Draft: efta02785335

EXHIBIT D¶

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶

x¶

Plaintiff,¶

-against-¶

GHISLAINE MAXWELL,¶

Defendant.¶

Case No.: 15-cv-07433-RWS¶

**CONFIDENTIAL**¶

x¶

Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein, taken pursuant to subpoena, was held at the law offices of Boies, Schiller & Flexner, LLP, 575 Lexington Avenue, New York, New York, commencing July 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 (866) 624-6221¶

Page 2¶

1
2 APPEARANCES:
3 On Behalf of the Plaintiff:
4 BOIES SCHILLER & FLEXNER, LLP
5 333 Main Street
6 Armonk, New York 10504
7 BY: DAVID BOIES, ESQUIRE
8 BOIES SCHILLER & FLEXNER, LLP
9 401 East Las Olas Boulevard
10 Fort Lauderdale, Florida 33301
11 BY: MEREDITH [REDACTED], ESQUIRE
12 SIGRID McCAWLEY, ESQUIRE
13 SANDRA PERKINS, PARALEGAL
14 [REDACTED]
15 JAFFE WEISSING [REDACTED] FISTOS &
16 LEHRMAN, P.L.
17 425 N. Andrews Avenue
18 Fort Lauderdale, Florida 33301
19 BY: BRAD [REDACTED], ESQUIRE
20 PAUL G. CASSELL, ESQUIRE
21 383 South University Street
22 Salt Lake City, Utah 84112
23 J. STANLEY POTTINGER, PLLC
24 49 Twin Lakes Road
25 South Salem, New York 10590
26 BY: STAN POTTINGER, ESQUIRE
27 On Behalf of Defendant:
28 HADDON [REDACTED]
29 Attorneys for Defendant
30 150 East 10th Avenue
31 Denver, Colorado 80203
32 BY: JEFFREY S. PAGLIUCA, ESQUIRE
33 LAURA A. MENNIGER, ESQUIRE
34 Also Present:¶

Page 4¶

1
2 MR. [REDACTED]: Brad [REDACTED], also
3 representing the plaintiff, [REDACTED]
4 [REDACTED]
5 MR. POTTINGER: Stan Pottinger,
6 also representing the plaintiff.
7 MR. CASSELL: Paul Cassell, from
8 Salt Lake City, Utah, also representing
9 [REDACTED]
10 MR. PAGLIUCA: Jeff Pagliuca and
11 Laura Menninger, on behalf of Ms.
12 Maxwell.
13 And Ms. McCawley has also entered
14 the room, and we have an assistant from
15 Boies Schiller from the Fort Lauderdale
16 office here today as well today.
17 THE VIDEOGRAPHER: Will the court
18 reporter please swear in the witness.
19 GHISLAINE MAXWELL,
20 called as a witness, having been duly
21 sworn by a Notary Public, was
22 examined and testified as follows:
23 EXAMINATION BY
24 MR. BOIES:
25 Q. Good morning, Ms. Maxwell. [REDACTED]¶

Page 3¶

1
2 THE VIDEOGRAPHER: This is DVD No.
3 1, Volume II, of the continued video
4 recorded deposition of Ghislaine Maxwell
5 in the matter [REDACTED] against
6 Ghislaine Maxwell, in the United States
7 District Court, Southern District of New
8 York.
9 This deposition is being held at
10 575 Lexington Avenue, New York, New
11 York, on July 22, 2016 at approximately
12 9:04 a.m.
13 My name is Rodolfo Duran. I am the
14 legal video specialist. The court
15 reporter is Leslie Fagin, and we are
16 both in association with Magna Legal
17 Services.
18 Will counsel please introduce
19 themselves.
20 MR. BOIES: This is David Boies, of
21 Boies, Schiller & Flexner, counsel for
22 plaintiff.
23 [REDACTED]: Meredith [REDACTED],
24 from Boies Schiller & Flexner, counsel
25 for plaintiff.¶

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1 G. Maxwell - Confidential
2 [REDACTED]
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7 [REDACTED]
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9 [REDACTED]
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13 [REDACTED]
14 [REDACTED]
15 [REDACTED]
16 [REDACTED]
17 [REDACTED]
18 [REDACTED]
19 [REDACTED]
20 [REDACTED]
21 [REDACTED]
22 [REDACTED]
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24 [REDACTED]
25 [REDACTED]¶

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2
3¶

[Redacted text block]¶

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2¶

[Redacted text block]¶

22 MR. PAGLIUCA: Object to the form
23 and foundation.
24 MR. BOIES: Excuse me, counsel.
25 MR. PAGLIUCA: I'm objecting to¶

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1 G. Maxwell - Confidential
2
3¶

[Redacted text block]¶

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1 G. Maxwell - Confidential
2 form and foundation, and I have an
3 opportunity to do that.
4 MR. BOIES: Yes, you do, but you do
5 not have an opportunity to disrupt the
6 deposition.
7 MR. PAGLIUCA: Which I'm not.
8 MR. BOIES: The court will decide
9 that, as the court has decided the
10 issues before.
11¶

[Redacted text block]¶

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2 [REDACTED]¶

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2 [REDACTED]¶

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1 G. Maxwell - Confidential
2 [REDACTED]¶

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1 G. Maxwell - Confidential
2 [REDACTED]¶

3 [REDACTED]¶

4 [REDACTED]¶

5 [REDACTED]¶

6 Q. You understand that you are under oath, correct?¶

7 A. I do.¶

8 Q. And you understand that the oath requires you to tell the truth, the whole truth and nothing but the truth in response to questions?¶

9 MR. PAGLIUCA: Object to the form and foundation.¶

10 Q. Do you?¶

11 A. I do understand that.¶

12 Q. Do you understand if you fail to do that, that you could be prosecuted for perjury?¶

13 MR. PAGLIUCA: Object to the form and foundation.¶

14 Q. Do you?¶

15 A. I understood that is what happens at these events.¶

16 Q. And do you understand that if you say that you do not recall and in fact you do¶

17 [REDACTED]¶

18 [REDACTED]¶

19 [REDACTED]¶

20 [REDACTED]¶

21 [REDACTED]¶

22 [REDACTED]¶

23 [REDACTED]¶

24 [REDACTED]¶

25 [REDACTED]¶

1 G. Maxwell - Confidential
2 recall, that would violate your oath?
3 MR. PAGLIUCA: Object to the form
4 and foundation.
5 A. If I don't recall, I don't recall.
6 It's not a question of whether I'm violating
7 my oath or not. I don't know. [REDACTED]¶

					P
1		G. Maxwell - Confidential
2		MR. PAGLIUCA: Object to the form
3		and foundation.
4		A. How would I know?
5		Q. Were you ever on a plane with
6		Mr. Epstein when, to your knowledge,
7		Mr. Epstein had sex with anyone?
8		A. Can you repeat the question?
9		Q. Were you ever on a plane with
10		Mr. Epstein when, to your knowledge,
11		Mr. Epstein had sex with anyone?
12		A. Not that I can recall.
13		Q. Were you ever on a plane with
14		Mr. Epstein when you saw Mr. Epstein having
15		sex with anyone?
16		A. Never.
17		Q. I want to be sure that t

1	G. Maxwell - Confidential
2	MR. PAGLIUCA: Object to the form
3	and foundation.
4	A. How would I know?
5	Q. Were you ever on a plane with
6	Mr. Epstein when, to your knowledge,
7	Mr. Epstein had sex with anyone?
8	A. Can you repeat the question?
9	Q. Were you ever on a plane with
10	Mr. Epstein when, to your knowledge,
11	Mr. Epstein had sex with anyone?
12	A. Not that I can recall.
13	Q. Were you ever on a plane with
14	Mr. Epstein when you saw Mr. Epstein having
15	sex with anyone?
16	A. Never.
17	Q. I want to be sure that the question
18	and answer is meeting. When you refer to
19	having sex with someone, what are you
20	referring to?
21	MR. PAGLIUCA: Object to the form
22

Page 18¶

1 G. Maxwell - Confidential¶

2 A. I think everyone here can¶

3 understand what intercourse is, is when you¶

4 have sex. I don't know how to say¶

5 intercourse any other way, having sex with¶

6 somebody. Perhaps you would like to define¶

7 it for me.¶

8 Q. I'm trying to get your definition¶

9 right now because you are the witness. When¶

10 you use the term intercourse, what are you¶

11 referring to?¶

12 A. I'm referring to a penis entering¶

13 someone's vagina.¶

14¶

You haven't tied your question to time or individual or specific location. And so unless you do that, we have an open-ended question that would span from the early '90s to 2000 or so, which would not be tied to the key events, individuals or locations of this case.¶

BY MR. BOIES:¶

Q. Let me ask you a couple more questions. Then I think we probably ought to call the court and get some guidance on this.¶

Q. Were you ever on Mr. Epstein's plane when, to your knowledge, Mr. Epstein¶

Page 22¶

1 G. Maxwell - Confidential
2 had oral sex with anyone [REDACTED]
3 A. No.
4 [REDACTED]
5 [REDACTED]
6 [REDACTED]
7 [REDACTED]
8 [REDACTED]
9 [REDACTED]
10 [REDACTED]
11 [REDACTED]
12 [REDACTED]
13 [REDACTED]
14 [REDACTED]
15 [REDACTED]
16 [REDACTED]
17 [REDACTED]
18 [REDACTED]
19 [REDACTED]
20 [REDACTED]
21 [REDACTED]
22 [REDACTED]
23 [REDACTED]
24 [REDACTED]
25 [REDACTED]¶

1 G. Maxwell - Confidential
2 court case on this list, one other person.
3 Q. Which one is that?
4 A. [REDACTED], because she has been
5 on the court papers.
6 Q. [REDACTED] who?
7 A. [REDACTED]
8 The only two I know is [REDACTED] and
9 Virginia, and one other name I recognize.
10 Q. So just to be clear, the only two
11 people listed on Maxwell Deposition Exhibit
12 26 that you know are [REDACTED]
13 A. And [REDACTED], yes.
14 Q. And the only other person on --
15 A. I don't know her, I recognize her
16 name.
17 Q. -- whose name you recognize is
18 [REDACTED], but you don't know her, never
19 met her?
20 A. I don't recall ever meeting her.
21 Q. Other than what you know from her
22 participation in this case, you don't know
23 anything about her, is that your testimony?
24 A. I don't even know -- I don't even
25 recognize what her participation is in this¶

Page 23¶

1 G. Maxwell - Confidential
2 [REDACTED]
3 [REDACTED]
4 MR. BOIES: I will show you a
5 document we have marked for
6 identification as Maxwell Deposition
7 Exhibit 26.
8 (Maxwell Exhibit 26, List of names,
9 marked for identification, as of this
10 date.)
11 Q. I would like you to go down this
12 list and tell me which names, if any, you
13 recognize on this list.
14 A. Just in the way the list runs in
15 order, I recognize the names -- by recognize,
16 only stating that I know the name, I'm not
17 making any representations about these
18 people.
19 Q. I understand that, and I will come
20 back and ask you, but if you don't recognize
21 the name...
22 A. [REDACTED]. [REDACTED]
23 And that's it on this list. Let me just
24 double-check. I recognize the name, not
25 because I know her, but just because of the¶

1 G. Maxwell - Confidential
2 case. I just know I recognize her name, and
3 I can't recall right now what her involvement
4 is, but I recognize the name.
5 Q. Other than whatever her involvement
6 in this case may be or may not be?
7 A. Correct.
8 Q. Is it fair to say it is your
9 testimony that except for that, you have no
10 knowledge about her at all?
11 A. Correct.
12 Q. And other than [REDACTED],
13 [REDACTED] and [REDACTED], you don't
14 know anything at all about any of the other
15 people listed here, is that your testimony?
16 A. I don't even know who they are.
17 You could put any names in front of me, I
18 wouldn't recognize them, I don't know them, I
19 don't even recognize the names.
20 Q. I think this is clear from your
21 last answer, but I want to be sure. It is
22 your testimony that other than [REDACTED]
23 and [REDACTED], you never met any of
24 these people at any homes of Mr. Epstein, is
25 that your testimony?¶

![](_page_7_Picture_17.jpeg)¶

Page 26¶

1 G. Maxwell - Confidential¶

2 MR. PAGLIUCA: Object to the form¶

3 and foundation.¶

4 A. I don't even know who they are, so¶

5 I wouldn't -- I have no clue who they are, I¶

6 don't know where they are, I don't know where¶

7 they come from, I don't recognize -- I only¶

8 pointed out [REDACTED] because I recognize¶

9 the name from various documents I read. I¶

10 don't have any knowledge of any other person¶

11 on this list. I don't believe I've ever even¶

12 seen these names. I don't know who they are¶

13 at all.¶

14 I would not be able to identify a¶

15 single name on this list other than those¶

16 three that I have indicated to you.¶

17 [REDACTED]¶

18 [REDACTED]¶

19 [REDACTED]¶

20 [REDACTED]¶

21 [REDACTED]¶

22 [REDACTED]¶

23 [REDACTED]¶

24 [REDACTED]¶

25 [REDACTED]¶

Page 27¶

1 G. Maxwell - Confidential¶

2 [REDACTED]¶

3 [REDACTED]¶

4 [REDACTED]¶

5 Q. Did you provide massages to¶

6 Mr. Epstein?¶

7 A. No.¶

8 Q. What?¶

9 A. No.¶

10 Q. Were you ever present when anyone¶

11 provided a massage to Mr. Epstein?¶

12 MR. PAGLIUCA: Object to the form¶

13 and foundation.¶

14 A. I have seen people give Mr. Epstein¶

15 massages. I have seen him on a massage¶

16 table. I have seen that.¶

17 Q. Have you seen someone other than¶

18 yourself give Mr. Epstein a massage at his¶

19 home in New York?¶

20 A. I can't recall seeing him in the¶

21 massage room in New York, no.¶

22 Q. I'm not asking whether you recall¶

23 seeing him in the massage room in New York.¶

24 I'm asking you whether you have ever seen¶

25 someone other than yourself give Mr. Epstein¶

Page 28¶

1 G. Maxwell - Confidential¶

2 a massage at his home in New York, regardless¶

3 of where in the home it was?¶

4 A. No.¶

5 Q. Have you ever seen anyone give¶

6 Mr. Epstein a massage at his home in Palm¶

7 Beach?¶

8 A. I have.¶

9 Q. Have you ever seen anyone give¶

10 Mr. Epstein a massage in New Mexico?¶

11 A. No, I can't recall.¶

12 Q. Have you ever seen anyone give¶

13 Mr. Epstein a massage in the Virgin Islands?¶

14 A. I have.¶

15 Q. Have you ever seen anyone give¶

16 Mr. Epstein a massage in Paris?¶

17 A. No, I don't recall seeing that.¶

18 Q. Have you ever seen anyone give¶

19 Mr. Epstein a massage on an airplane?¶

20 A. No.¶

21 Q. Have you ever seen anyone give¶

22 Mr. Epstein a massage anywhere other than his¶

23 home in Palm Beach or in the Virgin Islands?¶

24 A. I'm sorry, can you just repeat the¶

25 question?¶

Page 29¶

1 G. Maxwell - Confidential¶

2 Q. Have you ever seen anyone give¶

3 Mr. Epstein a massage anywhere other than in¶

4 his home in Palm Beach or in the Virgin¶

5 Islands?¶

6 A. No, I can't think of anyplace.¶

7 Q. Have you ever seen anyone give¶

8 Mr. Epstein a massage when Mr. Epstein was¶

9 not clothed?¶

10 A. Sorry, can you repeat the question?¶

11 Q. Have you ever seen anyone give¶

12 Mr. Epstein a massage when Mr. Epstein was¶

13 not clothed?¶

14 A. I think when Mr. Epstein received¶

15 massages, he never had clothes on.¶

16 Q. Who did you see give Mr. Epstein a¶

17 massage?¶

18 A. I can't recall the "whos" because I¶

19 don't really remember, but I have seen him¶

20 receive massages from professional adult¶

21 masseuses that I have seen him receive¶

22 massages.¶

23 Q. When you say professional adult¶

24 masseuses, what are you referring to?¶

25 A. I just want to be sure that we¶

![](_page_8_Picture_21.jpeg)¶

Page 30¶

1 G. Maxwell - Confidential¶

2 understand that the times I have seen him¶

3 receive a massage it's been by somebody who¶

4 is an adult, clearly an older person. I¶

5 don't know if they're professional, but an¶

6 older person appearing to be a professional¶

7 masseuse.¶

8 Q. What led you to believe that the¶

9 person giving the massage was a professional¶

10 masseuse?¶

11 A. Because the massages that I¶

12 witnessed looked professional. I don't know¶

13 how to -- I'm defining it as opposed to the¶

14 ones from where people ask me inappropriate¶

15 questions, I couldn't answer, but these are¶

16 people who would be clothed giving a¶

17 professional massage, it appeared to be a¶

18 professional massage, as opposed to any other¶

19 type of massage.¶

20 Q. Have you ever had what you refer to¶

21 as a professional massage?¶

22 A. I have.¶

23 Q. Have you ever had what you refer to¶

24 as a professional massage in any of Mr.¶

25 Epstein's homes?¶

Page 31¶

1 G. Maxwell - Confidential¶

2 A. I have.¶

3 Q. Did you ever have what you refer to¶

4 as a professional massage in Mr. Epstein's¶

5 home in New York?¶

6 A. I don't recall, but I think I have,¶

7 but I don't recall. I must have, but I don't¶

8 recall.¶

9 Q. Did you ever have what you refer to¶

10 as a professional massage in Mr. Epstein's¶

11 home in Palm Beach?¶

12 A. I did.¶

13 Q. Did you ever have what you refer to¶

14 as a professional massage in Mr. Epstein's¶

15 home in New Mexico?¶

16 A. I did.¶

17 Q. Did you ever have what you refer to¶

18 as a professional massage in Mr. Epstein's¶

19 home in Paris?¶

20 A. I did.¶

21 Q. Did you ever have what you refer to¶

22 as a professional massage in the Virgin¶

23 Islands?¶

24 A. I did.¶

25 Q. When you had what you referred to¶

Page 32¶

1 G. Maxwell - Confidential¶

2 as professional massages, you were clothed or¶

3 unclothed?¶

4 A. Unclothed.¶

5 Q. Completely unclothed?¶

6 A. Typically when you receive a¶

7 massage you are not clothed, so I was¶

8 unclothed, as is the norm in a massage¶

9 situation.¶

10 Q. That is, you didn't have any¶

11 clothes on, is that the case?¶

12 A. Generally, what happens is you are¶

13 not wearing any clothes and you have a towel¶

14 or sheet that covers you while you are¶

15 receiving the massage, so I would be covered¶

16 always, but underneath the sheet or towel, I¶

17 would not be wearing any clothing.¶

18 Q. Are you saying that the massage was¶

19 through the sheet?¶

20 A. Well, in some instances, yes.¶

21 Q. It is your testimony that when you¶

22 received what you referred to as professional¶

23 massages, the masseuse didn't touch your¶

24 skin, only touched the sheet?¶

25 MR. PAGLIUCA: Object to the form¶

Page 33¶

1 G. Maxwell - Confidential¶

2 and foundation.¶

3 A. I didn't say that. I said in some¶

4 instances, some massages are where you don't¶

5 touch the skin, so I have received massages¶

6 where I don't get touched, especially if it's¶

7 just pressure, so it's through a sheet, but I¶

8 have also received massages where you are¶

9 touched and the sheet is just there for¶

10 modesty.¶

11 Q. Have you ever received what you¶

12 referred to as a professional massage when¶

13 anyone else was in the room other than the¶

14 person that you are referring to as a¶

15 professional masseuse?¶

16 MR. PAGLIUCA: Object to the form¶

17 and foundation.¶

18 A. Can you repeat the question,¶

19 please?¶

20 Q. Have you ever received a massage¶

21 when anyone was in the room other than the¶

22 person that you refer to as a professional¶

23 masseuse?¶

24 MR. PAGLIUCA: Same objection.¶

25 A. I am entirely possible that in the¶

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1 G. Maxwell - Confidential
2 course of receiving a massage someone would
3 come in and sit and chat to me while I was
4 getting a massage, a friend would come in.
5 That has happened.
6 Q. Do you recall that happening?
7 A. Not with specificity, I can't think
8 of it actually, but I know that I've had
9 friends come in and we've talked and as I got
10 a massage, that has happened.
11 Q. Have you ever received a massage
12 when Mr. Epstein was present?
13 A. He has entered the room and gave me
14 a message or asked me a question, that has
15 happened.
16 Q. Have you ever received a massage
17 when Mr. Epstein was in the room other than
18 just to come in to give you a message or ask
19 you a question?
20 MR. PAGLIUCA: Object to the form
21 and foundation.
22 A. Not that I recall.
23 Q. Did you ever participate in
24 arranging for anyone to give Mr. Epstein a
25 massage?¶

