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FW: Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version)
Mon, 23 Mar 2020 21:28:16 +0000
Maxwell_Dep._Tr._(Slip_and_Fall_Case).pdf
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my paralegal found this. Not sure if you have it so I wanted to pass it along. It's a 2019 depo of Maxwell in a slip
and fall case in NYC. There are some clips below and the full version is attached.
Best,
Sigrid
Sigrid McCawley
Partner
on au er ae.
Sabina Mariella
Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version)
Note the File # has an AIG PRIV prefix (this has to mean that AIG is her insurance carrier on this case).
CUOMO, LLC.
Attorney for Defendant
Mineola, New York 11501
FILE NO.: AIGFRIV 17007
EFTA00011365
SHELDON BARR and THOMAS GARDNER,
-against-
CITY OF NEW YORK and
Plaintiffs,
Defendants,
INDEX NO.: 159225/2010
New York, New York
April 9, 2019
10:07 a.m.
EXAMINATION BEFORE TRIAL of the Defendant,
by GNISLAINE MAXWELL, iN
the above-entitled action, held at the above time
and place, taken before a Notary Public of the State
of New York, pursuant to Order and Stipulations
r
Page 9 (Primary residence as of 9/2015 NY)
EFTA00011366
Q.
What was your primary residence back in
September
A.
of 2015?
Q•
Can you tell me how much time you spent
there, say, back in 2015 from January 1st through
September 9, 2015?
A.
A lot of time. I lived there. That's my
primary residence.
Page 10 (Maxwell is a US Citizen as well as citizen of France and England)
Q.
A.
Where were you born?
Paris, France.
Q.
What is your date of birth?
A.
Q.
Are you a U.S. Citizen at this time?
A.
Yes.
Q.
When did you become a U.S. Citizen?
A.
I don't recall. But it was some time in
late
ftember.
'90s, mid '90s. I'm not sure. I don't
Q.
Are you a citizen of any other country?
A.
Yes.
0.
What other countries?
A.
France and England.
Page 11 Education and Licenses
EFTA00011367
Q.
Do you have any professional degrees or
licenses?
A.
I do.
Q.
In what?
A.
I'm a registered emergency technician,
first responder, EMT. I'm a helicopter pilot.
Q.
Sorry?
A.
Helicopter pilot.
Q•
Is your certification as an EMT in the
United States or another country?
A.
In the U.S.
Page 12 - Ellmax
11
12
13
14
17
18
19
20
21
22
23
Q.
What is Ellmax?
A.
It's no longer in existence.
Q.
What was it?
A.
It was a company I started to advise othe:
businesses on board placement, placing board of
directors, and any other questions they might have,
conferences, locations for conferences, speakers at
conferences.
Q.
What is the primary business? Is it
Ellmax, LLC.?
A.
I think so.
Q.
Is that a Florida Limited Liability
Company?
A.
Whatever paperwork I have. I don't recal_.
Whatever it says on the paperwork.
EFTA00011368
Page 16 —
Maxwell paid
(Proof of payments?)
personal assistant for more than 10 years (beginning 2001 or 2002) and
herself not through Ellmax.
Q.
-
A.
my personal assistant.
Q.
How long was
your personal assistant?
A.
More than ten years.
Q.
More than ten years from today?
A.
No. ■
doesn't work for me anymore.
Q.
When did you start working for you?
A.
Again, some time .n 2001, 2002. Something
like that.
Q.
Was
your personal assistant for the
next ten years?
A.
Yeah.
Q.
Was
paid by Ellmax, miLC.?
A.
I paid
myself.
Q.
Did you pay
out of a different company
or different funds or what source?
A.
t don't recall where T paid
from
exactly.
was not an employee of -- I was the
only person that did any work for El:rax.
Was
my personal assintart.
was abl•>
would do
Page 18 (Ellmax Florida Corporation — Maxwell stated that she lived in number of place in Florida)
EFTA00011369
9
C.
Was there a reason you chose a Florida
10
ILmited Liability Company for Ellmax, LAC.?
11
A.
I don't know why. I don't remember.
12
Q.
Were you also a Florida resident back in
13
2016?
14
A.
1 lived in Florida at certain times since 2
15
-2ved to the states.
IC.
2.
What is your address In Florida?
A.
7 lived in a number of different places in
IR
'lorida.
19
Q.
Do you own real estate in Florida?
2C
A.
No.
21
Q.
At any point did you maintain a residence
22
_n Florida?
23
A.
I've never owned a home in Florida.
24
u.
Dad you rent the sane residence in Florida?
2S
A.
No.
Page 23 (Communicated with her personal assistant via email, text or phone)
Where are the records?
EFTA00011370
1
2
3
4
5
6
7
8
in
.2
you
Q.
You said ■
was your personal assistant .
A.
I did.
Q.
Was that a remote job or did
lave with
or lived nearby?
A.
never lived in my none.
I can't
recall. Wherever
lived I don't know. I'm
.orry.
Q.
Was it a full-time or part-time 'oh?
A.
It was full-time.
D.
