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2 meet Mr. Epstein?
3 MR. PAGLIUCA: Object to the form
4 and foundation.
5 Q. You can answer.
6 A. I just explained.
7 A. I spent the entire time talking to
8 █ mother outside the house so the
9 answer to the question is no.
10 Q. No, did you not walk her up and
11 introduce her to Mr. Epstein?
12 A. I just said no.
13 Q. Did you participate in a massage
14 this first time when she first came to the
15 home and you were speaking with her mother,
16 she was in the home, is that correct, you
17 brought her into the home?
18 MR. PAGLIUCA: Object to the form
19 and foundation.
20 A. I will repeat again, I was standing
21 outside with her mother so very difficult for
22 me to do anything else at that time so no, I
23 did not take her upstairs.
24 Q. Did you participate --
25 A. Virginia lied 100 percent about
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2 you not to answer that question. I
3 don't have any problem with you asking
4 questions about what the subject matter
5 of this lawsuit is, which would be, as
6 you've termed it, sexual trafficking of
7 █
8 To the extent you are asking for
9 information relating to any consensual
10 adult interaction between my client and
11 Mr. Epstein, I'm going to instruct her
12 not to answer because it's not part of
13 this litigation and it is her private
14 confidential information, not subject to
15 this deposition.
16 MS. McCAWLEY: You can instruct her
17 not to answer. That is your right. But
18 I will bring her back for another
19 deposition because it is part of the
20 subject matter of this litigation so she
21 should be answering these questions.
22 This is civil litigation, deposition and
23 she should be responsible for answering
24 these questions.
25 MR. PAGLIUCA: I disagree and you
| | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | |Page 19
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2 absolutely everything that took place in that
3 first meeting. She has lied repeatedly,
4 often and is just an awful fantasist. So
5 very difficult for anything to take place
6 that she repeated because I was with her
7 mother the entire time.
8 Q. So did you have -- did you give a
9 massage with █ and Mr. Epstein
10 during the first time █ was at
11 the West Palm Beach house?
12 MR. PAGLIUCA: Object to the form
13 and foundation.
14 Q. Yes or no?
15 A. No.
16 Q. Have you ever given a massage with
17 █ in the room and Jeffrey
18 Epstein?
19 MR. PAGLIUCA: Object to the form
20 and foundation.
21 A. No.
22 Q. Have you ever given Jeffrey Epstein
23 a massage?
24 MR. PAGLIUCA: Object to the form,
25 foundation. And I'm going to instruct
|Page 21
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2 understand the bounds that I put on it.
3 MS. McCAWLEY: No, I don't. I will
4 continue to ask my questions and you can
5 continue to make your objections.
6 Q. Did you ever participate from the
7 time period of 1992 to 2009, did you ever
8 participate in a massage with Jeffrey Epstein
9 and another female?
10 MR. PAGLIUCA: Objection. Do not
11 answer that question. Again, to the
12 extent you are asking for some sort of
13 illegal activity as you've construed in
14 connection with this case I don't have
15 any problem with you asking that
16 question. To the extent these questions
17 involve consensual acts between adults,
18 frankly, they're none of your business
19 and I will instruct the witness not to
20 answer.
21 MS. McCAWLEY: This case involves
22 sexual trafficking, sexual abuse,
23 questions about her having interactions
24 with other females is relevant to this
25 case. She needs to answer these
| |Page 22
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2 questions.
3 MR. PAGLIUCA: I'm instructing her
4 not to answer.
5 MS. McCAWLEY: Then we will be back
6 here again.
7 Q. Have you ever given a massage to
8 Mr. Epstein with a female that was under the
9 age of 18?
10 A. Can you repeat the question?
11 Q. Yes. Have you ever given a massage
12 to Mr. Epstein with a female that was under
13 the age of 18?
14 A. No.
15 Q. Have you ever observed Mr. Epstein
16 having a massage given by an individual, a
17 female, who was under the age of 18?
18 A. No.
19 Q. Have you ever observed females
20 under the age of 18 in the presence of
21 Jeffrey Epstein at his home?
22 MR. PAGLIUCA: Object to the form
23 and foundation.
24 A. Again, I have friends that have
25 children --
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1 G Maxwell - Confidential
2 MR. PAGLIUCA: Object to the form
3 and foundation.
4 A. How would I possibly know how
5 someone is when they are at his house. You
6 are asking me to do that. I cannot possibly
7 testify to that. As far as I'm concerned,
8 everyone who came to his house was an adult
9 professional person.
10 Q. Are you familiar with the police
11 report that was issued in respect to the
12 investigation in this matter?
13 MR. PAGLIUCA: Object to the form
14 and foundation.
15 Q. Are you familiar with the police
16 report that was used in this matter, the
17 investigation of Jeffrey Epstein, has been
18 produced as a document in this matter?
19 A. I have seen a police report.
20 (Maxwell Exhibit 1, police report,
21 marked for identification.)
22 Q. The police report that you have in
23 front of you, can you turn to page 28 of that
24 report, the numbers are on the top right-hand
25 corner.
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1 G Maxwell - Confidential
2 Q. I'm not talking about friends. I'm
3 talking about individuals --
4 MR. PAGLIUCA: I'm going to object
5 to you interrupting the witness who was
6 answering your question. The question
7 was, have you ever seen anyone, female
8 under the age of 18 at the house and
9 that's the question she was answering.
10 If you want to strike that question and
11 ask another question, feel free, but let
12 the witness respond, please.
13 MS. McCAWLEY: I will do that.
14 Q. Have you ever observed a female
15 under the age of 18 at Jeffrey Epstein's home
16 that was not a friend, a child -- one of your
17 friend's children?
18 A. Again, I can't testify to that
19 because I have no idea what you are talking
20 about.
21 Q. You have no idea what I'm talking
22 about in the sense you never observed a
23 female under the age of 18 at Jeffrey
24 Epstein's home that was not one of your
25 friend's children, is that correct?
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1 G Maxwell - Confidential
2 You will see some redactions in
3 this report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it says, [REDACTED] stated
9 she performed the massage naked. At the
10 conclusion of this massage, Epstein paid
11 [REDACTED] \$200 for the massage. He explained, I
12 know you are not comfortable put I will pay
13 you if you bring some girls. He told her the
14 younger the better. [REDACTED] stated once tried
15 to bring a 23 year old to Epstein and he
16 stated the female was too old.
17 Have you heard Mr. Epstein use the
18 phrase the younger the better?
19 A. I have no recollection of hearing
20 that.
21 Q. Have you used the phrase in talking
22 to [REDACTED] and asking her to recruit
23 females for Mr. Epstein, the younger the
24 better?
25 MR. PAGLIUCA: Object to the form
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2 A. I have.
3 Q. No, you haven't.
4 A. Yes, I have.
5 Q. You are refusing to answer the
6 question.
7 A. Let's move on.
8 Q. I'm in charge of the deposition. I
9 say when we move on and when we don't.
10 You are here to respond to my
11 questions. If you are refusing to answer the
12 court will bring you back for another
13 deposition to answer these questions.
14 Do you understand that?
15 MR. PAGLIUCA: You don't need to
16 threaten the witness.
17 MS. MCCAWLEY: I'm not threatening
18 her. I'm making sure the record is
19 clear.
20 MR. PAGLIUCA: Certainly can you
21 apply to have someone come back and the
22 court may or may not have her come back
23 again.
24 Again, she is not answering
25 questions that relate to adult consent
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2 sexual acts on her?
3 MR. PAGLIUCA: Object to the form
4 and foundation.
5 A. I have not heard that.
6 Q. How do you know [REDACTED]?
7 A. [REDACTED]
8 [REDACTED]
9 [REDACTED].
10 Q. Was [REDACTED] under the age of
11 18?
12 MR. PAGLIUCA: Object to the form
13 and foundation.
14 A. I don't recall how old [REDACTED]
15 was.
16 Q. Did she tell police that Jeffrey
17 Epstein assaulted her sexually?
18 MR. PAGLIUCA: Object to the form
19 and foundation.
20 A. I never heard that.
21 Q. Did [REDACTED] recruit or bring
22 girls to the home that were under the age of
23 18?
24 MR. PAGLIUCA: Object to the form
25 and foundation and I think this has been
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2 sex acts. Period. And that's the
3 instruction and we can take it up with
4 the court.
5 Q. Ms. Maxwell, are you aware of any
6 sexual acts with masseuses and Jeffrey
7 Epstein that were nonconsensual?
8 A. No.
9 Q. How do you know that?
10 A. All the time that I have been in
11 the house I have never seen, heard, nor
12 witnessed, nor have reported to me that any
13 activities took place, that people were in
14 distress, either reported to me by the staff
15 or anyone else. I base my answer based on
16 that.
17 Q. Are you familiar with a person by
18 the name of [REDACTED]?
19 A. I am.
20 Q. Has [REDACTED] given a statement
21 to police about you performing sexual acts on
22 her?
23 A. I have not heard that.
24 Q. Has [REDACTED] given a statement
25 to police about Jeffrey Epstein performing
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2 asked and answered already.
3 Q. You can answer the question.
4 A. I have no idea what [REDACTED]
5 did.
6 Q. You never observed [REDACTED]
7 with girls under the age of 18 at Jeffrey's
8 home?
9 MR. PAGLIUCA: Object to the form
10 and foundation.
11 A. The answer is no, I have no idea.
12 Q. Do you know Glenn [REDACTED]?
13 A. I do.
14 Q. What is your relationship with
15 Glenn [REDACTED]?
16 MR. PAGLIUCA: Object to the form.
17 A. What do you mean what is my
18 relationship.
19 Q. Are you friendly with him, how do
20 you know him?
21 A. He is the husband of Eva [REDACTED].
22 Q. Is Eva [REDACTED] one of your friends?
23 A. Yes.
24 Q. Did you ever send Virginia to
25 Glenn's condo at the Breakers to give him a
| |Page 58
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2 massage?
3 MR. PAGLIUCA: Objection to the
4 form and foundation.