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1 G. Maxwell - Confidential
2 A. Part of my duties and my job -- can
3 you repeat the question so I understand, and
4 I give you the right answer exactly.
5 Q. Did you ever participate in
6 arranging for anyone to give Mr. Epstein a
7 massage?
8 A. Part of my professional
9 responsibilities, I did, and I've testified
10 previously, go to spas and other professional
11 areas and received massages from people in
12 these places, and if I felt that person was
13 good or I had had a good massage, I had asked
14 if they do home visits.
15 In that capacity, I had, people did
16 come to the house in that capacity, that I
17 thought were good.
18 Q. Did you ever arrange for anyone to
19 give Mr. Epstein a massage or to come to his
20 home to give him a massage, other than
21 someone who had previously given you a
22 massage?
23 A. Sorry, can you repeat the question?
24 Q. Did you ever arrange for anyone to
25 give Mr. Epstein a massage or to come to his¶

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1 G. Maxwell - Confidential
2 home to give him a massage, other than
3 someone who had previously given you a
4 massage?
5 A. No, I don't think so. No, I don't
6 think so.
7 Q. Is it your testimony that everyone
8 that you arranged to come to Mr. Epstein's
9 home to give Mr. Epstein a massage was
10 somebody you had already had a massage from?
11 A. No, that is not my testimony. I
12 don't recall -- there were definitely
13 instances where I had a massage and -- so
14 what you are asking me was if anyone came to
15 the house to give him a massage that I had
16 not had a massage from myself?
17 Q. It's a little different than that.
18 A. Okay.
19 Q. You've testified that you arranged
20 for some people to come to Mr. Epstein's home
21 to give him a massage, correct?
22 A. Yes.
23 Q. And at one point, I thought you had
24 testified that before you arranged to have
25 people come to give Mr. Epstein a massage,¶

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1 G. Maxwell - Confidential
2 you had -- you didn't use the word tested
3 them out, but that you had previously gotten
4 them to give you a massage so that you could
5 see how good they were, is that fair to say?
6 A. If I thought they were -- if I
7 thought it was a good massage, yes, that is
8 my testimony.
9 Q. What I had thought, and what I'm
10 now asking you is that everyone who you
11 arranged to come to Mr. Epstein's home to
12 give him a massage was somebody who you had
13 already had a massage from, is that fair?
14 A. Typically, yes, but that wasn't
15 exclusively. So I know that friends of mine,
16 for instance, would have a masseuse or
17 masseur that they thought was very good, and
18 they said this is a very good person.
19 So it is possible, and I'm pretty
20 sure sometimes on recommendations of other
21 people, that without me having a massage from
22 them, that they may have come to the house.
23 So I could not testify that every single
24 person that came to the house I received a
25 massage from, because that would not be true.¶

Page 38¶

1 G. Maxwell - Confidential¶

2 Q. Was every person who you arranged¶

3 to come to Mr. Epstein's house to give a¶

4 massage someone who either you had already¶

5 had a massage from or you had a friend who¶

6 recommended them as a good professional¶

7 masseuse?¶

8 MR. PAGLIUCA: Object to the form¶

9 and foundation.¶

10 A. Typically, that is how that would¶

11 work.¶

12 Q. Was there ever anyone who you¶

13 arranged to come to Mr. Epstein's house to¶

14 give him a massage, someone who you had not¶

15 previously gotten a massage from yourself or¶

16 received a recommendation from one of your¶

17 friends that it was a good professional¶

18 masseuse?¶

19 MR. PAGLIUCA: Object to the form¶

20 and foundation.¶

21 A. I cannot think of anyone that would¶

22 fit that category.¶

23 Q. You made a point in a previous¶

24 answer of referring to people as adult¶

25 masseuses. Do you recall that?¶

Page 39¶

1 G. Maxwell - Confidential¶

2 A. I do.¶

3 Q. When you refer to someone as an¶

4 adult masseuse, what are you referring to?¶

5 A. I think everybody in this room is¶

6 an adult.¶

7 Q. I don't necessarily disagree with¶

8 that, but what I'm asking you, since I can't¶

9 carry all these people with me every time¶

10 somebody reads this transcript, is what do¶

11 you mean by an adult?¶

12 A. Well, I think an adult is somebody¶

13 who looks older and professional and is¶

14 someone who has lived some life and looks¶

15 like any one of us in this room do, some a¶

16 little older and some a little younger.¶

17 Q. You are aware that there are¶

18 assertions that Mr. Epstein had massages from¶

19 females under the age of 21?¶

20 A. I am aware of that.¶

21 Q. Insofar as you are aware, did¶

22 Mr. Epstein ever have a massage from anyone¶

23 under the age of 21?¶

24 MR. PAGLIUCA: Object to the form¶

25 and foundation.¶

Page 40¶

1 G. Maxwell - Confidential¶

2 A. I know what the allegations are,¶

3 and I am aware of those, but as to my actual¶

4 knowledge of somebody under the age of 21, I¶

5 can't say that I know, I can't think of¶

6 anybody. I know Virginia has obviously made¶

7 those claims and she was 17 when he met her,¶

8 but other than her, I cannot think of¶

9 anybody.¶

10 Q. Insofar as you are aware, did¶

11 Virginia ever give Mr. Epstein a massage?¶

12 A. I know she said she did and I¶

13 believe she may have, but I don't ever see¶

14 her giving him a massage, so I can't say.¶

15 Q. Leaving aside any information that¶

16 you have that has come from Virginia in the¶

17 last decade?¶

18 A. Right.¶

19 Q. Going back to the time when¶

20 Virginia was less than 21, at that period of¶

21 time, did you believe that Virginia was¶

22 giving Mr. Epstein massages?¶

23 A. I do think she was giving him¶

24 massages.¶

25 Q. Is it your testimony that the only¶

Page 41¶

1 G. Maxwell - Confidential¶

2 female that you had any reason to believe was¶

3 under 21 who was giving Mr. Epstein massages¶

4 was Virginia?¶

5 MR. PAGLIUCA: Object to the form¶

6 and foundation.¶

7 A. First of all, I didn't know how old¶

8 Virginia was, so other than Virginia, so I¶

9 can't say, but other than -- I was not aware¶

10 of anybody else, no.¶

11 Q. You first met Virginia when?¶

12 A. I don't know.¶

13 Q. Approximately?¶

14 A. I believe it was in 2000, but now¶

15 I'm going off the knowledge that I have, not¶

16 from memory, so I met her the end of 2000¶

17 apparently.¶

18 Q. And when you met Virginia in 2000,¶

19 how old did you think she was?¶

20 MR. PAGLIUCA: Object to the form¶

21 and foundation.¶

22 A. I didn't think about how old she¶

23 was. I don't recall the actual meeting of¶

24 Virginia, so I can't say, but I think she was¶

25 at least, I thought she was a professional¶

Page 42¶

1 G. Maxwell - Confidential¶

2 masseuse as far as I can recall today, so¶

3 that would have made her, I thought that¶

4 would have made her, to work in a spa, I¶

5 didn't think about, and I, I thought she¶

6 appeared to be a professional masseuse.¶

7 Q. Remember questions a while ago¶

8 where you made a big point about people being¶

9 adult masseuses?¶

10 A. Right, yeah.¶

11 Q. When you met Virginia for the first¶

12 time --¶

13 A. Right.¶

14 Q. -- did you think she was an adult¶

15 masseuse, as you use that term?¶

16 A. I don't recall actually meeting¶

17 Virginia at the time, and in fact, were it¶

18 not for this case, I'm not sure I would¶

19 recall her at all.¶

20 Q. But you do recall knowing Virginia?¶

21 A. I do, yes.¶

22 Q. You do recall knowing that Virginia¶

23 was giving Mr. Epstein massages, correct?¶

24 MR. PAGLIUCA: Object to the form¶

25 and foundation.¶

Page 43¶

1 G. Maxwell - Confidential¶

2 A. I believe she was, but I can't say¶

3 for sure.¶

4 Q. Why do you believe Virginia was¶

5 giving Mr. Epstein massages?¶

6 A. Today, because -- but back then.¶

7 Q. Back then?¶

8 A. Because at some point she would¶

9 have been going to the massage room to give¶

10 massages.¶

11 Q. Back then, in the period around¶

12 2000?¶

13 A. Right.¶

14 Q. You believed that Virginia was¶

15 giving Mr. Epstein massages, correct?¶

16 A. I believe I did, yes.¶

17 Q. At the time back in the period¶

18 around 2000 that you believe that Virginia¶

19 was giving Mr. Epstein massages, how old did¶

20 you think Virginia was at the time?¶

21 MR. PAGLIUCA: Object to the form¶

22 and foundation.¶

23 A. I don't believe that I -- I don't¶

24 know what I thought at the time. It's a long¶

25 time ago and I just have no idea what I¶

Page 44¶

1 G. Maxwell - Confidential¶

2 thought. I really don't recall her, so it's¶

3 hard for me to testify what I thought about¶

4 her age at the time.¶

5 Q. Was Virginia, in the period of¶

6 around 2000, the youngest person that, as you¶

7 understood it, was giving Mr. Epstein¶

8 massages?¶

9 MR. PAGLIUCA: Object to the form¶

10 and foundation.¶

11 A. Again, I can't testify to her age,¶

12 but everybody else that I can recall seemed¶

13 to be again, like I would say, adults.¶

14 Q. You didn't think Virginia was an¶

15 adult, did you?¶

16 MR. PAGLIUCA: Object to the form¶

17 and foundation.¶

18 A. Like I said, I don't recall her. I¶

19 don't recall thinking about -- my memory is¶

20 of adults giving Jeffrey massages, and as I¶

21 don't really remember Virginia around that¶

22 time, I don't know what I think.¶

23 Q. You do remember Virginia, about¶

24 that time back in the 2000s, giving¶

25 Mr. Epstein massages?¶

Page 45¶

1 G. Maxwell - Confidential¶

2 MR. PAGLIUCA: Object to the form¶

3 and foundation.¶

4 A. I barely remember her at all.¶

5 Q. Whether you barely remember her or¶

6 not, you do remember that back in the period¶

7 around 2000, Virginia was giving Mr. Epstein¶

8 massages, right?¶

9 MR. PAGLIUCA: Objection to form¶

10 and foundation.¶

11 A. Only in the most general terms. It¶

12 would be somebody who would give him a¶

13 massage, and that's it.¶

14 Q. During the period of time back in¶

15 the period around 2000, when you knew that¶

16 Virginia was somebody who would give¶

17 Mr. Epstein a massage, was she somebody who¶

18 you considered an adult?¶

19 MR. PAGLIUCA: Objection to form¶

20 and foundation.¶

21 A. I didn't consider her at all¶

22 because she is not somebody that I really¶

23 interacted with.¶

24 Q. It is your testimony that Virginia¶

25 was not somebody that you interacted with, is¶

Page 46¶

1 G. Maxwell - Confidential
2 that what you're saying?
3 A. I said I didn't really interact --
4 it's not that I didn't interact with her at
5 all, but not enough for her to make a very
6 strong and lasting impression.
7 Q. Is it your testimony that you
8 interacted with Virginia, but you didn't
9 really interact with Virginia?
10 MR. PAGLIUCA: Objection to form
11 and foundation.
12 A. I don't understand what that
13 actually even means.
14 Q. You said that you interacted with
15 Virginia. Do you recall that?
16 A. In the most general terms, I do
17 recall her.
18 Q. And then you testified that you
19 didn't really interact with Virginia. Do you
20 recall saying that?
21 A. I consider this a real interaction.
22 I will not be forgetting this any time soon.
23 But the most casual of relationships, where
24 you say hello or to be nice or polite, or
25 offer someone a [REDACTED] of water or something¶

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1 G. Maxwell - Confidential
2 is what I would term a casual interaction.
3 It is not something that, from what are we
4 talking, 17, 18 years ago, something that
5 really sticks out in my mind.
6 Q. Is it your testimony that your only
7 relationship with Virginia was what you
8 referred to as a casual relationship where
9 you might say hello or offer a [REDACTED] of water
10 to be polite?
11 MR. PAGLIUCA: Objection to form
12 and foundation.
13 A. Generally, yes, that's how I would
14 characterize.
15 MR. PAGLIUCA: We've been going for
16 about an hour. I would like to take a
17 break.
18 MR. BOIES: Certainly.
19 THE VIDEOGRAPHER: The time is
20 10:01 a.m., and we are going off the
21 record.
22 (Recess.)
23 THE VIDEOGRAPHER: The time is
24 10:10 a.m., and we are back on the
25 record. This also begins DVD No. 2.¶

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1 G. Maxwell - Confidential
2 MR. PAGLIUCA: We've been going for
3 about an hour this morning. I think
4 you're probably aware that Ms. Maxwell
5 was deposed for a full seven hours on a
6 prior occasion. In my view, the court's
7 order is limited and we shouldn't be
8 covering ground that we covered in the
9 prior deposition.
10 At some point, we are going to need
11 to call the court, if we go at this
12 pace, for instruction about length of
13 time here, because my view is that this
14 is not supposed to be a seven-hour
15 deposition, you are not supposed to be
16 covering old ground, and you should be
17 asking questions related to the, what I
18 characterize as the eight discreet areas
19 related to a, quote, sexual activity
20 which precedes all of the eight items in
21 the court's order of July 10th.
22 We spent a lot of time not talking
23 about those issues, and I suggest we get
24 to it or we get the court on the phone
25 for some guidance about timing here.¶

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1 G. Maxwell - Confidential
2 MR. BOIES: I'm happy to get the
3 court on the phone any time you like. I
4 think the questions clearly relate to
5 sexual activity.
6 MR. PAGLIUCA: How old Virginia
7 [REDACTED] was or not does not relate to
8 sexual activity. Her memory of how old
9 [REDACTED] may or may not have
10 been does not relate to sexual activity,
11 and it was all asked and answered in the
12 prior deposition.
13 MR. BOIES: Your witness introduced
14 the subject, asserting that all of these
15 people were adults. I didn't ask
16 whether they were adults at that time.
17 I simply asked a general question that
18 was expressly covered by the judge's
19 order. Your client opened the door,
20 volunteered this and made it necessary
21 to do this.
22 I am happy to go to the court any
23 time you want, and I'm happy to go over
24 with the court some of these questions
25 and put it in context for the court with¶

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1 G. Maxwell - Confidential
2 respect to what the documentary evidence
3 is. I'm happy to do that any time you
4 want.
5 MR. PAGLIUCA: Let's get on with it
6 and ask some questions that are relevant
7 to what the court ordered here.
8 MR. BOIES: I am asking questions
9 that I think are clearly relevant. If
10 you don't think so, I invite you to take
11 it to the court. If not, then let me
12 get on with my questions. Any time that
13 I get to a point where you think you
14 want to stop the deposition and go to
15 the court, I am more than prepared to do
16 that.
17 BY MR. BOIES:
18 Q. Ms. Maxwell, during the break, did
19 you have conversations with anyone?
20 A. My lawyers.
21 Q. What did your lawyers say to you?
22 MR. PAGLIUCA: Don't answer that
23 question.
24 Q. What did you say to your lawyer?
25 MR. PAGLIUCA: Don't answer that¶

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1 G. Maxwell - Confidential
2 question.
3 Q. Did you ask your lawyer for any
4 legal advice?
5 MR. PAGLIUCA: Don't answer that
6 question.
7 Q. Did your lawyer give you any legal
8 advice?
9 MR. PAGLIUCA: Don't answer that
10 question.
11 MR. BOIES: These are all yes or no
12 questions.
13 MR. PAGLIUCA: She is not answering
14 any of those questions, Mr. Boies.
15 Q. Did your lawyer give you advice as
16 to how to answer the questions I was asking?
17 MR. PAGLIUCA: Don't answer that
18 question.
19 Q. Did your lawyer tell you that you
20 were creating problems for yourself with some
21 of your answers?
22 MR. PAGLIUCA: Don't answer that
23 question.
24 Q. Did your lawyer suggest how you
25 might answer some of my questions?¶

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1 G. Maxwell - Confidential
2 MR. PAGLIUCA: Don't answer that
3 question.
4 Q. Did you have conversations with
5 anyone other than your lawyer during the
6 break?
7 A. No.
8 Q. Did your lawyer tell you why he had
9 taken a break?
10 MR. PAGLIUCA: Don't answer that
11 question.
12 I don't think I did, by the way.
13 MR. BOIES: I'm happy to depose you
14 about it, if you want.
15 MR. PAGLIUCA: Sure.
16 MR. BOIES: I'm serious about that.
17 I'm happy to put you under oath right
18 now, and if you want to start talking
19 about what you did or did not do, I'm
20 happy to interrupt this deposition, put
21 you under oath and let you testify.
22 MR. PAGLIUCA: Ask a question.
23 MR. BOIES: I'm telling you.
24 Otherwise, I suggest you stop making
25 speeches.¶

