From: Si ’d McCawle

To:

Subject: Date: FW: Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version) Mon, 23 Mar 2020 21:28:16 +0000

Attachments: Maxwell_Dep.Tr.(Slip_and_Fall_Case).pdf

Inline-Images: image009.png; image022.png; image037.png; image064.png; image008.png; image001jpg; image002.jpg; image003.jpg; image004.jpg; image005.jpg; image006.jpg; image007.jpg; image010.jpg; image01 1.jpg; image012.jpg; image013.jpg; image014.jpg; image015.jpg; image016.jpg; image017.jpg; image018.jpg; image019.jpg; image020.jpg; image021.jpg; image023.jpg

my paralegal found this. Not sure if you have it so I wanted to pass it along. It’s a 2019 depo of Maxwell in a slip and fall case in NYC. There are some clips below and the full version is attached.

Best, Sigrid

Sigrid McCawley

Partner

BOIES SCHILLER FLEXNER LLP

on au er ae.

From: Sandra Perkins Sent: Monday, March 23 2020 5:13 PM To: Sigrid McCawley Sabina Mariella Subject: Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version)

Ghislaine Maxwell Deposition Transcript in slip and fall case (readers digest version)

Note the File # has an AIG PRIV prefix (this has to mean that AIG is her insurance carrier on this case).

	SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

	SHELDON BARR and THOMAS GARDNER,
	Plaintiffs,
-against
CITY OF NEW YORK and


	Defendants,
INDEX NO.:	159225/2010



	New York, New York
	April 9, 2019
	10:07 a.m.

	EXAMINATION BEFORE TRIAL of the Defendant,
	by GNISLAINE MAXWELL, iN
	the above-entitled action, held at the above time
	and place, taken before a Notary Public of the State
	of New York, pursuant to Order and Stipulations
r

Page 9 (Primary residence as of 9/2015 NY)

Q. What was your primary residence back in September A. of 2015? Q• Can you tell me how much time you spent there, say, back in 2015 from January 1st through September 9, 2015? A. A lot of time. I lived there. That’s my primary residence.

Page 10 (Maxwell is a US Citizen as well as citizen of France and England)

Q. A. Where were you born? Paris, France. Q. What is your date of birth? A. Q. Are you a U.S. Citizen at this time? A. Yes. Q. When did you become a U.S. Citizen? A. I don’t recall. But it was some time in late ftember. ’90s, mid ’90s. I’m not sure. I don’t Q. Are you a citizen of any other country? A. Yes. 0. What other countries? A. France and England.

Page 11 Education and Licenses

Q. Do you have any professional degrees or licenses? A. I do. Q. In what? A. I’m a registered emergency technician, first responder, EMT. I’m a helicopter pilot. Q. Sorry? A. Helicopter pilot. Q• Is your certification as an EMT in the United States or another country?

A. In the U.S.

Page 12 - Ellmax

	What is Ellmax? Q.
11	It’s no longer in existence. A.
12	Q. What was it?
13	It was a company I started to advise othe: A.
14	businesses on board placement, placing board of
	directors, and any other questions they might have,
	conferences, locations for conferences, speakers at
17	conferences.
18	Q. What is the primary business? Is it
19	Ellmax, LLC.?
20	I think so. A.
21	Q. Is that a Florida Limited Liability
22	Company?
23	Whatever paperwork I have. A. I don’t recal_.
	Whatever it says on the paperwork.

Page 16 — Maxwell paid (Proof of payments?) personal assistant for more than 10 years (beginning 2001 or 2002) and herself not through Ellmax.

GHISLAINE MAXWELL.

Page 18 (Ellmax Florida Corporation — Maxwell stated that she lived in number of place in Florida)

9	C.	Was there a reason you chose a Florida
10		ILmited Liability Company for Ellmax, LAC.?
11	A.	I don’t know why. I don’t remember.
12	Q.	Were you also a Florida resident back in
13	2016?
14	A.	1 lived in Florida at certain times since 2
15		-2ved to the states.
IC.	2.	What is your address In Florida?
	A.	7 lived in a number of different places in
IR	’lorida.
19	Q.	Do you own real estate in Florida?
2C	A.	No.
21	Q.	At any point did you maintain a residence
22	_n Florida?
23	A.	I’ve never owned a home in Florida.
24	u.	Dad you rent the sane residence in Florida?
2S	A.	No.

Page 23 (Communicated with her personal assistant via email, text or phone) Where are the records?

