o u m e a n t h e 22 m a i l a s i n p o s t a g e ? I ' m s o r r y . 23 M R . P A G L I U C A : T h e 24 n e w s p a p e r . 25 A . N o , n o , I h a v e n ' t h a d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 374 of 469 Highly Confidential Page 374 1 HIGHLY CONFIDENTIAL AEO 2 correspondence with them, no. 3 Q. Apart from Ms. Callahan, 4 have you had contact with any member 5 of the press? 6 A. Oh, I contacted Bianca 7 Jagger because she runs a foundation 8 that helps abused girls. 9 Q. Okay. Did you have any 10 c o n t a c t w i t h a n y o t h e r m e m b e r o f t h e 11 p r e s s ? 12 A . N o . 13 Q . W h e n w a s t h e l a s t t i m e t h a t 14 y o u s a w G h i s l a i n e M a x w e l l ? 15 A . I n N e w Y o r k , b e f o r e I l e f t 16 i n 2 0 0 7 . 17 Q . H o w l o n g b e f o r e y o u l e f t ? 18 A . I c a n ' t r e m e m b e r . 19 Q . W h a t t i m e o f y e a r w a s i t ? 20 A . W h e n I l e f t ? 21 Q . Y e s . 22 A . I t w a s t h e e n d o f A p r i l . 23 Q . H o w d o y o u k n o w t h a t ? 24 A . B e c a u s e I a m - - o n s o m e o f 25 t h e e m a i l s , I w a n t e d t o g o h o m e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 375 of 469 Highly Confidential Page 375 1 HIGHLY CONFIDENTIAL AEO 2 Actually, back to my mom. 3 Q. When's the last time you 4 spoke to Ghislaine Maxwell? 5 A. Before I left New York. 6 Q. Okay. Do you know how long 7 before you left? 8 A. I can't remember. 9 Q. Tell me what you recall 10 a b o u t t h e l a s t t i m e y o u s a w G h i s l a i n e 11 M a x w e l l . 12 A . I c a n ' t r e m e m b e r . 13 Q . W h e r e i t w a s ? 14 A . I c a n ' t r e m e m b e r m y l a s t 15 i n t e r a c t i o n w i t h G h i s l a i n e . 16 Q . O r t h e l a s t t i m e y o u s p o k e 17 w i t h h e r ? 18 M R . G U I R G U I S : O b j e c t i o n , 19 a s k e d a n d a n s w e r e d . 20 A . I c a n ' t r e m e m b e r t h e l a s t 21 t i m e I s p o k e t o h e r . Y e a h , I d o n ' t 22 r e m e m b e r t h e s p e c i f i c s . 23 Q . W e r e y o u l i v i n g w i t h A d a m a t 24 t h e t i m e y o u l a s t s p o k e t o G h i s l a i n e ? 25 A . Y e s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 376 of 469 Highly Confidential Page 376 1 HIGHLY CONFIDENTIAL AEO 2 Q. What did she say to you when 3 you last spoke to her -- 4 MR. GUIRGUIS: Objection, 5 asked and answered. 6 Q. -- when you were living with 7 Adam? 8 MR. GUIRGUIS: Objection, 9 asked and answered. 10 A . I c a n ' t r e m e m b e r . 11 Q . D i d y o u s p e a k t o h e r a b o u t 12 F I T ? 13 M R . G U I R G U I S : O b j e c t i o n , 14 a s k e d a n d a n s w e r e d . 15 A . I h a d s p o k e n t o h e r n u m e r o u s 16 t i m e s a b o u t F I T . 17 M S . M E N N I N G E R : C o u n s e l , 18 w h e n d i d I a l r e a d y a s k h e r , d i d 19 y o u s p e a k t o h e r a b o u t F I T . 20 M R . G U I R G U I S : Y o u ' v e a s k e d 21 h e r - - 22 T H E W I T N E S S : S e v e r a l t i m e s . 23 M S . M E N N I N G E R : I ' m n o t 24 t a l k i n g t o y o u . 25 M R . G U I R G U I S : O k a y . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 377 of 469 Highly Confidential Page 377 1 HIGHLY CONFIDENTIAL AEO 2 THE WITNESS: That was rude. 3 MR. GUIRGUIS: It was, and 4 I'm not going to answer her 5 question now. 6 You can proceed, Counsel. 7 MS. MENNINGER: When did I 8 last ask her about -- 9 MR. GUIRGUIS: I'm not going 10 t o a n s w e r y o u r q u e s t i o n . I ' m n o t 11 b e i n g d e p o s e d . I ' m n o t a r g u i n g 12 o b j e c t i o n s w i t h y o u . Y o u h a v e 13 a s k e d h e r a b o u t i t b e f o r e ; t h a t ' s 14 w h y I m a d e m y o b j e c t i o n . 15 Y o u c a n p r o c e e d w i t h y o u r 16 q u e s t i o n i n g w h e n e v e r y o u l i k e , 17 C o u n s e l . 18 M S . M E N N I N G E R : T h a n k y o u . 19 M R . G U I R G U I S : F e e l f r e e t o 20 s e a r c h t h e t r a n s c r i p t l a t e r . 21 M S . M E N N I N G E R : I w o u l d l i k e 22 t o m a r k a s D e f e n d a n t ' s E x h i b i t 8 . 23 ( D e f e n d a n t ' s E x h i b i t 8 , 24 B a t e s s t a m p e d R A N S O M E _ 0 0 0 0 0 4 , w a s 25 m a r k e d f o r i d e n t i f i c a t i o n . ) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 378 of 469 Highly Confidential Page 378 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you recognize Defendant's 3 Exhibit 8? 4 A. Yes, I do. 5 Q. What is it? 6 A. They're emails. 7 Q. Did you find these emails 8 and produce them? 9 A. That's correct. 10 Q . W h e r e d i d y o u f i n d t h e m ? 11 A . O n m y o l d e m a i l a c c o u n t t h a t 12 I h a d d u r i n g t h a t t i m e . 13 Q . W h a t w a s y o u r o l d e m a i l 14 a c c o u n t ? 15 A . 16 Q . W h e n d i d y o u s t o p u s i n g t h a t 17 e m a i l a c c o u n t ? 18 A . A g u e s s a y e a r o r a f e w 19 m o n t h s a f t e r . I c a n ' t r e c a l l w h e n I 20 s t o p p e d u s i n g i t . 21 Q . D o y o u s e e o n t h e f i r s t p a g e 22 w h e r e i t s a y s R A N S O M E 0 0 4 , t h e r e a r e 23 t w o e m a i l s i n t h e c h a i n w h i c h a r e 24 v i s i b l e ? 25 A . T h a t ' s c o r r e c t . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 379 of 469 Highly Confidential Page 379 1 HIGHLY CONFIDENTIAL AEO 2 Q. And did you produce the 3 other emails between those two that 4 are not visible? 5 A. Yes. 6 Q. When did you do that? 7 A. The same time I provided all 8 the emails originally. 9 Q. Okay. So you believed that 10 y o u p r o d u c e d s i x e m a i l s o f 11 c o n v e r s a t i o n b e t w e e n y o u r s e l f a n d 12 N a t a l y a M a l y s h e v ? 13 M R . G U I R G U I S : I ' m g o i n g t o 14 o b j e c t a n d j u s t a s k f o r 15 c l a r i f i c a t i o n . 16 I ' m n o t t r y i n g t o g i v e y o u a 17 h a r d t i m e o n t h i s o n e . W h e n y o u 18 s a y p r o d u c e d , y o u ' r e a s k i n g t h e 19 w i t n e s s i f s h e p r o v i d e d i t t o h e r 20 a t t o r n e y s , r i g h t ? B e c a u s e 21 o b v i o u s l y t h e a t t o r n e y s p r o d u c e d 22 t h e d o c u m e n t s i n t h i s c a s e . 23 M S . M E N N I N G E R : C o r r e c t . 24 M R . G U I R G U I S : S o j u s t - - 25 s h e d i d n ' t p r o d u c e a n y t h i n g , MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 380 of 469 Highly Confidential Page 380 1 HIGHLY CONFIDENTIAL AEO 2 obviously. 3 So she's asking you did you 4 collect this email and give it to 5 the lawyers, I guess is the 6 question. 7 A. Yeah, I collected all -- 8 all -- everything I had, I gave to my 9 lawyers. 10 Q . O k a y . S o y o u b e l i e v e y o u 11 g a v e s i x e m a i l s b e t w e e n y o u r s e l f a n d 12 N a t a l y a M a l y s h e v t o y o u r a t t o r n e y s ? 13 A . Y e s , I g a v e a l l m y e v i d e n c e . 14 Q . O k a y . A n d - - 15 M R . G U I R G U I S : I ' m g o i n g t o 16 o b j e c t t o t h a t l a s t q u e s t i o n a l s o 17 a s m i s r e p r e s e n t i n g t h e t e s t i m o n y . 18 M S . M E N N I N G E R : W h a t w a s 19 m i s r e p r e s e n t i n g w h a t t e s t i m o n y ? 20 M R . G U I R G U I S : Y o u ' r e s a y i n g 21 t h a t s h e g a v e s i x e m a i l s . 22 M S . M E N N I N G E R : W e l l , l e t ' s 23 g o b a c k , t h e n , a n d g e t t h e 24 t e s t i m o n y r i g h t . 