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2 MR. PAGLIUCA: Why don't we both
3 stop making speeches.
4 BY MR. BOIES:
5 [REDACTED]¶

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2¶

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G. Maxwell - Confidential Epstein's home in Palm Beach?¶

MR. PAGLIUCA: Objection to form¶

and foundation.¶

1 G. Maxwell - Confidential¶

2 MR. PAGLIUCA: Objection to form¶

3 and foundation.¶

4 A.¶

8 : jection to form¶

9 and foundation.¶

10 A.¶

Page 3',¶

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21 MR. PAGLIUCA: Objection to form
22 and foundation.
23 [Redacted]¶

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2 Q. You were aware of how many people
3 gave Mr. Epstein massages?
4 MR. PAGLIUCA: Objection to form
5 and foundation.
6 A. I was not with him actually very
7 often. I was frequently -- we were
8 frequently not together, so I couldn't know
9 what he would be doing when I wasn't with
10 him.
11 But when we were together, the
12 behavior as described as alleged did not
13 happen, so he would have one massage a day,
14 that would be it.
15 Q. So insofar as you were aware and
16 when you were with Mr. Epstein, he only had
17 one massage a day?
18 A. Yeah.
19 Q. Other than [REDACTED], as you
20 understood it at the time, were any of the
21 people that gave Mr. Epstein massages women
22 who were under 21?
23 MR. PAGLIUCA: Objection to form
24 and foundation.
25 A. I don't know what the ages were of¶

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1 G. Maxwell - Confidential
2 the people who were giving him massages, but
3 I believe they were professional masseuses.
4 Q. I think you testified that you
5 believe that [REDACTED] was a
6 professional masseuse, is that correct?
7 MR. PAGLIUCA: Objection to form
8 and foundation.
9 A. Based on how allegedly we met,
10 which was at a spa, I believe that when you
11 work at a spa, you are a professional. So
12 I'm basing my statement based on her working
13 as a professional massage person, at a
14 professional spa.
15 Q. When you met [REDACTED] at the
16 spa, what spa was it?
17 MR. PAGLIUCA: Objection to form
18 and foundation.
19 A. I don't recall the actual meeting,
20 but based on all the evidence and stories, it
21 was at Mar-a-Lago.
22 Q. You just testified that you met
23 [REDACTED] at a spa. Do you recall
24 that?
25 MR. PAGLIUCA: Objection to form¶

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1 G. Maxwell - Confidential
2 and foundation.
3 A. I said I don't recall the actual
4 meeting, but based on the evidence that we
5 have been produced, and I now believe it was
6 at Mar-a-Lago that that meeting may have
7 taken place.
8 Q. When you met [REDACTED], did
9 you understand that she was at that time a
10 professional masseuse?
11 MR. PAGLIUCA: Objection to form
12 and foundation.
13 A. I don't recall the actual first
14 meeting, I don't know.
15 Q. Whether or not you recall the
16 actual first meeting, was it your
17 understanding that [REDACTED] was a
18 professional masseuse?
19 MR. PAGLIUCA: Objection to form
20 and foundation.
21 A. I had no idea at the time, but I
22 believe she was working at a spa, and based
23 on what I believe today, she was a masseuse
24 at Mar-a-Lago.
25 Q. When you say based on what you¶

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1 G. Maxwell - Confidential
2 believe today, you believe she was a masseuse
3 at Mar-a-Lago, what is it that you've learned
4 that leads you to believe she was a masseuse
5 at Mar-a-Lago?
6 A. She worked at the spa, and that's
7 all I know, that she was 17 and that she held
8 herself out to be a masseuse.
9 Q. She told you she was a masseuse?
10 A. I don't know if she told me at the
11 time she was a masseuse. I believe today she
12 was a masseuse working at Mar-a-Lago and she
13 was 17 years old.
14 Q. You said she held herself out as a
15 masseuse. Do you recall that?
16 A. I just said it. The problem is I
17 don't recall with specificity. I don't
18 recall the actual meeting, so events in my
19 mind are conflated with all of her stories,
20 all of the lies that have been told.
21 So, today, I believe that she was a
22 17-year-old masseuse at Mar-a-Lago.
23 Q. Did she ever tell you that she was
24 a masseuse at Mar-a-Lago?
25 A. I don't recall specific¶

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1 G. Maxwell - Confidential
2 conversations with Virginia. Like I said, I
3 would actually barely remember her at all
4 were it not for this case.
5 Q. Why, then, do you believe she was a
6 masseuse at Mar-a-Lago?
7 A. Based on having met her at
8 Mar-a-Lago. I don't know why else she would
9 be at the house.
10 Q. At what house?
11 A. Why would she come to Jeffrey's
12 house if she was not a masseuse at
13 Mar-a-Lago, why else would she come.
14 Q. Did you ask her to come to
15 Jeffrey's house?
16 A. I don't recall the first meeting or
17 how it went down that she came to give
18 Jeffrey a massage or whatever she came to do.
19 All I remember as I testified in my first
20 deposition is that her mother came and that
21 we sat outside and I talked to her mother,
22 and that she went in and met Jeffrey and then
23 she left. And then subsequent to that, I
24 understand she gave him massages.
25 Q. My question was a simple yes or no¶

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1 G. Maxwell - Confidential
2 question. Did you ask her to come to
3 Jeffrey's house?
4 A. I can't recall exactly the meeting.
5 Q. In response, I got a paragraph that
6 makes a number of assertions that I'm now
7 going to have to follow-up. I'm prepared to
8 do that, but in light of your counsel's
9 desire to move the deposition along, I won't
10 have to follow-up things that you volunteer
11 if you don't volunteer them.
12 So if you will focus on my
13 question, and if it is simply a yes or no
14 answer and you give a yes or no answer, that
15 will shorten the deposition. If you want to
16 say other things, I'm not going to try to
17 stop you, but I am going to follow-up on what
18 you say.
19 My question now is simply, do you
20 recall, one way or the other, as you sit here
21 now, whether you asked [REDACTED] to
22 come to Mr. Epstein's house?
23 A. I do not.
24 Q. Do you recall, as you sit here now,
25 one way or another, whether [REDACTED]¶

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1 G. Maxwell - Confidential¶

2 was a masseuse, a towel girl, a maintenance¶

3 person or any other type employee at¶

4 Mar-a-Lago?¶

5 A. I do not.¶

6 Q. Did Mr. Epstein ever ask you to¶

7 attempt to obtain or secure people to give¶

8 him massages that were not professional¶

9 masseuses?¶

10 A. No.¶

11 Q. Do you remember somebody by the¶

12 name of [REDACTED]¶

13 A. I don't believe I ever met him.¶

14 Q. You don't believe you ever met him?¶

15 A. No.¶

16 Q. Do you remember anyone other than¶

17 yourself who secured or obtained people to¶

18 give Mr. Epstein massages?¶

19 MR. PAGLIUCA: Objection to form¶

20 and foundation.¶

21 A. Can you ask the question again,¶

22 please?¶

23 Q. Do you remember anyone other than¶

24 yourself who secured or obtained people to¶

25 give Mr. Epstein massages?¶

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1 G. Maxwell - Confidential¶

2 MR. PAGLIUCA: Objection to form¶

3 and foundation.¶

4 A. I believe Jeffrey did get massages¶

5 from other people who were recommendations¶

6 from other people for massages that had¶

7 nothing to do with me.¶

8 Q. Do you know who?¶

9 A. I only know what I read. Virginia¶

10 gave people.¶

11 Q. Other than what Virginia had said¶

12 in the last 10 years, were you aware of¶

13 anyone who was obtaining people to give¶

14 Mr. Epstein massages other than yourself?¶

15 A. I'm not -- I don't know what other¶

16 people do. I know that other people¶

17 recommended massages to him, but I can't¶

18 testify to what other people do for him or¶

19 did for him.¶

20 Q. Back in the 1990s and the 2000s,¶

21 did you see women under the age of 21 at¶

22 Mr. Epstein's houses?¶

23 MR. PAGLIUCA: This has been asked¶

24 and answered in her prior deposition.¶

25 Do you understand that? It's been¶

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1 G. Maxwell - Confidential¶

2 covered extensively.¶

3 MR. BOIES: I understand what the¶

4 prior deposition --¶

5 A. Other than friends of my family and¶

6 friends of other people's people, and the¶

7 people that I've identified, I am aware that¶

8 Jeffrey had friends that came over that¶

9 brought their kids with them from time to¶

10 time.¶

11 Q. These kids that you refer to, they¶

12 didn't give Mr. Epstein massages, did they?¶

13 MR. PAGLIUCA: Mr. Boies, this has¶

14 been asked and answered already.¶

15 MR. BOIES: I don't think that¶

16 particular question was asked and¶

17 answered, but whether it was asked and¶

18 answered or not, you can instruct not to¶

19 answer and then we will move on. I¶

20 think we take much more time with your¶

21 interjections than we would if you¶

22 simply let the witness answer the¶

23 question.¶

24 MR. PAGLIUCA: Well, we do, but¶

25 then we go down this road where you keep¶

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1 G. Maxwell - Confidential¶

2 asking these questions that have already¶

3 been asked and answered.¶

4 So the witness can answer the¶

5 question, but let's stick to the topic¶

6 here.¶

7 MR. BOIES: If you want to instruct¶

8 her not to answer, instruct her not to¶

9 answer. You are not going to convince¶

10 me with speeches.¶

11 A. What is the question, please?¶

12 Q. You referred to friends of¶

13 Mr. Epstein bringing their kids with them¶

14 when they came over?¶

15 A. Yes.¶

16 Q. Those kids, as you described, did¶

17 not give Mr. Epstein massages, correct?¶

18 A. I don't believe so.¶

19 Q. Limiting the people that we're¶

20 talking about just to people who gave¶

21 Mr. Epstein massages or who were brought to¶

22 the home to give Mr. Epstein massages, were¶

23 there people other than you who were¶

24 responsible for bringing those people to Mr.¶

25 Epstein's house?¶

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1 G. Maxwell - Confidential¶

2 MR. PAGLIUCA: Objection to form¶

3 and foundation.¶

4 A. I have no idea.¶

5 [REDACTED]¶

6 [REDACTED]¶

7 [REDACTED]¶

8 [REDACTED]¶

9 [REDACTED]¶

10 [REDACTED]¶

11 [REDACTED]¶

12 Q. Did [REDACTED] ever give Mr. Epstein a¶

13 massage?¶

14 A. I believe she did.¶

15 Q. Did she ever give you a massage?¶

16 A. She did.¶

17 Q. Was she what you referred to as a¶

18 professional masseuse?¶

19 A. I would.¶

20 Q. Had she ever worked in a spa?¶

21 A. I don't know if she worked in a¶

22 spa.¶

23 Q. Had she ever, prior to giving you¶

24 and Mr. Epstein massages, had she ever given¶

25 massages to other people?¶

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1 G. Maxwell - Confidential¶

2 MR. PAGLIUCA: Objection to form¶

3 and foundation.¶

4 A. I have no idea, I don't know.¶

5 Q. Prior to the time that [REDACTED] gave¶

6 you and Mr. Epstein massages, had she been a¶

7 professional masseuse?¶

8 MR. PAGLIUCA: Objection to form¶

9 and foundation.¶

10 A. I believe she went to massage¶

11 school and became a professional masseuse.¶

12 Q. Did she go to massage school before¶

13 or after you met her?¶

14 A. I believe after.¶

15 Q. Who paid for her massage school?¶

16 A. I have no idea.¶

17 Q. Who arranged for her to go to¶

18 massage school?¶

19 A. I have no idea.¶

20 Q. Did she ever give Mr. Epstein a¶

21 massage before she went to massage school?¶

22 A. I have no idea.¶

23 Q. Did she ever give you a massage¶

24 before she went to massage school?¶

25 A. I have no idea.¶

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1 G. Maxwell - Confidential¶

2 Q. Where did she go to massage school?¶

3 A. I don't know.¶

4 Q. When did she go to massage school?¶

5 A. I don't know.¶

6 Q. Did she tell you she went to¶

7 massage school?¶

8 A. I don't recall.¶

9 Q. Did someone else tell you she went¶

10 to massage school?¶

11 A. I don't recall. It's my belief she¶

12 went to massage school and became a¶

13 professional masseuse at some point.¶

14 Q. What is your belief based on?¶

15 A. I don't know why, it's just¶

16 something, I must have had a conversation¶

17 with her, I think, about it, but I don't¶

18 recall specifically the conversation. Just¶

19 in general terms, that's what I believe.¶

20 Q. Is it your testimony that she told¶

21 you in general terms in a conversation that¶

22 she had gone to massage school?¶

23 A. I don't recall a specific¶

24 conversation, but that is my general¶

25 impression.¶

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2 Q. Do you know how long she was in¶

3 massage school?¶

4 A. I don't.¶

5 Q. Did Mr. Epstein ask her to go to¶

6 massage school?¶

7 A. I don't know.¶

8 Q. How old was [REDACTED] when she gave¶

9 you a massage?¶

10 A. Mid 20s, I believe.¶

11 Q. And was the timeframe in which she¶

12 gave Mr. Epstein a massage the same timeframe¶

13 she gave you a massage?¶

14 A. I really don't recall. I can only¶

15 recall her giving me massages. I know she¶

16 gave Mr. Epstein massages, but I don't recall¶

17 them. I know she gave me them, I know she¶

18 gave me massages.¶

19 Q. How old was she when she gave¶

20 Mr. Epstein massages?¶

21 A. I met her, I believe, when she was¶

22 in her mid 20.s, it would have been in her¶

23 mid 20s.¶

24 Q. Did Mr. Epstein, insofar as you¶

25 believe, engage in sexual activities with¶

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1 G. Maxwell - Confidential¶

2 [REDACTED]¶

3 A. I would not know. I would say no.¶

4 Q. Did you engage in sexual activities¶

5 with [REDACTED]¶

6 A. No.¶

7 Q. Do you know how [REDACTED] came to¶

8 know Mr. Epstein?¶

9 A. I met her at her university [REDACTED]¶

10 [REDACTED]¶

11 [REDACTED]¶

12 [REDACTED]¶

13 A. In Palm Beach.¶

14 Q. At Mr. Epstein's home in Palm¶

15 Beach?¶

16 A. Yes.¶

17 Q. So is it fair to say that [REDACTED]¶

18 [REDACTED]¶

19 [REDACTED]¶

20 MR. PAGLIUCA: This has already¶

21 been testified to Mr. Boies. We are¶

22 repeating testimony now.¶

23 MR. BOIES: I think in the context¶

24 of the witness' answers, these are fair¶

25 questions.¶

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1 G. Maxwell - Confidential¶

2 Now, I've asked you before, if you¶

3 want to instruct her not to answer, if¶

4 you want to go to the judge, we are¶

5 happy to do that, but I would suggest,¶

6 in the interest of moving it along, that¶

7 you stop these speeches.¶

8 MR. PAGLIUCA: You are not moving¶

9 it along is the problem, so maybe we¶

10 should call the court and get some¶

11 direction here, because I am not going¶

12 to sit here and rehash the testimony we¶

13 already gave.¶

14 MR. BOIES: That's fine.¶

15 THE VIDEOGRAPHER: The time is¶

16 10:51 a.m. and we are going off the¶

17 record.¶

18 (Whereupon, an off-the-record¶

19 discussion was held.)¶

20 THE VIDEOGRAPHER: The time is¶

21 10:56 a.m. and we are going back on the¶

22 record. This begins DVD No. 3.¶

23 MR. BOIES: We have just had a call¶

24 with Judge Sweet's [REDACTED]. Judge Sweet¶

25 is not available and his [REDACTED]¶

Page 80¶

1 G. Maxwell - Confidential¶

2 instructed that the right way to do it¶

3 was to bring any issue to him after the¶

4 conclusion of the deposition.¶

5 The question that has been raised¶

6 is whether we should interrupt the¶

7 deposition now and seek guidance of the¶

8 court before continuing the deposition.¶

9 My view is that the deposition¶

10 needs to continue, and the counsel for¶

11 the defendant can instruct not to answer¶

12 and any questions that are instructed¶

13 not to answer can be brought to the¶

14 court, but I would not consent to¶

15 terminating the deposition at this¶

16 point.¶

17 MR. PAGLIUCA: I don't know if it's¶

18 a matter of consent or not. If I move¶

19 for a protective order, the deposition¶

20 is over and we can go litigate it in¶

21 front of Judge Sweet. We are here and¶

22 I'd like to complete this deposition¶

23 because this case needs to move along,¶

24 and quite frankly, I don't want to spend¶

25 money coming back here to do this again¶

Page 81¶

1 G. Maxwell - Confidential¶

2 or argue this in front of Judge Sweet.¶

3 But I will simply start referring¶

4 you back to the transcript and¶

5 instructing the witness not to answer¶

6 when I think we are getting into some¶

7 things that have been asked and answered¶

8 already.¶

9 MR. BOIES: Exactly the procedure¶

10 that I have proposed from the beginning.¶

11 If you think a question is out of¶

12 bounds, instruct not to answer and we¶

13 will then let the judge decide it.¶

14 BY MR. BOIES:¶

15 Q. How did it happen, Ms. Maxwell,¶

16 that [REDACTED]¶

17 [REDACTED], ended up giving massages to you¶

18 and Mr. Epstein?¶

19 MR. PAGLIUCA: I'm going to¶

20 instruct you not to answer the question.¶

21 This has been previously, the subject of¶

22 your former deposition, it doesn't fall¶

23 into any of the categories ordered by¶

24 the court, and so you don't need to¶

25 answer that.¶

![](_page_21_Picture_51.jpeg)¶

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1 G. Maxwell - Confidential¶

