UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

x

Plaintiff,

-against-Case No.: 15-cv-07433-RWS

GHISLAINE MAXWELL,

Defendants.

\*\*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

| <p>Page 18</p> <p>1 G Maxwell - Confidential</p> <p>2 meet Mr. Epstein?</p> <p>3 MR. PAGLIUCA: Object to the form</p> <p>4 and foundation.</p> <p>5 Q. You can answer.</p> <p>6 A. I just explained.</p> <p>7 A. I spent the entire time talking to</p> <p>8 █ mother outside the house so the</p> <p>9 answer to the question is no.</p> <p>10 Q. No, did you not walk her up and</p> <p>11 introduce her to Mr. Epstein?</p> <p>12 A. I just said no.</p> <p>13 Q. Did you participate in a massage</p> <p>14 this first time when she first came to the</p> <p>15 home and you were speaking with her mother,</p> <p>16 she was in the home, is that correct, you</p> <p>17 brought her into the home?</p> <p>18 MR. PAGLIUCA: Object to the form</p> <p>19 and foundation.</p> <p>20 A. I will repeat again, I was standing</p> <p>21 outside with her mother so very difficult for</p> <p>22 me to do anything else at that time so no, I</p> <p>23 did not take her upstairs.</p> <p>24 Q. Did you participate --</p> <p>25 A. █ lied 100 percent about</p> | <p>Page 20</p> <p>1 G Maxwell - Confidential</p> <p>2 you not to answer that question. I</p> <p>3 don't have any problem with you asking</p> <p>4 questions about what the subject matter</p> <p>5 of this lawsuit is, which would be, as</p> <p>6 you've termed it, sexual trafficking of</p> <p>7 █</p> <p>8 To the extent you are asking for</p> <p>9 information relating to any consensual</p> <p>10 adult interaction between my client and</p> <p>11 Mr. Epstein, I'm going to instruct her</p> <p>12 not to answer because it's not part of</p> <p>13 this litigation and it is her private</p> <p>14 confidential information, not subject to</p> <p>15 this deposition.</p> <p>16 MS. McCAWLEY: You can instruct her</p> <p>17 not to answer. That is your right. But</p> <p>18 I will bring her back for another</p> <p>19 deposition because it is part of the</p> <p>20 subject matter of this litigation so she</p> <p>21 should be answering these questions.</p> <p>22 This is civil litigation, deposition and</p> <p>23 she should be responsible for answering</p> <p>24 these questions.</p> <p>25 MR. PAGLIUCA: I disagree and you</p>                       |
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| <p>Page 19</p> <p>1 G Maxwell - Confidential</p> <p>2 absolutely everything that took place in that</p> <p>3 first meeting. She has lied repeatedly,</p> <p>4 often and is just an awful fantasist. So</p> <p>5 very difficult for anything to take place</p> <p>6 that she repeated because I was with her</p> <p>7 mother the entire time.</p> <p>8 Q. So did you have -- did you give a</p> <p>9 massage with █ and Mr. Epstein</p> <p>10 during the first time █ was at</p> <p>11 the West Palm Beach house?</p> <p>12 MR. PAGLIUCA: Object to the form</p> <p>13 and foundation.</p> <p>14 Q. Yes or no?</p> <p>15 A. No.</p> <p>16 Q. Have you ever given a massage with</p> <p>17 █ in the room and Jeffrey</p> <p>18 Epstein?</p> <p>19 MR. PAGLIUCA: Object to the form</p> <p>20 and foundation.</p> <p>21 A. No.</p> <p>22 Q. Have you ever given Jeffrey Epstein</p> <p>23 a massage?</p> <p>24 MR. PAGLIUCA: Object to the form,</p> <p>25 foundation. And I'm going to instruct</p>                                                                 | <p>Page 21</p> <p>1 G Maxwell - Confidential</p> <p>2 understand the bounds that I put on it.</p> <p>3 MS. McCAWLEY: No, I don't. I will</p> <p>4 continue to ask my questions and you can</p> <p>5 continue to make your objections.</p> <p>6 Q. Did you ever participate from the</p> <p>7 time period of 1992 to 2009, did you ever</p> <p>8 participate in a massage with Jeffrey Epstein</p> <p>9 and another female?</p> <p>10 MR. PAGLIUCA: Objection. Do not</p> <p>11 answer that question. Again, to the</p> <p>12 extent you are asking for some sort of</p> <p>13 illegal activity as you've construed in</p> <p>14 connection with this case I don't have</p> <p>15 any problem with you asking that</p> <p>16 question. To the extent these questions</p> <p>17 involve consensual acts between adults,</p> <p>18 frankly, they're none of your business</p> <p>19 and I will instruct the witness not to</p> <p>20 answer.</p> <p>21 MS. McCAWLEY: This case involves</p> <p>22 sexual trafficking, sexual abuse,</p> <p>23 questions about her having interactions</p> <p>24 with other females is relevant to this</p> <p>25 case. She needs to answer these</p> |

| <p>Page 22</p> <p>1 G Maxwell - Confidential<br/> 2 questions.<br/> 3 MR. PAGLIUCA: I'm instructing her<br/> 4 not to answer.<br/> 5 MS. McCAWLEY: Then we will be back<br/> 6 here again.<br/> 7 Q. Have you ever given a massage to<br/> 8 Mr. Epstein with a female that was under the<br/> 9 age of 18?<br/> 10 A. Can you repeat the question?<br/> 11 Q. Yes. Have you ever given a massage<br/> 12 to Mr. Epstein with a female that was under<br/> 13 the age of 18?<br/> 14 A. No.<br/> 15 Q. Have you ever observed Mr. Epstein<br/> 16 having a massage given by an individual, a<br/> 17 female, who was under the age of 18?<br/> 18 A. No.<br/> 19 Q. Have you ever observed females<br/> 20 under the age of 18 in the presence of<br/> 21 Jeffrey Epstein at his home?<br/> 22 MR. PAGLIUCA: Object to the form<br/> 23 and foundation.<br/> 24 A. Again, I have friends that have<br/> 25 children --</p>                                                                                                                                                                                                       | <p>Page 24</p> <p>1 G Maxwell - Confidential<br/> 2 MR. PAGLIUCA: Object to the form<br/> 3 and foundation.<br/> 4 A. How would I possibly know how<br/> 5 someone is when they are at his house. You<br/> 6 are asking me to do that. I cannot possibly<br/> 7 testify to that. As far as I'm concerned,<br/> 8 everyone who came to his house was an adult<br/> 9 professional person.<br/> 10 Q. Are you familiar with the police<br/> 11 report that was issued in respect to the<br/> 12 investigation in this matter?<br/> 13 MR. PAGLIUCA: Object to the form<br/> 14 and foundation.<br/> 15 Q. Are you familiar with the police<br/> 16 report that was used in this matter, the<br/> 17 investigation of Jeffrey Epstein, has been<br/> 18 produced as a document in this matter?<br/> 19 A. I have seen a police report.<br/> 20 (Maxwell Exhibit 1, police report,<br/> 21 marked for identification.)<br/> 22 Q. The police report that you have in<br/> 23 front of you, can you turn to page 28 of that<br/> 24 report, the numbers are on the top right-hand<br/> 25 corner.</p>                                         |
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| <p>Page 23</p> <p>1 G Maxwell - Confidential<br/> 2 Q. I'm not talking about friends. I'm<br/> 3 talking about individuals --<br/> 4 MR. PAGLIUCA: I'm going to object<br/> 5 to you interrupting the witness who was<br/> 6 answering your question. The question<br/> 7 was, have you ever seen anyone, female<br/> 8 under the age of 18 at the house and<br/> 9 that's the question she was answering.<br/> 10 If you want to strike that question and<br/> 11 ask another question, feel free, but let<br/> 12 the witness respond, please.<br/> 13 MS. McCAWLEY: I will do that.<br/> 14 Q. Have you ever observed a female<br/> 15 under the age of 18 at Jeffrey Epstein's home<br/> 16 that was not a friend, a child -- one of your<br/> 17 friend's children?<br/> 18 A. Again, I can't testify to that<br/> 19 because I have no idea what you are talking<br/> 20 about.<br/> 21 Q. You have no idea what I'm talking<br/> 22 about in the sense you never observed a<br/> 23 female under the age of 18 at Jeffrey<br/> 24 Epstein's home that was not one of your<br/> 25 friend's children, is that correct?</p> | <p>Page 25</p> <p>1 G Maxwell - Confidential<br/> 2 You will see some redactions in<br/> 3 this report, Ms. Maxwell, the redacted<br/> 4 information is redacted because it reveals<br/> 5 the name of a minor, someone who is under the<br/> 6 age of 18.<br/> 7 On page 28, in the third paragraph,<br/> 8 about halfway down, it says, [REDACTED] stated<br/> 9 she performed the massage naked. At the<br/> 10 conclusion of this massage, Epstein paid<br/> 11 [REDACTED] \$200 for the massage. He explained, I<br/> 12 know you are not comfortable put I will pay<br/> 13 you if you bring some girls. He told her the<br/> 14 younger the better. [REDACTED] stated once tried<br/> 15 to bring a 23 year old to Epstein and he<br/> 16 stated the female was too old.<br/> 17 Have you heard Mr. Epstein use the<br/> 18 phrase the younger the better?<br/> 19 A. I have no recollection of hearing<br/> 20 that.<br/> 21 Q. Have you used the phrase in talking<br/> 22 to [REDACTED] and asking her to recruit<br/> 23 females for Mr. Epstein, the younger the<br/> 24 better?<br/> 25 MR. PAGLIUCA: Object to the form</p> |

1 G Maxwell - Confidential\
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 [REDACTED] travel with you\
18 on Jeffrey's planes?\
19 A. I wouldn't remember if [REDACTED] was on\
20 the plane or not.\
21 Q. Did you ever have sex with [REDACTED]\
22 [REDACTED]?\
23 A. No.\
24 Q. Did you ever observe Jeffrey having\
25 sex with [REDACTED]?

1 G Maxwell - Confidential\
2 [REDACTED]?\
3 MR. PAGLIUCA: Object to the form\
4 and foundation.\
5 Q. Is that your testimony?\
6 A. I already said I don't recall all\
7 the times I've seen her and I have no memory\
8 of that.\
9 Q. Have you ever seen [REDACTED] in\
10 the house with Jeffrey Epstein [REDACTED]\
11 [REDACTED]\
12 MR. PAGLIUCA: Object to the form\
13 and foundation.\
14 A. I just told you I don't recall\
15 seeing [REDACTED].\
16 Q. Were you ever involved in an orgy\
17 with [REDACTED]?\
18 A. No, absolutely not.\
19 Q. Can you tell me, do you know an\
20 individual by the name of [REDACTED]?\
21 A. I do.\
22 Q. How did you meet [REDACTED]?\
23 A. At some point she was a friend of\
24 Jeffrey's and I recall meeting her at some\
25 point.

