gov.uscourts.nysd.447706.1320.0.pdf 1 pages January 3, 2024 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell , Case No. 15-cv-7433-LAP Dear Judge Preska, Pursuant to the Court’s December 18, 2023, uns ealing order, and follo wing conferral with Defendant, Plaintiff files this set of documents ordered unseal ed. The filing of these documents ordered unsealed will be done on a rolling basi s until completed. This filing also excludes documents pertaining to Does 105 ( see December 28, 2023, Email Correspondence with Chambers), 107, and 110 ( see ECF No. 1319), while the Court’s re view of those documents is ongoing. Respectfully, /s/ Sigrid S. McCawley Sigrid S. McCawley cc: Counsel of Record (via ECF) Case 1:15-cv-07433-LAP Document 1320 Filed 01/03/24 Page 1 of 1 ------------------------------------------------------------- gov.uscourts.nysd.447706.1320.1_1.pdf 2 pages EXHIBIT 4 Case 1:15-cv-07433-LAP Document 1320-1 Filed 01/03/24 Page 1 of 2From: Sent: To: gmaxl@ellmax.com Saturday, January 10, 2015 9:00 AM Philip Barden; Ross Gow I am out of my depth to understanding defamation and other legal hazards and don't want to end up in a law suit aimed at me from anyone if I can help it. Apparently even saying Virginia is a lier has hazard! I have never been in a suit criminal or civil and want it to stay that way. The US lawyers for the Jane Does are filling additional discovery motions and if I speak I open my self to being part of discovery apparently. I am trying to stay out of litigation and not have to employ lawyers for years as I get lost in US legal nightmare. I stand no legal risk currently on these old charges and civil suits against Jeffrey We need to consult with US lawyers on any statement I make and the complaints too Perhaps we make a statement of the legal risk of saying anything for potential defamation or something that prevents a full and frank detailed rebuttal+ the press not being the place for that? Regardless, Philip plse call jeffrey lawyer and see what you can under.stand from him and pehaps craft something in conjunction with him? Either way I think you need to speak to him to understand my risk so you can help me understand it -too may cooks in the kitchen and l can't make good decisions. Plse reach out to him today + I have already suffered such a terrible and painful loss over the last few days that I can't even see what life after press he'll even looks like -statements that don't address all just lead to more questions .. what is my relationship to clinton ? Andrew on and on. Let's rest till monday. I need head space THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INST AGRAM PLEDGE THE DAILY CATCH PRIVILEGED GM_001044 CONFIDENTIAL Case 1:15-cv-07433-LAP Document 1320-1 Filed 01/03/24 Page 2 of 2 ------------------------------------------------------------- gov.uscourts.nysd.447706.1320.2_1.pdf 10 pages Virginia L. Giuffre, Plaintiff, V. Ghislaine Maxwell, Defendant. United States District Court Southern District of New York Case No.: 15-cv-07433-RWS I --------------- PLAINTIFF'S MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL 1 Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition, Defendant refused to answer numerous questions about allegedly .. adult'' sexual activity related to Jeffrey Epstein. Because this activity is highly relevant to this case, Defendant should be ordered to answer questions about it. As the Court is aware, this defamation case involves Ms. Giuffre's assertions that she and other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the guise of being "massage therapists." See Complaint, (DE 1). at 127 (Giuffre '·described Maxwell's role as one of the main women who Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme''). In response to these assertions, Defendant has made the sweeping claim that Ms. Giuffre·s assertions are "entirely false'' and '·entirely untrue." Complaint, DE 1, at 131. 1 Defendant has labelled her entire deposition transcript as Confidential at this time. Counsel for the parties conferred at the deposition regarding answering questions. Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 1 of 10Yet during her deposition, Defendant refused to answer any questions that she construed as having something to do with ''consensual adult sex." Defem,e counsel supported that position that "frankly, [that's] none of your business and I instruct the witness not to answer." See Declaration of Sigrid S. Mccawley ("Mccawley Deel.'') at Exhibit 1, Tr. of Maxwell Depo. (Apr. 22, 2016) at 21. The result was that at a number of points throughout her deposition, Defendant refused to answer questions about subjects integral to this lawsuit, including questions about what the alleged ''massage therapists" were doing at Jeffrey Epstein's house and the sexual nature of those massages. For example, Defendant refused to answer questions about whether she had given Jeffrey Epstein a massage: Q. Have you ever given Jeffrey Epstein a massage? MR. PAGLIUCA: Object to the form, foundation. And I'm going to instruct you not to answer that question. I don't have any problem with you asking questions about what the subject matter of this lawsuit is, which would be, as you've termed it, sexual trafficking of Ms. Roberts. To the extent you are asking for information relating to any consensual adult interaction between my client and Mr. Epstein, I'm go;ng lo instruct her not to answer because it's not part of this litigation and it is her private confidential information, not subject to this deposition. MS. McCAWLEY: You can instruct her not to answer. That is your right. But I will bring her back for another deposition because it is part of the subject matter of this litigation so she should be answering these questions. This is civil litigation, deposition and she should be responsible for answering these questions. MR. PAGLIUCA: I disagree and you anderstand the bounds that I put on it. MS. McCA WLEY: No, I don't. I will continue to ask my questions and you can continue to make your objections. Q. Did you ever participate from the time period of 1992 to 2009, did you ever participate in a massage with Jeffrey Epstein and another female? MR. PAGLIUCA: Objection. Do not am,wer that question. Again, to the extent you are asking for some sort of illegal activity as you've construed in 2 Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 2 of 10connection with this case I don't have any problem with you asking that question. To the extent these questions involve consensual acts between adults, frankly, they're none of your business and I will instruct the 1vztness not to answer. MS. McCA WLEY: This case involves sexual trafficking, sexual abuse, questions about her having interactions with other females is relevant to this case. She needs to answer these questions. MR. PAGLIUCA: I'm instructing her not to answer. MS. McCA WLEY: Then we will be back here again. See Mccawley Deel. at Exhibit 2, Tr. of Maxwell Depo. (Apr. 22, 2016) at 19-22 ( emphasis added). Defendant's participation in massages with Epstein is a central part of this case. Ms. Giuffre has explained that during her first sexual encounter with Jeffrey Epstein, it was Defendant who provided instruction on how to do it and how to turn the massage into a sexual event. Obviously, proof that Defendant had previously massaged Epstein -include massages with sexual component -would provide important corroboration for Ms. Giuffre's testimony at trial. And proof that Defendant was involved in massages will further help prove that statements to the press that Virginia's allegations were ''obvious lies'' was itself an obvious lie. As another example, Defendant refused to answer questions about her knowledge that Johanna Sjoberg was hired to work for Epstein and provided massages. fn the police report, Johanna admitted that Maxwell recruited her to work for Epstein. See Mccawley Deel. at Exhibit 3, Giuffre000076-77 (police report indicating that Johanna was recruited by Maxwell). Yet during Defendant's deposition, she refused to answer questions regarding Johanna Sjoberg. Q. Do you know what tasks Johanna was hired to performance? A. She was tasked to answer telephones. Q. Did you ever ask her to rub Jeffrey's feet? ... A. I believe that J have read that, but I don't have any memory of it. 3 Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 3 of 10Q. Did you ever tell Johanna that she would get extra money if she provided Jeffrey massages? A. I was always happy to give career advice to people and I think that becoming somebody in the healthcare profession. either exercise instructor or nutritionist or professional massage therapist is an excellent job opportunity. Hourly wages are around 7, 8, $9 and as a professional healthcare provider you can earn somewhere between as we have established 100 to $200 and to be able to travel and have ajob that pays that is a wonderful job opportunity. So in the context of advising people for opportunities for work, it is possible that I would have said that she should explore that as an option. Q. Did you tell her she would get extra money if she massaged Jeffrey? A. I'm just saying, r cannot recall the exact conversation. I give career advice and I have done that. Q. Did you ever have Johanna massage you? A. 1 did. Q. How many times? A. I don't recall how many times. Q. Was there sex involved? A.No .... Q. Did you ever have sexual contact with Johanna? MR. PAGLIUCA: Object to the form and foundation. You need to give me an opportunity to get in between the questions. Anything that involves consensual sex on your part, I'm instructing you not to answer. Q. Did you ever have sexual contact with Johanna? A. [MR. PAGLIUCA?] Again, she is an adult -- Q. I'm asking you, did you ever have sexual contact with Johanna? A. I've just been instructed not to answer. Q. On \\.hat basis? A. You have to ask my lawyer. See Mccawley Deel. at Exhibit 4, Tr. of Maxwell Depo. (Apr. 22, 2016) at 60-62 (emphasis added). 4 Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 4 of 10Here again, this information is critical to the case. Among other things, these questions are designed to show a modus operani (''M.O") for Epstein and Maxwell -specifically, how they recruited for a non-sexual massage than converted the massage into sexual activities. One last illustration comes from Defendant's refusal to answer about her know ledge of Epstein's sexual interests during massages: 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. l'm not talking about any adult sexual things when I was with him. Q. When Jeffrey would have a massage, would he request that the masseuse pinch his nipples while he was having a massage? A. l'm not talking about anything with consensual adult situation. See Mccawley Deel. at Exhibit 5, Tr. of Maxwell Depo. (Apr. 22, 2016) at 82. While Epstein himself might also provide answers to these questions. it appears likely that he will assert his Fifth Amendment privilege regarding his sexual activities. Accordingly, Ms.. Giuffre must pursue questioning of Maxwell to obtain information on this subject. Here again, information about Epstein's sexual idiosyncrasies will provide important corroboration to Ms. Giuffre's testimony that she had sexual interactions of an identic:ll nature with Epstein. These refusals are not an isolated instance. Instead, similar refusals to answer questions occurred repeatedly throughout the deposition. See, e.g, Mccawley Deel. at Composite Exhibit 6. 