EFTA Document EFTA01306406

FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' NYSCEF DOC. NO. 1:2 INDEX NO. 159224/2016 RECEIVEDg e NYSCEF: 03/05/2020 Pa April 9, 2019 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK SHELDON BARR and THOMAS GARDNER, Plaintiffs, -against- CITY OF NEW YORK and 116 EAST 65TH STREET, LLC, Defendants, INDEX NO.: 159225/2010 535 Fifth Avenue New York, New York April 9, 2019 10:07 a.m. X X 1 EXAMINATION BEFORE TRIAL of the Defendant, 116 EAST 65TH STREET, LLC, by GHISLAINE MAXWELL, in the above-entitied action, held at the above time and place, taken before a Notary Public of the State of New York, pursuant to Order and Stipulations between Counsel. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323955 EFTA_0011 96640 EFTA01306406 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ NYSCEF DOC. NO. 113 1 2 3 4 5 6 7 8 11 12 12 IA 1( 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEI/NfblY*CEF: 03/05/2020 April 9, 2019 2 APPEARANCE S: THE LAW OFFICE OF JOSEPH FALLEK Attorney for Plaintiffs One Battery Park Plaza, 32nd Floor New York, New York 10004 BY: LARRY FALLEK, ESQ. CUOMO, LLC. Attorney for Defendant 116 EAST 65TH STREET, LLC. 200 Old Country Road, Suite 2 South Mineola, New York 11501 BY: MATTHEW CUOMO, ESQ. FILE NO.: AIGPRIV 17007 DEITZ Court Reporting... A Lexitas Company 800-676-0166 SDNY_GM_00323956 EFTA_00196641 EFTA01306407 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' NYSCEF DOC. NO. 113 1 2 3 4 5 6 7 8 9 ID 11 12 13 14 lb 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVIRpg@YBFEF: 03/05/2020 April 9, 2019 3 STIPULATIONS IT IS HEREBY STIPULATED AND AGREED by and between(among) counsel for the respective parties hereto, that: All rights provided by the C.P.L.R., including the right to object to any question, except as to form, or to move to strike any testimony at this(these) examinations(s), are reserved, and, in addition, the failure to object to any question or to move to strike any testimony at :his(these) examination(s) shall not be a bar or waiver to make such motion at, and is reserved for the trial of this action; IT IS FURTHER STIPULATED AND AGREED by and between(among) counsel for the respective parties hereto, that this(these) examinations(s) may be sworn to by the witness(es) being examined, before a Notary Public other than the Notary Public before whom thisithese) examination(s) was:were) begun; but the failure to do so, or to return the original of this(these) examinations(s) to counsel, shall not be deemed a waiver of the rights provided by DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323957 EFTA 00196642 EFTA01306408 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PMI NYSCEF DOC. NO. 113 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEINWY4CEF: 03/05/2020 April 9, 2019 4 ST/PULATIONS (Cont'd) Rules 3116 and 3117 of the C.P.L.R., and shall be controlled thereby; IT IS FURTHER STIPULATED AND AGREED by and between(among) counsel for the respective parties hereto, that this(these) examinations(s) may be utilized for all purposes as provided by the C.P.L.R; IT IS FURTHER STIPULATED AND AGREED by and between(among) counsel for the respective parties hereto, that the filing and certification of the original of this(these) examination(s) shall be and the same hereby are waived; IT IS FURTHER STIPULATED AND AGREED by and between(among) counsel for the respective parties hereto, that a copy of the within examination(s) shall be furnished to counsel representing the witness(es) testifying, without charge. IT IS FURTHER STIPULATED AND AGREED by and between(among) counsel for the respective parties DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323958 EFTA_00I96643 EFTA01306409 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' NYSCEF DOC. NO. 113 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVFERg@Y.%pEF: 03/05/2020 April 9, 2019 5 STI PULATIONS (Conttd) hereto, that all rights provided by the C.P.L.R., and Part 221 of the Uniform Rules for the Conduct of Depositions, including the right to object to any question, except as to form, or to move to strike any testimony at this examination is reserved; and in addition, the failure to object to any question or to move to strike any testimony at this examination shall not be a bar or waiver to make such motion at, and is reserved to, the trial of this action. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323959 EFTA_001196644 EFTA01306410 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 2 3 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIXWITsCEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL GHISLAINE M A X W E L L, called as a witness, having been first duly sworn by a Notary Public of the State of New York, was examined and testified as follows: EXAMINATION BY MR. FALLEK: Q. Please state your name for the record. A. Ghislaine Maxwell. Q. Please state your address for the record. A. 44 Kinnerton Street, London, England SW183X. MR. FALLEK: Good morning, Ms. Maxwell. My name is Larry Fallek. I represent the plaintiffs in this action, Sheldon Barr and Thomas Gardner. I will be asking you a series of questions about an accident that occurred back on September 9, 2015. Many of the questions are going to involve your ownership. When I say, "your ownership," I am referring to the ownership of 116 East 65th Street in Manhattan. THE WITNESS: Okay. MR. FALLEK: Before we start I have a few DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323960 EFTA_00I96645 EFTA01306411 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb NYSCEF DOC. NO. 113 1 2 3 b 7 6 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIligogNYSCEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL basic rules I want to discuss with you. Please make all your responses verbally. The Court Reporter can't take down a shake or nod of cite head. Like you are doing right now. THE WITNESS: Of course. MR. FALLEK: Please say yes or no. THE WITNESS: Yes. MR. FALLEK: And try not to shrug your shoulders or anything like that. Just make all your response verbally. THE WITNESS: I shall. MR. FALLEK: Please let me finish my entire question before you give an answer. The Court Reporter cannot take us both down speaking a - the same time. Q. Is that agreeable? A. Yes. MR. FALLEK: It's important that you stop me if you don't understand a question. If you do give an answer, I will assume that you understand my question. 