1 G Maxwell - Confidential\
2 A. No.\
3 Q. Were you aware that Jeffrey was\
4 having sexual contact with [REDACTED] 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 [REDACTED]\
11 [REDACTED] 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 [REDACTED]?\
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 [REDACTED]\
23 [REDACTED] I don't understand what your\
24 question is asking.\
25 Q. So you have never seen [REDACTED]

1 G Maxwell - Confidential\
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\
5 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 [REDACTED] doing?\
15 MR. PAGLIUCA: Object to the form\
16 and foundation.\
17 A. I have no idea what Nadia\
18 [REDACTED] was doing. I didn't hire her and\
19 I don't know what you are referring to.\
20 Q. You met [REDACTED]?\
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 [REDACTED]\
25 [REDACTED]?

Page 46

1 G Maxwell - Confidential

2 Q. Did Jeffrey arrange for a visa for

3 [REDACTED]?

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

5 cannot testify what Jeffrey did.

6 Q. Was Nadia 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 Nadia 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 Nadia 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 Nadia?

23 A. No.

24 Q. Is she a pilot?

25 A. I have no idea.

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1 G Maxwell - Confidential

2 Q. Does she fly with Larry Veseski

3 (phonetic), one of Jeffrey's pilots?

4 A. I have no idea.

5 Q. Are you a pilot?

6 A. I am.

7 Q. Have you flown with Jeffrey Veseki?

8 A. I have.

9 Q. Have you flown with Nadia

10 [REDACTED]?

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 [REDACTED]?

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

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1 G Maxwell - Confidential

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 [REDACTED] did.

18 Q. So you never observed [REDACTED]

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 [REDACTED]

Page 49

1 G Maxwell - Confidential

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 [REDACTED] 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 [REDACTED]?

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?

Page 54

1 G Maxwell - Confidential

2 A. I have.

3 Q. No, you haven't.

4 A. Yes, I have.

5 Q. You are refusing to answer the

6 question.

7 A. Let's move on.

8 Q. I'm in charge of the deposition. I

9 say when we move on and when we don't.

10 You are here to respond to my

11 questions. If you are refusing to answer the

12 court will bring you back for another

13 deposition to answer these questions.

14 Do you understand that?

15 MR. PAGLIUCA: You don't need to

16 threaten the witness.

17 MS. MCCAWLEY: I'm not threatening

18 her. I'm making sure the record is

19 clear.

20 MR. PAGLIUCA: Certainly can you

21 apply to have someone come back and the

22 court may or may not have her come back

23 again.

24 Again, she is not answering

25 questions that relate to adult consent

Page 55

1 G Maxwell - Confidential

2 sex acts. Period. And that's the

3 instruction and we can take it up with

4 the court.

5 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 [REDACTED]?

19 A. I am [REDACTED].

20 Q. Has [REDACTED] given a statement

21 to police about you performing sexual acts on

22 her?

23 A. I have not heard that.

24 Q. Has [REDACTED] given a statement

25 to police about Jeffrey Epstein performing

Page 56

1 G Maxwell - Confidential

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] had a sister and her

8 sister introduced [REDACTED], I believe, to

9 Jeffrey.

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

Page 57

1 G Maxwell - Confidential

2 asked and answered already.

3 Q. You can answer the question.

4 A. I have no idea what [REDACTED]

5 did.

6 Q. You never observed [REDACTED]

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 Glenn [REDACTED]?

13 A. I do.

14 Q. What is your relationship with

15 Glenn [REDACTED]?

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 Eva [REDACTED].

22 Q. Is Eva [REDACTED] one of your friends?

23 A. Yes.

24 Q. Did you ever send [REDACTED] to

25 Glenn's condo at the Breakers to give him a

Page 58

1 G Maxwell - Confidential\
2 massage?\
3 MR. PAGLIUCA: Objection to the\
4 form and foundation.\
5 A. No.\
6 Q. Did you ever instruct [REDACTED]\
7 [REDACTED] to have sex with Glenn?\
8 MR. PAGLIUCA: Objection to the\
9 form and foundation.\
10 A. I have never instructed [REDACTED] to\
11 have sex with anybody ever.\
12 Q. How old was Eva [REDACTED] 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,

Page 59

1 G Maxwell - Confidential\
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 [REDACTED] when\
8 did you first meet [REDACTED]?\
9 A. I don't recall the exact date.\
10 Q. Did you hire [REDACTED]?\
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 [REDACTED]?\
22 A. I don't recall the exact interview,\
23 no.\
24 Q. Do you know what tasks [REDACTED] was\
25 hired to performance?

Page 60

1 G Maxwell - Confidential\
2 A. She was tasked to answer\
3 telephones.\
4 Q. Did you ever ask her to rub\
5 Jeffrey's feet?\
6 MR. PAGLIUCA: Objection to the\
7 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 [REDACTED] 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 around 7, 8, \$9 and as a professional\
20 healthcare provider you can earn somewhere\
21 between as we have established 100 to \$200\
22 and to be able to travel and have a job that\
23 pays that is a wonderful job opportunity. So\
24 in the context of advising people for\
25 opportunities for work, it is possible that I

Page 61

1 G Maxwell - Confidential\
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 Q. Did you ever have [REDACTED] massage\
10 you?\
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. Did you ever instruct [REDACTED] to\
17 massage Glenn [REDACTED]?\
18 A. I don't believe -- I have no\
19 recollection of it.\
20 Q. Did you ever have sexual contact\
21 with [REDACTED]?\
22 MR. PAGLIUCA: Object to the form\
23 and foundation. You need to give me an\
24 opportunity to get in between the\
25 questions.

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1 G Maxwell - Confidential

2 Anything that involves consensual

3 sex on your part, I'm instructing you

4 not to answer.

5 Q. Did you ever have sexual contact

6 with [REDACTED]?

7 A. Again, she is an adult --

8 Q. I'm asking you, did you ever have

9 sexual contact with [REDACTED]?

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 [REDACTED] that was not consensual on

16 [REDACTED] part?

17 MR. PAGLIUCA: You can answer

18 nonconsensual.

19 A. I've never had nonconsensual sex

20 with anybody.

21 Q. Not [REDACTED]?

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.

Page 63

1 G Maxwell - Confidential

2 Q. So if [REDACTED] 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 [REDACTED] to Prince

10 Andrew?

11 MR. PAGLIUCA: Objection to the

12 form and foundation.

13 A. I've, again, read that [REDACTED]

14 claimed that she met or that she said she met

15 Prince Andrew. 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 [REDACTED]?

19 A. I do.

20 Q. How do you know her?

21 A. [REDACTED] was my assistant.

22 Q. So she worked for you?

23 A. Yes.

24 Q. Did you hire her?

25 A. Again, Jeffrey hired people.

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1 G Maxwell - Confidential

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 [REDACTED] 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 [REDACTED] 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, [REDACTED] and yourself?

18 A. We already --

19 Q. Were you involved with sex between

20 Jeffrey, [REDACTED] and yourself?

21 MR. PAGLIUCA: Everyone is talking

22 over each other. You heard the

23 question.

24 Again, you know what the

25 instruction is. If there is any

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1 G Maxwell - Confidential

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 [REDACTED] and yourself when [REDACTED] 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 [REDACTED] 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.

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1 G Maxwell - Confidential\
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

Page 79

1 G Maxwell - Confidential\
2 four or five?\
3 MR. PAGLIUCA: Objection to the\
4 form and foundation.\
5 A. When I was present at the house, I\
6 never saw something like that.\
7 Q. Do you know if [REDACTED] 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 [REDACTED] made with Jeffrey.\
14 Q. When [REDACTED] was in New York,\
15 would [REDACTED] 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 [REDACTED] in New York?\
23 MR. PAGLIUCA: Objection to the\
24 form and foundation.\
25 A. I would barely recollect her at

Page 80

1 G Maxwell - Confidential\
2 all, except for this story.\
3 Q. Do you recall [REDACTED]\
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 A. That's the sort of memory you would\
16 recall.\
17 Q. Do you recall, you said you don't\
18 remember her being at the New York mansion.\
19 When you were in New York would you stay at\
20 the New York mansion with Jeffrey?\
21 A. I stayed from time to time.\
22 Q. Do you recall [REDACTED] being at the\
23 New York mansion when Prince Andrew came to\
24 visit?\
25 MR. PAGLIUCA: Objection to the

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1 G Maxwell - Confidential\
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 [REDACTED] 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 [REDACTED] stay in the homes with him?\
19 A. I don't recall her staying in the\
20 houses.\
21 Q. Did you train [REDACTED] on how to\
22 recruit other girls for massages?\
23 MR. PAGLIUCA: Objection to the\
24 form and foundation.\
25 A. No.

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1 G Maxwell - Confidential

2 Q. Did you train [REDACTED] on how to

3 recruit other girls to perform sexual

4 massages?

5 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

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1 G Maxwell - Confidential

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

Page 84

1 G Maxwell - Confidential

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.

Page 85

1 G Maxwell - Confidential

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 [REDACTED] stamped [REDACTED] 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?

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1 G Maxwell - Confidential

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

5 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

Page 95

1 G Maxwell - Confidential

2 took place. I cannot testify to an actual

3 conversation or language that I used with

4 anybody at any time.

5 Q. Have you ever said to anybody that

6 you recruit other females over the age of 18

7 to take the pressure off you to having to

8 have sex with Jeffrey?

9 A. I totally resent and find it

10 disgusting that you use the word recruit. I

11 already told you I don't know what you are

12 saying about that and your implication is

13 repulsive.

14 Q. Answer my question.

15 A. I just did.

16 Q. Have you ever said to anybody that

17 you recruit females --

18 A. I don't recruit anybody.

19 Q. That's an answer. So you never

20 said that?

21 A. I'm testifying that I cannot

22 testify to an actual language --

23 Q. It's a yes or no.

24 A. I will not testify to an actual

25 statement made 17 years ago, so I cannot

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1 G Maxwell - Confidential

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.