2 Q. Was [REDACTED] paid for the massages¶

3 that she gave you?¶

4 A. I didn't pay her, so I believe she¶

5 was paid.¶

6 Q. Who paid her?¶

7 A. I don't know who paid her.¶

8 MR. PAGLIUCA: Again, you've¶

9 already answered that there was no¶

10 sexual activity between yourself and¶

11 Mr. Epstein related to these massages.¶

12 That's record testimony today. That's¶

13 within the scope of the court's order.¶

14 The rest of this is outside the scope of¶

15 the court's order, and I instruct you¶

16 not to answer.¶

17 MR. BOIES: You are taking the¶

18 position that as long as she said says¶

19 that a massage did not involve sexual¶

20 activity, we cannot ask about massages.¶

21 That's your view?¶

22 MR. PAGLIUCA: On this particular¶

23 questioning, yes.¶

24 BY MR. BOIES:¶

25 Q. Did Mr. Epstein pay [REDACTED] for the¶

Page 83¶

1 G. Maxwell - Confidential¶

2 massages that she gave Mr. Epstein?¶

3 MR. PAGLIUCA: You just asked this¶

4 question, and I told her not to answer.¶

5 I will tell her not to answer again for¶

6 the same reasons.¶

7 Q. Do you know how much Mr. Epstein¶

8 paid Johanna to give massages?¶

9 MR. PAGLIUCA: Same instruction to¶

10 the witness. Why do you believe this is¶

11 within the scope of the court's order?¶

12 MR. BOIES: Because of the court's¶

13 reference to massages, and because I¶

14 think how much a girl [REDACTED]¶

15 [REDACTED] was paid to give a¶

16 "massage" goes to whether there actually¶

17 was or was not sexual activity involved.¶

18 MR. PAGLIUCA: The witness has¶

19 testified there wasn't.¶

20 MR. BOIES: Perhaps it will¶

21 surprise you, I think it should not,¶

22 that I do not believe in my deposition I¶

23 need to simply accept her¶

24 characterization without¶

25 cross-examination. Now, that's¶

Page 84¶

1 G. Maxwell - Confidential¶

2 something the judge can decide, but a¶

3 question as to how much this young girl¶

4 was being paid for a "massage", I think¶

5 goes directly to the issue of sexual¶

6 activity.¶

7 MR. PAGLIUCA: Here is the problem,¶

8 Mr. Boies, at the first deposition,¶

9 there were very limited instructions not¶

10 to answer and the witness was not told¶

11 not to answer questions about how much¶

12 people were paid or not paid or any of¶

13 those subject matters. The witness was¶

14 only instructed not to answer about¶

15 sexual activity concerning adults in the¶

16 home.¶

17 None of this came up during the¶

18 deposition, and you just don't get a¶

19 chance to redo the deposition because¶

20 you feel like you want to.¶

21 So the judge's order is in the¶

22 context of the instructions to the¶

23 witness not to answer in the first¶

24 deposition, which is simply sexual¶

25 activity involving adults, which was the¶

Page 85¶

1 G. Maxwell - Confidential¶

2 only area that the witness was precluded¶

3 from talking about in the first¶

4 deposition. So that's where we're at.¶

5 MR. BOIES: I think that directly¶

6 misreads the judge's order, including¶

7 where it says: Defendant is ordered to¶

8 answer questions relating to defendant's¶

9 own sexual activity with or involving¶

10 Jeffrey Epstein, with or involving¶

11 plaintiff, with or involving underage¶

12 females, involving or including massage¶

13 with individuals defendant knew to be or¶

14 believed might become known to Epstein.¶

15 MR. PAGLIUCA: All of it is¶

16 preceded by the word sexual activity.¶

17 MR. BOIES: I think your point of¶

18 view is an interesting one, but we will¶

19 see what the judge rules on it.¶

20 BY MR. BOIES:¶

21 [REDACTED]¶

Page 86¶

1 G. Maxwell - Confidential
2 and foundation.
3 A. [REDACTED]
4 [REDACTED]
5 [REDACTED]
6 [REDACTED]
7 MR. PAGLIUCA: Objection to form
8 and foundation.
9 A. I don't know.
10 Q. Did any of them give you massages?
11 A. No.
12 Q. [REDACTED]
13 [REDACTED]
14 [REDACTED]
15 MR. PAGLIUCA: Objection to form
16 and foundation. Asked and answered.
17 A. No.
18 Q. Were they ever in the Virgin
19 Islands?
20 MR. PAGLIUCA: Objection to form
21 and foundation.
22 A. No.
23 [REDACTED]
24 [REDACTED]
25 [REDACTED]¶

Page 88¶

Page 87¶

Page 89¶

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1 G. Maxwell - Confidential¶

2¶

Page 91¶

1 G. Maxwell - Confidential 2 it to something in the case.¶

3 MR. BOLES: I think it's tied, but 4 if you instruct her not to answer, it¶

5 goes into the --¶

6 MR. PAGLIUCA: Meat grinder.¶

BY MR. BOLES:¶

14 A. an ou re eat t e uestion.¶

15¶

20 . AGLIUCA: Same objection.¶

21 A. No. 22 .¶

1 2 3¶

25¶

Page 93¶

G. Maxwell - Confidential¶

MAGNAO¶

Page 94¶

1 G. Maxwell - Confidential¶

2 [REDACTED]¶

3 A. I do.¶

4 MR. BOIES: Let me show you a¶

5 document that has been marked for¶

6 identification as Maxwell Deposition¶

7 Exhibit 27.¶

8 (Maxwell Exhibit 27, Article,¶

9 marked for identification, as of this¶

10 date.)¶

11 MR. PAGLIUCA: I'm going to need a¶

12 moment to review this, counsel.¶

13 MR. BOIES: Sure. Let me know when¶

14 you are finished.¶

15 MR. PAGLIUCA: I will.¶

16 Okay.¶

17 BY MR. BOIES:¶

18 Q. Did you see this article prior to¶

19 the time I'm showing it to you?¶

20 A. No.¶

21 Q. This is the first time you have¶

22 seen this article?¶

23 A. Yes.¶

24 Q. When did you first meet [REDACTED]¶

25 MR. PAGLIUCA: You are not¶

Page 95¶

1 G. Maxwell - Confidential¶

2 answering those questions. That has¶

3 nothing to do with what we're here for¶

4 today. We will take that up with the¶

5 judge, if we need to.¶

6 Q. Let me direct your attention to a¶

7 portion of this article. Did [REDACTED] ever¶

8 talk to you about women that she believed¶

9 Mr. Epstein had had sex with?¶

10 MR. PAGLIUCA: Don't answer that¶

11 question. We will take that up with the¶

12 judge.¶

13 MR. BOIES: Okay.¶

14 Q. Did [REDACTED] ever mention to you a¶

15 [REDACTED]¶

16 A. She did.¶

17 Q. Did [REDACTED] ever mention to you an¶

18 [REDACTED]¶

19 A. She did.¶

20 Q. When did [REDACTED]¶

21 [REDACTED]¶

22 A. She called me and asked me, I don't¶

23 know if she mentioned -- I want to take that¶

24 back. I don't know if she mentioned [REDACTED]¶

25 [REDACTED]. I think she just mentioned [REDACTED]¶

Page 96¶

1 G. Maxwell - Confidential¶

2 [REDACTED]¶

3 Q. Who was [REDACTED]¶

4 A. [REDACTED]¶

5 [REDACTED]¶

6 Q. [REDACTED]¶

7 [REDACTED]¶

8 A. Uh-huh.¶

9 Q. Who was [REDACTED]¶

10 A. [REDACTED]¶

11 [REDACTED]¶

12 [REDACTED]¶

13 Q. Did you know [REDACTED]¶

14 A. I did.¶

15 Q. When did you first meet [REDACTED]¶

16 [REDACTED]¶

17 A. I don't recall.¶

18 Q. Did you see [REDACTED] at¶

19 Mr. Epstein's house in Palm Beach?¶

20 A. No, I don't think so.¶

21 Q. Where did you see [REDACTED]¶

22 A. I believe I met her in New York at¶

23 some point.¶

24 Q. Did you see [REDACTED] at¶

25 Mr. Epstein's house in New York?¶

Page 97¶

1 G. Maxwell - Confidential¶

2 A. I don't recall meeting her there,¶

3 but -- I may have, but I don't recall.¶

4 Q. Did you ever meet [REDACTED]¶

5 A. I did.¶

6 Q. Where did you meet [REDACTED]¶

7 A. She was in New Mexico.¶

8 Q. At Mr. Epstein's property in New¶

9 Mexico?¶

10 A. Yes.¶

11 Q. And did Mr. Epstein ever have sex¶

12 with [REDACTED]¶

13 A. I have no idea.¶

14 Q. Did Mr. Epstein ever engage in¶

15 sexual activities with [REDACTED]¶

16 A. I have no idea.¶

17 Q. Did Mr. Epstein ever engage in¶

18 sexual activities with [REDACTED]¶

19 A. I don't know, I don't think so.¶

20 Q. Did [REDACTED] ever work for¶

21 Mr. Epstein?¶

22 A. I don't know.¶

23 Q. Did [REDACTED] ever visit you at¶

24 your apartment?¶

25 A. I don't recall her ever coming.¶

![](_page_25_Picture_85.jpeg)¶

Page 98¶

1 G. Maxwell - Confidential¶

2 Q. Did you ever fly on Mr. Epstein's¶

3 plane with [REDACTED]¶

4 A. I don't remember.¶

5 Q. Did you ever fly on Mr. Epstein's¶

6 plane with [REDACTED]¶

7 A. I don't think so.¶

8 Q. Did [REDACTED] ever give¶

9 Mr. Epstein a massage?¶

10 A. I don't -- I have no idea.¶

11 Q. Did [REDACTED]¶

12 [REDACTED]¶

13 A. I don't recall.¶

14 Q. What did [REDACTED] tell you about¶

15 [REDACTED] when she talked to you?¶

16 MR. PAGLIUCA: You don't have to¶

17 answer that. That has nothing to do¶

18 with the court's order and why we are¶

19 here.¶

20 Q. Did [REDACTED]¶

21 [REDACTED]¶

22 [REDACTED] had said that Mr. Epstein had engaged¶

23 in sexual activities with her?¶

24 A. She never said that.¶

25 Q. Excuse me?¶

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1 G. Maxwell - Confidential¶

2 A. I don't recall ever hearing such a¶

3 thing.¶

4 Q. You know [REDACTED], correct?¶

5 A. I do.¶

6 Q. Do you know whether or not [REDACTED]¶

7 [REDACTED]¶

8 [REDACTED]¶

9 MR. PAGLIUCA: Can you tell me how¶

10 that relates to this order, counselor?¶

11 MR. BOIES: Yes, I think it goes¶

12 directly to the sexual activity related¶

13 to [REDACTED] and what Mr. Epstein was¶

14 doing with [REDACTED]¶

15 Again, you can instruct not to¶

16 answer.¶

17 MR. PAGLIUCA: I'm trying to¶

18 understand why you are asking these¶

19 questions before I --¶

20 MR. BOIES: I'm asking these¶

21 questions because these are people who¶

22 not only have been publicly written¶

23 about in terms of the sexual activity¶

24 that they were put into in connection¶

25 with Mr. Epstein, but the person who¶

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1 G. Maxwell - Confidential¶

2 wrote about them is somebody who talked¶

3 to this witness about it, and I think¶

4 that this is more than easily understood¶

5 cross-examination.¶

6 MR. PAGLIUCA: Your question was,¶

7 do you know whether or not [REDACTED]¶

8 [REDACTED]¶

9 [REDACTED].¶

10 MR. BOIES: Yes. And if you let¶

11 her answer, you will see where it leads.¶

12 If you won't let her answer, the judge¶

13 is going to determine it. And I just¶

14 suggest to you that you stop these¶

15 speeches and stop debating, because you¶

16 are not going to convince me not to¶

17 follow-up on these questions. If you¶

18 can convince the court to truncate the¶

19 deposition, that's your right, but all¶

20 you're doing is dragging this deposition¶

21 out.¶

22 MR. PAGLIUCA: You have the¶

23 opportunity to give me a good faith¶

24 basis why you are asking these¶

25 questions.¶

Page 101¶

1 G. Maxwell - Confidential¶

2 MR. BOIES: I have given you a good¶

3 faith basis.¶

4 MR. PAGLIUCA: You haven't.¶

5 MR. BOIES: Then instruct not to¶

6 answer.¶

7 MR. PAGLIUCA: I am giving you the¶

8 opportunity to say why you are asking¶

9 the question, and why I'm telling her¶

10 not to answer and I am entitled to know¶

11 that.¶

12 MR. BOIES: You are not entitled to¶

13 know why I'm asking the question. You¶

14 are only entitled to know that it¶

15 relates to the subject matter that I am¶

16 entitled to inquire about, and I don't¶

17 think the judge is going to think that,¶

18 you know, where Mr. Epstein shipped¶

19 [REDACTED] off to is outside the scope¶

20 of what I'm entitled to inquire about.¶

21 THE WITNESS: Can we take a break?¶

22 MR. BOIES: Only if you commit not¶

23 to talk to your counsel during the¶

24 break.¶

25 THE WITNESS: That's ludicrous.¶

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1 G. Maxwell - Confidential¶

2 MR. BOIES: You want a break to¶

3 talk to your counsel, right?¶

4 THE WITNESS: I want to use the¶

5 bathroom.¶

6 MR. BOIES: You want to talk to¶

7 your counsel, right?¶

8 THE WITNESS: I talk to my counsel¶

9 all the time.¶

10 MR. BOIES: I don't want you¶

11 talking to your counsel while I'm in the¶

12 middle of this examination.¶

13 MR. PAGLIUCA: I'm going to talk to¶

14 her, so are we going to sit here and go¶

15 for the rest of the day until we're¶

16 done?¶

17 MR. BOIES: No, but I'm going to go¶

18 through the rest of this line of¶

19 questioning, unless you take her and¶

20 walk out and then, I'm going to protest¶

21 that to the judge.¶

22 MR. PAGLIUCA: He is refusing a¶

23 bathroom break to you right now.¶

24 MR. BOIES: No, I'm not. I'm happy¶

25 to have her take a bathroom break as¶

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1 G. Maxwell - Confidential¶

2 long as she doesn't use it as an excuse¶

3 to get coached by her lawyer.¶

4 THE WITNESS: For the record, I¶

5 want to object strongly to that.¶

6 MR. PAGLIUCA: You don't talk now.¶

7 Do you want to go to the bathroom?¶

8 THE WITNESS: Yes.¶

9 MR. PAGLIUCA: How about if I stay¶

10 here, Mr. Boies, will that work for you?¶

11 MR. BOIES: Absolutely.¶

12 THE VIDEOGRAPHER: The time is¶

13 11:31, and we are going off the record.¶

14 (Recess.)¶

15 THE VIDEOGRAPHER: The time is¶

16 11:34 a.m. and we are back on the¶

17 record. This also begins DVD No. 4.¶

18 BY MR. BOIES:¶

19 Q. Let me approach it this way. If¶

20 you turn to page 5 of 7 of the exhibit that¶

21 is Vicky [REDACTED] Daily Beast article. And if¶

22 you look at the third paragraph where [REDACTED]¶

[REDACTED] writes: What I had "on the girls" were¶

24 some remarkably brave first-person accounts.¶

25 Three on-the-record stories from the family,¶

Page 104¶

1 G. Maxwell - Confidential¶

2 a mother and her daughters who came from¶

3 Phoenix. The oldest daughter, an artist,¶

4 whose character was vouchsafed to me by¶

5 several sources, including the artist, Eric¶

6 Fischl, had told me weeping as she sat in my¶

7 living room, of how Epstein had attempted to¶

8 seduce both her and separately and her¶

9 younger sister, then only 16."¶

10 Did [REDACTED] tell you that?¶

11 A. No.¶

12 Q. Did [REDACTED] tell you that her¶

13 information was that [REDACTED]¶

14 [REDACTED]¶

15 A. No.¶

16 Q. Did you and Mr. Epstein visit [REDACTED]¶

17 [REDACTED]¶

18 A. I don't know I would characterize¶

19 the word visit with Mr. Epstein. We went for¶

20 business in Ohio because [REDACTED]¶

21 [REDACTED], and I accompanied him on a few¶

22 visits.¶

23 Q. Did you and Mr. Epstein go to Ohio,¶

24 and while you were in Ohio, see [REDACTED]¶

25¶

Page 105¶

1 G. Maxwell - Confidential¶

2 A. I believe actually that she was --¶

3 stayed at his house there, so I would have¶

4 seen her at the house. I believe I do recall¶

5 seeing her at the house, actually.¶

6 Q. When you say she stayed at the¶

7 house, you are referring to [REDACTED]¶

8 A. Yeah, I think [REDACTED] was¶

9 painting or something in Ohio, and he let her¶

10 stay at a place that he had.¶

11 Q. When you say "he" let her stay, you¶

12 are talking about [REDACTED]¶

13 A. No, I'm talking about Jeffrey¶

14 Epstein.¶

15 Q. So when you saw [REDACTED] in¶

16 Ohio, it was your understanding that she was¶

17 staying at property that Mr. Epstein had in¶

18 Ohio, is that correct?¶

19 A. I don't know if it was his property¶

20 or he rented it, I don't know what the nature¶

21 was. It was a property that he had that she¶

22 stayed at.¶

23 Q. [REDACTED] was staying in Ohio at¶

24 some property, and you don't know whose¶

25 property it was, is that fair?¶

Page 106¶

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1 G. Maxwell - Confidential
2 A. I don't know what -- I don't know
3 who owned -- I don't know anything about the
4 ownership of the property or how Jeffrey had
5 it or why he stayed there, I don't know.¶

6 Q. Was it clear to you that Jeffrey
7 had arranged for [REDACTED] to stay at
8 wherever she was staying in Ohio?¶

9 MR. PAGLIUCA: Objection to form
10 and foundation.¶

11 A. I have no idea what the arrangement
12 was between [REDACTED] and Jeffrey.¶

13 Q. When you referred to the property
14 where [REDACTED] was staying, you said you
15 didn't know how Jeffrey had it?¶

16 A. What's your question?¶

17 Q. Was it your understanding that
18 Jeffrey did have that property that she was
19 staying at in some capacity or another,
20 either owning it or leasing it or having been
21 given it by a friend?¶

22 MR. PAGLIUCA: Objection to form
23 and foundation.¶

24 A. I have no idea.¶

25 Q. Where was this property that you¶

1 G. Maxwell - Confidential
2 house in Columbus, Ohio, correct?¶

3 A. I don't know the arrangement that
4 [REDACTED] had with Jeffrey. I believe she
5 was painting there, but I was never aware of
6 the arrangement. I know that I saw her in
7 Ohio at a house.¶

8 Q. When you were with [REDACTED] at
9 this house in Columbus, Ohio, Mr. Epstein was
10 with you, correct?¶

11 A. I went to Ohio with him on
12 business, and we were at a house that he
13 could stay at and I stayed at, and I recall
14 [REDACTED] being at this house. That is
15 what I recall.¶

16 Q. When you went to Ohio with
17 Mr. Epstein, did you see [REDACTED] on more
18 than one occasion?¶

19 A. I don't recall.¶

20 Q. You saw [REDACTED] in Ohio with
21 Mr. Epstein on at least one occasion,
22 correct?¶

23 MR. PAGLIUCA: Objection to form
24 and foundation.¶

25 A. I recall seeing her in Ohio, but I¶

Page 107¶

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1 G. Maxwell - Confidential
2 and Mr. Epstein visited [REDACTED] at in
3 Ohio?¶