0. Is that understood? A. Yes. 0. The address that you just gave the Cot a DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323961 EFTA_00I96646 EFTA01306412 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEIWOYfICEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL Reporter, how long have you lived there? A. '92, '93. Q. Is that your primary residence at this time? A. No. It's just a home that I have. Q. How many homes do you own back in September of 2015? A. Two. Q. Where are those homes? A. 116 East 65th Street and the one in London. Q. When you say, "the one in London," you are referring to the address that you just gave? A. Yes. Q. Is that a private home? A. Yes. Q. Is that home owned by you individually or some other form? A. It's owned by me. Q. Is your name on the deed to that property or the title of the property? A. It was back then. I kind of -- it was up until recently. I don't know. I can't remember what it is now, if I changed it or not. Q. Sack in September of 2015, did you or any DE1TZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323962 EFTA_00I96647 EFTA01306413 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ NYSCEF DOC. NO. 113 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVEWY§CEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL of your entities or companies own any other homes? A. No. Q. What was your primary residence back in September of 2015? A. 116 East 65th Street. 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. Q. Did you travel back and forth between London and New York? A. Extensively at. all the time. I just Gen': go to London. I travel all the time to a lot of different places. Q. For what purposes do you travel, business, pleasure, or something else? A. I do business. But, it was also I work on work for a not-for-profit. And I do a lot of time doing conferences and a lot of speeches. Q. I'm just talking about the time period of January 1, 2015 through September 9, 2015. Would that be true with regard to that time period? DEITZ Court Reporting... A Lox tas Company 800-678-0166 SDNY_GM_00323963 EFTA_00I96648 EFTA01306414 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECElfiribNitCEF: 03/05/2020 April 9, 2019 GHISLA1NE MAXWELL A. Correct. Q. Where were you born? A. Paris, France. Q. What is your date of birth? A. The 25th of December 1961. 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 the late '90s, mid '90s. I'm not sure. I don't remember. Q. Are you a citizen of any other country? A. Yes Q. What other countries? A. France and England. Q. Sorry, France and? A. England. Q. Are you a citizen or you are a green card holder? A. I'm a citizen. Q. Can you tell me about your educational background? What is the highest level of education that you have? A. I have a master's. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323964 EFTA_00 I 96649 EFTA01306415 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb4j NYSCEF DOC. NO. 113 1 2 3 4 5 6 7 8 9 IC 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIyneNiiCEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL Q. In what? A. French and history from Oxford. It's a BA MA. So when you go to oxford and you get a bachelor's and some time passes and it turns into a master's. Q. What is the BA in? A. French and history. Q. It's a combined degree? A. Double honors degree in French and history. Q. Do you have any other degrees? A. No. 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. Q. You didn't offer any medical assistance to :he Plaintiff in this action? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323965 EFTA_00I96650 EFTA01306416 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' NYSCEF DOC. NO. 1:2 1 2 3 4 S 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEMyeNyICEF: 03/05/2020 April 9, 2C19 GHISLAINE MAXWELL A. No. Q. Are you presently employed? A. No. 0. Are you self-employed? A. No. Q. What was the last job that you had? A. The last job I had was at Ellmax. E-L-L-M-A-X. Q. What. is Ellmax? A. It's no longer in existence. Q. What was it? A. It was a company I started to advise other businesses on board placement, placing board of directors, and any other questions they might have, conferences, locations for conferences, speakers dt. 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 recall. Whatever it says on the paperwork. MR. FALLEK: I'm going to show you three DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323966 EFTA_00I96651 EFTA01306417 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbij NYSCEF DOC. NO. 113 1 2 4 5 6 7 B 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEiyireeNWEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL documents that we will have marked as Plaintiff's Exhibit 1, 2, 3. (Whereupon, the document dated 9-18-14, was received and marked as Plaintiff's Exhibit 1 for identification, as of this date, by the reporter.) (Whereupon, the document dated 2-23-15, was received and marked as Plaintiff's Exhibit 2 for identification, as of this date, by the reporter.) (Whereupon, the document dated 3-22-16, was received and marked as Plaintiff's Exhibit 3 for identification, as of this date, by the reporter.) MR. FALLEK: I'm directing your attention to the document we just marked as Plaintiff's Exhibit 1 for identification. Q. Do you recognize this document to be the 2014 Florida Limited Liability Annual Report for Illmax, LLC.? A. I have not seen this document before so I can't say that. Q. Just take a look at it. A. I'm looking at it, but it's the first time DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323967 EFTA )0196652 EFTA01306418 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbil NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEiPVEal-De 1 NYECEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL I've seen this. Q. Did you form Ellmax, LLC.? A. I did. Q. Is it your company? A. IL is. It was. 0. When was it formed? A. I think 2010 or '11. Q. Was it formed in Florida? A. I