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1 G Maxwell - Confidential

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

| <p>Page 98</p> <p>1 G Maxwell - Confidential<br/> 2 that was underage in London specifically to<br/> 3 provide a massage to Jeffrey, is that your<br/> 4 question?<br/> 5 Q. Yes.<br/> 6 A. No.<br/> 7 Q. Do you know who Alexander [REDACTED] is?<br/> 8 A. I don't recall her right now.<br/> 9 Q. Do you know if -- strike that.<br/> 10 During the time that you were<br/> 11 working for Jeffrey, did you ever observe any<br/> 12 foreign females, so in other words, not from<br/> 13 the United States, that were brought to<br/> 14 Jeffrey's home to perform massages?<br/> 15 MR. PAGLIUCA: Objection to the<br/> 16 form and foundation.<br/> 17 A. Females, what age are we talking?<br/> 18 Q. Any age.<br/> 19 A. Can you repeat the question?<br/> 20 Q. During the time you were working<br/> 21 for Jeffrey, did you ever observe any foreign<br/> 22 females of any age that were at Jeffrey's<br/> 23 home to perform a massage?<br/> 24 MR. PAGLIUCA: Objection to the<br/> 25 form and foundation.</p> | <p>Page 100</p> <p>1 G Maxwell - Confidential<br/> 2 form and foundation.<br/> 3 A. I already testified about not<br/> 4 knowing about underage girls.<br/> 5 Q. Did you provide any assistance with<br/> 6 obtaining visas for foreign girls that were<br/> 7 under the age of 18?<br/> 8 A. I've never participated in helping<br/> 9 people of any age to get visas.<br/> 10 Q. Did Jeffrey, was it Jeffrey's<br/> 11 preference to start a massage with sex?<br/> 12 MR. PAGLIUCA: Objection to the<br/> 13 form and foundation.<br/> 14 A. I think you should ask that<br/> 15 question of Jeffrey.<br/> 16 Q. Do you know?<br/> 17 A. I don't believe that was his<br/> 18 preference. I think -- you have to<br/> 19 understand, a massage -- perhaps you are not<br/> 20 really familiar with what massage is.<br/> 21 Q. I am, I don't need a lecture on<br/> 22 massage.<br/> 23 A. I think you do.<br/> 24 MR. PAGLIUCA: No question pending.<br/> 25 She will ask you another question now.</p> |
| ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| <p>Page 99</p> <p>1 G Maxwell - Confidential<br/> 2 A. Are you asking me if any foreigner,<br/> 3 not an American person, gave Jeffrey a<br/> 4 massage?<br/> 5 Q. Yes.<br/> 6 A. Well, as I sit here today, I can't<br/> 7 think of anyone who is foreign. Certainly --<br/> 8 I just can't think of anybody right this<br/> 9 second.<br/> 10 Q. How about any foreign girls who<br/> 11 were under the age of 18?<br/> 12 A. I already testified to not knowing<br/> 13 anything about underage girls.<br/> 14 Q. Were there foreign girls who were<br/> 15 brought to Jeffrey's home by Jean Luc Brunel<br/> 16 for the purposes of providing massages?<br/> 17 MR. PAGLIUCA: Objection to the<br/> 18 form and foundation.<br/> 19 A. I am not aware of Jean Luc bringing<br/> 20 girls. I have not no idea what you are<br/> 21 talking about.<br/> 22 Q. You have never been around foreign<br/> 23 girls who are under the age of 18 at<br/> 24 Jeffrey's homes?<br/> 25 MR. PAGLIUCA: Objection to the</p>          | <p>Page 101</p> <p>1 G Maxwell - Confidential<br/> 2 A. Massage is for health benefits.<br/> 3 Q. When did you first meet Jeffrey?<br/> 4 A. Some point in 1991.<br/> 5 Q. And did Jeffrey know your father?<br/> 6 A. No.<br/> 7 Q. How were you introduced to Jeffrey?<br/> 8 A. Some friend introduced us.<br/> 9 Q. Can you describe your relationship<br/> 10 back in 1991, was it friendship or was it<br/> 11 girlfriend relationship or was it a work<br/> 12 relationship, what was your relationship in<br/> 13 1991?<br/> 14 A. It was just friendly.<br/> 15 Q. Then I believe you testified you<br/> 16 began working for him in 1992, is that<br/> 17 correct?<br/> 18 A. Yes.<br/> 19 Q. In 1992 I know you gave me the<br/> 20 description of the work that you were<br/> 21 performing for him, how much was he paying<br/> 22 you, do you remember?<br/> 23 A. I don't recall.<br/> 24 Q. Do you know for example in 2001 how<br/> 25 much he was paying you?</p>                         |

| <p>Page 102</p> <p>1 G Maxwell - Confidential</p> <p>2 A. I don't recall.</p> <p>3 Q. Did it change over the years or did</p> <p>4 the payment remain the same?</p> <p>5 A. I believe over the course of time</p> <p>6 it increased a little bit.</p> <p>7 Q. Was that the -- was that payment</p> <p>8 the payment that -- was the payment made with</p> <p>9 respect to the jobs, the work you were</p> <p>10 performing for Jeffrey, was that your sole</p> <p>11 income at that time?</p> <p>12 MR. PAGLIUCA: I object to the</p> <p>13 form. I'm also going to instruct you</p> <p>14 not to answer about sources of -- your</p> <p>15 personal sources of income outside of</p> <p>16 Mr. Epstein at all.</p> <p>17 MS. McCAWLEY: What's the basis for</p> <p>18 that?</p> <p>19 MR. PAGLIUCA: It's confidential,</p> <p>20 it's not part of this lawsuit.</p> <p>21 MS. McCAWLEY: We have a protective</p> <p>22 order and it is part of this lawsuit</p> <p>23 with respect to our damage claims.</p> <p>24 MR. PAGLIUCA: It's not and, in</p> <p>25 fact, you are not entitled to ask</p> | <p>Page 104</p> <p>1 G Maxwell - Confidential</p> <p>2 worked for it and I had a loan, we did loans.</p> <p>3 Q. So a loan through Jeffrey?</p> <p>4 A. I don't recall the exact</p> <p>5 transaction.</p> <p>6 Q. Did he purchase for you a</p> <p>7 helicopter during the time you were working</p> <p>8 for him?</p> <p>9 A. It was his helicopter.</p> <p>10 Q. When did you obtain your pilot</p> <p>11 license?</p> <p>12 A. I believe it was '98 or '99.</p> <p>13 Q. Was that for both airplanes and</p> <p>14 helicopters or just helicopters?</p> <p>15 A. Just helicopters.</p> <p>16 Q. Have you ever flown President</p> <p>17 Clinton on your helicopter?</p> <p>18 A. That is another one of [REDACTED]</p> <p>19 lies.</p> <p>20 Q. The question is have you ever done</p> <p>21 that?</p> <p>22 A. I have never flown President</p> <p>23 Clinton at any time ever, in any helicopter,</p> <p>24 in any place, any time, in any state, in any</p> <p>25 country, at any time anywhere.</p>                                                                                                                          |
| -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| <p>Page 103</p> <p>1 G Maxwell - Confidential</p> <p>2 financial information of a defendant in</p> <p>3 this kind of case, in a defamation case</p> <p>4 unless and until there is a finding that</p> <p>5 you are entitled to punitive damages.</p> <p>6 That is clear in New York case law, both</p> <p>7 state and Federal.</p> <p>8 MS. McCAWLEY: We disagree on that</p> <p>9 point and we will come back to that.</p> <p>10 Q. From the source of payment from the</p> <p>11 source of Jeffrey, from your work, can you</p> <p>12 give me a range on that, do you know was it</p> <p>13 over \$100,000?</p> <p>14 A. I just testified I don't recall.</p> <p>15 Q. You don't don't know if it was</p> <p>16 \$500,000?</p> <p>17 A. It was less than that.</p> <p>18 Q. Somewhere between 100 and 500,</p> <p>19 would that be fair to say?</p> <p>20 A. I believe it was between 100 and</p> <p>21 \$200,000.</p> <p>22 Q. Did Jeffrey during the time that</p> <p>23 you were working for him purchase a town home</p> <p>24 for you?</p> <p>25 A. The subject of the townhouse is, I</p>     | <p>Page 105</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. Have you ever had dinner with</p> <p>3 President Clinton at Jeffrey's home, at any</p> <p>4 of Jeffrey's homes?</p> <p>5 A. No, I don't believe so.</p> <p>6 Q. Have you traveled on Jeffrey's</p> <p>7 planes with President Clinton?</p> <p>8 A. Yes, I have.</p> <p>9 Q. Would that have been in 2002?</p> <p>10 A. It's very hard for me to recollect</p> <p>11 exact dates but that sounds about right.</p> <p>12 Q. Was that during the time that</p> <p>13 [REDACTED] was working for Jeffrey?</p> <p>14 A. I don't know that [REDACTED] ever did</p> <p>15 work for Jeffrey. I don't exactly know if</p> <p>16 she testified to her so-called duties, we</p> <p>17 know she is a serial liar so I can't testify</p> <p>18 to what she did or didn't do. So I object to</p> <p>19 that characterization of her. So repeat the</p> <p>20 question, please.</p> <p>21 Q. Can you read the question back?</p> <p>22 (Record read.)</p> <p>23 Q. You can answer the question.</p> <p>24 A. What was the question again?</p> <p>25 Q. When you were traveling on the</p> |

1 G Maxwell - Confidential\
2 plane with President Clinton, was that during\
3 the time, it was 2002, that you were on a\
4 flight with Clinton, was that during the time\
5 [REDACTED] 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 [REDACTED], we know what [REDACTED] claims\
13 when she left, so I can't answer the\
14 question. I have no idea.\
15 Q. Do you know Prince Andrew?\
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?

1 G Maxwell - Confidential\
2 that he may have met socially through me.\
3 Q. Did you ever introduce Prince\
4 Andrew to [REDACTED] in London?\
5 A. I understand her story about London\
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 Prince\
12 Andrew to [REDACTED] in London?\
13 A. I have no recollection.\
14 Q. Did [REDACTED] 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 [REDACTED] 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.

