## EXHIBIT 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, -against- GHISLAINE MAXWELL, Defendants. Case No.: 15-cv-07433-RWS \*\*CONFIDENTIAL\*\* 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_1_Picture_16.jpeg) 2 APPEARANCES: BOLES SCHILLER & FLEXNER, LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdatle, Florida, 33301 BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH, ESQUIRE EMMA, PARALEGAL JAFFE WEISSING FISTOS & 9 LEHRMAN, P.L. Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 11 BY: BRAD, ESQUIRE 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 HADDON 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREY S. PAGL/UCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE 21 Also Present: 22 James Christe, videographer for sexual acts. 3 Q. I'm asking if they performed sexual acts? MR. PAGLIUCA: Object to the form and foundation. Q. Did any of the massage therapists who were at the home perform sexual acts for Jeffrey Epstein? A. I don't know what you mean by sexual acts. Q. Did any of the massage therapists who were working at the home perform sexual acts, including touching the breasts, touching the vaginal area, being touched while Jeffrey is masturbating, having intercourse, any of those things? MR. PAGLIUCA: Objection. Form and foundation. To the extent any of this is asking for to your knowledge any consensual sex act that may or may not have involved you, I'm instructing you not to answer the question. Q. I'm not asking about consensual sex 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 :o see -- can you read back the question? 11 (Record read.) 12 A. I'm not addressing any questions 13 about consensual adult sex. If you want to 14 talk about what the subject matter, which is 15 defamation and lying, , that 16 you and are participating in 17 perpetrating her lies, I'm happy to address 18 those. I never saw any inappropriate 19 underage activities with Jeffrey ever. 20 Q. I'm not asking about underage. I'm 21 asking about whether any of the masseuses 22 that were at the home perform sexual acts for 23 Jeffrey Epstein? 24 A. I have just answered the question. 25 Q. No, you haven't. A. I have. 3 Q. No, you haven't. A. Yes, I have. Q. You are refusing to answer the question. A. Let's move on. Q. I'm in charge of the deposition. I say when we move on and when we don't. You are here to respond to my questions. If you are refusing to answer the court will bring you back for another deposition to answer these questions. Do you understand that? MR. PAGLIUCA: You don't need to threaten the witness. MS. McCAWLEY: I'm not threatening her. I'm making sure the record is clear. MR. PAGLIUCA: Certainly can you apply to have someone come back and the court may or may not have her come back again. Again, she is not answering questions that relate to adult consent sex acts. Period. And that's the instruction and we can take it up with the court. Q. Ms. Maxwell, are you aware of any sexual acts with masseuses and Jeffrey Epstein that were nonconsensual? A. No. Q. How do you know that? A. All the time that I have been in the house I have never seen, heard, nor witnessed, nor have reported to me that any activities took place, that people were in distress, either reported to me by the staff or anyone else. I base my answer based on that. Q. Are the name of you familiar with a person by A. I am. Q. Has given astatement to police about you performing sexual acts on her? A. I have not heard that. Q. Has given a statement to police about Jeffrey Epstein performing 2 Q. Did you have sex with her? 3 MR. PAGLIUCA: This is the same 4 instruction about consensual or 5 nonconsensual. 6 Q. Was under the age of 18 when 7 you hired her? 8 A. No. I didn't hire her, as I said, 9 Jeffrey did. 10 Q. Did ever have sex with 11 Jeffrey? 12 MR. PAGLIUCA: Objection to the 13 form and foundation. 14 A. How would I know what somebody else 15 did. 16 Q. You weren't involved in the sex 17 between Jeffrey, and yourself? 18 A. We already -- 19 Q. Were you involved with sex between 20 Jeffrey, and yourself? 21 MR. PAGLIUCA: Everyone is talking 22 over each other. You heard the 23 question. 24 Again, you you know what the 25 instruction is. If there is any consensual issue involved, I instruct you not to answer. A. Moving on. Q. So you are refusing to answer that question? A. I've been instructed by my lawyer. Q. Did you ever have sex with Jeffrey, Virginia and yourself when Virginia was underage? A. Absolutely not. MR. PAGLIUCA: We've been going for about an hour. I would like to take a five-minute break, please. MS. McCAWLEY: I'm almost done. MR. PAGLIUCA: You are not going to allow abreak. MS. McCAWLEY: As soon as I get through my line of questioning, which is perfectly appropriate. Q. Did travel with you and Jeffrey to Europe? A. I'm sure she did. Q. What is she doing today? A. I have no idea. 