guess. I'm sorry, I just don't recall. Q. Could you tell me what the business purpose of Ellmax, LLC. is? A. It was a vehicle for me to be able to advise companies on board of directors and to help with companies for conferences and speakers for their conferences. Q. Board of directors of what type of companies are you advising people on? A. Mostly technology businesses, because I know a lot of people in technology. It could be in anything as a board of directors are needed in any type of company. And people of good character and outstanding abilities in business are always needed. And I, fortunately, have a lot of friends and people in that area that I will be able to place people in DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323968 EFTA_00I96653 EFTA01306419 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEigyeNlICEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL those type of companies. Q. Was the principal place of business of Ellmax, LLC. at 116A East 65th Street, New York, New York? A. It wasn't that specific. It was wherever I was. Everything that is in my head is my contact, my ideas. Q. Specifically the document in front of you, when you formed it, did you indicate that the principal place of business was 116 East 65th Street, New York, New York? A. I think it was just filed there. It would be easier for me other than any other reason. 0. Did you sign the documents for the limited liability company known as Ellmax, LLC.? A. I'm sure I did with my lawyers. There was no reason other than as an address of convenience. MR. FALLEK: Move to strike the nonresponsive portion. THE WITNESS: I'm not trying NR. FALLEK: Just try focus on the question that I'm asking you. THE WITNESS: I'm not trying to be evasive. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00323969 EFTA_00196654 EFTA01306420 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 2 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECELyneNWEF: 03/05/2020 Apri l 9, 2019 GHISLAINE MAXWELL Q. Who is A. She's my personal assistant. Q. How long was she your personal assistant? A. More than ten years. Q. More than ten years from today? A. No. She doesn't work for me anymore. Q. When did you start working for you? A. Again, some time in 2001, 2002. Something like that. Q. Was she your personal assistant for the next ten years? A. Yeah. Q. Was she paid by Ellmax, LLC.? A. I paid her myself. Q. Did you pay her out of a different company or different funds or what source? A. I don't recall where I paid her from exactly. She was not an employee of -- I was the only person that did any work for Ellmax. She was my personal assistant. She was able -- she would do anything I would ask her to do as regards to my travel, whatever. But she was -- she couldn't help me with Ellmax. She didn't know people to place them on board. If I directed her to get me on A DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323910 EFTA_00I96655 EFTA01306421 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ NYSCEF DOC. NO. 113 1 2 3 S 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIMeNISFEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL flight or something that may have been in relation to business opportunity, she would do that. Q. What is her current address? A. 1 don't know. Q. Do you know what state she lives in? A. I think she's in Detroit somewhere. Q. Back in 2016, did she live at 116 East 65th Street, New York, New York? A. No. Q. Where did she live in 2016? A. Somewhere in New Jersey. MR. FALLER: Directing your attention to Plaintiff's Exhibit 2 for identification. Q. Is that the 2015 Florida Limited Liability Company for Ellmax, LLC.? A. Again, I have not seen this before. I have to take -- I haven't seen this before. So I'm assuming that's what it is. Q. Were regular annual reports filed by Ellmax, LLC.? A. Again, that would have been my accountant, I would assume, would have a list of what is expected or legally. Q. Who was your accountant back then? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323971 EFTA_00 I 96656 EFTA01306422 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ NYSCEF DOC. NO. 113 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEDF/SO aqe NYSCEF: 03/05/2020 18 April 9, 2019 GHISLAINE MAXWELL A. I am sorry, I don't recall the name at this moment. Q. What was the name of the company that you worked for? A. I don't recall. I am sorry. Q. Was he in New York or Florida? A. In New York, I believe. Q. Was there a reason you chose a Florida Limited Liability Company for Ellmax, LLC.? A. I don't know why. I don't remember. Q. Were you also a Florida resident back in 2016? A. I lived in Florida at certain times since I moved to the states. Q. What is your address in Florida? A. I lived in a number of different places in Florida. Q. Do you own real estate in Florida? A. No. Q. At any point did you maintain a residence in Florida? A. I've never owned a home in Florida. Q. Did you rent the same residence in Florida? A. No. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323972 EFTA_00I96657 EFTA01306423 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' NYSCEF DOC. NO. 113 1 2 3 4 5 6 7 S 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIffeeNiiFEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL Q. How many months of the year, let's say, it 2016 did you reside in Florida? A. Probably none. Q. How much time did you spend in Florida 2016? A. Probably, I don't know, less than -- I don't know. A few weeks. Two weeks, three weeks. Q. What about in 2015? A. I don't remember the dales. Maybe the same. Q. The principal place of business in 2015 is still listed as 116A East 65th Street, New York, New York. A. That would have all been the address for convenience. Q. That address was never changed was it? A. I don't believe so. Q• .L:1 Was the address of Ellmax always the same from the time it was formed until up the time you say you dissolved it? A. As far as I can recall, yes. MR. FALLEK: 1 am directing your attention to Plaintiff's Exhibit 3 for identification. Q. Do you recognize this document? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323973 EFTA_00I96658 EFTA01306424 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEIg8eNWEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL A. Sorry. Q. Plaintiff's 3 for identification, do you recognize this to be the 2016 Florida Limited Liability Company Annual Report for Ellmax, LLC.? A. Again, I have never seen this. I will just take your word that that's what that is. Q. In 2016, was the principal place of business for Ellmax, LLC. also listed as 116 East 65th Street, New York, New York? A. Again, that was the address of convenience. The business is wherever I am, but yes. MR. FALLEK: Move to strike the nonresponsive portion of the answer. Q. Did Ellmax, LLC. ever have a different principal place of business? A. I don't believe I had any other address of convenience than the one it has listed. MR. FALLEK: Move to strike as nonresponsive. Q. Is the answer no? A. No. Q. No it never had any other principal place of business? A. No. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323974 EFTA_00196659 EFTA01306425 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' NYSCEF DOC. NO. 113 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEiyafliCEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL Q. What were the assets of Ellmax, LLC.? A. it didn't have any assets. Q. Who were the members of the limited liability company? A. I believe I was the sole member. Q. Did Ellmax, LLC. have any employees? A. No. Q. I believe you said the last job you had was for Ellmax, LLC.? A. Last work that I did as you asked. Q. Before you worked for Ellmax, LLC., whom do you work for? A. I was unemployed. Q. During what period of time was that? A. I believe around 2000 -- about 2009 or '08. Q• When did you first move to the United States to live here continuously? A. 1991. Q. Where did you live in 1991? A. I was traveling around the states. Q. Was 116 East 65th Street, New York, New York, the first residence that you had in the United States? MR. FALLER: You seemed confused. I will DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323975 ER-Ai/0196660 EFTA01306426 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2C 21 22 23 24 25 INDEX NO. 159224/2016 RECEiyneNWEF: 03/05/2020 April 9, 2019 GH:SLAINE MAXWELL ask it a different way. Q. Where was the first place you lived in the United States? A. I rented. Q. Where did you rent? A. I rented a place on 59th and Seventh. Q • Did there come a time period where you purchased a residence? A. Yes. Q. When was that? A. When I purchased 116, I believe, in 2000. Q. Before 116 was purchased, did you form 116 East 65th Street, LLC.? A. No. I don't believe so, no. MR. FALLEK: Could we have this marked as Plaintiff's Exhibit 4 for identification. (Whereupon, the document dated 4/5/19, was received and marked as Plaintiff's Exhibit 4 for identification, as of this date, by the reporter.) Q. Before we get to this document. Was there a time period in which =MI lived in Manhattan? A. I don't know. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323976 EFTA_00196661 EFTA01306427 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ NYSCEF DOC. NO. 113 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 10 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEM eNWEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL Q. You said she was your personal assistant. A. I did. (2• Was that a remote job or did she live with you or lived nearby? A. She never lived in my home. I can't recall. Wherever she lived I don't know. I'm sorry. Q. Was it a full-time or part-time job? A. It was full-time. Q. How would you communicate with her? A. Via, email, text, or phone. Q. During what time period, if any, did she live in New York? A. I don't know if she lived in New York. She worked for me, and she turned up for work for me. But, I don't know where she lived. Q. Did you have somebody else, a different personal assistant for you, in Manhattan? A. No. MR. FALLEK: I'm going to show you what was marked as Plaintiff's Exhibit 4 for identification. I ask you to take a look at that document. Q. Do you recognize this document to be a DE1TZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323977 EFTA 00196662 EFTA01306428 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pbij NYSCEF DOC. NO. 113 2 3 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 24 April 9, 2019 GHISLAINE MAXWELL document from the New York State Department of State regarding 116 East 65th Street, LLC.? A. I have never seen this document before. Q. Could you please take a look at it. MR. CUOMO: I think she has. A. I've looked at it. Q. Did you form 116 East 65th Street, LLC. A. Yes. Q. When was it formed? A. Some time in 2000. Q. Is that prior to the time that 116 East 65th Street was purchased? A. I don't know the timing of it when it was purchased. I don't know when the time was for the creation of it and the purchase of the house. I'm sorry. Q. Is 116 East 65th Street a limited liability company? A. I believe so. Q. Is it a New York Limited Liability Company? A. I don't remember where it is limited. It says, New York. Q. Who are the members of that LLC? A. I believe I'm the sole member. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323978 EFTA_00196663 EFTA01306429 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 P?' NYSCEF DOC. NO. 113 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 25 April 9, 2019 GHISLAINE MAXWELL Q. Was there ever any other members? A. I don't believe so. Q. Could you tell me who Darren Indyke, Esq. at 475 West Avenue, New York, New York is? Could you tell me who he is? A. He is a lawyer. Q. What is his connection with the LLC? A. He helped create it. Q. Did you hire him to create it? A. I don't recall how it went down exactly. How he came to do it. But, he was the lawyer. And he helped create it. Q. Was he referred to you by somebody? A. He worked for a friend of mine. Q. Who is that? A. A gentlemen called Mr. Epstein. Q. Sorry? A. A gentleman. Q. Is that Jeffrey Epstein? A. Yes. Q. What was the principal place of business of 116 East 65th Street, LLC.? A. well, 116 didn't do any business. Q. What was the principal place business? Do DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323979 EFTA_00 I 96664 EFTA01306430 