1 G Maxwell - Confidential\
2 A. That would be another of [REDACTED]\
3 lies and the lies you perpetrate. I never\
4 introduced Prince Andrew to Jeffrey Epstein\
5 at any time ever, so just add that the to\
6 long list of lies.\
7 Q. Did Jeffrey know Prince Andrew?\
8 A. Clearly he knew him. I think we\
9 have that answer but how -- yeah.\
10 Q. Do you know how Jeffrey met Prince\
11 Andrew?\
12 A. I do not know Jeffrey met Prince\
13 Andrew. What I do know is that I did not\
14 introduce them. That is one of the many\
15 lies. Are we tallying all the lies?\
16 Q. Do you know when Jeffrey met Prince\
17 Andrew?\
18 A. I do not know when Jeffrey met\
19 Prince Andrew.\
20 Q. Did you ever introduce Prince\
21 Andrew to any girls under the age of 18 who\
22 were not friends of yours children?\
23 A. I have not introduced Prince Andrew\
24 to anyone that I am aware of other than\
25 friends of mine who have kids under that age

1 G Maxwell - Confidential\
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?

Page 110

1 G Maxwell - Confidential

2 A. I've looked at it.

3 Q. Are you in that picture?

4 A. I am.

5 Q. Is that Prince Andrew in the

6 picture as well?

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

Page 111

1 G Maxwell - Confidential

2 will skip ahead. Hold that until we can

3 find one that has the [REDACTED] range on it.

4 Q. Do you recall [REDACTED] being at

5 your London town home?

6 A. I do not.

7 Q. Do you recall going to dinner with

8 Prince Andrew, Jeffrey Epstein and [REDACTED]

9 [REDACTED] in London, at any time?

10 A. I do not.

11 Q. Do you recall going to a place

12 called Club Tramp with Prince Andrew, Jeffrey

13 Epstein and yourself and [REDACTED]?

14 A. I would just like to state for the

15 record that Prince Andrew is a very famous

16 person, I know you are aware because you like

17 to use him so often in your press stories --

18 please let me finish. Were he at Tramp, at

19 any time, that would be reported by the

20 press. 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 [REDACTED]

24 shopping when you were in London to buy an

25 outfit to meet Prince Andrew?

Page 112

1 G Maxwell - Confidential

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 Prince Andrew 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 Prince Andrew being

25 present in New York for a party where [REDACTED]

Page 113

1 G Maxwell - Confidential

2 [REDACTED] was also present?

3 A. I don't recollect.

4 Q. Do you recall ever giving Prince

5 Andrew 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 Andrew --

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

Page 114

1 G Maxwell - Confidential\
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 Jeffrey\
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 Prince Andrew go\
23 into a room with [REDACTED] alone in your town\
24 home?\
25 A. I cannot recall. As I have said,

Page 115

1 G Maxwell - Confidential\
2 no.\
3 Q. Did Prince Andrew ever tell you\
4 that he had sex with [REDACTED]?\
5 A. He did not.\
6 Q. Did Jeffrey Epstein ever tell you\
7 that Prince Andrew had sex with [REDACTED]\
8 [REDACTED]?\
9 A. He did not.\
10 Q. Did Prince Andrew 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 Prince Andrew ever visit that\
17 island -- are you aware of Prince Andrew ever\
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 [REDACTED] was on the island?\
25 A. I do not.

Page 116

1 G Maxwell - Confidential\
2 Q. Were you present on the island when\
3 Prince Andrew 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 [REDACTED] to have sex with John Luc Brunel?\
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

Page 117

1 G Maxwell - Confidential\
2 asked [REDACTED] or whatever she is\
3 called now to have sex with anybody.\
4 Q. Did you ever provide [REDACTED]\
5 [REDACTED] with an outfit, an outfit of a sexual\
6 nature to wear for Les Wexner?\
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 Les Wexner?\
14 A. Categorically no. You did get\
15 that, I said categorically no\
16 Q. Don't worry I'm paying attention.\
17 A. You seemed very distracted in that\
18 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.

| <p>Page 146</p> <p>1 G Maxwell - Confidential<br/> 2 one of his planes?<br/> 3 A. There was a bed on one of his<br/> 4 planes that folded out, yes.<br/> 5 Q. Do you recall whether with respect<br/> 6 to this being in Santa Fe, do you recall<br/> 7 whether you were there for some form of a<br/> 8 party?<br/> 9 MR. PAGLIUCA: Objection to the<br/> 10 form and foundation.<br/> 11 A. I don't recall the trip at all and<br/> 12 this looks like a total work trip, not a<br/> 13 party trip.<br/> 14 Q. What would be the difference<br/> 15 between a work trip and a party trip?<br/> 16 A. Just that I would be on trips for<br/> 17 work and I believe that this looks like, AP<br/> 18 looks like it's one of the -- probably one of<br/> 19 the designers and the time would meet with a<br/> 20 trip to decorate the house, just the timing<br/> 21 of it.<br/> 22 Q. So would [REDACTED] be brought on<br/> 23 trips that were for the purpose of work and<br/> 24 decorating the house?<br/> 25 A. Like I said, I never worked with</p>           | <p>Page 148</p> <p>1 G Maxwell - Confidential<br/> 2 excerpts from -- we will identify what they<br/> 3 are but from the message pads.<br/> 4 Did you want to correct anything?<br/> 5 A. I want to make an addendum.<br/> 6 Would you mind rereading the last<br/> 7 question back to me?<br/> 8 (Record read.)<br/> 9 A. I also just want to say that at<br/> 10 this point I cannot recollect flying to<br/> 11 parties. Jeffrey went for work so -- was<br/> 12 this in Santa Fe, this flight as well.<br/> 13 Q. The flight we were looking at, yes<br/> 14 but it was to Santa Fe --<br/> 15 A. I don't recall going to any parties<br/> 16 in Santa Fe at any time but certainly flying<br/> 17 to Santa Fe for a party seems highly<br/> 18 improbable.<br/> 19 Q. So I'm going to direct your<br/> 20 attention to the document that I set before<br/> 21 you which is [REDACTED] number [REDACTED] and it<br/> 22 has different [REDACTED] numbers because it's a<br/> 23 smaller version of the larger production.<br/> 24 These are the pages I will be asking about.<br/> 25 In the time that you were working</p>                       |
| ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| <p>Page 147</p> <p>1 G Maxwell - Confidential<br/> 2 her but you would have to ask Jeffrey what he<br/> 3 brought her on the trip for.<br/> 4 Q. But she would travel with him when<br/> 5 there was a work trip like this?<br/> 6 A. I can't -- I'm seeing that she is<br/> 7 on this flight but I have no idea what she is<br/> 8 doing, he invited her, it would not be my<br/> 9 job.<br/> 10 Q. What about [REDACTED] would she<br/> 11 regularly travel with Jeffrey on flights?<br/> 12 A. I have no idea, you would have to<br/> 13 look through the flight logs. I have no<br/> 14 idea.<br/> 15 Q. Your recollection is -- what is<br/> 16 your recollection, do you recollect Nadia<br/> 17 traveling often on flights with Jeffrey?<br/> 18 A. Absolutely not. No, not at all. I<br/> 19 don't recollect her actually on the flight at<br/> 20 all.<br/> 21 Q. I think you can set that aside for<br/> 22 the moment.<br/> 23 (Maxwell Exhibit 9, message pad<br/> 24 pages, marked for identification.)<br/> 25 Q. We will mark as Exhibit 9 these</p> | <p>Page 149</p> <p>1 G Maxwell - Confidential<br/> 2 with Jeffrey in Palm Beach, do you recall a<br/> 3 process for taking, anybody at the house<br/> 4 taking messages when incoming phone calls<br/> 5 came in?<br/> 6 A. You are supposed to take a message<br/> 7 and receive the message and write the message<br/> 8 down. Who was the message was for, what time<br/> 9 it was taken and who took it and what the<br/> 10 message was, obviously.<br/> 11 Q. Does what's in front of you look<br/> 12 familiar with respect to the message pads<br/> 13 that you would have used at the house?<br/> 14 A. It is familiar.<br/> 15 Q. I'm going to direct your attention<br/> 16 to the second page of it?<br/> 17 MR. PAGLIUCA: These all have SAO<br/> 18 numbers on them or [REDACTED] ranges and I<br/> 19 don't see any of your [REDACTED] ranges on<br/> 20 these. I know you have produced message<br/> 21 pads but those have your [REDACTED] range<br/> 22 numbers on them and I'm wondering if<br/> 23 these are different documents.<br/> 24 MS. McCAWLEY: It's the same, just<br/> 25 ours have the [REDACTED] underneath them.</p> |

1 G Maxwell - Confidential\
2 These were produced as part of the rule\
3 26 discovery. We can get the additional\
4 [REDACTED] if you want.\
5 Q. The one I'm asking about first is\
6 the [REDACTED]. You can look at that and then\
7 I will identify the [REDACTED] 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 [REDACTED] and then I see under the\
15 M line it looks like Necole [REDACTED] or\
16 something like that, a phone number and a\
17 message saying returning your call and on the\
18 bottom it looks like [REDACTED].\
19 Explain to me, is this -- does this\
20 represent [REDACTED] taking down a message for you\
21 from [REDACTED] 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.

1 G Maxwell - Confidential\
2 Looking at this message pad, where it says\
3 signed [REDACTED], can you tell me who [REDACTED] 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 Necole [REDACTED] is?\
15 A. I don't.\
16 Q. I'm going to direct your\
17 attention -- do we have a [REDACTED] number for\
18 that?\
19 MR. \[REDACTED\]: [REDACTED].\
20 Q. [REDACTED] for that one.\
21 I will direct your attention to the\
22 first page which has the [REDACTED] on it.\
23 A. Okay.\
24 Q. Now at the top of that document, on\
25 the right-hand side, the message that reads

1 G Maxwell - Confidential\
2 for JE, date 1/02/03, message Caroline [REDACTED]\
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?

1 G Maxwell - Confidential\
2 A. They were supposed to take a\
3 message and the time and date and give the\
4 message.\
5 Q. Were they supposed to indicate who\
6 took the message?\
7 A. They were but it wasn't -- I don't\
8 really recall the actual process. I can see\
9 from here it looks like you were supposed to\
10 but that's not my handwriting so I can't say\
11 what that was.\
12 Q. Do you know who Caroline [REDACTED] is?\
13 A. No, I don't.\
14 Q. Do you know whether Caroline [REDACTED]\
15 was under the age of 18?\
16 A. I just testified I couldn't\
17 remember who she was so it would be difficult\
18 to know how old she was.\
19 Q. Do you know if she was coming to\
20 the house to provide massages?\
21 A. I don't remember who she is at all,\
22 so no.\
23 Q. And then I would like to direct\
24 your attention to the message right\
25 underneath it. Which says JE. [REDACTED]

Page 154

1 G Maxwell - Confidential\
2 and has a phone number and the message says,\
3 wants to know if she should bring her friend\
4 [REDACTED] 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

Page 155

1 G Maxwell - Confidential\
2 messages, very, very, very, very\
3 infrequently.\
4 Q. Do you know if [REDACTED] brought her\
5 friend [REDACTED] 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 [REDACTED] is, I don't know who\
11 [REDACTED] 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.