How would you communicate with
Page 25: Darren Indyke helped Maxwell create Ellmax
EFTA00011371
April 9, 2019
2
3
4
S
6
IJ
11
12
13
14
15
16
17
a
Q.
Was there ever any other members?
A.
1 don't believe so.
Q.
Could you tell me who Darren Indyke, Esq.
New York. New York is? Could
you tell me who he is?
A.
He is a :awyer.
O.
What :r his connection with the LLC?
A.
Me helped create tt.
Q.
Did you hire him to create it?
A.
I don't recall how tt went down exactly.
How he came to do it. But, he was the lawyer. Aryl
•.a helped create tt.
Q.
Was he referred to you by somebody?
A.
Ho worked tor a friend of mine.
Q.
Who is that?
A.
A gent:Almon called Mr. Spinel:—
Page 31 (Miami Beach address in 2014)
11
12
13
14
15
16
What is the address at
Miami Seach, Florida 33139?
A.
That was a home that i rented !or a short
while, and I stayed at the address.
0.
When did you rent it?
A.
I don't rota:: tne dates. 1 am sorry.
0.
Was it in the year 2014.
A.
I honestly don't remember.
Page 32 (Douglas Elliman was broker for sale of NY home)
EFTA00011372
:1
12
13
14
15
16
17
lE
:9
20
21
22
23
24
Q.
Was that based on your accountant or a
legal advise or on your own?
A.
I'm sure that was based on legal advise.
Q.
you?
Did you have a lawyer that formed it for
A.
You are asking things to go hack over 20
years. I don't recall exactly how it went. down.
Q.
Did you utilize the services of a broker
purchasing
A.
I don't remember.
Q.
Did you ut I re the services of a broke•(
when se:ling
A.
1 did.
D.
Was that Douglas Elliman?
A.
It was.
Page 40 (Odd that she says not married at the time ... could she be married now)?
EFTA00011373
1
2
3
April 9,
GHISLAINE
A.
No.
Q.
Who lived in
MAXWELL
Or.
4
September 9, 2015?
5
A.
Excuse me?
6
Q.
Are you married?
7
A.
I was not married at the time of this.
8
Q.
Do you have any chi:dren?
9
A.
No.
10
Q.
Did you have any help that lived in the
11
house with you?
12
A.
No.
13
Q.
Did you have a housekeeper?
14
A.
I did have a housekeeper, yes.
15
Q.
Live out or live in?
16
A.
Out.
Page 47 (says she used a MAC or laptop in 2015)
(for ESI)
15
16
17
18
19
70
2:
22
23
24
Q.
Were thorn computers kept in that office?
A.
There was a computer in that office.
Q.
What kind of computer was it?
A.
I think it was a Hock.
O.
Was it • laptop or desktop?
A.
I think it was • desk top. It could :olive
boon a laptop.
I don't know.
Q.
Who owned that desktop?
A.
Well, If it was a desk top it would have
been me. Actually I think it was laptop an 201',.
Q.
back in September of 2015, was there a desk
2019
EFTA00011374
Maxwell had a filing cabinet (hard copy records)
I didn't have oustnoss recoros.
C.
Where did you keep the records for Ellhax.
A.
I use to move my
: had a file cabinet
wherever I was sitting. 1 had a filing cabinet.
Q•
Where would that be kept? Cn what floor 1 -
the building?
A.
It moved. I frequently moved riy desk.
couldn't decide where I woulc sit. Tnere was a
period of time in the dining room became a place
where I would sit and the library. When I moved ny
desk my little filing system cop come with me.
Page 52-53 (Tax returns reflect Maxwell claiming to work 60 hour weeks for Terramar)
EFTA00011375
IS
16
17
18
19
20
21
22
23
24
25
Q.
Referring to the bottom portion next to the
yellow label of Plaintiff's Exhibit 10. Directing
your attention to Page S of the tax return. Do you
see this page?
A.
I do.
0.
Did you indicate in this tax return that
you worked 60 hours a week
A.
Yes.
n the terramar Project?
C.
Did you have other officers at that time
that worked for the Terramar Project?
A.
Well.
done 23 hours.
08172 Court KeportIng... A LexItas Company
S00-678-0166
YORK COUNTY CLERK 03/05/2020 12:59 PR
IMMIX NO.
?age 53
April 9, 2019
159224/3016
03/05/3020
113
1
2
3
Q.
Is that accurate?
A.
I'm ours it is.
Page 54-55 Claims only "contract contractors" who paid for work — but she and other board members
did not receive compensation.
EFTA00011376
25
A.
These aro just all directors and none of
DFITZ Court Reporting... A Lexitas Company
803-678-0166
YORK COUNTY CLERK 03/05/2020 12:59 P$
. 113
2
3
4
5
B
INDEX NO. 159224/201G
RECEIVED ?NEGEV: 03/05/2020
Page 55
April 9, 20:9
GRISLAINE MAXWEtt
cher. were :enumerated. Nobody was paid. But,
Terramar Project did have work called contract
contractors who did do work for it. A contract
employee or contract person that worked for tne
company is not the same as a regular employee. The.:
wouldn't come to work.