52-55; 64-65; 82: 92-93: 137-38: 307-09. The Court should compel Defendant to answer all these questions. In addition to the specific points made above, the "big picture" here reveals how vital such discovery is. At the core of Ms. Giuffre's allegations is the allegation that Defendant lured her into a sexual situation with the offer of a job making money as a massage therapist; that Epstein always habitually tried 5 Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 5 of 10to turn massages into sex (that was his modus operandi and plan all along); and that Maxwell recruited other females for an ostensibly proper position, such as therapeutic masseuse, with knowledge that the intent was for that person would be pressured to provide sexual gratification to Epstein. As a result, Epstein's use of massages for sexual purposes is a central part of this case. And Defendant's role in those massages -and knowledge of the purposes of those massages -is a critical piece of evidence showing her state of mind when she attacked Ms. Giuffre's assertions as ·'entirely untrue." Ms. Giuffre intends to prove at trial that Defendant knew full well the sexual purpose for which she was recruiting females -including underage females like Ms Giuffre. Ms. Giuffre is entitled to explore Defendant's knowledge of the sexual activities that took place under the guise of "massages.'' Otherwise Defendant will be able to portray to the jury an inaccurate picture of that what was happening at Epstein's house what nothing more than run-of-the-mill massage therapy. See, e.g., Mccawley Deel. at Exhibit 7. Tr. of Maxwell Depo. (Apr. 22, 2016) at 51 ("'Q: Did [the pay for massage therapists] vary on what sexual acts they performed? ... A: No, it varied depending on how much time. some massage therapists charge more and some charge less.''). Defendant's refusal to answer questions about alleged "adult" consensual sex also blocks Ms. Giuffre from seeking legitimate discovery in this case. By refusing to answer questions about her and Epstein's sexual activities with alleged "adults," Defendant is essentially given the ability to refuse to answer any sexual question she does not wish to answer. Defendant simply has to deem the question as involving "consensual adult sex" and no need be given. The result is to leave Ms. Giuffre with no way of exploring the identity of these alleged adults, the ages of these alleged adults, and indeed whether they were adults at all. This allows Defendant to claim 6 Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 6 of 10that she is unaware of any sexual activity im,olving underage females, because (she claims) the only sexual activity she was aware involved adults. The Court should compel Ms. Maxwell to answer all questions about her knowledge relating to sexual activities with Epstein and other females while at Epstein's various homes. See Fed. R. Crim. P. 37(a)(3)(B)(i); see, e.g, Kel(v v. Al Tech, No. 09 CIV. 962 LAK MHD, 2010 WL 1541585, at *20 (S.D.N.Y. Apr. 12, 2010) ("Under the Federal Rules, when a party refuses to answer a question during a deposition, the questioning party may subsequently move to compel disclosure of the testimony that it sought. The court must determine the propriety of the deponent's objection to answering the questions. and can order the deponent to provide improperly withheld answers during a continued deposition" (internal citations omitted)). Of course, the party objecting to discovery must carry the burden of proving the validity of its objections, particularly in light of "the broad and liberal construction afforded the federal discovery rules .... " John Wiley & Sons, Inc. v. Book Dog Books, LLC, 298 F.R.D. 184, 186 (S.D.N.Y. 2014). For purposes of a deposition, the information sought ''need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence.'' Chen-Oster v. Goldman, Sachs & Co., 293 F.R.D. 557, 561 (S.D.N.Y. 2013) (citing Fed.R.Civ.P. 26(6)(1)). Defendant cannot carry her burden of showing that the questions asked are not reasonably calculated to lead to the discovery of admissible evidence. This is a case in which sexual activities lie at the heart of the issues in dispute. As a result, it is hardly surprising to find that discovery pertains to alleged "adult" sexual activities -and questions about such subjects are entirely proper. See, e.g, Condit v Dunne, 225 r.R.D. 100, 113 (S.D.N.Y. 2004) (in defamation case, '·Plaintiff is hereby ordered to answer questions regarding his sexual relationships in so far 7 Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 7 of 10as they are relevant to a defense of substantial truth, mitigation of damages, or impeachment of plaintiff."); Weber v. lvfultimedia Entm't, Inc., No. 97 CIV. 0682 PKL THK, 1997 WL 729039, at *3 (S.D.N.Y. Nov. 24, 1997) ("While discovery is not unlimited and may not unnecessarily intrude into private matters, in the instant case inquiry into private matters is clearly relevant to the subject matter of the suit. Accordingly, plaintiff Misty Weber shall respond to defendants' interrogatories concerning her sexual partners .... ''). Generally speaking, instructions from attorneys to their clients not to answer questions at a deposition should be "limited to [issues regarding] privilege." Morales v. Zonda, inc., 204 F.R.D. 50, 54 (S.D.N.Y. 2001). In this case, defense counsel ranged far beyond the normal parameters of objections and sought to decide for himself what issues were relevant. That was improper and the Court should order a resumption of the Defendant's deposition so that she can answer questions about her knowledge of sexual activity relating to Jeffrey Epstein. CONCLUSION Defendant should be ordered to sit for a follow-up deposition and directed to answer questions regarding her knowledge of alleged "adult" sexual activity. Dated: May 5, 2016 Respectfully Submitted, By: v-J Sigrid cCawley (P. ac Vice) Meredith Schultz ( ro Hae Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 8 LP Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 8 of 10333 Main Street Armonk, NY 10504 Bradley J. Edwards (Pro Hae Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hae Vice) S.J. Quinney College of Law University of Utah 3 83 University St. Salt Lake City, UT 84112 (801) 585-52022 2 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 9 Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 9 of 10CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 5th day of May, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: lmenninger@hmflaw.com jpagliuca@hmflaw.com Case 1:15-cv-07433-LAP Document 1320-2 Filed 01/03/24 Page 10 of 10 ------------------------------------------------------------- gov.uscourts.nysd.447706.1320.3.pdf 6 pages EXHIBIT4 Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 1 of 6UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------X VIRGINIA L. GIUFFRE, Plaintiff, -against - GHISLAINE MAXWELL , Case No.: 15-cv- 07433-RWS Defendants. --------------------X **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena , was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 MAGNA9 LEGAL SERVICES Pagel Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 2 of 61 2 APPEARANCES: 3 BOIES SCHILLER & FLEXNER , LLP 4 Attorneys for Plaintiff 5 6 7 8 BY: 401 East Las Olas Boulevard Fort Lauderdatle, Florida , 33301 SIGRID McCAWLEY, ESQUIRE MEREDITH SCHULTZ, ESQUIRE EMMA ROSEN, PARALEGAL FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN, P.L. 10 11 12 BY: Attorneys for Plaintiff 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 BRAD EDWARDS, ESQUIRE 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREYS. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER , ESQUIRE 20 21 Also Present: 22 James Christe , videographer 23 24 25 MAGNA9 LEGAL SERVICES Page 2 Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 3 of 61 2 A. G Maxwell -Confidential She was tasked to answer 3 telephones. 4 Q. Did you ever ask her to rub 5 Jeffrey1s feet? 6 7 8 MR. PAGLIUCA: Objection to the form and foundation. A. I believe that I have read that, 9 but I don1t have any memory of it. 10 Q. Did you ever tell Johanna 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 MAGNA9 LEGAL SERVICES Page 60 Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 4 of 61 G Maxwell -Confidential 2 would have said that she should explore that 3 as an option. 4 Q. Did you tell her she would get 5 extra money if she massaged Jeffrey? 6 7 A. I'm just saying, I cannot recall the exact conversation. I give career advice 8 and I have done that. Q. Did you ever have Johanna massage 10 you? 11 I did A. Q. How many times? A. I don't recall how many times. 14 Was there sex involved? Q. 15 A. 16 Did you ever instruct Johanna to Q. 17 massage Glenn Dubin? 18 A. I don't believe --I have no 19 recollection of it. 20 Q. Did you ever have sexual contact 21 with Johanna? 22 23 24 25 MR. PAGLIUCA: Object to the form and foundation. You need to give me an opportunity to get in between the questions. MAGNA& LEGAL SERVICES Page 61 Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 5 of 61 2 3 4 5 G Maxwell -Confidential Anything that involves consensual sex on your part, I'm instructing you not to answer. Q. Did you ever have sexual contact 6 with Johanna? 7 8 A. Q. Again, she is an adult -- I'm asking you, did you ever have 9 sexual contact with Johanna? 10 A. 11 answer. 12 13 14 Q. A. Q. I've just been instructed not to On what basis? You have to ask my lawyer . Did you ever have sexual contact 15 with Johanna that was not consensual on 16 Johanna 's part? 17 18 19 MR. PAGLIUCA: You can answer nonconsensual. A. I've never had nonconsensual sex 20 with anybody. 21 22 23 Q. A. Not Annie Farmer? MR. PAGLIUCA: Objection. I just testified I never had 24 nonconsensual sex with anybody ever, at any 25 time, at anyplace, at any time, with anybody. MAGNA& LEGAL SERVICES Page 62 Case 1:15-cv-07433-LAP Document 1320-3 Filed 01/03/24 Page 6 of 6 ------------------------------------------------------------- gov.uscourts.nysd.447706.1320.4.pdf 17 pages EXHIBIT 6 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 1 of 17UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------X VIRGINIA L. GIUFFRE , Plaintiff , -against - GHISLAINE MAXWELL, Case No.: 15-cv-07433-RWS Defendants . --------------------X **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 MAGNA& LEGAL SERVICES Pagel Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 2 of 171 2 APPEARANCES: 3 BOIES SCHILLER & FLEXNER , LLP 4 Attorneys for Plaintiff 5 6 7 8 BY: 401 East Las Olas Boulevard Fort Lauderdatle , Florida, 33301 SIGRID MCCAWLEY, ESQUIRE MEREDITH SCHULTZ , ESQUIRE EMMA ROSEN, PARALEGAL FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN, P.L. 10 11 12 BY: Attorneys for Plaintiff 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 BRAD EDWARDS, ESQUIRE 13 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 15 16 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREYS. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER , ESQUIRE 20 21 Also Present: 22 James Christe , videographer 23 24 25 MAGNA9 LEGAL SERVICES Page 2 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 3 of 171 G Maxwell -Confidential 2 for sexual acts. 3 4 acts? 5 6 7 Q. I'm asking if they performed sexual MR. PAGLIUCA: Object to the form and foundation. Q. Did any of the massage therapists 8 who were at the home perform sexual acts for 9 Jeffrey Epstein? 10 A. I don't know what you mean by 11 sexual acts. 12 Q. Did any of the massage therapists 13 who were working at the home perform sexual 14 acts, including touching the breasts, 15 touching the vaginal area, being touched 16 while Jeffrey is masturbating, having 17 intercourse, any of those things? 18 19 20 21 22 23 24 25 MR. PAGLIUCA: Objection. foundation. Form and 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 MAGNA9 LEGAL SERVICES Page 52 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 4 of 17G Maxwell -Confidential 1 2 acts. I'm asking whether any of the massage 3 therapists performed sexual acts for Mr. 4 Epstein, as I have just described? 5 A. I have never seen anybody have 6 sexual intercourse with with Jeffrey, ever. 7 8 Q. I'm not asking about sexual intercourse. I'm asking about any sexual 9 act, touching of the breast --did you ever 10 see --can you read back the question? 11 (Record read. ) A. I'm not addressing any questions 12 13 about consensual adult sex. If you want to 14 talk about what the subject matter, which is 15 defamation and lying, Virginia Roberts , that 16 you and Virginia Roberts are participating in 17 perpetrating her lies, I'm happy to address 18 those. I never saw any inappropriate 19 underage activities with Jeffrey ever. 20 Q. I'm not asking about underage. I'm 21 asking about whether any of the masseuses 22 that were at the home perform sexual acts for 23 Jeffrey Epstein? 24 25 A. Q. I have just answered the question. No, you haven't. MAGNA& LEGAL SERVICES Page 53 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 5 of 171 2 3 4 5 A. Q. A. Q. G Maxwell -Confidential I have. No, you haven't. Yes, I have. You are refusing to answer the 6 question. 7 8 A. Q. Let's move on. I'm in charge of the deposition. 9 say when we move on and when we don't. 10 You are here to respond to my I 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 16 17 18 19 20 21 22 23 24 25 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 MAGNA& LEGAL SERVICES Page 54 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 6 of 171 2 3 4 5 G Maxwell -Confidential 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 6 sexual acts with masseuses and Jeffrey 7 Epstein that were nonconsensual? 8 9 10 A. Q. A. No. How do you know that? 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 Annie Farmer? 