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

6 A. It was in Columbus.¶

7 Q. Was it a house or an apartment?¶

8 A. It was a house.¶

9 Q. When you and Mr. Epstein visited
10 [REDACTED] at this house in Columbus, was
11 anyone else in the house?¶

12 A. I never visited [REDACTED] at the
13 house.¶

14 Q. Did you see [REDACTED] in Ohio?¶

15 A. I recall seeing her, but I didn't
16 visit. I didn't go to Ohio to see [REDACTED]
17 [REDACTED].¶

18 Q. When you went to Ohio, did you see
19 [REDACTED]¶

20 A. I recall seeing [REDACTED] in
21 Ohio.¶

22 Q. Where did you see her?¶

23 A. I recall seeing her at this house
24 that Jeffrey stayed at.¶

25 Q. [REDACTED] was staying in the¶

1 G. Maxwell - Confidential
2 couldn't tell you how many times I saw her.
3 For sure once, because I have a recollection
4 of seeing her once.¶

5 Q. And the house in which you and
6 Mr. Epsteitein and [REDACTED] were in
7 Columbus, Ohio, was that a house that you and
8 Mr. Epstein were staying in overnight?¶

9 A. I stayed overnight there.¶

10 Q. Was [REDACTED] staying there
11 overnight?¶

12 A. I don't recall.¶

13 Q. How many nights did you and
14 Mr. Epstein stay in this house in Columbus?¶

15 A. I don't recall.¶

16 Q. Was it more than one?¶

17 A. I don't recall.¶

18 Q. The night or nights that you and
19 Mr. Epstein stayed at this house in Columbus,
20 was [REDACTED] there?¶

21 A. I don't recall.¶

22 Q. When you saw [REDACTED] in Ohio,
23 did you talk to her?¶

24 A. I'm assuming I must have said
25 hello, so yes.¶

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1 G. Maxwell - Confidential
2 Q. Other than assuming you may have
3 said hello, did you have any conversations
4 with her?
5 A. Not that I recall.
6 Q. Did [REDACTED] complain to you or
7 Mr. Epstein about anything?
8 MR. PAGLIUCA: Objection to form
9 and foundation.
10 A. I don't know what she would have
11 done if she complained to Jeffrey about
12 anything, but she didn't complain to me, as
13 far as I recall.
14 Q. As far as you know, she didn't
15 complain to Mr. Epstein,, is that correct?
16 A. I have no knowledge of what she did
17 or didn't do in that regard.
18 Q. Did she call the police or threaten
19 to call the police because of anything that
20 either you or Mr. Epstein did?
21 MR. PAGLIUCA: Objection to form
22 and foundation.
23 A. I never ever heard that.
24 Q. [REDACTED] didn't tell you, is your
25 testimony?¶

1 G. Maxwell - Confidential
2 ever see [REDACTED]
3 A. I don't recall ever seeing her.
4 Q. [REDACTED]
5 [REDACTED]
6 A. [REDACTED]
7 Q. Did [REDACTED] ever engage in any
8 sexual activity with Mr. Epstein?
9 A. I wouldn't know. I would assume
10 not, but I don't know.
11 Q. Do you have any reason to believe
12 that Mr. Epstein engaged in any sexual
13 activity with [REDACTED]
14 MR. PAGLIUCA: Objection to form
15 and foundation.
16 A. I wouldn't know.
17 Q. [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]¶

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1 G. Maxwell - Confidential
2 MR. PAGLIUCA: Objection to form
3 and foundation.
4 A. My testimony is I never heard that,
5 period.
6 Q. That includes, I assume, that you
7 never heard that from [REDACTED] that's your
8 testimony?
9 MR. PAGLIUCA: Objection to form
10 and foundation.
11 A. I think you can safely say if
12 you've never heard it at all, it would
13 encompass anybody at all. It means you never
14 heard it, period.
15 Q. Did you ever see [REDACTED] in
16 Ohio?
17 A. Not that I recall.
18 Q. Where did you last see [REDACTED]
19 [REDACTED]
20 A. I only recall seeing her at the
21 ranch.
22 Q. In New Mexico?
23 A. Yeah.
24 Q. Other than seeing [REDACTED] at
25 Mr. Epstein's place in New Mexico, did you¶

1 G. Maxwell - Confidential
2 [REDACTED]
3 [REDACTED]
4 [REDACTED]
5 [REDACTED]
6 [REDACTED]
7 [REDACTED]
8 [REDACTED]
9 [REDACTED]
10 [REDACTED]
11 [REDACTED]
12 [REDACTED]
13 Q. Did you, or to your knowledge,
14 Mr. Epstein pay for [REDACTED] to go to
15 Thailand?
16 MR. PAGLIUCA: Objection to form
17 and foundation.
18 A. I am not aware.
19 Q. Do you know whether [REDACTED]
20 went to Thailand?
21 A. I have no knowledge of anything
22 like that.
23 Q. Did you ever give anyone
24 instructions as to how to give a massage?
25 MR. PAGLIUCA: Objection to form¶

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1 G. Maxwell - Confidential
2 and foundation.
3 A. No. With a clarification, I do --
4 I have very -- how to massage feet, pressure
5 points on a foot and pressure points on a
6 hand.
7 Q. Is what you're saying is that you
8 gave people instructions as to how to massage
9 feet and hands?
10 A. I have never given any
11 instructions. I have shown where pressure
12 points are on a hand and on a foot, but I
13 have never given instructions on how to do
14 it. I have demonstrated where a pressure
15 point on a hand and a foot is.
16 Q. Did you do that demonstration with
17 people who were giving or were planning to
18 give Mr. Epstein massages?
19 MR. PAGLIUCA: Objection to form
20 and foundation.
21 A. No, just in general, something
22 that I know how to do, so it would be just as
23 a general thing I have done.
24 Q. When you talk about general thing
25 you have done, is to tell people where the¶

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1 G. Maxwell - Confidential
2 pressure points are on hands and feet?
3 A. Yes.
4 Q. Did you ever use that knowledge to
5 try to show someone who was giving or was
6 planning to give Mr. Epstein a massage how to
7 do it?
8 MR. PAGLIUCA: Objection to form
9 and foundation. Asked and answered.
10 A. I am not aware of ever having done
11 that, but I am aware of having shown people
12 that there is a pressure point on the hand
13 and foot. I have no specific knowledge of
14 who. Just in general, I have done it.
15 Q. Did you show people pressure points
16 on hands and feet in Mr. Epstein's house in
17 Palm Beach?
18 A. I don't recall with specificity
19 where. I just know I do it because it's just
20 something that I happen to know, it helps
21 people, something I know.
22 Q. What I'm trying to be sure that I
23 have your testimony on is whether at any of
24 Mr. Epstein's properties, whether you call it
25 instructions or not, told people or showed¶

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1 G. Maxwell - Confidential
2 people how to give massage. Did you do that?
3 A. I have not done that.
4 Q. Did you ever tell or show people
5 how to give Mr. Epstein a massage?
6 A. No.
7 Q. Did you ever tell or show people at
8 Mr. Epstein's properties how to give
9 massages?
10 A. No.
11 Q. Did you at any time, at any of
12 Mr. Epstein's properties, tell or show anyone
13 how to give massages or how Mr. Epstein liked
14 massages?
15 MR. PAGLIUCA: Objection to form
16 and foundation.
17 A. No. I think Mr. Epstein is
18 perfectly capable --
19 MR. PAGLIUCA: There is no question
20 pending.
21 Q. Did Mr. Epstein, in your presence,
22 ever tell or show anyone how he liked
23 massages?
24 A. I don't recall.
25 Q. Did Mr. Epstein ever tell you how¶

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1 G. Maxwell - Confidential
2 he liked or didn't like massages given by any
3 particular person?
4 A. I can't recall.
5 Q. In other words, did he ever praise
6 to you or compliment to you some massage that
7 he had gotten or some person who had given
8 him a massage?
9 A. I'm sure in the course of time he
10 did, but I can't recall.
11 Q. Did he ever complain to you or
12 criticize the massage that anyone gave him?
13 A. Again, I don't recall.
14 Q. You know [REDACTED]
15 [REDACTED], correct?
16 A. I do.
17 Q. Did Mr. Epstein, insofar as you
18 have any reason to believe, ever engage in
19 sexual activities with her?
20 A. I have no knowledge.
21 Q. Did you ever engage in sexual
22 activities with [REDACTED]
23 A. No.
24 Q. Have you had any conversations with
25 [REDACTED] about Mr. Epstein's¶

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1 G. Maxwell - Confidential
2 massages or sexual activities?
3 MR. PAGLIUCA: Objection to form
4 and foundation.
5 A. No.
6 Q. When was the last time you had any
7 communications with [REDACTED]
8 A. A long time ago. So long, I don't
9 recall.
10 Q. Were you aware that [REDACTED]
11 [REDACTED] was noticed for a deposition in this
12 case?
13 A. I believe I did know that, yes.
14 Q. Did you have any conversations with
15 anyone as to whether or not [REDACTED]
16 [REDACTED] would or should show up for that
17 deposition?
18 MR. PAGLIUCA: Wait a minute, what
19 does that have to do with the court's
20 order. Don't answer that question.
21 Just don't answer it. This is silly.
22 MR. BOIES: I actually think it is
23 far from silly. I think it goes to an
24 obstruction of justice situation that I
25 think you would be well advised to allow¶

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1 G. Maxwell - Confidential
2 your client to answer the question on.
3 MR. PAGLIUCA: Do you have a good
4 faith basis to suggest that she
5 suggested that [REDACTED] not show up at
6 her deposition yesterday?
7 MR. BOIES: I don't know whether it
8 was you, I don't know whether it was
9 her, I don't know who did it. What I do
10 know is that she didn't show up, and I
11 think the evidence will be quite clear
12 that your client's testimony about the
13 extent of her relationship with [REDACTED]
14 [REDACTED] is not accurate.
15 And in that context, I think the
16 circumstances under which it turns out
17 that she doesn't show up is entirely
18 appropriate for examination, but that is
19 something that I'm happy to talk to the
20 judge about.
21 MR. PAGLIUCA: Sure. And I hope
22 that you give him some good faith basis
23 for the assertions that you are making
24 here today, which are wholly improper.
25 MR. BOIES: I don't think they are¶

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1 G. Maxwell - Confidential
2 at all improper. I am not making any
3 assertions. I'm simply asking
4 questions. I'm trying to find out what
5 the facts are.
6 MR. PAGLIUCA: No, you are not.
7 MR. BOIES: Yes, I am. You are
8 trying to keep the facts from coming
9 out.
10 MR. PAGLIUCA: No, I'm not. I'm
11 trying to keep this orderly and not
12 abusive as to where it is going.
13 MR. BOIES: This is so far from
14 abusive.
15 MR. PAGLIUCA: I think we should
16 take a lunch break, given it is noon.
17 MR. BOIES: We will do it in a half
18 hour, I want to finish this line of
19 questioning. I will guarantee we are
20 out by 12:30.
21 BY MR. BOIES:
22 Q. Let me ask you about a few other
23 people.
24 [REDACTED], do you know her?
25 A. I do.¶

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1 G. Maxwell - Confidential
2 Q. Is she anyone with whom Mr. Epstein
3 had sex?
4 MR. PAGLIUCA: Objection to form
5 and foundation.
6 A. I have no idea.
7 Q. Is she anyone with whom Mr. Epstein
8 engaged in sexual activities?
9 MR. PAGLIUCA: Objection to form
10 and foundation.
11 A. I have no personal knowledge.
12 Q. When you say you have no personal
13 knowledge, what do you mean by personal
14 knowledge?
15 A. I mean that I've read the police
16 reports, so that's the only knowledge I have
17 of what [REDACTED] or anybody else has with
18 Jeffrey. I have no way of knowing whether
19 they did or not. Personal knowledge means
20 did I know myself.
21 Q. After you saw the police reports
22 about Mr. Epstein's relations with [REDACTED]
23 [REDACTED], did you ever talk to Mr. Epstein
24 about whether or not that police report was
25 or was not accurate?¶

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1 G. Maxwell - Confidential¶

2 A. I have not.¶

3 Q. You did communicate with¶

4 Mr. Epstein after you saw that police report,¶

5 correct?¶

6 MR. PAGLIUCA: Objection to form¶

7 and foundation.¶

8 A. I don't know that's true.¶

9 Q. When did you see the police report?¶

10 MR. PAGLIUCA: If this involves¶

11 communications with me, I'm going to¶

12 instruct you not to answer the¶

13 questions.¶

14 Q. Is it your testimony that the only¶

15 time you saw the police reports was when it¶

16 was shown to you by your counsel?¶

17 A. That's the only time I recollect.¶

18 Q. What?¶

19 A. That's the only time I remember¶

20 seeing it.¶

21 Q. When did your counsel show you the¶

22 police report?¶

23 MR. PAGLIUCA: If you remember, you¶

24 can answer that question.¶

25 A. I don't know. I guess recently,¶

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1 G. Maxwell - Confidential¶

2 but I don't recall.¶

3 Q. In the last 30 days?¶

4 A. I really don't remember when I saw¶

5 it.¶

6 Q. Was the first time that you saw the¶

7 police report sometime this calendar year¶

8 2016?¶

9 A. I don't remember when I've seen¶

10 them. It's in the course of this latest¶

11 lies.¶

12 Q. What do you mean, in the course of¶

13 this latest lies?¶

14 A. In the course of this defamation¶

15 suit.¶

16 Q. And you may not be able to answer¶

17 this, but if you can, I just want to know.¶

18 When you saw the police report in the course¶

19 of this defamation suit, was it this calendar¶

20 year, that is 2016, sometime?¶

21 A. I don't know, I'm sorry, I have no¶

22 memory.¶

23 Q. When is the last time you had a¶

24 conversation or communication with¶

25 Mr. Epstein?¶

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1 G. Maxwell - Confidential¶

2 A. A very long time ago.¶

3 Q. How long?¶

4 A. I think two years ago, something¶

5 like that.¶

6 Q. Before this defamation lawsuit?¶

7 A. Excuse me?¶

8 Q. Before this defamation lawsuit?¶

9 A. You are asking if I communicated¶

10 with him before the defamation? What are you¶

11 asking me?¶

12 Q. Have you communicated with¶

13 Mr. Epstein since this defamation lawsuit was¶

14 filed?¶

15 A. I don't believe I have. I haven't¶

16 spoken to him -- no, I don't think so. I¶

17 don't remember when it was filed, no, I don't¶

18 think so.¶

19 Q. By communication, I don't mean just¶

20 speaking to him. I mean writing him a¶

21 letter, email, communicated in any way?¶

22 A. No.¶

23 Q. When you say no, does that mean you¶

24 have not communicated with Mr. Epstein in any¶

25 way since this lawsuit was filed?¶

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1 G. Maxwell - Confidential¶

2 A. I don't recall any communications¶

3 with him since this lawsuit has been filed.¶

4 Q. Did you ever discuss [REDACTED]¶

5 [REDACTED] with Mr. Epstein?¶

6 MR. PAGLIUCA: Objection to form¶

7 and foundation.¶

8 A. I would have had conversations with¶

9 him in general terms. Obviously I talked¶

10 about her with him but not in any context of¶

11 this situation. Just I will have talked to¶

12 him about her.¶

13 Q. When was the last time you talked¶

14 to Mr. Epstein about [REDACTED]¶

15 A. Probably in 2003, 2002.¶

16 Q. What was the subject matter of that¶

17 conversation?¶

18 A. I have no idea.¶

19 Q. Did it have anything to do with¶

20 Mr. Epstein's relationship with [REDACTED]¶

21 [REDACTED]¶

22 A. No, I have no idea. It would have¶

23 nothing to do with anything other than a¶

24 work-related issue.¶

25 Q. Did [REDACTED] work for¶

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1 G. Maxwell - Confidential¶

2 Mr. Epstein?¶

3 A. I believe she did.¶

4 Q. Was she working for Mr. Epstein in
5 2003?¶

6 A. I believe she was.¶

7 Q. What was her job?¶

8 A. I don't exactly know what her job,
9 her responsibilities were.¶

10 Q. Do you know any of job
11 responsibilities?¶

12 A. I believe she traveled with him and
13 help managed the houses and run the staff and
14 whatever else he asked her to do. She worked
15 for Mr. Epstein, so you would have to ask
16 him.¶

17 Q. Was it your understanding that
18 [REDACTED] at some point had had a
19 sexual or romantic relationship with
20 Mr. Epstein?¶

21 A. I have no knowledge of that.¶

22 Q. Let me go back to [REDACTED].
23 Did you know, yourself, [REDACTED].¶

24 A. I met her.¶

25 Q. Where did you meet her?¶

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1 G. Maxwell - Confidential¶

2 A. I don't recall where I met her, I
3 just don't.¶

4 Q. Did you meet her at one of
5 Mr. Epstein's properties?¶

6 A. It's possible, but I don't recall
7 where I met her.¶

8 Q. Did you ever see [REDACTED] at any of
9 Mr. Epstein's properties?¶

10 A. I believe that -- I believe on the
11 island, I recall, maybe.¶

12 Q. Virgin Islands?¶

13 A. Virgin Islands.¶

14 Q. Did [REDACTED] work for Mr. Epstein?¶

15 A. I don't know.¶

16 Q. Did [REDACTED] travel with Mr. Epstein?¶

17 A. I don't know. If she was on the
18 island, then presumably she did. I don't
19 recall.¶

20 Q. Did you ever see [REDACTED]
21 at any of Mr. Epstein's properties other than
22 in the Virgin Islands?¶

23 A. Not that I recall.¶

24 Q. Leaving aside anything that you
25 have learned since this defamation suit¶

1 G. Maxwell - Confidential
2 started, did you have any reason to believe
3 that Mr. Epstein had engaged in sexual
4 activities with [REDACTED]¶