5 A. No.
6 Q. Did you ever instruct Virginia
7 [REDACTED] to have sex with Glenn?
8 MR. PAGLIUCA: Objection to the
9 form and foundation.
10 A. I have never instructed Virginia to
11 have sex with anybody ever.
12 Q. How old was Eva [REDACTED] when she
13 met Jeffrey?
14 MR. PAGLIUCA: Objection to the
15 form and foundation.
16 A. I have no idea.
17 Q. What's she under the age of 18?
18 MR. PAGLIUCA: Objection to the
19 form and foundation.
20 A. I just testified I have idea how
21 old she was.
22 Q. You testified she was your friend.
23 You don't know how old she was when she met
24 Jeffrey?
25 A. That happened sometime in the '70s,
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2 A. She was tasked to answer
3 telephones.
4 Q. Did you ever ask her to rub
5 Jeffrey's feet?
6 MR. PAGLIUCA: Objection to the
7 form and foundation.
8 A. I believe that I have read that,
9 but I don't have any memory of it.
10 Q. Did you ever tell [REDACTED] that she
11 would get extra money if she provided Jeffrey
12 massages?
13 A. I was always happy to give career
14 advice to people and I think that becoming
15 somebody in the healthcare profession, either
16 exercise instructor or nutritionist or
17 professional massage therapist is an
18 excellent job opportunity. Hourly wages are
19 around 7, 8, \$9 and as a professional
20 healthcare provider you can earn somewhere
21 between as we have established 100 to \$200
22 and to be able to travel and have a job that
23 pays that is a wonderful job opportunity. So
24 in the context of advising people for
25 opportunities for work, it is possible that I
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2 how would I know, or '80s. I have no idea.
3 Can you testify to what your friends did 30
4 years ago?
5 Q. You don't ask the questions here,
6 Ms. Maxwell.
7 What about [REDACTED], when
8 did you first meet [REDACTED]?
9 A. I don't recall the exact date.
10 Q. Did you hire [REDACTED]?
11 A. I don't hire people, she came to
12 work at the house to answer phones.
13 Q. Where did you meet her?
14 A. I just testified, I don't recall
15 exactly when I met her.
16 Q. Was one of your job
17 responsibilities to interview people that
18 would be then hired by Jeffrey?
19 A. That was one of my
20 responsibilities.
21 Q. Do you recall interviewing [REDACTED]?
22 A. I don't recall the exact interview,
23 no.
24 Q. Do you know what tasks [REDACTED] was
25 hired to performance?
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2 would have said that she should explore that
3 as an option.
4 Q. Did you tell her she would get
5 extra money if she massaged Jeffrey?
6 A. I'm just saying, I cannot recall
7 the exact conversation. I give career advice
8 and I have done that.
9 Q. Did you ever have [REDACTED] massage
10 you?
11 A. I did.
12 Q. How many times?
13 A. I don't recall how many times.
14 Q. Was there sex involved?
15 A. No.
16 Q. Did you ever instruct [REDACTED] to
17 massage Glenn [REDACTED]?
18 A. I don't believe -- I have no
19 recollection of it.
20 Q. Did you ever have sexual contact
21 with [REDACTED]?
22 MR. PAGLIUCA: Object to the form
23 and foundation. You need to give me an
24 opportunity to get in between the
25 questions.
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2 over to the house in Palm Beach to give
3 massages?
4 A. It's important to understand that I
5 wasn't with Jeffrey all the time. In fact, I
6 was only in the house less than half the
7 time, so I cannot testify to when I wasn't in
8 the house how often she came when I wasn't
9 there.
10 What I can say is that I barely
11 would remember her, if not for all of this
12 rubbish, I probably wouldn't remember her at
13 all, except she did come from time to time
14 but I don't recollect her coming as often as
15 she portrayed herself.
16 Q. How many times a day on an average
17 day would Jeffrey Epstein get a massage?
18 MR. PAGLIUCA: Objection to the
19 form and foundation.
20 A. When I was at the house and when I
21 was there with him, he received a massage, on
22 average, about once a day.
23 Q. Just once?
24 A. Yes.
25 Q. Were there days when he received
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2 all, except for this story.
3 Q. Do you recall [REDACTED]
4 calling you because she was having a medical
5 crisis and you and Jeffrey taking her to the
6 hospital?
7 A. I have heard this absurd story and
8 if any part of it were true I would remember
9 that. I do not.
10 Q. You don't remember taking her to
11 the hospital?
12 A. It's not that I don't remember it,
13 it didn't happen.
14 Q. How do you know it didn't happen?
15 A. That's the sort of memory you would
16 recall.
17 Q. Do you recall, you said you don't
18 remember her being at the New York mansion.
19 When you were in New York would you stay at
20 the New York mansion with Jeffrey?
21 A. I stayed from time to time.
22 Q. Do you recall Virginia being at the
23 New York mansion when [REDACTED] came to
24 visit?
25 MR. PAGLIUCA: Objection to the
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2 four or five?
3 MR. PAGLIUCA: Objection to the
4 form and foundation.
5 A. When I was present at the house, I
6 never saw something like that.
7 Q. Do you know if Virginia was
8 required to be on call at all times to come
9 to the house if Jeffrey wanted her there?
10 MR. PAGLIUCA: Objection to the
11 form and foundation.
12 A. I have no idea of the arrangements
13 that Virginia made with Jeffrey.
14 Q. When Virginia was in New York,
15 would Virginia sleep at Jeffrey's mansion in
16 New York?
17 MR. PAGLIUCA: Objection to the
18 form and foundation.
19 A. I don't recollect her being in New
20 York and I have no idea where she slept.
21 Q. You don't ever remember seeing
22 [REDACTED] in New York?
23 MR. PAGLIUCA: Objection to the
24 form and foundation.
25 A. I would barely recollect her at
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2 form and foundation.
3 A. Like I told you, I don't recall her
4 being at the house at all.
5 Q. How many homes does Jeffrey have?
6 MR. PAGLIUCA: Objection to the
7 form and foundation.
8 A. When I was working for him, I think
9 he had six maybe.
10 Q. Would Virginia stay with him in
11 those homes?
12 MR. PAGLIUCA: Objection to the
13 form and foundation.
14 A. I can only testify for when I was
15 present with him and I cannot say what she
16 did when I wasn't present with him.
17 Q. When you were present, would
18 Virginia stay in the homes with him?
19 A. I don't recall her staying in the
20 houses.
21 Q. Did you train Virginia on how to
22 recruit other girls for massages?
23 MR. PAGLIUCA: Objection to the
24 form and foundation.
25 A. No.
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2 Q. I'm asking the questions. I know
3 what this case is about. I'm trying to -- I
4 will ask you questions if you don't
5 understand the question I can break it down
6 for you. I'm happy to do that.
7 A. Break it down a lot please.
8 Q. I will do that.
9 The question is, have you ever said
10 to anybody that you recruit other girls --
11 A. Why don't you stop there.
12 Q. Let me finish my question.
13 Have you ever said to anybody that
14 you recruit girls to take the pressure off
15 you, so you won't have to have sex with
16 Jeffrey, have you said that?
17 That's the question?
18 A. You don't ask me questions like
19 that. First of all, you are trying to trap
20 me, I will not be trapped. You are asking me
21 if I recruit, I told you no. Girls meaning
22 underage, I already said I don't do that with
23 underage people and as to ask me about a
24 specific conversation I had with language, we
25 talking about almost 17 years ago when this
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2 testify to actual language.
3 Q. So you won't testify to anything
4 I'm asking you 17 years ago about a statement
5 you made. How do you know it's 17 years ago?
6 A. We are talking about a time in
7 2000, right?
8 Q. Have you ever said that to anybody?
9 A. I'm 54 years old so you are asking
10 me in my entire life, what words are you
11 asking me in my entire life?
12 Q. Your entire life is limited by the
13 time you were with Jeffrey, this is the
14 question.
15 A. Let's time limit the question you
16 are asking me.
17 Q. So from, let's say, I think you
18 said you started with him in 1992, is that
19 correct, and finished with him in 2009.
20 So from 1992 to 2009 have you ever
21 said to anybody that you recruit other and we
22 will start with girls to take the pressure
23 off you to have sex with Jeffrey?
24 MR. PAGLIUCA: Objection to the
25 form and foundation.
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2 took place. I cannot testify to an actual
3 conversation or language that I used with
4 anybody at any time.
5 Q. Have you ever said to anybody that
6 you recruit other females over the age of 18
7 to take the pressure off you to having to
8 have sex with Jeffrey?
9 A. I totally resent and find it
10 disgusting that you use the word recruit. I
11 already told you I don't know what you are
12 saying about that and your implication is
13 repulsive.
14 Q. Answer my question.
15 A. I just did.
16 Q. Have you ever said to anybody that
17 you recruit females --
18 A. I don't recruit anybody.
19 Q. That's an answer. So you never
20 said that?
21 A. I'm testifying that I cannot
22 testify to an actual language --
23 Q. It's a yes or no.
24 A. I will not testify to an actual
25 statement made 17 years ago, so I cannot
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2 A. First of all I resent and despise
3 the world recruit. Would you like to define
4 what you mean by recruit and by girls, you
5 mean underage people. I never had to do
6 anything with underage people. So why don't
7 you reask the question in a way that I am
8 able to answer it.
9 Q. I'm asking if you ever said that to
10 anybody. So if you don't understand the word
11 recruit and you never used that word then the
12 answer to that question would be no.
13 A. I have no memory as I sit here
14 today having used that word.
15 Q. Did you ever meet an underage girl
16 in London to introduce her to Jeffrey to
17 provide him with a massage?
18 MR. PAGLIUCA: Objection to the
19 form and foundation.
20 A. Run that past me one more time.
21 Q. Did you ever meet an underage girl
22 in London to introduce her to Jeffrey to
23 perform a massage?
24 MR. PAGLIUCA: Same objection.
25 A. Are you asking me if I met anybody
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2 that was underage in London specifically to
3 provide a massage to Jeffrey, is that your
4 question?
