COMPOSITE EXHIBIT A¶
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶
x¶
Plaintiff,¶
-against-¶
GHISLAINE MAXWELL,¶
Defendants.¶
Case No.: 15-cv-07433-RWS¶
**CONFIDENTIAL**¶
x¶
Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York.¶
MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026¶
1¶
2 APPEARANCES:¶
3¶
BOIES SCHILLER & FLEXNER, LLP¶
4 Attorneys for Plaintiff 401 East Las Olas Boulevard Fort Lauderdatle, Florida, 33301¶
BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH, ESQUIRE EMMA, PARALEGAL¶
7¶
8¶
JAFFE WEISSING FISTOS & 9 LEHRMAN, P.L.¶
Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301¶
11 BY: BRAD, ESQUIRE¶
12¶
13 PAUL G. CASSELL, ESQUIRE¶
Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112¶
15¶
16¶
HADDON¶
17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203¶
BY: JEFFREY S. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE¶
20¶
21 Also Present: 22 James Christe, videographer¶
23¶
24¶
25¶
Questions About People Under the Age of 18 at Epstein's Home¶
2 Q. You can answer.¶
3 A. I have not any idea exactly of the 4 youngest adult employee that I hired for 5 Jeffrey.¶
6 Q. When you say adult employee, did 7 you ever hire someone that was under the age 8 of 18?¶
9 A. Never.¶
10 Q. Did you ever bring someone who was 11 under -- invite someone under the age of 18 12 to Jeffrey's home, any of his homes?¶
13 MR. PAGLIUCA: Object to the form 14 foundation.¶
15 A. Can you repeat the question?¶
16 Q. Did you ever invite anybody who was 17 under the age of 18 to Jeffrey's homes?¶
18 MR. PAGLIUCA: Same objections.¶
19 A. I have a number of friends that 20 have children and friends of mine that have 21 kids and in the invitation of my friends and 22 their kids, I'm sure I may have invited some 23 of my friend's kids to come.¶
24 Q. Anybody that is not a friend of 25 yours.¶
Questions About Meeting the Plaintiff and Massages with Plaintiff¶
2 A. held herself out¶
3 Q. I'm not asking how she held herself¶
4 out. I'm asking how she arrived at the home.¶
S Did you meet her and invite her to come to¶
6 the home or how did she arrive there?¶
7 MR. PAGLIUCA: Object to the form¶
8 and foundation.¶
9 A. held her to be a¶
10 masseuse and her mother drove her to the¶
11 house.¶
12 Q. When did you first meet¶
_4 A. I don't have a recollection of the¶
15 first meeting.¶
16 Q. Do you recall meeting her at¶
17 Mar-a-Lago?¶
18 A. Like I said, I don't have a¶
19 recollection of meeting¶
20 Q. So you recall being¶
21 brought to the home by her mother, is that¶
22 your testimony?¶
23 A. That is my testimony.¶
24 Q. And that is the first time you met¶
25 her?¶
2 A. Like I said, I don't recall meeting 3 her the first time. I do remember her mother 4 bringing her to the house.¶
5 Q. Are you a member at Mar-a-Lago?¶
6 A. No.¶
7 Q. Have you visited Mar-a-Lago?¶
8 A. Yes.¶
9 Q. Did you visit Mar-a-Lago in the 10 year 2000?¶
11 A. I'm pretty sure I did.¶
12 Q. When arrived at the 13 home with her mother, what happened?¶
14 A. I spoke to her mother outside of 15 the house and she -- what I don't recall is 16 exactly what happened because I was talking 17 to her mother the entire she was in the 18 house.¶
19 Q. Did you introduce to 20 Jeffrey Epstein?¶
21 A. I don't recall how she actually met 22 Mr. Epstein. As I said, I spoke to her 23 mother the entire time outside the house.¶
24 Q. Did you walk up to the 25 upstairs location at the Palm Beach house to¶
2 absolutely everything that took place in that¶
3 first meeting. She has lied repeatedly,¶
4 often and is just an awful fantasist. So¶