19 20 A. Q. I am. Has Annie Farmer given a statement 21 to police about you performing sexual acts on 22 her? 23 24 A. Q. I have not heard that. Has Annie Farmer given a statement 25 to police about Jeffrey Epstein performing MAGNA& LEGAL SERVICES Page 55 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 7 of 171 2 3 4 5 6 G Maxwell -Confidential Q. Did you have sex with her? MR. PAGLIUCA: This is the same instruction about consensual or nonconsensual. Q. Was Emmy under the age of 18 when 7 you hired her? 8 A. No. I didn't hire her, as I said, 9 Jeffrey did. 10 Q. Did Emmy ever have sex with 11 Jeffrey? 12 MR. PAGLIUCA: Objection to the 13 14 15 did. 16 form and foundation. A. How would I know what somebody else Q. You weren1t involved in the sex 17 between Jeffrey, Emmy and yourself? 18 19 A. Q. We already -- Were you involved with sex between 20 Jeffrey , Emmy and yourself? 21 22 23 24 25 MR. PAGLIUCA: Everyone is talking over each other. You heard the question. Again, you you know what the instruction is. If there is any MAGNA& LEGAL SERVICES Page 64 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 8 of 17l 2 3 4 5 G Maxwell -Confidential consensual issue involved, I instruct you not to answer . A. Moving on. Q. So you are refusing to answer that 6 question? 7 8 A. Q. I've been instructed by my lawyer. Did you ever have sex with Jeffrey , 9 Emmy, Virginia and yourself when Virginia was 10 underage? 11 12 13 14 15 16 17 18 19 20 21 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 a break. MS. MCCAWLEY: As soon as I get through my line of questioning , which is perfectly appropriate. Q. Did Emmy Taylor travel with you and 22 Jeffrey to Europe? 23 24 25 A. Q. A. I'm sure she did. What is she doing today? I have no idea. MAGNA& LEGAL SERVICES Page 65 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 9 of 171 2 Q. G Maxwell -Confidential Did you train Virginia on how to 3 recruit other girls to perform sexual 4 massages? 5 6 7 MR. PAGLIUCA: Objection to the form and foundation. A. No. And it's absurd and her entire 8 story is one giant tissue of lies and 9 furthermore, she herself has if she says 10 that, you have to ask her about what she did. 11 Q. Does Jeffrey like to have his 12 nipples pinched during sexual encounters? 13 14 15 MR. PAGLIUCA: Objection to form and foundation. A. I'm not referring to any advice on 16 my counsel. I'm not talking about any adult 17 sexual things when I was with him. 18 Q. When Jeffrey would have a massage, 19 would he request that the masseuse pinch his 20 nipples while he was having a massage? 21 A. I'm not talking about anything with 22 consensual adult situation. 23 24 25 Q. A. Q. What about with underage I am not aware of anything. You are not aware of Jeffrey MAGNA& LEGAL SERVICES Page 82 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 10 of 171 2 Q. G Maxwell -Confidential In your responsibilities in working 3 for Jeffrey, would you book massages for him 4 on any given day so that he would have a 5 massage scheduled? Would you take a call for 6 example and book a massage for him? 7 8 9 10 MR. PAGLIUCA: Objection to the form and foundation . Q. A. You can answer. Typically, that was not my 11 responsibility. He would either book the 12 massage himself or one of his other 13 assistants would do that. 14 15 that? 16 17 18 Q. From time to time you had to do MR. PAGLIUCA: Objection to the form and foundation . A. Like I said, typically it was 19 somebody else1s responsibility. 20 Q. If you were unable to book a girl 21 for a massage on a given day, would that mean 22 that you were responsible for giving him a 23 sexual massage? 24 25 MR. PAGLIUCA: Objection to the form and foundation and I instruct you MAGNA9 LEGAL SERVICES Page 92 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 11 of 171 2 3 4 G Maxwell -Confidential not to answer any questions about any of your consensual adult sexual activity. Q. So you are not going to answer that 5 question? 6 7 A. Q. You just heard my counsel. Have you ever said to anybody that 8 recruiting other girls to perform sexual 9 massages for Jeffrey Epstein takes the 10 pressure off you? 11 12 13 14 out. 15 MR. PAGLIUCA: Object to the form and foundation. A. Repeat the question and break it Q. Have you ever said to anybody that 16 you recruit girls -- 17 A. Stop right there. I never 18 recruited girls, let's stop there. Now 19 breakdown the question. 20 21 Q. A. Have you ever said to anybody -­ By girls, we are talking about 22 underage people --you said girls, are you 23 talking about underage --we are not talking 24 about consensual acts --this is a defamation 25 suit. MAGNA& LEGAL SERVICES Page 93 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 12 of 171 G Maxwell -Confidential 2 the flights? 3 A. I can't recollect having a meal 4 with them, but just so we are clear, the 5 allegations that Clinton had a meal on 6 Jeffrey 's island is 100 percent false. 7 Q. But he may have had a meal on 8 Jeffrey 's plane? 9 A. I'm sure he had a meal on Jeffrey 's 10 plane. 11 Q. You do know how many times he flew 12 on Jeffrey's plane? 13 14 15 16 17 A. Q. A. Q. A. I don't. Do you know I do. How do you He used to 18 Bill Clinton. who Doug Band is? know him? work or still works for 19 Q. Did you ever have a relationship 20 with him? 21 A. We are talking about adult 22 consensual relationships , it's off the 23 record . 24 Q. I'm not asking what you did with 25 him, I'm asking if you ever had a MAGNA& LEGAL SERVICES Page 137 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 13 of 171 G Maxwell -Confidential 2 relationship with him? 3 4 5 6 7 MR. PAGLIUCA: If you understand the term relationship , certainly you can answer that. A. Q. Define relationship . Somebody that you would have spent 8 time together, either seeing them in a 9 romantic relationship or -- 10 A. You need to be, what do you mean by 11 romantic . I was friends with Doug but you 12 are suggesting something more so I want to be 13 clear what you are actually asking me. 14 15 Q. You defined it. You said you were friends with him. If that's what you were 16 that's all I need to know. 17 While you were on the trip with 18 President Clinton, do you recall where you 19 stayed at these locations, in other words, 20 would you leave the jet and stay overnight at 21 a hotel, do you have a recollection of this 22 trip? 23 A. I recollect the trip but if you're 24 asking me where we stayed , you can see it's a 25 very fast paced trip. It was very tiring and MAGNA& LEGAL SERVICES Page 138 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 14 of 171 2 3 4 5 6 7 8 9 10 G Maxwell -Confidential form and foundation. A. sorry -- recognize Q. form A. Q. I I don't know why the name is --I'm can't --I have no idea. I the name but that's it. Was Johanna Sjoberg a masseuse? MR. PAGLIUCA: Objection to the and foundation . What are you asking me, I'm sorry? When Johanna Sjoberg worked for 11 Jeffrey Epstein, did she perform massages? 12 A. I've testified that when Johanna 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 Johanna . 17 Q. What did Johanna do for Jeffrey 18 Epstein , did she perform massages, anything 19 else? 20 21 22 MR. PAGLIUCA: Objection to the form and foundation. 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 MAGNA9 LEGAL SERVICES Page 307 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 15 of 171 G Maxwell -Confidential 2 massages from her. 3 Q. Did you ever have any sexual 4 interaction with her? 5 6 7 8 9 10 MR. PAGLIUCA: Object to the form and foundation and I1m going to instruct you if we1re talking about any consensual adult contact, you are not allowed to answer the question. Q. Did you have any sexual contact 11 with her in the presence of Jeffrey Epstein? 12 13 Q. MR. PAGLIUCA: Same instruction . Did you have any sexual contact 14 with her in the presence of anybody other 15 than Jeffrey Epstein? 16 17 Q. MR. PAGLIUCA: Same instruction. How many massages did you receive 18 from Johanna? 19 A. 20 amount. Q. I really don1t recall but a fair Did the massages involve sex? MR. PAGLIUCA: I1m going to 21 22 23 24 instruct you not to answer. Q. Have you ever engaged in sex with 25 any female? MAGNA9 LEGAL SERVICES Page 308 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 16 of 171 2 3 4 5 6 7 8 9 G Maxwell -Confidential 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 10 introducing Anuska to Jeffrey Epstein? 11 12 13 MR. PAGLIUCA: Objection to the form and foundation. A. I already testified that I don't 14 really recall Anuska. 15 Q. Were you responsible for 16 introducing Johanna to Jeffrey Epstein? 17 18 19 MR. PAGLIUCA: Objection to the form and foundation. A. Again, I don't like the 20 characterization of introduction. Johanna 21 came to answer telephones. 22 Q. When did you --were you the person 23 who brought or introduced or met Johanna for 24 purposes of bringing her to Jeffrey Epstein 's 25 home? MAGNA9 LEGAL SERVICES Page 309 Case 1:15-cv-07433-LAP Document 1320-4 Filed 01/03/24 Page 17 of 17 ------------------------------------------------------------- gov.uscourts.nysd.447706.1320.5.pdf 56 pages COMPOSITE EXHIBIT A Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 1 of 56Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK- - - - - - - - - - - - - - - - - - - - xVIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendants.- - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 2 of 56Page 2 1 2 APPEARANCES:3 BOIES SCHILLER & FLEXNER, LLP 4 Attorneys for Plaintiff 401 East Las Olas Boulevard 5 Fort Lauderdatle, Florida, 33301 BY: SIGRID McCAWLEY, ESQUIRE 6 MEREDITH SCHULTZ, ESQUIRE EMMA ROSEN, PARALEGAL 78 FARMER JAFFE WEISSING EDWARDS FISTOS & 9 LEHRMAN, P.L. Attorneys for Plaintiff 10 425 N. Andrews Avenue Fort Lauderdale, Florida 33301 11 BY: BRAD EDWARDS, ESQUIRE1213 PAUL G. CASSELL, ESQUIRE Attorneys for Plaintiff 14 383 South University Street Salt Lake City, Utah 84112 1516 HADDON MORGAN FOREMAN 17 Attorneys for Defendant 150 East 10th Avenu 18 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 19 LAURA A. MENNINGER, ESQUIRE2021 Also Present:22 James Christe, videographer232425 MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 3 of 56 Questions About People Under the Age of 18 at Epstein’s Home Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 4 of 56Page 13 1 G Maxwell - Confidential 2 Q. You can answer.3 A. I have not any idea exactly of the4 youngest adult employee that I hired for5 Jeffrey.6 Q. When you say adult employee, did7 you ever hire someone that was under the age8 of 18?9 A. Never. 10 Q. Did you ever bring someone who was11 under -- invite someone under the age of 1812 to Jeffrey's home, any of his homes?13 MR. PAGLIUCA: Object to the form14 foundation.15 A. Can you repeat the question?16 Q. Did you ever invite anybody who was17 under the age of 18 to Jeffrey's homes?18 MR. PAGLIUCA: Same objections.19 A. I have a number of friends that20 have children and friends of mine that have21 kids and in the invitation of my friends and22 their kids, I'm sure I may have invited some23 of my friend's kids to come.24 Q. Anybody that is not a friend of25 yours. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 5 of 56 Questions About Meeting the Plaintiff and Massages with Plaintiff Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 6 of 56Page 16 1 G Maxwell - Confidential 2 A. Ms. Roberts held herself out --3 Q. I'm not asking how she held herself4 out. I'm asking how she arrived at the home.5 Did you meet her and invite her to come to6 the home or how did she arrive there?7 MR. PAGLIUCA: Object to the form8 and foundation.9 A. Ms. Roberts held her to be a 10 masseuse and her mother drove her to the11 house.12 Q. When did you first meet Virginia13 Roberts?14 A. I don't have a recollection of the15 first meeting.16 Q. Do you recall meeting her at17 Mar-a-Lago?18 A. Like I said, I don't have a19 recollection of meeting Ms. Roberts.20 Q. So you recall Ms. Roberts being21 brought to the home by her mother, is that22 your testimony?23 A. That is my testimony.24 Q. And that is the first time you met25 her? MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 7 of 56Page 17 1 G Maxwell - Confidential 2 A. Like I said, I don't recall meeting3 her the first time. I do remember her mother4 bringing her to the house.5 Q. Are you a member at Mar-a-Lago?6 A. No.7 Q. Have you visited Mar-a-Lago?8 A. Yes.9 Q. Did you visit Mar-a-Lago in the 10 year 2000?11 A. I'm pretty sure I did.12 Q. When Ms. Roberts arrived at the13 home with her mother, what happened?14 A. I spoke to her mother outside of15 the house and she -- what I don't recall is16 exactly what happened because I was talking17 to her mother the entire she was in the18 house.19 Q. Did you introduce Ms. Roberts to20 Jeffrey Epstein?21 A. I don't recall how she actually met22 Mr. Epstein. As I said, I spoke to her23 mother the entire time outside the house.24 Q. Did you walk Ms. Roberts up to the25 upstairs location at the Palm Beach house to MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 8 of 56Page 19 1 G Maxwell - Confidential 2 absolutely everything that took place in that3 first meeting. She has lied repeatedly,4 often and is just an awful fantasist. So5 very difficult for anything to take place6 that she repeated because I was with her7 mother the entire time.8 Q. So did you have -- did you give a9 massage with Virginia Roberts and Mr. Epstein 10 during the first time Virginia Roberts was at11 the West Palm Beach house?12 MR. PAGLIUCA: Object to the form13 and foundation.14 Q. Yes or no?15 A. No.16 Q. Have you ever given a massage with17 Virginia Roberts in the room and Jeffrey18 Epstein?19 MR. PAGLIUCA: Object to the form20 and foundation.21 A. No.22 Q. Have you ever given Jeffrey Epstein23 a massage?24 MR. PAGLIUCA: Object to the form,25 foundation. And I'm going to instruct MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 9 of 56 Questions About Massages with Minors Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 10 of 56Page 22 1 G Maxwell - Confidential 2 questions.3 MR. PAGLIUCA: I'm instructing her4 not to answer.5 MS. McCAWLEY: Then we will be back6 here again.7 Q. Have you ever given a massage to8 Mr. Epstein with a female that was under the9 age of 18? 