O.
Who was that?
A.
I have had a number of -- I had a number of
different people. We also have one person who did
work for Terramar Project. They were always
()trait*, beCadae they would never come to work.
They would be remote.
Page 55: Robert Foos was a contracted employee for Terramar (Director of Development)
Who paid him?
EFTA00011377
14
15
16
17
16
21
22
21
74
25
0.
Were there any contracting employees back
in 2015 for Terramar Prolocc, Inc.?
A.
There were, yes.
Q.
Who were they?
A.
One. I believe It was Robert Foos.
D.
In what position did he hold?
A.
I think his official title was Director
Covelopment.
0.
Coos the additiona_ data sheet indicate
that you were also working 60 hours a week for
Terramar Project back in 2013?
A.
Yes.
DEITZ Court Report1mg... A Lexitas Company
800-6/8-0166
YORK COUNTY crairanvomunxis-tng
INDEX NO. 259224/2016
RECRIVED NTSCRF: 03/05/2020
?age 56
April 9, 20:9
GH1SLAINE
Page 57-58 (Mark, Paneth & Shron prepared her taxes for Terramar)
EFTA00011378
23
Q.
Was tne
24
Paneth c Shron,
25
New York 130017,
accountant that prepared it Mark,
LLP.,
New York,
as indicated on Plaintiff's Exhibit
DEITZ Court Reporting... A Lexitas Company
800-678-0166
YORK COUNTY CLERIC 61/015/2020 12:59 P$
113
1
2
10?
3
A.
4
Q.
5
A.
6
Q.
returns
8
Project?
INDEX NO.
Page 58
April 9, 2319
It may have been.
Were they your accountants?
They were.
Do they always tile your personal tax
and the tax returns for the Terramar
Page 66 (Discussed deed being titled as
15
16
:7
Q.
When it was purchased in
recall if you purchased it using
LLC.?
2000, do you
18
A.
I believe I did.
19
Q.
Were you the sole member of
20
LLC.?
21
A.
Yes.
22
Q.
Were you advised either by a lawyer or an
23
accountant to purchase the home through an LLC?
24
A.
I don't recall, but I'm sure I was.
Page 70
EFTA00011379
NO. 113
Page 7C
April 9, 2019
1
2
Q.
When in town is that where you would sleep?
3
A.
Yes.
4
Q.
You had your master bedroom in the house at
5
6
A.
Yes.
8
O.
2016?
That was all the time between 2000 thru
9
A.
Yes.
10
Q.
With respect to the Terramar Project, did
11
you ever collect or have you ever collected any
12
salary as the president of the Terramar Project?
13
A.
No.
Page 73-74
14
15
Q.
Have you received any
kind from the Terramar Project
remaavrat ion of uny
for your servic'• for
16
that not-for-profit entity?
17
A.
No.
18
Q.
Is there any place in the home, at
19
that is set aside for use solely by the
20
Terramar Protect?
21
A.
No.
03/05/2020
EFTA00011380
25
C.
When you worked for a particular company,
DEITZ Court Reporting... A Lexitas Company
800-678-0366
YORK COUNTY CLERK 03/05/2020 12:59 RI
. 113
1
2
3
4
5
6
INDEX NO. 159:
RECEIVED NYSCEF: 03,
Page 74
April 9, 2019
did you work with them at their premises?
A.
Yes.
Q.
DId you ever had them come to your
business, to
to do that work?
A.
No.
EFTA00011381
Q.
During the period of tire that Ellmax
10
11
functioned, did it generate revenue?
A small amount.
Q.
Did you ever collect a salary for Ellmax?
A.
No.
12
Q.
Were you ever disbursed any profits from
13
Ellmax?
14
A.
No.
15
Q.
What happened to the revenue that Ellmax
16
generated during that period of time, from 2010 to
:7
2013?
18
A.
It dust was used to deter cost such as
19
traveling and travel mostly.
20
Q.
What were the costs of travel related to
21
Ellmax where you were going?
22
A.
Sorry, most of the corpanies I would have
23
worked for were from Los Angeles. I went to LA and
24
also to London multiple times.
Page 76-77 (Monte Albers De Leon closing lawyer for house/Maxwell did not attend closing).
EFTA00011382
19
20
21
22
23
24
25
Q.
Did you attend
the closing
when you solo
the building
at
A.
No.
O.
Did you authorize
somebody to attend
the
closing
for
you?
A.
Yes.
Q.
Who was that?
DEITZ Court Reporting... A Lexitas Company
800-678-0166
YORK COUNTY CLERK 03
. 113
/05/2020
12:59
PX
1
2
3
4
INDEX NO. 159224/:
RECEIVED NYSCEF: 03/05/:
Page 77
April 9, 2019
A.
The lawyer that is on that. I don't
remember his name. Monte Albers De Leon.
Q.
Who is he? Is he your lawyer?
A.
He was a lawyer that I used.
Sandra Perkins Borger
Case Manager
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EFTA00011383