Draft: efta02788919

COMPOSITE EXHIBIT 1 (Filed Under Seal)¶

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶

x¶

f¶

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¶

Page 2¶

1
2 APPEARANCES:
3
4 BOIES SCHILLER & FLEXNER, LLP
Attorneys for Plaintiff
401 East Las Olas Boulevard
Fort Lauderdale, Florida, 33301
5 BY: SIGRID McCAWLEY, ESQUIRE
MEREDITH [REDACTED] ESQUIRE
EMMA [REDACTED] PARALEGAL
7
8 [REDACTED] JAFFE WEISSING [REDACTED] FISTOS &
9 LEHRMAN, P.L.
Attorneys for Plaintiff
425 N. Andrews Avenue
Fort Lauderdale, Florida 33301
10 BY: BRAD [REDACTED] ESQUIRE
11
12 PAUL G. CASSELL, ESQUIRE
Attorneys for Plaintiff
383 South University Street
Salt Lake City, Utah 84112
13
14
15
16 HADDON [REDACTED]
Attorneys for Defendant
150 East 10th Avenue
Denver, Colorado 80203
18 BY: JEFFREY S. PAGLIUCA, ESQUIRE
LAURA A. MENNINGER, ESQUIRE
19
20
21 Also Present:
22 James Christe, videographer
23
24
25¶

Page 3¶

1 THE VIDEOGRAPHER: We are now on
2 the record and recording. This begins
3 disk No. 1 in the deposition of
4 Ghislaine Maxwell in the matter of
5 [REDACTED] versus Ghislaine
6 Maxwell in the U.S. District Court for
7 the Southern District of New York.
8 Today is April 22, 2016 the time is
9 9:04 a.m.. This deposition is being
10 taken at 575 Lexington Avenue in New
11 York at the request of Sigrid McCawley
12 of Boies Schiller & Flexner.
13 The videographer is James Christe
14 and the court reporter is Leslie Fagin.
15 Will counsel state their appearance and
16 whom they represent and then court
17 reporter swear in Ms. Maxwell.
18 MS. McCAWLEY: My name is Sigrid
19 McCawley with my colleague Meredith
20 [REDACTED]. We are with Boies Schiller &
21 Flexner. We represent [REDACTED]
22 MR. [REDACTED]: Brad [REDACTED]. I also
23 represent [REDACTED].
24 MR. CASSELL: Paul Cassell, I also
25¶

Page 4¶

1 G Maxwell - Confidential
2 represent [REDACTED].
3 MR. PAGLIUCA: Jeff Pagliuca and
4 Laura Menninger on behalf of Ms.
5 Maxwell.
6 G H I S L A I N E M A X W E L L, called
7 as a witness, having been duly sworn by a
8 Notary Public, was examined and testified as
9 follows:
10 EXAMINATION BY
11 MS. McCAWLEY:
12 Q. Good morning. I'm going to explain
13 some of the rules that will happen with
14 respect to depositions.
15 Have you ever been deposed before?
16 A. I have not.
17 Q. What is going to happen here, we
18 have a court reporter and a videographer.
19 What they do is take down the words that we
20 say so when I ask you a question they will
21 record what you say in response to that. So
22 we have to be mindful that in order for them
23 to do their job we can't talk over each
24 other.
25 Another issue you have to be weary¶

Page 5¶

1 G Maxwell - Confidential
2 of is that in a response, you can't give a
3 nonverbal response, in other words, nodding a
4 yes or no, they need to hear verbal response
5 so they can record it on their transcript.
6 So that's important for you to remember as we
7 go through the day. If you forget, I will be
8 sure to remind you.
9 Is there anything that would
10 prevent you from giving truthful testimony
11 today?
12 A. There is not.
13 Q. You are not on any medications or
14 anything that would inhibit your ability to
15 remember or give truthful testimony?
16 A. I am not.
17 MR. PAGLIUCA: Could you identify
18 the assistant in the room.
19 MS. McCAWLEY: This is Emma [REDACTED]
20 from our New York office. She is a
21 paralegal.
22 [REDACTED]. Maxwell, can you please state
23 your address for the record?
24 A. Currently [REDACTED].
25 Q. What is your date of birth?¶

<p>Page 6</p> <p>1 G Maxwell - Confidential</p> <p>2 A. [REDACTED]</p> <p>3 Q. When did you first recruit a female</p> <p>4 to work for Mr. Epstein?</p> <p>5 MR. PAGLIUCA: I object to the form</p> <p>6 and foundation of the question. I</p> <p>7 believe this is confidential</p> <p>8 information. I ask anyone who is not</p> <p>9 admitted in this case be excused from</p> <p>10 the room, please.</p> <p>11 MS. McCAWLEY: So the response to</p> <p>12 that question would --</p> <p>13 MR. PAGLIUCA: The subject matter</p> <p>14 of this question is confidential and I'm</p> <p>15 designating it as confidential.</p> <p>16 MS. McCAWLEY: I just want to make</p> <p>17 that clear for the record.</p> <p>18 MR. [REDACTED]: So we don't delay the</p> <p>19 deposition I will step out of the room</p> <p>20 but I think it's important to lay the</p> <p>21 record that --</p> <p>22 MR. PAGLIUCA: I'm sorry, you are</p> <p>23 not admitted in this proceeding so you</p> <p>24 are not entitled to make any record. If</p> <p>25 Ms. McCawley wants to make a record she</p>	<p>Page 8</p> <p>1 G Maxwell - Confidential</p> <p>2 It's in the process of being sold. It still</p> <p>3 requires some final paperwork to be done, so</p> <p>4 just for the purposes of clarity.</p> <p>5 Q. Do you have a new address where you</p> <p>6 will be living?</p> <p>7 A. I do not.</p> <p>8 Q. For the purpose of the record, if</p> <p>9 there is something I ask you that you later</p> <p>10 remember something else or need to correct</p> <p>11 your testimony in some way, you can do that,</p> <p>12 just let me know what it is and we will go</p> <p>13 back to that question and can you clarify.</p> <p>14 A. Of course. I just wanted to be</p> <p>15 clear, there is still some paperwork pending</p> <p>16 for final release, but it's in the process of</p> <p>17 sale. But I don't have another address</p> <p>18 currently, so whilst that should still be of</p> <p>19 record that the mail could be forwarded</p> <p>20 there, so for purposes of clarity I wanted to</p> <p>21 be clear.</p> <p>22 Q. I appreciate that.</p> <p>23 So Ms. Maxwell, when did you first</p> <p>24 recruit a female to work for Mr. Epstein?</p> <p>25 MR. PAGLIUCA: Again. I object to</p>
<p>Page 7</p> <p>1 G Maxwell - Confidential</p> <p>2 can.</p> <p>3 MR. [REDACTED]: I can make a record</p> <p>4 right now.</p> <p>5 MR. PAGLIUCA: Maybe we should get</p> <p>6 the judge on the phone and talk about</p> <p>7 it.</p> <p>8 MR. [REDACTED]: The record will be</p> <p>9 short. This is the precise reason why</p> <p>10 [REDACTED] wants me in this case and</p> <p>11 I'm unable to effectively represent her</p> <p>12 at this time because I am unable to have</p> <p>13 access to the confidential information</p> <p>14 which includes apparently the entire</p> <p>15 deposition of Ms. Maxwell. But for the</p> <p>16 sake of not further delaying this, I</p> <p>17 will be outside the room.</p> <p>18 MS. McCAWLEY: Thank you.</p> <p>19 A. I would like to just -- wait for</p> <p>20 him to leave.</p> <p>21 Q. That's fine.</p> <p>22 A. I would just like to clarify the</p> <p>23 address. I'm in the process of selling the</p> <p>24 house so while while I still receive mail</p> <p>25 there, it's not my actual physical address.</p>	<p>Page 9</p> <p>1 G Maxwell - Confidential</p> <p>2 form and foundation of the question.</p> <p>3 Q. You can answer the question.</p> <p>4 A. First of all, can you please</p> <p>5 clarify the question. I don't understand</p> <p>6 what you mean by female, I don't understand</p> <p>7 what you mean by recruit. Please be more</p> <p>8 clear and specific about what you are</p> <p>9 suggesting.</p> <p>10 Q. Are you a female, is that the sex</p> <p>11 that you are?</p> <p>12 A. I am a female.</p> <p>13 Q. That's what I'm referring to a</p> <p>14 female and I'm asking you when you first, the</p> <p>15 very first time you recruited a female to</p> <p>16 work for Mr. Epstein?</p> <p>17 A. Again, I don't understand what</p> <p>18 female -- I am a 54 year old women.</p> <p>19 Q. I'm not making it age, any age of a</p> <p>20 female that you recruited to work for Mr.</p> <p>21 Epstein?</p> <p>22 A. Again, I was somebody who hired a</p> <p>23 number of people to work for Mr. Epstein and</p> <p>24 hiring is one of my functions.</p> <p>25 Q. And when is the first time you</p>

Page 6 1 G Maxwell - Confidential 2 A. [REDACTED] 3 Q. When did you first recruit a female 4 to work for Mr. Epstein? 5 MR. PAGLIUCA: I object to the form 6 and foundation of the question. I 7 believe this is confidential 8 information. I ask anyone who is not 9 admitted in this case be excused from 10 the room, please. 11 MS. McCAWLEY: So the response to 12 that question would -- 13 MR. PAGLIUCA: The subject matter 14 of this question is confidential and I'm 15 designating it as confidential. 16 MS. McCAWLEY: I just want to make 17 that clear for the record. 18 MR. [REDACTED]: So we don't delay the 19 deposition I will step out of the room 20 but I think it's important to lay the 21 record that -- 22 MR. PAGLIUCA: I'm sorry, you are 23 not admitted in this proceeding so you 24 are not entitled to make any record. If 25 Ms. McCawley wants to make a record she

Page 8 1 G Maxwell - Confidential 2 It's in the process of being sold. It still 3 requires some final paperwork to be done, so 4 just for the purposes of clarity. 5 Q. Do you have a new address where you 6 will be living? 7 A. I do not. 8 Q. For the purpose of the record, if 9 there is something I ask you that you later 10 remember something else or need to correct 11 your testimony in some way, you can do that, 12 just let me know what it is and we will go 13 back to that question and can you clarify. 14 A. Of course. I just wanted to be 15 clear, there is still some paperwork pending 16 for final release, but it's in the process of 17 sale. But I don't have another address 18 currently, so whilst that should still be of 19 record that the mail could be forwarded 20 there, so for purposes of clarity I wanted to 21 be clear. 22 Q. I appreciate that. 23 So Ms. Maxwell, when did you first 24 recruit a female to work for Mr. Epstein? 25 MR. PAGLIUCA: Again. I object to

Page 7 1 G Maxwell - Confidential 2 can. 3 MR. [REDACTED]: I can make a record 4 right now. 5 MR. PAGLIUCA: Maybe we should get 6 the judge on the phone and talk about 7 it. 8 MR. [REDACTED]: The record will be 9 short. This is the precise reason why 10 [REDACTED] wants me in this case and 11 I'm unable to effectively represent her 12 at this time because I am unable to have 13 access to the confidential information 14 which includes apparently the entire 15 deposition of Ms. Maxwell. But for the 16 sake of not further delaying this, I 17 will be outside the room. 18 MS. McCAWLEY: Thank you. 19 A. I would like to just -- wait for 20 him to leave. 21 Q. That's fine. 22 A. I would just like to clarify the 23 address. I'm in the process of selling the 24 house so while while I still receive mail 25 there, it's not my actual physical address.

Page 9 1 G Maxwell - Confidential 2 form and foundation of the question. 3 Q. You can answer the question. 4 A. First of all, can you please 5 clarify the question. I don't understand 6 what you mean by female, I don't understand 7 what you mean by recruit. Please be more 8 clear and specific about what you are 9 suggesting. 10 Q. Are you a female, is that the sex 11 that you are? 12 A. I am a female. 13 Q. That's what I'm referring to a 14 female and I'm asking you when you first, the 15 very first time you recruited a female to 16 work for Mr. Epstein? 17 A. Again, I don't understand what 18 female -- I am a 54 year old women. 19 Q. I'm not making it age, any age of a 20 female that you recruited to work for Mr. 21 Epstein? 22 A. Again, I was somebody who hired a 23 number of people to work for Mr. Epstein and 24 hiring is one of my functions. 25 Q. And when is the first time you

<p>Page 10</p> <p>1 G Maxwell - Confidential</p> <p>2 hired someone to work for Mr. Epstein, a</p> <p>3 female?</p> <p>4 A. As best as I can recollect, a woman</p> <p>5 the age probably of about 40 or 50 was in</p> <p>6 sometime in 1992.</p> <p>7 Q. How long did you work for Mr.</p> <p>8 Epstein?</p> <p>9 A. I started working for him at some</p> <p>10 point in 1992 and the nature of my work</p> <p>11 relationship with him changed over time so</p> <p>12 from around 2002, 2003, the work lessened</p> <p>13 considerably.</p> <p>14 Q. When did you --</p> <p>15 MR. PAGLIUCA: Can I interject for</p> <p>16 a moment. If we are talking about</p> <p>17 background --</p> <p>18 MS. McCAWLEY: I'm in the middle of</p> <p>19 a question. Let me finish it and then</p> <p>20 can you interject.</p> <p>21 Q. When you say 2002 to 2003 that the</p> <p>22 work lessened, when did you complete working</p> <p>23 for Mr. Epstein; when was the last time you</p> <p>24 were employed by him, the last date?</p> <p>25 A. I believe I still was doing --</p>	<p>Page 12</p> <p>1 G Maxwell - Confidential</p> <p>2 MR. PAGLIUCA: Object to the form</p> <p>3 and foundation.</p> <p>4 A. My job entailed running the homes</p> <p>5 that he had but much more importantly, most</p> <p>6 of the houses had construction and so whilst</p> <p>7 in 1992 there was no construction project,</p> <p>8 there was construction projects that began</p> <p>9 after that time and I was in charge not only</p> <p>10 of hiring architects, I was also in charge of</p> <p>11 all the filings or overseeing that, like a</p> <p>12 general contractor would.</p> <p>13 I also helped with hiring the</p> <p>14 architects, hiring the builders, reviewing</p> <p>15 the contracts for the builders, coordinating</p> <p>16 the building projects, coordinating how the</p> <p>17 projects would layout, the timing of the</p> <p>18 projects and all the various materials that</p> <p>19 they would require to run a very substantial</p> <p>20 building project. That's the nature of the</p> <p>21 job I was dealing with.</p> <p>22 Q. How old was the youngest female you</p> <p>23 ever hired to work for Jeffrey?</p> <p>24 MR. PAGLIUCA: Object to the form</p> <p>25 and foundation.</p>
<p>Page 11</p> <p>1 G Maxwell - Confidential</p> <p>2 helping him in a very nominal way, maybe an</p> <p>3 hour or two a year at sometime 2008 and 2009.</p> <p>4 MR. PAGLIUCA: So if you are going</p> <p>5 to be talking about general background,</p> <p>6 I don't need to designate that as</p> <p>7 confidential. So if you want to have</p> <p>8 them come back in, that's fine.</p> <p>9 I assumed by your first question</p> <p>10 you were going into more sensitive</p> <p>11 areas. I will leave it up to you, but</p> <p>12 if this is general background it will</p> <p>13 not be designated as confidential.</p> <p>14 MS. McCAWLEY: I appreciate that.</p> <p>15 I will jump back into my other</p> <p>16 questions.</p> <p>17 MR. PAGLIUCA: So we will keep it</p> <p>18 as confidential.</p> <p>19 Q. When you were first employed by him</p> <p>20 in 1992, what were you hired to do?</p> <p>21 A. First, I was consulting and what I</p> <p>22 did was I helped with decorating houses and</p> <p>23 in hiring staff to help run those houses.</p> <p>24 Q. Did your duties change over the</p> <p>25 course of 1992 to 2009?</p>	<p>Page 13</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. You can answer.</p> <p>3 A. I have not any idea exactly of the</p> <p>4 youngest adult employee that I hired for</p> <p>5 Jeffrey.</p> <p>6 Q. When you say adult employee, did</p> <p>7 you ever hire someone that was under the age</p> <p>8 of 18?</p> <p>9 A. Never.</p> <p>10 Q. Did you ever bring someone who was</p> <p>11 under -- invite someone under the age of 18</p> <p>12 to Jeffrey's home, any of his homes?</p> <p>13 MR. PAGLIUCA: Object to the form</p> <p>14 foundation.</p> <p>15 A. Can you repeat the question?</p> <p>16 Q. Did you ever invite anybody who was</p> <p>17 under the age of 18 to Jeffrey's homes?</p> <p>18 MR. PAGLIUCA: Same objections.</p> <p>19 A. I have a number of friends that</p> <p>20 have children and friends of mine that have</p> <p>21 kids and in the invitation of my friends and</p> <p>22 their kids, I'm sure I may have invited some</p> <p>23 of my friend's kids to come.</p> <p>24 Q. Anybody that is not a friend of</p> <p>25 yours.</p>

Page 10 1 G Maxwell - Confidential 2 hired someone to work for Mr. Epstein, a 3 female? 4 A. As best as I can recollect, a woman 5 the age probably of about 40 or 50 was in 6 sometime in 1992. 7 Q. How long did you work for Mr. 8 Epstein? 9 A. I started working for him at some 10 point in 1992 and the nature of my work 11 relationship with him changed over time so 12 from around 2002, 2003, the work lessened 13 considerably. 14 Q. When did you -- 15 MR. PAGLIUCA: Can I interject for 16 a moment. If we are talking about 17 background -- 18 MS. McCAWLEY: I'm in the middle of 19 a question. Let me finish it and then 20 can you interject. 21 Q. When you say 2002 to 2003 that the 22 work lessened, when did you complete working 23 for Mr. Epstein; when was the last time you 24 were employed by him, the last date? 25 A. I believe I still was doing --

Page 12 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. 4 A. My job entailed running the homes 5 that he had but much more importantly, most 6 of the houses had construction and so whilst 7 in 1992 there was no construction project, 8 there was construction projects that began 9 after that time and I was in charge not only 10 of hiring architects, I was also in charge of 11 all the filings or overseeing that, like a 12 general contractor would. 13 I also helped with hiring the 14 architects, hiring the builders, reviewing 15 the contracts for the builders, coordinating 16 the building projects, coordinating how the 17 projects would layout, the timing of the 18 projects and all the various materials that 19 they would require to run a very substantial 20 building project. That's the nature of the 21 job I was dealing with. 22 Q. How old was the youngest female you 23 ever hired to work for Jeffrey? 24 MR. PAGLIUCA: Object to the form 25 and foundation.

Page 11 1 G Maxwell - Confidential 2 helping him in a very nominal way, maybe an 3 hour or two a year at sometime 2008 and 2009. 4 MR. PAGLIUCA: So if you are going 5 to be talking about general background, 6 I don't need to designate that as 7 confidential. So if you want to have 8 them come back in, that's fine. 9 I assumed by your first question 10 you were going into more sensitive 11 areas. I will leave it up to you, but 12 if this is general background it will 13 not be designated as confidential. 14 MS. McCAWLEY: I appreciate that. 15 I will jump back into my other 16 questions. 17 MR. PAGLIUCA: So we will keep it 18 as confidential. 19 Q. When you were first employed by him 20 in 1992, what were you hired to do? 21 A. First, I was consulting and what I 22 did was I helped with decorating houses and 23 in hiring staff to help run those houses. 24 Q. Did your duties change over the 25 course of 1992 to 2009?

Page 13 1 G Maxwell - Confidential 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.

Page 14¶

1 G Maxwell - Confidential
2 Any female under the age of 18, did
3 you invite them to come to Jeffrey's home?
4 MR. PAGLIUCA: Object to the form
5 and foundation.
6 A. Again, as I said, I am not aware of
7 inviting anybody other than friends of mine
8 who have children to the house.
9 Q. Did you invite [REDACTED] to
10 come to Jeffrey Epstein's home when she was
11 under the age of 18?
12 MR. PAGLIUCA: Object to the form
13 and foundation.
14 [REDACTED] held herself out
15 as a masseuse and invited herself to come and
16 give a massage.
17 Q. My question is, did you invite
18 [REDACTED] when she was under the age
19 of 18 to come to Jeffrey Epstein's home?
20 MR. PAGLIUCA: Object to the form
21 and foundation.
22 A. Again, [REDACTED] was a
23 masseuse --
24 Q. I'm asking not asking if she was a
25 masseuse. I'm asking if you invited her to¶

Page 15¶

1 G Maxwell - Confidential
2 come to Jeffrey Epstein's home?
3 A. Again, there would be no course to
4 have a conversation with Virginia unless she
5 held herself out to be a masseuse.
6 Q. I'm not asking that question. I'm
7 asking if you invited her to come to Jeffrey
8 Epstein's home when she was under the age of
9 18?
10 A. Again, I repeat, she was a masseuse
11 and in the form and as my job, I was to have
12 people who he wanted for various things
13 including massage. She came as a masseuse.
14 Q. So you invited her to his home to
15 come to give a massage, is that correct?
16 MR. PAGLIUCA: Object to the form
17 and foundation. Misstates the witness'
18 testimony.
19 A. Again, I did not invite Virginia
20 [REDACTED]. She came as a masseuse.
21 Q. She who invited her to come as a
22 masseuse, she just showed up at the front
23 door?
24 MR. PAGLIUCA: Object to the form
25 and foundation.¶

Page 16¶

1 G Maxwell - Confidential
2 A. [REDACTED] held herself out --
3 Q. I'm not asking how she held herself
4 out. I'm asking how she arrived at the home.
5 Did you meet her and invite her to come to
6 the home or how did she arrive there?
7 MR. PAGLIUCA: Object to the form
8 and foundation.
9 A. [REDACTED] held her to be a
10 masseuse and her mother drove her to the
11 house.
12 Q. When did you first meet Virginia
13 [REDACTED]
14 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 [REDACTED].
20 Q. So you recall [REDACTED] 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?¶

Page 17¶

1 G Maxwell - Confidential
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 [REDACTED] 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 [REDACTED] 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 [REDACTED] up to the
25 upstairs location at the Palm Beach house to¶

<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 [REDACTED] 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. Virginia 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 [REDACTED]</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 [REDACTED] and Mr. Epstein</p> <p>10 during the first time [REDACTED] 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 [REDACTED] 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>

Page 18 1 G Maxwell - Confidential 2 meet Mr. Epstein? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 Q. You can answer. 6 A. I just explained. 7 A. I spent the entire time talking to 8 [REDACTED] mother outside the house so the 9 answer to the question is no. 10 Q. No, did you not walk her up and 11 introduce her to Mr. Epstein? 12 A. I just said no. 13 Q. Did you participate in a massage 14 this first time when she first came to the 15 home and you were speaking with her mother, 16 she was in the home, is that correct, you 17 brought her into the home? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 A. I will repeat again, I was standing 21 outside with her mother so very difficult for 22 me to do anything else at that time so no, I 23 did not take her upstairs. 24 Q. Did you participate -- 25 A. Virginia lied 100 percent about

Page 20 1 G Maxwell - Confidential 2 you not to answer that question. I 3 don't have any problem with you asking 4 questions about what the subject matter 5 of this lawsuit is, which would be, as 6 you've termed it, sexual trafficking of 7 [REDACTED] 8 To the extent you are asking for 9 information relating to any consensual 10 adult interaction between my client and 11 Mr. Epstein, I'm going to instruct her 12 not to answer because it's not part of 13 this litigation and it is her private 14 confidential information, not subject to 15 this deposition. 16 MS. McCAWLEY: You can instruct her 17 not to answer. That is your right. But 18 I will bring her back for another 19 deposition because it is part of the 20 subject matter of this litigation so she 21 should be answering these questions. 22 This is civil litigation, deposition and 23 she should be responsible for answering 24 these questions. 25 MR. PAGLIUCA: I disagree and you

Page 19 1 G Maxwell - Confidential 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 [REDACTED] and Mr. Epstein 10 during the first time [REDACTED] 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 [REDACTED] 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

Page 21 1 G Maxwell - Confidential 2 understand the bounds that I put on it. 3 MS. McCAWLEY: No, I don't. I will 4 continue to ask my questions and you can 5 continue to make your objections. 6 Q. Did you ever participate from the 7 time period of 1992 to 2009, did you ever 8 participate in a massage with Jeffrey Epstein 9 and another female? 10 MR. PAGLIUCA: Objection. Do not 11 answer that question. Again, to the 12 extent you are asking for some sort of 13 illegal activity as you've construed in 14 connection with this case I don't have 15 any problem with you asking that 16 question. To the extent these questions 17 involve consensual acts between adults, 18 frankly, they're none of your business 19 and I will instruct the witness not to 20 answer. 21 MS. McCAWLEY: This case involves 22 sexual trafficking, sexual abuse, 23 questions about her having interactions 24 with other females is relevant to this 25 case. She needs to answer these

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

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 --¶

Page 23 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?¶

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

<p>Page 26</p> <p>1 G Maxwell - Confidential 2 and foundation of the question. 3 A. First of all, can you break the 4 question apart. 5 Q. Have you used the phrase the 6 younger the better in speaking to [REDACTED] 7 and asking her to recruit females for Jeffrey 8 Epstein? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 Q. You can answer. It's yes or no. 12 A. No, that's absolutely not true, on 13 the second part of your question, I have not 14 asked Virginia to recruit females and the 15 first part of your question, if you can 16 repeat that again, the question you asked. 17 Q. Will you read back the question. 18 (Record read.) 19 A. I believe I answered the later part 20 of the question. The first part of the 21 question, it's impossible for me to recall 22 events that took place 16 years ago but it 23 doesn't sound like something I would say. 24 Q. On page 28, that same paragraph, 25 [REDACTED] was asked how many girls in total she</p>	<p>Page 28</p> <p>1 G Maxwell - Confidential 2 A. First of all, as I said when I was 3 present -- 4 Q. It is a yes or no. 5 A. No, it is not. 6 Q. You can answer the question in full 7 but please provide yes or no as an initial 8 matter. 9 A. I cannot answer yes or no, it's not 10 bounded by time. It's entirely possible I 11 could have been in a room or even in the 12 vicinity of Palm beach when somebody came and 13 I would not know. How would I know when 14 somebody was in the house. There is no way I 15 can know. 16 Q. Did you stay at Jeffrey Epstein's 17 home when you were in Palm Beach? 18 A. Most of the time. 19 Q. So how is it that you wouldn't know 20 if there was a female in the home under the 21 age of 18 if you were staying there? 22 A. Well, first of all, when I was 23 staying there, the house is actually quite 24 large and I have a very busy job and I had an 25 office with a door so the door would be shut</p>
<p>Page 27</p> <p>1 G Maxwell - Confidential 2 brought to Epstein. [REDACTED] stated that she 3 can remember, [REDACTED] stated that she brought 4 and, it's redacted there, and the victim in 5 this case. 6 Let me ask my question, I have a 7 question pending right now. 8 Are you testifying that you are 9 unaware of any underage, under the age of 18, 10 females coming to Jeffrey Epstein's home to 11 perform massages? 12 MR. PAGLIUCA: Object to the form 13 foundation. 14 A. You need to straddle that question 15 in a different time period. When I was 16 there, at the time I was present, the people 17 that gave Jeffrey, men and women who gave 18 Jeffrey massages were adults over the age of 19 18. 20 Q. Never in your time at any of 21 Jeffrey Epstein's homes were you present when 22 a female under the age of 18 was there to 23 give Jeffrey Epstein a massage? 24 MR. PAGLIUCA: Object to the form 25 and foundation.</p>	<p>Page 29</p> <p>1 G Maxwell - Confidential 2 and I would be working. I'm not responsible 3 for what Jeffrey does and I don't always pay 4 attention to what happens in the house. I'm 5 very busy. 6 Q. So you're testifying that you never 7 observed a female under the age of 18 at 8 Jeffrey Epstein's West Palm Beach home? 9 MR. PAGLIUCA: Object to the form 10 and foundation. 11 A. I already answered that question, I 12 believe. 13 Q. You didn't answer my question. 14 A. I did. 15 Q. Did you observe a female under the 16 age of 18 at Jeffrey Epstein's home in Palm 17 Beach? 18 A. Like I said, I work, I don't sit 19 there and watch people coming in and out of 20 the house. I cannot possibly tell you if I'm 21 in the home that somebody was there that I 22 did not see, I cannot comment on it, I have 23 no idea. 24 Q. Did you observe females at Jeffrey 25 Epstein's home that were laying out topless</p>

Page 26 1 G Maxwell - Confidential
2 and foundation of the question.
3 A. First of all, can you break the
4 question apart.
5 Q. Have you used the phrase the
6 younger the better in speaking to [REDACTED]
7 and asking her to recruit females for Jeffrey
8 Epstein?
9 MR. PAGLIUCA: Object to the form
10 and foundation.
11 Q. You can answer. It's yes or no.
12 A. No, that's absolutely not true, on
13 the second part of your question, I have not
14 asked Virginia to recruit females and the
15 first part of your question, if you can
16 repeat that again, the question you asked.
17 Q. Will you read back the question.
18 (Record read.)
19 A. I believe I answered the later part
20 of the question. The first part of the
21 question, it's impossible for me to recall
22 events that took place 16 years ago but it
23 doesn't sound like something I would say.
24 Q. On page 28, that same paragraph,
25 [REDACTED] was asked how many girls in total she

Page 28 1 G Maxwell - Confidential
2 A. First of all, as I said when I was
3 present --
4 Q. It is a yes or no.
5 A. No, it is not.
6 Q. You can answer the question in full
7 but please provide yes or no as an initial
8 matter.
9 A. I cannot answer yes or no, it's not
10 bounded by time. It's entirely possible I
11 could have been in a room or even in the
12 vicinity of Palm beach when somebody came and
13 I would not know. How would I know when
14 somebody was in the house. There is no way I
15 can know.
16 Q. Did you stay at Jeffrey Epstein's
17 home when you were in Palm Beach?
18 A. Most of the time.
19 Q. So how is it that you wouldn't know
20 if there was a female in the home under the
21 age of 18 if you were staying there?
22 A. Well, first of all, when I was
23 staying there, the house is actually quite
24 large and I have a very busy job and I had an
25 office with a door so the door would be shut

Page 27 1 G Maxwell - Confidential
2 brought to Epstein. [REDACTED] stated that she
3 can remember, [REDACTED] stated that she brought
4 and, it's redacted there, and the victim in
5 this case.
6 Let me ask my question, I have a
7 question pending right now.
8 Are you testifying that you are
9 unaware of any underage, under the age of 18,
10 females coming to Jeffrey Epstein's home to
11 perform massages?
12 MR. PAGLIUCA: Object to the form
13 foundation.
14 A. You need to straddle that question
15 in a different time period. When I was
16 there, at the time I was present, the people
17 that gave Jeffrey, men and women who gave
18 Jeffrey massages were adults over the age of
19 18.
20 Q. Never in your time at any of
21 Jeffrey Epstein's homes were you present when
22 a female under the age of 18 was there to
23 give Jeffrey Epstein a massage?
24 MR. PAGLIUCA: Object to the form
25 and foundation.

Page 29 1 G Maxwell - Confidential
2 and I would be working. I'm not responsible
3 for what Jeffrey does and I don't always pay
4 attention to what happens in the house. I'm
5 very busy.
6 Q. So you're testifying that you never
7 observed a female under the age of 18 at
8 Jeffrey Epstein's West Palm Beach home?
9 MR. PAGLIUCA: Object to the form
10 and foundation.
11 A. I already answered that question, I
12 believe.
13 Q. You didn't answer my question.
14 A. I did.
15 Q. Did you observe a female under the
16 age of 18 at Jeffrey Epstein's home in Palm
17 Beach?
18 A. Like I said, I work, I don't sit
19 there and watch people coming in and out of
20 the house. I cannot possibly tell you if I'm
21 in the home that somebody was there that I
22 did not see, I cannot comment on it, I have
23 no idea.
24 Q. Did you observe females at Jeffrey
25 Epstein's home that were laying out topless

<p>Page 30</p> <p>1 G Maxwell - Confidential 2 in the back of the home, in other words 3 without a shirt on? 4 A. So that's just another of 5 Virginia's lies. So let's be clear, at the 6 time when I was there and present, frequently 7 at the house, it was unusual to see people 8 without their clothes on. 9 Q. When you say unusual, did you 10 observe people without their clothes at 11 Jeffrey Epstein's home? 12 A. Can I answer. Sometimes people in 13 the privacy of a house and swimming pool, I 14 have seen people from time to time take their 15 top off. I have seen people from time to 16 time do that. Very unusual. Naked people 17 around the people at any frequent period of 18 time, I have never seen. 19 Q. Were they under the age of 18? 20 A. As I was saying, people when I was 21 in the house, were of adult age, if they were 22 children, friends of my family or friends 23 that were there, they may well have been 24 because I have nieces and nephews under the 25 age of 18, I cannot testify to anybody else</p>	<p>Page 32</p> <p>1 G Maxwell - Confidential 2 Q. Did you ever hire a masseuse that 3 was under the age of 18? 4 MR. PAGLIUCA: Object to the form 5 and foundation. 6 Q. Did you? 7 A. Again, I don't hire massage 8 therapists, so that was not my job. 9 Q. You just said you did, you just 10 said you hired massage therapists for Jeffrey 11 Epstein, I'm asking if you hired a massage 12 therapist who was under the age of 18? 13 A. Let me correct myself. When I 14 meant hire, I didn't mean hire in the way you 15 are doing it. What I say is that I went to 16 spas and I met people and if they did home 17 visits, Jeffrey would then, in fact, hire 18 them. I'm not responsible for hiring 19 someone. And they were not full-time, so 20 it's not a correct characterization. 21 Q. Did you ever, your term is meet, 22 did you ever meet a person that was under the 23 age of 18 that you -- that Jeffrey then hired 24 as a masseuse? 25 MR. PAGLIUCA: Object to the form</p>
<p>Page 31</p> <p>1 G Maxwell - Confidential 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.</p>	<p>Page 33</p> <p>1 G Maxwell - Confidential 2 and foundation. 3 A. First of all, [REDACTED] who 4 you are referring to was a masseuse aged 17, 5 we all now know, so your story that you keep 6 pushing out to the press that she was a 15 7 year old -- you and I both know was a lie, 8 correct. 9 Q. You are not sentencing my question. 10 A. You and I both know that was a lie, 11 correct. 12 Q. You are not answering my question. 13 I'm asking you whether you ever met a female 14 under the age of 18 that Jeffrey then hired 15 as a masseuse? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. The only person I can talk about 19 who clearly was a massage age 17, a masseuse, 20 was Virginia. 21 Q. Did you meet her and then introduce 22 her to Jeffrey? 23 A. I don't know. I already testified 24 I don't recall meeting her. 25 (Maxwell Exhibit 2, email, marked</p>

Page 30 1 G Maxwell - Confidential
2 in the back of the home, in other words
3 without a shirt on?
4 A. So that's just another of
5 Virginia's lies. So let's be clear, at the
6 time when I was there and present, frequently
7 at the house, it was unusual to see people
8 without their clothes on.
9 Q. When you say unusual, did you
10 observe people without their clothes at
11 Jeffrey Epstein's home?
12 A. Can I answer. Sometimes people in
13 the privacy of a house and swimming pool, I
14 have seen people from time to time take their
15 top off. I have seen people from time to
16 time do that. Very unusual. Naked people
17 around the people at any frequent period of
18 time, I have never seen.
19 Q. Were they under the age of 18?
20 A. As I was saying, people when I was
21 in the house, were of adult age, if they were
22 children, friends of my family or friends
23 that were there, they may well have been
24 because I have nieces and nephews under the
25 age of 18, I cannot testify to anybody else

Page 32 1 G Maxwell - Confidential
2 Q. Did you ever hire a masseuse that
3 was under the age of 18?
4 MR. PAGLIUCA: Object to the form
5 and foundation.
6 Q. Did you?
7 A. Again, I don't hire massage
8 therapists, so that was not my job.
9 Q. You just said you did, you just
10 said you hired massage therapists for Jeffrey
11 Epstein, I'm asking if you hired a massage
12 therapist who was under the age of 18?
13 A. Let me correct myself. When I
14 meant hire, I didn't mean hire in the way you
15 are doing it. What I say is that I went to
16 spas and I met people and if they did home
17 visits, Jeffrey would then, in fact, hire
18 them. I'm not responsible for hiring
19 someone. And they were not full-time, so
20 it's not a correct characterization.
21 Q. Did you ever, your term is meet,
22 did you ever meet a person that was under the
23 age of 18 that you -- that Jeffrey then hired
24 as a masseuse?
25 MR. PAGLIUCA: Object to the form

Page 31 1 G Maxwell - Confidential
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.

Page 33 1 G Maxwell - Confidential
2 and foundation.
3 A. First of all, [REDACTED] who
4 you are referring to was a masseuse aged 17,
5 we all now know, so your story that you keep
6 pushing out to the press that she was a 15
7 year old -- you and I both know was a lie,
8 correct.
9 Q. You are not sentencing my question.
10 A. You and I both know that was a lie,
11 correct.
12 Q. You are not answering my question.
13 I'm asking you whether you ever met a female
14 under the age of 18 that Jeffrey then hired
15 as a masseuse?
16 MR. PAGLIUCA: Object to the form
17 and foundation.
18 A. The only person I can talk about
19 who clearly was a massage age 17, a masseuse,
20 was Virginia.
21 Q. Did you meet her and then introduce
22 her to Jeffrey?
23 A. I don't know. I already testified
24 I don't recall meeting her.
25 (Maxwell Exhibit 2, email, marked

<p>Page 34</p> <p>1 G Maxwell - Confidential 2 for identification.) 3 Q. So I'm showing you a document that 4 we have marked as Maxwell Exhibit 2. It's a 5 document you produced in this matter labeled 6 confidential GM 00109. It's dated Sunday 7 June 12, 2011. It's from Jeffrey Epstein to 8 you. If you can turn to page 4 -- sorry, can 9 you turn to the first page, the cover page 10 initially which is 00109. If you look under 11 the time stamp it says, June 12, 2011 at 4:12 12 p.m., it says [REDACTED] 13 Is that your email address? 14 A. It is. 15 Q. Under that it says, Thank you. I 16 have it now and I'm working on a letter, a 17 little, I will send the final version 18 tomorrow and what ever it is will be 19 factually accurate. 20 Do you see that on page 1? 21 A. I do. 22 Q. Then I would like you to turn to 23 page 4 please. The second paragraph down on 24 page 4, it states, After some thought, I 25 recall that I first met [REDACTED] when she</p>	<p>Page 36</p> <p>1 G Maxwell - Confidential 2 Q. Are you questioning that this 3 document is incorrect, this document -- this 4 email that you wrote? 5 A. I wrote an email. I was trying to 6 be accurate, so who knows, with all the 7 rubbish that you guys have put out in the 8 press that I read, maybe in the moment I 9 wrote it a memory came to me that I don't 10 know, but as I sit here today and the 11 testimony I gave you today is I don't 12 recollect it. 13 Q. Does this refresh your recollection 14 that you recalled meeting [REDACTED] at 15 Mar-a-Lago? 16 A. It does not. 17 Q. So your testimony today is that you 18 don't remember meeting [REDACTED] at 19 Mar-a-Lago? 20 A. I do not. 21 I just want to clarify, when you 22 read so much stuff and so much rubbish that 23 comes out from [REDACTED], you don't 24 know what's up and down, at the time I wrote 25 this I believe I had a memory but as I sit</p>
<p>Page 35</p> <p>1 G Maxwell - Confidential 2 was working at a premier resort claiming to 3 be 18 years old and a professional masseuse? 4 MR. PAGLIUCA: What line are you 5 on, counsel. 6 MS. McCAWLEY: Second paragraph 7 down. 8 MR. PAGLIUCA: I got it. 9 Q. Is that a statement that you wrote? 10 A. It appears to be. 11 Q. So does that correct your testimony 12 that you did meet [REDACTED] at Mar-a-Lago? 13 A. Again, this was written in, when 14 were you saying? 15 Q. 2011. 16 A. So by 2011, [REDACTED] had already 17 perpetrated so many lies and stories it's 18 hard for me to accurately tell you today what 19 I remember back then. As I sit here today, 20 the testimony I give you today, I do not 21 recollect it. 22 Q. Do you have a reason to say that 23 this document that you wrote is incorrect? 24 A. It's in 2011, I can't possibly tell 25 you what I remember in 2011.</p>	<p>Page 37</p> <p>1 G Maxwell - Confidential 2 here today I do not. 3 Q. Ms. Maxwell, when did you first 4 meet [REDACTED] 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. [REDACTED] 17 [REDACTED] 18 [REDACTED] 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 [REDACTED] 22 [REDACTED]. 23 I'm asking if [REDACTED] was 13 24 years old when you first met her? 25 A. I have no idea.</p>

Page 34 1 G Maxwell - Confidential
2 for identification.)
3 Q. So I'm showing you a document that
4 we have marked as Maxwell Exhibit 2. It's a
5 document you produced in this matter labeled
6 confidential GM 00109. It's dated Sunday
7 June 12, 2011. It's from Jeffrey Epstein to
8 you. If you can turn to page 4 -- sorry, can
9 you turn to the first page, the cover page
10 initially which is 00109. If you look under
11 the time stamp it says, June 12, 2011 at 4:12
12 p.m., it says [REDACTED]
13 Is that your email address?
14 A. It is.
15 Q. Under that it says, Thank you. I
16 have it now and I'm working on a letter, a
17 little, I will send the final version
18 tomorrow and what ever it is will be
19 factually accurate.
20 Do you see that on page 1?
21 A. I do.
22 Q. Then I would like you to turn to
23 page 4 please. The second paragraph down on
24 page 4, it states, After some thought, I
25 recall that I first met [REDACTED] when she

Page 36 1 G Maxwell - Confidential
2 Q. Are you questioning that this
3 document is incorrect, this document -- this
4 email that you wrote?
5 A. I wrote an email. I was trying to
6 be accurate, so who knows, with all the
7 rubbish that you guys have put out in the
8 press that I read, maybe in the moment I
9 wrote it a memory came to me that I don't
10 know, but as I sit here today and the
11 testimony I gave you today is I don't
12 recollect it.
13 Q. Does this refresh your recollection
14 that you recalled meeting [REDACTED] at
15 Mar-a-Lago?
16 A. It does not.
17 Q. So your testimony today is that you
18 don't remember meeting [REDACTED] at
19 Mar-a-Lago?
20 A. I do not.
21 I just want to clarify, when you
22 read so much stuff and so much rubbish that
23 comes out from [REDACTED], you don't
24 know what's up and down, at the time I wrote
25 this I believe I had a memory but as I sit

Page 35 1 G Maxwell - Confidential
2 was working at a premier resort claiming to
3 be 18 years old and a professional masseuse?
4 MR. PAGLIUCA: What line are you
5 on, counsel.
6 MS. McCAWLEY: Second paragraph
7 down.
8 MR. PAGLIUCA: I got it.
9 Q. Is that a statement that you wrote?
10 A. It appears to be.
11 Q. So does that correct your testimony
12 that you did meet [REDACTED] at Mar-a-Lago?
13 A. Again, this was written in, when
14 were you saying?
15 Q. 2011.
16 A. So by 2011, [REDACTED] had already
17 perpetrated so many lies and stories it's
18 hard for me to accurately tell you today what
19 I remember back then. As I sit here today,
20 the testimony I give you today, I do not
21 recollect it.
22 Q. Do you have a reason to say that
23 this document that you wrote is incorrect?
24 A. It's in 2011, I can't possibly tell
25 you what I remember in 2011.