Page 156

1 G Maxwell - Confidential\
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 [REDACTED]\
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 [REDACTED], 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.

Page 157

1 G Maxwell - Confidential\
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 [REDACTED].\
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.\
25 [REDACTED].

1 G Maxwell - Confidential\
2 A. Yes.\
3 MR. \[REDACTED\]: [REDACTED].\
4 Q. I'm going to direct your attention\
5 to the top right-hand corner, for Mr.\
6 Epstein, [REDACTED], message [REDACTED], a phone\
7 number and called.\
8 Do you know who [REDACTED] is?\
9 A. I don't.\
10 Q. Do you know that [REDACTED] 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 [REDACTED] 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 Jean Luc 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 Jean Luc 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 Jean Luc is

1 G Maxwell - Confidential\
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.

1 G Maxwell - Confidential\
2 referring to.\
3 Q. Do you know if Jean Luc 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 Jean Luc\
10 ever tell you that Jean Luc 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 [REDACTED] number?\
23 Q. The bottom right-hand corner, Mr.\
24 Epstein, the date [REDACTED], Ms. Maxwell, it\
25 says, [REDACTED], it says, quote, [REDACTED] is

1 G Maxwell - Confidential\
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. [REDACTED] is 15.\
10 A. I don't know who [REDACTED] is, so I\
11 can't testify anything to [REDACTED].\
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 [REDACTED] to have\
22 his friend [REDACTED] come over on Tuesday of\
23 this week?\
24 A. I don't know who [REDACTED] is so it\
25 would be hard for me to arrange anything with

| <p>Page 162</p> <p>1 G Maxwell - Confidential<br/> 2 someone I don't know.<br/> 3 Q. Why is your name reflected on this<br/> 4 message pad?<br/> 5 MR. PAGLIUCA: Objection to the<br/> 6 form and foundation.<br/> 7 A. I have no idea. You would have to<br/> 8 ask whoever took the message.<br/> 9 Q. Did you, in the course of your<br/> 10 work, regularly take messages for Jeffrey<br/> 11 Epstein?<br/> 12 A. I already testified I hardly ever<br/> 13 did.<br/> 14 Q. Would you, in the course of your<br/> 15 work, regularly set up appointments for<br/> 16 females to come over and give massages for<br/> 17 Jeffrey Epstein?<br/> 18 MR. PAGLIUCA: Objection to the<br/> 19 form and foundation.<br/> 20 A. Can you specify, females, you mean<br/> 21 adults over the age of 18.<br/> 22 Q. Did you regularly set up for<br/> 23 Jeffrey adults over the age of 18 to come for<br/> 24 massages?<br/> 25 A. I didn't regularly do that, no.</p>                                                                                          | <p>Page 164</p> <p>1 G Maxwell - Confidential<br/> 2 messages, I don't know about how I would<br/> 3 possibly know if somebody I spoke to, one or<br/> 4 two times I took a message is, how old they<br/> 5 would be but I have never taken a message<br/> 6 where I was aware of anything being under the<br/> 7 age of 18 and I probably took it so<br/> 8 infrequently, it would be impossible.<br/> 9 Q. Can you turn to [REDACTED] it<br/> 10 should be the next page.<br/> 11 A. Uh-huh.<br/> 12 Q. Do you see at the top, it says, for<br/> 13 Mr. J. 11/8/04 and then the name is<br/> 14 redacted. It says, I have a female for him.<br/> 15 Why would a minor be calling<br/> 16 Jeffrey to say they have a female for him?<br/> 17 Do you know?<br/> 18 MR. PAGLIUCA: Objection to the<br/> 19 form and foundation.<br/> 20 A. First of all, I don't know that's a<br/> 21 minor, I don't know who took the message.<br/> 22 Q. I will represent to you these are<br/> 23 police reports and minor's names have to be<br/> 24 redacted for privacy purposes?<br/> 25 MR. PAGLIUCA: Objection to the</p> |
| --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| <p>Page 163</p> <p>1 G Maxwell - Confidential<br/> 2 Q. Would you take messages with<br/> 3 respect to females over the age of 18 to come<br/> 4 over for a massage?<br/> 5 A. I already testified I hardly ever<br/> 6 did take messages.<br/> 7 Q. But would you?<br/> 8 A. I already testified, I hardly<br/> 9 ever --<br/> 10 Q. I know hardly ever, but did you?<br/> 11 A. Over the course of time it is<br/> 12 possible I may have taken a couple, I have no<br/> 13 recollection. I hardly ever did and I did so<br/> 14 irregularly that it would hard for me to<br/> 15 pinpoint.<br/> 16 Q. Did you ever take a message for a<br/> 17 female under the age of 18 to come over for a<br/> 18 massage or for any other reason to be with<br/> 19 Jeffrey Epstein?<br/> 20 MR. PAGLIUCA: Object to the form<br/> 21 and foundation.<br/> 22 A. I hardly ever took a message. I<br/> 23 have absolutely no way of knowing, maybe one<br/> 24 of my friends' daughters called to say they<br/> 25 were coming to visit me. I have never taken</p> | <p>Page 165</p> <p>1 G Maxwell - Confidential<br/> 2 form and foundation.<br/> 3 Q. Do you know why a minor child would<br/> 4 be calling Jeffrey and leaving a message to<br/> 5 say, quote, I have a female for him?<br/> 6 MR. PAGLIUCA: Objection to the<br/> 7 form and foundation.<br/> 8 A. I can't testify anything about this<br/> 9 message, I don't know anything about it.<br/> 10 Q. I'm going to direct your attention<br/> 11 to the next page [REDACTED]. If you look at<br/> 12 the bottom left, you are going to see a<br/> 13 message for Jeffrey, from [REDACTED], it<br/> 14 says she doesn't have a number and left a<br/> 15 message that she called.<br/> 16 Do you know who [REDACTED] is?<br/> 17 A. I do not.<br/> 18 Q. Do you know that [REDACTED] was<br/> 19 13 at the time she placed this call to<br/> 20 Jeffrey?<br/> 21 A. I don't know who [REDACTED] is.<br/> 22 Q. Would Jeffrey regularly have 13<br/> 23 year olds call and leave messages?<br/> 24 MR. PAGLIUCA: Objection to the<br/> 25 form and foundation.</p>                                                       |

| <p>Page 166</p> <p>1 G Maxwell - Confidential</p> <p>2 A. How would I possibly, these were</p> <p>3 messages taken when I was not at the house</p> <p>4 and I have no idea who they are nor how old</p> <p>5 they are nor anything.</p> <p>6 Q. How do you know you weren't at the</p> <p>7 house on this day?</p> <p>8 A. I was hardly at the house in 2005.</p> <p>9 Q. So you could have been there, you</p> <p>10 just don't know?</p> <p>11 A. In the five days I might have been</p> <p>12 there in 2005, I suppose it's possible but</p> <p>13 it's unlikely.</p> <p>14 MR. PAGLIUCA: Do you know why this</p> <p>15 isn't redacted if you are representing</p> <p>16 all the names of people who are underage</p> <p>17 have been redacted from these records.</p> <p>18 MS. McCAWLEY: I think it was -- my</p> <p>19 assumption is it was a miss by the</p> <p>20 police department.</p> <p>21 Q. I will direct your attention to [REDACTED]</p> <p>22 [REDACTED] so you will skip a page and go back,</p> <p>23 it's the final page in the message pads and</p> <p>24 you will see on the top left for Jeffrey, on</p> <p>25 6/1/2005 from Jean Luc Brunel with a phone</p> | <p>Page 168</p> <p>1 G Maxwell - Confidential</p> <p>2 off the record.</p> <p>3 (Recess.)</p> <p>4 A F T E R N O O N S E S S I O N</p> <p>5 (Time noted: 1:21 p.m.)</p> <p>6 G H I S L A I N E M A X W E L L,</p> <p>7 resumed and testified as follows:</p> <p>8 EXAMINATION BY (Cont'd.)</p> <p>9 MS. McCAWLEY:</p> <p>10 THE VIDEOGRAPHER: It's now 1:21,</p> <p>11 we're starting disk No. 4. We are back</p> <p>12 on the record.</p> <p>13 Q. Ms. Maxwell, before the break, we</p> <p>14 were talking about and I think it's one of</p> <p>15 the exhibits that's marked in front of you,</p> <p>16 I'm not sure of the number, but the police</p> <p>17 report that I showed you earlier today.</p> <p>18 Now that you have knowledge of the</p> <p>19 police report and the criminal investigation</p> <p>20 with respect to Jeffrey Epstein, do you</p> <p>21 believe that Jeffrey Epstein abused any minor</p> <p>22 children?</p> <p>23 MR. PAGLIUCA: Objection to the</p> <p>24 form and foundation.</p> <p>25 A. Can you repeat the question please</p> |
| ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| <p>Page 167</p> <p>1 G Maxwell - Confidential</p> <p>2 number. It says, quote, He has a teacher for</p> <p>3 you to teach you how to speak Russian. She</p> <p>4 is two times eight years old. Not blond.</p> <p>5 Lessons are free and you can have your first</p> <p>6 today if you call.</p> <p>7 Do you know whether Jean Luc Brunel</p> <p>8 sent a Russian girl that was 16 years old</p> <p>9 over to Jeffrey Epstein's home?</p> <p>10 MR. PAGLIUCA: Objection to the</p> <p>11 form and foundation.</p> <p>12 A. I do not know.</p> <p>13 Q. Did you ever observe a Russian girl</p> <p>14 that was 16 years old come to Jeffrey</p> <p>15 Epstein's home?</p> <p>16 A. I am not aware of any 16 year old</p> <p>17 Russian girl that I can recall in Jeffrey</p> <p>18 Epstein's home.</p> <p>19 Q. Do you know whether Jeffrey Epstein</p> <p>20 had sex with a 16 year old Russian girl?</p> <p>21 MR. PAGLIUCA: Objection to the</p> <p>22 form and foundation.</p> <p>23 A. I do not know.</p> <p>24 THE VIDEOGRAPHER: It's 12:25.</p> <p>25 This will be the end of disk 3, we are</p>                                                                                 | <p>Page 169</p> <p>1 G Maxwell - Confidential</p> <p>2 and break it down so it's more</p> <p>3 understandable.</p> <p>4 Q. Now that you have the police report</p> <p>5 that I showed you this morning that you had</p> <p>6 an opportunity to look at.</p> <p>7 A. You gave it to me, I did not look</p> <p>8 at it.</p> <p>9 Q. The questions that I asked you</p> <p>10 about the police report -- you are aware</p> <p>11 there is a police report?</p> <p>12 A. I am aware there is a police</p> <p>13 report.</p> <p>14 Q. You are aware there was a criminal</p> <p>15 investigation of Jeffrey Epstein?</p> <p>16 A. I am aware that there was that.</p> <p>17 Q. Now that you are aware of those two</p> <p>18 things and having talked to Jeffrey Epstein,</p> <p>19 do you believe Jeffrey Epstein sexually</p> <p>20 abused minors?</p> <p>21 MR. PAGLIUCA: Objection to the</p> <p>22 form and foundation.</p> <p>23 A. Can you reask the second part of</p> <p>24 that question please.</p> <p>25 Q. Sure. The two documents we were</p>                |

1 G Maxwell - Confidential\
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 [REDACTED] 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.