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

7 A. I don't -- I have no idea. It
8 wouldn't be something I think about.¶

9 Q. I'm sorry, say that again?¶

10 A. I would have no idea.¶

11 Q. Did [REDACTED], insofar as
12 you were aware, ever give Mr. Epstein a
13 massage?¶

14 A. I have no idea.¶

15 Q. Did you ever see her go into the
16 massage room?¶

17 A. Not that I recall, no.¶

18 Q. Did you ever tell [REDACTED]
19 that Mr. Epstein wanted her in the massage
20 room?¶

21 A. No.¶

22 Q. Did you ever have any discussions
23 with Mr. Epstein about [REDACTED]¶

24 A. None.¶

25 Q. Did you ever have any discussions¶

1 G. Maxwell - Confidential
2 with [REDACTED] about Mr. Epstein?¶

3 A. None.¶

4 Q. Do you know how much money, if any,
5 Mr. Epstein paid [REDACTED]¶

6 A. I have no idea, no, I have no idea.¶

7 Q. Do you know whether Mr. Epstein
8 paid [REDACTED], even if you don't know
9 the amount?¶

10 A. No, I would not know that.
11 Actually, I don't, I don't recall any
12 conversation --¶

13 MR. PAGLIUCA: There is no question
14 pending.¶

15 Q. Do you know who [REDACTED]
16 is?¶

17 A. Yes.¶

18 Q. Would you identify him for the
19 record?¶

20 A. [REDACTED]¶

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1 G. Maxwell - Confidential
2 in Palm Beach in the 1990s and 2000s?
3 A. I don't believe so.
4 Q. [REDACTED] for
5 Mr. Epstein?
6 A. I believe late -- middle of 2000s.
7 2004, 2005, something like that.
8 Q. When he became [REDACTED]
9 [REDACTED], did he work for Mr. Epstein in
10 Palm Beach?
11 A. I believe he did.
12 Q. And did you see [REDACTED] at
13 Mr. Epstein's Palm Beach residence while [REDACTED]
14 [REDACTED]
15
16 A. I was not in Palm Beach when he was
17 working for Mr. Epstein.
18 Q. I think you answered the question,
19 but I want to be absolutely certain. Is it
20 your testimony that you never saw
21 [REDACTED] at Mr. Epstein's Palm Beach
22 residence?
23 A. That is not my testimony.
24 Q. Did you ever see [REDACTED] at
25 Mr. Epstein's Palm Beach residence?¶

1 G. Maxwell - Confidential
2 Q. Did you see [REDACTED] at Mr.
3 Epstein's Palm Beach residence in 2005?
4 A. I don't recall going to the house
5 in 2005, but if I was there and he was
6 working, I would have seen him.
7 Q. Do you recall, as you sit here now,
8 one way or another, whether you were at Mr.
9 Epstein's Palm Beach residence in 2005?
10 A. I don't recall going to the house
11 in 2005, but if I did go, I would have seen
12 him. And if I did go, it would have been
13 once, maybe, I maybe went to the house in
14 2005, I don't recall.
15 Q. If you went to the house in 2005,
16 is it your testimony it would have only been
17 once?
18 A. Sounds about right, maybe twice. I
19 was not in Palm Beach in 2005.
20 Q. For you to have been at Mr.
21 Epstein's house in Palm Beach, you would have
22 had to have been in Palm Beach, right?
23 A. I would have had to have been in
24 Palm Beach to be at his house in Palm Beach,
25 of course.¶

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1 G. Maxwell - Confidential
2 A. I'm sure I did because I would have
3 seen him. I'm sure I did see him but -- yes,
4 I would have seen him.
5 Q. When did you see [REDACTED] at
6 Mr. Epstein's Palm Beach residence?
7 A. If I'm right and I could -- the
8 dates are a bit off, Mr. Epstein's mother
9 died, I think [REDACTED] was working for
10 Mr. Epstein at that time, and I helped with
11 the funeral arrangements and I would have
12 seen him at that point.
13 Q. Other than the one occasion when
14 Mr. Epstein's mother died, we can figure out
15 what the date of that was --
16 A. I don't have all the dates in my
17 head.
18 Q. Other than the one occasion when
19 Mr. Epstein's mother died, did you ever see
20 [REDACTED]
21 A. In that period of time when I went
22 very infrequently to Palm Beach, I don't know
23 how many times, maybe once or twice and had
24 he been at the house, I would have seen him,
25 so there would have been very few times.¶

1 G. Maxwell - Confidential
2 Q. So when you say you were not in
3 Palm Beach in 2005, does that mean it is your
4 testimony you were not at Mr. Epstein's house
5 in Palm Beach in 2005?
6 A. I don't recall being at Mr.
7 Epstein's house in 2005, I don't really
8 recall being in Palm Beach in 2005, and if I
9 was in Palm Beach in 2005, I may not have
10 stayed at his house.
11 Q. Is it your testimony that the most
12 you would have been at Mr. Epstein's house in
13 Palm Beach in 2005 was once or twice, if
14 that?
15 A. To the best of my recollection,
16 that sounds about right. But I really don't
17 recall, 2005 is a long time ago, I just don't
18 recall.
19 Q. You were continuing to work for
20 Mr. Epstein in 2005?
21 A. I was helping out in just very
22 specific areas of staffing of the houses and
23 some architectural details and decorating.
24 Q. You were getting paid?
25 MR. PAGLIUCA: We've gone over¶

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1 G. Maxwell - Confidential¶

2 this. You don't need to testify about¶

3 this again. We will take it up with the¶

4 judge, if we need to. I let this go on¶

5 for 15 minutes about Palm Beach.¶

6 MR. BOIES: I ask the question, you¶

7 give the instruction, the judge decides.¶

8 Q. In 2005, were you assisting in the¶

9 arranging of massages for Mr. Epstein?¶

10 A. No.¶

11 Q. Not at all is your testimony?¶

12 A. Correct.¶

13 MR. BOIES: This is a good time to¶

14 take a lunch break.¶

15 MR. PAGLIUCA: Okay. I don't¶

16 intend on being here all day, so if you¶

17 have some important questions you want¶

18 to ask, you may want to get to those.¶

19 MR. BOIES: You can walk out any¶

20 time you want.¶

21 MR. PAGLIUCA: We are getting¶

22 close.¶

23 MR. BOIES: The judge will decide¶

24 whether that's appropriate or not.¶

25 MR. PAGLIUCA: We are getting¶

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1 G. Maxwell - Confidential¶

2 close.¶

3 THE VIDEOGRAPHER: It's 12:15 p.m.¶

4 and we are going off the record.¶

5 (Whereupon, a luncheon recess was¶

6 taken at 12:15 p.m.)¶

7 * * *¶

8 * * *¶

9 * * *¶

10 * * *¶

11 * * *¶

12 * * *¶

13 * * *¶

14 * * *¶

15 * * *¶

16 * * *¶

17 * * *¶

18 * * *¶

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25 * * *¶

Page 136¶

1 G. Maxwell - Confidential¶

2 A F T E R N O O N S E S S I O N¶

3 (Time noted: 1:16 p.m.)¶

4¶

5 G H I S L A I N E M A X W E L L,¶

6 resumed and testified as follows:¶

7¶

8 THE VIDEOGRAPHER: The time is 1:16¶

9 p.m., and we are back on the record.¶

10 This also begins DVD No. 5.¶

11 MR. PAGLIUCA: One housekeeping¶

12 matter before you get started. The¶

13 original deposition was as confidential¶

14 and we would designate this continued¶

15 deposition as confidential as well.¶

16 MR. BOIES: Okay.¶

17 Let me ask you to look at a¶

18 document that has been marked as Maxwell¶

19 Deposition Exhibit 28. This is another¶

20 list of names.¶

21 (Maxwell Exhibit 28, List of names,¶

22 marked for identification, as of this¶

23 date.)¶

24 Q. What I would ask you to do is to¶

25 identify the names that are here that you do¶

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1 G. Maxwell - Confidential¶

2 not recognize. That is, I think you will¶

3 recognize most of the names --¶

4 MR. POTTINGER: Excuse me one¶

5 second.¶

6 Q. What I was saying was that I would¶

7 like you to look at the names here and tell¶

8 me which names you do not recognize.¶

9 A. I pretty much recognize these¶

10 names. I don't know everybody very well, but¶

11 I recognize the names.¶

12 Q. You know who they are?¶

13 A. I don't know if I know who they¶

14 are. I recognize the names.¶

15 Q. Are most of the people on this list¶

16 people that you've met before?¶

17 MR. PAGLIUCA: Objection to form¶

18 and foundation.¶

19 A. I believe I've met pretty much¶

20 everybody on this list.¶

21 Q. Who on the list have you not met?¶

22 A. I think I met them all.¶

23 Q. Now, were all of these people¶

24 people that at one time or another you were¶

25 with with Mr. Epstein?¶

Page 138¶

1 G. Maxwell - Confidential¶

2 MR. PAGLIUCA: Objection to form¶

3 and foundation.¶

4 A. I believe so.¶

5 Q. Were any of these people on the¶

6 list, obviously leaving aside Mr. Epstein¶

7 himself, people who, to your knowledge,¶

8 received massages at one or more of Mr.¶

9 Epstein's properties?¶

10 MR. PAGLIUCA: Objection to form¶

11 and foundation.¶

12 A. I couldn't say.¶

13 Q. Are there any people on this list¶

14 who you have reason to believe received¶

15 massages at one or more of Mr. Epstein's¶

16 properties?¶

17 MR. PAGLIUCA: Objection to form¶

18 and foundation.¶

19 A. I couldn't say.¶

20 Q. Just to be clear, my most recent¶

21 question is whether any of the people on this¶

22 list are people who you have reason to¶

23 believe received massages at one of Mr.¶

24 Epstein's properties?¶

25 MR. PAGLIUCA: Same objection.¶

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1 G. Maxwell - Confidential¶

2 A. I couldn't say.¶

3 Q. Why can't you say?¶

4 A. Because I just don't know.¶

5 Q. Well, you know whether you have a¶

6 reason to believe, correct?¶

7 MR. PAGLIUCA: Objection to form¶

8 and foundation.¶

9 A. These are events that took place 17¶

10 years ago, and I really do not know. It is¶

11 possible that people on that list got a¶

12 massage, it's also possible they didn't. I¶

13 really don't know, leaving aside, of course,¶

14 Mr. Epstein himself.¶

15 Q. Yes.¶

16 MR. PAGLIUCA: One second, I'm¶

17 getting text messages.¶

18 [REDACTED]¶

19 [REDACTED]¶

20 [REDACTED]¶

21 [REDACTED]¶

22 [REDACTED]¶

23 [REDACTED]¶

24 [REDACTED]¶

25 MR. PAGLIUCA: Objection to form¶

Page 140¶

1 G. Maxwell - Confidential¶

2 and foundation.¶

3 A. [REDACTED] was his girlfriend.¶

4 Q. I am sorry?¶

5 A. [REDACTED] was his girlfriend.¶

6 Q. When was [REDACTED] Mr. Epstein's¶

7 girlfriend?¶

8 A. I don't know the dates, but I¶

9 believe in the '80s.¶

10 Q. In the 1980s?¶

11 A. Yeah, and part of the 1990s, I¶

12 believe. So I don't know when they started¶

13 and when they ended. They were in a¶

14 long-term relationship.¶

15 Q. Was Mr. Epstein engaged in sexual¶

16 activities with [REDACTED] during the¶

17 period of time that you were involved with¶

18 Mr. Epstein?¶

19 A. I wouldn't know.¶

20 Q. How old was [REDACTED] when she¶

21 was first involved with Mr. Epstein?¶

22 A. I don't know.¶

23 Q. How old was [REDACTED] when you¶

24 first met her?¶

25 A. I don't recall.¶

Page 141¶

1 G. Maxwell - Confidential¶

2 Q. Did any of the people on this list,¶

3 other than Mr. Epstein himself, and the list¶

4 is Exhibit 28, ever ask you to arrange a¶

5 massage?¶

6 MR. PAGLIUCA: Objection to form¶

7 and foundation.¶

8 A. Not that I recall.¶

9 Q. Did you arrange a massage for any¶

10 of the people on this list other than¶

11 Mr. Epstein?¶

12 A. Not that I recall.¶

13 Q. Were any of the people on this¶

14 list, other than Mr. Epstein, given a massage¶

15 at any of Mr. Epstein's residences?¶

16 MR. PAGLIUCA: Objection to form¶

17 and foundation. Asked and answered.¶

18 A. I wouldn't know.¶

19 Q. Did any of the people on this list,¶

20 other than Mr. Epstein, engage in sexual¶

21 activities with anyone at Mr. Epstein's¶

22 properties?¶

23 MR. PAGLIUCA: Objection to form¶

24 and foundation.¶

25 A. I wouldn't know.¶

Page 142¶

1 G. Maxwell - Confidential¶

2 Q. When you say I wouldn't know, I¶

3 take it you mean to include that you¶

4 testified that you do not know, is that¶

5 correct?¶

6 MR. PAGLIUCA: Objection to form¶

7 and foundation.¶

8 A. I would have no knowledge. I have¶

9 no knowledge of what you are asking me.¶

10 Q. Did you ever have conversations¶

11 with anyone that were intended to convince¶

12 them to engage in sexual activities with¶

13 Mr. Epstein?¶

14 MR. PAGLIUCA: Objection to form¶

15 and foundation. This has been asked and¶

16 answered in her previous deposition, by¶

17 the way.¶

18 A. No.¶

19 Q. Did you ever tell anyone that¶

20 Mr. Epstein was a scout for Victoria's¶

21 Secret?¶

22 A. I don't recall saying that.¶

23 Q. Did you ever tell anyone that¶

24 Mr. Epstein could get them a job with¶

25 Victoria's Secret?¶

Page 144¶

1 G. Maxwell - Confidential¶

2 [REDACTED]¶

Page 143¶

1 G. Maxwell - Confidential¶

2 A. I don't recall saying that.¶

3 Q. Do you deny saying that, or do you¶

4 simply say you don't recall, one way or¶

5 another, whether you said it?¶

6 MR. PAGLIUCA: This is outside the¶

7 court's order, so I will tell you not to¶

8 answer this, and we will take it up with¶

9 the judge.¶

10 [REDACTED]¶

Page 145¶

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2 [REDACTED]¶

![](_page_37_Picture_21.jpeg)¶

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1 G. Maxwell - Confidential 1 U. Maxwell - Confidential¶

C. Nlaxwell - Confidential¶

2¶

Page 147 e 149¶

1 2¶

15 Q. Was there anything that occurred 16 that led you to conclude that you didn't want¶

17 to be there anymore?¶

18 A. I ceased to be happy in the job and 19 I ceased to be happy spending time with¶

20 Mr. Epstein.¶

21 Q. Was there anything that happened 22 that you can identify that caused you to 23 cease to be happy spending time with¶

24 Mr. Epstein?¶

25 A. He became more difficult to work¶

G. Maxwell - Confidential¶

MAG NA 0¶

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1 G. Maxwell - Confidential
2 with.
3 Q. Was there any particular aspect of
4 that that you can identify now?
5 A. Just general. Just doesn't work.
6 Q. Let me focus on [REDACTED]. Now,
7 you testified that you have no reason to
8 believe that [REDACTED] engaged in sexual
9 activities with anyone at any of Mr.
10 Epstein's residences, is that correct?
11 A. I would have no knowledge of that.
12 Q. Did you ever see [REDACTED] engage
13 in sexual activities with anyone?
14 A. I did not.
15 Q. Did you ever see [REDACTED] taking
16 photographs of people engaged in sexual
17 activities?
18 A. I did not.
19 Q. I apologize for getting into
20 something that is kind of an intimate area,
21 but I need to establish this, in part because
22 it relates to patterns of conduct, and I need
23 to ask you some questions about your sexual
24 activities with Mr. Epstein.
25 A. Okay.¶

Page 151¶

Page 152¶

1 G. Maxwell - Confidential
2 [REDACTED]
3 [REDACTED]
4 [REDACTED]
5 [REDACTED]
6 [REDACTED]
7 Q. Did you ever have conversations
8 with anyone who was engaged in sexual
9 activities with Mr. Epstein about those
10 sexual activities?
11 MR. PAGLIUCA: Objection to form
12 and foundation.
13 A. I never had those conversations.
14 Q. So would it be your testimony that
15 you never had any conversations about Mr.
16 Epstein's sexual activities with [REDACTED]
17 [REDACTED]
18 A. I have never talked about sex with
19 [REDACTED] at any point. I have hardly ever
20 spoken to her.
21 Q. Would your testimony be the same
22 with respect to [REDACTED]
23 A. That would be true, correct, I have
24 not.
25 Q. And [REDACTED]?¶

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1 G. Maxwell - Confidential
2 A. Of course not.
3 Q. Were there any young men that, to
4 your knowledge, would bring women over to
5 Mr. Epstein's residences to perform services
6 for Mr. Epstein?
7 MR. PAGLIUCA: Objection to form
8 and foundation.
9 A. Can you repeat the question,
10 please?
11 Q. Were there any young men that, to
12 your knowledge, would bring women over to
13 Mr. Epstein's residences to perform services
14 for Mr. Epstein?
15 A. I have no idea what you are talking
16 about, I'm sorry.
17 Q. I'm talking about whether there
18 were any young men that brought women over to
19 Mr. Epstein's residence to perform services?
20 A. I can't think of a single man in
21 that context that I've ever met.
22 Q. You testified earlier that you did
23 not recall ever meeting [REDACTED], is
24 that correct?
25 A. I don't believe I ever have.¶

Page 154¶

1 G. Maxwell - Confidential¶

2 Q. Insofar as you were aware, did¶

3 [REDACTED] ever have a male friend that¶

4 visited her at the Epstein residences?¶

5 A. I don't recall ever seeing a man¶

6 with Virginia. I believe she had a fiance¶

7 that I was aware of, I think, but that's all.¶

8 Q. When were you aware that [REDACTED]¶

9 [REDACTED] had a fiance?¶

10 A. I can't say I became aware from¶

11 reading all this stuff, or I was aware of it¶

12 at the time. I don't know.¶

13 Q. Did you ever meet [REDACTED]¶

14 fiance?¶

15 A. I don't think I ever did. I don't¶

16 recall meeting any men with Virginia.¶

17 Q. Do you know [REDACTED],¶

18 [REDACTED]¶

19 A. I never heard that name before.¶

20 Q. Have you ever heard the name of¶

21 [REDACTED]¶

22 A. I don't recollect that name at all.¶

23 MR. PAGLIUCA: Mr. Boies, those¶

24 names are on Exhibit 26, which we have¶

25 already gone over and she said she¶

Page 155¶

1 G. Maxwell - Confidential¶

2 didn't recognize those people, so now we¶

3 are just repeating things that we went¶

4 over.¶

5 MR. BOIES: I am in the context of¶

6 seeing if I can refresh her¶

7 recollection, because these are women¶

8 that [REDACTED], who she also does not¶

9 recall, brought over to Mr. Epstein's¶

10 residences, and I also want to make a¶

11 very clear record of what her testimony¶

12 is and is not right now.¶

13 Again, you can instruct her not to¶

14 answer if you wish.¶

15 MR. PAGLIUCA: I'm trying to get to¶

16 nonrepetitive questions here. You¶

17 basically asked the same question three¶

18 times. Then we get a pile of notes that¶

19 get pushed up to you, you read those.¶

20 Then you ask those three times, and then¶

21 we go to another question. So it's¶

22 taking an inordinately long amount of¶

23 time and it shouldn't.¶

24 MR. BOIES: I think that is a¶

25 demonstrably inaccurate statement of¶

Page 156¶

1 G. Maxwell - Confidential¶

2 what has been going on, and I¶

3 attribute -- maybe I shouldn't attribute¶

4 it at all.¶

5 But if you want to instruct not to¶

6 answer, instruct not to answer. If you¶

7 don't, again, all I will do is request¶

8 that you cease your comments. I can't¶

9 do that. All I can do is seek sanctions¶

10 afterwards.¶

11 BY MR. BOIES:¶

12 Q. Ms. Maxwell.¶

13 A. Mr. Boies.¶

14 Q. What?¶

15 A. I'm replying. You said Ms.¶

16 Maxwell, I said Mr. Boies.¶

17 Q. Do you have a question?¶

18 A. No.¶

19 Q. I have a question.¶

20 A. I'm sure you do.¶

21 Q. During the time that you were in¶

22 the property or at the property that¶

23 Mr. Epstein has in the Virgin Islands, were¶

24 you aware of Mr. Epstein getting any¶

25 massages?¶

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1 G. Maxwell - Confidential¶

