Draft: efta02783436

EXHIBIT 6¶

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.¶

5 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 of is that in a response, you can't give a¶

3 nonverbal response, in other words, nodding a¶

4 yes or no, they need to hear verbal response¶

5 so they can record it on their transcript.¶

6 So that's important for you to remember as we¶

7 go through the day. If you forget, I will be¶

8 sure to remind you.¶

9 Is there anything that would¶

10 prevent you from giving truthful testimony¶

11 today?¶

12 A. There is not.¶

13 Q. You are not on any medications or¶

14 anything that would inhibit your ability to¶

15 remember or give truthful testimony?¶

16 A. I am not.¶

17 MR. PAGLIUCA: Could you identify¶

18 the assistant in the room.¶

19 MS. McCAWLEY: This is Emma¶

20 from our New York office. She is a¶

21 paralegal.¶

22 Q. Ms. Maxwell, can you please state¶

23 your address for the record?¶

24 A. Currently¶

25 Q. What is your date of birth?¶

2 A.¶

3 Q. When did you first recruit a female 4 to work for Mr. Epstein?¶

S MR. PAGLIUCA: I object to the form 6 and foundation of the question. I 7 believe this is confidential 8 information. I ask anyone who is not 9 admitted in this case be excused from 10 the room, please.¶

11 MS. McCAWLEY: So the response to 12 that question would¶

13 MR. PAGLIUCA: The subject matter 14 of this question is confidential and I'm 15 designating it as confidential.¶

16 MS. McCAWLEY: I just want to make 17 that clear for the record.¶

18 MR. : So we don't delay the 19 deposition I will step out of the room 20 but I think it's important to lay the 21 record that --¶

22 MR. PAGLIUCA: I'm sorry, you are 23 not admitted in this proceeding so you 24 are not entitled to make any record. If 25 Ms. McCawley wants to make a record she¶

1 2 G Maxwell - Confidential can.¶

3 4 MR. : I can make a record right now.¶

5 6 7 MR. PAGLIUCA: Maybe we should get the judge on the phone and talk about it.¶

8 9 10 11 12 13 14 15 16 17 MR. : The record will be short. This is the precise reason why wants me in this case and I'm unable to effectively represent her at this time because I am unable to have access to the confidential information which includes apparently the entire deposition of Ms. Maxwell. But for the sake of not further delaying this, I will be outside the room.¶

18 MS. McCAWLEY: Thank you.¶

19 20 A. I would like to just -- wait for him to leave.¶

21 Q. That's fine.¶

22 23 24 25 A. I would just like to clarify the address. I'm in the process of selling the house so while while I still receive mail there, it's not my actual physical address.¶

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.¶

5 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 hired someone to work for Mr. Epstein, a¶

3 female?¶

4 A. As best as I can recollect, a woman¶

5 the age probably of about 40 or 50 was in¶

6 sometime in 1992.¶

7 Q. How long did you work for Mr.¶

8 Epstein?¶

9 A. I started working for him at some¶

10 point in 1992 and the nature of my work¶

11 relationship with him changed over time so¶

12 from around 2002, 2003, the work lessened¶

13 considerably.¶

14 Q. When did you --¶

15 MR. PAGLIUCA: Can I interject for¶

16 a moment. If we are talking about¶

17 background --¶

18 MS. McCAWLEY: I'm in the middle of¶

19 a question. Let me finish it and then¶

20 can you interject.¶

21 Q. When you say 2002 to 2003 that the¶

22 work lessened, when did you complete working¶

23 for Mr. Epstein; when was the last time you¶

24 were employed by him, the last date?¶

25 A. I believe I still was doing --¶

1 G Maxwell - Confidential 2 helping him in a very nominal way, maybe an 3 hour or two a year at sometime 2008 and 2009.¶

4 MR. PAGLIUCA: So if you are going 5 to be talking about general background, 6 I don't need to designate that as 7 confidential. So if you want to have 8 them come back in, that's fine.¶

9 I assumed by your first question 10 you were going into more sensitive 11 areas. I will leave it up to you, but 12 if this is general background it will 13 not be designated as confidential.¶

14 MS. McCAWLEY: I appreciate that. 15 I will jump back into my other 16 questions.¶

17 MR. PAGLIUCA: So we will keep it 18 as confidential.¶

19 Q. When you were first employed by him 20 in 1992, what were you hired to do?¶

21 A. First, I was consulting and what I 22 did was I helped with decorating houses and 23 in hiring staff to help run those houses.¶

24 Q. Did your duties change over the 25 course of 1992 to 2009?¶

2 3 MR. PAGLIUCA: Object to the form and foundation.¶

4 S 6 7 8 9 10 11 12 A. My job entailed running the homes that he had but much more importantly, most of the houses had construction and so whilst in 1992 there was no construction project, there was construction projects that began after that time and I was in charge not only of hiring architects, I was also in charge of all the filings or overseeing that, like a general contractor would.¶

13 14 15 16 17 18 19 20 21 I also helped with hiring the architects, hiring the builders, reviewing the contracts for the builders, coordinating the building projects, coordinating how the projects would layout, the timing of the projects and all the various materials that they would require to run a very substantial building project. That's the nature of the job I was dealing with.¶

22 23 Q. How old was the youngest female you ever hired to work for Jeffrey?¶

24 25 MR. PAGLIUCA: Object to the form and foundation.¶

2 Q. You can answer.¶

3 A. I have not any idea exactly of the 4 youngest adult employee that I hired for 5 Jeffrey.¶

6 Q. When you say adult employee, did 7 you ever hire someone that was under the age 8 of 18?¶

9 A. Never.¶

10 Q. Did you ever bring someone who was 11 under -- invite someone under the age of 18 12 to Jeffrey's home, any of his homes?¶

13 MR. PAGLIUCA: Object to the form 14 foundation.¶

15 A. Can you repeat the question?¶

16 Q. Did you ever invite anybody who was 17 under the age of 18 to Jeffrey's homes?¶

18 MR. PAGLIUCA: Same objections.¶

19 A. I have a number of friends that 20 have children and friends of mine that have 21 kids and in the invitation of my friends and 22 their kids, I'm sure I may have invited some 23 of my friend's kids to come.¶

24 Q. Anybody that is not a friend of 25 yours.¶

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.¶

5 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¶

_4 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.¶

5 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 meet Mr. Epstein?¶

3 MR. PAGLIUCA: Object to the form¶

4 and foundation.¶

5 Q. You can answer.¶

6 A. I just explained.¶

7 A. I spent the entire time talking to¶

8 Virginia's mother outside the house so the¶

9 answer to the question is no.¶

10 Q. No, did you not walk her up and¶

11 introduce her to Mr. Epstein?¶

12 A. I just said no.¶

13 Q. Did you participate in a massage¶

14 this first time when she first came to the¶

15 home and you were speaking with her mother,¶

16 she was in the home, is that correct, you¶

17 brought her into the home?¶

18 MR. PAGLIUCA: Object to the form¶

19 and foundation.¶

20 A. I will repeat again, I was standing¶

21 outside with her mother so very difficult for¶

22 me to do anything else at that time so no, I¶

23 did not take her upstairs.¶

24 Q. Did you participate --¶

25 A. Virginia lied 100 percent about¶

2 absolutely everything that took place in that¶

3 first meeting. She has lied repeatedly,¶

4 often and is just an awful fantasist. So¶

5 very difficult for anything to take place¶

6 that she repeated because I was with her¶

7 mother the entire time.¶

8 Q. So did you have did you give a¶

9 massage with and Mr. Epstein¶

10 during the first time was at¶

11 the West Palm Beach house?¶

12 MR. PAGLIUCA: Object to the form¶

13 and foundation.¶

14 Q. Yes or no?¶

15 A. No.¶

16 Q. Have you ever given a massage with¶

17 in the room and Jeffrey¶

18 Epstein?¶

19 MR. PAGLIUCA: Object to the form¶

20 and foundation.¶

21 A. No.¶

22 Q. Have you ever given Jeffrey Epstein¶

23 a massage?¶

24 MR. PAGLIUCA: Object to the form,¶

25 foundation. And I'm going to instruct 1 2 3 4 S 6 7 G Maxwell - Confidential you not to answer that question. I don't have any problem with you asking questions about what the subject matter of this lawsuit is, which would be, as you've termed it, sexual trafficking of¶

8 9 10 11 12 13 14 15 To the extent you are asking for information relating to any consensual adult interaction between my client and Mr. Epstein, I'm going to instruct her not to answer because it's not part of this litigation and it is her private confidential information, not subject to this deposition.¶

16 17 18 19 20 21 22 23 24 MS. McCAWLEY: You can instruct her not to answer. That is your right. But I will bring her back for another deposition because it is part of the subject matter of this litigation so she should be answering these questions. This is civil litigation, deposition and she should be responsible for answering these questions.¶

25 MR. PAGLIUCA: I disagree and you¶

2 understand the bounds that I put on it.¶

3 MS. McCAWLEY: No, I don't. I will¶

4 continue to ask my questions and you can¶

S continue to make your objections.¶

6 Q. Did you ever participate from the¶

7 time period of 1992 to 2009, did you ever¶

8 participate in a massage with Jeffrey Epstein¶

9 and another female?¶

10 MR. PAGLIUCA: Objection. Do not¶

11 answer that question. Again, to the¶

12 extent you are asking for some sort of¶

13 illegal activity as you've construed in¶

14 connection with this case I don't have¶

15 any problem with you asking that¶

16 question. To the extent these questions¶

17 involve consensual acts between adults,¶

18 frankly, they're none of your business¶

19 and I will instruct the witness not to¶

20 answer.¶

21 MS. McCAWLEY: This case involves¶

22 sexual trafficking, sexual abuse,¶

23 questions about her having interactions¶

24 with other females is relevant to this¶

25 case. She needs to answer these¶

2 questions.¶

3 MR. PAGLIUCA: I'm instructing her¶

4 not to answer.¶

S MS. McCAWLEY: Then we will be back¶

6 here again.¶

7 Q. Have you ever given a massage to¶

8 Mr. Epstein with a female that was under the¶

9 age of 18?¶

10 A. Can you repeat the question?¶

11 Q. Yes. Have you ever given a massage¶

12 to Mr. Epstein with a female that was under¶

13 the age of 18?¶

14 A. No.¶

15 Q. Have you ever observed Mr. Epstein¶

16 having a massage given by an individual, a¶

17 female, who was under the age of 18?¶

18 A. No.¶

19 Q. Have you ever observed females¶

20 under the age of 18 in the presence of¶

21 Jeffrey Epstein at his home?¶

22 MR. PAGLIUCA: Object to the form¶

23 and foundation.¶

24 A. Again, I have friends that have¶

25 children¶

2 Q. I'm not talking about friends. I'm 3 talking about individuals --¶

4 MR. PAGLIUCA: I'm going to object S to you interrupting the witness who was 6 answering your question. The question 7 was, have you ever seen anyone, female 8 under the age of 18 at the house and 9 that's the question she was answering.¶

10 If you want to strike that question and 11 ask another question, feel free, but let 12 the witness respond, please.¶

13 MS. McCAWLEY: I will do that.¶

14 Q. Have you ever observed a female 15 under the age of 18 at Jeffrey Epstein's home 16 that was not a friend, a child -- one of your 17 friend's children?¶

18 A. Again, I can't testify to that 19 because I have no idea what you are talking 20 about.¶

21 Q. You have no idea what I'm talking 22 about in the sense you never observed a 23 female under the age of 18 at Jeffrey 24 Epstein's home that was not one of your 25 friend's children, is that correct?¶

2 MR. PAGLIUCA: Object to the form 3 and foundation.¶

4 A. How would I possibly know how 5 someone is when they are at his house. You 6 are asking me to do that. I cannot possibly 7 testify to that. As far as I'm concerned, 8 everyone who came to his house was an adult 9 professional person.¶

10 Q. Are you familiar with the police 11 report that was issued in respect to the 12 investigation in this matter?¶

13 MR. PAGLIUCA: Object to the form 14 and foundation.¶

15 Q. Are you familiar with the police 16 report that was used in this matter, the 17 investigation of Jeffrey Epstein, has been 18 produced as a document in this matter?¶

19 A. I have seen a police report. 20 (Maxwell Exhibit 1, police report, 21 marked for identification.)¶

22 Q. The police report that you have in 23 front of you, can you turn to page 28 of that 24 report, the numbers are on the top right-hand 25 corner.¶

2 You will see some redactions in 3 this report, Ms. Maxwell, the redacted 4 information is redacted because it reveals 5 the name of a minor, someone who is under the 6 age of 18.¶

7 On page 28, in the third paragraph, 8 about halfway down, it says, stated 9 she performed the massage naked. At the 10 conclusion of this massage, Epstein paid 11 $200 for the massage. He explained, I 12 know you are not comfortable put I will pay 13 you if you bring some girls. He told her the 14 younger the better. stated once tried 15 to bring a 23 year old to Epstein and he 16 stated the female was too old.¶

17 Have you heard Mr. Epstein use the 18 phrase the younger the better?¶

19 A. I have no recollection of hearing 20 that.¶

21 Q. Have you used the phrase in talking 22 to and asking her to recruit 23 females for Mr. Epstein, the younger the 24 better?¶

25 MR. PAGLIUCA: Object to the form¶

2 and foundation of the question.¶

3 A. First of all, can you break the¶

4 question apart.¶

5 Q. Have you used the phrase the¶

6 younger the better in speaking to¶

7 and asking her to recruit females for Jeffrey¶

8 Epstein?¶

9 MR. PAGLIUCA: Object to the form¶

10 and foundation.¶

11 Q. You can answer. It's yes or no.¶

12 A. No, that's absolutely not true, on¶

13 the second part of your question, I have not¶

14 asked Virginia to recruit females and the¶

15 first part of your question, if you can¶

16 repeat that again, the question you asked.¶

17 Q. Will you read back the question.¶

18 (Record read.)¶

19 A. I believe I answered the later part¶

20 of the question. The first part of the¶

21 question, it's impossible for me to recall¶

22 events that took place 16 years ago but it¶

23 doesn't sound like something I would say.¶

24 Q. On page 28, that same paragraph,¶

25 was asked how many girls in total she¶

2 brought to Epstein. stated that she¶

3 can remember, stated that she brought¶

4 and, it's redacted there, and the victim in¶

5 this case.¶

6 Let me ask my question, I have a¶

7 question pending right now.¶

8 Are you testifying that you are¶

9 unaware of any underage, under the age of 18,¶

10 females coming to Jeffrey Epstein's home to¶

11 perform massages?¶

12 MR. PAGLIUCA: Object to the form¶

13 foundation.¶

14 A. You need to straddle that question¶

15 in a different time period. When I was¶

16 there, at the time I was present, the people¶

17 that gave Jeffrey, men and women who gave¶

18 Jeffrey massages were adults over the age of¶

19 18.¶

20 Q. Never in your time at any of¶

21 Jeffrey Epstein's homes were you present when¶

22 a female under the age of 18 was there to¶

23 give Jeffrey Epstein a massage?¶

24 MR. PAGLIUCA: Object to the form¶

25 and foundation.¶

2 A. First of all, as I said when I was¶

3 present --¶

4 Q. It is a yes or no.¶

5 A. No, it is not.¶

6 Q. You can answer the question in full¶

7 but please provide yes or no as an initial¶

8 matter.¶

9 A. I cannot answer yes or no, it's not¶

10 bounded by time. It's entirely possible I¶

11 could have been in a room or even in the¶

12 vicinity of Palm beach when somebody came and¶

13 I would not know. How would I know when¶

14 somebody was in the house. There is no way I¶

15 can know.¶

16 Q. Did you stay at Jeffrey Epstein's¶

17 home when you were in Palm Beach?¶

18 A. Most of the time.¶

19 Q. So how is it that you wouldn't know¶

20 if there was a female in the home under the¶

21 age of 18 if you were staying there?¶

22 A. Well, first of all, when I was¶

23 staying there, the house is actually quite¶

24 large and I have a very busy job and I had an¶

25 office with a door so the door would be shut¶

2 and I would be working. I'm not responsible 3 for what Jeffrey does and I don't always pay 4 attention to what happens in the house. I'm 5 very busy.¶

6 Q. So you're testifying that you never 7 observed a female under the age of 18 at¶

8 Jeffrey Epstein's West Palm Beach home?¶

9 MR. PAGLIUCA: Object to the form 10 and foundation.¶

11 A. I already answered that question, I 12 believe.¶

13 Q. You didn't answer my question.¶

14 A. I did.¶

15 Q. Did you observe a female under the 16 age of 18 at Jeffrey Epstein's home in Palm 17 Beach?¶

18 A. Like I said, I work, I don't sit 19 there and watch people coming in and out of 20 the house. I cannot possibly tell you if I'm 21 in the home that somebody was there that I 22 did not see, I cannot comment on it, I have 23 no idea.¶

24 Q. Did you observe females at Jeffrey 25 Epstein's home that were laying out topless¶

2 in the back of the home, in other words¶

3 without a shirt on?¶

4 A. So that's just another of¶

S Virginia's lies. So let's be clear, at the¶

6 time when I was there and present, frequently¶

7 at the house, it was unusual to see people¶

8 without their clothes on.¶

9 Q. When you say unusual, did you¶

10 observe people without their clothes at¶

11 Jeffrey Espstein's home?¶

12 A. Can I answer. Sometimes people in¶

13 the privacy of a house and swimming pool, I¶

14 have seen people from time to time take their¶

15 top off. I have seen people from time to¶

16 time do that. Very unusual. Naked people¶

17 around the people at any frequent period of¶

18 time, I have never seen.¶

19 Q. Were they under the age of 18?¶

20 A. As I was saying, people when I was¶

21 in the house, were of adult age, if they were¶

22 children, friends of my family or friends¶

23 that were there, they may well have been¶

24 because I have nieces and nephews under the¶

25 age of 18, I cannot testify to anybody else¶

2 just another one of Virginia's many¶

3 fictitious lies and stories to make this a¶

4 salacious event to get interest and press.¶

5 It's absolute rubbish.¶

6 Q. Were you in charge of hiring¶

7 individuals to provide massages for Jeffrey¶

8 Epstein?¶

9 A. My job included hiring many people.¶

10 There were six homes. As I sit here, I hired¶

11 assistants, I hired architects, I hired¶

12 decorators, I hired cooks, I hired cleaners,¶

13 I hired gardeners, I hired pool people, I¶

14 hired pilots, I hired all sorts of people.¶

15 In the course and a very small part¶

16 of my job was from from time to time to find¶

17 adult professional massage therapists for¶

18 Jeffrey.¶

19 Q. When you say adult professional¶

20 massage therapists, where did you find these¶

21 massage therapists?¶

22 A. From time to time I would visit¶

23 professional spas, I would receive a massage¶

24 and if the massage was good I would ask that¶

25 man or woman if they did home visits.¶

2 Q. Did you ever hire a masseuse that 3 was under the age of 18?¶

4 MR. PAGLIUCA: Object to the form 5 and foundation.¶

6 Q. Did you?¶

7 A. Again, I don't hire massage¶

8 therapists, so that was not my job.¶

9 Q. You just said you did, you just 10 said you hired massage therapists for Jeffrey 11 Epstein, I'm asking if you hired a massage 12 therapist who was under the age of 18?¶

13 A. Let me correct myself. When I 14 meant hire, I didn't mean hire in the way you 15 are doing it. What I say is that I went to 16 spas and I met people and if they did home 17 visits, Jeffrey would then, in fact, hire 18 them. I'm not responsible for hiring 19 someone. And they were not full-time, so 20 it's not a correct characterization.¶

21 Q. Did you ever, your term is meet, 22 did you ever meet a person that was under the 23 age of 18 that you -- that Jeffrey then hired 24 as a masseuse?¶

25 MR. PAGLIUCA: Object to the form¶

2 and foundation.¶

3 A. First of all, who¶

4 you are referring to was a masseuse aged 17,¶

S we all now know, so your story that you keep¶

6 pushing out to the press that she was a 15¶

7 year old -- you and I both know was a lie,¶

8 correct.¶

9 Q. You are not sentencing my question.¶

10 A. You and I both know that was a lie,¶

11 correct.¶

12 Q. You are not answering my question.¶

13 I'm asking you whether you ever met a female¶

14 under the age of 18 that Jeffrey then hired¶

15 as a masseuse?¶

16 MR. PAGLIUCA: Object to the form¶

17 and foundation.¶

18 A. The only person I can talk about¶

19 who clearly was a massage age 17, a masseuse,¶

20 was Virginia.¶

21 Q. Did you meet her and then introduce¶

22 her to Jeffrey?¶

23 A. I don't know. I already testified¶

24 I don't recall meeting her.¶

25 (Maxwell Exhibit 2, email, marked¶

2 for identification.)¶

3 4 5 6 7 8 9 10 11 12 Q. So I'm showing you a document that we have marked as Maxwell Exhibit 2. It's a document you produced in this matter labeled confidential GM 00109. It's dated Sunday June 12, 2011. It's from Jeffrey Epstein to you. If you can turn to page 4 -- sorry, can you turn to the first page, the cover page initially which is 00109. If you look under the time stamp it says, June 12, 2011 at 4:12 p.m., it says¶

13 Is that your email address?¶

14 A. It is.¶

15 16 17 18 19 Q. Under that it says, Thank you. I have it now and I'm working on a letter, a little, I will send the final version tomorrow and what ever it is will be factually accurate.¶

20 Do you see that on page 1?¶

21 A. I do.¶

22 23 24 25 recall that I first met Q. Then I would like you to turn to page 4 please. The second paragraph down on page 4, it states, After some thought, I when she¶

2 3 was working at a premier resort claiming to be 18 years old and a professional masseuse?¶

4 5 MR. PAGLIUCA: What line are you on, counsel.¶

6 7 down. MS. McCAWLEY: Second paragraph¶

8 MR. PAGLIUCA: I got it.¶

9 Q. Is that a statement that you wrote?¶

10 A. It appears to be.¶

11 Q. 12 that you did meet So does that correct your testimony at Mar-a-Lago?¶

13 14 A. Again, this was written in, when were you saying?¶

15 Q. 2011.¶

16 17 18 19 20 21 A. So by 2011, had already perpetrated so many lies and stories it's hard for me to accurately tell you today what I remember back then. As I sit here today, the testimony I give you today, I do not recollect it.¶

22 Q. 23 this Do you have a reason to say that document that you wrote is incorrect?¶

24 A. 25 you what It's in 2011, I can't possibly tell I remember in 2011.¶

2 Q. 3 4 email that you wrote? Are you questioning that this document is incorrect, this document -- this¶

5 6 7 rubbish that 8 9 10 11 12 A. I wrote an email. I was trying to be accurate, so who knows, with all the you guys have put out in the press that I read, maybe in the moment I wrote it a memory came to me that I don't know, but as I sit here today and the testimony I gave you today is I don't recollect it.¶

13 14 that you recalled meeting 15 Mar-a-Lago? Q. Does this refresh your recollection at¶

16 A. It does not.¶

17 18 19 Q. So your testimony today is that don't remember meeting at Mar-a-Lago?¶

20 A. I do not.¶

21 22 I just want to clarify, when you read so much stuff and so much rubbish that 23 comes out from, you don't 24 know what's up and down, at the time I wrote 25 this I believe I had a memory but as I sit¶

2 here today I do not.¶

3 Q. Ms. Maxwell, when did you first¶

4 meet ?¶

5 MR. PAGLIUCA: Object to the form¶

6 and foundation.¶

7 A. I have no idea when I met her.¶

8 Q. Do you know how old she was when¶

9 you met her?¶

10 A. I have no idea how old she was when¶

11 I met her.¶

12 Q. Is it possible she was 13 years old¶

13 when you first met her?¶

14 MR. PAGLIUCA: Object to the form¶

15 and foundation.¶

A.¶

II¶

18 may have been in the house when Jeffrey was¶

19 in the house. I have no idea how old she¶

20 was.¶

21 Q. I understand¶

22¶

23 I'm asking if was 13¶

24 years old when you first met her?¶

25 A. I have no idea.¶

2 Q. Was she under 18 when you first met 3 her?¶

4 A. I have no idea how old she was when 5 I first met her.¶

6 Q. Did she look like a child when you 7 first met her?¶

8 A. I don't remember what she looked 9 like at the time she was in the house.¶

10 Q. How many years have you known her?¶

11 A. I can only recall the last time I 12 saw her.¶

13 Q. When was the first time you met 14 her?¶

15 A. Again, I just told you, I don't 16 recall the first time I met her.¶

17 Q. Did travel with you 18 on Jeffrey's planes?¶

19 A. I wouldn't remember if was O-20 the plane or not.¶

21 Q. Did you ever have sex with 22¶

23 A. No.¶

24 Q. Did you ever observe Jeffrey having 25 sex with¶

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¶

1 2 3 G Maxwell - Confidential 4 and foundation. 5 Q. 6 A. I already 7 8 of that. 9 Q. 10 the house with Is that your testimony? Jeffrey Epstein and foundation. seeing with ?¶

MR. PAGLIUCA: Object to the form¶

11 12 13 MR. PAGLIUCA: Object to the form¶

14 15 A. I just told you I don't recall¶

16 17 Q. Were you ever involved in an orgy¶

18 A. No, absolutely not.¶

19 Q. 20 individual by the name of Can you tell me, do you know an i¶

21 A. I do.¶

22 Q. How did you meet ?¶

23 A. At some 24 Jeffrey's and I recall 25 point. point she was a friend of meeting her at some¶

said I don't recall all the times I've seen her and I have no memory¶

Have you ever seen in¶

2 Q. Did you hire her?¶

3 A. First of all, I don't hire girls 4 like that, so let's be clear, I already S testified to that, and I have no idea what 6 you are referring to.¶

7 Q. When you say girls like that, what 8 do you mean?¶

9 A. I hire people who are professional 10 at the house. You are asking if I hired 11 somebody to do what, I don't know what you 12 are talking about. I hired people to work in 13 the homes.¶

14 Q. What was doing?¶

15 MR. PAGLIUCA: Object to the form 16 and foundation.¶

'7 A. I have no idea what was doing. I didn't hire her and 19 I don't know what you are referring to.¶

20 Q. You met¶

21 A. I testified I did.¶

22 Q. Did she work for Jeffrey Epstein?¶

23 A. I have no idea what she did.¶

24 Q. Have you flown on planes with U¶

2 A. I don't recollect. I don't know if¶

3 I did.¶

4 Q. How many times have you flown on¶

S Jeffrey Epstein's planes?¶

6 A. Too many times.¶

7 Q. More than 300?¶

8 A. I really couldn't tell you how¶

9 many.¶

10 Q. More than 400?¶

11 A. Again, I said I cannot tell you how¶

12 many, a lot.¶

13 Q. How many times with¶

14¶

15 A. I already testified, I have no¶

16 idea.¶

17 Q. How old was when¶

18 she first became involved with Jeffrey?¶

19 A. I have no idea.¶

20 Q. Was she 14?¶

21 MR. PAGLIUCA: Object to the form¶

22 and foundation.¶

23 A. I have no idea.¶

24 Q. Did she look like a child the first¶

25 time you met her?¶

2 MR. PAGLIUCA: Object to the form 3 and foundation. Asked and answered.¶

4 Q. Did she look like a child the first 5 time you met¶

6 A. I don't know what you mean if she 7 looked like a child.¶

8 Q. Did she look like she was under the 9 age of 18?¶

10 A. No.¶

11 Q. Did she look like she was under the 12 age of 16?¶

13 A. I just testified -- first of all, I 14 couldn't tell you how old she was, she didn't 15 like like a child, leave it at that.¶

16 Q. Did you know that she was a child?¶

17 MR. PAGLIUCA: Object to the form 18 and foundation.¶

19 A. I just answered I did not know how 20 old she was and she looked like an adult.¶

21 Q. In the times that you traveled with 22 her on Jeffrey Epstein's planes, did you ever 23 ask her how old she was?¶

24 MR. PAGLIUCA: Object to the form 25 and foundation. Assumes facts not in¶

2 evidence. The witness already testified¶

3 she doesn't remember.¶

4 Q. You can answer that question.¶

S Did you ever ask her on the many¶

6 flights you were with her or the many times¶

7 you were with her at the house?¶

8 A. First of all, I don't know I was on¶

9 many flights with her, you are making stories¶

10 up again as usual. And secondly, if I was on¶

11 a flight with her, there would not be any¶

12 reason why I would ask her how old she was.¶

13 Q. You don't recollect having any¶

14 conversation with her about her age?¶

15 A. I already testified to that.¶

16 Q. Do you know what¶

17 was hired to do for Jeffrey?¶

18 A. I already testified I didn't know¶

19 she was hired and I don't know that she did¶

20 anything. I don't know how to answer that¶

21 question.¶

22 Q. Was at the house,¶

23 the Palm Beach house, when you were present¶

24 at that house?¶

25 MR. PAGLIUCA: Object to the¶

2 foundation.¶

3 A. I have no recollection of her being 4 at the house at the same time as me.¶

5 Q. When did you first meet¶

6¶

7 A. I already told you I don't recall.¶

8 Q. Do you recall anything about¶

9¶

10 A. That she was tall and blond.¶

11 Q. Do you recall¶

12 interacting with other females at the house? 13 A. No, I do not. 14 Q. Did you arrange to get a visa for 15 to come into this country?¶

16 MR. PAGLIUCA: Object to the form¶

17 and foundation.¶

18 A. Absolutely not.¶

19 Q. Did Jeffrey arrange for a visa for¶

20¶

21 MR. PAGLIUCA: You need to give me 22 a break so I can interpose an objection.¶

23 Object to the form and foundation.¶

24 Q. You can answer.¶

25 A. What was the question?¶

2 Q. Did Jeffrey arrange for a visa for¶

3¶

4 A. I don't know what Jeffrey did. I¶

5 cannot testify what Jeffrey did.¶

6 Q. Was involved in sex with¶

7 Jeffrey and other girls?¶

8 MR. PAGLIUCA: Object to the form¶

9 and foundation.¶

10 Q. Girls under the age of 18?¶

11 MR. PAGLIUCA: Same objection.¶

12 A. I have no idea.¶

13 Q. Was involved with sex with¶

14 Jeffrey and girls over the age of 18?¶

15 MR. PAGLIUCA: Same objection.¶

16 A. I have no idea.¶

17 Q. Did recruit other girls for¶

18 sex with Jeffrey?¶

19 MR. PAGLIUCA: Object to the form¶

20 and foundation.¶

21 A. I have no idea.¶

22 Q. Do you still talk to¶

23 A. No.¶

24 Q.¶

25 A. I have no idea.¶

2¶

3¶

4 A. I have no idea.¶

S Q. Are you a pilot?¶

6 A. I am.¶

7 Q. Have you flown with¶

8 A. I have.¶

9 Q. Have you flown with¶

10¶

11 A. What do you mean by flown?¶

12 Q. Have you been on planes with her?¶

13 A. I already testified I don't recall 14 having her on a plane with me.¶

15 Q. Do you know¶

16 A. I do.¶

17 Q. When did you first meet her?¶

18 A. I don't recall exact dates.¶

19 Q. Did you meet her with the purpose 20 of hiring her to work for Jeffrey or having 21 Jeffrey hire her?¶

22 MR. PAGLIUCA: Object to the form 23 and foundation.¶

24 A. No.¶

25 Q. What was her relationship with¶

2 Jeffrey?¶

3 MR. PAGLIUCA: Object to the form 4 and foundation.¶

5 A. I don't know exactly the nature of 6 her relationship but she worked for him.¶

7 Q. What did she do?¶

8 MR. PAGLIUCA: Object to the form 9 and foundation.¶

10 A. At the time she when was with him I 11 believe she traveled with him and helped with 12 his travel arrangements.¶

13 Q. Did she bring girls to the house to 14 give massages to Jeffrey?¶

15 MR. PAGLIUCA: Object to the form 16 and foundation.¶

17 A. I don't know what did.¶

18 Q. So you never observed 19 bringing girls to the home to give massages 20 to Jeffrey?¶

21 MR. PAGLIUCA: Object to the form 22 and foundation.¶

23 A. I don't understand the question, 24 what did you mean bring?¶

25 Q. Did you ever observe¶

2 inviting, bringing, walking anyone into the 3 home to give a massage for Jeffrey?¶

4 MR. PAGLIUCA: Object to the form 5 and foundation.¶

6 A. I don't recollect anything like 7 that.¶

8 Q. Are you aware that was 9 a co-conspirator, named as a co-conspirator 10 in the case involving Jeffrey Epstein?¶

11 MR. PAGLIUCA: Object to the form 12 and foundation and also calls for a 13 legal conclusion.¶

14 MS. McCAWLEY I'm just asking if she 15 is aware of that.¶

16 A. I am aware.¶

17 Q. Who paid¶

18 A. I have no idea.¶

19 Q. Did you ever arrange payment for 20 any of the employees at the home?¶

21 MR. PAGLIUCA: Object to the form.¶

22 A. What do you mean by arrange?¶

23 Q. Were you ever in charge or 24 responsible for paying individuals at the 25 home, that worked there?¶

2 A. People had salaries and they were 3 paid by the office.¶

4 Q. Did you ever pay any individual, 5 did you ever hand an individual cash for work 6 they performed?¶

7 MR. PAGLIUCA: Object to the form.¶

8 A. Can you be more specific about what 9 you are asking me.¶

10 Q. Did you ever hand any individual 11 who was working at the home cash as payment 12 for something that they performed at the 13 home?¶

14 MR. PAGLIUCA: Object to the form.¶

15 A. To the best of my recollection 16 there were very few times where I would leave 17 some cash for people for work performed.¶

18 Q. And what type of work was being 19 performed where you would be doing that?¶

20 A. If I left cash for the pool guy, I 21 would have left potentially some cash for the 22 gardener, potentially for exercise 23 instructors and sometimes for massage 24 therapy.¶

25 Q. How much were the massage¶

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 threatenih 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 sexual acts on her?¶

3 MR. PAGLIUCA: Object to the form
4 and foundation.¶

5                                  A.                                  I have not heard that.¶

6 Q. How do you know [REDACTED]?¶

7 A. [Redacted]¶

[REDACTED]¶

10 Q. Was [REDACTED] under the age of
11 18?¶

12 MR. PAGLIUCA: Object to the form
13 and foundation.¶

14 A. I don't recall how old [REDACTED]
15 was.¶

16                      Q.                  Did she tell police that Jeffrey
17                      Epstein assaulted her sexually?¶

18 MR. PAGLIUCA: Object to the form
19 and foundation.¶

20 A. I never heard that.¶

21	Q.	Did [REDACTED] recruit or bring
22	girls to the home that were under the age of
23	18?

24 MR. PAGLIUCA: Object to the form
25 and foundation and I think this has been¶

2 asked and answered already.¶

3 Q. You can answer the question.¶

4 A. I have no idea what S did.¶

6 Q. You never observed 7 with girls under the age of 18 at Jeffrey's 8 home?¶

9 MR. PAGLIUCA: Object to the form 10 and foundation.¶

11 A. The answer is no, I have no idea.¶

12 Q. Do you know ?¶

13 A. I do.¶

14 Q. What is your relationship with¶

15¶

16 MR. PAGLIUCA: Object to the form.¶

17 A. What do you mean what is my 18 relationship.¶

19 Q. Are you friendly with him, how do 20 you know him?¶

21 A. He is the husband of¶

22 Q. Is one of your friends?¶

23 A. Yes.¶

24 Q. Did you ever send Virginia to¶

25 to give him a¶

2 massage?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 A. No.¶

6 Q. Did you ever instruct¶

7 to have sex with¶

8 MR. PAGLIUCA: Objection to the¶

9 form and foundation.¶

10 A. I have never instructed Virginia to¶

11 have sex with anybody ever.¶

12 Q. How old was when she¶

13 met Jeffrey?¶

14 MR. PAGLIUCA: Objection to the¶

15 form and foundation.¶

16 A. I have no idea.¶

17 Q. What's she under the age of 18?¶

18 MR. PAGLIUCA: Objection to the¶

19 form and foundation.¶

20 A. I just testified I have idea how¶

21 old she was.¶

22 Q. You testified she was your friend.¶

23 You don't know how old she was when she met¶

24 Jeffrey?¶

25 A. That happened sometime in the '70s,¶

2 how would I know, or '80s. I have no idea.¶

3 Can you testify to what your friends did 30¶

4 years ago?¶

5 Q. You don't ask the questions here,¶

6 Ms. Maxwell.¶

7 What about, when¶

8 did you first meet¶

9 A. I don't recall the exact date.¶

10 Q. Did you hire¶

11 A. I don't hire people, she came to¶

12 work at the house to answer phones.¶

13 Q. Where did you meet her?¶

14 A. I just testified, I don't recall¶

15 exactly when I met her.¶

16 Q. Was one of your job¶

17 responsibilities to interview people that¶

18 would be then hired by Jeffrey?¶

19 A. That was one of my¶

20 responsibilities.¶

21 Q. Do you recall interviewing¶

22 A. I don't recall the exact interview,¶

23 no.¶

24 Q. Do you know what tasks was¶

25 hired to performance?¶

2 A. She was tasked to answer¶

3 telephones.¶

4 Q. Did you ever ask her to rub¶

5 Jeffrey's feet?¶

6 7 MR. PAGLIUCA: Objection to the form and foundation.¶

8 A. I believe that I have read that, 9 but I don't have any memory of it.¶

10 Q. Did you ever tell that she 11 would get extra money if she provided Jeffrey 12 massages?¶

13 A. I was always happy to give career 14 advice to people and I think that becoming 15 somebody in the healthcare profession, either 16 exercise instructor or nutritionist or 17 professional massage therapist is an 18 excellent job opportunity. Hourly wages are 19 20 21 22 23 24 25 around 7, 8, $9 and as a professional healthcare provider you can earn somewhere between as we have established 100 to $200 and to be able to travel and have a job that pays that is a wonderful job opportunity. So in the context of advising people for opportunities for work, it is possible that I¶

2 would have said that she should explore that 3 as an option.¶

4 Q. Did you tell her she would get¶

5 extra money if she massaged Jeffrey?¶

6 A. I'm just saying, I cannot recall 7 the exact conversation. I give career advice 8 and I have done that.¶

9 10 you? Q. Did you ever have massage¶

11 A. I did.¶

12 Q. How many times?¶

13 A. I don't recall how many times.¶

14 Q. Was there sex involved?¶

15 A. No.¶

16 Q. 17 massage Did you ever instruct to¶

18 A. 19 I don't believe -- I have no recollection of it.¶

20 21 with Q. Did you ever have sexual contact¶

22 23 24 25 MR. PAGLIUCA: Object to the form and foundation. You need to give me an opportunity to get in between the questions.¶

2 Anything that involves consensual 3 sex on your part, I'm instructing you 4 not to answer.¶

S Q. Did you ever have sexual contact 6 with¶

7 A. Again, she is an adult --¶

8 Q. I'm asking you, did you ever have 9 sexual contact with¶

10 A. I've just been instructed not to 11 answer.¶

12 Q. On what basis?¶

13 A. You have to ask my lawyer.¶

14 Q. Did you ever have sexual contact 15 with that was not consensual on 16 part?¶

17 MR. PAGLIUCA: You can answer 18 nonconsensual.¶

19 A. I've never had nonconsensual sex 20 with anybody.¶

21 Q. Not¶

22 MR. PAGLIUCA: Objection.¶

23 A. I just testified I never had 24 nonconsensual sex with anybody ever, at any 25 time, at anyplace, at any time, with anybody.¶

2 Q. So if were to testify that 3 she did not consent to a sexual act that you 4 participated in --¶

5 A. I just told you I have never ever 6 under any circumstances with anybody, at any 7 time, in anyplace, in any form had 8 nonconsensual relations with anybody.¶

9 Q. Did you introduce 10¶

11 MR. PAGLIUCA: Objection to the 12 form and foundation.¶

13 A. I've, again, read that 14 claimed that she met or that she said she met 15 . I don't know if I was the one 16 who made the introduction or not.¶

17 Q. Do you know a female by the name of 18¶

19 A. I do.¶

20 Q. How do you know her?¶

21 A.¶

22 Q. So she worked for you?¶

23 A. Yes.¶

24 Q. Did you hire her?¶

25 A. Again, Jeffrey hired people.¶

2 Q. Did you have sex with her?¶

3 MR. PAGLIUCA: This is the same¶

4 instruction about consensual or¶

5 nonconsensual.¶

6 Q. Was under the age of 18 when¶

7 you hired her?¶

8 A. No. I didn't hire her, as I said,¶

9 Jeffrey did.¶

10 Q. Did ever have sex with¶

11 Jeffrey?¶

12 MR. PAGLIUCA: Objection to the¶

13 form and foundation.¶

14 A. How would I know what somebody else¶

15 did.¶

16 Q. You weren't involved in the sex¶

17 between Jeffrey, and yourself?¶

18 A. We already --¶

19 Q. Were you involved with sex between¶

20 Jeffrey, and yourself?¶

21 MR. PAGLIUCA: Everyone is talking¶

22 over each other. You heard the¶

23 question.¶

24 Again, you you know what the¶

25 instruction is. If there is any¶

2 consensual issue involved, I instruct¶

3 you not to answer.¶

4 A. Moving on.¶

5 Q. So you are refusing to answer that¶

6 question?¶

7 A. I've been instructed by my lawyer.¶

8 Q. Did you ever have sex with Jeffrey,¶

9 Virginia and yourself when Virginia was 10 underage?¶

11 A. Absolutely not.¶

12 MR. PAGLIUCA: We've been going for¶

13 about an hour. I would like to take a 14 five-minute break, please.¶

15 MS. McCAWLEY: I'm almost done.¶

16 MR. PAGLIUCA: You are not going to 17 allow a break.¶

18 MS. McCAWLEY: As soon as I get 19 through my line of questioning, which is 20 perfectly appropriate.¶

21 Q. Did travel with you and 22 Jeffrey to Europe?¶

23 A. I'm sure she did.¶

24 Q. What is she doing today?¶

25 A. I have no idea.¶

2 Q. Do you speak to her regularly now, 3 do you speak to her?¶

4 A. No.¶

5 Q. Do you know where she lives?¶

6 A. No.¶

7 Q. Do you know what country she lives 8 in?¶

9 A. No.¶

10 Q. Where is the last place you knew 11 that she lived?¶

12 A. Last place I knew for sure was in 13 Los Angeles.¶

14 Q. When did she stop working for you?¶

15 A. 2001, 2002.¶

16 Q. What tasks did she performance for 17 you?¶

18 A. She helped me with moving in and 19 out of houses, construction, she was a 20 general help, she helped with buying things 21 that needed to be purchased, if I needed her 22 to stand in for me during meetings, it was a 23 very wide ranging job.¶

24 Q. Did she ever bring females to 25 perform massages for Jeffrey?¶

2 MR. PAGLIUCA: Objection to the 3 form and foundation.¶

4 A. What are you asking me?¶

S Q. Did was it ever 6 responsibility to bring females to the house 7 for the purposes of massaging Jeffrey?¶

8 A. job was to help me with the 9 houses and work in homes. It was not her job 10 to whatever you just said, bring masseuses.¶

11 Q. Did she do that?¶

12 A. I have no recollection. I have no 13 idea.¶

14 Q. Did you pay or did Jeffrey pay 15 her?¶

16 A. Jeffrey.¶

17 Q. Do you recall how much she was 18 paid?¶

19 A. I do not.¶

20 MS. McCAWLEY: I think we can take 21 a break now.¶

22 THE VIDEOGRAPHER: It's 10:02 and 23 we are off the record.¶

24 (Recess.)¶

25 THE VIDEOGRAPHER: It's now 10:18.¶

2 We are back on the record and starting 3 disk No. 2.¶

4 Q. Ms. Maxwell, I asked you about¶

5 earlier.¶

6 Can you describe what¶

' duties were when she was with Mr.¶

8 Epstein?¶

9 MR. PAGLIUCA: Objection to the 10 form and foundation.¶

11 A. I believe that Virginia was a 12 masseuse.¶

13 Q. Was Virginia required to dress up 14 in any way for massages?¶

15 MR. PAGLIUCA: Objection to the 16 form and foundation.¶

17 A. I have no idea.¶

18 Q. Did you provide Virginia with 19 outfits to wear for certain massages?¶

20 A. I have no idea what you are talking 21 about.¶

22 Q. For example, did you ever provide 23 Virginia with a school girl outfit to wear 24 for a massage?¶

25 A. I have no idea what you are talking¶

2 about.¶

3 Q. So you didn't provide her with¶

4 that?¶

5 A. As I just testified, I have no idea¶

6 what you are talking about.¶

7 Q. I was trying to interpret whether¶

8 you didn't understand what a school girl¶

9 outfit was or you are saying that didn't¶

10 happen?¶

11 A. I clearly know what a school girl¶

12 outfit is. I have no recollection of¶

13 providing anybody with a school girl outfit.¶

14 Q. Did you have a set of outfits used¶

15 by the massage therapists that would include¶

16 things like a school girl outfit or a black¶

17 patent leather outfit or anything of that¶

18 nature?¶

19 MR. PAGLIUCA: Object to the form¶

20 and foundation.¶

21 A. That would be just another one of¶

22 Virginia's lies.¶

23 Q. You didn't have anything like that?¶

24 A. I did not.¶

25 Q. Did you have a basket of sex toys¶

2 that you kept in the Palm Beach house?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

S A. First of all what do you mean.¶

6 Q. A laundry basket that contained sex¶

7 toys in it?¶

8 MR. PAGLIUCA: Objection to the¶

9 form and foundation.¶

10 A. Can you ask the question again?¶

11 Q. Did you have a laundry basket that¶

12 contained sex toys in it, in the Palm Beach¶

13 House?¶

14 MR. PAGLIUCA: Objection to the¶

15 form and foundation.¶

16 Q. Did you have a laundry basket of¶

17 sex toys in the Palm Beach house?¶

18 MR. PAGLIUCA: Same objection.¶

19 Q. You can answer.¶

20 A. I don't recollect anything about a¶

21 laundry basket of sex toys.¶

22 Q. Do you recollect having sex toys at¶

23 the Palm Beach house?¶

24 A. You have to define what are you¶

25 talking about.¶

2 Q. A sex toy meaning a vibrator of
3 some kind, sometimes they are called dildos,
4 of that nature, anything like that?¶

5 A. I don't recollect anything that
6 would formally be a dildo, anything like
7 that.¶

8 Q. How would you describe sex toys?¶

9 A. I wouldn't describe sex toys.¶

10 Q. Did you have anything that was of
11 an electronic nature that would be used
12 during sex?¶

13 MR. PAGLIUCA: Objection to the
14 form and foundation.¶

15 A. I have no idea what you are
16 referring to.¶

17 (Maxwell Exhibit 3, transcript,
18 marked for identification.)¶

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5 MR. PAGLIUCA: Objection to the 6 form and foundation.¶