10 A. Can you repeat the question?11 Q. Yes. Have you ever given a massage12 to Mr. Epstein with a female that was under13 the age of 18?14 A. No.15 Q. Have you ever observed Mr. Epstein16 having a massage given by an individual, a17 female, who was under the age of 18?18 A. No.19 Q. Have you ever observed females20 under the age of 18 in the presence of21 Jeffrey Epstein at his home?22 MR. PAGLIUCA: Object to the form23 and foundation.24 A. Again, I have friends that have25 children -- MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 11 of 56 Questions About Hiring Massage Therapists Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 12 of 56Page 31 1 G Maxwell - Confidential 2 -- just another one of Virginia's many3 fictitious lies and stories to make this a4 salacious event to get interest and press.5 It's absolute rubbish.6 Q. Were you in charge of hiring7 individuals to provide massages for Jeffrey8 Epstein?9 A. My job included hiring many people. 10 There were six homes. As I sit here, I hired11 assistants, I hired architects, I hired12 decorators, I hired cooks, I hired cleaners,13 I hired gardeners, I hired pool people, I14 hired pilots, I hired all sorts of people.15 In the course and a very small part16 of my job was from from time to time to find17 adult professional massage therapists for18 Jeffrey.19 Q. When you say adult professional20 massage therapists, where did you find these21 massage therapists?22 A. From time to time I would visit23 professional spas, I would receive a massage24 and if the massage was good I would ask that25 man or woman if they did home visits. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 13 of 56Questions About and Nadia Marcinkova Jane Doe 2Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 14 of 56Page 37 1 G Maxwell - Confidential 2 here today I do not.3 Q. Ms. Maxwell, when did you first4 meet 5 MR. PAGLIUCA: Object to the form6 and foundation.7 A. I have no idea when I met her.8 Q. Do you know how old she was when9 you met her? 10 A. I have no idea how old she was when 11 I met her.12 Q. Is it possible she was 13 years old13 when you first met her?14 MR. PAGLIUCA: Object to the form15 and foundation.16 A. 18 may have been in the house when Jeffrey was 19 in the house. I have no idea how old she20 was.21 Q. I understand she was with 2223 I'm asking if was 1324 years old when you first met her?25 A. I have no idea. ■ - -- MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 15 of 56Page 38 1 G Maxwell - Confidential 2 Q. Was she under 18 when you first met3 her?4 A. I have no idea how old she was when5 I first met her.6 Q. Did she look like a child when you7 first met her?8 A. I don't remember what she looked9 like at the time she was in the house. 10 Q. How many years have you known her? 11 A. I can only recall the last time I12 saw her.13 Q. When was the first time you met14 her?15 A. Again, I just told you, I don't16 recall the first time I met her.17 Q. Did travel with you18 on Jeffrey's planes?19 A. I wouldn't remember if was on20 the plane or not.21 Q. Did you ever have sex with 2223 A. No.24 Q. Did you ever observe Jeffrey having25 sex with -- MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 16 of 56Page 39 1 G Maxwell - Confidential 2 A. No.3 Q. Were you aware that Jeffrey was4 having sexual contact with when5 she was 13 years old?6 MR. PAGLIUCA: Object to the form7 and foundation.8 A. I would be very shocked and9 surprised if that were true. 10 Q. Were you in the house when was in the house in a private area 12 with Jeffrey Epstein?13 MR. PAGLIUCA: Object to the form14 and foundation.15 A. Can you repeat the question.16 Q. Were you ever in the Palm Beach17 house when Jeffrey Epstein was in the house18 with ?19 MR. PAGLIUCA: Object to the form20 and foundation.21 A. I've already testified that I have22 met her and that she was there 23 I don't understand what your24 question is asking.25 Q. So you have never seen -■- -- MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 17 of 56Page 40 1 G Maxwell - Confidential 23 MR. PAGLIUCA: Object to the form4 and foundation.5 Q. Is that your testimony?6 A. I already said I don't recall all7 the times I've seen her and I have no memory8 of that.9 Q. Have you ever seen in 10 the house with Jeffrey Epstein 1112 MR. PAGLIUCA: Object to the form13 and foundation.14 A. I just told you I don't recall15 seeing 16 Q. Were you ever involved in an orgy17 with 18 A. No, absolutely not.19 Q. Can you tell me, do you know an20 individual by the name of Nadia Marcinkova?21 A. I do.22 Q. How did you meet Nadia Marcinkova?23 A. At some point she was a friend of24 Jeffrey's and I recall meeting her at some25 point. - - MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 18 of 56Page 46 1 G Maxwell - Confidential 2 Q. Did Jeffrey arrange for a visa for 3 Nadia Marcinkova? 4 A. I don't know what Jeffrey did. I 5cannot testify what Jeffrey did. 6 Q. Was Nadia involved in sex with 7Jeffrey and other girls? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 Q. Girls under the age of 18? 11 MR. PAGLIUCA: Same objection.12 A. I have no idea.13 Q. Was Nadia involved with sex with14Jeffrey and girls over the age of 18? 15 MR. PAGLIUCA: Same objection. 16 A. I have no idea.17 Q. Did Nadia recruit other girls for18 sex with Jeffrey? 19 MR. PAGLIUCA: Object to the form 20 and foundation. 21 A. I have no idea. 22 Q. Do you still talk to Nadia? 23 A. No.24 Q. Is she a pilot?25 A. I have no idea. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 19 of 56 Questions About Mr. Epstein and Sex Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 20 of 56Page 53 1 G Maxwell - Confidential 2 acts. I'm asking whether any of the massage3 therapists performed sexual acts for Mr.4 Epstein, as I have just described?5 A. I have never seen anybody have6 sexual intercourse with with Jeffrey, ever.7 Q. I'm not asking about sexual8 intercourse. I'm asking about any sexual9 act, touching of the breast -- did you ever 10 see -- can you read back the question?11 (Record read.)12 A. I'm not addressing any questions13 about consensual adult sex. If you want to14 talk about what the subject matter, which is15 defamation and lying, Virginia Roberts, that16 you and Virginia Roberts are participating in17 perpetrating her lies, I'm happy to address18 those. I never saw any inappropriate19 underage activities with Jeffrey ever.20 Q. I'm not asking about underage. I'm21 asking about whether any of the masseuses22 that were at the home perform sexual acts for23 Jeffrey Epstein?24 A. I have just answered the question.25 Q. No, you haven't. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 21 of 56 Questions About Sarah Kellen, Glen Dubin, Plaintiff, Johanna Sjoberg, Annie Farmer and Sex Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 22 of 56Page 54 1 G Maxwell - Confidential 2 A. I have.3 Q. No, you haven't.4 A. Yes, I have.5 Q. You are refusing to answer the6 question.7 A. Let's move on.8 Q. I'm in charge of the deposition. I9 say when we move on and when we don't. 10 You are here to respond to my11 questions. If you are refusing to answer the12 court will bring you back for another13 deposition to answer these questions.14 Do you understand that?15 MR. PAGLIUCA: You don't need to16 threaten the witness.17 MS. McCAWLEY: I'm not threatening18 her. I'm making sure the record is19 clear.20 MR. PAGLIUCA: Certainly can you21 apply to have someone come back and the22 court may or may not have her come back23 again.24 Again, she is not answering25 questions that relate to adult consent MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 23 of 56Page 55 1 G Maxwell - Confidential 2 sex acts. Period. And that's the3 instruction and we can take it up with4 the court.5 Q. Ms. Maxwell, are you aware of any6 sexual acts with masseuses and Jeffrey7 Epstein that were nonconsensual?8 A. No.9 Q. How do you know that? 10 A. All the time that I have been in11 the house I have never seen, heard, nor12 witnessed, nor have reported to me that any13 activities took place, that people were in14 distress, either reported to me by the staff15 or anyone else. I base my answer based on16 that.17 Q. Are you familiar with a person by18 the name of Annie Farmer?19 A. I am.20 Q. Has Annie Farmer given a statement21 to police about you performing sexual acts on22 her?23 A. I have not heard that.24 Q. Has Annie Farmer given a statement25 to police about Jeffrey Epstein performing MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 24 of 56Page 57 1 G Maxwell - Confidential 2 asked and answered already.3 Q. You can answer the question.4 A. I have no idea what Sarah Kellen5 did.6 Q. You never observed Sarah Kellen7 with girls under the age of 18 at Jeffrey's8 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 Dubin?13 A. I do.14 Q. What is your relationship with15 Glenn Dubin?16 MR. PAGLIUCA: Object to the form.17 A. What do you mean what is my18 relationship.19 Q. Are you friendly with him, how do20 you know him?21 A. He is the husband of Eva Dubin.22 Q. Is Eva Dubin one of your friends?23 A. Yes.24 Q. Did you ever send Virginia to25 Glenn's condo at the Breakers to give him a MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 25 of 56Page 58 1 G Maxwell - Confidential 2 massage?3 MR. PAGLIUCA: Objection to the4 form and foundation.5 A. No.6 Q. Did you ever instruct Virginia7 Roberts to have sex with Glenn?8 MR. PAGLIUCA: Objection to the9 form and foundation. 10 A. I have never instructed Virginia to11 have sex with anybody ever.12 Q. How old was Eva Anderson when she13 met Jeffrey?14 MR. PAGLIUCA: Objection to the15 form and foundation.16 A. I have no idea.17 Q. What's she under the age of 18?18 MR. PAGLIUCA: Objection to the19 form and foundation.20 A. I just testified I have idea how21 old she was.22 Q. You testified she was your friend.23 You don't know how old she was when she met24 Jeffrey?25 A. That happened sometime in the '70s, MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 26 of 56Page 59 1 G Maxwell - Confidential 2 how would I know, or '80s. I have no idea.3 Can you testify to what your friends did 304 years ago?5 Q. You don't ask the questions here,6 Ms. Maxwell.7 What about Johanna Sjoberg, when8 did you first meet Johanna?9 A. I don't recall the exact date. 10 Q. Did you hire Johanna?11 A. I don't hire people, she came to12 work at the house to answer phones.13 Q. Where did you meet her?14 A. I just testified, I don't recall15 exactly when I met her.16 Q. Was one of your job17 responsibilities to interview people that18 would be then hired by Jeffrey?19 A. That was one of my20 responsibilities.21 Q. Do you recall interviewing Johanna?22 A. I don't recall the exact interview,23 no.24 Q. Do you know what tasks Johanna was25 hired to performance? MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 27 of 56Page 60 1 G Maxwell - Confidential 2 A. She was tasked to answer3 telephones.4 Q. Did you ever ask her to rub5 Jeffrey's feet?6 MR. PAGLIUCA: Objection to the7 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 Johanna that she11 would get extra money if she provided Jeffrey12 massages?13 A. I was always happy to give career14 advice to people and I think that becoming15 somebody in the healthcare profession, either16 exercise instructor or nutritionist or17 professional massage therapist is an18 excellent job opportunity. Hourly wages are19 around 7, 8, $9 and as a professional20 healthcare provider you can earn somewhere21 between as we have established 100 to $20022 and to be able to travel and have a job that23 pays that is a wonderful job opportunity. So24 in the context of advising people for25 opportunities for work, it is possible that I MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 28 of 56Page 61 1 G Maxwell - Confidential 2 would have said that she should explore that3 as an option.4 Q. Did you tell her she would get5 extra money if she massaged Jeffrey?6 A. I'm just saying, I cannot recall7 the exact conversation. I give career advice8 and I have done that.9 Q. Did you ever have Johanna 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 Johanna to17 massage Glenn Dubin?18 A. I don't believe -- I have no19 recollection of it.20 Q. Did you ever have sexual contact21 with Johanna?22 MR. PAGLIUCA: Object to the form23 and foundation. You need to give me an24 opportunity to get in between the25 questions. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 29 of 56Page 62 1 G Maxwell - Confidential 2 Anything that involves consensual3 sex on your part, I'm instructing you4 not to answer.5 Q. Did you ever have sexual contact6 with Johanna?7 A. Again, she is an adult --8 Q. I'm asking you, did you ever have9 sexual contact with Johanna? 10 A. I've just been instructed not to11 answer.12 Q. On what basis?13 A. You have to ask my lawyer.14 Q. Did you ever have sexual contact15 with Johanna that was not consensual on16 Johanna's part?17 MR. PAGLIUCA: You can answer18 nonconsensual.19 A. I've never had nonconsensual sex20 with anybody.21 Q. Not Annie Farmer?22 MR. PAGLIUCA: Objection.23 A. I just testified I never had24 nonconsensual sex with anybody ever, at any25 time, at anyplace, at any time, with anybody. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 30 of 56Page 63 1 G Maxwell - Confidential 2 Q. So if Johanna were to testify that3 she did not consent to a sexual act that you4 participated in --5 A. I just told you I have never ever6 under any circumstances with anybody, at any7 time, in anyplace, in any form had8 nonconsensual relations with anybody.9 Q. Did you introduce Johanna to Prince 10 Andrew?11 MR. PAGLIUCA: Objection to the12 form and foundation.13 A. I've, again, read that Johanna14 claimed that she met or that she said she met15 Prince Andrew. I don't know if I was the one16 who made the introduction or not.17 Q. Do you know a female by the name of18 Emmy Taylor?19 A. I do.20 Q. How do you know her?21 A. Emmy was my assistant.22 Q. So she worked for you?23 A. Yes.24 Q. Did you hire her?25 A. Again, Jeffrey hired people. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 31 of 56 Questions About Emmy, Virginia, and Ms. Maxwell Regarding Sex Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 32 of 56Page 65 1 G Maxwell - Confidential 2 consensual issue involved, I instruct3 you not to answer.4 A. Moving on.5 Q. So you are refusing to answer that6 question?7 A. I've been instructed by my lawyer.8 Q. Did you ever have sex with Jeffrey,9 Emmy, Virginia and yourself when Virginia was 10 underage?11 A. Absolutely not.12 MR. PAGLIUCA: We've been going for13 about an hour. I would like to take a14 five-minute break, please.15 MS. McCAWLEY: I'm almost done.16 MR. PAGLIUCA: You are not going to17 allow a break.18 MS. McCAWLEY: As soon as I get19 through my line of questioning, which is20 perfectly appropriate.21 Q. Did Emmy Taylor travel with you and22 Jeffrey to Europe?23 A. I'm sure she did.24 Q. What is she doing today?25 A. I have no idea. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 33 of 56 Questions About Outfits and Sex Toys Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 34 of 56Page 69 1 G Maxwell - Confidential 2 about.3 Q. So you didn't provide her with4 that?5 A. As I just testified, I have no idea6 what you are talking about.7 Q. I was trying to interpret whether8 you didn't understand what a school girl9 outfit was or you are saying that didn't 10 happen?11 A. I clearly know what a school girl12 outfit is. I have no recollection of13 providing anybody with a school girl outfit.14 Q. Did you have a set of outfits used15 by the massage therapists that would include16 things like a school girl outfit or a black17 patent leather outfit or anything of that18 nature?19 MR. PAGLIUCA: Object to the form20 and foundation.21 A. That would be just another one of22 Virginia's lies.23 Q. You didn't have anything like that?24 A. I did not.25 Q. Did you have a basket of sex toys MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 35 of 56Page 70 1 G Maxwell - Confidential 2 that you kept in the Palm Beach house?3 MR. PAGLIUCA: Objection to the4 form and foundation.5 A. First of all what do you mean.6 Q. A laundry basket that contained sex7 toys in it?8 MR. PAGLIUCA: Objection to the9 form and foundation. 10 A. Can you ask the question again?11 Q. Did you have a laundry basket that12 contained sex toys in it, in the Palm Beach13 House?14 MR. PAGLIUCA: Objection to the15 form and foundation.16 Q. Did you have a laundry basket of17 sex toys in the Palm Beach house?18 MR. PAGLIUCA: Same objection.19 Q. You can answer.20 A. I don't recollect anything about a21 laundry basket of sex toys.22 Q. Do you recollect having sex toys at23 the Palm Beach house?24 A. You have to define what are you25 talking about. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 36 of 56 Questions About Plaintiff and Epstein and Sex Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 37 of 56Page 75 1 G Maxwell - Confidential 2 Q. Do you recall having a basket full3 of sex toys?4 A. I already told you I did not.5 Q. We were talking a moment ago about6 Ms. Roberts and her position as a masseuse,7 do you know what she was paid for working as8 a masseuse for Jeffrey Epstein?9 A. I do not. 10 Q. Did you ever pay her?11 A. I don't ever recall paying her.12 Q. Do you know what happened during13 the massage appointments with Jeffrey Epstein14 and Virginia Roberts?15 MR. PAGLIUCA: Objection to the16 form and foundation.17 A. No.18 Q. Were you ever present to view a19 massage between Jeffrey Epstein and Virginia20 Roberts?21 A. I don't recollect ever seeing22 Virginia and Jeffrey in a massage situation.23 Q. Do you ever recollect seeing them24 in a sexual situation?25 A. I never saw them in a sexual MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 38 of 56Page 76 1 G Maxwell - Confidential 2 situation.3 Q. Did you ever participate in sex4 with Virginia Roberts and Jeffrey Epstein?5 A. I never ever at any single time at6 any point ever at all participated in7 anything with Virginia and Jeffrey. And for8 the record, she is an absolute total liar and9 you all know she lied on multiple things and 10 that is just one other disgusting thing she11 added.12 Q. Did you help her obtain an13 apartment in Palm Beach to live in?14 MR. PAGLIUCA: Objection to the15 form and foundation.16 Q. Was that part of your17 responsibilities for Jeffrey?18 A. First of all, I didn't know she had19 an apartment in Palm Beach. I only learned20 that from the many times you guys have gone21 to the press to sell stories, so no.22 Q. Did you help her get a cell phone,23 was that one of your responsibilities for24 Jeffrey, to get her is a cell phone as part25 of her masseuse obligations? MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 39 of 56 Questions About Training Plaintiff to Recruit Girls for Massages Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 40 of 56Page 81 1 G Maxwell - Confidential 2 form and foundation.3 A. Like I told you, I don't recall her4 being at the house at all.5 Q. How many homes does Jeffrey have?6 MR. PAGLIUCA: Objection to the7 form and foundation.8 A. When I was working for him, I think9 he had six maybe. 10 Q. Would Virginia stay with him in11 those homes?12 MR. PAGLIUCA: Objection to the13 form and foundation.14 A. I can only testify for when I was15 present with him and I cannot say what she16 did when I wasn't present with him.17 Q. When you were present, would18 Virginia stay in the homes with him?19 A. I don't recall her staying in the20 houses.21 Q. Did you train Virginia on how to22 recruit other girls for massages?23 MR. PAGLIUCA: Objection to the24 form and foundation.25 A. No. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 41 of 56Page 82 1 G Maxwell - Confidential 2 Q. Did you train Virginia on how to3 recruit other girls to perform sexual4 massages?5 MR. PAGLIUCA: Objection to the6 form and foundation.7 A. No. And it's absurd and her entire8 story is one giant tissue of lies and9 furthermore, she herself has -- if she says 10 that, you have to ask her about what she did.11 Q. Does Jeffrey like to have his12 nipples pinched during sexual encounters?13 MR. PAGLIUCA: Objection to form14 and foundation.15 A. I'm not referring to any advice on16 my counsel. I'm not talking about any adult17 sexual things when I was with him.18 Q. When Jeffrey would have a massage,19 would he request that the masseuse pinch his20 nipples while he was having a massage?21 A. I'm not talking about anything with22 consensual adult situation.23 Q. What about with underage --24 A. I am not aware of anything.25 Q. You are not aware of Jeffrey MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 42 of 56 Questions About Ms. Maxwell’s Relationship with Mr. Epstein Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 43 of 56Page 91 1 G Maxwell - Confidential 2 has perpetrated, cannot tell you what is true3 or factual or not.4 Q. You said you were in the home a5 very limited time, so average in the year for6 example, 2004, how many times would you have7 been in his Palm Beach home?8 A. Very hard for me to state but very9 little. 10 Q. How about his New York home?11 A. Same.12 Q. Were you his girlfriend in that13 year, in 2004?14 A. Define what you mean by girlfriend.15 Q. Were you in a relationship with him16 where you would consider yourself his17 girlfriend?18 A. No.19 Q. Did you ever consider yourself his20 girlfriend?21 A. That's a tricky question. There22 were times when I would have liked to think23 of myself as his girlfriend.24 Q. When would that have been?25 A. Probably in the early '90s. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 44 of 56 Questions About Recruiting Girls, an Underage Girl in London, and Foreign Girls Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 45 of 56Page 97 1 G Maxwell - Confidential 2 A. First of all I resent and despise3 the world recruit. Would you like to define4 what you mean by recruit and by girls, you5 mean underage people. I never had to do6 anything with underage people. So why don't7 you reask the question in a way that I am8 able to answer it.9 Q. I'm asking if you ever said that to 10 anybody. So if you don't understand the word11 recruit and you never used that word then the12 answer to that question would be no.13 A. I have no memory as I sit here14 today having used that word.15 Q. Did you ever meet an underage girl16 in London to introduce her to Jeffrey to17 provide him with a massage?18 MR. PAGLIUCA: Objection to the19 form and foundation.20 A. Run that past me one more time.21 Q. Did you ever meet an underage girl22 in London to introduce her to Jeffrey to23 perform a massage?24 MR. PAGLIUCA: Same objection.25 A. Are you asking me if I met anybody MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 46 of 56Page 98 1 G Maxwell - Confidential 2 that was underage in London specifically to3 provide a massage to Jeffrey, is that your4 question?5 Q. Yes.6 A. No.7 Q. Do you know who Alexander Dixon is?8 A. I don't recall her right now.9 Q. Do you know if -- strike that. 10 During the time that you were11 working for Jeffrey, did you ever observe any12 foreign females, so in other words, not from13 the United States, that were brought to14 Jeffrey's home to perform massages?15 MR. PAGLIUCA: Objection to the16 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 working21 for Jeffrey, did you ever observe any foreign22 females of any age that were at Jeffrey's23 home to perform a massage?24 MR. PAGLIUCA: Objection to the25 form and foundation. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 47 of 56Page 99 1 G Maxwell - Confidential 2 A. Are you asking me if any foreigner,3 not an American person, gave Jeffrey a4 massage?5 Q. Yes.6 A. Well, as I sit here today, I can't7 think of anyone who is foreign. Certainly --8 I just can't think of anybody right this9 second. 10 Q. How about any foreign girls who11 were under the age of 18?12 A. I already testified to not knowing13 anything about underage girls.14 Q. Were there foreign girls who were15 brought to Jeffrey's home by Jean Luc Brunel16 for the purposes of providing massages?17 MR. PAGLIUCA: Objection to the18 form and foundation.19 A. I am not aware of Jean Luc bringing20 girls. I have not no idea what you are21 talking about.22 Q. You have never been around foreign23 girls who are under the age of 18 at24 Jeffrey's homes?25 MR. PAGLIUCA: Objection to the MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 48 of 56Page 100 1 G Maxwell - Confidential 2 form and foundation.3 A. I already testified about not4 knowing about underage girls.5 Q. Did you provide any assistance with6 obtaining visas for foreign girls that were7 under the age of 18?8 A. I've never participated in helping9 people of any age to get visas. 