25 Q . O n R A N S O M E 0 0 4 , h o w m a n y MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 381 of 469 Highly Confidential Page 381 1 HIGHLY CONFIDENTIAL AEO 2 emails between yourself and Natalya 3 Malyshev do you see total? 4 There's one at 1:04 a.m., 5 correct? 6 MR. GUIRGUIS: Counsel, 7 you're doing the exact thing that 8 I just tried to avoid confusion 9 on, right? 10 T h e r e ' s a d i f f e r e n c e b e t w e e n 11 w h a t w a s p r o d u c e d t o y o u - - a n d 12 a p p a r e n t l y a n d y o u ' r e s a y i n g t h a t 13 s i x e m a i l s w e r e p r o d u c e d t o 14 y o u - - 15 M S . M E N N I N G E R : N o , I w a s 16 n o t s a y i n g t h a t . 17 M R . G U I R G U I S : - - w h i c h 18 s h e ' s p r o v i d i n g t o h e r c o u n s e l . 19 M S . M E N N I N G E R : N o , I ' m n o t 20 s a y i n g t h a t . S o I ' m t r y i n g t o 21 g e t i t s t r a i g h t n o w . 22 Q . T h e r e ' s a n e m a i l i n d i c a t e d 23 o n t h e f i r s t p a g e f r o m N a t a l y t o y o u 24 a t 1 : 0 4 a . m . o n F e b r u a r y 3 r d , 2 0 0 7 , 25 c o r r e c t ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 382 of 469 Highly Confidential Page 382 1 HIGHLY CONFIDENTIAL AEO 2 A. Mm-hmm. Yes. 3 Q. And you can read the text of 4 that email, correct? 5 A. Yes, I can. 6 Q. And the next email down says 7 "Sarah Ransome" at 4:07 -- at 4:01 8 p.m. 9 A. Mm-hmm. 10 Q . C a n y o u r e a d t h a t e m a i l ? 11 A . N o , b e c a u s e i t ' s o n Y a h o o . 12 I t ' s a t e c h n o l o g i c a l t h i n g . Y o u c a n ' t 13 r e a d a l l e m a i l s . 14 Q . S o d i d y o u p r o d u c e t h e 15 F e b r u a r y ' 0 4 , ' 0 7 , 4 : 0 1 p . m . e m a i l 16 f r o m y o u r s e l f t o N a t a l y M a l y s h e v t o 17 y o u r a t t o r n e y s ? 18 M R . G U I R G U I S : O b j e c t i o n t o 19 t h e u s e o f t h e w o r d p r o d u c e . 20 A . I ' v e g i v e n a l l m y e m a i l 21 c o r r e s p o n d e n c e t o m y l a w y e r s . 22 Q . D i d y o u g i v e t h a t e m a i l t o 23 y o u r l a w y e r ? 24 A . I ' v e g i v e n a l l m y e m a i l s t o 25 m y l a w y e r s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 383 of 469 Highly Confidential Page 383 1 HIGHLY CONFIDENTIAL AEO 2 Q. Okay. The next email down 3 says "Sarah Ransome, February 5, 2007, 4 at 10:09 p.m." 5 Can you read the text of 6 that email on this document? 7 A. Mm-hmm. 8 Q. What does the 10:09 p.m. 9 email say? 10 A . A s I ' v e s p e c i f i e d b e f o r e , 11 t h i s i s a s c r e e n s h o t , o k a y , o f t h e 12 a c t u a l Y a h o o e m a i l . T h i s i s a 13 s c r e e n s h o t . S o t e c h n i c a l l y I c a n ' t 14 r e a d t h a t a n y w a y s , s e e i n g a s i t ' s a 15 s c r e e n s h o t . 16 Q . O k a y . 17 A . T h i s i s n ' t a c o m p u t e r . I 18 c a n ' t t a p i n t o t h a t e m a i l o n a p a g e 19 b e c a u s e i t ' s a s c r e e n s h o t . 20 Q . D i d y o u g i v e a F e b r u a r y 6 t h , 21 ' 0 7 , 2 : 0 0 a . m . e m a i l b e t w e e n y o u r s e l f 22 a n d N a t a l y M a l y s h e v t o y o u r a t t o r n e y s ? 23 A . I h a v e h a n d e d a l l o v e r m y 24 e v i d e n c e t o m y a t t o r n e y s . 25 Q . D i d y o u g i v e a F e b r u a r y 8 , MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 384 of 469 Highly Confidential Page 384 1 HIGHLY CONFIDENTIAL AEO 2 2007, 9:12 p.m. email from yourself to 3 Nataly Malyshev to your attorneys? 4 A. I have given all my evidence 5 to my attorneys. 6 MS. MENNINGER: I'm going to 7 show you Defendant's Exhibit 10. 8 (Defendant's Exhibit 10, 9 Bates stamped RANSOME_000006, was 10 m a r k e d f o r i d e n t i f i c a t i o n . ) 11 Q . D o y o u r e c o g n i z e D e f e n d a n t ' s 12 E x h i b i t 1 0 ? 13 A . Y e s . 14 Q . W h a t i s i t ? 15 A . I t ' s a n e m a i l c o r r e s p o n d e n c e 16 b e t w e e n L e s l e y G r o f f a n d m y s e l f . 17 Q . O n t h e s e c o n d p a g e , R A N S O M E 18 0 0 0 8 , d o y o u s e e o t h e r e m a i l s w i t h 19 h e a d i n g s b u t n o t e x t v i s i b l e i n t h e 20 s c r e e n s h o t ? 21 A . M m - h m m . 22 Q . D i d y o u g i v e e a c h o n e o f 23 t h o s e e m a i l s t o y o u r a t t o r n e y s ? 24 A . I h a v e g i v e n a l l m y 25 c o r r e s p o n d e n c e t o m y a t t o r n e y s . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 385 of 469 Highly Confidential Page 385 1 HIGHLY CONFIDENTIAL AEO 2 Q. Do you see in the "Smart 3 View" column on the left side a folder 4 named "Pumla Griszell"? 5 A. Yes, I do. 6 Q. Does that folder contain 7 your correspondence with Pumla 8 Griszell? 9 A. I didn't even know that 10 f o l d e r w a s t h e r e , b u t I p r e s u m e s o , 11 w h i c h i s w h y I w o u l d h a v e c r e a t e d i t 12 i n t h e f i r s t p l a c e . 13 Q . A n d i t a l s o s h o w s a 14 s u b s t a n t i a l n u m b e r o f d o c u m e n t s i n 15 y o u r I n b o x . 16 A . Y e s . 17 Q . D i d y o u s e a r c h y o u r I n b o x 18 f o r d o c u m e n t s r e s p o n s i v e t o t h e 19 s u b p o e n a t h a t I s h o w e d y o u a l i t t l e 20 w h i l e a g o ? 21 A . I d i d . I w a n t e d t o b e 22 t h o r o u g h w i t h m y r e s e a r c h , s o I , 23 d u r i n g t h a t t i m e f r a m e , w e n t t h r o u g h 24 e v e r y s i n g l e e m a i l . 25 Q . Y o u w e n t t h r o u g h e a c h o n e ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 386 of 469 Highly Confidential Page 386 1 HIGHLY CONFIDENTIAL AEO 2 A. I went through all of my 3 emails to make sure I gave all my 4 evidence to my lawyers. 5 Q. Did you search for keywords 6 or did you just read each email? 7 A. I read each email. 8 Q. And did you print out each 9 email? 10 A . I d i d n ' t p r i n t o u t . I s a v e d 11 t h e m t o a U S B s t i c k . 12 Q . A l l o f t h e m o r j u s t t h e o n e s 13 t h a t y o u t h o u g h t w e r e n e e d e d ? 14 A . J u s t t h e o n e s t h a t w e r e 15 f o r - - j u s t a n y t h i n g r e l a t e d t o 16 J e f f r e y , I s e n t o v e r . 17 Q . A n d I t h i n k y o u t e s t i f i e d 18 e a r l i e r y o u b e l i e v e y o u s t i l l h a v e 19 y o u r F I T a p p l i c a t i o n i n a n e m a i l ? 20 A . I h a v e n ' t r e a d i t . I ' m 21 a s s u m i n g I h a v e i t . 22 M S . M E N N I N G E R : I w a n t t o 23 s h o w y o u D e f e n d a n t ' s E x h i b i t 1 1 . 24 ( D e f e n d a n t ' s E x h i b i t 1 1 , 25 M a u r e e n C a l l a h a n a r t i c l e , w a s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 387 of 469 Highly Confidential Page 387 1 HIGHLY CONFIDENTIAL AEO 2 marked for identification.) 3 A. Oh, it's 9th of October, 4 sorry. 5 Q. Do you recognize this 6 document? 7 A. Let me go to the last 8 sentence. That catchphrase that I 9 mentioned earlier, as I said earlier, 10 I c o u l d n ' t r e m e m b e r t h e c o n t e n t s o f 11 t h e a r t i c l e e a r l i e r . I d o a p o l o g i z e , 12 I g o t t h e d a t e w r o n g f r o m t h e 1 6 t h . 13 I t w a s a c t u a l l y t h e 9 t h o f O c t o b e r . I 14 c o u l d n ' t r e m e m b e r t h e s p e c i f i c d a t e . 