7 A. First I have to read this.¶

8 Q. Sure.¶

9 MS. McCAWLEY: I will stop the 10 clock while the witness is reading.¶

11 MR. PAGLIUCA: No.¶

12 MS. McCAWLEY: Yes, if she is going 13 to read the whole document, I will stop 14 the clock.¶

15 MR. PAGLIUCA: If you give her 16 documents to refresh her recollection, 17 we are on the clock here.¶

18 MS. McCAWLEY: Then we will take it 19 up with the judge.¶

20 MR. PAGLIUCA: Read whatever you 21 need to answer the question.¶

22 MS. McCAWLEY: I'm going to set the 23 document aside and I'm just go to ask 24 you a question, independent of the 25 document.¶

2 3 of Q. Do you recall having a basket full sex toys?¶

4 A. I already told you I did not.¶

5 Q. We were talking a moment ago about 6 and her position as a masseuse, 7 do you know what she was paid for working as 8 a masseuse for Jeffrey Epstein?¶

9 A. I do not.¶

10 Q. Did you ever pay her?¶

11 A. I don't ever recall paying her.¶

12 Q. Do you know what happened during 13 the massage appointments with Jeffrey Epstein 14 and¶

15 MR. PAGLIUCA: Objection to the 16 form and foundation.¶

17 A. No.¶

18 Q. Were you ever present to view a 19 massage between Jeffrey Epstein and II¶

21 22 A. I don't recollect ever seeing Virginia and Jeffrey in a massage situation.¶

23 24 Q. Do you ever recollect seeing them in a sexual situation?¶

25 A. I never saw them in a sexual¶

2 situation.¶

3 Q. Did you ever participate in sex¶

4 with and Jeffrey Epstein?¶

5 6 7 8 9 10 11 A. any point I never ever at any single time at ever at all participated in anything with Virginia and Jeffrey. And for the record, she is an absolute total liar and you all know she lied on multiple things and that is just one other disgusting thing she added.¶

12 Q. Did you help her obtain an¶

13 apartment in Palm Beach to live in?¶

14 15 MR. PAGLIUCA: Objection to the form and foundation.¶

16 Q. Was that part of your¶

17 responsibilities for Jeffrey?¶

18 19 20 21 A. First of all, I didn't know she had an apartment in Palm Beach. I only learned that from the many times you guys have gone to the press to sell stories, so no.¶

22 23 24 25 Q. Did you help her get a cell phone, was that one of your responsibilities for Jeffrey, to get her is a cell phone as part of her masseuse obligations?¶

2 3 MR. PAGLIUCA: Objection to the form and foundation.¶

4 5 6 7 question properly? A. I don't know what that means, masseuse obligation, I don't know what you are referring to. Would you like to ask the¶

8 9 it again. Q. I think it was proper. I will ask¶

10 11 12 Did you ever assist in getting a cell phone to use during the time that she worked for Jeffrey Epstein?¶

13 14 A. I have no recollection of doing anything of that nature.¶

15 16 17 Q. Did you ever tell Virginia that you wanted her to have a cell phone so that she could be on call regularly?¶

18 19 conversation. A. I have no recollection of that¶

20 Q. 21 How often would Virginia come over to the house in Palm Beach to give massages?¶

22 23 MR. PAGLIUCA: Objection to the form and foundation.¶

24 A. Ask the question again, please.¶

25 Q. How often did come¶

2 over to the house in Palm Beach to give¶

3 massages?¶

4 A. It's important to understand that I¶

5 wasn't with Jeffrey all the time. In fact, I¶

6 was only in the house less than half the¶

7 time, so I cannot testify to when I wasn't in¶

8 the house how often she came when I wasn't¶

9 there.¶

10 What I can say is that I barely¶

11 would remember her, if not for all of this¶

12 rubbish, I probably wouldn't remember her at¶

13 all, except she did come from time to time¶

14 but I don't recollect her coming as often as¶

15 she portrayed herself.¶

16 Q. How many times a day on an average¶

17 day would Jeffrey Epstein get a massage?¶

18 MR. PAGLIUCA: Objection to the¶

19 form and foundation.¶

20 A. When I was at the house and when I¶

21 was there with him, he received a massage, on¶

22 average, about once a day.¶

23 Q. Just once?¶

24 A. Yes.¶

25 Q. Were there days when he received¶

2 four or five?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

S A. When I was present at the house, I¶

6 never saw something like that.¶

7 Q. Do you know if Virginia was¶

8 required to be on call at all times to come¶

9 to the house if Jeffrey wanted her there?¶

10 MR. PAGLIUCA: Objection to the¶

11 form and foundation.¶

12 A. I have no idea of the arrangements¶

13 that Virginia made with Jeffrey.¶

14 Q. When Virginia was in New York,¶

15 would Virginia sleep at Jeffrey's mansion in¶

16 New York?¶

17 MR. PAGLIUCA: Objection to the¶

18 form and foundation.¶

19 A. I don't recollect her being in New¶

20 York and I have no idea where she slept.¶

21 Q. You don't ever remember seeing¶

22 in New York?¶

23 MR. PAGLIUCA: Objection to the¶

24 form and foundation.¶

25 A. I would barely recollect her at¶

2 all, except for this story.¶

3 Q. Do you recall 4 calling you because she was having a medical 5 crisis and you and Jeffrey taking her to the 6 hospital?¶

7 A. I have heard this absurd story and 8 if any part of it were true I would remember 9 that. I do not.¶

10 Q. You don't remember taking her to 11 the hospital?¶

12 A. It's not that I don't remember it, 13 it didn't happen.¶

14 Q. How do you know it didn't happen?¶

15 16 A. That's the sort of memory you would recall.¶

17 18 Q. Do you recall, you said you don't remember her being at the New York mansion.¶

19 20 the New York mansion with Jeffrey? When you were in New York would you stay at¶

21 A. I stayed from time to time.¶

22 Q. Do you recall Virginia being at the 23 New York mansion when came to 24 visit?¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 A. Like I told you, I don't recall her 4 being at the house at all.¶

5 Q. How many homes does Jeffrey have?¶

6 MR. PAGLIUCA: Objection to the 7 form and foundation.¶

8 A. When I was working for him, I think 9 he had six maybe.¶

10 Q. Would Virginia stay with him in 11 those homes?¶

12 MR. PAGLIUCA: Objection to the 13 form and foundation.¶

14 A. I can only testify for when I was 15 present with him and I cannot say what she 16 did when I wasn't present with him.¶

17 Q. When you were present, would 18 Virginia stay in the homes with him?¶

19 A. I don't recall her staying in the 20 houses.¶

21 Q. Did you train Virginia on how to 22 recruit other girls for massages?¶

23 MR. PAGLIUCA: Objection to the 24 form and foundation.¶

25 A. No.¶

2 Q. Did you train Virginia on how to 3 recruit other girls to perform sexual 4 massages?¶

S MR. PAGLIUCA: Objection to the 6 form and foundation.¶

7 A. No. And it's absurd and her entire 8 story is one giant tissue of lies and 9 furthermore, she herself has -- if she says 10 that, you have to ask her about what she did.¶

11 Q. Does Jeffrey like to have his 12 nipples pinched during sexual encounters?¶

13 MR. PAGLIUCA: Objection to form 14 and foundation.¶

15 A. I'm not referring to any advice on 16 my counsel. I'm not talking about any adult 17 sexual things when I was with him.¶

18 Q. When Jeffrey would have a massage, 19 would he request that the masseuse pinch his 20 nipples while he was having a massage?¶

21 A. I'm not talking about anything with 22 consensual adult situation.¶

23 Q. What about with underage --¶

24 A. I am not aware of anything.¶

25 Q. You are not aware of Jeffrey¶

2 Epstein ever having sex with an underage 3 minor and asking them to pinch his nipples?¶

4 A. I am not.¶

5 Q. So I'm going to direct you to, I 6 believe it's Maxwell Exhibit 1, the police 7 report.¶

8 Are you aware that over 30 under 9 age minors gave testimony to police that they 10 were engaged in sexual acts during, 11 quote-unquote, massages.¶

12 MR. PAGLIUCA: The witness needs to 13 find Exhibit 1. Exhibit 1 -- if you can 14 hand me that please.¶

15 Q. So now with respect to the police 16 report, are you aware that over 30 underage 17 girls, meaning under the age of 18 gave 18 reports to police that they were assaulted 19 sexually by Jeffrey Epstein during massages?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. I read the police report. That's 23 all I can testify to.¶

24 Q. Are you aware of what is in the 25 police report? Are you aware that there were¶

2 30 girls¶

3 A. I did not count the number of girls¶

4 and I did read the police report. I can only¶

5 testify to what I read.¶

6 Q. So you are aware that the police¶

7 report contains reports from 30 underage¶

8 girls?¶

9 A. I can't testify to what the girls¶

10 said. I can only testify to the fact that I¶

11 read a police report that stated that.¶

12 Q. Were you working for Jeffrey -- you¶

13 said you worked for him off an on until 2009,¶

14 is that correct?¶

15 A. I helped out from time to time¶

16 Q. So you were working with him during¶

17 the time period when these underage girls¶

18 were visiting Jeffrey's home?¶

19 MR. PAGLIUCA: Objection to the¶

20 form and foundation.¶

21 A. I was not -- what year, I need¶

22 years.¶

23 Q. How about let's say 2005?¶

24 A. I'm not sure I was at the house at¶

25 all in 2005, maybe one day, maybe.¶

2 Q. How about 2004?¶

3 A. I was present for his mother's 4 his mother died in 2004 so I was there for 5 his mother's death and the funeral and I was 6 at the house maybe a handful of days, again.¶

7 Q. I would like to direct you to, you 8 have it pulled together now, it's page 39, 9 stamped 00040?¶

10 A. Can you repeat that, please.¶

11 Q. Sure. 00040.¶

12 A. Yes.¶

13 Q. At the top of that document, about 14 three lines down, you see the redacted 15 portions where there is black so it blacks 16 out the name.¶

17 A. I see black redacted portions.¶

18 Q. That's a black redaction of the 19 name of the minor and there is -- I will 20 represent for the record that's what it is. 21 You can contest that but I'm not asking about 22 the name of the minor.¶

23 Five lines down, it says, She was 24 just 16 years of age.¶

25 Do you see that?¶

2 3 A. I have to read that, if you want me to testify to some things.¶

4 S Q. I'm asking if you see where it says, She was just 16 years old.¶

6 A. No, I have to read it.¶

7 8 Q. It's five line downs on the first paragraph.¶

9 A. I do see that.¶

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Q. Then the next paragraph down, it says, this is the next full paragraph, it says, Epstein entered the room, introduced himself, Epstein lay on the table and told her to get comfortable, blank could not remember if room with a the massage he was towel. naked or if he entered the Blank stated she provided wearing her panties. She continued rubbing his thighs and feet advised he turned over on his back and continued to rub his legs with oil. Epstein touched her breast and began to masturbate. I asked if she knew what circumcised and uncircumcised meant. She stated circumcised is when the penis had no foreskin. Blank¶

25 Then jumping down to the next¶

2 paragraph, it says, Blank became upset,¶

3 crying hysterically and stated she was paid¶

4 and also instructed to have sex with Epstein¶

5 and by Epstein.¶

6 Do you see that there?¶

7 A. I do.¶

8 Q. Are you aware that there were¶

9 underage minors in the Palm Beach house that¶

10 were required to give sexual massages to¶

11 Jeffrey Epstein?¶

12 MR. PAGLIUCA: Objection to the¶

13 form and foundation. This has been¶

14 asked and answered already. Now you are¶

15 just reading a document.¶

16 MS. McCAWLEY: I am allowed to take¶

17 this deposition.¶

18 A. I already testified --¶

19 Q. Are you aware there were underage¶

20 girls, 30 of them, in this police report that¶

21 were assaulted by Jeffrey Epstein in the Palm¶

22 Beach house during the time you are working¶

23 there?¶

24 A. I am aware that Virginia has¶

25 lied repeatedly --¶

2 Q. I'm not asking about Virginia. I'm 3 asking if you are aware that there were over 4 30 underage girls who gave reports to police 5 officers during the time you worked for 6 Jeffrey Epstein. Are you aware of that?¶

7 MR. PAGLIUCA: Counsel, what is 8 your factual basis for asserting there 9 are 30 underaged people who gave 10 reports?¶

11 MS. McCAWLEY: I don't have to 12 answer that.¶

13 MR. PAGLIUCA: Are you representing 14 as an officer of the court that you have 15 personal knowledge that there are 30 16 people referenced in these police 17 reports?¶

18 MS. McCAWLEY: That's my 19 understanding, that there are 30 girls.¶

20 MR. PAGLIUCA: How is that your 21 understanding if these are redacted 22 reports?¶

23 MS. McCAWLEY: By reading through 24 the reports.¶

25 MR. PAGLIUCA: So you have personal¶

2 knowledge there are 30 people --¶

3 MS. McCAWLEY: Just like can you if¶

4 you read through -- I will not argue¶

5 with you counsel.. she can answer yes or 6 no.¶

7 Q. Are you aware there were over 30¶

8 individuals who were minors who gave reports¶

9 to police just like the one we just read that¶

10 they were sexually assaulted by Jeffrey¶

11 Epstein in the Palm Beach home during the¶

12 years that you were working with him?¶

13 MR. PAGLIUCA: Objection to the¶

14 form and foundation. You can answer if¶

15 you have knowledge.¶

16 A. I already testified I was limited¶

17 in the house, a couple of days, there is no¶

18 way I knew. I have read these reports. I¶

19 cannot testify to 30. Given the experience¶

20 I've had with Virginia's lies, it's very hard¶

21 for me to testify about what I see. I can¶

22 tell from you my personal knowledge I did not¶

23 know what you are referring to.¶

24 Q. You did not know there were¶

25 underage girls in the home that were being¶

2 assaulted by Jeffrey Epstein during the time¶

3 you were working there?¶

4 A. Based on the lies that I have¶

5 already been told, I cannot comment on any --¶

6 Q. Are you saying these 30 girls are¶

7 lying when they gave these reports to police¶

8 officers?¶

9 A. I'm not testifying to their lies.¶

10 I'm testifying to Virginia's lies.¶

11 Q. I am not asking about Virginia's¶

12 lies.¶

13 A. I can only testify to Virginia's¶

14 lies. I can testify to having read these¶

15 reports. I cannot testify to anything else¶

16 about them.¶

17 Q. So your testimony is that during¶

18 the time you were working there, you did not¶

19 know that these minor children were being¶

20 abused in the home while you were there?¶

21 A. What I have already told you and I¶

22 will repeat, I was in the house very limited¶

23 times, very few times. I do not know what¶

24 you are referring to. I've read these¶

25 reports but based on the lies that Virginia¶

2 has perpetrated, cannot tell you what is true 3 or factual or not.¶

4 Q. You said you were in the home a 5 very limited time, so average in the year for 6 example, 2004, how many times would you have 7 been in his Palm Beach home?¶

8 A. Very hard for me to state but very 9 little.¶

10 Q. How about his New York home?¶

11 A. Same.¶

12 Q. Were you his girlfriend in that 13 year, in 2004?¶

14 A. Define what you mean by girlfriend.¶

15 Q. Were you in a relationship with him 16 where you would consider yourself his 17 girlfriend?¶

18 A. No.¶

19 Q. Did you ever consider yourself his 20 girlfriend?¶

21 A. That's a tricky question. There 22 were times when I would have liked to think 23 of myself as his girlfriend.¶

24 Q. When would that have been?¶

25 A. Probably in the early '90s.¶

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?¶

16 MR. PAGLIUCA: Objection to the 17 form and foundation.¶

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 5 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.¶

S 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 testify to actual language.¶

3 Q. So you won't testify to anything¶

4 I'm asking you 17 years ago about a statement¶

5 you made. How do you know it's 17 years ago?¶

6 A. We are talking about a time in¶

7 2000, right?¶

8 Q. Have you ever said that to anybody?¶

9 A. I'm 54 years old so you are asking 10 me in my entire life, what words are you¶

11 asking me in my entire life?¶

12 Q. Your entire life is limited by the 13 time you were with Jeffrey, this is the 14 question.¶

15 A. Let's time limit the question you 16 are asking me.¶

17 Q. So from, let's say, I think you 18 said you started with him in 1992, is that 19 correct, and finished with him in 2009.¶

20 So from 1992 to 2009 have you ever 21 said to anybody that you recruit other and we 22 will start with girls to take the pressure 23 off you to have sex with Jeffrey?¶

24 MR. PAGLIUCA: Objection to the 25 form and foundation.¶

2 A. First of all I resent and despise 3 the world recruit. Would you like to define 4 what you mean by recruit and by girls, you 5 mean underage people. I never had to do 6 anything with underage people. So why don't 7 you reask the question in a way that I am 8 able to answer it.¶

9 Q. I'm asking if you ever said that to 10 anybody. So if you don't understand the word 11 recruit and you never used that word then the 12 answer to that question would be no.¶

13 A. I have no memory as I sit here 14 today having used that word.¶

15 Q. Did you ever meet an underage girl 16 in London to introduce her to Jeffrey to 17 provide him with a massage?¶

18 MR. PAGLIUCA: Objection to the 19 form and foundation.¶

20 A. Run that past me one more time.¶

21 Q. Did you ever meet an underage girl 22 in London to introduce her to Jeffrey to 23 perform a massage?¶

24 MR. PAGLIUCA: Same objection.¶

25 A. Are you asking me if I met anybody¶

2 that was underage in London specifically to 3 provide a massage to Jeffrey, is that your 4 question?¶

S Q. Yes.¶

6 A. No.¶

7 Q. Do you know who is.¶

8 A. I don't recall her right now.¶

9 Q. Do you know if -- strike that.¶

10 During the time that you were¶

11 working for Jeffrey, did you ever observe any¶

12 foreign females, so in other words, not from¶

13 the United States, that were brought to¶

14 Jeffrey's home to perform massages?¶

15 MR. PAGLIUCA: Objection to the¶

16 form and foundation.¶

17 A. Females, what age are we talking?¶

18 Q. Any age.¶

19 A. Can you repeat the question?¶

20 Q. During the time you were working¶

21 for Jeffrey, did you ever observe any foreign¶

22 females of any age that were at Jeffrey's¶

23 home to perform a massage?¶

24 MR. PAGLIUCA: Objection to the¶

25 form and foundation.¶

2 A. Are you asking me if any foreigner, 3 not an American person, gave Jeffrey a 4 massage?¶

5 Q. Yes.¶

6 A. Well, as I sit here today, I can't 7 think of anyone who is foreign. Certainly -- 8 I just can't think of anybody right this 9 second.¶

10 Q. How about any foreign girls who 11 were under the age of 18?¶

12 A. I already testified to not knowing 13 anything about underage girls.¶

14 Q. Were there foreign girls who were 15 brought to Jeffrey's home by 16 for the purposes of providing massages?¶

17 MR. PAGLIUCA: Objection to the 18 form and foundation.¶

19 A. I am not aware of bringing 20 girls. I have not no idea what you are 21 talking about.¶

22 Q. You have never been around foreign 23 girls who are under the age of 18 at 24 Jeffrey's homes?¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 A. I already testified about not¶

4 knowing about underage girls.¶

5 Q. Did you provide any assistance with¶

6 obtaining visas for foreign girls that were¶

7 under the age of 18?¶

8 A. I've never participated in helping¶

9 people of any age to get visas.¶

10 Q. Did Jeffrey, was it Jeffrey's¶

11 preference to start a massage with sex?¶

12 MR. PAGLIUCA: Objection to the¶

13 form and foundation.¶

14 A. I think you should ask that¶

15 question of Jeffrey.¶

16 Q. Do you know?¶

17 A. I don't believe that was his¶

18 preference. I think -- you have to¶

19 understand, a massage -- perhaps you are not¶

20 really familiar with what massage is.¶

21 Q. I am, I don't need a lecture on¶

22 massage.¶

23 A. I think you do.¶

24 MR. PAGLIUCA: No question pending.¶

25 She will ask you another question now.¶

2 A. Massage is for health benefits.¶

3 Q. When did you first meet Jeffrey?¶

4 A. Some point in 1991.¶

5 Q. And did Jeffrey know your father?¶

6 A. No.¶

7 Q. How were you introduced to Jeffrey?¶

8 A. Some friend introduced us.¶

9 Q. Can you describe your relationship 10 back in 1991, was it friendship or was it¶

11 girlfriend relationship or was it a work¶

12 relationship, what was your relationship in 13 1991?¶

14 A. It was just friendly.¶

15 Q. Then I believe you testified you¶

16 began working for him in 1992, is that 17 correct?¶

18 A. Yes.¶

19 Q. In 1992 I know you gave me the¶

20 description of the work that you were¶

21 performing for him, how much was he paying¶

22 you, do you remember?¶

23 A. I don't recall.¶

24 Q. Do you know for example in 2001 how¶

25 much he was paying you?¶

2 A. I don't recall.¶

3 Q. Did it change over the years or did 4 the payment remain the same?¶

5 A. I believe over the course of time 6 it increased a little bit.¶

7 Q. Was that the -- was that payment 8 the payment that -- was the payment made with 9 respect to the jobs, the work you were 10 performing for Jeffrey, was that your sole 11 income at that time?¶

12 MR. PAGLIUCA: I object to the 13 form. I'm also going to instruct you 14 not to answer about sources of -- your 15 personal sources of income outside of 16 Mr. Epstein at all.¶

17 MS. McCAWLEY: What's the basis for 18 that?¶

19 MR. PAGLIUCA: It's confidential, 20 it's not part of this lawsuit.¶

21 MS. McCAWLEY: We have a protective 22 order and it is part of this lawsuit 23 with respect to our damage claims.¶

24 MR. PAGLIUCA: It's not and, in 25 fact, you are not entitled to ask¶

2 financial information of a defendant in¶

3 this kind of case, in a defamation case¶

4 unless and until there is a finding that¶

5 you are entitled to punitive damages.¶

6 That is clear in New York case law, both¶

7 state and Federal.¶

8 MS. McCAWLEY: We disagree on that¶

9 point and we will come back to that.¶

10 Q. From the source of payment from the¶

11 source of Jeffrey, from your work, can you¶

12 give me a range on that, do you know was it¶

13 over $100,000?¶

14 A. I just testified I don't recall.¶

15 Q. You don't don't know if it was¶

16 $500,000?¶

17 A. It was less than that.¶

18 Q. Somewhere between 100 and 500,¶

19 would that be fair to say?¶

20 A. I believe it was between 100 and¶

21 $200,000.¶

22 Q. Did Jeffrey during the time that¶

23 you were working for him purchase a town home¶

24 for you?¶

25 A. The subject of the townhouse is, I¶

2 worked for it and I had a loan, we did loans.¶

3 Q. So a loan through Jeffrey?¶

4 A. I don't recall the exact¶

5 transaction.¶

6 Q. Did he purchase for you a¶

7 helicopter during the time you were working¶

8 for him?¶

9 A. It was his helicopter.¶

10 Q. When did you obtain your pilot¶

11 license?¶

12 A. I believe it was '98 or '99.¶

13 Q. Was that for both airplanes and¶

14 helicopters or just helicopters?¶

15 A. Just helicopters.¶

16 Q. Have you ever flown¶

17 on your helicopter?¶

18 A. That is another one of Virginia's¶

19 lies.¶

20 Q. The question is have you ever done¶

21 that?¶

22 A. I have never flown¶

23 at any time ever, in any helicopter,¶

24 in any place, any time, in any state, in any¶

25 country, at any time anywhere.¶

2 Q. Have you ever had dinner with¶

3 at Jeffrey's home, at any¶

4 of Jeffrey's homes?¶

5 A. No, I don't believe so.¶

6 Q. Have you traveled on Jeffrey's¶

7 planes with ?¶

8 A. Yes, I have.¶

9 Q. Would that have been in 2002?¶

10 A. It's very hard for me to recollect¶

11 exact dates but that sounds about right.¶

12 Q. Was that during the time that¶

13 Virginia was working for Jeffrey?¶

14 A. I don't know that Virginia ever did¶

15 work for Jeffrey. I don't exactly know if¶

16 she testified to her so-called duties, we¶

17 know she is a serial liar so I can't testify¶

18 to what she did or didn't do. So I object to¶

19 that characterization of her. So repeat the¶

20 question, please.¶

21 Q. Can you read the question back?¶

22 (Record read.)¶

23 Q. You can answer the question.¶

24 A. What was the question again?¶

25 Q. When you were traveling on the¶

2 plane with, was that during¶

3 the time, it was 2002, that you were on a¶

4 flight with was that during the time¶

5 Virginia was working for Jeffrey?¶

6 MR. PAGLIUCA: Object to the form.¶

7 Misstates the witness' answer and if you¶

8 can answer the question, you can answer¶

9 it.¶

10 A. Well, like I said, I don't recall¶

11 exactly when I flew with him. I don't recall¶

12 when Virginia, we know what Virginia claims¶

13 when she left, so I can't answer the¶

14 question. I have no idea.¶

15 Q. Do you know¶

16 A. I do.¶

17 Q. How long have you known him?¶

18 A. A very long time.¶

19 Q. Since you were a child?¶

20 A. I really -- it's so long, it's¶

21 really a long time ago. I just don't recall.¶

22 Q. Do you remember how you first met¶

23 him?¶

24 A. No, I do not.¶

25 Q. Did you introduce him to Jeffrey?¶

2 3 A. That would be another of Virginia's lies and the lies you perpetrate. I never¶

4 introduced 5 6 to Jeffrey Epstein at any time ever, so just add that the to long list of lies.¶

7 Q. Did Jeffrey know¶

8 9 have A. that Clearly he knew him. I think we answer but how -- yeah.¶

10 11 Q. Do you know how Jeffery met¶

12 A. I do not know Jeffrey met¶

13 14 15 What I do know is that I did not introduce them. That is one of the many lies. Are we tallying all the lies?¶

16 Q. 17 Do you know when Jeffrey met¶

18 19 A. I do not know when Jeffrey met¶

20 21 22 Q. Did you ever introduce to any girls under the age of 18 who were not friends of yours children?¶

23 24 25 A. I have not introduced to anyone that I am aware of other than friends of mine who have kids under that age¶

2 that he may have met socially through me.¶

3 Q. Did you ever introduce¶

4 to Virginia in London?¶

5 A. I understand her story about 6 but again, her tissue of lies is extremely 7 hard to pick apart what is true and what 8 isn't. Actually I wouldn't recollect her at 9 all but for her tissue stories about this 10 situation.¶

11 Q. So did you ever introduce¶

12 to Virginia in London?¶

13 A. I have no recollection.¶

14 Q. Did Virginia ever stay at your home 15 in London, your town home?¶

16 A. I know she claims she did but if 17 you are asking me here today to remember 18 specifically, I cannot.¶

19 Q. Do you remember taking a trip with 20 Virginia to travel over to Europe, including 21 London?¶

22 A. So I have seen her reports and I 23 have seen the plane reports. I see she says 24 she was on that but again, I really have no 25 recollection of her.¶

2 Q. Did you know that she was 17 at the 3 time of that trip?¶

4 MR. PAGLIUCA: Objection to the 5 form and foundation.¶

6 A. I have --¶

7 Q. Did you know she was 17 at the time 8 of that trip?¶

9 MR. PAGLIUCA: Objection to the 10 form and foundation.¶

11 A. I didn't even know she was on the 12 trip.¶

13 Q. Did you hold her passport for her 14 when she was traveling?¶

15 MR. PAGLIUCA: Objection to the 16 form and foundation.¶

17 A. I have no recollection whatsoever 18 of her even being on the trip nor holding her 19 passport.¶

20 (Maxwell Exhibit 4, picture, marked 21 for identification.)¶

22 Q. I'm showing you what we marked as 23 Maxwell Exhibit 4.¶

24 Can you take a look at that picture 25 for me?¶

2 A. I've looked at it.¶

3 Q. Are you in that picture?¶

4 A. I am.¶

5 Q.¶

7 A. It is.¶

8 MR. PAGLIUCA: I don't believe this 9 has been produced to us in discovery by 10 you.¶

11 MS. McCAWLEY: The picture?¶

12 MR. PAGLIUCA: Yes.¶

13 MS. McCAWLEY: It has.¶

14 MS. MENNINGER: Is it the same 15 exact photograph.¶

16 MS. McCAWLEY: I believe so. We 17 will find one. The picture has been 18 produced a number of times.¶

19 MR. PAGLIUCA: I've seen different 20 iterations of this, I don't believe I 21 have ever seen this.¶

22 MS. McCAWLEY: We had them blow it 23 up on a page so she could see it. We 24 could use an article.¶

25 While you are looking for that, I¶

1 G Maxwell - Confidential 2 will skip ahead. Hold that until we can 3 find one that has the range on it.¶

4 Q. Do you recall Virginia being at 5 your London town home?¶

6 A. I do not.¶

7 Q. Do you recall going to dinner with 8 , Jeffrey Epstein and in London, at any time?¶

10 A. I do not.¶

11 Q. Do you recall going to a place 12 called, Jeffrey 13 Epstein and yourself and¶

14 A. I would just like to state for tl 15 record¶

U U¶

I do not have any recollection of it 21 and I doubt it actually happened.¶

22 Q. You don't recall that.¶

23 Do you recall taking Virginia 24 shopping when you were in London to buy an 25 outfit to meet¶

2 A. No, I don't.¶

3 Q. Where in your town home we will 4 come back to that.¶

5 Do you have guest bedrooms in your 6 town home in London?¶

7 A. I do.¶

8 Q. How many?¶

9 A. Two.¶

10 Q. Did ever visit¶

11 Jeffrey and you in New York?¶

12 A. Yes.¶

13 Q. Do you remember him visiting you 14 and Jeffrey in New York in the spring of 15 2001?¶

16 A. Again, I can't testify to any 17 specific dates.¶

18 Q. So you don't have a recollection of 19 that?¶

20 A. I have a recollection -- you've 21 asked me if I have a recollection of being in 22 New York but if you are asking for a date, I 23 cannot confirm that date.¶

24 Q. Do you remember being 25 present in New York for a party where¶

2 was also present?¶

3 A. I don't recollect.¶

4 Q. Do you recall ever giving¶

5 a gift of a puppet that was in the 6 same -- that looked like him?¶

7 A. I never gave him a gift of a¶

8 puppet.¶

9 Q. Did Jeffrey ever give him a gift of 10 a puppet?¶

11 A. No, not that I am aware of.¶

12 Q. Have you ever given him any gifts?¶

13 MR. PAGLIUCA: Objection, 14 foundation.¶

15 A. I know¶

16 Q. Have you ever given him any gifts 17 that you remember when he came to Jeffrey's 18 home in New York?¶

19 A. I don't recall giving him any gifts 20 in New York.¶

21 (Maxwell Exhibit 5, picture, marked 22 for identification.)¶

23 Q. I think I directed you to page 24 0034.¶

25 Is that a picture that was taken at¶

2 your London town home?¶

3 A. I have no idea what this picture¶

4 was taken. I know what she purports it to be¶

5 but I'm not going to say that I do.¶

6 Q. Do the surroundings look like your¶

7 London town home?¶

8 A. They are familiar.¶

9 Q. Do you know who took this picture?¶

10 A. I do not.¶

11 Q. Did Jeffrey Epstein take the¶

12 picture?¶

13 A. I just testified I don't know who¶

14 took the picture.¶

15 Q. So you don't know if Jeffery¶

16 Epstein took the picture?¶

17 A. When I tell you I don't know who¶

18 took the picture, it doesn't mean him -- I¶

19 don't know who took the picture. You can¶

20 come up with 50 names, I still do not know¶

21 who took the picture.¶

22 Q. Did you observe go¶

23 into a room with Virginia alone in your town¶

24 home?¶

25 A. I cannot recall. As I have said,¶

2 no.¶

3 Q. Did ever tell you¶

4 that he had sex with¶

5 A. He did not.¶

6 Q. Did Jeffrey Epstein ever tell you¶

7 that had sex with¶

9 A. He did not.¶

10 Q. Did ever visit -- let¶

11 me back up for a moment We talked about¶

12 Jeffrey's homes, did Jeffrey have a home in¶

13 the U.S. Virgin islands called Little St.¶

14 James?¶

15 A. Yes.¶

16 Q. Did ever visit that¶

17 island -- are you aware of eve¶

18 visiting Jeffrey's island?¶

19 A. I am aware of that, yes.¶

20 Q. Do you know how many times he¶

21 visited?¶

22 A. I do not.¶

23 Q. Do you know if he visited when¶

24 Virginia was on the island?¶

25 A. I do not.¶

2 Q. Were you present on the island when¶

3 visited?¶

4 A. Yes.¶

5 Q. How many times?¶

6 A. I can only remember once.¶

7 Q. Were there any girls under the age 8 of 18 on the island during that one visit 9 that you remember that were not family or 10 friends of or daughters of your friends?¶

11 MR. PAGLIUCA: Objection to the 12 form and foundation.¶

13 A. There were no girls on the island 14 at all. No girls, no women, other than the 15 staff who work at the house. Girls meaning, 16 I assume you are asking underage, but there 17 was nobody female outside of the cooks and 18 the cleaners.¶

19 Q. Did you, as part of your duties in 20 working for Jeffrey, ever arrange for 21 Virginia to have sex with¶

22 MR. PAGLIUCA: Objection to the 23 form and foundation.¶

24 A. Just for the record, I have never 25 at any time, at anyplace, in any moment ever¶

2 asked or whatever she is¶

3 called now to have sex with anybody.¶

4 Q. Did you ever provide¶

with an outfit, an outfit of a sexual¶

6 nature to wear for¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. I think we addressed the outfit¶

10 issue.¶

11 Q. I am asking you if you ever¶

12 provided her with an outfit of a sexual¶

13 nature to wear for¶

14 A. Categorically no. You did get¶

15 that, I said categorically no¶

16 Q. Don't worry I'm paying attention.¶

17 18 A. You seemed very distracted in that moment.¶

19 (Maxwell Exhibit 6, flight logs,¶

20 marked for identification.)¶

21 A. Do you mind if I take a break for¶

22 the bathroom.¶

23 Q. It's 11:08 and we are going to go¶

24 off the record now.¶

25 THE VIDEOGRAPHER: It's now 11:09.¶

2 We are off the record.¶

3 (Recess.)¶

4 THE VIDEOGRAPHER: It's now 11:26,¶

5 we are back on the record and starting¶

6 disk No. 3.¶

7 Q. Ms. Maxwell, I think I handed you 8 right before the break, did I hand you the 9 flight logs, they look like this. Did I mark 10 those yet, I thought I did.¶

11 A. I don't believe I have it.¶

12 Q. These admittedly are a little 13 difficult to read so what I'm going to 14 provide you with to assist is I have a chart 15 that has the airport codes, because it will 16 have, for example, just for the record 17 reflects that the first page of document 18 , it will have a code in the from line 19 that says PBI, for example, to TEB so I a 20 chart that matches up, just in case you don't 21 understand what those letters mean, PBI 22 meaning Palm Beach, TEB meaning Teterboro, 23 which is New Jersey, but others are more 24 difficult but just for you to be able to 25 understand the logs, I will provide you with¶

2 that.¶

3 MR. PAGLIUCA: So we are clear, if 4 the witness has personal knowledge of 5 what these are that's fine but I don't 6 know what these are and I don't expect 7 the witness to accept the representation 8 that they are what they are.¶

9 MS. McCAWLEY: If she can testify 10 to what city it is, she can state that 11 on the record.¶

12 MR. PAGLIUCA: If she knows what it 13 is, she knows what it is, we are not 14 putting any affirmatively on the record 15 until you ask your questions.¶

16 Q. So I'm going to ask you and I think 17 we flagged a few of the pages which may 18 direct us a little bit easier but I will do 19 it by number which is at the bottom of 20 the document kind of at the side.¶

21 The first I will direct your 22 attention to is¶

23 A. Does it have a tab?¶

24 Q. It should. Let me make sure.¶

25 A. Yes it does.¶

2 Q. So I'm directing your attention to 3 the bottom, two lines up from the bottom, 4 there is a flight --¶

5 MR. PAGLIUCA: Are you on III¶

6 MS. McCAWLEY:¶

7 Q. So this flight is from, the one I'm 8 looking at, I think it's highlighted on your 9 copy. On the far corner on the date, it says 10 at the top and this would be the 11 and then the are the two I'm going to 12 direct your attention to.¶

13 Q. On that first one on the you 14 will see the column reading PBI in the from 15 column to TEB in the to column and you will 16 see some initials, you will see JE for 17 Jeffrey Epstein, GM for Ghislaine Maxwell, ■ 18 for and then Virginia?¶

19 A. I have to object.¶

20 MR. PAGLIUCA: You don't get to 21 object.¶

22 Q. She is turning into a lawyer 23 already?¶

24 A. I would like to.¶

25 Q. Let me ask the question and if you¶

1 G Maxwell - Confidential 2 have an issue -- so with respect to this 3 flight, do you recall being on a flight in 4 the -- going from Palm Beach to 5 Teterboro?¶

6 A. No, I don't recall any specific 7 flight.¶

8 Q. Do you recall flying with Virginia 9 on a flight with and Jeffrey 10 Epstein at any time?¶

11 A. I don't.¶

12 Q. How often did you fly on a plane 13 with a 17 year old?¶

14 MR. PAGLIUCA: Objection to form 15 and foundation.¶

16 A. I have no idea what you are talking 17 about, other than friends of mine that had 18 kids.¶

19 Q. Did you regularly fly on Jeffrey's 20 plane with individuals who were under the age 21 of 18?¶

22 MR. PAGLIUCA: Objection to the 23 form and foundation.¶

24 A. Can you repeat the question?¶

25 Q. Did you regularly fly on Jeffrey¶

2 Epstein's planes with individuals who were¶

3 under the age of 18?¶

4 A. I regularly flew on Jeffrey¶

5 Epstein's airplane but I cannot testify as to¶

6 flying with people under the age. I don't¶

7 believe that I did.¶

8 Q. Why wouldn't you remember flying¶

9 with a 17 year old?¶

10 MR. PAGLIUCA: Objection to the¶

11 form and foundation.¶

12 A. How would I know, one, that she is¶

13 17, how would you know that, how do you know¶

14 I'm on the plane.¶

15 Q. Are you saying you are not on this¶

16 flight, so this is a Palm Beach to Teterboro.¶

17 This says the JE, GM ■ and Virginia. The GM¶

18 you are saying is not you?¶

19 MR. PAGLIUCA: I object to the¶

20 form. You can answer the question if¶

21 you know.¶

22 A. How do you know the GM is me.¶

23 Q. Is it your testimony that on the¶

24 flight logs when it represents GM that it is¶

25 not you flying on the plane?¶

2 MR. PAGLIUCA: Objection to the 3 form and foundation.¶

4 A. GM can stand for any level, it 5 could be Georgina,¶

6 Q. Are there any people that flew with 7 Jeffrey Epstein that had the initials GM?¶

8 A. I don't know.¶

9 Q. Do you recall flying with Jeffrey 10 Epstein on his plane over 300 times during 11 the period of 1999 to 2005?¶

12 A. I cannot testify to how many times 13 I was on his plane because that would just be 14 impossible.¶

15 Q. You were on his plane regularly, 16 would you say?¶

17 A. I already testified I was on his 18 plane regularly.¶

19 Q. Is it your testimony and I'm 20 referring now to the line that we were just 21 talking about that you were not on the flight 22 from Palm Beach to Teterboro that lists JE, 23 GM, ■ and Virginia?¶

24 A. I am not testifying to that. I am 25 just saying that you cannot be sure that is¶

2 me.¶

3 Q. So as you sit here today, you don't 4 believe you flew on that plane?¶

5 A. I'm not saying that. I'm just 6 saying you cannot be sure that's me.¶

7 Q. Do you have reason to doubt that 8 when it says GM on these flight logs that 9 that represents you?¶

10 A. I cannot testify to that. I'm just 11 saying it may not be me.¶

12 Q. In looking at the flight logs and 13 look up, let's move up a couple of lines. If 14 you start at the top, you are going to see¶

15 JE, , then JE,¶

16 JE, ■ , JE, GM, JE, GM, JE, GM,¶

17 , reposition, JE, GM, JE, GM¶

18 , JE, GM,¶

19 female,¶

20 repositioning. JE, GM, III, JE,¶

21 GM, , JE, GM, III Virginia,¶

22 JE, GM, Virginia, repositioning and then 23 a certification.¶

24 So is it your testimony in looking¶

25 at that that you do not believe that the GM¶

2 represents you?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 A. I'm not saying that. I'm just¶

6 saying that you cannot -- I can't sit here¶

7 and tell you for sure GM is me and I cannot¶

8 testify remembering being on a flight at that¶

9 time.¶

10 Q. You don't remember being on any of¶

11 these flights with the initial GM?¶

12 A. I remember being on many flights.¶

13 I cannot testify that is a flight I am on.¶

14 Q. Let's go to the next page which is¶

15 going to be I want you to look at¶

16 line -- so the date is at the top, so it's¶

17 and if you go down, you will see¶

18 a line that says the and if you scroll¶

19 over you will see PBI to TIST, if you look at¶

20 the airport codes, TIST is going to be¶

21 representative for the U.S. Virgin Islands¶

22 and then you will see the list on the plane¶

23 JE, GM, II and¶

24 Do you recall flying from Palm¶

25 Beach to the U.S. Virgin Islands with¶

2 Jeffrey, yourself, and¶

I¶

4 MR. PAGLIUCA: I object to the form¶

5 and just so the record is clear, we¶

6 don't agree with whatever your¶

7 characterizations are. The document¶

8 speaks for itself and she can answer¶

9 based on whatever her personal knowledge¶

10 is.¶

11 MS. McCAWLEY: I understand.¶

12 Q. Do you recall flying with those¶

13 individuals from Palm Beach to the U.S.¶

14 Virgin Islands?¶

15 A. I have no recollection of any¶

16 individual flight you are pointing out here.¶

17 You are talking about 2001, how many years¶

18 ago is that?¶

19 Q. I'm asking the questions.¶

20 A. I'm not being difficult. I'm just¶

21 asking, it's like 14, 15 years ago, it's¶

22 impossible, I'm sorry.¶

23 Q. So your testimony is you don't¶

24 recall flying on that flight with¶

U¶

2 A. I cannot testify to that flight.¶

3 Q. Let's look at the next flight which 4 is on the from the Virgin Islands back 5 to Palm Beach, JE, Jeffrey Epstein, Ghislaine 6 Maxwell, , the 7 same individuals on the above flight.¶

8 A. It doesn't say my name, it has some 9 initials.¶

10 Q. I understand, the initials GM.¶

11 Do you recall flying on a plane, on 12 one of Jeffrey's planes from the Virgin 13 Islands to Palm Beach with¶

14 A. I do not.¶

15 Q. Was there any other person that 16 flew with Jeffrey Epstein with frequency 17 during that time period in these logs that 18 have the initials GM?¶

19 MR. PAGLIUCA: Objection to the 20 form and foundation.¶

21 A. I would have to look at all the 22 flight logs, I have no idea, I flew 23 frequently.¶

24 Q. Why don't you take a look at the 25 next three pages and see if that refreshes¶

2 your recollection.¶

3 MR. PAGLIUCA: You are talking¶

4 about¶

5 MS. McCAWLEY: She can pick any¶

6 couple of pages, those have a lot of the¶

7 individuals on them so that is a good¶

8 sampling.¶

9 MR. PAGLIUCA: So pick any pages¶

10 you want.¶

11 Q. Does that refresh your recollection¶

12 at all as to whether GM represents you or¶

13 some other individual?¶

14 A. Again, I can't testify whether that¶

15 represents me or not, I don't see any other¶

16 GMs but you have to understand that even if¶

17 my name is on that record doesn't mean I was¶

18 on the flight.¶

19 Q. So are you contesting the accuracy¶

20 of the flight logs? In other words, you said¶

21 it doesn't represent you are on the flight so¶

22 is it your testimony just because a name is¶

23 listed doesn't mean they were actually on the¶

24 flight?¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 A. I can't testify to what these¶

4 are records that were produced by¶

5 is on here, so these aren't federally¶

6 mandated records, so I can't testify to what¶

7 he produced.¶

8 Q. I would like you to turn to page,¶

9 at the bottom, the number is¶

10 And the month is¶

11 A. Okay.¶

12 Q. If you go down to the number that¶

13 is that would be you're¶

14 going to see on that line an which is a¶

15 and then you¶

16 will see which is going to be, I'm going¶

17 to pronounce it incorrectly,¶

18 I'm sure I'm not pronouncing that¶

19 correctly. Then you will see in the list,¶

20 you will see JE, GM, III¶

21 , it looks like --¶

22 A. I believe it says male.¶

23 Q. Yes. Then¶

24 believe. Is that GM on this page¶

25 representative of you?¶

2 A. Well, this would be a flight that I 3 would potentially remember with 4 on it but I don't actually recall going to 5 Russia.¶

6 Q. Are those your initials, do you 7 recall being on the flight?¶

8 A. Those are my initials with 9 , I don't recall this flight 10 either, but I would be more likely to if I 11 had a bit more time to study the timing of 12 this.¶

13 Q. Your testimony is you don't recall 14 flying with from to 15¶

16 A. I don't recall the to 17 flight. I have definitely flown with 18¶

19 Q. On that same page you will see 20 beneath there, beneath 22 you will see the 21 indication, same as above, same as above, 22 same as above in the column that originally 23 had the initials.¶