Page 37 1 G Maxwell - Confidential
2 here today I do not.
3 Q. Ms. Maxwell, when did you first
4 meet [REDACTED]
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. [REDACTED]
17 [REDACTED]
18 [REDACTED] 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 [REDACTED]
22 [REDACTED].
23 I'm asking if [REDACTED] was 13
24 years old when you first met her?
25 A. I have no idea.

Page 38¶

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]¶

Page 39¶

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]¶

Page 40¶

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.¶

Page 41¶

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 [REDACTED]¶

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]?¶

<p>Page 42</p> <p>1 G Maxwell - Confidential</p> <p>2 A. I don't recollect. I don't know if</p> <p>3 I did.</p> <p>4 Q. How many times have you flown on</p> <p>5 Jeffrey Epstein's planes?</p> <p>6 A. Too many times.</p> <p>7 Q. More than 300?</p> <p>8 A. I really couldn't tell you how</p> <p>9 many.</p> <p>10 Q. More than 400?</p> <p>11 A. Again, I said I cannot tell you how</p> <p>12 many, a lot.</p> <p>13 Q. How many times with [REDACTED]</p> <p>14 [REDACTED]</p> <p>15 A. I already testified, I have no</p> <p>16 idea.</p> <p>17 Q. How old was [REDACTED] when</p> <p>18 she first became involved with Jeffrey?</p> <p>19 A. I have no idea.</p> <p>20 Q. Was she 14?</p> <p>21 MR. PAGLIUCA: Object to the form</p> <p>22 and foundation.</p> <p>23 A. I have no idea.</p> <p>24 Q. Did she look like a child the first</p> <p>25 time you met her?</p>	<p>Page 44</p> <p>1 G Maxwell - Confidential</p> <p>2 evidence. The witness already testified</p> <p>3 she doesn't remember.</p> <p>4 Q. You can answer that question.</p> <p>5 Did you ever ask her on the many</p> <p>6 flights you were with her or the many times</p> <p>7 you were with her at the house?</p> <p>8 A. First of all, I don't know I was on</p> <p>9 many flights with her, you are making stories</p> <p>10 up again as usual. And secondly, if I was on</p> <p>11 a flight with her, there would not be any</p> <p>12 reason why I would ask her how old she was.</p> <p>13 Q. You don't recollect having any</p> <p>14 conversation with her about her age?</p> <p>15 A. I already testified to that.</p> <p>16 Q. Do you know what [REDACTED]</p> <p>17 was hired to do for Jeffrey?</p> <p>18 A. I already testified I didn't know</p> <p>19 she was hired and I don't know that she did</p> <p>20 anything. I don't know how to answer that</p> <p>21 question.</p> <p>22 Q. Was [REDACTED] at the house,</p> <p>23 the Palm Beach house, when you were present</p> <p>24 at that house?</p> <p>25 MR. PAGLIUCA: Object to the</p>
<p>Page 43</p> <p>1 G Maxwell - Confidential</p> <p>2 MR. PAGLIUCA: Object to the form</p> <p>3 and foundation. Asked and answered.</p> <p>4 Q. Did she look like a child the first</p> <p>5 time you met [REDACTED]</p> <p>6 A. I don't know what you mean if she</p> <p>7 looked like a child.</p> <p>8 Q. Did she look like she was under the</p> <p>9 age of 18?</p> <p>10 A. No.</p> <p>11 Q. Did she look like she was under the</p> <p>12 age of 16?</p> <p>13 A. I just testified -- first of all, I</p> <p>14 couldn't tell you how old she was, she didn't</p> <p>15 like a child, leave it at that.</p> <p>16 Q. Did you know that she was a child?</p> <p>17 MR. PAGLIUCA: Object to the form</p> <p>18 and foundation.</p> <p>19 A. I just answered I did not know how</p> <p>20 old she was and she looked like an adult.</p> <p>21 Q. In the times that you traveled with</p> <p>22 her on Jeffrey Epstein's planes, did you ever</p> <p>23 ask her how old she was?</p> <p>24 MR. PAGLIUCA: Object to the form</p> <p>25 and foundation. Assumes facts not in</p>	<p>Page 45</p> <p>1 G Maxwell - Confidential</p> <p>2 foundation.</p> <p>3 A. I have no recollection of her being</p> <p>4 at the house at the same time as me.</p> <p>5 Q. When did you first meet [REDACTED]</p> <p>6 [REDACTED]</p> <p>7 A. I already told you I don't recall.</p> <p>8 Q. Do you recall anything about [REDACTED]</p> <p>9 [REDACTED]</p> <p>10 A. That she was tall and blond.</p> <p>11 Q. Do you recall [REDACTED]</p> <p>12 interacting with other females at the house?</p> <p>13 A. No, I do not.</p> <p>14 Q. Did you arrange to get a visa for</p> <p>15 [REDACTED] to come into this country?</p> <p>16 MR. PAGLIUCA: Object to the form</p> <p>17 and foundation.</p> <p>18 A. Absolutely not.</p> <p>19 Q. Did Jeffrey arrange for a visa for</p> <p>20 [REDACTED]</p> <p>21 MR. PAGLIUCA: You need to give me</p> <p>22 a break so I can interpose an objection.</p> <p>23 Object to the form and foundation.</p> <p>24 Q. You can answer.</p> <p>25 A. What was the question?</p>

Page 42 1 G Maxwell - Confidential 2 A. I don't recollect. I don't know if 3 I did. 4 Q. How many times have you flown on 5 Jeffrey Epstein's planes? 6 A. Too many times. 7 Q. More than 300? 8 A. I really couldn't tell you how 9 many. 10 Q. More than 400? 11 A. Again, I said I cannot tell you how 12 many, a lot. 13 Q. How many times with [REDACTED] 14 [REDACTED] 15 A. I already testified, I have no 16 idea. 17 Q. How old was [REDACTED] when 18 she first became involved with Jeffrey? 19 A. I have no idea. 20 Q. Was she 14? 21 MR. PAGLIUCA: Object to the form 22 and foundation. 23 A. I have no idea. 24 Q. Did she look like a child the first 25 time you met her?

Page 44 1 G Maxwell - Confidential 2 evidence. The witness already testified 3 she doesn't remember. 4 Q. You can answer that question. 5 Did you ever ask her on the many 6 flights you were with her or the many times 7 you were with her at the house? 8 A. First of all, I don't know I was on 9 many flights with her, you are making stories 10 up again as usual. And secondly, if I was on 11 a flight with her, there would not be any 12 reason why I would ask her how old she was. 13 Q. You don't recollect having any 14 conversation with her about her age? 15 A. I already testified to that. 16 Q. Do you know what [REDACTED] 17 was hired to do for Jeffrey? 18 A. I already testified I didn't know 19 she was hired and I don't know that she did 20 anything. I don't know how to answer that 21 question. 22 Q. Was [REDACTED] at the house, 23 the Palm Beach house, when you were present 24 at that house? 25 MR. PAGLIUCA: Object to the

Page 43 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Object to the form 3 and foundation. Asked and answered. 4 Q. Did she look like a child the first 5 time you met [REDACTED] 6 A. I don't know what you mean if she 7 looked like a child. 8 Q. Did she look like she was under the 9 age of 18? 10 A. No. 11 Q. Did she look like she was under the 12 age of 16? 13 A. I just testified -- first of all, I 14 couldn't tell you how old she was, she didn't 15 like a child, leave it at that. 16 Q. Did you know that she was a child? 17 MR. PAGLIUCA: Object to the form 18 and foundation. 19 A. I just answered I did not know how 20 old she was and she looked like an adult. 21 Q. In the times that you traveled with 22 her on Jeffrey Epstein's planes, did you ever 23 ask her how old she was? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Assumes facts not in

Page 45 1 G Maxwell - Confidential 2 foundation. 3 A. I have no recollection of her being 4 at the house at the same time as me. 5 Q. When did you first meet [REDACTED] 6 [REDACTED] 7 A. I already told you I don't recall. 8 Q. Do you recall anything about [REDACTED] 9 [REDACTED] 10 A. That she was tall and blond. 11 Q. Do you recall [REDACTED] 12 interacting with other females at the house? 13 A. No, I do not. 14 Q. Did you arrange to get a visa for 15 [REDACTED] to come into this country? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. Absolutely not. 19 Q. Did Jeffrey arrange for a visa for 20 [REDACTED] 21 MR. PAGLIUCA: You need to give me 22 a break so I can interpose an objection. 23 Object to the form and foundation. 24 Q. You can answer. 25 A. What was the question?

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 [REDACTED] 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 [REDACTED] 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 [REDACTED] 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 [REDACTED]¶

23 A. No.¶

24 Q. [REDACTED]¶

25 A. I have no idea.¶

Page 47¶

1 G Maxwell - Confidential¶

2 [REDACTED]¶

3 [REDACTED]¶

4 A. I have no idea.¶

5 Q. Are you a pilot?¶

6 A. I am.¶

7 Q. Have you flown with [REDACTED]¶

8 A. I have.¶

9 Q. Have you flown with [REDACTED]¶

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?¶

<p>Page 50</p> <p>1 G Maxwell - Confidential</p> <p>2 A. People had salaries and they were</p> <p>3 paid by the office.</p> <p>4 Q. Did you ever pay any individual,</p> <p>5 did you ever hand an individual cash for work</p> <p>6 they performed?</p> <p>7 MR. PAGLIUCA: Object to the form.</p> <p>8 A. Can you be more specific about what</p> <p>9 you are asking me.</p> <p>10 Q. Did you ever hand any individual</p> <p>11 who was working at the home cash as payment</p> <p>12 for something that they performed at the</p> <p>13 home?</p> <p>14 MR. PAGLIUCA: Object to the form.</p> <p>15 A. To the best of my recollection</p> <p>16 there were very few times where I would leave</p> <p>17 some cash for people for work performed.</p> <p>18 Q. And what type of work was being</p> <p>19 performed where you would be doing that?</p> <p>20 A. If I left cash for the pool guy, I</p> <p>21 would have left potentially some cash for the</p> <p>22 gardener, potentially for exercise</p> <p>23 instructors and sometimes for massage</p> <p>24 therapy.</p> <p>25 Q. How much were the massage</p>	<p>Page 52</p> <p>1 G Maxwell - Confidential</p> <p>2 for sexual acts.</p> <p>3 Q. I'm asking if they performed sexual</p> <p>4 acts?</p> <p>5 MR. PAGLIUCA: Object to the form</p> <p>6 and foundation.</p> <p>7 Q. Did any of the massage therapists</p> <p>8 who were at the home perform sexual acts for</p> <p>9 Jeffrey Epstein?</p> <p>10 A. I don't know what you mean by</p> <p>11 sexual acts.</p> <p>12 Q. Did any of the massage therapists</p> <p>13 who were working at the home perform sexual</p> <p>14 acts, including touching the breasts,</p> <p>15 touching the vaginal area, being touched</p> <p>16 while Jeffrey is masturbating, having</p> <p>17 intercourse, any of those things?</p> <p>18 MR. PAGLIUCA: Objection. Form and</p> <p>19 foundation.</p> <p>20 To the extent any of this is asking</p> <p>21 for to your knowledge any consensual sex</p> <p>22 act that may or may not have involved</p> <p>23 you, I'm instructing you not to answer</p> <p>24 the question.</p> <p>25 Q. I'm not asking about consensual sex</p>
<p>Page 51</p> <p>1 G Maxwell - Confidential</p> <p>2 therapists paid?</p> <p>3 MR. PAGLIUCA: Object to the form</p> <p>4 and foundation.</p> <p>5 A. They get paid between 100 and $200.</p> <p>6 Q. Did it vary based on what sexual</p> <p>7 acts they performed?</p> <p>8 MR. PAGLIUCA: Object to the form</p> <p>9 and foundation.</p> <p>10 A. No. It varied depending how much</p> <p>11 time, some massage therapists charge more and</p> <p>12 some charge less.</p> <p>13 Q. Did the massage therapists that</p> <p>14 were hired to come to the home perform sexual</p> <p>15 acts for Jeffrey Epstein?</p> <p>16 MR. PAGLIUCA: Object to the form</p> <p>17 and foundation.</p> <p>18 A. What are you asking me?</p> <p>19 Q. I'm asking if the massage</p> <p>20 therapists --</p> <p>21 A. Are you asking me about underage</p> <p>22 girls?</p> <p>23 Q. I'm asking in general, did any of</p> <p>24 the massage therapists in the home --</p> <p>25 A. Are you asking if they were paid</p>	<p>Page 53</p> <p>1 G Maxwell - Confidential</p> <p>2 acts. I'm asking whether any of the massage</p> <p>3 therapists performed sexual acts for Mr.</p> <p>4 Epstein, as I have just described?</p> <p>5 A. I have never seen anybody have</p> <p>6 sexual intercourse with with Jeffrey, ever.</p> <p>7 Q. I'm not asking about sexual</p> <p>8 intercourse. I'm asking about any sexual</p> <p>9 act, touching of the breast -- did you ever</p> <p>10 see -- can you read back the question?</p> <p>11 (Record read.)</p> <p>12 A. I'm not addressing any questions</p> <p>13 about consensual adult sex. If you want to</p> <p>14 talk about what the subject matter, which is</p> <p>15 defamation and lying, [REDACTED], that</p> <p>16 you and [REDACTED] are participating in</p> <p>17 perpetrating her lies, I'm happy to address</p> <p>18 those. I never saw any inappropriate</p> <p>19 underage activities with Jeffrey ever.</p> <p>20 Q. I'm not asking about underage. I'm</p> <p>21 asking about whether any of the masseuses</p> <p>22 that were at the home perform sexual acts for</p> <p>23 Jeffrey Epstein?</p> <p>24 A. I have just answered the question.</p> <p>25 Q. No, you haven't.</p>

Page 50 1 G Maxwell - Confidential 2 A. People had salaries and they were 3 paid by the office. 4 Q. Did you ever pay any individual, 5 did you ever hand an individual cash for work 6 they performed? 7 MR. PAGLIUCA: Object to the form. 8 A. Can you be more specific about what 9 you are asking me. 10 Q. Did you ever hand any individual 11 who was working at the home cash as payment 12 for something that they performed at the 13 home? 14 MR. PAGLIUCA: Object to the form. 15 A. To the best of my recollection 16 there were very few times where I would leave 17 some cash for people for work performed. 18 Q. And what type of work was being 19 performed where you would be doing that? 20 A. If I left cash for the pool guy, I 21 would have left potentially some cash for the 22 gardener, potentially for exercise 23 instructors and sometimes for massage 24 therapy. 25 Q. How much were the massage

Page 52 1 G Maxwell - Confidential 2 for sexual acts. 3 Q. I'm asking if they performed sexual 4 acts? 5 MR. PAGLIUCA: Object to the form 6 and foundation. 7 Q. Did any of the massage therapists 8 who were at the home perform sexual acts for 9 Jeffrey Epstein? 10 A. I don't know what you mean by 11 sexual acts. 12 Q. Did any of the massage therapists 13 who were working at the home perform sexual 14 acts, including touching the breasts, 15 touching the vaginal area, being touched 16 while Jeffrey is masturbating, having 17 intercourse, any of those things? 18 MR. PAGLIUCA: Objection. Form and 19 foundation. 20 To the extent any of this is asking 21 for to your knowledge any consensual sex 22 act that may or may not have involved 23 you, I'm instructing you not to answer 24 the question. 25 Q. I'm not asking about consensual sex

Page 51 1 G Maxwell - Confidential 2 therapists paid? 3 MR. PAGLIUCA: Object to the form 4 and foundation. 5 A. They get paid between 100 and $200. 6 Q. Did it vary based on what sexual 7 acts they performed? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 A. No. It varied depending how much 11 time, some massage therapists charge more and 12 some charge less. 13 Q. Did the massage therapists that 14 were hired to come to the home perform sexual 15 acts for Jeffrey Epstein? 16 MR. PAGLIUCA: Object to the form 17 and foundation. 18 A. What are you asking me? 19 Q. I'm asking if the massage 20 therapists -- 21 A. Are you asking me about underage 22 girls? 23 Q. I'm asking in general, did any of 24 the massage therapists in the home -- 25 A. Are you asking if they were paid

Page 53 1 G Maxwell - Confidential 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, [REDACTED], that 16 you and [REDACTED] 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.

<p>Page 54</p> <p>1 G Maxwell - Confidential</p> <p>2 A. I have.</p> <p>3 Q. No, you haven't.</p> <p>4 A. Yes, I have.</p> <p>5 Q. You are refusing to answer the</p> <p>6 question.</p> <p>7 A. Let's move on.</p> <p>8 Q. I'm in charge of the deposition. I</p> <p>9 say when we move on and when we don't.</p> <p>10 You are here to respond to my</p> <p>11 questions. If you are refusing to answer the</p> <p>12 court will bring you back for another</p> <p>13 deposition to answer these questions.</p> <p>14 Do you understand that?</p> <p>15 MR. PAGLIUCA: You don't need to</p> <p>16 threaten the witness.</p> <p>17 MS. MCCAWLEY: I'm not threatening</p> <p>18 her. I'm making sure the record is</p> <p>19 clear.</p> <p>20 MR. PAGLIUCA: Certainly can you</p> <p>21 apply to have someone come back and the</p> <p>22 court may or may not have her come back</p> <p>23 again.</p> <p>24 Again, she is not answering</p> <p>25 questions that relate to adult consent</p>	<p>Page 56</p> <p>1 G Maxwell - Confidential</p> <p>2 sexual acts on her?</p> <p>3 MR. PAGLIUCA: Object to the form</p> <p>4 and foundation.</p> <p>5 A. I have not heard that.</p> <p>6 Q. How do you know [REDACTED]</p> <p>[REDACTED]</p> <p>10 Q. Was [REDACTED] under the age of</p> <p>11 18?</p> <p>12 MR. PAGLIUCA: Object to the form</p> <p>13 and foundation.</p> <p>14 A. I don't recall how old [REDACTED]</p> <p>15 was.</p> <p>16 Q. Did she tell police that Jeffrey</p> <p>17 Epstein assaulted her sexually?</p> <p>18 MR. PAGLIUCA: Object to the form</p> <p>19 and foundation.</p> <p>20 A. I never heard that.</p> <p>21 Q. Did [REDACTED] recruit or bring</p> <p>22 girls to the home that were under the age of</p> <p>23 18?</p> <p>24 MR. PAGLIUCA: Object to the form</p> <p>25 and foundation and I think this has been</p>
<p>Page 55</p> <p>1 G Maxwell - Confidential</p> <p>2 sex acts. Period. And that's the</p> <p>3 instruction and we can take it up with</p> <p>4 the court.</p> <p>5 Q. Ms. Maxwell, are you aware of any</p> <p>6 sexual acts with masseuses and Jeffrey</p> <p>7 Epstein that were nonconsensual?</p> <p>8 A. No.</p> <p>9 Q. How do you know that?</p> <p>10 A. All the time that I have been in</p> <p>11 the house I have never seen, heard, nor</p> <p>12 witnessed, nor have reported to me that any</p> <p>13 activities took place, that people were in</p> <p>14 distress, either reported to me by the staff</p> <p>15 or anyone else. I base my answer based on</p> <p>16 that.</p> <p>17 Q. Are you familiar with a person by</p> <p>18 the name of [REDACTED]</p> <p>19 A. I am.</p> <p>20 Q. Has [REDACTED] given a statement</p> <p>21 to police about you performing sexual acts on</p> <p>22 her?</p> <p>23 A. I have not heard that.</p> <p>24 Q. Has [REDACTED] given a statement</p> <p>25 to police about Jeffrey Epstein performing</p>	<p>Page 57</p> <p>1 G Maxwell - Confidential</p> <p>2 asked and answered already.</p> <p>3 Q. You can answer the question.</p> <p>4 A. I have no idea what [REDACTED]</p> <p>5 did.</p> <p>6 Q. You never observed [REDACTED]</p> <p>7 with girls under the age of 18 at Jeffrey's</p> <p>8 home?</p> <p>9 MR. PAGLIUCA: Object to the form</p> <p>10 and foundation.</p> <p>11 A. The answer is no, I have no idea.</p> <p>12 Q. Do you know Glenn [REDACTED]?</p> <p>13 A. I do.</p> <p>14 Q. What is your relationship with</p> <p>15 Glenn [REDACTED]?</p> <p>16 MR. PAGLIUCA: Object to the form.</p> <p>17 A. What do you mean what is my</p> <p>18 relationship.</p> <p>19 Q. Are you friendly with him, how do</p> <p>20 you know him?</p> <p>21 A. He is the husband of Eva [REDACTED].</p> <p>22 Q. Is Eva [REDACTED] one of your friends?</p> <p>23 A. Yes.</p> <p>24 Q. Did you ever send Virginia to</p> <p>25 Glenn's condo at the Breakers to give him a</p>

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 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] [REDACTED] 10 Q. Was [REDACTED] under the age of 11 18? 12 MR. PAGLIUCA: Object to the form 13 and foundation. 14 A. I don't recall how old [REDACTED] 15 was. 16 Q. Did she tell police that Jeffrey 17 Epstein assaulted her sexually? 18 MR. PAGLIUCA: Object to the form 19 and foundation. 20 A. I never heard that. 21 Q. Did [REDACTED] recruit or bring 22 girls to the home that were under the age of 23 18? 24 MR. PAGLIUCA: Object to the form 25 and foundation and I think this has been

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 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 [REDACTED] 19 A. I am. 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 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 Virginia to 25 Glenn's condo at the Breakers to give him a

<p>Page 58</p> <p>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 Virginia 7 [REDACTED] 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 [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,</p>	<p>Page 60</p> <p>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</p>
<p>Page 59</p> <p>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], when 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?</p>	<p>Page 61</p> <p>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.</p>

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 Virginia
7 [REDACTED] 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 [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 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 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], when
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 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]¶

10 [REDACTED]¶

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 [REDACTED]. 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].¶

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], 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 [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 66¶

1 G Maxwell - Confidential¶

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

3 do you speak to her?¶

4 A. No.¶

5 Q. Do you know where she lives?¶

6 A. No.¶

7 Q. Do you know what country she lives¶

8 in?¶

9 A. No.¶

10 Q. Where is the last place you knew¶

11 that she lived?¶

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

13 Los Angeles.¶

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

15 A. 2001, 2002.¶

16 Q. What tasks did she performance for¶

17 you?¶

18 A. She helped me with moving in and¶

19 out of houses, construction, she was a¶

20 general help, she helped with buying things¶

21 that needed to be purchased, if I needed her¶

22 to stand in for me during meetings, it was a¶

23 very wide ranging job.¶

24 Q. Did she ever bring females to¶

25 perform massages for Jeffrey?¶

Page 67¶

1 G Maxwell - Confidential¶

2 MR. PAGLIUCA: Objection to the¶

3 form and foundation.¶

4 A. What are you asking me?¶

5 Q. Did [REDACTED] was it ever [REDACTED]¶

6 responsibility to bring females to the house¶

7 for the purposes of massaging Jeffrey?¶

8 A. [REDACTED] job was to help me with the¶

9 houses and work in homes. It was not her job¶

10 to whatever you just said, bring masseuses.¶

11 Q. Did she do that?¶

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

13 idea.¶

14 Q. Did you pay [REDACTED] or did Jeffrey pay¶

15 her?¶

16 A. Jeffrey.¶

17 Q. Do you recall how much she was¶

18 paid?¶

19 A. I do not.¶

20 MS. MCCAWLEY: I think we can take¶

21 a break now.¶

22 THE VIDEOGRAPHER: It's 10:02 and¶

23 we are off the record.¶

24 (Recess.)¶

25 THE VIDEOGRAPHER: It's now 10:18.¶

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1 G Maxwell - Confidential¶

2 We are back on the record and starting¶

3 disk No. 2.¶

4 Q. Ms. Maxwell, I asked you about¶

5 [REDACTED] earlier.¶

6 Can you describe what Virginia¶

7 [REDACTED] duties were when she was with Mr.¶

8 Epstein?¶

9 MR. PAGLIUCA: Objection to the¶

10 form and foundation.¶

11 A. I believe that Virginia was a¶

12 masseuse.¶

13 Q. Was Virginia required to dress up¶

14 in any way for massages?¶

15 MR. PAGLIUCA: Objection to the¶

16 form and foundation.¶

17 A. I have no idea.¶

18 Q. Did you provide Virginia with¶

19 outfits to wear for certain massages?¶

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

21 about.¶

22 Q. For example, did you ever provide¶

23 Virginia with a school girl outfit to wear¶

24 for a massage?¶

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

Page 69¶

1 G Maxwell - Confidential¶

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¶

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1 G Maxwell - Confidential
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.¶

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1 G Maxwell - Confidential
2 Q. A sex toy meaning a vibrator of
3 some kind, sometimes they are called dildos,
4 of that nature, anything like that?
5 A. I don't recollect anything that
6 would formally be a dildo, anything like
7 that.
8 Q. How would you describe sex toys?
9 A. I wouldn't describe sex toys.
10 Q. Did you have anything that was of
11 an electronic nature that would be used
12 during sex?
13 MR. PAGLIUCA: Objection to the
14 form and foundation.
15 A. I have no idea what you are
16 referring to.
17 (Maxwell Exhibit 3, transcript,
18 marked for identification.)
19 [REDACTED]¶

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1 G Maxwell - Confidential¶

2 [REDACTED]¶

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4 [REDACTED]¶

5 MR. PAGLIUCA: Objection to the¶

6 form and foundation.¶

7 A. First I have to read this.¶

8 Q. Sure.¶

9 MS. McCAWLEY: I will stop the¶

10 clock while the witness is reading.¶

11 MR. PAGLIUCA: No.¶

12 MS. McCAWLEY: Yes, if she is going¶

13 to read the whole document, I will stop¶

14 the clock.¶

15 MR. PAGLIUCA: If you give her¶

16 documents to refresh her recollection,¶

17 we are on the clock here.¶

18 MS. McCAWLEY: Then we will take it¶

19 up with the judge.¶

20 MR. PAGLIUCA: Read whatever you¶

21 need to answer the question.¶

22 MS. McCAWLEY: I'm going to set the¶

23 document aside and I'm just go to ask¶

24 you a question, independent of the¶

25 document.¶

Page 75¶

1 G Maxwell - Confidential¶

2 Q. Do you recall having a basket full¶

3 of sex toys?¶

4 A. I already told you I did not.¶

5 Q. We were talking a moment ago about¶

6 [REDACTED] 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 [REDACTED]?¶

15 MR. PAGLIUCA: Objection to the¶

16 form and foundation.¶

17 A. No.¶

18 Q. Were you ever present to view a¶

19 massage between Jeffrey Epstein and [REDACTED]¶

20 [REDACTED]?¶

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¶

Page 76¶

1 G Maxwell - Confidential¶

2 situation.¶

3 Q. Did you ever participate in sex¶

4 with [REDACTED] and Jeffrey Epstein?¶

5 A. I never ever at any single time at¶

6 any point ever at all participated in¶

7 anything with Virginia and Jeffrey. And for¶

8 the record, she is an absolute total liar and¶

9 you all know she lied on multiple things and¶

10 that is just one other disgusting thing she¶

11 added.¶

12 Q. Did you help her obtain an¶

13 apartment in Palm Beach to live in?¶

14 MR. PAGLIUCA: Objection to the¶

15 form and foundation.¶

16 Q. Was that part of your¶

17 responsibilities for Jeffrey?¶

18 A. First of all, I didn't know she had¶

19 an apartment in Palm Beach. I only learned¶

20 that from the many times you guys have gone¶

21 to the press to sell stories, so no.¶

22 Q. Did you help her get a cell phone,¶

23 was that one of your responsibilities for¶

24 Jeffrey, to get her is a cell phone as part¶

25 of her masseuse obligations?¶

Page 77¶

1 G Maxwell - Confidential¶

2 MR. PAGLIUCA: Objection to the¶

3 form and foundation.¶

4 A. I don't know what that means,¶

5 masseuse obligation, I don't know what you¶

6 are referring to. Would you like to ask the¶

7 question properly?¶

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

9 it again.¶

10 Did you ever assist in getting¶

11 [REDACTED] a cell phone to use during¶

12 the time that she worked for Jeffrey Epstein?¶

13 A. I have no recollection of doing¶

14 anything of that nature.¶

15 Q. Did you ever tell Virginia that you¶

16 wanted her to have a cell phone so that she¶

17 could be on call regularly?¶

18 A. I have no recollection of that¶

19 conversation.¶

20 Q. How often would Virginia come over¶

21 to the house in Palm Beach to give massages?¶

22 MR. PAGLIUCA: Objection to the¶

23 form and foundation.¶

24 A. Ask the question again, please.¶

25 Q. How often did [REDACTED] come¶

<p>Page 78</p> <p>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</p>	<p>Page 80</p> <p>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 Virginia being at the 23 New York mansion when [REDACTED] came to 24 visit? 25 MR. PAGLIUCA: Objection to the</p>
<p>Page 79</p> <p>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 Virginia was 8 required to be on call at all times to come 9 to the house if Jeffrey wanted her there? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I have no idea of the arrangements 13 that Virginia made with Jeffrey. 14 Q. When Virginia was in New York, 15 would Virginia sleep at Jeffrey's mansion in 16 New York? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I don't recollect her being in New 20 York and I have no idea where she slept. 21 Q. You don't ever remember seeing 22 [REDACTED] in New York? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I would barely recollect her at</p>	<p>Page 81</p> <p>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 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.</p>

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 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 Virginia being at the
23 New York mansion when [REDACTED] came to
24 visit?
25 MR. PAGLIUCA: Objection to the

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 Virginia was
8 required to be on call at all times to come
9 to the house if Jeffrey wanted her there?
10 MR. PAGLIUCA: Objection to the
11 form and foundation.
12 A. I have no idea of the arrangements
13 that Virginia made with Jeffrey.
14 Q. When Virginia was in New York,
15 would Virginia sleep at Jeffrey's mansion in
16 New York?
17 MR. PAGLIUCA: Objection to the
18 form and foundation.
19 A. I don't recollect her being in New
20 York and I have no idea where she slept.
21 Q. You don't ever remember seeing
22 [REDACTED] in New York?
23 MR. PAGLIUCA: Objection to the
24 form and foundation.
25 A. I would barely recollect her at

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 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.

<p>Page 82</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. Did you train Virginia on how to</p> <p>3 recruit other girls to perform sexual</p> <p>4 massages?</p> <p>5 MR. PAGLIUCA: Objection to the</p> <p>6 form and foundation.</p> <p>7 A. No. And it's absurd and her entire</p> <p>8 story is one giant tissue of lies and</p> <p>9 furthermore, she herself has -- if she says</p> <p>10 that, you have to ask her about what she did.</p> <p>11 Q. Does Jeffrey like to have his</p> <p>12 nipples pinched during sexual encounters?</p> <p>13 MR. PAGLIUCA: Objection to form</p> <p>14 and foundation.</p> <p>15 A. I'm not referring to any advice on</p> <p>16 my counsel. I'm not talking about any adult</p> <p>17 sexual things when I was with him.</p> <p>18 Q. When Jeffrey would have a massage,</p> <p>19 would he request that the masseuse pinch his</p> <p>20 nipples while he was having a massage?</p> <p>21 A. I'm not talking about anything with</p> <p>22 consensual adult situation.</p> <p>23 Q. What about with underage --</p> <p>24 A. I am not aware of anything.</p> <p>25 Q. You are not aware of Jeffrey</p>	<p>Page 84</p> <p>1 G Maxwell - Confidential</p> <p>2 30 girls --</p> <p>3 A. I did not count the number of girls</p> <p>4 and I did read the police report. I can only</p> <p>5 testify to what I read.</p> <p>6 Q. So you are aware that the police</p> <p>7 report contains reports from 30 underage</p> <p>8 girls?</p> <p>9 A. I can't testify to what the girls</p> <p>10 said. I can only testify to the fact that I</p> <p>11 read a police report that stated that.</p> <p>12 Q. Were you working for Jeffrey -- you</p> <p>13 said you worked for him off an on until 2009,</p> <p>14 is that correct?</p> <p>15 A. I helped out from time to time.</p> <p>16 Q. So you were working with him during</p> <p>17 the time period when these underage girls</p> <p>18 were visiting Jeffrey's home?</p> <p>19 MR. PAGLIUCA: Objection to the</p> <p>20 form and foundation.</p> <p>21 A. I was not -- what year, I need</p> <p>22 years.</p> <p>23 Q. How about let's say 2005?</p> <p>24 A. I'm not sure I was at the house at</p> <p>25 all in 2005, maybe one day, maybe.</p>
<p>Page 83</p> <p>1 G Maxwell - Confidential</p> <p>2 Epstein ever having sex with an underage</p> <p>3 minor and asking them to pinch his nipples?</p> <p>4 A. I am not.</p> <p>5 Q. So I'm going to direct you to, I</p> <p>6 believe it's Maxwell Exhibit 1, the police</p> <p>7 report.</p> <p>8 Are you aware that over 30 under</p> <p>9 age minors gave testimony to police that they</p> <p>10 were engaged in sexual acts during,</p> <p>11 quote-unquote, massages.</p> <p>12 MR. PAGLIUCA: The witness needs to</p> <p>13 find Exhibit 1. Exhibit 1 -- if you can</p> <p>14 hand me that please.</p> <p>15 Q. So now with respect to the police</p> <p>16 report, are you aware that over 30 underage</p> <p>17 girls, meaning under the age of 18 gave</p> <p>18 reports to police that they were assaulted</p> <p>19 sexually by Jeffrey Epstein during massages?</p> <p>20 MR. PAGLIUCA: Objection to the</p> <p>21 form and foundation.</p> <p>22 A. I read the police report. That's</p> <p>23 all I can testify to.</p> <p>24 Q. Are you aware of what is in the</p> <p>25 police report? Are you aware that there were</p>	<p>Page 85</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. How about 2004?</p> <p>3 A. I was present for his mother's --</p> <p>4 his mother died in 2004 so I was there for</p> <p>5 his mother's death and the funeral and I was</p> <p>6 at the house maybe a handful of days, again.</p> <p>7 Q. I would like to direct you to, you</p> <p>8 have it pulled together now, it's page 39,</p> <p>9 [REDACTED] stamped [REDACTED] 00040?</p> <p>10 A. Can you repeat that, please.</p> <p>11 Q. Sure. 00040.</p> <p>12 A. Yes.</p> <p>13 Q. At the top of that document, about</p> <p>14 three lines down, you see the redacted</p> <p>15 portions where there is black so it blacks</p> <p>16 out the name.</p> <p>17 A. I see black redacted portions.</p> <p>18 Q. That's a black redaction of the</p> <p>19 name of the minor and there is -- I will</p> <p>20 represent for the record that's what it is.</p> <p>21 You can contest that but I'm not asking about</p> <p>22 the name of the minor.</p> <p>23 Five lines down, it says, She was</p> <p>24 just 16 years of age.</p> <p>25 Do you see that?</p>

Page 82 1 G Maxwell - Confidential 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

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 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 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?

1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 A. I have to read that, if you want me 2 Q. I'm not asking about Virginia. I'm 3 to testify to some things. 3 asking if you are aware that there were over 4 Q. I'm asking if you see where it 4 30 underage girls who gave reports to police 5 says, She was just 16 years old. 5 officers during the time you worked for 6 A. No, I have to read it. 6 Jeffrey Epstein. Are you aware of that? 7 Q. It's five line downs on the first 7 MR. PAGLIUCA: Counsel, what is 8 paragraph. 8 your factual basis for asserting there 9 A. I do see that. 9 are 30 underaged people who gave 10 Q. Then the next paragraph down, it 10 reports? 11 says, this is the next full paragraph, it 11 MS. McCAWLEY: I don't have to 12 says, Epstein entered the room, introduced 12 answer that. 14 her to get comfortable, blank could not 14 as an officer of the court that you have 15 remember if he was naked or if he entered the 15 personal knowledge that there arc 10 16 room with a towel. Blank stated she provided 16 people referenced in these police 17 the massage wearing her panties. She 17 reports? 18 continued rubbing his thighs and feet. Blank 18 MS. McCAWLEY: That's my 19 advised he turned over on his back and 19 understanding, that there are 30 girls. 20 continued to rub his legs with oil. Epstein 20 MR. PAGLIUCA: How is that your 21 touched her breast and began to masturbate. 21 understanding if these are redacted 22 I asked if she knew what circumcised and 22 reports? 23 uncircumcised meant. She stated circumcised 23 MS. McCAWLEY: By reading through 24 is when the penis had no foreskin. 24 the reports.¶

13 himself, Epstein lay on the table and told 13 MR. PAGLIUCA: Are you representing 25 Then jumping down to the next 25 MR. PAGLIUCA: So you have personal¶

Page 87 Page 89 3 crying hysterically and stated she was paid 3 MS. McCAWLEY: Just like can you if 8 Q. Are you aware that there were 8 individuals who were minors who gave reports 22 Beach house during the time you are working 22 tell from you my personal knowledge I did not¶

1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 paragraph, it says, Blank became upset. 2 knowledge there are 30 people -- 4 and also instructed to have sex with Epstein 4 you read through -- I will not argue 5 and by Epstein. 5 with you counsel.. she can answer yes or 6 Do you see that there? 6 no. 7 A. I do. 7 Q. Are you aware there were over 30 9 underage minors in the Palm Beach house that 9 to police just like the one we just read that 10 were required to give sexual massages to 10 they were sexually assaulted by Jeffrey 11 Jeffrey Epstein? 11 Epstein in the Palm Beach home during the 12 MR. PAGLIUCA: Objection to the 12 years that you were working with him? 13 form and foundation. This has been 13 MR. PAGLIUCA: Objection to the 14 asked and answered already. Now you are 14 form and foundation. You can answer if 15 just reading a document. 15 you have knowledge. 16 MS. McCAWLEY: I am allowed to take 16 A. I already testified I was limited 17 this deposition. 17 in the house, a couple of days, there is no 18 A. I already testified -- 18 way I knew. I have read these reports. I 19 Q. Are you aware there were underage 19 cannot testify to 30. Given the experience 20 girls, 30 of them, in this police report that 20 I've had with Virginia's lies, it's very hard 21 were assaulted by Jeffrey Epstein in the Palm 21 for me to testify about what I see. I can 23 there? 23 know what you are referring to. 24 A. I am aware that Virginia has 24 Q. You did not know there were 25 lied repeatedly -- 25 underage girls in the home that were being¶

<p>Page 90</p> <p>1 G Maxwell - Confidential 2 assaulted by Jeffrey Epstein during the time 3 you were working there? 4 A. Based on the lies that I have 5 already been told, I cannot comment on any -- 6 Q. Are you saying these 30 girls are 7 lying when they gave these reports to police 8 officers? 9 A. I'm not testifying to their lies. 10 I'm testifying to Virginia's lies. 11 Q. I am not asking about Virginia's 12 lies. 13 A. I can only testify to Virginia's 14 lies. I can testify to having read these 15 reports. I cannot testify to anything else 16 about them. 17 Q. So your testimony is that during 18 the time you were working there, you did not 19 know that these minor children were being 20 abused in the home while you were there? 21 A. What I have already told you and I 22 will repeat, I was in the house very limited 23 times, very few times. I do not know what 24 you are referring to. I've read these 25 reports but based on the lies that Virginia</p>	<p>Page 92</p> <p>1 G Maxwell - Confidential 2 Q. In your responsibilities in working 3 for Jeffrey, would you book massages for him 4 on any given day so that he would have a 5 massage scheduled? Would you take a call for 6 example and book a massage for him? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 Q. You can answer. 10 A. Typically, that was not my 11 responsibility. He would either book the 12 massage himself or one of his other 13 assistants would do that. 14 Q. From time to time you had to do 15 that? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. Like I said, typically it was 19 somebody else's responsibility. 20 Q. If you were unable to book a girl 21 for a massage on a given day, would that mean 22 that you were responsible for giving him a 23 sexual massage? 24 MR. PAGLIUCA: Objection to the 25 form and foundation and I instruct you</p>
<p>Page 91</p> <p>1 G Maxwell - Confidential 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.</p>	<p>Page 93</p> <p>1 G Maxwell - Confidential 2 not to answer any questions about any of 3 your consensual adult sexual activity. 4 Q. So you are not going to answer that 5 question? 6 A. You just heard my counsel. 7 Q. Have you ever said to anybody that 8 recruiting other girls to perform sexual 9 massages for Jeffrey Epstein takes the 10 pressure off you? 11 MR. PAGLIUCA: Object to the form 12 and foundation. 13 A. Repeat the question and break it 14 out. 15 Q. Have you ever said to anybody that 16 you recruit girls -- 17 A. Stop right there. I never 18 recruited girls, let's stop there. Now 19 breakdown the question. 20 Q. Have you ever said to anybody -- 21 A. By girls, we are talking about 22 underage people -- you said girls, are you 23 talking about underage -- we are not talking 24 about consensual acts -- this is a defamation 25 suit.</p>

Page 90 1 G Maxwell - Confidential
2 assaulted by Jeffrey Epstein during the time
3 you were working there?
4 A. Based on the lies that I have
5 already been told, I cannot comment on any --
6 Q. Are you saying these 30 girls are
7 lying when they gave these reports to police
8 officers?
9 A. I'm not testifying to their lies.
10 I'm testifying to Virginia's lies.
11 Q. I am not asking about Virginia's
12 lies.
13 A. I can only testify to Virginia's
14 lies. I can testify to having read these
15 reports. I cannot testify to anything else
16 about them.
17 Q. So your testimony is that during
18 the time you were working there, you did not
19 know that these minor children were being
20 abused in the home while you were there?
21 A. What I have already told you and I
22 will repeat, I was in the house very limited
23 times, very few times. I do not know what
24 you are referring to. I've read these
25 reports but based on the lies that Virginia

Page 92 1 G Maxwell - Confidential
2 Q. In your responsibilities in working
3 for Jeffrey, would you book massages for him
4 on any given day so that he would have a
5 massage scheduled? Would you take a call for
6 example and book a massage for him?
7 MR. PAGLIUCA: Objection to the
8 form and foundation.
9 Q. You can answer.
10 A. Typically, that was not my
11 responsibility. He would either book the
12 massage himself or one of his other
13 assistants would do that.
14 Q. From time to time you had to do
15 that?
16 MR. PAGLIUCA: Objection to the
17 form and foundation.
18 A. Like I said, typically it was
19 somebody else's responsibility.
20 Q. If you were unable to book a girl
21 for a massage on a given day, would that mean
22 that you were responsible for giving him a
23 sexual massage?
24 MR. PAGLIUCA: Objection to the
25 form and foundation and I instruct you

Page 91 1 G Maxwell - Confidential
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.