2 A. He did receive massages at the¶

3 Virgin Islands property.¶

4 Q. From whom did he receive massages¶

5 at the Virgin Islands?¶

6 A. There is a professional masseuse¶

7 and masseur that came from St. [REDACTED].¶

8 Q. This was somebody who came over¶

9 from St. [REDACTED] for the day to give massages¶

10 and then left, or was that person a resident?¶

11 A. I believe, from memory, they came¶

12 over, gave a massage and left.¶

13 Q. And who arranged for this person to¶

14 come over from St. [REDACTED]?¶

15 A. Probably the staff at the island.¶

16 Q. But you don't know?¶

17 A. The staff of the island would have¶

18 made those arrangements.¶

19 Q. Who at the staff?¶

20 A. Whoever would have been running the¶

21 island at that period of time.¶

22 Q. Do you know who that was?¶

23 A. I'm sorry, in this moment I can't¶

24 think of the names of the people who worked¶

25 on the island.¶

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1 G. Maxwell - Confidential¶

2 Q. Did you ever arrange for anyone to¶

3 give Mr. Epstein a massage at his Virgin¶

4 Island property?¶

5 A. I don't recall if I ever made a¶

6 call to the massage people in St. [REDACTED]. I¶

7 don't recall.¶

8 Q. Did Mr. Epstein ever receive¶

9 massages at his Virgin Island property from¶

10 people that he had brought with him on his¶

11 plane from the United States?¶

12 MR. PAGLIUCA: Objection to form¶

13 and foundation.¶

14 A. I don't know.¶

15 Q. Did you ever participate in¶

16 arranging for a massage for Mr. Epstein by¶

17 someone who had been brought to the island on¶

18 Mr. Epstein's plane?¶

19 A. My memory of the massages on the¶

20 island were from people who came from St.¶

21 [REDACTED].¶

22 Q. Does that mean that you never¶

23 participated in arranging for a massage for¶

24 Mr. Epstein at his Virgin Island property to¶

25 be given by someone who had been brought to¶

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1 G. Maxwell - Confidential¶

2 the island on Mr. Epstein's plane?¶

3 MR. PAGLIUCA: Objection to form¶

4 and foundation.¶

5 A. I don't recall, I have no idea.¶

6 Q. Mr. Epstein did bring women to his¶

7 Virgin Island property on his plane from time¶

8 to time, right?¶

9 MR. PAGLIUCA: Objection to form¶

10 and foundation.¶

11 A. People came to the island who were¶

12 his guests.¶

13 Q. And some of those guests, as you¶

14 described it, were women, right?¶

15 A. Indeed.¶

16 Q. Did you ever participate in¶

17 arranging for any of the women that came to¶

18 Mr. Epstein's Virgin Island property to¶

19 provide Mr. Epstein with a massage?¶

20 A. No.¶

21 Q. Where on the Virgin Island property¶

22 did Mr. Epstein have his massages?¶

23 A. I believe from memory he had them¶

24 in the [REDACTED] cabana.¶

25 Q. In what?¶

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1 G. Maxwell - Confidential¶

2 A. It was a cabana, and also he had a¶

3 beach place, a place on the beach where from¶

4 time to time he would...¶

5 Q. Did you ever see Mr. Epstein being¶

6 given a massage in the beach area where he¶

7 from time to time had massages?¶

8 A. I don't have any recollection of a¶

9 specific memory, but it was just on the¶

10 beach, so there wouldn't be any privacy, he¶

11 would just be getting a massage.¶

12 Q. That would be visible to people who¶

13 are on the beach, correct?¶

14 A. It would be, yes.¶

15 Q. Did you, at any time when you were¶

16 there, see Mr. Epstein being given a massage¶

17 in this beach area other than by a¶

18 professional masseuse brought to the island¶

19 from St. [REDACTED]?¶

20 A. I don't have any memory of -- I¶

21 don't have a specific memory of seeing him¶

22 get a massage on the beach. I just have an¶

23 image of a massage on the beach, so I don't¶

24 know who, I have no memory of it.¶

25 Q. Whether or not you have a specific¶

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1 G. Maxwell - Confidential¶

2 memory of it, do you have a general memory¶

3 that from time to time Mr. Epstein got¶

4 massages down in the beach area?¶

5 A. I have a general memory, I do.¶

6 Q. Do you have a general memory that¶

7 from time to time those massages were given¶

8 to Mr. Epstein by people other than a¶

9 professional masseuse brought to the island¶

10 from St. [REDACTED]?¶

11 MR. PAGLIUCA: Objection to form¶

12 and foundation.¶

13 A. I have no idea who would be giving¶

14 him a massage in that general memory of mine,¶

15 so I can't say. The massages that I recall¶

16 were from people from St. [REDACTED], and that's¶

17 what I recall.¶

18 Q. Did anyone ever complain to you¶

19 that Mr. Epstein had demanded sex of them?¶

20 MR. PAGLIUCA: Objection to form¶

21 and foundation.¶

22 A. Is that a question?¶

23 Q. Yes.¶

24 A. Never.¶

25 Q. Do you know somebody named [REDACTED]¶

1 G. Maxwell - Confidential
2 [REDACTED]
3 A. I do not.
4 Q. Who is he?
5 A. I don't know him -- I know who he
6 is now, but he worked, I believe, for [REDACTED]
7 [REDACTED], but prior to --
8 Q. [REDACTED]
9 A. Yeah.
10 Q. It's your testimony you never met
11 [REDACTED]
12 A. I don't recall ever meeting him.
13 Q. Do you remember being at [REDACTED]
14 [REDACTED]
15 [REDACTED]
16 A. I do not.
17 Q. Do you ever remember at [REDACTED]
18 [REDACTED] during
19 the period of time that you were with
20 Mr. Epstein?
21 A. I do not.
22 Q. Was there ever a time when you were
23 at [REDACTED] with a girl under the
24 age of 21 who had been with Mr. Epstein?
25 MR. PAGLIUCA: Objection to form¶

1 G. Maxwell - Confidential
2 MR. PAGLIUCA: Objection to form
3 and foundation.
4 A. No, no.
5 Q. Let me see if I can possibly
6 refresh your recollection. Do you recall
7 being at the [REDACTED]
8 [REDACTED] that was crying and very
9 distraught?
10 A. I have never seen that.
11 Q. Did you ever take the passport of
12 any person who had told you that Mr. Epstein
13 had demanded sex of them?
14 A. No.
15 Q. Were you ever at any residence of
16 Mr. Epstein's when Alan Dershowitz was
17 present?
18 A. I'm sure I was.
19 Q. Were you at Mr. Epstein's Palm
20 Beach residence when Mr. Dershowitz was
21 present?
22 A. I may have been. It's possible.
23 Q. Were you at Mr. Epstein's New
24 Mexico property when Mr. Dershowitz was
25 present?¶

1 G. Maxwell - Confidential
2 and foundation.
3 A. Can you repeat the question,
4 please?
5 Q. Sure.
6 You remember from time to time
7 being at [REDACTED], correct?
8 A. I do.
9 Q. And I think you testified that you
10 don't remember whether [REDACTED] was present
11 on any of those occasions, although he might
12 have been, correct?
13 A. If [REDACTED] was standing right
14 here in front of me, I wouldn't know who he
15 is.
16 Q. Does that mean you are saying that
17 you never met him or simply that you don't
18 remember him?
19 A. I don't know if I ever met him, but
20 if I saw him in a picture, maybe I would
21 recognize it, but I don't believe I'd
22 remember him.
23 Q. Did you ever go to the [REDACTED]
24 [REDACTED] with some woman who had previously
25 been with Mr. Epstein?¶

1 G. Maxwell - Confidential
2 A. I don't have any memory of that,
3 but it's possible. I just don't recall it.
4 Q. Were you at Mr. Epstein's Virgin
5 Islands property when Mr. Dershowitz was
6 present?
7 A. That I do recall, yes.
8 Q. Were you at Mr. Epstein's New York
9 property when Mr. Dershowitz was present?
10 A. Again, it's possible, but I don't
11 have a memory of it.
12 Q. How many times do you recall being
13 at Mr. Epstein's Virgin Island property when
14 Mr. Dershowitz was also present?
15 A. I only recall once.
16 Q. When was that?
17 A. I don't recall the date.
18 Q. Who else was present on that time?
19 A. I believe his wife and his
20 daughter.
21 Q. Anyone else?
22 A. I don't recall anyone else.
23 Q. Anyone else on the whole island. I
24 don't just mean with him. I mean did
25 Mr. Epstein have other guests with him at¶

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2 that time?
3 A. I don't recall anybody else.
4 Q. How did you arrive there?
5 A. I don't know.
6 Q. Did you come with Mr. Epstein?
7 A. I don't know, I'm sorry.
8 Q. How did Mr. Dershowitz arrive
9 there?
10 A. Again, I don't know.
11 Q. Did he come with Mr. Epstein?
12 A. I don't know.
13 Q. Other than that one time that you
14 say you were at the Virgin Island property
15 with Mr. Dershowitz, had you ever met
16 Mr. Dershowitz in Mr. Epstein's presence?
17 MR. PAGLIUCA: This is outside of
18 the court's order. I will tell you not
19 to answer that question.
20 THE WITNESS: Okay.
21 Q. Did Mr. Dershowitz ever receive a
22 massage at any of Mr. Epstein's properties?
23 A. I don't recall.
24 Q. Did you ever have any conversations
25 with Mr. Dershowitz?¶

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2 MR. PAGLIUCA: You don't have to
3 answer that question. About what,
4 anything?
5 Q. Did you ever have any conversations
6 with Mr. Dershowitz at Mr. Epstein's
7 properties?
8 A. I did, about metal detecting.
9 Q. Anything else?
10 A. I only recall metal detecting.
11 Q. Where did that conversation take
12 place?
13 A. As I was metal detecting.
14 Q. I said where?
15 A. On the island.
16 Q. That's the only conversation that
17 you recall, is that your testimony?
18 A. Yes, that is my testimony.
19 Q. Do you recall ever seeing
20 Mr. Dershowitz at any of Mr. Epstein's
21 residences other than the Virgin Island
22 property?
23 A. That's the only specific memory I
24 have of the conversation that I recall
25 because it was something special.¶

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2 Q. I'm not now asking you about a
3 conversation.
4 A. What are you asking me? Sorry.
5 Q. Do you recall ever seeing
6 Mr. Dershowitz at any of Mr. Epstein's
7 residences other than the Virgin Island
8 property?
9 A. I don't have any specific
10 recollection.
11 Q. Do you have a general recollection?
12 A. I have a general recollection that
13 I have seen him, but I just don't have any
14 other memory of it. I know I met him. I
15 just don't recall where or when, except for
16 that singular event on the island.
17 Q. When you say you have a general
18 recollection that you have seen him, do you
19 mean you have a general recollection that you
20 have seen him at Mr. Epstein's properties
21 other than the Virgin Islands?
22 A. It's just a general recollection,
23 but I have no specific memory of seeing him.
24 Q. All I'm trying to do is find out
25 whether your general recollection is a¶

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1 G. Maxwell - Confidential
2 general recollection of having seen him
3 someplace in the world or whether you have a
4 general recollection of having seen him at
5 Mr. Epstein's properties?
6 A. I'm sorry, I really can't answer.
7 I just don't know. The only memory I have of
8 him is on the island, and I don't have any
9 additional memory of him anywhere else.
10 Q. I mentioned a woman by the name of
11 [REDACTED] before. Are you familiar with a
12 [REDACTED] And I don't mean to imply
13 they are the same people.
14 A. Is this on any of these lists that
15 you gave me?
16 Q. It could have been on the first
17 list. I don't think so.
18 A. Is it on this list?
19 Q. It's not on the second list.
20 A. So what's your question?
21 Q. Are you familiar with a woman named
22 [REDACTED]
23 A. I'm familiar with the name, yes.
24 Q. Who is that person?
25 A. I don't recall who she is.¶

Page 170¶

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. What is to Mr. Epstein? A. I don't know. 0 .. Did you ever speak to connection . I don't recall. I know her name, and that's all I can -- I don't recall a conversation with her. I don't recall who she is at this int. Q. Was someone who provided massages or r. pstein? A. I don't believe so. Q. Did perform any services for r. pstein. MR. PAGLIUCA: Objection to form and foundation. A. I have no idea, I'm sorry. Q. When did you first become aware of charges that Mr. Epstein was having sex with a significant number of people at his residences? MR. PAGLIUCA: You don't have to answer that question. It's outside of the court's order.¶

1 G. Maxwell - Confidential 2 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 . re you giving me a timeframe heir. because it's been a long time. I'm assuming he is having sexual relations today. You have to bind it to some time. Q. You don't know who he is having sexual relationships with today. do you? A. No. Q. So you can only tell me who Mr. Epstein was having sexual relationships with at a time when you knew about it, correct? A. I have no knowledge of him actually having sex with anybod else outside of what we have identified, ow, ere came a time when you learned that people were asserting that he had had sexual activities with a lot more¶

Page 171¶

G. Maxwell - Confidential 2 Q. You have testified that you were 3 only aware of a few people that Mr. Epstein 4 had sex with or engaged in sexual activities 5 with at his residences, correct? 6 MR. PAGLIUCA: Objection to form and foundation. A. I didn't say that. Q. How many people are you aware of 10 that Mr. Epstein engaged in sexual activities 11 with at his residences? 12 A. I'm not aware. 13 Q. You are aware of some? 14 A. Well, the ones that we've 15 discussed, but that's all I'm aware of. 16 Q. That's my question. 17 A. Then I can concur, yes. 18 Q. Let's be clear. You have 19 identified three oeoole 20¶

Page 173¶

1 G. Maxwell - Confidential 2 than those three people at his residences, 3 correct? During the period of time that you 4 were involved with Mr. Epstein, correct? 5 A. Like everybody else, like the rest 6 of the world, when it was announced in the 7 papers. 8 Q. Yes. 9 And that was during 2005? 10 A. Whenever it was. 11 Q. At that point, did you do anything 12 to try to find out whether those assertions 13 were or were not accurate? 14 MR. PAGLIUCA: You don't have to 15 answer that. That's outside the court's 16 order. 17 Q. When you heard that there were 18 assertions that Mr. Epstein had engaged in 19 sexual activities with people who you had met 20 at Mr. Epstein's residences, did you do 21 anything to determine whether those 22 assertions were or were not accurate? 23 MR. PAGLIUCA: Objection to form 24 and foundation, and you don't have to 25 answer that question. It's outside the¶

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2 court's order.
3 Q. In terms of preparing for this
4 deposition, what documents did you review?
5 MR. PAGLIUCA: To the extent I
6 provided you with any documents to
7 review, I will tell you that's both --
8 it's privileged and I instruct you not
9 to answer.
10 Q. Did your lawyer provide you with
11 any documents to review in preparation for
12 this deposition that refreshed your
13 recollection about any of the events that
14 occurred?
15 MR. PAGLIUCA: You can answer that
16 question.
17 A. No.
18 Q. How many documents did your lawyer
19 provide you with?
20 MR. PAGLIUCA: You can answer.
21 A. One, I believe.
22 Q. One document. Was that a document
23 that had been prepared by your attorney, or
24 was it a document from the past?
25 MR. PAGLIUCA: I will tell you not¶

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1 G. Maxwell - Confidential
2 to answer that question.
3 Q. Was the document that your attorney
4 showed you a document that you had ever seen
5 before?
6 MR. PAGLIUCA: Again, don't answer
7 questions about what I showed you or
8 didn't show you.
9 She already testified that nothing
10 refreshed her recollection.
11 MR. BOIES: I don't have to accept
12 that answer. I can ask these questions,
13 and I think these are clearly not
14 privileged questions.
15 Q. Do you know a [REDACTED]
16 A. I do.
17 Q. Who is [REDACTED]
18 A. She was a friend of Jeffrey's.
19 Q. Was [REDACTED] someone with whom
20 Mr. Epstein engaged in sexual activities?
21 MR. PAGLIUCA: Objection to form
22 and foundation.
23 A. I don't know.
24 Q. Did you ever have any reason to
25 believe that Mr. Epstein was engaged in¶

Page 176¶

1 G. Maxwell - Confidential
2 sexual activities with [REDACTED]
3 MR. PAGLIUCA: Objection to form
4 and foundation.
5 A. I didn't have any reason -- I had
6 no idea whether they were or weren't.
7 Q. Were you with Mr. Epstein in 2005
8 when the Palm Beach police launched their
9 investigation?
10 MR. PAGLIUCA: You don't have to
11 answer the question. That's outside the
12 court's order.
13 Q. When the Palm Beach police launched
14 their investigation in 2005, did you make any
15 effort to retain records of the women who had
16 been present at Mr. Epstein's residences in
17 the prior period?
18 MR. PAGLIUCA: Don't answer that
19 question. It's outside the court's
20 order.
21 Q. When the Palm Beach police launched
22 their investigation in 2005, were you aware
23 of any effort to destroy records of women who
24 had been present at Mr. Epstein's residences
25 in the prior period?¶

Page 177¶

1 G. Maxwell - Confidential
2 MR. PAGLIUCA: Don't answer that
3 question. It's outside the court's
4 order.
5 Q. In 2005, were you aware of any
6 effort to destroy records of messages you had
7 taken of women who had called Mr. Epstein in
8 the prior period?
9 MR. PAGLIUCA: Don't answer that
10 question. It's outside the court's
11 order.
12 MR. BOIES: I said I would give you
13 a break every hour. It's been an hour.
14 MR. PAGLIUCA: Do you want a break
15 or do you want to keep going?
16 THE WITNESS: Keep going.
17 MR. BOIES: What I told you before,
18 you asked for a break every hour. I am
19 happy to give you a break at a fixed
20 time. What I'm not happy to do is
21 interrupt a chain of examination.
22 So if you want a break now, we will
23 take a break now. If you don't want a
24 break now, we will not break for another
25 hour.¶

Page 178¶

Page 180¶

1 G. Maxwell - Confidential
2 MR. PAGLIUCA: Is there a rule that
3 you can point me to that mandates that
4 you get to control the time and place of
5 breaks?¶