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 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 not to answer any questions about any of your consensual adult sexual activity. Q. So you are not going to answer that question? A. You just heard my counsel. Q. Have you ever said to anybody that recruiting other girls to perform sexual massages for Jeffrey Epstein takes the pressure off you? MR. PAGLIUCA: Object to the form and foundation. A. Repeat the question and break it out. Q. Have you ever said to anybody that you recruit girls -- A. Stop right there. I never recruited girls, let's stop there. Now breakdown the question. Q. Have you ever said to anybody A. By girls, we are talking about underage people -- you said girls, are you talking about underage -- we are not talking about consensual acts -- this is adefamation suit. 2 the flights? 3 A. I can't recollect having a meal 4 with them, but just so we are clear, the 5 allegations that had a meal on 6 Jeffrey's island is 100 percent false. 7 Q. But he may have had a meal on 8 Jeffrey's plane? 9 A. I'm sure he had a meal on Jeffrey's 10 plane. 11 Q. You do know how many times he flew 12 on Jeffrey's plane? 13 A. I don't. 14 Q. Do you know who is? 15 A. I do. 16 Q. How do you know him? 17 A. He used to work or still works for 18 19 Q. Did you ever have a relationship 20 with him? 21 A. We are talking about adult 22 consensual relationships, it's off the 23 record. 24 Q. I'm not asking what you did with 25 him, I'm asking if you ever had a 2 relationship with him? 3 MR. PACLIUCA: If you understand 4 the term relationship, certainly you can 5 answer that. 6 A. Define relationship. 7 Q. Somebody that you would have spent 8 time together, either seeing them in a 9 romantic relationship or -- 10 A. You need to be, what do you mean by 11 romantic. I was friends with Illtut you 12 are suggesting something more so I want to be 13 clear what you are actually asking me. 14 Q. You defined it. You said you were 15 friends with him. If that's what you were 16 that's all I need to know. 17 While you were on the trip with 18 do you recall where you 19 stayed at these locations, in other words, 20 would you leave the jet and stay overnight at 21 a hotel, do you have a recollection of this 22 trip? 23 A. I recollect the trip but if you're 24 asking me where we stayed, you can see it's a 25 very fast paced trip. It was very tiring and 2 form and foundation. 3 A. I don't know why the name is -- I'm 4 sorry -- I can't -- I have no idea. I 5 recognize the name but that's it. 6 Q. Was a masseuse? 7 MR. PAGLIUCA: Objection to the 8 form and foundation. 9 A. What are you asking me, I'm sorry? 10 Q. When worked for 11 Jeffrey Epstein, did she perform massages? 12 A. I've testified that when 13 came originally, she came to answer 14 telephones. I believe at some point she 15 became a masseuse. I don't recollect when 16 and I personally had massages from 17 Q. What did o 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 massages from her. Q. Did you ever have any sexual interaction with her? MR. PAGLIUCA: Object to the form and foundation and I'm going to instruct you if we're talking about any consensual adult contact, you are not allowed to answer the question. Q. Did you have any sexual contact with her in the presence of Jeffrey Epstein? MR. PAGLIUCA: Same instruction. Q. Did you have any sexual contact with her in the presence of anybody other than Jeffrey Epstein? MR. PAGLIUCA: Same instruction. Q. How many massages did you receive from A. I really don't recall but afair amount. Q. Did the massages involve sex? MR. PAGLIUCA: I'm going to instruct you not to answer. Q. Have you ever engaged in sex with any female? 2 3 MR. PAGLIUCA: I'm going to instruct you not to answer. 4 5 7 MS. McCAWLEY: I want the record to reflect that Ms. Maxwell's attorney is directing her not to answer this series of questions. B MR. PAGLIUCA: It definitely does. 9 10 Q. Were introducing you responsible for to Jeffrey Epstein? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 14 A. I already really recall testified that I don't 15Q. Were you responsible for 16introducing to Jeffrey Epstein? 17MR. PAGLIUCA: Objection to the 18 form and foundation. 19A. Again, I don't like the 20 characterization of introduction. 21 came to answer telephones. 22Q. When did you -- were you the person 23 who brought or introduced or met or 24 25 purposes of bringing her to Jeffrey home? Epstein's