Page 93 1 G Maxwell - Confidential
2 not to answer any questions about any of
3 your consensual adult sexual activity.
4 Q. So you are not going to answer that
5 question?
6 A. You just heard my counsel.
7 Q. Have you ever said to anybody that
8 recruiting other girls to perform sexual
9 massages for Jeffrey Epstein takes the
10 pressure off you?
11 MR. PAGLIUCA: Object to the form
12 and foundation.
13 A. Repeat the question and break it
14 out.
15 Q. Have you ever said to anybody that
16 you recruit girls --
17 A. Stop right there. I never
18 recruited girls, let's stop there. Now
19 breakdown the question.
20 Q. Have you ever said to anybody --
21 A. By girls, we are talking about
22 underage people -- you said girls, are you
23 talking about underage -- we are not talking
24 about consensual acts -- this is a defamation
25 suit.

<p>Page 94</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. I'm asking the questions. I know</p> <p>3 what this case is about. I'm trying to -- I</p> <p>4 will ask you questions if you don't</p> <p>5 understand the question I can break it down</p> <p>6 for you. I'm happy to do that.</p> <p>7 A. Break it down a lot please.</p> <p>8 Q. I will do that.</p> <p>9 The question is, have you ever said</p> <p>10 to anybody that you recruit other girls --</p> <p>11 A. Why don't you stop there.</p> <p>12 Q. Let me finish my question.</p> <p>13 Have you ever said to anybody that</p> <p>14 you recruit girls to take the pressure off</p> <p>15 you, so you won't have to have sex with</p> <p>16 Jeffrey, have you said that?</p> <p>17 That's the question?</p> <p>18 A. You don't ask me questions like</p> <p>19 that. First of all, you are trying to trap</p> <p>20 me, I will not be trapped. You are asking me</p> <p>21 if I recruit, I told you no. Girls meaning</p> <p>22 underage, I already said I don't do that with</p> <p>23 underage people and as to ask me about a</p> <p>24 specific conversation I had with language, we</p> <p>25 talking about almost 17 years ago when this</p>	<p>Page 96</p> <p>1 G Maxwell - Confidential</p> <p>2 testify to actual language.</p> <p>3 Q. So you won't testify to anything</p> <p>4 I'm asking you 17 years ago about a statement</p> <p>5 you made. How do you know it's 17 years ago?</p> <p>6 A. We are talking about a time in</p> <p>7 2000, right?</p> <p>8 Q. Have you ever said that to anybody?</p> <p>9 A. I'm 54 years old so you are asking</p> <p>10 me in my entire life, what words are you</p> <p>11 asking me in my entire life?</p> <p>12 Q. Your entire life is limited by the</p> <p>13 time you were with Jeffrey, this is the</p> <p>14 question.</p> <p>15 A. Let's time limit the question you</p> <p>16 are asking me.</p> <p>17 Q. So from, let's say, I think you</p> <p>18 said you started with him in 1992, is that</p> <p>19 correct, and finished with him in 2009.</p> <p>20 So from 1992 to 2009 have you ever</p> <p>21 said to anybody that you recruit other and we</p> <p>22 will start with girls to take the pressure</p> <p>23 off you to have sex with Jeffrey?</p> <p>24 MR. PAGLIUCA: Objection to the</p> <p>25 form and foundation.</p>
<p>Page 95</p> <p>1 G Maxwell - Confidential</p> <p>2 took place. I cannot testify to an actual</p> <p>3 conversation or language that I used with</p> <p>4 anybody at any time.</p> <p>5 Q. Have you ever said to anybody that</p> <p>6 you recruit other females over the age of 18</p> <p>7 to take the pressure off you to having to</p> <p>8 have sex with Jeffrey?</p> <p>9 A. I totally resent and find it</p> <p>10 disgusting that you use the word recruit. I</p> <p>11 already told you I don't know what you are</p> <p>12 saying about that and your implication is</p> <p>13 repulsive.</p> <p>14 Q. Answer my question.</p> <p>15 A. I just did.</p> <p>16 Q. Have you ever said to anybody that</p> <p>17 you recruit females --</p> <p>18 A. I don't recruit anybody.</p> <p>19 Q. That's an answer. So you never</p> <p>20 said that?</p> <p>21 A. I'm testifying that I cannot</p> <p>22 testify to an actual language --</p> <p>23 Q. It's a yes or no.</p> <p>24 A. I will not testify to an actual</p> <p>25 statement made 17 years ago, so I cannot</p>	<p>Page 97</p> <p>1 G Maxwell - Confidential</p> <p>2 A. First of all I resent and despise</p> <p>3 the world recruit. Would you like to define</p> <p>4 what you mean by recruit and by girls, you</p> <p>5 mean underage people. I never had to do</p> <p>6 anything with underage people. So why don't</p> <p>7 you reask the question in a way that I am</p> <p>8 able to answer it.</p> <p>9 Q. I'm asking if you ever said that to</p> <p>10 anybody. So if you don't understand the word</p> <p>11 recruit and you never used that word then the</p> <p>12 answer to that question would be no.</p> <p>13 A. I have no memory as I sit here</p> <p>14 today having used that word.</p> <p>15 Q. Did you ever meet an underage girl</p> <p>16 in London to introduce her to Jeffrey to</p> <p>17 provide him with a massage?</p> <p>18 MR. PAGLIUCA: Objection to the</p> <p>19 form and foundation.</p> <p>20 A. Run that past me one more time.</p> <p>21 Q. Did you ever meet an underage girl</p> <p>22 in London to introduce her to Jeffrey to</p> <p>23 perform a massage?</p> <p>24 MR. PAGLIUCA: Same objection.</p> <p>25 A. Are you asking me if I met anybody</p>

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 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 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 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 [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 [REDACTED] 16 for the purposes of providing massages? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I am not aware of [REDACTED] 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>

Page 98 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 [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.

Page 100 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.

Page 99 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 [REDACTED]
16 for the purposes of providing massages?
17 MR. PAGLIUCA: Objection to the
18 form and foundation.
19 A. I am not aware of [REDACTED] 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

Page 101 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>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 [REDACTED] t</p> <p>17 [REDACTED] on your helicopter?</p> <p>18 A. That is another one of Virginia's</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 [REDACTED]</p> <p>23 [REDACTED] 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 [REDACTED] 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 [REDACTED]</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 Virginia was working for Jeffrey?</p> <p>14 A. I don't know that Virginia 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>

Page 102 1 G Maxwell - Confidential 2 A. I don't recall. 3 Q. Did it change over the years or did 4 the payment remain the same? 5 A. I believe over the course of time 6 it increased a little bit. 7 Q. Was that the -- was that payment 8 the payment that -- was the payment made with 9 respect to the jobs, the work you were 10 performing for Jeffrey, was that your sole 11 income at that time? 12 MR. PAGLIUCA: I object to the 13 form. I'm also going to instruct you 14 not to answer about sources of -- your 15 personal sources of income outside of 16 Mr. Epstein at all. 17 MS. McCAWLEY: What's the basis for 18 that? 19 MR. PAGLIUCA: It's confidential, 20 it's not part of this lawsuit. 21 MS. McCAWLEY: We have a protective 22 order and it is part of this lawsuit 23 with respect to our damage claims. 24 MR. PAGLIUCA: It's not and, in 25 fact, you are not entitled to ask

Page 104 1 G Maxwell - Confidential 2 worked for it and I had a loan, we did loans. 3 Q. So a loan through Jeffrey? 4 A. I don't recall the exact 5 transaction. 6 Q. Did he purchase for you a 7 helicopter during the time you were working 8 for him? 9 A. It was his helicopter. 10 Q. When did you obtain your pilot 11 license? 12 A. I believe it was '98 or '99. 13 Q. Was that for both airplanes and 14 helicopters or just helicopters? 15 A. Just helicopters. 16 Q. Have you ever flown [REDACTED] t 17 [REDACTED] on your helicopter? 18 A. That is another one of Virginia's 19 lies. 20 Q. The question is have you ever done 21 that? 22 A. I have never flown [REDACTED] 23 [REDACTED] at any time ever, in any helicopter, 24 in any place, any time, in any state, in any 25 country, at any time anywhere.

Page 103 1 G Maxwell - Confidential 2 financial information of a defendant in 3 this kind of case, in a defamation case 4 unless and until there is a finding that 5 you are entitled to punitive damages. 6 That is clear in New York case law, both 7 state and Federal. 8 MS. McCAWLEY: We disagree on that 9 point and we will come back to that. 10 Q. From the source of payment from the 11 source of Jeffrey, from your work, can you 12 give me a range on that, do you know was it 13 over $100,000? 14 A. I just testified I don't recall. 15 Q. You don't don't know if it was 16 $500,000? 17 A. It was less than that. 18 Q. Somewhere between 100 and 500, 19 would that be fair to say? 20 A. I believe it was between 100 and 21 $200,000. 22 Q. Did Jeffrey during the time that 23 you were working for him purchase a town home 24 for you? 25 A. The subject of the townhouse is, I

Page 105 1 G Maxwell - Confidential 2 Q. Have you ever had dinner with 3 [REDACTED] at Jeffrey's home, at any 4 of Jeffrey's homes? 5 A. No, I don't believe so. 6 Q. Have you traveled on Jeffrey's 7 planes with [REDACTED] 8 A. Yes, I have. 9 Q. Would that have been in 2002? 10 A. It's very hard for me to recollect 11 exact dates but that sounds about right. 12 Q. Was that during the time that 13 Virginia was working for Jeffrey? 14 A. I don't know that Virginia ever did 15 work for Jeffrey. I don't exactly know if 16 she testified to her so-called duties, we 17 know she is a serial liar so I can't testify 18 to what she did or didn't do. So I object to 19 that characterization of her. So repeat the 20 question, please. 21 Q. Can you read the question back? 22 (Record read.) 23 Q. You can answer the question. 24 A. What was the question again? 25 Q. When you were traveling on the

1 G Maxwell - Confidential
2 plane with [REDACTED], was that during
3 the time, it was 2002, that you were on a
4 flight with [REDACTED], was that during the time
5 Virginia was working for Jeffrey?¶

6 MR. PAGLIUCA: Object to the form.
7 Misstates the witness' answer and if you
8 can answer the question, you can answer
9 it.¶

10 A. Well, like I said, I don't recall
11 exactly when I flew with him. I don't recall
12 when Virginia, we know what Virginia claims
13 when she left, so I can't answer the
14 question. I have no idea.¶

15 Q. Do you know [REDACTED]¶

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 A. That would be another of Virginia's
3 lies and the lies you perpetrate. I never
4 introduced [REDACTED] to Jeffrey Epstein
5 at any time ever, so just add that the to
6 long list of lies.¶

7 Q. Did Jeffrey know [REDACTED]¶

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

10 Q. Do you know how Jeffrey met [REDACTED]¶

11 [REDACTED]¶

12 A. I do not know Jeffrey met [REDACTED]¶

13 [REDACTED]. 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 [REDACTED]¶

17 [REDACTED]¶

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

20 [REDACTED]¶

21 Q. Did you ever introduce [REDACTED]¶

22 [REDACTED] to any girls under the age of 18 who
23 were not friends of yours children?¶

24 A. I have not introduced [REDACTED]¶

25 to anyone that I am aware of other than
friends of mine who have kids under that age¶

1 G Maxwell - Confidential
2 that he may have met socially through me.¶

3 Q. Did you ever introduce [REDACTED]
4 [REDACTED] to Virginia in London?¶

5 A. I understand her story about [REDACTED]
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 [REDACTED]
12 [REDACTED] to Virginia in London?¶

13 A. I have no recollection.¶

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

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

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

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

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 11.0 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 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 bein 25 present in New York for a party w re¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 G Maxwell - Confidential A. I've looked at it. Q. Are you in that picture? A. I am. A. It is. MR. PAGLIUCA: I don't believe this has been produced to us in discovery by you. MS. McCAWLEY: The picture? MR. PAGLIUCA: Yes. MS. McCAWLEY: It has. MS. MENNINGER: Is it the same exact photograph. MS. McCAWLEY: I believe so. We will find one. The picture has been produced a number of times. MR. PAGLIUCA: I've seen different iterations of this, I don't believe I have ever seen this. MS. McCAWLEY: We had them blow it up on a page so she could see it. We could use an article. While you are looking for that, I¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 21 22 23 24 25 Page 111 G Maxwell - Confidential will skip ahead. Hold that until we can find one that has the range on it. Q. Do you recall Virginia being at your London town home? A. I do not. . Do ou recall going to dinner with, Jeffrey Epstein and Virginia In ndon. at any time? A. I do not. Q. Do you recall going to a place called Epstein and yourself and A. I would Oust like to state record I • o not ave any reco ection of it an doubt it actually happened. Q. You don't recall that. Do you recall taking Virginia shopping when ou were in London to buy an outfit to mee¶

Page 113 1 G Maxwell - Confidential 2 was also present? 3 ill don't recollect. 4 . Do you recall ever giving 5 a gift of a puppet that 6 same -- that looked like him? 7 A. I never gave him a gift of a 8 puppet. 9 Q. Did Jeffrey ever give him a gift of 10 a puppet? 11 A. No, not that I am aware of. 12 Q. Have you ever given him any gifts? 13 MR. PAGLIUCA: Objection, 14 foundation. 15 A. I know 16 Q. Have you ever given him any gifts 17 that you remember when he came to Jeffrey's 18 home in New York? 19 A. I don't recall giving him any gifts 20 in New York. 21 (Maxwell Exhibit 5, picture. marked 22 for identification.) 23 Q. I think I directed you to page 24 0034. 25 Is that a picture that was taken at¶

Page 114 Page 116 1 G Maxwell - Confidential 2 . Were ou present on the island when 3 visited? 4 . es. 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 arras e for 21 Virginia to have sex wit 22 MR. PAGLIUCA: jection tothe 23 form and foundation. 24 A. Just for the record, I have never 25 at any time, at anyplace, in any moment ever¶

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 Jeffery 16 Epstein took the picture? 17 A. When I tell you I don't know who 18 took the picture, it doesn't mean him -- I 19 don't know who took the picture. You can 20 come up with 50 names, I still do not know 21 who took the picture. 22 Q. Did you observe go 23 into a room with Virginia a one in your town 24 home? 25 A. I cannot recall. As I have said,¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 115 G Maxwell - Confidential no. Q. Did ever tell you that he had sex wit A. He did not. Did Jeffre Epstein ever tell you tha had sex with Virginia A. He did not. Q. Did ever visit -- let me back up or a moment. We talked about Jeffrey's homes, did Jeffrey have a home in the U.S. Virgin islands called Little St. James? A. Yes. Q. Did ever visit that island -- are you aware o visiting Jeffrey's island? A. I am aware of that, yes. Q. Do you know how many times he visited? A. I do not. Q. Do you know if he visited when Virginia was on the island? A. I do not. ever¶

Page 117 1 G Maxwell - Confidential 2 asked or whatever she is 3 called now to have sex with anybody. ⁴iiDid you ever provide Virginia 5 with an outfit, an outfit of a sexual 6 nature to wear for - 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I think we addressed the outfit 10 issue. 11 Q. I am asking you if you ever 12 provided her with an outfit of a sexual 13 nature to wear for 14 A. Categorically no. You did get 15 that, I said categorically no 16 Q. Don't worry I'm paying attention. 17 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 118</p> <p>1 G Maxwell - Confidential</p> <p>2 We are off the record.</p> <p>3 (Recess.)</p> <p>4 THE VIDEOGRAPHER: It's now 11:26,</p> <p>5 we are back on the record and starting</p> <p>6 disk No. 3.</p> <p>7 Q. Ms. Maxwell, I think I handed you</p> <p>8 right before the break, did I hand you the</p> <p>9 flight logs, they look like this. Did I mark</p> <p>10 those yet, I thought I did.</p> <p>11 A. I don't believe I have it.</p> <p>12 Q. These admittedly are a little</p> <p>13 difficult to read so what I'm going to</p> <p>14 provide you with to assist is I have a chart</p> <p>15 that has the airport codes, because it will</p> <p>16 have, for example, just for the record</p> <p>17 reflects that the first page of document</p> <p>18 [REDACTED], it will have a code in the from line</p> <p>19 that says PBI, for example, to TEB so I a</p> <p>20 chart that matches up, just in case you don't</p> <p>21 understand what those letters mean, PBI</p> <p>22 meaning Palm Beach, TEB meaning Teterboro,</p> <p>23 which is New Jersey, but others are more</p> <p>24 difficult but just for you to be able to</p> <p>25 understand the logs, I will provide you with</p>	<p>Page 120</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. So I'm directing your attention to</p> <p>3 the bottom, two lines up from the bottom,</p> <p>4 there is a flight --</p> <p>5 MR. PAGLIUCA: Are you on [REDACTED]</p> <p>6 MS. McCAWLEY: [REDACTED]</p> <p>7 Q. So this flight is from, the one I'm</p> <p>8 looking at, I think it's highlighted on your</p> <p>9 copy. On the far corner on the date, it says</p> <p>10 [REDACTED] at the top and this would be the [REDACTED]</p> <p>11 and then the [REDACTED] are the two I'm going to</p> <p>12 direct your attention to.</p> <p>13 Q. On that first one on the [REDACTED] you</p> <p>14 will see the column reading PBI in the from</p> <p>15 column to TEB in the to column and you will</p> <p>16 see some initials, you will see JE for</p> <p>17 Jeffrey Epstein, GM for Ghislaine Maxwell, [REDACTED]</p> <p>18 for [REDACTED] and then Virginia?</p> <p>19 A. I have to object.</p> <p>20 MR. PAGLIUCA: You don't get to</p> <p>21 object.</p> <p>22 Q. She is turning into a lawyer</p> <p>23 already?</p> <p>24 A. I would like to.</p> <p>25 Q. Let me ask the question and if you</p>
<p>Page 119</p> <p>1 G Maxwell - Confidential</p> <p>2 that.</p> <p>3 MR. PAGLIUCA: So we are clear, if</p> <p>4 the witness has personal knowledge of</p> <p>5 what these are that's fine but I don't</p> <p>6 know what these are and I don't expect</p> <p>7 the witness to accept the representation</p> <p>8 that they are what they are.</p> <p>9 MS. McCAWLEY: If she can testify</p> <p>10 to what city it is, she can state that</p> <p>11 on the record.</p> <p>12 MR. PAGLIUCA: If she knows what it</p> <p>13 is, she knows what it is, we are not</p> <p>14 putting any affirmatively on the record</p> <p>15 until you ask your questions.</p> <p>16 Q. So I'm going to ask you and I think</p> <p>17 we flagged a few of the pages which may</p> <p>18 direct us a little bit easier but I will do</p> <p>19 it by [REDACTED] number which is at the bottom of</p> <p>20 the document kind of at the side.</p> <p>21 The first I will direct your</p> <p>22 attention to is [REDACTED]</p> <p>23 A. Does it have a tab?</p> <p>24 Q. It should. Let me make sure.</p> <p>25 A. Yes it does.</p>	<p>Page 121</p> <p>1 G Maxwell - Confidential</p> <p>2 have an issue -- so with respect to this</p> <p>3 flight, do you recall being on a flight in</p> <p>4 the -- [REDACTED] going from Palm Beach to</p> <p>5 Teterboro?</p> <p>6 A. No, I don't recall any specific</p> <p>7 flight.</p> <p>8 Q. Do you recall flying with Virginia</p> <p>9 on a flight with [REDACTED] and Jeffrey</p> <p>10 Epstein at any time?</p> <p>11 A. I don't.</p> <p>12 Q. How often did you fly on a plane</p> <p>13 with a 17 year old?</p> <p>14 MR. PAGLIUCA: Objection to form</p> <p>15 and foundation.</p> <p>16 A. I have no idea what you are talking</p> <p>17 about, other than friends of mine that had</p> <p>18 kids.</p> <p>19 Q. Did you regularly fly on Jeffrey's</p> <p>20 plane with individuals who were under the age</p> <p>21 of 18?</p> <p>22 MR. PAGLIUCA: Objection to the</p> <p>23 form and foundation.</p> <p>24 A. Can you repeat the question?</p> <p>25 Q. Did you regularly fly on Jeffrey</p>

Page 118 1 G Maxwell - Confidential 2 We are off the record. 3 (Recess.) 4 THE VIDEOGRAPHER: It's now 11:26, 5 we are back on the record and starting 6 disk No. 3. 7 Q. Ms. Maxwell, I think I handed you 8 right before the break, did I hand you the 9 flight logs, they look like this. Did I mark 10 those yet, I thought I did. 11 A. I don't believe I have it. 12 Q. These admittedly are a little 13 difficult to read so what I'm going to 14 provide you with to assist is I have a chart 15 that has the airport codes, because it will 16 have, for example, just for the record 17 reflects that the first page of document 18 [REDACTED], it will have a code in the from line 19 that says PBI, for example, to TEB so I a 20 chart that matches up, just in case you don't 21 understand what those letters mean, PBI 22 meaning Palm Beach, TEB meaning Teterboro, 23 which is New Jersey, but others are more 24 difficult but just for you to be able to 25 understand the logs, I will provide you with

Page 120 1 G Maxwell - Confidential 2 Q. So I'm directing your attention to 3 the bottom, two lines up from the bottom, 4 there is a flight -- 5 MR. PAGLIUCA: Are you on [REDACTED] 6 MS. McCAWLEY: [REDACTED] 7 Q. So this flight is from, the one I'm 8 looking at, I think it's highlighted on your 9 copy. On the far corner on the date, it says 10 [REDACTED] at the top and this would be the [REDACTED] 11 and then the [REDACTED] are the two I'm going to 12 direct your attention to. 13 Q. On that first one on the [REDACTED] you 14 will see the column reading PBI in the from 15 column to TEB in the to column and you will 16 see some initials, you will see JE for 17 Jeffrey Epstein, GM for Ghislaine Maxwell, [REDACTED] 18 for [REDACTED] and then Virginia? 19 A. I have to object. 20 MR. PAGLIUCA: You don't get to 21 object. 22 Q. She is turning into a lawyer 23 already? 24 A. I would like to. 25 Q. Let me ask the question and if you

Page 119 1 G Maxwell - Confidential 2 that. 3 MR. PAGLIUCA: So we are clear, if 4 the witness has personal knowledge of 5 what these are that's fine but I don't 6 know what these are and I don't expect 7 the witness to accept the representation 8 that they are what they are. 9 MS. McCAWLEY: If she can testify 10 to what city it is, she can state that 11 on the record. 12 MR. PAGLIUCA: If she knows what it 13 is, she knows what it is, we are not 14 putting any affirmatively on the record 15 until you ask your questions. 16 Q. So I'm going to ask you and I think 17 we flagged a few of the pages which may 18 direct us a little bit easier but I will do 19 it by [REDACTED] number which is at the bottom of 20 the document kind of at the side. 21 The first I will direct your 22 attention to is [REDACTED] 23 A. Does it have a tab? 24 Q. It should. Let me make sure. 25 A. Yes it does.

Page 121 1 G Maxwell - Confidential 2 have an issue -- so with respect to this 3 flight, do you recall being on a flight in 4 the -- [REDACTED] going from Palm Beach to 5 Teterboro? 6 A. No, I don't recall any specific 7 flight. 8 Q. Do you recall flying with Virginia 9 on a flight with [REDACTED] and Jeffrey 10 Epstein at any time? 11 A. I don't. 12 Q. How often did you fly on a plane 13 with a 17 year old? 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. I have no idea what you are talking 17 about, other than friends of mine that had 18 kids. 19 Q. Did you regularly fly on Jeffrey's 20 plane with individuals who were under the age 21 of 18? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. Can you repeat the question? 25 Q. Did you regularly fly on Jeffrey

1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 Epstein's planes with individuals who were 2 me. 3 under the age of 18? 3 Q. So as you sit here today. you don't 4 A. I regularly flew on Jeffrey 4 believe you flew on that plane? 5 Epstein's airplane but I cannot testify as to 5 A. I'm not saying that. I'm just 6 flying with people under the age. I don't 6 saying you cannot be sure that's me. 7 believe that I did. 7 Q. Do you have reason to doubt that 8 Q. Why wouldn't you remember flying 8 when it says GM on these flight logs that 9 with a 17 year old? 9 that represents you? 10 MR. PAGLIUCA: Objection to the 10 A. I cannot testify to that. I'm just 11 form and foundation. 11 saying it may not be me. 12 A. How would I know, one, that she is 12 Q. In looking at the flight logs and 13 17, how would you know that, how do you know 13 look up, let's move up a couple of lines. It 14 15 I'm on the plane. Q. Are you saying you are not on this 17 This says the JE, GM■ and Virginia. The GM 17 , reposition, JE, GM, .1E, GM 18 you are saying is not you? 18 JE, GM, 19 MR. PAGLIUCA: I object to the 19 female, 22 A. How do you know the GM is me. 22 JE, GM, • Virginia. repositioning and then 23 Q. Is it your testimony that on the 23 a certification. 24 flight logs when it represents GM that it is 24 So is it your testimony in looking 25 not you flying on the plane? 25 at that that you do not believe that the GM¶

14 15 you start at the top, you are oin to see .1E, then JE . 16 flight, so this is a Palm Beach to Teterboro. 16 JE, SE, GM. SE. GM, JE. GM, 20 form. You can answer the question if 20 repositionin • 1E, GM ,.1E, 21 you know. 21 GM. ..IE. GM. Virginia,¶

1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 2 represents you? 3 form and foundation. 3 MR. PAGLIUCA: Objection to the 4 A. GM can stand for any level, it 4 form and foundation. 5 could be Georgina. . 5 A. I'm not saying that. I'm just 6 Q. Are there any people that flew with 6 saying that you cannot -- I can't sit here 7 Jeffrey Epstein that had the initials GM? 7 and tell you for sure GM is me and I cannot B A. I don't know. 8 testify remembering being on a flight at that 9 Q. Do you recall flying with Jeffrey 9 time. 10 Epstein on his plane over 300 times during 10 Q. You don't remember being on any of 11 the period of 1999 to 2005? 11 these flights with the initial GM? 12 A. I cannot testify to how many times 12 A. I remember being on many flights. 13 I was on his plane because that would just be 13 I cannot testify that is a flight I am on. 14 impossible. 14 Q. Let's o to the next page which is 15 Q. You were on his plane regularly. 15 going to be . I want you to look at 16 would you say? 16 line -- so the ate is at the top, so it's 18 plane regularly. 18 a me at says th and if you scroll 19 Q. Is it your testimony and I'm 19 over you will see to Tin, if you look at 20 referring now to the line that we were just 20 the airport codes, TIST is going to be 21 talking about that you were not on the flight 21 representative for the U.S. Virgin Islands 22 from Palm Beach to Teterboro that lists JE, 22 and then ou will see the list on the plane 23 24 GM. and Virginia? A. am not testifying to that. I am 25 just saying that you cannot be sure that is 25 Beach to the U.S. Virgin Islands with¶

17 A. I already testified I was on his 17 and if ou go down, you will see 23 24 SE, GM. and Do you recall flying from Palm¶

Page 126¶

1 G Maxwell - Confidential
2 Jeffrey, yourself, [REDACTED] and Virginia
3 [REDACTED]?
4 MR. PAGLIUCA: I object to the form
5 and just so the record is clear, we
6 don't agree with whatever your
7 characterizations are. The document
8 speaks for itself and she can answer
9 based on whatever her personal knowledge
10 is.
11 MS. McCAWLEY: I understand.
12 Q. Do you recall flying with those
13 individuals from Palm Beach to the U.S.
14 Virgin Islands?
15 A. I have no recollection of any
16 individual flight you are pointing out here.
17 You are talking about 2001, how many years
18 ago is that?
19 Q. I'm asking the questions.
20 A. I'm not being difficult. I'm just
21 asking, it's like 14, 15 years ago, it's
22 impossible, I'm sorry.
23 Q. So your testimony is you don't
24 recall flying on that flight with Virginia
25 [REDACTED]?¶

Page 127¶

1 G Maxwell - Confidential
2 A. I cannot testify to that flight.
3 Q. Let's look at the next flight which
4 is on the [REDACTED] from the Virgin Islands back
5 to Palm Beach, JE, Jeffrey Epstein, Ghislaine
6 Maxwell, [REDACTED], [REDACTED], the
7 same individuals on the above flight.
8 A. It doesn't say my name, it has some
9 initials.
10 Q. I understand, the initials GM.
11 Do you recall flying on a plane, on
12 one of Jeffrey's planes from the Virgin
13 Islands to Palm Beach with [REDACTED]?
14 A. I do not.
15 Q. Was there any other person that
16 flew with Jeffrey Epstein with frequency
17 during that time period in these logs that
18 have the initials GM?
19 MR. PAGLIUCA: Objection to the
20 form and foundation.
21 A. I would have to look at all the
22 flight logs, I have no idea, I flew
23 frequently.
24 Q. Why don't you take a look at the
25 next three pages and see if that refreshes¶

Page 128¶

1 G Maxwell - Confidential
2 your recollection.
3 MR. PAGLIUCA: You are talking
4 about [REDACTED]
5 MS. McCAWLEY: She can pick any
6 couple of pages, those have a lot of the
7 individuals on them so that is a good
8 sampling.
9 MR. PAGLIUCA: So pick any pages
10 you want.
11 Q. Does that refresh your recollection
12 at all as to whether GM represents you or
13 some other individual?
14 A. Again, I can't testify whether that
15 represents me or not, I don't see any other
16 GMs but you have to understand that even if
17 my name is on that record doesn't mean I was
18 on the flight.
19 Q. So are you contesting the accuracy
20 of the flight logs? In other words, you said
21 it doesn't represent you are on the flight so
22 is it your testimony just because a name is
23 listed doesn't mean they were actually on the
24 flight?
25 MR. PAGLIUCA: Objection to the¶

Page 129¶

1 G Maxwell - Confidential
2 form and foundation.
3 A. I can't testify to what -- these
4 are records that were produced by [REDACTED]
5 is on here, so these aren't federally
6 mandated records, so I can't testify to what
7 he produced.
8 Q. I would like you to turn to page.
9 at the bottom, the [REDACTED] number is [REDACTED].
10 And the month is [REDACTED].
11 A. Okay.
12 Q. If you go down to the number that
13 is [REDACTED], that would be [REDACTED], you're
14 going to see on that line and then you
15 will see [REDACTED] which is going to be, I'm going
16 to pronounce it incorrectly, [REDACTED],
17 [REDACTED], I'm sure I'm not pronouncing that
18 correctly. Then you will see in the list,
19 you will see JE, GM, [REDACTED],
20 [REDACTED], it looks like --
21 A. I believe it says male.
22 Q. Yes. Then [REDACTED] I
23 believe. Is that GM on this page
24 representative of you?¶

1 G Maxwell - Confidential
2 A. Well, this would be a flight that I
3 would potentially remember with [REDACTED]
4 on it but I don't actually recall going to
5 Russia.
6 Q. Are those your initials, do you
7 recall being on the flight?
8 A. Those are my initials with
9 [REDACTED], I don't recall this flight
10 either, but I would be more likely to if I
11 had a bit more time to study the timing of
12 this.
13 Q. Your testimony is you don't recall
14 flying with [REDACTED] from [REDACTED] to
15 [REDACTED]
16 A. I don't recall the [REDACTED] to [REDACTED]
17 flight. I have definitely flown with
18 [REDACTED].
19 Q. On that same page you will see
20 beneath there, beneath 22 you will see the
21 indication, same as above, same as above,
22 same as above in the column that originally
23 had the initials.
24 A. Uh-huh.
25 Q. And the names.¶

1 G Maxwell - Confidential
2 then you will see the [REDACTED] which
3 is the column which is where I want you to
4 start looking at the log and there you're
5 going to see [REDACTED]
6 [REDACTED]
7 [REDACTED]
8 [REDACTED]
9 [REDACTED]
10 A. Okay.
11 Q. If you look at the column, if you
12 go back up to the top on the [REDACTED], if you look
13 at the column you will see JE, GM, [REDACTED],
14 Virginia [REDACTED] and I believe it says [REDACTED]
15 [REDACTED], sorry I'm not reading that very
16 well.
17 Do you recall flying from, if you
18 see the dates, the [REDACTED]
19 [REDACTED] Do you recall a trip that went from
20 the United States to [REDACTED] and to the places
21 I just mentioned where [REDACTED] was
22 on the plane with you?
23 MR. PAGLIUCA: Objection to the
24 form and foundation.
25¶

1 G Maxwell - Confidential
2 A. Uh-huh.
3 Q. Do you recall flying with [REDACTED]
4 [REDACTED] from [REDACTED] to [REDACTED]
5 [REDACTED]
6 A. I do.
7 Q. So the GM that would be represented
8 in that column would be you?
9 A. I recall going to [REDACTED] with [REDACTED]
10 [REDACTED] so that is likely to be me.
11 Q. You were on Jeffrey's plane for
12 that trip?
13 A. I believe I was.
14 Q. Do you know who [REDACTED]
15 is?
16 A. I do not.
17 Q. I'm going back towards the front
18 which is going to be [REDACTED] please. And
19 you're going to see --
20 A. Hang on I'm not --
21 Q. Take your time.
22 A. Okay.
23 Q. You are going to see in the date
24 column, you will see [REDACTED] and then about
25 halfway down you will see [REDACTED]¶

1 G Maxwell - Confidential
2 A. I already testified that I don't
3 recall Virginia on any of these flights.
4 Q. I would like to mark, as Maxwell 7,
5 I will put it at the top?
6 (Maxwell Exhibit 7, photo, marked
7 for identification.)
8 MR. PAGLIUCA: Has this document
9 been produced in discovery?
10 MS. McCAWLEY: Yes.
11 MR. PAGLIUCA: Do you have a [REDACTED]
12 number?
13 MS. McCAWLEY: This one doesn't.
14 Q. I'm going to ask you --
15 MR. PAGLIUCA: I don't recall
16 seeing this document so I would like to
17 see a [REDACTED] number document before we
18 ask questions about it.
19 MS. McCAWLEY: Can you go look for
20 it and I will continue. We will set
21 that aside until we get a [REDACTED] number.
22 You may want to leave that log up and
23 set it to the side and we will bounce
24 back to that.
25 Q. Do you recall -- I think earlier¶

1 G Maxwell - Confidential
2 you said you visited Jeffrey's island, I
3 think they called it St. Jeffrey or St.
4 James, the U.S. Virgin Island home.
5 A. St. James.
6 Q. Do you recall whether [REDACTED]
7 [REDACTED] was ever on that island?
8 A. Categorically, definitively,
9 absolutely, without a shadow of a doubt, when
10 I was present or any other time that I am
11 aware of, was [REDACTED] ever on that
12 island, I do not believe he went to that
13 island ever ever, that is an absolute
14 fabrication and an absolute flat out lie.
15 Q. Was [REDACTED]
16 [REDACTED] ever at any of Jeffrey
17 Epstein's homes when you present, other than
18 the island I know you said that did not
19 happen, the home in either New York or Palm
20 Beach or New Mexico?
21 A. I do not believe at any time
22 [REDACTED] was at any of Jeffrey's
23 homes, I have absolutely no knowledge or
24 otherwise that he was ever there.
25 Q. You don't recall having dinner with¶

1 G Maxwell - Confidential
2 observe Jeffrey and [REDACTED]
3 talking?
4 A. I'm sure they did.
5 Q. Did they seem friendly?
6 A. I don't recollect.
7 Q. Was Epstein one of the original
8 people that conceived the [REDACTED]
9 [REDACTED]
10 MR. PAGLIUCA: Objection to the
11 form and foundation.
12 Q. Do you know?
13 A. I don't have -- I don't know what
14 you are talking about.
15 Q. You don't know what I'm talking
16 about.
17 Did you ever, not at one of houses,
18 but did you ever eat dinner with [REDACTED]
19 [REDACTED] and Jeffrey Epstein?
20 A. Are you just talking in general
21 anywhere.
22 Q. In general?
23 A. I believe on a plane of this nature
24 we would have had a meal.
25 Q. But not outside of the travel on¶

1 G Maxwell - Confidential
2 him at any of those homes?
3 A. Again, Virginia is absolutely
4 totally lying. This is a subject of
5 defamation about Virginia and the lies she
6 has told and one of lies she told was that
7 President Clinton was on the island where I
8 was present. Absolutely 1000 percent that is
9 a flat out total fabrication and lie.
10 Q. You did fly on planes, Jeffrey
11 Epstein's planes with President Clinton, is
12 that correct?
13 A. I have flown, yes.
14 Q. Would it be fair to say that
15 President Clinton and Jeffrey are friends?
16 A. I wouldn't be able to characterize
17 it like that, no.
18 Q. Are they acquaintances?
19 A. I wouldn't categorize it.
20 Q. He just allowed him to use his
21 plane?
22 A. I couldn't categorize Jeffrey's
23 relationship.
24 Q. When you were on the plane with
25 Jeffrey and President Clinton, did you¶

1 G Maxwell - Confidential
2 the flights?
3 A. I can't recollect having a meal
4 with them, but just so we are clear, the
5 allegations that [REDACTED] had a meal on
6 Jeffrey's island is 100 percent false.
7 Q. But he may have had a meal on
8 Jeffrey's plane?
9 A. I'm sure he had a meal on Jeffrey's
10 plane.
11 Q. You do know how many times he flew
12 on Jeffrey's plane?
13 A. I don't.
14 Q. Do you know who [REDACTED] is?
15 A. I do.
16 Q. How do you know him?
17 A. He used to work or still works for
18 [REDACTED].
19 Q. Did you ever have a relationship
20 with him?
21 A. We are talking about adult
22 consensual relationships, it's off the
23 record.
24 Q. I'm not asking what you did with
25 him, I'm asking if you ever had a¶

Page 138 Page 140 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 G Maxwell - Confidential MR. PAGLIUCA: That s what the document says. Q. I'm not representing the date but there it is. So the last leg of that where it says same as above has, the second to last, I'm sorry on the ou remember being in Thailand with A. o. Q. Do you remember what the purpose of that trip was? A. I don't. Q. Do you know whether -- do you recall, did you stay the night in Thailand? A. I don't recall. Q. Do you recall why you went to Thailand? A. I don't recall. Q. Who is A. She I believe was a stewardess on this flight. Q. Did she perform any massages on the¶

G Maxwell - Confidential 2 relationship with him? 3 MR. PAGLIUCA: If you understand 4 the term relationship, certainly you can 5 answer that. 6 A. Define relationship. 7 Q. Somebody that you would have spent 8 time together, either seeing them in a 9 romantic relationship or -- 10 A. You need to be, what do ou mean by 11 romantic. I was friends witf but you 12 are suggesting something more so want to be 13 clear what you are actually asking me. 14 Q. You defined it. You said you were 15 friends with him. If that's what you were 16 that's all I need to know. 17 While ou were on the trip with 18 , do you recall where you 19 staye at ese ocations, in other words, 20 would you leave the jet and stay overnight at 21 a hotel, do you have a recollection of this 22 trip? 23 A. I recollect the trip but if you're 24 asking me where we stayed, you can see it's a 25 very fast paced trip. It was very tiring and¶

Page 139 1 G Maxwell - Confidential 2 I don't recollect where we stayed. 4 the same place Q. Do you recollect if ou stayed at stayed? In 3 5 other words, if you ett epane to go a 6 hotel did you all go together is your 7 recollection? 8 A. I honestly don't recollect, no. 9 Q. Part of this trip we were just 10 talking about, there is a flight that goes to 11 Thailand, do you remember being in Thailand? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 15 16 Q. On the A. Are you askin me - trip. 14 A. Are you referencing something? 17 Q. The part that, let me make sure 18 I've got it here. The entry that would be 19 the Thailand, would be the one -- let me make 20 sure I'm correct. I have you on the wrong 21 page, it's actual) the page before. It's 22 going to be . And it's oin to be the 23 entry on, starting o. and then 24 it goes down to where it has t e same as 25 above, to -- I'm sa¶

1 2 3 4 S 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Page 141 G Maxwell - Confidential flight? A. I don't recollect any massages on the flight. Q. Do you know who A. It doesn't -- no I don't know who that is, I can't recall. 1QThis is not in color, it's a black and but it has the label on it. Should I take the sticker off the one that has --I don't know if you want to swap it. MR. PAGLIUCA: Let the record reflect I am replacing this on the black and copy of this exhibit with Q. So, we were talking earlier, we were looking at the flight logs and we were talking about a trip and let me just get you back to the page. is?¶

1 G Maxwell - Confidential 2 Q. Can I direct your attention to the 3 picture, please. 4 A. Of course. 5 Q. Can you tell me who is in this 6 picture, who is pictured here, and for the 7 court reporter's benefit, can you go from the 8 left of the picture to the right of the 9 picture, to the extent you can identify the 10 individuals? 11 A. Sure. I cannot identify the person 12 on the left, I cannot identify the person 13 next left. I can identify Jeffrey Epstein. 14 I cannot identify the next person to his 15 right and the next person in the picture is 16 myself. 17 Q. Is the individual all the way to 18 the left at the beginning of the icture, 19 does that resemble . You might 20 want to look at the co or version if that 21 helps you at all, I know it's not the marked 22 one. I don't if that's easier to see, they 23 are both dark. 24 A. That does not look like 25 at all.¶

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 G Maxwell - Confidential Q. Do you recall -- MR. PAGLIUCA: Let's mark this then as deposition Exhibit 8 since we are referring to it and then you can give us copies as well. MS. MENNINGER: It's different because it has other people in this color photo. (Maxwell Exhibit 8, photo. marked for identification.) Q. Do you recall who took this photograph? A. I do not. Q. Do you recall this photograph being taken by Virginia? A. First of all, I don't know where we are. Q. So you don't recognize the building? A. don't recognize Does this like look a picture of a myself. recognize in the picture are Jeffrey and A. I don't recognize the building and I -- the only two people I¶

1 G Maxwell - Confidential 2 building that you would have seen when you 3 were on the trip in Europe? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't possibly answer that. 7 Q. Do you recall Virginia ever taking 8 pictures? 9 A. I barely recall Virginia, period. 10 Q. Do you recall her ever taking 11 pictures? 12 A. No, I don't. 13 Q. I'm going to direct your attention. 14 still within the flight logs to -- starting 15 on the next page from where you just were 16 which is goin imto be . And the date at 17 the top says you wt see and I'm 18 directing your attention down towar s the 19 middle to the bottom where you will see the 20 numbers 21 A. Uh-huh. 22 Q. And we've got actually I'm going to 23 direct your attention to the one that starts 24 with¶

1 G Maxwell - Confidential 2 and in the line, the remarks line you will 3 see JE. GM. 5 re you reading the 6 29th, is that what you're reading? 7 MS. McCAWLEY: I'm reading the 8 29th, yes. 9 . Below that ou will see JE. GM 12 you see that? 13 A. I do. 14 Q. Do you recall a trip from Teterboro 15 to Santa Fe and Santa Fe back to Palm Beach 16 with these individuals? 17 A. I don't. 18 19 . Do ou recall bein on a lane with and 20 on t. 21 Q. Do you recall ever witnessing any 22 sexual interaction on one of Jeffrey's planes 23 with any of these individuals? 24 A. I do not, absolutely not. 25 Q. Did Jeffrey have a fold out bed on¶

<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, █ 18 looks like it's one of the -- probably one of 19 the designers and the time would meet with a 20 trip to decorate the house, just the timing 21 of it. 22 Q. So would Virginia be brought on 23 trips that were for the purpose of work and 24 decorating the house? 25 A. Like I said, I never worked with</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 █ number █ and it 22 has different █ numbers because it's a 23 smaller version of the larger production. 24 These are the pages I will be asking about. 25 In the time that you were working</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 █, 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 █ ranges and I 19 don't see any of your █ ranges on 20 these. I know you have produced message 21 pads but those have your █ range 22 numbers on them and I'm wondering if 23 these are different documents. 24 MS. McCAWLEY: It's the same, just 25 ours have the █ underneath them.</p>

Page 146 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, █
18 looks like it's one of the -- probably one of
19 the designers and the time would meet with a
20 trip to decorate the house, just the timing
21 of it.
22 Q. So would Virginia be brought on
23 trips that were for the purpose of work and
24 decorating the house?
25 A. Like I said, I never worked with

Page 148 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 █ number █ and it
22 has different █ numbers because it's a
23 smaller version of the larger production.
24 These are the pages I will be asking about.
25 In the time that you were working

Page 147 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 █, 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

Page 149 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 █ ranges and I
19 don't see any of your █ ranges on
20 these. I know you have produced message
21 pads but those have your █ range
22 numbers on them and I'm wondering if
23 these are different documents.
24 MS. McCAWLEY: It's the same, just
25 ours have the █ underneath them.