10 Q. Did Jeffrey, was it Jeffrey's11 preference to start a massage with sex?12 MR. PAGLIUCA: Objection to the13 form and foundation.14 A. I think you should ask that15 question of Jeffrey.16 Q. Do you know?17 A. I don't believe that was his18 preference. I think -- you have to19 understand, a massage -- perhaps you are not20 really familiar with what massage is.21 Q. I am, I don't need a lecture on22 massage.23 A. I think you do.24 MR. PAGLIUCA: No question pending.25 She will ask you another question now. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 49 of 56 Questions About Underage Girls, Sex with Jon Luc Brunel, and Outfits Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 50 of 56Page 116 1 G Maxwell - Confidential 2 Q. Were you present on the island when3 Prince Andrew visited?4 A. Yes.5 Q. How many times?6 A. I can only remember once.7 Q. Were there any girls under the age8 of 18 on the island during that one visit9 that you remember that were not family or 10 friends of or daughters of your friends?11 MR. PAGLIUCA: Objection to the12 form and foundation.13 A. There were no girls on the island14 at all. No girls, no women, other than the15 staff who work at the house. Girls meaning,16 I assume you are asking underage, but there17 was nobody female outside of the cooks and18 the cleaners.19 Q. Did you, as part of your duties in20 working for Jeffrey, ever arrange for21 Virginia to have sex with John Luc Brunel?22 MR. PAGLIUCA: Objection to the23 form and foundation.24 A. Just for the record, I have never25 at any time, at anyplace, in any moment ever MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 51 of 56Page 117 1 G Maxwell - Confidential 2 asked Virginia Roberts or whatever she is3 called now to have sex with anybody.4 Q. Did you ever provide Virginia5 Roberts with an outfit, an outfit of a sexual6 nature to wear for Les Wexner?7 MR. PAGLIUCA: Objection to the8 form and foundation.9 A. I think we addressed the outfit 10 issue.11 Q. I am asking you if you ever12 provided her with an outfit of a sexual13 nature to wear for Les Wexner?14 A. Categorically no. You did get15 that, I said categorically no16 Q. Don't worry I'm paying attention.17 A. You seemed very distracted in that18 moment.19 (Maxwell Exhibit 6, flight logs,20 marked for identification.)21 A. Do you mind if I take a break for22 the bathroom.23 Q. It's 11:08 and we are going to go24 off the record now.25 THE VIDEOGRAPHER: It's now 11:09. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 52 of 56 Questions About Pictures of Naked Girls Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 53 of 56Page 188 1 G Maxwell - Confidential 2 people could use -- just like you would use3 if you needed to go online to get something,4 that people could use.5 Q. Was that on a desk that you would6 use in your work capacity when you were at7 the house?8 A. It was a desk, it was a room I was,9 I didn't really use that computer. 10 Q. Were there images of naked girls11 whether they be under the age of 18 or over12 the age of 18 on that computer?13 A. I have no recollection of any naked14 people on that computer when I was there in15 2003, we are talking.16 Q. What about from say '99 to 2003?17 A. No, I can't recollect any naked18 pictures.19 Q. Why were the computers removed from20 the house before the search warrant was21 executed?22 MR. PAGLIUCA: Objection to the23 form and foundation.24 A. I have no knowledge of anything25 like that. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 54 of 56 Questions About Topless Females Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 55 of 56Page 404 1 G Maxwell - Confidential 2 form and foundation.3 A. I mean I've been to his -- in the4 mid '90s, I would have communicated with5 people who worked for him.6 Q. Have you communicated with Leslie7 Wexner about this case?8 A. No.9 Q. Have you ever seen a topless female 10 at any one of Jeffrey Epstein's properties?11 MR. PAGLIUCA: Objection to the12 form and foundation. You've asked this13 question, by the way, earlier on today.14 A. Again, I testified that there are15 people who from time to time in the privacy16 of a swimming pool have maybe taken a bikini17 top off or something but it's not common and18 certainly when I was at the house I don't19 really recollect seeing that kind of20 activity.21 Q. Have you ever smoked cigarettes?22 A. Yes.23 Q. Have you ever smoked cigarettes24 with Virginia Roberts?25 A. I don't recall smoking cigarettes MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-5 Filed 01/03/24 Page 56 of 56 ------------------------------------------------------------- gov.uscourts.nysd.447706.1320.6.pdf 10 pages 1United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this Reply in Support of her Motion to Compel Defendant to Answer Deposition Questions. Instead of allowing Ms. Giuffre to take a full and complete deposition, Defendant flatly refused to answer questions critical to the key issues in this case. Contrary to Defendant’s assertions, Ms. Giuffre is not engaged in a “fishing expedition” but rather seeks to ask highly-focused questions specifically relevant to this case. In particular, Ms. Giuffre seeks to ask the Defendant questions regarding her participation in or knowledge of sexual activities connected with Jeffrey Epstein’s sexual abuse of females. Such questions are entirely appropriate in the discovery phase of this case, particularly where any answers will be maintained as confidential under the Protective Order entered in this case. As the Court is aware from previous pleadings, at the heart of this case lies the issue of Defendant’s knowledge that Ms. Giuffre was sexually abused by Jeffrey Epstein. Indeed, as the Defendant boldly acknowledges in her response (at p. 2), she intends to argue at trial that (among other things) she “never arranged for or asked [Ms. Giuffre] to have sex with anyone.” At trial, -2Ms. Giuffre intends to strongly disprove Defendant’s false assertions and to demonstrate that Defendant recruited Ms. Giuffre to be involved in massages of a sexual nature with Epstein. To develop evidence to support her position, Ms. Giuffre recently deposed Defendant about the central subjects in her case. Defendant flatly refused to answer a number of questions, and for the majority of the others, gave varying versions of “I don’t recall.” For example, when faced with the police report which contains statements from approximately thirty (30) different victims during a time frame which the Defendant acknowledges she was actively working for Epstein at his various homes, Defendant challenged the veracity of the victims’ reports: “Q. Are you saying these 30 girls are lying when they gave these reports to police officers? A. I’m not testifying to their lies. I’m testifying to Virginia’s lies.” SeeDeclaration of Sigrid McCawley (“McCawley Decl.”) at Exhibit 1, April 22, 2016 Deposition of Defendant at p. 89-90; 83-84. While Defendant was working with Epstein during the time period when these underage girls were visiting Jeffrey’s home, Defendant claimed to be at the house maybe once in 2005. Id.at p. 84. Yet, according to flight manifests, in that same general time period, Defendant was listed as a passenger at least eleven times either landing in or departing from West Palm Beach, Florida on Jeffrey Epstein’s private plane. SeeMcCawley Decl. at Exhibit 1, April 22, 2016 Depo Tr. at p. 84; see also McCawley Decl. at Composite Exhibit 2, Flight Logs from Jeffrey Epstein’s private planes. Moreover, again according to flight logs, Defendant was on Epstein’s planes over 300 times – including 23 times with Ms. Giuffre when Ms. Giuffre was underage. Yet, quite remarkably, Defendant claimed she “couldn’t recall” even one of those flights. SeeMcCawley Decl. at Exhibit 1, April 22, 2016 Deposition of Defendant at p. 120-122. 3Defendant even testified that she did not recall having Ms. Giuffre at her London townhome with Prince Andrew. Defendant stuck to this incredible story despite flight logs establishing her traveling to London with Ms. Giuffre and despite a photograph the three – Ms. Giuffre, Prince Andrew and Defendant – all standing together in Defendant’s home. See McCawley Decl. at Exhibit 1, April 22, 2016 Deposition of Defendant at p. 108-111. Defendant’s deposition consisted almost entirely of “I don’t recalls” or “I refuse to answer that question”1and also included a physical outburst that knocked the court reporter’s computer off the conference room table. SeeMcCawley Decl. at Exhibit 1, April 22, 2016 Deposition of Defendant at 207-208. Among the many questions that Defendant refused to answer at her deposition were a number of questions designed to show that Defendant was well aware that, for Epstein, a “massage” was actually a code word sexual activity – i.e., not a therapeutic massage but rather activity that involved sexual gratification for Epstein. Defendant refused to answer all such questions, asserting that they involved “private adult sexual relationships” which did not “relate in any way” to Ms. Giuffre’s claims. Id. at p. 4. But Defendant’s involvement in such “relationships” with Epstein would show that she knew full well the fate that was in store for Ms. Giuffre when she accepted Defendant’s invitation to come and provide “massages” to Epstein. Defendant admitted that she worked for Epstein from 1992 to 2009. SeeMcCawley Decl. at 1For example, when asked: “Q. Have you ever said to anybody that you recruit girls to take the pressure off you, so you won’t have to have sex with Jeffrey, have you said that? A. You don’t ask me questions like that. First of all, you are trying to trap me, I will not be trapped. You are asking me if I recruit. I told you no. Girls meaning underage, I already said I don’t do that with underage people and as to ask me about a specific conversation I had with language, we talking about almost 17 years ago when this took place. I cannot testify to an actual conversation or language that I used with anybody at any time.” SeeMcCawley Decl. at Exhibit 1, April 22, 2016 Depo Tr. at p. 94-95.4Exhibit 1, April 22, 2016 Deposition of Defendant at p. 10-11, 410. As the Court knows, the Palm Beach Police Report demonstrates multiple incidents of “massages” being given by untrained minor children that involved sexual acts. SeeMcCawley Decl. at Exhibit 3, Palm Beach Police Report. Defendant is also identified in that Palm Beach Police Report. See McCawley Decl. at Exhibit 3, Palm Beach Police Report at p. 75-76. And the details of Epstein’s sexual activities with Defendant (for example) are highly relevant to this case, because they will help corroborate Ms. Giuffre’s testimony that, while she was underage, she also engaged in sexual activity of an identical nature with Epstein. To allow Defendant to avoid answering these questions would preclude Ms. Giuffre from getting critical evidence in this case. Consider, for example, Defendant recruiting an eighteen year-old girl to be an “assistant,” bringing that girl to Epstein’s home, telling her she could make more money if she would give Epstein a massage, and then instructing her to give a massage that involved sexual acts. Under Defendant’s theory of discovery, Ms. Giuffre would be precluded from deposing her on that topic because the actions would culminate in “consensual adult sex.” Yet, that scenario would fully validate the pattern of events that occurred with Ms. Giuffre when she was under the age of eighteen. It would obviously show a “modus operandi” by Jeffrey Epstein and Defendant, which is clearly admissible under Fed. R. Evid. 404(b). Moreover, such inquiries are crucial to impeaching the Defendant at trial. During her deposition, Defendant attempted to characterize her work for Epstein as nothing more than a normal job handling hiring for the various mansions. SeeMcCawley Decl. at Exhibit 1, April 22, 2016 Deposition Tr. of Defendant at p. 9-12. Ms. Giuffre should be able to contest that assertion by having Defendant fully answer questions about whether that alleged “job” involved 5sexual activities, including orchestrating the hiring of females and converting massages into sexual encounters. Defendant attempts to paint the picture that Ms. Giuffre somehow is interested in all sexual relationships that the Defendant may have been involved with. That is not true. Ms. Giuffre has no intention of asking