## EXHIBIT 6 ## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x Plaintiff, -against- GHISLAINE MAXWELL, Defendants. Case No.: 15-cv-07433-RWS \*\*CONFIDENTIAL\*\* x Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 APPEARANCES: BOLES SCHILLER & FLEXNER, LLP Attorneys for Plaintiff East Las Olas Boulevard Fort Lauderdatle, Florida, 33301 BY: SIGRID McCAWLEY, ESQUIRE MEREDITH SCHULTZ, ESQUIRE EMMA ROSEN, PARALEGAL FARMER JAFFE WEISSING EDWARDS FISTOS & LEHRMAN, P.L. Attorneys for Plaintiff 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 BY: BRAD EDWARDS, ESQUIRE PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 383 South University Street Salt Lake City, Utah 84112 HADDON MORGAN FOREMAN Attorneys for Defendant East 10th Avenu Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE LAURA A. MENNINGER, ESQUIRE Also Present: James Christe, videographer for sexual acts. Q. I'm asking if they performed sexual acts? MR. PAGLIUCA: Object to the form and foundation. Q. Did any of the massage therapists who were at the home perform sexual acts for Jeffrey Epstein? A. I don't know what you mean by sexual acts. Q. Did any of the massage therapists who were working at the home perform sexual acts, including touching the breasts, touching the vaginal area, being touched while Jeffrey is masturbating, having intercourse, any of those things? MR. PAGLIUCA: Objection. Form and foundation. To the extent any of this is asking for to your knowledge any consensual sex act that may or may not have involved you, I'm instructing you not to answer the question. Q. I'm not asking about consensual sex G Maxwell - Confidential acts. I'm asking whether any of the massage therapists performed sexual acts for Mr. Epstein, as I have just described? A. I have never seen anybody have sexual intercourse with with Jeffrey, ever. Q. I'm not asking about sexual intercourse. I'm asking about any sexual act, touching of the breast -- did you ever see -- can you read back the question? (Record read.) A. I'm not addressing any questions about consensual adult sex. If you want to talk about what the subject matter, which is defamation and lying, , that you and are participating in perpetrating her lies, I'm happy to address those. I never saw any inappropriate underage activities with Jeffrey ever. Q. I'm not asking about underage. I'm asking about whether any of the masseuses that were at the home perform sexual acts for Jeffrey Epstein? A. I have just answered the question. Q. No, you haven't. A. I have. 3 Q. No, you haven't. A. Yes, I have. Q. You are refusing to answer the question. A. Let's move on. Q. I'm in charge of the deposition. I say when we move on and when we don't. You are here to respond to my questions. If you are refusing to answer the court will bring you back for another deposition to answer these questions. Do you understand that? MR. PAGLIUCA: You don't need to threaten the witness. MS. McCAWLEY: I'm not threatening her. I'm making sure the record is clear. MR. PAGLIUCA: Certainly can you apply to have someone come back and the court may or may not have her come back again. Again, she is not answering questions that relate to adult consent sex acts. Period. And that's the instruction and we can take it up with the court. Q. Ms. Maxwell, are you aware of any sexual acts with masseuses and Jeffrey Epstein that were nonconsensual? A. No. Q. How do you know that? A. All the time that I have been in the house I have never seen, heard, nor witnessed, nor have reported to me that any activities took place, that people were in distress, either reported to me by the staff or anyone else. I base my answer based on that. Q. Are you familiar with aperson by the name of A. I am. Q. Has given a statement to police about her? you performing sexual acts on A. I have not heard that. Q. Has given a statement to police about Jeffrey Epstein performing Q. Did you have sex with her? MR. PAGLIUCA: This is the same instruction about consensual or nonconsensual. Q. Was under the age of 18 when you hired her? A. No. I didn't hire her, as I said, Jeffrey did. Q. Did ever have sex with Jeffrey? MR. PAGLIUCA: Objection to the form and foundation. A. How would I know what somebody else did. Q. You weren't involved in the sex between Jeffrey, and yourself? A. We already -- Q. Were you involved with sex between Jeffrey, and yourself? MR. PAGLIUCA: Everyone is talking over each other. You heard the question. Again, you you know what the instruction is. If there is any consensual issue involved, I instruct you not to answer. A. Moving on. Q. So you are refusing to answer that question? A. I've been instructed by my lawyer. Q. Did you ever have sex with Jeffrey, , and yourself when was underage? A. Absolutely not. MR. PAGLIUCA: We've been going for about an hour. I would like to take a five-minute break, please. MS. McCAWLEY: I'm almost done. MR. PAGLIUCA: You are not going to allow abreak. MS. McCAWLEY: As soon as I get through my line of questioning, which is perfectly appropriate. Q. Did travel with you and Jeffrey to Europe? A. I'm sure she did. Q. What is she doing today? A. I have no idea. Q. Did you train on how to recruit other girls to perform sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. No. And it's absurd and her entire story is one giant tissue of lies and furthermore, she herself has -- if she says that, you have to ask her about what she did. Q. Does Jeffrey like to have his nipples pinched during sexual encounters? MR. PAGLIUCA: Objection to form and foundation. A. I'm