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 [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 [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 [REDACTED], message [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 [REDACTED] is?
13 A. No, I don't.
14 Q. Do you know whether [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 [REDACTED] 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 [REDACTED] 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 [REDACTED] 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 [REDACTED] 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 of [REDACTED]
10 ever tell you that [REDACTED] 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¶

Page 162 Page 164 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 im ssible. 9 Q. Can you turn to, it 10 should be the next page. 11 A. Uh-huh. 12 Q. Do you see at the top, it says, for 13 Mr. J. 11/8/04 and then the name is 14 redacted. It says, I have a female for him. 15 Why would a minor be calling 16 Jeffrey to say they have a female for him' 17 Do you know? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. First of all.1 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¶

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 Jeffery adults over the age of 18 to come for 24 massages? 25 A. I didn't regularly do that, no.¶

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

Page 165 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 goin to direct our attention 11 to the next page. If you look at 12 the bottom left, you are going to see a 13 message for Jeffrey, from 14 says she doesn't have a number and lett a 15 message that she called. 16 Do you know who 17 A. I do not. 18 Q. DO you know that 19 13 at the time she placed this call to 20 Jeffrey? 21 A. I don't know who is. 22 Q. Would Jeffrey regularly have 1 23 year olds call and leave messages? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. it is? was¶

<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 [REDACTED] 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 [REDACTED]</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>

Page 166 1 G Maxwell - Confidential 2 A. How would I possibly, these were 3 messages taken when I was not at the house 4 and I have no idea who they are nor how old 5 they are nor anything. 6 Q. How do you know you weren't at the 7 house on this day? 8 A. I was hardly at the house in 2005. 9 Q. So you could have been there, you 10 just don't know? 11 A. In the five days I might have been 12 there in 2005, I suppose it's possible but 13 it's unlikely. 14 MR. PAGLIUCA: Do you know why this 15 isn't redacted if you are representing 16 all the names of people who are underage 17 have been redacted from these records. 18 MS. McCAWLEY: I think it was -- my 19 assumption is it was a miss by the 20 police department. 21 Q. I will direct your attention to [REDACTED] 22 [REDACTED] so you will skip a page and go back, 23 it's the final page in the message pads and 24 you will see on the top left for Jeffrey, on 25 6/1/2005 from [REDACTED] with a phone

Page 168 1 G Maxwell - Confidential 2 off the record. 3 (Recess.) 4 A F T E R N O O N S E S S I O N 5 (Time noted: 1:21 p.m.) 6 G H I S L A I N E M A X W E L L, 7 resumed and testified as follows: 8 EXAMINATION BY (Cont'd.) 9 MS. McCAWLEY: 10 THE VIDEOGRAPHER: It's now 1:21, 11 we're starting disk No. 4. We are back 12 on the record. 13 Q. Ms. Maxwell, before the break, we 14 were talking about and I think it's one of 15 the exhibits that's marked in front of you, 16 I'm not sure of the number, but the police 17 report that I showed you earlier today. 18 Now that you have knowledge of the 19 police report and the criminal investigation 20 with respect to Jeffrey Epstein, do you 21 believe that Jeffrey Epstein abused any minor 22 children? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Can you repeat the question please

Page 167 1 G Maxwell - Confidential 2 number. It says, quote, He has a teacher for 3 you to teach you how to speak Russian. She 4 is two times eight years old. Not blond. 5 Lessons are free and you can have your first 6 today if you call. 7 Do you know whether [REDACTED] 8 sent a Russian girl that was 16 years old 9 over to Jeffrey Epstein's home? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I do not know. 13 Q. Did you ever observe a Russian girl 14 that was 16 years old come to Jeffrey 15 Epstein's home? 16 A. I am not aware of any 16 year old 17 Russian girl that I can recall in Jeffrey 18 Epstein's home. 19 Q. Do you know whether Jeffrey Epstein 20 had sex with a 16 year old Russian girl? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I do not know. 24 THE VIDEOGRAPHER: It's 12:25. 25 This will be the end of disk 3, we are

Page 169 1 G Maxwell - Confidential 2 and break it down so it's more 3 understandable. 4 Q. Now that you have the police report 5 that I showed you this morning that you had 6 an opportunity to look at. 7 A. You gave it to me, I did not look 8 at it. 9 Q. The questions that I asked you 10 about the police report -- you are aware 11 there is a police report? 12 A. I am aware there is a police 13 report. 14 Q. You are aware there was a criminal 15 investigation of Jeffrey Epstein? 16 A. I am aware that there was that. 17 Q. Now that you are aware of those two 18 things and having talked to Jeffrey Epstein, 19 do you believe Jeffrey Epstein sexually 20 abused minors? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. Can you reask the second part of 24 that question please. 25 Q. Sure. The two documents we were

<p>Page 170</p> <p>1 G Maxwell - Confidential 2 talking about, the document and the 3 investigation, you said you are aware of and 4 after having talked to Jeffrey Epstein, do 5 you believe Jeffrey Epstein sexually abused 6 minors? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. What do you mean I talked to 10 Jeffrey, you need to break the question down 11 further. 12 Q. So you have the police report. 13 A. I do. 14 Q. And you are aware of the criminal 15 investigation? 16 A. I am. 17 Q. Let's take those two things. After 18 knowing those two things, do you believe that 19 Jeffrey Epstein abused minor children? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Can you explain what you mean by 23 the question actually. 24 Q. I think the question speaks for 25 itself. I will try again. I will say it one</p>	<p>Page 172</p> <p>1 G Maxwell - Confidential 2 sentenced for sexual abuse, are you aware of 3 that? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 Q. Are you aware that Jeffrey Epstein 7 served time for sexual abuse of a minor? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I don't believe that's what he was 11 sentenced for, actually. 12 Q. So you don't know that Jeffrey 13 Epstein served time for sexually abusing a 14 minor? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I don't believe that's what he was 18 sentenced for. 19 Q. Do you know that Jeffrey Epstein 20 was convicted for procuring a minor for 21 prostitution? 22 MR. PAGLIUCA: Objection to the 23 form and foundation. 24 A. I don't know exactly what he was 25 convicted of. I don't know that he was</p>
<p>Page 171</p> <p>1 G Maxwell - Confidential 2 more time because I want you to be able to 3 understand it. 4 Knowing that you have the police 5 report here and knowing about the criminal 6 investigation, do you believe that Jeffrey 7 Epstein sexually abused minors? 8 MR. PAGLIUCA: Same objection. 9 A. I know what you put in front of me 10 and I know what I read. 11 Q. I'm asking what you believe, do you 12 believe Jeffrey Epstein sexually abused 13 minors? 14 A. I can only tell you what I read and 15 what you showed me. 16 Q. I'm asking what you believe, from 17 your own belief, do you believe that Jeffrey 18 Epstein abused minors? 19 A. I can only go from what I know 20 personally and what I know personally about 21 what Virginia's lies talked about. She is 22 the only person I know that actually claimed 23 that. And I can say with certitude that 24 everything Virginia said was a lie. 25 Q. You are aware Jeffrey Epstein was</p>	<p>Page 173</p> <p>1 G Maxwell - Confidential 2 convicted. I know he spent time in jail. 3 Q. Do you know that he spent time in 4 jail related to an issue with a minor child? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. I did not know that. 8 Q. What did you think he was spending 9 time in jail for? 10 A. I only know he went to jail for -- 11 it was alleged that he hired -- had an 12 underage prostitute. 13 Q. So knowing that, do you believe 14 that Jeffrey Epstein sexually abused minors? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I can only tell you what he went to 18 jail for. 19 Q. I'm asking what you believe. I'm 20 not asking what he went to jail for. I'm 21 asking for your belief. 22 A. I cannot testify to what I believe. 23 I can only say what I have seen in the 24 reports and I know he went to jail. 25 Q. You can testify to what you</p>

Page 170 1 G Maxwell - Confidential
2 talking about, the document and the
3 investigation, you said you are aware of and
4 after having talked to Jeffrey Epstein, do
5 you believe Jeffrey Epstein sexually abused
6 minors?
7 MR. PAGLIUCA: Objection to the
8 form and foundation.
9 A. What do you mean I talked to
10 Jeffrey, you need to break the question down
11 further.
12 Q. So you have the police report.
13 A. I do.
14 Q. And you are aware of the criminal
15 investigation?
16 A. I am.
17 Q. Let's take those two things. After
18 knowing those two things, do you believe that
19 Jeffrey Epstein abused minor children?
20 MR. PAGLIUCA: Objection to the
21 form and foundation.
22 A. Can you explain what you mean by
23 the question actually.
24 Q. I think the question speaks for
25 itself. I will try again. I will say it one

Page 172 1 G Maxwell - Confidential
2 sentenced for sexual abuse, are you aware of
3 that?
4 MR. PAGLIUCA: Objection to the
5 form and foundation.
6 Q. Are you aware that Jeffrey Epstein
7 served time for sexual abuse of a minor?
8 MR. PAGLIUCA: Objection to the
9 form and foundation.
10 A. I don't believe that's what he was
11 sentenced for, actually.
12 Q. So you don't know that Jeffrey
13 Epstein served time for sexually abusing a
14 minor?
15 MR. PAGLIUCA: Objection to the
16 form and foundation.
17 A. I don't believe that's what he was
18 sentenced for.
19 Q. Do you know that Jeffrey Epstein
20 was convicted for procuring a minor for
21 prostitution?
22 MR. PAGLIUCA: Objection to the
23 form and foundation.
24 A. I don't know exactly what he was
25 convicted of. I don't know that he was

Page 171 1 G Maxwell - Confidential
2 more time because I want you to be able to
3 understand it.
4 Knowing that you have the police
5 report here and knowing about the criminal
6 investigation, do you believe that Jeffrey
7 Epstein sexually abused minors?
8 MR. PAGLIUCA: Same objection.
9 A. I know what you put in front of me
10 and I know what I read.
11 Q. I'm asking what you believe, do you
12 believe Jeffrey Epstein sexually abused
13 minors?
14 A. I can only tell you what I read and
15 what you showed me.
16 Q. I'm asking what you believe, from
17 your own belief, do you believe that Jeffrey
18 Epstein abused minors?
19 A. I can only go from what I know
20 personally and what I know personally about
21 what Virginia's lies talked about. She is
22 the only person I know that actually claimed
23 that. And I can say with certitude that
24 everything Virginia said was a lie.
25 Q. You are aware Jeffrey Epstein was

Page 173 1 G Maxwell - Confidential
2 convicted. I know he spent time in jail.
3 Q. Do you know that he spent time in
4 jail related to an issue with a minor child?
5 MR. PAGLIUCA: Objection to the
6 form and foundation.
7 A. I did not know that.
8 Q. What did you think he was spending
9 time in jail for?
10 A. I only know he went to jail for --
11 it was alleged that he hired -- had an
12 underage prostitute.
13 Q. So knowing that, do you believe
14 that Jeffrey Epstein sexually abused minors?
15 MR. PAGLIUCA: Objection to the
16 form and foundation.
17 A. I can only tell you what he went to
18 jail for.
19 Q. I'm asking what you believe. I'm
20 not asking what he went to jail for. I'm
21 asking for your belief.
22 A. I cannot testify to what I believe.
23 I can only say what I have seen in the
24 reports and I know he went to jail.
25 Q. You can testify to what you

<p>Page 174</p> <p>1 G Maxwell - Confidential 2 believe. Do you believe -- 3 A. I can only testify -- 4 Q. Let me finish the question so the 5 record is clear. 6 Do you believe Jeffrey Epstein 7 sexually abused minors? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 Q. You can answer. 11 A. I can only testify to what I know. 12 I know that Virginia is a liar and I know 13 what she testified is a lie. So I can only 14 testify to what I know to be a falsehood and 15 half those falsehoods are enormous and so I 16 can only categorically deny everything she 17 has said and that is the only thing I can 18 talk about because I have no knowledge of 19 anything else. 20 Q. I'm not asking about Virginia. I'm 21 asking whether you believe that Jeffrey 22 Epstein sexually abused minors? 23 A. Again, I repeat, I can only go on 24 what I know and what I know is a falsehood 25 based on what Virginia said.</p>	<p>Page 176</p> <p>1 G Maxwell - Confidential 2 Q. Do you believe Jeffrey Epstein 3 sexually abused minors? 4 A. Again, I repeat, the only person I 5 know who has talked about these things that I 6 have personal -- was personally present, was 7 Virginia and I can only talk to Virginia and 8 she is a liar. 9 Q. Setting aside Virginia. Take her 10 out of the picture. It's my question. 11 A. We are here today because of 12 Virginia and her lies because this is a 13 defamation suit. 14 Q. Setting aside Virginia, do you 15 believe Jeffrey Epstein sexually abused 16 minors? 17 A. I cannot set aside Virginia because 18 that's why we are here and this is the only 19 reason I am sitting here in this room and I 20 will not set her aside and I cannot comment 21 about anything else except her because she is 22 the only person I actually know about. 23 Q. Are you refusing to answer that 24 question? 25 A. I am not refusing the question. I</p>
<p>Page 175</p> <p>1 G Maxwell - Confidential 2 Q. Do you believe Jeffrey Epstein 3 sexually abused minors? 4 A. Again, I repeat, Virginia is a liar 5 and based on Virginia's stories, that is 6 what -- she lied and I can only then talk 7 about what you've showed me in the police 8 reports and I know he went to jail. 9 Q. Do you believe that Jeffrey Epstein 10 sexually abused minors? I'm asking about 11 your belief. 12 A. Again, I just repeat, I can only 13 go -- my belief is Virginia is a liar. 14 Q. What is that belief? 15 A. She is an absolute liar and 16 everything she said is a lie and therefore, 17 everything that stems from that is a lie. 18 Q. So do you believe that Jeffrey 19 Epstein sexually abused minors? 20 A. Again -- can we move on from here? 21 Q. No. You are going to answer the 22 question. 23 A. I have already. 24 Q. No, you haven't. 25 A. I have.</p>	<p>Page 177</p> <p>1 G Maxwell - Confidential 2 can only testify about Virginia who is an 3 absolute total liar and you all know she is. 4 She lied about her age, you know she lied 5 about absolutely everything. So I can only 6 go on what I know as a liar and she is a 7 liar, an exaggerator, a fantasist and 8 absolutely true terrible person. 9 Q. I want you to listen very 10 carefully. I am asking you to set aside 11 Virginia. 12 A. I can't set aside Virginia. 13 Q. I am asking you to do that for 14 purposes of this question. 15 MR. PAGLIUCA: She doesn't have to. 16 MS. MCCAWLEY: She can refuse to 17 answer the question. 18 A. I'm not refusing to answer the 19 question. 20 Q. You are refusing. 21 My question has nothing to do with 22 Virginia. Let me make the record here. My 23 question has nothing to do with Virginia. I 24 want it to be clear for the court. My 25 question has nothing to do with Virginia.</p>

Page 174 1 G Maxwell - Confidential
2 believe. Do you believe --
3 A. I can only testify --
4 Q. Let me finish the question so the
5 record is clear.
6 Do you believe Jeffrey Epstein
7 sexually abused minors?
8 MR. PAGLIUCA: Objection to the
9 form and foundation.
10 Q. You can answer.
11 A. I can only testify to what I know.
12 I know that Virginia is a liar and I know
13 what she testified is a lie. So I can only
14 testify to what I know to be a falsehood and
15 half those falsehoods are enormous and so I
16 can only categorically deny everything she
17 has said and that is the only thing I can
18 talk about because I have no knowledge of
19 anything else.
20 Q. I'm not asking about Virginia. I'm
21 asking whether you believe that Jeffrey
22 Epstein sexually abused minors?
23 A. Again, I repeat, I can only go on
24 what I know and what I know is a falsehood
25 based on what Virginia said.

Page 176 1 G Maxwell - Confidential
2 Q. Do you believe Jeffrey Epstein
3 sexually abused minors?
4 A. Again, I repeat, the only person I
5 know who has talked about these things that I
6 have personal -- was personally present, was
7 Virginia and I can only talk to Virginia and
8 she is a liar.
9 Q. Setting aside Virginia. Take her
10 out of the picture. It's my question.
11 A. We are here today because of
12 Virginia and her lies because this is a
13 defamation suit.
14 Q. Setting aside Virginia, do you
15 believe Jeffrey Epstein sexually abused
16 minors?
17 A. I cannot set aside Virginia because
18 that's why we are here and this is the only
19 reason I am sitting here in this room and I
20 will not set her aside and I cannot comment
21 about anything else except her because she is
22 the only person I actually know about.
23 Q. Are you refusing to answer that
24 question?
25 A. I am not refusing the question. I

Page 175 1 G Maxwell - Confidential
2 Q. Do you believe Jeffrey Epstein
3 sexually abused minors?
4 A. Again, I repeat, Virginia is a liar
5 and based on Virginia's stories, that is
6 what -- she lied and I can only then talk
7 about what you've showed me in the police
8 reports and I know he went to jail.
9 Q. Do you believe that Jeffrey Epstein
10 sexually abused minors? I'm asking about
11 your belief.
12 A. Again, I just repeat, I can only
13 go -- my belief is Virginia is a liar.
14 Q. What is that belief?
15 A. She is an absolute liar and
16 everything she said is a lie and therefore,
17 everything that stems from that is a lie.
18 Q. So do you believe that Jeffrey
19 Epstein sexually abused minors?
20 A. Again -- can we move on from here?
21 Q. No. You are going to answer the
22 question.
23 A. I have already.
24 Q. No, you haven't.
25 A. I have.

Page 177 1 G Maxwell - Confidential
2 can only testify about Virginia who is an
3 absolute total liar and you all know she is.
4 She lied about her age, you know she lied
5 about absolutely everything. So I can only
6 go on what I know as a liar and she is a
7 liar, an exaggerator, a fantasist and
8 absolutely true terrible person.
9 Q. I want you to listen very
10 carefully. I am asking you to set aside
11 Virginia.
12 A. I can't set aside Virginia.
13 Q. I am asking you to do that for
14 purposes of this question.
15 MR. PAGLIUCA: She doesn't have to.
16 MS. MCCAWLEY: She can refuse to
17 answer the question.
18 A. I'm not refusing to answer the
19 question.
20 Q. You are refusing.
21 My question has nothing to do with
22 Virginia. Let me make the record here. My
23 question has nothing to do with Virginia. I
24 want it to be clear for the court. My
25 question has nothing to do with Virginia.

<p>Page 178</p> <p>1 G Maxwell - Confidential</p> <p>2 What I'm asking you is whether you</p> <p>3 believe Jeffrey Epstein abused minors?</p> <p>4 MR. PAGLIUCA: I object to the form</p> <p>5 and you made your record, she answered</p> <p>6 the question. A fair reading of her</p> <p>7 answer is she doesn't have a belief</p> <p>8 because she doesn't have any personal</p> <p>9 knowledge.</p> <p>10 MS. MCCAWLEY: Now you are</p> <p>11 testifying for the witness. Let her</p> <p>12 answer the question.</p> <p>13 MR. PAGLIUCA: It's a fair answer</p> <p>14 to the question.</p> <p>15 A. Again, I testified my only personal</p> <p>16 knowledge concerns Virginia and everything</p> <p>17 Virginia has said is an absolute lie, which</p> <p>18 is why we are here in this room. If you are</p> <p>19 asking me to testify about things I have no</p> <p>20 knowledge of other than the police report</p> <p>21 that you showed me, I am not in a position to</p> <p>22 make a statement based on that because you</p> <p>23 are asking me to speculate and I cannot</p> <p>24 speculate.</p> <p>25 Q. I'm asking you about your belief.</p>	<p>Page 180</p> <p>1 G Maxwell - Confidential</p> <p>2 said is a lie. Therefore, based on those</p> <p>3 lies I cannot speculate on what anybody else</p> <p>4 did or didn't do because if Virginia is the</p> <p>5 example of what that story is and everything</p> <p>6 she said is false, so everything that leads</p> <p>7 from that is false.</p> <p>8 Q. So the 30 other minor children in</p> <p>9 the police report are also telling lies about</p> <p>10 being sexually abused during massages with</p> <p>11 Mr. Epstein?</p> <p>12 MR. PAGLIUCA: Objection to the</p> <p>13 form and foundation. Counsel, can you</p> <p>14 show me in these police reports who the</p> <p>15 30 minors are?</p> <p>16 MS. MCCAWLEY: I'm asking my</p> <p>17 question.</p> <p>18 MR. PAGLIUCA: You are making a</p> <p>19 representation about numbers, you are</p> <p>20 making a representation on the record</p> <p>21 about what people said or didn't say.</p> <p>22 We have no knowledge about that. These</p> <p>23 are all redacted records so these are</p> <p>24 bad questions. They don't lead to any</p> <p>25 admissible evidence. It is only being</p>
<p>Page 179</p> <p>1 G Maxwell - Confidential</p> <p>2 I'm not asking you to speculate at all. I'm</p> <p>3 asking what you believe.</p> <p>4 A. You are asking me to speculate and</p> <p>5 I won't speculate.</p> <p>6 Q. I'm not asking you to speculate.</p> <p>7 I'm asking what you believe.</p> <p>8 MR. PAGLIUCA: She answered the</p> <p>9 question and we can move on.</p> <p>10 MS. MCCAWLEY: She hasn't answered</p> <p>11 the question.</p> <p>12 MR. PAGLIUCA: We are not going to</p> <p>13 engage in this debate. She answered the</p> <p>14 question. If you want to mark it and</p> <p>15 move to compel an answer to the</p> <p>16 question, have at it. Okay.</p> <p>17 Q. Ms. Maxwell, is it your belief that</p> <p>18 Jeffrey Epstein interacted sexually with</p> <p>19 minors?</p> <p>20 A. Again, you are asking me the same</p> <p>21 type of question exactly but with different</p> <p>22 language. Again, my only knowledge of</p> <p>23 somebody who claims these things that I have</p> <p>24 personal knowledge of is Virginia. Virginia</p> <p>25 is an absolute liar and everything she has</p>	<p>Page 181</p> <p>1 G Maxwell - Confidential</p> <p>2 propounded to the witness to harass her.</p> <p>3 So we are done with these questions.</p> <p>4 MS. MCCAWLEY: Are you done?</p> <p>5 MR. PAGLIUCA: Yes.</p> <p>6 Q. My question is, are you aware that</p> <p>7 Jeffrey Epstein was convicted of having</p> <p>8 relations with a minor child?</p> <p>9 MR. PAGLIUCA: She answered that</p> <p>10 question already.</p> <p>11 MS. MCCAWLEY: I'm getting to my</p> <p>12 next question.</p> <p>13 MR. PAGLIUCA: Ask your next</p> <p>14 question. Don't keep asking the same</p> <p>15 question.</p> <p>16 MS. MCCAWLEY: You are now</p> <p>17 shouting, I want the record to reflect</p> <p>18 that you are interrupting the</p> <p>19 deposition. I ask you to calm down,</p> <p>20 take a deep breath and please let me ask</p> <p>21 my questions.</p> <p>22 MR. PAGLIUCA: Your behavior is</p> <p>23 inappropriate.</p> <p>24 Q. I will ask you again.</p> <p>25 Do you believe that Jeffrey Epstein</p>

Page 178 1 G Maxwell - Confidential 2 What I'm asking you is whether you 3 believe Jeffrey Epstein abused minors? 4 MR. PAGLIUCA: I object to the form 5 and you made your record, she answered 6 the question. A fair reading of her 7 answer is she doesn't have a belief 8 because she doesn't have any personal 9 knowledge. 10 MS. MCCAWLEY: Now you are 11 testifying for the witness. Let her 12 answer the question. 13 MR. PAGLIUCA: It's a fair answer 14 to the question. 15 A. Again, I testified my only personal 16 knowledge concerns Virginia and everything 17 Virginia has said is an absolute lie, which 18 is why we are here in this room. If you are 19 asking me to testify about things I have no 20 knowledge of other than the police report 21 that you showed me, I am not in a position to 22 make a statement based on that because you 23 are asking me to speculate and I cannot 24 speculate. 25 Q. I'm asking you about your belief.

Page 180 1 G Maxwell - Confidential 2 said is a lie. Therefore, based on those 3 lies I cannot speculate on what anybody else 4 did or didn't do because if Virginia is the 5 example of what that story is and everything 6 she said is false, so everything that leads 7 from that is false. 8 Q. So the 30 other minor children in 9 the police report are also telling lies about 10 being sexually abused during massages with 11 Mr. Epstein? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. Counsel, can you 14 show me in these police reports who the 15 30 minors are? 16 MS. MCCAWLEY: I'm asking my 17 question. 18 MR. PAGLIUCA: You are making a 19 representation about numbers, you are 20 making a representation on the record 21 about what people said or didn't say. 22 We have no knowledge about that. These 23 are all redacted records so these are 24 bad questions. They don't lead to any 25 admissible evidence. It is only being

Page 179 1 G Maxwell - Confidential 2 I'm not asking you to speculate at all. I'm 3 asking what you believe. 4 A. You are asking me to speculate and 5 I won't speculate. 6 Q. I'm not asking you to speculate. 7 I'm asking what you believe. 8 MR. PAGLIUCA: She answered the 9 question and we can move on. 10 MS. MCCAWLEY: She hasn't answered 11 the question. 12 MR. PAGLIUCA: We are not going to 13 engage in this debate. She answered the 14 question. If you want to mark it and 15 move to compel an answer to the 16 question, have at it. Okay. 17 Q. Ms. Maxwell, is it your belief that 18 Jeffrey Epstein interacted sexually with 19 minors? 20 A. Again, you are asking me the same 21 type of question exactly but with different 22 language. Again, my only knowledge of 23 somebody who claims these things that I have 24 personal knowledge of is Virginia. Virginia 25 is an absolute liar and everything she has

Page 181 1 G Maxwell - Confidential 2 propounded to the witness to harass her. 3 So we are done with these questions. 4 MS. MCCAWLEY: Are you done? 5 MR. PAGLIUCA: Yes. 6 Q. My question is, are you aware that 7 Jeffrey Epstein was convicted of having 8 relations with a minor child? 9 MR. PAGLIUCA: She answered that 10 question already. 11 MS. MCCAWLEY: I'm getting to my 12 next question. 13 MR. PAGLIUCA: Ask your next 14 question. Don't keep asking the same 15 question. 16 MS. MCCAWLEY: You are now 17 shouting, I want the record to reflect 18 that you are interrupting the 19 deposition. I ask you to calm down, 20 take a deep breath and please let me ask 21 my questions. 22 MR. PAGLIUCA: Your behavior is 23 inappropriate. 24 Q. I will ask you again. 25 Do you believe that Jeffrey Epstein

<p>Page 182</p> <p>1 G Maxwell - Confidential 2 interacted sexually with minors? 3 A. Again, I go back to this, my only 4 actual knowledge is with Virginia and 5 Virginia is a liar, so I can only talk to 6 what Virginia's story and as I said before 7 and there are so many examples, I mean 8 thousands of examples of her lies, that that 9 is the only thing I can talk to. 10 Q. Based on that you do not believe 11 that Jeffrey Epstein sexually abused minors? 12 A. Again, as I said, I'm only talking 13 to what I know, I can only talk to Virginia. 14 Q. So is it your belief that Jeffrey 15 Epstein did not sexually abuse minors? 16 A. Again, I can only talk to what I 17 know and I know that Virginia is a liar and 18 that what she said is a lie. So I can only 19 testify to what she accused and you guys put 20 in the press for salacious purposes and 21 whatever terrible, inappropriate, unethical 22 and terrible reasons you chose to do that 23 about me and I can testify those are all 24 lies. 25 Q. Do you know whether Jeffrey Epstein</p>	<p>Page 184</p> <p>1 G Maxwell - Confidential 2 is a registered sex offender? 3 A. I am. 4 Q. Are you aware that Jeffrey Epstein 5 paid considerable amounts of money to settle 6 lawsuits with the minor children that he had 7 sexual contact with? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. I have no knowledge of those 11 issues. 12 Q. Why did you continue to maintain 13 contact with Jeffrey Epstein after he pled 14 guilty? 15 A. I'm a very loyal person and Jeffrey 16 was very good to me when my father passed 17 away and I believe that you need to be a good 18 friend in people's hour of need and I felt 19 that it was a very thoughtful, nice thing for 20 me to do to help in very limited fashion 21 which was helping if he had any issue with 22 his homes, in terms of the staffing issues. 23 It was very, very minor but I felt it was 24 thoughtful in somebody's hour of need. 25 Q. Did he continue to pay you during</p>
<p>Page 183</p> <p>1 G Maxwell - Confidential 2 sexually abused any minor children? 3 A. Again, I only know 1000 percent 4 that Virginia is a liar. I can only talk to 5 Virginia, her lies and your inappropriate, 6 unethical, really unattractive, terrible use 7 of her and the way that you have abused the 8 system, used the press for purposes that are 9 unethical, inappropriate and appalling. 10 Q. Do you believe that Jeffrey Epstein 11 used massages to lure minors to have sex with 12 him? 13 A. Again, that is Virginia's 14 testimony, which is a lie. 15 Q. But do you believe that? 16 A. Again, I refer back to Virginia. 17 Q. I'm asking whether you believe it 18 or not? 19 A. I can only go with what I know and 20 I know Virginia is a liar and therefore 21 that's a lie. 22 Q. So you don't believe that? 23 A. I said, I only know that Virginia 24 is lying. 25 Q. Are you aware that Jeffrey Epstein</p>	<p>Page 185</p> <p>1 G Maxwell - Confidential 2 that time period? 3 A. I was paid a little. 4 Q. You were paid? 5 A. Yes. 6 Q. When you say a little, what you did 7 mean by that? 8 A. I don't recall exactly the amount. 9 Q. So in 2009 when you left him, what 10 were you being paid? 11 A. I just told you, I don't recall. 12 Q. Were you being paid $100,000? 13 A. I just don't you I don't recall. 14 Q. Were you paid over a million 15 dollars? 16 A. I think I would remember over a 17 million dollars. 18 Q. So it was under a million dollars? 19 A. It was under a million dollars. 20 Q. Was it over $500,000? 21 A. I just told you, it was under 500, 22 it was an amount of money less than $500,000, 23 less than a million dollars and I did it out 24 of thoughtfulness and consideration for 25 somebody who was in trouble.</p>

Page 182 1 G Maxwell - Confidential
2 interacted sexually with minors?
3 A. Again, I go back to this, my only
4 actual knowledge is with Virginia and
5 Virginia is a liar, so I can only talk to
6 what Virginia's story and as I said before
7 and there are so many examples, I mean
8 thousands of examples of her lies, that that
9 is the only thing I can talk to.
10 Q. Based on that you do not believe
11 that Jeffrey Epstein sexually abused minors?
12 A. Again, as I said, I'm only talking
13 to what I know, I can only talk to Virginia.
14 Q. So is it your belief that Jeffrey
15 Epstein did not sexually abuse minors?
16 A. Again, I can only talk to what I
17 know and I know that Virginia is a liar and
18 that what she said is a lie. So I can only
19 testify to what she accused and you guys put
20 in the press for salacious purposes and
21 whatever terrible, inappropriate, unethical
22 and terrible reasons you chose to do that
23 about me and I can testify those are all
24 lies.
25 Q. Do you know whether Jeffrey Epstein

Page 184 1 G Maxwell - Confidential
2 is a registered sex offender?
3 A. I am.
4 Q. Are you aware that Jeffrey Epstein
5 paid considerable amounts of money to settle
6 lawsuits with the minor children that he had
7 sexual contact with?
8 MR. PAGLIUCA: Objection to the
9 form and foundation.
10 A. I have no knowledge of those
11 issues.
12 Q. Why did you continue to maintain
13 contact with Jeffrey Epstein after he pled
14 guilty?
15 A. I'm a very loyal person and Jeffrey
16 was very good to me when my father passed
17 away and I believe that you need to be a good
18 friend in people's hour of need and I felt
19 that it was a very thoughtful, nice thing for
20 me to do to help in very limited fashion
21 which was helping if he had any issue with
22 his homes, in terms of the staffing issues.
23 It was very, very minor but I felt it was
24 thoughtful in somebody's hour of need.
25 Q. Did he continue to pay you during

Page 183 1 G Maxwell - Confidential
2 sexually abused any minor children?
3 A. Again, I only know 1000 percent
4 that Virginia is a liar. I can only talk to
5 Virginia, her lies and your inappropriate,
6 unethical, really unattractive, terrible use
7 of her and the way that you have abused the
8 system, used the press for purposes that are
9 unethical, inappropriate and appalling.
10 Q. Do you believe that Jeffrey Epstein
11 used massages to lure minors to have sex with
12 him?
13 A. Again, that is Virginia's
14 testimony, which is a lie.
15 Q. But do you believe that?
16 A. Again, I refer back to Virginia.
17 Q. I'm asking whether you believe it
18 or not?
19 A. I can only go with what I know and
20 I know Virginia is a liar and therefore
21 that's a lie.
22 Q. So you don't believe that?
23 A. I said, I only know that Virginia
24 is lying.
25 Q. Are you aware that Jeffrey Epstein

Page 185 1 G Maxwell - Confidential
2 that time period?
3 A. I was paid a little.
4 Q. You were paid?
5 A. Yes.
6 Q. When you say a little, what you did
7 mean by that?
8 A. I don't recall exactly the amount.
9 Q. So in 2009 when you left him, what
10 were you being paid?
11 A. I just told you, I don't recall.
12 Q. Were you being paid $100,000?
13 A. I just don't you I don't recall.
14 Q. Were you paid over a million
15 dollars?
16 A. I think I would remember over a
17 million dollars.
18 Q. So it was under a million dollars?
19 A. It was under a million dollars.
20 Q. Was it over $500,000?
21 A. I just told you, it was under 500,
22 it was an amount of money less than $500,000,
23 less than a million dollars and I did it out
24 of thoughtfulness and consideration for
25 somebody who was in trouble.

<p>Page 186</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. Did you have an attorney to consult</p> <p>3 with during the criminal investigation of</p> <p>4 Jeffrey Epstein?</p> <p>5 A. I don't believe I did.</p> <p>6 Q. When did you learn that a search</p> <p>7 warrant was executed for the Palm Beach</p> <p>8 house?</p> <p>9 A. I don't recall exactly.</p> <p>10 Q. Were you present at the house in</p> <p>11 advance of the search warrant being executed?</p> <p>12 MR. PAGLIUCA: Object to the form</p> <p>13 of the question.</p> <p>14 A. I don't remember when the search</p> <p>15 warrant was executed and I don't remember the</p> <p>16 year that the search warrant was executed and</p> <p>17 whenever that was, I already testified, I was</p> <p>18 very, very infrequently at the house. So</p> <p>19 highly unlikely but I was there a couple of</p> <p>20 days, I just don't know which days it was in</p> <p>21 relation to the police situation.</p> <p>22 Q. Did you have a computer at the Palm</p> <p>23 Beach home that was a computer that you would</p> <p>24 use?</p> <p>25 A. No.</p>	<p>Page 188</p> <p>1 G Maxwell - Confidential</p> <p>2 people could use -- just like you would use</p> <p>3 if you needed to go online to get something,</p> <p>4 that people could use.</p> <p>5 Q. Was that on a desk that you would</p> <p>6 use in your work capacity when you were at</p> <p>7 the house?</p> <p>8 A. It was a desk, it was a room I was,</p> <p>9 I didn't really use that computer.</p> <p>10 Q. Were there images of naked girls</p> <p>11 whether they be under the age of 18 or over</p> <p>12 the age of 18 on that computer?</p> <p>13 A. I have no recollection of any naked</p> <p>14 people on that computer when I was there in</p> <p>15 2003, we are talking.</p> <p>16 Q. What about from say '99 to 2003?</p> <p>17 A. No, I can't recollect any naked</p> <p>18 pictures.</p> <p>19 Q. Why were the computers removed from</p> <p>20 the house before the search warrant was</p> <p>21 executed?</p> <p>22 MR. PAGLIUCA: Objection to the</p> <p>23 form and foundation.</p> <p>24 A. I have no knowledge of anything</p> <p>25 like that.</p>
<p>Page 187</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. Was there a computer available for</p> <p>3 use in the Palm Beach house?</p> <p>4 A. Can you be more specific.</p> <p>5 Q. Was there anywhere in the Palm</p> <p>6 Beach house where there was a computer where</p> <p>7 you said you worked for him and there were</p> <p>8 other staff in the house, was there ever a</p> <p>9 computer in the Palm Beach mansion that was</p> <p>10 accessible by you or other staff?</p> <p>11 MR. PAGLIUCA: Objection to the</p> <p>12 form and foundation.</p> <p>13 A. I stopped being regularly at the</p> <p>14 house sometime in 2003 so from 2003 to when</p> <p>15 the police search was executed, I have no</p> <p>16 memory of what there was or what there was</p> <p>17 not. I can only testify for what was there</p> <p>18 when I was present largely.</p> <p>19 Q. So in 2003 when you were still</p> <p>20 there, was there a computer that was</p> <p>21 accessible to you or other staff at the</p> <p>22 house?</p> <p>23 MR. PAGLIUCA: Objection to the</p> <p>24 form and foundation.</p> <p>25 A. There was a desktop computer that</p>	<p>Page 189</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. Do you know where the computers are</p> <p>3 now?</p> <p>4 MR. PAGLIUCA: Objection to the</p> <p>5 form and foundation.</p> <p>6 A. I don't know what computers you are</p> <p>7 talking of and I have no idea what you are</p> <p>8 referencing.</p> <p>9 Q. In 2003 you said there was a</p> <p>10 computer in a room on a desk?</p> <p>11 A. Right.</p> <p>12 Q. Do you know where that computer is</p> <p>13 now?</p> <p>14 A. I do not.</p> <p>15 Q. Did you take pictures of nude</p> <p>16 females in any of Epstein's homes or in and</p> <p>17 around the homes, out by the pool or anywhere</p> <p>18 like, in the Palm Beach home, the New York</p> <p>19 home, USVI home or the New Mexico home?</p> <p>20 MR. PAGLIUCA: Objection to the</p> <p>21 form and foundation.</p> <p>22 A. Can you repeat the question.</p> <p>23 Q. Did you take pictures of nude woman</p> <p>24 over 18 or under 18, females, in any of</p> <p>25 Jeffrey Epstein's homes, inside or outside in</p>

Page 186 1 G Maxwell - Confidential 2 Q. Did you have an attorney to consult 3 with during the criminal investigation of 4 Jeffrey Epstein? 5 A. I don't believe I did. 6 Q. When did you learn that a search 7 warrant was executed for the Palm Beach 8 house? 9 A. I don't recall exactly. 10 Q. Were you present at the house in 11 advance of the search warrant being executed? 12 MR. PAGLIUCA: Object to the form 13 of the question. 14 A. I don't remember when the search 15 warrant was executed and I don't remember the 16 year that the search warrant was executed and 17 whenever that was, I already testified, I was 18 very, very infrequently at the house. So 19 highly unlikely but I was there a couple of 20 days, I just don't know which days it was in 21 relation to the police situation. 22 Q. Did you have a computer at the Palm 23 Beach home that was a computer that you would 24 use? 25 A. No.