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 1 2 3 4 S 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NY9CEF: 03/05/2020 Page 26 April 9, 2019 GHISLAINE MAXWELL you maintain books for it? A. I don't have any paperwork regarding that. 1 don't have. It would have been with the accountant or whoever was dealing with it then. Q. Were there annual returns that were prepared for that LLC? A. I'm sure there were. Q. Did you sign them? A. I must have. Q. Where are they? A. So long ago I have no idea. I don't have that. Q. Did there come a time period where 116 East 65th Street, LLC. purchased the building at 116 East 65th Street, New York, New York? A. I am sorry, I don't know the -- I think 50. Q. Who owned your building? A. 116 East 65th Street, LLC. Q. When was it purchased by them? A. Like I have said, some time in 2000. MR. CUOMO: Before you ask another question I just want to talk to my client for a moment. (A short recess was taken.) DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323980 EFTA_00196665 EFTA01306431 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 2 3 4 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECELVED NYS_CEF: 03/05/2020 Page 2 April 9, 2019 GHISLAINE MAXWELL Q. Did you review any documents today before testifying? A. Only what was filed with the court with my lawyer. Q. Did you read or review your affidavit before testifying today? A. I did review? MR. FALLEK: Mark this as Plaintiff's Exhibit five. (Whereupon, the affidavit was received and marked as Plaintiff's Exhibit 5 for identification, as of this date, by the reporter.) MR. FALLEK: I will show you what was marked as Plaintiff's Exhibit 5 marked for identification. Q. I will ask if that is the affidavit that you reviewed? A. I'm going to read it to make sure. Q. Take your time. A. Is that okay? Q. Sure. Did you have a chance to read it? A. I have. Q. In your affidavit, in Paragraph 9, you say DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323981 EFTA_00 I 96666 EFTA01306432 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 28 April 9, 2019 GHISLAINE MAXWELI. that Ellmax, LLC. was a holding company when I started in 2010 with the intention of using for any consultation work that I may have done. What are you referring to? What consultation work that I may have done? A. Like I have explained earlier. I advised businesses or wanted to advise businesses in 2010 on placing people on boards or on any other aspect of business that would be relevant, conferences, and providing speakers for conferences. Q. You used the words "I may have done." Was that work you already had done or going to do? A. That I was hoping to do. Q. Were you one of the speakers or were you looking for other speakers? A. I have spoken, but I've never hired myselt to speak. Q. For Ellmax? A. No. That would have been funny. Q. You indicated also that you never took deductions on your taxes as a home office. Did you file income taxes in 2015? A. I did. Q. What taxes did you file in the United DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323982 EFT,k_00196667 EFTA01306433 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 April 9, 229 019 GHISLAINE MAXWELL States? A. Whatever I needed to file. Q. Did you file a New York State Income Tax? A. I'm sure I did. Q. Did you file Federal taxes in the Unites States? A. I'm sure I did. Q. What about City taxes? Did you also file those? A. I'm sure I did. Q. You also indicated in Paragraph 11, in 2010 when I started, you had said that you hired an assistant to Ellmax, LLC's payroll in 2017. Who was that? A. That was Dana. Q. Was that the same person that we spoke about before? A. Yes. Q. That's A. Yes. Q. What location did she work out of other than New Jersey? A. I believe her home. Q. Do you know if she worked out of her home DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323983 EFTA_00196668 EFTA01306434 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 30 April 9, 2019 GHISLAINE MAXWELL any other years? A. She worked. She was on call. She would have done work from her home. Q. What did she do for Ellmax, LLC.? A. She didn't do any work for Ellmax. She worked for me. She was my personal assistant. But if I asked her to make a flight or something, then it would have been. MR. CUOMO: Just clarify. Are you asking about 2017? MR. FALLEK: Yes. She said added her in 2017 on Ellmax's payroll. Q. Why did you add her to the payroll? A. I misunderstood the question. To shutdown the company. We restarted it start to shut it down. Q. Did she work for Ellmax prior to 2017? A. No. She -- whatever -- Ellmax was dormant from 2013 until I restarted to shut it down. MR. FALLEK: Move to strike as not responsive. Q. You did file annual reports, did you not, in 2014, '15, and '16 for Ellmax, LLC.? A. Right. But, it was just, you know, to DEITZ Court Reporting... A Lexitas Company 800-678-0166 S0NY_GM_00323964 EFTA_00196609 EFTA01306435 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NXSCEF: 03/05/2020 Page 31 April 9, 2019 GHISLAINE MAXWELL keep -- rather than going through the expense t' shut it down. It's expensive to shut it down. Q. so the answer is: No, you did file them all those year? A. It was filed, but it was dormant. Q. Did you have to file a fee every year? A. I'm sure I did. Q. What is the address at 16 Island Avenue, Suite 70, Miami Beach, Florida 33139? A. That was a home that I rented for a short while, and I stayed at the address. Q. When did you rent it? A. I don't recall the dates. 1 am sorry. Q. Was it in the year 2014. A. I honestly don't remember. MR. FALLEK: I'm showing you what was marked as Plaintiff's Exhibit 1 for identification, which it dates back to 2014. MR. CUOMO: She said she doesn't remember. A. I'm sorry, I don't recall. Q. In the year 2015 the address changed, is it not, to New York, New York? A. It has. Q. Do you know where the articles of an DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323985 EFTA_0011 96670 EFTA01306436 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 1 2 4 5 9 10 :1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RECEIVED NYSCEF: 03/05/2020 Page 32 April 9, 2019 GHISLAINE MAXWELL organization are for 116 East 65th Street, LLC.? A. I don't. Q. Do you know who has them? A. I don't. Q. Do you know what the business purposes was for forming 116 East 65th Street, LLC.? A. I think it's a common practice to place them as an LLC. I don't think there is anything unusual about that. 