5 Q. Yes.
6 A. No.
7 Q. Do you know who [REDACTED] is?
8 A. I don't recall her right now.
9 Q. Do you know if -- strike that.
10 During the time that you were
11 working for Jeffrey, did you ever observe any
12 foreign females, so in other words, not from
13 the United States, that were brought to
14 Jeffrey's home to perform massages?
15 MR. PAGLIUCA: Objection to the
16 form and foundation.
17 A. Females, what age are we talking?
18 Q. Any age.
19 A. Can you repeat the question?
20 Q. During the time you were working
21 for Jeffrey, did you ever observe any foreign
22 females of any age that were at Jeffrey's
23 home to perform a massage?
24 MR. PAGLIUCA: Objection to the
25 form and foundation.
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2 form and foundation.
3 A. I already testified about not
4 knowing about underage girls.
5 Q. Did you provide any assistance with
6 obtaining visas for foreign girls that were
7 under the age of 18?
8 A. I've never participated in helping
9 people of any age to get visas.
10 Q. Did Jeffrey, was it Jeffrey's
11 preference to start a massage with sex?
12 MR. PAGLIUCA: Objection to the
13 form and foundation.
14 A. I think you should ask that
15 question of Jeffrey.
16 Q. Do you know?
17 A. I don't believe that was his
18 preference. I think -- you have to
19 understand, a massage -- perhaps you are not
20 really familiar with what massage is.
21 Q. I am, I don't need a lecture on
22 massage.
23 A. I think you do.
24 MR. PAGLIUCA: No question pending.
25 She will ask you another question now.
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2 A. Are you asking me if any foreigner,
3 not an American person, gave Jeffrey a
4 massage?
5 Q. Yes.
6 A. Well, as I sit here today, I can't
7 think of anyone who is foreign. Certainly --
8 I just can't think of anybody right this
9 second.
10 Q. How about any foreign girls who
11 were under the age of 18?
12 A. I already testified to not knowing
13 anything about underage girls.
14 Q. Were there foreign girls who were
15 brought to Jeffrey's home by [REDACTED]
16 for the purposes of providing massages?
17 MR. PAGLIUCA: Objection to the
18 form and foundation.
19 A. I am not aware of [REDACTED] bringing
20 girls. I have not no idea what you are
21 talking about.
22 Q. You have never been around foreign
23 girls who are under the age of 18 at
24 Jeffrey's homes?
25 MR. PAGLIUCA: Objection to the
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2 A. Massage is for health benefits.
3 Q. When did you first meet Jeffrey?
4 A. Some point in 1991.
5 Q. And did Jeffrey know your father?
6 A. No.
7 Q. How were you introduced to Jeffrey?
8 A. Some friend introduced us.
9 Q. Can you describe your relationship
10 back in 1991, was it friendship or was it
11 girlfriend relationship or was it a work
12 relationship, what was your relationship in
13 1991?
14 A. It was just friendly.
15 Q. Then I believe you testified you
16 began working for him in 1992, is that
17 correct?
18 A. Yes.
19 Q. In 1992 I know you gave me the
20 description of the work that you were
21 performing for him, how much was he paying
22 you, do you remember?
23 A. I don't recall.
24 Q. Do you know for example in 2001 how
25 much he was paying you?
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2 A. I don't recall.
3 Q. Did it change over the years or did
4 the payment remain the same?
5 A. I believe over the course of time
6 it increased a little bit.
7 Q. Was that the -- was that payment
8 the payment that -- was the payment made with
9 respect to the jobs, the work you were
10 performing for Jeffrey, was that your sole
11 income at that time?
12 MR. PAGLIUCA: I object to the
13 form. I'm also going to instruct you
14 not to answer about sources of -- your
15 personal sources of income outside of
16 Mr. Epstein at all.
17 MS. McCAWLEY: What's the basis for
18 that?
19 MR. PAGLIUCA: It's confidential,
20 it's not part of this lawsuit.
21 MS. McCAWLEY: We have a protective
22 order and it is part of this lawsuit
23 with respect to our damage claims.
24 MR. PAGLIUCA: It's not and, in
25 fact, you are not entitled to ask
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2 worked for it and I had a loan, we did loans.
3 Q. So a loan through Jeffrey?
4 A. I don't recall the exact
5 transaction.
6 Q. Did he purchase for you a
7 helicopter during the time you were working
8 for him?
9 A. It was his helicopter.
10 Q. When did you obtain your pilot
11 license?
12 A. I believe it was '98 or '99.
13 Q. Was that for both airplanes and
14 helicopters or just helicopters?
15 A. Just helicopters.
16 Q. Have you ever flown [REDACTED]
17 [REDACTED] on your helicopter?
18 A. That is another one of Virginia's
19 lies.
20 Q. The question is have you ever done
21 that?
22 A. I have never flown [REDACTED]
23 [REDACTED] at any time ever, in any helicopter,
24 in any place, any time, in any state, in any
25 country, at any time anywhere.
| | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | |Page 103
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2 financial information of a defendant in
3 this kind of case, in a defamation case
4 unless and until there is a finding that
5 you are entitled to punitive damages.
6 That is clear in New York case law, both
7 state and Federal.
8 MS. McCAWLEY: We disagree on that
9 point and we will come back to that.
10 Q. From the source of payment from the
11 source of Jeffrey, from your work, can you
12 give me a range on that, do you know was it
13 over \$100,000?
14 A. I just testified I don't recall.
15 Q. You don't don't know if it was
16 \$500,000?
17 A. It was less than that.
18 Q. Somewhere between 100 and 500,
19 would that be fair to say?
20 A. I believe it was between 100 and
21 \$200,000.
22 Q. Did Jeffrey during the time that
23 you were working for him purchase a town home
24 for you?
25 A. The subject of the townhouse is, I
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2 Q. Have you ever had dinner with
3 [REDACTED] at Jeffrey's home, at any
4 of Jeffrey's homes?
5 A. No, I don't believe so.
6 Q. Have you traveled on Jeffrey's
7 planes with [REDACTED]?
8 A. Yes, I have.
9 Q. Would that have been in 2002?
10 A. It's very hard for me to recollect
11 exact dates but that sounds about right.
12 Q. Was that during the time that
13 Virginia was working for Jeffrey?
14 A. I don't know that Virginia ever did
15 work for Jeffrey. I don't exactly know if
16 she testified to her so-called duties, we
17 know she is a serial liar so I can't testify
18 to what she did or didn't do. So I object to
19 that characterization of her. So repeat the
20 question, please.
21 Q. Can you read the question back?
22 (Record read.)
23 Q. You can answer the question.
24 A. What was the question again?
25 Q. When you were traveling on the
| 1 G Maxwell - Confidential\ 2 plane with [REDACTED], was that during\ 3 the time, it was 2002, that you were on a\ 4 flight with [REDACTED] was that during the time\ 5 Virginia was working for Jeffrey? 6 MR. PAGLIUCA: Object to the form.\ 7 Misstates the witness' answer and if you\ 8 can answer the question, you can answer\ 9 it. 10 A. Well, like I said, I don't recall\ 11 exactly when I flew with him. I don't recall\ 12 when Virginia, we know what Virginia claims\ 13 when she left, so I can't answer the\ 14 question. I have no idea. 15 Q. Do you know [REDACTED]? 16 A. I do. 17 Q. How long have you known him? 18 A. A very long time. 19 Q. Since you were a child? 20 A. I really -- it's so long, it's\ 21 really a long time ago. I just don't recall. 22 Q. Do you remember how you first met\ 23 him? 24 A. No, I do not. 25 Q. Did you introduce him to Jeffrey? 1 G Maxwell - Confidential 2 A. That would be another of Virginia's\ 3 lies and the lies you perpetrate. I never\ 4 introduced [REDACTED] to Jeffrey Epstein\ 5 at any time ever, so just add that the to\ 6 long list of lies. 7 Q. Did Jeffrey know [REDACTED]? 8 A. Clearly he knew him. I think we\ 9 have that answer but how -- yeah. 10 Q. Do you know how Jeffrey met [REDACTED]\ 11 [REDACTED]? 12 A. I do not know Jeffrey met [REDACTED] 13 [REDACTED]. What I do know is that I did not\ 14 introduce them. That is one of the many\ 15 lies. Are we tallying all the lies? 16 Q. Do you know when Jeffrey met [REDACTED]\ 17 [REDACTED]? 18 A. I do not know when Jeffrey met\ 19 [REDACTED]. 20 Q. Did you ever introduce [REDACTED]\ 21 [REDACTED] to any girls under the age of 18 who\ 22 were not friends of yours children? 23 A. I have not introduced [REDACTED]\ 24 to anyone that I am aware of other than\ 25 friends of mine who have kids under that age 1 G Maxwell - Confidential\ 2 that he may have met socially through me. 3 Q. Did you ever introduce [REDACTED]\ 4 [REDACTED] to Virginia in London? 5 A. I understand her story about [REDACTED]\ 6 but again, her tissue of lies is extremely\ 7 hard to pick apart what is true and what\ 8 isn't. Actually I wouldn't recollect her at\ 9 all but for her tissue stories about this\ 10 situation. 11 Q. So did you ever introduce [REDACTED]\ 12 [REDACTED] to Virginia in London? 13 A. I have no recollection. 14 Q. Did Virginia ever stay at your home\ 15 in London, your town home? 16 A. I know she claims she did but if\ 17 you are asking me here today to remember\ 18 specifically, I cannot. 19 Q. Do you remember taking a trip with\ 20 Virginia to travel over to Europe, including\ 21 London? 