24 A. Uh-huh.¶

25 Q. And the names.¶

2 A. Uh-huh.¶

3 Q. Do you recall flying with¶

4 from to¶

5¶

6 A. I do.¶

7 Q. So the GM that would be represented¶

8 in that column would be you?¶

9 A. I recall going to with¶

10 so that is likely to be me.¶

11 Q. You were on Jeffrey's plane for¶

12 that trip?¶

13 A. I believe I was.¶

14 Q. Do you know who¶

15 is?¶

16 A. I do not.¶

17 Q. I'm going back towards the front¶

18 which is going to be please. And¶

19 you're going to see --¶

20 A. Hang on I'm not¶

21 Q. Take your time.¶

22 A. Okay.¶

23 Q. You are going to see in the date¶

24 column, you will see and then about¶

25 halfway down you will see¶

2 then you will see the [REDACTED] which¶

3 is the column which is where I want you to¶

4 start looking at the log and there you're¶

5 going to see [REDACTED]¶

[REDACTED]¶

[REDACTED]¶

[REDACTED]¶

[REDACTED]¶

[REDACTED]¶

11 A. Okay.¶

12           Q.           If you look at the column, if you¶

13 go back up to the top on the [REDACTED] if you look¶

14 at the column you will see JE, GM, █¶

15 [REDACTED] and I believe it says [REDACTED]¶

16 [REDACTED] sorry I'm not reading that very¶

17 well.¶

18 Do you recall flying from, if you¶

19 see the dates, the [REDACTED]¶

20 [REDACTED] Do you recall a trip that w that went from¶

21 the United States to [REDACTED] and to to the places¶

22 I just mentioned where [REDACTED] was¶

23 on the plane with you?¶

24 MR. PAGLIUCA: Objection to the¶

25 form and and foundation.¶

2 A. I already testified that I don't¶

3 recall Virginia on any of these flights.¶

4 Q. I would like to mark, as Maxwell 7,¶

5 I will put it at the top?¶

6 (Maxwell Exhibit 7, photo, marked¶

7 for identification.)¶

8 MR. PAGLIUCA: Has this document¶

9 been produced in discovery?¶

10 MS. McCAWLEY: Yes.¶

11 MR. PAGLIUCA: Do you have a 12 number? 13 MS. McCAWLEY: This one doesn't. 14 Q. I'm going to ask you -- 15 MR. PAGLIUCA: I don't recall 16 seeing this document so I would like to 17 see a number document before we 18 ask questions about it. 19 MS. McCAWLEY: Can you go look for 20 it and I will continue. We will set 21 that aside until we get a number. 22 You may want to leave that log up and 23 set it to the side and we will bounce¶

24 back to that.¶

25 Q. Do you recall -- I think earlier¶

2 you said you visited Jeffrey's island, I¶

3 think they called it St. Jeffrey or St.¶

4 James, the U.S. Virgin Island home.¶

5 A. St. James.¶

6 Q. Do you recall whether¶

7 was ever on that island?¶

8 A. Categorically, definitively,¶

9 absolutely, without a shadow of a doubt, when¶

10 I was present or any other time that I am¶

11 aware of, was ever on that¶

12 island, I do not believe he went to that¶

13 island ever ever, that is an absolute¶

14 fabrication and an absolute flat out lie¶

5 Q. Was¶

U ever at any of Jeffrey¶

iv EpsLeIn's homes when you present, other than¶

18 the island I know you said that did not¶

19 happen, the home in either New York or Palm¶

20 Beach or New Mexico?¶

21 A. I do not believe at any time¶

22 was at any of Jeffrey's¶

23 homes, I have absolutely no knowledge or¶

24 otherwise that he was ever there.¶

25 Q. You don't recall having dinner with¶

2 him at any of those homes?¶

3 A. Again, Virginia is absolutely¶

4 totally lying. This is a subject of¶

5 defamation about Virginia and the lies she¶

6 has told and one of lies she told was that¶

7 President Clinton was on the island where I¶

8 was present. Absolutely 1000 percent that is¶

9 a flat out total fabrication and lie.¶

10 Q. You did fly on planes, Jeffrey¶

11 Epstein's planes with President Clinton, is¶

12 that correct?¶

13 A. I have flown, yes.¶

14 Q. Would it be fair to say that¶

15 President Clinton and Jeffrey are friends?¶

16 A. I wouldn't be able to characterize¶

17 it like that, no.¶

18 Q. Are they acquaintances?¶

19 A. I wouldn't categorize it.¶

20 Q. He just allowed him to use his¶

21 plane?¶

22 A. I couldn't categorize Jeffrey's¶

23 relationship.¶

24 Q. When you were on the plane with¶

25 Jeffrey and President Clinton, did you¶

2 observe Jeffrey and¶

3 talking?¶

4 A. I'm sure they did.¶

5 Q. Did they seem friendly?¶

6 A. I don't recollect.¶

7 Q. Was Epstein one of the original¶

8 people that conceived the¶

9¶

10 MR. PAGLIUCA: Objection to the¶

11 form and foundation.¶

12 Q. Do you know?¶

13 A. I don't have I don't know what¶

14 you are talking about.¶

15 Q. You don't know what I'm talking¶

16 about.¶

17 Did you ever, not at one of houses,¶

18 but did you ever eat dinner with¶

19 and Jeffrey Epstein?¶

20 A. Are you just talking in general¶

21 anywhere.¶

22 Q. In general?¶

23 A. I believe on a plane of this nature¶

24 we would have had a meal.¶

25 Q. But not outside of the travel on¶

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 I don't recollect where we stayed.¶

3 Q. Do you recollect if you stayed at¶

4 the same place stayed? In¶

5 other words, if you left the plane to go a¶

6 hotel did you all go together is your¶

7 recollection?¶

8 A. I honestly don't recollect, no.¶

9 Q. Part of this trip we were just 10 talking about, there is a flight that goes to¶

11 Thailand, do you remember being in Thailand?¶

12 MR. PAGLIUCA: Objection to the 13 form and foundation.¶

14 A. Are you asking me --¶

15 Q. On the trip.¶

16 A. Are you referencing something?¶

17 Q. The part that, let me make sure¶

18 I've got it here. The entry that would be 19 the Thailand, would be the one -- let me make 20 sure I'm correct. I have you on the wrong¶

21 page, it's actually the page before. It's¶

22 going to be And it's going to be the¶

23 entry on starting on and then¶

24 it goes down to where it has the same as¶

25 above, to -- I'm saying¶

2¶

3 MR. PAGLIUCA: That's what the¶

4 document says.¶

5 Q. I'm not representing the date but¶

6 there it is. So the last leg of that where¶

7 it says same as above has, the second to¶

8 last, I'm sorry on the¶

1¶

10 Do you remember being in Thailand¶

11 with ?¶

12 A. I do.¶

13 Q. Do you remember what the purpose of¶

14 that trip was?¶

15 A. I don't.¶

16 Q. Do you know whether -- do you¶

17 recall, did you stay the night in Thailand?¶

18 A. I don't recall.¶

19 Q. Do you recall why you went to¶

20 Thailand?¶

21 A. I don't recall.¶

22 Q. Who is 7¶

23 A. She I believe was a stewardess on¶

24 this flight.¶

25 Q. Did she perform any massages on the¶

2 flight?¶

3 A. I don't recollect any massages on 4 the flight.¶

5 Q. Do you know who is?¶

6 A. It doesn't -- no I don't know who 7 that is, I can't recall.¶

8 Q. This is not in color, it's a black 9 and but it has the label on it.¶

10 Should I take the sticker off the one that 11 has -- I don't know if you want to swap it.¶

12 MR. PAGLIUCA: Let the record 13 reflect I am replacing this on the black 14 and copy of this exhibit with 15¶

16 Q. So, we were talking earlier, we 17 were looking at the flight logs and we were 18 talking about a trip and let me just get you 19 back to the page.¶

MI IN U •¶

2 Q. Can I direct your attention to the 3 picture, please.¶

4 A. Of course.¶

5 Q. Can you tell me who is in this 6 picture, who is pictured here, and for the 7 court reporter's benefit, can you go from the 8 left of the picture to the right of the 9 picture, to the extent you can identify the 10 individuals?¶

11 A. Sure. I cannot identify the person 12 on the left, I cannot identify the person 13 next left. I can identify Jeffrey Epstein. 14 I cannot identify the next person to his 15 right and the next person in the picture is 16 myself.¶

17 Q. Is the individual all the way to 18 the left at the beginning of the picture, 19 does that resemble . You might 20 want to look at the color version if that 21 helps you at all, I know it's not the marked 22 one. I don't if that's easier to see, they 23 are both dark.¶

24 A. That does not look like 25 at all.¶

2 Q. Do you recall --¶

3 MR. PAGLIUCA: Let's mark this then¶

4 as deposition Exhibit 8 since we are¶

5 referring to it and then you can give us¶

6 copies as well.¶

7 MS. MENNINGER: It's different¶

8 because it has other people in this¶

9 color photo.¶

10 (Maxwell Exhibit 8, photo, marked¶

11 for identification.)¶

12 Q. Do you recall who took this¶

13 photograph?¶

14 A. I do not.¶

15 Q. Do you recall this photograph being¶

16 taken by Virginia?¶

17 A. First of all, I don't know where we¶

18 are.¶

19 Q. So you don't recognize the¶

20 building?¶

21 A. I don't recognize the building and¶

22 I don't recognize -- the only two people I¶

23 recognize in the picture are Jeffrey and¶

24 myself.¶

25 Q. Does this like look a picture of a¶

2     building that you would have seen when you¶

3      were on the trip in Europe?¶

4 MR. PAGLIUCA: Objection to the¶

5 form and foundation.¶

6                                  A.                      I can't possibly answer that.¶

7           Q.       Do you recall Virginia ever taking¶

8 pictures?¶

A. I barely recall Virginia, period.¶

10                      Q.                  Do you recall her ever taking¶

11 pictures?¶

12 A. No, I don't.¶

13           Q.           I'm going to direct your attention,¶

14 still within the flight logs to -- starting¶

15 on the next page from where you just were¶

16           which is going to be [REDACTED]           And the date at¶

17 the top says [REDACTED] you will see [REDACTED] and I'm¶

18 directing your attention downwn towards the¶

19 middle to the bottom where you will see the¶

20 numbers [REDACTED]¶

21 A. Uh-huh.¶

22           Q.           And we've got actually I'm going to¶

23 direct your attention to the one that starts¶

24 with [REDACTED]¶

[REDACTED]¶

2 and in the line, the remarks line you will¶

3 see JE, GM,¶

5 MR. PAGLIUCA: Are you reading the¶

6 29th, is that what you're reading?¶

7 MS. McCAWLEY: I'm reading the¶

8 29th, yes.¶

9 Q. Below that you will see JE, GM, III¶

10¶

11¶

12 Do you see that?¶

13 A. I do.¶

14 Q. Do you recall a trip from Teterboro¶

15 to Santa Fe and Santa Fe back to Palm Beach¶

16 with these individuals?¶

17 A. I don't.¶

18 Q. Do you recall being on a plane with¶

19 and¶

20 A. I don't.¶

21 Q. Do you recall ever witnessing any¶

22 sexual interaction on one of Jeffrey's planes¶

23 with any of these individuals?¶

24 A. I do not, absolutely not.¶

25 Q. Did Jeffrey have a fold out bed on¶

2 one of his planes?¶

3 A. There was a bed on one of his¶

4 planes that folded out, yes.¶

5 Q. Do you recall whether with respect¶

6 to this being in Santa Fe, do you recall¶

7 whether you were there for some form of a¶

8 party?¶

9 MR. PAGLIUCA: Objection to the¶

10 form and foundation.¶

11 A. I don't recall the trip at all and¶

12 this looks like a total work trip, not a¶

13 party trip.¶

14 Q. What would be the difference¶

15 between a work trip and a party trip?¶

16 A. Just that I would be on trips for¶

17 work and I believe that this looks like, II¶

18 looks like it's one of the -- probably one of¶

19 the designers and the time would meet with a¶

20 trip to decorate the house, just the timing¶

21 of it.¶

22 Q. So would Virginia be brought on¶

23 trips that were for the purpose of work and¶

24 decorating the house?¶

25 A. Like I said, I never worked with¶

2 her but you would have to ask Jeffrey what he 3 brought her on the trip for.¶

4 Q. But she would travel with him when 5 there was a work trip like this?¶

6 A. I can't -- I'm seeing that she is 7 on this flight but I have no idea what she is 8 doing, he invited her, it would not be my 9 job.¶

10 Q. What about, would she 11 regularly travel with Jeffrey on flights?¶

12 A. I have no idea, you would have to 13 look through the flight logs. I have no 14 idea.¶

15 Q. Your recollection is -- what is 16 your recollection, do you recollect Nadia 17 traveling often on flights with Jeffrey?¶

18 A. Absolutely not. No, not at all. I 19 don't recollect her actually on the flight at 20 all.¶

21 Q. I think you can set that aside for 22 the moment.¶

23 (Maxwell Exhibit 9, message pad 24 pages, marked for identification.)¶

25 Q. We will mark as Exhibit 9 these¶

2 excerpts from -- we will identify what they 3 are but from the message pads.¶

4 Did you want to correct anything?¶

5 A. I want to make an addendum.¶

6 Would you mind rereading the last 7 question back to me?¶

8 (Record read.)¶

9 A. I also just want to say that at 10 this point I cannot recollect flying to 11 parties. Jeffrey went for work so -- was 12 this in Santa Fe, this flight as well.¶

13 Q. The flight we were looking at, yes 14 but it was to Santa Fe --¶

15 A. I don't recall going to any parties 16 in Santa Fe at any time but certainly flying 17 to Santa Fe for a party seems highly 18 improbable.¶

19 Q. So I'm going to direct your 20 attention to the document that I set before 21 you which is number and it 22 has different numbers because it's a 23 smaller version of the larger production.¶

24 These are the pages I will be asking about.¶

25 In the time that you were working¶

2 with Jeffrey in Palm Beach, do you recall a¶

3 process for taking, anybody at the house¶

4 taking messages when incoming phone calls¶

5 came in?¶

6 A. You are supposed to take a message¶

7 and receive the message and write the message¶

8 down. Who was the message was for, what time¶

9 it was taken and who took it and what the¶

10 message was, obviously.¶

11 Q. Does what's in front of you look¶

12 familiar with respect to the message pads¶

13 that you would have used at the house?¶

14 A. It is familiar.¶

15 Q. I'm going to direct your attention¶

16 to the second page of it?¶

17 MR. PAGLIUCA: These all have SAO¶

18 numbers on them or ranges and I¶

19 don't see any of your ranges on¶

20 these. I know you have produced message¶

21 pads but those have your range¶

22 numbers on them and I'm wondering if¶

23 these are different documents.¶

24 MS. McCAWLEY: It's the same, just¶

25 ours have the underneath them.¶

2 These were produced as part of the rule 3 26 discovery. We can get the additional 4 if you want.¶

5 Q. The one I'm asking about first is 6 the You can look at that and then 7 I will identify the number referenced 8 in this case.¶

9 I want to direct your attention to 10 the top right-hand corner just so I have an 11 understanding of how these messages were 12 taken. So I see that it says at the top it 13 says in the for line it says Ms. Maxwell and 14 the date of and then I see under the 15 M line it looks like or 16 something like that, a phone number and a 17 message saying returning your call and on the 18 bottom it looks like¶

19 Explain to me, is this does this 20 represent taking down a message for you 21 from is that how these work?¶

22 MR. PAGLIUCA: Objection to the 23 form and foundation. Go ahead.¶

24 Q. My question is, I'm trying to 25 understand how the messages were taken.¶

2 Looking at this message pad, where it says¶

3 signed can you tell me who was?¶

4 A. I cannot.¶

5 Q. You do not know.¶

6 Typically when these messages were¶

7 taken in your practice when you were there,¶

8 would the individual who took the message¶

9 write their name on the message?¶

10 MR. PAGLIUCA: Objection to the¶

11 form and foundation.¶

12 A. I don't recollect, you can ask who 13 wrote it so you can find out who it was. 14 Q. Do you know who is? 15 A. I don't. 16 Q. I'm going to direct your 17 attention -- do we have a number for 18 that? 19 MR. -: 20 Q. for that one. 21 I will direct your attention to the 22 first page which has the on it. 23 A. Okay.¶

24 Q. Now at the top of that document, on¶

25 the right-hand side, the message that reads¶

2 for JE, date, message¶

3 and then it's signed GM.¶

4 Is that your signature?¶

5 A. That's not my handwriting¶

6 Q. Would other people take a message,¶

7 how did this process work, is there someone¶

8 else in the house with the initials GM?¶

9 MR. PAGLIUCA: Objection to the¶

10 form and foundation.¶

11 A. I cannot answer that. It's not my¶

12 handwriting.¶

13 Q. I'm trying to understand how this¶

14 gets there. If you took a message and didn't¶

15 write it down, would someone else record that¶

16 message for you?¶

17 MR. PAGLIUCA: Objection to the¶

18 form and foundation.¶

19 A. All I can tell you, this is not my¶

20 handwriting so I cannot -- I have no idea¶

21 what that is.¶

22 Q. Was the practice that, what was the¶

23 practice when someone answered the phone with¶

24 these message pads, what were they supposed¶

25 to do?¶

2 3 4 A. They were supposed to take a message and the time and date and give the message.¶

5 6 Q. Were they supposed to indicate who took the message?¶

7 8 9 10 11 what that was. A. They were but it wasn't -- I don't really recall the actual process. I can see from here it looks like you were supposed to but that's not my handwriting so I can't say¶

12 Q. Do you know who is?¶

13 A. No, I don't.¶

14 Q. Do you know whether 15 was under the age of 18?¶

16 A. I just testified 17 18 to know how old she was. I couldn't remember who she was so it would be difficult¶

19 20 Q. Do you know if she was coming to the house to provide massages?¶

21 22 A. I don't remember who she is at all, so no.¶

23 Q. 24 25 underneath it. Which says JE, And then I would like to direct your attention to the message right f¶

2 and has a phone number and the message says,¶

3 wants to know if she should bring her friend¶

4 tonight.¶

5 What is that message referring to?¶

6 MR. PAGLIUCA: Objection to the¶

7 form and foundation.¶

8 A. I can't possibly know.¶

9 Q. Did individuals at the house take 10 messages for underage girls to come over and 11 bring friends for the purpose of providing 12 massages?¶

13 MR. PAGLIUCA: Objection to the¶

14 form and foundation.¶

15 A. How would I possibly know what you 16 are talking about.¶

17 Q. Did you record messages at the 18 house?¶

19 A. It's not my job.¶

20 Q. You did from time to time record 21 messages?¶

22 A. Hardly ever.¶

23 Q. But you did from time to time do 24 it?¶

25 A. I'm just saying I hardly ever took¶

2 messages, very, very, very, very¶

3 infrequently.¶

4 Q. Do you know if brought her¶

5 friend over on that night?¶

6 MR. PAGLIUCA: Objection to the¶

7 form and foundation.¶

8 A. One, I don't know what this message¶

9 is, I don't know if I was in Palm Beach, I¶

10 don't know who is, I don't know who¶

11 is and I don't know what this message¶

12 is referring to.¶

13 Q. So on January 2nd of 2003, were you¶

14 in Palm Beach?¶

15 A. I don't know.¶

16 Q. Where would you have been other¶

17 than Palm Beach at the time?¶

18 A. I could have been anywhere.¶

19 Q. Where did you typically live?¶

20 A. What are you asking me?¶

21 Q. So for example, in 2003, where was¶

22 your primary residence, was it wherever¶

23 Jeffrey was living and staying or was it¶

24 independent of that?¶

25 A. What was the date again.¶

2 Q. In 2003?¶

3 A. The end of 2003?¶

4 Q. January, the beginning.¶

5 A. I don't know, I could have been 6 anywhere, Jeffrey and I were leading almost 7 separate lives by then.¶

8 Q. If you were at the house that day, 9 did you recall seeing anybody by the name of 10¶

11 MR. PAGLIUCA: Objection to the 12 form and foundation.¶

13 A. I don't know if I was at the house, 14 so I can't testify to that.¶

15 Q. Let's flip back to the next page, 16 the one we were on before the the 17 message towards the bottom that says, for 18 Jeffrey, message of Ghislaine. And it says, 19 Would it be helpful to have and then redacted 20 come to Palm Beach today to stay here and 21 help train new staff with Ghislaine. Who 22 were you referring to in that message; do you 23 remember?¶

24 MR. PAGLIUCA: Objection to the 25 form and foundation.¶

2 Q. The question is, do you recall this 3 message?¶

4 A. I do not recall this message.¶

5 Q. Do you recall training a female 6 under the age of 18 at Jeffrey's home?¶

7 MR. PAGLIUCA: Objection to the 8 form and foundation.¶

9 A. I never trained a female under the 10 age of 18 at Jeffrey's home.¶

11 Q. Did you ever say it would be 12 helpful to have a female under the age of 18 13 come to Palm Beach today to stay here and 14 help train new staff with Ghislaine?¶

15 A. I never asked anyone under the age 16 of 18 come to help train new staff.¶

17 Q. I'm going to flip to the next page 18 which is .¶

19 A. By the way, that is not my 20 handwriting and it's not dated and I couldn't 21 possibly tell you who that is.¶

22 Did you hear that?¶

23 Q. You got your testimony on the 24 record.¶

2 A. Yes.¶

3 MR. -:¶

4 Q. I'm going to direct your attention 5 to the top right-hand corner, for Mr. 6 Epstein, , message a phone 7 number and called.¶

8 Do you know who is?¶

9 A. I don't.¶

10 Q. Do you know that was 15 at 11 the time she left this message?¶

12 MR. PAGLIUCA: Objection to the 13 form and foundation.¶

14 A. I don't know who is.¶

15 Q. And then I'm going to direct your 16 attention to the bottom left which is a 17 message JE message of and the 18 message says, He just did a good one, 18 19 years, she spoke to me and said I love 20 Jeffrey.¶

21 Was referring to sex with 22 an 18 year old in that message?¶

23 MR. PAGLIUCA: Objection to the 24 form and foundation.¶

25 A. How could I know what is¶

2 referring to.¶

3 Q. Do you know if had sex¶

4 with an 18 year old that he referenced to¶

5 Jeffrey Epstein?¶

6 MR. PAGLIUCA: Objection to the¶

7 form and foundation.¶

8 A. How could I possibly know.¶

9 Q. Did Jeffrey Epstein or 10 ever tell you that had sex with an¶

11 18 year old?¶

12 MR. PAGLIUCA: Objection to the¶

13 form and foundation.¶

14 A. I have no idea what you are talking 15 about.¶

16 Q. Did they ever tell you that?¶

17 A. I have no recollection of ever¶

18 hearing such a ridiculous thing.¶

19 Q. I will turn to the next page which¶

20 is SAO 2841?¶

21 MS. MENNINGER: Do you have the¶

22 number?¶

23 Q. The bottom right-hand corner, Mr.¶

24 Epstein, the date, Ms. Maxwell, it¶

25 says, it says, quote, is¶

2 available on Tuesday, no one for tomorrow.¶

3 Is this a message you took?¶

4 A. It's not my handwriting and I don't¶

5 know who R is.¶

6 Q. So when it says Ms. Maxwell in the¶

7 line there, is that you calling for Mr.¶

8 Epstein?¶

9 MR. PAGLIUCA: Objection to the¶

10 form and foundation.¶

11 A. I didn't write it, I don't know¶

12 when this message was taken. I don't even¶

13 know what it's referring to and I don't know¶

14 what my name is doing on that message pad.¶

15 Q. I know you said you only took them¶

16 a few times. Do you have a recollection of¶

17 taking messages of females who would call the¶

18 house to indicate whether or not they were¶

19 coming over?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation.¶

22 A. Give me a date range.¶

23 Q. On 7/9/04.¶

24 A. How would I know if I'm in Palm¶

25 Beach, most likely not.¶

2 Q. I'm asking if you have a¶

3 recollection of taking messages for girls who¶

4 would call the house¶

5 A. Girls.¶

6 Q. Females, who would call the¶

7 house --¶

8 A. Over the age of 18.¶

9 Q. is 15.¶

10 A. I don't know who is, so I¶

11 can't testify anything to¶

12 Q. Your name is on the message.¶

13 A. I didn't put it there and I don't¶

14 know what it's doing there.¶

15 Q. So your testimony is you didn't¶

16 take this message?¶

17 A. I obviously didn't take the¶

18 message, it's signed by somebody R, it's not¶

19 my handwriting. We don't know if I'm in Palm¶

20 Beach.¶

21 Q. Did you arrange for to have¶

22 his friend come over on Tuesday of¶

23 this week?¶

24 A. I don't know who is so it¶

25 would be hard for me to arrange anything with¶

2 someone I don't know.¶

3 Q. Why is your name reflected on this¶

4 message pad?¶

5 MR. PAGLIUCA: Objection to the¶

6 form and foundation.¶

7 A. I have no idea. You would have to¶

8 ask whoever took the message.¶

9 Q. Did you, in the course of your¶

10 work, regularly take messages for Jeffrey¶

11 Epstein?¶

12 A. I already testified I hardly ever¶

13 did.¶

14 Q. Would you, in the course of your¶

15 work, regularly set up appointments for¶

16 females to come over and give massages for¶

17 Jeffrey Epstein?¶

18 MR. PAGLIUCA: Objection to the¶

19 form and foundation.¶

20 A. Can you specify, females, you mean¶

21 adults over the age of 18.¶

22 Q. Did you regularly set up for¶

23 Jeffery adults over the age of 18 to come for¶

24 massages?¶

25 A. I didn't regularly do that, no.¶

2 Q. Would you take messages with 3 respect to females over the age of 18 to come 4 over for a massage?¶

5 A. I already testified I hardly ever 6 did take messages.¶

7 Q. But would you?¶

8 A. I already testified, I hardly 9 ever --¶

10 Q. I know hardly ever, but did you?¶

11 A. Over the course of time it is 12 possible I may have taken a couple, I have no 13 recollection. I hardly ever did and I did so 14 irregularly that it would hard for me to 15 pinpoint.¶

16 Q. Did you ever take a message for a 17 female under the age of 18 to come over for a 18 massage or for any other reason to be with 19 Jeffrey Epstein?¶

20 MR. PAGLIUCA: Object to the form 21 and foundation.¶

22 A. I hardly ever took a message. I 23 have absolutely no way of knowing, maybe one 24 of my friends' daughters called to say they 25 were coming to visit me. I have never taken¶

2 messages, I don't know about how I would¶

3 possibly know if somebody I spoke to, one or¶

4 two times I took a message is, how old they¶

5 would be but I have never taken a message¶

6 where I was aware of anything being under the¶

7 age of 18 and I probably took it so¶

8 infrequently, it would be impossible.¶

9 Q. Can you turn to, it¶

10 should be the next page.¶

11 A. Uh-huh.¶

12 Q. Do you see at the top, it says, for¶

13 Mr. J. 11/8/04 and then the name is¶

14 redacted. It says, I have a female for him.¶

15 Why would a minor be calling¶

16 Jeffrey to say they have a female for him?¶

17 Do you know?¶

18 MR. PAGLIUCA: Objection to the¶

19 form and foundation.¶

20 A. First of all, I don't know that's a¶

21 minor, I don't know who took the message.¶

22 Q. I will represent to you these are¶

23 police reports and minor's names have to be¶

24 redacted for privacy purposes?¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 Q. Do you know why a minor child would¶

4 be calling Jeffrey and leaving a message to¶

5 say, quote, I have a female for him?¶

6 MR. PAGLIUCA: Objection to the¶

7 form and foundation.¶

8 A. I can't testify anything about this¶

9 message, I don't know anything about it.¶

10 Q. I'm going to direct your attention¶

11 to the next page . If you look at¶

12 the bottom left, you are going to see a¶

13 message for Jeffrey, from, it¶

14 says she doesn't have a number and left a¶

15 message that she called.¶

16 Do you know who¶

17 A. I do not.¶

18 Q. Do you know that¶

19 13 at the time she placed this call to¶

20 Jeffrey?¶

21 A. I don't know who is.¶

22 Q. Would Jeffrey regularly have 13¶

23 year olds call and leave messages?¶

24 MR. PAGLIUCA: Objection to the¶

25 form and foundation.¶

2 A. How would I possibly, these were 3 messages taken when I was not at the house 4 and I have no idea who they are nor how old 5 they are nor anything.¶

6 Q. How do you know you weren't at the 7 house on this day?¶

8 A. I was hardly at the house in 2005.¶

9 Q. So you could have been there, you 10 just don't know?¶

11 A. In the five days I might have been 12 there in 2005, I suppose it's possible but 13 it's unlikely.¶

14 MR. PAGLIUCA: Do you know why this 15 isn't redacted if you are representing 16 all the names of people who are underage 17 have been redacted from these records.¶

18 MS. McCAWLEY: I think it was -- my 19 assumption is it was a miss by the 20 police department.¶

21 Q. I will direct your attention to 22 so you will skip a page and go back, 23 it's the final page in the message pads and 24 you will see on the top left for Jeffrey, on 25 6/1/2005 from with a phone¶

1 G Maxwell - Confidential 2 number. It says, quote, He has a teacher for 3 you to teach you how to speak Russian. She 4 is two times eight years old. Not blond. 5 Lessons are free and you can have your first 6 today if you call.¶

7 Do you know whether 8 sent a Russian girl that was 16 years old 9 over to Jeffrey Epstein's home?¶

10 MR. PAGLIUCA: Objection to the 11 form and foundation.¶

12 A. I do not know.¶

13 Q. Did you ever observe a Russian girl 14 that was 16 years old come to Jeffrey 15 Epstein's home?¶

16 A. I am not aware of any 16 year old 17 Russian girl that I can recall in Jeffrey 18 Epstein's home.¶

19 Q. Do you know whether Jeffrey Epstein 20 had sex with a 16 year old Russian girl?¶

21 MR. PAGLIUCA: Objection to the 22 form and foundation.¶

23 A. I do not know.¶

24 THE VIDEOGRAPHER: It's 12:25.¶

25 This will be the end of disk 3, we are¶

2 off the record.¶

3 (Recess.)¶

4 AFTERNOON SESSION¶

5 (Time noted: 1:21 p.m.)¶

6 GHISLAINE MAXWEL L,¶

7 resumed and testified as follows:¶

8 EXAMINATION BY (Cont'd.)¶

9 MS. McCAWLEY:¶

10 THE VIDEOGRAPHER: It's now 1:21,¶

11 we're starting disk No. 4. We are back¶

12 on the record.¶

13 Q. Ms. Maxwell, before the break, we¶

14 were talking about and I think it's one of¶

15 the exhibits that's marked in front of you,¶

16 I'm not sure of the number, but the police¶

17 report that I showed you earlier today.¶

18 Now that you have knowledge of the¶

19 police report and the criminal investigation¶

20 with respect to Jeffrey Epstein, do you¶

21 believe that Jeffrey Epstein abused any minor¶

22 children?¶

23 MR. PAGLIUCA: Objection to the¶

24 form and foundation.¶

25 A. Can you repeat the question please¶

2 and break it down so it's more¶

3 understandable.¶

4 Q. Now that you have the police report¶

5 that I showed you this morning that you had¶

6 an opportunity to look at.¶

7 A. You gave it to me, I did not look¶

8 at it.¶

9 Q. The questions that I asked you¶

10 about the police report you are aware¶

11 there is a police report?¶

12 A. I am aware there is a police¶

13 report.¶

14 Q. You are aware there was a criminal¶

15 investigation of Jeffrey Epstein?¶

16 A. I am aware that there was that.¶

17 Q. Now that you are aware of those two¶

18 things and having talked to Jeffrey Epstein,¶

19 do you believe Jeffrey Epstein sexually¶

20 abused minors?¶

21 MR. PAGLIUCA: Objection to the¶

22 form and foundation.¶

23 A. Can you reask the second part of¶

24 that question please.¶

25 Q. Sure. The two documents we were¶

1 G Maxwell - Confidential 2 talking about, the document and the 3 investigation, you said you are aware of and 4 after having talked to Jeffrey Epstein, do 5 you believe Jeffrey Epstein sexually abused 6 minors?¶

7 MR. PAGLIUCA: Objection to the 8 form and foundation.¶

9 A. What do you mean I talked to 10 Jeffrey, you need to break the question down 11 further.¶

12 Q. So you have the police report.¶

13 A. I do.¶

14 Q. And you are aware of the criminal 15 investigation?¶

16 A. I am.¶

17 Q. Let's take those two things After 18 knowing those two things, do you believe that 19 Jeffrey Epstein abused minor children?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. Can you explain what you mean by 23 the question actually.¶

24 Q. I think the question speaks for 25 itself. I will try again. I will say it one¶

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 believe. Do you believe --¶

3 A. I can only testify --¶

4 Q. Let me finish the question so the 5 record is clear.¶

6 Do you believe Jeffrey Epstein¶

7 sexually abused minors?¶

8 MR. PAGLIUCA: Objection to the 9 form and foundation.¶

10 Q. You can answer.¶

11 A. I can only testify to what I know.¶

12 I know that Virginia is a liar and I know¶

13 what she testified is a lie. So I can only¶

14 testify to what I know to be a falsehood and¶

15 half those falsehoods are enormous and so I¶

16 can only categorically deny everything she¶

17 has said and that is the only thing I can¶

18 talk about because I have no knowledge of¶

19 anything else.¶

20 Q. I'm not asking about Virginia. I'm¶

21 asking whether you believe that Jeffrey¶

22 Epstein sexually abused minors?¶

23 A. Again, I repeat, I can only go on¶

24 what I know and what I know is a falsehood¶

25 based on what Virginia said.¶

2 Q. Do you believe Jeffrey Epstein¶

3 sexually abused minors?¶

4 A. Again, I repeat, Virginia is a liar¶

5 and based on Virginia's stories, that is¶

6 what -- she lied and I can only then talk¶

7 about what you've showed me in the police¶

8 reports and I know he went to jail.¶

9 Q. Do you believe that Jeffrey Epstein¶

10 sexually abused minors? I'm asking about¶

11 your belief.¶

12 A. Again, I just repeat, I can only¶

13 go -- my belief is Virginia is a liar.¶

14 Q. What is that belief?¶

15 A. She is an absolute liar and¶

16 everything she said is a lie and therefore,¶

17 everything that stems from that is a lie.¶

18 Q. So do you believe that Jeffrey¶

19 Epstein sexually abused minors?¶

20 A. Again -- can we move on from here?¶

21 Q. No. You are going to answer the¶

22 question.¶

23 A. I have already.¶

24 Q. No, you haven't.¶

25 A. I have.¶

2 Q. Do you believe Jeffrey Epstein¶

3 sexually abused minors?¶

4 A. Again, I repeat, the only person I¶

5 know who has talked about these things that I¶

6 have personal -- was personally present, was¶

7 Virginia and I can only talk to Virginia and¶

8 she is a liar.¶

9 Q. Setting aside Virginia. Take her¶

10 out of the picture. It's my question.¶

11 A. We are here today because of¶

12 Virginia and her lies because this is a¶

13 defamation suit.¶

14 Q. Setting aside Virginia, do you¶

15 believe Jeffrey Epstein sexually abused¶

16 minors?¶

17 A. I cannot set aside Virginia because¶

18 that's why we are here and this is the only¶

19 reason I am sitting here in this room and I¶

20 will not set her aside and I cannot comment¶

21 about anything else except her because she is¶

22 the only person I actually know about.¶

23 Q. Are you refusing to answer that¶

24 question?¶

25 A. I am not refusing the question. I¶

2 can only testify about Virginia who is an 3 absolute total liar and you all know she is. 4 She lied about her age, you know she lied 5 about absolutely everything. So I can only 6 go on what I know as a liar and she is a 7 liar, an exaggerator, a fantasist and 8 absolutely true terrible person.¶

9 Q. I want you to listen very 10 carefully. I am asking you to set aside 11 Virginia.¶

12 A. I can't set aside Virginia.¶

13 Q. I am asking you to do that for 14 purposes of this question.¶

15 MR. PAGLIUCA: She doesn't have to.¶

16 MS. McCAWLEY: She can refuse to 17 answer the question.¶

18 A. I'm not refusing to answer the 19 question.¶

20 Q. You are refusing.¶

21 My question has nothing to do with 22 Virginia. Let me make the record here. My 23 question has nothing to do with Virginia. I 24 want it to be clear for the court. My 25 question has nothing to do with Virginia.¶

2 what I'm asking you is whether you¶

3 believe Jeffrey Epstein abused minors?¶

4 MR. PAGLIUCA: I object to the form¶

5 and you made your record, she answered¶

6 the question. A fair reading of her¶

7 answer is she doesn't have a belief¶

8 because she doesn't have any personal¶

9 knowledge.¶

10 MS. McCAWLEY: Now you are¶

11 testifying for the witness. Let her¶

12 answer the question.¶

13 MR. PAGLIUCA: It's a fair answer¶

14 to the question.¶

15 A. Again, I testified my only personal¶

16 knowledge concerns Virginia and everything¶

17 Virginia has said is an absolute lie, which¶

18 is why we are here in this room. If you are¶

19 asking me to testify about things I have no¶

20 knowledge of other than the police report¶

21 that you showed me, I am not in a position to¶

22 make a statement based on that because you¶

23 are asking me to speculate and I cannot¶

24 speculate.¶

25 Q. I'm asking you about your belief.¶

2 I'm not asking you to speculate at all. I'm 3 asking what you believe.¶

4 A. You are asking me to speculate and 5 I won't speculate.¶

6 Q. I'm not asking you to speculate.¶

7 I'm asking what you believe.¶

8 MR. PAGLIUCA: She answered the 9 question and we can move on.¶

10 MS. McCAWLEY: She hasn't answered 11 the question.¶

12 MR. PAGLIUCA: We are not going to 13 engage in this debate. She answered the 14 question. If you want to mark it and 15 move to compel an answer to the 16 question, have at it. Okay.¶

17 Q. Ms. Maxwell, is it your belief that 18 Jeffrey Epstein interacted sexually with 19 minors?¶

20 A. Again, you are asking me the same 21 type of question exactly but with different 22 language. Again, my only knowledge of 23 somebody who claims these things that I have 24 personal knowledge of is Virginia. Virginia 25 is an absolute liar and everything she has¶

2 said is a lie. Therefore, based on those 3 lies I cannot speculate on what anybody else 4 did or didn't do because if Virginia is the 5 example of what that story is and everything 6 she said is false, so everything that leads 7 from that is false.¶

8 Q. So the 30 other minor children in 9 the police report are also telling lies about 10 being sexually abused during massages with¶

11 Mr. Epstein?¶

12 MR. PAGLIUCA: Objection to the 13 form and foundation. Counsel, can you 14 show me in these police reports who the 15 30 minors are?¶

16 MS. McCAWLEY: I'm asking my 17 question.¶

18 MR. PAGLIUCA: You are making a 19 representation about numbers, you are 20 making a representation on the record 21 about what people said or didn't say. 22 We have no knowledge about that. These 23 are all redacted records so these are 24 bad questions. They don't lead to any 25 admissible evidence. It is only being¶

2 propounded to the witness to harass her.¶

3 So we are done with these questions.¶

4 MS. McCAWLEY: Are you done?¶

5 MR. PAGLIUCA: Yes.¶

6 Q. My question is, are you aware that¶

7 Jeffrey Epstein was convicted of having¶

8 relations with a minor child?¶

9 MR. PAGLIUCA: She answered that¶

10 question already.¶

11 MS. McCAWLEY: I'm getting to my¶

12 next question.¶

13 MR. PAGLIUCA: Ask your next¶

14 question. Don't keep asking the same¶

15 question.¶

16 MS. McCAWLEY: You are now¶

17 shouting, I want the record to reflect¶

18 that you are interrupting the¶

19 deposition. I ask you to calm down,¶

20 take a deep breath and please let me ask¶

21 my questions.¶

22 MR. PAGLIUCA: Your behavior is¶

23 inappropriate.¶

24 Q. I will ask you again.¶

25 Do you believe that Jeffrey Epstein¶

2 interacted sexually with minors?¶

3 A. Again, I go back to this, my only¶

4 actual knowledge is with Virginia and¶

5 Virginia is a liar, so I can only talk to¶

6 what Virginia's story and as I said before¶

7 and there are so many examples, I mean¶

8 thousands of examples of her lies, that that¶

9 is the only thing I can talk to.¶

10 Q. Based on that you do not believe¶

11 that Jeffrey Epstein sexually abused minors?¶

12 A. Again, as I said, I'm only talking¶

13 to what I know, I can only talk to Virginia.¶

14 Q. So is it your belief that Jeffrey¶

15 Epstein did not sexually abuse minors?¶

16 A. Again, I can only talk to what I¶

17 know and I know that Virginia is a liar and¶

18 that what she said is a lie. So I can only¶

19 testify to what she accused and you guys put¶

20 in the press for salacious purposes and¶

21 whatever terrible, inappropriate, unethical¶

22 and terrible reasons you chose to do that¶

23 about me and I can testify those are all¶

24 lies.¶

25 Q. Do you know whether Jeffrey Epstein¶

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?¶

8 MR. PAGLIUCA: Objection to the¶

9 form and foundation.¶

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 Q. Was there a computer available for 3 use in the Palm Beach house?¶

4 A. Can you be more specific.¶

5 Q. Was there anywhere in the Palm 6 Beach house where there was a computer where 7 you said you worked for him and there were 8 other staff in the house, was there ever a 9 computer in the Palm Beach mansion that was 10 accessible by you or other staff?¶

11 MR. PAGLIUCA: Objection to the 12 form and foundation.¶

13 A. I stopped being regularly at the 14 house sometime in 2003 so from 2003 to when 15 the police search was executed, I have no 16 memory of what there was or what there was 17 not. I can only testify for what was there 18 when I was present largely.¶

19 Q. So in 2003 when you were still 20 there, was there a computer that was 21 accessible to you or other staff at the 22 house?¶

23 MR. PAGLIUCA: Objection to the 24 form and foundation.¶

25 A. There was a desktop computer that¶

2 people could use -- just like you would use¶

3 if you needed to go online to get something,¶

4 that people could use.¶

5 Q. Was that on a desk that you would¶

6 use in your work capacity when you were at¶

7 the house?¶

8 A. It was a desk, it was a room I was,¶

9 I didn't really use that computer.¶

10 Q. Were there images of naked girls¶

11 whether they be under the age of 18 or over¶

12 the age of 18 on that computer?¶

13 A. I have no recollection of any naked¶

14 people on that computer when I was there in¶

15 2003, we are talking.¶

16 Q. What about from say '99 to 2003?¶

17 A. No, I can't recollect any naked¶

18 pictures.¶

19 Q. Why were the computers removed from¶

20 the house before the search warrant was¶

21 executed?¶

22 MR. PAGLIUCA: Objection to the¶

23 form and foundation.¶

24 A. I have no knowledge of anything¶

25 like that.¶

2 Q. Do you know where the computers are 3 now?¶

4 MR. PAGLIUCA: Objection to the 5 form and foundation.¶

6 A. I don't know what computers you are 7 talking of and I have no idea what you are 8 referencing.¶

9 Q. In 2003 you said there was a 10 computer in a room on a desk?¶

11 A. Right.¶

12 Q. Do you know where that computer is 13 now?¶

14 A. I do not.¶

15 Q. Did you take pictures of nude 16 females in any of Epstein's homes or in and 17 around the homes, out by the pool or anywhere 18 like, in the Palm Beach home, the New York 19 home, USVI home or the New Mexico home?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. Can you repeat the question.¶

23 Q. Did you take pictures of nude woman 24 over 18 or under 18, females, in any of 25 Jeffrey Epstein's homes, inside or outside in¶

2 or around the home?¶

3 A. I think we need to distinguish 4 between anyone under the age of 18 and over 5 the age of 18.¶

6 Q. We will start with, did you take 7 pictures of nude females in or around any of 8 Jeffrey's homes of women or females that were 9 under the age of 18?¶

10 A. No.¶

11 Q. Did you take pictures of nude 12 females¶

13 A. Nude you mean with no clothing on.¶

14 Q. Or half nude, with no top on, any 15 sort of nakedness to an individual.¶

16 In any of Jeffrey's homes, either 17 Palm Beach, New Mexico, USVI or New York 18 either outside by the pool, anywhere in or 19 around those homes of females over the age of 20 18?¶

21 A. So it is possible that I took 22 pictures of people that were somehow semi or 23 had some clothing on or no clothes on but at 24 no time were any of these pictures remotely 25 inappropriate. They were, you could see them¶

2 in a mainstream magazine today, there would 3 be no inappropriateness, they would be 4 covered, concealed, you wouldn't see anything 5 at all.¶

6 The types of -- first, I took very 7 few and they were always by request, this was 8 a picture you could put on your -- gift to 9 your parent or to your grandparents to put on 10 their mantel piece . It would be a very 11 benign sort of attractive picture where you 12 wouldn't see anything.¶

13 Q. Who would request those pictures?¶

14 A. From time to time, people, men and 15 women would ask to have nice photographs of 16 them taken.¶

17 Q. And did Jeffrey Epstein request 18 those pictures?¶

19 A. I don't ever recall him asking me 20 to take pictures.¶

21 Q. Did you give him pictures of naked 22 females as a present?¶

23 A. I don't recall ever giving a 24 present of -- I don't know why a photograph 25 would constitute a gift.¶

2 Q. Not as a gift.¶

3 Do you recall ever giving Jeffrey¶

4 Epstein pictures that you've taken of these 5 individuals in a naked state?¶

6 MR. PAGLIUCA: Objection to the 7 form and foundation.¶

8 A. First of all, we've already 9 established that they are not naked state 10 photographs.¶

11 Q. A piece of them being naked as you 12 described.¶

13 A. I said they would be attractive as 14 you would see in mainstream magazines and 15 those pictures could be a picture of a hand 16 or a foot, they didn't necessarily 17 constitute -- I know where you are headed 18 with this and it's nowhere appropriate and 19 it's really unattractive.¶

20 Q. I'm not headed anywhere. I'm just 21 asking the questions. Did you give Jeffrey 22 Epstein any of these pictures that you took 23 of females in the state that you described?¶

24 A. I can't recall ever giving him 25 pictures but it is possible that I took¶

2 pictures of people that would end up -- or a 3 friend of his that he would have -- not naked 4 or not inappropriate in any way, that he 5 might have somewhere in his house.¶

6 Q. Name for me all the individuals who 7 you took these pictures of?¶

8 A. It's entirely impossible for me to 9 name people. First of all, it was just -- it 10 would not be possible, I took thousands of 11 photos, not of people, I mostly take pictures 12 of landscapes and things. I have no 13 recollection specifically of people that I 14 took pictures of.¶

15 Q. So you can't remember, is it your 16 testimony you can't remember one person that 17 you took a picture of in either a naked or 18 semi naked state?¶

19 A. I seriously cannot recall. I just 20 don't recall.¶

21 Q. Did you take a picture of either alone or with another 23 individual in a naked state?¶

24 A. I have never taken, I believe, any 25 pictures of two people in any type of¶

2 situation, naked as you describe.¶

3 5 Q. Did you take a picture of on her own without another individual in it in a naked state?¶

6 7 8 9 10 11 A. I don't recall ever taking a picture of Virginia -- naked, we are not referring to someone with no clothing on at all, we are referring to someone that could be semi clad or could have a towel or we are not referring to anything inappropriate.¶

12 13 pictures Q. Was this a hobby of yours to take of the type that you are describing?¶