5 very difficult for anything to take place¶
6 that she repeated because I was with her¶
7 mother the entire time.¶
8 Q. So did you have did you give a¶
9 massage with and Mr. Epstein¶
10 during the first time was at¶
11 the West Palm Beach house?¶
12 MR. PAGLIUCA: Object to the form¶
13 and foundation.¶
14 Q. Yes or no?¶
15 A. No.¶
16 Q. Have you ever given a massage with¶
17 in the room and Jeffrey¶
18 Epstein?¶
19 MR. PAGLIUCA: Object to the form¶
20 and foundation.¶
21 A. No.¶
22 Q. Have you ever given Jeffrey Epstein¶
23 a massage?¶
24 MR. PAGLIUCA: Object to the form,¶
25 foundation. And I'm going to instruct¶
Questions About Massages with Minors¶
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¶
Questions About Hiring Massage Therapists¶
2 just another one of Virginia's many 3 fictitious lies and stories to make this a 4 salacious event to get interest and press. 5 It's absolute rubbish.¶
6 Q. Were you in charge of hiring 7 individuals to provide massages for Jeffrey 8 Epstein?¶
9 A. My job included hiring many people. 10 There were six homes. As I sit here, I hired 11 assistants, I hired architects, I hired 12 decorators, I hired cooks, I hired cleaners, 13 I hired gardeners, I hired pool people, I 14 hired pilots, I hired all sorts of people.¶
15 In the course and a very small part 16 of my job was from from time to time to find 17 adult professional massage therapists for 18 Jeffrey.¶
19 Q. When you say adult professional 20 massage therapists, where did you find these 21 massage therapists?¶
22 A. From time to time I would visit 23 professional spas, I would receive a massage 24 and if the massage was good I would ask that 25 man or woman if they did home visits.¶
Questions About¶
¶
2 here today I do not.¶
3 Q. Ms. Maxwell, when did you first¶
4 meet¶
5 MR. PAGLIUCA: Object to the form¶
6 and foundation.¶
7 A. I have no idea when I met her.¶
8 Q. Do you know how old she was when¶
9 you met her?¶
10 A. I have no idea how old she was when¶
11 I met her.¶
12 Q. Is it possible she was 13 years old¶
13 when you first met her?¶
14 MR. PAGLIUCA: Object to the form¶
15 and foundation.¶
16 A.¶
U¶
18 may have been in the house when Jeffrey was¶
19 in the house. I have no idea how old she¶
20 was.¶
21 Q. I understand she was with III¶
22¶
23 I'm asking if was 13¶
24 years old when you first met her?¶
25 A. I have no idea.¶
2 Q. Was she under 18 when you first met 3 her?¶
4 A. I have no idea how old she was when 5 I first met her.¶
6 Q. Did she look like a child when you 7 first met her?¶
8 A. I don't remember what she looked 9 like at the time she was in the house.¶
10 Q. How many years have you known her?¶
11 A. I can only recall the last time I 12 saw her.¶
13 Q. When was the first time you met 14 her?¶
15 A. Again, I just told you, I don't 16 recall the first time I met her.¶
17 Q. Did travel with you 18 on Jeffrey's planes?¶
19 A. I wouldn't remember if was cr, 20 the plane or not.¶
21 Q. Did you ever have sex with 22¶
23 A. No.¶
24 Q. Did you ever observe Jeffrey having 25 sex with¶
2 A. No.¶
3 Q. Were you aware that Jeffrey was¶
4 having sexual contact with when¶
5 she was 13 years old?¶
6 MR. PAGLIUCA: Object to the form¶
7 and foundation.¶
8 A. I would be very shocked and¶
9 surprised if that were true.¶
10 Q. Were you in the house when¶
was in the house in a private area¶
12 with Jeffrey Epstein?¶
13 MR. PAGLIUCA: Object to the form¶
14 and foundation.¶
15 A. Can you repeat the question.¶
16 Q. Were you ever in the Palm Beach¶
17 house when Jeffrey Epstein was in the house¶