22 A. So I have seen her reports and I\ 23 have seen the plane reports. I see she says\ 24 she was on that but again, I really have no\ 25 recollection of her. 1 G Maxwell - Confidential 2 Q. Did you know that she was 17 at the\ 3 time of that trip? 4 MR. PAGLIUCA: Objection to the\ 5 form and foundation. 6 A. I have -- 7 Q. Did you know she was 17 at the time\ 8 of that trip? 9 MR. PAGLIUCA: Objection to the\ 10 form and foundation. 11 A. I didn't even know she was on the\ 12 trip. 13 Q. Did you hold her passport for her\ 14 when she was traveling? 15 MR. PAGLIUCA: Objection to the\ 16 form and foundation. 17 A. I have no recollection whatsoever\ 18 of her even being on the trip nor holding her\ 19 passport. 20 (Maxwell Exhibit 4, picture, marked\ 21 for identification.) 22 Q. I'm showing you what we marked as\ 23 Maxwell Exhibit 4. 24 Can you take a look at that picture\ 25 for me? 1 G Maxwell - Confidential\ 2 A. I've looked at it.\ 3 Q. Are you in that picture?\ 4 A. I am.\ 5 Q. [REDACTED]\ 6 [REDACTED]\ 7 A. It is.\ 8 MR. PAGLIUCA: I don't believe this\ 9 has been produced to us in discovery by\ 10 you.\ 11 MS. McCAWLEY: The picture?\ 12 MR. PAGLIUCA: Yes.\ 13 MS. McCAWLEY: It has.\ 14 MS. MENNINGER: Is it the same\ 15 exact photograph.\ 16 MS. McCAWLEY: I believe so. We\ 17 will find one. The picture has been\ 18 produced a number of times.\ 19 MR. PAGLIUCA: I've seen different\ 20 iterations of this, I don't believe I\ 21 have ever seen this.\ 22 MS. McCAWLEY: We had them blow it\ 23 up on a page so she could see it. We\ 24 could use an article.\ 25 While you are looking for that, I 1 G Maxwell - Confidential\ 2 A. No, I don't.\ 3 Q. Where in your town home -- we will\ 4 come back to that.\ 5 Do you have guest bedrooms in your\ 6 town home in London?\ 7 A. I do.\ 8 Q. How many?\ 9 A. Two.\ 10 Q. Did [REDACTED] ever visit\ 11 Jeffrey and you in New York?\ 12 A. Yes.\ 13 Q. Do you remember him visiting you\ 14 and Jeffrey in New York in the spring of\ 15 2001?\ 16 A. Again, I can't testify to any\ 17 specific dates.\ 18 Q. So you don't have a recollection of\ 19 that?\ 20 A. I have a recollection -- you've\ 21 asked me if I have a recollection of being in\ 22 New York but if you are asking for a date, I\ 23 cannot confirm that date.\ 24 Q. Do you remember [REDACTED] being\ 25 present in New York for a party where [REDACTED] 1 G Maxwell - Confidential\ 2 will skip ahead. Hold that until we can\ 3 find one that has the [REDACTED] range on it.\ 4 Q. Do you recall Virginia being at\ 5 your London town home?\ 6 A. I do not.\ 7 Q. Do you recall going to dinner with\ 8 [REDACTED], Jeffrey Epstein and Virginia\ 9 in London, at any time?\ 10 A. I do not.\ 11 Q. Do you recall going to a place\ 12 called [REDACTED], Jeffrey\ 13 Epstein and yourself and [REDACTED]?\ 14 A. I would just like to state for the\ 15 record [REDACTED]\ 16 [REDACTED], at\ 17 [REDACTED], at\ 18 [REDACTED]\ 19 I do not have any recollection of it\ 20 and I doubt it actually happened.\ 21 Q. You don't recall that.\ 22 Do you recall taking Virginia\ 23 shopping when you were in London to buy an\ 24 outfit to meet [REDACTED]? 1 G Maxwell - Confidential\ 2 [REDACTED] was also present?\ 3 A. I don't recollect.\ 4 Q. Do you recall ever giving [REDACTED]\ 5 [REDACTED] a gift of a puppet that was in the\ 6 same -- that looked like him?\ 7 A. I never gave him a gift of a\ 8 puppet.\ 9 Q. Did Jeffrey ever give him a gift of\ 10 a puppet?\ 11 A. No, not that I am aware of.\ 12 Q. Have you ever given him any gifts?\ 13 MR. PAGLIUCA: Objection,\ 14 foundation.\ 15 A. I know [REDACTED] --\ 16 Q. Have you ever given him any gifts\ 17 that you remember when he came to Jeffrey's\ 18 home in New York?\ 19 A. I don't recall giving him any gifts\ 20 in New York.\ 21 (Maxwell Exhibit 5, picture, marked\ 22 for identification.)\ 23 Q. I think I directed you to page\ 24 0034.\ 25 Is that a picture that was taken at |Page 114
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2 your London town home?
3 A. I have no idea what this picture
4 was taken. I know what she purports it to be
5 but I'm not going to say that I do.
6 Q. Do the surroundings look like your
7 London town home?
8 A. They are familiar.
9 Q. Do you know who took this picture?
10 A. I do not.
11 Q. Did Jeffrey Epstein take the
12 picture?
13 A. I just testified I don't know who
14 took the picture.
15 Q. So you don't know if Jeffrey
16 Epstein took the picture?
17 A. When I tell you I don't know who
18 took the picture, it doesn't mean him -- I
19 don't know who took the picture. You can
20 come up with 50 names, I still do not know
21 who took the picture.
22 Q. Did you observe [REDACTED] go
23 into a room with Virginia alone in your town
24 home?
25 A. I cannot recall. As I have said,
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2 Q. Were you present on the island when
3 [REDACTED] visited?
4 A. Yes.
5 Q. How many times?
6 A. I can only remember once.
7 Q. Were there any girls under the age
8 of 18 on the island during that one visit
9 that you remember that were not family or
10 friends of or daughters of your friends?
11 MR. PAGLIUCA: Objection to the
12 form and foundation.
13 A. There were no girls on the island
14 at all. No girls, no women, other than the
15 staff who work at the house. Girls meaning,
16 I assume you are asking underage, but there
17 was nobody female outside of the cooks and
18 the cleaners.
19 Q. Did you, as part of your duties in
20 working for Jeffrey, ever arrange for
21 Virginia to have sex with [REDACTED]?
22 MR. PAGLIUCA: Objection to the
23 form and foundation.
24 A. Just for the record, I have never
25 at any time, at anyplace, in any moment ever
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2 no.
3 Q. Did [REDACTED] ever tell you
4 that he had sex with [REDACTED]?
5 A. He did not.
6 Q. Did Jeffrey Epstein ever tell you
7 that [REDACTED] had sex with Virginia
8 [REDACTED]?
9 A. He did not.
10 Q. Did [REDACTED] ever visit -- let
11 me back up for a moment. We talked about
12 Jeffrey's homes, did Jeffrey have a home in
13 the U.S. Virgin islands called Little St.
14 James?
15 A. Yes.
16 Q. Did [REDACTED] ever visit that
17 island -- are you aware of [REDACTED] ever
18 visiting Jeffrey's island?
19 A. I am aware of that, yes.
20 Q. Do you know how many times he
21 visited?
22 A. I do not.
23 Q. Do you know if he visited when
24 Virginia was on the island?
25 A. I do not.
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2 asked [REDACTED] or whatever she is
3 called now to have sex with anybody.
4 Q. Did you ever provide Virginia
5 [REDACTED] with an outfit, an outfit of a sexual
6 nature to wear for [REDACTED]?
7 MR. PAGLIUCA: Objection to the
8 form and foundation.
9 A. I think we addressed the outfit
10 issue.
11 Q. I am asking you if you ever
12 provided her with an outfit of a sexual
13 nature to wear for [REDACTED]?
14 A. Categorically no. You did get
15 that, I said categorically no
16 Q. Don't worry I'm paying attention.
17 A. You seemed very distracted in that
18 moment.
19 (Maxwell Exhibit 6, flight logs,
20 marked for identification.)
21 A. Do you mind if I take a break for
22 the bathroom.
23 Q. It's 11:08 and we are going to go
24 off the record now.
25 THE VIDEOGRAPHER: It's now 11:09.
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2 one of his planes?
3 A. There was a bed on one of his
4 planes that folded out, yes.
5 Q. Do you recall whether with respect
6 to this being in Santa Fe, do you recall
7 whether you were there for some form of a
8 party?
9 MR. PAGLIUCA: Objection to the
10 form and foundation.
11 A. I don't recall the trip at all and
12 this looks like a total work trip, not a
13 party trip.
14 Q. What would be the difference
15 between a work trip and a party trip?
16 A. Just that I would be on trips for
17 work and I believe that this looks like, █
18 looks like it's one of the -- probably one of
19 the designers and the time would meet with a
20 trip to decorate the house, just the timing
21 of it.
22 Q. So would Virginia be brought on
23 trips that were for the purpose of work and
24 decorating the house?
25 A. Like I said, I never worked with
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2 excerpts from -- we will identify what they
3 are but from the message pads.
4 Did you want to correct anything?
5 A. I want to make an addendum.
6 Would you mind rereading the last
7 question back to me?
8 (Record read.)
9 A. I also just want to say that at
10 this point I cannot recollect flying to
11 parties. Jeffrey went for work so -- was
12 this in Santa Fe, this flight as well.
13 Q. The flight we were looking at, yes
14 but it was to Santa Fe --
15 A. I don't recall going to any parties
16 in Santa Fe at any time but certainly flying
17 to Santa Fe for a party seems highly
18 improbable.
19 Q. So I'm going to direct your
20 attention to the document that I set before
21 you which is █ number █ and it
22 has different █ numbers because it's a
23 smaller version of the larger production.
24 These are the pages I will be asking about.
25 In the time that you were working
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2 her but you would have to ask Jeffrey what he
3 brought her on the trip for.
4 Q. But she would travel with him when
5 there was a work trip like this?
6 A. I can't -- I'm seeing that she is
7 on this flight but I have no idea what she is
8 doing, he invited her, it would not be my
9 job.
10 Q. What about █, would she
11 regularly travel with Jeffrey on flights?
12 A. I have no idea, you would have to
13 look through the flight logs. I have no
14 idea.