15 I r e m e m b e r t h e s p e c i f i c 16 s t a t e m e n t t h a t r e a l l y s t r u c k a c h o r d 17 w i t h m e , w h i c h w a s , " T h e t r u e n u m b e r 18 o f E p s t e i n ' s v i c t i m s w i l l n e v e r b e 19 k n o w n . " 20 Q . S o y o u b e l i e v e t h i s i s t h e 21 d o c u m e n t b y M a u r e e n C a l l a h a n t h a t y o u 22 r e a d l a s t O c t o b e r t h a t c a u s e d y o u t o 23 c o m e f o r w a r d ? 24 A . I ' m p r e s u m i n g s o , b e c a u s e 25 I ' v e g o n e s t r a i g h t t o t h e b a n k , a n d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 388 of 469 Highly Confidential Page 388 1 HIGHLY CONFIDENTIAL AEO 2 the sentence that I told you that I 3 remembered is this. So I'm assuming, 4 yes, that it's the same. 5 Q. And this article had a big 6 impact on you because it caused you to 7 come forward, I think you testified 8 earlier; is that correct? 9 A. That's correct. 10 Q . A l l r i g h t . D o y o u a l s o s e e 11 o n t h a t l a s t p a g e , j u s t r i g h t w h e r e 12 y o u w e r e , t h e r e ' s a l i t t l e b o x o n t h e 13 l e f t h a n d s i d e . C a n y o u r e a d t h a t o u t 14 l o u d , b e g i n n i n g " T o d a y J e f f r e y 15 E p s t e i n . . . " 16 D o y o u s e e t h a t i n b o l d 17 l e t t e r s o n t h a t l a s t p a g e ? 18 A . O h . 19 Q . C a n y o u j u s t r e a d t h a t 20 s e n t e n c e t o u s ? 21 A . " T o d a y J e f f r e y E p s t e i n i s a 22 f r e e m a n , a l b e i t o n e w h o r o u t i n e l y h a s 23 c i v i l l a w s u i t s b r o u g h t a g a i n s t h i m b y 24 y o u n g w o m e n o u t o f c o u r t . " 25 M S . M E N N I N G E R : O k a y . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 389 of 469 Highly Confidential Page 389 1 HIGHLY CONFIDENTIAL AEO 2 Defendant's Exhibit 12. 3 (Defendant's Exhibit 12, 4 website printout titled How to 5 Apply, was marked for 6 identification.) 7 Q. Do you recognize this 8 document? 9 A. I've seen it before, yes. 10 Q . A n d w h a t d o y o u r e c o g n i z e i t 11 b e ? 12 A . I t ' s t h e a p p l i c a t i o n h o w y o u 13 a p p l y t o F I T . 14 Q . I t t a l k s a b o u t s t u d e n t s 15 a p p l y i n g t o d i f f e r e n t p a r t s o f t h e 16 s c h o o l , i n c l u d i n g a r t s a n d d e s i g n o r 17 b u s i n e s s a n d t e c h n o l o g y . 18 D o y o u r e c a l l i f y o u w e r e 19 a p p l y i n g t o a p a r t i c u l a r a r e a a t F I T 20 o r a g e n e r a l a d m i s s i o n ? 21 A . I w a n t e d t o s p e c i a l i z e i n 22 f a s h i o n d e s i g n i n g . 23 Q . D o y o u k n o w i f t h a t w a s a 24 s p e c i a l a r e a ? 25 A . Y e s , i t w a s . F I T ' s t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 390 of 469 Highly Confidential Page 390 1 HIGHLY CONFIDENTIAL AEO 2 financial -- fashion school, so yeah. 3 Q. Did you visit the building 4 where FIT is located? 5 A. Yes, I did. 6 Q. Did you attend classes 7 there? 8 A. No. 9 Q. I mean did you visit a 10 c l a s s . I k n o w y o u d i d n ' t e n r o l l , b u t 11 d i d y o u v i s i t a c l a s s ? 12 A . N o , I d i d n ' t . B u t I w e n t t o 13 t h e u n i v e r s i t y , h a d a l o o k a r o u n d . 14 Q . D i d y o u t a k e a t o u r ? 15 A . N o t p e r s e . I m e a n , I w e n t 16 a r o u n d , I l o o k e d a t t h e u n i v e r s i t y . I 17 d i d n ' t g o o n a b i g p e r s o n a l i z e d t o u r 18 w i t h a s p e c i f i c p e r s o n , n o . 19 Q . D i d y o u t a l k t o a n y o f t h e 20 t e a c h e r s t h e r e ? 21 A . N o , I d i d n ' t . 22 Q . D o y o u r e c a l l t h e r e b e i n g 23 m u l t i p l e s t e p s f o r a p p l i c a t i o n s t o 24 F I T ? 25 A . T h e r e ' s m u l t i p l e s t e p s o n MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 391 of 469 Highly Confidential Page 391 1 HIGHLY CONFIDENTIAL AEO 2 any college application form. 3 Q. Do you remember what those 4 steps were when you were applying? 5 A. No. 6 Q. Do you remember an original 7 application which had details? 8 A. I can't remember the 9 original application form, no. 10 Q . D o y o u r e m e m b e r t h e r e b e i n g 11 a s e p a r a t e e s s a y p o r t i o n ? 12 A . Y e s , I d o r e m e m b e r t h a t . 13 Q . D o y o u r e m e m b e r a s e p a r a t e 14 p o r t i o n t h a t r e l a t e s t o s t u d e n t s w h o 15 a r e a p p l y i n g w h o a r e n o t U . S . 16 c i t i z e n s ? 17 A . I c a n ' t r e m e m b e r t h a t . I 18 c a n ' t r e m e m b e r t h e s p e c i f i c f o r m . 19 Q . D o y o u r e m e m b e r f i l l i n g o u t 20 a n y s p e c i a l p a p e r w o r k f o r s o m e o n e w h o 21 w a s a p p l y i n g w h o w a s n o t a U . S . 22 c i t i z e n ? 23 A . N o , t h e r e w a s n o p a p e r w o r k 24 a s s u c h f o r t h a t . J e f f r e y E p s t e i n w a s 25 s o r t i n g t h a t o u t f o r m e w i t h h i s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 392 of 469 Highly Confidential Page 392 1 HIGHLY CONFIDENTIAL AEO 2 connections at FIT. 3 Q. So you don't believe you 4 filled that part out? 5 MR. GUIRGUIS: Objection. 6 A. I said I can't remember 7 filling that part out. 8 Q. Do you remember getting a 9 copy of your transcript from Queen 10 M a r g a r e t U n i v e r s i t y ? 11 A . I h a v e n ' t g o t m y t r a n s c r i p t s 12 y e t , b u t I c a n g e t t h e m . 13 Q . D o y o u r e m e m b e r s u b m i t t i n g 14 t h e m t o F I T ? 15 A . I c a n ' t r e m e m b e r . 16 Q . D i d y o u g e t a d e g r e e f r o m a 17 s c h o o l i n E d i n b u r g h , h i g h s c h o o l ? 18 A . S o I f i n i s h e d a l l m y h i g h 19 s c h o o l q u a l i f i c a t i o n , w h i c h , y o u k n o w , 20 m y g r a d e s w e r e g o o d e n o u g h t o g e t i n t o 21 p s y c h o l o g y a n d s o c i o l o g y i n E d i n b u r g h . 22 Q . W h a t w a s t h e n a m e o f y o u r 23 h i g h s c h o o l ? 24 A . G r a n t o w n G r a m m a r S c h o o l . 25 Q . D i d y o u g e t a t r a n s c r i p t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 393 of 469 Highly Confidential Page 393 1 HIGHLY CONFIDENTIAL AEO 2 from that school to provide to FIT? 3 A. I think I was in the process 4 of getting my transcripts from Queen 5 Margaret. I did have a copy of my 6 high school grades as well. When you 7 fill out an application, you submit 8 all your grades, high school. 9 Q. And that's the one in 10 S c o t l a n d ? 11 A . Y e s , t h a t ' s c o r r e c t . 12 M S . M E N N I N G E R : I t h i n k I ' v e 13 o n l y g o t a c o u p l e m o r e q u e s t i o n s , 14 b u t I g o t m y p i l e s m e s s e d u p . 15 C a n w e t a k e a t w o - m i n u t e b r e a k 16 a n d I c a n g e t o r g a n i z e d a n d 17 f i n i s h e d . 18 ( T i m e n o t e d : 5 : 5 4 p . m . ) 19 ( R e c e s s . ) 20 ( T i m e n o t e d : 6 : 0 7 p . m . ) 21 M S . M E N N I N G E R : I ' m g o i n g t o 22 m a r k a n e w e x h i b i t D e f e n d a n t ' s 23 E x h i b i t 1 3 . 24 ( D e f e n d a n t ' s E x h i b i t 1 3 , 25 B a t e s s t a m p e d R A N S O M E _ 0 0 0 0 0 7 w a s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 394 of 469 Highly Confidential Page 394 1 HIGHLY CONFIDENTIAL AEO 2 marked for identification.) 3 Q. Do you recognize this 4 document? 5 A. Yes, I do. 6 Q. What is it? 7 A. It was an email sent to my 8 friend Pam. 9 Q. Is that different than Pam 10 t h a t y o u w e r e w i t h o n t h e i s l a n d ? 11 A . I w a s n e v e r w i t h P a m o n t h e 12 i s l a n d . I t w a s . 