18 with¶
19 MR. PAGLIUCA: Object to the form¶
20 and foundation.¶
21 A. I've already testified that I have¶
22 met her and that she was there¶
23 I don't understand what your¶
24 question is asking.¶
25 Q. So you have never seen¶
2¶
3 MR. PAGLIUCA: Object to the form 4 and foundation.¶
5 Q. Is that your testimony?¶
6 A. I already 7 8 of that. said I don't recall all the times I've seen her and I have no memory¶
9 Q. 10 the house with Have you ever seen in Jeffrey Epstein¶
11¶
12 13 MR. PAGLIUCA: Object to the form and foundation.¶
14 15 A. I just told you I don't recall seeing¶
16 17 with Q. Were you ever involved in an orgy¶
18 A. No, absolutely not.¶
19 Q. 20 individual by the name of Can you tell me, do you know an¶
21 A. I do.¶
22 Q. How did you meet¶
23 A. At some 24 Jeffrey's and I recall 25 point. point she was a friend of meeting her at some¶
2 Q. Did Jeffrey arrange for a visa for¶
3¶
4 A. I don't know what Jeffrey did. I¶
5 cannot testify what Jeffrey did.¶
6 Q. Was involved in sex with¶
7 Jeffrey and other girls?¶
8 MR. PAGLIUCA: Object to the form¶
9 and foundation.¶
10 Q. Girls under the age of 18?¶
11 MR. PAGLIUCA: Same objection.¶
12 A. I have no idea.¶
13 Q. Was involved with sex with¶
14 Jeffrey and girls over the age of 18?¶
15 MR. PAGLIUCA: Same objection.¶
16 A. I have no idea.¶
17 Q. Did recruit other girls for¶
18 sex with Jeffrey?¶
19 MR. PAGLIUCA: Object to the form¶
20 and foundation.¶
21 A. I have no idea.¶
22 Q. Do you still talk to¶
23 A. No.¶
24 Q.¶
25 A. I have no idea.¶
Questions About Mr. Epstein and Sex¶
2 acts. I'm asking whether any of the massage¶
3 therapists performed sexual acts for Mr.¶
4 Epstein, as I have just described?¶
5 A. I have never seen anybody have¶
6 sexual intercourse with with Jeffrey, ever.¶
7 Q. I'm not asking about sexual¶
8 intercourse. I'm asking about any sexual¶
9 act, touching of the breast -- did you ever¶
10 see can you read back the question?¶
11 (Record read.)¶
12 A. I'm not addressing any questions¶
13 about consensual adult sex. If you want to¶
14 talk about what the subject matter, which is¶
15 defamation and lying, that¶
16 you and are participating in¶
17 perpetrating her lies, I'm happy to address¶
18 those. I never saw any inappropriate¶
19 underage activities with Jeffrey ever.¶
20 Q. I'm not asking about underage. I'm¶
21 asking about whether any of the masseuses¶
22 that were at the home perform sexual acts for¶
23 Jeffrey Epstein?¶
24 A. I have just answered the question.¶
25 Q. No, you haven't.¶
Questions About Glen, Plaintiff, and Sex¶
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 19 her. I'm making sure the record is clear.¶
20 21 22 23 MR. PAGLIUCA: Certainly can you apply to have someone come back and the court may or may not have her come back again.¶
24 25 Again, she is not answering questions that relate to adult consent¶
2 sex acts. Period. And that's the¶
3 instruction and we can take it up with¶
4 the court.¶
5 Q. Ms. Maxwell, are you aware of any¶
6 sexual acts with masseuses and Jeffrey¶
7 Epstein that were nonconsensual?¶
8 A. No.¶
9 Q. How do you know that?¶
10 A. All the time that I have been in¶
11 the house I have never seen, heard, nor¶
12 witnessed, nor have reported to me that any¶
13 activities took place, that people were in¶
14 distress, either reported to me by the staff¶
15 or anyone else. I base my answer based on¶
16 that.¶
17 Q. Are you familiar with a person by¶
18 the name of¶
19 A. I am.¶
20 Q. Has given a statement¶
21 to police about you performing sexual acts on¶