15 Q. Your recollection is -- what is
16 your recollection, do you recollect Nadia
17 traveling often on flights with Jeffrey?
18 A. Absolutely not. No, not at all. I
19 don't recollect her actually on the flight at
20 all.
21 Q. I think you can set that aside for
22 the moment.
23 (Maxwell Exhibit 9, message pad
24 pages, marked for identification.)
25 Q. We will mark as Exhibit 9 these
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2 with Jeffrey in Palm Beach, do you recall a
3 process for taking, anybody at the house
4 taking messages when incoming phone calls
5 came in?
6 A. You are supposed to take a message
7 and receive the message and write the message
8 down. Who was the message was for, what time
9 it was taken and who took it and what the
10 message was, obviously.
11 Q. Does what's in front of you look
12 familiar with respect to the message pads
13 that you would have used at the house?
14 A. It is familiar.
15 Q. I'm going to direct your attention
16 to the second page of it?
17 MR. PAGLIUCA: These all have SAO
18 numbers on them or █ ranges and I
19 don't see any of your █ ranges on
20 these. I know you have produced message
21 pads but those have your █ range
22 numbers on them and I'm wondering if
23 these are different documents.
24 MS. McCAWLEY: It's the same, just
25 ours have the █ underneath them.
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2 someone I don't know.
3 Q. Why is your name reflected on this
4 message pad?
5 MR. PAGLIUCA: Objection to the
6 form and foundation.
7 A. I have no idea. You would have to
8 ask whoever took the message.
9 Q. Did you, in the course of your
10 work, regularly take messages for Jeffrey
11 Epstein?
12 A. I already testified I hardly ever
13 did.
14 Q. Would you, in the course of your
15 work, regularly set up appointments for
16 females to come over and give massages for
17 Jeffrey Epstein?
18 MR. PAGLIUCA: Objection to the
19 form and foundation.
20 A. Can you specify, females, you mean
21 adults over the age of 18.
22 Q. Did you regularly set up for
23 Jeffrey adults over the age of 18 to come for
24 massages?
25 A. I didn't regularly do that, no.
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2 messages, I don't know about how I would
3 possibly know if somebody I spoke to, one or
4 two times I took a message is, how old they
5 would be but I have never taken a message
6 where I was aware of anything being under the
7 age of 18 and I probably took it so
8 infrequently, it would be impossible.
9 Q. Can you turn to [REDACTED] it
10 should be the next page.
11 A. Uh-huh.
12 Q. Do you see at the top, it says, for
13 Mr. J. 11/8/04 and then the name is
14 redacted. It says, I have a female for him.
15 Why would a minor be calling
16 Jeffrey to say they have a female for him?
17 Do you know?
18 MR. PAGLIUCA: Objection to the
19 form and foundation.
20 A. First of all, I don't know that's a
21 minor, I don't know who took the message.
22 Q. I will represent to you these are
23 police reports and minor's names have to be
24 redacted for privacy purposes?
25 MR. PAGLIUCA: Objection to the
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2 Q. Would you take messages with
3 respect to females over the age of 18 to come
4 over for a massage?
5 A. I already testified I hardly ever
6 did take messages.
7 Q. But would you?
8 A. I already testified, I hardly
9 ever --
10 Q. I know hardly ever, but did you?
11 A. Over the course of time it is
12 possible I may have taken a couple, I have no
13 recollection. I hardly ever did and I did so
14 irregularly that it would hard for me to
15 pinpoint.
16 Q. Did you ever take a message for a
17 female under the age of 18 to come over for a
18 massage or for any other reason to be with
19 Jeffrey Epstein?
20 MR. PAGLIUCA: Object to the form
21 and foundation.
22 A. I hardly ever took a message. I
23 have absolutely no way of knowing, maybe one
24 of my friends' daughters called to say they
25 were coming to visit me. I have never taken
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2 form and foundation.
3 Q. Do you know why a minor child would
4 be calling Jeffrey and leaving a message to
5 say, quote, I have a female for him?
6 MR. PAGLIUCA: Objection to the
7 form and foundation.
8 A. I can't testify anything about this
9 message, I don't know anything about it.
10 Q. I'm going to direct your attention
11 to the next page [REDACTED]. If you look at
12 the bottom left, you are going to see a
13 message for Jeffrey, from [REDACTED], it
14 says she doesn't have a number and left a
15 message that she called.
16 Do you know who [REDACTED] is?
17 A. I do not.
18 Q. Do you know that [REDACTED] was
19 13 at the time she placed this call to
20 Jeffrey?
21 A. I don't know who [REDACTED] is.
22 Q. Would Jeffrey regularly have 13
23 year olds call and leave messages?
24 MR. PAGLIUCA: Objection to the
25 form and foundation.
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2 please?
3 Q. Is it an obvious lie that you had
4 sex toys in Jeffrey Epstein's Palm Beach
5 house?
6 MR. PAGLIUCA: Objection to the
7 form and foundation.
8 A. Did Virginia say that?
9 Q. I'm asking you a question.
10 Is it an obvious lie that you had
11 sex toys in Jeffrey Epstein's house?
12 A. I don't recall any sex toys.
13 Q. If someone said had you sex toys,
14 would that be an obvious lie?
15 MR. PAGLIUCA: Objection to the
16 form and foundation.
17 A. Like I said -- can you be more
18 specific about the house or whatever, what
19 exactly you are referring to, what's a sex
20 toy?
21 Q. Yes. How would you define a sex
22 toy?
23 A. No. I need you to define a sex
24 toy, I don't have enough knowledge of sex
25 toys.
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2 I took of people would only have been
3 mainstream type magazine type photos and any
4 photos I took could have been very happily
5 and expected to be displayed on your parents'
6 mantel piece or grandparents' mantel piece.
7 Q. Is it a lie that you approached
8 females to bring them to Jeffrey Epstein?
9 MR. PAGLIUCA: Objection to the
10 form and foundation.
11 A. Please ask the question, again.
12 Q. Sure. Is it a lie that you
13 approached females to bring them to Jeffrey
14 Epstein?
15 A. I don't know what you are asking
16 me.
17 Q. I'm asking you, if it's a lie that
18 you approached females to bring them to
19 Jeffrey Epstein?
20 MR. PAGLIUCA: Objection to the
21 form and foundation.
22 A. You are not asking me a good
23 question, sorry.
24 Q. You don't get to choose the
25 questions.
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2 Q. I will define it based on the
3 dictionary's definition, which is an object
4 or device used to sexually stimulate or
5 enhance sexual pleasure.
6 A. What's your question, please?
7 Q. The question is, is it an obvious
8 lie that you had sex toys in Jeffrey
9 Epstein's Palm Beach house?
10 MR. PAGLIUCA: Same objection.
11 Q. You can answer.
12 A. Like I said, I do not have any
13 recollection of sex toys in Jeffrey's house.
14 Q. Is it a lie, is it an obvious lie
15 that you took pictures of nude girls?
16 MR. PAGLIUCA: Object to the form
17 and foundation.
18 A. We already covered this. Girls we
19 are not referring to -- I can only testify to
20 taking pictures of adult people and I already
21 testified they are not nude, per se. That
22 every picture that I ever took and which they
23 were very limited, always by request, the
24 people would be covered or it would be a hand
25 or a foot. There was never any pictures that
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2 A. I would like to answer your
3 questions but you are not asking me a
4 question that I can answer.
5 Q. What about that is causing you
6 pause where you can't answer the question?
7 A. You are trying to trap me and
8 that's not fair, so I already testified that
9 I hire people across the board, so I would
10 hire architects, decorators, pool people,
11 exercise instructors, gardeners, cooks,
12 chefs, cleaning people. So I, in the course
13 of a very long time when I would hire people
14 I hired people to work for Jeffrey. So I'm
15 happy to testify to hiring people for every
16 possible conceivable proper job that you
17 could conceive of within the context of
18 Jeffrey's life and homes.
19 Q. Is it a lie that you approached
20 females to bring them to Jeffrey Epstein for
21 the purpose of performing massages?
22 MR. PAGLIUCA: Objection to the
23 form and foundation.
24 A. Again, I have already testified
25 that part of the job that I had was to hire
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2 agree to that?
3 MR. PAGLIUCA: Objection to the
4 form and foundation.
5 Q. Are they under the age of 18?
6 A. We already established that you can
7 be a masseuse in Florida at age 17. That
8 does not make it inappropriate.
9 A. I'm not saying appropriate or
10 inappropriate. I'm just asking if there were
11 any exercise instructors that were under the
12 age of 18.
13 A. I am not aware if anybody was but I
14 don't want to full out and say you █ she
15 said, we already established you can be a 17
16 year old masseuse and have it not be
17 something that is not appropriate. So when
18 you say that and then you go, well, you come
19 back and say something, now we can establish
20 that Virginia was 17 but you can be a 17 year
21 old legal masseuse, but I am not aware to
22 your point.
23 Q. Who were the other 17 year old
24 masseuses that you were aware of?
25 A. I am not aware of any.
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2 Epstein had a sexual preference for underage
3 minors?
4 MR. PAGLIUCA: Object to the form
5 and foundation.
6 A. I cannot testify to what
7 Jeffrey's --
8 Q. You don't know his preference?
9 A. You handed me a stack of papers
10 from the police reports and that's what I've
11 read but I have no knowledge, direct
12 knowledge, of what you are referencing.
13 Q. So you don't know, you don't know
14 in your own mind that Jeffrey Epstein had a
15 sexual preference for underage minors, is
16 that correct?
17 MR. PAGLIUCA: Objection to the
18 form and foundation.
19 Q. Is that correct?
20 A. Please ask the question again.
21 Q. You don't know in your own mind
22 that Jeffrey Epstein had a sexual preference
23 for underage minors?
24 MR. PAGLIUCA: Objection to the
25 form and foundation. You have to pause,
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2 Q. Were there any 16 year year old
3 masseuse that you are aware of?