14 MR. PAGLIUCA: Object to the form.¶

15 16 17 18 A. pictures pictures for landscapes and for architectural pieces. I just testified, I didn't take of many people. My preference is¶

19 Q. Where are those pictures today?¶

20 A. I have no idea.¶

21 Q. Do you have them in your home?¶

22 A. I do not.¶

23 Q. Do you have them on your computer?¶

24 A. I do not.¶

25 Q. What has Jeffrey Epstein told you¶

2 about the allegations related to the criminal 3 investigation that he was involved in?¶

4 A. I really can't say, not because I 5 don't want to say but I just think of what he 6 has said to me over the course of this time.¶

7 Q. Did he explain it to you and 8 explain what the charges were against him?¶

9 A. I never had a detailed conversation 10 with him, as I recall.¶

11 Q. Not detailed, just did he explain 12 anything that was happening to him?¶

13 A. I haven't spoken to him for so 14 long. I can't possibly testify to what 15 conversations I had with him over the course 16 of time.¶

17 Q. Did he talk to you about any of the 18 girls that were making allegations against 19 him other than Virginia?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. You are talking about the police 23 records again, all of that?¶

24 Q. Yes.¶

25 A. I have never had a conversation¶

2 about those things.¶

3 Q. What has Jeffrey Epstein told you¶

4 about¶

5 A. That she is a liar.¶

6 Q. What does he base that on?¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. You would have to check with him.¶

10 I can tell you why I think she is a liar, I'm¶

11 happy to do that.¶

12 Q. Did he tell you he did not have¶

13 sexual relations with ?¶

14 A. I can only testify what I know.¶

15 Q. I'm asking, has he told you that he¶

?6 did not have sexual relations with¶

II ?¶

18 A. I can only tell you what I know¶

19 about, I cannot tell you¶

20 what he knows about¶

21 Q. I'm asking, did he tell you that he¶

22 did not have sexual relations with¶

II ?¶

A. All he told me is she is a liar.¶

Q. That's all he said about Virginia¶

2¶

3 A. We went through all the lies that¶

4 you have sold to the papers and sold in¶

5 general and we have analyzed her lies and¶

6 your lies and your inappropriate behavior in¶

7 detail.¶

8 Q. Did he ever say that he did not¶

9¶

10¶

11¶

12¶

13¶

14¶

15¶

16¶

17¶

18¶

19¶

20¶

21¶

22¶

23 that¶

24 true?¶

25¶

have sexual relations with¶

A. I just testified that we went¶

through all of her lies.¶

Q. I understand what you said. I'm¶

asking you a question.¶

Did he ever tell you that he never¶

had sex with¶

A. I don't recall whether he ever -- I¶

don't know I ever had that question. We¶

focused on the lies she did say she had with¶

him as relates to me. I don't remember¶

asking him about his problems with her. I'm¶

interested in what she says about myself.¶

Q. Did you also talk about what things¶

was saying that were¶

A. There isn't anything that she said¶

MAG NA 0¶

2 that was true.¶

3 Q. Nothing she said that you are aware 4 of is true?¶

5 A. I think she is correct when she 6 talks about what her name is.¶

7 Q. Anything else?¶

8 A. I'm sure there must be one or two 9 other details but they are so far and few 10 between, I would have to look in detail at 11 all of her allegations to pinpoint what 12 possibly could be true.¶

13 Q. Did you ever ask Jeffrey if he had 14 sex with minors?¶

15 A. I have never been asked that 16 question.¶

17 Q. You never asked him that question.¶

18 What analysis did Jeffrey do to determine that the statements¶

were making were lies?¶

21 MR. PAGLIUCA: Objection to the 22 form and foundation.¶

23 A. Ask me again, please.¶

24 Q. What analysis did Jeffrey do to 25 determine that the statements that Virginia¶

2 were making were lies?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation. And to the extent¶

5 that any of this answer calls for any¶

6 privileged communication, I'm¶

7 instructing, with myself or another¶

8 lawyer representing you or in any common¶

9 interest agreement, I'm instructing you¶

10 not to answer.¶

11 MS. McCAWLEY: The court ruled she¶

12 is entitled and you had to produce¶

13 documents about communications with¶

14 Jeffrey, that's what I'm asking about.¶

15 I'm not asking about communications with¶

16 lawyers.¶

17 Q. I'm asking what analysis did¶

18 Jeffrey do to determine that the statements¶

19 that was making were lies,¶

20 if you know?¶

21 MR. PAGLIUCA: My objection is to¶

22 the extent she learned any of that¶

23 information as a result of either a¶

24 privileged communication from a lawyer,¶

25 one of her lawyers or a privileged¶

2 communications subject to a joint¶

3 defense agreement or common interest¶

4 agreement, I'm telling her not to¶

5 answer. To the extent she has¶

6 information outside of those things, she¶

7 is permitted to answer.¶

8 Q. Do you understand?¶

9 So if it was a conversation with a 10 lawyer which I'm not asking about, I don't 11 want you to tell me about your conversations 12 with lawyers.¶

13 I want you to tell me whether¶

14 Jeffrey Epstein ever told you what he 15 analyzed in order to determine which of of 16 what Virginia were saying were lies?¶

17 A. I do not know what he did, no.¶

18 So you agree she is lying, Singrid.¶

19 Q. I do not agree with that and I'm 20 asking the questions.¶

21 A. You just said her lies.¶

22 Q. I'm repeating a statement you made.¶

23 Q. Are you saying it's an obvious lie 24 that Jeffrey Epstein engaged in sexual 25 conduct with Virginia while Virginia was¶

2 underage?¶

3 A. I can only testify to what I saw¶

4 and what I was present for, so if you are¶

5 asking me what I saw then I am happy to¶

6 testify. I cannot testify to what somebody¶

7 else did or didn't do.¶

8 Q. Did you issue a statement¶

in 2015, stating that 10 claims were, quote, obvious 11 lies?¶

12 MR. PAGLIUCA: Objection to the 13 form and foundation.¶

14 Q. You can answer.¶

15 A. You need to reask me the question.¶

16 Q. Sure.¶

17 Did you issue a press statement¶

18 in¶

January of 2015, stating that¶

' claims were, quote, obvious lies?¶

21 MR. PAGLIUCA: Objection to the 22 form and foundation.¶

23 A. Can you ask it a different way, 24 please?¶

25 Q. I will ask it again and you can¶

2 listen carefully.¶

3 Did you issue a press statement¶

4 in¶

5 January of 2015, where you stated that¶

6 ' claims were, quote, obvious¶

7 lies?¶

8 MR. PAGLIUCA: Objection to the¶

9 form and foundation.¶

10 A. So my lawyer,¶

11 instructed to issue a statement.¶

12 Q. Today, did you say that Virginia¶

13 lied about, quote, absolutely everything?¶

14 A. I said that there are some things¶

15 she may not have lied about.¶

16 Q. So are you saying it's an obvious¶

17 lie that Jeffrey Epstein engaged in sexual¶

18 contact with Virginia while Virginia was¶

19 underage?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation.¶

22 A. Can you ask the question again,¶

23 please?¶

24 Q. Are you saying it's an obvious lie¶

25 that Jeffrey Epstein engaged in sexual¶

2 conduct with Virginia while Virginia was¶

3 underage?¶

4 MR. PAGLIUCA: Objection to the¶

5 form and foundation.¶

6 Q. You can answer.¶

7 A. Try again, please.¶

8 Q. Are you saying that it's an obvious¶

9 lie that Jeffrey Epstein engaged in sexual¶

10 conduct with Virginia while Virginia was¶

11 underage?¶

12 MR. PAGLIUCA: Objection to the¶

13 form and foundation.¶

14 A. Again, I'm telling you, first of¶

15 all, it was a statement that was issued by my¶

16 lawyer and -- through my lawyer¶

17 Q. I understand that. I'm asking you,¶

18 are you saying that it's an obvious lie that¶

19 Jeffrey Epstein engaged in sexual conduct¶

20 with Virginia while Virginia was underage.¶

21 Is that a lie?¶

22 MR. PAGLIUCA: Objection to the¶

23 form and foundation.¶

24 Q. You can answer.¶

25 A. So I cannot testify to what¶

2 and decided to put -- I can¶

3 testify to what Virginia's obvious lies are¶

4 as regards to me. I cannot make¶

5 representations about all the many lies she¶

6 may or may not have told about Jeffrey.¶

7 Q. So is Virginia lying when she says,¶

8 is it an obvious lie when she says that she¶

9 had sex with Jeffrey Epstein while she was¶

10 underage?¶

11 MR. PAGLIUCA: Objection to the¶

12 form and foundation.¶

13 A. Again, I'm testifying to what I¶

14 know to be true. I can only testify to all¶

15 the many lies she told about me. I cannot¶

16 testify to what lies she told about somebody¶

17 else. Given she told so many about me, one¶

18 can probably infer she is lying about¶

19 everything.¶

20 Q. So you think she is lying when she¶

21 said she had sex with Jeffrey Epstein when¶

22 she was underage?¶

23 MR. PAGLIUCA: Objection to the¶

24 form and foundation.¶

25 A. Again, I can only talk about what I¶

2 can positively say myself, not what somebody¶

3 else is going to represent.¶

4 Q. When you were saying that she was,¶

5 her claims of having sex with Jeffrey Epstein¶

6 were obvious lies, are you saying she is¶

7 lying about engaging in sexual conduct with¶

8 Jeffrey Epstein when she was underage?¶

9 MR. PAGLIUCA: Objection to the¶

10 form and foundation.¶

11 Q. You can answer.¶

12 A. Again, this was a statement that¶

13 was put out from my lawyer¶

And I can only testify to¶

15 the obvious lies that she says about me. I¶

16 cannot make representations about lies she¶

17 says about someone else, but she lies so many¶

18 times about me, one can probably infer she is¶

19 lying about everything.¶

20 Q. So is she not lying when -- is she¶

21 telling the truth when she says she had sex¶

22 with Jeffrey Epstein when she was underage?¶

23 MR. PAGLIUCA: Objection to the¶

24 form and foundation.¶

25 A. Again, I don't know how else to¶

2 tell you, I can only talk about what I know¶

3 to be true. What I know is her story about¶

4 how she claims that initial situation¶

5 happened is so egregiously false and such a¶

6 giant fat enormous, repulsive, disgusting,¶

7 inappropriate, vile lie, that that I can¶

8 testify to.¶

9 Q. Was she lying when she said she met¶

10 you at Mar-a-Lago?¶

11 A. Again I already testified I don't¶

12 recall meeting her at Mar-a-Lago.¶

13 Q. We showed you a document where you¶

14 said you met her at Mar-a-Lago when she was¶

15 17, is that correct?¶

16 MR. PAGLIUCA: Objection to the¶

17 form and foundation.¶

18 A. I think I already testified to¶

19 that. What I remembered based on all the¶

20 rubbish she has written and all the many¶

21 articles I have read, maybe in the moment¶

22 when I wrote that, have caused me to have¶

23 that but on reflection I don't recall it as I¶

24 sit here today.¶

25 Q. Are you saying that it was an¶

2 obvious lie that you approached Virginia¶

3 while she was under age at Mar-a-Lago?¶

4 MR. PAGLIUCA: Objection to the¶

5 form and foundation.¶

6 A. First of all, we can all agree 7 here, all of you sitting here that the lies 8 that you perpetrated in the press that she 9 was 15 and we should all agree now that that 10 is fake, a lie that was perpetrated between 11 all of you to make the story more exciting, 12 can we agree on that?¶

13 Q. That is not my question.¶

14 A. Can we agree she was not the age 15 she said and you put that in the press, that 16 is obviously, manifestly, absolutely, totally 17 a lie.¶

18 MS. McCAWLEY: I am going to put on 19 the record, Ms. Maxwell very 20 inappropriately and very harshly pounded 21 our law firm table in an inappropriate 22 manner. I ask she take a deep breath, 23 and calm down. I know this is a 24 difficult position but physical assault 25 or threats is not appropriate, so no¶

2 pounding, no stomping, no, that's not 3 appropriate,.¶

4 A. Can we be clear, I didn't threaten 5 anybody.¶

6 MR. PAGLIUCA: Stop, you made your 7 record, there is no dent in the table. 8 I don't see any chips. Can we take a 9 break now.¶

10 MS. McCAWLEY: I think it's 11 appropriate to take a break.¶

12 THE VIDEOGRAPHER: It's 1:56 and we 13 are off the record.¶

14 (Recess.)¶

15 THE VIDEOGRAPHER: It's now 2:13, 16 we're starting disk No. 5 and we are 17 back on the record.¶

18 Q. Ms. Maxwell, how old was¶

when you met her in Mar-a-Lago?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. I know today that she was 17 years 23 old.¶

24 Q. Are you saying that it's an obvious 25 lie that Virginia traveled on Jeffrey¶

2 Epstein's airplanes?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 Q. You can answer.¶

6 A. Are you referring to my statement¶

7 where that says that?¶

8 Q. I'm referring to the language you¶

9 use in your statement that says, obvious¶

10 lies?¶

11 A. Can you read my entire statement?¶

12 Q. Sure, let me pass it out.¶

13 (Maxwell Exhibit 10, email,marked¶

14 for identification.)¶

15 Q. This is GM 00068 and we will 16 mark it as -- what you have in front of you 17 is a statement at the top. This was produced 18 by your counsel, it is indicated No.¶

19 GM 00068. At the top the date reflects¶

20 January 2, 2015 from, appears to be a¶

21 , subject line, is you and 22 then there is a number of individuals you can 23 see at the top that are copied on this that 24 is sent to and bcc'd on this statement.¶

25 The statement, there are two parts¶

1 G Maxwell - Confidential 2 of it. There is an opening email that says, 3 please find an attached quotable statement on 4 behalf of Ms. Maxwell and there is more 5 language there and it's from and 6 then it says in the body of it, Jane Doe No. 7 3 or Jane Doe 3 is so not a 8 new individual. The allegations made by, and 9 10 11 12 13 14 15 16 17 18 19 20 21 22 it says Victoria but I believe that means against Ghislaine Maxwell are not true. The original allegations are not new and have been fully responded to and shown to be untrue. And the next paragraph says, Each time the story is retold, it changes with new salacious details about public figures and world leaders and now it is alleged by that is involved in having sexual relations with her which he denies. claims are obvious lies and should be treated as such and not publicized as news as they are defamatory.¶

23 24 25 The last paragraph states, Ghislaine Maxwell's original response to the lies and defamatory claims remains the same.¶

2 3 4 5 6 7 Maxwell strongly denies allegations of the strongly denies allegations of an unsavory nature which have appeared in the British press and elsewhere and reserves her right to seek redress at the repetition of such old defamatory claims.¶

8 9 lie that 10 Are you saying that it's an obvious Epstein's planes? traveled on Jeffrey¶

11 12 MR. PAGLIUCA: Objection to the form and foundation.¶

13 14 15 16 17 18 be in so A. I'm saying what's an obvious lie and I think we can all agree, you just had the case tossed out by . He just got removed from the case because you put him in a case that he wasn't supposed to what was said about him is not true.¶

19 Q. 20 lie that 21 Epstein's Are you saying that it's an obvious traveled on Jeffrey plane?¶

22 23 MR. PAGLIUCA: Objection to the form and foundation.¶

24 25 A. You have given me plane records that has her name on it but as I already¶

2 testified those aren't federally mandated¶

3 things and I can see her name on it but¶

4 that's what I -- I told you I don't recall¶

5 her on any planes.¶

6 Q. Is is that one of Virginia's¶

7 obvious lies?¶

8 A. There are more obvious ones.¶

9 Q. Is that one of them?¶

10 A. I can't testify to her being on a¶

11 plane or not.¶

12 Q. So is that an obvious lie?¶

13 A. There are more obvious lies, like¶

14¶

15 Q. I understand there are more obvious¶

16 ones. I'm asking you, is the fact that she¶

17 said she traveled on Epstein's planes an¶

18 obvious lie?¶

19 A. I think we can probably say because¶

20 you see her name on a plane record and she¶

21 went from A to B, that would not be the¶

22 obvious lie that I would pick.¶

23 Q. What obvious lie were you picking¶

24 when you made this statement?¶

25 A. There are so many that I would be¶

2 thrilled to go through all of them.¶

3 Q. Let's go through them.¶

4 What's the first one?¶

5 A. Her characterization of the first 6 meeting at Mar-a-Lago.¶

7 Q. What part of that was an obvious 8 lie?¶

9 A. The characterization that she said 10 that she said she was accosted. She looked 11 like, as best as I can recall, if I met her 12 in Mar-a-Lago as she claims, she worked at 13 Mar-a-Lago, she claims, and her statement she 14 worked at Mar-a-Lago, she would have been 15 dressed as all the spa people in Mar-a-Lago 16 would have been. It would have been 17 impossible to identify her as someone other 18 than someone who worked at a spa. She made 19 many claims, she has been a bathroom 20 attendant, front of house attendant, we don't 21 know what she was, so her obvious lies are 22 her contradictory of her own personal 23 statements within that.¶

24 Q. So what part of her statement 25 relating to Mar-a-Lago¶

2 A. I'm carrying on.¶

3 Q. I'm sorry. I thought you were¶

4 done.¶

5 A. Please. Her statement also that¶

6 she was driven by her father to Palm Beach.¶

7 She was driven by her mother, as a matter of¶

8 fact. Her whole entire characterization of¶

9 the first meeting with Jeffrey, as I was¶

10 outside speaking to her mother.¶

11 Q. Let me stop you there, so we don't¶

12 get too far ahead. Let me make sure I¶

13 understand your testimony.¶

14 The first, in the first piece when¶

15 you were talking, I believe you said and¶

16 correct me if I'm wrong, that her¶

17 characterization of the first meeting at¶

18 Mar-a-Lago was an obvious lie.¶

19 what part of that meeting was an¶

20 obvious lie?¶

21 A. By her own testimony, all her¶

22 various many different descriptions of what¶

23 she was or wasn't or where she was or wasn't,¶

24 they have all changed. She was either front¶

25 of house or bathroom attendant. I don't know¶

2 what she was, so just by her own words, one 3 doesn't know what's true and what isn't true.¶

4 Q. Are you saying what position she 5 said she was working in, is that what you are 6 considering the obvious lie?¶

7 A. I said inconsistency within her own 8 statement from everything, so in the 9 beginning it starts off with different 10 statements.¶

11 Q. Then I believe you said the second 12 piece was that she was driven by her father?¶

13 A. I said she was driven by her 14 mother.¶

15 Q. That's the obvious lie?¶

16 A. It's an obvious lie to me.¶

17 Q. You said why don't you state it in 18 your own words but the characterization of 19 how she was with Jeffrey, what about that is 20 an obvious lie?¶

21 A. I was standing outside talking to 22 her mother so the entire story is a 23 fabrication.¶

24 Q. Did she not have sex with Jeffrey 25 Epstein during that first massage?¶

2 MR. PAGLIUCA: Objection to the 3 form and foundation.¶

4 A. I was talking to her mother so...¶

5 Q. Do you know whether that's an 6 obvious lie, whether she had sex in that room 7 or not?¶

8 A. Her story about what happened 9 let's also be -- the story as first hit the 10 press was that somebody else led her to 11 Jeffrey's room, it was not me and then it 12 turned to being me so we have an obviously 13 important inconsistency, lie in my -- that's 14 how I would characterize a lie. It cannot be 15 me or somebody else, it can only be one or 16 the other.¶

17 Q. Who is the other person she said 18 took her to the room?¶

19 A. Why don't you ask her.¶

20 Q. I'm asking you.¶

21 A. How would I possibly know.¶

22 Q. You are saying that's a lie.¶

23 A. It was a lie in the papers, she 24 said it in the newspaper, it was in the 25 newspaper.¶

2 Q. How do you know she wasn't¶

3 identifying you?¶

4 A. She said somebody.¶

5 Q. How do you know that somebody¶

6 wasn't you?¶

7 A. Why did it suddenly become me, why¶

8 not say it was me and be done with it.¶

9 Q. So it's a lie because she¶

10 originally may not have named you and then¶

11 named you later?¶

12 A. It's obviously inconsistent to¶

13 somebody who wasn't me.¶

14 Q. How do you know it wasn't you?¶

15 A. I know it wasn't me because I was¶

16 talking to her mother.¶

17 Q. But she then named you, is what you¶

18 are saying?¶

19 A. That's an obvious lie.¶

20 Q. She named you?¶

21 A. It's an obvious lie because I¶

22 wasn't even in the house.¶

23 Q. Is it an obvious -- who did lead¶

24 her up to Jeffrey's room while you were¶

25 talking to her mother?¶

2 A. You would have to ask Virginia, I 3 don't know if she was led up to his room.¶

4 Q. You were standing with the mother, 5 is that correct?¶

6 A. That's correct.¶

7 Q. Who was working at the house that 8 day?¶

9 A.¶

10 A. Would typically lead 11 someone up to the room where Jeffrey was 12 having a massage?¶

13 A. I don't know she was led up to the 14 room to have a massage.¶

15 Q. She would have found her way on her 16 own?¶

17 A. I would suggest that that entire 18 story never happened at all in any of its 19 form.¶

20 Q. If you stood outside with the 21 mother, what did you think happened inside 22 then?¶

23 A. I believe that somebody, it wasn't 24 me, probably took her to meet 25 Jeffrey Epstein¶

2¶

3 Q. Did Jeffrey tell you that?¶

4 5 6 7 8 A. No but that would have been a normal interaction. I don't believe for a second -- I know her entire characterization didn't happen because I was outside talking to her mother the entire time.¶

9 10 Q. Why would she have come for a massage and not given a massage?¶

11 12 MR. PAGLIUCA: Objection to the form and foundation.¶

13 14 15 A. We are talking about her characterization of the first time that she came to the house.¶

16 17 18 19 Q. If I'm following you correctly, you're saying she walked in and would have gone to -- it's your assumption she would have gone and talked to Jeffrey and left?¶

20 21 22 23 24 A. When I was working for Jeffrey, typically he would meet someone before getting a massage from them to see if he wanted to have a massage from them, typically.¶

25 Q. So he would not have someone come¶

2 up to the room and start a massage?¶

3 A. He would not.¶

4 Q. So the young girls in the police¶

5 report who say they came over and were led up¶

6 to the room on the first day, would they be¶

7 wrong about that?¶

8 MR. PAGLIUCA: Objection to form¶

9 and foundation.¶

10 A. I can't comment what happened when¶

11 I was not at the house. I can only comment¶

12 when I was at the house.¶

13 Q. Was there ever a time where a woman¶

14 came to the house for the first time to give¶

15 a massage and Jeffrey had the massage that¶

16 day?¶

17 MR. PAGLIUCA: Objection to the¶

18 form and foundation.¶

19 A. Can we talk about adult¶

20 professional masseuses, please?¶

21 Q. I'm asking, whether adult or¶

22 underage?¶

23 A. I'm not interested in talking about¶

24 underage. I can only testify to what I know,¶

25 professional masseuses, adult, I cannot¶

2 testify to anything else.¶

3 Q. Why can't you testify to an¶

4 underage girl that came over and was led up¶

5 to the room for a massage?¶

6 MR. PAGLIUCA: Objection to the¶

7 form and foundation.¶

8 A. The police records you are¶

9 referring to?¶

10 Q. You are saying that didn't happen.¶

11 You're saying I can only testify to adults¶

12 that came for an interview and were led up to¶

13 the room. Why can't you testify to whether¶

14 an underage girl was brought in for an¶

15 interview and led up --¶

16 MR. PAGLIUCA: Objection to the¶

17 form and foundation.¶

18 Q. Go ahead.¶

19 A. Can you reask the question.¶

20 Q. Why can't you testify as to an¶

21 underage girl who came over for an interview¶

22 and then was then led up to the room for the¶

23 massage?¶

24 A. You've mangled your entire¶

25 question. Can you please reask that in a way¶

2 that I can answer it correctly?¶

3 Q. Why can you not testify as to¶

4 whether an underage girl, you said you can¶

5 testify as to females that were over the age¶

6 of 18, why can't you testify as to whether an¶

7 underage girl came over for an interview and¶

8 on the same day --¶

9 A. I don't know what you mean by¶

10 interview.¶

11 Q. You just said that Jeffrey Epstein¶

12 interviewed, it was your word, interviewed¶

13 the masseuses before they gave massages, is¶

14 that correct?¶

15 A. The word interview is making me --¶

16 I'm English, so you could have some¶

17 difficulty understanding the way I¶

18 communicate.¶

19 Q. I'm using your word.¶

20 A. Then I will reuse it a different¶

21 word. He would meet them because receiving a¶

22 massage is something you want to make sure¶

23 you are comfortable with the person and so¶

24 interview is not the correct word but you¶

25 would meet them to have a conversation with¶

2 them to see if you want to have a massage¶

3 with that person.¶

4 Q. Did Jeffrey Epstein ever meet an¶

5 underaged girl and on the same day receive a¶

6 massage from that girl?¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. I can't possibly testify to what¶

10 happened after I was not at the house.¶

11 Q. If you are aware, at any time you¶

12 were at the house, did you ever see that?¶

13 MS. MENNINGER: Let her finish the¶

14 question.¶

15 A. I can only testify to people who¶

16 were adult professional masseuses who came to¶

17 the house. I cannot testify to something I'm¶

18 not party to and don't know about. I can¶

19 only testify to what I saw. So when¶

20 professional adult masseuse, male and/or¶

21 females would come to the house, typically¶

22 when I was there, typically he would meet¶

23 with them prior, to have a conversation with¶

24 them about their experience, whatever, to¶

25 decide whether it would then A, if he had¶

2 time for a massage at that time or B, whether¶

3 he could have a massage at that moment.¶

4 Q. Was Virginia an adult when she came¶

5 over, was she over 18?¶

6 MR. PAGLIUCA: Objection to the¶

7 form and foundation.¶

8 A. I think we established, as of¶

9 today, we are all aware, everyone in this¶

10 room that she was 17.¶

11 Q. So you have been present when a¶

12 minor was brought over for a massage for¶

13 Jeffrey?¶

14 A. Can I say, as you are able to have¶

15 a massage at 17, so she came as a masseuse.¶

16 Q. I'm not saying whether or not you¶

17 are able to. I'm saying you've been present¶

18 at Jeffrey's home when an underage minor has¶

19 come over to give him a massage?¶

20 A. That's just not how that works.¶

21 You are able to be a masseuse at 17 so she¶

22 came to give -- for a massage, at 17 you are¶

23 able to come and give a massage.¶

24 Q. I'm not asking whether she is able¶

25 to do it. I'm asking whether you were¶

2 3 4 massage? present at the home when a girl under the age of 18 came over for the purposes of giving a¶

5 6 MR. PAGLIUCA: Objection to the form and foundation.¶

7 Q. You can answer.¶

8 9 10 11 12 13 14 A. You can be a professional masseuse at 17 in Florida, so as far as I am aware, a professional masseuse showed up for a massage. There is nothing inappropriate or incorrect about that and your mischaracterization of it, I think is unfortunate.¶

15 16 17 his home? Q. How many teenagers did he have that were professional masseuses that worked in¶

18 19 MR. PAGLIUCA: Objection to the form and foundation.¶

20 Q. How many?¶

21 22 A. First of all, I am not aware of teenagers who worked in his home.¶

23 Q. 24 25 for him, correct? You are aware of and you've stated she was 17 and she worked¶

2 A. No. I did not state that at all, 3 you are mischaracterizing my words and what I 4 said.¶

5 What I said was that we can all 6 agree and I think at this point there is not 7 one person in this room, however much you 8 would like her to be younger, to say she was 9 not 17 because that has been a very offensive 10 thing that you have all done. So she was 17. 11 At 17 you are allowed to be a professional 12 masseuse and as far as I'm concerned, she was 13 a professional masseuse. There is nothing 14 inappropriate or incorrect about her coming 15 at that time to give a massage. Her entire 16 characterization of her first time at the 17 house was to me an obvious lie, given it was 18 impossible for her entire story to take place 19 given I was speaking to her mother the entire 20 she was at the house.¶

21 Q. So it was impossible that day, that 22 first day she came and you were speaking to 23 the mother, for to have had 24 sex with Jeffrey Epstein during the time that 25 you were outside with her mother?¶

2 MR. PAGLIUCA: Objection to the 3 form and foundation.¶

4 A. You, again, are completely¶

5 mischaracterizing. I can only testify to¶

6 what I heard obvious lies about me and her¶

7 obvious lies about me are that she, as you¶

8 put out to the papers and every other which¶

9 way, went upstairs with her, didn't happen.¶

10 So that to me is an absolute, obvious lie. I¶

11 also don't believe that her -- her¶

12 mischaracterization of the length of time she¶

13 was there because as I recall, she just met¶

14 with Jeffrey and then left with her mother.¶

15 That's my recollection.¶

16 Q. So you were standing outside the¶

17 entire time that Virginia was in the house,¶

18 is that correct?¶

19 A. That is correct.¶

20 Q. So can you testify as to whether or¶

21 not, do you know either from Jeffrey or any¶

22 other source whether or not¶

23 had sex with Jeffrey on that first day that¶

24 she was at the house?¶

25 A. We can categorically state,¶

2 absolutely 1000 percent that she did not have¶

3 any type of sexual relations as described by¶

4 you in your court papers that took place¶

5 because those allegedly according to her lies¶

6 involved some aspect of me.¶

7 As I was standing outside with her¶

8 mother the entire time, her entire story is a¶

9 lie. Therefore, to ask me what she did or¶

10 didn't do during that time, I can only¶

11 testify to what she said about me, which was¶

12 1000 percent false.¶

13 Q. So let's not take the first time,¶

14 let's take the next time she comes.¶

15 A. No no, how can do you that, when¶

16 the basis of this entire horrible story that¶

17 you have put out is based on this first¶

18 appalling story that was written, repeated,¶

19 multiply by the press that lied about her¶

20 age, lied about the first time she came, lied¶

21 about and characterized the entire first¶

22 time. I have been so absolutely appalled by¶

23 her story and appalled by the entire¶

24 characterization of it and I apologize¶

25 sincerely for my banging at the table¶

2 earlier, I hope you accept my apology. It's 3 borne out of years of feeling the pressure of 4 this entire lie that she has perpetrated from 5 our first time and whilst I recognize that 6 was -- I hope you forgive me sincerely 7 because it was just the length of time that 8 that terrible story has been told and retold 9 and rehashed when I know it to be 100 percent 10 false.¶

11 Q. So not the first time she came, but 12 the second time she came or the third time or 13 any time she came, did you ever participate 14 in a massage with her in Jeffrey Epstein's 15 room?¶

16 A. I have never participated at any 17 time with Virginia in a massage with Jeffrey.¶

18 Q. Have you ever participated at any 19 time with Virginia in any kind of sexual 20 contact or sexual touching with Jeffrey and 21 Virginia?¶

22 A. I have not.¶

23 Q. So we were going through the list 24 of obvious lies and you were talking about 25 the first time which I believe we have¶

1 2 3 G Maxwell - Confidential completed but you can add to that if you need to.¶

4 5 6 What other obvious lies did tell that you were referring to in your statement?¶

7 8 9 10 11 12 13 14 15 16 A. II my goodness. Well, I think we can totally cover the story that I flew him with ■ there was a dinner with other entire thing is 100 percent fictitious. story, the and people and that I have testified for the record and I'm happy to do it again, that I have never flown myself as a pilot in a helicopter at any time, anyplace, at any time, to any part of the world.¶

17 18 Q. referring What other obvious lies were you to?¶

19 20 21 22 23 A. She was referring to, she is referring to a bunch of people. I don't believe ever came to the island at any time ever. I don't even know actually¶

24 25 Q. Just one moment, I want to hear all of them, but when you say you don't believe¶

2 ever came to the island, do you know¶

3 whether ever came to the island?¶

4 A. never came to the island.¶

5 Q. How do you know that?¶

6 A. Jeffrey doesn't know him, I don't¶

7 know him and I think had I don't¶

8 think -- had gone to the island¶

9 during the period when I would have been¶

10 involved in organizing a trip, I would have¶

11 been aware of it.¶

12 Q. So go ahead, you had another one.¶

13 A. It would be easier if I could see,¶

14 do you mind if a take a reference at some of¶

15 these newspaper articles or you just want me¶

16 to go from memory.¶

17 Her entire characterization of what¶

18 took place in London at my house with¶

19¶

20 Q. Was it an obvious lie that she was¶

21 at your house in London?¶

22 A. We can't really establish the¶

23 photograph and all that. I don't know if¶

24 that's true, if that's a real picture or not.¶

25 Q. So you dispute that you were¶

2 actually photographed in your town home in¶

3 London --¶

4 A. I don't recognize that picture.¶

5 I'm not sure if that's a real picture or not.¶

6 Q. And have you talked to¶

7 about that picture?¶

8 A. We discussed Virginia's entire tail¶

9 and he asked me if he even knew her.¶

10 Q. So did tell you that¶

11 he did not have sex with ?¶

12 A. He doesn't even know who¶

II is.¶

14 Q. Did he tell you that he didn't have¶

15 sex with her?¶

16 A. It would be difficult to have sex¶

17 with someone you don't know.¶

18 Q. He may not remember her?¶

19 A. I think the inference is he didn't¶

20 know who she was, he didn't have any¶

21 recollection of her whatsoever.¶

22 Q. Has ever come to your¶

23 London town home?¶

24 A. Yes. Ever being the entire time I¶

25 owned my house, yes.¶

2 Can I go on on her obvious lies?¶

3 Q. If you have more.¶

4 A. I have her entire¶

5 characterization I took her shopping into¶

6 Burberry and bought her a very expensive¶

7 dress and if this photo were real and if this¶

8 is -- I would never -- the outfit doesn't¶

9 work at all so --¶

10 Q. Do you not remember taking her¶

11 shopping or are you saying it's an obvious¶

12 lie, you know you did not take her shopping?¶

13 A. I did not take her shopping. I did¶

14 not by her a $5,000 handbag.¶

15 Q. Did Jeffrey by her a $5,000¶

16 handbag?¶

17 A. Her accusation was that I did.¶

18 Q. Do you know if Jeffrey bought her a¶

19 handbag during that trip to London?¶

20 A. I don't know what he did. She¶

21 accused me, I can't physically remember¶

22 buying a $5,000 not for her, not for anyone,¶

23 not for me.¶

24 Q. Did you ever go shopping with¶

25 Virginia?¶

2 A. I don't recall ever shopping with 3 Virginia.¶

4 Q. Did you have more to go over or did 5 you want me to ask my questions?¶

6 A. The entire characterization of what 7 took place in my house in London would have 8 been impossible.¶

9 Q. Can I ask, do you still have it, 10 the picture of the London town home with you 11 in it, 00407.¶

12 As you are looking at this picture, 13 Ms. Maxwell, as I'm looking at it it's on the 14 right-hand side, there appears to be a 15 picture hanging on the wall, do you recall 16 that in your London town home?¶

17 A. It's a little difficult to see.¶

18 Q. Do you recall having a picture on 19 the wall there by the room where you're 20 standing?¶

21 A. I do have a picture.¶

22 Q. Do you recall on the left-hand side 23 having a railing that looks like that with 24 sort of a bubble top?¶

25 A. I do.¶

2	Q.	So are you saying that it's an
3	obvious lie that Virginia's statement that
4	she had sex with [REDACTED] is an obvious
5	lie?

6	A. What I'm representing is that her
7	entire ludicrous and absurd story of what
8	took place in my house is an obvious lie.

9 Q. Includuding she had sex with [REDACTED]
10 [REDACTED]¶

11	A. She claimed things took place in my
12	bathroom in London. Her characterizations is
13	just not possible.

14	Q.	So you're saying it's an obvious
15	lie -- that she was telling an obvious lie
16	when she said she had sex with [REDACTED] ?

17	MR. PAGLIUCA: Objection to the form and foundation. The witness
18
19	answered the question.

20                   A.           I'm saying within the context of
21   all the stories she told, this particular
22   story -- back up, she claimed we went out at
23   night. [REDACTED]¶

[REDACTED]¶

2 . She characterized¶

3 that¶

4¶

5 She then characterized things took¶

6 place in my bathroom in the bathtub itself.¶

7 The tub is too small for any type of activity¶

8 whatsoever.¶

9 Q.¶

•¶

13 Q. That would be¶

14¶

A.¶

15 A. Yes.¶

16 Q. Are you saying that it was an¶

17 obvious lie when Virginia said that you made¶

18 her dress up in a school girl outfit?¶

19 MR. PAGLIUCA: Objection to the¶

20 form and foundation.¶

21 A. I already testified that, first of¶

22 all, I don't know what you are taking about,¶

23 I already testified I didn't get her outfits¶

24 and all of that.¶

25 Q. Is it an obvious lie that Virginia¶

2 was paid to go to give a massage to¶

3¶

4 MR. PAGLIUCA: Objection to the¶

5 form and foundation.¶

6 A. I cannot testify to what Virginia¶

7 did outside of -- I can't testify to what she¶

8 did, who she gave massages to.¶

9 Q. So you don't know on that one?¶

10 A. Of course I don't know.¶

11 Q. Do you agree that it's¶

12 psychologically harmful to have sex with a¶

13 minor?¶

14 MR. PAGLIUCA: Objection to form¶

15 and foundation.¶

16 A. What are you asking me?¶

17 Q. I'm asking if is it psychologically¶

18 harmful for an adult to have sex with a¶

19 minor?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation.¶

22 A. I don't know what you are asking.¶

23 This has nothing to do with¶

24 Q. It does.¶

25 A. How does it?¶

2 Q. I ask the questions, you answer.¶

3 If you can't answer, you can say I don't¶

4 know.¶

5 But my question is, do you agree¶

6 that it's psychologically harmful to have sex¶

7 with a minor?¶

8 MR. PAGLIUCA: Objection to the¶

9 form and foundation.¶

10 A. Are you giving me a random question¶

11 and as not relates to this case and not¶

12 relates to anything. It's obviously not¶

13 something that you want to have happen.¶

14 Q. Do you agree that Jeffrey Epstein¶

15 has harmed many minors by having sex with¶

16 them?¶

17 MR. PAGLIUCA: Objection to the¶

18 form and foundation.¶

19 A. I can't testify to what Jeffrey did¶

20 or didn't do. I have no knowledge of what¶

21 you are asking me.¶

22 Q. If Jeffrey had sex with minors,¶

23 would you agree that that could harm a minor?¶

24 MR. PAGLIUCA: Object to the form¶

25 and foundation.¶

2 A. Again, I am not testifying to what¶

3 Jeffrey did or did not do because I cannot.¶

4 Q. You don't know whether Jeffrey¶

5 Epstein ever had sex with a minor?¶

6 A. Again, I cannot testify to what¶

7 Jeffrey did or didn't do. I cannot.¶

8 Q. You never observed him having sex¶

9 with a minor?¶

10 A. I never observed Jeffrey having sex¶

11 with a minor.¶

12 Q. Do you agree that calling a sex¶

13 abuse victim a liar when she speaks about her¶

14 abuse can cause psychological harm?¶

15 MR. PAGLIUCA: Objection to the¶

16 form and foundation.¶

17 A. Can you repeat the question.¶

18 Q. Do you agree calling a sex abuse¶

19 victim when she speaks about her abuse can¶

20 cause psychological harm?¶

21 MR. PAGLIUCA: Objection to form¶

22 and foundation.¶

23 A. Say it again.¶

24 Q. Do you agree that calling a sexual¶

25 abuse victim a liar can cause psychological¶

1 G Maxwell - Confidential 2 harm.¶

3 MR. PAGLIUCA: Object to the form 4 form and foundation.¶

5 A. I would like to say all the 6 terrible things said about 7 me is extremely harmful and you should turn 8 that around. All the lies she has said and 9 you have backed her on have been extremely 10 damaging to me.¶

11 So what I can testify to is that 12 somebody who has made these outrageous 13 allegations and who is a serious liar and 14 that I know for a fact is a liar, that I can 15 testify is damaging to me.¶

16 Q. Do you agree that calling a sexual 17 abuse victim a liar when she speaks out about 18 her abuse can cause psychological harm?¶

19 MR. PAGLIUCA: Are you asking a 20 hypothetical question?¶

21 MS. McCAWLEY: Yes.¶

22 A. You are asking me to speculate?¶

23 Q. I'm not asking you to speculate¶

24 If somebody is a sexual abuse victim --¶

25 A. I can't testify to what some random¶

2 hypothetical person that you are asking me to 3 speculate on their mental state or health 4 versus speculative statement. I can't do 5 that, that's just not right.¶

6 Q. Do you agree that by calling¶

7 a liar when she was subject 8 to sexual abuse by Jeffrey Epstein can cause 9 psychological harm?¶

10 MR. PAGLIUCA: Objection to the 11 form and foundation. Assumes facts not 12 in evidence.¶

13 A. I can only tell you about what I 14 know of Virginia's lies. She lied 15 repeatedly, often and I know for a fact she 16 is a liar so I can only testify to what I 17 know and the fact that she has lied about me 18 from the beginning to the end and repeatedly 19 causes me to question anything that she may 20 feel.¶

21 Q. Is it an obvious lie you had sex 22 toys in Jeffrey Epstein's Palm Beach house?¶

23 MR. PAGLIUCA: Objection to the 24 form and foundation.¶

25 A. Can you repeat the question,¶

2 please?¶

3 Q. Is it an obvious lie that you had¶

4 sex toys in Jeffrey Epstein's Palm Beach¶

5 house?¶

6 MR. PAGLIUCA: Objection to the¶

7 form and foundation.¶

8 A. Did Virginia say that?¶

9 Q. I'm asking you a question.¶

10 Is it an obvious lie that you had¶

11 sex toys in Jeffrey Epstein's house?¶

12 A. I don't recall any sex toys.¶

13 Q. If someone said had you sex toys,¶

14 would that be an obvious lie?¶

15 MR. PAGLIUCA: Objection to the¶

16 form and foundation.¶

17 A. Like I said -- can you be more¶

18 specific about the house or whatever, what¶

19 exactly you are referring to, what's a sex¶

20 toy?¶

21 Q. Yes. How would you define a sex¶

22 toy?¶

23 A. No. I need you to define a sex¶

24 toy, I don't have enough knowledge of sex¶

25 toys.¶

2 Q. I will define it based on the 3 dictionary's definition, which is an object 4 or device used to sexually stimulate or 5 enhance sexual pleasure.¶

6 A. What's your question, please?¶

7 Q. The question is, is it an obvious 8 lie that you had sex toys in Jeffrey 9 Epstein's Palm Beach house?¶

10 MR. PAGLIUCA: Same objection.¶

11 Q. You can answer.¶

12 A. Like I said, I do not have any 13 recollection of sex toys in Jeffrey's house.¶

14 Q. Is it a lie, is it an obvious lie 15 that you took pictures of nude girls?¶

16 MR. PAGLIUCA: Object to the form 17 and foundation.¶

18 A. We already covered this. Girls we 19 are not referring to -- I can only testify to 20 taking pictures of adult people and I already 21 testified they are not nude, per se. That 22 every picture that I ever took and which they 23 were very limited, always by request, the 24 people would be covered or it would be a hand 25 or a foot. There was never any pictures that¶

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 21 females to bring them to Jeffrey Epstein for the purpose of performing massages?¶

22 23 form MR. PAGLIUCA: Objection to the and foundation.¶

24 A. 25 that part Again, I have already testified 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 visits. If that person said that they did, 14 they would sometimes come, from time to time, 15 not always, come back to the house to perform 16 a nonsexual professional male or female 17 massage. 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¶

18 Q. Were any of the exercise 19 instructors you hired under the age of 18?¶

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?¶

16 MR. PAGLIUCA: Objection to the 17 form and foundation.¶

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?¶

16 MR. PAGLIUCA: Objection to the 17 form and foundation.¶

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?¶

8 MR. PAGLIUCA: Objection to the¶

9 form and foundation.¶

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?¶

22 MR. PAGLIUCA: Objection to the¶

23 form and foundation.¶

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?¶

22 MR. PAGLIUCA: Objection to the¶

23 form and foundation.¶

24 A. What are you talking about?¶

25 Q. Sure. Would Jeffrey Epstein's¶

1 G Maxwell - Confidential 2 assistants, I think earlier you mentioned, we 3 talked about who worked in the 4 role as an assistant or 5 Would Jeffrey Epstein's assistants arrange 6 times for underage girls to come over the 7 house for sexual massages?¶

8 MR. PAGLIUCA: Objection to the 9 form and foundation.¶

10 A. Again, I read the police reports so 11 this is all happening according to the police 12 reports when I am no longer at the house so I 13 can't testify to what Jeffrey's assistants 14 did when this kind of activity as alleged in 15 the reports.¶

16 Q. So you don't know?¶

17 A. No.¶

18 Q. Would Jeffrey Epstein's assistants, 19 meaning or any 20 other assistant that you are aware of from 21 the time you worked there take nude 22 photographs of underage girls?¶

23 MR. PAGLIUCA: Object to the form 24 and foundation.¶

25 A. During what period of time?¶

2 Q. During any period of time you¶

3 worked, did you observe that?¶

4 A. I did not observe any such¶

5 photographs.¶

6 Q. Are you aware if they took those¶

7 kinds of photos?¶

8 A. I am not aware.¶

9 MR. PAGLIUCA: Can we take a¶

10 five-minute break.¶

11 THE VIDEOGRAPHER: It's 2:58 and we¶

12 are off the record.¶

13 (Recess.)¶

14 THE VIDEOGRAPHER: It's now 3:10.¶

15 We're starting disk No. 6 and we are¶

16 back on the record.¶

17 Q. Ms. Maxwell, was it an obvious lie¶

18 when Virginia said she was sent to Thailand¶

19 by Epstein in September of 2002?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation.¶

22 A. I have no knowledge of Virginia¶

23 being sent to Thailand.¶

24 But may I say something?¶

25 Q There is not a question pending¶

2 unless you want to clarify something.¶

3 Did you want to clarify that?¶

4 A. No, I just wanted to say something.¶

5 Q. Is it an obvious lie when Virginia 6 said she was given instructions to maintain 7 telephone contact with you while she was in 8 Thailand?¶

9 MR. PAGLIUCA: Objection to the 10 form and foundation.¶

11 A. Can you repeat the question?¶

12 Q. Is it an obvious lie when Virginia 13 said she was given instructions to maintain 14 telephone contact with you when she was in 15 Thailand?¶

16 MR. PAGLIUCA: Same objection.¶

17 A. I have no idea what instructions 18 Virginia was given, if any, when she went to 19 Thailand.¶

20 Q. So you know she went to Thailand?¶

21 A. I know she claimed she went to 22 Thailand from having read it but given that 23 she lied about everything it's hard to know 24 what is true and not true.¶

