Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - x [REDACTED], Plaintiff, Case No.: 15-cv-07433-RWS -against- GHISLAINE MAXWELL, Defendant. - - - - - x \*\*CONFIDENTIAL\*\* Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Page 2 1 2 APPEARANCES: 3 On Behalf of the Plaintiff: 4 BOIES SCHILLER & FLEXNER, LLP 333 Main Street 5 Armonk, New York 10504 BY: DAVID BOIES, ESQUIRE 6 BOIES SCHILLER & FLEXNER,LLP 401 East Las Olas Boulevard Fort Lauderdale, Florida 33301 8 BY: MEREDITH , ESQUIRE SIGRID McCAWLEY, ESQUIRE SANDRA PERKINS, PARALEGAL 10 JAFFE WEISSING FISTOS & 11 LEHRMAN, P.L. 425 N. Andrews Avenue 12 Fort Lauderdale, Florida 33301 BY: BRAD , ESQUIRE 13 14 PAUL G. CASSELL, ESQUIRE 383 South University Street 15 Salt Lake City, Utah 84112 16 J. STANLEY POTTINGER, PLLC 17 49 Twin Lakes Road South Salem, New York 10590 18 BY: STAN POTTINGER, ESQUIRE 19 On Behalf of Defendant: 20 HADDON 21 Attorneys for Defendant 150 East 10th Avenue 22 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 23 LAURA A. MENNIGER, ESQUIRE 24 Also Present: 25 Page 3 1 2 THE VIDEOGRAPHER: This is DVD No. 3 1, Volume II, of the continued video 4 recorded deposition of Ghislaine Maxwell 5 in the matter against 6 Ghislaine Maxwell, in the United States 7 District Court, Southern District of New 8 York. 9 This deposition is being held at 10 575 Lexington Avenue, New York, New 11 York, on July 22, 2016 at approximately 12 9:04 a.m. 13 My name is Rodolfo Duran. I am the 14 legal video specialist. The court 15 reporter is Leslie Fagin, and we are 16 both in association with Magna Legal 17 Services. 18 Will counsel please introduce 19 themselves. 20 MR. BOIES: This is David Boies, of 21 Boies, Schiller & Flexner, counsel for 22 plaintiff. 23 : Meredith 24 from Boies Schiller & Flexner, counsel 25 for plaintiff. Page 4 MR. Brad , ale, representing the plaintiff, 5 MR. POTTINGER: Stan Pottinger, 6 also representing the plaintiff. 7 MR. CASSELL: Paul Cassell, from 8 Salt Lake City, Utah, also representing 9 10 MR. PAGLIUCA: Jeff Pagliuca and 11 Laura Menninger, on behalf of Ms. 12 Maxwell. 13 And Ms. McCawley has also entered 14 the room, and we have an assistant from 15 Boies Schiller from the Fort Lauderdale 16 office here today as well today. 17 THE VIDEOGRAPHER: Will the court 18 reporter please swear in the witness. 19 GH I SLAINE MAXWEL L, 20 called as a witness, having been duly 21 sworn by a Notary Public, was 22 examined and testified as follows: 23 EXAMINATION BY 24 MR. BOIES: 25 Q. Good morning, Ms. Maxwell. Page 53 1 G. Maxwell - Confidential 2 MR. PAGLIUCA: Why don't we both 3 stop making speeches. 4 BY MR. BOIES: 5 ■ **I I I I • • • • • • • • • • • • • • • • E • • •** Page 54 2 [REDACTED] █ █ █ █ █ █ █ █ █ █ █ █ Page 55 1 G. Maxwell - Confidential 2 Epstein's home in Palm Beach? 3 MR. PAGLIUCA: Objection to form 4 and foundation. II • • • • • • Page 56 1                                  G. Maxwell - Confidential 2[REDACTED] - Barriban County City Bldg. Replacement Contract # [REDACTED] [REDACTED] [REDACTED] [REDACTED] [Redacted] [Redacted] [Redacted text block] [Redacted] [Redacted] **[REDACTED]** Page 571 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A . 8 MR. PAGLIUCA: Objection to form 9 and foundation. 10 A. [Redacted] [REDACTED] [REDACTED] [REDACTED] [REDACTED] [REDACTED] [REDACTED] [REDACTED] [REDACTED] Page 85 1 G. Maxwell - Confidential 2 only area that the witness was precluded 3 from talking about in the first 4 deposition. So that's where we're at. 5 MR. BOIES: I think that directly 6 misreads the judge's order, including 7 where it says: Defendant is ordered to 8 answer questions relating to defendant's 9 own sexual activity with or involving 10 Jeffrey Epstein, with or involving 11 plaintiff, with or involving underage 12 females, involving or including massage 13 with individuals defendant knew to be or 14 believed might become known to Epstein. 15 MR. PAGLIUCA: All of it is 16 preceded by the word sexual activity. 17 MR. BOIES: I think your point of 18 view is an interesting one, but we will 19 see what the judge rules on it. 20 BY MR. BOIES: 21 • • • • Page 86 1 2 and foundation. 3 A. [REDACTED] 8 MR. PAGLIUCA: Objection to form 9                                  and foundation. 10 A. I don't know. 11                      Q.                      Did any of them give you massages? 12                                  A.                                  No. 13 Q. [Redacted] 17 MR. PAGLIUCA: Objection to form 18 and foundation. Asked and answered. 19 A. No. 20           Q.           Were they ever in the Virgin 21 Islands? 22 MR. PAGLIUCA: Objection to form 23 and foundation. 24 A. No. 25 [REDACTED] [REDACTED] Page 871 2 [Redacted] [Redacted text block] 24 MR. PAGLIUCA: Objection to form 25                                 and foundation. Page 88 1                      G. Maxwell - Confidential 2 9      Q.      Were you aware of the presence of 10 sex toys or devices used in sexual activities 11 in Mr. Epstein's Palm Beach house? 14      A.      