13 Q . D o y o u r e m e m b e r t e s t i f y i n g 14 a b o u t s o m e o n e n a m e d P a m ? 15 A . P a m w a s m y f r i e n d i n N e w 16 Y o r k . 17 Q . I s t h a t t h e s a m e p e r s o n y o u 18 w e r e w r i t i n g h e r e , o r i s t h a t a 19 d i f f e r e n t p e r s o n ? 20 A . I t ' s t h e s a m e p e r s o n ; i t ' s 21 j u s t I c a l l e d h e r P a m . I t ' s a S o u t h 22 A f r i c a n n a m e . S h e ' s S o u t h A f r i c a n . 23 Q . H o w d i d y o u k n o w P a m ? 24 A . I m e t h e r i n N e w Y o r k . 25 Q . D o y o u k n o w w h e t h e r y o u p a i d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 395 of 469 Highly Confidential Page 395 1 HIGHLY CONFIDENTIAL AEO 2 for your plane ticket to come back to 3 New York from South Africa in February 4 of '07? 5 A. I didn't pay for my ticket. 6 Q. You did not? 7 A. No. 8 Q. Do you see in your email 9 exchange in Defendant's Exhibit 13 10 t h a t y o u w r o t e t o P a m o n F e b r u a r y 8 t h 11 o f ' 0 7 , " N o t g o i n g t o M i a m i a n y m o r e , 12 c l e a r l y , a n d h a v e t o p a y f o r m e f l i g h t 13 b a c k . " 14 I t ' s i n t h e s e c o n d p a r a g r a p h 15 t o w a r d s t h e b o t t o m . 16 A . M m - h m m . 17 Q . D i d y o u w r i t e t h a t ? 18 A . Y e s . 19 Q . B u t y o u d i d n o t , i n f a c t , 20 p a y f o r y o u r f l i g h t b a c k ? 21 A . N o . 22 Q . D o y o u k n o w w h a t y o u m e a n t 23 b y " N o t g o i n g t o M i a m i a n y m o r e , 24 c l e a r l y . . . " ? 25 A . I c a n ' t r e m e m b e r w h a t t h a t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 396 of 469 Highly Confidential Page 396 1 HIGHLY CONFIDENTIAL AEO 2 whole Miami thing was about. It never 3 came about, so I can't remember the 4 specific details on Miami. But it was 5 via Jeffrey Epstein. 6 Q. Okay. How did it happen 7 that you were writing, "I'm going to 8 have to pay for me flight back," but 9 you did not, in fact, pay for your 10 f l i g h t b a c k ? 11 A . B e c a u s e J e f f r e y E p s t e i n a n d 12 I h a d a f i g h t a b o u t m y w e i g h t . S o 13 t h a t w a s p r o b a b l y d u r i n g t h e a r g u m e n t , 14 t h e t i m e f r a m e t h a t I h a d t h e a r g u m e n t 15 w i t h J e f f r e y . H e s a i d t h a t h e r e f u s e d 16 t o p a y f o r m y f l i g h t b a c k i f I d i d n ' t 17 g e t d o w n t o 5 2 k i l o g r a m s . 18 Q . A n d h o w d i d i t c o m e a b o u t 19 t h a t y o u d i d n o t p a y f o r y o u r f l i g h t 20 b a c k ? 21 A . I c a r r i e d o n l o s i n g w e i g h t 22 t o t r y a n d g e t t o t h e g o a l t h a t 23 J e f f r e y a n d G h i s l a i n e h a d s e t f o r m e , 24 w h i c h i s 5 2 k i l o g r a m s . 25 Q . H o w d o e s t h a t r e l a t e t o MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 397 of 469 Highly Confidential Page 397 1 HIGHLY CONFIDENTIAL AEO 2 payment for a flight? 3 MR. GUIRGUIS: Objection. 4 A. Well, I didn't pay for that 5 flight because Jeffrey was financing 6 me, so I wouldn't have had the money 7 to pay for my own flight back. 8 Q. But you said you were "going 9 to have to pay for my flight back," 10 r i g h t ? 11 A . T h a t ' s c o r r e c t . 12 Q . A n d t h e n w h a t c h a n g e d ? 13 M R . G U I R G U I S : O b j e c t i o n , 14 a s k e d a n d a n s w e r e d . 15 A . I m a d e u p w i t h J e f f r e y . I 16 t r i e d t o m e e t m y t a r g e t w e i g h t o f 17 5 2 k i l o g r a m s . 18 Q . A n d h o w d i d y o u m a k e u p w i t h 19 h i m ? 20 A . I c a n ' t r e m e m b e r i f i t w a s 21 t e l e p h o n e c a l l o r e m a i l o r m e s s a g e , 22 b u t t h e r e w e r e v a r i o u s p h o n e c a l l s 23 t h a t w e r e m a d e t o m y f a m i l y h o m e f r o m 24 G h i s l a i n e a n d J e f f r e y d u r i n g t h a t t i m e 25 f r a m e . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 398 of 469 Highly Confidential Page 398 1 HIGHLY CONFIDENTIAL AEO 2 It was a very delicate time 3 because my family were up in arms the 4 fact I was told to be 52 kilograms, 5 which is not -- it can't be achievable 6 with my body frame, and they saw me 7 getting very ill. 8 And I didn't have the funds 9 to buy a flight back, so I had to do 10 w h a t G h i s l a i n e a n d J e f f r e y t o l d m e d o . 11 Q . W h a t d i d y o u d o ? 12 A . C o n t i n u e t o l o s e w e i g h t . 13 Q . D i d y o u s e e a n y m e d i c a l 14 p r o f e s s i o n a l s w h i l e y o u w e r e i n S o u t h 15 A f r i c a ? 16 A . N o . 17 Q . H o w d i d y o u c o m m u n i c a t e t o 18 J e f f r e y t h a t y o u h a d d e c i d e d t o 19 c o n t i n u e l o s i n g w e i g h t ? 20 A . S o J e f f r e y , G h i s l a i n e , 21 a g a i n , w e a l l c o r r e s p o n d e d b y 22 t e l e p h o n i c c a l l , B B M , m e s s a g e , m y 23 h o u s e p h o n e . I d e c i d e d t o l o s e 24 w e i g h t . I w a s g i v e n a n u l t i m a t u m t h a t 25 e i t h e r I d o i t o r I ' m f i n i s h e d . A t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 399 of 469 Highly Confidential Page 399 1 HIGHLY CONFIDENTIAL AEO 2 that point I had no option. 3 Q. If you wanted the flight 4 back. 5 A. If I wanted the flight back. 6 I had all my stuff in New York, I had 7 my life in New York, I was going to 8 FIT. 9 I didn't have any finances; 10 J e f f r e y w a s f u n d i n g m e . S o I w a s 11 s t u c k . I e i t h e r h a d t o d o w h a t 12 G h i s l a i n e a n d J e f f r e y t o l d m e d o o r I 13 w a s s t u c k , r e a l l y . 14 Q . Y o u w e r e s t u c k a t y o u r 15 f a t h e r a n d s t e p m o t h e r ' s h o u s e i n S o u t h 16 A f r i c a , w h e r e y o u g r e w u p ? 17 A . I d i d n ' t g r o w u p w i t h m y 18 f a t h e r a n d m y s t e p m o t h e r . 19 Q . Y o u g r e w u p i n S o u t h A f r i c a ? 20 A . I g r e w u p i n J o h a n n e s b u r g . 21 Q . W h e n y o u s a y y o u w e r e s t u c k , 22 y o u ' r e d e s c r i b i n g a t i m e y o u w e r e i n 23 S o u t h A f r i c a ? 24 A . I ' m d e s c r i b i n g a t i m e I w a s 25 o n h o l i d a y v i s i t i n g m y f a m i l y , t h a t MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 400 of 469 Highly Confidential Page 400 1 HIGHLY CONFIDENTIAL AEO 2 Jeffrey paid for. 3 Q. Okay. Did you finish your 4 answer? 5 A. Sorry, I just read here. 6 I'm describing a time that I was on 7 holiday visiting my family, that was 8 paid for by Jeffrey and Ghislaine. 9 They financed my ticket. They 10 f i n a n c e d e v e r y t i c k e t . T h e y f i n a n c e d 11 m y w h o l e l i f e s t y l e . 12 Q . G h i s l a i n e f i n a n c e d y o u r 13 t i c k e t ? 14 A . W e l l , t h e y w e r e o n e e n t i t y . 15 G h i s l a i n e i s J e f f r e y ' s r i g h t - h a n d 16 w o m a n . T h e y - - 17 Q . W h e n d i d G h i s l a i n e f i n a n c e 18 t h i s t i c k e t ? 19 A . I t w a s t h r o u g h J e f f r e y ' s 20 c o m p a n y t h a t s h e w o r k e d w i t h . 21 Q . D i d y o u c o r r e s p o n d b y e m a i l 22 w i t h G h i s l a i n e a b o u t f i n a n c i n g t h i s 23 t i c k e t ? 24 A . N o . 25 Q . Y o u s e a r c h e d f o r e m a i l s w i t h MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 401 of 469 Highly Confidential Page 401 1 HIGHLY CONFIDENTIAL AEO 2 yourself and Ghislaine, correct? 