22 her?¶
23 A. I have not heard that.¶
24 Q. Has given a statement¶
25 to police about Jeffrey Epstein performing¶
2 asked and answered already.¶
3 Q. You can answer the question.¶
4 A. I have no idea what 5 did.¶
6 7 8 Q. You never observed with girls under the age of 18 at Jeffrey's home?¶
9 10 MR. PAGLIUCA: Object to the form and foundation.¶
11 A. The answer is no, I have no idea.¶
12 Q. Do you know Glenn ?¶
13 A. I do.¶
14 15 Q. What is your relationship with Glenn ?¶
16 MR. PAGLIUCA: Object to the form.¶
17 18 relationship. A. What do you mean what is my¶
19 20 Q. Are you friendly with him, how do you know him?¶
21 A. He is the husband of Eva¶
22 Q. Is Eva one of your friends?¶
23 A. Yes.¶
24 Q. Did you ever send Virginia to¶
25 Glenn's condo at the Breakers to give him a¶
2 massage?¶
3 MR. PAGLIUCA: Objection to the¶
4 form and foundation.¶
5 A. No.¶
6 Q. Did you ever instruct¶
to have sex with Glenn?¶
8 MR. PAGLIUCA: Objection to the¶
9 form and foundation.¶
10 A. I have never instructed Virginia to¶
11 have sex with anybody ever.¶
12 Q. How old was Eva when she¶
13 met Jeffrey?¶
14 MR. PAGLIUCA: Objection to the¶
15 form and foundation.¶
16 A. I have no idea.¶
17 Q. What's she under the age of 18?¶
18 MR. PAGLIUCA: Objection to the¶
19 form and foundation.¶
20 A. I just testified I have idea how¶
21 old she was.¶
22 Q. You testified she was your friend.¶
23 You don't know how old she was when she met¶
24 Jeffrey?¶
25 A. That happened sometime in the '70s,¶
2 how would I know, or '80s. I have no idea.¶
3 Can you testify to what your friends did 30¶
4 years ago?¶
5 Q. You don't ask the questions here,¶
6 Ms. Maxwell.¶
7 What about, when¶
8 did you first meet¶
9 A. I don't recall the exact date.¶
10 Q. Did you hire¶
11 A. I don't hire people, she came to¶
12 work at the house to answer phones.¶
13 Q. Where did you meet her?¶
14 A. I just testified, I don't recall¶
15 exactly when I met her.¶
16 Q. Was one of your job¶
17 responsibilities to interview people that¶
18 would be then hired by Jeffrey?¶
19 A. That was one of my¶
20 responsibilities.¶
21 Q. Do you recall interviewing¶
22 A. I don't recall the exact interview,¶
23 no.¶
24 Q. Do you know what tasks was¶
25 hired to performance?¶
2 A. She was tasked to answer¶
3 telephones.¶
4 Q. Did you ever ask her to rub¶
5 Jeffrey's feet?¶
6 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 that she 11 would get extra money if she provided Jeffrey 12 massages?¶
13 A. I was always happy to give career 14 advice to people and I think that becoming 15 somebody in the healthcare profession, either 16 exercise instructor or nutritionist or 17 professional massage therapist is an 18 excellent job opportunity. Hourly wages are 19 20 21 22 23 24 25 around 7, 8, $9 and as a professional healthcare provider you can earn somewhere between as we have established 100 to $200 and to be able to travel and have a job that pays that is a wonderful job opportunity. So in the context of advising people for opportunities for work, it is possible that I¶
2 would have said that she should explore that 3 as an option.¶
4 Q. Did you tell her she would get¶
S 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 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 to 17 massage Glenn¶
18 A. I don't believe -- I have no 19 recollection of it.¶
20 Q. Did you ever have sexual contact 21 with¶
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.¶
2 Anything that involves consensual¶
3 sex on your part, I'm instructing you¶
4 not to answer.¶