25 Q. Would it make any sense for her to¶

2 be in contact with you, would there be any 3 reason why she needed to be in contact with 4 you?¶

5 MR. PAGLIUCA: Objection to the 6 form and foundation.¶

7 A. When are we talking about?¶

8 Q. When she went to Thailand.¶

9 MR. PAGLIUCA: Same objection.¶

10 Q. In 2002, would there be any reason 11 for her to remain in contact with you?¶

12 MR. PAGLIUCA: Objection to the 13 form and foundation.¶

14 A. Can you ask the question again, 15 please?¶

16 Q. Would there be any reason for 17 Virginia to maintain contact with you in 2002 18 when she went to Thailand?¶

19 MR. PAGLIUCA: Same objection.¶

20 A. First of all, I didn't know that 21 she went to Thailand. I had had nothing to 22 do with her trip to go to Thailand and there 23 would absolutely no reason for her to be in 24 touch with me, whatsoever.¶

25 Q. Did you ever have a phone number¶

2 that was¶

3 A. I did.¶

4 Q. Was that a cell phone number?¶

5 A. Yes.¶

6 Q. Is that your current cell phone¶

7 number?¶

8 A. Yes.¶

9 Q. I'm going to mark a couple of¶

10 things here?¶

11 (Maxwell Exhibit 11, photos, marked¶

12 for identification.)¶

13 THE WITNESS: Can I say something¶

14 now?¶

15 MR. PAGLIUCA: No.¶

16 THE WITNESS: Will you let me know¶

17 when I can?¶

18 MR. PAGLIUCA: When she asks you a¶

19 question:¶

20 Q. So we've marked this as Exhibit 11.¶

21 I'm showing you what's been marked as Exhibit¶

22 11 which is 003191 and 003192.¶

23 Can you take a look at that¶

24 document for me. Is that number that you¶

25 just identified the as being¶

2 your cell phone number, is that number on¶

3 this document?¶

4 A. It is.¶

5 Q. And do you know who authored this¶

6 document?¶

7 A. I do not.¶

8 Q. Who is¶

9 A. I don't know who is on this¶

10 document because I don't know what this¶

11 document is.¶

12 Q. Do you know someone by the name of¶

13¶

14 A. I do know someone by the name of¶

15¶

16 Q. Would he know your phone number?¶

17 MR. PAGLIUCA: Object to the form.¶

18 A. I have to idea.¶

19 Q. Why would Virginia be instructed to¶

20 call Ms. Maxwell at your number on this form?¶

21 MR. PAGLIUCA: Objection to the¶

22 form and foundation.¶

23 A. I don't know what this document is.¶

24 I don't know when it was done, I don't know¶

25 anything about it other than I can see it has¶

2 my name and my number on it.¶

3 Q. So -- you said -- is he¶

4 employed by Mr. Epstein?¶

5 A. Again, it is not the only one¶

6 on the planet.¶

7 Q. I understand.¶

8 Do you know a that is employed¶

9 by Mr. Epstein?¶

10 MR. PAGLIUCA: Objection to the¶

11 form and foundation.¶

12 A. Can you ask me the question again?¶

13 Q. Do you know someone by the name of¶

14 that was employed by Mr. Epstein back in 15 2002?¶

16 A. I do know somebody who was employed¶

17 by Mr. Epstein known as¶

18 Q. Do you recognize the other numbers¶

19 listed at the top of this document?¶

20 A. I do not.¶

21 Q. Would you have known cell¶

22 number at that time in 2002?¶

23 MR. PAGLIUCA: Objection to the¶

24 form and foundation.¶

25 A. I have no idea.¶

2 Q. Can I ask you to turn to the next¶

3 page, please.¶

4 Do you know who¶

5 is who is mentioned on this document?¶

6 A. I do not.¶

7 Q. If you look on the bottom lines of¶

8 the document, it says, Still in Thailand¶

9 during your stay, if she is, she will be¶

10 staying at the same hotel.¶

11 Do you recall ever giving Virginia¶

12 instructions to meet a girl in Thailand?¶

13 MR. PAGLIUCA: Objection to the¶

14 form and foundation.¶

15 A. I have already testified that I¶

16 didn't even know that Virginia was going to¶

17 Thailand.¶

18 Q. So you didn't give her instructions¶

19 to meet a girl in Thailand?¶

20 A. Like I said, I didn't even know she¶

21 was going to Thailand.¶

22 Q. Do you know whether Jeffrey Epstein¶

23 would have given her instructions to meet a¶

24 girl in Thailand?¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 A. I cannot possibly tell you what¶

4 Jeffrey did or didn't do. I wouldn't know.¶

S Q. Do you know whether Jeffrey Epstein¶

6 paid for Virginia to go to Thailand?¶

7 A. Again, I wouldn't know if he did.¶

8 (Maxwell Exhibit 12, documents,¶

9 marked for identification)¶

10 Q. I'm going to direct -- you can take¶

11 a look at it and then I'm going to direct¶

12 your attention to a couple of pages.¶

13 MR. PAGLIUCA: So the record should¶

14 be clear, this exhibit which is 12 is¶

15 375, 6, 7, 8, 9, 80, 1, and then skips¶

16 to 919, 920, 921, 922, 923, 924, 925 and¶

17 926.¶

18 Q. So I'm going to direct your¶

19 attention to the first page, have you ever¶

20 traveled with Jeffrey Epstein where you've¶

21 received a document like this from Shoppers¶

22 Travel in your own independent travel.¶

23 Do you recognize this?¶

24 MR. PAGLIUCA: Objection to the¶

25 form and foundation.¶

2 Q. The front form, the front page, do 3 you recognize this Shopper Travel form, have 4 you ever used them as a travel agent with 5 Jeffrey Epstein?¶

6 MR. PAGLIUCA: Same objection.¶

7 Q. You can answer.¶

8 A. I don't recognize this.¶

9 Q. Turning to the second page which is 10 the 00376, do you see at the top of that 11 document where it says Jeffrey Epstein, J. 12 Epstein 457 Madison Avenue 4th floor New York 13 New York.¶

14 Is that an address you are familiar 15 with that is Jeffrey Epstein's?¶

16 A. I am.¶

17 Q. Do you see below that, travel on 18 Singapore Airlines, and you are going to have 19 to go from New York JFK to Singapore Bangkok.¶

20 Do you see that?¶

21 MR. PAGLIUCA: What?¶

22 Q. The first entry is going to be on 23 September 27, New York.¶

24 MR. PAGLIUCA: I see it.¶

25 MS. McCAWLEY: I'm not talking to¶

2 you. I'm talking to the witness.¶

3 A. I see it.¶

4 Q. To Singapore Bangkok?¶

5 6 A. Singapore Bangkok I'm afraid are not the same place.¶

7 Q. Singapore, then Bangkok:¶

8 Q. I'm going to turn you to page¶

9 , it's a little further back 000919.¶

10 And do you see at the top where it says J.¶

11 12 mine? Epstein, underneath, Princess, change¶

13 A. I do.¶

14 Q. Does this refresh your recollection¶

15 16 paid that ' trip to Thailand was for by Jeffrey Epstein?¶

17 18 MR. PAGLIUCA: Objection to the form and foundation.¶

19 20 21 22 A. I can only testify to the piece of paper you showed me that has that information. I cannot testify from direct memory.¶

23 24 25 Q. When Virginia was traveling to Thailand, which the dates, again, I'm going to refer you back to the first page so you¶

2 can see the dates.¶

3 MR. PAGLIUCA: Can you identify a¶

4 number, please.¶

5 Q. which was at the top says,¶

6 I'm going to refer you,¶

7 at the same time, to the flight logs which¶

8 were marked, the thicker document that looks¶

9 like this with all the log entries on it.¶

10 I'm going to refer you to page --¶

11 MR. PAGLIUCA: That's Exhibit No.¶

12 6, correct? I'm trying to keep the¶

13 record straight.¶

14 MS. McCAWLEY: I don't have Exhibit¶

15 numbers on mine. That's¶

16 MR. PAGLIUCA: Hang on one second.¶

17 A. Can you repeat the number please.¶

18 Q. . And if you will look on¶

19 that page at the entry, under¶

20 starting with the and then it runs¶

21 down to the, looks like the that first¶

22 entry has¶

23 , Jeffrey Epstein and the¶

24 initials GM.¶

25 Do you remember taking a trip with¶

9 that's the it looks like, through the¶

10¶

11 A. I don't remember the dates. I¶

12 couldn't testify to when we actually did it¶

13 but I do remember the trip itself.¶

14 Q. So you were traveling with Jeffrey¶

15 Epstein and at the same¶

16 time Virginia was headed to Thailand, is that¶

17 correct?¶

18 MR. PAGLIUCA: Objection to the¶

19 form and foundation.¶

20 A. I don't know, is that right?¶

21 Q. If you look at on the¶

22 document that I gave you, the first document¶

23 and then you referred to, if you look in the¶

24 same as above lines, you will see the travel¶

25 group with¶

1 G Maxwell - Confidential¶

2 during¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 A. Can you repeat the question,¶

6 please?¶

7 Q. Do you remember taking a trip with¶

8 during¶

2 MR. PAGLIUCA: Are you asking her 3 to compare the documents or are you 4 asking her what her personal knowledge 5 is.¶

6 MS. McCAWLEY: I'm asking if she can 7 look at the doubts and tell me if she 8 recalls that she traveling with 9 at the same time this 10 document reflects Virginia was in 11 Thailand.¶

12 A. I can't testify to any dates. I 13 couldn't tell you. I can see a date and I 14 can see a date but I can't tell you that I 15 have a memory of the dates. I have a memory 16 of the trip, I don't have a memory of the 17 time.¶

18 Q. Who is ?¶

19 A.¶

20 Q. What is her address?¶

21 A. I don't know.¶

22 Q. Does she live in the United States?¶

23 A. She does.¶

24 Q. In what state?¶

25 A. I believe in New Jersey somewhere.¶

2 Q. Do you have her phone number?¶

3 A. Not memorized.¶

4 Q. Do you have the ability to get her 5 phone number?¶

6 A. Of course.¶

7 Q. Has she ever asked has¶

8 ever asked other girls to come over to 9 see Jeffrey Epstein for the purpose of a 10 sexual massage?¶

11 MR. PAGLIUCA: Objection to the 12 form and foundation.¶

13 A. Can you ask the question again 14 please.¶

15 Q. Has ever asked girls to 16 come over to see Jeffrey Epstein for the 17 purpose of a sexual massage?¶

18 MR. PAGLIUCA: Object to form and 19 foundation.¶

20 A. Can you ask again, please?¶

21 Q. Has ever asked girls to 22 come over to see Jeffrey Epstein for the 23 purpose of sexual massage?¶

24 A. I have no personal knowledge.¶

25 Q. What does do for you?¶

2 A. She helps with my not-for-profit¶

3 ocean foundation and any other related¶

4 activities that I may have.¶

5 Q. Is she paid for by Jeffrey Epstein?¶

6 A. No.¶

7 Q. She is paid for by you?¶

8 A. Yes.¶

9 Q. When did you first meet¶

10¶

11 A. I don't recollect exactly, sometime¶

12 maybe 2002, 2003.¶

13 Q. How did you meet her?¶

14 A. I don't recollect exactly how we¶

15 met.¶

16 Q. Did Jeffrey introduce you to her?¶

17 A. I don't recollect how we met.¶

18 Q. Does she know Jeffrey Epstein?¶

19 MR. PAGLIUCA: Objection to the¶

20 form and foundation.¶

21 A. Can you ask again, please?¶

22 Q. Does know Jeffrey¶

23 Epstein?¶

24 A. What do you mean by know?¶

25 Q. Has she met her him before?¶

2 MR. PAGLIUCA: Objection to the 3 form and foundation.¶

4 A. I can't recollect a time when¶

5 -- I've seen with Jeffrey but¶

6 Q. You are not sure¶

7 A. I know they know either other. I¶

8 can't testify to a meeting between them.¶

9 Q. Do you know where in New Jersey she 10 lives?¶

11 A. No¶

12 Q. You don't know a city?¶

13 A. No.¶

14 Q. How long has she worked for you?¶

15 A. Sometime 2002, 2003.¶

16 Q. To the present?¶

17 A. Yeah.¶

18 Q. Why do you think that 19 might know Jeffrey?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. Because you know, I know Jeffrey.¶

23 Q. Have you seen them together?¶

24 A. I already testified I have not seen 25 them together, to my recollection.¶

2 Q. Is it your testimony that¶

3 knows Jeffrey Epstein through the work¶

4 that she does for you?¶

5 MR. PAGLIUCA: Objection to the¶

6 form and foundation.¶

7 A. I don't recollect, and I don't¶

8 recollect how I met and I can't testify¶

9 to what relationship is or is not with¶

10 Jeffrey.¶

11 Q. Have you ever talked to Jeffrey¶

12 about¶

13 A. I don't know what you mean.¶

14 Q. In any way, have you ever had a¶

15 conversation with Jeffrey about¶

16 A. In what context.¶

17 Q. In any context. Have you ever 18 talked to Jeffrey Epstein about 2¶

19 A. works for me so it's entirely 20 possible that in the course of conversations¶

21 since 2002, 2003 that a conversation in which¶

22 name would have come up is entirely¶

23 possible.¶

24 Q. I provided you with and I'm sorry,¶

25 I don't know all the numbers, but the¶

2 statement that was issued by that 3 should be a single page still in your stack 4 of exhibits there.¶

S MR. PAGLIUCA: Exhibit 10.¶

6 Q. Did you authorize to issue 7 that statement on your behalf in January of 8 2015?¶

9 A. I already testified that that was 10 done by my lawyers.¶

11 Q. So did you authorize your lawyers 12 to issue a statement on your behalf through 13 in January of 2015?¶

14 A. It was determined that I had to 15 make a statement in the United Kingdom 16 because of the appalling lies and I just 17 thought of some new ones.¶

18 Virginia's statement that I 19 celebrated her 16 birthday with her. We can 20 all agree that that's entirely impossible. I 21 didn't meet her until she was 17 and other 22 lies she perpetrated that she had a diary and 23 we all know is a complete fake. That's not a 24 diary. It was just a book she was writing 25 that you helped sell to the press, as if it¶

2 was a diary, when it was just a story that¶

3 she is writing of fiction, fictional story¶

4 for money.¶

5 Q. How did you arrive at the words¶

6 that were put in that statement?¶

7 MR. PAGLIUCA: I'm going to object¶

8 and instruct you to the extent this¶

9 calls for any privileged communications¶

10 between yourself and or¶

11 another lawyer representing you, we're¶

12 asserting privilege. If you can answer¶

13 that without that, feel free to answer.¶

14 Q. So what your counsel is saying, and¶

15 I will exclude any privileged communications¶

16 you had with your lawyers.¶

17 The question is, how did you arrive¶

18 at the words that were put in that statement,¶

19 if you can tell me without disclosing¶

20 privileged communications?¶

21 A. I'm not sure that I can.¶

22 Q. Is the statement that you issued¶

23 true?¶

24 A. What do you mean by that?¶

25 Q. Is the statement that you issued,¶

2 the statement that's in front of you, is it a 3 true statement?¶

4 A. As in that Virginia is a liar?¶

5 Q. The words you put in there, is that 6 true?¶

7 A. Of course they're true.¶

8 Q. When did you become aware that the 9 statement was being released?¶

10 A. I don't recollect exactly.¶

11 Q. What day it was?¶

12 A. No.¶

13 Q. I'm sorry. Did you identify, I 14 might not have caught it, did you identify¶

15 the name of the lawyer that you said you 16 retained for purposes of this statement?¶

17 A. I think¶

18 Q. Did you pay that lawyer¶

19¶

20 A. Yes.¶

21 Q. Are you aware of any interstate or 22 international transportation of a woman aged 23 18 to 28 for the purposes of prostitution?¶

24 MR. PAGLIUCA: Objection to the¶

25 form and foundation.¶

2 A. I'm not sure I even understand your 3 question.¶

4 Q. I will go slower.¶

5 Are you aware of any interstate, 6 meaning between states, or international, 7 meaning oversees transportation, of women 8 aged 18 to 28, for the purposes of 9 prostitution?¶

10 MR. PAGLIUCA: Objection to the 11 form and foundation.¶

12 A. Are you asking -- I'm still not 13 sure I understand the question.¶

14 Q. I will try to make it clearer.¶

15 I'm asking you if you are aware of 16 any interstate, meaning between states, or 17 international transportation, meaning by 18 flight or by car or by train, of women aged 19 18 to 28, their ages are between the ages of 20 18 and 28, for the purposes of prostitution?¶

21 MR. PAGLIUCA: Objection to the 22 form and foundation.¶

23 A. In the world I'm sure that that 24 happens, I read about it all the time.¶

25 Q. Not in the world. Are you aware of¶

1 G Maxwell - Confidential 2 it, in your experience with Jeffrey Epstein, 3 of any interstate or international 4 transportation of women aged 18 to 28, for 5 the purposes of prostitution?¶

6 MR. PAGLIUCA: Objection to the 7 form and foundation.¶

8 A. So whilst I appreciate this might 9 not seem like a smart question, what do you 10 mean by prostitution, what are you asking me 11 exactly?¶

12 Q. That would be sex for hire, any 13 kind of sexual act that's paid for.¶

14 MR. PAGLIUCA: Objection to the 15 form and foundation.¶

16 A. Who's paying, what are you asking 17 me.¶

18 Q. It can be paid for by anybody. 19 It's a sexual act that's paid for.¶

20 I'm asking if you are aware of any 21 interstate or international transportation of 22 women aged 18 to 28, for the purposes of 23 prostitution?¶

24 MR. PAGLIUCA: Objection to the 25 form and foundation.¶

2 A. I have no idea what you are talking 3 about.¶

4 Q. So you are not aware of that?¶

5 A. No.¶

6 Q. Are you aware of any interstate or 7 international transportation of women, aged 8 18 to 28, for the purposes of having sex with 9 Epstein where they would receive compensation 10 of any type?¶

11 MR. PAGLIUCA: Objection to the 12 form and foundation.¶

13 A. I don't know what you are referring 14 to.¶

15 Q. Do you want me to repeat the 16 question?¶

17 A. Sure, go ahead.¶

18 Q. Are you aware of any interstate or 19 international transportation of woman, aged 20 18 to 28, for the purpose of having sex with 21 Jeffrey Epstein where they would receive 22 compensation of any type?¶

23 MR. PAGLIUCA: Objection to form 24 and foundation.¶

25 A. I am not aware of what you are¶

2 talking about.¶

3 Q. Are you aware of any interstate or¶

4 international transportation of women, aged¶

5 18 to 28, for the purposes of providing a¶

6 massage for Jeffrey Epstein?¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. So I you need to repeat that¶

10 question for me.¶

11 Q. Sure.¶

12 Are you aware of any interstate,¶

13 meaning between states, or international,¶

14 oversees, transportation of women, aged 18 to¶

15 28, for the purposes of providing massage for¶

16 Jeffrey Epstein?¶

17 MR. PAGLIUCA: Objection to the¶

18 form and foundation.¶

19 A. I think we can agree he did travel¶

20 from time to time with a professional adult¶

21 masseuse.¶

22 Q. Are you aware of any interstate or¶

23 international transportation of women, aged¶

24 18 to 28, for the purposes of providing a¶

25 massage to any person other than Jeffrey¶

2 Epstein?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 A. Again, I'm not aware of anybody¶

6 that, if you are asking for specifics to¶

7 someone else, I have no knowledge of that.¶

8 Q. So you are not aware of any¶

9 interstate or international transportation of¶

10 a woman aged 18 to 28 for the purposes of¶

11 providing a massage to any person other than¶

12 Jeffrey Epstein?¶

13 MR. PAGLIUCA: Objection to the¶

14 form and foundation.¶

15 A. I don't recall what any single¶

16 person being on a plane for a massage with¶

17 someone else other than Jeffrey, for the sole¶

18 purpose, if that's the question, I don't have¶

19 any recollection of that.¶

20 Q. Earlier in your testimony, you¶

21 stated that was 17 at the¶

22 time you met her.¶

23 How do you know she was 17?¶

24 MR. PAGLIUCA: Objection to the¶

25 form and foundation. And to the extent¶

2 that calls for a privileged response,¶

3 I'm instructing you not to answer.¶

4 Q. How do you know¶

5 was 17 at the time you met her?¶

6 MR. PAGLIUCA: Again, if you¶

7 learned that information from your¶

8 lawyer, I'm instructing you not to¶

9 answer.¶

10 A. I will follow my counsel's advice.¶

11 Q. Are you able to answer that¶

12 question without telling me information you¶

13 learned from a lawyer?¶

14 A. I'm not.¶

15 Q. So you don't have independent¶

16 knowledge that Virginia, according to your¶

17 statement, was 17 at the time you met her?¶

18 A. Again, my lawyer has instructed me¶

19 not to answer.¶

20 Q. I'm asking you a different¶

21 question. Whether you have any independent¶

22 knowledge, outside your lawyers, that¶

23 Virginia was 17 at the time you met her?¶

24 A. Following the instructions of my¶

25 lawyers, I can only remember or testify to¶

2 what she --¶

3 MR. PAGLIUCA: She is asking you a 4 different question. She is asking other 5 than what your lawyers have told you, do 6 you have any knowledge about her being 7 17, that's what she is asking.¶

8 A. I can't recollect where I got all 9 the information that I have that definitively 10 shows that.¶

11 Q. Earlier in your testimony, I 12 believe you said all of us would know that 13 Virginia was 17 at the time you met her.¶

14 How would we know that?¶

15 A. I think you know that by her own 16 dates, now that it was in 2000, so her entire 17 tail of me celebrating her 16th birthday is 18 clearly another giant falsehood.¶

19 Q. But she was 16 and 17 that year, 20 wasn't she?¶

21 A. Which year?¶

22 Q. You said it was 2000.¶

23 A. I think the information that I have 24 that indicates that definitively was 25 something that is privileged, so I can't¶

2 share with you.¶

3 Q. So you have privileged information¶

4 that definitively tells you that she was 17¶

5 at the time you met her?¶

6 A. I believe I do.¶

7 Q. How would we know that?¶

8 A. What are you asking me?¶

9 Q. Earlier today you testified that we 10 would know that she was 17 at the time that 11 you met her.¶

12 How would we know that?¶

13 A. I imagine you have access to 14 exactly the same information that I do.¶

15 Q. What is that information?¶

16 A. Again, it's privileged, I can't 17 share it with you but you have been on this 18 case for, I don't know, much much longer than¶

19 I have and I imagine you have all the 20 information that I do.¶

21 Q. Do you know whether your lawyers 22 have produced documents from you that would 23 show the age that Virginia was at the time 24 that you met her?¶

25 MR. PAGLIUCA: To the extent that¶

2 calls for a communication that you had¶

3 with one of your lawyers, I'm¶

4 instructing you not to answer that¶

5 question.¶

6 Q. I assume you, as part of the¶

7 discovery process, had to collect documents¶

8 that were relevant to this action, is that¶

9 correct?¶

10 A. I did.¶

11 Q. Did you collect documents that¶

12 would show that Virginia was 17 at the time¶

13 that you met her?¶

14 A. I think you have everything that¶

15 relates, that I had, contemporaneously per¶

16 what you asked for that I have that relates¶

17 to that.¶

18 Q. Did you have a document that¶

19 identified that Virginia was 17 at the time¶

20 that you met her?¶

21 A. You have all of the documents that¶

22 I had.¶

23 Q. I'm not asking what documents. I'm¶

24 asking, do you have a document that¶

25 identifies Virginia being 17 at the time you¶

2 met her?¶

3 A. You have every document that I¶

4 have. You have seen every document that I¶

5 have.¶

6 Q. That's not what I'm asking.¶

7 A. I don't recall every document that 8 I gave you, so I don't know. I would have to¶

9 look at every single document I gave you and¶

10 then review it but as I recall you have every 11 document that I have.¶

12 Q. What are you planning to show the 13 jury that will prove that Virginia was 17 14 when you met her?¶

15 A. Again that's privileged so I can't 16 share that with you.¶

17 Q. If you're showing the jury, it 18 wouldn't be privileged, so is there a 19 document you have produced in this matter 20 that shows that Virginia was 17 at the time 21 you met her?¶

22 MR. PAGLIUCA: She answered that 23 question already. She said she doesn't 24 know, she has given you everything. If 25 there is a decision -- assuming for the¶

2 moment there is such a document, just¶

3 hypothetically, and assuming for the¶

4 moment that it is going to get produced¶

5 somewhere, if it hasn't already been¶

6 produced, obviously that would involve a¶

7 waiver, a future waiver of the¶

8 privilege. I think that's the answer to¶

9 the question.¶

10 Q. Has the document been produced, do¶

11 you know?¶

12 A. You have everything that I have¶

13 given you, so if you can't -- if it's not in¶

14 those documents, I don't know what to tell¶

15 you.¶

16 Q. Your lawyers haven't withheld any¶

17 documents?¶

18 A. They are right here. You can ask¶

19 them.¶

20 Q. I'm asking you.¶

21 A. I don't know what -- they're¶

22 lawyers.¶

23 Q. When we were talking earlier about¶

24 , I asked you whether you had¶

25 ever given him a gift of a puppet.¶

2 Did you ever, not as a gift, did 3 you ever see in the presence of 4 a puppet? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. Can you be more direct, please? 8 Q. Sure. Were you ever in a room with 9 where there was a puppet? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. Can you be more specific please and 13 can you bound it by time and be more 14 specific, whatever you are actually asking 15 me? 16 Q. Were you ever in a room with 17 in New York in Jeffrey Epstein's home 18 where there was a puppet? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. What sort of puppet are you asking 22 me?¶

23 Q. Any kind of puppet? 24 A. You need to be more descriptive. I 25 don't know what you mean by puppet, there is¶

2 hand puppets, all sorts of puppets.¶

3 Q. Is there any puppet you've ever¶

4 seen in Jeffrey Epstein's home in the¶

5 presence of¶

6 A. Again, puppet, you know, there is¶

7 lots of types of puppets.¶

8 Q. Any type of puppet.¶

9 A. If you want to give me a 10 description of the puppet, I would be perhaps 11 be able to say.¶

12 Q. Any type of puppet?¶

13 A. Can you be more detailed?¶

14 Q. Have you ever seen a puppet in 15 Jeffrey Epstein's home in the presence of 16¶

17 A. My understanding of a puppet is a 18 small handheld item you have in a circus. I 19 have never seen that.¶

20 Q. Have you ever seen a puppet which 21 is defined as a movable model of a person or 22 animal that is used in entertainment and 23 typically moved either by strings or 24 controlled from above or by a hand inside it? 25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 A. I have not seen a puppet that fits 4 exactly that description.¶

5 Q. Have you seen any puppet that fits 6 any description?¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. Can you reask the question, please?¶

10 Q. Yes.¶

11 Have you seen any puppet that fits¶

12 any description in the presence of¶

II in Jeffrey Epstein's home?¶

MR. PAGLIUCA: Objection to the¶

15 form and foundation.¶

16 A. I am not aware of any small¶

17 handheld puppet that was there. There was a¶

18 puppet -- not a puppet -- there was a -- I¶

19 don't know how would you describe it really,¶

20 I don't know how would you describe it. Not¶

21 a puppet, I don't know how you would describe¶

22 it. A caricature of that was¶

23 in Jeffrey's home.¶

24 Q. Did you use that caricature to put¶

25 the hand of the caricature on¶

2 breast?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 A. I don't recollect. I recollect the¶

6 puppet but I don't recollect anything around¶

7 the puppet. You characterized puppet, I¶

8 characterize it as, I don't know, as a¶

9 characterization of¶

10 Q. Do you recollect asking¶

II to sit on lap with¶

12 the caricature of ?¶

13 A. I do not recollect that.¶

14 Q. What do you remember about the¶

15 caricature of the caricature¶

16 when you were in the presence of¶

17 and¶

18 MR. PAGLIUCA: Objection to the¶

19 form and foundation.¶

20 A. I don't recollect the story as told¶

21 by or Virginia. I don't even know¶

22 who -- I remember the caricature of¶

23 and I remember but I¶

24 don't recall anything else around the¶

25 caricature.¶

2 Q. Did you give it to him?¶

3 A. I did not.¶

4 Q. Who gave it to him?¶

5 6 A. I don't think it was given to him at all.¶

7 Q. Did he bring it?¶

8 A. No.¶

9 10 Q. Was it something that was at the house?¶

11 A. As best I recollect.¶

12 13 14 Q. Was it something that you saw at the house in advance of arrival?¶

15 16 the caricature, I recollect 17 don't recollect much else around the 18 caricature. A. Again, I don't real -- I recollect¶

19 Q. 20 house at the time you recollect the 21 Was there a party going on in the caricature?¶

22 23 MR. PAGLIUCA: Objection to the form and foundation.¶

24 A. You have to be way more specific?¶

25 Q. Do you remember, you said you¶

2 recollect this caricature, you recollect¶

3 being there. Do you recollect¶

4 a party going on at the time of that¶

5 interaction with and the¶

6 caricature?¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. I don't recollect a party -- first¶

10 of all, they weren't really parties -- I¶

11 don't recollect a party -- I don't know what¶

12 you mean by party in the context of that¶

13 scenario.¶

14 Q. Who do you recollect being at the¶

15 home during the time was there¶

16 with this caricature?¶

17 MR. PAGLIUCA: Objection to the¶

18 form and foundation.¶

19 A. I only recollect myself with¶

20 I don't recollect anybody else.¶

21 Q. You don't recollect Jeffrey Epstein¶

22 being there?¶

23 A. Actually, no.¶

24 Q. You don't recollect¶

25 being there?¶

2                                  A.                      No.¶

3                                  Q.                      You don't recollect [REDACTED]¶

4                                  [REDACTED] being there?¶

5                                  A.                      No.¶

6                                  Q.                      It was just you and [REDACTED]?¶

7                                  A.                      I am not saying it was just me and¶

8                                  [REDACTED], you are asking me do you¶

9                                  remember. I only remember [REDACTED], I¶

10                                  remember [REDACTED] and the caricature but¶

11                                  I can't place the caricature and everybody¶

12                                  else in the same context, the same timeframe¶

13                                  you are asking me.¶

14                                  Q.                      [REDACTED]¶

[REDACTED] [REDACTED]¶

[REDACTED] [REDACTED]¶

[REDACTED] [REDACTED]¶

18                                  [REDACTED] [REDACTED]¶

[REDACTED] [REDACTED]¶

[REDACTED] [REDACTED] [REDACTED]¶

[REDACTED] [REDACTED]¶

[REDACTED] [REDACTED]¶

[REDACTED] [REDACTED]¶

24                                  MR. PAGLIUCA: Objection to the¶

25                                  form and foundation.¶

¶

2 A. Typically, there is no typical 3 because there is no standard procedure, so I 4 can't comment or testify to¶

6 Q. Do you remember them being in the 7 house?¶

8 A. Not specifically. 9 Do you mind if I take a bathroom 10 break.¶

11 THE VIDEOGRAPHER: It's now 3:51 12 and we are off the record. 13 (Recess.)¶

14 THE VIDEOGRAPHER: It's now 4:04. 15 We are back on the record and we're 16 starting disk No. 7.¶

17 Q. Ms. Maxwell, during what time 18 period, I know you said, I believe you said 19 you met Jeffrey in 1991, if I'm correct there 20 and you've known him through the present.¶

21 During what time period within 22 those years would you say your relationship 23 was the closest with Jeffrey?¶

24 MR. PAGLIUCA: Objection to the 25 form and foundation.¶

2 A. What do you mean by close, sorry.¶

3 Q. I think earlier today you testified¶

4 that at some point in time you considered¶

5 yourself to be his girlfriend, is that the¶

6 closest you would say that your relationship¶

7 was with him and if so, what time period was¶

8 that?¶

9 MR. PAGLIUCA: Objection to the¶

10 form and foundation.¶

11 A. I don't think I said I was his¶

12 girlfriend, I would like to think of myself¶

13 as maybe, I don't think I sometime in the¶

14 mid '90s.¶

15 Q. How close was your relationship?¶

16 A. We were very friendly.¶

17 Q. Without going into details, was¶

18 your relationship with him intimate?¶

19 A. Yes.¶

20 Q. When was the last time you had¶

21 contact with Jeffrey Epstein?¶

22 A. What do you mean by contact.¶

23 Q. Either a phone call or email or¶

24 anything of that nature?¶

25 A. As best as I can recollect when¶

2 all -- sometime last year.¶

3 Q. So you haven't talked to him like, 4 for example, last week you didn't talk to 5 him?¶

6 A. I did not.¶

7 Q. How many times have you had either 8 direct or indirect, meaning, in the presence 9 of him or calling or emailing, contact with 10 Jeffrey Epstein from December 30, 2014 until 11 now?¶

12 A. I'm sorry, can you just¶

13 Q. Either in person or by phone or by 14 email, from December 30, 2014 until present.¶

15 A. I can't really characterize that 16 but not very much. There was a period when 17 in January when you filed your, whatever you 18 filed, where we spoke and then, since then 19 not much at all.¶

20 Q. Can you estimate how many emails 21 you would have sent Jeffrey from the period 22 of December 30, 2014 to the present?¶

23 A. Not very many at all.¶

24 Q. More than 20?¶

25 A. I really wouldn't be able to¶

2 characterize it because it wouldn't be that¶

3 many. I wouldn't know.¶

4 Q. More than 50?¶

5 A. It would be on the lesser side, not¶

6 on the more side.¶

7 Q. Can you give me a number?¶

8 A. I honestly couldn't. I would be¶

9 guessing.¶

10 Q. How many emails has Jeffrey sent¶

11 you from the period December 30, 2014 to the¶

12 present?¶

13 A. I would say less emails, even less¶

14 emails than I sent him.¶

15 Q. More than 20?¶

16 A. I would say on the lesser side.¶

17 Q. Less meaning 10?¶

18 A. I really can't recall, very little.¶

19 Q. When you spoke with Jeffrey in¶

20 January of 2015, what did he say to you?¶

21 A. I really couldn't remember exactly¶

22 what he said to me.¶

23 Q. Did you talk about¶

A. I'm sure we did but I couldn't¶

2 recall the exact conversation.¶

3 Q. Does Jeffrey Epstein send you text 4 messages?¶

5 A. No.¶

6 Q. Do you send him text messages?¶

7 A. No.¶

8 Q. How many phone calls have you had 9 with Jeffrey Epstein since December 30, 2014?¶

10 A. Again, very few.¶

11 Q. More than five?¶

12 A. Probably as many as the few emails 13 that I would characterize, so just very few. 14 I mean a small number.¶

15 Q. Are you aware of any disagreement 16 between your views about and 17 Jeffrey's views about¶

18 MR. PAGLIUCA: Object to the form 19 and foundation¶

20 A. I cannot speculate to his views. I 21 can only testify on my views.¶

22 Q. Earlier you went through the series 23 of lies. Have you talked to Jeffrey about 24 the lies and does he agree with you?¶

25 A. I have discussed some of the issues¶

1 G Maxwell - Confidential 2 with him, I can't remember specifically which 3 ones. I just don't recall. I'm sorry.¶

4 Q. Do you recall him telling you that 5 he didn't agree with you on any of those?¶

6 A. I don't recall him saying that.¶

7 Q. Do you have a joint defense 8 agreement with Jeffrey Epstein?¶

9 A. I believe I do.¶

10 Q. Do you have a joint defense 11 agreement with¶

12 A. I don't believe I do.¶

13 Q. Earlier today in your testimony, 14 when I was asking you some questions, you 15 said that you couldn't answer but that 16 Jeffrey Epstein could answer that question.¶

17 Would Jeffrey Epstein be in a 18 position to confirm or deny some of the 19 obvious lies that we've discussed today?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. I can't possibly testify to what 23 Jeffrey could or would say. I can't speak 24 for him.¶

25 Q. Would Jeffrey be able to confirm or¶

2 deny whether he had sex with¶

4 MR. PAGLIUCA: Objection to the¶

5 form and foundation.¶

6 A. I can't say what Jeffrey would say.¶

7 Q. Has he discussed that with you?¶

8 A. He has not.¶

9 Q. Would Jeffrey be able to confirm or 10 deny whether he had a sexual massage from 11 Virginia that first time she came to his 12 mansion in Palm Beach?¶

13 MR. PAGLIUCA: Objection to the 14 form and foundation.¶

15 A. I cannot speak for what he would 16 say. I can only speak for what I would say. 17 So as I testified everything that she said 18 about that first meeting didn't happen so...¶

19 Q. Has he told that you everything 20 about that first meeting didn't happen?¶

21 A. I know it didn't happen because she 22 put me in that room.¶

23 Q. I understand you know. But has 24 Jeffrey said when you are talking about the 25 obvious lies, • yeah, that never happened?¶

2 MR. PAGLIUCA: Objection to the 3 form and foundation.¶

4 A. I can't specifically recall that.¶

5 I don't know, but he has to agree with me 6 because it didn't happen.¶

7 Q. Can Jeffrey Epstein, would he be 8 able to confirm or deny whether he had sex 9 with underage girls?¶

10 MR. PAGLIUCA: Objection to the 11 form and foundation.¶

12 A. I can't testify to what Jeffrey 13 would say.¶

14 Q. Can Jeffrey confirm or deny whether 15 was on Jeffrey's island?¶

16 MR. PAGLIUCA: Objection to the 17 form and foundation.¶

18 A. I can't say what Jeffrey would say. 19 I can only say what I know to be true.¶

20 Q. Has Jeffrey talked to you about the 21 fact whether was on his island?¶

22 A. As best as I can recollect, he said 23 he was not on the island. As best as I can 24 recollect.¶

25 Q. Can Jeffrey Epstein confirm whether¶

2 he and were together in the¶

3 presence of¶

4 MR. PAGLIUCA: Objection to the¶

5 form and foundation.¶

6 A. I can't speak to what Jeffrey would¶

7 say.¶

8 Q. Has he talked to about¶

statement that she was in the¶

10 presence of¶

11 MR. PAGLIUCA: Objection to the¶

12 form and foundation.¶

13 A. I have not discussed individual¶

14 presences with Virginia. That's not -- I'm¶

15 only concerned with what I know to be the¶

16 stuff about me. So my focus has always been¶

17 the lies and the obvious lies as something I¶

18 can personally attest to. I cannot possibly¶

19 talk for anything else.¶

20 Q. Has Jeffrey Epstein said to you¶

21 anything along the lines of Virginia is lying¶

22 when she says she met¶

23 MR. PAGLIUCA: Objection to the¶

24 form and foundation.¶

25 A. Again, I'm not talking about what¶

2 she says as regards to other people. I can¶

3 talk to things as regards to me.¶

4 Q. I'm asking if Jeffrey ever said¶

5 that to you?¶

6 A. I don't recollect specific¶

7 conversations along those things.¶

8 Q. You don't recollect him saying that¶

9 to you?¶

10 A. I don't recollect him saying to me¶

11 that Virginia didn't meet . I'm¶

12 sure that wouldn't be a conversation that we¶

13 would have. It doesn't effect me whether¶

14 so I'm really only concerned about the lies¶

15 that were told as regards to me.¶

16 Q. Can Jeffrey Epstein confirm or deny¶

17 whether you sent Virginia to give¶

18 a massage?¶

19 MR. PAGLIUCA: Objection to the¶

20 form and foundation.¶

21 A. I can't say what Jeffrey would say,¶

22 I can tell you I didn't. I can't tell you¶

23 what anybody else.¶

24 Q. Have you discussed with him¶

25 Virginia's allegation that she gave¶

2 a massage?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 A. I didn't know that she did say¶

6 that.¶

7 Q. Do you know whether Jeffrey Epstein¶

8 has ever sent anybody to to¶

9 perform a massage for him?¶

10 MR. PAGLIUCA: Objection to the¶

11 form and foundation.¶

12 A. I couldn't possibly recollect¶

13 whether he did anything like that.¶

14 Q. Did you ever send anybody, not¶

15 Virginia, anybody else over to¶

16 home for a massage?¶

17 A. Not to the best of my knowledge.¶

18 Q. Do you know one of¶

19 friend by the name of¶

20¶

21 A. I do recollect a person of that¶

22 name.¶

23 Q. How do you know her?¶

24 A. I don't recollect.¶

25 Q. Did you meet her through Jeffrey?¶

2 A. I don't recollect.¶

3 Q. Do you recall when you met her?¶

4 A. I do not recollect.¶

5 Q. How many times have you seen¶

6 in your life?¶

7 A. The only reason I remember is¶

8 because it's an unusual name but I couldn't¶

9 tell you anything else.¶

10 Q. You didn't see her on a regular¶

11 basis, she wasn't one of your friends?¶

12 A. No.¶

13 Q. Was a masseuse?¶

14 A. Not to my knowledge.¶

15 Q. Do you have knowledge of whether¶

16 she had a sexual relationship with Jeffrey¶

17 Epstein?¶

18 A. I have no knowledge of that.¶

19 Q. When was the last time you spoke¶

20 with her?¶

21 A. A very long -- I have no idea.¶

22 Q. Would it be years?¶

23 A. Yes.¶

24 Q. What do you remember about¶

2 A. Nothing really.¶

3 Q. Do you remember what she looks¶

4 like?¶

5 A. I would just be speculating on how¶

6 I remember. I couldn't describe her.¶

7 Q. Do you recall traveling with her?¶

8 A. I don't.¶

9 Q. Did you ever go to her home?¶

10 A. I don't believe I did.¶

11 Q. Do you know where she lives?¶

12 A. I don't.¶

13 Q. Would you have met her through¶

14 Jeffrey Epstein?¶

15 MR. PAGLIUCA: Objection to the¶

16 form and foundation.¶

17 A. I already testified I don't¶

18 recollect how I met her and I remember her¶

19 because her name is very unusual.¶

20 Q. So what's your -- what recollection¶

21 do you have of her, do you have a specific¶

22 recollection of meeting her somewhere, you¶

23 just don't know when that was or how do you¶

24 know that name¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 A. I don't know why the name is I'm¶

4 sorry -- I can't -- I have no idea. I¶

5 recognize the name but that's it.¶

6 Q. Was a masseuse?¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. What are you asking me, I'm sorry?¶

10 Q. When worked for¶

11 Jeffrey Epstein, did she perform massages?¶

12 A. I've testified that when¶

13 came originally, she came to answer¶

14 telephones. I believe at some point she¶

15 became a masseuse. I don't recollect when¶

16 and I personally had massages from¶

17 Q. What did do for Jeffrey¶

18 Epstein, did she perform massages, anything¶

19 else?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation.¶

22 A. When she came she answered phones¶

23 and at some point, I believe, I don't have¶

24 any firm recollection, but I believe she went¶

25 to school and became a masseuse and I had¶

2 massages from her.¶

3 Q. Did you ever have any sexual¶

4 interaction with her?¶

5 MR. PAGLIUCA: Object to the form¶

6 and foundation and I'm going to instruct¶

7 you if we're talking about any¶

8 consensual adult contact, you are not¶

9 allowed to answer the question.¶

10 Q. Did you have any sexual contact¶

11 with her in the presence of Jeffrey Epstein?¶

12 MR. PAGLIUCA: Same instruction.¶

13 Q. Did you have any sexual contact¶

14 with her in the presence of anybody other¶

15 than Jeffrey Epstein?¶

16 MR. PAGLIUCA: Same instruction.¶

17 Q. How many massages did you receive¶

18 from¶

19 A. I really don't recall but a fair¶

20 amount.¶

21 Q. Did the massages involve sex?¶

22 MR. PAGLIUCA: I'm going to¶

23 instruct you not to answer.¶

24 Q. Have you ever engaged in sex with¶

25 any female?¶

2 MR. PAGLIUCA: I'm going to¶

3 instruct you not to answer.¶

4 MS. McCAWLEY: I want the record to¶

5 reflect that Ms. Maxwell's attorney is¶

6 directing her not to answer this series¶

7 of questions.¶

8 MR. PAGLIUCA: It definitely does.¶

9 Q. Were you responsible for¶

10 introducing to Jeffrey Epstein?¶

11 MR. PAGLIUCA: Objection to the¶

12 form and foundation.¶

13 A. I already testified that I don't¶

14 really recall¶

15 Q. Were you responsible for¶

16 introducing to Jeffrey Epstein?¶

17 MR. PAGLIUCA: Objection to the¶

18 form and foundation.¶

19 A. Again, I don't like the¶

20 characterization of introduction.¶

21 came to answer telephones.¶

22 Q. When did you -- were you the person¶

23 who brought or introduced or met for¶

24 purposes of bringing her to Jeffrey Epstein's¶

25 home?¶

2 MR. PAGLIUCA: Objection to the 3 form and foundation.¶

4 A. That's not how I would characterize 5 that.¶

6 Q. How would you characterize it?¶

7 A. I have testified that I'm 8 responsible for finding professional people 9 to work in the homes, age appropriate adult 10 people, so from pool attendants, to 11 gardeners, to chefs, to housekeepers, to 12 butlers, to chauffeurs and one of the 13 functions was to be able to answer the 14 telephones and in the context of finding 15 someone to answer the telephones, I did look 16 to try to find appropriate people to answer 17 the phones.¶

18 Q. So did you find Johanna for 19 purposes of that role?¶

20 A. So in the course of looking for 21 somebody to answer phones at the house, 22 Johanna was one of the people who said that 23 she was willing to answer phones.¶

24 Q. Did you approach her at her school 25 campus?¶

2 MR. PAGLIUCA: Objection to form 3 and foundation.¶

4 A. I honestly don't recall how, in 5 that moment, how I met and how she 6 came to get the job but...¶

7 Q. Did you typically, in your work for 8 Jeffrey Epstein, would you typically go to 9 school campuses to try to find individuals to 10 work for Jeffrey Epstein?¶

11 MR. PAGLIUCA: Objection to the 12 form and foundation.¶

13 A. I never -- what do you mean by 14 school? Let's characterize school.¶

15 Q. Any kind of school.¶

16 A. Obviously not. I never went to any 17 school with young people. I believe 18 came from an adult university, as I would 19 know in England, so university, I went there 20 but I never went, as i best recollect, 21 anywhere else.¶