Page 188 1 G Maxwell - Confidential 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.

Page 187 1 G Maxwell - Confidential 2 Q. Was there a computer available for 3 use in the Palm Beach house? 4 A. Can you be more specific. 5 Q. Was there anywhere in the Palm 6 Beach house where there was a computer where 7 you said you worked for him and there were 8 other staff in the house, was there ever a 9 computer in the Palm Beach mansion that was 10 accessible by you or other staff? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I stopped being regularly at the 14 house sometime in 2003 so from 2003 to when 15 the police search was executed, I have no 16 memory of what there was or what there was 17 not. I can only testify for what was there 18 when I was present largely. 19 Q. So in 2003 when you were still 20 there, was there a computer that was 21 accessible to you or other staff at the 22 house? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. There was a desktop computer that

Page 189 1 G Maxwell - Confidential 2 Q. Do you know where the computers are 3 now? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I don't know what computers you are 7 talking of and I have no idea what you are 8 referencing. 9 Q. In 2003 you said there was a 10 computer in a room on a desk? 11 A. Right. 12 Q. Do you know where that computer is 13 now? 14 A. I do not. 15 Q. Did you take pictures of nude 16 females in any of Epstein's homes or in and 17 around the homes, out by the pool or anywhere 18 like, in the Palm Beach home, the New York 19 home, USVI home or the New Mexico home? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. Can you repeat the question. 23 Q. Did you take pictures of nude woman 24 over 18 or under 18, females, in any of 25 Jeffrey Epstein's homes, inside or outside in

<p>Page 190</p> <p>1 G Maxwell - Confidential</p> <p>2 or around the home?</p> <p>3 A. I think we need to distinguish</p> <p>4 between anyone under the age of 18 and over</p> <p>5 the age of 18.</p> <p>6 Q. We will start with, did you take</p> <p>7 pictures of nude females in or around any of</p> <p>8 Jeffrey's homes of women or females that were</p> <p>9 under the age of 18?</p> <p>10 A. No.</p> <p>11 Q. Did you take pictures of nude</p> <p>12 females --</p> <p>13 A. Nude you mean with no clothing on.</p> <p>14 Q. Or half nude, with no top on, any</p> <p>15 sort of nakedness to an individual.</p> <p>16 In any of Jeffrey's homes, either</p> <p>17 Palm Beach, New Mexico, USVI or New York</p> <p>18 either outside by the pool, anywhere in or</p> <p>19 around those homes of females over the age of</p> <p>20 18?</p> <p>21 A. So it is possible that I took</p> <p>22 pictures of people that were somehow semi or</p> <p>23 had some clothing on or no clothes on but at</p> <p>24 no time were any of these pictures remotely</p> <p>25 inappropriate. They were, you could see them</p>	<p>Page 192</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. Not as a gift.</p> <p>3 Do you recall ever giving Jeffrey</p> <p>4 Epstein pictures that you've taken of these</p> <p>5 individuals in a naked state?</p> <p>6 MR. PAGLIUCA: Objection to the</p> <p>7 form and foundation.</p> <p>8 A. First of all, we've already</p> <p>9 established that they are not naked state</p> <p>10 photographs.</p> <p>11 Q. A piece of them being naked as you</p> <p>12 described.</p> <p>13 A. I said they would be attractive as</p> <p>14 you would see in mainstream magazines and</p> <p>15 those pictures could be a picture of a hand</p> <p>16 or a foot, they didn't necessarily</p> <p>17 constitute -- I know where you are headed</p> <p>18 with this and it's nowhere appropriate and</p> <p>19 it's really unattractive.</p> <p>20 Q. I'm not headed anywhere. I'm just</p> <p>21 asking the questions. Did you give Jeffrey</p> <p>22 Epstein any of these pictures that you took</p> <p>23 of females in the state that you described?</p> <p>24 A. I can't recall ever giving him</p> <p>25 pictures but it is possible that I took</p>
<p>Page 191</p> <p>1 G Maxwell - Confidential</p> <p>2 in a mainstream magazine today, there would</p> <p>3 be no inappropriateness, they would be</p> <p>4 covered, concealed, you wouldn't see anything</p> <p>5 at all.</p> <p>6 The types of -- first, I took very</p> <p>7 few and they were always by request, this was</p> <p>8 a picture you could put on your -- gift to</p> <p>9 your parent or to your grandparents to put on</p> <p>10 their mantel piece . It would be a very</p> <p>11 benign sort of attractive picture where you</p> <p>12 wouldn't see anything.</p> <p>13 Q. Who would request those pictures?</p> <p>14 A. From time to time, people, men and</p> <p>15 women would ask to have nice photographs of</p> <p>16 them taken.</p> <p>17 Q. And did Jeffrey Epstein request</p> <p>18 those pictures?</p> <p>19 A. I don't ever recall him asking me</p> <p>20 to take pictures.</p> <p>21 Q. Did you give him pictures of naked</p> <p>22 females as a present?</p> <p>23 A. I don't recall ever giving a</p> <p>24 present of -- I don't know why a photograph</p> <p>25 would constitute a gift.</p>	<p>Page 193</p> <p>1 G Maxwell - Confidential</p> <p>2 pictures of people that would end up -- or a</p> <p>3 friend of his that he would have -- not naked</p> <p>4 or not inappropriate in any way, that he</p> <p>5 might have somewhere in his house.</p> <p>6 Q. Name for me all the individuals who</p> <p>7 you took these pictures of?</p> <p>8 A. It's entirely impossible for me to</p> <p>9 name people. First of all, it was just -- it</p> <p>10 would not be possible, I took thousands of</p> <p>11 photos, not of people, I mostly take pictures</p> <p>12 of landscapes and things. I have no</p> <p>13 recollection specifically of people that I</p> <p>14 took pictures of.</p> <p>15 Q. So you can't remember, is it your</p> <p>16 testimony you can't remember one person that</p> <p>17 you took a picture of in either a naked or</p> <p>18 semi naked state?</p> <p>19 A. I seriously cannot recall. I just</p> <p>20 don't recall.</p> <p>21 Q. Did you take a picture of Virginia</p> <p>22 [REDACTED] either alone or with another</p> <p>23 individual in a naked state?</p> <p>24 A. I have never taken, I believe, any</p> <p>25 pictures of two people in any type of</p>

Page 190 1 G Maxwell - Confidential 2 or around the home? 3 A. I think we need to distinguish 4 between anyone under the age of 18 and over 5 the age of 18. 6 Q. We will start with, did you take 7 pictures of nude females in or around any of 8 Jeffrey's homes of women or females that were 9 under the age of 18? 10 A. No. 11 Q. Did you take pictures of nude 12 females -- 13 A. Nude you mean with no clothing on. 14 Q. Or half nude, with no top on, any 15 sort of nakedness to an individual. 16 In any of Jeffrey's homes, either 17 Palm Beach, New Mexico, USVI or New York 18 either outside by the pool, anywhere in or 19 around those homes of females over the age of 20 18? 21 A. So it is possible that I took 22 pictures of people that were somehow semi or 23 had some clothing on or no clothes on but at 24 no time were any of these pictures remotely 25 inappropriate. They were, you could see them

Page 192 1 G Maxwell - Confidential 2 Q. Not as a gift. 3 Do you recall ever giving Jeffrey 4 Epstein pictures that you've taken of these 5 individuals in a naked state? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. First of all, we've already 9 established that they are not naked state 10 photographs. 11 Q. A piece of them being naked as you 12 described. 13 A. I said they would be attractive as 14 you would see in mainstream magazines and 15 those pictures could be a picture of a hand 16 or a foot, they didn't necessarily 17 constitute -- I know where you are headed 18 with this and it's nowhere appropriate and 19 it's really unattractive. 20 Q. I'm not headed anywhere. I'm just 21 asking the questions. Did you give Jeffrey 22 Epstein any of these pictures that you took 23 of females in the state that you described? 24 A. I can't recall ever giving him 25 pictures but it is possible that I took

Page 191 1 G Maxwell - Confidential 2 in a mainstream magazine today, there would 3 be no inappropriateness, they would be 4 covered, concealed, you wouldn't see anything 5 at all. 6 The types of -- first, I took very 7 few and they were always by request, this was 8 a picture you could put on your -- gift to 9 your parent or to your grandparents to put on 10 their mantel piece . It would be a very 11 benign sort of attractive picture where you 12 wouldn't see anything. 13 Q. Who would request those pictures? 14 A. From time to time, people, men and 15 women would ask to have nice photographs of 16 them taken. 17 Q. And did Jeffrey Epstein request 18 those pictures? 19 A. I don't ever recall him asking me 20 to take pictures. 21 Q. Did you give him pictures of naked 22 females as a present? 23 A. I don't recall ever giving a 24 present of -- I don't know why a photograph 25 would constitute a gift.

Page 193 1 G Maxwell - Confidential 2 pictures of people that would end up -- or a 3 friend of his that he would have -- not naked 4 or not inappropriate in any way, that he 5 might have somewhere in his house. 6 Q. Name for me all the individuals who 7 you took these pictures of? 8 A. It's entirely impossible for me to 9 name people. First of all, it was just -- it 10 would not be possible, I took thousands of 11 photos, not of people, I mostly take pictures 12 of landscapes and things. I have no 13 recollection specifically of people that I 14 took pictures of. 15 Q. So you can't remember, is it your 16 testimony you can't remember one person that 17 you took a picture of in either a naked or 18 semi naked state? 19 A. I seriously cannot recall. I just 20 don't recall. 21 Q. Did you take a picture of Virginia 22 [REDACTED] either alone or with another 23 individual in a naked state? 24 A. I have never taken, I believe, any 25 pictures of two people in any type of

1 G Maxwell - Confidential
2 situation, naked as you describe.
3 Q. Did you take a picture of [REDACTED]
4 [REDACTED] on her own without another individual
5 in it in a naked state?
6 A. I don't recall ever taking a
7 picture of Virginia -- naked, we are not
8 referring to someone with no clothing on at
9 all, we are referring to someone that could
10 be semi clad or could have a towel or we are
11 not referring to anything inappropriate.
12 Q. Was this a hobby of yours to take
13 pictures of the type that you are describing?
14 MR. PAGLIUCA: Object to the form.
15 A. I just testified, I didn't take
16 pictures of many people. My preference is
17 pictures for landscapes and for architectural
18 pieces.
19 Q. Where are those pictures today?
20 A. I have no idea.
21 Q. Do you have them in your home?
22 A. I do not.
23 Q. Do you have them on your computer?
24 A. I do not.
25 Q. What has Jeffrey Epstein told you¶

1 G Maxwell - Confidential
2 about those things.
3 Q. What has Jeffrey Epstein told you
4 about [REDACTED]?
5 A. That she is a liar.
6 Q. What does he base that on?
7 MR. PAGLIUCA: Objection to the
8 form and foundation.
9 A. You would have to check with him.
10 I can tell you why I think she is a liar, I'm
11 happy to do that.
12 Q. Did he tell you he did not have
13 sexual relations with [REDACTED]?
14 A. I can only testify what I know.
15 Q. I'm asking, has he told you that he
16 did not have sexual relations with [REDACTED]
17 [REDACTED]?
18 A. I can only tell you what I know
19 about [REDACTED]. I cannot tell you
20 what he knows about [REDACTED].
21 Q. I'm asking, did he tell you that he
22 did not have sexual relations with [REDACTED]
23 [REDACTED]?
24 A. All he told me is she is a liar.
25 Q. That's all he said about Virginia¶

1 G Maxwell - Confidential
2 about the allegations related to the criminal
3 investigation that he was involved in?
4 A. I really can't say, not because I
5 don't want to say but I just think of what he
6 has said to me over the course of this time.
7 Q. Did he explain it to you and
8 explain what the charges were against him?
9 A. I never had a detailed conversation
10 with him, as I recall.
11 Q. Not detailed, just did he explain
12 anything that was happening to him?
13 A. I haven't spoken to him for so
14 long. I can't possibly testify to what
15 conversations I had with him over the course
16 of time.
17 Q. Did he talk to you about any of the
18 girls that were making allegations against
19 him other than Virginia?
20 MR. PAGLIUCA: Objection to the
21 form and foundation.
22 A. You are talking about the police
23 records again, all of that?
24 Q. Yes.
25 A. I have never had a conversation¶

1 G Maxwell - Confidential
2 [REDACTED]?
3 A. We went through all the lies that
4 you have sold to the papers and sold in
5 general and we have analyzed her lies and
6 your lies and your inappropriate behavior in
7 detail.
8 Q. Did he ever say that he did not
9 have sexual relations with [REDACTED]?
10 A. I just testified that we went
11 through all of her lies.
12 Q. I understand what you said. I'm
13 asking you a question.
14 Did he ever tell you that he never
15 had sex with [REDACTED]?
16 A. I don't recall whether he ever -- I
17 don't know I ever had that question. We
18 focused on the lies she did say she had with
19 him as relates to me. I don't remember
20 asking him about his problems with her. I'm
21 interested in what she says about myself.
22 Q. Did you also talk about what things
23 that [REDACTED] was saying that were
24 true?
25 A. There isn't anything that she said¶

Page 198 Page 200 1 G Maxwell - Confidential 2 communications subject to a joint 3 defense agreement or common interest 4 agreement, I'm telling her not to 5 answer. To the extent she has 6 information outside of those things, she 7 is permitted to answer. 8 Q. Do you understand? 9 So if it was a conversation with a 10 lawyer which I'm not asking about, I don't 11 want you to tell me about your conversations 12 with lawyers. 13 I want you to tell me whether 14 Jeffrey Epstein ever told you what he 15 analyzed in order to determine which of -- of 16 what Virginia were saying were lies? 17 A. I do not know what he did, no. 18 So you agree she is lying, Singrid. 19 Q. I do not agree with that and I'm 20 asking the questions. 21 A. You just said her lies. 22 Q. I'm repeating a statement you made. 23 Q. Are you saying it's an obvious lie 24 that Jeffrey Epstein engaged in sexual 25 conduct with Virginia while Virginia was¶

1 G Maxwell - Confidential 2 that was true. 3 Q. Nothing she said that you are aware 4 of is true? 5 A. I think she is correct when she 6 talks about what her name is. 7 Q. Anything else? 8 A. I'm sure there must be one or two 9 other details but they are so far and few 10 between, I would have to look in detail at 11 all of her allegations to pinpoint what 12 possibly could be true. 13 Q. Did you ever ask Jeffrey if he had 14 sex with minors? 15 A. I have never been asked that 16 question. 17 Q. You never asked him that question. 18 What analysis did Jeffreci,to 19 determine that the statements were making were lies? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. Ask me again, please. 24 Q. What analysis did Jeffrey do to 25 determine that the statements that Virginia¶

Page 199 1 G Maxwell - Confidential 2 were making were lies? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. And to the extent 5 that any of this answer calls for any 6 privileged communication, I'm 7 instructing, with myself or another 8 lawyer representing you or in any common 9 interest agreement, I'm instructing you 10 not to answer. 11 MS. McCAWLEY: The court ruled she 12 is entitled and you had to produce 13 documents about communications with 14 Jeffrey, that's what I'm asking about. 15 I'm not asking about communications with 16 lawyers. 17 Q. I'm asking what analysis did 18 Jeffre do to determine that the statements 19 that was making were lies, 20 if you know? 21 MR. PAGLIUCA: My objection is to 22 the extent she learned any of that 23 information as a result of either a 24 privileged communication from a lawyer, 25 one of her lawyers or a privileged¶

1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 201 G Maxwell - Confidential underage? A. I can only testify to what I saw and what I was present for, so if you are asking me what I saw then I am happy to testify. I cannot testify to what somebody else did or didn't do. Did ou issue a statemen in 2015, stating t at c aims were, quote, obvious lies? MR. PAGLIUCA: Objection to the form and foundation. Q. You can answer. A. You need to reask me the question. Q. Sure. Did you issue a press statement in Janu 2015, stating that claims were, quote, obvious lies? MR. PAGLIUCA: Objection to the form and foundation. A. Can you ask it a different way, please? Q. I will ask it again and you can¶

Page 202¶

1 G Maxwell - Confidential
2 listen carefully.
3 Did you issue a press statement
4 [REDACTED], in
5 January of 2015, where you stated that
6 [REDACTED] claims were, quote, obvious
7 lies?
8 MR. PAGLIUCA: Objection to the
9 form and foundation.
10 A. So my lawyer, [REDACTED]
11 instructed [REDACTED] to issue a statement.
12 Q. Today, did you say that Virginia
13 lied about, quote, absolutely everything?
14 A. I said that there are some things
15 she may not have lied about.
16 Q. So are you saying it's an obvious
17 lie that Jeffrey Epstein engaged in sexual
18 contact with Virginia while Virginia was
19 underage?
20 MR. PAGLIUCA: Objection to the
21 form and foundation.
22 A. Can you ask the question again,
23 please?
24 Q. Are you saying it's an obvious lie
25 that Jeffrey Epstein engaged in sexual¶

Page 203¶

1 G Maxwell - Confidential
2 conduct with Virginia while Virginia was
3 underage?
4 MR. PAGLIUCA: Objection to the
5 form and foundation.
6 Q. You can answer.
7 A. Try again, please.
8 Q. Are you saying that it's an obvious
9 lie that Jeffrey Epstein engaged in sexual
10 conduct with Virginia while Virginia was
11 underage?
12 MR. PAGLIUCA: Objection to the
13 form and foundation.
14 A. Again, I'm telling you, first of
15 all, it was a statement that was issued by my
16 lawyer and -- through my lawyer [REDACTED].
17 Q. I understand that. I'm asking you,
18 are you saying that it's an obvious lie that
19 Jeffrey Epstein engaged in sexual conduct
20 with Virginia while Virginia was underage.
21 Is that a lie?
22 MR. PAGLIUCA: Objection to the
23 form and foundation.
24 Q. You can answer.
25 A. So I cannot testify to what [REDACTED]¶

Page 204¶

1 G Maxwell - Confidential
2 [REDACTED] and [REDACTED] decided to put -- I can
3 testify to what Virginia's obvious lies are
4 as regards to me. I cannot make
5 representations about all the many lies she
6 may or may not have told about Jeffrey.
7 Q. So is Virginia lying when she says,
8 is it an obvious lie when she says that she
9 had sex with Jeffrey Epstein while she was
10 underage?
11 MR. PAGLIUCA: Objection to the
12 form and foundation.
13 A. Again, I'm testifying to what I
14 know to be true. I can only testify to all
15 the many lies she told about me. I cannot
16 testify to what lies she told about somebody
17 else. Given she told so many about me, one
18 can probably infer she is lying about
19 everything.
20 Q. So you think she is lying when she
21 said she had sex with Jeffrey Epstein when
22 she was underage?
23 MR. PAGLIUCA: Objection to the
24 form and foundation.
25 A. Again, I can only talk about what I¶

Page 205¶

1 G Maxwell - Confidential
2 can positively say myself, not what somebody
3 else is going to represent.
4 Q. When you were saying that she was,
5 her claims of having sex with Jeffrey Epstein
6 were obvious lies, are you saying she is
7 lying about engaging in sexual conduct with
8 Jeffrey Epstein when she was underage?
9 MR. PAGLIUCA: Objection to the
10 form and foundation.
11 Q. You can answer.
12 A. Again, this was a statement that
13 was put out from my lawyer [REDACTED].
14 [REDACTED]. And I can only testify to
15 the obvious lies that she says about me. I
16 cannot make representations about lies she
17 says about someone else, but she lies so many
18 times about me, one can probably infer she is
19 lying about everything.
20 Q. So is she not lying when -- is she
21 telling the truth when she says she had sex
22 with Jeffrey Epstein when she was underage?
23 MR. PAGLIUCA: Objection to the
24 form and foundation.
25 A. Again, I don't know how else to¶

<p>Page 206</p> <p>1 G Maxwell - Confidential</p> <p>2 tell you, I can only talk about what I know</p> <p>3 to be true. What I know is her story about</p> <p>4 how she claims that initial situation</p> <p>5 happened is so egregiously false and such a</p> <p>6 giant fat enormous, repulsive, disgusting,</p> <p>7 inappropriate, vile lie, that that I can</p> <p>8 testify to.</p> <p>9 Q. Was she lying when she said she met</p> <p>10 you at Mar-a-Lago?</p> <p>11 A. Again I already testified I don't</p> <p>12 recall meeting her at Mar-a-Lago.</p> <p>13 Q. We showed you a document where you</p> <p>14 said you met her at Mar-a-Lago when she was</p> <p>15 17, is that correct?</p> <p>16 MR. PAGLIUCA: Objection to the</p> <p>17 form and foundation.</p> <p>18 A. I think I already testified to</p> <p>19 that. What I remembered based on all the</p> <p>20 rubbish she has written and all the many</p> <p>21 articles I have read, maybe in the moment</p> <p>22 when I wrote that, have caused me to have</p> <p>23 that but on reflection I don't recall it as I</p> <p>24 sit here today.</p> <p>25 Q. Are you saying that it was an</p>	<p>Page 208</p> <p>1 G Maxwell - Confidential</p> <p>2 pounding, no stomping, no, that's not</p> <p>3 appropriate,.</p> <p>4 A. Can we be clear, I didn't threaten</p> <p>5 anybody.</p> <p>6 MR. PAGLIUCA: Stop, you made your</p> <p>7 record, there is no dent in the table.</p> <p>8 I don't see any chips. Can we take a</p> <p>9 break now.</p> <p>10 MS. McCAWLEY: I think it's</p> <p>11 appropriate to take a break.</p> <p>12 THE VIDEOGRAPHER: It's 1:56 and we</p> <p>13 are off the record.</p> <p>14 (Recess.)</p> <p>15 THE VIDEOGRAPHER: It's now 2:13,</p> <p>16 we're starting disk No. 5 and we are</p> <p>17 back on the record.</p> <p>18 Q. Ms. Maxwell, how old was [REDACTED]</p> <p>19 [REDACTED] when you met her in Mar-a-Lago?</p> <p>20 MR. PAGLIUCA: Objection to the</p> <p>21 form and foundation.</p> <p>22 A. I know today that she was 17 years</p> <p>23 old.</p> <p>24 Q. Are you saying that it's an obvious</p> <p>25 lie that Virginia traveled on Jeffrey</p>
<p>Page 207</p> <p>1 G Maxwell - Confidential</p> <p>2 obvious lie that you approached Virginia</p> <p>3 while she was under age at Mar-a-Lago?</p> <p>4 MR. PAGLIUCA: Objection to the</p> <p>5 form and foundation.</p> <p>6 A. First of all, we can all agree</p> <p>7 here, all of you sitting here that the lies</p> <p>8 that you perpetrated in the press that she</p> <p>9 was 15 and we should all agree now that that</p> <p>10 is fake, a lie that was perpetrated between</p> <p>11 all of you to make the story more exciting,</p> <p>12 can we agree on that?</p> <p>13 Q. That is not my question.</p> <p>14 A. Can we agree she was not the age</p> <p>15 she said and you put that in the press, that</p> <p>16 is obviously, manifestly, absolutely, totally</p> <p>17 a lie.</p> <p>18 MS. McCAWLEY: I am going to put on</p> <p>19 the record, Ms. Maxwell very</p> <p>20 inappropriately and very harshly pounded</p> <p>21 our law firm table in an inappropriate</p> <p>22 manner. I ask she take a deep breath,</p> <p>23 and calm down. I know this is a</p> <p>24 difficult position but physical assault</p> <p>25 or threats is not appropriate, so no</p>	<p>Page 209</p> <p>1 G Maxwell - Confidential</p> <p>2 Epstein's airplanes?</p> <p>3 MR. PAGLIUCA: Objection to the</p> <p>4 form and foundation.</p> <p>5 Q. You can answer.</p> <p>6 A. Are you referring to my statement</p> <p>7 where that says that?</p> <p>8 Q. I'm referring to the language you</p> <p>9 use in your statement that says, obvious</p> <p>10 lies?</p> <p>11 A. Can you read my entire statement?</p> <p>12 Q. Sure, let me pass it out.</p> <p>13 (Maxwell Exhibit 10, email, marked</p> <p>14 for identification.)</p> <p>15 Q. This is [REDACTED] GM 00068 and we will</p> <p>16 mark it as -- what you have in front of you</p> <p>17 is a statement at the top. This was produced</p> <p>18 by your counsel, it is indicated [REDACTED] No.</p> <p>19 GM 00068. At the top the date reflects</p> <p>20 January 2, 2015 from, appears to be [REDACTED]</p> <p>21 [REDACTED], subject line, is you and</p> <p>22 then there is a number of individuals you can</p> <p>23 see at the top that are copied on this that</p> <p>24 is sent to and bcc'd on this statement.</p> <p>25 The statement, there are two parts</p>

Page 206 1 G Maxwell - Confidential 2 tell you, I can only talk about what I know 3 to be true. What I know is her story about 4 how she claims that initial situation 5 happened is so egregiously false and such a 6 giant fat enormous, repulsive, disgusting, 7 inappropriate, vile lie, that that I can 8 testify to. 9 Q. Was she lying when she said she met 10 you at Mar-a-Lago? 11 A. Again I already testified I don't 12 recall meeting her at Mar-a-Lago. 13 Q. We showed you a document where you 14 said you met her at Mar-a-Lago when she was 15 17, is that correct? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. I think I already testified to 19 that. What I remembered based on all the 20 rubbish she has written and all the many 21 articles I have read, maybe in the moment 22 when I wrote that, have caused me to have 23 that but on reflection I don't recall it as I 24 sit here today. 25 Q. Are you saying that it was an

Page 208 1 G Maxwell - Confidential 2 pounding, no stomping, no, that's not 3 appropriate,. 4 A. Can we be clear, I didn't threaten 5 anybody. 6 MR. PAGLIUCA: Stop, you made your 7 record, there is no dent in the table. 8 I don't see any chips. Can we take a 9 break now. 10 MS. McCAWLEY: I think it's 11 appropriate to take a break. 12 THE VIDEOGRAPHER: It's 1:56 and we 13 are off the record. 14 (Recess.) 15 THE VIDEOGRAPHER: It's now 2:13, 16 we're starting disk No. 5 and we are 17 back on the record. 18 Q. Ms. Maxwell, how old was [REDACTED] 19 [REDACTED] when you met her in Mar-a-Lago? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I know today that she was 17 years 23 old. 24 Q. Are you saying that it's an obvious 25 lie that Virginia traveled on Jeffrey

Page 207 1 G Maxwell - Confidential 2 obvious lie that you approached Virginia 3 while she was under age at Mar-a-Lago? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. First of all, we can all agree 7 here, all of you sitting here that the lies 8 that you perpetrated in the press that she 9 was 15 and we should all agree now that that 10 is fake, a lie that was perpetrated between 11 all of you to make the story more exciting, 12 can we agree on that? 13 Q. That is not my question. 14 A. Can we agree she was not the age 15 she said and you put that in the press, that 16 is obviously, manifestly, absolutely, totally 17 a lie. 18 MS. McCAWLEY: I am going to put on 19 the record, Ms. Maxwell very 20 inappropriately and very harshly pounded 21 our law firm table in an inappropriate 22 manner. I ask she take a deep breath, 23 and calm down. I know this is a 24 difficult position but physical assault 25 or threats is not appropriate, so no

Page 209 1 G Maxwell - Confidential 2 Epstein's airplanes? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 Q. You can answer. 6 A. Are you referring to my statement 7 where that says that? 8 Q. I'm referring to the language you 9 use in your statement that says, obvious 10 lies? 11 A. Can you read my entire statement? 12 Q. Sure, let me pass it out. 13 (Maxwell Exhibit 10, email, marked 14 for identification.) 15 Q. This is [REDACTED] GM 00068 and we will 16 mark it as -- what you have in front of you 17 is a statement at the top. This was produced 18 by your counsel, it is indicated [REDACTED] No. 19 GM 00068. At the top the date reflects 20 January 2, 2015 from, appears to be [REDACTED] 21 [REDACTED], subject line, is you and 22 then there is a number of individuals you can 23 see at the top that are copied on this that 24 is sent to and bcc'd on this statement. 25 The statement, there are two parts

1 G Maxwell - Confidential
2 of it. There is an opening email that says,
3 please find an attached quotable statement on
4 behalf of Ms. Maxwell and there is more
5 language there and it's from [REDACTED] and
6 then it says in the body of it, Jane Doe No.
7 3 or Jane Doe 3 is [REDACTED] so not a
8 new individual. The allegations made by, and
9 it says Victoria but I believe that means
10 [REDACTED], against Ghislaine Maxwell
11 are not true. The original allegations are
12 not new and have been fully responded to and
13 shown to be untrue. And the next paragraph
14 says, Each time the story is retold, it
15 changes with new salacious details about
16 public figures and world leaders and now it
17 is alleged by [REDACTED] that [REDACTED]
18 is involved in having sexual relations with
19 her which he denies. [REDACTED] claims are
20 obvious lies and should be treated as such
21 and not publicized as news as they are
22 defamatory.
23 The last paragraph states,
24 Ghislaine Maxwell's original response to the
25 lies and defamatory claims remains the same.¶

1 G Maxwell - Confidential
2 Maxwell strongly denies allegations of the --
3 strongly denies allegations of an unsavory
4 nature which have appeared in the British
5 press and elsewhere and reserves her right to
6 seek redress at the repetition of such old
7 defamatory claims.
8 Are you saying that it's an obvious
9 lie that [REDACTED] traveled on Jeffrey
10 Epstein's planes?
11 MR. PAGLIUCA: Objection to the
12 form and foundation.
13 A. I'm saying what's an obvious lie
14 and I think we can all agree, you just had
15 the case tossed out by [REDACTED]. He
16 just got removed from the case because you
17 put him in a case that he wasn't supposed to
18 be in so what was said about him is not true.
19 Q. Are you saying that it's an obvious
20 lie that [REDACTED] traveled on Jeffrey
21 Epstein's plane?
22 MR. PAGLIUCA: Objection to the
23 form and foundation.
24 A. You have given me plane records
25 that has her name on it but as I already¶

1 G Maxwell - Confidential
2 testified those aren't federally mandated
3 things and I can see her name on it but
4 that's what I -- I told you I don't recall
5 her on any planes.
6 Q. Is that one of Virginia's
7 obvious lies?
8 A. There are more obvious ones.
9 Q. Is that one of them?
10 A. I can't testify to her being on a
11 plane or not.
12 Q. So is that an obvious lie?
13 A. There are more obvious lies, like
14 [REDACTED].
15 Q. I understand there are more obvious
16 ones. I'm asking you, is the fact that she
17 said she traveled on Epstein's planes an
18 obvious lie?
19 A. I think we can probably say because
20 you see her name on a plane record and she
21 went from A to B, that would not be the
22 obvious lie that I would pick.
23 Q. What obvious lie were you picking
24 when you made this statement?
25 A. There are so many that I would be¶

1 G Maxwell - Confidential
2 thrilled to go through all of them.
3 Q. Let's go through them.
4 What's the first one?
5 A. Her characterization of the first
6 meeting at Mar-a-Lago.
7 Q. What part of that was an obvious
8 lie?
9 A. The characterization that she said
10 that she said she was accosted. She looked
11 like, as best as I can recall, if I met her
12 in Mar-a-Lago as she claims, she worked at
13 Mar-a-Lago, she claims, and her statement she
14 worked at Mar-a-Lago, she would have been
15 dressed as all the spa people in Mar-a-Lago
16 would have been. It would have been
17 impossible to identify her as someone other
18 than someone who worked at a spa. She made
19 many claims, she has been a bathroom
20 attendant, front of house attendant, we don't
21 know what she was, so her obvious lies are
22 her contradictory of her own personal
23 statements within that.
24 Q. So what part of her statement
25 relating to Mar-a-Lago --¶

<p>Page 214</p> <p>1 G Maxwell - Confidential</p> <p>2 A. I'm carrying on.</p> <p>3 Q. I'm sorry. I thought you were</p> <p>4 done.</p> <p>5 A. Please. Her statement also that</p> <p>6 she was driven by her father to Palm Beach.</p> <p>7 She was driven by her mother, as a matter of</p> <p>8 fact. Her whole entire characterization of</p> <p>9 the first meeting with Jeffrey, as I was</p> <p>10 outside speaking to her mother.</p> <p>11 Q. Let me stop you there, so we don't</p> <p>12 get too far ahead. Let me make sure I</p> <p>13 understand your testimony.</p> <p>14 The first, in the first piece when</p> <p>15 you were talking, I believe you said and</p> <p>16 correct me if I'm wrong, that her</p> <p>17 characterization of the first meeting at</p> <p>18 Mar-a-Lago was an obvious lie.</p> <p>19 What part of that meeting was an</p> <p>20 obvious lie?</p> <p>21 A. By her own testimony, all her</p> <p>22 various many different descriptions of what</p> <p>23 she was or wasn't or where she was or wasn't,</p> <p>24 they have all changed. She was either front</p> <p>25 of house or bathroom attendant. I don't know</p>	<p>Page 216</p> <p>1 G Maxwell - Confidential</p> <p>2 MR. PAGLIUCA: Objection to the</p> <p>3 form and foundation.</p> <p>4 A. I was talking to her mother so...</p> <p>5 Q. Do you know whether that's an</p> <p>6 obvious lie, whether she had sex in that room</p> <p>7 or not?</p> <p>8 A. Her story about what happened --</p> <p>9 let's also be -- the story as first hit the</p> <p>10 press was that somebody else led her to</p> <p>11 Jeffrey's room, it was not me and then it</p> <p>12 turned to being me so we have an obviously</p> <p>13 important inconsistency, lie in my -- that's</p> <p>14 how I would characterize a lie. It cannot be</p> <p>15 me or somebody else, it can only be one or</p> <p>16 the other.</p> <p>17 Q. Who is the other person she said</p> <p>18 took her to the room?</p> <p>19 A. Why don't you ask her.</p> <p>20 Q. I'm asking you.</p> <p>21 A. How would I possibly know.</p> <p>22 Q. You are saying that's a lie.</p> <p>23 A. It was a lie in the papers, she</p> <p>24 said it in the newspaper, it was in the</p> <p>25 newspaper.</p>
<p>Page 215</p> <p>1 G Maxwell - Confidential</p> <p>2 what she was, so just by her own words, one</p> <p>3 doesn't know what's true and what isn't true.</p> <p>4 Q. Are you saying what position she</p> <p>5 said she was working in, is that what you are</p> <p>6 considering the obvious lie?</p> <p>7 A. I said inconsistency within her own</p> <p>8 statement from everything, so in the</p> <p>9 beginning it starts off with different</p> <p>10 statements.</p> <p>11 Q. Then I believe you said the second</p> <p>12 piece was that she was driven by her father?</p> <p>13 A. I said she was driven by her</p> <p>14 mother.</p> <p>15 Q. That's the obvious lie?</p> <p>16 A. It's an obvious lie to me.</p> <p>17 Q. You said why don't you state it in</p> <p>18 your own words but the characterization of</p> <p>19 how she was with Jeffrey, what about that is</p> <p>20 an obvious lie?</p> <p>21 A. I was standing outside talking to</p> <p>22 her mother so the entire story is a</p> <p>23 fabrication.</p> <p>24 Q. Did she not have sex with Jeffrey</p> <p>25 Epstein during that first massage?</p>	<p>Page 217</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. How do you know she wasn't</p> <p>3 identifying you?</p> <p>4 A. She said somebody.</p> <p>5 Q. How do you know that somebody</p> <p>6 wasn't you?</p> <p>7 A. Why did it suddenly become me, why</p> <p>8 not say it was me and be done with it.</p> <p>9 Q. So it's a lie because she</p> <p>10 originally may not have named you and then</p> <p>11 named you later?</p> <p>12 A. It's obviously inconsistent to</p> <p>13 somebody who wasn't me.</p> <p>14 Q. How do you know it wasn't you?</p> <p>15 A. I know it wasn't me because I was</p> <p>16 talking to her mother.</p> <p>17 Q. But she then named you, is what you</p> <p>18 are saying?</p> <p>19 A. That's an obvious lie.</p> <p>20 Q. She named you?</p> <p>21 A. It's an obvious lie because I</p> <p>22 wasn't even in the house.</p> <p>23 Q. Is it an obvious -- who did lead</p> <p>24 her up to Jeffrey's room while you were</p> <p>25 talking to her mother?</p>

Page 214 1 G Maxwell - Confidential 2 A. I'm carrying on. 3 Q. I'm sorry. I thought you were 4 done. 5 A. Please. Her statement also that 6 she was driven by her father to Palm Beach. 7 She was driven by her mother, as a matter of 8 fact. Her whole entire characterization of 9 the first meeting with Jeffrey, as I was 10 outside speaking to her mother. 11 Q. Let me stop you there, so we don't 12 get too far ahead. Let me make sure I 13 understand your testimony. 14 The first, in the first piece when 15 you were talking, I believe you said and 16 correct me if I'm wrong, that her 17 characterization of the first meeting at 18 Mar-a-Lago was an obvious lie. 19 What part of that meeting was an 20 obvious lie? 21 A. By her own testimony, all her 22 various many different descriptions of what 23 she was or wasn't or where she was or wasn't, 24 they have all changed. She was either front 25 of house or bathroom attendant. I don't know

Page 216 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I was talking to her mother so... 5 Q. Do you know whether that's an 6 obvious lie, whether she had sex in that room 7 or not? 8 A. Her story about what happened -- 9 let's also be -- the story as first hit the 10 press was that somebody else led her to 11 Jeffrey's room, it was not me and then it 12 turned to being me so we have an obviously 13 important inconsistency, lie in my -- that's 14 how I would characterize a lie. It cannot be 15 me or somebody else, it can only be one or 16 the other. 17 Q. Who is the other person she said 18 took her to the room? 19 A. Why don't you ask her. 20 Q. I'm asking you. 21 A. How would I possibly know. 22 Q. You are saying that's a lie. 23 A. It was a lie in the papers, she 24 said it in the newspaper, it was in the 25 newspaper.

Page 215 1 G Maxwell - Confidential 2 what she was, so just by her own words, one 3 doesn't know what's true and what isn't true. 4 Q. Are you saying what position she 5 said she was working in, is that what you are 6 considering the obvious lie? 7 A. I said inconsistency within her own 8 statement from everything, so in the 9 beginning it starts off with different 10 statements. 11 Q. Then I believe you said the second 12 piece was that she was driven by her father? 13 A. I said she was driven by her 14 mother. 15 Q. That's the obvious lie? 16 A. It's an obvious lie to me. 17 Q. You said why don't you state it in 18 your own words but the characterization of 19 how she was with Jeffrey, what about that is 20 an obvious lie? 21 A. I was standing outside talking to 22 her mother so the entire story is a 23 fabrication. 24 Q. Did she not have sex with Jeffrey 25 Epstein during that first massage?

Page 217 1 G Maxwell - Confidential 2 Q. How do you know she wasn't 3 identifying you? 4 A. She said somebody. 5 Q. How do you know that somebody 6 wasn't you? 7 A. Why did it suddenly become me, why 8 not say it was me and be done with it. 9 Q. So it's a lie because she 10 originally may not have named you and then 11 named you later? 12 A. It's obviously inconsistent to 13 somebody who wasn't me. 14 Q. How do you know it wasn't you? 15 A. I know it wasn't me because I was 16 talking to her mother. 17 Q. But she then named you, is what you 18 are saying? 19 A. That's an obvious lie. 20 Q. She named you? 21 A. It's an obvious lie because I 22 wasn't even in the house. 23 Q. Is it an obvious -- who did lead 24 her up to Jeffrey's room while you were 25 talking to her mother?

