Draft: efta02793597

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>

<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 2 questions. 3 MR. PAGLIUCA: I'm instructing her 4 not to answer. 5 MS. McCAWLEY: Then we will be back 6 here again. 7 Q. Have you ever given a massage to 8 Mr. Epstein with a female that was under the 9 age of 18? 10 A. Can you repeat the question? 11 Q. Yes. Have you ever given a massage 12 to Mr. Epstein with a female that was under 13 the age of 18? 14 A. No. 15 Q. Have you ever observed Mr. Epstein 16 having a massage given by an individual, a 17 female, who was under the age of 18? 18 A. No. 19 Q. Have you ever observed females 20 under the age of 18 in the presence of 21 Jeffrey Epstein at his home? 22 MR. PAGLIUCA: Object to the form 23 and foundation. 24 A. Again, I have friends that have 25 children --</p>

<p>Page 24</p> <p>1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. How would I possibly know how 5 someone is when they are at his house. You 6 are asking me to do that. I cannot possibly 7 testify to that. As far as I'm concerned, 8 everyone who came to his house was an adult 9 professional person. 10 Q. Are you familiar with the police 11 report that was issued in respect to the 12 investigation in this matter? 13 MR. PAGLIUCA: Object to the form 14 and foundation. 15 Q. Are you familiar with the police 16 report that was used in this matter, the 17 investigation of Jeffrey Epstein, has been 18 produced as a document in this matter? 19 A. I have seen a police report. 20 (Maxwell Exhibit 1, police report, 21 marked for identification.) 22 Q. The police report that you have in 23 front of you, can you turn to page 28 of that 24 report, the numbers are on the top right-hand 25 corner.</p>

<p>Page 23</p> <p>1 G Maxwell - Confidential 2 Q. I'm not talking about friends. I'm 3 talking about individuals -- 4 MR. PAGLIUCA: I'm going to object 5 to you interrupting the witness who was 6 answering your question. The question 7 was, have you ever seen anyone, female 8 under the age of 18 at the house and 9 that's the question she was answering. 10 If you want to strike that question and 11 ask another question, feel free, but let 12 the witness respond, please. 13 MS. McCAWLEY: I will do that. 14 Q. Have you ever observed a female 15 under the age of 18 at Jeffrey Epstein's home 16 that was not a friend, a child -- one of your 17 friend's children? 18 A. Again, I can't testify to that 19 because I have no idea what you are talking 20 about. 21 Q. You have no idea what I'm talking 22 about in the sense you never observed a 23 female under the age of 18 at Jeffrey 24 Epstein's home that was not one of your 25 friend's children, is that correct?</p>

<p>Page 25</p> <p>1 G Maxwell - Confidential 2 You will see some redactions in 3 this report, Ms. Maxwell, the redacted 4 information is redacted because it reveals 5 the name of a minor, someone who is under the 6 age of 18. 7 On page 28, in the third paragraph, 8 about halfway down, it says, [REDACTED] stated 9 she performed the massage naked. At the 10 conclusion of this massage, Epstein paid 11 [REDACTED] $200 for the massage. He explained, I 12 know you are not comfortable put I will pay 13 you if you bring some girls. He told her the 14 younger the better. [REDACTED] stated once tried 15 to bring a 23 year old to Epstein and he 16 stated the female was too old. 17 Have you heard Mr. Epstein use the 18 phrase the younger the better? 19 A. I have no recollection of hearing 20 that. 21 Q. Have you used the phrase in talking 22 to [REDACTED] and asking her to recruit 23 females for Mr. Epstein, the younger the 24 better? 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.¶

Page 47¶

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¶

Page 48¶

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.¶

Page 62¶

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.¶

Page 64¶

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¶

Page 65¶

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.¶

Page 78¶

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¶

Page 81¶

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.¶

Page 82¶

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¶

Page 83¶

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?¶

Page 94¶

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¶

Page 96¶

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.¶

Page 97¶

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 2 that was underage in London specifically to 3 provide a massage to Jeffrey, is that your 4 question? 5 Q. Yes. 6 A. No. 7 Q. Do you know who Alexander [REDACTED] is? 8 A. I don't recall her right now. 9 Q. Do you know if -- strike that. 10 During the time that you were 11 working for Jeffrey, did you ever observe any 12 foreign females, so in other words, not from 13 the United States, that were brought to 14 Jeffrey's home to perform massages? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. Females, what age are we talking? 18 Q. Any age. 19 A. Can you repeat the question? 20 Q. During the time you were working 21 for Jeffrey, did you ever observe any foreign 22 females of any age that were at Jeffrey's 23 home to perform a massage? 24 MR. PAGLIUCA: Objection to the 25 form and foundation.</p>