22 Q. Did you -- what university was it 23 that you went to?¶

24 A. I don't recall the university that 25 she went to right now.¶

2 Q. Would you visit more than one¶

3 university to try to find individuals to work 4 for Jeffrey Epstein?¶

5 A. As I recollect, I think that's, in 6 fact, the only university I went to.¶

7 Q. Did you go there more than once?¶

8 A. I think I went twice.¶

9 Q. Who else did you find from that 10 university, was there anybody other than¶

11¶

12 A. I don't recollect, I'm sorry.¶

13 Q. We are going to mark this as¶

14 Maxwell 13?¶

15 (Maxwell Exhibit 13, documents, 16 marked for identification.)¶

17 Q. Can you take a look at the document 18 I put in front of you, please.¶

19 Are you familiar with this 20 document?¶

21 A. I'm familiar with this actual 22 document.¶

23 Q. How was this document created?¶

24 MR. PAGLIUCA: Objection to the 25 form and foundation.¶

2 A. I don't know how this document was 3 created.¶

4 Q. You were involved in the creation 5 of this document?¶

6 A. I think you can see from the date 7 that it's 2004, 2005, so no.¶

8 Q. You weren't involved in the 9 creation of this document.¶

10 Did you -- we talked earlier about 11 Mr. Epstein's house, I'm talking about the 12 Palm Beach house where you said there was a 13 computer on the desk, that employees had 14 access to -- people who worked for Jeffrey 15 Epstein may have had access to?¶

16 A. I think anybody could have had 17 access to that.¶

18 Q. Was that computer used, if you know 19 to keep a log of addresses and phone contact 20 information for Jeffrey Epstein?¶

21 A. Are we talking about when this 22 document was created.¶

23 Q. In general, was there, on that 24 computer during the time that you were 25 present with Jeffrey Epstein, was there a¶

2 mechanism by which you kept electronic¶

3 information of names and addresses of¶

4 individuals that he knew?¶

5 MR. PAGLIUCA: Objection to the¶

6 form and foundation.¶

7 A. I can't testify to what was on that¶

8 computer or not after I was gone.¶

9 Q. Not when you were gone, when you¶

10 were there. If Jeffrey wanted to call, for¶

11 example, say, would someone be¶

12 able to go to that computer to pull up the¶

13 address information and phone contact¶

14 information for that individual?¶

15 MR. PAGLIUCA: Objection to the¶

16 form and foundation.¶

17 A. I couldn't possibly say.¶

18 Q. Did you ever have to keep track of¶

19 address or phone contact information for¶

20 Jeffrey Epstein?¶

21 A. That was not my job.¶

22 Q. Did you ever do it?¶

23 A. I am not responsible for keeping¶

24 his numbers so that wasn't my job at all.¶

25 Q. But did you ever do it? I know¶

2 it's not your job but did you ever do it, did 3 you ever keep phone contact information for 4 him?¶

5 A. During the course of the time we 6 were together, if he gave me a telephone 7 number, I would give it to an assistant to 8 put in the computer, I could do that.¶

9 Q. Would he ask you for contact 10 information for different individuals, if he 11 wanted to contact someone?¶

12 MR. PAGLIUCA: Objection to the 13 form and foundation.¶

14 A. In the course of the long period of 15 time when I was there, it certainly would be 16 possible for him to ask me for a telephone 17 number and if I had the -- I wouldn't always 18 have it -- I'm sure it happened.¶

19 Q. Was there a hardcopy book in 20 addition to the computer, a hardcopy book 21 that you could look for numbers that were 22 relevant to Jeffrey Epstein's life and 23 something on the computer or was it just an 24 electronic version?¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 Q. Was there a hard copy book as well 4 as something on the computer or was there 5 only electronic information on the phone 6 numbers?¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. I can only testify to what I know 10 obviously, and I believe that this is a copy 11 of a stolen document. I would love to know 12 how you guys got it.¶

13 Q. I'm asking during the time you 14 worked for Jeffrey Epstein, was there a 15 hardcopy document of any kind that kept phone 16 numbers for Jeffrey Epstein, if he needed to 17 contact someone?¶

18 A. The stolen document I have in front 19 of me that you have is what you are referring 20 to.¶

21 Q. So there was, during your time when 22 you were there, there was no other, you 23 mentioned there was information on a 24 computer. Was there any hardcopy document 25 that you could refer to to find someone's¶

2 number?¶

3 A. You have the stolen document in¶

4 front of you.¶

5 Q. You had access to this when you¶

6 worked for Jeffrey Epstein?¶

7 A. This is, I believe, the book that¶

8 was stolen, that was the hardcopy of whatever¶

9 was there.¶

10 Q. So when you were working for¶

11 Jeffrey Epstein, you were able to access this¶

12 book?¶

13 A. This book -- if this is what this¶

14 is, I believe it was, this is the stolen¶

15 document from his house.¶

16 Q. And you were able to access it when¶

17 you worked for him?¶

18 A. It was a document that was printed¶

19 that you could, if you needed to, look for a¶

20 number.¶

21 Q. Do you know how this book was¶

22 created?¶

23 A. No.¶

24 Q. When you referred to it a moment¶

25 ago, to a stolen document, when¶

2 turned this document over to the¶

3 FBI, are you aware he described it as a¶

4 document that came from your computer?¶

5 MR. PAGLIUCA: Objection to the¶

6 form and foundation.¶

7 A. I have no idea what he said or¶

8 didn't say, so if you want me to reference¶

9 something he said, you need to show it to me.¶

10 Q. Did you keep this document, an¶

11 electronic copy of it, on your personal¶

12 computer?¶

13 A. I don't recollect.¶

14 Q. If you had to update something, for¶

15 example, if there was a new number, a new¶

16 individual that Jeffrey had hired that you¶

17 were going to track, would you input that¶

18 information into this document on your¶

19 computer?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation.¶

22 A. I've already testified that I'm not¶

23 responsible for updating and keeping these¶

24 records.¶

25 Q. Did you have this document on your¶

2 computer, your personal computer?¶

3 A. I told you, I don't recollect¶

4 having this document on my computer.¶

5 Q. Do you know what computers this¶

6 document was on, if more than one?¶

7 A. I'm sorry, this is a long time ago¶

8 and I don't recall exactly how this was all¶

9 managed.¶

10 Q. If you didn't create this document,¶

11 do you know who did?¶

12 MR. PAGLIUCA: Objection to the¶

13 form and foundation.¶

14 A. I don't.¶

15 Q. I'm going to direct your attention¶

16 to part of this document. It's towards the¶

17 back, it's going to be page 91 and it has¶

18 label 001663. I'm going to¶

19 direct your attention to the section that¶

20 says, Massage Florida.¶

21 Did you input any of the names or¶

22 numbers under that section?¶

23 MR. PAGLIUCA: Objection to form¶

24 and foundation.¶

25 A. So this document is produced in¶

2 2004, 2005, so, no.¶

3 Q. But I'm sorry, correct me if I'm 4 misunderstanding your testimony, I thought 5 you said when you were working with Jeffrey, 6 that this document existed and it was 7 something you utilized?¶

8 A. I can't possibly tell you what 9 numbers were added or not added subsequent to 10 my departure.¶

11 Q. So you can't recall if you added 12 any of these numbers?¶

13 MR. PAGLIUCA: Objection to the 14 form and foundation, mischaracterizes 15 the witness' testimony.¶

16 17 18 Q. Are there any numbers on here or names that you recognize that you would have entered into this section?¶

19 20 21 into this so I would not be able to tell you. A. I already testified that I'm not responsible for inputting numbers and names¶

22 Q. Are there any names or numbers 23 under this section, Massage Florida, that you 24 would have provided to an assistant to input 25 into this document?¶

2 A. I can't possibly say.¶

3 Q. Do you see under Massage Florida, 4 about halfway down the first column, do you 5 see a number that says cell?¶

6 MR. PAGLIUCA: What page?¶

7 Q. It's 91, number 001663.¶

8 About halfway down, it says in the first 9 column, it says cell.¶

10 Do you see that?¶

11 A. I do.¶

12 Q. Would you have provided after, I 13 know you didn't hire her, Jeffrey hired her 14 but after you brought her to Jeffrey, would 15 you have given her cell phone number to an 16 assistant to input into this document?¶

17 MR. PAGLIUCA: Objection to form 18 and foundation.¶

19 A. I didn't bring her to Jeffrey, the 20 way you characterize and I would have no 21 knowledge of how this number ended up in this 22 book.¶

23 Q. I believe you, and I will try to 24 use your words so we are clear, you met 25 is that correct?¶

2 A. Yes.¶

3 Q. And then she began working for¶

4 Jeffrey?¶

5 A. Yes.¶

6 Q. Would you have provided whomever¶

7 was in charge of keeping this updated with¶

8 cell number so you would be able to¶

9 contact her if needed?¶

10 MR. PAGLIUCA: Objection to the¶

11 form and foundation.¶

12 A. I don't know. It could have been a¶

13 number of different ways, it it could have¶

14 been Jeffrey who gave it to somebody.¶

15 Q. You just don't remember doing that?¶

16 A. I do not.¶

17 Q. Now, as you look -- I want you to¶

18 take a look at the Florida massage list, it's¶

19 three columns there.¶

20 Do you, as you look at those names¶

21 on the various columns, do you know the ages¶

22 of any of the girls in this list?¶

23 A. I don't know. One, I don't know¶

24 who all the people are on this list and I¶

25 certainly don't know the ages.¶

2 Q. Do you know what their¶

3 qualifications are?¶

4 A. I don't know who the people are in¶

5 general so of course I don't know what their¶

6 qualifications are.¶

7 Q. Do you know why Jeffrey has so many¶

8 masseuses listed in Florida in his book here?¶

9 MR. PAGLIUCA: Objection to the¶

10 form and foundation.¶

11 A. Again, this book was created post¶

12 my departure, so I couldn't explain why all¶

13 these people were here.¶

14 Q. When you were there, you said this¶

15 book existed?¶

16 A. Yes.¶

17 Q. So when you were there, were there¶

18 a number of masseuses listed under the¶

19 Florida massage?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation and¶

22 mischaracterization of the witness'¶

23 testimony.¶

24 Q. I'm asking you a question.¶

25 When you were there, were there a¶

2 number of masseuses listed under the Florida¶

3 massage section?¶

4 A. When I was there, I would have, of¶

5 course there would have been some masseuses¶

6 listed but I could not tell you who or how¶

7 many and this -- I could not possibly because¶

8 I wouldn't remember.¶

9 Q. Do you know why Jeffrey would have¶

10 had so many names listed under his massage¶

11 Florida?¶

12 MR. PAGLIUCA: Objection to form¶

13 and foundation.¶

14 A. I can't testify to why Jeffrey has¶

15 so many.¶

16 Q. Did he use a different masseuse¶

17 every day?¶

18 MR. PAGLIUCA: Objection to the¶

19 form and foundation.¶

20 Q. You can answer.¶

21 A. When I was there he had a massage¶

22 roughly every day, one masseuse, and mostly¶

23 he would have them at random times, so it¶

24 would be difficult if you just only had one¶

25 person, man, woman, for an adult massage, to¶

2 come and be available for whatever time it¶

3 was. So he would have more than one person¶

4 that he could call for a massage because at¶

5 any given time the one that he called first¶

6 may not have been available.¶

7 Q. So would it typically be a¶

8 different person each day that would give him¶

9 a massage?¶

10 MR. PAGLIUCA: Objection to the¶

11 form and foundation.¶

12 A. It would be, when I was there,¶

13 based on availability.¶

14 Q. Would it surprise you to learn that¶

15 the Federal Government found that some of the¶

16 girls on this list under massage Florida were¶

17 under the age of 18?¶

18 MR. PAGLIUCA: Objection to the¶

19 form and foundation.¶

20 A. I can't testify to what the¶

21 government found or did not find because I¶

22 would have no knowledge of it.¶

23 Q. I'm asking if you would be¶

24 surprised by that?¶

25 MR. PAGLIUCA: Form and foundation.¶

2 A. I have knowledge of it. I can't 3 speculate.¶

4 Q. On the second column, towards the 5 bottom, there is the name, it's one up from 6 the bottom, there is the name 7 do you know¶

8 A. I do.¶

9 Q. Who is she?¶

10 A. She was a friend of Jeffrey's.¶

11 Q. Is she a masseuse?¶

12 A. She, I don't think she was a 13 masseuse, no.¶

14 Q. Why would be she listed under 15 Florida massages?¶

16 A. An input error.¶

17 Q. Is this list any individual that 18 would have sex with Jeffrey?¶

19 MR. PAGLIUCA: Objection to the 20 form and foundation.¶

21 A. I wouldn't have any knowledge of 22 that.¶

23 Q. Do you know if Jeffrey had sex with 24¶

25 MR. PAGLIUCA: Object to the form¶

2 and foundation.¶

3 A. First of all, I wouldn't have any¶

4 knowledge of that.¶

5 MS. McCAWLEY: We are going to take¶

6 a quick break.¶

7 THE VIDEOGRAPHER: It's now 4:39¶

8 and we are off the record.¶

9 (Recess.)¶

10 THE VIDEOGRAPHER: It's now 4:54¶

11 and we are as back on the record¶

12 starting disk number 8.¶

13 Q. Ms. Maxwell, we were talking¶

14 earlier about the journal and I believe you¶

15 said in 2004, 2005, you were no longer¶

16 working and responsible for that journal, is¶

17 that correct?¶

18 MR. PAGLIUCA: Objection to the¶

19 form and foundation.¶

20 A. What are we referring to, this¶

21 document right here?¶

22 Q. Yes.¶

23 A. I don't know who is the author of¶

24 this or I can't tell you what is in here¶

25 versus what would have been here when I was¶

2 around. I can't testify to that.¶

3 Q. Were you around in 2004, 2005?¶

4 A. I already testified that I was¶

5 there when Jeffrey's mother passed away and¶

6 so you know, I did visit for her passing and¶

7 I believe I was there for a couple of days in¶

8 2005.¶

9 Q. So if an employee of Mr. Epstein in¶

10 2004 said that you were the employee's direct¶

11 supervisor, would that be incorrect?¶

12 MR. PAGLIUCA: Objection to form¶

13 and foundation.¶

14 A. What employee, what's the¶

15 circumstances and what is the story, I don't¶

16 know what you are asking me.¶

17 Q. If said in 2004¶

18 when he was hired, you were his direct¶

19 supervisor, would that be true?¶

20 A. No.¶

21 Q. Were you in 2004 supervising¶

22¶

23 MR. PAGLIUCA: Objection to form¶

24 and foundation.¶

25 A. I never supervised¶

2 Q. Did take orders from 3 you?¶

4 MR. PAGLIUCA: Objection to the 5 form and foundation.¶

6 A. She worked for Jeffrey.¶

7 Q. If said you had 8 knowledge of underage girls coming to 9 Jeffrey's home for the purpose of sex, would 10 you contend that that is truthful?¶

11 MR. PAGLIUCA: Objection to the 12 form and foundation of the question.¶

13 A. I have no idea what you are talking 14 about, I'm sorry.¶

15 Q. If said that you 16 have knowledge of underage girls coming to 17 Jeffrey's home for the purpose of having 18 massages involving sex, would you say that 19 that statement is truthful?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. I can't testify to what 23 said or didn't say.¶

24 Q. I'm saying if said that you 25 had knowledge that there were girls coming¶

2 over to the house that were underage for the 3 purposes of sex, would that statement be 4 true?¶

5 MR. PAGLIUCA: Objection to form 6 and foundation.¶

7 A. I can't testify to what 8 said or didn't say or what he thought.¶

9 Q. Did you have knowledge of underage 10 girls coming to Jeffrey Epstein's house for 11 the purpose of sex?¶

12 A. No.¶

13 Q. Earlier I believe you testified, 14 correct me if I'm wrong, that the document 15 that is in front of you, the thicker document 16 was a stolen document.¶

17 Do you know who stole that 18 document?¶

19 A. I have read that stole the 20 document.¶

21 Q. And where have you read that?¶

22 A. I believe it was reported in the 23 press.¶

24 Q. Earlier we were talking about the 25 computers at Jeffrey Epstein's home. Did you¶

2 have a computer that was your computer¶

3 located in Jeffrey Epstein's home?¶

4 MR. PAGLIUCA: Objection to form¶

5 and foundation.¶

6 A. I've testified to the computer¶

7 already. Even when I was around, there was a¶

8 computer that people had access to.¶

9 Q. So is telling the¶

10 truth when he says that he downloaded that¶

11 book from your computer?¶

12 MR. PAGLIUCA: Objection to the¶

13 form and foundation.¶

14 A. I couldn't possibly tell you what¶

15 did or didn't do or said or didn't¶

16 say.¶

17 Q. Was it on your computer?¶

18 A. I already testified I have no idea¶

19 where this document came from.¶

20 Q. Did you have a list of names of¶

21 individuals with contact information for¶

22 Jeffrey Epstein on your personal computer?¶

23 A. Again, that wasn't my computer. I¶

24 already said that was a computer that lots of¶

25 people would have, so I have no recollection¶

2 of this document being on it, so I don't know 3 where this came from.¶

4 Q. I understand the computer at the 5 house that you're referencing. On a personal 6 computer of yours, did you have that 7 document?¶

8 A. I don't know where this document 9 came from, so I can't possibly say this 10 document was on any computer that I may have 11 had access to.¶

12 Q. On a personal computer of your own, 13 did you have lists of the phone numbers and 14 contact information relating to Jeffrey 15 Epstein?¶

16 A. Like everybody, I have an address 17 book but I can't possibly testify to where 18 this thing came from.¶

19 Q. Was it your address book or was it 20 addresses that related to Jeffrey Epstein?¶

21 MR. PAGLIUCA: Objection to the 22 form and foundation.¶

23 A. I don't know what you're asking me.¶

24 Q. On your personal computer, the 25 address book you are referencing, was it your¶

2 address book with individuals you knew or was 3 it an address book for your employer, Jeffrey 4 Epstein?¶

S A. Jeffrey has his situation and I 6 have no -- this is Jeffrey's, it came from 7 his home, so I can't testify to anything 8 about this in that period of time.¶

9 Q. So you didn't have on your computer 10 a list of contact information for individuals 11 that was related to Jeffrey Epstein?¶

12 A. I don't recall exactly what I had 13 back in 2004 and 2005, so I can't say what I 14 had back then that relates to his addresses, 15 I can't recall.¶

16 Q. So is it possible that someone 17 could have downloaded from your personal 18 computer a list of names and address that 19 were affiliated with Jeffrey Epstein?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. This didn't come from any computer 23 of mine.¶

24 Q. But is it possible that someone 25 could have downloaded a list of names and¶

2 addresses affiliated with Jeffrey Epstein 3 from your computer?¶

4 MR. PAGLIUCA: Objection to the 5 form and foundation.¶

6 A. I already said, I didn't have a 7 computer there, so I don't know where this 8 came from, I have no idea.¶

9 Q. I'm going to read to you some 10 testimony from deposition 11 and it's on page 370 and I want to ask you a 12 question about it, if it's true or false?¶

13 MR. PAGLIUCA: I'm going to object 14 unless you show the witness the 15 document.¶

16 MS. McCAWLEY: I will pass it. We 17 are not going to mark it. We will skip 18 it.¶

19 Q. Did you ever tell 20 that he better watch out and better keep his 21 mouth shut with respect to what occurred at 22 Mr. Epstein's home?¶

23 MR. PAGLIUCA: Objection to the 24 form and foundation.¶

25 A. It doesn't sound like anything I¶

2 would say.¶

3 Q. Did you ever threaten¶

4 in any way if he were to disclose¶

5 information he learned from his employment¶

6 with Jeffrey Epstein?¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. I'm happy to answer. No, I never¶

10 threatened him in any way.¶

11 Q. Were you concerned that he was¶

12 going to disclose that Jeffrey Epstein was¶

13 trafficking underage girls?¶

14 MR. PAGLIUCA: Objection to the¶

15 form and foundation.¶

16 A. First of all, there are so many¶

17 things wrong with that question, but I have¶

18 no knowledge of what you are talking about.¶

19 Q. Have you ever contacted or¶

20 instructed anyone to contact any witness in¶

21 this case for the purposes of threatening¶

22 them not to testify in this case?¶

23 MR. PAGLIUCA: Objection to the¶

24 form and foundation.¶

25 A. I have never called anybody with¶

2 reference to this case with any, anything you¶

3 just mentioned, I never threatened anyone.¶

4 Q. Have you ever directed anyone to¶

5 call any witnesses relevant to this case and¶

6 threaten them not to testify?¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. I never done such a thing.¶

10 Q. Did Jeffrey Epstein or you ever ask¶

11 any female, regardless of age, to carry¶

12 Jeffrey's baby for him?¶

13 MR. PAGLIUCA: Objection to the¶

14 form and foundation.¶

15 Q. Or anything along those lines?¶

16 MR. PAGLIUCA: Objection to the¶

17 form and foundation.¶

18 A. Can you repeat the question,¶

19 please?¶

20 Q. Did you or Jeffrey Epstein ever ask¶

21 any female, regardless of age, to carry¶

22 Jeffrey Epstein's baby for him?¶

23 MR. PAGLIUCA: Objection to the¶

24 form and foundation.¶

25 A. Are you asking --¶

2 Q. To become pregnant, did you or 3 Jeffrey Epstein ever ask any female to become 4 pregnant and carry Jeffrey Epstein's baby for 5 you or for Jeffrey?¶

6 MR. PAGLIUCA: Objection to form 7 and foundation.¶

8 A. You need to be very specific. I 9 have no idea what you are talking about. 10 That's completely rubbish.¶

11 Q. Did you or Jeffrey Epstein ask any 12 female to become pregnant and carry his baby 13 for either him or you?¶

14 MR. PAGLIUCA: Objection to the 15 form and foundation. Go ahead.¶

16 A. I can't testify to anything Jeffrey 17 did or didn't do when I am not present, but I 18 have never asked anybody to carry a baby for 19 me.¶

20 Q. Or anything along those lines?¶

21 MR. PAGLIUCA: Object to the form 22 and foundation.¶

23 Q. I want to make sure we are talking 24 about the same thing, not physically carry a 25 baby, I mean become pregnant with a baby?¶

2 MR. PAGLIUCA: Objection to the 3 form and foundation.¶

4 Q. I want to make sure we are clear.¶

5 A. I don't know what you are asking.¶

6 Q. That's why I want to make sure we 7 are clear.¶

8 A. We are clear. I never asked¶

9 anybody to carry a baby for me.¶

10 Q. Do you know if Jeffrey ever asked¶

11 anybody to carry a baby for him?¶

12 A. I'm not going to characterize any 13 conversation Jeffrey had with somebody else.¶

14 Q. You are not aware of that, is that 15 your testimony?¶

16 A. I am testifying I never have and I 17 will not testify for anything for Jeffrey.¶

18 Q. Did you ever hear Jeffrey ask 19 anybody to carry a baby for him?¶

20 A. I don't recollect conversation 21 about Jeffrey and babies in any form.¶

22 Q. Did Jeffrey ever tell he wanted to 23 have a baby?¶

24 A. I don't recollect baby 25 conversations with Jeffrey.¶

2 Q. So he never told you he wanted to 3 have a baby?¶

4 A. I don't recollect any baby 5 conversations with him saying he wanted to 6 have a baby.¶

7 Q. Did you ever bring any females to 8 the house that were not your friends' 9 children that were under the age of 18?¶

10 MR. PAGLIUCA: Objection to form 11 and foundation.¶

12 A. I have never, to my knowledge, 13 brought anybody under the age of 18 that's 14 not a friend of my family or my nieces or 15 nephews to the household.¶

16 Q. Earlier today you testified, I 17 believe, that with respect to your town home 18 Jeffrey paid for some of that and then gave 19 you a loan, is that correct?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. I said, actually I think it was a 23 loan, I believe it was a loan.¶

24 Q. The whole thing?¶

25 A. As best as I can recollect.¶

2 Q. Did you pay that loan back?¶

3 A. I don't have any outstanding loans 4 with him.¶

5 Q. So you paid it back?¶

6 A. I don't have any outstanding loans 7 with him.¶

8 Q. That's not an answer to my 9 question.¶

10 Did you pay back Jeffrey for the 11 loans?¶

12 A. I have paid back any loans I had 13 with him.¶

14 Q. You have or haven't?¶

15 A. Have.¶

16 Q. Were there any other gifts that 17 Jeffrey gave you during the time period of 18 say 1999 to the present that were in excess 19 of $50,000?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. What's the question again?¶

23 Q. Did Jeffrey give you any gifts in 24 excess of amounts of $50,000, I'm not talking 25 about a scarf here or something¶

2 insignificant, from 1999 to the present?¶

3 A. I can't recollect any gifts.¶

4 Q. Did he ever buy you a car?¶

5 A. I really don't recall, I can't¶

6 recall, it's a long time ago.¶

7 Q. You can't recall if Jeffrey Epstein¶

8 ever bought you a car?¶

9 A. I believe he did buy me a car, I¶

10 don't recall how much it cost. I don't¶

11 recall any of the financial details of that.¶

12 Q. Do you still have that car?¶

13 A. I don't.¶

14 Q. How long ago did you get rid of¶

15 that car?¶

16 A. I don't recall all the cars. Tho,¶

17 was a car back -- there was -- I don't¶

18 recall, I'm sorry.¶

19 Q. He supplied you with several cars?¶

20 MR. PAGLIUCA: Object to the form¶

21 and the mischaracterization of the¶

22 testimony.¶

23 A. I don't recall details of the cars.¶

24 Q. Did he supply with you more than¶

25 one car?¶

2 A. Over the course of time, I've¶

3 driven many cars.¶

4 Q. That Jeffrey provided to you?¶

5 A. They were cars that could be driven¶

6 and I just don't recall them.¶

7 Q. Were they in your name?¶

8 A. I don't recall.¶

9 Q. You don't recall if Jeffrey Epstein¶

10 ever put a car in your name?¶

11 A. We are talking a long time ago, I¶

12 really don't recall.¶

13 Q. When is the last time you had a car¶

14 from Jeffrey Epstein that you used?¶

15 A. 2000, 2001, 2002.¶

16 Q. Do you recall what kind of a car¶

17 that was?¶

18 A. I don't recall, I'm sorry.¶

19 Q. Did Jeffrey Epstein purchase¶

20 anything else for you besides the townhouse¶

21 and cars that would be over the amount of¶

22 $50,000?¶

23 A. I didn't say that he did, I said I¶

24 had a loan.¶

25 Q. Besides the loan, I'm sorry, you¶

2 are right, you did say you had a loan and you¶

3 said you paid that back, correct?¶

4 A. That's my testimony.¶

5 Q. Anything else in excess of $50,000¶

6 that he would have purchased for you?¶

7 A. We are talking 2002, 2001, I don't¶

8 recall any gifts really.¶

9 Q. When is the last time Jeffrey¶

10 Epstein gave you a gift in excess of $50,000?¶

11 MR. PAGLIUCA: Assumes facts not in¶

12 evidence. Form and foundation.¶

13 Q. You're saying you don't remember¶

14 from 2001 and 2002. I'm asking when is the¶

15 last time you remember Jeffrey Epstein¶

16 purchasing a gift for you?¶

17 A. I don't recall gifts in excess of¶

18 $50,000, I barely recall gifts, I barely¶

19 recall a lot of this -- I'm sorry, I don't¶

20 recall.¶

21 Q. Is Jeffrey Epstein paying for your¶

22 legal fees in this case?¶

23 A. No.¶

24 Q. Is he paying for anything related¶

25 to this case?¶

2 A. No.¶

3 4 Q. Are you aware of any grand theft police report relating to¶

5 6 A. I believe I've read a report in the press on that.¶

7 8 Q. Did you provide the press with a report on a grand theft by¶

9 10 A. I don't know how the press got that story.¶

11 12 Q. Do you know if committed a grand theft?¶

13 14 A. I only know what I read in the press.¶

15 16 17 Q. Did you ever state to the press that committed a grand theft?¶

18 19 A. I've never had any conversation directly with press.¶

20 21 22 Q. Did any of your representatives ever inform the press that committed a grand theft?¶

23 24 MR. PAGLIUCA: Objection to the form and foundation.¶

25 A. I have no way of knowing what my¶

2 representatives said to press or didn't.¶

3 Q. Did they ever discuss with you the¶

4 fact that they were going to report that¶

5 participated in a grand¶

6 theft?¶

7 A. I don't know how, first of all, I¶

8 don't know how I know that. I believe I read¶

9 it in a press report so...¶

10 Q. I'm going to mark this as composite¶

11 exhibit, Maxwell 14 please?¶

12 (Maxwell Exhibit 14, email, marked¶

13 for identification.)¶

14 Q. I'm going to direct you to page GM¶

15 00109. At the top of that page you are going¶

16 to see an email address from Jeffrey Epstein¶

17 on Sunday June 12, 2011 to¶

18¶

19 A. Yes.¶

20 Q. The re line says, This is the¶

21 actual version they wanted me to send which I¶

22 changed but this is back from my U.K.¶

23 lawyers.¶

24 Do you see that?¶

25 A. Yes.¶

2 3 4 5 6 7 8 9 Q. If you go down further, you're going to see halfway through the page, you will see your email address the and you will see a statement that says, Thank you. I have it now. I'm working on the letter a little. I will send final version tomorrow and whatever is in it will be factually accurate.¶

10 11 12 Beneath that you will see who I believe you identified earlier as one of your attorneys?¶

13 A. Uh-huh.¶

14 15 16 17 18 19 20 21 22 Q. And you will see a letter, starting the text of a letter starting, I want you to turn to the second page which is GM 00110. About halfway through the page, it says you will also presumably draw attention to the fact that prior to filing her suit against Mr. Epstein, fled the U.S. to avoid being arrested for grand theft. Police report available.¶

23 24 What grand theft were you referring to there that committed?¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 A. I don't know. However, I believe¶

4 she stole money from somewhere where she¶

5 worked.¶

6 Q. How do you know that was grand¶

7 theft?¶

8 A. I don't know how I know that.¶

9 Q. So you authorized a statement that¶

10 characterized that as grand theft without¶

11 knowing whether it was grand theft?¶

12 A. What month, what is the date of¶

13 this?¶

14 Q. The date of this is June 12, 2011?¶

15 A. So I'm afraid such a long time ago,¶

16 I'm not sure how, I really couldn't testify¶

17 as to how that language ended up in here.¶

18 Q. Do you have the police report? It¶

19 says police report available. Do you have¶

20 that document?¶

21 A. I don't have that document.¶

22 Q. Who does?¶

23 A. I have no idea.¶

24 Q. Would your lawyer¶

25 have that document?¶

2 A. I don't know who has this document.¶

3 Q. What's your basis in that statement 4 for saying fled the U.S.?¶

5 A. Again, you are asking me for a 6 statement that I made in 2011 and I can't say 7 what in 2011 exactly the basis of that 8 statement was.¶

9 Q. So you don't know whether or not 10 that statement is true?¶

11 A. This is in 2011 and it never went 12 out, so I'm not sure exactly.¶

13 Q. But you said in your email that you 14 were working to make it factually accurate, 15 is that correct?¶

16 A. That's what it says.¶

17 Q. I'm going to mark as Maxwell 15 a 18 document dated February 24, 2015?¶

19 (Maxwell Exhibit 15, email, marked 20 for identification.)¶

21 Q. This is an email from who 22 you've identified as your on¶

23 February 24, 2015 to which I understand 24 to be your email address and¶

25 The subject line says, VR cried rape. Prior¶

1 G Maxwell - Confidential 2 case dismissed as prosecutors found her not 3 credible. The message says, Ghislaine, some 4 helpful leakage, dot dot dot. What is it you 5 were leaking to the press?¶

6 MR. PAGLIUCA: Objection, there is 7 no foundation that she leaked anything 8 and you know that.¶

9 Q. What was it that you were leaking 10 to the press in that statement?¶

11 A. Again, I don't think that's 12 referring to that, that's just referring to 13 the press getting hold of whatever story it 14 is.¶

15 Q. What was leaking to the 16 press?¶

17 MR. PAGLIUCA: Objection to form 18 and foundation.¶

19 A. It doesn't say was leaking 20 anything. It doesn't say that.¶

21 Q. The statement says, helpful 22 leakage, is that correct?¶

23 A. It says helpful leakage. That 24 doesn't mean he leaked anything.¶

25 Q. Did you leak to the press¶

2 information to the press information about¶

3 the subject line, VR cried rape, prior case¶

4 dismissed as prosecutors found her not¶

5 credible?¶

6 A. I don't no idea what is¶

7 referring to. I think he is referring to the¶

8 press held the story. I couldn't testify to¶

9 that.¶

10 Q. Did you leak to the press¶

11 information regarding the statement, VR cried¶

12 rape prior case dismissed as prosecutors¶

13 found her not credible, either through you or¶

14 through¶

15 A. I think this is coming from the¶

16 daily mail.¶

17 Q. That is not my question, I'm asking¶

18 whether you or leaked that?¶

19 A. I have no knowledge, I have no¶

20 idea, I'm sorry. I can't -- I have no¶

21 recollection. I have no idea what she is¶

22 talking about.¶

23 Q. I'm going to mark this as 16?¶

24 (Maxwell Exhibit 16 email marked¶

25 for identification.)¶

2 Q. This is an email addressed at the 3 top from Jeffrey Epstein on Monday, January 4 12, 2015 to which I understand to be 5 your email address. The email reads, You can 6 issue a reward to any of Virginia's friends, 7 aquaints, family, that come forward to help 8 prove her allegations are false. The 9 strongest is the dinner and the new 10 version of the Virgin Islands that¶

11 practiced in an underage orgy.¶

12 Did you offer any rewards to 13 Virginia's family or friends to contradict 14 Virginia's story?¶

15 A. Absolutely not.¶

16 Q. Did Jeffrey Epstein offer any 17 rewards to any of Virginia's, as he suggests 18 here, friends, family or acquaintances to 19 contradict Virginia's story?¶

20 MR. PAGLIUCA: Objection to the 21 form and foundation.¶

22 A. I have no idea what he did.¶

23 Q. Did he tell he was going to offer 24 rewards to Virginia's acquaintances, friends 25 and family to prove her allegations were¶

2 false?¶

3 A. He did not.¶

4 Q. Do you know whether Jeffrey Epstein 5 paid to give testimony about 6¶

7 A. I don't know who is.¶

8 9 Q. So you don't Epstein paid her? know whether Jeffrey¶

10 A. I don't know who is.¶

11 12 13 Q. Have you ever contacted any of Virginia's friends, acquaintances or family regarding this case?¶

14 15 16 17 A. I don't know who Virginia's friends or family are and I have not contacted anybody related to her in any way, shape or form.¶

18 19 20 21 22 23 24 Q. I will turn you, I believe it's the thicker document which is Maxwell, I believe it was 14, right there, the compilation document to GM, at the bottom, GM 00071. You actually may want to turn to the prior page 70 so you can see the email chain. At the top of the page --¶

25 MR. PAGLIUCA: I don't have a 00071¶

2 on mine.¶

3 MS. McCAWLEY: It's the second page¶

4 in that document.¶

5 MR. PAGLIUCA: Okay.¶

6 Q. It's dated Friday March 11, 2011 7 from Maxwell to Jeffrey with the title, Daily 8 Mail and there is a forward from to 9 you and a number of other individuals, that's 10 on the cover page and as you scroll to the 11 second page, you are going to see that part 12 of the chain that I'm asking about and that 13 is the chain at the bottom which is dated 14 3/10/2011 from and it says we 15 think -- we should think about the letter to 16 the editor. School can be university. Age 17 of consent in Florida is complex. See below, 18 if you are 16 years old, a sexual 19 relationship with someone between 18 and 24 20 is legal in Florida. Two persons between 16 21 and 24, Florida statute 794.05. A person 24 22 years or of age or older who engages in 23 sexual activity with a person 16 or 17 years 24 of age commits a felony in the second degree. 25 So as soon as you turn 16 you are able to¶

2 have sexual relations and you can have sexual 3 relations with a minor under the age of 18 4 until your 24th birthday.¶

5 Why were you concerned with the age 6 of consent in Florida?¶

7 MR. PAGLIUCA: Objection to the 8 form and foundation of the question.¶

9 A. I wasn't concerned. I think this 10 was somebody sending me the statute for 11 informational purposes.¶

12 Q. Who is¶

13 A. He is the person who, 14 boss I believe, I don't know what the 15 relationship is.¶

16 Q. I didn't hear you?¶

17 A. I I'm not 18 sure exactly.¶

19 Q. Why would he be sending you 20 information addressing concerns about the age 21 of consent in Florida?¶

22 MR. PAGLIUCA: Objection to the 23 form and foundation.¶

24 A. I think he was just trying to be 25 telling me details that would happen,¶

2 Virginia in '11 was claiming she was 15 and¶

3 we thought she was 17. I didn't know what¶

4 the statutes were in Florida and I think he¶

5 was just trying to be helpful so I would¶

6 know.¶

7 Q. Did you have a concern that you had¶

8 violated this statute in Florida?¶

9 MR. PAGLIUCA: Objection to the¶

10 form and foundation.¶

11 A. No.¶

12 Q. Did you have a concern that Jeffrey¶

13 Epstein had violated this statute in Florida?¶

14 A. I'm not concerned what happened¶

15 with Jeffrey. I'm only concerned what¶

16 happens with me.¶

17 Q. Why did you communicate with¶

18 about the sexual consent age in¶

19 Florida?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation. It misstates her¶

22 testimony.¶

23 A. I wasn't concerned. I think he was¶

24 being helpful and stating what the statute¶

25 was.¶

2 Q. I'm going to turn you now in that 3 same stack the number GM 00088. At the 4 top of the email you are going to see Jeffrey 5 Epstein, dated June 8, 2011, to you and it's 6 got a re line, Vanity Fair. If you go down 7 the chain you will see where it says under 8 your email, Do you have a problem with 9 anything I said.¶

10 Were you communicating with Jeffrey 11 to confirm what statements you could put in 12 any press releases you were given?¶

13 MR. PAGLIUCA: Objection to the 14 form and foundation.¶

15 A. Any interest I have is in accuracy.¶

16 Q. Were you confirming with Jeffrey 17 Epstein what information you could put in 18 press releases?¶

19 MR. PAGLIUCA: Objection to the 20 form and foundation.¶

21 A. Again, I'm only looking for 22 accuracy.¶

23 Q. Why would you ask him if he had a 24 problem with anything you were saying?¶

25 A. If there is anything I¶

2 characterized that was not correct.¶

3 Q. That's not what you said. You¶

4 said, do you have a problem with anything I¶

5 said.¶

6 MR. PAGLIUCA: Objection to the¶

7 form and foundation. There is no¶

8 question pending.¶

9 MS. McCAWLEY: There is.¶

10 MR. PAGLIUCA: That's not a¶

11 question, it's a statement.¶

12 MS. McCAWLEY: Don't interrupt me.¶

13 Q. Di you say, do you have a problem¶

14 with anything I said?¶

15 A. That was asking in my parlance that¶

16 I wanted him to check it for accuracy.¶

17 Q. Did he tell you there was anything¶

18 inaccurate about the statement?¶

19 A. Again, I have to read the whole¶

20 thing to figure that out.¶

21 Q. Were you coordinating with Jeffrey¶

22 Epstein during this time period in 2011¶

23 regarding statements that you were issuing to¶

24 the press?¶

25 MR. PAGLIUCA: Did you withdraw the¶

2 last question.¶

3 MS. McCAWLEY: I'm not withdrawing¶

4 anything. I'm asking a question.¶

5 MR. PAGLIUCA: There was a question¶

6 pending. You didn't let the witness¶

7 answer the question, then you moved on¶

8 to another question so I'm asking for¶

9 clarification for the record now which¶

10 question are we answering.¶

11 MS. McCAWLEY: There is an answer.¶

12 The question was did he tell you¶

13 anything, there was anything in the¶

14 statement inaccurate about the statement¶

15 and she said again, I read the whole¶

16 thing --¶

17 THE WITNESS: I would have to.¶

18 MS. McCAWLELY: I would have to¶

19 read the whole thing to figure that out.¶

20 MR. PAGLIUCA: Then she started¶

21 reading it and you asked another¶

22 question.¶

23 MS. McCAWLEY: That's the question.¶

24 MR. PAGLIUCA: I'm wondering if its¶

25 still pending.¶

2 MS. McCAWLEY: It was answered.¶

3 Q. Were you coordinating with Jeffrey¶

4 Epstein during the time period in 2011¶

5 regarding the statements you were issuing to 6 the press?¶

7 MR. PAGLIUCA: Objection to the¶

8 form and foundation.¶

9 A. I only wanted to be accurate in any 10 factual statements that I made.¶

11 Q. You knew at that time that Jeffrey¶

12 Epstein had been convicted for sexual abuse 13 of a minor, is that correct?¶

14 MR. PAGLIUCA: Objection to form 15 and foundation.¶

16 A. He was sentenced I believe for 17 underage -- soliciting an underaged 18 prostitute.¶

19 Q. You knew that he was a registered 20 sex offender?¶

21 A. Yes.¶

22 Q. You were coordinating with him the 23 statement that you were going to be making to 24 the press to confirm whether they were 25 accurate in your words?¶

2 MR. PAGLIUCA: Objection to the¶

3 form and foundation.¶

4 A. I was not coordinating with¶

5 Jeffrey. He had details that I did not have.¶

6 I was not party to his case. I needed to¶

7 have information in order to be able to¶

8 respond so I was not coordinating with him.¶

9 I was merely asking for details that I could 10 have.¶

11 Q. Did Jeffrey write any of your press 12 statements for you?¶

13 A. No.¶

14 Q. He didn't draft any of them?¶

15 A. I have a lawyer who was working on 16 this and that was -- I asked, I believe as I 17 recollect asked him for information to make 18 sure I was being accurate in the 19 representations for whatever I was 20 discussing.¶

21 Q. Did Jeffrey provide you with any 22 drafts of statements to provide to the press?¶

23 A. I only recall drafts from my 24 lawyer.¶

25 Q. I will mark this as Maxwell 17.¶

1 G Maxwell - Confidential¶

2 (Maxwell Exhibit 17, email, marked 3 for identification.)¶

4 Q. This is an email from you on¶

5 January 10, 2015 to¶

6 The statement you had before you 7 earlier, that, if you can pull that in front 8 of you, the one page press release that you 9 gave. You might know from memory.¶

10 Was the press release that you 11 issued with the statement about Virginia 12 issued in or around January 2, 2015?¶

13 A. As best as I can recollect.¶

14 Q. I want to turn your attention to 15 the document I just handed you which is 16 No. 001044, from you to¶

17 It says in the first sentence, I'm 18 out of my depth to understand defamation, 19 other legal hazards and I don't want to end 20 up in a lawsuit aimed at me from anyone, if I 21 can help it. Apparently, even saying 22 Virginia is a liar has hazards.¶

23 You knew at the time you called 24 Virginia a liar in early January of 2015 that 25 that was something that would result in a¶

2 lawsuit, is that correct?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 A. I have legal advice that I took.¶

6 Q. But you knew in early January by¶

7 making a statement calling Virginia a liar¶

8 that you were subjecting yourself to a legal¶

9 dispute with her?¶

10 MR. PAGLIUCA: Objection to the¶

11 form and foundation.¶

12 A. I took legal advice as to what¶

13 should be said and not be said and the legal¶

14 advice that came from the United Kingdom¶

15 was --¶

16 MR. PAGLIUCA: You are not allowed¶

17 to talk about any legal advice that you¶

18 got from anybody that's a lawyer.¶

19 A. Sorry.¶

20 Q. So is it correct without telling me¶

21 what you talked to your lawyers about that¶

22 you knew because this is dated January 10¶

23 that when you made this statement in early¶

24 January, January 2 of 2015 you knew that¶

25 calling Virginia a liar would subject you to¶

2 a legal action, isn't that correct?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation. As to what you¶

5 knew -- whatever she knows would be¶

6 privileged.¶

7 MS. McCAWLEY: I'm asking if she¶

8 knows. I'm not asking her to tell me¶

9 about her privileged communications.¶

10 A. All I can say is I asked a question¶

11 and received legal advice.¶

12 (Maxwell Exhibit 18, email, marked¶

13 for identification.)¶

14 Q. This is an email dated January 15,¶

15 2015 from Jeffrey Epstein to you?¶

16 A. Uh-huh.¶

17 Q. It states in the first line, do you¶

18 want to come out and say she was the¶

19 girlfriend during the time?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation of the question and¶

22 actually the word is, there¶

23 is no vowel in there.¶

24 MS. McCAWLEY: I was just trying to¶

25 pronounce it.¶

2 Q. This email reads do you want¶

3 without a vowel, to come out and say¶

4 she was the girlfriend during the time.¶

5 Who was Jeffrey Epstein referring¶

6 to?¶

7 A. I believe he was referring to¶

8¶

9 Q. Why was he asking you if you wanted¶

10 to come out and say she was the 11 girlfriend?¶

12 MR. PAGLIUCA: Objection to the¶

13 form and foundation.¶

14 A. The way the press and you were 15 characterizing me is I was with Jeffrey 16 throughout this entire period of time and I 17 was not.¶

18 Q. Was with Jeffrey during this 19 period of time?¶

20 A. I believe she was.¶

21 Q. Did Jeffrey come out and tell the 22 press it was and not you that was with 23 him as he is proposing here?¶

24 A. I don't believe he did.¶

25 Q. Did you want him to do that?¶

2 A. No, I didn't ask him to do¶

3 anything. No.¶

4 Q. So do you know in January of 2015,¶

5 was his girlfriend?¶

6 A. 2015, I have no idea who was his¶

7 girlfriend in 2015.¶

8 Q. I'm sorry, you are correct.¶

9 In the period of 1999 to 2002, was 10 his girlfriend?¶

11 A. They spent a lot of time together.¶

12 Q. Did you talk to about going 13 to the press and saying that she was the 14 girlfriend and not you?¶

15 A. I have never spoken to¶

16 Q. Was offered any money to 17 make a statement that she was the girlfriend?¶

18 MR. PAGLIUCA: Objection to the 19 form and foundation.¶

20 A. I have no idea. I have never 21 spoken to and I don't know anything 22 I have no idea.¶

23 (Maxwell Exhibit 19, email, marked 24 for identification.)¶

25 Q. That's an email from Jeffrey to¶

2 Maxwell dated January 25, 2015.¶

3 A. Uh-huh.¶

4 Q. I will direct your attention to the 5 bottom email which is from you on Saturday 6 January 24, 2015. It says, I would 7 appreciate it if would come out and 8 say she was your girlfriend. I think she was 9 from the end of '99 to 2002.¶