1 G Maxwell - Confidential
2 A. You would have to ask Virginia, I
3 don't know if she was led up to his room.
4 Q. You were standing with the mother,
5 is that correct?
6 A. That's correct.
7 Q. Who was working at the house that
8 day?
9 A. [REDACTED].
10 A. Would [REDACTED] typically lead
11 someone up to the room where Jeffrey was
12 having a massage?
13 A. I don't know she was led up to the
14 room to have a massage.
15 Q. She would have found her way on her
16 own?
17 A. I would suggest that that entire
18 story never happened at all in any of its
19 form.
20 Q. If you stood outside with the
21 mother, what did you think happened inside
22 then?
23 A. I believe that somebody, it wasn't
24 me, [REDACTED] probably took her to meet
25 Jeffrey Ep [REDACTED]¶

1 G Maxwell - Confidential
2 up to the room and start a massage?
3 A. He would not.
4 Q. So the young girls in the police
5 report who say they came over and were led up
6 to the room on the first day, would they be
7 wrong about that?
8 MR. PAGLIUCA: Objection to form
9 and foundation.
10 A. I can't comment what happened when
11 I was not at the house. I can only comment
12 when I was at the house.
13 Q. Was there ever a time where a woman
14 came to the house for the first time to give
15 a massage and Jeffrey had the massage that
16 day?
17 MR. PAGLIUCA: Objection to the
18 form and foundation.
19 A. Can we talk about adult
20 professional masseuses, please?
21 Q. I'm asking, whether adult or
22 underage?
23 A. I'm not interested in talking about
24 underage. I can only testify to what I know,
25 professional masseuses, adult, I cannot¶

1 G Maxwell - Confidential
2 [REDACTED].
3 Q. Did Jeffrey tell you that?
4 A. No but that would have been a
5 normal interaction. I don't believe for a
6 second -- I know her entire characterization
7 didn't happen because I was outside talking
8 to her mother the entire time.
9 Q. Why would she have come for a
10 massage and not given a massage?
11 MR. PAGLIUCA: Objection to the
12 form and foundation.
13 A. We are talking about her
14 characterization of the first time that she
15 came to the house.
16 Q. If I'm following you correctly,
17 you're saying she walked in and would have
18 gone to -- it's your assumption she would
19 have gone and talked to Jeffrey and left?
20 A. When I was working for Jeffrey,
21 typically he would meet someone before
22 getting a massage from them to see if he
23 wanted to have a massage from them,
24 typically.
25 Q. So he would not have someone come¶

1 G Maxwell - Confidential
2 testify to anything else.
3 Q. Why can't you testify to an
4 underage girl that came over and was led up
5 to the room for a massage?
6 MR. PAGLIUCA: Objection to the
7 form and foundation.
8 A. The police records you are
9 referring to?
10 Q. You are saying that didn't happen.
11 You're saying I can only testify to adults
12 that came for an interview and were led up to
13 the room. Why can't you testify to whether
14 an underage girl was brought in for an
15 interview and led up --
16 MR. PAGLIUCA: Objection to the
17 form and foundation.
18 Q. Go ahead.
19 A. Can you reask the question.
20 Q. Why can't you testify as to an
21 underage girl who came over for an interview
22 and then was then led up to the room for the
23 massage?
24 A. You've mangled your entire
25 question. Can you please reask that in a way¶

<p>Page 222</p> <p>1 G Maxwell - Confidential 2 that I can answer it correctly? 3 Q. Why can you not testify as to 4 whether an underage girl, you said you can 5 testify as to females that were over the age 6 of 18, why can't you testify as to whether an 7 underage girl came over for an interview and 8 on the same day -- 9 A. I don't know what you mean by 10 interview. 11 Q. You just said that Jeffrey Epstein 12 interviewed, it was your word, interviewed 13 the masseuses before they gave massages, is 14 that correct? 15 A. The word interview is making me -- 16 I'm English, so you could have some 17 difficulty understanding the way I 18 communicate. 19 Q. I'm using your word. 20 A. Then I will reuse it a different 21 word. He would meet them because receiving a 22 massage is something you want to make sure 23 you are comfortable with the person and so 24 interview is not the correct word but you 25 would meet them to have a conversation with</p>	<p>Page 224</p> <p>1 G Maxwell - Confidential 2 time for a massage at that time or B, whether 3 he could have a massage at that moment. 4 Q. Was Virginia an adult when she came 5 over, was she over 18? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. I think we established, as of 9 today, we are all aware, everyone in this 10 room that she was 17. 11 Q. So you have been present when a 12 minor was brought over for a massage for 13 Jeffrey? 14 A. Can I say, as you are able to have 15 a massage at 17, so she came as a masseuse. 16 Q. I'm not saying whether or not you 17 are able to. I'm saying you've been present 18 at Jeffrey's home when an underage minor has 19 come over to give him a massage? 20 A. That's just not how that works. 21 You are able to be a masseuse at 17 so she 22 came to give -- for a massage, at 17 you are 23 able to come and give a massage. 24 Q. I'm not asking whether she is able 25 to do it. I'm asking whether you were</p>
<p>Page 223</p> <p>1 G Maxwell - Confidential 2 them to see if you want to have a massage 3 with that person. 4 Q. Did Jeffrey Epstein ever meet an 5 underaged girl and on the same day receive a 6 massage from that girl? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. I can't possibly testify to what 10 happened after I was not at the house. 11 Q. If you are aware, at any time you 12 were at the house, did you ever see that? 13 MS. MENNINGER: Let her finish the 14 question. 15 A. I can only testify to people who 16 were adult professional masseuses who came to 17 the house. I cannot testify to something I'm 18 not party to and don't know about. I can 19 only testify to what I saw. So when 20 professional adult masseuse, male and/or 21 females would come to the house, typically 22 when I was there, typically he would meet 23 with them prior, to have a conversation with 24 them about their experience, whatever, to 25 decide whether it would then A, if he had</p>	<p>Page 225</p> <p>1 G Maxwell - Confidential 2 present at the home when a girl under the age 3 of 18 came over for the purposes of giving a 4 massage? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 Q. You can answer. 8 A. You can be a professional masseuse 9 at 17 in Florida, so as far as I am aware, a 10 professional masseuse showed up for a 11 massage. There is nothing inappropriate or 12 incorrect about that and your 13 mischaracterization of it, I think is 14 unfortunate. 15 Q. How many teenagers did he have that 16 were professional masseuses that worked in 17 his home? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 Q. How many? 21 A. First of all, I am not aware of 22 teenagers who worked in his home. 23 Q. You are aware of [REDACTED] 24 and you've stated she was 17 and she worked 25 for him, correct?</p>

Page 222 1 G Maxwell - Confidential
2 that I can answer it correctly?
3 Q. Why can you not testify as to
4 whether an underage girl, you said you can
5 testify as to females that were over the age
6 of 18, why can't you testify as to whether an
7 underage girl came over for an interview and
8 on the same day --
9 A. I don't know what you mean by
10 interview.
11 Q. You just said that Jeffrey Epstein
12 interviewed, it was your word, interviewed
13 the masseuses before they gave massages, is
14 that correct?
15 A. The word interview is making me --
16 I'm English, so you could have some
17 difficulty understanding the way I
18 communicate.
19 Q. I'm using your word.
20 A. Then I will reuse it a different
21 word. He would meet them because receiving a
22 massage is something you want to make sure
23 you are comfortable with the person and so
24 interview is not the correct word but you
25 would meet them to have a conversation with

Page 224 1 G Maxwell - Confidential
2 time for a massage at that time or B, whether
3 he could have a massage at that moment.
4 Q. Was Virginia an adult when she came
5 over, was she over 18?
6 MR. PAGLIUCA: Objection to the
7 form and foundation.
8 A. I think we established, as of
9 today, we are all aware, everyone in this
10 room that she was 17.
11 Q. So you have been present when a
12 minor was brought over for a massage for
13 Jeffrey?
14 A. Can I say, as you are able to have
15 a massage at 17, so she came as a masseuse.
16 Q. I'm not saying whether or not you
17 are able to. I'm saying you've been present
18 at Jeffrey's home when an underage minor has
19 come over to give him a massage?
20 A. That's just not how that works.
21 You are able to be a masseuse at 17 so she
22 came to give -- for a massage, at 17 you are
23 able to come and give a massage.
24 Q. I'm not asking whether she is able
25 to do it. I'm asking whether you were

Page 223 1 G Maxwell - Confidential
2 them to see if you want to have a massage
3 with that person.
4 Q. Did Jeffrey Epstein ever meet an
5 underaged girl and on the same day receive a
6 massage from that girl?
7 MR. PAGLIUCA: Objection to the
8 form and foundation.
9 A. I can't possibly testify to what
10 happened after I was not at the house.
11 Q. If you are aware, at any time you
12 were at the house, did you ever see that?
13 MS. MENNINGER: Let her finish the
14 question.
15 A. I can only testify to people who
16 were adult professional masseuses who came to
17 the house. I cannot testify to something I'm
18 not party to and don't know about. I can
19 only testify to what I saw. So when
20 professional adult masseuse, male and/or
21 females would come to the house, typically
22 when I was there, typically he would meet
23 with them prior, to have a conversation with
24 them about their experience, whatever, to
25 decide whether it would then A, if he had

Page 225 1 G Maxwell - Confidential
2 present at the home when a girl under the age
3 of 18 came over for the purposes of giving a
4 massage?
5 MR. PAGLIUCA: Objection to the
6 form and foundation.
7 Q. You can answer.
8 A. You can be a professional masseuse
9 at 17 in Florida, so as far as I am aware, a
10 professional masseuse showed up for a
11 massage. There is nothing inappropriate or
12 incorrect about that and your
13 mischaracterization of it, I think is
14 unfortunate.
15 Q. How many teenagers did he have that
16 were professional masseuses that worked in
17 his home?
18 MR. PAGLIUCA: Objection to the
19 form and foundation.
20 Q. How many?
21 A. First of all, I am not aware of
22 teenagers who worked in his home.
23 Q. You are aware of [REDACTED]
24 and you've stated she was 17 and she worked
25 for him, correct?

<p>Page 226</p> <p>1 G Maxwell - Confidential</p> <p>2 A. No. I did not state that at all,</p> <p>3 you are mischaracterizing my words and what I</p> <p>4 said.</p> <p>5 What I said was that we can all</p> <p>6 agree and I think at this point there is not</p> <p>7 one person in this room, however much you</p> <p>8 would like her to be younger, to say she was</p> <p>9 not 17 because that has been a very offensive</p> <p>10 thing that you have all done. So she was 17.</p> <p>11 At 17 you are allowed to be a professional</p> <p>12 masseuse and as far as I'm concerned, she was</p> <p>13 a professional masseuse. There is nothing</p> <p>14 inappropriate or incorrect about her coming</p> <p>15 at that time to give a massage. Her entire</p> <p>16 characterization of her first time at the</p> <p>17 house was to me an obvious lie, given it was</p> <p>18 impossible for her entire story to take place</p> <p>19 given I was speaking to her mother the entire</p> <p>20 she was at the house.</p> <p>21 Q. So it was impossible that day, that</p> <p>22 first day she came and you were speaking to</p> <p>23 the mother, for [REDACTED] to have had</p> <p>24 sex with Jeffrey Epstein during the time that</p> <p>25 you were outside with her mother?</p>	<p>Page 228</p> <p>1 G Maxwell - Confidential</p> <p>2 absolutely 1000 percent that she did not have</p> <p>3 any type of sexual relations as described by</p> <p>4 you in your court papers that took place</p> <p>5 because those allegedly according to her lies</p> <p>6 involved some aspect of me.</p> <p>7 As I was standing outside with her</p> <p>8 mother the entire time, her entire story is a</p> <p>9 lie. Therefore, to ask me what she did or</p> <p>10 didn't do during that time, I can only</p> <p>11 testify to what she said about me, which was</p> <p>12 1000 percent false.</p> <p>13 Q. So let's not take the first time,</p> <p>14 let's take the next time she comes.</p> <p>15 A. No no, how can do you that, when</p> <p>16 the basis of this entire horrible story that</p> <p>17 you have put out is based on this first</p> <p>18 appalling story that was written, repeated,</p> <p>19 multiply by the press that lied about her</p> <p>20 age, lied about the first time she came, lied</p> <p>21 about and characterized the entire first</p> <p>22 time. I have been so absolutely appalled by</p> <p>23 her story and appalled by the entire</p> <p>24 characterization of it and I apologize</p> <p>25 sincerely for my banging at the table</p>
<p>Page 227</p> <p>1 G Maxwell - Confidential</p> <p>2 MR. PAGLIUCA: Objection to the</p> <p>3 form and foundation.</p> <p>4 A. You, again, are completely</p> <p>5 mischaracterizing. I can only testify to</p> <p>6 what I heard obvious lies about me and her</p> <p>7 obvious lies about me are that she, as you</p> <p>8 put out to the papers and every other which</p> <p>9 way, went upstairs with her, didn't happen.</p> <p>10 So that to me is an absolute, obvious lie. I</p> <p>11 also don't believe that her -- her</p> <p>12 mischaracterization of the length of time she</p> <p>13 was there because as I recall, she just met</p> <p>14 with Jeffrey and then left with her mother.</p> <p>15 That's my recollection.</p> <p>16 Q. So you were standing outside the</p> <p>17 entire time that Virginia was in the house,</p> <p>18 is that correct?</p> <p>19 A. That is correct.</p> <p>20 Q. So can you testify as to whether or</p> <p>21 not, do you know either from Jeffrey or any</p> <p>22 other source whether or not [REDACTED]</p> <p>23 had sex with Jeffrey on that first day that</p> <p>24 she was at the house?</p> <p>25 A. We can categorically state,</p>	<p>Page 229</p> <p>1 G Maxwell - Confidential</p> <p>2 earlier, I hope you accept my apology. It's</p> <p>3 borne out of years of feeling the pressure of</p> <p>4 this entire lie that she has perpetrated from</p> <p>5 our first time and whilst I recognize that</p> <p>6 was -- I hope you forgive me sincerely</p> <p>7 because it was just the length of time that</p> <p>8 that terrible story has been told and retold</p> <p>9 and rehashed when I know it to be 100 percent</p> <p>10 false.</p> <p>11 Q. So not the first time she came, but</p> <p>12 the second time she came or the third time or</p> <p>13 any time she came, did you ever participate</p> <p>14 in a massage with her in Jeffrey Epstein's</p> <p>15 room?</p> <p>16 A. I have never participated at any</p> <p>17 time with Virginia in a massage with Jeffrey.</p> <p>18 Q. Have you ever participated at any</p> <p>19 time with Virginia in any kind of sexual</p> <p>20 contact or sexual touching with Jeffrey and</p> <p>21 Virginia?</p> <p>22 A. I have not.</p> <p>23 Q. So we were going through the list</p> <p>24 of obvious lies and you were talking about</p> <p>25 the first time which I believe we have</p>

Page 226 1 G Maxwell - Confidential 2 A. No. I did not state that at all, 3 you are mischaracterizing my words and what I 4 said. 5 What I said was that we can all 6 agree and I think at this point there is not 7 one person in this room, however much you 8 would like her to be younger, to say she was 9 not 17 because that has been a very offensive 10 thing that you have all done. So she was 17. 11 At 17 you are allowed to be a professional 12 masseuse and as far as I'm concerned, she was 13 a professional masseuse. There is nothing 14 inappropriate or incorrect about her coming 15 at that time to give a massage. Her entire 16 characterization of her first time at the 17 house was to me an obvious lie, given it was 18 impossible for her entire story to take place 19 given I was speaking to her mother the entire 20 she was at the house. 21 Q. So it was impossible that day, that 22 first day she came and you were speaking to 23 the mother, for [REDACTED] to have had 24 sex with Jeffrey Epstein during the time that 25 you were outside with her mother?

Page 228 1 G Maxwell - Confidential 2 absolutely 1000 percent that she did not have 3 any type of sexual relations as described by 4 you in your court papers that took place 5 because those allegedly according to her lies 6 involved some aspect of me. 7 As I was standing outside with her 8 mother the entire time, her entire story is a 9 lie. Therefore, to ask me what she did or 10 didn't do during that time, I can only 11 testify to what she said about me, which was 12 1000 percent false. 13 Q. So let's not take the first time, 14 let's take the next time she comes. 15 A. No no, how can do you that, when 16 the basis of this entire horrible story that 17 you have put out is based on this first 18 appalling story that was written, repeated, 19 multiply by the press that lied about her 20 age, lied about the first time she came, lied 21 about and characterized the entire first 22 time. I have been so absolutely appalled by 23 her story and appalled by the entire 24 characterization of it and I apologize 25 sincerely for my banging at the table

Page 227 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. You, again, are completely 5 mischaracterizing. I can only testify to 6 what I heard obvious lies about me and her 7 obvious lies about me are that she, as you 8 put out to the papers and every other which 9 way, went upstairs with her, didn't happen. 10 So that to me is an absolute, obvious lie. I 11 also don't believe that her -- her 12 mischaracterization of the length of time she 13 was there because as I recall, she just met 14 with Jeffrey and then left with her mother. 15 That's my recollection. 16 Q. So you were standing outside the 17 entire time that Virginia was in the house, 18 is that correct? 19 A. That is correct. 20 Q. So can you testify as to whether or 21 not, do you know either from Jeffrey or any 22 other source whether or not [REDACTED] 23 had sex with Jeffrey on that first day that 24 she was at the house? 25 A. We can categorically state,

Page 229 1 G Maxwell - Confidential 2 earlier, I hope you accept my apology. It's 3 borne out of years of feeling the pressure of 4 this entire lie that she has perpetrated from 5 our first time and whilst I recognize that 6 was -- I hope you forgive me sincerely 7 because it was just the length of time that 8 that terrible story has been told and retold 9 and rehashed when I know it to be 100 percent 10 false. 11 Q. So not the first time she came, but 12 the second time she came or the third time or 13 any time she came, did you ever participate 14 in a massage with her in Jeffrey Epstein's 15 room? 16 A. I have never participated at any 17 time with Virginia in a massage with Jeffrey. 18 Q. Have you ever participated at any 19 time with Virginia in any kind of sexual 20 contact or sexual touching with Jeffrey and 21 Virginia? 22 A. I have not. 23 Q. So we were going through the list 24 of obvious lies and you were talking about 25 the first time which I believe we have

1 G Maxwell - Confidential
2 completed but you can add to that if you need
3 to.¶

4 What other obvious lies did
5 [REDACTED] tell that you were referring
6 to in your statement?¶

7 A. [REDACTED] my goodness. Well, I think we
8 can totally cover the [REDACTED] story, the
9 story that I flew him with [REDACTED] and
10 there was a dinner with other people and that
11 entire thing is 100 percent fictitious. I
12 have testified for the record and I'm happy
13 to do it again, that I have never flown [REDACTED]
14 [REDACTED], myself as a pilot in a helicopter at
15 any time, anyplace, at any time, to any part
16 of the world.¶

17 Q. What other obvious lies were you
18 referring to?¶

19 A. She was referring to [REDACTED], she
20 is referring to a bunch of people. I don't
21 believe [REDACTED] ever came to the island at
22 any time ever. I don't even know [REDACTED]
23 actually.¶

24 Q. Just one moment, I want to hear all
25 of them, but when you say you don't believe¶

1 G Maxwell - Confidential
2 [REDACTED] ever came to the island, do you know
3 whether [REDACTED] ever came to the island?¶

4 A. [REDACTED] never came to the island.¶

5 Q. How do you know that?¶

6 A. Jeffrey doesn't know him, I don't
7 know him and I think had [REDACTED] -- I don't
8 think -- had [REDACTED] gone to the island
9 during the period when I would have been
10 involved in organizing a trip, I would have
11 been aware of it.¶

12 Q. So go ahead, you had another one.¶

13 A. It would be easier if I could see,
14 do you mind if a take a reference at some of
15 these newspaper articles or you just want me
16 to go from memory.¶

17 Her entire characterization of what
18 took place in London at my house with [REDACTED]
19 [REDACTED]¶

20 Q. Was it an obvious lie that she was
21 at your house in London?¶

22 A. We can't really establish the
23 photograph and all that. I don't know if
24 that's true, if that's a real picture or not.¶

25 Q. So you dispute that you were¶

1 G Maxwell - Confidential
2 actually photographed in your town home in
3 London --¶

4 A. I don't recognize that picture.
5 I'm not sure if that's a real picture or not.¶

6 Q. And have you talked to [REDACTED]
7 [REDACTED] about that picture?¶

8 A. We discussed Virginia's entire tail
9 and he asked me if he even knew her.¶

10 Q. So did [REDACTED] tell you that
11 he did not have sex with [REDACTED]?¶

12 A. He doesn't even know who [REDACTED]
13 [REDACTED] is.¶

14 Q. Did he tell you that he didn't have
15 sex with her?¶

16 A. It would be difficult to have sex
17 with someone you don't know.¶

18 Q. He may not remember her?¶

19 A. I think the inference is he didn't
20 know who she was, he didn't have any
21 recollection of her whatsoever.¶

22 Q. Has [REDACTED] ever come to your
23 London town home?¶

24 A. Yes. Ever being the entire time I
25 owned my house, yes.¶

1 G Maxwell - Confidential
2 Can I go on on her obvious lies?¶

3 Q. If you have more.¶

4 A. I have -- her entire
5 characterization -- I took her shopping into
6 Burberry and bought her a very expensive
7 dress and if this photo were real and if this
8 is -- I would never -- the outfit doesn't
9 work at all so --¶

10 Q. Do you not remember taking her
11 shopping or are you saying it's an obvious
12 lie, you know you did not take her shopping?¶

13 A. I did not take her shopping. I did
14 not by her a $5,000 handbag.¶

15 Q. Did Jeffrey by her a $5,000
16 handbag?¶

17 A. Her accusation was that I did.¶

18 Q. Do you know if Jeffrey bought her a
19 handbag during that trip to London?¶

20 A. I don't know what he did. She
21 accused me, I can't physically remember
22 buying a $5,000 not for her, not for anyone,
23 not for me.¶

24 Q. Did you ever go shopping with
25 Virginia?¶

<p>Page 234</p> <p>1 G Maxwell - Confidential</p> <p>2 A. I don't recall ever shopping with</p> <p>3 Virginia.</p> <p>4 Q. Did you have more to go over or did</p> <p>5 you want me to ask my questions?</p> <p>6 A. The entire characterization of what</p> <p>7 took place in my house in London would have</p> <p>8 been impossible.</p> <p>9 Q. Can I ask, do you still have it,</p> <p>10 the picture of the London town home with you</p> <p>11 in it, [REDACTED] 00407.</p> <p>12 As you are looking at this picture,</p> <p>13 Ms. Maxwell, as I'm looking at it it's on the</p> <p>14 right-hand side, there appears to be a</p> <p>15 picture hanging on the wall, do you recall</p> <p>16 that in your London town home?</p> <p>17 A. It's a little difficult to see.</p> <p>18 Q. Do you recall having a picture on</p> <p>19 the wall there by the room where you're</p> <p>20 standing?</p> <p>21 A. I do have a picture.</p> <p>22 Q. Do you recall on the left-hand side</p> <p>23 having a railing that looks like that with</p> <p>24 sort of a bubble [REDACTED] top?</p> <p>25 A. I do.</p>	<p>Page 236</p> <p>1 G Maxwell - Confidential</p> <p>2 [REDACTED]. She characterized</p> <p>3 that [REDACTED].</p> <p>4 [REDACTED].</p> <p>5 She then characterized things took</p> <p>6 place in my bathroom in the bathtub itself.</p> <p>7 The tub is too small for any type of activity</p> <p>8 whatsoever.</p> <p>9 Q. [REDACTED]</p> <p>10 [REDACTED]</p> <p>11 [REDACTED]</p> <p>12 [REDACTED].</p> <p>13 Q. That would be [REDACTED]</p> <p>14 [REDACTED]</p> <p>15 A. Yes.</p> <p>16 Q. Are you saying that it was an</p> <p>17 obvious lie when Virginia said that you made</p> <p>18 her dress up in a school girl outfit?</p> <p>19 MR. PAGLIUCA: Objection to the</p> <p>20 form and foundation.</p> <p>21 A. I already testified that, first of</p> <p>22 all, I don't know what you are taking about,</p> <p>23 I already testified I didn't get her outfits</p> <p>24 and all of that.</p> <p>25 Q. Is it an obvious lie that Virginia</p>
<p>Page 235</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. So are you saying that it's an</p> <p>3 obvious lie that Virginia's statement that</p> <p>4 she had sex with [REDACTED] is an obvious</p> <p>5 lie?</p> <p>6 A. What I'm representing is that her</p> <p>7 entire ludicrous and absurd story of what</p> <p>8 took place in my house is an obvious lie.</p> <p>9 Q. Including she had sex with [REDACTED]</p> <p>10 [REDACTED]</p> <p>11 A. She claimed things took place in my</p> <p>12 bathroom in London. Her characterizations is</p> <p>13 just not possible.</p> <p>14 Q. So you're saying it's an obvious lie</p> <p>15 -- that she was telling an obvious lie</p> <p>16 when she said she had sex with [REDACTED]?</p> <p>17 MR. PAGLIUCA: Objection to the</p> <p>18 form and foundation. The witness</p> <p>19 answered the question.</p> <p>20 A. I'm saying within the context of</p> <p>21 all the stories she told, this particular</p> <p>22 story -- back up, she claimed we went out at</p> <p>23 night. [REDACTED]</p> <p>[REDACTED]</p>	<p>Page 237</p> <p>1 G Maxwell - Confidential</p> <p>2 was paid to go to give a massage to Glenn</p> <p>3 [REDACTED] at the Breakers?</p> <p>4 MR. PAGLIUCA: Objection to the</p> <p>5 form and foundation.</p> <p>6 A. I cannot testify to what Virginia</p> <p>7 did outside of -- I can't testify to what she</p> <p>8 did, who she gave massages to.</p> <p>9 Q. So you don't know on that one?</p> <p>10 A. Of course I don't know.</p> <p>11 Q. Do you agree that it's</p> <p>12 psychologically harmful to have sex with a</p> <p>13 minor?</p> <p>14 MR. PAGLIUCA: Objection to form</p> <p>15 and foundation.</p> <p>16 A. What are you asking me?</p> <p>17 Q. I'm asking if it is it psychologically</p> <p>18 harmful for an adult to have sex with a</p> <p>19 minor?</p> <p>20 MR. PAGLIUCA: Objection to the</p> <p>21 form and foundation.</p> <p>22 A. I don't know what you are asking.</p> <p>23 This has nothing to do with [REDACTED].</p> <p>24 Q. It does.</p> <p>25 A. How does it?</p>

Page 234 1 G Maxwell - Confidential 2 A. I don't recall ever shopping with 3 Virginia. 4 Q. Did you have more to go over or did 5 you want me to ask my questions? 6 A. The entire characterization of what 7 took place in my house in London would have 8 been impossible. 9 Q. Can I ask, do you still have it, 10 the picture of the London town home with you 11 in it, [REDACTED] 00407. 12 As you are looking at this picture, 13 Ms. Maxwell, as I'm looking at it it's on the 14 right-hand side, there appears to be a 15 picture hanging on the wall, do you recall 16 that in your London town home? 17 A. It's a little difficult to see. 18 Q. Do you recall having a picture on 19 the wall there by the room where you're 20 standing? 21 A. I do have a picture. 22 Q. Do you recall on the left-hand side 23 having a railing that looks like that with 24 sort of a bubble [REDACTED] top? 25 A. I do.

Page 236 1 G Maxwell - Confidential 2 [REDACTED]. She characterized 3 that [REDACTED]. 4 [REDACTED]. 5 She then characterized things took 6 place in my bathroom in the bathtub itself. 7 The tub is too small for any type of activity 8 whatsoever. 9 Q. [REDACTED] 10 [REDACTED] 11 [REDACTED] 12 [REDACTED]. 13 Q. That would be [REDACTED] 14 [REDACTED] 15 A. Yes. 16 Q. Are you saying that it was an 17 obvious lie when Virginia said that you made 18 her dress up in a school girl outfit? 19 MR. PAGLIUCA: Objection to the 20 form and foundation. 21 A. I already testified that, first of 22 all, I don't know what you are taking about, 23 I already testified I didn't get her outfits 24 and all of that. 25 Q. Is it an obvious lie that Virginia

Page 235 1 G Maxwell - Confidential 2 Q. So are you saying that it's an 3 obvious lie that Virginia's statement that 4 she had sex with [REDACTED] is an obvious 5 lie? 6 A. What I'm representing is that her 7 entire ludicrous and absurd story of what 8 took place in my house is an obvious lie. 9 Q. Including she had sex with [REDACTED] 10 [REDACTED] 11 A. She claimed things took place in my 12 bathroom in London. Her characterizations is 13 just not possible. 14 Q. So you're saying it's an obvious lie 15 -- that she was telling an obvious lie 16 when she said she had sex with [REDACTED]? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. The witness 19 answered the question. 20 A. I'm saying within the context of 21 all the stories she told, this particular 22 story -- back up, she claimed we went out at 23 night. [REDACTED] [REDACTED]

Page 237 1 G Maxwell - Confidential 2 was paid to go to give a massage to Glenn 3 [REDACTED] at the Breakers? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I cannot testify to what Virginia 7 did outside of -- I can't testify to what she 8 did, who she gave massages to. 9 Q. So you don't know on that one? 10 A. Of course I don't know. 11 Q. Do you agree that it's 12 psychologically harmful to have sex with a 13 minor? 14 MR. PAGLIUCA: Objection to form 15 and foundation. 16 A. What are you asking me? 17 Q. I'm asking if it is it psychologically 18 harmful for an adult to have sex with a 19 minor? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I don't know what you are asking. 23 This has nothing to do with [REDACTED]. 24 Q. It does. 25 A. How does it?

<p>Page 238</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. I ask the questions, you answer.</p> <p>3 If you can't answer, you can say I don't</p> <p>4 know.</p> <p>5 But my question is, do you agree</p> <p>6 that it's psychologically harmful to have sex</p> <p>7 with a minor?</p> <p>8 MR. PAGLIUCA: Objection to the</p> <p>9 form and foundation.</p> <p>10 A. Are you giving me a random question</p> <p>11 and as not relates to this case and not</p> <p>12 relates to anything. It's obviously not</p> <p>13 something that you want to have happen.</p> <p>14 Q. Do you agree that Jeffrey Epstein</p> <p>15 has harmed many minors by having sex with</p> <p>16 them?</p> <p>17 MR. PAGLIUCA: Objection to the</p> <p>18 form and foundation.</p> <p>19 A. I can't testify to what Jeffrey did</p> <p>20 or didn't do. I have no knowledge of what</p> <p>21 you are asking me.</p> <p>22 Q. If Jeffrey had sex with minors,</p> <p>23 would you agree that that could harm a minor?</p> <p>24 MR. PAGLIUCA: Object to the form</p> <p>25 and foundation.</p>	<p>Page 240</p> <p>1 G Maxwell - Confidential</p> <p>2 harm.</p> <p>3 MR. PAGLIUCA: Object to the form</p> <p>4 form and foundation.</p> <p>5 A. I would like to say all the</p> <p>6 terrible things [REDACTED] said about</p> <p>7 me is extremely harmful and you should turn</p> <p>8 that around. All the lies she has said and</p> <p>9 you have backed her on have been extremely</p> <p>10 damaging to me.</p> <p>11 So what I can testify to is that</p> <p>12 somebody who has made these outrageous</p> <p>13 allegations and who is a serious liar and</p> <p>14 that I know for a fact is a liar, that I can</p> <p>15 testify is damaging to me.</p> <p>16 Q. Do you agree that calling a sexual</p> <p>17 abuse victim a liar when she speaks out about</p> <p>18 her abuse can cause psychological harm?</p> <p>19 MR. PAGLIUCA: Are you asking a</p> <p>20 hypothetical question?</p> <p>21 MS. MCCAWLEY: Yes.</p> <p>22 A. You are asking me to speculate?</p> <p>23 Q. I'm not asking you to speculate .</p> <p>24 If somebody is a sexual abuse victim --</p> <p>25 A. I can't testify to what some random</p>
<p>Page 239</p> <p>1 G Maxwell - Confidential</p> <p>2 A. Again, I am not testifying to what</p> <p>3 Jeffrey did or did not do because I cannot.</p> <p>4 Q. You don't know whether Jeffrey</p> <p>5 Epstein ever had sex with a minor?</p> <p>6 A. Again, I cannot testify to what</p> <p>7 Jeffrey did or didn't do. I cannot.</p> <p>8 Q. You never observed him having sex</p> <p>9 with a minor?</p> <p>10 A. I never observed Jeffrey having sex</p> <p>11 with a minor.</p> <p>12 Q. Do you agree that calling a sex</p> <p>13 abuse victim a liar when she speaks about her</p> <p>14 abuse can cause psychological harm?</p> <p>15 MR. PAGLIUCA: Objection to the</p> <p>16 form and foundation.</p> <p>17 A. Can you repeat the question.</p> <p>18 Q. Do you agree calling a sex abuse</p> <p>19 victim when she speaks about her abuse can</p> <p>20 cause psychological harm?</p> <p>21 MR. PAGLIUCA: Objection to form</p> <p>22 and foundation.</p> <p>23 A. Say it again.</p> <p>24 Q. Do you agree that calling a sexual</p> <p>25 abuse victim a liar can cause psychological</p>	<p>Page 241</p> <p>1 G Maxwell - Confidential</p> <p>2 hypothetical person that you are asking me to</p> <p>3 speculate on their mental state or health</p> <p>4 versus speculative statement. I can't do</p> <p>5 that, that's just not right.</p> <p>6 Q. Do you agree that by calling</p> <p>7 [REDACTED] a liar when she was subject</p> <p>8 to sexual abuse by Jeffrey Epstein can cause</p> <p>9 psychological harm?</p> <p>10 MR. PAGLIUCA: Objection to the</p> <p>11 form and foundation. Assumes facts not</p> <p>12 in evidence.</p> <p>13 A. I can only tell you about what I</p> <p>14 know of Virginia's lies. She lied</p> <p>15 repeatedly, often and I know for a fact she</p> <p>16 is a liar so I can only testify to what I</p> <p>17 know and the fact that she has lied about me</p> <p>18 from the beginning to the end and repeatedly</p> <p>19 causes me to question anything that she may</p> <p>20 feel.</p> <p>21 Q. Is it an obvious lie you had sex</p> <p>22 toys in Jeffrey Epstein's Palm Beach house?</p> <p>23 MR. PAGLIUCA: Objection to the</p> <p>24 form and foundation.</p> <p>25 A. Can you repeat the question,</p>

Page 238 1 G Maxwell - Confidential 2 Q. I ask the questions, you answer. 3 If you can't answer, you can say I don't 4 know. 5 But my question is, do you agree 6 that it's psychologically harmful to have sex 7 with a minor? 8 MR. PAGLIUCA: Objection to the 9 form and foundation. 10 A. Are you giving me a random question 11 and as not relates to this case and not 12 relates to anything. It's obviously not 13 something that you want to have happen. 14 Q. Do you agree that Jeffrey Epstein 15 has harmed many minors by having sex with 16 them? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I can't testify to what Jeffrey did 20 or didn't do. I have no knowledge of what 21 you are asking me. 22 Q. If Jeffrey had sex with minors, 23 would you agree that that could harm a minor? 24 MR. PAGLIUCA: Object to the form 25 and foundation.

Page 240 1 G Maxwell - Confidential 2 harm. 3 MR. PAGLIUCA: Object to the form 4 form and foundation. 5 A. I would like to say all the 6 terrible things [REDACTED] said about 7 me is extremely harmful and you should turn 8 that around. All the lies she has said and 9 you have backed her on have been extremely 10 damaging to me. 11 So what I can testify to is that 12 somebody who has made these outrageous 13 allegations and who is a serious liar and 14 that I know for a fact is a liar, that I can 15 testify is damaging to me. 16 Q. Do you agree that calling a sexual 17 abuse victim a liar when she speaks out about 18 her abuse can cause psychological harm? 19 MR. PAGLIUCA: Are you asking a 20 hypothetical question? 21 MS. MCCAWLEY: Yes. 22 A. You are asking me to speculate? 23 Q. I'm not asking you to speculate . 24 If somebody is a sexual abuse victim -- 25 A. I can't testify to what some random

Page 239 1 G Maxwell - Confidential 2 A. Again, I am not testifying to what 3 Jeffrey did or did not do because I cannot. 4 Q. You don't know whether Jeffrey 5 Epstein ever had sex with a minor? 6 A. Again, I cannot testify to what 7 Jeffrey did or didn't do. I cannot. 8 Q. You never observed him having sex 9 with a minor? 10 A. I never observed Jeffrey having sex 11 with a minor. 12 Q. Do you agree that calling a sex 13 abuse victim a liar when she speaks about her 14 abuse can cause psychological harm? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. Can you repeat the question. 18 Q. Do you agree calling a sex abuse 19 victim when she speaks about her abuse can 20 cause psychological harm? 21 MR. PAGLIUCA: Objection to form 22 and foundation. 23 A. Say it again. 24 Q. Do you agree that calling a sexual 25 abuse victim a liar can cause psychological

Page 241 1 G Maxwell - Confidential 2 hypothetical person that you are asking me to 3 speculate on their mental state or health 4 versus speculative statement. I can't do 5 that, that's just not right. 6 Q. Do you agree that by calling 7 [REDACTED] a liar when she was subject 8 to sexual abuse by Jeffrey Epstein can cause 9 psychological harm? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. Assumes facts not 12 in evidence. 13 A. I can only tell you about what I 14 know of Virginia's lies. She lied 15 repeatedly, often and I know for a fact she 16 is a liar so I can only testify to what I 17 know and the fact that she has lied about me 18 from the beginning to the end and repeatedly 19 causes me to question anything that she may 20 feel. 21 Q. Is it an obvious lie you had sex 22 toys in Jeffrey Epstein's Palm Beach house? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. Can you repeat the question,

<p>Page 242</p> <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 Virginia say that? 9 Q. I'm asking you a question. 10 Is it an obvious lie that you had 11 sex toys in Jeffrey Epstein's house? 12 A. I don't recall any sex toys. 13 Q. If someone said had you sex toys, 14 would that be an obvious lie? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. Like I said -- can you be more 18 specific about the house or whatever, what 19 exactly you are referring to, what's a sex 20 toy? 21 Q. Yes. How would you define a sex 22 toy? 23 A. No. I need you to define a sex 24 toy, I don't have enough knowledge of sex 25 toys.</p>	<p>Page 244</p> <p>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.</p>
<p>Page 243</p> <p>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</p>	<p>Page 245</p> <p>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 242 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 Virginia say that?
9 Q. I'm asking you a question.
10 Is it an obvious lie that you had
11 sex toys in Jeffrey Epstein's house?
12 A. I don't recall any sex toys.
13 Q. If someone said had you sex toys,
14 would that be an obvious lie?
15 MR. PAGLIUCA: Objection to the
16 form and foundation.
17 A. Like I said -- can you be more
18 specific about the house or whatever, what
19 exactly you are referring to, what's a sex
20 toy?
21 Q. Yes. How would you define a sex
22 toy?
23 A. No. I need you to define a sex
24 toy, I don't have enough knowledge of sex
25 toys.

Page 244 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.

Page 243 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

Page 245 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

1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 lots of different types of people. In terms 2 of 18? 3 of whatever -- very small part of my job, 3 A. I think we can establish what adult 4 Jeffrey enjoyed getting massages. I think 4 would be. 5 that is something we can all agree in this 5 Q. You never interviewed or I know you 6 room and within the context of that, very 6 don't want to use the word hired, whatever 7 infrequently I would go to spas and myself 7 your role was, you brought in an exercise 8 happily receive a professional nonsexual 8 instructor that was under the age of IS to 9 massage from a man and/or from a woman and if 9 work at the house? 10 that massage was something that I thought was 10 MR. PAGLIUCA: Object to the form 11 something that was good. I would ask if that 11 and foundation. 12 man or woman would come back and does home 12 A. I have already testified that what 13 visits. If that person said that they did, 13 I was responsible for was to find people who 14 they would sometimes come, from time to time. 14 had competencies in whatever area I was 15 not always, come back to the house to perform 15 looking for. The competencies I was looking 16 a nonsexual professional male or female 16 for were professional and adult. 17 massage. 17 Q. So there was no exercise instructor 18 Q. Were any of the exercise 18 that worked at the Palm Beach house or the 20 A. Again, I don't hire, we've already 20 USVI under the age of 18? 21 established that I don't hire people. I 21 MR. PAGLIUCA: Objection to the 22 interview people to see if they are competent 22 form and foundation. 23 in the job that they do and/or whether they 23 A. I can only testify to when I was at 24 are someone who seemed that they can do home 24 the house. 25 visits. 25 Q. Yes.¶

19 instructors you hired under the age of 18? 19 New York house or the New Mexico house or the¶

1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 At the point where I think that 2 A. I can only testify to the years 3 there is somebody that has, can be either 3 when I was present. 4 whatever the job may be, pool, gardener, chef 4 Q. Right. 5 and/or exercise instructor and I think they 5 A. And I can also only testify to 7 skill that they had and they did a home visit 7 with and/or invited, to find the correct 8 which would obviously be mandatory and Mr. 8 word, I don't know what the correct word is. 9 Epstein would meet with them and decide if he 9 to come to do exercise or whatever it was at 10 wanted to have whatever skill it was that he 10 the house. 11 would do it and then he would then either 11 Of the people that I. male and/or 12 have them come back or hire them. 12 female that I brought were all appropriate 13 Q. Were there any exercise instructors 13 and age appropriate adults. 14 that worked at the home that were under the 14 Q. Over the age of 18? 15 age of 18? 15 A. We've established them as an adult. 16 MR. PAGLIUCA: Objection to the 16 Q. You are saying appropriate adults, 17 form and foundation. 17 so we are clear, you didn't him or bring in 18 A. Again, I keep coming back to this, 18 or know of any exercise instructors that were 19 that the people that I employed or -- not the 19 under the age of 18 at any of those homes? 20 right word, the people I would meet to come 20 A. I am also testifying that when I 21 and work at the house, under any guise 21 was present at the house and with the people 22 whatsoever, again, from any of the many 22 that I brought in, were all age appropriate 23 positions that I filled, were all over -- 23 adults. 24 were adults. 24 Q. How do you define age appropriate 25 Q. When you say adults, over the age 25 adults, is that over the age of 18, can we¶

6 could be good at whatever it is at whatever 6 people I personally either met and/or worked¶

<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 Virginia was 17 but you can be a 17 year 21 old legal masseuse, but I am not aware to 22 your point. 23 Q. Who were the other 17 year old 24 masseuses that you were aware of? 25 A. I am not aware of any.</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 Virginia now is 17, given she has changed her 10 age so many times. The only person that I am 11 aware of that was a masseuse at the time when 12 I was present in the house was Virginia. 13 Q. Is it an obvious lie that Jeffrey 14 Epstein had a sexual preference for underage 15 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>

Page 250 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 Virginia was 17 but you can be a 17 year
21 old legal masseuse, but I am not aware to
22 your point.
23 Q. Who were the other 17 year old
24 masseuses that you were aware of?
25 A. I am not aware of any.