3 A. That's correct. 4 Q. And you found none, correct? 5 A. That's correct. 6 Q. You found emails between 7 yourself and Lesley Groff about the 8 plane ticket back, correct? 9 A. That's correct. 10 Q . B u t n o n e w i t h G h i s l a i n e ? 11 A . I n e v e r s a i d o n c e t o d a y t h a t 12 I h a d e m a i l c o m m u n i c a t i o n w i t h 13 G h i s l a i n e . 14 Q . B u t y o u j u s t s a i d t h a t 15 G h i s l a i n e f i n a n c e d y o u r h o l i d a y i n 16 S o u t h A f r i c a . A n d w h a t i s y o u r b a s i s 17 f o r s a y i n g t h a t ? 18 M R . G U I R G U I S : O b j e c t i o n . 19 S h e d i d n o t s a y t h a t G h i s l a i n e 20 f i n a n c e d i t . 21 Q . W h a t i s y o u r b a s i s f o r 22 r e f e r r i n g t o G h i s l a i n e f i n a n c i n g y o u r 23 h o l i d a y i n S o u t h A f r i c a ? 24 M R . G U I R G U I S : O b j e c t i o n . 25 A . S o G h i s l a i n e i s J e f f r e y ' s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 402 of 469 Highly Confidential Page 402 1 HIGHLY CONFIDENTIAL AEO 2 right-hand man, so she -- so we report 3 to her. I told them I wanted to go 4 and see my family. They paid for my 5 flight. 6 Q. You told them when they were 7 together in the same place? 8 A. I can't remember the 9 specific location. I just wanted to 10 g o o n h o l i d a y t o s e e m y f a m i l y , w h i c h 11 G h i s l a i n e a n d J e f f r e y p a i d f o r . 12 Q . H o w d i d G h i s l a i n e p a y f o r 13 i t ? 14 A . I d o n ' t k n o w . Y o u s h o u l d 15 a s k G h i s l a i n e . 16 Q . D i d s h e w r i t e a c h e c k ? 17 A . Y o u s h o u l d a s k G h i s l a i n e . 18 Q . D i d s h e p u t i t o n a c r e d i t 19 c a r d ? 20 M R . G U I R G U I S : O b j e c t i o n . 21 A . Y o u s h o u l d a s k G h i s l a i n e . 22 Q . D o y o u h a v e a n y i d e a h o w 23 G h i s l a i n e M a x w e l l p a i d f o r y o u r t r i p 24 t o S o u t h A f r i c a ? 25 M R . G U I R G U I S : O b j e c t i o n . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 403 of 469 Highly Confidential Page 403 1 HIGHLY CONFIDENTIAL AEO 2 A. You should ask Ghislaine. 3 Q. Is that an answer? 4 MR. GUIRGUIS: Objection. 5 Q. Do you have an answer? 6 MR. GUIRGUIS: Objection. 7 A. You should ask Ghislaine how 8 she funded my ticket. 9 Q. I appreciate the tip. 10 D o y o u h a v e a n y i n f o r m a t i o n 11 i n s i d e o f y o u r h e a d a b o u t h o w 12 G h i s l a i n e f i n a n c e d y o u r t r i p t o S o u t h 13 A f r i c a ? 14 M R . G U I R G U I S : C o u n s e l , s h e 15 h a s r e p e a t e d l y s t a t e d t h a t s h e 16 d o e s n o t k n o w . Y o u k e e p a s k i n g 17 h e r t h e s a m e q u e s t i o n . 18 M S . M E N N I N G E R : N o , s h e h a s 19 r e p e a t e d t o h e m e t h a t s h e 20 n e e d e d - - I n e e d e d t o a s k m y 21 c l i e n t . 22 M R . G U I R G U I S : H o l d o n . 23 " Q U E S T I O N : G h i s l a i n e f u n d e d 24 y o u r t i c k e t ? 25 " A N S W E R : W e l l , s h e w a s h i s MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 404 of 469 Highly Confidential Page 404 1 HIGHLY CONFIDENTIAL AEO 2 right-hand... 3 "QUESTION: When did 4 Ghislaine finance this ticket? 5 "ANSWER: Well, it was 6 through Jeffrey's company that 7 she worked with." 8 Are you asking a different 9 question, Counsel? Am I 10 m i s u n d e r s t a n d i n g ? 11 M S . M E N N I N G E R : Y e a h , y o u 12 a r e . 13 M R . G U I R G U I S : P l e a s e . 14 M S . M E N N I N G E R : C a n y o u r e a d 15 t h e q u e s t i o n t h a t I a s k e d . 16 ( R e q u e s t e d p o r t i o n o f t h e 17 r e c o r d w a s r e a d b a c k . ) 18 A . I n m y h e a d , I c a n ' t r e m e m b e r 19 h o w s h e f i n a n c e d , h o w s h e a n d J e f f r e y 20 f i n a n c e d . 21 Q . D i d y o u s e e a n y i n v o i c e p a i d 22 b y G h i s l a i n e f o r y o u r t i c k e t ? 23 A . N o . B u t a t i c k e t w a s 24 p r o d u c e d w h i c h e n a b l e d m e t o f l y b a c k 25 t o m y f a m i l y , s o a t i c k e t w a s p r o d u c e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 405 of 469 Highly Confidential Page 405 1 HIGHLY CONFIDENTIAL AEO 2 by Ghislaine and Jeffrey in order for 3 me to fly home to see my family. 4 Q. How did Ghislaine produce a 5 ticket to you? 6 A. I can't remember. 7 Q. Did it come by email? 8 MR. GUIRGUIS: Objection. 9 A. I've provided all the emails 10 t h a t I h a v e . 11 Q . T h a t ' s n o t t h e q u e s t i o n . 12 D i d t h e t i c k e t g e t p r o d u c e d 13 t o y o u b y G h i s l a i n e b y e m a i l ? 14 M R . G U I R G U I S : O b j e c t i o n . 15 A . N o . 16 Q . D i d i t g e t s e n t b y a c o u r i e r 17 t o y o u f r o m G h i s l a i n e ? 18 M R . G U I R G U I S : O b j e c t i o n . 19 A . I c a n ' t r e m e m b e r h o w I 20 r e c e i v e d t h e t i c k e t s p e c i f i c a l l y . 21 Q . Y o u r f i n a l l i n e t o P a m i s , 22 " Y o u m u s t s a v e s o m e p a r t y i n g e n e r g y 23 f o r m e w h e n I c o m e b a c k . L o t s o f 24 l o v e , S a r a h . " 25 C o r r e c t ? MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 406 of 469 Highly Confidential Page 406 1 HIGHLY CONFIDENTIAL AEO 2 A. Mm-hmm. 3 Q. Is that right? 4 A. Mm-hmm. 5 Q. In the first paragraph, do 6 you advise Sarah, "Still very loved 7 up, so much so that he asked me to 8 move in with him and I accepted. All 9 good," exclamation point, exclamation 10 p o i n t , e x c l a m a t i o n p o i n t - - w e l l , 11 a b o u t e i g h t o f t h e m , o r t e n . 12 A . M m - h m m . 13 Q . I s t h a t w h a t y o u w r o t e ? 14 A . Y e s , t h a t ' s w h a t y o u w r o t e . 15 Q . I s t h a t t r u e ? 16 A . Y e s . 17 Q . L o o k i n g b a c k a t D e f e n d a n t ' s 18 E x h i b i t 8 , w h i c h y o u t e s t i f i e d e a r l i e r 19 w e r e y o u r c o m m u n i c a t i o n s w i t h N a t a l y 20 M a l y s h e v , o r s o m e o f t h e m - - 21 A . T h a t ' s E x h i b i t 9 . 22 M R . G U I R G U I S : W e s e e m t o b e 23 m i s s i n g E x h i b i t 8 f r o m t h e s t a c k . 24 M S . M E N N I N G E R : I c h e c k e d i t 25 d u r i n g t h e b r e a k . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 407 of 469 Highly Confidential Page 407 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: It's just out 3 of order. 4 THE WITNESS: Is this 5 Defendant's Exhibit 8? 6 MS. MENNINGER: Eight. 7 THE WITNESS: Is this 8 Exhibit 8? 9 MR. GUIRGUIS: Yes, it is. 10 Q . S o t h e e m a i l s w i t h M a l y s h e v . 11 M a y b e I w r o t e i t d o w n w r o n g . I 12 a p o l o g i z e . 13 M R . G U I R G U I S : W i t h w h o ? 14 I ' m s o r r y ? 15 M S . M E N N I N G E R : N a t a l y - - 16 T H E W I T N E S S : T h a t w a s 17 E x h i b i t - - o h , g o s h . T h i s i s 18 E x h i b i t 9 b e t w e e n N a t a l y a a n d 19 m y s e l f . 20 Q . O k a y . A n d i t ' s g o t R A N S O M E 21 0 0 0 4 a n d 0 0 0 5 ; i s t h a t r i g h t ? J u s t 22 m a k i n g s u r e w e ' r e l o o k i n g a t t h e s a m e 23 t h i n g . O n t h e l o w e r r i g h t - h a n d 24 c o r n e r . 25 A . Y e s , 0 0 0 0 0 4 . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 408 of 469 Highly Confidential Page 408 1 HIGHLY CONFIDENTIAL AEO 2 Q. All right. Those are emails 3 that you and Nataly exchanged in 4 February of 2007, correct? 