unbridled questions. To be clear, Ms. Giuffre intends to ask Defendant only questions that involve the following very narrow and crucial subject areas: (1) Defendant’s sexual relationship with Epstein from 1992 to 2009 – the time period in which she worked for Jeffrey Epstein and which Epstein (with the assistance of Defendant) was engaging in sexual acts with females under the cover of “massage”; (2) Defendant’s sexual interactions with any person in Epstein’s presence during that time period; (3) Defendant’s sexual activities at Epstein’s residences, including his private island “Little St. Jeff’s,” or his aircraft during that time period; (4) Defendant’s sexual activities with identified participants in Epstein’s sexual abuse during that time period; and (5) Defendant’s sexual interactions that occurred during or through what began as a “massage”; and (6) Defendant’s interactions with females to introduce to Jeffrey Epstein for the purpose of performing work, including sexual massages. Defendant claims that such questions are a mere “fishing expedition” without acknowledging the fact that these questions go to critical issues in this case. Other witnesses have testified regarding Defendant’s involvement in recruiting females for sex under the cover of a “massage.” During the investigation of Jeffrey Epstein, certain household staff was deposed. Alfredo Rodriguez, who was Jeffrey Epstein’s household manager, testified that the Defendant frequently stayed in Jeffrey Epstein’s home and assisted with bringing in young girls to act as “masseuses” for Jeffrey Epstein. Q. “Okay. Going back to where we started here was, does Ghislaine Maxwell have knowledge of the girls that would come over to Jeffrey Epstein’s house that are in 6roughly the same age group as C. and T. (minor children) and to have a good time as you put it? A. Yes. Q. And what was her involvement and/or knowledge about that? A. She knew what was going on.” See McCawley Decl. at Exhibit 4, Alfredo Rodriguez July 29, 2009 Dep. Tr. at 176-177. See also McCawley Decl. at Exhibit 4, Alfredo Rodriguez July 29, 2009 Depo Tr. at 96-101 (noting that high school age girls come to the home where Jeffrey Epstein and Ms. Maxwell reside). Juan Alessi, another household employee, also testified that young girls were regularly present at Jeffrey Epstein’s home where Ghislaine Maxwell resides. See McCawley Decl. at Exhibit 5, Juan Alessi November 21, 2005 Sworn Statement at p. 15-16, 21. Specifically, Juan Alessi informed the Palm Beach Police Detective as follows: “Alessi stated that towards the end of his employment, the masseuses were younger and younger. When asked how young, Mr. Alessi stated they appeared to be sixteen or seventeen years of age at most .” (emphasis added.) See McCawley Decl. at Exhibit 3, Palm Beach Police Report at p. 57. During Juan Alessi’s November 21, 2005 Sworn Statement taken by the Palm Beach Police Department, Mr. Alessi revealed that girls would come over to give “massages” and he observed Ms. Maxwell going upstairs in the direction of the bedroom quarters. SeeMcCawley Decl. at Exhibit 5, Juan Alessi November 21, 2005 Sworn Statement at 10. He also testified that after the massages, he would clean up sex toys that were kept in “Ms. Maxwell’s closet.” Id. at 11-13. See also McCawley Decl. at Exhibit 6, Juan Alessi September 8, 2009 Depo Tr. at p. 76- 77. He added that he and his wife were concerned with what was going on at the house ( Id.at 14) and that he observed girls at the house, including one named “Virginia.” Id.at 21. Mr. Rodriguez also testified that Defendant also had naked pictures of girls performing sexual acts on her computer. SeeMcCawley Decl. at Exhibit 7, Alfredo Rodriguez August 7, 2009 Dep. Tr. at 311-312; See also McCawley Decl. at Exhibit 6, Juan Alessi September 8, 2009 7Depo Tr. at p. 40-41 (“I know she [Maxwell] went out and took pictures in the pool because later on I would see them at the desk or at the house. And nude - 99.9 percent of the time they were topless. They were European girls.”). Q. “Did they appear to be doing any sexual? A. Yes, ma’am. Q. And in these instances were there girls doing sexual things with other girls? A. Yes, ma’am. Q. And I’m still talking about the pictures on Ms. Maxwell’s computer. A. Yes, ma’am.” Upon leaving his employment, Rodriguez testified that Defendant threatened him that he should not tell anyone about what happened at the house: A. “I have to say something. Mrs. Maxwell called me and told me not to ever discuss or contact her again in a threaten(ing) way. Q. When was this? A. Right after I left because I call one of the friends for a job and she told me this, but, you know, I feel intimidated and so I want to keep her out… Q. She made a telephone call to you and what precisely did she say? A. She said I forbid you that you’re going to be – that I will be sorry if I contact any of her friends again…She said something like don’t open your mouth or something like that. I’m a civil humble, I came as an immigra nt to service people, and right now you feel a little –I’m 55 and I’m afraid. First of all, I don’t have a job, but I’m glad this is on tape because I don’t want nothing to happen to me. This is the way they treat you, better do this and you shut up and don’t talk to nobody and— Q. When you say this is the way they treat, who specifically are you talking about when you say that word they? A. Maxwell. ” See McCawley Decl. at Exhibit 4, Alfredo Rodriguez July 29, 2009 Dep. Tr. at 169 – 172. In sum, at the core of this case are statements made by Ms. Giuffre that she was recruited, by Defendant, to be paid as a masseuse, yet was enticed or coerced into engaging in sexual acts with Epstein and Defendant for money. She has further explained that the recruitment of females through the offer of some legitimate position was the typical way in which Defendant and Epstein lured unsuspecting females to the house before converting the relationship into a sexual 8one. Ms. Giuffre has described the frequency of these “massages”, the sexual tendencies of the participants, the manner in which the massages became sexual in nature, and Defendant’s role at each stage. In response, Defendant has called Ms. Giuffre’s entire account “untrue” and “obvious lies.” Defendant has instead tried to portray her role as nothing more than an Epstein employee performing typical household management duties. Any personal knowledge Defendant has of Epstein’s sexual tendencies, habits, and use of massage for sex is entirely relevant to either corroborate Ms. Giuffre’s account. Likewise, Defendant’s participation in any sexual acts with Epstein, in his presence, on his properties, using his mode of converting massages into sex, or with females will directly corroborate Ms. Giuffre’s account. On the other hand, without access to the answers to these inquiries, Ms. Giuffre will be unable to expose the bias of Defendant, unable to thoroughly cross-examine Defendant’s position that she was just a lowly employee, and most importantly unable to demonstrate through the Defendant’s own admissions that Ms. Giuffre’s statements about Epstein and Defendant were absolutely true – and not “obvious lies.” Finally, Defendant fails to recognize that, for the discovery purposes at issue here, relevance “is an extremely broad concept.” Am. Fed'n of Musicians of the United States & Canada v. Sony Music Entm't, Inc. , No. 15CV05249GBDBCM, 2016 WL 2609307, at *3 (S.D.N.Y. Apr. 29, 2016). And once relevance is shown, “the party resisting discovery bears the burden of demonstrating that, despite the broad and liberal construction afforded the federal discovery rules, the requests are irrelevant, or are overly broad, burdensome, or oppressive.” Id. Here, the requests are not “overly broad” as Ms. Giuffre’s specific explanations of the targets of her questions make clear. Moreover, answering the questions is not “oppressive,” particularly given the fact that Defendant has placed allsubstantive aspects of the Deposition under seal. Of -9course, once Defendant answers the question – and her answers are placed under seal – the parties can file any further motions that may be required to determine whether the answers may be introduced at trial. CONCLUSION Defendant should be ordered to answer questions regarding sexual activity connected with Epstein’s sexual abuse and sexual trafficking organization as specifically identified above Dated: May 11, 2016 Respectfully Submitted,BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice)Boies Schiller & Flexner LLP401 E. Las Olas Blvd., Suite 1200Ft. Lauderdale, FL 33301(954) 356-0011 David Boies Boies Schiller & Flexner LLP333 Main StreetArmonk, NY 10504 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING,EDWARDS, FISTOS & LEHRMAN, P.L.425 North Andrews Avenue, Suite 2Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of LawUniversity of Utah383 University St.Salt Lake City, UT 84112(801) 585-5202 2 2This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation.10CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 11th day of May, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq.HADDON, MORGAN & FOREMAN, P.C.150 East 10 thAvenue Denver, Colorado 80203Tel: (303) 831-7364Fax: (303) 832-2628Email : lmenninger@hmflaw.com jpagliuca@hmflaw.com /s/ Sigrid S. McCawley Sigrid S. McCawley ------------------------------------------------------------- gov.uscourts.nysd.447706.1320.7.pdf 9 pages EXHIBIT 4Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 1 of 91 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 ?n 21 22 23 24 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Case No: 08-CV-80119 Plaintiff, Vs JEFFREY EPSTEIN, Defendant . I JANE DOE NO. 3 / Case NO: 08-CV-80232 Plaintiff, Vs JEFFREY EPSTEIN, Defendant. I JANE DOE NO. 4, Case No: 08-CV-80380 Plaintiff, Vs. JEFFREY EPSTEIN, Defendant . I JANE DOE NO. 5, Case No: 08-CV-80381 Pl;:i-intiff Vs JEFFREY EPSTEIN, Defendant. I Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 Page 1 NON PARTY (VR) 000247 GIUFFRE00093 5 Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 2 of 9I 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 . l'age 2 JANE DOE NO. 6, Case No: 08-CV-80994 1 V[DEOTAPED Plaintiff1 2 DEPOSITION Vs 3 of JEFFREY EPSTEIN, 4 ALFREDO RODRIGUEZ Defendan t. s 6 taken on behalf of the Plaintiffs pursuant 7 to a Re-Notice of Taking Deposition (Duces Tecum) JANE DOE NO. 7, Case No. 08-CV-80993 8 9 --- Plaintiff, 10 APPEARAN CES: 11 Vs MERMELSTEIN & HOROWIT Z, P.A. JEFFREY EPSTEIN, 12 BY: STUART MERMELSTE IN, ESQ. 18205 Biscayne Boulevard Defendant. 13 Suite 2218 Miami, Florida 33160 CM.A., Case No: 08-CV-80811 14 Attorney for Jane Doe 2, 3, 4, 5, Plaintiff, 6, and 7. Vs 15 JEFFREY EPSTEIN, 16 ROTHSTEIN ROSENFELDT ADLER Defendant. BY: BRAD J. EDWARDS, ESQ., and 17 CARA HOLMES, ESQ. Las Olas City Centre JANE DOE, Case No: 08-CV-80893 18 Suite 1650 401 East Las Olas Boulevard Plaintiff, 19 Fort Lauderdale, Florida 33301 Attorney for Jane Doe and E.W. Vs 20 And L.M. 21 JEFFREY EPSTEIN, PODHURST ORSECK 22 BY: KATHERINE W. EZELL Defendant. 25 West Flagler Street 23 Suite 800 Miami, Florida 33130 24 Attorney for Jane Doe 101 and 102. 25 Page 3 JANE DOE NO. II, Case No: 08-CV-8 0469 1 Plaintiff, APPEARANC ES: Vs 2 JEFFREY EPSTEIN, 3 LEOPOLD-KUVJN Defendant. ADAM J. LANGINO, ESQ. 4 2925 PGA Boulevard Suite 200 5 Palm Beach Gardens, Florida 33410 JANE DOE NO. 101, Case No: 09-CV-80591 Attorney for 8.B. 6 Plaintiff, 7 RICHARD WILLITS, ESQ. 2290 10th Avenue North Vs 8 Suite 404 Lake Worth, Florida 33461 JEFFREY EPSTEIN, 9 Attorney for C.M.A. 10 BURMAN, CRJTTON, LUTTIER & Defendant. 11 COLEMAN, LLP BY: ROBERT CRJTTON, ESQ. JANE DOE NO. 102, Case No: 09-CV-80656 12 515 North Flagler Drive Plaintiff, Suite 400 Vs 13 West Palm Beach, Florida 3340 l JEFFREY EPSTEIN, Attorney for Jeffrey Epstein. Defendant. 14 15 I 16 ALSO PRESENT: 17 JOE LANGSAM, V!DEOGRAPHER 1031 Ives Dairy Road 18 Suite 228 19 North Miami, Florida July 29, 2009 20 11:00 a.m. to 5:30 p.m. 21 22 23 24 25 ' .... .. . , .. .. ' ..;:-, .... :;;,;. "' = Kress Court Reporting, Inc. 305-866- 7688 7115 Rue Notre Dame, Miami Beach, FL 33141 Page 4 Page 5 , "• ' ' 2 (Pages 2 to 5) NON PARTY (VR) 000248 GIUFFRE000936 Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 3 of 9Page 94 A. I don't remember, sir. 1 2 3 Q. The next page is a message in the upper lelt dated January 13, 2005, from C.W. Correct? 4 A. Yes. 5 Q. That's the same C. that we've been 6 talking about. Correct? 7 A. Yes. 8 Q. That was at 7:30 p.m. Correct? 9 A. Yes. 10 Q. And you don't recall what that particular 11 call was about. Right? 12 A. No, sir. 13 Q. The message dated January 20, 2005, from 14 Maria. Do you see that on the bottom right? 