Page 252 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,

Page 251 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 Virginia now is 17, given she has changed her
10 age so many times. The only person that I am
11 aware of that was a masseuse at the time when
12 I was present in the house was Virginia.
13 Q. Is it an obvious lie that Jeffrey
14 Epstein had a sexual preference for underage
15 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

Page 253 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

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 Virginia
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 Virginia was 17 and we have established that
16 her mother brought her to the house and that
17 she came as a masseuse, age 17, which is
18 legal in Florida.
19 Q. Would Jeffrey Epstein's assistants
20 arrange times for underage girls to come to
21 the house for sexual massages?
22 MR. PAGLIUCA: Objection to the
23 form and foundation.
24 A. What are you talking about?
25 Q. Sure. Would Jeffrey Ep [REDACTED]¶

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 of [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] 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 Q. During any period of time you
3 worked, did you observe that?
4 A. I did not observe any such
5 photographs.
6 Q. Are you aware if they took those
7 kinds of photos?
8 A. I am not aware.
9 MR. PAGLIUCA: Can we take a
10 five-minute break.
11 THE VIDEOGRAPHER: It's 2:58 and we
12 are off the record.
13 (Recess.)
14 THE VIDEOGRAPHER: It's now 3:10.
15 We're starting disk No. 6 and we are
16 back on the record.
17 Q. Ms. Maxwell, was it an obvious lie
18 when Virginia said she was sent to Thailand
19 by Epstein in September of 2002?
20 MR. PAGLIUCA: Objection to the
21 form and foundation.
22 A. I have no knowledge of Virginia
23 being sent to Thailand.
24 But may I say something?
25 Q. There is not a question pending¶

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 Virginia
6 said she was given instructions to maintain
7 telephone contact with you while she was in
8 Thailand?
9 MR. PAGLIUCA: Objection to the
10 form and foundation.
11 A. Can you repeat the question?
12 Q. Is it an obvious lie when Virginia
13 said she was given instructions to maintain
14 telephone contact with you when she was in
15 Thailand?
16 MR. PAGLIUCA: Same objection.
17 A. I have no idea what instructions
18 Virginia was given, if any, when she went to
19 Thailand.
20 Q. So you know she went to Thailand?
21 A. I know she claimed she went to
22 Thailand from having read it but given that
23 she lied about everything it's hard to know
24 what is true and not true.
25 Q. Would it make any sense for her to¶

Page 258 Page 260 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 G Maxwell - Confidential your cell phone number, is that number on this document? A. It is. Q. And do you know who authored this document? A. I do not. Q. Who i= document because I don't now what this A. I don't know who is on this document is. mil. Do you know someone by the name of A. I do know someone by the name of Would he know your phone number? MR. PAGLIUCA: Object to the form. A. I have to idea. Q. Why would Virginia be instructed to call Ms. Maxwell at your number on this form? MR. PAGLIUCA: Objection to the form and foundation. A. I don't know what this document is. I don't know when it was done, I don't know anything about it other than I can see it has¶

1 G Maxwell - Confidential 2 be in contact with you, would there be any 3 reason why she needed to be in contact with 4 you? 5 MR. PAGLIUCA: Objection to the 6 form and foundation. 7 A. When arc we talking about? 8 Q. When she went to Thailand. 9 MR. PAGLIUCA: Same objection. 10 Q. In 2002, would there be any reason 11 for her to remain in contact with you? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. Can you ask the question again, 15 please? 16 Q. Would there be any reason for 17 Virginia to maintain contact with you in 2002 18 when she went to Thailand? 19 MR. PAGLIUCA: Same objection. 20 A. First of all, I didn't know that 21 she went to Thailand. I had had nothing to 22 do with her trip to go to Thailand and there 23 would absolutely no reason for her to be in 24 touch with me, whatsoever. 25 Q. Did you ever have a phone number¶

Page 259 1 G Maxwell - Confidential 2 that wa. 3 A. I id. 4 Q. Was that a cell phone number? 5 A. Yes. 6 Q. Is that your current cell phone 7 number? 8 A. Yes. 9 Q. I'm going to mark a couple of 10 things here? 11 (Maxwell Exhibit II, photos, marked 12 for identification.) 13 THE WITNESS: Can I say something 14 now? 15 MR. PAGLIUCA: No. 16 THE WITNESS: Will you let me know 17 when I can? 18 MR. PAGLIUCA: When she asks you a 19 question: 20 Q. So we've marked this as Exhibit II. 21 I'm showingijahat's been marked as Exhibit 22 II which is 003191 and 003192. 23 Can you take a look at that 24 document for me. Is that number that you 25 just identified thel. as being¶

Page 261 1 G Maxwell - Confidential 2 my name and my number on it. 3 Q. Soil._ you said.-- is he 4 employed y r. Epstein? 5 A. Again, it is not the only one. 6 on the planet. 7 Q. I understand. 8 Do you know a. that is employed 9 by Mr. Epstein? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. Can you ask me the question again? 13 . Do you know someone by the name of 14 that was employed by Mr. Epstein back in 15 16 A. I do know somebod who was employed 17 by Mr. Epstein known as 18 Q. Do you recognize e other numbers 19 listed at the top of this document? 20 A. I do not. 21 Q. Would you have known 22 number at that time in 2002? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I have no idea. cell¶

<p>Page 262</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. Can I ask you to turn to the next</p> <p>3 page, please.</p> <p>4 Do you know who [REDACTED]</p> <p>5 is who is mentioned on this document?</p> <p>6 A. I do not.</p> <p>7 Q. If you look on the bottom lines of</p> <p>8 the document, it says, Still in Thailand</p> <p>9 during your stay, if she is, she will be</p> <p>10 staying at the same hotel.</p> <p>11 Do you recall ever giving Virginia</p> <p>12 instructions to meet a girl in Thailand?</p> <p>13 MR. PAGLIUCA: Objection to the</p> <p>14 form and foundation.</p> <p>15 A. I have already testified that I</p> <p>16 didn't even know that Virginia was going to</p> <p>17 Thailand.</p> <p>18 Q. So you didn't give her instructions</p> <p>19 to meet a girl in Thailand?</p> <p>20 A. Like I said, I didn't even know she</p> <p>21 was going to Thailand.</p> <p>22 Q. Do you know whether Jeffrey Epstein</p> <p>23 would have given her instructions to meet a</p> <p>24 girl in Thailand?</p> <p>25 MR. PAGLIUCA: Objection to the</p>	<p>Page 264</p> <p>1 G Maxwell - Confidential</p> <p>2 Q. The front form, the front page, do</p> <p>3 you recognize this Shopper Travel form, have</p> <p>4 you ever used them as a travel agent with</p> <p>5 Jeffrey Epstein?</p> <p>6 MR. PAGLIUCA: Same objection.</p> <p>7 Q. You can answer.</p> <p>8 A. I don't recognize this.</p> <p>9 Q. Turning to the second page which is</p> <p>10 the 00376, do you see at the top of that</p> <p>11 document where it says Jeffrey Epstein, J.</p> <p>12 Epstein 457 Madison Avenue 4th floor New York</p> <p>13 New York.</p> <p>14 Is that an address you are familiar</p> <p>15 with that is Jeffrey Epstein's?</p> <p>16 A. I am.</p> <p>17 Q. Do you see below that, travel on</p> <p>18 Singapore Airlines, and you are going to have</p> <p>19 to go from New York JFK to Singapore Bangkok.</p> <p>20 Do you see that?</p> <p>21 MR. PAGLIUCA: What?</p> <p>22 Q. The first entry is going to be on</p> <p>23 September 27, New York.</p> <p>24 MR. PAGLIUCA: I see it.</p> <p>25 MS. McCAWLEY: I'm not talking to</p>
<p>Page 263</p> <p>1 G Maxwell - Confidential</p> <p>2 form and foundation.</p> <p>3 A. I cannot possibly tell you what</p> <p>4 Jeffrey did or didn't do. I wouldn't know.</p> <p>5 Q. Do you know whether Jeffrey Epstein</p> <p>6 paid for Virginia to go to Thailand?</p> <p>7 A. Again, I wouldn't know if he did.</p> <p>8 (Maxwell Exhibit 12, documents,</p> <p>9 marked for identification)</p> <p>10 Q. I'm going to direct -- you can take</p> <p>11 a look at it and then I'm going to direct</p> <p>12 your attention to a couple of pages.</p> <p>13 MR. PAGLIUCA: So the record should</p> <p>14 be clear, this exhibit which is 12 is</p> <p>15 375, 6, 7, 8, 9, 80, 1, and then skips</p> <p>16 to 919, 920, 921, 922, 923, 924, 925 and</p> <p>17 926.</p> <p>18 Q. So I'm going to direct your</p> <p>19 attention to the first page, have you ever</p> <p>20 traveled with Jeffrey Epstein where you've</p> <p>21 received a document like this from Shoppers</p> <p>22 Travel in your own independent travel.</p> <p>23 Do you recognize this?</p> <p>24 MR. PAGLIUCA: Objection to the</p> <p>25 form and foundation.</p>	<p>Page 265</p> <p>1 G Maxwell - Confidential</p> <p>2 you. I'm talking to the witness.</p> <p>3 A. I see it.</p> <p>4 Q. To Singapore Bangkok?</p> <p>5 A. Singapore Bangkok I'm afraid are</p> <p>6 not the same place.</p> <p>7 Q. Singapore, then Bangkok:</p> <p>8 Q. I'm going to turn you to page</p> <p>9 [REDACTED], it's a little further back 000919.</p> <p>10 And do you see at the top where it says J.</p> <p>11 Epstein, underneath, [REDACTED] Princess, change</p> <p>12 mine?</p> <p>13 A. I do.</p> <p>14 Q. Does this refresh your recollection</p> <p>15 that [REDACTED] trip to Thailand was</p> <p>16 paid for by Jeffrey Epstein?</p> <p>17 MR. PAGLIUCA: Objection to the</p> <p>18 form and foundation.</p> <p>19 A. I can only testify to the piece of</p> <p>20 paper you showed me that has that</p> <p>21 information. I cannot testify from direct</p> <p>22 memory.</p> <p>23 Q. When Virginia was traveling to</p> <p>24 Thailand, which the dates, again, I'm going</p> <p>25 to refer you back to the first page so you</p>

Page 262 1 G Maxwell - Confidential 2 Q. Can I ask you to turn to the next 3 page, please. 4 Do you know who [REDACTED] 5 is who is mentioned on this document? 6 A. I do not. 7 Q. If you look on the bottom lines of 8 the document, it says, Still in Thailand 9 during your stay, if she is, she will be 10 staying at the same hotel. 11 Do you recall ever giving Virginia 12 instructions to meet a girl in Thailand? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I have already testified that I 16 didn't even know that Virginia was going to 17 Thailand. 18 Q. So you didn't give her instructions 19 to meet a girl in Thailand? 20 A. Like I said, I didn't even know she 21 was going to Thailand. 22 Q. Do you know whether Jeffrey Epstein 23 would have given her instructions to meet a 24 girl in Thailand? 25 MR. PAGLIUCA: Objection to the

Page 264 1 G Maxwell - Confidential 2 Q. The front form, the front page, do 3 you recognize this Shopper Travel form, have 4 you ever used them as a travel agent with 5 Jeffrey Epstein? 6 MR. PAGLIUCA: Same objection. 7 Q. You can answer. 8 A. I don't recognize this. 9 Q. Turning to the second page which is 10 the 00376, do you see at the top of that 11 document where it says Jeffrey Epstein, J. 12 Epstein 457 Madison Avenue 4th floor New York 13 New York. 14 Is that an address you are familiar 15 with that is Jeffrey Epstein's? 16 A. I am. 17 Q. Do you see below that, travel on 18 Singapore Airlines, and you are going to have 19 to go from New York JFK to Singapore Bangkok. 20 Do you see that? 21 MR. PAGLIUCA: What? 22 Q. The first entry is going to be on 23 September 27, New York. 24 MR. PAGLIUCA: I see it. 25 MS. McCAWLEY: I'm not talking to

Page 263 1 G Maxwell - Confidential 2 form and foundation. 3 A. I cannot possibly tell you what 4 Jeffrey did or didn't do. I wouldn't know. 5 Q. Do you know whether Jeffrey Epstein 6 paid for Virginia to go to Thailand? 7 A. Again, I wouldn't know if he did. 8 (Maxwell Exhibit 12, documents, 9 marked for identification) 10 Q. I'm going to direct -- you can take 11 a look at it and then I'm going to direct 12 your attention to a couple of pages. 13 MR. PAGLIUCA: So the record should 14 be clear, this exhibit which is 12 is 15 375, 6, 7, 8, 9, 80, 1, and then skips 16 to 919, 920, 921, 922, 923, 924, 925 and 17 926. 18 Q. So I'm going to direct your 19 attention to the first page, have you ever 20 traveled with Jeffrey Epstein where you've 21 received a document like this from Shoppers 22 Travel in your own independent travel. 23 Do you recognize this? 24 MR. PAGLIUCA: Objection to the 25 form and foundation.

Page 265 1 G Maxwell - Confidential 2 you. I'm talking to the witness. 3 A. I see it. 4 Q. To Singapore Bangkok? 5 A. Singapore Bangkok I'm afraid are 6 not the same place. 7 Q. Singapore, then Bangkok: 8 Q. I'm going to turn you to page 9 [REDACTED], it's a little further back 000919. 10 And do you see at the top where it says J. 11 Epstein, underneath, [REDACTED] Princess, change 12 mine? 13 A. I do. 14 Q. Does this refresh your recollection 15 that [REDACTED] trip to Thailand was 16 paid for by Jeffrey Epstein? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I can only testify to the piece of 20 paper you showed me that has that 21 information. I cannot testify from direct 22 memory. 23 Q. When Virginia was traveling to 24 Thailand, which the dates, again, I'm going 25 to refer you back to the first page so you

Page 266 Page 268 2 can see the dates. 2 MR. PAGLIUCA: Are you asking her 4 number, please. 4 asking her what her personal knowledge 6 . I'm going to refer you, 6 MS. McCAWLEY: I'm asking if she can 15 numbers on mine. That's 15 have a memory of the dates. I have a memory¶

1 G Maxwell - Confidential 1 G Maxwell - Confidential 3 MR. PAGLIUCA: Can you identify a 3 to compare the documents or are you 5 , which was at the top says, 5 is. 7 at t e same time, to the flight logs which 7 look at the doubts and tell me if she 8 were marked, the thicker document that looks 8 recalls that she traveling with 9 like this with all the log entries on it. 9 at the same time this 10 I'm going to refer you to page -- 10 •ocument ref ects Virginia was in 11 MR. PAGLIUCA: That's Exhibit No. 11 Thailand. 1.2 6, correct? I'm trying to keep the 12 A. I can't testify to any dates. I 13 record straight. 13 couldn't tell you. I can see a date and I 14 MS. McCAWLEY: I don't have Exhibit 14 can see a date but I can't tell you that I 16 MR. PAGLIUCA: Hang on one second. 16 of the trip, I don't have a memory of the 17 A. Can ou repeat the number please. 17 time. 18 Q. . And if you will look on 18 Q. Who is 19 that age at t entry, under 19 A. 20 starting with th and then it runs 20 Q. What is her address? 21 own to the, looks like t . that first 21 A. I don't know. 22 ent ha, 22 Q. Does she live in the United States.' 23 . Jef rey Epstein and the 23 A. She does. 24 mina s M. 24 Q. In what state? 25 Do you remember taking a trip with 25 A. I believe in New Jersey somewhere.¶

Page 267 Page 269 8 during, 8 ever asked other girls to come over to 10 sexual massage? 15 Epstein and at the same 15 Q. Has ever asked girls to 18 MR. PAGLIUCA: Objection to the 18 MR. PAGLIUCA: Object to form and 21 Q. If you look at on the 21 Q. Has ever asked girls to 25 group with 25 Q. What does do for you?¶

1 G Maxwell - Confidential 1 G Maxwell - Confidential 2 during 2 Q. Do you have her phone number? 3 IUCA: Jectton to e 3 A. Not memorized. 4 form and foundation. 4 Q. Do you have the ability to get her 5 A. Can you repeat the question, 5 phone number? 6 please? 6 A. Of course. 7 . Do ou remember takin a trip with 7 . Has she ever asked -- has 9 t at s t it woks like, through t o 9 see e hey Epstein for the purpose of a 10 .. 11 I don't remember the dates. I 11 MR. PAGLIUCA: Objection to the 12 couldn't testify to when we actually did it 12 form and foundation. 13 but I do remember the trip itself. 13 A. Can you ask the question again 14 Q. So you were travelin with Jeffrey 14 please. 16 time Virginia was ea e to ailand, is that 16 come over to see e rey Epstein for the 17 correct? 17 purpose of a sexual massage? 19 form and foundation. 19 foundation. 20 A. I don't know, is that ri ht? 20 A. Can ou ask a ain, please? 22 document that I gave you, e trst document 22 come over to seeJeffrey Epstein for the 23 and then you referred to, if you look in the 23 purpose of sexual massage? 24 same as above lines,you will see the travel 24 A. I have no personal knowledge.¶

1 G Maxwell - Confidential
2 A. She helps with my not-for-profit
3 ocean foundation and any other related
4 activities that I may have.
5 Q. Is she paid for by Jeffrey Epstein?
6 A. No.
7 Q. She is paid for by you?
8 A. Yes.
9 Q. When did you first meet [REDACTED]
10 [REDACTED]
11 A. I don't recollect exactly, sometime
12 maybe 2002, 2003.
13 Q. How did you meet her?
14 A. I don't recollect exactly how we
15 met.
16 Q. Did Jeffrey introduce you to her?
17 A. I don't recollect how we met.
18 Q. Does she know Jeffrey Epstein?
19 MR. PAGLIUCA: Objection to the
20 form and foundation.
21 A. Can you ask again, please?
22 Q. Does [REDACTED] know Jeffrey
23 Epstein?
24 A. What do you mean by know?
25 Q. Has she met her him before?¶

1 G Maxwell - Confidential
2 Q. Is it your testimony that [REDACTED]
3 [REDACTED] knows Jeffrey Epstein through the work
4 that she does for you?
5 MR. PAGLIUCA: Objection to the
6 form and foundation.
7 A. I don't recollect, and I don't
8 recollect how I met [REDACTED] and I can't testify
9 to what [REDACTED] relationship is or is not with
10 Jeffrey.
11 Q. Have you ever talked to Jeffrey
12 about [REDACTED]
13 A. I don't know what you mean.
14 Q. In any way, have you ever had a
15 conversation with Jeffrey about [REDACTED]
16 A. In what context.
17 Q. In any context. Have you ever
18 talked to Jeffrey Epstein about [REDACTED]
19 A. [REDACTED] works for me so it's entirely
20 possible that in the course of conversations
21 since 2002, 2003 that a conversation in which
22 [REDACTED] name would have come up is entirely
23 possible.
24 Q. I provided you with and I'm sorry,
25 I don't know all the numbers, but the¶

1 G Maxwell - Confidential
2 MR. PAGLIUCA: Objection to the
3 form and foundation.
4 A. I can't recollect a time when
5 [REDACTED] -- I've seen [REDACTED] with Jeffrey but --
6 Q. You are not sure --
7 A. I know they know either other. I
8 can't testify to a meeting between them.
9 Q. Do you know where in New Jersey she
10 lives?
11 A. No
12 Q. You don't know a city?
13 A. No.
14 Q. How long has she worked for you?
15 A. Sometime 2002, 2003.
16 Q. To the present?
17 A. Yeah.
18 Q. Why do you think that [REDACTED]
19 might know Jeffrey?
20 MR. PAGLIUCA: Objection to the
21 form and foundation.
22 A. Because you know, I know Jeffrey.
23 Q. Have you seen them together?
24 A. I already testified I have not seen
25 them together, to my recollection.¶

1 G Maxwell - Confidential
2 statement that was issued by [REDACTED] that
3 should be a single page still in your stack
4 of exhibits there.
5 MR. PAGLIUCA: Exhibit 10.
6 Q. Did you authorize [REDACTED] to issue
7 that statement on your behalf in January of
8 2015?
9 A. I already testified that that was
10 done by my lawyers.
11 Q. So did you authorize your lawyers
12 to issue a statement on your behalf through
13 [REDACTED] in January of 2015?
14 A. It was determined that I had to
15 make a statement in the United Kingdom
16 because of the appalling lies and I just
17 thought of some new ones.
18 Virginia's statement that I
19 celebrated her 16 birthday with her. We can
20 all agree that that's entirely impossible. I
21 didn't meet her until she was 17 and other
22 lies she perpetrated that she had a diary and
23 we all know is a complete fake. That's not a
24 diary. It was just a book she was writing
25 that you helped sell to the press, as if it¶

<p>Page 274</p> <p>1 G Maxwell - Confidential</p> <p>2 was a diary, when it was just a story that</p> <p>3 she is writing of fiction, fictional story</p> <p>4 for money.</p> <p>5 Q. How did you arrive at the words</p> <p>6 that were put in that statement?</p> <p>7 MR. PAGLIUCA: I'm going to object</p> <p>8 and instruct you to the extent this</p> <p>9 calls for any privileged communications</p> <p>10 between yourself and [REDACTED] or</p> <p>11 another lawyer representing you, we're</p> <p>12 asserting privilege. If you can answer</p> <p>13 that without that, feel free to answer.</p> <p>14 Q. So what your counsel is saying, and</p> <p>15 I will exclude any privileged communications</p> <p>16 you had with your lawyers.</p> <p>17 The question is, how did you arrive</p> <p>18 at the words that were put in that statement,</p> <p>19 if you can tell me without disclosing</p> <p>20 privileged communications?</p> <p>21 A. I'm not sure that I can.</p> <p>22 Q. Is the statement that you issued</p> <p>23 true?</p> <p>24 A. What do you mean by that?</p> <p>25 Q. Is the statement that you issued,</p>	<p>Page 276</p> <p>1 G Maxwell - Confidential</p> <p>2 A. I'm not sure I even understand your</p> <p>3 question.</p> <p>4 Q. I will go slower.</p> <p>5 Are you aware of any interstate,</p> <p>6 meaning between states, or international,</p> <p>7 meaning oversees transportation, of women</p> <p>8 aged 18 to 28, for the purposes of</p> <p>9 prostitution?</p> <p>10 MR. PAGLIUCA: Objection to the</p> <p>11 form and foundation.</p> <p>12 A. Are you asking -- I'm still not</p> <p>13 sure I understand the question.</p> <p>14 Q. I will try to make it clearer.</p> <p>15 I'm asking you if you are aware of</p> <p>16 any interstate, meaning between states, or</p> <p>17 international transportation, meaning by</p> <p>18 flight or by car or by train, of women aged</p> <p>19 18 to 28, their ages are between the ages of</p> <p>20 18 and 28, for the purposes of prostitution?</p> <p>21 MR. PAGLIUCA: Objection to the</p> <p>22 form and foundation.</p> <p>23 A. In the world I'm sure that that</p> <p>24 happens, I read about it all the time.</p> <p>25 Q. Not in the world. Are you aware of</p>
<p>Page 275</p> <p>1 G Maxwell - Confidential</p> <p>2 the statement that's in front of you, is it a</p> <p>3 true statement?</p> <p>4 A. As in that Virginia is a liar?</p> <p>5 Q. The words you put in there, is that</p> <p>6 true?</p> <p>7 A. Of course they're true.</p> <p>8 Q. When did you become aware that the</p> <p>9 statement was being released?</p> <p>10 A. I don't recollect exactly.</p> <p>11 Q. What day it was?</p> <p>12 A. No.</p> <p>13 Q. I'm sorry. Did you identify, I</p> <p>14 might not have caught it, did you identify</p> <p>15 the name of the lawyer that you said you</p> <p>16 retained for purposes of this statement?</p> <p>17 A. I think [REDACTED].</p> <p>18 Q. Did you pay that lawyer [REDACTED]</p> <p>19 [REDACTED]</p> <p>20 A. Yes.</p> <p>21 Q. Are you aware of any interstate or</p> <p>22 international transportation of a woman aged</p> <p>23 18 to 28 for the purposes of prostitution?</p> <p>24 MR. PAGLIUCA: Objection to the</p> <p>25 form and foundation.</p>	<p>Page 277</p> <p>1 G Maxwell - Confidential</p> <p>2 it, in your experience with Jeffrey Epstein,</p> <p>3 of any interstate or international</p> <p>4 transportation of women aged 18 to 28, for</p> <p>5 the purposes of prostitution?</p> <p>6 MR. PAGLIUCA: Objection to the</p> <p>7 form and foundation.</p> <p>8 A. So whilst I appreciate this might</p> <p>9 not seem like a smart question, what do you</p> <p>10 mean by prostitution, what are you asking me</p> <p>11 exactly?</p> <p>12 Q. That would be sex for hire, any</p> <p>13 kind of sexual act that's paid for.</p> <p>14 MR. PAGLIUCA: Objection to the</p> <p>15 form and foundation.</p> <p>16 A. Who's paying, what are you asking</p> <p>17 me.</p> <p>18 Q. It can be paid for by anybody.</p> <p>19 It's a sexual act that's paid for.</p> <p>20 I'm asking if you are aware of any</p> <p>21 interstate or international transportation of</p> <p>22 women aged 18 to 28, for the purposes of</p> <p>23 prostitution?</p> <p>24 MR. PAGLIUCA: Objection to the</p> <p>25 form and foundation.</p>

Page 274 1 G Maxwell - Confidential 2 was a diary, when it was just a story that 3 she is writing of fiction, fictional story 4 for money. 5 Q. How did you arrive at the words 6 that were put in that statement? 7 MR. PAGLIUCA: I'm going to object 8 and instruct you to the extent this 9 calls for any privileged communications 10 between yourself and [REDACTED] or 11 another lawyer representing you, we're 12 asserting privilege. If you can answer 13 that without that, feel free to answer. 14 Q. So what your counsel is saying, and 15 I will exclude any privileged communications 16 you had with your lawyers. 17 The question is, how did you arrive 18 at the words that were put in that statement, 19 if you can tell me without disclosing 20 privileged communications? 21 A. I'm not sure that I can. 22 Q. Is the statement that you issued 23 true? 24 A. What do you mean by that? 25 Q. Is the statement that you issued,

Page 276 1 G Maxwell - Confidential 2 A. I'm not sure I even understand your 3 question. 4 Q. I will go slower. 5 Are you aware of any interstate, 6 meaning between states, or international, 7 meaning oversees transportation, of women 8 aged 18 to 28, for the purposes of 9 prostitution? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. Are you asking -- I'm still not 13 sure I understand the question. 14 Q. I will try to make it clearer. 15 I'm asking you if you are aware of 16 any interstate, meaning between states, or 17 international transportation, meaning by 18 flight or by car or by train, of women aged 19 18 to 28, their ages are between the ages of 20 18 and 28, for the purposes of prostitution? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. In the world I'm sure that that 24 happens, I read about it all the time. 25 Q. Not in the world. Are you aware of

Page 275 1 G Maxwell - Confidential 2 the statement that's in front of you, is it a 3 true statement? 4 A. As in that Virginia is a liar? 5 Q. The words you put in there, is that 6 true? 7 A. Of course they're true. 8 Q. When did you become aware that the 9 statement was being released? 10 A. I don't recollect exactly. 11 Q. What day it was? 12 A. No. 13 Q. I'm sorry. Did you identify, I 14 might not have caught it, did you identify 15 the name of the lawyer that you said you 16 retained for purposes of this statement? 17 A. I think [REDACTED]. 18 Q. Did you pay that lawyer [REDACTED] 19 [REDACTED] 20 A. Yes. 21 Q. Are you aware of any interstate or 22 international transportation of a woman aged 23 18 to 28 for the purposes of prostitution? 24 MR. PAGLIUCA: Objection to the 25 form and foundation.

Page 277 1 G Maxwell - Confidential 2 it, in your experience with Jeffrey Epstein, 3 of any interstate or international 4 transportation of women aged 18 to 28, for 5 the purposes of prostitution? 6 MR. PAGLIUCA: Objection to the 7 form and foundation. 8 A. So whilst I appreciate this might 9 not seem like a smart question, what do you 10 mean by prostitution, what are you asking me 11 exactly? 12 Q. That would be sex for hire, any 13 kind of sexual act that's paid for. 14 MR. PAGLIUCA: Objection to the 15 form and foundation. 16 A. Who's paying, what are you asking 17 me. 18 Q. It can be paid for by anybody. 19 It's a sexual act that's paid for. 20 I'm asking if you are aware of any 21 interstate or international transportation of 22 women aged 18 to 28, for the purposes of 23 prostitution? 24 MR. PAGLIUCA: Objection to the 25 form and foundation.

<p>Page 278</p> <p>1 G Maxwell - Confidential</p> <p>2 A. I have no idea what you are talking</p> <p>3 about.</p> <p>4 Q. So you are not aware of that?</p> <p>5 A. No.</p> <p>6 Q. Are you aware of any interstate or</p> <p>7 international transportation of women, aged</p> <p>8 18 to 28, for the purposes of having sex with</p> <p>9 Epstein where they would receive compensation</p> <p>10 of any type?</p> <p>11 MR. PAGLIUCA: Objection to the</p> <p>12 form and foundation.</p> <p>13 A. I don't know what you are referring</p> <p>14 to.</p> <p>15 Q. Do you want me to repeat the</p> <p>16 question?</p> <p>17 A. Sure, go ahead.</p> <p>18 Q. Are you aware of any interstate or</p> <p>19 international transportation of woman, aged</p> <p>20 18 to 28, for the purpose of having sex with</p> <p>21 Jeffrey Epstein where they would receive</p> <p>22 compensation of any type?</p> <p>23 MR. PAGLIUCA: Objection to form</p> <p>24 and foundation.</p> <p>25 A. I am not aware of what you are</p>	<p>Page 280</p> <p>1 G Maxwell - Confidential</p> <p>2 Epstein?</p> <p>3 MR. PAGLIUCA: Objection to the</p> <p>4 form and foundation.</p> <p>5 A. Again, I'm not aware of anybody</p> <p>6 that, if you are asking for specifics to</p> <p>7 someone else, I have no knowledge of that.</p> <p>8 Q. So you are not aware of any</p> <p>9 interstate or international transportation of</p> <p>10 a woman aged 18 to 28 for the purposes of</p> <p>11 providing a massage to any person other than</p> <p>12 Jeffrey Epstein?</p> <p>13 MR. PAGLIUCA: Objection to the</p> <p>14 form and foundation.</p> <p>15 A. I don't recall what any single</p> <p>16 person being on a plane for a massage with</p> <p>17 someone else other than Jeffrey, for the sole</p> <p>18 purpose, if that's the question, I don't have</p> <p>19 any recollection of that.</p> <p>20 Q. Earlier in your testimony, you</p> <p>21 stated that [REDACTED] was 17 at the</p> <p>22 time you met her.</p> <p>23 How do you know she was 17?</p> <p>24 MR. PAGLIUCA: Objection to the</p> <p>25 form and foundation. And to the extent</p>
<p>Page 279</p> <p>1 G Maxwell - Confidential</p> <p>2 talking about.</p> <p>3 Q. Are you aware of any interstate or</p> <p>4 international transportation of women, aged</p> <p>5 18 to 28, for the purposes of providing a</p> <p>6 massage for Jeffrey Epstein?</p> <p>7 MR. PAGLIUCA: Objection to the</p> <p>8 form and foundation.</p> <p>9 A. So I you need to repeat that</p> <p>10 question for me.</p> <p>11 Q. Sure.</p> <p>12 Are you aware of any interstate,</p> <p>13 meaning between states, or international,</p> <p>14 oversees, transportation of women, aged 18 to</p> <p>15 28, for the purposes of providing massage for</p> <p>16 Jeffrey Epstein?</p> <p>17 MR. PAGLIUCA: Objection to the</p> <p>18 form and foundation.</p> <p>19 A. I think we can agree he did travel</p> <p>20 from time to time with a professional adult</p> <p>21 masseuse.</p> <p>22 Q. Are you aware of any interstate or</p> <p>23 international transportation of women, aged</p> <p>24 18 to 28, for the purposes of providing a</p> <p>25 massage to any person other than Jeffrey</p>	<p>Page 281</p> <p>1 G Maxwell - Confidential</p> <p>2 that calls for a privileged response,</p> <p>3 I'm instructing you not to answer.</p> <p>4 Q. How do you know [REDACTED]</p> <p>5 was 17 at the time you met her?</p> <p>6 MR. PAGLIUCA: Again, if you</p> <p>7 learned that information from your</p> <p>8 lawyer, I'm instructing you not to</p> <p>9 answer.</p> <p>10 A. I will follow my counsel's advice.</p> <p>11 Q. Are you able to answer that</p> <p>12 question without telling me information you</p> <p>13 learned from a lawyer?</p> <p>14 A. I'm not.</p> <p>15 Q. So you don't have independent</p> <p>16 knowledge that Virginia, according to your</p> <p>17 statement, that, was 17 at the time you met her?</p> <p>18 A. Again, my lawyer has instructed me</p> <p>19 not to answer.</p> <p>20 Q. I'm asking you a different</p> <p>21 question. Whether you have any independent</p> <p>22 knowledge, outside your lawyers, that</p> <p>23 Virginia was 17 at the time you met her?</p> <p>24 A. Following the instructions of my</p> <p>25 lawyers, I can only remember or testify to</p>

Page 278 1 G Maxwell - Confidential 2 A. I have no idea what you are talking 3 about. 4 Q. So you are not aware of that? 5 A. No. 6 Q. Are you aware of any interstate or 7 international transportation of women, aged 8 18 to 28, for the purposes of having sex with 9 Epstein where they would receive compensation 10 of any type? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I don't know what you are referring 14 to. 15 Q. Do you want me to repeat the 16 question? 17 A. Sure, go ahead. 18 Q. Are you aware of any interstate or 19 international transportation of woman, aged 20 18 to 28, for the purpose of having sex with 21 Jeffrey Epstein where they would receive 22 compensation of any type? 23 MR. PAGLIUCA: Objection to form 24 and foundation. 25 A. I am not aware of what you are

Page 280 1 G Maxwell - Confidential 2 Epstein? 3 MR. PAGLIUCA: Objection to the 4 form and foundation. 5 A. Again, I'm not aware of anybody 6 that, if you are asking for specifics to 7 someone else, I have no knowledge of that. 8 Q. So you are not aware of any 9 interstate or international transportation of 10 a woman aged 18 to 28 for the purposes of 11 providing a massage to any person other than 12 Jeffrey Epstein? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I don't recall what any single 16 person being on a plane for a massage with 17 someone else other than Jeffrey, for the sole 18 purpose, if that's the question, I don't have 19 any recollection of that. 20 Q. Earlier in your testimony, you 21 stated that [REDACTED] was 17 at the 22 time you met her. 23 How do you know she was 17? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. And to the extent

Page 279 1 G Maxwell - Confidential 2 talking about. 3 Q. Are you aware of any interstate or 4 international transportation of women, aged 5 18 to 28, for the purposes of providing a 6 massage for Jeffrey Epstein? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. So I you need to repeat that 10 question for me. 11 Q. Sure. 12 Are you aware of any interstate, 13 meaning between states, or international, 14 oversees, transportation of women, aged 18 to 15 28, for the purposes of providing massage for 16 Jeffrey Epstein? 17 MR. PAGLIUCA: Objection to the 18 form and foundation. 19 A. I think we can agree he did travel 20 from time to time with a professional adult 21 masseuse. 22 Q. Are you aware of any interstate or 23 international transportation of women, aged 24 18 to 28, for the purposes of providing a 25 massage to any person other than Jeffrey

Page 281 1 G Maxwell - Confidential 2 that calls for a privileged response, 3 I'm instructing you not to answer. 4 Q. How do you know [REDACTED] 5 was 17 at the time you met her? 6 MR. PAGLIUCA: Again, if you 7 learned that information from your 8 lawyer, I'm instructing you not to 9 answer. 10 A. I will follow my counsel's advice. 11 Q. Are you able to answer that 12 question without telling me information you 13 learned from a lawyer? 14 A. I'm not. 15 Q. So you don't have independent 16 knowledge that Virginia, according to your 17 statement, that, was 17 at the time you met her? 18 A. Again, my lawyer has instructed me 19 not to answer. 20 Q. I'm asking you a different 21 question. Whether you have any independent 22 knowledge, outside your lawyers, that 23 Virginia was 17 at the time you met her? 24 A. Following the instructions of my 25 lawyers, I can only remember or testify to

<p>Page 282</p> <p>1 G Maxwell - Confidential</p> <p>2 what she --</p> <p>3 MR. PAGLIUCA: She is asking you a</p> <p>4 different question. She is asking other</p> <p>5 than what your lawyers have told you, do</p> <p>6 you have any knowledge about her being</p> <p>7 17, that's what she is asking.</p> <p>8 A. I can't recollect where I got all</p> <p>9 the information that I have that definitively</p> <p>10 shows that.</p> <p>11 Q. Earlier in your testimony, I</p> <p>12 believe you said all of us would know that</p> <p>13 Virginia was 17 at the time you met her.</p> <p>14 How would we know that?</p> <p>15 A. I think you know that by her own</p> <p>16 dates, now that it was in 2000, so her entire</p> <p>17 tail of me celebrating her 16th birthday is</p> <p>18 clearly another giant falsehood.</p> <p>19 Q. But she was 16 and 17 that year,</p> <p>20 wasn't she?</p> <p>21 A. Which year?</p> <p>22 Q. You said it was 2000.</p> <p>23 A. I think the information that I have</p> <p>24 that indicates that definitively was</p> <p>25 something that is privileged, so I can't</p>	<p>Page 284</p> <p>1 G Maxwell - Confidential</p> <p>2 calls for a communication that you had</p> <p>3 with one of your lawyers, I'm</p> <p>4 instructing you not to answer that</p> <p>5 question.</p> <p>6 Q. I assume you, as part of the</p> <p>7 discovery process, had to collect documents</p> <p>8 that were relevant to this action, is that</p> <p>9 correct?</p> <p>10 A. I did.</p> <p>11 Q. Did you collect documents that</p> <p>12 would show that Virginia was 17 at the time</p> <p>13 that you met her?</p> <p>14 A. I think you have everything that</p> <p>15 relates, that I had, contemporaneously per</p> <p>16 what you asked for that I have that relates</p> <p>17 to that.</p> <p>18 Q. Did you have a document that</p> <p>19 identified that Virginia was 17 at the time</p> <p>20 that you met her?</p> <p>21 A. You have all of the documents that</p> <p>22 I had.</p> <p>23 Q. I'm not asking what documents. I'm</p> <p>24 asking, do you have a document that</p> <p>25 identifies Virginia being 17 at the time you</p>
<p>Page 283</p> <p>1 G Maxwell - Confidential</p> <p>2 share with you.</p> <p>3 Q. So you have privileged information</p> <p>4 that definitively tells you that she was 17</p> <p>5 at the time you met her?</p> <p>6 A. I believe I do.</p> <p>7 Q. How would we know that?</p> <p>8 A. What are you asking me?</p> <p>9 Q. Earlier today you testified that we</p> <p>10 would know that she was 17 at the time that</p> <p>11 you met her.</p> <p>12 How would we know that?</p> <p>13 A. I imagine you have access to</p> <p>14 exactly the same information that I do.</p> <p>15 Q. What is that information?</p> <p>16 A. Again, it's privileged, I can't</p> <p>17 share it with you but you have been on this</p> <p>18 case for, I don't know, much much longer than</p> <p>19 I have and I imagine you have all the</p> <p>20 information that I do.</p> <p>21 Q. Do you know whether your lawyers</p> <p>22 have produced documents from you that would</p> <p>23 show the age that Virginia was at the time</p> <p>24 that you met her?</p> <p>25 MR. PAGLIUCA: To the extent that</p>	<p>Page 285</p> <p>1 G Maxwell - Confidential</p> <p>2 met her?</p> <p>3 A. You have every document that I</p> <p>4 have. You have seen every document that I</p> <p>5 have.</p> <p>6 Q. That's not what I'm asking.</p> <p>7 A. I don't recall every document that</p> <p>8 I gave you, so I don't know. I would have to</p> <p>9 look at every single document I gave you and</p> <p>10 then review it but as I recall you have every</p> <p>11 document that I have.</p> <p>12 Q. What are you planning to show the</p> <p>13 jury that will prove that Virginia was 17</p> <p>14 when you met her?</p> <p>15 A. Again that's privileged so I can't</p> <p>16 share that with you.</p> <p>17 Q. If you're showing the jury, it</p> <p>18 wouldn't be privileged, so is there a</p> <p>19 document you have produced in this matter</p> <p>20 that shows that Virginia was 17 at the time</p> <p>21 you met her?</p> <p>22 MR. PAGLIUCA: She answered that</p> <p>23 question already. She said she doesn't</p> <p>24 know, she has given you everything. If</p> <p>25 there is a decision -- assuming for the</p>