<p>Page 100</p> <p>1 G Maxwell - Confidential 2 form and foundation. 3 A. I already testified about not 4 knowing about underage girls. 5 Q. Did you provide any assistance with 6 obtaining visas for foreign girls that were 7 under the age of 18? 8 A. I've never participated in helping 9 people of any age to get visas. 10 Q. Did Jeffrey, was it Jeffrey's 11 preference to start a massage with sex? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I think you should ask that 15 question of Jeffrey. 16 Q. Do you know? 17 A. I don't believe that was his 18 preference. I think -- you have to 19 understand, a massage -- perhaps you are not 20 really familiar with what massage is. 21 Q. I am, I don't need a lecture on 22 massage. 23 A. I think you do. 24 MR. PAGLIUCA: No question pending. 25 She will ask you another question now.</p>

<p>Page 99</p> <p>1 G Maxwell - Confidential 2 A. Are you asking me if any foreigner, 3 not an American person, gave Jeffrey a 4 massage? 5 Q. Yes. 6 A. Well, as I sit here today, I can't 7 think of anyone who is foreign. Certainly -- 8 I just can't think of anybody right this 9 second. 10 Q. How about any foreign girls who 11 were under the age of 18? 12 A. I already testified to not knowing 13 anything about underage girls. 14 Q. Were there foreign girls who were 15 brought to Jeffrey's home by Jean Luc Brunel 16 for the purposes of providing massages? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I am not aware of Jean Luc bringing 20 girls. I have not no idea what you are 21 talking about. 22 Q. You have never been around foreign 23 girls who are under the age of 18 at 24 Jeffrey's homes? 25 MR. PAGLIUCA: Objection to the</p>

<p>Page 101</p> <p>1 G Maxwell - Confidential 2 A. Massage is for health benefits. 3 Q. When did you first meet Jeffrey? 4 A. Some point in 1991. 5 Q. And did Jeffrey know your father? 6 A. No. 7 Q. How were you introduced to Jeffrey? 8 A. Some friend introduced us. 9 Q. Can you describe your relationship 10 back in 1991, was it friendship or was it 11 girlfriend relationship or was it a work 12 relationship, what was your relationship in 13 1991? 14 A. It was just friendly. 15 Q. Then I believe you testified you 16 began working for him in 1992, is that 17 correct? 18 A. Yes. 19 Q. In 1992 I know you gave me the 20 description of the work that you were 21 performing for him, how much was he paying 22 you, do you remember? 23 A. I don't recall. 24 Q. Do you know for example in 2001 how 25 much he was paying you?</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]¶

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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¶

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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,¶

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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.¶

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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¶

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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 2 one of his planes? 3 A. There was a bed on one of his 4 planes that folded out, yes. 5 Q. Do you recall whether with respect 6 to this being in Santa Fe, do you recall 7 whether you were there for some form of a 8 party? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. I don't recall the trip at all and 12 this looks like a total work trip, not a 13 party trip. 14 Q. What would be the difference 15 between a work trip and a party trip? 16 A. Just that I would be on trips for 17 work and I believe that this looks like, AP 18 looks like it's one of the -- probably one of 19 the designers and the time would meet with a 20 trip to decorate the house, just the timing 21 of it. 22 Q. So would [REDACTED] be brought on 23 trips that were for the purpose of work and 24 decorating the house? 25 A. Like I said, I never worked with</p>

<p>Page 148</p> <p>1 G Maxwell - Confidential 2 excerpts from -- we will identify what they 3 are but from the message pads. 4 Did you want to correct anything? 5 A. I want to make an addendum. 6 Would you mind rereading the last 7 question back to me? 8 (Record read.) 9 A. I also just want to say that at 10 this point I cannot recollect flying to 11 parties. Jeffrey went for work so -- was 12 this in Santa Fe, this flight as well. 13 Q. The flight we were looking at, yes 14 but it was to Santa Fe -- 15 A. I don't recall going to any parties 16 in Santa Fe at any time but certainly flying 17 to Santa Fe for a party seems highly 18 improbable. 19 Q. So I'm going to direct your 20 attention to the document that I set before 21 you which is [REDACTED] number [REDACTED] and it 22 has different [REDACTED] numbers because it's a 23 smaller version of the larger production. 24 These are the pages I will be asking about. 25 In the time that you were working</p>