Page 25: Darren Indyke helped Maxwell create Ellmax

April 9, 2019

		GHISLAINE MAXWELL
2	Q.	Was there ever any other members?
3	A.	1 don’t believe so.
4	Q.	Could you tell me who Darren Indyke, Esq.
S	a	New York. New York is? Could
6		you tell me who he is?
	A.	He is a :awyer.
	O.	What :r his connection with the LLC?
	A.	Me helped create tt.
IJ	Q.	Did you hire him to create it?
11	A.	I don’t recall how tt went down exactly.
12		How he came to do it. But, he was the lawyer. Aryl
13		•.a helped create tt.
14	Q.	Was he referred to you by somebody?
15	A.	Ho worked tor a friend of mine.
16	Q.	Who is that?
17	A.	A gent:Almon called Mr. Spinel:—

Page 31 (Miami Beach address in 2014)

		What is the address at
		Miami Seach, Florida 33139?
11	A.	That was a home that i rented !or a short
12		while, and I stayed at the address.
13	0.	When did you rent it?
14	A.	I don’t rota:: tne dates. 1 am sorry.
15	0.	Was it in the year 2014.
16	A.	I honestly don’t remember.

:1	Q. Was that based on your accountant or a
12	legal advise or on your own?
13	I’m sure that was based on legal advise. A.
14	Q. Did you have a lawyer that formed it for
15	you?
16	You are asking things to go hack over 20 A.
17	I don’t recall exactly how it went. down. years.
lE	Q. Did you utilize the services of a broker
:9	purchasing
20	A. I don’t remember.
21	Q. Did you ut I re the services of a broke•(
22	when se:ling
23	1 did. A.
24	D. Was that Douglas Elliman?
	It was. A.

Page 40 (Odd that she says not married at the time … could she be married now)?

April 9, 2019

1		GHISLAINE MAXWELL
2	A.	No.
3	Q.	Who lived in Or.
4		September 9, 2015?
5	A.	Excuse me?
6	Q.	Are you married?
7	A.	I was not married at the time of this.
8	Q.	Do you have any chi:dren?
9	A.	No.
10	Q.	Did you have any help that lived in the
11	house with you?
12	A.	No.
13	Q. Did you have a housekeeper?
14	A. I did have a housekeeper, yes.
15	Q.	Live out or live in?
16	A.	Out.

Page 47 (says she used a MAC or laptop in 2015) (for ESI)

15	Q.	Were thorn computers kept in that office?
16	A.	There was a computer in that office.
17	Q.	What kind of computer was it?
18	A.	I think it was a Hock.
19	O.	Was it • laptop or desktop?
70	A.	I think it was • desk top. It could :olive
2:	boon a laptop.	I don’t know.
22	Q.	Who owned that desktop?
23	A.	Well, If it was a desk top it would have
24	been me.	Actually I think it was laptop an 201’, .
	Q.	back in September of 2015, was there a desk

Maxwell had a filing cabinet (hard copy records)

I didn’t have oustnoss recoros. C. Where did you keep the records for Ellhax. A. I use to move my : had a file cabinet wherever I was sitting. 1 had a filing cabinet. Q• Where would that be kept? Cn what floor 1 the building? A. It moved. I frequently moved riy desk. couldn’t decide where I woulc sit. Tnere was a period of time in the dining room became a place where I would sit and the library. When I moved ny desk my little filing system cop come with me.

Page 52-53 (Tax returns reflect Maxwell claiming to work 60 hour weeks for Terramar)

S00-678-0166

Page 54-55 Claims only “contract contractors” who paid for work — but she and other board members did not receive compensation.

DFITZ Court Reporting… A Lexitas Company 803-678-0166

	YORK COUNTY CLERK 03/05/2020 12:59 P$ INDEX NO. 159224/201G
. 113	RECEIVED ?NEGEV: 03/05/2020 Page 55 April 9, 20:9
	GRISLAINE MAXWEtt
2	cher. were :enumerated. Nobody was paid. But,
3	Terramar Project did have work called contract
4	contractors who did do work for it. A contract
5	employee or contract person that worked for tne
	company is not the same as a regular employee. The.:
	wouldn’t come to work.
B	O. Who was that?
	A. I have had a number of – I had a number of
	different people. We also have one person who did
	work for Terramar Project. They were always
	()trait*, beCadae they would never come to work.
	They would be remote.

Page 55: Robert Foos was a contracted employee for Terramar (Director of Development) Who paid him?

	in 2015 for Terramar Prolocc, Inc.?