10 Does that refresh your recollection 11 that you asked Jeffrey to have come 12 out and say she was his girlfriend?¶

13 A. I'm sure I would loved anybody to 14 come out and say they were with Jeffrey 15 rather than me.¶

16 Q. Was that an accurate statement you 17 were asking to be made to the press?¶

18 MR. PAGLIUCA: Objection to the 19 form and foundation.¶

20 A. When is this?¶

21 Q. 2015. The statement is whether she 22 was the girlfriend from '99 to 2002. As the 23 email reads.¶

24 A. What is your question?¶

25 Q. My question is, was that an¶

2 accurate statement you were going to be¶

3 giving to the press?¶

4 A. I didn't make the statement and¶

5 never came out, so it's completely¶

6 moot.¶

7 Q. My question is, was it an accurate¶

8 statement that was the girlfriend from¶

9 '99 to 2002 or were you just making that up¶

10 for purposes of deflecting press from you?¶

11 MR. PAGLIUCA: Objection to the¶

12 form and foundation.¶

13 A. As I said they spent a lot of time¶

14 together and...¶

15 Q. Were you also his girlfriend from¶

16 '99 to 2002?¶

17 A. I don't if I would have ever¶

18 characterized myself as his girlfriend, but¶

19 at that time, was with him as much if¶

20 not more than I was.¶

21 Q. I will mark this as Maxwell 20?¶

22 (Maxwell Exhibit 20, email, marked¶

23 for identification.)¶

24 Q. This is an email at the top, it's¶

25 labled 001060. At the top is a chain¶

2 from Jeffrey to you on January 11, 2015 and 3 if you look below, I'm going to start at the 4 bottom of that chain which is January 11 at 5 9:15 from Jeffrey and he wrote, do you 6 have an article coming out in Monday's paper. 7 If so, could you please forward us a copy.¶

8 Do you know what Jeffrey was 9 referring to there?¶

10 A. I don't know.¶

11 Q. If you look up in the email chain 12 do you see an email address from 13 responding to that letter?¶

14 A. I do.¶

15 Q. So that would be 16 that Jeffrey was emailing at that time 17 according to this chain, correct?¶

18 A. It certainly looks like it.¶

19 Q. The email from to Jeffrey is, 20 21 22 23 24 Nothing on Monday. I'm working on several possible articles about unfairness in the legal process that allows false charges to be inserted into legal documents with no opportunity to respond.¶

25 And do you see above that Jeffrey's¶

2 email to you says, quote, Careful.¶

3 A. Is that to me or to¶

4 Q. Jeffrey to at the top. Why¶

5 was Jeffrey telling you to be careful?¶

6 MR. PAGLIUCA: Objection to the¶

7 form and foundation.¶

8 A. I have no idea.¶

9 Q. What was he concerned about with¶

10 suggestion in the email¶

11 below?¶

12 MR. PAGLIUCA: Objection to form¶

13 and foundation.¶

14 A. I can't possibly know.¶

15 Q. Did you discuss with him why he¶

16 told you to be careful?¶

17 A. I had limited contact with him. i¶

18 don't recall where this goes in the chain,¶

19 why he was telling me to be careful, I have¶

20 no idea.¶

21 Q. Did you respond to this email?¶

22 A. If you don't have it, I didn't¶

23 respond.¶

24 Q. Did you ever delete emails during¶

25 the period of January of 2015?¶

2 A. I have every email that you asked 3 for in discovery, that I have I gave you.¶

4 Q. That's not my question.¶

5 Did you ever delete emails in 6 January of 2015?¶

7 A. I have not deleted anything that 8 you have asked me for in discovery. I have 9 given you everything that I have.¶

10 Q. That is not my question, my 11 question is, did you ever delete emails in 12 January of 2015?¶

13 A. In the normal course of my work, 14 there are emails from that I delete. 15 That is the type of email I've deleted. 16 Anything that is material to what you want, I 17 have not deleted.¶

18 Q. How do you know that?¶

19 A. Well, anybody that's to do with 20 Jeffrey or or women or anything of which 21 I know you were interested in, of which I 22 have anything I would not have done because I 23 don't want to subject myself to...¶

24 Q. Have you had your computer 25 forensically copied for purposes of this¶

2 litigation?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 A. Has someone made a copy of your¶

6 computer for purposes of this litigation.¶

7 A. No.¶

8 Q. Are you a citizen of the United¶

9 States?¶

10 A. I am.¶

11 Q. Are you also a citizen of England?¶

12 A. I am.¶

13 Q. Are you a citizen of any other¶

14 land?¶

15 A. TerraMar.¶

16 Q. That's the name of your charity¶

17 project that deals with oceans, is that¶

18 correct?¶

19 A. Yeah. I'm as well.¶

20 Q. Has Jeffrey Epstein funded TerraMar¶

21 for you?¶

22 A. He did give some money to TerraMar,¶

23 yes.¶

24 Q. How much?¶

25 A. I believe it was $50,000.¶

2 Q. Earlier today, you said you were in 3 the process of resolving the sale of your 4 town home. Where do you intend to live once 5 your town home is sold?¶

6 A. That's a good question. I don't 7 have an answer for you yet.¶

8 Q. You don't have a present plan. Do 9 you intend to live in the United States?¶

10 A. I don't have a present plan.¶

11 Q. Are you living outside of your town 12 home right now or are you still there?¶

13 A. I'm just surfing.¶

14 Q. Has Jeffrey Epstein ever purchased 15 a company for you or put a company in your 16 name?¶

17 MR. PAGLIUCA: Objection to the 18 form and foundation.¶

19 A. I have no recollection.¶

20 Q. Is there a Ghislaine Maxwell 21 corporation, for example?¶

22 A. No, not that I am aware of that has 23 anything to do with me. There may be with 24 one that someone else owns or started but not 25 one that is related to me.¶

2 MS. McCAWLEY: I'm going to take a 3 short break and make sure to keep it 4 short because I know you wanted to -- I 5 just want to wrap up what we have left.¶

6 THE VIDEOGRAPHER: It's now 5:49 we 7 are off the record.¶

8 (Recess.)¶

9 THE VIDEOGRAPHER: It's now 6:00 10 p.m. and we are back on the record.¶

11 Q. Ms. Maxwell, do you recall being 12 subpoenaed for a deposition back in 2009?¶

13 A. I do.¶

14 Q. Why did you avoid giving your 15 deposition in that case when you were 16 subpoenaed and had the opportunity to tell 17 your side of the story?¶

18 MR. PAGLIUCA: Objection to the 19 form and foundation.¶

20 A. That's not what happened.¶

21 Q. What happened?¶

22 A. As I best recall, I was subpoenaed 23 and a date was set for the subpoena and 24 everything was set and I believe it was with 25 Brad, correct me if I'm wrong, and¶

7 A. Correct.¶

8 Q. Did you give any statement that¶

9 your mother was ill and, therefore, you¶

10 couldn't take your deposition and had to¶

11 leave the country indefinitely?¶

12 A. That's an entirely separate¶

13 situation. Brad was involved in the¶

14 , I¶

15 believe, you know, is when fake suits were¶

'6 created in Jeffrey's case and¶

18 for that firm.¶

19 Q. And Mr. worked for that¶

20 firm?¶

21 A. So when the subpoena came, Brad¶

22 was involved with in the¶

23 case so when I was called for subpoena, then¶

24 and I had a subpoena, date and time set, Brad¶

25 went AWAL, meaning he failed to¶

1 G Maxwell - Confidential¶

2 Brad failed to show up for the¶

3 subpoena.¶

4 Q. So your testimony is Brad¶

5 did not show up for the deposition that had¶

6 been set?¶

and Brad worked¶

2 respond to calls and failed to get in touch¶

3 with my attorneys, even though a date and¶

4 time was set for the subpoena and so that's¶

5 what happened to that subpoena. It just¶

6 didn't happen.¶

7 Q. We may be talking about two¶

8 different cases so I will ask the question¶

9 again.¶

10 Was there ever a time where you¶

11 were subpoenaed to sit for a deposition that¶

12 you could not make it because you said that¶

13 your mother was ill?¶

14 A. So that is the same subpoena that¶

15 Brad failed to turn up for and then I¶

16 think five or six months passed between --¶

17 period of time, I can't characterize it¶

18 exactly, a period of time passed where then¶

19 he resurfaced and asked for a new subpoena to¶

20 be -- a new time to be set and because he had¶

21 contacted the press and done all sorts of¶

22 things that you guys are familiar with, I¶

23 believe, it was my lawyer suggested that I¶

24 should have some sort of protective order and¶

25 I believe between the time for when Brad¶

resurfaced after the¶

I for¶

4 creating fake cases in Jeffrey's and other¶

5 people's cases, in between the time when¶

6 there were -- trying to figure out the¶

7 protective situation for me, my mother was¶

8 sick, she is 89, she was 89 at that time so I¶

9 -- they -- we can all -- we all have parents,¶

10 so anyone, I don't know how old your parents¶

11 are but any parent or godparent, any¶

12 individual who is in the late 80s 90s, we can¶

13 understand has health issues so my mother's¶

14 health was deteriorating very rapidly at that¶

15 time and we had issues at home with who she¶

16 would talk to and how to manage her, her¶

17 healthcare situation and so I went home.¶

18 They were still arguing about the protective¶

19 order --¶

20 Q. Is it your testimony that there was¶

21 not a date set for your deposition at the¶

22 time you left to go see your mother?¶

23 A. I don't believe so.¶

24 Q. Are you friends with the¶

25 A. I am.¶

2 Q. Did you attend a wedding of¶

3 a few weeks after the date was set,¶

4 let's say a few weeks after you left to go¶

5 see your mother who was ill?¶

6 A. I don't recall exactly when I left¶

7 but it was before, a few weeks before¶

8 don't remember the exact timing of that, so¶

9 I'm sorry, can you repeat the question?¶

10 Q. Did you come back to the United¶

11 States to attend wedding?¶

12 A. I attended¶

13 wedding but I don't know if I came back¶

14 specifically for that or not.¶

15 Q. When we were looking at the flight¶

16 logs earlier, there was a flight where you¶

17 ended up in, I believe it was¶

18 in do you know how you got clearance¶

19 to land at that¶

20 A. I need to have a look at whatever¶

21 document.¶

22 Q. It's one of the flight logs, it was¶

23 on the flight with when we were¶

24 talking about you landed at¶

25 know you are a pilot, do you know what you¶

2 had to do to get clearance to land at that¶

3 naval base.¶

4 MR. PAGLIUCA: If you need to look¶

5 at something to answer the question, you¶

6 can. If you can't answer the question¶

7 without looking at something just¶

8 indicate such.¶

9 A. Regardless, I wouldn't have any¶

10 knowledge of that.¶

11 Q. Was traveling with you¶

12 on the flights you were on with¶

13 A. I would have to look at a document.¶

14 I wouldn't know if she was on all of them or¶

15 not. I don't know.¶

16 Q. Do you recall her being on any of¶

17 them?¶

18 A. To the best of my recollection, I¶

19 think she was. I don't recollect exactly¶

20 what flight she was on or not.¶

21 Q. was one of the¶

22 co-conspirators, physically, in the¶

23 nonconstitution agreement, is that correct?¶

24 MR. PAGLIUCA: Objection to the¶

25 form and foundation.¶

2 3 A. I have never seen the document but my understanding, I believe, is that she was.¶

4 5 6 Q. Did you ever stay the night ever at house have you ever stayed the night there?¶

7 A. In his home¶

8 Q. Yes.¶

9 A. I don't believe I did.¶

10 11 12 Q. Are you aware of anybody providing Jeffrey with two 12 year old girls as a birthday present?¶

13 14 MR. PAGLIUCA: Objection to the form and foundation.¶

15 A. No.¶

16 17 18 Q. Are you aware of anybody ever providing Jeffrey with girls under the age of 18 as a birthday present?¶

19 20 MR. PAGLIUCA: Objection to the form and foundation.¶

21 A. No.¶

22 23 24 Q. Do you know whether provided girls under the age of 18 to Jeffrey for the purposes of sex?¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 A. I am un -- the answer is no, I¶

4 don't know anything about that.¶

5 Q. Did you ever witness¶

6 bringing girls under the age of 18 to¶

7 any of Jeffrey residences?¶

8 MR. PAGLIUCA: Objection to the¶

9 form and foundation.¶

10 A. I don't recollect coming¶

11 to the house with girls, period.¶

12 Q. Do you, when I say house, I'm¶

13 including the U.S. Virgin Island home.¶

14 Do you recollect¶

15 bringing foreign girls under the age of 18 to¶

16 the U.S. Virgin Island house?¶

17 A. I don't recollect anything like¶

18 that.¶

19 Q. Do you know how Jeffrey Epstein¶

20 made his money?¶

21 A. No.¶

22 Q. Was on'¶

23 of his clients?¶

24 A. I have no idea.¶

25 Q. What do you know about the¶

2 relationship between Jeffrey Epstein and¶

3¶

4 A. Are you talking today?¶

5 Q. Yes, today.¶

6 A. I have no idea.¶

7 Q. Do they have a business¶

8 relationship?¶

9 A. I have no idea.¶

10 Q. Did they have a business¶

11 relationship during the time that you were¶

12 working for Jeffrey Epstein?¶

13 A. I believe in the '90s when I was¶

14 there they had a business relationship.¶

15 Q. Did they have any other kind of¶

16 relationship?¶

17 MR. PAGLIUCA: Objection to form¶

18 and foundation.¶

19 A. The only relationship I am aware of¶

20 is the business relationship.¶

21 Q. Do you know why sold the¶

22 New York house or gave the New York house to¶

23 Jeffrey, if you know?¶

24 MR. PAGLIUCA: Objection to the¶

25 form and foundation.¶

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?¶

8 MR. PAGLIUCA: Objection to the¶

9 form and foundation.¶

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 can take a moment to take a look at it, is¶

3 that a statement that Jeffrey Epstein wrote¶

4 for you to be issued to the press?¶

5 MR. PAGLIUCA: Objection to the¶

6 form and foundation.¶

7 A. The question was?¶

8 Q. Is this a statement that Jeffrey¶

9 Epstein wrote for you to be issued to the¶

10 press?¶

11 MR. PAGLIUCA: Same objection.¶

12 A. Is there any other emails that you¶

13 have that surround this that would allow me¶

14 to know what -- does this have a context?¶

15 Q. These were produced by your counsel¶

16 so the to extent there are emails that¶

17 surround this, this is what we were given.¶

18 A. Okay. I don't know whether he¶

19 wrote this -- obviously he wrote this and¶

20 sent this to me. I don't know if this is¶

21 post a phone call we had, I can't recollect¶

22 exactly.¶

23 Q. Do you know if this was issued to¶

24 the press, this statement?¶

25 A. The only press statement that was¶

2 issued is the one that you have.¶

3 Q. When the paragraph refers to you¶

4 being in a very long term committed¶

5 relationship with another man, who was that¶

6 other man?¶

7 MR. PAGLIUCA: You don't have to¶

8 answer the question.¶

9 MS. McCAWLEY: I'm asking the¶

10 identity of a witness in a statement she¶

11 is giving.¶

12 MR. PAGLIUCA: She didn't give the¶

13 statement.¶

14 MS. McCAWLEY: Jeffrey is writing¶

15 to her, I'm asking who is he is¶

16 referencing to a long term relationship.¶

17 You are going to refuse to let her¶

18 answer that question.¶

19 MR. PAGLIUCA: Yes.¶

20 MS. McCAWLEY: I would like to¶

21 state for the record he is refusing to¶

22 allow her to identify a potential¶

23 witness in this litigation. So we will¶

24 be back to get the answer to that¶

25 question.¶

2 Q. Do you recall when you were 3 traveling with that you 4 would be responsible for holding her 5 passport?¶

6 MR. PAGLIUCA: Objection to the 7 form and foundation.¶

8 A. I already testified I don't recall 9 traveling with Virginia.¶

10 Q. Do you recall whether Jeffrey 11 Epstein when he was traveling with a minor, 12 someone under the age of 18, someone would 13 hold their passport?¶

14 MR. PAGLIUCA: Object to the form.¶

15 A. I couldn't testify to what Jeffrey 16 did or didn't do.¶

17 Q. You never observed him gathering a 18 minor's passport and holding it during one of 19 the trips you were on?¶

20 A. I don't have a recollection of 21 that.¶

22 Q. Are you familiar with a company 23 called Hyperion Air Inc.?¶

24 A. I am.¶

25 Q. Is that a company you are¶

2 affiliated with?¶

3 A. No.¶

4 Q. Is that a company that Jeffrey¶

5 owns?¶

6 A. I knew it back in 2001, back when I¶

7 was working. I have no idea what that is¶

8 today.¶

9 Q. What about JEGE, are you familiar¶

10 with that company, JEGE Inc.?¶

11 A. I don't recall it.¶

12 Q. You don't recall?¶

13 A. It vaguely rings a bell. I don't¶

14 remember what it relates to.¶

15 Q. What about J Epstein Virgin Islands¶

16 Foundation, Inc.¶

17 Are you familiar with that company?¶

18 A. No.¶

19 Q. How did J Epstein & Company, Inc.?¶

20 A. Again, I don't recall his business¶

21 names and affiliations.¶

22 Q. How about NES LLC, are you familiar¶

23 with that name?¶

24 A. Again, I think that was one of his¶

25 businesses, but I don't recall.¶

2 Q. Do you know what that business did?¶

3 A. I don't.¶

4 5 Inc.? Q. How about New York Strategy Group¶

6 A. I don't know.¶

7 Q. What about Ghislaine Maxwell¶

8 Company, are you familiar with that company?¶

9 A. I never heard of that.¶

10 11 12 Q. Is that a company you are on record as being either a board member of or having a position of authority in?¶

13 14 MR. PAGLIUCA: Objection to the form and foundation.¶

15 A. I've never heard of the business.¶

16 17 18 19 Q. What negative, unflattering, private or potentially embarrassing information does Jeffrey Epstein know about you?¶

20 21 form MR. PAGLIUCA: Objection to the and foundation.¶

22 A. I imagine none.¶

23 24 25 Q. knowledge conducted? Does he know, does he have any of any illegal activity that you've¶

2 MR. PAGLIUCA: Object to the form 3 and foundation.¶

4 A. If you want to ask Jeffrey 5 questions about me, you would have to ask 6 him.¶

7 Q. Have you ever been involved in any 8 illegal activity in your lifetime?¶

9 MR. PAGLIUCA: Objection to the 10 form and foundation.¶

11 A. I can't think of anything I have 12 done that is illegal.¶

13 Q. Have you ever been arrested?¶

14 A. I have a DUI in the U.K. a long 15 time ago.¶

16 Q. Is that the only arrest you have on 17 your record?¶

18 A. Yes.¶

19 Q. I will mark as Maxwell 22 this 20 email?¶

21 (Maxwell Exhibit 22, email, marked 22 for identification.)¶

23 Q. This is dated January 21, 2015. 24 It's from Jeffrey Epstein to you, forwarding 25 the Guardian and I would like you to look at¶

2 the chain of emails so you understand the --¶

3 have an appreciation for who is on this.¶

4 It's a three-page document. The bottom of¶

5 the email appears to be a message from, there¶

6 is a -- at the very bottom there is the¶

7 signature block for¶

9 there is a message from a¶

10¶

11 Do you see that?¶

12 A. Uh-huh.¶

13 Q. Do you know who is?¶

14 A. I do not.¶

15 Q. Above that there is a message from¶

16 and you and it¶

17 says, so this isn't getting better, latest¶

18 from our chums at the Guardian and above that¶

19 you will see on January 21 an email from you¶

20 where you wrote, See below.¶

21 And right above that chain you will¶

22 see Jeffrey Epstein to you on January 21 and¶

23 his statement to you is, This will now end¶

24 but I think a dismissive statement is okay.¶

25 What did he mean by his statement,¶

and above that¶

2 This will now end?¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 A. I have no idea.¶

6 Q. Did you discuss with him what he¶

7 meant by the statement, This will now end?¶

8 A. I don't recall.¶

9 Q. Was he taking any action to ensure 10 that, quote, this will now end?¶

11 A. I have no idea.¶

12 (Maxwell Exhibit 23, email, marked 13 for identification.)¶

14 Q. This is an email from, if you look 15 at the chain at the top, you will see it's 16 from you to Jeffrey on January 27 and the 17 email at the bottom of the chain is from 18 Jeffrey to you on January 27.¶

19 He states, What happened to you and 20 your statement, question mark, question mark.¶

21 And you put at the top, I have not decided 22 what to do.¶

23 A. Uh-huh.¶

24 Q. Why was Jeffrey interested in you 25 making a statement to the press?¶

2 MR. PAGLIUCA: Objection to the 3 form and foundation.¶

4 A. I don't know that he was 5 interested. We made a statement and then I 6 was being advised to make an additional 7 statement and I never did.¶

8 Q. Was Jeffrey communicating with you 9 regularly on what additional statement you 10 might make?¶

11 MR. PAGLIUCA: Objection to the 12 form and foundation.¶

13 A. No, I've communicated with him very 14 little, as little as possible.¶

15 Q. Why did you feel you had to keep 16 him informed of statements you were making to 17 the press?¶

18 MR. PAGLIUCA: Objection to the 19 form and foundation.¶

20 A. I didn't feel I had to.¶

21 Q. Then why you were communicating 22 with him about statements you were making to 23 the press?¶

24 MR. PAGLIUCA: Objection to the 25 form and foundation.¶

2 A. Insofar as this is the case, it's 3 really all about Jeffrey, it's not a case 4 about me.¶

5 Q. In 2009, did you direct your 6 lawyer, either directly or indirectly, to 7 tell Brad that you were unavailable 8 to attend a deposition?¶

9 MR. PAGLIUCA: Objection to the 10 form and foundation. And this is a 11 privileged communication as I understand 12 the question, what someone said or 13 didn't say to their lawyer. So don't 14 answer the question.¶

15 Q. Can you answer that question 16 without revealing a privileged communication?¶

17 A. Can you ask the question again?¶

18 Q. In 2009, did you direct your lawyer 19 to tell Brad that you were 20 unavailable to attend a deposition?¶

21 MR. PAGLIUCA: Same instruction.¶

22 Q. Did you make any statement in 2009 23 to anybody that you were unavailable to 24 attend a deposition?¶

25 A. My mother was sick and I don't¶

2 recall exactly the sequence of events but¶

3 what sequence of events do exist are -- was¶

4 handled by my lawyers.¶

5 Q. What is your understanding of¶

6 Jeffrey Epstein's nonprosecution agreement?¶

7 A. I have no idea.¶

8 Q. Do you have an understanding of the 9 co-conspirators listed in the nonprosecution 10 agreement?¶

11 MR. PAGLIUCA: Objection to the 12 form and foundation.¶

13 A. I have no knowledge of his 14 agreement, whatever that is.¶

15 Q. Do you know, you mentioned earlier 16 today that was one of the listed 17 co-conspirators.¶

18 Do you know who the other 19 co-conspirators are in the nonprosecution 20 agreement?¶

21 MR. PAGLIUCA: Objection to the 22 form and foundation.¶

23 A. I do not know.¶

24 Q. What did Jeffrey Epstein tell you 25 about the nonprosecution agreement?¶

2 A. I don't think I've ever discussed 3 it with him.¶

4 Q. How did you come to learn that¶

5 was covered by the 6 nonprosecution agreement?¶

7 A. I believe I read it in the press.¶

8 Q. Did you have any discussions with 9 with about the nonprosecution 10 agreement?¶

11 A. I have not had any discussions with 12¶

13 Q. When is the last time you spoke to 14 ?¶

15 A. Maybe 2005, 2006 maybe.¶

16 Q. And same with . 17 when is the last time you recall speaking 18 with¶

19 A. Probably even more time before 20 that, maybe I've never had communications 21 really with¶

22 Q. I'm sorry, I didn't hear that.¶

23 A. I never had communications with 24 her.¶

25 Q You were working for Jeffrey at the¶

2 same time was also working for Jeffrey,¶

3 isn't that correct?¶

4 A. I didn't know what did for¶

5 Jeffrey so I didn't characterize what her¶

6 relationship or work or not was and I was¶

7 still helping him with his construction¶

8 projects and the like but I never crossed¶

9 paths with¶

10 Q. What did you think was doing¶

11 for Jeffrey?¶

12 A. I have no idea what was doing¶

13 for Jeffrey.¶

14 Q. Did you observe at any of¶

15 Jeffrey's houses while you were there?¶

16 A. She was at the house on occasion.¶

17 Q. What would she be doing there?¶

18 A. I have no idea.¶

19 Q. Did you know if she lived at his¶

20 houses?¶

21 A. I have no idea.¶

22 Q. Did you ever go into a bedroom and¶

23 see her belongings at one of the houses?¶

24 A. Not that I recall, no.¶

25 Q. I'm going to mark this as Maxwell¶

2 Exhibit 24?¶

3 (Maxwell Exhibit 24, email, marked 4 for identification.)¶

5 Q. You can see at the top of the first 6 page which is GM 0001, it's dated January 3, 7 2015 from you to the¶

8 Is that who we 9 referred to today?¶

10 A. Yes.¶

11 Q. And can you tell me, it says, Have 12 some info. Call me when you have a moment.¶

13 what is redacted there?¶

14 A. I don't recall, I'm sorry.¶

15 Q. Do you know why there is a 16 redaction on this document?¶

17 A. You would have to confer with my 18 lawyers.¶

19 Q. What did you discuss on that call?¶

20 A. I don't have any specific knowledge 21 of that call.¶

22 Q. So the call is being made on 23 Saturday, January 3, 2015?¶

24 MR. PAGLIUCA: Objection to the 25 form and foundation.¶

2 Q. The document states, it's Saturday 3 January 3, 2015. You issued your press 4 release on January 2, 2015.¶

5 Were you discussing with 6 the subject of during 7 these calls?¶

8 MR. PAGLIUCA: Objection to the 9 form and foundation.¶

10 A. I don't know if I spoke to him.¶

11 Q. I would like you to turn to GM 0002 12 and the bottom chain says 13 Saturday January 3, to re, and he says 14 let me know when we can talk. Got some 1 5 specific questions to ask you about U •¶

17 Do you recall having a conversatic: 18 with about 19 or around early January of 2015?¶

20 A. I don't know if we actually spoke.¶

21 Q. Did you ever speak to 22 about after you issued your 23 statement on January 2, 2015?¶

24 A. I know that we did speak at some 25 point but I don't recollect when we spoke.¶

2 Q. What did you talk about?¶

3 A. Just what a liar she is.¶

4 Q. What did he say to you?¶

5 A. What a liar she is.¶

6 Q. Did he tell you why he thought she¶

7 was a liar?¶

8 A. I don't think he told me why she¶

9 was a liar. The substance of everything that 10 she said was a lie with regard to him.¶

11 Q. What did you say to him?¶

12 A. She is a liar.¶

13 Q. That was the whole conversation, it¶

14 was you said to him, she is a liar and he¶

15 said to you she say liar and did you discuss¶

16 any of the details about what those lies¶

17 were?¶

18 A. I don't recollect.¶

19 Q. Was that only one conversation you¶

20 had?¶

21 A. I don't recollect. I don't¶

22 recollect actually the conversation but other¶

23 than -- in detail other than we both said she¶

24 was a liar.¶

25 Q. Do you regularly communicate with¶

2¶

3 MR. PAGLIUCA: Objection to the¶

4 form and foundation.¶

5 A. What do you mean by regularly.¶

6 Q. Do you email with him once a month,¶

7 once every two months or text him or call¶

8 him?¶

9 A. No, we are not in that type of¶

10 regular touch.¶

11 Q. Do you travel with him regularly?¶

12 A. I don't know, I have traveled with¶

13 him. We have traveled together but regularly¶

14 is not a correct characterization.¶

15 Q. Do you travel with him more than¶

16 once a year?¶

17 A. There is no standard. There is no¶

18 set pattern. The answer to that was no.¶

19 Q. Have you ever observed him with any¶

20 underage, any women, female under the age of¶

21 18, interacting, that's not a child or a¶

22 family friend, interacting for the purposes¶

23 of a sexual relationship with that¶

24 individual?¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 A. I've never seen interact in¶

4 any way of that nature.¶

5 Q. Have you ever gone to dinner with¶

6 him with any individual under the age of 18¶

7 that's not a family member or friend of yours¶

8 that is under the age of 18?¶

9 MR. PAGLIUCA: Objection to form¶

10 and foundation.¶

11 A. We've been to dinner all the time,¶

12 I am not not sure who is at dinner with us, I¶

13 can't testify to that.¶

14 Q. Has he ever brought a female under¶

15 the age 18 that's not a relative of his --¶

16 A. He has children.¶

17 Q. I said not relatives.¶

18 A. I can't possibly testify to who he¶

19 comes to dinner with, I wouldn't recall.¶

20 Q. To your knowledge, has he ever had¶

21 a relationship with any female under the age¶

22 of 18 for purposes of a romantic relationship¶

23 to your knowledge?¶

24 A. I can't testify to¶

25 relationship.¶

2 Q. You haven't observed that?¶

3 A. No.¶

4 Q. Have you talked to¶

5 about coming to testify at trial in this 6 case?¶

7 A. No.¶

8 Q. When was the last time you 9 communicated with¶

10 A. 1994, 1995.¶

11 Q. I believe earlier, did you say that 12 you -- when is the last time you've been to 13 his home in¶

14 A. I said -- you asked me if I stayed 15 the night.¶

16 Q. I'm asking you a different 17 question. When is the last time you have 18 been to his home in¶

19 A. Roughly the same time, in the 20 middle of the '90s sometime, mid '90s.¶

21 Q. Not in the years 2000 to 2002?¶

22 A. Mid '90s.¶

23 Q. Have you ever communicated with any 24 representative of¶

25 MR. PAGLIUCA: Objection to the¶

2 form and foundation.¶

3 A. I mean I've been to his -- in the¶

4 mid '90s, I would have communicated with¶

5 people who worked for him.¶

6 Q. Have you communicated with¶

7 about this case?¶

8 A. No.¶

9 10 Q. Have you ever seen a topless female at any one of Jeffrey Epstein's properties?¶

11 MR. PAGLIUCA: Objection to the¶

12 13 form and foundation. You've asked this question, by the way, earlier on today.¶

14 15 16 17 18 19 20 A. Again, I testified that there are people who from time to time in the privacy of a swimming pool have maybe taken a bikini top off or something but it's not common and certainly when I was at the house I don't really recollect seeing that kind of activity.¶

21 Q. Have you ever smoked cigarettes?¶

22 A. Yes.¶

23 24 with Q. Have you ever smoked cigarettes ?¶

25 A. I don't recall smoking cigarettes¶

2 with¶

3 Q. I'm marking this as Maxwell 25.¶

4 (Maxwell Exhibit 25, email, marked 5 for identification.)¶

6 Q. I'm showing you what has been¶

7 marked as Maxwell 25.¶

8 This is an email dated January 11,¶

9 2015 at the top?¶

10 Do you see that that from Jeffrey 11 to you?¶

12 A. Uh-huh.¶

13 Q. And then below there is an email¶

14 from to you and cc'ing 15 on January 11, 2015.¶

16 Do you see that?¶

17 A. Uh-huh.¶

18 Q. It says, Dear Ghislaine, as you 19 know I have been working behind the scenes 20 and this article comes from that. It helps 21 but doesn't answer the VR claims. I will get 22 the criminal allegations out. This shows the 23 MOS will print truth, not just a VR voice 24 piece. We can only make the truth by making 25 a statement.¶

2 What did he mean when he said, I 3 will get the criminal allegations out, what 4 was he referring to?¶

5 MR. PAGLIUCA: Objection to the 6 form and foundation.¶

7 A. I have no idea.¶

8 Q. Were there criminal allegations 9 about Virginia that either your lawyer or 10 were leaking to the press?¶

11 MR. PAGLIUCA: Objection to form 12 and foundation.¶

13 A. I have no idea.¶

14 Q. Did you ask him what he meant when 15 he said, I will get the criminal allegations 16 out?¶

17 A. I don't recollect the conversation.¶

18 Q. Did you direct him to leak to the press criminal allegations about¶

II ?¶

21 A. I already testified that I have no 22 knowledge of what you are asking me.¶

23 Q. Were you copied on this email, 24 correct?¶

25 A. I was.¶

2 Q. Did Jeffrey Epstein assist in¶

3 obtaining information about criminal¶

4 allegations relating to¶

5 MR. PAGLIUCA: Objection to form¶

6 and foundation.¶

7 A. I have no recollection.¶

8 Q. Did assist in¶

9 obtaining information regarding criminal¶

10 allegations of¶

11 MR. PAGLIUCA: Objection to form¶

12 and foundation.¶

13 A. I have no knowledge of that.¶

14 Q. Did you ever discuss that with¶

15¶

16 A. Discuss what?¶

17 Q. Criminal allegations about¶

■¶

19 A. I don't believe I have.¶

20 Q. Have you ever discussed allegations¶

21 relating to --¶

22 Q. Do you know if Jeffrey Epstein had¶

23 any relationship with the U.S. government¶

24 either working for the CIA or the FBI in his¶

25 lifetime?¶

2 MR. PAGLIUCA: Objection to the 3 form and foundation.¶

4 A. I have no knowledge of that.¶

5 Q. Do you know if Jeffrey Epstein has 6 any friends that are in the CIA or FBI?¶

7 MR. PAGLIUCA: Objection to the 8 form and foundation.¶

9 A. I have no idea.¶

10 Q. Are you aware of an investigation 11 of Jeffrey Epstein in the early '80s relating 12 to the SEC?¶

13 MR. PAGLIUCA: Objection to the 14 form and foundation.¶

15 A. I have no knowledge of that.¶

16 Q. Are you aware that Jeffrey Epstein 17 has told people that he worked for the 18 government to recover stolen funds?¶

19 MR. PAGLIUCA: Objection to the 20 form and foundation.¶

21 A. I don't recall conversations about 22 that.¶

23 Q. Has he ever told that you he worked 24 for the U.S. government?¶

25 A. I don't recollect that.¶

2 Q. You don't recollect or has he never 3 told you that?¶

4 A. I have no knowledge, I don't 5 recollect him telling me he worked for the 6 government.¶

7 Q. Does Jeffrey Epstein have any 8 affiliation with the Israeli government?¶

9 MR. PAGLIUCA: Objection to the 10 form and foundation.¶

11 A. I have no knowledge of that.¶

12 Q. Do you know if he ever performed 13 any work for the Israeli government?¶

14 A. I have no knowledge of that¶

15 Q. Have you ever visited Israel with 16 Jeffrey Epstein?¶

17 A. I'm sorry, I don't recollect.¶

18 Q. You've seen the flight logs that I 19 provided you today. Are there, during the 20 time you worked for Jeffrey Epstein, were 21 there times that you flew on commercial 22 flights rather than Jeffrey Epstein's planes?¶

23 A. Yes.¶

24 Q. How often did that occur?¶

25 A. Decently.¶

2 3 Q. Were there other flights that you recall flying on with Jeffrey Epstein that 4 were on flights that -- where 5 not the pilot? was¶

6 A. 7 pilot. was not always the¶

8 Q. How many planes did Jeffrey Epstein 9 have during the time you were with him?¶

10 MR. PAGLIUCA: Objection to the 11 form and foundation.¶

12 A. So you need to give me a date 13 range.¶

14 Q. During the time period of 1992 15 through when you left your employment which I 16 think you said was in 2009?¶

17 A. So in the '90s he had one plane and 18 at some point in the 2000s he had two planes 19 but I can't testify to anything past 2002, 20 2003, what happened to his planes after that.¶

21 Q. Do you know what travel agency, if 22 any, Jeffrey would use when he would send 23 someone, for example, you or one of his other 24 employees on a flight somewhere? Did he use 25 a particular travel agency to make those¶

2 arrangements?¶

3 A. I don't recall.¶

4 Q. Were you ever responsible for 5 making those arrangements for other 6 individuals?¶

7 A. I don't recall making flight¶

8 arrangements.¶

9 Q. Was it a New York travel agent that 10 you would use for those arrangements?¶

11 A. Again, we are talking 16, 17, 18 12 years. I just don't recall anything to do 13 with travel agents.¶

14 Q. Would Jeffrey Epstein ever fly, for 15 example, on a commercial flight 16 to meet you in New Mexico?¶

17 MR. PAGLIUCA: Objection to the 18 form and foundation.¶

19 A. I can't testify to that.¶

20 Q. Do you recall a trip where you met 21 in New Mexico?¶

22 A. No, I don't recall any specific 23 trip, no.¶

24 Q. Why would you be sent to New 25 Mexico, is there a reason why you would go¶

2 there in the course of the work you were¶

3 doing for Jeffrey?¶

4 MR. PAGLIUCA: Objection to the¶

5 form and foundation.¶

6 A. I was never sent. I had a job to¶

7 do and I would have to go to New Mexico for¶

8 work.¶

9 Q. Would assist in that¶

10 project?¶

11 MR. PAGLIUCA: Objection to the¶

12 form and foundation.¶

13 A. No. The project was largely¶

14 complete, largely complete by the end -- I¶

15 don't remember the dates exactly but it was¶

16 largely complete by the 1990s, 2000s.¶

17 Q. Do you know why would¶

18 be going to New Mexico to meet you?¶

19 MR. PAGLIUCA: Objection to the¶

20 form and foundation.¶

21 A. I don't know. She worked for¶

22 Jeffrey.¶

23 MR. PAGLIUCA: I think we are out¶

24 of time, counsel.¶

25 THE VIDEOGRAPHER: It's true.¶

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 tc 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¶

1¶

2¶

3¶

4¶

5¶

6 GHISLAINE MAXWELL¶

7¶

8¶

9¶

10¶

11¶

12 MAXWELL EXHIBIT¶

13 Exhibit 1 police report¶

14 Exhibit 2 email¶

15 Exhibit 3 transcript¶

16 Exhibit 4 photo¶

17 Exhibit 5 photo¶

18 Exhibit 6 flight logs¶

19 Exhibit 7 photo¶

20 Exhibit 8 photo¶

21 Exhibit 9 message pad pages¶

22 Exhibit 10 email¶

23 Exhibit 11 photo¶

24 Exhibit 12 documents¶

25 Exhibit 13 documents¶

INDEX¶

By Ms. McCawley¶

EXHIBITS¶

PAGE¶

4¶

PAGE¶

24¶

33¶

71¶

109¶

113¶

117¶

133¶

143¶

147¶

209¶

259¶

263¶

1¶

2 MAXWELL EXHIBIT PAGE¶

3 Exhibit 14 email 345¶

4 Exhibit 15 email 348¶

5 Exhibit 16 email 348¶

6 Exhibit 17 email 361¶

7 Exhibit 18 email 363¶

8 Exhibit 19 email 365¶

9 Exhibit 20 email 367¶

10 Exhibit 21 email 384¶

11 Exhibit 22 email 390¶

12 Exhibit 23 email 392¶

13 Exhibit 24 email 398¶

14 Exhibit 25 email 405¶

15¶

16¶

17¶

18¶

19¶

20¶

21¶

22¶

23¶

24¶

CERTIFICATE¶

I HEREBY CERTIFY that the witness,
GHISLAINE MAXWELL, was duly sworn by me and
that the deposition is a true record of the
testimony given by the witness.¶

¶

Leslie Fagin,
Registered Professional Reporter
Dated: April 22, 2016¶

(The foregoing certification of
this transcript does not apply to any
reproduction of the same by any means, unless
under the direct control and/or supervision
of the certifying reporter.)¶

2 ACKNOWLEDGMENT OF DEPONENT¶

, do hereby 4 certify that I have read the foregoing pages, and that the same is a correct transcription 5 of the answers given by me to the questions therein propounded, except for the 6 corrections or changes in form or substance, if any, noted in the attached Errata Sheet.¶

9 GHISLAINE MAXWELL DATE 11 Subscribed and sworn to before me this 12 day of, 2016. 13 My commission expires: Notary Public¶

¶

ERRATA¶

PAGE LINE CHANGE¶

<b>A</b>		313:14,15,17 317:5,11,16 331:8 332:11	393:6,9 address 5:23 7:23 7:25 8:5,17 34:13 53:17 264:14 268:20 314:13,19 332:16,19,25 333:2,3,18 345:16 345:18 346:4 348:24 351:5 368:12	affiliated 333:19 334:2 388:2 affiliation 409:8 affiliations 388:21 affirmatively 119:14 afraid 265:5 347:15 age 9:19,19 10:5 13:7,11,17 14:2 14:11,18 15:8 22:9,13,17,20 23:8,15,23 25:6 27:9,18,22 28:21 29:7,16 30:19,21 30:25 32:3,12,23 33:14,19 43:9,12 44:14 46:10,14 56:10,22 57:7 58:17 64:6 83:9 83:17 85:24 95:6 98:17,18,22 99:11 99:23 100:7,9 107:21,25 116:7 121:20 122:3,6 153:15 157:6,10 157:12,15 161:8 162:21,23 163:3 163:17 164:7 177:4 188:11,12 190:4,5,9,19 207:3,14 222:5 225:2 228:20 246:19 247:15,25 248:8,20 249:13 249:14,19,22,24 249:25 250:5,7,12 251:10 254:17 283:23 310:9 325:17 336:11,21 339:9,13 353:16 353:22,24 354:3,5 354:20 355:18 379:18,23 380:6 380:15 382:6,17 383:5,14,15,20 384:2,15 387:12	401:20 402:6,8,15 402:21 aged 33:4 275:22 276:8,18 277:4,22 278:7,19 279:4,14 279:23 280:10 384:11 agency 354:17 410:21,25 agent 201:9,18 202:4 264:4 348:22 350:18 355:18 391:8 406:10 411:9 agents 350:14 411:13 ages 276:19,19 322:21,25 ago 26:22 59:4 75:5 94:25 95:25 96:4 96:5 106:21 126:18,21 317:25 319:7 341:6,14 342:11 347:15 390:15 agree 126:6 200:18 200:19 207:6,9,12 207:14 211:14 226:6 237:11 238:5,14,23 239:12,18,24 240:16 241:6 246:5 250:2 273:20 279:19 298:24 299:5 301:5 agreement 199:9 200:3,4 299:8,11 378:23 395:6,10 395:14,20,25 396:6,10 ahead 111:2 150:23 214:12 221:18 231:12 278:17 337:15 383:23 aimed 361:20
<b>ability</b> 5:14 269:4 <b>able</b> 60:22 73:12 97:8 118:24 135:16 171:2 224:14,17,21,23 224:24 253:12 281:11 288:11 296:25 299:25 300:9 301:8 310:13 314:12 317:11,16 320:21 322:8 353:25 360:7 413:7 <b>absolute</b> 31:5 76:8 134:13,14 175:15 177:3 178:17 179:25 227:10 <b>absolutely</b> 19:2 26:12 40:18 45:18 65:11 134:9,23 135:3,8 145:24 147:18 163:23 177:5,8 202:13 207:16 228:2,22 258:23 351:15 <b>absurd</b> 80:7 82:7 235:7 <b>abuse</b> 21:22 172:2 172:7 182:15 239:13,14,18,19 239:25 240:17,18 240:24 241:8 359:12 <b>abused</b> 90:20 168:21 169:20 170:5,19 171:7,12 171:18 173:14 174:7,22 175:3,10 175:19 176:3,15 178:3 180:10 182:11 183:2,7 <b>abusing</b> 172:13 <b>accept</b> 119:7 229:2 <b>access</b> 7:13 283:13	<b>acknowledgment</b> 417:2 <b>acquaintances</b> 135:18 351:18,24 352:12 <b>act</b> 52:22 53:9 63:3 277:13,19 <b>action</b> 284:8 363:2 392:9 <b>activities</b> 53:19 55:13 270:4 <b>activity</b> 21:13 93:3 236:7 255:14 353:23 389:24 390:8 404:20 <b>acts</b> 21:17 51:7,15 52:2,4,8,11,14 53:2,3,22 55:2,6 55:21 56:2 83:10 93:24 <b>actual</b> 7:25 72:5 95:2,22,24 96:2 153:8 182:4 312:21 345:21 <b>add</b> 107:5 230:2 <b>added</b> 76:11 320:9 320:9,11 <b>addendum</b> 148:5 <b>addition</b> 315:20 <b>additional</b> 150:3	<b>admissible</b> 180:25 <b>admitted</b> 6:9,23 <b>admittedly</b> 118:12 <b>adult</b> 13:4,6 20:10 24:8 30:21 31:17 31:19 43:20 53:13 54:25 62:7 82:16 82:22 93:3 137:21 220:19,21,25 223:16,20 224:4 237:18 243:20 248:3,16 249:15 279:20 308:8 310:9 311:18 324:25 383:14 <b>adults</b> 21:17 27:18 162:21,23 221:11 247:24,25 249:13 249:16,23,25 383:9 <b>advance</b> 186:11 291:13 <b>advice</b> 60:14 61:7 82:15 281:10 362:5,12,14,17 363:11 <b>advised</b> 86:19 393:6 <b>advising</b> 60:24	<b>affiliated</b> 333:19 334:2 388:2 affiliation 409:8 affiliations 388:21 affirmatively 119:14 afraid 265:5 347:15 age 9:19,19 10:5 13:7,11,17 14:2 14:11,18 15:8 22:9,13,17,20 23:8,15,23 25:6 27:9,18,22 28:21 29:7,16 30:19,21 30:25 32:3,12,23 33:14,19 43:9,12 44:14 46:10,14 56:10,22 57:7 58:17 64:6 83:9 83:17 85:24 95:6 98:17,18,22 99:11 99:23 100:7,9 107:21,25 116:7 121:20 122:3,6 153:15 157:6,10 157:12,15 161:8 162:21,23 163:3 163:17 164:7 177:4 188:11,12 190:4,5,9,19 207:3,14 222:5 225:2 228:20 246:19 247:15,25 248:8,20 249:13 249:14,19,22,24 249:25 250:5,7,12 251:10 254:17 283:23 310:9 325:17 336:11,21 339:9,13 353:16 353:22,24 354:3,5 354:20 355:18 379:18,23 380:6 380:15 382:6,17 383:5,14,15,20 384:2,15 387:12	<b>agency</b> 354:17 410:21,25 agent 201:9,18 202:4 264:4 348:22 350:18 355:18 391:8 406:10 411:9 agents 350:14 411:13 ages 276:19,19 322:21,25 ago 26:22 59:4 75:5 94:25 95:25 96:4 96:5 106:21 126:18,21 317:25 319:7 341:6,14 342:11 347:15 390:15 agree 126:6 200:18 200:19 207:6,9,12 207:14 211:14 226:6 237:11 238:5,14,23 239:12,18,24 240:16 241:6 246:5 250:2 273:20 279:19 298:24 299:5 301:5 agreement 199:9 200:3,4 299:8,11 378:23 395:6,10 395:14,20,25 396:6,10 ahead 111:2 150:23 214:12 221:18 231:12 278:17 337:15 383:23 aimed 361:20