<p>Page 147</p> <p>1 G Maxwell - Confidential 2 her but you would have to ask Jeffrey what he 3 brought her on the trip for. 4 Q. But she would travel with him when 5 there was a work trip like this? 6 A. I can't -- I'm seeing that she is 7 on this flight but I have no idea what she is 8 doing, he invited her, it would not be my 9 job. 10 Q. What about [REDACTED] would she 11 regularly travel with Jeffrey on flights? 12 A. I have no idea, you would have to 13 look through the flight logs. I have no 14 idea. 15 Q. Your recollection is -- what is 16 your recollection, do you recollect Nadia 17 traveling often on flights with Jeffrey? 18 A. Absolutely not. No, not at all. I 19 don't recollect her actually on the flight at 20 all. 21 Q. I think you can set that aside for 22 the moment. 23 (Maxwell Exhibit 9, message pad 24 pages, marked for identification.) 25 Q. We will mark as Exhibit 9 these</p>

<p>Page 149</p> <p>1 G Maxwell - Confidential 2 with Jeffrey in Palm Beach, do you recall a 3 process for taking, anybody at the house 4 taking messages when incoming phone calls 5 came in? 6 A. You are supposed to take a message 7 and receive the message and write the message 8 down. Who was the message was for, what time 9 it was taken and who took it and what the 10 message was, obviously. 11 Q. Does what's in front of you look 12 familiar with respect to the message pads 13 that you would have used at the house? 14 A. It is familiar. 15 Q. I'm going to direct your attention 16 to the second page of it? 17 MR. PAGLIUCA: These all have SAO 18 numbers on them or [REDACTED] ranges and I 19 don't see any of your [REDACTED] ranges on 20 these. I know you have produced message 21 pads but those have your [REDACTED] range 22 numbers on them and I'm wondering if 23 these are different documents. 24 MS. McCAWLEY: It's the same, just 25 ours have the [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 2 someone I don't know. 3 Q. Why is your name reflected on this 4 message pad? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I have no idea. You would have to 8 ask whoever took the message. 9 Q. Did you, in the course of your 10 work, regularly take messages for Jeffrey 11 Epstein? 12 A. I already testified I hardly ever 13 did. 14 Q. Would you, in the course of your 15 work, regularly set up appointments for 16 females to come over and give massages for 17 Jeffrey Epstein? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. Can you specify, females, you mean 21 adults over the age of 18. 22 Q. Did you regularly set up for 23 Jeffrey adults over the age of 18 to come for 24 massages? 25 A. I didn't regularly do that, no.</p>

<p>Page 164</p> <p>1 G Maxwell - Confidential 2 messages, I don't know about how I would 3 possibly know if somebody I spoke to, one or 4 two times I took a message is, how old they 5 would be but I have never taken a message 6 where I was aware of anything being under the 7 age of 18 and I probably took it so 8 infrequently, it would be impossible. 9 Q. Can you turn to [REDACTED] it 10 should be the next page. 11 A. Uh-huh. 12 Q. Do you see at the top, it says, for 13 Mr. J. 11/8/04 and then the name is 14 redacted. It says, I have a female for him. 15 Why would a minor be calling 16 Jeffrey to say they have a female for him? 17 Do you know? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. First of all, I don't know that's a 21 minor, I don't know who took the message. 22 Q. I will represent to you these are 23 police reports and minor's names have to be 24 redacted for privacy purposes? 25 MR. PAGLIUCA: Objection to the</p>

<p>Page 163</p> <p>1 G Maxwell - Confidential 2 Q. Would you take messages with 3 respect to females over the age of 18 to come 4 over for a massage? 5 A. I already testified I hardly ever 6 did take messages. 7 Q. But would you? 8 A. I already testified, I hardly 9 ever -- 10 Q. I know hardly ever, but did you? 11 A. Over the course of time it is 12 possible I may have taken a couple, I have no 13 recollection. I hardly ever did and I did so 14 irregularly that it would hard for me to 15 pinpoint. 16 Q. Did you ever take a message for a 17 female under the age of 18 to come over for a 18 massage or for any other reason to be with 19 Jeffrey Epstein? 20 MR. PAGLIUCA: Object to the form 21 and foundation. 22 A. I hardly ever took a message. I 23 have absolutely no way of knowing, maybe one 24 of my friends' daughters called to say they 25 were coming to visit me. I have never taken</p>