4 A. I am not aware.
5 Q. Any 15?
6 A. I just want to be clear. The only
7 person that I am aware of who claims to have
8 been a -- we have to -- we established
9 Virginia now is 17, given she has changed her
10 age so many times. The only person that I am
11 aware of that was a masseuse at the time when
12 I was present in the house was Virginia.
13 Q. Is it an obvious lie that Jeffrey
14 Epstein had a sexual preference for underage
15 minors?
16 MR. PAGLIUCA: Objection to the
17 form and foundation.
18 A. Can you ask the question again?
19 Q. It is it an obvious lie that
20 Jeffrey Epstein had a sexual preference for
21 underage minors?
22 MR. PAGLIUCA: Objection to the
23 form and foundation.
24 A. Can you ask the question again?
25 Q. Is it an obvious lie that Jeffrey
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2 let me object, answer the question.
3 Listen to her question, pause, I object,
4 you answer.
5 Q. So you don't know in your own mind
6 that Jeffrey Epstein had a sexual preference
7 for underage minors?
8 MR. PAGLIUCA: Objection to the
9 form and foundation.
10 Q. You can answer.
11 A. I cannot tell you what Jeffrey's
12 story is. I'm not able to.
13 Q. Did Jeffrey Epstein have a scheme
14 to recruit underage girls to use them for
15 purposes of sexual massages?
16 MR. PAGLIUCA: Objection to the
17 form and foundation.
18 A. Can you ask me again, please?
19 Q. Did Jeffrey Epstein have a scheme
20 to recruit underage girls to recruit them for
21 sexual massages?
22 MR. PAGLIUCA: Objection to the
23 form and foundation.
24 A. Can you ask it a different way?
25 Q. Did Jeffrey Epstein have a scheme
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2 A. Nothing really.
3 Q. Do you remember what she looks
4 like?
5 A. I would just be speculating on how
6 I remember. I couldn't describe her.
7 Q. Do you recall traveling with her?
8 A. I don't.
9 Q. Did you ever go to her home?
10 A. I don't believe I did.
11 Q. Do you know where she lives?
12 A. I don't.
13 Q. Would you have met her through
14 Jeffrey Epstein?
15 MR. PAGLIUCA: Objection to the
16 form and foundation.
17 A. I already testified I don't
18 recollect how I met her and I remember her
19 because her name is very unusual.
20 Q. So what's your -- what recollection
21 do you have of her, do you have a specific
22 recollection of meeting her somewhere, you
23 just don't know when that was or how do you
24 know that name [REDACTED]?
25 MR. PAGLIUCA: Objection to the
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2 massages from her.
3 Q. Did you ever have any sexual
4 interaction with her?
5 MR. PAGLIUCA: Object to the form
6 and foundation and I'm going to instruct
7 you if we're talking about any
8 consensual adult contact, you are not
9 allowed to answer the question.
10 Q. Did you have any sexual contact
11 with her in the presence of Jeffrey Epstein?
12 MR. PAGLIUCA: Same instruction.
13 Q. Did you have any sexual contact
14 with her in the presence of anybody other
15 than Jeffrey Epstein?
16 MR. PAGLIUCA: Same instruction.
17 Q. How many massages did you receive
18 from [REDACTED]?
19 A. I really don't recall but a fair
20 amount.
21 Q. Did the massages involve sex?
22 MR. PAGLIUCA: I'm going to
23 instruct you not to answer.
24 Q. Have you ever engaged in sex with
25 any female?
| | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | |Page 307
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2 form and foundation.
3 A. I don't know why the name is -- I'm
4 sorry -- I can't -- I have no idea. I
5 recognize the name but that's it.
6 Q. Was [REDACTED] a masseuse?
7 MR. PAGLIUCA: Objection to the
8 form and foundation.
9 A. What are you asking me, I'm sorry?
10 Q. When [REDACTED] worked for
11 Jeffrey Epstein, did she perform massages?
12 A. I've testified that when [REDACTED]
13 came originally, she came to answer
14 telephones. I believe at some point she
15 became a masseuse. I don't recollect when
16 and I personally had massages from [REDACTED].
17 Q. What did [REDACTED] do for Jeffrey
18 Epstein, did she perform massages, anything
19 else?
20 MR. PAGLIUCA: Objection to the
21 form and foundation.
22 A. When she came she answered phones
23 and at some point, I believe, I don't have
24 any firm recollection, but I believe she went
25 to school and became a masseuse and I had
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2 MR. PAGLIUCA: I'm going to
3 instruct you not to answer.
4 MS. MCCAWLEY: I want the record to
5 reflect that Ms. Maxwell's attorney is
6 directing her not to answer this series
7 of questions.
8 MR. PAGLIUCA: It definitely does.
9 Q. Were you responsible for
10 introducing [REDACTED] to Jeffrey Epstein?
11 MR. PAGLIUCA: Objection to the
12 form and foundation.
13 A. I already testified that I don't
14 really recall [REDACTED].
15 Q. Were you responsible for
16 introducing Johanna to Jeffrey Epstein?
17 MR. PAGLIUCA: Objection to the
18 form and foundation.
19 A. Again, I don't like the
20 characterization of introduction. [REDACTED]
21 came to answer telephones.
22 Q. When did you -- were you the person
23 who brought or introduced or met [REDACTED] for
24 purposes of bringing her to Jeffrey Epstein's
25 home?
| Page 310 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to the 3 form and foundation. 4 A. That's not how I would characterize 5 that. 6 Q. How would you characterize it? 7 A. I have testified that I'm 8 responsible for finding professional people 9 to work in the homes, age appropriate adult 10 people, so from pool attendants, to 11 gardeners, to chefs, to housekeepers, to 12 butlers, to chauffeurs and one of the 13 functions was to be able to answer the 14 telephones and in the context of finding 15 someone to answer the telephones, I did look 16 to try to find appropriate people to answer 17 the phones. 18 Q. So did you find Johanna for 19 purposes of that role? 20 A. So in the course of looking for 21 somebody to answer phones at the house, 22 Johanna was one of the people who said that 23 she was willing to answer phones. 24 Q. Did you approach her at her school 25 campus? Page 311 1 G Maxwell - Confidential 2 MR. PAGLIUCA: Objection to form 3 and foundation. 4 A. I honestly don't recall how, in 5 that moment, how I met [REDACTED] and how she 6 came to get the job but... 7 Q. Did you typically, in your work for 8 Jeffrey Epstein, would you typically go to 9 school campuses to try to find individuals to 10 work for Jeffrey Epstein? 11 MR. PAGLIUCA: Objection to the 12 form and foundation. 13 A. I never -- what do you mean by 14 school? Let's characterize school. 15 Q. Any kind of school. 16 A. Obviously not. I never went to any 17 school with young people. [REDACTED], I believe 18 came from an adult university, as I would 19 know in England, so university, I went there 20 but I never went, as I best recollect, 21 anywhere else. 22 Q. Did you -- what university was it 23 that you went to? 24 A. I don't recall the university that 25 she went to right now. Page 312 1 G Maxwell - Confidential 2 Q. Would you visit more than one 3 university to try to find individuals to work 4 for Jeffrey Epstein? 5 A. As I recollect, I think that's, in 6 fact, the only university I went to. 7 Q. Did you go there more than once? 8 A. I think I went twice. 9 Q. Who else did you find from that 10 university, was there anybody other than 11 [REDACTED]? 12 A. I don't recollect, I'm sorry. 13 Q. We are going to mark this as 14 Maxwell 13? 15 (Maxwell Exhibit 13, documents, 16 marked for identification.) 17 Q. Can you take a look at the document 18 I put in front of you, please. 19 Are you familiar with this 20 document? 21 A. I'm familiar with this actual 22 document. 23 Q. How was this document created? 24 MR. PAGLIUCA: Objection to the 25 form and foundation. Page 313 1 G Maxwell - Confidential 2 A. I don't know how this document was 3 created. 4 Q. You were involved in the creation 5 of this document? 6 A. I think you can see from the date 7 that it's 2004, 2005, so no. 8 Q. You weren't involved in the 9 creation of this document. 10 Did you -- we talked earlier about 11 Mr. Epstein's house, I'm talking about the 12 Palm Beach house where you said there was a 13 computer on the desk, that employees had 14 access to -- people who worked for Jeffrey 15 Epstein may have had access to? 16 A. I think anybody could have had 17 access to that. 18 Q. Was that computer used, if you know 19 to keep a log of addresses and phone contact 20 information for Jeffrey Epstein? 21 A. Are we talking about when this 22 document was created. 23 Q. In general, was there, on that 24 computer during the time that you were 25 present with Jeffrey Epstein, was there a Page 314 1 G Maxwell - Confidential\ 2 mechanism by which you kept electronic\ 3 information of names and addresses of\ 4 individuals that he knew?\ 5 MR. PAGLIUCA: Objection to the\ 6 form and foundation.\ 7 A. I can't testify to what was on that\ 8 computer or not after I was gone.\ 9 Q. Not when you were gone, when you\ 10 were there. If Jeffrey wanted to call, for\ 11 example, say [REDACTED], would someone be\ 12 able to go to that computer to pull up the\ 13 address information and phone contact\ 14 information for that individual?\ 15 MR. PAGLIUCA: Objection to the\ 16 form and foundation.\ 17 A. I couldn't possibly say.\ 18 Q. Did you ever have to keep track of\ 19 address or phone contact information for\ 20 Jeffrey Epstein?\ 21 A. That was not my job.\ 22 Q. Did you ever do it?\ 23 A. I am not responsible for keeping\ 24 his numbers so that wasn't my job at all.\ 25 Q. But did you ever do it? I know Page 315 1 G Maxwell - Confidential\ 2 it's not your job but did you ever do it, did\ 3 you ever keep phone contact information for\ 4 him?\ 5 A. During the course of the time we\ 6 were together, if he gave me a telephone\ 7 number, I would give it to an assistant to\ 8 put in the computer, I could do that.