¶

<b>air</b> 124:19 129:15 387:23	<b>amount</b> 185:8,22 308:20 342:21	44:20 45:24 52:23 54:5,11,13 55:15 57:3,11 59:12 60:2 62:4,11,17 65:3,5 70:19 73:6 74:21 88:12 89:5 89:14 92:9 93:2,4 95:14,19 97:8,12 102:14 105:23 106:7,8,8,13 107:9 122:20 126:8 138:5 144:6 152:11 174:10 175:21 176:23 177:17,18 178:7 178:12,13 179:15 199:5,10 200:5,7 201:14 203:6,24 205:11 209:5 222:2 225:7 238:2 238:3 243:11 245:2,4,6 253:2,4 253:10 264:7 274:12,13 281:3,9 281:11,19 284:4 286:8 299:15,16 307:13 308:9,23 309:3,6,21 310:13 310:15,16,21,23 324:20 335:9 340:8 358:7,11 372:7 378:5,6 380:3 386:8,18,24 394:14,15 401:18 405:21 413:5	<b>answers</b> 417:5 304:19 305:5,13,24 306:24 309:10,14 <b>anybody</b> 13:16,24 14:7 30:25 53:5 58:11 62:20,24,25 63:6,8 69:13 93:7 93:15,20 94:10,13 95:4,5,16,18 96:8 96:21 97:10,25 99:8 117:3 149:3 156:9 180:3 208:5 250:13 277:18 280:5 292:20 303:23 304:8,14 304:15 308:14 312:10 313:16 335:25 337:18 338:9,11,19 339:13 352:16 362:18 366:13 370:19 379:10,16 384:18 394:23 <b>anyplace</b> 62:25 63:7 116:25 230:15 <b>ap</b> 124:15,16,22 145:3,9 146:17 <b>apart</b> 26:4 108:7 <b>apartment</b> 76:13 76:19 <b>apologize</b> 228:24 <b>apology</b> 229:2 <b>appalled</b> 228:22,23 <b>appalling</b> 183:9 228:18 273:16 <b>apparently</b> 7:14 361:21 <b>appearance</b> 3:16 <b>appearances</b> 2:2 <b>appeared</b> 211:4 <b>appears</b> 35:10 209:20 234:14 391:5	<b>apply</b> 54:21 416:16 <b>appointments</b> 75:13 162:15 <b>appreciate</b> 8:22 11:14 277:8 366:7 <b>appreciation</b> 391:3 <b>approach</b> 310:24 <b>approached</b> 207:2 244:7,13,18 245:19 <b>appropriate</b> 65:20 192:18 207:25 208:3,11 249:12 249:13,16,22,24 250:9,17 310:9,16 <b>april</b> 1:18 3:9 416:12 <b>aquaints</b> 351:7 <b>architect</b> 383:12 <b>architects</b> 12:10,14 31:11 245:10 <b>architectural</b> 194:17 <b>area</b> 39:11 52:15 248:14 <b>areas</b> 11:11 <b>arent</b> 129:5 212:2 <b>argue</b> 89:4 <b>arguing</b> 376:18 141:5 <b>arrange</b> 45:14,19 46:2 49:19,22 116:20 161:21,25 254:20 255:5 <b>arrangements</b> 48:12 79:12 411:2 411:5,8,10 <b>arrest</b> 390:16 <b>arrested</b> 346:21 390:13 <b>arrival</b> 291:14 <b>arrive</b> 16:6 274:5 274:17 <b>arrived</b> 16:4 17:12 <b>article</b> 110:24 368:6 405:20
<b>airport</b> 118:15 125:20 210:17 230:19,21 230:22 231:2,3,4 231:7,8 211:15 299:11 368:5,8,12,15,19 369:3,10 370:20 407:8,14 <b>alcohol</b> 236:3 71:23,23 73:3 218:9,10,24 98:7 304:18 317:25 328:17 329:7,15 329:22,24 330:7 330:19 331:9,15 334:10,19 335:3 <b>allegation</b> 303:25 <b>allegations</b> 137:5 195:2,18 198:11 210:8,11 211:2,3 240:13 351:8,25 405:22 406:3,8,15 406:19 407:4,10 407:17,20 <b>alleged</b> 173:11 210:17 255:14 <b>allegedly</b> 228:5 <b>allow</b> 65:17 385:13 386:22 <b>allowed</b> 87:16 135:20 226:11 308:9 362:16 <b>allows</b> 368:22 153:25 155:4,10 <b>american</b> 99:3 <b>americas</b> 1:24	<b>analyzed</b> 197:5 200:15 58:12 140:22 63:10,15 80:23 106:15 107:4,7,11,13,17 107:19,21,23 108:4,12 110:5 111:8,12,15,25 112:10,24 113:5 113:15 114:22 115:3,7,10,16,17 116:3 231:19 232:7,10,22 235:4 235:10,16,24 236:3,4 286:24 287:3,9,17 288:5 288:16 289:13,22 290:9,12,15,17,23 290:23 291:16 292:3,5,15,20 293:6,8,9,10,14 302:3,10,22 303:11 398:8 399:6,18,21 401:2 402:3 403:4 2:10 290:11 291:13 402:24 <b>angeles</b> 66:13 <b>animal</b> 288:22 55:18,20,24 56:6,7,8,10,14 62:21 <b>answer</b> 9:3 13:2 18:5,9 20:2,12,17 21:11,20,25 22:4 26:11 28:6,9 29:13 30:12 44:4	<b>answered</b> 26:19 29:11 43:3,19 53:24 57:2 87:14 152:23 178:5 179:8,10,13 181:9 235:19 285:22 307:22 359:2 413:8 <b>answering</b> 20:21,23 23:6,9 33:12 54:24 73:13	<b>answers</b> 30:4 305:5,13,24 306:24 309:10,14 <b>anybody</b> 13:16,24 14:7 30:25 53:5 58:11 62:20,24,25 63:6,8 69:13 93:7 93:15,20 94:10,13 95:4,5,16,18 96:8 96:21 97:10,25 99:8 117:3 149:3 156:9 180:3 208:5 250:13 277:18 280:5 292:20 303:23 304:8,14 304:15 308:14 312:10 313:16 335:25 337:18 338:9,11,19 339:13 352:16 362:18 366:13 370:19 379:10,16 384:18 394:23 <b>anyplace</b> 62:25 63:7 116:25 230:15 <b>ap</b> 124:15,16,22 145:3,9 146:17 <b>apart</b> 26:4 108:7 <b>apartment</b> 76:13 76:19 <b>apologize</b> 228:24 <b>apology</b> 229:2 <b>appalled</b> 228:22,23 <b>appalling</b> 183:9 228:18 273:16 <b>apparently</b> 7:14 361:21 <b>appearance</b> 3:16 <b>appearances</b> 2:2 <b>appeared</b> 211:4 <b>appears</b> 35:10 209:20 234:14 391:5	<b>apply</b> 54:21 416:16 <b>appointments</b> 75:13 162:15 <b>appreciate</b> 8:22 11:14 277:8 366:7 <b>appreciation</b> 391:3 <b>approach</b> 310:24 <b>approached</b> 207:2 244:7,13,18 245:19 <b>appropriate</b> 65:20 192:18 207:25 208:3,11 249:12 249:13,16,22,24 250:9,17 310:9,16 <b>april</b> 1:18 3:9 416:12 <b>aquaints</b> 351:7 <b>architect</b> 383:12 <b>architects</b> 12:10,14 31:11 245:10 <b>architectural</b> 194:17 <b>area</b> 39:11 52:15 248:14 <b>areas</b> 11:11 <b>arent</b> 129:5 212:2 <b>argue</b> 89:4 <b>arguing</b> 376:18 141:5 <b>arrange</b> 45:14,19 46:2 49:19,22 116:20 161:21,25 254:20 255:5 <b>arrangements</b> 48:12 79:12 411:2 411:5,8,10 <b>arrest</b> 390:16 <b>arrested</b> 346:21 390:13 <b>arrival</b> 291:14 <b>arrive</b> 16:6 274:5 274:17 <b>arrived</b> 16:4 17:12 <b>article</b> 110:24 368:6 405:20

¶

<b>articles</b> 206:21 231:15 368:21	180:16 181:14 183:17 191:19	63:21 255:4,20 268:19 315:7	<b>availability</b> 325:13 <b>available</b> 160:2 187:2 325:2,6 346:22 347:19	414:10 <b>babies</b> 338:21 <b>baby</b> 336:12,22 337:4,12,18,25,25 338:9,11,19,23,24 339:3,4,6
<b>aside</b> 74:23 133:21 147:21 176:9,14 176:17,20 177:10 177:12 384:10	192:21 196:15,21 197:13,20 199:14 199:15,17 200:10 200:20 201:5 203:17 212:16 216:20 220:21 224:24,25 237:16 237:17,22 238:21 240:19,22,23 241:2 242:9 244:15,17,22 245:3 250:10 268:2,4,6 276:12 276:15 277:10,16 277:20 280:6 281:20 282:3,4,7 283:8 284:23,24 285:6 286:20 287:14,21 290:10 293:8,13 299:14 303:4 307:9 316:13 323:24 325:23 328:16 332:23 336:25 338:5 343:14 348:5 350:17 353:12 357:15 358:4,8 360:9 363:7,8 364:9 366:17 383:13 386:9,15 403:16 406:22	<b>assistants</b> 31:11 92:13 254:19 255:2,5,13,18 <b>assume</b> 116:16 284:6 <b>assumed</b> 11:9 <b>assumes</b> 43:25 241:11 343:11 <b>assuming</b> 285:25 286:3 <b>assumption</b> 166:19 219:18 <b>attached</b> 210:3 417:6 <b>attend</b> 377:2,11 394:8,20,24 <b>attendant</b> 213:20 213:20 214:25 <b>attendants</b> 310:10 <b>attended</b> 377:12 <b>attention</b> 29:4 73:2 117:16 119:22 120:2,12 142:2 144:13,18,23 148:20 149:15 150:9 151:17,21 153:24 158:4,16 165:10 166:21 263:12,19 319:15 319:19 346:18 361:14 366:4 <b>attest</b> 302:18 <b>attorney</b> 186:2 309:5 <b>attorneys</b> 2:4,9,13 2:17 346:12 375:3 <b>attractive</b> 191:11 192:13 <b>author</b> 327:23 <b>authored</b> 260:5 <b>authority</b> 389:12 <b>authorize</b> 273:6,11 <b>authorized</b> 347:9	<b>availability</b> 325:13 <b>available</b> 160:2 187:2 325:2,6 346:22 347:19 <b>avenu</b> 2:17 <b>avenue</b> 1:17,24 2:10 3:11 264:12 <b>average</b> 78:16,22 91:5 <b>avoid</b> 346:21 373:14 <b>awal</b> 374:25 <b>aware</b> 14:6 39:3 49:8,15,16 55:5 82:24,25 83:8,16 83:24,25 84:6 87:8,19,24 88:3,6 89:7 99:19 107:24 111:16 113:11 115:17,19 134:11 164:6 167:16 169:10,12,14,16 169:17 170:3,14 171:25 172:2,6 181:6 183:25 184:4 198:3 223:11 224:9 225:9,21,23 231:11 250:13,21 250:24,25 251:3,4 251:7,11 255:20 256:6,8 275:8,21 276:5,15,25 277:20 278:4,6,18 278:25 279:3,12 279:22 280:5,8 289:16 298:15 318:3 338:14 344:3 372:22 379:10,16 381:19 384:9,18 408:10 408:16 <b>awful</b> 19:4	<b>back</b> 8:13 11:8,15 20:18 22:5 26:17 30:2 35:19 53:10 54:12,21,22 68:2 72:16 73:24 86:19 101:10 103:9 105:21 112:4 115:11 118:5 127:4 131:17 132:13 133:24 141:19 145:15 148:7 156:15 166:22 168:11 182:3 183:16 208:17 235:22 246:12,15 247:12 247:18 250:19 256:16 261:14 265:9,25 294:15 319:17 327:11 333:13,14 340:2,5 340:10,12 341:17 343:3 345:22 373:10,12 377:10 377:13 386:24 388:6,6 <b>backed</b> 240:9 <b>background</b> 10:17 11:5,12 <b>bad</b> 180:24 <b>band</b> 129:21 137:14 <b>banging</b> 228:25 <b>bangkok</b> 131:4 140:9 264:19 265:4,5,7 202:10 204:2 274:10 275:17,19 346:11 347:24 348:24
<b>asked</b> 26:14,16,25 43:3 57:2 68:4 86:22 87:14 112:21 117:2 157:15 169:9 198:15,17 232:9 269:7,8,15,21 284:16 286:24 337:18 338:8,10 358:21 360:16,17 363:10 366:11 370:2,8 375:19 403:14 404:12	<b>asking</b> 9:14 14:24 14:24,25 15:6,7 16:3,4 20:3,8 21:12,15 24:6 25:22 26:7 32:11 33:13 37:23 39:24 41:10 49:14 50:9 51:18,19,21,23,25 52:3,20,25 53:2,7 53:8,20,21 62:8 67:4 83:3 85:21 86:4 88:2,3 90:11 94:2,20 96:4,9,11 96:16 97:9,25 99:2 108:17 112:22 116:16 117:11 126:19,21 137:24,25 138:13 138:24 139:14 148:24 150:5 155:20 161:2 171:11,16 173:19 173:20,21 174:20 174:21 175:10 177:10,13 178:2 178:19,23,25 179:2,3,4,6,7,20	<b>assumed</b> 11:9 <b>assumes</b> 43:25 241:11 343:11 <b>assuming</b> 285:25 286:3 <b>assumption</b> 166:19 219:18 <b>attached</b> 210:3 417:6 <b>attend</b> 377:2,11 394:8,20,24 <b>attendant</b> 213:20 213:20 214:25 <b>attendants</b> 310:10 <b>attended</b> 377:12 <b>attention</b> 29:4 73:2 117:16 119:22 120:2,12 142:2 144:13,18,23 148:20 149:15 150:9 151:17,21 153:24 158:4,16 165:10 166:21 263:12,19 319:15 319:19 346:18 361:14 366:4 <b>attest</b> 302:18 <b>attorney</b> 186:2 309:5 <b>attorneys</b> 2:4,9,13 2:17 346:12 375:3 <b>attractive</b> 191:11 192:13 <b>author</b> 327:23 <b>authored</b> 260:5 <b>authority</b> 389:12 <b>authorize</b> 273:6,11 <b>authorized</b> 347:9	<b>availability</b> 325:13 <b>available</b> 160:2 187:2 325:2,6 346:22 347:19 <b>avenu</b> 2:17 <b>avenue</b> 1:17,24 2:10 3:11 264:12 <b>average</b> 78:16,22 91:5 <b>avoid</b> 346:21 373:14 <b>awal</b> 374:25 <b>aware</b> 14:6 39:3 49:8,15,16 55:5 82:24,25 83:8,16 83:24,25 84:6 87:8,19,24 88:3,6 89:7 99:19 107:24 111:16 113:11 115:17,19 134:11 164:6 167:16 169:10,12,14,16 169:17 170:3,14 171:25 172:2,6 181:6 183:25 184:4 198:3 223:11 224:9 225:9,21,23 231:11 250:13,21 250:24,25 251:3,4 251:7,11 255:20 256:6,8 275:8,21 276:5,15,25 277:20 278:4,6,18 278:25 279:3,12 279:22 280:5,8 289:16 298:15 318:3 338:14 344:3 372:22 379:10,16 381:19 384:9,18 408:10 408:16 <b>awful</b> 19:4	<b>babies</b> 338:21 <b>baby</b> 336:12,22 337:4,12,18,25,25 338:9,11,19,23,24 339:3,4,6 <b>back</b> 8:13 11:8,15 20:18 22:5 26:17 30:2 35:19 53:10 54:12,21,22 68:2 72:16 73:24 86:19 101:10 103:9 105:21 112:4 115:11 118:5 127:4 131:17 132:13 133:24 141:19 145:15 148:7 156:15 166:22 168:11 182:3 183:16 208:17 235:22 246:12,15 247:12 247:18 250:19 256:16 261:14 265:9,25 294:15 319:17 327:11 333:13,14 340:2,5 340:10,12 341:17 343:3 345:22 373:10,12 377:10 377:13 386:24 388:6,6 <b>backed</b> 240:9 <b>background</b> 10:17 11:5,12 <b>bad</b> 180:24 <b>band</b> 129:21 137:14 <b>banging</b> 228:25 <b>bangkok</b> 131:4 140:9 264:19 265:4,5,7 202:10 204:2 274:10 275:17,19 346:11 347:24 348:24

¶

361:5,16 391:16 405:14	89:11 91:7 118:22 121:4 122:16	132:15 134:12,21 136:23 140:23	213:11 291:11 295:25 301:22,23	119:19 120:3,3 129:9 141:24
<b>barely</b> 78:10 79:25 144:9 343:18,18	123:22 125:25 126:13 127:5,13	141:19 146:17 168:21 169:19	304:17 311:20 339:25 361:13	144:19 150:18 156:17 158:16
<b>base</b> 55:15 196:6 377:17,19,24 378:3	132:5 134:20 144:25 145:15	170:5,18 171:6,11 171:12,16,17	373:22 378:18 <b>better</b> 25:14,18,24	159:23 165:12 262:7 326:5,6
<b>based</b> 51:6 55:15 90:4,25 126:9 174:25 175:5 178:22 180:2 182:10 206:19 228:17 243:2 325:13	149:2 155:9,14,17 156:20 157:13 160:25 161:20 186:7,23 187:3,6 187:9 189:18 190:17 214:6 241:22 242:4 243:9 248:18 300:12 313:12	172:10,17 173:13 173:19,22 174:2,2 174:6,21 175:2,9 175:18 176:2,15 178:3 179:3,7 181:25 182:10 183:10,15,17,22 184:17 186:5 193:24 210:9 214:15 215:11 218:9,23 219:5 227:11 229:25 230:21,25 268:25 282:12 283:6 294:18 299:9,12 306:10 307:14,23 307:24 311:17 316:10 317:7,14 321:23 327:14 328:7 330:13,22 339:17,23 341:9 344:5 345:8 346:11 347:3 352:18,19 354:14 359:16 360:16 364:7,20,24 371:25 373:24 374:15 375:23,25 376:23 377:17 379:3,9 381:13 396:7 403:11 407:19	391:17 <b>big</b> 73:7,8 <b>bikini</b> 404:16 130:3 137:18 230:13 301:15,21 <b>birth</b> 5:25 <b>birthday</b> 273:19 282:17 354:4 379:12,18 <b>bit</b> 102:6 119:18 130:11 37:4,16,23 38:17,22,25 39:4 39:11,18 40:2,9 40:17 145:10,19 147:10 <b>bk</b> 145:3 <b>black</b> 69:16 85:15 85:17,18 141:8,13 <b>blacks</b> 85:15 <b>blank</b> 86:14,16,18 87:2 <b>block</b> 391:7 <b>blond</b> 45:10 167:4 <b>blow</b> 110:22 <b>board</b> 245:9 389:11 <b>body</b> 210:6 <b>boies</b> 1:15 2:3 3:13 3:21 <b>book</b> 92:3,6,11,20 273:24 315:19,20 316:3 317:7,12,13 317:21 321:22 323:8,11,15 331:11 332:17,19 332:25 333:2,3 <b>borne</b> 229:3 <b>boss</b> 354:14 <b>bottom</b> 72:17	364:5 368:4 391:4 391:6 392:17 399:12 <b>bought</b> 233:6,18 341:8 <b>boulevard</b> 2:4 <b>bounce</b> 133:23 <b>bound</b> 287:13 <b>bounded</b> 28:10 <b>bounds</b> 21:2 352:5,7,10 <b>brad</b> 2:11 3:23 373:25 374:2,4,13 374:17,21,24 375:15,25 394:7 394:19 <b>break</b> 26:3 45:22 65:14,17 67:21 93:13 94:5,7 117:21 118:8 168:13 169:2 170:10 208:9,11 256:10 294:10 327:6 373:3 <b>breakdown</b> 93:19 <b>breakers</b> 57:25 237:3 <b>breast</b> 53:9 86:21 290:2 <b>breasts</b> 52:14 <b>breath</b> 181:20 207:22 <b>bring</b> 13:10 20:18 25:13,15 48:13,24 54:12 56:21 66:24 67:6,10 154:3,11 244:8,13,18
<b>basis</b> 62:12 88:8 102:17 228:16 305:11 348:3,7	<b>becoming</b> 60:14 <b>bed</b> 73:24 145:25 146:3 <b>bedroom</b> 397:22 <b>bedrooms</b> 112:5 <b>began</b> 12:8 86:21 101:16 322:3 <b>beginning</b> 72:13 142:18 156:4 215:9 241:18 <b>begins</b> 3:3 <b>behalf</b> 4:4 210:4 273:7,12 <b>behavior</b> 181:22 197:6 <b>belief</b> 171:17 173:21 175:11,13 175:14 178:7,25 179:17 182:14 <b>believe</b> 6:7 10:25 26:19 29:12 36:25 48:11 56:8 60:8 61:18 68:11 72:16 83:6 100:17 101:15 102:5 103:20 104:12 105:5 110:8,16,20 118:11 122:7 124:4,25 129:22 129:24 131:13	<b>bell</b> 388:13 <b>belongings</b> 397:23 <b>beneath</b> 130:20,20 346:10 <b>benefit</b> 142:7 <b>benefits</b> 101:2 <b>benign</b> 191:11 <b>best</b> 10:4 50:15	<b>bit</b> 102:6 119:18 130:11 37:4,16,23 38:17,22,25 39:4 39:11,18 40:2,9 40:17 145:10,19 147:10 <b>black</b> 69:16 85:15 85:17,18 141:8,13 <b>blacks</b> 85:15 <b>blank</b> 86:14,16,18 87:2 <b>block</b> 391:7 <b>blond</b> 45:10 167:4 <b>blow</b> 110:22 <b>board</b> 245:9 389:11 <b>body</b> 210:6 <b>boies</b> 1:15 2:3 3:13 3:21 <b>book</b> 92:3,6,11,20 273:24 315:19,20 316:3 317:7,12,13 317:21 321:22 323:8,11,15 331:11 332:17,19 332:25 333:2,3 <b>borne</b> 229:3 <b>boss</b> 354:14 <b>bottom</b> 72:17	<b>boulevard</b> 2:4 <b>bounce</b> 133:23 <b>bound</b> 287:13 <b>bounded</b> 28:10 <b>bounds</b> 21:2 352:5,7,10 <b>brad</b> 2:11 3:23 373:25 374:2,4,13 374:17,21,24 375:15,25 394:7 394:19 <b>break</b> 26:3 45:22 65:14,17 67:21 93:13 94:5,7 117:21 118:8 168:13 169:2 170:10 208:9,11 256:10 294:10 327:6 373:3 <b>breakdown</b> 93:19 <b>breakers</b> 57:25 237:3 <b>breast</b> 53:9 86:21 290:2 <b>breasts</b> 52:14 <b>breath</b> 181:20 207:22 <b>bring</b> 13:10 20:18 25:13,15 48:13,24 54:12 56:21 66:24 67:6,10 154:3,11 244:8,13,18

¶

245:20 249:17	92:5 150:17	238:3,19 240:25	cars 341:16,19,23	416:15
291:7 321:19	160:17 161:4,6	241:4 245:6	342:3,5,21	<b>certify</b> 416:5 417:4
339:7	165:19,23 167:6	255:13 268:12,14	<b>case</b> 1:7 6:9 7:10	<b>certifying</b> 416:19
<b>bringing</b> 17:4	260:20 295:23	271:4,8 272:8	21:14,21,25 27:5	<b>certitude</b> 171:23
48:19 49:2 99:19	314:10 325:4	282:8,25 283:16	49:10 94:3 103:3	<b>chain</b> 352:23
309:24 380:6,15	336:5 385:21	285:15 286:13	103:3,6 118:20	353:12,13 356:7
<b>british</b> 211:4	398:12,19,21,22	293:11 294:4	150:8 211:15,16	367:25 368:4,11
[REDACTED] 159:25	401:7	296:15 297:18	211:17 238:11	368:17 369:18
161:22	<b>called</b> 4:6 71:3	299:2,22,23 300:6	283:18 335:21,22	391:2,21 392:15
<b>brought</b> 16:21	111:12 115:13	301:4,12,18 302:6	336:2,5 343:22,25	392:17 399:12
18:17 27:2,3	117:3 134:3 158:7	303:21,22 307:4	349:2 350:3,12	<b>change</b> 11:24 102:3
98:13 99:15	163:24 165:15	314:7 320:8,11	352:13 360:6	265:11 418:3
146:22 147:3	236:11,12 325:5	321:2 324:14	373:15 374:16,23	<b>changed</b> 10:11
155:4 221:14	335:25 361:23	325:20 326:2	394:2,3 403:6	214:24 251:9
224:12 248:7	374:23 387:23	327:24 328:2	404:7	345:22
249:12,22 254:16	<b>calling</b> 80:4 160:7	329:22 330:7	<b>cases</b> 375:8 376:4,5	<b>changes</b> 210:15
309:23 321:14	164:15 165:4	332:9,17 333:7,13	[REDACTED] 152:2 153:12	417:6
339:13 382:5	239:12,18,24	333:15 337:16	153:14	<b>characterization</b>
383:3 402:14	240:16 241:6	341:3,5,7 348:6	<b>cash</b> 50:5,11,17,20	32:20 105:19
[REDACTED] 99:15	296:9 362:7,25	350:20 369:14	50:21	213:5,9 214:8,17
116:21 166:25	<b>calls</b> 49:12 149:4	375:17 378:6	<b>cassell</b> 2:13 3:25,25	215:18 219:6,14
167:7 379:22	199:5 274:9 281:2	385:21 390:11	<b>categorically</b>	226:16 228:24
380:6,14	284:2 298:8 375:2	402:13,18,24	117:14,15 134:8	231:17 233:5
<b>bubble</b> 234:24	399:7	410:19 411:19	174:16 227:25	234:6 290:9
<b>builders</b> 12:14,15	<b>calm</b> 181:19 207:23	<b>capacity</b> 188:6	<b>categorize</b> 135:19	309:20 401:14
<b>building</b> 12:16,20	<b>campus</b> 310:25	382:18 384:13	135:22	<b>characterizations</b>
143:20,21 144:2	<b>campuses</b> 311:9	<b>car</b> 276:18 341:4,8	<b>caught</b> 275:14	126:7 235:12
<b>bunch</b> 230:20	<b>canada</b> 132:6,7,21	341:9,12,15,17,25	<b>cause</b> 239:14,20,25	<b>characterize</b>
<b>burberry</b> 233:6	141:21	342:10,13,16	240:18 241:8	135:16 216:14
<b>business</b> 21:18	<b>cant</b> 4:23 5:2 23:18	<b>career</b> 60:13 61:7	<b>caused</b> 206:22	290:8 296:15
381:7,10,14,20	35:24 73:10 84:9	<b>careful</b> 369:2,5,16	<b>causes</b> 241:19	297:2 298:13
388:20 389:2,15	99:6,8 105:17	369:19	<b>causing</b> 245:5	310:4,6 311:14
<b>businesses</b> 388:25	106:13 112:16	<b>carefully</b> 177:10	<b>ccing</b> 405:14	321:20 338:12
<b>busy</b> 28:24 29:5	125:6 128:14	202:2	<b>celebrated</b> 273:19	375:17 397:5
<b>butlers</b> 310:12	129:3,6 137:3	<b>caricature</b> 289:22	<b>celebrating</b> 282:17	<b>characterized</b>
<b>buy</b> 111:24 341:4,9	141:7 144:6 147:6	289:24,25 290:12	<b>cell</b> 76:22,24 77:11	228:21 236:2,5
<b>buying</b> 66:20	153:10 154:8	290:15,15,22,25	77:16 259:4,6	290:7 347:10
233:22	156:14 161:11	291:16,18,21	260:2 261:21	357:2 367:18
[REDACTED] 268:18	165:8 177:12	292:2,6,16 293:10	321:5,9,15 322:8	383:8
269:8,15,21,25	188:17 192:24	293:11	<b>certain</b> 68:19	<b>characterizing</b>
270:10,22 271:18	193:15,16 195:4	[REDACTED] 152:2	<b>certainly</b> 54:20	364:15
272:3,15,18	195:14 212:10	153:12,14	99:7 138:4 148:16	<b>charge</b> 12:9,10 31:6
	220:10 221:3,13	<b>carry</b> 336:11,21	315:15 322:25	49:23 51:11,12
	221:20 222:6	337:4,12,18,24	368:18 404:18	54:8 322:7
	223:9 231:22	338:9,11,19	<b>certificate</b> 416:2	<b>charges</b> 195:8
<b>call</b> 73:8 77:17 79:8	233:21 237:7	<b>carrying</b> 214:2	<b>certification</b> 124:23	368:22

<b>charity</b> 371:16	<b>355:2</b>	<b>close</b> 376:24	<b>246:12,14,15</b>	<b>communications</b>
<b>chart</b> 118:14,20	<b>claims</b> 102:23	<b>clock</b> 77:11,12	<b>247:12,20 249:9</b>	<b>199:13,15 200:2</b>
<b>chauffeurs</b> 310:12	<b>106:12 108:16</b>	<b>close</b> 74:10,14,17	<b>250:18 254:20</b>	<b>274:9,15,20 363:9</b>
<b>check</b> 196:9 357:16	<b>179:23 201:10,20</b>	<b>close</b> 295:2,15	<b>255:6 269:8,16,22</b>	<b>396:20,23</b>
<b>chef</b> 247:4 383:11	<b>202:6 205:5 206:4</b>	<b>closest</b> 294:23	<b>272:22 293:16,23</b>	<b>company</b> 372:15,15
<b>chefs</b> 245:12	<b>210:19,25 211:7</b>	<b>295:6</b>	<b>325:2 333:22</b>	<b>387:22,25 388:4</b>
<b>310:11</b>	<b>213:12,13,19</b>	<b>closet</b> 73:20	<b>351:7 363:18</b>	<b>388:10,17,19</b>
<b>377:2,11,12</b>	<b>251:7 405:21</b>	<b>clothes</b> 30:8,10	<b>364:3,10,21 366:7</b>	<b>389:8,8,10</b>
<b>child</b> 23:16 38:6	<b>clarification</b> 358:9	<b>190:23</b>	<b>366:11,14 377:10</b>	<b>compare</b> 268:3
<b>42:24 43:4,7,15</b>	<b>clarify</b> 7:22 8:13	<b>clothing</b> 190:13,23	<b>382:17 396:4</b>	<b>compel</b> 179:15
<b>43:16 106:19</b>	<b>9:5 36:21 257:2,3</b>	<b>194:8</b>	<b>406:19 405:20</b>	<b>compensation</b>
<b>165:3 173:4 181:8</b>	<b>clarity</b> 8:4,20	<b>club</b> 111:12 236:9	<b>402:19 405:20</b>	<b>278:9,22</b>
<b>401:21</b>	<b>cleaners</b> 31:12	<b>236:10,10,11,13</b>	<b>comfortable</b> 25:12	<b>competencies</b>
<b>children</b> 13:20 14:8	<b>116:18</b>	<b>coconspirator</b> 49:9	<b>86:14 222:23</b>	<b>248:14,15</b>
<b>22:25 23:17,25</b>	<b>cleaning</b> 245:12	<b>49:9</b>	<b>coming</b> 27:10 29:19	<b>competent</b> 246:22
<b>30:22 90:19</b>	<b>clear</b> 6:17 8:15,21	<b>coconspirators</b>	<b>78:14 153:19</b>	<b>compilation</b> 352:20
<b>107:22 168:22</b>	<b>9:8 30:5 41:4</b>	<b>378:22 395:9,17</b>	<b>160:19 163:25</b>	<b>complete</b> 10:22
<b>170:19 180:8</b>	<b>54:19 103:6 119:3</b>	<b>395:19</b>	<b>226:14 247:18</b>	<b>273:23 412:14,14</b>
<b>183:2 184:6 339:9</b>	<b>126:5 137:4</b>	<b>code</b> 118:18	<b>329:8,16,25</b>	<b>412:16</b>
<b>402:16</b>	<b>138:13 174:5</b>	<b>codes</b> 118:15	<b>330:10 350:15</b>	<b>completed</b> 230:2
<b>china</b> 131:4 140:9	<b>177:24 208:4</b>	<b>125:20</b>	<b>368:6 380:10</b>	<b>completely</b> 227:4
<b>377:18</b>	<b>249:17 251:6</b>	<b>colleague</b> 3:20	<b>403:5</b>	<b>337:10 367:5</b>
<b>chips</b> 208:8	<b>263:14 321:24</b>	<b>collect</b> 284:7,11	<b>commencing</b> 1:17	<b>complex</b> 353:17
<b>choose</b> 244:24	<b>338:4,7,8 413:10</b>	<b>color</b> 141:8 142:20	<b>comment</b> 29:22	<b>composite</b> 345:10
<b>382:22,24</b>	<b>378:2</b>	<b>143:9</b>	<b>90:5 176:20</b>	<b>computer</b> 186:22
<b>chose</b> 182:22	<b>clearer</b> 276:14	<b>colorado</b> 2:18	<b>220:10,11 294:4</b>	<b>186:23 187:2,6,9</b>
<b>266:23</b>	<b>clearer</b> 276:14	<b>column</b> 120:14,15	<b>411:15</b>	<b>187:20,25 188:9</b>
<b>christe</b> 2:22 3:14	<b>clearly</b> 33:19 69:11	<b>120:15 130:22</b>	<b>commercial</b> 409:21	<b>188:12,14 189:10</b>
<b>chums</b> 391:18	<b>107:8 282:18</b>	<b>131:8,24 132:3,12</b>	<b>commission</b> 417:13	<b>189:12 194:23</b>
<b>cia</b> 407:24 408:6	<b>384:10</b>	<b>132:14 321:4,9</b>	<b>commits</b> 353:24	<b>313:13,18,24</b>
<b>cigarettes</b> 404:21	<b>client</b> 20:10	<b>326:4</b>	<b>committed</b> 344:12	<b>314:8,12 315:8,20</b>
<b>404:23,25</b>	<b>clients</b> 380:23	<b>columns</b> 322:19,21	<b>344:16,22 346:24</b>	<b>315:23 316:4,24</b>
<b>circumcised</b> 86:22	<b>104:17,23</b>	<b>com 34:12</b>	<b>386:4</b>	<b>318:4,12,19 319:2</b>
<b>86:23</b>	<b>105:3,7 106:2,4</b>	<b>come</b> 11:8 13:23	<b>common</b> 199:8	<b>319:2,4 331:2,2,6</b>
<b>circumstances</b> 63:6	<b>129:20 130:3,9,14</b>	<b>14:3,10,15,19</b>	<b>200:3 404:17</b>	<b>331:8,11,17,22,23</b>
<b>328:15</b>	<b>130:18 131:4</b>	<b>15:2,7,15,21 16:5</b>	<b>communicate</b>	<b>331:24 332:4,6,10</b>
<b>circus</b> 288:18	<b>134:7,11,15,16,22</b>	<b>45:15 51:14 54:21</b>	<b>222:18 355:17</b>	<b>332:12,24 333:9</b>
<b>citizen</b> 371:8,11,13	<b>135:7,11,15,25</b>	<b>54:22 73:24 77:20</b>	<b>400:25</b>	<b>333:18,22 334:3,7</b>
<b>city</b> 2:14 119:10	<b>136:2,8,19 137:5</b>	<b>77:25 78:13 79:8</b>	<b>communicated</b>	<b>370:24 371:6</b>
<b>271:12</b>	<b>137:18 138:18</b>	<b>103:9 112:4</b>	<b>393:13 403:9,23</b>	<b>computers</b> 188:19
<b>civil</b> 20:22	<b>139:4,15 140:11</b>	<b>114:20 154:10</b>	<b>404:4,6</b>	<b>189:2,6 319:5</b>
<b>clad</b> 194:10	<b>212:14 230:8,14</b>	<b>156:20 157:13,16</b>	<b>communicating</b>	<b>330:25</b>
<b>claimed</b> 63:14	<b>266:22 267:2,8,15</b>	<b>161:22 162:16,23</b>	<b>356:10 393:8,21</b>	<b>concealed</b> 191:4
<b>171:22 235:11,22</b>	<b>267:25 268:9</b>	<b>163:3,17 167:14</b>	<b>communication</b>	<b>conceivable</b> 245:16
<b>257:21</b>	<b>301:15,21 351:9</b>	<b>219:9,25 223:21</b>	<b>199:6,24 284:2</b>	<b>conceive</b> 245:17
<b>claiming</b> 35:2	<b>377:3,23 378:12</b>	<b>224:19,23 232:22</b>	<b>394:11,16</b>	<b>conceived</b> 136:8

<b>concern</b> 355:7,12	89:1 90:1 91:1	226:1 227:1 228:1	364:1 365:1 366:1	<b>consulting</b> 11:21
<b>concerned</b> 24:7	92:1 93:1 94:1	229:1 230:1 231:1	367:1 368:1 369:1	<b>contact</b> 39:4 61:20
226:12 302:15	95:1 96:1 97:1	232:1 233:1 234:1	370:1 371:1 372:1	62:5,9,14 184:7
303:14 335:11	98:1 99:1 100:1	235:1 236:1 237:1	373:1 374:1 375:1	184:13 202:18
354:5,9 355:14,15	101:1 102:1,19	238:1 239:1 240:1	376:1 377:1 378:1	229:20 257:7,14
355:23 369:9	103:1 104:1 105:1	241:1 242:1 243:1	379:1 380:1 381:1	258:2,3,11,17
<b>concerns</b> 178:16	106:1 107:1 108:1	244:1 245:1 246:1	382:1 383:1 384:1	295:21,22 296:9
354:20	109:1 110:1 111:1	247:1 248:1 249:1	385:1 386:1 387:1	308:8,10,13
<b>concludes</b> 413:17	112:1 113:1 114:1	250:1 251:1 252:1	388:1 389:1 390:1	313:19 314:13,19
<b>conclusion</b> 25:10	115:1 116:1 117:1	253:1 254:1 255:1	391:1 392:1 393:1	315:3,9,11 316:17
49:13	118:1 119:1 120:1	256:1 257:1 258:1	394:1 395:1 396:1	322:9 331:21
<b>condo</b> 57:25	121:1 122:1 123:1	259:1 260:1 261:1	397:1 398:1 399:1	332:14 333:10
<b>conduct</b> 200:25	124:1 125:1 126:1	262:1 263:1 264:1	400:1 401:1 402:1	335:20 369:17
203:2,10,19 205:7	127:1 128:1 129:1	265:1 266:1 267:1	403:1 404:1 405:1	<b>contacted</b> 335:19
<b>conducted</b> 389:25	130:1 131:1 132:1	268:1 269:1 270:1	406:1 407:1 408:1	352:11,15 375:21
<b>confer</b> 398:17	133:1 134:1 135:1	271:1 272:1 273:1	409:1 410:1 411:1	<b>contained</b> 70:6,12
<b>confidential</b> 1:11	136:1 137:1 138:1	274:1 275:1 276:1	412:1 413:1,12	<b>contains</b> 84:7
4:1 5:1 6:1,7,14	139:1 140:1 141:1	277:1 278:1 279:1	<b>confirm</b> 112:23	<b>contd</b> 168:8
6:15 7:1,13 8:1	142:1 143:1 144:1	280:1 281:1 282:1	299:18,25 300:9	<b>contemporaneou...</b>
9:1 10:1 11:1,7,13	145:1 146:1 147:1	283:1 284:1 285:1	301:8,14,25	284:15
11:18 12:1 13:1	148:1 149:1 150:1	286:1 287:1 288:1	303:16 356:11	<b>contend</b> 329:10
14:1 15:1 16:1	151:1 152:1 153:1	289:1 290:1 291:1	359:24	<b>contest</b> 85:21
17:1 18:1 19:1	154:1 155:1 156:1	292:1 293:1 294:1	<b>confirming</b> 356:16	<b>contesting</b> 128:19
20:1,14 21:1 22:1	157:1 158:1 159:1	295:1 296:1 297:1	<b>connection</b> 21:14	<b>context</b> 60:24
23:1 24:1 25:1	160:1 161:1 162:1	298:1 299:1 300:1	<b>consensual</b> 20:9	235:20 245:17
26:1 27:1 28:1	163:1 164:1 165:1	301:1 302:1 303:1	21:17 52:21,25	246:6 272:16,17
29:1 30:1 31:1	166:1 167:1 168:1	304:1 305:1 306:1	53:13 62:2,15	292:12 293:12
32:1 33:1 34:1,6	169:1 170:1 171:1	307:1 308:1 309:1	64:4 65:2 82:22	310:14 385:14
35:1 36:1 37:1	172:1 173:1 174:1	310:1 311:1 312:1	93:3,24 137:22	<b>continue</b> 21:4,5
38:1 39:1 40:1	175:1 176:1 177:1	313:1 314:1 315:1	308:8	133:20 184:12,25
41:1 42:1 43:1	178:1 179:1 180:1	316:1 317:1 318:1	<b>consent</b> 54:25 63:3	<b>continued</b> 86:18,20
44:1 45:1 46:1	181:1 182:1 183:1	319:1 320:1 321:1	353:17 354:6,21	<b>contractor</b> 12:12
47:1 48:1 49:1	184:1 185:1 186:1	322:1 323:1 324:1	355:18	<b>contracts</b> 12:15
50:1 51:1 52:1	187:1 188:1 189:1	325:1 326:1 327:1	<b>consider</b> 91:16,19	<b>contradict</b> 351:13
53:1 54:1 55:1	190:1 191:1 192:1	328:1 329:1 330:1	<b>considerable</b> 184:5	351:19
56:1 57:1 58:1	193:1 194:1 195:1	331:1 332:1 333:1	<b>considerably</b> 10:13	<b>contradictory</b>
59:1 60:1 61:1	196:1 197:1 198:1	334:1 335:1 336:1	<b>consideration</b>	213:22
62:1 63:1 64:1	199:1 200:1 201:1	337:1 338:1 339:1	185:24	<b>control</b> 416:18
65:1 66:1 67:1	202:1 203:1 204:1	340:1 341:1 342:1	<b>considered</b> 295:4	<b>controlled</b> 288:24
68:1 69:1 70:1	205:1 206:1 207:1	343:1 344:1 345:1	<b>considering</b> 215:6	<b>conversation</b> 15:4
71:1 72:1 73:1	208:1 209:1 210:1	346:1 347:1 348:1	<b>constitute</b> 191:25	44:14 61:7 77:19
74:1 75:1 76:1	211:1 212:1 213:1	349:1 350:1 351:1	192:17	94:24 95:3 195:9
77:1 78:1 79:1	214:1 215:1 216:1	352:1 353:1 354:1	<b>construction</b> 12:6,7	195:25 200:9
80:1 81:1 82:1	217:1 218:1 219:1	355:1 356:1 357:1	12:8 66:19 397:7	219:2 222:25
83:1 84:1 85:1	220:1 221:1 222:1	358:1 359:1 360:1	<b>construed</b> 21:13	223:23 272:15,21
86:1 87:1 88:1	223:1 224:1 225:1	361:1 362:1 363:1	<b>consult</b> 186:2	298:2 303:12

¶

| 338:13,20 344:18
399:17 400:13,19
400:22 406:17 | 373:25 374:7
378:23 383:20
397:3 401:14
406:24 417:4 | 142:7 177:24
199:11 228:4
413:7,14
<b>cover</b> 34:9 71:21
230:8 353:10
413:13
<b>covered</b> 191:4
243:18,24 396:5
<b>create</b> 319:10
<b>created</b> 312:23
313:3,22 317:22
323:11 374:16
<b>creating</b> 376:4
<b>creation</b> 313:4,9
<b>credible</b> 349:3
350:5,13
<b>cried</b> 348:25 350:3
350:11
<b>criminal</b> 168:19
169:14 170:14
171:5 186:3 195:2
405:22 406:3,8,15
406:19 407:3,9,17
<b>crisis</b> 80:5
<b>crossed</b> 397:8
<b>crying</b> 87:3
<b>current</b> 259:6
<b>currently</b> 5:24 8:18 | 125:16 131:23
140:5 144:16
150:14 152:2
153:3 155:25
159:24 160:22
209:19 268:13,14
313:6 347:12,14
373:23 374:24
375:3 376:21
377:3 410:12
417:9
<b>dated</b> 34:6 157:20
348:18 353:6,13
356:5 362:22
363:14 366:2
384:24 390:23
398:6 405:8
416:12
<b>dates</b> 47:18 105:11
112:17 132:19
265:24 266:2
267:11 268:12,15
282:16 412:15
<b>daughters</b> 116:10
163:24
<b>day</b> 5:7 78:16,17,22
84:25 92:4,21
156:8 166:7 218:8
220:6,16 222:8
223:5 226:21,22
227:23 275:11
324:17,22 325:8
417:12
<b>days</b> 78:25 85:6
89:17 166:11
186:20,20 328:7
<b>dealing</b> 12:21
<b>deals</b> 371:17
<b>dear</b> 405:18
<b>death</b> 85:5
<b>debate</b> 179:13
<b>december</b> 296:10
296:14,22 297:11
298:9
<b>decently</b> 409:25 | <b>decide</b> 223:25
247:9
<b>decided</b> 204:2
392:21
<b>decision</b> 285:25
<b>decorate</b> 146:20
<b>decorating</b> 11:22
146:24
<b>decorators</b> 31:12
245:10
<b>deep</b> 181:20 207:22
<b>defamation</b> 53:15
93:24 103:3 135:5
176:13 361:18
<b>defamatory</b> 210:22
210:25 211:7
<b>defendant</b> 2:17
103:2
<b>defendants</b> 1:9
<b>defense</b> 200:3
299:7,10
<b>define</b> 70:24 91:14
97:3 138:6 242:21
242:23 243:2
249:24
<b>defined</b> 138:14
288:21
<b>definitely</b> 130:17
309:8
<b>definition</b> 243:3
<b>definitively</b> 134:8
282:9,24 283:4
<b>deflecting</b> 367:10
<b>degree</b> 353:24
<b>delay</b> 6:18
<b>delaying</b> 7:16
<b>delete</b> 369:24 370:5
370:11,14
<b>deleted</b> 370:7,15,17
<b>denies</b> 210:19
211:2,3
<b>dent</b> 208:7
<b>denver</b> 2:18
<b>deny</b> 174:16 299:18
300:2,10 301:8,14
303:16 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | ---------------------------------------------------------------------------------¶

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