<p>Page 165</p> <p>1 G Maxwell - Confidential 2 form and foundation. 3 Q. Do you know why a minor child would 4 be calling Jeffrey and leaving a message to 5 say, quote, I have a female for him? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I can't testify anything about this 9 message, I don't know anything about it. 10 Q. I'm going to direct your attention 11 to the next page [REDACTED]. If you look at 12 the bottom left, you are going to see a 13 message for Jeffrey, from [REDACTED], it 14 says she doesn't have a number and left a 15 message that she called. 16 Do you know who [REDACTED] is? 17 A. I do not. 18 Q. Do you know that [REDACTED] was 19 13 at the time she placed this call to 20 Jeffrey? 21 A. I don't know who [REDACTED] is. 22 Q. Would Jeffrey regularly have 13 23 year olds call and leave messages? 24 MR. PAGLIUCA: Objection to the 25 form and foundation.</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 2 agree to that? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 Q. Are they under the age of 18? 6 A. We already established that you can 7 be a masseuse in Florida at age 17. That 8 does not make it inappropriate. 9 A. I'm not saying appropriate or 10 inappropriate. I'm just asking if there were 11 any exercise instructors that were under the 12 age of 18. 13 A. I am not aware if anybody was but I 14 don't want to full out and say you █ she 15 said, we already established you can be a 17 16 year old masseuse and have it not be 17 something that is not appropriate. So when 18 you say that and then you go, well, you come 19 back and say something, now we can establish 20 that █ was 17 but you can be a 17 year 21 old legal masseuse, but I am not aware to 22 your point. 23 Q. Who were the other 17 year old 24 masseuses that you were aware of? 25 A. I am not aware of any.</p>

<p>Page 252</p> <p>1 G Maxwell - Confidential 2 Epstein had a sexual preference for underage 3 minors? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 A. I cannot testify to what 7 Jeffrey's -- 8 Q. You don't know his preference? 9 A. You handed me a stack of papers 10 from the police reports and that's what I've 11 read but I have no knowledge, direct 12 knowledge, of what you are referencing. 13 Q. So you don't know, you don't know 14 in your own mind that Jeffrey Epstein had a 15 sexual preference for underage minors, is 16 that correct? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 Q. Is that correct? 20 A. Please ask the question again. 21 Q. You don't know in your own mind 22 that Jeffrey Epstein had a sexual preference 23 for underage minors? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. You have to pause,</p>

<p>Page 251</p> <p>1 G Maxwell - Confidential 2 Q. Were there any 16 year old 3 masseuse that you are aware of? 4 A. I am not aware. 5 Q. Any 15? 6 A. I just want to be clear. The only 7 person that I am aware of who claims to have 8 been a -- we have to -- we established 9 █ now is 17, given she has changed her 10 age so many times. The only person that I am 11 aware of that was a masseuse at the time when 12 I was present in the house was █. 13 Q. Is it an obvious lie that Jeffrey 14 Epstein had a sexual preference for underage 15 minors? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Can you ask the question again? 19 Q. It is it an obvious lie that 20 Jeffrey Epstein had a sexual preference for 21 underage minors? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Can you ask the question again? 25 Q. Is it an obvious lie that Jeffrey</p>

<p>Page 253</p> <p>1 G Maxwell - Confidential 2 let me object, answer the question. 3 Listen to her question, pause, I object, 4 you answer. 5 Q. So you don't know in your own mind 6 that Jeffrey Epstein had a sexual preference 7 for underage minors? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 Q. You can answer. 11 A. I cannot tell you what Jeffrey's 12 story is. I'm not able to. 13 Q. Did Jeffrey Epstein have a scheme 14 to recruit underage girls to use them for 15 purposes of sexual massages? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Can you ask me again, please? 19 Q. Did Jeffrey Epstein have a scheme 20 to recruit underage girls to recruit them for 21 sexual massages? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Can you ask it a different way? 25 Q. Did Jeffrey Epstein have a scheme</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?¶

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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 2 mechanism by which you kept electronic 3 information of names and addresses of 4 individuals that he knew? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I can't testify to what was on that 8 computer or not after I was gone. 9 Q. Not when you were gone, when you 10 were there. If Jeffrey wanted to call, for 11 example, say Les Wexner, would someone be 12 able to go to that computer to pull up the 13 address information and phone contact 14 information for that individual? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I couldn't possibly say. 18 Q. Did you ever have to keep track of 19 address or phone contact information for 20 Jeffrey Epstein? 21 A. That was not my job. 22 Q. Did you ever do it? 23 A. I am not responsible for keeping 24 his numbers so that wasn't my job at all. 25 Q. But did you ever do it? I know</p>