not referring to any advice on my counsel. I'm not talking about any adult sexual things when I was with him. Q. When Jeffrey would have amassage, would he request that the masseuse pinch his nipples while he was having a massage? A. I'm not talking about anything with consensual adult situation. Q. What about with underage -- A. I am not aware of anything. Q. You are not aware of Jeffrey Q. In your responsibilities in working for Jeffrey, would you book massages for him on any given day so that he would have a massage scheduled? Would you take a call for example and book amassage for him? MR. PAGLIUCA: Objection to the form and foundation. Q. You can answer. A. Typically, that was not my responsibility. He would either book the massage himself or one of his other assistants would do that. Q. From time to time you had to do that? MR. PAGLIUCA: Objection to the form and foundation. A. Like I said, typically it was somebody else's responsibility. Q. If you were unable to book agirl for a massage on agiven day, would that mean that you were responsible for giving him a sexual massage? MR. PAGLIUCA: Objection to the form and foundation and I instruct you not to answer any questions about any of your consensual adult sexual activity. Q. So you are not going to answer that question? A. You just heard my counsel. Q. Have you ever said to anybody that recruiting other girls to perform sexual massages for Jeffrey Epstein takes the pressure off you? MR. PAGLIUCA: Object to the form and foundation. A. Repeat the question and break it out. Q. Have you ever said to anybody that you recruit girls -- A. Stop right there. I never recruited girls, let's stop there. Now breakdown the question. Q. Have you ever said to anybody -- A. By girls, we are talking about underage people -- you said girls, are you talking about underage -- we are not talking about consensual acts -- this is adefamation suit. the flights? A. I can't recollect having a meal with them, but just so we are clear, the allegations that had ameal on Jeffrey's island is 100 percent false. Q. But he may have had ameal on Jeffrey's plane? A. I'm sure he had ameal on Jeffrey's plane. Q. You do know how many times he flew on Jeffrey's plane? A. I don't. Q. Do you know who is? A. I do. Q. How do you know him? A. He used to work or still works for Q. Did you ever have arelationship with him? A. We are talking about adult consensual relationships, it's off the record. Q. I'm not asking what you did with him, I'm asking if you ever had a relationship with him? MR. PAGLIUCA: If you understand the term relationship, certainly you can answer that. A. Define relationship. Q. Somebody that you would have spent time together, either seeing them in a romantic relationship or -- A. You need to be, what do you mean by romantic. I was friends with Mut you are suggesting something more so I want to be clear what you are actually asking me. Q. You defined it. You said you were friends with him. If that's what you were that's all I need to know. while you were on the trip with do you recall where you stayed at these locations, in other words, would you leave the jet and stay overnight at a hotel, do you have arecollection of this trip? A. I recollect the trip but if you're asking me where we stayed, you can see it's a very fast paced trip. It was very tiring and form and foundation. A. I don't know why the name is -- I'm sorry -- I can't -- I have no idea. I recognize the name but that's it. Q. Was a masseuse? MR. PAGLIUCA: Objection to the form and foundation. A. What are you asking me, I'm sorry? Q. When worked for Jeffrey Epstein, did she perform massages? A. I've testified that when came originally, she came to answer telephones. I believe at some point she became amasseuse. I don't recollect when and I personally had massages from Q. What did ofor Jeffrey Epstein, did she perform massages, anything else? MR. PAGLIUCA: Objection to the form and foundation. A. When she came she answered phones and at some point, I believe, I don't have any firm recollection, but I believe she went to school and became amasseuse and I had massages from her. 3 Q. Did you ever have any sexual interaction with her? MR. PAGLIUCA: Object to the form and foundation and I'm going to instruct you if we're talking about any consensual adult contact, you are not allowed to answer the question. Q. Did you have any sexual contact with her in the presence of Jeffrey Epstein? MR. PAGLIUCA: Same instruction. Q. Did you have any sexual contact with her in the presence of anybody other than Jeffrey Epstein? MR. PAGLIUCA: Same instruction. Q. How many massages did you receive from A. I really don't recall but afair amount. Q. Did the massages involve sex? MR. PAGLIUCA: I'm going to instruct you not to answer. Q. Have you ever engaged in sex with any female? MR. PAGLIUCA: I'm going to instruct you not to answer. MS. McCAWLEY: I want the record to reflect that Ms. Maxwell's attorney is directing her not to answer this series of questions. MR. PAGLIUCA: It definitely does. Q. Were you responsible for introducing to Jeffrey Epstein? MR. PAGLIUCA: Objection to the form and foundation. A. Ialready testified that I don't really recall Q. Were you responsible for introducing to Jeffrey Epstein? MR. PAGLIUCA: Objection to the form and foundation. A. Again, I don't like the characterization of introduction. came to answer telephones. Q. When did you -- were you the person who brought or introduced or met or purposes of bringing her to Jeffrey home? Epstein's