6 MR. BOIES: No. We will take a
7 break now, because if what you are going
8 to do is say, you said at the very
9 beginning of this thing that you wanted
10 to have a rule that every hour we took a
11 break, and I said that was fine with me,
12 but I just didn't want you taking a
13 break, particularly since you reserve
14 the right to talk to your client during
15 breaks, in the middle of an examination.¶

16 Now you are saying let's continue
17 for a while but I am not agreeing to
18 continue for the next hour. We will
19 take a break, and we will come back and
20 we will go from there.¶

21 MR. PAGLIUCA: We will take a break
22 at your request now, and then if I want
23 to take a break, we will take another
24 break.¶

25 MR. BOIES: If you take a break to¶

Page 179¶

Page 181¶

1 G. Maxwell - Confidential
2 talk to your witness, I guarantee you
3 there will be a motion for sanctions. I
4 think what you're doing with this
5 witness is inappropriate. I think your
6 instructions not to answer,
7 conversations that you had with her
8 while she is under oath and under
9 examination is inappropriate.¶

10 THE VIDEOGRAPHER: It's 2:18 p.m.,
11 and we are off the record.
12 (Recess.)¶

13 THE VIDEOGRAPHER: The time is 2:28
14 p.m. This also begins DVD No. 6.¶

15 BY MR. BOIES:¶

16 Q. Let me hand you a document that has
17 been previously marked as Maxwell Exhibit 13.
18 And I would like you to turn to page 91 of
19 that exhibit. And you see the heading that
20 says, "Massage-Florida"?¶

21 A. Actually, I don't -- yes, I do,
22 sorry.¶

23 Q. Then you see a list of telephone
24 numbers with names?¶

25 A. I do.¶

1 G. Maxwell - Confidential¶

2 Q. I would like to go down those names
3 and see if any of those people are people
4 that you recognize. However you think is
5 best, we can go name by name, or you can tell
6 me which ones you recognize and which ones
7 you don't.¶

8 A. I recognize [REDACTED]. I recognize
9 [REDACTED]. These are
10 names that ring bells, nothing else.¶

11 [REDACTED] I recognize the name.¶

12 Q. Where is [REDACTED]¶

13 A. [REDACTED]. I just recognize
14 these names. It doesn't mean anything else.
15 I'm just recognizing names.¶

16 [REDACTED].
17 Let me do it again and make sure I
18 didn't miss anyone. That's it.¶

19 Q. Now, with respect to the people
20 that you say you recognized the names of,
21 [REDACTED], were¶

22 [REDACTED], were
23 any of those people, people who provided
24 massages to Mr. Epstein?¶

25 MR. PAGLIUCA: Objection to form¶

1 G. Maxwell - Confidential
2 and foundation.¶

3 A. Sorry, I guess. I believe [REDACTED]
4 did, and I believe -- I think that's it that
5 I know of, I think.¶

6 Q. Now, just going down the names of
7 people that you did not recognize, I take it
8 you are not aware or recognize the name [REDACTED]
9 first name?¶

10 A. It was just a first name. I can't
11 think of a [REDACTED] at this point.¶

12 Q. The same thing is true for [REDACTED]¶

13 A. I don't recognize [REDACTED].¶

14 Q. And [REDACTED]¶

15 A. I don't recognize [REDACTED]¶

16 Q. And [REDACTED]¶

17 A. Is that [REDACTED] Where is that?
18 That's [REDACTED], I'm sorry, I missed her.
19 That would probably be [REDACTED].¶

20 I think [REDACTED] might have been a
21 masseuse as well. There is a [REDACTED] in the
22 back of my head.¶

23 Q. [REDACTED]¶

24 A. I don't know who that is.¶

25 Q. What about [REDACTED]¶

Page 182¶

1 G. Maxwell - Confidential¶

2 A. No.¶

3 Q. What about [REDACTED]¶

4 A. No.¶

5 Q. [REDACTED]¶

6 A. No.¶

7 Q. [REDACTED]¶

8 A. I didn't think I know a [REDACTED]¶

9 period.¶

10 Q. [REDACTED]¶

11 A. No.¶

12 Q. Is that Virginie?¶

13 A. I don't know what that is.¶

14 Q. Then there is a [REDACTED] or [REDACTED]¶

15 Do you see that?¶

16 A. I don't see that.¶

17 Q. It's right after Virginia, which is¶

18 right after [REDACTED]¶

19 A. I see it. I don't know who that¶

20 is.¶

21 Q. How about [REDACTED]¶

22 A. No idea.¶

23 Q. There is someone here [REDACTED], and¶

24 described as a redhead?¶

25 A. I don't know who that is.¶

Page 183¶

1 G. Maxwell - Confidential¶

2 Q. [REDACTED]¶

3 A. No.¶

4 Q. And there is a [REDACTED]¶

5 A. I don't know.¶

6 Q. [REDACTED]¶

7 A. No idea.¶

8 Q. Then there is [REDACTED]¶

9 A. That's a name that keeps coming up.¶

10 I recognize the name, but I don't know her in¶

11 particular.¶

12 Q. What about [REDACTED]¶

13 A. I have no idea who that is.¶

14 Q. [REDACTED]¶

15 A. No idea.¶

16 Q. Somebody that's listed as¶

17 [REDACTED], Virginia's friend?¶

18 A. No.¶

19 Q. [REDACTED], do you know who that¶

20 is?¶

21 A. No.¶

22 Q. How about [REDACTED] friend?¶

23 A. No.¶

24 Q. Do you know who [REDACTED] is?¶

25 A. No.¶

Page 184¶

1 G. Maxwell - Confidential¶

2 Q. Next one is [REDACTED] --¶

3 A. [REDACTED] is Virginia's guy that you¶

4 asked me about. I don't know [REDACTED]¶

5 Q. I asked you about a [REDACTED].¶

6 A. Right, I don't know him, so I'm¶

7 guessing, I don't know him.¶

8 Q. [REDACTED]¶

9 A. No.¶

10 Q. [REDACTED]¶

11 A. No.¶

12 Q. [REDACTED]¶

13 A. I don't know who these people are.¶

14 Q. Was there a list that was kept of¶

15 women or girls who provided massages?¶

16 MR. PAGLIUCA: This has been¶

17 previously deposed on. This is not part¶

18 of the court's order, I will tell her¶

19 not to answer.¶

20 MR. BOIES: You are going to tell¶

21 her not to answer a question that says¶

22 was there a list of women or girls who¶

23 provided massages?¶

24 MR. PAGLIUCA: She has been¶

25 previously deposed on this subject.¶

Page 185¶

1 G. Maxwell - Confidential¶

2 MR. BOIES: I think this is¶

3 squarely in the court's order, but if¶

4 you instruct her not to answer, you¶

5 instruct her not to answer.¶

6 MR. PAGLIUCA: We'll find out.¶

7 BY MR. BOIES:¶

8 Q. I take it you don't know the ages¶

9 of any of these people?¶

10 A. The ones that I did recognize were¶

11 roughly my age. The ones I don't know, I¶

12 wouldn't have a clue.¶

13 Q. Did you, or insofar as you are¶

14 aware anyone, maintain a list of females that¶

15 provided massage services to Mr. Epstein at¶

16 his residences?¶

17 MR. PAGLIUCA: Objection to form¶

18 and foundation.¶

19 You can answer if you can.¶

20 A. I don't know anything about a list.¶

21 Q. Let me go back to Exhibit 28. I¶

22 want to go down this list, excluding¶

23 Mr. Epstein himself, and just ask you a¶

24 series of the same essential questions about¶

25 each one.¶

Page 186¶

Page 188¶

1 G. Maxwell - Confidential
2 [REDACTED], which of Mr. Epstein's
3 residences did you see [REDACTED] at?
4 A. I don't have a memory of [REDACTED]
5 where I would have seen her.
6 Q. Did you see her at some residence
7 or property?
8 A. I did.
9 Q. Of Mr. Epstein?
10 A. I did.
11 Q. You just can't remember which ones,
12 is that fair?
13 A. Yes, that's fair.
14 Q. [REDACTED], which residences of
15 Mr. Epstein did you see [REDACTED] at?
16 A. I don't actually recall meeting
17 [REDACTED], so I can't recall.
18 Q. So [REDACTED] may be somebody
19 who you never met, is that your testimony?
20 A. No, I'm not saying that. I just
21 don't recall her really at all. I'm sorry, I
22 don't recall.
23 Q. Did you see [REDACTED] at some
24 residence or property of Mr. Epstein?
25 A. I don't recall.¶

1 G. Maxwell - Confidential
2 not to answer these questions anymore.
3 These do not appear -- I let this go on,
4 they don't appear to be tied to the
5 court's order as relating to sex or
6 massages or anything that's contained in
7 the order. This is just simply what was
8 somebody doing at some property at some
9 point in time. So don't answer these
10 questions.
11 Q. It is your assertion that, leaving
12 Mr. Epstein aside, none of the people on this
13 list engaged in sexual activities with either
14 you or Mr. Epstein, correct?
15 MR. PAGLIUCA: Objection to form
16 and foundation.
17 A. I can only testify to myself. I
18 cannot testify to Mr. Epstein.
19 Q. With respect to Mr. Epstein, do you
20 know, one way or another, whether any of
21 these people engaged in sexual activities?
22 A. With respect to Mr. Epstein, how
23 would I know that?
24 Q. The answer is lots of ways, but all
25 I can do is ask you whether you know it or¶

Page 187¶

Page 189¶

1 G. Maxwell - Confidential
2 Q. [REDACTED], what properties of
3 Mr. Epstein did you see [REDACTED] at?
4 A. Palm Beach, and I believe New
5 Mexico and New York.
6 Q. And [REDACTED]
7 A. Palm Beach, I believe.
8 Q. And what was [REDACTED] doing at
9 Palm Beach when you saw her?
10 A. If I remember correctly, she was a
11 real estate broker.
12 Q. Did you see [REDACTED] at
13 Mr. Epstein's Virgin Island property?
14 A. I don't recall.
15 Q. When you saw [REDACTED] in Palm
16 Beach and New Mexico and New York, what was
17 she doing?
18 A. I don't know.
19 Q. Do you know why she was there?
20 A. I think she was just a friend.
21 Q. A friend of Mr. Epstein's?
22 A. Yeah.
23 Q. [REDACTED], what Epstein
24 properties did you see her at?
25 MR. PAGLIUCA: I will now tell you¶

1 G. Maxwell - Confidential
2 not.
3 A. I don't.
4 Q. Do you have any reason to believe
5 -- because I don't want to get stuck on your
6 concept of personal knowledge -- do you have
7 any reason to believe that any of the people
8 on this list had sexual activities with
9 Mr. Epstein?
10 A. I do not.
11 Q. Do you have any reason to believe
12 that any of these people had massages at any
13 Epstein property?
14 A. I have no idea. It's entirely
15 possible, but I have no idea.
16 Q. Do you have any reason to believe
17 that any of the people on this list, other
18 than Mr. Epstein himself, engaged in sexual
19 activities with anyone on Mr. Epstein's
20 properties?
21 A. I have no reason to believe that.
22 Q. Let me go to [REDACTED].
23 I asked you some questions about [REDACTED]
24 [REDACTED] earlier and about a possible visit
25 to that residence of a [REDACTED]. Do you¶

Page 190¶

1 G. Maxwell - Confidential
2 recall that subject generally?
3 A. I recall you asking me a question
4 about it, yes, I do.
5 Q. Let me ask about another time at
6 the [REDACTED]. Were you ever at the
7 [REDACTED] with people who worked at the
8 Epstein residence?
9 MR. PAGLIUCA: Objection to form
10 and foundation.
11 A. No.
12 Q. Were you ever at the [REDACTED]
13 [REDACTED] when there were a number of females
14 under the age of 21 dancing?
15 A. Excuse me?
16 Q. Were you ever at the [REDACTED]
17 [REDACTED] when there were a number of females
18 under the age of 21 dancing?
19 A. The only people I have seen dancing
20 at any [REDACTED].
21 Q. Just those children, no other
22 children?
23 A. No other children.
24 Q. Were you ever at the [REDACTED]
25 [REDACTED] when females who you had seen at¶

Page 191¶

1 G. Maxwell - Confidential
2 the residences of Mr. Epstein, [REDACTED]
3 [REDACTED], were present and dancing?
4 A. Can you ask me the question again?
5 Q. Sure. I'm focusing on [REDACTED]
6 [REDACTED] and I'm focusing on children other
7 than [REDACTED].
8 A. I'm there.
9 Q. I'm asking whether you were ever at
10 [REDACTED] where there were females
11 other than the [REDACTED] who were
12 dancing.
13 A. I've never witnessed --
14 MR. PAGLIUCA: Objection to form
15 and foundation.
16 A. [REDACTED], who I have
17 certainly seen dancing, I don't recall any
18 dancing at [REDACTED] by any
19 other people.
20 MR. BOIES: I think pending
21 resolution of the instructions not to
22 answer, I don't have any further
23 questions at this time. If you give me
24 a minute, just to check.
25 Thank you very much.¶

Page 192¶

1 G. Maxwell - Confidential
2 MR. PAGLIUCA: I want to make a
3 record here before we are done. I do
4 get a chance to speak. Are we going off
5 the record now?
6 MR. BOIES: You want to talk on the
7 record?
8 MR. PAGLIUCA: Yes, is that okay
9 with you?
10 MR. BOIES: You want to ask her
11 questions?
12 MR. PAGLIUCA: No. I want to make
13 a record of your closing of the
14 deposition.
15 MR. BOIES: I don't know how you
16 can make a record of my closing the
17 deposition, but if you want to take up
18 the time and the transcript space to
19 talk as opposed to writing a letter or
20 filing a motion, go for it.
21 MR. PAGLIUCA: To the extent you
22 have questions that are within the
23 court's order that you haven't asked,
24 that I haven't objected to, meaning no
25 other questions, this deposition is¶

Page 193¶

1 G. Maxwell - Confidential
2 closed.
3 If there are questions that I have
4 instructed the witness not to answer and
5 it later turns out the judge disagrees
6 with my characterization, we will be
7 back to revisit it, but we are done as
8 far as I'm concerned.
9 MR. BOIES: The deposition is not
10 closed. There are a number of
11 instructions not to answer. I think it
12 is a fair point that if the court were
13 to conclude that none of the questions
14 that have been instructed need to be
15 answered, we're not going to be
16 continuing the deposition, barring some
17 additional information coming to light.
18 MR. PAGLIUCA: I think we agree
19 then.
20 THE VIDEOGRAPHER: The time is 2:51
21 p.m., and we are going off the record.
22 (Time noted: 2:51 p.m.)
23
24
25¶

1 2 3 4 5 6 7 8 9	INDEX GHISLAINE MAXWELL By Mr. Boles	PAGE 4	Page 194 1 2 3 Questions Marked 4 Page Line Page Line Page Line 5 None 6 7 8 9
10	EXHIBITS		10
11			11
12	EXHIBIT	PAGE	12
13	Exhibit 26 List of names	23	13
14	Exhibit 27 Article	94	14
15	Exhibit 28 List of names	135	15
16			16
17			17
18			18
19			19
20			20
21			21
22			22
23			23
24			24

25		25
		Page 195	Page 197
1		1
2		2	CERTIFICATE
3	DEPOSITION SUPPORT INDEX	3
4		4
5	Direction to Witness Not to Answer	5	I HEREBY CERTIFY that GHISLAINE
6	Page Line Page Line Page Line	6	MAXWELL, was duly sworn by me and that the
	50 22 50 25 51 5	7	deposition is a true record of the testimony
	51 9 51 17 51 22	8	given by the witness.
	52 2 81 17 82 6
	82 25 83 7 94 21		Leslie Fagin.
	95 6 98 12 118 11		Registered Professional Reporter
	142 6 142 13 165 16		Dated: July 22, 2016
	165 25 169 22 172 13
14	172 22 173 4 173 24	14
15	174 5 175 9 175 17	15	(The foregoing certification of
16	175 25 176 8 183 14	16	this transcript does not apply to any
17	186 23	17	reproduction of the same by any means, unless
18		18	under the direct control and/or supervision
19	Request for Production of Documents	19	of the certifying reporter.)
20	Page Line Page Line Page Line	20
21	None	21
22		22
23	Stipulations	23
24	Page Line Page Line Page Line	24
25	None	25

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Page 198 1 ACKNOWLEDGMENT OF DEPONENT 2 I, , do hereby certify that I have read the foregoing pages, and that the same is a correct transcription of the answers given by me to the questions therein propounded, except for the corrections or changes in form or substance, if any, noted in the attached Errata Sheet. 3 GHISLAINE MAXWELL DATE 4 Subscribed and sworn to before me this day of, 2016. 5 My commission expires: 6 Notary Public 7

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![](_page_51_Picture_11.jpeg)¶

A

![](_page_53_Picture_6.jpeg)¶

![](_page_55_Picture_6.jpeg)¶

<p><b>香港特别市政府英属新加坡</b> <span><span><span></span></span></span></p>
	<span></span>	<span></span>	<span></span>	<span></span>	<span></span>
<b>行政区划</b>	<span> </span>	<span> </span>	<span> </span>	<span> </span>	<span> </span>
<b>市</b>	<span> </span>	<span> </span>	<span> </span>	<span> </span>	<span> </span>
<b>县</b>	<span> </span>	<span> </span>	<span> </span>	<span> </span>	<span> </span>
<b>市辖区</b>	<span> </span>	<span> </span>	<span> </span>	<span> </span>	<span> </span>
<b>市政府</b>	<span> </span>	<span> </span>	<span> </span>	<span> </span>	<span> </span>
<b>市长</b>	<span> </span>	<span> </span>	<span> </span>	<span> </span>	<span> </span>
<b>市议会</b>	<span> </span>	<span> </span>	<span> </span>	<span> </span>	<span> </span>
<b>市议员</b>	<span> </span>	<span> </span>	<span> </span>	<span> </span>	<span> </span>
<b>市议会</b>	<span> </span>	<span> </span>	<span> </span>	<span> </span>	<span> </span>
<b>市议员</b>	<span> </span>	<span> </span>	<span> </span>	<span> </span>	<span> </span>

![](_page_58_Picture_6.jpeg)¶

<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>افراد</span></div> <div><span></span></div> <div><span>نام</span></div> <div><span></span></div> </div>	<p><span><b>والد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>والاتحاد</span></div> <div><span></span></div> <div><span>المعلومات</span></div> <div><span></span></div> </div>	<p><span><b>زرد الزرد</b></span></p> <div> <div><span> </span><span> </span><span> </span></div> <div><span></span></div> <div><span>استاد</span></div> <div><span></span></div> <div><span>وال</span></div></div>
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EXHIBIT D¶