S Q. Did you ever have sexual contact¶
6 with¶
7 A. Again, she is an adult --¶
8 Q. I'm asking you, did you ever have¶
9 sexual contact with¶
10 A. I've just been instructed not to¶
11 answer.¶
12 Q. On what basis?¶
13 A. You have to ask my lawyer.¶
14 Q. Did you ever have sexual contact¶
15 with that was not consensual on¶
16 part?¶
17 MR. PAGLIUCA: You can answer¶
18 nonconsensual.¶
19 A. I've never had nonconsensual sex¶
20 with anybody.¶
21 Q. Not¶
22 MR. PAGLIUCA: Objection.¶
23 A. I just testified I never had¶
24 nonconsensual sex with anybody ever, at any¶
25 time, at anyplace, at any time, with anybody.¶
2 Q. So if were to testify that 3 she did not consent to a sexual act that you 4 participated in --¶
5 A. I just told you I have never ever 6 under any circumstances with anybody, at any 7 time, in anyplace, in any form had 8 nonconsensual relations with anybody.¶
9 Q. Did you introduce 10¶
11 MR. PAGLIUCA: Objection to the 12 form and foundation.¶
13 A. I've, again, read that 14 claimed that she met or that she said she met 15 I don't know if I was the one 16 who made the introduction or not.¶
17 Q. Do you know a female by the name of 18¶
19 A. I do.¶
20 Q. How do you know her?¶
21 A.¶
22 Q. So she worked for you?¶
23 A. Yes.¶
24 Q. Did you hire her?¶
25 A. Again, Jeffrey hired people.¶
Questions About Virginia, and Ms. Maxwell Regarding Sex¶
2 consensual issue involved, I instruct¶
3 you not to answer.¶
4 A. Moving on.¶
5 Q. So you are refusing to answer that¶
6 question?¶
7 A. I've been instructed by my lawyer.¶
8 Q. Did you ever have sex with Jeffrey,¶
9 Virginia and yourself when Virginia was 10 underage?¶
11 A. Absolutely not.¶
12 MR. PAGLIUCA: We've been going for 13 about an hour. I would like to take a 14 five-minute break, please.¶
15 MS. McCAWLEY: I'm almost done.¶
16 MR. PAGLIUCA: You are not going to 17 allow a break.¶
18 MS. McCAWLEY: As soon as I get 19 through my line of questioning, which is 20 perfectly appropriate.¶
21 Q. Did travel with you and 22 Jeffrey to Europe?¶
23 A. I'm sure she did.¶
24 Q. What is she doing today?¶
25 A. I have no idea.¶
Questions About Outfits and Sex Toys¶
2 about.¶
3 Q. So you didn't provide her with¶
4 that?¶
5 A. As I just testified, I have no idea¶
6 what you are talking about.¶
7 Q. I was trying to interpret whether¶
8 you didn't understand what a school girl¶
9 outfit was or you are saying that didn't¶
10 happen?¶
11 A. I clearly know what a school girl¶
12 outfit is. I have no recollection of¶
13 providing anybody with a school girl outfit.¶
14 Q. Did you have a set of outfits used¶
15 by the massage therapists that would include¶
16 things like a school girl outfit or a black¶
17 patent leather outfit or anything of that¶
18 nature?¶
19 MR. PAGLIUCA: Object to the form¶
20 and foundation.¶
21 A. That would be just another one of¶
22 Virginia's lies.¶
23 Q. You didn't have anything like that?¶
24 A. I did not.¶
25 Q. Did you have a basket of sex toys¶
2 that you kept in the Palm Beach house?¶
3 MR. PAGLIUCA: Objection to the¶
4 form and foundation.¶
5 A. First of all what do you mean.¶
6 Q. A laundry basket that contained sex¶
7 toys in it?¶
8 MR. PAGLIUCA: Objection to the¶
9 form and foundation.¶
10 A. Can you ask the question again?¶
11 Q. Did you have a laundry basket that¶
12 contained sex toys in it, in the Palm Beach¶
13 House?¶
14 MR. PAGLIUCA: Objection to the¶
15 form and foundation.¶
16 Q. Did you have a laundry basket of¶
17 sex toys in the Palm Beach house?¶
18 MR. PAGLIUCA: Same objection.¶
19 Q. You can answer.¶