\ 9 Q. Would he ask you for contact\ 10 information for different individuals, if he\ 11 wanted to contact someone?\ 12 MR. PAGLIUCA: Objection to the\ 13 form and foundation.\ 14 A. In the course of the long period of\ 15 time when I was there, it certainly would be\ 16 possible for him to ask me for a telephone\ 17 number and if I had the -- I wouldn't always\ 18 have it -- I'm sure it happened.\ 19 Q. Was there a hardcopy book in\ 20 addition to the computer, a hardcopy book\ 21 that you could look for numbers that were\ 22 relevant to Jeffrey Epstein's life and\ 23 something on the computer or was it just an\ 24 electronic version?\ 25 MR. PAGLIUCA: Objection to the Page 316 1 G Maxwell - Confidential\ 2 form and foundation.\ 3 Q. Was there a hard copy book as well\ 4 as something on the computer or was there\ 5 only electronic information on the phone\ 6 numbers?\ 7 MR. PAGLIUCA: Objection to the\ 8 form and foundation.\ 9 A. I can only testify to what I know\ 10 obviously, and I believe that this is a copy\ 11 of a stolen document. I would love to know\ 12 how you guys got it.\ 13 Q. I'm asking during the time you\ 14 worked for Jeffrey Epstein, was there a\ 15 hardcopy document of any kind that kept phone\ 16 numbers for Jeffrey Epstein, if he needed to\ 17 contact someone?\ 18 A. The stolen document I have in front\ 19 of me that you have is what you are referring\ 20 to.\ 21 Q. So there was, during your time when\ 22 you were there, there was no other, you\ 23 mentioned there was information on a\ 24 computer. Was there any hardcopy document\ 25 that you could refer to to find someone's Page 317 1 G Maxwell - Confidential\ 2 number?\ 3 A. You have the stolen document in\ 4 front of you.\ 5 Q. You had access to this when you\ 6 worked for Jeffrey Epstein?\ 7 A. This is, I believe, the book that\ 8 was stolen, that was the hardcopy of whatever\ 9 was there.\ 10 Q. So when you were working for\ 11 Jeffrey Epstein, you were able to access this\ 12 book?\ 13 A. This book -- if this is what this\ 14 is, I believe it was, this is the stolen\ 15 document from his house.\ 16 Q. And you were able to access it when\ 17 you worked for him?\ 18 A. It was a document that was printed\ 19 that you could, if you needed to, look for a\ 20 number.\ 21 Q. Do you know how this book was\ 22 created?\ 23 A. No.\ 24 Q. When you referred to it a moment\ 25 ago, to a stolen document, when [REDACTED] 1 G Maxwell - Confidential\ 2 [REDACTED] turned this document over to the\ 3 FBI, are you aware he described it as a\ 4 document that came from your computer?\ 5 MR. PAGLIUCA: Objection to the\ 6 form and foundation.\ 7 A. I have no idea what he said or\ 8 didn't say, so if you want me to reference\ 9 something he said, you need to show it to me.\ 10 Q. Did you keep this document, an\ 11 electronic copy of it, on your personal\ 12 computer?\ 13 A. I don't recollect.\ 14 Q. If you had to update something, for\ 15 example, if there was a new number, a new\ 16 individual that Jeffrey had hired that you\ 17 were going to track, would you input that\ 18 information into this document on your\ 19 computer?\ 20 MR. PAGLIUCA: Objection to the\ 21 form and foundation.\ 22 A. I've already testified that I'm not\ 23 responsible for updating and keeping these\ 24 records.\ 25 Q. Did you have this document on your 1 G Maxwell - Confidential\ 2 computer, your personal computer?\ 3 A. I told you, I don't recollect\ 4 having this document on my computer.\ 5 Q. Do you know what computers this\ 6 document was on, if more than one?\ 7 A. I'm sorry, this is a long time ago\ 8 and I don't recall exactly how this was all\ 9 managed.\ 10 Q. If you didn't create this document,\ 11 do you know who did?\ 12 MR. PAGLIUCA: Objection to the\ 13 form and foundation.\ 14 A. I don't.\ 15 Q. I'm going to direct your attention\ 16 to part of this document. It's towards the\ 17 back, it's going to be page 91 and it has\ 18 [REDACTED] label [REDACTED] 001663. I'm going to\ 19 direct your attention to the section that\ 20 says, Massage Florida.\ 21 Did you input any of the names or\ 22 numbers under that section?\ 23 MR. PAGLIUCA: Objection to form\ 24 and foundation.\ 25 A. So this document is produced in 1 G Maxwell - Confidential\ 2 2004, 2005, so, no.\ 3 Q. But I'm sorry, correct me if I'm\ 4 misunderstanding your testimony, I thought\ 5 you said when you were working with Jeffrey,\ 6 that this document existed and it was\ 7 something you utilized?\ 8 A. I can't possibly tell you what\ 9 numbers were added or not added subsequent to\ 10 my departure.\ 11 Q. So you can't recall if you added\ 12 any of these numbers?\ 13 MR. PAGLIUCA: Objection to the\ 14 form and foundation, mischaracterizes\ 15 the witness' testimony.\ 16 Q. Are there any numbers on here or\ 17 names that you recognize that you would have\ 18 entered into this section?\ 19 A. I already testified that I'm not\ 20 responsible for inputting numbers and names\ 21 into this so I would not be able to tell you.\ 22 Q. Are there any names or numbers\ 23 under this section, Massage Florida, that you\ 24 would have provided to an assistant to input\ 25 into this document? 1 G Maxwell - Confidential\ 2 A. I can't possibly say.\ 3 Q. Do you see under Massage Florida,\ 4 about halfway down the first column, do you\ 5 see a number that says [REDACTED] cell?\ 6 MR. PAGLIUCA: What page?\ 7 Q. It's 91, [REDACTED] number 001663.\ 8 About halfway down, it says in the first\ 9 column, it says [REDACTED] cell.\ 10 Do you see that?\ 11 A. I do.\ 12 Q. Would you have provided after, I\ 13 know you didn't hire her, Jeffrey hired her\ 14 but after you brought her to Jeffrey, would\ 15 you have given her cell phone number to an\ 16 assistant to input into this document?\ 17 MR. PAGLIUCA: Objection to form\ 18 and foundation.\ 19 A. I didn't bring her to Jeffrey, the\ 20 way you characterize and I would have no\ 21 knowledge of how this number ended up in this\ 22 book.\ 23 Q. I believe you, and I will try to\ 24 use your words so we are clear, you met\ 25 [REDACTED], is that correct? 1 G Maxwell - Confidential 2 A. Yes. 3 Q. And then she began working for 4 Jeffrey? 5 A. Yes. 6 Q. Would you have provided whomever 7 was in charge of keeping this updated with cell number so you would be able to contact r if needed? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. I don't know. It could have been a 13 number of different ways, it it could have 14 been Jeffrey who gave it to somebody. 15 Q. You just don't remember doing that? 16 A. I do not. 17 Q. Now, as you look -- I want you to 18 take a look at the Florida massage list, it's 19 three columns there. 20 Do you, as you look at those names 21 on the various columns, do you know the ages 22 of any of the girls in this list? 23 A. I don't know. One, I don't know 24 who all the people are on this list and I 25 certainly don't know the ages. 1 G Maxwell - Confidential 2 Q. Do you know what their 3 qualifications are? 4 A. I don't know who the people are in 5 general so of course I don't know what their 6 qualifications are. 7 Q. Do you know why Jeffrey has so many 8 masseuses listed in Florida in his book here? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. 11 A. Again, this book was created post 12 my departure, so I couldn't explain why all 13 these people were here. 14 Q. When you were there, you said this 15 book existed? 16 A. Yes. 17 Q. So when you were there, were there 18 a number of masseuses listed under the 19 Florida massage? 20 MR. PAGLIUCA: Objection to the 21 form and foundation and 22 mischaracterization of the witness' 23 testimony. 24 Q. I'm asking you a question. 25 When you were there, were there a 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 number of masseuses listed under the Florida massage section? A. When I was there, I would have, of course there would have been some masseuses listed but I could not tell you who or how many and this -- I could not possibly because I wouldn't remember. Q. Do you know why Jeffrey would have had so many names listed under his massage Florida? MR. PAGLIUCA: Objection to form and foundation. A. I can't testify to why Jeffrey has so many. Q. Did he use a different masseuse every day? MR. PAGLIUCA: Objection to the form and foundation. Q. You can answer. A. When I was there he had a massage roughly every day, one masseuse, and mostly he would have them at random times, so it would be difficult if you just only had one person, man, woman, for an adult massage, to 1 G Maxwell - Confidential 2 come and be available for whatever time it 3 was. So he would have more than one person 4 that he could call for a massage because at 5 any given time the one that he called first 6 may not have been available. 7 Q. So would it typically be a 8 different person each day that would give him 9 a massage? 10 MR. PAGLIUCA: Objection to the 11 form and foundation. 12 A. It would be, when I was there, 13 based on availability. 14 Q. Would it surprise you to learn that 15 the Federal Government found that some of the 16 girls on this list under massage Florida were 17 under the age of 18? 18 MR. PAGLIUCA: Objection to the 19 form and foundation. 20 A. I can't testify to what the 21 government found or did not find because I 22 would have no knowledge of it. 23 Q. I'm asking if you would be 24 surprised by that? 25 MR. PAGLIUCA: Form and foundation. |Page 326
1 G Maxwell - Confidential
2 A. I have knowledge of it. I can't
3 speculate.
4 Q. On the second column, towards the
5 bottom, there is the name, it's one up from
6 the bottom, there is the name [REDACTED],
7 do you know [REDACTED]?
8 A. I do.
9 Q. Who is she?
10 A. She was a friend of Jeffrey's.
11 Q. Is she a masseuse?
12 A. She, I don't think she was a
13 masseuse, no.
14 Q. Why would be she listed under
15 Florida massages?
16 A. An input error.
17 Q. Is this list any individual that
18 would have sex with Jeffrey?
19 MR. PAGLIUCA: Objection to the
20 form and foundation.