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. Did you have a lawyer that formed it for you? A. You are asking things to go back over 20 years. I don't recall exactly how it went down. Q. Did you utilize the services of a broker in purchasing 116 East 65th Street? A. I don't. remember. Q. Did you utilize the services of a broker when selling 116 East 65th Street? A. 1 did. Q. Was that Douglas Elliman? A. It was. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323986 EFTA_00I96671 EFTA01306437 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 2 3 4 S 6 7 A 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVEDPage 3 NYSCEF: 3 03/05/2020 April 9, 2019 GHISLAINE MAXWELL Q. How much did 116 East 65th Street, LLC. pay for the purchase of 116 East 65th Street in Manhattan? A. Around, I think it was, $6,000,000. Around 6,000,000. Q. Could you describe the building to me at 116 East 65th Street? A. What do you mean? Q. Let's start with, how many floors did the building have? A. Five. Q. That includes the roof and the basement? A. No. I think the basement would be six. If you count the roof then seven. Q. What was the square footage of the building? A. Around 6,500 or 6000 (sic). Something like that. Q. How many bedrooms did it have? Four. Q. How many bathrooms? A. Four. Q. Was the lot a 25 foot wide lot? A. Yes. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323987 EFTA 00196672 EFTA01306438 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEIPage VED NYSCEF: 34 03/05/2020 April 9, 2019 GHISLAINE MAXWELL Q. Was this a limestone building? A. Yes. Q. Did it have an elevator? A. Yes. 0. Was there a separate entrance that the building had? How many entrances did 116 East 65th Street have? A. Two. MR. FALLEK: I will show you a document : will have marked as Plaintiff's Exhibit 6. (Whereupon, the copy of a photograph was received and narked as Plaintiff's Exhibit 6 for identification, as of this date, by the reporter.) Q. Do you recognize what is shown in Plaintiff's Exhibit 6 for identification? A. I do. Q. What do you recognize that to be? A. 116 East 65th Street. Q. Is that the building that was purchased by 116 East 65th Street, LLC.? A. Yes. Q. Does that document or that photograph fairly and accurately show the way the building DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323988 EFTA_00I96673 EFTA01306439 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ NYSCEF DOC. NO. 113 2 3 4 5 6 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVE gD e NYSCEF: 03/05/2020 Pa 35 April 9, 2019 GHISLAINE MAXWELL appeared back on September 9th of 2015? A. I suppose. Q. Was there a tree or tree well in front of your premises? A. Yes. Q. Was a portion of the tree well was part ' your premises and your neighbor's premises? A. No. Q. Do you recognize the metal cage surrounding the tree well? A. Yes. Q. During the time period that 116 East 65th Street owned the building, did you or anybody on your behalf make any changes to the tree or the tree well? A. This tree well that you demonstrate here in this photograph, is the tree and the tree well belonging to my neighbor at 114 East 65th. Q. Is a portion of that tree going on your property? A. I don't recall, but that's the address of the tree. Q. Did you ever discuss the tree or tree well with your neighbor? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323989 EFTA_00 I 96674 EFTA01306440 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PM' NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page JO April 9, 2019 GHISLAINE MAXWELL A. No. Q. You said it's whose tree well? A. Diandra. Q. Diandra Douglas? A. Yes. Q. Did they live there before you moves there? A. No. Q. When did they move in? A. I don't recall exactly. Maybe 2005 or '06. Something like that. Q. At any time did you sweep the leaves from that tree on that portion of the sidewalk in front of your premises? A. Can you repeat the question? Q. Was there anytime that you lived at 116 East 65th street where you maintained the tree that we are referring to in the photograph? A. Diandra's tree? Q. Yes. A. No. Q. Did you ever trim the branches? A. No. Q. Did anybody on your behalf ever water the DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323990 EFTA_00I96675 EFTA01306441 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 37 April 9, 2019 GHISLAINE MAXWELL tree? A. No. Q. Did you do anything or have anyone do anything around the tree well? A. Around Diandra's tree? Q. Yes. A. No. Q. Did you ever discuss the tree with Diandra? A. No. Q. The sidewalk that is depicted in the picture, were any changes made to that sidewalk by you or anybody on your behalf during the time period that 116 East 65th Street owned the premises? MR. CUOMO: Hold on a second. From that photograph can you tell? MR. FALLEK: I'm not talking about that. I'm just directing her to the sidewalk. MR. CUOMO: Hear me out. I have a question for you. Are you representing that all of the sidewalk in that photograph depicted is Exhibit 6 is in front of 116 East 65th Street or are you asking her part from that photograph in front of 116 East 65th Street? MR. FALLEK: Let's first ask about the DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323991 EFTA_00I96676 EFTA01306442 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 2 3 S 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 38 April 9, 2019 GH:SLATNE MAXWELL photograph. Q. Was any work done by you or anybody to that area that is shown in the photograph? A. I've never directed anybody to do any work on the sidewalk. Q. Did anybody do any work to the sidewalk during that time period that you lived there? MR. CUOMO: Again, note my objection. Are you talking about the sidewalk in front of her home or the sidewalk that is in the photograph, which could be in front of multiple buildings? MR. FALLEK: The sidewalk in the photograph. A. I don't remember work being done passed me on the sidewalk. But, there was work, I believe, done around Diandra's tree. But, I don't know. Q. What was the work done around Diandra's tree? A. That tree is a big tree. It has a lot of roots. And I think there was some work done around her tree and her tree well, but I don't recall. 