<p>Page 316</p> <p>1 G Maxwell - Confidential 2 form and foundation. 3 Q. Was there a hard copy book as well 4 as something on the computer or was there 5 only electronic information on the phone 6 numbers? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I can only testify to what I know 10 obviously, and I believe that this is a copy 11 of a stolen document. I would love to know 12 how you guys got it. 13 Q. I'm asking during the time you 14 worked for Jeffrey Epstein, was there a 15 hardcopy document of any kind that kept phone 16 numbers for Jeffrey Epstein, if he needed to 17 contact someone? 18 A. The stolen document I have in front 19 of me that you have is what you are referring 20 to. 21 Q. So there was, during your time when 22 you were there, there was no other, you 23 mentioned there was information on a 24 computer. Was there any hardcopy document 25 that you could refer to to find someone's</p>

<p>Page 315</p> <p>1 G Maxwell - Confidential 2 it's not your job but did you ever do it, did 3 you ever keep phone contact information for 4 him? 5 A. During the course of the time we 6 were together, if he gave me a telephone 7 number, I would give it to an assistant to 8 put in the computer, I could do that. 9 Q. Would he ask you for contact 10 information for different individuals, if he 11 wanted to contact someone? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. In the course of the long period of 15 time when I was there, it certainly would be 16 possible for him to ask me for a telephone 17 number and if I had the -- I wouldn't always 18 have it -- I'm sure it happened. 19 Q. Was there a hardcopy book in 20 addition to the computer, a hardcopy book 21 that you could look for numbers that were 22 relevant to Jeffrey Epstein's life and 23 something on the computer or was it just an 24 electronic version? 25 MR. PAGLIUCA: Objection to the</p>

<p>Page 317</p> <p>1 G Maxwell - Confidential 2 number? 3 A. You have the stolen document in 4 front of you. 5 Q. You had access to this when you 6 worked for Jeffrey Epstein? 7 A. This is, I believe, the book that 8 was stolen, that was the hardcopy of whatever 9 was there. 10 Q. So when you were working for 11 Jeffrey Epstein, you were able to access this 12 book? 13 A. This book -- if this is what this 14 is, I believe it was, this is the stolen 15 document from his house. 16 Q. And you were able to access it when 17 you worked for him? 18 A. It was a document that was printed 19 that you could, if you needed to, look for a 20 number. 21 Q. Do you know how this book was 22 created? 23 A. No. 24 Q. When you referred to it a moment 25 ago, to a stolen document, when 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¶

Page 325¶

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 2 over to the house that were underage for the 3 purposes of sex, would that statement be 4 true? 5 MR. PAGLIUCA: Objection to form 6 and foundation. 7 A. I can't testify to what Alfredo 8 said or didn't say or what he thought. 9 Q. Did you have knowledge of underage 10 girls coming to Jeffrey Epstein's house for 11 the purpose of sex? 12 A. No. 13 Q. Earlier I believe you testified, 14 correct me if I'm wrong, that the document 15 that is in front of you, the thicker document 16 was a stolen document. 17 Do you know who stole that 18 document? 19 A. I have read that Alfredo stole the 20 document. 21 Q. And where have you read that? 22 A. I believe it was reported in the 23 press. 24 Q. Earlier we were talking about the 25 computers at Jeffrey Epstein's home. Did you</p>

<p>Page 332</p> <p>1 G Maxwell - Confidential 2 of this document being on it, so I don't know 3 where this came from. 4 Q. I understand the computer at the 5 house that you're referencing. On a personal 6 computer of yours, did you have that 7 document? 8 A. I don't know where this document 9 came from, so I can't possibly say this 10 document was on any computer that I may have 11 had access to. 12 Q. On a personal computer of your own, 13 did you have lists of the phone numbers and 14 contact information relating to Jeffrey 15 Epstein? 16 A. Like everybody, I have an address 17 book but I can't possibly testify to where 18 this thing came from. 19 Q. Was it your address book or was it 20 addresses that related to Jeffrey Epstein? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I don't know what you're asking me. 24 Q. On your personal computer, the 25 address book you are referencing, was it your</p>