21 A. I wouldn't have any knowledge of
22 that.
23 Q. Do you know if Jeffrey had sex with
24 [REDACTED]?
25 MR. PAGLIUCA: Object to the form
|Page 328
1 G Maxwell - Confidential
2 around. I can't testify to that.
3 Q. Were you around in 2004, 2005?
4 A. I already testified that I was
5 there when Jeffrey's mother passed away and
6 so you know, I did visit for her passing and
7 I believe I was there for a couple of days in
8 2005.
9 Q. So if an employee of Mr. Epstein in
10 2004 said that you were the employee's direct
11 supervisor, would that be incorrect?
12 MR. PAGLIUCA: Objection to form
13 and foundation.
14 A. What employee, what's the
15 circumstances and what is the story, I don't
16 know what you are asking me.
17 Q. If [REDACTED] said in 2004
18 when he was hired, you were his direct
19 supervisor, would that be true?
20 A. No.
21 Q. Were you in 2004 supervising [REDACTED]
22 [REDACTED]?
23 MR. PAGLIUCA: Objection to form
24 and foundation.
25 A. I never supervised [REDACTED].
| | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | |Page 327
1 G Maxwell - Confidential
2 and foundation.
3 A. First of all, I wouldn't have any
4 knowledge of that.
5 MS. MCCAWLEY: We are going to take
6 a quick break.
7 THE VIDEOGRAPHER: It's now 4:39
8 and we are off the record.
9 (Recess.)
10 THE VIDEOGRAPHER: It's now 4:54
11 and we are as back on the record
12 starting disk number 8.
13 Q. Ms. Maxwell, we were talking
14 earlier about the journal and I believe you
15 said in 2004, 2005, you were no longer
16 working and responsible for that journal, is
17 that correct?
18 MR. PAGLIUCA: Objection to the
19 form and foundation.
20 A. What are we referring to, this
21 document right here?
22 Q. Yes.
23 A. I don't know who is the author of
24 this or I can't tell you what is in here
25 versus what would have been here when I was
|Page 329
1 G Maxwell - Confidential
2 Q. Did [REDACTED] take orders from
3 you?
4 MR. PAGLIUCA: Objection to the
5 form and foundation.
6 A. She worked for Jeffrey.
7 Q. If [REDACTED] said you had
8 knowledge of underage girls coming to
9 Jeffrey's home for the purpose of sex, would
10 you contend that that is truthful?
11 MR. PAGLIUCA: Objection to the
12 form and foundation of the question.
13 A. I have no idea what you are talking
14 about, I'm sorry.
15 Q. If [REDACTED] said that you
16 have knowledge of underage girls coming to
17 Jeffrey's home for the purpose of having
18 massages involving sex, would you say that
19 that statement is truthful?
20 MR. PAGLIUCA: Objection to the
21 form and foundation.
22 A. I can't testify to what [REDACTED]
23 said or didn't say.
24 Q. I'm saying if [REDACTED] said that you
25 had knowledge that there were girls coming
| 1 2 3 4 G Maxwell - Confidential over to the house that were underage for the purposes of sex, would that statement be true? 5 6 MR. PAGLIUCA: Objection to form and foundation. 7 8 A. I can't testify to what said or didn't say or what he t oug t. 9 10 11 Q. Did you have knowledge of underage girls coming to Jeffrey Epstein's house for the purpose of sex? 12 A. No. 13 14 15 16 Q. Earlier I believe you testified, correct me if I'm wrong, that the document that is in front of you, the thicker document was a stolen document. 17 18 Do you know who stole that document? 19 20 A. I have read that stole the document. 21 Q. And where have you read that? 22 23 24 A. I believe it was reported in the press. Q. Earlier we were talking about the 25 computers at Jeffrey Epstein's home. Did you 1 2 3 G Maxwell - Confidential have a computer that was your computer located in Jeffrey Epstein's home? 4 5 MR. PAGLIUCA: Objection to form and foundation. 6 7 8 A. I've testified to the computer already. Even when I was around, there was a computer that o le had access to. 9 10 11 Q. So is telling the truth when he says at e ownloaded that book from your computer? 12 13 MR. PAGLIUCA: Objection to the form and foundation. 14 15 16 A. I couldn't possibly tell you what did or didn't do or said or didn't say. 17 Q. Was it on your computer? 18 19 A. I already testified I have no idea where this document came from. 20 21 22 Q. Did you have a list of names of individuals with contact information for Jeffrey Epstein on your personal computer? 23 24 A. Again, that wasn't my computer. I already said that was a computer that lots of 25 people would have, so I have no recollection 1 G Maxwell - Confidential 2 of this document being on it, so I don't know 3 where this came from. 4 Q. I understand the computer at the 5 house that you're referencing. On a personal 6 computer of yours, did you have that 7 document? 8 A. I don't know where this document 9 came from, so I can't possibly say this 10 document was on any computer that I may have 11 had access to. 12 Q. On a personal computer of your own, 13 did you have lists of the phone numbers and 14 contact information relating to Jeffrey 15 Epstein? 16 A. Like everybody, I have an address 17 book but I can't possibly testify to where 18 this thing came from. 19 Q. Was it your address book or was it 20 addresses that related to Jeffrey Epstein? 21 MR. PAGLIUCA: Objection to the 22 form and foundation. 23 A. I don't know what you're asking me. 24 Q. On your personal computer, the 25 address book you are referencing, was it your 1 G Maxwell - Confidential 2 address book with individuals you knew or was 3 it an address book for your employer. Jeffrey 4 Epstein? 5 A. Jeffrey has his situation and I 6 have no -- this is Jeffrey's, it came from 7 his home, so I can't testify to anything 8 about this in that period of time. 9 Q. So you didn't have on your computer 10 a list of contact information for individuals 11 that was related to Jeffrey Epstein? 12 A. I don't recall exactly what I had 13 back in 2004 and 2005. so I can't say what I 14 had back then that relates to his addresses. 15 I can't recall. 16 Q. So is it possible that someone 17 could have downloaded from your personal 18 computer a list of names and address that 19 were affiliated with Jeffrey Epstein? 20 MR. PAGLIUCA: Objection to the 21 form and foundation. 22 A. This didn't come from any computer 23 of mine. 24 Q. But is it possible that someone 25 could have downloaded a list of names and |Page 334
1 G Maxwell - Confidential
2 addresses affiliated with Jeffrey Epstein
3 from your computer?
4 MR. PAGLIUCA: Objection to the
5 form and foundation.
6 A. I already said, I didn't have a
7 computer there, so I don't know where this
8 came from, I have no idea.
9 Q. I'm going to read to you some
10 testimony from [REDACTED] deposition
11 and it's on page 370 and I want to ask you a
12 question about it, if it's true or false?
13 MR. PAGLIUCA: I'm going to object
14 unless you show the witness the
15 document.
16 MS. McCAWLEY: I will pass it. We
17 are not going to mark it. We will skip
18 it.
19 Q. Did you ever tell [REDACTED]
20 that he better watch out and better keep his
21 mouth shut with respect to what occurred at
22 Mr. Epstein's home?
23 MR. PAGLIUCA: Objection to the
24 form and foundation.
25 A. It doesn't sound like anything I
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1 G Maxwell - Confidential
2 reference to this case with any, anything you
3 just mentioned, I never threatened anyone.
4 Q. Have you ever directed anyone to
5 call any witnesses relevant to this case and
6 threaten them not to testify?
7 MR. PAGLIUCA: Objection to the
8 form and foundation.
9 A. I never done such a thing.
10 Q. Did Jeffrey Epstein or you ever ask
11 any female, regardless of age, to carry
12 Jeffrey's baby for him?
13 MR. PAGLIUCA: Objection to the
14 form and foundation.
15 Q. Or anything along those lines?
16 MR. PAGLIUCA: Objection to the
17 form and foundation.
18 A. Can you repeat the question,
19 please?
20 Q. Did you or Jeffrey Epstein ever ask
21 any female, regardless of age, to carry
22 Jeffrey Epstein's baby for him?
23 MR. PAGLIUCA: Objection to the
24 form and foundation.
25 A. Are you asking --
Page 335
1 G Maxwell - Confidential
2 would say.
3 Q. Did you ever threaten [REDACTED]
4 [REDACTED] in any way if he were to disclose
5 information he learned from his employment
6 with Jeffrey Epstein?
7 MR. PAGLIUCA: Objection to the
8 form and foundation.
9 A. I'm happy to answer. No, I never
10 threatened him in any way.
11 Q. Were you concerned that he was
12 going to disclose that Jeffrey Epstein was
13 trafficking underage girls?
14 MR. PAGLIUCA: Objection to the
15 form and foundation.
16 A. First of all, there are so many
17 things wrong with that question, but I have
18 no knowledge of what you are talking about.
19 Q. Have you ever contacted or
20 instructed anyone to contact any witness in
21 this case for the purposes of threatening
22 them not to testify in this case?
23 MR. PAGLIUCA: Objection to the
24 form and foundation.
25 A. I have never called anybody with
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1 G Maxwell - Confidential
2 Q. To become pregnant, did you or
3 Jeffrey Epstein ever ask any female to become
4 pregnant and carry Jeffrey Epstein's baby for
5 you or for Jeffrey?
6 MR. PAGLIUCA: Objection to form
7 and foundation.
8 A. You need to be very specific. I
9 have no idea what you are talking about.
10 That's completely rubbish.
11 Q. Did you or Jeffrey Epstein ask any
12 female to become pregnant and carry his baby
13 for either him or you?
14 MR. PAGLIUCA: Objection to the
15 form and foundation. Go ahead.
16 A. I can't testify to anything Jeffrey
17 did or didn't do when I am not present, but I
18 have never asked anybody to carry a baby for
19 me.
20 Q. Or anything along those lines?
21 MR. PAGLIUCA: Object to the form
22 and foundation.
23 Q. I want to make sure we are talking
24 about the same thing, not physically carry a
25 baby, I mean become pregnant with a baby?