No, not that I recall. Page 89 2 [Redacted] 3 [Redacted] 4 [Redacted] 5 [Redacted] [Redacted] 6 [Redacted] 7 [Redacted] 8 Q. Do you know whether Mr. Epstein 9 possessed sex toys or devices used in sexual 10 activities? 11 [Redacted] [Redacted] 12 [Redacted] 13 A. No. 14 [Redacted] [Redacted] 15 [Redacted] 16 [Redacted] 17 [Redacted] [Redacted] 18 [Redacted] 19 [Redacted] [Redacted] 20 [Redacted] 21 [Redacted] 22 [Redacted] 23 [Redacted] [Redacted] 24 [Redacted] [Redacted] 25 [Redacted] Page 90 2 Il Page 91 1                                                      G. Maxwell - Confidential 2                                                      it to something in the case. 3                                                      MR. BOIES: I think it's tied, but 4                                                      if you instruct her not to answer, it 5                                                      goes into the -- 6                                                      MR. PAGLIUCA: Meat grinder. 7                                                      BY MR. BOIES: 8                                                      Q. [REDACTED] [REDACTED] [REDACTED] 14                                                      A. Can you repeat the question? 15                                                      Q. [REDACTED] 20                                                      MR. PAGLIUCA: Same objection. 21                                                      A. No. 22                                                      Q. Other than yourself and the blond 23                                                      and brunette that you have identified as 24                                                      having been involved in three-way sexual 25                                                      activities, with whom did Mr. Epstein have Page 92 1                      G. Maxwell - Confidential 2 sexual activities? - [REDACTED]       [REDACTED] - [REDACTED] 5 A. I wasn't aware that he was having 6 sexual activities with anyone when I was with 7 him other than myself. 8                     Q.         I want to be sure that I'm clear. 9 Is it your testimony that in the 1990s and 10 2000s, you were not aware that Mr. Epstein 11 was having sexual activities with anyone 12 other than yourself and the blond and 13 brunette on those few occasions when they 14           were involved with you? 15                     A.                That is my testimony, that is 16 correct. [REDACTED] [REDACTED] [REDACTED] [REDACTED] Page 93 2 [REDACTED] [REDACTED] 3 [REDACTED] [REDACTED] 4 [REDACTED] 5 [REDACTED] [REDACTED] 6 [REDACTED] 7 [REDACTED] 8 [REDACTED] 9 [REDACTED] 10 [REDACTED] [REDACTED] 11 [REDACTED] 12 [REDACTED] 13 [REDACTED] 14 [REDACTED] 15 [REDACTED] 16 [REDACTED] 17 [REDACTED] 18 [REDACTED] 19 [REDACTED] 20 [REDACTED] [REDACTED] 21 [REDACTED] 22 [REDACTED] 23 [REDACTED] 24 [REDACTED] 25 Q. Do you know [REDACTED] Page 112 2 ever see 3 A. I don't recall ever seeing her. 4 Q. 6 A. 7 Q. Did ever engage in any 8 sexual activity with Mr. Epstein? 9 A. I wouldn't know. I would assume 10 not, but I don't know. 11 Q. Do you have any reason to believe 12 that Mr. Epstein engaged in any sexual 13 activity with 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. I wouldn't know. 17 Q. Did you ever give a massage to 18 anyone other than Mr. Epstein at any of Mr. 19 Epstein's properties? 20 A. First of all, I never said I gave 21 Mr. Epstein a massage. 22 Q. I will ask that question if you 23 want, but I was focusing on people other than 24 Mr. Epstein right now. 25 A. I don't give massages. Page 113 2 Q. Let's just tie that down. It 3 your testimony that you've never given 4 anybody a massage? 5 A. I have not given anyone a massage. 6 Q. You never gave Mr. Epstein a 7 massage, is that your testimony? 8 A. That is my testimony. 9 Q. You never gave a 10 massage is your testimony? 11 A. I never gave a 12 massage. 13 Q. Did you, or to your knowledge, 14 Mr. Epstein pay for to go to 15 Thailand? 16 MR. PAGLIUCA: Objection to form 17 and foundation. 18 A. I am not aware. 19 Q. Do you know whether 20 went to Thailand? 21 A. I have no knowledge of anything 22 like that. 23 Q. Did you ever give anyone 24 instructions as to how to give a massage? 25 MR. PAGLIUCA: Objection to form Page 193 2 closed. 3 If there are questions that I have 4 instructed the witness not to answer and 5 it later turns out the judge disagrees 6 with my characterization, we will be 7 back to revisit it, but we are done as 8 far as I'm concerned. 9 MR. BOIES: The deposition is not 10 closed. There are a number of 11 instructions not to answer. I think it 12 is a fair point that if the court were 13 to conclude that none of the questions 14 that have been instructed need to be 15 answered, we're not going to be 16 continuing the deposition, barring some 17 additional information coming to light. 18 MR. PAGLIUCA: I think we agree 19 then. 20 THE VIDEOGRAPHER: The time is 2:51 21 p.m., and we are going off the record. 22 (Time noted: 2:51 p.m.) 23 24 25