1 G Maxwell - Confidential

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

1 G Maxwell - Confidential

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.

1 G Maxwell - Confidential

2 A. I would like to answer your\
3 questions but you are not asking me a\
4 question that I can answer.

5 Q. What about that is causing you\
6 pause where you can't answer the question?

7 A. You are trying to trap me and\
8 that's not fair, so I already testified that\
9 I hire people across the board, so I would\
10 hire architects, decorators, pool people,\
11 exercise instructors, gardeners, cooks,\
12 chefs, cleaning people. So I, in the course\
13 of a very long time when I would hire people\
14 I hired people to work for Jeffrey. So I'm\
15 happy to testify to hiring people for every\
16 possible conceivable proper job that you\
17 could conceive of within the context of\
18 Jeffrey's life and homes.

19 Q. Is it a lie that you approached\
20 females to bring them to Jeffrey Epstein for\
21 the purpose of performing massages?

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

24 A. Again, I have already testified\
25 that part of the job that I had was to hire

| <p>Page 250</p> <p>1 G Maxwell - Confidential<br/> 2 agree to that?<br/> 3 MR. PAGLIUCA: Objection to the<br/> 4 form and foundation.<br/> 5 Q. Are they under the age of 18?<br/> 6 A. We already established that you can<br/> 7 be a masseuse in Florida at age 17. That<br/> 8 does not make it inappropriate.<br/> 9 A. I'm not saying appropriate or<br/> 10 inappropriate. I'm just asking if there were<br/> 11 any exercise instructors that were under the<br/> 12 age of 18.<br/> 13 A. I am not aware if anybody was but I<br/> 14 don't want to full out and say you █ she<br/> 15 said, we already established you can be a 17<br/> 16 year old masseuse and have it not be<br/> 17 something that is not appropriate. So when<br/> 18 you say that and then you go, well, you come<br/> 19 back and say something, now we can establish<br/> 20 that █ was 17 but you can be a 17 year<br/> 21 old legal masseuse, but I am not aware to<br/> 22 your point.<br/> 23 Q. Who were the other 17 year old<br/> 24 masseuses that you were aware of?<br/> 25 A. I am not aware of any.</p> | <p>Page 252</p> <p>1 G Maxwell - Confidential<br/> 2 Epstein had a sexual preference for underage<br/> 3 minors?<br/> 4 MR. PAGLIUCA: Object to the form<br/> 5 and foundation.<br/> 6 A. I cannot testify to what<br/> 7 Jeffrey's --<br/> 8 Q. You don't know his preference?<br/> 9 A. You handed me a stack of papers<br/> 10 from the police reports and that's what I've<br/> 11 read but I have no knowledge, direct<br/> 12 knowledge, of what you are referencing.<br/> 13 Q. So you don't know, you don't know<br/> 14 in your own mind that Jeffrey Epstein had a<br/> 15 sexual preference for underage minors, is<br/> 16 that correct?<br/> 17 MR. PAGLIUCA: Objection to the<br/> 18 form and foundation.<br/> 19 Q. Is that correct?<br/> 20 A. Please ask the question again.<br/> 21 Q. You don't know in your own mind<br/> 22 that Jeffrey Epstein had a sexual preference<br/> 23 for underage minors?<br/> 24 MR. PAGLIUCA: Objection to the<br/> 25 form and foundation. You have to pause,</p> |
| ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| <p>Page 251</p> <p>1 G Maxwell - Confidential<br/> 2 Q. Were there any 16 year old<br/> 3 masseuse that you are aware of?<br/> 4 A. I am not aware.<br/> 5 Q. Any 15?<br/> 6 A. I just want to be clear. The only<br/> 7 person that I am aware of who claims to have<br/> 8 been a -- we have to -- we established<br/> 9 █ now is 17, given she has changed her<br/> 10 age so many times. The only person that I am<br/> 11 aware of that was a masseuse at the time when<br/> 12 I was present in the house was █.<br/> 13 Q. Is it an obvious lie that Jeffrey<br/> 14 Epstein had a sexual preference for underage<br/> 15 minors?<br/> 16 MR. PAGLIUCA: Objection to the<br/> 17 form and foundation.<br/> 18 A. Can you ask the question again?<br/> 19 Q. It is it an obvious lie that<br/> 20 Jeffrey Epstein had a sexual preference for<br/> 21 underage minors?<br/> 22 MR. PAGLIUCA: Objection to the<br/> 23 form and foundation.<br/> 24 A. Can you ask the question again?<br/> 25 Q. Is it an obvious lie that Jeffrey</p>                                                          | <p>Page 253</p> <p>1 G Maxwell - Confidential<br/> 2 let me object, answer the question.<br/> 3 Listen to her question, pause, I object,<br/> 4 you answer.<br/> 5 Q. So you don't know in your own mind<br/> 6 that Jeffrey Epstein had a sexual preference<br/> 7 for underage minors?<br/> 8 MR. PAGLIUCA: Objection to the<br/> 9 form and foundation.<br/> 10 Q. You can answer.<br/> 11 A. I cannot tell you what Jeffrey's<br/> 12 story is. I'm not able to.<br/> 13 Q. Did Jeffrey Epstein have a scheme<br/> 14 to recruit underage girls to use them for<br/> 15 purposes of sexual massages?<br/> 16 MR. PAGLIUCA: Objection to the<br/> 17 form and foundation.<br/> 18 A. Can you ask me again, please?<br/> 19 Q. Did Jeffrey Epstein have a scheme<br/> 20 to recruit underage girls to recruit them for<br/> 21 sexual massages?<br/> 22 MR. PAGLIUCA: Objection to the<br/> 23 form and foundation.<br/> 24 A. Can you ask it a different way?<br/> 25 Q. Did Jeffrey Epstein have a scheme</p>      |

1 G Maxwell - Confidential\
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 [REDACTED]\
10 [REDACTED] 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 [REDACTED] 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 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 [REDACTED] 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 [REDACTED]\
23 being sent to Thailand.\
24 But may I say something?\
25 Q. There is not a question pending

1 G Maxwell - Confidential\
2 assistants, I think earlier you mentioned, we\
3 talked about [REDACTED] who worked in the\
4 role as an assistant or [REDACTED]\
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 [REDACTED] [REDACTED] 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?

1 G Maxwell - Confidential\
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 [REDACTED]\
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 [REDACTED]\
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 [REDACTED] 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

1 G Maxwell - Confidential\
2 can see the dates.\
3 MR. PAGLIUCA: Can you identify a\
4 [REDACTED] number, please.\
5 Q. [REDACTED], which was at the top says,\
6 [REDACTED]. 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 [REDACTED].\
16 MR. PAGLIUCA: Hang on one second.\
17 A. Can you repeat the number please.\
18 Q. [REDACTED]. And if you will look on\
19 that page at the entry, under [REDACTED]\
20 [REDACTED] starting with the [REDACTED] and then it runs\
21 down to the, looks like the [REDACTED], that first\
22 entry has President Clinton, Kevin Spacey,\
23 Chris Tucker, Jeffrey Epstein and the\
24 initials GM.\
25 Do you remember taking a trip with

1 G Maxwell - Confidential\
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 President Clinton at the same time this\
10 document reflects [REDACTED] 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 [REDACTED]?\
19 A. [REDACTED].\
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.

1 G Maxwell - Confidential\
2 President Clinton during September of 2002?\
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 President Clinton during September of 2002,\
9 that's the 21st, it looks like, through the\
10 27th?\
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 President Clinton at the same\
16 time [REDACTED] 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 September 27 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 President Clinton?

1 G Maxwell - Confidential\
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 [REDACTED]\
8 [REDACTED] 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 [REDACTED] 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 [REDACTED] 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 [REDACTED] do for you?

Page 286

1 G Maxwell - Confidential

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 Prince Andrew, I asked you whether you had

25 ever given him a gift of a puppet.

Page 287

1 G Maxwell - Confidential

2 Did you ever, not as a gift, did

3 you ever see in the presence of Prince Andrew

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 Prince Andrew 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 Prince

17 Andrew 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

Page 288

1 G Maxwell - Confidential

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 Prince Andrew?

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 Prince Andrew?

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

Page 289

1 G Maxwell - Confidential

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 Prince

13 Andrew in Jeffrey Epstein's home?

14 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 Prince Andrew that was

23 in Jeffrey's home.

24 Q. Did you use that caricature to put

25 the hand of the caricature on [REDACTED]

1 G Maxwell - Confidential\
2 [REDACTED] 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 Andrew.

10 Q. Do you recollect asking [REDACTED]\
11 [REDACTED] to sit on Prince Andrew's lap with\
12 the caricature of Prince Andrew?

13 A. I do not recollect that.

14 Q. What do you remember about the\
15 caricature of the Prince Andrew caricature\
16 when you were in the presence of Prince

17 Andrew, [REDACTED] and [REDACTED]?

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

20 A. I don't recollect the story as told\
21 by [REDACTED] or [REDACTED]. I don't even know\
22 who -- I remember the caricature of Prince\
23 Andrew and I remember Prince Andrew but I\
24 don't recall anything else around the\
25 caricature.

1 G Maxwell - Confidential\
2 Q. Did you give it to him?

3 A. I did not.

4 Q. Who gave it to him?

5 A. I don't think it was given to him\
6 at all.

7 Q. Did he bring it?

8 A. No.

9 Q. Was it something that was at the\
10 house?

11 A. As best I recollect.

12 Q. Was it something that you saw at\
13 the house in advance of Prince Andrew's\
14 arrival?

15 A. Again, I don't real -- I recollect\
16 the caricature, I recollect Prince Andrew, I\
17 don't recollect much else around the\
18 caricature.

