Ghislaine Maxwell deposition excerpt on sexual activities at Epstein's homes, 2016

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶

Plaintiff,¶

• against-

Case No.:¶

15-cv-07433-RWS¶

GHISLAINE MAXWELL,¶

Defendant.¶

** 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¶

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APPEARANCES: On Behalf of the Plaintiff: BOIES SCHILLER & FLEXNER, LLP 333 Main Street Armonk, New York 10504 BY: DAVID BOIES, ESQUIRE¶

BOIES SCHILLER & FLEXNER,LLP¶

Fort Lauderdale, Florida 33301 BY: MEREDITH SCHULTZ, ESQUIRE SIGRID McCAWLEY, ESQUIRE SANDRA PERKINS, PARALEGAL¶

FARMER JAFFE WEISSING EDWARDS FISTOS & LEHRMAN, P.L.¶

Fort Lauderdale, Florida 33301 BY: BRAD EDWARDS, ESQUIRE¶

PAUL G. CASSELL, ESQUIRE¶

Salt Lake City, Utah 84112¶

J. STANLEY POTTINGER, PLLC¶

South Salem, New York 10590 BY: STAN POTTINGER, ESQUIRE¶

On Behalf of Defendant:¶

HADDON MORGAN FOREMAN Attorneys for Defendant¶

Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE LAURA A. MENNIGER, ESQUIRE¶

Also Present:¶

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MR. EDWARDS: Brad Edwards, also representing the plaintiff,¶

MR. POTTINGER: Stan Pottinger, also representing the plaintiff.¶

MR. CASSELL: Paul Cassell, from Salt Lake City, Utah, also representing¶

MR. PAGLIUCA: Jeff Pagliuca and Laura Menninger, on behalf of Ms. Maxwell.¶

And Ms. McCawley has also entered the room, and we have an assistant from Boies Schiller from the Fort Lauderdale office here today as well today.¶

THE VIDEOGRAPHER: Will the court reporter please swear in the witness.¶

G H I S L A I N E M A X W E L L, called as a witness, having been duly sworn by a Notary Public, was examined and testified as follows:¶

EXAMINATION BY¶

MR. BOIES: Q. Good morning, Ms. Maxwell. When¶

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2. MR. PAGLIUCA: Why don’t we both stop making speeches.
3. BY MR. BOIES:
4. Q. Ms. Maxwell, let me use the term that your lawyer used of sexual activities.
5. We’ve been talking about intercourse and we’ve been talking about oral sex.
6. Did you engage in any sexual activities with Mr. Epstein other than sexual intercourse and oral sex?
7. MR. PAGLIUCA: Objection to form and foundation.
8. A. Can you ask the question again, please?
9. Q. Sure.
10. Did you engage in any sexual activities with Mr. Epstein other than what you have referred to as sexual intercourse and oral sex?
11. A. No.
12. Q. Did you engage in any sexual activities with anyone other than Mr. Epstein at his home in New York?
13. MR. PAGLIUCA: Objection to form

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2. and foundation.
3. A. No.
4. Q. As you understand the term sexual activities, what does that encompass?
5. A. In what context are you asking?
6. I’m not sure I understand the question.
7. “Sexual activities” meaning kissing or something?
8. Q. Kissing, touching with hands or mouths or other parts of your body.
9. A. That would form sexual activity.
10. Q. Using sexual activity in that sense, did you engage in sexual activities with anyone other than Mr. Epstein at his home in New York?
11. MR. PAGLIUCA: Objection to form and foundation.
12. A. No.
13. Q. Whenever I use the term sexual activities, I will be using it in the way we just defined it. Do you understand that?
14. A. Yes.
15. Q. Did you engage in sexual activities with anyone other than Mr. Epstein at Mr.

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2	Epstein's home in Palm Beach?
3	MR. PAGLIUCA: Objection to form and foundation.
4	A. I did.
5	Q. With whom?
6	A. I don't actually have a name.
7	Q. Did you know the name at the time?
8	A. At the time I did.
9	Q. When was this?
10	A. Sometime in the '90s, the late '90s and early 2000s.
11	Q. Was there more than one person with whom you engaged in sexual activities other than Mr. Epstein at Mr. Epstein's home in Palm Beach? If the question is unclear, I will rephrase it.
12	A. Yes.
13	Q. How many people other than Mr. Epstein were there with whom you engaged in sexual activities at Mr. Epstein's home in Palm Beach?
14	A. A few.
15	Q. How many?
16	A. I don't have a number.

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2	Q. Approximately?
3	A. A few.
4	Q. More than ten?
5	A. A few is a few.
6	Q. Is a few more than ten?
7	A. A few is not more than ten.
8	Q. Is a few more than five, as you use the term?
9	A. No.
10	Q. So it would be fewer than five people?
11	A. It's a few people.
12	Q. But I'm saying, I'm trying to get an understanding of what you mean by a few?
13	A. I understand that.
14	Q. And as you use the term few, can that include more than five people?
15	A. I just said it's five or less and it's a few. I'm not prepared to characterize a number because I just don't have a number.
16	Q. Do you remember the names of any of the people with whom you engaged in sexual activities at Mr. Epstein's home in Palm Beach?

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G. Maxwell - Confidential MR. PAGLIUCA: Objection to form and foundation. A. I do not. Q. Can you describe any of the people with whom you engaged in sexual activities at Mr. Epstein’s home in Palm Beach? MR. PAGLIUCA: Objection to form and foundation. A. The description that I have is somebody who is roughly my age, and I recall a blond and I recall a brunette, and that’s pretty much what I recall. Q. And the people that you recall as people with whom you engage in sexual activities at Mr. Epstein’s home in Palm Beach, male or female or both? A. Female. Q. Where in Mr. Epstein’s home in Palm Beach were you when you engaged in sexual activities with the females that you have referred to? MR. PAGLIUCA: Objection to form and foundation. A. Master bedroom.¶