<p>Page 331</p> <p>1 G Maxwell - Confidential 2 have a computer that was your computer 3 located in Jeffrey Epstein's home? 4 MR. PAGLIUCA: Objection to form 5 and foundation. 6 A. I've testified to the computer 7 already. Even when I was around, there was a 8 computer that people had access to. 9 Q. So is Alfredo Rodriguez telling the 10 truth when he says that he downloaded that 11 book from your computer? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. I couldn't possibly tell you what 15 Alfredo did or didn't do or said or didn't 16 say. 17 Q. Was it on your computer? 18 A. I already testified I have no idea 19 where this document came from. 20 Q. Did you have a list of names of 21 individuals with contact information for 22 Jeffrey Epstein on your personal computer? 23 A. Again, that wasn't my computer. I 24 already said that was a computer that lots of 25 people would have, so I have no recollection</p>

<p>Page 333</p> <p>1 G Maxwell - Confidential 2 address book with individuals you knew or was 3 it an address book for your employer, Jeffrey 4 Epstein? 5 A. Jeffrey has his situation and I 6 have no -- this is Jeffrey's, it came from 7 his home, so I can't testify to anything 8 about this in that period of time. 9 Q. So you didn't have on your computer 10 a list of contact information for individuals 11 that was related to Jeffrey Epstein? 12 A. I don't recall exactly what I had 13 back in 2004 and 2005, so I can't say what I 14 had back then that relates to his addresses, 15 I can't recall. 16 Q. So is it possible that someone 17 could have downloaded from your personal 18 computer a list of names and address that 19 were affiliated with Jeffrey Epstein? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. This didn't come from any computer 23 of mine. 24 Q. But is it possible that someone 25 could have downloaded a list of names and</p>

<p>Page 334</p> <p>1 G Maxwell - Confidential 2 addresses affiliated with Jeffrey Epstein 3 from your computer? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I already said, I didn't have a 7 computer there, so I don't know where this 8 came from, I have no idea. 9 Q. I'm going to read to you some 10 testimony from Alfredo Rodriguez's deposition 11 and it's on page 370 and I want to ask you a 12 question about it, if it's true or false? 13 MR. PAGLIUCA: I'm going to object 14 unless you show the witness the 15 document. 16 MS. McCAWLEY: I will pass it. We 17 are not going to mark it. We will skip 18 it. 19 Q. Did you ever tell Alfredo Rodriguez 20 that he better watch out and better keep his 21 mouth shut with respect to what occurred at 22 Mr. Epstein's home? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. It doesn't sound like anything I</p>

<p>Page 336</p> <p>1 G Maxwell - Confidential 2 reference to this case with any, anything you 3 just mentioned, I never threatened anyone. 4 Q. Have you ever directed anyone to 5 call any witnesses relevant to this case and 6 threaten them not to testify? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I never done such a thing. 10 Q. Did Jeffrey Epstein or you ever ask 11 any female, regardless of age, to carry 12 Jeffrey's baby for him? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 Q. Or anything along those lines? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Can you repeat the question, 19 please? 20 Q. Did you or Jeffrey Epstein ever ask 21 any female, regardless of age, to carry 22 Jeffrey Epstein's baby for him? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Are you asking --</p>

<p>Page 335</p> <p>1 G Maxwell - Confidential 2 would say. 3 Q. Did you ever threaten Alfredo 4 Rodriguez in any way if he were to disclose 5 information he learned from his employment 6 with Jeffrey Epstein? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I'm happy to answer. No, I never 10 threatened him in any way. 11 Q. Were you concerned that he was 12 going to disclose that Jeffrey Epstein was 13 trafficking underage girls? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. First of all, there are so many 17 things wrong with that question, but I have 18 no knowledge of what you are talking about. 19 Q. Have you ever contacted or 20 instructed anyone to contact any witness in 21 this case for the purposes of threatening 22 them not to testify in this case? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I have never called anybody with</p>

<p>Page 337</p> <p>1 G Maxwell - Confidential 2 Q. To become pregnant, did you or 3 Jeffrey Epstein ever ask any female to become 4 pregnant and carry Jeffrey Epstein's baby for 5 you or for Jeffrey? 6 MR. PAGLIUCA: Objection to form 7 and foundation. 8 A. You need to be very specific. I 9 have no idea what you are talking about. 10 That's completely rubbish. 11 Q. Did you or Jeffrey Epstein ask any 12 female to become pregnant and carry his baby 13 for either him or you? 14 MR. PAGLIUCA: Objection to the 15 form and foundation. Go ahead. 16 A. I can't testify to anything Jeffrey 17 did or didn't do when I am not present, but I 18 have never asked anybody to carry a baby for 19 me. 20 Q. Or anything along those lines? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 Q. I want to make sure we are talking 24 about the same thing, not physically carry a 25 baby, I mean become pregnant with a baby?</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¶