19 Q. Was there a party going on in the\
20 house at the time you recollect the\
21 caricature?

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

24 A. You have to be way more specific?

25 Q. Do you remember, you said you

1 G Maxwell - Confidential\
2 recollect this caricature, you recollect\
3 Prince Andrew being there. Do you recollect\
4 a party going on at the time of that\
5 interaction with Prince Andrew 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 Prince Andrew was there\
16 with this caricature?

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

19 A. I only recollect myself with Prince\
20 Andrew, 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 [REDACTED]\
25 being there?

1 G Maxwell - Confidential

2 A. No.

3 Q. You don't recollect [REDACTED]\
4 [REDACTED] being there?

5 A. No.

6 Q. It was just you and Prince Andrew?

7 A. I am not saying it was just me and\
8 Prince Andrew, you are asking me do you\
9 remember. I only remember Prince Andrew, I\
10 remember Prince Andrew 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. Would Prince Andrew typically\
15 travel with Secret Service or some sort of\
16 security when he would come to visit you and\
17 Jeffrey in New York?

18 A. Typically he would have somebody.

19 Q. Would they be in the house or\
20 outside of the house? Would they usually\
21 stay in the house or outside of the house, in\
22 other words guarding the doors or would they\
23 come inside?

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

1 G Maxwell - Confidential\
2 he and [REDACTED] were together in the\
3 presence of Prince Andrew?\
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 [REDACTED]\
9 [REDACTED] statement that she was in the\
10 presence of Prince Andrew?\
11 MR. PAGLIUCA: Objection to the\
12 form and foundation.\
13 A. I have not discussed individual\
14 presences with [REDACTED]. 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 [REDACTED] is lying\
22 when she says she met Prince Andrew?\
23 MR. PAGLIUCA: Objection to the\
24 form and foundation.\
25 A. Again, I'm not talking about what

1 G Maxwell - Confidential\
2 [REDACTED] 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 Glenn [REDACTED] 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 [REDACTED] anybody else over to Glenn [REDACTED]\
16 home for a massage?\
17 A. Not to the best of my knowledge.\
18 Q. Do you know one of Alexander\
19 [REDACTED] friend by the name of Anuska\
20 DiGeorgio?\
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?

1 G Maxwell - Confidential\
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 [REDACTED] didn't meet Prince Andrew. 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 [REDACTED] to give Glenn [REDACTED]\
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 [REDACTED] allegation that she gave Glenn

1 G Maxwell - Confidential\
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 Anuska\
6 DiGeorgio 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 Anuska DiGeorgio 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 Anuska\
25 DiGeorgio?

Page 306

1 G Maxwell - Confidential\
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 Anuska DiGeorgio?\
25 MR. PAGLIUCA: Objection to the

Page 307

1 G Maxwell - Confidential\
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 [REDACTED] 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 [REDACTED] worked for\
11 Jeffrey Epstein, did she perform massages?\
12 A. I've testified that when [REDACTED]\
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 [REDACTED].\
17 Q. What did [REDACTED] 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

Page 308

1 G Maxwell - Confidential\
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 [REDACTED]?\
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?

Page 309

1 G Maxwell - Confidential\
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 Anuska 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 Anuska.\
15 Q. Were you responsible for\
16 introducing [REDACTED] 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. [REDACTED]\
21 came to answer telephones.\
22 Q. When did you -- were you the person\
23 who brought or introduced or met [REDACTED] for\
24 purposes of bringing her to Jeffrey Epstein's\
25 home?

Page 310

1 G Maxwell - Confidential

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 [REDACTED] for

19 purposes of that role?

20 A. So in the course of looking for

21 somebody to answer phones at the house,

22 [REDACTED] 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?

Page 311

1 G Maxwell - Confidential

2 MR. PAGLIUCA: Objection to form

3 and foundation.

4 A. I honestly don't recall how, in

5 that moment, how I met [REDACTED] 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. [REDACTED], 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.

Page 312

1 G Maxwell - Confidential

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 [REDACTED]?

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.

Page 313

1 G Maxwell - Confidential

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

| <p>Page 314</p> <p>1 G Maxwell - Confidential<br/> 2 mechanism by which you kept electronic<br/> 3 information of names and addresses of<br/> 4 individuals that he knew?<br/> 5 MR. PAGLIUCA: Objection to the<br/> 6 form and foundation.<br/> 7 A. I can't testify to what was on that<br/> 8 computer or not after I was gone.<br/> 9 Q. Not when you were gone, when you<br/> 10 were there. If Jeffrey wanted to call, for<br/> 11 example, say Les Wexner, would someone be<br/> 12 able to go to that computer to pull up the<br/> 13 address information and phone contact<br/> 14 information for that individual?<br/> 15 MR. PAGLIUCA: Objection to the<br/> 16 form and foundation.<br/> 17 A. I couldn't possibly say.<br/> 18 Q. Did you ever have to keep track of<br/> 19 address or phone contact information for<br/> 20 Jeffrey Epstein?<br/> 21 A. That was not my job.<br/> 22 Q. Did you ever do it?<br/> 23 A. I am not responsible for keeping<br/> 24 his numbers so that wasn't my job at all.<br/> 25 Q. But did you ever do it? I know</p>                                                                   | <p>Page 316</p> <p>1 G Maxwell - Confidential<br/> 2 form and foundation.<br/> 3 Q. Was there a hard copy book as well<br/> 4 as something on the computer or was there<br/> 5 only electronic information on the phone<br/> 6 numbers?<br/> 7 MR. PAGLIUCA: Objection to the<br/> 8 form and foundation.<br/> 9 A. I can only testify to what I know<br/> 10 obviously, and I believe that this is a copy<br/> 11 of a stolen document. I would love to know<br/> 12 how you guys got it.<br/> 13 Q. I'm asking during the time you<br/> 14 worked for Jeffrey Epstein, was there a<br/> 15 hardcopy document of any kind that kept phone<br/> 16 numbers for Jeffrey Epstein, if he needed to<br/> 17 contact someone?<br/> 18 A. The stolen document I have in front<br/> 19 of me that you have is what you are referring<br/> 20 to.<br/> 21 Q. So there was, during your time when<br/> 22 you were there, there was no other, you<br/> 23 mentioned there was information on a<br/> 24 computer. Was there any hardcopy document<br/> 25 that you could refer to to find someone's</p> |
| ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| <p>Page 315</p> <p>1 G Maxwell - Confidential<br/> 2 it's not your job but did you ever do it, did<br/> 3 you ever keep phone contact information for<br/> 4 him?<br/> 5 A. During the course of the time we<br/> 6 were together, if he gave me a telephone<br/> 7 number, I would give it to an assistant to<br/> 8 put in the computer, I could do that.<br/> 9 Q. Would he ask you for contact<br/> 10 information for different individuals, if he<br/> 11 wanted to contact someone?<br/> 12 MR. PAGLIUCA: Objection to the<br/> 13 form and foundation.<br/> 14 A. In the course of the long period of<br/> 15 time when I was there, it certainly would be<br/> 16 possible for him to ask me for a telephone<br/> 17 number and if I had the -- I wouldn't always<br/> 18 have it -- I'm sure it happened.<br/> 19 Q. Was there a hardcopy book in<br/> 20 addition to the computer, a hardcopy book<br/> 21 that you could look for numbers that were<br/> 22 relevant to Jeffrey Epstein's life and<br/> 23 something on the computer or was it just an<br/> 24 electronic version?<br/> 25 MR. PAGLIUCA: Objection to the</p> | <p>Page 317</p> <p>1 G Maxwell - Confidential<br/> 2 number?<br/> 3 A. You have the stolen document in<br/> 4 front of you.<br/> 5 Q. You had access to this when you<br/> 6 worked for Jeffrey Epstein?<br/> 7 A. This is, I believe, the book that<br/> 8 was stolen, that was the hardcopy of whatever<br/> 9 was there.<br/> 10 Q. So when you were working for<br/> 11 Jeffrey Epstein, you were able to access this<br/> 12 book?<br/> 13 A. This book -- if this is what this<br/> 14 is, I believe it was, this is the stolen<br/> 15 document from his house.<br/> 16 Q. And you were able to access it when<br/> 17 you worked for him?<br/> 18 A. It was a document that was printed<br/> 19 that you could, if you needed to, look for a<br/> 20 number.<br/> 21 Q. Do you know how this book was<br/> 22 created?<br/> 23 A. No.<br/> 24 Q. When you referred to it a moment<br/> 25 ago, to a stolen document, when Alfredo</p>                                                                                                                                                 |

Page 318

1 G Maxwell - Confidential

2 Rodriguez 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

Page 319

1 G Maxwell - Confidential

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 [REDACTED] 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

Page 320

1 G Maxwell - Confidential

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 Q. Are there any numbers on here or

17 names that you recognize that you would have

18 entered into this section?

19 A. I already testified that I'm not

20 responsible for inputting numbers and names

21 into this so I would not be able to tell you.

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?

Page 321

1 G Maxwell - Confidential

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 [REDACTED] cell?

6 MR. PAGLIUCA: What page?

7 Q. It's 91, [REDACTED] number 001663.

8 About halfway down, it says in the first

9 column, it says [REDACTED] 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 [REDACTED] is that correct?

Page 322

1 G Maxwell - Confidential

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 [REDACTED] 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.

Page 323

1 G Maxwell - Confidential

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

Page 324

1 G Maxwell - Confidential

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

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1 G Maxwell - Confidential

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.