Page 282 1 G Maxwell - Confidential 2 what she -- 3 MR. PAGLIUCA: She is asking you a 4 different question. She is asking other 5 than what your lawyers have told you, do 6 you have any knowledge about her being 7 17, that's what she is asking. 8 A. I can't recollect where I got all 9 the information that I have that definitively 10 shows that. 11 Q. Earlier in your testimony, I 12 believe you said all of us would know that 13 Virginia was 17 at the time you met her. 14 How would we know that? 15 A. I think you know that by her own 16 dates, now that it was in 2000, so her entire 17 tail of me celebrating her 16th birthday is 18 clearly another giant falsehood. 19 Q. But she was 16 and 17 that year, 20 wasn't she? 21 A. Which year? 22 Q. You said it was 2000. 23 A. I think the information that I have 24 that indicates that definitively was 25 something that is privileged, so I can't

Page 284 1 G Maxwell - Confidential 2 calls for a communication that you had 3 with one of your lawyers, I'm 4 instructing you not to answer that 5 question. 6 Q. I assume you, as part of the 7 discovery process, had to collect documents 8 that were relevant to this action, is that 9 correct? 10 A. I did. 11 Q. Did you collect documents that 12 would show that Virginia was 17 at the time 13 that you met her? 14 A. I think you have everything that 15 relates, that I had, contemporaneously per 16 what you asked for that I have that relates 17 to that. 18 Q. Did you have a document that 19 identified that Virginia was 17 at the time 20 that you met her? 21 A. You have all of the documents that 22 I had. 23 Q. I'm not asking what documents. I'm 24 asking, do you have a document that 25 identifies Virginia being 17 at the time you

Page 283 1 G Maxwell - Confidential 2 share with you. 3 Q. So you have privileged information 4 that definitively tells you that she was 17 5 at the time you met her? 6 A. I believe I do. 7 Q. How would we know that? 8 A. What are you asking me? 9 Q. Earlier today you testified that we 10 would know that she was 17 at the time that 11 you met her. 12 How would we know that? 13 A. I imagine you have access to 14 exactly the same information that I do. 15 Q. What is that information? 16 A. Again, it's privileged, I can't 17 share it with you but you have been on this 18 case for, I don't know, much much longer than 19 I have and I imagine you have all the 20 information that I do. 21 Q. Do you know whether your lawyers 22 have produced documents from you that would 23 show the age that Virginia was at the time 24 that you met her? 25 MR. PAGLIUCA: To the extent that

Page 285 1 G Maxwell - Confidential 2 met her? 3 A. You have every document that I 4 have. You have seen every document that I 5 have. 6 Q. That's not what I'm asking. 7 A. I don't recall every document that 8 I gave you, so I don't know. I would have to 9 look at every single document I gave you and 10 then review it but as I recall you have every 11 document that I have. 12 Q. What are you planning to show the 13 jury that will prove that Virginia was 17 14 when you met her? 15 A. Again that's privileged so I can't 16 share that with you. 17 Q. If you're showing the jury, it 18 wouldn't be privileged, so is there a 19 document you have produced in this matter 20 that shows that Virginia was 17 at the time 21 you met her? 22 MR. PAGLIUCA: She answered that 23 question already. She said she doesn't 24 know, she has given you everything. If 25 there is a decision -- assuming for the

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 [REDACTED], I asked you whether you had
25 ever given him a gift of a puppet.¶

1 G Maxwell - Confidential
2 Did you ever, not as a gift, did
3 you ever see in the presence of [REDACTED]
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 [REDACTED] 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 [REDACTED]
17 [REDACTED] 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¶

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 [REDACTED]
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 [REDACTED]
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¶

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?
[REDACTED]
10 Q. Yes.
11 Have you seen any puppet that fits
12 any description in the presence of [REDACTED]
13 [REDACTED] 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 [REDACTED] 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                      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 [REDACTED].
10                      Q. Do you recollect asking Virginia
11                      [REDACTED] to sit on [REDACTED] lap with
12                      the caricature of [REDACTED]
13                      A. I do not recollect that.
14                      Q. What do you remember about the
15                      caricature of the [REDACTED] caricature
16                      when you were in the presence of [REDACTED]
17                      [REDACTED], [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 Virginia. I don't even know
22                      who -- I remember the caricature of [REDACTED]
23                      [REDACTED] and I remember [REDACTED] 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 [REDACTED]
14                      arrival?
15                      A. Again, I don't real -- I recollect
16                      the caricature, I recollect [REDACTED], 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                      [REDACTED] being there. Do you recollect
4                      a party going on at the time of that
5                      interaction with [REDACTED] 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 [REDACTED] was there
16                      with this caricature?
17                      MR. PAGLIUCA: Objection to the
18                      form and foundation.
19                      A. I only recollect myself with [REDACTED]
20                      [REDACTED], 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 Virginia
4                      [REDACTED] being there?
5                      A. No.
6                      Q. It was just you and [REDACTED]
7                      A. I am not saying it was just me and
8                      [REDACTED], you are asking me do you
9                      remember. I only remember [REDACTED], I
10                      remember [REDACTED] and the caricature but
11                      I can't place the caricature and everybody
12                      else in the same context, the same timeframe
13                      you are asking me.
14                      Q. [REDACTED]
15                      [REDACTED]
16                      [REDACTED]
17                      [REDACTED]
18                      [REDACTED]
19                      [REDACTED]
20                      [REDACTED]
21                      [REDACTED]
22                      [REDACTED]
23                      [REDACTED]
24                      [REDACTED]
25                      MR. PAGLIUCA: Objection to the
form and foundation.¶

Page 294¶

1 G Maxwell - Confidential¶

2 A. Typically, there is no typical¶

3 because there is no standard procedure, so I¶

4 can't comment or testify to [REDACTED].¶

5 [REDACTED].¶

6 Q. Do you remember them being in the¶

7 house?¶

8 A. Not specifically.¶

9 Do you mind if I take a bathroom¶

10 break.¶

11 THE VIDEOGRAPHER: It's now 3:51¶

12 and we are off the record.¶

13 (Recess.)¶

14 THE VIDEOGRAPHER: It's now 4:04.¶

15 We are back on the record and we're¶

16 starting disk No. 7.¶

17 Q. Ms. Maxwell, during what time¶

18 period, I know you said, I believe you said¶

19 you met Jeffrey in 1991, if I'm correct there¶

20 and you've known him through the present.¶

21 During what time period within¶

22 those years would you say your relationship¶

23 was the closest with Jeffrey?¶

24 MR. PAGLIUCA: Objection to the¶

25 form and foundation.¶

Page 295¶

1 G Maxwell - Confidential¶

2 A. What do you mean by close, sorry.¶

3 Q. I think earlier today you testified¶

4 that at some point in time you considered¶

5 yourself to be his girlfriend, is that the¶

6 closest you would say that your relationship¶

7 was with him and if so, what time period was¶

8 that?¶

9 MR. PAGLIUCA: Objection to the¶

10 form and foundation.¶

11 A. I don't think I said I was his¶

12 girlfriend, I would like to think of myself¶

13 as maybe, I don't think I -- sometime in the¶

14 mid '90s.¶

15 Q. How close was your relationship?¶

16 A. We were very friendly.¶

17 Q. Without going into details, was¶

18 your relationship with him intimate?¶

19 A. Yes.¶

20 Q. When was the last time you had¶

21 contact with Jeffrey Epstein?¶

22 A. What do you mean by contact.¶

23 Q. Either a phone call or email or¶

24 anything of that nature?¶

25 A. As best as I can recollect when¶

Page 296¶

1 G Maxwell - Confidential¶

2 all -- sometime last year.¶

3 Q. So you haven't talked to him like,¶

4 for example, last week you didn't talk to¶

5 him?¶

6 A. I did not.¶

7 Q. How many times have you had either¶

8 direct or indirect, meaning, in the presence¶

9 of him or calling or emailing, contact with¶

10 Jeffrey Epstein from December 30, 2014 until¶

11 now?¶

12 A. I'm sorry, can you just --¶

13 Q. Either in person or by phone or by¶

14 email, from December 30, 2014 until present.¶

15 A. I can't really characterize that¶

16 but not very much. There was a period when¶

17 in January when you filed your, whatever you¶

18 filed, where we spoke and then, since then¶

19 not much at all.¶

20 Q. Can you estimate how many emails¶

21 you would have sent Jeffrey from the period¶

22 of December 30, 2014 to the present?¶

23 A. Not very many at all.¶

24 Q. More than 20?¶

25 A. I really wouldn't be able to¶

Page 297¶

1 G Maxwell - Confidential¶

2 characterize it because it wouldn't be that¶

3 many. I wouldn't know.¶

4 Q. More than 50?¶

5 A. It would be on the lesser side, not¶

6 on the more side.¶

7 Q. Can you give me a number?¶

8 A. I honestly couldn't. I would be¶

9 guessing.¶

10 Q. How many emails has Jeffrey sent¶

11 you from the period December 30, 2014 to the¶

12 present?¶

13 A. I would say less emails, even less¶

14 emails than I sent him.¶

15 Q. More than 20?¶

16 A. I would say on the lesser side.¶

17 Q. Less meaning 10?¶

18 A. I really can't recall, very little.¶

19 Q. When you spoke with Jeffrey in¶

20 January of 2015, what did he say to you?¶

21 A. I really couldn't remember exactly¶

22 what he said to me.¶

23 Q. Did you talk about Virginia¶

24 [REDACTED]?¶

25 A. I'm sure we did but I couldn't¶

<p>Page 298</p> <p>1 G Maxwell - Confidential 2 recall the exact conversation. 3 Q. Does Jeffrey Epstein send you text 4 messages? 5 A. No. 6 Q. Do you send him text messages? 7 A. No. 8 Q. How many phone calls have you had 9 with Jeffrey Epstein since December 30, 2014? 10 A. Again, very few. 11 Q. More than five? 12 A. Probably as many as the few emails 13 that I would characterize, so just very few. 14 I mean a small number. 15 Q. Are you aware of any disagreement 16 between your views about [REDACTED] and 17 Jeffrey's views about [REDACTED]? 18 MR. PAGLIUCA: Object to the form 19 and foundation 20 A. I cannot speculate to his views. I 21 can only testify on my views. 22 Q. Earlier you went through the series 23 of lies. Have you talked to Jeffrey about 24 the lies and does he agree with you? 25 A. I have discussed some of the issues</p>	<p>Page 300</p> <p>1 G Maxwell - Confidential 2 deny whether he had sex with Virginia 3 [REDACTED]? 4 MR. PAGLIUCA: Objection to the 5 form and foundation. 6 A. I can't say what Jeffrey would say. 7 Q. Has he discussed that with you? 8 A. He has not. 9 Q. Would Jeffrey be able to confirm or 10 deny whether he had a sexual massage from 11 Virginia that first time she came to his 12 mansion in Palm Beach? 13 MR. PAGLIUCA: Objection to the 14 form and foundation. 15 A. I cannot speak for what he would 16 say. I can only speak for what I would say. 17 So as I testified everything that she said 18 about that first meeting didn't happen so... 19 Q. Has he told that you everything 20 about that first meeting didn't happen? 21 A. I know it didn't happen because she 22 put me in that room. 23 Q. I understand you know. But has 24 Jeffrey said when you are talking about the 25 obvious lies, [REDACTED] yeah, that never happened?</p>
<p>Page 299</p> <p>1 G Maxwell - Confidential 2 with him, I can't remember specifically which 3 ones. I just don't recall. I'm sorry. 4 Q. Do you recall him telling you that 5 he didn't agree with you on any of those? 6 A. I don't recall him saying that. 7 Q. Do you have a joint defense 8 agreement with [REDACTED] 9 A. I believe I do. 10 Q. Do you have a joint defense 11 agreement with Alan Dershowitz? 12 A. I don't believe I do. 13 Q. Earlier today in your testimony, 14 when I was asking you some questions, you 15 said that you couldn't answer but that 16 Jeffrey Epstein could answer that question. 17 Would Jeffrey Epstein be in a 18 position to confirm or deny some of the 19 obvious lies that we've discussed today? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. I can't possibly testify to what 23 Jeffrey could or would say. I can't speak 24 for him. 25 Q. Would Jeffrey be able to confirm or</p>	<p>Page 301</p> <p>1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. I can't specifically recall that. 5 I don't know, but he has to agree with me 6 because it didn't happen. 7 Q. Can Jeffrey Epstein, would he be 8 able to confirm or deny whether he had sex 9 with underage girls? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I can't testify to what Jeffrey 13 would say. 14 Q. Can Jeffrey confirm or deny whether 15 [REDACTED] was on Jeffrey's island? 16 MR. PAGLIUCA: Objection to the 17 form and foundation. 18 A. I can't say what Jeffrey would say. 19 I can only say what I know to be true. 20 Q. Has Jeffrey talked to you about the 21 fact whether [REDACTED] was on his island? 22 A. As best as I can recollect, he said 23 he was not on the island. As best as I can 24 recollect. 25 Q. Can Jeffrey Epstein confirm whether</p>

Page 298 1 G Maxwell - Confidential
2 recall the exact conversation.
3 Q. Does Jeffrey Epstein send you text
4 messages?
5 A. No.
6 Q. Do you send him text messages?
7 A. No.
8 Q. How many phone calls have you had
9 with Jeffrey Epstein since December 30, 2014?
10 A. Again, very few.
11 Q. More than five?
12 A. Probably as many as the few emails
13 that I would characterize, so just very few.
14 I mean a small number.
15 Q. Are you aware of any disagreement
16 between your views about [REDACTED] and
17 Jeffrey's views about [REDACTED]?
18 MR. PAGLIUCA: Object to the form
19 and foundation
20 A. I cannot speculate to his views. I
21 can only testify on my views.
22 Q. Earlier you went through the series
23 of lies. Have you talked to Jeffrey about
24 the lies and does he agree with you?
25 A. I have discussed some of the issues

Page 300 1 G Maxwell - Confidential
2 deny whether he had sex with Virginia
3 [REDACTED]?
4 MR. PAGLIUCA: Objection to the
5 form and foundation.
6 A. I can't say what Jeffrey would say.
7 Q. Has he discussed that with you?
8 A. He has not.
9 Q. Would Jeffrey be able to confirm or
10 deny whether he had a sexual massage from
11 Virginia that first time she came to his
12 mansion in Palm Beach?
13 MR. PAGLIUCA: Objection to the
14 form and foundation.
15 A. I cannot speak for what he would
16 say. I can only speak for what I would say.
17 So as I testified everything that she said
18 about that first meeting didn't happen so...
19 Q. Has he told that you everything
20 about that first meeting didn't happen?
21 A. I know it didn't happen because she
22 put me in that room.
23 Q. I understand you know. But has
24 Jeffrey said when you are talking about the
25 obvious lies, [REDACTED] yeah, that never happened?

Page 299 1 G Maxwell - Confidential
2 with him, I can't remember specifically which
3 ones. I just don't recall. I'm sorry.
4 Q. Do you recall him telling you that
5 he didn't agree with you on any of those?
6 A. I don't recall him saying that.
7 Q. Do you have a joint defense
8 agreement with [REDACTED]
9 A. I believe I do.
10 Q. Do you have a joint defense
11 agreement with Alan Dershowitz?
12 A. I don't believe I do.
13 Q. Earlier today in your testimony,
14 when I was asking you some questions, you
15 said that you couldn't answer but that
16 Jeffrey Epstein could answer that question.
17 Would Jeffrey Epstein be in a
18 position to confirm or deny some of the
19 obvious lies that we've discussed today?
20 MR. PAGLIUCA: Objection to the
21 form and foundation.
22 A. I can't possibly testify to what
23 Jeffrey could or would say. I can't speak
24 for him.
25 Q. Would Jeffrey be able to confirm or

Page 301 1 G Maxwell - Confidential
2 MR. PAGLIUCA: Objection to the
3 form and foundation.
4 A. I can't specifically recall that.
5 I don't know, but he has to agree with me
6 because it didn't happen.
7 Q. Can Jeffrey Epstein, would he be
8 able to confirm or deny whether he had sex
9 with underage girls?
10 MR. PAGLIUCA: Objection to the
11 form and foundation.
12 A. I can't testify to what Jeffrey
13 would say.
14 Q. Can Jeffrey confirm or deny whether
15 [REDACTED] was on Jeffrey's island?
16 MR. PAGLIUCA: Objection to the
17 form and foundation.
18 A. I can't say what Jeffrey would say.
19 I can only say what I know to be true.
20 Q. Has Jeffrey talked to you about the
21 fact whether [REDACTED] was on his island?
22 A. As best as I can recollect, he said
23 he was not on the island. As best as I can
24 recollect.
25 Q. Can Jeffrey Epstein confirm whether

1 G Maxwell - Confidential
2 he and [REDACTED] were together in the
3 presence of [REDACTED]
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 Virginia
9 [REDACTED] statement that she was in the
10 presence of [REDACTED]
11 MR. PAGLIUCA: Objection to the
12 form and foundation.
13 A. I have not discussed individual
14 presences with Virginia. That's not -- I'm
15 only concerned with what I know to be the
16 stuff about me. So my focus has always been
17 the lies and the obvious lies as something I
18 can personally attest to. I cannot possibly
19 talk for anything else.
20 Q. Has Jeffrey Epstein said to you
21 anything along the lines of Virginia is lying
22 when she says she met [REDACTED]
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 Virginia, 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 [REDACTED]
19 [REDACTED] friend by the name of [REDACTED]
20 [REDACTED]
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 Virginia didn't meet [REDACTED]. I'm
12 sure that wouldn't be a conversation that we
13 would have. It doesn't effect me whether --
14 so I'm really only concerned about the lies
15 that were told as regards to me.
16 Q. Can Jeffrey Epstein confirm or deny
17 whether you sent Virginia to give 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 Virginia's 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 [REDACTED]
6 [REDACTED] 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 [REDACTED] 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 [REDACTED]
25 [REDACTED]¶

<p>Page 306</p> <p>1 G Maxwell - Confidential</p> <p>2 A. Nothing really.</p> <p>3 Q. Do you remember what she looks</p> <p>4 like?</p> <p>5 A. I would just be speculating on how</p> <p>6 I remember. I couldn't describe her.</p> <p>7 Q. Do you recall traveling with her?</p> <p>8 A. I don't.</p> <p>9 Q. Did you ever go to her home?</p> <p>10 A. I don't believe I did.</p> <p>11 Q. Do you know where she lives?</p> <p>12 A. I don't.</p> <p>13 Q. Would you have met her through</p> <p>14 Jeffrey Epstein?</p> <p>15 MR. PAGLIUCA: Objection to the</p> <p>16 form and foundation.</p> <p>17 A. I already testified I don't</p> <p>18 recollect how I met her and I remember her</p> <p>19 because her name is very unusual.</p> <p>20 Q. So what's your -- what recollection</p> <p>21 do you have of her, do you have a specific</p> <p>22 recollection of meeting her somewhere, you</p> <p>23 just don't know when that was or how do you</p> <p>24 know that name [REDACTED]</p> <p>25 MR. PAGLIUCA: Objection to the</p>	<p>Page 308</p> <p>1 G Maxwell - Confidential</p> <p>2 massages from her.</p> <p>3 Q. Did you ever have any sexual</p> <p>4 interaction with her?</p> <p>5 MR. PAGLIUCA: Object to the form</p> <p>6 and foundation and I'm going to instruct</p> <p>7 you if we're talking about any</p> <p>8 consensual adult contact, you are not</p> <p>9 allowed to answer the question.</p> <p>10 Q. Did you have any sexual contact</p> <p>11 with her in the presence of Jeffrey Epstein?</p> <p>12 MR. PAGLIUCA: Same instruction.</p> <p>13 Q. Did you have any sexual contact</p> <p>14 with her in the presence of anybody other</p> <p>15 than Jeffrey Epstein?</p> <p>16 MR. PAGLIUCA: Same instruction.</p> <p>17 Q. How many massages did you receive</p> <p>18 from [REDACTED]</p> <p>19 A. I really don't recall but a fair</p> <p>20 amount.</p> <p>21 Q. Did the massages involve sex?</p> <p>22 MR. PAGLIUCA: I'm going to</p> <p>23 instruct you not to answer.</p> <p>24 Q. Have you ever engaged in sex with</p> <p>25 any female?</p>
<p>Page 307</p> <p>1 G Maxwell - Confidential</p> <p>2 form and foundation.</p> <p>3 A. I don't know why the name is -- I'm</p> <p>4 sorry -- I can't -- I have no idea. I</p> <p>5 recognize the name but that's it.</p> <p>6 Q. Was [REDACTED] a masseuse?</p> <p>7 MR. PAGLIUCA: Objection to the</p> <p>8 form and foundation.</p> <p>9 A. What are you asking me, I'm sorry?</p> <p>10 Q. When [REDACTED] worked for</p> <p>11 Jeffrey Epstein, did she perform massages?</p> <p>12 A. I've testified that when [REDACTED]</p> <p>13 came originally, she came to answer</p> <p>14 telephones. I believe at some point she</p> <p>15 became a masseuse. I don't recollect when</p> <p>16 and I personally had massages from [REDACTED]</p> <p>17 Q. What did [REDACTED] do for Jeffrey</p> <p>18 Epstein, did she perform massages, anything</p> <p>19 else?</p> <p>20 MR. PAGLIUCA: Objection to the</p> <p>21 form and foundation.</p> <p>22 A. When she came she answered phones</p> <p>23 and at some point, I believe, I don't have</p> <p>24 any firm recollection, but I believe she went</p> <p>25 to school and became a masseuse and I had</p>	<p>Page 309</p> <p>1 G Maxwell - Confidential</p> <p>2 MR. PAGLIUCA: I'm going to</p> <p>3 instruct you not to answer.</p> <p>4 MS. MCCAWLEY: I want the record to</p> <p>5 reflect that Ms. Maxwell's attorney is</p> <p>6 directing her not to answer this series</p> <p>7 of questions.</p> <p>8 MR. PAGLIUCA: It definitely does.</p> <p>9 Q. Were you responsible for</p> <p>10 introducing [REDACTED] to Jeffrey Epstein?</p> <p>11 MR. PAGLIUCA: Objection to the</p> <p>12 form and foundation.</p> <p>13 A. I already testified that I don't</p> <p>14 really recall [REDACTED].</p> <p>15 Q. Were you responsible for</p> <p>16 introducing [REDACTED] to Jeffrey Epstein?</p> <p>17 MR. PAGLIUCA: Objection to the</p> <p>18 form and foundation.</p> <p>19 A. Again, I don't like the</p> <p>20 characterization of introduction. [REDACTED]</p> <p>21 came to answer telephones.</p> <p>22 Q. When did you -- were you the person</p> <p>23 who brought or introduced or met [REDACTED] for</p> <p>24 purposes of bringing her to Jeffrey Epstein's</p> <p>25 home?</p>

Page 306 1 G Maxwell - Confidential 2 A. Nothing really. 3 Q. Do you remember what she looks 4 like? 5 A. I would just be speculating on how 6 I remember. I couldn't describe her. 7 Q. Do you recall traveling with her? 8 A. I don't. 9 Q. Did you ever go to her home? 10 A. I don't believe I did. 11 Q. Do you know where she lives? 12 A. I don't. 13 Q. Would you have met her through 14 Jeffrey Epstein? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A. I already testified I don't 18 recollect how I met her and I remember her 19 because her name is very unusual. 20 Q. So what's your -- what recollection 21 do you have of her, do you have a specific 22 recollection of meeting her somewhere, you 23 just don't know when that was or how do you 24 know that name [REDACTED] 25 MR. PAGLIUCA: Objection to the

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 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 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 [REDACTED] 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 [REDACTED]. 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 Johanna for¶

19 purposes of that role?¶

20 A. So in the course of looking for¶

21 somebody to answer phones at the house,¶

22 Johanna was one of the people who said that¶

23 she was willing to answer phones.¶

24 Q. Did you approach her at her school¶

25 campus?¶

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 [REDACTED], 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, where [REDACTED]</p>

Page 314 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 [REDACTED], 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

Page 316 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

Page 315 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

Page 317 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, where [REDACTED]

1 G Maxwell - Confidential
2 [REDACTED] 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¶

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 [REDACTED] 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¶

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?¶

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.¶

Page 326¶

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¶

Page 327¶

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¶

Page 328¶

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 [REDACTED] 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]¶

Page 329¶

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 [REDACTED] 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 [REDACTED] 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 [REDACTED]¶

23 said or didn't say.¶

24 Q. I'm saying if [REDACTED] said that you¶

25 had knowledge that there were girls coming¶

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 8 said or didn't say or what he to..¶

9 Q. Did you have knowledge of underage 10 girls coming to Jeffrey Epstein's house for 11 the purpose of sex?¶

12 A. No.¶

13 Q. Earlier I believe you testified, 14 correct me if I'm wrong, that the document 15 that is in front of you, the thicker document 16 was a stolen document.¶

17 Do you know who stole that 18 document?¶

19 A. I have read that stole the 20 document.¶

21 Q. And where have you read that?¶

22 A. I believe it was reported in the¶

23 press. 24 Q. Earlier we were talking about the¶

25 computers at Jeffrey Epstein's home. Did you¶

1 2 3 G Maxwell - Confidential have a computer that was your computer located in Jeffrey Epstein's home?¶

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

6 7 8 A. I've testified to the computer already. Even when I was around, there was a computer that o le had access to.¶

9 10 11 Q. So is telling the truth when he says t at e ownloaded that book from your computer?¶

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

14 15 16 A. I couldn't possibly tell you what did or didn't do or said or didn't say.¶

17 Q. Was it on your computer?¶

18 19 A. I already testified I have no idea where this document came from.¶

20 21 22 Q. Did you have a list of names of individuals with contact information for Jeffrey Epstein on your personal computer?¶

23 A. Again, that wasn't my computer. I¶

24 25 already said that was a computer that lots of people would have, so I have no recollection 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 arc referencing, was it your¶

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 Page 334 Page 336 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¶

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

Page 335 1 G Maxwell - Confidential 2 would say. 3 . Did you ever threaten 4 in any way if he were to sclose 5 in ormation 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¶

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

Page 338¶

1 G Maxwell - Confidential¶

2 MR. PAGLIUCA: Objection to the¶

3 form and foundation.¶

4 Q. I want to make sure we are clear.¶

5 A. I don't know what you are asking.¶

6 Q. That's why I want to make sure we¶

7 are clear.¶

8 A. We are clear. I never asked¶

9 anybody to carry a baby for me.¶

10 Q. Do you know if Jeffrey ever asked¶

11 anybody to carry a baby for him?¶

12 A. I'm not going to characterize any¶

13 conversation Jeffrey had with somebody else.¶

14 Q. You are not aware of that, is that¶

15 your testimony?¶

16 A. I am testifying I never have and I¶

17 will not testify for anything for Jeffrey.¶

18 Q. Did you ever hear Jeffrey ask¶

19 anybody to carry a baby for him?¶

20 A. I don't recollect conversation¶

21 about Jeffrey and babies in any form.¶

22 Q. Did Jeffrey ever tell he wanted to¶

23 have a baby?¶

24 A. I don't recollect baby¶

25 conversations with Jeffrey.¶

Page 339¶

1 G Maxwell - Confidential¶

2 Q. So he never told you he wanted to¶

3 have a baby?¶

4 A. I don't recollect any baby¶

5 conversations with him saying he wanted to¶

6 have a baby.¶

7 Q. Did you ever bring any females to¶

8 the [REDACTED] house that were not your friends'¶

9 children that were under the age of 18?¶

10 MR. PAGLIUCA: Objection to form¶

11 and foundation.¶

12 A. I have never, to my knowledge,¶

13 brought anybody under the age of 18 that's¶

14 not a friend of my family or my nieces or¶

15 nephews to the [REDACTED] household.¶

16 Q. Earlier today you testified, I¶

17 believe, that with respect to your town home¶

18 Jeffrey paid for some of that and then gave¶

19 you a loan, is that correct?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation.¶

22 A. I said, actually I think it was a¶

23 loan, I believe it was a loan.¶

24 Q. The whole thing?¶

25 A. As best as I can recollect.¶

Page 340¶

1 G Maxwell - Confidential¶

2 Q. Did you pay that loan back?¶

3 A. I don't have any outstanding loans¶

4 with him.¶

5 Q. So you paid it back?¶

6 A. I don't have any outstanding loans¶

7 with him.¶

8 Q. That's not an answer to my¶

9 question.¶

10 Did you pay back Jeffrey for the¶

11 loans?¶

12 A. I have paid back any loans I had¶

13 with him.¶

14 Q. You have or haven't?¶

15 A. Have.¶

16 Q. Were there any other gifts that¶

17 Jeffrey gave you during the time period of¶

18 say 1999 to the present that were in excess¶

19 of $50,000?¶

20 MR. PAGLIUCA: Objection to the¶

21 form and foundation.¶

22 A. What's the question again?¶

23 Q. Did Jeffrey give you any gifts in¶

24 excess of amounts of $50,000, I'm not talking¶

25 about a scarf here or something¶

Page 341¶

1 G Maxwell - Confidential¶

2 insignificant, from 1999 to the present?¶

3 A. I can't recollect any gifts.¶

4 Q. Did he ever buy you a car?¶

5 A. I really don't recall, I can't¶

6 recall, it's a long time ago.¶

7 Q. You can't recall if Jeffrey Epstein¶

8 ever bought you a car?¶

9 A. I believe he did buy me a car, I¶

10 don't recall how much it cost. I don't¶

11 recall any of the financial details of that.¶

12 Q. Do you still have that car?¶

13 A. I don't.¶

14 Q. How long ago did you get rid of¶

15 that car?¶

16 A. I don't recall all the cars. There¶

17 was a car back -- there was -- I don't¶

18 recall, I'm sorry.¶

19 Q. He supplied you with several cars?¶

20 MR. PAGLIUCA: Object to the form¶

21 and the mischaracterization of the¶

22 testimony.¶

23 A. I don't recall details of the cars.¶

24 Q. Did he supply with you more than¶

25 one car?¶

<p>Page 342</p> <p>1 G Maxwell - Confidential</p> <p>2 A. Over the course of time, I've</p> <p>3 driven many cars.</p> <p>4 Q. That Jeffrey provided to you?</p> <p>5 A. They were cars that could be driven</p> <p>6 and I just don't recall them.</p> <p>7 Q. Were they in your name?</p> <p>8 A. I don't recall.</p> <p>9 Q. You don't recall if Jeffrey Epstein</p> <p>10 ever put a car in your name?</p> <p>11 A. We are talking a long time ago, I</p> <p>12 really don't recall.</p> <p>13 Q. When is the last time you had a car</p> <p>14 from Jeffrey Epstein that you used?</p> <p>15 A. 2000, 2001, 2002.</p> <p>16 Q. Do you recall what kind of a car</p> <p>17 that was?</p> <p>18 A. I don't recall, I'm sorry.</p> <p>19 Q. Did Jeffrey Epstein purchase</p> <p>20 anything else for you besides the townhouse</p> <p>21 and cars that would be over the amount of</p> <p>22 $50,000?</p> <p>23 A. I didn't say that he did, I said I</p> <p>24 had a loan.</p> <p>25 Q. Besides the loan, I'm sorry, you</p>	<p>Page 344</p> <p>1 G Maxwell - Confidential</p> <p>2 A. No.</p> <p>3 Q. Are you aware of any grand theft</p> <p>4 police report relating to [REDACTED]?</p> <p>5 A. I believe I've read a report in the</p> <p>6 press on that.</p> <p>7 Q. Did you provide the press with a</p> <p>8 report on a grand theft by [REDACTED]?</p> <p>9 A. I don't know how the press got that</p> <p>10 story.</p> <p>11 Q. Do you know if [REDACTED]</p> <p>12 committed a grand theft?</p> <p>13 A. I only know what I read in the</p> <p>14 press.</p> <p>15 Q. Did you ever state to the press</p> <p>16 that [REDACTED] committed a grand</p> <p>17 theft?</p> <p>18 A. I've never had any conversation</p> <p>19 directly with press.</p> <p>20 Q. Did any of your representatives</p> <p>21 ever inform the press that [REDACTED]</p> <p>22 committed a grand theft?</p> <p>23 MR. PAGLIUCA: Objection to the</p> <p>24 form and foundation.</p> <p>25 A. I have no way of knowing what my</p>
<p>Page 343</p> <p>1 G Maxwell - Confidential</p> <p>2 are right, you did say you had a loan and you</p> <p>3 said you paid that back, correct?</p> <p>4 A. That's my testimony.</p> <p>5 Q. Anything else in excess of $50,000</p> <p>6 that he would have purchased for you?</p> <p>7 A. We are talking 2002, 2001, I don't</p> <p>8 recall any gifts really.</p> <p>9 Q. When is the last time Jeffrey</p> <p>10 Epstein gave you a gift in excess of $50,000?</p> <p>11 MR. PAGLIUCA: Assumes facts not in</p> <p>12 evidence. Form and foundation.</p> <p>13 Q. You're saying you don't remember</p> <p>14 from 2001 and 2002. I'm asking when is the</p> <p>15 last time you remember Jeffrey Epstein</p> <p>16 purchasing a gift for you?</p> <p>17 A. I don't recall gifts in excess of</p> <p>18 $50,000, I barely recall gifts, I barely</p> <p>19 recall a lot of this -- I'm sorry, I don't</p> <p>20 recall.</p> <p>21 Q. Is Jeffrey Epstein paying for your</p> <p>22 legal fees in this case?</p> <p>23 A. No.</p> <p>24 Q. Is he paying for anything related</p> <p>25 to this case?</p>	<p>Page 345</p> <p>1 G Maxwell - Confidential</p> <p>2 representatives said to press or didn't.</p> <p>3 Q. Did they ever discuss with you the</p> <p>4 fact that they were going to report that</p> <p>5 [REDACTED] participated in a grand</p> <p>6 theft?</p> <p>7 A. I don't know how, first of all, I</p> <p>8 don't know how I know that. I believe I read</p> <p>9 it in a press report so...</p> <p>10 Q. I'm going to mark this as composite</p> <p>11 exhibit, Maxwell 14 please?</p> <p>12 (Maxwell Exhibit 14, email, marked</p> <p>13 for identification.)</p> <p>14 Q. I'm going to direct you to page GM</p> <p>15 00109. At the top of that page you are going</p> <p>16 to see an email address from Jeffrey Epstein</p> <p>17 on Sunday June 12, 2011 to [REDACTED]</p> <p>18 [REDACTED]</p> <p>19 A. Yes.</p> <p>20 Q. The re line says, This is the</p> <p>21 actual version they wanted me to send which I</p> <p>22 changed but this is back from my U.K.</p> <p>23 lawyers.</p> <p>24 Do you see that?</p> <p>25 A. Yes.</p>

Page 342 1 G Maxwell - Confidential 2 A. Over the course of time, I've 3 driven many cars. 4 Q. That Jeffrey provided to you? 5 A. They were cars that could be driven 6 and I just don't recall them. 7 Q. Were they in your name? 8 A. I don't recall. 9 Q. You don't recall if Jeffrey Epstein 10 ever put a car in your name? 11 A. We are talking a long time ago, I 12 really don't recall. 13 Q. When is the last time you had a car 14 from Jeffrey Epstein that you used? 15 A. 2000, 2001, 2002. 16 Q. Do you recall what kind of a car 17 that was? 18 A. I don't recall, I'm sorry. 19 Q. Did Jeffrey Epstein purchase 20 anything else for you besides the townhouse 21 and cars that would be over the amount of 22 $50,000? 23 A. I didn't say that he did, I said I 24 had a loan. 25 Q. Besides the loan, I'm sorry, you

Page 344 1 G Maxwell - Confidential 2 A. No. 3 Q. Are you aware of any grand theft 4 police report relating to [REDACTED]? 5 A. I believe I've read a report in the 6 press on that. 7 Q. Did you provide the press with a 8 report on a grand theft by [REDACTED]? 9 A. I don't know how the press got that 10 story. 11 Q. Do you know if [REDACTED] 12 committed a grand theft? 13 A. I only know what I read in the 14 press. 15 Q. Did you ever state to the press 16 that [REDACTED] committed a grand 17 theft? 18 A. I've never had any conversation 19 directly with press. 20 Q. Did any of your representatives 21 ever inform the press that [REDACTED] 22 committed a grand theft? 23 MR. PAGLIUCA: Objection to the 24 form and foundation. 25 A. I have no way of knowing what my

Page 343 1 G Maxwell - Confidential 2 are right, you did say you had a loan and you 3 said you paid that back, correct? 4 A. That's my testimony. 5 Q. Anything else in excess of $50,000 6 that he would have purchased for you? 7 A. We are talking 2002, 2001, I don't 8 recall any gifts really. 9 Q. When is the last time Jeffrey 10 Epstein gave you a gift in excess of $50,000? 11 MR. PAGLIUCA: Assumes facts not in 12 evidence. Form and foundation. 13 Q. You're saying you don't remember 14 from 2001 and 2002. I'm asking when is the 15 last time you remember Jeffrey Epstein 16 purchasing a gift for you? 17 A. I don't recall gifts in excess of 18 $50,000, I barely recall gifts, I barely 19 recall a lot of this -- I'm sorry, I don't 20 recall. 21 Q. Is Jeffrey Epstein paying for your 22 legal fees in this case? 23 A. No. 24 Q. Is he paying for anything related 25 to this case?

Page 345 1 G Maxwell - Confidential 2 representatives said to press or didn't. 3 Q. Did they ever discuss with you the 4 fact that they were going to report that 5 [REDACTED] participated in a grand 6 theft? 7 A. I don't know how, first of all, I 8 don't know how I know that. I believe I read 9 it in a press report so... 10 Q. I'm going to mark this as composite 11 exhibit, Maxwell 14 please? 12 (Maxwell Exhibit 14, email, marked 13 for identification.) 14 Q. I'm going to direct you to page GM 15 00109. At the top of that page you are going 16 to see an email address from Jeffrey Epstein 17 on Sunday June 12, 2011 to [REDACTED] 18 [REDACTED] 19 A. Yes. 20 Q. The re line says, This is the 21 actual version they wanted me to send which I 22 changed but this is back from my U.K. 23 lawyers. 24 Do you see that? 25 A. Yes.

1 G Maxwell - Confidential
2 Q. If you go down further, you're
3 going to see halfway through the page, you
4 will see your email address the [REDACTED]
5 and you will see a statement that says, Thank
6 you. I have it now. I'm working on the
7 letter a little. I will send final version
8 tomorrow and whatever is in it will be
9 factually accurate.
10 Beneath that you will see [REDACTED]
11 [REDACTED] who I believe you identified earlier
12 as one of your attorneys?
13 A. Uh-huh.
14 Q. And you will see a letter, starting
15 the text of a letter starting, I want you to
16 turn to the second page which is GM 00110.
17 About halfway through the page, it says you
18 will also presumably draw attention to the
19 fact that prior to filing her suit against
20 Mr. Epstein, [REDACTED] fled the U.S. to
21 avoid being arrested for grand theft. Police
22 report available.
23 What grand theft were you referring
24 to there that [REDACTED] committed?
25 MR. PAGLIUCA: Objection to the¶

1 G Maxwell - Confidential
2 A. I don't know who has this document.
3 Q. What's your basis in that statement
4 for saying [REDACTED] fled the U.S.?
5 A. Again, you are asking me for a
6 statement that I made in 2011 and I can't say
7 what in 2011 exactly the basis of that
8 statement was.
9 Q. So you don't know whether or not
10 that statement is true?
11 A. This is in 2011 and it never went
12 out, so I'm not sure exactly.
13 Q. But you said in your email that you
14 were working to make it factually accurate,
15 is that correct?
16 A. That's what it says.
17 Q. I'm going to mark as Maxwell 15 a
18 document dated February 24, 2015?
19 (Maxwell Exhibit 15, email, marked
20 for identification.)
21 Q. This is an email from [REDACTED] who
22 you've identified as your [REDACTED] on
23 February 24, 2015 to [REDACTED] which I understand
24 to be your email address and [REDACTED].
25 The subject line says, VR cried rape. Prior¶

1 G Maxwell - Confidential
2 form and foundation.
3 A. I don't know. However, I believe
4 she stole money from somewhere where she
5 worked.
6 Q. How do you know that was grand
7 theft?
8 A. I don't know how I know that.
9 Q. So you authorized a statement that
10 characterized that as grand theft without
11 knowing whether it was grand theft?
12 A. What month, what is the date of
13 this?
14 Q. The date of this is June 12, 2011?
15 A. So I'm afraid such a long time ago,
16 I'm not sure how, I really couldn't testify
17 as to how that language ended up in here.
18 Q. Do you have the police report? It
19 says police report available. Do you have
20 that document?
21 A. I don't have that document.
22 Q. Who does?
23 A. I have no idea.
24 Q. Would your lawyer [REDACTED]
25 have that document?¶

1 G Maxwell - Confidential
2 case dismissed as prosecutors found her not
3 credible. The message says, Ghislaine, some
4 helpful leakage, dot dot dot. What is it you
5 were leaking to the press?
6 MR. PAGLIUCA: Objection, there¶

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COMPOSITE EXHIBIT 1 (Filed Under Seal)¶