A.	There were, yes.
Q.	Who were they?
A.	One. I believe It was Robert Foos.
D.	In what position did he hold?
A.	I think his official title was Director
Covelopment.
0.	Coos the additiona_ data sheet indicate
	that you were also working 60 hours a week for
	Terramar Project back in 2013?
A.	Yes.

DEITZ Court Report1mg… A Lexitas Company 800-6/8-0166

YORK COUNTY	crairanvomunxis	-	tng	INDEX NO. 259224/2016
				RECRIVED NTSCRF: 03/05/2020 ?age 56 April 9, 20:9
	GH1SLAINE

Page 57-58 (Mark, Paneth & Shron prepared her taxes for Terramar)

23	Q.		accountant that prepared it Mark,
24	Paneth c Shron,	LLP.,	New York,
25	New York 130017,		as indicated on Plaintiff’s Exhibit

DEITZ Court Reporting… A Lexitas Company 800-678-0166

YORK	COUNTY	CLERIC	61/015/2020	12:59	INDEX NO.
113					RECEIVED NYSCEF: Page 58 April 9, 2319
1				CHISLAINE MAXWELL
2	10?
3	A.		It may have been.
4	Q.		Were they your accountants?
5	A.	They were.
6	Q.		Do they always tile your personal tax
	returns		and the tax returns for the Terramar
8	Project?

Page 66 (Discussed deed being titled as

15	2000, do you Q. When it was purchased in
16	recall if you purchased it using
:7	LLC.?
18	A. I believe I did.
19	Were you the sole member of Q.
20	LLC.?
21	A. Yes.
22	Were you advised either by a lawyer or an Q.
23	accountant to purchase the home through an LLC?
24	A. I don’t recall, but I’m sure I was.

NO. 113 RECEIVED NYSCEF: Page 7C April 9, 2019 03/05/2020

1	GHISLATNE MAXWELL
2	When in town is that where you would sleep? Q.
3	A. Yes.
4	Q. You had your master bedroom in the house at
5
6	A. Yes.
	O. That was all the time between 2000 thru
8	2016?
9	A. Yes.
10	Q. With respect to the Terramar Project, did
11	you ever collect or have you ever collected any
12	salary as the president of the Terramar Project?
13	A. No.
Page 73-74
14	Q. Have you received any remaavrat ion of uny
15	kind from the Terramar Project for your servic’• for
16	that not-for-profit entity?
17	No. A.
18	Is there any place in the home, at Q.
19	that is set aside for use solely by the

20 Terramar Protect?

21 A. No.

DEITZ Court Reporting… A Lexitas Company 800-678-0366

	YORK COUNTY CLERK 03/05/2020 12:59 RI	INDEX NO. 159:
. 113		RECEIVED NYSCEF: 03, Page 74
		April 9, 2019
1	GHISLAINE MAXWELL

Q. DId you ever had them come to your

business, to to do that work?

1				GHISLAINE MAXWELL
2					did you work with them at their premises?
3	A.	Yes.

A. No.

	Q. During the period of tire that Ellmax
	functioned, did it generate revenue?
	A small amount.
10	Q. Did you ever collect a salary for Ellmax?
11	A. No.
12	Were you ever disbursed any profits from Q.
13	Ellmax?
14	A. No.
15	Q. What happened to the revenue that Ellmax
16	generated during that period of time, from 2010 to
:7	2013?
18	A. It dust was used to deter cost such as
19	traveling and travel mostly.
20	Q. What were the costs of travel related to
21	Ellmax where you were going?
22	Sorry, most of the corpanies I would have A.
23	worked for were from Los Angeles. I went to LA and
24	also to London multiple times.

Page 76-77 (Monte Albers De Leon closing lawyer for house/Maxwell did not attend closing).

DEITZ Court Reporting… A Lexitas Company 800-678-0166

		INDEX NO. 159224/: YORK COUNTY CLERK 03 /05/2020 12:59 PX
. 113		RECEIVED NYSCEF: 03/05/: Page 77
		April 9, 2019

1		GHISLAINE MAXWELL
2	A.	The lawyer that is on that. I don’t
3		remember his name. Monte Albers De Leon.
4	Q.	Who is he? Is he your lawyer?
	A.	He was a lawyer that I used.

Sandra Perkins Borger

Case Manager

BOIES SCHILLER FLEXNER LLP

The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that. among other protections, is the subject of attorney-client privilege. attorney work product or exempt from disclosure under applicable law. lithe reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination. distribution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error. please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1 08201831859