1 G Maxwell - Confidential\
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 [REDACTED],\
7 do you know [REDACTED]?\
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 [REDACTED]?\
25 MR. PAGLIUCA: Object to the form

1 G Maxwell - Confidential\
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

1 G Maxwell - Confidential\
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 Alfredo Rodriguez 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 [REDACTED]\
22 [REDACTED]?\
23 MR. PAGLIUCA: Objection to form\
24 and foundation.\
25 A. I never supervised [REDACTED]

1 G Maxwell - Confidential\
2 Q. Did [REDACTED] take orders from\
3 you?\
4 MR. PAGLIUCA: Objection to the\
5 form and foundation.\
6 A. She worked for Jeffrey.\
7 Q. If Alfredo Rodriguez 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 Alfredo Rodriguez 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 Alfredo\
23 said or didn't say.\
24 Q. I'm saying if Alfredo said that you\
25 had knowledge that there were girls coming

| <p>Page 330</p> <p>1 G Maxwell - Confidential<br/> 2 over to the house that were underage for the<br/> 3 purposes of sex, would that statement be<br/> 4 true?<br/> 5 MR. PAGLIUCA: Objection to form<br/> 6 and foundation.<br/> 7 A. I can't testify to what Alfredo<br/> 8 said or didn't say or what he thought.<br/> 9 Q. Did you have knowledge of underage<br/> 10 girls coming to Jeffrey Epstein's house for<br/> 11 the purpose of sex?<br/> 12 A. No.<br/> 13 Q. Earlier I believe you testified,<br/> 14 correct me if I'm wrong, that the document<br/> 15 that is in front of you, the thicker document<br/> 16 was a stolen document.<br/> 17 Do you know who stole that<br/> 18 document?<br/> 19 A. I have read that Alfredo stole the<br/> 20 document.<br/> 21 Q. And where have you read that?<br/> 22 A. I believe it was reported in the<br/> 23 press.<br/> 24 Q. Earlier we were talking about the<br/> 25 computers at Jeffrey Epstein's home. Did you</p>                                                                                                                | <p>Page 332</p> <p>1 G Maxwell - Confidential<br/> 2 of this document being on it, so I don't know<br/> 3 where this came from.<br/> 4 Q. I understand the computer at the<br/> 5 house that you're referencing. On a personal<br/> 6 computer of yours, did you have that<br/> 7 document?<br/> 8 A. I don't know where this document<br/> 9 came from, so I can't possibly say this<br/> 10 document was on any computer that I may have<br/> 11 had access to.<br/> 12 Q. On a personal computer of your own,<br/> 13 did you have lists of the phone numbers and<br/> 14 contact information relating to Jeffrey<br/> 15 Epstein?<br/> 16 A. Like everybody, I have an address<br/> 17 book but I can't possibly testify to where<br/> 18 this thing came from.<br/> 19 Q. Was it your address book or was it<br/> 20 addresses that related to Jeffrey Epstein?<br/> 21 MR. PAGLIUCA: Objection to the<br/> 22 form and foundation.<br/> 23 A. I don't know what you're asking me.<br/> 24 Q. On your personal computer, the<br/> 25 address book you are referencing, was it your</p>                                  |
| -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| <p>Page 331</p> <p>1 G Maxwell - Confidential<br/> 2 have a computer that was your computer<br/> 3 located in Jeffrey Epstein's home?<br/> 4 MR. PAGLIUCA: Objection to form<br/> 5 and foundation.<br/> 6 A. I've testified to the computer<br/> 7 already. Even when I was around, there was a<br/> 8 computer that people had access to.<br/> 9 Q. So is Alfredo Rodriguez telling the<br/> 10 truth when he says that he downloaded that<br/> 11 book from your computer?<br/> 12 MR. PAGLIUCA: Objection to the<br/> 13 form and foundation.<br/> 14 A. I couldn't possibly tell you what<br/> 15 Alfredo did or didn't do or said or didn't<br/> 16 say.<br/> 17 Q. Was it on your computer?<br/> 18 A. I already testified I have no idea<br/> 19 where this document came from.<br/> 20 Q. Did you have a list of names of<br/> 21 individuals with contact information for<br/> 22 Jeffrey Epstein on your personal computer?<br/> 23 A. Again, that wasn't my computer. I<br/> 24 already said that was a computer that lots of<br/> 25 people would have, so I have no recollection</p> | <p>Page 333</p> <p>1 G Maxwell - Confidential<br/> 2 address book with individuals you knew or was<br/> 3 it an address book for your employer, Jeffrey<br/> 4 Epstein?<br/> 5 A. Jeffrey has his situation and I<br/> 6 have no -- this is Jeffrey's, it came from<br/> 7 his home, so I can't testify to anything<br/> 8 about this in that period of time.<br/> 9 Q. So you didn't have on your computer<br/> 10 a list of contact information for individuals<br/> 11 that was related to Jeffrey Epstein?<br/> 12 A. I don't recall exactly what I had<br/> 13 back in 2004 and 2005, so I can't say what I<br/> 14 had back then that relates to his addresses,<br/> 15 I can't recall.<br/> 16 Q. So is it possible that someone<br/> 17 could have downloaded from your personal<br/> 18 computer a list of names and address that<br/> 19 were affiliated with Jeffrey Epstein?<br/> 20 MR. PAGLIUCA: Objection to the<br/> 21 form and foundation.<br/> 22 A. This didn't come from any computer<br/> 23 of mine.<br/> 24 Q. But is it possible that someone<br/> 25 could have downloaded a list of names and</p> |

| <p>Page 334</p> <p>1 G Maxwell - Confidential<br/> 2 addresses affiliated with Jeffrey Epstein<br/> 3 from your computer?<br/> 4 MR. PAGLIUCA: Objection to the<br/> 5 form and foundation.<br/> 6 A. I already said, I didn't have a<br/> 7 computer there, so I don't know where this<br/> 8 came from, I have no idea.<br/> 9 Q. I'm going to read to you some<br/> 10 testimony from Alfredo Rodriguez's deposition<br/> 11 and it's on page 370 and I want to ask you a<br/> 12 question about it, if it's true or false?<br/> 13 MR. PAGLIUCA: I'm going to object<br/> 14 unless you show the witness the<br/> 15 document.<br/> 16 MS. McCAWLEY: I will pass it. We<br/> 17 are not going to mark it. We will skip<br/> 18 it.<br/> 19 Q. Did you ever tell Alfredo Rodriguez<br/> 20 that he better watch out and better keep his<br/> 21 mouth shut with respect to what occurred at<br/> 22 Mr. Epstein's home?<br/> 23 MR. PAGLIUCA: Objection to the<br/> 24 form and foundation.<br/> 25 A. It doesn't sound like anything I</p>              | <p>Page 336</p> <p>1 G Maxwell - Confidential<br/> 2 reference to this case with any, anything you<br/> 3 just mentioned, I never threatened anyone.<br/> 4 Q. Have you ever directed anyone to<br/> 5 call any witnesses relevant to this case and<br/> 6 threaten them not to testify?<br/> 7 MR. PAGLIUCA: Objection to the<br/> 8 form and foundation.<br/> 9 A. I never done such a thing.<br/> 10 Q. Did Jeffrey Epstein or you ever ask<br/> 11 any female, regardless of age, to carry<br/> 12 Jeffrey's baby for him?<br/> 13 MR. PAGLIUCA: Objection to the<br/> 14 form and foundation.<br/> 15 Q. Or anything along those lines?<br/> 16 MR. PAGLIUCA: Objection to the<br/> 17 form and foundation.<br/> 18 A. Can you repeat the question,<br/> 19 please?<br/> 20 Q. Did you or Jeffrey Epstein ever ask<br/> 21 any female, regardless of age, to carry<br/> 22 Jeffrey Epstein's baby for him?<br/> 23 MR. PAGLIUCA: Objection to the<br/> 24 form and foundation.<br/> 25 A. Are you asking --</p>                                                             |
| ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| <p>Page 335</p> <p>1 G Maxwell - Confidential<br/> 2 would say.<br/> 3 Q. Did you ever threaten Alfredo<br/> 4 Rodriguez in any way if he were to disclose<br/> 5 information he learned from his employment<br/> 6 with Jeffrey Epstein?<br/> 7 MR. PAGLIUCA: Objection to the<br/> 8 form and foundation.<br/> 9 A. I'm happy to answer. No, I never<br/> 10 threatened him in any way.<br/> 11 Q. Were you concerned that he was<br/> 12 going to disclose that Jeffrey Epstein was<br/> 13 trafficking underage girls?<br/> 14 MR. PAGLIUCA: Objection to the<br/> 15 form and foundation.<br/> 16 A. First of all, there are so many<br/> 17 things wrong with that question, but I have<br/> 18 no knowledge of what you are talking about.<br/> 19 Q. Have you ever contacted or<br/> 20 instructed anyone to contact any witness in<br/> 21 this case for the purposes of threatening<br/> 22 them not to testify in this case?<br/> 23 MR. PAGLIUCA: Objection to the<br/> 24 form and foundation.<br/> 25 A. I have never called anybody with</p> | <p>Page 337</p> <p>1 G Maxwell - Confidential<br/> 2 Q. To become pregnant, did you or<br/> 3 Jeffrey Epstein ever ask any female to become<br/> 4 pregnant and carry Jeffrey Epstein's baby for<br/> 5 you or for Jeffrey?<br/> 6 MR. PAGLIUCA: Objection to form<br/> 7 and foundation.<br/> 8 A. You need to be very specific. I<br/> 9 have no idea what you are talking about.<br/> 10 That's completely rubbish.<br/> 11 Q. Did you or Jeffrey Epstein ask any<br/> 12 female to become pregnant and carry his baby<br/> 13 for either him or you?<br/> 14 MR. PAGLIUCA: Objection to the<br/> 15 form and foundation. Go ahead.<br/> 16 A. I can't testify to anything Jeffrey<br/> 17 did or didn't do when I am not present, but I<br/> 18 have never asked anybody to carry a baby for<br/> 19 me.<br/> 20 Q. Or anything along those lines?<br/> 21 MR. PAGLIUCA: Object to the form<br/> 22 and foundation.<br/> 23 Q. I want to make sure we are talking<br/> 24 about the same thing, not physically carry a<br/> 25 baby, I mean become pregnant with a baby?</p> |

Page 362

1 G Maxwell - Confidential\
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 [REDACTED] 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 [REDACTED] a liar would subject you to

Page 363

1 G Maxwell - Confidential\
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 [REDACTED] 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 [REDACTED], there\
23 is no vowel in there.\
24 MS. MCCAWLEY: I was just trying to\
25 pronounce it.

Page 364

1 G Maxwell - Confidential\
2 Q. This email reads do you want\
3 [REDACTED], 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 [REDACTED].\
9 Q. Why was he asking you if you wanted\
10 [REDACTED] 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 [REDACTED] 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 [REDACTED] 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?

Page 365

1 G Maxwell - Confidential\
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 [REDACTED] 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 [REDACTED] his girlfriend?\
11 A. They spent a lot of time together.\
12 Q. Did you talk to [REDACTED] about going\
13 to the press and saying that she was the\
14 girlfriend and not you?\
15 A. I have never spoken to [REDACTED]\
16 Q. Was [REDACTED] 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 [REDACTED] 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