20 A. I don't recollect anything about a¶
21 laundry basket of sex toys.¶
22 Q. Do you recollect having sex toys at¶
23 the Palm Beach house?¶
24 A. You have to define what are you¶
25 talking about.¶
Questions About Plaintiff and Epstein and Sex¶
2 3 of Q. Do you recall having a basket full sex toys?¶
4 A. I already told you I did not.¶
5 Q• We were talking a moment ago about 6 and her position as a masseuse, 7 do you know what she was paid for working as 8 a masseuse for Jeffrey Epstein?¶
9 A. I do not.¶
10 Q. Did you ever pay her?¶
11 A. I don't ever recall paying her.¶
12 Q. Do you know what happened during 13 the massage appointments with Jeffrey Epstein 14 and¶
15 MR. PAGLIUCA: Objection to the 16 form and foundation.¶
17 A. No.¶
18 Q. Were you ever present to view a massage between Jeffrey Epstein and II ?¶
21 A. I don't recollect ever seeing 22 Virginia and Jeffrey in a massage situation.¶
23 Q. Do you ever recollect seeing them 24 in a sexual situation?¶
25 A. I never saw them in a sexual¶
2 situation.¶
3 Q. Did you ever participate in sex¶
4 with and Jeffrey Epstein?¶
S 6 7 8 9 10 11 A. any point I never ever at any single time at ever at all participated in anything with Virginia and Jeffrey. And for the record, she is an absolute total liar and you all know she lied on multiple things and that is just one other disgusting thing she added.¶
12 Q. Did you help her obtain an¶
13 apartment in Palm Beach to live in?¶
14 15 MR. PAGLIUCA: Objection to the form and foundation.¶
16 17 Q. Was that part of your responsibilities for Jeffrey?¶
18 19 20 21 A. First of all, I didn't know she had an apartment in Palm Beach. I only learned that from the many times you guys have gone to the press to sell stories, so no.¶
22 23 24 25 Q. Did you help her get a cell phone, was that one of your responsibilities for Jeffrey, to get her is a cell phone as part of her masseuse obligations?¶
Questions About Training Plaintiff to Recruit Girls for Massages¶
2 form and foundation.¶
3 A. Like I told you, I don't recall her 4 being at the house at all.¶
S Q. How many homes does Jeffrey have?¶
6 MR. PAGLIUCA: Objection to the 7 form and foundation.¶
8 A. When I was working for him, I think 9 he had six maybe.¶
10 Q. Would Virginia stay with him in 11 those homes?¶
12 MR. PAGLIUCA: Objection to the 13 form and foundation.¶
14 A. I can only testify for when I was 15 present with him and I cannot say what she 16 did when I wasn't present with him.¶
17 Q. When you were present, would 18 Virginia stay in the homes with him?¶
19 A. I don't recall her staying in the 20 houses.¶
21 Q. Did you train Virginia on how to 22 recruit other girls for massages?¶
23 MR. PAGLIUCA: Objection to the 24 form and foundation.¶
25 A. No.¶
2 Q. Did you train Virginia on how to 3 recruit other girls to perform sexual 4 massages?¶
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¶
Questions About Ms. Maxwell's Relationship with Mr. Epstein¶
2 has perpetrated, cannot tell you what is true¶
3 or factual or not.¶
4 Q. You said you were in the home a¶
5 very limited time, so average in the year for¶
6 example, 2004, how many times would you have¶
7 been in his Palm Beach home?¶
8 A. Very hard for me to state but very¶
9 little.¶
10 Q. How about his New York home?¶
11 A. Same.¶
12 Q. Were you his girlfriend in that¶
13 year, in 2004?¶
14 A. Define what you mean by girlfriend.¶
15 Q. Were you in a relationship with him¶
16 where you would consider yourself his¶
17 girlfriend?¶
18 A. No.¶
19 Q. Did you ever consider yourself his¶