5 A. That's correct. 6 Q. And can you read to us the 7 email at the bottom from you to Nataly 8 on February 8, 2007. 9 A. "Hey sweetie, how are you? 10 I ' m b u s y w r i t i n g m y e s s a y f o r F I T . 11 W h a t f u n . I h a d a b i t o f a f i g h t w i t h 12 J e f f r e y . O h , w e l l , w h a t c a n y o u d o . 13 I m e a n t t o a s k i n m y l a s t e m a i l c a n 14 y o u p l e a s e e m a i l m e y o u r a d d r e s s . I t 15 l o o k s l i k e I ' m n o t g o i n g t o M i a m i 16 e i t h e r . W e l l , a t l e a s t I w i l l b e b a c k 17 i n N Y . H o p e y o u a r e w e l l a n d l o o k 18 f o r w a r d t o s e e i n g y o u s o o n . P l e a s e 19 t e l l J e n n i f e r I s a y h i . L o t s o f h u g s 20 a n d k i s s e s , S a r a h . " 21 Q . W e r e y o u w r i t i n g y o u r F I T 22 e s s a y i n F e b r u a r y 2 0 0 7 w h i l e y o u w e r e 23 i n S o u t h A f r i c a ? 24 A . Y e a h . I t t o o k m e q u i t e s o m e 25 t i m e w r i t i n g m y e s s a y , s o i t w a s o v e r MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 409 of 469 Highly Confidential Page 409 1 HIGHLY CONFIDENTIAL AEO 2 a duration of... 3 Q. Did you email your essay 4 from South Africa to Ghislaine 5 Maxwell? 6 A. I don't recall emailing her. 7 Q. Defendant's Exhibit 10, I 8 think it is, with Lesley Groff? 9 A. Yes. 10 M R . G U I R G U I S : H o l d o n a 11 s e c o n d . L e t m e j u s t f i n d m y 12 c o p y . 13 Q . A n d I s h o w R A N S O M E 0 0 6 i s 14 t h e f i r s t o n e i n t h e l o w e r r i g h t - h a n d 15 c o r n e r . 16 A . Y e s . 17 Q . S o d i d y o u c o r r e s p o n d w i t h 18 L e s l e y a b o u t f a x i n g y o u r F I T 19 a p p l i c a t i o n i n t o h e r o n o r a b o u t 20 F e b r u a r y 8 , 2 0 0 7 ? 21 A . Y e s . 22 Q . D i d y o u a l s o a s k h e r t o l o o k 23 i n t o b o o k i n g a f l i g h t f o r y o u b a c k t o 24 N e w Y o r k ? 25 A . T h a t ' s c o r r e c t . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 410 of 469 Highly Confidential Page 410 1 HIGHLY CONFIDENTIAL AEO 2 Q. Did you give her the date 3 you wanted to fly back? 4 A. That's correct. 5 Q. And the next email down, did 6 you say, "Hi, can you please phone 7 back?" 8 A. Mm-hmm. 9 Q. Was that to Lesley or to 10 J e f f r e y ? 11 A . I c a n ' t r e m e m b e r w h o i t w a s 12 t o . J e f f r e y n e v e r c o r r e s p o n d e d 13 d i r e c t l y ; h e e i t h e r d i d i t t h r o u g h 14 L e s l e y G r o f f o r - - s o I c a n ' t r e m e m b e r 15 w h o p h o n e d m e b a c k . 16 Q . C a n y o u t u r n t w o p a g e s b a c k 17 t o w h e r e i t s a y s R A N S O M E _ 0 0 0 9 . 18 D o y o u s e e t h o s e e m a i l s ? 19 A . M m - h m m . 20 M R . G U I R G U I S : R e a d t h e 21 e m a i l s , d o n ' t j u s t . . . 22 Q . D i d L e s l e y a s k w h a t t y p e o f 23 v i s a y o u w e r e c o m i n g o n , s t u d e n t o r 24 t o u r i s t ? 25 M R . G U I R G U I S : H o l d o n , MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 411 of 469 Highly Confidential Page 411 1 HIGHLY CONFIDENTIAL AEO 2 Counsel. 3 Are you through with it? 4 THE WITNESS: Sorry, I 5 haven't finished reading yet. 6 Q. Did Lesley ask what type of 7 visa you were coming on, student or 8 tourist? 9 A. That's correct. 10 Q . A n d w h a t w a s y o u r r e s p o n s e ? 11 A . I c a n ' t r e m e m b e r w h a t m y 12 r e s p o n s e w a s . 13 Q . I s i t v i s i b l e i n t h i s 14 e x h i b i t ? 15 A . N o . 16 Q . A l l r i g h t . Y o u s a i d y o u 17 l e f t N e w Y o r k i n l a t e A p r i l - - 18 A . T h a t ' s c o r r e c t . 19 Q . - - 2 0 0 7 ? 20 D i d y o u f i n d a n y r e c o r d s 21 r e f l e c t i n g t h a t d e p a r t u r e w h e n y o u 22 w e r e g o i n g t h r o u g h a l l o f y o u r e m a i l s 23 a n d y o u r o t h e r d o c u m e n t s ? 24 A . N o . 25 Q . W h e n w a s t h e l a s t t i m e y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 412 of 469 Highly Confidential Page 412 1 HIGHLY CONFIDENTIAL AEO 2 saw Jeffrey Epstein? 3 A. April 2007. 4 Q. Where did you see him last? 5 A. In New York. 6 Q. Where in New York? 7 A. I can't remember where I 8 last saw him. 9 Q. Do you remember what 10 h a p p e n e d t h e l a s t t i m e y o u s a w h i m ? 11 A . N o , I c a n ' t r e m e m b e r w h a t 12 h a p p e n e d . 13 Q . D o y o u k n o w w h e t h e r h e g a v e 14 y o u a n y m o n e y t h e l a s t t i m e y o u s a w 15 h i m ? 16 A . N o , h e d i d n ' t g i v e m e m o n e y . 17 Q . D o y o u k n o w i f y o u t a l k e d 18 a b o u t F I T t h e l a s t t i m e y o u s a w h i m ? 19 A . I d i d n ' t r e a l l y w a n t 20 a n y t h i n g d o w i t h J e f f r e y a n d G h i s l a i n e 21 a t t h a t s t a g e . S o a t t h a t p o i n t I d i d 22 n o t t a l k a b o u t F I T a n y m o r e w i t h t h e m . 23 I j u s t w a n t e d t o g o b a c k h o m e t o m y 24 m o m . 25 Q . A n d t h i s i s w h e n y o u w e r e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 413 of 469 Highly Confidential Page 413 1 HIGHLY CONFIDENTIAL AEO 2 living with Adam? 3 A. Yes. 4 Q. When did you decide you 5 didn't want to have anything to do 6 with Jeffrey Epstein? 7 A. After my trip to South 8 Africa, my relationship deteriorated 9 with Jeffrey and Ghislaine. So I 10 d i d n ' t r e a l l y w a n t t o b e h e r e a n y m o r e . 11 Q . W h e n d i d y o u m a k e t h a t 12 d e c i s i o n ? 13 A . I w a s k i n d o f t o y i n g w i t h 14 t h e i d e a o f g o i n g b a c k . I w a s i n a 15 b i t o f a m e s s a f t e r w h a t I h a d b e e n 16 t h r o u g h w i t h G h i s l a i n e a n d J e f f r e y , 17 s o - - y e a h . 18 Q . A n d w h o p u r c h a s e d y o u r p l a n e 19 t i c k e t t o L o n d o n ? 20 A . I t h i n k i t w a s m y m o m . I 21 c a n ' t r e m e m b e r . 22 Q . W e r e y o u s t i l l t a k i n g t h e 23 m e d i c a t i o n s a t t h e t i m e y o u w e n t b a c k ? 24 A . Y e s . 25 Q . A n d y o u r e t u r n e d f r o m S o u t h MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 414 of 469 Highly Confidential Page 414 1 HIGHLY CONFIDENTIAL AEO 2 Africa in February 2007, correct? 3 A. That's correct. 4 Q. And that's when you made the 5 decision to break with Jeffrey by 6 moving in with Adam, correct? 7 A. I wanted to distance myself 8 from Jeffrey. Things weren't great. 9 What he was doing was wrong and what 10 h e w a s d o i n g t o m e w a s w r o n g , a n d I 11 g o t p r e t t y d e p r e s s e d a b o u t i t . I w a s 12 i n - - I w a s s t u c k i n a d a r k h a l l w a y . 13 I w a s b a s i c a l l y b e i n g a b u s e d b y a m a n , 14 a n d I - - I d i d n ' t - - I d i d n ' t k n o w 15 w h a t t o d o , w h e r e t o g o . 16 Q . D i d y o u h a v e a b a n k a c c o u n t 17 i n N e w Y o r k ? 18 A . Y e s , I d i d . 19 Q . W i t h w h i c h b a n k ? 20 M R . G U I R G U I S : O b j e c t i o n . 21 S a m e o b j e c t i o n I g a v e a t t h e 22 b e g i n n i n g , f i n a n c i a l i n f o r m a t i o n 23 f o r a n o n p a r t y w i t n e s s . 24 M S . M E N N I N G E R : T h e n a m e o f 25 t h e b a n k . T h e n a m e o f t h e b a n k . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 415 of 469 Highly Confidential Page 415 1 HIGHLY CONFIDENTIAL AEO 2 Q. Let me ask you this: What 3 did you do with the cash you received 4 from Jeffrey Epstein? Did you put it 5 in the bank? 6 A. No. I spent it on food, 7 cabs. General expenses. 8 Q. Where did you get the money 9 that you put into the bank? 10 A . F r o m t h e o c c a s i o n a l m o d e l i n g 11 j o b t h a t I g o t , f r e e l a n c e m o d e l i n g . 12 Q . W e r e y o u s t i l l m o d e l i n g i n 13 t h e s p r i n g o f 2 0 0 7 ? 14 A . N o . 15 M R . G U I R G U I S : O f f t h e 16 r e c o r d . 17 ( A n o f f - t h e - r e c o r d 18 d i s c u s s i o n w a s h e l d . ) 19 M R . G U I R G U I S : B a c k o n t h e 20 r e c o r d . 21 M S . M E N N I N G E R : I t h i n k i f 22 y o u c a n j u s t g i v e m y c o - c o u n s e l 23 a n d I a m i n u t e o f f t h e r e c o r d . 24 ( T i m e n o t e d : 6 : 2 8 p . m . ) 25 ( R e c e s s . ) MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 416 of 469 Highly Confidential Page 416 1 HIGHLY CONFIDENTIAL AEO 2 (Time noted: 6:29 p.m.) 3 Q. In February of 2007, you 4 decided to make a break with Jeffrey 5 Epstein, correct? 6 A. No, I didn't decide to make 7 a break with Jeffrey Epstein. He let 8 me down with my FIT application and he 9 wasn't taking me seriously, and he 10 w a s n ' t f o l l o w i n g t h r o u g h h i s e n d o f 11 t h e d e a l , b a s i c a l l y . 12 Q . H o w d i d h e l e t y o u d o w n w i t h 13 y o u r F I T a p p l i c a t i o n ? 14 A . B e c a u s e I d i d n ' t g o t o F I T . 15 Q . A n d w h y d i d n ' t y o u g o t o 16 F I T ? 17 A . B e c a u s e I w a n t e d t o g o h o m e 18 b a c k t o m y m o m . 19 Q . W h e n d i d y o u d e c i d e t h a t h e 20 l e t y o u d o w n w i t h t h e F I T a p p l i c a t i o n ? 21 A . W e l l , I t h i n k i t w a s p r e t t y 22 m u c h a f t e r t h a t i n c i d e n t w i t h A l a n a n d 23 t h e f a c t t h a t I h a d b e e n s e x u a l l y 24 a b u s e d f o r m o n t h s o n e n d b y J e f f r e y , I 25 k i n d o f w a n t e d t o c a l l i t t i m e w i t h MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 417 of 469 Highly Confidential Page 417 1 HIGHLY CONFIDENTIAL AEO 2 him. 3 I saw how he was acting with 4 the other girls. I saw how they got 5 pretty mentally messed up as well; for 6 example, . So... 7 Q. And you saw that before you 8 went to South Africa? 9 A. Yes. 10 Q . A n d w h i l e y o u w e r e i n S o u t h 11 A f r i c a , y o u g o t i n a f i g h t w i t h 12 J e f f r e y . 13 A . T h a t ' s c o r r e c t . 14 Q . A n d y o u d i d n ' t w a n t t o l o s e 15 t h i s w e i g h t , c o r r e c t ? 16 A . I d i d n ' t w a n t t o l o s e t h i s 17 w e i g h t b e c a u s e I w o u l d b e d e a d i f I 18 w e i g h e d 5 2 k i l o g r a m s . 19 Q . Y o u d i d n ' t w a n t t o l o s e t h e 20 w e i g h t i n S o u t h A f r i c a , c o r r e c t ? 21 A . I w a n t e d t o - - I w a s 22 d e s p e r a t e t o g o t o F I T . I t r i e d t o 23 l o s e a s m u c h w e i g h t a s I c o u l d f o r 24 J e f f r e y a n d G h i s l a i n e . 25 Q . W h i l e y o u w e r e i n S o u t h MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 418 of 469 Highly Confidential Page 418 1 HIGHLY CONFIDENTIAL AEO 2 Africa, you did some reevaluating of 3 your life? 4 MR. GUIRGUIS: Objection. 5 A. Reevaluating of my life? I 6 wouldn't say I spent the holiday 7 reevaluating my life, no. 8 Q. Were you happy when you were 9 in South Africa? 10 A . I w a s c o n c e r n e d b e c a u s e I 11 w a s b e i n g a s k e d a n d b e i n g h o u n d e d t o 12 f i n d a 1 8 - y e a r - o l d P A f o r J e f f r e y , a n d 13 I k n e w t h a t w a s w r o n g b e c a u s e h e w o u l d 14 d o e x a c t l y t h e s a m e t h i n g t o t h a t g i r l 15 t h a t h e d i d t o m e , a n d I w o u l d n o t l e t 16 h i m d o t h a t t o a n o t h e r g i r l . 17 Q . S o w h e n y o u w e r e i n S o u t h 18 A f r i c a , y o u d e c i d e d t o m a k e a b r e a k 19 f r o m J e f f r e y . 20 M R . G U I R G U I S : O b j e c t i o n . 21 A . I d i d n ' t d e c i d e t o m a k e a 22 b r e a k ; I d e c i d e d t o d i s t a n c e m y s e l f 23 f r o m J e f f r e y . N o t m a k e a b r e a k , b u t 24 t o d i s t a n c e m y s e l f . 25 Q . W h e n y o u c a m e b a c k , y o u MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 419 of 469 Highly Confidential Page 419 1 HIGHLY CONFIDENTIAL AEO 2 moved in with Adam? 3 A. That's correct. 4 Q. You can't remember the last 5 time that you saw Jeffrey? 6 MR. GUIRGUIS: Objection. 7 That's not the testimony. 8 A. No. 9 MS. MENNINGER: No further 10 q u e s t i o n s . T h a n k y o u . 11 T H E W I T N E S S : T h a n k y o u . 12 M S . M E N N I N G E R : D o y o u h a v e 13 a n y ? 14 M R . G U I R G U I S : G i v e m e o n e 15 s e c o n d t o c o n f e r . 16 W e h a v e n o q u e s t i o n s . 17 M S . M E N N I N G E R : C o u n s e l , 18 w e ' r e g o i n g t o , u n f o r t u n a t e l y , 19 b e f o r e w e g o o f f t h e r e c o r d , n e e d 20 t o l e a v e t h e d e p o s i t i o n o p e n , 21 j u s t b e c a u s e t h e r e a r e s o m e e m a i l 22 d o c u m e n t s t h a t w e r e r e f e r e n c e d 23 b u t n o t p r o d u c e d . A n d w e c a n 24 f o l l o w u p a n d h a v e a d i s c u s s i o n 25 w i t h c o u n s e l a b o u t t h a t . MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 420 of 469 Highly Confidential Page 420 1 HIGHLY CONFIDENTIAL AEO 2 MR. GUIRGUIS: Okay. So on 3 the record -- we can carry on the 4 conversation, certainly, off the 5 record. 6 But while we're on the 7 record, I will say that my 8 understanding is that those 9 documents were all produced to 10 y o u , i n c l u d i n g a l l t h e e m a i l s 11 t h a t y o u a s k e d h e r a b o u t , a n d 12 w h e r e a r e t h e m i s s i n g e m a i l s , a n d 13 s h e k e p t s a y i n g t h e y ' d b e e n 14 p r o d u c e d t o h e r a t t o r n e y s . M y 15 u n d e r s t a n d i n g i s t h a t t h e 16 a t t o r n e y s d i d p r o v i d e t h e m t o 17 d e f e n s e c o u n s e l . 18 M S . M E N N I N G E R : W e l l , 19 t h e r e ' s a c u r r e n t p a s s p o r t t h a t 20 w e k n o w w a s n o t p r o d u c e d , t h e r e 21 i s a n F I T a p p l i c a t i o n t h a t w e 22 k n o w w a s n o t p r o d u c e d , a n d I 23 b e l i e v e t h e r e a r e e m a i l s t h a t 24 w e r e n o t p r o d u c e d . 25 A n d I ' m h a p p y t o h a v e t h e MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 421 of 469 Highly Confidential Page 421 1 HIGHLY CONFIDENTIAL AEO 2 conversation continue off the 3 record, but I'm telling you those 4 are some of my recollections. 5 MR. GUIRGUIS: Okay. And to 6 be clear so that I'm not 7 misrepresenting, I see that I 8 said there were documents and the 9 emails. I meant to clarify, as 10 i n t h e e m a i l s I k n o w w e r e 11 p r o d u c e d . 12 I c a n ' t s p e a k t o a n y o t h e r 13 d o c u m e n t s t h a t y o u m i g h t w a n t t o 14 r a i s e a d i s p u t e a b o u t . B u t w i t h 15 r e s p e c t t o t h e e m a i l s t h a t y o u 16 s a i d , m y u n d e r s t a n d i n g , a t l e a s t 17 a s I s i t h e r e , i s t h a t t h e y w e r e 18 p r o d u c e d . 19 T h a t s a i d , I t h i n k w e c a n g o 20 o f f t h e r e c o r d a n d r e s o l v e a n y 21 o t h e r i s s u e s b e t w e e n c o u n s e l a n d 22 I . 