UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x Plaintiff, -against- GHISLAINE MAXWELL, Defendants. Case No.: 15-cv-07433-RWS \*\*CONFIDENTIAL\*\* x 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 2 APPEARANCES: BOIES SCHILLER & FLEXNER, LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard Fort Lauderdatle, Florida, 33301 BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH , ESQUIRE EMMA , PARALEGAL JAFFE WEISSING FISTOS & 9 LEHRMAN, P.L. Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 11 BY: BRAD , ESQUIRE 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 HADDON 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE 21 Also Present: 22 James Christe, videographer 1 2 3 4 5 6 7 8 THE VIDEOGRAPHER: We are now on the record and recording. This begins disk No. 1 in the deposition of Ghislaine Maxwell in the matter of versus Ghislaine Maxwell in the U.S. District Court for the Southern District of New York. 9 10 11 12 13 Today is April 22, 2016 the time is 9:04 a.m.. This deposition is being taken at 575 Lexington Avenue in New York at the request of Sigrid McCawley of Boies Schiller & Flexner. 14 15 16 17 18 The videographer is James Christe and the court reporter is Leslie Fagin. Will counsel state their appearance and whom they represent and then court reporter swear in Ms. Maxwell. 19 20 21 22 MS. McCAWLEY: My name is Sigrid McCawley with my colleague Meredith We are with Boies Schiller & Flexner. We represent 23 24 MR. : Brad . I also represent 25 MR. CASSELL: Paul Cassell, I also 2 represent 3 MR. PAGLIUCA: Jeff Pagliuca and 4 Laura Menninger on behalf of Ms. S Maxwell. 6 GHISLAINE MAXWELL, 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 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. S 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 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 2 3 Any female under the age of 18, did you invite them to come to Jeffrey's home? 4 5 MR. PAGLIUCA: Object to the form and foundation. 6 7 8 A. Again, as I said, I am not aware of inviting anybody other than friends of mine who have children to the house. 9 10 11 Q. Did you invite to come to Jeffrey Epstein's home when she was under the age of 18? 12 13 MR. PAGLIUCA: Object to the form and foundation. 14 15 16 A. held herself out as a masseuse and invited herself to come and give a massage. 17 18 19 Q. My question is, did you invite when she was under the age of 18 to come to Jeffrey Epstein's home? 20 21 MR. PAGLIUCA: Object to the form and foundation. 22 23 A. Again, was a masseuse -- 24 25 Q. I'm asking not asking if she was a masseuse. I'm asking if you invited her to 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. A. Again, I did not invite 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. 2 A. held herself out 3 Q. I'm not asking how she held herself 4 out. I'm asking how she arrived at the home. S 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. held her to be a 10 masseuse and her mother drove her to the 11 house. 12 Q. When did you first meet 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 20 Q. So you recall 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? 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. S 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 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 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 up to the 25 upstairs location at the Palm Beach house to 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 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 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 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, that 16 you and 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. 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 19 her. I'm making sure the record is clear. 20 21 22 23 MR. PAGLIUCA: Certainly can you apply to have someone come back and the court may or may not have her come back again. 24 25 Again, she is not answering questions that relate to adult consent 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 19 A. I am. 20 Q. Has given a statement 21 to police about you performing sexual acts on 22 her? 23 A. I have not heard that. 24 Q. Has given a statement 25 to police about Jeffrey Epstein performing 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 S 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? 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 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 S 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. 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 S 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 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 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 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 is? 15 A. I do. 16 Q. How do you know him? 17 A. He used to work or still works for 18 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 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 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 , 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 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 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 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 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 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? 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 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. 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 19 20 21 very, very infrequently at the house. So highly unlikely but I was there a couple of days, I just don't know which days it was in relation to the police situation. 22 23 24 Q. Did you have a computer at the Palm Beach home that was a computer that you would use? 25 A. No. 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. 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? 24 A. Again, I have already testified 25 that part of the job that I had was to hire 2 lots of different types of people. In terms 3 4 5 6 7 8 9 10 11 something that was good, I would ask if that 12 man or woman would come back and does home 13 14 15 16 17 of whatever -- very small part of my job, Jeffrey enjoyed getting massages. I think that is something we can all agree in this room and within the context of that, very infrequently I would go to spas and myself happily receive a professional nonsexual massage from a man and/or from a woman and if that massage was something that I thought was visits. If that person said that they did, they would sometimes come, from time to time, not always, come back to the house to perform a nonsexual professional male or female massage. 18 19 instructors you hired under the age of 18? Q. Were any of the exercise 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. 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? 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 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. 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 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 II 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. 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? 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 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, 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? 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? 24 A. Can you ask it a different way? 25 Q. Did Jeffrey Epstein have a scheme 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 a 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? 24 A. What are you talking about? 25 Q. Sure. Would Jeffrey Epstein's 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? 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. 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 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 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 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