20 girlfriend?¶
21 A. That's a tricky question. There¶
22 were times when I would have liked to think¶
23 of myself as his girlfriend.¶
24 Q. When would that have been?¶
25 A. Probably in the early '90s.¶
Questions About Recruiting Girls, an Underage Girl in London, and Foreign Girls¶
2 A. First of all I resent and despise 3 the world recruit. Would you like to define 4 what you mean by recruit and by girls, you 5 mean underage people. I never had to do 6 anything with underage people. So why don't 7 you reask the question in a way that I am 8 able to answer it.¶
9 Q. I'm asking if you ever said that to 10 anybody. So if you don't understand the word 11 recruit and you never used that word then the 12 answer to that question would be no.¶
13 A. I have no memory as I sit here 14 today having used that word.¶
15 Q. Did you ever meet an underage girl 16 in London to introduce her to Jeffrey to 17 provide him with a massage?¶
18 MR. PAGLIUCA: Objection to the 19 form and foundation.¶
20 A. Run that past me one more time.¶
21 Q. Did you ever meet an underage girl 22 in London to introduce her to Jeffrey to 23 perform a massage?¶
24 MR. PAGLIUCA: Same objection.¶
25 A. Are you asking me if I met anybody¶
2 that was underage in London specifically to 3 provide a massage to Jeffrey, is that your 4 question?¶
5 Q. Yes.¶
6 A. No.¶
7 Q. Do you know who is?¶
8 A. I don't recall her right now.¶
9 Q. Do you know if -- strike that.¶
10 During the time that you were¶
11 working for Jeffrey, did you ever observe any¶
12 foreign females, so in other words, not from¶
13 the United States, that were brought to¶
14 Jeffrey's home to perform massages?¶
15 MR. PAGLIUCA: Objection to the¶
16 form and foundation.¶
17 A. Females, what age are we talking?¶
18 Q. Any age.¶
19 A. Can you repeat the question?¶
20 Q. During the time you were working¶
21 for Jeffrey, did you ever observe any foreign¶
22 females of any age that were at Jeffrey's¶
23 home to perform a massage?¶
24 MR. PAGLIUCA: Objection to the¶
25 form and foundation.¶
2 A. Are you asking me if any foreigner, 3 not an American person, gave Jeffrey a 4 massage?¶
S Q. Yes.¶
6 A. Well, as I sit here today, I can't 7 think of anyone who is foreign. Certainly -- 8 I just can't think of anybody right this 9 second.¶
10 Q. How about any foreign girls who 11 were under the age of 18?¶
12 A. I already testified to not knowing 13 anything about underage girls.¶
14 Q. Were there foreign girls who were 15 brought to Jeffrey's home by 16 for the purposes of providing massages?¶
17 MR. PAGLIUCA: Objection to the 18 form and foundation.¶
19 A. I am not aware of bringing 20 girls. I have not no idea what you are 21 talking about.¶
22 Q. You have never been around foreign 23 girls who are under the age of 18 at 24 Jeffrey's homes?¶
25 MR. PAGLIUCA: Objection to the¶
2 form and foundation.¶
3 A. I already testified about not¶
4 knowing about underage girls.¶
5 Q. Did you provide any assistance with¶
6 obtaining visas for foreign girls that were¶
7 under the age of 18?¶
8 A. I've never participated in helping¶
9 people of any age to get visas.¶
10 Q. Did Jeffrey, was it Jeffrey's¶
11 preference to start a massage with sex?¶
12 MR. PAGLIUCA: Objection to the¶
13 form and foundation.¶
14 A. I think you should ask that¶
15 question of Jeffrey.¶
16 Q. Do you know?¶
17 A. I don't believe that was his¶
18 preference. I think -- you have to¶
19 understand, a massage -- perhaps you are not¶
20 really familiar with what massage is.¶
21 Q. I am, I don't need a lecture on¶