0. Do you remember when that was? A. I don't. Q. Was it before September 9, 2015? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323992 EFTA_00I96677 EFTA01306443 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 RECEIVED NY.SCEF: 03/05/2020 Page 39 April 9, 2019 GHISLAINE MAXWELL A. Any work would have been done around that tree would have been done prior to that, yes. Q. The work you are referring to, was that done to the tree, the tree well, or the sidewalk? A. 1 apologize, I just don't know. I don't know. Q• Besides the Diandra did anybody else live in the house during that time period? A. Any house? Q. Diandra's house. A. I don't know who lived with Diandra. Q. We are referring to 114 East. 65th Street? A. 114, yes. Q. Did you ever talk to her about the condition of the tree, the tree roots, or th. sidewalks prior to September 9, 2015? A. No. Q. Did anybody ever complain to you about the condition of the sidewalk in front of your premises before September 9th of 2015? A. No. Q. Did you ever receive any violations from the City of New York or anybody regarding the condition of the sidewalk in front of your premises? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323993 EFTA_00I96678 EFTA01306444 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 1 2 3 4 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 40 03/05/2020 April 9, 2019 GHISLAINE MAXWELL A. No. Q. Who lived in 116 East 65th Street on September 9, 2015? A. Excuse me? Q. Are you married? A. I was not married at the time of this. Q. Do you have any children? A. No. Q. Did you have any help that lived in the house with you? A. No. Q. Did you have a housekeeper? A. I did have a housekeeper, yes. Q. Live out or live in? A. Out. Q. How many days a week did she come to your home? A. She came every day during the week. Q. That was Monday through Friday? A. Correct. Q. What was her name? A. Maritsa. MR. CUOMO: Just to be clear now, you are talking about 2015? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323994 EFTA_0011 96679 EFTA01306445 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PMI NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 41 April 9, 2019 GHISLAINE MAXWELL MR. FALLEN: Yes, back in September of 2O15. A. That's how I answered your question. Q. Maritsa worked for you five days back then? A. Yes. Q. What were her duties and responsibilities? A. She was my housekeeper. So she would keep the house clean, and she would do the laundry. And She would Hoover. She would help me cleanup in the kitchen after I made a mess. MR. CUOMO: I have to break in there. (A discussion was held off the record.) Q. Who was responsible to take care of the outside of the home specifically the sidewalk in front of your home? A. I don't. But, I didn't designate anybody to clean the sidewalk or whatever. Q. Did somebody maintain the sidewalk in front of the home back in 2015? A. No. Q. Who would sweep the sidewalks? A. I don't know. Q. sidewalk? If there was snow, who would shovel the 0EITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323995 EFTA_0011 96680 EFTA01306446 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 1 2 3 4 5 6 8 0 10 11 12 13 14 15 16 77 18 19 2C 21 22 23 24 25 RECEIVED NYSCEF: 03/05/2020 Page 42 April 9, 2019 GHTSLAINE MAXWELL A. I'm not sure. Q. Did you hire an outside contractor or gardener or a person to maintain the exterior? A. No. Q. Did you enter the premises through the front door every time you went in and out? A. Sometimes mostly. Q. How else would you go in the house other than the entrance that is shown in the photo in front of you? A. You could go in the other entrance. Obviously, I mostly used the front entrance. Q. You said there were two entrances. A. Yes. MR. FALLEK: Could we have this marked. (Whereupon, the copy of a photograph was received and marked as Plaintiff's Exhibit 7 for identification, as of this date, by the reporter.) MR. FALLEK: 1 will show you a photograph, which we marked as Plaintiff's Exhibit 7 to: identification. Q. Have you seen this photograph before? A. I have not. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323996 EFTA_00196681 EFTA01306447 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 2 3 4 5 6 7 G IC 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 April 9, 2019 GHISLAINE MAXWELL Q. Do you recognize what is shown in that photograph? A. I do. But, I don't know what this bag is (indicating). Q• That makes two of us. MR. CUOMO: Just notice the bag hanging from the door handle. Q. Separate from the bag, do you recognize -- A. I do. Q. Is that a door to the premises of 116 East. 65th Street, New York, New York? A. It appears to be, yes. Q. How do you refer to this entrance? Is it the service entrance, business entrance? A. Separate entrance. Q. Where does this entrance lead? A. To the house. Q. Have you ever received or seen the Certificate Of Occupancy? A. Have I? Q. Seen the Certificate Of Occupancy for the house? A. I don't recall seeing it. Q. Is the building a two-family residence? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GM_00323497 EFTA _00I96682 EFTA01306448 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 Pb4 INDEX NO. 159224/2016 NYSCEF DOC. NO. 113 2 3 4 S 6 8 9 10 11 12 :3 :4 15 16 :7 :8 19 20 21 22 23 24 25 RECEIVED NYSCEF: 03/05/2020 Page 44 April 9, 2019 GHISLAINE MAXWELL A. I believe it is valued, but I think it has a designation as a two-family residence or however you say that. 0. Did you have a dog at the time that you lived in the building? A. Yes. 0• Was that Beware Of Dog sign put up by you or someone on your behalf? A. 1 put it up. 0. Who would walk the dog when you lived there back in 2015? A. I walked my dog. Dana walked my dog or whoever. 0. Did you reg.-Ile/1y walk the dog yourself? A. Yes. 0. Is there a back entrance to the building? A. NO. 0. :n order to walk the dog, would you have to go out the front door or the side door? A. You could go out either entrance. Q. Would you go every day? A. Yes. Q. Is there a buzzer or intercom system for in and out one of those doors DEIT? Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00323498 EFTA_00 I 96683 EFTA01306449 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ NYSCEF DOC. NO. 113 1 2 3 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 45 April 9, 2019 GHISLATNE MAXWELL that entrance? A. I don't think so. Q. What about for the front door, the door that is shown in Exhibit 6 for identification? A. There was a buzzer for that door. Q. How many buzzers were there? A. Just one I think. Q. Where would it buzz in the interior -- A. Buzz to the telephone. Q. To the telephone? A. Yes. Q. Where is the telephone kept? A. Telephone everywhere. All the telephones would go. You couldn't fail to hear the doorbell. Q. Who would answer the door? Would that be you or someone else? A. Whoever got to it first. Q. Who would that be? Would you say Maritsa? A. Typically me or Dana or Maritsa, whoever. Q. Were there times when Dana was in the house back in September of 2015? A. Yes. Q. What about in August of 2015, were there also times where she would be in the house? DEITZ Court Reporting... A Lexitas Company 800-678-0166 SONY_GNL00323999 OF1A_00196524 EFTA01306450 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PNJ NYSCEF DOC. NO. 113 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 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 46 April 9, 2019 GHISLAINE MAXWELL A. Yes. MR. FALLEK: Could I have this marked. ;Whereupon, the diagram of the house was received and marked as Plaintiff's Exhibit 8 for identification, as of this date, by the reporter.) (Whereupon, the diagram of the house was received and marked as Plaintiff's Exhibit 9 for identification, as of this date, by the reporter.) MR. FALLEK: I will show you what was marked as Plaintiff's Exhibit 8. Q. Do you recognize what has been marked as Plaintiff's Exhibit 8 for identification? A. Yes. Q. When you sold the premises, 116 East 65th Street, is this a diagram that was used in order to sell the home? A. I think it was, yes. Q. Do you recognize what is depicted in that diagram? A. Yes. Q. What is it? A. It says office. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324000 EFTA_00I96685 EFTA01306451 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 I S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 47 April 9, 2019 GHISLAINE MAXWELL Q. What is here generally? A. Sorry. Q. What is depicted in the diagram? A. The house. Q. Does it fairly and accurately show the layout of the house, 116 East 65th Street? A. Yes. Q. Did the home have an office in it? A. It was called an office. Q. How big was that area labeled as an office? A. It says here 17.3 feet, 17 feet 3 inches x 8 feet 3 inches. Q. Were there 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 Mack. Q. Was it a laptop or desktop? A. I think it was a desk top. It could have been 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 in 2015. Q. Back in September of 2015, was there a desk DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324001 EFTA_00I96686 EFTA01306452 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 2O 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 48 April 9, 2019 GHISLAINE MAXWELL also in that room? A. Yes. Q. was there a copy machine? A. There may have been. Q. Was there a fax machine? A. No. Q. What other equipment was kept in that office? A. No equipment. I can't remember if it was a laptop or a desktop. Dana -- that's where Dana generally sits. Q. Was there any other office equipment kept in their? A. No. Q. Was there a door to that room? A. Yes. There was also a coffee station. There was a little coffee sink, a little fridge in there for access in the garden. It's like a garden room. You could get a drink if you were sitting in the garden back here. MR. FALLEK: I will show you what was marked as Plaintiff's Exhibit 9 for identification. This is just a blow-up or larger version of Plaintiff's Exhibit 8 for DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324002 EFTA_00I96687 EFTA01306453 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 3 4 5 6 7 6 9 10 11 12 13 14 15 16 17 16 19 20 21 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 49 April 9, 2019 GNISLAINE MAXWELL Identification. Q. Does this fairly and accurately show the layout of the building at 116 East 65th Street as it existed back in September of 2015? A. Yes. Q. Was there any portions or rooms in this building rented out or separated? A. No. Q. Was anything cordoned off? A. No. Q. What was kept in the basement of the building? A. Laundry mostly. Q. What was on the roof of the building? A. Nothing. AC I think. Q. On the first floor there :s also a library? That's what it says. Q. Did you utilize that room as a library? A. No. It was more like 7 use it to watch TV. There was big screen in that room. Q. Was there a room in that building where you stored business records? A. No. Q. Where did you store your business records DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324003 EFTA_00I96688 EFTA01306454 FILED: NEW YORK COUNTY CLERK 03/05/2020 12:59 PPP NYSCEF DOC. NO. 113 1 2 3 4 5 6 7 9 9 10 11 12 13 14 15 16 17 18 19 20 2: 22 23 24 25 INDEX NO. 159224/2016 RECEIVED NYSCEF: 03/05/2020 Page 50 April 9, 2019 GHISLAINE MAXWELL back in 2015? A. I didn't have business records. Q. Where did you keep the records for Climax, 1. A. 1 use to move my -- I had a file cabinet wherever I was sitting. I had a filing cabinet. Q. Where would that be kept? On what floor in the building? A. It moved. I frequently moved my desk. couldn't decide where I would sit. There was a period of time in the dining room became a place where I would sit and the library. When I moved my desk my little filing system cop come with me. Q. Did you conduct business out of 116 East 65th street? A. No. Q. Where did you conduct any business for Ellmax, LLC.? A. I go to any client and I would go to their office. Q. Tell me about your Terramar Projects? A. It's a not-for-profit based on the ocean. Q. When did you form the Terramar Project? A. I think it was in 2011 or 2012. DEITZ Court Reporting... A Lexitas Company 800-678-0166 SDNY_GM_00324004 EFTA_00 I 96689 EFTA01306455