15 A. Yes. 16 Q. Do you know who that is? 17 A. I think I have a different page. 18 Q. You're a little ahead of me. January 20, 19 2005. 20 MR. CRITTON: I think that's page 31. 21 THE WITNESS: I don't remember who she 22 23 24 25 1 2 3 was, sir. BY MR. MERMELSTEIN: Q. You don't recall what that message was about? Page 95 A. No, sir. Q. What about the next page there is a message that Eva called? 4 A. Yes. 5 Q. Dated January 21, 2005? 6 A. Yes. 7 Q. Do you know who Eva is? 8 A. Yes. 9 Q. Who is Eva? 10 A. The assistant comptroller from the New 11 York office. 12 Q. Do you remember her last name? 13 A. Polish last name I guess. She was 14 Russian. She is Russian actually. 15 Q. Did you ever travel to any other 16 residences that Mr. Epstein had? 17 A. No. 18 19 20 21 22 23 24 25 Q. Are you aware he had a residence in the Virgin Islands? MR. CRITTON: Form. THE WITNESS : Yes. BY MR. MERMELSTEIN : Q. And would he sometimes travel to that residence from Palm Beach? A. Yes. 1 2 3 4 5 Page 96 Q. Okay. Do you recall on any occasion who would travel with him to the Virgin Islands? MR. CRITTON: Form. THE WITNESS: No, sir. BY MR. MERMELSTEIN: 6 Q. I think we were talking about the money 7 before, the household account, sometimes you gave 8 gilts? 9 A. Yes, I was told to buy some gifts. 10 Q. Forwhom? 11 A. For the guests. 12 Q. Okay. And what kind of gifts? 13 A. Shoes, sweaters, clothes. 14 Q. So were you instructed to buy something 15 in particular at a particular store? 16 A. They would go to the store, if they like 17 something I will go alter and pay them and 18 retrieve it. 19 Q. Okay. So would this be a girl who was 20 staying at the house? 21 A. Yes. 22 Q. Okay. This was one of the girls who 23 travelled with Mr. Epstein to Palm Beach. 24 Correct? 25 A. Yes. 1 2 3 4 5 6 7 8 Page 97 Q. And so Mr. Epstein would instruct you to go shopping with this girl? A. Yes. Q. And instructed you to pay for whatever it is she wanted to buy? A. Yes. Q. Was there a price limit or anything of that nature? 9 A. No, sir. 10 Q. So when the girl decided what she wanted 11 you would -- 12 A. I would write them a check. 13 Q. In that instance you would pay by check? 14 A. Yes. 15 Q. Any other instances where you gave gilts 16 to girls at the instruction of Mr. Epstein? 1/ f'\, i,u, 1 vvu.:, ,~~-,~,~, ,~~ "•~ , , .. ~, 18 told me I will buy the item. 19 Q. I'm sorry? 20 A. You know, when I was told to purchase 21 this item for them, you know, I will do that, but 22 not on any other occasions . 23 Q. What do you mean not in any locations? 24 A. Any other occasions. 25 Q. Not any other occasions. Okay. Did you 25 (Pages 94 to 97) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000271 GIUFFRE000959 Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 4 of 9Page 98 ever buy flowers for a girl? A. Yes, sir. Q. Tell me about that. 1 2 3 4 5 6 7 8 9 A. I was told to buy flowers and roses for a 10 11 12 13 14 girl performing in high school. Q. Which girl was that? A. I don't remember the name, sir. Q. What was Mr. Epstein's relationship to this girl? MR. CRITTON: Form. THE WITNESS: I think she was an acquaintance, friend. BY MR. MERMELSTEIN: Q. She was a friend? 15 A. Yes, sir. 16 Q. Now, she was performing at the high 17 school in what capacity? 18 A. There was like a --like a play in the 19 graduation for high school. 20 Q. A play for graduation? 21 A. Yes, in the high school theatre there was 22 some kind of performance . 23 Q. Was it like a theatre production? 24 A. Yeah, something like that. I didn't go 25 inside so I didn't know what was going on inside. Page 99 1 Q. Why do you say it was for graduation? 2 A. Because everybody was the graduation 3 outside, there were parents, there were a lot of 4 people at the school. 5 Q. Okay. A lot of high schools have theatre 6 production companies and they put on plays. 7 Correct? 8 MR. CRITTON: Form. 9 THE WITNESS: It was towards the end of 10 the year. Well, I think I overheard that 11 there was a graduation performance of some 12 kind. 13 BY MR. MERMELSTEIN: 14 Q. But you didn't go in so you don't know? 15 A. No, sir. 16 Q. But this was a high school student you 11 were bringing me nowers w. 1s L11aL '-V" t:L.l. 18 A. Yes. 19 Q. Had you seen this girl before at the El 20 Brillo Way property? 21 A. Yes, sir. 22 Q. You had seen her a number of times? 23 A. Yes, sir. 24 Q. Do you recall her name? 25 A. I don't remember her name, sir. 1 2 Page 100 Q. Now, you said you never went inside the theatre? 3 A. No, sir. 4 Q. Okay. How did you get to the flower 5 store? 6 A. I called the girl to her cell and she 7 will come to the back door and I give her the 8 flowers. 9 Q. Was anyone else around at the time? 10 A. No, sir. 11 Q. And you mentioned this was a girl you had 12 seen before? 13 A. Yes. Q. Was this girl who had come to give massages to Mr. Epstein? MR. CRITTON: Form. 14 15 16 17 18 19 20 21 22 23 24 25 THE WITNESS: I don't know if she was doing massages but she was at the house. BY MR. MERMELSTEIN : Q. What would she have been there for? A. To visit him. Q. This was a high school girl who was coming to visit Mr. Epstein at the house? A. She came to the house, I open the door and I left, you know. Page 101 1 Q. Did you take her to the kitchen like you 2 did -- 3 A. Yes. 4 Q. So you brought her to the kitchen just 5 like you did for the girls who gave him massages. 6 Correct? 7 A. Yes, sir. 8 Q. Did you ever pay her? 9 A. I don't remember, sir, but probably I 10 did. 11 12 13 MR. CRITTON : Form, move to strike, speculation. BY MR. MERMELSTEIN: 14 Q. Why do you say you probably did? 15 A. Because I was the only one paying -- 16 well, not the only one but, you know, but chances - -J./ Ul,C 1 f-'OIU "'-' ~-• • -~• L -• ,_, •~-• -, 18 particular instance that I gave her money. 19 Q. Is it fair to say that the girls who came 20 to the Palm Beach residence, these are not the 21 girls who are staying there, the girls who came -- 22 were there to give massages. Correct? 23 MR. CRITTON: Form. 24 THE WITNESS : Yes. 25 BY MR. MERMELSTEIN: 26 (Pages 98 to 101) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000272 GIUFFRE00096 l Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 5 of 9Page 166 1 written down anywhere? 1 2 A. No. 2 3 Q. It's my understanding that C. and T. 3 4 either came to his house alone to visit with Mr. 4 5 Epstein or brought other girls in their age group 5 6 to Mr. Epstein. 6 7 Were you familiar with that type of 7 8 recruitment process of girls bringing other girls? 8 9 MR. CRITTON: Form. 9 10 THE WITNESS: Yes. 10 11 BY MR. EDWARDS: 11 12 Q. Can you tell me more about what you know 12 13 about girls bringing other girls that are 13 14 relatively the same age to come to Jeffrey 14 15 Epstein's house and to use your words, have a good 15 16 time? 16 17 MR. CRITTON: Form. 17 18 THE WITNESS: It's hard to know who they 18 19 knew. But I think that was --they feel 19 20 better themselves when they're in a group 20 21 than going by themselves, but I don't know 21 22 somebody recruiting. 22 23 BY MR. EDWARDS: 23 24 Q. Okay. And you've talked about, at least 24 25 referred to yourself I believe to the police and 25 Page 167 1 as well today as a human ATM machine. Right? 1 2 MR. CRITTON: Form. 2 3 THE WITNESS: Something like that. I was 3 4 supposed to carry cash at all times. 4 5 BY MR. EDWARDS: 5 6 Q. One of the primary reasons why you 6 7 carried cash was to pay the girls in this age 7 8 group of C. and T. for whatever happened at the 8 9 house. Right? 9 10 MR. CRITTON: Form. 10 THE WITNESS : Yes. 11 BY MR. EDWARDS: 12 Q. That's a fair statement. Right? 13 MR. CRITTON: Form. THE WITNESS : Yes. BY MR. EDWARDS: ay. n w ., example, would bring somebody else to the house, did you pay C. as well as whomever she brought to the house, pay them both1 A. No, I pay only one person. Q. Okay. My understanding, and tell me if this is wrong or you can corroborate this, is that Mr. Epstein would pay the girl that was actually performing whatever was happening in the room --Page 168 for now we'll call it a massage --as well as anybody who brought that person over to the house, they would both get paid cash. Are you familiar with that? MR. CRITTON: Form. THE WITNESS: No. BY MR. EDWARDS : Q. If C. brought another girl over to the house and C. stayed downstairs but this other girl went upstairs with Mr. Epstein, which one would you pay? A. I don't know because I was told who to pay. Q. And Sarah Kellen always told you? A. Sarah told me pay so and so. Q. So if we were going to ask anybody else about the exact method in terms of who would get paid and for what, who would the people be? I mean, other than Mr. Epstein who else could we ask these questions? A. Sarah. Q. Sarah Kellen? A. Yes. Q. She would know this? A. Yes. Page 169 Q. What about Ghislaine Maxwell? MR. CRITTON: Form. THE WITNESS: You're talking about the boss. I don't know. BY MR. EDWARDS: Q. To your knowledge was Ghislaine Maxwell aware of these girls that are in the age group of C. and T. coming to Jeffrey Epstein's house to have a good time? MR. CRITTON : Form. THE WITNESS : I have to say something. Mrs. Maxwell called me and told me not to ever discuss or contact her again in a threaten way. BY MR. EDWARDS: the friends for a job and she told me this, but, you know, I feel intimidated and so I want to keep her out. Q. What exactly did she say? First of all, was this a telephone call? A. Yes, she was in New York. Q. She called you on your cell phone? A. Yes. 43 (Pages 166 to 169) Kress Court Reporting, Inc. 305-866-7688 7115 Rue Notre Dame, Miami Beach, FL 33141 NON PARTY (VR) 000289 GIUFFRE000978 Case 1:15-cv-07433-LAP Document 1320-7 Filed 01/03/24 Page 6 of 91 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 8 9 Page 170 Q. Is this the cell phone that was issued to you by Mr. Epstein? A. No, it was my personal phone. I was already -- Q. Gone? A. Yeah, this is three, four months down the road. Q. So if you le~ in -- A. February, March --it was May or June. Q. Of 2005? A. Yes. Q. And you got a call from Ghislaine Maxwell out of the blue? A. Yes. Q. And do you know what prompted that telephone call? A. Because I contact somebody in New York to get a job. Q. Who was that person? A. I contact Jean-Luc and I contact Eva, the Swedish girl, she used to be very good friends with Mr. Epstein because she asked me she need somebody in New York. Q. What does Eva do? A. Eva was a model many years ago and he Page 171 married --Eva is the mother of the girl who was on the wall. Q. Who is on the wall of Mr. Epstein's house? A. Yeah. Q. All right. There is a younger girl model that's on the wall of Mr. Epstein's house and this lady Eva is her mother? A. Yes. 10 Q. And at some point in time you called her 11 in New York to get a job7 12 A. That's right. 13 Q. And you also called Jean-Luc Bernell? 14 That's his name. Right? 15 A. Jean-Luc, yeah, I don't remember his last 16 17 18 19 20 21 22 23 24 25 name. l,!. uoes mat sound ram111ar to you, Jean-Luc Bernell? A. Yeah. Q. What did Eva and/or Jean-Luc say about employing you7 A. No, they said they're going to find out and obviously the first thing they did was talk to Mrs. Maxwell. Q. She made a telephone call to you and what 1 precisely did she say? Page 172 i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 A. She said I forbid you that you're going to be --that I will be sorry if I contact any of her friends again. Q. Okay. Other than you will be sorry if you contact any of my friends again did she say anything else about what you know about Mr. Epstein and/or what goes on at his house? A. She said something like don't open your mouth or something like that. But you have to understand, I'm a civil humble, I came as an immigrant to service people, and right now you feel a little --I'm 55 and I'm afraid. First of all, I don't have a job, but I'm glad this is on tape because I don't want nothing to happen to me. This is the way they treat you, better do this and you shut up and don't talk to nobody and -- Q. When you say this is the way they treat, who specifically are you talking about when you say the word they? A. Maxwell. Q. And usually when you say the word they, you're not only talking about one person -- A. Wealthy people. Q. Are you also putting Jeffrey Epstein in Page 173 that category? MR. CRITTON: Form. THE WITNESS : I didn't talk to him directly most of the time. BY MR. EDWARDS : 6 Q. What's the reason why if you were his 7 head of security that you wouldn't have more 8 direct contact with him? Why is that? 9 MR. CRITTON: Form. 10 THE WITNESS: He wanted that way, you 11 know, so, yeah, I have to talk to Sarah, 12 Sarah is not available talk to Lesley in New 13 York. He didn't want to be disturbed . 14 BY MR. EDWARDS: 15 16 Q. Even while you were in the same house with him he still had other people you could talk 1/ i:o Oh