22 massage.¶
23 A. I think you do.¶
24 MR. PAGLIUCA: No question pending.¶
25 She will ask you another question now.¶
Questions About Underage Girls, Sex with, and Outfits¶
2 Q. Were you present on the island when¶
3 visited?¶
4 A. Yes.¶
5 Q. How many times?¶
6 A. I can only remember once.¶
7 8 9 10 Q. Were there any girls under the age of 18 on the island during that one visit that you remember that were not family or friends of or daughters of your friends?¶
11 12 MR. PAGLIUCA: Objection to the form and foundation.¶
13 14 15 16 17 18 A. There were no girls on the island at all. No girls, no women, other than the staff who work at the house. Girls meaning, I assume you are asking underage, but there was nobody female outside of the cooks and the cleaners.¶
19 20 21 Q. Did you, as part of your duties in working for Jeffrey, ever arrange for Virginia to have sex with¶
22 23 MR. PAGLIUCA: Objection to the form and foundation.¶
24 25 A. Just for the record, I have never at any time, at anyplace, in any moment ever¶
3 called now to have sex with anybody.¶
4 Q. Did you ever provide¶
I with an outfit, an outfit of a sexual¶
6 nature to wear for¶
7 MR. PAGLIUCA: Objection to the¶
8 form and foundation.¶
9 10 A. I think we addressed the outfit issue.¶
11 Q. I am asking you if you ever¶
12 provided her with an outfit of a sexual¶
13 nature to wear for¶
14 A. Categorically no. You did get¶
15 that, I said categorically no¶
16 Q. Don't worry I'm paying attention.¶
17 18 moment. A. You seemed very distracted in that¶
19 (Maxwell Exhibit 6, flight logs,¶
20 marked for identification.)¶
21 22 the bathroom. A. Do you mind if I take a break for¶
23 24 Q. It's 11:08 and we are going to go off the record now.¶
25 THE VIDEOGRAPHER: It's now 11:09.¶
2 asked or whatever she is¶
Questions About Pictures of Naked Girls¶
2 people could use -- just like you would use¶
3 if you needed to go online to get something,¶
4 that people could use.¶
5 Q. Was that on a desk that you would¶
6 use in your work capacity when you were at¶
7 the house?¶
8 A. It was a desk, it was a room I was,¶
9 I didn't really use that computer.¶
10 Q. Were there images of naked girls¶
11 whether they be under the age of 18 or over¶
12 the age of 18 on that computer?¶
13 A. I have no recollection of any naked¶
14 people on that computer when I was there in¶
15 2003, we are talking.¶
16 Q. What about from say '99 to 2003?¶
17 A. No, I can't recollect any naked¶
18 pictures.¶
19 Q. Why were the computers removed from¶
20 the house before the search warrant was¶
21 executed?¶
22 MR. PAGLIUCA: Objection to the¶
23 form and foundation.¶
24 A. I have no knowledge of anything¶
25 like that.¶
Questions About Topless Females¶
2 form and foundation.¶
3 A. I mean I've been to his -- in the¶
4 mid '90s, I would have communicated with¶
5 people who worked for him.¶
6 Q. Have you communicated with¶
7 about this case?¶
8 A. No.¶
9 Q. Have you ever seen a topless female 10 at any one of Jeffrey Epstein's properties?¶
11 MR. PAGLIUCA: Objection to the¶
12 form and foundation. You've asked this 13 question, by the way, earlier on today.¶
14 A. Again, I testified that there are 15 people who from time to time in the privacy 16 of a swimming pool have maybe taken a bikini 17 top off or something but it's not common and 18 certainly when I was at the house I don't 19 really recollect seeing that kind of 20 activity.¶
21 Q. Have you ever smoked cigarettes?¶
22 A. Yes.¶
23 Q. Have you ever smoked cigarettes 24 with¶
25 A. I don't recall smoking cigarettes¶