23 ( T i m e n o t e d : 6 : 3 4 p . m . ) 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 422 of 469 Highly Confidential Page 422 1 HIGHLY CONFIDENTIAL AEO 2 3 ____________________________ SARAH RANSOME 4 5 Signed and subscribed to before me, this_______day 6 of ___________ 2017. 7 _________________________ Notary Public 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 423 of 469 Highly Confidential Page 423 1 2 C E R T I F I C A T E 3 STATE OF NEW YORK ) : 4 COUNTY OF NEW YORK) 5 6 I, Jeremy Richman, a Notary Public 7 within and for the State of New York, do hereby 8 certify: 9 THAT SARAH RANSOME, the witness 10 whose deposition is hereinbefore set forth, was 11 duly sworn by me and that such deposition is a 12 true record of the testimony given by such 13 witness. 14 I further certify that I am not 15 related to any of the parties to this action by 16 blood or marriage; and that I am in no way 17 interested in the outcome of this matter. 18 IN WITNESS WHEREOF, I have hereunto 19 set my hand this 19th day of February 2017. 20 21 22 ________________________ Jeremy Richman 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 424 of 469 Highly Confidential Page 424 1 2 INDEX 3 EXAMINATION BY 4 MS. MENNINGER 7 5 P.M. Session 199 6 7 EXHIBITS MARKED 8 (Defendant's Exhibit 1, hand-drawn 128 9 picture marked for identification.) 10 ( D e f e n d a n t ' s E x h i b i t 2 , h a n d - d r a w n 1 4 9 11 p i c t u r e , w a s m a r k e d f o r 12 i d e n t i f i c a t i o n . ) 13 ( D e f e n d a n t ' s E x h i b i t 3 , a f f i d a v i t , 2 6 2 14 w a s m a r k e d f o r i d e n t i f i c a t i o n . ) 15 ( D e f e n d a n t ' s E x h i b i t 4 , 2 7 4 16 R A N S O M E _ 0 0 0 1 6 8 , w a s m a r k e d f o r 17 i d e n t i f i c a t i o n . ) 18 ( D e f e n d a n t ' s E x h i b i t 5 , j u r y t r i a l 3 2 3 19 d e m a n d , w a s m a r k e d f o r 20 i d e n t i f i c a t i o n . ) 21 ( D e f e n d a n t ' s E x h i b i t 6 , B a t e s 3 3 5 22 s t a m p e d R a n s o m e _ 0 0 0 0 1 7 , w a s m a r k e d 23 f o r i d e n t i f i c a t i o n . ) 24 ( D e f e n d a n t ' s E x h i b i t 7 , B a t e s 3 3 9 25 s t a m p e d R a n s o m e _ 0 0 0 2 0 4 , w a s m a r k e d MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 425 of 469 Highly Confidential Page 425 1 for identification.) 2 (Defendant's Exhibit 8, Notice of 363 3 Service of Rule 45 Subpoena and 4 Notice of Deposition of Sarah 5 Ransome, was marked for 6 identification.) 7 (Defendant's Exhibit 8, Bates 377 8 stamped RANSOME_000004, was marked 9 for identification.) 10 ( D e f e n d a n t ' s E x h i b i t 1 0 , B a t e s 3 8 4 11 s t a m p e d R A N S O M E _ 0 0 0 0 0 6 , w a s m a r k e d 12 f o r i d e n t i f i c a t i o n . ) 13 ( D e f e n d a n t ' s E x h i b i t 1 1 , M a u r e e n 3 8 6 14 C a l l a h a n a r t i c l e , w a s m a r k e d f o r 15 i d e n t i f i c a t i o n . ) 16 ( D e f e n d a n t ' s E x h i b i t 1 2 , w e b s i t e 3 8 9 17 p r i n t o u t t i t l e d H o w t o A p p l y , w a s 18 m a r k e d f o r i d e n t i f i c a t i o n . ) 19 ( D e f e n d a n t ' s E x h i b i t 1 3 , B a t e s 3 9 3 20 s t a m p e d R A N S O M E _ 0 0 0 0 0 7 w a s m a r k e d 21 f o r i d e n t i f i c a t i o n . ) 22 23 Q U E S T I O N S I N S T R U C T E D N O T T O A N S W E R 24 d o y o u h a v e a n y s o u r c e o f i n c o m e ? 1 0 25 s o I ' m g o i n g t o a s k y o u a l a s t 1 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 426 of 469 Highly Confidential Page 426 1 time: Do you have any source of 2 income? 3 what is your partner's occupation? 13 4 and where do your parents live? 14 5 Ms. Ransome, there was a question 15 6 pending when you took a break with 7 your lawyers. Can you please 8 answer the question. 9 what is your partner's cell phone 28 10 n u m b e r ? 11 a n d y o u ' r e s t a y i n g w h e r e w h i l e 3 1 12 y o u ' r e h e r e ? 13 h a v e y o u b e e n p r o m i s e d t h a t y o u 3 4 14 w o u l d h a v e c o u n s e l t o h e l p y o u 15 b r i n g a l a w s u i t a g a i n s t a n u m b e r o f 16 p e o p l e ? 17 w h a t ' s t h e p r i v a t e l e g a l m a t t e r ? 1 7 2 18 w h a t d i d y o u t a l k a b o u t w i t h A l a n 1 8 4 19 D e r s h o w i t z ? 20 d i d y o u s i g n a c o m m o n i n t e r e s t 1 8 5 21 a g r e e m e n t w i t h J e f f r e y ? 22 d i d h e d o a n y t h i n g i n t e r m s o f 1 9 9 23 c o n t a c t i n g a n y o n e o n y o u r b e h a l f ? 24 w h a t w a s t h e s p e c i f i c l e g a l m a t t e r 1 9 9 25 t h a t y o u w e r e s e e k i n g MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 427 of 469 Highly Confidential Page 427 1 representation for? 2 who prescribed it to you? 204 3 so please tell me how to reach your 241 4 stepmother, Linda Ransome. 5 when did you see that? 284 6 when did you provide them to your 363 7 counsel? 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 428 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 429 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 430 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 431 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 432 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 433 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 434 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 435 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 436 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 437 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 438 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 439 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 440 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 441 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 442 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 443 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 444 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 445 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 446 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 447 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 448 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 449 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 450 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 451 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 452 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 453 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 454 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 455 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 456 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 457 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 458 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 459 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 460 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 461 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 462 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 463 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 464 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 465 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 466 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 467 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 468 of 469 Jane Doe 2 MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 469 of 469